# 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

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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 25 0 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 Hea t Capacity ................................ ............ 27

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Subpart A : Background on Accuracy and Calibration Requirements 1 

### Background: The current rule provides, with limited exceptions, that “flow meters and other devices (e.g., belt scales) that measure data us ed 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:

 

### Fue l Mass Flow Meter s;  

### Fuel Volumetric Flow Meter s;  

### Weighing S ys tems;  

### Tank Level Sensor ;  

### Acid Concentration Monitor ; and  

### Methane Anal yz er. EPA has received a number of comments on what the 5% accuracy requirement reall y means, which measurement devices it s hould 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 propo sal. Accuracy Requirements in Other Reporting P rograms 1. Acid Rain Program and NO X 

### Budget Program

 

### Requirements for Continuous Emissions Monitoring are described in 40 CFR Part 75. The performance specifications for fuel flow meters under Part 75, Ap pendix 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 f ull scale (initial calibration and periodic QA).

 QA test required annually .  

### In formation 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 accurac y 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.

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2. California M andatory GHG R eporting Program

 

### Section 95103(a)(9) of Subarticle 1 General Requirements for the Mandat ory 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 r etain record of such calibrations

. ” 

### (http://www.arb.ca.gov/cc/reporting/ghg - rep/ghg rep.htm)

 

### California originally

proposed an accuracy

requirement of ± 2.5 percent. The Final Statement of Reasons for Rulemaking responded to public comments regarding the accuracy

requirement. Commenters stated that the ± 2.5 percent uncertainty requirement is too stringent and is not achievable with most of the existing flow measurement devices used in the petroleum industry .  

### California also recognized there could be measurement difficulties for some facilities and fuel types, including solid fuels. The response to comments document concluded that, “ Because it is impractical to write into the regulatio n 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 R ulemaking 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 typ ically 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 ty pically accuracies for various ty pes 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 b y vendor.

 Mass flow meter

– 0.2 pe rcent 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 b y 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 be low.

 

### 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 probabl y not in practice among all industries.

 

### Different standards for accuracy also appl y depending on whether the material is being weighed and used within a plant for proces s 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

asso ciated with those industries and variables that are of most critical interest in the GHG emission calculations.

 

### In commerce, weighing devices are likel y to conform to NI ST Handbook 44, if a device is used. Penns yl vania, for example, specifies that weighi ng devices used in commerce must comply with NIST Handbook 44 (see, for example, Pa. Code Title 70, Weights, Measures And Standards; Cha pter 10. Device Ty

pe Approval; http://www .pacode.com/secure/data/070/chapter10/chap10toc.html ). Enforcement, inspection, and certification (“sealing”) is done at the county level.

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Appendix A

– Supporting Tables

TABLE A - 1. SUMMARY OF FUEL FLOWMETER ACCURACY TEST BETWEEN 2005 & 2009
ACCURA CY TEST METHOD CODE DESCRIPTION TEST ME THOD CODE TOTAL

TEST AVG LOW

LEVEL ACCURACY (PERCENT) AVG MID

LEVEL ACCURACY (PERCENT) AVG HI

ACCURACY (PERCENT) 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 Appendi x 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 LEV EL ACCURACY MID LEVEL ACCURACY HIGH LEVEL ACCURACY 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 702Table A - 3. Load Cell Performance Co mparison

Type Weight Range Accuracy (Full Scale) Applications Strengths Weaknesses Mechanical Load Cells Hydraulic Load Cells Up to 10,000,000

lb 0.2 5% Tanks, bins and hoppers. Takes high

im pacts, Expensive,

complex. Hazardous areas. insensitive to

tem perature. 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, Lo w cost,

simple construction Strain gages are

exposed, require protection Shear Beam Load Cells 10 - 5 ,000 lbs. 0.03% Tanks, platform scales, off

center loads High side load

rejection, better sealing and protection Canister Load Cells to 500 ,000 lbs. 0.05% Truck, tank, track, and hopper scales Handles load

mo vements No horizontal

load protection Ring and Pancake Load Cells 5 - 500 ,000 lbs. Tanks, bins , scales All stainless

steel No load

mo vement allowed Button and wa sher Load Cells 0 - 50 ,000 lbs 1% Small scales Small, inexpensive Loads must be

centered, no load mo vement permitted 0 - 200 lbs. typ. Other Load Cells Helical 0 - 40 ,000 lbs. 0.20% Plat form, 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 Measurem ent Devices and Device Accuracy Vendor Accuracy M ass Flow Meter s 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% o f 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% Co ncentration Monitors (for l iquid 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: CH 4 : ±0.5

