Enclosure 1
ENCLOSURE 1

INFORMATION COLLECTION REQUEST FOR

Off-Site Waste and Recovery Operations

This information collection request is being conducted by the Environmental Protection Agency’s (EPA) 

Office of Air and Radiation (OAR) to assist the EPA Administrator in developing emission standards for 

Off-Site Waste and Recovery Operations under Clean Air Act (CAA) section 112. The survey is being sent 

under the authority of Section 114 of the CAA. 

BACKGROUND:

Section 112 (d) of the Clean Air Act (CAA) calls for EPA to promulgate national technology-based emission 

standards for hazardous air pollutants (NESHAP) for sources emitting one or more of the HAP listed in CAA 

section 112(b). For major sources, these technology-based standards must reflect the maximum degree of 

emissions reductions of HAP achievable (after considering cost, energy requirements, and nonair quality 

health and environmental impacts). In addition, under CAA section 112(d)(6), EPA is required to review 

the technology-based standards and revise them “as necessary (taking into account developments in 

practices, processes, and control technologies)” no less frequently than every 8 years. Furthermore, we are 

required by section 112(f) (2) of the Clean Air Act (CAA) to assess the risk remaining (residual risk) eight 

years after the promulgation of maximum achievable control technology (MACT) standards under section 

112(d). If we find the residual risk fails to protect public health with an ample margin of safety or to prevent 

(taking into consideration various factors) adverse environmental effects, we are required to promulgate 

more stringent standards. 

The Off-Site Waste and Recovery Operations maximum achievable control technology (MACT) standards 

were promulgated on July 1, 1996 (see 61 FR 34140). We are collecting specific detailed information to 

support development of standards as part of our review as described above. Please note this survey is for offsite waste and recovery operations only. 

CAA section 114(a) states that the Administrator may require any person who owns or operates any emission 

source, who manufactures emission control equipment or process equipment, who the Administrator believes 

may have information necessary for the purposes set forth in section 114(a), or who is subject to any 

requirement of the CAA (other than certain provisions under Title II), to provide EPA with information for 

the following purposes:

1. Developing or assisting in the development of the following:

a. State implementation plans (§§ 110 and 111(d));

b. New Source Performance Standards (NSPS) (§ 111);

c. National Emissions Standards for Hazardous Air Pollutants (NESHAP) (§ 112);

d. Solid waste combustion or other related solid waste regulations (§ 129);

2. Determining whether any person is in violation of any standards or requirements developed under 

the authorities cited above; or

3. Carrying out any provision under the CAA (except certain provisions under Title II).

The Administrator may require that those persons identified above do the following so the Administrator 

may have the information necessary for the items listed in #1-3:

 establish and maintain records; 

 make reports; 
 install, use, and maintain monitoring equipment, and use audit procedures, or methods; 

 sample emissions (in accordance with such procedures or methods, at such locations, at such 

intervals, during such periods, and in such manner as the Administrator shall prescribe); 

 keep records on control equipment parameters, production variables or other indirect data when 

direct monitoring of emissions is impractical; 

 submit compliance certifications in accordance with section 114(a)(3); and 

 provide such other information as the Administrator may reasonably require.

DIRECTIONS: 

 All recipients must complete and return this survey by April 10, 2013.

 Please identify clearly any response(s) that you consider to be confidential business 

information (CBI). Any responses not so identified will be included in a publicly available 

database. Refer to Enclosures 3, 4, 5, and 6 for more information on the treatment of CBI and a list 

of information you may be asked to submit later to substantiate a claim of confidentiality.

DEFINITIONS: For the purposes of this ICR only, terms used have the meanings attributed to them in 40 

CFR 63.681. 

CONFIDENTIAL BUSINESS INFORMATION (CBI): 

Please indicate if any CBI is included in this survey response: Y XN 

OFF-SITE WASTE AND RECOVERY OPERATIONS

We believe that you own a facility that has Off-Site Waste and Recovery Operations. If you believe that 

this survey does not pertain to you, please indicate your reason below: 

 The Off-Site Waste and Recovery Operations are permanently shut down. Please also identify the 

date the Off-Site Waste and Recovery Operations were shut down, what steps were taken to close the 

equipment or stop operations, and if you still have a permit.

_________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

 No Off-Site Waste and Recovery Operations at this facility. Please identify the operations at the 

facility. 

________________________________________________________________________________

________________________________________________________________________________

________________________________________________________________________________

If your facility does not have Off-Site Waste and Recovery Operations, please respond as soon as 

possible. We will review that information and respond as to whether you need to complete any other part 

of the survey.
Enclosure 2
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 1 of 13

General Information

Name of Legal Owner: Systech Environmental Corporation

Legal Owner Address: 3085 Woodman Dr. Dayton, OH 45420

Number of Legal Owner Employees: 800-888-8011

Facility Name: Systech Environmental Corporation

Facility Address: 2701 N. 145th E. Ave Tulsa, OK 74116

Mailing Address (if different from 

facility address):

Facility Contact Name: Randy Robinson

Facility Contact Title: Facility Manager

Facility Contact Phone Number: 800-778-7224 x117

Facility Contact Email Address: randy.robinson@lafarge-na.com

Number of Company Employees at 

the Entire Facility: 4

Please enter any other comments 

regarding general ownership 

information here:
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 2 of 13

Facility Information

Is the facility a major source for HAP? (see definition below)

Major sources are any stationary source or group of stationary 

sources located within a contiguous area and under common 

control that emits or has the potential to emit considering 

controls, in the aggregate, 10 tons per year (TPY) or more of 

any hazardous air pollutant or 25 TPY or more of any 

combination of HAP. 

Are there one or more off-site waste management or recovery 

operations at the facility subject to the Off-Site Waste and 

Recovery Operations (OSWRO) MACT (40 CFR 63, subpart DD)?

Is the facility exempt from complying with the OSWRO MACT?

What type(s) of off-site waste does the facility accept? (please 

include shipment method, physical form (i.e., solid, liquid, 

sludge), and a general description)

Approximately how many sources (facilities) does that waste 

come from?

What is the base year for which information is being provided? 

(please limit reporting years between 2006 and 2012, and 

provide the most current year)

For this base year, what was the amount of off-site waste 

received? (please specify units; e.g., gal/yr)

For this base year, what was the HAP content of the off-site 

waste received? (please specify units; e.g., tons)

How many hours per year are control devices bypassed to the 

atmosphere to perform routine maintenance?

Are any OSWRO operations scheduled to be discontinued? 

Are any OSWRO operations scheduled to be added or 

expanded?

What is the permitting classification of your facility?

What are the operating permit IDs for the OSWRO operations at 

your facility?

Is your operating permit available online?

Please provide the coordinates (in decimal degrees) of your 

facility property boundary at each corner (node). Alternatively, 

please provide the minimum distance from any OSWRO 

emission point to the facility property boundary.

Please enter any other comments regarding the facility here:

The facility currently receives hazardous waste in 

a blended form from only one off-site location, 

the Systech facility in Fredonia, KS . The waste 

Currently 1.

#2009-205-C Construction permit issued, 

Operating permit under review by ODEQ.

If yes, please provide a link to or a copy of your 

most recent operating permit. If no, please 

provide a copy of your most recent operating 

If yes, please provide date(s) that addition(s) 

and/or expansion(s) will begin production and 

explain changes:

If yes, please provide dates of closure and explain 

changes:

 ocated within the property lines of a co-located cem 

February 2012 through December 31, 2012

101,364,798 lbs/yr

approximately 12,337,993 lbs

If yes, please explain:

0

 er 36.19556, -95.812222 NW 36.19667, -95.81222, 
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 3 of 13

If no, please explain.

If no, please explain.

If "Other", please explain:

Ap42 factors in conjuction with average vapor concentrations 

from tanks.

If "Other", please explain:

If neither apply, please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Pumps 7

Compressors 0

Agitators 2

Pressure relief devices 0

Sampling connection systems 2

Open-ended valves or lines Total all valves - 139

Connectors 586

Instrumentation systems 0

valves (open-ended or lines) capped except when in use. 

Total all valves 139. Total counts of all equipment includes 

Please enter any other comments regarding equipment 

leaks here:

What is the number of each type of component for the 

equipment in OSWRO HAP service (equipment that contacts 

off-site material having a total HAP concentration ≥ 10% by 

weight for 300 hours/year or more)?

