EPA-450/2-76-016-b
STANDARDS SUPPORT
AND
ENVIRONMENTAL IMPACT STATEMENT
VOLUME II.
PROMULGATED STANDARDS
OF PERFORMANCE
FOR PETROLEUM REFINERY
SULFUR RECOVERY PLANTS
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
January 1978
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This report has been reviewed by the Emission Standards and Engineering
Division, Office of Air Quality Planning and Standards, Office of Air and
Waste Management, Environmental Protection Agency, and approved for
publication. Mention of company or product names does not constitute
endorsement by EPA. Copies are available free of charge to Federal
employees, current contractors and grantees, and non-profit organiza-
tions - as supplies permit - from the Library Services Office (MD-35) ,
Environmental Protection Agency, Research Triangle Park, N.C. 27711;
or may be obtained, for a fee, from the National Technical Information ,
Service, 5285 Port Royal Road, Springfield, Virginia 22161.
Publication No. EPA-450/2-76-016b
ii
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FINAL
Standards Support and
Environmental Impact Statement
Petroleum Refinery Sulfur Recovery Plants
Type of Action: Administrative
Prepared by
Director, Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Approved by
(Date)
Assistant Administrator
Office of Air and Waste Management
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Additional copies may be obtained or reviewed at:
U. S. Environmental Protection Agency
Library (MD-35)
Research Triangle Park, North Carolina 27711
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TABLE OF CONTENTS
Page
List of Figures - v
Chapter 1. SUMMARY
1,1 SUMMARY OF CHANGES SINCE PROPOSAL . f,.. - , 1-1
1.2 SUMMARY OF THE IMPACTS OF THE PROMULGATED ACTION ,,. 1-2
Chapter 2, SUMMARY OF PUBLIC COMMENTS
2.1 GENERAL .'..-, , - 2"1
2.2 EMISSION CONTROL TECHNOLOGY 2~3
2.3 ECONOMIC IMPACT .- - - 2~7
2.4 ENVIRONMENTAL IMPACT 2^16
2.5 ENERGY IMPACT , 2-19
2.6 LEGAL CONSIDERATIONS ., 2-2.2
2,7 TEST METHODS AND MONITORING ..,....,,,.. 2-22
TABLE 2-1 LIST OF COMMENTERS 2-25
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List of Figures
Page
Figure 2.1 Incremental Annual Cost vs. Plant Capacity
Figure 2.2 Capacity Distribution of New Petroleum Refinery
Claus Sulfur Recovery Plants (1976-1981)
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1. SUMMARY -...-.. •.._••
On October 4, 1976, the Environmental Protection Agency (EPA) proposed
a standards of performance for petroleum refinery Claus sulfur recovery
plants (41 FR 43866) under authority of section 111 of the Clean Air Act.
Public comments were requested on the proposal in the Federal Register
publication. Twenty-two letters were received from oil company representa-
tives, State and local air pollution agencies, a vendor of emission source
testing equipment, and several Federal agencies. The comments that were
submitted along with responses to these comments are summarized in this
document. The summary of comments and responses serves as the basis for
the revisions which have been made to the standard between proposal and
promulgation.
1.1 SUMMARY OF CHANGES SINCE PROPOSAL
Only one significant change has been made since proposal of the
standard of performance for petroleum refinery Claus sulfur recovery plants.
The proposed standard would have required that all petroleum refinery Claus
sulfur recovery plants achieve 99.9 percent overall reduction in sulfur
emissions. The promulgated standard includes an exemption for Claus
sulfur recovery plants with a capacity of 20 long tons per day (LTD) or less,
installed in a petroleum refinery with a crude oil capacity of 50,000 barrels
per stream day (BSD) or less which is owned or controlled by a refiner with a
total combined crude oil processing capacity.,of 137,500 BSD or less. Otherwise,
the promulgated standard does not differ from the proposed standard.
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1
1.2 SUMMARY OF THE IMPACTS OF THE PROMULGATED ACTION
1.2.1 Alternatives to the Promulgated Action
. The alternative control systems are discussed in chapter 4 of the
Standards Support and Environmental Impact Statement (SSEIS, Vol. 1).
These alternative systems are based upon combinations of the best demon-
strated technology, considering costs, for petroleum refinery Claus sulfur
recovery plants. The analysis of the alternatives of taking no action and
of postponing the promulgated action is outlined in chapter 7 (SSEIS, Vol. 1).
These alternatives remain the same.
1.2.2 Environmental Impact of the Promulgated Action
The small petroleum refinery exemption will apply to less than
2 1/2 percent of new petroleum refinery Claus sulfur plant capacity.
However, in most cases those refinery Claus sulfur recovery plants which
are exempted will still be required by existing State regulations to install
emission controls equivalent to alternative I (99 percent overall control
of sulfur emissions). Thus, the adverse environmental impact of the
promulgated standard will be the difference between the emissions resulting
from 99.9 percent control and 99 percent control of less than 240 LTD-of
sulfur emissions by this date. In some cases, this action could lead to
a reduction in sulfur emissions because it will not discourage the voluntary
installation of sulfur recovery plants at a number of small refineries which
are not required by existing regulations to install Claus sulfur recovery,
plants.
1.2.3 Economic Impact of the Promulgated Action
The small petroleum refinery exemption in the promulgated standard
Will eliminate the adverse economic impact of the standard on small refiners.
