MEMORANDUM

DATE: March 10, 2011

SUBJECT: Data Changes for Facilities Since Proposal

Residual Risk and Technology Review for the Marine Tank Ves sel Loading Operations Source Category - Promulgation EPA Contract No.: EP-D-07-061; EPA Project No.: 005 RTI Project No.: 0212783.005

FROM: Karen Schaffner, RTI International

TO: Stephen Shedd, EPA/OAQPS/SPPD

The purpose of this memorandum is to document changes to t he 2005 NEI/NATA data set for use in conducting the residual risk analysis for t he Marine Tank Vessel Loading Operations (MTVLO) source category for the October 2010 Ri sk and Technology Review (RTR) proposal (75 FR 65068; October 21, 2010).

I. Background

In the October 21, 2010 proposal notice (75 FR 65068), we provided f or public comment the results from a residual risk analysis for MTVLO at 152 facilities in the 2005 NEI/NATA data base. We found that three facilities had risks greater than 1 in a million from MTVLO.

II. Revisions to Facility Files

We received public comments and some data during the comment period on 4 facilities. One commenter provided a report assessing the risks and erro rs in the 2005 NEI/NATA but did not provide specific data revisions or corrections. Facilit ies provided corrected data files and information prior to, during, and after the public comment period. Facilities and other public

commenters identified data errors in the 2005 NEI/NATA data set such as out-of-date data, incorrect latitude and longitude (including emission point lo cations outside of the facility’s fenceline), incorrect HAP emission calculations, and incorrect identification of HAP compounds. The data changes suggested by commenters were evaluated, an d in some cases, we requested additional information and emission data to follow up on comments received. A summary of the analysis and changes for each facility are provided below

.

TransMontaigne, Fort Lauderdale FL, NEIFLT$4246 . For the TransMontaigne facility in Fort Lauderdale, Florida, the public comments included a reco mmendation that EPA use corrected latitude and longitudes values for the non-MTVL O and incorporate the corrected data into the 2005 NEI/NATA. Prior to proposal, we correcte d the latitudes and longitudes for2

MTVLO, conducted an analysis of the residual risk, and foun d the risk was less than 1-in-1 million for MTVLO and found the facility-wide risk was above 1-in-1 million.

We contacted the facility to discuss changes to latitude and longitude for non-MTVLO emission sources, and in those discussions, we determined the correct coordinates for the gasoline vapor recovery unit (VRU) (0.086 HAP tons per year (tpy)) and updated the data set. For storage tank emission sources (1.0 HAP tpy), we determ ined the facility centroid was the correct location and revised the latitudes and longitudes. EPA has updated the 2005 NEI/NATA data set with the corrected data and conducted a risk analy sis to determine the facility-wide risk.

Chevron Pipeline Company, Nederland TX, NEI6451 . Chevron provided corrected data files for their facility prior to the comment period, which included corrections to latitudes and longitudes and correct identification of HAP compounds. The facilities identified issues with the data set that included the mistaken reporting of naphtha (a hydrocarbon) as naphthalene (a HAP) and incorrect coordinates, and the facility noted that emi ssions were artificially high in 2005 because during the emergency after Hurricane Rita, they we re permitted to continue operating using gravity loading, but the control device was not operating due to lack of electricity. The facility and EPA agreed that it was more appropriate to use the following year’s emission data (2006). EPA incorporated the changes into the 2005 NEI/NATA to update the data set for this facility and conducted a risk analysis to determine the ri sk for MTVLO and the facility-wide

risk.

TPC Group, Houston TX, NEI8135 . For the TPC Group (formerly Texas Petrochemicals) facility in Houston, Texas, the faci lity indicated there were errors in the data set and provided corrected data sets prior to and after the co mment period. The facility reported a

number of emissions sources with incorrect latitudes and l ongitudes, which may have resulted from a systematic coordinate system translation erro r at the facility for the coordinates that went into the 2005 NEI/NATA. The facility has reduced emissions since 2005, and has entered into a voluntary emission reduction agreement (VERA) with Tex as Commission on Environmental Quality (TCEQ) and a settlement agreement with the Cit y of Houston. Emissions of 1,3- butadiene were reduced by more than 75 percent from 2004 to 2008, an d the facility reduced the allowable emissions authorized in its permit to make the emission reductions permanent.

