Review of Industry Test Reports for Refinery MACT II Regulation


 United States
 Environmental Protection
 Agency
Office of Air Quality
Planning and Standards
Research Triangle Park, NC 2771
EPA - 454/R-99-052
September 1999
 Air
&EPA
Review of Industry Test Reports
for Refinery MACT II Regulation

-------
        Final  Report

    Review of Industry
        Test Reports
                 by

    Susan J. Abbgy, Michael W. Holdren,
Joshua K. Finegold, and Patricia M. Holowecky
               Battelle
           505 King Avenue
       Columbus, Ohio 43201-2693
          September 17,1999
          Contract 68-D-99-009
        Work Assignment No. 1-03
            Project Officer

             Kathy Weant



        Work Assignment Manager

            Rima Dishakjian

 Emissions, Monitoring, and Analysis Division
 Office of Air Quality Planning and Standards
    U.S. Environmental Protection Agency

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                                    EPA Disclaimer
The information in this document has been funded wholly or in part by the United States
Environmental Protection Agency under Contract 68-D-99-009 to Battelle.  It has been subject to
the Agency's peer and administrative review, and it has been approved for publication as an EPA
document.  Mention of trade names or commercial products does not constitute endorsement or
recommendation for use.
                                   Battelle Disclaimer
This report is a work prepared for the United States Government by Battelle.  In no event shall
either the United States Government or Battelle have any responsibility or liability for any
consequences of any use, misuse, inability to use, or reliance upon the information contained
herein, nor does either warrant or otherwise represent in any way the accuracy, adequacy,
efficacy, or applicability of the contents hereof.
                                           11

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Abstract

In order to set Maximum Achievable Control Technology (MACT) standards, the US
EPA is gathering emissions data from industry sources. These test data must be evaluated for
appropriate Quality Assurance/Quality Control (QA/QC) procedures. For the Refinery MACT II
standard, test reports are being gathered from industry tests, and must be evaluated before data
can be used for standard-setting purposes.
This final report describes work conducted by Battelle staff to evaluate 55 test reports
gathered from various refinery tests. For this report, Battelle has reviewed and evaluated the 55
test reports and has provided a brief summary report for each refinery test report. Each summary
report is organized in tabular format and includes the following headings: pollutant measured,
EPA air method that was used, deviations from the EPA method, other methods used, method
validation, audit conducted, method QA/QC requirements achieved, and sample data calculations
conducted. Each industry test report also received an overall rating based upon the tabular
information. Finally, a brief summary on the overall quality of the data is included with each
summary report.
This report is submitted in fulfillment of contract No. 68-D-99-009 (Work Assignment
No. 1-03) by Battelle under the sponsorship of the U.S. Environmental Protection Agency. It
covers the period from March 11, 1999 to September 17, 1999, and all work was completed as of
September 17, 1999.
111

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                                       Contents


Abstract  	iii

Figures	iv

Tables	iv

Section 1   Introduction  	   1

Section 2   Results  	   3

Appendix
       Summary Reports of 55 Industry Test Reports	  10

                                         Figure

1.     Distribution of 55 Industry Test Reports According to Tier Classifications  	   9

                                         Table

1.     Industry Test Report Title and Assigned Tier Level	  4
                                           iv

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                                     Section 1
                                   Introduction

      In order to set Maximum Achievable Control Technology (MACT) standards, the U.S.
EPA is gathering emissions data from industry sources. These test data must be evaluated for
appropriate Quality Assurance/Quality Control (QA/QC) procedures. For the Refinery MACT II
standard, test reports are being gathered from industry tests, and must be evaluated before the
data can be used for standard-setting purposes.
      For this report, Battelle has reviewed and evaluated 55 industry test reports. A summary
report was written for each industry test report.  Each summary report is organized in tabular
format and includes the following headings:

      •      Pollutant Measured
             EPA Air Method (Stationary Source) That Was Used
      •      Deviations from EPA Method
      •      If Other Method Used, List Summary
             If Not EPA Method, Validation By Method 301 ?
             Was Audit Conducted?
             Method QA/QC Requirements Met?
      •      Sample Data Calculations Conducted?

Each industry test report is also given a rating level as follows:
       TIER I       EPA Air Method or EPA (other than air), State, or unknown method
                    with Method Validation
       TIER II      State Agency method (e.g., California), no Method Validation

-------
      TIER III     Unknown method, no Method Validation, good QA procedures
      TIER IV     Unknown method, no QA documentation

Each industry test report receives one of the above ratings based upon the information shown in
each summary report as well as from comments in the original test report.  For instance, because
industry test report No. 22 makes use of only EPA Air Methods, this report received a TIER I
rating. However, the report indicates that the data results are suspect. This is discussed in the
brief summary on overall quality of the data that is provided for each summary report.

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                                       Section 2
                                        Results

       Table 1 lists the fifty-five (55) industry test reports that were provided to Battelle. The
Tier Level that was assigned to each report is shown in the last column of the table.  Most of the
reports were classified as Tier Level I reports. Figure  1 shows a graphical distribution of the 55
test reports according to Tier Classification. Appendix A contains Battelle's summary reports of
all 55 industry test reports.

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Table 1.  Industry Test Report Title and Assigned Tier Level
Report
No;;*:.
' • • "'•;• , '

1
2
3
4
5
6
7
8
9
10
11
12
13
14
; v "Report Description (Title)
;l.'' ;.'' ' '-/.;..!'" ",5, '[':". . :.. .'• .'" ' ""• • "••;"£"?:£;- . :
.. . ?• ;.-..'!:.: - 'A t? sr..ri ^' :"• "' " • ,^'-!^H:> 	 yV« ....,-.
^ • '••. •>.->•• '- ;, - „-.,,.;'..• - n-r- - ; K.";-'- > •- •

Western States Petroleum Association report on AB2588
Pooled Source Emission Test Program, July 1990
Report on Compliance Testing, Indian Refining,
Lawrenceville, Illinois, March 8, 1993
Particulate Emission Evaluation, BP Oil Refinery, Lima,
Ohio, January 19, 1994
Ashland Petroleum Company, Canton, Ohio, FCC Stack
Test Report, May 4, 1994
Plant No. 2 Fluid Catalytic Cracking Unit Emission Test
Report, Sun Refining and Marketing, Toledo, Ohio, July
20, 1994
Total Petroleum, Incorporated, Alma, Michigan,
Emission Sampling on the FCC CO Boiler Exhaust,
April 18, 1996
Emission Compliance and CEM Relative Accuracy Test
Program FCCU Exhaust Stack, Clark Refining and
Marketing, Blue Island Illinois, December 29, 1994
Emission Compliance Test Program FCCU Exhaust
Stack, Clark Refining and Marketing, Blue Island
Illinois, July 3, 1997
Evaluation of Sulfur Dioxide, Nitrogen Oxides, and
Carbon Monoxide Emissions, Marathon Petroleum
lefinery, Detroit, Michigan, August 6, 1991
Results of Nitrogen Oxide and Carbon Monoxide
Emissions Testing Conducted on an Uni finer Charge
Heater, Marathon Petroleum Refinery, Detroit,
Michigan, July 19, 1994
Results of Compliance Testing on the Alkylation and
Unifiner Flares, Marathon Petroleum Refinery, Detroit
Michigan, September 16, 1996
[Results of Compliance Testing Performed on the
Cracking Plant Flare, Marathon Petroleum Refinery,
Detroit, Michigan, September 25, 1996
fParticulate Emission Compliance Study, FCC Unit-CO
Boiler Stack, Mobil Oil Corporation, Joliet, Illinois,
kugust 19, 1996
[Particulate Emission Compliance Study, Mobil Oil
[Corporation, Joliet, Illinois, September 20, 1996
Docket No.
fr ..-..'

II-I-4
IV-D-6
IV-D-7
IV-D-8
IV-D-9
IV-D-10
IV-D-14,
Attachment 1
IV-D-14,
Attachment 2
IV-D-15,
Attachment 1
IV-D-15
Attachment 2
IV-D-15,
Attachment 3
IV-D-15,
Attachment 4
IV-D-16,
Attachment 1
IV-D-16,
Attachment 2
Tier Level -
il -
•*•+', *M

*
II
I
I
I
I
I
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Table 1.  Industry Test Report Title and Assigned Tier Level
Report
'Wf;
• •'"r-C. r.'-''~ i
**•".*' "3 .
" 1 Report Description (Title),
-•' ' p.- •,"-.•'• -"^'W'y1'-;^"- "•?:• * ••'V
Z-* ; ^"i- •-'-•-ris-f-rci?:*1-;, • '^.'- + ?/• "
*^ :;^; -^;P*;V,I? ,'r :<-;p *• •• •••
;v. ?;vV-'':-:;(~:-^|s! •/!::•. *>-r± "
1 5 [FCC Information Request and Stack Testing Results,
[Mobil Oil Corporation, Joliet, Illinois, June 18, 1997
16 [No. 1 and No. 2 Cat Cracker Stack Particulate Emission
[Testing, Shell Oil Company, Wood River, Illinois, April
p/8, 1992
17
18
19
No. 1 and No. 2 Cat Cracker Stack Particulate Emission
Testing, Shell Oil Company, Wood River, Illinois,
October 27/28, 1992
No. 1 and No. 2 Cat Cracker Stack Particulate Emission
Testing, Shell Oil Company, Wood River, Illinois,
January 12/13, 1993
No. 1 and No. 2 Cat Cracker Stack Particulate Emission
Testing, Shell Oil Company, Wood River, Illinois,
February 16/17, 1994
20 JNo. 2 Cat Cracker Formal Particulate Emission Testing,
phell Oil Company, Wood River, Illinois, August 8,
1994
21 [Formal Particulate Emission Testing Fluid Catalytic
packing Unit ESP Exhaust, UNO- YEN Company,
temont, Illinois, October 28, 1993
22
23
24
25
26
27
28
Report of Particulate, CO, and SO2 Testing on the CO
Boiler of the FCCU, UNO-VEN Company, Lemont,
Illinois, December 22, 1994
Fluidized Catalytic Cracking Unit CO Boiler Emissions
testing Results, UNO-VEN Company, Lemont, Illinois,
May 24, 1995
1 12P-2 Particulate Emissions Results Report, UNO-
VEN Company, Lemont, Illinois, February 5, 1996
Source Test Report Particulate Matter Emissions
Results, Clark Oil and Refining Corporation, Hartford,
Illinois, November 19, 1993
Source Test Report Particulate Matter Emissions
Results, Clark Oil and Refining Corporation, Hartford,
Illinois, March 1994
Total Particulate Matter and Particle Size Distribution
FCC Stack, Clark Oil and Refining Corporation,
Hartford, Illinois, March 1 1, 1994
Confirmation of Information Emission Test Report,
Clark Oil and Refining Corporation, Hartford, Illinois,
April 1994
Docket No.
- . ' t
V -(''''
1 ."'.- • ' " '. •
IV-D-16,
Attachment 3
TV-D-17,
Attachment 1
IV-D-17,
Attachment 2
IV-D-17,
Attachment 3
IV-D-17,
Attachment 4
IV-D-17,
Attachment 5
IV-D-18,
Attachment 1
IV-D-18,
Attachment 2
IV-D-18,
Attachment 3
IV-D-18,
Attachment 4
IV-D-19,
Attachment 1
IV-D-19,
Attachment 2
IV-D-19,
Attachment 3
IV-D-19,
Attachment 4
TierLevel
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Table 1.  Industry Test Report Title and Assigned Tier Level
Report
:. NO;;X
i* -.: ;&;•-; f
•" • *"*?•!!' •
29
30
"
32
33
34
35
36
37
38
39
40
41
42
; . : , Report Description?(TitIe) ?
i^£r^^*^;l$&,: -:w A^Liifit.,-.- ;,;
•i,--:^,-~-'~^^^-i-.Vf^ •...:, ••-•-?:• ••;3&?~~-^>T^: -• ••'•
f^^fiSvfr, :.,>S^-?f.-|*-V-: ' ::,-'-^-. o^jt*^*,^^*.; , ; . ' -:
AI;..,,-' ^«VK ;•>••' -- • ; '.^Vi.v • •".'- i . - ... . .' • •'•^h'x ' * •.~^,.r..r-i''i •-.. ' ";
Confirmation of Information Emission Test Report
FCCU, Clark Oil and Refining Corporation, Hartford,
llinois, December 20, 1994
Source Emission Testing for Particulate Matter Size
distribution, Clark Oil and Refining Corporation,
Hartford, Illinois, April 12, 1996
Source Emissions Testing for Particulate Matter, Clark
Oil and Refining Corporation, Hartford, Illinois, May 1,
1996
Source Emissions Testing Report FCCU, Clark Oil and
lefining Corporation, Hartford, Illinois, June 27, 1996
Source Emissions Testing for Particulate Size
Distribution, Clark Oil and Refining Corporation,
Hartford, Illinois, August 5, 1996.
Source Emissions Compliance Testing Report for PM,
SO2, FCCU, Clark Oil and Refining Corporation,
Hartford, Illinois, August 7, 1996
imission Compliance Test Program FCCU CO Boiler
Stack, Marathon Oil Company, Robinson, Illinois, May
12, 1993
Emission Compliance Test Program FCCU CO Boiler
Stack, Marathon Oil Company, Robinson, Illinois,
August 4/5, 1993
Particulate Emission Characterization Test Program
FCCU CO Boiler Stack, Marathon Oil Company,
Robinson, Illinois, March 9/10, 1994
Particulate Emission Compliance Test Program FCCU
CO Boiler Stack, Marathon Oil Company, Robinson,
Illinois, June 27, 1994
Particulate Emission Compliance Test Program FCCU
CO Boiler Stack, Marathon Oil Company, Robinson,
[llinois, August 9, 1994
Emission Compliance Test Program FCCU CO Boiler
Stack, Marathon Oil Company, Robinson, Illinois,
March 14, 1995
Superior Refinery FCCU Stack Test Reports, Murphy
Oil, USA, Incorporated, Superior, Wisconsin, January
1995
Particulate Emissions Test Program FCCU-ESP Exhaust
Stack, Murphy Oil, USA, Incorporated, Superior,
Docket No.
>-• • : -•
IV-D-19,
Attachment 5
IV-D-19,
Attachment 6
IV-D-19,
Attachment 7
IV-D-19,
Attachment 8
IV-D-19,
Attachment 9
IV-D-19,
Attachment 10
IV-D-20,
Attachment 1
IV-D-20,
Attachment 2
IV-D-20,
Attachment 3
IV-D-20,
Attachment 4
IV-D-20,
Attachment 5
IV-D-20,
Attachment 6
IV-D-21,
Attachment 1
IV-D-21,
Attachment 2
TiefEevel'
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Table 1.  Industry Test Report Title and Assigned Tier Level
Report
No.^-
•-•;.J;^