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An analysis of-the economic impact of standards based on alternative I!
prior to proposal concluded that these standards were affordable for both
large and small refiners. The impact on the small refiner's profitability,
however, would be over five times the corresponding impact on the large
refiner. In terms of the incremental costs of recovering an incremental
ton of sulfur, the impact is also much more severe, with the small refiner
paying up to $6300 per ton of sulfur removed. This very high incremental
cost per incremental ton of sulfur recovered is considered unreasonable,
especially in light of the small refiner's inability to pass on pollution
control costs as easily as the large refiner. Thus, the promulgated
standards include an exemption for the small refiner.
1.2.4 .Other Considerations
1.2.4.1 Adverse Impacts
The potential adverse impacts associated with these standards are
discussed in chapters 1 and 7 of the SSEIS, Vol. 1. These impacts remain
unchanged simce the regulations were proposed.
1.2.4.2 Relationship Between Local Short-Term Uses of Man's Environment
and the Maintenance and Enforcement of Long-Term Production
This impact is discussed in chapter 7 and 9 of the SSEIS, Vol. 1, and
remains unchanged since proposal.
1.2.4.3 Irreversible and Irretrievable Commitments of Resources
This impact is discussed in chapter 7 of the SSEIS, Vol. 1, and
remains unchanged since proposal.
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2. SUMMARY OF PUBLIC COMMENTS •
The list of commenters and their affiliations is shown in Table 2-1.
Twenty-two letters were received commenting on the proposed standard and
Volume 1 of the Standards Support and Environmental Impact Statement.
The significant comments have been combined into the following seven
major areas:
1. General
2. Emission Control Technology
3. Economic Impact
. 4. Environmental Impact
5. Energy Impact
6. Legal Considerations
7'. Test Methods and Monitoring
The comments and issues, along with responses to these comments, are
discussed in the following sections of this chapter. A summary of the
changes to the regulation is included in section 2 of chapter 1.
2.1 GENERAL
2.1.1 Coverage of the Standard
Several commenters stated that it was not clear which sulfur recovery
process or processes were meant to be covered by the proposed standard.
Others felt that the standard should not be limited to sulfur recovery
plants in petroleum refineries; or that the standard should not apply to
"stand-by" Claus sulfur recovery plants.
Although other processes are available for removing sulfur from-
petroleum refinery acid gases (e.g. the Stretford and Giammarco-Vetrocoke-
H2S processes), only the Claus sulfur recovery process is covered by the
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promulgated standard. Essentially all petroleum refinery sulfur recovery
plants will be covered, however, due to the very limited use of alternative
sulfur recovery processes in domestic refineries. As of January, 1975,
only one U.S. petroleum refinery had installed a Stretford sulfur plant
and none had installed a Giammarco-Vetrocoke-H2S process in lieu of a
Claus sulfur recovery plant. Accordingly, the definition of "sulfur
recovery plant" has been revised in the promulgated standard to make it
clear that only Claus sulfur plants are covered by the standard.
To support proposal of standards of performance, a Standards Support
and Environmental Impact Statement (SSEIS) is prepared which includes an
in-depth analysis of the environmental, energy, and economic impacts of
the proposed standard on the affected industry. The SSEIS supporting
the proposed standard dealt only with the petroleum refining industry
and, hence, the promulgated standard covers only petroleum refinery Claus;
sulfur recovery plants.
An SSEIS is currently under development to support proposal of standards
of performance for Claus sulfur recovery plants in the natural gas and
oil production industry. When these standards are proposed and promulgated,
most new, modified, and reconstructed sulfur recovery plants will be
covered by standards since petroleum refining and natural gas and oil
production presently account for 80 percent of the recovered sulfur
production in the U.S.
The promulgated standard will cover "standby" Claus sulfur plants
in petroleum refineries although it does not require installation of such
units. In those cases where a refiner chooses to install a standby
Claus sulfur recovery unit, it will be required to meet the standard
when it is in operation.
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2.1.2 Implementation of Section lll(d)
When standards of performance were proposed, EPA requested comment from
States regarding'the burden that might be imposed fay implementing section lll(d)
requiring the development of State plans limiting emissions of reduced
sulfur compounds in those States where reduction emission control systems
were currently being used to reduce sulfur emissions from petroleum refinery
Claus sulfur plants. The Agency felt that where these systems were
being used, reduced sulfur compound emissions were less than 300 to 500 ppm
which is only slightly .higher than the emission limit included in the
proposed standard. Implementing section lll(d), therefore, would require
a significant amount of Federal and State manpower, but would accomplish
little, if any, additional reduction in emissions from refinery Claus
sulfur recovery plants.
The one State agency which addressed this issue indicated agreement
with this conclusion. Accordingly, section m(d) will be implemented
in the future as. time and resources permit, taking into consideration
other requirements of the Clean Air Act, as amended, which EPA must
implement. However, at this time, no guideline document will be
issued and no State plans will be required.
2.2 EMISSION CONTROL TECHNOLOGY
2.2.3 Data Base for the Standard "
Two commenters expressed the view that the data base was insufficient
to support the proposed standard. These commenters felt that the emission
test data EPA collected was obtained when Claus sulfur recovery plants
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1
were operating below design capacity and, therefore, the emission controls
were not operating at their rated capacities. Also, these commenters. felt
that emission control equipment vendor data was relied on too heavily to
determine the performance of emission controls.
During the technical investigation to determine the best systems
Of emission reduction, all known tail gas processes in full operation were
tested including tail gas processes in Canadian natural gas plants.
