ILLINOIS POLLUTION CONTROL BOARD

January

10,

1980

CLARK OIL

& REFINING CORPORATION,

Petitioner,

V.

)

PCB 79—181

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

MR. JOHN T. BERNBOM APPEARED ON BEHALF

OF PETITIONER;

MS. ALICE

NUSSBAUNI, ASSISTANT ATTORNEY GENERAL, APPEARED ON

BEHALF OF

RESPONDENT.

OPINION

AND

ORDER OF THE BOARD

(by Mr. Goodman):

On August

31,

1979 Petitioner Clark Oil

& Refining Cor-

poration

(Clark) filed a petition for variance before the Board

requesting Variance from Rules 204(f)(1) and 205(g)(l) of

Chapter

2:

Air Pollution Control Regulations

of the Illinois

Pollution Control Board as they apply to Clark’s Blue Island

refinery

located at 131st and Kedzie, Blue Island, Cook County,

Illinois.

The Environmental Protection Agency

(Agency) filed

its recommendation and hearing was held on November

27,

1979;

no citizens appeared at hearing and the Board has received no

public comment

in this matter.

On October

30, 1979 Clark filed

an amendment

to the petition withdrawing Clark’s request

for a

variance from the hydrocarbon standards

of Rule 205(g)(1)(C)

due to the fact that compliance has been achieved by Clark;

therefore, variance from the hydrocarbon limitation i~no longer

necessary.

The subject facility

is

a low sulfur oil refinery which

processes approximately 70,000 barrels

of crude oil per day

utilizing

a fuel gas

desulfurization process known as the

Stretford technology which converts the hydrogen sulfide gas

into elemental

sulfur.

Prior to

1970, the facility had a

history of odor emissions which were predominantly composed of

hydrogen sulfide

gas.

In the early 1970’s

a survey of the

facility’s

fuel gas system determined

that the sulfur dioxide

emission levels from the refinery were in compliance with the

existing standard.

Due to an increasing sulfur content of its

incoming crude oil and due to an increasing number of odor

complaints, Clark decided that sulfur removal from the fuel

37—125

---

gas system would he required for future compliance.

After

evaluation of various sulfur removal technologies,

the Stret—

ford process of desulfurization was chosen.

The equipment was

put

in operation

in April

of

1976,

After

a short period of

operation Clark discovered that the fuel gas desulfurization

system was experiencing numerous problems and that the facil-

ity was not

in compliance with the hydrocarbon emission

standards of Rule 205(g)(1)(C).

Clark developed a program

to redesign and modify the sys-

tem which was completed

in 1978 at an approximate cost of

$250,000.

Subsequent test results indicated compliance with

the standards;

however, the redesigned system proved to be

unreliable and was incapable of continuous desulfurization

of

the off gases due to previously existing mechanical chemical

and biological problems with the Stretford unit.

Clark now

proposes a new program which

it is confident will correct the

operational problems of the Stretford unit and will improve

the system’s effectiveness consistently with continuous com-

pliance with the sulfur dioxide standard.

If at the end of

this proposed program compliance

is not obtained,

Clark will

stop financial commitments to the unit using the Stretford

process and will proceed with replacement of the unit using

other sulfur removal

technology.

In its investigation the Agency solicited views of persons

who might be adversely affected by this variance petition and

received no responses.

No complaint has been reported to the

Agency since a single complaint was logged in June 19,

1978,

In its recommendation the Agency agrees with the facts as

alleged by Clark in its petition and amendments thereto.

The nearest sulfur dioxide monitoring station is

located

at Eisenhower High School in Blue Island,

which is approxi-

mately one—half mile north of the facility.

In 1978 only one

excursion of the 24—hour primary standard was recorded,

so

that the Blue Island site

is considered not in violation of

this ambient air quality standard,

The

annual arithmetic mean

reported at the sampling station

for 1978 was 0.016 ppm,

whereas the primary ambient air quality standard for sulfur

dioxide

is 0.03 ppm.

This one excursion for the 24—hour

maximum concentration was recorded at 0.164 ppm, whereas the

primary ambient air quality standard for the 24—hour maximum

concentration

is 0.14 ppm.

Worth Township

is presently

unclassified

as either an attainment or a nonattainment area

as

to sulfur dioxide.

Allowable sulfur dioxide emissions under Rule 204(f)(1)(A)

are 2,000 ppm or 724 tons per year.

The Agency estimates that

the maximum sulfur dioxide emissions

from the Blue Island

facility when the Stretford unit

is not in operation are 2,489

ppm,

or 901 tons per year.

