INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
April 10, 2025

GENERAL FACILITY INFORMATION
Facility Name:  Columbia Gulf Transmission, Banner Compressor Station
Facility Address:  82 County Road 233, Water Valley, MS 38965-9106
County: Calhoun
SIC Code(s): 4922
NAICS Code(s): 486210  

APPLICATION SUMMARY 
Permit No.: 0300-00005
Permit Action:  Renewal and Minor Modification
Permit Folder: PER20240001
Application Receipt Date: May 22, 2024
Application Deemed Complete: 
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): A, YYYY, ZZZZ, DDDDD
112(r) / RMP: N/A
Other: N/A	
FACILITY DESCRIPTION
Columbia Gulf Transmission owns and operates its Banner Compressor Station located at 82 County Road 233 near Water Valley, Mississippi, for the purpose of transporting natural gas through its pipeline distribution system. Natural gas compression at the Banner Compressor Station is accomplished through six (6) 2,000-horsepower natural gas-fired reciprocating compressor engines, one (1) 2,800-horsepower natural gas-fired reciprocating compressor engine, one (1) 16,000-horsepower natural gas-fired turbine, and one (1) 12,500-horsepower natural gas-fired turbine. All combustion equipment fires only pipeline quality natural gas. The compressor station also operates one (1) 455-horsepower natural gas-fired emergency generator engine and one (1) 5.25 MMBTUH process heater.  The station also has facility blowdowns, truck loading operations, fugitive emissions, as well as, insignificant activities. 

TITLE V SOURCE APPLICABILITY 
The Banner Compressor Station 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 (NOx) and Carbon Monoxide (CO).  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 an individual HAP, formaldehyde.  

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	50.65	
PM10	50.65	
PM2.5	50.65	
Sulfur Dioxide (SO2)	2.36	
Nitrogen Oxides (NOx)	2,257.37	
Carbon Monoxide (CO)	725.59	
Volatile Organic Compounds (VOC)	88.44	
Total Reduced Sulfur (TRS)	0.00	
Lead	0.00	
CFC/HCFC	0.00	
Total HAP 	57.65	
Formaldehyde	39.98	
Acetaldehyde	5.47	
Acrolein	5.39	
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 as an existing major source for PSD purposes.  The permit action is to reissue the Title V permit which will not trigger a Prevention of Significant Deterioration (PSD) Review.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The fire pump (Emission Point AA-015) has been decommissioned. There are no other proposed modifications to the Banner Compressor Station.

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 Banner Compressor Station.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

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.  The facility is a Major Source of HAP emissions.  

Emission Points AA-001 through AA-007 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 do not have to meet the requirements of 40 CFR Part 63, Subpart ZZZZ or the General Provisions of 40 CFR 63, Subpart A, including initial notification requirements.

Emission Point AA-012 is an existing emergency spark ignition 4 stroke rich burn (4SRB) stationary RICE with a site rating of less than 500 brake HP located at a major source of HAP emissions and as such must meet the applicable operational requirements and emergency operational requirements of 40 CFR Part 63, Subpart ZZZZ.

Emission Point AA-016 is an existing emergency spark ignition four stroke lean burn (4SLB) stationary RICE with a site rating of less than 500 brake HP located at a major source of HAP emissions and as such must meet the applicable operational requirements and emergency operational requirements of 40 CFR Part 63, Subpart ZZZZ.

40 CFR 63 Subpart YYYY
MACT Subpart YYYY - National Emissions Standards for Hazardous Air Pollutants for Hazardous Air Pollutants for Stationary Combustion Turbines, 40 CFR Part 63, Subpart YYYY establishes emission and operating limitations for HAP emissions from stationary combustion turbines located at a major source for HAPs.  Emission Points AA-008 and AA-009 are existing sources since each was constructed prior to the NESHAP YYYY effective date of January 14, 2003.   Therefore, NESHAP YYYY is not applicable to the turbines.  

