Oklahoma Department of Environmental Quality s26

OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY AIR QUALITY DIVISION

MEMORANDUM April 26, 2006

TO: Dawson Lasseter, P.E., Chief Engineer, Air Quality

THROUGH: Grover Campbell, P.E., Existing Source Permits Section

THROUGH: Phil Martin, P.E., New Source Permits Section

THROUGH: Peer Review

FROM: Eric L. Milligan, P.E., Engineering Section

SUBJECT: Evaluation of Permit Application 2006-051-TVR Duke Energy Field Services, L.P. Carney Gas Plant (SIC 1321) NE/4 of NW/4 of Section 12-T15N-R2E, Lincoln County Directions: 1 mile south of Carney and 1½ miles west of Hwy 177

SECTION I. INTRODUCTION

Duke Energy Field Services has requested renewal of their current Part 70 operating permit. The facility is currently operating as authorized by Permit No. 96-355-TV (M-3), dated January 21, 2006. This permit incorporates CAM for the rich-burn internal combustion engines with catalytic converters that have the potential to emit greater than 100 TPY prior to control (engines P-ENG3 and P-ENG15). The following changes requested by the company have also been incorporated:

 Revision of serial numbers, in the permit memorandum, of engines that were replaced;  Removal of P-ENG12 which is permanently taken out of service;  Engine P-ENG14 is only used for emergency electrical generation and qualifies as an insignificant emission unit and the company requests that it not be included with the other compressor engines;  Add a new 210-barrel atmospheric/environmental water tank (EU-3, P-T32);  Remove tanks P-T22 and P-T23 since they are permanently out of service;  Other minor revisions to listed tank sizes; PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 2

The permittee requested two operating scenarios. One scenario when the gas plant was operating and NSPS, Subpart KKK is applicable and the other scenario when the gas plant is not operating and NSPS, Subpart KKK is not applicable. However, applicability of NSPS, Subpart KKK can only change if the gas plant is permanently shut down and never restarted.

SECTION II. FACILITY DESCRIPTION

The facility was constructed as a cryogenic natural gas processing plant, to extract hydrocarbon liquids from raw natural gas streams. Two raw natural gas streams (high-pressure and low- pressure) are delivered to the plant. After extraction of the hydrocarbon liquids, residue gas and liquids are sold as product. The facility is currently operating as a booster station and the gas is sent to the Kingfisher Gas Plant after compression and dehydration. It is anticipated that the hydrocarbon liquids extraction process will be restarted at a future date.

Low-pressure gas enters the plant through a separator, for removal of free liquids, and is then compressed by the inlet compressors (Engines # 2, 3, 8, 9, and 10). This stream and the high- pressure gas stream are then combined upstream of a glycol dehydration unit. Depending on future field conditions, the high-pressure stream may bypass glycol dehydration and combine with the low-pressure inlet downstream of this unit.

The glycol dehydration unit uses triethylene glycol (TEG) to remove entrained water from the gas stream. Gas and glycol counter flow in the dehydrator, where the TEG through direct contact with the gas removes the water vapor. After regeneration, “lean” glycol is recirculated through the system.

Dry gas from the contactor is then compressed by pre-boost compressors (Engines #6 and/or 7) prior to process dehydration. Process dehydration is accomplished by two molecular sieve beds, one in service while the other is being regenerated. Regeneration of the molecular sieve is conducted by passing a heated gas slipstream through the bed for removal of water. The wet gases are then cooled and condensed removing the water.

Dehydrated gas is cooled through a series of heat exchangers. Condensed liquids are fed directly to the demethanizer while vapors are routed to the turboexpander. A near isotropic expansion reduces pressure and temperature while also delivering shaft work to the recompressor.

Mixed hydrocarbon product (ethane, propane, butane, condensate (EPBC)) is separated from the residue gas (primarily methane) in the demethanizer. EBPC is transported via pipeline to ONEOK for fractionation. Residue gas is transported from the plant via pipeline after compression (engines #5 or 11). Condensate from the separators is transported via pipeline. Condensate from the low pressure inlet scrubber and low-pressure dumps are transported by truck. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 3

Emission units (EUs) have been arranged into Emission Unit Groups (EUGs) in the following outline. There is only one operating scenario for the facility. For this scenario, pipeline-quality natural gas is the primary fuel for the engines, which are operated continuously.

SECTION III. EQUIPMENT

The following table lists both the emission unit, engine designation by the company, and description including serial number to provide a tracking mechanism. The equipment listed represents the facility as it is currently.

EUG 1 and 2 Internal Combustion Engines EUG EU Point Make/Model Hp Serial # Const. Date 1 2 P-ENG2 White 8G825 W/CC 800 15838 2000 1 3 P-ENG3 Waukesha L7042 GSI W/CC 1,100 385982 2004 1 5 P-ENG5 White 6G825 W/CC 600 17682R 2000 1 6 P-ENG6 White 8G825 W/CC 800 17620 2002 1 7 P-ENG7 White 8G825 W/CC 800 17116 1980 1 8 P-ENG8 Clark RA-8 800 25508 1980 1 9 P-ENG9 White 8G825 W/CC 800 2219277401 1999 1 10 P-ENG10 Caterpillar 399TA W/CC 830 49C00900 1980 1 11 P-ENG11 White 6G825 W/CC 600 283559 2000 1 15 P-ENG15 Waukesha P9390G W/CC 1,194 288644 2005 W/CC - With Catalytic Converter.

EUG 3 Tanks VP EUG EU Point Contents Gallons (psia) Const. Date 3 EU-3 P-T17 Methanol 1,000 1.6 1993 * * P-T18 Antifreeze 4,700 0.01 --- 3 EU-3 P-T19 Condensate 8,820 3-8 1992 3 EU-3 P-T20 Condensate 8,820 3-8 1992 3 EU-3 P-T30 Condensate 8,820 3-8 2000 3 EU-3 P-T31 Methanol 8,820 1.6 2001 3 EU-3 P-T32 Slop Water 8,820 <0.5 2003 * These tanks are not assigned to EUGs or EUs, because the emissions associated with these units are negligible. These tanks are included here only for the sake of completeness. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 4

EUG 4 Tanks 4 EU-4 P-T21 Mixed Gas Liquids 30,000 350 Pre-1975 (Pressurized) 4 EU-4 P-T24 Condensate (Pressurized) 40,000 25 Pre-1975 4 EU-4 P-T25 Condensate (Pressurized) 28,000 50 Pre-1975 4 EU-4 P-T26 Condensate (Pressurized) 28,000 150 Pre-1975 4 EU-4 P-T27 Propane (Pressurized) 16,000 100 Pre-1975 * * P-T28 Lube Oil 5,000 0.01 --- * * P-T29 Lube Oil 6,500 0.01 --- * These tanks are not assigned to EUGs or EUs, because the emissions associated with these units are negligible. These tanks are included here only for the sake of completeness.

In addition to the tanks listed above, the facility has a water storage tank, a slop water tank, a 250-gallon triethylene glycol tank, a 1,000-gallon kerosene tank, and a 500-gallon diesel tank. There are also some tanks stored at the site, but which are not in service.

EUG 5 Condensate Truck Loading EU Type of Equipment 1 Loading Operations

EUG 6 Dehydration Unit’s Reboiler and Still Vent W/Condenser EU Type of Equipment Rated Heat Input Const Date 1 Reboiler 0.5 MMBTUH 1984

EUG 7 Fugitives Emissions EU Type of Equipment 1 Valves, flanges, and miscellaneous

Point Make/Model Height Dia. Flow Temp. Fuel (feet) (inches) (ACFM) (°F) (SCFH) P-ENG2 White 8G8251 19 11 4,608 1,340 6,200 P-ENG3 Waukesha L7042 GSI1 31 11 5,091 1,028 8,269 P-ENG5 White 6G8251 24 8 3,160 1,250 4,800 P-ENG6 White 8G8251 23 11 4,608 1,340 6,200 P-ENG7 White 8G8251 28 8 4,608 1,340 6,200 P-ENG8 Clark RA-8 28 14 6,985 1,400 8,000 P-ENG9 White 8G8251 19 11 4,608 1,340 6,200 P-ENG10 Caterpillar 399TA1 18 12 3,767 1,108 6,673 P-ENG11 White 6G8251 15 8 3,160 1,250 4,800 P-ENG15 Waukesha P9390G1 20 12 6,095 1,114 9,225 1 - with catalytic converter PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 5

SECTION IV. EMISSIONS

Emissions from the engines are based on continuous operation and the following emission factors. Engine Emissions Factors (g/hp-hr)

Sources NOX CO VOC White 8G825 engines W/CC; P-ENG2, P-ENG6, P-ENG9 3.0 2.0 0.5 Waukesha L7042 GSI engine W/CC; P-ENG3 3.0 3.0 0.5 White 6G825 engines W/CC; P-ENG5 3.0 2.0 0.5 White 8G825 engines W/CC; P-ENG7 3.0 3.0 0.5 Clark RA-8 engine; P-ENG8 22.3 5.0 2.0 Caterpillar 399TA engine W/CC; P-ENG10 3.0 3.0 0.5 White 6G825 engines W/CC; P-ENG11 3.0 3.0 0.5 Waukesha P9390G W/CC; P-ENG15 3.0 3.0 0.5 W/CC – With Catalytic Converter

Emissions from the tanks are based on TANKS3.1. There are no emissions from the pressurized tanks. Flashing losses/emissions from the condensate tanks are based on the Vasquez-Beggs gas/oil correlation method and a throughput of 777,400-gallons per year. Emissions from loading of condensate are based on AP-42 (1/95), Section 5.2 (4.85 lb/1,000 gallons) and 777,400 gallons splash-loaded per year. Fugitive VOC emissions are based on EPA’s “1995 Protocol for Equipment Leak Estimates” (EPA-453/R-95-017) average emission factors for oil and gas production, an estimated % C3+, and an estimated number of components. Emissions from the glycol dehydration unit’s reboiler and the mole sieve heater are based on AP-42 (7/98), Chapter 1.4, and continuous operation. Emissions of VOC from the glycol dehydration unit equipped with a flash tank and a condenser are based on an extended gas analysis, a natural gas throughput of 24 MMSCFD, a lean glycol recirculation rate of 3.5 gallon per minute (gpm), and GRI-GlyCalc Version 4.0 with the exhaust gases from the flash tank being combusted in the reboiler and the still vent being routed through a condenser. Dehydration units using glycol desiccants will emit benzene, toluene, ethyl benzene, xylene, and n-hexane from the glycol reboiler vapor stack/condenser. These compounds are regulated as HAP. Emissions of HAP are below the major source thresholds.

