Petroleum Coke: Industry and Environmental Issues

Congressional research reportOct 29, 2013

Ask Donna

What actually matters in this document.

Text

Petroleum Coke: Industry and Environmental

Issues

name redacted

Analyst in Environmental Policy

October 29, 2013

Congressional Research Service

7-....

www.crs.gov

R43263

Petroleum Coke: Industry and Environmental Issues

Summary

In early 2013, media outlets around Detroit, Michigan began publishing stories about large piles

of petroleum coke stored along the Detroit Riverfront. Petroleum coke (petcoke) is a blackcolored solid composed primarily of carbon, and may contain limited amounts of elemental forms

of sulfur, metals and non-volatile inorganic compounds. Petcoke is essentially chemically inert.

Petcoke exposure is considered to pose few human health or environmental risks, but may present

significant nuisance concerns. The material in Detroit was the byproduct of the nearby Marathon

Refinery’s processing of heavy crude oils derived, in part, from Canadian oil sands deposits. The

situation gained national attention with the publication of an article in the New York Times (“A

Black Mound of Canadian Oil Waste Is Rising over Detroit,” New York Times, May 17, 2013).

The piles of petcoke sparked local concerns over the potential impacts of the material on human

health and the environment, and whether these concerns were adequately addressed by local,

state, and federal regulations. As petroleum refining is a nationwide commercial industry, these

concerns may arise in other regions.

Petcoke is a co-product of several distillation processes used in refining heavy crude oil. Nearly

half of U.S. petroleum refineries (56 or more) use a coking process to convert heavy crude oils

into refined petroleum products, and more refineries may follow suit to take advantage of the

supply of heavy crude oils from Canada’s oil sands projects. Although it is a refining co-product,

petcoke has economic value as both a heating fuel and raw material in manufacturing. In 2012,

the U.S. Energy Information Administration reported that U.S. refineries produced in excess of 56

million metric tons of petcoke, of which 80% was exported.

The U.S. Environmental Protection Agency has surveyed the potential human health and

environmental impacts of petcoke through its High Production Volume (HPV) Challenge Program

and found the material to be highly stable and non-reactive at ambient environmental conditions.

Most toxicity analyses of petcoke find it has a low potential to cause adverse effects on aquatic or

terrestrial environments as well as a low health hazard potential in humans, with no observed

carcinogenic, reproductive, or developmental effects. Cases of repeated-dose and chronic

inhalation of fugitive dust (as generated during petcoke handling and storage) in animal studies

do appear associated with respiratory inflammation. Emissions from the combustion of petcoke,

however, can have impacts on human health and the environment, including the release of

common pollutants, hazardous substances, and high levels of the greenhouse gas, carbon dioxide.

While some federal statutes address certain environmental impacts of petcoke’s life-cycle, most

regulatory action and oversight has been undertaken at the state and local levels, generally

through facility-specific permitting requirements. Federally, petcoke is exempted from

classification as either a solid or hazardous waste under the Resource Conservation and Recovery

Act (RCRA) and is not considered a hazardous substance under the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA). Petcoke facilities may be

regulated under certain provisions of the National Pollutant Discharge Elimination System

(NPDES) permit program, as authorized by the Clean Water Act (CWA), if it is determined that

runoff from sites where it is stored has the potential to transport the substance to nearby surface

waters. The handling of petcoke may also create instances of reduced air quality due to releases of

fugitive dust into the atmosphere. Most of the impacts of fugitive dust are localized; and thus,

much of the regulatory oversight is implemented at the local and state level. Whether such

oversight is providing adequate protection is among the issues that have been raised.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Contents

Background .................................................................................... Error! Bookmark not defined.

Petcoke Uses ............................................................................................................................. 1

Petcoke Composition ................................................................................................................ 2

Petcoke Compared to Metallurgical Coke and Coal ................................................................. 2

Petcoke Grades .......................................................................................................................... 3

Coking Refineries and Outputs ....................................................................................................... 4

Petcoke Storage Terminals ........................................................................................................ 6

Petcoke Market and Exports ..................................................................................................... 6

Potential Health and Environmental Impacts .................................................................................. 7

EPA’s Hazard and Toxicity Characterizations ........................................................................... 7

Environmental Fate ............................................................................................................. 8

Environmental Toxicity....................................................................................................... 8

Human Health Effects ......................................................................................................... 9

Reactivity ............................................................................................................................ 9

Federal Regulatory Requirements ........................................................................................... 10

Waste Classifications ......................................................................................................... 11

Industrial Stormwater Runoff ........................................................................................... 13

Fugitive Dust..................................................................................................................... 14

Regulatory Standards for Petcoke Combustion in Power Generation .............................. 15

Conclusion .................................................................................................................................... 15

Figures

Figure 1. Sponge Coke .................................................................................................................... 4

Figure 2. Shot Coke ......................................................................................................................... 4

Figure 3. U.S. Refinery Net Petcoke Production............................................................................. 5

Figure 4. Net Petcoke Production vs. Exports ................................................................................. 7

Figure A-1. Shell Delayed Coking Unit ........................................................................................ 18

Figure A-2. ExxonMobil Flexi-Coking Unit ................................................................................. 18

Figure A-3. U.S. Refineries with Coking Capacity ....................................................................... 19

Figure A-4. Coking Refineries by PADD ...................................................................................... 20

Figure A-5. Refining and Coking Capacity by PADD .................................................................. 21

Tables

Table 1. Petcoke Elemental Composition ........................................................................................ 2

Table 2. Petcoke vs. Metcoke and Coal ........................................................................................... 3

Table 3. Petcoke vs. Coal: Combustion Emissions ....................................................................... 10

Table A-1. U.S. Refineries with Coking Capacity ......................................................................... 22

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Appendixes

Appendix. Petroleum Refining and Petcoke Production ............................................................... 17

Contacts

Author Contact Information ........................................................... Error! Bookmark not defined.

Acknowledgments .......................................................................... Error! Bookmark not defined.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Background

Some Members of Congress have expressed concern about storage and management of petroleum

coke (petcoke) in their districts. Despite a lack of data on observed health impacts, local concerns

have included potential human health and environmental impacts of fugitive dusts and runoff into

waterways. Broader concerns have also been raised about the carbon dioxide (greenhouse gas)

emissions from petcoke combustion.

Petcoke is the co-product of several processes used in petroleum refining to upgrade “residuum”

into gasoline and middle distillate-range fuels. Residuum (or resid) remains after refineries

initially distill heavy crude oils. Petcoke is a black-colored solid composed primarily of carbon,

and may contain limited amounts of elemental forms of sulfur, metals, and non-volatile inorganic

compounds.

The petroleum industry and federal regulators characterize petcoke as a “co-product” because it

may have some commercial value as a boiler fuel and as a raw material in manufacturing. Nearly

half of U.S. petroleum refineries employ “coking” processes. Refineries also produce petcoke as a

by-product of catalysis, which refineries later consume as a fuel.

In addition to the existing suite of coking refineries, other refineries may add coking processes to

take advantage of increased supplies of heavy crude oils from Canada’s oil sand projects.

Meanwhile, newly available light crude oil from U.S. unconventional shale projects and the Texas

Permian Basin is leading some coking refineries to cut back on coking. At present, it is uncertain

whether petcoke production will increase, remain steady or even decline, given the changing slate

of U.S. crude oil supplies. Nevertheless, the export and demand for U.S. petcoke has been rising

recently.

Community stakeholders have grown concerned over the potential effects on public health and

the environment related to the production, storage, transportation, and use of petcoke. Some of

these impacts include concerns over air quality due to fugitive dust, water quality due to run-off,

and the potential for toxic and other emissions (including greenhouse gas emissions) from its

combustion as a fuel source. In light of these concerns, industry, regulators, and compliance

officers may be interested in best practices related to the storing, containing, and managing of

petcoke.

