## Technical Memorandum
TO: Brenda Shine, Refining and Chemicals Group, SPPD FROM: Eric Goehl, Environmental Protection Specialist Refining and Chemicals Group, SPPD (E143-01)
DATE: April 6, 2012 SUBJECT: Summary of Fuel Gas Compositional Analyses
I. Purpose The objective of this documen t is to provide a summary of the fuel gas compositional analyses received by the EPA from the 2011 In formation Collection Request (ICR) of the petroleum refinery industry.
II. Background On April 1, 2011, the EPA sent an ICR to facilities in the U.S. petroleum refining industry. The ICR was comprehensive and designed to collect information on processing characteristics, crude slate characteristics, emissi ons inventories and source testing to bolster our current data and fill known data gaps. The I CR had four components: (1) a questionnaire on processes and controls to be completed by all petroleum refine ries (Component 1); (2) an emissions inventory to be developed by all petr oleum refineries using the emissions estimation protocol developed for this effort (Component 2) ; (3) distillation feed sa mpling and analysis to be conducted by all petroleum refineries (Compone nt 3); and (4) emission s source testing to be completed in accordance with an EPA-approved protocol for specific sources at specific petroleum refineri es (Component 4). Component 4 of the ICR requested source test ing for twelve different types of emission sources or units: fluid catalytic cracking units (FCCU), thermal catalytic cracking units, catalytic reforming units, sulfur recovery units, delayed coking units, fluid coking units, hydrocracking units, hydrogen plants, asphalt blowing units, fuel gas systems, cooling water systems, and wastewater treatment systems. This memorandum summarizes the results of the fuel gas compositional analyses conducted on fuel gas systems for selected refineries. A similarmemorandum is available for the other emission sources requested to be tested as a result of this ICR. Facilities often claimed specific fuel gas pr ocess information and/or composition as CBI, and included that information in the CBI version of the emission source test reports stored in the EPA’s CBI office in Research Triangle Park, NC. As fuel gas composition is not directly emissions data, large portions or even the comp lete test reports may be claimed as CBI. This memorandum summarizes and presents only non-CBI data received as a result of the 2011 ICR.
III. Source-specific Testing Program Below is a list of facilities required to test their fuel gas systems.

• Chevron – El Segundo, CA (CA5A0130): submitted as CBI

• Shell – Martinez, CA (CA5A0160): submitted as CBI

• ConocoPhillips – Rodeo, CA (CA5A0280)

• Valero – Benecia, CA (CA5A0320)

• PBF Energy – Delaware City, DE (DE1A0360)

• Citgo – Lemont, IL (IL2A0400)

• Calcasieu – Lake Charles, LA (LA3C0520)

• Citgo – Lake Charles, LA (LA3C0560)

• ExxonMobil – Baton Rouge, LA (LA3C0590)

• Marathon – Garyville, LA (LA3C0610): Original test request was for Marathon – Catlettsburg, KY (KY2A0490); EPA approved re quest to test at Garyville instead.

• ExxonMobil – Billings, MT (MT4A0790)

• ConocoPhillips-Bayway – Linden, NJ (NJ1A0850)

• Tesoro – Mandan, ND (ND2B0900): submitted as CBI

• Sunoco-Toledo – Oregon, OH (OH2A0940)

• Holly – Tulsa, OK (OK2C0980)

• Sunoco – Marcus Hook, PA (PA1A1020): Pr ovided daily grab samples taken over a period of two months for all constituents other than benzene

• ExxonMobil – Baytown, TX (TX3B1160)

• Houston Refining – Houston, TX (TX3B1200)

23 • ConocoPhillips – Ferndale, WA (WA5A1430)

• U.S. Oil – Tacoma, WA (WA5A1440)

• Hovensa – St. Croix, USVI (VI6A1530)
Owners or operators of fuel gas systems at th ese facilities were requested to test for:

• C1 through C5 hydrocarbons plus benzene

• Total reduced sulfur (TRS), hydrogen sulfid e, carbonyl sulfide, and carbon disulfide

• Hydrogen, carbon monoxide, carbon dioxide, nitrogen, and oxygen,

• Higher heating value, moisture, and gas flow rate.

Additional detail of the sour ce testing requirements for the fuel gas systems can be found at can be found at http://www.epa.gov/ttn/a tw/petref/petrefpg.html

.

IV. Results A summary of the test results for the fuel ga s systems are provided in a Microsoft® Excel spreadsheet titled “Combined_Refinery_Fue l_Gas_Results_nonCBI.xlsx.” The following designations were used to describe the dete ction levels of the re ported emissions data.

• DLL = Detection Level Limited. This de signation was commonly applied to the TRS results where some TRS compo unds were detected and other TRS compounds were below detection limit and TRS was determined as the sum of these concentrations. This designation was applied to compounds footnoted with a J, which indicates that the compound was detected, but at concentrations less than the quantification level (calib rated range) of the analysis.

• BDL = Below Detection Limit.

• No designation or ADL = Above Detection Limit.

• EQL = Exceeds Quantitation Limit. This designation was used when results were noted to be greater than the calibrate d quantitation range for the analysis.