TECHNICAL SUPPORT DOCUMENT FOR

REVISION OF CERTAIN PROVISIONS: PROPOSED RULE FOR

MANDATORY REPORTING OF GREENHOUSE

GASES

Office of Air and Radiation

U.S. Environmental Protection Agency

July 8, 2010



TABLE OF CONTENTS

  TOC \o "1-1" \h \z \u    HYPERLINK \l "_Toc266342006"  Subpart A: 
Background on Accuracy and Calibration Requirements	  PAGEREF
_Toc266342006 \h  3  

  HYPERLINK \l "_Toc266342007"  Subpart A:  Background Research on
Definitions	  PAGEREF _Toc266342007 \h  10  

  HYPERLINK \l "_Toc266342008"  Subpart C:  Heterogeneity and
Variability of Municipal Solid Waste in Relation to Municipal Waste
Combustor Emissions	  PAGEREF _Toc266342008 \h  11  

  HYPERLINK \l "_Toc266342009"  Subpart C:  Comparison of 250 Tons of
MSW Per Day And 250 MMBtu/hr Heat Input Capacity	  PAGEREF _Toc266342009
\h  23  

  HYPERLINK \l "_Toc266342010"  Subpart X (Petrochemical Production) and
Y (Petroleum Refineries):  Evaluation of Process Heaters Less than 30
MMBtu/hr Rated Heat Capacity	  PAGEREF _Toc266342010 \h  27  

 

Subpart A:  Background on Accuracy and Calibration Requirements

Background:  The current rule provides, with limited exceptions, that 
“flow meters and other devices (e.g., belt scales) that measure data
used to calculate GHG emissions shall be calibrated prior to April 1,
2010 using the procedures specified in this paragraph and each relevant
subpart of this part. All measurement devices must be calibrated
according to the manufacturer’s recommended procedures, an appropriate
industry consensus standard, or a method specified in a relevant subpart
of this part. All measurement devices shall be calibrated to an accuracy
of 5 percent.”  Measurement devices that may be used to comply with
the rule include:

Fuel Mass Flow Meters;

Fuel Volumetric Flow Meters;

Weighing Systems;

Tank Level Sensor; 

Acid Concentration Monitor; and

Methane Analyzer.

EPA has received a number of comments on what the 5% accuracy
requirement really means, which measurement devices it should be applied
to, and whether 5% is an appropriate value.  Based on these questions,
we are reviewing the calibration and accuracy requirements in the rule. 
This document provides some background materials gathered and evaluated
in developing the proposal. 

Accuracy Requirements in Other Reporting Programs

 

1.  Acid Rain Program and NOX Budget Program

Requirements for Continuous Emissions Monitoring are described in 40 CFR
Part 75. The performance specifications for fuel flow meters under Part
75, Appendix D state:

Conduct a flow meter accuracy test using American Society of Mechanical
Engineers (ASME) methods or using comparison to a reference flow meter
designed to American Gas Association (AGA) standards.

Error must be no more than 2.0 percent of full scale (initial
calibration and periodic QA).

QA test required annually.

Information from the Acid Rain Program accuracy tests between 2005 and
2009 show:

Fuel flow meter accuracy ranged between 0.10 and 0.40 percent; and

Transmitter transducer accuracy ranged between 0.20 and 0.50 percent.

Tables A-1 and A-2 in Appendix A summarize the Acid Rain Program
accuracy test results.

	

     2.  California Mandatory GHG Reporting Program

Section 95103(a)(9) of Subarticle 1 General Requirements for the
Mandatory Reporting of Greenhouse Gas Emissions of the California GHG
Reporting Rule has an accuracy requirement for fuel use measurements
that states:

“Fuel Use Measurement Accuracy. The operator shall employ procedures
for fuel use data measurements (mass or volume flow) used to calculate
GHG emissions that quantify fuel use with an accuracy within ±5
percent. All fuel use measurement devices shall be maintained and
calibrated in a manner and at a frequency required to maintain this
level of accuracy. The operator shall make available to the verification
team documentation to support this level of accuracy. The operator who
measures solid fuels shall validate fuel consumption estimates with belt
or conveyor scale calibrations conducted at least quarterly, and retain
record of such calibrations.” (  HYPERLINK
"http://www.arb.ca.gov/cc/reporting/ghg-rep/ghg-rep.htm" 
http://www.arb.ca.gov/cc/reporting/ghg-rep/ghg-rep.htm )

California originally proposed an accuracy requirement of ±2.5 percent.
The Final Statement of Reasons for Rulemaking responded to public
comments regarding the accuracy requirement. Commenters stated that the
±2.5 percent uncertainty requirement is too stringent and is not
achievable with most of the existing flow measurement devices used in
the petroleum industry. 

California also recognized there could be measurement difficulties for
some facilities and fuel types, including solid fuels.  The response to
comments document concluded that, “Because it is impractical to write
into the regulation detailed specifications for evaluating the absolute
accuracy of measurements for each solid fuel, we chose to require in
section 95103(a)(9) that facility operators employ procedures to ensure
a fuel activity accuracy of ±5 percent. Operators must maintain and
calibrate equipment to meet this level of accuracy, and maintain
appropriate records.

California modified the original accuracy requirement of ±2.5 to ±5.0
percent for the final rule. 

The California regulation and Final Statement of Reasons for Rulemaking
did not contain additional detail on the rational for the 5 percent
accuracy requirement or the change from the original 2.5 percent
requirement.

What is the typical range of accuracy achievable for other measurement
devices used in Part 98 (e.g., belt scales, weigh hoppers, truck weigh
scales)?

Based on information from internet product searches and vendor
information, measurement devices typically have accuracy ranges less
than ± 5 percent.

 

The Instrument Engineers Handbook lists load cell performance
specifications for individual load cells which have accuracy ranges
between 0.03 and 1 percent. Table A-3 in Appendix A lists typically
accuracies for various types of load cells.

Vendor information found through internet searches also showed accuracy
ranges of less than 5 percent. The accuracy ranges obtained from the
vendor information for devices that may be used in GHG reporting are
listed below. Table A-4 in Appendix A contains the detailed information
by vendor.

Mass flow meter  –  0.2 percent to 1 percent;

Volumetric flow meter – 0.125 to 1 percent;

Load cell accuracy – 0.02 to 5 percent;

Liquid level sensors – 0.075 to 2 percent;

Concentration monitors – 0.1 to 2 percent; and

Landfill gas monitors – 0.1 to 3 percent.

Uniform Accuracy Requirements Across Part 98 Versus Subpart-specific? 

The range of accuracy of new measurement technologies on the market
today does not suggest that different accuracy requirements are needed
by type of technology, if the required standard is near 5%.  If
differentiation is needed, it may be driven by the cost of maintenance
and replacement of older equipment that cannot meet the 5% requirement. 
Therefore, if differentiation is necessary, it may be needed by industry
rather than technology, as explained below.

The standards for accurately weighing raw materials and products are
likely to vary between industries, and between facilities within an
industry, and even among separate processes within a single facility.

Different processes are likely to be more or less tolerant of different
accuracies, so a single standard for accuracy is probably not in
practice among all industries.

Different standards for accuracy also apply depending on whether the
material is being weighed and used within a plant for process control,
or weighed as part of a sale or purchase in commerce.  Process control
may not require the same level of accuracy as in commerce.  

Additional information from specific industries could be needed to
identify the customary level of accuracy associated with those
industries and variables that are of most critical interest in the GHG
emission calculations.

In commerce, weighing devices are likely to conform to NIST Handbook 44,
if a device is used.  Pennsylvania, for example, specifies that weighing
devices used in commerce must comply with NIST Handbook 44 (see, for
example, Pa. Code Title 70, Weights, Measures And Standards; Chapter 10.
Device Type Approval;   HYPERLINK
"http://www.pacode.com/secure/data/070/chapter10/chap10toc.html" 
http://www.pacode.com/secure/data/070/chapter10/chap10toc.html ).
Enforcement, inspection, and certification (“sealing”) is done at
the county level.

