PERMIT REVIEW SUMMARY

Company Name:	Tellus Operating Group LLC, Baxterville Compressor Station
Facility Location:	4 Gulf Camp Circle
Lumberton, MS  39455
Source Number:	1440-00030
County: 		Lamar
Permit Action:	Construction Permit (2 new internal compressor engines, AA-017 & AA-019)

PROJECT DESCRIPTION

Tellus Operating Group LLC, Baxterville Compressor Station is an existing natural gas processing facility that has a Synthetic Minor Operating Permit.  Tellus has submitted applications for a construction permit for two (2) new compressor engines.  For one of the new engines, the facility is uncertain what type of engine will be installed , so the application contains options for three different scenarios depending on the manufacturing date of the engines.  The facility will be required to submit a modification to the SMOP within 12 months of certification of construction.  The SMOP modification will specify the type of engine installed and only the requirements applicable to that engine scenario will be carried forward.   

PERMIT LIMITATIONS

The project proposes the construction and operation of a new lean burn compressor engine up to 1800 hp, proposed emission point AA-017.  The construction permit outlines 3 federally enforceable scenarios for each engine type that is described in the construction application.  

Option 2:  For an engine manufactured after 7/1/2010:  These engines are subject to federally enforceable emission standards in 40 CFR 60, Subpart JJJJ.  

NOx limit:	1.00 g/hp-hr
CO limit:	2.00 g/hp-hr
VOC limit:	0.70 g/hp-hr

Option 2:  For an engine manufactured between 7/1/2007 and 7/1/2010:  These engines are subject to federally enforceable emission standards in 40 CFR 60, Subpart JJJJ.  

NOx limit:	2.00 g/hp-hr
CO limit:	4.00 g/hp-hr
VOC limit:	1.00 g/hp-hr

Option 3:  For an engine manufactured before 7/1/2007:

This engine will not be subject to 40 CFR 60, Subpart JJJJ and these engines would not be subject to any emission standard in 40 CFR 63, Subpart ZZZZ.  Federally enforceable short term emission limits are being proposed that reflect the emission factors for the units. 

NOx limit:		4.08 lb/MMBTU	
CO limit:		3.72 lb/MMBTU

In addition to the limitations for NOx and CO, the facility will be required to install and operate a catalytic oxidizer on the engine in order to ensure HAP (formaldehyde) emissions are below major source thresholds.  Carbon Monoxide is a surrogate for Formaldehyde emissions, therefore, the facility will show the formaldehyde emissions are as represented in the application by showing the CO emissions are consistent with the manaufacturer’s guarantee. 

The project also includes the addition of a post-July 1, 2011 model internal compressor engine less than or equal to 500 hp.  This unit is subject to the following emission standards of NSPS JJJJ:

NOx limit:	1.00 g/hp-hr
	CO limit:	2.00 g/hp-hr
VOC limit:	0.70 g/hp-hr

The facility has requested federally enforceable NOx, CO, Total HAP and Individual HAP limitations for all the engines at the facility (AA-015, AA-016, AA-017 and AA-019), to restrict the facility-wide emissions below the Title V threshold.  The proposed limitations are as follows:

NOx limit:			95 tpy on a 12-month rolling average for AA-015, AA-016, AA-017 and AA-019 combined
CO limit:			95 tpy on a 12-month rolling average for AA-015, AA-016, AA-017 and AA-019 combined
Total HAP limit:		19.5 tpy on a 12-month rolling average for AA-015, AA-016, AA-017 and AA-019 combined
Individual HAP limit:	9.0 tpy on a 12-month rolling average for AA-015, AA-016, AA-017 and AA-019 combined

EMISSION EVALUATION

The facility has requested federally enforceable emission limitations to remain below Title V thresholds and be subject to a Synthetic Minor Operating Permit.  The emission inventory has been updated to reflect the existing federally enforceable limits combined with the new limits established in the construction Permit.

