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

Subpart A: Background Research on Definitions .................................................................. 10

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

Municipal Waste Combustor Emissions................................................................................... 11

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

Capacity ....................................................................................................................................... 23

Subpart X (Petrochemical Production) and Y (Petroleum Refineries): Evaluation of 

Process Heaters Less than 30 MMBtu/hr Rated Heat Capacity ............................................ 27
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.

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

test results.

 

1 Developed with support from Eastern Research Group. 
4

 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.

 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.
5

 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)

AV

AC

(P

AGA Report No. 7, Measurement of Natural Gas by Turbine 

Meter

AGA7 19 0.10 0.10

American Petroleum Institute Method in Appendix D API 32 0.20 0.20

ASME Method in Appendix D ASME 40 0.40 0.20

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

International Organization for Standardization Method in 

Appendix D

ISO 33 0.30 0.30

Laboratory Comparison against Reference Meter LCRM 530 0.20 0.20

NIST-Traceable Method Approved by Petition NIST 84 0.20 0.20

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

TEST TYPE LOW LEVEL 

ACCURACY

MID LEVEL 

ACCURACY

HIG

AC

ACCURACY SPEC CODE 

DESCRIPTION

ACCURACY 

SPEC CODE

TOTAL 

TEST 

AVG

(PERCENT)

TOTAL 

TEST 

AVG 

(PERCENT)

TOTAL 

TEST 

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

Sum of Accuracies of All Components SUM 678 0.30 703 0.50 702
Table A-3. Load Cell Performance Comparison

Type Weight Range

Accuracy 

(Full Scale) Applications Strengths Weaknesses

Mechanical Load Cells

Hydraulic Load 

Cells

Up to 10,000,000 

lb

0.25% Tanks, bins 

and hoppers.

Takes high 

impacts,

Expensive, 

complex.

Hazardous 

areas.

insensitive to 

temperature.

Pneumatic Load 

Cells

Wide High Food industry, 

hazardous 

areas

Intrinsically 

safe.

Slow response.

Contains no 

fluids.

Requires clean,

dry air

Strain Gage Load Cells

Bending Beam 

Load Cells

10-5,000 lbs. 0.03% Tanks, 

platform 

scales,

Low cost, 

simple 

construction

Strain gages are 

exposed, require 

protection

Shear Beam Load 

Cells

10-5,000 lbs. 0.03% Tanks, 

platform 

scales, 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 

washer Load 

Cells

0-50,000 lbs 1% Small scales Small, 

inexpensive

Loads must be 

centered, no load 

movement 

permitted

0-200 lbs. typ.

Other Load Cells

Helical 0-40,000 lbs. 0.20% Platform, 

forklift, wheel 

load,

automotive 

seat weight

Handles off-axis 

loads, overloads, 

shocks

Fiber optic 0.10% Electrical 

transmission

cables, stud or 

bolt mounts

Immune to 

RFI/EMI and

high temps, 

intrinsically safe

Piezo-resistive 0.03% Extremely 

sensitive, high

signal output 

level

High cost, 

nonlinear output

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

Honeywell

Compression Canister Load 

Cells 1%

S-Beam Load Cells 0.02%

Pancake Type Load Cells 0.1%

Ring Type Load Cells 1%

ADI Artech

S-Beam Load Cells 1%

Shear Beam Load Cells 1%

Bending Beam Load Cells 1%

Compression Canister Load 

Cells 1%

Eilerson 

Insdustrial 

Sensors

Various Load Cell Types 0.25%

Control Systems Weigh Hoppers 0.5%
9

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

Technology Belt Feeder 0.1-5%

Siemens 

Industry USA

Weigh Hoppers 0.25-0.5%

Belt Weighers 0.5-2%

Avery Weigh 

Tronics

Truck and Railroad Scales 0.25-0.4% (static)

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

Floor Scales 0.05%

Compression Load Cells 0.05%

Kistler-Morse Compression Load Cells 0.08%

Rice Lake 

Weighing 

Systems

Belt Scales 0.25%

 
10

Subpart A: Background Research on Definitions

EPA is proposing to add definitions of the following terms to 40 CFR 98.6 due to the large 

number of questions received requesting clarification of the definition of these terms: 

agricultural byproducts, primary fuel, solid byproducts, waste oil, and wood residuals. The 

proposed definitions are based on the results of an Internet search and experience with terms in 

the Acid Rain Program

For the purposes of Part 98, “Agricultural byproducts” would include the parts of crops that are 

not ordinarily used for food (e.g., corn straw, peanut shells, pomace, etc.). “Solid byproducts” 

