INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
September 2020

FOR:
Gulf LNG Energy, LLC
LNG Clean Energy Project
125 Industrial Road
Pascagoula, MS 39567
    Jackson County

FACILITY DESCRIPTION
Gulf LNG Energy, LLC is a Liquefied Natural Gas (LNG) import terminal located in Pascagoula, Mississippi (Jackson County).  The facility’s operations fall within SIC Code 4922, Natural Gas Transmission and NAICS Code 486210, Pipeline Transportation of Natural Gas. A Permit to Construct was issued for the facility on February 9, 2007 and the initial Title V Operating Permit was issued on January 9, 2014.  LNG received at the site is stored and passed through one of ten different vaporizers that heat the LNG and convert it into a gas which is then transferred to a pipeline and passed into the distribution system.  There is a heater for re-gasifying LNG and venting it to the atmosphere from the two main LNG storage vessels and related equipment during operational upsets and other equipment used to provide emergency support should the facility lose power.   A detailed list of the permitted emission sources is included in the table below.

Emission Point	Description	
AA-001 through AA-010	Ten (10) natural gas-fired, submerged combustion vaporizers rated at 95.6 MMBtu/hr each, which are used for heating Liquefied Natural Gas (LNG) to change it from liquid to gas phase.	
AA-011	12.13 MMBtu/hr natural gas-fired heater for re-gasifying LNG and venting it to the atmosphere from the two (2) main LNG storage vessels and related equipment during operational upsets.	
AA-012 and AA-013	Two (2) natural gas-fired turbines rated at 142.4 MMBTUH (20,500 hp) each used for supplying back-up electrical power to the facility.	
AA-014	5.1 MMBTUH (755 hp) diesel-fired emergency generator for providing electrical power to start the turbines and maintain other systems in the event of electrical power loss with an associated 300 gallon diesel storage tank.	
AA-015	4.3 MMBTUH (610 hp) diesel-fired fire water pump located within the facility with an associated 700 gallon diesel storage tank.	
AA-016	4.1 MMBTUH (665 hp) diesel-fired fire water pump located on the jetty with an associated 700 gallon diesel storage tank.	
AA-017	1.7 MMBTUH (300 hp) diesel-fired emergency air compressor for supplying compressed air to the facility when the main air supply is non-operational with an associated 140 gallon diesel storage tank.	

TITLE V SOURCE APPLICABILITY 
The facility’s potential-to-emit exceeds the Title V major source threshold of 100 tons per year (tpy) for each of the following criteria air pollutants: Carbon Monoxide (CO) and Nitrogen Oxides (NOX).
 
The facility’s potential-to-emit hazardous air pollutants (HAP) does not exceed the major source thresholds of 25 tpy of total HAP and 10 tpy for any individual HAP since the facility has taken restrictions on hours of operation of the fuel burning equipment. 

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(c)(iii); therefore, the PSD threshold for a major source is 250 tpy.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no modifications to the facility or other significant permit changes proposed as part of this permitting action. 

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

Although the facility has equipment that is subject to emissions limits or emission standards, no unit has pre-control emissions exceeding the major source thresholds, and no unit uses a control device to comply with an emission limit or standard.  Therefore, CAM does not apply to any unit at this facility.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

•	40 CFR 63, Subpart ZZZZ, NESHAP for Stationary Reciprocating Internal Combustion Engines (RICE) – The provisions of Subpart ZZZZ are applicable to stationary reciprocating internal combustion engines located area and major sources of HAP emissions.  The facility is an area source of HAP and has four engines that are subject to the provisions of Subpart ZZZZ. The engines will comply with Subpart ZZZZ by complying with the applicable provisions of 40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition Internal Combustion Engines.
  
•	40 CFR 63, Subpart HH, NESHAP for Oil and Natural Gas Production Facilities – The provisions of Subpart HH are applicable to the emission points that are located at oil and natural gas production facilities.  This subpart is not applicable since the site does not produce oil or natural gas and does not operate a glycol dehydration unit.

•	40 CFR 63, Subpart HHH, NESHAP for Natural Gas Transmission and Storage Facilities – The provisions of Subpart HHH are applicable to natural gas transmission and storage facilities that transport or store natural gas prior to entering a pipeline and that are major sources of HAP.  This subpart is not applicable since the site is an area source of HAP.

•	40 CFR 63, Subpart YYYY, NESHAP for Stationary Combustion Turbines – The provisions of Subpart YYYY are applicable to stationary combustion turbines located at major sources of HAP.  This subpart is not applicable to the site operations and equipment since the site is an area source of HAP.

