mojave desert ir quality management district

1 Preliminary Determination/Decision - Statement of Basis

SCG – South Needles Compressor Station; Revised 01-11-21

MOJAVE DESERT

AIR QUALITY MANAGEMENT DISTRICT

Preliminary Determination/Decision - Statement of Basis for

Renewal and Modification to

FOP Number: 3100068 For:

Southern California Gas Company Facility:

South Needles Compressor Station Facility Address:

11 miles south of Needles, CA on

Hwy. 95, 92363

(East side of Hwy 95)

Document Date: 01-11-21

Submittal date to EPA/CARB for review on or before 01-12-21

EPA/CARB 45-day Commenting Period ends: 02-26-21

Public Notice Posted on or before: 01-19-21

Public Commenting Period ends: 02-18-21

Permit Issue date: On or about 03-01-21

Permitting Engineer:

Samuel J Oktay, PE

[email protected]

14306 PARK AVENUE, VICTORVILLE, CALIFORNIA 92392 PHONE: (760) 245-1661 • FAX: (760) 245-2022 • EMAIL: [email protected]



A. Facility Information

Owner/Company Name: SOUTHERN CALIFORNIA GAS COMPANY

Owner Mailing Address: Southern California Gas Company

P.O. Box 2300 SC-9314, Chatsworth CA 91313

Facility Name: South Needles Compressor Station

Facility Location: 11 miles south of Needles, CA on Hwy. 95, 92363

(East side of Hwy 95)

MDAQMD Federal Operating Permit Number: 3100068

MDAQMD Company Number: 0031

MDAQMD Facility Number: 00068

Responsible Official: Mr. Firas Hamze

Title: Field Operations Manager

Phone Number: 562-477-1107

Phone Number: (760) 243-6574

Facility “Site” Contact #1: Justin Griffis

Phone Number: (760) 243-6561

Facility “Site” Contact #2: Alison Wong

Title: Senior Environmental Specialist

Phone Number: 213-604-4534

e-mail: [email protected]

Facility “Off Site” Contacts: Chanice Allen

Phone Number: (213) 276-5047

e-mail: [email protected]

Nature of Business: Natural Gas Compression and Transmission

SIC/NAICS Code: 4922/486210 – Pipeline Transmission of

Natural Gas

Facility Location: UTM (Km) 718.729E / 3841.635N

DECIMAL COORDINATES: 34.694203°/-114.611174°



B. Introduction

1. Application and Setting

The Federal Clean Air Act Amendments of 1990 established a nation-wide permit to operate

program commonly known as "Title V". The Mojave Desert Air Quality Management District

(MDAQMD or District) adopted Regulation XII [Rules 1200-1210] and Rule 221 - Federal

Operating Permit Requirement; [Version in SIP = Current, 40CFR 52.220(c)(216)(i)(A)(2) -

02/05/96 61 FR 4217], to implement both the Federal Operating Permit and Acid Rain Permit

programs locally and have received Final Program Approval from EPA on March 6, 1996.

This facility (Southern California Gas Company, South Needles Compressor Station, herein

SCG - South Needles (SN) is subject to the Operating Permit requirements of Title V of

the federal Clean Air Act, Part 70 of Title 40 of the Code of Federal Regulations (CFR),

and MDAQMD Regulation XII, Federal Operating Permits. SCG – SN is defined

as a federal Major Facility pursuant to District Rule 1201 – Federal Operating Permit Definition,

as this facility has a Potential to Emit (PTE) greater than the Major Facility thresholds for

Carbon Monoxide, Nitrogen Oxides, and Hazardous Air Pollutants (HAPs).

Pursuant to Regulation XII, Federal Operating Permits, the District has reviewed the terms and

conditions of this Federal Operating Permit and determined that they are still valid and correct.

This review included an analysis of federal, state, and local applicability determinations for all

sources, including those that have been modified or permitted since the issuance of the initial

Federal Operating Permit. The review also included an assessment of all monitoring in the

permit for sufficiency to determine compliance. This Statement of Legal and Factual Basis,

pursuant to Rule 1203(B)(1)(a)(i), is intended to assess the adequacy of the existing Title V

Permit and explain the District's basis in composing the proposed Renewal.

Additionally, and concurrently with this Title V renewal, SCG-SN is proposing to permit and

operate a New Spark-Ignited (SI) Natural Gas IC Engine equipped with a 3-Way NSCR Catalyst.

SCG-SN, is defined as a federal Major Facility pursuant to District Rule 1201 – Federal

Operating Permit Definitions. The proposed addition of the new emissions unit is classified as a

Significant Modification to SCG-SN, Federal Operating Permit (FOP). Pursuant to District Rule

1205 – Modifications of Federal Operating Permits, section (B)(2) and District Rule

1302(D)(1)(d), this document serves as the preliminary decision and Statement of Legal and

Factual Basis for both the Title V Renewal as well as the analysis required pursuant to the

Permitting and operation of the proposed new engine.

In the MDAQMD, state and District requirements are also applicable requirements and are

included in the Federal Operating Permit. These requirements can be federally enforceable or

non-federally enforceable. State and District only applicable requirements are designated as

such.



C. Description of Facility

SCG – South Needles, is located 11 miles south of Needles, CA on Hwy. 95, 92363 (East side of

Hwy 95). SCG South Needles is a natural gas compression and transmission pipeline facility

located in Needles, California.

The facility consists of the following equipment.

Table 1 Equipment Summary:

District Permit

No. Equipment Description

B000298 NATURAL GAS IC ENGINES POWERING RECIPROCATING

COMPRESSORS, UNITS #1-#7

B002151 SPARK-IGNITED (SI) IC ENGINE GENERATOR, UNIT #1



B013423 NATURAL GAS-POWERED PNEUMATIC DEVICES

B014049 PROPOSED NEW: SPARK-IGNITED (SI) NATURAL GAS IC

ENGINE, POWERING AN AIR COMPRESSOR

C014050 PROPOSED NEW: 3-WAY NSCR CATALYST, INNIO WAUKESHA

NATURAL GAS FIRED ENGINE

E003364 IC ENGINE, EMERGENCY DIESEL ENGINE POWERING FIRE

PUMP #2

E003365 IC ENGINE, EMERGENCY DIESEL ENGINE POWERING FIRE

PUMP #1

E009234 NATURAL GAS IC ENGINE, EMERGENCY, AUXILIARY

E013453 IC ENGINE, EMERGENCY SPARK-IGNITED, AUXILIARY

T002280 STORAGE TANK, USED CRANKCASE OIL

T002281 STORAGE TANK, ODORANT

D. Description of Project

The purpose of this action is to renew the Southern California Gas Company, South

Needles (SCG-SN) Compressor Station’s Federal Operating Permit, 3100068, and

concurrently with this Title V renewal, SCG-SN is proposing to permit and operate a New

Spark-Ignited (SI) Natural Gas IC Engine equipped with a 3-Way NSCR Catalyst.

The proposed new equipment is described as a SPARK-IGNITED (SI) 4-Stroke Rich Burn

Engine, NATURAL GAS IC ENGINE, POWERING AN AIR COMPRESSOR. Specifically, the

equipment is described as a 400 horsepower (hp) natural gas fueled internal combustion engine



with pending District Permit B014049, powering an air compressor. Engine is further described

as a Waukesha, Model VGF-F18SE that is turbocharged and will be equipped with a Non-

Selective Catalytic Reduction Catalyst described as an EmPact system catalyst provided by

INNIO located within the engines exhaust stack. It is designed to reduce emissions of oxides of

nitrogen (NOx), carbon monoxide (CO), hydrocarbons (HC), formaldehyde (CH2O), and

Hazardous Air Pollutants (HAPs).

The Mojave Desert Air Quality Management District (MDAQMD or District) received an

application for proposed new equipment on April 20, 2020, and an application to renew their

Title V on December 17, 2018.

The applicant has proposed to offset the proposed engine using Emission Reduction Credits

(ERCs) that are owned by SCG with ERC Certificate Number 0083. SCG has proposed that the

engine be permitted to operate up to 2200 hours per year. Therefore, emissions from this device

will be offset with these ERC credits.

A copy of the Title V Renewal Application in Appendix A, and their application for the new

Natural powered air compressor can be viewed in Appendix B.

Pursuant to District Rule 1301 – New Source Review Definitions, SCG, South Needles (SCG-

SN), is an existing Major Facility for CO, NOx, and HAPs. This region of the MDAQMD is

classified as ‘attainment/unclassified’ by USEPA for Ozone, NO2, and CO; therefore, and

pursuant to District Rule 1303 – New Source Review Requirements, the proposed equipment is

subject to both BACT and Offset requirements for the Nonattainment Air Pollutant/Precursors of

NOx, and PM10/2.5. Since nearly all emissions from this facility is combustion based, all PM is

considered to be PM10 and all PM10 is PM2.5.

Also, and since the proposed new engine is a new emissions unit located at an existing Major

Source Facility, a complete NSR Analysis is required.

SCG-SN, is defined as a federal Major Facility pursuant to District Rule 1201 – Federal

Operating Permit Definitions. The proposed addition of the new emissions unit is classified as a

Significant Modification to SCG-SN, Federal Operating Permit (FOP). Pursuant to District Rule

1205 – Modifications of Federal Operating Permits, section (B)(2) and District Rule

1302(D)(1)(d), this document serves as the preliminary decision and Statement of Legal and

Factual Basis for both the Title V Renewal as well as the analysis required pursuant to the

Permitting and operation of the proposed new engine.

E. District Rule 1302 - Procedure

1. Rule 1302(B)(1) - Initial Analysis

Pursuant to the requirements of this rule section, the MDAQMD has determined the application

contains all the applicable requirements as required by rule 1302(B)(1)(a) to be deemed

complete. The applicable requirements are identified below along with the subsequent analysis

and discussion throughout this document as required.



Pursuant to the requirements in District Rule 1302 B(1)(a)(ii)(a)(1), an analysis of Alternative

Siting is not required as the proposed equipment is not a Federal Major Modification as defined

in District Rule 1302.

District Rule 1302(B)(1)(ii), Requirements for Facilities Requiring Offsets; requires the

applicant of all new and modified Facilities requiring offsets pursuant to District Rule 1303(B):

To provide an alternative siting analysis including an analysis of alternative sites, sizes and

production processes pursuant to 42 U.S.C. §7503(a)(5) (Federal Clean Air Act §173(a)(5)).

Such analysis shall be functionally equivalent to that required pursuant to Division 13 of the

California Public Resources Code (commencing with section 21000).

