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Q656.
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My
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fluidized
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catalytic
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cracking
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unit
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(FCCU)
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is
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monitored
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by
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a
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CEMs.
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How
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should
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those
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emissions
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be
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reported?
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A656. EPA has prepared a general table of reporting instructions for FCC units with CEMs as presented in the table below. In addition EPA has provided guidance on how to report regenerator and process gas and explained how to avoid double counting of emissions in the following common situations:
1. Should I report my "complete combustion regenerator" as a “process"process-only” only" configuration or as a “shared "shared process/combustion stack” stack" configuration?
2. Should I enter “petroleum coke” or “catalyst coke” into the “Types "petroleum coke" or "catalyst coke" into the "Types of fuel combusted in the unit(s) monitored by the CEMS” CEMS" field?
3. Should I report my "CO boiler" as a “process"process-only” only" configuration or as a “shared "shared process/combustion stack” stack" configuration?
4. Should I enter “regenerator "regenerator flue gas” gas" or “FCCU "FCCU process gas” gas" in the “Types "Types of fuel combusted in the unit(s) monitored by the CEMS” CEMS" field since the CO boiler burns mostly these fuels?
5. Under the “process-only” configuration, should I leave “CO2 “CO2 emissions attributable to process CO2 CO2 emissions” blank under the “CEMS Monitoring Location Process Units?
6. Under the “shared "shared process/combustion stack” stack" configuration, how do I report my process emissions given that there are both process and combustion emissions?
7. Under the “process"process-only” only" configuration, what do I report under “Equation "Equation C-10 Summary and Results”Results"?
8. Under the “shared process/combustion stack” configuration, under “Equation C-10 Summary and Results”, do I report the total CH4 and N2O CH4 and N2O emissions at the CML or only the emissions from the combustion of auxiliary fuels used in the CO boiler?
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1. I have a CEMS that monitors the CO2 CO2 emissions from a catalytic cracking unit with a complete combustion regenerator (no CO boiler) that burns off petroleum coke which has deposited on the catalyst. Should I report this as a “process-only” configuration or as a “shared process/combustion stack” configuration?
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3. I have a CEMS that monitors the CO2 CO2 emissions from a CO boiler that receives process gas from a catalytic cracking unit. Should I report this as a “process-only” configuration or as a “shared process/combustion stack” configuration?
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5. Under the “process-only” configuration, should I leave “CO2 “CO2 emissions attributable to process CO2 emissions” blank under the “CEMS Monitoring Location Process Units” section because I’ve already reported all my CO2 CO2 emissions under the “Annual CO2 Emissions” section? Wouldn’t it be double-counting to enter these emissions in both locations?
There should always be CO2 CO2 emissions attributable to the process, since these emissions are a normal part of FCCU operation. Double-counting is not a concern because e-GGRT calculates subpart and facility total emissions using the only total annual CO2 CO2 emissions measured by the CEMS.
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The instructions in 98.253(c)(1)(ii) indicate that the process emissions should be the “Total annual CO2 mass emissions (biogenic and non-biogenic) measured by the CEMS” minus the “CO2 “CO2 emissions from CEMS Monitoring Location (CML) attributable to combustion.” The emissions attributable to combustion should be calculated using the applicable methods in subpart C.
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You would typically report only the CH4 and N2O CH4 and N2O emissions due to combustion of fuel gas and other Table C-2 fuels used in the CO boiler. Section 98.252(a) provides specific instructions for calculating CH4 and N2O emission from the combustion of fuel gas (i.e. , using the default CH4 and N2O emission factors for “Petroleum (All fuel types in Table C-1)” in Table C-2 of Subpart C). If you have a separate stationary combustion source that shares a common stack with the process emissions, also include and report the CH4 and N2O emissions due to combustion of fuels used in the stationary combustion unit following the requirements of subpart C. The CH4 and N2O CH4 and N2O emissions generated from the combustion of catalyst petroleum coke are reported under the subject process unit’s e-GGRT data entry forms and should not be included in the CML’s reporting section “CEMS Equation C-10 Summary and Results.”
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Updated on
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Source: Michael Hannan, 6/20/2012
Approval / Publishing History: Version 1
Expiration: none
Relevant Subparts: Subpart Y, FCCU CEMs
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