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Schaffner, Karen S.

From: Bliss Higgins [bhiggins@environcorp.com]

Sent: Friday, January 14, 2011 4:26 PM

To: Schaffner, Karen S.

Cc: Christina_Harris@kindermorgan.com; Kyle LeJeune; Shedd.Steve@epamail.epa.gov

Subject: RE: RTR MVL: review questions on revised 2005 NEI dataset

Karen, 

Please see responses to your questions below. 

Thank you, 

Bliss 

Marine Vessel Loading: 

• Records for Access Assign ID (column A), 263 to 284 [these are labeled A to V in Emission Pt Label (column BQ) 

and on map]: These emission points have an SCC 40600298 that would indicate they are marine vessel loading. 

These records do not have the MVL MACT code of 0603 but rather are marked as “NONE”. Please confirm 

whether these emission points are marine vessel loading and whether they should be part of the MVL emissions.

• Access IDs 263 to 284 represent HAP emissions from two separate loading activities, Barge Dock 2 

Uncontrolled Loading and Barge Dock 2 Controlled Loading (EPA Release Point IDs 387 and 438, respectively). 

Emissions from both of these loading activities should be considered MVL MACT affected. 

• Records for Access Assigned ID (column A), 195 to 204 [these are labeled 1 to 10 in Emission Pt Label (column 

BQ) and on map]: These emission points have an SCC 40899997 that would indicate they are marine vessel 

loading. Please confirm whether these emission points are marine vessel loading, since the emissions appear to 

occur at what looks like a ST area (and do not appear to fall on any particular piece of equipment)? 

• Access IDs 195 to 204 represent HAP emissions from uncontrolled loading at Ship Dock #1 (SD-1) [EPA Release 

Point ID 155]. This loading activity should be considered MVL MACT affected. 

• Records for Access Assigned ID (column A), 226 to 236, [these are labeled 32 to 42 in Emission Pt Label (column 

BQ) and on map]: These emission points have an SCC 40899997 that would indicate they are marine vessel 

loading. Please confirm whether these emission points are marine vessel loading, since the emissions appear to 

occur at what looks like a ST area? 

• Access IDs 226 to 236 represent HAP emissions from uncontrolled loading at Ship Dock #2 (SD-2) [EPA Release 

Point ID 156]. This source should be considered MVL MACT affected. 

Total Facility: 

• Looking at the plot of emission points on the site map, there are several emission points that are not shown as 

having HAP emissions, for example, there are no emission points shown on the far “right” side of the facility 

site. Please confirm that there are no HAP emissions from these storage tanks or other emissions points. 

• Based on a visual comparison of the plot diagrams of HAP emitting sources that you provided to our plot of 

the actual HAP emissions reported/reconciled for the calendar year 2005, your plot is correct. 
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• There were no changes to any of the stack parameter columns. Please confirm that the stack parameters are 

correct (i.e., stack height, exit gas temperature, stack diameter, exit gas velocity, exit gas flow rate) and no 

changes needed. 

• Kinder Morgan is not aware of any inaccuracies in the 2005 stack parameter data that was used in EPA Risk 

Assessment. Note, for the effort associated with the reconciliation of significant anomalies in 2005 HAP 

emission data and coordinates, Kinder Morgan did not conduct a detailed analysis of Galena Park emission 

source stack parameter data, and therefore, did not propose to reconcile any such data. Accordingly, Kinder 

Morgan believes no changes in source parameter data are required. 

Bliss M. Higgins 

Principal 

ENVIRON International 

225 408 2693, direct

225 408 2696, main

225 241 4097, mobile 

From: Schaffner, Karen S. [mailto:ksschaffner@rti.org] 

Sent: Monday, December 20, 2010 2:16 PM 

To: Bliss Higgins 

Cc: Christina_Harris@kindermorgan.com; Kyle LeJeune; Shedd.Steve@epamail.epa.gov 

Subject: RTR MVL: review questions on revised 2005 NEI dataset 

Hi Bliss: Thank you for sending the revised 2005 NEI dataset for KinderMorgan, Galena Park TX. I went through the 

changes for the emissions records. A few questions for KM are listed below. I attached my version of the dataset (with 

kss initials at the end) and attached the map with the emission points plotted; only the MVL emission points are labeled 

on the map. 

As you noted, coordinates were revised (for both total facility emission points and MVL emissions points) and the HAP 

emissions were revised (for total facility emissions points). There were no emission changes for MVL. All emission 

points appear to fall within the facility boundary.

Thanks, Karen 

Marine Vessel Loading: 

Records for Access Assign ID (column A), 263 to 284 [these are labeled A to V in Emission Pt Label (column BQ) and on 

map]: These emission points have an SCC 40600298 that would indicate they are marine vessel loading. These records 

do not have the MVL MACT code of 0603 but rather are marked as “NONE”. Please confirm whether these emission 

points are marine vessel loading and whether they should be part of the MVL emissions. 

Records for Access Assigned ID (column A), 195 to 204 [these are labeled 1 to 10 in Emission Pt Label (column BQ) and 

on map]: These emission points have an SCC 40899997 that would indicate they are marine vessel loading. Please 

confirm whether these emission points are marine vessel loading, since the emissions appear to occur at what looks like 

a ST area (and do not appear to fall on any particular piece of equipment)? 

Records for Access Assigned ID (column A), 226 to 236, [these are labeled 32 to 42 in Emission Pt Label (column BQ) and 

on map]: These emission points have an SCC 40899997 that would indicate they are marine vessel loading. Please 
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confirm whether these emission points are marine vessel loading, since the emissions appear to occur at what looks like 

a ST area? 

Total Facility: 

Looking at the plot of emission points on the site map, there are several emission points that are not shown as having 

HAP emissions, for example, there are no emission points shown on the far “right” side of the facility site. Please 

confirm that there are no HAP emissions from these storage tanks or other emissions points. 

There were no changes to any of the stack parameter columns. Please confirm that the stack parameters are correct 

(i.e., stack height, exit gas temperature, stack diameter, exit gas velocity, exit gas flow rate) and no changes needed. 

Karen Schaffner

Air Quality Engineering Group

RTI International

3040 Cornwallis Rd (800 Park, C311)

Research Triangle Park, NC 27709

phone: (919) 316 3740

fax: (919) 541 7155

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