Petcoke Uses

Petcoke may be combusted as fuel in industrial and power generating plants. Cement plants and

power plants are currently the two greatest consumers of petcoke. There is some limited use as

space heating and in commercial brick kilns in Europe, and a small but emerging market as a

metallurgical coal blending component for the steel industry. In the United States, the high sulfur

content may limit the petcoke in a coal/petcoke blend in a plant designed for coal. However, more

recently designed Circulating Fluidized Bed (CFB) boilers can accommodate 100% high sulfur

coke.1

Fuel grade petcoke can substitute for “steam coal” in power plant boilers, having the advantage of

a higher heating value (discussed below). Conventional coal-fired boilers can blend petcoke with

Pet Coke Consulting LLC, http://www.petcokeconsulting.com/primer/index.html.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

steam coal, and newer boiler designs have replaced steam coal with petcoke entirely.2 Cement

plants consume fuel-grade petcoke in rotary kilns.

Anode grade calcined petcoke is the principal raw material used in manufacturing carbon anodes

for use in aluminum smelting. The anodes act as conductors of electricity and as a source of

carbon in the electrolytic cell that reduces alumina into aluminum metal. Carbon anode

manufacturers, predominantly captive operations of aluminum smelting companies, purchase

anode grade calcined petcoke, mix it with pitch binders, press the mixture into blocks, and then

bake the mixture to form a finished, hardened carbon anode.

Petcoke Composition

Petcoke is composed primarily of carbon. The specific chemical composition of petcoke depends

on the composition of the petroleum feedstock used in refining. Petcoke impurities (i.e., the nonelemental carbonaceous substances) include some residual hydrocarbons left over from

processing (referred to as volatiles), as well as elemental forms of nitrogen, sulfur, nickel,

vanadium, and other heavy metals. These impurities exist as a hardened residuum captured within

coke’s carbon matrix. Table 1 provides an observed range of petcoke properties for green and

calcined petcoke.

Table 1. Petcoke Elemental Composition

By Weight Percent

Composition

Green

Calcined

Carbon

89.58–91.80

98.40

Hydrogen

3.71–5.04

0.14

Oxygen

1.30–2.14

0.02

Nitrogen

0.95–1.20

0.22

Sulfur

1.29–3.42

1.20

Ash (including heavy metals

such as nickel and vanadium)

0.19–0.35

0.35

Carbon-Hydrogen Ratio

18:1–24:1

910:1

Source: U.S. Environmental Protection Agency, Screening-Level Hazard Characterization, Petroleum Coke

Category, June 2011; and H.W. Nelson, Petroleum Coke Handling Problems, 1970.

Notes: The process of “calcining” converts green coke to almost pure carbon, with a defined structure to

produce carbon anodes for the aluminum industry.

Petcoke Compared to Metallurgical Coke and Coal

Petcoke has a significantly high heating value compared to metallurgical coke (metcoke) and

bituminous coals (see Table 2). The higher heating value comes at the cost of higher sulfur and

nitrogen content, however. Ash content is relatively low, compared to coal, but much of it is in the

form of heavy metals. Due to the severe thermal environment in which petcoke forms, there is

Thermal coal is sometimes called “steam coal” because it is used to fire boiler plants that produce steam for electricity

generation and industrial uses.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

very little combustible volatile material. The low volatile content, in comparison to coal and other

fossil fuels, makes petcoke more difficult to ignite and sustain combustion.3

Bituminous coal includes two subtypes: thermal and metallurgical.4 Metallurgical coke is made

from low ash, low sulfur bituminous coal, with special coking properties. To produce metcoke,

special coke ovens heat metallurgical grade coal at temperatures of 1,000ºF to 2,000ºF to fuse

fixed carbon and inherent ash, and drive off most of the volatile matter.5 Approximately 1.5 tons

of metallurgical coal will produce one ton of metcoke. The final product is a nearly pure carbon

source with sizes ranging from basketballs (foundry coke) to a fine powder (coke breeze).

Table 2. Petcoke vs. Metcoke and Coal

Heating Value and Price

Fuel

Coal Rank

Btu / lb.

$/Short Ton

Petcoke

n.a.

14,200

See Note

Metcoke

Metallurgic

12,600

171.51

Pittsburgh #8

Bituminous

13,000

68.25

Illinois #6

Bituminous

11,000

45.40

Powder River Basin

Sub-bituminous

8,800

10.30

Steam Coal

Source: MIT, The Future of Coal Appendices, P5, http://web.mit.edu/coal/The_Future_of_Coal_Appendices.pdf,

and EIA, Coal News and markets, http://www.eia.gov/coal/news_markets/.

Notes: Steam Coal Prices as of July 19, 2013. Petcoke prices track steam coal prices, but at a discount that may

range from 15% to 85%. Recent prices have been closer to 67% of steam coal prices.

Petcoke Grades

The coking processes described above produce “green coke,” which then requires additional

thermal processing to remove any residual hydrocarbons (volatile matter) to increase the

percentage of elemental carbon. Thermal processing lowers the potential toxicity of the coke.

Depending on the coking operation temperatures, length of coking-time, and quality of the crude

oil feedstock, one of several grades of petcoke can be produced:



sponge coke, the most common type of regular-grade petcoke, used as a solid

fuel (see Figure 1);

needle coke, a premium-grade coke made from special petroleum feedstock, used

in the manufacture of high-quality graphite electrodes for the steel industry;

shot coke, produced from heavy petroleum feedstock, used as fuel, but less

desirable than sponge coke (see Figure 2);

purge coke, produced by flexi-coking, used as a fuel in coke-burning boilers; or

Anthony Pavone, “Converting Petroleum Coke to Electricity,” Proceedings from the 14th National Industrial Energy

Technology Conference, Houston, TX, April 22-23, 1992, http://repository.tamu.edu/bitstream/handle/1969.1/92212/

ESL-IE-92-04-47.pdf.

Bituminous coals are mined throughout the eastern United States range but generally have higher sulfur and nitrogen

contents than western coals.

Oxbow, Metallurgical Coke, http://www.oxbow.com/Products_Industrial_Materials_Metallurgical_Coke.html. Also

see Grande Cache Coal, Met Coke 101, http://www.gccoal.com/about-us/met-coal-101.html.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues



catalyst coke, carbon deposited on catalysts, used in various refining processes

and burned off and used as a fuel in the refining process; not recoverable in a

concentrated form.

Figure 1. Sponge Coke

Figure 2. Shot Coke

Partially Crushed

Source: John D. Elliott, Shot Coke: Design &

Operations, http://www.fwc.com/publications/

tech_papers/oil_gas/shotcoke.pdf.

Source: John D. Elliott, Shot Coke: Design &

Operations, http://www.fwc.com/publications/

tech_papers/oil_gas/shotcoke.pdf.

Coking Refineries and Outputs

The fleet of petroleum refineries operating throughout the United States has steadily declined in

the past several decades as refining capacity has become concentrated in larger refineries. At

present, some 115 refineries (and refinery complexes) produce over 17 million barrels per day of

motor fuels and other petroleum products. Nearly half (56) have the coking capacity to convert

heavy crude oils6 (see the Appendix to this report).

Coking capacity has been concentrated in refineries operating along the Gulf Coast, the historic

refining center of the United States and primary destination for crude oil imports. However, to

take advantage of the increasing supply of heavier crude oils from Canada’s oil sands projects,

several Midwest refineries have added coking conversion capacity.

U.S. refineries have the capacity to process 2.5 million barrels per day of petroleum resid. The

Gulf Coast not only represents the greatest refining capacity (9.3 million barrels per day), it also

represents also the greatest coking capacity (1.5 million barrels per day).