EUG-6 Dehydration Unit – HAP Emissions Controlled Emissions Pollutant CAS # lb/hr TPY Benzene 71432 0.0272 0.1191 Ethylbenzene 108883 0.0022 0.0096 Toluene 100414 0.0173 0.0758 Xylene 1330207 0.0114 0.0499 n-Hexane 110543 0.0653 0.2860

Totals 0.1234 0.5404 PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 6

EUG 7 Fugitive VOC Emissions Emission Equipment %C3+ Factor (lb/hr) TPY Wet Gas Service 680 Valves 24 0.00992 1.61894 7.09096 1,764 Flanges 24 0.00086 0.36409 1.59471 46 Others 24 0.01940 0.21418 0.93811 Light Oil Service 570 Valves 100 0.00550 3.13500 13.73130 1,425 Flanges 100 0.00024 0.34200 1.49796 5 Pump Seals 100 0.02866 0.14330 0.62765

Total Fugitive Emissions 5.81751 25.48069

Emissions Summary - Criteria Pollutants

NOX CO VOC EUG/Pt lb/hr TPY lb/hr TPY lb/hr TPY 1/P-ENG2 5.29 23.18 3.53 15.45 0.88 3.86 1/P-ENG3 7.28 31.87 7.28 31.87 1.21 5.31 1/P-ENG5 3.97 17.38 2.65 11.59 0.66 2.90 1/P-ENG6 5.29 23.18 3.53 15.45 0.88 3.86 1/P-ENG7 5.29 23.18 5.29 23.18 0.88 3.86 1/P-ENG8 39.33 172.27 8.82 38.63 3.53 15.45 1/P-ENG9 5.29 23.18 3.53 15.45 0.88 3.86 1/P-ENG10 5.49 24.04 5.49 24.04 0.91 4.01 1/P-ENG11 3.97 17.38 3.97 17.38 0.66 2.90 1/P-ENG15 7.90 34.59 7.90 34.59 1.32 5.77 3 – Tanks ------23.90 5 - Loading ------1.89 6/1 Reboiler 0.05 0.22 0.04 0.18 <0.01 0.01 6/1 Still Vent ------1.51 6.61 7/1 ------5.82 25.48 ISA - Regen 0.16 0.69 0.13 0.58 0.01 0.04 ISA - ENG14 13.50 3.38 14.74 3.69 1.10 0.28

Total 102.81 394.54 66.90 232.08 20.26 109.99 ISA – Insignificant Activity not listed as an EU or EUG. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 7

The internal combustion engines have emissions of HAP, the most significant being formaldehyde. Formaldehyde emission estimates are based on continuous operation and the emission factors below. The factors for the rich-burn engines with catalytic converters were reduced by 75% to estimate reductions due to the use of the catalytic converters. The facility is still a minor source of HAP.

Formaldehyde Emissions from the Engines Factor Est. Emissions Point Make/Model Hp MMBTUH lb/MMBTU lb/hr TPY P-ENG2 White 8G8251 800 6.20 0.0051 0.032 0.140 P-ENG3 Waukesha L7042 GSI1 1,100 8.27 0.0051 0.042 0.184 P-ENG5 White 6G8251 600 4.80 0.0051 0.024 0.105 P-ENG6 White 8G8251 800 6.20 0.0051 0.032 0.140 P-ENG7 White 8G8251 800 6.20 0.0051 0.032 0.140 P-ENG8 Clark RA-8 800 8.00 0.0205 0.164 0.718 P-ENG9 White 8G8251 800 6.20 0.0051 0.032 0.140 P-ENG10 Caterpillar 399TA1 830 6.67 0.0051 0.034 0.149 P-ENG11 White 6G8251 600 4.80 0.0051 0.024 0.105 P-ENG14 Caterpillar G398TA1 625 5.24 0.0051 0.027 0.012 P-ENG15 Waukesha P9390G1 1,194 9.23 0.0051 0.047 0.206

Totals 0.490 2.039 1 - with catalytic converter.

SECTION V. INSIGNIFICANT ACTIVITIES

The insignificant activities identified and justified in the application are duplicated below. Appropriate recordkeeping of activities indicated below with “*” is specified in the Specific Conditions.

1. Stationary reciprocating internal combustion engines burning natural gas, gasoline, aircraft fuels, or diesel fuel which are either used exclusively for emergency power generation or for peaking power service not exceeding 500 hours per year. The facility has a 625-hp Caterpillar G398TA engine that is used for emergency power generation and does not operate more than 500 hours per year.

2. Space heaters, boilers, process heaters, and emergency flares less than or equal to 5 MMBTUH heat input (commercial natural gas). The glycol dehydration units reboiler and the mole sieve regeneration heater are both less than 5 MMBUTH and others may be used in the future. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 8

3. Emissions from stationary internal combustion engines rated less than 50-hp output. The facility’s equipment includes an air compressor, equipment washer, and miscellaneous small equipment powered by an internal combustion engine rated at less than 50-hp and other small engines may be used in the future.

4. * Storage tanks with less than or equal to 10,000 gallons capacity that store volatile organic liquids with a true vapor pressure less than or equal to 1.0 psi at maximum storage temperature. Tanks T-18, T-19, T-28, and T-29 store miscellaneous materials including lube oil and antifreeze. These tanks have capacities less than 10,000 gallons and the vapor pressures of the materials stored are less than 1.0 psi and other tanks may be added in the future.

5. Emissions from crude oil and condensate marine and truck loading equipment operations at crude oil and natural gas production sites where the loading rate does not exceed 10,000 gallons per day averaged over a 30-day period. During May 1998 loading operations averaged 4,196 gallons per day.

6. * Emissions from storage tanks constructed with a capacity less than 39,894 gallons, which store VOC with a vapor pressure less than 1.5 psia at maximum storage temperature. All tanks under #4 are also covered here.

7. Additions or upgrades of instrumentation or control systems that result in emissions increases less than the pollutant quantities specified in OAC 252:100-8-3(e)(1). None identified but may be conducted in the future.

8. Cold degreasing operations utilizing solvents that are denser than air. A parts washer is on site, but uses a solvent with a vapor density heavier than air.

9. Site restoration and/or bioremediation activities <5 years expected duration. The facility has a soil vapor extraction remediation system.

10. Emissions from the operation of groundwater remediation wells including but not limited to emissions from venting, pumping, and collecting activities subject to de minimis limits for air toxics (OAC 252:100-41-43) and HAPs (§112(b) of CAAA90).

11. * Surface coating and degreasing operations which do not exceed a combined total usage of more than 60 gallons/month of coatings, thinners, clean-up solvents, and degreasing solvents at any one emission unit.

12. Hand wiping and spraying of solvents from containers with less than 1 liter capacity used for spot cleaning and/or degreasing in ozone attainment areas. Routine maintenance on compressor engines might require use of a degreasing solvent sprayed from containers with less than a 1 liter capacity. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 9

13. * Activities that have the potential to emit no more than 5 TPY (actual) of any criteria pollutant. The 1,000 gallon methanol tank has emissions of less than 5 TPY. No activities were identified at this time but may be in the future.

SECTION VI. OKLAHOMA AIR POLLUTION CONTROL RULES

OAC 252:100-1 (General Provisions) [Applicable] Subchapter 1 includes definitions but there are no regulatory requirements.

OAC 252:100-3 (Air Quality Standards and Increments) [Applicable] Primary Standards are in Appendix E and Secondary Standards are in Appendix F of the Air Pollution Control Rules. At this time, all of Oklahoma is in attainment of these standards.

OAC 252:100-4 (New Source Performance Standards) [Applicable] Federal regulations in 40 CFR Part 60 are incorporated by reference as they exist on July 1, 2002, except for the following: Subpart A (Sections 60.4, 60.9, 60.10, and 60.16), Subpart B, Subpart C, Subpart Ca, Subpart Cb, Subpart Cc, Subpart Cd, Subpart Ce, Subpart AAA, and Appendix G. NSPS regulations are addressed in the “Federal Regulations” section.

OAC 252:100-5 (Registration, Emission Inventory, and Annual Fees) [Applicable] The owner or operator of any facility that is a source of air emissions shall submit a complete emission inventory annually on forms obtained from the Air Quality Division. An emission inventory was submitted and fees paid for previous years as required.

OAC 252:100-8 (Permits for Part 70 Sources) [Applicable] Part 5 includes the general administrative requirements for Part 70 permits. Any planned changes in the operation of the facility which result in emissions not authorized in the permit and which exceed the “Insignificant Activities” or “Trivial Activities” thresholds require prior notification to AQD and may require a permit modification. Insignificant activities mean individual emission units that either are on the list in Appendix I (OAC 252:100) or whose actual calendar year emissions do not exceed the following limits:

 5 TPY of any one criteria pollutant  2 TPY of any one hazardous air pollutant (HAP) or 5 TPY of multiple HAPs or 20% of any threshold less than 10 TPY for single HAP that the EPA may establish by rule

Emissions limitations are based on the previous permits and information in the permit application. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 10

OAC 252:100-9 (Excess Emission Reporting Requirements) [Applicable] In the event of any release which results in excess emissions, the owner or operator of such facility shall notify the Air Quality Division as soon as the owner or operator of the facility has knowledge of such emissions, but no later than 4:30 p.m. the next working day. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Part 70/Title V sources must report any exceedance that poses an imminent and substantial danger to public health, safety, or the environment as soon as is practicable. Under no circumstances shall notification be more than 24 hours after the exceedance.

OAC 252:100-13 (Open Burning) [Applicable] Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in this subchapter.

OAC 252:100-19 (Particulate Matter) [Applicable] This subchapter specifies a particulate matter (PM) emissions limitation of 0.6 lb/MMBTU from indirect fired fuel-burning equipment with a rated heat input of 10 MMBTUH or less. For external combustion units burning natural gas, AP-42, Table 1.4-2 (7/98), lists the total PM emissions for natural gas to be 7.6 lb/MMft3 or about 0.0076 lb/MMBTU. For 4-cycle rich burn engines burning natural gas, AP-42 (7/00), Section 3.2 lists the total PM emissions as 0.01 lb/MMBTU. The permit requires the use of commercial-grade natural gas for all fuel-burning equipment to ensure compliance with Subchapter 19.

This subchapter also limits PM from direct-fired fuel-burning units and industrial processes that can be reasonably expected to emit PM. Per AP-42 factors, there are no significant particulate emissions from any activity at this facility except indirectly fired fuel-burning equipment.

OAC 252:100-25 (Visible Emissions and Particulates) [Applicable] No discharge of greater than 20% opacity is allowed except for 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. When burning natural gas, there is very little possibility of exceeding the opacity standards.