43
44
45
46
47
48
49
50
51
52

54
T^;-'^:^ C ^Report Description-Critic)^
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%MS;:4S^Wt'^^-::-i:C' .-.-.•^^i^^;^: -: • -^
F^^v>>iPN:^ <".:• ->"•<&*«. 	 ;>^affl%''. ' : •
;^^-.v,j-^^^r-; ,.•:..- vpsfcjv, ^;:-|^S^PH^'- :•• 	 ;•
Jjf'.., yc[ti.->.:\,.;:,-«»;fei^«K;';:.. .-.; .••-...-.". • -. ••$&. ;; r. i^jijVu ': :'• •
Wisconsin, November 20, 1996
Particulate Emission Compliance Test Program FCCU
ESP Exhaust Stack, Murphy Oil, USA, Incorporated,
Superior, Wisconsin, August 20, 1997
Stack Emissions Test, Coastal Eagle Point Oil
Company, Westville, New Jersey, August 15, 1996 and
December 11, 1996
Evaluation Test Report: Determination of Emissions
rom the No. 3 Reformer at Tosco Refining, San
Francisco, California, February 26, 1999
Emission Test Report, Marathon Ashland Petroleum
LLC, Garyville, Louisiana, January 1, 1998 through
June 30, 1998
RCRA Trial Bum Report for CO Boiler No. 1 at the
Shell Oil Manufacturing Complex, Martinez, California,
April 1989 (Revised October 1989)
RCRA Trial Burn Report for CO Boiler No. 2 at the
Shell Oil Manufacturing Complex, Martinez, California,
November 1991
Trial Burn Report for CO Boiler No. 3 at the Shell Oil
Manufacturing Complex, Martinez, California,
December 16, 1993
Test Report for Exxon Company, USA, Benecia,
California, February 12-20, 1990
Determination of Air Toxics Emission Rates - FCCU
Volume I and Volume II, Mobil Oil Corporation,
Torrance, California, May 16, 30, and 31, 1990
lesults of Dioxin Testing on the Catalytic Reformer
Unit #1 Exhaust, Texaco Refinery, Bakersfield,
California, August 8, 1991
NOx, SO2, CO, Sulfates and Particulate Compliance
Emission Test Program-Heavy Oil Scrubber Exhaust
(EPN 121) 70,000 BBL/Day without NaHCO3
njection, Valero Refining Company, Corpus Christi,
Texas, March 15, 1995
AB2588 Air Toxics Emissions Test Report FCCU CO
Boiler Volume I-Main Report, Texaco Refining and
Marketing, Los Angeles Plant, Wilmington, California,
May 24, 1996
Docket No.
'i'C- '.::••. '-":'
!.';„,; : r •". '•*.'•• ' ~i '•

IV-D-31,
Attachment 3
IV-D-51
IV-D-62
IV-J-5
IV-J-8
IV-J-12
IV-J-13
IV-J-9
IV-J-10
IV-J-11
IV-J-14
IV-J-15
TiefuOTeveK
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;^ uig^;fer n&'Vj** '-. '•

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TV
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IV
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II
II
II
II
II
I
II

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Table 1. Industry Test Report Title and Assigned Tier Level
 Report
             Report Description (Title)
 Docket No.
TierEeyer
   55
Preliminary results of emission testing at Chevron
lefinery, Richmond, California, January, 1997
Awaiting final
  version for
 docket entry
    IV

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I
0)
CT
V
45-


40-


35-


30-


25-


20-


15-


10-
                                          IV
                                           Other
III
             Figure 1.  Distribution of 55 Industry Test Reports According To Tier
                                      Classifications

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               Appendix A
Summary Reports of 55 Industry Test Reports
                   10

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Report No.:  1
Report Title: Western States Petroleum Association Report on AB2588 Pooled Source Emission Test Program, July 1990
Docket No.:  II-I-4
Pollutant
Measured
PCDD/PCDF
Formaldehyde
Benzene
Polyaromatic
hydrocarbons
(PAHs)
Phenol
Acetaldehyde
Hydrogen
sulfide
EPA Air
Method
(Stationary
Source)







Deviations
From EPA
Method, If
Any







If Other
Method, List
Brief
Summary
Method 1613
and Methods
8280/8290
CARB Method
430
CARB Method
410A
CARB Method
429
Modification of
CARB Method
429
Modification of
CARB Method
430
Modification of
CARB Methods
15 and 16
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Hydrogen
cyanide
Toluene
Xylenes
U-
dichloroethane
Ethylene
dichloride
Ethylene
dibromide
Dibromoethane
Total petroleum
hydrocarbons
EPA Air
Method
(Stationary
Source)

VOST
Method
VOST
Method





Deviations
From EPA
Method, If
Any








If Other
Method, List
Brief
Summary
Modification of
CARB Method
426
CARB Method
422 and
Modifications
CARB Method
422 and
Modifications
CARB Method
422 and
Modifications
CARB Method
422 and
Modifications
CARB Method
422 and
Modifications
CARB Method
422 and
Modifications
CARB Method
422 and
Modifications
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Hydrogen
chloride
Ethyl benzene
Ammonia
Total reduced
sulfur
compounds
Arsenic
Beryllium
Cadmium
EPA Air
Method
(Stationary
Source)







Deviations
From EPA
Method, If
Any




Modification
of EPA
Multi-Metals
train
Modification
of EPA
Multi-Metals
train
Modification
of EPA
Multi-Metals
train
If Other
Method, List
Brief
Summary
GARB Method
421
CARS Method
422 and
Modifications
Modification of
CARB Method
421
Modification of
CARB Methods
15 and 16



If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported



Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Copper
Lead
Manganese
Nickel
Selenium
Zinc
Total chromium
EPA Air
Method
(Stationary
Source)







Deviations
From EPA
Method, If
Any
Modification
of EPA
Multi-Metals
train
Modification
of EPA
Multi-Metals
train
Modification
of EPA
Multi-Metals
train
Modification
of EPA
Multi-Metals
train
Modification
of EPA
Multi-Metals
train
Modification
of EPA
Multi-Metals
train

If Other
Method, List
Brief
Summary






CARB Method
425
If Not EPA
Method,
Validation By
Method 301?






None reported
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Hexavalent
chromium
Mercury
EPA Air
Method
(Stationary
Source)


Deviations
From EPA
Method, If
Any


If Other
Method, List
Brief
Summary
CARS Method
425
CARB Method
101A
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
 This report is classified:  TIER II

 Rating levels are defined as:
 TIER I       EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
 TIER II      State Agency method (e.g., California), no Method Validation
 TIER III     Unknown method, no Method Validation, good QA procedures
 TIER IV     Unknown method, no QA documentation

 Rating levels are based on the following comments and on information found in the report summary table.

 Dioxins in Wastewater
 Analytical laboratory performing the analysis was certified by the state of California.  Both low resolution (EPA Method 8280) and high resolution
 (EPA Method 8290 and 1613) laboratory analytical procedures for dioxin/furan quantification were used. The laboratory used was capable of
 producing detection limits for EPA Method 8280 nearly as low as EPA Method 1613. It was therefore deemed acceptable to use EPA Method 8280
 on occasion for cost effectiveness since the purpose of the analytical results was to show process performance rather than to indicate regulatory
 compliance.  There is a statement made in the results section which reads, "A review of the laboratory's quality assurance and quality control data
 indicated that the results are of known quality and considered valid." All samples were taken in duplicate, but only one sample was analyzed.  One-
 liter amber bottles, specially cleaned, were supplied by the contract laboratory. Latex gloves were worn during sampling.  All samples were
 immediately cooled and kept in ice chests containing blue ice for delivery to the laboratory.

Emissions on 19 Refinery Sources
A series of tests were conducted on 19 refinery sources to develop preliminary emission factors to aid in preparation of the 1989 emission estimate
report mandated by AB2588, Air Toxics Hot Spots Information and Assessment Act of 1987.  These emission factors were established for a limited
population of each type of source and were obtained at essentially a single point in time. Therefore the accuracy with which these factors reflect

-------
representative emission factors from all refinery sources is unknown. The field test and laboratory data, calculation summaries, and QA/QC
documentation for tests preformed on each source were prepared and submitted as a separate series of documents entitled Interim Project Report.
According to the test report, all method QA/QC requirements were met. However, all QA/QC results were not reported and therefore could not be
verified.  Copies of field and laboratory spike data and minimum detectable and minimum quantifiable levels are included in Interim Reports along
with chain of custody documentation and equipment calibration data. Emission factors are calculated from triplicate test runs.
Method Descriptions:
CARB Method 422
CARD Method 426
CARB Method 421
CARB Method 15
CARB Method 430
EPA Multi-Metals Train
CARB Method 425
CARB Method 101A
EPA VOST Method
CARB Method 429
CARB Method 410A
CARB Method 41 OB
CARB Method 430
CARB Method 429
Determination of Halogenated Organics from Stationary Sources
Determination of Cyanide Emissions from Stationary Sources
Determination of Hydrochloric Acid Emissions from Stationary Sources
Determination of Hydrogen Sulfide, Carbonyl Sulfide and Carbon Disulfide Emissions from Stationary Sources
Determination of Formaldehyde in Emissions from Stationary Sources
Combination of CARB Methods 12, 101A, 104, 424, 425, and 433 for Determination of Specific Metals
Determination of Total Chromium and Hexavalent Chromium Emissions from Stationary Sources
Determination of Particulate and Gaseous Mercury Emissions from Sewage Sludge Incinerators
Collection of Volatile Components on a Combined Tenax/Charcoal Adsorption Column
Determination of PAHs Using GC/MS Scan Analysis Extended to Include Phenol
Determination of Low Concentrations of Benzene from Stationary Sources
Determination of High Concentrations of Benzene from Stationary Sources
Determination of Formaldehyde in Emissions from Stationary Sources
Determination of Polycyclic Aromatic Hydrocarbon (PAH) Emissions from Stationary Sources

-------
 Report No.:  2
 Report Title: Report on Compliance Testing, Indian Refining, Lawrenceville, Illinois, March 8, 1993
 Docket No.: IV-D-6
Pollutant
Measured
Participate
Sulfur dioxide
Opacity
Carbon
monoxide
EPA Air
Method
(Stationary
Source)
Methods 1 - 5
andSF
Method 6
Method 9
Method 10
Deviations
From EPA
Method, If
Any




If Other
Method, List
Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
PE Audit
conducted (audit
number 7194)
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
See below
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

The purpose of this test program was to quantify the emission levels of particulates, sulfur dioxide, carbon monoxide, and opacity for compliance
purposes. The testing took place at the FCCU stack of an Illinois refinery.

According to the test report, all method QA/QC requirements were met.  However, specific QA/QC results were not reported as such and therefore
could not be verified.  No deviations from U.S. EPA testing procedures were noted. Documentation for meter box full test calibration, post test
calibration check, nozzle calibration data, and type S pilot tube inspection data are included in report.  In addition, QC documentation such as field

-------
test data sheets and chain of custody forms are provided in the appendices of the test report and appear complete. An audit sample of sulfur dioxide
was analyzed along with the sample analysis (percent difference = 0.9).

-------
Report No.:  3
Report Title: Particulate Emission Evaluation, BP Oil Refinery, Lima, Ohio, January 19, 1994
Docket No.:  IV-D-7
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1 - 5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
None reported
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Testing was performed at the exhaust of the FCCU waste heat boiler ESP exhaust at a refinery located in Ohio.  The purpose of the test program was
to determine the particulate emission rates from the unit for engineering purposes.

Leak checks of the pilot tube lines and the sample train were all acceptable by EPA regulations, according to the report. Flue gas analysis for carbon
dioxide, oxygen, and carbon monoxide was conducted by drawing an integrated air bag sample and analyzing it on a portable gas analyzer.  The
average of these readings  for each run was used in calculating the emission rates.  Calibration of the equipment used was conducted within 60 days of
the test date, although calibration data is not part of test report and therefore could not be verified.

-------
Report No.: 4
Report Title: Ashland Petroleum Company, Canton, Ohio, FCC Stack Test Report, May 4, 1994
Docket No.: IV-D-8
Pollutant
Measured
Participate
Opacity
Sulfur dioxide
Hydrocarbons
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 9
Method 6C
Method 25A
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
None reported
None reported
None reported
This report is classified: TIER I

Rating levels are defined as:
TIER I EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II State Agency method (e.g., California), no Method Validation
TIER III Unknown method, no Method Validation, good QA procedures
TIER IV Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

This report contains test results on emissions of particulate, sulfur dioxide, hydrocarbons, and opacity. Reported results for particulate emissions
were in excess of their permitted levels while sulfur dioxide and hydrocarbon emission rates were below their permitted levels. The high levels of
particulate were deemed due to the stack test not being carried out under representative operating conditions according to EPA regulations (i.e. tests
carried out during start up period). Particulate emissions were tested following U. S. EPA Methods 1-5 and opacity readings by EPA Method 9. Test
methods used for sulfur dioxide and hydrocarbons were not mentioned in the report text but were indicated on spreadsheets in the appendices. No
quality control samples were reported.