– 3.0 CO 2 : ±0.5

– 3.0 O 2 : ±1.0 Enviro - Equipment, Inc. CES LANDTEC GEM - 2000 CH 4 : Range 0 - 100% Resolution 0.1% CO 2 : Range 0 - 60% Resolution 0.1% O 2 : Range 0 - 25% Resolution 0.1% Flow A ccura cy

±3% 50 - 150 SCFM Load Cells Vendor Equipment Type Accuracy (full scale) Honeywell Com

pression 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% Com pression 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 Measurem ent 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; w

hichever is higher (in motion) Floor Scales 0.05% Com pression Load Cells 0.05% Kistler - Morse Com pression Load Cells 0.08% Rice Lake Weighing Sy st ems Belt Scales 0.25%

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Subpart A: Background Research on Definitions EPA is p roposing 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 b yproducts, p rimary fuel, s olid by

products, w aste oil, and w ood 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 by products” would include the parts of crops that are not ordinarily

used for food (e.g., corn straw, peanut shells, pomace, etc.). “Solid by products” 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 fu el” 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 phy sical 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 ty

pes. 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 Prim ary Fuel: http://edocket.access.gpo.gov/cfr_2008/julqtr/pdf/40cfr72.2.pdf Waste Oil: http://www.epa.g ov/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

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Subpart C: Heterogeneity and Variability of Municipal Solid Waste in Relation to Municipal Waste Combustor Emissions 2 

### Background and Summary MSW is a fuel for MWCs, which are a category of stationary

combustion source s 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 ph ys ic ally measure their carbon dioxide emissions. These include:
 Tier 2: Mass Balance Calculations. This method estimates the annual mass of CO 2 

### emissions for MWCs by

multiplying the mass of steam generated b y MSW combustion, by the efficiency

of steam generation and by a default CO 2 

### emission factor for MSW.

 Tier 4: Continuous Emissions Monitoring. This method requires hourly measurements of CO 2 

### concentration and stack gas volumetric flow rate to calculate the mass of CO 2 

### emissions. Carbon dioxide (CO 2 

### ) emiss ions 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, MW Cs with a maximum rated heat capacity greater than 250 tons per day are required to appl y the Tier 4 method and use continuous emissions monitoring s ys tems to directl y 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 th e requirement for the Tier 4 monito ring 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 the se factors contribute to variability in CO 2 

### emissions through the carbon content and ratio of fossil carbon to biogenic carbon 3 

### in MSW, and the range of possible variation of composition .

2 Devel oped 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 I PCC 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 condi tions, wo uld cycle back to the atmosphere as CO 2 due to degradation processes. As a result, CO 2 emissions from biogenic materials from sustainably - grown biomass are not included in inventories of human - caused greenhouse gas emissions. The fossil fraction o f MSW includes materials that are derived from fossil fuels that have been sequestered under the earth. When fossil - based

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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 princip al components and average national composition of MSW in 2008 are shown in Table 1 , as estimated b y EPA (2009) in Municipal Solid W aste Generation, Recycling, and Disposal in the United States Detailed Ta bles and Figures for 2008 . Table 1 : Princip a l components of MSW and am ount 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% Meta ls 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 m aterials primarily consist of plastics , sy

nthetic 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 typ es 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 sit e - specific variation in the CO 2 

### emissions from MWCs and the ratio of fossil to biogenic CO 2 

### in MSW burned in MWCs. Consequently , CO 2 

### emissions from MWCs are much harder to characterize accuratel y using mass balance or other calculation methods than are CO 2 

### 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 generall y have a relatively homogeneous fuel source with relativel y 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, an d/or institutional waste. Household waste includes material discarded b y single and multiple materials are extracted from the earth and converted into CO 2 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).

