### Memoranda Documenting Changes to the RTR Dataset for the Shipbuilding and

Ship Repair (Surface Coating) Source Category

EPA Docket No.: EPA-HQ-OAR-2010-0786

The following memoranda all relate to chan ges made to the shipbuilding and ship

repair RTR dataset and were consolidated to have them altogether in a single

document.

Table of Contents:

Documentation for Eliminating Prelimin ary Risk (MIR) > 1-in-1 Million .............................2

Default Emissions Assumptions fo r Shipbuilding RTR Dataset ...........................................14

Unspecified Glycol Ether Emissions at NASSCO Facility (NEI 23077) .................................17

Additional Information on Shipbuilding Facilities with MIR >0.5 in 1 Million and

<1 in 1 Million based on Actual Emissions ................................................................................22

Summary of Estimated Shipyard Facilities Subject to Shipbuilding and Ship Repair

(Surface Coating) NESHAP (Subpart II) ..................................................................................27

1

# Memorandum: Documentation for Eliminating

Preliminary Risk (MIR) > 1

‐ in

‐ 1 Million

2

### March 22, 2010

MEMORANDUM

Subject: Documentation for Eliminating Pr eliminary Risk (MIR) > 1-in-1 Million

Ship Building and Ship Repair RTR

EPA Contract EP-D-06- 118; Work Assignment #03-06

From: Kaye Whitfield

To: Docket No. EPA_HQ-OAR-2010-0786

Shipbuilding and Ship Repair (Surface Coating) RTR

Preliminary dispersion modeling of the revised ANPRM dataset for surface

coating operations associated with the shipbuilding and ship repair industry indicated that

the risk associated with four facilities wa s estimated to be more than 1-in-1 million.

Additional data were gathered regarding em issions from these facilities, and revised

estimates of risk for these facilities indicat es none of the revised risks exceed one in a

million. The additional data gathering effort s and associated adjustment of predicted

risks are described in this memorandum.

The four facilities of c oncern and the associated predicted risks are shown in

Table 1. The predicted risks result from emissi ons of chromium, naphthalene, and nickel.

The emissions data for these four facilities were based on data in the 2005 NEI database,

and represent 2002 emissions. The risk analys is is intended to evaluate the risk

associated with surface coating operations at shipbuilding and ship repair facilities.

Therefore, for our purposes, only those em issions associated with surface coating

operations should be included in the risk analysis. Faciliti es and State agencies were

contacted to obtain additional detail regardi ng the types of sources emitting the pollutants

of concern.

The Maryland Department of the Environment was contacted to obtain

additional information regarding the source of the hexavalent ch romium Cr (VI) and

naphthalene emissions from the U.S. Coast Gu ard facility in Curtis Bay, Maryland. The

State contact, Mr. John Eckert , was asked what portion of the Cr (VI) and naphthalene

emissions for the most recent data availabl e was from surface coating operations.

The Maryland Department of the Envi ronment contact indicated that no

chromium emissions were reported for th e Coast Guard facility for 2007 or 2008, and

that the 2006 chromium emissions (the most recent available) resulted only from welding

operations. Therefore, for our purposes, the surface coating Cr (VI) emissions were

assumed to be zero, and the associated risk is zero.

3

### 4 The 2008 naphthalene emissions from this facility were 48.4 pounds; the

preliminary risk results were based on an em issions rate of 880 pounds per year. If the

predicted risk associated with naphthalene emissions (7.36E-06) is multiplied by the ratio

of the emission rates (48.4/880) , the resulting adjusted risk is 4.05E-07, less than 1-in-1

million. Therefore, the adjusted risk for th e Coast Guard facility is less than 1-in-1

million.

The Louisiana Department of Environmental Quality (LDEQ) was contacted

to determine if the chromium and nickel em issions from the three Louisiana facilities

resulted from surface coating emissions. Ms. Jackie Heber of LDEQ directed us to the

plant-wide summary emissions available on their website, and indicated if any additional

information was desired, an information request must be submitted. Two information

requests were submitted; one for chromium emissions data, and one for nickel emissions

data, and the emissions information obtained are summarized in Tables 2 and 3. As can

be seen in these tables, in 2008 none of the Cr (VI) or nickel emissions at these facilities

resulted from surface coating operations. Ther efore, for our purposes, the risk associated

with the Cr (VI) and nick el emissions is zero.

