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Lase Post the Attached Two Issu( From: Brad Frost To: Batty, Stuart lasepost the attachedtwo issu( From: BradFrost To: Batty,Stuart; Hartshorn,Wally Start: 7l19l2OO7 Due: 7l20l2$Ol Subject: Pleasepost the attachedtwo issuedpermits and the accompanyingresponsiveness summaryto the recor Pleasepost the attachedtwo issuedpermits and the accompanyingresponsiveness summary to the recordfor the ConocoPhillipsCORE prolect. htto://www.epa.state.il.us/public-notices/qeneral- notices.html#conoco-ohillips-wood-river Thanks Illinois EnvironmentalProtection Agency Bureauof Air Julv 2007 ResponsivenessSummary for PublicComments and Questions on the Cokerand Refinery Expansion Project at the Wood River Refineryin Roxana,Illinois andthe Wood River ProductsTerminal in Hartford,Illinois Facility Identificationand Application Nos.: Refinery: 119090AAA, 06050052 Terminal:I 19050AAN.061 10049 Tableof Contents Page Decision J Background CommentPeriod and Public Hearins Availabilityof Documents A AppealProvisions i Commentsand Questions with Responsesby thelllinois EPA 5 General 5 Air Pollution 8 New SourceReview 9 BACT/LAER 9 Air QualityAnalysis and Emission Offsets 15 Analysisof Altematives t6 Global Warmins 20 Air Permitting 25 Flaring 25 CrudeOil Supply 35 Delayed Coking )t Emissions 40 Other 45 Existing GroundwaterContamination 47 Compliance 48 Public Particioation 49 Other Comments 50 For Additional Information 50 DECISION On July 19,200'1,the Illinois EnvironmentalProtection Agency (Illinois EPA) Bureauof Air issueda constructionpermit to ConocoPhillipsfor the Cokerand 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 summaryto addressquestions relevant to the issuanceof the air permit and other questionsand comments raisedduring the commentperiod. Questionsrelating to the Bureauof Water permit will be addressedin a separateResponsiveness Summary when the Bureauof Water takesfinal action on therevised NPDES permit. Copiesof thepermits can be obtainedfrom the contactlisted at the endofthis document.The permitsand additional copies ofthis documentcan also be obtainedfrom the Illinois EPA websitewww. eoa.state.il.us/public-notices/ BACKGROIJND ConocoPhillipsoperates the Wood River Refinery locatedin Roxana,Illinois to producea varietyofpetroleum products for dishibutionin the St. LouisnChicago, and Indianapolis Metropolitan areasand throughout the Midwest. Wood River is positionedby refining capacity and by geographicallocation to processthe growing volumesofheavy crudeoil from Canada. On May 15,2006,the Illinois EPA, Bureauof Air receivedan applicationfrom ConocoPhillips for a Coker and Refinery Expansion(CORE) Project. The CORE Project entailsinstalling facilities to increaseboth the total crudeprocessing and percentage of heavier.crudeat the Wood River Refinery in order to increasethe supply of petroleumproducts to the Upper Midwest. In order to handlethe increasedproduct throughput, ConocoPhillips is alsoproposing certain changesat the Wood River ProductsTerminal (also ownedby ConocoPhillips). The Illinois EPA is consideringConocoPhillips's CORE project and the changesto the WoodRiver Products Terminal to comprisea single largerproject for the purposeof the federalrules for Preventionof Significant Deterioration(PSD) andthe staterules for Major StationarySources Construction andModifi cation (MSSCAM). COMMENT PERIOD AND PUBLIC HEARING The Illinois EPA BureauofAir evaluatesapplications and issues permits for sourcesof emissionsto the atmosphere.An air permit applicationmust appropriatelyaddress compliance with applicableair pollutioncontrol laws and regulations before a permitcan be issued. Following its initial technicalreview of ConocoPhillips' application,the Illinois EPA Bureauof Air madea preliminary determinationthat the applicationsmet the standaf,dsfor issuanceof a constructionpermit andprepared draft permits for public review and comment. ConocoPhillipsrequested that the Illinois EPA hoid a publichearing on the COREProject. This hearingalso addressed ConocoPhillips's application for revisionand reissuance of its National PollutantDischarge Elimination System (NPDES) permit to allow increasedwastewater dischargesfrom the Wood River Refinery due to the CORE project. The public commentperiod openedwith thepublication of a hearingnotice in theAlton Telegraphon March24, 20O7.The