T’XACO fl~C

(LO ‘KP3RI RFFINFR

PL~IlIIONER

~ a

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ci a 

pet

t x ~ I~xa~ In

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r ~u1e O~ 

i a a a aye ~t

un~

LO- OOt~

ne

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c3~r ~

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g r t

fecommend t

i~led

7’

T~e Loc Tort rc ir~r

has a

cap

rackarg

Jiarge eoct~

called coas dr~n~

as aug oae ation waiT o~y

ore aruir te~ne used ~t a a u~ 1

o ~‘har o a routed

a di r

where rackirci tat

~ e~3) of tTc ~ra

ano ~omc of

tue c~argc a laid

OvL

a Lhe dir

1h aapo~ pr case t

the iractionatana

ow~x for ccpa~at n

Wher ~e batck is eompl~cd

LTe drum a~ complete~y ± II of por r ~ohe

A thas point

there

no f rther _np~t iito

Trur

vapors a

stal) goirg off t

the frac ronating tower fo: p oceslng

At this

oiut b1owdo~n f

the uni~ takes places

yap ~s are erouted t a blowdown k~o Y-~

out drum

Steair is ther ~njected

into the druri to purge the vapors

from the coke drura~ Then the aag r is water~cooled in the blowdowr~

quench drums Part of the vapo~ are liquefied and are i~scharged

to the sewers

The renai~arg vapor’~ are discharged to the atma

phere and are the vaporr ar quest o~

Vapor emissions o~hydrocarooru~ are as foI1ows~ 253~4 lbs/hr. 

—

301

31,500 ppm.. The 

limit 

set in Rule 205 (g) (2) is 10 ppm.. Such emiss-

ions are of a periodic nature, existing only when the unit is being

blown down..

The control proposed for these vapor emissions is a knockout pot

to

collect and condense the vapors further.. Non-condensable vapors

will then be routed to a smokeless flare.

Petitioner~s compliance schedule 

to

complete installation 

of

the

proposed equipment is as follows:

Jan.. 28, 

1974

Apply 

for

IEPA 

construction 

permit

Feb.. 22, 

1974

Contract for concrete construction

to

be awarded (other construction

work 

to be done by in—house per-

sonnel)

March 15, 1974    

Start construction

Sept.. 1, 1974     

End construction

Sept.. 1, 1974     

Start operations

This project is, estimated to cost $80,000..

The Board takes notice of the fact that though Rule 205 (g) (2)

went intc effect on December 31, 1973, a permit ~.oconstruct 

this

equipment 

was

not applied for 

until 

January 28, 1974, a month later..

Nowhere (Ices Petitioner allege any reason for this delay. Attached

to the Petition is a chart indicating that this project has 

been in

the

works since May of 1972. The Board fails to understand why in-

itiating the construction of this project did not begin until 22

months after initial consideration was given by Texaco to this pro-

ject. It appears that there is no new or novel technology being

used to control this emission source.. This Board cannot speculate

as to why this project could not have been accelerated to meet 

the

December 31, 1973, deadline. While there may have been acceptable

reasons for this delay, the Petition is devoid of such evidence.. It

is clearly the burden of Petitioner to supply such data, and without

it the Board must find that Petitioner has failed to establish due

course for the grant of variance..

Hardship:

Petitioner alleged that it would suffer unreasonable and arbitrary

hardship if this variance is not granted? for the reasons that follow..

1, It cannot comply with Rule 205 (g) (2) before September 1,

1974, because of fixed delivery dates from equipment vend-

ors, beyond Petitioner~s control..

2. A shutdown of the unit from May 

1,

1974, until September

1, 1974, would decrease production by 960,000 barrels of

gasoline, 678,000 barrels of middle distillate, and 28,320

tons of coke. Backup in tankage causes a loss of 184,000

barrels of recovered gas oil. These products would be lost

to the public and would cost the Petitioner $1,376,322. Pet-

itioner would have to lay off 22 persons for four months and

31 persons for one month..