Appendix A – Supporting Tables

TABLE A-1. SUMMARY OF FUEL FLOWMETER ACCURACY TEST BETWEEN 2005 & 2009

ACCURACY TEST METHOD CODE DESCRIPTION	TEST METHOD CODE	TOTAL TEST	AVG
LOW LEVEL ACCURACY

(PERCENT)	AVG MID LEVEL ACCURACY

(PERCENT)	AVG HIGH LEVEL ACCURACY

(PERCENT)

AGA Report No. 7, Measurement of Natural Gas by Turbine Meter	AGA7	19
0.10	0.10	0.10

American Petroleum Institute Method in Appendix D	API	32	0.20	0.20	0.20

ASME Method in Appendix D	ASME	40	0.40	0.20	0.30

In-Line Comparison against Master Meter at Facility	ILMMF	251	0.10	0.20
0.30

International Organization for Standardization Method in Appendix D	ISO
33	0.30	0.30	0.40

Laboratory Comparison against Reference Meter	LCRM	530	0.20	0.20	0.20

NIST-Traceable Method Approved by Petition	NIST	84	0.20	0.20	0.20



TABLE A-2. SUMMARY OF TRANSMITTER TRANSDUCER TEST BETWEEN 2005 & 2009

TEST TYPE

LOW LEVEL ACCURACY	MID LEVEL ACCURACY	HIGH LEVEL ACCURACY

ACCURACY SPEC CODE DESCRIPTION	ACCURACY SPEC CODE	TOTAL TEST 	AVG

(PERCENT)	TOTAL TEST 	AVG 

(PERCENT)	TOTAL TEST 	AVG (PERCENT)

Actual Accuracy of Each Component	ACT	1,221	0.20	1,198	0.20	1,198	0.20

Sum of Accuracies of All Components	SUM	678	0.30	703	0.50	702	0.50





Table A-3. Load Cell Performance Comparison

Type	Weight Range	Accuracy (Full Scale)	Applications	Strengths
Weaknesses

Mechanical Load Cells

Hydraulic Load Cells	Up to 10,000,000 lb	0.25%	Tanks, bins and hoppers.
Takes high impacts,	Expensive, complex.



	Hazardous areas.	insensitive to temperature.

	Pneumatic Load Cells	Wide	High	Food industry, hazardous areas
Intrinsically safe.	Slow response.





Contains no fluids.	Requires clean, dry air

Strain Gage Load Cells

Bending Beam Load Cells	10-5,000 lbs.	0.03%	Tanks, platform scales,	Low
cost, simple construction	Strain gages are exposed, require protection

Shear Beam Load Cells	10-5,000 lbs.	0.03%	Tanks, platform scales, off-
center loads	High side load rejection, better sealing and protection	 

Canister Load Cells	to 500,000 lbs.	0.05%	Truck, tank, track, and hopper
scales	Handles load movements	No horizontal load protection

Ring and Pancake Load Cells	5- 500,000 lbs.	 	Tanks, bins, scales	All
stainless steel	No load movement allowed

Button and washer Load Cells	0-50,000 lbs	1%	Small scales	Small,
inexpensive	Loads must be centered, no load movement permitted

	0-200 lbs. typ.





Other Load Cells

Helical	0-40,000 lbs.	0.20%	Platform, forklift, wheel load, automotive
seat weight	Handles off-axis loads, overloads, shocks	 

Fiber optic	 	0.10%	Electrical transmission cables, stud or bolt mounts
Immune to RFI/EMI and high temps, intrinsically safe	 

Piezo-resistive	 	0.03%	 	Extremely sensitive, high signal output
level	High cost, nonlinear output

Source: Instrument Engineers Handbook, Process Measurement and Analysis,
Fourth Edition, 2003



Table A-4. Example Vendors for Measurement Devices and Device Accuracy

Vendor	Accuracy 

Mass Flow Meters

Alicat Scientific 	0.8% of reading + 0.2% of full scale for most models

Sierra Instruments	1% of full scale for most models

MKS Instruments 	1% of full scale for most models

TSI 	2% of reading a full scale for most models

Brooks Instrument 	0.2%, 0.5% or 1% depending on model

Bronk Horst High Tech 	0.2% of reading and 0.2% of full scale

Fluid Components International	0.5% for gases

Volumetric Flow Meters

Sure Flow Products	0.5% - 1% of full scale

Instramart	0.8% of reading + 0.2% of full scale for Flocat LA10-A Gas
flow meter

Liquid Controls	0.125 – 0.5% of reading – liquid volume meters

Liquid Level Sensors

SensorOne 	0.25% of full scale for most products

SSI Technologies Inc	2% of full scale

Endress+Hauser 	0.075% to 0.2%

Concentration Monitors (for liquid acids and bases)

Horiba 	1% for most products

Jetalon Solutions, Inc 	0.1% for the CR-288

Analytical Technology, Inc 	2% of full scale for Q45/85 Peracetic acid
monitor

Landfill Gas Monitors

Geotech GA2000 Portable Gas Analyzer 

	Gas Accuracy depends on concentration level:

CH4: ±0.5 – 3.0

CO2: ±0.5 – 3.0

O2: ±1.0

Enviro-Equipment, Inc. CES-LANDTEC GEM-2000 

	CH4: Range 0-100%	Resolution 0.1%

CO2: Range 0-60%	Resolution 0.1%

O2: Range 0-25%	Resolution 0.1%

Flow Accuracy ±3% 50-150 SCFM

Load Cells 

Vendor	Equipment Type	Accuracy (full scale)

Honeywell	Compression Canister Load Cells	1%

	S-Beam Load Cells	0.02%

	Pancake Type Load Cells	0.1%

	Ring Type Load Cells	1%

ADI Artech	S-Beam Load Cells	1%

	Shear Beam Load Cells	1%

	Bending Beam Load Cells	1%

	Compression Canister Load Cells	1%

Eilerson Insdustrial Sensors	Various Load Cell Types	0.25%

Control Systems Technology	Weigh Hoppers	0.5%

	Belt Feeder	0.1-5%

Siemens Industry USA	Weigh Hoppers	0.25-0.5%

	Belt Weighers	0.5-2%

Avery Weigh Tronics	Truck and Railroad Scales	0.25-0.4% (static)

0.5% or +/- 400 lbs; whichever is higher (in motion)

	Floor Scales	0.05%

	Compression Load Cells	0.05%

Kistler-Morse	Compression Load Cells	0.08%

Rice Lake Weighing Systems	Belt Scales	0.25%



   

Subpart A:  Background Research on Definitions

EPA is proposing to add definitions of the following terms to 40 CFR
98.6 due to the large number of questions received requesting
clarification of the definition of these terms:  agricultural
byproducts, primary fuel, solid byproducts, waste oil, and wood
residuals.  The proposed definitions are based on the results of an
Internet search and experience with terms in the Acid Rain Program

For the purposes of Part 98, “Agricultural byproducts” would include
the parts of crops that are not ordinarily used for food (e.g., corn
straw, peanut shells, pomace, etc.).  “Solid byproducts” would
include plant matter such as vegetable waste, animal materials/wastes,
and other solid biomass, except for wood, wood waste and sulphite lyes
(black liquor).  “Wood residuals” would include waste wood recovered
primarily from MSW streams, construction and demolition debris, and
primary timber processing.  Wastewater process sludge generated at pulp
and paper mills would also be included; however, we are soliciting
comment on whether the default emission factors for wood and wood
residuals are appropriate for paper mill wastewater sludge, and, if not,
what those emission factors should be.  “Primary fuel” would be
defined as the fuel that contributes the greatest percentage of the
annual heat input to a combustion unit.  “Waste oil,” which we are
proposing to add to Table C-1 as a new fuel type, would be defined as
oil whose physical properties have changed, either through storage,
handling, or use, so that the oil can no longer be used for its original
purpose.  Waste oil would include both automotive and industrial oils of
various types. 

This document includes some relevant references. 

Agricultural By-products:

  HYPERLINK
"http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/display.abstra
ctDetail/abstract/8953/report/0" 
http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/display.abstrac
tDetail/abstract/8953/report/0 

  HYPERLINK
"http://pubs.acs.org/doi/pdf/10.1021/ie50350a007?cookieSet=1" 
http://pubs.acs.org/doi/pdf/10.1021/ie50350a007?cookieSet=1 

  HYPERLINK "http://www.unu.edu/unupress/unupbooks/80362e/80362E04.htm" 
http://www.unu.edu/unupress/unupbooks/80362e/80362E04.htm 

Primary Fuel:

  HYPERLINK
"http://edocket.access.gpo.gov/cfr_2008/julqtr/pdf/40cfr72.2.pdf" 
http://edocket.access.gpo.gov/cfr_2008/julqtr/pdf/40cfr72.2.pdf  

Waste Oil:

  HYPERLINK "http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s11.pdf" 
http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s11.pdf 

  HYPERLINK "http://en.wikipedia.org/wiki/Waste_oil" 
http://en.wikipedia.org/wiki/Waste_oil 

Wood Residuals

  HYPERLINK "http://www.fpl.fs.fed.us/documnts/pdf1998/mckee98a.pdf" 
http://www.fpl.fs.fed.us/documnts/pdf1998/mckee98a.pdf 

Subpart C:  Heterogeneity and Variability of Municipal Solid Waste in
Relation to Municipal Waste Combustor Emissions

 

Background and Summary

MSW is a fuel for MWCs, which are a category of stationary combustion
sources covered under Subpart C of EPA’s Mandatory Greenhouse Gas
Reporting rule (2009). Subpart C requires stationary combustion sources
to report their carbon dioxide emissions and establishes four tiers of
methods for stationary combustion sources to calculate or physically
measure their carbon dioxide emissions.  These include:

Tier 2: Mass Balance Calculations. This method estimates the annual mass
of CO2 emissions for MWCs by multiplying the mass of steam generated by
MSW combustion, by the efficiency of steam generation and by a default
CO2 emission factor for MSW.

