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Air Quality Update
March, 2008, Vol 11, No 1 S
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A total of 209 consultants and industry representatives attended emissions inventory workshops in Oklahoma City on January 16 and in Tulsa on January 23, which represents a 28% increase over last year’s attendance. There were several attendees from out-of-state, and at least one from Canada. The annual workshops provide instruction on the submission of emission inventories and the use of REDBUD, the Emissions Inventory web application. Both workshops provided hands-on training opportunities where participants could practice entering information online.

Just as in last year’s workshop, the morning session provided an introduction to the basics of emissions inventories and REDBUD. An in-depth discussion followed in the afternoon session.

The following two procedural changes were reviewed:

  • Attendees were reminded that the submission due date is April 1st. Requests for extensions must be submitted in writing and “show good cause” why an extension is needed.

  • REDBUD now incorporates additional data trapping; i.e. there are more “Information Required” data fields. As in previous years, the importance of filing early was stressed, particularly when using REDBUD.

Feedback forms that were returned at the conclusion of each workshop indicated a very positive reception. One attendee wrote, “I work with 12 different states. ODEQ AEI Section is by far the most knowledgeable and helpful . . .”

There were several questions asked at each workshop which will be incorporated into the Frequently Asked Questions (FAQ) section of the Emissions Inventory website at The workshop agenda and Microsoft PowerPoint presentations are available at


The Air Quality Advisory Council held two meetings in Oklahoma City in the first quarter of 2008. The agenda for the January 17 meeting included hearings on several proposed rules for Chapter 100 of the Oklahoma Administrative Code, including a reconsideration of the proposed new mercury rule. At the February 5 meeting, the focus was on the proposed increase in annual operating fees for both minor facilities and Part 70 sources.

At the January 17 meeting the group voted to retain Mr. David Branecky as Chair for 2008, and Mr. Rick Treeman as Vice Chair. Mr. Branecky represents the electric utilities industry, and Mr. Treeman represents agricultural interests.

Modifications to Subchapter 24, Particulate Matter Emissions from Grain, Feed and Seed Operations, were recommended to be forwarded to the Environmental Quality Board for consideration at its February 29 meeting.

Proposed changes to Subchapter 9, Excess Emission Reporting Requirements, were considered at the January meeting, and the Council voted to continue consideration of the proposal to its July meeting. The changes would make the rule consistent with the current interpretation of the EPA guidelines on excess emissions. Proposed changes to Subchapter 33, Control of Emissions of Nitrogen Oxides, were also carried over to the July meeting.

A large portion of the January meeting was focused on the proposed mercury emissions rule. Mr. Max Price, Environmental Programs Specialist with the Air Quality Division, presented three possible options for a new Subchapter 44, Control of Mercury from Coal-fired Electric Steam Generating Units. The first option would be to incorporate by reference the federal Clean Air Mercury Rule (CAMR). A second option is the adoption of a state rule incorporating the Maximum Achievable Control Technology (MACT) standard first proposed by EPA on January 30, 2004. The third option is adoption of the model rule issued in November 2005 by the State and Territorial Air Pollution Program Administrators and Association of Local Air Pollution Control Officials (now called the National Association of Clean Air Agencies). This last option requires greater reductions and shorter timelines than the federal version and prohibits trading of mercury credits. The Council heard comments from a number of citizens. Most of those commenting were in support of the third option. The Council deferred a decision on adoption of the rule until its April 2008 meeting. Subsequent to the Council meeting, there were actions taken by the federal courts that will need to be taken into consideration by the Council. In a unanimous decision, the U.S. Court of Appeals for the D.C. Circuit vacated both EPA’s rule delisting coal- and oil-fired electric generating units from regulation under Section 112 of the Clean Air Act (Delisting Rule) and the Clean Air Mercury Rule (CAMR).

