ILLINOIS POLLUTION CONTROL BOARD
March
2,
1989
SHELL OIL COMPANY,
)
)
Petitioner,
V.
)
PCB 89—43
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
OPINION AND ORDER
OF THE BOARD
(by J. Marlin):
This matter comes before the Board upon a February 28,
1989
Illinois Environmental Protection Agency (“Agency”)
Recommendation
that
the Board grant a forty—five day provisional
variance to the Shell
Oil Company (“Shell”)
from 35
Ill. Adm.
Code 214.382(b).
Shell requests
a variance
to allow time
to do
necessary repairs on the Shell Claus Off—gas Treater
(“SCOT”)
unit of its Sulfur Recovery System.
Shell
operates a refinery complex
in Wood River Township,
Madison County,
Illinois.
The Shell
refinery includes a Sulfer
Recovery System with the Shell
Claus Off—gas Treater (“SCOT”)
Unit.
The SCOT unit reduces
the sulfur compounds
in the tail—
gases to
112S with hydrogen, heat and catalyst.
The converted H2S
is recycles back
to the claus
units
for conversion
to sulfer.
The treated tail—gas from SCOT
is then
incinerated prior
to
exhaust to the atmosphere via a stack.
These emissions are
limited by 35 Ill.
Adm. Code 214.382(b)
to 1,000 ppm of sulfer
dioxide
(SO2).
The Sulfer Recovery Units/SCOT are presently
operated pursuant to an operating permit, Application No.
79090040,
with an expiration date of June
31,
1989.
The SCOT unit required a shut—down to allow necessary
repairs
to be performed.
With the reduction
in other SO2
producing operations,
Shell will
reduce total SO2 emissions by 5
of the total permitted SO2 emissions of
its Wood River complex.
Accordingly,
the Agency states that
it believes that there should
not be any environmental impact from the shutdown of the SCOT
unit.
Compliance with 35 Ill.
Adm. Code 214.382(b) would
require
shutdown of the refinery during the repairs of the SCOT unit.
This would
cause
an economic loss to Shell
in excess of $600,000
per day.
Thus,
the Agency states that shutdown of the refinery
would cause an arbitrary and unreasonable hardship on Shell.
97—05
—2—
Shell has a definite compliance plan.
The necessary repairs
to the SCOT unit will be done during the
45 day period of the
provisional variance.
While
the SCOT unit
is shutdown, the rest
of the refinery will
limit SO2 emissions to 95
of Shell’s
permitted level.
There
is no reasonable alternative for
compliance and according to the Agency that the reduction of
emissions from other
SO2 emission sources will minimize any
possible adverse impacts.
The Board having received notification from the Agency that
compliance on a short term basis with the petroleum and petro
chemical processes limitations
imposed by 35
Ill.
Adm. Code
214.382(b) would impose an arbitrary or unreasonable hardship
upon Shell,
and the Board concurring
in that notification, hereby
grants provisional variance, subject
to the conditions suggested
by the Agency.
This Opinion constitutes
the Board’s findings of fact and
conclusions of law
in this matter.
ORDER
Shell Oil Company
is hereby granted
a provisional variance
from the requirements of
35
Ill. Mm.
Code 214.382(b)
for the
Shell Claus Off—gas Treater (SCOT)
Unit at its Wood River
Manufacturing Complex from January 19,
1989 until March
4,
1989,
subject to the following conditions:
1.
During
the period of the provisional variance,
the total
emissions of sulfur dioxide from the facility shall not
exceed 9,863 lbs/hr.
2.
Within three
(3) days of the end
of each calendar week,
from the date the provisional variance
is granted, the
petitioner
shall submit
a written report to
the Agency
providing the emissions of sulfur dioxide from the
refinery complex for each day in tons per day and pounds
per hour.
3.
The weekly report shall also contain
a summary of the
maintenance that was performed on the unit during the
subject calendar week.
4.
The weekly report shall
be submitted
to:
Regional Manager
State o~Illinois EPA
—
DAPC
2009 Mall Street
Collinsviile,
Illinois
62234
97—06
—3—
5.
If the levels of ambient concentrations of sulfur
dioxide, based
on the Agency’s ambient air monitors
located
in South Roxana or Wood Rover, begin to
indicate
that an excursion of the NAAQS of 0.14 ppm
(24 hours
average)
is possible, the petitioner shall
implement
measures to reduce sulfur dioxide emissions from the
refinery complex.
The measures may include, but not be
limited
to,
reducing crude
feed rates
to the refinery or
switching to low sulfur fuels.
The Agency will notify
the petitioner by the fastest means available upon
occurrence of these levels.
Local wind speed and
direction will be considered
in the determination if
notification to petitioner
is appropriate.
Within ten days of the date of this Order,
Petitioner
shall
execute and forward
to James J. O’Donnell, Enforcement Programs,
Illinois Environmental Protection Agency, 2200 Churchill Road,
P.
0.
Box 19276, Springfield, Illinois
62794—9276,
a Certification
of Acceptance
and Agreement
to be bound
to all terms
and
conditions of this variance.
Failure to execute and forward the
Certificate within 10 days renders this variance void and of no
force and effect as
a shield against enforcement of rules from
which variance was granted.
The form of said Certification shall
be as follows:
CERTIFICATION
I,
(We), ____________________________, having read the
Order of the Illinois Pollution Control Board,
in PCB 89-43,
dated March
2,
1989,
understand
and accept the said Order,
realizing that such acceptance renders all terms and conditions
thereto binding and enforceable.
Petitioner
By:
Authorized
Agent
Title
Date
97—07
—4—
Section 41 of the Environmental Protection Act,
Ill.
Rev.
Stat.
1987 ch.
111 1/2 par.
1041, provides for appeal of Final
Orders of the Board within 35 days.
The Rules of the Supreme
Court of Illinois establish filing requirements.
IT IS SO
ORDERED.
I,
Dorothy
M.
Gunn,
Clerk
of
the
Illinois
Pollution
Control
Board,
hereby
certify
that the above Opinion and Order was
adopted
on
the
~‘)~/
day
of
_____________,
1989, by
a vote
of
_______
Dorothy M. inn,
Clerk
Illinois Po~VlutionControl Board
97—08