INFORMATION RELATIVE TO
THE DRAFT TITLE V OPERATING PERMIT
May 4, 2020

FOR:
Southern Natural Gas Company LLC, Louisville Compressor Station
700 Metts Street
Louisville, Mississippi

FACILITY DESCRIPTION
Southern Natural Gas Company owns and operates its Louisville Compressor Station located at 700 Metts Street in Louisville, Mississippi, for the purpose of transporting natural gas through its pipeline distribution system. Natural Gas compression at the Louisville Compressor Station is accomplished through sixteen (16) compressor engines.  Six (6) compressor engines (Emission Points AA-001 through AA-006) each have a capacity of 800-HP, four (4) compressor engines (Emission Points AA-007 through AA-010) each have a capacity of 1,000-HP, and six (6) compressor engines (Emission Points AA-011 through AA-016) each have a capacity of 1,350-HP.  All combustion equipment fires only pipeline quality natural gas. In addition to compressor engines, the Louisville Compressor Station operates two (2) emergency backup power generator engines, Emission Point AA-017 rated at 275-HP and Emission Point AA-018 rated at 500-HP, to generate power for the facility during emergencies. The Louisville Station also has one (1) 3.0 MMBTU boiler (Emission Point AA-019), truck loading operations, equipment blow down and fugitive sources from piping and equipment, and emissions from insignificant activities. 

TITLE V SOURCE APPLICABILITY
The Louisville 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 (tpy) of each of the following criteria air pollutants: nitrogen oxides (NOx), carbon monoxide (CO), and volatile organic compounds (VOC). In addition, the facility has the potential to emit more than 25 tpy of total hazardous air pollutants (HAP) and more than 10 tpy of the HAP, formaldehyde, as well as more than 100,000 tons per year of greenhouse gasses. 

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The state SO2 standard of 4.8 lbs/MMBTU had previously been identified as applicable to the 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 these sources.  The state SO2 standard is applicable to Emission Point AA-016.

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.  The facility has the potential to emit NOx, CO, and VOC greater than 250 tpy; therefore, the facility is considered an existing major source for PSD purposes.  This permitting action will not change the current PSD status of the facility.  The compressor engines (AA-001 through AA-016) are considered “Grandfathered Sources”.

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.

There is no control equipment associated with any emission units subject to an emission limit or standard at this facility, so Compliance Assurance Monitoring does not apply.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 SUBPART GG
The provisions of 40 CFR 60 Subpart GG - New Source Performance Standards for Stationary Gas Turbines (NSPS GG) are applicable to stationary gas turbines with a heat input at peak load equal to or greater than 10 MMBTU/hr, which commenced construction, modification, or reconstruction after October 3, 1977.  The facility does not operate any stationary combustion turbines; therefore, the facility is not subject to NSPS GG.  

40 CFR 60 SUBPART KKKK
The provisions of 40 CFR 60 Subpart KKKK - New Source Performance Standards for Stationary Combustion Turbines (NSPS KKKK) 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.  The facility does not operate any stationary combustion turbines; therefore, the facility is not subject to NSPS KKKK.   

40 CFR 60 SUBPART IIII
The provisions of 40 CFR 60 Subpart IIII - New Source Performance Standards for Stationary Compression Ignition Internal Combustion Engines (NSPS IIII) are applicable to stationary compression ignition internal combustion engines that commenced construction, modification, or reconstruction after June 12, 2006.  Emission Points AA-001 through AA-018 are stationary spark ignition internal combustion engines.  Therefore, NSPS IIII is not applicable to the engines.  

40 CFR 60 SUBPART JJJJ
The provisions of 40 CFR 60 Subpart JJJJ - New Source Performance Standards for Stationary Spark Ignition Internal Combustion Engines 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-018 were each constructed prior to the affected date of June 12, 2006.   Therefore, NSPS JJJJ is not applicable to the engines.  

