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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

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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 res ponses

Hi Celia, Kelly, and Marise: Thank you so much for your input on the 2005 NEI data set. I have one a dditional question and a few notes to share with you.

A. Based on the revised coordinates sent on 17 Dec 201 0, there are a few points that seem to be outside t he facility boundary. See the attached map. I may ha ve the facility boundary drawn incorrectly.

a. There is one point outside the boundary at the bott om of the map. Please confirm whether the facility boundary, as marked in yellow, is correct or whethe r it should be extended downward on the map to include the point just outside the facility boundar y. 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 i t is truly part of the facility? TPC does not own any property to the west of Sims B ayou, the water body that separates that emission point from the rest of the plant. In eval uating 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 th e emissions from this point are very low, we agree that relocating it to a location at or near the cen troid 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 fro m “1501” (for HON) to “0603” for MVL. I left the 1 record for Methanol unloading as MACT_Code 1501.2

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

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C. With respect to item 9 from my 15 Nov 2010 email, f or Emission_Unit 0066, I saw differing stack parame ters for 1 record (Emission_Unit 0066) from the June 2010 fi le 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 flo w (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 fla re measured, and it was 150 feet and not the 50 fee t shown in either of the numbers provided; therefore, pleas e use 150 feet as the height of this emission point

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We have been unable to locate information to confir m the other parameters. Since it is a flare, it is more likely that the higher temperature of 833 degrees i s correct, and we agree this is the better to use. We also agreed that EPA will use the June 19 data for the r emaining parameters unless and until TPC can provid e updated information or confirm that the October 12 is more correct. In reviewing the October 12 communication, we see no information to help sort o ut the differences.

Since we have not been able to locate anything to t his point to confirm either set of numbers, using 1 50 feet as the height, 833 degrees as the temperature, and the June 1 data for the other parameters is an appr opriate path forward. However, should this assumption prod uce any results of concern with EPA’s modeling, ple ase contact TPC as soon as possible so that we can disc uss further. We know from a plethora of actual amb ient monitoring results in and around our plant that no results of concern from a risk standpoint should re sult. TPC has open path (Fourier Transform Infrared – FTIR) m onitoring on our north and south fencelines, and Te xas 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 valu e, so included a 2009 value of 1.34 tpy 1,3-Butadie ne for
this emission source. We believe that this emission point is the rail loa ding racks. For the rail racks, the actual amount of 1,3- butadiene emissions that TPC reported to TCEQ for t he 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