ILLINOIS POLLUTION CONTROL BOARD

February 20, 1985

UNION

OIL COMPANY

OF CALIFORNIA,

Petitioner,

PCB 84~66

ILLINOIS ENVICCIMECTAL

PROTECTION AC~CC~

OPINION

AND OF~DER~ THE BOARD (by J~ Marlin):

This matter c~~s before the Board

upon a May 31, 1984

petition

for varia~~filed by Union Oil

Company of California

(Union)

requesting

two

year extension of

relief

from 35 Ill~

Adm~ Code 304~l22(b)or until final resolution

of its

site~

specific regulators proceeding R84—13; whichever is

sooner~

Section

304~122(b) provides a 3~0mg/l ammonia

nitrogen effluent

standard

applic ~ble to Unio&s Chicago

Refinery discharge into

the Chicago

Sar tary and Ship Canals In its petition

Union

requested

that ~nding resolution of its

site—specific request it

be allowed

to ~charge aamonia nitrogen

at levels of 775 lbs/day

monthly

averagc; and 1,705 pounds daily maximum which

correspond

to ~

BAT allowables~ The most recent variance, PCB

82—

87,

set the levels at 550 and 1,010 pounds respectively~ In

its

Response

to the Agency Recommendation Union

“requests that the

condition relating to effluent ammonia quantity be revised

to

consider the increased ammonia from the coker complex~

On July 19,

1984,

the Board granted the Illinois

Environmental Protection Agency~s (Agency) motion to file its

recommendation instanter~ Union~s response was filed on July

23,

1984~

Meanwhile, Union experienced an explosion and fire later

that

days The Board granted Union~smotion to defer decision in

this

matter (August 22, l984)~ An amended petition subsequently

was

filed on November 19, l984~ The Agency moved to file its

recommendation instanter which was granted by the Board on

January 10, l985~ U~C~5ruary7, 1985, the Agency filed a

motion

to

allow the filin~:,

~:~‘lem’~ ~l recomm:Cation~ U:~icn

objected

in its

F

~

i.e mot

granted~

Hearing was waived and none was helO~

One citizen

comment

was received by the Agency on December 20, 1984

and was

attached

to its recommendation~ The Board does not

interpret the

comment as an objection so as to trigger

a

hearing in

this

matter,

63~7h

---

2

Union has been granted four previous variances from the

ammonia nitrogen effluent limitation found at section 394.122(b):

PCB

77—163, September 29, 1977; 27 PCB 511

PCB 78—168, September 21, 1978; 31

PCB

499

PCB

80—124, September 4, 1980; 39 PCB 438

PCB 82—87, October 5, 1982; 49

PCB

43

and December 2, 1982; 50

PCB

57

The variance in PCB 82—87 imposed a monthly average ammonia

nitrogen effluent limitation of 550 lbs/day and a daily maximum

of 1,010 pounds.

Union owns and operates a petroleum refinery located in

Lemont in Will County which has a rated capacity of 154,000

barrels o~crude oil

per

day. Most of the oil used is sour crude

whiØh is High in nitrogen content and which pontributes to the

high ammonia nitrogen levels in its wastewatIr discharge. The

refinery draws from and discharges to the Chicago Sanitary and

Ship Canal. After treatment in Union’s wastewater treatment

plant (WWTP), approximately 3.3 million gallons per day (MGD) of

process wastewater and contaminated surface runoff are

discharged. The WWTP consists of a combined flow equalization

and storm basin, two API separators, a primary clarifier,

activated sludge basin and a polishing pond. In—plant technology

includes three 3our water strippers, two stripper storage tanks,

and the recycl: ig and treating of all tooling water. Union’s

volume of treat d effluent is about 28 gallons per barrel of

crude oil refii ..d (USEPA

BAT

guidelines are 42 gallons per

barrel).

In lieu of direct compliance with 35 Ill. Adm. Code

304.122(b), Union has filed for site—specific regulatory relief

(R84—13).

The data in the chart

below

show that since January 1983,

Union has complied with the interim ammonia nitrogen variance

limitations of 550 lbs/day monthly average and 1,010 lbs. daily

maximum. Union expects that its expanded Delayed Coker Unit and

•its new Needle Coker Complex will increase the ammonia nitrogen

concentration of its effluent by 73 lbs/day under “specified

procSss conditions”. (Response at 3)

•

Union believes that the

strippers will not remove all the extra ammonia nitrogen

anticipated (Am. Pet, at 5).

