Feb 23, 2016 Page 1 of 48 

CITY OF PHILADELPHIA 

Department of Public Health 

Environmental Protection Division 

Air Management Services 

InterOffice Memo 

To: File 

From: Noelle Helmstetter and Maryjoy Ulatowski 

Date: February 23, 2016 

Subject: 1997 8-Hour RACT Analysis for Kinder Morgan Liquids Terminals, LLC -

Philadelphia Terminal 

Table of Contents

I. Introduction: ............................................................................................................................................................. 3

II. Company Description: ............................................................................................................................................. 3

III. Applicability for NOx and VOC RACT: ................................................................................................................ 3

IV. 1997 1-hour VOC RACT Sources: ........................................................................................................................... 3

V. Sources Evaluated for 1997 8-hour VOC RACT : ................................................................................................... 4

VI. VOC RACT Evaluation: ........................................................................................................................................... 5

A. Tank Car/Truck Loading Operations ................................................................................................................... 5

1. Tank Car/Truck Loading Operations - 1 Hour RACT Requirements ................................................................. 5

2. Tank Car/Truck Loading Operations- Permit Modifications ............................................................................. 6

3. Tank Car /Truck Loading Operations- Applicable Requirements ................................................................... 11

4. Tank Car/Truck Loading Operations - 8 Hour RACT Evaluation .................................................................... 11

a. Controlled Loading Positions .................................................................................................................. 11

b. Uncontrolled Loading Positions .............................................................................................................. 12

5. Tank Car/Truck Loading Operations – Proposed 8 Hour RACT Requirements .............................................. 20

a. Loading of Liquids Organic Liquids with RVP > 4.0 psi ........................................................................ 20

b. Loading of Liquids Organic Liquids with RVP < 4.0 psi ........................................................................ 21

B. Marine Vessel Loading Operations: .................................................................................................................... 22

1. Marine Vessel Loading Operations: 1-Hour RACT ....................................................................................... 22

2. Marine Vessel Loading Operations - Permit Modifications ............................................................................ 22

3. Marine Vessel Loading Operations: PTE ........................................................................................................ 22

4. Marine Vessel Loading Operations: 8-Hour Case-by-Case RACT Analysis .................................................. 24

a. Technically Feasibility Evaluation: ......................................................................................................... 24

b. Cost Analysis of Technically Feasible Control Options: ......................................................................... 27

5. Marine Vessel Loading Operations: Proposed New Limits ............................................................................. 30

a. Conclusion: .............................................................................................................................................. 30

6. Marine Vessel Loading Operations: Proposed 8-Hour RACT Requirements .................................................. 30
Feb 23, 2016 Page 2 of 48 

C. Fugitive Emissions .............................................................................................................................................. 31

1. Fugitive Emissions: 1-Hour RACT ................................................................................................................. 31

2. Fugitive Emissions: Applicable Requirements & Permit Modifications ......................................................... 32

3. Fugitive Emissions: 8hr RACT Determination ................................................................................................ 32

D. Storage Tanks .................................................................................................................................................... 32

E. Emergency Generator ......................................................................................................................................... 38

F. Boilers ................................................................................................................................................................ 38

D. De Minimis Sources: ........................................................................................................................................... 38

1. Soil Vapor Extraction (SVE) Remediation System (206 Process) ................................................................ 39

2. Cleaning & Degassing Operations (204 Process) .......................................................................................... 39

3. Other Smaller Sources Listed as Insignificant ............................................................................................... 39

G. Control Devices ................................................................................................................................................... 39

VII. Conclusions and Recommendations: .................................................................................................................... 39

Attachment A - AMS Permit 08211/14350 Background Memo .................................................................................. 41

Attachment B - AMS Permit 09105 Background Memo .............................................................................................. 43

Attachment C - Marine Loading PTE (at maximum hourly throughput capacity) ....................................................... 45

Attachment D - AMS Permit No. 11184 Background Memo ....................................................................................... 46

Attachment E - Example Chemicals ............................................................................................................................. 47

Attachment F - Vendor Quote ...................................................................................................................................... 48

Attachment G – Marine Vapor Control Unit Affidavit ................................................................................................. 48
Feb 23, 2016 Page 3 of 48 

I. Introduction: 

The Clean Air Act (CAA) requires that moderate (or worse) ozone nonattainment areas implement reasonably 

available control technology (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and 

Nitrogen Oxides (NOx). Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City moderate ozone 

nonattainment area for the 1997 8-hour ozone NAAQS. This document presents the findings of a RACT evaluation 

for the 1997 8-hour ozone standard for this facility. 

II. Company Description: 

Kinder Morgan Liquids Terminals (KMLT), LLC owns and operates as a bulk liquid terminal, located at 3300 North 

Delaware Avenue, Philadelphia, PA 19134, that warehouses a variety of products/chemicals/materials based on 

customer’s demand. The materials/chemicals are in-bounded via ship/barge, rail car, and tank trucks and then the 

materials/chemicals are stored in fixed roof and internal floating roof tanks. The material/chemicals in the tanks are 

shipped out by ship/barge (marine), rail tank car, and tank truck. Kinder Morgan Liquids Terminals, LLC 

(Philadelphia Terminal) was previously named “GATX Terminals Corporation.” Sources at the facility include 

tank/truck loading, marine loadings, storage tanks, compressors, emergency engine, fugitive emissions and 

insignificant sources. Examples of some chemicals or products that have been stored at the facility during the 2014 

calendar year is listed in Attachment E. 

III. Applicability for NOx and VOC RACT: 

Kinder Morgan Liquids Terminals, LLC - Philadelphia Terminal is not a major source of NOx having potential NOx 

emissions less than 100 tons per year, the major source threshold in Philadelphia County that is applicable to NOx 

RACT for the 1997 8-hour ozone National Ambient Air Quality Standard (NAAQS). 

Kinder Morgan Liquids Terminals, LLC is a major source of VOC having potential VOC emissions greater than 50 

tons per year, the major source threshold in Philadelphia County that is applicable to VOC RACT for the 1997 8-hour 

ozone NAAQS. 

IV. 1997 1-hour VOC RACT Sources: 

Kinder Morgan Liquids Terminals, LLC is subject to the 1-hour RACT. As a result of a case-by-case RACT 

determination, the facility is subject to the 1-hour RACT Plan Approval listed under the facility’s previous name, 

“GATX Terminals Corporation”, effective on May 29, 1995, and approved by the United States Environmental 

Protection Agency (EPA) on October 31, 2001 in 66 FR 54936. 

Table IV.1 below lists the VOC sources included in the 1-hr RACT Permit with the status of the source as of July 

2015. Further discussion on the applicable 1-hour RACT requirements is provided in Section VI of this document for 

each source evaluated. 

	Table	IV‐1:		VOC	Sources	subject	to	1‐hour	RACT	

1-hr RACT Sources July 2015 Status: 

(Controlled Tank-Truck Loading Operations) 

Tank car/truck loading racks connected to the NOA

Thermal Oxidation Unit -A, B. E, F, M &, V 

Controlled tank car-truck loading positions are now 

in Racks A, E, F, M, and D. See permit modification 

section under each group for details on specific 

permits. 

(Uncontrolled Tank-Truck Loading Operations) 

All uncontrolled tank car/truck positions: (RacksC,D,G,H,N,O,P,R,R-I,T & X) 

Uncontrolled tank car -truck loading positions are 

now in the Racks listed on page 8 of this memo. See 

permit modification section under each group for 

details on specific permits 

13.4 MMBtu/hr boiler; Active. In 2010, the boiler was modified to allow it 

to burn natural gas and was fitted with a low NOx 

Burner. 

6.7 MMBTU/hr boiler Removed and replaced with a new 12.6 MMBtu/hr 

boiler with low NOx burner in 2005. 

Thermal Oxidation Unit Active 

Oil/water separator Active, under insignificant sources 
Feb 23, 2016 Page 4 of 48 

14 volatile organic tanks, volume less than 

40,000 gallons 

Active, all presumptive/CTG RACT sources. 

81 volatile organic tanks, volume greater than 

40,000 gallons 

Active, all presumptive/CTG RACT sources. 

Fugitive Emissions from Process Equipment 

Components 

Active, CTG RACT Source 

Marine vessel loading operation, two berths. Active 

NOA - Control Equipment Active 

V. Sources Evaluated for 1997 8-hour VOC RACT : 

The facility’s significant air emissions sources contributing to VOC emissions are listed in the Table V-1. The facility’s 

control devices for these emissions units are listed in Table V-2. The facility’s De minimis air emissions sources (less 

than 1 tpy of VOC) contributing to VOC emissions are provided in Table V-3. 

Table	V‐1:	Sources	subject	to	8‐hour	RACT	

VOC Sources: RACT Category 

 Tank car/truck loading- organic liquids with RVP > 4.0 psi 

(controlled) 

Tank car/truck loading- organic liquids with RVP < 4.0 psi 

(uncontrolled) 

CTG RACT and Case-by-case 

RACT 

Case-by-case RACT 

 Marine vessel loading operations Case-by-case RACT 

 Fugitive emissions from process piping pumps, valves, & flanges. CTG RACT 

108 storage tanks (81 storage tanks with capacities greater than or 

equal to 40,000 gallons; 27 storage tanks with capacities less than 

40,000 gallons); 

CTG RACT and Presumptive 

RACT 

 ***490 hp emergency generator (Emergency Generator #1) Presumptive RACT 

12.6 MMBtu/hr boiler (Boiler #1); and 

 ***13.4 MMBtu/hr boiler (Boiler #2) 

Presumptive RACT 

***Indicate sources that were installed/constructed after the 1-hr RACT Permit. 

Table	V‐2:	VOC	Control	Devices	

 Control Devices: Comments 

A. One NAO Thermal Oxidation Unit (aka Thermal 

Incinerator as described under 1-hour RACT) 

This unit captures VOC emissions from 

controlled tank car/truck loading 

operations. 

B. *** One (1) Marine Vapor Combustion Unit (MVCU). 

Used for controlled marine vessel loading of cumene. 

 

 

This unit was installed after the SIPapproved 1-hr RACT plan approval was 

issued, and it is only used during marine 

loading cumene operations. This unit was 

installed when there was an increased 

marine loading of cumene. It was installed 

to ensure compliance with the facility-wide 

Hazardous Air Pollutant (HAP) Synthetic 

Minor limits of AMS Plan Approval 06021 

dated 2/2/2007. 

***Indicate sources that were installed/constructed after the 1-hr RACT Determination. 

 
Feb 23, 2016 Page 5 of 48 

Table	V‐3:	De	Minimis	VOC	Sources		

 Tank cleaning and degassing operations

*** Soil Vapor Extraction System with CatOx

***Two (2) 48 hp air compressors; 

Painting of tanks; 

Sump tank; (listed as "insignificant source) 

Catch basins (listed as “insignificant sources” on Title V Operating Permit V95-044); 

Two oil water separator (Receives <200 gallons of organic materials per day, listed as “insignificant 

sources” on Title V Operating Permit V95-044); 

Drumming operations (listed as “insignificant sources” on Title V Operating Permit V95-044); 

Steam cleaning of equipment (listed as “insignificant sources” on Title V Operating Permit V95-044); 

Chemical dryers (listed as “insignificant sources” on Title V Operating Permit V95-044); 

Pipe cleaning (listed as “insignificant sources” on Title V Operating Permit V95-044); 

Flushing of tanks with incoming products (listed as “insignificant sources” on Title V Operating Permit 

V95-044); 

Fire equipment (listed as “insignificant sources” on Title V Operating Permit V95-044); 

Mobile tanks (500 gallons each, listed as “insignificant sources” on Title V Operating Permit V95-044); 

Tanks 1 (Emergency containment tank, listed as “insignificant sources” on Title V Operating Permit V95-

044); 

Tanks 2 and 3 (Emergency containment tank, listed as “insignificant sources” on Title V Operating Permit 

V95-044); 

Tank no471 (#2 oil for the vapor incinerator, listed as “insignificant sources” on Title V Operating Permit 

V95-044); 

Tank no. 420 (#2 oil for the boilers, listed as “insignificant sources” on Title V Operating Permit V95-044); 

***Indicate sources that were installed/constructed after the 1-hr RACT Determination. 

VI. VOC RACT Evaluation: 

A.			Tank Car/Truck Loading Operations

Kinder Morgan Liquid Terminals, LLC owns and operates various tank car/truck loading racks. A loading rack 

consists of multiple loading positions. Each loading position of a rack connects to a specific storage tank, and are 

used to transfer liquids between a tank car or trucks and the storage tank. Tank car / truck loading racks have various 

loading positions that can either be "controlled" or "uncontrolled". Controlled loading positions are permanently 

configured to vent to a NAO Thermal Oxidation Unit to control VOC emissions. Gasoline or organic liquids with a 

RVP equal to or greater than 4.0 psi are required to be controlled, per the presumptive RACT requirements of 25 PA 

Code 129.59. Uncontrolled loading positions at a loading rack are not vented to the Thermal Oxidizer, but are 

limited to loading liquids with RVP less than 4.0 psi. Therefore, uncontrolled loading is only expected to occur at 

any uncontrolled loading positions. 

