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Schaffner, Karen S.

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

Sent: Friday, December 17, 2010 5:47 PM

To: Schaffner, Karen S.; Shedd.Steve@epamail.epa.gov

Cc: Nidini, Kelly J.; Stan Hayes

Subject: RE: RTR MVL: review of TPC 12Oct2010 data sets

Attachments: TPC.Corr Lat-Lon.xlsx

Dear Steve and Karen – 

Please see the responses to the questions in your email of November 15 below, in blue font. If you have any additional 

questions, please do not hesitate to call me or email to me at any time. Although I will be on vacation for the next two 

weeks, I will be monitoring my email and will try to respond to anything from you over the holiday vacation within a few 

days. 

I wish you all a very happy holiday and wonderful New Year. 

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: Monday, November 15, 2010 2:18 PM 

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

Cc: Shedd.Steve@epamail.epa.gov 

Subject: RTR MVL: review of TPC 12Oct2010 data sets 

Dear Marise and Celia: Thank you for providing the revised data sets for TPC Houston TX on 12 Oct 2010. We have 

reviewed the files and have several follow-up questions, to make certain we understand the information you sent, and a 

few ideas for next steps. Please contact Steve Shedd with EPA or me to discuss any questions. Thank you, Karen. 

Review of TPC dataset Excel files sent on 12Oct2010: 

Reviewed files: 

FromTPC_2010Oct12_2005 NEI.Marine Term.TPC.xlsx 

FromTPC_2010Oct12_2005 NEI.Marine Term.TPC.xlsx 

From TPC_2010Oct12_2005 NEI Marine Term TPC (js) with 2009 data.xlsx 

Am returning files: 

FromTPC_2010Oct12_2005 NEI.Marine Term.TPC_kss.xlsx

From TPC_2010Oct12_2005 NEI Marine Term TPC (js) with 2009 data_kss.xlsx 

TPC_2010Nov12_Image1.jpg 

TPC_2010Nov12_Image2.jpg 
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MVL Records: 

1. What is the difference between files “2005 NEI.Marine Term.TPC.xlsx” and “2005 NEI.Marine Term.TPC.xlsx”? It 

appears that both files “2005 NEI.Marine Term.TPC.xlsx” have coordinate changes and one stack parameter 

correction in the file, and are the same file (i.e., duplicate file). There didn’t appear to be any other changes. 

Please confirm. 

Yes, these two files are the same. The same email and the associated attachment from James Scroggins dated 

August 11, 201 was attached twice in an email to Steve Shedd on October 12, 2010. I apologize for the

confusion.

2. There were 4 records for MVL operations in the original 2005 NEI dataset and also in 

“FromTPC_2010Oct12_2005 NEI.Marine Term.TPC.xlsx”. In June, TPC mentioned that Methanol emissions were 

from “unloading”, not loading, so please confirm. 

Methanol is only unloaded at the TPC marine loading facility.

3. The Process_MACT_Code field is entered as 1501 for the whole data set (this is the MACT code for HON). The 3 

(or 4) records for MVL should be 0603 (this is the MACT code for Marine Vessel Loading Operations). Please 

confirm that this change should be made. 

Yes, the change should be made.

Total Facility Records: 

4. There were 89 records for the facility in the original 2005 NEI data set sent to TPC in June 2010; the corrected 

data set has 59 records. Which records were dropped/deleted, and why? 

It appears that EMISSION_UNIT 0193 was dropped because all of the HAPs listed in the original table were 

essentially zeros (i.e., 9.04E-08), accounting for 31 deleted entries. However, the corrected data set has two 

duplicate entries for EMISSION_UNIT 0158, thus bringing the total to 59 (89 – 31 deleted + 1 duplicate = 59)

5. There were 32 records for the facility related to Boilers, Process_MACT_Code field 107-2, that appear to have 

been deleted/dropped from the data set for the facility. These records include those for Emission_Unit 0193; 

Process_ID 0073; SCC 10200601; Emission_Release_Point_ID 0204. Could you confirm why? 

Please refer to the response to question No. 4 – 31 were essentially zeros and 1 was a duplicate, thus totaling 32 

deleted or dropped records.

6. There were 2 records for Emission_Unit 0158; Process_ID 0068; SCC 40899999; Emission_Release_Point_ID 

0167 in the original data set (original had 1,3-butadiene emissions of 0.09 ton; and MTBE emissions of 0.2961 

ton). 2 more records were added for this emission point; the new records appear to be duplicates of the 

original. Please confirm that these are meant to be added. 

They were duplicate entries and, therefore, do not need to be added. Please delete them.

7. It appears that all coordinate data have been corrected. Our GIS person checked the coordinate data for all 59 

records. It looked like several emission points are outside the facility boundary, as we understood the facility 

boundaries from earlier conversations. The attached file called “FromTPC_2010Oct12_2005 NEI.Marine 

Term.TPC_kss.xlsx” contains an additional field to the far right of the worksheet called 

“OUTSIDE_PROPERTY_ID”, with a number key to the plotting of those points on the attached file 

“TPC_2010Nov12_Image1.jpg”. Approximately 18 records looked like they are outside the facility boundaries. 

Could you check on these points and address any problems? 

