INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
August 18, 2026

GENERAL FACILITY INFORMATION
Facility Name:  Cooperative Energy, a Mississippi electric cooperative, Sylvarena Generating Plant
Facility Address:  
3012 Smith County Road 97
Bay Springs, MS 39422    
County: Smith
SIC Code(s): 4911
NAICS Code(s): 221112  

APPLICATION SUMMARY 
Permit No.: 2500-00048
Permit Action:  Modification
Permit Folder: PER20260003
Application Receipt Date: March 12, 2026
Application Deemed Complete: May 1, 2026
CBI Submitted?: No	NSPS (Part 60): Subpart A, Subpart GG, Subpart IIII
NESHAP (Part 61): N/A
NESHAP (Part 63): Subpart A, Subpart ZZZZ
112(r) / RMP: N/A
Other: Acid Rain, CSAPR	

FACILITY DESCRIPTION
Cooperative Energy operates the Sylvarena Generating Plant (“SGP” or “Sylvarena”) in Smith County, MS, where the facility has nominal generation capacity of 129 megawatts (MW). A Permit to Construct was issued May 29, 2002, and the initial Title V Operating Permit (TVOP) was issued June 10, 2009 with subsequent reissuances occurring in 2017 and 2022. SGP operates under TVOP Air Ref. No. 2500-00048.

Electricity generation is supplied by three 417.7 MMBtu/hr Natural Gas-Fired Simple Cycle Combustion Turbines (Emission Points AA-001, AA-002, and AA-003). Emission Points AA-001, AA-002, and AA-003 are monitored by a Continuous Emission Monitoring System (CEMS) and Nitrogen Oxide (NOx) emissions are controlled by water injection. Each turbine is operated in conjunction with a respective 2-cell Mechanical Draft Cooling Tower (Emission Point AA-006). SGP employs a 6.6 MMBtu/hr Diesel-fired 4-Stroke Blackstart Emergency Generator (Emission Point AA-004) and a 1.32 MMBtu/hr Diesel- fired 4-Stroke Emergency Fire Pump (Emission Point AA-007) for emergency situations. The combustion turbines, emergency engines, and cooling towers are sources of Particulate Matter (PM), PM less than 10 micrometers (μm) in diameter (PM10), PM less than 2.5 μm in diameter (PM2.5), Sulfur Dioxide (SO2), Nitrogen Oxide (NOx), Carbon Monoxide (CO), Volatile Organic Compounds (VOC), and HAP emissions. 

Emission Point	Description	
AA-001	417.7 MMBtu/hr Natural Gas-Fired Simple Cycle Combustion Turbine
Continuous Emission Monitoring System with Water Injection for NOx emissions control
Construction Date: April 1, 2002                                                                                                               New combustors: TBD	
AA-002	417.7 MMBtu/hr Natural Gas-Fired Simple Cycle Combustion Turbine
Continuous Emission Monitoring System with Water Injection for NOx emissions control
Construction Date: April 1, 2002                                                                                                                    New combustors: TBD	
AA-003	417.7 MMBtu/hr Natural Gas-Fired Simple Cycle Combustion Turbine
Continuous Emission Monitoring System with Water Injection for NOx emissions control
Construction Date: April 1, 2002                                                                                                                    New combustors: TBD	
AA-004	6.6 MMBtu/hr (896 hp) Emergency Generator
Diesel-fired 4-Stroke Blackstart Compression Ignition Combustion Engine
Non-resettable Hour Meter
Construction Date: April 1, 2002	
AA-006	Three (3) 2-cell Mechanical Draft Cooling Towers
Replaced (like-kind): 2026	
AA-007	1.32 MMBtu/hr (189 hp) Emergency Fire Pump
Diesel-fired Compression Ignition Combustion Engine
Construction Date: 2025	

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: Nitrogen Oxides (NOX) and Carbon Monoxide (CO). 

The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the major source thresholds of 25 tpy of total HAPs and 10 tpy for any individual HAP.

Facility-Wide Potential-to-Emit Summary1
Pollutant	Pre-replacement Proposed Controlled Emissions (tons/yr)	Post-replacement Proposed Controlled Emissions (tons/yr)	
Particulate Matter (TSP)	144.86	10.46	
PM10	144.86	22.52	
PM2.5	144.86	19.37	
Sulfur Dioxide (SO2)	34.28	2.18	
Nitrogen Oxides (NOx)	173.99	240.4	
Carbon Monoxide (CO)	242.59	244.5	
Volatile Organic Compounds (VOC)	197.82	8.18	
Total HAP 	7.35	2.77	
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 CO and NOX but will continue to limit facility-wide emissions of those pollutants to 244.5 and 240.4 tpy respectively and a combined operating hours to 11,133 hours per year (hrs/yr), as determined on a 365-day rolling total, after the replacement of the final combustor. The permit had previously contained conditions 3.B.2, 3.B.3, and 3.B.4. Those conditions still exist but have been changed to reflect the new emissions due to the replacement of the combustors. Previously, the facility was permitted to run 9000 hours per year, had a higher NOX emission limit on a ppm basis, and a lower CO emission limit due to a lower amount of permitted operating hours. The new limits, after the installation of the final combustor, reflect the manufacturer guarantees on the new combustors NOX emissions and allow for increased number of operating hours overall which will increase the overall emissions. The existing limits will remain in place until all combustors have been replaced in AA-001, AA-002, and AA-003. 

