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 
2

TABLE OF CONTENTS 

Subpart A..................................................................................................................................3

Background on Accuracy and Calibration Requirements ..................................................3 

Calibration- Temperature and Pressure Transmitters for Orifice, Nozzle, and Venturi 

Meters..................................................................................................................................10 

Background Information on BAMM .................................................................................12 

Subpart C................................................................................................................................14

Heterogeneity and Variability of Municipal Solid Waste in Relation to Municipal Waste 

Combustor Emissions .........................................................................................................14 

Default Biomass Fraction for Municipal Solid Waste and Tires.......................................26 

Comparison of 250 Tons of MSW Per Day And 250 MMBtu/hr Heat Input Capacity ...27 

Subpart C and D.....................................................................................................................31

Part 75 Units that Combust Biomass (Results of Database Query) ..................................31 

Subpart X and Y.....................................................................................................................34

Evaluation of Process Heaters Less than 30 MMBtu/hr Rated Heat Capacity ................34 

Subpart OO.............................................................................................................................55

Impact of Minor Constituents on the GW of the Mixture as a Function of Concentration

.............................................................................................................................................55 

Subpart PP..............................................................................................................................56

CO2 Density Value ..............................................................................................................56 
3

Subpart A 

Background on Accuracy and Calibration Requirements1

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. 

 

1 Developed with support from Eastern Research Group. 
4

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.” (http://www.arb.ca.gov/cc/reporting/ghg-rep/ghgrep.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. 
5

 

• 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; 

http://www.pacode.com/secure/data/070/chapter10/chap10toc.html). 

Enforcement, inspection, and certification (“sealing”) is done at the county level. 
6

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 

Tanks, bins 

and hoppers. 

Takes high 

impacts, 

Hydraulic Load 

Cells 

Up to 10,000,000 

lb 

0.25% 

Hazardous 

areas. 

insensitive to 

temperature. 

Expensive, 

complex. 

Intrinsically 

safe. 

Pneumatic Load Slow response. 

Cells 

Wide High Food industry, 

hazardous 

areas 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, offcenter 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 0-50,000 lbs 

washer Load 

Cells 0-200 lbs. typ. 

1% Small scales Small, 

inexpensive 

Loads must be 

centered, no load 

movement 

permitted 

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 
 

8

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. CESLANDTEC 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) 

Compression Canister Load 

Cells 

1% 

S-Beam Load Cells 0.02% 

Pancake Type Load Cells 0.1% 

Honeywell 

Ring Type Load Cells 1% 

S-Beam Load Cells 1% 

Shear Beam Load Cells 1% 

ADI Artech Bending Beam Load Cells 1% 

Compression Canister Load 

Cells 

1% 

Eilerson 

Insdustrial 

Sensors 

Various Load Cell Types 0.25% 

Control Systems Weigh Hoppers 0.5% 
 

9

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

Technology Belt Feeder 0.1-5% 

Siemens Weigh Hoppers 0.25-0.5% 

Industry USA Belt Weighers 0.5-2% 

Truck and Railroad Scales 

0.25-0.4% (static) 

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

Floor Scales 0.05% 

Avery Weigh 

Tronics 

Compression Load Cells 0.05% 

Kistler-Morse Compression Load Cells 0.08% 

Rice Lake 

Weighing 

Systems 

Belt Scales 0.25% 

 
 

10

Calibration- Temperature and Pressure Transmitters for Orifice, Nozzle, and Venturi Meters 

Based on conversations with industry since release of the 2009 Final Rule, EPA learned of a 

concern regarding temperature and pressure transmitters for orifice, nozzle and venturi meters. 

