'btl b Illinois EnvironmentalProtection Agency Bureauof Air Iuly 2007
ResponsivenessSummary for PublicComments and Questions on the Cokerand Refinery Expansion Project at the WoodRiver Refineryin Roxana,lllinois andthe Wood RiverProducts Terminal in Hartford,Illinois
Facilif Identificationand Application Nos.: Ref,rnery:I l9090AAA, 06050052 Terminal:1 19050AAN, 061 10049 Tableof Contents
Page Decision 3 Background J CommentPeriod and Public Hearins 3 AvailabiliWof Documents 4 Appeal Provisions 4 Commentsand Ouestions with Responsesbv theIllinois EPA 5 General Air Pollution 8 New SourceReview 9 BACT/LAER 9 Air Qualiw Analvsisand Emission Offsets t) Analysisof Altematives 16 Global Warming 20 Air Permitting 25 Flarine 25 Crude Oil Supplv 35 Delayed Coking JI Emissions 40 Other 45 ExistineGroundwater Contamination 41 Compliance 48 PublicParticipation 49 OtherComments 50 For Additional Information 50 o DECISION On July 19,200l,lhe Illinois EnvironmentalProtection Agency (Illinois EPA) Bureauof Air issueda constructionpermit to ConocoPhillipsfor theCoker and Refinery Expansion Project at its Wood River Refinery at 900 SouthCentral Avenue in Roxanaand the Wood River Products Terminalat 2150South Delmar in Hartford. The Bureauof Air hasalso issued this surnrnaryto addressquestions relevant to the issuanceof theair permitand other questions and comments raisedduring the commentperiod. Questionsrelating to theBureau of Waterpermit will be addressedin a separateResponsiveness Summary when the Bureau ofWater takesfinal action on therevised NPDES permit.
Copiesof thepermits can be obtainedfrom the contactlisted at the endof this document.The permitsand additional copies ofthis documentcan also be obtainedfrom theIllinois EPA websitewww.epa. state. il.us/public-notices/.
BACKGROUND
ConocoPhillipsoperates the Wood River Refinerylocated in Roxana,Illinois to producea varielyofpetroleum products for distributionin the St.Louis, Chicago, and Indianapolis Metropolitanareas and throughout the Midwest. WoodRiver is positionedby refiningcapacity andby geographicallocation to processthe growingvolumes ofheavy crudeoil from Canada.
On May 15,2006,the Illinois EPA, Bureauof Air receivedan application from ConocoPhillips for a Cokerand Refinery Expansion (CORE) Project. The COR-E Project entails installing facilitiesto increaseboth the totalcrude processing and percentage ofheavier crude at the Wood RiverRefinery in orderto increasethe supplyof petroleumproducts to theUpper Midwest. In orderto handlethe increasedproduct throughput, ConocoPhillips is alsoproposing certain changesat theWood River Products Terminal (also owned by ConocoPhillips).The Illinois EPA is consideringConocoPhillips's CORE project and the changesto theWood River Products Terminalto comprisea singlelarger project for thepurpose of the federalrules for Preventionof SignificantDeterioration (PSD) and the state rules for Major StationarySources Construction andModifi cation (MSSCAM).
COMMENT PERIOD AND PUBLIC HEARING
The Illinois EPA BureauofAir evaluatesapplications and issues permits for sourcesof emissionsto theabnosphere. An air permitapplication rnust appropriately address compliance with applicableair pollutioncontrol laws and regulations before a permitcan be issued. Followingits initial technicalreview of ConocoPhillips'application, the Illinois EPA Bureauof Air madea preliminarydetermination that the applicationsmet the standardsfor issuanceof a constructionpermit and prepared draft permits for publicreview and comment.
ConocoPhillipsrequested that the Illinois EPA hold a publichearing on theCORE Project. This hearingalso addressed ConocoPhillips's application for revisionand reissuance of its National PollutantDischarge Elimination System (NPDES) permit to allow increasedwastewater dischargesfrom theWood River Refinery due to the COREproject. Thepublic commentperiod openedwith thepublication of a hearingnotice in the Alton Telegraphon March24 , 200'7. The hearingnotice was published again in theAlton Telegraphon March31"' and April 7,2007 . The publichearing was held on May 8,200'7,aI theHartford Elementary School in Hartford. The purposeof this publichearing was to acceptoral comments into the writtenhearing record and answerquestions about the proposed project. The written comment period remained open until June15,2007.
AVAILABILITY OF DOCUMENTS
The constructionpermits issued to ConocoPhillipsand this responsivenesssummary are availableon theIllinois PermitDatabase at www.epa.gov/region5/airlpermits/ilonline.htm (pleaselook for the documentsunder All PermitRecords (sorted by name),PSD,Major NSR Records).Copies ofthese documents may alsobe obtainedby contactingthe Illinois EPA at the telephonenumbers listed at theend of thisdocurnent.
APPEAL PROVISIONS
The constructionpermits being issued for theproposed project grants approval to construct pursuantto the federalrules for Preventionof SignificantDeterioration ofAir Quality(PSD), 40 CFR 52.21.Accordingly, individuals who filed commentson the draftpermit or participatedin thepublic hearing may petitionthe U.S. Environmental Protection Agency (USEPA) to review thePSD provisions of the issuedpermit. In addition,as comments were submitted on the draft permitfor theproposed project that requested a changein thedraft permit, the issuedpermit does not becomeeffective until afterthe period for filing ofan appealhas passed. The procedures govemingappeals are contained in the CodeofFederal Regulations (CFR), "Appeal ofRCRA, UIC andPSD permits," 40 CFR 124.19.If an appealrequest will be submittedto USEPAby a meansother than regular mail, referto the EnvironmentalAppeals Board website at www.epa.gov/eab/eabfaq.htm#3for instructions. lf an appealrequest will be filed by regulat mail, it shouldbe senton a timelybasis to the followingaddress:
U.S.Environmental Protection Agency Clerk of the Board,Environmental Appeals Board (MC I 1038) Ariel RiosBuilding 1200Pennsylvania Avenue, N.W. Washington,D.C. 20460-000I Telephone:202 /23 3 -0 | 22 Gcncral l. Peoplehave catalytic converters on their cars. ConocoPhillipsshould put catalytic convefierson its operations.
The various emissionunits at the refinery are and will be equippedwith appropriate equipmentto control emissionsof different pollutants. This control equiprnentdoes not include catalyticconverters like thoseused on automobileengines. Catalytic convertersare specificallydesigned to control certain pollutantsas present in the exhaustfrom gasoline-fueledengines. The fypesof control equipmentthat are used on different emissionunits at the refinery dependon the particular emission characteristicsofthe units. For example,the emissionsof nitrogen oxides(NO,) from the FluidizedCatalytic Cracking (FCC) Units will be controlledby selective catalyticreduction (SCR) systems, which useammonia and a catalystbed to control emissions.NO* emissionsfrom heatersand boilerswill be controlledwith ultra low NO* burners that minimize the formation of NO*.
2- Whatis the cuffentconventional crude distillation capacity ofthe refinety?
The current conventionalcrude distillation capacityis 306,000barrels per day.
3. Whatis the cunentoutput of dieselfuel from therefinery?
ConocoPhillipsindicates that the output of dieselfuel is approximately70,000 barrels per day, all cf which is low sulfur diesel.
4. Whatwill be thecetane level of theultralow sulfurdiesel fuel afterthe proposed project is complete?Is thecetane level dependent on renewablediesel production?
At the public hearing,ConocoPhillips indicated that the cetanelevel oflow sulfur diesel,currenlly at 48, is not expectedto change. The specificationfor low-sulfur dieselis a minimum cetanelevel of42. The cetanelevel oflow sulfur fuel produced by the refinery is not dependenton renewablediesel production.
5. Are futureprojects expected to reducearomatic content and increase cetane to meetthe new USEPAregulations?
The Illinois EPA is not ableto predict the outcomeof future projectsat the refinery.
6. Is gasolineoutput with theproposed project dependent on theethanol addition to meet theminimum octane requirements?
According to ConocoPhillips,the refinery hasthe ability to make gasoline blendstocksthat do not require ethanoladdition. However,one of the advantagesof the project is the ability to make more "reformulated blendstock." This is the gasolineblendstock that is prepared for usewith 10 percentethanol.
7. What is themaximum vapor pressure speciflcation for gasolinein summermonths?
As explainedby ConocoPhillipsat the public hearing,there is no longer a vapor pressurespecification. Reformulated gasoline has what is termed a '.VOC limit," which is an equationthat incorporatesvariables such as the actual distillation points of the blend,the sulfur content,etc.
8. What is the capon vaporpressure ofgasoline?
As explainedby ConocoPhillipsat the public hearing,since reformulated gasoline is now required, there is no longer a cap on the vapor pressureof gasoline.The actual vapor pressurefor the reformulatedgasoline blendstock produced by the refinery is now about 5.5 Reid vapor pressure(RVP). In the past,when the vapor pressure was capped,the RVP was 8.0. The reasonthat reformulatedblendstock has to be lower than 5.5 RVP is becauseblending ethanol with gasolineelevates the vapor pressure,which must be compensatedfor by a lower RVP in the gasoline blendstock,
9. Will theproposed project enable ConocoPhillips to removepentanes during the summer to allow ethanolblending? Also, if pentanesare taken out, where are they stored?
The new coker gasplant will improve the separationofpentanes from the gasoline blendstock. Thesepentanes are storedand blendedinto conventionalgasoline for usein attainment areas.
10. How muchnatural gas does the refinery use today compared with how muchit will use afterthe proposed project? Will hydrogenbe producedfrom naturalgas?
The main sourceoffuel for usein the refinery is refinery fuel gasproduced as a byproduct of refining operations.According to ConocoPhillips,the refinery would Spically useabout 40 million standardcubic feet ofnatural gasper day alter the proposedproject, which is what it currently uses.The proposedhydrogen plant will userefinery gasas a feedstock.The needfor hydrogenis minimizedby the using of coking as an initial crackingprocess. As related to minimization of flaring, useof nahlral gasto supplementthe fuel supply to the refinery is desirableas it provides the necessaryflexibility to be able to consistentlyrecover waste gas for useas fuel.
11. Ratherthan flaring waste gases, ConocoPhillips should capture the energyvalue of waste gasesby capturingthem and using them as fuel.
Theserecovery systems are alreadyin placeat the refinery. For example,the majority offuel gasesused in the refinery, which are usedas fuel in the heatersand boilers,comes from recoveredprocess gas. 12. I am concernedabout benzene releases from the refinery.
A variety offederal regulatoryprograms currently in placeare Nctingto reduce releasesof benzenefrom the refinery. In addition,USEPA is adoptingregulations to reducethe benzeneemissions from automobilesand other gasolinepowered vehicles,which would require a significantreduction in the benzenecontent of gasoline.
13. I am concemedabout the amount and quality of wastewaterdischarged from therefinery.
Commentsand questionsabout wastewater discharges will be addressedby the Illinois EPA's Bureau of Water when it takesfinal actionon ConocoPhillips' applicationfor a revisedNPDES permit for the Wood River Refinery.
14. We arerunning out of gas. We'vereached maximum production, and we've got to find the gasor thepetroleum and we haveto useit at the sametime. We haveto conserve.It doesn'tmake sense to useit up asfast as we canbecause we havechildren and grandchildrento think about. Theother thing that's a realityis theproblem of global warmingissue that we all haveto dealwith. I hopethat ConocoPhillips will look into usingrenewable sources of energyat this refinery. Are thereany plans to try to usesolar panelsor wind or electricitygenerated from theriver aspart of theproposed project?
As discussedby ConocoPhillipsat the public hearing,ConocoPhillips has a technologygroup that is looking into alternativesources of power,but at this point in time they do not fit into this particular project.
15. What additionalsafety measures can be takenby ConocoPhillipsto assurethe safety of the workersand the sr"rroundingcommunity should a major incident occur? What wamingalert system is in placefor thesunounding communities in the eventof a chemicalleak, explosion or toxic release?A full emergencycommunity aleft system shouldbe in placethat includes a telephonewaming system and community waming signalsthat distinguish whether residents should evacuate or seekcover inside, with the environmentalstandards.
ConocoPhillipsindicates that worker safetyis alwaysa concern,both to protect individual workers from accidentsand to preventincidents. Work to improve worker safety,including safet5rawareness, safety compliance and operationaland processchanges to improve safety,occur on an ongoingbasis, Theseactions also reducerisks for nearby residents.The refinery doeshave a communityalert networkoby which it can quickly contactarea residentsby phonein the caseofan emergency,
16. The draftpermit does not addressnew equipment and process changes for productionof renewablediesel fuel from animalfats and vegetable oils, as recently announced by ConocoPhillips.If this activityis goingto occurat theWood River refinery, why is there nothingin thepermit application and the draftpermit relating to theseplans? The production of renewablediesel fuel is not addressedby the applicationfor this permit or the permit itself becauserenewable diesel fuel is not part of the CORE project that is being addressed.ConocoPhillips has not announcedspecific plans for the Wood River refinery in this regard. If ConocoPhillipsdecides to produce renewablediesel fuel at the Wood River refinery, a separateconstruction permit would be required for the new equipmentand processchanges that would be involvedwith the project. The changesin emissionthat would accompanythe project would be addressedduring the processingofthat application.
Au folluiisn t7. How manyodor complaints were received due to theWood River refinery during the last three years,and what was the natureof t}tem? What evaluationsand equipment improvementshave been carried out in orderto eliminateodor complaints? Have evaluationsbeen performed to eliminateodor complaints in thenew project?
Five odor complaintshave been received by the Illinois EPA in the past three years due to "refinery-type" odors. Three were petroleumodors in the Hartford area. One was a sulfur odor in the SouthRoxana area. One was a pungenttype odor in the Wood River area.
The refinery was granteda constructionpermit in May 2006to replacea ground levelflare with an elevatedflare. The useofan elevatedflare as opposedto a ground level unit will reduceany potentialfor odor associatedwith the operationof thisflare.
Additional odors are not anticipatedto result from this project. One of the principal concernsfor odorsis emissionsof hydrogensulfide (II2S). The control equipmentin placetoday and the proposedcontrols in this project will result in minimal emissionsof HzS. If odors do occur, the Illinois EPA will investigateand take appropriate actionfor eachodor complaintthat it receives.If equipmentis not beingoperated properly, the solutionis obvious. If equipmentis operatedproperly but nuisanceodors occur, further investigationwould be neededto determinewhat shouldbe doneto alter the operationto mitigate or eliminatesuch odors.
18. Whenthe w:ind blows from that directionwhere I live, abouta half mile away,I smellthe cokerwhen it rains. The crudeoil odoris sobad. Is it goingto be worse?
Although there havebeen a handful of complaintsdue to relinery type odors,none havebeen related to the operationof the existingcoking unit. Operation of a second coking unit is not expectedto generateadditional odorsat the refinery.
19. I live aboutthree miles downwind of therefinery and I havehad asthma all my life. I cannotimagine what it wouldbe like to havemore particles in the air. While the project itself will haveemissions of particulatematter, they will be more than offsetby the reductionsin emissionsof particulatematter from existingunits, sothere will be a net decreasein particulatematter emissions.(Refer to the Attachmentsto the permit that addressemissions of particulate matter.
BACT/LAER
20. Canthe Illinois EPA providea listingof the emissionunits that ConocoPhillips purchasedfrom Premcor?
Appendix C of the ConsentDecree contains a list of assetsConocoPhillips purchasedfrom Premcor. This ConsentDecree can be found on the internet at http://www.ena.qov/comoliance/resources/decrees/civiUcaa/conocophillips-cd,pdf.
2r. Whatdoes "lowest achievable emission rate" mean?
The lowestachievable emission rate is the most stringentemission limit derived from either (1) the most stringentemission limitation containedin the implementationplan of any statefor suchclass or categoryofsourcel or (2) the most stringentemission limitation achievedin practiceby suchclass or categoryof source.
