Component 2 Form Approved 03/28/2011 OMB Control No. 2060-0657 Approval Expires 03/31/2014

1 

## Petroleum Refinery Emissions Information Collection

PART VI. EMISSION S INVENTORY DATA

The U.S. EPA is working to fulfill its obligati ons under CAA section 112(f )(2) to review residual risk from the petroleum refinery NESHAP subparts CC and UUU, CA A section 112(d)(6) to perform technology reviews of the petroleum refinery NESHAP subparts CC and UUU, and CAA sections 111(b) to review the petroleum re finery NSPS subpart J. Emission data sets provided by the individual refineries will be used for these reviews.

Please provide emission estimates (tons/yr) for the 2010 calendar year for individual HAP and criteria pollutants for all emission sources locat ed at the facility us ing the Refinery ICR Component 2 Reporting Tool av ailable on the ICR website ( https://refineryicr.rti.org ). You may report emissions by emissions pointrather than by unit, but you should identify which units are associated with each emissions point. (Note: You do not have to report emissions a single way throughout the entire inventory. For example, you may report equipment leak emissions by process unit for the major pro cess units and by geographical ar ea for other areas of your refinery.) Emission sources include, but are not limited to:

• Each processing unit for which you provide d an ID in Part I, Question 16

• Each electricity generating, steam genera ting, or combined heat and power unit listed in Table 1-2 of Part II

• Each process heater listed in Table 2-1 of Part II

• Each fuel gas and natural gas system for which you provided equipment leaks data in Table 3-2 of Part II

• Each storage tank regardless of size or partial pressure of material stored

• Each “other atmospheric vent” listed in Table 11-1 of Part II (except for vents controlled by a flare)

• Each flare listed in Table 12-1 of Part II, including those controlling emissions from “other atmospheric vents” lis ted in Table 11-1 of Part II

Except as noted below, provide emission esti mates following the methods provided in the Emission Estimation Protocolfor Petroleum Refineries (Version 2.1 – Final ICR Draft). As noted in the Emission Estimation Protocolfor Petroleum Refineries , for each unit for which there are multiple methodologies for estima ting emissions, you must use the highest Methodology Rank in the Emission Estimation Protocolfor Petroleum Refineries for which you have available 2010 data. For example, if Methodology Rank 1 for NO X is estimating emissions using a continuous emissions monitori ng system (CEMS), and you have a NO X CEMS on that unit, you must use the CEMS results to estimate NO X emissions from that unit. However, if you did not have a NO X CEMS installed on that unit during 2010, you do not have available data toComponent 2 Form Approved 03/28/2011 OMB Control No. 2060-0657 Approval Expires 03/31/2014

2 use Methodology Rank 1 for NO X ; you must then consider whethe r you have available data to use Methodology Rank 2 for NO X from that unit. Similarly, if a particular methodology requires speciation of a stream and you do not have speciat ion data available, yo u are not required to conduct additional sampling and analysis (but if you do have speciation data available and no higher ranking methodology can be used, you mu st use the methodology that calls for speciation).

For units and other emissions points not addressed in the Emission Estimation Protocol for Petroleum Refineries , you should provide the emissions estim ates as your TRI or State inventory or use engineering estimates a nd process knowledge for pollutants not required to be reported for TRI or State inventory. Also provide a brief explanati on of the methodology you used in the “Comments” column of the em issions template provided.

For wastewater treatment systems, also pleas e provide a copy of the Refinery Wastewater Emissions Tool spreadsheet (provided as part of the Emission Estimation Prot ocol for Petroleum Refineries ) completed for your refinery.

Instructions for completing the emi ssions template are provided below.

1. Emissions point ID : Provide the identification number or code for the location at which emissions are released into the environment. If this is an emissions point for one particular process unit or a flare, you may use the Unit ID as your Emissions point ID. If you choose to report fugitive emissions by proces s unit, the Emissions point ID should be “FUG-” plus the Unit ID ( e.g. , if you are reporting equipment leak emissions for a FCCU with a Unit ID of FCCU01, the Emissi ons point ID is “FUG- FCCU01”).

2. Emissions point description : Provide a description of the emissions point for easy reference ( e.g. , FCCU regenerator vent stack; cata lytic reforming unit depressurization vent; crude heater vent; facility-w ide start-up and shutdown emissions).

