PERMIT REVIEW SUMMARY
Permit Writer:	Ryan Ozment 		Date:	March 11, 2019
Company Name:	Venture Oil and Gas Inc, Jernigan 6-10 No 1 Facility
Facility Location:	Well Road off of Smith County Road 1C
Source Number:	2500-00095
County: 		Smith
PROJECT DESCRIPTION
Venture Oil and Gas, Inc., has applied for the concurrent issuance of a Construction Permit and a Synthetic Minor Operating Permit for the Jernigan 6-10 No. 1 Facility. The Jernigan facility produces oil and natural gas and contains the following emission sources: the production wells, heater treater, separators, oil storage tanks, produced water storage tanks, a process control flare, and oil and produced water load-out operations. 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.  The facility is also an area source for hazardous air pollutants (HAPs) because the potential emissions are less than the major source threshold (>25 tons per year total, and >10 tons per year individual).
APPLICABLE/PROPOSED PERMIT 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.  The permittee is also required to route all vented gas emissions from the oil tanks, heater treater, and separators to the control flare (Emission Point AA-001). 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.
11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(b):  The maximum permissible emissions of PM from any fossil fuel burning installations greater than 10 MMBTU per hour heat input and less than 10,000 MMBTU per hour is determined by the relationship 
E = 0.8808 × I-0.1667
where E is the emission rate in pounds per MMBTU per hour heat input and I is the heat input in MMBTU per hour.
11 Miss. Admin. Code Pt. 2, R. 1.3.D(1)(a):  The maximum permissible emission of ash and/or PM from fossil fuel burning installations shall be limited to 0.6 pounds per MMBTU per hour heat input.
11 Miss. Admin. Code Pt. 2, R. 1.4.A(1):  The maximum discharge of sulfur oxides from any fuel burning installations where fuel is burned primarily for heat or power by indirect heat transfer shall not exceed 4.8 lbs (measured as sulfur dioxide) per MMBTU heat input.  
11 Miss. Admin. Code Pt. 2, R. 1.4.B(2):  The maximum emission of gas containing hydrogen sulfide (H2S) from any gas streams shall not exceed one grain per 100 standard cubic feet.  Gas streams containing H2S in excess of one grain per 100 standard cubic feet must be incinerated at temperatures of not less than 1600ºF.  
NSPS APPLICABILITY
40 CFR 60, Subpart Kb (Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984):  This subpart applies to storage vessels greater than 75 m3 that store volatile organic liquids constructed after July 1984.  There is an exemption listed in this subpart under 40 CFR 60.10b(d)(4) that reads “This subpart does not apply to… vessels with a design capacity less than 1,589.874 m3 used for petroleum or condensate stored, processed, or treated prior to custody transfer.  The 21,000-gallon crude oil storage tank meets this exemption and the other tanks are less than the 75 m3 threshold; therefore, Subpart Kb is not applicable.
40 CFR 60, Subpart KKK (Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011):  this subpart applies to particular sites constructed, reconstructed, or modified before 2011.  This is a greenfield site at the time of this permit issuance; therefore, it is being constructed after the applicability date and Subpart KKK is not applicable.
40 CFR 60, Subpart LLL (Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011):  this subpart applies to particular sites constructed, reconstructed, or modified before 2011.  This is a greenfield site at the time of this permit issuance; therefore, it is being constructed after the applicability date and Subpart LLL is not applicable.
40 CFR 60, Subpart IIII (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines):  this subpart applies to owners and operators of stationary compression ignition internal combustion engines manufactured after April 2006.  The engine proposed for the site will be a pre-2006 engine; therefore, it was manufactured before the applicability date and Subpart IIII is not applicable.
40 CFR 60, Subpart JJJJ (Standards of Performance for Stationary Compression Ignition Internal Combustion Engines):  this subpart applies to owners and operators of stationary spark ignition internal combustion engines manufactured after June 2006.  The engine proposed for the site will be a pre-2006 engine; therefore, it was manufactured before the applicability date and Subpart JJJJ 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):  this subpart is applicable to fugitive emissions components at well sites constructed after 2015; therefore, Subpart OOOOa is applicable.  Requirements under this subpart include:
•	Repair or replacement of sources of fugitive emissions within 30 days after detection of the fugitive emissions.
•	Development of an emission monitoring plan in accordance with the requirements outlined in the permit.
•	Initial compliance demonstration within one year of startup.
•	Continuous compliance demonstration periodically.
•	Annual reporting.
The crude oil storage tanks located at the facility have the potential to be subject to Subpart OOOOa; however, due to the fact that the emissions from the crude oil storage tanks are required to be sent to the process flare for control via this federally enforceable permit, the tanks are exempt from the applicable requirements of Subpart OOOOa.
MACT APPLICABILITY
40 CFR 63, Subpart HH (National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas production Facilities):  this subpart is applicable to oil and natural gas production facilities that are major and area sources of HAPs.  Area sources must own and operate a triethylene glycol (TEG) dehydration unit.  This facility will not operate a TEG dehydration unit; therefore, Subpart HH does not apply.
40 CFR 63, Subpart HHH (National Emission Standards for Hazardous Air Pollutants From Natural Gas Transmission and Storage Facilities):  this subpart applies to major sources of HAPs.  The facility has proposed taking limits to remain an area source; therefore, Subpart HHH does not apply.
PUBLIC PARTICIPATION
The 30-day public notice period began on April 2, 2019, with the publication of a notice in the Laurel Leader Call and ends May 2, 2019.
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.