22. ConocoPhillipsshould invest up front in bettercontrol technology at therefinery.
ConocoPhillipsis required to upgradeemission control technologyon various units at the refinery pursuant to the ConsentDecree, which requiresupgrades of control equipments on boilersand heaters,the sulfur recoveryplants, and catalytic crackingunits. All units at the refinery must complywith applicablefederal NESHAP standards. For new and modilied units affectedby the proposedproject, in addition to complyingwith federalNSPS standards, ConocoPhillips must implementBest Available Control Technology(BACT) for emissionsof carbon monoxide(CO) and the LowestAchieve Emission Rate for emissionsof volatile organicmaterial (VOM). zJ. If this projectis approved,ConocoPhillips should be required to usethe best available emissioncontrol technology, regardless of the cost. It shouldalso not be ableto do any emissionstrading. ConocoPhillipscan afford to do everythingpossible to reducethe emissionsfrom the refineryafter this projectand it shouldbe requiredto do that.
This project is subjectto New SourceReview for emissionsof VOM and CO. Accordingly,ConocoPhillips must implementthe LowestAchievable Emission Rate (LAER) for VOM emissionsand the BestAvailable Control Technology(BACT) for CO emissions.LAER doesnot considercost of controlsunless the costof maintaininga particular level of control would be so great that a project could not be built or operatedat any locationor reasonableset of circumstances.Cost factors can be consideredin a BACT determination,to the extentallowed by USEPArules and guidance. Cost was not a significantfactor in the determinationsof BACT and LAER madefor the proposedproject.
1A The CO emissionlimit proposedin theapplication as BACT for flaring,0.37 lbs/million Btu, wouldnot be enforceable.There is no practicalmethod to enforcethis limit, which by its natureis an emissionfactor and not a measurement.ConocoPhillips also has not proposedany method to veriff compliancewith this limit. It wouldbe very convenient for ConocoPhillipsto havea BACT limit thatby definitionis met independentof how muchCO a flare emits,with the calculatedemissions always being equal to the limit.
As notedby this comment the CO emissionlimit proposedby ConocoPhillipsas BACT for flaring is a USEPAemission factor and was not intendedto be enforceablein the samemanner as a more traditional emissionlimit. Instead,the proposedCO emissionlimit wasintended to serveas a representationofthe CO emissionsof a properly operatedflare. However,as implied by this comment proper operationof a flare shouldbe direcfly addressedby specifyingthe particular work practicesthat must be implernentedfor the flare, It would be poor regulatory practiceto rely on a emissionlimit to implicitly require proper operationof a flare asspecific practices for proper operationcan readily be set. In addition, setting BACT solelyin terms of an emissionlimit would not act to require practicesto prevent and minimizeflaring,
25. The CO emissionlimit proposedin the applicationby ConocoPhillipsas BACT for flaring,0.37 lbs/million Btu (proposedon page7-9 ofthe application)was correctly rejectedby the Illinois EPA. SettingBACT asthis emissionlimit wouldnot serveto reduceCO emissionsby reducingthe amountof flaringthat occurs.While it doesnot appearthat the Illinois EPA hasapplied this limit asBACT, it is whatConocoPhillips proposed.In casethe Illinois EPA is still consideringthis limit orhas somehowincluded it in its calculationsunderlying other limits in the draftpermit, the Illinois EPA should rejectsuch a notion. Theproposed limit is achrallya USEPAemission factor for CO emissionsexpressed in termsof the fuel valueof the wastegas that is flared. This factor hasnothing to do with BACT. Sucha limit wouldallow unlimitedhours of routine flaringat this rate,and by definitionis not thebest available technology but is insteadan averageor typicalCO emissionfactor for flaring.
The issuedpermit doesnot set BACT for CO in terms of this emissionrate proposed by ConocoPhillips.BACT for CO is setin terms of work practicesto minimize CO emissions,consistent with the generalapproach taken in the draft permit. These work practiceshave been further developedas a result of further review by the Illinois EPA in responseto other public comments.
26. ProjectVOM flaring emissionsdo not meetLAER requirements.The ProjectSummary for theproposed project prepared by thelllinois EPA incorrectlyimplies that the main sourceof VOM from flaringis thepilot flame,so that this shouldbe the mainfocus of
10 the LAER evaluationand no othersource of flareemissions need be evaluatedfor LAER.T However,the largest contributor to VOM emissionsfrom flaringis thewaste gasesthat are flared, since a percentageof ttreVOM is not destroyedand is emitted. Flaresare typically considered to havea VOM dbstructionefficiency of 98%with good combustionconditions, with 2% of VOM routedto the flarebeing emitted. This is a significantpercentage given the nature and magnitude offlaring thatcan occur at a refinery. Thereforethe statementabove that "since flares themselves are VOM control devices,no additionalconhol of theVOM thatis generatedthrough the combustion of pilot fuel gasis necessary"is doublyinaccurate. LAER requiresmeasures to prevent flaring eventsentirely, ratherthan allowing flaring, which still emitsVOM to the atmosphere.
The statementin the Project Summaryaddressed by this commentwas not intended to havethe further meaningclaimed by this comment. Indeed,the statementis fully consistentwith the further discussionin the comment,as it addresseswaste gases, rather than the pilot flame, asthe principal contributor to CO and VOM emissions from flaring and the appropriatefocus of a BACT and LAER evaluationfor flaring.
27. The draftpermit would set"blended limits" on emissionsfrom new flaresand other units sothat separateBACT andLAER limits for flaringwould not be set. In particular, Condition4.7.6 of thedraft permit, which shouldaddress only flaring,would set emissionlimits for theDelayed Coker Unit Flare(DCUF) that may alsoaddress other operationsrelated to thenew coker. Thelimits thatare set fbr thenew HydrogenPlant (HP2)would address the Hydrogen Plant Heater (HP2 H-1), the associatedCooling WaterTower (CWT 24) and,fugitive emissions, as well asthe flare (HP2F). The scope ' of theselimits obscuresexactly how muchemissions of CO andVOM would beallowed for flaringwith BACT andLAER. Theapplication must provide a clearand complete projectdescription and the permit must set limits for the individualemission units to ensurethat each unit meetsBACT andLAER.
The permit doesnot set"blended" limits for the permitted annualemissions of the flare for the newDelayed Coker Unit and this flare's permitted emissionsof CO and VOM are setby Condition 4.7.6.
While blendedlimits are setfor the permitted annualemissions of the flare for the new HydrogenPlant, the flare is permitted to emit up to the limits in Condition 4.7.6. However,separate, lower limits are alsoset in Condition 4.1.6for the process heaterfor the plant, HeaterHP2 H-1. Condition 4.6.6sets a limit on the VOM emissionsof CoolingWater Tower 24, allowingonly minimal VOM emissions.The emissionsof the flare by itself are expectedto be no more than the differencein theselimits. For example,the expectedannual emissions of CO wouldbe no more
' *The RBLC databasestates for pastpemits thatsince flares are themselves VOM controldevices, no additional controlof theVOM from thecombustion ofpilot fuel gasis necessary.Therefore, no additionalVOM control technologiesaxe necessaxy for thetwo newflares." Project Summary, page l9-
11 than 36.2tons.2 While annualCO emissionscould be greater(but in no casemore than 147.9tons as limited by Condition 4.7.6),this could only occur with circumstancesthat actedto lower CO emissionsof the processheater. This approachhas beentaken for the new HydrogenPlant giventhe nature and designof the unit, which generatesa low VOM contenf byproduct wastegas stream that is normally usedas fuel in the unit itself.
28. TheBACT/LAER evaluationfor flaring did not evaluatethe most stringent technologies available,which prevent entire flaring eventsand achieve the maximum degree ofCO andVOM emissionreductions. ln this regard,the applicationincorrectly indicates t.hat thereare no "technicallyfeasible CO conkol options"for theflares. (See Sections 7.3 of the application.)Other refineries have equipment and practices that minimize flaring emissionsby minimizingflaring. Suchapproaches were not evaluatedfor theproject. Preventingflaring eventscompletely or minimizingthe quantitiesof gasesflared is the bestmethod to preventboth VOM andCO emissionsand all otherflaring emissions (includingcarbon dioxide (CO)). Suchmethods were not evaluatedin the application for theproposed project.
The BACT/LAER evaluationsfor the proposedproject for flaring was madebased on the featuresin the designof the new DelayedCoker Unit that will act to minimize flaring and in the contextof existingrequirements that addressflaring at the Wood River refinery. In particular, the ConsentDecree also includes requirements relatedto hydrocarbonflaring eventsoas is relevantto emissionsofCO and VOM from flaring. The causeof significanthydrocarbon flaring incidentsmust be investigated,including performanceof root causeanalyses, steps must be taken to correct the conditionsthat causesuch incidents, and the number and extentofsuch incidentsmust be minimized. Iletailed reporting is alsorequired for theseincidents. Provisionshave been included in the issuedpermit that make similar requirement applicablefor the new flares that would be installedwith the proposedproject.
29. Additionalevaluation ofBACT andLAER is neededfor ventingofpressure relief devicesto gasrecovery systems (while addingsufficient compressor capacity so that this doesnot causeadditional flaring).
Pressurerelief devicesare addressedby the provisionsfor flaring, asthey are mechanismsthrough which wastegases are ventedfrom processunits at relineries for recoveryor flaring.
30. The annualVOM emissionrate from flaring achievedby Shell,Martinez, should be used asthe basis to seta LAER limit for theproposed project. This resultsin a LAER limit for theWood River refinery of 5.9 tons/year,given that the Wood River refineryis about four timeslarger than theMaftinez refinery.' Shellstates in its FlareMinimization Plan thatit hasbeen able to achievelow flaring emissionsincluding emergencies in a safe
' 147.9tons (overall limit on CO emissions)- I1L7 tons(limit on heaterCO emissions): 36.2tons (remainder availablefor flare). 3 (385,000barrels per day (bpd)projected for ConocoPhillips)/(98,500bpd ShellMartinez) x 1.5hy: 5.9tpy
t2 manner.Nothing in theBAAQMD flarerule with its requirementfor a Flare MinimizationPlan (FMP) causesany compromisein saferefinery operations, which allow flaring in a true emergency.However, the FMP doesrequire rigorous monitoring, reporting,planning, and evaluation of flare events,and equipment improvements so that methodsand equipment are in placeto preventemergencies and minimize flaring. These methodsmake the refinery saferby minimizing anergencyshutdowns and reducing repeatedfl aringemissions.
The information cited in this commentdoes not support settinga LAER requirementfor the Wood River refinery that is expressedin terms of annual emissions.As notedby the comment,the relevantBAAQMD regulationsdo not prohibit flaring, asflaring is an appropriateaction to addressdisposal ofprocess gasin emergencies.Likewise, Flare Minimization Plan preparedby ShellMartinez indieatesthat noneofthe proceduresthat are part ofthat plan would restrict access to the flareswhen flaring is viewedas necessaryfor personnelor equipmentsafety, which further necessitatesflaring by operatorswithout hesitationwhen warranted for safety. Settinga limit in terms of annualemissions of flaringoin the manner proposedby this comment,would potentiallyact to prohibit flaring when it was appropriate, It would set an absolute,enforceable limit on the extentof flaring that could occur at the refinery independentofthe actual circumstancesat the refinery in a particular year.
_lt- Additionalevaluation of LAER is requiredfor firgitiveemissions for therefinery as a wholeto providebaseline and future conditions with increasedcapacity, which will likely leadto increasesin fugitiveemissions. Information on frequencyof inspectionof valves, flanges,pumps, and compressors for leaksand information on anypast violations at the refrneryinvolving these operations should be provided. Lists shouldbe provided includingthe numbers ofall typesofvalves, flanges, pumps, and compressor seals.
LAER for VOM emissionsdue to componentleaks is appropriatelyaddressed by relianceupon and referenceto the provisionsofthe NESHAP for Petroleum Refineriesthat addresscomponents leaks. The NESHAP providesa comprehensive approachto this sourceof emissionsfor very effectivecontrol of emissions,It requiresimplementation of a Leak DetectionAnd Repair (LDAR) program to identify and repair leaking componentsin a timely manner. As certain typesof serviceand applicationsare more likely to havecomponents that experience frequent leaksand require repairs antl follow-up monitoring if conventionaltypes of fittings are used,the NESHAP leadsto useof "advancedfittings," as discussedin this comment,in thcseapplications. This is becauseofthe stringentdefinition ofthe NESHAP for a leaking component.At the sametime, advancedfittings are not required in circumstancesin which they might actuallylead to increasedemissions, as advancedlitting are not as reliableunder certain typesand conditionsof service.
The ConsentDecree addresses VOM emissionfrom existingcomponents at the refinery, asit requiresenhancements to the LDAR Program for existing components.These enhancements should act to significantlyreduce the VOM
IJ emissionsfrom leaking componentsat the existingprocess units at the refinery.
TablesC-3a and C-3b ofthe applicationprovide a listing ofthe various typesof componentsto be installed,type of servicefor eachcomponents, quantity ofeach componenttype, and the area (processunit) in which the componentswould be installed.
.JL. Additionalevaluation of LAER is requiredfor VOM emissionsfrom wastewater treatmenttanks and ponds, including evaluation ofupstream controls to prevent contaminationof wastewaterthat leadsto emissionsofhydrocarbons and wastewater containinghydrocarbons and other pollutants and enclosure of anyopen wastewater systems,and data on concentrationof hydrocarbons(lighter products and heavy diesel- range)and other contaminantsin the wastewater.
LAER is appropriatelyset for wastewatertreatment plant operations, Pollution preventiontechniques are well establishedto prevent avoidablecontamination of wastewater.As suchcontamination does occur and is inevitablegive the nature of petroleumrefining. The initial focusfor control of emissionsof VOM and other volatile pollutantsfrom wastewateris containingsuch materials with the wastewater.This enablesemissions of thesematerials to be controlledin the initial treatmentunits, which are designedto separatevolatile material from the wastewater,rather than beinglost directly to the atmospherefrom the drain system aswastewater is beingtransported to enclosedtreatment units. The VOM emissions from the initial treatmentunits are then readily controlledas the emissionsare combustible.The VOM emissionsgenerated as a byproduct of subsequent treatment units are alsoreadily controlledas units are enclosedand the bulk ofthe gasstream is methaneproduced from anaeraobicwastewater treatment.
Data on the presenceof hydrocarbonsin the wastewaterwould not be useful,as it would not directly correlatewith the potentialVOM emissionsfrom treatment plant operations.In particular,the presenceofproduct materialsshould be expectedto reduceVOM emissionsas VOM emissionswould dissolvein suchcompounds and then be readily removedin the oil water separators.
33. LAER for VOM emissionsfor thenew storagetanks should require that tanks be equippedwith unslottedguidepoles, rather than slotted guidepoles. Unslotted guidepoles shouldalso be installedon existingstorage tanks. This is becauseslotted guidepoles havea significantconhibution to the VOM emissionsofa floatingrooftank.
Slottedguideposts that are closedat the top and equippedwith sleevesand wipers, aswould be usedfor the new tanks, do not contribute significanflyto the VOM emissionsfrom a floating rooftank. The useof unslottedguideposts and appropriatelyequipped slotted guideposts, cannot be distinguishedfor purposesof control of VOM emissions,based on USEPAemissions estimation methodology for tanks. In part, this is becauseslotted guideposts eliminate the needfor separate fittings on a tank for samplingand level measurements,which alsocontribute to
t4 VOM emissions.As a result, the net effectof useof slottedguideposts is not significant.
34. Additionalevaluation of LAER is requiredfor existingstorage tanks at therefinery, whichwill haveincreased throughput due to theproject, which shouldbe upgradedto BACT. The applicationshould have listed all storagetanks for anevaluation of baseline conditionsincluding tank type, product,throughput, information on tank fittings and controls,past violations, tank degassingprocedures, tank cleaningprocedures, etc.
The existingtanks for which LAER requirementshave not beenset are not subject to LA-ERbecause they are not beingphysically modified and will not experiencea changein the methodof operation. The applicationdoes addresses increases in VOM emissionsat existingtanks that will potentiallyoccur due to increasesin the throughputofthese tanks as a resultofthe project.