-------
Test equipment calibration data and standards documentation are provided in the appendices of the test report.  According to the test report, all
method QA/QC requirements were met. However, specific QA/QC results were not reported as such and therefore could not be verified.

-------
Report No.: 5
Report Title: Plant No. 2 Fluid Catalytic Cracking Unit Emission Test Report, Sun Refining and Marketing, Toledo, Ohio, July 20, 1994
Docket No.: IV-D-9
Pollutant
Measured
Particulate
Sulfur dioxide

Opacity
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6

Method 9
Deviations
From EPA
Method, If
Any

If Other
Method,
List Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)

EPA Method(s)
Was Audit
Conducted?
See below
EPA audit samples
No. 8376 and
8601 were
analyzed with the
samples
See below
Method QA/QC
Requirements
Met?
None reported
Audit samples
within
acceptable range
None reported
Sample Data
Calculations
Conducted?
Yes
Yes

Yes
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

FCC Unit testing was conducted at a Sun Company refinery for paniculate and sulfur dioxide emissions to determine the compliance status of the
CCU per Ohio EPA Operating Permit. The report also includes results for opacity. According to the test report, quality control procedures were
conducted according to the basic principles as set forth in Volumes I, II, and III of the Quality Assurance Handbook prepared by the EPA Quality
Assurance staff. Also, external QA audits were conducted, and the results are provided in report. No deviations from standard U. S. EPA methods
were reported. No abnormal operating conditions were reported during testing. Documentation for dry gas meter, pitot tube, gravimetric check,
magnehelic gauge, and nozzle diameter check calibration data were included in the report.

-------
Quality Control procedures are described in the test report. Two audit samples of sulfur dioxide were analyzed along with the sample analysis ,and
results are reported to be within acceptable range. The test report is not specific about audits for the other pollutants measured.

Review of this test report included verification that sample data calculations were performed correctly. Some sample data calculations are wrong (see
Appendix lof test report).

-------
Report No.: 6
Report Title: Total Petroleum, Incorporated, Alma, Michigan, Emission Sampling on the FCC CO Boiler Exhaust, April 18, 1996
Docket No.: IV-D-10
Pollutant
Measured
Particulate
Opacity
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 9
Deviations
From EPA
Method, If Any

If Other
Method, List
Brief Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
This report is classified: TIER I
Rating levels are defined as:
TIER I EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II State Agency method (e.g., California), no Method Validation
TIER III Unknown method, no Method Validation, good QA procedures
TIER IV Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Emission testing was conducted on the exhaust of a carbon monoxide boiler that services the exhaust of the FCCU. Particulate emissions
determination was carried out using U.S. EPA Methods 1-5. Opacity testing was conducted with U.S. EPA Method 9. According to the test report,
all method QA/QC requirements were met. However, specific QA/QC results were not reported as such and therefore could not be verified.
Equipment calibration forms are provided in the appendix of the test report. A representative from the MDEQ Air Quality Division was present to
observe the testing. Formulas for calculations are provided, however no sample data calculations are provided in the report.

-------
 Report No.: 7
 Report Title: Emission Compliance and CEM Relative Accuracy Test Program FCCU Exhaust Stack, Clark Refining and Marketing, Blue Island
 Illinois, December 29, 1994
 Docket No.: IV-D-14, Attachment 1
Pollutant
Measured
Sulfur dioxide
Carbon
monoxide
Particulate
Opacity
EPA Air
Method
(Stationary
Source)
Method 6C
Method 10
Methods 1-5
Method 9
Deviations
From EPA
Method, If
Any




If Other
Method, List
Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
This report is classified: TIER I
Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
             State Agency method (e.g., California), no Method Validation
                aown method, no Method Validation, good QA procedure
TIER II
ncy method (e.g., California), no Method Validation
i method, no Method Validation, good QA procedures
: method, no OA documentation
TIER III    Unknown method, no Method Validation,
TIER IV    Unknown method, no QA documentation
Rating levels are based on the following comments and on information found in the report summary table.

-------
Emission compliance testing was performed on the FCCU exhaust stack at an Illinois refinery. Test methods followed those as detailed in 40CFR
Part 60, 1996, Appendix A for U.S. EPA Methods 1-5, 6C, 9, and 10.

A representative from Illinois EPA was present to observe the test series. Quality control results are not provided in the test report. Documentation
of test equipment calibration and calibration gas certificates of analysis are provided in the appendices of the test report.

Review of this test report included verification that sample data calculations were performed correctly.

-------
 Report No.:  8
 Report Title:  Emission Compliance Test Program FCCU Exhaust Stack, Clark Refining and Marketing, Blue Island Illinois, July 3, 1997
 Docket No.: IV-D-14, Attachment 2
Pollutant
Measured
Particulate
Opacity
Carbon
monoxide
Sulfur dioxide
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 9
Method 10
Method 6C
Deviations
From EPA
Method, If
Any




If Other
Method, List
Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
Yes using PS-2
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
YesA
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

An emission compliance test program was carried out to test for emissions which included particulate, opacity, carbon monoxide and sulfur dioxide.
Three emission compliance test runs were conducted for each of two process conditions. A relative accuracy certification test program was
conducted during this test period on the SO2 monitor. AThe result of the CEM relative accuracy indicated 14.6% which is within the allowable 20%
limit specified in Appendix B - Performance Specification (PS) 2.

EPA methods were followed and sample calculations were conducted for all emissions being tested.  QA/QC documentation is not provided in the
test report except test equipment calibration data which are provided in the appendix.

-------
 Report No.: 9
 Report Title: Evaluation of Sulfur Dioxide, Nitrogen Oxides, and Carbon Monoxide Emissions, Marathon Petroleum Refinery, Detroit, Michigan,
 August 6, 1991
 Docket No.: IV-D-15, Attachment 1
Pollutant
Measured
Exhaust gas
composition
Sulfur dioxide
Nitrogen oxide
Carbon
monoxide
EPA Air
Method
(Stationary
Source)
Method 3
Method 6C
Method IE
Method 10
Deviations
From EPA
Method, If
Any




If Other
Method, List
Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

The purpose of this test was to quantify emissions from the Sulfur Recovery Unit (SRU) Incinerator.  The test report did not provide any data
verification information or quality control results of emissions testing data, or the subsequent interpretation of that data. The text of the report states
the field data sheets are provided in Appendix B. No Appendix B is present. Very little information is reported besides method used and results.
Review of this test report was to include verification that sample data calculations were performed correctly. No sample data calculations are
provided in the test report.

-------
 Report No.: 10
 Report Title:  Results of Nitrogen Oxide and Carbon Monoxide Emissions Testing Conducted on an Unifmer Charge Heater, Marathon Petroleum
 Refinery, Detroit, Michigan, July 19, 1994
 Docket No.: IV-D-15, Attachment 2
Pollutant
Measured
Nitrogen oxide
Carbon
monoxide
EPA Air
Method
(Stationary
Source)
Method 7E
Method 10
Deviations From
EPA Method, If
Any
U.S. EPA NOX and
CO instrument
calibration
procedure
U.S. EPA NOX and
CO instrument
calibration
procedure
If Other
Method,
List Brief
Summary


If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Emission testing was conducted on a Unifier Charge Heater at a Marathon refinery. Nitrogen oxide and carbon monoxide emissions were tested
following EPA Method 7E and Method 10 respectively. Exhaust gas sampling was also conducted to comply with EPA Methods 1-4. According to
section 3.3 of the test report, Quality Assurance/Quality Control guidelines for source sampling were followed during the emission testing. However,
no QA/QC documentation is provided and therefore cannot be verified.
A representative of the Wayne County Air Pollution Control Division (WCAPCD) was on site to observe test procedures.

-------
Modifications were made to the U.S. EPA reference NOX and CO instrument calibration procedure. Two point calibrations using the zero-gas and
137 ppmv gas was performed to enable NOX measurements of concentrations within the range of 0-200 ppmv, and the zero-gas and 448 ppmv gas to
enable CO measurements of concentrations within the range of 0-2000 ppmv.

According to the test report, system bias checks and other quality checks were within the allowable deviation, however raw data is not provided.  And
although cited in the text, no appendices are attached.

-------
 Report No.:  11
 Report Title: Results of Compliance Testing on the Alkylation and Unifmer Flares, Marathon Petroleum Refinery, Detroit Michigan, September 16,
 1996
 Docket No.:  IV-D-15, Attachment 3
Pollutant
Measured
Opacity
Refinery Gas
Compounds
(VOCs by GC)
EPA Air
Method
(Stationary
Source)
Method 22
Method 18
Deviations
From EPA
Method, If
Any


If Other
Method, List
Brief
Summary

UOP Method
539-87
If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
This report is classified:  TIER I

Rating levels are defined as:
TIER I       EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Compliance testing was performed under normal operating conditions on the Alkylation and Unifmer flares to demonstrate compliance with 40CFR
63.lib.

According to the test report, U.S. EPA QA/QC guidelines for source sampling were followed during the tests. No raw data is provided to allow for
verification of this. A mention of a QA/QC check of both field and laboratory data showed that one of the gas samples had "a large amount of
ambient air within the sample". This sample was removed from the calculations for the Net Heating Value.

-------
Review of this test report was to include verification that sample data calculations were performed correctly. However, no sample data calculations
were provided in the test report. None of the appendices cited in the text of the report are provided.  Therefore, no calibration data or field data sheets
are available for review.

-------
 Report No.:  12
 Report Title: Results of Compliance Testing Performed on the Cracking Plant Flare, Marathon Petroleum Refinery, Detroit, Michigan, September
 25, 1996
 Docket No.:  IV-D-15, Attachment 4
Pollutant
Measured
Refinery Gas
Compounds
(VOCs by GC)
Opacity
EPA Air
Method
(Stationary
Source)
Method 18
Method 22
Deviations From EPA
Method, If Any
Molecular weight of
the gas was determined
from gas composition
analysis performed on
collected gas samples-
not Method 3

If Other
Method,
List Brief
Summary
UOP Method
539-87

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
Method
QA/QC
Requirements
Met?
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Compliance testing was performed on a Marathon Cracking Plant flare. EPA Methods 1-4, 18, and UOP Method 539-87 were carried out on the flare
gas.  Opacity was determined by EPA Method 22. Section 2.4 of the test report states that Quality Assurance/Quality Control guidelines were
followed during the test, however no QA/QC documentation is provided and therefore could not be verified. No supporting documentation is
provided for any aspect of testing and all appendices that are cited throughout the text are missing.

-------
Report No.: 13
Report Title: Particulate Emission Compliance Study, FCC Unit-CO Boiler Stack, Mobil Oil Corporation, Joliet, Illinois, August 19, 1996
Docket No.: IV-D-16, Attachment 1
Pollutant
Measured

Particulate
EPA Air
Method
(Stationary
Source)
Methods 1- 5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?

None reported
Method QA/QC
Requirements
Met?

None reported
Sample Data
Calculations
Conducted?

Yes
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

A particulate emission compliance test program was performed on the FCC Unit- CO Boiler Stack at a Mobil Oil refinery in Illinois. The purpose of
the test program was to determine particulate emission rates during normal operating conditions. A representative from the Illinois EPA observed the
tests.

According to the test report, the sampling team enforced a QA Program in order to minimize factors that may cause errors. This included the daily
preparation of reagents and standardization of reagents carried out daily during on-site analysis. According to the test report, all method QA/QC
requirements were met. However, specific QA/QC results were not reported as such and therefore could not be verified. The test meters (dry and
wet) were calibrated according to methods in the Quality Assurance Handbook.

QA/QC documentation is not provided in the test report except test equipment calibration data which are provided in the appendix. Review of this
report included verification that sample data calculations were performed correctly.

-------
Report No.: 14
Report Title: Particulate Emission Compliance Study, Mobil Oil Corporation, Joliet, Illinois, September 20, 1996
Docket No.: IV-D-16, Attachment 2
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
None reported
This report is classified: TIER I

Rating levels are defined as;
TIER I EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II State Agency method (e.g., California), no Method Validation
TIER III Unknown method, no Method Validation, good QA procedures
TIER IV Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Particulate emission testing was conducted on a FCC Unit-CO Boiler Stack of Mobil Oil Corp. EPA Methods 1-5 were performed. According to the
test report, all testing, sampling, analytical, and calibration procedures used for this test program were performed as described in 40 CFR Part 60. No
deviations from U.S. EPA testing procedures were noted. Test equipment calibration data are provided in the appendix of the report. Quality control
procedures for all aspects of field sampling, sample preservation and holding time, reagent quality, analytical method, and instrument cleaning,
calibration, and safety were followed according to the test report, and all method QA/QC requirements were met. However, specific QA/QC results
were not reported as such and therefore could not be verified.

-------
 Report No.: 15
 Report Title: FCC Information Request and Stack Testing Results, Mobil Oil Corporation, Joliet, Illinois, June 18, 1997
 Docket No.: IV-D-16, Attachment 3
Pollutant
Measured
Particulate
Carbon
monoxide
Opacity
EPA Air
Method
(Stationary
Source)
Method 5
Method 10
Method 9
Deviations
From EPA
Method, If
Any



If Other
Method, List
Brief
Summary



If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

A particulate and gaseous emission test program was conducted on the FCC-CO Boiler stack at a refinery in Illinois. The purpose of the test program
was to determine particulate and gaseous emissions during normal operating conditions. Stack testing was conducted using Methods 5, 9, and 10 for
particulates, opacity, and carbon monoxide respectively. U.S. EPA representatives from Region V observed portions of the testing.

