INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
August 28, 2023

GENERAL FACILITY INFORMATION
Facility Name:  Tennessee Gas Pipeline Company LLC, Batesville Compressor Station No. 63
Facility Address:  
8450 Highway 6 West, Batesville, MS 38606    
County: Panola
SIC Code(s): 4922
NAICS Code(s): 486210  

APPLICATION SUMMARY 
Permit No.: 2100-00023
Permit Action: Renewal
Permit Folder: PER20230001
Application Receipt Date: August 1, 2023
Application Deemed Complete: August 25, 2023
CBI Submitted?: No	NSPS (Part 60): N/A
NESHAP (Part 61): N/A
NESHAP (Part 63): A, ZZZZ, DDDDD
112(r) / RMP: N/A
Other: N/A	

FACILITY DESCRIPTION
Tennessee Gas Pipeline Company owns and operates its Batesville Compressor Station No. 63 located on Highway 6 West in Batesville, Mississippi, for the purpose of transporting natural gas through its pipeline distribution system. The Batesville Compressor Station consists of significant sources of emissions from twenty-three (23) natural gas-fired compressor engines, one (1) natural gas-fired emergency backup generator engine, two (2) natural gas-fired jacket water heaters, one (1) natural gas-fired process water evaporator, one (1) natural gas-fired boiler, and one (1) parts degreaser. The Batesville Compressor Station also operates fresh glycol and jacket water tanks that circulate a glycol water mixture for removal of heat from the engines, one (1) gasoline storage tank, one (1) pipeline condensate tank, compressor engine blowdown, fugitive emissions from equipment, and numerous liquid product storage tanks qualifying as insignificant activities. The following table lists the significant emission points at the compressor station. The products of combustion from the combustion of natural gas in the facility’s compressor engines are the primary sources of pollutants, including VOC, NOx, CO, PM10/PM2.5, and HAPs.

Emission Point	Description	
AA-000	Facility Wide	
AA-008	1100 horsepower (hp) Cooper Bess Model GMV-10H two stroke lean burn (2SLB) spark ignition (SI) natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-2A)	
AA-009	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-3A)	
AA-010	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-4A)	
AA-011	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-5A)	
AA-012	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-6A)	
AA-013	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-7A)	
AA-014	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-8A)	
AA-015	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-9A)	
AA-016	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-10A)	
AA-017	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-11A)	
AA-018	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-1B)	
AA-019	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-2B)	
AA-020	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-3B)	
AA-021	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-4B)	
AA-022	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-5B)	
AA-023	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-6B)	
AA-024	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-7B)	
AA-025	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-8B)	
AA-026	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-9B)	
AA-027	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-10B)	
AA-028	1100 hp Cooper Bess Model GMV-10H 2SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-11B)	
AA-039	Natco 5.6 MMBTU/hr Jacket Water Heater (Serial # HLT-1P29001-01) (Ref. No. JWHPT-1)	
AA-049	7860 hp Wartsilla Model W18V34-SG-C four stroke lean burn (4SLB) spark ignition (SI) natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-1D)	
AA-050	7860 hp Wartsilla Model W18V34-SG-C 4SLB SI natural gas-fired non-emergency compressor engine (Ref. No. ENG PT-2D)	
AA-051	One 4.0 MMBTU Natco jacket water heater (Ref. No. JWHPT-2)	
AA-052	1462 hp Caterpillar Model 3516 SITA 4SLB SI natural gas-fired emergency power generating engine (Ref. No. 63-AUX5)	
AA-053	Parts Degreaser (Ref. No. DEGR.)	
AA-054	Pipeline Condensate Tank (Ref. No. AST-4)	
AA-055	Gasoline Tank (Ref. No. AST-11)	
AA-056	Glycol Tanks (Ref. No. AST-13 & AST-15)	
AA-057	Jacket Water Surge Tanks (Ref. No. AST-7, AST-8, AST-12, AST-14, ASR-16, AST-17)	
AA-058	2 MMBtu/hr Process Water Evaporator	
AB-000	Blowdown	
AC-000	Fugitives	

TITLE V SOURCE APPLICABILITY 
The Batesville Compressor Station No. 63 is a major Title V source because the facility’s potential-to-emit exceeds the Title V threshold of Carbon Monoxide (CO), Nitrogen Oxides (NOx), and Volatile Organic Compounds (VOC). 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 a single HAP (Formaldehyde).

