_ P.I -

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

) ll-B-15 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 21 of 132 
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• 

P.2 

TO: 

FROM: 

DATE: 

MEMORANDUM 

Air Docket A-98-13 

Organic Liquids Distribution MACT Rule 

ESD Project No. 96/05 

Bernd Haneke and Greg LaFlam, PES, Inc. 

December 1, 1999 

SUBJECT: Estimation of the Population of Refineries that Conduct 

Organic Liquids Distribution (OLD) Operations 

Purpose 

During the October 5,1999 EPA OLD Stakeholders meeting, the EPA indicated that its 

1998 OLD survey had captured approximately 30 percent of all petroleum refineries that 

potentially have OLD-type operations. Representatives ofthe American Petroleum Institute 

(API) commented that they believed that 100 percent of such refineries were captured in the 

survey, and therefore the EPA may be overstating the baseline emissions and potential control 

costs for refineries that belong to the OLD operations source category. Based on API's 

comment, we have reanalyzed the OLD data base to determine the number of refineries likely to 

conduct OLD-type operations as defined for the OLD category. 

Methodology 

To develop a ratio that describes how many refineries conduct OLD-type operations, we 

analyzed both the OLD data base and the negative declarations received from facilities. A 

negative declaration is a letter from a facility declaring that it does not conduct the defined OLDtype operations, or that its annual emissions do not meet the survey thresholds (5 tpy of one HAP 

or 12.5 tpy for all HAP actual emissions for the base year 1997). 

The ratio was calculated by dividing the number of refineries that reported OLD-type 

operations by the total number of refineries that responded to the survey. Based upon the 

"Organic Liquids Distribution Industry Profile, Revised Draft", as of 1996 there were 173 

operable refineries in the nation. This number was multiplied by the ratio/percentage to 

determine the total number of refineries in the U.S. that conduct OLD-type operations. 

Results 

The attached table summarizes all ofthe refineries that submitted information to the EPA 

for the OLD survey. Refineries submitted a variety of information. Some refineries submitted 

/ 
P.3 

Memo on Refineries with OLD 

December 1,1999 

Page 2 

only information on organic liquids, while others submitted infonnation on storage tanks and 

transfer racks that are expected to be regulated by the OLD MACT. Some refineries submitted 

surveys listing only organic liquids that will not be regulated by the OLD MACT; consequently, 

they were counted as not having OLD-type operations. 

A total of 58 refineries submitted either: (a) completed OLD surveys, or (b) letters stating 

that they do not conduct any OLD-type operations. Of these 58 responses, 21 facilities (36 

percent) report that they do not conduct any OLD-type operations. Therefore, approximately 64 

percent (100-36) ofthe refineries that responded to the survey may conduct some type of organic 

liquids distribution activity which will be regulated by the OLD MACT. This ratio/percentage 

was used to determine, how many refineries in the nation potentially conduct OLD-type 

operations. Multiplying the total number of refineries (173) in the nation by 64 percent indicates 

that there are approximately 111 refineries that conduct OLD-type operations. 

As the EPA received completed surveys from 37 refineries, a calculation based on the 

total number of refineries nationwide conducting some sort of OLD-type operations results in a 

coverage of 33 percent (37/111 x 100 = 33). This indicates that 67 percent ofthe refineries 

conducting OLD-type operations were not surveyed or did not respond to the survey. 

Conclusions 

In calculating baseline emissions and control costs for the OLD industry, the EPA had 

estimated that about 70 percent ofthe refineries conducting OLD-type operations were not 

surveyed. This reanalysis indicates that a more accurate number may be 66 percent. Thus, the 

EPA may have overestimated the OLD emissions and costs for the refinery segment ofthe OLD 

industry by about 10 percent [(l-0.67)/(l-0.7) -1 = 10 percent]. This analysis also indicates that 

since the survey did not capture all ofthe refineries with OLD-type operations, a revised 

extrapolation ofthe surveyed refineries will be necessary to accurately estimate nationwide 

baseline emissions and control costs. 

7. 
P.4 

Memo on Refineries with OLD 

December 1,1999 

Page 3 

Refineries that Responded to the O.L.D. Survey 

Legal Owner 

Atlantic Richfield Corporation 

BP Exploration and Oil Company 

BP Exploration and Oil Company 

BP Exploration and Oil Company 

Catlettsburg Refining LLC 

Cenex Harvest States 

Chalmette Refining L.L.C. 

Chevron Corporation 

Chevron Corporation 

Chevron Products Company 

Chevron Corporation 

Chevron Products Company 

Chevron Corporation 

Crown Central Petroleum 

Corporation 

Crown Central Petroleum 

Corporation 

Deer Park Refining Limited 

Partnership and Equilon 

Enterprises, LLC 

Diamond Shamrock Refining 

Co., L.P. 

Equilon Enterprises L.L.C. 

Exxon Corporation 

Exxon Corporation 

Exxon Corporation 

Exxon Corporation 

Fina Inc. 

Fina, Inc. 