AIR QUALITY A}{ALYSIS AND EMISSION OFF'SETS
35. Hasthere been an evaluationby theIllinois EPA of cumulativeimpacts of this projectin conjunctionwith the othernearby sources such as US Steelin CraniteCity?
This project will potentia\ result in an increasein emissionsof CO that would qualify as significantunder the federalrules for Preventionof Significant Deterioration(PSD). The air quality impact analysisperformed for CO emissions for the proposedproject showsthat air quality for CO will not be significanfly impactedby the project. Modeling of other PSDpollutants was not performed or required for the proposedproject asemissions ofthese other PSD pollutantswill either decreaseor not increasesignificantly with the project ascompared to the applicablePSD significantemission rate. Accordingly,air quality for thesePSD pollutantswill improve or not changesignificantly.
The role of the Wood River refinery in regionalair quality for ozoneand PMz.s,for which the Greater St. Louis areais alsocurrently nonattainment,will be addressed by the Illinois EPA and the Missouri Departmentof Natural Resources.This will occur tluring the air quality analysisthat will be part ofthe developmentofthe plansto bring the areainto attainmentwith the National Ambient Air Qualiff Standardsfor ozoneand PM" ..
36. Throughemission offsets, clean air in St.Louis is beingtraded for dirty air in Roxana.
The offsetsfor emissionsof VOM required for the proposedproiect do not trade cleanair in onelocation for dirty air in another,as both St, Louis and Roxanaare locatedin the Greater St. Louis area. This is becausethe ozonein the ambient air is not emittedfrom sourcesbut is formed in the atmospherefrom photochemical reactionsofprecursor compounds, i.e., VOM andNO*, in the presenceof sunlight. High ambientlevels of ozonethat exceedthe National Ambient Air Quality Standardmay occur many milesdownwind from a collectionof sourcesat which
l5 precursor compoundsare emitted. Long range transport of precursorsis also important for ozoneair quality as transport affectsthe levelsofprecursors in the air t enteringurban areas. Given thesecircumstances, the Greater St. Louis areais a singlenonattainment area, with an overall problem with nonattainmentofthe ozone air quality standard. Given the nature of the problem,it is not possibleto distinguishor differentiatethe effectson ozoneair quality from emissionsofVOM in Roxanafrom thosein St. Louis.
Incidentally,the plannedoffsets also satisfy applicable regulatory requirements. Illinois' rules governingmajor modificationsin nonattainmentareas, which reflect the provisionsof the CleanAir Act, require emissionsoffsets for VOM to be obtainedfrom within the samenonattainment area as a proposedproject. The emissionoffsets planned for this project clearly meetthis requirement.
Jt. What is thename of the sourceproviding the VOM emissionoffsets for this project?
The offsetswill comefrom JW Aluminum Company,which is locatedjust southwest of downtownSt. Louis,
38. Whatis the statusof thePremcor Consent Decree and how is it manasedwith the ConsentDecree for ConocoPhillips?
The ConsentDecree previously signed by Premcor (99-87-GPM)has effectively been incorporatedinto the new ConsentDecree with ConocoPhillips(H-05-0258) as is shownby the provisionsin the new decreeaddressing the Distilling West FCC Unit.
39. Creditsfor somethingthat was required under a consentdecree should not be available for usein a nettingor offsettransaction.
The relevantprovision of the ConsentDecree that addressesthe ability to utilize creditsfor the proposedproject is Paragraph262(d). This paragraph providesthat if ConocoPhillipshas a singleproject that involvesinstallation of ConsentDecree controlsas well as other constructionthat would occur at the sametime and be permitted as a singleproject, ConocoPhillipscan utilize the emissionsdecreases from the installationof conttols required by the ConsentDecree for that project.
40. How is eachunit purchasedfrom Premcortaken into accountin thenetting analysis?
The permit for the project includesinformation showinghow eachunit is or is not usedin the netting exercisefor fhe proposedproject (Refer to the permit, Table III in Attachments2 through 8.)
ANALYSIS OF ALTERNATIVES
41. Pollution preventionmethods and project alternativesto coking, which would avoid the various impacts from coking, shouldhave beenpublicly evaluated.
t6 There are not "pollution preventionmethods" available to ConocoPhillipsthat would avoid the needfor coking. While the heavystream of material that will be cokedcould be sold as asphalt,the marketsfor asphaltare both limited and seasonal.If this streamwere sold as asphalt,this streamof material alsowould not be availableto be refined into gasolineand dieselfuel, which are the productsof the refinery for which consumptionis increasing.
Coking is a modern crude oil processingtechnology that is routinely usedat refineriesfor the purposesand in the circumstancesin which ConocoPhillipswould useit. The reasonswhy this technologyis usedin particular situationrelate to well- recognizedfactors that affectdecisions by any refinery with respectto process equipment. Theseinclude availability and costof crude oil for the refinery givenits location,the amountsof different productsthat consumedby local markets,the value of different products,the type of processingthat is neededto produce different productsgiven the nature ofthe crude oil supply,the reliability, yield, energyconsumption and other demandsof different processes,the capacityand capability of existingequipment at a relinery, the ability to meetor supplementthe demandfor certain productsby other means,competition from other companiesto meetthe demand,etc. Given the commonuse of coking processesto crack heavy petroleumstreams distilled from crude oil or bitumen,it is not necessaryfor ConocoPhillipsto revealthe specificevaluations and businessdecision-making that led up to the proposedproject. t11 Why shouldn'tthe refinery use a hydrocrackerin conjunctionwith thedelayed coker?
The primary conversionprocesses commonly evaluated are non-catalytic(e.g., delayedcoking) and catalytic(e.g., hydrocracking). A refinery must generally determinewhich processis more advantageousbased on criteria suchas the compositionof crude oil supplythat is availablefor the refinery, operatingand maintenanceneeds, frequency of start-ups,and marketsfor different products. Becausethe Wood River refinery is an existingrefineryo ConocoPhillips must also considerwhich processwill better handlethe variousproducts and intermediates from either the catalyticor non-catalyticprocess considering the existingprocessing equipmentat the refinery. Of particular relevanceis the fact that this refinery currently operatesa delayedcoker, which meansthat the proposedsecond delayed coker could be installedto be directly integratedwith the existingdownstream processunits. Considerableimprovements over the yearshave also been made to the safetyof delayedcokers through the automaticunheading of cokedrums. The Illinois EPA hasdetermined that there is no reasonto believethat the proposed coker is any lesssophisticated or "modern" giventhe current configurationofthe refinery and the typesof crude slateswhich would be processedat the refinery. Also relevantfor this choiceis the energybalance and productsof the refinery. The hydrocrackingprocess is dependentupon the useof hydrogen,where as cokin! crackshydrocarbons without needfor hydrogen. Coking doesproduce a solid by- product for which there must be a suitablemarket.
t7 43. If therewere a cleanerfeedstock available from Canada,it might lower emissionsand requireless water and wastewater and cleaning ofpipelines and less processing at the WoodRiver refinery. It seemslike a cleanerfeedstock might reduce the environmental impact of the entireprocess from the start of the pipeline to the activities at the Wood Riverrefinery.
The transportationprocess for this new supply of crude oil versustransport of partially refined productswill not result in any additional energyimpacts or cleaning. When the material is receivedat the refinery, all of the non-petroleum materialswill be processedin the refinery just as existingcrude is processed.For example,water will be extractedin the process,and it will be handledthrough the wastewatertreatment plant consistentwith typical refinery practices.
44. At theoil sandsdeposit in Alberta,Canada, state-of-the-art refining technology is being usedto processsome of bitumen,with a high-percentageconversion to light crudecalled syntheticcrude oil, whichis put into light products.In contrast,delayed coking is an oldertechnology, which has been the subjectofOSHA andUSEPA safety wamings. Why is ConocoPhillipsinstalling a delayedcoker unit whenit coulduse modem tecbnology,like in Canada?Also, why couldn'tthe crudeoil undergohydrocracking in Canadabefore it is shipped?My understandingis thatit couldand the Wood River refinerywould have more usable product and less coke and it wouldhave less wastewater becausetoo cut all thatcoke out anduse voluminous amounts of water,which would help with thecone ofdepression and help with the discharges.
The refining of bitumen that takesplace in Canadais performed becausethe bitumen recoveredfrom oil sandsis very viscousand cannotbe directly shippedby conventionalpipelines. It must generallyeither be blendedor diluted with lighter petroleumproducts or processedor "upgraded," with the resulting material is generallyreferred to as"synthetic crude oil." This upgradingis performed using standardrefining processes,including delayedcoking followedby hydrocracking,as will alsobe performedwith modern equipmentat the Wood River refinery. The extentof processingthat occursin Canadais dictatedby the needto producea syntheticcrude oil that is sufficientlyliquid that is can be shippedby pipeline.It is more economicalfor existingrefineries, which are closerto markets and have facilitiesto make a rangeoffinal products,to then completethe processingofthe syntheticcrude oil, rather than duplicatethose facilities in Canada. Other factors alsoact to influencethe extentof initial processingofthe bitumen that is performed in Canada,e,g., the availability of natural gasto make the hydrogenneeded for hydrocrackingand the absenceof local markets for petroleumcoke.
Cana cleanergrade of crudeoil be transportedfrom Canadato the WoodRiver Refinery by usingupgraded technology in Canada?
Productionof a cleanergrade of crude oil in Canadawould necessarilyentail "full refining" of the crude oil in Canada, While it would be possibleto constructa new
18 refinery in Canadaat the sourceofthe crude oil, it is more costeffective and efficientto pipe crude oil to existingrefineries that alreadyhave the facilitiesto processmaterial to supplythe demandsand environmentalspecifications for local markets.
40, Otherrefineries that process healy crudehave or haveplans to build a facility to gasify the crudeto makehydrogen and elechicity for the refinery. Ftom the perspectiveof nationalenergy security, wouldn't it be betterthan the use of thenatural gas, as proposed, andwouldnt thatcreate more local iobsand wouldn't that be a highervalue use ofcoke?
The Illinois EPA is not awareof any refineriesthat havefacilities to gasify petroleumcoke to direetly producehydrogen or that plan to constructsuch facilities. Certain refineriesdo havefacilities to gasifypetroleum coke to produce fuel gas,which can then be usedas fuel in processunits or in a cogenerationfacility or usedas a feedstockto producehydrogen. A hydrogenplant is being developedto usepitch as a feedstock However,steam methane reforming, asused at the Wood River refinery, usingfuel gasor natural gasas a feedstock,is commonlyused to producehyd rogen at refineries.
Most of the fuel combustedat the Wood River refinery is not natural gasas suggestedby this cornment.Rather, the primary fuel at the refinery is fuel gasthat is a byproduct from certain relining processes.The gasilicationof petroleumcoke would greatly increasethe magnitude,duration and costof expandingthe Wood River refinery. It is alsounclear what operationalbenefit would be derivedfrom suchelTort as the refinery will producesufficient refinery fuel gasand hydrogenfor its operationswithout a gasificationunit. Operationcf a cokegasification unit would alsoadd anotherelement of complexityto the operationand managementof the refinery. As gasificationof petroleumcoke is believedgenerally desirableo it is certainly possiblefor anothercompany to pursue developmentof a new source specificallyfor that purpose,relying on ConocoPhillipsancl other refineriesto provide its feedstock.
47. Someof thenegative impacts ofthe useofpetroleum coke as fuel in a boiler areits high sulfurcontent, which potentially contributes to higheremissions of sulfurdioxide (SOz) andsulfuric acid mist from theboiler, the combustioncharacteristics of thecoke, which potentiallyincreases NO" emissions,and the healy metalsin theash.*
Useofpetroleum cokeas a fuel in a boiler generallyposes emissions issues that are similar to thosethat are posedby useof high-sulfur coalin the boiler. That is, the boiler must be equippedwith appropriatecontrol systemsfor emissionsof PM, NO* and SO2,as neededto comply$,ith applicableemissions stanalarals that apply to the boiler, While the trace levelsof certain metalsin petroleumcoke, such as vanadium and nickel, are higher than in coal,emissions of thesemetals are controlledalong
4 Challengesqnd Economicsof LlsingPetroleum Cokefor Power Generation,World Energy Commission, http://www.worldenergy.org/wec-geis/publications/defaulVtech-papers/lTth,congress/12 26.asp
l9 with the PM and they end up in the ash. On the other hand, sincethe mercury contentofpetroleum cokeis much lower than that of coal,use ofpetroleum coke doesnot posethe sameconcerns for mercury impact asthe useof coal.
48. The analysisof alternativesto theproposed project should have considered the broader impactson theUnited States of usingcrude oil from Canada.At a minimum,these impactsinclude the overallimpacts additional energy use, additional hydrogen use, additionalflaring, increases in refineryaccidents, additional use ofcoke asfuel in power plants,impacts ofnew pipelinesand pipeline accidents, and potential on impactson regionalair qualitydue to changesin vehiclefuels. Theseimpacts and long-term implicationsare severe when considering added emissions criteria pollutants, toxic pollutantsand greenhouse gases, as well asdestmction ofland andwater resources, and impactson people,plants, and wildlife.
It is beyondthe scopeofthe analysisof alternativesfor the proposedproject to considerthe impactson the United Statesfrom using Canadiancrude oil, as recommendedby this project. The United Statesobtains crude oil from various oil fields,both domesticand foreign,with a variety of impactsassociated with the production and transportationof that crude oil. While purchaseofforeign crude oil reducesthe environmentsimpacts on the United Statesfrom oil production,it has economicimpacts on the United Statesand the world economy.Use of domestic crude oil reducesthose economic impacts but hasenvironrnental impacts. In some cases,those impacts can be severe.For example,the Exxon Valdez oil spill involved transportationof crude oil by tanker from Alaska.
GLOBALWARMING
49. Condition2.5 in the draftpermit states that the Illinois EPA hasbroadly considered altemativesto theproposed project, as required by 35 IAC 203.306.However, the Illinois EPA waspremature in findingthat it hasconsidered altematives to the project. Thehigh energyuse ofthe projectand resultant emissions of greenhousegases should havebeen considered pursuant to 35 IAC 203.306,as a majorenvironmental and social costofthe project. Altemativesto theproject that would avoid severe project energy use andemissions of greenhousegases should be evaluated,as required by 35 IAC 203.306. At a minimum,this costof theseimpacts should be identifiedand evaluated, so that altemativescan be seriouslyevaluated.
Alternativesto the proposedproject were reasonablyanalyzed. While there are theoreticallyalternatives to this project that would avoid the proposedproject, these alternativescan be readily dismissed.For example,the existingrnotor vehiclefleet could be replacedwith electricalvehicles, with electricifysupplied by wind-based power plants. Not only is this not somethingthat ConocoPhillipswould undertake, but it is not somethingthat could be undertakenas an alternativeto the proposed project as it respondsto needsfor conventionalfuels in the immediatefuture.
On a more realistic level,the continuing and increaseddemand for fuels in the
20 markets servedby the Wood River refinery could potentiallybe met by relineries other than the Wood River refinery. However,importation of fuel to the Midwest from other locationswould not eliminatethe emissionsfrom somesimilar projecf as suchproject would still occur elsewhereto meetthe public demandfor fuels and changesin the global suppliesof crude oil. As emissionsof criteria pollutantsaffect air quality on a regionalscale and greenhousegases are ofconcern on a global scale, relocationof the project would be of uncertainbenefits environmentally. Moreover, importation of fuelswould certainly havesignificant impacts on residentsof the greater St. Louis area as it would affectthe costand availability of fuelsin the area. It could alsohave negative environmental effects as it would affectthe availability of reformulatedgasoline for the area,which the Wood River refinery producesas the local refinery servingthe area. In summary,the proposedproject is a reasonable proposalby ConocoPhillipsfor the Wood River relinery to continuein its historic role in supplyingfuels to the GreaterSt. Louis area and the Midwest. While the refinery hasimpacts on the environment,those impacts are significantlyoutweighed by the benefitscurrently being providedfor societyofthe fuelsthat the refinery produces.