Specifically, the petroleum refining and petrochemical industry informed us that some existing 

meters in refinery fuel gas systems do not have temperature and total pressure sensors and 

transmitters installed immediately adjacent to the meter. However, some of these installations 

have one pressure and temperature measurement point that can provide compensation 

information for the particular fuel line or system and meters installed on the line or system. The 

industry expressed concern that new pressure and temperature monitors cannot be safely added 

without a facility or unit shut-down unless the system can be securely isolated and bypassed to 

enable continued unit operation. Moreover, they noted that even if a system can be isolated, the 

work involved to plan, engineer, and execute the installation and tie in of these devices to the 

process data systems will take considerable time and may not be feasible before the end of 2010. 

The industry representatives suggested that conditions at a flow meter can be reliably and 

accurately represented by temperature and pressure indications remote from the flow meter, and 

therefore that the use of remote temperature and pressure indication should be allowed if a 

reporter can demonstrate that these can be used to provide representative compensation for the 

remotely located fuel meter. The industry representatives provided the approaches described in 

the following paragraphs as examples of potential methods to demonstrate that a remote 

measurement provides a representative indication: 

A. Representative Conditions 

In order to determine if the remote temperature and pressure values are representative of 

conditions at the flow meter, temperature and pressure surveys could be conducted to determine 

the difference between the readings at the transmitters not proximal to the meter and the actual 

conditions at the meter. A typical temperature survey involves the use of an infrared gun, reading 

local gauges, or an equivalent method and recording the temperature for each flow meter, near 

each flow meter. If a temperature transmitter is not proximal to the meter, the difference between 

the recorded value and the monitored temperature is recorded to give a temperature loss for the 

line. This temperature loss, if significant, is then used to correct the monitored temperatures for 

the particular flow meter. Pressure throughout a system is not expected to vary as widely and 

could be determined through a pressure survey or calculated using standard fluid dynamics 

equations, with the resulting calculated result used to compensate the measured flow at the fuel 

metering device. A pressure survey generally involves using a calibrated pressure gauge to 

measure the pressure in the pipe at, or as close as possible to, the meter. The measured pressure 

would then be compared to the pressure monitoring from an existing transmitter on the 

line/system and an appropriate “correction factor” calculated to correct the live pressure 

transmitter readings to the corrected pressure at the meter. 

B. Corrections 

In the event a correction is needed to account for temperature and pressure changes, such 

corrections could be done by applying a “correction factor” to the measured values based on 
 

11

comparisons in the data handling/calculation systems, such as through the temperature and 

pressure surveys described above. 

C. Active Compensation 

Active compensation, in the context discussed, is the automated feed of the measured total 

pressure and temperature information into the metering calculation system algorithms 

periodically (e.g., every minute or every 10 minutes). In many current configurations, the total 

pressure and temperature data used in these algorithms are constants set to provide a reasonable 

match with the system in question. The sensors and transmitters furnishing the automated 

pressure and temperature data may be located adjacent to the meter or on the same line/system 

remote from the meter. 
 

12

Background Information on BAMM 

Based on conversations with the petrochemical and petroleum refining industry since release of 

the 2009 Final Rule, EPA learned of a concern regarding the ability to install measurement 

devices in 2010 if installation would require a unit (or process line or facility) shutdown or a hot 

tap. In the context of these discussions, industry representatives provided additional information 

regarding (i) the circumstances that would justify use of Best Available Monitoring Methods 

(BAMM) beyond 2010, and (ii) the proposed process for implementing BAMM beyond 2010. 

The industry representatives surveyed members of their trade associations to obtain information 

related to this issue. According to the industry representatives, twenty-three companies 

responded from a broad cross-section of the industry ranging from companies that have a single 

refinery to the large household names that have several refineries in the United States. These 

respondents operate facilities ranging from refineries that make a single product with a limited 

range of process units to plants which produce a much larger number of products and have a 

substantial number of process units at the facility. According to the representatives, it is common 

knowledge that refineries vary substantially in their capacity and production, thus there is no 

such thing as the typical refinery. 