1. Tank Car/Truck Loading Operations	‐	1 Hour RACT Requirements

Under the 1-hour RACT permit, each rack was identified rack as “controlled” or “uncontrolled.” Loading racks with 

some controlled loading positions were called controlled loading racks, even though they could also have 

uncontrolled loading positions. The case-by-case requirements for the tank car/truck loading racks included in the 

SIP-approved 1-hr RACT plan approval are provided in Table VI.A-1 below. 

 
Feb 23, 2016 Page 6 of 48 

Table	VI.A‐1:	1‐hour	RACT	Case‐by‐Case	Requirements	for	Tank	Car/Truck	Loading	

Condition 2B The operation of the following equipment in accordance with the presumptive RACT 

requirements of 25 PA Code 129.93(c)(4) 

Condition 2C Tank car/truck loading racks – A, B, E, F, M, & V shall comply with 25 PA Code 129.59 

Condition 2D Tank car/truck loading racks – C, D, G, H, N, O, P, R, R-1, T, & X which are uncontrolled shall 

be limited to processing organic liquid with vapor pressure lower than 4 RVP 

Condition 3A Tank car/truck loading racks – C, D, G, H, N, O, P, R, R-1, T, & X which are uncontrolled shall 

be limited to 129 tons of VOC per year. 

Condition 5B GATX [Kinder Morgan] shall monitor throughput of material processed and vapor pressures for 

all tanks, marine loading, and tank car/truck loading racks on a daily basis.” 

Under the 1-hour RACT, controlled loading racks are subject to 25 PA Code 129.59. As per 25 PA Code 129.59 (a), 

a person may not cause or permit the loading of gasoline (defined in 25 PA Code 121.1, as petroleum distillate with a 

Reid Vapor Pressure (RVP) ≥ 4.0 psi and which is a liquid at standard temperature and pressure) into a vehicular tank 

from a bulk gasoline terminal unless the gasoline loading racks are equipped with a vapor collection and disposal 

system capable of processing volatile organic vapors and gases so that no more than 0.0668 pounds (30.3 grams) of 

gasoline (measured as propane) are emitted to the atmosphere for every 100 gallons (380 liters) of gasoline loaded. In 

other words, loading of organic liquids with RVP > 4.0 psi was required to be controlled by operation of a vapor 

collection and control system. As a result, the facility operates a NAO Thermal Oxidizer. Operation of uncontrolled 

racks was limited to loading of liquids with RVP < 4.0 psi and subject to a combined emission limit of 129 tons of 

VOC per year. 

The 1-hour RACT permit did not specify that there were certain loading positions in the “controlled racks” (i.e., racks 

A, B, E, F, M & V) that were not connected to the control. However, Kinder Morgan has operated these positions for 

loading of liquids with RVP < 4.0 psi to be able to comply with 25 PA Code 129.59. Further, the facility and AMS 

have interpreted any uncontrolled loading at any of the racks to be subject to the 129 tpy VOC limit in the 1-hour 

RACT plan approval. 

2. Tank Car/Truck Loading Operations‐		Permit Modifications

Table VI.A-2 lists the permit modifications for the controlled and uncontrolled tank car/ truck loading operations that 

AMS has approved since the 1-hr RACT Permit. 

Table	VI.A‐2:	Permit	Modifications	

Permit Modifications 

Controlled and uncontrolled tank car /truck loading positions and racks have changed since the 1-hr 

RACT permit because certain racks are connected to certain storage tanks. Storage tanks usage depends 

on the clients’ storage needs and the materials stored in the tanks. 

TV No 095-44 dated 9/9/2001

 DSP Loading Rack is listed and permitted in the facility's Title V Operating Permit No. 95-044 

under uncontrolled loading rack. This loading rack was present during the 1-hr RACT, but not 

addressed at the time.

TV No. 095-44 dated 9/9/2001 and AMS Permit No. 02139 dated 12/10/2007.

 Uncontrolled Rail Siding 1, Rail Siding 2, and Rail 3 Siding loading positions were present 

during the 1-hr RACT, but not addressed. These were not racks (physical structures), but these 

were positions where the rail/tank cars would be set up for loading. With the exception of Rail 

Siding 1, Spot 1, these rail loading positions are listed and permitted in the facility's Title V No. 

095-44 permit as uncontrolled loading positions. 

 Rail Siding 1, Spot 1 is a controlled loading position associated with Rack D which was modified 

to a controlled rack in 2007 under AMS Permit No. 02139 below.

AMS Permit No. 02139 dated 12/10/2007 allowed for the following modifications:

 Rack X (450 gpm pump capacity) was modified to add a new bottom loading position which is 

controlled and vented to the control device. The permit limits loading from the Rack X new 

bottom position (controlled loading) to 49.25 million gallons per 12 month rolling period and a 
Feb 23, 2016 Page 7 of 48 

VOC emissions of 2 tons per rolling 12 month period. The VOC potential increase from 

controlled emission from Rack X is the 2 tpy based on the throughput limit. With this permit 

modification, Rack X is now considered a controlled rack with the ability to also load materials 

with RVP < 4 at its existing uncontrolled loading position. 

 The permit also allowed for disconnecting the existing vapor recovery line from Rack V and 

rerouting to Loading Rack D. The vapor line from Rack V was rerouted to Rack D so products 

with RVP of 4 or greater may be loaded on one side by truck and by rail on the other side (Rail 

Siding 1, Spot 1). Rack D is now considered a controlled rack and Rack V is now considered 

an uncontrolled rack. The pump capacity for Racks D and V is 450 gallons per minute. 

 This permit did not change the total VOC PTE for uncontrolled tank car and truck loading 

operations because the 129 tons per rolling 12 month period is still in effect. 

AMS Permit No. 08211 dated 12/11/2008 allowed for the following modifications:

 All controlled loading positions were removed from Racks X and B (one controlled loading 

position from each rack for a total of two controlled loading positions). With this permit 

modification, Racks X and B are now considered uncontrolled racks. The permit also limits 

Racks B and X to loading of only organic liquids with a RVP of less than 4.0 psi. With the 

addition of Racks B and X to the uncontrolled Racks, there is no potential increase in the facility's 

emissions from uncontrolled tank car truck loading operations since the 129 tons of VOC per year 

RACT limit is still in effect. 

 One controlled loading position was moved to Rack F and the other controlled loading position 

was moved to Rack M. Racks F and M to be controlled racks, remaining capable of 

loading both uncontrolled and controlled products. As a result of the modifications 

above, Rack F increased loading capacity from 450 gpm to 1200 gpm for controlled products. 

Rack M loading capacity remains at 450 gallons per minute, but the number of controlled loading 

positions at Rack M increased to two. 

 The permit also limits tank truck loading of ethanol at facility to 150,000,000 gallons per 

 rolling 12 month which equates to about 3 tpy. (See Attachment A - AMS Permit 08211/14350 

Memo for the detailed calculation.) Overall there is no VOC emission increase for the facility 

since uncontrolled loading is still limited to 129 tons per year. 

AMS Permit No 09105 dated 1/19/2010

 This permit intended to clarify the terms uncontrolled and controlled racks and uncontrolled and 

controlled loading positions at the facility and applicable requirements of the racks and loading 

positions to the 1-hr RACT permit. The 1-hr RACT permit listed specific racks as “controlled 

racks” and needed to comply with the requirements of 25 PA Code 129.59, requiring VOC 

control through operation of a vapor collection and disposal system (the NAO Thermal oxidizer). 

The 1-hr RACT Permit listed specific racks as “uncontrolled racks” which needed to comply 

with a 129 tons per year VOC limit. The 1-hr RACT Permit did not list or clarify that the 

controlled racks may also have uncontrolled loading positions which were not vented to a control 

device. When reading the 1-hr RACT permit, one might interpret that controlled racks have all 

controlled loading positions, but as explained earlier this is not the case. AMS Permit No 09105

clarified the applicable requirements for the positions rather than racks, based on the connection 

of loading positions to the control. The permit also removed the identification of specific racks 

and provided the applicable requirements in terms of loading positions rather than loading racks, 

per the facility’s request. 

 Another intent of the permit was to provide consistency with the Philadelphia Air Management 

Services regulations, and construction permits approved by AMS after the 1-hr RACT permit. As 

listed in the AMS permits above, some of the controlled racks and uncontrolled racks no longer 

had the same status as under the 1-hr RACT permit. The permit proposed language that provided 

consistency with previous permits issued by AMS.

 There were no changes to any RACT emission limits from the original 1-hr RACT Plan 

Approval. There were no physical changes proposed with the permit modification. The proposed 

clarification to the RACT conditions approved in this permit has not been approved into the SIP 

to date, but is proposed to be approved into the SIP as part of this 8-hour RACT determination. 
Feb 23, 2016 Page 8 of 48 

See Attachment B - AMS Permit 09105 Memo, for a comparison of conditions between the AMS 

Permit No. 09105 and the 1-hr RACT permit.

AMS Permit No. 14351 dated 12/11/2014 allowed for the following modifications:

 Increase ethanol throughput through the facility from 150,000,000 to 200,000,000 gallons per 12-

month rolling, which corresponds to an emissions limit of 3.99 tons per rolling 12 month period 

for tank truck loading of ethanol. This is a potential increase of about 1 tpy of VOC emission from 

the increase in ethanol throughput. (See Attachment A - AMS Permit 08211/14351 Memo for 

detailed calculations.) Overall there is no VOC emission increase for the facility since 

uncontrolled loading is still limited to 129 tons per year. 
Feb 23, 2016 Page 9 of 48 

After the approved permits, the racks at Kinder Morgan have been modified to the following: Table	VI.A‐3:	Summary	of	Modifications	to	Tank	Car	/	Truck	Loading	Racks		

Rack ID 

Previous Rack 

Category 

 (1-Hr RACT Permit) 

Summary of Modifications Controlled vs. Uncontrolled 

A Controlled None Remains with controlled and uncontrolle

( 2 controlled loading positions and 2 uncontrolle

E Controlled None Remains with controlled and uncontrolle

( 1 controlled loading position and 6 uncontrolle

F Controlled 

Increased pump capacity from 450 gpm to 

1200 gpm for controlled loading. Additional 

control position added. The pump capacity 

for uncontrolled loading is at 450 gpm. 

Remains with controlled and uncontrolle

 ( 2 controlled loading positions and 2 uncontroll

M Controlled Additional controlled loading position added. No increase in rack pump capacity. Remains with controlled and uncontrolle

( 2 controlled loading positions and 4 uncontrolle

D Uncontrolled Uncontrolled positions connected to control. Currently has controlled and uncontrolle

( 2 controlled loading positions and 3 uncontroll

B Controlled Controlled positions no longer connected to control. Currently with uncontrolled posit

(2 uncontrolled loading position

V Controlled Controlled positions no longer connected to control. Currently with uncontrolled posit

(1uncontrolled loading positio

C Uncontrolled None All positions remain uncontroll

(2 uncontrolled loading position

G Uncontrolled None All positions remain uncontroll

(4 uncontrolled loading position

H Uncontrolled None All positions remain uncontroll

(2 uncontrolled loading position

N Uncontrolled None All positions remain uncontroll

(2 uncontrolled loading position

O Uncontrolled None All positions remain uncontroll

(4 uncontrolled loading position

P Uncontrolled None All positions remain uncontroll

(2 uncontrolled loading position

R Uncontrolled None All positions remain uncontroll

(4 uncontrolled loading position

R-1 Uncontrolled None All positions remain uncontroll

(2 uncontrolled loading position

T Uncontrolled None All positions remain uncontroll

(4 uncontrolled loading position
Feb 23, 2016 Page 10 of 48 

X Uncontrolled Added controlled positions, but then remove

d

from rack. 

All positions remain uncontroll

(2 uncontrolled loading position

DSP N/A New All positions are uncontrolled

( 1 controlled loading position

Rail Siding 1 N/A 

New All positions are uncontrolled, expect for Rail Sid

controlled under Rack D. ( 5 uncontrolled loadi

controlled loading position) 

Rail Siding 2 N/A New All positions are uncontrolled

( 12 uncontrolled loading positio

Rail Siding 3 N/A New All positions are uncontrolled

(7 uncontrolled loading position
Feb 23, 2016 Page 11 of 48 

3.		Tank Car /Truck Loading Operations‐	Applicable Requirements

Loading of VOC materials with a RVP greater than or equal to 4.0 psi continues to be subject to the CTG RACT 

regulation 25 PA Code 129.59(a), as specified in the 1-hour RACT plan approval. Additionally, the loading of VOC 

materials with a RVP greater than or equal to 4.0 psi is subject to AMR V, Section V(a). As per AMR V, Section 

V(a), no person shall load any organic material having a Reid vapor pressure of 4.0 pounds or greater into any tank 

truck, tank car, or trailer from any loading facility from which 20,000 gallons or more of such organic material are 

loaded in any one day from this facility unless this facility is equipped with a vapor recovery system properly 

installed, well maintained, in operation, and approved by the Department. Such a vapor recovery system shall be 

capable of collecting the organic materials emitted from the filling operation and disposing of these emissions so as to 

prevent their release to the atmosphere. 

