INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
June 19, 2022

GENERAL FACILITY INFORMATION
Facility Name: Tennessee Gas Pipeline Company LLC, Purvis Compressor Station Number 534
Facility Address:  560 Pumping Station Road, Purvis, MS 39475    
County: Forrest
SIC Code(s): 4922
NAICS Code(s): 486210  

APPLICATION SUMMARY 
Permit No.: 0800-00023
Permit Action:  Renewal
Permit Folder: PER20210002
Application Receipt Date: November 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
Tennessee Gas Pipeline Company owns and operates its Purvis Compressor Station located at 560 Pumping Station Road, in Purvis, Mississippi (Forrest County) for the purpose of transporting natural gas through its pipeline distribution system. Natural gas compression at the Purvis Compressor Station is accomplished through seven (7) compressor engines, five (5) engines rated at 3,000 Horsepower (HP) and two (2) engines rated at 5,500 HP. The station also operates one (1) natural gas-fired emergency generator engine rated at 377-HP.  Other sources of emissions include, blowdown activities, fugitive emissions from piping and equipment, liquid product storage tanks, as well as other sources qualifying as insignificant activities.

Emission Point	Description	
AA-002	3,000 Horsepower (HP) (30.27 MMBtu/hr) Cooper Bessemer Model LSV-12 natural gas-fired four stroke lean burn (4SLB) spark ignition (SI) compressor engine (Ref. No. ENG PT-1A)	
AA-003	3,000 HP (30.27 MMBtu/hr) Cooper Bessemer Model LSV-12 natural gas-fired 4SLB SI compressor engine (Ref. No. ENG PT-2A)	
AA-004	3,000 HP (30.27 MMBtu/hr) Cooper Bessemer Model LSV-12 natural gas-fired 4SLB SI compressor engine (Ref. No. ENG PT-3A)	
AA-005	3,000 HP (30.27 MMBtu/hr) Cooper Bessemer Model LSV-12 natural gas-fired 4SLB SI compressor engine (Ref. No. ENG PT-4A)	
AA-006	3,000 HP (30.27 MMBtu/hr) Cooper Bessemer Model LSV-12 natural gas-fired 4SLB SI compressor engine (Ref. No. ENG PT-5A)	
AA-007	5,500 HP (64.74 MMBtu/hr) Cooper Bessemer Model 16V-250 natural gas-fired two stroke lean burn (2SLB) SI compressor engine (Ref. No. ENG PT-6A)	
AA-008	5,500 HP (64.74 MMBtu/hr) Cooper Bessemer Model 16V-250 natural gas-fired 2SLB SI compressor engine (Ref. No. ENG PT-7A)	
AA-009	377 HP (3.01 MMBtu/hr) Caterpillar Model G3480 natural gas-fired four stroke rich burn (4SRB) SI emergency generator engine (Ref. No. AUX1)	

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 each of the following criteria air pollutants: Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Volatile Organic Compounds (VOC)}.  The facility’s potential-to-emit hazardous air pollutants (HAPs) exceeds the Title V major source thresholds of 25 tpy of total HAPs and 10 tpy for the following individual HAPs – Acetaldehyde and Formaldehyde.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	69.70	
PM10	69.70	
PM2.5	69.70	
Sulfur Dioxide (SO2)	1.2	
Nitrogen Oxides (NOx)	6437.04	
Carbon Monoxide (CO)	568.46	
Volatile Organic Compounds (VOC)	210.21	
Total Reduced Sulfur (TRS)	0	
Lead	0	
CFC/HCFC	0	
Total HAP 	104.21	
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 and CO from the existing equipment at the compressor station exceed 250 tpy and hence the facility is considered 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
No physical modifications have occurred at the facility and no other significant permit changes are proposed as part of this permitting action, other than the items denoted below:

1.	Language has been included in the permit to require monitoring, recordkeeping, and reporting requirements for the emergency engine.

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, therefore, Compliance Assurance Monitoring does not apply to the Purvis 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, acetaldehyde and formaldehyde.

40 CFR 63 Subpart ZZZZ
The permittee is subject to Subpart ZZZZ—National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, and shall comply with all applicable requirements.    

Emission Points AA-002 through AA-008 are existing spark ignition 2SLB and 4SLB stationary RICE, each with a site rating greater than 500 brake HP located at a major source of HAP emissions and as such are not required to meet any requirements of 40 CFR Part 63, Subpart ZZZZ or the General Provisions in Subpart A.

Emission Point AA-009 is an existing spark ignition emergency stationary engine with a site rating less than 500 HP located at a major source of HAPs. As such, this emission point must meet the operational and scheduled maintenance requirements of 40 CFR 63, Subpart ZZZZ.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

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-002 through AA-009 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-002 through AA-009 are stationary spark ignition internal combustion engines that commenced construction prior to the June 12, 2006, effective date.  Therefore, these engines are not subject to any provisions of NSPS JJJJ.

SPECIFIC APPLICABLE REQUIREMENTS
The eight (8) significant air emission combustion sources are subject to state standards for PM and Opacity. Emission Point AA-009 has a particulate matter emission limitation of 0.6 lbs/MMBTU, because the source has a rated heat input less than 10 MMBTU/hr. Emission Points AA-002 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(s)	Pollutant/ Parameter	Limit/Standard	Monitoring Requirements	
AA-002
through
AA-008	PM	
E=0.8808*(I)-0.1667	Record Type and Quantify of Fuel Used	
AA-009	HAPs	Operating Requirement	Scheduled Maintenance Requirements	
	HAPs	Operating Requirement	Operational Requirements	
	PM	
0.6 lb/MMBTU	Record Type and Quantify of Fuel Used	
	Operational Restriction	Operational Requirement	Monitoring of operations	
	Operational Restriction	Emergency Operational Requirements	Monitoring of operations	

OTHER REQUIREMENTS:
None.