According to the information provided by the industry representatives, the appropriate time to 

install new monitoring equipment is during normally scheduled shutdowns or turnarounds 

because: 

• It avoids the inherent safety risks of hot tapping; 

• It minimizes the costs to install monitoring equipment; and 

• In the interim, prior to equipment installation, there are suitable methods to determine the 

greenhouse gas emissions which are adequate for reporting purposes. 

Industry noted that while there are some rare situations in which the bypass or isolation of the 

equipment could enable a monitoring device to be installed while the process continues to 

operate, it would be impossible to estimate for purposes of these revisions the number of such 

specific situations at the present time because it would require an engineering review of pipe 

configuration and other engineering considerations at each monitor site and would inevitably 

require months to complete. Rather, it is an issue that is better suited to be addressed in the 

context of an individual application to continue a limited use BAMM after 2010. 

According to the industry representatives none of the companies reported that their turnaround 

cycles for Crude Distillation Units, Vacuum Distillation Units, FCCUs, Distillate Hydrotreating 

Units, Cat Feed Hydrotreaters, Hydrocrackers, Hydrogen Plants, Catalytic Reformers, Coking 

Units, Sulfur Recovery Units, Boilers or Steam Generation Units, or Cogeneration Units were 

one year or less. Seven companies did report that their turnarounds varied for Boilers or Steam 

Generation Units, with at least some on a one year cycle; six companies noted similar 

turnarounds for Catalytic Reformers. 

When asked how long BAMM would be needed for each type of unit, industry provided the 

typical range of turnaround cycles provided by the companies with regards to the units listed 
 

13

above. They also noted that there is no generally applicable cycle for the entire industry for any 

of these units; in addition, the companies typically vary the cycle between refineries to avoid 

having all of the manufacturing capacity shut down at the same time. Industry also emphasized 

that there are exceptions to the ranges provided below both on the high side and on the low side 

and thus the ranges provided are not all inclusive but a range that covers the larger part of the 

industry. All the ranges are in years. 

Crude Distillation Units: 4 – 7 

Vacuum Distillation Units: 4 – 6 

FCCU: 4 – 5 

Distillate Hydrotreating Units: 3 – 5 

Cat Feed Hydrotreaters: 3 – 5 

Hydrocrackers: 3 – 5 

Hydrogen Plants: 2 – 5 

Coking Units: 3 – 5 

Sulfur Recovery Units: 3 – 5 

Cogeneration Units: 3 – 5 

The industry representatives also provided information regarding what types of monitoring 

devices are most at issue regarding installation in 2010, noting that their survey showed that fuel 

gas meters and/or their associated sensors, transmitters, and piping are the most problematic 

devices for the refining sector in this time frame. They stated that if all monitoring devices had 

to be installed in 2010, facilities would likely be required to engage in a number of “hot taps” 

(and assume their inherent risks and hazards to worker safety and facility operations) to install 

specific instruments. The industry representatives considered “hot-tapping” to be the installation 

of devices which penetrate the pipe or vessel wall while in service, which involves welding a 

special fitting on the pipe or vessel exterior, installing a full-bore opening valve on this fitting, 

using specialty tools to drill a hole through the wall, and then installing the device through the 

penetration created. According to industry, the risks with hot-tapping are: 

• Uncontrolled release of flammable and/or explosive gases and the risk of ignition and 

fire or flash fire; and 

• Burn-through and ignition while welding the fitting on the pipe/vessel. 

The industry representative also noted that hot-tapping is regulated under OSHA regulations at 

29 C.F.R. 1910.147(a)(2)(iii)(B), and that OSHA-mandated criteria regulating this activity 

discourage hot tapping in order to limit the risk of employee injury. 

Regarding the frequency by which processes or units are shut down, industry representatives 

indicated that, ideally, process unit shutdowns and turnarounds are the same, and if unscheduled 

shut downs do occur, they tend to be short and the units are restarted as quickly as safe 

operations allow. According to industry representatives, it is generally not feasible to install new 

equipment during unscheduled unit outages. 
 

