INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
November 24, 2021

GENERAL FACILITY INFORMATION
Facility Name:  Trunkline Gas Company, LLC, Independence Compressor Station
Facility Address:  8354 Highway 305, Coldwater, MS 38618    
County: Tate
SIC Code(s): 4922
NAICS Code(s): 486210  

APPLICATION SUMMARY 
Permit No.: 2600-00025
Permit Action:  Renewal
Permit Folder: PER20210001
Application Receipt Date: August 24, 2021
Application Deemed Complete: Yes
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): A, ZZZZ
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
Trunkline Gas Company owns and operates its Independence Compressor Station located at 8354 Highway 305, in Coldwater, Mississippi (Tate County) for the purpose of transporting natural gas through its pipeline distribution system. Natural gas compression at the Independence Compressor Station is accomplished through eight (8) natural gas-fired compressor engines: four (4) engines rated at 2,000-HP each, three (3) engines rated at 3,000-HP each, and one (1) engine rated at 10,000-HP.  The station also operates two (2) natural gas-fired emergency generator engines: one (1) engine rated at 530-HP and one (1) engine rated at 51-HP.  Other sources of emissions includes three (3) 1.5 MMBTU/hr natural gas-fired boilers, two (2) 0.225 MMBTU/hr natural gas-fired tube heaters, fugitive emissions from piping and equipment, emissions from truck loading activities, liquid product storage tanks, as well as, insignificant activities.

TITLE V SOURCE APPLICABILITY 
The facility’s potential-to-emit (PTE) exceeds the Title V major source threshold of 100 tons per year (tpy) for Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Volatile Organic Compounds (VOC).  The facility’s potential-to-emit hazardous air pollutants (HAPs) also exceeds the major source threshold of 25 tpy of total HAPs and 10 tpy for the individual HAP, formaldehyde.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	35.37	
PM10	35.37	
PM2.5	35.37	
Sulfur Dioxide (SO2)	0.58	
Nitrogen Oxides (NOx)	4863.37	
Carbon Monoxide (CO)	248.17	
Volatile Organic Compounds (VOC)	133.96	
Total Reduced Sulfur (TRS)	0	
Lead	0	
CFC/HCFC	0	
Total HAP 	74.23	
Formaldehyde	52.41	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The potential emissions of NOx from the existing equipment at the compressor station exceed 250 tpy and hence the facility is considered as an existing major source for PSD purposes. This permitting action is to renew the Title V Operating permit and as such does not change the PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The facility submitted a 502(b)10 modification in November 2021 for the replacement of Emission Point AA-026 (40 HP emergency generator engine) with Emission Point AA-028 (51 HP emergency generator engine).  There are no other physical 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.

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.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR 63 Subpart ZZZZ
The Reciprocating Internal Combustion Engines (RICE) NESHAP, Subpart ZZZZ, regulates HAP emissions from RICE. Emission Points AA-001 through AA-008 are considered “Existing” units, because they all were constructed prior to December 19, 2002.  

Emission Points AA-001 through AA-004 and AA-008 are existing spark ignition two stroke lean burn  (2SLB) stationary RICE with a site rating of more than 500 HP located at a major source of HAPs. As such, these emission points do not have to meet the requirements of Subparts A and ZZZZ.  Emission Points AA-005 through AA-007 are existing spark ignition four stroke lean burn (4SLB) stationary RICE with a site rating of more than 500 HP located at a major source of HAPs. As such, these emission points do not have to meet the requirements of Subparts A and ZZZZ.  Emission Point AA-018 is a new 4SLB stationary emergency RICE with a site rating of more than 500 HP and is located at a major source of HAPs.  As such, this source is only subject to the emergency operational requirements of Subpart ZZZZ. Emission Point AA-028 is a new four stroke rich burn (4SRB) stationary emergency RICE with a site rating of less than 500 HP and is located at a major source of HAPs.  As such, this source must comply with NESHAP ZZZZ by meeting the requirements of 40 CFR 60, Subpart JJJJ.  

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

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-008 and AA-018 are stationary spark ignition internal combustion engines but were constructed prior to the NSPS JJJJ effective date; therefore, these engines are not subject to the provisions of NSPS JJJJ.   Emission Point AA-028 was manufactured after January 1, 2011. As such, this source is subject to the applicable requirements of NSPS JJJJ.  

40 CFR 60 SUBPART OOOO
The provisions of 40 CFR 60 Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification, or Reconstruction Commenced After August 23, 2011, and on or Before September 18, 2015 establishes emission standards and compliance schedules for the control of volatile organic compounds (VOC) and sulfur dioxide (SO2) emissions from affected facilities in the Crude Oil and Natural Gas Production source category that commence construction, modification, or reconstruction after August 23, 2011, and on or Before September 18, 2015.  The facility was constructed prior to the NSPS OOOO effective date; therefore, the facility is not subject to the provisions of NSPS OOOO.

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 establishes emission standards and compliance schedules for the control of volatile organic compounds (VOC) and sulfur dioxide (SO2) emissions from affected facilities in the Crude Oil and Natural Gas Production source category that commence construction, modification, or reconstruction after September 18, 2015.  The facility was constructed prior to the NSPS OOOOa effective date; therefore, the facility is not subject to the provisions of NSPS OOOOa.

SPECIFIC APPLICABLE REQUIREMENTS
The fifteen (15) significant air emission combustion sources are subject to state standards for PM and Opacity. Emission Points AA-018 through AA-023 and AA-028 each have a particulate matter emission limitation of 0.6 lbs/MMBTU, because each has a rated heat input less than 10 MMBTU/hr. Emission Points AA-001 through AA-008 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.  The only fuel that is being used 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 recordkeeping of the type and quantity of fuel used.

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001 through AA-008,
AA-018 through AA-023, and
AA-028	Opacity	40% Opacity	Record Type of Fuel Used	
AA-001
through
AA-008	PM	E = 0.8808 * I -0.1667	Record Type and Quantify of Fuel Used	
AA-018 through AA-023 and
AA-028	PM	0.6 lb/MMBTU	Record Type and Quantify of Fuel Used	
AA-019 through AA-023	SO2	4.8 lbs/MMBTU	Record Type and Quantify of Fuel Used	
	HAP	Operational Requirements	Conduct five year tune-ups	
AA-028	HC + NOx and CO	Operational Requirements	Monitoring of operations	
AA-018 and
AA-028	Operations	Emergency Operational Requirements	Monitoring of operations	

OTHER REQUIREMENTS:  N/A