INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
April 22, 2019

FOR:
Columbia Gulf Transmission Company, Inverness Compressor Station
4161 Four Mile Road
Humphreys County
  
FACILITY DESCRIPTION
Columbia Gulf Transmission owns and operates its Inverness Compressor Station located in Humphreys County for the purpose of transporting natural gas through its pipeline distribution system. Natural gas compression at the Inverness Compressor Station is accomplished through four (4) 4,800-HP natural gas-fired Cooper-Beesemer Model LSV-16SG 4SLB SI natural gas-fired compressor engines, one (1) 16,793-HP Solar Mars Model 100-T15005 natural gas-fired compressor turbine, and one (1) 21,916-HP Solar Titan Model 130-19500S natural gas-fired compressor turbine.  The station also operates one (1) 750-HP and one (1) 46-HP natural gas-fired emergency generator engine, as well as, one (1) 46-HP natural gas-fired emergency fire pump engine.  Other sources of emissions includes emissions from piping and equipment fugitive sources, as well as, insignificant activities.  This permitting action is to reissue the   Title V Operating Permit and will not trigger a Prevention of Significant Deterioration (PSD) Review.

TITLE V PROGRAM APPLICABILITY BASIS
The Inverness Compressor Station is a major source as defined by Title V of the Federal Clean Air Act due to its potential to emit more than 100 tons per year, each, of Carbon Monoxide (CO) and Nitrogen Oxides (NOx).   The facility also has the potential to emit more than 25 tons per year of total hazardous air pollutants (HAP) or more than 10 tons per year of an individual HAP, formaldehyde.  Therefore, the facility is classified as a Major Source with respect to HAP emissions.  Further, the facility has the potential to emit NOx and CO emissions above the 250 tpy PSD threshold; therefore, the facility is considered an existing Major Source for PSD purposes. 

LEGAL AND FACTUAL BASIS FOR DRAFT PERMIT CONDITIONS
The State and Federally-enforceable conditions of Title V Operating Permits are based upon the requirements of the State of Mississippi Air Emissions Operating Permit Regulations for the Purposes of Title V of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 6.), and applicable requirements effective upon the date of permit issuance.  Applicable requirement means all of the following as they apply to emissions units in a Title V source:

1.	any standard or other requirement set forth in the State Implementation Plan (SIP) approved or promulgated by EPA through rulemaking under Title I of the Federal Clean Air Act (Federal Act) including the following:

a.	most of the State of Mississippi Air Emission Regulations for the Prevention, Abatement, and Control of Air Contaminants (11 Miss. Admin. Code Pt. 2, Ch. 1.) 
b.	the State of Mississippi Regulations for the Prevention of Air Pollution Emergency Episodes (11 Miss. Admin. Code Pt. 2, Ch. 3.),
c.	the State of Mississippi Regulations for the Prevention of Significant Deterioration of Air Quality (11 Miss. Admin. Code Pt. 2, Ch. 5.), and 40 CFR Part 52.21 by reference, and
d.	the provisions of the State of Mississippi Permit Regulations for the Construction and/or Operation of Air Emissions Equipment (11 Miss. Admin. Code Pt. 2, Ch. 2.), relating to construction permits and synthetic minor operating permits;

2.	any term or condition of any construction permits issued pursuant to Mississippi regulations approved or promulgated through rulemaking under Title I;

3.	any standard or other requirement under Section 111 of the Federal Act, including Section 111(d) which includes Title 40, Part 60 of the Code of Federal Regulations (40 CFR Part 60) and relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.;

4.	any standard or other requirement under Section 112 of the Federal Act, including relevant sections of 11 Miss. Admin. Code Pt. 2, Ch. 1.and 40 CFR Parts 61, 63, and 68;

5.	any standard or other requirement of the acid rain program under Title IV of the Federal Act or the regulations promulgated thereunder, including the State of Mississippi Acid Rain Program Permit Regulations for Purposes of Title IV of the Federal Clean Air Act (11 Miss. Admin. Code Pt. 2, Ch. 7.)  adopted November 17, 1994, and 40 CFR Parts 72, 73, 75, 77, and 78;

6.	any requirements established pursuant to Section 504(b) or Section 114(a)(3) of the Federal Act;

7.	any standard or other requirement governing solid waste incineration under Section 129 of the Federal Act;

8.	any standard or other requirement for consumer and commercial products under Section 183(e) of the Federal Act;

9.	any standard or other requirement for tank vessels under Section 183(f) of the Federal Act;

10.	any standard or other requirement of the program to control air pollution from outer continental shelf sources under Section 328 of the Federal Act;

11.	any standard or other requirement of the regulations promulgated to protect stratospheric ozone under Title VI of the Federal Act;

12.	any national ambient air quality standard or increment or visibility requirement under part C of Title I of the Federal Act.