During EPA emission tests of the SCOT, Beavon, and Wellman-Lord processes,
oil shortages as a result of the 1974 OPEC oil embargo caused the Beavon
process tested to operate at 1/3 capacity. The SCOT and Wellman-Lord
processes, which were tested, however, were operating very near normal
capacity. The results of emission tests conducted by the Los Angeles
Air Pollution Control District (LA APCD) at the Beavon, SCOT, and Well man-
Lord units which have been installed in Los Angeles County when these
processes were operating at design capacity were also obtained. Subsequently,
the LA APCD supplied emission test data for two additional Beavon units
which were put into operation following EPA's technical investigation.
All the data from LA APCD were comparable to that collected in EPA's
emission tests which showed emissions well below the numerical emission
limits included in the proposed standard.
In developing standards of performance, not only emission, data from
existing well-controlled sources are considered, but also guarantees by
vendors of control equipment, data and information from pilot and
prototype installations, foreign technology, published literature on
emission control technology, and contractor reports on the performance
of emission control technology. Data and information from vendors,
literature surveys, and a contractor's report on tail gas scrubbing
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systems indicated that several processes, including the SCOT, Beavon,
Cleanair, HeTlman-Lord, and IFP-2, could comply with the standard which
was proposed. Thus, the proposed standard was based on data from a
number of sources.
2.2.4 Stringency of the Numerical Emission Limits
Several commenters questioned the ability of emission control systems
to reduce sulfur emissions to the level required by the standard. These
commenters cited factors such as Claus sulfur recovery plant process
fluctuations, the reduced efficiencies of emission controls due to the
presence of high concentrations of C02 in the stream to be treated, and
the effect on emissions of the use of fuels containing sulfur for the
incinerator step included in the oxidation emission control system (i.e.
Wellman-Lord scrubbing). -
Unlike the low temperature extended Claus reaction processes, such as
the IFP-1 and Sulfreen, tail gas scrubbing systems are not sensitive to
the H2S/S02 ratios in the exhaust from a Claus sulfur plant. The literature
descriptions of tail gas scrubbing systems, such as the SCOT, Beavon,
and Wellman-Lord processes, cite their ability to accept, with proper
design, routine fluctuations in the exhaust gases from the sulfur recovery
plant. Obviously the limit of this dampening effect is the absorbing
capacity of the tail gas scrubbing system which is installed. Normal
routine fluctuations should not require design of a tail gas scrubbing
system with an inordinately large absorbing capacity. Thus, with proper
operation and maintenance, emissions from tail gas scrubbing systems
will not exceed the numerical emission limit included in the standard
due to routine random fluctuations in the exhaust gases from the Claus
sulfur recovery plant. Based on emission tests and other information,
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the numerical emission limits included in the promulgated standard
incorporate an adequate margin to allow for Claus process fluctuations.
The reduction emission control systems (i.e. Beavon process) can
easily meet the 300 ppmv total sulfur/10 ppmv H2S emission limit under i
normal operating conditions. While it is true that a very high concentration
of C09 in the gases treated by the Beavon'process could cause an"unfavorable.
shift in the chemical reactions within the process which would reduce its
overall efficiency, it is very unlikely that a petroleum refinery sour
gas would contain sufficient C02 to significantly impair its performance.
There is the possibility that in the future partial oxidation pf
oil will become a major source of refinery fuel gas. In this situation,
refinery sour gas could contain high concentrations of C02- According
to the process vendor, however, the Beavon process could be modified to
meet the 300 ppmv total sulfur emission limit even in high C02 applications.
This would require steam injection into the Beavon reactor to promote
conversion of organic sulfur compounds to H2S, thereby reducing overall
sulfur emissions.
With regard to the potential increase in S02 emissipns if a h-jgh sulfyr
fuel is used to satisfy incineration requirement of the oxidation emission
control processes, the tail gas scrubbing portion of these processes, which
follow the incineration steps, are capable of reducing S02 emissions to
the level of the promulgated standard regardless of the incinerator fuel
sulfur content. .. -..
2.2.5 Restrictions on New Technology
One commenter was concerned that the standard would prevent the
development of new technology which would be as effective as oxidation
or reduction control systems in controlling sulfur plant emissions, but
less costly.
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An owner or operator Is required only to control emissions from an
affected facility so that residual emissions discharged to the atmosphere
are at or below the level required by the standard. The owner or operator
is not required to use the systems discussed in the SSEIS, but may
employ any emission control system which meets the appropriate emission
limit.
2.3 ECONOMIC IMPACT
2.3.1 The Costs of Complying with the Standards Were Underestimated
Several commenters, all from the petroleum industry, believed that the
costs required to comply with the standard of performance for petroleum
refinery Claus sulfur recovery plants were underestimated. These
commenters considered the costs contained in the SSEIS much lower than
their actual costs of installing and operating alternative II emission
control systems. Also, they believed the incremental investment required
by standards based on alternative II over the next five years would
exceed the estimate of $110 million.
Other commenters disagreed with certain basic concepts used in
developing the economic analysis in the Standards Support and Environmental
Impact Statement (SSEIS). Their major comments were: (1) the cost impact
of the standard should have been considered in terms of the sulfur
produced by the Claus sulfur recovery plant and not in terms of the
production of petroleum products by the total refinery; (2) all the
pollution control costs resulting from compliance with standards based
on alternative II, including the,cost of the Claus sulfur recovery plant,
should have been considered; (3) the variations in the price paid for
recovered sulfur should have been considered; and (4) the additional
cost necessary to comply with the standards where a Claus sulfur recovery
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1
plant processed a gas stream containing less than 60 percent H2S should
have been considered.
Generally, the costs were based on information received from petroleum
refinery sources. It was necessary to scale the investment costs from one
size to another and then to increase the costs, which are 1971-72 vintage,
to allow for inflation. Both of these manipulations will tend to introduce
errors. Based upon a review of the information obtained both during the
course of the study and during the comment period, however, there is. no
need, to revise the original cost estimates.
