Petitioner,
v.
ILLINOIS ENVIRONMENTAL
PROTECTION AGENCY,
Respondent.
IEPA
08-00
TC114-
(Provisional Variance - Air)
RECEEIVED
CLERKS OFFICE
JAN 2 2 2008
STATE OF ILLINOIS
c4nllution
Control Board
Date: January 18, 2008
ILLINOIS ENVIRONMENTAL PROTECTIO
AGENCY
By: Charles -
E. Matoesian
Assistant Counsel
Division of Legal Counsel
BEFORE THE ILLINOIS POLLUTION CONTROL BOARD
WRB REFINING LLC WOOD RIVER REFINERY
NOTICE
TO: John Therriault, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
PLEASE TAKE NOTICE that I have today filed with the Office of the Pollution Control
Board the
REQUEST FOR PROVISIONAL VARIANCE – SULFUR DIOXIDE EMISSION
LIMITATION REQUIREMENTS
on behalf of the Illinois Environmental Protection Agency, a
copy of which is herewith served upon you.
1021 North Grand Avenue East
P.O. Box 19276
Spring field, IL 62794-9276
THIS FILING IS SUBMITTED ON
217/782-5544
RECYCLED PAPER
ILLINOIS ENVIRONMENTAL PROTECTION AGENCY
January 18, 2008
WRB REFINING LLC WOOD RIVER REFINERY
Petitioner,.
V.
ILLINOIS ENVIRONMENTAL PROTECTION
AGENCY,
Respondent.
IEPA 08
(Provisional
Variance — Air)
Re : Request for Provisional Variance — Sulfur Dioxide Emission Limitation
Requirements
On January 16, 2008, the Illinois Environmental Protection Agency ("Illinois EPA")
received from WRB Refining LLC ("WRB") a request for provisional variance to allow
the shutdown of the flare gas recovery compressor ("FGRC") for the Distilling Flare at its
Wood River Refinery. The shutdown of the FGRC may result in an exceedance of 35 Ill.
Adm. Code 214.301 and of the Wood River Refinery's Clean Air Act Permit Program
("CAAPP") operating permit condition 7.7.3(g). Section 214.301 concerns the rate of
emission of sulfur dioxide ("SO
2")
from process emission sources. The Illinois EPA
accepted this request for review pursuant to the requirements of the Illinois
Environmental Protection Act ("Act") and the applicable Illinois EPA regulations.
The Illinois EPA evaluated the request pursuant to the requirements of Sections 35, 36,
and 37 of the Act (415 ILCS 5/35, 5/36, 5/37) and the Illinois EPA regulations at 35 Ill.
Adm. Code Part 180. The Illinois EPA is granting WRB's request for provisional
variance as the source has demonstrated that an arbitrary and unreasonable hardship will
result in the event of a denial. More specifically, the regulatory relief requested by WRB
is intended to allow maintenance to prevent a possible catastrophic failure of the machine
which might result in a significant safety concern and risk to personnel. Such a failure
might also lead to a larger release.
WRB seeks a provisional variance from operating permit condition 7.7.3(g) as it pertains
to SO2
emissions from the Distilling Flare resulting from shutdown of the FGRC
contained within CAAPP application number 95120306, issued on November 7, 2003,
and 35 Ill . Adm. Code Part 214 Subpart K (Process Emission Sources). The Illinois
EPA is granting relief from operating permit condition 7.7.3(g) as it pertains to SO2
emissions from the Distilling Flare resulting from shutdown of the FGRC and the
applicable requirements of 35 Ill. Adm. Code Section 214.301 (General Limitation).
Relief is granted until such time as maintenance to the Distilling Flare FGRC is
completed, or through January 31, 2008, whichever occurs first. However, in no case
may the period of the shutdown of the FGRC, or the relief granted by this provisional
variance, exceed five days.
The Illinois EPA is granting WRB's request for a provisional variance subject to the
following conditions:
1.
In lieu of the emission limitation requirements of 35 Ill. Adm. Code Section
214.301 (General Limitation), WRB shall be allowed to exceed the SO
2 emission
limits resulting from a shutdown of the FGRC for the Distilling Flare for a period
not to exceed five days.
2.
In lieu of the emission limitation requirements of operating permit condition
7.7.3(g) of CAAPP application number 95120306, issued on November 7, 2003,
WRB shall be allowed to exceed the SO 2
emission limits resulting from a
shutdown of the FGRC for the Distilling Flare for a period not to exceed five
days.
3.
WRB
shall submit to the Illinois EPA, by February 15, 2008, the following:
a.
A report containing a complete description of the repairs that were
required to return the FGRC to operation.
b.
A complete description of the preventative maintenance program initiated
to prevent a reoccurrence of the subject problem.
c.
Sulfur dioxide emissions released from the distilling flare during the
timeframe of shutdown of the FGRC. This shall include all supporting
calculations and the actual clocktimes of the shutdown period.
d.
A complete description of all measures taken during the shutdown to
minimize the release of sulfur dioxide emissions from the entire refinery
complex.
Robert A. Messina
Chief Legal Counsel
Illinois Environmental Protection Agency
cc: IPCB,
Clerk
4?
• 4
STATE OF ILLINOIS
)
) SS.
COUNTY OF SANGAMON )
PROOF OF SERVICE
I, the undersigned, on oath state that I have served the attached Request for Provisional
Variance – Sulfur Dioxide Emission Limitation Requirements upon the person to whom it is
directed, by placing it in an envelope addressed to:
TO: John T. Therriault, Clerk
Illinois Pollution Control Board
James R. Thompson Center
100 W. Randolph Street, Suite 11-500
Chicago, Illinois 60601
and mailing it by First Class Mail from Springfield, Illinois on January 18, 2008 with sufficient
postage affixed.
SUBSCRIBED AND SWORN TO BEFORE ME
this 18
th
day of January, 2007
Notary Public
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OFFICIAL SEAL
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I.
BRENDA BOEHNER
:i:
NOTARY PUBLIC, STATE OF ILLINOIS *
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COMMISSION EXPIRES 11
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3-2009 :;:.
THIS FILING IS SUBMITTED ON RECYCLED PAPER