14

Subpart C 

Heterogeneity and Variability of Municipal Solid Waste in Relation to Municipal Waste 

Combustor Emissions2

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 carbon3in MSW, and the range of possible 

variation of composition. 

 

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

International 

3 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 
 

15

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 

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 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 

 

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). 
 

16

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 frequently4on the 

challenges of characterizing the generation and composition of MSW. Inconsistencies in statelevel 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. 

 

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

17

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 Table 2. According to Figure 1, Connecticut combusts 65% of its MSW, and Florida, 

Hawaii, Maine, and Massachusetts manage over 20% of their MSW in waste-to-energy projects5. 

Twenty states do not have any MWCs within their borders. 

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

 

5 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) 
 

18

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

Districtof Colum

bia

Florida

G

eorgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland

Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

N

e

braska

N

evada

N

ew

Ham

pshire

N

ew Jersey

N

ew

Mexico

N

ew

York

N

orth Carolina

N

orth Dakota

Ohio

Oklahoma

Oregon

Pennsylvania

Rho

d

eIsland

South Carolina

SouthDakota

Tennessee

Texas

Utah

Verm

ont

Virginia

Washington

West Virginia Wisconsin

Wyo

ming

Percentofstate

MSW generation

Landfilled

Recycled

Waste-to-energy

Figure 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 Figure 2, 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. 
 

19

Figure 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 
 

20

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 Figure 3. 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. 

Figure 4 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 Figure 2), 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. 
 

21

0

5

10

15

20

25

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Recycling rate

Number of counties

(a) New Mexico

0

20

40

60

80

100

120

140

160

0 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Recycling rate

Number of municipalities

(b) Massachusetts 

0

10

20

30

40

50

60

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Recycling rate

Number of municipalities

(c) New Hampshire 

Figure 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.
 

22

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Discard

e

d

m

u

nicipal solid

wa

ste

stre

a

m

co

m

p

osition

(by

%

wet m

ass)

Glass

Residues

Metal

Durable goods

Plastics

Paper

Organics

Figure 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). 

Table 3 and 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). 
 

23

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

24

Figure 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 

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 

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 

http://www.epa.gov/osw/nonhaz/municipal/msw99.htm
 

25

EPA. (2009). Municipal Solid Waste in the United States: 2008 Facts and Figures, Data Tables. 

U.S. Environmental Protection Agency (EPA). Retrieved from 

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 

http://www.eia.doe.gov/cneaf/solar.renewables/page/mswaste/msw_report.html

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 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: 10.1061/(ASCE)EE.1943-

7870.0000032 
 

26

Default Biomass Fraction for Municipal Solid Waste and Tires 

EPA has amended 40 CFR 98.33(e)(3) to add an alternative calculation methodology for 

biogenic CO2 emissions from the combustion of tires and/or MSW that may be used when the 

total contribution of these fuels to the unit’s heat input is 10 percent or less. The methodology 

may also be used for small, batch incinerators that burn no more than 1,000 tons of MSW per 

year. Units that qualify for and elect to use the methodology use Tier 1 to calculate the total 

annual CO2 emissions from the combustion of the MSW or tires, and multiply the result by an 

appropriate default factor that represents the biomass fraction of the fuel, to obtain an estimate of 

the annual biogenic CO2 emissions. This memo provides the underlying data used to generate 

the default factors of 0.20 for tires and 0.60 for MSW that is found in the rule. 

MSW 

See Table 3 in the previous section: “Heterogeneity and Variability of Municipal Solid Waste in 

Relation to Municipal Waste Combustor Emissions”. The default factor of 0.60 is the average 

biogenic fraction of MSW during the time series from 1989 through 2005. 

2. Tires 

The default value for tires was based on data available from the Rubber Manufacturers 

Association (RMA). According to RMA the typical composition of tires is different depending 

on if it is a passenger tire or a truck tire. The characteristics are presented below. The default 

factor of 0.20 is the average biogenic fraction of passenger and truck tires. 