Tier 4: Continuous Emissions Monitoring. This method requires hourly
measurements of CO2 concentration and stack gas volumetric flow rate to
calculate the mass of CO2 emissions.

Carbon dioxide (CO2) emissions from MWCs are a function of the
composition of MSW that they burn for fuel. As a result, the choice of
monitoring techniques will depend upon the extent to which the
composition of MSW used as a fuel for combustion in MWCs varies.

Under Subpart C, MWCs with a maximum rated heat capacity greater than
250 tons per day are required to apply the Tier 4 method and use
continuous emissions monitoring systems to directly measure their carbon
dioxide emissions on a continuous basis if the unit meets the six
requirements in 98.33(b)(4)(ii).  Units equal to or less than 250 tons
per day are required to use Tier 4 if they meet the three conditions
outlined in 98.33 (b)(4)(iii).  Stakeholders have expressed concern,
contesting the requirement for the Tier 4 monitoring method.  The
stakeholder advocates the use of the Tier 2 mass balance estimate method
instead, asserting that application of the Tier 4 method is ‘costly’
and that there is ‘no logical basis’ for this requirement in the
stated purpose of the Mandatory Greenhouse Gas Reporting Rule.

The purpose of this document is to provide background on the factors
influencing MSW composition variability, how these factors contribute to
variability in CO2 emissions through the carbon content and ratio of
fossil carbon to biogenic carbon in MSW, and the range of possible
variation of composition. 

Both the overall carbon content and the ratio of fossil carbon to
biogenic carbon of MSW varies according to the composition of biogenic
and non-biogenic carbon-based materials in the MSW. The principal
components and average national composition of MSW in 2008 are shown in 
 REF _Ref253493775 \h  Table 1 , as estimated by EPA (2009) in Municipal
Solid Waste Generation, Recycling, and Disposal in the United States
Detailed Tables and Figures for 2008.

Table   SEQ Table \* ARABIC  1 : Principal components of MSW and amount
of each component generated in the United States in 2008 (EPA 2009)

Material	Generation	Share of total

	short tons

	Paper	77,420	31%

Glass	12,150	5%

Metals	20,850	8%

Plastics	30,050	12%

Rubber and leather	7,410	3%

Textiles	12,370	5%

Wood	16,390	7%

Food scraps	31,790	13%

Yard trimmings	32,900	13%

Miscellaneous inorganic wastes	3,780	2%

Other	4,500	2%

Total	249,610	100%



Non-biogenic carbon-based materials primarily consist of plastics,
synthetic textiles, and rubber; biogenic materials include paper,
natural textiles (e.g., cotton, linen), wood, food waste, and yard
trimmings (EIA 2007). Glass and metals are inorganic materials.

There are four types of compositional variability in the MSW stream:
variability in the definition of MSW, geographic variability, seasonal
variability, and long-term compositional trends. Each of these factors
is discussed below.  Each factor can result in considerable
site-specific variation in the CO2 emissions from MWCs and the ratio of
fossil to biogenic CO2 in MSW burned in MWCs. Consequently, CO2
emissions from MWCs are much harder to characterize accurately using
mass balance or other calculation methods than are CO2 emissions from
other stationary combustion sources covered under Subpart C of EPA’s
Mandatory Greenhouse Gas Reporting rule (2009).  Other types of
stationary combustion sources such as fossil fuel-fired combustors 
generally have a relatively homogeneous fuel source with relatively
well-characterized fossil C content.

Description of four types of variability in the MSW stream

Variability in the definition of MSW

Municipal solid waste or MSW can be defined as solid phase household,
commercial/retail, and/or institutional waste. Household waste includes
material discarded by single and multiple residential dwellings, hotels,
motels, and other similar permanent or temporary housing establishments
or facilities.  Commercial/retail waste includes material discarded by
stores, offices, restaurants, warehouses, non-manufacturing activities
at industrial facilities, and other similar establishments or
facilities. Institutional waste includes material discarded by schools,
nonmedical waste discarded by hospitals, material discarded by
non-manufacturing activities at prisons and government facilities, and
material discarded by other similar establishments or facilities. 
Household, commercial/retail, and institutional waste does not include
used oil, wood pellets, construction, renovation, and demolition wastes
(which includes, but is not limited to, railroad ties and telephone
poles), clean wood, industrial process or manufacturing wastes, medical
waste, or motor vehicles (including motor vehicle parts or vehicle
fluff).  Household, commercial/retail, and institutional wastes include
yard waste, refuse-derived fuel, and motor vehicle maintenance
materials, limited to vehicle batteries and tires, except where a single
waste stream consisting of tires is combusted in a unit. 

Biocycle magazine’s State of Garbage in America series has reported
frequently on the challenges of characterizing the generation and
composition of MSW. Inconsistencies in state-level data led Biocycle to
revise its methodology for estimating the generation and composition of
MSW (Biocycle 2004), but problems persist in compiling an accurate
estimate of MSW generation and composition in the United States through
a state-by-state bottom-up estimate (Biocycle 2006, p. 28):

Wastes that are typically not considered part of the MSW stream, such as
construction and demolition materials, automobile scrap, industrial
wastes, biosolids, and agricultural wastes, may be classified as MSW in
state estimates.

Each state has its own method for collecting state-wide MSW management
information; there is a high degree of certainty in the overall tonnages
of MSW that are landfilled and that are combusted due to reporting
requirements, but recycling and yard trimming composting facilities are
often not required to report throughput; and

Exported MSW is not tracked by all states, and some states are not able
to distinguish non-MSW waste exports from MSW exports.

Challenges in accurately and consistently defining the wastes that
constitute MSW can lead to mischaracterization of MSW as a fuel for
combustion in MWCs. Non-MSW wastes may have substantially different
carbon contents and fractions of fossil and biogenic components; for
example, wood can form a large share of construction and demolition
debris. Consequently, CO2 emissions from wastes considered MSW that are
combusted in MWCs, but which fall outside of EPA’s definition of MSW,
can lead to different CO2 emissions than might be predicted using
default emission factors.  

Geographic variability

The composition of MSW varies geographically across the United States.
Geographic variability is driven by factors such as the following (EPA
2008, p. 21):

“Variance in the per capita generation of some products, such as
newspapers and telephone directories, depending upon the average size of
the publications. Typically, rural areas will generate less of these
products on a per person basis than urban areas.

“Level of commercial activity in a community. This will influence the
generation rate of some products, such as office paper, corrugated
boxes, wood pallets, and food scraps from restaurants.

“Variations in economic activity, which affect waste generation in
both the residential and the commercial sectors.

 “Local and state regulations and practices. Deposit laws, bans on
landfilling of specific products, and variable rate pricing for waste
collection are examples of practices that can influence a local waste
stream.”

MSW combustion occurs predominantly in the northeast and southern
regions of United States, shown in   REF _Ref253665144 \h  Table 2 .
According to   REF _Ref253665181 \h  Figure 1 , Connecticut combusts 65%
of its MSW, and Florida, Hawaii, Maine, and Massachusetts manage over
20% of their MSW in waste-to-energy projects. Twenty states do not have
any MWCs within their borders.

Table   SEQ Table \* ARABIC  2 : Municipal waste-to-energy projects by
U.S. region (EPA 2008, p. 151)

Figure   SEQ Figure \* ARABIC  1 : Share of waste management methods
employed by U.S. states, as a percentage of total tonnage of MSW
generation (Adapted from Arsova et al., 2008)

As shown in   REF _Ref253658813 \h  Figure 1 , bans on scrap tires, used
oil, and lead-acid batteries are common, but bans on other types of
goods such as yard trimmings, white goods, and electronics are more
variable. State-level regulations banning disposal of materials in MSW
landfills can influence the composition of waste that is sent to MWCs. 
Often the regulations govern waste haulers.  The boundaries of
“wastesheds” can shift day by day as a function of relative tipping
fees for landfilling versus combustion.  Thus, as the haulers (and/or
the municipalities they serve) try to divert materials from landfills,
they also divert them from combustors.  

Figure   SEQ Figure \* ARABIC  2 : MSW landfill disposal bans for
selected materials (Arsova et al., 2008). Notes: (1) most of these bans
pertain to landfilling, but they may influence composition of waste
destined for combustors as well; (2) state regulations may have changed
since the date of publication of this table.

The level of recovery through recycling programs can also influence the
composition of MSW. Paper components such as newspaper, cardboard,
office paper, and mixed paper types are collected through recycling
programs, often at a high rate of recovery. The recovery rate (i.e., the
quantity of materials recovered for recycling as a percentage of total
waste generated, not including any losses or contamination of
recyclables), of municipal recycling systems is variable on a
municipal/county level as well as by state, as shown by   REF
_Ref253582977 \h  Figure 2 .  The rates depend upon a number of
technical and non-technical factors, including the type of recycling
system (e.g., single-stream versus dual-stream curbside collection), the
age of the program (i.e., how long it has been established), the level
of public outreach, municipal policies such as variable-rate waste
collection (also known as Pay As You Throw, or PAYT), frequency of
collection, and demographics (e.g., recovery rates are correlated with
median household income). Other practices, such as the level of backyard
composting in a region, can also affect the recovery rate of materials
in certain communities (EPA 2008, p. 21). Recovery of paper, yard
trimmings, and other materials will influence the carbon content and
ratio of fossil-to-biogenic components of MSW sent to MWCs for
combustion, and, consequently, the resulting CO2 emissions.