As per the above CTG conditions, AMS finds that 25 PA Code 129.59(a) is more stringent than AMR V, Section 

V(a) for VOC emissions due to the emission limit from loading. Therefore, this RACT requirement for loading of 

VOC materials with a RVP greater than or equal to 4.0 psi remains unchanged. Controlled loading must be connected 

to the NAO Thermal Oxidation unit which is capable of processing volatile organic vapors and gases so that the 

above emission rate is met (i.e. 0.0668 pounds /100 gallons of gasoline). See the table below for a “Tank Car/Truck 

Loading Operations 1-hr RACT Summary” of applicable regulations. Additionally, it is important to note that the 

NAO Thermal Oxidation Unit has a maximum throughput capacity of 85,260 gallons per hour. 

Loading of VOC materials with a RVP below 4.0 psi is applicable to case-by-case RACT. As specified in the caseby-case SIP-approved 1-hour RACT plan approval conditions, the uncontrolled tank car/truck loading racks can only 

process organic liquid with a vapor pressure lower than 4.0 RVP and have a combined emission limit of 129 tons of 

VOC per year. Although not specified in the SIP-approved 1-hour RACT plan approval, AMS considers the loading 

of materials with a vapor pressure lower than 4.0 RVP at the “controlled racks” (as identified in the SIP-approved 1-

hour RACT plan approval) to be subject to the 129 tons of VOC per year limit. 

4. Tank Car/Truck Loading Operations	‐	8 Hour RACT Evaluation

a. Controlled Loading Positions

Table VI.A-4 below provides the PTE of controlled loading positions based on a possible actual operating scenario 

of 1000 hours of operation per controlled rack per year, which is the most a loading position can operate due to the 

time it takes to move trucks in and out of the position, connecting and disconnecting the loading arm, etc. 

Table	VI.A‐4:	Potential	VOC	Emissions	from	Controlled	Tank	Car/Truck	Loading	Operations	

Location Position* 

Pumping 

Rate 

(gpm) 

Emission 

Factor** 

(lb/100 

gal) 

Emissions 

(lb/hr) 

Operating 

Hours*** 

(Hours/year) 

Total 

Controlled 

Loading 

Emissions 

(tons/year) 

A Rack 

1 -Truck 

450 0.0668 18.036 1000 2 - Truck 9.018 

E Rack 1 - Truck 450 0.0668 18.036 1000 9.018 

F Rack 1 - Truck 1200 0.0668 48.096 1000 2 - Truck 24.048 

M Rack 

1 - Truck 

450 0.0668 18.036 1000 9.018 2 - Truck 

D Rack 1 - Truck 450 0.0668 18.036 1000 9.018 

Spot 1-1 2 - Rail 450 0.0668 18.036 1000 9.018 

TOTAL - 3,450 - 138.28 6000 69.14 

*A=. and M racks have two (2) loading positions that cannot load simultaneously due to space issues (a truck can 

only fit on one side of the rack); 

**Emission factor from 25 PA Code 129.59(a); 
Feb 23, 2016 Page 12 of 48 

***Operation is physically limited to 1,000 hours per controlled rack per year due to the time it takes to connect and 

disconnect trucks, move in and out of position, etc. 

As seen above, all controlled loading has the potential to emit a total of 69.14 tons of VOC per year. Based on 

compliance with the 25 PA Code 129.59, all controlled positions loading organic liquids greater than or equal to 4.0 

RVP are connected to the NAO Thermal Oxidation Unit, which is capable of processing volatile organic vapors and 

gases so that emissions are no more than 0.0668 pounds of VOC /100 gallons of gasoline. Stack testing of the NAO 

Thermal Oxidation Unit is necessary in order to ensure compliance the control device emission rate limitation. 

b. Uncontrolled Loading Positions

Table VI.A-6 lists the uncontrolled tank car truck loading positions at the facility. Each uncontrolled loading rack 

pump has a maximum capacity of 450 gallons per minute. The PTE for each uncontrolled loading position is based 

on AP-42 Section 5.2 and fuel grade ethanol. Fuel grade ethanol is the facility’s highest emitting product that can be 

loaded without controls. Table VI.A-5 below provides the fuel grade ethanol properties and loading operations 

characteristic that were used to calculate the loading loss emission factor (LL). 

Table	VI.A‐5:	Loading	Loss	Emissions	Factor	for	Fuel	Grade	Ethanol		

 **CE=0% because there is no control 

Table VI.A-6 in the following page provides a more detailed PTE estimate per uncontrolled loading position, 

assuming ethanol loading. As shown in Table VI.A-6, uncontrolled loading positions at the facility are subject to the 

129 tpy and that the PTE calculations per position to continue to be the most stringent and enforceable limit of the 

PTE. 

Chemical 

Vapor 

Pressure 

(psia) 

M; 

Molecular Weight CE%** S; Saturation Factor 

T; 

Annual Avg. 

Temp. 

(deg. F) 

LL; 

Emission 

Factor 

(lb/1,000 gal) 

1.21 46 0 0.5 60 0.67 
Feb 23, 2016 Page 13 of 48 

 Uncontrolled Loading Positions 

														Table	VI.A‐6:	Potential	VOC	Emissions	from	Uncontrolled	Tank	Car/Truck	Loading	Operations		

Rack 

Name 

No. of 

Uncontrolled 

Loading 

Positions 

Pumping 

Rate 

(gpm) 

LL; 

Emission Factor 

(lb/1,000 gal) 

Emissions 

(lb/hr) 

Operating 

Hours 

(Hours/year) 

Emissions  

(tons) 

Simultaneous 

Loading? 

** ** 

Number of 

Positions Loaded 

Simultaneously 

A Rack* 2 450 0.67 18.0 1,000 9.0 No 1 

450 0.67 18.0 1,000 9.0 

E Rack* 6 

450 0.67 18.0 1,000 9.0 

Yes 2 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

F Rack* 1 450 0.67 18.0 1,000 9.0 No 1 

M 

Rack* 4 

450 0.67 18.0 1,000 9.0 

No 1 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

D Rack* 3 

450 0.67 18.0 1,000 9.0 

450 0.67 18.0 1,000 9.0 No 1 450 0.67 18.0 1,000 9.0 

B Rack 2 450 0.67 18.0 1,000 9.0 No 1 

450 0.67 18.0 1,000 9.0 

V Rack 1 450 0.67 18.0 1,000 9.0 No 1 

C Rack 2 

450 0.67 18.0 1,000 9.0 

Yes 2 

450 0.67 18.0 1,000 9.0 

G Rack 4 

450 0.67 18.0 1,000 9.0 

Yes 2 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

H Rack 2 450 0.67 18.0 1,000 9.0 Yes 2 

450 0.67 18.0 1,000 9.0 

N Rack 2 450 0.67 18.0 1,000 9.0 No 1 
Feb 23, 2016 Page 14 of 48 

450 0.67 18.0 1,000 9.0 

O Rack 4 

450 0.67 18.0 1,000 9.0 

No 1 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

P Rack 2 450 0.67 18.0 1,000 9.0 No 1 

450 0.67 18.0 1,000 9.0 

R Rack 4 

450 0.67 18.0 1,000 9.0 

Yes 2 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

R-1 

Rack 2 450 0.67 18.0 1,000 9.0 No 1 

450 0.67 18.0 1,000 9.0 

X Rack 2 450 0.67 18.0 1,000 9.0 No 1 

450 0.67 18.0 1,000 9.0 

DSP 

Rack 1 450 0.67 18.0 1,000 9.0 No 1 

T-Rack 4 450 0.67 18 1000 9.0 No 1 

Rail 

Siding 1 5 

450 0.67 18.0 1,000 9.0 

Yes 5 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

Rail 

Siding 2 12 

450 0.67 18.0 1,000 9.0 

Yes 12 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

Rail 

Siding 3 7 450 0.67 18.0 1,000 9.0 Yes 7 

450 0.67 18.0 1,000 9.0 
Feb 23, 2016 Page 15 of 48 

450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 450 0.67 18.0 1,000 9.0 

TOTAL 

 * Each rack has additional positions connected to the control, whose PTE has been considered for RACT under controlled loading. ** Operation is limited to 1,000 hours per year due to the time it takes to connect and disconnect trucks, move in and out of position, etc. EmiSection 5.2 using fuel grade ethanol. This is not an enforceable emissions limitation, but reflects actual and projected operations. *** Some loading racks are able to load simultaneously, that is, they can have two trucks loading at the same time, one on each side of the racloading racks cannot load simultaneously, that is, they can only load one truck at a time because one side of the rack is blocked by an obstruct

there is not enough space to load more than one truck per side at any given time. Rail sidings at the facility have enough space to simultaneouloading position. 
Feb 23, 2016 Page 16 of 48 

In order to determine RACT 1997 8-hour ozone NAAQS for “uncontrolled” tank/rail car and truck loading 

operations, AMS has evaluated the feasibility of adding a control device to control VOC emissions from loading 

VOC liquid materials with an RVP < 4.0 psi. The following provides the associated analysis: 

Table	VI.A‐7:	Possible	Control	Rankings	for	Uncontrolled	Loading	Operations	

*Does not include capture efficiency, therefore the actual control efficiencies used in the calculations below may 

vary as they will integrate capture efficiency (i.e. 90% is included in the analysis for an additional Thermal 

Oxidation Unit at the tank car/truck loading racks) 

Technically Feasibility Evaluation:

(1) Connection to the Existing Thermal Oxidation Unit - Technically Infeasible 

a. Kinder Morgan Liquid Terminals, LLC cannot connect any additional loading positions to the NAO 

Thermal Oxidation Unit following the following reasons:

i. The existing thermal oxidizer is currently operated at capacity;

ii. The existing control system is not set up to handle such varying streams from very lean to 

very rich; 

iii. It is not technically feasible to connect additional loading positions located at the 

“Controlled Loading Racks” (as defined in the 1-hor SIP-approved plan approval) since 

the racks have physical space limitations that would prevent the installation of equipment 

such as metered loading equipment, top/bottom loading arms, overflow sensors, steel 

support structures, etc.;

iv. Additionally, it is important to note that control of the low vapor pressure chemicals would 

require the control device to burn excessive quantities of natural gas in order to achieve 

and maintain the required operating temperature. As a result, the oxidizer would be 

generating significant nitrogen oxide and carbon monoxide emissions to achieve 

insignificant VOC reductions from the low vapor pressure products. This would be 

counterproductive with respect to protecting the environment. ;

(2) Additional Thermal Oxidation Unit - Technically Feasible 

a. As is described above, Thermal Oxidation is a process in which the hydrocarbons in a gas stream 

are combusted to form carbon dioxide and water at an elevated temperature. Thermal Oxidation is 

governed by temperature, time, and turbulence. In order to achieve effective combustion the 

organic must be raised 100 degree Fahrenheit or more above its ignition temperature and held at 

that for good oxidation to occur. An auxiliary fuel is required to ensure the temperature is 

maintained for proper combustion.

b. There are essentially two (2) types of incinerators: thermal and catalytic. Each type is considered 

technically feasible for the marine loading operation. However, for costs analysis purposes, thermal 

incineration is being considered since the relative cost of the two are similar. 

(3) Carbon Adsorption – Technically Infeasible 

a. Adsorption is where gas molecules are passed through a bed or solid particles, then diffuses from 

the gas stream to the bed, and held on the media by attractive forces. Adsorptive capacity of the 

solid for the gas tends to increase with the gas phase concentration, molecular weight, diffusivity, 

polarity, and boiling point. 

b. Typical adsorbents media in use include activated carbon, silica gel, activated alumina, synthetic 

zeolites, fuller’s earth, and other clays. This RACT analysis is oriented toward the use of activate 

carbon, a commonly used adsorbent for VOCs. Carbon adsorption is effective when materials have 

a molecular weight of 50 or greater. 

Control Estimated Effectiveness*

Thermal Oxidation 95-98 %

Carbon Adsorption 85-95%

Bioreactor 60-99%

Scrubbers 50-98%

Condensation 50-90%
Feb 23, 2016 Page 17 of 48 

c. Carbon adsorption is considered technically infeasible for the operation since it would not be 

effective on all materials handled at the dock. Ethanol is loaded into vessels in addition to other 

materials. The molecular weight of ethanol is 46, thus making carbon adsorption infeasible.

(4) Bioreactor – Technically Infeasible

a. There are several different types of bioreactors from soil beds or bio-filters to bio-trickling filters, 

and bio-scrubbers. Typically used for odor control, bioreactors can be used to oxidize VOCs. For a 

bioreactor to be effective, one needs a consistent stream and maintain temperature above 60 degrees 

Fahrenheit. The marine vessel operation at Kinder Morgan is intermittent and the climates average 

annual temperature is below 60 degrees Fahrenheit. While there are other factors to consider, this 

control option is considered technically infeasible due to the intermittent nature of the operation and 

the climate of the area.

