PUBLIC NOTICE DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	  Slater Smith 			Date:	October 18, 2018
Company Name:	Australis TMS Inc., Lewis 7-18H-1 Production Facility
Facility Location:	Country Farm Road
Centreville, Mississippi
Source Number:	0080-00045
County: 		Amite

PROJECT DESCRIPTION
Australis TMS Inc., has applied for the issuance of a Synthetic Minor Operating Permit (SMOP) for the Lewis 7-18H-1 Production Facility. The Lewis 7-18H-1 Production Facility produces oil and natural gas and contains the following emission sources: the production wells, pump jack engine (Emission Point AA-002), three-phase separator, heater treater (Emission Point AA-001), oil/l/condensate storage tanks (Emission Points AA-004, AA-005, AA-006, and AA-007), produced water storage tanks (Emission Points AA-010 and AA-011), a process control flare (Emission Point AA-003), oil/condensate (Emission Point AA-013) and produced water load-out (Emission Point AA-014) operations, and facility-wide fugitive emissions (Emission Point AA-016). The facility has the potential to exceed the Title V major source threshold of 100 tons per year for Volatile Organic Compounds (VOC); however, the facility will operate and maintain control equipment (i.e. the control flare) in order to remain a Synthetic Minor source.

SYNTHETIC MINOR LIMITATIONS
For the entire facility, the permittee shall limit the emissions of VOC to no more than 95.0 tons per year for each consecutive 12-month period on a rolling basis. Furthermore, for the entire facility, the permittee shall limit the emissions of any individual HAP to no more than 9.0 tons per year and the emissions of all combined HAPs to no more than 24.0 tons per year for each consecutive 12-month period on a rolling basis. The permittee is required to route emissions from Emission Points AA-001, AA-004, AA-005, AA-006, AA-007, and AA-013 to the control flare (Emission Point AA-003). The permittee is also required to comply with several work practice standards for the control flare in order to ensure that the vented gas emissions are controlled as efficiently as possible.

NSPS/MACT APPLICABILITY
40 CFR Part 60, Subpart Kb
This subpart applies to each storage vessel with a capacity greater than or equal to 75 cubic meters (m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification is commenced after July 23, 1984. As such, this facility is potentially subject to this subpart. However, according to §60.110b(d)(4), these tanks are exempt because they are “[v]essels with a design capacity less than or equal to 1,589.874 m3 used for petroleum or condensate stored, processed, or treated prior to custody transfer”; therefore, these emission points are not subject to Subpart Kb.

40 CFR Part 60, Subpart KKK
This subpart applies to the “affected facilities” located at onshore natural gas processing plant. A natural gas processing plant is defined as “any processing site engaged in the extraction of natural gas liquids from field gas, fractionation of mixed natural gas liquids to natural gas products, or both.” While natural gas is produced during the extraction and treatment of the produced oil, all produced gas is flared off. As such, this facility does not meet the definition of a natural gas processing plant and is therefore not subject to Subpart KKK.
40 CFR Part 60, Subpart LLL
This subpart applies to natural gas processing facilities located onshore. As noted earlier, this facility does not process natural gas for sale. All produced gas emissions are routed to the control flare for destruction. As such, this facility does not meet the definition of a natural gas processing plant and is therefore not subject to Subpart LLL.
40 CFR Part 60, Subpart JJJJ
This subpart applies to the owners/operators of spark ignition internal combustion engines which commenced construction following a specified, engine specific date. Emission Points AA-008 and AA-009 are non-emergency natural gas fired engine which were manufactured after June 12, 2006. These emission points are subject to and shall comply with the applicable requirements of 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines.
40 CFR Part 60, Subpart OOOO
This subpart applies to the owners and operators of any of a list of onshore affected facilities which were constructed after August 23, 2011 and on or before September 18, 2015. Notably, the following two equipment groups at this facility are exempt from this subpart:
(1)	The facility will use a number of controllers throughout the operation; however, these controllers will be mechanical, not pneumatic, and are therefore not affected under this subpart. 
(2)	The annual potential VOC emissions from each storage vessel (i.e. Emission Points AA-003 through AA-007) will be below 6 tons per year. As such, these storage vessels are not affected under this subpart. 
Because none of the equipment located at the facility is affected by this subpart, the facility is not subject to the requirements of Subpart OOOO.
40 CFR Part 63, Subpart HH
This subpart applies to the owners and operators of glycol dehydration units located at natural gas production facilities which are major or area sources. This facility does not operate any glycol dehydration units and is therefore not subject to Subpart HH.

40 CFR Part 63, Subpart ZZZZ
This subpart applies to the owner/operators of stationary reciprocating internal combustion engines (RICE) which are located at major or area source of HAP emissions. Emissions Points AA-008 and AA-009 are stationary RICE; therefore, these emission points are subject to and shall comply with all applicable requirements of 40 CFR Part 63, Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines.
It is important to note that Emission Points AA-008 and AA-009 are stationary, spark ignition RICE which were constructed after June 12, 2006 and are therefore considered to be “new” stationary RICE located at an area source of HAPs. As such, these emission points will demonstrate compliance with Subpart ZZZZ by complying with the applicable requirements of 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark Ignition Internal Combustion Engines.

PUBLIC PARTICIPATION
The 30-day public notice period began on October 18, 2018, with the publication of a notice in the Enterprise-Journal.

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.