PERMIT REVIEW SUMMARY

Permit Writer:	Cevion Span 			Date:	March 9, 2017

Company Name:	Columbia Gulf Transmission LLC, Holcomb Compressor Station

Facility Location:	Old Mississippi 7
			Holcomb, MS 38940

Source Number:	0960-00040

County: 		Grenada

PROJECT DESCRIPTION

Columbia Gulf Transmission’s proposed Holcomb Compressor Station will be located in Grenada County, MS. The station will receive natural gas via pipeline from an upstream compressor station, compress the gas, then transmit it via pipeline to a downstream station. The station is covered by SIC 4922, and has the potential to operate seven (7) days a week, twenty-four (24) hours per day. 
The facility will consist of two (2) natural gas-fired turbines, one (1) emergency generator, one (1) process heater, forty (40) catalytic heaters, one (1) 1,260 waste water tank and one (1) 2,056 gallon condensate tank. The new turbines will be equipped with advanced dry-low-NOx combustion controls, known by the manufacturer as SoLoNOx.

The CO, NOx, and VOC emissions at the facility are variable depending on the operating load of the units.  The facility intends to operate the units at full load (>50 % load) and the potential to emit for these pollutants have been estimated using normal load emission factors with minimal operation in low load, low temperature and startup/shutdown operations which have higher short term emissions. When considering the worst case lb/hr emission for CO, which is operating at low load, the facility has the potential to be above the Prevention of Significant Deterioration (PSD) thresholds of 250 tpy.  Therefore, the draft permit contains both lb/hr emission limits for each operating mode and a ton per year limit for CO.  Since the annual tpy limit will only allow for minimal time in operational modes other than normal operation, the draft permit only proposes the facility demonstrate compliance with the normal mode lb/hr limit.  The facility will use the manufacturer’s information for other modes to use in calculating monthly and annual emissions.  

The NOx emissions are also variable; however even when considering the worst case lb/hr operational mode for the turbines, the NOx emissions will be below the PSD threshold.  The turbines are subject to a New Source Performance Standard, which limits NOx emissions.  Since no limitation on NOx in needed to avoid PSD, there is no lb/hr or tpy limitations proposed for NOx; however, the draft permit does require the facility to monitor and report NOx emissions.
The facility’s potential to emit for all regulated PSD pollutants, with the exception of CO which will have a PSD avoidance limit, are less than 250 tons per year. Therefore, PSD is not required. The facility will be a Title V source upon start of operation.

PROPOSED CONSTRUCTION PERMIT LIMITS 
The draft permit contains the following proposed limitations in order to maintain emissions below PSD thresholds:

Operating Mode	Emissions Limit per turbine
Carbon Monoxide	
Normal Operation (≥50 % load)	7.43 lb/hr	
 Low Load (< 50 %); 	653.41 lb/hr	
Low Ambient Temp. (< 0 °F)	31.41 lb/hr	
Startup & Shutdown	272.70 lb/event	
Annual Emissions	78.83 tpy 	

In order to comply with the limitations, the permittee will be required to perform periodic performance tests for CO for normal operation.  The permittee will also have to monitor the amount of operating times for each operating scenario and calculate monthly and 12-month rolling average annual emissions to show compliance with the tons per year emission limitation.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

NSPS apply to new, modified, or reconstructed stationary sources meeting criteria established in 40 CFR Part 60. The following NSPS were evaluated for this new station.
 
•	Subpart Dc (Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units) applies to steam generating units with a maximum design heat input capacity of ≥ 10 MMBtu/hr, but ≤ 100 MMBtu/hr which are constructed, modified, or reconstructed after June 9, 1989. The proposed heater will be rated at 1.10 MMBtu/hr; therefore, the NSPS is not applicable. The proposed catalytic heaters are not steam generating units.

•	Subpart OOOO (Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution for which Construction, Modification or Reconstruction Commenced after August 23, 2011, and on or before September 18, 2015) is not applicable since this facility will be constructed after the applicable date of this subpart.

•	Subpart OOOOa (Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015).  Fugitive components at new compressor stations are an affected facility under this subpart; therefore, the fugitive components at the facility will be subject to this Subpart.

•	Subpart KKKK Standards of Performance for Stationary Combustion Turbines.  New combustion turbines, such as the proposed Solar Mars 100 turbines, that have a peak heat input of 10 MMBtu/hr and greater, and will be constructed after February 18, 2005 are subject to the requirements of Subpart KKKK.  Sources covered by Subpart KKKK are exempt from the requirements in Subpart GG (the previous combustion turbine NSPS). Based on manufacturer data, the Solar Mars 100 combustion turbines will comply with the emission limits.

•	Subpart JJJJ (Standards of Performance for Stationary Spark Ignition Internal Combustion Engines) applies to stationary spark ignition engine manufacturers and owners/operators. The proposed emergency generator will be subject to the Subpart JJJJ emission limits for engines > 130 hp. Based on manufacturer data, the engine will comply with the emission limits.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

NESHAP are publicized under 40 CRR Part 63 for specific processes and HAP emissions. The proposed Station has potential HAP emissions that are less than the major source threshold and will be considered an area source of HAPs. 

•	40 CFR 63 Subpart YYYY for stationary combustion turbines is only applicable to major sources of HAPS; therefore, the turbines are not subject to this regulation.
•	Subpart ZZZZ for stationary reciprocating internal combustion engines is applicable to the proposed emergency generator. The proposed emergency generator is a new stationary reciprocating internal combustion engine located at an area source of HAPs. Therefore, the engine meets the requirements of Subpart ZZZZ by meeting the requirements of NSPS Subpart JJJJ.
•	There are two NESHAPs which regulate emissions from industrial, commercial and institutional boilers – 40 CFR 63 Subpart DDDDD (major sources of HAPs) and 40 CFR 63 Subpart JJJJJJ (area sources of HAPs). The proposed Station will be an area source of HAPs; natural gas-fired sources are exempt from the requirements of Subpart JJJJJJ.

PUBLIC PARTICIPATION

The 30-day public notice period began on March 31, 2017, with the publication of a notice in the Grenada Star and ends May 01, 2017.

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.