With regard to the total incremental investment required over the
next five years by a standard of performance based on alternative emission
control system II, the estimate of Claus sulfur plant incremental cpn,trol
costs to comply with the standard and the estimate of the nujnber of
Claus sulfur plants that will be cqyered by the standard are essentially
correct. Therefore, the $110 million seems reasonably accurate. .
The objective of the economic impact analysis was tp determine ;
the reasonableness of the incremental control costs imposed on a petroleum
refinery to comply with a standard of performance based on alternative
emission control system II. The appropriate basis for such an analysis
is the petroleum refinery in which a Claus sulfur plant is constructed,
not the sulfur plant itself. While Claus sulfur recovery plants may
have been installed in the past primarily for economic reasons, in the
future sulfur recovery plants will be installed primarily to comply with
State or local air pollution control regulations.
In assessing the economic impact of a standard based on alternative II,
the cost of the Claus sulfur recovery plant was not considered a cost
attendant to compliance with the standard. This is appropriate since
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essentially all States where additional petroleum refining capacity will
most likely be built already require installation of Claus sulfur recovery
plants with alternative I emission control systems. Thus, the economic
impact of a standard of performance based on alternative II is only that
associated with the additional costs of alternative II over alternative I.
With regard to the variation in the price of elemental sulfur., it
is true that this price varies widely from time to time. In determining
the incremental costs associated with a standard based on alternative II,
however, the change in sulfur revenue is relatively minor compared to
the costs associated with other parameters. Consequently, the impact of
this variation in the price of elemental sulfur on the estimated costs of
complying with promulgated standard is negligible.
It is also true that Claus sulfur recovery plant performance decreases
when dilute H2S gas streams are treated. An investigation of the effect
of H2S concentration on investment costs by R.M. Parsons Company, however,
indicates that installing a Claus sulfur recovery plant to handle a
50 percent H2S acid gas stream, compared to a 90 percent H-S stream,
increases the capital costs from about 10 percent for a 10 LTD plant to
about 17 percent for a 100 LTD plant. These percentages are within the
overall accuracy of the basic cost estimates.
2.3.2 The Costs of Complying with the Standard are Excessive
Several commenters, while not necessarily disagreeing with the cost •
data, felt that the costs associated with a standard of performance based
on alternative emission control system II were unreasonable. Among
other things, these commenters indicated that these high costs would
mean that sulfur recovery would no longer be a profitable operation in
petroleum refineries and that a cost-benefit analysis would have shown
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the need for more lenient standards. Additionally, these commenters also
felt that the costs required to comply with the standard were not justified
in all areas of the country.
The fact that a standard of performance based on alternative emission
control system II might lessen or eliminate the profit resulting from the
operation of an uncontrolled Claus sulfur recovery plant was not a consi-
deration in developing the proposed standard. Standards of performance
usually result in increased capital and operating costs. The question is
Whether the increased costs associated with standards of performance are
reasonable. The "reasonableness" of the proposed standard of performance
was examined by assessing such factors as whether or not the standard
would deter or preclude the construction of additional petroleum refining
capacity, the impact upon'petroleum product prices and supplies, and the
change in petroleum refiner profitability. The impact of a standard of
performance based on alternative emission control system II, in terms of
these factors, is reasonable.
With regard to cost/benefit analyses, litigation involving standards
of performance has clearly established that this sort of analysis is not
required by section 111 of the Clean Air Act. The courts have arrived
at this conclusion after examining the legislative history of section 111
of the Clean Air Act and in light of the difficulty of assigning a dollar
value to the benefits associated with reduced atmospheric pollutant levels.
The primary objective of standards of performance developed under
section 111 of the Clean Air Act is to maintain existing air quality and
to prevent new air pollution problems from arising. Consequently, these
standards are not designed to achieve any specific ambient air quality
levels, but are intended to require the use of the best systems of emission
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reduction, considering costs, environmental impacts, and energy requirements
throughout the U.S. Thus, new'Claus sulfur recovery plants within
petroleum refineries will be required to meet the standard regardless of
their geographic location.
2.3.3 Exemption of Small Refineries
Several commenters, including a State air pollution control agency,
recommended an exemption from the standard for small petroleum refineries
and/or petroleum refineries which install small Claus sulfur recovery plants.
These commenters felt that the cost impact of the standard on small
petroleum refineries would be extremely burdensome, compared to the cost
impact on large petroleum refineries. They also felt that an exemption
for the small refiner would not have a significant adverse environmental
impact since the small refiner represents only a small segment of to.tal
domestic petroleum refining capacity. Several of the commenters suggested
that a standard covering all new petroleum refinery Claus sulfur recovery
plants could actually have a negative environmental impact since this
standard would discourage the installation of sulfur recovery plants at
petroleum refineries in those few cases where these plants are not already
required by existing State air pollution regulations.
The SSEIS concluded that a standard of performance for Claus sulfur
recovery plants based on alternative emission control system II was
"affordable" for both large and small refineries. At the same time,
however, it was acknowledged that the economic impact of the standard
would be much more severe on the small refiner. The small refiner's
profits could be reduced by 1.3 to 7.5 percent due to complying with a
standard based on alternative II. This impact is over five times that
imposed by the standard on the large refiner.
