INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
August 10, 2016

FOR:
SG Resources, Mississippi LLC, Southern Pines Energy Center
2501 Tung Oil Road
Leakesville, MS 39451    

FACILITY DESCRIPTION
SG Resources, Mississippi LLC, Southern Pines Energy Center is an existing natural gas storage facility located in Leakesville, Greene County, Mississippi.  The facility operates six (6) 7,695-HP natural gas-fired compressor engines, one (1) 657-HP diesel-fired emergency backup generator, two (2) 2.0-MMBTUH glycol dehydration reboilers, two (2) glycol dehydration still vents, truck loading activities, two (2) BTEX eliminators, two (2) 10-MMBTUH natural gas line heaters, ten (10) storage tanks, as well as, emissions associated with maintenance activities and fugitive sources.  

TITLE V PROGRAM APPLICABILITY BASIS
SG Resources, Mississippi LLC, Southern Pines Energy Center is a major source as defined by Title V of the Federal Clean Air Act (CAA) due to its potential to emit more than 100 tons per year of the criteria air pollutants nitrogen oxides (175 tpy) and carbon monoxide (161 tpy). The facility does not have the potential to emit more than 25 tons per year of total hazardous air pollutants (HAP) or more than 10 tons per year of any individual HAP.  The facility also does not have the potential to emit more than 100,000 tons per year of greenhouse gasses. The potential emissions of criteria pollutants from the existing equipment at the compressor station does not exceed 250 tpy and hence the facility is considered as a “synthetic minor 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 associated with any emission unit subject to an emission limit or standard at this facility, therefore Compliance Assurance Monitoring does not apply to SG Resources, Mississippi LLC, Southern Pines Energy Center.

MACT APPLICABILITY
The facility is an Area Source of HAPs since it emits less than 25 tons per year of total HAPs and less than 10 tpy of any individual HAP.

40 CFR 63 SUBPART ZZZZ
The Reciprocating Internal Combustion Engines (RICE) NESHAP, Subpart ZZZZ, regulates HAP emissions from RICE. 

Emission Points AA-006 through AA-009 and AA-013 and AA-014 are new 4-stroke lean-burn (4SLB) spark-ignition (SI) stationary RICE with a rating of more than 500 HP located at an Area Source of HAPs.  These sources are required to meet the requirements of NESHAP ZZZZ by meeting the requirements of 40 CFR 60 Subpart JJJJ per 40 CFR 63.6590(c)(1).  No further requirements apply for these sources under NESHAP Subpart ZZZZ or Subpart A.

Emission Point AA-015 is a new 4-stroke lean-burn (4SLB) compression-ignition (CI) stationary RICE with a rating of more than 500 HP located at an Area Source of HAPs.  This source is required to meet the requirements of NESHAP ZZZZ by meeting the requirements of 40 CFR 60 Subpart IIII per 40 CFR 63.6590(c)(1).  No further requirements apply for this source under NESHAP Subpart ZZZZ or Subpart A.

40 CFR 63 SUBPART JJJJJJ 
Since the facility is an “Area” source of HAP emissions, the facility is potentially subject to 40 CFR 63, Subpart JJJJJJ; consequently, the facility is not a “Major” source of HAP emissions, and is thus not subject to 40 CFR 63, Subpart DDDDD. Since the facility is an “Area” source, only “Industrial, Commercial, Institutional” (ICI) boilers could potentially be affected units. Since the facility’s external combustion sources are exclusively “gas-fired,” pursuant to §63.11195(e) they are exempt from the requirements of Subpart JJJJJJ. 

NSPS APPLICABILITY

40 CFR 60 SUBPART JJJJ 
Emission Points AA-006 through AA-009, AA-013, and AA-014, are subject to 40 CFR 60 Subpart JJJJ - New Source Performance Standards for Stationary Spark Ignition Internal Combustion Engines.  The provisions of NSPS JJJJ are applicable to stationary spark ignition internal combustion engines that commenced construction, modification, or reconstruction after June 12, 2006.  Emission Points AA-006 through AA-009, AA-013, and AA-014 were each constructed in 2007.  

Under 40 CFR 60, Subpart JJJJ, the following limits for Emission Points AA-006 through AA-009, AA-013, AA-014: 2.0 grams/horsepower-hour for NOx, 4.0 grams/horsepower-hour for CO, and 1.0 grams/horsepower-hour for VOCs.  

The permittee is required to conduct subsequent performance tests every 8,760 hours or three (3) years, whichever comes first, after the date of the initial performance stack tests, to demonstrate compliance with emissions limitations.  The permittee is also required to operate and maintain the stationary engine according to the manufacturer's emission-related written instructions and to comply with the applicable notifications, reporting, and recordkeeping requirements in 40 CFR 60.4245.

40 CFR 60 SUBPART IIII 
Emission Point AA-015 is subject to 40 CFR 60 Subpart IIII - New Source Performance Standards for Stationary Compressions Ignition Internal Combustion Engines.  The provisions of NSPS IIII are applicable to stationary compression ignition internal combustion engines that commenced construction, modification, or reconstruction after June 12, 2006.  Emission Point AA-015 was constructed in 2007. 

40 CFR 60 SUBPART Dc 
Emission Points AA-018 and AA-019 are subject to 40 CFR 60 Subpart Dc - New Source Performance Standards for Small Industrial-Commercial-Institutional Steam Generating Units.  The provisions of NSPS Dc are applicable to steam generating units that are constructed after June 9, 1989, with a maximum design heat input capacity between 10-100 MMBTU/hr.  Each line heater is rated at 10 MMBTU/hr and were constructed after the June 9, 1989 effective date.  Since the units are only capable of firing natural gas, the only requirement under NSPS Dc is monthly recordkeeping of the quantity of natural gas combusted for each source. 