Passenger Tire

Natural rubber 14 %

Synthetic rubber 27%

Carbon black 28%

Steel 14 - 15%

Fabric, fillers, 

accelerators, antiozonants, 

etc.

16 - 17%

Average weight: New 25 lbs, 

Scrap 22.5 lbs.

Source: Rubber Manufacturers Association. 

http://www.rma.org/scrap_tires/scrap_tire_markets/scr

ap_tire_characteristics/ 

Truck Tire

Natural rubber 27 %

Synthetic rubber 14%

Carbon black 28%

Steel 14 - 15%

Fabric, fillers, 

accelerators,

antiozonants, etc.

16 - 17%

Average weight: New 120 lbs., 

Scrap 110 lbs.
 

27

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

Background and Summary6

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 

 

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

28

Estimates of the heating value of MSW are given in Table 4. 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 4: Heating value for estimates for MSW 

Heating value of MSW 

Btu/pound mmBtu/short ton 

Notes Source 

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 materialspecific 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 materialspecific 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: 

o 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 

o 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 
 

29

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 Table 4. 

Results 

Table 5 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 Table 4 above, and in 40 CFR § 60.58b(j). 

Table 5: Equivalent maximum rated heat input capacity at various MSW heat input rates for two different 

MWC rated input capacities 

Equivalent maximum rated heat input capacity (mmBtu/hour) 

Max. rated input 

capacity (short 

tons/day) 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 

http://www.eia.doe.gov/cneaf/solar.renewables/page/mswaste/msw_report.html, accessed 

June 21, 2010. 
 

30

EPA (1996) AP 42, Fifth Edition, Volume I Chapter 2: Solid Waste Disposal, Section 2.1: 

Refuse Combustion, p. 2.1-29. Retrieved from 

http://www.epa.gov/ttn/chief/ap42/ch02/index.html, accessed June 21, 2010. 
 

31

Subpart C and D 

Part 75 Units that Combust Biomass (Results of Database Query) 

On August 24, 2010, a query of the CAMD database was performed, to identify units in 

Part 75 monitoring and reporting programs (i.e., Acid Rain, CAIR, RGGI, NOx SIP Call) that 

combust biomass and/or partially biogenic fuels such as municipal solid waste (MSW) and tirederived fuel (TDF), either as the primary fuel or as a secondary fuel. For each unit, the query 

also provided the unit’s reporting frequency (i.e., year-round or ozone season-only), its Part 75 

heat input methodology, and (if applicable) its CO2 mass emissions methodology. 

The objective of the query was to find out how many Part 75 units that burn biomass or 

partly biogenic fuels would qualify to use a recently-proposed Greenhouse gas (GHG) emissions 

reporting option under 40 CFR Part 987. That option would allow Part 75 units to report only the 

total annual CO2 mass emissions in their Part 98 GHG emissions reports, instead of separately 

reporting biogenic CO2 and non-biogenic CO2 emissions. 

To qualify for the optional biogenic CO2 reporting, a unit that combusts biomass or 

partly biogenic fuel(s) would either have to be: (1) an Acid Rain Program (ARP) unit; (2) a 

RGGI Program unit; or (3) a CAIR unit (or NOx SIP Call unit) that is not in ARP or RGGI, and 

that reports heat input data (but not CO2 mass emissions data) to EPA year-round using Part 75 

methods. Units in Categories (1) and (2) are subject to Subpart D of Part 98. Units in Category 

(3) fall under §98.33(a)(5) of Subpart C. Many units are in more than one Part 75 program. 

