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. Intr oductio n: ........................................................................................................... .................................................. 3

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

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

IV. 1997 1-hour VO C RACT Sources: ............................................................................................. .............................. 3

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

VI. VOC RACT Evaluatio n: ...................................................................................................... ..................................... 5

A. Tank Car/Truck Loading Oper ations ........................................................................................ ........................... 5

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

2. Tank Car/Truck Loading Oper ations- Permit Modifications ................................................................... .......... 6

3. Tank Car /Truck Loading Oper ations- Applicable Requirements ............................................................... .... 11

4. Tank Car/Truck Loading Opera tions - 8 Hour RA CT Evaluation ................................................................. ... 11

a. Controlled Load ing Pos itions ............................................................................................... ................... 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 Oper ations - Permit Modifications ................................................................... ......... 22

3. Marine Vessel Load ing Operati ons: PTE ..................................................................................... ................... 22

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

a. Technically Feas ibility Eval uation: ........................................................................................ ................. 24

b. Cost Analysis of Technical ly Feasible Co ntrol Op tions : ..................................................................... .... 27

5. Marine Vessel Loading Oper ations: Proposed New Limits ..................................................................... ........ 30

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

6. Marine Vessel Loading Operations: Pr oposed 8-Hour RACT Requirements .................................................. 30Feb 23, 2016 Page 2 of 48 C. Fugitive Emissions ........................................................................................................ ...................................... 31

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

2. Fugitive Emissions: Applicable Re quirements & Permit Modifications ........................................................ . 32

3. Fugitive Emissions: 8h r RACT Dete rmination ................................................................................ ................ 32

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

E. Emergenc y Genera tor ...................................................................................................... ................................... 38

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

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

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

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

3. Other Smaller Source s Listed as In signifi cant ........................................................................... .................... 39

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

VII. Conclusions an d Recommendations: ......................................................................................... ........................... 39

Attachment A - AMS Permit 0 8211/14350 Back ground Me mo ......................................................................... ......... 41

Attachment B - AMS Permit 09105 Backgrou nd Memo ............................................................................... ............... 43

Attachment C - Marine Loading PTE (a t maximum hourly thro ughput cap acity) ..................................................... .. 45

Attachment D - AMS Permit No . 11184 Backgr ound Memo ........................................................................... ............ 46

Attachment E - Ex ample Chemicals .............................................................................................. ............................... 47

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

Attachment G – Marine Vapor Control Unit Affidavit ............................................................................ ..................... 48Feb 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 op erates as a bulk liquid term inal, 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 Term inals 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 produc ts 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 thre shold 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 in cluded 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 Loadin g Operations) Tank car/truck loading racks connected to the NO A

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 Loadin g 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 sourcesFeb 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/cons tructed 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 so urces” on Title V Operating Permit V95-044); Steam cleaning of equipment (listed as “insignifican t sources” on Title V Operating Permit V95-044); Chemical dryers (listed as “insignificant so urces” on Title V Operating Permit V95-044); Pipe cleaning (listed as “insignificant source s” 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 sour ces” 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 “ins ignificant 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 “insigni ficant sources” on Title V Operating Permit V95-044);

***Indicate sources that were installed/cons tructed 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 positio n 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 co ntrol 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. Ther efore, 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‐b y‐Case	Requireme nts	for	Tank	Ca r/Truck	Loading