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When the economic impact of a standard based on alternative emission
V;
control system II is considered from the standpoint of cost effectiveness
(i.e., the incremental cost per incremental unit of sulfur emissions controlled
at Claus sulfur recovery plants of various capacities), the difference
in the impact of the standard on small and large petroleum refineries .
becomes more extreme. For example, Figure 2.1 shows that the incremental
cost of controlling an incremental ton of sulfur emissions to comply ;with
the proposed standard ranges from about $580 for a 100 LTD Claus sulfur*
recovery plant to about $6300 for a 3 LTD Claus sulfur recovery plant.
For small Claus sulfur recovery plants in small petroleum refineries,
this very high incremental cost per incremental ton of sulfur recovered
is unreasonable. As several commenters have stated, the small refiner
cannot increase his prices to recoup pollution control costs as readily
as the large refiner due to the competitive nature of the petroleum
refining industry. Thus, some relief from the standard is warranted for
small Claus sulfur recovery plants at small petroleum refineries.
In a number of cases, relatively large petroleum refineries operate
small Claus sulfur recovery plants. Large petroleum refineries, however,
should not be able to make use of an exemption from the standard. For
large petroleum refineries, regardless of the Claus sulfur recovery
i
plant capacity, the cost of complying with a standard based on alternative
emission control system II is reasonable. Consequently, the promulgated
standard provides an exemption from the standard only for small petroleum
refineries which install a Claus sulfur recovery plant with a capacity
of 20 long tons per day (LTD) or less.
The 1977 amendments to the Clean Air Act added a definition of a
small petroleum refinery to section 211, which deals with the regulation
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Figure 2.1. Incremental Annual Cost vs. Plant Capacity
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CO
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of fuels. A small petroleum refinery is defined as one with a crude oil
processing capacity of 50,000 B'D or less which is owned or controlled by a
refiner of 137,500 barrels per stream day (BSD) or less. A small petroleum
refinery is defined in the promulgated standard consistent with this
definition currently included in the Clean Air Act.
Figure 2.1 was the basis for selecting 20 LTD as the cut-off point
for exempting small Glaus sulfur recovery plants from compliance with the ,
standard. As shown by this figure, for Glaus sulfur plants of less than
20 LTD, the "cost effectiveness" of alternative emission control system It,.
over alternative emission control system I deteriorates rapidly. Thus,
this is the most reasonable point for an exemption to become effective.
Figure 2.2 shows that this exemption will apply to less, than 2 1/2 percent
of new petroleum refinery Calus sulfur plant capacity. As discussed,
earlier, in most instances these new Glaus sulfur recovery plants exempted
from the standard will still be required by existing State regulations :..,
to install emission control equivalent to alternative I. Consequently,
this exemption will not lead to a significant adverse environmental •
impact. Also, in those few areas where State regulations do not require
the installation of Claus sulfur recovery plants, which tends to be
States containing only one or two small petroleum refineries, this
exemption will avoid the potential adverse impact raised by several
commenters of discouraging the installation of these plants.
The following examples illustrate how this exemption is to be applied:
Example 1. A petroleum refinery of 50,000 BSD or less, which is
owned or controlled by a refiner with a total crude oil processing capacity
of 137,500 BSD or less, with or without existing Claus sulfur recovery.
plant capacity, exists prior to proposal of the standard. After proposal
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Figure 2.2 Capacity Distribution of New Petroleum Refinery
Claus Sulfur Recovery Plants (1976-1981)
LlJ
CJ
ui
D.
20
Percent of total capacity
15
10
.A.,,
10
20 30 70
CLAUS PLANT CAPACITY, LTD
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1
of the standard, a Claus sulfur recovery plant of 20 LTD or less is
.installed at the refinery. This new Claus sulfur recovery plant is not
covered by the standard. On the other hand, a Claus sulfur recovery .
plant of 30 LTD added to this refinery would be covered by the standard.
Example 2. A petroleum refinery of 60,000 BSD, which is not owned
or controlled by a refiner with a total combined crude oil processing
capacity of 137,500 BSD or less, with or without existing Claus sulfur
recovery plant capacity, exists prior to proposal of the standard. A
Claus sulfur recovery plant of any size added to this refinery (after
proposal of the standard) would be covered by the standard since the
refinery has a capacity larger than 50,000 BSD.
Example 3. An existing petroleum refinery of 50,000 BSD or less,
which is owned or controlled by a refiner with a total crude oil processing
capacity of 137,500 BSD or less, operates with an existing Claus sulfur
recovery plant capacity of 20 LTD or less. After proposal of the standard,
the capacity of the petroleum refinery is increased to more than 50,000 BSD.
The existing sulfur recovery plant is not covered by the standard.
However, a sulfur recovery plant of any capacity added after the addition
of the new refinery capacity is covered by the standard. If the capacity
of this petroleum refinery is increased to more than 50,000 BSD and, at
the same time, a Claus sulfur recovery plant of 20 LTD or less is also
added to this petro-leum refinery, the new sulfur recovery plant would be covered
by the standard..
2.4 ENVIRONMENTAL IMPACT
2.4.1 Environmental Impacts of the Standard Were Not Clear
One commenter suggested that the environmental impact statement
was one-sided, highly technical, and improperly included within the SSEIS.
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Other commenters stated that the adverse impacts which might result from
the various 1-iquid and solid wastes discharged from the alternative II
emission-control systems were not adequately .discussed. Two of these
commenters also believed that the beneficial impact of the standard
(i.e., future reduction in .SCL emissions) were overestimated due to an
overestimate of future petroleum refinery Claus sulfur plant capacity.
