C:\Documents and Settings\pwright\Desktop\bpxam pufinal\BPXA MPU FinalPe rmit&SOB-Revision1.doc 

## DEPARTMENT OF ENVIRONMENTAL CONSERVATION

AIR QUALITY CONTROL OPERATING PERMIT

Permit No. 200TVP01 I ssue Date: April 14, 2003 Application No. 200 Expi ration Date: May 13, 2008 Revision 1: May 25, 2004

The Department of Environmental Conser vation, under the authority of AS 46.14 and 18 AAC 50, issues an operating permit to the Permittee, BP Exploration (Alaska) Inc. , for the operation of the Milne Point Production Facility

. This permit satisfies the obligation of the owner and operator to obtain an operating permit as set out in AS 46.14.130(b).

As set out in AS 46.14.120(c), the Permittee shall co mply with the terms and conditions of this operating permit.

All stationary source-specific terms and conditions of Air Qua lity Control Construction Permit No. 0073-AC023 and 200CP02 have been incorporated into this Operating Permit

. The reporting requirements in this Operating Permit also replace the repo rting requirements of Exhibit D of Air Quality Control Permit-to-Operate No. 9673-AA005

.
This Operating Permit becomes effective May 14, 2003.

John F. Kuterbach, Manager Air Permits ProgramPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 2 of 61 

## Table of Contents
List of Abbreviations Used in this Permit....................................................................................2 Section 1. Identification...................................................................................................... ..........2 Section 2. General Emission Information.....................................................................................2 Section 3. Source Inventory and Description ...............................................................................2 Section 4. Emission Fees ....................................................................................................... .......2 Section 5. Source-Specific Requirements.....................................................................................2 Fuel-Burning Equipment ......................................................................................................... ....2 Emission Units Subject to Federal New Sour ce Performance Standards (NSPS), Subpart A ....2 Storage Tanks Subject to NSPS Subpar t Kb, Emission Unit ID(s) 19 and 20 ............................2 Emission Units Subject to NSPS Subpart Dc, Emission Unit ID(s) 3 and 4...............................2 Turbines Subject to NSPS Subpart GG NO X Standard , Emission Unit ID(s) 1 and 2 ..............2 Emission unit Subject to Owner Requested Limit to Maintain the HAP-minor Status of the Facility ....................................................................................................................... ..................2 Emission units Subject to Owner Requested Li mits for Ambient Air Quality Protection ..........2 Heaters Subject to BACT Limits ................................................................................................. 2 Turbines Subject to BACT and PSD Avoidance Limits..............................................................2 Vents Subject to BACT Limits................................................................................................... .2 Fuel Consumption Monitoring.................................................................................................... .2 Hours of Operation Monitoring for Fuel-fired Emission units....................................................2 Section 6. Visible Emissions and PM Monitoring, Recordkeeping and Reporting......................2 Section 7. Stationary source-Wide Requirements ........................................................................2 Section 8. Insignificant Sources............................................................................................... .....2 Section 9. Generally Applicable Requirements............................................................................2 Section 10. General Source testing and Monitoring Requirements................................................2 Section 11. General Recordkeeping, Reporting, and Compliance Certification Requirements .....2 Section 12. Standard Conditions Not Otherwise Included in the Permit........................................2 Section 13. Permit As Shield from Inapplicable Requirements .....................................................2 Section 14. Visible Emissions Forms ............................................................................................ .2 Visible Emissions Field Data Sheet............................................................................................. 2 Visible Emissions Observation Record .......................................................................................2 Section 15. SO 2 Material Balance Calculation ...............................................................................2 Section 16. ADEC Notification Form............................................................................................. 2Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 3 of 61 List of Abbreviations Used in this Permit
AAC .....................Alaska Administrative Code ADEC...................Alaska Department of Environmental Conservation AS ........................Alaska Statutes ASTM ..................American Society fo r Testing and Materials BACT...................Best Available Control Technology BPXA...................BP Exploration (Alaska) Inc. BTU......................British Thermal Units CEMS...................Continuous Emissions Monitoring System CFP ......................Central Facilities Pad C.F.R....................Code of Federal Regulations CO........................Carbon Monoxide DAR .....................Data Analysis Report DLE......................Dry Low Emissions dscf.......................Dry standard cubic foot EEMSP.................Excess Emissions and Monitoring Systems Performance EPA......................US Environmental Protection Agency Gal........................gallons gr./dscf .................grain per dry standard cubic foot (1 pound = 7000 grains) GPA......................Gas Producers Association GPH......................gallons per hour HAPs or HACs.....Hazardous Air Pollutants or Hazardous Air Contaminants [ HAPs or HACs as contained in AS 46.14.990(14)] hp..........................horsepower hr ..........................hour ID .........................Source Identification Number kPa........................kiloPascals LHV .....................Lower Heating Value (or Net Heating Value) MACT..................Maximum Achievable Control Technology [ MACT as contained in 40 C.F.R. 63] MMBtu.................Million British Thermal Units MR&R..................Monitoring, Recordkeeping, and Reporting MW ......................megaWatts NAICS..................North American Indus try Classification System NESHAPs ............Federal National Emission Standards for Hazardous Air Pollutants [NESHAPS as contained in 40 C.F.R. 61] NO X ......................Nitrogen Oxides NSPS....................Federal New Source Performance Standards [ NSPS as contained in 40 C.F.R. 60] O 2 .........................Oxygen PEMS ...................Predictive Emissions Monitoring System pph........................pounds per hour ppm ......................Parts per millionPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 4 of 61 ppmv ....................Parts per million by volume ppmvd ..................Parts per million by volume dry PM-10 ..................Particulate Matter less than or e qual to a nominal ten microns in diameter PS .........................Performance specification PSD ......................Prevention of Significant Deterioration PTE ......................Potential to Emit RM .......................Reference Method SIC. ......................Standard Industrial Classification SO 2 .......................Sulfur dioxide SSPOWGEN........Software program devel oped by General Electric Inc. TPH......................Tons per hour TPY......................Tons per year VOC .....................volatile organic compound [ VOC as defined in 18 AAC 50.990(103)] wt% ......................weight percentPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 5 of 61 Section 1. Identification

Names and Addresses
Permittee: BP Exploration (Alaska) Inc. 900 East Benson Boulevard Anchorage, AK 99508

Facility Name: Milne Point Production Facility Central Facilities Pad (CFP), B-Pad, and E-Pad

Location of CFP: 70 ° 27.5 ′ North; 149 ° 26.2 ′ West

Physical Address: Milne Poin t Unit, North Slope, Alaska

Owner: BP Exploration (Alaska) Inc. 900 East Benson Boulevard Anchorage, Alaska 99508

Operator: BP Exploration (Alaska) Inc. 900 East Benson Boulevard Anchorage, Alaska 99508

Permittee’s Responsible Official Edward D. Lafehr, Milne Point Delivery Manager

Designated Agent: CT Corporation System 801 West 10th Street, Suite 300 Juneau, AK 99801

Facility and Building Contac t: Facilities Supervisor (907) 670-3331

Fee Contact: James A. Pfeiffer, Air Specialist MB2-6, P.O. Box 196612 Anchorage, AK 99519-6612

Stationary source Process Description

SIC Code of the Facility: 1311 NAICS Code of the Facility: 211111 [18 AAC 50.350(b)(1), 1/18/97]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 6 of 61 Section 2. General Emission Information [18 AAC 50.350(b)(1), 1/18/97]
Emissions of Regulated Air Contaminants, as provided in the Permittee's application:

NO X , CO, SO 2 , PM, VOC, and various hazardous air pollutants (HAPs).

Stationary source Classifications:
(1) 18 AAC 50.300(b)(2) - Milne Poin t Production Facility is a st ationary source containing fuel-burning equipment with a rated capaci ty of 100 million Btu (MMBtu) per hour or

more (2) 18 AAC 50.300(c)(1) - (Preventi on of Significant Deterioratio n (PSD) major facility) - Milne Point Production Facility is a stationary source that has the potential to emit (PTE) 250 tons per year (TPY) or more of a regulated air pollutant in an area designated as in attainment or unclassifiable for that air pollutant

Operating Permit Classifications:
(1) 18 AAC 50.325(b)(1) - Milne Point Production Facility is a stati onary source that emits or has the potential to em it 100 TPY or more of a regulated air pollutant (2) 18 AAC 50.325(b)(3) - Milne Point Production Facility is a stati onary source that contains an emission unit subject to one or more of the standards adopted by reference in 18 AAC 50.040(a) - (c) (3) 18 AAC 50.325(c) - Milne Point Production Facility is a stationary source described in 18 AAC 50.300 (b) through (e)Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 7 of 61 Section 3. Emission Unit Inventory and Description [18 AAC 50.350(d)(2), 1/18/97] Emission Units listed in Table 1 have speci fic monitoring, record keeping, or reporting conditions in this permit. Emission unit descri ptions and ratings are given for identification purposes only.

Table 1 – Emission unit In ventory and Description

ID Tag No. Location Make/ Model or

Other Identifier Nominal Maximum Fuel Type Actual Date Installed

or Modified 3

Turbines 1 PU-0701 Central Facilities Pad (CFP) GE LM-2500 29,500 hp ISO 29,500 hp ISO Fuel gas & Liquid Fuel 1985

1A PU-0701A 5 CFP GE LM2500 DLE 29,500 hp ISO 29,500 hp ISO Fuel Gas To Be Determined 2 PU-0801 CFP GE LM-2500 29,500 hp ISO 29,500 hp ISO Fuel gas & Liquid Fuel 1985

Heaters 3 H-5302A CFP Thermoflux 30.0 MMBtu/hr 35.0 MMBtu/hr Fuel Gas 1995 4 H-5302B CFP Thermoflux 30.0 MMBtu/hr 35.0 MMBtu/hr Fuel Gas 1995 5 H-4510A E-Pad Latoka 14.4 MMBtu/hr 14.4 MMBtu/hr Fuel Gas 1995 4 6 H-4510B E-Pad Latoka 14.4 MMBtu/hr 14.4 MMBtu/hr Fuel Gas 1995 4
7 H-5701A CFP Thermoflux 22.7 MMBtu/hr 29.0 MMBtu/hr Fuel Gas & Liquid Fuel 1985

8 H-5701B CFP Thermoflux 22.7 MMBtu/hr 29.0 MMBtu/hr Fuel Gas & Liquid Fuel 1985

9 H-2001A B-Pad Thermoflux 9.8 MMBtu/hr 12.0 MMBtu/hr Fuel Gas 1985 10 H-2001B B-Pad Thermoflux 9.8 MMBtu/hr 12.0 MMBtu/hr Fuel Gas 1985 Emergency Engines 11 PU-0101A CFP Detroit Diesel 1,500 hp 1.5 MW Liquid Fuel 1985 12 PU-0101B CFP Detroit Diesel 1,500 hp 1.5 MW Liquid Fuel 1985 13 PU-0101C CFP Detroit Diesel 1,500 hp 1.5 MW Liquid Fuel 1985 14 PU-0110A CFP Cummins 187 hp 187 hp Liquid Fuel 1985 15 PU-0110B CFP Cummins 187 hp 187 hp Liquid Fuel 1985 16 PU-4703 1 CFP Cat 3304 120 hp 120 hp Liquid Fuel 1985 17 PU-2004 B-Pad Cummins 600 hp 0.448 MW Liquid Fuel 1985 Flare 2 18 Flare CFP National, Inc. 0.34 MMscf/day 83 MMscf/day Fuel Gas 1985 18A Flare CFP Corona 0.125 MMscf/day 83 MMscf/day Fuel Gas To Be Determined Vents 21 B-Pad Process Vent 198523 T-6001& T6101B CFP Oil Reserve Tanks 1985

24 CFP Produced Water Surge Tank 1985 25 CFP Glycol Dehydration Unit Table notes: 1 Emission unit ID 16 is a non-road engine. 2 Flare nominal flow rate of 0.125 MMscf/day is pilot and purge only. 3 The actual installation or modification date is provided fo r historical reference, for determining PSD applicability

and for the purpose of determining NSPS applicability (except as noted). Modification means any physical change in, or change in the method of operation of, an existing stationary source which increases the amount of any air pollutant (to which a standard applies) emitted into the atmosphere by the stationary source or which results in the emission of any air pollutant (to which a standard applies) into the atmosphere not previously emitted, as defined in 40 C.F.R. 60.2 effective 7/1/98.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 8 of 61 4 For the purpose of NSPS applicability, the installation or modification date for Emission Unit ID(s) 5 4 and 65 is

1984 because the heaters were originally installed at the ARCO Alaska Kuparuk River Unit West Sak pilot plant in 1984. They were moved from West Sak to MPU E-pad in 1995. 5 BPXA is replacing Emission Unit 1 (Tag No. PU-0701 ), with Emission Unit 1A (Tag No. PU-0701A).Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 9 of 61 Section 4. Emission Fees

1. Assessable Emissions. The Permittee shall pay to the De partment an annual emission fee based on the stationary source’s assessable em issions as determined by the Department under 18 AAC 50.410. The assessable emission f ee rate is set out in 18 AAC 50.410(b). The Department will assess fees per ton of each air pollutants that the stationary source emits or has the potential to emit in quantities greater than 10 tons per year. The quantity for which fees will be assessed is the lesser of

1.1 the stationary source's assessable potential to emit of 1,383 TPY; or

1.2 the stationary source’s projected annual rate of emissions that will occur from July 1 to the following June 30, based upon actua l annual emissions emitted during the most recent calendar year or another 12 month period approved in writing by the Department, when demonstrated by

a. an enforceable test met hod described in 18 AAC 50.220;

b. material balance calculations;

c. emission factors from EPA’s publication AP -42, Vol. I, adopted by reference in 18 AAC 50.035; or

d. other methods and calculations approved by the Department

. [18 AAC 50.346(a)(1), 5/3/02 and 18 AAC 50.350(c) & 50.400 – 50.420, 1/18/97]

2. Assessable Emission Estimates. Emission fees will be assessed as follows:

2.1 no later than March 31 of each year, the Permittee may submit an estimate of the stationary source’s assessable emissions to ADEC, Air Permits Program, ATTN: Assessable Emissions Estimate, 410 Willoughby Ave., Juneau, AK 99801-1795 ; the submittal must include all of the assumptions and calculations used to estimate the assessable emissions in sufficient detail so the Department can verify the estimates;

or

2.2 if no estimate is received on or before Ma rch 31 of each year, emission fees for the next fiscal year will be based on the potential to emit set forth in condition 1.1. [18 AAC 50.346(a)(1), 5/3/02 and 18 AAC 50.350(c) & 50.400 – 50.420, 1/18/97]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 10 of 61 Section 5. Emission Uni t-Specific Requirements

Fuel-Burning Equipment

3. Visible Emissions. The Permittee shall not cause or allow visible emissions, excluding condensed water vapor, emitted from Emi ssion Units 1 and 1A, 2 through 15, 17, 18, and 18A listed in Table 1 to reduce visibility through the exhaust e ffluent by any of the following:

a. more than 20 percent for more than three minutes in any one hour 1

, [18 AAC 50.055(a)(1), 1/18/97 and 18 AAC 50.350(d)(1)(C), 6/21/98] [40 CFR 52.70, 11/18/98]

b. more than 20 percent for more than th ree minutes in any one hour (applies to Emission unit ID 18 only), [BACT Limit from Permit–to-Operate 8636-AA014, 9/15/85]

c. more than 20 percent averaged over any six consecutive minutes. [18 AAC 50.055(a)(1) & 50.346(c), 5/3/02 and 18 AAC 50.350(d)(1)(C), 6/21/98]

3.1 For Emission Unit ID(s) 1A, 3 through 6, 9, and 10, burn only gas as fuel. Monitoring for these emission units shall cons ist of an annual certif ication that each of these emission units fired only gas. Report under condition 81 if any fuel is burned other than gas.

3.2 For Emission Unit ID(s) 1, 2, 7, and 8, when operated on gas, monitoring shall consist of an annual certifica tion that the emission units fi red only gas. If any of Emission unit ID(s) 1, 2, 7 and 8 operate on liquid fuel for more than 400 hours in a consecutive 12-month period monitor, r ecord, and report according to conditions 38.1b through 40 for that emission unit.

3.3 For Emission Unit ID(s) 11 through 15, and 17, as long as they do not exceed 400 hours of emergency and non-emergency ope ration per consecutive 12-month period, monitoring shall consist of an annual certi fication of compliance with the opacity standard. Otherwise, monitor, record and report visible emissions in accordance with conditions 38.1b through 40.

3.4 For Emission Unit ID 18 and 18A (flares), m onitor, record and re port in accordance with condition 46. [18 AAC 50.350(g) - (i) & 50.346(c), 5/3/02]

1 For purposes of this permit, the “more than three minutes in any one hour” criterion in this condition and

condition 53 will no longer be effective when the Air Quality Control (18 AAC 50) regulation package effective 5/3/02 is adopted by the U.S. EPA. The six-minute average standard is enforceable only by the state until the new regulations dated May 3, 2002 is approved by EPA into the SIP at which time this standard becomes federally enforceable.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 11 of 61 4. Particulate Matter. The Permittee shall not cause or allow particulate matter emitted from Emission Unit ID(s) 1 and 1A, 2 thr ough 15, 17, 18, and 18A listed in Table 1 to exceed 0.05 grains per cubic foot of exhaust gas corrected to standard conditions and averaged over three hours. [18 AAC 50.346(c), 5/3/02; 18 AAC 50.055(b)(1), 1/18/97 and 18 AAC 50.350(d)(1)(C), 6/21/98]

4.1 For Emission Unit ID(s) 1A, 3 through 6, 9, and 10, burn only gas as fuel. Monitoring for these emission units shall cons ist of an annual certif ication that each of these emission units fired only gas. Report under condition 81 if any fuel is burned other than gas.

4.2 For Emission Unit ID(s) 1, 2, 7, and 8, when operated on gas, monitoring shall consist of an annual certifica tion that the emission units fi red only gas. If any of Emission unit ID(s) 1 and 2 operate on liquid fuel for more than 400 hours in a consecutive 12-month period monitor, reco rd, and report according to conditions 43 and 45 for that emission unit. If any of Emission unit ID(s) 7 and 8 operate on liquid fuel for more than 400 hours in a consecu tive 12-month period monitor, record, and report according to conditions 41 and 42 for that emission unit.

4.3 For Emission Unit ID(s) 11 through 15, and 17, as long as they do not exceed 400 hours of emergency and non-emergency ope ration per consecutive 12-month period, monitoring shall consist of an annual certifi cation of compliance w ith the particulate matter standard. Otherwise, monitor, record and report vi sible emissions in accordance with conditions 43 and 45. [18 AAC 50.346(c) & 50.350(g) – (i), 5/3/02]

4.4 For Emission Unit ID(s) 18 and 18A (flare s), the Permittee must annually certify compliance with the particulate matter standard. [18 AAC 50.346(c) & 50.350(g) – (i), 5/3/02]

5. Sulfur Compound Emissions. In accordance with 18 AAC 50.055(c), the Permittee shall not cause or allow sulfur co mpound emissions, expressed as SO 2 , from Emission Unit ID(s) 1 and 1A, 2 through 15, 17, 18, and 18A to exceed 500 ppm averaged over three hours. [18 AAC 50.346(c), 5/3/02; 18 AAC 50.055(c), 1/ 18/97; and 18 AAC 50.350(d)(1)(C), 6/21/98]

5.1 For Emission Unit ID(s) 1 and 1A, 2 through 10, and 18, and 18A when using fuel
gas:

a. Monitoring conducted as required by condition 17 satisfies the monitoring requirements necessary to assure compliance with this condition.

b. Keep records of analyses conducte d in accordance with condition 17.1a.

c. Report as excess emissions, in accordance with condition 81, whenever the fuel combusted causes sulfur compound emissions to exceed the standard of condition 5.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 12 of 61 d. Include copies of the records requir ed by condition 5.1b with the stationary source operating report re quired by condition 83. [18 AAC 50.350(g) - (i), 1/18/97]

5.2 For Emission Unit ID(s) 1, and 2, 7 and 8, 11 through 15, and 17, when using liquid fuel from a North Slope topping plant, th e Permittee shall obtain from the topping plant the results of a mont hly fuel sulfur analysis.

a. The Permittee shall include in the stati onary source operating report required by condition 83 a list of the sulfur conten t measured for each month covered by the report.

b. If the fuel sulfur contains greater than 0.75 percent sulf ur by weight, the Permittee shall calculate SO 2 emissions in PPM using either the SO 2 material balance calculation in Section 15, or Method 19 of 40 C.F.R. 60, Appendix A7, adopted by reference in 18 AAC 50.040(a).

c. If SO 2 emissions are calculated under condition 5.2b to exceed 500 ppm, the Permittee shall report unde r condition 81. The repor t shall document the calculation under condition 5.2b.

d. For fuel with a sulfur content greater than 0.75 percent by weight, the Permittee shall include in the stationary source operating report required by condition 83 the calculated SO 2 emissions in PPM. [18 AAC 50.346(c) & 350(g) - (i), 5/3/02]
Emission Units Subject to Federal New Source Performance Standards (NSPS), Subpart A

6. NSPS Subpart A Startup, Shutdown , & Malfunction Requirements. The Permittee shall maintain records for Emission unit ID(s) 1 through 4 in accordance with 40 CFR 60.7(b). [18 AAC 50.350(h), 5/3/02 & 18 AAC 50.040(a)(1), 7/2/00] [40 C.F.R. 60.7(b), Subpart A, 7/1/01]

7. NSPS Subpart An Excess Emissions and Mo nitoring Systems Performance (EEMSP) Report . For Emission Unit ID(s) 1, 1A, and 2 the Permittee shall comply with 40 CFR 60.7(c) and (d). [18 AAC 50.350(i), 1/18/97 & 18 AAC 50.040(a)(1), 7/2/00] [40 C.F.R. 60.7(c) & (d), Subpart A, 7/1/01]

8. NSPS Subpart A, Performance (Source) Tests. At such times as may be required by the NSPS Administrator, the Permittee shall conduct source tests for Emission Unit ID(s) 1,1A, and 2 according to Section 10 of this permit and 40 C. F. R. 60.8 and shall provide the Department and EPA with a written re port of the results of the source test. [18 AAC 50.040(a)(1), 8/15/02] [40 C.F.R. 60.8(a)-(e), Subpart A, 7/1/01]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 13 of 61 9. NSPS Subpart A Good Air Pollution Control Practice. The Permittee shall maintain and operate Emission Unit ID(s) 1 thr ough 4 in accordance with 40 CFR 60.11(d). [18 AAC 50.040(a)(1), 8/15/02] [40 C.F.R. 60.11(d), Subpart A, 7/1/01]

10. NSPS Subpart A Credible Evidence. The credible evidence rule of 40 CFR 60.11(g) applies to Emission Unit ID(s) 1, 1A, and 2. [18 AAC 50.040(a)(1), 8/15/02] [40 C.F.R. 60.11(g), Subpart A, 7/1/01]

11. NSPS Subpart A Concealm ent of Emissions. The Permittee shall not conceal emissions from Emission Unit ID(s) 1, 1A, and 2 as provided in 40 CFR 60.12. Monitoring shall consist of an annual certification that the Permittee does not conceal emissions. [18 AAC 50.040(a)(1), 8/15/02] [40 C.F.R. 60.12, Subpart A, 7/1/01]

12. NSPS Subpart A, Monitoring. For the continuous mon itoring system (CMS) required under condition 14.1, the Permittee shall: [18 AAC 50.040(a)(1), 8/15/02] [40 C.F.R. 60.13(a), 7/1/01]

12.1 Install and operate the CMS in accordance with 40 C.F.R. 60.13(b). [40 C.F.R. 60.13(b), 7/1/01]

12.2 Install the CMS in accordance with 40 C.F.R. 60.13(f). [40 C.F.R. 60.13(f), 7/1/01]

12.3 Reduce data from the CMS in accordance with 40 C.F.R. 60.13(h). [40 C.F.R. 60.13(h), 7/1/01]
Emission Units Subject to NSPS Subpar t Dc, Emission Unit ID(s) 3 and 4

13. NSPS Subpart Dc Requirements . The Permittee shall maintain records of the amount of fuel gas combusted during each day for Emission Unit ID(s) 3 and 4 in accordance with 40 CFR 60.48c(g) Subpart Dc. [18 AAC 50.040(a)(2)(D), 8/15/02] [40 C.F.R. 60.48c(g), Subpart Dc, 7/1/01]
Turbines Subject to NSPS Subpart GG NO X Standard, Emission Unit ID(s) 1, 1A, and 2

14. NSPS Subpart GG NO X Standard . Except as provided in conditions 15 and 16, the Permittee shall not allow the corrected exhaus t gas concentration from Emission Unit ID(s) 1, 1A and 2 to exceed 215 ppmvd of NO X at ISO standard day conditions and 15 percent oxygen when firing fuel gas. Emission Unit ID(s ) 1 and 2 are exempt from the limit in this condition when firing emergency fuel, which in cludes periods when source tests required by condition 22.1 are conducted. [18 AAC 50.040(a)(2)(V), 8/15/02] [40 C.F.R. 60.332(a)(2), Subpart GG, 7/1/01]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 14 of 61 14.1 Install and operate a continuous monitoring system (CMS) in Em ission Unit ID(s) 1 and 2 to monitor and record the fuel consum ption and the ratio of water to fuel being fired in the turbines, in accordance with 40 C.F.R. 60.334(a). [18 AAC 50.350(g) & (h), 1/18/97] [40 C.F.R. 60.334(a), Subpart GG, 7/1/01]

14.2 Report in accordance with 40 C.F.R. 60.334(c)(1).

15. Ice Fog Exemption and Reporting. Emission Unit ID(s) 1 and 2 are exempt from condition 14 when the Permittee deems ice fog a traffic hazard in accordance with 40 C.F.R. 60.332(f). Report in accord ance with 40 C.F.R. 60.334(c)(3). [18 AAC 50.040(a)(2)(V), 8/15/02] [40 C.F.R. 60.332(f), Subpart GG, 7/1/01]

16. Emergency Fuel Exemption and Reporting . Emission Unit ID(s) 1 and 2 are exempt from the limit of condition 14 when fired with liquid fuel during circ umstances that make it impossible to fire fuel gas in the turbin es. The Permittee shall report each exemption period in accordance wi th 40 CFR 60.334(c)(4). [18 AAC 50.040(a)(2)(V), 8/15/02] [40 C.F.R. 60.332(k), Subpart GG, 7/1/01] [40 C.F.R. 60.334(c)(4), Subpart GG, 7/1/01]

17. NSPS Subpart GG Sulfur Standard. The Permittee shall not allow the sulfur content for the fuel burned in Emission Unit ID(s) 1, 1A, and 2 to exceed 0.8 percent by weight. [18 AAC 50.040(a)(2)(V), 8/15/02] [40 C.F.R. 60.333(b), Subpart GG, 7/1/01]

17.1 Determine compliance monthly with the fuel sulfur content standa rd in this condition as follows: [40 C.F.R. 60.334 & 60.335(d), Subpart GG, 7/1/01]

a. For gaseous fuels, monitor, record, and re port the sulfur content of the fuel gas fired in Emission Unit IDs 1, 1A and 2 in accordance with either 40 CFR 60.334(b), (c) and §60.335(d), or the custom schedule and plan approved August 28, 2002, or a revised custom schedule and plan approved in accordance with 40 CFR 60.334(b)(2).

b. For liquid fuels, determine the sulfur c ontent using one of the methods specified in ASTM D 2880-71, or an EPA approved alternative method.

c. The fuel sulfur analysis required under this condition may be performed by the owner or operator, a service contractor retained by the owner or operator, the fuel vendor, or any ot her qualified agency. [40 C.F.R. 60.335(e), Subpart GG, 7/1/01]

17.2 Keep records of analysis as required by condition 17.1.

17.3 The Permittee shall semi-annually report to the EPA results of all sulfur monitoring required by this condition. [40 C.F.R. 60.334(c)(2), Subpart GG, 7/1/01]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 15 of 61 17.4 For the purpose of EEMSP reports and su mmary report required under condition 7, the Permittee shall report in acco rdance with 40 C.F.R. 60.334(c)(2). [18 AAC 50.350(i), 1/18/97] [40 C.F.R. 60.334(c)(2), Subpart GG, 7/1/01]

18. Periodic Monitoring, Recordkeeping a nd Reporting for NSPS Subpart GG NO X Emission Standard. In addition to the NSPS monito ring, recordkeeping, and reporting requirements of condition 15, source tests conducted in accordan ce with conditions 23.1a and 23.4 shall be used as the basis to determine compliance with the NO x emission limit of condition 15 for Emission Unit ID(s) 1 and 2. For Emission Unit ID 1A, conduct an initial performance test in accordance with 40 CF R 60.8. Submit reports in accordance with condition 81 any time the NOx emission rate exceeds the standard in condition 15. [18 AAC 50.350(g) - (i), 1/18/97] [18 AAC 50.220(a) - (c), 1/18/97]

19. Turbine NO X and CO Monitoring Requirements. To monitor compliance with the NO X PSD avoidance standard and the CO BACT limits in Table 5, the Permittee shall monitor process parameters hourly and calculate the NO X and CO emission rates in pounds per hour (pph) no less than once per month for Emission Unit ID(s) 1, 1A, and 2 in accordance with conditions 19.1, 19.3, or 20.3 as follows: [Construction Permit No. 0073-AC023, 7/13/01]

19.1 Unless required to use a CEMS by condition 20.3 for either NO X or for CO, calculate emission rates for Emission Unit ID(s) 1 a nd 2 using the best-f it correlation most recently approved by the Department or most recently submitted for approval by the Permittee under condition 21.5 or condition 22.3.