A printout of the relevant email correspondence between the RTR project

team and the State agencies is prov ided at the end of this memorandum.Table1.PreliminaryPredictedRisks–RevisedShipbuildingandShipRepairRTRANPRMDatasetFacilityIDFacilityName,LocationMaximumIndividualRiskPollutantNameCancerRiskRiskContributionSHP_NEILA0710078TrinityYacht,NewOrleans,LA5.68299E‐05Chromium(VI)compounds5.68299E‐05100SHP_NEI33201U.S.CoastGuard,CurtisBay,MD7.36832E‐06Chromium(VI)compounds6.2117E‐0684.37.36832E‐06Naphthalene1.13881E‐0615.46SHP_NEI6105TrinityMarine,Madisonville,LA6.06011E‐06Nickelcompounds4.75956E‐0678.546.06011E‐06Chromium(VI)compounds1.30055E‐0621.46SHP_NEILA0570062Thoma‐SeaBoatBuilders,Lockport,LA3.13181E‐06Chromium(VI)compounds1.77076E‐0656.543.13181E‐06Chromium(VI)compounds1.18051E‐0637.695Table2.ChromiumEmissionsDataforLouisianaFacilitiesYearAI#FacilityNameSCCSCC1SCC2SCC3SCC4ChromiumVI(andcompounds)(lb/year)20082449Thoma‐SeaShipBuildersLLC‐LockportYard30900202IndustrialProcessesFabricatedMetalProductsAbrasiveBlastingofMetalPartsSandAbrasive15200817146TrinityMarineProducts‐Plant#3830900500IndustrialProcessesFabricatedMetalProductsWeldingGeneral22200817146TrinityMarineProducts‐Plant#3830903008IndustrialProcessesFabricatedMetalProductsMachiningOperationsPlasmaTorch2032200817146TrinityMarineProducts‐Plant#3830904600IndustrialProcessesFabricatedMetalProductsOxyfuelCuttingGeneral6200830357TrinityYachtsLLC30900500IndustrialProcessesFabricatedMetalProductsWeldingGeneral73.45200830357TrinityYachtsLLC31606002IndustrialProcessesPhotographicFilmManufacturingProductManufacturing‐FinishingOperationsCutting/SlittingOperations0**DATAABOVEPROVIDEDBYLADEQINRESPONSETOINFORMATIONREQUEST0030082.RECEIVED3/17/1067Table3.NickelEmissionsfromTrinityMarine,Madisonville,LAYearAI#AINameOwnerSourceIDSourceDescriptionSourceTypeNickel(andcompounds)(lb/yr)200817146TrinityMarineProducts‐Plant#38TrinityIndustriesIncSR0004W‐1‐WeldingFugitiveEmissions16200817146TrinityMarineProducts‐Plant#38TrinityIndustriesIncTMP995TC‐TorchCuttingFugitiveEmissions25200817146TrinityMarineProducts‐Plant#38TrinityIndustriesIncTMP997PC‐PlasmaCuttingFugitiveEmissions1354**DATAABOVEPROVIDEDBYLADEQINRESPONSETOINFORMATIONREQUEST0030096.RECEIVED3/19/10Email Exchanges with Maryland DEQ re

Coast Guard facility at Hawkins Point

(a.k.a. US Coast Guard Curtis Bay

‐

NEI33201)

Naphthalene Related (inverse chronological order)

Mary

‐ Jo

‐ Ok so here is what I found out. For their "painting and surface coating operations" in 2007,

they reported 16.8 lbs/year. For 2008, they reported 48.4 lbs/year. They reported that none came out

of their boilers for either year.

John

>>> "Mary

‐ Jo Caldwell" < mjcaldwell@nc.rr.com > 3/17/2010 3:34 PM >>>

Thanks very much.

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: "John Eckert" < jeckert@mde.state.md.us >

To: "Mary

‐ Jo Caldwell" < mjcaldwell@nc.rr.com >

Cc: "Dave Reeves" < dwreeves@rti.org >

Sent: Wednesday, March 17, 2010 3:16 PM

Subject: Re: US Coast Guard Yard

Mary

‐ Jo

‐ Sorry I didn't get to you earlier today, I've been out in the field all day.

I'll be out on the field for the majority of the day tomorrow as well, but

I'll try to look at that sometime either this afternoon or tomorrow.

John

>>> "Mary

‐ Jo Caldwell" < mjcaldwell@nc.rr.com > 3/17/2010 9:49 AM >>>

John,

The info. you provided me on chromium emissions from the Coast Guard

facility at Hawkins Point (also referred to as US Coast Guard Curtis Bay

‐

NEI33201) was just what I needed. Thank you.

Now the risk modeling (based on 2002 emissions) indicates a potential



### 8problem due to naphthalene emissions from this facility. Could you please

tell me what 2008 and 2007 naphthalene emissions were for this facility, and

if the emissions were associated with painting operations? If there are

emissions, it would be very helpful if you had stack parameters, as right

now we're treating them as a volume source, which probably overstates

impacts.

Thanks very much

‐‐ Mary

‐ Jo Caldwell

Chromium Related

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: "John Eckert" < jeckert@mde.state.md.us >

To: "Mary

‐ Jo Caldwell" < mjcaldwell@nc.rr.com >

Sent: Friday, March 12, 2010 8:58 AM

Subject: Re: US Coast Guard Yard

Mary

‐ Jo

‐ So they did not specify what type of chromium was emitted in their report,

but their report did say it came from welding operations. I don't know enough about welding or

chromium emissions to know what kind of chromium welding would emit.

John

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: "John Eckert" < jeckert@mde.state.md.us >

To: "Mary

‐ Jo Caldwell" < mjcaldwell@nc.rr.com >

Sent: Friday, March 12, 2010 7:02 AM

Subject: Re: US Coast Guard Yard

Mary

‐ Jo

‐ I can check. In our emissions report it was just represented as "Chromium or

Chromium Compounds". I will check if the USCG specified in the report the

sent in.

John

>>> "Mary

‐ Jo Caldwell" < mjcaldwell@nc.rr.com > 3/11/2010 4:42 PM >>>

John

‐ Thanks for the information. Do you know if their 2006 chromium emissions

were reported as trivalent chromium, or hexavalent, or just chromium compounds?