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 proposes to replace and upgrade the combustors in the combustion turbines (Emission Points AA-001 through AA-003) and a like-kind replacement of the cooling towers (AA-006). The facility also replaced the fire pump engine (AA-005) with a new engine (AA-007) in 2025. 

The combustors will be replaced over a period of approximately 3 years due to the supply chain of the parts. However, the facility has asked to have all three modifications done at the same time as the permit renewal. Therefore, sunsetting language has been added to Conditions 3.B.2, 3.B.3, 3.B.4, and 5.B.3 to reflect the emission limits both before the combustors are replaced, during the replacement process, and after the final combustor has been replaced. Cooperative Energy has provided an estimate of a timeline in their facility comments dated Aug. 18, 2026 and attached to Ensite as “18 AUG 2026 Facility Comments.” 

This modification will be processed at the same time as the permit renewal. The permit renewal application was submitted on August 18, 2026 and due in November 2026. To prevent repeatedly opening the permit, the facility requested and was accommodated with an early renewal. 

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, so Compliance Assurance Monitoring does not apply.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

National Emission Standards Hazardous Air Pollutants for Stationary Combustion Turbines (40 CFR 63, Subpart YYYY) 
Subpart YYYY establishes national emission limitations and operating limitations for hazardous air pollutants (HAP) emissions from stationary combustion turbines located at major sources of HAP emissions. The facility is a minor source of HAP emissions. Therefore, the provisions of Subpart YYYY do not apply.

National Emission Standards Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR 63, Subpart ZZZZ) 
The National Emission Standards Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (40 CFR 63, Subpart ZZZZ) establishes national emission limitations and operating limitations for HAP emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. SGP is an area source of HAP emissions because the facility generates less than 10 tpy for individual HAP and less 25 tpy for total HAP. Emission Points AA-004 and AA-007 are emergency stationary reciprocating internal combustion engines and are subject to and shall comply with 40 CFR 63, Subpart ZZZZ.

Emission Point AA-004 is an existing RICE located at an area source of HAPs and is subject to the work practice standards and the emergency engine hourly operational restrictions. 

Emission Point AA-007 is a new RICE located at an area source of HAPs. Therefore, compliance with 40 CFR Part 63, Subpart ZZZZ shall be achieved by meeting all applicable requirements of 40 CFR Part 60, Subpart IIII. No further requirements apply for such engines under NESHAP Subpart ZZZZ.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

Standards of Performance for Stationary Gas Turbines (40 CFR 60, Subpart GG)
The Standards of Performance for Stationary Gas Turbines (40 CFR 60, Subpart GG) were promulgated to regulate NOx and SO2 emissions generated by stationary gas turbines. Subpart GG applies to all stationary gas turbines with a heat input at peak load equal to or greater than 10.7 gigajoules (10 MMBtu/hr), based on the lower heating value of the fuel fired, that commences construction, modification, or reconstruction after October 3, 1977. Emission Points AA-001, AA-002, and AA-003 have heat inputs greater than 10 MMBtu/hr and were constructed after 1977; therefore, the stationary gas turbines are subject to 40 CFR 60, Subpart GG. Emission Points AA-001, AA-002, and AA-003 are subject to NOx emission standards and fuel sulfur standards. SGP will use water injection to control NOx emissions from each turbine, so in accordance with 40 CFR 60, Subpart GG the permittee is required to install and maintain a Continuous Emission Monitoring System (CEMS). The permittee will be subject to and shall comply with all applicable requirements of 40 CFR Part 75 for the CEMS. Therefore, the provisions of Subpart GG apply.

Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (40 CFR 60, Subpart IIII)
The Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (40 CFR 60, Subpart IIII) establish emission limitations and management practices for stationary compression ignition internal combustion engines which were constructed after July 11, 2005. Emission Points AA-004 and AA-007 are stationary compression ignition internal combustion engines and as such, are potentially subject to this subpart. Emission Point AA-004 was manufactured and constructed before 2005, and is not subject to 40 CFR 60, Subpart IIII. Emission Point AA-007 was manufactured and constructed after 2005, and is subject to 40 CFR 60, Subpart IIII.