19.2 Calculate NOx and CO emission rates fo r Emission Unit ID 1A hourly using the most recently submitted emission index from condition 24.2 and fuel

19.3 Install a CEMS for NO X or for CO as indica ted in condition 20, and

a. no later than 120 days after submitting the report for the second failing test if two consecutive Relative Accuracy (RA) tests performed under condition 22.1 for the Department-approved correlati on exceed the limits in conditions 19.3a(i) or 19.3a(ii).

(i) twenty percent when the RM value is used in the denominator of the RA equation in 40 CFR 60, Appendix B, Pe rformance Specification 2, Section 12, Equation 2-6 (average emissions duri ng test are greater than 50 percent of the emission standard) or

(ii) ten percent when the applicable em ission standard is used in the denominator of the RA equation in 40 CFR 60, Appendix B, Performance Specification 2, Section 12, Equation 2- 6 (average emissions during test are less than 50 percent of the emission standard), and

b. calculate an hourly emission rate (lb/hr) using a fuel specific emission factor (lb/MMBtu) and a heat consumpti on value (MMBtu/hr) and as follows:Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 16 of 61 (i) Determine the fuel specific emission factor from NO X or CO and O 2 measured volume concentrations and Method 19.

(ii) Use consistent heating values (highe r or lower heating value) throughout the analysis.

(iii) If the “F” factor from Table 19-2 in Method 19 is used in the calculations, use the higher heating va lue in all calculations.

20. Continuous Emissions Moni toring System (CEMS). If monitoring NO X and CO under condition 20.3, the Permittee shall use a CEMS as follows: [Construction Permit No. 0073-AC023, 7/13/01]

20.1 Within 90 days of CEMS installatio n under condition 20.3, conduct a relative accuracy test of the CEMS as set out in 65 FR 61744, Performance Specification 2 (PS2) for NO X and Performance Specification 4 (PS4) for CO, dated October 17, 2000. A CEMS is not acceptable if it does not meet the limits set out in Section 13.2 of PS2.

20.2 Within 60 days of completing the Relative Accuracy (RA) test under condition 20.1, submit a CEMS quality assurance, quality c ontrol (QA/QC) plan to the Department for approval.

20.3 Record the results of the RA test conducted under condition 20.1.

20.4 Report to the Department

a. the results of the RA test required by condition 20.1 as set out in Section 8 of PS2 within 60 days of comp leting the RA tests; and

b. a copy of the plan required by condition 20.2 upon completion of the plan.

21. Best-Fit Correlation Method. If monitoring NO X and CO under condition 20.1, the Permittee shall develop best-fit correlations

a. between NO X emission rates from source tests and turbine process parameters, and

b. between CO emission rates from source te sts and turbine process parameters, as follows: [Construction Permit No. 0073-AC023, 7/13/01]

21.1 Notify the Department of intention to de velop a best-fit corr elation for emission monitoring, and submit a source test plan to the Department in accordance with condition 73, includingPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 17 of 61 a. identification of the proposed process parameters for which the Permittee elects to measure a parametric monitoring correlation, and

b. a description of the monitoring methodology accuracy and precision of methodology and sampling rates of each parameter.

21.2 Conduct three sets 3 of initial Referen ce Method (RM) source tests as described in condition 69 at each of three loads (high, medium, and low), on each turbine, for each of the four operating scen arios listed below, for NO X and CO.

a. Fuel gas, without DWI,

b. Fuel gas, with DWI,

c. Liquid Fuel, without DWI, and

d. Liquid Fuel with DWI

21.3 During the RM source tests required unde r condition 21.2, collect and record the process parameters identified in cond ition 21.1a for the purpose of developing parametric correlations for NO X and CO emission rates for both fuel gas and liquid fuel.

21.4 Using the RM test results from conditi on 21.2, develop best-fit correlations for emission rates based on turbine process para meters as follows: (The correlations may also be based on SSPOWGEN (software program ) or other vendor data as well as the RM source tests.)

a. NO X /fuel gas, with and without DWI;

b. NO X /liquid fuel, with and without DWI;

c. CO/fuel gas, with and without DWI; and

d. CO/liquid fuel, with and without DWI.

21.5 Within 60 days after completing the RM tests under condition 21.2, submit to the Department for written approval a report th at describes the best-fit correlation development, including the methodology, a ssumptions, analysis (with sample calculations), supporting notes, and a list of all process parameters used in the correlations with an analysis of their statistical relevance for the corr elation (i.e. an r 2 analysis of curve fit).

21.6 Develop QA procedures for the process para meters used in the correlation developed under condition 21.5.

3 One set = one run, so three runs are required at high load, three at medium and three at low.
6 One set = one run, so three runs are required at high load, three at medium and three at low.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 18 of 61 21.7 Include with the stationary source operating report requ ired by condition 83 copies of the QA procedures de veloped under condition 21.6.

22. Relative Accuracy (RA) Test Procedures for NO X and CO. Except as provided in condition 22.4, the Permittee shall determine th e RA of all correlations most recently approved under condition 21.5 or condition 22.3 annually as follows: [Construction Permit No. 0073-AC023, 7/13/01]

22.1 No more than 12 months after the previous series of RM tests, conduct RM tests for NO X and CO as follows:

a. Conduct a minimum of three sets 6 RM source tests as described in condition 69 at each of three loads (high, medium, and low), on one turbine (in even years on Emission Unit ID 1 and in odd years on Em ission Unit ID 2), for each of the four following operating scenarios:

(i) Fuel gas, without DWI,

(ii) Fuel gas, with DWI,

(iii) Liquid fuel, without DWI, and

(iv) Liquid fuel, with DWI.

b. Record each statistically relevant proce ss parameter during each RM source test no less than once every 15 minutes. Ma rk the beginning and end of each RM source test on the output record.

c. Record the NO X and CO emission concentrations in ppm for each RM source test period ("RM value") for each of th e operating scenarios in condition 22.1a.

d. Determine the integrated average NO X and CO emission rates in pph for each RM test period using the best fit corr elations approved by the Department under condition 21.5 or condition 22.3.

22.2 Calculate the relative accuracy of a correla tion compared to a RM test as follows:

a. If the RM has an instrumental or integrated non-instrumental sampling technique, make a direct comparison of the RM value and the correlation value.

b. If the RM has a grab sampling technique, first average the results from all grab samples taken during the test run, and th en compare this av erage value against the value obtained from th e correlation during the run.

c. Using the procedures in 40 CFR 60, A ppendix B, Performance Specification 2, Section 12 and summarizing the results on a data sheet similar to that shown in Section 18 calculate thePermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 19 of 61 (i) arithmetic mean of the differen ce between the "RM value" and the "correlation value",

(ii) standard deviation,

(iii) confidence coefficient, and

(iv) relative accuracy.

22.3 Based on RA test results, propose revisions to the best-fit correlation. Within 60 days after completing the RM tests, submit to the Department for written approval a report that describes the best-fit co rrelation revision, including the methodology, assumptions, analysis (with sample calcul ations), supporting notes , and a list of all process parameters used in the correlations with an analysis of their statistical relevance for the correlation (i.e. an r 2 analysis of curve fit). Revise QA procedures for the process parameters used in the best-fit correlation most recently approved by the Department.

22.4 If five consecutive annual RA verifications of any correlation are less than the limits in Condition 20.3 the Permittee may decrease the testing frequency to once every 24 months, with the Department's concurrence.

22.5 Include with the stationary source operating report required under condition 83 copies of the results of all RM tests (i ncluding any rejected test results) conducted under condition 22.1a.

23. Emission Index for Emission Unit ID 1A. In conjunction with the testing required by condition 19, conduct a CO emissi ons test at four loads in the normal operating range of Emission Unit ID 1A.

23.1 Correct the NO x and CO values from the test to 15 percent oxygen. Take the highest value from all the results and a dd a 20 percent safety margin.

23.2 Using the results from condition 24.1, calcu late an emission index for Emission Unit ID 1A in lb/MMBtu based on the lowe r heating value of the fuel for NO x and CO using the methodology in 40 CFR 60 Appendix A Method 19.

Emission Unit Subject to Owner Requested Limi t to Maintain the HAP-minor Status of the Stationary Source

24. Operation of Closed Vent System. The Permittee shall operate the closed vent system for Emission Units ID 25 (Glycol Dehydr ation Unit) a minimum of 2400 hours per calendar year to recycle the vent scrubbe r hydrocarbons back into the third stage compression for recovery. [18 AAC 50.335(g)(1), 1/18/97]

24.1 Monitor and record the monthly and year-t o-date operating time of the closed vent system.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 20 of 61 24.2 Include with the stationary source operating report requ ired by condition 83, copies of the records required by condition 24.1.

24.3 If the total number of hours of closed ve nt system operation for the calendar year is less than 2400 hours, then

a. estimate HAP emissions from the stationary source,

b. submit a report in accordance with condition 81, and

c. reevaluate the HAP-major status of the stationary source.

Emission Units Subject to Owner Requested Li mits for Ambient Air Quality Protection

25. Liquid Fuel Sulfur Requirements. The Permittee shall burn liquid fuel with no greater than 0.30 percent sulfur by weight in any of the fuel-burning equipment listed in Table 1. Monitor, record, and report as follows: [Construction Permit No. 0073-AC023, 7/13/01]

25.1 For Emission Unit ID(s) 1 and 2 (Subpart GG turbines) obtain records of the sulfur content of the liquid fuel as required in condition 17.1. For all other fuel burning equipment listed in Table 1 except for Em ission Unit ID(s) 1 and 2, obtain a record of the sulfur content of the liqui d fuel as required in condition 5.2.

25.2 Keep records of the results of each liquid fuel sulfur analysis.

25.3 Submit a report in accordance with condition 81 whenever liquid fuel sulfur content exceeds the sulfur limit in condition 25.

25.4 Submit with the stationary source operating report requ ired by condition 83, copies of the records requi red under condition 25.2. [18 AAC 50.350(g) - (i), 7/2/00]

26. Liquid Fuel Consumption Limit. The Permittee shall burn no more than one million gallons of liquid fuel per 12 consecutive months at the CFP, B-Pad, and E-Pad in all of the equipment listed in Table 1 and all other fuel burning equipment that may be present on the specified pads, except for fuel burned in motor vehicles and in insignificant Emission Units as listed at 18 AAC 50.335(r), (s), and (t ). The Permittee shall not exclude Emission Units on rotary drill rigs as insignificant Emission Units. [Construction Permit No. 0073-AC023, 7/13/01]

26.1 Measure the monthly total liquid fuel used by Emission Unit ID(s) 1 and 2 using the fuel meters required by condition 14.1. Fo r other fuel burning emission units, the fuel use may be estimated by calculations approved by the Department. Fuel meters, if used, must be calibrated using NIST tr aceable standards and mu st be accurate to within plus or minus five percent.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 21 of 61 26.2 Calculate and record the total liquid fuel burned in the previous 12 consecutive months.

26.3 Submit a report in accordance with condition 81 whenever the liquid fuel quantity in gallons exceeds the liquid fu el limit in condition 26.

26.4 Include with the stationary source operating report requ ired by condition 83, copies of the records required under condition 26.2 for each rolling 12-month total during the reporting period. [18 AAC 50.350(g) - (i), 7/2/00]

27. Fuel Gas Sulfur Requirements. The Permittee shall burn fuel gas with no greater than 100 ppmvd H 2 S 12-month rolling average in any of the fuel burning equipment listed in Table 1. [Construction Permit No. 0073-AC023, 7/13/01]

27.1 Monitor and record the H 2 S content of the fuel gas as required in condition 17.1a and 17.2.

27.2 Submit a report in accordance with co ndition 81 whenever the 12-month rolling period average fuel gas H 2 S content exceeds the H 2 S limit in condition 27.

27.3 Include with the stationary source operating report required by condition 83, a summary of the consecutive 12-m onth period average fuel gas H 2 S concentration for each month of the reporting period. [18 AAC 50.350(g) - (i), 7/2/00]

28. Annual Limits. The Permittee shall comply with the annual operating hour limits shown in Table 2. [Construction Permit No. 0073-AC023, 7/13/01]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 22 of 61 Table 2 – Annual Limits

Emission Unit Limits 7 and 8 Operate no more than 200 hours during any 12 consecutive months, combine d, while firing liquid fuel. 11, 12, and 13 Operate no more than 900 hours during any 12 consecutive months, combined. 14 and 15 Operate no more than 600 hours during any 12 consecutive months, combined. 17 Operate no more than 300 hours during any 12 consecutive months. 16 Operate no more than 1,344 hours per year while at CFP, B-pad, and E-pad. 18 and 18A Operate sequentially except duri ng periods of transfer of gas from one flare to th e other. The period of overlapping operations should be the minimum practical, and shall not exceed 72 hours. The combined output during overlapping operations shall at no time exceed the combined output greater than 83 MMscf/day.

28.1 The Permittee shall maintain a log that in cludes the operating time in hours for each emission unit listed in Table 2. Each month, calculate the monthly operating time in hours for each emission unit listed in Ta ble 2 and summarize the operating time in hours for the previous twelve months.

28.2 Submit a report in accordance with cond ition 81 whenever the previous 12-month operating hours summarized under condition 28.1 exceed the limits listed in Table 2.

28.3 Include with the stationary source operating report requ ired by condition 83, copies of the records required by condition 28.1. [18 AAC 50.350(g) - (i), 7/2/00]

29. Daily Operating Limits. The Permittee shall comply with the daily operating scenarios shown in Table 3 and as follows:

a. Operate under scenario 1 except as provided in condition 29.b.

b. Operate under scenarios 2 or 3 only if fuel gas is una vailable or during source testing. Prorate operation of each scenario used during each day. [Construction Permit No. 0073-AC023, 7/13/01]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 23 of 61 Table 3 – Daily Operating Limits 7

Scenario 1 Scenario 2 Scenario 3 Emission Unit ID Fuel Limit Fuel Limit Fuel Limit 1 Fuel Gas None 2 Fuel Gas None Fuel Gas/ Liquid Fuel Combined total of 900 lb SO 2 /day Fuel Gas/ Liquid Fuel Combined total of 900 lb SO 2 /day 7 Fuel Gas None Liquid Fuel None Liquid Fuel 8 Fuel Gas None Liquid Fuel None Liquid Fuel Combined total of 24 hr/day 11 Liquid Fuel Liquid Fuel Liquid Fuel 12 Liquid Fuel Liquid Fuel Liquid Fuel 13 Liquid Fuel Combined total of76.5 MWhr/day Liquid Fuel Combined total of 15.0 MW-hr/day Liquid Fuel Combined total of72.0 MWhr/day 14 Liquid Fuel Liquid Fuel Liquid Fuel 15 Liquid Fuel Combined total of 12 hr/day Liquid Fuel Combined total of 16 hr/day Liquid Fuel Combined total of 12 hr/day 17 Liquid Fuel 9.8 MWhr/day Liquid Fuel 9.8 MWhr/day Liquid Fuel 9.8 MWhr/day

29.1 The Permittee shall maintain a daily log for each emission unit listed in Table 3 that includes the operating scenario and complia nce data. Each month, summarize the daily operating scenarios for the month.

29.2 Submit a report in accordance with condition 81 any violations of the daily operating scenarios in Table 3.

29.3 Include with the stationary source operating report requ ired by condition 83, copies of the records required by condition 29.1. [18 AAC 50.350(g) - (i), 7/2/00]
Heaters Subject to BACT Limits

30. Heater CO and NO X BACT Limits . The Permittee shall not cause or allow CO or NO X emissions from Emission Unit ID(s) 3 through 10 to exceed the limits in Table 4 below. [Construction Permit No. 0073-AC023, 7/13/01]

30.1 Monitor, record and report by following established preventative maintenance guidelines, and maintaining records of maintenance completed. Retain maintenance records for five years, and submit records to the Department upon request.

7 Equipment not listed in Table 3 is not subject to any daily operating limits.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 24 of 61 Table 4 – Heater BACT Limits

Pollutant Emission Unit IDs Make/Model Emission Limit (short term) per Individual Heater Annual Emission Limit for Heaters (tpy)

3, 4, 9, and 10 Thermoflux 5 and 6 Latoka 0.2 lb/MMBtu

7 and 8 0.2 lb/MMBtu (when firing fuel gas) CO

Thermoflux

5 lb/1000 gallons (when firing liquid fuel) No Limit

3 and 4 Thermoflux 0.05 lb/MMBtu 5 and 6 Latoka 0.08 lb/MMBtu 7 and 8 0.08 lb/MMBtu (when firing fuel gas) Thermoflux

11.3 lb/hr (based on HHV, when firing liquid fuel) NO X

9 and 10 Thermoflux 0.08 lb/MMBtu No Limit

30.2 Do not operate Emission Unit ID(s) 9 and 10 on liquid fuel at any time.

30.3 No later than 180 days after permit issuance, conduct source tests on Emission Unit IDs 3 and 5 for NO X to ascertain compliance with th e emission limit in this condition for Emission Unit IDs 3 through 6, when firi ng natural gas, except as provided in condition 30.4. Conduct source tests in accordance with the requirements in Section 10. Determine the NO X emission rate for the heater using exhaust properties determined by 40 C.F.R. 60, Appendix A, Method 19, and exhaust gas measurements in Section 10. Determine compliance with the NO X emission rate using 40 C.F.R. 60, Appendix A, Method 19.

30.4 The requirement to conduct source tests on Emission Unit IDs 3 and 5 under condition 30.3 is waived if the Department determines that previous source tests for these emission units are acceptable.

30.5 Submit a report in accordance with condition 81 any exceedance of a NO X emission limit specified in Table 4. [18 AAC 50.350(g) - (i), 7/2/00] [Construction Permit No. 0073-AC023, 7/13/01]
Turbines Subject to BACT and PSD Avoidance Limits

31. Turbine CO, NO X , SO 2 , and PM BACT and PSD Avoidance Limits . The Permittee shall not cause or allow CO, NO X , SO 2 , and PM emissions from Emission Unit ID(s) 1, 1A, and 2 to exceed the limits in Table 5 below. [Construction Permit No. 0073-AC023, 7/13/01]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 25 of 61 Table 5 – Turbine BACT and PSD Avoidance Limits

Pollutant Make/Model Emission Unit IDs BACT Limit Emissions (short term) per Individual Turbine PSD Avoidance Limits Annual Emissions for Turbines (tpy) CO 70 pph 94.4 each (BACT annual limit) NO X 184 ppmvd @ 15% O 2 and ISO conditions 625 combined

SO 2 No Limit 0.30% sulfur by weight in liquid fuel, or 100 ppmvd H 2 S in gaseous fuel PM GE LM2500 DLE, Emission Unit ID1A and GE LM2500, Emission Unit IDs 1 and 2
No Limit 28 combined

Notes: 1) All emission limits for NO X refer to full load ISO conditions. 2) All emission limitations are annual average unless otherwise noted.

32. Turbine NO X Load Limits . The Permittee shall comply with the NO X BACT limit in Table 5 by limiting operational load and/or usi ng Direct Water Injection (DWI) technology for each of the turbines. [Construction Permit No. 0073-AC023, 7/13/01]

32.1 If not using Direct Water Injection (DWI):

a. When using natural gas, operate at no greater than 22,156 kW (generator output) each.

b. When using liquid fuel:

(i) except for DWI start-up periods, opera te at no greater than 8,122 kW (generator output) each.

(ii) during DWI startup, operate at no greater than 9,500 kW each.

(iii) during emergency fuel switches, opera te for no more than 2 hours without DWI.

(iv) during source testing, operate at mi nimum loads required to accomplish the source test.

(v) during scheduled maintenance of the AquaChem water treatment system, operate for no more than 2 hours without DWI.

32.2 If using DWI, load is restricted to ma ximum load at which compliance with the NO X BACT limit in Table 5 was demonstrated for each fuel during any source test required under conditions 21.2b, 21.2d, 22.1a(ii), or 22.1a(iv).Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 26 of 61 33. Monitoring, Recordkeeping, and Reportin g for Turbine BACT and PSD Avoidance Limits . The Permittee shall monitor Emissi on Unit ID(s) 1, 1A, and 2 as follows: [Construction Permit No. 0073-AC023, 7/13/01]

33.1 For NO X BACT emission limit conduct source tests as required in condition 21.2, 22.1, 22.4, and 24 to demonstrate compliance with the NO X BACT limit in Table 5.

33.2 For NO X BACT load limit record the load in kW for Emission Unit IDs 1, 1A, and 2 for each hour of the day and whether DWI was used.

33.3 For NO X PSD avoidance limit no later than the fifteenth day of each calendar month, calculate the NO X emissions in tons/month for th e previous calendar month using Equation 1 below. Calculate and r ecord the 12-month rolling total NO X emissions for both turbines by adding the total NO X emissions for the prior calendar month to the monthly totals for the previous months.

Equation 1 ⎟ ⎟ ⎠ ⎞ ⎜ ⎜ ⎝ ⎛

× ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

× ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

= ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

lb ton

mo hr
hr lb ER
mo tons emissions NO X 2000 Where,

ER = Average hourly NO X emission rate for previous month in pph from condition 19

33.4 For CO Hourly BACT limit monitor and cal culate the CO emission rate in pph as indicated in condition 19.

33.5 For CO Annual BACT limit no later than th e fifteenth day of each calendar month, calculate CO emissions in tons/month fo r the previous calendar month using Equation 2 below. Calculate and record th e 12-month rolling total CO emissions for both turbines by adding the total CO emissi ons for the prior cal endar month to the monthly totals for the previous months.

Equation 2 ⎟ ⎟ ⎠ ⎞ ⎜ ⎜ ⎝ ⎛

× ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

× ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

= ⎟ ⎠ ⎞ ⎜ ⎝ ⎛

lb ton

mo hr
hr lb ER
mo tons emissions CO 2000 Where,

ER = Average hourly CO emission rate for previous month in pph from condition 19

33.6 For SO 2 PSD avoidance limit comply with the fuel sulfur limits, monitoring, recordkeeping and reporting requirements set out in conditions 25 and 27.

33.7 For PM PSD Avoidance LimitPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 27 of 61 a. For fuel gas:

(i) Except as provided in condition 33.7a(ii ), calculate and record the total amount of fuel gas in MMscf used in both turbines for each month using the readings taken under condition 14.1;

(ii) for any time period during which the unit is operational and the fuel consumption records are missing or in correct, estimate fuel consumption based on the design firing rate of the unit for the prevailing ambient temperature;

(iii) add the totals determined under condition 33.7a(i) or 33.7a(ii) to the monthly totals for the previous 11 mont hs to get 12 month fuel gas usage in MMscf/yr;

(iv) calculate the 12 month PM-10 emissions from fuel gas using Equation 3; and
Equation 3 ) / 0005

. 0 )( )( ( lb tons F EF E NG = Where:

E NG = PM-10 emissions from fuel gas in TPY

EF = PM-10 emission factor in lb/MMscf as described in condition 33.7a(v)

F = 12-month fuel gas usage in MMsc f/yr as calculated in condition 33.7a(iii)

(v) determine the emission factor to be us ed in condition 33.7a(iv) as follows.

(A) Until a source test is required by condition 33.7c, use an initial emission factor of 6.02 lb/MMsc f (AP-42 Supplement F, 4/00, Table 3.1-2a).

