response to comments kinder morgan operating lp -c ... · response to comments kinder morgan...

Response to CommentsKinder Morgan Operating LP - "C" - Blytheville Terminal

Permit #: 0232-AR-llAFIN: 47-00012

On, May 11, 2008 the Director of the Arkansas Department of Environmental Qualitygave notice of a draft permitting decision for the above referenced facility. During thecomment period, one interested party submitted written comments, data, views, orarguments on the draft permitting decision. The Department's response to these issues isas follows:

Comment #1: Facility has requested to increase the monolithic blockpour height to amaximum of40 ft from the 20ft height limitation in the draft permit. Thismodeling data substantiates that modeledfence line H2S exposuresdecrease (i.e., maximum allowable emissions rates increase) significantlyfor all block locations as the blockpouring height increases from 20It to40ft·

The facility will observe the maximum emission rates established inAppendix A for the 20ft blockform height for elevations above 20ft andto a maximum elevation of40 ft.

Response #1: The maximum block height has been increased to 40 ft as requested.

ADEQARK A N S A SDepartment of Environmental Quality

June 30, 2009

Gary BeardTerminal ManagerKinder Morgan Operating LP - "C" - Blytheville Terminal6162 State Hwy 18 EastBlytheville, AR 72315

Dear Mr. Beard:

The enclosed Permit No. 0232-AR-ll is your authority to construct, operate, and maintain theequipment and/or control apparatus as set forth in your application initially received on2/23/2009.

After considering the facts and requirements of A.C.A. §8-4-101 et seq., and implementingregulations, I have determined that Permit No. 0232-AR-ll for the construction, operation andmaintenance of an air pollution control system for Kinder Morgan Operating LP - "c" Blytheville Terminal to be issued and effective on the date specified in the permit, unless aCommission review has been properly requested under §2.l.l4 of Regulation No.8, ArkansasDepartment of Pollution Control & Ecology Commission's Administrative Procedures, withinthirty (30) days after service of this decision.

All persons submitting written comments during the thirty (30) day, and all other persons entitledto do so, may request an adjudicatory hearing and Commission review on whether the decisionof the Director should be reversed or modified. Such a request shall be in the form and mannerrequired by §2.l.l4 of Regulation No.8.

Sincerely,

LL~Mike BatesChief, Air Division

ARKANSAS DEPARTMENT OF ENVIRONMENTAL QUALITY5301 NORTHSHORE DRIVE / NORTH LITTLE ROCK / ARKANSAS 72118-5317 / TELEPHONE 501-682-0744 / FAX 501-682-0880

www.odeq.stote.or.us

ADEQMINOR

SOURCEAIR PERMIT

Permit No.: 0232-AR-l1

IS ISSUED TO:

Kinder Morgan Operating LP - "C" - Blytheville Terminal6162 State Hwy 18 EastBlytheville, AR 72315

Mississippi CountyAFIN: 47-00012

THIS PERMIT IS THE ABOVE REFERENCED PERMITTEE'S AUTHORITY TOCONSTRUCT, MODIFY, OPERATE, AND/OR MAINTAIN THE EQUIPMENT AND/ORFACILITY IN THE MANNER AS SET FORTH IN THE DEPARTMENT'S MINOR SOURCEAIR PERMIT AND THE APPLICATION. THIS PERMIT IS ISSUED PURSUANT TO THEPROVISIONS OF THE ARKANSAS WATER AND AIR POLLUTION CONTROL ACT(ARK. CODE ANN. SEC. 8-4-101 ET SEQ.) AND THE REGULATIONS PROMULGATEDTHEREUNDER, AND IS SUBJECT TO ALL LIMITS AND CONDITIONS CONTAINEDHEREIN.

Signed:

kL~Mike BatesChief, Air Division

June 30, 2009

Date

Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012

Table of Contents

I: FACILITY INFORMATION 3Section I: FACILITY INFORMATION 4Section II: INTRODUCTION 5

Summary of Permit Activity 5Process Description 5Regulations 8Total Allowable Emissions 8

Section III: PERMIT HISTORY 9Section IV: EMISSION UNIT INFORMATION 12

SN-25 Conditions 14SN-1001 and 1002 Conditions 15Emergency Ammonia Flare Conditions 15SN-17 Conditions 15SN-902, 905, & 906 Conditions 16Block Pouring Conditions (SN-903) 18Prilling Conditions (SN-907) 19

Section VI: GENERAL CONDITIONS 22APPENDIX A

2

Kinder Morgan Operating LP - "c" - Blytheville TerminalPermit #: 0232-AR-11AFIN: 47-00012

List of Acronyms and Abbreviations

A.C.A.

AFIN

CFR

CO

HAP

lb/hr

No.

NOx

PM

PM10

S02

Tpy

UTM

VOC

MT

Arkansas Code Annotated

ADEQ Facility Identification Number

Code of Federal Regulations

Carbon Monoxide

Hazardous Air Pollutant

Pound Per Hour

Number

Nitrogen Oxide

Particulate Matter

Particulate Matter Smaller Than Ten Microns

Sulfur Dioxide

Tons Per Year

Universal Transverse Mercator

Volatile Organic Compound

Metric Ton

3

Kinder Morgan Operating LP - "C" - Blytheville TenninalPennit #: 0232-AR-llAFIN: 47-00012

Section I: FACILITY INFORMATION

PERMITTEE: Kinder Morgan Operating LP - "c" - Blytheville Tenninal

AFIN: 47-00012

PERMIT NUMBER: 0232-AR-ll

FACILITY ADDRESS: 6162 State Hwy 18 EastBlytheville, AR 72315

MAILING ADDRESS: 6162 State Hwy 18 EastBlytheville, AR 72315

COUNTY: Mississippi County

CONTACT NAME: Gary Beard

CONTACT POSITION: Tenninal Manager

TELEPHONE NUMBER: 870-763-0800

REVIEWING ENGINEER: Jennifer Boyette

UTM North South (Y):

UTM East West (X):

Zone 16: 3977036.84 m

Zone 16: 250374.47 m

4

Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFlN: 47-00012

Section II: INTRODUCTION

Summary of Permit Activity

Kinder Morgan-Blytheville Terminal operates a bulk terminal at 6162 State Highway 18 East inBlytheville, Arkansas. This permit modification is for the installation of a Refined Molten SulfurHandling and Storage Facility. This includes a 22MMBTUIhr Natural Gas fired boiler (SN901), a sulfur pit (SN-902), a sulfur block pouring operation (SN-903), a sulfur blockcrushing/handling (SN-904), a remelt tank (SN-905), a sulfur storage tank (SN-906), a priller(SN-907), a cooling tower (SN-908), and finished product loading (SN-909). The changes in thepermitted emission increases are 5.9 tpy PM, 6.0 tpy PMIO, -0.3 tpy S02, 0.6 tpy VOC, 8.0 tpyNOx, 8.0 tpy CO, and 78.55 tpy H2S.

Process Description

The facility permanently ceased its manufacturing operations at the end of May 2004; allemission sources associated with manufacturing are permanently shutdown.

Kinder Morgan-Blytheville Terminal is now a "Terminal Operation" providing storage forseveral bulk products and No.2 fuel oil.

Dry Bulk Product Storage and Handling (SN-25)

Bulk products brought into the plant are bulk loaded into barges, railcars, and trucks. Theseproducts include:

• Coal and Coke

• Ores and Metal Alloys

• Aggregates

• Grains and Feeds

• Urea Products

• Dry Bulk Fertilizer Products (potash, sulfates, nitrates, phosphates), and

• Inorganic Salts

Coal, coke, alloys and aggregate products will be stored in an outdoor stockpile area at thefacility. Emissions from these piles will be controlled by use of canopies and/or manual watersprays. Grains, feeds, urea products and dry bulk fertilizer products will be stored indoors.

In addition, a small amount of drying (LPG-fired Fluidized Bed Dryer), crushing and screeningof some metal alloys may occur at the facility from time to time. These emissions have beenincluded in the emissions totals for SN-25.

