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

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