Litigation involving standards of performance has established that
preparation of an environmental impact statement under the National
Environmental Policy Act is not necessary for actions under section 111
of the Clean Air Act. Nonetheless, the adverse,, as well as beneficial,
impacts of standards of performance are considered. The beneficial
environmental impacts of the standard of performance for'refinery Claus
sulfur recovery plants overwhelmingly outweigh the adverse impacts of
the standard.
Alternative II emission control systems do discharge varying amounts
of liquid wastes. The SSEIS clearly identifies the potential waste.
streams from the SCOT, Beavon, Stretford, and We11man-Lord processes.
Since these streams are quite small in comparison with the liquid waste
streams generated within a typical petroleum refinery and waste treatment
systems capable of treating these streams are routinely installed within
petroleum refineries, no adverse environmental impact is foreseen.
Waste catalysts from tail gas treating systems are normally reprocessed
because-of-the value of the metals,in the catalyst. Since this is not a
refinery process, the impact of chemicals or catalyst regeneration was
not considered in the environmental assessment. The assessment is limited
to direct environmental impact. Secondary impacts, such as addition'al
emissions from manufacture of tail gas system hardware, production of
chemicals, or off-site regeneration of spent chemicals, were not assessed.
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With regard to the estimate of future Glaus sulfur recovery plant
capacity, a survey of the latest issue of the "Hydrocarbon Processing"
Box-Score Supplement indicates that 3800 tons of sulfur capacity is due
for completion in 1976 and 1977 alone. Although the publication does
not differentiate between Glaus sulfur recovery units within petroleum,
refineries and those in oil and natural gas production fields, an effort
was made to list only those units associated with petroleum refining.
On this basis, 8000 LTD appears to be a reasonable estimate of 1980
petroleum refinery Glaus sulfur plant capacity.
2.4.2 Existing State Regulations
Several commenters indicated that contrary to EPA's claim that most
State implementation plans (SIP's) require new petroleum refinery Glaus
sulfur recovery plants to achieve 99 percent control of sulfur emissions,
most SIP's do not require this level of control, but generally require
control equivalent to only two- or three-stage Glaus sulfur recovery
plants (about 94-96 percent control). Thus, they felt that a standard of
performance based on alternative emission control system I (99 percent
control) would result in a substantial reduction in sulfur emissions
from petroleum refinery Glaus sulfur recovery plants, and that the
additional 0.9 percent control required by the proposed standard was
unreasonable.
Most new Glaus sulfur recovery plant capacity will likely be installed
in those States with large petroleum refining capacities. As of 1976,
over 90 percent of all U.S. petroleum refining capacity was located in
17 States. A review of the State regulations for new petroleum refinery
Glaus sulfur recovery plants clearly indicates that the majority of
these 17 States require control of sulfur emissions equivalent to alternative
2-18
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emission control system I. Thus, a standard of performance based on'
\_
alternative I would have little or no impact on petroleum refinery
sulfur recovery plant emissions since most new Claus sulfur plants will
be required to achieve 99 percent control of emissions due to State
regulatory requirements.
In developing standards of performance, State regulations applicable
to the facility covered by the standards are reviewed. The main considerations
in developing standards of performance, however, are the capabilities of
alternative emission control systems and the incremental costs of these
systems. Both costs and technology have been discussed in some detail in
previous sections and alternative emission control system II .is considered
"the best system-of emission reduction" for petroleum refinery Claus
sulfur recovery plants.
2.5 ENERGY IMPACT
In the energy impact analysis, the SSEIS concluded, that compliance with
the proposed standard would lead to a significant energy savings within a
petroleum refinery. One commenter felt the basis of this conclusion
was not adequately explained. Another commenter felt that the total
energy requirements of the reduction control systems of alternative II
were not considered. Specifically, this commenter stated that, even
though incineration of the off-gases from reduction emission control
systems might not be required, up to 25 percent of the fuel that would
normally be used for incineration was needed to maintain an incinerator
on standby. This energy requirement was not taken into consideration in
the energy impact analysis. Generally, all, the commenters felt that
tail gas scrubbing systems are net consumers of energy and that the
energy savings noted were due to the Claus sulfur plant's energy production
of by-products, not due to the tail gas scrubbing system,
2-19 ' ' '• '""• , - .' '•' "•". .-•.-• ' : •
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The prediction of an energy savings associated with a standard based
on alternative emission control system II is based on data which show
that the major reduction emission control system option of alternative II
(the Beavon process) consumes less energy than the major emission control
system option of alternative I (the IFP-1 process). The reduced energy
consumption of the Beavon process is due to the fact that incineration
of the tail gas released to the atmosphere from the Beavon process is
not required, while the alternative I system requires incineration of
the tail gas before release to the atmosphere. This data shows,however,
that the major oxidation emission control system of alternative II
(the Wellman-Lord process) is a net consumer of energy compared to
alternative I. The incremental energy impact of a standard of performance
based on alternative II is equal to the difference in energy consumption
between a Claus sulfur plant which has installed alternative II arid.a
Claus sulfur plant which has installed alternative I, since existing
State regulations will require new petroleum refinery Claus sulfur
recovery plants to install alternative I in lieu of a standard of performance
If future petroleum refinery Claus sulfur plant capacity is equipped half-and
with the Beavon process and the Wellman-Lord process, an overall energy
I
savings will result.
In estimating the actual energy savings attributable to a standard
of performance based on alternative emission control system II, complete
recovery of the energy produced by the Claus sulfur plant and the emission
control system for both alternative I and alternative II was assumed. This
energy savings resulting from the use of alternative II over alternative I
was converted to an equivalent barrels of fuel -oil. While it may not
be feasible in a petroleum refinery to fully utilize the steam produced
-half
2-20
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by a, Glaus sulfur plant and its emission control system in all cases,
even if no energy is recovered, the data show that a significant energy
savings results from the use of the Beavon process of alternative II
compared to the energy consumption associated with alternative I.