5


Emissions estimates for the urea loading are based on AP-42 factors for urea bagging (Section8.2-4, Table 8-2.1). There are no specified emissions for loading operations according to thestatement on 8.2-5, which states "nationwide approximately 90% of urea produced is bulkloaded. Few plants control their bulk loading operations. Generation of visible emissions isnegligible." To be conservative, factors for urea bagging were used. The urea bagging factor is0.19Ib/ton of product produced.

Emission factors for handling, loading and storing the other bulk materials are based on AP-42factors and assume the maximum capacity of the existing equipment.

Ammonia Loading Heater

Liquid ammonia is stored in tanks at -28 0 F; loading, requires a temperature of about 40 0 F.

Liquid ammonia is circulated through the inside of heat transfer tubes of a heat exchanger whilethe outside of the tubes are heated by three burners fired with natural gas exclusively. Eachburner has a maximum heat Input of 6.7 MMBtu/hr (total 20.1 MMBtu/hr). Four 12-inchdiameter exhaust stacks vent the flue gases. The heater (purchased was originally in 1968) hadnew tubes and new fuel train controls installed in 2004 (manufacturer specifications and P&IDdrawing are included with application).

The heater (SN-319) will be used intermittently (rail/truck loading only); the emissions areestimated on a "potential to emit" basis so as to not restrict the heaters use.

Allowable emissions will be demonstrated by natural gas usage; the permittee will monitornatural gas usage by the heater. The ammonia heater is not subject to NSPS, 40 CFR 60, SubpartDc (natural gas fired only) since the ammonia is not being used as a heat exchange medium aspresented in the NSPS definition.

Emergency Ammonia Flares

The two ammonia flares are installed to provide a means of ammonia thermal destruction duringemergencies such as extended periods of electrical power interruption. The on-site ammoniaproduct storage tanks are cooled by electrically powered units. The vapor pressure within thetanks is required to be maintained below one (l) psi. Pressure relief valves vent to the ammoniaflares before the tank pressure exceeds one (l) psi. Combined usage for both flares is (fourseparate pilots) 0.8 Mclli of natural gas per hour (considered an insignificant activity). Themaximum feed rate per flare is 12,000 lbs/hr. The ammonia destruction efficiency of the flare is99%. NOx generated by the thermal destruction is 0.5% by weight of the ammonia introduced.Emissions permitted represent the pollutants from the flares pilots only. Emissions as a result offlares being used during emergencies shall be reported separately.

Fugitives from Pumps, Seals & Taps

Ammonia emissions occur from the pumps, seals, and taps at the facility (SN-17). Theemissions are estimated based on an annual mass balance.

No.2 Fuel Storage

A 263,210 storage tank (SN-I00l) will be used to store a highly refined petroleum distillateproduced at the Chevron Oronite Hot Springs Arkansas Plant. Emissions result from standinglosses form the tank and loading and unloading of trucks (SN-I002).

6

Kinder Morgan Operating LP - "e" - Blytheville TerminalPermit #: 0232-AR-IlAFIN: 47-00012

Refined Molten Sulfur Handling and Storage

Refined molten sulfur (i.e., molten sulfur generated as a petroleum refining by-product) will bebrought to the facility primarily by rail and secondarily by truck or barge. Mined sulfur (asknown as frasch sulfur) will not be handled at the facility. The facility will employ unloadingprocedures to ensure there are no venting emissions from transportation vessels while at thefacility. The unloading emissions occur at the sulfur pit or the storage tank as a transportationvessel is unloaded. There are no emission sources defined for the transportation vessels as aresult of the aforementioned operating procedures.

Rail cars or trucks will be heated with steam upon reaching the facility, if required, to ensure themolten sulfur can be handled. A 22 MMBTUIhr boiler (SN-901) will provide the steamnecessary to heat the sulfur. The boiler will be fueled by natural gas. The targeted temperaturefor handling the molten sulfur is 260-280oF. Sulfur freezes below 240°F and becomes thick andviscous above 300°F.

Once the sulfur has been heated to 260-280°F, the molten sulfur is emptied from a rail car or tanktruck, via gravity, air pressure, and/or pumping, into the sub grade concrete pit that is enclosedexcept for the pipe and hose openings in the lid, or may be conveyed directly to the monolithicblock pouring area by truck or piping. Molten sulfur can be unloaded to the pit area at a rate oftwo and a half90-MT (metric ton) rail cars per hour. The emissions ofH2S occurring as themolten sulfur displaces air in the sulfur pit are permitted as SN-902.

Molten sulfur will be poured into a monolithic block (SN-903) for long term storage or will betemporarily stored in a steam-heated, insulated storage tank (SN-906) for short term storage priorto block pouring, prilling, prill storage, and shipping. Molten sulfur will be pumped from thesulfur pit to the storage tank or to the block pouring area via pumps at a rate ofup to 500 MT perhour (capacity of the pump). The pumping rate to the block pouring area will be adjusteddependent upon the H2S content of the molten sulfur being poured. Molten sulfur can bepumped from barges to the insulated storage tank (SN-906) at rates up to 1,000 MT per hourBlock Sulfur Handling (SN-904) includes breaking chunks from the pour block with a front endloader, transferring those blocks to the crusher, and conveying the crushed material to the RemeltTank. The maximum amount of solid sulfur handled in this step will be limited by the remelttank and the priller capacity. The throughput of the remelt tank and the priller is 2,400 MT perday.

Solid sulfur is conveyed from the crusher into a remelt tank (SN-905). Emissions are estimatedusing vapor displacement and H2S concentration in the Remelt Tank. Once melted, the sulfur canbe pumped to the priller for final forming or the molten sulfur storage tank. The loading rate islimited by crusher capacity and by the priller capacity.

Molten sulfur is pumped to the priller (SN-907) from the molten sulfur storage tank to be prilled(pelletized) by dropping though a screen into a water bath. Emissions are estimated using massbalance of a loss of the labile content of the H2S concentration (37.5% ppmw) of the moltensulfur. The maximum pump rate to the priller is 100 MTIhr. The hourly throughput for the

7


prilling will be limited to control H2S emissions when the block pouring of sulfur is conducted orwhen the concentration ofH2S exceeds 200 ppmv.

Sulfur prills are then stored or shipped to customers. The prill loading emissions are permittedas SN-909.

Regulations

The following table contains the regulations applicable to this permit.

Regulations

Arkansas Air Pollution Control Code, Regulation 18, effective January 25, 2009

Regulations of the Arkansas Plan ofImplementation for Air Pollution Control,Regulation 19, effective January 25, 2009

Total Allowable Emissions

The following table is a summary of emissions from the facility. This table, in itself, is not anenforceable condition of the permit.

TOTAL ALLOWABLE EMISSIONS

Emission RatesPollutant

lb/hr tpy

PM 3.3 20.8

PM10 3.3 13.4

S02 0.4 0.3

VOC 1.8 2.7

CO 4.2 15.9

NOx 7.6 20.8

Ammonia 2.6 11.3

Chromium 0.03 0.11

Manganese 0.06 0.24

Nickel 0.001 0.001

H2S 18.13 78.55

8

Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-IlAFIN: 47-00012

Section III: PERMIT HISTORY

232-A

232-AR-l

232-AR-2

232-AR-3

232-AR-4

232-AR-5

Issued to Agrico Chemical Company in 1974 for the installation of a 1000 ton perday urea synthesis and granulation plant for the manufacture of fertilizer material.This proposed facility was an addition to the existing plant which producedanhydrous ammonia. An oil fired boiler was installed to supply process steam.

Issued to Freeport-McMoRan Resource Partners on 6/7/88. This permitdocumented the change of ownership. No physical changes were made at theplant.

Issued to Agricultural Minerals, Limited Partnership on 6/20/90. This permitdocumented the change of ownership, as well as the installation of an ammoniarecovery scrubber on the urea plant process vent.

Issued to Agricultural Minerals, Limited Partnership on 2/14/94. This permit wasfor the installation of a nitric acid plant at the facility. The nitric acid plant wasnever built.

Issued to Terra Nitrogen, Limited Partnership on 10/24/95. This permitdocumented the change of ownership, as well as the installation of a new boiler(SN-13). This permit also raised the allowable emission rate from the ureaproduction common stack for ammonia due to stack test results.