(B) Once a source test required by condition 33.7c has been conducted, use the PM emission factor for fuel gas in lb/MMscf from the source test.

b. For liquid fuel:

(i) Except as provided in condition 33.7b(ii ), calculate and record the total amount of liquid fuel in gallons used in both turbines for each month using the readings taken under condition 14.1;

(ii) for any time period during which the unit is operational and the fuel consumption records are missing or in correct, estimate fuel consumption based on the design firing rate of the unit for the prevailing ambient temperature;Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 28 of 61 (iii) add the totals determined under condition 33.7b(i) or 33.7b(ii) to the monthly totals for the previous 11 mo nths to get 12 month liquid fuel usage in gal/yr;

(iv) calculate the 12 month PM-10 emissions from liquid fuel using Equation 4; and
Equation 4 ) / 0005

. 0 )( )( )( ( lb tons HV F EF E D =

Where:

E

D = PM-10 emissions from liquid fuel in TPY

EF = PM-10 emission factor in lb/ MMBtu, based on High Heating Value (HHV), as described in condition 33.7b(v)

F

= 12-month liquid fuel usage in gal/yr as calcula ted in condition 33.7b(iii)

HV = HHV of liquid fuel

(v) determine the emission factor to be used in condition 33.7b(iv) as follows.

(A) Until a source test is required by condition 33.7c, use an initial emission factor of 0.012 lb/MMBtu (AP-42, Supplement F, 4/00, Table 3.1-2a).

(B) Once a source test required by condition 33.7c has been conducted, use the PM emission factor for liquid fuel in lb/MMBtu, based on HHV, from the source test.

c. No later than the fifteenth day of each calendar month, calculate and record the 12-month total PM-10 emissions for th e turbines by adding emissions from conditions 33.7a(iv) and 33.7b( iv). The first time that the 12-month total from this condition exceeds 26 tons, determine PM-10 emission factors for the turbines, in lb/MMscf for fuel gas firi ng and in lb/MMBtu (based on HHV), for liquid fuel-firing, with and without DWI, by conducting source tests in accordance with condition 69. Submit a s ource test plan in accordance with condition 73 no later than 60 days after the end of the month in which the 12- month total exceeded 26 tons. Keep records documenting the emissions calculations.

33.8 Notify the Department per condition 81 should the twelve-month consecutive summation of emissions of any air pollutant exceed the limit for that pollutant in Table 5.

33.9 Notify the Department per condition 81 any violations of the operating load limits for Emission Unit ID 1, 1A, or 2 in condition 32.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 29 of 61 33.10 Notify the Department per condition 81 whenever the CO hourly emission rate exceeds the CO hourly emission limit in Table 5.

33.11 Report the monthly and the consecutiv e twelve-month period summation of emissions, for each month of the reporti ng period, with each stationary source operating report required by condition 83.

33.12 Submit with the operating re port required by condition 83, copies of the records required by condition 33.2. [18 AAC 50.350(g) - (i), 7/2/00] [Construction Permit No. 0073-AC023, 7/13/01]
Vents Subject to BACT Limits

34. Vent VOC BACT.

34.1 The Permittee shall limit Well Pad B vents to 36.5 tpy of VOC emissions.
34.2 Monitoring shall consist of an annual certification und er condition 84 that the requirements of this condition have b een met during the reporting period.

34.3 Monitor by calculating monthly VOC em issions from Well Pad B as follows:

a. Determine VOC content of a representati ve sample of the gas stream at Well Pad B within 90 days of permit issuan ce and at least onc e each per rolling twelve months thereafter using ASTM D-1945 or alternate procedure approved in writing by the Department, b. Determine the mass of VOC’s per standard cubic feet of fuel gas using the analysis conducted in condition 34.3(a),

c. Monitor the fuel gas stream flow rate by installing a calibrated rotometer, d. Record the actual fuel gas flow rate, ga s temperature, and gas pressure at least once each month,

e. Calculate the total VOC emissions (tons ) vented at Well Pad B each month using the recorded gas flow rate, gas te mperature, gas pressure, the most recent VOC content, and total numb er of hours in the month, f. Determine the total VOC quantity vented during the previous 12 months by summing the monthly VOC emissions, and
g. Report the VOC emissions in the F acility Operating Report required by Condition 83. [Construction Permit No. 0073-AC023, 7/13/01] [18 AAC 50.350(g) - (i), 7/2/00]
Fuel Consumption Monitoring

35. The Permittee shall monitor, record, and report fuel consumption at the stationary source as follows: [Operating Permit No. 9673-AA005, 1/17/97]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 30 of 61 35.1 Monitor and record the monthly total vol ume of fuel consumed by the turbines (Emission Unit ID(s) 1, 1A, and 2 combin ed), heaters (Emission Unit ID(s) 3 through 10 combined), engines (Emission Unit ID(s) 11 through 17 combined) and flares (Emission Unit ID(s) 18 and 18A co mbined). For the turbines, use the monitoring device required by condition 14.1 to measure the fuel consumption. For all other fuel-burning emission units, the Permittee may estimate fuel use.

35.2 Include with the stationary source operating report re quired under condition 83, the monthly fuel consumption (MMscf/mont h or gallons/month) for each of the combined emission unit groups stated in condition 35.1 and the monthly total quantity of fuel consumed at the stati onary source, for the period covered by the report. [18 AAC 350(g) – (i), 1/18/97]
Hours of Operation Monitoring for Fuel-fired Emission Units

36. The Permittee shall monitor, record, and report the hours of operation as follows: [Operating Permit No. 9673-AA005, 1/17/97]

36.1 Monitor and record the monthly operati ng time for each fuel-burning emission unit listed in Table 1, excluding flares.

36.2 Include with the stationary source operating report re quired under condition 83, the monthly hours of operation for each fuel- burning emission unit listed in Table 1, excluding flares. [18 AAC 350(g) – (i), 1/18/97]

37. Flaring. For flaring events the Permittee shall m onitor, record, and report as follows: [Construction Permit No. 0073-AC023, 7/13/01]

37.1 Calculate the monthly estimated emissions of PM, NO X , SO 2 , and CO using published emission factors.

37.2 Include with the stationary source operating report required under condition 83, copies of the calculations required under condition 37.1. [18 AAC 50.350(g) - (i), 6/21/98]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 31 of 61 Section 6. Visible Emissions and PM Monitoring, Recordkeeping and Reporting

38. Visible Emissions Monitoring. The Permittee shall observe th e exhaust of Emission Unit ID(s) 1, 2, 7, 8, 11 through 15, and 17, for visi ble emissions using the Method 9 Plan under condition 38.1.

38.1 Method 9 Plan. For all 18-minute observations in this plan, observe exhaust, following 40 C.F.R. 60, Appendix A-4, Meth od 9, adopted by reference in 18 AAC 50.040(a), for 18 minutes to obtain 72 consecu tive 15-second opacity observations.

a. First Method 9 Observation. For Emission Unit ID(s) 11 through 15, and 17, observe exhaust for 18 minutes within six m onths after the effec tive date of this permit.

b. Second Method 9 Observation. Observe exhaust while firing on liquid fuel per condition 38.1 within 30 days after the end of a calendar month in which the cumulative hours of operation on liquid fuel for the past 12 consecutive months exceed 400, except when an 18-minute Me thod 9 observation has already been conducted in accordance with condition 38.1 in the same 12 consecutive month period and the emission unit appears to not have excess visible emissions while in operation on liquid fuel.

c. Third Method 9 Observation. Observe exhaust while firing on liquid fuel per condition 38.1 within 30 days after the end of a calendar month in which the cumulative hours of operation on liquid fuel for the past 12 consecutive month period exceed 800.

d. Increased Method 9 Frequency. If a six-minute average opacity is observed during the most recent set of observations to be greater than 15 percent and one or more observations are greater than 20 pe rcent, then increase or maintain the 18-minute observation frequency for that emission unit to at least monthly intervals, until a six-minute average opac ity observed during the most recent set of observations is not greater than 15 percent or no more than one observation is greater than 20 percent.

39. Visible Emissions Recordkeeping. The Permittee shall keep reco rds in accordance with this condition.

39.1 When conducting the Method 9 observations of condition 38.1

a. the observer shall record

(i) the name of the stationary source, emission unit and lo cation, stationary source type, observer's name and aff iliation, and the date on the Visible Emissions Field Data Sheet in Section 14;Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 32 of 61 (ii) the time, estimated distance to the emissions location, approximate wind direction, estimated wind speed, descri ption of the sky condition (presence and color of clouds), plume background, and operating rate (load or fuel consumption rate) on the sheet at the time opacity observations are initiated and completed;

(iii) the presence or absence of an a ttached or detached plume and the approximate distance from the emissions outlet to the point in the plume at which the observations are made;

(iv) opacity observations to the nearest five percent at 15-second intervals on the Visible Emissions Observation Record in Section 14, and

(v) the minimum number of observations required by the permit; each momentary observation recorded shall be deemed to represent the average opacity of emissions for a 15-second period;

b. to determine the six-minute average opacity, divide the observations recorded on the record sheet into sets of 24 cons ecutive observations; sets need not be consecutive in time and in no case sha ll two sets overlap; fo r each set of 24 observations, calculate the average by summing the opacity of the 24 observations and dividing this sum by 24; record the average opacity on the sheet;

c. calculate and record the highest 18- consecutive-minute average observed.

40. Visible Emissions Reporting. The Permittee shall report visible emissions as follows:

40.1 include in each stationary sour ce operating report under condition 83

a. copies of the observation results (i.e . opacity observati ons), except for the observations the Permittee has already supplied to the Department; and

b. a summary to include:

(i) number of days observations were made;

(ii) highest six-minute average observed; and

(iii) dates when one or more observed six- minute averages were greater than 20 percent;

40.2 a summary of any monitoring or record keeping required under conditions 38 and 39 that was not done;

40.3 report under condition 81:Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 33 of 61 a. the results of Method 9 observations that exceed an average 20 percent for any six-minute period; and

b. if any monitoring under condition 38 was not performed when required. [18 AAC 50.346(c) & 50.350(g) – (i), 5/3/02]

41. Particulate Matter Monitoring for Liquid Fuel Fired Heaters. The Permittee shall conduct source tests on liquid fuel fired Emi ssion Unit ID(s) 7 and 8, to determine the concentration of particulate matter (PM) in the exhaust of an emission unit in accordance with the following.

41.1 Within six months of exceeding the criteria of condition 41.2, either

a. conduct a PM source test according to requi rements set out in Section 10; or

b. make repairs so that emissions no longe r exceed the criteri a of condition 41.2; to show that emissions are below those criteria, observe emissions as described in condition 38.1 under load conditions comp arable to those when the criteria were exceeded.

41.2 Conduct the test according to condition 41.1 if 18 consecutive minutes of Method 9 observations result in an 18-minute aver age opacity greater than 20 percent.

41.3 During each one hour PM source test run, observe the exhaust for 18 minutes in accordance with Method 9 and calculate th e average opacity that was measured during each one-hour test run. Submit a c opy of these observations with the source test report.

41.4 The automatic PM source test requirement in conditions 41.1 and 41.2 is waived for an emissions unit if a PM source test on th at unit has shown compliance with the PM standard during this permit term.

42. Particulate Matter Reporting for Liquid Fuel Fired Heaters. The Permittee shall report for liquid fuel fired Emissi on Unit ID(s) 7 and 8 as follows:

42.1 report under condition 81

a. the results of any PM source test that exceeds the PM emissions limit; or

b. if one of the criteria of condition 41.2 was exceeded and the Permittee did not comply with either condition 41.1a or 41.1b;

42.2 in each stationary source operati ng report under condition 83, include

a. the dates, Emission Unit ID(s), and results when an observed 18-minute average was greater than an appl icable threshold in condition 41.2;

b. a summary of the results of any PM testing under condition 41; andPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 34 of 61 c. copies of any visible em issions observation result s (opacity observations) greater than the thres holds of condition 41.2, if they were not already submitted.

43. Particulate Matter Monitoring for Diesel Engines and Liquid Fuel Fired Turbines. The Permittee shall conduct source tests on Emission Unit ID(s) 1, 2, 11 through 15, and 17, to determine the concentration of particulat e matter (PM) in the exhaust of an emission unit in accordance with the following.

43.1 Within six months of exceeding the crit eria of condition 43.2a or 43.2b, either

a. conduct a PM source test according to requi rements set out in Section 10; or

b. make repairs so that emissions no longe r exceed the criteri a of condition 41.2; to show that emissions are below those criteria, observe emissions as described in condition 38.1 under load conditions comp arable to those when the criteria were exceeded.

43.2 Conduct the test according to condition 41.1 if

a. 18 consecutive minutes of Method 9 obs ervations result in an 18-minute average opacity greater than 20 percent, or

b. for an emission unit with an exhaust stack diameter that is less than 18 inches, 18 consecutive minutes of Method 9 obs ervations result in an 18-minute average opacity that is greater than 15 percent and not more than 20 percent, unless the Department has waived this requirement in writing.

43.3 During each one-hour PM source test run, observe the exhaust for 18 minutes in accordance with Method 9 and calculate the average opacity that was measured during each one-hour test run. Submit a c opy of these observations with the source test report.

43.4 The automatic PM source test requirement in conditions 41.1 and 41.2 is waived for an emissions unit if a PM source test on th at unit has shown compliance with the PM standard during this permit term.

44. Particulate Matter Recordkeeping for Di esel Engines and Liquid Fuel Fired Turbines. Within 180 calendar days after the effec tive date of this permit, the Permittee shall record the exhaust stack diameter(s) of Emission Un it ID(s) 1, 2, 11 through 15, and 17. Report the stack diameter(s) in th e next operating report under condition 83.

45. Particulate Matter Reporting for Diesel Engines and Liquid Fuel Fired Turbines. The Permittee shall report for Emission Un it ID(s) 1, 2, 11 through 15, and 17 as follows:

45.1 Report under condition 81

a. the results of any PM source test that exceeds the PM emissions limit; orPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 35 of 61 b. if one of the criteria of condition 41.2 was exceeded and the Permittee did not comply with either condition 41.1a or 41.1b;

45.2 Report observations in excess of the thresh old of condition 43.2b within 30 days of the end of the month in which the observations occur;

45.3 Include in each stationary source operating report under condition 83,

a. the dates, Emission Unit ID(s), and results when an observed 18-minute average was greater than an appl icable threshold in condition 41.2;

b. a summary of the results of any PM testing under condition 41; and

c. copies of any visible em issions observation result s (opacity observations) greater than the thres holds of condition 41.2, if they were not already submitted. [18 AAC 50.346(c) & 50.350(g) – (i), 5/3/02]
Flares (Emission Unit ID 18 and 18A)

46. Visible Emissions Monitoring, Recordkeeping, and Reporting . The Permittee shall observe the first six daylight flare events 8 occurring during the life of this permit 9

.

46.1 Monitor flare events using Method-9 for 18 minutes to obtain 72 individual 15- second readings.

46.2 Record the following information for observed events:

a. the flare(s) Emission Unit ID number;

b. results of the Method-9 observations;

c. reason(s) for flaring;

d. date, beginning and ending time of event; and

e. cumulative volume of gas flared.

46.3 Monitoring of a flare event may be post poned for safety or weather reasons, or because a qualified observer is not available. Until monitoring has been completed on the six flare events described in this condition, the Permittee shall either monitor each qualifying flare event or include in the next stationary source operating report required by condition 83 an explanation of the reason the event was not monitored.

8 For purposes of this permit, a “flare event” is flaring of gas for greater than one hour as a result of scheduled

release operations, i.e. maintenance or well testing ac tivities. It does not include non-scheduled release operations, i.e. process upsets, emergency flaring, or de minimis venting of gas incidental to normal operations.
9 Flare events monitored within 12-months prior to perm it effective date may count towards the six-event total.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 36 of 61 46.4 Attach copies of the records required by condition 46.2 with th e stationary source operating report required by condition 83.

46.5 Report under condition 81 whenever the opac ity standard in condition 3 is exceeded. [18 AAC 50.350(g) – (i), 5/3/02]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 37 of 61 Section 7. Stationary Source-Wide Requirements

47. Prohibitions - Significant New Al ternatives Policy Programs. The Permittee shall comply with the prohibitions set out in 40 C.F.R. 82.174(b) through (d) (Protection of Stratospheric Ozone Subpart G - Significan t New Alternatives Pr ogram) pertaining to substitute products for ozone-depleting com pounds. Monitor by certifying annually that the Permittee complies with these prohibitions. [18 AAC 50.040(d) and 50.350(d)(1), 1/18/97] [40 C.F.R. 82.174(b) - (d), 1/13/95]

48. Prohibitions - Halon Emissions Reduction. The Permittee shall comply with the prohibitions set out in 40 C. F.R. 82.270(b) through (f) (P rotection of Protection of Stratospheric Ozone Subpart H - Halon Emi ssions Reduction). Monitor by certifying annually that the Permittee comp lies with these prohibitions. [18 AAC 50.040(d) and 50.350(d)(1), 1/18/97] [40 C.F.R. 82.270(b) - (f), 3/5/98]

49. Emission Unit Aggregation. The Permittee shall aggregate potential emissions from CFP, B-pad, and E-pad at the Milne Point Unit for the purpose of determining applicability with the modification requirements of 18 AAC 50.300(h)(3). This condition is not federally enforceable. [18 AAC 50.990(37), 1/18/97] [18 AAC 50.910, 1/18/97]

50. Notification Requirements. Notwithstanding the regulations set forth in 18 AAC 50.300(h), the Permittee shall notify the Department, in accordance with condition 51, prior to: [Construction Permit No. 0073-AC023, 7/13/01]

50.1 installing a stationary source at the stationa ry source that is not listed in Table 1of this permit;

50.2 making a change to an emission unit listed in Table 1 that would cause it to deviate from the description of it provided in Table 1; or

50.3 making a change to the emission characteristics of an emission unit listed in Table 1, including adding waste heat recovery, in a manner that would increase the ambient air quality impact.

51. Notification Procedures. The Permittee shall use the following procedures when notifying the Department pursuant to condition 50: [Construction Permit No. 0073-AC023, 7/13/01]

51.1 For changes described by 18 AAC 50.370(a) , notify the Department in accordance with 18 AAC 50.370(b). The Permittee may implement the changes in accordance with 18 AAC 50.370(c).

51.2 For all other changes,Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 38 of 61 a. ask the Department if additional ambient impact assessment modeling is warranted for the proposed change;

b. within 60 days of receiving written Department notice that modeling is warranted, prepare and submit to the Department an ambient impact assessment for the specified air pollutan t and averaging period; and

c. do not make the change until the Departme nt concurs that the change will not interfere with attainment or maintenan ce of ambient air quality standards and maximum allowable ambient concentrations.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 39 of 61 Section 8. Insignifica nt Emission Units
This section contains the requirements that the Permittee identified under 18 AAC 50.335(q)(2) as applicable to insignificant emission units at th e stationary source. This section also specifies the testing, monitoring, recordk eeping, and reporting for insigni ficant emission units that the Department finds necessary to ensure compliance w ith the applicable requirements. Insignificant emission units are not exempted from any ai r quality control requirement or federally enforceable requirement.

As set out in 18 AAC 50.350(m), the shield of AS 46.14.290 does not apply to these emission units.

52. For emission units at the stationary source th at are insignificant as defined in 18 AAC 50.335(q)-(v) that are not listed in this permit, the following apply:

52.1 The Permittee shall submit the compliance certifications of condition 84 based on reasonable inquiry;

52.2 The Permittee shall comply with the requirements of condition 64;

52.3 The Permittee shall report in the stati onary source operating report required by condition 83 if an emission unit listed in this condition 52, because of actual emissions less than the thresholds of 18 AAC 50.335(r), has actual emissions greater than any of those thresholds set out in 18 AAC 50.335(r).

52.4 No other monitoring, recordkeep ing or reporting is required.
[18 AAC 50.346(b)(1), 5/3/02]

53. The Permittee shall not cause or allow vi sible emissions, excluding condensed water vapor, emitted from an industrial process, fu el-burning equipment, or an incinerator to reduce visibility through the exhaus t effluent by any of the following:

53.1 more than 20% for more than three minutes in any one hour 10

, [18 AAC 50.055(a)(1), 1/18/97, 40 CFR 52.70, 11/18/98]

53.2 more than 20% averaged over any six consecutive minutes.
[18 AAC 50.055(a)(1), 5/3/02]

54. The Permittee shall not cause or allow particul ate matter emitted from an industrial process or fuel-burning equipment to exceed 0.05 grains per cubic foot of exhaust gas corrected to standard conditions and averaged over three hours.
[18 AAC 50.055(b)(1), 1/18/97]

55. The Permittee shall not cause or allow su lfur compound emissions, expressed as SO 2 , from an industrial process or fuel-burning equipm ent, to exceed 500 ppm averaged over three hours.
[18 AAC 50.055(c), 1/18/97]

10 See Footnote 1.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 40 of 61 Section 9. Generally Applicable Requirements

56. NESHAPs Subpart A, Applicability Determination. The Permittee shall determine rule applicability and designation of affected emission units unde r National Emission Standards for Hazardous Air Pollutants (NESHAPs) fo r Source Categories (40 CFR 63) in accordance with the procedures described in 40 CFR 63.1(b).

56.1 NESHAPS Subpart A, Recordkeeping . The Permittee shall maintain records in accordance with §63.10(b)(3). [40 C.F.R. 63.1(b) & C.F.R. 63.10(b)(3), 7/1/01] [18 AAC 50.040(c)(1)(A) & 50.040(c(1)(E ), 7/2/00; 18 AAC 50.350(h), 1/18/97]

57. Asbestos NESHAP. The Permittee shall comply with the requirements set forth in 40 C.F.R. 61.145 and 61.150 (Subpart M) and th e applicable sections set forth in 40 C.F.R. 61, Subpart A and Appendix A. [18 AAC 50.040(b)(3) & 50.350(d)(1), 1/18/97] [40 C.F.R. 61, Subparts A & M, and Appendix A, 12/19/96]

58. Refrigerant Recycling and Disposal. The Permittee shall comply with the applicable standards for recycling and emission reduction of refrigerants set forth in 40 C.F.R. 82, Subpart F. Applicable requireme nts include 40 CFR 82.154, 82.156, 82.161, 82.162, and 82.166. [18 AAC 50.040(d) & 50.350(d)(1), 1/18/97] [40 C.F.R. 82, Subpart F, 7/1/97]

59. Good Air Pollution Control Practice. The Permittee shall do the following for Emission Unit ID(s) 5 through 25:

a. Perform regular maintenance consideri ng the manufacturer’s or the operator’s maintenance procedures;

b. Keep records of any maintenance that would have a significant effect on emissions; the records may be kept in electronic format;

c. Keep a copy of either the manufacturer’s or the operator’s maintenance procedures. [18 AAC 50.030 & 50.346(b)(2), 5/3/02 & 18 AAC 50.350(f)(2) & (3), 1/18/97]

60. Dilution. The Permittee shall not dilute emissions w ith air to comply with this permit. Monitoring shall consist of an annual certif ication that the Permittee does not dilute emissions to comply with this permit. [18 AAC 50.045(a), 1/18/97]

61. Reasonable Precautions to Prevent Fugitive Dust. The Permittee shall take reasonable precautions to prevent particulate matter from being emitted into the ambient air when causing or permitting bulk materials to be handled, transported, or stored, or when engaging in an industrial activity or construction project. Mo nitoring shall consist of an annual certification that reas onable precautions were taken.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 41 of 61 [18 AAC 50.346(c), 5/3/02; 18 AAC 50.045(d) & 50 .335(g), 1/18/97 & 18 AAC 50.040(e), 7/2/00]

62. Stack Injection. The Permittee shall not release materials other than process emissions, products of combustion, or materials introduced to control pollutant emissions from a stack at an emission unit constructed or modifi ed after November 1, 1982, unless approved in writing by the Department. Monitoring shall co nsist of an annual ce rtification that the Permittee does not conduct stack inje ction at the stationary source. [18 AAC 50.055(g), 1/18/97]

63. Open Burning. The Permittee shall conduct any open burni ng at the stationary source in accordance with the requirements of 18 AAC 50.065. Monitoring shall consist of an annual certification that any ope n burning complied with 18 AAC 50.065. [18 AAC 50.040(e), 7/21/01, 18 AAC 50.065, 7/21/01, 18 AAC 50.350(d)(1), 1/18/97]

64. Air Pollution Prohibited. No person may permit any emission which is injurious to human health or welfare, animal or plant life, or property, or which would unreasonably interfere with the enjoym ent of life or property. [18 AAC 50.346(a)(2), 5/3/02; 18 AAC 50.110, 5/26/72; 18 AAC 50.040(e), 7/2/00]

64.1 If emissions present a potential threat to human health or safety, the Permittee shall report any such emissions according to condition 81.

64.2 As soon as practicable after becoming aware of a complaint that is attributable to emissions from the stationary source, the Pe rmittee shall investigate the complaint to identify emissions that the Permittee belie ves have caused or are causing a violation of condition 64.

64.3 The Permittee shall initiate and complete co rrective action necessary to eliminate any violation identified by a comp laint or investigation as soon as practicable if

a. after an investigation because of a complaint or other reason, the Permittee believes that emissions from the stationa ry source have caused or are causing a violation of condition 64; or

b. the Department notifies the Permittee th at it has found a violation of condition 64.

64.4 The Permittee shall keep records of

a. the date, time, and nature of all emissions complaints received;

b. the name of the person or persons that complained, if known;

c. a summary of any investigation, including reasons the Permittee does or does not believe the emissions have caused a violation of condition 64; and

d. any corrective actions taken or planned fo r complaints attributable to emissions from the stationary source.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 42 of 61 64.5 With each stationary source operating report required under condition 83, the Permittee shall include a brief summa ry report which must include

a. the number of complaints received;

b. the number of times the Permittee or the Department found corrective action
necessary;

c. the number of times action was taken on a complaint within 24 hours; and

d. the status of corrective actions the Permittee or Department found necessary that were not taken within 24 hours.