3. Unit ID(s) : Provide the identification number or c ode for the unit(s) associated with this emissions point. Use the same identification number that you provi ded in Component 1. For sulfur recovery, enter th e SRU ID. For an emissions point that covers the entire facility, enter “All Units.” (Note that for flares, you ar e not required to identify the process units and/or vents routed to each flar e; the response to this question is the Flare ID). For units not included in Component1, use a unique ID for each process unit. When possible, use the same identifier fr om your permit or emissions inventory.

4. SCC : The ICR website ( https://refineryicr.rti.org ) provides source classification codes (SCC) extracted from EPA’s 2005 National Scale Air Toxics Assessment (NATA) National Emissions Inventory (NEI) database lookup tables . There have been updates (both additions and deletions) to the SCC over the years, a nd the list on the ICR website contains the current list of SCC that EPA would like you to use for this inventory. If a code that you have used in the past no longer appears in the a pplicable lookup table, please select the most appropria te code from those listed.

5. Type of Release (Point or Fugitive) : Point releases are the emissions released from a facility unit that is included in the facility inventory through one or more stacks or vents.Component 2 Form Approved 03/28/2011 OMB Control No. 2060-0657 Approval Expires 03/31/2014

3 Fugitive releases are air pollutants released to the air other than those from stacks or vents, including small releases from leaking plant equipment such as valves, pump seals, flanges, or sampling connections, and large open area releases such as from landfills, waste ponds, coke drum cutting, coke tran sport and storage, or unpaved roads.

6. Point Sources : Complete the columns listed below if you answered “Point” in Number 5.

Release Height (ft) : Enter the height of the stack or vent from the ground.

Internal Vent Diameter (ft) : Enter the diameter of the stack or vent at the release height.

Exit Temperature (°F) : Enter the temperature of the exit gas stream

Gas Flow Rate (acfm) : Enter the flow rate of the exit gas stream.

7. Fugitive Sources : Complete the columns listed be low if you answered “Fugitive” in Number 5.

Length (ft) : Enter the dimension of the sour ce in the east-west (x-) direction

Width (ft) : Enter the dimension of the source in the north-south (y-) direction

Angle : The release angle is the orientation of the y-dimension relative to true North, measured positive for clockwise starting at 0 degrees (maximum less than 90 degrees). EPA will assume 0 degrees if it is not provided.

8. Longitude and Latitude : Pay particular attention when entering emission release point stack parameters and locations. EPA requires latitude/longitude for each emissions point provided in North American Da tum (NAD) 83 and prefers six di gits to the right of the decimal point. (If currently available coordina tes have five digits to the right of the decimal point instead of six, those coordinates are acceptabl e.) These data are critical inputs to the modeling files that EPA will use to determine the risk profile for the residual risk review process. 1

9. Pollutant name : Enter the name of the pollutant for which you are estimating emissions. You will need to enter only one pollutant per row; for most units, it will take multiple rows to provide emissions estimates for all pollutants.

10. Pollutant CAS No. or Pollutant Code : See Table 1-1 of the Emission Estimation Protocol for Petroleum Refineries for a list of CAS numbers and Pollutant Codes for selected

1 Latitude measure in decimal degrees of the angular distance on a meridian north or south of the equator. Positive (+) data point for North America. Example: +78.123456. For point sources, this represents the center of the source; for fugitive sources, this is the southwest corner if the fugitive angle is zero or the western most corner if the fugitive angle is greater than zero. Longitude measure in decimal degrees of the angular distance on a meridian east or west of the prime meridian. Negative (-) data point for North Am erica. Example: -123.23456 1. For point sources this represents the center of the source; for fugitive sources, this is the southwest corner if the fugitive angle is zero, or the western most corner if the fug itive angle is greater than zero.Component 2 Form Approved 03/28/2011 OMB Control No. 2060-0657 Approval Expires 03/31/2014

4 pollutants. The same list is also include d in the Refinery I CR Component 2 Reporting Tool.

11. 2010 routine emissions (tons) : All emissions reported in th is column should reflect the ACTUAL emissions during normal operation for the reported calendar year. If you use a CEMS/CMS to monitor emissions of a partic ular pollutant, report in this column the emissions measured during all pe riods when readings were wi thin the calibrated span of the CEMS/CMS.

12. Methodology used for routine emissions : Indicate whether the emissions are based on direct measurements, stack testing, engin eering calculations, or another method.

