ILLINOIS POLLUTION CONTROL BOARD
    December 20, 1973
    IN T~iEMATTER OF:
    PROPOSED MODIFICATION OF
    )
    R-73-6
    AIR POLLUTION CONTROL
    REGULATION 205
    (b)
    (1)
    OPINION AND ORDER OF THE BOARD
    (by Mr. Marder)
    On
    April 13, 1972, the Pollution Control Board adopted a
    comprehensive scheme of emission standards for air contaminants;
    this was docketed R 71-23.
    Included in these regulations was Rule
    205
    (b)
    (1)
    which states as follows:
    “No person shall cause or allow the discharge of
    more than 8 pounds per hour of organic material in-
    to the atmosphere during the loading of any organic
    material from the aggregate loading pipes of any
    loading facility having a throughput of greater than
    40,000 gallons per day into any railroad tank car,
    tank truck, or trailer, unless each such loading
    pipe is equipped with air pollution control equip—
    ment capable of reducing by
    85
    or more the uncon-
    trolled organic material that would be otherwise
    emitted to the atmosphere if splash loading were
    employed.”
    The compliance date for this regulation is December 31,
    1973.
    On March 26, 1973,
    the Illinois Petroleum Council,
    a trade
    association of integrated oil companies,
    filed a petition asking
    for modification of this regulation.
    The proposed regulation
    would recognize submerged
    loading pipes as
    an acceptable pollution
    abatement method when loading organic material.
    On May 11,
    1973, the Agency filed a letter outlining its
    reasons for recommending adoption of the proposal.
    The essence
    of the letter is that the best data available show that submerged
    pipe loading will comply with the intent of the regulation by
    reducing emissions by 85
    over splash loading.
    Two hearings were held on this matter, the first on June 6,
    1973,
    in Chicago, and the second on July 23, 1973,
    in Springfield.
    Two
    main
    points
    seemed
    to
    ring
    clear
    during
    both
    hearings.
    1)
    The
    regulation
    is
    somewhat ambiguous, part-
    ially because of the use of the term “splash
    loading” which has a negative definition.
    10
    —485
    —2—
    2)
    The intent of the regulation may very
    well have been to allow submerged pipe
    loading as an acceptable pollution con-
    trol
    device.
    The Illinois Petroleum Council has made a strong case in its
    behalf, and as mentioned because the Agency is in agreement no re-
    buttal was offered.
    It would seem that the object of all parties
    concerned is to get a clear definition of the regulation.
    The Illinois Petroleum Council contends that a total expendi-
    ture of $18,300,000 would be needed to install vapor recovery sys-
    tems
    on all existing terminals in Illinois.
    Based on a standard
    terminal
    (R.
    21)
    the Illinois Petroleum Council anticipated a net
    operating loss of $22,886.50 per standard terminal.
    This point re-
    quires some thought.
    Although we may concede that the imposition
    of vapor recovery systems will result in an operating loss,
    it is
    the first responsibility of the Board to maintain an environment
    which meets the air quality standards and which affords citizens a
    high degree of protection from nuisances.
    The fact that pollution
    control devices
    do not “pay for themselves”
    from a corporate view-
    point does not necessarily mean that they will not more than pay
    for themselves on an environmental basis.
    In regards to vapor recovery systems, perhaps the main point
    is that very few
    (R. 11, 7/23/73)
    such units are in operation to-
    day.
    Perhaps even more significant
    is that manufacturers are not
    willing to guarantee that these units would meet the 85
    criteria
    during
    all’ t~mperatureextremes encountered in Illinois
    (R.
    20,
    7/23/73)
    Evidence was presented
    (R.
    26,
    6/25/73)
    that by using American
    Petroleum Institute Bulletin 2514
    (Pet. ex.
    4)
    a loss reduction of
    about 88
    can be accomplished by submerged pipe loading.
    The Illinois Petroleum Council has by exhibits shown that much
    of the testimony given during the hearings on R-71-23
    (Emission
    Standards)
    supported submerged pipe loading.
    1)
    (Pet.
    ex.
    7a)
    Statement by Mr.
    C.J.
    Pardee..
    .
    “testimony was presented by
    Continental Oil Co. concerning its re-
    search on the effectiveness of sub-
    merged fill pipe loading in the re-
    duction of air emissions from organic
    material.
    This research indicates
    that by the use of submerged fill
    pipes
    the addition of such a device
    not only will reduce air emissions
    from 85 to
    95 percent of total em-
    issions from the tank...”
