INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
December 8, 2022

GENERAL FACILITY INFORMATION
Facility Name:  Formentera Operations LLC, West Nancy Field Facility
Facility Address:  11570 County Road 280, Vossburg, MS 39366    
County: Clarke
SIC Code(s): 1311
NAICS Code(s): 21111   

APPLICATION SUMMARY 
Permit No.: 0440-00011
Permit Action:  Renewal with minor modification
Permit Folder: PER20220002
Application Receipt Date: 8/25/2022
Application Deemed Complete: 9/20/2022
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): A, ZZZZ
 112(r) / RMP: N/A
Other: Part 64 (CAM)	

FACILITY DESCRIPTION
The Formentera Operations LLC, West Nancy Field facility is an existing crude oil and natural gas production facility located in Vossburg, Mississippi (Clarke County).  The facility operates a power oil pump, water knockout separator, various tanks for storage of produced oil and water and a waste gas flare that combusts off-gases from the production process as referenced in the table below.  The flare also serves as a control device to control emissions of hydrogen sulfide (H2S) from the water knockout separator, process storage tanks, and truck loading activities.  Emissions from the storage tanks and truck loading are routed to the primary flare or to a vapor recovery unit (VRU) which collects the gas so that it can be compressed and transferred to a sales gas line, if available. Operations at the facility fall within SIC Code 1311.  The purpose of this permitting action is to renew the facility’s Title V Operating Permit.

Emission Point	Description	
AA-020	Tank truck loading process with emissions routed through a vapor recovery unit (VRU) to the flare, AA-034 (Ref. No. TTL)	
AA-025	300 barrel (12,600 gallon) fixed-roof crude oil storage tank with emissions routed through a VRU to Emission Point AA-034 (Ref. No. TK10)	
AA-026	300 barrel (12,600 gallon) fixed-roof crude oil storage tank with emissions routed through a VRU to Emission Point AA-034 (Ref. No. TK11)	
AA-027	300 barrel (12,600 gallon) fixed-roof crude oil storage tank with emissions routed through a VRU to Emission Point AA-034 (Ref. No. TK12)	
AA-030	1,500 barrel (63,000 gallon) fixed-roof crude oil storage tank with emissions routed through a VRU to Emission Point AA-034 (Ref. No. 22a-10-OST-CV)	
AA-031	400 barrel (16,800 gallon) fixed-roof bad crude oil storage tank with emissions routed through a VRU to Emission Point AA-034 (Ref. No. 22b-10-OST-CV)	
AA-032	400 barrel (16,800 gallon) fixed-roof bad crude oil storage tank with emissions routed through a VRU to Emission Point AA-034 (Ref. No. 22c-10-OST-CV)	
AA-033	Two (2), 400 barrel (16,800 gallon) fixed-roof produced water storage tanks with emissions routed through a VRU to Emission Point AA-034 (Ref. Nos. 22d-10-WST-CV and 22e-10-WST-CV)	
AA-034	Control flare to combust relief gas from the vapor recovery unit (VRU) which collects emissions from the process oil tanks and the tank truck loading process. The flare also handles VRU discharge during gas line downtime and during process upsets. (Ref. No. 23-10-F)	
AA-035	Fugitive emissions from process equipment and components (Ref. No. FE-01)	
AA-036	300 barrel (12,600 gallon) fixed-roof crude oil storage tank with emissions routed through a VRU to Emission Point AA-034 (Ref. No. 22f-22-OST-CV)	
AA-037	Water knockout with low pressure relief gas routed to Emission Point AA-034	
AA-038	625 HP (5.24 MMBTU/hr) Caterpillar sweet natural gas-fired four-stroke rich-burn (4SRB) power oil pump reciprocating internal combustion engine (RICE) (Ref. No. 26-19-ICE-ES)	

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 the criteria air pollutant Sulfur Dioxide (SO2).  The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the Title V major source thresholds of 25 tpy of total HAPs or 10 tpy for any individual HAP since all gas is required to be routed to the flare for combustion by 11 Miss. Admin. Code Pt. 2, R. 1.4.B(2).

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	0.37	
PM10	0.60	
PM2.5	0.60	
Sulfur Dioxide (SO2)	231.03	
Nitrogen Oxides (NOx)	62.03	
Carbon Monoxide (CO)	70.35	
Volatile Organic Compounds (VOC)	14.18	
Total Reduced Sulfur (TRS)	3.70	
Lead	0.00	
CFC/HCFC	0.00	
Total HAP 	1.8	
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 less than 250 tpy of each of the regulated NSR pollutants; therefore, it is an existing minor source under the PSD program.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
The heater treater has been replaced with a water knockout separator with the gas from the knockout routed to the flare. Facility emissions were not affected by this change since the heater treater was unfired. The water knockout separator has been designated as Emission Point AA-021, previously described as “low pressure relief gas”. Four smaller engines used for pumping the well (Emission Points AA-001 through AA-004), 202 hp each, have been replaced by one 625 hp engine designated as Emission Point AA-038, with associated permit requirements. A 300 barrel (bbl) (12,600 gallon) oil storage tank has also been added (Emission Point AA-036) at the facility.