Mary

‐ Jo Caldwell

‐‐‐‐‐ Original Message

‐‐‐‐‐



### 9From: "John Eckert" < jeckert@mde.state.md.us >

To: < mjcaldwell@nc.rr.com >

Sent: Thursday, March 11, 2010 3:25 PM

Subject: US Coast Guard Yard

Mrs Caldwell

‐ When I went into our Emissions Inventory for the US Coast Guard Yard, there were no

reported Chromium emissions for 2007 or 2008. Their 2009 report has not been sent in yet but I would

assume no chromium there either. There was a little bit of chromium in 2006 in the amount of 0.021

tons for the entire year. I also checked the EPA's TRI website which showed no chromium emissions.

Their MACT reports for 2009 also showed no chromium emissions. I hope this helps. If you have any

further questions let me know. Thanks

– John

Email Exchanges with Louisiana DEQ re

Trinity Yacht, Trinity Marine, and Thoma

‐ Sea Facilities

Nickel Emissions (In reverse chronological order)

Mary Jo

‐ Attached is the information. Thanks

Melinda Molieri

Access Sciences Public Records Technician

Louisiana Department of Environmental Quality

Phone: 225.219.3168

Email: melinda.molieri@la.gov

Records Management: Access - Integrity – Security

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: Mary

‐ Jo Caldwell [mailto:mjcaldwell@nc.rr.com]

Sent: Friday, March 19, 2010 11:27 AM

To: Kaneka Morris; Melinda Molieri

Subject: Fw: Public Records Request 0030096

Happy Friday, Ladies. And come tomorrow, Happy Spring!

On Wednesday I submitted the attached records request. Jackie Heber

responded promptly to my last information request, and I wonder if she's

responded to this one yet. If so, can you tell me when I might be able to

access the response? Thanks very much.



### 10Mary

‐ Jo Caldwell

919

‐ 812

‐ 5309

mjcaldwell@nc.rr.com

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: < publicrecords@la.gov >

To: < mjcaldwell@nc.rr.com >

Sent: Wednesday, March 17, 2010 1:18 PM

Subject: Public Records Request 0030096

> REQUESTOR INFORMATION

> ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐

> FULL NAME

.... Mary

‐ Jo Caldwell

> ORGANIZATION

.... Caldwell Environmental, Inc.

> MAIL ADDRESS

‐ 1

.... 6205 Winthrop Drive

> MAIL ADDRESS

‐ 2

....

> CITY

.... Raleigh

> STATE

.... NC

> ZIP

.... 27612

> PHONE

.... 919

‐ 812

‐ 5309

> FAX

.... 919

‐ 420

‐ 7677

> E

‐ MAIL

.... mjcaldwell@nc.rr.com

>

> REQUEST DETAILS

> Want to know sources of 2008 nickel emissions for Trinity Marine Products

> Plant #38 AI # 17146. If file could be saved in xls format, and a link to

> file provided, as was done for last info. request, I'd be very

> appreciative. Thx

>

> DELIVERY METHOD

> Fax copies to me. (20 pages or less)

>

> PLEASE REFERENCE THIS REQUEST BY CONFIRMATION CODE "0030096".

Chromium Related (in reverse chronological order)

----- Original Message -----

From: Melinda Molieri

To: Mary-Jo Caldwell



### 11Cc: Kaneka Morris

Sent: Wednesday, March 17, 2010 11:51 AM

Subject: RE: Records Req. 0030082

Mary Jo,

Here is the link that will tell you how to retrieve the files.

Thanks

http://pknpost.deq.louisiana.gov/cgi

‐ bin/pnp/files.cgi?dir=LUenNZlcF

Melinda Molieri

Access Sciences Public Records Technician

Louisiana Department of Environmental Quality

Phone: 225.219.3168

Email: melinda.molieri@la.gov

Records Management: Access - Integrity - Security

I've fulfilled the request and have already sent it back to the public records folks. I have no idea how

long they take to get it to you though.

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: Mary

‐ Jo Caldwell [mailto:mjcaldwell@nc.rr.com]

Sent: Tuesday, March 16, 2010 2:27 PM

To: Jackie Heber

Cc: Dave Reeves

Subject: Fw: Public Records Request 0030082

Hi Jackie,

As you suggested, I submitted an official public records request for the

chromium emissions data for the three facilities we discussed. This request

is summarized below.

Can you tell me about how long it may take to respond to the information

request? Your best guess as to turnaround time would be greatly

appreciated.

Thank you very much.



### 12Mary

‐ Jo Caldwell

‐‐‐‐‐ Original Message

‐‐‐‐‐

From: < publicrecords@la.gov >

To: < mjcaldwell@nc.rr.com >

Sent: Monday, March 15, 2010 6:11 PM

Subject: Public Records Request 0030082

> REQUESTOR INFORMATION

> FULL NAME

.... Mary

‐ Jo Caldwell

> ORGANIZATION

.... Caldwell Environmental, Inc.

> MAIL ADDRESS

‐ 1

.... 6205 Winthrop Drive

> MAIL ADDRESS

‐ 2

....

