INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
August 5, 2026

GENERAL FACILITY INFORMATION
Facility Name:  Kinder Morgan Southeast Terminals LLC, Collins Terminal
Facility Address:  31 Kola Road, Collins, MS 39428    
County: Covington
SIC Code(s): 4226
NAICS Code(s): 493190

APPLICATION SUMMARY 
Permit No.: 0640-00024
Permit Action: Renewal
Permit Folder: PER20220001
Application Receipt Date: 
Application Deemed Complete:
CBI Submitted?: No	NSPS (Part 60): A, Kb, XX
NESHAP (Part 61): N/A
NESHAP (Part 63): A, BBBBBB
112(r) / RMP: Yes
Other: 	

FACILITY DESCRIPTION
Kinder Morgan owns and operates a bulk fuel storage terminal which has a standard industrial classification (SIC) code of 4226, for special warehousing and storage, not otherwise classified. The facility stores and transfers into cargo trucks gasoline (motor gas (MOGAS)), denatured ethanol, reformulated gasoline, petroleum distillate and gasoline additives. The following table contains the significant emission points at the facility. 

Emission Point	Description	
AA-001	604,588 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (mechanical shoe seal – built 1962) (Facility Ref. No. Tank #1)	
AA-002	403,709 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (vapor mounted seal – built 1962) (Facility Ref. No. Tank #2)	
AA-003	421,535 Gallon Fixed Roof Distillate Storage Tank (Facility Ref. No. Tank #3)	
AA-004	615,976 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (mechanical shoe seal – built 1962) (Facility Ref. No. Tank #4)	
AA-005	1,606,000 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (vapor mounted seal – built 1962) (Facility Ref. No. Tank #5)	
AA-006	10,000 Gallon Fixed Roof Additive Storage Tank (Facility Ref. No. Tank #6)	
AA-007	10,000 Gallon Fixed Roof Off Spec Product Storage Tank (Facility Ref. No. Tank #7)	
AA-008	10,000 Gallon Fixed Roof Additive Storage Tank (Facility Ref. No. Tank #8)	
AA-009	Truck Loading Rack Equipped with a VCU (includes three lanes each with two diesel loading arms, one ethanol loading arm and three gasoline loading arms)	
AA-010	4,000 Gallon Lubricity Additive Tank (Facility Ref. No. Tank #10)	
AA-011	3,415,146 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (mechanical shoe primary, rim mounted secondary – built 2005) (Facility Ref. No. Tank #9)	
AA-012	3,553,200 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (mechanical shoe primary, rim mounted secondary – built 2010) (Facility Ref. No. Tank #11)	
AA-013	Butane Unloading	
AA-014	250 Gallon Sample Return Tank (Facility Reference Number: Tank SRT, Formerly Tank #12)	
AA-015	250 Gallon Ethanol Day Tank (Facility Reference Number: Tank EDT, Formerly Tank #13)	
AA-016	10,000 gallon additive tank (Facility Reference: Tank #14)	
AA-017	Piping Fugitives includes leaks from Equipment in Gasoline Service (See 40 CFR 63.11100)	

TITLE V SOURCE APPLICABILITY 
The facility’s potential-to-emit (PTE) exceeds the Title V major source threshold of 100 tons per year (tpy) for Volatile Organic Compounds (VOC). The facility’s potential-to-emit hazardous air pollutants (HAPs) does not exceed the major source threshold of 25 tpy of total HAPs and 10 tpy for any individual HAP.