40 CFR 63 Subpart DDDDD 
MACT Subpart DDDDD - National Emission Standards for Hazardous Air Pollutants for Industrial for Institutional, Commercial, and Industrial Boilers and Process Heaters, 40 CFR Part 63, Subpart DDDDD, establishes emission and operating limitations for HAP emissions from industrial, commercial, or institutional boilers and process heaters that are located at, or is part of, a major source of HAPs.

The facility has several insignificant space heaters and water heaters.  However, space heaters and hot water heaters are not process heaters under the definition of process heaters in 40 CFR 63.7575 and thus are not subject to the MACT.  However, the 5.25 MMBTUH Process Heater (Emission Point AA-017) qualifies as process heater with a heat input capacity of greater than 5 million Btu per hour but less than 10 million Btu per hour, designed to burn gas 1 fuels (natural gas).  The facility is required to conduct biennial tune-ups of the process heater.  Since the unit qualifies as a new process heater and not an existing process heater, the unit is not required to conduct the 1-time energy assessment performed by a qualified energy assessor.

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 MMBTUH, which commenced construction, modification, or reconstruction after October 3, 1977. The Banner Compressor Station operates two (2) stationary combustion turbines (AA-008 and AA-009) rated greater than 10 MMBTUH.  However, Emission Point AA-008 was manufactured in 1966, Emission Point AA-009 was manufactured in 1971, and neither unit has been modified or reconstructed since the NSPS GG effective date.  Therefore, the turbines are 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.  Emission Points AA-008 and AA-009 were constructed prior to the NSPS KKKK effective date and have not been modified; therefore, the turbines are not subject to any requirements of 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.  The stationary reciprocating internal combustion engines (Emission Points AA-001 through AA-007, AA-012, and AA-016) at the Banner Compressor Station 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-007, AA-012, and AA-016 are stationary spark ignition internal combustion engines, however, each engine was manufactured prior to the NSPS JJJJ effective date; therefore, the engines are not subject to any 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 Production, Transmission and Distribution for which Construction, Modification or Reconstruction Commenced After August 23, 2011, and on or before September 18, 2015 are potentially applicable to various sources at an affected compressor station.  All sources at the compressor station were installed prior to the August 23, 2011, effective date, therefore, the sources are not subject to any requirements 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, are applicable to the collection of fugitive emissions components at an affected compressor station.  However, the compressor station was constructed prior to the September 18, 2015, affected date.  Further, the Banner Compressor Station has not undergone modification that would trigger the NSPS.  Therefore, NSPS OOOOa is not applicable to the Banner Compressor Station.  

SPECIFIC APPLICABLE REQUIREMENTS
Emission Points AA-001 through AA-009, AA-012, and AA-016 are subject to state standards for PM and Opacity. Emission Points AA-012, AA-016, and AA-017 have a PM 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-009 each have a rated heat input greater than 10 MMBTU/hr and thus are subject to a PM 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 at the facility is natural gas.  Since natural gas is a clean burning fuel, the units should have a large margin of compliance with the PM and Opacity standards. The only monitoring proposed for compliance demonstration for PM and Opacity for these units is recording the fuel type. 

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	
AA-001
through
AA-009	PM	E=0.8808*I -0.1667	Record type and quantity of fuel	
AA-001
through
AA-009,
AA-012,
AA-016,
and
AA-017	Fuel Restriction	Natural gas only	Record type of fuel	
AA-012
and
AA-016	PM	0.6 lb/MMBTU	Record type and quantity of fuel	
	Operations	Scheduled Maintenance Activities	Monitoring of operations	
	Operations	Emergency Operations	Monitoring of operations	
	Operations	Minimizing Emissions	Monitoring of operations	
AA-017	SO2	4.8 lb/MMBTU	Record type and quantity of fuel	
	Operations	Operational Requirements	Monitoring of operations	

OTHER REQUIREMENTS:
N/A