Since the proposed change is not a Federal Major Modification, the requirements of Rule

1302(B)(1)(a)(ii) a.1 and a.2 do not apply; see discussion below.

Provide a statewide compliance certification stating that all Facilities which are under the control

of the same person (or persons under common control) in the State of California are in

compliance with all applicable emissions limitations and standards under the Federal Clean Air

Act and the applicable implementation plan for the air district in which the other Facilities are

located.

Since the proposed change is not a Federal Major Modification, the requirements of Rule

1302(B)(1)(a)(ii) a.1 and a.2 do not apply; see discussion below.

Provide a District Rule 1310 applicability analysis sufficient to show that the Facility or

Modification is or is not a Federal Major Facility or a Federal Major Modification as defined in

District Rule 1310(C).

The PTE from the proposed engine is significantly lower than the Federal Major Modification

threshold, therefore the proposed modification is NOT a Federal Major Modification and

District Rule 1310 is NOT applicable; see Tables below for Federal Significant Emissions

threshold and PTE emissions from proposed engine.

Demonstrate that the requirements of subsections (B)(1)(a)(ii) a.1 and a.2 shall not apply if the

Facility or Modification has been determined to not be a Federal Major Facility or a Federal

Major Modification as defined in District Rule 1310(C)(6) and (7) or the Facility has previously

applied for and received a valid Plantwide Applicability Limit (PAL) pursuant to the provisions

of District Rule 1310(F).

The PTE from the proposed engine is significantly lower than the Federal Major Modification

threshold, therefore the proposed modification is NOT a Federal Major Modification and

District Rule 1310 is NOT applicable; see Tables below for Federal Significant Emissions

threshold and PTE emissions from proposed engine. Additionally, and since the change is not



a Federal Major Modification, the requirements of Rule 1302(B)(1)(a)(ii) a.1 and a.2 do not

apply.

Table 2 - Federal Significant Emissions Increase Threshold quantities

SCG-SN is located within a Federal attainment/unclassified area, therefore the Emission Rates of

column 1 are applicable. The proposed emission increases are well below the Federal Significant

Emissions Increase Thresholds as shown in the Table below.

2. Rule 1302(C)(1) – Analysis; Determination of Emissions

The owner/operator has proposed to operate the new SPARK-IGNITED (SI) NATURAL GAS

IC ENGINE, POWERING AN AIR COMPRESSOR engine for prime power purposed and

operate no more than 2200 hours per year; defined as a rolling twelve-month period of time.

Therefore, and pursuant to District Rule 1302, Procedure, the engines Potential to Emit (PTE)

has been calculated based on 24 Hrs/Day, and no more than 2200 hours per year. NOX, CO and

VOC emission levels are based on BACT and manufacturer’s guaranteed levels; SOx and PM

are based on AP-42 emission factors for a Spark Ignited, Natural Gas fired, four-stroke rich-burn

(4SRB) engine. Table 3 below summarizes the proposed engine’s emissions.

Table 3 - Emission Calculations for Proposed Prime Powered Air Compressor (B014049)

*CO *NOx PM10 PM2.5 SOx *VOC

gm/Bhp-

hr

0.60 0.15 0.040 0.040 0.002 0.15

Lbs/Yr 1163 291 77 77 5 291

TPY 0.29 0.15 0.04 0.04 0.002 0.15

*Indicates BACT and Manufacturers guaranteed emissions rates.

Lbs per year and TPY are based on proposed operational permit limit of 2200 hours/yr.



3. Rule 1302(C)(2) – Analysis; Determination of Nonattainment NSR Requirements

Pursuant to District Rule 1302(C)(2)(a), it is determined that that the provisions of District Rule

1303 apply to the new or modified facility. Specifically, it is determined that pursuant to

1302(C)(2)(ii), and since the applicant is NOT utilizing SERs to reduce the PE, then District

Rule 1303(A) is applicable, and therefore, the MDAQMD has developed conditions to the

proposed Permit to include BACT requirements. Additionally, and pursuant to District Rule

1302(C)(2)(iv), the MDAQMD has made a Determination of Offsets as required by 1302(C)(3).

a. District Rule 1302(C)(2)(a) - BACT Evaluation

Best Available Control Technology (BACT) is required for each new or Modified Permit Unit at

a Modified Facility that emits, or has the Potential to Emit, twenty-five (25) tons per year or

more of any Nonattainment Air Pollutant or its Precursors (District Rule 1303(A)(3)). SCG-SN,

has a facility PTE in excess of twenty-five (25) tons per year for the Nonattainment Air

Pollutants and Precursors of NOx, and VOCs, greater than 15 tpy for PM10, and greater than 100

tpy for CO; it is a minor source for SOx. Since the facility is a Regulation XIII Major Source for

NOx, CO, VOC, and PM10, BACT must be applied to all new equipment.

The proposed new SPARK-IGNITED (SI) NATURAL GAS IC ENGINE, POWERING AN AIR

COMPRESSOR, and equipped with an EmPact system catalyst provided by INNIO has

Guaranteed Emissions rates that are considered to be BACT for this equipment Class and

Category for CO, NOx, PM10, and VOC’s. These BACT limits are applicable to this facility as it

is an existing NSR Major Source for these pollutants as defined in Regulation XIII.

Table 4 below summarizes the new emission unit’s emissions, and compares them with

Regulation XIII thresholds to determine pollutant specific BACT applicability. See Appendix C

for applicable BACT Documentation from the BAAQMD, and SCAQMD.

Table 4 - BACT Limits and Applicability Determination

*CO *NOx *PM10 *PM2.5 SOx *VOC

(ROC)

gm/Bhp-hr 0.60 0.15 Natural Gas

Combustion

Natural Gas

Combustion

NA:

Natural Gas

Combustion

0.15

Facility

PTE TPY

428 1088 19 19 0.3 59

Regulation

XIII,

District

Rule 1303

Threshold-

TPY

100 25 15 NA 25 25

BACT

Triggered

Yes/No?

Yes Yes Yes NA No Yes



BACT Limits and analysis Note: Asterisk (*) indicates that BACT is triggered for that specific

air pollutant; BACT limits or other requirements are discussed below:

*CO: 0.60 (gm/Bhp-hr); Engine will meet this BACT limit as emissions limit is a Permit

Condition.

*NOx: 0.15 (gm/Bhp-hr); Engine will meet this BACT limit as emissions limit is a Permit

Condition.

*PM2.5/PM10: Engine will meet this BACT limit, by combusting Natural Gas only (PM10/2.5

BACT); use of utility grade Natural Gas as fuel is BACT for PM10/2.5 and is a Permit

Condition.

SOx: Facility is not a Major Source for this pollutant, and daily emission do not exceed 25

Lbs/day for this air pollutant, therefore BACT is not triggered. Nonetheless, Natural Gas as fuel

is BACT for this air pollutant.

*VOC: 0.15 (gm/Bhp-hr); Engine will meet this BACT limit as emissions limit is a Permit

Condition.

Table 5 – Comparison between SCAQMD and BAAQMD BACT Determination and proposed

Engine Emissions

Category CO

gm/Bhp-

hr

NOx

gm/Bhp-

hr

PM10 PM2.5 SOx VOC

(ROC)

gm/Bhp-

hr

Proposed

Engine

Emissions

gm/Bhp-hr

0.60 0.15 Natural Gas

Combustion

Natural Gas

Combustion

NA:

Natural Gas

Combustion

0.15

BAAQMD 0.60 0.15 n/d, n/s;

Typical

Technology

is Natural

Gas

Combustion

n/d, n/s;

Typical

Technology

is Natural

Gas

Combustion

n/d, n/s;

Typical

Technology

is Natural

Gas

Combustion

0.15

SCAQMD

BACT

Determination

<=0.60 <=0.15 NA NA NA <=0.15

Proposed

Engine Meets

BACT

Yes/No?

Yes Yes Yes Yes Yes Yes

4. District Rule 1302(C)(3) – Analysis; Determination of Offsets

Offsets are required for any new or modified Facility which has the Potential to Emit a Regulated

Air Pollutant in an amount greater than or equal to the thresholds for the Nonattainment Air

Pollutants and their Precursors specified in District Rule 1303(B)(1). The offset threshold is 100



tons per year for CO, 15 tons per year for PM10, 25 tons per year for NOX, 25 tons per year for

SOx, and 25 tons per year for ROC (VOC).

Note: Federal Major Source Thresholds in this area are 100 TPY for NOx, and 100 TPY for PM-

10; NSR thresholds, pursuant to Regulation XIII is 25 TPY for NOX and 15 TPY for PM-10.

Since the MDAQMD is in attainment for CO and SOX, offsets are not required for these air

pollutants. Offsets are required for VOC and NOX since they are non-attainment precursor

pollutants (ozone precursors), and for PM10 since it is a non-attainment pollutant at the state

level.

In conclusion, NOX, VOC, and PM10 emission types must be offset, and SCG-SN is proposing

to offset the engines NOx, VOC and PM10 emissions using ERC’s, which they currently own

and as documented as Certificate 0083 (see Appendix D for copy).

These ERCs were originally generated at their SCG Blythe Compressor facility due to replacing

some of their Internal Combustion Engines during the 2001 time-frame. The SCG Blythe

Compressor (SCG BCS) Station Facility is located within the same air basin and located in an

area with the same ozone attainment status (outside the Federal Ozone nonattainment Area

(FONA)), as is the SCG South Needles facility. Therefore, the ERC’s are eligible for use by the

SCG South Needles facility to offset the PTE from the proposed engine. Since RACT is not

applicable outside the FONA, and these ERCs were generated and will be used outside the

FONA, RACT adjustment is not required.

Since their ERC’s do not contain PM10 emission credits, SCG-SN is proposing to offset PM10

emissions using NOx for PM10 at an Interpollutant Ratio of 2 to 1 (2:1).

District Rule 1305, Emission Offsets, section (B)(6) requires the following:

(for full text, see: https://www.mdaqmd.ca.gov/home/showpublisheddocument?id=482)

1305(B)(6) - Interpollutant Offsets

(a) Emissions reductions of one type of Air Pollutant may be used as Offsets

for another type of Air Pollutant upon approval of the APCO.

(i) For a Federal Major Facility as defined in District Rule 1310(C)(6) or a

Federal Major Modification as defined in District Rule 1310(C)(7) and

which is located in a Federal nonattainment area the APCO’s approval

shall be made in consultation with CARB and the approval of USEPA, on

a case-by-case basis as long as the provisions of subsection (B)(6)(b)

below are met.

