ILLINOIS

POLLUTION

CONTROL

BOARD

December

20,

1973

AMOCO

OIL

COMPANY

PETITIONER

AMOCO CHEMICALS

CORP.

)

PCB

73-397

PETITIONER

)

73-398

v.

)

73-~399

73—400

73—401

ENVIRONMENTAL

PROTECTION

AGENCY

RESPONDENT

RICHARD

J.

GOETSCH, ATTORNEY,

in behalf of AMOCO

THOMAS A.

CENGEL, ASSISTANT ATTORNEY

GENERAL,

in behalf of the EN-

VIRONIVIENTAL

PROTECTION

AGENCY

OPINION

AND ORDER OF THE BOARD

(by Mr.

harder)

This

case

comes

to

the

Board

on

amended

petitions

of

Amoco

Oil

Com-

pany for variances.

The original petitions were filed

as

follows:

PCB

73—397 and PCB 73—398 were filed September

24,

1973;

PCB 73—399,

400,

and 401 were filed September

25,

1973.

On September

26,

1973,

the

Board ordered the petitions for

73-397 and 73-398

inadequate because

they did not adequately relate the environmental consequences of the

variances if granted.

The Petition for 73-399 was inadequate in that

it

did not state the effects upon surrounding air quality of the emiss-

ion

of

2093

lbs.

of

sulphur

dioxide

during

a

two-hour

period

every

four

days.

The petitions

for 73-400 and

401 were not adequate

in

that no

statements

(except a conclusory

one) were given as to the effects upon

the environment and upon the public at large.

Amended petitions were

filed October 25,

1973.

PCB 73—397 requests a variance from Rule 205

(C)

of the Air Pollution

Regulations for the operation of an oil—water separator

(Area C separa-

tor), Operating Permit

#0

2 12 0447

I.D.# 119-115 AAE,

granted on Feb-

ruary

14,

1973, until June 30,

1974.

PCB 73-398 requests a variance

from Rule 205

(g)

of the Air Pollution Regulations for the operation of

a catalytic reforming unit (Permit

#0

2

11

0585 ID# 119

115 AAA

granted

on April

5,

1971)

until June

30,

1974,

PCB 73-399 requests a variance

from Rule 204

(F)

of the Air Pollution Regulations for operation of

a

multi—purpose additives plant

(Permit

#0

2 11 0588

ID# 119 115 AAA

granted on June 28,

1973)

until June

30,

1974.

PCB

73-400

requests

a

variance from Rule 205

(C)

of the Air Pollution Regulations for

a deter-

gent additive plant

(Permit

#0

2

11

0482 I.D.# 119 115 AAD, granted Feb-

ruary

7,

1973)

until June

30,

1974.

PCB 73-401 requests a variance from

10

--439

---

—2—

Rule

205

(G) of the

Air

Pollution Regulations for its multi-purpose add-

itive plant, mentioned in

PCB

73-399,

until

June

30, 1974.

The

Agency

recommendations

in

these

matters,

filed

November

14,

1973,

recommended

a

grant

of

the

variances.

The

matters

were

heard

during

con-

solidated

hearings

on

November

20,

1973.

Amoco

operates

a

refinery

located

in

Wood

River,

Madison

County,

Ill-

inois.

This refinery is capable of processing 110,000 barrels of oil

per day.

On

hearing

Mr.

E.

3. Sullivan, project engineer for air and water con-

servation

at

the

Wood

River

Refinery,

gave

the

major

part

of

the

testi-

mony.

Richard

B.

Schwendinger,

staff

ecologist

with

Amoco,

testified

as

to

the

effects

of

continued

emissions

on

tile

surrounding

area

should

Am-

oco

be

granted

these

variances.

P03

73—397

concerns

an

oil—water

separator.

This

unit

is

a

single

compartment,

gravity-type

oil

separator

that

services

Amoco’s

crude

run-

ning

unit

#5

and

catalytic

cracking

unit

#2

(R.

4).

The

oily

waste

from

these two units flows through

the

separator

where

oil

is

recovered

for

recycling

CR. 4).

The separator is completely covered with a steel plate

and vented through a 126 ft. stack to the atmosphere

CR.

5).

Water goes

through the unit at 300—400 gallons per minute and oil goes through it

at a rate of 4,000 gallons per day.

Contaminants discharged from this unit are 160 lbs/hr hydrocarbons

equivalent methane.

carbons

(Pet.

P.

2).

Control of the emissions will be through compression and condensation.

The

separator will be sealed airtight and’kept at a slightly positive

pressure to prevent the ingress of air into the unit, in order to prevent

explosions which are possible when air and hydrocarbons mix

CR. 6).