64.6 The Permittee shall notify the Department of a complaint that is attributable to emissions from the stationary source w ithin 24 hours after receiving the complaint, unless the Permittee has initiated correctiv e action within 24 hour s of receiving the complaint. [18 AAC 50.346(a)(2) & 50.350(g) - (i), 5/3/02]

65. Technology-Based Emission Standard. If an unavoidable emergency, malfunction, or non-routine repair, as defined in 18 AAC 50.235, causes emissions in excess of a technology-based emission standard 11 , the Permittee shall take all reasonable steps to minimize levels of emissions that exceed th e standard. Excess emissions reporting under condition 81 requires information on the steps taken to minimize emissions. The report required under condition 81 is adequate mon itoring for compliance under this condition. [18 AAC 50.235(a) & 50.350(f)(3), 1/18/97]

66. Permit Renewal . To renew this permit, the Permittee shall submit an application under 18 AAC 50.335 no sooner than November 13, 2006 and no later than November 13, 2007. [18 AAC 50.335(a), 1/18/97]

11 Technology-based emission standard means a best available control te chnology standard (BACT); a lowest achievable emission rate standard (LAER); a maximum achievable control technology standard established 40 C.F.R. 63, Subpart B, adopted by reference in 18 AAC 50.040(c); a standard adopted by reference in 18 AAC 50.040(a) or (c); and any other similar standard for which the stringency of the standard is based on determinations of what is technologically feasible, considering relevant factors. [18 AAC 50.990(91)]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 43 of 61 Section 10. General Source Test ing and Monitoring Requirements

67. Requested Source Tests. In addition to any source testing explicitly required by the permit, the Permittee shall c onduct source testing as reque sted by the Department to determine compliance with applicable permit requirements. [18 AAC 50.220(a), 1/18/97 & 18 AAC 50.345(a) & (k), 5/3/02]

68. Operating Conditions. Unless otherwise specified by an applicable requirement or test method, the Permittee shall conduct source testing [18 AAC 50.220(b) & 50.350(g), 1/18/97]

68.1 at a point or points that characterize the actual discharge into the ambient air; and

68.2 at the maximum rated burning or operating capacity of the emission unit or another rate determined by the Department to ch aracterize the actual discharge into the ambient air.

69. Reference Test Methods. The Permittee shall use the followi ng as reference test methods when conducting source testing for compliance with this permit:

69.1 Source testing for compliance with re quirements adopted by reference in 18 AAC 50.040(a) must be conducted in accordance with the methods and procedures specified in 40 C.F.R. 60. [18 AAC 50.220(c)(1)(A) & 50.350(g), 1/18/97 & 18 AAC 50.040(a), 8/15/02] [40 C.F.R. 60, 7/1/01]

69.2 Source testing for compliance with re quirements adopted by reference in 18 AAC 50.040(b) must be conducted in accordance with the methods and procedures specified in 40 C.F.R. 61. [18 AAC 50.040(b), 8/15/02; 50.220(c)(1)(B) & 50.350(g), 1/18/97] [40 C.F.R. 61, 7/1/01]

69.3 Source testing for compliance with re quirements adopted by reference in 18 AAC 50.040(c) must be conducted in acco rdance with the source test methods and procedures specified in 40 C.F.R. 63. [18 AAC 50.040(c), 8/15/02, 18 AAC 50.220(c)(1)(C) & 50.350(g), 1/18/97] [40 C.F.R. 63, 7/1/01]

69.4 Source testing for reduction in visibility through the exhaust effluent must be conducted in accordance with the procedures set out in Reference Method 9. [18 AAC 50.030, 5/3/02, 18 AAC 50.220(c)(1)(D) & 50.350(g), 1/18/97]

69.5 Source testing for emissions of total particulate matter, sulfur compounds, nitrogen compounds, carbon monoxide, lead, volatile or ganic compounds, fluorides, sulfuric acid mist, municipal waste combustor orga nics, metals, and acid gases must be conducted in accordance with the methods and procedures specified in 40 C.F.R. 60, Appendix A. [18 AAC 50.040(a)(4), 8/15/02 & 18 AAC 50.220(c)(1)(E) & 50.350(g), 1/18/97] [40 C.F.R. 60, Appendix A, 7/1/01]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 44 of 61 69.6 Source testing for emissions of PM-10 mu st be conducted in accordance with the procedures specified in 40 C. F.R. 51, Appendix M, Method 201. [18 AAC 50.035(b)(2), 7/2/00; 18 AAC 50.220(c)(1)(F) & 50.350(g), 1/18/97] [40 C.F.R. 51, Appendix M, 7/1/01]

69.7 Source testing for emissions of any pollutant may be determined using an alternative method approved by the Department in accordance with 40 C.F.R. 63 Appendix A, Method 301. [18 AAC 50.040(c)(19), 8/15/02 & 18 AAC 50.220(c)(2) & 50.350(g), 1/18/97] [40 C.F.R. 63, Appendix A, Method 301, 4/5/02]

70. Excess Air Requirements. To determine compliance with this permit, standard exhaust gas volumes must include only the volume of gases formed from the theoretical combustion of the fuel, plus the excess air volume normal for the specific source type, corrected to standard conditions (dry gas at 68° F and an absolute pressure of 760 millimeters of mercury). [18 AAC 50.220(c)(3), 18 AAC 50.350(g), 1/18/97 & 18 AAC 50.990(88), 5/3/02]

71. Test Exemption. The Permittee is not required to comply with conditions 73, 74 and 75 when the exhaust is observ ed for visible emissions. [18 AAC 50.345(a), 5/3/02]

72. Test Deadline Extension. The Permittee may request an extension to a source test deadline established by the Department. The Permittee may delay a source test beyond the original deadline only if the extension is approved in writing by the Department’s appropriate division di rector or designee. [18 AAC 50.345(a) & (l), 5/3/02]

73. Test Plans. Except as provided in condition 71, befo re conducting any source tests, the Permittee shall submit a plan to the Department . The plan must include the methods and procedures to be used for sampling, testing, and quality assurance and must specify how the emission unit will operate during the te st and how the Permittee will document that operation. The Permittee shall submit a complete plan within 60 days after receiving a request under condition 67 and at least 30 days before the scheduled date of any test unless the Department agrees in writing to some other time period. Retesting may be done without resubmitting the plan. [18 AAC 50.345(a) & (m), 5/3/02]

74. Test Notification. Except as provided in condition 71, at least 10 days before conducting a source test, the Permittee shall give the Department written notice of the date and the time the source test will begin. [18 AAC 50.345(a) & (n), 5/3/02]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 45 of 61 75. Test Reports. Except as provided in condition 71, within 60 days after completing a source test, the Permittee shall submit two copies of the results in the format set out in the Source Test Report Outline , adopted by reference in 18 AAC 50.030. The Permittee shall certify the results in the manner set out in condition 77. If requested in writing by the Department, the Permittee must provide preliminary results in a shorter period of time specified by the Department. [18 AAC 50.345(a) & (o), 5/3/02]

76. Particulate Matter Calculations. In source testing for complia nce with the particulate matter standards in conditions 4 and 54, the th ree-hour average is determined using the average of three one-hour test runs. [18 AAC 50.220(f) & 50.350(g), 1/18/97]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 46 of 61 Section 11. General Recordkeeping, Re porting, and Compliance Certification Requirements

77. Certification. The Permittee shall certify all reports, compliance certifications, or other documents submitted to the Department and required under the permit by including the signature of a responsible official for the permitted stationary source following the statement: “Based on information and belief fo rmed after reasonable inquiry, I certify that the statements and information in and attach ed to this document are true, accurate, and complete." Excess emission reports must be certified either upon submittal or with an operating report required for the same repor ting period. All other reports and other documents must be certified upon submittal. When certifying a co mpliance certification, the official’s signature must be notarized. [18 AAC 50.205 and 50.350(b)(3) & (j), 1/18/97; and 18 AAC 50.345(a) & (j), 5/3/02]

78. Submittals. Unless otherwise directed by the Department or this permit, the Permittee shall send reports, compliance certifications, and other documents required by this permit to ADEC, Air Permits Program, 610 Univer sity Ave., Fairbanks, AK 99709-3643, ATTN: Compliance Technician. [18 AAC 50.350(i), 1/18/97]

79. Information Requests. The Permittee shall furnish to the Department, within a reasonable time, any information the Departme nt requests in writing to determine whether cause exists to modify, revoke and reissue, or terminate the permit or to determine compliance with the permit. Upon request, th e Permittee shall furnish to the Department copies of records required to be kept by the permit. The Department may require the Permittee to furnish copies of those record s directly to the federal administrator. [18 AAC 50.200 & 50.350(b)(3), 1/18/97; and 18 AAC 50.345(a) & (i) & 50.350(g) – (i), 5/3/02]

80. Recordkeeping Requirements. The Permittee shall keep al l records required by this permit for at least five years after the date of collection, including: [18 ACC 50.350(h), 5/3/02] [40 C.F.R. 60.7(f), Subpart A, 7/1/01]

80.1 copies of all reports and certifications submitted pursuant to this section of the permit; and

80.2 records of all monitoring required by th is permit, and information about the monitoring including:

a. calibration and maintenance records, original strip chart or computer-based recordings for continuous m onitoring instrumentation;

b. sampling dates and times of sampling or measurements;

c. the operating conditions that existed at the time of sampling or measurement;

d. the date analyses were performed;Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 47 of 61 e. the location where samples were taken;

f. the company or entity that performed the sampling and analyses;

g. the analytical techniques or met hods used in the analyses; and

h. the results of the analyses.

81. Excess Emissions and Permit Deviation Reports.

81.1 Except as provided in condition 64, the Permittee shall report all emissions or operations that exceed or deviate from th e requirements of this permit as follows:

a. in accordance with 18 AAC 50.240(c), as soon as possible after the event commenced or is discovered, report

(i) emissions that present a potential thr eat to human health or safety; and

(ii) excess emissions that the Permitt ee believes to be unavoidable;

b. in accordance with 18 AAC 50.235(a), within two working days after the event commenced or was discovered, report an unavoidable emergency, malfunction, or nonroutine repair that causes emissions in excess of a technology based emission standard;

c. report all other excess emissions and permit deviations

(i) within 30 days of the end of the mont h in which the emissions or deviation occurs or is discovered, except as provided in conditions 81.1c(ii) and 81.1c(iii);

(ii) if a continuous or recu rring excess emissions is not corrected within 48 hours of discovery, within 72 hours of discovery unless the Department provides written permission to re port under condition 81.1c(i); and

(iii) for failure to monitor, as required in other applicable conditions of this permit.

81.2 When reporting excess emissions, the Pe rmittee must report using either the Department’s on-line form, which can be found at www.dec.state.ak.us/awq/excess/report.asp, or, if the Permittee prefers, the form contained in Section 16 of this permit. The Permittee must provide all information called for by the form that is used.

81.3 When reporting a permit deviation, the Permittee must report using the form contained in Section 16 of this permit. The Permittee must provide all information called for by the form.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 48 of 61 81.4 If requested by the Department, the Permitt ee shall provide a more detailed written report as requested to follow up an excess emissions report. [18 AAC 50.235(a)(2), 50.240(c), & 50.350(i), 1/18/97; and 18 AAC 50.346(a)(3), 5/3/02 ]

82. NSPS and NESHAP Reports. The Permittee shall: [18 AAC 50.040, 8/15/02; & 50.350(i)(2), 1/18/97; and 40 C.F.R. 60 & 61, 7/1/01]

82.1 attach to the stationary source operating report require d by condition 83, copies of any NSPS and NESHAPs reports submitted to the U.S. Environmental Protection Agency (EPA) Region 10 unless copies have already been provided to the Department at the time submitted to EPA, and

82.2 upon request by the Department provide a c opy of any EPA-granted waiver of the federal emission standards, record keep ing, monitoring, performance testing, or reporting requirements, or approve d custom monitoring schedules.

83. Operating Reports. During the life of this permit, the Permittee shall submit to the Department an original and two copies of an operating report by April 30 for the period January 1 to March 31, by July 30 for the pe riod April 1 to June 30, by October 30 for the period July 1 to September 30, and by Februa ry 14 for the period October 1 to December 31 of the previous year.

83.1 The operating report must include all inform ation required to be in operating reports by other conditions of this permit.

83.2 If excess emissions or permit deviations th at occurred during the reporting period are not reported under condition 83.1, either

a. The Permittee shall identify

(i) the date of the deviation;

(ii) the equipment involved;

(iii) the permit condition affected;

(iv) a description of the excess emi ssions or permit deviation; and

(v) any corrective action or preventive m easures taken and the date of such actions; or

b. When excess emissions or permit deviat ions have already been reported under condition 81 the Permittee may cite the date or dates of those reports.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 49 of 61 83.3 The operating report must include a listing of emissions monitored under condition 38 which trigger additional test ing or monitoring, whether or not the emissions monitored exceed an emission stan dard. The Permittee shall include in the report

a. the date that additional monitori ng or testing was triggered;

b. the equipment involved;

c. the permit condition affected; and

d. the monitoring result which triggered the additional monitoring. [18 AAC 50.346(b)(3), 5/3/02; 18 AAC 50.350(d)(4), 6/21/98; and 18 AAC 50.350(f)(3) & (i), 1/18/97]

84. Annual Compliance Certification. Each year by March 31, and for reporting periods following the effective date of this permit the Permittee shall compile and submit to the Department an original and two copies of an annual compliance certification report as follows: [18 AAC 50.350(j), 1/18/97]

84.1 For each permit term and condition set fo rth in Section 4 through Section 11, including terms and conditions for m onitoring, reporting, and recordkeeping: [18 AAC 50.350(d)(4), 6/21/98]

a. certify the compliance status over the pr eceding calendar year consistent with the monitoring required by this permit;

b. state whether compliance is intermittent or continuous;

c. briefly describe each method used to determine the compliance status; and

d. notarize the responsible official’s signature. [18 AAC 50.205, 1/18/97 & 50.345(a) & (j), 5/3/02]

84.2 In addition, submit a copy of the report di rectly to the EPA-Region 10, Office of Air Quality, M/S OAQ-107, 1200 Sixth Av enue, Seattle, WA 98101. [18 AAC 50.350(j), 1/18/97]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 50 of 61 Section 12. Standard Conditions Not Otherwise Included in the Permit

85. The Permittee must comply with each permit term and condition. Noncompliance with a permit term or condition constitutes a viol ation of AS 46.14, 18 AAC 50, and, except for those terms or conditions designated in the pe rmit as not federally enforceable, the Clean Air Act, and is grounds for

85.1 an enforcement action;

85.2 permit termination, revocation and reissuan ce, or modification in accordance with AS 46.14.280; or

85.3 denial of an operating-pe rmit renewal application. [18 AAC 50.350(b)(3), 1/18/97 & 18 AAC 50.345(a) & (c), 5/3/02]

86. It is not a defense in an enforcement action to claim that it would have been necessary to halt or reduce the permitted activity in order to maintain compliance with a permit term or condition. [18 AAC 50.350(b)(3), 1/18/97 & 18 AAC 50.345(a) & (d), 5/3/02]

87. Each permit term and condition is independent of the permit as a whole and remains valid regardless of a challenge to a ny other part of the permit. [18 AAC 50.350(b)(3), 1/18/97 & 18 AAC 50.345(a) & (e), 5/3/02]

88. Compliance with permit terms and conditions is considered to be compliance with those requirements that are

88.1 included and specifically iden tified in the permit; or

88.2 determined in writing in the permit to be inapplicable. [18 AAC 50.350(b)(3), 1/18/97 & 18 AAC 50.345(a) & (b), 5/3/02]

89. The permit may be modified, reopened, revoked a nd reissued, or terminated for cause. A request by the Permittee for modi fication, revocation and reissu ance, or termination or a notification of planned change s or anticipated noncomplia nce does not stay any permit condition. [18 AAC 50.350(b)(3), 1/18/97 & 18 AAC 50.345(a) & (f), 5/3/02]

90. The permit does not convey any property rights of any sort, nor any exclusive privilege. [18 AAC 50.350(b)(3), 1/18/97 & 18 AAC 50.345(a) & (g), 5/3/02]

91. The Permittee shall allow the Department or an inspector authorized by the Department, upon presentation of credentials and at reasonable times with the consent of the owner or operator to

91.1 enter upon the premises where an emission un it subject to the permit is located or where records required by the permit are kept;Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 51 of 61 91.2 have access to and copy any records required by the permit;

91.3 inspect any stationary source, equipment, practices, or operations regulated by or referenced in the permit; and

91.4 sample or monitor substances or parameters to assure compliance with the permit or other applicable requirements. [18 AAC 50.350(b)(3), 1/18/97 & 18 AAC 50.345(a) & (h), 5/3/02]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 52 of 61 Section 13. Permit As Shield fr om Inapplicable Requirements

In accordance with AS 46.14.290, and based on inform ation supplied in the stationary source application, this secti on of the permit contains the require ments determined by the Department not to be applicable to the Milne Point Production Facility.

Table 6 identifies the emission units that are not subject to the sp ecified requirements at the time of permit issuance. Some of the requirements listed below may become applicable during the permit term due to an invoking even t, even though the requirement is deemed inapplicable at the time of permit issuance.

92. If any of the requirements listed in Table 6 become applicable during the permit term, the Permittee shall comply with such requirements on a timely basis. The Permittee shall also provide appropriate notification to EPA, and apply for a construction permit or an operating permit revision, if necessary.

Table 6 - Permit Shields Granted. Non Applicable Requirements Reason Non-Applicable

All Gas-Fired Heaters 40 CFR 60 Subpart D Heat input capacities below threshold (250 MMBtu/hr); and units not classified as Fossil-Fuel-Fired Steam Generators , as defined in subpart 40 CFR 60 Subpart Da Heat input capacities below threshold (250 MMBtu/hr); and units not classified as Fossil-Fuel-Fired Steam Generators , as defined in subpart 40 CFR 60 Subpart Db Heat input capacities below threshold (100 MMBtu/hr); and commenced prior to effective date of subpart Heaters: H-4510A, H-4510B, H-5701A, H-5701B, H-2001A, and H-2001B 40 CFR 60 Subpart Dc Commenced construction prior to effective date of subpart (6/9/89) Heaters: H-5302A and H-5302B 40 CFR 60 Subpart A: §60.7(a)(1), (2), & (3) 40 CFR 60 Subpart Dc: §60.48c(a)(1) (Initial Notification Only) Obsolete requirements – completed as required.

40 CFR 60 Subpart A: §60.7(a)(4) This requirement only applies to “existing facilities, “ as defined in 40 CFR 62. 40 CFR 60 Subpart A: §60.7(c)&(d) The provisions of 60.7(c)&(d) apply only to New Source Performance Standards which require the installation of a continuous monitoring system (CMS) or monitoring device, as defined in 60.2; BPX is not required to install a CMS or monitoring device per Subpart Dc 40 CFR 60 Subpart A: §60.8 40 CFR 60 Subpart Dc: §§60.42c, 60.43c, 60.44c, 60.45c, 60.46c, 60.47c, 60.48c(a)(4), (b) - (f) & (h) Standards for SO 2 and PM and related performance test, monitoring, and reporting requirements not applicable for affected stationary source fired on fuel gas

40 CFR 60 Subpart Dc: §60.48c(a)(2) – (3) Stationary source is not subject to any requirements that limit the annual capacity factor for any fuel or mixture of fuels – stationary source fires only fuel gas.

All Storage Tanks 40 CFR 60 Subpart K Commenced construction after effective date(s) of subpart (5/19/78)Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 53 of 61 Non Applicable Requirements Reason Non-Applicable 40 CFR 60 Subpart Ka Commenced construction after effective date(s) of subpart (7/23/84) Storage Tanks #1 (Produced Water Surge Tank), T-6001, and T-6101B 40 CFR 60 Subpart Kb Contents stored prior to custody transfer, therefore vessel is exempt from the subpart Storage Tanks: T-6101A and T-2002 40 CFR 60 Subpart A 40 CFR 60 Subpart Kb: §§60.112b, 60.113b, 60.114b, 60.115b, 60.116b(c)- (g) T-6101A: Except as specified in paragraphs (a) and (b) of 60.116b, vessels with a capacity of > or = 151 cubic meters storing a liquid with a maximum true vapor pressure < 3.5 kPa (0.5 psia) are exempt from General Provisions – Subpart A, and from the provisions of Subpart Kb T-2002: Except as specified in paragraphs (a) and (b) of 60.116b, vessels with a capacity < 75 cubic meters are exempt from General Provisions – Subpart A, and from the provisions of Subpart Kb Turbines: PU-0701 and PU-0801 40 CFR 60 Subpart GG: §60.332(a)(1) Standard only applies to Electric Utility Stationary Gas Turbines

, as defined in subpart – emission unit is not an Electric Utility Stationary Gas Turbine as defined in Subpart GG 40 CFR 60 Subpart GG: §60.332(a)(2) when firing liquid (emergency) fuel Standard does not apply when firing emergency fuel as defined in subpart. 40 CFR 60 Subpart GG: §§60.334(b), 60.335(a) for fuel-bound Nitrogen testing of fuel gas only EPA Region X waived fuel-bound nitrogen monitoring for NSPS affected stationary gas turbines operated by BPXA at Milne Point (ref. correspondence dated August 28, 2002;). No shield is provided for sulfur monitoring requirements in these subparts. 40 CFR 60 Subpart A: §60.7(a)(1), (2), & (3) (Initial Notification Only) Obsolete requirements – completed as required.

40 CFR 60 Subpart A: §60.7(a)(4) This requirement only applies to “existing facilities”, as defined in 40 CFR 60.2 40 CFR 60 Subpart A: §60.8(a) 40 CFR 60 Subpart GG: §§60.335(b), (c)(1), (c)(3) (Initial Performance Test Only) Obsolete requirements – completed as required.

All Flares 40 CFR 60 Subpart A: §60.18 These flares ar e not control devices us ed to comply with applicable Subparts of 40 CFR 60 and 40 CFR 61 Stationary source-Wide 40 CFR 60 Subpart J, GGG, QQQ Stationary sour ce does not meet the definition for a petroleum refinery 40 CFR 60 Subpart KKK Stationary source is not a natural gas processing plant as defined in subpart 40 CFR 60 Subpart LLL Stationary source does not operate natural gas sweetening unit(s) 40 CFR 61 Subpart A Requirements only apply to sources subject to any provisions of 40 CFR 61 40 CFR 61 Subpart J No process components in benzene service , as defined by subpart (10% benzene by weight) 40 CFR 61 Subpart M: §61.142 Stationary source is not an Asbestos Mill 40 CFR 61 Subpart M: §61.143 Stationary source roadways not exposed to asbestos tailings or asbestos containing waste 40 CFR 61 Subpart M: §61.144 Stationary source does not engage in any manufacturing operations using commercial asbestos 40 CFR 61 Subpart M: §61.146 Stationary source does not spray apply asbestos containing materialsPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 54 of 61 Non Applicable Requirements Reason Non-Applicable 40 CFR 61 Subpart M: §61.147 Stationary source does not engage in any fabricating operations using commercial asbestos 40 CFR 61 Subpart M: §61.148 Stationary source does not install or reinstall, on any stationary source component, insulation mate rial containing commercial asbestos 40 CFR 61 Subpart M: §61.149 Applies to only those facilities subject to 61.142 40 CFR 61 Subpart M: §61.151 Applies to only those facilities subject to 61.142, 61.144, or 61.147 40 CFR 61 Subpart M: §61.152 Stationary source does not use air cleaning equipment 40 CFR 61 Subpart M: §61.153 No reporting requirements apply for sources subject to 61.145 40 CFR 61 Subpart M: §61.154 Stationary source is not an active waste disposal site and does not receive asbestos containing waste material 40 CFR 61 Subpart M: §61.155 Stationary source does not process regulated asbestos containing material (RACM) Activities subject to 40 CFR 61, Subpart M §61.145 40 CFR 61 Subpart A: §§61.05(a), 61.07, 61.09 Owners or operators of demolition and renovation operation are exempt from the requirements of 61.05(a), 61.07, and 61.09 40 CFR 61 Subpart A: §61.10 Demolition and renovation operations exempt from 61.10(a) 40 CFR 61 Subpart A: §§61.13, 61.14 Emission tests or monitoring is not required under the standards for demolition and renovation Stationary source-Wide 40 CFR 61 Subpart V No process components in volatile hazardous air pollutant (VHAP) service , as defined by subpart (> or = 10 % VHAP by weight) 40 CFR 61 Subpart Y Stationary source does not operate storage vessels in benzene service 40 CFR 61 Subpart BB Stationary source does not conduct benzene transfer operations 40 CFR 61 Subpart FF Stationary source does not conduct benzene waste operations 40 CFR 63 Subpart T Stationary source does not operate halogenated solvent cleaning machines 40 CFR 63 Subpart CC Stationary source does not meet the definition for a petroleum refinery

All Storage Tanks 40 CFR 63 Subpart OO Provisions only apply to tanks affected by 40 CFR 60, 61, or 63 that specifically reference 40 CFR 63 Subpart OO 40 CFR 63 Subpart SS Provisions only apply to tanks affected by 40 CFR 60, 61, or 63 that specifically reference 40 CFR 63 Subpart SS Drain Systems 40 CFR 63 Subpart RR Provisions only apply to drain systems affected by 40 CFR 60, 61, or 63 that specifically refe rence 40 CFR 63 Subpart RR Stationary source-Wide 40 CFR 63 Subpart VV Provisions only apply to oil-water separators and organic-water separators affected by 40 CFR 60, 61, or 63 that specifically reference 40 CFR 63 Subpart VV 40 CFR 63 Subpart HH Stationary source exempt from subpart because it exclusively processes, stores, or transfers “bl ack oil” and stationary source is not a major source of HAPs. 40 CFR 63 Subpart HHH Stationary source does not transmit or store natural gas prior to entering the pipeline to a local distribution company or to a final end user and stationary source is not a major source of HAPs. 40 CFR 63 Subpart EEEE Stationary source is not a major source of HAPs. 40 CFR 63 Subpart A (except for §63.1(b) & §63.10(b)(3) Requirements only apply to emission units subject to any provision of 40 CFR 63 – this stationary source is not subject toPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 55 of 61 Non Applicable Requirements Reason Non-Applicable 40 CFR 63, Subpart A except for the requirement to determine rule applicability in 40 C.F.R. 63.1(b) and to keep records of rule applicability determination in 40 C.F.R. 63.10(b)(3). Turbines: PU-0701 and PU-0801 40 C.F.R. 64 - Compliance Assurance Monitoring The parametric correlations for PU-0701 and PU-0801, along with the associated continuous process monitors required by the Title V operating permit for these units, qualify as a "continuous compliance determination method" as defined in 40 C.F.R. 64.1. Therefore these units are ex empt from 40 C.F.R. 64 per §64.2(b)(1)(vi). Tank: T-2002 and Glycol Dehydration Unit (Emission Unit ID 25) 40 C.F.R. 64 - Compliance Assurance Monitoring These units do not have pre-control device emissions of an applicable regulated air pollutant equal to or greater than 100 tpy (criteria pollutants), 10 tpy any individual hazardous air pollutant (HAP), or 25 tpy all HAP combined. All Units except PU-0701, PU-0801, T-2002, and Glycol Dehydration Unit (Emission Unit ID 25) 40 C.F.R. 64 - Compliance Assurance Monitoring These units do not use a control device to achieve compliance with any emission limitation or standard. Stationary source-Wide 40 C.F.R. 68 - Risk Management Programs "Naturally occurring hydrocarbon mixtures: (crude oil, condensate, natural gas and produced water) prior to entry into a petroleum refining process unit (NAICS code 32411) or a natural gas processing plant (NAICS code 211112) are exempt from the threshold determination. (See final Rule exempting from threshold determination regulated flammable substances in naturally occurring hydrocarbons mixtures prior to initial processing, 63 FR 640 [January 6, 1998]). Less than 10,000 lbs. of other mixtures containing regulated flammable substances that meet the criteria for an NFPA rating of 4 for flammability are stored at the stationary source. Therefore, CFP, B-Pad, and E-Pad, a crude petroleum and natural gas production stationary source, (NAICS code 211111) does not process or store regulated flammable or toxic substances in excess of threshold quantities. 40 CFR 82 Subpart A: §82.1 Stationary source does not produce, transform, destroy, import or export Class I or Group I or II substances or products 40 CFR 82 Subpart B: §82.30 Stationary source does not service motor vehicles air conditioners 40 CFR 82 Subpart C: §82.60 Stationary source is not the ultimate consumer and not a manufacturer or distributor of Class I and II products or substances 40 CFR 82 Subpart D: §82.80 Subpart applies only to Federal departments, agencies, and instrumentalities 40 CFR 82 Subpart E: §82.100 Stationary source is not the ultimate consumer and not a manufacturer or distributor of Class I and II products or substances 40 CFR 82 Subpart F: §82.158 Stationary source does not manufacture or import recovery and recycling equipment. 40 CFR 82 Subpart F: §82.160 Stationary source does not contract equipment testing organization to certify recovery an d recycling equipment 40 CFR 82 Subpart F: §82.164 Stationary source does not sell reclaimed refrigerant 40 CFR 82 Subpart F: Appendix C Stationary source is not a third party entity that certifies recovery equipment 40 CFR 82 Subpart F: Appendix D Stationary source does not have technician certification program 40 CFR 82 Subpart G: §82.174(a) Stationary source does not manufacture substitute chemicals or products for ozone-depleting compounds.Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 56 of 61 Non Applicable Requirements Reason Non-Applicable 40 CFR 82 Subpart H: §82.270(a) Stationary source does not manufacture halon. Non-road Engine: PU-4703 18 AAC 50.055 The limits of 18 AAC 50.055 do not apply to non-road engines. Stationary source-Wide 18 AAC 50.201 Requirement is not applicable until such time as the Department requests an ambient air quality investigation [18 AAC 50.350(l), 1/18/97]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 57 of 61 Section 14. Visible Emissions Forms

Visible Emissions Field Data Sheet

Certified Observer:

_________________________

Company:

Location:

Test No.: Date:

Source:

Operating Rate:

Clock Time Initial Final

Observer location Distance to discharge

Direction from discharge

Height of observer point

Background description

Weather conditions Wind Direction

Wind speed

Ambient Temperature

Relative humidity

Sky conditions: (clear, overcast, % clouds, etc.)

