INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
April 28, 2023

GENERAL FACILITY INFORMATION
Facility Name:  Tennessee Gas Pipeline Company LLC, New Albany Compressor Station Number 851
Facility Address:  
1362 County Road 81
New Albany, MS 38652    
County: Union
SIC Code(s): 4922
NAICS Code(s): 486210  

APPLICATION SUMMARY 
Permit No.: 2700-00019
Permit Action:  Renewal without modification 
Permit Folder: PER20220001
Application Receipt Date: October 28, 2022
Application Deemed Complete: April 19, 2023
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, LLC owns and operates its New Albany Compressor Station located at 1362 County Road 81, New Albany, Mississippi, for the purpose of transporting natural gas through its pipeline distribution system.  The station consists of eight (8) natural gas fired compressor engines, one (1) natural gas fired emergency generator, and fugitive emissions from piping and equipment, natural gas blowdown, and storage tanks that qualify as insignificant activities. The following table lists the significant emission points at the facility.  The products of combustion from the combustion of natural gas in the facility’s compressor engines are the primary sources of pollutants, including VOC, NOx, CO, PM10/PM2.5, and HAPs.

Emission Point	Description	
AA-000	Facility Wide	
AA-001	800 HP Waukesha-Pierce four stroke lean burn (4SLB) spark ignition (SI) natural gas-fired emergency generator engine (Ref. AUX PT-1)	
AA-002	1,450 HP Clark Model TRA-8 two stroke lean burn (2SLB) SI natural gas-fired non-emergency compressor engine (Ref. ENG PT-1A)	
AA-003	1,450 HP Clark Model TRA-8 2SLB SI natural gas-fired non-emergency compressor engine (Ref. ENG PT-2A)	
AA-004	1,450 HP Clark Model TRA-8 2SLB SI natural gas-fired non-emergency compressor engine (Ref. ENG PT-3A)	
AA-005	1,450 HP Clark Model TRA-8 2SLB SI natural gas-fired non-emergency compressor engine (Ref. ENG PT-3A)	
AA-006	1,650 HP Clark Model HBA-6T 2SLB SI natural gas-fired non-emergency compressor engine (Ref. ENG PT-5A	
AA-007	2,050 HP Clark Model HBA-8T 2SLB v natural gas-fired non-emergency compressor engine (Ref. ENG PT-6A)	
AA-008	2,050 HP Clark Model HBA-8T 2SLB SI natural gas-fired non-emergency compressor engine (Ref. ENG PT-7A)	
AA-009	2,050 HP Clark Model HBA-8T 2SLB SI natural gas-fired non-emergency compressor engine (Ref. ENG PT-8A	

TITLE V SOURCE APPLICABILITY 
Tennessee Gas Pipeline Company, New Albany Compressor Station Number 851 is a major Title V source because the facility’s potential-to-emit exceeds the Title V threshold of 100 tons per year of Nitrogen Oxides, Carbon Monoxide, and Volatile Organic Compounds.  The facility’s potential-to-emit Hazardous Air Pollutants (HAPs) also exceeds the Title V threshold of 25 tons per year for total HAPs and 10 tons per year for a single HAP (Formaldehyde).

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	31.14	
PM10	41.44	
PM2.5	41.44	
Sulfur Dioxide (SO2)	0.05	
Nitrogen Oxides (NOx)	1582.82	
Carbon Monoxide (CO)	457.36	
Volatile Organic Compounds (VOC)	107.52	
Total Reduced Sulfur (TRS)	-	
Lead	-	
CFC/HCFC	-	
Total HAP 	57.35	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

