Emission Reduction Initiative - "ERI"

• Baseline is calendar year 1997.
• Goal line is calendar year 2004 including any revisions submitted by July 31, 2005.
• Commitment is 50% reduction of total mass of pollutant emissions to air, water and waste.
• There is no commitment to reduce any specific pollutant, media, or risk.
• Avoid double counting of pollutants.

Air:

• Includes air emissions of criteria pollutants sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), volatile organic compounds (VOC), particulate matter or total suspended particles (PM or TSP), and lead as reported in the Emission Inventory and subsequent revisions submitted to the Minnesota Pollution Control Agency (MPCA) with the following adjustments of sources not reported in the 1997 baseline:
  • Flare gas combustion emissions
  • Soil vapor extraction
  • Portable internal combustion engines
  • Fluid Catalytic Cracking Unit CO boiler bypass
  • Cooling towers
• Includes Toxic Release Inventory (TRI) reportable air emissions not otherwise counted as part of the PM or VOC tables.
• Includes air emissions from the Koch Sulfuric Acid Unit.
• Excludes global climate change gases.
• Excludes air emissions from insignificant sources as defined in state air rules.
• Excludes air emissions of PM-10 since it is a subset of PM (TSP).
• Excludes emissions from sources not identified prior to the ERI commitment including the following:
  • Sulfur recovery plant CO emissions.
  • PM from transportation of coke handling trucks
  • PM from cooling water towers

Water:

• Includes water emissions of National Pollutant Discharge Elimination System (NPDES) pollutants chemical oxygen demand (COD), Total Suspended Solids (TSS), and Oil & Grease (O&G) as reported in the Discharge Monitoring Report (DMR).
• Includes water emissions reported in the TRI and not otherwise included in the DMR.
• Excludes water emissions of biological oxygen demand (BOD) since it is a subset of COD.
• Excludes KSAU water emissions co-discharged with Continental Nitrogen.
• Excludes storm water runoff from property that is not discharged through the NPDES permit.

Waste:

• Includes waste disposed to land and via incineration, including hazardous, industrial and municipal waste as reported in the Waste Reports submitted to the MPCA, and waste disposal invoices.
• Includes waste from the KSAU.
• Includes current remediation waste such as:
  • Soil clean-up from current spills
  • Soil contaminated from newly discovered tank floor leaks
  • Tank clean-outs/tank bottoms
  • Lined basin clean-outs
  • Sewer sludge, wastewater treatment sludge
• Excludes waste emissions of TRI chemicals since these are already counted in the total waste figures.
• Excludes non-process/hardware waste, i.e. process vessels, tank demolition, equipment demolition, heat exchanger bundles.
• Excludes waste that is recycled on or off-site for beneficial re-use including but not limited to:
  • Catalyst reclamation, carbon regeneration
  • Energy recovery
  • Concrete, asphalt, and roadway mix
  • Scrap metal, Wood chips
  • Fuel blending
• Excludes historical remediation waste such as:
  • Contaminated soil from excavations for sewer projects
  • All waste from historical Solid Waste Management Units (SWMUs)
  • Material removed from landfarm
  • Unlined basin cleanouts (e.g. B5 basin)
  • Coke fines
• If soil from a recent spill is excavated in an area with historically contaminated soils, an effort is made to break out historic vs. recent contaminated soil (when feasible).
• Excludes waste/contaminated soil generated from non-Flint Hills Resources companies that maintain equipment on-site (e.g. Magellan Pipeline, Koch Pipeline).