(5) Scrubbers – Technically Infeasible

a. Scrubbers use a process called absorption to remove pollutants from an air stream to a liquid 

stream. The absorption processes the organics in the air stream are dissolved in a liquid solvent. 

The limiting factors as a primary control technique deal with the availability of a suitable solvent 

and the solubility of the organic. In this case, the terminal would require different solvents to handle 

the varying material handled. Based on the organics in the air stream requiring different absorption 

media this control option is considered technically infeasible.

(6) Condensation – Technically Infeasible 

a. Refrigeration units are basically “heat pumps,” absorbing heat on the “cold side” of the system and 

releasing heat on the “hot side” of the system. 

b. A refrigerated condenser is a viable option if:

i. The air stream is saturated with the organic compound

ii. The organic vapor containment system limits air flow

iii. Required air flow does no overload a refrigeration system with heat

iv. Only one organic compound is emitted

c. Since the marine vessel loading operation is only considered to be 50 percent saturated and there 

are multiple organic compounds, this control option is considered infeasible. 

Technically Feasibility Cost Analysis:

 Thermal Oxidizer Technical Feasibility Cost Analysis: 

“Uncontrolled Loading at All Positions” 

The goal of this cost analysis is to determine the feasibility of connecting all uncontrolled loading positions located at 

either the “Controlled Loading Racks” or at the “Uncontrolled Loading Racks” to a second thermal oxidation unit. 

(As is explained above, connection to the existing NAO Thermal Oxidation Unit is technically infeasible.) 

To determine the cost effectiveness of the technically feasible control option, connection to a thermal oxidation unit, 

a cost analysis was conducted and is presented below. The capital cost for the thermal oxidizer is based on a vendor 

quote for another project (see “Attachment F”) and is presented in the following tables. Below is a cost analysis for 

the control of all uncontrolled loading positions at any Rack. 

The cost analysis is based on 8760 hours annual of operation of a thermal oxidizer. All uncontrolled positions will 

need to be vented to the thermal oxidizer and as seen in Table IV-6, the total of uncontrolled operation hours for all 

uncontrolled position is more than 8760 hours. 

 
Feb 23, 2016 Page 18 of 48 

Uncontrolled Loading at All Positions – Total Capital Investment 

*See Attachment F for vendor quote 

 
Feb 23, 2016 Page 19 of 48 

------------------------------------------------------------------------------------------------------------------------------------------- 

All Uncontrolled Loading Positions – Total Annual Cost 

Table	IV.A‐8:	All	Uncontrolled	Loading	Positions	–	Cost	Summary

Source Total Capital 

Investment 

Total Annual Operating 

Cost (8760 hours) 

All Uncontrolled Loading Rack Positions $3,038,318.71 $ 1,900,430.61 

Based on a vendor quote for another project, the capital cost for the thermal oxidizer is estimated to be $3,038,318.71 

and the annual operating costs are $ 1,900,430.61per year. The costs estimates are consistent with the EPA Air 

Pollution Control Costs Manual, Version 6. The annual costs include operating and maintenance labor, fuel and 

electrical costs, and a capital depreciation of 7 percent over 10 years. The costs of the technically feasible controls are 

based on vendor quotes and readily available literature. The cost of this control unit is scaled from the original 

contractor proposal using the “Sixth-Tenth Factor Rule.” The equation, referenced from Peters and Timmerhaus, 

Plant Design and Economics for Chemical Engineers, Fourth Edition, 1191 Page 169, is as follows: 

 
Feb 23, 2016 Page 20 of 48 

As is discussed above, the potential to emit for total uncontrolled loading position is 129 tons of VOC per year. Using 

the 129 tons of VOC per year as the baseline emissions, and given the total capital investment and annual operating 

costs, the implementation and use of a thermal oxidation unit at each uncontrolled loading position does not prove to 

be cost effective in nature in that it yields a cost effectiveness of $17,678.42/ton. 

In light of the aforementioned, given that the only technically feasible control option is not cost effective, no 

requirement to connect all uncontrolled loading positions to a thermal oxidation unit can be made. 

All Uncontrolled Loading Positions – Technical/Cost Feasibility 

Table	VI.A‐9:	All	Uncontrolled	Loading	Positions	–Cost	Feasibility	

Rank 1 Control 

Technology 

Baseline NOx 

Emissions 

(tpy) 

NOx 

Reduction 

(%) 

NOx 

Reduction 

(tpy) 

Total Annualized Cost Cost 

Effectiveness 

($/Ton) 

1 Thermal 

Oxidation 

129 83.3 107.5 $1,900, 430.61 $17,678.42 

Technically Feasibility Conclusion:

The above cost analysis shows that based on the current permitted values/PTEs, the only technically feasible control, 

(the thermal oxidation unit) for all uncontrolled loading positions is not cost effective and thus no control device is 

determined as RACT. AMS; therefore, determines that the new case-by-case conditions presented above for 

uncontrolled loading positions represents VOC RACT under the 1997 8-hour ozone standard for the tank car/truck 

loading operations in Kinder Morgan. Additionally, in order to further ensure compliance with the 129 tons of VOC 

per year limitation, the facility is accepting the following limits: VOC emissions shall be limited to 9.0 tons of VOC 

per year and 18.1 pounds per hour per uncontrolled position at each tank car/truck loading rack. 

5. Tank Car/Truck Loading Operations – Proposed 8 Hour RACT Requirements		

a. Loading of Liquids Organic Liquids with RVP > 4.0 psi

For the tank car and truck loading of organic liquids with RVP of or greater than 4.0 psi, AMS proposes RACT 

should continue to be compliance with the CTG RACT regulation 25 PA Code 129.59. The current level of control 

continues to represent RACT under the 1997 8-hour RACT. 

 Kinder Morgan is also taking a 57.0 pounds of VOC per hour limit for all controlled rail tank car/truck loading 

positions at the facility. The 57.0 lb/hr corresponds to the maximum capacity of the oxidizer at 1421 gallons per 

minute or 82,600 gallons per hour and the 0.0668 lb/100 gallon limit from 25 Pa Code 129.59(a). AMS has 

determined the following conditions in Table VI.A-10 below for controlled loading as RACT and as conditions in the 

revised RACT plan approval. 

Table	VI.A‐10:	Controlled	Loading	‐	8	hr	RACT	

Condition 2A 

[The requirements of 

25 Pa Code Section 

129.59 are being 

written out for clarity ]

Volatile Organic Compounds (VOC) liquids with a Reid Vapor Pressure (RVP) greater 

than or equal to 4.0 psi shall only be loaded at loading positions connected to the NAO 

Thermal Oxidation Unit complying with 0.0668 pounds (30.3 grams) of organic liquids 

(measured as propane) are emitted to the atmosphere for every 100 gallons (380 liters) of 

liquids loaded. 

Condition 3A.1 

[NEW- in the RACT 

The total combined VOC emissions from all controlled tank car/truck loading 

positions/operations at the facility shall be less than 57.0 pounds per hour. 

Cost of Equipment A = Cost of Equipment B * (Capacity of Equipment A / Capacity of Equipment B)^0.6
Feb 23, 2016 Page 21 of 48 

Plan Approval] 

Condition 4A and 

Condition 5A 

[ Both Conditions 

new in the RACT 

Plan Approval]

Kinder Morgan shall conduct stack testing per AMS approved protocol on the NAO 

Thermal Oxidation Unit at least every five (5) years. 

Initial testing must commence no later than 18 months following the effective date of 

this plan approval. 

AMS has added the following additional monitoring and recordkeeping requirements to the RACT plan approval: 

Condition 5A Kinder Morgan shall monitor throughput of material processed and vapor pressures for 

all tanks, marine loading, and tank car/truck loading racks on a daily basis. 

Condition 7A 

[NEW- in the RACT 

Plan Approval] 

For controlled and uncontrolled loading tank car/truck operations, Kinder Morgan Liquid 

Terminals, LLC shall keep records of the following: 

1. Which rack is being used for loading; 

2. Which position at each rack is being used for loading; 

3. Whether the position being used for loading is controlled or uncontrolled; 

4. The name of material loaded per position; 

5. Throughputs of each material loaded per position; 

6. The corresponding vapor pressures of the material loaded per position; 

7. Emissions calculations from all controlled loading rack positions to 

 demonstrate compliance with the lb/hour limit of Condition 3.A.1 

b. Loading of Liquids Organic Liquids with RVP < 4.0 psi

AMS has determined the following new case-by-case conditions for uncontrolled loading as 8-hr RACT: 

Table	VI.A‐11:	Uncontrolled	Loading	‐	8	hr	RACT	

Condition 2B 

[New in 8hr- RACT 

Plan Approval]

Loading operations at any tank car/truck loading position not connected to the NAO 

Thermal Oxidizer, or “uncontrolled tank car/truck loading position”, shall be limited to 

processing organic liquid with a Reid Vapor Pressure (RVP) less than 4.0 pounds per 

square inch (psi). 

Condition 3B.1 thru 

B.3 

 [NEW- in the RACT 

8hr - Plan Approval]

Loading operations at “uncontrolled tank car/truck loading positions” shall comply with 

the following: 

1. Total combined emissions from all “uncontrolled tank car/truck loading positions” at 

the facility combined shall be limited to 129 tons of VOC per 12 month rolling 

period; 

2. Emissions from each “ uncontrolled tank car/truck loading position” shall not exceed 

9.0 tons of VOC per 12 month rolling period; 

3. Emissions from each “uncontrolled tank car/truck loading position” emission shall 

not exceed 18.1 pounds of VOC per hour. 

AMS has added the following additional monitoring and recordkeeping requirements to the RACT plan approval: 

Condition 5A Kinder Morgan shall monitor throughput of material processed and vapor pressures for 

all tanks, marine loading, and tank car/truck loading racks on a daily basis. 

Condition 7A 

[NEW- in the RACT 

Plan Approval] 

For controlled and uncontrolled loading tank car/truck operations, Kinder Morgan Liquid 

Terminals, LLC shall keep records of the following: 

1. Which rack is being used for loading; 

2. Which position at each rack is being used for loading; 

3. Whether the position being used for loading is controlled or uncontrolled; 

4. The name of material loaded per position; 

5. Throughputs of each material loaded per position; 

6. The corresponding vapor pressures of the material loaded per position; 

7. Emissions calculations from all controlled loading rack positions to 
Feb 23, 2016 Page 22 of 48 

 demonstrate compliance with the lb/hour limit of Condition 3.A.1 

8. Emissions calculations from all uncontrolled loading rack positions on a monthly 

 and rolling 12 month period to demonstrate compliance with Condition 3.B.1 

9. Emissions calculations per uncontrolled loading rack position on an hourly, 

 monthly, and rolling 12-month period to demonstrate compliance with 

Conditions 3.B.2 and 3.B.3. 

B.		Marine Vessel Loading Operations:

1.		Marine Vessel Loading Operations:		1‐Hour RACT

Under the 1-hour RACT permit, marine vessel loading operations of VOCs is limited to commodities with a RVP of 

less than 4 psia and limited to 59 tons of VOC per year. Table VI.B-1 below lists the 1-hr RACT requirements 

associated with marine loading operations. 

Table	VI.B‐1:	Marine	Vessel	Loading	‐	1	hr	RACT	

The SIP-approved 1-hr RACT plan approval includes the following case-by-case requirements for marine vessel 

loading: 

Condition 2F The marine vessel loading shall not process petroleum distillate with vapor pressures 

greater than 4 RVP. 

Condition 3A(2)C The operation of the marine vessel loading shall be limited to 59 tons of VOC per year 

Condition 5B GATX [Kinder Morgan] shall monitor throughput of material processed and vapor 

pressures for all tanks, marine loading, and tank car/truck loading racks on a daily basis.” 

2.		Marine Vessel Loading Operations	‐	Permit Modifications

In 2012, Kinder Morgan increased cumene storage and barge loading operations. In order to maintain the facility’s 

Synthetic Minor status for Hazardous Air Pollutants at the terminal, a Marine Vapor Combustor Unit (MVCU) was 

installed to control VOC emissions from cumene barge loading. The MVCU is specifically designed to handle 

materials with a true vapor pressure below 0.4 psi, such as cumene. 

The 1-hr RACT permit limited marine loading to products less than RVP of 4.0. In 2012, AMS Plan Approval No. 

11184 was approved by AMS for installation of a MVCU to control emissions from cumene loading. The facility 

anticipated a future increase in cumene loading operations and the MVCU was installed to assure comply with the 

HAP limits of AMS Plan Approval No. 06021. Cumene has a RVP of less than 4 and is not required to be controlled 

under the 1-hour RACT permit. AMS Plan Approval No. 06021 limits cumene loading to 457,889,148 gallons per 12 

month rolling period which equates to about 1 tpy of cumene emissions from marine loading assuming a control 

efficiency of 98% for the MVCU. See Attachment D for detailed calculations and background information on the 

permit. AMS Plan Approval No. 06021 did not result in any significant changes to the 1-hr RACT permit since the 

facility is still subject to the 59 tpy limit for marine loading and the RVP of cumene is well below 4 psi. 

