ILLINOIS POLLUTION CONTROL BOARD

August

4,

1988

IN THE MATTER OF:

AMENDMENTS TO

35

ILL.

ADM.

CODE

214,

)

R86—30

SULFUR LIMITATIONS

PROPOSED RULE.

SECOND NOTICE.

PROPOSED OPINION AND ORDER OF THE BOARD

(by J.

Theodore Meyer):

This matter

is before

the Board on

a

joint proposal

for

regulatory amendment filed

by the Illinois Environmental

Protection Agency (Agency)

and Shell Oil Company (Shell) on July

7,

1986.

The joint proposal

seeks

to amend

35

Ill.

Adm.

Code

214, which regulates sulfur emissions from stationary

sources.

The proposal

is designed

to tighten emissions from Shell’s Wood

River Manufacturing Complex

(WRMC)

so as

to ensure

the attainment

and maintenance of National Ambient Air Quality Standards (NAAQS)

for sulfur dioxide

(SO7)

for the Wood River

area,

On April 21,

1988

the Board proposed

for First Notice

a rule which

is

substantially the same as

the rule submitted by Shell

and the

Agency.

The proposed rule was published

in the Illinois Register

on May 13,

1988, at 12

Ill. Reg.

8219.

Several comments were received after

First Notice

publication.

The Department of Commerce and Community Affairs

filed

a comment which stated that the proposed rule will have no

effect on small businesses regulated by the rule,

(P.C.

#2.)

The Board

notes that the proposed

rule regulates only Shell’s

WRMC in Wood River,

Illinois.

Comments were also filed by Shell

(P.C.

#1)

and the Agency

(P.C.

#3).

This Opinion will address

only these comments.

The Board’s rationale for proposing this

rule

is set forth

in the Proposed Opinion of April

21, 1988.

Section 214.101.

In its First Notice proposal, the Board made

some changes

to Section

214,101(c) which were intended merely

to

clarify which procedures are to be used for solid

fuel averaging

measurements.

Shell believes that these proposed changes go

beyond the scope of this proceeding,

and states that the changes

are the subject of rulemaking

in Measurements Methods

for

Emissions of Sulfur Compounds,

R87—3l.

Shell

submits that the

changes

to subsection

(C)

are not required

to make this site

specific rule operative.

The Board

agrees,

and will not propose

any changes

to subsection

(C)

for Second Notice,

The Board

has also proposed

a new Section 214.101(h)

to

provide

for the use of

the Tutwiler procedure

for measurement

of

91—267

---

—2—

the concentration

of hydrogen sulfide

in petroleum refinery

fuel

gas,

Shell believes that this subsection needs

to be qualified

as applying only to compliance determinations for Section

214.382(c).

(Section 214.382(c)

contains

the bulk of

the rules

proposed

in this proceeding,

and applies only

to Shell’s WRMC.)

Shell states that other petroleum refineries

in Illinois use

other measurement procedures as permitted by the Agency.

Shell

also maintains that subsection

(h), as proposed at First

Notice,

could

be

in conflict with future changes

to the federal

new source performance

standards,

which may set a standard

for

continuous emission monitors.

The Board again agrees with

Shell’s comments, and will qualify Section 214.101(h)

as applying

only to compliance determination for Section 214.382(c).

Section 214.382(d)

—

permit conditions.

At First Notice

the

Board

added a sentence

to proposed Section 214.382(d) which

requires,

as

a permit condition,

that data be maintained

in order

to adequately demonstrate compliance.

The Board specified

certain types

of data,

and asked

for comment

on that listed

data.

In

its

comments, the Agency agrees

that

these types of

data are necessary

to calculate compliance.

The Agency does

suggest

that some proviso be inserted

to

allow

the elimination

of

some of

the required data, through permit decision,

if

that data

is

no longer needed because of

the addition of continuous

emission monitors.

Shell maintains that the listed information

is much too specific and would not be necessary

if Shell chooses

to show compliance

through

the use of continuous emission

monitors or other measurement methods.

Shell proposes that the

language

of Section 214.383(d)

be modified.

The Board

is persuaded that the language of Section

214.382(d)

should be less specific on what data must be

maintained.

Therefore,

the Board will delete

the specific data

listed

in its First Notice proposal, and instead generally

require that sufficient data be maintained

to adequately

determine compliance.

