ILLINOIS POLLUTION CONTROL BOARD

March

26,

1975

IN THE

MATTER

OF

PROPOSED

AMENDMENTS TO

CHAPTER

2:

AIR POLLUTION

)

R73—8,

10,

17

REGULATIONS

OPINION

OF

THE

BOARD

(by Mr.

Dumelle):

This Opinion and Order concludes

the Board’s consideration

of three proposals

to amend Chapter

2: Air Pollution Regulations

which were submitted,

separately,

by three parties and

therefore assigned separate docket numbers.

For purposes of

public hearings,

the

three were consolidated into one set of

hearings held during May and June of 1974.

The first proposal,

R73—8,

was submitted on

May

14,

1973 by the Illinois Oil and Gas Association

(IOGA)

,

and

sought to amend Chapter

2:

Air Pollution Regulations as

they

pertain to storage

tanks

used for organic materials as well

as oil—water separation tanks.

The

specific changes proposed

were the following:

Change Number

1: Amend Rule

103(1)

by adding the following

permit exemptions:

(17) all storage tdnks of volatile organic material

with

capacity of less than 40,000 gallons;

(18) all organic material

-

water single or multiple

compartment effluent water separator facilities for

Illinois crude oil of vapor pressure

of

less

than

5

pounds per square inch absolute

(psia)

Change Number

2:

Amend Rule

205(c) (2)

(13)

by deletion

as

follows:

~

~

Change

Number

1 would exempt two additional

types of

equipment

from

the

permit

requirement

(Rule

103)

.

Change

Number

2

would

broaden

the

exemption

from

the

organic

material—

water separation emission limits

(Rule 205(c))

by removing

the geographic requirement.

16 —259

---

—2—

The second proposal,

R73-l0, was submitted by Amoco Oil

Company on September 4,

1973.

This proposal would amend

Rule 206(c), Petroleum and Petrochemical Processes,

to

increase the allowable emissions of carbon monoxide

(Ca)

from 200 parts per million

(ppm)

corrected to 50

excess air

to 750 ppm corrected to 50

excess air for existing catalyst

regenerators and to 350 ppm corrected to 50

excess air for

new catalyst regenerators.

The changes proposed are to add

paragraphs

(2)

and

(3)

to the Rule as follows:

(c) Petroleum and Petrochemical Processes.

(1)

No

person shall

cause or allow the emission of a carbon

monoxide

waste

gas

stream

into

the

atmosphere

from

a

petroleum

or

petrochemical

process

unless

such

waste

gas

stream

is

burned

in

a

direct

flame

afterburner

or

carbon

monoxide

boiler

so

that

the

resulting

concentration

of

carbon

monoxide

in

such

waste

gas

stream

is

less

than

or equal to 200 ppm corrected to

50 percent excess

air,

or

such waste gas stream

is controlled

by other

equivalent

air

pollution

control

equipment

approved

by

the

Agency according

to

the

provisions

of

Part

I

of

this

Chapter.

(2)

Notwithstanding

naragraph

(1)

of

this

Rule

206(c)

any

existing

petroleum or petrochemical process

using

catalyst

regenerators

of

fluiclized

catalytic

converters

ecuipped

for

stoichiometric

combustion

of

carbon

monoxide

:Lntarnally

within

the

regenerator,

may

emit

a

carbon

monoxide

waste

gas

steam

into

the

atmosphere

if

the

carbon

monoxide

concentration

of

such

waste

gas

stream

is

less

than or equal

to 750 ppm corrected to

50

percent

excess air~

(3)

Notwithstanding paragraph

(I) of

this Rule

206(c)

any

new petroleum or petrochemical process using catalyst

regenerators of fluidized catalytic converters equipped

for stoichiometric combustion of carbon monoxide internally

within the regenerator,

may

emit

a carbon monoxide

waste gas stream into the atmosphere

if the carbon

monoxide concentration

of

such waste gas stream

is less

than or equal

to 350 ppm correct to

50 percent excess

air.

The third proposal,

R73-17, was submitted by the Illinois

Environmental Protection Agency

(Agency)

on December 13,

1973.

It would modify Rule 204

(f) (2)

,

Sulfuric Acid Mist

Standards

and Limitations and Rule 204 (g) (2), Sulfuric Acid

Mist and Sulfur Trioxide Measurement,

of Chapter

2: Air

Pollution Regulations as follows:

16~26O

---

—3—

Rule

204(f)

(2)

-(~3-

Sulfuric Acid Mist Standards and Limitations.

(A)

No person shall cause or allow the emission of

sulfuric acid mist into the atmosphere from any

process emission source to exceed 0,15 pound of acid

mist per ton of acid ~ed—ef

manufactured.

(~)

With the exception of Rule

204(f) (2) (A)

and fuel

comlustion

sources,

no

person

shall

cause

or

allow

the

emission

of

sulfuric

acid

and/or

sulfur

~fromanl7emassionsourcee1thera1one

or

in oom/I~tionwi?~ the emissions of sulfuric

acid and/or sulfur trioxide from all other similar

emissIons sources at

a plant or premises to

exceed

0.1 lb

in an~one hour period.

~P*

Sulfuric Acid Mist and Sulfur Trioxide Measurement,

(A)

Measurement of sulfuric acid mist and sulfur

trioxide from sources manufacturing sulfuric acid

shall be accordinq to the Barium-thorin titration

method as published in

36 Fed.

Rep.

24893.