Condition 2B The operation of the following equipmen t in accordance with th e 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 (def ined 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 ga ses 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 re sult, 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 conn ected 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 controlle d 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 AM S 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 se t up for loading. With the exception of Rail Siding 1, Spot 1, these rail loading positions ar e 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 pos ition 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 th e 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 aFeb 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 th e 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 a pplicable 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 requir ements 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 positio ns 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 SI P 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 a llowed 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 poten tial 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 48After 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	RacksRack IDPrevious RackCategory(1-Hr RACT Permit)Summary of ModificationsControlled vs. UncontrolledA ControlledNone Remains with controlled and uncontrolled positions.( 2 controlled loading positions and 2 uncontrolled loading posiitions)E ControlledNone Remains with controlled and uncontrolled positions.( 1 controlled loading position and 6 uncontrolled loading positions)F ControlledIncreased pump capacity from 450 gpm to1200 gpm for controlled loading. Additionalcontrol position added. The pump capacityfor uncontrolled loading is at 450 gpm.Remains with controlled and uncontrolled positions.( 2 controlled loading positions and 2 uncontrolled loading positions)M ControlledAdditional controlled loading position added.No increase in rack pump capacity.Remains with controlled and uncontrolled positions.( 2 controlled loading positions and 4 uncontrolled loading positions)D UncontrolledUncontrolled positions connected to control. Currently has controlled and uncontrolled positions.( 2 controlled loading positions and 3 uncontrolled loading positions)B ControlledControlled positions no longer connected tocontrol.Currently with uncontrolled positions.(2 uncontrolled loading positions)V ControlledControlled positions no longer connected tocontrol.Currently with uncontrolled positions.(1uncontrolled loading position)C UncontrolledNone All positions remain uncontrolled.(2 uncontrolled loading positions)G UncontrolledNone All positions remain uncontrolled.(4 uncontrolled loading positions)H UncontrolledNone All positions remain uncontrolled.(2 uncontrolled loading positions)N UncontrolledNone All positions remain uncontrolled.(2 uncontrolled loading positions)O UncontrolledNone All positions remain uncontrolled.(4 uncontrolled loading positions)P UncontrolledNone All positions remain uncontrolled.(2 uncontrolled loading positions)R UncontrolledNone All positions remain uncontrolled.(4 uncontrolled loading positions)R-1 UncontrolledNone All positions remain uncontrolled.(2 uncontrolled loading positions)T UncontrolledNone All positions remain uncontrolled.(4 uncontrolled loading positions)Feb 23, 2016 Page 10 of 48X UncontrolledAdded controlled positions, but then removedfrom rack.All positions remain uncontrolled.(2 uncontrolled loading positions)DSP N/ANew All positions are uncontrolled.( 1 controlled loading position)Rail Siding 1 N/ANew All positions are uncontrolled, expect for Rail Siding 1, Spot 1 which iscontrolled under Rack D. ( 5 uncontrolled loading positions and 1controlled loading position)Rail Siding 2 N/ANew All positions are uncontrolled.( 12 uncontrolled loading positions)Rail Siding 3 N/ANew All positions are uncontrolled.(7 uncontrolled loading positions)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 equa l 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 th an 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 wh ich 20,000 gallons or more of such organic material are loaded in any one day from this facility unless this fac ility 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 load ing. 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 pr ocessing 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 re gulations. 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 ap plicable to case-by-case RACT . As specified in the caseby-case SIP-approved 1-hour RA CT plan approval conditions, the uncontro lled 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 iden tified 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 positio n, connecting and disconnecting the loading arm, etc.

Table	VI.A‐4:	Potential	VOC	Emis sions	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 9.018 2 - Truck

E Rack 1 - Truck 450 0.0668 18.036 1000 9.018

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

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 ca nnot 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 contro lled 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, whic h 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 etha nol 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 calcu late the loading loss emission factor (L L ).

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

**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, uncont rolled 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) L L ; Emission

Factor (lb/1,000 gal)