Thus,

the Agency will determine,

as part

of the permitting process, exactly what information~must be kept

by Shell,

The Board believes

that this change will allow for the

flexibility desired by Shell and suggested by the Agency, while

achieving the Board’s objective of proof of compliance.

Section 214.382(e)

—

exemption

from the “combination

of fuels”

rule.

In

its April

21 First Notice opinion,

the Board expressed

concern over the proposed exemption from Section 214.162

“Combination

of Fuels.”

The Board

stated that it was unable

to

clearly see why Shell cannot use the equation set out

in Section

214.162, and asked for comment on the issue.

Both the Agency and

Shell have responded.

The Agency states

that the practical

reason for the

exemption from Section 214.162

is that the Tutwiler procedure,

91—268

---

—3—

which is specified for compliance demonstration, does

not

calculate emissions

in pounds per million Btu and

thus will not

yield

a pounds

per hour emission

rate.

Instead,

the Tutwiler

method calculates

the amount

of sulfur

in

the fuel.

The Agency

states that Shell has shown

that the heat content of

its

fuel

is

remarkably constant.

With that basic fact,

and using

the

Tutwiler method,

the Agency submits that compliance may be shown

in

a very straightforward manner.

Likewise,

Shell contends that

the exemption from the combination of

fuels rule

is meant only to

greatly simplify compliance auditing.

Shell

states that the

emission limits

in Section 214.382 are not higher

than would be

provided

for

in Section 214,162.

The Board is satisfied by these

responses,

and will propose the exemption from Section 214.162

for Second Notice.

Procedure for alternative emission rates.

The only portion of

the joint proposal

which the Board

did not propose

for First

Notice was

the request

for

a subsection which would establish a

procedure for obtaining an alternative emission rate

to the

limits set forth

in

this

rule.

In

its comments,

Shell

again asks

that such a procedure be included

in the

rule.

Shell contends

that an alternative emission

rate procedure

is desirable

and

necessary

to provide flexibility for

future development.

Shell

maintains

that the delay required

for full rulemaking would most

likely stifle Shell’s ability to respond

to changes

in technology

or market place demands.

The Agency did not comment on this

issue.

The Board will not add an alternative emission rate

procedure to the proposed rule.

As noted

in the April

21, 1988

First Notice opinion,

a site specific rule is,

by definition,

tailored

to the needs of

a particular facility.

An alternative

emission rate within

a site specific regulation might allow

a

facility

to “escape”

from emission limits which the facility

itself originally proposed, without proceeding through the notice

and comment provisions of rulemaking.

The Board also notes that

although Shell

contends

in its comments that an alternative

emission rate would

not change

limitations on sulfur content of

fuel and sulfur dioxide from various processes,

the

revised joint

proposal suggests that alternative emission rates be allowed from

the subsections which set limits

on the sulfur content of the

refinery flasher pitch and the allowable hydrogen sulfide

in the

refinery fuel gas burned by Shell.

(Ex, 9.)

Other comments.

In

its April

21,

1988 Proposed Opinion,

the

Board raised questions on several

other issues.

The Agency and

Shell have responded to those questions.

First, Shell has

provided the equivalency calculation for the emission limit

change

for the sulfur recovery unit

(SRtJ)

from 14

lbs/ton

of

sulfur

recovered to

1000 ppm in the final flue gas.

(P.C.

#1,

Attachment A.)

The Agency states

that the proposed 1000 ppm

91—269

---

—4—

limit approximates the present limit

of

14 lbs/ton of

sulfur

recovered.

Both the Agency and Shell agree

that

the primary

reason

for the change

to

a concentration limit

is

to provide a

simpler and more easily audited method

of determining

compliance.

Second,

the Agency and Shell

state

that the eight—

hour sampling requirement

for refinery fuel gas.

(Section

214.382(c)(2))

is consistent with the requirements of Shell’s

existing permits from the Agency.

Third, both the Agency and

Shell explain that the emission limits

for each source operations

grouping

(SOG) were based on

air quality limits.

The allowable

emissions under

current Board regulations were reduced until

modeling showed that the reduced emissions would not meet the

NAAQS.

Finally,

Shell states

that the proposed

rule has been

placed within

the section which regulates the industry to be

consistent with other portions of the air regulations.

The

Agency agrees with the Board

that this rule could be placed

in

its own section,

but submits that leaving the rule within Section

214.382 will not cause confusion.

Thus,

the Board sees no need

to alter

the proposed rule in response

to any

of these issues.