With which subpart do you comply for equipment leaks?

Please provide documentation demonstrating the basis for 

the equipment leak emissions estimates. What type of 

documentation are you providing?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Equipment Leaks

Have you verified and/or corrected the equipment leak 

emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO equipment leaks in Enclosure 2A?

What emissions calculation approach was used to estimate 

the equipment leak emissions?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

It is included in the fugitive emission section for 

equipment leaks.

If no, please explain.

If "Other", please explain:

See equipment leaks

If "Other", please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Transfer system (piping and equipemtn) is included in 

equipment leaks.

Please enter any other comments regarding transfer 

systems here:

Transfer Systems

Have you entered the OSWRO transfer system emissions in 

Enclosure 2A?

Have you completed all control information fields for your 

OSWRO transfer systems in Enclosure 2A?

What emissions calculation approach was used to estimate 

the transfer system emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the transfer system emissions estimates. Are you providing 

emissions factors or source test data?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

Facility does not have any equipment of this type.

If no, please explain.

If "Other", please explain:

If "Other", please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Please enter any other comments regarding organic or oilwater separators here:

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the oil-water and organic-water separators emissions 

estimates. Are you providing emissions factors or source 

test data?

Oil-water and organic-water separators

Have you entered the OSWRO oil-water and organic-water 

separators emissions in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO oil-water and organic-water separators in Enclosure 

2A?

What emissions calculation approach was used to estimate 

the oil-water and organic-water separators emissions?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

If no, please explain.

If "Other", please explain:

Please list each OSWRO container requiring Level 1 or Level 2 control: 

Container ID Container capacity

Container emissions control level 

implemented

Facility does not handle off-site containers. Facility 

Truck emission during off-loading included in 

If yes, please describe the control technique(s):

Containers

Have you entered the OSWRO containers emissions in 

Enclosure 2A?

Have you completed all control information fields for your 

OSWRO containers in Enclosure 2A?

What emissions calculation approach was used to estimate 

the containers emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the containers emissions estimates. Are you providing 

emissions factors or source test data?

Please provide the additional capital and annual 

costs of this practice above that required by the 

OSWRO NESHAP:

If "Other", please explain:

Please enter any other comments regarding containers here:

Facilitiy only receives trucks from off-site. 

Emissions from trucks are only when done is 

(add information for more containers as necessary)
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

If no, please explain.

No waste surface inpoundments.

If no, please explain.

If "Other", please explain:

If "Other", please explain:

Please enter any other comments regarding surface 

impoundments here:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of this 

practice above that required by the OSWRO NESHAP:

Surface Impoundments

Have you entered the OSWRO surface impoundments 

emissions in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO surface impoundments in Enclosure 2A?

What emissions calculation approach was used to estimate 

the surface impoundments emissions?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?

Please provide documentation demonstrating the basis for 

the surface impoundments emissions estimates. Are you 

providing emissions factors or source test data?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 8 of 13

If no, please explain.

If no, please explain.

If "Other", please explain:

Process Vent Emissions Information

Have you verified and/or corrected the process vent 

emissions for your OSWRO processes in Enclosure 2A?

Have you completed all control information fields for your 

OSWRO process vent streams in Enclosure 2A?

What emissions calculation approach was used to estimate 

the process vent emissions?

No process vents.

Please enter any other comments regarding process vents 

here:

If "Other", please explain:

If yes, please describe the control technique(s):

Please provide the additional capital and annual costs of 

this practice above that required by the OSWRO NESHAP:

Please provide documentation demonstrating the basis for 

the process vent emissions estimates. Are you providing 

emissions factors or source test data?

Are you implementing work practices or other HAP control 

techniques beyond those required by the MACT standard?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 9 of 13

Tanks Emissions Information

Please list each OSWRO tank requiring Level 1 or Level 2 control: 

Tank ID Tank capacity Tank content MTVP1 Tank content AVP2 Tank height Tank diameter

Tank average 

annual throughput

Tank emissions 

control equipment

1 180,000 gallons

Not available - mixture is 

not consistant 0.31887 psia 30 ft 32 ft

12,184,533 gallons 

based on received 

amt

Cement Kiln or carbon 

as a back-up

2 180,000 gallons

Not available - mixture is 

not consistant 0.31887 psia 30 ft 32 ft

12,184,533 gallons 

based on received 

amt

Cement Kiln or carbon 

as a back-up

1

 Maximum True HAP Vapor Pressure 

2

 Average HAP Vapor Pressure 

For each tank with an internal floating roof, please list the slotted ladder information: 

Tank ID

Number of ladders 

with slotted legs

Gasketed deck cover 

over slotted ladder(s)?

Ladder sleeve over 

slotted ladder(s)?

Pole wipers in place for 

slotted ladder legs?

For each tank with a fixed roof, please list the tank fitting information: 

Tank ID

Number of access 

hatches

Number of gauge 

hatches

Number of 

conservation vents

Number of 

valves/instruments

Number of 

emergency 

1 0 0 1 3 1

2 0 0 1 3 1

1

 Maximum True HAP Vapor Pressure

For each tank with a floating roof (internal or external), please list the tank information: 

Tank ID

Annual number of 

days roof rests on 

landing legs Length of landing legs

(add information for more tanks as necessary)

Please provide documentation demonstrating the basis 

for the tanks emissions estimates. Are you providing 

emissions factors, source test data or other data?

Quarterly composit samples are analyzed and then averaged 

Are you implementing work practices or other HAP 

control techniques beyond those required by the MACT 

standard?

Have you entered the tanks emissions for your OSWRO 

processes in Enclosure 2A?

Have you completed all control information fields for 

your OSWRO storage vessels in Enclosure 2A?

What emissions calculation approach was used to 

estimate the tank emissions?

If no, please explain.

If no, please explain.

Please provide the additional capital and annual costs of this 

practice above that required by the OSWRO NESHAP:

If "Other", please explain:

If "Other", please explain:

If yes, please describe the control technique(s):

(add information for more tanks as necessary)

(add information for more tanks as necessary)

(add information for more tanks as necessary)
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 10 of 13

Tanks Emissions Information

Please enter any other comments regarding tanks here:

Vapor pressure only availavle via 

tanks 4.09b. Average of monthly 

Vapor Pressure at Daily Averal Liquid 

Surface Temperature. All tank top 

equipement is included in the 
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 11 of 13

Off-Site Material Treatment

If you treat off-site waste using biological degradation, please answer the following questions:

What method of off-site waste HAP reduction is used?

Material is used an alternative fuel for cement 

plant. 

How do you characterize the components of the waste 

products you receive that are treated with biological 

degradation?

If "Other" or more than one of the above applies, 

please explain.

Please enter any other comments regarding off-site waste 

treatment here:

Do you perform any testing or other practices to 

determine whether fouling agents may be in the waste 

received?
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 12 of 13

Startup and Shutdown Events

If no for any of the above, please explain:

The control devices are for non-fugitive 

emissions. The kilns are the primary control 

device a back-up carbon system is avialble 

when the kilns are not operationa.

Transfer Systems

Containers

The United States Court of Appeals for the District of Columbia Circuit vacated portions of two provisions in the EPA’s CAA 

section 112 regulations governing the emissions of HAP during periods of startup, shutdown and malfunction (SSM). Sierra 

Club v. EPA, 551 F.3d 1019 (D.C. Cir. 2008). Specifically, the Court vacated the SSM exemption contained in 40 CFR 63.6(f)(1) 

and 40 CFR 63.6(h)(1), that are part of a regulation, commonly referred to as the “General Provisions Rule,” that the EPA 

promulgated under section 112 of the CAA. When incorporated into CAA section 112(d) regulations for specific source 

categories, these two, now vacated, provisions exempted sources from the requirement to comply with the otherwise 

applicable CAA section 112(d) emission standard during periods of SSM. To be consistent with the Court’s decision, facilities 

must comply with the applicable standards at all times.