The following additional changes were made to the permit:
•	A new CAM plan was provided and incorporated in the permit. 
•	References to a hydrogen sulfide concentration limit in the gas after combustion in the flare were removed (see old permit Conditions 5.B.5 and 5.C.3) since there is no regulatory limit on hydrogen sulfide concentration in the combusted flare gas. 11 Miss. Admin. Code Pt. 2, R. 1.4.B(2) is a work practice standard which requires incineration of gas streams which exceed 1 grain/100 SCF.
•	New Condition 3.B.2 was added requiring efficient operation of air emission equipment and routine maintenance.
•	New Condition 3.B.4 was added containing requirements for the flare, Emission point AA-034.
•	New Condition 3.B.5 was added to incorporate CAM applicability,
•	New Condition 3.B.7 was added to restrict the fuel for Emission Point AA-038 to pipeline quality natural gas or propane.
•	A new Section D., Work Practice Standards, was added to incorporate requirements from 40 CFR 63, Subpart ZZZZ.
•	The calibration frequency requirement for monitors and flow meters used to determine flare gas flow in Condition 5.B.1 was changed from “at least monthly” to “at least quarterly” to mirror the requirements from 40 CFR 60, Subpart A, Appendix F for flow meters.
•	Condition 5.B.2 contains new language to disallow the collection of a flare gas sample for H2S analysis during truck loading events. It is believed that sampling during truck loading would produce results not appropriate for use in emissions calculations for an entire month due to the intermittent nature of the truck loading emissions.
•	New Condition 5.B.3 was added to require annual sampling of the flare gas to demonstrate that the heating value continues to meet 200 Btu/ SCF minimum requirement of Condition 3.B.4(e). 
•	New Condition 5.B.5 was added to require monthly visible emissions testing of the flare.
•	New Condition 5.B.6 was added containing specific requirements for the flare auto-igniter system.
•	New Condition 5.B. 8 was added containing specific requirements for recordkeeping associated with the flare system.
•	New Conditions 5.B.9, 5.B.10, 5.B.11 and 5.B.12 were added to address specific CAM requirements. 
•	Reporting requirements for Method 22 testing are included in new permit Condition 5.C.1(b)
•	Reporting requirements for the auto-igniter system and the H2S monitor system were included in permit Condition 5.C.1(c).
•	New Condition 5.C.2 was added to require reporting of CAM exceedances and excursions, and information regarding implementation of a CAM QIP, if applicable.
•	New Condition 5.C.4 requires reporting of fuel type and quality for Emission Point AA-038 specifically, instead of facility-wide as previously required, since the engine fuel is restricted by permit Condition 3.B.7.
•	New Condition 5.C.5 was added to require reporting of the results of the annual evaluation of the remote status of the   pump engine, Emission Point AA-038.
•	Emission Point AA-021, which was associated with a heater treater removed from service, was removed from the permit. A new Emission Point AA-037 was added to incorporate the water knockout unit which was added to the process.

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.

The facility flare is utilized as a control device to burn gas containing greater than 1 grain of H2S/100 Scf. The requirement to burn off gases is considered to be a work practice. As defined in the CAM regulation at 40 CFR 64.1, an emission limitation may be expressed in the form of a work practice, process parameter, or other form of specific design. Thus, all three criteria are met and CAM is applicable and shall be utilized to ensure compliance with the requirement to burn the off gases. The parameters chosen to indicate that off gases are being burned shall be the presence of a flame or spark at the flare tip and a H2S concentration less than 10 ppm at the flare tip when off gases are being vented,

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 HH
40 CFR 63, Subpart HH — National Emissions Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities applies to specific emission sources at both major and area sources of HAPs that are at an oil and natural gas production facility.  While the facility is an area source for HAPs, it does not operate a triethylene glycol (TEG) dehydration unit; therefore, the facility is not subject to the requirements of Subpart HH.

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 Point AA-038 is an existing four stroke rich burn (4SRB) remote spark ignition stationary RICE with a site rating greater than 500 brake HP located at an area source of HAP emissions and as such is required to meet the scheduled maintenance and operational requirements of 40 CFR Part 63, Subpart ZZZZ and the General Provisions in Subpart A.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 SUBPART Kb
The provisions of 40 CFR 60 Subpart Kb - New Source Performance Standards for Volatile Organic Liquid Storage Vessels for which Construction, Reconstruction, or Modification Commenced after July 3, 1984.  All storage tanks at the facility are each less than 420,000 gallons and are used to store petroleum or condensate stored, processed, or treated prior to custody transfer; therefore, per 40 CFR 60.110b(d)(4), the facility is not subject to NSPS Kb.

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 Point AA-038 was constructed prior to June 12, 2006; therefore, the facility is not subject to NSPS JJJJ.

40 CFR 60 SUBPART OOOO
The provisions of 40 CFR 60 Subpart OOOO - New Source Performance Standards 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.  The facility was constructed prior to the applicability date; therefore, the facility is not subject to NSPS OOOO.

40 CFR 60 SUBPART OOOOa
The provisions of 40 CFR 60 Subpart OOOOa - New Source Performance Standards for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction Commenced after September 18, 2015.  The facility was constructed prior to the applicability date, except for Emission Point AA-037 (300 bbl crude oil storage tank).  Emission Point AA-037 was constructed in 2018.  This tank receives oil overflowing from the power oil tank, hence there are no flash emissions and the annual VOC emissions are less than 6 tons; therefore, the facility is not subject to NSPS OOOOa.

SPECIFIC APPLICABLE REQUIREMENTS

Emission Point(s)	Pollutant/ Parameter	Limit/Standard	Monitoring Requirements	
Facility Wide	H2S	Operating Requirement	Compliance Assurance Monitoring Requirements:	
AA-034	H2S	Operating Requirement	Compliance Assurance Monitoring Requirements:	
AA-034	Operational Restriction	Operating Requirement	Operational Requirements	
AA-034	SO2	70 lb/hr (24-hr average)	Monitoring of operations	
AA-038	Operational Restriction	Operating Requirement	Operational Requirements	
AA-038	PM	0.6 lb/MMBTU	Record Type and Quantify of Fuel Used