Again, this energy savings is due primarily to the difference in incineration
requirements between alternative emission control system I and the
Beavon process of alternative emission control system II.
Concerning the need to maintain an incinerator in a standby condition
within a reduction emission control system, the situation discussed by
the commenter who raised this point is unique and is not expected to
arise where a new Claus sulfur recovery plant is built with a reduction
emission control system. The case in question involved the retrofitting
of a Beavon unit at a petroleum refinery on an existing Claus sulfur
plant. To reduce installation costs, the refiner elected to use the
existing incinerator on the Claus plant rather than install the emergency
incineration system which is normally used with the Beavon process to
handle emergencies and process upsets. Normally, the only incinerator
energy requirement associated with a Beavon unit at a new Claus sulfur
recovery plant is the fuel required for the emergency incinerator's
.pilot light.
Generally, emission control systems are net consumers of energy and
the impact of this increased energy consumption is considered in developing
standards of performance. With regard to the standard of performance
for petroleum refinery Claus sulfur plants, however, no data was submitted
to show that the conclusion regarding an energy savings associated with
a standard based on alternative emission control system II is significantly
in error. In any event, compared to the energy consumption of a typical
2-21
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petroleum refinery, an overall energy consumption considerably greater
than the estimate included in the SSEI5 would not have a significant ;
adverse impact on energy consumption within a refinery.
2.6 LEGAL CONSIDERATIONS
Two commenters questioned EPA's authority for requiring the control of
sulfur emissions from petroleum refinery Claus sulfur recovery plants.
They contended that in most cases Claus sulfur recovery plants were
installed in refineries for the purpose of controlling sulfur emissions.
The additional requirement to further control Claus sulfur recovery
plant emissions was both unreasonable and not authorized by section 111
of the Clean Air Act.
Generally, petroleum .refineries have installed Claus sulfur recovery
plants as a profit-making venture, or to meet the requirements of local or
State air pollution control regulations. The fact that Claus sulfur
recovery plants are used for control of sulfur emissions, however, does
not preclude the development of a standard of performance to limit emissions
from new Claus sulfur plants. Section 111 of the Clean Air Act directs
the Administrator to establish standards which reflect "the degree of
emission reduction achievable through the application of the best system
of continuous emission reduction which (taking into consideration the ;
cost of achieving such emission reduction; and any non-air quality, health,
and environmental impacts; and energy requirements) the Administrator
determines has been adequately demonstrated for that category of sources."
2.7 TEST METHODS AND MONITORING ' . '
2.7.1 Unsuitability of Reference Method 15
i
Several commenters were concerned that Reference Method 15 for
determining sulfur emissions from petroleum refinery Claus sulfur plants
2-22
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would be too complex, expensive, and hazardous for use in petroleum
refinery applications. These commenters felt that this method is only
suitable for the laboratory environment. • •
While Reference Method 15 does require equipment that is.relatively
expensive and complex, most petroleum refineries currently operate gas,
chromatographs which are routinely used for process control. Thus, most
sources affected by the standard of performance are expected to have the
capability to perform the required tests. For those who do not have
this capability, however, source test consultants are available who will
perform the required tests for a reasonable fee.
The potential,hazard of Reference Method 15 is due to the requirement
of the flame photometric detector associated with the gas chromatograph
for a continuous flame to "operate the instrument. The areas in which ,
testing required by the standard would be. conducted, however, are not
areas which are considered to present an explosion hazard since, in many
cases, the exhaust gas being tested is coming from an incinerator. If
there were an explosion hazard, a relatively simple solution is available.
Since performance testing would be only a short-term project, it would
be possible to enclose the flame photometric detector in a box filled
with hydrocarbon-free compressed gas. . .
Reference Method 15 ,has been thoroughly evaluated in.field testing.
situations and does not present any problems which would preclude its
use.- The instrumentation .w'i 11 operate over a wide temperature range and
does not require rigorous temperature control. The permeation tubes
used for calibration must be held at a constant temperature, but this is
easily accomplished with the use of a constant temperature bath.
2-23
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2.7.2 Continuousi Emisslion
Several commenters raised questions about the continuous r-misurpn
monitoring requirements included in the standard. One commenter stated
that the use of Reference Method 15 as a continuous monitor was not. pru-tica'i.
This commenter felt that only H?S emissions should ba noifitor^d continuously
and that a number of accurate and reliable H2S monitors wore available
at less cost than Reference Method 15 instrumentation. Another commenter
questioned the ability of continuous emission monitoring equipment to
accurately measure the very low concentrations of pollutants in the .tail
gases discharged into the atmosphere.
Reference Method 15 was not proposed for use as the continuous monitoring
method since it was not developed for that purpose. Performance specifications
for continuous emission monitors to monitor emissions of reduced sulfur
compounds are currently under development. Thus, the promulgated standard
does not require the installation of continuous emission monitors to
monitor these emissions until performance specifications for these
monitors are proposed and promulgated under Appendix B of 40 CFR Part GO.
Performance specifications for continuous emission monitors to'monitor
emissions of S02, however, have already been developed. These monitors
are quite capable of measuring S02 concentrations in the range of 250 ppm.
