INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
June 2025

GENERAL FACILITY INFORMATION
Facility Name:  Venture Oil and Gas Inc, Hiwannee Operations
Facility Address:  
Dove Land Road
Waynesboro, MS 39367    
County: Wayne
SIC Code(s): 1321
NAICS Code(s): 211112  

APPLICATION SUMMARY 
Permit No.: 2840-00074
Permit Action:  Renewal with 502(b)10 Modification
Permit Folder: PER20230001
Application Receipt Date: November 19, 2024
Application Deemed Complete: {Use administrative completeness date}
CBI Submitted?: {Yes / No}	NSPS (Part 60): Subpart Kb, Subpart KKK, Subpart LLL, Subpart JJJJ, Subpart OOOO, Subpart OOOOa
NESHAP (Part 61): N/A
NESHAP (Part 63): Subpart A, Subpart HH, Subpart HHH, Subpart ZZZZ
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
Venture Oil and Gas operates the Hiwannee Operations which consists of a central tank battery, reinjection gas compressors, and associated well pad activities under an Air Title V Operating Permit. The Facility is located in Hiwannee near Waynesboro, Mississippi. 

The facility treats natural gas and oil that is pumped from local wells to remove salt water and other impurities. Saltwater is held in tanks onsite before it is hauled away to a saltwater injection well. Oil is collected in tanks before it is trucked to market. Gas is separated and pumped to a gas processing plant. Gas is flared during maintenance and shutdowns as necessary. 

The facility consists of five (5) flares, ten (10) oil tanks and two (2) water tanks, one (1) triethylene glycol dehydrator (TEG), and a variety of equipment components. The facility operates six (6) compressor engines as well. The facility operates several small pressure vessels and small natural gas fired external combustion sources where each one is less than one (1) MMBTUH. 

Facility Emission Points and Descriptions.
Emission Point	Facility ID	Description	
AA-002	--	Central Tank Battery Flare combusting gases from the tanks, truck loading, TGE, and losses from the vapor recovery unit (VRU). The flare pilot is 0.05 MMBTU/Hr natural gas-fired.	
AA-003	--	Natural Gas Fired External Combustion Equipment consisting of four (4) line heaters, three (3) flare pilots, two (2) heater treaters, two (2) dehydrators, one (1) reboiler	
AA-004	C-12	Gas Injection Compressor, 145 hp, 1989 model year, 1.02 MMBTU/hr, 4 stroke, spark ignition, rich burn, <10L displacement	
AA-005	C-164	Gas Injection Compressor, 865 hp, 1991 model year, 6.06 MMBTU/hr, 4 stroke, lean burn, spark ignition,    < 10L displacement	
AA-007	C-30	Gas Injection Compressor, 255 hp, pre-2006 model year, 1.79 MMBTU/hr, 4 stroke, rich burn, spark ignition, <10L displacement	
AA-009	--	Central Tank Battery Equipment Component Fugitive Emissions	
AA-010	--	Reinjection Station Equipment Component Fugitive Emissions	
AA-011	--	Well 17-1 Flare and Flare Pilot	
AA-012	--	Well 16-13 Flare and Flare Pilot	
AA-013	C-201	Gas Injection Compressor, 840 hp, 2013 model year, 5.88 MMBTU/hr, 4 stroke, lean burn, spark ignition, <10 L displacement	
AA-016	--	Glycol Dehydrator	
AA-017	--	Truck Loading	
AA-018	--	Ten (10) 16,800 gallon Oil Condensate Production Storage Tanks at the Central Battery vented to VRU or flare	
AA-019	--	Two (2) 16,800 gallon Salt-Water Storage Tanks at the Central Battery vented to the VRU or flare	
AA-020	--	Well 16-12-2 Emergency Flare and pilot	
AA-021	--	Reinjection Station Emergency Flare and Pilot	
AA-022	--	Three (3) 16,800 gallon Oil Condensate Storage Tanks and one (1) 16,800 gallon Salt-Water Storage Tank at Well 16-13-1	
AA-023	C-140	Gas Injection Compressor, 373 hp, 1981 model year, 2.61 MMBTU/hr, 4 stroke, rich burn, spark ignition, <10L displacement	
AA-024	--	400 hp Gas Injection Compressor engine, 1994 model G3408 TA, 2.8 MMBTUH	
AA-025	--	One (1) 8,820 gallon Oil Condensate Storage Tank at Reinjection Station	

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: Sulfur Dioxide (SO2), Nitrogen Oxides (NOx), Carbon Monoxide (CO), and Volatile Organic Compounds (VOCs). 