(B)

With the exception of Rule 204(q) (C) (A), measurement

of sulfuric acid rn/st and sulfur trioxide shall be

accor~ng to t~ Turbidimetric Method using barium

chloride a~~~Tfiedby

the Agency according to the

ions of Part lof

th

is Cha

ten

Public hearings on the above proposals were

held

as

follows:

DATE

LOCATION

TESTIMONY PRESENTED

May

8,

1974

~HTd~ago

R73—lO, R73—l7

May 14,

1974

Springfield

R73—8,

R73—l7

May

28,

1974

Belleville

R73—8, R73—lO

June

9,

1974

Chicago

R73—l7

Following

a

review of the testimony and exhibits

submitted

by industry and Agency witnesses

at the hearings,

a

Proposed

Final

Draft of amendments was published on January

28, 1975 in

the Environmental Register

#97 with

a public

comment period extending until March

1,

1975.

Comments

concerning the Proposed Final Draft were received from the

Agency, Dr. Wadden

(University of Illinois School of Pubic

Health), Clark Oil, Commonwealth Edison,

Olin Brass, Keystone

Wire,

TRW, and Bell and Howell.

16—261

---

—4—

All

of

the

information

submitted

for

the

record

in

this

proceeding, including comments received with regard to the

Proposed Final Draft,

has

been reviewed by the

Board

in

arriving

at

the

conclusions

and

orders

contained

in

this

Opinion

and

Order

of

the

Board.

DISCUSSION OF R73-8,

ORGANIC MATERIAL

Public hearings were held on this proposal on

May

8,

1974 in Chicago,

May

14, 1974 in Springfield,

and

May

28,

1974 in Belleville, the

IOGA

presenting evidence at the

Springfield

and

Belleville hearings.

The Agency, at the

Chicago hearing, moved to dismiss the proposal on the basis

of a deficient petition

CR.

4), said motion being ruled

against by the hearing officer at the Belleville hearing

CR.

261).

Testimony centered on the oil field sites in Illinois.

These fields contain 26,000 wells

CR.

166) and are serviced

by 9,500 oil-water separators.

There are approximately

10,000 oil field sites in Illinois

CR. 270) which produced

50 million barrels of oil in 1971 but only 30 million barrels

in 1973

CR.

168).

The number of wells drilled has declined

also

CR. 168).

The IOGA subrtiitted exhibits

1 to

9, photographs,

to show the age

and

condition of typical oil field facilities.

Although the IOGA proposal concerns both storage tanks

and oil-water separators, the IOGA was concerned primarily

about the oil—water separators

CR. 135).

Since all fields

must practice oil-water separation,

“storage” tanks are part

of the separation process, and only about 200 to 300 tanks

are actually for storage and not for oil—water separation

CR. 140, 272).

There is an existing permit exemption for

organic liquid storage

tanks

of less

than

5,000 gallons

capacity CRule lO3Ci) (14)), so that the aforementioned 200

to 300

tanks

relates to tanks in the size range of 5,000 to

40,000 gallons.

Ninety percent of the oil-water separator

tanks

have a capacity of 210 barrels

C8,800 gallons)

CR.

282).

It is uneconomical to have separation tanks processing

less than 200 gallons per day

and

in fact some tanks process

2,000 barrels

per

day of fluid

(84,000 gallons

per

day)

consisting of an oil and water mixture

CR. 282-284).

Various arguments were raised by the Petitioner in

support of the proposal; the Board didn’t

intend

to

regulate

the emissions from the oil field facilities, the emissions

from these facilities are insignificant, and no permits are

required for oil field facilities since these are not, by

18—262

---

—5—

The primary argument of the IOGA was that there is no

public benefit in requiring permits for facilities not

regulated by substantive regulations

(R.

254).

As contained

in their petition the IOGA asserted the following:

“The undersigned are of the opinion that Rule 103

(PERMITS)

requires a permit for “emission sources”, as

defined in Rule

101

(DEFINITIONS)

to be equipment or a

facility of a’type capable of emitting “specified air

contaminants” into the atmosphere. “Specified air

contaminants”, as defined in Rule 101, are those air

contaminants as to which Chapter

II contains emission

standards or other specified limitions.

Since Chapter

II contains no standards or specified limitations for a

stationary tank, reservoir or other container of less than

40,000 gallons, see Rule 205, or for a single or

multiple compartment effluent water separator facility

for production of Illinois crude oil under certain

conditions, see Rule 205(c) (2)

,

it is the belief of the

undersigned that such facility is not, therefore,

an

“emission source” and a permit

is not required under

Rule 103.”

The Agency argued that there are substantive regulations

covering these facilities and that permits should be required

(R,

98)

.

Specifically, the Agency asserted that there are

rules governing the loading of storage tanks under 40,000

gallons capacity

(Rule 204(b))

which would rebut Petitioner’s

argument regarding these facilities

(R.

257).

These rules

are essentiall.y tank design and operation rules and the

Agency needs the permit procedure to check that the construction

or operation of these tanks is in compliance with Board

regulations

(R.

259).

There are also rules governing

organic material-water separators

(Rule 205(c))

with exemptions

for facilities outside major metropolitan areas handling low

vapor pressure crude oil

(Rule 205(c)(2)).

While 205(c) (2)

may mean that most separators are in compliance assuming

they meet the requirements of the exemption,

the Agency felt

that permits still were required (R.

261).

Also,

the

Agency was willing to have special permit applications for

storage tanks and oil-water separators

to ease alleged

industry burden in filing permit applications

(R. ibid).

The Board agrees with the Agency that there are substantive

regulations covering some of these facilities.

We

find,

however, no necessity for permits for the 9,500 tanks located

on oil field sites because of the likely exemption of most

of them by Rule 205(c) (2)

as will be discussed later.

~6—263

---

—6—

The IOGA’s argument of Board intent is based on the

original air emission standards proceeding, R71-23.

The

IOGA quotes the following portion of page 39 of the R71-23

Opinion of the Board to indicate Board intent

(R.