U.S. petcoke production has remained constant over the last decade for the reason that refining

capacity has remained constant (see Figure 3). In 2012, the U.S. Energy Information

Administration (EIA) reported that U.S. refineries produced 42 million metric tons of marketable

For further background on the refining industry, see CRS Report R41478, The U.S. Oil Refining Industry:

Background in Changing Markets and Fuel Policies, by (name redacted) et al.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

petcoke and another 15 million metric tons of catalyst coke.7 For the purpose of comparison, the

United States produced 9.3 million tons of coke from metallurgical grade coal8 and more than 1.2

billion tons of coal in 2012.9

Figure 3. U.S. Refinery Net Petcoke Production

Thousand Metric Tons per Year

Source: U.S. Energy Information Administration, U.S. Refinery Net Production, http://www.eia.gov/dnav/pet/

pet_pnp_refp2_dc_nus_mbbl_a.htm.

Notes: Catalysts used in various refining processes (e.g., catalytic cracking) become deactivated from the buildup

of carbon deposits, In order to reactivate the catalysts; the carbon is burned off and used as a fuel by the

refinery. The carbon coke is not recoverable in a concentrated form.

Overall, petcoke production reflects refinery capacity utilization rate, which represents the use of

the refinery atmospheric crude oil distillation units. The rate is calculated by dividing the gross

input to these units by the operable refining capacity of the units. The utilization rate has

averaged from 82% to 88%.10 U.S. refineries have been producing approximately 40 million

metric tons of marketable petcoke annually over the period of 2007 through 2012. Refineries,

however, need enough light-heavy price spread (LHS) between coker feedstock (heavy resid) and

light products (gasoline, jet, and diesel) to run their coking units profitably. With the rising

availability of U.S. produced light-sweet crude oil, however, some refineries may choose to cut

back on coking, and thus produce less coke. These and other variables lend uncertainty to

whether petcoke production will increase, remain steady or decline in the coming years.

The U.S. Energy Information Administration reported that U.S. refinery net production of petroleum coke in 2012

was 310,481 thousand barrels (U.S. Refinery Net Production, http://www.eia.gov/dnav/pet/

pet_pnp_refp2_dc_nus_mbbl_a.htm). 1 metric ton is the equivalent of 5.51 barrels.

American Iron and Steel Institute, Annual Statistical Report, 2012, p.80. Production and Consumption of Coke.

U.S. Energy Information Administration, Monthly Energy Review, Coal, June 2013, http://www.eia.gov/totalenergy/

data/monthly/index.cfm#coal.

U.S. Energy Information Administration, Refinery Utilization and Capacity, http://www.eia.gov/dnav/pet/

pet_pnp_unc_dcu_nus_a.htm.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Petcoke Storage Terminals

Refineries temporarily stockpile petcoke on their facilities, but because they generally lack

sufficient storage space must transport it regularly to avoid production slowdowns. Typically,

coker drums are mounted over railroad tracks so that coke can be discharged directly into open

hopper or gondola cars. The rail cars then transport the petcoke to calcining plants or to

temporary storage terminals.

A complete accounting of independent terminals that store petcoke exceeds the scope of this

report. However, a CRS survey identified at least four companies with petroleum coke as a

primary business line: SSM Petroleum Coke LLC, TCP Petroleum coke Corp, DTE Petroleum

Coke, LLC, and Kinder Morgan Petroleum Coke Gp LC.11 SSM Petroleum Coke is an affiliate of

Oxbow Carbon LLC (Koch Industries, Inc.). Koch Carbon, LLC specialize in the global sourcing,

supply, handling, and transportation of bulk commodities including, but not limited to, petcoke.

TCP Petroleum Coke Corporation is a joint venture between CITGO Petroleum Corporation

(CITGO) and RWE Power AG, offering a diversified marketing network to over 30 countries.

DTE Petroleum Coke is a subsidiary of DTE Energy, a diversified energy company that includes

electric/gas utilities. DTE Energy has reportedly removed the petcoke it stored at its Detroit Bulk

Storage site along the Detroit River.12 Kinder Morgan Petroleum Coke L.P. advertises that it is

responsible for handling over 10 million tons of petcoke through several terminals located on the

Texas Gulf Coast.

Petcoke Market and Exports

Petcoke competes with both coal and metcoke in the international market. Its comparatively

higher heating values makes it an economic substitute for steam coal. However, its granular

physical properties may add to the cost of material handling, which is reflected in a discounted

price compared with coal in the United States. Petcoke prices track coal prices but at discounts in

the range of 15% to 85%.13 Recently U.S. petcoke price have ranged from 67% to 68% of coal

prices.

U.S. petcoke exports have steadily increased over the last decade, as the U.S. market has given

way to increased demand overseas (see Figure 4). In 2012, 80% of marketable (i.e., non-catalyst)

petcoke was exported. The largest recipients of U.S. petcoke exports in 2012 were China (14%),

followed by Japan (11%), Mexico (9%), and Turkey (7%). China’s demand has steadily increased

during the last decade.

A search through http://www.Manta.com produced six U.S. companies matching “petroleum coke.”

“Pet Coke Piles Along Detroit River Clear Away,” CBS Detroit, August 27, 2013, http://detroit.cbslocal.com/2013/

08/27/pet-coke-piles-along-detriot-river-cleared-away/.

Personal communication with Mike Stewart, Jacobs Consultancy/Petroleum Coke Quarterly.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Figure 4. Net Petcoke Production vs. Exports

Thousand Metric Tons per Year

50,000

Thousand Metric Tons

40,000

30,000

Net

Marketable

U.S. Market

20,000

10,000

Export

Market

-10,000

-20,000

-30,000

-40,000

2005 2006 2007 2008 2009 2010 2011 2012

Net Marketable 39,474 39,818 38,694 39,529 38,105 38,895 40,749 41,376

U.S. Market

16,458 15,577 14,450 14,461 12,185 9,155 7,677 7,952

Export Market -23,016-24,241-24,244-25,068-25,920-29,740-33,071-33,424

Source: U.S. Energy Information Administration, U.S. Refinery Net Production, http://www.eia.gov/dnav/pet/

pet_pnp_refp2_dc_nus_mbbl_a.htm, and Petroleum Coke Exports by Destination, http://www.eia.gov/dnav/pet/

pet_move_expc_a_eppc_eex_mbbl_a.htm.

Potential Health and Environmental Impacts

The recent increase in coking capacity in the United States has raised concerns over the potential

impacts of petcoke on both human health and the environment. Local concerns include air quality

hazards, water quality hazards, and potential exposure to toxic substances. These impacts may

arise during various stages of petcoke’s life-cycle, including its production, handling, storage,

transportation, combustion, and use. Broader concerns have been raised about the greenhouse gas

(i.e., carbon dioxide) emissions from petcoke combustion. The focus of this report, however, is on

the impacts of handling and storage, not on end-use combustion.

EPA’s Hazard and Toxicity Characterizations

In recent years, the U.S. Environmental Protection Agency (EPA) has surveyed the potential

human health and environmental impacts of petcoke through its High Production Volume (HPV)

Challenge Program. The HPV Challenge Program, initiated jointly by EPA, Environmental

Defense Fund (EDF), American Petroleum Institute (API), and American Chemistry Council

(ACC), was instituted for several purposes, including

1. to collect health and environmental effects data on industrial chemicals produced

in the United States in high volumes,

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

2. to provide the public with basic hazard information that would allow for active

participation in environmental decision-making at all levels—local, state, and

federal, and

3. to provide EPA with valuable hazard and toxicity information to support its

mission of protecting human health and welfare.

Companies have sponsored research into more than 2,200 HPV chemicals, with approximately

1,400 administered directly through the HPV Challenge Program and the remainder administered

indirectly through international efforts.14 API sponsored a testing group for the petcoke

category,15 which produced an analysis in December 2007.16 This analysis was supplemented by

EPA, after stakeholder comments, and published in June 2011.17

The findings from EPA’s hazard characterization of petcoke are summarized in the following

sections.

