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NRDC Exhibit 1.60000.Pdf '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
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