According to the test report, all testing, sampling, analytical, and calibration procedures  used for the program were performed as described in 40CFR
60.  No audits were reported. The sampling team enforced a QA Program that included  the daily preparation of reagents, and standardization of
reagents carried out daily during on-site analysis. According to the test report, all method QA/QC requirements were met.  However, specific QA/QC

-------
results were not reported as such and therefore could not be verified. The test meters (dry and wet) were calibrated according to methods in the
Quality Assurance Handbook.

Review of this test report was to include verification that sample data calculations were performed correctly.  No sample data calculations are
provided in the test report. A summary of results calculations are provided but appear to be equations only.

-------
Report No.: 16
Report Title: No. 1 and No. 2 Cat Cracker Stack Participate Emission Testing, Shell Oil Company, Wood River, Illinois, April 7/8, 1992
Docket No.: IV-D-17, Attachment 1
Pollutant
Measured
Participate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If Any

If Other
Method, List
Brief
Summary

Rating levels are based on the following comments and on information found in the report summary table.

Participate emission testing was conducted on two cat cracker precipitate stacks belonging to Shell Oil Co. The purpose of this test was to determine
the degree of compliance with applicable Illinois EPA emission codes. EPA Methods 1-5 were followed and sample calculations were conducted.
The test report states that emission testing was conducted following procedural requirements as detailed in Title 40, Code of Federal Regulations
(40 CFR). According to the test report, all method QA/QC requirements were met. However, specific QA/QC results were not reported as such and
therefore could not be verified. Documentation of all field test data including equipment calibrations, chain of custody, and several supporting
calculations are provided in the appendices.

-------
 Report No.: 17
 Report Title: No. 1 and No. 2 Cat Cracker Stack Participate Emission Testing, Shell Oil Company, Wood River, Illinois, October 27/28, 1992
 Docket No.: IV-D-17, Attachment 2
Pollutant
Measured
Participate
Sulfur oxide
Sulfuric acid
mist
Hydrogen
sulfides
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6
Method 8
Method 15
Deviations
From EPA
Method, If
Any




If Other
Method, List
Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
This report is classified: TIER I

Rating levels are defined as;
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Particulate emission testing was conducted on two cat cracker precipitate stacks belonging to Shell Oil Co. The purpose of this test was to determine
the degree of compliance with applicable Illinois EPA emission codes.  EPA Methods 1-5 were followed and sample calculations were conducted.
In a second attached test report, results of sulfur oxide, sulfuric acid mist, and hydrogen sulfide emission testing on two cat cracker precipitator stacks
are presented.

-------
Both test reports state that emission testing was conducted following procedural requirements as detailed in Title 40, Code of Federal Regulations
(40 CFR). However, there was no description of quality assurance or quality control procedures in the test report. Documentation of all field test
data including equipment calibrations, chain of custody, and several supporting calculations are provided in the appendices.

-------
Report No.: 18
Report Title: No. 1 and No. 2 Cat Cracker Stack Particulate Emission Testing, Shell Oil Company, Wood River, Illinois, January 12/13, 1993
Docket No.: IV-D-17, Attachment 3
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

Particulate emission testing was conducted on two cat cracker precipitate stacks belonging to Shell Oil Co. The purpose of this test was to determine
the degree of compliance with applicable Illinois EPA emission codes. EPA Methods 1-5 were followed and sample calculations were conducted.
The test report states that emission testing was conducted following procedural requirements as detailed in Title 40, Code of Federal Regulations
(40CFR). However, there was no specific mention of quality assurance or quality control procedures in the test report. Documentation of all field
test data including equipment calibrations, chain of custody, and several supporting calculations are provided in the appendices.

-------
Report No.: 19
Report Title: No. 1 and No. 2 Cat Cracker Stack Participate Emission Testing, Shell Oil Company, Wood River, Illinois, February 16/17, 1994
Docket No.: IV-D-17, Attachment 4
Pollutant
Measured
Participate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

A series of emission tests was conducted on two cat cracker precipitator stacks following procedural requirements as detailed in 40CFR. Field test
data and calculation summaries are included in Appendix A. According to the test report, all method QA/QC requirements were met. However,
specific QA/QC results were not reported as such and therefore could not be verified. The report does contain documentation for the calibration of
the instruments, as well as sample chain of custody forms.
Review of this report included verification that sample data calculations were performed correctly.

-------
 Report No.: 20
 Report Title: No. 2 Cat Cracker Formal Particulate Emission Testing, Shell Oil Company, Wood River, Illinois, August 8, 1994
 Docket No.: IV-D-17, Attachment 5
Pollutant
Measured


Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?


None reported
Method QA/QC
Requirements
Met?

None reported
Sample Data
Calculations
Conducted?

Yes
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III    Unknown method, no Method Validation, good QA procedures
TIER IV    Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Particulate emission testing was conducted on a cat cracker precipitator stack at Shell Oil Co. The purpose of this test was to determine the degree of
compliance with applicable Illinois EPA emission codes. EPA Methods  1-5 were followed and sample calculations were conducted. The test report
states that emission testing was conducted following procedural requirements as detailed in Title 40, Code of Federal Regulations (40 CFR).
However, there was no description provided of quality assurance or quality control procedures  in the test report. Documentation of all field test data
including equipment calibrations, chain of custody, and several supporting calculations are provided in the appendices.
There are several values and text purposefully obliterated by ink, that may present a problem (e.g., Sections 1.1, 4.3, Table 1).

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 Report No.: 21
 Report Title: Formal Particulate Emission Testing Fluid Catalytic Cracking Unit ESP Exhaust, UNO-VEN Company, Lemont, Illinois, October 28,
 1993
 Docket No.: IV-D-18, Attachment 1
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Method 1-5
andSF
Deviations
From EPA
Method, If Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

A series of formal particulate emission tests were conducted on the outlet of the electrostatic precipitator associated with the FCCU. According to the
test report, emission test methods followed those detailed in 40CFR 60. The purpose of this test series was to determine the concentration and
emission rate of total particulate exhausting from the ESP outlet for compliance with permitted levels specified by Illinois EPA.

There was no description provided of quality assurance, quality control, or audit procedures in the test report. Documentation of all field test data
including equipment calibrations, chain of custody, and several supporting calculations are provided in the appendices.
Review of this report included verification that sample data calculations were performed correctly.

-------
 Report No.: 22
 Report Title: Report of Paniculate, CO, and SO2 Testing on the CO Boiler of the FCCU, UNO-YEN Company, Lemont, Illinois, December 22, 1994
 Docket No.:  IV-D-18, Attachment 2
Pollutant
Measured
Participate
Sulfur dioxide
Carbon
monoxide
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6
Method 10
Deviations
From EPA
Method, If
Any



If Other
Method, List
Brief
Summary



If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
None reported
This report is classified:  TIER I /data suspect

Rating levels are defined as:
TIER I       EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

This report contains results from particulate, sulfur dioxide, and carbon monoxide testing on a FCCU unit. EPA Methods 1-5, 6, and 10 were
followed respectively.  Although equipment calibration data and sample calculations are provided, it is stated that the results are inaccurate due to
problems with the stack test and are an inaccurate reflection of emissions from the stack. This complete data package should be considered suspect.

-------
 Report No.: 23
 Report Title:  Fluidized Catalytic Cracking Unit CO Boiler Emissions Testing Results, UNO-YEN Company, Lemont, Illinois, May 24, 1995
 Docket No.: IV-D-18, Attachment 3
Pollutant
Measured
Participate
Sulfur
dioxide
Carbon
monoxide
Opacity
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6
Method 10
Method 9
Deviations
From EPA
Method, If
Any




If Other
Method, List
Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
Yes
None reported
None reported
Method QA/QC
Requirements
Met?
See below
See below*
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

This test report was the result of an information request from U.S. EPA Region 5 to conduct particulate, sulfur dioxide, and carbon monoxide
emission testing for a fluid catalytic cracking unit (FCCU) at an Illinois refinery.

All calibration gases used were certified EPA Protocol #1. Calibration gas certifications are provided in appendix C. All equipment used for the
tests were calibrated according to procedures detailed in the EPA Quality Assurance Handbook for Air Pollution Measurement Systems - Volume III
- Stationary Source Specific Methods. Copies of chain of custody forms, laboratory QC data, and field data sheets  are provided in the appendices.

-------
The program included the collection of field and reagent blanks and an audit sample for SO2 analysis. The results of the blanks and audit sample are
presented on page 4-2 of the report. It is not stated specifically whether these QC samples meet acceptance criteria*.

Review of this test report was to include verification that sample data calculations were performed correctly.  No sample data calculations are
provided in the test report.  Emission calculation summaries are provided but appear to be equations only.

-------
 Report No.: 24
 Report Title: 112P-2 Particulate Emissions Results Report, UNO-YEN Company, Lemont, Illinois, February 5, 1996
 Docket No.: IV-D-18, Attachment 4
Pollutant
Measured
Particulate
Opacity
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 9
Deviations
From EPA
Method, If
Any


If Other
Method, List
Brief
Summary


If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
Method
QA/QC
Requirements
Met?
See below
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Particulate measurements and opacity readings were conducted on the CO Boiler exhaust of a FCC unit. The purpose of the testing was to quantify
the emission rates of particulate matter and determine opacity from the exhaust to determine compliance with applicable limitations set forth in the
facility's construction permit. Particulate measurements followed EPA Methods 1-5, while opacity readings were collected by EPA Method 9. A
representative from the Illinois  Environmental Protection Agency was present during the testing.  Sample equations are provided in Appendix A,
however no sample data calculations are provided.

Per the test report, equipment used for the stack test program was calibrated in accordance with the appropriate sampling method and the procedures
listed in the EPA Quality Assurance Handbook for Air Pollution Measurement Systems -  Volume III - Stationary Source Specific Methods.
According to the test report, pre and post calibrations were within allowable errors.  All equipment calibration data is provided in Appendix E.

-------
A field audit was performed of the dry gas meter with a result of 3.5%. Sample chain of custody procedures were followed and chain of custody
forms are provided in the appendix of the report. Results of filter and train blanks are provided in section 5.3 of the text.

-------
Report No.: 25
Report Title: Source Test Report Particulate Matter Emissions Results, Clark Oil and Refining Corporation, Hartford, Illinois, November 19, 1993
Docket No.: IV-D-19, Attachment 1
Pollutant
Measured

Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?

None reported
Method QA7QC
Requirements
Met?

None reported
Sample Data
Calculations
Conducted?

Yes
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

The purpose of this test was to conduct compliance emission testing for particulate matter (PM) from the fluid catalytic cracking unit (FCCU) stack
of a facility in Illinois. The PM testing of the source was performed in accordance with U.S. EPA methods 1-5.

According to the test report, all method QA/QC requirements were met. However, specific QA/QC results were not reported as such and therefore
could not be verified. A detailed outline of all methods used is contained within the report. Calibration data and chain of custody data are also
contained within the report. Review of this test report included verification that sample data calculations were performed correctly. Sample data
calculations are provided in appendix B.

-------
Report No.: 26
Report Title: Source Test Report Particulate Matter Emissions Results, Clark Oil and Refining Corporation, Hartford, Illinois, March 1994
Docket No.: IV-D-19, Attachment 2
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
Was Audit
Conducted?
None reported
Method
QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

Particulate emissions were measured from a FCCU stack owned by Clark Oil and Refining Corporation. The Particulate Matter testing of the source
was performed in accordance with U.S. EPA methods. Three 1-hour test runs were performed at or near maximum load on the source.

Representatives from the Illinois EPA were present during the test program. Sample calculations were conducted and are provided with complete
field test data in the appendices of the test report. Documentation for quality assurance/quality control procedures that were conducted during the test
are also provided in the appendices of the report (e.g., chain of custody, equipment calibration worksheets) and appear complete.

Final leak checks and other field QC checks were reported to be within the guidelines outlined in U.S. EPA Method 5.

-------
Report No.: 27
Report Title: Total Particulate Matter and Particle Size Distribution FCC Stack, Clark Oil Refining Corporation, Hartford, Illinois, March 11, 1994
Docket No.: IV-D-19, Attachment 3
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

The purpose of this test was to conduct compliance air emissions testing on the FCC unit and included three 1-hour test runs.  The air emissions
testing included total particulate matter testing and particle size distribution analysis. It is stated that all emissions testing was conducted following
the procedures outlined in 40 CFR 60, Appendix A. Review of this report included verification that sample data calculations were performed
correctly. The following QA/QC documentation is provided in the appendices of the test report: field data sheets, laboratory data, equipment
calibration records, and sample calculations. No audit procedures were reported.

Particle size distribution analysis was conducted from the particulate collected on the Method 5 filter. The analysis was conducted using the Elzone18
analysis technique (Micromeritics Instrument Corporation). The Elzone analyzer counts and sizes the pulses that occur when particles in an
electrolytic solution pass through an orifice tube (negative electrode).

-------
Report No.: 28
Report Title: Confirmation of Information Emission Test Report, Clark Oil and Refining Corporation, Hartford, Illinois, April 1994
Docket No.: IV-D-19, Attachment 4
Pollutant
Measured
Paniculate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

Rating levels are based on the following comments and on information found in the report summary table.

A representative from the Illinois EPA was present during the test program. Sample calculations were conducted and are provided with complete
field test data in the appendices of the test report. Documentation for quality assurance/quality control procedures that were conducted during the test
are also provided in the appendices of the report (e.g., chain of custody, equipment calibration worksheets) and appear complete.
Final leak checks and other field QC checks were reported to be within the guidelines outlined in U.S. EPA Method 5.