Issued to Terra Nitrogen, Limited Partnership on 11/12/96. The permit includedincreasing the VOC emission limit for the urea boiler based on stack test data, theaddition of an ammonia emission limit for the DAN evaporator as a result ofresearch conducted, installation of two vessels where nitric acid and ammoniacondensate are combined prior to entering the evaporator, and grouping ammoniaemission sources SN-07, SN-12, SN-14, and SN-19, together to have a collectiveammonia emission limit.

232-AOP-RO Issued to Terra Nitrogen Limited Partnership on 5/1/98. This was the first permitunder Title V for this facility. The permit reflected a change in emission factorsand not a physical change in the plant. The permit incorporated a plant wideapplicable limit (PAL) on the emission of each pollutant.

9

Kinder Morgan Operating LP - "C" - Blytheville TenninalPennit #: 0232-AR-IlAFIN: 47-00012

232-AOP-Rl Issued to Terra Nitrogen Limited Partnership on 8/2/2000. The MinorModification allowed for the installation of a second flare stack. The flare stackwas similar to the existing flare stack and is used only for extended powerinterruptions or in the event both the stand-by and the primary compressors failsimultaneously (the flares incidence of use averages less than once per year).Yearly emissions for the facility's predominate pollutant (ammonia) did notincrease. The aggregate increase for all pollutants was less than 0.5 tons per yearbased on the pilot burner only.

232-AOP-R2 Issued to Terra Nitrogen Limited Partnership on April 26, 2002. Themodification changed the requirement for having a person certified in Method 9opacity reading to having a person trained (but not certified).

232-AOP-R3 Issued to Terra Nitrogen Limited Partnership on November 3, 2003. The originalTitle V pennit for the facility (232-AOP- RO) was issued on May 1, 1998. Thepennit expired on Apri130, 2003. This pennit renewed the Title V pennit inaccordance with General Provision 3 of the pennit and ADEQ Regulation§26.406.

There were no modifications to the facility; however, a CAM Plan was added forthe Urea Granulation Wet Scrubbers (SN-12) and emission rates of pollutantswere changed as follows:

1.) a correction to tables in Specific Conditions 21 and 24;

2.) lower ammonia (NH3) emission rates at the C02 vent for the AmmoniaManufacturing Process (SN-07) because of past experience and less emissionsfrom the common stack (SN-14) based on emission tests, and feweremissions from Urea Granulation (SN-12) based on emission tests,

3.) lower volatile organic compound (VOC) and methanol emission rates for SN07 as a result of updated emission factors;

4.) higher CO emission rates for SN-13 because of changes in AP-42 emissionfactors.

5.) Sources SN-32 and SN-33 were combined with SN-07 since they representedthe HAPs from SN-07; and SN-31 was combined with SN-12 since itrepresents the HAPs from SN-12.

6.) A pennit shield and CAM plan was added.

232-AR-6 Issued on November 19th, 2004. This pennit allowed the facility to pennanently

cease its manufacturing operations at the end ofMay 2004; all emission sourcesassociated with manufacturing were pennanently shutdown.

Terra is now a "Tenninal Operation." The new operation's emissions qualifiedTerra for a SIP (Minor Source) pennit.

This pennit recognized the following changes:

10

Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-11AFIN: 47-00012

1.) Permanent shutdown of all emission sources solely associated withmanufacturing;

2.) Addition of the ammonia-loading heater;

3.) Continued permitting ofSN-05 A & B, the ammonia flares;

4.) Continued permitting ofSN-25, the urea loading operations;

5.) Continued permitting of SN -17, the ammonia fugitive emissions plantwidefrom loading operations;

6.) An updated insignificant activities list.

The annual net reduction in the facility's allowable emissions will be more than4,900 tons.

232-AR-7 Issued on January 19, 2006. This permit allowed the facility to change the namefrom Terra Nitrogen Limited Partnership to Kinder Morgan-Blytheville Terminal.This modification also allowed this facility to provide bulk storage for a highlyrefined petroleum distillate (No.2 fuel oil). Emissions increased by 1.0 tpy VOCdue to standing and working losses from the tank.

232-AR-8 Issued on May 23,2006. This modification allowed this facility to includemultiple product categories in addition to the existing urea handling at SN-25 andto revise the emission calculations to more accurately reflect the operation of thefacility. These changes resulted in permitted emissions reductions of 2.1 tpyPMlPMIO, 0.1 tpy S02, 0.1 tpy VOC, 0.3 tpy CO, 0.4 tpy NOx, and 34.0 tpyammonia. Permitted emissions increased by 0.11 tpy chromium, 0.24 tpymanganese and 0.001 tpy nickel.

232-AR-9 Issued on April 23, 2008. This modification allowed this facility to installadditional handling (conveyor, screener, and silo) and processing equipment (LPgas-fired dryer) to SN-25, the dry bulk storage and handling operations, whichwill allowed the facility to handle wet anthracite coal products (8-10% moisturecontent). These changes resulted in permitted emissions increases of 0.2 tpyPM/PM IO , 0.1 tpy S02, 0.1 tpy VOC, 0.5 tpy CO, and 2.5 tpy NOx•

232-AR-10 Issued on August 20, 2008. This permit modification was to update the generalpermit conditions for research and development and to approve the conduction ofa two week research and development and/or pilot testing of a small portablepellet dryer. The evaluations were conducted using a portable trailer-mounted1MM BTU/hr LPG-fired dryer to treat solid palletized sulfur and may consumeup to 1,200 gallons of LPG. The facility will not exceed emissions of 1 ton peryear (tpy) of any single air contaminant or 2.5 tpy of any combined aircontaminants during this test. The permitted emissions remain unchanged.

11


Section IV: EMISSION UNIT INFORMATION

Specific Conditions

1. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 19, §19.501 et seq., and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304and §8-4-311]

SN Description Pollutant lb/hr tpy

PM 10 1.7 6.8

Dry Bulk Product S02 0.1 0.1

25Drying, Storage, and

VOC 0.1 0.1HandlingCO 0.6 0.5

NOx 3.3 2.5

PM 10 0.2 0.7

S02 0.2 0.1

319Ammonia Loading

VOC 0.3 1.0HeaterCO 1.7 7.4

NOx 2.1 8.8

Distillate Fuel Oil No.21001 Vertical Fixed Roof VOC 0.2 0.5

TankUncontrolled Emissions

1002 from Loading and VOC 1.0 0.5Unloading Trucks

PM10 0.2 0.8

S02 0.1 0.1

901 Boiler (22MMBtu/hr) VOC 0.2 0.6

CO 1.9 8.0

NOx 2.2 9.5

904Sulfur Block

PMIO 0.2 0.9Crushing/Handling

908 Cooling Tower PM10 0.9 3.8

909Sulfur Finished Product

PM10 0.1 0.4Loading

12


2. The permittee shall not exceed the emission rates set forth in the following table.[Regulation 18, §18.801 and A.C.A. §8-4-203 as referenced by A.c.A. §8-4-304 and §84-311]

SN Description Pollutant lblhr tpy

Fugitives from17 Pumps, Seals and Ammonia 2.6 11.3

TrapsDry Bulk Product PM 1.7 14.2

25Drying, Storage, and Chromium 0.03 0.11

Handling Manganese 0.06 0.24Nickel 0.001 0.001

319Ammonia Loading

PM 0.2 0.7Heater

901 Boiler (22MMBtulhr) PM 0.2 0.8

902Sulfur Pit (Truck or

H2S 0.28 1.20Rail Unloading)

903 Sulfur Block Pouring H2S 2.72 6.14

904Sulfur Block

PM 0.2 0.9CrushinglHandling

905 Sulfur Re-melt Tank H2S 0.03 0.12

906Molten Sulfur Storage

H2S 1.82 1.01Tank

Priller Exhaust VentH2S 16.00

with Block Pouring907

Priller Exhuast Vent70.08

H2S 2.20without BlockPouring

908 Cooling Tower PM 0.9 3.8

909Sulfur Finished PM 0.1 0.4

Product Loading

3. Visible emissions may not exceed the limits specified in the following table of this permitas measured by EPA Reference Method 9. [A.C.A. §8-4-203 as referenced by A.C.A.§8-4-304 and §8-4-311]

