# Petroleum Coke: Industry and Environmental Issues

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URL: https://www.frixlaw.com/law-library/documents/crs%3AR43263

## Record

- **Collection:** Congressional research report
- **Document type:** CRS Report
- **Published:** October 29, 2013
- **Citation:** R43263

## 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.

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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

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

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

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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

1

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

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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

2

Thermal coal is sometimes called “steam coal” because it is used to fire boiler plants that produce steam for electricity
generation and industrial uses.

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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

3

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.
4
Bituminous coals are mined throughout the eastern United States range but generally have higher sulfur and nitrogen
contents than western coals.
5
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.

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

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

6

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.

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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.

7

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.
8
American Iron and Steel Institute, Annual Statistical Report, 2012, p.80. Production and Consumption of Coke.
9
U.S. Energy Information Administration, Monthly Energy Review, Coal, June 2013, http://www.eia.gov/totalenergy/
data/monthly/index.cfm#coal.
10
U.S. Energy Information Administration, Refinery Utilization and Capacity, http://www.eia.gov/dnav/pet/
pet_pnp_unc_dcu_nus_a.htm.

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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.

11

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/.
13
Personal communication with Mike Stewart, Jacobs Consultancy/Petroleum Coke Quarterly.
12

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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
0

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,

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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
14

U.S. Environmental Protection Agency’s High Production Volume (HPV) Challenge Program, http://www.epa.gov/
chemrtk/index.htm.
15
U.S. Environmental Protection Agency, Robust Summaries & Test Plans: Petroleum Coke, http://www.epa.gov/
chemrtk/pubs/summaries/ptrlcoke/c12563tc.htm.
16
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.
17
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.
18
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.

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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
19

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.
20
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.

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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
21

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.
22
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.
23
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...)

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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.
24
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.
25
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.

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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.

26

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) .
27
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
Register 42110. “The coke product itself may best be characterized as a co-product of the coking operation, while the
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.
28
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) .
29
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).
30
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.

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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
31

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/.
32
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) .
33
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.

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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
34

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) .
35
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) .

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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
36

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.

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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.

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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.

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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.

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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