(ii) For all other Facilities or Modifications subject to this provision the

APCO’s approval shall be made in consultation with CARB on a case-by-

case basis.

(b) In approving the use of interpollutant offsets the APCO shall determine that:

(i) The trade is technically justified; and

(ii) The applicant has demonstrated, to the satisfaction of the APCO, that



the combined effect of the Offsets and emissions increases from the new

or modified Facility will not cause or contribute to a violation of an

Ambient Air Quality Standard.

(c) The APCO shall, based upon an air quality analysis, determine the amount of

Offsets necessary, as appropriate.

(d) Interpollutant trades between PM10 and PM10 precursors may be allowed on a

case by case basis. PM10 emissions shall not be allowed to Offset nitrogen oxide

or reactive organic compounds emissions within any ozone nonattainment area.

(e) Such ERCs comply with the applicable provisions of section (B)(1) above.

Since there are no PM-10 credits available on their ERC’s, SCG-SN is proposing the use of NOx

for PM-10 at a 2:1. The APCO has subsequently determined this ratio to be conservative, and

will not have an impact on NAAQS/SAAQS. It is further rationalized that NOx can be used to

offset PM-10 as requested, as it is a PM-10 precursor, and it is not practical to Model emissions

of 77 pounds of PM-10 that would result in technical feasibility.

Note: The proposed use of NOX for PM10 was communicated to the USEPA via e-mail on

December 2, 2020. On December 4, 2020, EPA provided their concurrence and acceptance on

the proposed 2:1 NOX for PM10 use as proposed by SCG-SN. See Appendix H for copy of this

correspondence.

Table 6, below, summarizes the current Certificate ERC amount and those which will remain

once the proposed engine is permitted; accordingly, a new Certificate will be issued accordingly.

It is noted that a portion of the ERCs will also be used to offset emissions from a similar

proposed engine at the SCG-North Needles facility. That proposed action is currently pending.

Facility is located within a Federal Ozone Attainment or Unclassified Area for CO, PM10,

Ozone, and SOx, therefore, and pursuant to District Rule 1305(C), the following Offset Ratios

shall apply and as proposed at 2:1 NOX for PM10.

Table 6 - ERC Certificate 0083, Class A Emission Reduction Credits Analysis

Pollutant - Pounds per Year

NOX VOC PM10 CO

Certificate 0083 ERC after 2019 SCG-

North and South Needles NSR Action

1,283,531 12,879 NA NA

Proposed Engine PTE for South

Needles District Permit B014049

291 291 77 1163

Proposed South Needles Engine; NOx

for PM10 at 2:1 Ratio.

154 NA NA NA

New Certificate Amount 1,283,086 12,588 NA NA

5. District Rule 1302(C)(5) – Analysis; Determination of Requirements for Toxic Air

Contaminants

Pursuant to District Rule 1320 – New Source Review for Toxic Air Contaminants, SCG-SN is

subject to both State and Federal Toxic New Source Review, as SCG-SN is a Modified Facility



which has the potential to emit Toxic Air Contaminants, and contains Emissions Units which are

subject to an Airborne Toxic Control Measure (State T-NSR). SCG-SN has the potential to emit

10 tons per year of a single Hazardous Air Pollutant (Federal T-NSR) and/or 25 tpy of a

combination of HAPs.

Pursuant to the requirements of District Rule 1320, an applicability analysis of state and federal

air toxic regulations was conducted for the proposed equipment (State T-NSR and Federal T-

NSR, respectively). The State T-NSR and Federal T-NSR analyses are described below:

Section (E)(1)(b) of District Rule 1320 requires that if any ATCM applies to the proposed

equipment, the requirements of that ATCM shall be added to the District permit.

This new equipment is NOT subject to any State ATCM.

Pursuant to District Rule 1320, section (E)(2), State T-NSR also requires an Emission Unit

Prioritization Score to be calculated utilizing the most recently approved CAPCOA Facility

Prioritization Guidelines, the most recently approved OEHHA Unit Risk Factor for cancer

potency factors, and the most recently approved OEHHA Reference Exposure Levels (REL’s)

for non-cancer acute factors, and non-cancer chronic factors. Therefore, and pursuant to District

Rule 1320 a Prioritization Score (PS) is calculated for this New emissions device based on the

proposed potential to emit values.

The results for this 1 – Proposed New SPARK-IGNITED (SI) NATURAL GAS IC ENGINE,

POWERING AN AIR COMPRESSOR emission unit is provided below:

Table 7 - Prioritization Scores from Proposed Engine

Cancer

Priority

Acute Non-

cancer Priority

Chronic Non-

cancer Priority

New SI 4SRB Engine 0.0186 0.0083 0.0015

Distance to receptor nearest receptor is greater than 7500 meters.

The Cancer Prioritization Score from the proposed engine, quantified using HARP2, is 0.0186,

which by definition is considered a “Low Priority” emission source, and the associated health

risk is considered acceptable.

The Acute Non-Cancer Priority Score from the proposed engine is 0.0083, which is defined as a

“Low Priority” emission source, and the associated health risk is considered acceptable.

The Chronic Non-Cancer Priority Score from the proposed engine is 0.0015, which is defined as

a “Low Priority” emission source, and the associated health risk is considered acceptable.

6. District Rule 1302(C)(6) – Analysis; Determination of Requirements for Prevention of

Significant Deterioration

Rule 1302(B)(1)(a)(i)c requires that any application for an ATC or modification to a Permit to

Operate (PTO) includes: "A District Rule 1600 applicability analysis sufficient to determine



whether the Facility or Modification is or is not a new PSD Major Source or a PSD Major

Modification as defined in District Rule 1600(B) using the procedures set forth in 40 CFR 52.21

(a)(2)."

The SCG-SN is located in an area designated as attainment or unclassified for all National

Ambient Air Quality Standards (NAAQS). Therefore, SCG-SN is potentially subject to PSD for

all criteria pollutants. SCG-SN is an existing PSD Major Source for CO, NOx, VOCs, and

PM10, since the facility PTE is greater than 250 tpy for these two pollutants, CO and NOx.

However, SCG-SN does not have a PSD permit since permitting of most of the emissions units’

pre-dates PSD regulations.

Emissions from the proposed new engine are compared with PSD Significant Emissions

Increases (SEI) thresholds for each PSD regulated pollutant to determine if additional PSD

analysis and/or requirements are triggered. This comparison is summarized in Table below.

Table 8 - PSD Analysis and Results

Units CO NOx PM10 PM2.5 SOx VOC

gm/Bhp-hr 0.60 0.15 0.040 0.040 0.040 0.15

Lbs/Yr 1163 291 77 77 5 291

TPY; NEI

Net

Emissions

Increase

0.6 0.15 0.40 0.40 0.002 0.15

PSD: NEI

Threshold

100 40 15 10 40 40

Significant

Emissions

Increase

(SEI) ?

No No No No No No

The results of the emissions comparison with the appropriate pollutant PSD thresholds is that the

modification DOES NOT trigger the PSD Significant Increase Thresholds, therefore no further

PSD analysis is required.

7. District Rule 1302(C)(7) – Analysis; Determination of Notice Requirements

Pursuant to the requirements of this rule section, it is determined that this rule section requires a

Determination of Notice Requirements because rule 1302(C)(7)(a)(i) is applicable as the new

permit unit is subject to District Regulation XII – Federal Operating Permits, and because section

1302(C)(7)(a)(ii) is applicable as the new permit unit is also subject to the provisions of District

Rule 1303(B).

Public Noticing will therefore occur pursuant to District Rule 1302(D)(3).

8. District Rule 1302(D) – Permit Issuance Procedure



The MDAQMD has determined that the proposed permitting activity is subject to this rule

section, therefore, the MDAQMD will issue this Preliminary Decision is accordance with the

requirements of this rule section.

a. District Rule 1302(D)(5)(b)(iv); NAAQS Impact Analysis

This rule section requires that any new or Modified Facility located in an area classified by

USEPA as attainment or unclassifiable shall determine if the Facility will cause or contribute to a

violation of the National Ambient Air Quality Standards (NAAQS). The proposed modification,

discussed herein, through implementation of BACT, will not contribute to a violation of the

NAAQS. BACT is discussed in detail in other sections of this document.

9. NSR Preliminary Decision - Conclusion

The District has reviewed the proposed new emission unit application for Southern California

Gas South Needles and conducted a succinct written analysis as required by District Rule 1302,

section (D)(1)(b) and District Rule 1203, section (B)(1)(a). The District has determined that the

proposed equipment and application are in compliance with all applicable District, State, and

Federal rules and regulations as proposed and when operated in terms of the permit conditions

stated below.

10. Operating Conditions

The following equipment descriptions and operating conditions will be placed on the Authorities

to Construct (ATC) for the project and in Part III of SCG-SN FOP. The specific section numbers

of the FOP are identified here as well. Note that all new and modified equipment descriptions

and permit conditions will be in redline/strikethrough form.

Description: SPARK-IGNITED (SI) NATURAL GAS IC ENGINE, POWERING AN AIR

COMPRESSOR consisting of: Year of Manufacture; 2020; 4SRB; Engine is Subject to NSPS 40

CFR Part 60 Subpart JJJJ, BACT and Offset Requirements of District Regulation XIII. Facility is

a HAP Major Source. Engine meets the requirements of Subpart ZZZZ §63.6590 (C) by meeting

the Standards of 40 CFR part 60 subpart JJJJ, for spark ignition engines. Engine is equipped with

the following Control Device:

EmPact system catalyst provided by INNIO

Guaranteed Emissions (g/bhp-hr):

NOx: 0.15

CO: 0.60

VOC: 0.15

Exhaust Stack is 13.5 feet high and has a 0.67-foot diameter.

Exhaust vents at 2129 ACFM and at a temperature of 1211 Degrees F.

Facility elevation is 1348 feet above sea level.



One INNIO Waukesha, NG fired internal combustion engine Model No. VGF-F18SE and Serial

No. TBD, Turbo Charged, Air-To-Fuel Ratio Controller, Electronic Control Module, producing

400 bhp with 6 cylinders at 1800 rpm while consuming a maximum of 3.7 MMBtu/hr. This

equipment powers a Compressor Model No. LeROI HGT17 and Serial No. TBD, rated at TBD.