Standards of Performance for Stationary Combustion Turbines (40 CFR 60, Subpart KKKK)
Subpart KKKK establishes emission standards and compliance schedules for the control of emissions from stationary combustion turbines that commenced construction, modification or reconstruction after February 18, 2005. Emission Points AA-001, AA-002, and AA-003 are being fitted with new combustors in 2026. The project will allow for the increase in emissions of NOX and CO by increasing the overall run time of the compressors. However, the new combustors are more efficient and the PTE based on 8760 hr/year will result in a decrease of emissions. Therefore, this is not a modification project. Therefore, the provisions of Subpart KKKK do not apply.

Standards of Performance for Stationary Combustion Turbines (40 CFR 60, Subpart KKKKa)
Subpart KKKKa establishes emission standards and compliance schedules for the control of emissions from stationary combustion turbines that commenced construction, modification, or reconstruction after December 13, 2024. Emission Points AA-001, AA-002, and AA-003 are being fitted with new combustors in 2026. The project will allow for the increase in emissions of NOX and CO by increasing the overall run time of the compressors. However, the new combustors are more efficient and the PTE based on 8760 hr/year will result in a decrease of emissions. Therefore, this is not a modification and the provisions of Subpart KKKKa will not apply to the project. 

Standards of Performance for Greenhouse Gas Emissions for Electric Generating Units (40 CFR 60, Subpart TTTT)
Subpart TTTT establishes emission standards and compliance schedules for the control of greenhouse gas (GHG) emissions from a steam generating unit or an integrated gasification combined cycle (IGCC) facility that commences construction after January 8, 2014, commences reconstruction after June 18, 2014, or commences modification after January 8, 2014, but on or before May 23, 2023. The facility will be modified after May 23, 2023. Therefore, the provisions of Subpart TTTT do not apply.

Standards of Performance for Greenhouse Gas Emissions for Modified Coal-Fired Steam Electric Generating Units and New Construction and Reconstruction Stationary Combustion Turbine Electric Generating Units (40 CFR 60, Subpart TTTTa)
Subpart TTTTa establishes emission standards and compliance schedules for the control of greenhouse gas (GHG) emissions from a coal-fired steam generating unit or integrated gasification combined cycle facility (IGCC) that commences modification after May 23, 2023. The GHG standards included in this subpart apply to any steam generating unit or IGCC that combusts coal and that commences modification after May 23, 2023 and The GHG standards included in this subpart also apply to any stationary combustion turbine that commences construction or reconstruction after May 23, 2023, that meets the relevant applicability conditions in 40 CFR 60.5509a(a)(1) and (2). The facility is an electric generating unit (EGU) that has a base load rating greater than 250 MMBTU/hr and has a nominal generation capacity of 129 MW but the facility uses natural gas not coal. Therefore, the provisions of Subpart TTTTa do not apply.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
AA-001
AA-002
AA-003	PM	E = 0.8808 * I-0.1667	Monitoring and recordkeeping	
	Operation Restriction	11,133 hours per year	Monitor and record hours	
	NOX	25 PPM at 15% O2, 240.4 tpy	CEMS, Recordkeeping	
	CO	40 PPM at 15% O2, 244.5 tpy	Biennial Stack test, one time stack test	
	Fuel Restriction	Natural Gas only	Recordkeeping	
	NOX	NOx ≤ 0.0075*(14.4/Y) + F; expressed as percent by volume at 15% O2 on a dry basis 	CEMS	
	Fuel Sulfur Content	0.8 percent by weight	Monitoring and recordkeeping	
	NOX	CSAPR applicability	CEMS	
AA-004	HAP	Safety and Good Air Pollution Control Practices	Recordkeeping	
		Operational Requirement	Recordkeeping	
		Install and Maintain a Non-Resettable Hour Meter	Recordkeeping	
AA-004	HAP	Emergency Engine Standards	Recordkeeping	
AA-007	NMHC                     NOX               CO                    PM	Emissions Standards	Recordkeeping	
	Fuel Requirement	Diesel fuel standards:
a)	Max sulfur content of 15 ppm, and
b)	Minimum cetane index of 40 or a maximum aromatic content of 35 volume percent	Recordkeeping	
	NOX                  CO	Purchase certified engine	Recordkeeping	
	Hours of Operation	Operating Requirements	Recordkeeping	

OTHER REQUIREMENTS:
•	Emission Points AA-001, AA-002, AA-003, AA-004, and AA-007 are subject to State Standards for PM emissions; however, the equipment should have a large margin of compliance because the emissions sources are burning natural gas and low sulfur diesel. No additional monitoring is proposed.
•	The permittee is subject to and shall comply with all applicable requirements of 40 CFR Part 72 through 78 – Acid Rain Program and Continuous Emission Monitoring System regulations. The permittee submitted a complete Acid Rain Program application and the Acid Rain Permit is attached to the TVOP.
•	The permittee is subject to and shall comply with all applicable requirements of 40 CFR Part 97 - Cross-State Air Pollution Rule (CSAPR) Monitoring Provisions.