ILLINOIS POLLUTION CONTROL BOARD
October 14,
1971
TEXACO, INC.
v.
)
#
71—235
(70—29)
ENVIRONMENTAL PROTECTION AGENCY
Philip
R. Wimbish,
for Texaco,
Inc.
Delbert
0.
Haschemeyer,
for the Environmental Protection
Agency
Opinion of the Board
(by Mr.
Currie)
Texaco
was
granted
a variance February
17,
1971,
to complete
the installation
of equipment designed to bring under control
emissions
of hydrogen sulfide from
a brine lagoon at its
oil
production
facility near
Salem.
The order required the company
to determine ambient concentrations of the gas,
to evaluate
the efficiency of its
new equipment,
and to apply by August
1
for an extension if more time was needed.
It was recognized that
the application
of
the electrolytic
technology
then under
consideration to oil field wastes was experimental,
and that
even
if the unit worked well
it might be necessary
to ~insta1l
additional
units
in order to achieve
an acceptable level of air
quality
Texaco filed
a timely request to extend the variance until
December
1
of this
year,
and we held
a second hearing.
The
Agency recommends we grant
the brief extension
on conditions,
and we
agree.
The evidence established that
the electrolytic
installation
was completed
in June;
that while it removed
a considerable
amount of hydrogen sulfide
it was only 50-60
as effective
as
anticipated;
that its operation resulted
in
a
low
pH
that required
large quantities
of caustic to avoid corrosion;
that there were
severe scaling and plugging problems imcairing dependability;
and that
in sum the unit proved unsatisfactory
(R.
19-28).
Texaco
immediately developed an alternative ylan
that has been demonstrated
successful in
field experiments.
The
new system
involves
the oxidation
of hydrogen sulfide to elemental sulfur by the introduction
of
compressed air
in the presence
of nickel chloride
as
a catalyst
(R.
57-60).
Complete removal
of the hydrogen sulfide from
the
water—-an estimated 7500 pounds per day
(P.
74)--
is expected
(P.
53,
68).
As much
as
65 to 130 ~ounds
of the gas will he
stripped
from the water by
the rising air,
but this will be collected
in
a closed vessel and introduced
into
a second nair
of tanks
where further oxidation will take place, and the ultimate emissions
of hydrogen sulfide to the atmosphere from these second tanks
are expected to be on the order of six and one half pounds per
day
(P.
68-72).
This compares extremely favorably with
the estimated
pre-control emissions of 3,000 pounds
a day.
The construction of the new system has already begun
(P.
113).
The company first estimated
that
it would be able to complete
this
completely revised and much more effective program within the
time
allotted for finishing the single electrolytic unit, but minor
delays have interfered that cannot be blamed upon Texaco,
such
as difficulties with
the soil
in excavation
(P.
114).
Completion
is now expected
in the first half of November
(P.
150), but could
be delayed by seasonal rains
(P.
151).
We think the December
1
date entirely reasonable
and commend Texaco
for its application
to the solution of
this difficult problem.
The company has provided
a large number
of sampling reports that demonstrate that
in the
meantime there should be no serious health danger,
although at
times. the concentrations near homes within a mile of the lagoon
reach the level of detectible odor
(P.
l21).l
Several
of the lagoon’s
nearest neighbors,
stressing that odors have been something
of
a problem, have submitted statements
indicating they do not
object to this beief extension
(E.g., Petitioner’s
Ex.
2).
To
close down production for this period could have enormous adverse
consequences,
as detailed
in our earlier opinion,
and it would
not be warranted by the seriousness of the pollution problem.
We shall condition
this extension on the posting of
further
security,
as required by statute,
and on the company’s performing
additional ambient tests after completion of the project.
1.
The Agency’s sampling showed that concentrations tend to be
highest with low wind in the evening or early morning,
with the highest two-hour concentration 0,019 ppm
(EPA
Ex.
1).
The Litton report to the federal air pollution
authorities
(NAPCA Publication APTD
69-37,
p.
83, Petitioner’s
Ex.
15)
recites
“no reported injury
to health”
at levels
up to 0.030 mom, though
the “odor threshold”
is said to
be lower.
Texaco reported
a number of readings above 0.1
ppm,
ranging up
to about 0.8, but generally for periods of
only
two to
five minutes
(Petitioner’s Exs.
20-25).
Litton
reports that smell
is “slightly perceptible”
at 0,100 ppm
and “definitely perceptible”
at 0.330, while giving
10 ppm
as the “minimum concentration causing eye irritation.”
2
—
656
This opinion constitutes
the Board’s findings
of fact and
conclusions
of
law.
ORDER
Texaco,
Inc.,
is hereby granted an extension
of the variance
of February
17,
1971,
to emit hydrogen sulfide gas
from its
brine lagoon near Salem,
Illinois, until December
1,
1971,
on
the following conditions:
1.
Production
at the facilities in question shall not be increased
during the period of this variance;
2.
The$lO,000 security required by the February
17 order shall
be extended to secure compliance with
the terms of
this
order;
3.
The nickel catalyst oxidation facility described
in this
opinion shall be in full operation by December
1,
1971;
4.
Monthly progress reports shall be filed with
the Agency and
with
the Board, and
a final report within thirty days after
completion of the facility;
5.
Texaco shall submit to the Agency and
to the Board
the
results of an independent sampling of ambient air quality
in the lagoon area and in nearby inhabited areas within thirty
days after completion
of the facility.
I,
Regina
E.
Ryan, Clerk of the Pollution Control Board,
certify
that the Board adopted the above Opinion of the Board this
14
day of
October
1