-------
 Report No.: 29
 Report Title: Confirmation of Information Emission Test Report FCCU, Clark Oil and Refining Corporation, Hartford, Illinois, December 20, 1994
 Docket No.: IV-D-19, Attachment 5
Pollutant
Measured
Participate
Sulfur dioxide
Carbon
monoxide
Oxygen
Carbon dioxide
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6C
Method 10
Method 3
Method 3A
Deviations
From EPA
Method, If
Any





If Other
Method, List
Brief
Summary





If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
Yes
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

The purpose of this test program was to conduct emission testing programs for oxygen, carbon dioxide, sulfur dioxide, carbon monoxide, and
particulate matter from the FCCU stack of a facility in Illinois.  Three 1-hour test runs were performed at or near maximum load on the source.  It is
stated in the test report that all methods were performed in accordance with U.S. Environmental Protection Agency (U.S. EPA) methodology.

Stack gas emissions of carbon dioxide, oxygen, sulfur dioxide, and carbon monoxide from the source were measured with continuous emission
monitors. Sample calculations were conducted and are provided with complete field test data in the appendices of the test report. Review of this
report included verification that sample data calculations were performed correctly. Documentation for quality assurance/quality control procedures

-------
that were conducted during the test are also provided in the appendices of the report (e.g., chain of custody, equipment calibration worksheets) and
appear complete.

Final leak checks and other field QC checks were reported to be within the guidelines outlined in U.S. EPA Method 5.

-------
Report No.: 30
Report Title: Source Emission Testing for Particulate Matter Size Distribution, Clark Oil and Refining Corporation, Hartford, Illinois, April 12, 1996
Docket No.: IV-D-19, Attachment 6
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

Rating levels are based on the following comments and on information found in the report summary table.

Particulate emissions were measured from a FCCU stack owned by Clark Oil and Refining Corporation. The particulate matter testing of the soi
was performed in accordance with U.S. EPA methods. Two 1-hour test runs were performed at or near maximum production load on the source.

Sample calculations were conducted and are provided with complete field test data in the appendices of the test report. Documentation for quality
assurance/quality control procedures that were conducted during the test are also provided in the appendices of the report (e.g., chain of custody,
equipment calibration worksheets) and appear complete.

Final leak checks and other field QC checks were reported to be within the guidelines outlined in U.S. EPA Method 5.
source

-------
Report No.: 31
Report Title: Source Emissions Testing for Particulate Matter, Clark Oil and Refining Corporation, Hartford, Illinois, May 1, 1996
Docket No.: IV-D-19, Attachment 7
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1- 5
Deviations
From EPA
Method, If Any

If Other
Method, List
Brief
Summary

Rating levels are based on the following comments and on information found in the report summary table.

The purpose of this test program was to conduct in-house emission tests for total particulate matter (PM) from the FCCU stack at a facility in Illinois.
All tests were performed in accordance with U.S. EPA methodology. Three 1-hour test runs were performed at or near maximum production load.

Sample calculations were conducted and are provided with complete field test data in the appendices of the test report. Review of this report included
verification that sample data calculations were performed correctly. Documentation for quality assurance/quality control procedures that were
conducted during the test are also provided in the appendices of the report (e.g., chain of custody, equipment calibration worksheets) and appear
complete.
Final leak checks and other field QC checks were reported to be within the guidelines outlined in U.S. EPA Method 5.

-------
 Report No.: 32
 Report Title: Source Emissions Testing Report FCCU, Clark Oil and Refining Corporation, Hartford, Illinois, June 27, 1996
 Docket No.:  IV-D-19, Attachment 8
Pollutant
Measured
Particulate
Sulfur dioxide
Carbon
monoxide
Carbon dioxide
Oxygen
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6 C
Method 10
Method 3A
Method 3
Deviations
From EPA
Method, If
Any





If Other
Method, List
Brief
Summary





If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
None reported
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Emission testing was conducted on a FCCU stack at a Clark Oil Facility. Emissions were determined for oxygen, carbon dioxide, particulate, sulfur
dioxide and carbon monoxide.  EPA Methods 3, 3A, 5, 6C and 10 were performed respectively. Calculations were conducted and provided in the

-------
report for each pollutant tested. There was no reference as to whether quality assurance/quality control requirements were met.  Chain of custody
procedures were used to document sample handling. Test equipment data are provided in the appendix of the report.

Ancillary data collected includes particle size distribution by Polarized Light Microscopy (PLM).

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Report No.: 33
Report Title: Source Emissions Testing for Particulate Size Distribution, Clark Oil and Refining Corporation, Hartford, Illinois, August 5, 1996.
Docket No.: IV-D-19, Attachment 9
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
None Reported
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

Emission tests for particulate matter (PM) size distribution from the FCCU stack at a Clark Oil facility located in Illinois were conducted using U.S.
EPA Method 5 sample train to collect total particulate matter on glass fiber filters. Three 30-minute test runs were performed at or near maximum
production load. Field test data, laboratory data, and chain of custody forms are provided in the appendices of the test report. Filter samples were
sent to the RJ Lee Group, Inc., for particle size distribution. Particle size distributions were determined using computer-controlled scanning electron
microscopy techniques.

Review of this report was to include verification that sample data calculations were performed correctly. However, no sample data calculations were
provided in the test report. Copies of the field data sheets are included, along with charts of data results (see appendix B). No audits were conducted
during emission testing. According to the test report, all method QA/QC requirements were met. However, specific QA/QC results were not
reported as such and therefore could not be verified.

-------
Report No.: 34
Report Title: Source Emissions Compliance Testing Report for PM, SO2, FCCU, Clark Oil and Refining Corporation, Hartford, Illinois, August 7,
1996
Docket No.: IV-D-19, Attachment 10
Pollutant
Measured
Particulate
Carbon dioxide
Sulfur dioxide
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 3A
Method 6C
Deviations
From EPA
Method, If
Any

If Other
Method,
List Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

Emission testing was conducted on a FCC unit located at a Clark Oil facility. Emissions were tested for carbon dioxide, particulate matter, and sulfur
dioxide. EPA Methods 3A, 5 and 6C were followed respectively. The O2 and CO2 testing were performed to correct the SO2 reading for the
quenching factor.

Sample data calculations were performed for each pollutant measured. According to the test report, all method QA/QC requirements were met.
However, specific QA/QC results were not reported as such and therefore could not be verified. Final leak checks and other field QC checks were
reported to be within the guidelines outlined in U.S. EPA Method 5.

QA/QC documentation such as field test data sheets, equipment calibration records, chain of custody forms, and calibration gas certificates are
provided in the appendices of the test report and appear complete.

-------
 Report No.:  35
 Report Title:  Emission Compliance Test Program FCCU CO Boiler Stack, Marathon Oil Company, Robinson, Illinois, May 12, 1993
 Docket No.: IV-D-20, Attachment 1
Pollutant
Measured
Particulate
Sulfur dioxide
Nitrogen oxide
Carbon
monoxide
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6C
Method 7E
Method 10
Deviations
From EPA
Method, If
Any




If Other
Method,
List Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

An emission compliance test program was conducted on the FCCU CO Boiler stack at a Marathon Oil refinery located in Illinois.  Specifically,
compliance testing was conducted for particulate, sulfur dioxide, nitrogen oxides, and carbon monoxide at the exhaust stack location.  According to
the test report, test methods followed those as detailed  in 40CFR, Part 60, Appendix A; EPA Methods 1-5, 6C, 7E and 10.

A representative from the Illinois EPA was present to observe the test series.

Review of this report included verification that sample data calculations were performed correctly. According to the test report, all method QA/QC
requirements were met. However, specific QA/QC results were not reported as such and therefore could not be verified. QC documentation such as

-------
field test data sheets, QA/equipment calibration records, chain of custody forms, and calibration gas certificates are provided in the appendices of the
test report and appear complete.

-------
 Report No.:  36
 Report Title: Emission Compliance Test Program FCCU CO Boiler Stack, Marathon Oil Company, Robinson, Illinois, August 4/5, 1993
 Docket No.:  IV-D-20, Attachment 2
Pollutant
Measured
Particulate
Sulfur dioxide
Nitrogen oxides
(as NO2)
Opacity
Carbon
monoxide
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6C
Method 7E
Method 9
Method 10
Deviations
From EPA
Method, If
Any





If Other
Method,
List Brief
Summary





If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
None reported
Yes
This report is classified:  TIER I

Rating levels are defined as;
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Emission testing was conducted on a FCCU Boiler exhaust stack at a refinery located in Illinois.  Emissions tested included  particulate, sulfur
dioxide, nitrogen oxides (as NO2), opacity and carbon monoxide. Test methods followed those as detailed in 40CFR, Part 60, Appendix A; EPA
Methods 1-5, 6C,  7E, 9, and 10. The test series was conducted under the following conditions: runs 1 and 3 each encompassed normal soot blowing,
runs 2 and 4 each  encompassed normal FCCU CO boiler operation, and runs 5 and 6 each encompassed modified soot blowing.
Representatives of the Illinois EPA were present to observe the test series.

-------
Sample data calculations are provided in Appendix A.  According to the test report, all method QA/QC requirements were met. However, specific
QA/QC results were not reported as such and therefore could not be verified. QC documentation such as field test data sheets, equipment calibration
records, chain of custody forms, and calibration gas certificates are provided in the appendices of the test report and appear complete.

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 Report No.: 37
 Report Title: Particulate Emission Characterization Test Program FCCU CO Boiler Stack, Marathon Oil Company, Robinson, Illinois, March 9/10,
 1994
 Docket No.: IV-D-20, Attachment 3
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER HI     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

An emission characterization test program was performed on the FCCU CO Boiler exhaust stack at a refinery located in Illinois.  All methods were
performed according to CFR40, Part 60, EPA Methods 1-5, the TNRCC Sampling and Laboratory Procedures Manual, and the Quality Assurance
Handbook for Air Pollution Measurement Systems, Volume III, Stationary Source Specific Methods.  Total particulate, non-sulfate, and PMIO (less
than 10 n particulate) emission rates in Ibs/hr were calculated for each run and particle size distribution analysis was conducted using the Elzone®
analysis technique (Micromeritics Instrument Corporation). The Elzone® analyzer counts and sizes the pulses that occur when particles in an
electrolytic solution pass-through an orifice tube (negative electrode).

Review of this report included verification that sample data calculations were performed correctly. QA/QC results were not reported and therefore
could not be verified. QC documentation such as field test  data sheets, equipment calibration records, and chain of custody forms are provided in the
appendices of the test report and appear complete.

-------
Report No.:  38
Report Title:  Particulate Emission Compliance Test Program FCCU CO Boiler Stack, Marathon Oil Company, Robinson, Illinois, June 27, 1994
Docket No.: IV-D-20, Attachment 4
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
Deviations
From EPA
Method, If Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes
This report is classified: TIER I

Rating levels are defined as;
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Emissions testing was conducted on the FCCU CO Boiler at a refinery in Illinois for demonstration of compliance with the particulate emission
standard. Particulate emission testing was conducted following EPA Methods 1-5. Representatives of the Illinois EPA and a representative of the
U.S. EPA were present to observe the test series. The test series was conducted under the following conditions: runs 1 and 2 each encompassed
normal operation and run 3 encompassed soot blowing.

Sample data calculations and process data are provided in the appendices of the test report.  Specific QA/QC results were not reported and therefore
could not be verified.  QC documentation such as field test data sheets, equipment calibration records, and chain of custody forms are provided in the
appendices of the test report and appear complete.

-------
Report No.:  39
Report Title:  Particulate Emission Compliance Test Program FCCU CO Boiler Stack, Marathon Oil Company, Robinson, Illinois, August 9, 1994
Docket No.: IV-D-20, Attachment 5
Pollutant
Measured
Particulate
Opacity
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 9
Deviations
From EPA
Method, If
Any


If Other
Method, List
Brief
Summary


If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

A particulate emission compliance test program was performed on the FCCU CO Boiler stack at a refinery located in Illinois. A continuous soot
blowing system was installed prior to this test program and was operational during the particulate testing. Three 60-minute runs were conducted to
determine total particulate emission rates and visible emissions.  Test methods followed those as detailed in the CFR40, Part 60, Appendix A; EPA
Methods 1-5 and 9. Representatives of the Illinois EPA were present to observe the test series.

Review of this report included verification that sample data calculations were performed correctly. Specific QA/QC results were not reported and
therefore could not be verified. QC documentation such as field test data sheets, equipment calibration records, and chain of custody forms are
provided in the appendices of the test report and appear complete.

-------
 Report No.:  40
 Report Title: Emission Compliance Test Program FCCU CO Boiler Stack, Marathon Oil Company, Robinson, Illinois, March 14, 1995
 Docket No.: IV-D-20, Attachment 6
Pollutant
Measured
Particulate
Sulfur dioxide
Carbon
monoxide
Opacity
Oxygen
EPA Air
Method
(Stationary
Source)
Methods 1-5
Method 6C
Method 10
Method 9
Method 3
Deviations
From EPA
Method, If
Any





If Other
Method, List
Brief
Summary





If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
None reported
None reported
This report is classified:  TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

This test summary includes data from emission testing on a FCCU CO Boiler stack as well as emission sampling from a FCCU Regenerator Duct.
Emissions testing conducted on the boiler stack included particulate, sulfur dioxide, and carbon monoxide. Sampling of carbon dioxide, carbon
monoxide, and oxygen were conducted on the Regenerator Duct and used to calculate the material balance over the CO Boiler.  A continuous soot
blowing system installed on the CO Boiler was operational during the emission testing.  Representatives of the Illinois EPA were present to observe
the test series.