hearingnotice was published again in theAlton Telegraphon March31'' andApril 7,2O07. The publicheming was held on May 8, 2007,at theHartford Eiementary School in Hartford. The purposeof this public hearingwas to acceptoral commentsinto tle written hearingrecord and answerquestions about the proposedproject. The written commentperiod remainedopen until June15.2007. AVAILABILITY OF DOCUMENTS Theconstruction permits issued to ConocoPhillipsand this responsivenesssummary are availableon the Illinois PermitDatabase at wwv/.epa.gov/region5/airlpermits/ilonline.htm (pleaselook for thedocuments under All PermitRecords (sorted by name),PSD/lvlajor NSR Records).Copies ofthese documentsmay alsobe obtainedby contactingthe Illinois EPA at the telephonenumbers listed at the end of this document. APPEAL PROVISIONS The constructionpermits being issuedfor the proposedproject gfantsapproval to construct purswmtto the federalrules for Preventionof SigrrificantDeterioration of Air Quality (PSD),40 CFR 52.21.Accordingly, individuals who filed commentson the draft permit or participatedin the public hearingmay petition the U.S. EnvironmentalProtection Agency (USEPA)to review the PSD provisionsof the issuedpermit. In addition, as commentswere submittedon the draft permit for the proposedproject that requesteda changein the draft permit, the issuedpermit does not becomeeffective until afterthe period for filing ofan appealhas passed. The procedures governingappeals are containedin the CodeofFederal Regulations(CFR), 'Appeal ofRCRA, UIC andPSD permits," 40 CFR 124.19.If anappeal request will be submittedto USEPAby a meansother than regularmail, refer to the EnvironmentalAppeals Board website at www.epa.gov/eab/eabfaq.htrn#3for instructions. If an appealrequest will be filed by regulm mail, it shouldbe senton a timely basisto the following address: U.S. EnvironmentalProtection Agency Clerk of the Board,Environmental Appeals Board (MC I l03B) Ariel RiosBuilding 1200Pennsylvania Avenue, N.W. Washington,D.C. 20460-0001 Telephone:202/233 -0122 A THE ILLINOISEP General 1. Peoplehave catalytic converters on their cars. ConocoPhillipsshould put catalytic converte$on its operations. The various emissionutrits 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 presentin the exhaustfrom gasoline-fueledengines. The typesof control equipmentthat are used on different emissionunits at the refinery dependon the particular emission characteristicsof the units. For example,the emissionsof nitrogen oxides(NO*) from the Fluidized Catalytic 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 minimizethe formation of NO*. What is the cunent conventionalcrude distillation capacityof the refine4fl The current conventionalcrude distillation capacityis 306,000barrels per day. 3. What is the curent output of dieselfuel from the refinery? ConocoPhillipsindicates that the output of dieselfuel is approximately70,000 barrels per day' all of which is low sulfur diesel. A What will be the cetanelevel of the ultralow sulfir dieselfue1 after the proposedproject is complete?Is the cetanelevel dependenton renewablediesel production? At the public hearing,ConocoPhillips indicated tlat the cetanelevel of low sulfur dieselocurrently at 48, is not expectedto change. The specificationfor low-sulfur dieselis a minimum cetanelevel of 42. The cetanelevel of low sulfur fuel produced by the refinery is not dependenton renewablediesel production. 5. Are future projectsexpected to reducearomatic content and increasecetane to meetthe new USEPA regulations? The lllinois EPA is not able to predict the outcomeof future projectsat tle refinery. Is gasolineoutput with the proposedproject dependenton the ethanoladdition to meet the minimum octanerequirements? According to ConocoPhillips,the refinery hasthe ability to make gasoline blendstocksthat do not require ethanoladdition. Howeyer,one of the advantagesof the project is the ability to make more o'reformulatedblendstock." This is the gasolineblendstock that is preparedfor usewith 10 percentethanol. 7. What is the maximum vaporpressure specification 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. 6. What is the cap on vapor pressureof gasoline? As explainedby ConocoPhillipsat the public hearing,since reformulated gasoline is now requiredothere 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
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