SN Limit Regulatory Citation

319,901,904,& 5% §18.501

909

25,908 15% §18.501

13

Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-l1AFIN: 47-00012

4. The permittee shall not cause or permit the emission of air contaminants, including odorsor water vapor and including an air contaminant whose emission is not otherwiseprohibited by Regulation 18, if the emission of the air contaminant constitutes air'pollution within the meaning ofA.C.A. §8-4-303. [Regulation 18, §18.801 andAC.A §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

5. The permittee shall not conduct operations in such a manner as to unnecessarily cause aircontaminants and other pollutants to become airborne. [Regulation 18, §18.901 andAC.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

SN-25 Conditions

6. The permittee shall not exceed the throughputs at the bagging and loading operationscontained in the following table per rolling 12-month period. [Regulation 19, §19.705,Regulation 18, §18.l004 and A.C.A §8-4-203 as referenced by AC.A §8-4-304 and§8-4-311]

Product Tons per year

Urea 90,000

Coal and Coke 500,000

Ores and Metal Alloys 200,000

Aggregates 300,000

Grains and Feeds 200,000

Dry Bulk Fertilizer Products 300,000

Inorganic Salts 200,000

7. The permittee shall maintain monthly records which demonstrate compliance withSpecific Condition 6. These records shall:

A Document the monthly receipts of dry bulk products;

B. Document the twelve month rolling total;

C. Be updated by the fifteenth day of the month following the month to which therecords pertain;

D. Be maintained on site for a minimum of two years; and

E. Be made available to Department personnel upon request.

[Regulation 19, §19.705 and AC.A. §8-4-203 as referenced by A.CA. §8-4-304 and§8-4-311]

14


8. The fuel consumption for the LPG-fired Fluidized Bed Dryer shall not exceed 340,400gallons per consecutive 12-month period. The permittee shall maintain monthly recordsand these records shall be updated by the 15th day of the month following the month towhich the records pertain. A copy of these records shall be maintained on site and madeavailable to Department personnel upon request. [Regulation 18, §18.1 004, Regulation19, §19.705 and AC.A §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

SN-1001 and 1002 Conditions

9. The throughput at SN-lOOI shall not exceed 789,628 gallons of No. 2 fuel oil based on arolling twelve month total. The permittee shall maintain records of the throughput at thissource. These records shall be maintained on a monthly basis and updated by the 15th

day of the month following the month to which the records pertain. A copy of theserecords shall be maintained on site and made available to Department personnel uponrequest. [Regulation 19, §19.705 and 40 CFR Part 52, Subpart E]

Emergency Ammonia Flare Conditions

10. The permittee shall record data regarding the use of the flare stacks. The followinginformation shall be logged:

A Event causing the flare(s) to be used;

B. The date and time that the flare usage started;

C. The length oftime that the flare(s) were used;

D. The identification of material and the estimated pounds of material being flared; and

E. The legible name of the person logging the information.

[Regulation 19, §19.703 and AC.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

11. Any use of the flares shall be reported in accordance with Regulation 19, by the nextbusiness day and every six months. This does not include the time when only the pilot isoperating. [Regulation 19, §19.705 and AC.A §8-4-203 as referenced by AC.A.§8-4-304 and §8-4-311]

12. The Department reserves the right to evaluate the use of the flares and require permittingof flaring events if the Department deems that emissions from the flares are substantial orpredictable or if the use of the flares is not for emergencies and upset conditions.[Regulation 19, §19.705 ofRegulation 19 and AC.A. §8-4-203 as referenced by AC.A§8-4-304 and §8-4-311]

SN-17 Conditions

13. The ammonia throughput at this facility shall not exceed 100,000 tons per consecutivetwelve month period. [Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced byAC.A §8-4-304 and §8-4-311]

14. The permittee shall maintain monthly records which demonstrate compliance withSpecific Condition 13. These records shall:

15

Kinder Morgan Operating LP - "c" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012

A. Document the monthly receipts of dry bulk products;

B. Document the twelve month rolling total;

C. Be updated by the fifteenth day of the month following the month to which therecords pertain;

D. Be maintained on site for a minimum of two years; and

E. Be made available to Department personnel upon request.

[Regulation 18, §18.1 004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

Refined Molten Sulfur Handling and Storage Conditions

SN-902, 905, & 906 Conditions

15. The following operating procedure (or a documented practice/procedure that achieves thesame results) must be followed to prevent the release of any H2S emissions during theunloading/emptying of molten sulfur transportation vessels:

1) Hook the unloading hose to the transportation vessel,

2) Then hook up an air pressure line to the transportation vessel, if needed andappropriate,

3) Then open the bottom/unloading valve (the purpose for this is to create a suctionwithin the transportation vessel) to ensure no vapors leave the top relief valves orhatch of the transportation vessel),

4) Then finally open the top/relief valve, or turn on air pressure, allowing the moltensulfur to flow or to be pumped.

5) Upon completion of unloading, turn off the pump if appropriate, then close thetop/relief valve or tum off and disconnect the air pressure line, then close thebottom unloading valve and disconnect the unloading hose.

No transportation vessels may be vented while on the facility premises.[Regulation 18, §18.l004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311 ]

16. The barge pump rate of molten sulfur shall not exceed 1,000 MT/hr. The permittee shallmonitor and record the barge pump rates during receiving. These records shall bemaintained on a monthly basis and updated by the 15th day of the month following themonth to which the records pertain. A copy of these records shall be maintained on siteand made available to Department personnel upon request. [Regulation 18, §18.1 004and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

17. Each shipment of molten sulfur must be accompanied by documentation certifying theconcentration ofH2S or an analysis must be performed while at the facility to determinethe H2Sconcentration of each shipment from a representative transportation vessel priorto unloading. [Regulation 18, §18.l004 and A.C.A. §8-4-203 as referenced by A.C.A.§8-4-304 and §8-4-311]

16


18. The permittee shall measure and record the concentration the concentration ofH2S in theheadspace of SN-902, 90S, and 906 within 8 hours prior to each filling. Thesemeasurements shall be compared to headspace concentration of H2S listed in the tablebelow:

SN Description Concentration in Headspace

SN-902 Sulfur Pit 9S0 ppmv

SN-90S Remelt Tank 210 ppmv

SN-906 Molten Sulfur Storage Tank 950 ppmv

If the headspace concentration at or below the listed values, no further action is required.If the measurements indicate these headspaces concentrations are exceeded, the fill rateof the source shall be monitored and shall not exceed the fill rate determined by thefollowing equation:

FR = ERL*783189.6

HSConc

where

FR = Fill Rate (MT/hr)

ERL = Emission Rate Limit for H2S listed in Specific Condition 2.

HSConc. = Head Space Concentration (ppmv) H2S

[Regulation 18, §18.1 004 and A.C.A §8-4-203 as referenced by AC.A §8-4-304 and§8-4-311]

19. To demonstrate compliance with Specific Condition 18, the following records shall bekept:

A The measured head space concentration (ppmv)

B. Calculated maximum allowed fill rate (MT/hr)

C. Actual Fill Rate (e.g., pump rate, rail cars per hour and size of rail car, trucks per hourand size of trucks, buckets of solidified sulfur and size of loader bucket, etc.)

D. If the headspace concentrations listed the table of Specific Condition 18 is notexceeded, only records for Part A are required.

These records shall be maintained on a monthly basis and updated by the lSth day of themonth following the month to which the records pertain. A copy of these records shall bemaintained on site and made available to Department personnel upon request.[Regulation 18, §18.1004 and A.C.A §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

17


Block Pouring Conditions (SN-903)

20. The total height of the monolithic sulfur block shall not exceed 40 ft. The total area ofthe blocks creating the monolithic sulfur block shall be bound by the UTM coordinates250607.5 to 250767.5 east - west and 3978292.5 to 3977595.5 north - south. [Regulation18, §18.1 004 and A.C.A. §8-4-203 as referenced by A.C.A §8-4-304 and §8-4-311]

21. A single sulfur block poured shall not be less than 11,025 sq ft. [Regulation 18, §18.1 004and A.C.A. §8-4-203 as referenced by AC.A §8-4-304 and §8-4-311]

22. The permittee shall calculate and monitor the maximum molten sulfur block pouring ratesallowed dependent on the minimum form height at the time of the pour, as found inAppendix A, using the equation:

PR = 5533.18* ERCone.

where:

PR = pour rate (MT/hr)

ER* = maximum H2S emission rate (lb/hr) for a given height at a particularlocation. Values for ER are listed in Appendix A. For pour heights between 20 ftand up to 40 ft, the ER values for 20 ft will be used as a limiting factor.

