Response to Comments Kinder Morgan Operating LP - "C" - Blytheville Terminal Permit #: 0232-AR-ll AFIN: 47-00012 On, May 11, 2008 the Director of the Arkansas Department of Environmental Quality gave notice of a draft permitting decision for the above referenced facility. During the comment period, one interested party submitted written comments, data, views, or arguments on the draft permitting decision. The Department's response to these issues is as follows: Comment #1: Facility has requested to increase the monolithic blockpour height to a maximum of 40 ft from the 20ft height limitation in the draft permit. This modeling data substantiates that modeledfence line H2S exposures decrease (i.e., maximum allowable emissions rates increase) significantly for all block locations as the blockpouring height increasesfrom 20 It to 40ft· The facility will observe the maximum emission rates established in Appendix A for the 20ft blockform height for elevations above 20ft and to a maximum elevation of 40 ft. Response #1: The maximum block height has been increased to 40 ft as requested.
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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
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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
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).
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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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-11AFIN: 47-00012
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]
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-11AFIN: 47-00012
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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-11AFIN: 47-00012
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]
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Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
[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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
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
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Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
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
Kinder Morgan Operating LP - "C" - Blytheville TerminalPermit #: 0232-AR-llAFIN: 47-00012
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)
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)
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
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,