Each State and Federally-enforceable condition of the draft Title V Operating Permit references the specific relevant requirements of 11 Miss. Admin. Code Pt. 2, Ch. 6.or the applicable requirement upon which it is based. Any condition of the draft Title V permit that is enforceable by the State but is not Federally-enforceable is identified in the draft Title V permit as such.

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
There is no control equipment associated with any of the emission units subject to an emission limit or standard at this facility, therefore, Compliance Assure Monitoring does not apply to the Inverness Compressor Station.

MODIFICATIONS
During draft permit review, Columbia Gulf Transmission requested that performance stack testing be allowed in lieu of portable analyzer testing requirements for NOx and CO for Emission Points AA-011 and AA-012.  Therefore, the draft permit contains a provision to allow performance stack testing be allowed in lieu of portable analyzer testing.

Plant-wide fugitive emissions (Emission Point AA-013) have been included in the list of permitted emission points.

The state SO2 standard of 4.8 lbs/MMBTU had previously been identified as applicable to the compressor engines and emergency engines.  However, it has been determined that these types of units are not subject to this standard since the fuel is not primarily burned to produce heat or power by indirect heat transfer.  Therefore, the state SO2 standard is being removed from the Title V Permit.

The previous Title V permit contained a monitoring plan for Emission Points AA-011 and AA-012.  This monitoring plan has been included at the end of this document, even though the applicable requirements have been included in conditions of the permit.  Additionally, the previous Title V permit contained an option for utilizing a custom fuel monitoring plan in lieu of complying with Condition 5.B.4 of the Title V permit.  The option to utilize the custom fuel monitoring plan has been removed from this Title V permit.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is a Major Source of Hazardous Air Pollutants (HAP) since the facility has the potential to emit more than 25 tons per year of total HAPs and 10 tpy of formaldehyde.

40 CFR 63 Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
The Reciprocating Internal Combustion Engines (RICE) NESHAP, Subpart ZZZZ, regulates HAP emissions from RICE.

Emission Points AA-001 through AA-004 and AA-007 through AA-009, are subject to the National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE), 40 CFR Part 63, Subpart ZZZZ.

Emission Points AA-001 through AA-004 are existing non-emergency four stroke lean burn (4SLB) spark ignition (SI) stationary RICE, each with a site rating of more than 500 brake HP located at a major source of HAP emissions, and as such, are exempt from the requirements of 40 CFR 63, Subpart ZZZZ and the General Provisions in Subpart A.

Emission Points AA-007 and AA-009 are existing four stroke rich burn (4SRB) SI emergency stationary RICE with a site rating of less than 500 brake HP located at a major source of HAP emissions, and as such, are subject to the operational requirements of 40 CFR 63, Subpart ZZZZ and the applicable General Provisions in Subpart A.

Emission Point AA-008 is an existing 4SRB SI emergency stationary RICE with a site rating of greater than 500 brake HP located at a major source of HAP emissions, and as such, is subject only to the emergency operational requirements of 40 CFR 63, Subpart ZZZZ.

40 CFR 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters 
The facility does not operate any boilers or process heaters.  The facility does operate small insignificant space heaters which are not classified as process heaters per the definition of process heaters in 40 CFR 63.7575, and thus are not subject to the MACT.

40 CFR 63 Subpart HHH 
The NESHAP for Natural Gas Transmission and Storage Facilities establishes emission limitations and operating limitations for HAP emissions from glycol dehydrators from owners and operators of natural gas transmission and storage facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user, and that are major sources of HAP emissions.  The Inverness Compressor Station is a Major Source of HAP emissions but does not operate any glycol dehydrators; therefore, NESHAP HHH does not apply to the facility.

40 CFR 63 Subpart YYYY 
The NESHAP for Stationary Combustion Turbines establishes emission and operating limitations for HAP emissions from stationary combustion turbines located at a major source for HAPS.  The Inverness Compressor Station operates two (2) turbines.  Emission Point AA-011 is an existing source that was constructed prior to the effective date of January 14, 2003.   Therefore, Subpart YYYY is not applicable to Emission Point AA-011.  

Emission Point AA-012 was reconstructed after the effective date of January 14, 2003, and was only required to comply with the Initial Notification requirements of NESHAP YYYY but need not comply with any other requirement of NESHAP YYYY until EPA takes final action in the Federal Register.  The initial notification has been submitted for Emission Point AA-012.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 SUBPART Kb
NSPS Kb applies to each volatile organic liquid storage tank that is greater than 75 cubic meters (19,813 gallons) in capacity and that has been constructed, reconstructed, or modified after July 23, 1984. NSPS Kb is not applicable to any of the organic liquid storage tanks at the facility as none of the tanks are sized over 19,813 gallons.