Conc. = concentration ofH2S (ppmw) in molten sulfur

*Instructions and example for determining the correct ER are provided below:

A. Determine the dimensions and location of the block being poured anddetermine which model blocks contain a portion of the block being poured.(Appendix A has locations of model blocks in UTM; Appendix B has agraphical representation). See graphical example below:

Model Block Model Block Model BlocklA 2A 3A

Example Block:A Single Pour

Block

Model Block Model Block Model BlockIB 2B 3B

Note: For this example block, the corresponding modeled blocks are lA, 2A, IB, and 2. SeeAppendix Afar locations ofmodeled blocks.

B. Using Appendix A, record the H2S emission rate for each height range for allof the model blocks affected by the pour block. Choose the lowest H2Semission rate (ER) for each height range out of the modeled data set affectedby the pour block.

18


[Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

23. The permittee shall maintain records which demonstrate compliance with SpecificConditions 20 to 22. These records shall include:

A. The location of the pour block and the corresponding modeled block ID's

B. The H2S emission rates for the corresponding model blocks (all height ranges). Thelowest emission rate for each height range shall be selected and used as the limit forthe block pour.

C. The concentration of H2S (ppmw) contained in the molten sulfur being poured.

D. Calculation of Pour Rate (MT/hr) for the four height ranges

E. The pour rates (MT/hr) for each height range

F. The final height of the block (ft)

G. Area ofthe block (sq ft)

These records shall be maintained on a daily basis when pouring sulfur block. A copy ofthese records shall be maintained on site and made available to Department personnelupon request. [Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A.§8-4-304 and §8-4-311]

Prilling Conditions (SN-907)

Prilling without Block Pouring

24. If block pouring operations have been conducted within the last 24 hours or withconcurrent operation of the Block Pouring operations (SN-903) the maximum allowablepump rate for the priller shall be monitored and shall not exceed the value calculatedfrom the flowing equation:

2661.82P R(priller) = C

onc

where:

PRcpriller) = pour rate (MT/hr) molten sulfur

Cone. = concentration of H2S (ppmw) in molten sulfur

[Regulation 18, §18.1004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

25. To demonstrate compliance with Specific Condition 24 records must be kept and shallinclude the following:

A. The time and date of operations for SN-903(Block Pouring) and SN-907 (Prilling).

B. The concentration (ppmw) ofH2S in the molten sulfur prilled.

C. The calculation determining the maximum pour rate (PR in MT/hr).

19


D. The actual pump rate (MT/hr)

These records shall be maintained on a daily basis when the source is in operation. Acopy of these records shall be maintained on site a minimum of 18 months and madeavailable to Department personnel upon request. [Regulation 18, §18.1 004 andA.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

Prilling with Block Pouring

26. If block pouring operations have NOT been conducted within the last 24 hours or withconcurrent operation of the Block Pouring operations (SN-903) the maximum allowablepump rate for the priller shall be monitored and shall not exceed the value calculatedfrom the flowing equation:

19358.74PR{priller) = C

onc

where:

PRCpriller) = pour rate (MT/hr) molten sulfur

Cone. = concentration ofH2S (ppmw) in molten sulfur[Regulation 18, §18.1 004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

27. To demonstrate compliance with Specific Condition 26, records must be kept and shallinclude the following:

A. The time and date of operations for SN-903(Block Pouring) and SN-907 (Prilling).

B. The concentration (ppmw) ofH2S in the molten sulfur prilled.

C. The calculation determining the maximum pour rate (PR in MT/hr).

D. The actual pump rate (MT/hr)

If the H2S concentration in the molten sulfur is 200 ppmw or below only records listed inA and B are required.[Regulation 18, §18.1 004 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

28. To demonstrate the monitoring requirements in Specific Conditions 15, 18, 22, and 24,the permittee shall install, calibrate, and maintain pump flow meters. The flow rates shallbe monitored continuously, and recorded every 30 minutes while in operation.[Regulation 18, §18.1003 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and§8-4-311]

20

Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-IlAFIN: 47-00012

Section V: INSIGNIFICANT ACTIVITIES

The Department deems the following types of activities or emissions as insignificant on the basisof size, emission rate, production rate, or activity in accordance with Group A of theInsignificant Activities list found in Regulation 18 and 19 Appendix A. Insignificant activityemission determinations rely upon the information submitted by the permittee in an applicationdated January 9, 2008.

Description Category

2 Flare Stack @ 0.8 Mcfh ofNG/hr A-I

Ammonia Loading A-13

Wastewater Lagoon, Ammonia A-13

Wastewater Lagoon, Urea A-13

Wastewater Lagoon, Emergency A-13

Evaporative Cooler A-13

UAN Storage and Handling A-13

Gasoline Storage Tank A-3

Diesel Storage Tank A-3

Lab EquipmentNents A-5

21


Section VI: GENERAL CONDITIONS

1. Any terms or conditions included in this permit that specify and reference ArkansasPollution Control & Ecology Commission Regulation 18 or the Arkansas Water and AirPollution Control Act (AC.A. §8-4-101 et seq.) as the sole origin of and authority for theterms or conditions are not required under the Clean Air Act or any of its applicablerequirements, and are not federally enforceable under the Clean Air Act. ArkansasPollution Control & Ecology Commission Regulation 18 was adopted pursuant to theArkansas Water and Air Pollution Control Act (A.C.A §8-4-101 et seq.). Any terms orconditions included in this permit that specify and reference Arkansas Pollution Control& Ecology Commission Regulation 18 or the Arkansas Water and Air Pollution ControlAct (A.C.A §8-4-101 et seq.) as the origin of and authority for the terms or conditionsare enforceable under this Arkansas statute.

2. This permit does not relieve the owner or operator of the equipment and/or the facilityfrom compliance with all applicable provisions of the Arkansas Water and Air PollutionControl Act and the regulations promulgated under the Act. [A.C.A. §8-4-203 asreferenced by AC.A §8-4-304 and §8-4-311]

3. The permittee shall notify the Department in writing within thirty (30) days aftercommencement of construction, completion of construction, first operation of equipmentand/or facility, and first attainment of the equipment and/or facility target production rate.[Regulation 19, §19.704 and/or AC.A §8-4-203 as referenced by A.C.A §8-4-304 and§8-4-311]

4. Construction or modification must commence within eighteen (18) months from the dateofpermit issuance. [Regulation 19, §19.410(B) and/or Regulation 18, §18.309(B) andAC.A. §8-4-203 as referenced by A.C.A §8-4-304 and §8-4-311]

5. The permittee must keep records for five years to enable the Department to determinecompliance with the terms of this permit such as hours of operation, throughput, upsetconditions, and continuous monitoring data. The Department may use the records, at thediscretion of the Department, to determine compliance with the conditions of the permit.[Regulation 19, §19.705 and/or Regulation 18, §18.1004 and A.C.A §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311]

6. A responsible official must certify any reports required by any condition contained in thispermit and submit any reports to the Department at the address below. [Regulation 19,§19.705 and/or Regulation 18, §18.l004 and A.C.A §8-4-203 as referenced by A.C.A.§8-4-304 and §8-4-311]

Arkansas Department of Environmental QualityAir DivisionATTN: Compliance Inspector Supervisor

22

Kinder Morgan Operating LP - "C" - Blytheville TenninalPennit #: 0232-AR-llAFIN: 47-00012

