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You should report this as a “process-only” configuration.  The emissions from the combustion of petroleum coke deposited on the catalyst are considered to be process emissions, not combustion emissions.  The only time a complete combustion catalytic cracking unit would report as a “shared process/combustion stack” configuration is if the unit had auxiliary fuel fired by the catalytic cracking unit during start-up or idling of the unit and these emissions were measured by the CEMS.

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Question 2
Question 2

2. Under the process-only configuration, should I enter “petroleum coke” or “catalyst coke” into the “Types of fuel combusted in the unit(s) monitored by the CEMS” field?

No.  You should leave this field blank because no fuels are combusted in a process-only configuration. Emissions arising from catalyst petroleum coke burned within the regenerator are considered to be process emissions, not combustion emissions.  Alternatively, to eliminate the e-GGRT validation messages, you may enter “none” or “not applicable” in this field.

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You would typically report only the CH4 and N2O emissions due to combustion of fuel gas and other Table C-2 fuels used in the CO boiler.  If you have a separate stationary combustion source that shares a common stack with the process emissions, also include and report the CH4 and N2O emissions due to combustion of fuels used in the stationary combustion unit following the requirements of subpart C.  The CH4 and N2O emissions generated from the combustion of catalyst petroleum coke are reported under the subject process unit’s e-GGRT data entry forms and should not be included in the CML’s reporting section “CEMS Equation C-10 Summary and Results.”

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