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### PART VI. EMISSION S INVENTORY DATA

The U.S. EPA is working to fulfill its obliga tion under CAA sections 111(b), 112(f)(2), and 112(d)(6) to review residual risk from the petroleum refinery NESH AP subparts CC and UUU and to perform technology reviews of the pe troleum refinery NESH AP subparts CC and UUU and the petroleum refinery NSPS subpart J. Em ission data sets provided by the individual

refineries will be used for these reviews. Refe r to the ICR website for instructions for obtaining a copy of the EPA’s 2005 NATA NEI data set for each of your refineries (i f available) for your

reference.

For each unit listed below, provide emission esti mates (tons/yr) for the 2010 calendar year for individual HAP and criteria pollutants using the emissions template provided. You may report emissions by emission point rather than by un it, but you should identify which units are associated with each emission poi nt. (Note: You do not have to report emissions one way or the other throughout the entire inve ntory. For example, you may report equipment leak emissions by process unit for the major pro cess units and by geographical ar ea for other areas of your refinery.)

• Each processing unit for which you provide d an ID in Part I, Question 16

• Each process heater listed in Table 2-1 of Part II

• Each fuel gas and natural gas system for which you provided equipment leaks

data in Table 3-2 of Part II

• Each storage tank listed in Table 4-1 of Part II

• Each “other atmospheric vent” listed in Table 11-1 of Part II (except for vents controlled by a flare)

• Each flare listed in Table 12-1 of Part II, including those controlling emissions from “other atmospheric vents” lis ted in Table 11-1 of Part II

• Each solid waste management unit listed in Table 17-1 of Part II

Except as noted below, provide emission esti mates following the methods provided in the

Emission Estimation Protocol for Petroleum Refineries (Version 2.1 – Final ICR Draft). As

noted in the Emission Estimation Protocol for Petroleum Refineries , for each unit for which there are multiple methodologies for estima ting emissions, you must use the highest Methodology Rank in the Emission Estimation Protocol for Petroleum Refineries for which you have available 2010 data. For example, if Methodology Rank 1 for NO X is estimating emissions using a continuous emissions monitori ng system (CEMS), and you have a NO X CEMS on that unit, you must use the CEMS results to estimate NO X emissions from that unit. However, if you

did not have a NO X CEMS installed on that unit during 2010, you do not have available data to use Methodology Rank 1 for NO X ; you must then consider whethe r you have available data to use Methodology Rank 2 for NO X from that unit. Similarly, if a particular methodology requires speciation of a stream and you do not have speciat ion data available, yo u are not required to conduct additional sampling and analysis (but if you do have speciation data available and noForm Approved __/__/__
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2 higher ranking methodology can be used, you mu st use the methodology that calls for speciation).

For units and other emissions points not addressed in the Emission Estimation Protocol for Petroleum Refineries , you should provide the emissions estim ates as your TRI or State inventory or use engineering estimates a nd process knowledge for pollutants not required to be reported for TRI or State inventory. Also provide a brief explanati on of the methodology you used in the

“Comments” column of the em issions template provided.

For wastewater treatment systems, also pleas e provide a copy of the Refinery Wastewater Emissions Tool spreadsheet (provided as part of the Emission Estimation Prot ocol for Petroleum Refineries ) completed for your refinery.

Instructions for completing the emi ssions template are provided below.

1. Emission point ID : Provide the identification number or code for the location at which

emissions are released into the environment. If this is an emission point for one particular process unit or a flare, you may use the Unit ID as your Emission point ID (the response to Number 3 will be completed auto matically if you do so). If you choose to report fugitive emissions by process unit, th e Emission point ID should be “FUG-” plus the Unit ID ( e.g. , if you are reporting equipment leak emissions for a FCCU with a Unit ID of FCCU01, the Emission poi nt ID is “FUG- FCCU01”).

2. Emission point description : Provide a description of the emissions point for easy reference ( e.g. , FCCU regenerator vent stack; cata lytic reforming unit depressurization vent; crude heater vent; facility-w ide start-up and shutdown emissions).