Environmental Fate

Most chemical analyses of petcoke, as referenced by EPA, find it to be highly stable and nonreactive at ambient environmental conditions.

Due to the extreme conditions under which petcoke is produced, qualities such as melting point,

boiling point, vapor pressure, and water solubility exist well outside the range of ambient

conditions. If released to the environment, petcoke would not be expected to undergo many of the

environmental fate pathways which could lead to environmental risks. Depending on the particle

size and density of the material, terrestrial releases of petcoke become incorporated into the soil

or transported via wind or surface water flow. If released to the aquatic environment, petcoke

incorporates into sediment or floats on the surface, depending on the particle size and density in

relation to water. Chemically, petcoke is essentially inert. That is, petcoke does not vaporize into

the atmosphere, does not react chemically in the presence of water, and does not react chemically

in the presence of light. Furthermore, it is not biodegradable, nor does it bio-accumulate

substances—such as toxic chemicals—into its structure.18

Environmental Toxicity

Most eco-toxicity analyses of petcoke, as referenced by EPA, find it has a low potential to cause

adverse effect on aquatic or terrestrial environments.

The environmental effects of petcoke have been tested along various pathways for exposure in the

environment, including both aquatic and terrestrial endpoints in plants and animals. Aquatic and

terrestrial toxicity tests have been performed to assess the hazard of petcoke releases to

U.S. Environmental Protection Agency’s High Production Volume (HPV) Challenge Program, http://www.epa.gov/

chemrtk/index.htm.

U.S. Environmental Protection Agency, Robust Summaries & Test Plans: Petroleum Coke, http://www.epa.gov/

chemrtk/pubs/summaries/ptrlcoke/c12563tc.htm.

The American Petroleum Institute Petroleum HPV Testing Group, Petroleum Coke Category Analysis and Hazard

Characterization, submitted to EPA December 28, 2007, http://www.epa.gov/hpv/pubs/summaries/ptrlcoke/

c12563rr2.pdf.

U.S. Environmental Protection Agency, Screening-Level Hazard Characterization, Petroleum Coke Category, June

2011, http://www.epa.gov/chemrtk/hpvis/hazchar/Category_Petroleum%20Coke_June_2011.pdf.

Petcoke’s volatilization is negligible, its rate of hydrolysis is negligible, and its rate of atmospheric photo-oxidation

is negligible. Neither biodegradation nor bioaccumulation is applicable.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

representative aquatic organisms and terrestrial soil-dwelling invertebrates and plants. In these

studies, petcoke was found to be non-toxic to terrestrial plants and animals, non-toxic to aquatic

animals (both vertebrates and invertebrates), and showed only slight effects on aquatic plants at

the exposure levels tested (i.e., studies found slight growth inhibition in freshwater algae).19 (The

exposure levels and durations were conducted in accordance with EPA and Organization for

Economic Co-operation and Development (OECD) recommendations, although, presumably,

these tests could be re-administered at higher dosages or intervals to assess the effects of greater

concentrations.)

Human Health Effects

Most toxicity analyses of petcoke, as referenced by EPA, find it has a low health hazard potential

in humans, with no observed carcinogenic, reproductive, or developmental effects. Only animal

cases studies of repeated-dose and chronic inhalation have shown respiratory inflammation

attributed to the non-specific effects of dust particles rather than the specific effects of petcoke.

Inhalation of and skin contact with petcoke were assessed to be the most likely exposure routes to

humans. Most repeated-dose inhalation exposure studies (on rats and primates) found cases of

irreversible respiratory effects and significantly increased lung weights. These effects were

considered to be non-specific responses of the respiratory tract to high concentrations of dust

particles rather than compound specific-induced effects. Petcoke was not found to be

carcinogenic via inhalation. No excess skin or visceral cancers were observed in a lifetime skin

painting study. Petcoke was not found to produce genetic mutations in bacteria and mammalian

cells in standard in vitro toxicity tests or to produce chromosome aberrations of bone marrow in

standard in vivo toxicity tests. Petcoke was not found to produce any reproductive or

developmental effects following repeated inhalation or exposure to the skin.20

Reactivity

Petcoke is generally stable under normal conditions; however, the substance has the potential to

become flammable or explosive. Emissions from the combustion—either accidentally or

purposefully—of petcoke can have impacts on human health and the environment, including the

release of common pollutants, hazardous substances, and greenhouse gases.

When petcoke is combusted, common pollutants and hazardous decomposition products may be

produced such as carbon monoxide, carbon dioxide, sulfur dioxide, nitrogen oxides, particulate

matter, and heavy metals, depending upon the chemical composition of the feedstock (see Table 1

Environmental toxicity studies referenced by the EPA analysis include Wildlife International, Ltd., Petroleum Coke:

A 96-Hour Static-Renewal Acute Toxicity Test with the Fathead Minnow (Pimephales promelas), Final Report, Project

No. 472A-1134, 2006; Wildlife International, Ltd., Petroleum Coke: A 48-Hour Static-Renewal Acute Immobilisation

Test with the Cladocern (Daphnia magna), Final Report, Project No. 472A-112, 2006; Wildlife International, Ltd.,

Petroleum Coke: A 96-Hour Toxicity Test with the Freshwater Alga (Selenastrum capricornutum), Final Report,

Project No. 472A-114, 2006; Wildlife International, Ltd., Petroleum Coke: A 21-Day Toxicity Test to Determine the

Effects of the Test Substance on Seedling Emergence and Growth of Terrestrial Plants, Final Report, Project No. 472102, 2006; Wildlife International, Ltd., Petroleum Coke: A 14-Day Acute Toxicity Test with the Earthworm (Eisenia

fetida), Final Report, Project No. 472-101, 2006.

Toxicity studies referenced by the EPA analysis include Huntingdon Life Sciences, Study No. 03-4246, “Petroleum

Coke: Reproduction/Developmental Toxicity Screening Study in Rats via Nose-Only Inhalation Exposures,” 2006;

Klonne, D. R., Burns, J. M., Halder, C. A., Holdsworth, C. E. and Ulrich, C. E., “Two Year Inhalation Study of

Petroleum Coke in Rats and Monkeys.” American Journal of Industrial Medicine, 11:375-389, 1987; and IRDC

(International Research & Development Corporation), “Chronic Inhalation Toxicity Study of Petroleum Coke (Delayed

Process) in Rats and Monkeys,” API Publication number 32-30234, 1985.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

for the chemical composition of petcoke). These releases may take place unintentionally, through

the natural or unintended combustion of surface or air-borne dust particles, or intentionally,

through the combustion of petcoke for electrical power generation or other like purposes.

Petcoke’s use as a fuel is criticized because it commonly has higher greenhouse gas emissions

relative to the amount of heat it generates when burned. Table 3 presents potential carbon dioxide

(CO2) emissions for petcoke in comparison to metallurgical coke and several grades of steam

coal. When petcoke or coal combust, CO2 forms from one carbon atom (C) uniting with two

oxygen atoms (O).21 Assuming complete combustion, 1 pound of carbon combines with 2.667

pounds of oxygen to produce 3.667 pounds of carbon dioxide. Petcoke with a carbon content of

90% and a heating value of 14,200 Btu per pound emits about 232 pounds of carbon dioxide per

million Btu when completely burned.22 Comparatively, Powder River Basin coal with a carbon

content of 48% and a heating value of 8,800 Btu per pound emits about 202 pounds of carbon

dioxide per million Btu when completely burned, or 15% less than petcoke. Because coal has

high hydrogen-to-carbon ratio compared to petcoke, part of its energy content comes from the

combustion of hydrogen that is emitted as water vapor instead of carbon dioxide.