would include plant matter such as vegetable waste, animal materials/wastes, and other solid 

biomass, except for wood, wood waste and sulphite lyes (black liquor). “Wood residuals” would 

include waste wood recovered primarily from MSW streams, construction and demolition debris, 

and primary timber processing. Wastewater process sludge generated at pulp and paper mills 

would also be included; however, we are soliciting comment on whether the default emission 

factors for wood and wood residuals are appropriate for paper mill wastewater sludge, and, if 

not, what those emission factors should be. “Primary fuel” would be defined as the fuel that 

contributes the greatest percentage of the annual heat input to a combustion unit. “Waste oil,” 

which we are proposing to add to Table C-1 as a new fuel type, would be defined as oil whose 

physical properties have changed, either through storage, handling, or use, so that the oil can no 

longer be used for its original purpose. Waste oil would include both automotive and industrial 

oils of various types. 

This document includes some relevant references. 

Agricultural By-products:

http://cfpub.epa.gov/ncer_abstracts/index.cfm/fuseaction/display.abstractDetail/abstract/8953/rep

ort/0

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

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

Primary Fuel:

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

Waste Oil:

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

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

Wood Residuals

http://www.fpl.fs.fed.us/documnts/pdf1998/mckee98a.pdf
11

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 

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 
12

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

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 

 

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).
13

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. 

Geographic variability

 

4 Usually Biocycle runs their “State of Garbage in America” article annually, but there have been occasional gaps.
14

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)
15

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Alabama

Alaska

Arizona

Arkansas

California

Colorado

Connecticut

Delaware

District of Columbia

Florida

Georgia

Hawaii

Idaho

Illinois

Indiana

Iowa

Kansas

Kentucky

Louisiana

Maine

Maryland Massachusetts

Michigan

Minnesota

Mississippi

Missouri

Montana

Nebraska

Nevada

New Hampshire

New Jersey

New Mexico

New York

North Carolina

North Dakota

Ohio

Oklahoma

Oregon Pennsylvania Rhode Island

South Carolina

South Dakota

Tennessee

Texas

Utah

Vermont

Virginia Washington

West Virginia Wisconsin

Wyoming

Percent of state 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. 
16

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 
17

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.
18

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.
19

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Discarded municipal solid waste stream composition

(by % wet mass)

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). 
20

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)
21

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
22

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
23

Subpart C: 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. 
24

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 Notes Source

Btu/pound mmBtu/short ton

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

29

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

29

5,040 10.08 Heating value of MSW in 1989; 

based on estimates of 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 
25

combustors firing refuse-derived fuel and [...] 10,500 kilojoules per kilogram for combustors 

firing municipal solid waste that is not refuse-derived fuel”. These values correspond to MSW 

heat rates of 9.0 and 11.0 mmBtu/short ton respectively, consistent with the EPA (1996) values 

from AP-42, identified in 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

Max. rated input 

capacity (short 

tons/day)

Equivalent maximum rated heat input capacity (mmBtu/hour)

Low MSW heat input

(9 mmBtu/short ton)

Medium MSW heat input

(10 mmBtu/short ton)

High MSW heat input

(12 mmBtu/short ton)

250 94 104 122

600 225 250 300

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

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

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

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

The 250 short tons/day input capacity threshold is more stringent than the 250 mmBtu/short ton 

heat input capacity threshold, regardless of the MSW heating value. Using the medium MSW 

heat input value of 10 mmBtu/short ton, a threshold of 600 short tons of MSW per day is 

equivalent to the 250 mmBtu/hour threshold that applies to other stationary sources. MWCs that 

combust MSW with heating values higher than 10 mmBtu/short ton will have a higher equivalent 

maximum rated heat input capacity; MWCs that combust MSW with heating values lower than 

10 mmBtu/short ton will have a lower equivalent maximum rated heat input capacity.

Conclusion

Acknowledging the variability in MSW composition and heat content, a threshold of 600 short 

tons of MSW per day is consistent with the 250 mmBtu/hour threshold that applies to other 

stationary combustion units for Tier 4 reporting in 40 CFR § 98.33(b)(4)(ii).

References

EIA. (2007). Methodology for Allocating MSW to Renewable/Non-Renewable Energy. Energy

Information Administration (EIA). Retrieved from 

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

June 21, 2010.
26

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.
27

Subpart X (Petrochemical Production) and Y (Petroleum Refineries): Evaluation of 

Process Heaters Less than 30 MMBtu/hr Rated Heat Capacity

I. Purpose7

The purpose of this memorandum is to document the evaluation of process heaters that 

have a rated heat capacity of less than 30 million British thermal units per hour (MMBtu/hr). 