3. Marine Vessel Loading Operations:		PTE		

The section below was provided by the facility and discusses the potential to emit of marine loading operations based 

on physical restrictions. 

Marine Transfer Operation - Potential annual operating hours

The Kinder Morgan Philadelphia Terminal operates two (2) marine vessel berths, Berth 1 and Berth 2. Both inbound 

and outbound transfers and controlled (cumene only) and uncontrolled transfers can be conducted at each berth. In 

addition, transfers can be conducted at the berths simultaneously, excluding controlled outbound transfers using the 

Marine Vapor Control Unit (MVCU). Outbound transfers requiring vapor control may only be conducted at one 

berth at a time. 
Feb 23, 2016 Page 23 of 48 

The potential annual hours of operation, or cumulative inbound and outbound pumping interval, for the marine vessel 

transfer operation is 15,392 hours per year, including 7,507 hours per year and 7,884 hours per year for Berth 1 and 

Berth 2, respectively. 

The potential annual hours of operation for Berth 1 are based on the outbound transfer of fuel grade ethanol (FGE). 

FGE can be pumped to a vessel for up to 12 consecutive hours proceeded by and followed by a 1 hour idle period for 

staging the vessel at arrival and unstaging the vessel at departure. Therefore, during each 14 hour duration at Berth 1, 

the terminal can transfer FGE for 12 hours or for 85.7% of the time available. A calendar year has 8,760 hours, so 

transfers at Berth 1 can be conducted for 85.7% of 8,760 hours or 7,507 hours per year. If we assume that each 

outbound transfer must be replenished by an equivalent inbound transfer, the Berth 1 potential annual 

outbound pumping interval, or marine vessel loading time, is equal to 50% of 7,507 hours or 3,754 hours per 

year. 

The potential annual hours of operation for Berth 2 are based on the outbound transfer of acetone. Acetone can be 

pumped to a vessel for up to 36 consecutive hours proceeded by and followed by a 2 hour idle period for staging the 

vessel at arrival and unstaging the vessel at departure. Therefore, during each 40 hour duration at Berth 2, the 

terminal can transfer acetone for 36 hours or for 90% of the time available. A calendar year has 8,760 hours, so 

transfers at Berth 2 can be conducted for 90% of 8,760 hours or 7,884 hours per year. If we assume that each 

outbound transfer must be replenished by an equivalent inbound transfer, the Berth 2 potential annual 

outbound pumping interval, or marine vessel loading time, is equal to 50% of 7,884 hours or 3,942 hours per 

year.

In conclusion, the potential outbound pumping interval for the marine vessel operation is 7,696 hours per 

year, including 3,754 hours for Berth 1 and 3,942 hours for Berth 2. 

Marine Transfer Operation - Potential VOC loading emissions

The Kinder Morgan Philadelphia Terminal does not own any of the product transferred across their docks. The 

marine vessel loading operation services multiple customers with varying products, such as FGE, cumene, phenol, 

acetone and nonene. The customer and type of product is always subject to change as is the demand for the products 

transferred. 

Since marine loading operations at the terminal are variable with respect to product and throughputs, we offer the 

following scenarios below based on potential operating hours at each berth to reflect fluctuations in potential annual 

VOC emissions. 

While the marine loading process is physically capable of emitting more, the 1-hour RACT Plan Approval limits 

VOC emissions to 59 tpy. As a result, the VOC PTE remains 59 tpy. 
Feb 23, 2016 Page 24 of 48 

4.		Marine Vessel Loading Operations: 8‐Hour Case‐by‐Case RACT Analysis

As mentioned above, there is a Marine Vapor Combustion Unit (MVCU) installed at the facility to control cumene 

emissions from marine loading operations. In order to further justify the AMS 8-Hour RACT determination, an 

economic evaluation has also been performed to evaluate the feasibility of adding a control device for marine vessel 

loading operations. The following provides the associated analysis: 

Table	VI.B‐4:	Possible	Control	Rankings	for	Marine	Vessel	Loading:	‐	Add	Est.	Overall	Effectiveness	with	CE	to	

table	

Control Control Device 

Estimated 

Effectiveness 

Capture Efficiency 

from loading 

operations 

Overall Effectiveness with 

Capture Efficiency 

Thermal Oxidation 95-98% 85.% 80.75-83.3% 

Carbon Adsorption 85-95% 85.% 72.25-80.75% 

Bioreactor 60-99% 85.% 51-84.15% 

Scrubbers 50-98% 85.% 42.5-80.75% 

Condensation 50-98% 85.% 42.5-80.75% 

* Estimated Effectiveness is the control efficiency for pollutants reaching the control device. Estimated Overall 

Effectiveness notes that not all fugitive emissions from the loading operation will reach the control device and 

factors in an 85% capture efficiency based on a no leak check on a tanker that maintains a minimum positive 

pressure below +3 to +5 inches of water is 85%.( Section 9, Table 9-5, 2015, Pag-9-6, 9-7) 

a. Technically Feasibility Evaluation:

(1) Thermal Oxidation 

Thermal Oxidation is a process in which the hydrocarbons in a gas stream are combusted to form carbon 

dioxide and water at an elevated temperature. Thermal Oxidation is governed by temperature, time, and 

turbulence. In order to achieve effective combustion the organic must be raised 100 degree Fahrenheit 

or more above its ignition temperature and held at that for good oxidation to occur. An auxiliary fuel is 

required to ensure the temperature is maintained for proper combustion. There are essentially two (2) 

types of incinerators: thermal and catalytic. Each type is considered technically feasible for the marine 

loading operation. However, for costs analysis purposes, thermal incineration is being considered since 

the relative cost of the two are similar. 

(a) Existing MVCU to control organics with true vapor pressures of 0.4psia or greater –technically 

infeasible. 

The existing Marine Vapor Combustor (MVCU) was specifically designed for loading of cumene 

and the maximum design true vapor pressure is set at 0.4 psia. Table VI.B-6 lists VOC emissions 

from marine vessel loading from the facility for the 2012-2013 calendar years. As the table indicates 

the majority of marine loading emissions are from ethanol, with an RVP ( or true vapor pressure 

@100 F) of 2.3 psia. Due to its design, using the MVCU to control VOC emissions from loading of 

any organic liquids with true vapor of 0.4 psi or greater, including ethanol, is technically infeasible. 

Table	VI.B‐5:	Properties	of	Ethanol,	phenol,	and	cumene.	

Products/chemi

cals/ 

material 

Molecular 

Weight 

Emission 

factor 

(lbs/1000 

gallons) 

VP at 68 

F 

(psi) 

Reid Vapor Pressure 

(RVP) a

 or True Vapor 

Pressure b

 @100 F (psi) 

Fuel Grade 

Ethanol 

46.07 0.87 (@ 

60 F) 

1.53 2.3c

Phenol 94.12 0.004 0.00418 0.019 c
Feb 23, 2016 Page 25 of 48 

Cumene 120.20 0.091 0.06456 0.187c

a Reid Vapor Pressure (RVP) is a common measure of volatility of petroleum liquids defined as the absolute vapor 

pressure exerted by a liquid at 100°F. Under PA Code 121.1 is defined as the measure of pressure exerted on the 

interior of a special container as determined by the appropriate methodologies in 40 Coder of Federal Regulations 

(CFR) Part 80, Appendix E. 40 CFR Part 80 Appendix E method s determine the absolute pressure of a sample, 

measured against a vacuum of a gasoline or gasoline-oxygenate blend sample saturated with air at 32–40 °F (0–4.5 

°C). The absolute (measured) pressure is observed with a system volume ratio of 1 part sample and 4 parts 

evacuated space at 100 °F (37.8 °C). b

 True vapor pressure is defined as the equilibrium partial pressure exerted by a volatile organic liquid as a function 

of temperature. For a pure component at 100°F, the true vapor pressure is equivalent to the RVP. [Source Section 

9.4.1.1, Emission Estimation Protocol for Petroleum Refineries, RTI International April 2015] c

 Obtained by using Antoine’s equation and EPA AP42 Emission Factor, Section 7.1, Eq. 1-25 and Table 7.1-5 and a 

assuming a TLA of 100 °F (37.8 °C).

Table	VI.B‐6:	Actual	VOC	Emissions	Reported	in	2012	and	2013	for	Marine	Vessel	Loading	
Feb 23, 2016 Page 26 of 48 

(b) Existing MVCU to control organics with true vapor pressures of less than 0.4psia –Infeasible. 

The existing MVCU is capable of controlling VOC emissions from commodities with true vapor 

pressure less than 0.4 psia. As shown Table VI.B-6, in 2012 and 2013, less than 2% of VOC 

emissions from marine loading corresponded to organics with true vapor less than less than 0.4 psi. 

Loading of cumene is already being controlled by the existing MVCU. However Kinder Morgan, by 

agreement, can only use the MVCU to control cumene emissions from marine loading operations 

conducted on behalf of a single customer. As a result, the use of the MVCU to control emissions 

from marine loading operations of VOCs with true vapor pressures less than 0.4 psia generally is 

infeasible. A January 22, 2016 affidavit from Kinder Morgan discussing the agreed upon operational 

restrictions for the MVCU has been included in Attachment G. 

(c) New Thermal Oxidation Unit or MVCU to control all VOC emissions from marine loadingTechnically Feasible. 

Installing and operating a new thermal oxidation unit is technically feasible, but economically 

infeasible as discussed in the cost analysis below (See Option 1 in the following section below). 

(2) Carbon Adsorption – Technically Infeasible 

Adsorption is where gas molecules are passed through a bed or solid particles, then diffuses from the 

gas stream to the bed, and held on the media by attractive forces. Adsorptive capacity of the solid for the 

gas tends to increase with the gas phase concentration, molecular weight, diffusivity, polarity, and 

boiling point. 

Typical adsorbents media in use include activated carbon, silica gel, activated alumina, synthetic 

zeolites, fuller’s earth, and other clays. This RACT analysis is oriented toward the use of activated 

carbon, a commonly used adsorbent for VOCs. Carbon adsorption is effective when materials have a 

molecular weight of 50 or greater. 

Carbon adsorption is considered technically infeasible for the operation since it would not be effective 

on all materials handled at the dock. Ethanol is loaded into vessels in addition to other materials. The 

molecular weight of ethanol is 46, thus making carbon adsorption infeasible. 

(3) Bioreactor – Technically Infeasible 

There are several different types of bioreactors from soil beds or bio-filters to bio-trickling filters, and 

bio-scrubbers. Typically used for odor control, bioreactors can be used to oxidize VOCs. For a 

bioreactor to be effective, one needs a consistent stream and maintain temperature above 60 degrees 

Fahrenheit. The marine vessel operation at Kinder Morgan is intermittent and the climates average 

annual temperature is below 60 degrees Fahrenheit. While there are other factors to consider, this 

control option is considered technically infeasible due to the intermittent nature of the operation and the 

climate of the area. 

 
Feb 23, 2016 Page 27 of 48 

(4) Scrubbers – Technically Infeasible 

Scrubbers use a process called absorption to remove pollutants from an air stream to a liquid stream. 

The absorption processes the organics in the air stream are dissolved in a liquid solvent. The limiting 

factors as a primary control technique deal with the availability of a suitable solvent and the solubility of 

the organic. In this case, the terminal would require different solvents to handle the varying material 

handled. Based on the organics in the air stream requiring different absorption media this control option 

is considered technically infeasible. 

(5) Condensation – Technically Infeasible 

Refrigeration units are basically “heat pumps,” absorbing heat on the “cold side” of the system and 

releasing heat on the “hot side” of the system. 

A refrigerated condenser is a viable option if:

i. The air stream is saturated with the organic compound

ii. The organic vapor containment system limits air flow

iii. Required air flow does no overload a refrigeration system with heat

iv. Only one organic compound is emitted

Since the marine vessel loading operation is only considered to be 50 percent saturated and there are 

multiple organic compounds, this control option is considered infeasible. 

b. Cost Analysis of Technically Feasible Control Options:

To determine the cost effectiveness of the technically feasible options, cost analysis for the following option was 

conducted: 

 
Feb 23, 2016 Page 28 of 48 

Option 1- Install a new Thermal Oxidation Unit or MVCU to control all marine loading. 

Option 1 involves installation of new equipment. The capital cost for the thermal oxidizer is based on a vendor quote 

for another project (see Attachment F), and is presented in the tables below. 

Marine Vessel Loading – Total Capital Investment 

*See Attachment F for vendor quote. 

