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UNO—VEN

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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