50. ln 2006,Govemor Blagojevich announced a climatechange initiative by the Stateof Illinois to addressemissions ofgreenhouse gases, which will build on Illinois' role asa nationalleader in protectingpublic health and the environment.This initiativemarks the beginningofserious efforts by Illinois to addressglobal climate change and builds on stepsthat Illinois is alreadytaking to loweremissions of greenhousegases, such as providingincentives for energyefficiency and encouraging the use ofwind powerand biofuels.
Governor Blagojevichhas instructed the Illinois Climate ChangeAdvisory Group, which he hasconvened for this initiative, to evaluatea full rangeof policiesand strategiesto reduceIllinois' emissionsof greenhousegases. Accordingly, the Advisory Group is focusednot only on the facilitiesthat supplyfuel and energy,but alsoon the facilitiesand peopleof lllinois who usethat fuel and energy. This is critical as significantreductions in emissionsof greenhousegases requires comprehensiveactions to reduceenergy consumption, including significant improvementsin the energyefficiency of transportation,heating, cooling, and lighting, machineryand appliances,etc. While facilitiesthat producefuels and energy,e.g., petroleum refineries, can 4!3!q makeimprovements to reducethe energyconsumed in their operations,these reductions are not sufficientto roll back emissionsof greenhousegases. As relatedto emissionsof greenhousegases from oocrudeoil," a reductionin the usageof gasolineand other petroleumproducts usage is needed,sThus the focusof efforts in Illinois to reduceemissions of greenhouse gasesfrom useof petroleum-basedfuels must be to actually reducethe usageofsuch fuels. This will alsoprovide other benefitssuch as stabilizingfuel prices, maintaining and improving air quality, and reducingtraflic congestion.The
'Whilerenewablefuels,i.e.,ethanolandbiodiesel,canbesubstitutedforsomefuel,theextentofsuchsubstitution thatis feasibleis relativelyminor in termsofthe ovemllemissions ofgreenhouse gases attdbutable to useof petroleum-basedfuels,
2l activitiesofthe refineriesthat supply fuels are a secondaryconsideration in these efforts, both due to the lessermagnitude oftheir emissionsand their role in meeting [linois's current needsand demandsfor fuels.
51. TheU.S- Global Change Research Program published a reporton impactsof climate changein theMidwest," which findsthat, higher summer temperatures and resultant increasedair pollutionin the Midwestwill resultfrom climatechange. This is because hottersummers could act to increasethe formation of groundJevelozone, which is formedthrough reactions of precursorcompounds energized by sunlighton hot days. As major urban areasin the Midwest are cuffently nonattainmentfor ozone,climate change is making it more difficult to attain andmaintain compliancewith the ozoneair quality standards.The report also found that heat-related deaths in theregion due to climate changewill increase,and the report as a wholefound many other severe impacts due to climatechange. The public is relyingon the Illinois EPA to seriouslyevaluate altemativesto theproposed project that will not only protectpublic health from traditionalair pollutants,but alsofrom greenhousegases, whose effect is to exacerbate air pollutionand threats to publichealth.
As observedby this comrnent,global warming potentiallyhas myriad negative impactson human health and welfare and the environment,both directly and indirectly, However,it is alsoobvious that the challengeof global warming will require a comprehensiveregulatory approachin the United States,which is ultimately imposedby Congresson a national level. Until specificregulations are put into placeby the appropriate stateor national authorities,ad-hoc actions to compelindividual action on global warming through conventionalenvironmental permitting programs are capricious, Even if suchactions were taken, they would probably provide only illusory benefits,as they would be limited in their scopeto new projects. They would not reach or affect existingsources, which contribute the majority of emissionsof concern. Suchactions might alsohave a stifling effect on the continuingdevelopment and deploymentof new technologyto improve energy elficiencyand reduceemissions of greenhousegases, as suchactions would stifle innovation or discouragecapital investment.
52. The applicatio_nfor theproposed project does not containinformation for emissionsof COz,methane' and other greenhouse gases from thenew aadmodifred heaters that are paft of theproject, which couldbe readilycalculated by ConocoPhillips.The analysisof altemativesto theproject should have reviewed the environmentaland social impacts of emissionsof greenhousegases, which requiresa quantificationofthese emissions, in orderto demonstratethat the benefits of theproject will outweighits environmentaland socialimpacts, as required to complywith Illinois regulations.A full reviewofproject
6 Climate Charge Impacts on the United States,The Potential Consequencesof Climate Variability and Change, Overview: Midwest, by the National AssessmentSynthesis Team, US Clobal ChangeResearch Program, 2000, http://www.usgcrp.gov/usgcrp/Library/nationalassessmenVTMw.pd{,(The U.S. Global ChangeResearch Program (USGCRP) is a govemmentresearch program codified by Congressin the Global ChangeResearch Act of 1990.) Full webpage: http://wr,r"w.usgcrp.gov/usgcrp/Library/nationalassessment/overviewmidwest.htm ' Mary emissionspoints in the refinery emit methane,which is a potent greenhousegas, 20 times strongerthan CO2,and a major componentofthe fuel gas used at refineries. Illinois' definition ofVOM excludesmethane.
22 altemativesshould have also included prevention and.ior mitigation of emissionsof greenhousegases. Estimates of CO2emissions were provided by ConocoPhillipsfor anotherrecent proposal to expandits refineryin RodeoCalifomia.o It showedthat the increasein emissionsof greenhousegases would be largerthan many of the decreasesin emissionsfrom Califomia'sEarly Action measure,effectively wiping out decreasesmade in othersectors. Estimating emissions of greenhousegases from theproposed project just makesgood sense since the project will setrefinery practice and the environmental impactsofthe refineryfor decades.
The important greenhousegas emitted from processingof crude oil and useof petroleumrelineries is COz. This is becauseCO2 is the product of combustionwhen carbon,which makesup the bulk of crude oil, is burned. This is different from methaneand other greenhousegases, which are pollutantsin the more traditional sense,as they are contaminantsand processesmay be manipulatedor controlledto reducethe formation of thesematerials. For example,the trace levelsof emissions of methanethat accompanycombustion of any fossilfuel can be minimizedby good combustionpractices. In contrast,COz is the unavoidableproduct of combustionof carbon,as is desirableas it representscomplete combustion of that carbonto CO2, rather than CO.
As alreadydiscussedo use of petroleum-basedfuels directly leadsto emissionsof greenhousegases. The magnitudeof this contribution is large,with activitiesrelated to useofpetroleum products currently contributing about 45 percentofthe COz emissionsof the United States,As observedby this comment,emissions of COz can be readily calculatedfrom information on the type and amountoffuel that is being burned, Emissionsof CO2associated with useof crude oil can be roughly estimated usinga factorof1000 pounds of CO2per ton of crudeoil consumed.Accordingly, as this project involvesa nominal increasein the annualcapacity of the Wood River refinery ofabout 27 million barrels, the project potentiallyinvolves handling crude oil that could annually contribute as much as about 12.5million metric tons of CO: emissionsto the atmosphere.'As the majorityof theseemissions would occur when gasoline,diesel and other petroleumproducts produced by the refinery are usedothe split betweenconsumption/emissions at the refinery and eonsumption/emissionsof the usersof fuelsis ofuncertain significance.Reductions in theseemissions will require improvementsin energyefficiency by the usersas fuelsso that lessfuel is consumedon a regional,national and internationallevel.
" ConocoPhillipsis pursuingpermit for a majorexpansion at its refineryin RodeoCalifornia. For thatproject, ConocoPhillipsprovided an estimateofthe CO2emissions increases, about 1.25 million metrictons per year. This is a largeincrease, as it is morethan I 0/oofthe comprehensivesinventory for emissionsofgreenhouse gases prepared by theBAAQMD for theentire Bay Area,which addresses emissions from industrialsources, cars, trucks, ships, building heating,etc. The proposedproject at the Wood River refinery representsa much larger refinery and expansion(up to 385,000bpd, compared to theRodeo 76,000 bpd refinery) and involves heavy cnrde oil, which requiresmore processing than lighter crude oi1- CO2 emissions will be muchhigher for theproposed project than for the ConocoPhillipsRodeo refinery, which are already extremely large. ' While 1?.5million metrictons may see like a largenumber, global emissions of CO2are measured in termsof billionsof metrictons Der vear.
.!,) 53. ConocoPhillipshas publicly announced plans to reduceemissions ofgreenhouse gases. In 2006,ConocoPhillips became the first majorUS oil companyto join the US Climate Action Partnership.James Mulva, ConocoPhillips' chairman and chief executivehas beenreported as saying that "Voluntaryprograms are not goingto meetthe challengeof climatechange," . . . "The longerwe wait - two or five yearsor morefrom now - it won't be mitigation,it will be adaptation."r0Unfortunately, the proposed project is movingin the oppositedirection, with moreenergy-intensive processing of very heavyCanadian crudeoi1.
In actual factoConocoPhillips went on record supportingmandatory, national regulationsaddressing greenhouse gas emissions. This is consistentwith its participation in the US Climate Action Partnership,which is a diversegroup of businessesand environmentalleaders that havecome together to call for mandatory actionon climatechange, endorsing a comprehensiveapproach involving phased targetsfor reductionof emissionsof CO2accompanied by a range of policy approaches,ConocoPhillips should be praisedfor its endorsementof regulatory actionto addressglobal climatechange, especially when certain other companies would prefer to ignore global warming. However,ConocoPhillips corporate positionon climatechange is not inconsistentwith the current project, which would meeta needfor fuel in the immediatefuture using an existingrefinery.
Globalwaming is a scientificfact that is now acceptedworldwide. The UnitedStates is far behindEurope in whatit hasdone with altemativeenergy and energy conservation andConocoPhillips is not helping. If ConocoPhillipswants to expandand get more energy,why doesn'tit investin somenew altemative energy methods instead of investingin continueduse of crudeoil to producefuels. Insteadofbuilding a new cokeq why doesn'tit put otherprocesses at therefrnery?
ConocoPhillipsis pursuing the current project becauseits primary businessis supplyingpetroleum based fuels, products for which there is both an ample need and evengrealer demand. As obseryedby this comment,the United Statesis far behind Europe and many other developednations in actionsthat would reducethe demandfor the petroleum-basedfuels that ConocoPhillipsproduces. Other countriesalso provide strongersupport for the developmentof alternativeenergy technologies,as will be critical to rollback emissionsof greenhousegas emissions.
55. Emissionsof greenhousegases should be monitoredand measured- How muchmethane andCOz would be releasedby uncontrolledpressure-relief devices? How muchCOz will be releasedby thehydrogen plant?
Treatingemissions ofCOz and othergreenhouse gases as regulated air pollutant,as is effectivelybeing requestedby this comment,would be inconsistentwith current Illinois law. In particular, COzis a compoundthat is presentin the earth's
10 "ConocoPhillips: The anti-Exxon; The Texas-basedoil companybreaks with he other U.S. majors to support mandatorynational regulation of greenhouseas emissions,"Fortune, Marc Gunther,April I I, 2007, http://money.cnn.conl2007104/10/newslcompanies/pluggedin_guntherconocophillips.fortune/index.htrn
24 atmosphere,occurring both naturally and as a product offossil fuel combustion, CO2in the atmospherehas not beencommonly regarded as an air oopollutant' Indeed,the ecospheredepends upon the presenceof COz emissionsto support green plants. Historically, CO2in the ambientatmosphere has not beenconsidered harmful to humansor the environment.
At the sametime, the Illinois EPA is working to developrequirements for tracking and routine reporting of emissionsof CO2,and perhapsother greenhousegases in Illinois in the near future. This activity would be comprehensive,as it would addressall significantstationary sources of theseemissions. Improved tracking of emissionsof suchemissions is important in conjunctionwith Illinois' clrrent initiative to reduceemissions of greenhousegases,
56. Whatenergy effrciency evaluations were carried out for this project,ifany?
ConocoPhillipsindicated that is has an *energyaction checklist"that setsenergy standardsthat everynew constructionproject must meet, For example,new processunits must be designedso that the temperatureofthe final product is such that all usableheat energyhas been recovered. This checklistis ConocoPhillips' way of evlluating proposedprojects for energyefficiency.
57. How muchadditional methane will be emittedby flaringdue to theproposed project?
Emissionsof methanefrom the refinery from flaring shouldbe decreasingdue to the various measuresthat are beingimplemented to minimizeflaring. Au fcruittrue
FLARING
58. Theproposed project will entailconstruction oftwo new flaresand increased use of existingflares. These flares are subject to BACT for CO emissionsand LAER for VOM emissions.However, the draft permit would not requireBACT or LAER for flaring.
The existingflares are not subjectto BACT or LAER becausethey are not being physicallymodified and will not experiencea changein the methodofoperation, This is becausethey will be in the sameservice, with the sameprocess stream and function, asat present, Indeedodue to the requirementsof the ConsentDecree it is appropriateto anticipatethat emissionsofthe existingprocess flares at the refinery will be declining. The issuedpermit includesadditional requirements as part of BACT and LAER for the newflares in responseto public comments.
59. The applicationdoes not includeemissions information related to flaring from theproject or from contemporaneousprojects over the last frve years, which shouldhave been provided. Not only is there a largepotential to emit at the new flares,but emissionsat existingflares will increasedue to theproject because of increasedproduction at the
25 refinery. The applicationis not completewithout this informationand must be supplemented.
The applicationdoes include emissionsinformation for neq modified and debottleneckedflares and for any increasesin flaring and flaring emissions associatedwith contemporaneousprojects.
60. USEPAprohibits routine flaring and requires preventative measures to minimizeSOz emissionsfrom flaring. A USEPAEnforcement Alert" wamsthat frequent, routine flaring,which may causeexcessive, uncontrolled SO2 emissions, is not considered"Good PollutionControl Practice," and may violatefederal regulations adopted pursuant to the CleanAir Act. Unforhrnately,none of theserequirements are met by theproposed project.The applicationfailed to providethe necessary analysis on availablemethods, suchas having sufficient compressor capacity to rigorouslyprevent and minimize entire flaring eventsand thus achievemaximum controlsand lowest emissionsfrom flaring. Suchrnethods minimize emissions of all nollutantsfrom flarine.and are used at otler refineries.
As alreadyexplained, the Wood River refinery is subjectto requirementsto minimize flaring asit contributesto SOzemissions, Incidentally, while expressing concernsabout excessiveflaring, the USEPAconfirmed that the proper useof flaring is a goodengineering practice, as flaring destroyshazardous and objectionablegases by burning thosegases. Flaring alsoprevents injuries to employees,fires and explosions,and damageto equipment.
61. Theapplication incorrectly states that there is no way to reduceCO emissionsfrom flaring andat the sametime controlVOM emissions,assuming that either VOM waste gasmust be flaredor elsedirectly emined.r2 However, t".ou.-ry of wastegas back to a refinery'sfuel gassystem acts to preventboth VOM andCO emissionsfrom flaring.
This statementwas madein the contextof the Wood River refinery, where measures to reducehydrocarbon and thus VOM emissionsfrom flaring by minimizing and eliminating suchevents are in place. Given that suchmeasures are in place,the flaring eventsthat actuallydo occur must generallybe consideredunavoidable, as indicatedin the application. (Certainly, any further discussionabout whether a particular flaring eventwas avoidablewill occur after the eventhas occurred.)
62. CO emissionsfrom flaring arerelated to combustionefficiency, which varies. Ifthe combustionefficiency of a flarewere l00o/0,there would be no CO emissionsfrom the flare. Flarecombustion effrciency varies according to the qualityof the gasesburned, the
" USEPA Enforcement Alert, Vol. 3, Number 9, October 2000 http:/A,i.ww.epa.gov/compliance/resources/newsletters/civil/enfalerVflaring.pdf 12 "),troprocess changes that would reduce the CO emissionsexist. Sincethe flares serve as VOM controldevices in an 8-hour ozonenon-attainment area, their operation is becessary-Therefore, oo CO confol technologiesexist for thenew flares." Application,page 7-9
zo capacityof the flare,how well the flaremixes the fuels and air, flareexit velocity,wind conditions,etc. Combustionefficiency can vary from low, downto only 60% or lessof VOM combustedto very high, over9'9%o efficiency. Regulators in Texasand Califomia usedestruction efficiencies down to 930lowhen calculating flare emissionswhen waste gassent to a flarehas a low Btu contentinstead of the98% more commonly used in emissioncalculations. Many studiesshow that efficiency can be very low, downto even 30%. Theratios of emittedCO, CO2,VOM, etc.,also vary. ChoosingUSEPA's CO emissionfactor, which relates to averageor tlpical conditions,for BACT for a flare wouldbe unsound.