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)(a); therefore, the PSD threshold for a major source is 250 tpy.  The potential emissions of NOx and CO from the existing equipment at the compressor station exceed the 250 tpy threshold and hence the facility is considered an "existing major source" for PSD permitting purposes. The facility is not proposing new construction or physical modifications with this Title V permit renewal application; thus, PSD review of this Title V permit renewal application is not required and is not addressed herein.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no proposed facility modifications in the draft permit. The changes to the current Title V permit include the following:
•	Emission Point AA-000 was redefined as facility wide to include all emission sources rather than only equipment fugitives.
•	New Condition 3.B.1 was added to restrict the fuel combusted facility wide to pipeline quality natural gas.
•	New Condition 3.B.2 was added to restrict hydrogen sulfide emissions facility wide. 
•	Conditions 3.B.4, 3.B.5 and 3.B.6 in the current permit were eliminated since the emergency generator engine, Emission Point AA-001, is not subject to the requirements referenced in these conditions per 40 CFR 63.6590(b)(1)(i).
•	New Condition 5.C.2 was added to require annual reporting of the hours of operation and the reason for operation for each instance that the emergency generator engine is operated.
•	The requirement in Condition 5.B.1 to monitor the type and quantity of fuel consumed was removed and replaced with the requirement to monitor the type and quality of fuel consumed. There is no permit limit or regulatory requirement which would make it necessary to monitor the quantity of fuel combusted. However, fuel type and quality would be indicators of compliance with state standards for particulate matter and sulfur dioxide.
•	The requirement in Condition 5.C.1 to report the type and quantity of fuel consumed was removed and replaced with the requirement to report the type and quality of fuel consumed.

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 Tennessee Gas Pipeline Company, New Albany Compressor Station Number 851.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
MACT Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, 40 CFR Part 63, Subpart ZZZZ 

40 CFR 63, Subpart ZZZZ establishes national emission limitations and operating limitations for hazardous air pollutants (HAP) emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. 

Emission Points AA-002 through AA-009 are existing stationary RICE that are two stroke lean burn (2SLB) units with a site rating of more than 500 brake horsepower.  Consequently, these units do not have any requirements for Subpart ZZZZ nor the General Provisions in Subpart A as specified in 40 CFR 63.6590(b)(3)(i).  

Emission Point AA-001 is a new emergency 4SLB stationary RICE with a site rating greater than 500 brake HP. Consequently, this unit does not have any requirements for Subpart ZZZZ nor the General Provisions in Subpart A as specified in 40 CFR 63.6590(b)(1)(i), except for the initial notification requirements which has been previously accomplished. However, this engine is required to meet the emergency operational requirements of 40 CFR 63.6640(f) in order to continue to be considered an emergency stationary RICE under Subpart ZZZZ.  

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
40 CFR 60 SUBPART GG
The provisions of 40 CFR 60 Subpart GG - Standards of Performance 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 MMBTUH, which commenced construction, modification, or reconstruction after October 3, 1977.  The New Albany Compressor Station does not operate any stationary combustion turbines; therefore, NSPS GG is not applicable to the facility.  

40 CFR 60 SUBPART KKKK
The provisions of 40 CFR 60 Subpart KKKK - Standards of Performance 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 New Albany Compressor Station does not operate any stationary combustion turbines; therefore, NSPS KKKK is not applicable to the facility.  

40 CFR 60 SUBPART IIII
The provisions of 40 CFR 60 Subpart IIII - Standards of Performance 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-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 - Standards of Performance 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-009 were each constructed prior to June 12, 2006, therefore NSPS JJJJ is not applicable to the engines.  

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.  However, the compressor station was installed prior to the August 23, 2011, affected date. Further, the New Albany Compressor Station has not undergone modification that would trigger the NSPS.  Therefore, NSPS OOOO is not applicable to the New Albany 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, 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 New Albany Compressor Station has not undergone modification that would trigger the NSPS.  Therefore, NSPS OOOOa is not applicable to the New Albany Compressor Station.  

SPECIFIC APPLICABLE REQUIREMENTS
The facility’s natural gas-fired sources, Emission points, AA-001 through AA-009, are subject to state standards for particulate matter and opacity.  Since natural gas is a clean burning fuel, the units should have a large margin of compliance with the PM and Opacity standards. All emission sources are restricted to pipeline quality natural gas. The only monitoring proposed for compliance demonstration for PM, H2S and Opacity for these units is recordkeeping by documenting the fuel type and quality. 

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-000	Fuel restriction	Pipeline quality natural gas only	Record Type and Quantify of Fuel Used	
AA-000	H2S	1 grain/100 scf	Record Type and Quantify of Fuel Used	
AA-001	PM	0.6 lb/MMBTU	Record Type and Quantify of Fuel Used	
AA-001	HAP	Operating restriction	Record hours of operation and reason for operating	
AA-002 through
AA-009	PM	E=0.8808*I -0.1667	Record Type and Quality of Fuel Used	
AA-001 through
AA-009	Opacity	40%	Record Type and Quality of Fuel Used