EMISSIONS RATES:

Emission Type Est. Max Load Unit

CO 0.60 gm/bhp-hr

NOx 0.15 gm/bhp-hr

PM10 0.040 gm/bhp-hr

PM2.5 0.040 gm/bhp-hr

SOx 0.002 gm/bhp-hr

VOC 0.15 gm/bhp-hr

CONDITIONS:

1. This equipment, and associated air pollution control device(s), shall be installed, operated, and

maintained in strict accord with those recommendations of the manufacturer/supplier and/or

sound engineering principles in a manner consistent with good air pollution control practice for

minimizing emissions. Unless otherwise noted, this equipment shall also be operated in

accordance with all data and specifications submitted with the application for this permit.

[District Rule 1302(C)(2)(a)]

2. This equipment shall be exclusively fueled with pipeline quality natural gas with a sulfur

content not exceeding 1.0 grains per 100 dscf on a rolling twelve-month average basis.

Compliance with this limit shall be demonstrated by providing evidence of a contract, tariff sheet

or other approved documentation that shows that the fuel meets the definition of pipeline quality

gas.


3. A non-resettable four-digit (9,999) hour timer shall be installed and maintained on this unit to

indicate elapsed engine operating time.


4. The engine shall only be used with a properly maintained and properly functioning EmPact

Air Fuel Ratio Controller (AFRC) and control device operating with valid District Permit

C014050. The control device shall be an EmPact system and three-way catalysts/non-selective

catalytic reduction (NSCR) catalyst provided by INNIO. The AFR controller must be maintained

and operated appropriately in order to ensure proper operation of the engine and NSCR so as to

minimize emissions at all times as required by §60.4243(g).

Note: The emissions of this engine have been offset with Emission Reduction Credits (ERCs)

using a portion of Certificate Number 0083. The quantification of this engines emissions and

corresponding Offsets are contingent on the proper operation and emissions reductions by these

control devices. Therefore, and when required, the Owner/Operator shall only replace this



catalyst and AFR with the same manufacturers and model numbers unless otherwise approved by

the MDAQMD.

[40 CFR 60, Subpart JJJJ and District Rule 1303(B)]

5. The owner/operator shall maintain an operations log for this unit current and on-site (or at a

central location) for a minimum of five (5) years, and this log shall be provided to District, State

and Federal personnel upon request. The log shall include, at a minimum, the following

information:

a. Calendar year operation in terms of fuel consumption (in standard cubic feet);

b. Calendar year total operating hours (NOT TO EXCEED 2200 hours/year), and

c. Maintenance and repair actions, including date and description.

[40 CFR 60.4243(a)(1) and 60.4245(a)(2), and District Rule 1303(B) – Offset limiting]

6. This engine is subject to 40 CFR 60, Subpart JJJJ - New Source Performance Standard for

Stationary Spark Ignition Internal Combustion Engines and these permit conditions. In the event

of conflict, the more stringent requirements shall apply.

[District Rules 204 and 1302]

7. Pursuant to the Source Testing requirements of condition 8, the owner/operator must provide a

written performance test plan or protocol at least thirty days prior to the test date. The

owner/operator must conduct all required compliance/performance tests in accordance with a

District-approved test protocol. The owner/operator must notify the District a minimum of ten

(10) days prior to the compliance/performance test date so that an observer may be present. The

final compliance/performance test results must be submitted to the District not later than forty-

five (45) days after the source test date. All compliance/performance test notifications, protocols,

and results may be submitted electronically to [email protected].

[40 CFR 60.4243(b)(2)(ii); District Rule 1302(C)(2)(a)]

8. The owner/operator must conduct an initial performance test within 1 year of engine startup

and conduct subsequent performance testing every 8,760 hours or 3 years, whichever comes first,

thereafter to demonstrate compliance. Test shall be performed in accordance with 40 CFR 60

Subpart JJJJ and the Districts Approved Source Test Protocol:

a. Measurements to determine O2 concentration must be made at the same time as the

measurements for NOX concentration using EPA Method 3, 3A, or 3Bb of 40 CFR part 60,

appendix A-2 or ASTM Method D6522-00.

b. Exhaust flowrate of the stationary internal combustion engine exhaust shall be determined

using EPA Method 2 or 2C of 40 CFR part 60, appendix A-1 or Method 19 of 40 CFR part 60,

appendix A-7.

c. Measurements to determine moisture must be made at the same time as the measurement for

NOX concentration using EPA Method 4 of 40 CFR part 60, appendix A-3, Method 320 of 40

CFR part 63, appendix A, or ASTM Method D6348-03.

d. NOX sampling shall occur at the outlet of the control device using EPA Method 7E of 40 CFR

part 60, appendix A-4, ASTM Method D6522-00, Method 320 of 40 CFR part 63, appendix A,

or ASTM Method D6348-03.Results of this test consist of the average of three 1-hour or longer

runs.



e. CO shall be sampled at the outlet of the control device using EPA Method 10 of 40 CFR part

60, appendix A4, ASTM Method D6522-00, Method 320 of 40 CFR part 63, appendix A, or

ASTM Method D6348-03.

f. VOC shall be sampled at the outlet of the control device using EPA Methods 25A and 18 of 40

CFR part 60, appendices A-6 and A-7, Method 25A with the use of a hydrocarbon cutter as

described in 40 CFR 1065.265, Method 18 of 40 CFR part 60, appendix A-6, Method 320 of 40

CFR part 63, appendix A, or ASTM Method D6348-03.

g. Sampling port locations and exhaust traverse points shall be made in accordance with Table 2

to Subpart JJJJ of Part 60 - Requirements for Performance Tests.

(See: https://www.ecfr.gov/cgi-bin/text-idx?node=sp40.7.60.jjjj)

[District Rule 204, 1302 and 40 CFR 60, Subpart JJJJ]

9. This engine is BACT equipped and the emissions have been offset with ERCs. Therefore, the

owner/operators shall ensure that the engines emissions are less than or equal to the following

maximum values as required by source tests. If, during source testing, the values are higher than

the referenced values, the owner/operator shall take the appropriate corrective action and retest

as required until the required emission levels are achieved. Maximum Allowed Emission Levels

are:

NOx: 0.15 g/Hp-hr

VOC: 0.15 g/Hp-hr

CO: 0.60 g/Hp-hr

[District Rules 204 and 1303]

10. Emissions from this engine have been offset with Emission Reduction Credits (ERC) from

SCG Certificate Number 0083. As such, this engine shall NOT operate more than 2200 hours in

any single 1-year time period, defined as any consecutive twelve-month period of time.

[District Rule 1303(B)]

11. Fuel consumption shall be monitored using a periodic monitoring system. The operator shall

install, calibrate, maintain and operate this monitoring system according to a District-approved

monitoring plan, and it shall be installed prior to initial equipment startup.

For missing records of fuel usage, the substitute data value shall be the best available estimate of

the parameter based on all available process data e.g. load, operating hours etc. The procedure

used to estimate the substitute data value shall be documented and records of the procedure used

for such estimates shall be maintained.

[40 CFR 98.35(b)(2), 40 CFR 70.6 (a)(3)(B), District Rule 1302(C)(2)(a)]

12. A facility wide Comprehensive Emission Inventory (CEI) for all emitted criteria and toxic air

pollutants must be submitted to the District, in a format approved by the District, upon District

request.

[District Rule 107(b), H&S Code 39607 & 44341-44342, and 40 CFR 51, Subpart A]



F. District Rule 1520 - Control of Toxic Air Contaminants from Existing Sources

Pursuant to District Rule 1520, the applicant submitted a 2018 Comprehensive Emission

Inventory Report (CEIR), which was inputted into the HOTSPOTS ANALYSIS AND

REPORTING PROGRAM EMISSION INVENTORY MODULE VERSION 2.1.0, (HARP2)

Software program for subsequent analysis and results. This methodology is consistent with the

2016 CAPCOA Facility Prioritization Guidelines, and is based on a receptor greater than 7500

meters.

The Table below summarizes the SCG-SN post-modification facility prioritization scores.

As shown, the carcinogenic Prioritization Score is less than one (1), therefore, SCG SN is

categorized as an “Low Priority” facility as defined by District Rule 1320, section (E)(2)(b).

Therefore, no Contemporaneous Risk Reduction is required as a result of adding the proposed

engine. Nonetheless, the proposed engine will have add-on controls considered to be Toxics Best

Available Control Technology, T-BACT, through the use of a 3-Way Catalytic Emission

Reduction System and associated Air Fuel Ratio Control System.

Table 9 - Facility Prioritization Scores, Includes PTE from Proposed Engine

Cancer

Priority

Acute Noncancer

Priority

Chronic

Noncancer Priority

Proposed Modified

Facility 0.0243 0.128 0.0016

Distance to receptor; nearest receptor is greater than 7500 meters.

The facility’s highest Cancer Prioritization Score, quantified using HARP2, is 0.0243, which by

definition, is considered “Low Priority”, and the associated health risk is considered acceptable.

The facility Acute Non-Cancer Priority score is 0.0128, which is defined as “Low Priority” and

the associated health risk is considered acceptable.

The facility Chronic Non-Cancer Priority score is 0.0016, which is defined as “Low Priority” and

the associated health risk is considered acceptable.

G. District Rule 1320 - New Source Review for Toxic Air Contaminants

a. Pursuant to District Rule 1320(F)(1); Federal Toxic New Source Review Program Analysis

(Federal T-NSR), the Modified Facility/Emissions Unit was analyzed to determine if any current,

enforceable Maximum Achievable Control Technology (MACT) standards apply to the affect

Emission Units.

Federal NSPS, 40 CFR Part 60, Subpart JJJJ - Standards of Performance for Stationary Spark

Ignition Internal Combustion Engines is applicable to the proposed engine, which must comply

with the emission standards as summarized in Table 1 of Subpart JJJJ as shown below.

For full Regulations, see: https://www.ecfr.gov/cgi-bin/text-idx?node=sp40.7.60.jjjj

https://www.ecfr.gov/cgi-bin/text-idx?node=sp40.7.60.jjjj



NSPS, Subpart JJJJ requires that this Stationary Emergency SI Engines, and is in the range

100≤HP<500, must meet the following emission rate limitations as indicated in Table 1 of

Subpart JJJJ as shown below:



Table 10 - Comparison of Emission requirements of Subpart JJJJ and the proposed engine.

Emission Standards

Pollutant Subpart JJJJ

g/Hp-hr

Proposed Emissions

(Emergency Gas Fired IC

Engine BACT)

gm/Hp-hr

NOx 2.0 0.15

CO 4.0 0.60

VOC 1.0 0.15

The emissions from the proposed engine is well below the requirements of subpart JJJJ,

therefore, the proposed engine meets the emissions requirements of Subpart JJJJ.

