MEMORANDUM

DATE: March 10, 2011 

SUBJECT: Data Changes for Facilities Since Proposal 

 Residual Risk and Technology Review for the Marine Tank Vessel 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 the 2005 NEI/NATA data 

set for use in conducting the residual risk analysis for the Marine Tank Vessel Loading 

Operations (MTVLO) source category for the October 2010 Risk 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 for 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 errors in the 2005 NEI/NATA but did 

not provide specific data revisions or corrections. Facilities 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commenters identified data errors in the 2005 NEI/NATA data set such as out-of-date data, 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 locations outside of the facility’s 

fenceline), incorrect HAP emission calculations, and incorrect identification of HAP compounds. 

The data changes suggested by commenters were evaluated, and 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 recommendation that EPA use 

corrected latitude and longitudes values for the non-MTVLO and incorporate the corrected data 

into the 2005 NEI/NATA. Prior to proposal, we corrected the latitudes and longitudes for 
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MTVLO, conducted an analysis of the residual risk, and found 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 determined 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 analysis 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 emissions were artificially high in 2005 

because during the emergency after Hurricane Rita, they were 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 risk for MTVLO and the facility-wide 

risk. 

TPC Group, Houston TX, NEI8135. For the TPC Group (formerly Texas 

Petrochemicals) facility in Houston, Texas, the facility indicated there were errors in the data set 

and provided corrected data sets prior to and after the comment period. The facility reported a 

number of emissions sources with incorrect latitudes and longitudes, which may have resulted 

from a systematic coordinate system translation error 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 Texas Commission on Environmental 

Quality (TCEQ) and a settlement agreement with the City of Houston. Emissions of 1,3-

butadiene were reduced by more than 75 percent from 2004 to 2008, and 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 clarifications from the 

facility. EPA corrected the 2005 NEI/NATA data set based 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 centroid 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 unloading and not part of the MTVLO 

source category; deleted two records that were noted as duplicate records by the facility; 

incorporated a stack height change for one record; and revised the 1,3-butadiene emissions for 

nine records to reflect emission reductions achieved at the facility. EPA incorporated these 

changes into the 2005 NEI/NATA to update the data set for this facility and conducted a risk 

analysis to determine the risk for MTVLO and the facility-wide risk. 
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KM Liquids Terminals, Galena Park TX, NEITX20191. KM Liquids Terminals (Kinder 

Morgan) noted errors in their public comments for the Galena 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 corrections 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 (part of facility-wide emissions and are not 

part of MTVLO emissions), the facility identified incorrect product speciations for 1,3-butadiene 

and benzene in several products, including in aromatic concentrate, blendstock, clean petroleum 

products, gasoline blendstock, hydrocarbon blendstock, LPC Pygas, and Pygas. The facility 

corrected the speciation and provided recalculated storage tank emissions based on the speciation 

corrections. For storage tank roof landing loss emissions (part of the facility-wide emissions 

and are not part of MTVLO emissions), the AP-42/API procedures that are used to estimate 

emissions often result in more emissions than the total 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 period. EPA reviewed the data set 

and requested additional clarifications from the facility. EPA incorporated these changes into the 

2005 NEI/NATA to update the data set for this facility and conducted a risk analysis to 

determine the risk for MTVLO and the facility-wide risk. 

In addition, the facility reported in their public comments that they have significantly 

reduced facility-wide HAP emissions since 2005, with work practices, engineering controls, 

participation in the TCEQ’s Find and Fix Initiative, and their 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 (from 77 tpy to 8.3 tpy). The 

facility provided copies of these two agreements. 
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III. References 

Harris, C., KM Liquids Terminals LLC, to Air and Radiation Docket. Docket ID No. EPA-HQOAR-2010-0600, Letter with Comments on EPA’s Proposed Rule – Residual 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 December 6, 2010. 

Textor, M., TPC Group, to Air and Radiation Docket. Docket ID No. EPA-HQ-OAR-2010-

0600, Letter with Comments on EPA’s Proposed Rule – Residual 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 No. EPA-HQ-OAR-2010-0600, Letter 

with Comments on EPA’s Proposed Rule – Residual Risk and Technology Review (RTR) for 

National Emission Standards for Marine Tank Vessel Loading Operations. Docket item no. 

EPA-HQ-OAR-2010-0600-0359. Dated December 6, 2010. 

Schaffner, K., RTI International, to P. Siler, TransMontaigne. Electronic mail suggesting an 

approach for latitude and longitude changes to the 2005 NEI/NATA data set for TransMontaigne 

Fort Lauderdale, FL facility. Dated January 28, 2011. 

 

Siler, P., TransMontaigne, to K. Schaffner, RTI International. Electronic mail accepting latitude 

and longitude changes to the 2005 NEI/NATA data set for TransMontaigne Fort Lauderdale 

facility. Dated February 3, 2011. 

Schaffner, K., RTI International, to S. Shedd, EPA/OAQPS/SPPD/CCG. Draft Trip Report - 

Chevron Pipeline Company, Beaumont, TX for site visit on June 23, 2010. 

Herman, M., Chevron, to K. Schaffner, RTI International. 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 International. 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. Electronic mail providing input on 

the 2005 NEI/NATA HAP emissions dataset for Texas Petrochemicals, Houston TX facility. 

Dated October 12, 2010. 

Schaffner, K., RTI International, to M. Textor, K. Nidini, and C. Chu, TPC Group. Electronic 

mail with questions on the 2005 NEI/NATA HAP emissions dataset for Texas Petrochemicals, 

Houston TX facility. Dated November 15, 2010. 
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Textor, M., TPC Group, to K. Schaffner, RTI International and S. Shedd, 

EPA/OAQPS/SPPD/CCG. Electronic mail providing input on the 2005 NEI/NATA HAP 

emissions dataset for Texas Petrochemicals, Houston TX facility. Dated December 17, 2010. 

Schaffner, K., RTI International, to M. Textor, K. Nidini, and C. Chu, TPC Group. Electronic 

mail with questions on the 2005 NEI/NATA HAP emissions dataset 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 Texas Petrochemicals, Houston 

TX facility. Dated February 1, 2011. 

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

the 2005 NEI/NATA HAP emissions dataset for Texas Petrochemicals, Houston TX facility. 

Dated February 9, 2011. 

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

the 2005 NEI/NATA HAP emissions dataset for Texas Petrochemicals, 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 International. Electronic mail providing 

input on the 2005 NEI/NATA HAP emissions dataset for KM Liquids 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 emissions dataset for KM Liquids 

Terminals, Galena Park TX facility. Dated January 24, 2011. 

Shedd, S., EPA/OAQPS/SPPD/CCG, to B. Higgins, Environ Corporation. Electronic mail 

requesting follow up on benzene and 1,3-butadiene emissions reductions for KM Liquids 

Terminals, Galena Park TX facility. Dated February 23, 2011.

Shankle, G., TCEQ, to S. Kean, Kinder Morgan Energy Partners. 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 for KM Liquids Terminals, Galena 

Park TX facility. Dated December 21, 2006. 
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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.