II. Summary of Findings

Small process heaters (those with rated heat capacity less than 30 MMBtu/hr) are 

generally not subject to Federal or consent decree emission limits and therefore are not typically 

required to monitor fuel gas usage at the individual process heater or boiler. These small process 

heaters are expected to contribute less than 5 percent of the stationary combustion source 

emissions. 

III. Background

The U. S. Environmental Protection Agency (EPA) finalized mandatory greenhouse gas 

(GHG) reporting requirements on October 30, 2009 (74 FR 56260), which requires petroleum 

refineries to use Tier 3 calculation and monitoring methods for stationary combustion sources 

that combust fuel gas. EPA received feedback from stakeholders seeking relief from the Tier 3 

monitoring requirements for small combustion sources. 

IV. Approach and Discussion of Results

Available information regarding existing monitoring requirements for small stationary

combustion sources at petroleum refineries was reviewed. Attachment 1 presents a summary of 

consent decree requirements. As shown in the Attachment 1, requirements for nitrogen oxide 

(NOX) from process heaters generally apply to process heaters greater than 40 MMBtu/hr. 

Similarly, review of NOX emission limits in 40 CFR 60 subpart Ja and in South Coast Air 

Quality Management District (AQMD) Rule 1109 indicate that these rules apply to process 

heaters greater than 40 MMBtu/hr. 40 CFR 60 subpart Dc specifically addresses sulfur dioxide 

(SO2) and particulate matter (PM) emissions from steam generating units from 10 to 100 

MMBtu/hr rated heat capacity. The PM emission standards, however, apply only to units that 

combust coal (alone or in combination with other fuels) in units with rated heat capacities of 30 

MMBtu/hr or greater. While the SO2 standards apply to smaller units, compliance with the SO2

standards is expected to be assessed from hydrogen sulfide (H2S) or total sulfur monitoring in the 

fuel gas mix drum rather than at the individual combustion unit. Thus, it appears likely that most 

process heaters less than 30 MMBtu rated input heat capacity are not typically required to 

monitor fuel gas usage at the individual process heater or boiler.

The distribution of process heaters were estimated based on facility-specific processing 

unit capacities (EIA, 2006) and fuel use factors used previously to project GHG emissions by 

petroleum refinery (Coburn, 2007). Based on these factors, the cumulative process heater 

 

7 Developed with support from Jeff Coburn, RTI International. 
28

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.
28

 Lion Oil Co. – El Dorado, AR 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install low-NOx burners or alternate 

technology

0.045 lb/MMBtu for 

atmospheric heater

(8-y

App

Heaters and boilers CO BACT analysis, install controls and comply 

with EPA-established limits

Ana

Con

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

refinery fuel gas

CEM

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

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

Date 

Chevron USA Products Co. – El Segundo, CA 

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Affected facility under subpart J; eliminate 

fuel oil burning

Date 

Chevron USA Products Co. – Richmond, CA 

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Affected facility under subpart J; eliminate 

fuel oil burning

Date 

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

Heaters and boilers SO2 Affected facilities under subpart J

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

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J 3/31

Heaters and boilers SO2 Comply with 40 C.F.R. §60.104(a)(1) Date 
29

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J Date 

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

Valero (formerly Ultramar Diamond Shamrock) – Wilmington, CA

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install NOx controls on at least 30% of the 

heater capacity greater than 40 MMBtu/hr

7/31

Heater H-27 Affected facility under subpart J 12/3

Heaters and boilers SO2, PM, 

CO

Affected facilities under subpart J Date 

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 

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 

insta

refin

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 

PAL
30

Valero Energy (formerly Ultramar Diamond Shamrock, formerly Total Petroleum) – Denver (Com

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

Citgo Petroleum – Savannah, GA 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers 

combusting refinery 

fuel gas

SO2 Affected facility under subpart J Date 

FCCU heater NOx Install controls (SCR, low-NOx burners, etc.) 

or shut down

0.040 lbs/MMBtu 12/3

Heaters and boilers SO2 Affected facility under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers 

that combust 

refinery fuel gas

SO2 Affected facility under subpart J Date 

Marathon Ashland Petrol. – Robinson, IL 

Unit Pollutant Requirement Emission Limit Dead

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

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 

the P

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 

the P

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

Unit Pollutant Requirement Emission Limit Dea

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

Heaters and boilers SOx and 

NOx

Discontinue burning of fuel oil 30 d

entry

Heaters and boilers Affected sources under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers 