 

Direct Cost

Purchsed Equipment* 522,950.94 $ 

Instrumentation -

Sales Tax 31,377.06 $ 

Freight 26,147.55 $ 

Purchased Equipment Cost 580,475.55 $ 

Direct Installation Costs

Foundations & Supports 46,438.04 $ 

Handling & Erection 81,266.58 $ 

Electrical 23,219.02 $ 

Piping 11,609.51 $ 

Insulation for ductwork 5,804.76 $ 

Painting - $ 

Direct Installation Costs 168,337.91 $ 

Site Preparation 5,804.76 $ 

Total Direct Cost 754,618.22 $ 

Indirect Cost

Engineering 58,047.56 $ 

Construction and field expenses 29,023.78 $ 

Contractor fees 58,047.56 $ 

Start-up 11,609.51 $ 

Performance test 7,500.00 $ 

Total Indirect Cost 164,228.41 $ 

Total Capital Investment 918,846.63 $ 
Feb 23, 2016 Page 29 of 48 

Annual Hours of Operation (hrs) 7696

TotaL Capital Investment Cost (TCI) $918,846.63

Direct Annual Cost (DAC)

Operator Labor (0.5 hr/shift@$ 18 hr) $8,658.00

Supervisor (15% of Operator) $1,298.70

Operating Materials

Maintenance

Labor(0.5 hr/shift  $25/hr ) $12,025.00

Materials (100% of maintenance

Labor) $12,025.00

Natural Gas ($1.16 per therm) $843,792.52

Electricity (5.47 kw, 7696hrs, $0.162/kwh) $6,819.73

$884,618.95

Indirect Annual Cost (IAC)

Overhead (60% of sum of operating supervisor, main labor, & maint materials) $20,404.02

Adminstrative Charges (2%TC) $18,376.93

Property taxes (1% TCI) $9,188.47

Insurace (1% TCI) $9,188.47

Capital Recovery,CR (7% over 10 years)   $130,843.76

$188,001.65

Total Annual Operating  Cost = DAC+IAC $1,072,620.59

Table	VI.B‐6:	Marine	Loading	Operations	–	Cost	Summary	

Control

Device

Baseline

VOC

Emissions

(tpy)

VOC Reduction  

(%)

VOC

Reduction(tpy)  

Total Annualized

Cost

Cost

Effectiveness

($/ton)

Thermal

Oxidation 59 83.3 49.147 $1,072,620.59 $21,824.74

*Includes 85% capture efficiency based on Emission Estimation Protocol for Petroleum Refineries, Section 9, Table 

9-5, 2015, Pag-9-6, 9-7 
Feb 23, 2016 Page 30 of 48 

If an add-on air pollution control device or vapor balance system is used to capture and control emissions, then the 

capture and control efficiencies should be included in the emission estimate. The capture efficiency is the portion of 

the total emissions that is captured by the vapor collection system. The effectiveness of the vapor collection system, or 

capture system, is dependent on the leak tightness of the truck tank, rail car, or marine vessel; the condition of the 

connection from the tanker or vessel collection header equipment to the vapor collection system; the leak tightness of 

the terminal’s vapor collection system; and the control device. Capture efficiency for the vapor collection system can 

be applied based on the leak check conducted for the tanker truck, rail car, and marine vessel. The capture efficiency 

for a no leak check on a tanker that maintains a minimum positive pressure below +3 to +5 inches of water is 85%. 

The 95-98% destruction efficiency of the thermal oxidizer is not the same as the capture efficiency for the capture 

system or the vapor collection system. 

Based on a vendor quote for another project, the capital cost for the thermal oxidizer is estimated to be $918,846.63 

and the annual operating costs are $1,072,620.59 per year. The costs estimates are consistent with the EPA Air 

Pollution Control Costs Manual, Version 6. The annual costs include operating and maintenance labor, fuel and 

electrical costs, and a capital depreciation of 7 percent over 10 years. The costs of the technically feasible controls are 

based on vendor quotes and readily available literature. The cost of this control unit is scaled from the original 

contractor proposal using the “Sixth-Tenth Factor Rule.” The equation, referenced from Peters and Timmerhaus, 

Plant Design and Economics for Chemical Engineers, Fourth Edition, 1191 Page 169, is as follows: 

Based on the current permitted values, the technically feasible control, installation of a new Thermal Oxidation Unit 

to control VOC emissions from marine loading operation generally, is not cost effective. Accordingly, no control 

device is required. 

5.		Marine Vessel Loading Operations: Proposed New Limits

The RACT analysis for marine loading operations concluded that no control are required, assuming a baseline VOC 

emissions of 59 tpy. Nonetheless, Kinder Morgan has accepted a reduction of the marine vessel loading VOC 

emissions limit from 59 tpy VOC to 51tpy. AMS would note that substituting 51 tpy for 59 tpy would not change the 

conclusion of the cost effectiveness calculations performed in section VI.B.4.a. above. Lowering the baseline VOC 

emissions to 51 tpy would result in comparatively lower emission reductions, and increase the cost / ton VOC 

reduced by installing a new thermal oxidation unit.

a. Conclusion:

As a result of the cost analysis above, AMS determines that that the new case-by-case conditions presented in the 

following section for marine vessel loading represent VOC RACT under the 1997 8-hour ozone standard for the 

marine vessel loading operations in Kinder Morgan. – New limits, existing RVP < 4 limit are 1-hour RACT.

6. Marine Vessel Loading Operations: Proposed 8‐Hour RACT Requirements

Stack testing of the Marine Vapor Combustion Unit is necessary in order to ensure compliance the control device 

destruction efficiency. 

Note: Under 40 CFR 63 Subpart Y there are presumptive RACT requirements for marine loading operations that 

process 10 million gallons of gasoline per year or 200 million barrels of crude per year. Kinder Morgan’s Marine 

Vessel Loading has not been able to load either gasoline or crude since accepting the RVP limit in 1-hour RACT. 

Table	VI.B‐8:	Marine	Loading	Operations	–	8	hr	RACT	

AMS has determined the following case-by-case conditions for marine vessel loading as 8-hr RACT: 

Cost of Equipment A = Cost of Equipment B * (Capacity of Equipment A / Capacity of Equipment B)^0.6
Feb 23, 2016 Page 31 of 48 

Condition 2C 

[Keeping 1hr- RACT Plan Approval Language in 

the 8hr RACT Plan Approval]

Marine vessel loading operations shall not process 

petroleum distillate with a vapor pressure of 4.0 RVP or 

greater. 

Condition 3.C 

[Modifying 1hr- RACT Plan Approval Language in 

the 8hr RACT Plan Approval to a 12 month rolling 

period instead of per year]

1. Marine vessel loading operations shall not exceed51 

tons of VOC per 12 month rolling period; 

Condition 5B 

 [NEW- in the 8-hr RACT Plan Approval] 

The Permittee shall conduct stack testing per AMS 

approved protocol on the Marine Vapor Combustion Unit 

at least every five (5) years.” Testing shall be conducted 

on the Marine Vapor Combustion Unit within 5 years of 

the last test date conducted. 

AMS has added the following additional monitoring and recordkeeping requirements to the RACT plan approval: 

Condition 5A[NEW- in the 8-hr RACT Plan 

Approval]

Kinder Morgan shall monitor throughput of material 

processed and vapor pressures for all tanks, marine loading, 

and tank car/truck loading racks on a daily basis. 

Condition 6B [NEW- in the 8-hr RACT Plan 

Approval] 

For marine vessel loading operations, Kinder Morgan 

Liquid Terminals, LLC shall keep records of the following: 

1. The name of material loaded; 

2. Whether the loading is controlled or uncontrolled; 

3. Throughputs of each material loaded; 

4. True vapor pressures and verification that the material 

 loaded has a RVP of less than 4.0; 

5. Emission calculations on a monthly and rolling 12- 

 month period to demonstrate compliance with 

 Conditions 3.C.1 and 3.C.2.. 

C.		Fugitive Emissions

1. Fugitive Emissions:		1‐Hour RACT

The following sources of VOC fugitive emissions from flanges, valves, and pumps leaks are subject to case-by-case 

1-hour RACT requirements, per the SIP-approved RACT plan approval (under its former name “GATX Terminals 

Corporation”), effective on May 29, 1995, and approved by EPA on October 31, 2001 in 66 FR 54936: 

 P01 – Process Piping Flanges 

o Fuel/Material: Organic/Inorganic Compounds 

 P02 – Process Piping Valves 

o Fuel/Material: Organic/Inorganic Compounds 

 P03 – Process Piping Pumps 

o Fuel/Material: Organic/Inorganic Compounds 

Additionally, under the SIP-approved 1-hr RACT plan approval, the facility is required to monitor, detect, and repair 

leaks from all valves, pumps, and flanges processing all liquids, including non-VOC liquids. The SIP-approved 1-hr 

RACT plan approval includes the following conditions: 

o Condition 2E: 

o “The implementation of a quarterly leak detection and repair program on all pumps, valves, and 

flanges containing VOC;” 

o Condition 5A: 

o “GATX [Kinder Morgan] shall monitor all valves, pumps, and flanges quarterly for visual leaks. 

GATX shall also monitor valves, pumps, and flanges which process organic liquid greater than or 

equal to 4 RVP for leaks of greater than 10,000 ppmv.” 
Feb 23, 2016 Page 32 of 48 

2. Fugitive Emissions:		Applicable Requirements & Permit Modifications

Fugitive process emission leaks are covered by the CTG regulation, AMR V, Section XIII. As per AMR V Section 

XIII(1), no person shall cause, suffer, allow or permit volatile organic compounds (VOC) to be emitted from leaking 

flanges, gaskets, seals, connections, joints, fittings or other process equipment components not involving moving 

parts, nor shall any person cause, suffer, allow or permit VOC to be emitted from leaking valves, pumps, 

compressors, safety pressure relief devices or other process equipment components involving moving parts such that: 

1. The VOC emission from any leaking process equipment component results in a VOC 

in air concentration of 10,000 parts per million by volume (ppmv), or greater, when 

measured by test methods approved by the Department. 

AMS issued Plan Approval No. 09105 dated January 19, 2010 which changed Condition 5A to be consistent with 

AMR V Section XIII the following: “The Permittee shall monitor all valves, pumps, flanges in Volatile Organic 

(VOC) service quarterly for visual leaks or for leaks greater than 10,000 ppmv.” 

AMS Permit No 09105 dated 1/19/2010

 The permit also intended to clarify fugitive emission requirements. The permit proposed to 

modify Condition 5.A of the 1-hr RACT permit from “GATX shall monitor all valves, pumps, 

and flanges quarterly for visual leaks. GATX shall also monitor valves, pumps, and flanges 

which process organic liquid greater or equal to 4 RVP for leaks greater than 10,000 ppmv” to 

“The Permittee shall monitor all valves, pumps, and flanges in Volatile Organic (VOC) Service 

quarterly for visual leaks or for leaks greater than 10,000 ppmv.” The reasons for the requested 

change was that the RACT program was intended to reduce VOC emissions from major facilities. 

The wording of the 1-hr RACT Permit, required that the facility monitor all organics including 

organics that are not VOC. The RACT regulation applies to VOCs. The change will provide 

consistency with Air Management Regulation (AMR) Section XIII.

 

3. Fugitive Emissions:		8hr RACT Determination

Since AMR V, Section XIII has specific leak thresholds, it is more stringent than the LDAR requirement from the 1-

hr RACT, and this will supersede the LDAR requirements. Consistently, AMS requests that the LDAR requirements 

be removed from the RACT plan approval. AMS determines that compliance with AMR V, Section XIII and the 

revisions to the SIP-approved 1-hr RACT plan approval represents VOC RACT under the 1997 8-hour ozone 

standard for the fugitive emissions in Kinder Morgan Liquid Terminals, LLC. 

D.			Storage Tanks

The storage tanks are covered by Control Technique Guideline RACT regulations or under the Presumptive RACT 

requirements of 25 PA Code 129.57 or 25 Pa Code 129.56 as specified in the “CTG RACT Regulation” column of 

the following table listed below. For informational purposes, the table also includes any applicable operational 

requirements (possible materials stored in the tank) or VOC limits per various AMS construction permits issued. 

For storage tanks with capacities greater than 40,000 gallons, since each unit stores petroleum/organic products with 

a vapor pressure ≥ 1.5 psi and ≤ 11 psi, the RACT requirement is the installation of an external or an internal floating 

roof, as per the CTG rule 25 PA Code 129.56. The installation of an external or internal floating roof for storage 

tanks with capacities greater than 40,000 gallons storing petroleum/organic products with a vapor pressure ≥ 1.5 psi 

and ≤ 11 psi also satisfies the requirements of AMR V, Section II which similarly stipulates the implementation of a 

properly installed and well maintained organic material vapor control device such as a floating roof. 

For storage tanks with capacities greater than or equal to 2,000 gallons but less than or equal to 40,000 gallons, since 

each unit stores petroleum/organic products with a vapor pressure > 1.5 psi, the RACT requirement is the existence of 
Feb 23, 2016 Page 33 of 48 

pressure relief valves which are maintained in good operating condition and which are set to release at various 

pressures, as per the CTG rule 25 PA Code 129.57. 

The Description Codes are as follows:

IFR – Internal Floating Roof 

FR – Fixed Roof 

VFR DSP- Vertical Fixed Roof, Distilled Spirits 

DS IFR – Double seal, Internal Floating Roof 

HFR -Horizontal Fixed Roof 

VFR – Vertical Fixed Roof) 

IP - Installation Permit 

GP- General Permit 

PA - Plan Approval 

		Table	V1.D‐1:		Storage	Tanks	

Source 

ID Description* CTG RACT Regulation 

Materials 

Stored 

VOC 

Emission 

Limit 

From 

Permit No. 