For each emission source type, do the annual emissions estimate in the Enclosure 2A "Emissions (TPY)" field include the 

annual emissions from startup and shutdown events that you added in the "STARTUP EMISSIONS (TPY)" and "SHUTDOWN 

EMISSIONS (TPY)" fields? Please enter a separate response for each emissions point type below:

For each emission source type, can you comply with the emissions limitation and/or work practices in the regulation that apply 

during normal operation during startup and shutdown events? Please enter a separate response for each emissions point type 

below:

Surface Impoundments

Tanks

Organic and Oil-Water Separators

Equipment Leaks

Process Vents

Equipment Leaks

Transfer Systems

Organic and Oil-Water Separators

Containers

Surface Impoundments

Process Vents

Tanks
U.S. EPA Information Collection Request for Off-Site Waste and Recovery Operations

Page 13 of 13

Startup and Shutdown Events

Please provide the following information about all startup and shutdown events:

System automatically switches to carbon if kilns 

are not available.

5. What safety issues are connected with a startup or shutdown event?

1. What emissions source types experience startup and shutdown events?

2. How often do startup or shutdown events occur? 

3. What is the average and range of event duration?

1.d. How are emissions released to the atmosphere (e.g., through a 

pressure relief device)?

1.c. How does the startup or shutdown event compare to normal 

operations (e.g., differences in flowrate, temp., pressure, alternate fuels 

used, alternate control devices used, etc.)?

1.a. Under normal operating conditions, do these emissions sources 

operate continuously?

1.b. What triggers the equipment to experience a startup or shutdown 

event (e.g. hot startup, startup after an emergency shutdown, re-start, 

control device startup)?

4. What marks the end of the startup or shutdown event?

9. During startup and shutdown events, if you cannot comply with the emissions 

limitation and/or work practices in the regulation that apply during normal 

operation, what is the minimum emissions level that could be achieved? 

9.b. How much would it cost to minimize HAP emissions in this manner?

9.c. How much would HAP emissions be reduced compared to an 

uncontrolled event? (If "emission factor" is used as basis for emissions 

estimate, please provide the emission factor and sources of the emission 

factor.1)

Please enter any other comments 

regarding startup or shutdown here:

1

 If "source test" is used as basis for emissions estimate, please provide a copy of the 

source test.

9.a. Please describe how HAP emissions would be minimized.

6. How do you determine the HAP emissions during the event? 

7. How are control devices and work practices used to minmize emissions during 

the startup or shutdown event?

8. What compliance determination method(s) do you use during startup and 

shutdown events (e.g., monitor with CEMS)? 
Enclosure 2a: 

Equipment 

Leaks
Enclosure 2a

Page 1

Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name

Emission 

Unit ID Process ID

Emission 

Release 

Point ID

SCC 

Code1

Emissions 

Start Date

Emissions 

End Date

Pollutant 

CAS 

Number2

Pollutant Name (include 

organic and nonorganic pollutants)

Actual 

Emissio

ns (TPY)

MACTAllowable 

Emissions 

(TPY)3

Routine 

Emission

s Max 

Hourly 

(lbs/hr)

Startup 

Emissio

ns (TPY)

Startup 

Emissio

ns 

(lbs/hr)

Shutdo

wn 

Emissio

ns 

(TPY)

Shutdo

wn 

Emissio

ns 

(lbs/hr) MACT Source Category

Emission 

Release 

Point Type4 

Stack 

Height (ft)

Exit Gas 

Temperatu

re (°F)

Stack 

Diameter (ft)

Exit Gas 

Velocity 

(ft/sec)

Exit Gas 

Flow 

Rate 

(ft3/sec)

Fugitive 

Length (EW) (ft)

Fugitive 

Width (NS) (ft)

Fugitive 

Angle 

(degrees) 

5

Longitude 

(decimal 

degrees)6

Latitude 

(decimal 

degrees)6

Is 

Control 

Measur

e In 

Place?

Control 

Measur

e 7

Control 

Measur

e 

Efficien

cy Comments

EXAMPLE 

ENTRY:

American Welding 

Paducah Plant 25 25 50310001 01/01/10 12/31/10 100414 Ethyl Benzene 2.45 4.32 6.7 1.24 0.08 0.61 0.2

Off-Site Waste and Recovery 

Operations vertical 44 1600 3.099999905 3.86999989 1758 NA NA NA -72.078903 41.44273758 yes flare 98%

reduction efficency based on 

manufacturer guarantees

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 75088 Acetonitrile 0.002 n/a 0.001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 71432 Benzene 0.003 n/a 0.001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 100414 Ethyl Benzene 0.002 n/a 0.001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 67561 Methyl Alcohol 0.004 n/a 0.001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 108101 Methyl Isobutyl ketone 0.002 n/a 0.001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 1634044 methyl t-butyl ether 0.061 n/a 0.016 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 91203 napthlene <.001 n/a 0.000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 100425 sytrene 0.001 n/a 0.000 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 127184 tetrachloroethylene 0.002 n/a 0.001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 108883 toluene 0.085 n/a 0.022 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

Systech 

Environmental 

Corporation - Tulsa, 

OK Fugitive Fugitive Fugitive 50310001 2/6/2012 12/31/2012 1330207 xyelene (mixed) 0.065 n/a 0.017 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations Fugitive N/A N/A N/A N/A N/A 94 149 0 95.8125 36.195 n/a n/a n/a Fugitive soureces - equipment lea

1

 For SCC Code, please input one of the following codes:

SCC SCC Description

50310001 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Equipment Leaks 

50310002 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Containers

50310003 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Tanks

50310004 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Organic and Oil-Water Separators

50310005 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Surface Impoundments

50310006 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Transfer Systems

50310007 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Process Vents

2

 See List of HAPs in separate worksheet for a table of CAS numbers and HAPs

3

 MACT- allowable emissions are the maximum emission levels allowed while in compliance with the MACT standards

4

 Emission point type choices include: fugitive, vertical, horizontal, goose neck, vertical with rain cap, or downward-facing vent

5

 Fugitive Angle: Specifies the rotation of the source from north (in the clockwise direction). The location coordinates should reflect the southwest corner of the area source as shown in this graphic: 

6 Location of stack or southwest corner of a fugitive emissions release point

7

 For control measures, please include all control measures used for that emission point, including but not limited to:

Activated Carbon 

Adsorption

list specific 

type in 

Control 

Measure 

Comments 

column

Combustor

list specific 

type in 

Control 

Measure 

Comments 

column

Electrostatic 

Precipitator

Fabric 

Filter/Baghouse

Flare

Pressurized Tank

Fixed Roof Tank

Fixed Roof Tank 

Vented to Control 

Device

External Floating 

Roof Tank

Fixed Roof Tank 

with Internal 

Floating Roof

Vapor Balancing

Floating Membrane 

Cover

Cover Vented to 

Control Device

High-Efficiency 

Particulate Air Filter 

(HEPA)

(annual average if the parameter varies)

Vertical Emissions Release Point Parameters Fugitive Emissions Release 

Point Parameters
Enclosure 2a

Page 2

Leak Detection and 

Repair Program

Condenser

Scrubber

list specific 

type in 

Control 

Measure 

Comments 

column

Multiple Controls in 

Series

list specific 

types in 

Control 

Measure 

Comments 

column

Other Control 

Device

describe in 

Control 

Measure 

Comments 

column

Pollution Prevention 

Technique

describe in 

Control 

Measure 

Comments 

column

Process 

Modification

describe in 

Control 

Measure 

Comments 

column
DRAFT

Pollutant Name CAS No.