112)

in

regulating storage tanks:

“Based on proof of hardship by the Illinois oil

and gas producers,

we have made an exception for storage

tanks used in the production of Illinois crude oil

because of the low vapor pressure and consequent low

emission rate of the oil,

the generally remote location

of these installations, and the declining nature of the

industry, which increases the burden of building floating

roofs that would have to be abandoned in

a, short time

(Brown,

R.

1022-36; Ex.

114, Nos.

25,

100).

The specification

of positive pressure vent valves and vacuum breakers in

such cases was suggested by the industry,

(ibid)

.“

The Agency’s response was that there is an existing

permit exemption for storage tanks of 5,000 gallons capacity

or less

(Rule 103(i) (14))

in addition to the storage regulation

(Rule 205(a)) and these regulations are indicative of Board

intent.

In addition, Board intent in regulating oil-water

separators is specified on pages 39 and 40 of the R 71-23

Opinion according to the Agency

(R.

259).

The following

portion of page 40 indicates the intent.

“Other significant sources of offensive organic

emissions are facilities for the loading of gasoline

and other products, and for the separation of hydrocarbons

from water.

Rules

205(b) and

(c) require such established

good practices as submerged loading pipes, gas-tight

connections for tank-truck loading, and enclosed separators

with appropriate controls.

See Hydrocarbon Techniques,

supra,

pp. 4-5 to 4-14;

the supporting testimony of

Conoco and Amoco as to loading

(Ex.

114, Nos.

29,

37);

EPA’s backup document

(Ex.

60); and the suggestion by

Sullivan (Ex.

114,

No.

37)

and Knowles

(Ex.

60,

p.

24)

that separators may be controlled without requiring the

modification of existing vessels.”

It was alleged by the IOGA that the emissions from the

roughly 10,000 oil field sites is equivalent to the burning

of one ton of coal per day

CR.

265,

269).

Extensive questioning

by Board and Agency personnel as to the basis for the one

ton figure

(R. 276—280,

285—290) revealed discrepancies as

to the accuracy and completeness of the supporting data

(R.

299-301).

In particular, Exhibit

10,

submitted by the IOGA,

states that hydrocarbon vapor emissions from eleven test

16 —264

---

—7—

sites ranged from zero up

to 27 standard cubic feet

(scf)

per barrel.

Using these data,

along with the 1972 Illinois

crude oil production figures, results in a total daily

emission from all sites of up to 3.75 x 106

scf.

Averaged

over the area where oil

is produced,

up to a height of 100

feet,

the atmospheric concentration of hydrocarbons

is

0.06

parts per million

(ppm)

according to Exhibit

10.

The IOGA

witness testified,

however, that the total hydrocarbon

emissions from all the separators and storage tanks

is only

110,000 cubic feet

(R.

283); but

neglected

to

give

the

duration of the emission,

i.e. hour, day,

year.

The

witness also confused the 0.06 ppm atmospheric concentration

with the concentrations of emissions from the tanks and

separators

(see Exhibit 10 and R.

283).

Our conclusion is that

insufficient reliable information is contained in the record

to

support the one ton per day figure testified to by the

Petitioner.

We believe, however, that the emissions are not

excessive and are likely to be non—photochemically reactive

in

nature.

The Petitioner’s proposal

to delete the location requirements

from Rule 205(c) (2) (B)

is based on the rural location of

these separator facilities.

Only three counties within the

major metropolitan areas,

St. Clair, Madison, and Sangamon,

contain oil producing facilities and these produced in 1972

only 362,000 barrels of the 50 million total for the state,

a percentage of 0,72 percent (incorrectly stated by the IOGA

as 0.0072 percent)

(R.

267)

.

It seems

that most facilities

would be exempt with or without 205(c) (2) (B)

and the impact

of the others will therefore not be significant.

Our review of the record indicates,

therefore,

that

both proposals of

the IOGA as modified by us should be

adopted.

We have modified the proposed language of Rule

103(i) (17)

to reflect the hearing record, which was concerned

with oil field sites producing Illinois crude oil.

In

addition, our intent in adopting additional permit exemptions,

Rules 103(1) (17)

and 103(1) (18),

is to limit these exemptions

to facilities located on the oil field sites, containing the

oil wells producing Illinois crude oil, testified to at the

hearings.

The specific language of the amendments we are

adopting is contained in our Order attached hereto.

DISCUSSION OF R73-lO, CARBON MONOXIDE

The proposal is intended to allow Amoco to use its new

technology catalyst regeneration process

(Ultracat)

on its

fluidized bed catalytic cracking

(FCC)

unit without additional

emission controls for CO.

According to Amoco’s petition,

their Ultracat process converts over 99

of the CO in the

regenerator, reduces CO emissions, corrected to

50

excess

air,

to below 750 ppm for existing units and 350 ppm for new

units, improves liquid hydrocarbon yields from the FCC by

0.7 to

3.0,

and decreases coke production by

15 to 25.

16—265

---

—8—

The catalyst in the FCC unit becomes coated with carbon

and its efficiency

in producing liquid hydrocarbons, including

gasoline, decreases.

The catalyst is regenerated by burning

off the carbon in the regeneration unit,

the exhaust gases

from which typically have CO concentrations of

5 to 10

(Pet.

Ex.

1)

and are combusted in a CO boiler to produce

additional steam for process use.

The Ultracat process more

completely regenerates the catalyst and thus improves FCC

performance while at the same time reducing the CO in the

regenerator exhaust

to levels of 1000 ppm,

i.e.,

0.1

on a

continuous basis

CR.

15).