P051 VFR DSP 25 PA Code 129.57 

P052 VFR DSP 25 PA Code 129.57 

P053 VFR DSP 25 PA Code 129.57 

P054 VFR DSP 25 PA Code 129.57 

P055 VFR DSP 25 PA Code 129.57 

P056 VFR DSP 25 PA Code 129.57 

P057 VFR DSP 25 PA Code 129.57 

P058 VFR DSP 25 PA Code 129.57 

P104 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P105 VFR 25 PA Code 129.56 

&AMR V, Section II 

P106 VFR 25 PA Code 129.56 & 

AMR V, Section II 

Slack Wax or 

equivalent with 

a vapor 

pressure of 

0.0019 psia or 

less at 70 

degrees 

Fahrenheit. 

0.04 tons 

per rolling 

12 month 

period. 

IP 12239 

dated 

10/ 24 2012. 

GP 14378 - 

dated 

12/10/2014 

Reactivation 

of Tank 

P107 DS IFR 25 PA Code 129.56 

&AMR V, Section II 

P108 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P121 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P122 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P123 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P124 DS IFR 25 PA Code 129.56 & 
Feb 23, 2016 Page 34 of 48 

AMR V, Section II 

P125 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P126 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P127 VFR 25 PA Code 129.56 

&AMR V, Section II 

P128 VFR 25 PA Code 129.56 & 

AMR V, Section II 

GP 14378 - 

dated 

12/10/2014 

Reactivation 

of Tank 

P129 VFR 25 PA Code 129.56 

&AMR V, Section II 

GP 14372 - 

dated 

11/28/2014 

Reactivation 

of Tank 

P130 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P131 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P133 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P134 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P135 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P137 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P140 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P141 VFR 25 PA Code 129.56 

&AMR V, Section II 

P142 VFR 25 PA Code 129.56 & 

AMR V, Section II 

Fural or 

equivalent with 

vapor pressure 

of 0.0225 psia 

or less at 70 

degrees 

Fahrenheit. 

0.10 tons 

per rolling 

12 month 

period. 

IP 12239 

dated 

10/ 24 2012. 

P143 IFR 25 PA Code 129.56 

&AMR V, Section II 

P144 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P145 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P146 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P147 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

of 2.0 psia or 

less at 78 

0.22 tons 

per rolling 

12 month 

period. 

PA No. 

11184 

dated 

4/13/2012 
Feb 23, 2016 Page 35 of 48 

degrees 

Fahrenheit. 

P148 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P149 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Cumene or 

equivalent with 

vapor pressure 

of 0.0606 psia 

or less at 70 

degrees 

Fahrenheit. 

0.06 tons 

per rolling 

12 month 

period. 

IP 12239 

dated 

10/ 24 2012. 

P150 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

of 2.79 psia or 

less at 70 

degrees 

Fahrenheit. 

0.62 tons 

per rolling 

12 month 

period. 

IP 12239 

dated 

10/ 24 2012 

P151 IFR 25 PA Code 129.56 

&AMR V, Section II 

P152 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P153 IFR 25 PA Code 129.56 

&AMR V, Section II 

P154 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P155 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P156 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P157 VFR 25 PA Code 129.56 & 

AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

of 2.0 psia or 

less at 78 

degrees 

Fahrenheit. 

0.22 tons 

per rolling 

12 month 

period. 

PA No. 

11184 

dated 

4/13/2012 

P158 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

of 2.0 psia or 

less at 78 

degrees 

Fahrenheit. 

0.22 tons 

per rolling 

12 month 

period. 

PA No. 

11184 

dated 

4/13/2012 

P159 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P160 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P161 IFR 25 PA Code 129.56 

&AMR V, Section II 

P162 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P163 IFR 25 PA Code 129.56 
Feb 23, 2016 Page 36 of 48 

&AMR V, Section II 

P164 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P198 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P199 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P200 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P201 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P202 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P203 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P204 IFR 25 PA Code 129.56 

&AMR V, Section II 

P205 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P206 IFR 25 PA Code 129.56 

&AMR V, Section II 

P207 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P208 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P209 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P210 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P211 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P212 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P213 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

of 2.79 psia or 

less at 70 

degrees 

Fahrenheit. 

0.47 tons 

per rolling 

12 month 

period. 

IP 12228 

dated 

10/172012. 

 

P214 VFR 25 PA Code 129.56 

&AMR V, Section II 

P215 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

of 2.79 psia or 

less at 70 

degrees 

Fahrenheit. 

0.42 tons 

per rolling 

12 month 

period. 

IP 12228 

dated 

October 17, 

2012; 14226 

dated 

8/28/2014 

P216 IFR 25 PA Code 129.56 

&AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

0.47 tons 

per rolling 

12 month 

period. 

12228 dated 

October 17, 

2012; 

14226 dated 
Feb 23, 2016 Page 37 of 48 

of 2.79 psia or 

less at 70 

degrees 

Fahrenheit. 

8/28/2014 

P217 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P218 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P219 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P220 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P221 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P222 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P223 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Cumene or 

equivalent with 

vapor pressure 

of 0.21 psia or 

less at 78 

degrees 

Fahrenheit. 

0.22 tons 

per rolling 

12 month 

period. 

PA No. 

11184 

dated 

4/13/2012 

P224 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P225 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Cumene or 

equivalent with 

vapor pressure 

of 0.21 psia or 

less at 78 

degrees 

Fahrenheit. 

0.22 tons 

per rolling 

12 month 

period. 

PA No. 

11184 

dated 

4/13/2012 

P226 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P227 IFR 25 PA Code 129.56 & 

AMR V, Section II 

P228 IFR 25 PA Code 129.56 & 

AMR V, Section II 

Fuel Grade 

Ethanol or 

equivalent with 

vapor pressure 

of 2.79 psia or 

less at 70 

degrees 

Fahrenheit. 

0.0.10 

tons per 

rolling 12 

month 

period. 

IP 12239 

dated 10/24/ 

2012. 

P301 DS IFR 25 PA Code 129.56 & 

AMR V, Section II 

P302 DS IFR 25 PA Code 129.56 & 

AMR V, Section II 

P303 DS IFR 25 PA Code 129.56 & 

AMR V, Section II 

P304 DS IFR 25 PA Code 129.56 & 

AMR V, Section II 

P305 VFR 25 PA Code 129.56 & 

AMR V, Section II 

P420 HFR 25 PA Code 129.57 
Feb 23, 2016 Page 38 of 48 

P421 HFR 25 PA Code 129.57 

P422 HFR 25 PA Code 129.57 

P440 VFR 25 PA Code 129.57 

P450 VFR 25 PA Code 129.57 

P451 VFR 25 PA Code 129.57 

P460 HFR 25 PA Code 129.57 

P470 HFR 25 PA Code 129.57 

P471 HFR 25 PA Code 129.57 

P481 HFR 25 PA Code 129.57 

P482 HFR 25 PA Code 129.57 

P483 HFR 25 PA Code 129.57 

P484 HFR 25 PA Code 129.57 

P485 HFR 25 PA Code 129.57 

P486 HFR 25 PA Code 129.57 

P487 HFR 25 PA Code 129.57 

P488 HFR 25 PA Code 129.57 

P489 HFR 25 PA Code 129.57 

P490 HFR 25 PA Code 129.57 

FT00 25 PA Code 129.57 

FT01 25 PA Code 129.57 

FT02 25 PA Code 129.57 

FT03 25 PA Code 129.57 

The following sources are covered by Presumptive RACT regulations, as is specified in the “Presumptive RACT 

Regulation” column of the table below: 

E.			Emergency Generator

For the one (1) 490 hp emergency generator, the presumptive RACT requirement is the installation, operation, and 

maintenance of the unit as per the manufacturer’s specifications. and a 500 hour per rolling 12 month period 

operation limit from AMS Installation Permit No. 09052 dated July 16, 2009. 

F.			Boilers

For the one (1) 13.4 MMBtu/Hr boiler and the one (1) 12.6 MMBtu/Hr, the presumptive RACT requirement is the 

installation, operation, and maintenance of the boiler as per the manufacturer’s specifications. These RACT 

requirements for Boiler #2, are part of the 1-hour RACT Plan Approval for the facility (under its former name 

“GATX Terminals Corporation”), effective on May 29, 1995, and approved by EPA on October 31, 2001 in 66 FR 

54936. 

D. De Minimis Sources:

VOC emissions from the Soil Vapor Extraction System and Cleaning and Degassing Operations are each is below 

2.7 tons per year VOC). AMS determines that installing any control technology on such small source is both 

technically and economically unreasonable. 

Source Description Capacity

(hp) Fuel Burned Presumptive RACT Regulation

EG01 Emergency Generator 1 490 Diesel 25 PA Code 129.93(c)(5)

Source Description Capacity

(MMBtu/Hr) Fuel Burned Presumptive RACT Regulation

CU01 Boiler #1, Hurst Boiler 12.6 No. 2, Natural Gas 25 Pa Code 129.93(c)(1)

CU01A 01 Boiler #2, York Boiler 13.4 No. 2, Natural Gas 25 Pa Code 129.93(c)(1)
Feb 23, 2016 Page 39 of 48 

1.			Soil Vapor Extraction (SVE) Remediation System		(206 Process)

This equipment consists of an air sparge and soil vapor extraction system to remediate dissolved and adsorbed 

phase hydrocarbons on the Philadelphia Regional Port Property across from Kinder Morgan. The soil vapor 

extraction system consists of a holding tank, vapor/liquid separator, soil vapor extraction regenerative blower, and 

an electric catalytic oxidizer. AMS Installation Permit No. 10017 dated March 19, 2010 limits emissions to less 

than 2.7 tons per 12 month rolling period. The actual VOC emissions from this unit in 2014 was less than 

1tpy (0.02 tpy). 

2.				Cleaning & Degassing Operations (204 Process)

AMS Installation Permit No. 03047 dated May 21, 2004 limits tank degassing and cleaning operations to 1.8 

tons of VOC per 12 months. The actual VOC emissions from this unit in 2014 was less than 1 tpy (0.287 

tpy). 

Since the actual baseline emission of both sources are well below 1 tpy, based on AMS's engineering knowledge 

and experience, installing control devices on both sources is technically and economically unreasonable. 

3.				Other Smaller Sources Listed as Insignificant

VOC emissions from each the following sources is below 1.0 tons per year VOC. Based on AMS permitting and 

engineering knowledge, AMS determines that installing any control technology on such small source i s both 

technically and economically unreasonable. 

 Painting of tanks, 

 Sump tank, 

 Catch basins, 

 Two oil water separator (Receives <200 gallons of organic materials per day, 

 Drumming, Steam cleaning of equipment, 

 Chemical dryers, pipe cleaning, 

 Flushing of tanks with incoming products, 

 Fire equipment, Mobile tanks (500 gallons each), 

 Tanks 1 (Emergency containment tank), 

 Tanks 2 and 3 (Emergency containment tank), 

 Tank no. 471 (#2 oil for the vapor incinerator), 

 Tank no. 420 (#2 oil for the boilers), 

 Two 48 HP Diesel Air Compressors

G. Control Devices

For the NAO Thermal Oxidization Unit and the Marine Vapor Combustion Unit, the presumptive RACT requirement 

due to combustion is the installation, operation, and maintenance of the unit as per the manufacturer’s specifications. 

These RACT requirements for the NAO Thermal Oxidation Unit are part of the SIP-approved 1-hour RACT Plan 

Approval for the facility (under its former name “GATX Terminals Corporation”), effective on May 29, 1995, and 

approved by EPA on October 31, 2001 in 66 FR 54936. 

VII. Conclusions and Recommendations: 

AMS has determined or recommends the following RACT requirements for 1997 8-hour ozone NAAQS. 

Source Presumptive RACT Regulation

NAO Thermal Oxidizer 25 PA Code 129.93(c )(4)

Vapor Combustor 25 PA Code 129.93(c )(4)
Feb 23, 2016 Page 40 of 48 

 The attached revised RACT Permit dated January 22, 2016 is submitted for SIP approval and includes caseby-case RACT requirements per 25 PA Code 129.91-92 for tank car-truck loading operations and marine 

loading operations. 

 Fugitive emissions will comply with the CTG RACT Requirements of AMR V, Section XIII. The 

requirement has been included in the RACT Plan Approval to prevent anti-backsliding issues. 

 Each storage tanks will comply with a CTG RACT or the presumptive RACT requirements of 25 PA Code 

129.56 or 129.57. A RACT determination for the storage tanks is not submitted for SIP approval. 

 Each boiler will comply with the presumptive RACT of 25 PA Code 129.93(c)(1). 

 The emergency generator will comply with the presumptive RACT requirements of 25 PA Code 

129.93(c)(5). A RACT determination for the emergency generator is not submitted for SIP approval. 