A

compressor will remove vapors from the stack, compress them, sending liq-

uids to be recycled and overhead gases to a smokeless flare, where the

hydrocarbons will be burned, creating carbon dioxide and water

CR.

6).

The

witness

testified

CR.

7)

and

the

Agency

agreed

in

its

recommenda-

tion

(P.

ions 100.

The

witness

also

alleged

that

there

was

no

other

method

to

bring

the

unit

into

compliance

without

closing

the

unit

down

CR.

7).

Should

the

unit

be

shut

down,

the

entire

refinery

would

have

to

be

closed

CR.

7).

This

would

mean

that

there

would

be

a

loss

of

production

of

105,000

bar-

rels

of

oil

per

day

CR.

8).

Since all of Amoco’s other refineries are

operating

very

near

capacity,

this

loss

could

not

be

recovered

CR.

8).

The

control

equipment

will

not

be

available

to

Amoco

in

time

to

comply

with

the

12/31/73

deadline.

Amoco

alleges

and

the

Agency

does

not

rebut

that

there

will

be

no

adverse

effect

on

the

environment

should

Amoco

be

granted

this

variance

•

No

actual

tests

had

been

run

on

this

unit,

but

Am-

oco

interpolated

from

tests

done

by

Air

Resources,

Inc

•,

run

in

December

1972

and

January

1973,

that

the

Area

C

separator

contributes

only

.008

10—440

---

—3—

ppm hydrocarbons

to the ambient

air.

This was determined by taking the

average one—hour concentration of non-methane hydrocarbons of

2,02 ppm.

The average 8-hour concentration was 2.08 ppm.

National standards

are

based on 3-hour samples.

Here Amoco has determined that their 3—hour

concentration would be about

2 ppm.

The national standard to

be ob-

tained by 1975

is

0.24 ppm.

Amoco

had

no way of determining

the

emiss-

ions

of

the

C

area

separator

because

of

the

complexity

of

the

refinery

itself and its numerous discontinuous

sources

of

hydrocarbon

emissions

as well

as the

fact that there are two other refineries

in the area.

Am-

oco

postulated

that

because

they

have

25

of

the

refining capacity,

they

contribute

25

of

the

hydrocarbons

or

.5

ppm.

Since

the

Area

C senarator

contributes

1.6

of

the

hydrocarbon

emissions

from

the

refinery,

this

un-

it

would

be

emitting

.008

ppm.

This

logic

is

by

no

means

definitive

of

the

actual

emissions

from

this

source.

The

basic

assumption

that

because

Amoco

has

25

of

the

refining

capacity,

it has

25

of

hydrocarbon

emiss-

ions

does not take into account numerous variables

such

as emission con-

trols

on other units.

Were these variances

for

a longer time

than

six

months,

or had the Agency questioned

these figures, which were

determined

by

a

method

which

cannot

be

assumed

100

valid,

additional data would be

required.

Without

Agency

rebuttal

the

Board

will

consider

Petitioner~s

figures

as

fairly

representative.

The

Board

notes

that

equipment

delivery

delays

are the

reason

for

many

variances

such

as

the

ones

presented

here.

Amoco

has

shown

a

dili--

gent

effort

to

bring

this

unit

into

compliance.

In

its

petition

Amoco

also

alleges

that

there

is

no photochemical smog

in

the

area

because

of

low

measures

of

oxides

in

tne

atmosphere

(Pet.

P.

5)

It

is

the

finding

of

the

Board

that

Amoco

has

met

its

burden

of

proof,

in

proving

unreasonable

hardship

and

minimal

environmental

impact.

PCB

73—398

concerns

a

catalytic

reforming

unit

which

processes

low

~

naphtha

material

from

the

crude

running

unit

and

catalytic-

ally

refonns

it

into

material

having

high-octane

qualities

for

blending

of

gasoline

(R.

11)

Emissions

from

the

units

are

hydrocarbons.

Points

to

be

controlled

in

the

unit

are

its

blow—down

system

and

3

other

points

in

the

reactors

(R.

11)

Control will be brought about by capping all

emission sources

and.

rout--

ing

the

vapor

to

a

smokeless

flare

to

be installed

in

the

refinery

(R.

12)

Evidence showed that this

control method will bring about

a

100

reduct-

ion

in the emissions

from this unit.

It was

also proved

that

certain

in-

ternal

changes

in

the

system

have

already

reduced

emissions

on

one

point

source

from

105

#/hr

to

18

lbs/hr

(R.

15)

.

The other embssion

from this

unit

is approximately

375 to

690

lbs.

of hydrocarbons

once

or twice

a

week.

The

only

way

Amoco

can

bring

this

unit

into

compliance

by

December

31,

---

—4—

1973,

is to shut it down

(R.

15).

