## FROM: Jeff Coburn and Kristin Sroka

TO: Brenda Shine, Refining and Chemicals Group, SPPD

DATE: April 6, 2012

SUBJECT: Compilation of Non-confidential Component 1 Responses to the 2011 Petroleum Refinery Information Collection Request

Purpose

The objective of this memorandum is to pr ovide background and addi tional information about the database of compiled Component 1 responses to the 2011 Petroleum Refinery Information Collection Request.

Background

On April 1, 2011, the EPA sent an ICR to facilities in the U.S. petroleum refining industry. The ICR was comprehensive and designed to collect information on processing characteristics, crude slate characteristics, emissi ons inventories and source testing to bolster our current data and fill known data gaps. The ICR had four components: (1) a questionnaire on processes and controls to be completed by all petroleum refine ries (Component 1); (2) an emissions inventory to be developed by all petr oleum refineries using the emissions estimation protocol developed for this effort (Component 2) ; (3) distillation feed sa mpling and analysis to be conducted by all petroleum refineries (Compone nt 3); and (4) emission s source testing to be completed in accordance with an EPA-approved protocol for specific sources at specific petroleum refineri es (Component 4).

Component 1 includes detailed process and c ontrol system information for a variety of emission sources commonly present at a petr oleum refinery. A printable copy of the Component 1 questionnaire can be found at http://www.epa.gov/ttn/a tw/petref/petrefpg.html . An electronic Reporting Tool was deve loped using Microsoft® Access, and facilities were instructed to submit their Component 1 information using th is tool. Some of the process information requested in Component 1 may in clude proprietary or business se nsitive information, which the facility could claim as Confidential Business Inform ation (CBI). When facilities wished to make a claim of CBI on portions of their Component 1 response, they were in structed to submit a complete database that with responses to a ll the questions (includi ng the CBI) to EPA’s CBI Document Control Officer. In addition they were instructed to submit a scrubbed copy of the Component 1 database with the CBI responses removed. This memorandum documents the development of an aggregate d, non-CBI Component 1 database.

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Compilation of non-CBI Component 1 Responses

The EPA mailed letters requesting responses to the ICR to 152 facilities based on the listing of facilities in the Petroleum Refining Capacity repor t (EIA, 2010). Three facilities did not complete the ICR, as they indicated that th ey are not petroleum refineries. Two facilities noted that they are operated as contiguous operations (and under common ownership or control) with another petroleum refinery on the list. Ther efore, only one of the two Facility ID numbers assigned to those facilities was used to submit the combined ICR response. Two other refineries requested an additional Facility ID number becau se they operate two non-contiguous refineries (with integrated operations so they are listed only once in EIA 2010). Consequently, the EPA received Component 1 responses from 149 refinery “facilities.”

Of these 149 refineries, only 33 respondent s did not make any CBI claims in their Component 1 submittals. As the vast majority of complete submittals were claimed CBI, the EPA concentrated on developing a compiled and quality assured ve rsion of the complete (CBI) data set. The 33 non-CBI Component 1 responses we re compiled into the da tabase first; then the

file was transferred to the secure CBI room for compilation of the responses that contained CBI.

Data submittals were reviewed to ensure that th e correct Facility ID had been properly entered. Any corrections or edits requested by respondents we re made to the complete (CBI) data set. In addition, the structure of the comp iled database differed slightly from the Reporting Tool in that it provided fields for notes in multiple database tables (the Reporting Tool included a “Notes” field at the facility level only). Therefore, part of the review pr ocess was to distribute the notes from the Reporting Tool Notes field to th e proper location in the compiled database.

In addition, not all respondents used the data base tool, but instead submitted data in Microsoft® Excel spreadsheets. The EPA asked mo st of these respondents to resubmit their data in the originally-requested Reporting Tool form at (exceptions were made for some small refineries), and all but a few of those did so. For the five Microsoft® Excel responses that remained, the spreadsheets had to be reviewed to ensure that, for example, process unit IDs were properly and consistently entered between sheets so that the data could be transferred into the compiled database. For the three Microsoft® Ex cel responses that cont ained CBI, no effort was made to develop a non-CBI version. As such, the compiled, non-CBI database contains entries for 146 facilities. Table 1 provides a crosswalk fr om the original mailing list to the Component 1 submittal, indicating which submittals are not in the non-CBI version of the Component 1

database.

