INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
January 11, 2017

FOR:
Tennessee Gas Pipeline Company, LLC
Heidelberg Compressor Station Number 538
83 County Road 37
Heidelberg, MS 39439 (Jasper County)

FACILITY DESCRIPTION
Tennessee Gas Pipeline Company, Compressor Station Number 538 is an existing natural gas compressor station (SIC 4922) located near Heidelberg, Mississippi.  The primary emissions sources of significance operated at the site include nine (9) natural gas-fired compressor engines, two (2) natural gas fired emergency generators, and one (1) above ground gasoline storage tank. Fugitive emissions resulting from the facility operations are also included.

TITLE V PROGRAM APPLICABILITY BASIS
Tennessee Gas Pipeline Company - Station 538 is a major source as defined by the Title V program due to its potential to emit more than 100 tons per year (tpy) of each of the following criteria air pollutants:  Carbon Monoxide (498 tpy), Nitrogen Oxides (3,405 tpy), and Volatile Organic Compounds (159 tpy).  The facility also has the potential to emit over 10 tpy of an individual hazardous air pollutant (HAP) (29 tpy of Formaldehyde) and over 25 tpy of total HAPs (102 tpy).  

The facility is also a major source for Prevention of Significant Deterioration (PSD), with emissions of CO and NOx exceeding 250 tpy.  However, no modifications are being proposed as part of this renewal action.

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 so 40 CFR 64 Compliance Assurance Monitoring does not apply.

NSPS APPLICABILITY
New Source Performance Standards (NSPS) contained in 40 CFR Part 60 were reviewed to determine applicability.  Based on this review, the permittee is not subject to the following subparts as follows:

•	40 CFR 60, Subpart Dc – Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units Source does not apply since there are no steam generating units at this facility.  
•	40 CFR 60, Subpart K – Standards of Performance for Storage Vessels for Petroleum Liquids applies to petroleum liquids storage vessels with a storage capacity greater than 40,000 gallons and constructed, reconstructed, or modified after June 11, 1973 but before May 19, 1978.  There are no petroleum storage vessels with a capacity greater than 40,000 gallons at this facility.  Therefore, this regulation is not applicable.
•	40 CFR 60, Subpart Ka – Standards of Performance for Storage Vessels for Petroleum Liquids applies to petroleum liquids with a storage capacity greater than 40,000 gallons and constructed, reconstructed, or modified after May 18, 1978 but before June 23, 1984.  There are no petroleum storage vessels with capacity greater than 40,000 gallons at this facility.  Therefore, this regulation is not applicable. 
•	40 CFR 60, Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels applies to volatile organic liquid storage vessels with a storage capacity greater than 75 cubic meters (19,810 gallons) and constructed, reconstructed, or modified after July 23, 1984.  There are no tanks at the facility that have capacities exceeding this threshold.  Therefore, this regulation is not applicable.
•	40 CFR 60, Subpart LLL – Standards of Performance for Onshore Natural Gas Processing:  SO2 emission standards apply to a sweetening unit and a sulfur recovery unit at a natural gas processing plant.  This regulation defines a sweetening unit as a process device used to separate hydrogen sulfide and carbon dioxide from sour natural gas and a sulfur recovery unit as a process device that recovers elemental sulfur from the separated acid gas.  This facility does not operate a sweetening unit or a sulfur recovery unity at this facility.  Therefore, this regulation is not applicable. 
•	40 CFR 60, Subpart IIII – Standards of Performance for Compression Ignition Internal Combustion Engines (CI ICE) applies to owners or operators of stationary CI ICE that commence construction, modification, or reconstruction after July 11, 2005 and to manufacturers of 2007 and later model year CI ICE.  This facility does not operate any stationary diesel fired CI ICE.  Therefore, this regulation is not applicable.  
•	40 CFR 60, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines (SI ICE) applies to stationary spark ignition combustion engines with horsepower greater than 25 hp constructed after specified dates, dependent on horsepower rating and combustion type (rich or lean).  All spark ignited internal combustion engines at this facility were installed and manufactured prior to the specified applicability dates, with the exception of Emission Point AA-014.  Specifically, Emission Point AA-014 is not subject because although construction commenced after June 12, 2006, the engine was manufactured prior to January 1, 2009, the applicability date for emergency engines.  Therefore, this regulation is not applicable.  
•	40 CFR 60, Subpart OOOO – Standards of Performance for Crude Oil and Natural Gas Production, Transmission, and Distribution applies to owners and operators of onshore crude oil and natural gas facilities which commence construction, modification, or reconstruction after August 23, 2011.  This facility does not employ reciprocating or centrifugal compressors that are located prior to the point of natural gas custody transfer (40 CFR Part 60.5365(b)&(c)).  Additionally, all storage tanks located at this facility were constructed prior to August 23, 2011 and have not been modified or reconstructed after this applicability date.  Furthermore, as outlined in 40 CFR Part 60.5395, these storage tanks are not located at well sites.  Therefore, this regulation is not applicable
•	40 CFR 60, Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015 applies to facilities in the crude oil and natural gas source category that commenced construction, modification, or reconstruction after September 18, 2015.  This facility is considered a natural gas compressor station and is potentially subject to this regulation.  However, all equipment and processes potentially subject to this regulation were installed prior to the applicability date and have not been modified or reconstructed.  Therefore, this regulation is not applicable.   
NESHAP APPLICABILITY
National Emission Standards for Hazardous Air Pollutants (NESHAPs) are emissions standards for hazardous air pollutants (HAPs) applicable to select area and major sources of HAPs.  HAP emission limits are established on the basis of a maximum achievable control technology (MACT) determination for the particular major source.  A major source of HAPs is defined as having potential emissions in excess of 25 tpy for total HAPs and/or potential emissions in excess of 10 tpy for any individual HAP.  

