DRAFT PERMIT REVIEW SUMMARY

Permit Writer:	Thomas Parker 	Date:	July 11, 2025

Company Name:	BBT Mississippi LLC, Baxterville Compressor Station

Facility Location:	1017 Clear Creek Church Road, Columbia, MS  39429

Source Number:	1440-00049

County: 		Marion

FACILITY DESCRIPTION

BBT Mississippi LLC (BBT) proposes to construct the new Baxterville Compressor Station near Columbia, Mississippi. The Baxterville Compressor Station will provide end-user natural gas to customers in and around the Baxterville Field of Lamar and Marion counties. The Baxterville Compressor Station can process up to 345,000 MMBtu/day of sweet natural gas. At the compressor station, waste oil, water, and condensate liquids (from routine maintenance operations) will be loaded, as necessary, onto trucks for disposal. There will be two (2) liquid storage tanks for purposes of maintenance activities and one (1) emergency backup generator engine. Gas will be compressed using one (1) compressor engine.  The following table includes the emission points at the facility.

Emission Point	Description	
AA-001	1,380-Horsepower (HP) 2022 Caterpillar Model 3516J natural gas-fired, four-stroke, lean burn (4SLB) compressor engine with emissions controlled by an oxidation catalyst. [Facility ID No. C-1]	
AA-002	122-HP 2025 Generac natural gas-fired emergency generator engine for 80-kiloWatt (kW) Model SG080 Genset. [Facility ID No. G-1]	
AA-003	8,820-gallon (50-barrel) Condensate Storage Tank for Maintenance Purposes [Facility ID No. Tk-1]	
AA-004	8,820-gallon (50-barrel) Oil Storage Tank for Maintenance Purposes [Facility ID No. Tk-2]	
AA-005	Fugitive emissions from equipment leaks	
AA-006	Compressor driven by Emission Point AA-001 [Facility ID No. CPR-1]	
AA-007	Startup, Shutdown, Maintenance Emissions [Facility ID No. SSM-1]	
AA-008	Liquids Truck Loading [Facility ID No. LOAD-1]	

PROJECT/PERMIT ACTION DESCRIPTION

BBT is classified as a True minor source with respect to Title V of the Federal Clean Air Act. The facility has the uncontrolled potential to emit less than 100 tons per year (tpy) of all criteria pollutants and less than 25 tpy of combined hazardous air pollutants (HAPs), as well as less than 10 tpy of each individual HAP.

EMISSION SUMMARY

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	0.49	
PM10	0.49	
PM2.5	0.49	
Sulfur Dioxide (SO2)	0.03	
Nitrogen Oxides (NOx)	6.72	
Carbon Monoxide (CO)	13.45	
Volatile Organic Compounds (VOC)	12.91	
Formaldehyde	2.67	
Total HAP 	2.74	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

APPLICABLE/PROPOSED PERMIT LIMITATIONS

The compressor engine (Emission Point AA-001) is also limited to 1.0 g/HP-hr NOx emissions, 2.0 g/HP-hr CO emissions, and 0.7 g/HP-hr VOC emissions in order to comply with 40 CFR 60, Subpart JJJJ emission limitations. The facility is required to conduct performance stack testing every 8,760 hours of operation, or 3 years, whichever comes first.

NSPS APPLICABILITY

40 CFR 60 Subpart IIII
The provisions of 40 CFR 60 Subpart IIII - New Source Performance Standards for Compression Ignition Internal Combustion Engines (NSPS IIII) are applicable to stationary compression ignition internal combustion engines that commenced construction, modification, or reconstruction after April 1, 2006.  None of the compressor station’s engines are compression ignition internal combustion engines, therefore, none of the compressor station’s engines are subject to any requirements of NSPS IIII.  

40 CFR 60 Subpart JJJJ
The provisions of 40 CFR 60 Subpart JJJJ - New Source Performance Standards for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ) are applicable to stationary spark ignition internal combustion engines that commenced construction, modification, or reconstruction after June 12, 2006.  The compressor engine (Emission Point AA-001) was reconstructed in 2022, and the emergency generator engine (Emission Point AA-002) was manufactured in 2025.  Therefore, each engine is subject to emission standards for NOx, CO and VOC. The standards applicable to the engines from Table 1 of NSPS Subpart JJJJ are shown in the table below.

Non-Emergency Engine Manufactured after 7/1/10 (Emission Point AA-001)	
Pollutant	Emission Standard	Emission Standard	
NOx	1.0 g/BHP-HR	82 ppmvd @ 15% O2	
CO	2.0 g/BHP-HR	270 ppmvd@15% O2	
VOC	0.7 g/BHP-HR	60 ppmvd@15% O2	
Emergency Engine (25<HP<130) Manufactured after 1/1/09 (Emission Point AA-002)	
NOX + HC	10 g/BHP-HR	N/A	
CO	387 g/BHP-HR	N/A	
VOC	N/A	N/A	

To demonstrate compliance with the emission standards in NSPS Subpart JJJJ, the facility purchased a non-certified engine for Emission Point AA-001. Therefore, an initial performance test is required to be conducted followed by subsequent testing to demonstrate compliance with the standards. A maintenance plan must also be developed and records kept demonstrating proper maintenance procedures are followed.