Shutting down the unit would cause a

net loss in gasoline production

as the unit produces 8,000 to 9,000 bar-

rels of reformate

a day.

These statements constitute the alleged hardship.

Emissions from this unit were calculated to be

.0055 hydrocarbons,

using the same conjectural method used in PCB 73-397.

Amoco alleges

and the Agency concurs that the granting of this variance will not have

a hindering effect on progress toward achieving the 1975 Federal hydro-

carbon standard (Agency Rec.

P.

3).

There have been no complaints

from the public on this process

(Agency

Rec.

P.

7).

Again in this petition,

as

in the others, Amoco has shown diligent

effort to meet the scheduled compliance

date,

but because of problems

with suppliers and equipment delivery delays, they cannot meet these

compliance dates.

The

Board

finds

that

Amoco has met the burden of proof for a variance

under Section

35 of

the

Invironmental Protection

Act.

PCD 73-399 concerns

a multi-purpose additive plant.

This plant pro-

duces

a number of different additives for motor oil, diesel lube oil,

and specialty use additives.

The plant has five different sections and

produces

13 different products

(R.

18)

The

problem

here

is

with

sulphur dioxide emissions which are produced

when

the

plant

is

turning out

a sulphur scavenger.

This process takes

48

hours

per

batch.

During

the

process

it is necessary

to strip out one

of the reactants

and remove the hydrogen sulfide that

is formed in the

process.

These

materials

are

presently

being

disposed

of

by

flare,

but

this

burning

causes

sulphur

dioxide

(R.

18)

The

control

method

planned

for

this

unit

will route materials

from

the

plant

to

a

chiller.

The

material

will

then

pass

to

a

separator

where

the

liquids

will

drop

out

and

flow

to

a

receiver,

The

gas

will

then

pass

through

a

second

chiller

to

remove

all

of

the

liquid

from

the

gas.

From

there

the hydrogen sulfide will be transported

to

an existing

absorption

system,

where

it

will

be

disposed

of

(A.

19)

.

This processing

should

reduce

sulphur

dioxide

emissions

100

(R.

20)

This

project

has

been

delayed

and

cannot

be

completed

by

the

scheduled

compliance

date,

because

of

delays

in

receiving

the refrigerator equip-

ment

(R.

20)

Testimony

alleges

that

the

only

way

to

bring

the

plant

into

compliance

is

by

closing

it

down.

This would create

a severe shortage in LPG

gas,

in

which

the

sulphur

scavenger

is

used,

because according to testi—

mony

Amoco

at

Pood

River

is

the

sole

supplier

of

this

product.

Amoco

alleges,

and

the

Agency

agrees,

that

the

granting

of

this

variance

will

not

adversely

affect

the

quality

of

the

environment

around

the

plant.

The

data

provided

is

again

figured

by

the

same

method

as

used

in

the

hy-

drocarbon

data.

It

was

also

shown

that

no

adverse

effects

could

be

de—

10

—442

---

—~—

termined from the sulphur dioxide

emissions

to

plant

vegetation

or

to

workers in the plant or to citizens in areas surrounding the plant

(R.

38).

This source contributes

.0013 ppm sulphur dioxide

(R.

22).

The Agency in its recommendation

(P.

3)

states

that

Amocors control

program will aid in achieving the 1975 Federal Ambient Air Quality

Standard for sulphur dioxide.

Ambient

air

monitoring

indicates

concen-

tration of 0.438 ppm maximum 1 hour average

and 0.032

ppm

24 hr.

aver--

age, against a standard of 0.14

ppm

maximum

24 hr.

The Board finds Amoco has

met

its burden of

proving

hardship

and

cx--

plaining the lack of environmental harm

in the

instant case,

and

the

variance will be granted.

PCB

73—400 and

PCB

73—401 concern different units, but these

units

have the same type

of

emis~ibnproblems and control procedures proposed

(R.

31)

.

73—400 involves hydrocarbon emissions from a detergent additive

plant and 73-401 concerns the multi-purpose additive plant that was dis-

cussed in 73—399.

The problem emissions arise when filter aid is added to reaction ket-

tles, pre—coat mix tanks and filter pre-coat mix tanks.

The emissions enter the atmosphere when a nitrogen purge is added to

these tanks to allow the operator to add the filter aids

(R. 24-25), Hy-

drocarbons are carried off with the nitrogen and vented to the atmos-

phere.

Some of the tanks have uncontrolled nitrogen blankets which car-

ry hydrocarbons off to the atmosphere

(R.

25).

The proposed control method for those units will make these

a closed

handling system wherein the nitrogen blanket and filter aid addition

will be done automatically and under pressure

(R,

25-27).

The work is scheduled to be completed on these units around April 1,

1974

(R.

27).