We reviewed draft data set submitted and requested additional cl arifications from the facility. EPA corrected the 2005 NEI/NATA data set base d on input from the facility. EPA confirmed the corrected latitudes and longitudes provided by the facility for emissions sources; revised the latitudes and longitudes to the facility centro id for two emission points (total 0.034 HAP tpy) that were offsite; revised the MACT code for one record to a non-MTVLO MACT

code because the emissions were determined to be from unlo ading and not part of the MTVLO source category; deleted two records that were noted as dupl icate records by the facility; incorporated a stack height change for one record; and revis ed the 1,3-butadiene emissions for

nine records to reflect emission reductions achieved at th e facility. EPA incorporated these changes into the 2005 NEI/NATA to update the data set for t his facility and conducted a risk analysis to determine the risk for MTVLO and the facili ty-wide risk.3

KM Liquids Terminals, Galena Park TX, NEITX20191 . KM Liquids Terminals (Kinder Morgan) noted errors in their public comments for the Ga lena Park, Texas facility, and stated that the latitude and longitude and the emission rate data were incorrect. The facility noted that they over-reported HAP emissions and provided data correcti ons to EPA for the more significant data anomalies, including corrections to organic liquid product speciation and re-estimation of tank roof landing losses. For storage tank emissions (par t of facility-wide emissions and are not part of MTVLO emissions), the facility identified incor rect product speciations for 1,3-butadiene and benzene in several products, including in aromatic conc entrate, blendstock, clean petroleum products, gasoline blendstock, hydrocarbon blendstock, LPC Py gas, and Pygas. The facility corrected the speciation and provided recalculated storage tank emissions based on the speciation corrections. For storage tank roof landing loss emissio ns (part of the facility-wide emissions and are not part of MTVLO emissions), the AP-42/API proc edures that are used to estimate

emissions often result in more emissions than the t otal mass of liquid in the tank. The facility reviewed roof landing loss emissions and identified where emissions estimated to more than the maximum (emissions cannot be more than the total mass of liquid heel plus mass of heel vapor space), identified six tanks with more than the “maximum” possible emissions, and adjusted emissions (benzene) based on a ratio of the total mass to total roof landing loss emissions. For roof landing loss emissions, the product speciation profiles were corrected, too. Kinder Morgan provided a revised data set to EPA during the public comment perio d. EPA reviewed the data set and requested additional clarifications from the facilit y. EPA incorporated these changes into the 2005 NEI/NATA to update the data set for this facility and con ducted a risk analysis to determine the risk for MTVLO and the facility-wide risk.

In addition, the facility reported in their public commen ts that they have significantly reduced facility-wide HAP emissions since 2005, with work pra ctices, engineering controls, participation in the TCEQ’s Find and Fix Initiative, and t heir 2008 Benzene Reduction agreement. Facility-wide emissions from 2005 to 2009 have been reduced for 1,3-butadiene by 97 percent (49 tpy to 1.4 tpy) and by 89 percent for benzene (fr om 77 tpy to 8.3 tpy). The facility provided copies of these two agreements.4

III. References

Harris, C., KM Liquids Terminals LLC, to Air and Radia tion Docket. Docket ID No. EPA-HQOAR-2010-0600, Letter with Comments on EPA’s Proposed Rule – R esidual Risk and Technology Review (RTR) for National Emission Standards for Marine Tank Vessel Loading Operations. Docket item no. EPA-HQ-OAR-2010-0600-281. Dated Dec ember 6, 2010.

Textor, M., TPC Group, to Air and Radiation Docket. Docke t ID No. EPA-HQ-OAR-2010- 0600, Letter with Comments on EPA’s Proposed Rule – Residua l Risk and Technology Review (RTR) for National Emission Standards for Marine Tank Vessel Loading Operations. Docket item no. EPA-HQ-OAR-2010-0600-300. Dated December 6, 2010.

Todd, M., API, to Air and Radiation Docket. Docket ID N o. EPA-HQ-OAR-2010-0600, Letter with Comments on EPA’s Proposed Rule – Residual Risk an d Technology Review (RTR) for

National Emission Standards for Marine Tank Vessel Loa ding Operations. Docket item no. EPA-HQ-OAR-2010-0600-0359. Dated December 6, 2010.

Schaffner, K., RTI International, to P. Siler, Trans Montaigne. Electronic mail suggesting an approach for latitude and longitude changes to the 2005 NEI/NAT A data set for TransMontaigne Fort Lauderdale, FL facility. Dated January 28, 2011.

