Reference: Comments on Petroleum Refining Emissions

We are pleased to provide comments on ARB’s presentations and regarding the LCFS. The comments herein address the question of emissions from oil refineries. Refinery emissions contribute to the CARBOB and ULSD fuel pathways. Also, diesel and residual oil are inputs for the production, transport, and distribution of other fuels. Refinery Emission Calculations The GREET model estimates emissions from oil refining and assigns the emissions to gasoline blendstock, diesel, LPG, and residual oil. The key input is the refinery efficiency, which translates into energy used per mmBtu of product fuel. Table 1 summarizes the refinery efficiency assumptions used in CA_GREET1.8b, GREET1_2103, recommended inputs, and literature references. The inputs for petroleum refining have evolved over the years with differ considerably values for both baseline gasoline and diesel. The CA_GREET inputs were adapted from the GREET 1.8b model with adjustments for CA RFG production. These values were derived from the original 2004 paper from Argonne National Laboratory that attempts to assign a refining intensity to each petroleum product (Wang, 2004)