3. Unit ID : Provide the identification number or code for the unit( s) associated with this emission point. Use the same identification num ber that you provided in Part II, Sections 2 through 13, 15, and 16. For sulfur recovery, enter the SRU ID. For an emissions point that covers the entire facility, enter “All Units.” (Note that for flares, you are not required to identify the process units and/or ve nts routed to each fl are; the response to this question is the Flare ID.

4. SCC : Attachment 1 provides source classifi cation codes (SCC) extracted from the NEI database lookup tables. There have been updates (both additions and deletions) to the SCC over the years, and the list in Attachment 1 contains the current list of SCC that EPA would like you to use for this inventory. If a code that you have used in the past no longer appears in the applicab le lookup table, please select the most appropriate code

from those listed.

5. Pollutant name : Enter the name of the pollutant for which you are estimating emissions. You will need to enter only one pollutant per row; for most units, it will take multiple rows to provide emissions estimates for all pollutants.

6. Pollutant CAS No. or Pollutant Code : See Table 1-1 of the Emission Estimation Protocol for Petroleum Refineries for a list of CAS numbers and Pollutant Codes for selected pollutants.Form Approved __/__/__
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3 7. 2010 emissions (tons) : All emissions reported in th is column should reflect the ACTUAL emissions during normal operation for the reported calenda r year. (If you use a CEMS/CMS to monitor emissions of a partic ular pollutant, the readings for the entire year were within the calibr ated span of the CEMS/CMS , and you have completed the CEMS Template or CMS Template for that monitor, then you may report the total emissions recorded by that CE MS/CMS in this column.)

8. Protocol methodology rank used : Provide the rank number from the appropriate chapter

of the Emission Estimation Protocol for Petroleum Refineries that best describes how you estimated emissions for the unit and pollutant provided in this row. If a pollutant’s emissions for a given source are based on a mixture of different methodology ranks ( e.g. , calculating equipment leak emissions using li ne by line composition for some parts of a process and average composition for other pa rts), report the prot ocol methodology rank that contributed most to the total reported em issions. If any of your emissions sources is

not included in the Emission Estimation Protocol for Petroleum Refineries ( e.g. , an ethylene unit), enter “N/A.”

9. 2010 non-routine emissions (tons) : All emissions reported in this column should reflect the ACTUAL emissions during any non-routine operation for the reported calendar year, including startups, shutdowns, and other ev ents. If you use a CEMS/CMS to monitor emissions of a particular polluta nt and the readings for part of the year were not within the calibrated span of the CEMS/CMS, estimat e emissions of that pollutant from the process unit during that event a nd report the value here. Enter 0 if there were not nonroutine operations for this source during 2010 or if non-routine emissions are not applicable for the source type ( e.g. , equipment leaks). You may use an emissions point ID representing “All Units” to report the non-routine emi ssions (see descriptions for Number 1 and Number 3).

10. Maximum hourly emissions (lb/hr) : Enter the maximum actual emissions from the unit during normal operation in any one hour of 2010. See the Emission Estimation Protocol for Petroleum Refineries for additional information on how to determine hourly

emissions.

11. Annual emissions allowed by NESHAP for emission points subject to emission limits (tons/yr) : Enter the annual emissions during normal operation allowed by the NESHAP to which this unit is subject. (Note that if the NESHAP limit is on a concentration basis, you will need to use process data at maximum ca pacity to convert the limit to tons/yr. Similarly, if the NESHAP limit is on a per cent reduction basis, you may need to use

information about the inlet to the control devi ce to estimate the allowable emissions.) If this unit is not subject to any NESHAP for this pollutant, enter “N/A.”

As an example, if you comply with the 1 lb per 1,000 lb coke burn-off limit for PM for an FCCU, determine and report the allowed annual PM emissions based on the annual quantity of coke burned in 2010 when repor ting the allowed PM emissions and enter “N/A” when reporting the allowed nickel emi ssions. Alternatively, if you comply with

the 0.029 lb/hr nickel emissions limit for an FCCU, enter “N/A” when reporting the

allowed PM emissions and determine and re port the allowed annual nickel emissionsForm Approved __/__/__
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4 based on the operating hours of the unit in 2010 when reporting the allowed nickel

emissions.