> CITY

.... Raleigh

> STATE

.... NC

> ZIP

.... 27612

> PHONE

.... 919

‐ 812

‐ 5309

> FAX

.... 919

‐ 420

‐ 7677

> E

‐ MAIL

.... mjcaldwell@nc.rr.com

>

> REQUEST DETAILS

> ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐

> For the three facilities listed below, for 2008 I want to know if any

> painting operations emit hexavalent chromium, and if so, what are

> hexavalent chromium emissions from painting operations? How did facility

> calculate hexavalent chromium emissions from painting (i.e., transfer

> efficiency assumed, control efficiency, etc.) The three facilities I am

> interested in are: AI#2449 Thoma

‐ Sea, in Lockport; AI#30357 Trinity

> Yachts in New Orleans; and AI#17146 Trinity Marine Products Plant #38, in

> Madisonville. If possible, would prefer info. be emailed, but if not

> possible, please fax to # provided.



### 13

# Memorandum: Default Emissions Assumptions

for Shipbuilding and Ship Repair (Surface

Coating) RTR Dataset

14

### August 30, 2010

MEMORANDUM

TO: Docket No.: EPA-HQ-OAR-2010-0786

FROM: Kaye Whitfield, Project Lead

Risk and Technology Review - National Emission Standards for Hazardous Air

Pollutants (NESHAP) for Shipbuilding a nd Ship Repair (Surface Coating)

SUBJECT: Default Emissions Assumpti ons for Shipbuilding RTR Dataset

This memorandum summarizes the approach used to develop default emissions data for the RTR

dataset for surface coating operations at shipbu ilding and ship repair facilities. There are

approximately 40 shipyards included in our list of ~85 major source (and synthetic minor source)

shipyards that have missing or incomplete emissi ons data (based on NEI and TRI searches).

The following bullets summarize the emissions a ssumptions being recommended to populate the

RTR dataset:

1) For facilities with missing HAP and criteria air pollutants (CAP) emissions data, use the

following default VOC emissions data:

-For facilities that emit less than 25 TPY, assign default emissions of 7 tons VOHAP

(based on average reported emissions fr om five medium-sized facilities)

-For facilities that emit greater than or equal to 25 TPY of total HAP, assign default

emissions of 25 tons VOHAP (based on recommendation by EPA’s Dr. Mohamed

Serageldin)

2) For any facility with only actual VOC or default VOC emissions data, use the following

solvent profile to calculate default HAP emissions from VOC data:

HAP Solvent Default Profile Synthetic Minor

Default Emissions Major Source

Default Emissions

Xylene (all isomers) 78% 5.5 tons 19.5 tons

Ethyl benzene 15% 1.0 tons 3.75 tons

Toluene 7% 0.5 tons 1.75 tons

Total 100% 7.0 tons 25 tons

3) There were several ANPRM comments indicatin g that shipyard pain ting operations need

to be modeled as volume sources (instead of point sources); ther efore, the default

volume source parameters to be used for subsequent risk modeling are:

15

### Exit Gas Temperature (F) – 72 (based on NEI default)

Exit Gas Velocity (ft/sec) – 0.0003 (based on NEI default)

Exit Gas Flow Rate (cu ft/sec) – 0 (based on NEI default)

Fugitive Height (ft) - 10 (based on NEI default)

Fugitive Width (N-S) (ft) – 100 (based on 1993 Risk Assessment for NASSCO -

avg of small sources, Docket OAR-2002-0061,

VIII-D-01)

Fugitive Length (E-W) (ft) – 100 (based on 1993 Risk Assessment for NASSCO -

avg of small sources, Docket OAR-2002-0061,

VIII-D-01)

Fugitive Angle (degrees) – 0 (based on NEI default)

16

# Memorandum: Unspecified Glycol Ether Emissions at NASSCO

Facility (NEI 23077)

17

### 18 September 9, 2010

MEMORANDUM

TO: EPA Docket No.: EPA

‐ HQ

‐ OAR

‐ 2010

‐ 0786)

FROM: Kaye Whitfield, EPA/OAQPS/SPPD

SUBJECT: NASSCO (NEI 23077)

– Unspecified Glycol Ether Emissions

The recent risk modeling results for the shipbuilding and ship repair (surface coating) source

category identified the highest HI and HQ for the NASSCO facility (NEI 23077) located in San Diego, CA.

The risk driver was 11.4 tons of unspecified glycol ethers based on 2002 NEI data

– which defaults to the

most health

‐ protective glycol ether RfC used as a surrogate for the risk analysis. The amount of glycol

ethers in the data set appears high by comparison with other large shipyards; therefore, NASSCO was

contacted directly to verify the 11.4 tons of uspecified glycol ether emissions reported in NEI.

NASSCO Facility Contact: Sarah Giobbi, Environmental Engineer, 619

‐ 544

‐ 7778

Ms. Giobbi was contacted on 8/3/10, and she informed us that NASSCO reports their annual

material usage to the San Diego Air Pollution Control District. They reported the following unspecified

glycol ether emissions:

2004

– 2007: 0 lbs

2008: 2,476 lbs

2009: not finished yet

She also stated that she did not have readily available access to the old (2002) data and NASSCO has not

reported any EGME or DEGBE emissions since 2004. Five new spray booths and associated controls

were installed in 2009 and will also reduce some of their painting emissions.

Recommendation: replace NASSCO’s 11.4 tons of unspecified glycol ether emissions with the 2008 data,

where 2,476 lbs (1.24 tons) should be used for the RTR data set.

A copy of NASSCO’s 2008 emissions inventory report is attached.The San Diego Air Pollution Control District has prepared emission estimates for the above facility.