OAC 252:100-29 (Fugitive Dust) [Applicable] No person shall cause or permit the discharge of any visible fugitive dust emissions beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. Under normal operating conditions, this facility will not cause a problem in this area; therefore it is not necessary to require specific precautions to be taken. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 11

OAC 252:100-31 (Sulfur Compounds) [Applicable] Part 5 limits sulfur dioxide emissions from new fuel-burning equipment (constructed after July 1, 1972). For gaseous fuels the limit is 0.2 lb/MMBTU heat input. This is equivalent to approximately 0.2 weight percent sulfur in the fuel gas which is equivalent to 2,000 ppmw sulfur. Thus, a limitation of 343 ppmv sulfur in a field gas supply will be in compliance. The permit requires the use of pipeline-grade natural gas or field gas with a maximum sulfur content of 343 ppmv for all fuel-burning equipment to ensure compliance with Subchapter 31. Initial compliance testing of the fuel sulfur content and further testing whenever the gas supplier or gas field is changed will be used to ensure compliance with this limitation.

OAC 252:100-37 (Volatile Organic Compounds) [Applicable] Part 3 requires storage tanks constructed after December 28, 1974, with a capacity of 400 gallons or more and storing a VOC with a vapor pressure greater than 1.5 psia to be equipped with a permanent submerged fill pipe or with an organic vapor recovery system. The methanol tank and condensate tanks are subject to this rule. Part 3 requires VOC loading facilities with a throughput equal to or less than 40,000 gallons per day to be equipped with a system for submerged filling of tank trucks or trailers if the capacity of the vehicle is greater than 200 gallons. This facility does not have the physical equipment (loading arm and pump) to conduct this type of loading and is not subject to this requirement. Part 5 limits the VOC content of coatings used in coating lines or operations. This facility does not normally conduct coating or painting operations except for routine maintenance of the facility and equipment, which is exempt. Part 7 requires fuel-burning equipment to be operated and maintained so as to minimize emissions. Temperature and available air must be sufficient to provide essentially complete combustion. Part 7 requires all effluent water separators openings or floating roofs to be sealed or equipped with an organic vapor recovery system. There are no effluent water separators located at this facility. Part 7 also requires all reciprocating pumps and compressors handling VOCs to be equipped with packing glands and rotating pumps and compressors handling VOCs to be equipped with mechanical seals. The equipment at this location is subject to this requirement.

OAC 252:100-41 (Hazardous Air Pollutants) [Applicable] Part 3 addresses hazardous air contaminants. NESHAP, as found in 40 CFR Part 61, are adopted by reference as they exist on September 1, 2004, with the exception of Subparts B, H, I, K, Q, R, T, W and Appendices D and E, all of which address radionuclides. In addition, General Provisions as found in 40 CFR Part 63, Subpart A, and the Maximum Achievable Control Technology (MACT) standards as found in 40 CFR Part 63, Subparts F, G, H, I, J, L, M, N, O, Q, R, S, T, U, W, X, Y, AA, BB, CC, DD, EE, GG, HH, II, JJ, KK, LL, MM, OO, PP, QQ, RR, SS, TT, UU, VV, WW, XX, YY, CCC, DDD, EEE, GGG, HHH, III, JJJ, LLL, MMM, NNN, OOO, PPP, QQQ, RRR, TTT, UUU, VVV, XXX, AAAA, CCCC, DDDD, EEEE, FFFF, GGGG, HHHH, IIII, JJJJ, KKKK, MMMM, NNNN, OOOO, PPPP, QQQQ, RRRR, SSSS, TTTT, UUUU, VVVV, WWWW, XXXX, YYYY, ZZZZ, AAAAA, BBBBB, CCCCC, EEEEE, FFFFF, GGGGG, HHHHH, IIIII, JJJJJ, KKKKK, LLLLL, MMMMM, NNNNN, PPPPP, QQQQQ, RRRRR, SSSSS and TTTTT are hereby adopted by reference as they exist on PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 12

September 1, 2004. These standards apply to both existing and new sources of HAPs. These requirements are covered in the “Federal Regulations” section. Part 5 is a state-only requirement governing toxic air contaminants. Part 5 regulates sources of toxic air contaminants that have emissions exceeding a de minimis level. However, Part 5 of Subchapter 41 has been superseded by OAC 252:100-42. The Air Quality Council approved Subchapter 42 for permanent rulemaking on April 20, 2005. The Environmental Quality Board approved Subchapter 42 as both a permanent and emergency rule on June 21, 2005. The emergency Subchapter 42 was sent for Gubernatorial signature on June 30, 2005, and became effective by emergency August 11, 2005. Subchapter 42 is expected to become permanently effective on June 15, 2006. Because Subchapter 41, Part 5 has been superseded, the requirements of Part 5 will not be reviewed in this memorandum. Should Subchapter 42 fail to take effect, this permit will be reopened to address the requirements of Subchapter 41, Part 5.

OAC 252:100-42 (Toxic Air Contaminants (TAC)) [Applicable] All parts of OAC 252:100-41, with the exception of Part 3, shall be superseded by this subchapter. Any work practice, material substitution, or control equipment required by the Department prior to June 11, 2004, to control a TAC, shall be retained, unless a modification is approved by the Director.

OAC 252:100-43 (Testing, Monitoring, and Recordkeeping) [Applicable] This subchapter provides general requirements for testing, monitoring and recordkeeping and applies to any testing, monitoring or recordkeeping activity conducted at any stationary source. To determine compliance with emissions limitations or standards, the Air Quality Director may require the owner or operator of any source in the state of Oklahoma to install, maintain and operate monitoring equipment or to conduct tests, including stack tests, of the air contaminant source. All required testing must be conducted by methods approved by the Air Quality Director and under the direction of qualified personnel. A notice-of-intent to test and a testing protocol shall be submitted to Air Quality at least 30 days prior to any EPA Reference Method stack tests. Emissions and other data required to demonstrate compliance with any federal or state emission limit or standard, or any requirement set forth in a valid permit shall be recorded, maintained, and submitted as required by this subchapter, an applicable rule, or permit requirement. Data from any required testing or monitoring not conducted in accordance with the provisions of this subchapter shall be considered invalid. Nothing shall preclude the use, including the exclusive use, of any credible evidence or information relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed.

The following Oklahoma Air Pollution Control Rules are not applicable to this facility: OAC 252:100-11 Alternative Emissions Reduction not requested OAC 252:100-15 Mobile Sources not in source category OAC 252:100-17 Incinerators not type of emission unit OAC 252:100-23 Cotton Gins not type of emission unit OAC 252:100-24 Grain Elevators not in source category PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 13

The following Oklahoma Air Pollution Control Rules are not applicable to this facility: OAC 252:100-33 Nitrogen Dioxides not in source category OAC 252-100-35 Carbon Monoxide not type of emission unit OAC 252:100-39 Nonattainment Areas not in area category OAC 252:100-47 Municipal Solid Waste Landfills not in source category

SECTION VII. FEDERAL REGULATIONS

PSD, 40 CFR Part 52 [Applicable] Total emissions of NOX and CO are greater than 250 TPY, the major source threshold level for PSD. Any future increases of emissions must be evaluated for PSD if they exceed a significance level (40 TPY NOX, 100 TPY CO, 40 TPY SO2, 40 TPY VOC, 25 TPY TSP, 15 TPY PM10).

NSPS, 40 CFR Part 60 [Subpart KKK is Applicable] Subpart K, Ka, Kb, VOL Storage Vessels. The three 8,820 gallon condensate tanks at the site are not subject because they are below the threshold level of Subpart Kb of 19,813-gallons and they store condensate prior to custody transfer as defined by Subpart Kb. All tanks were either constructed prior to promulgation of these standards or have capacities less than 19,813-gallons. Subpart GG, Stationary Gas Turbines. There are none at this facility. Subpart VV, Equipment Leaks of VOC in the Synthetic Organic Chemical Manufacturing Industry. The equipment is not in a SOCMI plant. Subpart KKK, Equipment Leaks of VOC from Onshore Natural Gas Processing Plants. This subpart applies to natural gas processing plants that commence construction, reconstruction, or modification after January 20, 1984, and include the following facilities located at onshore natural gas processing plants: a compressor station, dehydration unit, underground storage tank, field gas gathering system, or liquefied natural gas unit located at an on-shore natural gas processing plant. Although a portion of the facility (cryogenic processing area) was added during 1984, the construction contract was signed (by the previous owners) in September 1983, prior to the effective date of this subpart. Most of the plant is exempt from this subpart based on construction prior to January 24, 1984. The compressors attached to EUs P-ENG2, P-ENG5, P- ENG11, and P-ENG15 were recently replaced and the new compressors are subject to the requirements of this subpart. All three units are in residue or wet gas service and are subject to the record keeping requirements of §§ 60.486(j) and 60.635(c). Paragraphs 60.486(j) and 60.635(c) requires information and data that demonstrates that these units are not in VOC service or that they are in wet gas service to be recorded in a log that is kept in a readily accessible location. This information is kept on-site in a log at the facility. The mole sieve process unit is subject to the monitoring requirements of this subpart. Subpart LLL, Onshore Natural Gas Processing: SO2 Emissions. This subpart affects natural gas sweetening units. No natural gas sweetening operation is located at this site. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 14

NESHAP, 40 CFR Part 61 [Not Applicable] There are no emissions of any of the regulated pollutants: arsenic, asbestos, beryllium, benzene, coke oven emissions, mercury, radionuclides or vinyl chloride except for trace amounts of benzene. Subpart J, Equipment Leaks of Benzene, only affects process streams that contain more than 10% benzene by weight. All process streams at this facility are below this threshold.

NESHAP, 40 CFR Part 63 [Not Applicable] Subpart HH, Oil and Natural Gas Production. This subpart affects major sources of HAPs that process, upgrade, or store natural gas prior to the point at which it enters the natural gas transmission and storage source category or is delivered to a final end user. This facility processes, upgrades, and stores natural gas prior to being delivered to a final end user and is considered to be an oil and natural gas production facility. Based on the ratings of the engines and the current emission factors from AP-42, this facility is not a major source of HAPs.

Subpart ZZZZ, Reciprocating Internal Combustion Engines (RICE). This subpart was promulgated on June 15, 2004. This subpart affects RICE with a site-rating greater than 500 brake horsepower and which are located at a major source of HAP emissions. The subpart establishes emission and operating limitations for each affected source. Based on emission calculations, this facility is not a major source of HAPs and is not subject to this subpart.

Compliance Assurance Monitoring, 40 CFR Part 64 [Applicable] Compliance Assurance Monitoring, as published in the Federal Register on October 22, 1997, applies to any pollutant specific emission unit at a major source, that is required to obtain a Title V permit, if it meets all of the following criteria:

 It is subject to an emission limit or standard for an applicable regulated air pollutant  It uses a control device to achieve compliance with the applicable emission limit or standard  It has potential emissions, prior to the control device, of the applicable regulated air pollutant greater than major source levels.

