INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
August 25, 2025

GENERAL FACILITY INFORMATION
Facility Name:  Texas Gas Transmission LLC, Clarksdale Compressor Station
Facility Address:  3305 US Highway 61 South, Clarksdale, MS 38614    
County: Coahoma
SIC Code(s): 4922
NAICS Code(s): 486210  

APPLICATION SUMMARY 
Permit No.: 0540-00008
Permit Action:  Renewal
Permit Folder: PER20240001
Application Receipt Date: February 23, 2024
Application Deemed Complete: 
CBI Submitted?: No	NSPS (Part 60): A, GG
NESHAP (Part 61): N/A
NESHAP (Part 63): A, YYYY, ZZZZ
112(r) / RMP: {N/A or Yes}
Other: N/A	

FACILITY DESCRIPTION
Texas Gas Transmission owns and operates its Clarksdale Compressor Station for the purpose of transporting natural gas through a pipeline distribution system. Natural gas compression at the station is accomplished through seven (7) 2,000-horsepower natural gas-fired compressor engines, one (1) 14,300-horsepower natural gas-fired turbine, and one (1) 14,050-horsepower natural gas-fired turbine. The compressor station also operates two (2) 250-hp natural gas-fired emergency generator engines and one (1) 35-horsepower natural gas-fired air compressor engine.  The station also has facility blowdowns, fugitive emissions, as well as, insignificant activities. The following table includes the significant emission points at the facility.

Emission Point	Description	
AA-001	2,000 Horsepower (HP) (16.12 MMBTU/hr) Cooper Bessemer two stroke lean burn (2SLB) natural gas-fired spark ignition (SI) compressor engine (Model No. GMW-8TF, Facility Ref. No. RC01)	
AA-002	2,000 HP (16.12 MMBTU/hr) Cooper Bessemer 2SLB natural gas-fired SI compressor engine (Model No. GMW-8TF, Facility Ref. No. RC02)	
AA-003	2,000 HP (16.12 MMBTU/hr) Cooper Bessemer 2SLB natural gas-fired SI compressor engine (Model No. GMW-8TF, Facility Ref. No. RC03)	
AA-004	2,000 HP (16.12 MMBTU/hr) Cooper Bessemer 2SLB natural gas-fired SI compressor engine (Model No. GMW-8TF, Facility Ref. No. RC04)	
AA-005	2,000 HP (15.45 MMBTU/hr) Cooper Bessemer 2SLB natural gas-fired SI compressor engine (Model No. GMWA-8, Facility Ref. No. RC05)	
AA-006	2,000 HP (15.45 MMBTU/hr) Cooper Bessemer 2SLB natural gas-fired SI compressor engine (Model No. GMWA-8, Facility Ref. No. RC06)	
AA-007	2,000 HP (15.45 MMBTU/hr) Cooper Bessemer 2SLB natural gas-fired SI compressor engine (Model No. GMWA-8, Facility Ref. No. RC07)	
AA-008	14,300 HP (112.37 MMBTU/hr) Pratt & Whitney simple-cycle natural gas-fired compressor turbine at ISO conditions and 12,000 HP at NEMA conditions (Model No. GG3C-4, Facility Ref. No. TB02)	
AA-009	14,050 HP (89.77 MMBTU/hr) General Electric regenerative-cycle natural gas-fired compressor turbine at ISO conditions and 12,090 HP at NEMA conditions (Model No. M3122R, Facility Ref. No. TB03)	
AA-013	250 HP (2.5 MMBTU/hr) Waukesha four stroke rich burn (4SRB) natural gas-fired SI emergency backup power generator engine (Model No. H2476G, Facility Ref. No. AX04)	
AA-015	250 HP (2.5 MMBTU/hr) Waukesha 4SRB natural gas-fired SI emergency backup power generator engine (Model No. H2475, Facility Ref. No. AX06)	
AA-016	35 HP (0.42 MMBTU/hr) Wisconsin 4SRB natural gas-fired SI non-emergency air compressor engine (Model No. W41770, Facility Ref. No. AX03)	

TITLE V SOURCE APPLICABILITY 
Texas Gas Transmission’s Clarksdale Compressor Station Number 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)	20.35	
PM10	29.36	
PM2.5	29.36	
Sulfur Dioxide (SO2)	0.81	
Nitrogen Oxides (NOx)	2,375.33	
Carbon Monoxide (CO)	215.33	
Volatile Organic Compounds (VOC)	64.88	
Total Reduced Sulfur (TRS)	0	
Lead	0	
CFC/HCFC	0	
Total HAP 	36.90	
Formaldehyde	27.49	
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 facility has the potential to emit more than 250 tons per year of NOx and hence the facility is considered as an existing major source for PSD purposes.  This permitting action to renew the Title V permit will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no modifications to the facility or other significant permit changes proposed as part of this permitting action.

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 Clarksdale Compressor Station.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is a major source of HAP emissions since the facility has the potential to emit more than 25 tpy of total HAPs and 10 tpy of the individual HAP, formaldehyde.

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.    

Emission Points AA-001 through AA-007 are 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 Points AA-013 and AA-015 are existing emergency spark ignition 4 stroke rich burn (4SRB) stationary RICE each 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 non-emergency spark ignition 4SRB stationary RICE with a site rating of less than or equal to 100 brake HP located at a major source of HAP emissions and as such must meet the applicable 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.  Since the Compressor Station does not operate any boilers or process heaters, the facility is not subject to NESHAP DDDDD or to any requirements in NESHAP DDDDD.

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 Clarksdale Compressor Station operates two (2) stationary combustion turbines (AA-008 and AA-009) rated greater than 10 MMBTUH.  

Emission Point AA-008 is a 112.37-MMBTUH simple cycle turbine that was constructed in 1962 and has not undergone significant reconstruction or modification and is therefore not subject to the provisions of NSPS GG.  

Emission Point AA-009 is an 89.77-MMBTUH regenerative cycle turbine that was constructed in 1982 and is therefore subject to the SO2 provisions of NSPS GG.  Emission Point AA-009 is not subject to the NOx requirements of NSPS GG per 40 CFR 60.332(l), which states that regenerative cycle gas turbines with a heat input less than or equal to 107.2 gigajoules per hour (100 million Btu/hour) are exempt from 40 CFR 60.332(a), which specify the standards for nitrogen oxides.

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 at the Clarksdale 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-013, AA-015, 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 Clarksdale Compressor Station has not undergone a modification that would trigger the NSPS.  Therefore, NSPS OOOOa is not applicable to the Clarksdale Compressor Station.  

SPECIFIC APPLICABLE REQUIREMENTS
Emission Points AA-001 through AA-007, AA-013, AA-015, and AA-016 are subject to state standards for PM and Opacity. Emission Points AA-013, AA-015, and AA-016 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 recordkeeping by documenting 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.

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001
through
AA-009	PM	E=0.8808*I -0.1667	Record type of fuel	
AA-009	Fuel Sulfur Content	≤ 0.8% sulfur by weight	Monitoring of operations	
	Fuel Restriction	Combust natural gas only	Monitoring of operations	
AA-013
AA-015	Operations	Emergency Operations	Monitoring of operations	
	Operations	Operational Requirements	Monitoring of operations	
AA-013
AA-015
AA-016	PM	0.6 lb/MMBTU	Record type of fuel	
	Operations	Operational Requirements	Monitoring of operations