Assuming the .1ont’iy anrage nmnonia nitrogen limitation of

550 lbs/day was r~tnsnedand f’~rtnsrassm..sin~ an additional 73

lbs/day ammonia nitrogen, based on the chart data, there would be

excursions above the limitation. Union has failed to make a

•convincing case for the requested 775 lbs/day monthly average

level in this proceeding. The Board will, however, increase the

current monthly average level to 625 lbs/day to allow for the

increase expected

from

the coker facilities. The Board notes

that the Agency has supplied data in terms of a thirty day

63-76

---

3

A summary of the effluent ammonia data submitted by Union in

its discharge monitorinq reports (DMR~s) fo~

~t

Quantity

Concentra~

Flow MGD

(lbs/day)

tion mg/i

Month

~

~v,

Max,

*Juiy 84

0,67

235~4

297,0

20.7

June 84

3,74

327.8

684,2

4,8

May 84

2,85

534,6

990,0

10,2

April 84

4,25

418,0

759,0

11,8

March 84

3~54

545,6

970.2

18.5

Feb. 84

2,76

519,2

827.2

23,1

Jan 84

0.80

244,2

4O0~4

Dec. 93

2,39

39i.f~

693~(~

Nov. 83

2,76

514,8

67i,~

Oct. 83

3,40

503,8

Sept. 83

3,62

5(5,0

662,2

16,8

Aug. 83

3,28

451,0

807,4

16,5

July 83

3,82

519,2

699,6

16,3

June 83

2,42

536,8

695,2

26,7

May 83

3,18

499,4

717,2

18,9

April 83

4,61

539,0

690,8

14,1

March 83

.06

473,0

803,0

14,0

Feb. 83

~8i

543,4

930,6

23,3

Jan, 83

04

506,0

6~3,2

20,~

*

Explosion an ~ire of July 23, 1984 terminated refinery

activities. T s data is from the January 7, 1985 Agency

Recommendation The original kilog an/day values have been

converted into lbs/day by use of the multiplier value 2,2,

The daily maximum interim limitation of 1,010 lbs/day

ammonia nitrogen, as the above data point out, was not

violated, Assuming an addit~onal 73 lbs/day, there would have

been two excursions during the listed 19 months, Therefore, the

Board will increase the da ly iax trim to provide for the increase

in ammonia nitrog~an expect as ~esult of the coker

facilities, The Board will increase the daily maximum ammonia

nitrogen interim limitaton to 1,160 lbs/day~

The Board bcl~

hi Jn~o-~w~l1 be able to meet these

limitations over t

t ~aiiance The Bo~ .11

address the need

i

~t

~.i ii~

of expe~Le~

increases in nitrogen in crude oil in the regulatory

proceeding. In granting this variance the Board specifically

notes that Union~swater corse~ ation oractices increase the

concentration of ammonia nitrogen in its effluent, but not the

total amount discharged. The Board has no intention of

penalizing Unior for conserving water,

83~77

---

4

For a history of Unio&s efforts at compliance see Table 1

in its response to the Agency recommendatio~ ~f note d~ringthe

last variance period is the use of a sulfide ~o~iugchemical

and additional steam to enhance nitrification, tull scale trial

addition of Sybron/biochemical mutant bacteria to establish a

nitrifier population, and the installation of permanent dissolved

oxygen analyzers in the aeration basin (Response, Table 1), The

additional steam and bacteria did not increase nitrification (Am,

Pet, at 11), Present annual operating and maintenance costs are

over $1,800,000 (Am, Pet, at 6)~ Present design projects include

hydrogen peroxide addition to the WWTP and final clarifier

modifications

Alternativ?. stems to meet the 3 mg/l ammonia nitrogen

effluent standar iere studied by Union~s consultants in the

Aware Report whi is incorporated ~nto this ~a’iance

proceedings Cons.~.dered not technically feas~~weuc singls~

stage activated sludge, single stage actrvat~ ~Iudge with mutant

bacteria, land application, ozonaLion, air stripping and steam

stripping (R84—13 Aware Report at 3—22), Other systems which can

meet the 3 mg/l ammonia nitrogen standards but not consistently

include: single stage activated sludge with powdered activated

carbon, two stage activated sludge, two stage biological

treatment with activated sludge in the first phase and fixed

media in the s ‘ond stage, and ion exchan~ (Id, at 3—23)~

Breakpoint chl ~ination can consistently meet the 3 mg/l standard

but its use wc 0 result in the formation of potentially toxic

chlorinated hy ~carbons (Id, at 4—21 through 4—24), Its capital

cost is $l,95C ~00 and its operating and maintenance cost is

$932,000 per y ar (Id, at 4—24),

The environmental impact of the granting of variance is

minimal, Unio~~calculated its discharge of ammonia to the

Chicago Sanitari c~dShip Canal as increasing the concentration

in the Canal by (~~0~0mg/I (Am~Pet, at 14), The ammonia

nitrogen loadings from the three Metropolitan Sanitary District

of Greater Chicago~s(MSD) WWTPs total 93,6 percent of all such

loadings to the Illinois River system which includes the CanaL

Union discharges 1,3 percent (Am, Pet, 22), At the Lockport

sampling station, the secondary use ammonia nitrogen standards of

35 Ill, Adm, Code 302 407 are being consistently violated (Ama

Pet, 16, 24), Neither Union nor the Agency address whether the

Illinois River downstream meets the general use ammonia nitrogen

water quality standards of section 302,212,

As for strep

ox~ concent ions, ~ sc~ondary

use water qual~.

