ILLINOIS POLLUTION CONTROL BOARD
July 10,
1980
MOBIL OIL CORPORATION,
Petitioner,
v.
)
PCB 80—53
ILLINOIS ENVIRONMENTAL
)
PROTECTION AGENCY,
)
Respondent.
OPINION AND ORDER OF THE BOARD
(by
I.
Goodman):
On April
15,
1980 the Petitioner,
Mobil Oil Corporation,
filed
a Revised Petition for Variance Extension.
Petitioner
seeks an extension of the variance from Rule 408(a) of Chapter
3:
Water Pollution (hereinafter, Chapter
3) granted to it in PCB
78—277.
The Petitioner has waived a hearing in this matter.
The
Illinois Environmental Protection Agency (Agency) recommends that
Petitioner be granted a variance from Rule 408(a) of Chapter
3,
as
it pertains to cyanide,
until December
31,
1981 subject to
specified conditions.
Pursuant to the Board*s Procedural Rule
402(a), the Petitioner has requested that the record from the
prior variance proceeding
(PCB 78—277) be incorporated into the
record.
The request is granted.
Petitioner owns and operates
a conventional petroleum fuel
refinery in Channahon
Township, Will County, Illinois.
The
facility utilizes water from the Des Plaines River for boiler
feed, cooling tower makeup,
and as once—through, non—contact
cooling water.
Process water from the refinery is subjected to
pre—treatment and final
treatment before being discharged into
the Des Plaines River.
The Board has granted Petitioner a variance from cyanide
limitations on six previous occasions.
The most recent variance,
was granted on February 1,
1979 and extended until July 1,
1980.
Petitioner in its February 25,
1980 progress report stated that
additional control measures had been installed and that monitors
were in operation.
The
report also indicated that
a test of
ammonium polysulfide injection into the fluidic catalytic cracker
(FCC) unit to evaluate the conversion of cyanides to biodegradable
thiocyanates would be conducted.
Petitioner is currently studying bio-nitrification to
determine whether it contributes to cyanide excursions.
The
nitrification treatment facility appears to reduce the cyanide
levels and then release cyanide in a slug load when nitrification
—2—
rates are high; therefore, Petitioner has concluded that
fluctuations in the bio—system pH during nitrification may
be
one of the primary eontributing factors in the release of cyanide
from the biomass.
Furthermore,
studies
indicate that nitrate
ions cause a positive interference with the total cyanide test.
Petitioner is currently determining whether this phenomenon is
causing its reported cyanide excursions.
Despite effluent level excursions, cyanide concentrations in
the
river mixing zone have remained very low.
Upstream and
downstream
monitoring reports indicate that the
refinery is not
adding significantly to cyanide levels
in the Des
Plaines River.
The Board
finds that an arbitrary
and unreasonable hardship
would be imposed upon the Petitioner
if the variance extension
were denied.
The lack of available control technology for
cyanide, the good faith efforts of the petitioner,
and the
absence of noticeable harm to the environment convince the Board
that the petitioner should he granted a variance
from Rule 408(a)
of Chapter
3 until December 31,
1981 subject to conditions
included in the Order herein.
The Will County Health Department responded to the variance
petition with a letter pointing out the existence of recreational
uses of the Illinois River downstream from Mobil and requesting
that the Board consider the hazards of cyanide with respect to
other uses of the stream,
The Board commends the interest taken
by the Health Department on behalf of the citizens but,
nevertheless,
finds that the total discharge levels
in this case
are
so small that any potential harm downstream is de minimus.
This Opinion constitutes the findings of fact and
conclusions of law in this matter.
ORD
ER
It is the Order
of
the Illinois Pollution Control Board
that:
I.
Petitioner,
Mobil Oil Corporation, be granted a variance
from Rule 408(a) of Chapter
3 until December 31,
1981,
subject
to the following conditions:
a.
The cyanide effluent discharge level shall
not exceed
a monthly average of 0.2 mg/i and a daily maximum of
0.37
mg/l,
with the exception that Petitioner shall be allowed
one excursion per month above the daily maximum which
shall not exceed an absolute level of 1,5 mg/i.
b.
Petitioner shall continue to submit progress reports
to the Agency in the same manner as required by previous
variances for this facility.
—3--
2.
This variance shall
terminate if Petitioner demonstrates
to the Board that,
under the same facts as herein, positive
interference during the testing procedure is the sole cause
for cyanide readings to exceed the limitations
in Rule 408(a)
of Chapter 3.
3.
The Illinois Environmental Protection Agency is
authorized to modify Petitioner’s NPDES permit to be
consistent with the terms of this variance, including
granting permission for the use of sulfamic acid in testing
for cyanide
levels.
4.
In the event that Petitioner discovers the cause or
causes of its cyanide excursions,
it shall immediately
notify the Agency thereof, and within a reasonable time
thereafter,
submit to the Agency a program to achieve
compliance with Rule 408(a) of Chapter
3 as
it pertains to
cyanide.
5.
Within 45 days after the date of this Order, Petitioner
shall execute and forward to the Illinois Environmental
Protection Agency, Division of Water Pollution Control,
Compliance Assurance Unit,
2200 Churchill Road,
Springfield,
illinois 62706 a Certification of acceptance and agreement to
be hound to all terms and conditions of the variance.
This
45—day period shall
be held in abeyance for any period during
which this matter
is appealed.
The certification shall be
as
follows:
CERTIFICATION
Mobil Oil Corporation hereby accepts and agrees to be bound by
all terms and conditions of the order of the Pollution Control
Board in PCB 80—53 dated
____________________
—
Petitioner
By
,
Authorized Agent
Title
Date
I, Christan L,
Moffett,
Clerk of the Illinois Pollution
Control Board, hereby certify that th~above Opinion and Order
wer~adopted on the
Jb~”
day of
1980 by
a vote
of
..~-
D
