INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
April 23, 2016

FOR:
Florida Gas Transmission Company, Wiggins Compressor Station No. 10
201 Florida Gas Road 
Wiggins, Mississippi

FACILITY DESCRIPTION
Florida Gas Transmission Company owns and operates its Wiggins Compressor Station located 3659 County Road 100 near Wiggins, Mississippi, for the purpose of transporting natural gas through its pipeline distribution system. Natural Gas compression at the Wiggins Compressor Station is accomplished through eight (8) compressor engines. Five (5) engines (AA-001 through AA-005) have a capacity of 2,000 hp; two (2) engines (AA-013 & AA-014) have a capacity of 4,000 hp, and one (1) engine (AA-012) has a capacity of 2,400 hp.  All combustion equipment fires only pipeline quality natural gas. In addition to compressor engines, the Wiggins Compressor Station operates one (1) emergency backup power engine (AA-015) to generate power for the facility during emergencies, as well as, several small liquid product storage tanks. The Wiggins Station also has and fugitive sources from piping and equipment, as well as, tank emissions. 

TITLE V PROGRAM APPLICABILITY BASIS
The Wiggins Compressor Station is a major source as defined by Title V of the Federal Clean Air Act due to its potential to emit more than 100 tons per year of each of the following criteria air pollutants: nitrogen oxides (1,595 tpy), carbon monoxide (379 tpy), & volatile organic compounds (131 tpy). In addition, the facility has the potential to emit more than 25 tons per year of total hazardous air pollutants and more than 10 tons per year of the hazardous air pollutant, formaldehyde.  The facility does not have the potential to emit more than 100,000 tons per year of greenhouse gasses. The potential emissions of NOx from the existing equipment at the compressor station exceed 250 tpy and hence the facility is considered as an “existing major source” for PSD purposes. 

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS

The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 6.), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (11 Miss. Admin. Code Pt. 2, Ch. 1.) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (11 Miss. Admin. Code Pt. 2, Ch. 3.),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (11 Miss. Admin. Code Pt. 2, Ch. 5.), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (11 Miss. Admin. Code Pt. 2, Ch. 2.), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 7.)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 11 Miss. Admin. Code Pt. 2, Ch. 6.or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

CAM APPLICABILITY
There is no control equipment located at this facility, therefore Compliance Assurance Monitoring (CAM) provisions do not apply. 

NSPS APPLICABILITY
No New Source Performance Standards apply to the facility.

MACT APPLICABILITY
The facility is a major source of HAPs since they emit more than 25 tons per year of total HAPs and 10 tpy of an individual HAP (formaldehyde).

The Reciprocating Internal Combustion Engines (RICE) NESHAP, Subpart ZZZZ, regulates HAP emissions from RICE. The eight (8) 4-stroke lean-burn RICE (AA-001 through AA-005 & AA-012 through AA-014) are considered “Existing” units, because they all were constructed prior to December 19, 2002.  Emission Points AA-001 through AA-005 and AA-012 are existing spark ignition 4 stroke lean burn (4SLB) stationary RICE with a rating of more than 500 HP located and a major source of HAPs, so they do not have to meet the requirements of the subpart and of subpart A per §63.6590(b)(3)(ii).  Emission Points AA-013 and AA-014 are  existing spark ignition 2 stroke lean burn (2SLB) stationary RICE with a rating of more than 500 HP located and a major source of HAPs, so they do not have to meet the requirements of the subpart and Subpart A per 63.6590(b)(3)(i) 

Emission Point AA-015 is as an existing 625-HP 4SRB natural gas-fired emergency generator; The citation §63.6590(b)(3)(iii) states that existing emergency stationary RICE with a site rating of more than 500 brake HP located at a major source of HAPs that does not operate or in not contractually obligated to be available for more than 15 hours per calendar year for the purposes specified in §63.6640(f)(2)(ii) and (iii) do not have to meet the requirements of this subpart and of subpart A.  However, emergency operational requirements of §63.6640(f) apply.

The facility denoted no insignificant combustion sources, such as process heaters, space heaters, or water heaters.  Therefore, there are no requirements to meet under 40 CFR 63, Subpart DDDDD - National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters.  

SPECIFIC APPLICABLE REQUIREMENTS
The nine (9) significant air emission combustion sources are subject to state standards for PM and Opacity. Emission Point AA-015 has a particulate matter emission limitation of 0.6 lbs/MMBTU, because it has a rated heat input less than 10 MMBTU/hr. Emission Points AA-001 through AA-005 and AA-012 through AA-014 each have a rated heat input greater than 10 MMBTU/hr and thus are subject to a particulate matter limit of E=0.8808 * I-0.1667 where E is the emission rate in pounds per million BTU per hour heat input and I is the heat input in millions of BTU per hour.  The state SO2 standard of 4.8 lbs/MMBTU had previously been identified as applicable to the compressor engines and the emergency use engines.  However, it has been determined that these types of units are not subject to this standard since the fuel is not primarily burned to produce heat or power by indirect heat transfer.  Therefore, the state SO2 standard is being removed from the Title V Permit.

The only fuel that is being used is natural gas.  Since natural gas is a clean burning fuel, these units should have a large margin of compliance with the PM and Opacity standards. Therefore, the only monitoring requirement is the recording of the type and quantity of fuel used. 

For Emission Point AA-015, the 400 annual hours of operations restriction that was originally included in the Air Construction PSD Permit and was carried over into the Air Title V Operating Permit has been removed from this Air Title V Operating Permit.  The 400 annual hours operational restriction was put in place prior to promulgation of 40 CFR 63 Subpart ZZZZ.  NESHAP ZZZZ restricts routine operations from affected emergency backup generator engines, such as testing and maintenance, to 100 annual hours of operations; therefore, the annual restriction is more stringent.  Thus, this permitting action effectively modifies the outdated construction permit requirements by removal of the 400 annual hours of operations restriction.  This is intended as a Construction Permit change completed via the Title V Operating Permit renewal.
  
Other specific requirements are listed below.

Emission Point(s)	Pollutant/ Parameter	Limit/Standard	Monitoring Requirements	
AA-001
through
AA-005 &
AA-012
through
AA-014	PM	E = 0.8808 * I -0.1667, or as otherwise limited by facility modification restrictions.	Record Type and Quantify of Fuel Used	
AA-012	NOX	2.0 grams per brake horsepower-hour, not to exceed 11.0 lb/hr and 48.18 tons/yr	Biennial Performance Stack Testing	
AA-013
AA-014	NOX	2.0 grams per brake horsepower-hour, not to exceed 17.64 lbs/hr and 77.26 tons/yr	Biennial Performance Stack Testing	
	CO	2.8 grams per brake horsepower-hour, not to exceed 24.7 lbs/hr and 108.19 tons/yr	Biennial Performance Stack Testing	
	VOC	0.8 grams per brake horsepower-hour, not to exceed 7.06 lbs/hr and 30.92 tons/yr	Biennial Performance Stack Testing	
AA-015	PM	0.6 lb/MMBTU, or as otherwise limited by facility modification restrictions.	None	
	NOX	0.98 grams per brake horsepower-hour, not to exceed 1.35 lbs/hr and 0.27 tons/yr	Monitoring of operations	
	CO	2.14 grams per brake horsepower-hour, not to exceed 2.95 lbs/hr and 0.59 tons/yr	Monitoring of operations	
	VOC	0.04 grams per brake horsepower-hour, not to exceed 0.055 lbs/hr and 0.11 tons/yr	Monitoring of operations	
	Operations	Operate only in emergency operation, maintenance and testing, and in non-emergency situations for < 50 hours per year.	Monitoring of operations	

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