Clark Oil and Refining Corporation

(Clark)

testified at

the hearings and suggested that Rule 206(c)

be changed to

increase the allowable emissions of CO to 0.2~percent (2000

ppm)

for existing FCC regenerators and 0.05 percent

(500

ppm)

for new FCC regenerators.

Clark is presently converting

their existing FCC units to the new Universal Oil Products

(UOP)

hot regenerator technology which will result in better

hydrocarbon yields,

less coke production, and decreased CO

emissions from the regenerators

(R. 46-47).

The UOP system

will result in a 98

reduction of CO emissions and a discharge

to the atmosphere of

2000 ppm

(R..

50).

Comparing the two re~eneratorsystems, Ultracat and

UOP,

they are basically the same

in that they use increased

amounts of air and operate at higher temperatures than

conventional regenerators

CR.

347);

there are, however,

certain metallurgical differences

(R.

368).

The increased

yields of hydrocarbons from the FCC would probably be identical

between Ultracat and UOP

CR.

34.5)

.

The economics are also

similar, the capital costs for installing either the UOP or

Ultracat system would be approximately the same

(R.

366).

There is, however,

a matter of royalties;

because Clark has

existing UOP units,

it would cost Clark $500 to $1000 per

day in royalties to use the Amoco process and it was for

this reason that Clark chose UOP over Amoco

CR.

365).

Except for the two Clark facilities and Amoco’s Wood

River facility, the other petroleum refineries

in Illinois

have CO boilers.

Amoco has the Ultracat process and the

Clark facilities are presently being converted to the UOP

process, Clark’s decision having been made in 1972

(R.

368).

This proposal of Amoco then concerns three existing petroleum

refineries plus all new refineries that would he constructed

with the new technology catalyst regenerators.

The Board

takes judicial notice of the sizes and locations of the

existing refineries

in Illinois

(obtained from 1973 American

Petroleum Institute data)

as follows:

16—266

---

—9—

REFINERY

LOCATION

SIZE (barrels/calendar day)

Amoco Oil

Wood River

107,000

Clark Oil and Refining

Blue Island

68,000

Clark Oil and Refining

Hartford

36,000

Marathon Oil

Robinson

195,000

Mobil Oil

Joliet

175,000

Shell Oil

Wood River

260,000

Texaco Oil

Lawrenceville

84,000

Texaco Oil

Lockport

72,000

Union Oil

Lemont

152,000

Wireback Oil

Plymouth

1,500

Yetter Oil

Colmar

1,000

Much testimony concerned the environmental impact of

the CO emissions from the refineries.

Atmospheric dispersion

modelling and ambient air sampling showed that at CO emission

limits of 1,000 ppm or 2,000 ppm, there would not be

a

significant adverse effect on the ambient concentrations of

CO.

The dispersion modelling at Clark’s Blue Island facility

showed that for the worst possible meteorological conditions,

the existing facility could produce a maximum 1-hour ambient

concentration of 11 ppm while the facility as modified could

produce a maximum concentration of 0.2 ppm

CR.

320).

The

maximum

8-hour ambient concentration would be 6.26 ppm with

the existing Blue Island facility and 0.14 ppm with the

modified facility

(R.

323)

.

Modelling for the Amoco Wood

River refinery shows maximum downwind CO concentrations of

8

to

9 ppm for conventional regeneration and less than 0.1 ppm

for Ultracat regeneration

CR.

18-19).

The federal primary

standards for CO are 35 ppm for one hour and 9 ppm for eight

hours,

these levels not to be exceeded more than once a year

CR.

451).

Ambient air sampling performed at three locations

in the vicinity of Amoco with Ultracat in operation showed

negligible contributions by Amoco to the ambient air concentrations

of CO

(Pet. Ex.

1, Appendix I).

They did, however,

indicate

a contribution from the Clark facility (which

is south of

Amoco)

for short periods of

time,

the levels of which are

“not inconsistent with those values calculated... for the

present Clark operation in Blue Island”

CR.

398).

The Agency also performed dispersion modelling

(Agency

Ex.

1)

to compare with Clark and Amoco.

The maximum contribution

using the Amoco proposal for existing facilities

(750 ppm

corrected to 50% excess air) would be less than 0.5 ppm for

the one hour maximum

(R.

454),

This ambient level is

approximately

4 times that which would occur under the

existing emission regulation of 200 ppm.

The Agency concluded

that the impact of the Amoco proposal on air quality would

be negligible at present

CR.

455)

because the existing

16—267

---

—10—

instrumentation is not sensitive enough to detect the difference

CR.

466)

.

The Agency did not do dispersion calculations for

multiple refineries, their results being for a single refinery

ignoring background levels

CR.

465)

.

The Board notes that

conclusions reached from modelling studies performed for

single emission sources by either Amoco, clark, or the

Agency only indicate the possible contribution to air pollution

levels and not the total ambient air pollution levels.

As

was

oointed

out

by

Dr.

~adden,

the

toual

amounts

of

CC

emitted

from

the

FCC

units

may

represent

a

significant

nurnuet

)t

artornc~xj~it~s

b-~.sec

ci

~

~r

—xtau

~r

O~i~

LCflS

cf

CO.

tcadden

estlrates

referenclnç

the

RL~2

Opinion

of

the

Board,

that

a

relaxation

of

the

exist:.ng

CO

emission

standard from 200 ppm to 750 ppm, corrected to 50

excess

air,

as

proposed

by

Amoco,

is

equivalent

to

the

emissions

from

7000

additional

cars

(1970

model)

driven

20 miles a

day.

He

concludes

that

this

is

a

significant

amount

because

the

assimilative

capacity

of

the

atmosphere

is

not

infinite

and

because

violations

of

the

CC

air

quality

standards

do

occur

in

major

metropolitan

areas

of

Illinois.