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	0.00	
PM10	0.00	
PM2.5	0.00	
Sulfur Dioxide (SO2)	0.00	
Nitrogen Oxides (NOx)	11.87	
Carbon Monoxide (CO)	57.91	
Volatile Organic Compounds (VOC)	244.09	
Total Reduced Sulfur (TRS)	0.00	
Lead	0.00	
CFC/HCFC	0.00	
Total HAP 	9.72	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The facility is not one of the 28 categorical facilities listed in 40 CFR 52.21(b)(1)(i)(a); therefore, the PSD threshold for a major source is 250 tpy.  The facility has the potential to emit more than 250 tpy of VOCs but will continue to limit facility-wide emissions of VOCs to less than 250 tpy; therefore, the facility is considered an existing minor PSD source.  This permitting action will not change the current PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
There are no physical modifications to the facility proposed as part of this permitting action. The applicable Part 63, National Emission Standard for Hazardous Air Pollutants (NESHAP), Subpart BBBBBB, was revised effective May 8, 2024, which made it necessary to add several new permit conditions to address the new requirements. The permittee requested that design requirements for IFR inspections for the older IFR gasoline storage tanks should be in accordance with 40 CFR 63 Subpart WW as allowed by Item 2.(e) of Table 1 of 40 CFR 63, Subpart BBBBBB. The permittee requested that for Emission Points AA-011 and AA-012 compliance with 40 CFR 60 Subpart Kb should be demonstrated by complying with 40 CFR 63 Subpart WW. The necessary Subpart WW requirements were added, and the Subpart Kb requirements were eliminated when allowed. In cases where Subpart BBBBBB requirements were more restrictive than 40 CFR 60 Subpart XX requirements, the Subpart BBBBBB, requirements were included in place of the Subpart XX requirements. The permit changes include the following:
•	A revised Condition 3.B.6 to include TOC limit of limit of 35 mg/L of gasoline loaded based on 40 CFR 63 Subpart BBBBBB and more stringent performance testing procedures in accordance with 40 CFR 60.503(a). The limit of 169.68 tpy of TOC for Emission Point AA-009 was removed since throughput limits are used to limit potential emissions.
•	New Condition 3.B.10 to add the requirements of 40 CFR 63 Subpart WW for Emission Points AA-011 and AA-012.
•	New Condition 3.B.11 which limits the concentration of gasoline vapor above each internal floating roof.
•	New work practice standard Condition 3.D.2 regarding the handling of gasoline to prevent spills/releases.
•	New work practice standard Condition 3.D.4 was added to incorporate the requirements of Subpart BBBBBB for truck loading after May 8, 2027.
•	New Condition 5.B.3 regarding records submitted electronically via CEDRI.
•	New Condition 5.B.4 to incorporate recordkeeping from Subpart WW.
•	New Condition 5.B.5 to incorporate tank inspection requirements in accordance with option 2(e) of Table 1, Subpart BBBBBB.
•	New Condition 5.B.6 to incorporate LEL monitoring for floating roof tanks.
•	New Condition 5.B.7 to incorporate recordkeeping requirements for LEL monitoring.
•	New Condition 5.B.9 to include recordkeeping for tanks subject to 40 CFR 60 Subpart Kb but complying under 40 CFR 63, Subpart WW.
•	New Condition 5.B.11 to require performance testing of the VCU no later than 180 days after May 8, 2027.
•	New Condition 5.B.12 to include changes to the annual certification testing of gasoline cargo tanks after May 8, 2027.
•	New Condition 5.B.13 to update recordkeeping requirements for cargo tanks under Subpart BBBBBB.
•	New Condition 5.B.16 to incorporate requirements for VCU monitoring after May 8, 2027.
•	New Condition 5.B.17 to incorporate operating requirements for the VCU under Subpart BBBBBB.
•	New Conditions 5.B.18 and 19 to incorporate recordkeeping requirements for the VCU.
•	New Conditions 5.B.21 and 22 to incorporate recordkeeping requirements under Subpart BBBBBB for cargo tanks loaded which did not have proper documentation or had incompatible vapor collection equipment.
•	New Condition 5.B.23 to include requirements for recordkeeping for deviations as required by Subpart BBBBBB.
•	New Condition 5.B.24 to incorporate recordkeeping requirements for CMS under Subpart BBBBBB.
•	New Condition 5.B.25 to incorporate recordkeeping requirements under Subpart BBBBBB for performance tests and evaluations.
•	New Condition 5.B.26 to include required performance testing conditions.
•	New Condition 5.B.30, which outlines the new Subpart BBBBBB requirements for leak detection monitoring. The new procedures are optional until May 8, 2027, and mandatory thereafter.
•	New Condition 5.B.31, which outlines new recordkeeping requirements for leak detection surveys conducted under Condition 5.B.30.
•	New Condition 5.C.1 was added to include the requirement for submittal of a notification of compliance status.
•	New Conditions 5.C.2 and 5.C.3 were added to include state requirements for submittal of notice and protocol for performance testing, and for submittal of test results. 
•	Condition 5.C.4 regarding semiannual reporting was modified to include a termination date of May 8, 2027.
•	New Condition 5.C.5 was added for semiannual reporting after May 8, 2027.
•	New Condition 5.C.6 was added regarding compliance reporting procedures.
•	New Condition 5.C.11 was added regarding electronic performance test reporting requirements.

COMPLIANCE ASSURANCE MONITORING (CAM) APPLICABILITY
40 CFR Part 64 specifies the requirements for CAM.  The general applicability of this rule can be found in 40 CFR 64.2 and requires a Title V source to comply with the CAM requirements if all three of the following criteria are met for a pollutant-specific emission unit (PSEU):

1.	The unit is subject to an emission limitation or standard for a regulated air pollutant other than exemptions under 40 CFR 64.2(b)(1);
2.	The unit uses a control device to comply with the standard; and
3.	The unit has pre-control emissions exceeding Title V major source threshold.