Acetaldehyde 75070

Acetamide 60355

Acetonitrile 75058

Acetophenone 98862

2-Acetylaminofluorene 53963

Acrolein 107028

Acrylamide 79061

Acrylic acid 79107

Acrylonitrile 107131

Allyl chloride 107051

4-Aminobiphenyl 92671

Aniline 62533

o-Anisidine 90040

Asbestos 1332214

Benzene (including benzene from gasoline) 71432

Benzidine 92875

Benzotrichloride 98077

Benzyl chloride 100447

Biphenyl 92524

Bis(2-ethylhexyl)phthalate (DEHP) 117817

Bis(chloromethyl)ether 542881

Bromoform 75252

1,3-Butadiene 106990

Calcium cyanamide 156627

Captan 133062

Carbaryl 63252

Carbon disulfide 75150

Carbon tetrachloride 56235

Carbonyl sulfide 463581

Catechol 120809

Chloramben 133904

Chlordane 57749

Chlorine 7782505

Chloroacetic acid 79118

2-Chloroacetophenone 532274

Chlorobenzene 108907

Chlorobenzilate 510156

Chloroform 67663

Chloromethyl methyl ether 107302

Chloroprene 126998

Cresols/Cresylic acid (isomers and mixture) 1319773

o-Cresol 95487

m-Cresol 108394

p-Cresol 106445

Cumene 98828

2,4-D, salts and esters 94757

DDE 3547044

Diazomethane 334883

Dibenzofurans 132649

1,2-Dibromo-3-chloropropane 96128

Dibutylphthalate 84742

1,4-Dichlorobenzene(p) 106467

3,3-Dichlorobenzidene 91941

Dichloroethyl ether (Bis(2-chloroethyl)ether) 111444

1,3-Dichloropropene 542756

Dichlorvos 62737

Diethanolamine 111422

N,N-Diethyl aniline (N,N-Dimethylaniline) 121697

List of Hazardous Air Pollutants (HAP)
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Diethyl sulfate 64675

3,3-Dimethoxybenzidine 119904

Dimethyl aminoazobenzene 60117

3,3'-Dimethyl benzidine 119937

Dimethyl carbamoyl chloride 79447

Dimethyl formamide 68122

1,1-Dimethyl hydrazine 57147

Dimethyl phthalate 131113

Dimethyl sulfate 77781

4,6-Dinitro-o-cresol, and salts 534521

2,4-Dinitrophenol 51285

2,4-Dinitrotoluene 121142

1,4-Dioxane (1,4-Diethyleneoxide) 123911

1,2-Diphenylhydrazine 122667

Epichlorohydrin (l-Chloro-2,3-epoxypropane) 106898

1,2-Epoxybutane 106887

Ethyl acrylate 140885

Ethyl benzene 100414

Ethyl carbamate (Urethane) 51796

Ethyl chloride (Chloroethane) 75003

Ethylene dibromide (Dibromoethane) 106934

Ethylene dichloride (1,2-Dichloroethane) 107062

Ethylene glycol 107211

Ethylene imine (Aziridine) 151564

Ethylene oxide 75218

Ethylene thiourea 96457

Ethylidene dichloride (1,1-Dichloroethane) 75343

Formaldehyde 50000

Heptachlor 76448

Hexachlorobenzene 118741

Hexachlorobutadiene 87683

Hexachlorocyclopentadiene 77474

Hexachloroethane 67721

Hexamethylene-1,6-diisocyanate 822060

Hexamethylphosphoramide 680319

Hexane 110543

Hydrazine 302012

Hydrochloric acid 7647010

Hydrogen fluoride (Hydrofluoric acid) 7664393

Hydrogen sulfide 7783064

Hydroquinone 123319

Isophorone 78591

Lindane (all isomers) 58899

Maleic anhydride 108316

Methanol 67561

Methoxychlor 72435

Methyl bromide (Bromomethane) 74839

Methyl chloride (Chloromethane) 74873

Methyl chloroform (1,1,1-Trichloroethane) 71556

Methyl hydrazine 60344

Methyl iodide (Iodomethane) 74884

Methyl isobutyl ketone (Hexone) 108101

Methyl isocyanate 624839

Methyl methacrylate 80626

Methyl tert butyl ether 1634044

4,4-Methylene bis(2-chloroaniline) 101144

Methylene chloride (Dichloromethane) 75092

Methylene diphenyl diisocyanate (MDI) 101688

4,4'¬-Methylenedianiline 101779

Naphthalene 91203
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Nitrobenzene 98953

4-Nitrobiphenyl 92933

4-Nitrophenol 100027

2-Nitropropane 79469

N-Nitroso-N-methylurea 684935

N-Nitrosodimethylamine 62759

N-Nitrosomorpholine 59892

Parathion 56382

Pentachloronitrobenzene (Quintobenzene) 82688

Pentachlorophenol 87865

Phenol 108952

p-Phenylenediamine 106503

Phosgene 75445

Phosphine 7803512

Phosphorus 7723140

Phthalic anhydride 85449

Polychlorinated biphenyls (Aroclors) 1336363

1,3-Propane sultone 1120714

beta-Propiolactone 57578

Propionaldehyde 123386

Propoxur (Baygon) 114261

Propylene dichloride (1,2-Dichloropropane) 78875

Propylene oxide 75569

1,2-Propylenimine (2-Methyl aziridine) 75558

Quinoline 91225

Quinone 106514

Styrene 100425

Styrene oxide 96093

2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746016

1,1,2,2-Tetrachloroethane 79345

Tetrachloroethylene (Perchloroethylene) 127184

Titanium tetrachloride 7550450

Toluene 108883

2,4-Toluene diamine 95807

2,4-Toluene diisocyanate 584849

o-Toluidine 95534

Toxaphene (chlorinated camphene) 8001352

1,2,4-Trichlorobenzene 120821

1,1,2-Trichloroethane 79005

Trichloroethylene 79016

2,4,5-Trichlorophenol 95954

2,4,6-Trichlorophenol 88062

Triethylamine 121448

Trifluralin 1582098

2,2,4-Trimethylpentane 540841

Vinyl acetate 108054

Vinyl bromide 593602

Vinyl chloride 75014

Vinylidene chloride (1,1-Dichloroethylene) 75354

Xylenes (isomers and mixture) 1330207

o-Xylenes 95476

m-Xylenes 108383

p-Xylenes 106423

Antimony Compounds 0

Arsenic Compounds (inorganic including arsine) 0

Beryllium Compounds 0

Cadmium Compounds 0

Chromium Compounds 0

Cobalt Compounds 0

Coke Oven Emissions 0
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Cyanide Compounds 0

Glycol ethers 0

Lead Compounds 0

Manganese Compounds 0

Mercury Compounds 0

Fine mineral fibers 0

Nickel Compounds 0

Polycylic Organic Matter 0

Radionuclides (including radon) 0

Selenium Compounds 0
Enclosure 2a: 

Tanks 
Enclosure 2a

Page 1

Please complete this table for all OSWRO emission units. Please report all emissions related to the off-site waste handled and/or treated.

Facility Name

Emission 

Unit ID Process ID

Emissio

n 

Release 

Point ID

SCC 

Code1

Emissions 

Start Date

Emissions 

End Date

Pollutant 

CAS 

Number2

Pollutant 

Name 

(include 

organic and 

non-organic 

pollutants)

Actual 

Emissio

ns (TPY)

MACTAllowable 

Emissions 

(TPY)3

Routine 

Emission

s Max 

Hourly 

(lbs/hr)

Startup 

Emission

s (TPY)

Startup 

Emissio

ns 

(lbs/hr)

Shutdo

wn 

Emissio

ns 

(TPY)

Shutdow

n 

Emissio

ns 

(lbs/hr) MACT Source Category

Emission 

Release 

Point Type4 

Stack 

Height (ft)

Exit Gas 

Temperatu

re (°F)

Stack 

Diameter (ft)

Exit Gas 

Velocity 

(ft/sec)

Exit Gas 

Flow 

Rate 

(ft3/sec)

Fugitive 

Length (EW) (ft)

Fugitive 

Width (N-S) 

(ft)

Fugitive 

Angle 

(degrees) 

5

Longitude 

(decimal 

degrees)6

Latitude 

(decimal 

degrees)6

Is 

Control 

Measur

e In 

Place?

