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Schaffner, Karen S.

From: Textor, Marise L. [Marise.Textor@tpcgrp.com]

Sent: Wednesday, February 09, 2011 11:25 AM

To: Schaffner, Karen S.

Cc: Shedd.Steve@epamail.epa.gov; Nidini, Kelly J.; Bogany, Carolyn

Subject: RE: RTR MVL: review of TPC revised coordinates and responses

Karen and Steve – please see TPC’s written response to Karen’s January 26 email below, in bold red italics. If you have 

any questions, please do not hesitate to contact me. 

Best regards, 

Marise 

Marise Lada Textor, P.E. 

Corporate Director - Regulatory Affairs 

marise.textor@tpcgrp.com 

TPC Group | www.tpcgrp.com 

Office: 713.840.2410 | Cell: 713.703.8245 | Fax: 281.271.4506 

5151 San Felipe, Suite 800 | Houston, Texas 77056

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

Sent: Wednesday, January 26, 2011 3:03 PM 

To: Chu, Celia; Nidini, Kelly J.; Textor, Marise L. 

Cc: Shedd.Steve@epamail.epa.gov 

Subject: RTR MVL: review of TPC revised coordinates and responses 

Hi Celia, Kelly, and Marise: Thank you so much for your input on the 2005 NEI data set. I have one additional question 

and a few notes to share with you. 

A. Based on the revised coordinates sent on 17 Dec 2010, there are a few points that seem to be outside the 

facility boundary. See the attached map. I may have the facility boundary drawn incorrectly. 

a. There is one point outside the boundary at the bottom of the map. Please confirm whether the facility

boundary, as marked in yellow, is correct or whether it should be extended downward on the map to 

include the point just outside the facility boundary. 

Yes, the facility boundary should be extended down to include this emission point, which we believe is

the plant flare. 

b. Please confirm the point out to the left on the map; are the coordinates correct for this point, and it is 

truly part of the facility? 

TPC does not own any property to the west of Sims Bayou, the water body that separates that 

emission point from the rest of the plant. In evaluating the emissions data and other information 

associated with this data point, we believe that it is a tank that is located internally to the plant. As 

we discussed in our phone call today, given that the emissions from this point are very low, we agree 

that relocating it to a location at or near the centroid of the main plant area will be an appropriate

location and much more appropriate than its current location outside the plant boundary. 

B. Revisions made by KS: 

a. I revised the MACT_Code field for 3 MVL records from “1501” (for HON) to “0603” for MVL. I left the 1

record for Methanol unloading as MACT_Code 1501. 
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b. I revised the records that were noted as duplicate records by marking to delete (Emission_Unit 0158 

with HAP 1,3-Butadiene and MTBE). 

We confirm that these two changes sound appropriate. 

C. With respect to item 9 from my 15 Nov 2010 email, for Emission_Unit 0066, I saw differing stack parameters for 

1 record (Emission_Unit 0066) from the June 2010 file we sent to TPC when compared to the 12 Oct 2010 file 

TPC sent. 

19June2010: Stack Ht (50); Exit gas T (833); Stack Diameter (3.599); Exit gas velocity (3.5385); Gas flow 

(36) 

12Oct2010: Stack Ht (50); Exit gas T (279); Stack Diameter (4.388); Exit gas velocity (65.6); Gas flow 

(993.2699) 

Based on the emissions information associated with this emission point, we believe that this point is the plant 

flare. We recently had the stack height of the flare measured, and it was 150 feet and not the 50 feet shown 

in either of the numbers provided; therefore, please use 150 feet as the height of this emission point. 

We have been unable to locate information to confirm the other parameters. Since it is a flare, it is more 

likely that the higher temperature of 833 degrees is correct, and we agree this is the better to use. We also 

agreed that EPA will use the June 19 data for the remaining parameters unless and until TPC can provide 

updated information or confirm that the October 12 is more correct. In reviewing the October 12 

communication, we see no information to help sort out the differences. 

Since we have not been able to locate anything to this point to confirm either set of numbers, using 150 feet 

as the height, 833 degrees as the temperature, and the June 1 data for the other parameters is an appropriate 

path forward. However, should this assumption produce any results of concern with EPA’s modeling, please 

contact TPC as soon as possible so that we can discuss further. We know from a plethora of actual ambient 

monitoring results in and around our plant that no results of concern from a risk standpoint should result. TPC 

has open path (Fourier Transform Infrared – FTIR) monitoring on our north and south fencelines, and Texas 

Commission on Environmental Quality (TCEQ) operates monitors at Milby Park north of the plant and at 

Chavez High School south of the plant. 

D. For Butadiene emissions from Emission_Release_Point_ID 0166, your note indicated emissions would be a 

“small number”; assumed 10 percent of the 2005 value, so included a 2009 value of 1.34 tpy 1,3-Butadiene for 

this emission source. 

We believe that this emission point is the rail loading racks. For the rail racks, the actual amount of 1,3-

butadiene emissions that TPC reported to TCEQ for the year 2009 in our emissions inventory was 1.0203 tons 

per year. Please adjust accordingly. 

If you could respond to item A as soon as you can, that would be great. Thank you, Karen 

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