•	40 CFR 63, Subpart JJJJJJ, NESHAP for Industrial, Commercial, and Institutional Boilers at Area Sources – The provisions of Subpart JJJJJJ are applicable to Industrial, Commercial, and Instituational Boilers at area sources that burn coal, oil, or biomass as fuel.  This subpart is not applicable to site operations and equipment since the site only combusts natural gas.  In addition, process heaters and waste heat boilers are excluded from the definition of boiler for Subpart JJJJJJ.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

•	40 CFR 60, Subpart Dc, Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units – The provisions of Subpart Dc are applicable to steam generating units for which construction commences after June 9, 1989, and has a maximum design heat input capacity of 100 MMBtu/hr or less, but greater than or equal to 10 MMBtu/hr.  Emission Point AA-011 is a natural gas fired unit that was constructed after this date and has a maximum design heat input capacity of 12.13 MMBtu/hr; therefore the unit is subject to Subpart Dc.  However, since this unit is fired by natural gas, the only applicable requirement is to monitor and record fuel usage.

Emission Points AA-001 through AA-010 are not believed to be subject to Subpart Dc.  Submersible combustion vaporizers are not considered “steam generating units” under the EPA policy (memo by Bruce Jordan).  The memo states that devices which combust fuel and transfer heat from the combustion gases to a heat transfer medium directly are not considered steam generating units for Subpart Dc applicability.  Since in the vaporizers the combustion products are directly mixed with the water bath and no barrier separates the media being heated from the heat source, Subpart Dc is not applicable in this case.

•	40 CFR 60, Subpart GG, Standards of Performance for Stationary Gas Turbines – The provisions of Subpart GG are applicable to stationary gas turbines with a heat input at peak load equal to or greater than 10 MMBtu/hr and that were constructed after October 3, 1977.  Emission Points AA-012 and AA-013 meet the applicability criteria; however, they were constructed after February 18, 2005, and are subject to the provisions of 40 CFR 60, Subpart KKKK.  Per 40 CFR 60.4305 of Subpart KKKK, these turbines are exempt from the requirements of Subpart GG.

•	40 CFR 60, Subpart IIII, Standards of Performance for Stationary Compression Ignition (CI) Internal Combustion Engines – The provisions of Subpart IIII are applicable to stationary CI engines that commenced construction after July 11, 2005, where the engine is manufactured after April 1, 2006, (not a fire pump engine) or manufactured as a certified National Fire Protection Association (NFPA) fire pump engine after July 1, 2006.  Emission Points AA-014 through AA-017, are emergency diesel engines that are considered new units and shall comply with the applicable requirements of Subpart IIII.

•	40 CFR 60, Subpart KKKK, Standards of Performance for Stationary Combustion Turbines – The provisions of Subpart KKKK are applicable to stationary combustion turbines with a heat input at peak load equal to or greater than 10 MMBtu/hr and that commenced construction after February 18, 2005. Emission Points AA-012 and AA-013 are subject to and shall comply with the applicable requirements of Subpart KKKK.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001 through AA-013	PM/PM10 (filterable)	E=0.8808*I-0.1667	The margin of compliance is significant and warrants no additional monitoring	
AA-001 through AA-010	NOx

CO	3.7 lbs/hr and 16.3 tons/yer (per unit)

3.0 lbs/hr and 13.1 tons/yr (per unit)
	The permittee is required to stack test to demonstrate compliance once every five years
Monitor and record the hours of operation.	
AA-011	PM
SO2	Fuel Limitation	Record the amount of fuel combusted on a monthly basis.	
AA-012 AA-013	NOx

CO

Hours of Operation	14.2 lbs/hr and 7.1 tons/yr (per unit)

17.2 lbs/hr and 8.6 tons/yr (per unit)

≤ 1,000 hours/year (per unit)	Monitor and record the hours of operation. 	
	SO2	≤ 0.060 lb SO2/MMBtu	Monitor, record and maintain records of fuel sulfur content	
AA-014 through AA-017	PM/PM10	0.6 lbs/MMBtu	The margin of compliance is significant and warrants no additional monitoring	
	Hours of Operation	≤ 1,000 hours/year (per unit)	Monitor and record the hours of operation	
AA-014	NMHC+NOx
CO 
PM (filterable only)	≤ 6.4 g/kW-hr
≤ 3.5 g/kW-hr
≤ 0.2 g/kW-hr	Certified engine documentation	
AA-017	NMHC+NOx
CO 
PM (filterable only)	≤ 4.0 g/kW-hr
≤ 3.5 g/kW-hr
≤ 0.2 g/kW-hr	Certified engine documentation	
AA-014 and AA-017	Opacity	Operating and maintenance requirements	Monitor and record operating hours for emergency units and general recordkeeping requirements	
AA-015 and AA-016	NMHC+NOx
CO 
PM (filterable only)	≤ 4.0 g/kW-hr
≤ 3.5 g/kW-hr
≤ 0.2 g/kW-hr	Certified engine documentation