  REF _Ref253385703 \h  Figure 3  provides data on of the range of
geographic variability in the MSW stream by summarizing state-level
MSW-sort data (i.e., the composition of MSW after recovery from
recycling programs). The figure illustrates that paper and organics
(i.e., food waste and yard trimmings) components in particular exhibit a
high level of variability, fluctuating by nearly 20 percent (as a
fraction of total MSW wet weight) across different states. Plastics have
been observed to constitute from 6 (in Kansas) to 18 percent (in Iowa)
of the MSW stream. The data reveal that there is significant geographic
variability in the composition of MSW, particularly the fractions that
contribute to fossil and biogenic CO2 emissions.

Seasonal variability

The composition of MSW varies seasonally, according to variations in
climate as well as economic and demographic waste generation factors
each year (EPA 2008, p. 21). Examples of factors that contribute to
seasonal variability in the composition of MSW—yard trimmings in
particular—include the following trends:

Increased generation of grass clippings in spring, summer, and fall
months (and in most climates, no generation in the winter),

The occurrence of autumn leaves (September/October/November) in areas
with deciduous forests and urban trees, and

Generation of Christmas tree and wrapping paper waste in
December/January.

Local and/or state policies may also have an impact on the level of
seasonal variation in MSW composition. Since many states ban yard
trimmings, autumn leaves, and Christmas trees from the MSW stream (see  
REF _Ref253658813 \h  Figure 1 ), the level of seasonal variation in the
generation of yard trimmings will be less in these jurisdictions.

MWCs have limited ability to even out the seasonal variation  since it
is generally not feasible to store MSW for more than a few days prior to
combustion (due to odor and hygiene concerns).  Consequently, the
underlying seasonal variation in MSW that fuels MWCs will translate to
seasonal variation in CO2 emissions as well.

(a) New Mexico

(b) Massachusetts

 (c) New Hampshire

Figure   SEQ Figure \* ARABIC  3 : Distribution of recovery rates across
counties and municipalities using different recycling programs in (a)
New Mexico, (b) Massachusetts, and (c) New Hampshire. Note: The vertical
axes differ in scale.

Figure   SEQ Figure \* ARABIC  4 : Variation in composition of discarded
MSW streams by state (Staley & Barlaz, 2009). Paper and organics
(composed of yard trimmings and food scraps) result in biogenic CO2
emissions when combusted, while plastics result in fossil CO2 emissions.
Glass and metal fractions are not combustible and do not result in CO2
emissions. Durables include appliances/electronics, carpets, and other
miscellaneous/bulky items, and residues include other unspecified waste
fractions; these categories may also contain materials that generate
fossil or biogenic CO2 emissions in MWCs.

Long-term compositional trends

Long-term changes in MSW composition also contribute to variability in
the MSW stream. Over time, the types of materials entering the MSW
stream are changing to reflect patterns of production, consumption, and
waste generation in the United States.

For example, the U.S. Energy Information Administration (EIA) has
studied energy generation from fossil and biogenic wastes in MSW. They
found two trends in the composition of the MSW stream from 1989 to 2007:
first, the heat content (BTUs per pound) of MSW has increased, and
second, the fossil fraction of MSW has increased relative to the
biogenic fraction (EIA 2007).   REF _Ref253665419 \h  Table 3  and   REF
_Ref253571706 \h  Figure 5  shows how the fossil fraction of MSW has
increased relative to the biogenic share on a heat-content basis from
1989 to 2005 within the United States. EIA attributes this trend to
“more plastics being discarded at the same time that decreasing
amounts of paper and paper products are entering the waste stream”
(EIA 2007, p. 5). 

The estimates developed by EIA highlight the effect that long-term
compositional trends can have on CO2 emissions from MSW combustion.
Changes in the heat content and ratio of fossil to biogenic components
of MSW will influence both the carbon content of MSW combusted as fuel
as well as the fossil-to-biogenic ratio of CO2 emissions.

Table   SEQ Table \* ARABIC  3 : MSW heat content and biogenic/fossil
shares from 1989 to 2005 (EIA 2007, p. 6)

Figure   SEQ Figure \* ARABIC  5 : Trends in fossil and biogenic
fractions of MSW on a heat-content basis (EIA 2007)

* * * * * * *

 

In sum, the composition of MSW is very heterogeneous – containing
thousands of individual materials and over a dozen different categories
of materials – and extremely variable on a geographic and temporal
basis.  This underlying variability in the composition of the fuel of
MWCs implies that accurate monitoring requires frequent sampling, and an
approach to either characterize the fossil and biogenic components of
the fuel or, more directly, of the emissions themselves.  

References

Arsova, L., Haaren, R. V., Goldstein, N., Kaufman, S. M., & Themelis, N.
J. (2008). The State Of Garbage in America. Biocycle. Retrieved from  
HYPERLINK "http://www.jgpress.com/archives/_free/001782.html" 
http://www.jgpress.com/archives/_free/001782.html 

EPA. (2006). Solid Waste Management and Greenhouse Gases: A Life-Cycle
Assessment of Emissions and Sinks. U.S. Environmental Protection Agency
(EPA). Retrieved from   HYPERLINK
"http://epa.gov/climatechange/wycd/waste/reports.html" 
http://epa.gov/climatechange/wycd/waste/reports.html 

EPA. (2008). Municipal Solid Waste in the United States: 2007 Facts and
Figures. U.S. Environmental Protection Agency (EPA). Retrieved from  
HYPERLINK "http://www.epa.gov/osw/nonhaz/municipal/msw99.htm" 
http://www.epa.gov/osw/nonhaz/municipal/msw99.htm 

EPA. (2009). Municipal Solid Waste in the United States: 2008 Facts and
Figures, Data Tables. U.S. Environmental Protection Agency (EPA).
Retrieved from   HYPERLINK
"http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw2008data.pdf" 
http://www.epa.gov/epawaste/nonhaz/municipal/pubs/msw2008data.pdf 

EIA. (2007). Methodology for Allocating MSW to Renewable/Non-Renewable
Energy. Energy Information Administration (EIA). Retrieved from  
HYPERLINK
"http://www.eia.doe.gov/cneaf/solar.renewables/page/mswaste/msw_report.h
tml" 
http://www.eia.doe.gov/cneaf/solar.renewables/page/mswaste/msw_report.ht
ml 

Friedland, D. (2009). Petition for Reconsideration. Beveridge and
Diamond. Petition for reconsideration of Mandatory Reporting of
Greenhouse Gases, Final Rule.

IPCC. (2006). 2006 IPCC Guidelines for National Greenhouse Gas
Inventories. Volume 3: Industrial Process and Product Use, Chapter 3:
Chemical Industry Emissions. Retrieved from   HYPERLINK
"http://www.ipcc-nggip.iges.or.jp/public/2006gl/vol3.html" 
http://www.ipcc-nggip.iges.or.jp/public/2006gl/vol3.html 

Mandatory Greenhouse Gas Reporting, 74 Fed. Reg. 56374 (2009).

Staley, B. F., & Barlaz, M. A. (2009). Composition of Municipal Solid
Waste in the United States and Implications for Carbon Sequestration and
Methane Yield. Journal of Environmental Engineering, 135(10), 901-909.
doi:   HYPERLINK "http://dx.doi.org/10.1061/(ASCE)EE.1943-7870.0000032" 
10.1061/(ASCE)EE.1943-7870.0000032   

Subpart C:  Comparison of 250 Tons of MSW Per Day And 250 MMBtu/hr Heat
Input Capacity

Background and Summary

MSW is a fuel for MWCs, which are a category of stationary combustion
sources covered under Subpart C of EPA’s Mandatory Greenhouse Gas
Reporting Rule. Subpart C requires stationary combustion sources to
report their carbon dioxide emissions and establishes four tiers of
methods for stationary combustion sources to calculate or physically
measure their carbon dioxide emissions.

According to sections 40 CFR § 98.33(b)(4)(ii)(A), stationary
combustion units with a “maximum rated heat input capacity greater
than 250 mmBtu/hr, or if the unit combusts municipal solid waste […] a
maximum rated input capacity greater than 250 [short] tons per day of
MSW” that meet the other five conditions in paragraphs (b)(4)(ii)(B)
through (b)(4)(ii)(F) must use the Tier 4 Calculation Methodology to
calculate their carbon dioxide emissions. Some owners and operators of
MWCs contended that the threshold of 250 short tons per day of MSW is
more stringent than the 250 mmBtu/hr heat input threshold for other
stationary combustion units, and therefore places a disproportionate
burden on MWCs.