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 are applicable to the collection of fugitive emissions components at an affected compressor station.  However, the compressor station was installed prior to the September 18, 2015, affected date.  Further, the compressor station has not undergone modification that would trigger the NSPS.  Therefore, NSPS OOOOa is not applicable to the compressor station.  

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 an individual HAP, formaldehyde.

40 CFR 63 Subpart YYYY - National Emission Standards for Hazardous Air Pollutants for Stationary Combustion Turbines
The NESHAP for Stationary Combustion Turbines establishes national emission limitations and operating limitations for HAP emissions from stationary combustion turbines located at major sources of HAP emissions, and requirements to demonstrate initial and continuous compliance with the emission and operating limitations.  The facility does not operate any stationary combustion turbines; therefore, the facility is not subject to NESHAP YYYY.   

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-016 are existing spark ignition 2 stroke lean burn (2SLB) stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions and as such are not required to meet the requirements of 40 CFR Part 63, Subpart ZZZZ or the General Provisions in Subpart A.

Emission Points AA-017 and AA-018 are existing emergency SI stationary RICE with a site rating of less than or equal to 500 brake HP located at a major source of HAP emissions.  As such, the emergency engines must meet the maintenance and emergency operational requirements of Subpart ZZZZ.  No further requirements apply for such engines under 40 CFR 63 Subparts ZZZZ or A, other than recordkeeping and reporting.

40 CFR 63 Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters 
Since the compressor station is a “Major” source of Hazardous Air Pollutant (HAP) emissions, the facility is potentially subject to 40 CFR 63, Subpart DDDDD.  The facility has several insignificant space heaters and water heaters.  However, space heaters are not process heaters per the definition of process heaters in 40 CFR 63.7575, and thus are not subject to the MACT.   However, the 3.0 MMBTUH boiler (Emission Point AA-019) qualifies as boiler with a heat input capacity of less than 5 million Btu per hour, designed to burn natural gas.  The facility is required to conduct a tune-up of the boiler every five years.  Additionally, the unit was required to conduct a one-time energy assessment performed by a qualified energy assessor, which was completed on June 8, 2015.

SPECIFIC APPLICABLE REQUIREMENTS
The significant air emission combustion sources are subject to state standards for PM and Opacity. Emission Points AA-017 through AA-019 have a particulate matter emission limitation of 0.6 lbs/MMBTU, because each unit has a rated heat input less than 10 MMBTU/hr. Emission Points AA-001 through AA-016 each have a rated heat input greater than 10 MMBTU/hr 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.  Emission Point AA-019 is subject to an SO2 limit of 4.8 lbs/MMBTU. 

The only fuel that is being used for the compressor engines, boiler, and the emergency backup generator engines is natural gas.  Since natural gas is a clean burning fuel, these units should have a large margin of compliance with the PM and Opacity standards. Therefore, the only monitoring requirement is the recording of the type of fuel used. 

The facility’s small comfort space heaters qualify as insignificant activities.  These activities are subject to the state standards for PM, SO2 and Opacity.  Since these units combust natural gas and the size of the units are small, no monitoring is proposed for the units.  There are no other applicable requirements for the facility’s other insignificant activities listed in their Title V application.

Other requirements are tabularized below.

Emission Point(s)	Pollutant/ Parameter	Limit/Standard	Monitoring Requirements	
AA-001 through AA-016	PM	E=0.8808*I -0.1667	Record Type and Quality of Fuel Used	
AA-017 through AA-019	PM	0.6 lb/MMBTU	Record Type and Quality of Fuel Used	
AA-001 through AA-019	Operational Restriction	Combust natural gas only	Record Type and Quality of Fuel Used	
AA-017
and
AA-018	Operational Restriction	Must operate a non-resettable hour meter	Monitoring of operations	
	Operational Restriction	Scheduled Maintenance Activities	Monitoring of operations	
	HAPs	Emergency Operations	Monitoring of operations	
AA-019	SO2	4.8 lb/MMBTU	Record Type and Quality of Fuel Used	
	HAPs	Perform Tune-ups every 5-years	Monitoring of operations