Plume description: Color

Distance visible

Water droplet plume? (Attached or detached?)

Other informationPermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 58 of 61 Visible Emissions Observation Record Page ___ of ___ Company _________________ Certified Observer____________________

Test Number __________________________

_ Clock time

______________________ Date: Visibility reduction every 15 Seconds (Opacity) Steam Plume

(check if applicable) Comments

Hr Min 0 15 30 45 Attached Detached

Additional information:

_______________________________________ Observer Signature

Data Reduction: Duration of Observation Period (minutes) ________________ Number of Observations _________________ Number of Observations exceeding 20% __________________

Average Opacity Summary Set Time Opacity Number Start—End Sum AveragePermit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 59 of 61 Section 15. SO 2

Material Balance Calculation If a fuel shipment contains more than 0.75 pe rcent sulfur by weight, calculate the three-hour exhaust concentration of SO 2 using the following equations:



### A = 31,200 

### x [wt%S fuel ] = 31,200 

### x ______ = ______

B = 0.148 

### x [wt%S fuel ] = 0.148 

### x ______ = ______

C = 0.396 

### x [wt%C fuel ] = 0.396 

### x ______ = ______

D = 0.933 

### x [wt%H fuel ] = 0.933 

### x ______ = ______

E = B + C + D = ______ + ______ + ______ = ______

F = 20.9 

### – [ vol% dry O 2, exhaust 

### ] = 20.9 

### - ______ = ______

G = [ vol% dry O 2, exhaust 

### ] ÷ F = ______ ÷ ______ = ______

H = 1 + G = 1 + ______ = ______

I = E x H = ______ x ______ = ______

SO 2 concentration 

### = A ÷ I = ______ ÷ ______ = ______ ppm

The wt%S fuel , wt%C fuel , and wt%H fuel are equal to the weight percents of sulfur, carbon, and hydrogen in the fuel. These percentages should total 100%.

The fuel weight percent (wt%) of sulfur is obtained pursuant to condition XI.2. The fuel weight percents of carbon and hydrogen ar e obtained from the fuel refiner.

The volume percent of oxygen in the exhaust (vol% dry O 2, exhaust ) is obtained from oxygen meters, manufacturer’s data, or from the most recent analysis under 40 C.F.R. 60, Appendix A-2, Method 3, adopted by reference in 18 AAC 50.040(a), at the same engine load used in the calculation.

Enter all of the data in percentages wi thout dividing the percentages by 100. For example, if wt%S fuel = 1.0%, then enter 1.0 into the equations, not 0.01, and if vol% dry O 2, exhaust = 3.00%, then enter 3.00, not 0.03. [18 AAC 50.346(c), 5/3/02]Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 60 of 61 Section 16. ADEC Notification Form Fax this form to: (907) 269-7508 Telephone: (907) 269-8888 BP Exploration (Alaska) Inc.

. Company Name Milne Point Production Facility Facility Name Reason for notification:  Excess Emissions T Other Deviation fr om Permit Condition If you checked this box If you checked this box Fill out section 1 fill out section 2

When did you discover the Excess Em issions or Other Deviation: Date:__/__/__ Time:__:__

Section 1. Excess Emissions

(a) Event Information (Use 24-hour clock) : START Time : END Time: Duration (hr:min): Date: : : :
Date: : : :
Total: : (b) Cause of Event (Check all that apply) : T START UP T UPSET CONDITION T CONTROL EQUIPMENT T SHUT DOWN T SCHEDULED MAINTENANCE T OTHER ____________________ Attach a detailed description of what happened, including the parameters or operating conditions exceeded.
(c) Sources Involved: Identify each emission source involved in the event, using the same identification number and name as in the permit. List any control device or monitoring system affected by the event. Attach additional sheets as necessary. Source ID No. Source Name Description Control Device

(d) Emission Limit Potentially Exceeded Identify each emission standard potentially exceeded during the event. Attach a list of ALL known or suspected injuries or health impacts. Identify what observati on or data prompted this report. Attach additional sheets as necessary. Permit Condition Limit Emissions Observed

(e) Excess Emission Reduction: Attach a description of the measures taken to minimize and/or control emissions during the event.

(f) Corrective Actions:Permit No. 200TVP01 Issued: April 14, 2003 Milne Point Production Facility Expires: May 13, 2008 Revision 1: May 25, 2004

Page 61 of 61 Attach a description of corrective actions taken to restore the system to normal operation and to minimize or eliminate chances of a recurrence.

(g) Unavoidable Emissions: Do you intend to assert that these excess emissions were unavoidable? T YES T NO Do you intend to assert the affirmative defense of 18 AAC 50.235? T YES T NO

Section 2. Other Permit Deviations

(a) Sources Involved: Identify each emission source involved in the event, using the same identification number and name as in the permit. List any control device or monitoring system affected by the event. Attach additional sheets as necessary. Source ID No. Source Name Description Control Device

(b) Permit Condition Deviation: Identify each permit condition deviation or potentia l deviation. Attach additional sheets as necessary. Permit Condition Potential Deviation

___________________________________ ______________________________________

___________________________________ ______________________________________

___________________________________ ______________________________________

(c) Corrective Actions: Attach a description of actions taken to correct the deviation or potential deviation and to prevent

recurrence.

Based on information and belief formed after reas onable inquiry, I certify that the statements and information in and attached to this document are true, accurate, and complete.

Printed Name: Signature: Date:Milne Point Production Facility

C:\Documents and Settings\pwright\Desktop\bpxam pufinal\BPXA MPU FinalPe rmit&SOB-Revision1.doc 

## Alaska Department of Environmental Conservation
Air Permits Program
April 14, 2003
BP Exploration (Alaska) Inc.
Milne Point Production Facility

STATEMENT OF BASIS

of the terms and conditions for

Permit No. 200TVP01

Prepared by Sally Ryan and Robert Dolan

Revision 1 – William Ashton
May 25, 2004Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 2 of 43 INTRODUCTION
This document sets forth the legal and factual basis for the terms and conditions of Operating Permit No. 200TVP01, as amended through Revision 1.

STATIONARY SOURCE IDENTIFICATION
Section 1 of Operating Permit No. 200TVP01, Revisi on 1 contains information on the stationary source as provided in the Title V permit applicati on and subsequent submittals and as revised in Construction Permit No. 0073-AC023 and 200CP01.

The Milne Point Production Facility is an oil and gas explorati on and production operation. The SIC code is 1311. The stationary source is owne d and operated by BP Expl oration (Alaska) Inc., who is also the Permittee for this permit. Fuel gas, crude oil, and water are extracted from the subsurface of well pads. This mixture of fluids is transported by pipeline to the Central Facility Pad (CFP) where the gas, crude, and water are separa ted. Some of the fuel gas is used as a fuel in the combustion equipment at the CFP and we ll pads; the remainder is compressed and reinjected back into the reservoir. Separated produ ced water is also re-injected into the reservoir.

Well work that involves the use of rotary drill rigs and associated engines, boilers, heaters, camps and camp equipment, pits and tanks is pe rformed periodically at B-Pad and E-Pad. Such well work is of short duration and performed according to dynamic schedules.

EMISSION UNIT INVENTORY AND DESCRIPTION
Table 1 of Operating Permit No. 200TVP01, Revi sion 1 contains information on the emission units at the stationary source as provided in the Title V permit application and subsequent submittals and as revised in Constructi on Permit No. 0073-AC023, and 200CP02, with the following exceptions:

• The ratings for Emission Unit ID(s) 9 and 10 changed in 2001 when low NO X burners were added.

• The Title V application indi cated that there are two Produced Water Surge Tanks. The Department revised this to one based on a co mment by BPXA and verified by reviewing the 1984 Technical Analysis Report.

Table 1 of Operating Permit No. 200TVP01, Re vision 1 is provided for information and identification purposes only. Specifically, the emission unit rating/size provided in the table does not create an enforceable limit.

EMISSIONS
Section 2 of Operating Permit No. 200TVP01, Revi sion 1 lists the regulated air pollutants as provided in the Title V application. Ta ble A shows the potential-to-emit (PTE) 12 in TPY as

12 Potential to Emit or PTE means the maximum quantity of a release of an air pollutant, considering a stationary source's physical or operational design, based on continual operation of all emission units within the stationaryPermit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 3 of 43 provided in the Title V permit application a nd subsequent submittals and as revised in Construction Permit No. 0073-AC023 and 200CP02. As shown in the PSD A pplicability table in the Legal and Factual Basis for the constructi on permit, PSD applicability was determined by calculating the increase in actual emissions, by polluta nt, due to the change or series of changes since the prior PSD review in 1985. Since construction permit 0073-AC023 was PSD for CO, and BACT was applied, the PSD bank balance for al l the pollutants went back to zero when the construction permit 0073-AC023 was issued.
Table A - Milne Point Unit Potential-to-Emit (TPY) NO X CO PM-10 SO 2 VOC Total 707 386 35 68 187 1383 Table notes: See Emissions Summary Table included in Attachment AA Sources: *Revised Milne Point Improvements – Phase II Request for Amendment to Air Quality Control Permit to Operate NO. 9673-AA005, November 1996. *Response to ADEC Completeness Determination for Construction Permit No. 0073-AC023, March 10, 2000. *Letter from Ross Klie (BPXA) to Jim Baumgart ner (ADEC), Subject: Milne Point Unit Updated PSD Application Analysis (for Construction Permit 0073-AC023), June 12, 2000.
The assessable PTE listed under condition 1.1 is th e sum of the emissions of each individual regulated air pollutant for which the stationary source has the potential to emit quantities greater than 10 TPY. The assessable emissions for th e Milne Point Production Fa cility are 1383 TPY.

As shown in the Emissions Summary Table incl uded in Attachment AA, emission factors are based on AP-42, the manufacturer, or emission limits . This table is based on information from BPXA's 1996 construction permit application and subsequent submittals.

The emissions summary table included in Attach ment AA does not specifically show the VOC emissions from non-combustion emission units. Table B shows a summary of VOC emission sources from non-combustion emissi on units at the Milne Point Un it. This table is based on information from BPXA. This summary does not include the water filtration scour gas unit (removed) or Tanks T-2601 a nd T-2606 (located at C-Pad).

Table B - Milne Point Unit VOC Emission Sources VOC Emissions (TPY) Emission Unit ID or Tag # Location Make/ Model or Other Identifier UnControlled Control Strategy Controlled

(No ID) B-Pad Process Vent 23 None 0 (No ID) E-Pad Process Vent 23 None 0 CFP Produced Water Surge Tank 141.1 Collect and Flare 1 0PU-5401A, PU5401B CFP Flotation cells 17.7 Vent Scrubber 2 17.7

V-5501, V-5502, V-5503, V-5511, V-5521 CFP Compressor Vents 17.7 Vent Scrubber 2 17.7

PU-5301/V4 CFP TEG Reboiler 52.6 Vent Scrubber 2 52.6

CL-5401 CFP Backwash Clarifier Purge Gas 8.8 None 8.8

source for 24 hours a day, 365 days a year, reduced by the effect of pollution control equipment and approved state or federal limitations on the capacity of the stationa ry source's emission units or the stationary source to emit an air pollutant, including limitations such as restrictions on hours or rates of operation and type or amount of material combusted, stored, or processed . . . as defined in AS 46.14.990(21), effective 1/18/97.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 4 of 43 VOC Emissions (TPY) Emission Unit ID or Tag # Location Make/ Model or Other Identifier UnControlled Control Strategy Controlled

CFP Drain Purge 6.9 Vent Scrubber 2 6.9

T-2001 CFP Diesel Storage Tank 0.1 None 0.1 T-2002 CFP Methanol Storage Tank 0 None 0 T-5853 CFP Methanol Storage Tank 0 None 0 T-6001 CFP Crude Oil Tank (Oil Reserve Tank) 14.9 Gas Blanket 1 0

T-6101A CFP Diesel Storage Tank 3.2 None 3.2 T-6101B CFP Crude Oil Tank (Oil Reserve Tank) 7.5 Gas Blanket 1 0 T-6102A CFP Gasoline Storage Tank 0.1 None 0.1 T-6102B CFP Gasoline Storage Tank 0.1 None 0.1 CFP Purge Gas 6.9 None 6.9 Subtotal 323.6 114.1 V-5417 CFP Sand Slurry Tank (Nitrogen Purge) 1.1 None 1.1 Totals 324.7 115.2 Table notes: 1) BACT Limit 2) Voluntary control Sources: *PSD Permit Application, Conoco, Inc. – Milne Point Project, March 16, 1984 *Letter from H.D. Haley (Conoco) to Mr. Doug Lowe ry (ADEC), containing additional information on VOC emissions at the Milne Point Unit, October 9, 1984 *Revised Milne Point Improvements – Phase II Reques t for Amendment to Air Quality Control Permit to Operate NO. 9673-AA005, November 1996 (Table 1-4, Sand Slurry Calculations and Tank VOC Emissions Report in Appendix C, and Table 3-1)

BASIS FOR REQUIRING AN OPERATING PERMIT Section 2 includes a description of the regulatory classifications of the Milne Point Production Facility. This stationary source requires an operating permit under 18 AAC 50.325(b)(1), (b)(3), and (c). As provided in the Title V application, the Miln e Point Production Facili ty contains emission units subject to federal emission standards, is classified under 18 AAC 50.300(b)(2) and (c)(1), and also contains emission units subject to an existing constr uction permit. Therefore, under 18 AAC 50.335(e), the Title V application for the M ilne Point Production Facility is required to include identification of the following “regulated emission units”:

• Each emission unit subject to a standa rd adopted by reference in 18 AAC 50.040 under 18 AAC 50.335(e)(2)

• Each emission unit regulated by a standard in 18 AAC 50.055, Industria l Processes and Fuel Burning Equipment, under18 AAC 50.335(e)(4)(C)

• Emission units subject to requirements in an existing Air Quality Control Construction Permit 18 AAC 50.335(e)(5)

The emission sources at Milne Point Production F acility, classified as “regulated sources” according to the above Department regulations, are listed in Table 1 of Operating Permit No. 200TVP01.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 5 of 43 CURRENT AIR QUALITY PERMITS

Background
On January 18, 1997, the Department implemente d a divided construction and operating permit program. Air Quality permits issu ed prior to this date were called "permits-to-operate," and included all construction permit requirements as well as operating permit requirements. Since January 18, 1997, the Department has authorized construction activities through its construction permit program. Construction permits are usually issued separately from the Title V Operating Permit, but may be combined with Title V Operati ng Permit if requested by the Permittee. If it is not issued concurrently with the Title V Oper ating permit, then the Title V Operating Permit must eventually be amended to incorpor ate the construction permit requirements.

Previous Air Quality Permit-to-Operate
The most recent operating permit issued for this stationary source is permit-to-operate number 9673-AA005 dated January 17, 1997. This permit-to -operate includes all stationary sourcespecific construction authoriza tions through January 17, 1997, si nce it was issued prior to January 18, 1997. These stationary source-specific requirements were included in Construction Permit No. 0073-AC023.

Construction Permits

Construction Permit No. 0073-AC023 was issued to this stationary source on July 13, 2001. The stationary source-specific requirements establishe d in this construction permit are included in Operating Permit 200TVP01 as described below.

Construction Permit 200CP02 is pending. Revision 1 of the operating permit, which incorporates all the changes authorized by 200CP 02, will be public noticed concurrently with the preliminary decision for construction permit 200CP02.

Title V Operating Permi t Application History
BP Exploration (Alaska) Inc. submitted a Title V application on December 1, 1997, and submitted additional information on March 10, 1998, and May 2, 2000.

The information in the application has been updated based on Construction Permit No. 0073- AC023.

Revision 1 (pending): The department proposing to revise 200TVP01, Initial Permit, to incorporate changes proposed in Construc tion Permit No. 200CP02. The changes revise conditions originally imposed in Permit No. 0073-AC023 as described in Table C below.

COMPLIANCE HISTORY
The stationary source has operated at its currentlocation since 1985. The stationary source was last inspected on December 9, 1998 and the stationary source was found to be in compliance with the Title V application. The inspection re port indicates that Emission Unit ID(s) 9 and 10Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 6 of 43 had exceeded their NO X limit during a source test conducted for the purpose of determining compliance with the Title V permit application, and that BPXA had entered into a Compliance Order by Consent for the heaters. Constr uction Permit No. 0073-AC023 contains a condition prohibiting the use of liquid fuel in these heaters, which effectively resolves this problem. This condition has been carried over in to Operating Permit No. 200TVP01.

Review of the permit file for Permit-to-Operate 9673-AA005 indicates that th is stationary source has no other unresolved compliance issues as of the issue date of this permit.

STATIONARY SOURCE-SPECIFIC RE QUIREMENTS CARRIED FORWARD
State of Alaska regulations in 18 AAC 50.350(d)(1 )(D) require that an operating permit includeeach stationary source-specific requirement established in a prior construction permit or permitto-operate. Table C below lists the permit c ondition that establishe d a requirement in Construction Permit No. 0073-AC023 and the new condition in Operating Permit No. 200TVP01 that carries the old requirement into the new permit. Table C also shows how the conditions originally established in Pe rmit No,. 0073-AC023 were revised in Construction Permit 200CP02.

In 2003 the Alaska Legislature passed HB 160, th is law made several changes in verbage to match federal law. A ‘source’ was changed to ‘emission unit.’ A ‘facility’ was changed to ‘stationary source.’ These changes have been made in the operating permit.Milne Point Production FacilityStatement of BasisPage 7 of 43Table C - Comparison of Conditions13Permit No.0073-AC023ConditionNumberDescriptionPermit No.200TVP01ConditionNumberRevisions(not including format changes)Permit 200TVP01, Revision 1 (as authorizedby 200CP02)Table 1 Emission Unit Inventory Table 1 Added Emission Unit ID Numbers Add Emission Units 1A, 18A, and 21(Vent B)authorized by 200CP025 Visible emissions (VE)standard 3 Added emission units that were not part ofconstruction permit action (ID(s) 11 through13, and 17Added Emission Units authorized by 200CP026 PM standard 4 Added emission units that were not part ofconstruction permit action (ID(s) 11 through13 and 17)Added Emission Units authorized by 200CP027 Sulfur emission standard andmonitoring5 Added emission units that were not part ofconstruction permit action (ID(s) 11 through13 and 17); added more specific MR&Rrather than referring to other conditionsAdded Emission Units authorized by 200CP028 NSPS Subpart A 60.7(b) forEmission unit ID(s) 1 through 46 No change, except cites federal regulationrather than paraphrases itNo change9 NSPS Subpart A 60.12 forEmission Unit ID(s) 1 through 411 No change, except cites federal regulationrather than paraphrases itAdded Emission Units authorized by 200CP0210.1 - NSPS Subpart A 60.7(c)for Emission Unit ID(s) 1 and 2Added Emission Units authorized by 200CP0210.2 - NSPS Subpart A 60.7(d)for Emission Unit ID(s) 1 and 27No change, except cites federal regulationrather than paraphrases it10.3 - NSPS Subpart A 60.8 forEmission Unit ID(s) 1 and 28 Initial test required by 60.8 has beencompleted. Condition now requires testingas requested by the NSPS Administrator.No change10.5 - NSPS Subpart A 60.13(f)for Emission Unit ID(s) 1 and 212.2 No change, except cites federal regulationrather than paraphrases it.No change1010.6 - NSPS Subpart A 60.13(h)for Emission Unit ID(s) 1 and 212.3 No change, except cites federal regulationrather than paraphrases it.No change11 11.1 - NSPS Subpart GG NOXstandard and monitoring forEmission Unit ID(s) 1 and 214 No longer required to maintain copies ofdocumentation showing accuracy of flowmeters and set NSPS NOx limit to be basedNo change13This table does not include all standard and general conditionsMilne Point Production FacilityStatement of BasisPage 8 of 43Permit No.0073-AC023ConditionNumberDescriptionPermit No.200TVP01ConditionNumberRevisions(not including format changes)Permit 200TVP01, Revision 1 (as authorizedby 200CP02)only on the turbine heat rate withoutconsidering controlsand the primary fuel(fuel gas). Cites federal regulation ratherthan paraphrases it.11.2 - NSPS sulfur standard andmonitoring for Emission UnitID(s) 1 and 217 Removed sulfur emission standard becauseall of the monitoring is for the fuel sulfurstandard, cites federal regulation rather thanparaphrases it.Added Emission Units authorized by 200CP0211.1a For turbines, requires flowmeters for both liquid andgaseous fuel.14.1 No change No change11.2a For turbines, fuel oil sulfurtesting - Analyze each fuelshipment rather than monthly.Allows alternative monitoringplan.17.1b Fuel nitrogen testing removed from thecondition. EPA granted waiver from fuelnitrogen testing at Milne Point in a letterdated August 28, 2002.No change11.2b For turbines, fuel gas H2Stesting – Allows length-of-stainif the sulfur content is less than50 ppm, or a revised alternativemonitoring plan for if the H2S isgreater than 50 ppm.17.1a No change, except cites federal regulationrather than paraphrases itNo change12 NSPS Subpart Dc req'ts forEmission Unit ID(s) 3 and 413 No change, except cites federal regulationrather than paraphrases itNo change13, 14 NSPS Subpart Kb for EmissionUnit ID(s) 19 and 200 No change, except cites federal regulationrather than paraphrases itNo change15 Flaring req'ts 37 No change No change16, 17 Notification req'ts 50 & 51 No change No change18 Fuel oil req'ts 25 & 26 Minor changes per BPXA comment No change18.2 Limits liquid fuel usage at thefacility stationary source to1,000,000 gallons per year26 No change Change six months to three months per BPXA request19 Fuel gas req'ts 27 Clarified that the fuel gas H2S limit is anannual average because the limit wasrequested for PSD avoidance.No changeMilne Point Production FacilityStatement of BasisPage 9 of 43Permit No.0073-AC023ConditionNumberDescriptionPermit No.200TVP01ConditionNumberRevisions(not including format changes)Permit 200TVP01, Revision 1 (as authorizedby 200CP02)20 Annual operating hoursrestrictions28 Log record is no longer required to be keptdaily because emergency equipment doesnot operate daily.Change Table 2 name to “Annual Limits” Add annualoperating restrictions for the flares21 Daily operating restrictions 29 Clarified that operating limit excludesoperating time when source tests areconducted.Permit clarification requested by BPXA for sulfur limitfor Emission Units 1 and 2 while operating underScenarios 2 and 322 CO BACT for heaters whenfiring fuel gas30 No change No changeNOXBACT for turbines 31 No change No change23NOXBACT for heaters 30 NOXBACT limit for heaters - no change No change23.1a & b Permit specifies maximum loadwhile operating on fuel gas andliquid fuel, with and withoutDirect Water Injection1.1 & 32.2 Changed kW limits during ramp-up periods. No change23.2a, 23.3b, 23.3c Initial source tests andinstallation of Low-NOxburnersNone Removed. The initial tests and installationof the Low-NOx burners have beencompleted. Provisions for completion ofsource tests as requested by the Departmentare included in the non-facility stationarysource-specific condition 65.No change24 VOC BACT limits for vents 34 No change Reinstate original Well Pad B VOC tpy BACT limit perBPXA request.25 NOXPSD Avoidance forturbines1.1 No change No change26 SO2PSD Avoidance for allemission Units1.1 SO2PSD Avoidance for turbines (PSDavoidance for other emission Unit containedin conditions 26 and 27)No change27 PM PSD Avoidance for turbines 33.7 No change No change28 CO hourly BACT for turbines 1.1 No change No change29 CO annual BACT for turbines 1.1 No change No change30 CO BACT for Emission UnitID(s) 7 and 830 No change No change-- PM BACT for Flare 3.b Opacity 20% limit is a surrogate for PM.Limit is from Permit-to-Operate 8673-No changeMilne Point Production FacilityStatement of BasisPage 10 of 43Permit No.0073-AC023ConditionNumberDescriptionPermit No.200TVP01ConditionNumberRevisions(not including format changes)Permit 200TVP01, Revision 1 (as authorizedby 200CP02)AA01431 Install, maintain and operateequipment in accordance withmanufacturers parameters9 and 59 No change, except that the NSPS emissionunits split off from the other emission unitsNo change38 Best Fit Correlation Method fordeveloping relationshipsbetween emission rates fromsource tests and turbine processparameters for NOXand CO.21 Changes correlation submittal requirementfrom 45 days to 60 days.Revised to include Emission Unit 1A, which replacesEmission Unit 1 and is subject to only the testing foroperation on fuel gas, without DWI.39 Relative Accuracy Tests forNOXand CO.22 Revised to include Emission Unit 1A, which replacesEmission Unit 1 and is subject to only the testing foroperation on fuel gas, without DWI .40 CEMS requirements 20 No change.51, 14 Recordkeeping – Permittee nowrequired to keep most recordsfor at least five years, andSubpart Kb tank records for lifeof emission unit80 and 0 No change, except 0 now cites federalregulation rather than paraphrases it63 - 67VE monitoring - requiresmethod 9 observation for liquidfuel-fired emission units onceevery 1,000 hours and once ayear for gas-fired emission units38 Changed to current VE monitoring scheduleof 1stobservation after 400 hours and 2ndafter 800 hours per year with provisions forincreased frequency for liquid fuel-firedemission units. VE monitoring not requiredfor gas-fired emission units.Revised to include Emission Unit 1A and 18A, whichreplace Emission Unit 1 and 18 and is subject to thesame requirements.68 PM monitoring – excludesheaters, flares, and emissionunits using only gaseous fuelsfrom automatic PM test basedon opacity. Requires emissionunits to calculate averageopacity during PM source test41 PM monitoring is not required for anyemission units when fired using fuel gas.No change70 VE recordkeeping –keeprecords of operating hours39 No change No changeMilne Point Production FacilityStatement of BasisPage 11 of 43Permit No.0073-AC023ConditionNumberDescriptionPermit No.200TVP01ConditionNumberRevisions(not including format changes)Permit 200TVP01, Revision 1 (as authorizedby 200CP02)71.1, 72 VE reporting 40 No change No changePermit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: Draft January 15, 2004

