PUBLIC NOTICE DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Slater Smith 			Date:	October 24, 2018

Company Name:	Petro Hunt LLC, Seale et al Number 1 Tank Battery

Facility Location:	Wagon Wheel Road
Meadville, MS 39653

Coordinates:		N 31° 26’ 01”
			W 90° 56’ 53”

Source Number:	0820-00029

County: 		Franklin

FACITITY DESCRIPTION
Petro Hunt LLC, Seale et al Number 1 Tank Battery (Petro Hunt) is requesting an Air Construction Permit for a proposed crude oil production facility. The proposed facility is located in rural Franklin County, and Image 1 demonstrates that Petro Hunt will be in compliance with 11 Miss. Admin. Code Pt. 2, R. 2.2.B(14)., which establishes buffer zones for air emissions sources.
The well that will supply crude oil to the facility is identified as the Seale et al Number 1 Tank Battery. The facility is a typical petroleum production site with the equipment necessary for the separation of oil, gas, and water produced by the wells. Oil and water are stored on site for sale and disposal, respectively.
	
Image 1. Proposed construction area of Petro Hunt LLC, Seale et al Number 1 Tank Battery
Latitude: 31° 26’ 01”
Longitude: 90° 56’ 53”	

PROJECT DESCRIPTION
The project will consist of one well on-site which will deliver a produced gas/oil/water mixture to the tank battery facility then a fired heater treater separator (Emission Point AA-003). From the heater treater, liquid phase materials are routed to their appropriate storage tanks (two 16,800 gallon oil storage tanks (Emission Point AA-004) and two 16,800 gallon produced water storage tanks (Emission Point AA-005)), and gases are routed to the flare (Emission Point AA-001), as seen in Image 2.
Petro Hunt has the potential to exceed the Title V threshold for Volatile Organic Compound (VOC) and Hazardous Air Pollutant (HAP) emissions; however, the facility will self-imposed restrictions on facility operations to limit VOC and HAP emissions, consistent with 11 Miss. Admin. Code, Pt. 2, Ch. 6. The facility will require that the flare is operated at all times while venting gas, all produced gas and storage tank emissions be routed to the flare to limit VOC and HAP emissions to minor source levels, and limit tank fugitive emissions so that NSPS Subpart OOOOa will not be applicable to the storage tanks. Emissions produced during truck loading (Emission Point AA-007) will vent to the atmosphere.

Image 2. Petro Hunt, LLC Seale et al Number 1 Tank Battery Process Flow Diagram
Emission Point AA-003a (Heater Treater Burner) is considered an Insignificant Activity per
11 Miss. Admin. Code Pt. 2, R.6.7.D(1).	

EMISSIONS SUMMARY
Table 1. Proposed Potential Emissions for Petro Hunt LLC, Seale et al Number 1 Tank Battery (tons per year)	
Permit Action	Issuance Year	PM	PM10	SO2	NOx	CO	VOC	Total HAPs	
Construction	2018	0.67	0.69	0.69	0.00	28.07	67.31	1.09	
Table 1 demonstrates that Petro Hunt’s proposed emissions with restrictions are well below all Title V thresholds of 100 tons per year (tpy). The facility is an Area source of HAPs because the facility does not have potential to emit 10 tpy of an individual HAP or 25 tpy of any combination of HAP emissions.
11 MISSISSIPPI ADMINISTRATION CODE PART 2, CHAPTER 1
The Control Flare and Heater Treater are natural gas combustion units, and are subject to state standards for particulate matter and sulfur dioxide. Since natural gas is a relatively clean burning fuels, the units will have a large margin of compliance and will not approach the State Standards for PM and SO2.
NEW SOURCE PERFORMANCE STANDARDS (NSPS)
Subpart Kb – Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
The subpart is not applicable because the crude oil and condensate storage tanks each have a volume less than 420,000 gallons prior to custody transfer.
Subpart KKK – Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants
The facility does operate equipment with VOC leaks; however, the facility is not subject to Subpart KKK because it does not meet the definition of a natural gas processing plant.
Subpart IIII – Standards of Performance for Stationary Compression Ignition Internal Combustion Engines
The subpart is not applicable because the facility will not utilize any compression engines.
Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines.
The subpart is not applicable because the facility will not utilize any spark ignition engines.
Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After August 23, 2011 and on or Before September 18, 2015
The facility is not subject to Subpart OOOO because construction will be commenced after August 23, 2011.
Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced After September 18, 2015
The site will be an affected facility for the collection of fugitive emissions components at a well site. Semiannual testing recordkeeping, and reporting is required. The facility will not operate any pneumatic devices or pumps. All oil storage tanks and water storage tanks will have potential emissions less than 6 tpy when considering the flare as a permitted control device; therefore, Subpart OOOOa is not applicable to any storage tank. No compressors are utilized at the site. The facility will not operate as a natural gas processing plant, and will not utilized an acid gas removal process.
The crude oil storage tanks located at the facility have the potential to be subject to Subpart OOOOa; however, since the emission from the crude oil storage tanks will be routed to the process flare for control, the tanks will be exempt from the applicable requirements of Subpart OOOOa. Petro Hunt will be an affected facility for the collection of fugitive emissions components at a well site; thus, the facility will conduct semiannual testing, recordkeeping, and reporting consistent with Subpart OOOOa.

NATIONAL EMISSION STANDARDS OF HAZARDOUS AIR POLLUTANTS (NESHAPs) AND/OR MAXIMUM ACHIEVIABLE CONTROL TECHNOLOGY (MACT)
The facility is an Area Source of Hazardous Air Pollutants (HAP) since the facility does not emit more than 25 tons per year of total HAPs nor 10 tpy of an individual HAP.
Subpart HH – National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities
The facility does not meet the criteria of 40 CFR Part 63.760(a)(3) since the facility will incinerate the produced gas. Petro Hunt will temporarily store hydrocarbon liquids produced by the well prior to transport offsite to market. However, the facility is an Area Source of HAP emissions, and the only potentially affected source would be a triethylene glycol (TEG) dehydration unit. There will be no TEG dehydration units at Petro Hunt; therefore, the facility is not subject to Subpart HH.
Subpart HHH – National Emissions Standards for Hazardous Air Pollutants from Nation Gas Transmission and Storage Facilities
Subpart HHH provides HAP emission limits for natural gas transmission and storage facilities that are Major Sources of HAP emissions. Petro Hunt is an Area Source of HAP emissions; therefore, the facility is not subject to Subpart HHH.
Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
There are no stationary reciprocating internal combustion engines located at the facility so Petro Hunt is not subject to Subpart ZZZZ.
COMPLIANCE ASSURACNE MONITORING (CAM)
Under 40 CFR Part 64, CAM facilities are required to prepare and submit monitoring plans for certain emission units with the Title V application. The Cam Plans provide an on-going and reasonable assurance of compliance with emission limits. Under the general applicability criteria, the regulation only applies to emission units that use a control device to achieve compliance with an emission limit and whose pre-controlled emission levels exceed the major source thresholds under the Title V permitting program. If it is determined that the flare is subject to CAM, then compliance with 40 CFR Part 60.18 has been determined to be presumptively acceptable for CAM. Since the flare is required due to the hydrogen sulfide content of the gas, CAM is not applicable to the flare.

PUBLIC PARTICIPATION

The 30-day public notice period began on October 31, 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.