It is important to note that for the non-CBI database, all reasonable efforts were made to

ensure that the database contai ned no CBI. In several cases, in formation provided in the “Notes” field of the responses contained information that the respondent had marked as CBI elsewhere in the Reporting Tool. In other cases, the responde nt provided a list of CBI claims in the cover letter, but the data had not b een correctly removed from the Reporting Tool. Any CBI found as part of this review was redacted from both th e compiled Component 1 database and the original Reporting Tool response. It is also important to note that the table “cbi_tracking” in the compiled database does not include a complete list of everything that was claimed as CBI by respondents. The Reporting Tool automatically added entries to this table when the corresponding box was checked on one of the da ta entry forms, but entries were not

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automatically added for other fields that respondents wished to claim as CBI. Some respondents

familiar with Microsoft® Access were able to add en tries directly to this table, but most simply deleted the additional information they considered CBI and then provided a statement that the

information was considered CBI in the “N otes” field or a separate cover letter.

Finally, as noted above, the non-CBI responses were reviewed and compiled prior to the addition of any non-CBI. For the creation of th e full non-CBI database, it is important to note that the partially compiled database containing th e 33 non-CBI facilities wa s used as the starting point. For those respondents that claimed some of their data as CBI, the non-CBI responses were imported into the compiled database exactly as submitted (with the exception of changing the Facility ID as needed and the removal of any inadvertent CBI as descri bed above). In other words, the “Notes” field was not broken out in to multiple tables for the 113 facilities that

claimed some of their data as CBI. Similarl y, any facility-requested changes for the 113

facilities that claimed some of their data as CBI are not reflected in the compiled non-CBI database. However, these corrections are docum ented in email correspondence presented with the original individual responses.

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Table 1. List of Petroleum Refinery ICR respondents

ICR ID Facility Name 1 

### City State Notes

AK5A0040 BP Exploration (Alaska) Inc. Prudhoe Bay AK

AK5A0050 ConocoPhillips Alaska, Inc. Kuparuk AK

AK5A0060 Petro Star Inc. North Pole AK

AK5A0070 Petro Star Inc. Valdez AK

AK5A0080 Tesoro Alaska Refinery Kenai AK

AK5A0090 Flint Hills Resources Alaska LLC North Pole AK

AL3C0030 Shell Chemical LP Saraland AL

AL3D0010 Goodway Refining LLC Atmore AL

AL3D0020 Hunt Refining Company Tuscaloosa AL

AR3D0100 Cross Oil Refining & Mark eting, Inc. Smackover AR

AR3D0110 Lion Oil Co. El Dorado AR

CA5A0120 BP West Coast Products, LLC Carson CA

CA5A0130 Chevron USA Inc. El Segundo CA

CA5A0140 Chevron USA Inc. Richmond CA

CA5A0150 Alon USA Bakersfield CA

CA5A0160 Shell Martinez Refinery Martinez CA

CA5A0170 Tesoro Los Angeles Refinery Wilmington CA

CA5A0180 Alon USA Long Beach Refinery Long Beach CA

CA5A0190 ExxonMobil Torrance Refinery Torrance CA

CA5A0200 Greka Energy Santa Maria Refining Santa Maria CA

CA5A0210 Valero Wilmington Asphalt Plant Wilmington CA

CA5A0220 Kern Oil & Refining Co. Bakersfield CA

CA5A0230 Alon USA Paramount Refinery Paramount CA

CA5A0240 San Joaquin Refining Co., Inc. Bakersfield CA

CA5A0250 Tenby Inc. Oxnard CA Did not respond because the facility is not a refinery

CA5A0260 ConocoPhillips Los Angeles Refinery
- Carson Plant Carson CA

CA5A0270 ConocoPhillips Los Angeles Refinery Wilmington CA

CA5A0280 ConocoPhillips San Francisco Refinery Rodeo CA

CA5A0290 ConocoPhillips - Santa Maria Arroyo Grande CA

CA5A0300 Tesoro Golden Eagle Refinery Martinez CA

CA5A0310 Valero Wilmington Refinery Wilmington CA

CA5A0320 Valero Benicia Refinery Benicia CA

CA5A0330 Lunday-Thagard Co. South Gate CA

CO4A0340 Suncor Energy (U.S.A.) Inc. Commerce City Refinery Commerce City CO Provided Excel spreadsheets that contained CBI; response not included in non-CBI Component 1 database

CO4A0350 Suncor Energy USA - Denver Commerce City CO Facility ID not used; responses submitted as part of CO4A0340