12. Hourly emissions allowed by NESHAP fo r emission points subject to emission limits (lb/hr) : Enter the maximum hourly emissions during normal operation allowed by the NESHAP to which this unit is subject. Fo r example, when reporting nickel emissions from an FCCU, enter “N/A” if you comply with a PM emissions limit but report the allowed hourly emissions rate if you comply w ith the nickel emission rate alternative. (Note that if the NESHAP limit is on a concen tration basis, you will need to use process data at maximum capacity to convert the limit to lb/hr. Similarly, if the NESHAP limit is on a percent reduction basis, you may need to use information about the inlet to the control device to estimate the allowable emissions.) If this unit is not subject to any NESHAP for this pollutant, enter “N/A.”

As an example, if you comply with the 1 lb per 1,000 lb coke burn-off limit for PM for an FCCU, determine and report the allowed hour ly PM emissions based on the maximum quantity of coke burned in an hour du ring 2010 when reporting the allowed PM emissions and enter “N/A” when reporting the al lowed nickel emissions. Alternatively, if you comply with the 0.029 lb/h r nickel emissions limit for an FCCU, enter “N/A” when reporting the allowed PM emissions and enter “0.029” (lb/hr) when re porting the allowed

nickel emissions.

13. Annual emissions allowed by permit (tons/yr) : Enter the annual emissions during normal operation allowed by your operating permit (may be more stringent than the emissions limit under the applicable NESHAP). (Note th at if the permit limit is on a concentration basis, you will need to use process data at maximum capacity to convert the limit to tons/yr.) If your permit does not have a numer ical limit for emissions of this pollutant from this unit, enter “N/A” (see example for Number 11).

14. Hourly emissions allowed by permit (lb/hr) : Enter the maximum hourly emissions during normal operation allowed by your operating permit (may be more stringent than the emissions limit under the applicable NESHAP). (Note that if the permit limit is on a concentration basis, you will need to use pr ocess data at maximum capacity to convert the limit to lb/hr.) If your permit does not ha ve a numerical limit for emissions of this pollutant from this unit, enter “N/A” (see example for Number 12).

15. Type of Release (Point or Fugitive) : Point releases are the emissions released from a facility unit that is included in the facility inventory through one or more stacks or vents. Fugitive releases are air pollutants released to the air other than those from stacks or vents, including small releases from leaking plant equipment such as valves, pump seals, flanges, or sampling connections, and large open area releases such as from landfills, waste ponds, coke drum cutting, coke tran sport and storage, or unpaved roads.

16. Point Sources : Complete the columns listed below if you answered “Point” in Number

15.

Release Height (ft) : Enter the height of the stack or vent from the ground.Form Approved __/__/__
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5 Internal Vent Diameter (ft) : Enter the diameter of the stack or vent at the release height.

Exit Temperature (°F) : Enter the temperature of the exit gas stream

Gas Flow Rate (acfm) : Enter the flow rate of the exit gas stream.

17. Fugitive Sources : Complete the columns listed below if you answered “Fugitive” in

Number 15.

Length (ft) : Enter the dimension of the sour ce in the east-west (x-) direction

Width (ft) : Enter the dimension of the source in the north-south (y-) direction

Angle : The release angle is the orientation of the y-dimension relative to true North, measured positive for clockwise starting at 0 degrees (maximum 89 degrees). EPA will assume 0 degrees if it is not provided.

18. Longitude and Latitude : Pay particular attention when entering emission release point stack parameters and locations. EPA require s latitude/longitude for each emission point provided in North American Da tum (NAD) 83 and prefers six di gits to the right of the decimal point. (If currently available coordina tes have five digits to the right of the decimal point instead of six, those coordinates are acceptabl e.) These data are critical inputs to the modeling files that EPA will use to determine the risk profile for the residual risk review process. 1

19. Comments : Provide any comments that you feel ar e necessary to qualify or explain any of your answers to the previous questions.

