PERMIT REVIEW SUMMARY

Permit Writer:	Clinton Gentry				Date:	March 27, 2023

Company Name:	Southern Natural Gas Company, LLC
			Rose Hill Compressor Station

Facility Location:	To Be Determined
32° 8’ 30.79” N
88° 52’ 39.91” W

Source Number:	0440-00071

County: 		Clarke

FACILITY DESCRIPTION

Southern Natural Gas Company, LLC’s (Southern Natural Gas) Rose Hill Compressor station is natural gas transmission station categorized under SIC code 4922. The facility’s primary function is the transportation of natural gas along a pipeline by receiving low-pressure inlet natural gas and them compressing the gas to increase the pressure in the pipeline and maintain the downstream flow. The facility has the following emissions sources: one (1) natural gas fired emergency generator (Emission Point AA-001),  two (2) compressor turbines (Emission Points AA-002 and AA-003), one (1) turbine fuel line heater (Emission Point AA-004), miscellaneous space and water heaters (Emission Point AA-005), a pipeline condensate tank (Emission Point AA-006), a parts degreaser (Emission Point AA-007), pipe and equipment fugitives (Emission Point AA-008), Truck Loading (Emission Point AA-009), and emergency shutdown actives (Emission Point AA-010).

PROJECT/PERMIT ACTION DESCRIPTION
Southern Natural Gas has applied for a permit to construct as well as a true minor determination for their Rose Hill Compressor Station. The facility has an anticipated start of construction beginning in September 2023. 

EMISSION SUMMARY

Criteria Pollutant	Maximum Uncontrolled	Title V Threshold	
Carbon Monoxide (CO)	27.17	100	
Nitrogen Oxides (NOx)	24.87	100	
Sulfur Dioxide (SO2)	2.23	100	
Particulate Matter 10 (PM10)	4.34	100	
Volatile Organic Compounds (VOC)	12.66	100	
Total Hazardous Air Pollutants (HAP)	0.71	25	
*All emissions are expressed in units of tons per year (tpy)

As shown in the table above, Southern Natural Gas’ uncontrolled emissions fall well below their respective Title V thresholds. Due to this, the facility is not required to undertake any type of enforceable emissions limit and meets the applicability to be classified as a True Minor Source. However, since the facility’s emissions for CO, NOX and VOC are greater than 10% of the Title V threshold, the facility is required to obtain a construction permit. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR Part 60 Subpart Kb – Standards of Performance for Volatile Organic Liquid Storage Vessels
This subpart applies to owners and operators of storage vessels with capacities greater than or equal to 75 cubic meters (~19,813 gallons) that are used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification commenced after July 23, 1984. All tanks at the site are planned to be less than this threshold; therefore, this subpart does not apply.

40 CFR Part 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal Combustion Engines
This subpart applies to owners and operators of stationary spark ignition (SI) internal combustion engines (ICE). The Rose Hill Compressor Station will operate a 670 hp natural gas fired SI ICE and, therefore, will be subject to this subpart.

40 CFR Part 60 Subpart KKKK – Standards of Performance for Stationary Combustion Turbines.
This subpart applies to owners and operators of stationary combustion turbines that commenced construction, modification, or reconstruction after February 18, 2005. The proposed Taurus 70 Turbines will have an input grater than 10 MMBtu/hr each. Therefore, this facility is subject to this subpart.
40 CFR Part 60 Subpart OOOOa – Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification, or Reconstruction commenced after September 18, 2015.
This subpart applies to owners and operators of crude oil and natural gas production sources that commence construction, modification, or reconstruction after September 18, 2015. The Rose Hill Compressor Station is considered a natural gas compressor station and is part of the rule’s natural gas transmission segment. The facility will be subject to the regulations for fugitive emissions under this subpart.

NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

Due to the facility’s potential HAP emissions being below 25 tpy for all HAPs and 10 tpy for any individual HAP, Southern Natural Gas will be classified as an Area Source of HAPs.

40 CFR Part 63 Subpart HHH – National Emissions Standards for Hazardous Air Pollutants from Natural Gas Transmission and Storage Facilities.
This subpart applies to owners and operators of natural gas transmission and storage facilities that transport or store natural gas prior to entering the pipeline to a local distribution company or to a final end user. As such, this facility is potentially subject to this subpart. However, this facility does not operator a glycol dehydration unit which is the only “affected” source under this regulation. Therefore, this facility will not be subject to this subpart.

40 CFR Part 63 Subpart ZZZZ – National Emissions Standards for Hazardous Air Pollutants from Reciprocating Internal Combustion Engines (RICE).
This subpart applies to owners and operators of existing, new, or reconstructed stationary compression ignition (CI) and Spark ignition (SI), emergency and non-emergency RICE. As such, this facility is subject to this subpart. However, this facility will meet all applicable requirements under this subpart by complying with all applicable requirements under 40 CFR 60 Subpart JJJJ. No further requirements under Subpart ZZZZ will apply. 

PUBLIC PARTICIPATION

The 30-day public notice period began on public notice start date, with the publication of a notice in the Meridian Star and ends public notice end date.

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.