Page 12 of 43 Permit No. 0073-AC023 Condition Number Description Permit No. 200TVP01 Condition Number Revisions (not including format changes)

5 Visible emissions (VE)standard 3 Added emission units that were not part of construction permit action (ID(s) 11 through 13, and 17 6 PM standard 4 Added emission units that were not part of construction permit action (ID(s) 11 through 13 and 17) 7 Sulfur emission standard and monitoring 5 Added emission units that were not part of construction permit action (ID(s) 11 through 13 and 17); added more specific MR&R rather than referring to other conditions 8 NSPS Subpart A 60.7(b) for Emission Units ID(s) 1 through 4 6 No change, except cites federal regulation rather than paraphrases it 9 NSPS Subpart A 60.12 for Emission Units ID(s) 1 through 4 11 No change, except cites federal regulation rather than paraphrases it 10.1 - NSPS Subpart A 60.7(c) for Emission Units ID(s) 1 and 2 10.2 - NSPS Subpart A 60.7(d) for Source ID(s) 1 and 2 7 No change, except cites federal regulation rather than paraphrases it

10.3 - NSPS Subpart A 60.8 for Emission Units ID(s) 1 and 2 8 Initial test required by 60.8 has been completed. Condition now requires testing as requested by the NSPS Administrator. 10.5 - NSPS Subpart A 60.13(f) for Emission Units ID(s) 1 and 2 12.2 No change, except cites federal regulation rather than paraphrases it. 10

10.6 - NSPS Subpart A 60.13(h) for Emission Units ID(s) 1 and 2 12.3 No change, except cites federal regulation rather than paraphrases it. 11.1 - NSPS Subpart GG NO X standard and monitoring for Emission Units ID(s) 1 and 2 14 No longer required to maintain copies of documentation showing accuracy of flow meters and set NSPS NOx limit to be based only on the turbine heat rate without considering controls and the primary fuel (fuel gas). Cites federal regulation rather than paraphrases it. 11

11.2 - NSPS sulfur standard and monitoring for Emission Units ID(s) 1 and 2 17 Removed sulfur emission standard because all of the monitoring is for the fuel sulfur standard, cites federal regulation rather than paraphrases it. 11.1a For turbines, requires flow meters for both liquid and gaseous fuel. 14.1 No change

11.2a For turbines, fuel oil sulfur testing - Analyze each fuel shipment rather than monthly. Allows alternative monitoring plan. 17.1b Fuel nitrogen testing removed from the condition. EPA granted waiver from fuel nitrogen testing at Milne Point in a letter dated August 28, 2002. 11.2b For turbines, fuel gas H 2 S testing – Allows length-of-stain if the sulfur content is less than 50 ppm, or a revised alternative monitoring plan for if the H 2 S is greater than 50 ppm. 17.1a No change, except cites federal regulation rather than paraphrases itPermit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 13 of 43 Permit No. 0073-AC023 Condition Number Description Permit No. 200TVP01 Condition Number Revisions (not including format changes)

12 NSPS Subpart Dc req'ts for Emission Units ID(s) 3 and 4 13 No change, except cites federal regulation rather than paraphrases it 13, 14 NSPS Subpart Kb for Emission Units ID(s) 19 and 20 0 No change, except cites federal regulation rather than paraphrases it 15 Flaring req'ts 37 No change 16, 17 Notification req'ts 50 & 51 No change 18 Fuel oil req'ts 25 & 26 Minor changes per BPXA comment 18.2 Limits liquid fuel usage at the facility to 1,000,000 gallons per year 26 No change

19 Fuel gas req'ts 27 Clarified that the fuel gas H 2 S limit is an annual average because the limit was requested for PSD avoidance. 20 Annual operating hours restrictions 28 Log record is no longer required to be kept daily because emergency equipment does not operate daily. 21 Daily operating restrictions 29 Clarified that operating limit excludes operating time when source tests are conducted. 22 CO BACT for heater s when firing fuel
gas 30 No change

NO X BACT for turbines 31 No change 23

NO X BACT for heaters 30 NO X BACT limit for heaters - no change 23.1a & b Permit specifies maximum load while operating on fuel gas and liquid fuel, with and without Direct Water Injection 1.1 & 32.2 Changed kW limits during ramp-up periods.

23.2a, 23.3b, 23.3c Initial source tests and installation of Low-NOx burners None Removed. The initial tests and installation of the Low-NOx burners have been completed. Provisions for completion of source tests as requested by the Department are included in the non-facility-specific condition 65. 24 VOC BACT limits for vents 34 No change 25 NO X PSD Avoidance for turbines 1.1 No change 26 SO 2 PSD Avoidance for all sources 1.1 SO 2 PSD Avoidance for turbines (PSD avoidance for other source contained in conditions 26 and 27) 27 PM PSD Avoidance for turbines 33.7 No change 28 CO hourly BACT for turbines 1.1 No change 29 CO annual BACT for turbines 1.1 No change 30 CO BACT for Source ID(s) 7 and 8 30 No change -- PM BACT for Flare 3.b Opacity 20% limit is a surrogate for PM. Limit is from Permit-to-Operate 8673-AA014 31 Install, maintain and operate equipment in accordance with manufacturers parameters 9 and 59 No change, except that the NSPS sources split off from the other sources

51, 14 Recordkeeping – Permittee now required to keep most records for at least five years, and Subpart Kb tank records for life of source 80 and 0 No change, except 0 now cites federal regulation rather than paraphrases itPermit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 14 of 43 Permit No. 0073-AC023 Condition Number Description Permit No. 200TVP01 Condition Number Revisions (not including format changes)

63 - 67 VE monitoring - requires method 9 observation for liquid fuel-fired sources once every 1,000 hours and once a year for gas-fired sources 38 Changed to current VE monitoring schedule of 1 st observation after 400 hours and 2 nd after 800 hours per year with provisions for increased frequency for liquid fuel-fired sources. VE monitoring not required for gas-fired

sources. 68 PM monitoring – excludes heaters, flares, and sources using only gaseous fuels from automatic PM test based on opacity. Requires sources to calculate average opacity during PM source test 41 PM monitoring is not required for any sources when fired using fuel gas.

70 VE recordkeeping –keep records of operating hours 39 No change

71.1, 72 VE reporting 40 No change

LEGAL BASIS FOR THE PERMIT CONDITIONS

The state and federal regulations for each condition are cited in Operating Permit No. 200TVP01.

STATEMENT OF BASIS FOR THE PERMIT CONDITIONS

The state and federal regulations for each condition are cited in Operating Permit No. 200TVP01.

Conditions 1 and 2, Emission Fees Applicability: The regulations require all permits to include due dates for the payment of fees and any method the Permittee may us e to re-compute assessable emissions.

Factual Basis: These standard conditions require the Permittee to pay fees in accordance with the Department's billing regulations. The billing regu lations set the due dates for payment of fees based on the billing date.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 15 of 43 The default assessable emissions are emissions of each air pollutant authorized by the permit (AS 46.14.250(h)(1)(A)). Air polluta nt means any regulated air pollutant and any hazardous air pollutant. Therefore, assessable emissions under AS 46.14.250(h)(1)(A) means the potential to emit any air pollutant identified in the permit, including t hose not specifically limited by the permit. For example, hydrogen chlo ride (HCl) emissions from an incinerator are assessable emissions because they are a hazardous air pollutant, even if there is currently no emission limit on HCl for that class of incinerator.

The conditions also describe how the Permitt ee may calculate actual annual assessable emissions based on previous actual annual emissions. According to AS 46.14.250(h)(1)(B), assessable emissions are based on each air po llutant. Therefore, fees based on actual emissions must also be paid on any pollutant emitted whether or not the permit contains any limitation of that pollutant. This standard condition speci fies that, unless otherwise approved by the Department, calculations of assessable emissi ons based on actual emissions use the most recent previous calendar year's emissions. Since each current year's assessable emissions are based on the previous year, the Department will not give ref unds or make additional billings at the end of the current year if the estimated emissions a nd current year actual emissions do not match. The Permittee will normally pay for actual emissions - just with a one-year time lag. Projected actual emissions may differ from the pr evious year's actual emissions if there is a change at the stationary source, such as ch anges in equipment or an emission rate from existing equipment.

If the Permittee does not choose to annually calculate assessab le emissions, emissions fees will be based on “potential to emit” (PTE).

The SO 2 PTE set forth in the condition is based on liquid fuel with 0.3% by weight sulfur content, fuel gas with a sulfur content of 100 ppm H 2 S by volume, and emission factors as shown in Attachment AA. If the actual sulfur content of the fuel is greater than these assumptions, the assessable emissions calculati ons provided by the Permittee should reflect the actual sulfur content.

Condition 3 and Section 6, Vi sible Emissions Standard Applicability: This regulation applies to operati on of all fuel-burning equipment in Alaska. Emission Unit ID(s) 1 through 15, a nd 17, 18 and 18A are fuel-burning equipment.

Factual Basis: Condition 3 requires the Permittee to co mply with the federal and the state visible emission standards applicable to fuel -burning equipment. The Permittee shall not cause or allow the equipment to violate these standards. The standard does not apply to Emission Unit ID 16 (nonroad engine). This co ndition also contains the flare BACT opacity limit of 20% carried forward from perm it No. 8636-AA014 for Emission Unit ID 18 and 18A.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 16 of 43 The Milne Point Flare is a gas-assisted flare that includes a flare scrubber 14 . The flare scrubber functions to separate any wet gas c ondensate or liquids from the vapor passing through the system. The flare is subject to the 20 percent state visible emissions standard and also to a 20 percent opacity BACT limit. Condition 3.b contains the NO X , CO, and VOC BACT limit for the flare using opacity as the surrogate. The Department determined that smoke is a sign of deterioration in flare operatio n, and the opacity is an indirect indicator of other pollutants. This condition has recently been adopted in to regulation as a standard condition. MR&R requirements are listed in Section 6 of the permit.

Gas Fired: Monitoring – The monitoring of gas fired emission un its for visible emissions is waived, i.e. no source testing will be required. The Department has found that fuel gas fired equipment inherently has negligible PM emissions. However, the Department can request a source test for PM emi ssions from any smoking equipment. Reporting – The Permittee must annually certify that only gaseous fuels are used in the equipment. Liquid Fired: Monitoring – The visible emissions may be observed by Method-9 plan as detailed in Section 6. Corrective actions such as mainte nance procedures and either more frequent or less frequent testing may be required depending on the results of the observations. Recordkeeping - The Permittee is required to record the results of all visible emission observations and record any actions taken to reduce visible emissions. Reporting - The Permittee is required to report: 1) emissions in excess of the federal and the state visible emissions standard, and 2) deviations from permit conditions. The Permittee is required to include copies of the results of all visible emission observations with the stationary source operating report. Insignificant Emission Units: For Emission Unit ID(s) 14 and 15, as long as it does not exceed 400 hours of operation per calendar year no monitoring is require d in accordance with recently issued Department Guidance AWQ 02-014. The Permittee must annually certify compliance with the opacity standard.

Dual Fuel Fired Emission Units: For Emission Unit ID(s) 1, 2, 7, and 8, as long as they operate on gas monitoring is annual certification of complia nce with the opacity standard. When they operate on backup liquid fuel for more than 400 hours in a calendar year mon itoring as detailed in Section 6 is required in accordance with recently issued Department Guidance AWQ 02- 014.

Flares:

14 Sometimes referred to as knockout (K.O.) drum.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 17 of 43 Monitoring for flares (Emission Unit ID 18 a nd 18A) requires Method -9 observations of scheduled flaring events lasting more than one hour. The Permittee must report the results of these observations to the Department.

Condition 4 and Section 6, Partic ulate Matter (PM) Standard Applicability: The PM standard applies to operation of all fuel burning equipment in Alaska. Emission Unit ID(s) 1 through 15, and 17,18 and 18A are fuel-burning equipment. The SIP standard for PM applies to all fuel-bur ning equipment because it is contained in the federally approved SIP dated October 1983.

Factual Basis: Condition 4 requires the Permittee to comply with the state PM (also called grain loading) standard applicable to fuel-burning equipment. The Permittee shall not cause or allow fuel-burning equipm ent to violate this standard. MR&R requirements are listed in Section 6 of the permit.

Gas Fired: Monitoring – The monitoring of gas fired emission un its for particulate matter is waived, i.e. no source testing will be required. The Department has found that fuel gas fired equipment inherently has negligible PM emissions. However, the Department can request a source test for PM emi ssions from any smoking equipment. Reporting – The Permittee must annually certify that only gaseous fuels are used in the equipment. Liquid Fired: Monitoring –The Permittee is required to conduct PM source testing if threshold values for opacity are exceeded. Recordkeeping - The Permittee is required to record the results of PM source tests. Reporting - The Permittee is required to report: 1) incidents when emissions in excess of the opacity threshold values have been observe d, and 2) results of PM source tests. The Permittee is required to include copies of the results of all visible emission observations with the stationary source operating report. Insignificant Emission Units: For Emission Unit ID(s) 14 and 15, as long as it does not exceed 400 hours of operation per calendar year no monitoring is require d in accordance with recently issued Department Guidance AWQ 02-014. The Permittee must annually certify compliance with the particulate matter standard.

Dual Fuel Fired Emission Units: For Emission Unit ID(s) 1, 2, 7, and 8, as long as they operate on gas monitoring is annual certification of complia nce with the particulate ma tter standard. When they operate on backup liquid fuel for more than 400 hours in a calendar year monitoring as detailed in Section 6 is required in accordan ce with recently issued Department Guidance AWQ 02-014.

Flares:Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 18 of 43 Monitoring of gas fired flares for particulate matter is waiv ed, i.e. no source testing will be required, because of the difficulty and que stionable results these tests produce when applied to flares. The Department has recogniz ed this fact by incorporating the waiver in the State Implementation Plan adopted in November 1984 which has not been federally approved. No recordkeeping or reporting is required.

Condition 5, Sulfur Compound Emissions Applicability: The sulfur emission standard applie s to operation of all fuel-burning equipment in the State of Alaska. Emission Unit ID(s) 1 through 15, and 17, 18 and 18A are fuel-burning equipment. The SIP standard for sulfur dioxide applies because it is contained in the federally approved SIP dated October 1983.

Factual Basis: The condition requires the Permittee to comply with the sulfur emission standard applicable to fuel-burning equipment. The Permittee may not cause or allow the affected equipment to vi olate this standard. Sulfur dioxide comes from the sulfur in the liq uid, hydrocarbon fuel (e.g. diesel or No. 2 fuel oil). Fuel containing no more than 0.75% su lfur by weight will always comply with the emission standard. For fuels with a sulfur content higher than 0.75% , the condition requires the Permittee to use Section 15 to calculate the sulfur-dioxide concentration using the equations to show that the standard is not exceeded. Fuel sulfur testing will verify compliance. Fuel gas sulfur is measured as hydrogen sulfide (H 2 S) concentration in ppm by volume (ppmv). Calculations 15 show that fuel gas containing no more than 4000 ppm H 2 S will always comply with this emission standard. Th is is true for all fuel gases, even with no excess air. Equations to calculate the exhaust gas SO 2 concentrations resulting from the combustion of fuel gas were not included in this permit. Fuel gas with an H 2 S concentration of even 10 percent of 4000 ppm is currently no t available in Alaska and is not projected to be available during the life of this permit. Recordkeeping - For liquid fuel the Permittee is require d to record the fuel sulfur content, and for fuel gas, the H 2 S concentration of the fuel gas. Reporting – The Permittee is required to report as “s tate” excess emissions whenever the fuel combusted causes sulfur compound emissions to exceed the standards in this condition. The Permittee is required to include the material ba lance calculations for fuel oil in the excess emissions report. The Permittee is required to include copies of the records mentioned in the previous paragraph with the stationa ry source operating report.

Conditions 6 through 12, NSPS Subpart A Requirements Applicability: The Department has incorporated by reference the NSPS effective July 1, 1999, for specific industrial activi ties, as listed in 18 AAC 50.040.

15 See ADEC Air Permits Web Site at http://www.state.a k.us/dec/dawq/aqm/newpermit.h tm, under "Stoichiometric

Mass Balance Calculations of Exhaust Gas SO 2 Concentration."Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 19 of 43 Most (with the exception of some storage tanks) emission units subject to an NSPS are subject to Subpart A. At this stationary s ource, Emission Unit ID(s) 1, 1A and 2 are subject to NSPS Subpart GG and Emission Unit ID(s) 3 and 4 are subject to NSPS Subpart Dc and therefore subject to Subpart A. Emission Un it ID(s) 19 and 20 are s ubject to Subpart Kb (recordkeeping only) and, therefore, are not subject to Subpart A. Condition 6 - Start-up, shutdow n, or malfunction record maintenance requirements in 40 C.F.R. 60.7(b) are applicab le to all NSPS emission units subject to Subpart A. Condition 7 - Excess emission reporting requi rements in 40 C.F.R. 60.7(c) & (d) is applicable because there are applicable emissi on standards for Emission Unit ID(s) 1, 1A and 2. The Department has included in Attachment A of the basis a copy of the federal EEMSP reporting form for use by the stationary source.

Condition 8 – Performance Tests procedures in 40 C.F.R. 60. 8 are applicable to Emission Unit ID(s) 1, 1A and 2. Condition 9 - Good air pollution control practices in 40 C.F.R. 60.11(d) are applicable to all NSPS emission units subject to Subpar t A (Emission Unit ID(s) 1 through 4). Condition 10 – Credible Evidence procedures in 40 C.F.R. 60.11(g) are applicable to all NSPS emission units subject to Subpart A with applicable standard s (Emission Unit ID(s) 1, 1A and 2). Condition 11 - Concealment of emissions prohibiti ons in 40 C.F. R. 60.12 are applicable to Emission Unit ID(s) 1, 1A and 2. Condition 12 - Continuous monitoring system re quirements in 40 C.F.R. 60.13(f) and (h) are applicable to Emission Unit ID(s) 1, 1A and 2. Recordkeeping requirements in 40 C.F.R. 60.7(f) are applicable to all NSPS emission units. (Satisfied by condition 80) The Flare is not subject to 40 C.F. R. 60.18 because it is a safety device and not a control device. It does not receive any tank va pors from any NSPS regul ated emission units.

Factual Basis: General provisions of 40 C.F.R. 60, Subpart A apply to owners or operators who are subject to a relevant s ubpart under Part 60, ex cept when otherwise specified in an applicable subpa rt or relevant stan dard. The intent of Subpart A is to eliminate the repetition of requirements applicab le to all owners or operators affected by NSPS.

Condition 13, NSPS Subpart Dc Requirements Applicability: NSPS Subpart Dc applies to steam generating units for which construction, modification, or reconstructi on, commenced after June 9, 1989 and have maximum design heat input capacities of 29 MW (100 MMBtu/hr) or less, but greater than or equal to 2.9 MW (10 MMBtu/hr). Emission Unit ID(s) 3 and 4 were in stalled in 1995 and have maximum design heat input capacities of 35 MMBtu/hr (Table 1 of Operating Permit No. 200TVP01); and are therefore subject to Subpart Dc. Thes e emission units do not burn oil so are not subject to the SO 2 or PM standards in Subpart Dc. Only the recordkeeping requirements in 40 C. F.R. 60.48c(g) apply to Emission Unit ID(s) 3 and 4 because the heaters are not subject to an SO 2 or PM standard. The record retention schedule in 40 C.F.R. 60.48c(i) is satisfied by condition 80.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 20 of 43 Factual Basis: This condition incorporates the appli cable sections of Subpart Dc, which deal with recordkeeping and maintenance.

Conditions 14 through 18, NSPS Subpart GG Requirements Applicability: NSPS Subpart GG applies to stationary gas turbines with a heat input at peak load (maximum load at ISO standard day conditions 16 ) equal to or greater than 10.7 gigajoules per hour (10 MMBtu/hr), based on th e lower heating value (LHV) of the fuels fired and constructed, modified, or reconstr ucted after October 3, 1977. Emission Unit ID(s) 1, 1A and 2 were installed af ter October 3, 1977. Their heat input varies depending on whether Direct Water Injection (DWI) is use d, however, the heat i nput of the turbines without considering any add-on equipment defines the NSPS limit for the turbines. The heat input for Emission Unit IDs 1, 1A and 2 is a bove 10.7 gigajoules/hour as shown in Table D below. The turbines are theref ore subject to NSPS Subpart GG. Emission Unit IDs 1, 1A and 2 are subject to 40 C.F.R. 60.332(a)(2) when firing fuel gas. This standard does not apply when Emission Unit IDs 1 and 2 are fired using liquid fuel, which is used at the stationary source only when the fuel gas supply is curtailed or as required when conduction source tests. Therefor e, the liquid fuel qualifies as an “emergency fuel” and the exemption of 40 C.F.R. 60.332(k) applies. Emission Unit IDs 1, !A and 2 are not subj ect to 40 C.F.R. 60.332(a)(1) because the stationary source is no t an electric utility.

Construction Permit No. 0073-AC023 condition 25.1 requires the Permittee to use Direct Water Injection (DWI) on the turbines to avoid PSD for NO X . Therefore, the turbines are subject to 40 C.F.R 60.334(a), which requires the installation of a continuous monitoring system to monitor and record fuel consumption and ratio of water to fuel fired in the turbine. The Permittee is also required to conduct sour ce tests for the purpose of determining the water to fuel ratio necessary to comply with the NO X standard in condition 14. Because the turbines use DWI, they are also allowed an exemption to the NO X standard under 40 C.F.R. 60.332(f) when ice fog is deemed a traffic hazard by the owner or operator. Fuel-bound nitrogen monitoring requirements do not apply when firing pipeline quality natural gas. BPXA uses only pi peline quality natural gas so no monitoring for gaseous fuel is included in the permit.

Factual Basis: Conditions 14 and 17 incorporate NSPS Subpart GG NO X emission and sulfur compound limits into the permit. The Pe rmittee may not allow the turbines to violate these standards.

General Discussion - Nitrogen Oxide Standard: For a turbine subject to 40 C.F.R. 60.332, the NO X standard is determined by the following equation:

F Y STD NOX + = ) / 4

. 14 ( 015

. 0 Where,

STD NOX = allowable NO X emissions (percent by volume at 15 percent oxygen and on a dry basis)

16 ISO standard day conditions means 288 degrees Kelvin (59 degrees F), 60 percent relative humidity, and 101.3

kPa (14.7 psi) as defined in 40 C.F.R 60.331(g).Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 21 of 43 Y

= manufacturer’s maximum rated heat input (kJ/W-hr), or actual measured heat rate based on lower hea ting value of fuel as measured at actual peak load for the affected sta tionary source. The value of Y shall not exceed 14.4 kJ/W-hr

F

= NO X emissions allowance for fuel bound nitrogen, percent by volume, assumed to be zero

. The following table 17 shows the peak generator load at ISO standard day conditions, associated heat rate, and NSPS NO X emission standards calculat ed using the above equation, in parts per million by volume on a dry basis (ppmvd). (The NO X standard in ppmvd is the NO X standard in percent by volume multiplied by 10,000.) The assumption that the fuelbound nitrogen is zero is a conservative a ssumption. The Permittee may submit a permit amendment request to the Department if site and fuel-specific data is available and the Permittee wishes to revise the NSPS NO X standard.