This memorandum evaluates approximate equivalencies between the 250
short tons of MSW per day threshold for units combusting MSW and the 250
mmBtu/hour heat input capacity threshold for other stationary combustion
units. The calculation and relevant data are provided below.

Calculation and Data Sources

The formula for converting the maximum rated heat input capacity of a
MWC unit in short tons per day into an equivalent maximum rated heat
input capacity can be expressed as follows:

MSW input rate [short tons/day] * MSW heating value [mmBtu/short ton] ÷
N [hours/day]= Heat input rate [mmBtu/hour]

Where,

	MSW input rate = the maximum rated input capacity of the unit, in short
tons per day

	MSW heating value = the heat rate of MSW, in mmBtu per short ton

N = the time period over which MWC operation is evaluated in a day to
determine maximum rated input capacity, in hours per day 

Heat input rate = the maximum rated heat input capacity of the unit, in
mmBtu per hour

To evaluate the equivalent heat input capacity at rates of 250 short
tons/day and 250 short tons/day, two parameters are required: (i) the
heating value of MSW combusted in MWCs, and (ii) the number of hours per
day over which MWC operation is evaluated to determine maximum rated
input capacity.

Heating value of MSW Combusted in MWCs

Estimates of the heating value of MSW are given in   REF _Ref264890501
\h  Table 1 . Due to the considerable heterogeneity of MSW, heating
value estimates range from 4,500 to 5,865 Btu/pound, or 9.0 to 11.7
mmBtu/short ton. This range reflects the variability in MSW composition
resulting from geographic variability, seasonal patterns in MSW
disposal, and long-term trends in MSW generation.

Table   SEQ Table \* ARABIC  1 : Heating value for estimates for MSW

Heating value of MSW	Notes	Source

Btu/pound	mmBtu/short ton



4,500	9.00	MSW that is not refuse-derived fuel	EPA (1996), p. 2.1-29

5,500	11.00	MSW refuse-derived fuel	EPA (1996), p. 2.1-29



5,040	10.08	Heating value of MSW in 1989; based on estimates of
material-specific heating values and U.S. MSW composition taken from EPA
(2006) Facts and Figures: 2005.	EIA (2007), Table 1, p. 6

5,865	11.73	Heating value of MSW in 2005; based on estimates of
material-specific heating values and U.S. MSW composition taken from EPA
(2006) Facts and Figures: 2005.	EIA (2007), Table 1, p. 6



Number of Hours Per Day Over Which MWC Operation is Evaluated to
Determine Maximum Rated Input Capacity

Second, according to 40 CFR § 60.58b(j), the maximum rated input
capacity of MWCs is evaluated over a 24-hour period (i.e., N = 24),
regardless of whether the MWC operates continuously or as a batch-feed
operation. The procedures for calculating MWC unit capacity are defined
as follows:

For MWC units that are capable of combusting MSW continuously for a
24-hour period, “the unit capacity shall be calculated based on 24
hours of operation at the maximum charging rate”, where the maximum
charging rate is either:

The maximum design heat input capacity of the unit multiplied by a
heating value for the MSW fuel combusted, for combustors designed based
on heat capacity, or

The maximum design charging rate, for combustors not designed based on
heat capacity.

For batch-feed MWC units, unit capacity is calculated “as the maximum
design amount of municipal solid waste that can be charged per batch
multiplied by the maximum number of batches that could be processed in a
24-hour period.”

40 CFR § 60.58b(j) also specifies that the MSW heating values to
convert the design heat input capacity of a MWC into the unit’s input
capacity shall be “12,800 kilojoules per kilogram for combustors
firing refuse-derived fuel and […] 10,500 kilojoules per kilogram for
combustors firing municipal solid waste that is not refuse-derived
fuel”. These values correspond to MSW heat rates of 9.0 and 11.0
mmBtu/short ton respectively, consistent with the EPA (1996) values from
AP-42, identified in   REF _Ref264890501 \h  Table 1 .

Results

  REF _Ref264890494 \h  Table 2  provides the equivalent maximum rated
heat input capacities for two different MWC unit rated input capacities
using the equation and parameters provided above. Due to the variability
in MSW heating values, we selected three MSW heat input values: a low
value of 9 mmBtu/short ton; a medium value of 10 mmBtu/short ton, and a
high value of 12 mmBtu/short ton. This range is representative of the
values provided by   REF _Ref264890501 \h  Table 1  above, and in 40 CFR
§ 60.58b(j).

Table   SEQ Table \* ARABIC  2 : Equivalent maximum rated heat input
capacity at various MSW heat input rates for two different MWC rated
input capacities

Max.  rated input capacity (short tons/day)	Equivalent maximum rated
heat input capacity (mmBtu/hour)

	Low MSW heat input

(9 mmBtu/short ton)	Medium MSW heat input

(10 mmBtu/short ton)	High MSW heat input

(12 mmBtu/short ton)

250	94	104	122

600	225	250	300

Notes:	Calculated over a 24-hour operating period (i.e., N = 24
hours/day)

Gray = below 250 mmBtu/hr threshold for other stationary combustion
units

	Black = equal to 250 mmBtu/hr threshold for other stationary combustion
units

	Bold = above 250 mmBtu/hr threshold for other stationary combustion
units

The 250 short tons/day input capacity threshold is more stringent than
the 250 mmBtu/short ton heat input capacity threshold, regardless of the
MSW heating value. Using the medium MSW heat input value of 10
mmBtu/short ton, a threshold of 600 short tons of MSW per day is
equivalent to the 250 mmBtu/hour threshold that applies to other
stationary sources. MWCs that combust MSW with heating values higher
than 10 mmBtu/short ton will have a higher equivalent maximum rated heat
input capacity; MWCs that combust MSW with heating values lower than 10
mmBtu/short ton will have a lower equivalent maximum rated heat input
capacity.

Conclusion

Acknowledging the variability in MSW composition and heat content, a
threshold of 600 short tons of MSW per day is consistent with the 250
mmBtu/hour threshold that applies to other stationary combustion units
for Tier 4 reporting in 40 CFR § 98.33(b)(4)(ii).

References

EIA. (2007). Methodology for Allocating MSW to Renewable/Non-Renewable
Energy. Energy Information Administration (EIA). Retrieved from  
HYPERLINK
"http://www.eia.doe.gov/cneaf/solar.renewables/page/mswaste/msw_report.h
tml" 
http://www.eia.doe.gov/cneaf/solar.renewables/page/mswaste/msw_report.ht
ml , accessed June 21, 2010.

EPA (1996) AP 42, Fifth Edition, Volume I Chapter 2:  Solid Waste
Disposal, Section 2.1: Refuse Combustion, p. 2.1-29. Retrieved from  
HYPERLINK "http://www.epa.gov/ttn/chief/ap42/ch02/index.html" 
http://www.epa.gov/ttn/chief/ap42/ch02/index.html , accessed June 21,
2010.

Subpart X (Petrochemical Production) and Y (Petroleum Refineries): 
Evaluation of Process Heaters Less than 30 MMBtu/hr Rated Heat Capacity

I.	Purpose

The purpose of this memorandum is to document the evaluation of process
heaters that have a rated heat capacity of less than 30 million British
thermal units per hour (MMBtu/hr). 

II.	Summary of Findings

Small process heaters (those with rated heat capacity less than 30
MMBtu/hr) are generally not subject to Federal or consent decree
emission limits and therefore are not typically required to monitor fuel
gas usage at the individual process heater or boiler.  These small
process heaters are expected to contribute less than 5 percent of the
stationary combustion source emissions. 

III.	Background

The U. S. Environmental Protection Agency (EPA) finalized mandatory
greenhouse gas (GHG) reporting requirements on October 30, 2009 (74 FR
56260), which requires petroleum refineries to use Tier 3 calculation
and monitoring methods for stationary combustion sources that combust
fuel gas.   EPA received feedback from stakeholders seeking relief from
the Tier 3 monitoring requirements for small combustion sources. 

IV.	Approach and Discussion of Results

Available information regarding existing monitoring requirements for
small stationary combustion sources at petroleum refineries was
reviewed.  Attachment 1 presents a summary of consent decree
requirements.  As shown in the Attachment 1, requirements for nitrogen
oxide (NOX) from process heaters generally apply to process heaters
greater than 40 MMBtu/hr.  Similarly, review of NOX emission limits in
40 CFR 60 subpart Ja and in South Coast Air Quality Management District
(AQMD) Rule 1109 indicate that these rules apply to process heaters
greater than 40 MMBtu/hr.  40 CFR 60 subpart Dc specifically addresses
sulfur dioxide (SO2) and particulate matter (PM) emissions from steam
generating units from 10 to 100 MMBtu/hr rated heat capacity.  The PM
emission standards, however, apply only to units that combust coal
(alone or in combination with other fuels) in units with rated heat
capacities of 30 MMBtu/hr or greater.  While the SO2 standards apply to
smaller units, compliance with the SO2 standards is expected to be
assessed from hydrogen sulfide (H2S) or total sulfur monitoring in the
fuel gas mix drum rather than at the individual combustion unit.  Thus,
it appears likely that most process heaters less than 30 MMBtu rated
input heat capacity are not typically required to monitor fuel gas usage
at the individual process heater or boiler.