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residential dwellings, hotels, motels, and other similar permanent or temporary housing establishments or facilities. Commercial/retail waste includes material di scarded b y stores, offices, restaurants, warehouses, non - manufacturing activities at industrial facilities, and other similar establishments or facilities. Institutional waste includes material discarded b y s chools, nonmedical waste discarded by hospitals, material discarded by non - manufacturing activities at prisons and government facilities, and material discarded b y 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 f luff). 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 frequently4 

### on the challenges of characterizing the generation and composition of MSW. Inconsistencies in state level data led Biocycle to revise its methodology for estimating the generation and composition of MSW (Biocycle 2004), but problems persist in compil ing 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 typical ly not considered part of the MSW stream, such as construction and demolition materials, auto mobile 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 b y all states, and some states are not able to distinguish non - MSW waste exports from MSW exports. Challenges in accuratel y and consistently defining the wastes that constitute MSW can lead to mischarac terization 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. Consequentl y, CO 2 

### emissions from wastes considered MSW that are combusted in MWCs, but which fall outside of EPA’s definition of MSW, can lead to different CO 2 

### 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.

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The compositio n 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. Ty pically , rural areas will generate less of these products on a per person basis tha n 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, an d food scraps from restaurants.
 “Variations in economic activity , which affect waste generation in both the residential and the commercial sectors.
 “L ocal 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 projects 5



### . Twenty states do not have an y 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 M SW processed in waste - to - energy projects (EPA 2008, p. 151). The remaining 10% is largel y 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)

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0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%AlabamaAlaskaArizonaArkansasCaliforniaColoradoConnecticutDelawareDistrict of ColumbiaFloridaGeorgiaHawaiiIdahoIllinoisIndianaIowaKansasKentuckyLouisianaMaineMarylandMassachusettsMichiganMinnesotaMississippiMissouriMontanaNebraskaNevadaNew HampshireNew JerseyNew MexicoNew YorkNorth CarolinaNorth DakotaOhioOklahomaOregonPennsylvaniaRhode IslandSouth CarolinaSouth DakotaTennesseeTexasUtahVermontVirginiaWashingtonWest VirginiaWisconsinWyomingPercent of state MSW generation Landfille d Recy cl ed Wa ste - to - ener gy

Figure 1 : Share of waste m anagem ent methods employed by U.S. states, as a percentage of tota l 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 ty

pes of goods such as yard trimmings, white goods, and ele ctronics are more variable. S tate - 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 m aterials (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 s ys tems is variable on a mun icipal/county

level as well as b y state , as shown by Figure 3 . The rates depend upon a number of technical and non - technical factors, including the type of recycling s ys tem (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., recov ery 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 o ther materials will influence the carbon content and ratio of fossil - to - biogenic components of MSW sent to MWCs for combustion, and, consequently , the resulting CO 2 

### 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 b y nearl y 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 CO 2 

### emissions. Seasonal variability The composition of MSW varies seasonall y, according to variations in climate as w ell as economic and demographic waste generation factors each ye ar (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:
 In creased 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 wrapp ing 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 generall y not feasible to store MSW for more than a few day s prior to combustion (due to odor and hygiene concerns). Consequently , the underlyingseasonal variation in MSW that fuels MWCs will translate to seasonal variation in CO 2 

### emissions as well.

### 18 0 5 10 15 20 25

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Recycling rateNumber 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 rateNumber of municipalities

(b) Massachusetts

0 10 20 30 40 50 60

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Recycling rateNumber of municipalities

(c) New Ham psh ire 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) Gl ass Residues Metal Durablegoods Plastics Pape r 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 CO 2 emissions when combusted, while plastics result in fossil CO 2 emissions. Glass and metal fractions are not combustible and do not result in CO 2 emissions. Durables include appliances/electronics, carpets, and other miscellaneous/bulky items, and residues include other unspecified waste fractions; these categories m ay also contain materials that generate fossil or biogenic CO 2 emissions in MWCs. 