40 CFR 60 SUBPART GG
The provisions of 40 CFR 60 Subpart GG - New Source Performance Standards for Stationary Gas Turbines are applicable to stationary gas turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 million Btu) per hour, based on the lower heating value of the fuel fired, that commenced construction, modification, or reconstruction after October 3, 1977.  The facility operates two (2) turbines.  Emission Point AA-011 is subject to the fuel sulfur requirements and NOx emission limitations of NSPS GG.   Emission Point AA-012 is subject to 40 CFR, Subpart KKKK and is therefore exempt from the requirements of NSPS GG.

40 CFR 60 SUBPART KKKK
The provisions of 40 CFR 60 Subpart KKKK - New Source Performance Standards for Stationary Combustion Turbines are applicable to stationary combustion turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 MMBtu) per hour, based on the higher heating value of the fuel, which commenced construction, modification, or reconstruction after February 18, 2005.  Emission Point AA-011 was constructed prior to the NSPS KKKK effective date and is therefore exempt from the requirements of NSPS KKKK.  Emission Point AA-012 was reconstructed in 2008, after the NSPS KKKK effective date, and is therefore subject to the fuel sulfur requirements and NOx emission limitations of NSPS KKKK.

40 CFR 60 Subpart IIII
The provisions of 40 CFR 60 Subpart IIII - New Source Performance Standards for Compression Ignition Internal Combustion Engines (NSPS IIII) are applicable to stationary compression ignition internal combustion engines that commenced construction, modification, or reconstruction after April 1, 2006.  The facility does not operate any stationary compression ignition internal combustion engines; therefore, no requirements of NSPS IIII are applicable to the facility.  

40 CFR 60 Subpart JJJJ
The provisions of 40 CFR 60 Subpart JJJJ - New Source Performance Standards for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ) are applicable to stationary spark ignition internal combustion engines that commenced construction, modification, or reconstruction after June 12, 2006.  Emission Points AA-001 through AA-004 and AA-007 through AA-009 are stationary spark ignition internal combustion engines; however, each engine has a construction date before the June 12, 2006, effective date.  Therefore, none of the engines are subject to any requirements of NSPS JJJJ.  

40 CFR 60 Subpart KKK
The provisions of 40 CFR 60, Subpart KKK - Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants (NSPS KKK) apply to affected facilities in onshore natural gas processing plants that commences construction, reconstruction, or modification after January 20, 1984, and on or before August 23, 2011.  Since the Inverness Compressor Station is not located at an onshore natural gas processing plant, as defined in 40 CFR 60.631, the Inverness Compressor Station is not subject to NSPS KKK.

40 CFR 60 Subpart OOOO
The provisions of 40 CFR 60, Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Production, Transmission and Distribution (NSPS OOOO) are potentially applicable to owners and operators of onshore affected facilities that commence construction, modification, or reconstruction after August 23, 2011.  The only potentially affected sources at the Inverness Compressor Station are the facility’s compressor engines and oil condensate storage vessel.  However, the compressor engines and storage vessel are not new and have not been modified or reconstructed after August 23, 2011; consequently, NSPS OOOO does not apply to the Inverness Compressor Station.
40 CFR 60 Subpart OOOOa
The provisions of 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 (NSPS OOOOa) are potentially applicable to new and modified sources in the oil and gas industry after August 18, 2015.  The only potentially affected sources at the Inverness Compressor Station are the facility’s compressor engines, with respect to Leak Detection and Repair (LDAR), and pneumatic controllers.  However, there have been no new compressors installed at the facility resulting in increased compression, nor has the facility modified any existing compressor engines or pneumatic controllers; consequently, NSPS OOOOa does not apply to the Inverness Compressor Station.
SPECIFIC APPLICABLE REQUIREMENTS
Emission Points AA-007 through AA-009 have a particulate matter emission limitation of 0.6 lbs/MMBTU, because they have a rated heat input less than 10 MMBTU/hr. Emission Points AA-001 through AA-004, AA-011, and AA-012, each have a rated heat input greater than 10 MMBTUH and thus are subject to a particulate matter limit of E=0.8808 * I-0.1667 where E is the emission rate in pounds per million BTU per hour heat input and I is the heat input in millions of BTU per hour.