All of the engines except P-ENG8 use a control device to achieve compliance with their applicable emission limits. Out of these engines, only the 1,100-hp Waukesha L7042 GSI and Waukesha P9390G engines have the potential to emit (pre-control device) 100 TPY of NOX and/or CO. Since, these units do not have the potential to emit (taking into account control devices) 100 TPY of NOX and CO, the facility submitted the information required under § 64.4 for NOX and CO with their application to renew the initial Title V operating permit. All applicable requirements were incorporated into the permit.

The CAM plan submitted for the engines with catalytic converters required measurement of the temperature of the exhaust gases into the catalyst bed and pressure differential across the catalyst bed and an inspection and preventative maintenance plan. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 15

Chemical Accident Prevention Provisions, 40 CFR Part 68 [Applicable] This facility handles naturally occurring hydrocarbon mixtures at a natural gas processing plant and the Chemical Accident Prevention Provisions are applicable to this facility. The facility was required to submit the appropriate accidental release emergency response program plan prior to June 21, 1999. A plan was submitted to EPA for this facility. More information on this federal program is available on the web page: www.epa.gov/ceppo.

Stratospheric Ozone Protection, 40 CFR Part 82 [Subparts A and F are Applicable] These standards require phase out of Class I & II substances, reductions of emissions of Class I & II substances to the lowest achievable level in all use sectors, and banning use of nonessential products containing ozone-depleting substances (Subparts A & C); control servicing of motor vehicle air conditioners (Subpart B); require Federal agencies to adopt procurement regulations which meet phase out requirements and which maximize the substitution of safe alternatives to Class I and Class II substances (Subpart D); require warning labels on products made with or containing Class I or II substances (Subpart E); maximize the use of recycling and recovery upon disposal (Subpart F); require producers to identify substitutes for ozone-depleting compounds under the Significant New Alternatives Program (Subpart G); and reduce the emissions of halons (Subpart H). Subpart A identifies ozone-depleting substances and divides them into two classes. Class I controlled substances are divided into seven groups; the chemicals typically used by the manufacturing industry include carbon tetrachloride (Class I, Group IV) and methyl chloroform (Class I, Group V). A complete phase-out of production of Class I substances is required by January 1, 2000 (January 1, 2002, for methyl chloroform). Class II chemicals, which are hydrochlorofluorocarbons (HCFCs), are generally seen as interim substitutes for Class I CFCs. Class II substances consist of 33 HCFCs. A complete phase-out of Class II substances, scheduled in phases starting by 2002, is required by January 1, 2030. Subpart F requires that any persons servicing, maintaining, or repairing appliances except for motor vehicle air conditioners; persons disposing of appliances, including motor vehicle air conditioners; refrigerant reclaimers, appliance owners, and manufacturers of appliances and recycling and recovery equipment comply with the standards for recycling and emissions reduction.

The standard conditions of the permit address the requirements specified at §82.156 for persons opening appliances for maintenance, service, repair, or disposal; §82.158 for equipment used during the maintenance, service, repair, or disposal of appliances; §82.161 for certification by an approved technician certification program of persons performing maintenance, service, repair, or disposal of appliances; §82.166 for recordkeeping; § 82.158 for leak repair requirements; and §82.166 for refrigerant purchase records for appliances normally containing 50 or more pounds of refrigerant. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 16

SECTION VIII. COMPLIANCE

Inspection A full compliance evaluation was conducted on June 4, 2004. Camas Frey of Air Quality conducted the inspection. No violations were identified during the inspection. A partial compliance evaluation was conducted on April 25, 2005. Kyle Jantzen of Air Quality conducted the inspection. No violations were identified during the inspection.

Testing The most recent testing is shown below was submitted showing compliance with the applicable emission limits.

Permit Limits Test Results

NOX CO NOX CO EU Source lb/hr lb/hr lb/hr lb/hr Quarter 1/P-ENG2 White 8G825 W/CC 5.29 3.53 0.54 0.93 4/2005 1/P-ENG3 Waukesha L7042 GSI W/CC 7.28 7.28 0.54 0.99 1/2006 1/P-ENG5 White 6G825 W/CC 3.97 2.65 1.35 1.65 3/2003 1/P-ENG6 White 8G825 W/CC 5.29 3.53 0.58 0.58 1/2006 1/P-ENG7 White 8G825 W/CC 5.29 5.29 0.96 0.99 1/2006 1/P-ENG8 Clark RA-8 39.33 8.82 4.48 1.20 1/2006 1/P-ENG9 White 8G825 W/CC 5.29 3.53 0.74 0.73 1/2006 1/P-ENG10 Caterpillar 399TA W/CC 5.49 5.49 1.59 2.94 4/2005 1/P-ENG11 White 6G825 W/CC 3.97 3.97 1.33 1.77 3/2005 1/P-ENG15 Waukesha P9390G W/CC 7.90 7.90 0.29 0.45 1/2006 W/CC – With Catalytic Converter

Tier Classification and Public Review This application has been determined to be Tier II based on the request for renewal of a Part 70 operating permit. The permittee has submitted an affidavit that they are not seeking a permit for land use or for any operation upon land owned by others without their knowledge. The affidavit certifies that the application only involves land owned by the applicant or the applicant business.

The applicant published the “Notice of Filing a Tier II Application” in the Lincoln County News a weekly newspaper, in Lincoln County, on February 9, 2006. The notice stated that the application could be reviewed at the Chandler Public Library, 1021 Manvel Ave., Chandler, Oklahoma or at the AQD main office in Oklahoma City. The applicant will publish the “Notice of Tier II Draft Permit” in a daily newspaper, in Stephens County. The draft permit will be made available for public review for a period of 30 days. The draft permit will also be available for public review on the Air Quality section of the DEQ web page at http://www.deq.state.ok.us. This facility is not located within 50 miles of the border of Oklahoma and any other state. After public review the draft permit will be forwarded to EPA Region VI for a 45-day review period. PERMIT MEMORANDUM 2006-051-TVR DRAFT Page 17

Fees Paid A Part 70 operating permit renewal application fee of $1,000.

SECTION IX. SUMMARY

The facility is operating as stated in the application. Ambient air quality standards are not threatened at this site. There are no active Air Quality compliance or enforcement issues concerning this facility. Issuance of the renewal operating permit is recommended, contingent on public and EPA review. DRAFT

PERMIT TO OPERATE AIR POLLUTION CONTROL FACILITY SPECIFIC CONDITIONS

Duke Energy Field Services, L.L.C. Permit Number 2006-051-TVR Carney Gas Processing Plant

The permittee is authorized to operate in conformity with the specifications submitted to Air Quality on January 23, 2006 and all supplemental information. The Evaluation Memorandum dated April 26, 2006, explains the derivation of applicable permit requirements and estimates of emissions; however, it does not contain operating limitations or permit requirements. Continuing operations under this permit constitutes acceptance of, and consent to, the conditions contained herein:

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

EUG 1 & 2 Internal Combustion Engines: Emission limitations for Emission Units (EUs): P-ENG2, P-ENG3, C P-ENG5, P-ENG6, P-ENG7, P-ENG8, P-ENG9, P-ENG10, P-ENG11, and P-ENG15.

Emission Unit Units NOX CO VOC P-ENG2 800-hp Superior 8G825 lb/hr 5.29 3.53 0.88 w/Catalytic Converter TPY 23.18 15.45 3.86

P-ENG3 1,100-hp Waukesha lb/hr 7.28 7.28 1.21 L7042 GSI TPY 31.87 31.87 5.31

P-ENG5 600-hp Superior 6G825 lb/hr 3.97 2.65 0.66 w/Catalytic Converter TPY 17.38 11.59 2.90

P-ENG8 800-hp Clark RA-8 lb/hr 39.33 8.82 3.53 TPY 172.27 38.63 15.45

P-ENG9 800-hp Superior 8G825 lb/hr 5.29 3.53 0.88 w/Catalytic Converter TPY 23.18 15.45 3.86 SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 2

Emission Unit Units NOX CO VOC P-ENG10 830-hp Caterpillar lb/hr 5.49 5.49 0.91 G399TA TPY 24.04 24.04 4.01

P-ENG15 1,192-hp Waukesha lb/hr 7.90 7.90 1.32 P9390G TPY 34.59 34.59 5.77 w/Catalytic Converter

a. EUs P-ENG2, P-ENG3, C P-ENG5, P-ENG6, P-ENG7, P-ENG9, P-ENG10, P-ENG11, and P-ENG15 shall be set to operate with their exhaust gases passing through functioning catalytic converters. [OAC 252:100-8-6(a)]

EUGs 3 & 4 Tanks: Storage tank VOC emissions are estimated based on existing equipment items but do not have a specific limitation.

Vapor EUG EU Point Contents Gallons Pressure (psia) 3 EU-3 P-T17 Methanol 1,000 1.6 * * P-T18 Antifreeze 4,700 0.01 3 EU-3 P-T19 Condensate 8,820 3-8 3 EU-3 P-T20 Condensate 8,820 3-8 3 EU-3 P-T30 Condensate 8,820 3-8 3 EU-3 P-T31 Methanol 8,820 1.6 3 EU-3 P-T32 Slop Water 8,820 <0.5 4 EU-4 P-T21 Mixed Gas Liquids 30,000 350 (Pressurized) 4 EU-4 P-T24 Condensate (Pressurized) 40,000 25 4 EU-4 P-T25 Condensate (Pressurized) 28,000 50 4 EU-4 P-T26 Condensate (Pressurized) 28,000 150 4 EU-4 P-T27 Propane (Pressurized) 16,000 100 * * P-T28 Lube Oil 5,000 0.01 * * P-T29 Lube Oil 6,500 0.01 * These tanks are not assigned to EUGs, because there are no emissions associated with these units. These tanks are included here only for the sake of completeness.

In addition to the tanks listed above, the facility has a water storage tank, a slop water tank, a 250-gallon triethylene glycol tank, a 1,000-gallon kerosene tank, and a 500-gallon diesel tank. There are also some tanks stored at the site, but which are not in service. SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 3

EUG 5 Condensate Truck Loading: Condensate truck loading emissions are estimated based on existing equipment items but do not have a specific limitation.

EU Type of Equipment 1 Loading Operations

EUG 6 Dehydration Unit’s Reboiler and Still Vent W/Condenser: Emissions from the glycol dehydration unit’s reboiler are considered insignificant and do not have specific emission limits but it is limited to the existing equipment as it is. Emissions from the glycol dehydration unit’s still vent w/condenser are estimated based on existing equipment items, a extended gas analyses, and the dehydration units throughput (24 MMSCF/day). Emission limits have been established based on this information and are shown in the table below.

