Public Notice
Mississippi Environmental Quality Permit Board
P. O. Box 2261 | Jackson, MS 39225
515 East Amite St. | Jackson, MS 39201
Telephone No. (601) 961-5171

Public Notice Start Date: August 24, 2021	MDEQ Contact: Slater Smith

Tellus Operating Group LLC, Tallahala 4-7 Number 1 Tank Battery ("TOG"), located at Smith County Road 95, in Sylvarena, MS, (601) 898-7444, has applied to the Mississippi Department of Environmental Quality (MDEQ) for the following permitting action(s): Reissuance of Title V Operating Permit (TVOP) Air Ref. No. 2500-00088. The applicant's operations fall within SIC Code 1321.  A Statement of Basis has been prepared that contains a discussion of the decision-making that went into the development of the permit and provides the permitting authority, the public, and other government bodies a record of the technical issues surrounding issuance of the permit. The Statement of Basis also addresses any changes to emissions and/or discharges resulting from any modification of the facility.  
TOG is an existing gas and oil production facility with a tank battery that is requesting reissuance of TVOP Air Ref. No. 2500-00088. The gas, oil, and water mixture is drawn from local well(s) and is routed to the onsite separators. The produced, separated gas is then routed to a Control Flare for destruction. Produced gas is flared because the facility is not near a pipeline. Smith County and other surrounding counties are known for an oil shale that contains sour gas. Sour gas is natural gas that contains high concentrations of hydrogen sulfide.  The hydrogen sulfide will be destroyed by routing the produced gas to the Control Flare. Water produced by oil and gas production is routed from the Separator to a Water/Oily Water Storage Tank, prior to the water being routed to a disposal well. Separated oil is routed to three Oil Storage Tanks. The treated, produced oil will be stored until Truck Loading. Emissions produced by the Separator, Water/Oily Water Storage Tank, Oil Storage Tanks, and Truck Loading are routed to the Control Flare. Previously, TOG was considered a True Minor source of emissions when the facility was able to send produced sour gas to an off-site processing facility but that is no longer an option. The facility is required by 11 Miss. Admin. Code Pt. 2, R. 1.4.B(2). to incinerate produced sour gas that exceeds the State Regulation for control of hydrogen sulfide emissions. The facility has the potential to exceed the Prevention of Significant Deterioration (PSD) threshold for volatile organic compound (VOC) emissions and the Title V major source threshold for HAP emissions prior to incineration of the produced gas. The facility is able to comply with 11 Miss. Admin. Code Pt. 2, R. 1.4.B(2). and avoid exceeding the PSD threshold for VOC emissions by routing all produced sour gas to the Control Flare, but the destruction of the produced gas containing H2S causes the facility to become subject to the TVOP program for sulfur dioxide emissions. Incineration of produced gas reduces HAP emissions below Title V major source thresholds which allows the facility to be considered an area source. PSD avoidance limitations will be established under the authority of 11 Miss. Admin. Code Pt. 2, R.2.15.C. Therefore, the facility will flare all produced gas and limit sulfur dioxide emissions to avoid the PSD program. Compliance with the limits will be demonstrated by monitoring and recordkeeping requirements.
The staff of the Permit Board has developed this draft permit based on information submitted to the Permit Board by the applicant, appropriate State and Federal agencies and other interested parties. The staff of the Permit Board is soliciting all relative information pertaining to the proposed activity, including public comment, to ensure that the final staff recommendation on the draft permit complies with all State and Federal regulations. Public review and comment on the draft permit and supporting documentation is an important element in the staff evaluation and resulting recommendation to the Permit Board. The draft permit conditions have been developed to ensure compliance with all State and Federal regulations but are subject to change based on information received as a result of public participation.
Persons wishing to comment upon or object to the proposed determinations are invited to submit comments in writing to Slater Smith at https://www.mdeq.ms.gov/smith-slater/ or to the Permit Board address shown above, no later than the end of the thirty (30) day public notice. All comments received by this date will be considered in the formulation of final determinations regarding the application(s). A public hearing will be held if the Permit Board finds a significant degree of public interest in the proposed permit(s). Persons wishing to request a public hearing may do so by submitting that request in writing to Slater Smith at https://www.mdeq.ms.gov/smith-slater/ or to the Permit Board address shown above. The Permit Board is limited in the scope of its analysis to environmental impact. Any comments relative to zoning or economic and social impacts are within the jurisdiction of local zoning and planning authorities and should be addressed to them.
After receipt of public comments and thorough consideration of all comments, the staff will formulate its recommendations for permit issuance and a proposed permit if that is the recommendation. The Title V Permit to Operate is a permit that is required by Title V of the Federal Clean Air Act and the Mississippi Air and Water Pollution Control Law. The Title V permit is a Federally-enforceable permit as well as a State permit.  Therefore, the U.S. Environmental Protection Agency (EPA) will also be allowed an opportunity to review the application, proposed permit, and all comments received during the public comment period prior to Permit Board action on the application. 
The status regarding EPA’s 45-day review of this project and the deadline for citizen’s petitions can be found at the following website address:  https://www.epa.gov/caa-permitting/mississippi-proposed-title-v-permits 
Additional details about the application, including a copy of the draft permit, are available by writing or calling the Public Records Request Officer at the above Permit Board address and telephone number or by completing the form at the following website: https://www.mdeq.ms.gov/about-mdeq/public-records-request/public-records-request-form/ .  Additionally, a copy of the draft permit and statement of basis may be found on the MDEQ’s website at: https://opc.deq.state.ms.us/publicnotice.aspx . This information is also available for review at the office of the MDEQ at the Permit Board address shown above during normal business hours. Please bring the foregoing to the attention of persons whom you know will be interested.