It is commonpractice to conservativelycalculate VOM emissionsfrom flaring using a minimum level of destructione{ficieney so asto overstateVOM emissions.This level of combustionefliciency is 98 percent,which USEPAindicates is the minimum level of destructionefficiency that will generallybe achievedwhen a flare is operatedto complywith 40 CFR 60.18,as is required for flares at the Wood River refinery. Similar approachesare taken for emissionsof other pollutantsfrom flaring that are affectedby destructionor combustionefficiency of the flare. While the destructionefficiency for flaring that doesnot complywith 40 CFR 60.18may be lower than 987o,as discussed by this comment,this is not relevantto the flares at the Wood River refinery. In addition,this commentdoes not identify a methodby which the effectofnormal variation in destructionefficiency ofa flare and lts effect on VOM emissionscould be readily determinedin practiceor showthat sucha methodis needed.
63. The flare associatedwith thenew hydrogen plant would not be "assisted"with either introductionof air or steam.Steam or air-assistedflares are considered basic to provide goodmixing in a flare andmaintain combustion efficiency. Non-assisted flares should not be consideredto meetBACT requirements.
The wastegas from the hydrogenplant that would be flared, which shouldonly occur during upsetsor emergenciesgiven the nature ofhydrogen plants,is expected to be low-Btu gas,which is primarily CO and COz and hasa low VOM content. As the heatcontent ofthe wastegas is between200 and 300 Btu per SCF,use of steam or air assistis not required for effectivecombustiono as reflectedin USEPA's regulationsfor proper designand operationof flares.
64. Thereare many proven approachesfor reducingthe numberof flaring episodesand the quantityof wastegas flared and thus reducing all flaringemissions. They include: 1) Havingsufficient compressor capacity, including redundant compressor capacity to recyclewaste gases to therefinery fuel gassystem (especially important when the refineryis beingexpanded so that more waste gases may beproduced); 2) Managing depressurizationduring unit shutdownsso that the gas recovery system is not overwhelmed;3) Constructingstronger process vessels to increaseworking pressures to enablecontainment ofprocess gases during shutdown rather than flaring; 4) Implementationof detailedprocedures to diagnoseand eliminate unnecessary flaring, and 5) Fixing equipmentthat repeatedly malfunctions and causes rmnecessary "emergency"
21 flaring. A plan for minimizing flaring and root causeanalysis for flaring activity that doesoccur are keys to prcventingunnecessary flaring. Theseapproaches are used at existingrefineries and have been shown to lowerthe numberand magnitude of flaring events.An analysisofsuch approacheswas not providedfor theproposed project and the draftpermit would only superficiallyaddress these approaches to reducingflaring and flaringemissions.
As generallyobserved by this comment,there are many waysto reduceemissions from flaring. For the new processflare systemsat the refinerp the various approachesto minimizationof flaring and flaring emissionsdiscussed in this commentare required as appropriatefor the particular processunits that are servedby the flare system.This hasbeen clarilied in the conditionsof the issued permit for flaring, The oneexception is constructingstronger process vessels. This has not beenidentified as a reasonableor recommendedapproach to reducing flaring emissions.It would poseoperational concerns as it would implicitly entail operationofprocess vessels at higher pressures.In addition, careful managementof depressurizationofvessels during unit shutdownsappears to be very effectivein minimizing and eliminatingshutdowns as a contributor to flaring.
65. The SCAQMDand the BAAQMD haveboth identifiedadequate compressor capacity for recoveryof wastegas as being effective in minimizingflaring eventsand their associated emissions.This approachwas not evaluatedfor theproposed project for BACT and LAER.
The new flare systemfor the newDelayed Coker Unit will include redundantwaste gascompressors, as currenfly usedat the ShelloMartinez refinery. A condition has beenincluded in the issuedpermit requiring this as an elementof BACT and LAER for this newflare system. The flare for the new hydrogenplant doesnot handlea wastegas that is suitablefor recoveryfor usein the refinery fuel gassystem.
66. Withoutrigorous monitoring, adequate compressor capacity, process control, and appropriatepermit conditions, sigaificant flaring can be expectedat theWood River refinerywith theproposed project.
The extentof future flaring at the Wood River refinery is minimizedby operational and economicincentives to maintain stableprocess operation with consistent product yields and to recoverwaste gas that is producedfor useas fuel, ConocoPhillipsalso has a statedobjective of minimizing its COz emissions. Accordingly,it is unclearto what extent,if any, the permit must mandateparticular action by ConocoPhillipsto preventsignificant flaring at the refinery in the future. Nevertheless,the issuedpermit mandatesthat ConocoPhillipstake particular actionsto minimize flaring, consistentwith the actionsthat havebeen taken at and required of other refineries.
67. Withoutadequate compressor capacity, significant flaring canbe expectedat theWood Riverrefinery with theproposed project. Theapplication does not provideinformation
28 for the nine existing flares in different areasof the refinery for baselinecompressor capacityor the amount,ifany, thatthis capacitywould be increasedwith theproposed project. As foundby theBAAQMD andSCAQMD, compressor capacity is key in preventingflaring. It allowsthe refinery to consistentlyrecover waste gases for useas fuel, ratherthan flaring these gases with associatedemissions. Adding compressor capacity,as discussed in its FlareMinimization Plan, enabled Shell, Martinez to reduce flaring,including emergency flaring, to very low levelscompared to otherrefineries in theBay Area. TheTesoro, Avon refinery(previously Tosco), also in theBay Area, whichhad the worst flaring record prior to theBAAQMD rulemaking,reduced its emissionsgreatly by addingcompressor capacity.
Adequatecompressor capacity is only one approachto minimizing flaring. Whether other approachedare adequatefor the existingflares at the Wood River refinery or additionalwaste gas compression capacity will haveto be installedat the refinery is not a matter that can be determinedat this time asmeasures to reduceemissions from existingflares are ongoing. Whether additional compressorcapacity should be installedfor existingflare systemsat the refinery is a matter that is appropriately dealt with in the contextof the ConsentDecree.
68. At therefineries in theBay Area,flaring, including emergency flaring, was also further reducedafter adoption of rulesfor flaringby the BAQMD, showingthe feasibilityof controllingflaring through prevention mechanisms. The principles and equipment used by refineriesin theBay Areamust be appliedwith specificityto theproposed project.
For the flare for the DelayedCoking Unit, for which BACT and LAER are required,the issuedpermit requiresthat ConocoPhillipsimplement the measures similar to that specifiedby the BAAQMD to reduceflaring. Theseare preparation of and operationpursuant to a Flare Minimization Plan and performanceof "root causeanalyses" for significantflaring incidents. In this regard,the BAAQMD's flaring rules put into placecertain administrativerequirements whose purpose is to lead to reductionin flaring and flaring emissions.The rules do not identify or prescribespecific measures that refineriesmust useto reduceflaring. Thus,while the DelayedCoking Unit will havea gasrecovery system with redundant compressorcapacity as alreadydiscussed, this is not a measurethat is mandatedby the BAAQMD rules.
The BAAQMD's rules for flaring at petroleumrefineries do not addressflaring at wastewatertreatment plants. At wastewatertreatment plants,flares serveas control devicesfor the emissionsfrom certain units and do not handlewaste gas streamsas are potential presentwith the operationand upsetof processunits at a refinery.
6q A detailedevaluationr3 ofthe refineriesin theBay Area,which reviewed data reported by therefineries and their FlareMinimization Plans, found that the dirtiest refinery processescaused more flaring, with moreemissions, than other refinery processes. This
" "FlaringPrevention Measures," Communities for a BetterEnvironment (CBE), Grcg Karras, Apnl 2007
29 is directlyapplicable to the WoodRiver refinery, which is expandingits dirtiestrefining processes.
This evaluationfound that certain refining processeshad the potentialto generate more emissionsfrom flaring. Accordinglyoit recommendedthat theseparticular processesbe subjectto especiallythorough reviewwith appropriate actions implementedto minimizeflaring associatedwith theseprocesses.
70. Theapplication failed to evaluateLAER achievedin practiceby refineriesthat rigorously implementapproaches to minimizeflaring. Shellhas documented its approachesfor minimizingflaring andachieving very low flaringemissions at its refineryin Martinez, California,in theFlare Minimization Plan for this refinery'"required by BAAQMD rules. BACT andLAER for flaring at theWood River refineryshould be at leastas stringent as the equipmentand practices in placeat the ShellMartinez refinery. Evenbefore adoption of the BAAQMD rules,the ShellMartinez refinery did not havelarge flaring events comparedto thelarge and routine flaring events, with substantialemissions, at other refineriesin theBay Area. The ShellMartinez refinery has continued to exhibitvery low flaring emissionscompared to otherBay Arearefineries. The Flare Minimization Plan for the ShellMartinez refinery should be evaluatedand the approachesapplied to Wood River refineryin detailto satisSrBACT andLAER requirements.
In responseto this comment,the Flare Minimization Plan preparedby Shell Martinez hasbeen closely reviewed. The issuedpermit requiresa Flaring Minimization Plan for the new coker flare beingconstructed as part of this project (coker flare) that addressthe various approachesthat havebeen taken by Shetl Martinez to reducingflaring, as presentedin the Flare Minimization Plan for that refinery.
71. Shell,Martinez has two wastegas recovery compressors for dedicateduse in its Delayed CokingArea, with eachcompressor having enough capacity to handlegases from this areawhen one of thecompressors is out of service.ConocoPhillips should do the same.
As previouslydiscussed, the flare systemfor the new DelayedCoker Unit will include redundantwaste gas compressors, like the systemat the ShellMartinez refinery. In this regard, ShellMartine4 with its DelayedCoker Unit that was installedin the mid-1990's,also provides anecdotal evidence that operationof a modernDelayed Coker Unit doesnot significantlycontribute to flaring emissions, given ShellMartinez's excellentrecord on minimizing flaring emissionsas cited by
14 Shell's FlaxeMinimization Plan for the Martinez refinery indicatesthat "As the refinery alreadyhas very significant capital inlrastructurefor flare gasrecovery in place, proceduralmodifications can be used to achreve much higher retums on a $/ton emissionsreduction basis. New refinery proceduresdescribed in this Flare Minimization Plan address actions to further minimize flaring during process upsets and additional planning requirements for maintenance ard turnaxound activities. Careful planning of any activity with the potential for flaring is the most successful minimization approach that has been employed at SMR. Procadures for reporting and investigating all flaring provide meansto leam from unanticipatedevents. The result ofthis work will be further reductionsin flaring." Excerpt from the Shell Marlinez Refinery, Flare Minimization Plan, RedactedVersion, RevisedMaxch 25 2007, submittedto the Bay Area Air Quality ManagementDistdct
30 this commenter.
72. The Shell Martinez RefineryFlare Minimization Plan emphasizedthe importanceof thoroughroot causeanalysis of flaringincidents to avoidsimilar events in thefuture and reduceemissions from flaring emissions.This measure is neededfor theproposed projectdue both to thelarge increase in refinerycapacity and the refinery's history of flaring.
The issuedpermit requiresthat root-causeanalyses be performed for the new flare for the DelayedCoking Unit for any significantflaring incident for hydrocarbons.
Operationalmonitoring lbr wastegas that is flaredis importantto provideaccuate data for emissionsfrom flaring andto providea factualbasis for evaluationof thenumber and natureof flaring eventsand their associatedemissions and to perform root causeanalyses for flaring. Monitoringdevices are available to trackthe flow of gasesto a flare. Monitoringfor theconcentration of VOM andsulfir compoundsin wastegases, in combinationwith recordsfor pilot andpurge gas flow, is neededto providegood informationon thewaste gas bumed by a flareand the accompanyingemissions.
The issuedpermit requirescontinuous monitoring to identify when wastegases are flared. This requirementis accompaniedby requirementsfor monitoring or instrumentationto reasonablydetermine the amountof gasthat is flaredo requirementsfor samplingand analysisof wastegas or maintenanceofrecords for the compositionofthe gas,and requirementsfor monitoring or recordsrelated to fuel usagefor the pilot and ventingofpurge gasto the flare.
74. Thedraft permit would only superficiallyaddress monitoring for flaring. Despitereadily availablemonitoring devices and a ConsentDecree that addresses excessive flaring at the woodRiver refinery in thepast, it is surprisingthat the draftpermit does not contain requirementsfor monitoringofflow or compositionof wastegas going to the flaxe. BACT andLAER for flaringnecessitate operational monitoring in orderto minimize emissions.As monitoringof flaringhas been successfully implemented pursuant to applicableregulations at manyCalifomia refineries, this work providesa ready-made solutionfor deficienciesin the applicationfor theproposed project, with provenmethods thatcan be includeddirectly into thepermit.
In particular,rigorous operational monitoring should be requiredfor flaringas specified by themles of the SCAQMDand BAAQMD. TheFlare Monitoring Rule, Regulation 12-11," whichwas adopted by theBAAQMD in 2003,shows that issues related to operationalmonitoring for flaringhave been worked out, including verification ofgas flow andanalysis for hydrocarbonsand sulfur content of wastegas. This rulewas adoptedfollowing input with manufacturersof monitors,refineries and the public. Each requirementofthis rule shouldbe incorporatedinto thepermit for theproposed project. Thesemeasures are needed for theproposed project due both to the largeincrease in refinerycapacity and the refinery's history of flaring. TheTexas Commission on
" BAAQMD Regulation l2 Rule I1, http://www.baaqmd.gov/dsVregulations/rgl2ll.pdf
-)l EnvironmentalQuality also found that accurate emissions data must first be collectedin orderto thenbe ableto identifuand develop options for controllingrefinery flaring, which emphasizesthe importanceof operationalmonitoring as paft of flare emission control.'oThe ShellMartinez Refinery Flare Minimization Plan also emphasized the impoftanceof monitoring.
The issuedpermit includesan appropriatelevel of specificityfor operational rnonitoringfor flaring. As the fundamentalobjective for flaring is to minimize and eliminateflaring, it is not appropriatefor the permit to include the detailed requirementsfor operationalmonitoring presentin the BAAQMD's Flare Monitoring Rule. Given the very low level of flaring that shouldoccur in the future at the Wood River refinery, a simpler approachto operationalmonitoring at the refinery shouldbe established,as comparedto the circumstancesof the refineriesin California that led to the BAAQMD and SCAQMD adoptingtheir Flare Monitoring rules severalyears ago. Accordingly,the issuedpermit setsthe purposesthat must be fulfilled for the operationalmonitoring for flaring, i.e.,collection of data to identify when wastegases are flared and in what quantity, The permit doesnot prescribewhat monitoring techniquesmust be usedand how monitoring must be conducted. tJ. In 2006,the BAAQMD adoptedadditional requirements for reportingof flaring at refineriesin its rulesfor FlaresAt PetroleumRefineries, Regulation 12-12. The provisionsof this rule shouldalso be includedin the conditionsof thepermit for the project.lT
The issuedpermit includesappropriate provisions for reporting relatedto flaring. Given the nature ofthe Illinois EPA's proceduresfor review ofreports from sources,detailed reporting relat€dto flaring associatedwith this project will be more efficiently and effectivelyhandled if it occursin conjunctionwith routine quarterly reporting, rather than as stand-alonereports for significantflaring events.Provisions for prompt reporting upon occurrenceof certain flaring events are appropriately setin the CleanAir Act Permit Program (CAAPP) permit for the refinery.