EU Type of Equipment Rated Heat Input 1 Reboiler 0.5 MMBTUH

Emission Limitations VOC Source lb/hr TPY Glycol Dehydration Unit Still Vent 1.51 6.61

a. The glycol dehydration unit shall be equipped with a flash tank and a condenser. Emissions from the flash tank shall be routed to the glycol dehydration unit’s reboiler firebox. Emissions from the glycol dehydration unit’s still vent shall be routed through the condenser or an equally effective control device (VOC control efficiency of at least 84%) prior to being emitted to the atmosphere. b. The natural gas throughput of the glycol dehydration unit shall not exceed 24 MMSCFD (annual average). c. The lean glycol recirculation rate of the glycol dehydration unit shall not exceed 3.5 gallons per minute. d. The outlet temperature of the glycol dehydration unit’s still vent condenser shall not exceed 120 ºF (annual average). e. The condenser shall be equipped with a properly functioning thermometer to measure the outlet temperature of the condenser. f. The permittee shall monitor and record the outlet temperature of the condenser at least monthly during daylight hours. With each inspection the outlet temperature shall be recorded as follows:

Date of inspection ______Discharge temperature ______Inspected by ______SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 4

EUG 7 Fugitives Emissions: Fugitive VOC emissions are estimated based on existing equipment items but do not have a specific limitation.

EU Type of Equipment 1 Valves, flanges, and miscellaneous

2. The fuel-burning equipment shall use pipeline-grade natural gas or field gas with a maximum sulfur content of 343 ppmv. [OAC 252:100-31]

3. The permittee shall be authorized to operate this facility continuously (24 hours per day, every day of the year). [OAC 252:100-8-6(a)]

4. Each engine/turbine at the facility shall have a permanent identification plate attached which shows the make, model number, and serial number. [OAC 252:100-45]

5. The permittee shall keep operation and maintenance (O&M) records for those engines/turbines which do not conduct quarterly testing. Such records shall at a minimum include the dates of operation, and maintenance, type of work performed, and the increase, if any, in emissions as a result. [OAC 252:100-8-6 (a)(3)(B)]

6. At least once per calendar quarter, the permittee shall conduct tests of NOX and CO emissions in exhaust gases from each engine and each replacement engine when operating under representative conditions for that period. Testing is required for each engine and replacement engine if it runs for more than 220 hours during a calendar quarter. Engines shall be tested no sooner than 20 days after the last test. Testing shall be conducted using a portable analyzer in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. When four consecutive quarterly tests show an engine/turbine to be in compliance with the emissions limitations shown in the permit, then the testing frequency may be reduced to semi-annual testing. Likewise, when the following two consecutive semi-annual tests show compliance, the testing frequency may be reduced to annual testing. Upon any showing of non-compliance with emissions limitations or testing that indicates that emissions are within 10% of the emission limitations, the testing frequency shall revert to quarterly. Any reduction in the testing frequency shall be noted in the next required compliance certification. Reduced testing does not apply to engines with catalytic converters. [OAC 252:100-8-6 (a)(3)(A)]

7. When periodic compliance testing shows engine exhaust emissions in excess of the lb/hr limits, the permittee shall comply with the provisions of OAC 252:100-9 for excess emissions during start-up, shut-down, and malfunction of air pollution control equipment. Requirements of OAC 252:100-9 include immediate notification and written notification of Air Quality and demonstrations that the excess emissions meet the criteria specified in OAC 252:100-9. [OAC 252:100-9] SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 5

8. Replacement (including temporary periods of 6 months or less for maintenance purposes), of the internal combustion engines with emissions specified in this permit with engines/turbines of lesser or equal emissions of each pollutant (in lbs/hr and TPY) is authorized under the following conditions. [OAC 252:100-8-6(f)(2)]

a. The permittee shall notify AQD in writing no later than 7 days in advance of the start- up of the replacement engine(s)/turbine(s). Said notice shall identify the old engine/turbine and shall include the new engine/turbine make and model, horsepower rating, fuel usage, stack flow (ACFM), stack temperature (F), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr, lb/hr, and TPY) at maximum horsepower for the altitude/location. b. Quarterly emissions tests for the replacement engine(s)/turbine(s) shall be conducted to confirm continued compliance with NOx and CO emissions limitations. A copy of the first quarter testing shall be provided to AQD within 60 days of start-up of each replacement engine/turbine. The test report shall include the engine/turbine fuel usage, stack flow (ACFM), stack temperature (oF), stack height (feet), stack diameter (inches), and pollutant emission rates (g/hp-hr, lbs/hr, and TPY) at maximum rated horsepower for the altitude/location. c. Replacement equipment and emissions are limited to equipment and emissions that are not subject to NSPS, NESHAP, or PSD.

9. The permittee shall maintain records of operations as listed below. These records shall be maintained on-site or at a local field office for at least five years after the date of recording and shall be provided to regulatory personnel upon request. [OAC 252:100-43]

a. Operating hours for each engine if operated less than 220 hours per quarter and not tested. b. Periodic testing for each engine or hours of operation. c. Analysis of current fuel gas sulfur content (updated whenever the supply changes). d. Amount of gas processed by the glycol dehydration unit (monthly). e. O&M records for any engine not tested in each 6 month period. f. Records required by NSPS, Subpart KKK. g. Glycol dehydration unit’s condenser outlet temperature (monthly).

10. The following records shall be maintained on-site to verify Insignificant Activities. No recordkeeping is required for those operations, which qualify as Trivial Activities. [OAC 252:100-8-6 (a)(3)(B)]

a. For fluid storage tanks with a capacity of less than 39,894 gallons and a true vapor pressure less than 1.5 psia: Records of the capacity of the tanks and contents. b. For surface coating and degreasing operations which do not exceed a combined total usage of more than 60 gallons/month: The amount of coatings, thinners, clean-up solvents, and degreasing solvents used. SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 6

c. For activities that have the potential to emit less than 5 TPY (actual) of any criteria pollutant: The type of activity and the amount of emissions from that activity (annual).

11. The permittee shall comply with the Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants, NSPS Subpart KKK, for each compressor attached to EUs P-ENG2, P-ENG5, P-ENG11, and P-ENG15. [40 CFR 60.630 to 60.636]

a. Information and data used to demonstrate that a reciprocating compressor is not in VOC service shall be recorded in a log that is kept in a readily accessible location as per § 60.486(j). b. Information and data used to demonstrate that a compressor is in wet gas service shall be recorded in a log that is kept in a readily accessible location.

12. The permittee shall comply with the Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants NSPS Subpart KKK, for each affected facility in the Mole-Sieve process. [40 CFR 60.630 to 60.636]

a. The owner/operator shall comply with the requirements of §§ 60.482-1(a), (b), and (d) and § 60.482-2 through § 60.482-10 except as provided in § 60.333 [§ 60.632(a)]

(1) The owner/operator shall demonstrate compliance with §§ 60.482-1 to 60.482- 10 for all affected equipment within 180 days of initial startup which shall be determined by review of records, reports, performance test results, and inspection using methods and procedures specified in § 60.485 unless the equipment is in vacuum service and is identified as required by § 60.486(e)(5). [§ 60.482-1(a), (b), & (d)] (2) The owner/operator shall comply with the monitoring, inspection, and repair requirements, for pumps in light liquid service, of §§ 60.482-2(a), (b), and (c) except as provided in §§ 60-482-2(d), (e), and (f). (3) Each compressor shall be equipped with a seal system that includes a barrier fluid system and that prevents leakage of VOC to the atmosphere, except as provided in § 60.632(c), § 60.633(f), § 60.482-1(c), § 60.482-3(h), and § 60.482-3(i). [§ 60.482-3(a)] i) Each compressor seal system shall comply with the requirements of §§ 60.482-3(b). ii) Each barrier fluid system shall be equipped with a sensor as required by § 60.482-3(d) that is monitored or equipped with an alarm as required by § 60.482-3(e) and repaired as required by §§ 60.482-3(f) and (g). SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 7

(4) Any existing reciprocating compressor in a process unit which becomes an affected facility under provisions of § 60.14 or § 60.15 is exempt from §§ 60.482(a), (b), (c), (d), (e), and (h) , provided the owner or operator demonstrates that recasting the distance piece or replacing the compressor are the only options available to bring the compressor into compliance with the provisions of §§ 60.482-3(a) through (e) and (h). [§ 60.482-3(j)] (5) The owner/operator shall comply with the operation and monitoring requirements, for pressure relief devices in gas/vapor service, of §§ 60.482-4(a) and (b) except as provided in § 60-482-4(c) and § 60.633(b). (6) Sampling and connection systems are exempt from the requirements of § 60.482-5. [§ 60.633(c)] (7) Each open-ended valve or line shall be equipped with a cap, blind flange, plug, or a second valve, except as provided in § 60.632(c). The cap, blind flange, plug, or second valve shall seal the open end at all times except during operations requiring process fluid flow through the open-ended valve or line. Each open-ended valve or line equipped with a second valve shall be operated in a manner such that the valve on the process fluid end is closed before the second valve is closed. When a double block-and-bleed system is being used, the bleed valve or line may remain open during operations that require venting the line between the block valves but shall be closed at all other times. [§ 60.482-6] (8) The owner/operator shall comply with the monitoring, inspection, and repair requirements, for valves in gas/vapor service and light liquid service, of §§ 60.482-7(b) through (e), except as provided in §§ 60.633(d), 60.482-7(f), (g), and (h), §§ 60.483-1, 60.483-2, and 60.482-1(c). [§ 60.482-7(a)] (9) The owner/operator shall comply with the monitoring and repair requirements, for pumps and valves in heavy liquid service, pressure relief devices in light liquid or heavy liquid service, and flanges and other connectors, of §§ 60.482- 8(a) through (d). [§ 60.482-8] (10) Delay of repair of equipment is allowed if it meets one of the requirements of §§ 60.482-9(a) through (e). (11) The owner/operators using a closed vent system and control device to comply with these provisions shall comply with the design, operation, monitoring and other requirements of 60.482-10(b) through (g). [§ 60.482-10(a)] b. An owner/operator may elect to comply with the alternative requirements for valves of §§ 60.483-1 and 60.483-2. [§ 60.632(b) & § 60.482-1(b)] c. An owner/operator may apply to the Administrator for permission to use an alternative means of emission limitation that achieves a reduction in emissions of VOC at least equivalent to that achieved by the controls required in NSPS Subpart KKK. In doing so, the owner or operator shall comply with requirements of § 60.634. [§ 60.632(c)] d. Each owner/operator subject to the provisions of NSPS Subpart KKK shall comply with the test method and procedures of § 60.485 except as provided in §§ 60.632(f) and 60.633(h). [§ 60.632(d)] SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 8

e. Each owner/operator subject to the provisions of NSPS Subpart KKK shall comply with the recordkeeping requirements of § 60.486 and the reporting requirements of § 60.487 except as provided in §§ 60.633, 60.635, and 60.636. [§ 60.632(e)] f. Each owner/operator subject to the provisions of NSPS Subpart KKK shall comply with the recordkeeping requirements of §§ 60.635(b) and (c) in addition to the requirements of § 60.486. [§ 60.635(a)] g. Each owner/operator subject to the provisions of NSPS Subpart KKK shall comply with the and the reporting requirements of §§ 60.636(b) and (c) in addition to the requirements of § 60.487. [§ 60.636(a)]

13. No later than 30 days after each anniversary date of the issuance of the original Title V operating permit (July 23, 2001), the permittee shall submit to Air Quality Division of DEQ, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit. The following specific information is required to be included: [OAC 252:100-8-6 (c)(5)(A) & (D)]

a. Testing results for each engine/turbine (quarterly or other applicable period). b. Operating hours of engines/turbines, which operated less than 220 hours and were not tested in a quarter. c. Natural gas throughput of the glycol dehydration unit (MMSCFD – annual average).