5301 Northshore DriveNorth Little Rock, AR 72118-5317

7. The permittee shall test any equipment scheduled for testing, unless stated in the SpecificConditions of this pennit or by any federally regulated requirements, within the followingtime frames: (1) newly constructed or modified equipment within sixty (60) days ofachieving the maximum production rate, but no later than 180 days after initial start up ofthe permitted source or (2) existing equipment already operating according to the timeframes set forth by the Department. The pennittee must notify the Department of thescheduled date of compliance testing at least fifteen (15) days in advance of such test.The pennittee must submit compliance test results to the Department within thirty (30)days after the completion of testing. [Regulation 19, §19.702 and/or Regulation 18,§18.1 002 and A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-311]

8. The pennittee shall provide: [Regulation 19 , §19.702 and/or Regulation 18 , §18.l002and A.C.A. §8-4-203 as referenced by A.c.A. §8-4-304 and §8-4-311]

a. Sampling ports adequate for applicable test methods;

b. Safe sampling platfonns;

c. Safe access to sampling platforms; and

d. Utilities for sampling and testing equipment

9. The pennittee shall operate equipment, control apparatus and emission monitoringequipment within their design limitations. The pennittee shall maintain in goodcondition at all times equipment, control apparatus and emission monitoring equipment.[Regulation 19, §19.303 and/or Regulation 18, §18.1104 and A.C.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311]

10. If the permittee exceeds an emission limit established by this permit, the pennittee will bedeemed in violation of said pennit and will be subject to enforcement action. TheDepartment may forego enforcement action for emissions exceeding any limitsestablished by this pennit provided the following requirements are met: [Regulation 19,§19.601 and/or Regulation 18, §18.1101 and A.C.A. §8-4-203 as referenced by A.c.A.§8-4-304 and §8-4-311]

a. The pennittee demonstrates to the satisfaction of the Department that theemissions resulted from an equipment malfunction or upset and are not the resultof negligence or improper maintenance, and the pennittee took all reasonablemeasures to immediately minimize or eliminate the excess emissions.

b. The pennittee reports the occurrence or upset or breakdown of equipment (bytelephone, facsimile, or overnight delivery) to the Department by the end of thenext business day after the occurrence or the discovery of the occurrence.

c. The permittee must submit to the Department, within five business days after theoccurrence or the discovery of the occurrence, a full, written report of suchoccurrence, including a statement of all known causes and of the scheduling and

23


nature of the actions to be taken to minimize or eliminate future occurrences,including, but not limited to, action to reduce the frequency of occurrence of suchconditions, to minimize the amount by which said limits are exceeded, and toreduce the length of time for which said limits are exceeded. If the information isincluded in the initial report, the information need not be submitted again.

11. The permittee shall allow representatives of the Department upon the presentation ofcredentials: [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-3Il]

a. To enter upon the permittee's premises, or other premises under the control of thepermittee, where an air pollutant source is located or in which any records arerequired to be kept under the terms and conditions of this permit;

b. To have access to and copy any records required to be kept under the terms andconditions of this permit, or the Act;

c. To inspect any monitoring equipment or monitoring method required in thispermit;

d. To sample any emission ofpollutants; and

e. To perform an operation and maintenance inspection of the permitted source.

12. The Department issued this permit in reliance upon the statements and presentationsmade in the permit application. The Department has no responsibility for the adequacy orproper functioning of the equipment or control apparatus. [A.C.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-3ll]

13. The Department may revoke or modify this permit when, in the judgment oftheDepartment, such revocation or modification is necessary to comply with the applicableprovisions of the Arkansas Water and Air Pollution Control Act and the regulationspromulgated the Arkansas Water and Air Pollution Control Act. [Regulation 19,§19.41O(A) and/or Regulation 18, §18.309(A) and A.C.A. §8-4-203 as referenced byA.C.A. §8-4-304 and §8-4-3l1]

14. This permit may be transferred. An applicant for a transfer must submit a written requestfor transfer of the permit on a form provided by the Department and submit the disclosurestatement required by Arkansas Code Annotated §8-I-106 at least thirty (30) days inadvance of the proposed transfer date. The permit will be automatically transferred to thenew permittee unless the Department denies the request to transfer within thirty (30) daysof the receipt of the disclosure statement. The Department may deny a transfer on thebasis of the information revealed in the disclosure statement or other investigation or,deliberate falsification or omission of relevant information. [Regulation 19, §19.407(B)and/or Regulation 18, §18.307(B) and A.C.A. §8-4-203 as referenced by A.C.A. §8-4304 and §8-4-311]

15. This permit shall be available for inspection on the premises where the control apparatusis located. [A.C.A. §8-4-203 as referenced by A.C.A. §8-4-304 and §8-4-3ll]

24

Kinder Morgan Operating LP - "c" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012

16. This permit authorizes only those pollutant emitting activities addressed herein. [A.C.A.§8-4-203 as referenced by AC.A §8-4-304 and §8-4-311]

17. This permit supersedes and voids all previously issued air permits for this facility.[Regulation 18 and 19 and AC.A §8-4-203 as referenced by AC.A. §8-4-304 and §8-4311]

18. The pemlittee must pay all permit fees in accordance with the procedures established inRegulation No.9. [AC.A §8-1-105(c)]

19. The permittee may request in writing and at least 15 days in advance of the deadline, anextension to any testing, compliance or other dates in this permit. No such extensions areauthorized until the permittee receives written Department approval. The Departmentmay grant such a request, at its discretion in the following circumstances:

a. Such an extension does not violate a federal requirement;

b. The permittee demonstrates the need for the extension; and

c. The permittee documents that all reasonable measures have been taken to meetthe current deadline and documents reasons it cannot be met.

[Regulation 18, §18.l02(C-D), Regulation 19, §19.103(D), A.C.A §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311, and CFR Part 52, Subpart E]

20. The permittee may request in writing and at least 30 days in advance, temporaryemissions and/or testing that will otherwise exceed an emission rate, throughputrequirement, or other limit in this permit. No such activities are authorized until thepermittee receives written Department approval. Any such emissions shall be included inthe facilities total emissions and reported as such. The Department may grant such arequest, at its discretion under the following conditions:

a. Such a request does not violate a federal requirement;

b. Such a request is temporary in nature;

c. Such a request will not result in a condition of air pollution;

d. The request contains such information necessary for the Department to evaluatethe request, including but not limited to, quantification of such emissions and thedate/time such emission will occur;

e. Such a request will result in increased emissions less than five tons of anyindividual criteria pollutant, one ton of any single HAP and 2.5 tons of totalHAPs; and

f. The permittee maintains records of the dates and results of such temporaryemissions/testing.

[Regulation 18, §18.l02(C-D), Regulation 19, §19.103(D), AC.A. §8-4-203 asreferenced by A.C.A. §8-4-304 and §8-4-311, and CFR Part 52, Subpart E]

25

Kinder Morgan Operating LP - "c" - Blytheville TerminalPennit #: 0232-AR-llAFIN: 47-00012

21. The permittee may request in writing and at least 30 days in advance, an alternativeto the specified monitoring in this permit. No such alternatives are authorized until thepermittee receives written Department approval. The Department may grant such arequest, at its discretion under the following conditions:

a. The request does not violate a federal requirement;

b. The request provides an equivalent or greater degree of actual monitoring to thecurrent requirements; and

c. Any such request, if approved, is incorporated in the next permit modificationapplication by the permittee.

[Regulation 18, §18.l02(C-D), Regulation19, §19.103(D), A.C.A. §8-4-203 as referencedby A.C.A. §8-4-304 and §8-4-311, and CFR Part 52, Subpart E]

26

APPENDIX A

Maximum Allowable H2S Emission Rates for Sulfur Block Forming Operations

Table 1-12Effects of the Height of Release for Sulfur Block Forming Operations on thePlacement of Operations. Estimation of Maximum Allowable Emission Rates.