### Long -term compositional trends Long - term changes in MSW composition also contribute to variability in the MSW stream. Over time, the ty

pes of materials entering the MSW str eam are chang ing 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 CO 2 

### emissions from MSW combustion. Chang es 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 CO 2 

### emissions.

Table 3 : MSW heat content and biogen ic/fossil shares from1989 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

– containin g 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 require s 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). Th e 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 - Cy cle 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 St ates: 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 S tates: 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 In formation 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 Greenh ouse 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 Man datory

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 o f MSW Per Day And 250 MMBtu/hr Heat Input Capacity Background and Summary 6 

### MSW is a fue l for MWCs, which are a category of stationary

combustion source s covered under Subpart C of EPA’s Mandatory Greenhouse Gas Reporting R ule. 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 phy sicall y 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 Metho dology 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

comb ustion 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 evalu ated to determine maximum rated input capacity. Heating value of MSW Combusted in MW Cs 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 estim ates 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 v alue of MSW in 1989; based on estimates of material specific heating values and U.S. MSW composition taken from EPA (2006) Facts and Figures: 2005. EIA (2007), Table 1, p. 6 5,865 11.73 Heating value of MSW in 2005; based on estimates of material specific heating values and U.S. MSW composition taken from EPA (2006) Facts and Figures: 2005. EIA (2007), Table 1, p. 6 

### Number of Hours Per Day Over Which MWC Operation is Evaluated to Determine Maximum Rated Input Capacity Second, according to 40 CFR § 60.58 b(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:
 Fo r 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 uni t 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 s hall 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 b y 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 Note s : 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 othe r 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 In formation 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 IChapter 2: Solid Waste Disposal, Section 2.1: Refuse Combustion, p. 2.1 - 2 9. 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 Heate rs Less than 30 MMBtu/hr Rated Heat Capacity I. Purpose 7 

### 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). I I . Summary of F indings Small process heaters (those with rated heat capacity less than 30 MMBtu/hr) are generall y not subject to Federal or consent decree emission limits and therefore are not typicall y 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. I II . 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 Tie r 3 monitoring requirements for small combustion sources. I V . 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 (NO X

### ) from process heaters generall y appl y to process heaters greater than 40 MMBtu/hr. Similarly , review of NO X 

### emission limits in 40 CFR 6 0 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 specificall y addresses sulfur dioxide (SO2) and particulate matter (PM) emis sions 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 great er. While the SO 2 

### standards apply to smaller units, compliance with the SO 2 

### standards is expected to be assessed from hydrogen sulfide (H 2 

### S) or total sulfur monitoring in the fuel gas mix drum rather than at the individual combustion unit. Thus, it appea rs likel y 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- specif ic processing unit capacities (EIA, 2006) and fuel use factors used previousl y 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 257,83 1 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 capaci ties 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 multipl e 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 245,9 96 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 proc ess 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 perc ent of the nationwide fuel use. V . References Coburn J. 2007. Greenhouse Gas Industry Profile for the Petroleum Refining Industry . Prepared for U.S. Environmental Protection Agency , Washington, DC. Contract No. GS - 10F 0283K. June 11. EIA (Energy

Informat ion Administration). 2006. Refinery Capacity Report 2006. Prepared b y the Energy

Information Administration, Washington, DC. June 15.

### 28

Lion Oil Co. – El Dorado, AR Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NO x Install low -NOx burners or alternate technology 0.045 lb/MMBtu for atmospheric heater (8 - year program Appendix C) Heaters and boilers CO BACT analysis, install controls and comply with EPA - established limits Analysis Controls 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 o n 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 6/30/1 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 b urners, shut down, etc.) must represent 30% of the total heat input capacity of H/B greater than 40 MMBtu/hr 0.040 lbs/MMBtu 6/30/11 Heaters and boilers SO2 Affected facility under subpart J; eliminate fuel oil burning Date of entry 

### ConocoPhillips (f

ormerly Tosco, formerly Un ocal 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 Unoca l 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