Table 3. Petcoke vs. Coal: Combustion Emissions

Coal Rank

Sulfur

%wt.

Btu / lb.

Carbon

%wt.

Petcoke

n.a.

1.5–6.0

14,200

89–92

232

Metcoke

Metallurgic

0.4–0.7

12,600

91–92

266

Pittsburgh #8

Bituminous

3.0

13,000

73–74

207

Illinois #6

Bituminous

3.9

11,000

60–61

201

Powder River Basin

Sub-bituminous

0.5

8,800

48–49

202

Fuel

CO2 lbs./

Million Btu

Steam Coal

Source: MIT, The Future of Coal Appendices, p. P5.

Notes: Potential carbon dioxide emissions calculated by percent carbon ÷ Btu per pound x 36,670 = pounds

(lbs.) of carbon dioxide per million Btu.

Federal Regulatory Requirements

Various aspects of the production, handling, storage, transportation, combustion, and use of

petcoke have been addressed at local, state, and federal levels to protect human health and the

environment. While some federal statutes address certain environmental impacts of petcoke’s lifecycle, most regulatory action and oversight has been undertaken at the state and local levels,

generally through facility-specific permitting requirements. With few exceptions, petcoke is not

specifically regulated by local, state, or federal codes.23 Rather, it is petcoke’s potential

B. D. Hong and E. R. Slatick, Carbon Dioxide Emission Factors for Coal, U.S. Energy Information Administration,

http://www.eia.gov/coal/production/quarterly/co2_article/co2.html.

Potential carbon dioxide emissions can be calculated by use of the following formula: percent carbon ÷ Btu per

pound x 36,670 = pounds (lbs.) of carbon dioxide per million Btu.

In a survey of state statutes, conducted by the U.S. Library of Congress’s Law Library for this report on August 9,

2013, California was found to be the only state which has passed laws to directly manage the environmental impacts

from the handling, storage, and transportation of petcoke. California State Code on petcoke included California Code–

HSC Section 40459 (requirements for enclosing piles of petcoke when storing the substance prior to shipment),

http://www.leginfo.ca.gov/cgi-bin/displaycode?section=hsc&group=40001-41000&file=40440-40459, and California

(continued...)

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

contribution to more general hazards (e.g., air and water quality impacts such as haze, fugitive

dust, and stormwater runoff) that is monitored and controlled through various permitting and

reporting requirements at the state and local levels. This report focuses on the federal response to

petcoke and on the rules that may be implemented during the handling, storage, and

transportation phases of petcoke’s life-cycle. States may also have their own laws or regulations

related to the handling, storage, and transportation of petcoke, specifically, or high-productionvolume industrial substances like petcoke, more generally; a full review of state and local code is

beyond the scope of this report.

Regulatory agencies at all levels of government commonly aim to manage the human health and

environmental impacts of industrial materials (e.g., petcoke) based upon thorough assessments of

their hazardous exposure pathways. Because of its relative inertness, exposure to petcoke is

considered to pose few human health and environmental risks. Thus, federal law generally

exempts petcoke from classification as either a solid or hazardous waste. Despite these

exemptions, petcoke may nevertheless present significant nuisance concerns. A “nuisance” is the

unreasonable, unwarranted and/or unlawful use of property, which causes inconvenience or

damage to others, either to individuals or to the general public.24 A nuisance may not violate any

regulatory standard or cause demonstrable environmental or health impacts; however, if a

nuisance interferes with a person’s use of his or her property, it may be the basis for a lawsuit for

damages or an injunction. For example, fugitive dust from petcoke storage piles can be deposited

on and in nearby waterways, outdoor areas, or residents’ homes, leaving a black- or grey-colored

residue. This deposition may result in undesirable and unsightly conditions, interfering with

residents’ comfort and use of their property. Similarly, dust from coke piles can challenge the

operations of commercial or industrial facilities, such as pharmaceutical research and production

plants, electronics assembly, or fuel cell membrane manufacturing. Dust from nearby coke piles

can increase filtration costs or threaten the integrity of strict quality control standards required for

such high technology operations.

In light of these issues, the monitoring and management of petcoke at the federal level is

summarized in the following sections.

Waste Classifications

Federal law generally exempts petcoke from classification as either a solid or hazardous waste.

The exemption for petcoke from classification as either a solid or hazardous waste stems from the

scope of the statutory term “solid waste” as decided in American Mining Congress v. U.S. EPA.25

(...continued)

Code–VEH Section 23114 (requirements for the transportation of petcoke by vehicle), http://www.leginfo.ca.gov/cgibin/displaycode?section=veh&group=23001-24000&file=23100-23135.

A nuisance may be either a private nuisance or a public nuisance. An activity constitutes a private nuisance if it is a

substantial and unreasonable invasion of another’s interest in the private use and enjoyment of land, without involving

trespass. Private nuisance actions are brought by the aggrieved landowner. An activity is a public nuisance if it creates

an “unreasonable” interference with a right common to the general public. Unreasonableness may rest on the activity

significantly interfering with, among other things, public health and safety. Public nuisance cases are usually brought

by the government rather than private entities, but may be brought by the latter if they suffer special injury.

American Mining Congress v. U.S. EPA, 824 F.2nd 1177 (D.C. Cir. 1987). The court held that the EPA exceeded its

authority by amending its definition of “solid waste” under the Resource Conservation and Recovery Act (RCRA) to

include secondary materials destined for reuse within an industry’s ongoing production process. The court held that

EPA’s interpretation is contrary to RCRA’s plain language (§ 1004(5) defines solid waste to include “discarded

material”), and that EPA’s inclusion of materials retained for immediate use as discarded material strains the everyday

usage of that term.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

In that decision, the court held that materials recycled and reused in an ongoing manufacturing or

industrial process were not considered to be “discarded,” and hence, not considered to be “solid

wastes.” Furthermore, in 1998, EPA identified a list of petroleum refining wastes that would be

subject to federal regulations applicable to the management of hazardous waste established under

the Resource Conservation and Recovery Act (RCRA).26 In this rulemaking, EPA stated that

petcoke is not a refining waste, but rather a “co-product” of the refining process.27 In separate

rulemaking, EPA included petcoke among other fuels in its definition of “traditional fuels” (at 40

C.F.R. 241.2). As a result of these determinations, unless or until it is discarded, petcoke would

not be subject to federal waste management requirements established under RCRA.

Petcoke would not be subject to the federal cleanup authorities of the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA, often referred to as

Superfund)28 because of the exclusion of petroleum from the statute. The response authorities of

CERCLA specifically apply to the release of hazardous substances, pollutants, or contaminants

into the environment. Hazardous substances under CERCLA are broader than hazardous wastes

under RCRA and include hundreds of toxic chemicals. However, CERCLA defines a hazardous

substance, pollutant, or contaminant to exclude “petroleum, including crude oil or any fraction

thereof which is not otherwise specifically listed or designated as a hazardous substance.”29 EPA’s

interpretation has been that hazardous substances present in petroleum that are naturally occurring

or are normally added during the refining process are fractions of the petroleum that would fall

within the scope of the exclusion from CERCLA. EPA’s position has been that CERCLA may be

applied to the cleanup of wastes containing petroleum, if the wastes contain hazardous substances

that are not part of the petroleum product itself.30 Hazardous substances that may leach from a

petroleum product into the environment, and therefore no longer be part of the petroleum product,

may raise other issues.

42 U.S.C. 6901 et seq. For further discussion of the authorities of RCRA, see CRS Report RL30798, Environmental

Laws: Summaries of Major Statutes Administered by the Environmental Protection Agency, coordinated by (name red

acted) .