Table D - NSPS NO X Standard Operating Scenario Heat Input (gigajoules/hr) Heat Rate (Btu/KW-hr) Heat Rate (KJ/W-hr) Y Fuel Bound Nitrogen (%) F NO X Standard (ppmvd)

Fuel gas, without DWI 2,514 9,532 10.05 0 215

Sulfur Dioxide Standard: The Permittee is required to comply with one of the following sulfur requirements for Emission Unit ID(s) 1, 1A and 2 (turbines): (1) do not cause or allow SO 2 emission in excess of 0.015 percent by volume, at 15 percent O 2 and on a dry basis (150 ppmvd), or (2) do not cause or allow the sulfur cont ent to exceed 0.8 percent by weight. The Department has only included the fuel sulf ur standard listed in item (2) above in the permit. The Department has calculated that burning liquid fuel with 0.8 percent sulfur by weight results in 530 ppmvd SO 2 in the exhaust and burning fuel gas with 0.8 percent sulfur by weight results in 389 ppmvd in the exhaust. These values are both higher than 150 ppmvd stated in item (1) above. Therefore, for excess emissions reporting required under 40 C.F.R. 60.7(c), it is only necessary to re port as excess emissions when the liquid fuel sulfur content exceeds 0.8 percent by weight or the H 2 S content of the fuel gas exceeds 0.8 sulfur by weight (about 4390 ppm). Exemptions: Emergency gas turbines, 18 military gas turbines for us e in other than a garrison stationary source, military gas turbines installed fo r use as military training facilities, and fire fighting gas turbines are exempt from NO X emission limit in condition 14. Monitoring -

17 From the NSPS NO X Standards Table in the Legal and Factual Basis for Construction Permit No. 0073-AC023,

page 14.
18 Emergency Gas Turbine means any stationary gas turbine that oper ates as a mechanical or electrical power

emission unit only when the primary power emission unit for a stationary source has been rendered inoperable by an emergency situation, as defined in 40 C.F.R. 60.331(e), effective 7/1/01.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 22 of 43 Nitrogen Dioxide: NSPS Subpart GG NO X emission standard monitoring is incorporated into the permit in condition 14.1. The initial so urce tests required to determine the water to fuel ratio that must be maintained to m eet the NSPS NOx limit has been completed by BPXA. Therefore, these conditions state the ong oing requirements that pertain to monitoring and reporting the water-to-fuel ratio The water-to-f uel ratio will be monitored continuously by the flow meters. The Permittee is required to report as "federal" excess emissions any time the water-to-fuel ratio falls below the level needed to keep NO X emissions below 214 ppmvd. Additional periodic monitoring is included in condition 18. The additional monitoring is necessary to ensure that turbine emission stay below the NSPS NO X emission standard. Sulfur Dioxide: NSPS Subpart GG fuel sulfur monitoring is incorporated into the permit in condition 17.1b for liquid fuel. This condition includes a provision for the Permittee to use an alternative plan for monitoring liquid fuel sulfur, but only with EPA approval. If an alternative plan is approved, the Permittee is re quired to submit it to the Department before using it to comply with this permit. Sulfur Dioxide: NSPS Subpart GG fuel sulfur standard recordkeeping is incorporated into the permit in condition 17.2. Reporting - Nitrogen Oxides: NSPS Subpart GG NO X standard reporting requi rements are incorporated into the permit in condition 14.2. The Permittee is required to comply with NSPS excess emission reporting requirements as described in condition 7 of the permit. Condition 14.2 cites 40 CFR 60.334(c)(1), which describes exactly what is defined as excess emissions for the purpose of reporting under condition 7. Sulfur Dioxide: NSPS Subpart GG SO 2 standard reporting requirements are incorporated into the permit in condition 17.4. For the purpose of reporting under condition 7, report any daily period during which the sulfur content of the fuel being fi red in the gas turbine exceeds 0.8 percent as excess emissions.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 23 of 43 Conditions 19 through 22, Turbine NO X and CO Monitoring, Best-Fit Correlation Method, and Relative Accuracy Test Procedures Applicability: Applies because the Permittee request ed to use a Best-Fit Correlation Method to monitor Turbine NO X and CO.

Factual Basis: 18 AAC 50.320(a)(2) require s the department to "include terms and conditions as necessary to ensure that th e Permittee will build a nd operate the proposed stationary source or modification in accord ance with 18 AAC 50.315(e), including terms and conditions . . .that require the Pe rmittee to install, use, and ma intain monitoring equipment". This condition requires the Permittee to use a PEMS (in the form of a department-approved correlative relationship) or a CEMS to monitor NO X and CO emissions. BPXA proposed using SSPOWGEN in their c onstruction permit application (BP 1999). In ex parte discussions they i ndicated they did not want to be limited to SSPOWGEN, but instead wanted to use a correlative relati onship based on source tests and SSPOWGEN. The Department will allow use of th e correlative relative relations hip as long as it performs as well as a CEMS as indicated in Condition 19. Condition 20 contains procedures for developing correlative relationships. Condition 21 contains relative accuracy pro cedures to ensure that the emission rates predicted by the department-app roved correlative relationship ar e representative of the actual NO X and CO emission rates from the turbines EPA has prepared a draft specification for the purpose of evaluating th e acceptability of a PEMS at the time of installation, Example Specifi cations and Test Procedures for Predictive Emission Monitoring Systems. The Relative A ccuracy Test Procedur es in Condition 21 are based on this draft procedure. This methodology has been accepted by the Department for turbine NO X and CO monitoring as long as it meets relative accuracy re quirements stated in the conditions.

Condition 23, Operation of Closed Vent System Applicability : Owner requested condition for limiting venting will result in reduction of HAPs emissions sufficient to make give stationary source HAP minor status.

Factual Basis : Condition requires recovery of ve nted vapors for a minimum of 2400 hours per year. Monitoring requires tracking hou rs that the vent system is closed and reporting cumulative total hours to department in operating reports.

Condition 25, Fuel Oil Sulfur Requirements Applicability: Owner Requested Limits for Ambien t Air Quality Protection and PSD Avoidance for SO 2 , carried over from Construction Permit No. 0073-AC023 condition 18.1.

Factual Basis: Condition 25 limits liquid fuel sulfur to 0.3 percent by weight. Monitoring - To ensure compliance with the fuel o il sulfur limit, monitoring of liquid fuel sulfur is required under NSPS for the turbines as describe d in condition 17.1b. Monitoring for all other equipment is described in condition 25.1. Recordkeeping and Reporting - Condition 17 only a ddresses the turbines, and also the owner requested limit of 0.30 percent fuel sulfur by wei ght is lower then the NSPS fuel sulfur limit of 0.8 percent. For this reason, additional r ecordkeeping and reporting for all equipment isPermit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 24 of 43 required to ensure compliance with the 0.30 percent fuel sulfur limit. The Permittee is required to keep records of all sulfur analyses . The Permittee is required to report any time the fuel sulfur content is over 0.30 percent as "state" excess emissions under condition 81.

Condition 26, Liquid Fue l Consumption Limit Applicability: Owner Requested Limits for Ambien t Air Quality Protection and PSD Avoidance for SO 2 , carried over from Construction Permit No. 0073-AC023 condition 18.2.

Factual Basis: Condition 26 restricts liquid fuel usage to 1,000,000 gallons for the equipment listed in Table 1 (stationary equipmen t at CFP, B pad and E pad) and all other fuel burning equipment that may be present on the sp ecified pads, except for fuel burned in motor vehicles and in insignificant em ission units, as described in the Legal and Factual Basis for Construction Permit No. 0073-AC023 under co ndition 18. This condition requires the Permittee to monitor fuel usage and report it to the Department, ensuring compliance with the fuel limit. Drill rigs are to be included in the 1,000,000 ga llon per year liquid fuel limit. Since BPXA must report the fuel usage in drill rigs, this limit provides the Department with a mechanism to track actual emissions from drill rigs. The inclusion of drill rigs in the liquid fuel limit works in conjunction with a Memorandum of Understanding (MOU) signed by BPXA and the Department in July, 2001, which addresses the ambient air quality effect of drill rigs at MPU. The MOU formalized a 1998 agreement between the Department and BPXA in which the Department agreed to exclude drill rigs from the ambient impact analysis for the MPU Phase II project addressed in Construction Permit No. 0073-AC023 only, in excha nge for "real" emissi on reductions at the MPU. (In the ambient air quality analysis for this construction permit, the Department had determined that the Permittee was at 100 percent of the 24-hr PM-10 and 24-hr SO 2 Class II increments (without drill rig/well servicing impa cts)). The MOU requires that rotary drill rigs at Pad F use highline power (with certain lim itations), and for all rotary drill rigs at MPU to use liquid fuel with a maximum sulfur cont ent of 0.15 percent by weight when available, but not to exceed 0.30 percen t sulfur by weight.

Condition 27, Fuel gas Sulfur Requirements Applicability: Owner Requested Limits for Ambien t Air Quality Protection and PSD Avoidance for SO 2 , carried over from Construction Permit No. 0073-AC023 condition 19.

Factual Basis: This condition limits the H 2 S content of fuel gas to 100 ppmv, rolling 12- month average. Monitoring - The fuel gas monitoring conducted per condition 17.1a satisfies the fuel analysis requirements for all MPU emission units since the fuel gas supply is the same for all MPU CFP, B-Pad, and E-Pad emission units. Recordkeeping and Reporting - Conditions 27.1 through 27.3 contain recordkeeping and reporting (including "state" excess emission reportin g) requirements necessary to assure the Department that the Permittee will comply with the owner-reque sted limit of 100 ppmv.

Condition 28, Annual Operating RestrictionsPermit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 25 of 43 Applicability: Owner Requested Limits for Ambien t Air Quality Protection and PSD Avoidance for SO 2, carried over from Construction Permit No. 0073-AC023 condition 20.

Factual Basis: Condition 28 contains annual operating restrictions. These are unchanged from Permit-to-Operate No. 9673-AA005, with the exception of Emission Unit ID(s) 11 through 13 and ID(s) 14 and 15 now being allowe d to operate 900 and 600 hrs/yr combined, respectively, instead of 300 hrs/yr each. The operating limits include emergency operation. Monitoring and Recordkeeping - The Permittee is required to keep a log showing the hours of operation on liquid fuel. Reporting - The Permittee is required to report as "s tate" excess emissions and the amount of time the limit in this condition is exceeded a nd to include copies of the log with the stationary source operating report. (Condition 26 describes another annual lim it on liquid fuel usage of 1,000,000 gallons/year in equipment listed in Table 1.)

Conditions 29, Daily Operating Hourly Limits Applicability: Owner Requested Limits for Ambien t Air Quality Protection and PSD Avoidance for SO 2, carried over from Construction Permit No. 0073-AC023 condition 20.

Factual Basis: Condition 29 contains daily operating limits. Monitoring and Recordkeeping - The Permittee is required to keep a log of the operating scenarios. Reporting - The Permittee is required to report "sta te" excess emissions and the amount of time the limit in this condition is exceeded a nd to include copies of the log with the stationary source operating report.

Condition 30, Heater CO and NO X BACT and PSD Avoidance Limits Applicability: These BACT and PSD avoidance limits apply because they were carried over from the previous construction permit.

Factual Basis: Tables E and F show the limits, the basi s of limits, and origin of limits that are included in Operating Permit No. 200TVP01, condition 30.

Table E - Heater CO BACT an d PSD Avoidance Limits
Emission Unit ID Limit BACT/PSD Avoidance Basis Origin

3 and 4 0.2 lb CO/MMBtu PSD Avoidance Emission cap to avoid PSD Permit 9573-AA001 Amendment 1 5 and 6 0.2 lb CO/MMBtu PSD Avoidance Emission cap to avoid PSD Permit 9573-AA001 Amendment 1 7 and 8 when firing fuel gas 0.2 lb CO/MMBtu BACT Cannot verify origin – based on use of fuel gas Permit 8536-AA008

7 and 8 when firing liquid fuel 5 lb CO/1000 gallons BACT AP-42, Table 1.3-1, 9/98 Permit 0073-AC023

9 and 10 0.2 lb CO/MMBtu BACT Cannot verify origin – based on use of fuel gas Permit 8536-AA008Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 26 of 43 CO Monitoring, Recordkeeping, and Reporting - Because source test s have shown the actual CO emissions to be well below the emission limit, the Department requires only that the Permittee follow established preventative mainte nance guidelines, and maintain records of maintenance completed.

Table F - Heater NO X BACT and PSD Avoidance Limits Emission Unit ID Limit BACT/PSD Avoidance Basis Origin

3 and 4 0.05 lb NO X /MMBtu PSD Avoidance Emission cap to avoid PSD Permit 9573-AA001 Amendment 1 5 and 6 0.08 lb NO X /MMBtu and 5 TPY/unit PSD Avoidance Emission cap to avoid PSD Permit 9573-AA001 Amendment 1

7 and 8 when firing fuel gas 0.08 lb NO X /MMBtu BACT Data submitted by Conoco - based on gas firing and use of low NO X burners Permit 8536-AA008

7 and 8 when firing liquid fuel 11.3 lb NO X /hr BACT Method 19 (15% air on a dry basis, and 29 MMBtu/hr (HHV)) Permit 0073-AC023

9 and 10 0.08 lb NO X /MMBtu BACT Data submitted by Conoco – based on gas firing and use of low NO X burners Permit 8536-AA008

NO X Monitoring and Recordkeeping - The last source tests for Emission Units ID(s) 3 through 6 were more than five years prior to the issue date of Operating Permit No 200TVP01, so the Department is re quiring verification of the NO X emission rates by testing one of the heaters in each set within 180 days of permit issuance. Source testing may be waived if the Department determines that prev ious source tests are repr esentative of current operating conditions. The Permittee was require d to conduct a source test on Emission Unit ID(s) 7 and 9 (after installation of Low-NO x burners) in Construction Permit No. 0073- AC023. These source tests and installation of Low-NO x burners in Emission Unit IDs 9 and 10 are one-time requirements that have been met, so they are not carried forward to Operating Permit No. 200TVP01. Reporting - The Permittee is required to report "sta te" excess emissions and the amount of time a limit in this condition is exceeded.

Conditions 31 through 33, Turbine BACT and PSD Avoidance Limits Applicability: These BACT and PSD avoidance limits apply because they were carried over from the previous construction permit.

Factual Basis: Table G shows the limits, the basis of limits, and origin of limits that are included in Operating Permit No. 200TVP01 conditions 31 through 33.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 27 of 43 Table G - Turbine CO, NO X , PM, and SO 2 BACT and PSD Avoidance Limits

Emission Unit ID Limit BACT/PSD Avoidance Basis Origin

CO 1, 1A and 2 No greater than 70 lb/hr for Fuel Gas/Liquid Fuel BACT SSPOWGEN, 70 lb/hr is based on 0 MW and includes a 20% safety factor Permit 0073-AC023

1, 1A and 2 No more than 94.4 TPY, each BACT SSPOWGEN, based on 30 days at 5 MW (50 lb/hr) and 225 days at 10 MW (19 lb/hr) Permit 0073-AC023

NO X 1, 1A and 2 184 ppmvd @ 15% O 2 , dry, corrected to ISO conditions. BACT Vendor emission data – based on standard combustion control Permit 8536-AA008, revised in 9473-AA010 and 9573-AA001, Amendment 4 1, 1A and 2 No more than 625.0 TPY PSD Avoidance Permit 0073-AC023

SO 2 PSD Avoidance Calculated Permit 0073-AC023 All equipment Use liquid fuel with no greater than 0.3 wt% S, and fuel gas with no greater than 100 ppmv H 2 S (rolling 12- month average) Ambient Air Quality Protection Modeling Permit 0073-AC023

PM-10 1,1A and 2 6.93 lb/MMscf PSD Avoidance AP-42. (EPA 2000, Table 3.1- 2a) 19 Permit 0073-AC023

Nitrogen Oxides : Condition 31 contains the NO X instantaneous BACT limit, and the annual NO X PSD avoidance limit, carried over fr om Construction Permit No. 0073-AC023. Monitoring - The Permittee is required to conduct source tests under condition 21.2 or 22.1ato show compliance with the NO X BACT emission concentration. Although the Department is requiring monitoring of the NO X emission concentration using source tests, the operating load limits are nece ssary as well for two reasons. First, these assumptions were included in the ambient ai r quality analysis for Construction Permit No. 0073-AC023, and any violations of the operating limits might have affected other pollutants. Second, violations of the BACT limit would be difficult to predict and prevent above the operating load limits. The Permittee is required to use operational limits or install Direct Water Injection on the turbines to comply with the annual NO X PSD avoidance limit of no more than 625 TPY. 20 The Permittee is required to monitor the NO X rate in pph using an approved correlative relationship or a CEMS as provided in condi tion 19, and compile the 12-month rolling total to ensure that the 625 TPY limit is not exceeded.

19 MMscf lb MMscf scf scf

Btu
Btu MMBtu
MMBtu lb 93

. 6 1000 1050
1000 1 0066

. 0

= × × ×

20 BPXA notified the Department of DWI installation on September 23, 2001.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 28 of 43 Reporting - The results of source tests are includ ed with the stati onary source operating report under condition 21.7.
Carbon Monoxide : Condition 31 contains the CO BACT limits carried forward from Construction Permit No. 0073-AC023. The Permittee requested in their application of September 22, 2003 that the CO BACT limit be changed from 94.4 TPY for each turbine to 188.8 TPY for both turbines. The Department is denying this request because, with the installa tion of the new turbine, they are not similar units and does not want to bubble dissimilar units. Monitoring and Recordkeeping - The Permittee is required to monitor the CO emission rate in pph using an approved correlative relationshi p or a CEMS as provided in condition 19, and compile the 12-month rolling total to ensu re that the 94.4 TPY limit is not exceeded. Reporting - The Permittee is required to report "state" excess emissions. Sulfur Dioxide : Condition 31 (PSD avoidance for the turbin es) refers to the sulfur limits and MR&R in conditions 25 and 27 for all equipment, to keep SO 2 emissions below the PSD threshold. This condition was a PSD avoi dance requirement carried forward from Construction Permit No. 0073-AC023.
Particulate Matter : Condition 31 limits PM emissions from the turbines to 28 TPY. This condition was a PSD avoidance requirement car ried forward from Construction Permit No. 0073-AC023. Monitoring - The Permittee is required to monitor fuel gas and liquid fuel usage for the turbines using the fuel flow meters re quired by condition 14.1, th en calculate PM-10 emissions as described in conditions 33.7a and 33.7b.
Since this is a PSD-avoidance limit, the cons truction permit required the Permittee to conduct source tests for all of the possibl e operational scenarios (both fu el gas- and liquid fuel-firing, with and without DWI). Although PM from fuel gas-firing is expected to be significantly lower than for fuel-oil-firing, it does occur under certain conditions, for instance incomplete combustion of the carbon in the fuel. The li quid fuel emission factor s are required to be determined based on the high heating value (HHV) of the liquid fuel. These requirements have been carried over to Operating Permit No. 200TVP01. Recordkeeping - The Permittee is required to calcula te and record the 12-month total PM-10 emissions for the turbines and the first time that the 12-month total from this condition exceeds 26 tons, the Permittee is required to conduct source tests to verify the AP-42 emission factor. Reporting - The Permittee is required to report "sta te" excess emissions and to attach a summary of the 12-month PM-10 emission to the stationary so urce operating report.

Condition 34, Vent BACT and PSD Avoidance Limits Applicability: These BACT and PSD avoidance limits apply because they were carried over from the previous construction permit.

Factual Basis: Table H shows the limits, the basis of limits, and origin of limits that are included in Operating Permit No. 200TVP01, condition 34.

Table H - Vent BACT and PSD Avoidance LimitsPermit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 29 of 43 Emission Unit ID Limit BACT/PSD Avoidance Basis Origin

23 Provide a gas blanket and back pressure relief valve BACT Permit 8536-AA008

24 Collect and Flare vent gas BACT Collect and reinject fuel gas downhole, or flare Permit 0073-AC023

21 and 22 Use for Emergency purposes only Limit Well Pad B vents to 36.5 tpy of VOC emiisions BACT Permit 8536-AA008

Volatile Organic Compounds: Condition 0 contains a VOC BACT limit of gas blanketing and a back-pressure relief valve on the oil reserve ta nks (Emission Unit ID 23). Condition 0 contains the VOC BACT limits for the Produced Wate r Surge Tank. Construction Permit No. 0073- AC023 condition 24.2 prohibits venting of gas to the atmosphere from the produced water surge tank and requires isolation of the pressure cont rol valve that goes to the vent header. BPXA completed this requirement on May 29, 2001. There is another pressure c ontrol valve that goes to the flare that is not required to be isolated. A 1984 BACT limit was apparently left out of the Permit-to-Operate 9473-AA010 and all subsequent permits. During an audit on October 2 and 3, 2003 this oversight was noted and BPXA then asked for the vents to be included in the existing construction and operating permit. In Pe rmit 8536-AA008 the venting from Well Pad B and Well Pad E were assumed to be due to emergency venting. These limits were assumed to be in place for emission estimates for PSD avoidance for Construction Permit No. 0073-AC023.

The majority of the process vent header VOC em issions occur from the fuel gas controlled by a rotometer that is used as bla nket purge gas on the methanol and sump tanks. The second source of emissions is the sump tank working and breath ing losses. The third source is the water pig launcher. The annual VOC emissions are estimated as 2.60 tpy for the rotometer fuel gas flow, 16.5 lbs/yr for the sump tank, and zero for the water pig launcher. The fuel gas has a VOC percentage of 8.4%, by weight, based on five fuel gas samples that have an average molecular weight of 18.34 lb/lbmole. 21

Monitoring - These requirements require monthly totalizing by the rotometer Recordkeeping - The Permittee is required to keep records showing that well pad B and well pad E vents are used for emergency purposes only. Reporting - Include with the stationary source operat ing report the record s showing that well pad B and well pad E vents are us ed for emergency purposes only.

Conditions 35 and 36, Fuel Consumption and Hours of Operation Monitoring Applicability and Factual Basis: The old operating permit No. 9673-AA005 contained conditions that must be carried forw ard to this Title V permit. These conditions contain requirements to measure fuel consump tion so that emission levels may be calculated and operating hours monitoring for all fuel burning equipment, except flares.

Condition 37, Flaring

21 From Fax note from Julie Ackerlund, Ackerlund, Inc. to William Ashton, ADEC on December 12, 2003.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 30 of 43 Applicability: Ambient air quality pr otection requirement.

Factual Basis: This condition provides the Department with actual information on flaring, in order to ensure that emission estimates fr om flaring provided in the PSD application are representative of actual emissions.

Conditions 38 through 45 (Section 6), Visibl e Emissions and PM Monitoring Plan Applicability: Applies because these conditions de tail the monitoring, recordkeeping, and reporting required in conditions 3 and 4.

Factual Basis: Each permit term and condition must include MR&R requirements showing verifiable compliance with each pe rmit term and condition. The Permittee must establish by actual visual observa tions which can be supplemented by other means, such as a defined Stationary source Oper ation and Maintenance Program, th at the stationary source is in continuous compliance with the State's em ission standards for visible emissions and particulate matter. The correlation between part iculate matter and visible emissions that is the basis for this monitoring procedure is discussed under conditions 3 and 4. These conditions detail a stepwise process for monitoring compliance with the State's visible emissions and particulate matter standards fo r liquid fired emission units. Equipment types covered by these conditions at the Milne Point Produc tion Facility are liquid fuel-fired internal combustion engines and dual fuel-fired turbines and heaters. Initial monitoring frequency schedules are established along with subsequent reductions or increases in frequency depending on the results of the self-monitoring program. The monitoring frequency in condition 19 is not as freque nt as in 18 AAC 50.346( c) because all the monitored equipment is emergency equipment or equipment fired using liquid fuel only in emergencies and are expected to seldom e xperience more than 400 hours of operation per
year. Monitoring frequencies for liquid hydrocarbon fu els, are detailed in these conditions.

Reasonable action thresholds are established in these conditions that require the Permittee to progressively address potential visible emi ssion problems from sources either through maintenance programs and/or more rigorous te sts that will quantify whether a specific emission standard has been exceeded.

More details are found in the Factual Basis statement for Conditions 3 and 4.

Condition 46, (Section 6), Visible Emissions MR&R Plan for Flares Applicability: Applies because this condition deta ils the monitoring, recordkeeping, and reporting required to demonstr ate compliance with conditi on 3 for gas-fired flares.

Factual Basis: Condition 46 was developed to provid e a standardized version of flare monitoring that is not dependent upon the type or design of upstream equipment. It has been claimed that gas-fired flares normally burn without emitting visible emissions, but actual field data demonstrating this assumption is not available. However, gas-fired flares have been shown to smoke when a control device, i.e. a knockout drum, flare scrubber, gas or steam assist, or vapor recovery system malfuncti ons. Thus, the condition sets out a protocol to collect actual field data to determine complia nce with the 20% opacity standard for flares.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 31 of 43 A recent Department analysis of industry flar ing operations indicates that 49% of the gas flared (by volume) is for pilot/purge, 25% is for flaring less than one hour, and 26% is for flaring that lasts more than one hour. Pilot/ purge flaring constitutes half of all flaring by volume and is continuous in nature and can be observed at any tim e. This type of flaring has not caused violations of the opacity standard in the past and can be checked at any time by agency inspectors. The remaini ng half of the flaring volume is split evenly between less than and greater than one-hour durat ion. Therefore, the monitoring scheme in this condition addresses the half of the non-cont inuous flaring operations that are scheduled and for which a certified observer can reas onably be located onsite. Since it is impractical to requi re facilities to have a certified Method-9 opacity reader on site for unpredictable emergency flaring, the mon itoring protocol require s Method-9 readings only during scheduled flare ev ents. Scheduled events such as those generated by maintenance activities and well testing of greater than one-hour in duration will be observed. These one-hour events are currently quantifie d and reported to the Alaska Oil and Gas Conservation Commission for other reasons and thus provi des a confirming information record of the occurrence of these events. Only those events as define d in the condition need to be monitored. If no events meeting this de finition occur during the life of the permit then no monitoring is required. Since only flaring that is scheduled and exceeds one hour is required to be observed, operators will have time to provide certifie d Method-9 readers onsite. Most oil and gas production facilities in Alaska are located at remo te sites, so it is not reasonable to selfmonitor all or even a large sample of the flar ing that occurs. Data collected from planned events will help the Department refine this monitoring scheme during future permit cycles. Process upsets and emergency events that may or may not exceed one hour occur randomly and do not lend themselves easily to periodic monitoring. At this time, the Department will rely on stationary source excess emission report s, citizen complaints, and agency inspections for information concerning these short term and emergency events.

Conditions 47 and 48, Halon Prohibitions Applicability: These prohibitions apply to all f acilities that use halon for fire extinguishing and explosion inertion. The Miln e Point Production Facility uses halon and is therefore subject to the federal regulations contained in 40 CFR 82.

Factual Basis: These conditions incorporate applic able 40 CFR 82 requirements. The Permittee may not cause or allow violations of these prohibitions. No additional MR&R requirements are required to ensure comp liance with these federal requirements.