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ICR ID Facility Name 1 

### City State Notes

DE1A0360 PBF Energy Co. LLC Delaware City DE

GA1A0370 Nustar Asphalt Refining LLC Savannah GA

HI5A0380 Chevron Products Co Hawaii Refinery Kapolei HI

HI5A0390 Tesoro Hawaii Refinery Kapolei HI

IL2A0400 CITGO Lemont Refinery Lemont IL

IL2A0410 ExxonMobil Oil Corporation - Joliet Refinery Joliet IL

IL2A0420 Marathon Petroleum Co. - Illinois Refining Division Robinson IL

IL2A0430 WRB Refining LLC - Wood River Refinery Roxana IL

IN2A0440 BP Products North America, Inc. Whiting IN

IN2A0450 CountryMark Cooperative, LLP Mount Vernon IN

KS2C0460 Coffeyville Resources Refining & Marketing Coffeyville KS

KS2C0470 National Cooperative Refinery

Association McPherson KS

KS2C0480 Frontier El Dorado Refining Co. El Dorado KS

KY2A0490 Marathon Petroleum Co. - Catlettsburg Refinery Catlettsburg KY

KY2A0500 Somerset Refinery, Inc. Somerset KY

LA3C0510 Pelican Refining Co LLC Lake Charles LA

LA3C0520 Calcasieu Refining Company Lake Charles LA

LA3C0560 CITGO Petroleum Corporation -
LCMC Lake Charles LA

LA3C0570 ConocoPhillips Lake Charles Refinery Westlake LA

LA3C0580 Excel Paralubes Westlake LA Facility ID not used; responses submitted as part of LA3C0570

LA3C0590 ExxonMobil Baton Rouge Refinery Baton Rouge LA

LA3C0600 Chalmette Refining LLC Chalmette LA

LA3C0610 Marathon Petroleum Co. - Garyville Refinery Garyville LA

LA3C0620 Motiva Enterprises Convent Refinery Convent LA

LA3C0630 Motiva Enterprises Norco Refinery Norco LA

LA3C0640 Murphy Oil USA INC Meraux Refinery Meraux LA

LA3C0650 Valero St. Charles Refinery Norco LA

LA3C0670 Placid Refining Company Port Allen LA

LA3C0680 Shell Chemical LP St Rose Facility Saint Rose LA

LA3C0690 ConocoPhillips Company - Alliance Refinery Belle Chasse LA

LA3C0700 Alon USA Krotz Springs Refinery Krotz Springs LA

LA3D0530 Calumet Lubricants Co LP Cotton Valley LA

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ICR ID Facility Name 1 

### City State Notes

LA3D0540 Calumet Lubricants Co LP Princeton LA

LA3D0660 Calumet Shreveport Lubricants & Waxes, LLC Shreveport LA

MI2A0710 Marathon Petroleum Co. - Detriot Refinery Detroit MI

MN2B0720 Flint Hills Resources Pine Bend Refinery Rosemount MN

MN2B0730 Northern Tier Energy/Marathon
Petroleum Co. St. Paul Park MN

MS3C0740 Chevron Pascagoula Refinery Pascagoula MS

MS3D0750 Ergon Refining Inc Vicksburg MS

MS3D0760 Hunt Southland Refining Co. - Sandersville Refinery Heidelberg MS

MT4A0770 CHS, Inc. Laurel MT

MT4A0780 ConocoPhillips Co. Billings Refinery Billings MT

MT4A0790 ExxonMobil Billings Refinery Billings MT

MT4A0800 Montana Refining Company, Inc. Great Falls MT

ND2B0900 Tesoro Mandan Refinery Mandan ND

NJ1A0820 Hess Corporation - Port Reading Refinery Port Reading NJ

NJ1A0830 Chevron Products Co Perth Amboy NJ

NJ1A0840 Nustar Asphalt Refining LLC Paulsboro NJ

NJ1A0850 Conoco Phillips Bayway Refinery Linden NJ

NJ1A0860 Valero Energy Corp./PBF Energy Company, LLC Paulsboro NJ

NM3E0880 Western Refining Gallup Refinery Jamestown NM

NM3E0890 Holly Corp. Navajo Refinery Artesia NM

NM3E0891 Navajo Refining Co. (Holly Corp.) Lovington NM Did not originally receive a CAA Section 114 letter; requested additional Facility ID to report as two separate facilities