Siler, P., TransMontaigne, to K. Schaffner, RTI Inte rnational. Electronic mail accepting latitude and longitude changes to the 2005 NEI/NATA data set for Tra nsMontaigne Fort Lauderdale facility. Dated February 3, 2011.

Schaffner, K., RTI International, to S. Shedd, EPA/OAQ PS/SPPD/CCG. Draft Trip Report - Chevron Pipeline Company, Beaumont, TX for site visit on June 23, 2010.

Herman, M., Chevron, to K. Schaffner, RTI Internation al. Corrected 2005 NEI/NATA HAP emissions dataset for Chevron Pipeline Company, Nederland TX facility, sent by electronic mail. Dated July 6, 2010.

Herman, M., Chevron, to K. Schaffner, RTI Internation al. Corrected 2006 NEI/NATA HAP emissions dataset for Chevron Pipeline Company, Nederland TX facility, sent by electronic mail. Dated July 2, 2010.

Chu, C., TPC Group, to S. Shedd, EPA/OAQPS/SPPD/CCG. Ele ctronic mail providing input on

the 2005 NEI/NATA HAP emissions dataset for Texas Petroc hemicals, Houston TX facility. Dated October 12, 2010.

Schaffner, K., RTI International, to M. Textor, K. Ni dini, and C. Chu, TPC Group. Electronic mail with questions on the 2005 NEI/NATA HAP emissions data set for Texas Petrochemicals, Houston TX facility. Dated November 15, 2010.5

Textor, M., TPC Group, to K. Schaffner, RTI Internationa l and S. Shedd, EPA/OAQPS/SPPD/CCG. Electronic mail providing input on t he 2005 NEI/NATA HAP emissions dataset for Texas Petrochemicals, Houston T X facility. Dated December 17, 2010.

Schaffner, K., RTI International, to M. Textor, K. Ni dini, and C. Chu, TPC Group. Electronic mail with questions on the 2005 NEI/NATA HAP emissions data set for Texas Petrochemicals, Houston TX facility. Dated January 26, 2011.

Schaffner, K., RTI International, to M. Textor and C. Bogany, TPC Group. Electronic mail with questions on the 2005 NEI/NATA HAP emissions dataset for Te xas Petrochemicals, Houston TX facility. Dated February 1, 2011.

Textor, M., TPC Group, to K. Schaffner, RTI Internationa l. Electronic mail providing input on

the 2005 NEI/NATA HAP emissions dataset for Texas Petroc hemicals, Houston TX facility. Dated February 9, 2011.

Bogany, C., TPC Group, to K. Schaffner, RTI Internation al. Electronic mail providing input on

the 2005 NEI/NATA HAP emissions dataset for Texas Petroc hemicals, Houston TX facility. Dated February 10, 2011.

Schaffner, K., RTI International, to B. Higgins, Environ Corporation. Electronic mail with questions on the 2005 NEI/NATA HAP emissions dataset for KM Liquids Terminals, Galena Park TX facility. Dated December 20, 2010.

Higgins, B., Environ Corporation, to K. Schaffner, RTI I nternational. Electronic mail providing input on the 2005 NEI/NATA HAP emissions dataset for KM Liqu ids Terminals, Galena Park TX facility. Dated January 14, 2011.

Schaffner, K., RTI International, to B. Higgins, Environ Corporation. Electronic mail with confirmation of a change to the 2005 NEI/NATA HAP emissio ns dataset for KM Liquids Terminals, Galena Park TX facility. Dated January 24, 2011.

Shedd, S., EPA/OAQPS/SPPD/CCG, to B. Higgins, Environ C orporation. Electronic mail requesting follow up on benzene and 1,3-butadiene emissions r eductions for KM Liquids Terminals, Galena Park TX facility. Dated February 23, 2011.

Shankle, G., TCEQ, to S. Kean, Kinder Morgan Energy Pa rtners. Letter transmitting signed agreements with TCEQ regarding the “Hawk” thermal imaging study for KM Liquids Terminals, Galena Park TX facility. Dated April 27, 2006.

Zimmerman, L., Kinder Morgan Liquids Terminals, LLC, to G . Shankle, TCEQ. Letter and attachments regarding the “Hawk” thermal imaging study fo r KM Liquids Terminals, Galena Park TX facility. Dated December 21, 2006.6

Shankle, G., TCEQ, to C. Munguia, Kinder Morgan Liquids Terminals, LLC. Letter and attachments transmitting signed commitment letters for benzene emissions reductions with TCEQ for KM Liquids Terminals, Galena Park TX facility . Dated June 3, 2008.