ir~

~ut~

Ste ciard or

4 ~

;or the Lana? is

being violated

(Am,

Pet 16, 24; see 35 Ills Adm, Code 302,405,

303,441), Union alleges

that

these dissolved oxygen violations

are due to the

discharges upstream of the

Union facilities (Am,

Pet, 16),

most likely referring to

the MSD~s Northside, Calumet

and West—Southwest wastewater treatment plants~ The general

i~~e

dissolved

oxygen

ctandards downstream for the Illinois River

were

violated five

ti~ a in two

years (Am, Pet, l5)~

63~78

---

The Board finds that the granting of

te~ ~r’riance

i~’

cause

minimal environmental

impacL Union should~ r ~r, con~nue

its efforts to

reduce the concentration of ita amronia niti ~ç~en

discharge,

Given

that a technically feasible and economically

reasonable

means of meeting the 3 mg 1 ammonia nitrogen

standard

has not been

identified despite Urioi~s efforts, the

Board finds

that denial

of variance i’ould irpose an arbitrary or

unreasonable

hardship~ Because

Union did timely file its petition

and that

any delay (explosion)

wee beyond its con~ro1, the

term of

variance

wi1~ tn~ ~rarted

from September 29, 1984 until April

25,

1987 or

unti

~.he Board renders a final d ision on its site—

specific

regulatory proposat, R~4—~3, whicflever is sooner,

The

variane

will be subject to condition~

lbs r~rim aminoni~

nitrogen

effluent limitations shall ba

~‘

~‘‘~

cr~e of I~

lbs/day

and a daily maximum of 1,160 lb’jcay

~i.nn shall

continue

to monitor and report

diecharge data, The Board

believes

that the condition requiring monitoring

of the coking

complex

discharge is necessary,

However, the Board agrees

with

Union that

condition number ~ of the Agency recommendation,

which

recommends the study of additional ammonia nitrogen removal

systems,

is unnecessary ir light of the Aware Report,

Petitioner

shall continue

~ts research

10 idertify means of further reducing

its

discharge

ammonia nitrogen,

This Opin

constitutes the Board~s findin3s

of fact and

conclusions

of w in this matter,

Union

Oil Company of California, Chicago

Refinery, located

in Lemont

Illinoi

her by gran~cd a variance from 35 Ill,

Adm, Code

304,12~b~ ~ ecF to ~he conditions below:

1,

This variance begins on September 29, 1984

and

expires on April 2~ 1987 or when a final decision

is

rendered by th~ ~~rd ii R84~l3 whichever is sooner,

2, The interir efflier

amro i nitrogen limitations

shall be a monthly av~rge of 625 lbs/day

and a daily

maximum of 1,160 1 /day~

3, Tie disct

eported

~

stated i

4, Petitiorer s ~ll

-aple and mo-iitor flows

from the

Delayed Cokera

r I t

~w Needle Coker complex to

determine the effcct

I the increased Delayed

Coker

capacity

and the rew Needle Coker

complex on ammonia

loadings to the treatm~’nt plant and on

effluent

quality ~nd quarti y fr ~ the treatment plant~

63-79

---

6

5, By December 31, 1985, Petitioner s

“

report on its findings from the at

above

Illinois Environmental Protection Agency

Attn: James Frost

7. Pet..~ionez 1 submit all data from studies referred

to .n Cond

4 above, wher r~uestedby the Agency.

In toe eve, at this varia ice is termintteo by a cite—

specific rt’ Petiticner shah

e’bmi

all data to

the Agency un 60 cay after the effective date of

8. Within 45 day- of the date of this Order, petitioner

shall execute and complete a Certificate of Acceptance

and submit it to the Agency at the same address in

Paragraph 6 above. This 45 day period shall be in

abeya e during any period that this matter is being

CERTI FICATE

UNION OIL COIP 7 OF CALIFORNIA Patitioner, hereby accepts and

agrees to be bound by all terms and conditions of the Order of

the Pollution Con rol )ard

‘ri

PCB 84—66 dated

________________

Petitioner

By

____________

-

,

Title

Date

IT

ISSOOr.

I, Dorothy M. Gunn, Clerk of the Illinois Pollution Control

Board, hereby certify -hat

he

abcve

Opinion and Order was

the _______________•day of

.ILIt~9’t~7I

,

1985 by

1?,.

Dorothy

.

Gunn, Clerk

Illinois Pollution

Pata”~’sph 3