Furthermore, 40 CFR Part 63, Subpart ZZZZ—National Emissions Standards for Hazardous Air

Pollutants for Stationary Reciprocating Internal Combustion Engines is Applicable to the

proposed engine. For full text, see: https://www.ecfr.gov/cgi-bin/text-

idx?c=ecfr;rgn=div6;view=text;node=40%3A14.0.1.1.1.1;idno=40;sid=e94dcfde4a04b27290c44

5a56e635e58;cc=ecfr

§63.6602 of 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 sources of HAP emissions. This subpart also establishes

requirements to demonstrate initial and continuous compliance with the emission limitations and

operating limitations.

§63.6590(c), Stationary RICE subject to Regulations under 40 CFR Part 60. An affected source

that meets any of the criteria in paragraphs (c)(1) through (7) of this section must meet the

requirements of this part by meeting the requirements of 40 CFR part 60 subpart IIII, for

compression ignition engines or 40 CFR part 60 subpart JJJJ, for spark ignition engines. Since

the proposed engine meets the requirements of Subpart JJJJ, no further requirements apply for

such engines under this part, §63.6590(c)(4), for a new or reconstructed spark ignition 4

stroke rich burn (4SRB) stationary RICE with a site rating of less than or equal to 500

brake HP located at a major source of HAP emissions; (Facility is a HAP Major Source)

Therefore, the proposed engine meets the requirements of NESHAP Subpart ZZZZ by

meeting the requirements of NSPS Subpart JJJJ.

H. Rules and Regulations Applicable to the Proposed Project

District Rules:

Rule 201/203 – Permits to Construct/Permit to Operate. Any equipment which may cause the

issuance of air contaminants must obtain authorization for such construction from the Air

Pollution Control Officer. SCG-SN is in compliance with this rule as they appropriately applied

https://www.ecfr.gov/cgi-bin/text-idx?c=ecfr;rgn=div6;view=text;node=40%3A14.0.1.1.1.1;idno=40;sid=e94dcfde4a04b27290c445a56e635e58;cc=ecfr





for a District permit for all new equipment and maintains District permits for all residing

equipment.

Rule 204 – Permit Conditions. To assure compliance with all applicable regulations, the Air

Pollution Control Officer (Executive Director) may impose written conditions on any permit.

The District has imposed permit conditions to ensure SCG-SN complies with all applicable

regulations.

Rule 206 – Posting of Permit to Operate. Equipment shall not operate unless the entire permit is

affixed upon the equipment or kept at a location for which it is issued and will be made available

to the District upon request.

Rule 207 – Altering or Falsifying of Permit. A person shall not willfully deface, alter, forge, or

falsify any issued permit.

Rule 209 – Transfer and Voiding of Permits. SCG-SN shall not transfer, whether by operation of

law or otherwise, either from one location to another, from one piece of equipment to another, or

from one person to another. When equipment which has been granted a permit is altered,

changes location, or no longer will be operated, the permit shall become void.

Rule 210 – Applications. SCG-SN provided all the required information to correctly address the

proposed equipment pursuant to this rule, although there were instances in which additional

information were required, in which the thirty (30) day clock was restarted.

Rule 212 – Standards for Approving Permits. This rule establishes baseline criteria for

approving permits by the District for certain projects. In accordance with these criteria, the

proposed modifications and application does not cause issuance of air contaminants in violation

of Sections 41700 or 41701 of the State Health and Safety code.

Rule 221 – Federal Operating Permit Requirement. SCG-SN is in compliance with this rule, as

they currently hold and maintain a Federal Operating Permit.

Rule 301 – Permit Fees. The proposed equipment will increase SCG-SN annual permit fees by

the applicable amounts described in section (E) of this rule.

Rule 401 – Visible Emissions. This rule limits visible emissions opacity to less than 20 percent

(or Ringlemann No. 1). In normal operating mode, visible emissions are not expected to exceed

20 percent opacity.

Rule 402 – Nuisance. This rule prohibits facility emissions that cause a public nuisance. The

proposed modifications and associated equipment is required by permit condition to employ

good engineering and operational principles in order to minimize emissions and the possibility of

a nuisance.



Rule 404 – Particulate Matter Concentration. This rule requires that no person exceed the

particulate matter concentration provided in Table 404(a). Since Natural Gas is the only fuel

that will be combusted by the proposed engine, the emitted particulate concentration will

comply with the requirements of this rule.

Rule 405 – Solid Particulate Matter – Weight. This rule requires that no person exceed the

particulate matter process weights provided in Table 405(a). Since Natural Gas is the only fuel

that will be combusted by the proposed engine, the emitted Solid Particulate Matter will

comply with the requirements of this rule; emissions will not exceed the limits in Table 405(a)

and the proposed engine will therefore meet the requirements of this rule.

Rule 408 – Circumvention. This rule prohibits hidden or secondary rule violations. The

proposed modifications as described are not expected to violate Rule 408.

Rule 430 – Breakdown Provisions. Any Breakdown which results in a violation to any rule or

regulation as defined by Rule 430 shall be properly addressed pursuant to this rule.

Regulation IX:

Rule 900 – Standards of Performance for New Stationary Sources (NSPS). Rule 900 adopts all

applicable provisions regarding standards of performance for new stationary sources as set forth

in 40 CFR 60. These regulations are periodically updated to reflect actions published in the

Federal Register (FR) by the EPA.

40 CFR 60 Subpart JJJJ – Standards of Performance for Stationary Spark Ignition Internal

Combustion Engines applies to the proposed new engine. This regulation limits allowable

emissions from the engine, however, BACT emission requirements are lower than those required

by this NSPS, and therefore the proposed engine will comply with the requirements of this

NSPS.

Regulation X – National Emission Standards for Hazardous Air Pollutants. Pursuant to

Regulation X, SCG-SN is required to comply with all applicable ATCMs and under state law, a

federal National Emission Standards for Hazardous Air Pollutants (NESHAP) becomes the State

ATCM, unless the Air Resources Board (ARB) has already adopted an ATCM for the source

category and associated hazardous air pollutant(s). In the case of the proposed new equipment,

there are no applicable State ATCM’s, however, NESHAP Subpart ZZZZ is applicable and since

the proposed engine will be in compliance with NSPS Subpart JJJJ, it will be in compliance with

Subpart ZZZZ, as clarified in the subpart.

Regulation XII – Title V Permits

This regulation contains requirements for sources which must have a FOP. SCG-SN currently

has a FOP and is expected to comply with all applicable rules and regulations.

Rule 1201 – Federal Operating Permit Definitions.

SCG-SN is defined as a federal Major Facility pursuant to this rule.



Rule 1203 – Federal Operating Permits.

The proposed new engine is subject to New Source Review and is being processed pursuant to

District Rule 1302, Procedures, which allows for Significant Modifications to be processed

concurrent with NSR actions. This procedure conforms to all applicable provisions of District

Regulation XII. Further, this permit modification will be noticed similarly to District Rule 1207

requirements and in accordance with District Rule 1302.

This document represents the preliminary determination for the proposed modifications to SCG-

SN FOP. This proposed Significant Modification will also be properly noticed pursuant to

District Rule 1207, as required.

Rule 1205 – Modifications of Federal Operating Permits.

The proposed new engine classifies as a Significant Permit Modification to SCG-SN Federal

Operating Permit (FOP), and subsequently, this permit modification will be issued in accordance

with the provisions of District Rule 1302 pursuant to Rule 1203.

Rule 1207 – Notice and Comment.

This NSR permitting action is being noticed concurrent with the Significant Modification of

SCG-SN Federal Operating Permit. Notably, this affords the public the right to petition USEPA

to reconsider the decision to not object to the permit action.

Rule 1208 – Certification.

SCG-SN included a Certification of Responsible Official as required with the submitted

application for the proposed equipment.

Rule 1211 – Greenhouse Gas Provisions of Federal Operating Permits.

SCG-SN is NOT a Major GHG Facility pursuant to Rule 1211.

Regulation XIII – New Source Review

Rule 1302 – Procedure.

This rule applies to all new or Modified Facilities and requires certain requirements to be

fulfilled when submitting an application. All applicable requirements of this rule are discussed

in this NSR document as part of the Analysis procedure. Certification of compliance with the

Federal Clean Air Act, applicable implementation plans, and all applicable District rules and

regulations have been addressed. The Authority to Construct (ATC) application package for the

proposed equipment includes sufficient documentation to comply with Rule 1302(D)(5)(b)(ii).

Permit conditions for the proposed engine will require compliance with Rule 1302(D)(5)(b)(iii).

Rule 1303 – Requirements. This rule requires BACT and offsets for selected facility

modifications. The Proposed engine does trigger BACT and offset requirements and will meet

BACT requirements. The proposed engine will be equipped with a NSCR catalytic emission

reduction system. Additionally, the engines emissions must be fully offset for NOX, VOC,

PM10/2.5 which will be accomplished through use of their wholly owned ERC document with

certification number 0083. See previous sections of this document for additional details.



Rule 1304 – Emissions Calculations. The Proposed Emissions from the proposed modifications

were calculated pursuant to section (B)(1)(a) of this rule.

Rule 1310 – Federal Major Facilities and Modifications. Emissions from the proposed new

engine are determined to NOT be a Federal Major Modification as calculated in accordance with

Rule 1310(E)(1)(a) as the Projected Actual Emissions, calculated pursuant to District Rule 1310

(E)(3)(c), will not exceed the Federal Major Modification Thresholds. Calculation

methodologies are similar to those required by District Rule 1304(B)(1)(a).

Rule 1320 – New Source Review for Toxic Air Contaminants. Pursuant to the requirements of

District Rule 1302, an applicability analysis of State and Federal air toxic regulations was

conducted for the proposed modifications (State T-NSR and Federal T-NSR, respectively) and is

discussed in further detail in this document.

Rule 1520 – Control of Toxic Air Contaminants from Existing Sources. This permit action is

subject to Rule 1520, as SCG-SN is an existing Major Facility as it has a facility PTE greater

than ten (10) tons per year for CO, NOx, PM10/2.5, and VOC, as well as has a PTE to emit a TAC.

A facility prioritization analysis was conducted and it was determined that the facility is a Low

Priority Facility, and the associated health effects are considered acceptable. See previous

sections for additional details.