The reason for this late date is delay in receiving mat-

erial and equipment delivery from suppliers

(R.

28).

Testimony showed and was not rebutted that if these variances are not

granted, the only way Amoco can comply with the regulations is to close

down the units

(R. 28,

33).

It

is alleged that to close down the units would cause Amoco, and

those it supplies, to go out of the motor oil business.

This

is because

of the delay in getting new sources of additives and testing them with

the produced oil.

Such testing would take longer than the period of

these variances

(R.

29-34).

The Petitioner has brought forth figures based on the method used in

PCB 73-397 to determine that the detergent additive plant emits

.002 ppm

hydrocarbons

(R.

32) and the multi-purpose additive plant emits

.0075

ppm hydrocarbons

(R,

29).

The Agency in

its

recommendation believes

that Amoco is dealing with the problem in good faith

and that these

emiss

ions will not hinder the attainment of the Federal Air Quality Standards

10

—

443

---

—6—

by 1975.

The Board

will

grant a variance for the equipment outlined in PCB

73—400 and 73—401.

It is

truly unfortunate that variance cases such

as these

must be

determined

on

records

that

are

very

difficult

for

the

Board to deal

with.

Were

it

not

for

the

fact

that Amoco will be

bringing

the

sub-

ject

units

into

complete

compliance

and

the

fact

that

these

variances

are

for

a

short

period

of

time,

the

Petitioners

would

be

required

to

provide

more

definitive

environmental

impact

statements.

In

granting

a

variance,

it

is

the

duty

of

the

Board

to

weigh

the

hardship

of

Petitioner

against

the

effect

the

variance

will

have

on

the

community.

In

this

record

the

data

on

environmental

impact

to

the

community

is

mostly

conclusory.

The

Board

would like to see sup-

porting

documents

as

to

the

way

environmental

impact

is

determined.

The Board needs

facts, not conclusions

or assumptions,

on which to

base

a

decision.

Should

Amoco

petition

for

extension

of

this

vari-

ance or future variances for the Wood River Refinery, thorough stud-

ies of

the

environmental impact,

or source data

as to conclusions

stated in this matter, shall be presented before the Board will con-

sider giving a favorable ruling.

This Opinion constitutes the findings of fact and conclusions of

law of the Board.

ORDER

IT

IS

THE

ORDER of the Pollution Control Board that:

I.

A variance is granted Petitioner from Rule 205

(C)

for the oper-

ation of an oil-water separator (Permit

#

0

2 12 0447 ID# 119 113

AAE)

until June 30,

1974,

or until

its

control program is completed, which-

ever is sooner.

Petitioner shall apply for all necessary operating

and construction permits for this project and shall notify the Agency

upon completion of the program.

2.

A variance is granted Petitioner from Rule 205

(g)

for the oper-

ation of

a catalytic reforming unit (Permit

#

0

2 11 0585 ID# 119 115

AAA)

until June 30,

1974,

or until its control program is

completed,

whichever

is

sooner,

Petitioner shall apply

for all

necessary opera-

ting and construction permits

for

this project and shall notify

the

Agency upon completion of the program.

3.

A variance is granted Petitioner

from Rule

204

(F)

for the

oper-

ation

of

a multi-purpose

additive

plant

(Permit

#

0

2 11 0588

ID# 119

115

AAA)

until

June

30,

1974,

or

until

its

control

program

is

completed,

whichever

is

sooner.

Petitioner

shall

apply

for

all

necessary

operating

and

construction

permits

for

this

project

and

shall

notify

the

Agency

upon

completion

of

the

program.

IO—-444

---

—7—

4.

A variance is granted Petitioner from Rule

205

(g)

for the op-

eration of a detergent additive plant

(Permit

#

0

2 11 0482 ID# 119

115

AAD)

until June

30,

1974, or until its control program is completed,

whichever is sooner.

Petitioner shall apply for all necessary operating

and construction permits for this project and shall notify the Agency

upon completion of the program.

5.

A variance is granted Petitioner from Rule

205

(g)

for the oper-

ation of

a multi-purpose additive plant

(Permit

#

0

2

11

0588 ID# 119

115 AAA)

until June

30,

1974,

or until its control program is

completed,

whichever is

sooner.

Petitioner shall apply for all necessary operating

and construction permits for this project and shall notify the Agency

upon completion of the program.

6.

Respondent shall, within thirty days from the date of this Order,

post

a performance bond in a

form satisfactory to the Agency in the

amount of $50,000, guaranteeing installation of air pollution control

equipment as ordered above.

IT IS SO ORDERED.

I,

Christan L. Moffett, Clerk of the Illinois Pollution Control

Board, certify that the above Opinion and Order was adopted by the Board

on the 20th day of December,

1973, by a vote of

5 to

0.