INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
March 8, 2023

GENERAL FACILITY INFORMATION
Facility Name:  Entergy Mississippi LLC, Gerald Andrus Plant
Facility Address:  
200 M P and L Road
Highway 82 West
Greenville, MS 38701    
County: Washington
SIC Code(s): 4911
NAICS Code(s): 221112  

APPLICATION SUMMARY 
Permit No.: 2800-00048
Permit Action: Renewal
Permit Folder: PER20220002
Application Receipt Date: May 16, 2022
Application Deemed Complete:
September 10, 2022
CBI Submitted?: No	NSPS (Part 60): Subpart IIII
NESHAP (Part 61): N/A
NESHAP (Part 63): Subparts ZZZZ, DDDDD, UUUUU
112(r) / RMP: N/A
Other: Acid Rain Program; Cross State Air Pollution Rule; 40 CFR 1090, Subpart D	

FACILITY DESCRIPTION
Entergy Mississippi LLC, Gerald Andrus Plant (“Gerald Andrus”) is an existing electrical power generation plant that utilizes steam generating boilers. The facility has the potential to operate four boilers. The 7,275 MMBtu/hr Steam Generating Boiler (Emission Point AA-001) is the main energy generating unit. The facility can use two 230 MMBtu/hr Auxiliary Boilers (Emission Points AB-001 and AC-001) to improve the startup process. The facility can potentially utilize a 90 MMBtu/hr Temporary/Auxiliary Boiler (Emission Point AA-005) for startup; however, Emission Point AA-005 is only brought on-site for temporary occasions. Emission Points AA-001, AB-001, and AC-001 are able to fire natural gas and No. 2 fuel oil. Emission Point AA-005 is able to fire natural gas and No. 2 fuel oil. The facility keeps two Emergency Generators (Emission Points AA-002 and AA-004) onsite for backup power and an Emergency Fire Water Pump (Emission Point AA-006) for emergency situations. Emission Points AA-002 and AA-004 are 800 hp (5.6 MMBtu/hr) and 150 hp (1.05 MMBtu/hr), respectively, and fire ultra-low-sulfur-diesel (ULSD). The emission sources emit the following pollutants: Particulate Matter (PM), PM less than 10 micrometers (μm) in diameter (PM10), PM less than 2.5 μm in diameter (PM2.5), Sulfur Dioxide (SO2), Nitrogen Oxide (NOx), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), and Hazardous Air Pollutant (HAP).
The following sections will specifically address Title V Source applicability, Prevention of Significate Deterioration (PSD) applicability, Facility Modifications/Permit Changes, Compliance Assurance Monitoring (CAM) applicability, Standards of Performance for New Stationary Sources (NSPS) applicability, National Emissions Standards for Hazardous Air Pollutants (NESHAP)/ Maximum Achievable Control Technology (MACT) applicability, and Specific Applicable Requirements