The results of the query showed that there are 53 units in Part 75 programs that combust 

biomass or partly biogenic fuel. Ten of these units would not qualify for optional biogenic CO2 

reporting at the present time, because they are subject only to the CAIR Ozone Season Program, 

and report heat input data to EPA on an ozone season-only basis, rather than year-round---

however, these 10 units could qualify in subsequent years if they were to switch to year-round 

reporting. The status of three other units that combust refuse (MSW) as a secondary fuel is 

questionable, because units that combust MSW are required by Part 98 to quantify biogenic CO2 

emissions (see §98.33(e)(3))8. By means of a phone call to one of the facilities on the list9, we 

have learned that there is a fourth Part 75 unit that burns MSW as a backup fuel. Finally, one unit 

identified by the query was eliminated from further consideration because it combusts coal 

refuse, not municipal solid waste (the monitoring plan was incorrectly coded). 

 

7

See the proposed revisions to §§98.3(c), 98.33, and 98.36(d) in the August 11, 2010 Federal Register notice (75 

FR 48744-48814). 

8 These three units are included as candidates for the optional biogenic CO2 reporting only because they are subject 

to Part 75. Note, however, that if the proposal to make biogenic CO2 emissions reporting optional is finalized, the 

rule would become internally inconsistent, because §98.33(e)(3) would require Part 75 units that combust MSW to 

quantify biogenic CO2, but the new rule provision would not require the facility to report biogenic CO2 emissions 

separately. 

9

 August 25, 2010 telephone call from Robert Vollaro of CAMD to Donald Kom of the City of Ames, IA 
 

32

This means that to the best of our knowledge, there are an estimated 43 Part 75 units that 

could presently qualify for the proposed optional biogenic CO2 reporting under Part 98. The 

adjusted results of the query are presented in Table 1, below. The 10 units that could not 

currently qualify for the optional reporting, but may be able to qualify in future years, are shown 

in Table 2, below. Biomass fuels and partly biogenic fuels are highlighted in yellow in Tables 1 

and 2. 

Table 1: Part 75 Units that Would Presently Qualify 

for Optional Biogenic CO2 Reporting 

Unit Type 

Primary fuel Secondary fuel Number of 

Units EGU Non-EGU 

Coal TDF 17 17 - 

Coal Wood 8 6 2 

Wood Natural Gas 7 7 - 

Coal Municipal Solid Waste 4 3 1 

Wood ------- 2 2 - 

TDF ------- 1 1 - 

Coal Process Sludge 1 - 1 

Wood Other Solid Fuel 1 1 - 

Wood Coal 1 1 - 

Residual Oil Wood 1 - 1 

Table 2: Part 75 Units that May Qualify for Optional Biogenic CO2 Reporting in 

Future Years 

Unit Type 

Primary fuel Secondary fuel Number of 

Units EGU Non-EGU 

Coal Wood 5 1 4 

Wood Coal 2 2 - 

TDF LPG 2 2 - 

Coal Process Sludge 1 - 1 

Table 1 shows that twelve (12) of the qualifying units combust biomass or partly biogenic 

fuel as the primary fuel. For 11 of these 12 units, wood is the primary fuel, and for the other 

unit, TDF is the primary fuel. Nine of the 12 units combust secondary fuels (seven of them burn 

natural gas, one burns coal, and one burns “other” solid fuel). Three of the units (two wood-fired 

units and one TDF-fired unit) list no secondary fuels. 

For the remaining 31 units in Table 1, 30 of them combust coal as the primary fuel and 

one unit combusts residual oil. All 31 of the units burn biomass or partly biogenic fuel as a 
 

33

secondary fuel---17 of them burn TDF, 9 of them burn wood, 4 of them burn MSW, and one 

paper mill unit combusts process sludge. 

 Thirty eight (38) of the 43 units in Table 1 are electricity generating units (EGUs) and 

the other 5 are non-EGUs. Four (4) of the 5 non-EGUs are located at pulp and paper 

manufacturing facilities. 

For all the results from the database query, please see the data entry to docket EPA-HQOAR-2008-0508 titled List_of_Part_75_units_that_combust_biomass. 