It appears that PC_2010Nov12_Image1.jpg is based on the uncorrected coordinates. We are attaching a new file 

to this email with corrected coordinates, TPC.Corr Lat-Lon.xlsx. To assist in incorporating the corrected 
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information, we have put it in a format similar to the one used by HEM-3 (EPA’s risk model) to specify source 

locations. This should make use of the corrected data straightforward. Column U in EPA’s file corresponds to 

the numbers (without the letters “ID”) in column A of the new attached file. 

8. It appears that the coordinates for the 4 MVL emission points are off a bit from where we expected them. For 

example, J.Scroggins sent a 2010June03 email with coordinates of Latitude 29.717762152834343, Longitude -

95.24133682250976. These are somewhat different from those provided in the latest file: -95.241944, 

29.716388 for the Emission_Release_Point_ID 0070 and -95.241944, 29.716666 for Emission_Release_Point_ID 

0218. In looking at the map where the docks and vapor processer actually are, they look a bit off (See map key 

numbers 19, 20, 21, 22). Please advise which are correct. 

James sent one corrected point (latitude and longitude) in June. We recommend that EPA use this single 

corrected location from James for the dock emission points, which will result in a much more accurate location 

than EPA’s current coordinates for dock emission points. Nonetheless, due to the heavy industrialized

surrounding area, the precise location of these dock points will not affect the final result significantly. 

9. It looks like the stack parameters for one record have been corrected (Emission_Unit 0066; Process_ID 0057; 

SCC 30119799; Emission_Release_Point_ID 0051), and for all other emission points, the stack parameters are 

correct as is. Could you please confirm this. 

Our comparison of the two files does not show any difference in parameters; please identify which parameters 

you are speaking about so that we can check again. 

10. What is the significance of the SCC titles in Red text and yellow highlight in file “2005 NEI Marine Term TPC (js) 

with 2009 data.xlsx” and the SCC titles in Red text and yellow highlight in file “FromTPC_2010Oct12_2005 

NEI.Marine Term.TPC.xlsx”? 

These were indicated in yellow highlights and red text because they were large sources and incorrectly located 

in the community and therefore would be risk drivers in EPA’s original (and incorrect due to incorrect

coordinates) risk analysis. The yellow highlights and red text were internal convenience notations and not 

necessarily meant for EPA information. We apologize for any confusion. 

What is the field name for the values in column B of the “2005 NEI Marine Term TPC (js) with 2009 data.xlsx” 

spreadsheet – is it “Emission_Release_Point_ID”? 

Yes, this is “Emission_Release_Point_ID”. 

New values of 1,3-butadiene are suggested for 9 records. If you suggest that emissions data for 2009 are more 

representative of plant operation, then we need to create a full facility data set with the 2009 emissions data, as 

well as a full data set for 2005 emissions. 

The 2009 data are representative of current operation. TPC does not intend to increase emissions of 1,3-

butadiene. As discussed during the EPA visit to TPC, under a voluntary emissions reduction agreement (VERA) 

with the State of Texas, we have invested significant capital expenditures and made significant changes in our 

operating practices and culture, resulting in a 75 percent reduction in emissions of 1,3-butadiene, plant-wide, 

since our baseline year of 2004. 

The reason that TPC only provided the 1,3-butadiene information is that 99 percent of the risk resulted from 

emissions of 1,3-butadiene. The only other two compounds in the NEI are chromium compounds and MTBE. 

EPA should be able to see a similar relationship in their 2005 analysis, for confirmation. 

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
MTextorTPC-2010Dec17_TPC.Corr Lat-Lon.xlsx

TPC Corrected Lat-Lon

Source ID

Location 

type 

(U=UTM, 

L=lat/lon)

Longitude (decimal) or UTM 

East (m) [use center for 

point or volume sources, SW 

corner for area sources]

Latitude (decimal) or UTM 

North (m) [use center for point 

or volume sources, SW corner 

for area sources]

ID01 L -95.262953 29.697958

ID02 L -95.262953 29.697958

ID000004 L -95.249064 29.698235

ID000016 L -95.256564 29.697958

ID000017 L -95.256286 29.69768

ID000018 L -95.256564 29.69768

ID000019 L -95.256564 29.69768

ID000023 L -95.255731 29.69768

ID000051 L -95.255453 29.694624

ID000054 L -95.252953 29.699624

ID000064 L -95.254064 29.696013

ID000070 L -95.241337 29.717762 MTVLO Source

ID000097 L -95.254064 29.699624

ID000127 L -95.255731 29.697958

ID000166 L -95.252397 29.695735

ID000167 L -95.253508 29.694902

ID000168 L -95.254064 29.69768

ID000171 L -95.254342 29.699069

ID000207 L -95.253508 29.694902

ID000209 L -95.253508 29.694902

ID000210 L -95.256008 29.697402

ID000211 L -95.255731 29.699347

ID000214 L -95.249897 29.699069

ID000218 L -95.241337 29.717762 MTVLO Source

ID000224 L -95.249897 29.698513

ID000225 L -95.249619 29.698235

ID000227 L -95.253786 29.698513

ID000228 L -95.255175 29.697958

ID000232 L -95.241337 29.717762

ID000236 L -95.255175 29.696569

ID000237 L -95.252675 29.697402

ID000238 L -95.252397 29.698235

ID000240 L -95.255175 29.697402

ID000241 L -95.255175 29.697124

NOTES: HEM-3/AERMOD Emission Location File Format (first four columns)

Yellow shading/red text denotes corrected latitude/longitude values

Blue shading indicates MTVLO source