The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed 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)	1.70	
PM10	0.95	
PM2.5	0.95	
Sulfur Dioxide (SO2)	117.07	
Nitrogen Oxides (NOx)	197.60	
Carbon Monoxide (CO)	133.19	
Volatile Organic Compounds (VOC)	130.26	
Total Reduced Sulfur (TRS)	2.39	
Total HAP 	5.20	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility has the potential to emit more than 250 tons per year of SO2, NOx, CO, and VOCs but will continue to limit facility-wide emissions of SO2, NOx, CO, and VOCs to less than 250 tpy; therefore, the facility is considered a moderate stationary source. This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The facility has applied for a 502(b)10 change to operate two (2) 0.75 MMBTU/hr gas-fired line heaters and one (1) small intermittent use flare. These qualify as Insignificant Activities. Emission Point AA-001(1200 HP engine) was replaced with the Emission Point AA-023 (373 HP engine). Emission Points AA-006 and AA-008 have been removed from operation and rendered unable to operate. Emission Point AA-015 has been removed from the site. Emission Point AA-024 was added to the site.

Potential Emissions from New Activities:
Pollutant	2023 Actual Emission Rates (tpy)	PTE Emissions
(tons/yr)	New Proposed Emission Rates (tpy)	
PM10	0.74	0.10	0.84	
PM2.5	0.74	0.10	0.84	
Sulfur Dioxide (SO2)	43.52	11.76	55.28	
Nitrogen Oxides (NOx)	33.62	1.09	34.71	
Carbon Monoxide (CO)	13.76	2.57	16.33	
Volatile Organic Compounds (VOC)	48.16	0.99	49.15	

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.

Although the facility has equipment (AA-002, flare) with pre-control emissions exceeding major source thresholds, CAM is not applicable because the flare is the control device to control Hydrogen Sulfide (H2S) emissions from the gas.  Therefore, CAM does not apply to any unit at this facility.  

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR 63, Subpart A
The provisions of 40 CFR 63 Subpart A apply to all owners and operators of a stationary source that emits or has the potential to emit any HAP listed in section 112(b) of the Clean Air Act. As the facility has the potential to emit HAPs, Subpart A is applicable to the facility.

40 CFR 63, Subpart HH – National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities 
40 CFR 63 Subpart HH provides HAP emission limits for oil and gas production facilities that are major or area sources of HAP emissions. The facility is an area source of HAP emissions, therefore 40 CFR 63.760(a)(1) applies. The facility stores hydrocarbon liquids, therefore 40 CFR 63.760(a)(2) applies. The facility reinjects produced gas when it is returned from a processing facility therefore 40 CFR 63.760(a)(3) is not applicable.  The facility is subject to 40 CFR 63 Subpart HH because (a)(1) and (a)(2) are applicable even if (a)(3) is not.

The affected HAP source is the triethylene glycol (TEG) dehydration unit (AA-016). 

The facility emits approximately 5.2 tpy of HAPs. The facility is not required to update its major source determination yearly per 40 CFR 63.760(c). 

The facility expects to produce 12,985 mcf/day of natural gas and 142,930 L/day of crude oil. Therefore the facility is not exempted by 40 CFR 63.670(e)(2).

Finally, The facility emits 0.04 megagrams per year of benzene. Therefore, by 40 CFR 63.764(e)(1)(ii), the facility is exempt from the requirements of Subpart HH but must keep records of the actual benzene emissions to support this exemption as determined by 40 CFR 63.772(b)(2).

40 CFR 63, Subpart HHH – National Emission Standards for Hazardous Air Pollutants from Natural Gas Transmission and Storage Facilities 
40 CFR 63, Subpart HHH applies to natural gas facilities that are major sources of HAPs. The facility is an area source of HAPs, therefore 40 CFR 63, Subpart HHH does not apply. 

40 CFR 63 Subpart ZZZZ, National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines 
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. The facility operates five (5) existing RICE. 

Emission Points AA-004, AA-007, AA-023, and AA-024 are existing four stroke rich burn stationary RICE with a site rating of less than 500 brake HP located at an area source of HAP emissions. These emission points must meet the scheduled maintenance activities and operational requirements of Item 10 of Table 2d of Subpart ZZZZ. 

Emission Point AA-005 is an existing four stroke rich burn station RICE with a site rating greater than 500 brake HP. It qualifies as a “remote” RICE since the engine is located in a sparsely populated area where there are five (5) or fewer building intended for human occupancy within a 0.25 mile radius. This emission point must meet the scheduled maintenance activities and operational requirements of Item 11 of Table 2d of Subpart ZZZZ. 

Emission Point AA-013 is a spark ignition 4SLB stationary RICE with a site rating of more than 500 brake HP. This RICE complies with Subpart ZZZZ by complying with the requirements of 40 CFR 60, Subpart JJJJ.  

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY
40 CFR 60, Subpart A
The provisions of this part apply to the owner or operator of any stationary source which contains an affected facility, the construction or modification of which is commenced after the date of publication in this part of any standard (or, if earlier, the date of publication of any proposed standard) applicable to that facility. The facility is not excepted under Subpart B, Ba, or C. Therefore, some Subpart A requirements are applicable. 

