INFORMATION RELATIVE TO 
THE DRAFT TITLE V OPERATING PERMIT
February 21, 2022

GENERAL FACILITY INFORMATION
Facility Name:  Colonial Pipeline Company, Collins Complex
Facility Address:  35 Pump Station Road, Collins, MS 39428    
County: Covington
SIC Code(s): 4613
NAICS Code(s): 486910  

APPLICATION SUMMARY 
Permit No.: 0640-00013
Permit Action:  Renewal with Minor Modification
Permit Folder: PER20210002
Application Receipt Date: 10/22/2021
Application Deemed Complete: 
CBI Submitted?: No	NSPS (Part 60): A, Ka, JJJJ
NESHAP (Part 61): N/A
NESHAP (Part 63): A, ZZZZ, BBBBBB, 
112(r) / RMP: No
Other: N/A	

FACILITY DESCRIPTION
Colonial Pipeline Company owns and operates a petroleum liquids pipeline breakout complex in Collins, Mississippi.  The Collins Complex consists of three facilities. The main facility, referred to as the Collins Tank Farm, receives gasoline and fuel oil products via a direct pipeline from two petroleum refineries south of the site for storage prior to injection into the Colonial main pipelines for distribution to the eastern half of the United States. The Collins Tank Farm currently consists of eight gasoline storage tanks, two pressure relief and/or transmix storage tanks, four fuel oil storage tanks, and a loading rack to offload transmix into trucks. The second facility at the Collins Complex is the Collins Injection Station, which includes three smaller storage tanks. Two of the tanks are utility tanks used for maintenance activities and one of the tanks is for pressure relief of the injection manifold, as well as the main Colonial pipelines. The third facility is referred to as Kola Station. The Kola Station has one utility tank and ancillary equipment.  The facility’s emission sources are tabulated below.

Emission Point	Description	
IA	Insignificant Activities	
AA-000	Leaks from Equipment in Gasoline Service	
AA-001	6,076,686 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2065)	
AA-002	4,983,132 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2066)	
AA-003	4,512,018 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2067)	
AA-004	7,046,004 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2068)	
AA-005	8,353,506 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2074)	
AA-006	4,971,624 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2076)	
AA-007	64,176 Gallon Refined Petroleum Fuels (Including Transmix but Excluding Gasoline) Pressure Relief Tank with Internal Floating Roof (Facility Ref.: Tank No. 2072)	
AA-008	101,388 Gallon Refined Petroleum Fuels (Including Transmix but Excluding Gasoline) Pressure Relief Tank with Internal Floating Roof (Facility Ref.: Tank No. 2073)	
AA-009	7,190,946 Gallon Refined Petroleum Fuels (Excluding Gasoline) Storage Tank with Fixed Roof (Facility Ref.: Tank No. 2069)	
AA-010	9,256,044 Gallon Refined Petroleum Fuels (Excluding Gasoline) Storage Tank with Fixed Roof (Facility Ref.: Tank No. 2070)	
AA-011	7,833,798 Gallon Refined Petroleum Fuels (Excluding Gasoline) Storage Tank with Fixed Roof (Facility Ref.: Tank No. 2071)	
AA-012	7,218,750 Gallon Refined Petroleum Fuels (Excluding Gasoline) Storage Tank with Fixed Roof (Facility Ref.: Tank No. 2075)	
AA-013	7,792,680 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2083)	
AA-014	7,807,380 Gallon Refined Petroleum Fuels (Including Gasoline) Storage Tank with Internal Floating Roof (Facility Ref.: Tank No. 2084)	
AA-015	126,000 Gallon Refined Petroleum Fuels (Including Transmix but Excluding Gasoline) Pressure Relief Tank with Internal Floating Roof (Facility Ref.: Tank No. 5043)	
AA-016	18,204 Gallon Refined Petroleum Fuels (Including Transmix but Excluding Gasoline) Storage Tank with Fixed Roof (Facility Ref.: Tank No. 5040)	
AA-017	26,250 Gallon Refined Petroleum Fuels (Including Transmix but Excluding Gasoline) Storage Tank with Fixed Roof (Facility Ref.: Tank No. 5048)	
AA-018	18,204 Gallon Refined Petroleum Fuels (Including Transmix but Excluding Gasoline) Storage Tank with Fixed Roof (Facility Ref.: Tank No. 5060)	
AA-019	134.1 Horsepower (HP) (0.939 MMBtu/hr) diesel fired compression ignition (CI) emergency backup generator engine (Facility Ref.: Collins Tank Farm Emergency Diesel Generator)	
AA-021	26.8 HP (0.188 MMBtu/hr) propane fired spark ignition (SI) four stroke lean burn (4SLB) emergency backup generator engine (Facility Ref.: Collins Injection Emergency Propane Generator)	
AA-024	80 HP (0.563 MMBtu/hr) propane fired SI 4SLB emergency backup generator engine (Facility Ref.: Collins Tank Farm Emergency Propane Generator)	
AA-025	Transmix Truck Loading Rack	
AA-031	Tank Cleaning Process	
AA-032	43.4 HP (0.304 MMBtu/hr) propane fired SI 4SLB emergency backup generator engine (Facility Ref.: Kola Booster Station Emergency Generator)	

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 the criteria air pollutant 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 since the facility has taken a limit of 24.9 .