14. The Permit Shield (Standard Conditions, Section VI) is extended to the following requirements that have been determined to be inapplicable to this facility: [OAC 252:100-8-6(d)(2)]

a. 40 CFR Part 60, NSPS, Subpart K b. 40 CFR Part 60, NSPS, Subpart Ka c. 40 CFR Part 60, NSPS, Subpart Kb d. OAC 252:100-33, Nitrogen Oxides e. OAC 252:100-35, Carbon Monoxide

15. EU P-ENG3 and P-ENG-15 are subject to Compliance Assurance Monitoring (CAM) and shall comply with all applicable requirements and shall perform monitoring as approved in Table 1, Appendix A of this permit. The permittee shall have 18 months from the date of issuance of Permit No. 2006-051-TVR to comply with the requirements of the CAM plan. [40 CFR Part 64]

a.The owner/operator shall comply with the Operation of Approved Monitoring requirements of § 64.7(a) through (e). b. A quality improvement plan (QIP) shall be developed and implemented for these EU if there are six excursions, within a six month period, from the established ranges in Appendix A. Excursions do not include periods of startup or shutdown. The QIP shall comply with the requirements of § 64.8(b) through (e). [§ 64.8(a)] c.The owner/operator shall comply with the Recordkeeping and Reporting requirements of § 64.9(a) through (c). SPECIFIC CONDITIONS 2003-294-TVR (M-1) Page 9

16. This permit supercedes all other Air Quality permits, which are now null and void. APPENDIX A, PERMIT 2006-051-TVR Page 1

TABLE 1. DUKE ENERGY FIELD SERVICES COMPANY COMPLIANCE ASSURANCE MONITORING FOR THE P-ENG3 and P-ENG15 ENGINES WITH CATALYTIC CONVERTERS Indicator No. 1 Indicator No 2 Indicator No. 3 Indicator No. 4

I. Indicator Temperature of exhaust gas into Pressure differential (decrease) of Oxygen (O2) from the Inspection & Preventative catalyst exhaust gas (press. in - press. out engine. Maintenance (I/PM). across catalyst)

Measurement Exhaust gas temperature shall be Pressure differential shall be O2 concentration into the Monthly inspection Approach measured continuously using an measured monthly using a catalyst shall be measured according to PM plan; inline thermocouple and differential pressure gauge. continuously using an in-line maintenance performed as translated by a temp. scanner or O2 sensor. needed. other end device. II. Indicator Range The indicator range is above The indicator range is a pressure The indicator range shall be Not Applicable

700ºF, but lower than 1,250ºF. drop deviation of less than 4 inches O2 <0.5%. Excursions are Excursions shall trigger H2O from the established events lasting 30 minutes or corrective action, logging, and benchmark for a specific load. longer. Excursions shall reporting in semiannual report. Excursions trigger corrective action, trigger corrective action, logging and reporting in semiannual logging, and reporting in report. semiannual report. III. Performance Criteria Temperature shall be measured Pressure drop across the catalyst Observations shall be Inspections are performed on A. Data at the inlet to the catalyst by a shall be measured at the inlet and performed at the engine the engine, AFR, and the Representativenes thermo couple with a minimum outlet of the catalyst with a exhaust while the engine is catalyst. Monthly PM s accuracy of +/-5ºF. minimum accuracy of +/-0.25 operating. inspections verify operating

inches H2O. characteristics of the system.

B. Verification of Thermocouple scanner or other The pressure gauge shall be O2 sensor replaced quarterly. After 3,000 hours, the AFR Operational Status end device shall be visually calibrated quarterly. Pressure taps system shall be tested for QA/QC Practices checked quarterly and tested shall be checked monthly for operability and the AFR set annually. plugging. points are verified.

C. Monitoring Temperature shall be measured Initial benchmark monitoring shall be O2 percent shall be Monthly inspection in Frequency continuously. Compliance performed no later than 180 days monitored continuously. accordance with PM plan. assumed daily if no corrective after issuance of the TV renewal action events occur. permit. Initial monitoring shall be used to establish the benchmark pressure differentials at various loads. The data shall be recorded and compared to measured monthly values. Compliance is assumed monthly if no corrective action events occur. APPENDIX A, PERMIT 2006-051-TVR Page 2

Indicator No. 1 Indicator No 2 Indicator No. 3 Indicator No. 4

D. Data Collection Temperature data shall be Pressure data shall be recorded on O2 is measured whenever an Records are maintained to Procedures recorded on a strip chart or other log sheets once a month. O2 sensor is replaced. document the monthly recording device continuously. Excursions require logging and Excursions require logging inspections and any required Excursions require logging and reporting in semiannual report. and reporting in semiannual maintenance. reporting in semiannual report. report. E. Averaging period None, not to exceed minimums None, not to exceed minimums and N/A NA and maximums. maximums. TITLE V (PART 70) PERMIT TO OPERATE / CONSTRUCT STANDARD CONDITIONS (July 1, 2005)

SECTION I. DUTY TO COMPLY

A. This is a permit to operate / construct this specific facility in accordance with Title V of the federal Clean Air Act (42 U.S.C. 7401, et seq.) and under the authority of the Oklahoma Clean Air Act and the rules promulgated there under. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112]

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

C. The permittee shall comply with all conditions of this permit. Any permit noncompliance shall constitute a violation of the Oklahoma Clean Air Act and shall be grounds for enforcement action, for revocation of the approval to operate under the terms of this permit, or for denial of an application to renew this permit. All terms and conditions (excluding state-only requirements) are enforceable by the DEQ, by EPA, and by citizens under section 304 of the Clean Air Act. This permit is valid for operations only at the specific location listed. [40 CFR §70.6(b), OAC 252:100-8-1.3 and 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. [OAC 252:100-8-6 (a)(7)(B)]

SECTION II. REPORTING OF DEVIATIONS FROM PERMIT TERMS

A. Any exceedance resulting from emergency conditions and/or posing an imminent and substantial danger to public health, safety, or the environment shall be reported in accordance with Section XIV. [OAC 252:100-8-6 (a)(3)(C)(iii)]

B. Deviations that result in emissions exceeding those allowed in this permit shall be reported consistent with the requirements of OAC 252:100-9, Excess Emission Reporting Requirements. [OAC 252:100-8-6 (a)(3)(C)(iv)]

C. Oral notifications (fax is also acceptable) shall be made to the AQD central office as soon as the owner or operator of the facility has knowledge of such emissions but no later than 4:30 p.m. the next working day the permittee becomes aware of the exceedance. Within ten (10) working days after the immediate notice is given, the owner operator shall submit a written report describing the extent of the excess emissions and response actions taken by the facility. Every written report submitted under OAC 252:100-8-6 (a)(3)(C)(iii) shall be certified by a responsible official. [OAC 252:100-8-6 (a)(3)(C)(iii)] TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 2

SECTION III. MONITORING, TESTING, RECORDKEEPING & REPORTING

A. The permittee shall keep records as specified in this permit. Unless a different retention period or retention conditions are set forth by a specific term in this permit, these records, including monitoring data and necessary support information, shall be retained on-site or at a nearby field office for a period of at least five years from the date of the monitoring sample, measurement, report, or application, and shall be made available for inspection by regulatory personnel upon request. Support information includes all original strip-chart recordings for continuous monitoring instrumentation, and copies of all reports required by this permit. Where appropriate, the permit may specify that records may be maintained in computerized form. [OAC 252:100-8-6 (a)(3)(B)(ii), 8-6 (c)(1), and 8-6 (c)(2)(B)]

B. Records of required monitoring shall include: (1) the date, place and time of sampling or measurement; (2) the date or dates analyses were performed; (3) the company or entity which performed the analyses; (4) the analytical techniques or methods used; (5) the results of such analyses; and (6) the operating conditions as existing at the time of sampling or measurement. [OAC 252:100-8-6 (a)(3)(B)(i)]

C. No later than 30 days after each six (6) month period, after the date of the issuance of the original Part 70 operating permit, the permittee shall submit to AQD a report of the results of any required monitoring. All instances of deviations from permit requirements since the previous report shall be clearly identified in the report. [OAC 252:100-8-6 (a)(3)(C)(i) and (ii)]

D. If any testing shows emissions in excess of limitations specified in this permit, the owner or operator shall comply with the provisions of Section II of these standard conditions. [OAC 252:100-8-6 (a)(3)(C)(iii)]

E. In addition to any monitoring, recordkeeping or reporting requirement specified in this permit, monitoring and reporting may be required under the provisions of OAC 252:100-43, Testing, Monitoring, and Recordkeeping, or as required by any provision of the Federal Clean Air Act or Oklahoma Clean Air Act.

F. Submission of quarterly or semi-annual reports required by any applicable requirement that are duplicative of the reporting required in the previous paragraph will satisfy the reporting requirements of the previous paragraph if noted on the submitted report.