### 29

ConocoPhillips (fo rmerly 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 Ma ria (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 sulf ur 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 burnin g or combustion of fuel oil (during NG curtailment, may burn low sulfur fuel oil) 12/31/05 Heaters and boilers SO2 Affected facilities under subpart J 12/31/07 

### Valero ( formerly Exxon Co. USA) – Benicia, CA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Discontinue burning or combustion of fuel oil (during NG curtailment, may burn low sulfur fuel oil) 12/31/05 Heaters and boilers SO2 Affected facilities under subpart J 12/31/07 

### Suncor Energy (formerly Conoco In c.) – 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.) D ate 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 o 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

### 30

Valero E nergy (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 l ow sulfur fuel oil) 12/31/05 Heaters and boilers SO2 Affected facilities under subpart J 12/31/07 

### Citgo Petroleum – Savannah, GA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers combusting refinery fuel gas SO2 Affected faci lity 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 emis sion 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 o f fuel oil 30 days after Date of entry Heaters and boilers Affected sources under subpart J Date of entry 

### ConocoPhillips (formerly Tosco Refining, Equilon, Wood River, & Shell Oil) – Wood River (Roxana), IL Unit Pollutant Requirement Emission Limi t Deadline Heaters and boilers (Distilling West) SO2 Affected facilities under subpart J Date of lodging

### 31

ConocoPhillips (formerly Tosco Refining, Equilon, Wood River, & Shell Oil) – Wood River (Roxana), IL Unit Pollutant Requirement Emission Limi t Deadline 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 6/01/0 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 e ntry 

### 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 Compl y with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.010 lb/MMBtu (24 -hr avg.), 0.005 lb/MMBtu (365 - day avg.) Date of application for the PAL Heaters and boilers that burn fuel gas only SO2 Comply with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.040 lb SO2/MMBtu or 125 ppmvd H2S in fuel gas (365 - day avg.) Date of application for the PAL 

### Citgo Petroleum Corp. – Lake Charles, LA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install controls on 30% of total heat input capacity of heaters and boilers with capacities greater than 40 MMBtu/hr 6/30/11 Heaters and boilers that combust refinery fuel gas SO2 Affected facility under subpart J Date of entry 

### ConocoPhillips (former ly 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 Affec ted facilities under subpart J Date of lodging

### 32

ConocoPhillips (former ly Conoco Inc.) – Westlake (Lake Charles), LA 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 boi lers 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 Pl antwide 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 Compl y with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.010 lb/MMBtu (24 -hr avg.), 0.005 lb/MMBtu (365 - day avg.) Date of application for the PAL Heaters and boilers that burn fuel gas only SO2 Comply with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.040 lb SO2/MMBtu or 125 ppmvd H2S in fuel gas (365 - day avg.) Date of application for the PAL 

### Valero (formerly Orion Refining Corp, formerly TransAmerican Refining Corp) – Norco (St. Charles Parish), LA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Discontinue burning or combustion of fuel oil (during NG curtailment, may burn low sulfur fuel oil) 12/31/05 Heaters and boilers SO2 Affected facilities under subpart J 12/31/07 

### ConocoPhillips (formerly, Tosco Refining Co., formerly BP Oil Co.) – Belle Chasse (Alliance), LA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers (except 191 - H - 1) SO2 Affected facilities under subpart J Date of lodging Heater 191 - H - 1 SO2 Affected facilities under subpart J 12/31/06 

### Valero (formerly Basis Petroleum, Inc.) – Krotz Springs, LA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Discontinue burning or combustion of fuel oil (duri ng NG curtailment, may burn low sulfur fuel oil) 12/31/05 Heaters and boilers SO2 Affected facilities under subpart J 12/31/07