-------
Test methods followed those as detailed in 40CFR, Part 60, Appendix A; U.S. EPA Methods 1-5, 6C, 9, and 10 and the Quality Assurance Handbook
for Air Pollution Measurement Systems, Volume III, Stationary Source Specific Methods.

Review of this report included verification that sample data calculations were performed correctly. According to the test report, all method QA/QC
requirements were met.  However, specific QA/QC results were not reported as such and therefore could not be verified. QC documentation such as
field test data sheets, equipment calibration records, chain of custody forms, and calibration gas certificates are provided in the appendices of the test
report and appear complete.

-------
 Report No.: 41
 Report Title: Superior Refinery FCCU Stack Test Reports, Murphy Oil, USA, Incorporated, Superior, Wisconsin, January 1995
 Docket No.:  IV-D-21, Attachment 1
Pollutant
Measured
Particulate
Sulfur dioxide
Nitrogen
oxides
Total VOC
Nickel
Formaldehyde
Ammonia
Polycyclic
Organic Matter
EPA Air
Method
(Stationary
Source)
Methods 1-5
andSF
Method 6C
Method 7E
Method 25A
with THC
Analyzer
Method 29 with
ICP



Deviations
From EPA
Method, If
Any






If Other
Method, List
Brief
Summary





Method 00 11
(SW-846)
Sampling train was similar to
U.S. EPA Method 5 and analysis
was performed by HPLC
Method 23 with
HPLC

If Not EPA
Method,
Validation By
Method 301?
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
None reported
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
This report is classified: TIER I

Rating levels are defined as:

-------
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

A comprehensive emission compliance test program was conducted on the FCCU ESP exhaust stack at a refinery located in Wisconsin. Test methods
followed those as detailed in the 40CFR, Part 60, U.S. EPA Methods 1 - 4, 5/5F, 6C, IE, 23, 25A, and 29, 40CFR, Part 266, Method 0011, SW-846
Method 0010 (Modified Method 5) and the Wisconsin DNR test methods and procedures described in NR440 and NR445. A representative of the
Wisconsin Department of Natural Resources (DNR) was present to observe the test series.

Review of this report included verification that sample data calculations were performed correctly. According to the report, all method QA/QC
requirements were met. However, specific QA/QC results were not reported as such and therefore could not be verified.  Comprehensive QC
documentation including field test data sheets, equipment calibration records, chain of custody forms, standard certificates of analysis, and calibration
gas certificates are provided in the appendices of the test report and appear complete.

-------
Report No.: 42
Report Title: Particulate Emissions Test Program FCCU-ESP Exhaust Stack, Murphy Oil, USA, Incorporated, Superior, Wisconsin, November 20,
1996
Docket No.: IV-D-21, Attachment 2
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
andSF
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

Rating levels are defined as;
TIER I EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II State Agency method (e.g., California), no Method Validation
TIER HI Unknown method, no Method Validation, good QA procedures
TIER IV Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

An informal emission test was conducted on a FCCU-ESP Exhaust stack. Particulate emissions were sampled using EPA Method 5 and samples
were analyzed by EPA Methods 5 and 5F to determine total particulates and non-sulfate particulates respectively. Test methods followed the
requirements in 40CFR, Part 60, Appendix A; U.S. EPA Methods 1-4, 5, and 5F as well as the Quality Assurance Handbook for Air Pollution
Measurement Systems; Volume III, Stationary Sources Specific Methods. Specifically, analysis of the front half particulate was conducted with U.S.
EPA Method 5 and 5F to determine the total particulate and non-sulfate particulate. The back half impinger catch was analyzed for particulate in
accordance with the Wisconsin DNR procedures for total back half particulate determination.

Extensive sample data calculations are provided in the appendix of the test report. Specific QA/QC results were not reported and therefore could not
be verified. However, QC documentation such as field test data sheets and equipment calibration records are provided in the appendices of the test
report and appear complete.

-------
Report No.:  43
Report Title: Particulate Emission Compliance Test Program FCCU ESP Exhaust Stack, Murphy Oil, USA, Incorporated, Superior, Wisconsin,
August 20, 1997
Docket No.:  IV-D-31, Attachment 3
Pollutant
Measured
Particulate
EPA Air
Method
(Stationary
Source)
Methods 1-5
andSF
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
None reported
Sample Data
Calculations
Conducted?
Yes, see below
This report is classified: TIER I
Rating levels are defined as;
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

A formal particulate emission compliance test program was conducted on the FCCU ESP stack at a refinery located in Wisconsin. Test methods
followed the requirements specified in the 40CFR, Part 60, 1996, Appendix A, U.S. EPA Methods 1-4 and 5/5F, the Quality Assurance Handbook for
Air Pollution Measurements Systems; Volume III, Stationary Sources Specific Methods and the Wisconsin DNR test methods and procedures
described in NR 415 and NR 440.

Review of this report was to include verification that sample data calculations were performed correctly. However, the value for A. was not reported,
making the calculations and results impossible to verify.  QC documentation such as field test data sheets, equipment calibration records, and
calibration gas certificates are provided in the appendices of the test report and appear complete.

-------
 Report No.: 44
 Report Title: Stack Emissions Test, Coastal Eagle Point Oil Company, Westville, New Jersey, August 15, 1996 and December 11, 1996
 Docket No.: IV-D-51
Pollutant
Measured
Particulate
Sulfur oxides
(as SO2)
SO3 & H2SO4
(as H2SO4)
Nitrogen
oxides (as
N02)
Carbon
monoxide
Non-methane
hydrocarbons
Benzene
Ammonia
Cyanide
EPA Air
Method
(Stationary
Source)
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Deviations
From EPA
Method, If
Any









If Other
Method, List
Brief
Summary







•N

If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
This report is classified: TIER IV

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation

-------
TIER III    Unknown method, no Method Validation, good QA procedures
TIER IV    Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

The purpose of this test was to compare emissions from a FCC unit to the allowable emissions given from a referenced permit.  Emissions listed
included particulate, sulfur oxides, sulfuric acid mist, nitrogen oxides, carbon monoxide, total non-methane hydrocarbons, benzene, ammonia, and
cyanide.  Results of nitrogen oxide emissions were found to have exceeded allowable limits. There was no report of which methods were used nor of
any quality assurance/quality control procedures being carried out.

No QA/QC documentation such as field test data sheets, equipment calibration records, chain of custody forms, or calibration gas certificates are
provided.

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Report No.: 45
Report Title: Evaluation Test Report: Determination of Emissions from the No. 3 Reformer at Tosco Refining, San Francisco, California, February
26, 1999
Docket No.:  IV-D-62
Pollutant
Measured
Carbon dioxide
Carbon monoxide
Nitrogen oxides
Sulfur dioxide
Total
hydrocarbons
Oxygen
EPA Air
Method
(Stationary
Source)






Deviations
From EPA
Method, If
Any






If Other Method,
List Brief Summary
CARB Method 100-
Nondispersive infra-
red (NDIR)
CARB Method 100-
Gas filter correlation
(NDIR)
CARB Method 100-
Chemiluminescence
CARB Method 100-
Ultraviolet
photometry
CARB Method 100-
Flame ionization
detector
CARB Method 100-
Paramagnetic
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
None reported
None reported
Was Audit
Conducted?
Yes
Yes
Yes
Yes
Yes
Yes
Method QA/QC
Requirements
Met?
See below
See below
See below
See below
See below
See below
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
Yes
Yes

-------
Pollutant
Measured
PCDD/PCDF



Polychlorinated
biphenyls (PCBs)
Polycyclic
aromatic
hydrocarbons
(PAHs)
EPA Air
Method
(Stationary
Source)
Method 23



Method 23


Deviations
From EPA
Method, If
Any
Continuous
sampling
according to
CARS
Method 100
for stack gas
molecular
weight
See below*


If Other Method,
List Brief Summary
HRGC/HRMS



HRGC/HRMS
GARB Method 429
with HRGC/HRMS

If Not EPA
Method,
Validation By
Method 301?
None reported



None reported
None reported

Was Audit
Conducted?
Yes



Yes
Yes

Method QA/QC
Requirements
Met?
See below



See below
See below

Sample Data
Calculations
Conducted?
Yes



Yes
Yes

This report is classified: TIER II

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER HI     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

The California Air Resources Board (CARB) conducted emissions tests at a catalytic reforming unit at a refinery located in San Francesco. The
source test was the second in a series of tests to collect emissions data to supplement the existing HAP emissions data for refinery processes.

QA/QC procedures include several different types of blanks, including trip blanks, method blanks, etc. There were also cleaning and contamination
checks to limit possible contamination from glassware, filters and resin. Isokinetic sampling was kept at 100 ± 10% for all sampling trains, and leak

-------
checks were all within allowed levels. Surrogate, internal, and alternate standard recoveries were used to determine both levels within samples and
the ability of the resin to both sample and then retain the target analytes. Finally, laboratory control samples (LCS) were created to test recoveries,
and all recoveries were within the 100 + 50% range (for pollutants-PCDD/PCDF, PCBs, PAHs). A performance evaluation sample (PE) was also
sent by the EPA to the lab, and the results have been submitted to the EPA (pg. 62-78).

Review of this report included verification that sample data calculations were performed correctly. QC documentation such as field test data sheets,
equipment calibration records, chain of custody forms, and calibration gas certificates are provided in the appendices of the test report and appear
complete. Extensive charts of all the results from both continuous sampling and calculation results are provided.

Target PAH analytes: naphthalene, 2-methylnaphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene, anthracene, fluoranthene, pyrene,
benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(e)pyrene, benzo(a)pyrene, perylene, indeno(l,2,3-cd)pyrene,
dibenzo(a,h)anthracene, benzo(ghi)perylene.

*Minor method modifications were necessary to determine PCBs in the same sample and to meet the ARB Method 428 reporting requirements for
the target compounds (dioxins and furans).

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 Report No.: 46
 Report Title: Emission Test Report, Marathon Ashland Petroleum LLC, Garyville, Louisiana, January 1, 1998 through June 30, 1998
 Docket No.: IV-J-5
Pollutant
Measured
Total particulate
hazardous air
pollutants (HAP)
Weighted
particulate
hazardous air
pollutants
Total gaseous
hazardous air
pollutants
Weighted gaseous
hazardous air
pollutants
EPA Air
Method
(Stationary
Source)
Not given
Not given
Not given
Not given
Deviations
From EPA
Method, If
Any




If Other
Method, List
Brief
Summary




If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
Was Audit
Conducted?
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
See discussion below for details of emissions reported.

This report is classified:  TIER IV

Rating levels are defined as:
TIER I       EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

-------
This test report is the second semiannual report of emissions for 1998 at a Marathon Ashland Louisiana refinery which is required under their early
reductions specialty permit. A summary of the total actual HAP emissions as well as the established Alternate Emission Limit (AEL) are provided in
the report. The procedures used to determine emissions from each emission unit are not provided, however the emission results are summarized in
the appendices of the report.

The following permit items were in compliance during the testing period (first half of 1998) according to the report: dock flow meters; MVC infrared
detector; MVC color camera; vapor tightness; MVC annual leak test; PCE injection meter; FCCU catalysts metals analyses; and continuous
monitoring of FCCU  scrubber performance parameters.

FCCU vent pollutants measured: arsenic; chromium; mercury; nickel; cadmium; lead; selenium.

Speciated particulate emissions reported: arsenic; barium; cadmium; chromium; copper; lead; mercury; nickel; selenium; silver; vanadium; zinc.

Platformer regenerator vent pollutants measured: HC1 and C12.

Stack test data reported: catalyst regeneration rate; perchloroethylene injection rate; HC1 emission rate; C12 emission rate.

Marine and barge loading operations emissions reported: n-hexane; benzene; toluene; ethylbenzene; xylene; 2,2,4-trimethylpentane; cresols;
naphthalene.

Shipments made  over the docks by barge and ship were reported in barrels with marine loading emission factors. In addition, semiannual loading
emissions were reported for gasoline (ship/barge), fuel oil, turbine  fuel, kerosene, platformate, naphtha, cracking stock, n-butane, i-butane, asphalt,
and alkylates.

Lastly, speciated  VOC emissions contributed by product loading was reported for 24 VOCs.  QA/QC results were not reported and therefore could
not be verified.

-------
Report No.: 47
Report Title: RCRA Trial Burn Report for CO Boiler No. 1 at the Shell Oil Manufacturing Complex, Martinez, California, April 1989 (Revised
October 1989)
Docket No.: IV-J-8
Pollutant
Measured
Toluene feed
Toluene
Benzene
Particulate
Carbon
monoxide
Carbon dioxide
Oxygen
Total unbumed
hydrocarbons
Van condensate
Probe wash/
condensate
Metals (stack
gas)
EPA Air
Method
(Stationary
Source)

Method 1 8
Method 18
Methods 1-5
Method 10
Method 3A
Method 3A
Method 25A
Method 6C

Method 5
Deviations
From EPA
Method, If
Any











If Other
Method, List
Brief
Summary
Method S004
Method 80 15
(SW-846)







Method 602
(SW-846)
Method 602
(SW-846)
Method 3050
(SW-846)
If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
Yes
Audit cylinder
AAL- 17620
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Sample Data
Calculations
Conducted?
Yes
Yes
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Metals (waste
liquid feed)
EPA Air
Method
(Stationary
Source)

Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief
Summary
Method S004
Method 3050A
(SW-846)
If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
Yes, see below
Sample Data
Calculations
Conducted?
None reported
This report is classified: TIER I

Rating levels are based on the following comments and on information found in the report summary table.