It

is

clear from the record that these new catalyst

regeneration processes are being installed at Clark and

Amoco in order to improve product yields, the reduction in

CO emissions being of secondary concern.

Amoco’s Ultracat

process

is promoted as a process that improves yields

CR.

426,

428)

and Clark chose the UOP process over Ultracat and

CO boilers because

it

offered the best cost benefit

(R.

342).

In 1972 a short test run of the UOP system at Clark’s

Blue Island refinery showed an increased liquid yield of

1.5

and a CO reduction of more than 90

CR.

340,

352)

Although this CO reduction was not adequate to meet the

existing emission limits, Clark decided to install the UOP

system at both their refineries

in 1972 and early 1973

(R.

340);

a decision the Board cannot condone.

The decision to

install a CO boiler behind an tJltracat

system would depend

on the cost-benefit analysis;

CR.

428)

in addition, there

may not be sufficient CO in the new technology regenerator

exhaust to use a CO boiler to reduce the emissions to 200

ppm

(R.

432).

If it were not for the latter fact,

the Board

would require compliance with the existing standard by the

use of

a CO boiler

to clean the remaining CO from these

regenerators.

Yield information was submitted both by Amoco and

Clark. Amoco Exhibit

3 shows gasoline yields for 4 commercially

operating Ultracat units to have increased by approximately

3~based on

the feed volume;

the range of data for

35

tests

on the 4 units varied between 0.8

and 5.9.

Other data

included in Petitioner’s Exhibit

1 shows gasoline yield

improvements of between 0.7

and 4.7

for three Amoco units.

Clark calculated that the benefit of their hot regeneration

process compared to a CO boiler is enough additional fuel to

16—268

---

—11—

heat 2200 homes each year

(R.

341)

.

Although Clark did not

submit any yield data during the hearings, Table

1

of

the

affidavit submitted by Clark following the hearings projects

an

increase

in

gasoline

yield

of

7.9,

and

a

decrease

in

cycle

(fuel)

oil

of

8.8,

after

their

hot

regeneration

plus

riser

cracking

system

is

installed.

The

increase

in

yield

depends on the product mix for each refinery.

Carbon

monoxide

emission

data

for the Amoco tJltracat

unit

at Woma Piver ~qere~n’~lcded ~n Petit~oner’’-E~h~n

These

aata

were

taken

at

hourly

intervals

hetweer~ February

28, 1973 and Amri:L

27, 1973 and show CO emissions from the

stack

varying

from

a

trace

~

in

excess

of

1, 000

ppm.

According to Amoco

these

data

show

that

the

unit

can

meet

a

limit of

1,~000ppm at stack conditions, or 750 ppm at 50

excess air,

as set forth in their petition on a continuously

operating

basis

CR.

15).

An

examination

of

the

data

shows,

however,

that

the

emissions

are

significantly

less

than

1,000

ppm

most

of

the

time,

as

shown

in

the

following

table.

CO

concentration

in

stack

Percent of time

.~

1,000 ppm

0.15

800 ppm

0,22

700 ppm

0.95

~‘

600 ppm

1.91

500 ppm

4,11

500 ppm

200

ppm

74.0

100

ppm

54.0

During 54 percent of the time the emissions were less than

100 ppm; during 74 percent of the time the CO emissions were

less than 200 ppm; and during ninety-six percent of the time

the emissions were less than 500 ppm which is equal to the

federally proposed new source standard

(Pet, Ex.

1)

Clark did not present any emission data since their UOP

units are under construction,

Their proposal is based on

statements from UOP that an emission concentration of 2000

ppm could be guaranteed

CR.

49)

.

However, Clark Exhibit

4,

a letter to Clark from a C.W. Strother of UOP,

indicates

that after installation of the hot regenerator system, and

reasonable operating experience,

“we would expect the CO

content could be reduced to less than 500 ppm by volume with

minor operating and mechanical changes.”

At the conclusion of the hearings, the Agency took the

position that the 200 ppm standard is technically and economically

feasible based on the R 71-23 record, but that the Amoco

proposal was an acceptable loosening of air quality in that

16—269

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—12—

health and welfare are not impaired; while the benefits to the

people

(improved gasoline yields)

would be increased,

citing

Rule 303, Nondegradation,

of the Air Pollution Regulations.

The

Agency felt, however,

that the Clark proposal would result

in further degradation of air quality without providing any

additional benefits beyond that provided by the Amoco proposal

(R.

478-480).

We agree with this interpretation of the non—

degradation rule by the Agency.

Based on the record in this matter, the Amoco proposal

(750 ppm corrected to

50

excess air for existing sources,

350 ppm corrected to

50

excess air for new sources)

is the

maximum relaxation

to the existing regulation supportable.

A case could possibly be made for a tighter limit in that

96

of Amoco’s data show CO emissions lower than 500 ppm at

stack conditions and the UOP process can, with minor modifications,

reduce emissions to 500 ppm at stack conditions.

The federal

new source standard for CO emissions from FCC catalyst

regenerators

is

0.05 percent by volume

(500 ppm)

based in

part on the recognition of in situ combustion of CO in the

regenerators

CR.

14)

.

However, because the Amoco proposed

limits will not significantly degrade the environment, and

will result in benefits in terms of improved yields,

the Board will

accept the Amoco proposal with the language refinements

suggested by the Agency as contained in our Order attached

hereto.

It should be noted that the new paragraphs

(2) and

(3) of Rule 206(c)

are intended to be applied only to the

new technology catalyst regenerators such as Ultracat or UOP

hot regeneration.