### 33

Marathon Ashland Petrol. LLC – Detroit, MI Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install controls on 30% of total heat input capacity of heaters and boilers with capacities greater than 40 MMBtu/hr 12/31/08 Heaters and boilers CO Comply with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.060 lb/MMBtu (24 -hr avg. ), 0.040 lb/MMBtu (365 - day avg.) Date of application for the PAL Heaters and boilers SO2, PM Affected facilities under subpart J Date of entry (8/30/01) Heaters and boilers PM Comply with emission limit if a Plantwide Applicability Limit (PAL) is adopt ed 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 H2 S 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 emiss ion 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 limi t 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

### 34

Chevron USA Inc. – Pa scagoula, MS Unit Pollutant Requirement Emission Limit Deadline Heaters and boi lers NOx Controlled H/B (SCR, low -NOx burners, shut down, etc.) must represent 30% of the total heat input capacity of H/B greater than 40 MMBtu/hr 0.040 lbs/MMBtu 6/30/11 Heaters and boilers SO2 Affected facility under subpart J; eliminate fuel oil burning Date of entry 

### Ergon Refining Inc. – Vicksburg, MS Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Affected facilities under subpart J Date of lodging Heaters and boilers SO2 Eliminate fuel oil burning except during natural gas curtailment Date of lodging 

### Cenex Harvest States – Laurel, MT Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Shut down or install NOx controls on at least 30% of the heater capacity greater than 40 MMBtu/hr 12/31/11 Heaters and boilers SO2 Minimize burning of fuel oil 

### Conoco Inc. – Billings, MT Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install NOx controls on at least 30% of the heater capacity greater than 40 MMBtu/hr 7/31/09 Heater H - 16 Affected facility under subpart J 6/30/03 Heaters and boilers SO2, PM,

CO Affected facilities under subpart J Date of lodging Heaters and boilers SO2 Comply with emission limit when fuel oil is burned 300 tons/year (365 - day avg.) Date of lodging Heaters and boilers PM Comply with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.005 lb/MMBtu (365 - day avg.); 0.010 lb/MMBtu (24 - hr avg.) Date refinery applies for PAL Heaters and boilers CO Comply with emissi on 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

### 35

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 Affe cted 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 boil ers combusting refinery fuel gas SO2 Affected facility under subpart J Date of entry


### Sunoco (formerly Coastal Eagle Point Oil Co.) – Westville, NJ Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install controls and accept federally enforceable emission limits 0.040 lb/MMBtu 3 years Heaters and boilers SO2, PM Affected facilities under subpart J Date of lodging Heaters and boilers SO2 Eliminate fuel oil burning except during natural gas curtailment Date of lodging B oilers 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 b oilers (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 Emis sion 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

### 36

Navajo Refining Co. – Ar tesia, NM Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install next generation ultra low NOx burners for all controlled heaters and boilers except Boilers B - 7 and B - 8 12/31/05 and 12/31/09 Heaters and boilers SO2 Affected facilities under subpart J Date of lodging Heaters and boilers SO2 Eliminate burning of fuel oil (with a few exceptions) Date of lodging 

### Tesoro (formerly BP, formerly Amoco Oil Co.) – Mandan, ND Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install controls on 30% of total heat input capacity of heaters and boilers with capacities greater than 40 MMBtu/hr 1/18/05 Heaters and boilers SO2 Eliminate fuel oil burning 3/31/01 Heaters and boilers Subject to subparts A & J as those subparts apply to fuel gas combustion devices 9/30/03 Heaters and boilers H2S Volume -weighted, rolling 3 -hour average concentration of H2S in refinery fuel gas 0.10 gr/dscf 12/31/01 until 9/30/03



### BP Oil Co. – Toledo, OH Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install controls on 30% of total heat input capacity of heaters and boilers with capacities greater than 40 MMBtu/hr 1/18/05 Heaters and boilers Subject to subparts A & J as those subparts apply to fuel gas combustion devices 9/30/03 Heaters and boilers H2S Volume -weighted, rolling 3 -hour average concentration of H2S in refinery fuel gas 0.10 gr/dscf 12/31/01 until 9/30/03 

### Marathon Ashland Petroleum LLC (formerly Ashland, Inc.) – Canto n, 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 boil ers 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