See U.S. Environmental Protection Agency, Final Rule, “Hazardous Waste Management System; Identification and

Listing of Hazardous Waste; Petroleum Refining Process Wastes; Land Disposal Restrictions for Newly Identified

Wastes; and CERCLA Hazardous Substance Designation and Reportable Quantities,” August 6, 1998, 63 Federal

principal products are the light ends that are returned to the refining process. Thus, the Agency is affirming that the

conventional coking operation is a production process, resids are normal feedstocks to this process and petroleum coke

is a legitimate fuel product.” Id, at page 42121.

42 U.S.C. 9601 et seq. For further discussion of the authorities of CERCLA, see CRS Report R41039,

Comprehensive Environmental Response, Compensation, and Liability Act: A Summary of Superfund Cleanup

Authorities and Related Provisions of the Act, by (name redacted) .

The definition of the term “hazardous substance” in Section 101 (14) of CERCLA is codified at 42 U.S.C. 9601(14).

The definition of the terms “pollutant” and “contaminant” in Section 101(33) of CERCLA is codified at 42 U.S.C.

9601(33).

U.S. Environmental Protection Agency, Office of General Counsel, Scope of the CERCLA Petroleum Exclusion

Under Sections 101(14) and 104(a)(2), July 31, 1987. Section 104(a)(2) of CERCLA, as originally enacted in 1980,

defined the term “pollutant or contaminant.” Section 101(f) of the Superfund Amendments and Reauthorization Act of

1986 re-designated the definition of this term in Section 101(33) of CERCLA, cited above. The full text of the 1987

guidance is available at http://www.epa.gov/compliance/resources/policies/cleanup/superfund/petro-exclu-mem.pdf.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Industrial Stormwater Runoff

The handling and storage of petcoke may be regulated under certain provisions of the National

Pollutant Discharge Elimination System (NPDES) permit program,31 as authorized by the Clean

Water Act (CWA),32 if it is determined that runoff from storage sites due to rain or snowmelt has

the potential to transport the substance to nearby surface waters.

Activities that take place at industrial facilities, such as material handling and storage, are often

exposed to the weather. As runoff from rain or snowmelt comes into contact with these activities,

it can pick up pollutants and transport them to a nearby storm sewer system or directly to a river,

lake, or coastal water. Recognition of the water quality problems of stormwater runoff led

Congress in 1987—when it last comprehensively amended the CWA—to direct EPA to

implement a specific permit program for stormwater discharges from industrial sources and

municipalities (P.L. 100-4). These stormwater requirements were incorporated into the National

Pollutant Discharge Elimination System (NPDES), a comprehensive permit program authorized

in Section 402 of the CWA. Under the act, it is illegal to discharge pollutants from point sources

(e.g., industrial plant pipes, sewage treatment plants, or storm sewers) into the nation’s waters

without a permit. NPDES permits are the fundamental compliance and enforcement mechanism

of the law. EPA manages the NPDES stormwater program in four states (Idaho, Massachusetts,

New Hampshire, and New Mexico), plus the District of Columbia and most U.S. territories, and

has delegated that authority to the remaining 46 states and the Virgin Islands. Therefore, the vast

majority of industrial and other facilities obtain NPDES permit coverage for stormwater

discharge through their state. Petroleum refining facilities are one of several categories of

facilities that are specifically covered under the CWA stormwater regulatory program.

Common requirements for coverage under an industrial stormwater permit include development

of a written stormwater pollution prevention plan (SWPPP), implementation of control measures,

and submittal of a request for permit coverage, usually referred to as the Notice of Intent (NOI).

The SWPPP is a written assessment of potential sources of pollutants in stormwater runoff and

control measures that will be implemented at the facility to minimize the discharge of these

pollutants in runoff from the site. These control measures include site-specific best management

practices, maintenance plans, inspections, employee training, and reporting. The procedures

detailed in the SWPPP must be implemented by the facility and updated as necessary, with a copy

of the SWPPP kept on-site. The industrial stormwater permit also requires collection of visual,

analytical, and compliance monitoring data to determine the effectiveness of implemented best

management practices. Stormwater permits are valid for up to five years and must be renewed.

Best management practices for the prevention of industrial stormwater runoff include ensuring

adequate storage facilities and equipment, spill detection and repair, and employee training. Many

environmental agencies, including EPA, provide extensive summaries of best management

practices.33

For further discussion on the NPDES Permit Program, see CRS Report 97-290, Stormwater Permits: Status of EPA’s

Regulatory Program, by (name redacted) , as well as U.S. Environmental Protection Agency, “National Pollutant

Discharge Elimination System,” http://cfpub.epa.gov/npdes/.

33 U.S.C. §§1251-1387. For further discussion of the authorities of CWA, see CRS Report RL30030, Clean Water

Act: A Summary of the Law, by (name redacted) .

An extensive list of best management practices for stormwater runoff, included under the general categories of “good

housekeeping practices,” “minimize exposure,” “erosion and sediment control,” and “management of runoff,” can be

found in U.S. Environmental Protection Agency, Industrial Stormwater, Fact Sheet Series, Sector C: Chemical and

Allied Products Manufacturing and Refining, U.S. EPA Office of Water, EPA-833-F-06-018, December 2006,

http://www.epa.gov/npdes/pubs/sector_c_chemical.pdf.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Fugitive Dust

The handling, storage, and transportation of petcoke may create instances of reduced air quality

due to weather or activity related releases of fugitive dust into the atmosphere. Most of the

impacts of fugitive dust are localized; and thus, much of the regulatory oversight is implemented

at the local and state level and generally takes the form of a fugitive dust control program.

Facilities may be required by state or local agencies to develop a fugitive dust control program for

many reasons. State and local agencies, based on their own air emission measurements, their own

code of regulations, environmental consent orders, or complaints of nuisance, may require a

fugitive dust program from any facility if it processes, uses, stores, transports, or conveys bulk

materials from a highly emitting dust source. Further, these programs are often a necessary

component to any air permitting requirements at the state and local level, including permits to

install, operate, or decommission a facility. At the federal level, Clean Air Act (CAA)34 National

Ambient Air Quality Standards (NAAQS) have been set nationwide by EPA for particulate matter

(PM).35 NAAQS are standards for outdoor (ambient) air that are intended to protect public health

and welfare from harmful concentrations of pollution. If fugitive dust generation is determined to

be an issue at a facility that produces, handles, stores, transports, or uses petcoke, and if the

facility is situated in an area that is identified by the EPA as “nonattainment” for PM NAAQS,

then it may be possible for state authorities to ask the facility to report on and manage its fugitive

dust emissions—if it is not doing so already—within the context of their State Implementation

Plans (SIPs).

Whether petcoke storage is considered a significant source of PM depends a number of factors,

including how the coke is handled (e.g., number of drops), individual petcoke particle sizes and

the size of the overall petcoke piles, as well as the storage method. In some cases, petcoke may

have been processed through pulverization that generates dust which could be monitored and

controlled at PM2.5 (less than 2.5 microns). PM2.5 can produce greater health impacts because it is

more respirable than “coarse” PM which is larger than 2.5 microns. PM that is greater than about

10 microns is generally considered less of a health risk because it is less respirable. As illustrated

in Figure 1, most forms of petcoke are comprised of granules orders of magnitude larger than

PM2.5, and are not likely respirable, but may pose a nuisance concern. Also, in some cases,

petcoke storage may be ephemeral because markets support frequent elimination of stored

inventories.