Since the applicable regulations are state standards for combustion for PM and SO2, all the units should have a large margin of compliance.  The only fuel that is being used is natural gas, therefore, the only monitoring requirement is the recording of the type and quantity of fuel used.

Other requirements are tabularized below.

Emission Point(s)	Pollutant / Parameter	Limit/Standard	Monitoring Requirements	
AA-007
through
AA-009	PM	0.6 lbs/MMBTUH	Record Type and Quality of Fuel Used	
AA-001
through
AA-004,
AA-011,
and
AA-012	PM	E=0.8808*I-0.1667	Record Type and Quality of Fuel Used	
AA-011	SO2	≤ 0.8% sulfur by weight	Record Type and Quality of Fuel Used	
	NOx	Temperature > 0 °F: Full load 42 ppmvd @15% O2 and 21.4 lb/hr	
Performance Testing and Monitoring of operations	
		Temperature > 0 °F: Low load (< 50% load) 70 ppmvd @ 15% O2 and 24.8 lb/hr		
		Low Temperature (<0 °F): 42 ppmvd @ 15% O2 21.6 lb/hr		
		Startup/Shutdown: 9.5 lb/hr		
		209.8 tpy		
	CO	Temperature > 0 °F: Full load: 15.5 lb/hr		
		Temperature > 0 °F: Low load (< 50% load): 475.1 lb/hr		
		Low Temperature (<0 °F): 31.3 lb/hr		
		Startup/Shutdown: 190.4 lb/hr		
		150.0 tpy		
AA-012	SO2	0.060 lb SO2 /MMBTU (20 grains S/100scf	Record Type and Quality of Fuel Used	
	NOx	Temperature ≥ 0 °F: Full load: 42 ppmvd @15% O2 and 26.0 lb/hr	Performance Testing and Monitoring of operations	
		Temperature ≥ 0 °F: Low load (< 50% load): 70 ppmvd @ 15% O2 and 30.2 lb/hr		
		Low Temperature (< 0 °F): 42 ppmvd @ 15% O2 and 26.3 lb/hr		
		Startup/Shutdown: 10.7 lb/hr		
		99.6 tpy		
	CO	Temperature ≥ 0 °F: Full load: 18.8 lb/hr		
		Temperature ≥ 0 °F: Low load  (< 50% load): 577.4 lb/hr		
		Low Temperature (< 0 °F): 38.1 lb/hr		
		Startup/Shutdown: 211.9 lb/hr		
		143.3 tpy		
AA-007
and
AA-009	General
Operating
Conditions	Scheduled Maintenance Activities	Monitoring of operations	
		Operational Requirements		
		Continuous Compliance and Minimizing Emissions		
AA-007
through
AA-009	Hour Meter	Emergency Operational Requirements	Monitoring of operations	

Requirements	Specific Monitoring Provisions	
General Monitoring Approach	Emissions testing for NOx and CO combined with monitoring of T5 combustion zone temperature to document normal turbine operation.	
Testing & Monitoring Methods	•	Referenced method testing to document compliance with NOx and CO limits at full load and to record T5 values during testing (actual T5 to be within 75F of design level).
•	Annual emission testing for NOx and CO using portable emissions analyzer; record T5 temperature during testing.
•	Continuous monitoring of T5 combustion zone temperature reported by turbine control panel.	
Indicator Range	•	Audible alarm if T5 exceeds design level by >10F for 10 seconds.
•	Automatic shutdown if T5 exceeds design level by > 20F for 20 seconds.	
Data Collection Agency	Continuous monitoring of T5 temperature; record date and time of any automatic turbine shutdowns due to T5 over-temperature conditions.	
Averaging Period	None.	
Recordkeeping	Records of testing, QA/QC, and over-temperature shutdowns to be retained for 5 years.	
Reporting	•	Submit reference method and portable analyzer test results to MDEQ within 60 days after testing.
•	Documentation of over-temperature shutdowns to be included in semi-annual monitoring report.	
QA/QC	•	Reference method and portable emissions analyzer testing to be conducted in accordance with test protocol detailing QA/QC to be used during testing and subject to approval by MDEQ.
•	Thermocouples will be checked for proper calibration annually.	
“T5” – thermocouples which measures the inlet temperature into the power turbine. Since it is not possible to measure the combustor temperature directly due to the extremely high temperatures, measuring T5 and using a complex mathematical algorithm to obtain the combustor temperature is industry standard. As combustor zone temperature (measured by T5) is a critical parameter to maintaining low emissions and meeting its low emissions guarantees, the design T5 temperature is set at 1,360F for the Mars turbine and 1,400F for the Titan turbine. All of the full-load testing occurred at T5 values within 50F of the design temperature.