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A656. EPA has prepared a general table of reporting instructions for FCC units with CEMs as presented in the table below. In addition EPA has provided guidance on how to report regenerator and process gas and explained how to avoid double counting of emissions in the following common situations:
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1. I have a CEMS that monitors the CO2 emissions from a catalytic cracking unit with a complete combustion regenerator (no CO boiler) that burns off petroleum coke which has deposited on the catalyst. Should I report this as a “process-only” configuration or as a “shared process/combustion stack” configuration?
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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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