This test report contains the results of a trial burn conducted for the Shell Oil catalytic cracker CO boiler system over a 3-4 week time period in 1989.
This trial burn was to support an operating permit application under RCRA. The tests were designed to demonstrate that the boiler met the
performance requirements of RCRA. The trial burn was performed under the regulatory authority of the California Department of Health Services and
Region IX of the U.S. EPA.

The report states that QA/QC procedures were in accordance with EPA protocols. The report contains a detailed explanation of the QA/QC
procedures that were enacted in the analytical portion of the study including trip blanks, storage blanks, laboratory blanks, duplicate and spike
recovery analysis. An audit analysis was performed for the onsite GC/PID. QC documentation such as field test data, equipment calibration records,
and chain of custody forms are listed in the table of contents but not appended to the test report.

ASamples were prepared using Method 3050 and depending on the metals species, SW-846, Method 6010, 7041, 7060, 7420, 7470, 7740, or 7841 was
used for analysis. Metals measured in stack gas particulate: aluminum; antimony; arsenic; barium; beryllium; cadmium; chromium; cobalt; copper;
iron; lead; manganese; nickel; selenium; silver; sodium; thallium; vanadium; zinc.

Review of this report was to include verification that sample data calculations were performed correctly. However, no verifiable sample data
calculations were provided in the test report.

-------
Report No.: 48
Report Title: RCRA Trial Bum Report for CO Boiler No. 2 at the Shell Oil Manufacturing Complex, Martinez, California, November 1991
Docket No.: IV-J-12
Pollutant
Measured
Waste Liquid
Feed:
Flow
Heating value
Ash, % by
weight
Viscosity
Water, % by
weight
Organic phase,
%w
Ultimate
analysis
Metals*:
Antimony
EPA Air
Method
(Stationary
Source)









Deviations
From EPA
Method, If
Any









If Other Method,
List Brief
Summary
EPA 625/6-89/021
ASTM D 240 87
EPA S004 and
EPA 600/8-84-
0023
ASTM D482-87
EPA S004
ASTM D 445-88
EPA S004
ASTM D 428 1-83
EPA S004
ASTM D 428 1-83
EPA S004
ASTM D 3 178-84,
ASTM D 3 179-84,
ASTM D 3 174-88
EPA S004
EPA S004, EPA
SW-846 3040
EPA SW-846
7041
If Not EPA
Method,
Validation By
Method 301?
EPA Method
None reported
None reported
None reported
None reported
None reported
None reported
EPA Method
EPA Method
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Molybdenum
Nickel „
Selenium
Silver
EPA Air
Method
(Stationary
Source)












Deviations
From EPA
Method, If
Any












If Other Method,
List Brief
Summary
EPA SW-846
7060
EPA SW-846
6010
EPA SW-846
6010
EPA SW-846
6010
EPA SW-846
6010
EPA SW-846
6010
EPA SW-846
7421
EPA SW-846
7471
EPA SW-846
6010
EPA SW-846
6010
EPA SW-846
7740
EPA SW-846
6010
If Not EPA
Method,
Validation By
Method 301?
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Thallium
Vanadium
Zinc
Organics-
waste liquid
feed
Toluene/
benzene feed
Toluene/
benzene feed
flow
Stack Gas:
Toluene
Benzene
Carbon
monoxide
TUHC
Particulate
EPA Air
Method
(Stationary
Source)








Method 10
Method 25A
Methods 1-5
Deviations
From EPA
Method, If
Any











If Other Method,
List Brief
Summary
EPA SW-846
7841
EPA SW-846
6010
EPA SW-846
6010
EPA S004, EPA
SW-846
8240/8270
EPA S004
Modified EPA
SW-846 8020
EPA 625/6-89/021
VOST SW-846
0030/5040
VOST SW-846
0030/5040



If Not EPA
Method,
Validation By
Method 301?
EPA Method
EPA Method
EPA Method
EPA
Method(s)
None reported
EPA
Method(s)
EPA
Method(s)
EPA
Method(s)
EPA Method
EPA Method
EPA
Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
Yes
Yes
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Yes, see below
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
w>
Pollutant
Measured
HC1
Metals*
EPA Air
Method
(Stationary
Source)

Draft metals
sampling train
Deviations
From EPA
Method, If
Any


If Other Method,
List Brief
Summary
CARS Method
421

If Not EPA
Method,
Validation By
Method 301?
None reported
EPA Method
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
Yes, see below
Yes, see below
Sample Data
Calculations
Conducted?
None reported
None reported
       See discussion below for a more detailed description of pollutants measured.

       This report is classified: TIER II

       Rating levels are defined as;
       TIER I       EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
       TIER II      State Agency method (e.g., California), no Method Validation
       TIER III     Unknown method, no Method Validation, good QA procedures
       TIER IV     Unknown method, no QA documentation

       Rating levels are based on the following comments and on information found in the report summary table.

       This test report presents the results of the trial burn for a CO Boiler which was required to comply with Federal EPA performance standards
       determined by RCRA and California EPA for industrial boilers burning hazardous waste. Seven test runs were conducted during the trial bum in
       August, 1991. The tests were conducted under each of two worst-case boiler operating conditions. Representative liquid hazardous waste containing
       principal organic hazardous constituents was used in the emission testing.

       During the trial burn, liquid waste feed was analyzed for heating value, ash, viscosity, water and organic phase content, ultimate analysis, metals
       content, and 40CFR 261 Appendix VIII constituents.  The POHC feed rate and concentration was also measured. The POHCs selected for these tests
       were toluene and benzene. Particulate matter was analyzed for total weight and metals content. HC1 and metals emissions were also sampled in the
       stack gas. Carbon monoxide, carbon dioxide, oxygen, total hydrocarbons, waste feed and stack gas flow rates were monitored by continuous
       emission analyzers and flow monitors.
      The following results are also reported: composition of the catalytic cracker regenerator offgas (CO); composition of flexicoker gas; composition of
      refinery fuel gas; composition of low sulfur fuel oil; waste liquid characteristics including the following metals*: antimony, arsenic, barium,

-------
beryllium, cadmium, chromium, copper, lead, mercury, molybdenum, nickel, selenium, silver, thallium, vanadium, and zinc. Results are also reported
for heating value; viscosity; water; ash content; chlorine; and ultimate analysis (carbon, oxygen, hydrogen, nitrogen, phosphorus, ash, sulfur.

Waste feed volatile organics: methylene chloride; carbon disulfide; chloroform; 1,2-dichloroethane; 2-butanone; 1,4-dioxane; 1,1,1-trichloroethane;
1,2-dichloropropane; trichloroethene; 1,2-dibromoethane; benzene; tetrachloroethene; 1,1,2,2-tetrachloroethane; toluene; chlorobenzene;
ethylbenzene; styrene; zylene (total).

Waste feed semi-volatile organics: pyridine; phenol; aniline; 2-chlorophenol; 1,3-dichlorobenzene; 1,4-dichlorobenzene; 1,2-dichlorobenzene; 2-
methylphenol; 4-methylphenol; nitrobenzene; 2,4-dimethylphenol; naphthalene; 2,4,6-trichlorophenol; dimethylphthalate; 2,4-dinitrophenol; 4-
nitrophenol; 2,4-dinitrotoluene; diethylphthalate; 4,6-dinitro-2-methylphenol; phenanthrene; anthracene; di-n-butylphthalate; fluoroanthene; pyrene;
butylbenzylphthalate; benzo(a)anthracene; bis(2-ethylhexyl)phthalate; chrysene; di-n-octylphthalate; benzo(b)fluoranthene; benzo(k)fluoranthene;
benzo(a)pyrene; indeno(l,2,3-cd)pyrene; dibenzo(a,h)anthracene; 7,12-dimethylbenz(a)anthracene; dibenz(a,h)acridine.

The test report describes the equipment, test methods, operating procedures, and quality assurance methodology employed during the test.  Quality
assurance procedures were thoroughly implemented according to section 5.0. A failed pilot tube, post-test leak check invalidated run 3. The data for
run 3 is provided in table 4-6 along with the replacement run 7. Quality assurance performance is presented in table 5-1 of the test report for all
methods and pollutants.  According to this table, all quality parameters met requirements.

Documentation of all calibrations and chain of custody are said to be provided in Appendix E, which is not attached.

An audit analysis of the VOST was conducted at the end of the trial burn. Two audit cylinders were analyzed for benzene and toluene by sampling the
cylinders via a manifold system.

ASTM Method description:
ASTM D240-87            Standard Test Method for Heat of Combustion of Liquid Hydrocarbon Fuels by Bomb Calorimeter
ASTM D482-87            Standard Test method for Ash from Petroleum Products
ASTM D445-88            Standard Test Method for Kinematic Viscosity of Transparent and Opaque Liquids (Calculation of Dynamic Viscosity)
ASTM D4281-83            Standard Test Method for Oil and Grease (Fluorocarbon Extractable Substances) by Gravimetric Determination
ASTM D 3178-84           Standard Test Method for Carbon and Hydrogen in the Analysis Sample of Coal and Coke
ASTM D 3179-84           Standard Test Method for Nitrogen in the Analysis of Coal and Coke
ASTM D 3174-88           Standard Test Method for Ash in the Analysis Sample of Coke from Coal

-------
Report No.: 49
Report Title: Trial Burn Report for CO Boiler No. 3 at the Shell Oil Manufacturing Complex, Martinez, California, December 16, 1993
Docket No.:  IV-J-13
Pollutant
Measured
Volatile organics
including toluene
and benzene
Semivolatile
organics
Ash
Water
Viscosity
Chloride
Ultimate analysis
(% by weight)
Carbon
Oxygen
Hydrogen
Nitrogen
Phosphorous
Ash
Antimony
Arsenic
EPA Air
Method
(Stationary
Source)









Deviations
From EPA
Method, If
Any









If Other
Method, List
Brief Summary
Method 8240
Method 8270
ASTMD482-91
ASTMD1744
ASTM D88
Method D9252
ASTM D529 1-92
ASTM D3 176-89
ASTM D529 1-92
ASTM D3 179-84
AO21
ASTM D3 174-89
Method 7041
(GFAAs)
Method 7060
(GFAAs)
If Not EPA
Method,
Validation By
Method 301?
EPA Method
EPA Method
None reported
None reported
None reported
EPA Method
None reported
EPA Method
EPA Method
Was Audit
Conducted?
Yes
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
See below
See below
See below
See below
See below
See below
See below
See below
See below
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Barium
Beryllium
Cadmium
Chromium
Lead
Mercury
Silver
Thallium
Toluene
Benzene
Particulate
PCDD/PCDF
Stack gas HC1/C12
EPA Air
Method
(Stationary
Source)










Methods 1-5
Method 23

Deviations
From EPA
Method, If
Any













If Other
Method, List
Brief Summary
Method 6010
(GFAAs)
Method 60 10
(GFAAs)
Method 60 10
(GFAAs)
Method 6010
(GFAAs)
Method 7421
(GFAAs)
Method 7471
(GFAAs)
Method 60 10
(GFAAs)
Method 7841
(GFAAs)
Method 0030
Method 0030


Method 0050
If Not EPA
Method,
Validation By
Method 301?
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
EPA Method
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Yes
Yes
None reported
Yes
None reported
Method QA/QC
Requirements
Met?
See below
See below
See below
See below
See below
See below
See below
See below
See below
See below
See below
See below
See below
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported

-------
Pollutant
Measured
Stack gas total
unburned
hydrocarbons
EPA Air
Method
(Stationary
Source)
Method 25A
Deviations
From EPA
Method, If
Any

If Other
Method, List
Brief Summary

If Not EPA
Method,
Validation By
Method 301?
EPA Method
Was Audit
Conducted?
None reported
Method QA/QC
Requirements
Met?
See below
Sample Data
Calculations
Conducted?
None reported
This report is classified: TIER II

Rating levels are based on the following comments and on information found in the report summary table.

Trial burn performance testing was conducted at a manufacturing complex in California. The purpose of this test program was to demonstrate the
ability of CO Boiler No. 3 to meet federal RCRA performance standards while burning representative hazardous waste containing POHCs. Benzene
and toluene were designated as the POHCs of interest for the trial bum. Boiler exhaust emissions were determined for particulate matter, hydrogen
chloride/chlorine, multiple metals, and dioxins/furans under four different operating conditions. Three replicate sampling runs were conducted during
each operating condition. The pollutants listed in the above table were measured in the waste feed and/or stack gas, as applicable.
According to the test report, QA/QC results indicated that data was well documented, reliable, and defensible and met the project data objectives as
defined in the Quality Assurance Project Plan (QAPP). Extensive QA/QC procedures including blanks, surrogate recoveries, duplicates were
conducted. There is some specific discussion of QC results which are outside the acceptance limits, the cause, and corrective action taken. Three
dioxin/furan audit samples were by U.S. EPA. The audit samples consisted of a blank, a low level, and a medium level dioxin/furan sample that
contained tetra- through octa-isomers of PCDDs and PCDFs.

A performance audit was conducted of the VOST sampling system for toluene and benzene during the trial bum. This audit consisted of collecting a
gas sample of toluene and benzene from a U.S. EPA gas cylinder. A representative from the California Department of Toxic Substances Control
(DTSC) observed collection of the audit samples. Results of the audits are contained in Appendix A, which is not attached to the test plan.

-------
Review of this report was to include verification that sample data calculations were performed correctly. However, no sample data calculations were
provided in the test report. According to the test report, all method QA/QC requirements were met. However, not all QA/QC results were reported as
such and therefore could not be verified. The test report states that QC documentation such as field test data sheets, equipment calibration records,
chain of custody forms, and calibration gas certificates are provided in the appendices of the test report, however the appendices are not present.