Facility-Wide Potential-to-Emit Summary1
Pollutant	PTE Emissions (tons/yr)	
Particulate Matter (TSP)	Data not provided	
PM10	1.00	
PM2.5	1.00	
Sulfur Dioxide (SO2)	1.00	
Nitrogen Oxides (NOx)	3.00	
Carbon Monoxide (CO)	1.00	
Volatile Organic Compounds (VOC)	236.00	
Total Reduced Sulfur (TRS)	0	
Lead	0	
CFC/HCFC	0	
Total HAP 	24.9	
1 The PTE emissions reflect any emission limits or enforceable restrictions included in the proposed permit.

PREVENTION OF SIGNIFICANT DETERIORATION (PSD) APPLICABILITY
The potential emissions of VOC from the existing equipment at the facility is restricted to 236 tpy and hence the facility is considered as an existing moderate source for PSD purposes. This permitting action is to renew the Title V Operating permit and as such does not change the PSD status of the facility.

FACILITY MODIFICATIONS AND/OR PERMIT CHANGES
Numerous changes have been made to the conditions of this draft permit.  Physical modifications at the facility include the following:
•	Removal of five (5) tanks (Emission Points AA-026 through AA-030) previously permitted but never constructed,
•	Removal of two (2) skid tanks (Emission Points AA-022 and AA-023) no longer located at the facility,
•	Removal of NESHAP CCCCCC provisions due to the removal of Emission Points AA-022 and AA-023,
•	Increase the number of allowable floating roof landings for the floating roof tanks in the permit from five (5) to ten (10) per year, and
•	Emissions estimates reconciliation for all storage tanks at the facility.

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.

There is no control equipment associated with any emission units subject to an emission limit or standard at this facility, so Compliance Assurance Monitoring does not apply.

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) APPLICABILITY

40 CFR 63 Subpart ZZZZ
The provisions of 40 CFR 63 Subpart ZZZZ - National Emissions Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE) regulates HAP emissions from RICE. 

Emission Point AA-019 is an existing spark ignition (SI) propane-fired emergency engine with a site rating less than 500 HP that is located at an area source of HAP emissions, and as such, is required to meet the applicable operational and scheduled maintenance requirements of 40 CFR 63 Subpart ZZZZ and the applicable General Provisions in 40 CFR Part 63, Subpart A.

Emission Points AA-021, AA-024, and AA-032 are new emergency stationary SI propane-fired engines, each with a site rating less than 500 HP that are located at an area source.  As such, each source must meet the requirements of Subpart ZZZZ by meeting the requirements of 40 CFR part 60 subpart JJJJ, for spark ignition engines. No further requirements apply for such engines under 40 CFR 63 Subparts ZZZZ or A.

40 CFR 63 Subpart BBBBBB
The provisions of 40 CFR 63 Subpart BBBBBB - National Emissions Standards for Hazardous Air Pollutants for Source Category: Gasoline Distribution Bulk Terminals, Bulk Plants, and Pipeline Facilities (NESHAP BBBBBB) establishes national emission limitations and management practices for hazardous air pollutants (HAP) emitted from area source gasoline distribution bulk terminals, bulk plants, and pipeline facilities. NESHAP BBBBBB also establishes requirements to demonstrate compliance with the emission limitations and management practices. 

The facility’s sources that are in gasoline service include Emission Points AA-001 through AA-006, AA-013, and AA-014, as well as, leaks from equipment in gasoline service (Emission Point AA-000).  Each source is subject to the emission limitations, monitoring, recordkeeping, and reporting requirements of NESHAP BBBBBB.

NEW SOURCE PERFORMANCE STANDARDS (NSPS) APPLICABILITY

40 CFR 60 SUBPART K
The provisions of 40 CFR 60 Subpart K - New Source Performance Standards for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification Commenced After June 11, 1973, and Prior to May 19, 1978 (NSPS K) are applicable to storage vessels for petroleum liquids which has a storage capacity greater than 151,412 liters (40,000 gallons).  

Emission Points AA-001 through AA-014 and AA-016 through AA-018 were constructed prior to the June 11, 1973, Subpart K effective date and are therefore not subject to the requirements of NSPS K.

For purposes of NSPS K, Ka, and Kb, a table is provided below with each tank’s year of construction, as provided by the permittee.