Results

The results of the CAMD database query show that a relatively significant number of Part 

75 units (43) would qualify for optional biogenic CO2 emissions reporting under the August 11, 

2010 proposed revisions to Part 98. Twelve (12) of these units combust wood or TDF as the 

primary fuel, and the other 31 units combust a variety of biogenic or partly biogenic fuels (i.e., 

wood, TDF, MSW, process sludge) as secondary fuels. Ten other Part 75 units that report 

emissions data to EPA on an ozone season-only basis could not qualify for the optional biogenic 

CO2 reporting at the present time, but could qualify in future years by switching to year-round 

reporting. 

 
 

34

Subpart X and Y 

Evaluation of Process Heaters Less than 30 MMBtu/hr Rated Heat Capacity 

I. Purpose10

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 

 

10 Developed with support from Jeff Coburn, RTI International. 
 

35

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-10F0283K. June 11. 

EIA (Energy Information Administration). 2006. Refinery Capacity Report 2006. Prepared by 

the Energy Information Administration, Washington, DC. June 15. 
 

36

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 
 

37

Chevron USA Products Co. – Richmond, CA 

Unit Pollutant Requirement Emission Limit Deadline 

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 
 

38

 Valero (formerly Ultramar Diamond Shamrock) – Wilmington, CA 

Unit Pollutant Requirement Emission Limit Deadline 

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 
 

39

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 
 

40

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 
 

41

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 
 

42

Marathon Ashland Petroleum LLC – Garyville, LA 

Unit Pollutant Requirement Emission Limit Deadline 

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 
 

43

Marathon Ashland Petrol. LLC – Detroit, MI 

Unit Pollutant Requirement Emission Limit Deadline 

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 
 

44

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 
 

45

 Conoco Inc. – Billings, MT 

Unit Pollutant Requirement Emission Limit Deadline 

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 federallyenforceable emission limits 0.040 lb/MMBtu 3 years 
 

46

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

Unit Pollutant Requirement Emission Limit Deadline 

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 
 

47

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 
 

48

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

Unit Pollutant Requirement Emission Limit Deadline 

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 
 

49

 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) 
 

50

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 
 

51

Marathon Ashland Petrol. LLC – Texas City, TX 

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 

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 
 

52

 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 
 

53

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 
 

54

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 

 

 
 

55

Subpart OO 

Impact of Minor Constituents on the GW of the Mixture as a Function of Concentration 

Impact of Minor Constituents on the GWP of the Mixture as a Function of Concentration

GWP Relationship

Concentration of 

Minor 

Constituent

GWP of 

Major 

Constituent

GWP of 

Minor 

Constituent

CO2e of 

Major 

Constituent

CO2e of 

Minor 

Constituent

Weighted 

GWP of 

Combination

Percent by Which GWP of 

Mixture is Higher than That 

of Major Constituent

10x (hypothetical) 0.1% 100 1000 99.9 1 100.9 0.9%

0.5% 100 1000 99.5 5 104.5 4.5%

1.0% 100 1000 99 10 109 9.0%
 

56

Subpart PP 

CO2 Density Value 

EPA proposed that standard temperature and pressure for subpart PP be 60 degrees F and 1.000 

atm. For the proposal, EPA identified a table in the online database of thermodynamic properties 

developed by the National Institute of Standards and Technology (NIST) (available at 

http://webbook.nist.gov/chemistry/fluid/) with density values of CO2 listed by temperature in 

degrees F and by pressure in psi. EPA decided to use the density values of CO2 at 60 degrees F 

and at 14.713 psi, which is equivalent to 1.00116 atm pressure, as the density value of CO2 in 

the proposal. That value is 0.0018704 metric tons per standard cubic meter. 

Between the proposal and this final rule, EPA identified a second NIST table on the online 

database with density values of CO2 listed by temperature in degrees F and by pressure in atm. 

By using this NIST table, we can select a more precise value for the density of CO2 at the exact 

standard conditions specified for subpart PP. Therefore, in this final action, we are using 

0.0018682 metric tons per standard cubic meter as the density of CO2 because it is the density 

value of CO2 at 60 degrees F and 1.000 atm.