Regulation XVI, Rule 1600 – Prevention of Significant Deterioration

The purpose of this regulation is to set forth requirements for all new Major PSD Facilities and

Major PSD Modifications which emit or have the potential to emit a PSD Air Pollutant pursuant

to the requirements of 40 CFR 52.21. The proposed modification does not constitute a new

Major PSD Facility or a Major PSD Modification; therefore, PSD does not apply to the proposed

project. A detailed discussion of PSD occurs in the above sections of this document.

State Regulations

Regulation XI— Source Specific Standards:

District Rule 1160 —Internal Combustion Engines

This rule does not apply because SCG-SN is not located in a federal ozone non-attainment area.

Regulation XII — Federal Operating Permits

This regulation contains requirements for sources which must have a federal operating permit.

The identified changes constitute a significant modification of the Title V permit. Specific

requirements of Regulation XII are stipulated as shown below.

Rule 1202 — Applications

This rule designates that official applications will be used as necessary under Regulation XII and

outlines the specified information which shall be included on the official application to the Air

Pollution Control Officer to determine completeness as well as provides a timeline for that

determination. This application includes official District forms. The District has evaluated this



permitting action and concluded that the proposed project requires a significant Title V

Modification and will be processed as such and in accordance with the procedure specified in the

rule.

Rule 1203 — Federal Operating Permits (FOP)

The rule defines the permit operating term, stipulates the process by which FOPs, Significant

Modifications to FOPs and Renewals of FOPs shall be issued. This rule further identifies

restrictions on issuance, permit contents, operational flexibility, compliance certification, permit

shield, and violation of permit conditions. The proposed FOP action is considered a significant

permit modification. The District will submit this SOB and Draft Title V FOP to the EPA and

CARB and make documents available for public review and comment within the specified

comment period in accordance with the procedure outlined in Rule 1203(B)(1).

Rule 1205 —Modifications of Federal Operating Permits

This rule specifies the process by which FOPs are modified. The District will determine if the

action constitutes a significant permit modification and will incorporate the changes as required

by Regulation XII, as applicable.

Rule 1302 —Procedure

Rule 1302 outlines the procedures for preparing an ATC permit application. See previous

sections of this document for a complete NSR analysis.

Rule 1303 — Requirements

The BACT and offset requirements of Regulation XIII are addressed in this rule.

The BACT and offset requirements of Regulation XIII are addressed in this rule.

BACT: Any new or modified Permit Unit which emits, or has the Potential to Emit, 25 lbs/day or

more of any Nonattainment Air Pollutant shall be equipped with BACT. Plus any new or

Modified Facility which emits, or has the Potential to Emit, 25 tpy or more of any Nonattainment

Air Pollutant shall be equipped with BACT for each new Permit Unit. BACT will apply to the

new engine for NOx, ROC (as VOC), and PM10 per Rule 1303 (A)(3) since the facility has a

PTE greater than 25 tpy for NOx and VOC and greater than 15 tpy for PM10.

Offsets: Based on the emissions analysis presented in earlier in this document, the facility is

proposing the use of ERCs to offset the non-attainment pollutants. Rule 1305 describes the

techniques for calculating the required offsets, including the use of ERCs.

Rule 1304 — Emissions Calculations

The SCG-SN modification involves new equipment installation of one SPARK-IGNITED (SI)

NATURAL GAS IC ENGINE, POWERING AN AIR COMPRESSOR. This rule outlines how

to account for the associated emission increases.

Rule 1305 —Emissions Offsets

This Rule provides the procedures and formulas to determine the eligibility of, calculate the

amount of, and determine the use of Offsets required pursuant to the provisions of District Rule



1303(B). The provisions of this rule have been followed in the netting analysis and a summary of

those results are included in this document. A live Excel spreadsheet is also available for review

at the District office upon request.

Rule 1310— Federal Major Facilities and Modifications

This rule sets additional requirements for Federal Major Facilities and Modifications. SCG-SN is

an existing major federal source. Nonetheless, the modifications proposed in the SCG-SN project

are less than the federal significant emissions increase threshold, thus the project is not a Federal

Major Modification, and this rule is not applicable.

Rule 1320 —New Source Review for Toxic Air Contaminants

This rule is applicable to all new, Modified or Relocated Facilities or Permit Units which emit or

have the potential to emit any HAP, TAC, or Regulated Toxic Substance. MDAQMD Rule 1320

follows a step-wise process for evaluating applications for compliance with air toxics

requirements. The initial steps are outlined below, including applicability of Federal and State T-

NSR, and conducting HRAs, if applicable for each EU. Note: The prioritization score for this

facility is quantified as Low Priority and therefore an HRA is not required.

Federal T-NSR

The SCG SN facility is currently considered a Major Source of HAP, and subject to Federal T-

NSR. MDAQMD Rule 1320 requires that if a facility is subject to Federal T-NSR, any

applicable NESHAP standards will apply. The SCG-SN engine is required to comply with any

applicable currently enforceable NESHAP standards, or a case-by-case NESHAP standard as

determined by the MDAQMD. One MACT standards is applicable to the new engine, Subpart

ZZZZ. The engine will comply with this requirement and NSPS, Subpart JJJJ by being BACT

equipped.

State T-NSR Program Analysis (State T-NSR)

This subsection requires the applicant and MDAQMD to identify and include in the permitting

analysis any applicable and currently enforceable California Air Toxics Control Measures

(ATCM). The proposed natural-gas fired Reciprocating IC Engines are not subject to a

California ATCM.

Health Risk Assessment (HRA)

Under the State T-NSR, Rule 1320 requires evaluation of each Emission Unit using prioritization

scoring and an HRA if the prioritization score is high. The facility has a prioritization score of

less than 1, and therefore an HRA is not required.

Regulation XIV — Emission Reduction Credit Banking

Rule 1402 established an Emission Reduction Credit Registry by which emission reduction

credits can be banked by a facility that has met all the applicable requirements of the rule.

Southern California Gas Company previously banked ERCs as documented by Certificate

number 0083. A copy of these, Class A Emission Reduction Credits, is shown in Appendix D.

SCG has proposed to use a portion of these credits to offset the proposed new engine.



The MDAQMD has reviewed and approved that request. The remaining portion of the ERCs will

be documented with a new Certificate number and the appropriate entries the Registry, which is

maintained by the MDAQMD, will also occur.

The emissions, and ERC analysis is shown in greater detail earlier in this document.

Additionally, there is NO adjustment required for these Credits as there is no RACT requirement

for this location of the MDAQMD. Therefore, there will be no reduction upon use of the ERCs

pursuant to Regulation XIV.

Rule 1520 — Control of Toxic Air Contaminants from Existing Sources

This rule applies on a facility-wide basis requiring public notice and/or risk reduction at elevated

levels of health risk for existing facilities based on actual levels of TAC emissions.

2018 emissions inventory resulted in a Prioritization score for Cancer of 0.0243. This

prioritization score is less than 1. Therefore, the facility is considered an “Low Priority” facility,

and the associated health risk is considered acceptable; an HRA is Not Required.

It is further considered that the SCG-SN will employ T-BACT on the proposed engine

equipment through the use of NSCR.

Regulation XVI — Prevention of Significant Deterioration (PSD)

This rule is applicable to projects that have emissions of attainment pollutants greater than the

new Major PSD Facilities and Major PSD Modifications thresholds. An applicability assessment

of PSD has been performed and it is determined that the SCG-SN new engine is not a PSD Major

Modification.

The Following Sections of this SOB pertain to Renewal of the SCG-SN Federal Operating

Permit:

APPENDIX F of this Statement of Basis, contains:

Continuous Parameter Monitoring System (CPMS) Plan as submitted by Southern California

Gas Company South Needles Compressor Station Generators for Generators Gl, G2, and G3

operating with District Permit Numbers B002151, B002152, and B002153 respectively and

pursuant to condition 7 for each permitted unit.

APPENDIX G of this Statement of Basis, contains: Source Test Extension Request and

MDAQMD response.

I. MODIFICATIONS TO CURRENT FEDERAL OPERATING PERMIT:

GENERAL UPDATES

● General formatting updates to improve the consistency of the Title V permits program.

● Update rule citations throughout the permit. Each rule citation was reformatted for program

consistency which includes relocating the SIP citations to Part VII. The table sufficiently

identifies each rule, the SIP status of the rule and the federal enforceability of each rule.



PART I: INTRODUCTORY INFORMATION

This section of the Federal Operating Permit contains general information about Southern

California Gas Company (SCG), South Needles Compressor Station, including facility

identifying information (section A), a description of the facility (section B), and a description of

the facility’s equipment (section C).

Changes made to this section of the FOP, include:

● Change in Responsible Official to Mr. Carlos Gaeta, Field Manager.

● Change in Facility “Site” Contact #2 to Alison Wong, Environmental.

● Change in “Off-Site” Contact to Chanice Allen.

● Minor changes made to equipment description and conditions for the following District

Permits:

B000298, B002151, B002152, B002153, E003364, E003365, E009234, E013453, B013423,

T002280, and T002281.

● STATE ONLY, New District Permit B013423; regarding Natural Gas Pneumatic Devices;

permit added pursuant to California Code of Regulations, Title 17, Division 3, Chapter 1,

Subchapter 10 Climate Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for

Crude Oil and Natural Gas Facilities.

Proposed New District Permit B014049; Spark-Ignited Natural Gas Engine Powered Air

Compressor; emissions from this proposed engine shall be offset with ERC’s owned by Southern

California Gas Company under Certificated Number 0083.

Proposed New District Permit C014050; 3-Way NSCR Catalyst described as EmPact system

catalyst provided by INNIO located within the exhaust stack of INNIO Waukesha engine model

VFG-F18SE, with proposed Permit Number B014049.

PART II: FACILITYWIDE APPLICABLE REQUIREMENTS; EMISSIONS

LIMITATIONS; MONITORING, RECORDKEEPING, REPORTING AND TESTING

REQUIREMENTS; COMPLIANCE CONDITIONS; COMPLIANCE PLANS

This section of the Federal Operating Permit contains requirements applicable to the entire

facility and equipment (Section A), facility-wide monitoring, recordkeeping, and reporting

requirements (Section B), and facility-wide compliance conditions (Section C).

Changes made to this section of the FOP:

• Part II, Section A. Updated to include rule revisions which occurred since the time of the

last renewal.

• Part II, Section A, revised to incorporate changes made to District Rule 442, Usage of

Solvents.



• Part II, Section A, revised to incorporate changes made to District Rule 1104, Organic

Solvent Degreasing Operations.