G. Every report submitted under OAC 252:100-8-6 and OAC 252:100-43 shall be certified by a responsible official. [OAC 252:100-8-6 (a)(3)(C)(iv)]

H. Any owner or operator subject to the provisions of NSPS shall maintain records of the occurrence and duration of any start-up, shutdown, or malfunction in the operation of an affected facility or any malfunction of the air pollution control equipment. [40 CFR 60.7 (b)] TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 3

I. Any owner or operator subject to the provisions of NSPS shall maintain a file of all measurements and other information required by the subpart recorded in a permanent file suitable for inspection. This file shall be retained for at least two years following the date of such measurements, maintenance, and records. [40 CFR 60.7 (d)]

J. The permittee of a facility that is operating subject to a schedule of compliance shall submit to the DEQ a progress report at least semi-annually. The progress reports shall contain dates for achieving the activities, milestones or compliance required in the schedule of compliance and the dates when such activities, milestones or compliance was achieved. The progress reports shall also contain an explanation of why any dates in the schedule of compliance were not or will not be met, and any preventative or corrective measures adopted. [OAC 252:100-8-6 (c)(4)]

K. All testing must be conducted by methods approved by the Division Director under the direction of qualified personnel. All tests shall be made and the results calculated in accordance with standard test procedures. The use of alternative test procedures must be approved by EPA. When a portable analyzer is used to measure emissions it shall be setup, calibrated, and operated in accordance with the manufacturer’s instructions and in accordance with a protocol meeting the requirements of the “AQD Portable Analyzer Guidance” document or an equivalent method approved by Air Quality. [40 CFR §70.6(a), 40 CFR §51.212(c)(2), 40 CFR § 70.7(d), 40 CFR §70.7(e)(2), OAC 252:100-8-6 (a)(3)(A)(iv), and OAC 252:100-43]

L. The permittee shall submit to the AQD a copy of all reports submitted to the EPA as required by 40 CFR Part 60, 61, and 63, for all equipment constructed or operated under this permit subject to such standards. [OAC 252:100-4-5 and OAC 252:100-41-15]

SECTION IV. COMPLIANCE CERTIFICATIONS

A. No later than 30 days after each anniversary date of the issuance of the original Part 70 operating permit, the permittee shall submit to the AQD, with a copy to the US EPA, Region 6, a certification of compliance with the terms and conditions of this permit and of any other applicable requirements which have become effective since the issuance of this permit. The compliance certification shall also include such other facts as the permitting authority may require to determine the compliance status of the source. [OAC 252:100-8-6 (c)(5)(A), (C)(v), and (D)]

B. The certification shall describe the operating permit term or condition that is the basis of the certification; the current compliance status; whether compliance was continuous or intermittent; the methods used for determining compliance, currently and over the reporting period; and a statement that the facility will continue to comply with all applicable requirements. [OAC 252:100-8-6 (c)(5)(C)(i)-(iv)]

C. Any document required to be submitted in accordance with this permit shall be certified as being true, accurate, and complete by a responsible official. This certification shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the certification are true, accurate, and complete. [OAC 252:100-8-5 (f) and OAC 252:100-8-6 (c)(1)] TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 4

D. Any facility reporting noncompliance shall submit a schedule of compliance for emissions units or stationary sources that are not in compliance with all applicable requirements. This schedule shall include a schedule of remedial measures, including an enforceable sequence of actions with milestones, leading to compliance with any applicable requirements for which the emissions unit or stationary source is in noncompliance. This compliance schedule shall resemble and be at least as stringent as that contained in any judicial consent decree or administrative order to which the emissions unit or stationary source is subject. Any such schedule of compliance shall be supplemental to, and shall not sanction noncompliance with, the applicable requirements on which it is based, except that a compliance plan shall not be required for any noncompliance condition which is corrected within 24 hours of discovery. [OAC 252:100-8-5 (e)(8)(B) and OAC 252:100-8-6 (c)(3)]

SECTION V. REQUIREMENTS THAT BECOME APPLICABLE DURING THE PERMIT TERM

The permittee shall comply with any additional requirements that become effective during the permit term and that are applicable to the facility. Compliance with all new requirements shall be certified in the next annual certification. [OAC 252:100-8-6 (c)(6)]

SECTION VI. PERMIT SHIELD

A. Compliance with the terms and conditions of this permit (including terms and conditions established for alternate operating scenarios, emissions trading, and emissions averaging, but excluding terms and conditions for which the permit shield is expressly prohibited under OAC 252:100-8) shall be deemed compliance with the applicable requirements identified and included in this permit. [OAC 252:100-8-6 (d)(1)]

B. Those requirements that are applicable are listed in the Standard Conditions and the Specific Conditions of this permit. Those requirements that the applicant requested be determined as not applicable are summarized in the Specific Conditions of this permit. [OAC 252:100-8-6 (d)(2)]

SECTION VII. ANNUAL EMISSIONS INVENTORY & FEE PAYMENT

The permittee shall file with the AQD an annual emission inventory and shall pay annual fees based on emissions inventories. The methods used to calculate emissions for inventory purposes shall be based on the best available information accepted by AQD. [OAC 252:100-5-2.1, -5-2.2, and OAC 252:100-8-6 (a)(8)]

SECTION VIII. TERM OF PERMIT

A. Unless specified otherwise, the term of an operating permit shall be five years from the date of issuance. [OAC 252:100-8-6 (a)(2)(A)] TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 5

B. A source’s right to operate shall terminate upon the expiration of its permit unless a timely and complete renewal application has been submitted at least 180 days before the date of expiration. [OAC 252:100-8-7.1 (d)(1)]

C. A duly issued construction permit or authorization to construct or modify will terminate and become null and void (unless extended as provided in OAC 252:100-8-1.4(b)) if the construction is not commenced within 18 months after the date the permit or authorization was issued, or if work is suspended for more than 18 months after it is commenced. [OAC 252:100-8-1.4(a)]

D. The recipient of a construction permit shall apply for a permit to operate (or modified operating permit) within 180 days following the first day of operation. [OAC 252:100-8-4(b)(5)]

SECTION IX. SEVERABILITY

The provisions of this permit are severable and if any provision of this permit, or the application of any provision of this permit to any circumstance, is held invalid, the application of such provision to other circumstances, and the remainder of this permit, shall not be affected thereby. [OAC 252:100-8-6 (a)(6)]

SECTION X. PROPERTY RIGHTS

A. This permit does not convey any property rights of any sort, or any exclusive privilege. [OAC 252:100-8-6 (a)(7)(D)]

B. This permit shall not be considered in any manner affecting the title of the premises upon which the equipment is located and does not release the permittee from any liability for damage to persons or property caused by or resulting from the maintenance or operation of the equipment for which the permit is issued. [OAC 252:100-8-6 (c)(6)]

SECTION XI. DUTY TO PROVIDE INFORMATION

A. The permittee shall furnish to the DEQ, upon receipt of a written request and within sixty (60) days of the request unless the DEQ specifies another time period, any information that the DEQ may request to determine whether cause exists for modifying, reopening, revoking, reissuing, terminating the permit or to determine compliance with the permit. Upon request, the permittee shall also furnish to the DEQ copies of records required to be kept by the permit. [OAC 252:100-8-6 (a)(7)(E)]

B. The permittee may make a claim of confidentiality for any information or records submitted pursuant to 27A O.S. 2-5-105(18). Confidential information shall be clearly labeled as such and shall be separable from the main body of the document such as in an attachment. [OAC 252:100-8-6 (a)(7)(E)]

C. Notification to the AQD of the sale or transfer of ownership of this facility is required and shall be made in writing within 10 days after such date. [Oklahoma Clean Air Act, 27A O.S. § 2-5-112 (G)] TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 6

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, reissuance, termination, notification of planned changes, or anticipated noncompliance does not stay any permit condition. [OAC 252:100-8-6 (a)(7)(C) and OAC 252:100-8-7.2 (b)]

B. The DEQ will reopen and revise or revoke this permit as necessary to remedy deficiencies in the following circumstances: [OAC 252:100-8-7.3 and OAC 252:100-8-7.4(a)(2)]

(1) Additional requirements under the Clean Air Act become applicable to a major source category three or more years prior to the expiration date of this permit. No such reopening is required if the effective date of the requirement is later than the expiration date of this permit. (2) The DEQ or the EPA determines that this permit contains a material mistake or that the permit must be revised or revoked to assure compliance with the applicable requirements. (3) The DEQ or the EPA determines that inaccurate information was used in establishing the emission standards, limitations, or other conditions of this permit. The DEQ may revoke and not reissue this permit if it determines that the permittee has submitted false or misleading information to the DEQ.

C. If “grandfathered” status is claimed and granted for any equipment covered by this permit, it shall only apply under the following circumstances: [OAC 252:100-5-1.1]

(1) It only applies to that specific item by serial number or some other permanent identification. (2) Grandfathered status is lost if the item is significantly modified or if it is relocated outside the boundaries of the facility.

D. To make changes other than (1) those described in Section XVIII (Operational Flexibility), (2) administrative permit amendments, and (3) those not defined as an Insignificant Activity (Section XVI) or Trivial Activity (Section XVII), the permittee shall notify AQD. Such changes may require a permit modification. [OAC 252:100-8-7.2 (b)]

E. Activities that will result in air emissions that exceed the trivial/insignificant levels and that are not specifically approved by this permit are prohibited. [OAC 252:100-8-6 (c)(6)]

SECTION XIII. INSPECTION & ENTRY

A. Upon presentation of credentials and other documents as may be required by law, the permittee shall allow authorized regulatory officials to perform the following (subject to the permittee's right to seek confidential treatment pursuant to 27A O.S. Supp. 1998, § 2-5-105(18) for confidential information submitted to or obtained by the DEQ under this section): TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 7

(1) enter upon the permittee's premises during reasonable/normal working hours where a source is located or emissions-related activity is conducted, or where records must be kept under the conditions of the permit; (2) have access to and copy, at reasonable times, any records that must be kept under the conditions of the permit; (3) inspect, at reasonable times and using reasonable safety practices, any facilities, equipment (including monitoring and air pollution control equipment), practices, or operations regulated or required under the permit; and (4) as authorized by the Oklahoma Clean Air Act, sample or monitor at reasonable times substances or parameters for the purpose of assuring compliance with the permit. [OAC 252:100-8-6 (c)(2)]

SECTION XIV. EMERGENCIES

A. Any emergency and/or exceedance that poses an imminent and substantial danger to public health, safety, or the environment shall be reported to AQD as soon as is practicable; but under no circumstance shall notification be more than 24 hours after the exceedance. [OAC 252:100-8-6 (a)(3)(C)(iii)(II)]

B. An "emergency" means any situation arising from sudden and reasonably unforeseeable events beyond the control of the source, including acts of God, which situation requires immediate corrective action to restore normal operation, and that causes the source to exceed a technology-based emission limitation under this permit, due to unavoidable increases in emissions attributable to the emergency. [OAC 252:100-8-2]

C. An emergency shall constitute an affirmative defense to an action brought for noncompliance with such technology-based emission limitation if the conditions of paragraph D below are met. [OAC 252:100-8-6 (e)(1)]

D. The affirmative defense of emergency shall be demonstrated through properly signed, contemporaneous operating logs or other relevant evidence that:

(1) an emergency occurred and the permittee can identify the cause or causes of the emergency; (2) the permitted facility was at the time being properly operated; (3) during the period of the emergency the permittee took all reasonable steps to minimize levels of emissions that exceeded the emission standards or other requirements in this permit; (4) the permittee submitted timely notice of the emergency to AQD, pursuant to the applicable regulations (i.e., for emergencies that pose an “imminent and substantial danger,” within 24 hours of the time when emission limitations were exceeded due to the emergency; 4:30 p.m. the next business day for all other emergency exceedances). See OAC 252:100-8-6(a)(3)(C)(iii)(I) and (II). This notice shall contain a description of the emergency, the probable cause of the exceedance, any steps taken to mitigate emissions, and corrective actions taken; and TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 8

(5) the permittee submitted a follow up written report within 10 working days of first becoming aware of the exceedance. [OAC 252:100-8-6 (e)(2), (a)(3)(C)(iii)(I) and (IV)]

E. In any enforcement proceeding, the permittee seeking to establish the occurrence of an emergency shall have the burden of proof. [OAC 252:100-8-6 (e)(3)]

SECTION XV. RISK MANAGEMENT PLAN

The permittee, if subject to the provision of Section 112(r) of the Clean Air Act, shall develop and register with the appropriate agency a risk management plan by June 20, 1999, or the applicable effective date. [OAC 252:100-8-6 (a)(4)]

SECTION XVI. INSIGNIFICANT ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate individual emissions units that are either on the list in Appendix I to OAC Title 252, Chapter 100, or whose actual calendar year emissions do not exceed any of the limits below. Any activity to which a State or federal applicable requirement applies is not insignificant even if it meets the criteria below or is included on the insignificant activities list. [OAC 252:100-8-2]

(1) 5 tons per year of any one criteria pollutant. (2) 2 tons per year for any one hazardous air pollutant (HAP) or 5 tons per year for an aggregate of two or more HAP's, or 20 percent of any threshold less than 10 tons per year for single HAP that the EPA may establish by rule.