Control 

Measur

e 7

Control 

Measur

e 

Efficien

cy Comments

EXAMPLE 

ENTRY:

American Welding 

Paducah Plant 25 25 25 50310001 01/01/10 12/31/10 100414 Ethyl Benzene 2.45 4.32 6.7 1.24 0.08 0.61 0.2

Off-Site Waste and Recovery 

Operations vertical 44 1600 3.099999905 3.86999989 1758 NA NA NA -72.078903 41.44273758 yes flare 98%

reduction efficency based on 

manufacturer guarantees

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 75088 Acetonitrile <.001 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon Kiln 900 /carbo kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 71432 Benzene 0.001 n/a 0.0003 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 100414 Ethyl Benzene <.001 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 67561 Methyl Alcohol 0.001 n/a 0.0003 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 108101 Methyl Isobutyl <.001 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 1634044 methyl t-butyl et 0.015 n/a 0.0038 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 91203 napthlene <.001 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 100425 sytrene <.001 n/a 0.0001 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 127184 tetrachloroethyl 0.001 n/a 0.0003 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 108883 toluene 0.021 n/a 0.0054 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

Systech Environment Tanks 1&2 Tanks 1 & 2 Cement K 50310003 2/6/2012 12/31/2012 1330207 xyelene (mixed) 0.016 n/a 0.0041 n/a n/a n/a n/a

Off-Site Waste and Recovery 

Operations vertical Kiln/g kiln 43ft/carb kiln 500 / c kiln 6.9 /carbon 0.5 kiln 26,600 N/A N/A N/A -95.8125 36.195 yes Cement K Kiln 99.99 Control Devices and units combine 

1

 For SCC Code, please input one of the following codes:

SCC SCC Description

50310001 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Equipment Leaks 

50310002 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Containers

50310003 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Tanks

50310004 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Organic and Oil-Water Separators

50310005 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Surface Impoundments

50310006 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Transfer Systems

50310007 Waste Disposal, Solid Waste Disposal-Industrial, Non-TSDF Treatment, Storage, Disposal Processes, Process Vents

2

 See List of HAPs in separate worksheet for a table of CAS numbers and HAPs

3

 MACT- allowable emissions are the maximum emission levels allowed while in compliance with the MACT standards

4

 Emission point type choices include: fugitive, vertical, horizontal, goose neck, vertical with rain cap, or downward-facing vent

5

 Fugitive Angle: Specifies the rotation of the source from north (in the clockwise direction). The location coordinates should reflect the southwest corner of the area source as shown in this graphic: 

6 Location of stack or southwest corner of a fugitive emissions release point

7

 For control measures, please include all control measures used for that emission point, including but not limited to:

Activated Carbon 

Adsorption

list specific 

type in 

Control 

Measure 

Comments 

column

Combustor

list specific 

type in 

Control 

Measure 

Comments 

column

Electrostatic 

Precipitator

Fabric 

Filter/Baghouse

Flare

Pressurized Tank

Fixed Roof Tank

Fixed Roof Tank 

Vented to Control 

Device

External Floating 

Roof Tank

Fixed Roof Tank with 

Internal Floating 

Roof

Vapor Balancing

Floating Membrane 

Cover

Cover Vented to 

Control Device

High-Efficiency 

Particulate Air Filter 

(HEPA)

Leak Detection and 

Repair Program

Condenser

Scrubber

list specific 

type in 

Control 

Measure 

Comments 

column

(annual average if the parameter varies)

Vertical Emissions Release Point Parameters Fugitive Emissions Release Point 

Parameters
Enclosure 2a

Page 2

Multiple Controls in 

Series

list specific 

types in 

Control 

Measure 

Comments 

column

Other Control Device

describe in 

Control 

Measure 

Comments 

column

Pollution Prevention 

Technique

describe in 

Control 

Measure 

Comments 

column

Process Modification

describe in 

Control 

Measure 

Comments 

column
DRAFT

Pollutant Name CAS No.

Acetaldehyde 75070

Acetamide 60355

Acetonitrile 75058

Acetophenone 98862

2-Acetylaminofluorene 53963

Acrolein 107028

Acrylamide 79061

Acrylic acid 79107

Acrylonitrile 107131

Allyl chloride 107051

4-Aminobiphenyl 92671

Aniline 62533

o-Anisidine 90040

Asbestos 1332214

Benzene (including benzene from gasoline) 71432

Benzidine 92875

Benzotrichloride 98077

Benzyl chloride 100447

Biphenyl 92524

Bis(2-ethylhexyl)phthalate (DEHP) 117817

Bis(chloromethyl)ether 542881

Bromoform 75252

1,3-Butadiene 106990

Calcium cyanamide 156627

Captan 133062

Carbaryl 63252

Carbon disulfide 75150

Carbon tetrachloride 56235

Carbonyl sulfide 463581

Catechol 120809

Chloramben 133904

Chlordane 57749

Chlorine 7782505

Chloroacetic acid 79118

2-Chloroacetophenone 532274

Chlorobenzene 108907

Chlorobenzilate 510156

Chloroform 67663

Chloromethyl methyl ether 107302

Chloroprene 126998

Cresols/Cresylic acid (isomers and mixture) 1319773

o-Cresol 95487

m-Cresol 108394

p-Cresol 106445

Cumene 98828

2,4-D, salts and esters 94757

DDE 3547044

Diazomethane 334883

Dibenzofurans 132649

1,2-Dibromo-3-chloropropane 96128

Dibutylphthalate 84742

1,4-Dichlorobenzene(p) 106467

3,3-Dichlorobenzidene 91941

Dichloroethyl ether (Bis(2-chloroethyl)ether) 111444

1,3-Dichloropropene 542756

Dichlorvos 62737

Diethanolamine 111422

N,N-Diethyl aniline (N,N-Dimethylaniline) 121697

List of Hazardous Air Pollutants (HAP)
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Diethyl sulfate 64675

3,3-Dimethoxybenzidine 119904

Dimethyl aminoazobenzene 60117

3,3'-Dimethyl benzidine 119937

Dimethyl carbamoyl chloride 79447

Dimethyl formamide 68122

1,1-Dimethyl hydrazine 57147

Dimethyl phthalate 131113

Dimethyl sulfate 77781

4,6-Dinitro-o-cresol, and salts 534521

2,4-Dinitrophenol 51285

2,4-Dinitrotoluene 121142

1,4-Dioxane (1,4-Diethyleneoxide) 123911

1,2-Diphenylhydrazine 122667

Epichlorohydrin (l-Chloro-2,3-epoxypropane) 106898

1,2-Epoxybutane 106887

Ethyl acrylate 140885

Ethyl benzene 100414

Ethyl carbamate (Urethane) 51796

Ethyl chloride (Chloroethane) 75003

Ethylene dibromide (Dibromoethane) 106934

Ethylene dichloride (1,2-Dichloroethane) 107062

Ethylene glycol 107211

Ethylene imine (Aziridine) 151564

Ethylene oxide 75218

Ethylene thiourea 96457

Ethylidene dichloride (1,1-Dichloroethane) 75343

Formaldehyde 50000

Heptachlor 76448

Hexachlorobenzene 118741

Hexachlorobutadiene 87683

Hexachlorocyclopentadiene 77474

Hexachloroethane 67721

Hexamethylene-1,6-diisocyanate 822060

Hexamethylphosphoramide 680319

Hexane 110543

Hydrazine 302012

Hydrochloric acid 7647010

Hydrogen fluoride (Hydrofluoric acid) 7664393

Hydrogen sulfide 7783064

Hydroquinone 123319

Isophorone 78591

Lindane (all isomers) 58899

Maleic anhydride 108316

Methanol 67561

Methoxychlor 72435

Methyl bromide (Bromomethane) 74839

Methyl chloride (Chloromethane) 74873

Methyl chloroform (1,1,1-Trichloroethane) 71556

Methyl hydrazine 60344

Methyl iodide (Iodomethane) 74884

Methyl isobutyl ketone (Hexone) 108101

Methyl isocyanate 624839

Methyl methacrylate 80626

Methyl tert butyl ether 1634044

4,4-Methylene bis(2-chloroaniline) 101144

Methylene chloride (Dichloromethane) 75092

Methylene diphenyl diisocyanate (MDI) 101688

4,4'¬-Methylenedianiline 101779

Naphthalene 91203
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Nitrobenzene 98953

