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UNO—VEN
)
R93—8
TO AMENI)
PECULATIONS,
)
(Pull emak
inq)
PERTAINNC
TO
WATER
POLLUTION
Proposed Rule.
First
Notice.
OPINION AND ORDER OF
THE
BOARD
(by
B.
Forcade)
On January
28,
1993,
UNO-VEN Company
(UNO-VEN)
filed
a
petition requesting amendments to the site-specific regulation
found at Section 304.213.
A hearing was held on April
28,
1993
in Bolingbrook,
Illinois.
Members of the public attended the
hearing.
On August
17,
1993,
UNO-VEN
filed
a motion for decision.
The motion requests the Board to propose the rulemaking for first
notice.
UNO-VEN indicates that the existing site—specific rule
will expire at the end of the year.
UNO—VEN claims that
if the
Board does not proceed to adopt the proposed rule,
UNO-VEN would
need to pursue other relief.
The Board grants UNO—VEN’s motion
and proceeds to send this rule to first notice.
UNO—VEN is proposing four changes to the site—specific rule
change granted
in 1987 found in Section 304.213:
(1)
change
Union Oil of California to TJNO—VEN to reflect
a change
in
ownership;
(2) add a concentration—based limitation for ammonia
nitrogen on
a monthly basis;
(3) require a report on nitrogen
in
feedstock within 60 days after the end of the calendar year; and
(4)
to extend the expiration date of the rule until December
31,
2001.
(Pet.
at 3.)
The Board granted the site—specific rule
found
in Section 304.213 to Union Oil of California on March 19,
1987
in Docket R84—13.
UNO-VEN operates a petroleum refinery located
in Will County
near Lemont,
Illinois.
(Pet.
at 5.)
The refinery produces
approximately 25 different products of which ninety-five percent
of the output goes
into making automobile gasoline,
diesel fuels,
home heating oils and turbine
fuels used in the Midwest.
(Pet.
at
6.)
The refinery has a current rated capacity of 153,000 barrels
per day and employs approximately 750 people.
(Pet.
at 6.)
UNO-VEN currently discharges to the Chicago Sanitary and
Ship Canal
(Canal)
which
is
a tributary to the Illinois River.
(Pet.
at
4.)
UNO-VEN currently takes approximately 4.4 million
gallons of water from the Canal daily and discharges
approximately
3.8
million gallons
to the Canal.
(Pet.
at
6.)
The
difference
is due to cooling tower evaporation and steam
losses.
(Pet.
at
6.)
UWO—VEN
reports
that
the
:3.0
mg/i
NH~—N
state
ef
fluent
level
1
i m
t
has
not
been attainable
on
a consistent
basis.
(Pet
.
at
7.)
The
site-specific
rule
making granted
in
1987
required
the
refinery to continue
its efforts
to reduce the concentration of
ammonia nitrogen
in its wastewaters.
(Pet.
at
10.)
UNO-VEN has
continuously upgraded its wastewater treatment plant to comply
with this requirement.
(Pet.
at
10.)
UNO—VEN has spent
in excess
of
$4.2 million on
improvements to the wastewater treatment
plant.
(Pet.
at
11.)
UNO-VEN has improved the plant’s performance at ammonia
removal despite higher nitrogen content
in the crude
oil,
a
higher crude throughput,
and a decrease
in wastewater volume.
(Pet.
at 13.)
From 1986 to 1991,
the annual average ammonia
concentration declined from 22.2
to 2.4 mg/l,
a 89
reduction.
(Pet.
at
13.)
This decrease was achieved despite a higher
nitrogen content in crude
oil,
a higher crude throughput,
and a
decrease
in wastewater volume.
(Pet.
at 13.)
A consultant’s report concludes that the following
technologies have the greatest potential for meeting the
standard:
-
activated sludge with powdered activated carbon treatment,
-
activated sludge with fluidized bed reactor; and
-
activated sludge with granular media filtration and ion
exchange.
(Pet.
at
14.)
The costs of implementing these technologies range from
$7,094,000 to $18,382,000 with operating and maintenance costs
from $1,444,000 per year to $1,913,000 per year.
(Pet.
at
14.)
it
is anticipated that the fluidized bed reactor would have a
unit cost of $240 per pound of ammonia removed.
(Pet.
at 16.)
The consultant does not recommend that tJNO—VEN pursue any of
these alternatives.
(Pet.
at
14.)
The consultant concluded that
ongoing improvements to the wastewater treatment facility have at
least as great
a prospect of reducing ammonia nitrogen levels as
the alternate technologies.
(Pet.
at 14.)
Studies performed for UNO-VEN show that the discharge has no
substantial impact upon dissolved oxygen levels.
(Pet.
at
19.)
UNO-VEN further maintains that requiring compliance with the
ammonia nitrogen standard would not result
in
a measurable
improvement
of the Illinois River System.
(Pet.
at
19.)