Modeled Emission Rate 1.0 Ib/hr; Height of Release 40 feet

Source Source Group Individual Individual Volume Delta Original Target Off-Site Maximum AllowableGroup ID Concentration Volume Source Source of Emission H2S H2S Emission Rate

(J1g1m3) ID Concentration Concentrations Rate (lbslbr) Concentration (Ibslbr)

(J1g1m3) (J1g1ro3)

GIA 44.54605 IA 11.83683 32.709 1.0 121.5 7.501GIB 43.80576 IB 11.80378 32.002 1.0 121.5 7.582GlC 43.80555 1C 11.02661 32.779 1.0 121.5 8.046G10 43.8049 10 11.5981 32.207 1.0 121.5 7.699GlE 43.8045 IE 10.94332 32.861 1.0 121.5 8.100GlF 43.80428 IF 11.88442 31.920 1.0 121.5 7.538G2A 44.47316 2A 11.59308 32.880 1.0 121.5 7.644G2B 43.80619 2B 11.7887 32.017 1.0 121.5 7.591G2C 43.80552 2C 10.68433 33.121 1.0 121.5 8.272G2D 43805 2D 11.43444 32.371 1.0 121.5 7.795G2E 43.80471 2E 11.86052 31.944 1.0 121.5 7.551G2F 43.80447 2F 11.8631 31.941 1.0 121.5 7.549G3A 44.41599 3A 11.35793 33.058 1.0 121.5 7.787G3B 43.80625 3B 11.3292 32.477 1.0 121.5 7.858G3C 43.80561 3C 11.15786 32.648 1.0 121.5 7.963G3D 43.80531 3D 10.99444 32.811 1.0 121.5 8.067G3E 43.80507 3E 11.28953 32.516 1.0 121.5 7.882G3F 43.80465 3F 11.60986 32.195 LO 121.5 7.692G4A 44.35632 4A 11.11777 33.239 1.0 121.5 7.939G4B 43.80626 4B 10.64329 33.163 1.0 121.5 8.300G4C 43.806 4C 10.84361 32.962 1.0 121.5 8.165G4D 43.80572 4D 10.98493 32.821 1.0 121.5 8.073G4E 43.80545 4E 11.59309 32.212 1.0 121.5 7.702G4F 43.80485 4F 12.1504 31.654 1.0 121.5 7.394GSA 44.26066 5A 12.66381 31.597 1.0 121.5 7.099G5B 43.80672 5B 12.30707 31.500 1.0 121.5 7.313G5C 43.80643 5C 11.72655 32.080 1.0 121.5 7.625G5D 43.80606 50 11.47373 32.332 1.0 121.5 7.771G5E 43.80574 5E 11.40763 32.398 1.0 121.5 7.811G5F 43.89614 5F 10.91415 32.982 1.0 121.5 8.110G6A 44.15707 6A 11.12128 33.036 1.0 121.5 7.954G6B 43.80722 6B 10.83963 32.968 1.0 121.5 8.167G6C 43.80691 6C 10.6588 33.148 1.0 121.5 8.289G6D 43.80599 6D 10.09275 33.713 1.0 121.5 8.698G6E 43.86143 6E 10.2648 33.597 1.0 121.5 8.564G6F 43.97418 6F 10.73078 33.243 1.0 121.5 8.225G7A 44.04542 7A 10.24766 33.798 1.0 121.5 8.558G7B 43.80774 7B 10.36856 33.439 1.0 121.5 8.493G7C 43.8074 7C 10.10595 33.701 LO 121.5 8.688G7D 43.8064 7D 10.74956 33.057 1.0 121.5 8.228G7E 44.01202 7E 11.40154 32.610 1.0 121.5 7.796G7F 43.89571 7F 11.69662 32.199 1.0 121.5 7.635G8A 43.92568 8A 10.04488 33.881 1.0 121.5 8.723G8B 43.80831 8B 10.76226 33.046 1.0 121.5 8.219G8C 43.80791 8C 11.22123 32.587 1.0 121.5 7.924G8D 43.99567 8D 11.23655 32.759 1.0 121.5 7.898G8E 44.0078 8E 12.28329 31.725 1.0 121.5 7.309G8F 43.8056 8F 12.91207 30.894 1.0 121.5 7.017G9A 43.8092 9A 12.65222 31.157 1.0 121.5 7.140G9B 43.80841 9B 12.13956 31.669 1.0 121.5 7.400G9C 43.92852 9C 12.09134 31.837 1.0 121.5 7.415G9D 44.08806 9D 12.36088 31.727 1.0 121.5 7.263

G9E 43.83918 9E 12.22032 31.619 1.0 121.5 7.355G9F 43.80576 9F 11.68233 32.123 1.0 121.5 7.651

GlOA 43.80972 lOA 11.72554 32.084 1.0 121.5 7.626

GlOB 43.82959 lOB 11.62148 32.208 1.0 121.5 7.683GlOC 44.13027 10C 11.48011 32.650 1.0 121.5 7.739G10D 44.00483 10D 10.99201 33.013 1.0 121.5 8.050

AVIA Environmental. LLCMay 2009

Page 1 00 DEVCO - Blytheville FacilityModeling Results Heights, DSP-IO-40 Rslts

1111111111111111111111111111111111111111111111111111111111111111111111111111

Table 1-12Effects of the Height of Release for Sulfur Block Forming Operations on thePlacement of Operations. Estimation of Maximum Allowable Emission Rates.

Modeled Emission Rate 1.0 Ib/hr; Height of Release 40 feet

Source Source Group Individual Individnal Volume Delta Original Target Off-Site Maximum AllowableGroup ID Concentration Volume Source Source of Emission H2S H2S Emission Rate

(Jiglm3) ID Concentration Concentrations Rate (Ibslhr) Concentration (lbslhr)(Jiglm3) (Jiglrn3)

G10E 43.80659 IOE 10.58742 33.219 1.0 121.5 8.338GlOF 43.80592 IOF 11.8481 31.958 1.0 121.5 7.558GilA 43.81029 IIA 11.01594 32.794 1.0 121.5 8.052GlIB 44.11763 liB 10.31686 33.801 1.0 121.5 8.501GIIC 44.14101 IIC 11.02946 33.112 1.0 121.5 8.014GIlD 43.80743 lID 11.87573 31.932 1.0 121.5 7.542GIIE 43.80679 liE 12.58611 31.221 1.0 121.5 7.173GIIF 43.80633 IIF 13.00374 30.803 1.0 121.5 6.975G12A 44.04358 12A 11.10766 32.936 1.0 121.5 7.973G12B 44.26051 12B 11.58279 32.678 1.0 121.5 7.668G12C 43.96814 12C 12.08372 31.884 1.0 121.5 7.416G120 43.80775 120 12.23598 31.572 1.0 121.5 7.349G12E 43.80725 12E 13.48124 30.326 1.0 121.5 6.763Gl2F 43.80676 12F 14.44799 29.359 1.0 121.5 6.377G13A 44.29947 13A 11.62352 32.676 1.0 121.5 7.642G13B 44.16455 13B 12.1494 32015 1.0 121.5 7.365G13C 43.80884 13C 13.07653 30.732 1.0 121.5 6.941G130 43.80828 130 13.63477 30.174 1.0 121.5 6.698G13E 43.80773 13E 13.74773 30.060 1.0 121.5 6.651G13F 43.80719 13F 13.40941 30.398 1.0 121.5 6.794G14A 44.32846 14A 12.60846 31.720 1.0 121.5 7.121Gl4B 43.84909 14B 12.87096 30.978 1.0 121.5 7.033Gl4C 43.80895 14C 12.53144 31.278 1.0 121.5 7.200Gl40 43.8083 140 12.10716 31.701 1.0 121.5 7.417Gl4E 43.80771 14E 11.46838 32.339 1.0 121.5 7.774Gl4F 43.80714 14F 12.86956 30.938 1.0 121.5 7.037G15A 44.1057 15A 11.80762 32.298 1.0 121.5 7.555Gl5B 43.81033 15B 11.37692 32.433 1.0 121.5 7.829GI5C 43.80924 15C 11.55806 32.251 1.0 121.5 7.722G150 43.80853 150 12.70716 31.101 1.0 121.5 7.114G15E 43.80788 15E 13.59021 30.218 1.0 121.5 6.717Gl5F 43.80728 15F 14.0563 29.751 1.0 121.5 6.527Gl6A 43.81139 16A 11.60504 32.206 1.0 121.5 7.694Gl6B 43.81057 16B 12.45103 31.360 1.0 121.5 7.240Gl6C 43.80979 16C 13.00172 30.808 1.0 121.5 6.975G160 43.8089 160 13.08748 30.721 1.0 121.5 6.936G16E 43.80814 16E 13.50673 30.301 1.0 121.5 6.752G16F 43.80758 16F 14.56753 29.240 1.0 121.5 6.333G17A 43.81206 17A 12.35882 31.453 1.0 121.5 7.286G17B 43.81115 17B 12.36953 31.442 1.0 121.5 7.281G17C 43.8103 17C 13.16149 30.649 1.0 121.5 6.903Gl70 43.80903 170 13.78434 30.025 1.0 121.5 6.636Gl7E 43.80812 17E 13.97569 29.832 1.0 121.5 6.559Gl7F 43.80766 17F 13.71012 30.098 1.0 121.5 6.667G18A 43.83804 18A 12.71825 31.120 1.0 121.5 7.106Gl8B 43.8112 18B 13.05991 30.751 1.0 121.5 6.949Gl8C 43.81027 18C 13.04479 30.765 1.0 121.5 6.956Gl80 43.80938 180 12.69526 31.114 1.0 121.5 7.120GI8E 43.80859 18E 12.07841 31.730 1.0 121.5 7.432Gl8F 43.80784 18F 12.88524 30.923 1.0 121.5 7.030Gl9A 43.88798 19A 12.24666 31.641 1.0 121.5 7.337G19B 43.81186 19B 11.85801 31.954 1.0 121.5 7.552Gl9C 43.81084 19C 11.58757 32.223 1.0 121.5 7.705Gl90 43.8099 190 12.77553 31.034 1.0 121.5 7.081G19E 43.80902 19E 13.66477 30.144 1.0 121.5 6.685Gl9F 45.24524 19F 14.13511 31.110 1.0 121.5 6.395G20A 43.93258 20A 11.65253 32.280 1.0 121.5 7.657G20B 43.81207 20B 12.50272 31.309 1.0 121.5 7.214

