PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry 	Date:	February 27, 2019

Company Name:	Venture Oil and Gas Inc, Kiewit 18-9 Number 1 Production Facility

Facility Location:	Oil Well Road
			Bay Springs, MS

Source Number:	1300-00076

County: 		Jasper

PROJECT DESCRIPTION

Venture Oil and Gas Inc (Venture), has applied for a modification to their existing Construction Permit and a True Minor Determination for the Kiewit 18-9 Number 1 Production Facility. The Kiewit 18-9 Number 1 Production facility is an oil and gas production facility containing the following emission points: one (1) heater treater, one (1) two phase separator, loadout operation, and five (5) storage tanks. All emissions from the storage tanks and field gas heater treater are routed to a control flare for combustion. 

The Kiewit 18-9 Number 1 Production Facility has shown a decline in oil and gas production over the years to the point that potential uncontrolled emissions for VOC and HAP have fallen below Title V thresholds. Therefore, it qualifies as a true minor source. The current oil and gas production rates are estimated at 88 bbls/day and 5.9 mscf/day respectively. While the facility has a sales line for natural gas located on site, it remains unused since early 2016 due to low gas production rates. 

The following emission points have been removed from the site: 0.5 MMBTU/hr Field Gas Line Heater (Emisison Point AA-001), 99 HP Diesel Generator (Emission Point AA-003), Two Phase Separator (Emission Point AA-006), and 1,000 Gallon Diesel Storage Tank (Emission Point AB-007). 

EMISSION SUMMARY

Parameter	Potential Uncontrolled	Potential Controlled	
PM	0.00	0.03	
PM10	0.02	0.04	
PM2.5	0.02	0.04	
VOC	75.85	7.98	
NOx	0.21	0.44	
CO	0.18	1.30	
SO2	0.00	0.06	
Total HAPs	5.38	0.42	

As demonstrated above, Venture’s potential, uncontrolled emissions fall under all Title V thresholds of 100 tons per year (tpy) for VOCs. The facility is an area source of HAPs due to the facilities potential to emit being under 10 tpy for any individual HAP, and 25 tpy for any combination of HAP emissions.

NSPS APPLICABILITY

Subpart Kb – Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
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 40 CFR 60.110b(d)(4), these vessels are exempt because they are “[v]essels with a design capacity less than or equal to 1589.874 m3 used for petroleum or condensate stored, processed, or treated prior to custody transfer.”; therefore, these emissions points are not subject to this Subpart Kb. 

Subpart OOOO – Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution
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. The storage vessels are potentially subject to this subpart. However, the facility will route all gas emissions from each storage vessel (Emission Points AB-001 through AB-005) to a control flare causing the annual potential VOC emissions from these vessels to be below 6 tons per year. As such, this facility is not subject to this subpart. 

MACT APPLICABILITY

Subpart HH – Oil and Natural Gas Production Facilities
The facility is defined as an oil production facility, operating as an Area source of HAPs. However, Area sources are only subject to Subpart HH if the facility operates a triethylene glycol (TEG) dehydration unit according to 40 CFR 63.760(b)(2). The facility is not subject to Subpart HH because it does not operate a TEG dehydration unit.

PUBLIC PARTICIPATION

The 30-day public notice period began on March 26th , with the publication of a notice in the Laurel Leader Call and ends April 25th.

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.