13. 2010 non-routine emissions (tons) : All emissions reported in this column should reflect the ACTUAL emissions during any non-routine operation for the reported calendar year, including startups, shutdowns, and other ev ents. If you use a CEMS/CMS to monitor emissions of a particular pollutant and the re adings for certain periods of the year were not within the calibrated span of the CEMS /CMS, estimate emissions of that pollutant from the process unit during those periods a nd report the value here . Enter 0 if there were not non-routine operations for this source during 2010 or if non-routine emissions are not applicable for the source type ( e.g. , equipment leaks). You may use an emissions point ID representing “All Units” to report the non-routine emissions (see descriptions for Number 1 and Number 3).

14. Maximum hourly emissions (lb/hr) : Enter the maximum actual emissions from the unit during normal operation in any one hour of 2010. See the Emission Estimation Protocol for Petroleum Refineries for additional information on how to determine hourly emissions.

15. Annual emissions allowed by NESHAP for emissions points subject to emission limits (tons/yr) : Enter the annual emissions during normal operation allowed by the NESHAP to which this unit is subject. (Note that if the NESHAP limit is on a concentration basis, you will need to use process data at maximum ca pacity to convert the limit to tons/yr. Similarly, if the NESHAP limit is on a per cent reduction basis, you may need to use information about the inlet to the control devi ce to estimate the allowable emissions.) If this unit is not subject to any NESHAP for this pollutant, enter “N/A.”

As an example, if you comply with the 1 lb per 1,000 lb coke burn-off limit for PM for an FCCU, determine and report the allowed annual PM emissions based on the annual quantity of coke burned in 2010 when repor ting the allowed PM emissions and enter “N/A” when reporting the allowed nickel emi ssions. Alternatively, if you comply with the 0.029 lb/hr nickel emissions limit for an FCCU, enter “N/A” when reporting the allowed PM emissions and determine and re port the allowed annual nickel emissions based on the operating hours of the unit in 2010 when reporting the allowed nickel emissions.

16. Hourly emissions allowed by NESHAP for emissions points subject to emission limits (lb/hr) : Enter the maximum hourly emissions during normal operation allowed by theComponent 2 Form Approved 03/28/2011 OMB Control No. 2060-0657 Approval Expires 03/31/2014

5 NESHAP to which this unit is subject. Fo r example, when reporting nickel emissions from an FCCU, enter “N/A” if you comply with a PM emissions limit but report the allowed hourly emissions rate if you comply w ith the nickel emission rate alternative. (Note that if the NESHAP limit is on a concen tration basis, you will need to use process data at maximum capacity to convert the limit to lb/hr. Similarly, if the NESHAP limit is on a percent reduction basis, you may need to use information about the inlet to the control device to estimate the allowable emissions.) If this unit is not subject to any NESHAP for this pollutant, enter “N/A.”

As an example, if you comply with the 1 lb per 1,000 lb coke burn-off limit for PM for an FCCU, determine and report the allowed hour ly PM emissions based on the maximum quantity of coke burned in an hour du ring 2010 when reporting the allowed PM emissions and enter “N/A” when reporting the al lowed nickel emissions. Alternatively, if you comply with the 0.029 lb/h r nickel emissions limit for an FCCU, enter “N/A” when reporting the allowed PM emissions and enter “0.029” (lb/hr) when re porting the allowed nickel emissions.

17. Annual emissions allowed by permit (tons/yr) : Enter the annual emissions during normal operation allowed by your operating permit (may be more stringent than the emissions limit under the applicable NESHAP). (Note th at if the permit limit is on a concentration basis, you will need to use process data at maximum capacity to convert the limit to tons/yr.) If your permit does not have a numer ical limit for emissions of this pollutant from this unit, enter “N/A” (see example for Number 15).

18. Hourly emissions allowed by permit (lb/hr) : Enter the maximum hourly emissions during normal operation allowed by your operating permit (may be more stringent than the emissions limit under the applicable NESHAP). (Note that if the permit limit is on a concentration basis, you will need to use pr ocess data at maximum capacity to convert the limit to lb/hr.) If your permit does not ha ve a numerical limit for emissions of this pollutant from this unit, enter “N/A” (see example for Number 16).

19. Comments : Provide any comments that you feel ar e necessary to qualify or explain any of your answers to the previous questions.