• Part II, Section A, revised to incorporate formatting changes referencing District Rule

1113, Architectural Coatings.

• Part II, Section A, revised to incorporate changes made to District Rule 1114, Wood

Products Coating Operations.

• Part II, Section A, revised to incorporate changes made to District Rule 1115, Metal Parts

& Products Coating Operations.

Changes made to Part II, Section B: None

Changes made to Part II, Section C: None

PART III: EQUIPMENT SPECIFIC APPLICABLE REQUIREMENTS; EMISSIONS

LIMITATIONS; MONITORING, RECORDKEEPING, REPORTING AND TESTING

REQUIREMENTS; COMPLIANCE CONDITIONS; COMPLIANCE PLANS

This section of the Federal Operating Permit contains equipment-specific applicable

requirements including emission limitations, monitoring and recordkeeping, reporting and

testing, and compliance plans.

Changes made to Part III, Section A thru Section O:

District Permit Description of change made

B000298 Permit has been updated to remove references to District Rule 1160

compliance as this Rule is Not applicable to this facility, which is located

outside the FONA; condition 23 has been updated to reflect that CARB

GHG reports must be submitted through their Cal e-GGRT Reporting

Portal.

B002151 Permit has been revised to update permit conditions for consistency with

similar equipment and to incorporate stack information into equipment

description.



description.



description.

B013423 STATE ONLY, New District Permit B013423; regarding Natural Gas

Pneumatic Devices; permit added pursuant to California Code of

Regulations, Title 17, Division 3, Chapter 1, Subchapter 10 Climate



Change, Article 4, Subarticle 13: Greenhouse Gas Emission Standards for

Crude Oil and Natural Gas Facilities.

E003364 Permit has been revised to update permit conditions for consistency with


description.



description.



description.


similar equipment.


similar equipment.

B014049 Proposed New District Permit B014049; Spark-Ignited Natural Gas

Engine Powered Air Compressor; emissions from this proposed engine

shall be offset with ERC’s owned by Southern California Gas Company

under Certificated Number 0083.

C014050 Proposed New District Permit C014050; 3-Way NSCR Catalyst described

as EmPact system catalyst provided by INNIO located within the exhaust

stack of INNIO Waukesha engine model VFG-F18SE, with proposed

Permit Number B014049.

T002280 Permit has been revised to update permit conditions for consistency with


description.

T002281 Permit has been revised to update permit conditions for consistency with


description.

PART IV: STANDARD FEDERAL OPERATING PERMIT CONDITIONS

This section of the Federal Operating Permit contains standard federal operating permit

conditions. Changes made to this section of the FOP: None

PART V: OPERATIONAL FLEXIBILITY



Changes made to this section of the FOP:

Section B, Off Permit Changes has been updated for consistency with similar Title V Permits.

PART VI: CONVENTIONS, ABBREVIATIONS, DEFINITIONS, MDAQMD

APPLICABLE SIP

This section of the Federal Operating Permit contains information on conventions, abbreviations

and definitions.

Changes made to this section of the FOP; moved some abbreviations so that they are in

alphabetic order.

PART VII: DISTRICT SIP HISTORY AND CITATIONS

This section of the Federal Operating Permit contains a SIP table of all applicable District Rules

and Historical Summary.

Changes have been made to this section of the FOP:

• SIP table updated to include rule revisions, which have occurred since the time of the last

renewal.

J. Rule Applicability:

District Rules

Rule 201/203 – Permits to Construct/Permit to Operate. Any equipment which may cause the

issuance of air contaminants must obtain authorization for such construction from the Air

Pollution Control Officer. SCG- SN (South Needles) Compressor Station is in compliance with

this rule as they have appropriately applied for a District permit for all new equipment and

maintain District permits for all residing equipment per Part II, section A of their FOP.

Rule 204 – Permit Conditions. To assure compliance with all applicable regulations, the Air

Pollution Control Officer (Executive Director) may impose written conditions on any permit.

SCG-SN Compressor Station complies with all applicable regulations per Part II of their FOP.

Rule 206 – Posting of Permit to Operate. Equipment shall not operate unless the entire permit is

affixed upon the equipment or kept at a location for which it is issued and will be made available

to the District upon request. SCG-SN Compressor Station complies with this regulation per Part

II of their FOP.

Rule 207 – Altering or Falsifying of Permit. A person shall not willfully deface, alter, forge, or

falsify any issued permit. SCG-SN Compressor Station complies with this regulation per Part II

of their FOP.



Rule 209 – Transfer and Voiding of Permits. SCG-SN Compressor Station shall not transfer,

whether by operation of law or otherwise, either from one location to another, from one piece of

equipment to another, or from one person to another. When equipment which has been granted a

permit is altered, changes location, or no longer will be operated, the permit shall become void.

SCG-SN Compressor Station complies with this regulation per Part II their FOP.

Rule 217 – Provisions for Sampling and Testing Facilities. This rule stipulates that the APCO

may require the applicant to provide and maintain requirements for sampling and testing. In the

event that facilities, be equipped to accommodate testing the APCO shall notify the

Owner/Operator in writing of the required size, number and location of sampling ports; the size

and location of the sampling platform: the access to the sampling platform, and the utilities for

operating the sampling and testing equipment. SCG-SN Compressor Station is in compliance

with this rule per Part II of their FOP.

Rule 219 – Equipment not Requiring a Permit. This rule exempts certain equipment from

District Permit. SCG-SN Compressor Station is in compliance with this rule per Part II.

Rule 221 – Federal Operating Permit Requirement. SCG-SN Compressor Station is in

compliance with this rule, as they currently hold and maintain a Federal Operating Permit.

Rule 301/312 – Permit Fees/Fees for Federal Operating Permits. SCG-SN Compressor Station

annual permit fees are due by the applicable amounts.

Rule 401 – Visible Emissions. This rule limits visible emissions opacity to less than 20 percent

(or Ringlemann No. 1). In normal operating mode, visible emissions are not expected to exceed

20 percent opacity. SCG-SN Compressor Station is in compliance with this rule per Part II.

Rule 403 – Fugitive Dust. This rule prohibits fugitive dust beyond the property line of any

emission source. SCG-SN Compressor Station is in compliance with this rule per Part II.

Rule 404 – Particulate Matter Concentration. SCG-SN Compressor Station shall not discharge

into the atmosphere from this facility, particulate matter (PM) except liquid sulfur compounds, in

excess of the concentration at standard conditions, shown in Rule 404, Table 404 (a).

(a) Where the volume discharged is between figures listed in the table the exact concentration

permitted to be discharged shall be determined by linear interpolation.

(b) This condition shall not apply to emissions resulting from the combustion of liquid or

gaseous fuels in steam generators or gas turbines.

(c) For the purposes of this condition, emissions shall be averaged over one complete cycle of

operation or one hour, whichever is the lesser time period.

SCG-SN Compressor Station is in compliance with this rule per Part II.

Rule 405 – Solid Particulate Matter, Weight. SCG-SN Compressor Station shall not discharge

into the atmosphere from this facility, solid PM including lead and lead compounds in excess of the

rate shown in Rule 405, Table 405(a):



(a) Where the process weight per hour is between figures listed in the table, the exact

weight of permitted discharge shall be determined by linear interpolation.

(b) For the purposes of this condition, emissions shall be averaged over one complete

cycle of operation or one hour, whichever is the lesser time period.

SCG-SN Compressor Station is in compliance with this rule per Part II.

Rule 406 – Specific Contaminants. This rule limits single source of emissions of sulfur compounds.

SCG-SN Compressor Station meets this requirement by complying with operating condition listed

in Part II, of their FOP.

Rule 407 – Liquid and Gaseous Air Contaminants. This rule limits CO emissions from facilities.

SCG-SN Compressor Station meets this requirement by complying with operating condition listed

in Part II, of their FOP.

Rule 408 – Circumvention. This rule prohibits hidden or secondary rule violations. The

proposed renewal as described is not expected to violate Rule 408. SCG-SN Compressor Station

meets this requirement by complying with operating condition listed in Part II, of their FOP.

Rule 409 – Combustion Contaminants. This rule limits the emissions of combustion

contaminants exceeding 0.23 gram per cubic meter (0.1 grain per cubic foot) of gas calculated to

12 percent of carbon dioxide (CO2) at standard conditions averaged over a minimum of 25

consecutive minutes. SCG-SN Compressor Station meets this requirement by complying with

operating condition listed in Part II, of their FOP.

Rule 430 – Breakdown Provisions. Any Breakdown which results in a violation to any rule or

regulation as defined by Rule 430 shall be properly addressed pursuant to this rule. SCG-SN

Compressor Station meets this requirement by complying with operating condition listed in Part II,

of their FOP.

Rule 442 – Usage of Solvents. This rule reduces VOC emissions from VOC containing materials

or equipment that is not subject to any other rule in Regulation XI. SCG-SN Needles Compressor

Station meets this requirement by complying with operating condition listed in Part II, of their FOP.

Rule 900 – Standards of Performance for New Stationary Sources (NSPS). Rule 900 adopts all

applicable provisions regarding standards of performance for new stationary sources as set forth

in 40 CFR 60. The proposed new engine will meet the requirements of 40 CFR 60, Subpart JJJJ,

Standards of Performance for Stationary Spark Ignition Internal Combustion Engines.

Rule 1104 – Organic Solvent Degreasing Operations. This recently revised rule limits the

emission of VOCs from wipe cleaning and degreasing operations using organic solvents. SCG-

SN Compressor Station meets this requirement by complying with operating condition listed in

Part II, of their FOP.



Rule 1113 – Architectural Coatings. This rule limits the quantity of VOC in Architectural Coatings.

SCG-SN Compressor Station meets this requirement by complying with operating condition

listed in Part II, of their FOP.

Rule 1114– Wood Products Coatings. This recently revised rule limits the quantity of VOC in

Wood Coatings. SCG-SN Compressor Station meets this requirement by complying with

operating condition listed in Part II, of their FOP.

Rule 1115 – Metal Parts and Products Coatings. This recently revised rule limits the emission of

VOC from coatings associated with Metal Parts and Products. SCG-SN Compressor Station meets

this requirement by complying with operating condition listed in Part II, of their FOP.

Rule 1160 – Internal Combustion Engines. This recently revised District Rule is NOT

applicable to the SCG-SN Compressor Station as this facility is located in a Federal Ozone

Attainment Area (FONA).