SECTION XVII. TRIVIAL ACTIVITIES

Except as otherwise prohibited or limited by this permit, the permittee is hereby authorized to operate any individual or combination of air emissions units that are considered inconsequential and are on the list in Appendix J. Any activity to which a State or federal applicable requirement applies is not trivial even if included on the trivial activities list. [OAC 252:100-8-2]

SECTION XVIII. OPERATIONAL FLEXIBILITY

A. A facility may implement any operating scenario allowed for in its Part 70 permit without the need for any permit revision or any notification to the DEQ (unless specified otherwise in the permit). When an operating scenario is changed, the permittee shall record in a log at the facility the scenario under which it is operating. [OAC 252:100-8-6 (a)(10) and (f)(1)]

B. The permittee may make changes within the facility that:

(1) result in no net emissions increases, (2) are not modifications under any provision of Title I of the federal Clean Air Act, and (3) do not cause any hourly or annual permitted emission rate of any existing emissions unit to be exceeded; TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 9

provided that the facility provides the EPA and the DEQ with written notification as required below in advance of the proposed changes, which shall be a minimum of 7 days, or 24 hours for emergencies as defined in OAC 252:100-8-6 (e). The permittee, the DEQ, and the EPA shall attach each such notice to their copy of the permit. For each such change, the written notification required above shall include a brief description of the change within the permitted facility, the date on which the change will occur, any change in emissions, and any permit term or condition that is no longer applicable as a result of the change. The permit shield provided by this permit does not apply to any change made pursuant to this subsection. [OAC 252:100-8-6 (f) (2)]

SECTION XIX. OTHER APPLICABLE & STATE-ONLY REQUIREMENTS

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

(1) No person shall cause or permit the discharge of emissions such that National Ambient Air Quality Standards (NAAQS) are exceeded on land outside the permitted facility. [OAC 252:100-3] (2) Open burning of refuse and other combustible material is prohibited except as authorized in the specific examples and under the conditions listed in the Open Burning Subchapter. [OAC 252:100-13] (3) No particulate emissions from any fuel-burning equipment with a rated heat input of 10 MMBTUH or less shall exceed 0.6 lb/MMBTU. [OAC 252:100-19] (4) For all emissions units not subject to an opacity limit promulgated under 40 CFR, Part 60, NSPS, no discharge of greater than 20% opacity is allowed except for 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. [OAC 252:100-25] (5) No visible fugitive dust emissions shall be discharged beyond the property line on which the emissions originate in such a manner as to damage or to interfere with the use of adjacent properties, or cause air quality standards to be exceeded, or interfere with the maintenance of air quality standards. [OAC 252:100-29] (6) No sulfur oxide emissions from new gas-fired fuel-burning equipment shall exceed 0.2 lb/MMBTU. No existing source shall exceed the listed ambient air standards for sulfur dioxide. [OAC 252:100-31] (7) Volatile Organic Compound (VOC) storage tanks built after December28, 1974, and with a capacity of 400 gallons or more storing a liquid with a vapor pressure of 1.5 psia or greater under actual conditions shall be equipped with a permanent submerged fill pipe or with a vapor-recovery system. [OAC 252:100-37-15(b)] (8) 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] TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 10

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. (3) Class I substances (listed at Appendix A to Subpart A) include certain CFCs, Halons, HBFCs, carbon tetrachloride, trichloroethane (methyl chloroform), and bromomethane (Methyl Bromide). Class II substances (listed at Appendix B to Subpart A) include HCFCs.

B. If the permittee performs a service on motor (fleet) vehicles when this service involves an ozone-depleting substance refrigerant (or regulated substitute substance) in the motor vehicle air conditioner (MVAC), the permittee is subject to all applicable requirements. Note: The term “motor vehicle” as used in Subpart B does not include a vehicle in which final assembly of the vehicle has not been completed. The term “MVAC” as used in Subpart B does not include the air-tight sealed refrigeration system used as refrigerated cargo, or the system used on passenger buses using HCFC-22 refrigerant. [40 CFR 82, Subpart B]

C. The permittee shall comply with the following standards for recycling and emissions reduction except as provided for MVACs in Subpart B. [40 CFR 82, Subpart F]

(1) Persons opening appliances for maintenance, service, repair, or disposal must comply with the required practices pursuant to § 82.156. (2) Equipment used during the maintenance, service, repair, or disposal of appliances must comply with the standards for recycling and recovery equipment pursuant to § 82.158. (3) Persons performing maintenance, service, repair, or disposal of appliances must be certified by an approved technician certification program pursuant to § 82.161. (4) Persons disposing of small appliances, MVACs, and MVAC-like appliances must comply with record-keeping requirements pursuant to § 82.166. (5) Persons owning commercial or industrial process refrigeration equipment must comply with leak repair requirements pursuant to § 82.158. (6) Owners/operators of appliances normally containing 50 or more pounds of refrigerant must keep records of refrigerant purchased and added to such appliances pursuant to § 82.166. TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 11

SECTION XXI. TITLE V APPROVAL LANGUAGE

A. DEQ wishes to reduce the time and work associated with permit review and, wherever it is not inconsistent with Federal requirements, to provide for incorporation of requirements established through construction permitting into the Sources’ 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 Oklahoma Administrative Code 252:100-8-7.2(a) only if the following procedures are followed:

(1) The construction permit goes out for a 30-day public notice and comment using the procedures set forth in 40 Code of Federal Regulations (CFR) § 70.7 (h)(1). This public notice shall include notice to the public that this permit is subject to Environmental Protection Agency (EPA) review, EPA objection, and petition to EPA, as provided by 40 CFR § 70.8; that the requirements of the construction permit will be incorporated into the Title V permit through the administrative amendment process; that the public will not receive another opportunity to provide comments when the requirements are incorporated into the Title V permit; and that EPA review, EPA objection, and petitions to EPA will not be available to the public when requirements from the construction permit are incorporated into the Title V permit. (2) A copy of the construction permit application is sent to EPA, as provided by 40 CFR § 70.8(a)(1). (3) A copy of the draft construction permit is sent to any affected State, as provided by 40 CFR § 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 CFR § 70.8(a) and (c). (5) The DEQ complies with 40 CFR § 70.8 (c) upon the written receipt within the 45-day comment period of any EPA objection to the construction permit. The DEQ shall not issue the permit until EPA’s objections are resolved to the satisfaction of EPA. (6) The DEQ complies with 40 CFR § 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 CFR § 70.7 (f) and (g). (10) The DEQ shall not issue the administrative permit amendment if performance tests fail to demonstrate that the source is operating in substantial compliance with all permit requirements.

B. To the extent that these conditions are not followed, the Title V permit must go through the Title V review process. TITLE V PERMIT STANDARD CONDITIONS July 1, 2005 Page 12

SECTION XXII. CREDIBLE EVIDENCE

For the purpose of submitting compliance certifications or establishing whether or not a person has violated or is in violation of any provision of the Oklahoma implementation plan, nothing shall preclude the use, including the exclusive use, of any credible evidence or information, relevant to whether a source would have been in compliance with applicable requirements if the appropriate performance or compliance test or procedure had been performed. [OAC 252:100-43-6] PART 70 PERMIT

AIR QUALITY DIVISION STATE OF OKLAHOMA DEPARTMENT OF ENVIRONMENTAL QUALITY 707 NORTH ROBINSON, SUITE 4100 P.O. BOX 1677 OKLAHOMA CITY, OKLAHOMA 73101-1677

Permit No. 2006-051-TVR

Duke Energy Field Services, L.P. having complied with the requirements of the law, is hereby granted permission to operate the Carney Gas Plant located in the NE/4 of the NW/4 of Section 12, T15N, R2E, Lincoln County, Oklahoma, subject to the following conditions, attached:

[X] Standard Conditions dated July 1, 2005 [X] Specific Conditions

This permit shall expire five years from the date of issuance, except as Authorized under Section VIII of the Standard Conditions.

______Division Director, Air Quality Division Date

DEQ Form #100-890 Revised 2/14/05 Duke Energy Field Services, L.P. Attn: Martin Smith 370 17th Street, Suite 2500 Denver, CO 80202

SUBJECT: Permit No. 2006-051-TVR Facility: Carney Gas Plant Location: S12, T15N, R3E, Lincoln County, Oklahoma

Dear Mr. Smith:

Air Quality has completed initial review of the application and prepared a draft permit. Since the application was determined to be a Tier II application, in accordance with 27A O.S. 2-14-301 and 302 and OAC 252:4-7-13(c), the enclosed draft permit is ready for public review. The requirements for public review of the draft permit include the following steps, which you must accomplish:

1. Publish at least one legal notice (one day) in at least one newspaper of general circulation within the county where the facility is located. (Instructions enclosed) 2. Provide for public review (for a period of 30 days following the date of the newspaper announcement) a copy of the application and draft permit at a convenient location (preferentially at a public location) within the county of the facility. 3. Send AQD a written affidavit of publication for the notices from Item #1 above together with any additional comments or requested changes, which you may have for the permit application within 20 days of publication.

The permit review time is hereby tolled pending the receipt of the affidavit of publication. Thank you for your cooperation. If you have any questions, please refer to the permit number above and contact the permit writer at [email protected] or at (405) 702-4217.

Sincerely,

Dawson Lassetter, P.E. Chief Engineer AIR QUALITY DIVISION

Enclosures

Copy: Shawnee Local DEQ Office (Lincoln County)