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	Data Not Provided	
PM10	68.73	
PM2.5	68.73	
Sulfur Dioxide (SO2)	1.23	
Nitrogen Oxides (NOx)	4,041.59	
Carbon Monoxide (CO)	775.32	
Volatile Organic Compounds (VOC)	280.01	
Total Reduced Sulfur (TRS)	0	
Lead	0	
CFC/HCFC	0	
Total HAP 	171.41	
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 potential emissions of NOx, CO, and VOC from the existing equipment at the compressor station exceed the 250 tpy threshold and hence the facility is considered an "existing major source" for PSD permitting purposes. The facility is not proposing new construction or physical modifications with this Title V permit renewal application; thus, the PSD status of the facility is not changing. 

Emission Points AA-008 through AA-028 at the Station are considered grandfathered sources. Emission Points AA-049 and AA-050 were installed in 2000. The PSD regulation was deemed not applicable to the installation of these engines due to net emission reductions. 

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no proposed facility modifications in the draft permit. The changes to the current Title V permit include the following:
•	Emission Point AA-000 was redefined as facility wide to include all emission sources rather than only equipment fugitives.
•	Emission Point AA-051 was revised to reflect one (1) 4.0 MMBTUH natural gas fired jacket water heater instead of two (2) heaters.

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 Tennessee Gas Pipeline Company, New Albany Compressor Station Number 851.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
MACT Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines, 40 CFR Part 63, Subpart ZZZZ 

40 CFR 63, Subpart ZZZZ establishes national emission limitations and operating limitations for hazardous air pollutants (HAP) emitted from stationary reciprocating internal combustion engines (RICE) located at major and area sources of HAP emissions. 

Emission Points AA-008 through AA-028 are existing non-emergency spark ignition (SI) two stroke lean burn (2SLB) stationary RICE, each with a site rating of more than 500 brake HP located at a major source of HAP emissions and as such are not required to meet the requirements of 40 CFR Part 63, Subpart ZZZZ or the General Provisions in Subpart A.

Emission Points AA-049 and AA-050 are existing non-emergency spark ignition (SI) four stroke lean burn (4SLB) stationary RICE, each with a site rating of more than 500 brake HP located at a major source of HAP emissions and as such are not required to meet the requirements of 40 CFR Part 63, Subpart ZZZZ or the General Provisions in Subpart A.

Emission Point AA-052 is an existing emergency stationary RICE with a site rating of more than 500 brake HP located at a major source of HAP emissions and as such is not required to meet any requirements of 40 CFR Part 63, Subpart ZZZZ or the General Provisions in Subpart A, except for the emergency operational requirements.

MACT DDDDD - National Emission Standards for Hazardous Air Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters, Subpart DDDDD

40 CFR 63, Subpart DDDDD establishes national emission limitations and operating limitations for hazardous air pollutants (HAP) emitted from Industrial, Commercial, and Institutional Boilers and Process Heaters. 

Since the Batesville Compressor Station is a “Major” source of Hazardous Air Pollutant (HAP) emissions, the facility is subject to 40 CFR 63, Subpart DDDDD.  The facility has several insignificant space heaters; however, space heaters are not process heaters per the definition of process heaters in §63.7575, and thus are not subject to the requirements of 40 CFR Part 63, Subpart DDDDD.   

Emission Point AA-039 is an existing process heater with a heat input capacity of less than 10 MMBTU/hr, but greater than 5 MMBTU/hr, designed to burn natural gas.  As such, the heater does not have any applicable emission standards and only has to comply with the work practice standards of 40 CFR 63, Subpart DDDDD.  The process heater must have a tune-up completed biennially. The unit has completed the 1-time energy assessment and its initial tune-up.

Emission Point AA-051 is an existing process heater with a heat input capacity of less than 5 MMBTU/hr, designed to burn natural gas.  As such, the heater does not have any applicable emission standards and only has to comply with the work practice standards of 40 CFR 63, Subpart DDDDD.  The process heater must have a tune-up completed every 5-years.  The unit has completed the 1-time energy assessment and its initial tune-up.

40 CFR 63 Subpart HHH - National Emission Standards for Natural Gas Transmission and Storage Facilities
The NESHAP for Natural Gas Transmission and Storage Facilities establishes emission limitations and operating limitations for HAP emissions from 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, and that are major sources of HAP emissions.  The Batesville Compressor Station does not operate any glycol dehydrators; therefore; NESHAP HHH does not apply to the facility.