76. Themonitoring conditions in the draftpermit for flaring,which only reiteratefederal
16 TCEQ Master Control StrategyList, Point Sources,page 5, September7, 2005 http://www.nctcog-org/trans/airlsip/future/lists/TCEQ-oint%20Source%20List.pdf
1' RepodableFlaring Eyent: Any flaring where more than 500,000 standaxdcubic feet per calendarday ofvent gas is flared or where sulfirr dioxide (SOr) emissionsare greaterthan 500 poundsper day. For flares that are operatedas a backup, stagedor cascadesystem, the volume is determinedon a cumulative basis;the total volume equalsthe total ofvent gas flared at each flare in the system. For flaring lasting more than one calendar day, each day of flaring constitutes a sepajate flaring event unless the owner or operator demonstrates to the satisfaction ofthe APCO that the cause offlaring is the same for two or more consecutiye days. A reporlable flaring event ends when it can be demonstratedby monitoring required in Section 12-12-501that the integrity ofthe water seal has beenmaintained su{Iciently to preventvent gas to the flare tip. For flares without water sealsor water seal monitors as requiredby Section l2-12-501, a reportableflari g event endswhen the rate of flow ofvent gas falls below 0.5 feet per second. http://www.baaqmd. gov/dsVregulationVrgl 2 I 2.pdf
-)L requirementsfor monitoringof flaresand which were in placein thepast when ConocoPhillipshad excessive flaring, are vaguely stated.
The monitoring requirementsofthe applicablefederal rules for flaring are appropriatelyincorporated by the permit by referenceto thoserules. These req[irements addressproper operationof a flare for effectivedestruction of organic constituentsin wastegas and effectivecombustion as relatedto generationof CO. '77. TheWood River refmeryhas a majorpotential for emissionsfrom flaring.r8Baseline flaring emissionsand compressor capacity at therefinery must be providedto thepublic, and potentialincreases from flaring must be evaluatedin light ofthis information about otherrefineries. However, the applicationdid not provideinformation on existingor wastegas compressor capacity or informationon root causesofpast flaringat the refinery,or thevolume, duration, and emissions of individualflaring events. Without monitoringof thevolume and composition of wastegas sent to the flare,and without designingsufficient gas recovery capacity, increased and poorly quantified flaring will occurat existingflares at therefinery with this project.
Under the ConsentDecree, ConocoPhillips must prepare and submit its Compliance Plan for Flaring Devices,which will addressthe existingflares at the Wood River refinery, by December31, 2007[Paragraphs 141 and 142of the Decree]. ConocoPhillipsmust alsouse flow metersor reliable flow estimationparameters to determinethe emissionsfrom flaring [Paragraph165]. '78. I Thepermit should require ConocoPhillips to developand implement a flareminimization planto capturewaste gas for useas fuel, rather than flaring it, sothat flaring emissions arereduced.
Wastegas is routinely capturedfor useas fuel rather than beingflared. For existing processunits, requirementsfor minimization of flaring are establishedby the ConsentDecree. The Decree requires ConocoPhillips to developa plan that includessteps to correct the conditionsthal causeor contributeto excessiveAcid GasFlaring and HydrocarbonFlaring.
As part of this project, ConocoPhillipswill be installing redundantwaste gas recoverycompressors for the newDelayed Coker Unit, eachof which is designedfor 100percent of routine gasesfrom the unit. The issuedconstruction permit also requiresConocoPhillips to developantl implementa Flaring Minimization Plan for the new Coker Unit and the newHydrogen Plant.
r8 Although it is unlikely that the Wood River refinery performed as well ast}re averageBay Area refinery before the Bay Area reductionsoccurred (since USEPA fotmd that excessiveflaring was occurring),ifthe Wood River refinery had performed as well per barel of crude oil processed,baseline emissions ofTotal Organic Carbon (TOC) for the refinery would be about 1898 tons per year. Furthermore,the proposedproject representsa 1260loincrease in refinery capacity (306,000 to 385,000bpd). Flaring emissionswill likely increasemore tharl 260lobecause the refinery is increasingproduction in the most intensive parl ofthe refinery, with higher-sulfur inputs. Witlt a26Vo incrcaseon top ofbase TOC emissions1898 tons per year, TOC emissionsfrom flaring at the Wood River refinery would increaseby alnost 500 tons per year, evenusing conservativeassumptions that could underestimateflaring.
J-l 79. Whatmonitoring devices with whatdetection limits arecurrently installed to measure flow andcomposition of wastegases for eachexisting flare at therefinery? What specificmonitoring devices will be installedfor the newflares?
The existingflares must be operatedto complywith the requirementsof the N€w SourcePerformance Standrrds (NSPS)and/or National EmissionStandards for HazardousAir PollutantsCNESHAP) for flares. The NSPSand NESHAP require monitoring for a pilot flame be presentin a flare at all timesthat wastemay be sent to the flare, which ensuresthat any wastegases that are sentto the flare will be ignited and combusted,They do not require other monitoring. Under the Consent Decree,ConocoPhillips must be ableto reasonablydetermine flow and H2Scontent of wastegas,
The issuedpermit requiresthat monitoring and recordkeepingbe implementedfor new flares to be ableto determineflow and compositionof wastegas. Useof specific monitoring devicesis not required and can be addressedin the processingofa revisedTitle 5 permit (CleanAir Act Permit Program Permit) to addressthe proposedproject,
80. How many flaring eventsdue to upsetsoccurred at the Wood River refinery during the Iastthree years.
There were ten eventsin 2005,ten eventsin 2006,and four eventsin 2007. The majority ofeventsoccurring in 2005were attributable to problemswith the startup of the gascompressor on the distilling westcoker. The majority of eventsfor 2006 were attributable to power outages.Power outages also contributed to events. Poweroutages affect both the processunit and the wastegas system, as they rely upon availability of electricalpower. ConocoPhillipsindicates that it is working with Ameren to improve the reliability of the power supply for the refinery.
81. How manyflaring eventsresulted in visualsmoking and what evaluations were performedto determinethe associated emissions of particulatematter and polycyclic aromatichydrocarbons?
Therewere sevenevents in 2005,seven events in 2006,and oneevent in 2007. Specificevaluations were not conductedto quantify emissionsof particulate matter or polycyclichydrocarbons. Such evaluation was not considerednecessary given the duration of eventsand the compositionofthe refinerytswaste gas streams, which do not contain significantlevels of aromatic hydrocarbons.
82. How muchSO2, VOM, PM, NO*, CO, andCOz is emittedfrom the existingflares affectedby theproject? Is thatlisted somewhere and should itbe part of thepermit?
Table C-l of the applicationcontains the baselineannual emissionsof CO, NO,, and VOM for the existingflares affectedby the project. The annual emissions,based on
34 24 consecutivemonths of actual emissiondata are: 7.8tons of CO,3.6 tons of NO,, and 3.4 tons of VOM. The emissionsof PM and SOzwere not quantified asthey would be minimal given the nature of the gasstreams b€ing flared. Historically, emissionsofCO2 from the refinery havenot beenquantilied. The increasesin emissionsat theseflares are addressedin AttachmentI ofthe permit.
83. What is thedestruction efficiency assumed for calculatingflaring emissionsand what is thebasis ofthis figure?
For putposesof calculationemissions, properly operatedflares are assumedto achieve98 percentdestruction efficiency for VOM and CO containedin the waste gas. This conservativelevel of performanceis basedon information on USEPA's Compilation of Air Pollutant Emission Factors, LP-42. Actual destruction efliciency could be significantlyhigher,
84. How muchcompressor capacity for recoveringwaste gases is beinginstalled for eachof thenew flaresfor theproject? What calculations were performed to ensurethe compressorcapacity will be sufficient to eliminateall routine flaxing?
Redundantcompressors are beinginstalled on the newcoker flare. Each compressoris designedto route 100percent ofthe projectedflow of wastegas from the cokeunit to the fuel gasrecovery system.le The adequacyofthe recoverysystem in practicewill be addressedby the required Flaring Minimization Plan. Other flareswhich would handlegases from the existingflare gasrecovery system are not affectedby this project.
CRUDE OIL SUPPLY
85. The proposedproject would involve modifications and expansionfor the purposeof processingless*expensive, heavier crude oil, with resultantincreased local and global pollution and hazards,that will be locked in for decades.The proposedproject represents a major new direction in U.S. refinery operationswith modifications to processheavy Canadiancrude oil recoveredfrom oil sands. This oroiect is a test caseof this trend for useof heaviercrude oil with higherenergy use. Processingofoil sandshas impacts in Canada,including degradationofpristine boreal forest and impactson plants and wildlife Canada. This project requirescareful evaluationdue to its nature and its long-term implications.
It is beyondthe scopeofthe Illinois EPA's review ofthe applicationsfor the proposed project to formally consider the various impacts in Canada from the recovery and processing of crude oil from oil sands. This is a matter that is appropriately considered and addressed by the federal and provincial governments ofCanada as they regulate this activity. Howeveroas this comment observes,the recovery ofcrude oil in Canada is accompanied by environmental impacts, as is the le ConocoPhillipsindicates that the gas flow mtes ofprocess units were modeledat maximum designrates of units plus an engineeringsafety factor using computersimulation software for petroleumrefining processes
35 recoveryof oil from other locations. Theseimpacts are loweredas the consumption of crude oil is reduced.
86. What evaluationsof heavy-metals,such as lead and mercury, in theheavy crude oil have beenperformed? Will mercuryand lead be emittedfrom the refiningprocess? What measurementsare planned for the future for heavymetals in coke to be manufacturedand whatwill be donebecause of tlreincrease in theseheavy metals? What practices will be usedto ensurethat these increases of healy metalsdo not escapeinto theenvironment?
Healy metals,which are presentin parts per million and billion levelsin crude oil, havenot beenidentified as a specialconcern for crude oil.20Loss of metalsto the environmentis controlledby the generalnature of refining operationsand the emissioncontrol practicesand add-oncontrol equipmentimplemented for cefiain units. As an operationalmatter, there are alsoproduction consequencesas metals can poisoncatalysts used in refining operations.USEPA and the American PetroleumInstitute ar€ currently engagedin studieson the hearTmetal contentsin various crude oils, to further improve the understandthe relationshipbetween metalsin the crude oil supply,the operationofrefining units, and the metalscontent of products and environmentaldischarges.
87. Theheary crudeoil thatwill be usedat theWood River refinery will be very cheap. ConocoPhillipsstands to makea lot ofmoney from this projectand it canafford these enhancedenvironmental controls without sacrificing jobs. Oftenwith increased environmentalcontrols, there might actuallybe oppoftunityfor morejobs becauseof the workersthat areneeded to operateand maintain of thesecontrols.
Heavy crude oil is not cheap. It is only lessexpensive when comparedto lighter crude oil. The lower costof heaviercrude oil is accompaniedby additional expenses for investmentin the facilitiesneeded to be ableto processthe heaviermaterial. It is alsoaccompanied by shifts in the amountof different productsthat can be made and the revenuestream for a refinery. The quality of different products may alsobe affectedso that additional effort may be neededto adapt and enhancecertain processunits to maintain product quality. As Canadahas ratified the Kyoto protocolothe costof healy crude from Canadamay increasedue to the costsof mitigating emissionsof greenhousesassociated with the extractionand initial processingof crude oil from oil sands.Accordinglyo this project is the result of a complexbusiness decision by ConocoPhillips.One of the elementsthat must go into this businessdecision is a recognitionthat the Wood River refinery will haveto operatein compliancewith environmentalrequirements, with a workforce that is able to properly operateand maintain environmentalcontrol systems.This is an essentialaspect of the proposedproject irrespectiveof the costof compliance.
88. Processingofheavier crude oil (with longerhydrocarbon molecules and higher sulfur content)means more refining to producegasoline and diesel, and to removesulfur. This
20 According to infomation provide by ConocoPhillips,the lead and mercury content in the expectedcrude slateis approximately 3 ppm and 7 ppb respectively.
36 will increasethe potential for upsetconditions and associated emissions due to the higher temperatuesand pressures needed to processheavier crude oil.
The relinery currently processesheavy crude oil, sothat the proposedproject would not representa significantchange to the overall operationof the refinery, While the project involvesinstallation ofa secondDelayed Coker Unit to havemore capacity to crack the heavieststream from crude oil, the newcracking units would be designedfor this purposeand include appropriatefeatures to maintain safe operation. Accordingly,an increasein upsetsshould not be expectedwith the proposedproject.
89. ConocoPhillipshas applied for authorizationto operateduring breakdowns when pollution control equipmentdoes not work. This underminesthe effectivecontrol of emissions,which will be especiallyimportant when processing heavier crude oil, which is like1yto increaseprocess upsets at therefinery.
ConocoPhillipsrequest for authorizationfor excessemissions during malfunction and breakdownaddressed possible exceedances of a genericstate emission standard for SOr emissions.Under staterules, ConocoPhillipsmust obtain "prior authorization" for exceedancesofthe statestandard as it must showthat continued operationwith excessemissions may be necessaryto protect personnelor equipment. This alsoenables a permit to be preparedwith conditionsthat appropriately addressthe possibilitythat suchcontinued operation with excess emissionsmay occur. However,whether ConocoPhillipsactions to avoid malfunctionsand reduceemissions in the eventof a malfunctionare still subjectto scrutiny by the Illinois EPA and USEPA asto whether the particular eventwas avoidableand goodair pollution control practiceswere followed. In eontrast,the federalNSPS state that the otherwiseapplicable standard simply doesnot apply during malfunctions. The appropriatenessof actionstaken by a sourcerelative to malfunction are only subjectto after-the-factreview as to whetherit wasavoidable and goodair pollution control practiceswere followed.
DELAYED COKING
90. Coking is a high temperatureand pressureprocess for the heaviestfraction of crude oil handledby a refinery. Emissionsof particulatematter, other criteria pollutants,toxic healy metals,and greenhousegases can be extreme,especially considering fugitive emissionsand accidentalreleases. These should all havebeen evaluated. This is especiallynecessary given the proposeduse of cmde oi1from Canadianoil sands,which is particularly heavy, so this project resultsin a large amount of coking and energyuse. Data on the carbon content of the crude oil supply to the refinery and the range of sulfirr, heavy metals,selenium, and other contaminantscontained in the crude oil and impactsof thesepollutants should have beenprovided by ConocoPhillips.
Emissions of PSD/I.{SRpollutants from coking are addressedin the application, including emissionsfrom both routine operation and emergency flaring. Emissions
JI of heavymetals have not beenidentified as a particular concernfor coking units as fine material is not entrainedin a gasstream during the coking process.While USEPA has adoptedNESHAP standardsfor emissionsof metal hazardousair pollutantsfrom catalyticcracking and catalyticreforming units, it has not adopted similar NESHAP standardsfor coking. Moreover,these NESHAP for these catalyticprocess units set a number of alternativestandards that apply either to total particulate emissionsor nickel emissions,a singleheavy metal. Emissionsof greenhousegases associated with coking are better addressedin terms ofthe overall energyconsumption and emissionsof a refinery"'or in termsofthe total emissions of greenhousegases associated with the crude oil that a refinery processes.
91. An evaluationis neededfor the impactsofincreased coking at therefinery on wastewater.This is especiallytrue giventhe planned use of crudeoil from Canadianoil sands.
The impactson the wastewatertreatment plant havebeen addressed by the air permit asfurther shownin Section4.10 of the permit, The wastewatertreatment plant will require modificationsto accommodatean increasein wastewaterflow and solidsand organicloading due to increasedrefining operationsand to treat the wastewaterfrom the scrubberson the FCC Units. Thesemodifications will have emissionconsequences and are appropriatelylimited by this sectionofthe permit.
92. An evaluationis neededfor the impactsofincreased coking at therefinery on soil contamination.This is especiallytrue given the planneduse of crudeoil from Canadian oil sands.
This project shouldnot contributeto soil contaminationat the refinery. Soil contaminationat refineriesis generallythe result of historie relinery designand operatingpractices. As suchspills occurred, lighter materialstypically are of particular concernfor contamination.As spills of material now occur at the refinery with the potentialfor soil contamination,such spills must be investigated and either rernediatedor appropriatelycontained pending remediation in the futurc.