### 37

Sunoco, Inc. – Toledo, OH Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Ins tall 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 4 0 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 i nstallation or Date refinery applies for PAL Heaters and boilers SO2 Comply with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.040 lb SO2/MMBtu (365 - day avg.) OR 125 ppmvd H2S in fuel gas (365 - day avg.) Date refinery applies for PAL 

### Sunoco, Inc. – Tulsa, OK Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install NOx controls on at least 30% of the heater capacity (all of the capacity greater than 40 MMBtu/hr if less than 30% of total) 8 years after 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 Petrol eum 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

### 38

Sunoco, Inc. – Marcus Hook, PA Unit Pollutant Requirement Emission Limit Deadline 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) – P hiladelphia (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/ Heaters and boilers SO2 Affected facilities under subpart J 12/31/10 Heaters and boilers SO2 Eliminate fuel oil burning (a few exceptions provided) Date of entry (later dates for a few) 

### ConocoPhillips (formerly Tosco Refining Co., formerly BP) – Trainer (Marcus Hook), PA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Affected facilities under subpart J 6/30/08 

### BP (formerly Amoco Oil Co.) – Texas City, TX Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Install controls on 30% of total heat input capacity of heaters and boilers with capacities greater than 40 MMBtu/hr 1/18/05 Heaters and boilers Subject to subparts A & J as those subparts apply to fuel gas combustion devices Date of entry 

### Citgo – Corpus Christi, TX Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers (East and West) NOx Install controls on 30% of total heat input capacity of heaters and boilers with capacities greater than 40 MMBtu/hr 6 /30/11 Heaters and boilers that combust refinery fuel gas SO2 Affected facility under subpart J Date of entry 

### Flint Hills Resources (formerly Koch Petroleum Group, includes SWest Refining) – Corpus Christi, TX Unit Pollutant Requirement Emissio n 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

### 39

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 Li mit (PAL) is adopted 0.060 lb/MMBtu (24 -hr avg.), 0.040 lb/MMBtu (365 - day avg.) Date of application for the PAL Heaters and boilers SO2, PM Affected facilities under subpart J Date of entry (8/30/01) Heaters and boilers PM Comply with emission limit if a Plantwide Applicability Limit (PAL) is adopted 0.010 lb/MMBtu (24 -hr avg.), 0.005 lb/MMBtu (365 - day avg.) Date of application for the PAL Heaters and boilers that burn fuel gas only SO2 Comply with emission limit if a Plantwide Applicability Limit (PAL ) is adopted 0.040 lb SO2/MMBtu or 125 ppmvd H2S in fuel gas (365 - day avg.) Date of application for the PAL 

### ConocoPhillips (formerly Phillips Petroleum Co.) – Borger, TX Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Affe cted 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 (former ly 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 o il (during NG curtailment, may burn low sulfur fuel oil) 12/31/05 Heaters and boilers SO2 Affected facilities under subpart J 12/31/10 

### Valero Refining Co. – Corpus Christi, TX Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Discontinue burning or combustion of fuel oil (during NG curtailment, may burn low sulfur fuel oil) 12/31/05 Heaters and boilers (East) SO2 Affected facilities under subpart J 12/31/10 Heaters and boilers (West) SO2 Affected facilities under subpar t J 12/31/07

### 40

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/ 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 oi l (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 Deadl 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 subpart s A & J as those subparts apply to fuel gas combustion devices Date of entry 

### Chevron USA – Salt Lake Ci ty, UT Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers NOx Controlled H/B (SCR, low -NOx burners, shut down, etc.) must repr esent 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 

### 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

### 41

Heaters and boilers S ubject 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 (form erly Tosco Refining Co.) – Ferndale, WA Unit Pollutant Requirement Emission Limit Deadline Heaters and boilers SO2 Affected facilities under subpart J Date of lodging 

### Ergon - West Virginia inc. (formerly Quaker State Oil Refining Corp.) – Newell, WV Unit Pollutant Requirement Emission Limit Deadline Boiler A NOx Install next generation ultra low -NOx burner EPA to determine emission limit Install Boiler B NOx Install next generation ultra low -NOx burner EPA to determine emission limit Inst all 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 boiler s 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 a 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