### Criteria

Pollutant Annual Emissions

(tons/yr) Max Hourly Emissions

(lbs/hr)

Carbon Monoxide (CO) 4.4 36.8

Nitrogen Oxides (NOx) 12.9 146.0

Particulate Matter (PM10) 23.2 37.3

Particulate Matter (PM2.5) 0.6 7.1

Reactive Organic Gases (ROG) 304.2 270.6

Sulfur Oxides (SOx) 1.4 4.7

Total Organic Gases (TOG) 306.4 274.2

Total Particulates (TSP) 23.3 37.6



### Toxic Air

Contaminant Annual Emissions

(lbs/yr) Max Hourly Emissions

(lbs/hr)

1,2,4-Trimethylbenzene 91085.28 38.204

1,3-Butadiene 84.70 0.144

2,2,4-Trimethylpentane 0.50 0.025

Acetaldehyde 305.19 0.520

Acetone 3471.29 1.413

Acrolein 13.21 0.023

Aluminum 157.95 1.439

Ammonia 127.17 0.065

Arsenic 0.70 0.001

Barium 141.38 0.379

Benzene 72.97 0.141

Butanol 149242.17 61.069

Cadmium 9.30 0.037

Chlorobenzene 0.08 < 0.001

Chromium, Hexavalent 4.68 0.002

Chromium, Non-Hexavalent 10.26 0.121

Copper 602.12 1.396

Dichlorobenzene 0.02 < 0.001

Diesel Particulate 1637.94 7.478

Ethanol 28.60 0.622

Ethyl Benzene 11169.11 24.750

Ethylene Oxide 2885.57 1.344

Formaldehyde 673.89 1.148

Glycol Ethers, Unspecified 2476.72 9.991

Hexane 44.02 0.096

Hydrogen Chloride 72.59 0.124

Isopropyl Alcohol 125.44 0.322

Lead 3.62 0.016

Manganese 339.94 0.151

Mercury 0.78 0.001

Methanol 801.43 1.937

Methyl Ethyl Ketone 4.61 0.002

Methyl Isobutyl Ketone 377.33 7.465

Naphthalene 7.69 0.013

Nickel 113.29 0.131



### 19

### Toxic Air

Contaminant Annual Emissions

(lbs/yr) Max Hourly Emissions

(lbs/hr)

PAH, Unspecified 14.10 0.024

Propylene 181.96 0.310

Propylene Glycol 18.35 0.139

Propylene Glycol Methyl Ether 31347.77 18.939

Selenium 0.86 0.001

Silica, Crystalline 12.06 4.160

Silver 25.90 0.075

Styrene 170.98 1.035

Toluene 60.15 0.340

Xylenes 9430.30 25.452

Zinc 455.95 1.217



### 20

# Memorandum: Additional Information on Shipbuilding

Facilities with MIR >0.5

‐ in

‐ 1 Million and <1

‐ in

‐ 1 Million based

on Actual Emissions

21

### MEMORANDUM

August 6, 2010

SUBJECT: Additional Information on Shi pbuilding Facilities with MIR >0.5-in-1

million and <1-in-1 million based on Actual Emissions

RTR: Shipbuilding and Ship Repair (Surface Coating)

FROM: Kaye Whitfield, EPA/OAQPS/SPPD/NRCG

TO: EPA Docket No. EPA-HQ-OAR-2010-0786

The purpose of this memorandum is to present additional information related to the five

major source shipyards that resulted with MIRs between 0.5- and 1-in-1 million in the most

recent risk modeling using actual emissions. If the current MACT allowable factor of 2 times

the actual emissions is used in the next risk modeling, these five facili ties would have MIR >1-

in-1 million.

The table below summarizes the available informa tion on these facilities from the RTR data set

and the recent risk analyses.

NEI ID # Facility Name (Location) MIR

‐ Actual

(MIR

‐ Allowable) Risk Drivers

NEI779 Norfolk Naval Shipyard

(Portsmouth, VA) 0.9

(2) Cadmium cmpds (78%);

POM 71002 (8%);

Benzene (5%)

NEIRSCO

‐

0074 Detyens Shipyard (2383 Hwy

41

Mt Pleasant, SC) 0.85

(2) Cr+6 cmpds (95%)

NEI 820

(SHP1) Trinity Industries Plant 118

(850

‐ B Pine St

Beaumont, TX) 0.8

(2) Naphthalene (100%)

NEIWA1408

2 Puget Sound Naval Shipyard

(Bremerton, WA) 0.77

(2) Arsenic cmpds (54%);

methylene chloride

(24%);

NEILA0120 Bollinger Gretna (4640 Peters

Road

Harvey, LA) 0.5

(1) Propylene oxide (84%);

benzene (13%)



### 22

### 23 Issue 1 – Norfolk Naval Shipyard and Puget S ound Naval Shipyard – Risk driver

emissions not associated with surface coating operations

The Norfolk Naval Shipyard and Puget Sound Naval Shipyard are part of the Naval

Sea Systems Command (NAVSEA) division of the United States Navy. The recent risk

modeling was based on reported emissions for both of these facilities from 2002 NEI

data. Both facilities were contacted in order to verify that “risk driver” pollutants were in

fact emitted from surface coating operations s ubject to the Shipbuilding and Ship Repair

MACT. After reviewing the facility’s latest annual emissions inventory, environmental

personnel at the Norfolk Naval Shipyard c onfirmed that no cadmium emissions (the

major risk driver – 78%) were emitted from the facility’s surface coating operations. 1



### Similarly, the Puget Sound Shipyard confirme d that there 2009 ar senic and methylene

chloride emissions from surface coating opera tions were either significantly lower than

the reported 2002 NEI emissions used in the ri sk modeling or not asso ciated with coating

operations. Those emission records associat ed with non-surface coating operations will

be corrected in the RTR dataset and will be excluded from the risk analysis for the

MACT category. Attachment 1 contains the 2009 annual emission reports for the Norfolk

naval facility.