 The distribution of  process heaters were estimated based on
facility-specific processing unit capacities (EIA, 2006) and fuel use
factors used previously to project GHG emissions by petroleum refinery
(Coburn, 2007).   Based on these factors, the cumulative process heater
capacity for all U.S. refineries is estimated to be 257,831 MMBtu/hr. 
The cumulative sum of the process heater capacities projected to be 30
MM Btu/hr or greater based on the EIA reported process capacities is
253,796 MMBtu/hr or over 98 percent of the nationwide capacity.  We note
that the EIA processing capacities are reported for the refinery.  In
some cases, there may be two or more processing units of the same type
at the refinery, so that the individual process heater sizes projected
from the EIA processing capacities will be overstated if there are
multiple units at the refinery.  Assuming every unit has two process
heaters (or that each facility has two units for each type of processing
unit listed in EIA), the cumulative sum of the process heater capacities
projected to be 30 MM Btu/hr or greater is 245,996 MMBtu/hr or
approximately 95 percent of the nationwide capacity.  As it is
anticipated that the larger facilities are more likely to have either
multiple equipment trains or multiple process heaters for a given
process unit, the actual fuel use for process heaters with rated heat
capacities of 30 MMBtu/hr or more is expected to be somewhere between
these two estimates; however, in both scenarios, process heaters with
rated heat capacities less than 30 MMBtu/hr are projected to contribute
less than 5 percent of the nationwide fuel use.

V.	References

Coburn J. 2007. Greenhouse Gas Industry Profile for the Petroleum
Refining Industry. Prepared for U.S. Environmental Protection Agency,
Washington, DC. Contract No. GS-10F-0283K. June 11.

EIA (Energy Information Administration).  2006.  Refinery Capacity
Report 2006.  Prepared by the Energy Information Administration,
Washington, DC. June 15.



           Lion Oil Co. – El Dorado, AR 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install low-NOx burners or alternate technology
0.045 lb/MMBtu for atmospheric heater	(8-year program – see Appendix
C)

Heaters and boilers	CO	BACT analysis, install controls and comply with
EPA-established limits

Analysis - 4/30/03

Controls – 12/31/04

Heaters and boilers	SO2	Comply with subpart J; limit H2S in refinery
fuel gas

CEMS by 12/31/06



	BP (formerly Atlantic Richfield Co. (ARCO)) – Carson, CA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

Date of entry



	Chevron USA Products Co. – El Segundo, CA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Controlled H/B (SCR, low-NOx burners, shut down,
etc.) must represent 30% of the total heat input capacity of H/B greater
than 40 MMBtu/hr	0.040 lbs/MMBtu	6/30/11

Heaters and boilers	SO2	Affected facility under subpart J; eliminate
fuel oil burning

Date of entry



	Chevron USA Products Co. – Richmond, CA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Controlled H/B (SCR, low-NOx burners, shut down,
etc.) must represent 30% of the total heat input capacity of H/B greater
than 40 MMBtu/hr	0.040 lbs/MMBtu	6/30/11

Heaters and boilers	SO2	Affected facility under subpart J; eliminate
fuel oil burning

Date of entry



 	ConocoPhillips (formerly Tosco, formerly Unocal Corp.) – Carson
(LAR), CA 

Heaters and boilers	SO2	Affected facilities under subpart J

3/31/05

Heaters and boilers	SO2	Comply with 40 C.F.R. §60.104(a)(1)

Date of lodging



	ConocoPhillips (formerly Tosco, formerly Unocal Corp.) – Wilmington
(LA), CA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

3/31/05

Heaters and boilers	SO2	Comply with 40 C.F.R. §60.104(a)(1)

Date of lodging



 	ConocoPhillips (formerly Tosco, formerly Unocal Corp.) – Rodeo (SF),
CA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

Date of lodging



 	ConocoPhillips (formerly Tosco, formerly Unocal Corp.) – Santa Maria
(SF), CA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

Date of lodging

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/06



 	Valero (formerly Ultramar Diamond Shamrock) – Wilmington, CA

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/07



 	Valero ( formerly Exxon Co. USA) – Benicia, CA

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/07



 	Suncor Energy (formerly Conoco Inc.) – Commerce City (Denver), CO 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity greater than 40 MMBtu/hr

7/31/09

Heater H-27

Affected facility under subpart J

12/31/06

Heaters and boilers	SO2, PM, CO	Affected facilities under subpart J

Date of lodging

Heaters and boilers	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.005 lb/MMBtu (365-day avg.);
0.010 lb/MMBtu (24-hr avg.)	Date refinery applies for PAL

Heaters and boilers	CO	Comply with emission limit when NOx controls are
added or if a Plantwide Applicability Limit (PAL) is adopted	0.040
lb/MMBtu (365-day avg.); 0.060 lb/MMBtu (24-hr avg.)	Date of NOx control
installation or Date refinery applies for PAL

Heaters and boilers	SO2	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.040 lb SO2/MMBtu (365-day avg.)
OR 125 ppmvd H2S in fuel gas (365-day avg.)	Date refinery applies for
PAL



	Valero Energy (formerly Ultramar Diamond Shamrock, formerly Total
Petroleum) – Denver (Commerce City), CO 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/07



	Citgo Petroleum – Savannah, GA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers combusting refinery fuel gas	SO2	Affected facility
under subpart J

Date of entry

FCCU heater	NOx	Install controls (SCR, low-NOx burners, etc.) or shut
down	0.040 lbs/MMBtu	12/31/08

Heaters and boilers	SO2	Affected facility under subpart J

Date of entry



	Tesoro Hawaii Petrol. (formerly BHP)  – Kapolei, HI 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

6/30/11

Heaters and boilers that combust refinery fuel gas	SO2	Affected facility
under subpart J

Date of entry



	Marathon Ashland Petrol.  – Robinson, IL 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2, PM	Affected facilities under subpart J

Date of entry (8/30/01)

Heaters and boilers 	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.010 lb/MMBtu (24-hr avg.), 0.005
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers that burn fuel gas only	SO2	Comply with emission
limit if a Plantwide Applicability Limit (PAL) is adopted	0.040 lb
SO2/MMBtu or 125 ppmvd H2S in fuel gas (365-day avg.)	Date of
application for the PAL



	Premcor Refining Group (formerly Clark Oil and Refining Corp.) –
Hartford, IL

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Combination of current and new generation ultra
low-NOx burners and low NOx burners	Design to achieve between 0.012 and
0.06 lb/MMBtu	10/1/05

Heaters and boilers	SOx and NOx	Discontinue burning of fuel oil

30 days after Date of entry

Heaters and boilers

Affected sources under subpart J

Date of entry



	ConocoPhillips (formerly Tosco Refining, Equilon, Wood River, & Shell
Oil) – Wood River (Roxana), IL 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers (Distilling West)	SO2	Affected facilities under
subpart J

Date of lodging

Heaters and boilers (except Distilling West)	SO2	Affected facilities
under subpart J

6/30/08



	BP (formerly Amoco Oil Co.) – Whiting, IN 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers	SO2	Eliminate fuel oil burning

6/01/03

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

12/31/01



	National Cooperative Refinery Association – McPherson, KS 

Unit	Pollutant	Requirement	Emission limit	Deadline

Boilers SB-016 and SB-018	NOx	Comply with emission limit	101.9 tons/yr
(12-month avg.) (both boilers combined)	Date of lodging

Distillate hydrotreater feeder & platformer heater	H2S	Comply with H2S
concentration limit in fuel gas	5 gr/100 scf (365-day avg.)	30 days
after Date of entry



	Marathon Ashland Petroleum LLC (formerly Ashland, Inc.) –
Catlettsburg, KY 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2, PM	Affected facilities under subpart J

Date of entry (8/30/01)

Heaters and boilers 	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.010 lb/MMBtu (24-hr avg.), 0.005
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers that burn fuel gas only	SO2	Comply with emission
limit if a Plantwide Applicability Limit (PAL) is adopted	0.040 lb
SO2/MMBtu or 125 ppmvd H2S in fuel gas (365-day avg.)	Date of
application for the PAL



	Citgo Petroleum Corp.  – Lake Charles, LA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

6/30/11

Heaters and boilers that combust refinery fuel gas	SO2	Affected facility
under subpart J

Date of entry



 	ConocoPhillips (formerly Conoco Inc.) – Westlake (Lake Charles), LA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity greater than 40 MMBtu/hr

7/31/09

Heaters and boilers	SO2, PM, CO	Affected facilities under subpart J

Date of lodging

Heaters and boilers	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.005 lb/MMBtu (365-day avg.);
0.010 lb/MMBtu (24-hr avg.)	Date refinery applies for PAL