DISCUSSION OF R73-l7, SULFURIC ACID MIST

Activity in reviewing the existing Rule 204(f) (2),

Sulfuric Acid Mist Standards and Limitations, was initiated

by Bell and Howell by petition to the Board on February 13,

1973.

Bell and Howell suggested an amendment to distinguish

between manufacturers and users of sulfuric acid because

small scale users of acid such as Bell and Howell were,

in

their opinion, unable to meet the existing limit of 0.15

lb/ton of acid used or manufactured.

Although the Board was

not required to hold hearings since the petition did not

contain 200 signatures, by order of March

8,

1973 the Board

requested the Agency to advise it on the necessity for

modifying the regulation.

The Agency response was the

proposal submitted to the Board on December 13,

1973.

For the most part, emissions of sulfuric acid mist

result from the manufacturing or use of the acid

CR.

184),

although as will be seen later, combustion processes,

flue

gas conditioning, and stack gas scrubbers also are emitters

of acid mist.

Submissions to the Agency for permits and

other purposes show that one of the biggest problem areas,

aside from acid manufacturing,

is the use of sulfuric acid

in baths to pickle iron and steel products

(R.

181,

187).

16—270

---

—13—

These baths contain about 15 percent acid and their purpose

is to clean the surface of the metal

immersed,

The amount

of acid mist evolving from the tank surface depends on the

temperature,

the surface area of the tank, and the activity

of the reaction

(R.

186).

The use of acid per ton of metal

is not an important parameter.

These pickling facilities

are usually ground—level type sources with the emissions

vented through the roof or side of the building

(R.

188)

The Agency presented,

initially,

information on the

environmental

harm

caused by acid mist,

This information,

exhibit

1, included effects on plants,

human health, and

objects

(corrosion).

The Agency witness testified

(R.

66—

91)

that the industrial hygenists threshold limit value

CTLV)

for acid mist is

1 mg/rn3,

based on

8 hour exposures,

5

days a week,

and that this level can be detected by odor,

taste,

and

irritation

CR.

67-68)

.

Research has shown bronchio-

spasms, increased pulmonary air flow resistance and other

reactions

at

acid

mist

levels

of

0,35

to

0.5

mg/m3

beginning

after

3 minutes of exposure and continuing

throughout

a

fifteen minute exposure period

CR.

69)

.

This research also

showed the occurrence of chronic bronchitis during long term

intermittent exposures.

Human studies indicate 4 times

greater sensitivity to sulfuric acid than to sulfur dioxide

CR.

73).

The Russian acid mist ~eve1, not a standard but a

goal

to be attained,

is 0.3 mg/rn

.

Sulfuric acid causes a

spotting type injury to plant leaves, the sensitivity depending

on factors such

as humidity, light intensity, and nutrient

level;

in conjunction with fog

CR. 74-75)

.

The effects on

materials

(corrosion of metal)

depend on humidity and temperature,

and based on data for sulfur dioxide and the transformation

to sulfuric acid,

it is concluded tha~corrosion can take

place at a concentration of 0.32

mg/rn

(R.

77).

The Agency witness concluded that a maximum 1 hour

ambient concentration of sulfuric acid of 0.2 mg/rn3 would

not have an adverse affect on humans,

plants, animals, and

materials

CR.

78).

It

should be noted that the witness

originally concluded that the maximum 1 hour level should be

0.08 mg/m3 based on the possibility of corrosion

CR.

82);

but considerations of control equipment availability, attainability,

and economics resulted in a maximum 1 hour ambient level of

0.2 mg/m3 which will provide some small margin of safety in

terms of human health

CR.

88). This testimony was not rebutted

by other witnesses and in fact Monsanto

(R.

600)

and Edison

(R.

648)

suggested regula~ionsbased on attaining an ambient

concentration of 0.2 mg/rn

.

The environmental impact data

were presented by the Agency in order to justify its proposal

and the Board does not construe it as establishing an ambient

air quality standard for sulfuric acid mist.

16—

271

---

—14—

The Agency then made dispersion calculations to determine

the allowable emission rate of acid mist.

These calculations,

Agency Exhibit 1 of June

19,

1974,

assumed

a ground level

source,

stable atmospheric conditions,

a wind speed of

1

meter/sec,

and a distance of 100 meters from the source;

and

resulted in

a maximum allowable emission rate of 0.1 lb/hr

(actually the calculation results in 0.073

lb/hr)

.

Under

cross examination,

the Agency witness stated that the stable

atmospheric condition can occur

in Illinois from

25 to 40

percent of the time,

and that the wind speed used

is appropriate

for the stability class used

(R.

536-537).

The distance of

100 meters was used as

a compromise since it does allow over

300 feet of dispersion even though companies using sulfuric

acid are interspersed in the neighborhood

CR.

190)

and thus

located “very near locations where people are expected to

occur for some period of time,

such as residential areas”

CR.

534)

The Agency based their modeling on a “ground level”

emission source;

the reason being that most sources of acid

mist consist of short stacks or vents so that aerodynamic

influences due to the buildings, which could cause downwash,

could occur

(R. 529-530).

Edison suggested that dispersion

from stacks be taken into account; but their exhibit

8,

a

paper by Briggs, showed that for stacks less than 50

higher

than the building, aerodynamic downwash will cause

a plume

to behave like

a ground level source.

This exhibit therefore

supports the Agency position.

The Agency,

in Attachment F

to their post hearing response, made a random sampling of

their permits to see the elevations where acid was emitted.

Of

43 sulfuric acid mist sources,

no acid mist was emitted

through a stack of sufficient height to improve the dispersion

beyond that of

a ground level source according to the Agency.

Monsanto also presented dispersion calculations

to show the

benefits of stack height, and suggested a regulation based

on maintaining a ground level concentration of 0.2 mg/rn3 for

acid users

(R.