40 CFR 63 Subpart YYYY - National Emission Standards for Stationary Combustion Turbines
The NESHAP for Stationary Combustion Turbines establishes national emission limitations and operating limitations for HAP emissions from stationary combustion turbines located at major sources of HAP emissions, and requirements to demonstrate initial and continuous compliance with the emission and operating limitations.  The Batesville Compressor Station does not operate any turbines; therefore; NESHAP YYYY does not apply to the facility.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 Subpart Kb
The provisions of 40 CFR 60, Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984, are standards applicable to vessels used for storing volatile organic liquids.  Each of the facility’s liquid product storage tanks are below 19,800 gallons; therefore, none of the facility’s liquid product storage tanks are subject to NSPS Kb.

40 CFR 60 Subpart GG
The provisions of 40 CFR 60, Subpart GG – Standards of Performance 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 compressor station does not operate any turbines, therefore, the compressor station is not subject to any requirements of NSPS GG.

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 Batesville Compressor Station is not located at an onshore natural gas processing plant, as defined in 40 CFR 60.631, the compressor station is not subject to NSPS KKK.

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 twenty-three (23) RICE are stationary spark ignition internal combustion engines but were each constructed prior to the June 12, 2006, effective date.  Therefore, none of the compressor stations’ RICE are subject to any requirements of NSPS JJJJ.  

40 CFR 60 Subpart KKKK
The provisions of 40 CFR 60 Subpart KKKK - New Source Performance Standards for Stationary Combustion Turbines 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.  The compressor station does not operate any turbines, therefore, the compressor station is not subject to any requirements of NSPS KKKK.

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 (NSPS OOOO) are potentially applicable to owners and operators of onshore affected facilities that commence construction, modification, or reconstruction after August 23, 2011.  The only potentially affected sources at the Compressor Station are the facility’s compressor engines.  However, the compressor engines are not new and have not been modified or reconstructed after August 23, 2011; consequently, NSPS OOOO does not apply to the compressor station.

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 (NSPS OOOOa) are potentially applicable to new and modified sources in the oil and gas industry after August 18, 2015.  The only potentially affected sources at the Compressor Station are the facility’s compressor engines, with respect to Leak Detection and Repair (LDAR), and pneumatic controllers.  However, there have been no new compressors installed at the facility resulting in increased compression, nor has the facility modified any existing compressor engines or pneumatic controllers; consequently, NSPS OOOOa does not apply to the compressor station.

SPECIFIC APPLICABLE REQUIREMENTS
All significant air emission combustion sources are subject to state standards for PM and Opacity. Twenty-seven (27) of the air emission sources are fuel burning equipment. Emission Points AA-039, AA-051, and AA-058 are subject to an SO2 limit of 4.8 lbs/MMBTU. Emission Points AA-039, AA-051, AA-052 and AA-058 have a PM emission limitation of 0.6 lbs/MMBTU, because each source has a rated heat input less than 10 MMBTU/hr. Emission points AA-008 through AA-028, AA-049, and AA-050 each have a rated heat input greater than 10 MMBTU/hr and thus are subject to a particulate matter limit of E=0.8808 * I-0.1667 where E is the emission rate in lb/MMBTU/hr heat input and I is the heat input in MMBTU/hr.

The only fuel that is being used for the twenty-seven (27) significant air emission combustion sources is natural gas.  Since natural gas is a clean burning fuel, these units should have a large margin of compliance with the PM and Opacity standards.  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(s)	Pollutant / Parameter	Limit / Standard	Monitoring Requirements	
AA-008 through AA-028,
AA-049, and       AA-050	PM	E=0.8808*I-0.1667	Record Type and Quality of Fuel Used	
AA-039,   AA-051, AA-052,
and
AA-058	PM	0.6 lbs/MMBTU	Record Type and Quality of Fuel Used	
AA-039, AA-051,
and
 AA-058	SO2	4.8 lbs/MMBTU	Record Type and Quality of Fuel Used	
AA-039	HAP	Operational Requirement	Conduct Tune Ups biennially	
AA-051	HAP	Operational Requirement	Conduct Tune Ups every 5-years	
AA-052	HAP	Operating restriction	Record hours of operation and reason for operating