Heaters and boilers	CO	Comply with emission limit when NOx controls are
added or if a Plantwide Applicability Limit (PAL) is adopted	0.040
lb/MMBtu (365-day avg.); 0.060 lb/MMBtu (24-hr avg.)	Date of NOx control
installation or Date refinery applies for PAL

Heaters and boilers	SO2	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.040 lb SO2/MMBtu (365-day avg.)
OR 125 ppmvd H2S in fuel gas (365-day avg.)	Date refinery applies for
PAL



	Marathon Ashland Petroleum LLC – Garyville, LA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

12/31/08

Heaters and boilers	CO	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.060 lb/MMBtu (24-hr avg.), 0.040
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers	SO2, PM	Affected facilities under subpart J

Date of entry (8/30/01)

Heaters and boilers 	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.010 lb/MMBtu (24-hr avg.), 0.005
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers that burn fuel gas only	SO2	Comply with emission
limit if a Plantwide Applicability Limit (PAL) is adopted	0.040 lb
SO2/MMBtu or 125 ppmvd H2S in fuel gas (365-day avg.)	Date of
application for the PAL



 	Valero (formerly Orion Refining Corp, formerly TransAmerican Refining
Corp) – Norco (St. Charles Parish), LA

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/07



            ConocoPhillips (formerly, Tosco Refining Co., formerly BP
Oil Co.) – Belle Chasse (Alliance), LA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers (except 191-H-1)	SO2	Affected facilities under
subpart J

Date of lodging

Heater 191-H-1	SO2	Affected facilities under subpart J

12/31/06



 	Valero (formerly Basis Petroleum, Inc.) – Krotz Springs, LA

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/07



	Marathon Ashland Petrol. LLC – Detroit, MI 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

12/31/08

Heaters and boilers	CO	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.060 lb/MMBtu (24-hr avg.), 0.040
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers	SO2, PM	Affected facilities under subpart J

Date of entry (8/30/01)

Heaters and boilers 	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.010 lb/MMBtu (24-hr avg.), 0.005
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers that burn fuel gas only	SO2	Comply with emission
limit if a Plantwide Applicability Limit (PAL) is adopted	0.040 lb
SO2/MMBtu or 125 ppmvd H2S in fuel gas (365-day avg.)	Date of
application for the PAL



 	Flint Hills Resources (formerly Koch Refining Co.) – Rosemount (Pine
Bend), MN 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install ultra low-NOx burners on heaters and
boilers with HHV 40 MMBtu/hr or higher	Design to achieve 0.012 – 0.04
lb/MMBtu	12/31/06

Heaters and boilers

Affected facilities under subpart J (few exceptions)

1/01/01



	Marathon Ashland Petroleum LLC (formerly Ashland, Inc.) – St. Paul
Park, MN 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

12/31/08

Heaters and boilers	CO	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.060 lb/MMBtu (24-hr avg.), 0.040
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers	SO2, PM	Affected facilities under subpart J

Date of entry (8/30/01)

Heaters and boilers 	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.010 lb/MMBtu (24-hr avg.), 0.005
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers that burn fuel gas only	SO2	Comply with emission
limit if a Plantwide Applicability Limit (PAL) is adopted	0.040 lb
SO2/MMBtu or 125 ppmvd H2S in fuel gas (365-day avg.)	Date of
application for the PAL



	Chevron USA Inc. – Pascagoula, MS 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Controlled H/B (SCR, low-NOx burners, shut down,
etc.) must represent 30% of the total heat input capacity of H/B greater
than 40 MMBtu/hr	0.040 lbs/MMBtu	6/30/11

Heaters and boilers	SO2	Affected facility under subpart J; eliminate
fuel oil burning

Date of entry



	Ergon Refining Inc. – Vicksburg, MS 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

Date of lodging

Heaters and boilers	SO2	Eliminate fuel oil burning except during natural
gas curtailment

Date of lodging



 	Cenex Harvest States – Laurel, MT 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Shut down or install NOx controls on at least
30% of the heater capacity greater than 40 MMBtu/hr

12/31/11

Heaters and boilers	SO2	Minimize burning of fuel oil





 	Conoco Inc. – Billings, MT 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity greater than 40 MMBtu/hr

7/31/09

Heater H-16

Affected facility under subpart J

6/30/03

Heaters and boilers	SO2, PM, CO	Affected facilities under subpart J

Date of lodging

Heaters and boilers	SO2	Comply with emission limit when fuel oil is
burned	300 tons/year (365-day avg.)	Date of lodging

Heaters and boilers	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.005 lb/MMBtu (365-day avg.);
0.010 lb/MMBtu (24-hr avg.)	Date refinery applies for PAL

Heaters and boilers	CO	Comply with emission limit when NOx controls are
added or if a Plantwide Applicability Limit (PAL) is adopted	0.040
lb/MMBtu (365-day avg.); 0.060 lb/MMBtu (24-hr avg.)	Date of NOx control
installation or Date refinery applies for PAL

Heaters and boilers	SO2	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.040 lb SO2/MMBtu (365-day avg.)
OR 125 ppmvd H2S in fuel gas (365-day avg.)	Date refinery applies for
PAL



 	Montana Refining Co. – Great Falls, MT 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install next generation ultra low NOx burners
for any heater or boiler that begins to operate with a heat input
capacity of 40 MMBtu/hr or greater

Any time during life of consent decree

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/06

Heaters and boilers	SO2	Eliminate burning of fuel oil (with a few
exceptions)

Date of lodging



	Citgo Asphalt Refining Co. – Paulsboro, NJ 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers combusting refinery fuel gas	SO2	Affected facility
under subpart J

Date of entry



	Sunoco (formerly Coastal Eagle Point Oil Co.) – Westville, NJ 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls and accept
federally-enforceable emission limits	0.040 lb/MMBtu	3 years

Heaters and boilers 	SO2, PM	Affected facilities under subpart J

Date of lodging

Heaters and boilers	SO2	Eliminate fuel oil burning except during natural
gas curtailment

Date of lodging

Boilers 5, 6, 7, and 8	PM-10	Comply with emission limit	0.000427
lbs/MMBtu (1-hr avg.) 	Date of entry



	ConocoPhillips (formerly Tosco Refining Co., formerly Bayway) –
Linden (Bayway), NJ 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers (except selected)	SO2	Affected facilities under
subpart J

Date of lodging

Selected heaters and boilers	SO2	Affected facilities under subpart J

6/30/11



 	Valero Energy Corp. (formerly Mobil Oil) – Paulsboro, NJ

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/08



 	Navajo Refining Co. – Artesia, NM 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install next generation ultra low NOx burners
for all controlled heaters and boilers except Boilers B-7 and B-8

12/31/05 and 12/31/09

Heaters and boilers	SO2	Affected facilities under subpart J

Date of lodging

Heaters and boilers	SO2	Eliminate burning of fuel oil (with a few
exceptions)

Date of lodging



	Tesoro (formerly BP, formerly Amoco Oil Co.) – Mandan, ND 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers	SO2	Eliminate fuel oil burning

3/31/01

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

9/30/03

Heaters and boilers	H2S	Volume-weighted, rolling 3-hour average
concentration of H2S in refinery fuel gas	0.10 gr/dscf	12/31/01 until
9/30/03



	BP Oil Co. – Toledo, OH 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

9/30/03

Heaters and boilers	H2S	Volume-weighted, rolling 3-hour average
concentration of H2S in refinery fuel gas	0.10 gr/dscf	12/31/01 until
9/30/03



	Marathon Ashland Petroleum LLC (formerly Ashland, Inc.) – Canton, OH 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

12/31/08

Heaters and boilers	CO	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.060 lb/MMBtu (24-hr avg.), 0.040
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers	SO2, PM	Affected facilities under subpart J

Date of entry (8/30/01)

Heaters and boilers 	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.010 lb/MMBtu (24-hr avg.), 0.005
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers that burn fuel gas only	SO2	Comply with emission
limit if a Plantwide Applicability Limit (PAL) is adopted	0.040 lb
SO2/MMBtu or 125 ppmvd H2S in fuel gas (365-day avg.)	Date of
application for the PAL



 	Sunoco, Inc. – Toledo, OH

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity (all of the capacity greater than 40 MMBtu/hr if less
than 30% of total)

8 years after Date of entry

Heaters and boilers 	SO2	Affected facilities under subpart J

12/31/09

Heaters and boilers	SO2	Eliminate fuel oil burning (a few exceptions
provided)

Date of entry



 	Conoco Inc. – Ponca City, OK 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity greater than 40 MMBtu/hr

7/31/09

Heaters and boilers	SO2, PM, CO	Affected facilities under subpart J

Date of lodging

Heaters and boilers	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.005 lb/MMBtu (365-day avg.);
0.010 lb/MMBtu (24-hr avg.)	Date refinery applies for PAL