600).

Neglecting power plants and confining

ourselves to users of acid, we find that the emissions are

usually from vents on top of buildings and therefore can be

considered “ground level” sources.

The

technical feasibility and economic reasonableness

of the proposed amendment was based on a case study of a

controlled pickling facility.

This facility,

characterized

as

a

large

user

of

acid,

uses

over

1,000

tons/year

of

acid

CR.

202)

and pickles

20 tons/hr of steel plate

(Exhibit 2

of

5/14/74)

.

A description of the facility

(R. 195-199)

indicates

one pickling line consisting

of

six tanks,

two of which

compose the actual pickling operation; exhausted through

a

push-pull system having

a total

flow rate of 48,000 cfm into

three stacks.

Each exhaust system contains control equipment

consisting of demisters and the stacks themselves are 5 to

6

feet above and across the Street from houses, the plant

being located in a cut

CR. 198-199).

16—272

---

—15—

Stack tests were performed on each stack at the facility

on April

3,

1973.

The results show average total emissions

for three tests of the stacks to be 0.058

lb/hr of sulfuric

acid, with the maximum total emission measured being 0.067

lb/hr

(Exhibit

2 of 5/14/74)

.

The test was observed by the

Agency

(Exhibit

1 of 5/14/74)

and found to have been properly

conducted.

This facility is therefore able to comply with

the proposed amendment.

Economic analyses were performed by the Agency to show

the

costs

of

complying

with

the

0,1

lb/hr

proposal.

Data

from

the

aforementioned

controlled

facility

were

used

along

with estimates from control equipment vendors

in generating

cost estimates for small, medium, and moderately large

facilities

CR.

222)

.

Control equipment efficiency

of 98

percent was used even though higher efficiency equipment is

available, based on the stack tests

(B.

229).

In addition,

costs for the small facility were based on

98 percent collection,

even though compliance would require a less efficient system.

Costs of equipment and installation were compared to the

gross income expected from these facilities. The following

table summarizes the results of the economic study

(Exhibit

3 of 5/14/74)

Facility

Exhaust Gas Flow

Quantity of Steel

Cost of Control as

Pickled

Percent of Income

Small

10,000 scfm

16,000 ton/year

3.8%

Medium

20,000 scfm

32,000 ton/year

3.1%

Large

40,000 scfm

64,000 ton/year

2.5%

In absolute terms the control system costs vary from

$6,100 to $15,950 annually.

The Illinois Manufacturers

Association presented profit information for U.S. manufacturers

and compared it with the above percentage compliance costs

in attempting to show the economic unreasonableness of the

proposed amendment

(IMA letter dated August 5,

1974); but

incorrectly interpreted the Agency’s conclusions.

Agency

compliance costs are 2.5 to 3.8 percent of income

(sales

minus expenses) whereas IMA profits of

4.0 to 5.6 percent

are in terms of sales and cannot be compared directly. The

Agency compliance costs,

in terms of sales,

are considerably

less than the profits and are not found by us to be unreasonable.

A significant issue concerns the applicability of the

Agency’s case study

to other acid users.

The Agency characterized

their case study as being an adequate test;

the largest user

of sulfuric acid for which valid information was available

to the Agency

CR.

204).

Comments from Keystone Steel and

16

—273

---

—16—

Wire and others indicated facilities using considerably

larger quantities of acid.

For example, Keystone uses about

8 times the acid as in the case study facility

(R.

203) and

they

estimate

six

other

companies

in

Illinois

as

having

similar usage rates

CR.

204).

These very large facilities

have several pickling lines and have exhaust gas flow rates

considerably

in excess of the 48,000 cfm of the facility

studied.

Testimony from Keystone was that in 1973,

6,765

tons of acid were used and 300,000 tons of rods and wire were

pickled on their three lines

(B.

558.)

.

To comply with the

proposed limit of

0.1 lb/hr for their plant would require

Keystone to install a collection system having 99.53 percent

efficiency;

~nd would result in a stack emission concentration

of 0.14 mg/m’~,which is lower than the ambient level of 0.2

mg/rn3 recommended by the Agency

CR.

562).

The Board finds that for these few large facilities a

regulation taking into account the size of the facility is

necessary based on the testimony.

The 0.1 lb/hr limit

proposed by the Agency is suitable for the great majority,

but there

is a certain size facility beyond which compliance

may not be feasibl.

Keystone proposed a regulation based on the surface

area of the pickling tanks which, assuming a collection

system efficiency of

95%, would allow them to emit 1.08

lb/hr

CR.

565).

They did not,

however, perform dispersion

modelling to determine the resulting ambient levels of acid

CR.

567).

Keystone controls emissions from the tanks using

a layer of foam but does not ha\~eother controls

(B.

571).

Olin Brass proposed the 0.1 lb/hr limit for facilities

using 1,333 lb/hr of acid or less,

and the existing limit of

0.15 lb/ton for facilities using in excess of 1,333 lb/hr

(Written submission dated July 30,

1974)

.

On

a yearly

basis, assuming 6,000 hours/year,

this breakpoint would

represent

a facility using 4,000 tons/year of sulfuric acid.

Other witnesses suggested other methods of accounting for

facility size.

The record contains information as to the factors to be

used in formulating a size-dependent regulation.

The first

issue is the uncontrolled emissions of sulfuric acid mist.

Exhibit

1 of 5/14/74 states that the Agency case study at

one time had vapor emissions of 34.7 mg/rn3 based on test

results an~that uncontrolled emissions in the range of

20

to

50

mg/rn

can be expected.

Keystone suggests

30 mg/rn3 as

an average value for pickling operations

(R.