To demonstrate compliance with the emission standards in NSPS Subpart JJJJ, the facility will purchase a certified engine for Emission Point AA-002.

40 CFR 60 Subpart KKK
The provisions of 40 CFR 60, Subpart KKK - Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants (NSPS KKK) apply to affected facilities in onshore natural gas processing plants that commences construction, reconstruction, or modification after January 20, 1984, and on or before August 23, 2011.  Since the Baxterville Compressor Station is not located at an onshore natural gas processing plant, as defined in 40 CFR 60.631, the Baxterville Compressor Station is not subject to NSPS KKK.

40 CFR 60 Subpart OOOO
The provisions of 40 CFR 60, Subpart OOOO - Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification, or Reconstruction Commenced After August 23, 2011, and on or Before September 18, 2015 (NSPS OOOO) are potentially applicable to owners and operators of onshore affected facilities that commence construction, modification, or reconstruction between August 23, 2011, and September 18, 2015.  Since the facility’s construction date is after September 18, 2015, no sources at the compressor station are 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 and On or Before December 6, 2022 (NSPS OOOOa) are potentially applicable to new and modified sources in the oil and gas industry between August 18, 2015, and December 6, 2022.  Since the facility’s construction date is after December 6, 2022, no sources at the compressor station are subject to any requirements of NSPS OOOOa.

40 CFR 60 Subpart OOOOb
The provisions of 40 CFR 60, Subpart OOOOb - Standards of Performance for Crude Oil and Natural Gas Facilities for Which Construction, Modification or Reconstruction Commenced After December 6, 2022 (NSPS OOOOb) are potentially applicable to new and modified sources in the oil and gas industry after December 6, 2022. 

The date of construction and installation of the compressor is after December 6, 2022; therefore, the compressor’s rod packing will be required to be replaced every 26,000 hours/36 months. Subpart OOOOb also requires the volumetric flow rate of each cylinder not exceed two (2) standard cubic feet per minute (scfm). This rate is used to dictate when rod packing must be repaired or replaced.

The storage vessels at the site will only be used to capture liquids during maintenance activities and will be used for any purposes of a storage vessel defined in 40 CFR 60.5430b; therefore, the storage vessels are not subject to NSPS OOOOb.

The fugitive emissions components are the components (e.g., pumps, valves, and connectors) assembled to support a process unit, which is a unit (e.g., natural gas processing) that can operate independently if supplied with sufficient feed and storage. The fugitive emissions components at the Baxterville Compressor Station will be constructed after the NSPS OOOOb effective date. Therefore, the fugitive emission components (Emission Point AA-005) are subject to the LDAR requirements of NSPS OOOOb.

40 CFR 60 Subpart Kc
The provisions of 40 CFR 60, Subpart Kc - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After October 4, 2023, are standards applicable to vessels used for storing volatile organic liquids.  The facility’s maintenance liquids storage tanks are each below 20,000 gallons; therefore, the facility’s maintenance liquids storage tanks are not subject to NSPS Kc.

MACT APPLICABILITY

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is an area source of Hazardous Air Pollutants (HAP) since the facility does not have the potential to emit more than 25 tons per year of total HAPs or 10 tpy of any individual HAP.

40 CFR 63 Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines
The Reciprocating Internal Combustion Engines (RICE) NESHAP, Subpart ZZZZ, regulates HAP emissions from RICE.

Emission Point AA-001 is considered a new, spark ignition, 4-stroke lean-burn, non-emergency engine, with a site rating greater than 500 HP that is located at an area source of HAP emissions. As such, the engine must meet the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR 60, subpart JJJJ, for spark ignition engines. No further requirements apply for such engines under 40 CFR 63 Subpart ZZZZ or the General Provisions of Subpart A.

Emission Point AA-002 is considered a new, spark ignition, 4-stroke lean-burn, emergency engine with a site rating less than 500 HP that is located at an area source of HAP emissions. As such, the engine must also meet the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR 60, subpart JJJJ, for spark ignition engines. No further requirements apply for such engines under 40 CFR 63 Subpart ZZZZ or the General Provisions of Subpart A.

40 CFR 63 Subpart JJJJJJ - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources
Since the Baxterville Compressor Station is an area source of Hazardous Air Pollutant (HAP) emissions, the facility is potentially subject to 40 CFR 63, Subpart JJJJJJ However, since the Compressor Station does not operate any boilers, none of the facility’s combustion sources are subject to Subpart JJJJJJ or to any requirements in Subpart JJJJJJ.

40 CFR 63 Subpart HHH - National Emission Standards for Hazardous Air Pollutants From Oil and Natural Gas Production Facilities
NESHAP HHH does not apply to this facility because it is not a major source of HAPs, and there are no glycol dehydration units at the facility. 

PUBLIC PARTICIPATION

The 30-day public notice period began on October 1, 2025, when the notice was posted on MDEQ’s website and ends October 31, 2025.

RECOMMENDATION

The staff has preliminarily decided to recommend issuance of the permit to the Mississippi Environmental Quality Permit Board as shown in the draft permit. However, the staff recommendation to the Board will be made only after a thorough consideration of all public comments.