St

1

NJ

Paulsboro

08066

PBF/ Paulsboro Refinery

180,000

1st New Jersey

1

DE

Delaware

19706

PBF/Delaware City

190,000

At large Delaware

2

IL

Roxana

62084

Phillips 66/ Wood River Refinery

306,000

12th Illinois

2

IL

Drummond

60410

ExxonMobil/ Joliet Refinery

250,000

16th Illinois

2

IL

Robinson

62454

Marathon/ Robinson Refinery

206,000

15th Illinois

2

IL

Lemont

60439

Citgo/ Lemont Refinery

167,000

3rd Illinois

2

IN

Whiting

46394

BP/ Whiting Refinery

413,000

1st Indiana

2

KS

El Dorado

67042

Holly-Frontier/ El Dorado Refinery

135,000

4th Kansas

2

KS

Coffeyville

67337

CVR Coffeyville Refinery

115,000

2nd Kansas

2

KS

McPherson

67460

Cenex-NCRA/ McPherson Refinery

85,000

1st Kansas

2

MI

Detroit

48217

Marathon/ Detroit Refinery

106,000

13th Michigan

2

MN

Rosemont

55068

Flint Hills/ Pine Bend Refinery

320,000

2nd Minnesota

2

OH

Oregon

43616

BP-Husky/ Toledo Refinery

160,000

9th Ohio

2

OH

Lima

45804

Husky/ Lima Refinery

155,000

4th Ohio

2

OK

Ponca City

74601

Phillips 66/ Ponca City Refinery

187,000

3rd Oklahoma

3

AL

Tuscaloosa

35401

Hunt/ Tuscaloosa Refinery

72,000

7th Alabama

3

LA

Baton Rouge

70805

ExxonMobil/ Baton Rouge Refinery

503,500

2nd Louisiana

3

LA

Garyville

70051

Marathon/ Garyville Refinery

490,000

2nd Louisiana

3

LA

Lake Charles

70601

Citgo/ Lake Charles Refinery

425,000

3rd Louisiana

3

LA

Norco

70079

Valero/ St. Charles Refinery

270,000

6th Louisiana

3

LA

Belle Chasse

70037

Phillips 66/ Alliance Refinery

247,000

1st Louisiana

CRS-22

City

Zip

Facility

Bbl/D

Congressional District

PADD

St

3

LA

Westlake

70669

Phillips 66/ Lake Charles Refinery

239,000

3rd Louisiana

3

LA

St. Charles Parrish

70079

Motiva/ Norco Refinery

234,700

6th Louisiana

3

LA

Chalmette

70043

ExxonMobil/ Chalmette Refinery

192,500

1st Louisiana

3

MS

Pascagoula

39581

Chevron/ Pascagoula Refinery

330,000

4th Mississippi

3

TX

Port Arthur

77641

Motiva/ Port Arthur Refinery

600,000

14th Texas

3

TX

Baytown

77520

ExxonMobil/ Baytown Refinery

573,000

36th Texas

3

TX

Texas City

77590

Marathon/ Texas City Refinery

475,000

14th Texas

3

TX

Beaumont

77703

ExxonMobil/ Beaumont Refinery

365,000

14th Texas

3

TX

Deer Park

77536

Shell/ Deer Park Refinery

340,000

36th Texas

3

TX

Corpus Christi

78407

Valero/ Bill Greehy Refinery Complex East

325,000

27th Texas

3

TX

Port Arthur

77641

Valero/ Port Arthur Refinery

310,000

14th Texas

3

TX

Houston

77017

Lyondell/ Houston Refinery

268,000

29th Texas

3

TX

Sweeny

77463

Phillips 66/ Sweeny Refinery Complex

247,000

14th Texas

3

TX

Texas City

77590

Valero/ Texas City Refinery

245,000

14th Texas

3

TX

Port Arthur

77642

Total/ Port Arthur Refinery

174,000

14th Texas

3

TX

Corpus Christi

78047

Citgo/ Corpus Christi Refinery East & West Plant

165,000

27th Texas

3

TX

Corpus Christi

78408

Flint Hills/ Corpus Christi Refining Complex East Plant

150,000

27th Texas

3

TX

Borger

79007

Phillips 66/ Borger Refinery

146,000

13th Texas

3

TX

Pasadena

77506

Petrobras/ Pasadena Refinery

100,000

29th Texas

3

TX

Tyler

75702

Delek/ Tyler Refinery

60,000

1st Texas

4

MT

Billings

59101

ExxonMobil/ Billings Refinery

60,000

At Large Montana

4

MT

Billings

59101

Phillips 66/ Billings Refinery

58,000

At Large Montana

4

UT

Salt Lake City

84116

Chevron/ Salt Lake City Refinery

45,000

2nd Utah

CRS-23

City

Zip

Facility

Bbl/D

Congressional District

PADD

St

City

Zip

Facility

Bbl/D

Congressional District

4

WY

Cheyenne

82007

Holly-Frontier/ Cheyenne Refinery

52,000

At Large Montana

5

CA

Paramount

90723

Alon/ California Refineries

70,000

40th California

5

CA

El Segundo

90245

Chevron/ El Segundo Refinery

290,000

33rd California

5

CA

Benicia

94510

Valero/ Benicia Refinery

170,000

5th California

5

CA

Martinez

94553

Tesoro/ Golden Eagle Refinery

166,000

5th California

5

CA

Martinez

94553

Shell/ Martinez Refinery

165,000

5th California

5

CA

Torrance

90509

ExxonMobil/ Torrance Refinery

150,000

43rd California

5

CA

Carson

90745

Phillips 66/ Los Angeles Refinery

139,000

44th California

5

CA

Wilmington

90744

Valero/ Wilmington Refinery

135,000

44th California

5

CA

Wilmington

90744

Tesoro Los/ Angeles Refinery

97,000

44th California

5

WA

Blaine

98230

BP/ Cherry Point Refinery

230,000

1st Washington

5

WA

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

1

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/crs%3AR43263. Public record. Not legal advice.