Air Enforcement: Mississippi Commission on Environmental Quality and Flowood Compressor Station Operator Enter Into Agreed Order

Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.

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The Mississippi Commission on Environmental Quality (“MCEQ”) and Gulf South Pipeline Company, LLC, (“Gulf South”) entered into an April 4th Agreed Order (“AO”) addressing alleged violations of a Clean Air Act Title V Operating Permit (“Permit”). See Order No. 7097-21

The AO provides that Gulf South operates a compressor station (“CS”) in Flowood, Mississippi.

MCEQ is stated to have notified Gulf South by letter dated February 13, 2020, of certain alleged violations at the CS. The alleged violations included a failed performance test regarding emission points AA-012 and AA-013. Such alleged failure is stated to have included:

  • Reduces the mass content of either TOC or total HAP in the gases vented to the device by 95.0 percent by weight or greater;
  • Reduces the concentration of either TOC or total HAP in the exhaust gases at the outlet to the device to a level equal to or less than 20 part per million by volume on a dry basis corrected to 3 percent oxygen; or
  • Operates at a minimum temperature of 760 degrees C, provided the control device has demonstrated that combustion zone temperature is an indicator of destruction efficiency.

The AO also states that there was a failure to conduct initial performance tests on Emission Points AA-0012 and AA-013 within 180 days of startup of the units.

Gulf South is stated to have asserted the initial performance tests were successfully completed on July 10, 2019, after the temperature set point of the combustion chamber was increased from 1,400 degrees Fahrenheit to 1600. Further, Gulf South asserted the temperature set point of the combustion chamber remained at 1,610 degrees Fahrenheit since the successful performance test was completed.

The AO assesses a civil penalty of $55,125.

A copy of the AO can be downloaded here.

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Mitchell, Williams, Selig, Gates & Woodyard, P.L.L.C.
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