(Distilling West)

SO2 Affected facilities under subpart J Date 
31

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers 

(except Distilling 

West)

SO2 Affected facilities under subpart J 6/30

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

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Eliminate fuel oil burning 6/01

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

12/3

National Cooperative Refinery Association – McPherson, KS 

Unit Pollutant Requirement Emission limit Dead

Boilers SB-016 and 

SB-018

NOx Comply with emission limit 101.9 tons/yr (12-month 

avg.) (both boilers 

combined)

Date 

Distillate 

hydrotreater feeder 

& platformer heater

H2S Comply with H2S concentration limit in fuel 

gas

5 gr/100 scf (365-day avg.) 30 d

entry

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

Unit Pollutant Requirement Emission Limit Dead

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

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 

the P

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 

the P

Citgo Petroleum Corp. – Lake Charles, LA 

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers 

that combust 

refinery fuel gas

SO2 Affected facility under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install NOx controls on at least 30% of the 

heater capacity greater than 40 MMBtu/hr

7/31

Heaters and boilers SO2, PM, 

CO

Affected facilities under subpart J Date 
32

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

Unit Pollutant Requirement Emission Limit Dead

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 

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 

insta

refin

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 

PAL

Marathon Ashland Petroleum LLC – Garyville, LA 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install controls on 30% of total heat input 

capacity of heaters and boilers with capacities 

greater than 40 MMBtu/hr

12/3

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 

the P

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

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 

the P

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 

the P

Valero (formerly Orion Refining Corp, formerly TransAmerican Refining Corp) – Norco (St. Char

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers 

(except 191-H-1)

SO2 Affected facilities under subpart J Date 

Heater 191-H-1 SO2 Affected facilities under subpart J 12/3

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3
33

Marathon Ashland Petrol. LLC – Detroit, MI 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install controls on 30% of total heat input 

capacity of heaters and boilers with capacities 

greater than 40 MMBtu/hr

12/3

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 

the P

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

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 

the P

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 

the P

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

Unit Pollutant Requirement Emission Limit Dead

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

12/3

Heaters and boilers Affected facilities under subpart J (few 

exceptions)

1/01

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install controls on 30% of total heat input 

capacity of heaters and boilers with capacities 

greater than 40 MMBtu/hr

12/3

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 

the P

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

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 

the P

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 

the P
34

Chevron USA Inc. – Pascagoula, MS 

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Affected facility under subpart J; eliminate 

fuel oil burning

Date 

Ergon Refining Inc. – Vicksburg, MS 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J Date 

Heaters and boilers SO2 Eliminate fuel oil burning except during 

natural gas curtailment

Date 

Cenex Harvest States – Laurel, MT

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Shut down or install NOx controls on at least 

30% of the heater capacity greater than 40 

MMBtu/hr

12/3

Heaters and boilers SO2 Minimize burning of fuel oil

Conoco Inc. – Billings, MT

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install NOx controls on at least 30% of the 

heater capacity greater than 40 MMBtu/hr

7/31

Heater H-16 Affected facility under subpart J 6/30

Heaters and boilers SO2, PM, 

CO

Affected facilities under subpart J Date 

Heaters and boilers SO2 Comply with emission limit when fuel oil is 

burned

300 tons/year (365-day 

avg.)

Date 

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 

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 

insta

refin

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 

PAL
35

Montana Refining Co. – Great Falls, MT 

Unit Pollutant Requirement Emission Limit Dead

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 

cons

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

exceptions)

Date 

Citgo Asphalt Refining Co. – Paulsboro, NJ 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers 

combusting refinery 

fuel gas

SO2 Affected facility under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install controls and accept federallyenforceable emission limits0.040 lb/MMBtu 3 ye

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

Heaters and boilers SO2 Eliminate fuel oil burning except during 

natural gas curtailment

Date 

Boilers 5, 6, 7, and 8 PM-10 Comply with emission limit 0.000427 lbs/MMBtu (1-hr 

avg.) 