93. Becauseofanployee accidentsassociated with DelayedCoker Units, a ChemicalSafety Aler1(Hazards of DelayedCoker Unit (DCU) Operations,August 2003) was jointly issuedby USEPA,the OccupationalSafety and Health Administration (OSHA), the U.S. Departrnentof Labor,and the ChemicalEmergency Preparedness and Prevention Office. This alertfound that Delayed Coker Units areincreasing in usedue to their ability to processlower quality crude oil, ashigher quality crude becomes less available to refiners. The alert found that theseunits havehazards that must be addressedby the operatorsof theunits, listing the various process steps and the specifichazards that are posed.
'' The quantity and quality ofthe intermediatesheams produced by an initial conversionprocess, like coking, has implications for the amount of energy consuned by downstream pfocess units at a refinery. The product slate of a refinery is also relevant for a meaningfi,rl assessmentof the energy efficiency ofa refinery.
38 While this ChemicalSafety Alert identified potentialsafety hazards for workers from delayedcoking units, it alsodescribed actions that could be taken to minimize thoserisks. ConocoPhillipsindicates that the new DelayedCoker Unit is being designedwith features,such as mechanical interlocks and an automatedremote drum unheader,to addressthe dangersthat may be posedby older coker unit and help preventaccidents. Similar upgradesare plannedfor the existingcoker unit during a future maintenanceturnaround at the refinery, In the meantime,a manual safetyprocedure involving multiple signaturesas cross-checksis being used to preventincidents, That procedurewas enhancedthis spring and ConocoPhillips indicatesthat it has beenvery effective. The Illinois EPA will be examiningthe effectivenessand the adequacyof the measurescurrently being implementedby ConocoPhillipsand the measuresthat are planned. This will occur aspart of the Illinois EPA's investigationinto recentreleases that haveoccurred from the existing coker unit at the refinery.
94. Thenew coking unit, which will processthe heavy crude, is goingto producepetroleum coke. GivenUSEPA's and Illinois' newrules on mercuryemissions from coalfired powerplants, what will ConocoPhillipsdo with thepetroleum coke if powerplants can not useit? Do all thecoal-fired power plants around use it or just a few or some?
Thereis no reasonto believethat coal-firedpower plants will no longer use petroleumcoke from the refinery. Additionally, the market that the relinery choosesto sellproducts to has no impact on its ability to complywith the applicable regulations.
Incidentally,the new coker will not direc y processheavy crude oil. The function of the new coker unit is to further processmore ofthe bottom fraction of crude oil, which is currently producedat the refinery and sold as asphalt. The coker unit will convertthis bottom fraction into petroleumcoke, a solid fuel material, and a liquid streamthat can be further processedinto higher value petroleumproducts.
95. I am concemedabout coking because ofpast releasesfrom the cokerunits at therefinery, whichreleased material that caused damage to homesand property. As part of this project,is ConocoPhillipstaking into considerationthat according to anAugust 2003 documentprepared by the USEPAand OSHA, delayed coker units have been found to causefrequent and severe accidents. Considering the past violations at therefinery, will employeesbe safeand nearby residents be safegiven the hazardsassociated with these units? Whatsteps will be takento ensurethe safetyof employees?
The past releasesappear to havebeen caused by operatorerror. As part ofthis project, safetyinterlocks will be installedon lhe new coking unit to prevent similar releasesfrom the newunit. ConocoPhillipsindicates that the new coker unit will haveall ofthe latestsafety features for a coking unit, including automated equipment,interlock valves,enhanced instrumentation and other safetysystems.
96. Whatmeasures have been evaluated to eliminatefugitive dust from cokingduring the
39 manufacture,storage and transportationof petroleumcoke due to the project? Have there beenrecent violations at therefinery involving these operations.
With appropriatehousekeeping practices, the handling ofpetroleum cokeis not a significantsource of fugitive dust. The cokeis cut out of the cokedrums with water jets, which wetsthe surfaceof the cokepreventing dusting. Thereafter,fugitive dust can be readily controlledby appropriate handlingpractices with applicationof addifional water or other dust suppressantas neededto control fugitive dust. Given thesecircumstances, the handlingofcoke by ConocoPhillipshas not posedany concernsfor compliance.
EMISSTONS
97. A fu1levaluation is neededfor emissionsPM2.5 from theproject, including secondary formationof PM2.5caused by SO2and NO1 emissions from theproject.
The generaleffect ofthe changesoccurring at the refinery, including the proposed project, is to reduceits contribution to the levelsof PM:.sin the ambientair and to improve air quality. This is becausethe net effectof thesechanges is to reduce emissionsof direct PM. Emissionsof precursorsto PMz.sare alsoreduced as emissionsof emissionsof SO2are substantiallyreduced. (Emissionsof NO* would not increasesignificantly, even with the permitted increasein production.)
As the Greater St, Louis area is currently designatednonattainment for PM2.5,the Illinois EPA and the Missouri Departmentof Natural Resourcesmust developand implementattainment plans to bring the area into attainmentof the National Ambient Air Quality Standards(NAAQS) for PMz.s.This will provide a comprehensiveevaluation of local and regionalemissions of direct PMz.sand precursorsto PM2.5,including emissionsfrom the Wood River refinery, as necessary to assurethat the complianceof the NAAQS for PM2.5is achievedand maintained throughoutthe area.
98. This provisionofthe ConsentDecree purporting to allow useof emissionreductions as part ofprojectsat the refineryis contraryto the CleanAir Act andthus invalid.22 Section 173(c)(2)of theClean Air Act expresslyprohibits the use of emissionsreductions requiredby theAct asoffsets. ConocoPhillips cannot be allowedto useemission reductionsrequired by theConsent Decree as offsets for this projectbecause these reductionsare required by the CleanAir Act.
Section173(c)(2) of the CleanAir Act, which dealswith emissionoffsets for major projectsin nonattainmentareas, is not relevantto the permitting ofthe proposed project for emissionsof SOz. Not only will the proposedproject occurin an
" Paragraph262(d)ofthe ConsentDecree provides that "...utilize emissionsreductions from the installation of controls requiredby this ConsentDecree in determiningwhether a project that includes both the installation of controls under this ConsentDecree and other constructionthat occurs at the sametime and is nermitted as a sinele pfoject triggers major New SourceReview requirements.;"
40 attainmentarea for SOu,and not in a nonattainmentarea, but the decreasesin SOz emissionare beingused for purposesof "netting" to demonstratethat the proposed project is not a major project. The emissionsdecreases are not being usedas emissionoffsets, which would entail a transfer of emissionreduction credits from onesource to another,as is occurring for the proposedproject for emissionsof votrt.
99. If the emissiondecreases from the installationof scrubberson theFCC Unitswere not creditedagainst the proposed project, the project would have a significantincrease in SO2 emissionsand be a majormodification for emissionsof SO2under the PSD rules. The additionof the scrubbersto theFCC Units results in decreasesin SOzemissions of 5,909.6tpy from FCC I and5,221.9 tpy from FCC2 (total 11,132tpy). If tlese decreases werenot creditedtowards the project, the project would have a net SO2decrease ofonly 36 tpy." Whenincreased SOz from flaring,missing from theapplication, are included, hundredsof tonsper year more emissions are added with theproposed project. While theseemissions can be preventedwith BACT for new andexisting flares that wi handle theadditional waste gases due to theproposed project, the project would increaseSO: emissionsby morethan 40 tpy ascurrently proposed. This triggersPSD for emissionsof SO2,requiring BACT for emissionsof SOzfrom new andmodified emission units.
As this commentconfirms, at most only a fraction of the decreasein SOzemission from the installationofscrubbers on the FCC Units is neededto ensurethat the proposedproject is not a major project for emissionsof SO2. Accordingly, assumingfor purposesofargument that evenmost ofthe decreasein SO2emissions from installationof scrubberson the FCC Units could not be relied upon for the permitting ofthe proposedproject, the remainingdecreases would still be sufficient for the project not to be a considereda major modificationfor emissionsof SOz.
In addition,the refinery is subjectto requirements,as touched upon by this comment,that act to preventincreases in SO2emissions due to increasedflaring at existingflares in conjunctionwith this project. In particular, the ConsentDecree includesrequirements to investigatethe causeof flaring incidentsthat contributeto S02emissions, including performanceof root causeanalysis, to take stepsto correct the conditionsthat causesuch incidents, and to minimizethe number and extentof suchincidents. Theserequirements are accompaniedby provisionsfor detailed reporting for significantflaring incidentswith estimatesofSOz emissions,the root causeanalysis and the correctiveaction plan. Stipulatedpenalties applyif an incident resultedfrom carelessoperation, failure to operatein accordancewith good engineeringpractice, or failure to follow written procedures.A conditionhas been includedin the issuedpermit that makesclear that thesepractices, other than stipulatedpenalties, are alsoapplicable for the new flare that would be installed with the new DelayedCoking Unit.
100. In orderto clearlyevaluate the proposed project and altematives, the project should be assessedwithout the SOzemission decreases from the scrubberson the FCCUnits u l1,168tpy - 11,132tpy : 36rpy
4l (1 I,132tons), which arenot allowableunder the CleanAir Act, andseparately from offsetsflom otherprojects (3,165 tons). In this light, tlle proposedproject by itself will resultin an annualSOz emissions increase of 3,129tons.
This commentreflects an incorrect evaluationofthe proposedproject for emissions of SO2. The project is only beingpermitted for 1548tons per year of "new" SOz emissions.The project alsowill only be accompaniedby an emissionsdecrease of 1,554tons per year from other contemporaneousprojects. However,these decreasesby themselveswould still be sullicient for the project to net out ofPSD reviewfor emissionsof SOr. The installationof the scrubberson the existingFCC Units will provide a further decreasein emissionsofSOz ofat least11,132 tons per year. In summary,there will be a substantialdecrease in refinery's SOzemissions from current levelsafter the proposedproject is complete. Thesecircumstances do not necessitatean alternativeformulation ofthe extentofthose decreasesto assess the effectofthe project or consideralternatives to the proposedproject.
101. To the extentthe decreases in SOzemissions listed for other"Contemporaneous" projects wereor will be carriedout pursuantto theConsent Decree or areotherwise required by the CleanAir Act, theyare not allowablefor offsets.The Illinois EPA mustprovide a detailedevaluation of this issueand historical review ofreasons for these contemporaneousprojects in orderto addressthe potential improper use of offsetsby ConocoPhillipsfor this project.2a
The emissionsdecreases for ContemporaneousProjects are itemizedin Table C-12 of the application. Thesedecreases occurred with and were relied upon for other projectsat the refinery. Their circumstancesofthese past decreasesare identical to the future emissionsdecreases that will occur at the FCC Units with installationof scrubbers, Incidentally,the amountof thesedecreases is only about 11580tons.
I02. Thecurrent SOz emissions of theWood River refineryare very high comparedto those ofrefineriesin Texasand Califomia. Thetouted 11,168 ton reductionin annualSOz emissionsthat will accompanythe proposed project is long overdueand is improperly beingused to coverup the increasesin SO: emissionsthat actuallyresult from the proposedproject, when SOz emissions should have been reduced separately, on its own merits.For example,the baseline annual SOz emissions of theWood River refinery,with a currentcapacity ofabout 306,000bpd, are about I1,468 tons, which is almost8 trmes higherthan the emissionsof BP's SouthCoast refinery when adjusted for capactty.25
Emissionof SO2should not be comparedas simply as suggestedby this comment.
" AppendixC ofthe applicationshows the total use of 3,165tpy of SOxoffsets, i.e., 1,580Qy ofoffsetsfrom contemporaneousprojects of at startupof "FCCU-3and DU-2 LC Startup"and 1,585Qy of additionaloffsets when theproject is completed. " In 2005,the averageSO2 emissions reported for the28 refineriesin Texaswere 1,985 tons, for a total-52,868 tons. ln 2005,the average SO2 emissions for the five refineriesin theSan Frarcisco Bay Are were2532 tons, for a totalof 12,662tons. In the SouthCoast area (Los Angeles area), the average SO2 emissions of sevenrefineries were 683tons, for a totalof only 4779tons. The largestcapacity Califomia refurery, the BP SouthCoast refinery with a capacityof260,000 barrels per dayftpd), emittedonly l22l tonsofSO, in 2005.
42 This is becauseof the variousfactors that affect SO: emissionsof a refinery. These factorsinclude location and accessto different sourcesof crude oil, the nature of crude oil that a refinery is capableof processing,the nature ofthe relining processes at the refinery, ageof the units at a refinery, and a number of other factors.
103. The total SOzbaseline emissions of theWood River refinery are not providedin the application(Table C-1, proposed Project Emission Increases Summary, Appendix C 5)26 Theremay be additionalsignificant SOz emissions from facilitiesat therefinery that are not includedin this listing,which shouldbe providedto thepublic as part of the applicationand for considerationof altemativesto theproject.
The applicationwas appropriatelyprepared to addressthe existingemission units at the refinery that are affectedby the proposedproject. Information on the total baselineemissions of SO2of the Wood River Refineryis availablefrom the Annual EmissionReports submitted by ConocoPhillipsfor 2004and 2005,which indicate annual SOzemissions of about 12,500tons. It is not necessaryto include data in the applicationfor baselineemissions for existingunits that are not affectedby this project In fact, the majority of the emissionsof the refinery are addressedin the application,since the project includeschanges at existingprocess units at the start of the refining process.
104. Evenafter the emissionsdecreases with theproject are achieved, with controlof SOz emissionsof theFCC Units,the totalannual SO: emissionsfor thevarious operations at theWood River refinerylisted in the applicationare 1891tons (Appendix C TableC-1). This Tabledoes not providetotal SO2 for all refineryunits, only emissionsfrom theunits in theproject, so the totalfor therefinery may be evenhigher. Whencompared to the averageSO2 emissions for refineriesin otler regions,the Wood River refinery will still havemore SO2 emissions than the rypical refinery in Texas,(1786 tpy)'?? or Califomia (1,607tpy). It will alsohave higher emissions than the largest Califomia refinery (BP \xith |,221tpy). Accordinglly,the Wood River refinery cannot be consideredto provide thebest control for emissionsof S0r. or eventhe averaserate of conhol.after the proposedproject.
It is wholly inappropriate to comparethe future permitted SOzemissions of the Wood River refinery, as setby the permit, to the gglga! emissionsof other refineries. The permitted emissionsof the refinery, asset by the permit, incorporatesafety factorsto accountfor normal variation in the operationofprocesses and control measuresas relatedto emissions.After the proposedproject is completed,it is expectedthat the actual SOzemissions from the Wood River refinery will consistentlybe significantlylower than the permitted emissions,with actualSOz
26 The total ofemissions listed for the units at the refinery after the project in Appendix C, Table C-l is not provided, only the changein emissions. However, the column entitled "PotentiaVProjectedActual Emission Rate (tons/yr)" provides emissionsexpected after the CORE Project for individual units, which totals on the Table to 89 I tons/yr. ^1'' The refinery in Texasthat emitted l l,T86 tons ofSO2 in 2005 is not tlpical and is an outlier comparedto the other Texasrefineries-
43 emissionsthat coincidentrlly are equalto or lessthan the "average" refineries discussedin this comment. o The actual SOzemissions ofother refineriesare alsonot indicative ofthe amount of SO2emissions that thoserefineries are allowedto emit by applicableemissions standardsand permits. Accordingly,their actual SO2emissions do not provide a meaningfulreference for whether the SO2emissions of the Wood River refinery would be well controlledin the future. In this regard, the ConsentDecree, which addressesexisting emission units, and the federalNew SourcePerformance Standards,which will addressnew and modified units at the refinery, can be consideredto require very goodcontrol of the SOzemissions of the refinery in the future.
105. The decreasesin the SO2emiisions of theFCC Units arerequired by a ConsentDecree with the USEPA,the Stateof Illinois andother states that address the Wood River refineryand other refineries operated by ConocoPhillips.28Therefore ConocoPhillips cannottake credit for thesedecreases for permittingthe proposed project. In particular, the ConsentDecree requires ConocoPhillips to installcertain emission controls at the WoodRiver refinery,including scrubbers on the FCCUnits, which provide most of the SO2emissions decreases. The ConsentDecree also states that ConocoPhillips may not takecredit for reductionsrequired by the ConsentDecree.