 The NAO Thermal Oxidation Unit and the Vapor Combustor shall comply with the presumptive RACT 

requirements of 25 PA Code SS129.93(c)(4). A RACT determination for the NAO Thermal Oxidation Unit 

and Vapor Combustor is not submitted for SIP Approval. 

 2/23/2016 

_________________________________________________________________________________ 

Edward Wiener, Chief of Source Registration Date
Feb 23, 2016 Page 41 of 48 

Attachment A - AMS Permit 08211/14350 Background Memo 

DATE: 11/26/2014

TO: FILE

FROM: Maryjoy Ulatowski; Environmental EngineerSUBJECT: Installation Permit 08211/14350

Owner: Kinder Morgan Liquid TerminalsAddress: 3300 N. Delaware Ave., Philadelphia, PA 19134RE: Loading Tank Modification

Kinder Morgan submitted an Installation Permit to increase the facility's tank truck loading throughput from 150,000,000 to 200,000,000 gallons per rolling 12 month.The original 150,000,000 throughput limit was from Plan Approval 08211 dated December

The potential VOC emission increase from the modification is about 1 ton per year.

CMI Calculations from Permit Application No. 14350Loading losses from ethanol will be before fuel throughput increase: (Using S= 0.6, submerged loading: normal service) 

*Loading Losses (mg/l or lb/1000 gal) = 12.46 x (SPM/T) *(1-eff/100), where S=saturation factor 0.6 0.6*EPA's AP-42, equation pg 5.2-7 P=true vapor pressure 2.1

M = molecular weight of vapors 46.07T = temperature 80 F Capture Efficiency 0.99Control Device Efficiency 0.98Overall reduction Efficiency 0.9702

Loading losses = 0.039914372 lbs ethanol /1000 gallon of ethanol loading loaded

Ethanol emissions from loading = (throughput * ethanol emission factor) 

throughput limit 150,000,000.00 gal/year 

Ethanol emissions from loading = 5987.16 lbs/year 
Feb 23, 2016 Page 42 of 48 

2.99 tons/year 

Loading losses from ethanol will be after ethanol throughput increase: (Using S= 0.6, submerged loading: dedicated vapor balance) *Loading Losses (mg/l or lb/1000 gal) = 12.46 x (SPM/T) *(1-eff/100), where S=saturation factor 0.6 0.6*EPA's AP-42, equation pg 5.2-7 P=true vapor pressure 2.1

M = molecular weight of vapors 46.07T = temperature 80 F Capture Efficiency 0.99Control Device Efficiency 0.98Eff= Overall Reduction Efficiency 0.9702

Loading losses = 0.039914372 lbs ethanol /1000 gallon of ethanol loading loaded

Ethanol emissions from loading = (throughput * ethanol emission factor) 

throughput limit 200,000,000.00 gal/year 

Ethanol emissions from loading = 7982.87 lbs/year 

3.99 tons/year 

Increase in VOC emissions from modification: 1.00 tons/year 
Feb 23, 2016 Page 43 of 48 

Attachment B - AMS Permit 09105 Background Memo 

 Kinder Morgan Liquid Terminals has submitted a Plan Approval Application to modify Conditions 2.C, 2.D, 3.A.(1), and 5.A of the f

Approval for VOC. The original Plan Approval was issued to GATX Terminal Corporation. Modification of the conditions will clarify 

with the facility’s operating scenarios, Philadelphia Air Management Services regulations, and construction permits previously issuedemission limits from the original RACT Plan Approval. The modifications are listed below:

Condition No. 

1-hr RACT Requirement: 2010 RACT Modification Permit 

Modify RACT Requirement to: 

2.C Tank Car/Truck Loading Racks A,B,E,F,M & V shall comply 

with 25 PA Code 129.59. 

Volatile Organic Compounds (VOC) that requivapor incinerator per applicable regulations or pconditions will be loaded at controlled tank car located at racks A,E,F,M, or D. 

2.D Tank Car/truck loading racks – C,D,G,H,N,O,P,R,R-1, T, & X 

which are uncontrolled shall be limited to processing organic liquid with vapor pressures lower than 4 RVP. 

All volatile organic liquids loaded at uncontrollpositions at the facility must have a Reid Vapor (RVP) less than 4.0. 

3.A.(1) Tank Car/Truck loading Rack C,D,G,H,N,O,P,R,R-1, T,X which 

are uncontrolled shall be limited to 129 tons of VOC per year 

All uncontrolled tank car/truck loading positionshall be limited to 129 tons of VOC per year. 

5.A GATX shall monitor all valves, pumps, and flanges quarterly for 

visual leaks. GATX shall also monitor valves, pumps, and 

flanges which process organic liquid greater or equal to 4 RVP for leaks greater than 10,000 ppmv 

The Permittee shall monitor all valves, pumps, Volatile Organic (VOC) Service quarterly for vfor leaks greater than 10,000 ppmv. 

 Modify Condition 2.C from “Tank Car/Truck Loading Racks A,B,E,F,M & V shall comply with 25 PA Code 129.59.” to “Volatile O

that require control by vapor incinerator per applicable regulations or permit conditions will be loaded at controlled tank car positionD.” Reasons for the requested change

The change creates consistency with operations at Kinder Morgan. The Draft Renewal Title V Operating Permit, which is currently u

list of uncontrolled and controlled loading rack positions at the facility. 

 Modify Condition 2.D from “Tank Car/truck loading racks – C,D,G,H,N,O,P,R,R-1, T, & X which are uncontrolled shall be limited 

with vapor pressures lower than 4 RVP” to “All volatile organic liquids loaded at uncontrolled rack positions at the facility must hav(RVP) less than 4.0.” Reasons for the requested change

The change creates consistency with operations at Kinder Morgan. The Draft Renewal Title V Operating Permit, which is currently u

list of uncontrolled and controlled loading rack positions at the facility. 
Feb 23, 2016 Page 44 of 48 

 Modify Condition 3.A.(1) from “Tank Car/Truck loading Rack C,D,G,H,N,O,P,R,R-1, T,X which are uncontrolled shall be limited to 

to “All uncontrolled tank car/truck loading positions at the facility shall be limited to 129 tons of VOC per year”. Reasons for the requested change

The change creates consistency with construction permits issued and with operations at Kinder Morgan. The Draft Renewal Title V O

currently under review, will provide a list of uncontrolled and controlled loading rack positions at the facility. 

 Modify Condition 5.A from “GATX shall monitor all valves, pumps, and flanges quarterly for visual leaks. GATX shall also monito

which process organic liquid greater or equal to 4 RVP for leaks greater than 10,000 ppmv” to “The Permittee shall monitor all valveVolatile Organic (VOC) Service quarterly for visual leaks or for leaks greater than 10,000 ppmv.” Reasons for the requested change

The RACT program was intended to reduce VOC and NOx emissions from major facilities. The current wording of Condition 5.A re

monitor all organics including organics that are not VOC. The RACT regulation applies to VOCs. The change will clarify that moni

VOCs. The change will also provide consistency with Air Management Regulation (AMR) Section XIII. 
Feb 23, 2016 Page 45 of 48 

Attachment C - Marine Loading PTE (at maximum hourly throughput capacity)
Feb 23, 2016 Page 46 of 48 

Attachment D - AMS Permit No. 11184 Background Memo 

KMLT has submitted a Plan Approval Application to increase cumene loading, unloading, and storage volumes. The 

majority of cumene will be loaded out to marine vessels. Since the future volume of cumene is significantly greater 

and the facility has a Synthetic Minor HAP emissions limit, Kinder Morgan is proposing to control all cumene 

emissions over the dock with a Marine Vapor Combustion Unit. There will be two cumene vapor controlled loading 

positions, but the system will be designed such that one can be operated at a time. In addition, cumene will be stored 

in internal floating roof tanks. 

In order for Kinder Morgan to handle cumene, Kinder Morgan will need to replace the internal floating roofs on Tank 

223 and Tank 225. In addition Kinder Morgan will install internal floating roof into the fixed roof Tanks Nos. 147, 

157 and 158 to be able to store ethanol and other materials of the same vapor pressure or lower. 

Emission Calculations (From Attachment 2 of the Plan Approval Application) 

Below are the potential emissions from each source or piece of equipment. 

Source Pollutant Emissions (tpy) 

VOC/HAP NOx CO PM SO2 

Cumene Loading 

Positions 

1.05 

Tank 147 0.22 

Tank 155 0.22 

Tank 158 0.22 

Tank 223 0.05 

Tank 225 0.05 

Oxidizer 0.2 6.2 9.4 0.2 -- 

Additional 

Fugitives 

0.09 

The loading loses from the cumene loading position were calculated using EPA’s AP-42 Section 5.2. 

 LL = 12.46 SPM / T 

 

 LL =loading loss, pounds per 1000 gallons (lb/1000 gal) of liquid load loaded 

 S = saturation factor, 0.5 for submerged loading of marine barges. 

 P =true vapor pressure of liquid loaded, psia (Cumene =0.1644 psia) 

 M = Molecular Weight, lb/lb-mol (Cumene 120.2) 

 T = Temperature of Liquid Loaded, degrees R(F+460) 

 (Assuming average annual temp 70F) 

 LL  12.46(0.5)(0.1644)(120.2)/(530) = 0.0046 (lb/1000 gallons) 

 Annual Emissions = LL X Annual throughput in gallons 

 = (0.0046 lb/1000 gallons) x (457,889,148 gallons) 

 = 1.05 tons per year 

Storage Tanks emissions were estimated using EPA’s Tanks 4.0 Program. 

 
Feb 23, 2016 Page 47 of 48 

Attachment E - Example Chemicals 

The following are examples of some chemicals, products, or liquids that have been stored at the facility during the 

2014 calendar year. 

Products/chemicals/ 

material 

Molecular 

Weight 

Vapor 

Pressure 

(VP) 

Actual (psi) 

VP Max 

(psi) 

VP at 68 

F 

(psi) 

Reid Vapor Pressure 

(RVP) a

 or True 

Vapor Pressure b

@100 F (psi) 

Formic Acid 46 0.28546 1.05541 0.65173 < 4 

Acetic Anhydride 102.09 0.02279 0.014146 0.07297 < 4 

Aviation Gasoline 72.25 1.82318 5.4981 3.76235 > 4 d

Fuel Grade Ethanol 46.07 0.67 2.48443 1.53 2.3c

Slack Wax 420.00 0.00148 0.00042 0.0002 < 4 

Farnesene 204.36 0.00717 0.02848 0.01707 < 4 

Phenol 94.12 0.07478 0.0101 0.00418 0.019 c

Area 6 CO Product 150.50 0.06069 0.02783 0.01447 < 4 

Plasticizer 390.57 2.99 E-05 0.0101 0.01707 < 4 

Furfural 96.09 0.00407 0.04426 0.02014 0.076c

Xylene 106.17 0.03763 0.21434 0.1193 < 4 

Toluene 92.13 0.15206 0.71005 0.4217 1.026c

Cumene 120.20 0.0188 0.12054 0.06456 0.187c

Alpha-Methylstyrene 118.20 0.01888 0.12054 0.06456 < 4 

Nonene 120.00 0.06156 0.26933 0.15575 < 4 

Valeric Acid 102.13 0.00403 0.00645 0.00294 < 4 

Cyclohexanone 98.20 0.02412 0.12226 0.07007 < 4 

Motor Oil 190.00 2.00E-5 0.00011 5.60E-5 < 4 

a Reid Vapor Pressure (RVP) is a common measure of volatility of petroleum liquids defined as the absolute vapor 

pressure exerted by a liquid at 100°F. Under PA Code 121.1 is defined as the measure of pressure exerted on the 

interior of a special container as determined by the appropriate methodologies in 40 Coder of Federal Regulations 

(CFR) Part 80, Appendix E. 40 CFR Part 80 Appendix E method s determine the absolute pressure of a sample, 

measured against a vacuum of a gasoline or gasoline-oxygenate blend sample saturated with air at 32–40 °F (0–4.5 

°C). The absolute (measured) pressure is observed with a system volume ratio of 1 part sample and 4 parts 

evacuated space at 100 °F (37.8 °C). b

 True vapor pressure is defined as the equilibrium partial pressure exerted by a volatile organic liquid as a function 

of temperature. For a pure component at 100°F, the true vapor pressure is equivalent to the RVP. [Source Section 

9.4.1.1, Emission Estimation Protocol for Petroleum Refineries, RTI International April 2015] c

 Obtained by using Antoine’s equation and EPA AP42 Emission Factor, Section 7.1, Eq. 1-25 and Table 7.1-5 and a 

assuming a TLA of 100 °F (37.8 °C).
Feb 23, 2016 Page 48 of 48 

. 

d

 The RVP of Aviation Gasoline is assumed to be > 4 psi since gasoline is defined as a material with a RVP of 4 psi 

or greater. 

Attachment F - Vendor Quote 

 (The vendor quote is attached in the following pages) 

 

Attachment G – Marine Vapor Control Unit Affidavit 

 (The affidavit is attached in the following pages)