This facility is a major source of HAPs as the potential to emit is greater than 10 tpy for formaldehyde and 25 tpy of total HAPs.  Existing and proposed NESHAP standards were reviewed to determine applicability.  Based on this review, the permittee is subject to the following subparts as follows:

•	40 CFR 63 Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines regulates HAP emissions from existing, new, and reconstructed stationary compression ignition (CI) and spark ignition (SI), emergency and non-emergency, RICE located at major and area sources of HAP emissions.  This standard is potentially applicable to this facility because it operates several reciprocating internal combustion engines.  
Specifically, nine (9) of the facility’s engines (AA-003 thru AA-011) are considered existing spark ignition 2-stroke lean burn (2SLB) sources over 500 brake horsepower (bhp) and do not have any applicable requirements associated with this regulation per 40 CFR 63.6590(b)(3)(i).  

Emission Point AA-014 is a new emergency stationary RICE located at a major source with a site rating of more than 500 brake hp and exempt from any requirements besides an initial notification requirement of 40 CFR 63.6590(b)(1)(i).  

Emission Point AA-001 is subject to Subpart ZZZZ per 40 CFR 63.6590(a)(1)(ii), and complies with applicable maintenance, record keeping and notification requirements for emergency engines.  

The permittee is not subject to the following subparts as follows:

•	40 CFR 63, Subpart HH – National Emissions Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities Source applies oil and gas production facilities.  This facility is a transmission and storage facility.  Therefore, this regulation is not applicable. 
•	40 CFR 63, Subpart HHH – National Emissions Standards for Hazardous Air Pollutants from Natural Gas Transmission and Storage Facilities Source regulates emission limitations on HAPs emitted from Natural Gas Transmission and Storage Facilities.  This facility is considered a natural gas compression and storage facility and is potentially subject to his regulation.  However, this facility does not operate a glycol dehydration unit which is the only ‘affected’ source under this regulation.  Therefore, this facility is not subject to Subpart HHH. 
•	40 CFR 63, Subpart DDDDD – National Emissions Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters regulates HAP emissions from new and existing industrial, commercial, or institutional boilers and process heaters located at major sources of HAP emissions.  This facility does not operate a boiler or process heater subject to this rule.  Therefore, this regulation is not applicable. 
•	40 CFR 63, Subpart JJJJJJ – National Emissions Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources regulates emission limitations on HAPs emitted from industrial commercial, and institutional boilers located at an area source of HAPs.  This facility is a major source of HAPs.  Therefore, this regulation is not applicable. 
SPECIFIC APPLICABLE REQUIREMENTS
The facility’s eleven (11) natural gas-fired sources are subject to state standards for particulate matter and opacity.  Since natural gas is a clean burning fuel, the units should have a large margin of compliance with the PM and Opacity standards. The only monitoring proposed for compliance demonstration for PM and Opacity for these units is documenting the fuel type and quantity. 

The facility’s small water heaters and comfort space heaters qualify as insignificant activities.  These activities are subject to the state standards for PM, SO2 and Opacity.  Since these units combust natural gas and the size of the units are very small, no monitoring is proposed for the units.  There are no other applicable requirements for the facility’s other insignificant activities listed in their Title V application.