1 Latitude measure in decimal degrees of the angular distance on a meridian north or south of the equator. Positive (+) data point for North America. Example: +78.123456. For point sources, this represents the center of the source; for fugitive sources, this is the southwest corner if the fugitive angle is zero or the western most corner if the fugitive angle is greater than zero. Longitude measure in decimal degrees of the angular distance on a meridian east or west of the prime meridian. Negative (-) data point for North Am erica. Example: -123.23456 1. For point sources this represents the center of the source; for fugitive sources, this is the southwest corner if the fugitive angle is zero, or the western most corner if the fug itive angle is greater than zero.Form Approved __/__/__OMB Control No. ____-____Approval Expires __/__/__6PART VI. EMISSIONS INVENTORY DATA

Emission point ID Emission point description Unit ID SCC Pollutant name Pollutant CAS No. or Pollutant Code 2010 emissions (tons) Protocol methodology rank used 2010 non-routine emissions (tons) Maximum hourly emissions (lb/hr) Annual emissions allowed by NESHAP (tons/yr) Hourly emissions allowed by NESHAP (lb/hr) Annual emissions allowed by permit (tons/yr) Hourly emissions allowed by permit (lb/hr) Type of Release (Point or Fugitive)Point SourcesFugitiveSources Longitude Latitude Comments

Release Height (ft) Internal Vent Diameter (ft) Exit Temperature (°F) Gas Flow Rate (acfm) Length (ft) Width (ft) AngleForm Approved __/__/__OMB Control No. ____-____Approval Expires __/__/__1-1Attachment 1. Lists of SCC(This is an example of one of multiple tables that will be posted on the ICR website.Each type of emission source will have atable ofSCC on the ICR website.)List of Storage Tank SCCSCCSCC_L1SCC_L2SCC_L3SCC_L440302001 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Crude Oil40302002 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Gasoline40302003 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Jet Naphtha (JP-4 or Jet B)40302004 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Kerosene (including JetKerosene Jet A-1, Jet A, JP-5,or JP-8)40302005 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Distillate Fuel (Diesel Fuel,#2 Fuel Oil, or #3 Fuel Oil)40302006 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Heavy Fuel Oil (# 4 Fuel Oil)40302007 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Residual or Heavy Gas Oil (#5 or #6 Fuel Oil)40302008 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Unfinished or IntermediateNaphtha40302009 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesFixed Roof Tanks Other (Specify)40302101 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Crude Oil40302102 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Gasoline40302103 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Jet Naphtha (JP-4 or Jet B)Form Approved __/__/__OMB Control No. ____-____Approval Expires __/__/__1-2SCCSCC_L1SCC_L2SCC_L3SCC_L440302104 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Kerosene (including JetKerosene Jet A-1, Jet A, JP-5,or JP-8)40302105 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Distillate Fuel (Diesel Fuel,#2 Fuel Oil, or #3 Fuel Oil)40302106 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Heavy Fuel Oil (# 4 Fuel Oil)40302107 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Residual or Heavy Gas Oil (#5 or #6 Fuel Oil)40302108 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Unfinished or IntermediateNaphtha40302109 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(Without Geodesic Dome)Other (Specify)40302201 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Crude Oil40302202 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Gasoline40302203 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Jet Naphtha (JP-4 or Jet B)40302204 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Kerosene (including JetKerosene Jet A-1, Jet A, JP-5,or JP-8)40302205 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Distillate Fuel (Diesel Fuel,#2 Fuel Oil, or #3 Fuel Oil)40302206 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Heavy Fuel Oil (# 4 Fuel Oil)40302207 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Residual or Heavy Gas Oil (#5 or #6 Fuel Oil)40302208 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Unfinished or IntermediateNaphthaForm Approved __/__/__OMB Control No. ____-____Approval Expires __/__/__1-3SCCSCC_L1SCC_L2SCC_L3SCC_L440302209 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesExternal Floating Roof Tanks(With Geodesic Dome)Other (Specify)40302301 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Crude Oil40302302 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Gasoline40302303 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Jet Naphtha (JP-4 or Jet B)40302304 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Kerosene (including JetKerosene Jet A-1, Jet A, JP-5,or JP-8)40302305 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Distillate Fuel (Diesel Fuel,#2 Fuel Oil, or #3 Fuel Oil)40302306 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Heavy Fuel Oil (# 4 Fuel Oil)40302307 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Residual or Heavy Gas Oil (#5 or #6 Fuel Oil)40302308 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Unfinished or IntermediateNaphtha40302309 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesInternal Floating Roof Tanks Other (Specify)40302401 Petroleum and SolventEvaporationPetroleum Product Storage atRefineriesLPG Pressurized Tanks Examples: Propane Spheres,Butane Spheres