Issue 2 – Trinity Industries listed with incorrect NAICS/SIC codes

The Trinity Industries Plant located in B eaumont, Texas is listed in the NEI with

NAICS code 336510 - Railroad Rolling Stock Ma nufacturing and an SIC code of 3743 –

Railroad Equipment. 2 

### The facility was contacted in order to determine whether or not

shipbuilding or ship repair was performed at the site. A representative of the company

confirmed that Trinity Industr ies builds barges at other f acilities it owns (located in

Missouri, Tennessee, and Louisiana) but not at the Beaumont facility. 3 

### Therefore this

facility should not be listed as a shipbuilding or ship repair facility and all associated

records should be removed from the RTR data set for the shipbuilding source category.

Issue 3 – Bollinger Gretna Facility and Detyens Shi pyard risk driver emissions listed with

incorrect SCC codes

The Bollinger Gretna facility and the Detyens Shipyard are both shipbuilding and

ship repair facilities. The risk driver em issions (propylene oxide and benzene) used for

the Bollinger Gretna facility in the risk modeling (2002 NEI) were associated with SCC

30980001 – Industrial Processes Fabricated Metal Products – Equipment Leaks. The risk

driver emissions (chromium VI) used for the Detyens Shipyard in the risk modeling were

associated with SCC 30900199 – Industrial Proc esses Fabricated Metal Products General

Processes Not Classified. Those emission reco rds associated with these metal fabrication

SCCs will be corrected in the RTR dataset and not part of the risk analysis for the MACT

category.

1 Phone conversation with Mathew Peppers on August 4, 2010.

2 Envirofacts Website. Facility Detail Report.

http://iaspub.epa.gov /enviro/fii_query_dtl.disp_program_ facility?p_regist ry_id=110000464122

3 Phone conversation with company representative on August 4, 2010.Attachment 1- 2009 Facility Emissions Inventories –Norfolk Naval ShipyardsSourceTypeUsage(lb/yr)Usage(gal/yr)PM(lb/yr)VOC(lb/yr)Antimony(lb/yr)ButoxyEthanol 2(lb/yr)ButoxyethylAcetate 2(lb/yr)ChromiumTrioxide(VI) (lb/yr)Cumene(lb/yr)Ethylbenzene(lb/yr)Ethyleneglycolmonoethylether(lb/yr)Hexamethylene-1,6-diisocyanate (lb/yr)Methylisobutylketone(lb/yr)Nickel(lb/yr)Toluene(lb/yr)Xylene(lb/yr)PNTO-009 Spray booth (thermal) 0.000.00 0.00PNTO-011 Spray booth (thermal) 409.500.11 0.001.50PNTO-012 Anchor Chain Painting98.00 0.00 246.76PNTS-001 Spray booth15.13 5.54 42.370.270.01PNTS-002 Spray booth (powder) 166.690.42 0.00PNTS-003 Spray booth0.00 0.00 0.00PNTS-004 Spray booth56.26 22.42 157.53 0.01 0.010.01 3.7418.75PNTS-005 Spray booth28.38 12.64 79.46 0.000.540.62PNTS-006 Spray booth1,331.19 611.51 3,727.332.54 70.04 1.802.38 260.55PNTS-011 Outdoor painting23,013.61 7,827.54 63,373.31 0.04 7.8712.98 2,438.59 40.39 0.17 0.170.08 3,725.75PNTS-018 Spray booth15.62 6.51 43.730.110.6417.12 0.00PNTS-019 Spray booth0.00 0.00 0.00PNTS-025 Spray booth52.00 4.00 145.6039.25 19.633.9335.33PNTS-026 Spray booth173.34 32.90 491.1379.03 52.62PNTS-028 Spray booth637.52 269.57 1,785.054.048.80 38.05615.45 4.05PNTS-029 Spray booth11.83 5.40 33.130.29 0.150.88PNTS-030 Spray booth39.25 18.32 109.902.149.88PNTS-031 Spray booth (powder) 352.500.18 0.00PNTS-033 Spray booth0.56 0.24 1.600.010.48PNTS-034 Spray booth13.00 1.17 36.921.364.14Total (lb/yr)8,818.47 70,273.82 0.05 47.13 19.63 0.01 17.18 2,523.55 42.19 8.97 38.86 1.50 714.54 4,112.58Total (ton/yr)4.41 35.14 2.50E-05 0.02 0.01 5.00E-06 0.01 1.26 0.02 4.49E-03 0.02 7.51E-04 0.36 2.06outdoor 0.00 23,111.61 7,827.54 63,620.07 0.04 7.87 0.00 0.00 12.98 2,438.59 40.39 0.17 0.17 0.00 0.08 3,725.75spray booth 0.00 2,374.08 990.22 6,653.75 0.01 39.26 19.63 0.01 4.20 84.96 1.80 8.80 38.69 0.00 714.46 386.83Spray booth (powder) 519.19 0.00 0.59 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00Spray booth (thermal) 409.50 0.00 0.11 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 1.50 0.00 0.00total 928.69 25,485.69 8,818.47 70,273.82 0.05 47.13 19.63 0.01 17.18 2,523.55 42.19 8.97 38.86 1.50 714.54 4,112.58NNSY CY 2009 - Paint Use & Emissions24