The individual 4 VOCs and 19 SVOCs detected are presented in tables in the test report.
ASTM Method Description:
ASTMD482-91
ASTM D1744
ASTM D88
ASTM D5291-92
ASTM D3176-89
ASTM D3179-84
ASTM D3174-89
Standard Test Method for Ash from Petroleum Products
Standard Test Method for Determination of Water in Liquid Petroleum Products by Karl Fischer Reagent
Standard Test Method for Saybolt Viscosity
Standard Test Method for Instrumental Detection of Carbon, Hydrogen, and Nitrogen in Petroleum Products/Lubricants
Standard Test Method for Ultimate Analysis of Coal and Coke
Standard Test Method for Nitrogen in the Analysis of Coal and Coke
Standard Test Method for Ash in the Analysis Sample of Coke from Coal

-------
 Report No.: 50
 Report Title: Test Report for EOOon Company, USA, Benecia, California, February 12-20, 1990
 Docket No.: IV-J-9
Pollutant Measured
Polycyclic aromatic
hydrocarbons (PAHs)
Phenols
Formaldehyde
Acetaldehyde
H2S
Total and hexavalent
chromium
Benzene
1,3-Butadiene
NH3
Total Metals*
EPA Air
Method
(Stationary
Source)









EPA Metals
Method**
Deviations
From EPA
Method, If
Any










If Other
Method, List
Brief
Summary
CARB429
CARB429
CARB430
CARB430
CARB 11
CARB
425/EPA7191
CARB 410A
CARB410A
BAAQMD
ST-1B
See below
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
EPA Method
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
See below
See below
See below
See below
See below
See below
See below
See below
See below
See below
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes

Yes


Yes
Yes
This report is classified: TIER II

-------
Rating levels are defined as:
TIER I EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II State Agency method (e.g., California), no Method Validation
TIER III Unknown method, no Method Validation, good QA procedures
TIER IV Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Emission testing was conducted on a FCCU stack at an Exxon refinery. Tests were conducted for PAHs, NH3, H2S, benzene and 1,3-butadiene in
triplicate while five tests were performed for total metals at the main stack.

*Metals that were measured: arsenic, beryllium, cadmium, total chromium, copper, lead, manganese, mercury, nickel, selenium, zinc.

**Metals samples were prepared according to EPA draft document Methodology For The Determination of Metals Emissions in Exhaust Gases From
Hazardous Waste Incineration and Similar Combustion Processes. Analytical methods used are listed in the test report.

Analysis for hexavalent chromium resulted in unacceptable spike recoveries and use of the method of standard additions resulted in unacceptable
linear correlation. Therefore, no results are reported for hexavalent chromium. According to the test report, all method QA/QC requirements were
met. However, specific QA/QC results were not reported for some pollutants and therefore could not be verified.

QC documentation such as field test data sheets, equipment calibration records, and chain of custody forms are provided in the appendices of the test
report and appear complete.

Method Description:
CARB Method 430 Determination of Formaldehyde in Emissions from Stationary Sources
CARB Method 425 Determination of Total Chromium and Hexavalent Chromium Emissions from Stationary Sources
CARB Method 429 Determination of PAHs Using GC/MS Scan Analysis Extended to Include Phenol
CARB Method 410A Determination of Low Concentrations of Benzene from Stationary Sources

-------
Report No.: 51
Report Title: Determination of Air Toxics Emission Rates - FCCU Volume I and Volume II, Mobil Oil Corporation, Torrance, California, May 16,
30, and 31,1990
Docket No.: IV-J-10
Pollutant
Measured
PAH
Phenol
Formaldehyde
Acetaldehyde
Benzene
Hydrogen
sulfide
Ammonia
Hydrogen
cyanide
1,3-butadiene
Arsenic
EPA Air
Method
(Stationary
Source)









USEPA
Multi-Metals
Train
I
Deviations
From EPA
Method, If
Any









Modified
with CARB
Methods
(see text)
If Other Method,
List Brief Summary
CARB Method 429
Modification of
CARB Method 429
CARB Method 430
Modification of
CARB Method 430
CARB Method 4 10A
Modification of
CARB Method 4 10A
and CARB Method 15
Modification of
CARB Method 421
Modification of
CARB Method 426
VOST Method

If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
Yes
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
Yes
None reported
Yes
None reported
Yes
Yes
None reported
None reported
Yes
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

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Pollutant
Measured
Beryllium
Cadmium
Copper
Lead
Manganese
Nickel
Selenium
Zinc
Mercury
EPA Air
Method
(Stationary
Source)
USEPA
Multi-Metals
Train
USEPA
Multi-Metals
Train
USEPA
Multi-Metals
Train
USEPA
Multi-Metals
Train
USEPA
Multi-Metals
Train
USEPA
Multi-Metals
Train
USEPA
Multi-Metals
Train
USEPA
Multi-Metals
Train

Deviations
From EPA
Method, If
Any









If Other Method,
List Brief Summary








CARB Method 101 A
If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
None reported
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes

-------
Pollutant
Measured
Chromium
(Total)
Chromium
(Hexavalent)
EPA Air
Method
(Stationary
Source)


Deviations
From EPA
Method, If
Any


If Other Method,
List Brief Summary
CARS Method 425
CARS Method 425
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
Yes
Yes
Sample Data
Calculations
Conducted?
Yes
Yes
This report is classified:  TIER II

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER HI     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Test series was conducted to satisfy the requirements for measurement of Air Toxics Hot Spots Information and Assessment Act of 1987. FCCU
source emission testing was performed to measure the emission rates of formaldehyde, benzene, metals, PAHs, phenol, acetaldehyde, hydrogen
sulfide, hydrogen cyanide, 1,3-butadiene and ammonia.
Method Description:
CARE Method 101A
CARS Method 15
CARB Method 104
CARB Method 410A/410B
NIOSH Method 6701
CARB Method 426
CARB Method 425
CARB Method 429
CARB Method 429
CARB Method 430
Determination of Particulate and Gaseous Mercury Emissions From Sewage Sludge Incinerators
Modified for the Collection and Analysis of Reduced Sulfur Compounds
Determination of Beryllium Emissions from Stationary Sources
Determination of Low and High Concentraions of Benzene from Stationary Sources
Determination of Ammonia
Modified Version to Determine Particulate and Gaseous Hydrogen Cyanide
Determination of Total Chromium and Hexavalent Chromium Emissions from Stationary Sources
Determination of Polycyclic Aromatic Hydrocarbons (PAH) Emissions from Stationary Sources
Modified for Analysis of Phenol
Determination of Formaldehyde in Emissions from Stationary Sources

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CARB Method 430         Modified for the Analysis of Acetaldehyde
EPA Multi-Metals Train     Modified with CARB Methods 12,101A, 104,423,424,425 and 433
EPA VOST Procedure      Determination of Benzene, Toluene, Xylene and 1,3-Butadiene


Review of this report included verification that sample data calculations were performed correctly. According to the test report, all method QA/QC
requirements were met. However, some QA/QC results were not reported and therefore could not be verified. QC documentation such as field test
data sheets, equipment calibration records, chain of custody forms, and calibration gas certificates are provided in the appendices of the test report and
appear complete.

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Report No.:  52
Report Title:  Results of Dioxin Testing on the Catalytic Reformer Unit #1 Exhaust, Texaco Refinery, Bakersfield, California, August 8,1991
Docket No.: IV-J-11
Pollutant
Measured
PCDD
PCDF
EPA Air
Method
(Stationary
Source)


Deviations
From EPA
Method, If Any


If Other
Method, List
Brief
Summary
CARD 428
CARB428
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
Was Audit
Conducted?
None reported
None reported
Method QA/QC
Requirements
Met?
Yes, see below
Yes, see below
Sample Data
Calculations
Conducted?
Yes
Yes
This report is classified:  TIER II

Rating levels are defined as;
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II     State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Source emission testing was conducted on a Catalytic Reformer Unit No. 1 exhaust at a refinery in California to determine emissions of
polychlorinated dibenzo-p-dioxins (PCDD) and polychlorinated dibenzofurans (PCDF) during the catalyst regeneration process. Testing followed
CARS Method 428. Representatives from the Kem County Air Pollution Control District were present during the test series.

Review of this report included verification that sample data calculations were performed correctly. Review of the laboratory data presented in the test
report reveals recovery efficiencies for the internal and surrogate standards were acceptable.  QC documentation such as field test data sheets,
equipment calibration records, chain of custody forms, and laboratory quality control records are provided in the appendices of the test report and
appear complete.

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Report No.: 53
Report Title: NOx, SO2, CO, Sulfates and Particulate Compliance Emission Test Program-Heavy Oil Scrubber Exhaust (EPN 121) 70,000 BBL/Day
without NaHCO3 Injection, Valero Refining Company, Corpus Christi, Texas, March 15,1995
Docket No.: IV-J-14
Pollutant
Measured
Particulate
Opacity
Sulfur dioxide
Sulfuric acid
Nitrogen oxides
Carbon
monoxide
EPA Air
Method
(Stationary
Source)
Methods 1-5B
Method 9
Method 8
Method 8
Method 7E
Method 10
Deviations
From EPA
Method, If
Any






If Other
Method, List
Brief Summary






If Not EPA
Method,
Validation By
Method 301?
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
EPA Method(s)
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
This report is classified: TIER I

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

A formal emissions test program was conducted at a refinery located in Texas. These tests were conducted to comply with a TNRCC/U.S. EPA
permit. Test methods followed those specified in 40CFR Part 60, EPA Methods 1-4, 5B, 7E, 8, 9, and 10 and the TNRCC Sampling and Laboratory
Procedures Manual.

-------
Review of this report was to include verification that sample data calculations were performed correctly. However, no sample data calculations were
provided in the test report. QA/QC results were not reported and therefore could not be verified. QC documentation such as field test data sheets,
equipment calibration records, chain of custody forms, and process data are provided in the appendices, however the appendices are not attached to the
report.

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 Report No.: 54
 Report Title: AB2588 Air Toxics Emissions Test Report FCCU CO Boiler Volume I-Main Report, Texaco Refining and Marketing, Los Angeles
 Plant, Wilmington, California, May 24,1996
 Docket No.: IV-J-15
Pollutant
Measured
Reduced Sulfur
Benzene,
Ethylbenzene,
Toluene, and
Xylene (BTEX)
Hydrogen chloride
Hexavalent and
total chromium
Cyanide
PAH's and Phenol
Formaldehyde and
Acetaldehyde
Multiple metals
Ammonia
EPA Air
Method
(Stationary
Source)









Deviations
From EPA
Method, If
Any









If Other
Method, List
Brief
Summary
CARS 15
CARB410A
CARS 421
CARB425
CARB426
CARB429
CARS 430
CARD 436
SCAQMD
207.1
If Not EPA
Method,
Validation By
Method 301?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Was Audit
Conducted?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Method QA/QC
Requirements
Met?
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
None reported
Sample Data
Calculations
Conducted?
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
This report is classified:  TIER II
Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation

-------
TIER II State Agency method (e.g., California), no Method Validation
TIER III Unknown method, no Method Validation, good QA procedures
TIER IV Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

Emission testing was conducted on a FCCU CO boiler at a Texaco refinery in California. The objective of the test program was to measure the
emissions of selected toxic substances for AB2588 emissions inventory. CARB methods were followed and sample calculations were conducted for
each measured pollutant. CARB Methods 1 -4 were followed for determination of sampling point, flue gas velocity and flow rate, flue gas
composition and molecular weight, and flue gas moisture content.

According to the test report, all method QA/QC requirements were met. However, specific QA/QC results were not reported as such and therefore
could not be verified. Quality documentation such as field test data sheets, equipment calibration records, chain of custody forms, and calibration gas
certification are provided in the appendices of the test report and appear complete.

The emissions that were measured using Method 15 included carbon disulfide, carbonyl sulfide, dimethyl disulfide, hydrogen sulfide, methyl
mercaptan.

PAHs measured using Method 429 included naphthalene, 2-methylnaphthalene, acenaphthylene, acenaphthene, fluorene, phenanthrene, anthracene,
fluoranthene, pyrene, benzo(a)anthracene, chrysene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(e)pyrene, benzo(a)pyrene, perylene,
indeno(l,2,3-c,d)pyrene, dibenz(a,h)anthracene, benzo(g,h,i)perylene, phenol.

Metals that were measured using Method 436 included arsenic, beryllium, cadmium, copper, lead, manganese, mercury, nickel, selenium, zinc.

-------
Report No.: 55
Report Title: Preliminary results of emission testing at Chevron Refinery, Richmond, California, January, 1997
Docket No.: Awaiting final version for docket entry
Pollutant
Measured
PCDD/PCDF
PCBs
PAHs
EPA Air Method
(Stationary
Source)
Data package
only- see below
Data package
only- see below
Data package
only- see below
Deviations
From EPA
Method, If
Any
NA
NA
NA
If Other
Method, List
Brief
Summary
NA
NA
NA
If Not EPA
Method,
Validation By
Method 301?
NA
NA
NA
Was Audit
Conducted?
NA
NA
NA
Method QA/QC
Requirements
Met?
NA
NA
NA
Sample Data
Calculations
Conducted?
NA
NA
NA
This report is classified:  TIER IV

Rating levels are defined as:
TIER I      EPA Air Method or EPA (other than air), State, or unknown method with Method Validation
TIER II      State Agency method (e.g., California), no Method Validation
TIER III     Unknown method, no Method Validation, good QA procedures
TIER IV     Unknown method, no QA documentation

Rating levels are based on the following comments and on information found in the report summary table.

This report contains preliminary results of emissions test conducted at a Richmond refinery. According to the report, these are considered preliminary
results and are subject to change and review.  This preliminary draft contains only data sheets, no actual discussions of results, QA/QC, or method
used. Results are provided for dioxins/furans, PCBs, and PAHs.

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