The management of fugitive dust commonly involves the submission of a fugitive dust plan to

state or local agencies. These plans would include an analysis of the quantity and opacity of

fugitive dust from the facility; a determination of the type of fugitive dust control methods that

would be the most effective, taking into account the quantity, moisture content, specific gravity,

and particle size distribution of the bulk materials on-site; an assessment of the type of control

technologies, methods, and equipment to be implemented or installed, and the schedule for

implementation or installation; and a report on the level of recordkeeping and maintenance

requirements for activities that are implemented under the dust program. Fugitive dust plans

commonly set out an operating program designed to significantly reduce emissions to the lowest

level that a particular source is capable of achieving by the application of control technology that

is both reasonably available and based on technological and economic feasibility. The

33 U.S.C. §§1251-1387. For further discussion of the authorities of CWA, see CRS Report RL30030, Clean Water

Act: A Summary of the Law, by (name redacted) .

For further discussion of particulate matter, see CRS Report RL34762, The National Ambient Air Quality Standards

(NAAQS) for Particulate Matter (PM): EPA’s 2006 Revisions and Associated Issues, by (name redacted) .

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

requirement for fugitive dust plans for a given facility and the plan’s enforcement remain at the

discretion of the state and local agencies.

Best management practices for the prevention of fugitive dust include ensuring adequate storage

facilities and equipment, emission detection and repair, and employee training. Many

environmental agencies, including the U.S. EPA, provide extensive summaries of best

management practices.36

Regulatory Standards for Petcoke Combustion in Power Generation

The combustion of petcoke, and the resulting emissions from this combustion, may be regulated

under several different provisions in the CAA and the CWA.

When petcoke is used for industrial or power generating purposes, emissions from its combustion

are regulated under the standards set on the respective facilities. For example, some of the federal

regulations which may be implemented by the combustion of petcoke at industrial or power

generating facilities include EPA’s New Source Performance Standards for Electricity Generating

Units, Clean Air Interstate Rule (CAIR) for NOx and SO2, CAA Title V Permitting Requirements,

GHG Reporting Program, Steam Electric Effluent Guidelines, recently finalized Mercury and Air

Toxics Standards/Utility MACT, and proposed Coal Combustion Waste Rules, as well as the

various state rules under State Implementation Plans.

A full description of these requirements is beyond the scope of this report.

Conclusion

Petcoke production depends on the crude oil demand of operating refineries that in tum depend

on the availability of heavy and light crude oils and their comparative cost advantages. The

domestic production of petcoke may increase as U.S. refineries continue to add coking capacity to

take advantage of competitively priced petroleum produced from Canada’s oil sands and other

heavy crude oil sources. Conversely, as U.S. light crude oil production increases, U.S. coking

refineries may find an economic advantage in switching to lighter crude oils and idle their coking

units. If that occurs, the production and export of U.S. petcoke may reverse.

Community stakeholder and regulator concerns about fugitive dust emission into the air and

stormwater runoff into waterways are likely to continue in situations where there is not sufficient

mitigation and abatement. In some states, permit conditions have been imposed to mitigate the

emissions from petcoke storage and handling. The specific permit conditions (e.g., enclosed

conveyors and storage silos) are generally based on best management practices as determined by

state regulators. At the federal level, Clean Air Act (CAA) National Ambient Air Quality

Standards (NAAQS) for outdoor (ambient) air continue to protect public health and welfare from

harmful concentrations of particulate matter pollution. If states determine that fugitive dust

generation is an issue at a facility that produces, handles, stores, transports, or uses petcoke, and if

the facility is situated in an area that is identified by the EPA as “nonattainment” for PM NAAQS,

then state authorities may ask the facility to report on and manage its fugitive dust emissions—if

it is not doing so already—within the context of their State Implementation Plans (SIPs). States

An extensive list of emission control techniques for fugitive dust can be found in U.S. Environmental Protection

Agency, Fugitive Dust Background Document and Technical Information Document for Best Available Control

Measures, U.S. EPA Office of Air and Radiation, EPA-450/2-92-004, September 1992, http://www.epa.gov/oaqps001/

lead/pdfs/1992_09_fugitive_dust.pdf.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

and localities may also have their own regulatory standards for fugitive dust, independent of

whether the area is in nonattainment of federal PM NAAQS.

In light of these concerns, industry, regulators, and compliance officers have shown a continued

interest in impact assessment and best practices related to the storing, containing, and managing

of petcoke. Two bills have been introduced in the 113th Congress regarding petcoke: H.R. 2298,

the Petroleum Coke Transparency and Public Health Study Act (introduced 6/6/2013), and S.

1388, Petroleum Coke Transparency and Public Health Study Act (introduced 7/30/2013). Each

would require the Secretary of Health and Human Services, in consultation with the

Administrator of the Environmental Protection Agency, to conduct a study on the public health

and environmental impacts of the production, transportation, storage, and use of petcoke.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Appendix. Petroleum Refining and Petcoke

Production

Petroleum refineries use several key processes to convert crude oil systematically into refined

products; these include atmospheric distillation, hydrocracking, hydrotreating, reforming, and

ultimately coking. The refinery’s atmospheric distillation column initially separates crude oil into

lighter streams of hydrocarbons based on their boiling temperatures. The gasoline-range of

petroleum distillates condense at the top of the column. Middle distillate fuels (kerosene, jet, and

diesel fuels) condense in the middle of the column. The heavier-still range of gas oils condense

lower in the column. Residuum, a heavy tar-like material figuratively referred to as the “bottom

of the barrel,” has such a high boiling temperature that it remains at the bottom of the column.

In order to produce more gasoline, refineries “crack” the heavier distillation products into the

gasoline range with heat, pressure, hydrogen, and catalysts. Hydrotreating removes elemental

sulfur from gasoline and middle-distillate fuels through a reaction with hydrogen gas.

Coking dates back to the late 1920s, but became an important process for U.S. refineries during

the 1980s and 1990s. During this time, refineries faced a dwindling supply of light sweet crude

oils favored for making gasoline and distillate fuels. They began switching to increasingly more

available, heavy-sour crude oils. The resid that remained after refining heavier crudes initially

found use as “ship’s bunker fuel” and as boiler fuel in electric power plants. With the

implementation of Clean Air Act regulations, power plants switched from boiler fuel to cleaner

burning natural gas. During the same era, the demand for gasoline increased, and refineries began

adding coking to convert the “resid” into motor fuels.

Coking initially converts petroleum residuum into lighter range hydrocarbons; low-Btu gas that

can serve as a fuel in refinery operations; and “green coke.”

Refineries commonly employ one of three types of coking processes:



delayed coking—a thermal cracking process that converts residuum into gasified

products streams and concentrated carbon coke. It is called “delayed coking”

because cracking takes place in a coke drum rather than in a furnace or reactor.

The residuum is heated in a furnace first, and then fed into the bottom of the coke

drum. The “cracked” light products are drawn off at the top of the drum and sent

to a fractionator which separates out gasoline, naphtha, gas oil, and lighter

products. The drums are “de-coked” by hydraulic or mechanical cutting

processes. In delayed coking, one coking drum is filled while a second is decoked (emptied). First commercialized in 1928, delayed coking predominates

among U.S. refineries that process heavy crude oil. See Figure A-1.

flexi-coking—a continuous fluidized-bed thermal cracking process integrated

with coke gasification. It converts most of the carbon coke to carbon monoxide

(CO), which is then mixed with carbon (C2) and lighter hydrocarbons to produce

a low quality fuel gas. The process was commercialized in 1976. See Figure A-2.

fluid coking—a variation on flexi-coking that uses a cyclone to separate the coke.

The process was commercialized in 1954.

Congressional Research Service

Petroleum Coke: Industry and Environmental Issues

Figure A-1. Shell Delayed Coking Unit

Puget Sound Refinery

Figure A-2. ExxonMobil Flexi-Coking

Unit

Rotterdam, The Netherlands

Source: ExxonMobil Research & Engineering

Company, Upgrading of Heavy Oils with Flexicoking.

Source: Shell.

Independent processors convert the green coke into to either fuel grade or anode grade coke

depending upon the crude oil refined and the coking process used.