4-Nitrobiphenyl 92933

4-Nitrophenol 100027

2-Nitropropane 79469

N-Nitroso-N-methylurea 684935

N-Nitrosodimethylamine 62759

N-Nitrosomorpholine 59892

Parathion 56382

Pentachloronitrobenzene (Quintobenzene) 82688

Pentachlorophenol 87865

Phenol 108952

p-Phenylenediamine 106503

Phosgene 75445

Phosphine 7803512

Phosphorus 7723140

Phthalic anhydride 85449

Polychlorinated biphenyls (Aroclors) 1336363

1,3-Propane sultone 1120714

beta-Propiolactone 57578

Propionaldehyde 123386

Propoxur (Baygon) 114261

Propylene dichloride (1,2-Dichloropropane) 78875

Propylene oxide 75569

1,2-Propylenimine (2-Methyl aziridine) 75558

Quinoline 91225

Quinone 106514

Styrene 100425

Styrene oxide 96093

2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746016

1,1,2,2-Tetrachloroethane 79345

Tetrachloroethylene (Perchloroethylene) 127184

Titanium tetrachloride 7550450

Toluene 108883

2,4-Toluene diamine 95807

2,4-Toluene diisocyanate 584849

o-Toluidine 95534

Toxaphene (chlorinated camphene) 8001352

1,2,4-Trichlorobenzene 120821

1,1,2-Trichloroethane 79005

Trichloroethylene 79016

2,4,5-Trichlorophenol 95954

2,4,6-Trichlorophenol 88062

Triethylamine 121448

Trifluralin 1582098

2,2,4-Trimethylpentane 540841

Vinyl acetate 108054

Vinyl bromide 593602

Vinyl chloride 75014

Vinylidene chloride (1,1-Dichloroethylene) 75354

Xylenes (isomers and mixture) 1330207

o-Xylenes 95476

m-Xylenes 108383

p-Xylenes 106423

Antimony Compounds 0

Arsenic Compounds (inorganic including arsine) 0

Beryllium Compounds 0

Cadmium Compounds 0

Chromium Compounds 0

Cobalt Compounds 0

Coke Oven Emissions 0
Pollutant Name CAS No.

List of Hazardous Air Pollutants (HAP)

Cyanide Compounds 0

Glycol ethers 0

Lead Compounds 0

Manganese Compounds 0

Mercury Compounds 0

Fine mineral fibers 0

Nickel Compounds 0

Polycylic Organic Matter 0

Radionuclides (including radon) 0

Selenium Compounds 0
Other ICR 

Response Info.
PART 70 PERMIT

AIR QUALITY DIVISION

STATE OF OKLAHOMA

DEPARTMENT OF ENVIRONMENTAL QUALITY

707 N. ROBINSON STREET, SUITE 4100

P.O. BOX 1677

OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit Number: 2009-205-C

Systech Environmental Corporation,

having complied with the requirements of the law, is hereby granted permission toconstruct the Systech Environmental Facility located in Section 22, T2ON, R14E,

Rogers County, Oklahoma,subject to standard conditions dated July 21, 2009, and specific conditions, bothattached.

In the absence of commencement of construction, this permit shall expire eighteen

(18) months from the date below, except as authorized under Section VIII of the

Standard Conditions.

Director, DEQ Date
Quality on July 1, 2009. The Evaluation Memorandum dated December 21, 2010, explains the

derivation of applicable permit requirements and estimates of emissions; however, it does notcontain operating limitations or permit requirements. Commencing construction or continuingoperations under this permit constitutes acceptance of, and consent to, the conditions contained

herein:

Points of emissions and limitations for each point: [OAC 252:100-8-6(a)(1)]

EUG 1 Tanks

2. Tank #1 and Tank #2 are subject to federal New Source Performance Standards, 40 CFR

Part 60 Subpart Kb, and shall comply with all applicable standards including but notlimited to: [40 CFR 60.110 to 60.116]

a. §60.llOb

b. §60.lllbc. §60.112bd. §60.113be. §60.114bf. §60.115b

g. §60.116b

Applicability and designation of affected facility.Definitions.

Standard for VOC.

Testing and procedures.

Alternative means of emission limitation.

Reporting and recordkeeping requirements.

Monitoring of Operations.

Throughput ID# Contents (gal/yr)

Tank #1 Fuel Quality Waste 48,880,800 Tank #2 Fuel Quality Waste

EUG 2 Fugitive Emission Sources m# Contents

Fugitives Fuel Quality Waste

EUG 3 Unloading Rack

Throughput ID# Contents (gal/yr)

Unloading Rack Fuel Quality Waste 48,880,800
of valves leaking.

o. §61.243-2 Alternative standards for valves in VHAP service--skip period leak

detection and repair.

p. §61.244 Alternative means of emission limitation.

q. §61.245 Test methods and procedures.

r. §61.246 Recordkeeping requirements.s. §61.247 Reporting requirements.

4. The facility is subject to NESHAP, 40 CFR Part 61, Subpart FF and shall comply with all

applicable provisions including but not limited to:

[40 CFR Part 61, Subpart FF1

a. § 61.342 Standards: General;

b. § 61.348 Standards: Treatment processes;c. § 61.349 Standards: Closed-vent systems and control devices;d. § 61.354 Monitoring of operations;e. § 61.355 Test methods, procedures, and compliance provisions;f. § 61.356 Recordkeeping requirements; and

g. § 61.357 Reporting requirements.

5. The facility is subject to NESHAP, 40 CFR Part 63, Subpart DD and shall comply with all

applicable provisions including but not limited to: [40 CFR Part 63, Subpart DDJ

a. §63.680

b. §63.681

c. §63.683

d. §63.684

e. §63.685

f. §63.686

g. §63.687

Applicability and designation of affected sources.Definitions.

Standards: General.Standards: Off-site material treatment.Standards: Tanks.Standards: Oil-water and organic-water separators.

Standards: Surface impoundments.

f. §61.242-4

g. §61.242-5

h. §61.242-6

i. §61.242-7

j. §61.242-8

k. §61.242-9

1. §61.242-10

m. §61.242-11

n. §61.243-1

Standards: Pressure relief devices in gas/vapor service.Standards: Sampling connecting systems.

Standards: Open-ended valves or lines.Standards: Valves.Standards: Pressure relief services in liquid service and connectors.Standards: Surge control vessels and bottoms receivers.

Standards: Delay ofrepair.Standards: Closed-vent systems and control devices.

Alternative standards for valves in VHAP service--allowable percentage
p. §63.697 Reporting requirements.

q. §63.698 Implementation and enforcement.

6. Upon issuance of an operating permit, the permittee shall be authorized to operate this

facility continuously (24 hours per day, every day ofthe year).

7. The permittee shall maintain records of operation as listed below. These records shall be

retained on-site for at least five years from the date of recording, inspection, testing, or

repair, and shall be made available to regulatory personnel upon request.

[OAC 252:1 00-8-6(a)(3)(B)]

a. Throughput for Tank #1 and Tank #2 to demonstrate compliance with the limit in

Specific Condition #1 (monthly and 12-month rolling totals).

b. Records required by NSPS, 40 CFR Part 60, Subpart Kb.

c. Records required by NESHAP, 40 CFR Part 61, Subpart V.

d. Records required by NESHAP, 40 CFR Part 61, Subpart FF.e. Records required by NESHAP, 40 CFR Part 63, Subpart DD.

8. The permittee shall file an administratively complete operating permit application within

180 days of commencement of operation. The permittee shall also include in the

application any testing showing compliance with the applicable emission limitations.

[OAC 252:1 00-8-4(b)(5)]
Clean Air Act (42 U.S.C. 7401, et al.) and under the authority of the Oklahoma Clean Air Act

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

B. The issuing Authority for the permit is the . Air Quality Division (AQD) of the OklahomaDepartment of Environmental Quality (DEQ). The permit does not relieve the holder of theobligation to comply with other applicable federal, state, or local statutes, regulations, rules, orordinances. . . [Oklahoma Clean Air Act,.27A O.S. § 2-5-112].

• C. The permittee shall comply with all conditions ofthis permit. Any permit noncompliance

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

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

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

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

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

specific location listed.

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

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

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

conditions of the permit. However, nothing in this paragraph shall be construed as precludingconsideration of a need to halt or reduce activity as a mitigating factor in assessing penalties for

noncompliance if the health, safety, or environmental impacts of halting or reducing operationswould be more serious than the impacts of continuing operations. [OAC 252:100-8-6(a)(7)(B)]

SECTION. II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

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

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

XIV (Emergencies). [OAC 252:100-8-6(a)(3)(C)(iii)(I) & (II)]B. Deviations that result in emissions exceeding those allowed in this permit shall be reportedconsistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements.