PERMIT MODIFICATIONS
There are changes in the draft permit from the current permit.  Changes include:
1.	Two (2) new line heaters (AA0-018 & AA-019) are included; each unit was authorized in 2011 by Section 502(b)10 of the CAA;
2.	A second BTEX Eliminator (AB-002) has been installed.  There is now one (1) BTEX Eliminator for each glycol dehydrator still vent;
3.	Glycol dehydration still vent No. 3 was never installed and has been removed from the permit;
4.	The natural gas-fired pump engine (AA-020) was never installed and has been removed from the permit;
5.	The total, combined horsepower operations restriction of 202,224,600 HP-hr per 12-month rolling total for the combined engines (AA-006 through AA-009, AA-013, and AA-014) was increased from 33,704,100 HP-hr. 33,704,100 HP-hr was erroneously input during the previous permitting action, and is the amount allocated to an individual engine.  The total combined allowable output is 202,224,600 HP-hr per 12-month rolling total for the combined engines;
6.	The 500-annual hours of operation restriction on the emergency backup generator has been removed from the permit and replaced with more restrictive operational requirements per 40 CFR 63 Subpart ZZZZ; and
SPECIFIC APPLICABLE REQUIREMENTS
The seven (7) reciprocating internal combustion sources are subject to state standards for PM and Opacity. Emission Points AA-002, AA-003, and AA-015 have a PM emission limitation of 0.6 lbs/MMBTU, because each source has a rated heat input less than 10 MMBTU/hr. Emission Points AA-006 through AA-009, AA-013, AA-014, AA-018, and AA-019, each have a rated heat input greater than 10 MMBTU/hr and thus are subject to a PM 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 seven (7) 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 these sources.  The state SO2 standard is applicable to Emission Points AA-002, AA-003, AA-018, and AA-019.

The only fuel that is being used for seven (7) engines 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. 

Other specific requirements are listed below.
Emission Point(s)	Pollutant/ Parameter	Limit/Standard	Monitoring Requirements	
AA-002
AA-003
AA-015	PM	0.6 lbs/MMBTU or as otherwise limited by facility modification restrictions	Record Type and Quantify of Fuel Used	
AA-004	Benzene	Shall operate with emissions routed to and controlled by Emission Point AA-001	Monitoring of operations	
AA-005	Benzene	Shall operate with emissions routed to and controlled by Emission Point AB-002	Monitoring of operations	
AA-006 through AA-009      AA-013 AA-014
AA-018
AA-019	PM	E=0.8808*I -0.1667 or as otherwise limited by facility modification restrictions	Record Type and Quantify of Fuel Used	
	Fuel Restriction	Shall burn only natural gas	Record Type and Quantify of Fuel Used	
AA-006 through AA-009      AA-013 AA-014	NOx
CO
VOC	2.0 g/HP-hr or 160 ppmvd @ 15% O2
4.0 g/HP-hr or 540 ppmvd @ 15% O2
1.0 g/HP-hr or 86 ppmvd @ 15% O2	Performance Stack Testing every 8,760 hours, or triennially, whichever comes first	
	Operational Restriction	Shall only operate the compressor engines with emissions routed to and controlled by the oxidation catalyst	Monitoring of operations	
	Operational Restriction	Shall only operate a total of 202,224,600 HP-hr per 12 month rolling total  combined for all engines	Monitoring of operations	
AA-006 through AA-009	NOx	12.72 lb/hr and 27.86 tons/yr. The total aggregate from all six engines is limited to 163.47 tons on 12 month rolling basis	Performance Stack Testing every 8,760 hours, or triennially, whichever comes first	
	CO	9.86 lb/hr and 21.59 tons/yr. The total aggregate from all six engines is limited to 151.36 tons on 12 month rolling basis	Performance Stack Testing every 8,760 hours, or triennially, whichever comes first	
AA-013 AA-014	NOx	11.88 lb/hr and 26.01 tons/yr. The total aggregate from all six engines is limited to 163.47 tons on 12 month rolling basis	Performance Stack Testing every 8,760 hours, or triennially, whichever comes first	
	CO	14.84 lb/hr and 32.51 tons/yr. The total aggregate from all six engines is limited to 151.36 tons on 12 month rolling basis	Performance Stack Testing every 8,760 hours, or triennially, whichever comes first	
AA-015	THC/NOx
CO
PM	4.0 g/kw-hr
3.5 g/kw-hr
0.2 g/kw-hr	Monitoring of operations	
	Fuel Content	Maximum sulfur content of 15 ppm; and a Minimum cetane index of 40 or a maximum aromatic content of 35%volume. 	Monitoring of operations	
AA-002
AA-003
AA-018
AA-019	SO2	4.8 lbs/MMBTU or as otherwise limited by facility modification restrictions	Record Type and Quantify of Fuel Used	

The NOx and CO emissions limitations for Emission Points AA-006 through AA-009, AA-013, and AA-014 are for PSD avoidance.  The horsepower operations restriction of 202,224,600 HP-hr per 12-month rolling for the combined engines will ensure that Emission Points AA-006 through AA-009, AA-013, and AA-014 do not exceed the limitations of 163.47 tons/yr of NOx and 151.36 tons/yr of CO.

Emission Points AA-006 through AA-009, AA-013, and AA-014 also have an operational restriction to operate the compressor engines with emissions routed to and controlled by the oxidation catalyst and to only combust natural gas.