The provisionsof the ConsentDecree with respectto "use" of emissionreductions are more involvedthat indicatedin this comment. The ability of ConocoPhillipsto useemissions decreases that result from actionsunder this decreeis a matter that is addressedby the actualterms ofthe ConsentDecree, which allow use ofthe emissiondecreases for permitting of the proposedproject. (Paragraph262(d) of the ConsentI)ecree). The provisionsof the ConsentDecree that addressuse of emission decreaseswere negotiatedby ConocoPhillips,the USEPA and other parties to the Decree,as the Decreeconstitutes a negotiatedsettlement of allegedviolations on the part of ConocoPhillips.
106. The SO: limits for theFCC Units proposedin thedraft permit do not representBACT . andshould be lower. Thedraft permit would require the FCCUnits to meetlimits of 25 pprnvdSO2, 365-day rolling average,and 50 ppmvd,T-day rolling arerage,both at 0% 02, pursuantto Paragraphs57 and60 ofthe ConsentDecree. A studyby the USEPA,the Universityof Texas,and the Texas Commission on EnvironmentalQuality reviewing the emissionrates achieved in practicefound that the Valero refinery in CorpusChristi, Texasmet a 20 ppm limit in 2003.This limit shouldbe requiredfor this project.
This commentdoes not support settinglower SOulimits for the FCC Units. The proposedproject doesnot trigger a requirementfor BACT for emissionsof SOu. In addition,these comments suggest that a stringentlevel of control for SOzemissions
'8 United Statesof America and the Statesof lllinois, Louisiana and New Jersey,Comnonwealth of Pennsylvania ard the Northwest Clean Air Agency v. ConocoPhillipsCompany; Civil Action No. H-05-0258, enteredby the District Court for the SouthemDistrict ofTexas on January27, 2005 (ConsentDecree)
44 is alreadyrequired by the ConsentDecree. The study cited by this commentshows actual SOr emissionsat 20 ppm in a particular year, which is consistentwith an emissionlimit set at 25 ppm, to provide a safetyfactor for normal variation in operationof an FCC Unit and its SOzemission control systems. l0'/. It is not clearwhether there is a netreduction in emissionsfrom this project,as ConocoPhillipsclaims. With all of the nettingand all of thedebottlenecking and all of theproblems that are involved, there is goingto be an increasein emissions.I don't want thenetting to be "smokeand mirrors." I wantthere to be an actualdecreases in emissions.
The project will result in a net increasein emissionsof someregulated pollutants (e.g.,VOM, CO, and PM). For pollutantsfor which there is net decreasein emissions(e.g.oNO. and SO2).In order for emissionsdecreases to be considered creditablefor purposesof a netting exercise,they must be actual decreasesin emissions.
108. Whatwill be the increasein emissionof HzSfrom theproposed project, in pounds,from boththe Wood River andthe Distillins Westfacilities?
There will be at most a minimal increaseof H2Sas a result of this project. Nlost of the HrS and other sulfur compoundswill be recoveredby the new sulfur recovery units aselemental sulfur. The H2Sin the tail gasfrom the Sulfur RecoveryUnits is convertedto SOzin the oxidizers. The H2Sin the fuel gassystem will be converted to SO2through combustionin the heatersor other combustiondevices.
109. An evaluationis neededfor emissionsand impacts ofthe projecton thepublic from odors,including odors due to flaring,fugitive H2S emissions from highersulfur products at therefinery, and other sources of emissions.
This project will not be significantfor emissionsof HzS. This is becausestreams with pctentially significantlevels of emissionsof HzSwill be combusted,either as fuel gasor by flaring, convertingthe HrS to SOz. Overall, the emissionsof HzSfrom the refinery shouldbe decreasingbegause of improvementsbeing madepursuant to the ConsentDecree.
OTHER
110. TheD.C. CircuitCourl recently vacated the Boiler MACT Rule,which means there is no industrystandard and permits require indiyidual MACT analysesfor anyboilers that weresubject to this rule.2e
While the D.C. Circuit Court recentlyissued an order finding that the "Boiler MACT Rule" shouldbe vacated,the Circuit Court has not yet issueda final mandateto vacatethis rule, In the interim, the Boiler MACT Rule remainsin
2e http://pacer.cadc-uscourls.gov/docs/common/opinions/200706/04- 1385a.pdf-
45 effect. When and if a final mandateis issued,the Illinois EPA would proceedas instructedby USEPAfor this unusualdevelopment with respectto this rule. This could necessitateConocoPhillips having to obtain a revisedconstruction permit for the boilers and steamgenerating units that would haveotherwise been subject to the Boiler MACT Rule. A case-by-caseMACT determinationmight alsohave to be madethrough an appropriate revisionof the CAAPP permit for the refinery, so as to addressexisting boilers at the refinery, independentofthe proposedproject.
11 i . How manypressure-relief devices at the refineryvent to the atmosphereand what monitoringdevices are used to determinewhether these devices have vented? How many pressure-reliefdevices from thenew project will ventto the atmosphere?What monitoringdevices will beused to determinewhether they have vented?
While many ofthe pressurerelief devicesvent to the existingvent gasreeovery' system,which routesdischarges to the fuel gassystem, there are certain pressure relief valvesthat vent direcfly to the atmosphereto protect equipmentand workers from catastrophicfailure. There are no new hydrocarbonpressure relief valvesas part ofthe proposedproject. Pressurerelief valvesare recognizedas potential sourcesof emissionsdue to leaksand are addressedby the Leak Detectionand Repair (LDAR) program that ConocoPhillipsmust implementunder stateand federal rules. For pressurerelief valves,this program requiresmeasurements with a portable organicvapor analyzerwhenever a valve opens, Thesemeasurements are usedto confirm that the valve hasproperly resealedafter the eventwas over or that the new rupture disk wasproperly installedover the pressurerelief valve.
1I2. Will the valvesfor theproposed project be leaklessbellow valves? How manynew compressorsand pumps will havedouble seals and how manywill not?
ConocoPhillipsis not planning to usebellow valves. Bellowsvalves and certain other "leaklessrrequipment can hayesignificant emissions when failures occur.In particularobellow valvesare not reliable in "aggressive"service. This type of equipmentis alsonot availablefor all situationsin refinery operations.
All new pumpsin light liquid servicein the new units will be equippedwith double seals.It is anticipatedthat the definition for a leak set as LAER could be met with control technologiessuch as dual or mechanicalseals.
113. Hasthe Illinois EPA analyzedhow theproposed changes to federalNew Source PerfbrmanceStandards (NSPS) for petroleumrefineries, which will be applicableto this project,affect the permit?
Many of the amendmentsand new rules30were driven by the control technologies required by USEPA'sNew SourceReview Consent Decrees for various refineries. Although theserules are not expectedto be adopteduntil 2008,the proposedproject
30 On April 30, 2007,the USEPA proposed amondments to the currentNSPS lbr PetroleumRefineries (40 CFR60 SubpartJ) anda new NSPSfor unitsincluding FCC units, coking units, and sultur plants. (40 CFR60, SubpartJa).
46 will be designedcomply with thesenew and revisedNSPS standards, which are consistentwith the stringentemission limits set in the ConocoPhillipsConsent Decree.
114. The EndangeredSpecies report submitted by ConocoPhillipsis inadequatebecauso they usedwhat appears to be aninappropriate model for thedeposition modeling and the follow-upevaluation - usingone for hazardouswaste incineration facilities rather than for therefiuing of crudeoil from Canadiantar sands.In addition,the dataused in the modelappears to for the existingsupplies of crudeoil.
The analysisfor impactsofthe proposedproject on threatenedand endangered specieswas properlf prepared. Depositionmodeling was conductedwith an appropriatemodel. While the specificmodel was originally developedto address depositionassociated with hazardouswaste incineration, it is alsosuitable for addressingdeposition of emissionsfrom other typesofsources. This is because there is nothing unique about how depositionoccurs from a hazardouswaste incinerator as comparedto how depositionoccurs from other typesof sources.The data usedin the analysisthat reflected"current" compositionofcertain emissions was appropriategiven the very conservativenature ofthe particular data. In addition,the analysisshowed very low potentialimpacts so that the precisionofthis data was not a critical elementfor the conclusionofthe analysis.
nxistinq Groundwate
115. Will the coneofdepression under our townsget larger with the additionalgroundwater thatwill be pumpedand used for theproposed project?
The proposedproject will not expandthe coneof depressionas the pumping rate will not increasewith this project. The coneof depressionis the intentionalresult of actionstaken to preventthe migration ofexisting soil contaminationunder certain areasof the relinery. By pumping groundwaterfrom under the refinery and maintaininga coneof depression,groundwater flows toward the refinery, rather than awayfrom the refinery, which preventsthe spreadof contamination.Collected groundwateris then treatedto removecontamination,
116. Is therea reasonthat that contamination is not beingrernediated in anotherway insteadof just pullingthe waterdown far enoughso it is not cominginto contactwith contaminated soil? GivenConocoPhillips stated goal of protectingthe local communityand the environment,it shouldfind anotherapproach to the contaminationinstead ofwasting this muchgroundwater, which couldbe otlterwisebe used for productivepurposes.
Equilon EnterprisesLLC dlbla ShellProducts US is required by a RCRA permit issuedby the Illinois EPA, Bureau ofLand to maintain a gradient control under the relinery. This is doneby maintaining a coneof depressionthat prevents contaminationfrom migrating off-site. ConocoPhillipsis maintainingthe coneof depressionfor Equilon, asit is required to do under a contractwith Equilon. When
47 the RCRA permit was issued,this approachwas determined to be an acceptable approachfor containingcontamination. This approachis both feasibleand cost- effectiveas it doesnot disrupt the operationof the refinery, The groundwaterthat is pumpedis productively,as it is oneofthe sourcesofwater for the refinery
1l'1. How is the groundwatercontamination in theHartford area, where a layerof oil floatson the top of groundwater,being addressed?
The groundwatercontamination in the Hartford area is being remediatedby the Hartford Working Group under an Administrative Order on Consentfrom USEPA (No. R7003-5-04-001).The Hartford Working Group is a consortiumof the companiesthat havebeen found to be responsiblefor this contaminationand are subjectto this Order. ConocoPhillipsis not oneof thesecompanies.
eglopliance
118. It is the responsibilityof the Illinois EPA to reviewand grant the conshuctionpermit not only for what complieswith theClean Air Act andlllinois' regulationsbut alsohow it impactsthe people who live here. TheIllinois EPA hasdiscretion. The Illinois EPA can bepermissive and relax requirements or it canrequire the best technologies and actual pollutionreductions. The Illinois EPA canrequire strict conhols and monitoring and can enforcecompliance and prosecute violations.
The Illinois EPA's actionon the applicationfor the proposedproject is constrained by applicablelaws and regulations. The Illinois EPA doesnot havethe authority to relax requirementsas suggestedby this comment. Likewise,the lllinois EPA does not havethe authority to arbitrarily setrequirements for control of emissionsthat are more stringentthan allowedunder applicableregulations and permitting programs. The Illinois EPA has usedthe discretionaryauthority that it doespossess to setstringent requirements for the proposedproject, accompaniedby rigorous requirementsfor monitoring, The Illinois EPA alsoenforces compliance and, with the assistanceof the Office of the Attorney General,prosecutes violations.
119. TheWood River Refinery has a historyof noncompliancewith environmentalregulations asdoes ConocoPhillips. ConocoPhillips was sued by the USEPAand the Stateof Illinois for violatingthe CleanAir Act. It is thesubject of a ConsentDecree that requires it to do certainthings by certaindates so that their facilitiescomply with the law. It hasasked for moretime to complywith cer-tainrequiremenls.
The requestfor extensiondoes not apply to the Wood River refinery. ConocoPhillipshas requestedfor someof its other refineriesthat were affectedby a hurricane,which preventedthem from meetingthe schedulein the ConsentDecree.
120. Theproposed project requires evaluation ofthe commitmentof ConocoPhillipsto clean up emissionsof therefinery due to pastviolations independent of this expansion.
48 ConocoPhillipshas been fulfilling its obligationsunder the ConsentDecree to resolvealleged emission violations at the Wood River refinery.
121. ConocoPhillipswas out of compliancewit the CleanAir Act for the lasttwelve quarters.
The ECHO databasedoes indicate that the refinery has allegedlybeen out of compliancewith the CleanAir Act. However,the Illinois EPA is not awareof current violationsof applicableair pollution control laws or regulations.It is believedthat the noncompliancethat underliesthe data in the ECHO databaseis historic noncomplianc€,which hasbeen legally resolvedwith the ConsentDecree. Publie_Eartrerpaliol
122. It hasbeen my experiencewith otherpublic hearings on constructionpermit applications thatI askquestions at thehearing, and if theIllinois EPA staffdoes not know the answefs,then I don't getthe answersuntil afterit is all over. I haveno oppoftunityto commenton the answers.The Illinois EPA shouldfind someway of puttingthe answers on therecord so that I canthen submit and extend the commentperiod so I car cofiment on the answers.I do not expectall theanswers to be availableat a publichearing, but it wouldbe very helpfulif I wouldbe ableto havethe answersand then be ableto comment on them.
The proceduresfor public commentperiods and public hearingsdo not accommodatethe continuingexchange or dialog on draft constructionpermits requestedby this comment. The Illinois EPA staff respondsto questionsat public hearingson constructionpermits as it is ableto do so. However,the primary purposea public commentperiod, including a public hearingis to obtain input from the public on the Illinois EPA's preliminary decisionsthat a proposedproject is entitled to a constructionpermit.
123. More detaileddata must be providedby ConocoPhillips,rather than requiring the public to effectivelyprovide the analysisby pulling togetherthis information.An evaluationis neededfor manyof the issuesraised at thepublic hearing that were not answeredat the hearing.The public brought up key environmentaland health issues and questions about basicdata and impacts of theproject. The transcriptshows that many ofthese issues were not evaluated.There should be a follow-upon all questionsevaluated.
This ResponsivenessSummary provides the Illinois EPA's follow-up to the various issuesand questionsraised at the hearingand in written public comments.As explainedin responseto various comments,comments did not identify issuesthat required submittal of more data or performanceof additional analysesby ConocoPhillips.
124. Thereare many additional clear hazards from this project,but the applicationfailed to providebasic information for publicanalysis, and the time for publicreview was shorl considerinsthe factthat the oublic had to assemblemuch basic data. TheIllinois EPA
49 shouldre-evaluate the project taking into accountthese additional issues and re-open the commentperiod.
The public commentperiod, which lastedover 80 days,provided a reasonable amount of time for the public to reviewthe applicationfor the proposedproject and submit informed comments.The public commentsdo not raiseany issueswhose nature is suchthat they warrant preparation ofa new draft permit by the Illinois EPA and re-openingof a public commentperiod. While various concernsare raised about the proposedprojecto the commentsdo not showthat the project, as currently proposedby ConocoPhillips,would posesignilicant hazards to the public or should not be permitted.
Other-eommculr
125. Fuelefficiency standards for vehiclesneed to be increased.We alsoneed to movepast fossil fuelsand develop electric cars and wind andsolar energy. As SenatorObama has stated,for the sakeofour security,our economy,ourjobs andour plane! the ageof oil mustend in our time.
126- Thereare a lot of healthproblems in this area.Many of our childrenhave asthma. We do not needany more particulate matter or ozonein the air. l2'7. ConocoPhillipsshould operate its heatingand cracking units more effrciently.
128. It is importantto work to devisecredible, practical, cost-effective approaches to address the emissionsof greenhousegases at thenational and at the intemationallevel, given the globalnature of climatechange. ConocoPhillips should strive to do this for this project.
F.orlaaitionat fnfor
Questionsabout the public commentperiod and permit decision shouldbe directedto
BradleyFrost, Community Relations Coordinator Illinois EnvironmentalProtection Agency Office of CommunityRelations I 021North GrandAvenue, East P.O. Box 19506 Springfield, Illinois 62194-9506
211-1 82-1 02'l Desk Line 217-182-9t43TDD 2 17- 524- 5023Facsimile
brad.fros t(rD,i llinoi s. sov