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: PM10, PM2.5 SO2, CO, and VOC. The facility’s potential-to-emit hazardous air pollutants (HAPs) exceeds the major source threshold of 25 tpy of total HAPs and 10 tpy for any individual HAP.
Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions
(tons/yr)	
Particulate Matter (TSP)	7,100	
PM10	7,100	
PM2.5	7,100	
Sulfur Dioxide (SO2)	162,000	
Nitrogen Oxides (NOx)	9,320	
Carbon Monoxide (CO)	2,800	
Volatile Organic Compounds (VOC)	184	
Total Reduced Sulfur (TRS)	0.00	
Lead	0.00	
CFC/HCFC	0.00	
Total HAP 	29.1	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility operates fossil-fuel boilers totaling more than 250 MMBtu/hr heat input. The facility is 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 100 tpy.  The facility has the potential to emit more than 100 tons per year of PM, NOx, SO2, and CO; therefore, the facility is a major stationary source.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The facility has not requested any modifications to the permit. The following changes were made to the permit:
•	Emission Point AA-001 is subject to the Cross State Air Pollution Rule. The permit reissuance will update the requirement to reflect the current applicable subpart, Subpart EEEEE.
•	Emission Points AA-001, AB-001, and AC-001 are subject to 11 Miss. Admin. Code Pt. 2, R. 1.3. D(1)(b). which limits PM (Filterable Only) emissions. Previously,  Emission Points AA-001, AB-001, and AC-001 were subject to lb/MMBtu limitation, based on the emission equation of the standard. This permitting action will remove those specific limitations and the emission equation remains.
•	Emission Points AA-001, AB-001, and AC-001 were subject to a visual observation requirement while combusting No. 6 fuel oil. The previous permit contained two conditions applying the same monitoring and recordkeeping requirement. The requirements. This permitting action will remove those conditions because the facility no longer combusts No. 6 fuel oil.
•	Previously, Emission Point AA-005 was limited to 2880 hours per year, based on a 12-month rolling total, and a fuel sulfur content of 0.25%. Those limitations were added to the Title V Operating Permit on July 18, 2005. The limits were added to avoid 40 CFR 60, Subpart Dc and 40 CFR 63, Subpart DDDDD and ensure the boiler met the definition of temporary boiler. The hourly limit was more stringent than either Federal definition. The fuel sulfur content limitation is greater than the maximum fuel sulfur content listed in the application. Therefore, hourly limitation was overburdensome and fuel sulfur content limitation was unnecessary. This permitting action has removed the language.

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.

STANDARDS OF PERFORMACNCE FOR NEW SOURCES (NSPS) APPLICABILITY
Standards of Performance for Fossil-Fuel-Fired Steam Generators (40 CFR 60, Subpart D)
40 CFR 60, Subpart D was promulgated to regulate SO2, PM, and NOx emissions generated by fossil-fuel-fired steam generating units. Units subject to Subpart D commenced construction, modification, or reconstruction after August 17, 1971, and has a heat input capacity from fuels combusted in the steam generating unit of greater than 250 MMBtu/hr. Emission Points AA-001, AB-001, and AC-001 are fossil-fuel-fired steam generators constructed after 1971. Emission Point AA-001 has a heat input capacity greater than 250 MMBtu/hr while Emission Points AB-001 and AC-001 do not meet the heat input threshold. Emission Point AA-001 is subject to Subpart D. Emission Point AA-001 has completed the initial compliance demonstration methods required by Subpart D and there are no continuous methods of compliance.

Standards of Performance for Electric Utility Steam Generating Units (40 CFR 60, Subpart Da)
40 CFR 60, Subpart Da was promulgated to regulate SO2, PM, CO, NO2, and NOx emissions generated by electric utility steam generating units (EGU). Units subject to Subpart Da commenced construction, modification, or reconstruction after September 18, 1978, and has a heat input capacity from fuels combusted in the steam generating unit of greater than 250 MMBtu/hr. Emission Points AA-001, AB-001, and AC-001 are fossil-fuel-fired steam generators constructed in 1973. Emission Points AB-001 and AC-001 do not meet the heat input threshold. Emission Point AA-001 meets the heat input capacity threshold but was constructed before 1978. Therefore, Emission Points AA-001, AB-001, and AC-001 are not subject to Subpart Da.

Standards of Performance for Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Db)
40 CFR 60, Subpart Db was promulgated to regulate SO2, PM, and NO2 emissions generated by steam generating units. Units subject to Subpart Db commenced construction, modification, or reconstruction after June 19, 1984, and has heat input capacity greater than 100 MMBtu/hr. Emission Points AA-001, AB-001, and AC-001 are steam generators constructed in 1973, and are not subject to Subpart Db.

Standards of Performance for Small Industrial-Commercial-Institutional Steam Generating Units (40 CFR Part 60, Subpart Dc)
40 CFR 60, Subpart Dc was promulgated to regulate SO2 and PM emissions generated by small steam generating units. Units subject to Subpart Dc commenced construction, modification, or reconstruction after June 9, 1989, and has a maximum heat input capacity from fuels combusted in the steam generating unit of 100 MMBtu/hr or less, but greater than 10 MMBtu/hr. Emission Points AA-001, AB-001, and AC-001 are not subject to Subpart Dc because the boilers were constructed before 1989. Emission Point AA-005 is potentially subject to Subpart Dc because the steam generating unit will have a heat input capacity less than 100 MMBtu/hr but greater than 10 MMBtu/hr. Emission Point AA-005 is a permitted temporary boiler that is not on-site. Emission Point AA-005 is not subject to Subpart Dc while complying with the definition of temporary boiler, as described in 40 CFR 60.41c, Subpart Dc.

Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (40 CFR 60, Subpart IIII)
40 CFR 60, Subpart IIII establishes emission limitations and management practices for stationary compression ignition internal combustion engines. Engines subject to Subpart IIII were constructed after July 11, 2005, where non-fire pump engines were manufactured after April 1, 2006 and National Fire Protection Association (NFPA) fire pump engines were manufactured after July 1, 2006. Emission Points AA-002, AA-004, and AA-006 are stationary compression ignition internal combustion engines. Emission Points AA-002 and AA-004 were constructed before December 19, 2002 and are not fire pump engines. Emission Points AA-002 and AA-004 are not subject to Subpart IIII. Emission Point AA-006 was constructed in 2021. Emission Point AA-006 is an EPA certified emergency fire pump that will combust ultra-low-sulfur-diesel (ULSD). Emission Point AA-006 is subject to and shall comply with all applicable requirements of Subpart IIII. Subpart IIII requires engines to comply with the ULSD fuel standards of 40 CFR 1090, Subpart D.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP)/ MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) APPLICABILITY 
National Emission Standards Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR 63, Subpart ZZZZ) 
40 CFR 63, Subpart ZZZZ establishes national emission limitations and operating limitations for HAP emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. Gerald Andrus is a major source of HAP emissions because the facility generates more than 25 tpy for total HAP. Emission Points AA-002, AA-004, and AA-006 are emergency stationary reciprocating internal combustion engines and are potentially subject to Subpart ZZZZ. Emission Point AA-002 is an existing emergency stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions. Emission Point AA-002 does not have to meet the requirements of Subpart ZZZZ or Subpart A. Emission Point AA-004 is an existing emergency stationary RICE with a site rating of less than 500 brake HP located at a major source of HAP emissions. Emission Point AA-004 is subject to and shall comply with all applicable requirements of Subpart ZZZZ Emission Point AA-006 is a new emergency compression ignition stationary RICE with a site rating of less than 500 brake HP located at a major source of HAP emissions. Emission Point AA-006 shall meet the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR 60, Subpart IIII.

National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters (40 CFR 63, Subpart DDDDD)
40 CFR 63, Subpart DDDDD establishes national emission limitations and work practice standards for HAP emitted from industrial, commercial, and institutional boilers and process heaters located at major sources of HAP. Subpart DDDDD also establishes requirements to demonstrate initial and continuous compliance with the emission limitations and work practice standards. Emission Points AA-001, AA-005, AB-001, and AC-001 are industrial boilers located at a major source of HAP emissions and are potentially subject to Subpart DDDDD. Emission Point AA-001 is not subject to Subpart DDDDD while operating as a natural gas-fired EGU, as defined in 40 CFR 63, Subpart UUUUU, firing at least 85 percent natural gas on an annual heat input basis. Emission Point AA-005 is a permitted temporary boiler that is not on-site. Emission Point AA-005 is not subject to Subpart DDDDD if the boiler complies with the definition of a temporary boiler, according to Subpart DDDDD. Emission Points AB-001 and AC-001 are defined as units designed to burn gas 1 subcategory. However, Emission Points AB-001 and AC-001 have the potential to combust liquid fuel. Emission Points AB-001 and AC-001 are not subject to any emission limits while combusting gas 1 fuels, but comply with all applicable work practice standards, recordkeeping, and reporting requirements. The permittee shall submit a notification to the DEQ if a fuel switch occurs or a physical change is made the boiler(s) causing a change in applicability.
National Emission Standards for Hazardous Air Pollutants for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units (40 CFR 63, Subpart UUUUU)
40 CFR 63, Subpart UUUUU establishes national emission limitations and work practice standards for HAP emitted from coal- and oil-fired EGU, as defined in 40 CFR 63.10042, Subpart UUUUU. Subpart UUUUU also establishes requirements to demonstrate initial and continuous compliance with the emission limitations. Emission Point AA-001 is an EGU and potentially subject to Subpart UUUUU. Emission Points AA-005, AB-001, and AC-001 are not subject to Subpart UUUUU because the boilers are not EGUs.