With the exception of the changes discussed above,

the Board

will not alter

the substance of rule proposed on April

21.

Minor

changes

in format will

be made

in response

to suggestions

from

the Administrative Code Unit.

ORDER

The Board hereby proposes the following amendments for

Second Notice,

which are

to be filed with the Joint Committee on

Administrative Rules.

TITLE

35:

ENVIRONMENTAL PROTECTION

SUBTITLE

B:

AIR POLLUTION

CHAPTER

I:

POLLUTION CONTROL BOARD

SUBCHAPTER

c:

EMISSION STANDARDS AND

LIMITATIONS FOR STATIONARY SOURCES

PART 214

SULFUR LIMITATIONS

SUBPART A:

GENERAL PROVISIONS

Section 214.101

Measurement Methods

a)

Sulfur Dioxide Measurement.

Measurement

of sulfur

dioxide emissions from stationary sources shall

be made

according

to the procedure published in

40 CFR 60,

Appendix A,

Method

6

(1982),

or by measurement

procedures specified by the Illinois Environmental

Protection Agency (Agency) according to

the provisions

of

35

Ill. Adm. Code 201.

91—270

---

—5—

b)

Sulfuric Acid Mist and Sulfur Trioxide Measurement.

Measurement of sulfuric acid mist and sulfur trioxide

shall

be according to the barium—thorin titration method

as published in 40 CFR 60, Appendix A, Method

8 (1982).

c)

Solid Fuel Averaging Measurement.

If low sulfur solid

fuel

is used to comply with Sections 214.121, 214.122,

212.141,

214.142, 214.162 and

212.421, the applicable

solid

fuel sulfur dioxide standard shall be met

by

a

two

month average of daily samples with 95 percent of the

samples being no greater than 20 percent above the

average.

A.S.T.M. procedures shall be used for solid

fuel sampling,

sulfur and heating value determinations.

h)

Hydrogen Sulfide Measurement.

For purposes of

determinin~compliance with Section 214.382(c),

the

concentration of hydrogen sulfide

in petroleum refinery

fuel gas shall

be measured using

the Tutwiler Procedure

specified in 40 CFR 60.648

(1986).

(Source:

Amended at 12

Ill. Reg.

_____,

effective

_____________)

Section 214.102

Abbreviations and Units

a)

The following abbreviations are used in this Part:

btu

British thermal

units

(60

F)

ft

foot

grains

J

Joule

kg

kilogram

kg/MW—hr

kilogram per megawatt—hour

km

kilometer

lbs

pounds

lbs/mmbtu

pounds per million btu

m

meter

mg

milligram

Mg

rnegagram,

metric ton or tonne

mi

mile

mmbtu

million British thermal

units

mmbtu/hr

million British thermal units

per hour

MW

megawatt; one million watts

MW—hr

megawatt—hour

ng

nanogram, one billionth

of

a gram by

volume

ng/J

nanograms per Joule

ppm

parts per million

scf

standard cubic foot

scm

standard cubic meter

T

English ton

9 1—271

---

—6—

b)

The following conversion factors have been used

in this

Part:

English

Metric

2.205 lb

1 kg

1 T

0.907 Mg

1 lb/T

0.500 kg/Mg

mmbtu/hr

0.293 MW

1 lb/mmbtu

1.548 kg/MW—hr or 430 ng/J

1 mi

1.61 km

1 gr/scf

2289 mg/scm

(Source amended at

12 Ill.

Reg.

________,

effective

______________)

Section 214.104

Incorporations by Reference

The following materials are incorporated by reference:

a)

40 CFR 60, Appendix A

(1982):

1)

Method

6:

method

for measurement of sulfur dioxide

emissions;

2)

Method

8:

barium—thorin titration method

b)

American Society for Testing and Materials,

1916 Race

Street,

Philadelphia, PA 19103:

1)

For solid

fuel sampling:

ASTM D—2234

(1976)

ASTM D—20l3 (1976)

2)

For sulfur determinations:

ASTM D—3l77

(1976)

ASTM D—2622

(1982)

3)

For heating value determinations:

ASTM D—20l5

(1976)

ASTM D—3286

(1976)

c)

Tutwiler Procedure for hydrogen sulfide,

40 CFR 60.648

k1286).

(Source:

Amended at 12 Ill.

Reg.