• • [OAC 252:1 00-8-6(a)(3)(C)(iv)]

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

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

[OAC 252: l00-8-6(a)(3)(C)(iv)J
the permit may specify that records may .be maintained in computerized form.

[OAC 252:100-8-6 (a)(3)(B)(ii), OAC 252:1 00-8-6(c)(1), and OAC 252:1 00-8-6(c)(2)(B)]

B. Records ofrequired monitoring shall include:

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

(2) the date or dates analyses were performed;(3) the company or entity which performed the analyses;(4) the analytical techniques or methods used;(5) the results of such analyses; and

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

[OAC 252:1 00-8-6(a)(3)(B)(i)]

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

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

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

monitoring. All instances of deviations from permit requirements since the previous report shallbe clearly identified in the report. Submission of these periodic reports will satisfy any reporting

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

submitted report. [OAC 252:1 00-8-6(a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner oroperator shall comply with the provisions of Section II (Reporting Of Deviations From PermitTerms) ofthese standard conditions. . [OAC 252:1 00-8-6(a)(3)(C)(iii)]

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

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

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

Air Act or Oklahoma Clean Air Act. [OAC 252:100-431F. Any Annual Certification of Compliance, Semi Annual Monitoring and Deviation Report,Excess Emission Report, and Annual Emission Inventory submitted in accordance with this

permit shall be certified by a responsible official. This certification shall be signed by aresponsible official, and shall contain the following language: “I certify, based on information

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

true, accurate, and complete.”

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

252:100-9-7(e), and OAC 252:100-5-2.1(f)]
continuous monitoring system or monitoring device is inOperative.

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

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

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

achieving the activities, milestones or compliance required in the schedule of compliance and thedates ‘when such activities, milestones or compliance was achieved. The V progress reports shall

also contain an explanation of why any dates in the schedule of compliance were not or will notbe met, and any preventive or corrective measures adopted. V V , .[OAC 252:100-8-6(c)(4)]

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

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

accordance with standard test procedures. The use of alternative test procedures must beapproved by EPA. When a portable analyzer is used to V measure emissions it shall be setup,calibrated, and operated in accordance with the manufacturer’s instructions and in accordance

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

or an equivalent method approved by Air Quality. V V V

[OAC 252:100-8-6(a)(3)(A)(iv), and OAC 252:100-431

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

(Permits for Part 70 Sources), OAC 252:100-19 (Control ofEmission of Particulate Matter), andOAC 252:100-5 (Emission Inventory), shall be conducted in accordance with applicable testing

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

particulate matter less than 10 microns in diameter (PM10). NSPS may allow reporting of onlyparticulate matter emissions caught in the filter (obtained using Reference Method 5).

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

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

subject to such standards. V [OAC 252:l00-8-6(c)(1) and OAC 252:100, Appendix Q]SECTION IV. COMPLIANCE CERTIFICATIONS ‘ V V V

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

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

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

certification of compliance with the terms and conditions of this permit and of any otherapplicable requirements which have become effective since the issuance of this permit. V

[OAC 252: i00-8-6(c)(5)(A), and (D)1
results of the required monitoring. This certification shall be signed by a responsible official,

and shall contain the following language: “I certify, based on information and belief formedafter reasonable inquiry, the statements and information in the document are true, accurate, and

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

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissionsunits or stationary sources that are not in compliance with all applicable requirements. This

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

actions with milestones, leading to~ compliance with any applicable requirements for which theemissions unit or .stationary source is in noncompliance. This compliance schedule shall

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

administrative order to which the emissions unit or stationary source is subject. Any suchschedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the

applicable requirements on which it is based, except that a compliance plan shall not be requiredfor any noncompliance condition which is corrected within 24 hours of discovery.

[OAC 252:l00-8-5(e)(8)(B) and OAC 252:100-8-6(c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE

PERMIT TERM

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

permit term and that are applicable to the facility. Compliance with all new requirements shallbe certified in the next annual certification. [OAC 252:100-8-6(c)(6)]

SECTION VI. PERMIT SHIELD

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

established for alternate operating scenarios, emissions trading, and emissions averaging, butexcluding terms and conditions for which the permit shield is expressly prohibited under OAC

252:100-8) shall be deemed compliance with the applicable requirements identified and includedin this permit. [OAC 252:100-8-6(d)(1)]

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

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

applicable are summarized in the Specific Conditions ofthis permit. [OAC 252:l00-8-6(d)(2)]
A. Unless specified otherwise, the term of an operating permit shall be five years from the dateof issuance. [OAC 252:1 00-8-6(a)(2)(A)]B. A source’s right to operate shall terminate upon the expiration of its permit unless a timelyand complete renewal application has been submitted at least 180 days before the date ofexpiration. [OAC 252:100-8-7.1 (d)( 1)1C. A duly issued construction permit or authorization to construct or modify will terminate and

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

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

work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]D. The recipient of a construction permit shall apply for a permit to operate (or modifiedoperating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the applicationof any provision of this permit to any circumstance, is held invalid, the application of such

provision to other circumstances, and the remainder ofthis permit, shall not be affected thereby.

[OAC 252:100-8-6 (a)(6)j

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege.

[OAC 252:1 00-8-6(a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon

which the equipment is located and does not release the permittee from any liability for damageto persons or property caused by or resulting from the maintenance or operation ofthe equipmentfor which the permit is issued. [OAC 252:100-8-6(c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty

(60) days of the request unless the DEQ specifies another time period, any information that the

DEQ may request to determine whether cause exists for modifying, reopening, revoking,
C. Notification to the AQD of the sale or transfer of ownership of this facility is required andshall be made in writing within thirty (30) days after such sale or transfer.

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

SECTION XII. REOPENING, MODIFICATION & REVOCATION

A. The permit may be modified, revoked, reopened and reissued, or terminated for cause.Except as provided for minor permit modifications, the filing of a request by the permittee for a

permit modification, revocation and reissuance, termination, notification of planned changes, or

anticipated noncompliance does not stay any permit condition.

[OAC 252:1 00-8-6(a)(7)(C) and OAC 252:100-8-7.2(b)]

B. The DEQ will reopen and revise or revoke this permit prior to the expiration date in the

following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source

category three or more years prior to the expiration date of this permit. No such

reopening is required if the effective date of the requirement is later than the expiration

date ofthis permit.

(2) The DEQ or the EPA determines that this permit contains a material mistake or that the

permit must be revised or revoked to assure compliance with the applicable requirements.

(3) The DEQ or the EPA determines that inaccurate information was used in establishing the

emission standards, limitations, or other conditions of this permit. The DEQ may revoke

and not reissue this permit if it determines that the permittee has submitted false or

misleading information to the DEQ.

(4) DEQ determines that the permit should be amended under the discretionary reopening

provisions of OAC 252:100-8-7.3(b).

C. The permit may be reopened for cause by EPA, pursuant to the provisions of OAC 100-8-7.3(d). [OAC 100-8-7.3(d)]

D. The permittee shall notify AQD before making changes other than those described in SectionXVIII (Operational Flexibility), those qualifying for administrative permit amendments, or thosedefined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII). The

notification should include any changes which may alter the status of a “grandfathered source,”

as defined under AQD rules. Such changes may require a permit modification.

[OAC 252:100-8-7.2(b) and OAC 252:100-5-1.1]
§ 

for confidential information submitted to or obtained by the DEQ under this section):

(1) enter upon the permitte&s premises during reasonable/normal working hours where a

source is located or emissions-related activity is conducted, or where records must be

kept under the conditions ofthe permit;

(2) have access to and copy, at reasonable times, any records that must be kept under the

conditions ofthe permit;

(3) inspect, at reasonable times and using reasonable safety practices, any facilities,

equipment (including monitoring and air pollution control equipment), practices, oroperations regulated or required under the permit; and

(4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times

substances or parameters for the purpose of assuring compliance with the permit.

[OAC 252:1 00-8-6(c)(2)J

SECTION XIV. EMERGENCIES

A. Any exceedance resulting from an emergency shall be reported to AQD promptly but no later

than 4:30 p.m. on the next working day after the permittee first becomes aware of the

exceedance. This notice shall contain a description of the emergency, the probable cause of theexceedance, any steps taken to mitigate emissions, and corrective actions taken.

