Title: afgafgasdgfsd
Author: Bruce Ferguson
Last saved by: Slater Smith
Company: None

Permit Review Summary
Page

DRAFT PUBLIC NOTICE PERMIT REVIEW SUMMARY

Permit Writer:	  Slater Smith 			Date:	October 22, 2018
Company Name:	Australis TMS Inc., Longleaf 29H-1 and 29H-2 Production Facility
Facility Location:	Off Ash Road
Centreville, Mississippi
Coordinates:		N 31° 07’ 48.83”
W 90° 46’ 06.16”
Source Number:	0080-00047
County: 		Amite

PROJECT DESCRIPTION
Australis TMS Inc., has applied for the issuance of a Synthetic Minor Operating Permit (SMOP) for the Longleaf 29H-1 and 29H-2  Production Facility. The Longleaf 29H-1 and 29H-2  facility produces oil and natural gas and contains the following emission sources: the production wells, two heater treaters, oil/condensate storage tanks, produced water storage tanks, a process control flare, oil/condensate and produced water load-out operations, and facility-wide fugitive emissions. 
Australis TMS Inc., Longleaf 29H-1 and 29H-2  Production Facility was issued a construction permit for eight 16,800 gallon Crude Oil Storage Tanks, two natural gas-fired Pump Jack Engines, and a three phase separator. According to the SMOP application, only six crude oil storage tanks and two electric Pump Jacks were constructed. Also, the Three Phase Separator’s emissions are viewed as part of the two Vertical Emulsion Heater Treaters per the Certification of Construction.
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 also required to route all vented gas emissions from 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 (m^3) 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 m^3 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 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-007 through AA-012) 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 60, Subpart OOOOa
This subpart applies to the owners and operators of any of a list of onshore affected facilities which were constructed after September 18, 2015. The facility completed construction on March 4, 2015; therefore, the facility is not subject to Subpart OOOOa.
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.
PUBLIC PARTICIPATION
The 30-day public notice period began on October 29, 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.

65733 PER20160001