562)

and KSF

Chemical Processes, manufacturers of mist removal equipment,

notes that acid mist levels up to

50

mg/rn3 can exist in the

inlets of control equipment (Exhibit 1 of 6/19/74)

.

Therefore,

16—274

---

—17—

a value of

35 mg/rn3 for the uncontrolled emissions

is supported

by the record and is used by us

in structuring the regulation.

The second factor is the degree of control possible.

PUREco, designers of pickling facilities and acid recovery

facilities, testified that an emission concentration of

0.4

mg/rn3, achieved in the Agency case

study, can be achieved

(B.

626)

,

based on the results of an emission test;

and a

concentration

50

to 100 percent greater can be routinely

maintained

(B.

629).

The facility tested by PUREc0 had a

push-pull exhaust system and mesh dernister pads.

In terms

of equipment efficiency,

95 or

98 percent would be a practical

level using mesh demister pads

(R.

632)

.

The PUREc0 testimony

indicates that an emission concentration of 0.6 to 0.8 mg/rn3

can be routinely maintained and this suggests, using an

uncontrolled value of

35 mg/rn3,

a collection system efficiency

of 97.7

to 98.2 percent.

Agency data for the controlled

facility

(Exhibits

1 and 2 of

5/14/74)

can be used to calculate

a controlled emission concentration of 0.37 mg/rn3 which,

when compared to an average uncontrolled emission of

35

ing/m3, results in a collection system efficiency of

98.9

percent.

The Keystone witness was of the opinion that

efficiencies greater than 95 percent could not be achieved

on

a day-by-day basis using demister pads

CR.

574).

The

majority of the information indicates the reasonableness of

using

98 percent collection efficiency as

a factor in developing

the regulation which we are ordering today.

The final factor is the tie-in with the size of the

facility.

The Agency data is for a facility using 1,000

tons/year of acid, operating 6,240 hours/year, and having an

exhaust flow rate of 48,000 cfrn.

Keystone uses 6,765 tons/year

of acid, operates 6,600 hours/year, and would need an estimated

exhaust flow rate,

based on their calculations,

of 194,000

cfm.

Other facilities mentioned by KSF and PUREc0 used up

to 15,000 tons/year of acid and had exhaust flow rates as

high as 600,000 cfm.

(Exhibit

1 of

6/19/74,

R.

626)

Based on all the above materials, we find that a regulation

limiting the emissions of sulfuric acid mist to 0.5 lb/ton

of acid used is justified for the few large facilities.

This would require control equipment of approximately

98

percent efficiency;

achievable with a well maintained push-

pull exhaust system plus demister. Applied to Keystone’s

facility,

the resulting emission rate allowed would be

approximately 0.51 lb/hr; and applied to the Agency case

study facility,

the resulting emission rate allowed would be

approximately 0.08 lb/hr.

The Agency proposal of

0.1 lb/hr

is equivalent to this

0.5 lb/ton regulation

at

a yearly acid

usage rate of approximately 1,300 tons.

Therefore,

the

emission limits we order are the following:

16—275

---

—18—

0.1 lb/hr

for less than 1,300 tons per year acid used;

0.5 lb/ton acid used for greater than or equal

to 1,300

tons per year acid used.

This regulation is consistent with the Agency proposal for

most users of sulfuric acid, and would in addition allow

some relief for the few large scale users of acid.

In their comment relating to the Proposed Final Draft

the Agency points out,

correctly,

that the emission limit of

0.5 lb/ton for the large facilities will result in an ambient

concentration greater than the desired 0.2 mg/rn3 using their

dispersion model.

We believe, however, that the few large

facilities such as Keystone Wire would he unable to meet the

Agency’s 0.1 lb/hr. emission standard but are able to comply

with

our 0.5 lb/ton standard.

The Agency also suggests in their comment that references

to

acid

mist

and acid usage be based on

100%

sulfuric acid.

They point out that the test method referred to in Rule

204(g) (2)

measures acid mist as 100%

acid

and

that

their

facility study was in terms

of

100% acid.

Keystone specified

acid usage in terms

of

66°Baumne acid which is 93,2% sulfuric

acid,

For

consistency

we hereby specify that all references

to sulfuric acid are to be based on 100% acid.

Other comments received on the Proposed Final Draft

related to acid recovery systems, and to the aggregating of

emissions

from multiple sources, among other things; all of

which

have

been considered by the Board.

The above discussion applied to users of acid.

The

existing regulation as applied

to manufacturers of acid was

not proposed to be amended by the Agency,

and little testimony

concerning manufacturers was presented.

Testimony also concerned the application of the proposed

amendment

to non—users of sulfuric acid,

Glass container

manufacturers and utilities using flue gas conditioning or

sulfur oxide scrubbing devices at their power plants were

concerned that the Agency may apply the limits to them.

The

Agency reiterated that they were mainly concerned,

in this

proposal, with users of acid and intend the regulation to

apply to users of acid

(R.

544).

In addition, when testimony

regarding emissions of sulfur compounds from flue gas conditioning

devices was presented,

the Agency stipulated that the proposed

regulation

is not intended to include

flue gas conditioning

CR.

548).

We accept the limitation on the applicability of

the

regulation.

16—276

---

—19—

The Agency proposal to amend Rule 204(g) (2), Measurement

Techniques, was withdrawn during the hearings

CR.

520)

.

They

plan to reintroduce

a modified procedure in the future.

I,

Christan

L.

Moffett,

Clerk

of

the

Illinois

Pollution

Control

Board,

hereby

certify

the

above

Opinion

was

adopted

on

the

Q~day

of

March,

1975 by a vote

of

~

~sanL.I~1ofetr

Illinois Pollution

rol Board

16

—

277