13— 302

The hardship case 

thus rests 

on

th~epossibility of 

an enforcement

action being filed should Petitioner/fail 

to

cease operations in vio-

lation of Rule 205 (g) (2).. 

It must be 

noted that even 

if

this Board

were to grant variance, Petitioner 

is

still liable to enforcement

for the period of January 1, 1974, 

to

April 2, 1974 (the date of fil-

ing of the original variance petition).. This Board cannot help but

wonder why, if Petitioner is concerned with possible enfOrcement act-

ion, they waited until April 2, 1974, to file for variance, If the

project for abatement was initiated in 1972, Petitioner should have

filed its petition by October 1, 1973, to assure itself total protect-

ion. Surely Petitioner was aware that 

it

would not be in compliance

by December 31, 1973.. Therefore, Petitioner by its own inaction has

left itself open for enforcement proceedings for a significant per-

iod of time. In 

light of this the Board’must 

find that Petitioner

has not met its burden of proof regarding hardship, or even that such

hardship was not self-imposed.

Environmental 

Impact:

Petitioner alleges that there will be no injury to the public from

the grant of this variance, 

that its emissions do not contribute

to photochemical smog.. Air monitoring performed for Petitioner 

by

Air Resources, Inc., taken between November 19, 1973, and December 17,

1973, showed the following results:

Ill, ppm

Pollutant    

Ambient Air   

~n~~Con~ibution    

Standard

Oxidants      

0.059        

0,001        

0.08

NO~

0.017        

0.001        

0.05

No data 

presented 

to show how the refinery

contribution was cal-

culated,

Petitioner alleges that 

its discharges will not contribute

to photo-

chemical smog.. This conclusion is 

based on tests which show that less

than five percent of 

its emissions are olefinic compounds. This

con-

clusion, however, is not sufficient 

to meet

the criteria as outlined

in Chapter 2 of the Board Rules.. 

The definition of photochemically

reactive material includes three distinct categories of organic emiss-

ions. Petitioner explores only one 

—

olefinics. There is no mention

of aromatics of eight carboh 

atoms or

more, 

or of ethylene, branched

hydrocarbons, or 

toluene.. ~The 

combination of any

of the 

above may 

not

exceed 20, nor can 

the aromatics alone exceed 8 to be considered

non-photochemically reactive.. Without such data the Board cannot accur-

atel~assesss the contribution such vapors will add to the potential of

photochemical smog.

The Board takes note of the recent high ozone levels in the Chicago

major metropolitan areas.. As such we must be even more aware that

photochemical smog can no longer be assumed a potential problem, but

one which becomes more real as time goes on..

On April 4 an Agency inspector noted no odors outside the refinery

boundaries. The refinery is in an industrial area with no residential

buildings within 1/4 mile of the facility.. The Agency has received

no citizen complaints..

13

—

303

rt~

~ mb

ho So id

o icasor

nu~ coral da U

or:

fo~ TO

urar

a a ~r

tha

a a ci as

are e

emertal

ro~ U a

a or

P~tm

i,i

~~or

Te ar cut

~“i

a ~y

deq aU o

ta a’~ ra~e x r giaa

e t

d ~ort ose ar

rru~ Cc

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w le

ch ate nay ear St at las

do a ~l

p esented

e So r

TU ‘a~ian e v all cc U

o:e

di e ~o alio

00t ~ ne to ‘~eir~tiate ~his proceed ro ~r 3

a a adequate pro

r ror

arpose~ delay

U a

rIm a

~ non cors ~‘t ~

lard

IT IS THE OR~U f tIe So 1 at

octro

3oa I

pel-itior. for

~n e ~Ueb

apra~

1951

‘~ —~

withoU

prejudice

1, Chris~an L.. Moffett, Clerk of tIme ~ lano s P Ilution ContoU

Board, o~rtafy that the above OpanUn a d drder ‘gas adoptea by ~he

Board on the 8th 3c~y of August, 1 4, by a vot~ f 4 to 0

13— 304