Heaters and boilers	CO	Comply with emission limit when NOx controls are
added or if a Plantwide Applicability Limit (PAL) is adopted	0.040
lb/MMBtu (365-day avg.); 0.060 lb/MMBtu (24-hr avg.)	Date of NOx control
installation or Date refinery applies for PAL

Heaters and boilers	SO2	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.040 lb SO2/MMBtu (365-day avg.)
OR 125 ppmvd H2S in fuel gas (365-day avg.)	Date refinery applies for
PAL



 	Sunoco, Inc. – Tulsa, OK

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity (all of the capacity greater than 40 MMBtu/hr if less
than 30% of total)

8 years after Date of entry

Heaters and boilers 	SO2	Affected facilities under subpart J

Date of entry

Heaters and boilers	SO2	Eliminate fuel oil burning (a few exceptions
provided)

Date of entry



	Valero (formerly Ultramar/Diamond Shamrock, formerly Total Petroleum
Inc.) – Ardmore, OK

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/10



 	Sunoco, Inc. – Marcus Hook, PA

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity (all of the capacity greater than 40 MMBtu/hr if less
than 30% of total)

6/15/10

Heaters and boilers 	SO2	Affected facilities under subpart J

Date of entry

Heaters and boilers	SO2	Eliminate fuel oil burning (a few exceptions
provided)

Date of entry (12/31/05 for a few)



 	Sunoco (combined Sun & Chevron) – Philadelphia (Girard Pt & Pt
Breeze), PA

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install NOx controls on at least 30% of the
heater capacity (all of the capacity greater than 40 MMBtu/hr if less
than 30% of total)

6/15/10

Heaters and boilers 	SO2	Affected facilities under subpart J

12/31/10

Heaters and boilers	SO2	Eliminate fuel oil burning (a few exceptions
provided)

Date of entry (later dates for a few)



	ConocoPhillips (formerly Tosco Refining Co., formerly BP) – Trainer
(Marcus Hook), PA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

6/30/08



	BP (formerly Amoco Oil Co.) – Texas City, TX 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

Date of entry



	Citgo – Corpus Christi, TX 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers (East and West)	NOx	Install controls on 30% of total
heat input capacity of heaters and boilers with capacities greater than
40 MMBtu/hr

6/30/11

Heaters and boilers that combust refinery fuel gas	SO2	Affected facility
under subpart J

Date of entry



      Flint Hills Resources (formerly Koch Petroleum Group, includes
SWest Refining) – Corpus Christi, TX 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install ultra low-NOx burners on heaters and
boilers with HHV 40 MMBtu/hr or higher	Design to achieve 0.012 – 0.04
lb/MMBtu	12/31/06



Marathon Ashland Petrol. LLC – Texas City, TX 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

12/31/08

Heaters and boilers	CO	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.060 lb/MMBtu (24-hr avg.), 0.040
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers	SO2, PM	Affected facilities under subpart J

Date of entry (8/30/01)

Heaters and boilers 	PM	Comply with emission limit if a Plantwide
Applicability Limit (PAL) is adopted	0.010 lb/MMBtu (24-hr avg.), 0.005
lb/MMBtu (365-day avg.)	Date of application for the PAL

Heaters and boilers that burn fuel gas only	SO2	Comply with emission
limit if a Plantwide Applicability Limit (PAL) is adopted	0.040 lb
SO2/MMBtu or 125 ppmvd H2S in fuel gas (365-day avg.)	Date of
application for the PAL



	ConocoPhillips (formerly Phillips Petroleum Co.) – Borger, TX 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

Date of lodging



	ConocoPhillips (formerly Phillips Petroleum Co.) – Sweeny, TX 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

6/30/08

 

 	Valero (formerly Ultramar/Diamond Shamrock Corp.) – Three Rivers, TX


Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/10



 	Valero (formerly Ultramar/Diamond Shamrock Corp.) – Sunray (McKee),
TX 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/10



 	Valero Refining Co. – Corpus Christi, TX

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers (East)	SO2	Affected facilities under subpart J

12/31/10

Heaters and boilers (West)	SO2	Affected facilities under subpart J

12/31/07



 	Valero (formerly Basis Petroleum, Inc.) – Houston, TX

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/07



 	Valero (formerly Basis Petroleum, Inc.) – Texas City, TX

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Discontinue burning or combustion of fuel oil
(during NG curtailment, may burn low sulfur fuel oil)

12/31/05

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/07



	Tesoro (formerly BP, formerly Amoco Oil Co.) – Salt Lake City, UT 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers	SO2	Eliminate fuel oil burning

6/01/02

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

Date of entry



	Chevron USA – Salt Lake City, UT 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Controlled H/B (SCR, low-NOx burners, shut down,
etc.) must represent 30% of the total heat input capacity of H/B greater
than 40 MMBtu/hr	0.040 lbs/MMBtu	6/30/11

Heaters and boilers	SO2	Affected facility under subpart J; eliminate
fuel oil burning except during natural gas curtailment, test runs, or
training

Date of entry



	Giant Refining (formerly BP, formerly Amoco Oil Co.) – Yorktown, VA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers	SO2	Eliminate fuel oil burning

6/01/01

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

Date of entry



	BP (formerly Atlantic Richfield Co. (ARCO)) – Ferndale (Cherry
Point), WA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install controls on 30% of total heat input
capacity of heaters and boilers with capacities greater than 40 MMBtu/hr

1/18/05

Heaters and boilers

Subject to subparts A & J as those subparts apply to fuel gas combustion
devices

9/30/05

Heaters and boilers	H2S	Volume-weighted, rolling 3-hour average
concentration of H2S in refinery fuel gas	0.10 gr/dscf	12/31/01 until
9/30/05



	ConocoPhillips (formerly Tosco Refining Co.) – Ferndale, WA 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Affected facilities under subpart J

Date of lodging



Ergon-West Virginia inc. (formerly Quaker State Oil Refining Corp.) –
Newell, WV 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Boiler A	NOx	Install next generation ultra low-NOx burner	EPA to
determine emission limit	Install – 12/31/05

Boiler B	NOx	Install next generation ultra low-NOx burner	EPA to
determine emission limit	Install – 12/31/08

Boiler C	NOx	Comply with emission limit	0.050 lb/MMBtu (3-hr avg.)
12/31/03

H-101	NOx	Comply with emission limit	0.065 lb/MMBtu (3-hr avg.)	12/31/03

Heaters and boilers	SO2	Affected facilities under subpart J

12/31/06

Heaters and boilers	SO2	Eliminate fuel oil burning except during natural
gas curtailment

Date of lodging



	Murphy Oil USA Inc. – Superior, WI 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	SO2	Reduce burning of fuel oil	33.3 tons/month
(12-month avg.)	5/01/02



 	Navajo Refining Co. – Lovington, NM 

Unit	Pollutant	Requirement	Emission Limit	Deadline

Heaters and boilers	NOx	Install next generation ultra low NOx burners
for all controlled heaters and boilers except Boilers B-7 and B-8

12/31/05 and 12/31/09

Heaters and boilers	SO2	Affected facilities under subpart J

Date of lodging

Heaters and boilers	SO2	Eliminate burning of fuel oil (with a few
exceptions)

Date of lodging



 

 

 Developed with support from Eastern Research Group. 

 Developed with support from Christopher Evans, Robert Lanza, Randy
Freed, and Veronica Kennedy, ICF International

 Carbon-based components of MSW are distinguished into fossil and
biogenic fractions because these fractions are accounted for differently
under IPCC guidelines for developing national greenhouse gas inventories
(IPCC 2006) and are required to be reported separately under Subpart C
of the MRR. The biogenic fraction of MSW includes biomass-derived
materials containing carbon that, under natural conditions, would cycle
back to the atmosphere as CO2 due to degradation processes. As a result,
CO2 emissions from biogenic materials from sustainably-grown biomass are
not included in inventories of human-caused greenhouse gas emissions.
The fossil fraction of MSW includes materials that are derived from
fossil fuels that have been sequestered under the earth. When
fossil-based materials are extracted from the earth and converted into
CO2 or other greenhouse gases, they are considered anthropogenic
emissions and are included in inventories. For more information, please
refer to IPCC (2006) and EPA (2006, p. 13).

 Usually Biocycle runs their “State of Garbage in America” article
annually, but there have been occasional gaps.

 MWCs account for roughly 90% of MSW processed in waste-to-energy
projects (EPA 2008, p. 151). The remaining 10% is largely made up of
tires, which are sent separately to cement kilns, utility boilers, pulp
and paper mills, industrial boilers, and dedicated tire-derived fuel
facilities for combustion. (EPA 2008, p. 151)

 Developed with support from Christopher Evans and Randy Freed, ICF
International. 

 Developed with support from Jeff Coburn, RTI International. 

 PAGE   12 

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ICF		

EP-W-06-008		Revision Number: 4

Task Order: 018		Date: February 11, 2010

Task: 05		Page   PAGE  1  of   NUMPAGES  12 