# Memorandum: Summary of Estimated Shipyards

Subject to Shipbuilding and Ship Repair (Surface

Coating) NESHAP (subpart II)

25

### MEMORANDUM

DATE: October 25, 2010

SUBJECT: Summary of Estimated Shipyard s Subject to Shipbuilding and Ship

Repair (Surface Coating) NESHAP (subpart II)

FROM: Kaye Whitfield, EPA/OAQPS/SPPD/NRCG

TO: EPA Docket No. EPA-HQ-OAR-2010-0786

The purpose of this memorandum is to document the current information on the

number of facilities engaged in shipbuilding and ship repair activities and subject to Subpart II:

1. 85 total (MACT) sources [~44 major sources + ~41 synthetic minor sources]

- includes all ~20 of the biggest shipyards that were identified in original MACT project

2. 500+ additional facilities in the U.S. that have shipbuilding or ship repair activities, but

are area sources of HAP emissions or not surface coating (MACT) related

3. 71 sources modeled (included in risk analysis report dated July 2010)

- includes 25 facilities that should have been excluded

– not part of the 85 (i.e., area

sources or facilities not subject to MACT because they do not build or repair ships)

- therefore, only 46 of the 71 modeled sources are part of the MACT category

- ~15 of the 46 modeled sources include default emissions assigned based on

assumptions

4. 39 additional facilities were identified with missing emissions data Æ not modeled

- typically smaller repair operations with unknown coating usage

- several smaller “sister” operations to nearby major source facilities

- several with missing/unknown NEI ID numbers

5. The 39 facilities with missing data were identified after the default emissions were

assigned to the other 15 facilities with missing data; there are no technical reasons for

differentiating between any of the 39 + 15 = 54 facilities with missing or incomplete

emissions data.

6. Total number of MACT sources = 46 + 39 = 85

List of 85 Facilities Subject to Shipbuilding and Ship Repair NESHAP (Subpart II)