1.21 46 0 0.5 60 0.67Feb 23, 2016 Page 13 of 48Uncontrolled Loading PositionsTable	VI.A‐6:	Potential	VOC	Emissions	from	Uncontrolled	Tank	Car/Truck	Loading	OperationsRackNameNo. ofUncontrolledLoadingPositionsPumpingRate(gpm)LL;Emission Factor(lb/1,000 gal)Emissions(lb/hr)OperatingHours(Hours/year)Emissions (tons)SimultaneousLoading?** **Number ofPositions LoadedSimultaneouslyTotal UncontrolledLoading Emissions(tons/year)TotalUncontrolledLoadingEmissionsLimitation(tons/year)A Rack* 2450 0.67 18.0 1,000 9.0No 1 9.05129450 0.67 18.0 1,000 9.0E Rack* 6450 0.67 18.0 1,000 9.0Yes 2 18.10450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0F Rack* 1 450 0.67 18.0 1,000 9.0 No 1 9.05MRack*4450 0.67 18.0 1,000 9.0No 1 9.05450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0D Rack* 3450 0.67 18.0 1,000 9.0No 1 9.05450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0B Rack 2450 0.67 18.0 1,000 9.0No 1 9.05450 0.67 18.0 1,000 9.0V Rack 1 450 0.67 18.0 1,000 9.0 No 1 9.05C Rack2450 0.67 18.0 1,000 9.0Yes 2 18.10450 0.67 18.0 1,000 9.0G Rack 4450 0.67 18.0 1,000 9.0Yes 2 18.10450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0H Rack2450 0.67 18.0 1,000 9.0Yes 2 18.10450 0.67 18.0 1,000 9.0N Rack 2 450 0.67 18.0 1,000 9.0 No 1 9.05Feb 23, 2016 Page 14 of 48450 0.67 18.0 1,000 9.0O Rack 4450 0.67 18.0 1,000 9.0No 1 9.05450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0P Rack 2450 0.67 18.0 1,000 9.0No 1 9.05450 0.67 18.0 1,000 9.0R Rack 4450 0.67 18.0 1,000 9.0Yes 2 18.10450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0R-1Rack2450 0.67 18.0 1,000 9.0No 1 9.05450 0.67 18.0 1,000 9.0X Rack 2450 0.67 18.0 1,000 9.0No 1 9.05450 0.67 18.0 1,000 9.0DSPRack1 450 0.67 18.0 1,000 9.0 No 1 9.05T-Rack 4 450 0.67 18 1000 9.0 No 19.05RailSiding 15450 0.67 18.0 1,000 9.0Yes 5 45.25450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0RailSiding 212450 0.67 18.0 1,000 9.0Yes 12 108.60450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0RailSiding 37450 0.67 18.0 1,000 9.0Yes 7 63.35450 0.67 18.0 1,000 9.0Feb 23, 2016 Page 15 of 48450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0450 0.67 18.0 1,000 9.0TOTAL424.63129* 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. Emissions based on AP-42,Section 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 eachside of the rack. On the other hand mostloading 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 obstruction such as a wall or piping;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 simultaneously load a rail car at eachloading 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	R ankings	for	Uncontrolled	Loadin g	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 cu rrently 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 inst allation 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 cont rol 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 temperat ure. 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 pr ocess in which the hydro carbons 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 operatio n. 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 medi a by attractive forces. Ad sorptive 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 ge l, 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, bi oreactors can be used to oxidize VOCs. For a bioreactor to be effective, one needs a consistent stream and maintain temp erature above 60 degrees Fahrenheit. The marine vessel operation at Kinder Morgan is intermittent and the climates average annual temperature is below 60 de grees 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 ab sorption to remove pollutants from an air stream to a liquid stream. The absorption processes th e organics in the air stream ar e 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 “h eat pumps,” absorbing heat on th e “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 feasib ility 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 NA O 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 ope ration 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 quoteFeb 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 co st 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 unc ontrolled 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 un it at each uncontrolled loadin g 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 techni cally 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	Lo ading	Positions	–Cost	Feasibil ity

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 base d 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 accep ting the following limits: VOC emissions shall be lim ited to 9.0 tons of VOC per year and 18.1 pounds per hour per uncontro lled 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 regula tion 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:	Controlle d	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 w ith 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 atmo sphere 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)^0.6Feb 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 toFeb 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 opera tions 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 th e 1-hr RACT requirements associated with marine loading operations.

Table	VI.B‐1:	Marine	Vess el	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 Ai r Pollutants at the terminal, a Mari ne 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 RV P 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. S ee 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 - Po tential 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 (c umene only) and uncontrolled transfers ca n be conducted at each berth. In addition, transfers can be conducted at the berths simu ltaneously, 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 h ours 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 equiva lent 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 ba sed 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. Th erefore, during each 40 hou r duration at Berth 2, the

terminal can transfer acetone for 36 hou rs 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 equiva lent 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 customer s with varying products, such as FGE, cumene, phenol, acetone and nonene. The customer and type of product is alwa ys 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 pr ovides the associ ated analysis:

Table	VI.B‐4:	Possible	Control	R ankings	for	Marine	Vessel	Loadi ng:	‐	Add	Est.	Overall	Ef fectiveness	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 le ak 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. Therma l 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 fo r 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 co sts analysis purposes, thermal inci neration 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 v apor 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 2.3 c

Phenol 94.12 0.004 0.00418 0.019 cFeb 23, 2016 Page 25 of 48 Cumene 120.20 0.091 0.06456 0.187 c

a Reid Vapor Pressure (RVP) is a common measure of vola tility 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 partia l 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 T LA of 100 °F (37.8 °C)

.