NV5A0810 Foreland Refining Corp Eagle Springs Refinery Ely NV

OH2A0910 BP-Husky Refining Company Oregon OH

OH2A0920 Marathon Petroleum Co. - Canton Refinery Canton OH

OH2A0930 Lima Refining Company Lima OH

OH2A0940 Sunoco, Inc./Toledo Refining Company, LLC Oregon OH

OK2C0950 ConocoPhillips - Ponca City Refinery Ponca City OK

OK2C0960 Wynnewood Refining Company Wynnewood OK

OK2C0970 Holly Refining & Marketing Tulsa LLC (East) Tulsa OK

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ICR ID Facility Name 1 

### City State Notes

OK2C0980 Holly Refining & Marketing Tulsa LLC (West) Tulsa OK

OK2C0990 Valero Ardmore Refinery Ardmore OK

OK2C1000 Ventura Refining & Transmission,
LLC Thomas OK

PA1A1020 Sunoco Inc (R&M) - Marcus Hook Refinery Marcus Hook PA

PA1A1030 Sunoco Inc. Philadelphia Refinery Philadelphia PA

PA1A1040 ConocoPhillips Co - Trainer Refinery Trainer PA

PA1B1010 American Refining Group, Inc. Bradford PA

PA1B1050 United Refining Co Warren PA

TN2A1060 Valero Memphis Refinery Memphis TN

TX3A1070 AGE Refining, Inc. San Antonio TX

TX3A1080 Alon USA Big Spring Refinery Big Spring TX

TX3A1120 Western Refining El Paso Refinery El Paso TX

TX3A1190 Delek Refining Ltd Tyler TX

TX3A1230 WRB Refining LLC - Borger Refinery Borger TX

TX3A1290 Valero Three Rivers Refinery Three Rivers TX

TX3A1300 Valero McKee Refinery Sunray TX

TX3B1090 Total Petrochemicals USA, Inc. Port Arthur Refinery Port Arthur TX

TX3B1100 Belvieu Environmental Fuels Mont Belvieu TX Did not respond because the facility is not a refinery

TX3B1110 BP Products North America, Inc. Texas City TX

TX3B1130 CITGO Corpus Christi Refinery (East) Corpus Christi TX

TX3B1131 CITGO Corpus Christi Refinery (West) Corpus Christi TX Did not originally receive a CAA Section 114 letter; requested additional Facility ID to report as two separate facilities

TX3B1140 Valero Corpus Christi Refinery East Corpus Christi TX

TX3B1150 Pasadena Refining System Inc. Pasadena TX

TX3B1160 ExxonMobil Refining & Supply Baytown Refinery Baytown TX

TX3B1170 ExxonMobil Oil Beaumont Refinery Beaumont TX

TX3B1180 Flint Hills Resources Corpus Christi Refining Complex (West) Corpus Christi TX

TX3B1181 Flint Hills Resources Corpus Christi Refining Complex (East) Corpus Christi TX Did not originally receive a CAA Section 114 letter; requested additional Facility ID to report as two separate facilities

TX3B1200 Houston Refining LP, A LyondellBasell Company Houston TX

TX3B1210 Marathon Petroleum Co LLC Texas City TX

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ICR ID Facility Name 1 

### City State Notes

TX3B1220 Motiva Enterprises Port Arthur Refinery Port Arthur TX

TX3B1240 ConocoPhillips Sweeny Refinery Old Ocean TX

TX3B1250 Valero Port Arthur Refinery Port Arthur TX

TX3B1260 Deer Park Refining Limited Partnership Deer Park TX

TX3B1270 Trigeant - BTB Refining Corpus Christi TX

TX3B1280 South Hampton Resources Silsbee TX Did not respond because the facility is not a refinery

TX3B1310 Valero Corpus Christi Refinery West Corpus Christi TX

TX3B1320 Valero Houston Refinery Houston TX

TX3B1330 Valero Texas City Refinery Texas City TX

UT4A1340 Tesoro Salt Lake City Refinery Salt Lake City UT

UT4A1350 Chevron Products Co. Salt Lake Refinery Salt Lake City UT

UT4A1360 Silver Eagle Refining-Woods Cross

Inc. Woods Cross UT

UT4A1370 Big West Oil, LLC North Salt Lake UT

UT4A1380 Holly Refining & Marketing Company - Woods Cross Refinery Woods Cross UT

VA1A1390 Western Refining Yorktown Refinery Grafton VA

VI6A1530 HOVENSA LLC St. Croix VI

WA5A1400 BP West Coast Products LLC Blaine WA

WA5A1410 Shell Oil Products US - Puget Sound Refinery Anacortes WA

WA5A1420 Tesoro Anacortes Refinery Anacortes WA

WA5A1430 ConocoPhillips Ferndale Refinery Ferndale WA

WA5A1440 U.S. Oil & Refining Co. Tacoma WA

WI2B1460 Murphy Oil USA, Inc. Superior Refinery Superior WI

WV1B1450 Ergon West Virginia Inc Newell WV

WY4A1470 Frontier Refining, Inc. Cheyenne WY

WY4A1480 Sinclair Little America Refinery Casper WY Provided Excel spreadsheets that contained CBI; response not included in non-CBI Component 1 database

WY4A1490 Garco Energy Douglas WY

WY4A1500 Silver Eagle Refining-Evanston Evanston WY

WY4A1510 Sinclair Wyoming Refining Company Sinclair WY Provided Excel spreadsheets that contained CBI; response not included in non-CBI Component 1 database

WY4A1520 Wyoming Refining Co Newcastle WY