40 CFR 60, Subpart Kb, Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984
40 CFR 60, Subpart Kb applies to each volatile organic liquid storage tank that is greater than 75 cubic meters in capacity and that was constructed, reconstructed, or modified after July 23, 1984. AA-018, AA-019, and AA-022 are 16,800 gallon (63.6 m3) tanks built after July 23, 1984. These vessels are exempt from Subpart Kb due to 40 CFR 60.110b(d)(4) which exempts vessels with a design capacity less than or equal to 1,589.874 m3 used for petroleum or condensate stored, processed, or treated prior to custody transfer. Therefore, AA-018, AA-019, and AA-022 are not subject to Subpart Kb. 

40 CFR 60, Subpart KKKK - Standards of Performance for Equipment Leaks of VOC From Onshore Natural Gas Processing Plants for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011
The facility operates equipment with VOC leaks. However, the facility is not a natural gas processing plant as defined in 40 CFR 60.631 and therefore not subject to Subpart KKK. 

40 CFR 60, Subpart LLL - Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011
The facility does not operate sweetening units. Therefore, 40 CFR 60, Subpart LLL is not applicable.

40 CFR 60, Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
The facility operates several Stationary Spark Ignition Internal Combustion Engines in the table below. Subpart JJJJ establishes performance standards for spark ignition internal combustion engines with a manufacturing or reconstruction date after June 12, 2006. Emission Point AA-013 is subject to Subpart JJJJ. 

Subpart JJJJ Applicability Table.
Emission point	HP	Most recent date manufactured or reconstructed	Subpart JJJJ Applicable	
AA-004	145	Pre-2006	No	
AA-005	865	1991	No	
AA-007	255	Pre-2006	No	
AA-013	840	2013	Yes	
AA-023	373	1981	No	
AA-024	400	1994	No	

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
40 CFR 60, Subpart OOOO applies to facilities that commence construction, modification, or reconstruction after August 13, 2011. An affected facility must continue to comply with the requirements of this subpart until it begins complying with a more stringent requirement, that applies to the same affected facility, in an approved, and effective, state or Federal plan that implements Subpart OOOOc, or modifies or reconstructs after December 6, 2022, and thus becomes subject to Subpart OOOOb. All activities on the site were installed prior to August 13, 2011 except Emission Point AA-013 which is subject to Subpart OOOO requirements in 40 CFR 60.5385. 
For Emission Point AA-018 (nine storage tanks), the permittee operates a vapor recovery unit (VRU) which captures the vapors and routes them to the compressor for reinjection at the reinjection station which reinjects the gases for maintaining the bottom hole pressure for product recovery. This system for product recovery restricts the volatile organic compounds from the storage tanks operation below the applicability threshold (6 tpy) as described in 40 CFR 60.5365(e) and therefore the permittee is not subject to Subpart OOOO.  The facility is furthermore required to comply with the state requirement for restricting hydrogen sulfide emissions below 1grain/100scf (16ppm) and the facility complies with that limit by utilizing the VRU.

40 CFR 60, Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities Commenced after September 18, 2015
The facility removed compressor engine AA-015. Therefore, all activities were installed prior to September 18, 2015 and 40 CFR 60, Subpart OOOOa is not applicable. 

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility wide	CO
NOX
SO2	<249.0 tpy	Monitor and record monthly and rolling 12-month emission rates.	
	Individual HAPs
Total HAPS	< 9.0 tpy for individual
<24.0 tpy for total	Monitor and record monthly and rolling 12-month emission rates.	
	H2S	< 1 grain/100 scf	Routing produced gas to the flare for destruction	
AA-002
AA-003
AA-004
AA-005
AA-007
AA-013
AA-023
AA-024	PM	< 0.6 pounds per million BTU per hour	Natural Gas units so large margin of compliance so no additional monitoring 	
AA-004 AA-005 AA-007 AA-023
AA-024	HAPs	Oil Analysis options	Recordkeeping requirements	
	HAPs	Maintenance and Operations requirements	Recordkeeping requirements	
AA-011
AA-012
AA-020
AA-021	PM	0.8808 * (I) -0.1667	Natural Gas units so large margin of compliance so no additional monitoring	
AA-013	NOX
	1.0 g/hp-hr or 82 ppmvd at 15% O2.
	Performance Testing in conjunction with facility-wide emission limitation performance testing for demonstrating compliance with emission limitations.  	
	VOC	0.7 g/hp-hr or 60 ppmvd at 15% O2	Performance Testing in conjunction with facility-wide emission limitation performance testing for demonstrating compliance with emission limitations.  	
	CO	2.0 g/hp-hr or 270 ppmvd at 15% O2	Performance Testing in conjunction with facility-wide emission limitation performance testing for demonstrating compliance with emission limitations.  	
	AFR	Operate and maintain properly	Recordkeeping requirements	
	GHG and VOCs	Rod Packing Replacement Requirement	Monitor and record the number of hours or days since the last rod packing replacement.