Table	VI.B‐6:	Actual	VOC	Emi ssions	Reported	in	2012	and	2013	fo r	Marine	Vessel	LoadingFeb 23, 2016 Page 26 of 48 (b) Existing MVCU to control organics with true vapor pressures of less th an 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 re sult, 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 attr active forces. Adsorptive cap acity of the solid for the gas tends to increase with the gas phase concentra tion, molecular weight, diffusivity, polarity, and boiling point. Typical adsorbents media in use include activated carbon, silica ge l, activated alumina, synthetic zeolites, fuller’s earth, and other clays. This RACT an alysis 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 t echnically infeasible for the opera tion 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 so il 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 temp erature above 60 degrees Fahrenheit. The marine vessel operation at Kinder Morgan is intermittent and the climates average annual temperature is below 60 de grees 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 str eam 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 re quiring different absorption media this control option is considered technically infeasible.

(5) Condensation – Technically Infeasible Refrigeration units are basically “h eat pumps,” absorbing heat on th e “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 co nsidered 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 Un it 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 Estima tion Protocol for Petroleum Refineries, Section 9, Table 9-5, 2015, Pag-9-6, 9-7Feb 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 estimat e. The capture efficiency is the portion of the total emissions that is captured by the vapor collection system. The effectiveness of th e 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 equi pment 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 ma intains a minimum positive pressure belo w +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 co st 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 performe d in section VI.B.4.a. above. Lowering the baseline VOC emissions to 51 tpy would result in comparatively lowe r 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 ther e 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	Loadi ng	Operations	–	8	hr	RACT AMS has determined the following case-by-case cond itions for marine vessel loading as 8-hr RACT:

Cost of Equipment A = Cost of Equipment B * (Capacity of Equipment A / Capacity of Equipment B)^0.6Feb 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 fla nges, valves, and pumps leaks are subject to case-by-case 1-hour RACT requirements, per the SIP-approved RACT pl an 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, pu mps, 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 cove red 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 com pounds (VOC) to be emitted from leaking flanges, gaskets, seals, connections, joints, fittings or other process equipment com ponents 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 proce ss 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 th an 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 fo r 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 regula tion 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 determin es 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 purpo ses, 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 capac ities greater than 40,000 gallons, since each un it 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 stor ing petroleum/organic products with a vapor pressure ≥ 1.5 psi

and ≤ 11 psi also satisfies the requiremen ts 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 ofFeb 23, 2016 Page 33 of 48 pressure relief valves which are maintained in good ope rating 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

4/13/2012Feb 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 129.56Feb 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 datedFeb 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 129.57Feb 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 presumptiv e 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 economi cally 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 sour ces 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 economi cally 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 Va por 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 Un it are part of the SIP-approved 1-hour RACT Plan Approval for the facility (under its former name “GATX Te rminals 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 presump tive RACT of 25 PA Code 129.93(c)(1).