Emission Point AA-009 is a major source for VOCs and utilizes a vapor combustion unit to meet the 35 mg TOC/L gasoline loaded emission limit.  However, the unit is subject to National Emission Standards for Hazardous Air Pollutants (NESHAP), Part 63 Subpart BBBBBB (promulgated after November 15, 1990) which exempts the facility from CAM. 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY
The facility is an area source of Hazardous Air Pollutants (HAP) since the facility is limited to less than 25 tons per year of total HAPs and 10 tpy of any individual HAP.

40 CFR 63 Subpart R - National Emission Standards for Gasoline Distribution Facilities (Bulk Gasoline Terminals and Pipeline Breakout Stations)
The provisions of 40 CFR Part 63, Subpart R apply to bulk gasoline terminals that are Major Sources for HAP emissions. While the facility is a Bulk Gasoline Terminal, the facility is an area source; therefore, the facility is not subject to any requirements of 40 CFR Part 63, Subpart R.   

40 CFR 63 Subpart BBBBBB - National Emission Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities
The provisions of 40 CFR Part 63, Subpart BBBBBB establishes national emission limitations and management practices for HAPS emitted from area source gasoline distribution bulk terminals, bulk plants, and pipeline facilities. This subpart also establishes requirements to demonstrate compliance with the emission limitations and management practices.  Since the facility is an area source and is a Bulk Terminal, the facility is subject to the requirements of 40 CFR Part 63, Subpart BBBBBB.  

Emission limitations and operating requirements are included for the VCU controlling emissions from the truck loading operations and for the fixed roof and floating roof storage tanks in gasoline service. 

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 Subpart Kb - Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced after July 23, 1984
The provisions of NSPS Kb are standards applicable to storage vessels with a capacity greater than or equal to 75 cubic meters (m3) that is used to store volatile organic liquids (VOL) for which construction, reconstruction, or modification commenced after July 23, 1984.  Emission Points AA-011 and AA-012 are subject to the requirements of NSPS Kb.  Emission Point AA-011 is a 3,415,146 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (mechanical shoe primary, rim mounted secondary – built 2005) (Facility Ref. No. Tank #9).  Emission Point AA-012 is a 3,553,200 Gallon Internal Floating Roof Gasoline (MOGAS), Denatured Ethanol, or Distillate Storage Tank (mechanical shoe primary, rim mounted secondary – built 2010) (Facility Ref. No. Tank #11). 

The facility has requested to comply with Subpart Kb by complying with 40 CFR 63 Subpart WW as allowed with certain conditions by 40 CFR 60.110b(e)(5). This option allows the inspection of  each IFR while storing gasoline, thus avoiding the expense of emptying the tank solely for the purpose of conducting an inspection.

Each of the facility’s remaining storage tanks are exempt from the requirements of NSPS Kb, based on tank size, construction date, or vapor pressure requirements for the stored liquid products.  

40 CFR 60 Subpart XX - Standards of Performance for Bulk Gasoline Terminals
The provisions of NSPS XX apply to the loading racks at a bulk gasoline terminal which deliver liquid product into gasoline tank trucks for which construction or modification commenced after December 17, 1980, and On or Before June 10, 2022.  Emission Point AA-009 is a Truck Loading Rack Equipped with a VCU.  The rack includes three lanes each with two diesel loading arms, one ethanol loading arm, and three gasoline loading arms.  Emission Point AA-009 is subject to a TOC emission limitation of ≤ 35 mg TOC/L gasoline loaded as well as operational and design requirements. The emission limit of ≤ 35 mg TOC/L gasoline loaded under 40 CFR 63, Subpart BBBBBB is more stringent due to the updated testing procedures, therefore compliance with the Subpart BBBBBB limit also demonstrates compliance with the Subpart XX limit.

SPECIFIC APPLICABLE REQUIREMENTS
There are no other applicable requirements for the facility’s other insignificant activities listed in their Title V application.

Emission Point No.	Pollutant	Draft Permit Emission Limits	Monitoring Requirements	
Facility-wide	VOC	Product throughput limitations	Maintain monthly records of the throughputs of each product.	
AA-009	HAP	TOC ≤ 35 mg TOC/L gasoline loaded 	Stack test once per permit term. Maintain and operate a continuous parameter monitoring system at all times. 	
		Loading rack design and operating requirements	Load gasoline into cargo tanks with documentation of testing for vapor tightness.	
AA-001 AA-002 AA-004 AA-005 AA-011 AA-012	HAP	Install a fixed roof in combination with an internal floating roof with a mechanical shoe primary seal 	Routine inspections of the internal floating roof.	
		Concentration of gasoline vapor above the IFR limited to at or below 25 percent of the LEL	Performance testing each  year.	
AA-017	HAP	Equipment Leaks	Periodic inspections of all equipment in gasoline service with  repair and recordkeeping/reporting requirements.	

OTHER REQUIREMENTS:
None.