At hearinq UNO-VEN presented testimony from William Busse,
Lee Erchull, James Huff and Robert
N.
Stein.
Mr. Busse
is the
supervisor
of environmental services
at UNO—VEN.
lie
testified
on
the status
ol
the
LJNO—VFN
ref
i
nery
in
relat
ion
to
the
requested
site—specific rule.
Mr.
Erchul
is
the senior environmental
specialist
for UNO-VEN.
lie testified
on UNO-VEN’s progress
in
removing ammonia
from
its
wastewater
in an effort to comply with
the ammonia
standards.
In particular,
he explained changes
to
the
wastewater
treatment
plant
and changes
in the sour water
stripper.
Mr.
Stein
is
an environmental
consultant
with AWARE
Environmental
Inc.
He testified
on an evaluation performed on
UNO-VEN’s
waste
water
treatment program.
This evaluation found
that UNO-VEN has a state-of-the-art wastewater treatment system
which exceeds Best Available Technology criteria.
However,
the
data shows that UNO-VEN
is unable to consistently and reliably
attain the ammonia nitrogen limitation of 3.0 mg/l.
The study
also included~anevaluation of additional technologies for the
removal
of ammonia.
However,
additional studies are needed
before any decision could be made concerning additional treatment
plant controls.
Mr. Huff of Huff
& Huff Inc.,
an environmental consultant,
testified on a 1992 study on ammonia discharge at UNO-VEN.
The
study shows a reduction in the ammonia discharge since the 1984
site specific rule was adopted.
The study also found no
localized impacts from the discharge during a stream
investigation.
He also notes that UNO—VEN is continuing to
pursue means of further decreasing the ammonia discharge.
On June
21,
1993,
the Agency and UNO—VEN filed a joint
comment recommending changes to the site—specific rule as
proposed.
The proposed changes included using
a daily maximum
limit for ammonia nitrogen of 26 milligrams/liter
(m/l)
and a 30
day monthly average limitation of 9.4 m/l.
The comment also
changes the date of termination of the site specific rule to
December 31,
1999.
Included with the comment were exhibits in
support of the recommended changes.
CONCLUSION
The Board agrees that site—specific relief
is appropriate,
based on the record of this proceeding.
UNO-VEN has attempted to
achieve compliance by modifying
its wastewater treatment system
and studying alternate technologies.
While these efforts have
substantially reduced the ammonia nitrogen discharges,
compliance
with the effluent limitation
is still not obtainable on
a
consistent or reliable basis.
The rule the Board today proposes
for first notice
is the rule proposed by UNO-VEN
in
its petition
with the modifications agreed to between the Agency and UNO-VEN.
U
N I.) N N
The
Board
di rec:ts
the
Cloth
to
cause
the
filing
of
the
following
proposal
for
First
Notice
in
the
Illinois
Register.
TITLE
35:
ENVIRONMENTAL
PROTECTION
SUBTITLE
C:
WATER
POLLUTION
CHAPTER
I:
POLLUTION
CONTROL
BOARD
PART
304
EFFLUENT
STANDARDS
SUBPART
B:
SITE SPECIFIC RULES AND EXCEPTIONS
NOT OF GENERAL APPLICABILITY
Section 304.213
UNO-VEN Refinery Ammonia Discharge
a)
This Section applies
to discharges
from Union Oil
Compan~.of
California-’-~UNO—VEN’~Chicago Refinery,
located
in Lemont into the Chicago Sanitary and Ship
Canal.
b)
The requirements
of Section 304.122(b)
shall not apply
to the discharge.
Instead Union UNO—VEN must meet
applicable Best Available Technology Economically
Achievable
(BAT)
limitations pursuant to 40 CFR 419.23
-(1985)
(1992)
incorporated by reference
in subsection
(c).
UNO-VEN shall also meet a monthly
average
limitation for ammonia nitrogen of 9.4 mg/i and a daily
maximum limitation of 26.0 mg/i.
c)
The Board incorporates by reference
40 CFR 419.23
-(-1985)
(1992)
only as
it relates to ammonia nitrogen as
N.
This
incorporation includes no subsequent
amendments or editions.
d)
Union
UNO—VEN
shall continue its efforts to reduce the
concentration of ammonia nitrogen
in its wastewaters.
e)
Union UNO-VEN shall monitor the nitrogen concentration
of
its oil feedstocks and report on an annual basis
such concentrations
to the Agency.
f)
Union UNO—VEN shall submit the reports described
in
subsection
(e)
no later than ~-9 60 days after the end
of
a calendar year.
g)
The provisions
of
this
Section
shall
terminate on
December
3l,-~
1999.
5
IT
IS SO ORDERED.
I,
Dorothy M.
Gunn,
Clerk of the Illinois Pollution Control
Board, hereby certify that the above opinion and order was
adopted on the
~
day of
~
,
1993,
by
a vote
of
7-~
/-~/~
~
~‘
;C.
Dorothy
M.
~unn, Clerk
Illinois Pollution Control Board