AVIA Environmental, LLCMay 2009

Page 20f3 DEVCO - Blytheville FacilityModeling Results Heights, DSP-10-40 Rslts

Table 1-12Effects of the Height of Release for Sulfur Block Forming Operations on the

Placement of Operations. Estimation of Maximum Allowable Emission Rates.Modeled Emission Rate 1.0 Ib/hr; Height of Release 40 feet

Source Source Group Individual Individual Volume Delta Original Target Off-Site Maximum AllowableGroup ID Concentration Volume Source Source of Emission H2S H2S Emission Rate

(Jlglm3) lD Concentration Concentrations Rate (Ibs/br) Concentration (Ibs/br)("glm3) ("glm3)

G20C 43.81096 20C 13.05655 30.754 1.0 121.5 6.950G20D 44.0443 200 13.25113 30.793 1.0 121.5 6.845G20E 45.64279 20E 14.08956 31.553 1.0 121.5 6.384G20F 47.38504 20F 14.58896 32.796 1.0 121.5 6.080G21A 43.97826 21A 12.45522 31.523 1.0 121.5 7.224G2IB 43.81243 21B 12.80894 31.003 1.0 121.5 7.065G21C 44.38274 21C 13.40113 30.982 1.0 121.5 6.755G2ID 46.12879 2ID 13.59795 32.531 1.0 121.5 6.543G21E 47.92789 21E 13.38514 34.543 1.0 121.5 6.497G21F 49.30291 21F 12.81187 36.491 1.0 121.5 6.635G22A 44.02658 22A 12.755 31.272 1.0 121.5 7.074G22B 44.82619 22B 12.75749 32.069 1.0 121.5 7.010G22C 46.7522 22C 12.45483 34.297 1.0 121.5 7.002G220 48.5989 22D 12.1235 36.475 1.0 121.5 7.013G22E 49.81885 22E 13.25743 36.561 1.0 121.5 6.407G22F 50.10328 22F 12.41195 37.691 1.0 121.5 6.752G23A 45.35365 23A 12.15625 33.197 1.0 121.5 7.264G23B 47.46195 23B 12.25525 35.207 1.0 121.5 7.041G23C 49.27229 23C 11.14027 38.132 1.0 121.5 7.483G23D 50.22744 23D 12.26015 37.967 1.0 121.5 6.813G23E 50.12759 23E 13.56391 36.564 1.0 121.5 6.262G23F 49.12215 23F 13.6012 35.521 1.0 121.5 6.321G24A 48.26477 24A 11.5273 36.737 1.0 121.5 7.353G24B 50.00043 24B 13.10124 36.899 1.0 121.5 6.457G24C 50.33868 24C 12.23792 38.101 1.0 121.5 6.815G24D 49.70906 240 12.59716 37.112 1.0 121.5 6.699G24E 48.45877 24E 13. 27561 35.183 1.0 121.5 6.502G24F 46.7719 24F 14.66179 32.110 1.0 121.5 6.097G25A 50.42088 25A 11.72908 38.692 1.0 121.5 7.060G25B 50.50594 25B 13.12133 37.385 1.0 121.5 6.411G25C 49.32084 25C 13.6389 35.682 1.0 121.5 6.292G250 47.57788 250 12.14373 35.434 1.0 121.5 7.087G25E 45.9753 25E 12.47156 33.504 1.0 121.5 7.056G25F 44.51793 25F 14.67851 29.839 1.0 121.5 6.245G26A 50.35826 26A 11.89586 38.462 1.0 121.5 6.980G26B 48.67863 26B 11.97703 36.702 1.0 121.5 7.080G26C 47.039 26C 14.43762 32.601 1.0 121.5 6.157G260 45.30566 260 13.38614 31.920 1.0 121.5 6.692G26E 43.88504 26E 12.24348 31.642 1.0 121.5 7.339G26F 43.82296 26F 13.03233 30.791 1.0 121.5 6.960G27A 48.3633 27A 12.34035 36.023 1.0 121.5 6.927G27B 46.38317 27B 11.96053 34.423 1.0 121.5 7.280G27C 44.59717 27C 13.97796 30.619 1.0 121.5 6.502G27D 43.98792 270 15.16824 28.820 1.0 121.5 6.110G27E 43.96779 27E 12.72354 31.244 1.0 121.5 7.094G27F 43.95041 27F 13.1514 30.799 1.0 121.5 6.897G28A 45.69775 28A 13.75652 31.941 1.0 121.5 6.510G28B 45.38531 28B 13.1146 32.271 1.0 121.5 6.804G28C 45.13668 28C 12.6975 32.439 1.0 121.5 7.014G280 44.93645 28D 15.78764 29.149 1.0 121.5 5.850G28E 44.77341 28E 14.89404 29.879 1.0 121.5 6.151G28F 44.63934 28F 13.51005 31.129 1.0 121.5 6.689G29A 49.54663 29A 15.14235 34.404 1.0 121.5 5.752G29B 48.77387 29B 13.37607 35.398 1.0 121.5 6.437G29C 48.1035 . 29C 13.27858 34.825 1.0 121.5 6.527G29D 47.52649 290 14.55175 32.975 1.0 121.5 6.083G29E 47.02836 29E 16.91659 30.112 1.0 121.5 5.402G29F 46.60281 29F 13.82857 32.774 1.0 121.5 6.416

Minimum Allowable Emission Rate for Sulfur Block Forming Operations within the Specified Area 5.402Maximum Allowable Emission Rate for Sulfur Block Forming Operations within the Specified Area 8.723

A VIA Environmental, LLCMay 2009

Page 30f3 DEVCO· Blytheville FacilityModeling Results Heights, DSP-JO-40 Rslts

CERTIFICATE OF SERVICE

I, Pam Owen, hereby certify that a copy of this permit has been mailed by first class mail to

Kinder Morgan Operating LP - "e" - Blytheville Terminal, 6162 State Hwy 18 East, Blytheville,

AR, 72315, on this ..sO+h day of~UJ,_~ ,2009.

Pam Owen, AAII, Air Division

response to comments kinder morgan operating lp -c ... · response to comments kinder morgan...

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