After considerable discussion and revision at the February meeting, the proposed fee increases in Subchapter 5, Registration, Emission Inventory and Annual Operating Fees, were recommended by Council members to be forwarded to the Environmental Quality Board at its February 29, 2008 meeting. The changes would increase annual operating fees for both minor facilities and for Part 70 sources. Additional income resulting from a fee increase would be used to cover current and anticipated staffing requirements in administering the Department’s air programs. The Council also passed a resolution to be sent to the Governor and the Legislature asking their support of requiring mobile sources to help pay for the costs of clean air regulations.

The next Council meeting will be held in Tulsa on Wednesday, April 16, 2008.


It is time once again for DEQ certified Lead-Based Paint (LBP) contractors and firms to renew their certification. The 2007-2008 certification year will end March 31, 2008. To renew a LBP certification, contractors must submit a complete LBP renewal application, including documentation of refresher training and fees to DEQ by March 31, 2008.

Starting this year there is additional information required with the renewal application. As a result of the new immigration law (HB 1804), applicants who are United States citizens must provide a document to DEQ from each of the following three categories:

  1. A copy of a valid, unexpired driver’s license or photo-identification card from state of residency.

  2. An original or certified copy of a birth certificate, a photocopy of a valid, unexpired U.S. passport, a photocopy of a Certificate of Citizenship (N-560 or N-561), or a photocopy of a Naturalization Certificate (N-550 or N-570).

  3. A signed and notarized Affidavit Regarding Citizenship (the affidavit must be signed in the presence of a notary public).

For all non-U.S. citizens, applicants must provide to DEQ an Affidavit Regarding Citizenship signed in the presence of a notary public and documentation demonstrating “lawful presence.” A list of acceptable documents is posted on DEQ’s Web site at or applicants can call Richard Hooper at 405-702-4100.

Refresher training has already begun and will continue through March 2008. Please check the DEQ website for current class schedules.

Attention needs to be given to timely submittal of LBP quarterly reports. Every individual that is certified by the DEQ to participate in any of the LBP disciplines is required to submit a quarterly activity report. These reports are very important to an individual’s certification because all quarterly reports must be filed before a certification can be renewed. When reports are not filed in a timely manner, already limited program resources must be used to send late notices. Quarterly report forms are available on request or If you have questions, feel free to contact Richard Hooper, Crystal K. Stearns or Kevin Tallant at 405-702-4100.


Currently, EPA lists three sections under review: Section 12.2, Coke Production; Section 12.5.1, Steel Mini-mills; and all of Chapter 15, Ordnance Detonation. During the review process sections were added to the Ordnance Detonation chapter. The comment periods for all three chapters are now closed.

Find more AP-42 information on EPA’s TTN-CHIEF Bulletin Board at


A new version of the Excess Emission Online System was released on 1-29-08. The new version includes an option to upload immediate notifications, written reports, demonstrations of cause, and data/calculations. At this time, the system will only accept files with the following extensions: .doc, .pdf, .xls or .txt. If you would like to upload other file types, please contact the excess emissions team. Contact Hillary Moseley at 405-702-4100 for more information.


Dry cleaning facilities have been regulated by EPA since September 22, 1993, when the National Perchloroethylene Air Emission Standards for Dry Cleaning Facilities (NESHAP M) was first promulgated. On December 21, 2005 EPA proposed changes to NESHAP M to include additional (residual risk) standards needed to protect public health with an ample margin of safety. Perchloroethylene is a hazardous pollutant also known as PCE or perc. The final rule was promulgated July 27, 2006. The standards are based on whether a facility is existing (machines installed before 12/9/1991, or a new transfer machine installed or reconstructed between 12/9/1991 and 9/22/1993) or new (machines installed on or after 12/9/1991), whether the machine is a dry-to-dry system (one machine does all the washing and drying) or a transfer system (at least two machines—a washer and a dryer or reclaimer), and whether a small area source, large area source, or major source. Note that small area sources generally consume less than 140 gallons of PCE per year—see the Small Area Source Category Fact Sheet for specifics, and large area sources generally consume less than 1,800 gallons of PCE per year—see the Large Area Source Category Fact Sheet for specifics.