Consequently, the promulgated standard requires the installation of
continuous emission monitors to monitor S02 emissions where an oxidation
emission control system or a reduction emission control system followed;
by an incinerator is employed to comply with the standard. ;
2-24
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TABLE 2-1
LIST OF CQMMENTERS ON THE PROPOSED
STANDARDS OF PERFORMANCE FOR PETROLEUM
REFINERY CLAUS SULFUR"RECOVERY PLANTS
epinmenl:er
SR-1
Dr. A. E. Martin
Dept. of Health, Education & Welfare.
NIEHS, P.O. BOX 12233
Research Triangle Park, N. C. 27711
SR-2
Mr. Steven Kir by
Hoi lister & Brace
125 East Victoria Street
Santa Barbara, Call far-pi a 93101
SR-3
Mr. F. W. qicaapn.e, Chief
AJr Facilities Branch
Environmental Protect;]pn Agency - Region
26 Federal Pljtza
New York, Hew York "JOQ07
II
S.R-4
Donald K. Fleming, Associate Director
Process, Eyaljjatipn
"'ate pf Gas. Tephnplngy
South State Street
Chippgo, I'llinqis 6Q616
SR-5
•Mr, Wyatt U Walker,
Vice Presicjent Refining
Continental Oil Company
P.Q; Box 2197
Houston, Texas 7700]
SR-6
Mr. James W. Copper
Division of Air Pollution Control
Alabama Air Pollution Control Comm'ss-'
645 South McDonough Street
Montgomery, Alabama 36130
on
2-25
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1
SR-7
Mr. John M. Daniel, Jr., P.E.
Assistant Executive Director
State Air Pollution Control Board
Ninth Street - Room 1106
Richmond, Virginia 23219
SR-8
Mr. L. A. McReynolds, Manager
Phillips Petroleum Company
Bartlesville, Oklahoma 74004
SR-9
Mr. L. Kronenberger
Exxon Company, U.S.A.
P.O. Box 2180
Houston, Texas 77001
SR-10
Mr. Michael J. Hays
Dow Chemical, U.S.A.
Oyster Creek Division
P.O. Box BB
Freeport, Texas 77541
sR-n
Mr. John B, English, Director
Air Pollution Control
4440 Calle Real
Santa Barbara, California 93110
SR-12
Mr. Arne E. Gubrud, Director
Environmental Affairs
American Petroleum Institute
2101 L Street, N.W.
Washington, D. C. 20037
SR-13
Mr. I. H. Silman
Standard Oil of California
225 Bush Street
San Francisco, California 94104
SR-14
Mr. E. F. Srnythe, P.E., Chief
Permits & Inventories • .
Environmental Affairs
El Paso Natural Gas Company
P.O. Box 1492
El Paso, Texas 79978
2-26
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SR-15
Mr. Sidney R. Galler, Deputy Assistant
Secretary for Environmental Affairs
U.S. Dept. of Commerce
Washington, D. C. 20230
SR-16
Mr. Jim Stevenson, Chief Chemist
Farmers Union Central Exchange, Inc.
P.O. Box 126
Laurel, Montana 59044
SR-17
Mr. C. J. Hoffman, Manager
Environmental Services
Champlin Petroleum Company
P.O. Box 9365
Fort Worth, Texas 76107
SR-18
Mr. W. J. Racine, Vice President
Products Division
Atlantic Richfield Company
515 Soyth. Flower Street
Lps Angel ess California 90051
SR-19
Mr, Charles L, Kimbell, President
Houstpn Atlas, Inc.
9441 Baythorne
Houston, Texas 77041
SR-20
Mr. A. P, Kowalik, Manager
Environmental Affairs
Gulf Oil Company, U.S,
P.O. Box 2Q01
Houston, Texas 77Q01
SR-21
Mrr Dr C. Kloeckner
Environmental Service Representative
Standard Oil Company (Indiana)
200 East Randolph Drive
Chicago, Illinois 60601
SR-21
Mr. I. G. Huddle
Planning & Process Coordinator
Standard Oil Company (Indiana)
200 East Randolph Drive
Chicago, Illinois 60601
2-27
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SR-22
Mr. Dave Smith, Environmental Engineer
Atlantic Richfield Company
Harvey Technical Center
400 East Sibley Boulevard
Harvey, Illinois 60426
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TECHNICAL REPORT DATA
(Please read Instructions on tlie reverse before completing)
1. REPORT NO.
EPA-450/2-76-016-b
3. RECIPIENT'S ACCESSION-NO.
4. TITLE AND SUBTITLE
Standards Support and Environmental Impact Statement
Volume ii: Proposed Standards of Performance for
Petroleum Refinery Sulfur Recovery Plants
5. REPORT DATE
6. PERFORMING ORGANIZATION CODE
January, 1978
7. AUTHOR(S)
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U. S. Environmental Protection Agency, Office of Air
Quality Planning and Standards, Emission Standards and
Engineering Division, Research Triangle Park, N. C.
27711
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
200/04
15. SUPPLEMENTARY NOTES
Volume 1 discussed the proposed standards and the resulting
environmental and economic effects. This volume, Volume 2, discusses the differences
between the proposed and promulgated
16. ABSTRACT
was
A national emission standard for sulfur dioxide and reduced sulfur compounds
proposed under authority of section 111 of the Clean Air Act. The inStof the
rl^5 t0 m mfze Deduced sulfur and sulfur dioxide emissions from refiner?
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b.lDENTIFIERS/OPEN ENDED TERMS
c. COS AT I Field/Group
Air pollution
Petroleum refineries
Desulfurization
Sulfur recovery plants
Emission Standards
sulfur plant tail-gas treating
Air pollution control
18. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS (ThisReport)
Unclassified
21. NO. OF PAGES
33
20. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
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