______,

effective

___________)

91—272

---

—7—

Section 214.382

Petroleum and Petrochemical Processes

a)

Section 214.301 shall

not apply to existing processes

designed

to remove sulfur compounds from the flue gases

of petroleum and petrochemical processes.

b)

No person shall cause

or allow

the emission of more than

1,000 ppm of sulfur dioxide into the atmosphere from any

~ew

process

emission

source

in

the

St.

Louis

(Illinois)

major

metropolitan

area

designed

to

remove

sulfur

compounds from the flue gas of petroleum and

petrochemical processes.

~e e~eee~~4 Ths~’Pe~

s~?t~

~4ex~e

pe~me~t~4e

~

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Sti~?~f

~eee~te~e~

f~

c)

The following

limitations apply

to any petroleum

refinery in the Village of Roxana:

1)

No person shall cause

or allow the combustion of

refinery flasher

pitch containing more

than 3.0

(three percent) sulfur by weight.

This shall

be

demonstrated by daily sampling of refinery flasher

pitch.

2)

No

person

shall

burn

petroleum

refinery

fuel

gas

in

any fuel gas combustion device

if that refinery

fuel gas contains more than

39 grains hydrogen

sulfide per 100 dry standard cubic feet

(893

mg/scm).

This shall be demonstrated by sampling

the refinery fuel gas once every eight hours.

3)

No person shall cause or allow the total emission

of sulfur dioxide into the atmosphere from the

following source groupings to exceed the following

amounts:

A)

All

process

heaters

at

distilling

unit

No.

1

—

459

lbs/hr

(208

kg/hr).

B)

All

process

heaters

at

distilling

unit

No.

2

—

1260 lbs/hr

(571 kg/hr).

C)

All gas plant process heaters

—

159 lbs/hr

(72.1 kg/hr).

D)

All vacuum flasher unit heaters

—

378

lbs/hr

(171

kg/hr).

E)

All process heaters at the alkylation, benzene

extraction unit and catalytic feed

hydrotreating units

—

346 lbs/hr

(157 kg/hr).

91—273

---

—8—

F)

All

boilers

generating

steam

for

general

plant

use— 2,400

lbs/hr

(1,090 kg/hr).

G)

All heaters serving the hydrocracker unit

catalytic reformer No.

1,

and the saturates

gas plant

—

1,660 lbs/hr

(753 kg/hr).

H)

All

process

heaters

at

the

aromatics

east

process

—

768 lbs/hr

(348 kg/hr).

I)

All

catalytic

cracking

units

—

3,430 lbs/hr

(1,560

kg/hr).

All

asphalt

converters,

distilling

unit

No.

1,

the

aromatics

east

process,

all

boilers

generating

steam

for

general

plant

use,

and

all

gas

plant

process

heaters

—

2,710

lbs/hr

(1,230 kg/hr.)

d)

Compliance

with

the

emission

limitations

of

subsections

(b) and

(c)(3)

of this Section shall

be demonstrated on

a three—hour

block averac~ebasis.

Such demonstrations

shall require,

as

a permit condition,

that data as

required

by

the Illinois Environmental Protection Agency

be maintained

in order

to adequately determine the

sulfur dioxide emission rate from each source operations

group.

e)

Sources

in

the Village of Roxana are not subject

to the

emission limitations of Section 214.162 when burning

refinery flasher pitch

or refinery fuel gas.

f)

Individual

process

emission

sources

in

the

Villa~e

of

Roxana

are

still

sub~ect

to

the

emission

limitation

of

Section 214.301 notwithstanding

their inclusion

in

a

source operations group.

iL

Notwithstanding the provisions

of

35 Ill.

Adm.

Code

201.102 of this Chapter, any physical change

in any

emission source subject

to subsection

(b),

(C),

(d),

or

(e)

of this Section which alters

the height of release,

temperature

or

volumetric

flow

rate

of

the

effluent

gases

of such source,

or alters the diameter

of the exit

stack, shall

be deemed

a modification for

the purposes

of

35

Ill.

Adm. Code 201.142 of this Chapter.

(Source:

Amended at 12

Iii.

Reg.

______,

effective

_____________

IT

IS SO ORDERED.

91—274

---

—9—

I, Dorothy M.

Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify~Jiatthe above Proposed Opinion and Order

was adopted on the

~

day of

~—~-i--

,

1988, by a

vote of

-7—°

.

~

Dorothy M./Gunn, Clerk

Illinois Pollution Control Board

91—275