August 16, 2010

Stephen A. Shedd

U.S. Environmental Protection Agency

109 T.W. Alexander Drive

Mail Code: E143-01

Research Triangle Park, NC 27709

 RE: Ongoing API Work to Review and Correct As Necessary Data on Four Marine 

Vessel Loading Facilities

Dear Steve: 

In advance of our call today on the Marine Vessel Loading Risk and Technology Review Rule, I 

wanted to give you a brief update on our efforts to review and correct as necessary source and 

emission data for the following four marine vessel loading facilities:

TransMontaigne (Coastal Terminals in the NEI), Fort Lauderdale, FL

TX Petrochemical, Houston, TX

Kinder Morgan (Pasadena Terminal and Galena Park Terminal in the NEI), Galena Park, 

TX

Unocal/Chevron (Unocal in the NEI), Nederland, TX

We understand from prior communications that EPA’s preliminary risk analyses indicated that 

these four facilities may have a 70-year cancer maximum individual risk (MIR) over 1 in a 

million for marine vessel loading operations. As a result, EPA has sought additional information 

about these four facilities, including site visits to each.

We very much appreciate EPA’s efforts to review and confirm the data used to characterize these 

facilities in EPA’s risk analyses. To contribute to that effort, API has retained ENVIRON to 

provide assistance to API in reviewing source and emission data at the four facilities and to work 

with facility staff to ensure that data are correct and accurately represent current facility 

operations.

Matthew Todd

Policy Advisor

Regulatory and Scientific Affairs

1220 L Street, NW

Washington, DC 20005-4070

USA

Telephone 202-682-8319

Fax 202-682-8270

Email toddm@api.org

www.api.org
That effort is on-going and is not yet complete. However, an initial review of 2005 NEI source 

and emission data for the four facilities has been done, the results of which are provided with this 

letter. In a series of figures, 2005 NEI emission release points are plotted on aerial photo images 

of each facility. Emission release points are identified by ID number, geographical location, and 

MACT code. 

As evident in the figures, there appear to be potentially important data errors in the NEI that 

could cause EPA’s preliminary risk analyses to calculate inaccurate and overstated risk. For 

example, latitude and longitude coordinates for some emission release points are incorrect at 

three of the four facilities (TransMontaigne, TX Petrochemical, and Kinder Morgan). Such 

mistaken offsite placement of emission release points, at times directly in residential areas, 

would cause calculated risk due to emissions from these points to be overstated, possibly by a 

wide margin.

In other cases, emissions data in the NEI are incorrect. For example, as we have discussed with 

EPA previously, naphthalene emissions for the Unocal/Chevron facility are incorrectly high due 

a mistaken reporting of naphtha as “naphthalene.” Naphtha is a product of crude oil distillation 

containing a mixture of hydrocarbons that boil within a particular temperature range. Naphtha is 

a broad term referring to this mixture of liquid hydrocarbons and is not the same as naphthalene.

While data review and correction efforts are still underway, ENVIRON has received corrected 

data for two of the four facilities. Risk analyses for these two facilities were re-done with EPA’s 

HEM-3 risk model using corrected data. In both cases, facility-wide cancer MIR was reduced to 

below 1 in a million.

Data errors, such as those above, may cause inaccurate results that are misleading and material to 

EPA’s residual risk rule making. To guard against that possibility, we believe that risk analyses 

for these facilities should be re-done by EPA using corrected data. 

From our previous conversations with you, however, we understand that EPA does not plan to do 

so prior to rule proposal due to the short time before the court-ordered deadline. This is very 

disconcerting to the four terminals that took efforts to provide updated data to EPA. If EPA 

does not re-run the risk model, at a minimum, we urge EPA, both in its rule proposal and 

in any accompanying documentation of preliminary risk analyses, to acknowledge API’s 

ongoing data review and correction efforts for these four facilities, the nature of data 

errors uncovered to date, the effects that these errors would have on estimated risk, and 

their possible implications for residual risk rule making.

* * *

API stands ready to continue discussing with EPA how to improve residual risk assessments and 

their supporting databases, and we will be available to participate in efforts to do so. 
API and its members express appreciation for EPA’s efforts to ensure the accuracy of source and 

emission data used in EPA’s residual risk analyses, and EPA’s willingness to confirm with 

companies such data. We will welcome the opportunity to discuss these issues further with EPA 

and to provide EPA with additional information or clarifications as needed.

Sincerely,

Matthew Todd

Cc: K.C. Hustvedt, EPA
Fig. 1 - Coastal Terminals (Ft. Lauderdale) – 2005 NEI Emission Release Points + Corrected Location for Marine Vapor Recovery Unit
Fig. 1 - Unocal/Chevron (Nederland) – 2005 NEI Emission Release Points (All MACT Codes)
Fig. 2 - Unocal/Chevron (Nederland) – 2005 NEI Emission Release Points (Marine Vessel Loading MACT Code 603)
Fig. 3 - Unocal/Chevron (Nederland) – 2005 NEI Emission Release Points (Gasoline Distribution MACT Code 601)
Fig. 4 - Unocal/Chevron (Nederland) – 2005 NEI Emission Release Points (Blank MACT Code)
Fig. 5 - Unocal/Chevron (Nederland) – 2005 NEI Emission Release Point 000078 (tons/yr; naphthalene & MTBE)
Fig. 1 - TX Petrochemicals (Houston) – 2005 NEI Emission Release Points (All) + Corrected Location for Dock Facilities
Fig. 2 - TX Petrochemicals (Houston) – 2005 NEI Emission Release Points (No Marine Vessel Loading MACT Code 603) + Corrected Location for Dock Facilities
Fig. 3 - TX Petrochemicals (Houston) – 2005 NEI Emission Release Points (HON MACT Code 1501)
Fig. 4 - TX Petrochemicals (Houston) – 2005 NEI Emission Release Points (Blank MACT Code)
Fig. 5 - TX Petrochemicals (Houston) – 2005 NEI Emission Release Points (Incorrect Locations In/Near Residential Areas) 
Fig. 1 - Pasadena/Galena Park (Galena Park) – 2005 NEI Emission Release Points (All)
Fig. 2 - Pasadena/Galena Park (Galena Park) – 2005 NEI Emission Release Points (Marine Vessel Loading MACT Code 603)
Fig. 3 - Pasadena/Galena Park (Galena Park) – 2005 NEI Emission Release Points (Gasoline Distribution MACT Code 601)
Fig. 4 - Pasadena/Galena Park (Galena Park) – 2005 NEI Emission Release Points (Blank MACT Code)
Fig. 5 - Pasadena/Galena Park (Galena Park) – Throughput Instead of Emissions? Incorrect Locations?