Source	Date	Source	Date	Source	Date	
AA-001	1971	AA-007	1971	AA-013	1972	
AA-002	1971	AA-008	1971	AA-014	1972	
AA-003	1971	AA-009	1971	AA-015	1981	
AA-004	1971	AA-010	1971	AA-016	1963	
AA-005	1971	AA-011	1971	AA-017	1972	
AA-006	1971	AA-012	1971	AA-018	1963	
 
 40 CFR 60 SUBPART Ka
The provisions of 40 CFR 60 Subpart Ka - New Source Performance Standards for Storage Vessels for Petroleum Liquids for Which Construction, Reconstruction, or Modification commenced After May 18, 1978, and Prior to July 23, 1984 (NSPS Ka) are applicable to storage vessels with a storage capacity greater than 151,416 liters (40,000 gallons) that is used to store petroleum liquids for which construction is commenced after May 18, 1978.  Emission Point AA-015 is an affected facility because it is a storage vessel with a storage capacity greater than 151,416 liters (40,000 gallons) that is used to store petroleum liquids for which construction was commenced after May 18, 1978.  Emission Point AA-015 is therefore subject to the floating roof requirements of NSPS Ka.   Emission Points AA-001 through AA-014 and AA-016 through AA-018 were constructed prior to the May 18, 1978 Subpart Ka effective date and are therefore not subject to the requirements of NSPS Ka.  

40 CFR 60 SUBPART Kb
The provisions of 40 CFR 60 Subpart Kb - New Source Performance Standards for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984 (NSPS Kb) are 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 is commenced after July 23, 1984.  Emission Points AA-001 through AA-018 were constructed prior to the July 23, 1984 Subpart Kb effective date and are therefore not subject to the requirements of NSPS Kb.

40 CFR 60 SUBPART JJJJ
The provisions of 40 CFR 60 Subpart JJJJ - New Source Performance Standards for Stationary Spark Ignition Internal Combustion Engines (NSPS JJJJ) are applicable to stationary spark ignition internal combustion engines that commenced construction, modification, or reconstruction after June 12, 2006.  Emission Points AA-021, AA-024, and AA-032, are stationary spark ignition internal combustion engines and were each constructed after the June 12, 2006, effective date.  Emission Point AA-021 is a 2010 model Cummins engine, Emission Point AA-024 is a 2013 model Cummins engine, and Emission Point AA-032 is a 2016 model Cummins engine.  Emission Points AA-021, AA-024, and AA-032, are subject to the emergency operational requirements of NSPS JJJJ and comply with the emission limitations as certified engines.  

SPECIFIC APPLICABLE REQUIREMENTS
The four (4) significant air emission combustion sources are subject to state standards for PM and Opacity. Emission Points AA-019, AA-021, AA-024, and AA-032, each have a particulate matter emission limitation of 0.6 lbs/MMBTU, because they each have a rated heat input less than 10 MMBTU/hr.  Since these units combust propane and the size of the units are small, no monitoring is proposed for the units.  There are no other applicable requirements for the facility’s other insignificant activities listed in their Title V application.

Emission Point No.	Pollutant/ Parameter	Draft Permit Emission Limits	Monitoring Requirements	
Facility-wide	VOC	236 tpy (12-month rolling basis)	Monitoring of operations	
	HAPs	9.9 tpy for each Individual HAP and 
24.9 tpy Total HAPs	Monitoring of operations	
AA-015	Operating Restriction	Operating Requirement	Monitoring of operations	
AA-000
AA-001
through
AA-006
AA-013
AA-014	Operating Restriction	Operating Requirement	Monitoring of operations	
AA-019
AA-021
AA-024
AA-032	PM
(filterable only)	0.6 lb/MMBTU, or as otherwise limited by facility modification restrictions	Record Type and Quantify of Fuel Used	
AA-007
AA-008
AA-015
through
AA-018	Operating Restriction	Operating Requirement	Monitoring of operations	
AA-025	Operating Restriction	Operating Requirement	Monitoring of operations	
AA-009
through
AA-012	Operating Restriction	Operating Requirement	Monitoring of operations	
AA-021
AA-024 AA-032	NOx + HC and CO	10 g/HP-hr NOx + HC and 387 g/HP-hr CO	Monitoring of operations	
AA-019
AA-021
AA-024 AA-032	Operating Restriction	Emergency Operational Requirements	Monitoring of operations	
AA-000
AA-001
through
AA-006
AA-013 AA-014	Operating Requirement	Minimizing Emissions	Monitoring of operations	
AA-019	Operating Requirement	Scheduled Maintenance Requirements	Monitoring of operations	
	Operating Requirement	Minimizing Emissions	Monitoring of operations	
	Operating Requirements	Operational Requirements	Monitoring of operations	
AA-021
AA-024
AA-032	Operating Requirement	Operational Requirement	Monitoring of operations	
Facility-wide	Operating Requirement	Minimizing Emissions	Monitoring of operations	
	Operating Requirement	Operational Requirements	Monitoring of operations	

OTHER REQUIREMENTS:
N/A