 The emergency generator will comply with the pr esumptive RACT requirements of 25 PA Code 129.93(c)(5). A RACT determinati on 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 RA CT 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 DateFeb 23, 2016 Page 41 of 48Attachment A - AMS Permit08211/14350 Background MemoDATE:11/26/2014TO: FILEFROM: Maryjoy Ulatowski; Environmental EngineerSUBJECT:Installation Permit 08211/14350Owner:Kinder Morgan Liquid TerminalsAddress:3300 N. Delaware Ave., Philadelphia, PA 19134RE:Loading Tank ModificationKinder Morgan submitted an Installation Permit to increase the facility's tank truck loading throughput from150,000,000 to 200,000,000 gallons per rolling 12 month.The original 150,000,000 throughput limit was from PlanApproval 08211 dated DecemberThe potential VOC emission increase from the modification is about 1 ton per year.CMI Calculations from Permit Application No. 14350Loading losses from ethanol will bebeforefuel 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 2.1M = molecular weight of vapors 46.07T = temperature 80 F 540Capture Efficiency 0.99Control Device Efficiency 0.98Overall reduction Efficiency 0.9702Loading losses = 0.039914372 lbs ethanol /1000 gallon of ethanol loading loadedEthanol emissions from loading = (throughput * ethanol emission factor)throughput limit 150,000,000.00 gal/yearEthanol emissions from loading = 5987.16 lbs/yearFeb 23, 2016 Page 42 of 482.99tons/yearLoading losses from ethanol will beafterethanol 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 2.1M = molecular weight of vapors 46.07T = temperature 80 F 540Capture Efficiency 0.99Control Device Efficiency 0.98Eff= Overall Reduction Efficiency 0.9702Loading losses = 0.039914372 lbs ethanol /1000 gallon of ethanol loading loadedEthanol emissions from loading = (throughput * ethanol emission factor)throughput limit 200,000,000.00 gal/yearEthanol emissions from loading = 7982.87 lbs/year3.99tons/yearIncrease in VOCemissions frommodification:1.00tons/yearFeb 23, 2016 Page 43 of 48Attachment 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 thefacility’s RACT PlanApproval for VOC. The original Plan Approval was issued to GATXTerminal Corporation. Modification of the conditions will clarify and provide consistencywith the facility’s operating scenarios, Philadelphia Air Management Servicesregulations, and construction permits previouslyissued. There are no changes to anyemission limits from the original RACT PlanApproval. The modifications are listed below:ConditionNo.1-hr RACT Requirement: 2010 RACT Modification PermitModify RACT Requirement to:2.C Tank Car/Truck Loading Racks A,B,E,F,M & V shall complywith 25 PA Code 129.59.Volatile Organic Compounds (VOC) that require control byvapor incinerator per applicable regulations or permitconditions will be loaded at controlled tank car positionslocated 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, & Xwhich are uncontrolled shall be limited to processing organicliquid with vapor pressures lower than 4 RVP.All volatile organic liquids loaded at uncontrolled rackpositions at the facility must have a Reid Vapor Pressure(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 whichare uncontrolled shall be limited to 129 tons of VOC per yearAll uncontrolled tank car/truck loading positions at the facilityshall be limited to 129 tons of VOC per year.5.A GATX shall monitor all valves, pumps, and flanges quarterly forvisual leaks. GATX shall alsomonitor valves, pumps, andflanges which process organic liquid greater or equal to 4 RVP forleaks greater than 10,000 ppmvThe Permittee shall monitor all valves, pumps, and flanges inVolatile Organic (VOC) Service quarterly for visual leaks orfor leaks greater than 10,000 ppmv.Modify Condition 2.C from “Tank Car/Truck Loading Racks A,B,E,F,M & V shall comply with25 PA Code 129.59.” to “Volatile Organic Compounds (VOC)that require control by vapor incinerator per applicable regulations or permit conditions will be loaded at controlled tank carpositions located at racks A,E,F,M, orD.”Reasons for the requested changeThe change creates consistency with operations at Kinder Morgan. The Draft Renewal Title V Operating Permit, which is currentlyunder review, will provide alist 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 limitedto processing organic liquidwith vapor pressures lower than 4 RVP” to “All volatile organicliquids loaded at uncontrolled rack positions at the facility must have a Reid Vapor Pressure(RVP) less than 4.0.”Reasons for the requested changeThe change creates consistency with operations at Kinder Morgan. The Draft Renewal Title V Operating Permit, which is currentlyunder review, will provide alist 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 to129 tons of VOC per year”to “All uncontrolled tank car/truck loading positions at thefacility shall be limited to 129 tons of VOC per year”.Reasons for the requested changeThe change creates consistency with construction permits issued and with operations at Kinder Morgan. The Draft Renewal Title VOperating Permit, which iscurrently under review, will provide a list of uncontrolledand 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 monitor valves, pumps, and flangeswhich process organic liquid greater or equal to 4 RVP for leaks greater than 10,000 ppmv” to “The Permittee shall monitor allvalves, pumps, and flanges inVolatile Organic (VOC) Service quarterly for visualleaks or for leaks greater than 10,000 ppmv.”Reasons for the requested changeThe RACT program was intended to reduce VOC and NOx emissionsfrom major facilities. The current wording of Condition 5.A requires that the facilitymonitor all organics including organics that are not VOC. The RACT regulation applies to VOCs. The change will clarify that monitoring will only apply toVOCs. The change will also provide consistency with Air Management Regulation (AMR) Section XIII.Feb 23, 2016 Page 45 of 48Attachment 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 inte rnal 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.

L L = 12.46 SPM / T

L L =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 pressu re of liquid loaded, psia (Cumene =0.1644 psia)

M = Molecu lar Weight, lb/lb-mol (Cumene 120.2) T = Temperature of Liquid Loaded, degrees R(F+460) (Assuming average annual temp 70F)

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

Annual Emissions = L L 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 2.3 c

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 0.076 c Xylene 106.17 0.03763 0.21434 0.1193 < 4

Toluene 92.13 0.15206 0.71005 0.4217 1.026 c

Cumene 120.20 0.0188 0.12054 0.06456 0.187 c

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 vola tility 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 partia l 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 T LA 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 Vapo r Control Unit Affidavit

(The affidavit is attached in the following pages)