Facility Name 

ARCO-Los Angeles Refinery 

BP Oil Lima Refinery 

Alliance Refinery 

BP Oil Toledo Refinery 

Catlettsburg Refinery 

Refinery (no name provided) 

Chalmette Refinery 

Salt Lake City Refinery 

Hawaii Refinery 

El Segundo Refinery 

Chevron El Paso Refinery (North 

Facility) 

Chevron Products Company, 

Pascagoula Refinery 

Chevron Products Richmond 

Refinery 

La Gloria Oil and Gas Co. 

Crown Refinery in Pasadena, CA 

Shell Deer Park Plant 

McKee Plants 

Wood River Refining Company 

Exxon Company USA Baton 

Rouge Refinery 

Exxon Baytown Refinery 

Exxon Benicia Refinery 

Exxon Co. U.S.A. Billings 

Refinery 

Port Arthur Refinery 

Big Spring Refinery 

Type of Data 

Submitted 

Survey 

Survey 

Survey 

Survey 

Survey 

No Survey 

Survey 

No Survey 

Survey 

Survey 

Survey 

No Survey 

Survey 

No Survey 

No Survey 

No Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

No Survey 

Survey 

Facility Reported 

Applicable OLD 

Operations? 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

No 

No 

No 

Yes 

Yes 

No 

Yes 

No 

No 

No 

Yes 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

Yes 
P.5 

Memo on Refineries with OLD 

December 1, 1999 

Page 4 

Refineries that Responded to the O.L.D. Survey (continued) 

Legal Owner 

Koch Refining Company, L.P. 

Koch Refining Company, L.P. 

Koch Refining Company, L.P. 

Lyondell-Citgo Refining 

Company Ltd. 

Marathon Oil Company, formally 

USX for 1997 

Marathon Ashland Petroleum 

LLC 

Marathon Ashland Petroleum, 

LLC 

Marathon Ashland Petroleum 

LLC 

Marathon Ashland Petroleum 

LLC 

Marathon Ashland Petroleum 

LLC 

Mobil Oil Corporation 

Mobil Corporation 

PDV Midwest Refining, LLC 

Peerless Oil and Chemicals, Inc. 

Petroleos De Venezuela S.A. 

Phillips Petroleum Company 

Phillips Petroleum Company 

Refinery Holding Company, L.P. 

Shell Oil Company 

Shell Oil Company 

Shell Oil Company 

Facility Name 

Corpus Christi West Refinery 

Corpus Christi East Refinery 

Pine Bend Facility 

Lyondell-Citgo Refining Company 

Ltd. 

Texas City Refinery 

Ohio Refining Division 

Minnesota Refining Division-St. 

Paul Park Refinery 

Michigan Refining Division 

Louisiana Refining Division 

Illinois Refining DivisionRobinson Refinery 

Mobil Oil Torrance Refinery 

Mobil Beaumont Refinery 

PDV Midwest Refining, L.L.C, 

Lemont Refinery 

Peerless Oil and Chemicals, Inc. 

Lake Charles Manufacturing 

Facility 

Sweeny Refinery and 

Petrochemical Complex 

Phillips Borger Refinery & NGL 

Center 

Refinery Holding Co. Refinery 

(South Facility) 

Shell Norco Chemical Company 

(West Site) 

Shell Norco Refining Company 

Deer Park Refinery 

Type of Data 

Submitted 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

No Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Facility Reported 

Applicable OLD 

Operations? 

Yes 

Yes 

Yes 

.Yes 

Yes 

No 

Yes 

No 

Yes 

Yes 

No 

No 

Yes 

No 

No 

Yes 

Yes 

No 

Yes 

Yes 

No 

H 
P.6 

- V . 

1 

Memo on Refineries with OLD 

December 1, 1999 

Page 5 

Refineries that Responded to the O.L.D. Survey (concluded) 

Legal Owner 

Shell Oil Company 

Sinclair Oil Corporation 

Sinclair Oil Corporation 

Sinclair Oil Corporation 

The Coastal Corporation ' 

Ultramar Diamond Shamrock 

Ultramar Diamond Shamrock 

Corporation 

Ultramar Diamond Shamrock 

Ultramar Diamond Shamrock 

Corporation 

Valero Energy Corporation 

Valero Energy Corporation 

Valero Energy Corporation 

Valero Refining Company-Texas 

Facility Name 

Shell Norco Chemical Company 

(East Site) 

Sinclair, Little America Refinery 

Sinclair, Wyoming Refinery 

Tulsa Refinery 

Coastal Refining and Marketing, 

Inc. 

Alma Refinery 

TRI Petroleum, Inc. Ardmore 

Refinery 

Colorado Refining Company 

Three Rivers Refinery 

Valero Refining Company -

Louisiana 

Corpus Christi Refinery 

Valero Refining Company-Texas 

City Refinery 

Houston Refinery 

Type of Data 

Submitted 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

Survey 

No Survey 

Survey 

Survey 

Survey 

Survey 

Facility Reported 

Applicable OLD 

Operations? 

Yes 

No 

Yes 

No 

Yes 

No 

No 

No 

No 

Yes 

Yes 

Yes 

Yes