Condition 49, Emission Un it Aggregation Applicability: The aggregated potential emissions ar e the potential emissions from all emission units installed after August 7, 1980, fo r the purpose of determining applicability with the modification require ments of 18 AAC 50.300(h)(3).Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 32 of 43 Factual Basis: The Milne Point Unit consists of the Central Facilities Pad (CFP) and other well pads. At the time of the 1996 PSD applic ation, the stationary source consisted ofthe CFP and pads A through N. The Department determined that, except for B-Pad and EPad, the other non-contiguous well pads were excluded from the "existing permit [No. 9573- AA001] since the combined ambient impacts are insignificant". O-Pad was proposed in 1996 (BP 1996) but was not constructed as of July 1998. In May 2000, BPXA met with the Department to discuss construction of S- Pad. BPXA asserted that S-Pad should be disaggregated from CFP for the same reasons th at C-Pad is disaggregated. The Department did not contradict that assert ion and has allowed S-Pad to be disaggregated from the Milne Point Unit CFP for the purpose of determining applicability with the modification requirements of 18 AAC 50.300(h)(3).
Construction Permit No. 0073-AC023, includes C FP, B-Pad and E-Pad. A Memorandum of Understanding (MOU) dated July 17, 2001 stipulat es requirements for drill rigs at the Milne Point Unit. The MOU formalized a 1998 agreement between the Department and BPXA in which the Department agreed to exclude drill rigs from the ambient impact analysis for that project only, in exchange for "real " emission reductions at the MPU. Operating Permit No. 200TVP01 includes CFP, B-Pad, and E-Pad. Pads A through N (except for B and E) and S-Pad are disaggr egated for the reasons cited above. The Department will need to determine the aggregation status of any additional well pads (including O-Pad) or nearby faci lities on a case-by-case basis.

Conditions 50 and 51, Notificati on Requirements and Procedures Applicability: Ambient air quality protection requirements carried over from Construction Permit No. 0073-AC023.

Factual Basis: These conditions require the Permittee to notify the Department prior to doing anything that will affect the stationary source’s imp act on ambient air. These requirements are separate from the notif ication requirements for the Construction Permit 0073-AC023.

Conditions 52 through 55, Insignificant Emission Units Applicability: These general emission standards apply to all industrial processes fuelburning equipment, and incinerators regardless of size.

Factual Basis: Conditions 52 through 55 require the Pe rmittee to comply with the general standards for insignificant emission units. The Permittee may not cause or allow their equipment to violate these standards. Insignifi cant emission units are not listed in the permit unless specific monitoring, recordkeeping and re porting are necessary to ensure compliance. The Department finds that the insignificant emi ssion units at this stationary source do not need specific monitoring, recordkeeping and reporting to ensure compliance with these conditions.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 33 of 43 Condition 56, NESHAPS Subparts A, App licability Determinations (Recordkeeping Only) Applicability: NESHAPs Subpart A requirements apply to facilities categorized in 40 C.F.R. 63.

Factual Basis: The condition requires the Permittee to retain records of NESHAP applicability determinations.

Condition 57, Asbestos NESHAP Applicability: The asbestos demolition and renovation requirements apply if the Permittee engages in asbestos demolition or renovation.

Factual Basis: The condition requires the Permittee to comply with asbestos demolition or renovation requirements in 40 C.F.R. 61, Subp art M. Because these regulations include adequate monitoring and reporting requirements and because the Permittee is not currently engaged in such activity, simply citing the regulatory requirements is sufficient to ensure compliance with these federal regulations.

Condition 58, Refrigerant Recycling and Disposal Applicability: Applies if the Permittee engages in th e recycling or disposal of certain refrigerants.

Factual Basis: The condition requires the Permittee to comply with the standards for recycling and emission reduction of refrigerants set forth in 40 C.F.R. 82, Subpart F, that will apply if the Permittee uses certa in refrigerants. Because thes e regulations include adequate monitoring and reporting requirements and because the Permittee is not currently engaged in such activity, simply citing the regulatory requirements is sufficient to ensure compliance with this federal regulation.

Condition 59, Good Air Pollu tion Control Practice Applicability: Applies to all emission units, except NSPS regulated emission units, i.e. Emission Unit ID(s) 1, 1A, 2, 3, and 4.

Factual Basis: The condition requires the Permittee to comply with good air pollution control practices for all emission units. Maintaining and operating equipment in good wo rking order is fundamental to preventing unnecessary or excess emissions. Standard conditions for monitoring compliance with emission standards are based on the assump tion that good maintenance is performed. Without appropriate maintenance, equipment can deteriorate more quickly than with appropriate maintenance. If appropriate main tenance is not applied to the equipment, the Department may have to apply more frequent periodic monitoring requirements (unless the monitoring is already continuous) to ensure that the monitoring results are representative of actual emissions. The Permittee is required to keep maintenance records to show that proper maintenance procedures were followed, and to make the records available to the Department. The Department may use these records as a trigge r for requesting source te sting if the records show that maintenance has been deferred.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 34 of 43 Condition 60, Dilution Applicability: This state regulation applies to the Permittee because the Permittee is subject to emission standards in 18 AAC 50.

Factual Basis: The condition prohibits the Permittee from diluting emissions as a means of compliance with any standard in 18 AAC 50. No specific monitoring for this condition is practical. Other than the required annual ce rtification, no monitoring, recordkeeping or reporting is necessary for this condition. The Permittee presently does not dilute emissions. Dilution would probably require a physical change to the stati onary source. A reasonable inquiry and certification by a res ponsible official as to whethe r such changes occurred over the reporting period is suffici ent to assure compliance.

Condition 61, Reasonable Precauti ons to Prevent Fugitive Dust Applicability: Bulk material handling requirement s apply to the Permittee because the Permittee could engage in bulk material handling, transporting, or storing; or will engage in industrial activity at th e stationary source.

Factual Basis: The underlying regulation, 18 AAC 50.045(d), requires the Permittee to take reasonable action to prevent particulate matter (PM) from being emitted into the ambient air.

Condition 62, Stack Injection Applicability: Stack injection requirements apply to the stationary source because the stationary source contains a stack or emission unit constructed or modified after November 1, 1982.

Factual Basis: The condition prohibits the Permittee fr om releasing materials other than process emissions, products of combustion, or materials introduced to control pollutant emissions from a stack (i.e. disposing of materi al by injecting it into a stack). No specific monitoring for this condition is practical. Othe r than the required a nnual certification, no monitoring, recordkeeping or reporting is n ecessary for this condition. The Permittee presently does not inject wast es into stacks. Waste inje ction would probably require a physical change to the stationary source. A reasonable inquiry and certification by a responsible official as to whether such ch anges occurred over th e reporting period is sufficient to assure compliance. In additi on, compliance is ensured by agency inspections, because the emission unit or stack would n eed to be modified to accommodate stack injection.

Condition 63, Open Burning Applicability: The open burning state regulation in 18 AAC 50.065 applies to the Permittee if the Permittee conducts open burning at the stationary source.

Factual Basis: The condition requires the Permittee to comply with the regulatory requirements when conducting open burni ng at the stationary source.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 35 of 43 More extensive monitoring and recordkeeping is not warranted because the Permittee does not conduct open burning as a routine part of th eir business. Also, mo st of the requirements are prohibitions, which are not easily monitored. Additional monitoring is achieved through condition 64, which requires a r ecord of complaints. Theref ore, the Department does not believe that additional monitoring is warranted.

Condition 64, Air Pollution Prohibited Applicability: Air Pollution Prohibited requirement s apply to the stationary source because the stationary sour ce will have emissions.

Factual Basis: The condition prohibits the Permittee from causing any emission which is injurious to human health or welfare, animal or plant life, or pr operty, or which would unreasonably interfere with the enjoyment of life or property. While the other permit conditions and emissions limitation should ensure compliance with this condition, unforeseen emission impacts can cause violations of th is standard. These violations would go undetected except for complaints from affected persons. Therefore, to monitor compliance, the Permittee must monitor and respond to complaints. The Permittee is required to report any complaints and injurious emissions. The Permittee must keep records of the date, time, and nature of all complaints received and summary of the investigation and co rrective actions undertaken for these complaints and to submit copies of these records upon request of the Department. The Department will determine whether the necessary actions were taken. No corrective actions are necessary if the complaint is frivolous or there is not a violation of 18 AAC 50.110, however this condition is intende d to prevent the Permittee from prejudging that complaints are invalid.

Condition 65, Technology-B ased Emission Standard Applicability: Technology Based Emission Standard requi rements apply to the stationary source because the stationary source contai ns equipment subject to a technology-based emission standard, such as BACT, MACT, LAER , NSPS or other “tec hnologically feasible” determinations.

Factual Basis: The Permittee is required to take reas onable steps to minimize emissions if certain activity causes an exceedance of any technology-based emission standard in this permit. The conditions of this permit list ap plicable technology-based emission standards and require excess emission reporting for each standard in accordan ce with condition 81. Excess emission reporting under condition 81 requ ires information on the steps taken to minimize emissions, the report required unde r condition 81 is adequate monitoring for compliance with this condition.

Condition 66, Permit Renewal Applicability: Applies if the Permittee intends to renew the permit.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 36 of 43 Factual Basis: The Permittee is required to submit an application for permit renewal by the specific dates applic able to Milne Point Production Facilit y as listed in this condition. Monitoring, recordkeeping, and reporting for this condition consist of the application submittal. No additional requirements are necessary to ensure compliance with this condition.

Condition 67, Requested Source Tests Applicability: Applies because this is a standard co ndition to be included in all permits.

Factual Basis: The Permittee is required to conduct source tests as requested by the Department. Monitoring consists of conducting the requested source test, and no recordkeeping or reporting requirements are ne cessary to ensure compliance with this condition.

Conditions 68 through 70, Operating Condi tions, Reference Test Methods, Excess Air Requirements Applicability: Apply because the Permittee is required to conduct source tests by this permit.

Factual Basis: The Permittee is required to conduct sour ce test as set out in conditions 68 through 70. These conditions supplement the specific monitoring requirements stated elsewhere in this permit. The test report s required by condition 75 adequately monitor compliance with conditions 68 through 70, ther efore no additional MR&R requirements are necessary to ensure complia nce with these conditions.

Condition 71, Test Exemption Applicability: Applies when the emission unit exhaust is observed for visible emissions.

Factual Basis: As provided in 18 AAC 50.345(a), 5/ 03/02, the requirements for test plans, notifications and reports do not appl y to visible emissions observations by smoke readers, except in connection with required particul ate matter testing.

Conditions 72 through 75, Test Deadline Exte nsion, Test Plans, Notifications and Reports Applicability: Apply because the Permittee is required to conduct source tests by this permit.

Factual Basis: Standard conditions 18 AAC 50.345(l) - (o) are incorporated through these conditions. Because these sta ndard conditions supplement sp ecific monitoring requirements stated elsewhere in this permit no MR&R is requ ired. The source test itself is adequate to monitor compliance with this condition.

Condition 76, Particulate Ma tter (PM) Calculations Applicability: Applies when the Permittee tests for compliance with the PM standard.

Factual Basis: The condition incorporates a regulato ry requirement for PM source tests. Because this condition supplements specific monito ring requirements stated elsewhere in this permit, no MR&R is require d to ensure compliance w ith this condition.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 37 of 43 Condition 77, Certification Applicability: This is a standard condition to be in cluded in all permits. Applies because every permit requires the Permittee to submit reports.

Factual Basis: This condition requires the Permittee to certify all reports submitted to the Department. To ease the certification burden on the Permittee, the condition allows the excess emission reports to be ce rtified with the stationary source operating report, even though it must still be submitted more frequently than the stationary source operating report. This condition supplements the reporting requireme nts of this permit, therefore no additional MR&R is necessary to ensure co mpliance with this condition.

Condition 78, Submittals Applicability: Applies because the Permittee is required to send reports to the Department.
Factual Basis: This condition requires the Permittee to send submittals to the address specified in this condition. Receipt of the submittal at the correct Department office is sufficient monitoring for this condition. This condition supplements the reporting requirements of this permit, therefore no additional MR&R is necessary to ensure compliance with this condition.

Condition 79, Information Requests Applicability: Applies to all Permittees, and in corporates a standard condition.

Factual Basis: This condition incorporates a sta ndard condition in regulation, which requires the Permittee to submit information re quested by the Department. Receipt of the requested information is adequate monitoring.

Condition 80, Recordkeeping Requirements Applicability: Applies because the Permittee is required by the permit to keep records.

Factual Basis: The condition restates the regulator y requirements for recordkeeping, and supplements the recordkeeping defined for specific conditions in the permit. The records being kept provide adequate evidence of comp liance with this requirement, therefore, no additional MR&R is required.

Condition 81, Excess Emission and Permit Deviation Reports Applicability: Applies when the emissions or operations deviate from the requirements of the permit.

Factual Basis: This condition satisfies two state regu lations related to excess emissions - the technology-based emission standard regula tion and the excess emission regulation. Although there are some differences between the regulations, the c ondition satisfies the requirements of each regulation.

The condition mandates the use of th e Department's reporting form.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 38 of 43 The reports themselves and the other monito ring records required under this permit provide an adequate monitoring of whether the Permittee has complied with the condition. Therefore, no additional MR&R is necessary to ensure compliance with this condition. Please note that there may be additional federally required excess emission reporting requirements.

Condition 82, NSPS and NESHAP Reports Applicability: Applies to facilities subject to NSPS and NESHAP federal regulations.

Factual Basis: The condition supplements the sp ecific reporting requirements in 40 C.F.R. 60 and 40 C.F.R. 61. The conditi on does not need any MR&R. The reports themselves are adequate monitoring for compliance with this condition.

Condition 83, Stationary source Operating Reports Applicability: Applies to all permits.

Factual Basis: The condition restates the requirement s for reports listed in regulation. The condition supplements the specific reporti ng requirements elsewhere in the permit and does not need any MR&R. The reports themse lves are adequate monitoring for compliance with this condition.

Condition 84, Annual Compliance Certification Applicability: Applies to all Permittees.

Factual Basis: This condition specifies the periodic compliance certification requirements, and specifies a due date for the annual compliance certification. Because this requirement is a report, no MR&R is needed.

Conditions 85 through 91, Standard Conditions Applicability: Applies because these are standard conditions to be included in all permits.

Factual Basis: These are standard conditions re quired for all operating permits.

Condition 92, Permit Shield Applicability Applies because the Permittee has requested a shield for the applicable requirements listed under this condition.

Factual Basis: Table 6 of Operating Permit No. 200 TVP01 shows the permit shields that the Department granted to the Permittee. The permit conditions set forth the requirements that the Department determined were not applic able to the stationary source. The following table shows the requests that were denied and the reason that they were denied. The Department based the determinations on th e permit application, pa st operating permit, construction permits and inspection reports.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 39 of 43 Table I - Permit Shields Denied 

### Shield requested for: Reason for shield request: Reason for request denial: Stationary source-Wide 18 AAC 50.045(b) - Prohibitions The permit implements all applicable air quality requirements for the stationary source. Since compliance with the permit will constitute compliance with applicable local, state, or federal air quality laws, this requirement is not directly applicable to the stationary source. 18 AAC 50.045(c) - Prohibitions This requirement will be implemented through 18 AAC 50.201, which is otherwise addressed in the permit. This requirement is not applicable because the Department will impose any special requirements to protect ambient air quality through permit conditions adopted under 50.201. These prohibitions are ongoing requirements and therefore cannot be shielded. They have not been placed in the permit because they add no value to the permit with respect to controlling stationary source emission sources. These prohibitions remain in effect because they are in regulation whether they appear in the stationary source operating permit or not.

Shielding the applicant from subparagraph (b) for instance would have the effect of shielding the applicant from all requirements contained in the Air Quality Control Regulations including the requirement to obtain a permit if the shield requested is granted.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 40 of 43 

### Shield requested for: Reason for shield request: Reason for request denial: Liquid Fuel-Fired Emergency Internal Combustion Engines PED-0110A, PED-0110B, PU-4703A, and PU-4703B: AQC Permit No. 9673-AA005 Condition 7, Exhibits A, B, C, and D These combustion emission units are insignificant per 18 AAC 50.335(r). They have actual emission rates less than those listed in 18 AAC 335 (r)(1) through (15). Emission unit-specific limits and monitoring, recordkeeping, and reporting requirements were included in AQC Construction Permit No. 0073-AC023, which rescinded AQC Permit No. 9673- AA005.

Gas-Fired Heaters H-4510A and H-4510B: AQC Permit No. 9673-AA005 Exhibit B Carbon Monoxide The CO value of 0.20 lb/MMBtu is not an emission limit, it is an emission estimate. Both AQC Permit 9673- AA005 and the 1985 PSD permit identify 0.20 lb/MMBtu as the limit for CO emissions.Permit No.: 200TVP01 Statement of Basis Milne Point Production Facility Revision 1: May 25, 2004

Page 41 of 43 Attachment A Figure 1--Summary Report -- Excess Emission and Monitoring System Performance Pollutant (Circle One—SO 2 /NO X /fuel sulfur) Reporting period dates: From __________to ___________ Company: Emission Limitation ____________________________________________ Address: Monitor Manufacturer and Model No. _______________________________ Date of Latest CMS (CEMS and PEMS) Certification or Audit

____________________________ Process Unit(s) Description: Total source operating time in reporting period 1

________________________ Emission data summary 1 CMS (CEMS and PEMS) performance
summary 1
1. Duration of excess emissions in reporting period due to: 1. CMS (CEMS and PEMS) downtime in reporting period reporting period due to: a. Startup/shutdown _____ a. Monitor equipment malfunctions ____ b. Control equipment problems _____ b. Non-Monitor equipment malfunctions ____ c. Process problems _____ c. Quality assurance calibration ____ d. Other known causes _____ d. Other known causes ____ e. Unknown causes _____ e. Unknown causes

____ 2. Total duration of excess emission _____ 2. Total CMS (C EMS and PEMS) Downtime ____ 3. Total duration of excess emissions X (100) [Total source operating time] ______% 2 3. [Total CMS (CEMS and PEMS) Downtime] X (100) /[Total source operating time] _______% 2
1 For opacity, record all times in minutes. For gases, record all times in hours.
2 For the reporting period: If the total duration of excess emissi ons is 1 percent or greater of the total operating time or the total CMS (CEMS or PEMS) downtime is 5 percent or greater of the total oper ating time, both the summary report form and the excess emission report de scribed in this condition shall be submitted.

On a separate page, describe any changes since last quarter in CMS, process or controls. I certify that the information contained in this report is true, accurate, and complete.

------------------ ------------------ ----------------- ----------------- Name

------------------ ------------------ ----------------- ----------------- SignatureMilne Point Production Facility Statement of BasisPage 42 of 43Attachment AABP Milne Point Permit No. 200TVP01 Emission SpreadsheetEmission Unit #1,23,4 5,6 9.10,11 12 13,14 15,16 17,18 19Stationary source Tag PU-0701 H-5302A H-4510A PU-0101A,B H-5701A H-2001A PU-0110A PU-2004 SandPU-0801 H-5302B H-4510B PU-0101C H-5701B H-2001BPU-0110B CFP B-Pad Slurry EmissionsEquipment Type Turbines Heaters Heaters Engines Flare HeatersbHeaters Emer.EngineEngine Vents Vents Tank (TPY)Number units 2 2 2 2 3 1 2 2 2 2 1Permitted under PSD1985yes yes no No no yes yes no yes no yesTypical fuelaNG AFO NG NG AFO NG NG AFONG AFO AFOContinous RatedCapacity (CRC)243.11 500,000 35.0 14.4 1.5 0.340 29.0 29.0 12.0 12.0 600.0-CRC units MMBtu/hr Gal/yr(each)MMBtu/hr MMBtu/hr MW MMscf/day MMBtu/hr MMBtu/hr MMBtu/hr hp hpAdditional information 25.0 25.2 n/a n/a 2,010.36 n/a n/a 0.3 n/a 0.3 0.3-units MW MW n/a n/a hp n/a n/a % fuelsulfurn/a % fuelsulfur% fuel sulfurfuel flow (lb/hr) n/a 13,557 n/a n/a 735.3 n/a n/a 13,557 n/a n/a n/aHeat rate (BTU/hp-hr) n/a n/a n/a n/a n/a n/a n/a n/a n/a n/aAssumed Annual Load 100% n/a 100% 100% n/a n/a 100% 100% 100% n/a n/aOperational time (NOX,VOC)8,760 0 8760 8760300 365 8760 0 8760300300 8760units hrs/yr hrs/yr hrs/yr hrs/yr Hrs/yr days/yrhrs/yr hrs/yr hrs/yr hrs/yr hrs/yr hrs/yrOperational time ( CO,SO2, PM)8,510 250 8760 8760300 365 8660100 8760300300 8760units hrs/yr hrs/yr hrs/yr hrs/yr Hrs/yr days/yrhrs/yr hrs/yr hrs/yr hrs/yr hrs/yr hrs/yrheat value of fuel 1,120 n/a 1,120 1,120 19,700 1,120 1,120 0.123 1,120 0.123 0.123-units of heat value BTU/scf **** BTU/scfBTU/scf BTU/lb BTU/scf BTU/scf MMBTU/galBTU/scf MMBTU/galMMBTU/galfuel density n/a 6.78 n/a n/a n/a 10.6 n/a n/a n/a n/a n/aOperational limit none 17,500 n/a n/a 89.6 n/a 100 300 300units hp n/a n/a MWhr-day n/a hr/yr hr/yr hr/yrother limits21,3717,771 combined on dieselon diesel on dieselunits kw - noDWIkw - no DWINOxemission rate184.00184.000.0480.08 10.60 0.0680.080.08 14.0 14.0-units ppm ppm lb/MMBtu lb/MMBtu g/hp-hr lb/MMBtu lb/MMBtu lb/103gal lb/MMBtu g/hp-hr g/hp-hr-safety factor n/a n/a 1.0 n/a n/a n/a n/a n/a n/a-from ManufacturerLimit Vendor+1.2 sfAP-42 5/84 PSDapplAP-42 5/84 PSDapplAP-42 AP-42NOxTPYper unit7.36 5.05 7.05 4.73 10.16 0.00 4.20 0.06 2.78NOxcheck g/sec0.2117 0.1451 0.2027 0.1359 0.2923 0.0000 0.1210 0.0001 0.0799NOxTPY14.7 10.1 21.1 4.7 20.3 0.0 8.4 0.1 2.8NOXTPY w/emissioncaps625.014.7 10.1 21.1 4.7 20.38.4 0.1 2.8707.3Sulfur content1000.301001000.301001000.301000.300.30Milne Point Production Facility Statement of BasisPage 43 of 43-units % ppm ppm % ppm ppm % ppm % %SO2emission rate 16.89 0.006 16.89 16.89 0.002 16.89 16.89 0.433 16.89 0.002 0.002-units lb/MMscf lbSO2/lbfuellb/MMscf lb/MMscf LbSO2/hphrlb/MMscf lb/MMscf lb/MMBtu lb/MMscf lbSO2/hp-hrlbSO2/hp-hr-from calculated calculated calculated calculated Calculated calculated calculatedcalculated calculated calculated calculatedSO2TPY per unit15.60 10.17 2.31 0.95 0.64 1.05 1.89 0.63 0.79 0.00 0.18SO2check g/sec0.4487 0.2926 0.0665 0.0274 0.0185 0.0301 0.0545 0.0181 0.0228 0.0001 0.0052SO2TPY31.2 20.3 4.6 1.9 1.9 1.0 3.8 1.3 1.6 0.0 0.267.8PM10emission rate 6.930 0.012 6.2 6.2 0.30 40.0 6.2 2.0 6.2 1 1-units lb/MMscf lb/MMBtu lb/MMscf lb/MMscf g/hp-hr ug/l lb/MMscf lb/103gal lb/MMscf g/hp-hr g/hp-hr-from AP-42 AP-42 AP-42 AP-42 Vendor+1.2 sfAP-42 AP-42 AP-42 ManufacturerAP-42 AP-42PM10TPY per unit0.85 0.35 0.17 1.64 0.70 0.03 0.29 0.00 0.20PM10check g/sec0.024 0.000 0.005 0.047 0.020 0.001 0.008 0.029 0.029PM10TPY1.7 0.7 0.5 1.6 1.4 0.1 0.6 0.0 0.2PM10TPY w/emissioncaps28.01.70 0.70 0.51 1.64 1.39 0.06 0.58 0.01 0.20 34.8CO max ER70700.200.20 6.6 0.370.205.00.20 3.03 3.03-units pph pph lb/MMBTU lb/MMBtu g/hp-hr lb/MMBtu lb/MMBtu lb/103gal lb/MMBtu g/hp-hr g/hp-hr-from limit Limit Vendor+1.2 sfAP-42 3/84 PSDapplAP-42 limit AP-42 AP-42CO TPYper unit94.430.66 12.61 4.39 25.71 25.11 0.07 10.51 0.01 0.60CO check g/sec0.8820 0.3629 0.1262 0.7397 0.7224 0.0021 0.3024 0.0872 0.0872CO TPY total61.3 25.2 13.2 25.7 50.2 0.1 21.0 0.0 0.6CO TPY w/ emissioncaps188.861.3 25.2 13.2 25.7 50.2 0.1 21.0 0.0 0.6386.2VOC ER 0.087 0.062 5.8 5.8 0.2 0.140 5.8 0.2 5.8 1.12 1.12-units g/hp-hr g/hp-hr lb/MMscflb/MMscf g/hp-hr lb/MMBtu lb/MMscf lb/103gal lb/MMscf g/hp-hr g/hp-hr-from AP-42 ManufacturerAP-42 AP-42 Vendor+1.2 sfAP-42 AP-42 AP-42 AP-42 AP-42 AP-42VOC TPY per unit28.14 0.58 0.79 0.33 0.20 9.73 0.66 0.00 0.27 0.00 0.22VOC check g/sec0.8096 0.5816 0.0228 0.0094 0.0057 0.2799 0.0189 0.0001 0.0078 0.0322 0.0322VOC TPY total56.3 1.2 1.6 0.7 0.6 9.7 1.3 0.0 0.5 0.0 0.2 114.1 36.5 1.1 223.8Notes:Total1,419.9aFuel burned in source, -fuel gas, AFO-arctic fuel oil (No. 2 diesel)bHeaters are dual fuel- fired, a maximum of 100 hours per year on dieselcShaded cells indicate permit limits (ORL's, BACT limits, PSD avoidance limits)