SPECIFIC APPLICABLE REQUIREMENTS 

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001
AA-005
AB-001
AC-001	PM
(Filterable Only)	E = 0.8808*I-0.1667	Monitor and Record Fuel Combustion	
	SO2	4.8 lbs/MMBtu		
	Smoke	40 percent Opacity		
AA-002
AA-004
AA-006	PM
(Filterable Only)	0.6 lb/MMBTU	None. Large margin of compliance guarantee by ULSD.	
AA-004	HAP	Operate Engine Using Good Air Pollution Control Practices	Maintain Manufacturer’s Specifications.	
		Minimize Emissions Using Manufacturer’s Emission-Related Instructions		
	Hours of Operation	Install and Maintain a Non-resettable Hour Meter	Monitor and Keep Records of Non-resettable Hour Meter.	
	HAP	Minimize Idle Time		
	Hours of Operation	No time limit on emergency use. Maintenance checks and readiness testing is limited to 100 hours per calendar year and non-emergency use is limited to 50 hours per year, to be included in the 100 hours per year.	Monitor and Keep Records of Non-resettable Hour Meter.	
AA-004	Maintenance	Change oil and filter every 500 hours of operation.
Inspect air cleaner every 1,000 hours of operation.
Inspect all hoses and belts every 500 hours of operation.	Monitor and Record All Maintenance Conducted.	
AA-005	Hours of Operation	180 days of consecutive usage.	Monitor and Record Temporary Boiler Usage.	
AA-006	NMHC + NOx	Emissions shall not exceed
4.0 g/KW-hr ( 3.0 g/HP-hr)	Maintain Manufacturer’s Specifications.	
AA-006	PM	Emissions shall not exceed
0.20 g/KW-hr ( 0.15 g/HP-hr)	Maintain Manufacturer’s Specifications.	
	Fuel Usage	Ultra-Low-Sulfur Diesel (USDL) Standards		
	Hours of Operation	Install and Maintain a Non-resettable Hour Meter	Monitor and Keep Records of the hours from the Non-resettable Hour Meter.	
	HAP	Operate Engine Using Good Air Pollution Control Practices	Maintain Manufacturer’s Specifications.	
		Minimize Emissions Using Manufacturer’s Emission-Related Instructions		
	Hours of Operation	No time limit on emergency use. Maintenance checks and readiness testing is limited to 100 hours per calendar year and non-emergency use is limited to 50 hours per year, to be included in the 100 hours per year.	Monitor and Keep Records of the hours from the Non-resettable Hour Meter.	
AB-001
AC-001	Maintenance	Conduct an annual tune-up.	Keep Annual Tune Up Records.	

OTHER REQUIREMENTS:
•	Emission Points AA-001, AA-002, AA-004, AA-005, AA-006, AB-001, and AC-001 are subject to State Standards for PM emissions; however, the equipment should have a large margin of compliance because the emissions sources are burning natural gas and low sulfur diesel. No additional monitoring is proposed.
•	Emission Points AA-001, AA-005, AB-001, and AC-001 are subject to State Standards for SO2 emissions; however, the equipment should have a large margin of compliance because the emissions sources are burning natural gas and low sulfur diesel. No additional monitoring is proposed.
•	The permittee is subject to and shall comply with all applicable requirements of 40 CFR Part 72 through 78 – Acid Rain Program regulations. The permittee submitted a complete Acid Rain Program application and the Acid Rain Permit is attached to the TVOP.
•	The permittee is subject to and shall comply with all applicable requirements of 40 CFR Part 97, Subpart EEEEE - Cross-State Air Pollution Rule (CSAPR) Monitoring Provisions.