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 document is to provide a summary of the fuel gas compositional 

analyses received by the EPA from the 2011 Information 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, emissions inventories and source testing to bolster our 

current data and fill known data gaps. The ICR had four components: (1) a questionnaire on 

processes and controls to be completed by all petroleum refineries (Component 1); (2) an 

emissions inventory to be developed by all petroleum refineries using the emissions estimation 

protocol developed for this effort (Component 2); (3) distillation feed sampling and analysis to 

be conducted by all petroleum refineries (Component 3); and (4) emissions source testing to be 

completed in accordance with an EPA-approved protocol for specific sources at specific 

petroleum refineries (Component 4). 

Component 4 of the ICR requested source testing 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 similar 
memorandum is available for the other emission sources requested to be tested as a result of this 

ICR. 

Facilities often claimed specific fuel gas process 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 complete 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 request 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): Provided 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) 

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• ConocoPhillips – Ferndale, WA (WA5A1430) 

• U.S. Oil – Tacoma, WA (WA5A1440) 

• Hovensa – St. Croix, USVI (VI6A1530) 

 Owners or operators of fuel gas systems at these facilities were requested to test for: 

• C1 through C5 hydrocarbons plus benzene 

• Total reduced sulfur (TRS), hydrogen sulfide, 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 source testing requirements for the fuel gas systems can be found 

at can be found at http://www.epa.gov/ttn/atw/petref/petrefpg.html. 

IV. Results 

A summary of the test results for the fuel gas systems are provided in a Microsoft® Excel 

spreadsheet titled “Combined_Refinery_Fuel_Gas_Results_nonCBI.xlsx.” The following 

designations were used to describe the detection levels of the reported emissions data. 

• DLL = Detection Level Limited. This designation was commonly applied to the 

TRS results where some TRS compounds 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 (calibrated 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 calibrated quantitation range for the analysis.