Current Facility-Wide Emissions	
Emission Unit	NOx (tpy)	CO (tpy)	VOC (tpy)	PM10 (tpy)	SO2 (tpy)	Total HAPs (tpy)	Highest Individual HAP (tpy) (Formaldehyde)	
AA-007	0.32	0.27	0.02	0.02	0.00	0.01	<0.0001	
AA-009	2.44 a	0.45 a	0.19	0.26	0.02	0.00	<0.0001	
AA-010	0	0	2.82	0	0	3.22	<0.0001	
AA-013	0	0	2.89	0	0	1.75	<0.0001	
AA-015	95	95	15.20	0.01	0.04	1.82 	0.93 	
AA-016			15.20	0.01	0.04	1.82 	0.93 	
AA-018	0	0	0.54	0	0	0	0	
Tanks	0	0	0.04	0	0	0.01	0.00	
Fugitive						0.01		
Total			45.59				2.24	

Proposed Facility-Wide Emissions	
Emission Unit	NOx (tpy)	CO (tpy)	VOC (tpy)	PM10 (tpy)	SO2 (tpy)	Total HAPs (tpy)	Highest Individual HAP (tpy) (Formaldehyde)	
AA-007	0.32	0.27	0.27	0.02	0.00	0.01	<0.0001	
AA-009	2.44 a	0.45 a	0.04	0.19	0	0.00	<0.0001	
AA-010	0	0	8.85	0	0	3.22	<0.0001	
AA-013	0	0	2.89	0	0	1.75	<0.0001	
AA-015	95a	95a	15.20	0.01	0.04	19.5	9.0a	
AA-016			15.20	0.01	0.04			
AA-017			25.0 b	0.6	0.04			
AA-019			5.5 b	0.00	0.01			
AA-018	0	0	0.54	0	0	0	0	
Tanks	0	0	0.04	0	0	0.01	0	
Fugitive						0.01		
Total						24.5	9.0	

a PTE established by a federally enforceable emission limitation
b Based upon worst case engine option in the application at 8760 hours/year operation.  The worst case engine is Option 2.  The VOC PTE was adjusted to include formaldehyde emissions. 

New Source Performance Standards (NSPS) Applicability

The applicant has proposed to construct two new spark ignition internal combustion engines.  One of the units (proposed Emission Point AA-017) is potentially subject to 40 CFR 60, Subpart JJJJ – Standards of Performance for Spark Ignition Internal Combustion Engines (ICE).  If the applicant selects to construct and operate Engine Option 1 or Engine Option 2, this subpart will apply including NOx, CO, and VOC emission standards and corresponding monitoring, recordkeeping and reporting.  The draft permit contains language reflecting applicable requirements if Option 1 or 2 is selected.  The permittee will be required to submit a Compliance Plan within 30 days of certification of construction of the units detailing applicable requirements if Option 1 or Option 2 engines are constructed.  This NSPS Subpart would not apply to the engine option 3 since engines manufactured prior to July 1, 2007 are not subject. 

The other proposed spark ignition unit (proposed Emission Point AA-019) was manufacuted in 2015, therefore NSPS Subpart JJJJ will apply.

New Emission Standards for Hazardous Air Pollutants (NESHAPs) Applicability

The facility wide emissions of total HAP are less than 25 tons per year and all individual HAPs are less than 10 tons per year.  Therefore, the facility is considered an area source of HAP emissions.  The new engines will be subject to area source requirements of 40 CFR 63, Subpart ZZZZ, National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines.  If the engines are subject to NSPS Subpart JJJJ, the emission points will satisfy the requirements of this regulation by meeting the requirements of the NSPS.  If the selected engines are not subject to the NSPS, they will be required to comply with applicable requirements in the regulation for remote RICE.  The permittee will be required to submit a Complicance Plan within 30 days of certification of construction of the units detailing applicable requirements of this regulation based upon the engine scenario selected.

Other Requirements
If Engine Option 1 or 2 is selected, the facility will comply with the short term limitation by complying with the monitoring, recordkeeping and reporting requirements in the applicable NSPS and NESHAP.  If Engine Option 3 engines are selected, the permit will be required to show compliance with the short term emission limit by performing an initial stack test.  

The permittee will be required to monitor the hours of operation of each engine and calculate monthly and 12-month rolling average CO, NOx  and HAP emissions to show compliance with the tons per year limitation.

The facility must submit an application to modify their Synthetic Minor Operating Permit within 12 months of submittal of the certification of construction for the new units.

PUBLIC PARTICIPATION
The 30-day public notice period began on August 12, 2016, with the publication of a notice in the Hattiesburg American and ends September 12, 2016.

RECOMMENDATION
The staff has preliminarily decided to recommend issuance of the permit to the Mississippi Environmental Quality Permit Board as shown in the draft permit.  However, the staff recommendation to the Board will be made only after a thorough consideration of all public comments.