26

### # Facility Name Location NEI ID No.

1 Northrop Grumman Ship Systems Inc. Pascagoula NEI11169

2 Barge Cleaning and Repair Channelview NEI13187

3 National Steel & Shipbuilding

‐ General

Dynamics Co. San Diego NEI23077

4 San Francisco Dry Dock San Francisco NEI23453

5 Aker Philadelphia Shipyard Philadelphia NEI2PA101569

6 Amfels, Inc. Brownsville NEI2TX06138

7 Newport News Shipbuilding & Dry Dock

Co. Newport News NEI310

8 Jeffboat Jeffersonville NEI31325

9 BAE Systems Norfolk Ship Repair Inc. Norfolk NEI314

10 U.S. Coast Guard Yard

– Curtis Bay Curtis Bay NEI33201

11 Cascade General, Inc. Portland NEI40623

12 Trinity Marine Products/Plant No. 38 Madisonville NEI6105

13 Northrop Grumman Ship

Systems/Avondale Operations Avondale NEI6184

14 Bath Iron Works Co. Bath NEI6292

15 US Navy

– Norfolk Naval Shipyard Portsmouth NEI779

16 Atlantic Dry Dock LLC. Jacksonville NEI8274

17 Atlantic Marine Inc Mobile NEI8609

18 North Florida Shipyards Inc. Jacksonville NEIFL0310231

19 International Ship Repair & Marine

Serv. Tampa NEIFL0570021

20 Bollinger Shipyards Lockport, LLC. Lockport NEILA0051

21 Halter Gulf Coast Fabrication Bay St. Louis NEIMS1690



### 27

### # Facility Name Location NEI ID No.

22 Northrop Grumman Ship Systems Inc. Gulfport NEIMS1698

23 Bayonne Drydock Bayonne NEINJ01712517

24 Union Dry Dock & Repair Co. Hoboken NEINJ01712524

25 Detyens Shipyard

– Mt. Pleasant Mt. Pleasant NEIRSC0

‐ 0074

26 Detyens Shipyard

– Charleston N. Charleston NEIRSC0

‐ 0236

27 Metal Trades

– Cooper River N. Charleston NEISC2314

28 Metal Trades

– Yonges Island Yonges Island NEISC2322

29 Newpark Shipbuilding

– Pasadena Inc. Pasadena NEITXT$11635

30 US Navy Puget Sound Naval Shipyard

PSNS Bremerton NEIWA14082

31 Marinette Marine Corp Marinette NEIWI0755480

32 850 Pine Street Inc Beaumont SHP_SHP1

33 G M D Shipyard Brooklyn SHP_SHP10

34 Gulf Ship LLC Gulfport SHP_SHP11

35 Lyon Shipyard

– Sealift Drydock Norfolk SHP_SHP12

36 Marine Hydraulics Norfolk SHP_SHP13

37 Mayship Repair Contracting Staten Island SHP_SHP14

38 New York Shipyard Corp, IKEA Red Hook Brooklyn SHP_SHP15

39 Tampa Ship LLC Tampa SHP_SHP16

40 Atlantic Marine Philadelphia LLC Philadelphia SHP_SHP2

41 Brownsville Marine Products Brownsville SHP_SHP3

42 Caddell Dry Dock Staten Island SHP_SHP4

43 Central Gulf Shipyard New Iberia SHP_SHP5

44 Colonna Marine LLC

‐ Colonna Yachts Norfolk SHP_SHP6



### 28

### # Facility Name Location NEI ID No.

45 Erie Shipbuilding Erie SHP_SHP7

46 Foss Maritime Co Seattle SHP_SHP9

47 Bath Iron Works Brunswick NEI6243

48 Bay Shipbuilding Co. Sturgeon Bay NEIWIT$8533

49 Bender Shipbuilding & Repair Co. Inc. Mobile NEIAL09736603BNDRS26

50 Boston Ship Repair LLC. (part of Atlantic

Marine) Boston NEIMA0251435

51 Colonna’s Shipyard Inc. Norfolk NEIVAT$2469

52 Conrad Shipyard LLC Morgan City NEILA10170381CNRDS29

53 Duwamish Shipyard Inc. Seattle NEIWA10654

54 Electric Boat Corp Groton NEICT0605

55 General Dynamics Electric Boat Corp. N. Kingstown NEI44260

56 Gulf Marine Repair Corp Tampa NEIFL0570442

57 Gunderson LLC Portland NEI16611

58 Kiewit Offshore Services Ltd. Ingleside NEITX40978362KWTFF24

59 North American Fabricators LLC. Houma

60 North American Shipbuilding LLC

–

Larose Shipyard Larose

61 Tampa Bay Shipbuilding & Repair Co. Tampa NEIFL0570286

62 Trinity Marine Products Inc. Plant 48 Brusly NEILAT$10610

63 Trinity Marine Products Inc. Plant 296 Ashland City NEITNT$4754

64 Trinity Marine Products Inc. Plant #75 Caruthersville NEI34481

65 Ashland Exploration Inc Ashland

66 Baltimore Marine Industries Baltimore



### 29

### # Facility Name Location NEI ID No.

67 Brown & Root Inc Greens Bayou Fab Houston

68 Gulf Island Fabrication Houma

69 Halter Lockport/Halter Marine Inc. Lockport

70 Halter Marine

– Gulfport Gulfport NEIMS1696

71 Halter Marine Pascagoula, Inc. Pascagoula NEIMS1726

72 ISG Sparrows Point Inc. Sparrows Point NEI33221

73 J. R. McDermott, Inc. Amelia NEI6097

74 LMS Ship Management Inc. Memphis NEITNT$5074

75 Lyon Shipyard Norfolk

76 Marine Industrial Febricators Inc. New Iberia

77 Metro Machine of VA Norfolk

78 Mississippi Marine

‐ South Yard Greenville NEIMS1843

79 Pelican Island Inc Galveston NEITXRGB0463

80 Platzer Ship Yards, Inc. Houston

81 Portsmouth Naval Shipyard Kittery

82 Southwest Marine, Inc. San Diego NEICA0733199

83 USN North Island San Diego NEICA0732740

84 VT Halter Moss Point Moss Point NEIMS1720

85 VT Halter Moss Point Marine Escatawba NEIMS1721



### 30

### List of 25 Facilities that were modeled for RTR but were later removed from the above listing.

# Facility Name Location NEI ID No.

1 Delta Engineering Channelview NEI11242

2 Global Intermodal Systems Oakland NEI19046

3 Anacapa Marine Service Oxnard NEI25972

4 Ventura Harbor Boatyard Inc. Ventura NEI26111

5 Duckworth Steel Boats, Inc. Tarpon Springs NEI2FL030480

6 Dynamic Industries, Inc./Dynamic Topside New Iberia NEI2LA045011

7 Blount Boats Inc. Warren NEI2RIIR1822

8 American Shipyard LLC Newport NEI2RIIR3317

9 Bollinger Shipyards, Inc. Houston NEI2TX1507

10 North Yard Port Arthur NEI2TX165

11 Hendry Corp Tampa NEI3FL12057HEN

12 Todd Pacific Shipyards Corp Seattle NEI46670

13 Bollinger Shipyards Lockport /Bollinger

Larose Larose NEI6000

14 Dock Yard Port Arthur NEI6705

15 Wilson & Hampton Refinishing Inc. San Diego NEICA0732521

16 Southbay Boat Yard Chula Vista NEICA0732603

17 North Star Propellers Inc. San Diego NEICA0732968

18 Bollinger Shipyards Lockport LLC

/Bollinger Gretna LLC Harvey NEILA0120

19 Bollinger Calcasieu LLC/Shipyard Cleaning Sulphur NEILA0190100

20 Thoma

‐ Sea Ship Builders LLC/Lockport Lockport NEILA0570062

21 Trinity Marine Group Inc/Trinity Yachts New Orleans NEILA0710078



### 31

### 32 # Facility Name Location NEI ID No.

22 Texas Barge & Boat, Inc. Freeport NEITX17990

23 Bollinger Texas City LP Texas City NEITXRGB0593

24 Orange Yard Orange NEITXROC0376

25 Fairhaven Shipyard Bellingham SHP_SHP8