Regulation X – Emission Standards for Additional Specific Air Contaminants. Pursuant to

Regulation X, SCG-SN Compressor Station is required to comply with all applicable ATCMs,

MACTs and NESHAPS.

ATCM 17 CCR 93115 applies to the Emergency Diesel Engine operating under District Permit

E013097; SCG-SN Compressor Station is in compliance with this ATCM.

The specific MACTs/NESHAPS applicable to SCG-SN Compressor Station are listed under the

Federal Requirements below.

Regulation XII – Federal Operating Permits. This regulation contains requirements for sources

which must have a FOP. SCG-SN Compressor Station currently has a FOP and is expected to

comply with all applicable rules and regulations.

Rule 1201 – Federal Operating Permit Definitions. SCG-SN Compressor Station is defined as a

federal Major Facility pursuant to this rule.

Rule 1203 – Federal Operating Permits. This rule outlines the permit term, issuance,

restrictions, content, operational flexibility, compliance certification, permit shield, and

violations of Federal Operating Permits. SCG-SN Compressor Station meets this requirement by

complying with operating condition listed in Part II, of their FOP.

Rule 1205 – Modifications of Federal Operating Permits. The action to renew SCG-SN

Compressor Station’s FOP does not constitute a modification, however, the addition of the New

SPARK-IGNITED (SI) NATURAL GAS IC ENGINE, POWERING AN AIR COMPRESSOR

constitutes a Significant Permit Modification, as this action will result in an emission’s increase

at an existing Major Source and existing Title V facility. As such the Title V permit will be

issued in accordance with District Rule 1203.



Rule 1206 – Reopening, Reissuance and Termination of Federal Operating Permits. The

combined NSR of permitting a new engine and Title V Renewal does require a Reopening, and

Reissuance of the SCG-SN FOP; therefore, this action is subject to this Rule.

Rule 1207 – Notice and Comment. This rule outlines the noticing requirements for Notice and

Comment. SCG-SN Compressor Station’s has and/or will properly notice(d) their renewal and

concurrent NSR action pursuant to this rule.

Rule 1208 – Certification. SCG-SN Compressor Station’s included a Certification of

Responsible Official as required with the submitted applications.

Rule 1211 – Greenhouse Gas Provisions of Federal Operating Permits. SCG-SN Compressor

Station’s is a Major GHG Facility pursuant to Rule 1211; the facility has been and will remain in

compliance with the requirements pertaining to this regulation.

Regulation XIII – New Source Review. This regulation sets forth requirements for the

preconstruction review of all new or modified facilities. This facility is undergoing a facility

“Modification” as they have proposed the additional of a new emission source that will result in

an increase of Regulated Air Pollutants. The associated analysis is conducted pursuant to District

Regulation XIII- New Source Review see previous sections of this SOB for a full analysis.

Federal Regulations

40 CFR 60, Subpart JJJJ–Standards of Performance for Stationary Spark Ignition Internal

Combustion Engines. The proposed New Engine and associated Catalyst shall be in compliance

with this regulation per Part II of their FOP.

40 CFR 63, Subpart ZZZZ–National Emission Standards for Hazardous Air Pollutants for

Reciprocating Internal Combustion Engines. SCG-SN Compressor Station’s complies with this

regulation per Part II of their FOP.

40 CFR 64, Compliance Assurance Monitoring. The Compliance Assurance Monitoring (CAM)

rule (40 CFR 64) applies to each Pollutant Specific Emissions Unit (PSEU) when it is located at

a Major Facility that is required to obtain Title V, Part 70 or 71 permit and it meets all of the

following criteria. “PSEU” means an emissions unit considered separately with respect to each

regulated air pollutant.

The PSEU must:

a. Be subject to an emission limitation or standard [40 CFR 64; AND,

b. Use a control device to achieve compliance [40 CFR 64.2(a)(2)]; AND,

c. Have the potential pre-control emissions that exceed or are equivalent to the major source

threshold. [40 CFR 64.2(a)(3)]

Presented in Appendix A is an CAM Analysis as provided by the owner/operator; in summary

CAM does NOT apply to any of the equipment at the SCG-SN Compressor Station. We have

reviewed the analysis and agree with this conclusion.



K. Conclusions and Recommendations:

The District has reviewed the application for the renewal of the Federal Operating Permit and the

application for the new internal combustion engine, and it is determined that the renewal permit

and permitting of the new engine shall be in compliance with all applicable District, state, and

federal rules and regulations as proposed, and when operated in the terms of the permit

conditions given herein. The proposed permit and corresponding statement of legal and factual

basis has been, or will be, publicly noticed pursuant to District Rule 1207. To view the public

notice please refer to Appendix E of this document.

L. Public Comment and Notifications:

1. Public Comment

This preliminary determination will be publicly noticed on or before 01-19-21.

The 30-Day Public Commenting Period that will end at COB on 02-18-21.

Noticing Methods include the following, per District Rule 1207(A)(1)(a) and District Rule

1302(D)(2) and (3):

• Published in newspapers of general circulation - Press Enterprise and the Daily Press on

or before 01-19-21

• Mailed and/or emailed to MDAQMD contact list of persons requesting notice of actions

(see the contact list following the Public Notice in Appendix E) on or before 01-12-21

• Posted on the MDAQMD Website at the following link:

http://www.mdaqmd.ca.gov/permitting/public-notices-advisories/public-notices-

permitting-regulated-industry

2. Notifications

The preliminary determination was submitted via e-mail to EPA and CARB pursuant to District

Rule 1207 for a forty-five (45) day review period on or before 01-12-21. The final modified FOP

shall be issued on or about 03-01-21. All correspondence as required by District Rules 1302 and

1207 were forwarded electronically to the following recipients:

Director, Office of Air Division Chief, Stationary Source Division

United States EPA, Region IX California Air Resources Board

75 Hawthorne Street P.O. Box 2815

San Francisco, CA 94105 Sacramento, CA 95812

Via EPA’s Portal: https://cdx.epa.gov/ Via e-mail at: [email protected]

Field Operations Manager C/O Alison Wong via e-mail

Southern California Gas Company

P.O. Box 2300, Chatsworth CA 91313

http://www.mdaqmd.ca.gov/permitting/public-notices-advisories/public-notices-permitting-regulated-industry

http://www.mdaqmd.ca.gov/permitting/public-notices-advisories/public-notices-permitting-regulated-industry

https://cdx.epa.gov/

A-37 Preliminary Determination/Decision - Statement of Basis


APPENDIX A Title V Renewal Application

B-49 Preliminary Determination/Decision - Statement of Basis


APPENDIX B New SI ICE Application- NSR



Emission Calculations

C-65 Preliminary Determination/Decision - Statement of Basis


APPENDIX C BACT Determinations

E-1 Preliminary Determination/Decision - Statement of Basis


Appendix D: Certificate of Ownership, Class A Emissions Reduction Credits, Front Side

Reduction



Appendix D: Certificate of Ownership, Class A Emissions Reduction Credits, Back Side



APPENDIX E Public Notice

NOTICE OF TITLE V PERMIT RENEWAL

NOTICE IS HEREBY GIVEN THAT Southern California Gas Company's South Needles (SCG-

SN) Compressor Station facility, located 11 miles south of Needles, CA on Hwy 95, has applied

for the renewal of their Federal Operating Permit (FOP) pursuant to the provisions of MDAQMD

Regulation XII. The Applicant is a company engaged in the compression and distribution of

pipeline quality natural gas for use by its customers throughout Southern California. The facility

is required to maintain a Title V permit because the potential emissions exceed the major source

thresholds for Nitrous Oxides, Carbon Monoxide, and Hazardous Air Pollutants (HAPs).

Concurrent with their Title V Renewal, SCG-SN has proposed the addition of a New SPARK-

IGNITED (SI) NATURAL GAS IC ENGINE, POWERING AN AIR COMPRESSOR. The new

engine will be equipped with Best Available Control Technology (BACT) and all new emissions

will be offset with Emission Reduction Credits (ERCs) that are owned by SCG.

REQUEST FOR COMMENTS: Interested persons are invited to submit written comments

and/or other documents regarding the terms and conditions of the proposed renewal of South

Needles Compressor Station’s Federal Operating Permit. If you submit written comments, you

may also request a public hearing on the proposed issuance of the Federal Operating Permit. To

be considered, comments, documents and requests for public hearing must be submitted no later

than 5:00 P.M. on February 18, 2021, to the MDAQMD, Attention: Samuel J Oktay, PE at the

address listed below.

PETITION FOR REVIEW: Federal Operating Permits are also subject to review and approval

by the United States Environmental Protection Agency (USEPA). If the USEPA finds no

objection to the proposed permit renewal, the final permit will be issued. In the event of public

objection to the issuance of a specific permit, a Title V petition may be submitted to the USEPA

Administrator electronically through the Central Data Exchange at: https://cdx.epa.gov/. In order

to file a Title V petition, issues must be raised with reasonable specificity during the public

comment period, and filed within 60 days of the close of the USEPA review period.

AVAILABILITY OF DOCUMENTS: The proposed Federal Operating Permit, as well as the

application and other supporting documentation are available for review at the MDAQMD

offices, 14306 Park Avenue, Victorville, CA 92392. In addition, these documents are available

on the MDAQMD website and can be viewed at following link:

https://www.mdaqmd.ca.gov/permitting/public-notices-advisories/public-notices-permitting-

regulated-industry. Please contact Samuel J Oktay, PE, Air Quality Engineer, at the address,

above, or (760) 245-1661, extension 1610, or at [email protected] for additional questions

pertaining to this action and/or corresponding documents.

*Traducción en español esta disponible por solicitud. Por favor llame: (760) 245-1661*

SHERI HAGGARD

Engineering Supervisor II

Mojave Desert Air Quality Management District



14306 Park Avenue

Victorville, CA 92392



Figure 1: MDAQMD contact list of persons requesting notice of actions



Figure 1: MDAQMD contact list of persons requesting notice of actions (continued from

previous page)

F-1 Preliminary Determination/Decision - Statement of Basis


APPENDIX F: CONTINUOUS PARAMETER MONITORING SYSTEM

PLAN

G-1 Preliminary Determination/Decision - Statement of Basis


APPENDIX G: SOURCE TEST EXTENSION REQUEST

H-1 Preliminary Determination/Decision - Statement of Basis


APPENDIX H: EPA CORRESPONDENCE REGARDING INTERPOLUTANT TRANSFER

H-2 Preliminary Determination/Decision - Statement of Basis


mojave desert ir quality management district

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