    10—486
    —3—
    2)
    (Pet.
    ex.
    7b)
    Statement by Mr.
    H.
    E.
    Hesketh:
    “.
    -
    .the reducing of the emiss-
    ions by
    85 percent,
    in my opinion, can be
    achieved by bottom-type loading.”
    3)
    (Pet.
    ex.
    7
    cJ)
    Statement by Mr.
    R.
    H.
    Bruggink of Clark Oil Co.:
    “We urge the
    Board to consider the alternatives and the
    cost/benefit relationship to specify sub-
    merged pipe filling or the equivalent as
    alternatives to be used for Rule 205
    (b)
    (1)
    .“
    The above statements are not grounds for an amendment but
    merely reflect the feeling of industry at the time.
    The intent of the use of submerged pipe loading is alluded to
    when one looks at the opinion written by Mr. Currie,
    “In the Matter
    of Emission Standards” on April 13, 1972,
    page 40:
    “Other significant sources of offensive or-
    ganic emissions are facilities
    for the load-
    ing 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 con-
    trols.1’
    (Emphasis added.)
    The following points review how the Illinois Petroleum Coun-
    cil has arrived at an
    88 percent reduction figure.
    1.
    There
    is no accurate
    way
    of
    measuring
    actual losses due to splash loading
    (R.
    6,
    6/25/73),
    and therefore it is almost
    impossible
    to calculate
    a 100 percent
    starting point from which an
    85 percent
    reduction can be calculated.
    2.
    Splash loading losses can be considered
    as made up of three separate losses:
    a)
    Displacement
    b)
    Evaporation
    c)
    Entrainment
    3.
    Entrainment losses by definition are elim-
    inated by bottom filling.
    10
    —
    487
    —4—
    4.
    The American Petroleum Institute Bulletin
    2514
    (R.
    26, 6/25/73)
    states that entrain-
    ment losses may be three times evaporation
    losses.
    Also data show that evaporative
    1osses are significantly less for submerged
    ~ading than splash loading.
    5.
    Using these facts
    the Illinois Petroleum
    Council has calculated
    (Pet.
    ex.
    2)
    that
    the percent reduction of emissions by us-
    ing submerged fill pipes over splash load-
    ing would be abOut 88 percent.
    On the basis of the above evidence the Board must agree that sub-
    merged pipe loading will indeed meet the
    85 percent reduction criteria
    intended by Regulation 205
    (b)
    (1).
    During the comment period the Illinois Environmental Protection
    Agency reported that the Federal Environmental Protection Agency has
    published a supplement to its AP-42 Emission Factor text.
    Using the
    new factors the Illinois Environmental Protection Agency calculates
    emission control of 67
    rather than the aforementioned 80
    to 90.
    The Agency indicated that upon verification of the above calculations,
    the Board will be notified.
    Having received no such notification, the
    Board will rule on the best firm information it has
    at its disposal.
    Again the Board feels that submerged pipe loading
    is
    an efficient
    method of dealing with the problem.
    It is a simple method, one
    which we can be relatively confident will be used by plant personnel.
    One of our major considerations
    is that pollution control equipment
    should be usable.
    Many control devices, although technically sound,
    are so besieged with mechanical difficulties that plant operating per-
    sonnel shove them to the side,
    and they suffer the possibility of be-
    coming mere window dressing.
    This should not be the case with sub-
    merged pipe loading.
    This Opinion constitutes the findings of fact and conclusions
    of law of the Board.
    ORDER
    IT IS
    THE ORDER of the Illinois Pollution Control Board that
    Rule 205
    (b)
    (1)
    of the Air Pollution Regulations shall be changed
    from its present wording to read as follows:
    “No person shall
    cause or allow the discharge
    of more than
    8 pounds per hour of organic mat-
    erial into the atmosphere during the loading
    of any organic material from the aggregate
    loading pipes of any loading facility having a
    throughput of greater than 40,000 gallons per
    day into any railroad tank car, tank truck or
    10— 48~
    —5—
    trailer unless such loading facility is
    equipped with submerged loading pipes or
    a device that is equally effective in
    controlling emissions and is approved by
    the Agency according to the provisions of
    Part
    I of this Chapter.”
    IT
    IS SO ORDERED.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify that the above Opinion and Order was
    adopted on the’20th day of December,
    1973 by a vote of 5-0.
    Qs~ifl,~L~~
    10
    —
    489

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