Date 

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

Unit Pollutant Requirement Emission Limit De

Heaters and boilers 

(except selected)

SO2 Affected facilities under subpart J Da

Selected heaters and 

boilers

SO2 Affected facilities under subpart J 6/3

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

Unit Pollutant Requirement Emission Limit De

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/

Heaters and boilers SO2 Affected facilities under subpart J 12/
36

Navajo Refining Co. – Artesia, NM 

Unit Pollutant Requirement Emission Limit Deadlin

Heaters and boilers NOx Install next generation ultra low NOx 

burners for all controlled heaters and boilers 

except Boilers B-7 and B-8

12/31/0

Heaters and boilers SO2 Affected facilities under subpart J Date of 

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

exceptions)

Date of 

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

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Eliminate fuel oil burning 3/31

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

9/30

Heaters and boilers H2S Volume-weighted, rolling 3-hour average 

concentration of H2S in refinery fuel gas

0.10 gr/dscf 12/3

BP Oil Co. – Toledo, OH 

Unit Pollutant Requirement Emission Limit Dead

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/

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

9/30/

Heaters and boilers H2S Volume-weighted, rolling 3-hour average 

concentration of H2S in refinery fuel gas

0.10 gr/dscf 12/31

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install controls on 30% of total heat input 

capacity of heaters and boilers with capacities 

greater than 40 MMBtu/hr

12/3

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 

the P

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

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 

the P

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 

the P
37

Sunoco, Inc. – Toledo, OH

Unit Pollutant Requirement Emission Limit Dead

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 ye

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

provided)

Date 

Conoco Inc. – Ponca City, OK

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install NOx controls on at least 30% of the 

heater capacity greater than 40 MMBtu/hr

7/31

Heaters and boilers SO2, PM, 

CO

Affected facilities under subpart J Date 

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 

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 

insta

refin

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 

PAL

Sunoco, Inc. – Tulsa, OK

Unit Pollutant Requirement Emission Limit Dead

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 ye

Heaters and boilers SO2 Affected facilities under subpart J Date 

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

provided)

Date 

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

Unit Pollutant Requirement Emission Limit Dea

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

Sunoco, Inc. – Marcus Hook, PA

Unit Pollutant Requirement Emission Limit Dead

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
38

Sunoco, Inc. – Marcus Hook, PA

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J Date 

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

provided)

Date 

for a 

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

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

provided)

Date 

for a 

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J 6/30

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

Unit Pollutant Requirement Emission Limit Dead

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/

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

Date 

Citgo – Corpus Christi, TX 

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers 

that combust 

refinery fuel gas

SO2 Affected facility under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Deadlin

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

12/31/0
39

Marathon Ashland Petrol. LLC – Texas City, TX 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install controls on 30% of total heat input 

capacity of heaters and boilers with capacities 

greater than 40 MMBtu/hr

12/3

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 

the P

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

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 

the P

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 

the P

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J 6/30

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

Valero Refining Co. – Corpus Christi, TX

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers 

(East)

SO2 Affected facilities under subpart J 12/3

Heaters and boilers 

(West)

SO2 Affected facilities under subpart J 12/3
40

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Discontinue burning or combustion of fuel oil 

(during NG curtailment, may burn low sulfur 

fuel oil)

12/3

Heaters and boilers SO2 Affected facilities under subpart J 12/3

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

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Eliminate fuel oil burning 6/01

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

Date 

Chevron USA – Salt Lake City, UT 

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Affected facility under subpart J; eliminate 

fuel oil burning except during natural gas 

curtailment, test runs, or training

Date 

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

Unit Pollutant Requirement Emission Limit Dead

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

Heaters and boilers SO2 Eliminate fuel oil burning 6/01

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

Date 

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

Unit Pollutant Requirement Emission Limit Dead

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
41

Heaters and boilers Subject to subparts A & J as those subparts 

apply to fuel gas combustion devices

9/30

Heaters and boilers H2S Volume-weighted, rolling 3-hour average 

concentration of H2S in refinery fuel gas

0.10 gr/dscf 12/3

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

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Affected facilities under subpart J Date 

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

Unit Pollutant Requirement Emission Limit Dead

Boiler A NOx Install next generation ultra low-NOx burner EPA to determine emission 

limit

Insta

Boiler B NOx Install next generation ultra low-NOx burner EPA to determine emission 

limit

Insta

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

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

Heaters and boilers SO2 Affected facilities under subpart J 12/3

Heaters and boilers SO2 Eliminate fuel oil burning except during 

natural gas curtailment

Date 

Murphy Oil USA Inc. – Superior, WI

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers SO2 Reduce burning of fuel oil 33.3 tons/month (12-month

avg.)

5/01

Navajo Refining Co. – Lovington, NM 

Unit Pollutant Requirement Emission Limit Dead

Heaters and boilers NOx Install next generation ultra low NOx burners 

for all controlled heaters and boilers except 

Boilers B-7 and B-8

12/3

Heaters and boilers SO2 Affected facilities under subpart J Date 

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

exceptions)

Date