Congressional Research Service

Figure A-3. U.S. Refineries with Coking Capacity

by Petroleum Adminstration for Defense Districts (PADD)

Source: Prepared for CRS by the Library of Congress.

Notes: See Table A-1 for a list of refineries.

CRS-19

Figure A-4. Coking Refineries by PADD

Source: Compiled by CRS from various sources.

CRS-20

Figure A-5. Refining and Coking Capacity by PADD

Source: Compiled by CRS from various sources.

Notes: Coking capacity denotes the throughput capacity to process petroleum resid.

CRS-21

Table A-1. U.S. Refineries with Coking Capacity

Advertised Refinery Capacity in Barrels per Day (Bbl/D)

PADD

Paulsboro

08066

PBF/ Paulsboro Refinery

180,000

1st New Jersey

Delaware

19706

PBF/Delaware City

190,000

At large Delaware

Roxana

62084

Phillips 66/ Wood River Refinery

306,000

12th Illinois

Drummond

60410

ExxonMobil/ Joliet Refinery

250,000

16th Illinois

Robinson

62454

Marathon/ Robinson Refinery

206,000

15th Illinois

Lemont

60439

Citgo/ Lemont Refinery

167,000

3rd Illinois

Whiting

46394

BP/ Whiting Refinery

413,000

1st Indiana

El Dorado

67042

Holly-Frontier/ El Dorado Refinery

135,000

4th Kansas

Coffeyville

67337

CVR Coffeyville Refinery

115,000

2nd Kansas

McPherson

67460

Cenex-NCRA/ McPherson Refinery

85,000

1st Kansas

Detroit

48217

Marathon/ Detroit Refinery

106,000

13th Michigan

Rosemont

55068

Flint Hills/ Pine Bend Refinery

320,000

2nd Minnesota

Oregon

43616

BP-Husky/ Toledo Refinery

160,000

9th Ohio

Lima

45804

Husky/ Lima Refinery

155,000

4th Ohio

Ponca City

74601

Phillips 66/ Ponca City Refinery

187,000

3rd Oklahoma

Tuscaloosa

35401

Hunt/ Tuscaloosa Refinery

72,000

7th Alabama

Baton Rouge

70805

ExxonMobil/ Baton Rouge Refinery

503,500

2nd Louisiana

Garyville

70051

Marathon/ Garyville Refinery

490,000

2nd Louisiana

Lake Charles

70601

Citgo/ Lake Charles Refinery

425,000

3rd Louisiana

Norco

70079

Valero/ St. Charles Refinery

270,000

6th Louisiana

Belle Chasse

70037

Phillips 66/ Alliance Refinery

247,000

1st Louisiana

CRS-22

City

Zip

Facility

Bbl/D

Congressional District

PADD

Westlake

70669

Phillips 66/ Lake Charles Refinery

239,000

3rd Louisiana

St. Charles Parrish

70079

Motiva/ Norco Refinery

234,700

6th Louisiana

Chalmette

70043

ExxonMobil/ Chalmette Refinery

192,500

1st Louisiana

Pascagoula

39581

Chevron/ Pascagoula Refinery

330,000

4th Mississippi

Port Arthur

77641

Motiva/ Port Arthur Refinery

600,000

14th Texas

Baytown

77520

ExxonMobil/ Baytown Refinery

573,000

36th Texas

Texas City

77590

Marathon/ Texas City Refinery

475,000

14th Texas

Beaumont

77703

ExxonMobil/ Beaumont Refinery

365,000

14th Texas

Deer Park

77536

Shell/ Deer Park Refinery

340,000

36th Texas

Corpus Christi

78407

Valero/ Bill Greehy Refinery Complex East

325,000

27th Texas

Port Arthur

77641

Valero/ Port Arthur Refinery

310,000

14th Texas

Houston

77017

Lyondell/ Houston Refinery

268,000

29th Texas

Sweeny

77463

Phillips 66/ Sweeny Refinery Complex

247,000

14th Texas

Texas City

77590

Valero/ Texas City Refinery

245,000

14th Texas

Port Arthur

77642

Total/ Port Arthur Refinery

174,000

14th Texas

Corpus Christi

78047

Citgo/ Corpus Christi Refinery East & West Plant

165,000

27th Texas

Corpus Christi

78408

Flint Hills/ Corpus Christi Refining Complex East Plant

150,000

27th Texas

Borger

79007

Phillips 66/ Borger Refinery

146,000

13th Texas

Pasadena

77506

Petrobras/ Pasadena Refinery

100,000

29th Texas

Tyler

75702

Delek/ Tyler Refinery

60,000

1st Texas

Billings

59101

ExxonMobil/ Billings Refinery

60,000

At Large Montana

Billings

59101

Phillips 66/ Billings Refinery

58,000

At Large Montana

Salt Lake City

84116

Chevron/ Salt Lake City Refinery

45,000

2nd Utah

CRS-23

City

Zip

Facility

Bbl/D

Congressional District

PADD

City

Zip

Facility

Bbl/D

Congressional District

Cheyenne

82007

Holly-Frontier/ Cheyenne Refinery

52,000

At Large Montana

Paramount

90723

Alon/ California Refineries

70,000

40th California

El Segundo

90245

Chevron/ El Segundo Refinery

290,000

33rd California

Benicia

94510

Valero/ Benicia Refinery

170,000

5th California

Martinez

94553

Tesoro/ Golden Eagle Refinery

166,000

5th California

Martinez

94553

Shell/ Martinez Refinery

165,000

5th California

Torrance

90509

ExxonMobil/ Torrance Refinery

150,000

43rd California

Carson

90745

Phillips 66/ Los Angeles Refinery

139,000

44th California

Wilmington

90744

Valero/ Wilmington Refinery

135,000

44th California

Wilmington

90744

Tesoro Los/ Angeles Refinery

97,000

44th California

Blaine

98230

BP/ Cherry Point Refinery

230,000

1st Washington

Anacortes

98221

Shell/ Puget Sound Refinery

145,000

2nd Washington

Source: Various

Notes: Alon operates three units in Bakersfield, Paramount, and Long Beach, CA, as one refinery, but the delayed coker is reported as inactive.

CRS-24

Petroleum Coke: Industry and Environmental Issues

Author Contact Information

(name redacted)

Analyst in Environmental Policy

[redacted]@crs.loc.gov , 7-....

Acknowledgments

This report was originally co-authored by (name redacted), former CRS Specialist in Energy Policy. The

current author would also like to thank (name redacted), Graphics Specialist, Congressional Research

Service; Jacqueline V. Nolan, Cartographer, Library of Congress; Cassandra Foley, Law Librarian,

Congressional Research Service; and James Werner, Environmental Policy Section Research Manager,

Congressional Research Service.

Congressional Research Service

EveryCRSReport.com

The Congressional Research Service (CRS) is a federal legislative branch agency, housed inside the

Library of Congress, charged with providing the United States Congress non-partisan advice on

issues that may come before Congress.

EveryCRSReport.com republishes CRS reports that are available to all Congressional staff. The

reports are not classified, and Members of Congress routinely make individual reports available to

the public.

Prior to our republication, we redacted names, phone numbers and email addresses of analysts

who produced the reports. We also added this page to the report. We have not intentionally made

any other changes to any report published on EveryCRSReport.com.

CRS reports, as a work of the United States government, are not subject to copyright protection in

the United States. Any CRS report may be reproduced and distributed in its entirety without

permission from CRS. However, as a CRS report may include copyrighted images or material from a

third party, you may need to obtain permission of the copyright holder if you wish to copy or

otherwise use copyrighted material.

Information in a CRS report should not be relied upon for purposes other than public

understanding of information that has been provided by CRS to members of Congress in

connection with CRS' institutional role.

EveryCRSReport.com is not a government website and is not affiliated with CRS. We do not claim

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.