[OAC 252:100-8-6 (a)(3)(C)(iii)(I) and (IV)]

B. Any exceedance that poses an imminent and substantial danger to public health, safety, or the

environment shall be reported to AQD as soon as is practicable; but under no circumstance shall

notification be more than 24 hours after the exceedance. [OAC 252:1 00-8-6(a)(3)(C)(iii)(II)]

C. An “emergency” means any situation arising from sudden and reasonably unforeseeable

events beyond the control of the source, including acts of God, which situation requiresimmediate corrective action to restore normal operation, and that causes the source to exceed a

technology-based emission limitation under this permit, due to unavoidable increases in

emissions attributable to the emergency. An emergency shall not include noncompliance to theextent caused by improperly designed equipment, lack of preventive maintenance, careless or

improper operation, or operator error. [OAC 252:100-8-21

D. The affirmative defense of emergency shall be demonstrated through properly signed,

contemporaneous operating logs or other relevant evidence that: [OAC 252:100-8-6 (e)(2)]

(1) an emergency occurred and the permittee can identify the cause or causes of the

emergency;
F. Every written report or document submitted under this section shall be certified as required

by Section III (Monitoring, Testing, Recordkeeping & Reporting), Paragraph F.

[OAC 252:1 00-8-6(a)(3)(C)(iv)J

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall developand register with the appropriate agency a risk management plan by June 20, 1999, or theapplicable effective date. [OAC 252:1 00-8-6(a)(4)]SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate individual emissions units that are either on the list in Appendix I to OAC Title 252,Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below.

Any activity to which a State or Federal applicable requirement applies is not insignificant even

ifit meets the criteria below or is included on the insignificant activities list.

(1) 5 tons per year of any one criteria pollutant.(2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an

aggregate oftwo or more HAP’s, or 20 percent of any threshold less than 10 tons per yearfor single HAP that the EPA may establish by rule.

[OAC 252:100-8-2 and OAC 252:100, Appendix I]

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to

operate any individual or combination of air emissions units that are considered inconsequential

and are on the list in Appendix J. Any activity to which a State or Federal applicable

requirement applies is not trivial even ifincluded on the trivial activities list.

[OAC 252:100-8-2 and OAC 252:100, Appendix J]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without theneed for any permit revision or any notification to the DEQ (unless specified otherwise in the

permit). When an operating scenario is changed, the permittee shall record in a log at the facilitythe scenario under which it is operating. [OAC 252:100-8-6(a)(10) and (f)(1)]
below in advance of the proposed changes, which shall be a minimum of seven (7) days, or

twenty four (24) hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, theDEQ, and the EPA shall attach each such notice to their copy of the permit. For each such

change, the written notification required above shall include a brief description of the change

within the permitted facility, the date on which the change will occur, any change in emissions,and any permit term or condition that is no longer applicable as a result of the change. The

permit shield provided by this permit does not apply to any change made pursuant to thisparagraph. [OAC 252:1 00-8-6(f)(2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

A. The following applicable requirements and state-only requirements apply to the facilityunless elsewhere covered by a more restrictive requirement:

(1) Open burning of refuse and other combustible material is prohibited except as authorized

in the specific examples and under the conditions listed in the Open Burning Subchapter.

[OAC 252:100-131

(2) No particulate emissions from any fuel-burning equipment with a rated heat input of 10

MMBTUH or less shall exceed 0.6 1b/MMBTU. [OAC 252:100-19]

(3) For all emissions units not subject to an opacity limit promulgated under 40 C.F.R., Part

60, NSPS, no discharge of greater than 20% opacity is allowed except for:

[OAC 252:100-25]

(a) Short-term occurrences which consist of not more than one six-minute period in any

consecutive 60 minutes, not to exceed three such periods in any consecutive 24 hours.

In no case shall the average of any six-minute period exceed 60% opacity;

(b) Smoke resulting from fires covered by the exceptions outlined in OAC 252:100-13-7;(c) An emission, where the presence of uncombined water is the only reason for failure

to meet the requirements of OAC 252:100-25-3(a); or

(d) Smoke generated due to a malfunction in a facility, when the source of the fuel

producing the smoke is not under the direct and immediate control of the facility andthe immediate constriction of the fuel flow at the facility would produce a hazard to

life and/or property.

(4) No visible fugitive dust emissions shall be discharged beyond the property line on which

the emissions originate in such a manner as to damage or to interfere with the use of
with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia

or greater under actual conditions shall be equipped with a permanent submerged fill pipeor with a vapor-recovery system. [OAC 252:100-37-15(b)]

(7) All fuel-burning equipment shall at all times be properly operated and maintained in a

manner that will minimize emissions of VOCs. [OAC 252:100-37-36]

SECTION XX. STRATOSPHERIC OZONE PROTECTION

A. The permittee shall comply with the following standards for production and consumption of

ozone-depleting substances: [40 CFR 82, Subpart A]

(1) Persons producing, importing, or placing an order for production or importation of certain

class I and class II substances, HCFC-22, or HCFC-141b shall be subject to the

requirements of §82.4;

(2) Producers, importers, exporters, purchasers, and persons who transform or destroy certain

class I and class II substances, HCFC-22, or HCFC-141b are subject to the recordkeeping

requirements at §82.13; and

(3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons,

HBFCs, carbon tetrachloride, trichioroethane (methyl chloroform), and bromomethane

(Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include

HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves anozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle airconditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term

“motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the

vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the

air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger

buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions

reduction except as provided for MVACs in Subpart B: [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply

with the required practices pursuant to § 82.156;

(2) Equipment used during the maintenance, service, repair, or disposal of appliances must

comply with the standards for recycling and recovery equipment pursuant to § 82.158;

(3) Persons performing maintenance, service, repair, or disposal of appliances must be
SECTION XXI. TITLE

V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it isnot inconsistent with Federal requirements, to provide for incorporation of requirements

established through construction permitting into the Source’s Title

V permit without causing

redundant review. Requirements from construction permits may be incorporated into the Title

V

permit through the administrative amendment process set forth in OAC 252:100-8-7.2(a) only ifthe following procedures are followed:

(1) The construction permit goes out for

a 30-day public notice and comment using the

procedures set forth in 40 C.F.R. § 70.7(h)(1). This public notice shall include notice to

the public that this permit is subject to EPA review, EPA objection, and petition to

EPA, as provided by 40 C.F.R. § 70.8; that the requirements of the construction permit

will be incorporated into the Title

V permit through the administrative amendment

process; that the public will not receive another opportunity to provide comments whenthe requirements are incorporated into the Title

V permit; and that EPA review, EPA

objection, and petitions to EPA will not be available to the public when requirementsfrom the construction permit are incorporated into the Title

V permit.

(2)

A copy of the construction permit application is sent to EPA, as provided by 40 CFR §

70.8(a)(1).

(3)

A copy of the draft construction permit is sent to any affected State, as provided by 40

C.F.R. § 70.8(b).

(4)

A copy of the proposed construction permit is sent to EPA for

a 45-day review period

as provided by 40 C.F.R.~ 70.8(a) and (c).

(5) The DEQ complies with 40 C.F.R. § 70.8(c) upon the written receipt within the 45-day

comment period of any EPA objection to the construction permit. The DEQ shall notissue the permit until EPA’s objections are resolved to the satisfaction ofEPA.

(6) The DEQ complies with 40 C.F.R. § 70.8(d).(7)

A copy of the final construction permit is sent to EPA as provided by 40 CFR § 70.8(a).

(8) The DEQ shall not issue the proposed construction permit until any affected State and

EPA have had an opportunity to review the proposed permit, as provided by these

permit conditions.

(9) Any requirements of the construction permit may be reopened for cause after

incorporation into the Title

V permit by the administrative amendment process, by

DEQ as provided in OAC 252:100-8-7.3(a), (b), and (c), and by EPA as provided in 40

C.F.R. § 70.7(f) and (g).
For the purpose of submitting compliance certifications or establishing whether or not

a person

has violated or is in violation of any provision of the Oklahoma implementation plan, nothing

shall preclude the use, including the exclusive use, of any credible evidence or information,

relevant to whether

a source would have been in compliance with applicable requirements if the

appropriate performance or compliance test or procedure had been performed.

[OAC 252:100-43-6]