Since there were no ambient air

quality violations during the numerous times that the sulfur

37—126

---

dioxide emission standards were exceeded due to malfunctions

of the facility, and since

it

is expected that there will be

fewer excursions of the sulfur dioxide standards as Clark

corrects the problems, the Agency believes that a variance

will not result

in a violation of the ambient air quality

standards.

Clark alleges that

it

has

spent sizeable amounts of money

and considerable effort to properly operate the Stretford unit

so as to meet the present standards,

The Stretford process

unit was originally installed due to the

limited area of space

available for installation

of desulfurization equipment,

If

the proposed variance is not granted,

Clark alleges that it

will be forced to abandon

a project that has cost approximately

$5

million and a technology that may provide alternatives for

other small refineries,

Clark further alleges that

any

other

alternative technology for sulfur removal will take until 1982

to become operable and will cost approxir~ately$8 million.

The Board finds

that

denial of

the

proposed variance

would impose an arbitrary and unreasonable hardship upon Clark.

Clark

is attempting to utilize an innovative process

to desul—

furize

the

off gases of one process in order to utilize them

as fuel for other processes,

One alternative available to

Clark

is

to

flare

off the sour process off gases and use

natural gas or low sulfur fuel

oil

in

its

refinery combustion

units,

The alternative of

flaring a useful energy source and

utilizing natural gas and/or lower sulfur fuel oil

as the

energy source

for the other processes is to the Board not only

unreasonable, but a wasteful

use

of energy sources

that

are

presently

in short

supply.

The evidence indicates that the

harm to the environment should

the

proposed variance be granted

would be minimal,

On

balance,

the

Board finds that granting

the variance to allow

Clark

to perfect the Stretford process

of fuel gas desulfurization is the most beneficial resolution

of

this situation,

The Board therefore grants

variance from

Rule 204(f)(1)(A) until

June

30, 1981

under certain conditions,

This Opinion constitutes the findings of fact and conclu-

sions

of law of the Board

in this matter,

ORDER

Finding that Clark Oil

& Refining Corporation

is unable

to comply with the Board~sregulations

at this time and finding

that the proposed variance will not interfere with the attain-

ment or maintenance of ambient air quality standards

in

the

area,

the Board hereby grants variance from Rule 204(f)(1)(A)

until June

30,

1981 for the Clark Oil

& Refining Corporation

facility at Blue Island,

Cook County,

Illinois,

under the

following conditions:

37—12 7

---

—4—

A)

Emissions of sulfur dioxide into the atmosphere from any

process emission source shall not exceed 2500

ppm

time.

B)

Clark Oil

&

Refining Corporation shall execute the com-

pliance

program

contained

in

Exhibit F to this proceeding,

which

Exhibit is hereby incorporated by reference as if

fully set forth herein.

C)

Clark

Oil

&

Refining

Corporation

shal 1

submit

program

reports on a monthly basis to the Illinois Environmental

Protection Agency, 2200 Churchill Road, Springfield,

Illinois

62706, relating the present operating condition

of the fuel gas desulfurization

unit

and

the status of

the

compliance

program.

D)

If the fuel gas desulfurization

system

is not operable

so as to achieve continuous compliance with the sulfur

dioxide standards by the end of the term of this variance,

Clark Oil

&

Refining Corporation shall

submit

a plan to

the Agency regarding

an

alternative

technology

for

treating

the subject process off gases.

E)

within 45 days of the adoption of this Order, Clark Oil

& Refining Corporation shall execute and forward to the

Illinois Environmental Protection Agency at the address

listed in paragraph

(C) above, a Certification of Accep-

tance and Agreement to be bound to all of terms and con-

ditions of this Order.

The

45

day

period

shall

be

held

in

abeyance

during

any

period

this

matter

is

being

appealed.

The

form

of

said

certification

shall

be

as

CERTIFICATION

I

(we),

________________________,

having

read

and

fully understanding the Order of the Illinois Pollution Control

Board in PC 79—181, hereby accept said Order and agree to be

bound by all of the terms and conditions thereof.

SIGNED _______________________

TITLE

_________________________

DATE

IT

IS

SO

ORDERED.

37—128

---

I, Christan L~Moffett, Clerk of the Illinois Pollution

and Order were

adopted on the

~

day of _______________________

_________

___________________________,

1980

Control Board,

here)Dy certify th~~~~pinion

by a vote of

~j~p

Christan L, Moffe~

Illinois Pollution Control Board

n

~7—129