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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 (co lumn BQ) and on map]: These emission points have an SCC 406 00298 that would indicate they are marine vessel lo ading.
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 loa ding and whether they should be part of the MVL emi ssions.

• **Access IDs 263 to 284 represent HAP emissions from two separate loading activities, Barge Dock 2**  **Uncontrolled Loading and Barge Dock 2 Controlled Lo ading (EPA Release Point IDs 387 and 438, respectiv**  **ely). Emissions from both of these loading activities sho**  **uld be considered MVL MACT affected.**

• Records for Access Assigned ID (column A), 195 to 2 04 [these are labeled 1 to 10 in Emission Pt Label (column BQ) and on map]: These emission points have an SC C 40899997 that would indicate they are marine vess el loading. Please confirm whether these emission poi nts are marine vessel loading, since the emissions appear to occur at what looks like a ST area (and do not appe ar 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 Re**  **lease Point ID 155]. This loading activity should be con**  **sidered MVL MACT affected.**

• Records for Access Assigned ID (column A), 226 to 2 36, [these are labeled 32 to 42 in Emission Pt Labe l (column BQ) and on map]: These emission points have an SCC 40899997 that would indicate they are marine vesse l loading. Please confirm whether these emission poi nts 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 Re**  **lease Point ID 156]. This source should be considered MV**  **L 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 emi ssion points shown on the far “right” side of the f acility
site. Please confirm that there are no HAP emissio ns from these storage tanks or other emissions poin ts.

• **Based on a visual comparison of the plot diagrams o f HAP emitting sources that you provided to our plo**  **t of the actual HAP emissions reported/reconciled for th**  **e calendar year 2005, your plot is correct.**2

• 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 ra te) and no changes needed.

• **Kinder Morgan is not aware of any inaccuracies in t he 2005 stack parameter data that was used in EPA R**  **isk Assessment. Note, for the effort associated with t**  **he reconciliation of significant anomalies in 2005 HAP**  **emission data and coordinates, Kinder Morgan did no t conduct a detailed analysis of Galena Park emissi**  **on 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; S hedd.Steve@epamail.epa.gov Subject: RTR MVL: review questions on revised 2005 NEI data set

Hi Bliss: Thank you for sending the revised 2005 NEI dataset for KinderMorgan, Galena Park TX. I we nt 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 to tal facility emission points and MVL emissions poin ts) and the HAP emissions were revised (for total facility emission s 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 (co lumn BQ) and on map]: These emission points have an SCC 40600298 t hat would indicate they are marine vessel loading. These records
do not have the MVL MACT code of 0603 but rather ar e marked as “NONE”. Please confirm whether these e mission points are marine vessel loading and whether they s hould be part of the MVL emissions.

Records for Access Assigned ID (column A), 195 to 2 04 [these are labeled 1 to 10 in Emission Pt Label (column BQ) and on map]: These emission points have an SCC 408999 97 that would indicate they are marine vessel loadi ng. Please confirm whether these emission points are marine ve ssel loading, since the emissions appear to occur a t what looks like a ST area (and do not appear to fall on any particu lar piece of equipment)?

Records for Access Assigned ID (column A), 226 to 2 36, [these are labeled 32 to 42 in Emission Pt Labe l (column BQ) and on map]: These emission points have an SCC 4089999 7 that would indicate they are marine vessel loadin g. Please3 confirm whether these emission points are marine ve ssel loading, since the emissions appear to occur a t 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 p oints 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 di ameter, 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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