From: "Matt Todd" <ToddM@api.org> 

 

 To: Steve Shedd/RTP/USEPA/US@EPA, Ted Palma/RTP/USEPA/US@EPA 

 

 Cc: <shayes@environcorp.com> 

 

 Date: 08/16/2010 12:10 PM 

 

 Subject: FW: ADDITIONAL FIGURE DESCRIPTIONS 

 

Steve and Ted – please see email from Stan below. If you have additional questions prior 

to the call, Stan has agreed to discuss these with you.

His direct line is 510.420.2527.

 Matt

From: Stan Hayes [mailto:shayes@Environcorp.com]

Sent: Monday, August 16, 2010 12:06 PM

To: Matt Todd

Subject: ADDITIONAL FIGURE DESCRIPTIONS

Matt –

Here are some additional figure descriptions that might assist Steve in interpreting the 

images sent to him previously:

Coastal

 Figure 1 All 2005 NEI emission release points (all

 MACT codes), plus corrected location for Marine Vapor

 Recovery Unit; note that none of the points is designated as

 Marine Vessel Loading MACT code 603; rather, all of the

 points in the 2005 NEI have a Gasoline Distribution MACT

 code 601 or an unspecified (blank) MACT code; note that the

 2005 NEI assumes that all of the other sources at the

 facility are collocated at an incorrect point offsite and to

 the west of the facility, near the intersection of SE 22nd

 St. and S Federal Hwy

Unocal/Chevron
 Figure 1 All 2005 NEI emission release

points (all MACT codes)

 Figure 2 Emission release points with Marine

 Vessel Loading MACT code 603 (note that the 2005 NEI only

 lists point 1 as MACT code 603, and does not include points

 Unocal 000077, Unocal 000078, or Unocal 000184, which all

 have blank MACT codes)

 Figure 3 Emission release point with Gasoline

 Distribution MACT code 601 (only point Unocal 000263)

 Figure 4 Emission release points with

 unspecified (blank) MACT code (all points but Unocal 1 and

 Unocal 000263)

 Figure 5 Emission release point Unocal 000078

 (blank MACT code); note the incorrectly large emissions of

 naphthalene (7.7 tons) due to misreporting of “naphtha” as

 “naphthalene”

TX Petrochemicals

 Figure 1 All 2005 NEI emission release points

 (all MACT codes) plus the location provided by TX

 Petrochemical staff for the actual location of dock

 facilities

 Figure 2 2005 NEI emission release points

 with Marine Vessel Loading MACT code 603 (none are contained

 in the NEI for this facility) plus the location provided for

 the dock facilities

 Figure 3 Emission release points with HON

 MACT code 1501
 Figure 4 Emission release points with

 unspecified (blank) MACT code

 Figure 5 Emission release points mislocated

 in or near residential areas

Pasadena-Galena Park

 Figure 1 All 2005 NEI emission release

points (all MACT codes)

 Figure 2 Emission release points with Marine

 Vessel Loading MACT code 603; note two emission release

 points mislocated in residential area

 Figure 3 Emission release point with Gasoline

 Distribution MACT code 601 (note the large number of points

 represented in the 2005 NEI to be collocated on Clinton

 Drive just north of a Galena Park tank farm)

 Figure 4 Emission release points with

 unspecified (blank) MACT code

 Figure 5 Emission release points (a)

 mislocated in residential areas (i.e., two of three points

 having Marine Vessel Loading MACT code 603 at the Pasadena

 Terminal) and (b) collocated Galena Park Terminal points

 with Gasoline Distribution MACT code 601 mislocated in the

 roadway adjacent to a tank farm

If you’d like, I could also give him a call before the 2 pm ET call.

Stan

_____________________________________
Stan R. Hayes

Principal

ENVIRON International Corporation

6001 Shellmound Street, Suite 700

Emeryville, CA 94608

(510) 420-2527

(510) 655-9517 (fax)

(415) 298-0489 (cell)

mailto:shayes@environcorp.com

www.environcorp.com