The New Control Requirements…

New dry-to-dry equipment (constructed or reconstructed on or after 12/9/1991) must have a refrigerated condenser. Equipment installed after 12/21/2005 must also have a closed loop system with a carbon adsorber following the refrigerated condenser that operates immediately before the machine door is opened (a “generation 4” machine).

You must eliminate any transfer machines by 7/28/2008 (except for those at small area sources installed between 12/9/1991 and 9/22/1993).

You cannot install (including relocating a used machine) a PCE machine in a building with a residence on or after 7/13/2006. If you have a PCE machine located in a building with a residence, when it wears out you cannot replace it with another PCE machine.

If you installed a PCE machine in a building with a residence on or after 12/21/2005, but before 7/13/2006, you must operate the dry cleaning system inside a vapor barrier enclosure with its exhaust system operating at all times the dry cleaning machine operates and during maintenance; and route the PCE gas vapor stream through a refrigerated condenser, and pass the vapor stream from inside the dry cleaning drum through a carbon adsorber immediately before the door of the machine is opened (a “generation 4” machine).

You must eliminate PCE machines installed (including relocating a used machine) after 12/21/2005 in a building with a residence by 7/27/2009. You must eliminate PCE machines installed (including relocating a used machine) before 12/21/2005 in a building with a residence by 12/21/2020.

The New Monitoring Requirements…

On any new or existing equipment with a refrigerated condenser, you must measure and record the refrigeration system high pressure and low pressure during the drying phase to determine if they are in the range specified in the manufacturer's operating instructions. If the machine is not equipped with refrigeration system pressure gauges, then you must measure the outlet temperature. It must be equal to or less than 45 °F. If the pressure is outside the operating range or the temperature is greater than 45 °F, you must make repairs or adjustments and write down all changes. Measurements must be made once a week using a colorimetric detector tube or gas analyzer.

You must control fugitive emissions. A sight, smell and touch inspection is required weekly for all equipment. Sources constructed before 12/21/2005 must complete monthly vapor leak detections beginning 7/28/2008. Sources constructed on or after 12/21/2005 must complete monthly vapor leak detections by the later of 7/27/2006 or immediately upon startup.

The New Reporting Requirements…

All new PCE sources must submit to the DEQ by registered mail, a Compliance Status Notification by 7/28/2008. The following information must be provided, and the notification must be signed by a responsible official who shall certify that the information contained in the statement is accurate and true.

(1) The name and address of the owner or operator;

(2) The address (that is, physical location) of the dry cleaning facility;

(3) If they are located in a building with a residence(s), even if the residence is vacant at the time of this notification;

(4) If they are located in a building with no other tenants, leased space, or owner occupants;

(5) Whether they are a major or area source;

(6) The yearly PCE solvent consumption based upon the yearly solvent consumption calculated according to § 63.323(d); and

(7) Whether or not they are in compliance with each applicable requirement of § 63.322.

What next…

If you are a permitted facility, your current DEQ permit most likely does not include the new EPA requirements. Thus, you must obtain a new permit—either by modifying an individual permit to include the new requirements, or by obtaining a new Authorization to Operate under the Dry Cleaning General Permit. The Dry Cleaning General Permit was updated 1/24/2008, and includes the new requirements. Thus, you should make application for a new Authorization to Operate as soon as possible. If you submit your application for coverage under the General Permit prior to 7/27/08 it will also serve as the Compliance Status Notification mentioned previously. The fee for a new Authorization to Operate is currently $150.


Visible Emissions Evaluation training is being offered through CenSARA. Training will occur in Oklahoma City on March 25, 26, 27 and Tulsa on April 22, 23, 24. Field certifications and a classroom lecture will be offered at both locations. Applicants who have not attended smoke school previously are required to attend the classroom lecture. Lecture attendance is encouraged for all applicants who have not attended a lecture in the past year. These courses will meet EPA Method 9 and Method 22 training requirements. Individuals qualifying at the field certification will be certified to make visible emission readings.

Maps and registration information for both locations are available at the CenSARA website:

Questions may also be directed to Lyndee Songer at 405-702-4166.


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