ILLINOIS POLLUTION CONTROL BOARD

August 22, 1984

UNION

OIL

COMPANY

OF

CALIFORNIA,

)

)

Petitioner,

)

)

v.

)

P~B84—129

)

ILLINOIS

ENVIRONMENTAL

)

PROTECTION

AGENCY,

)

)

Respondent.

)

OPINION AND ORDER OF THE BOARD

(by W. J. Nega):

This provisional variance request comes before the Board

upon an August 22,

1984 Recommendation of the Illinois Environmental

Protection Agency

ency).

The Agency recommends

that

a 45-day

provisional variance be granted to Union Oil

Company

of California

(Union Oil) from 35 Ill. Mm. Code 304.120, 35 Ill. Adm. Code 304.124,

35 Ill. Mm. Code 304.125,

and 35 Ill. Mm. Code 304.141(a) to

allow it to bypass the wastewater treatment plant (WWTP) at its

Chicago

Refinery

and

discharge

water to the Chicago

Sanitary

and

Ship

(S

&

5)

Canal

until

repairs

are

completed

and

normal

operation

of

its

WPP

can

be

resumed.

The

Petitioner

is

a

corporation

organized

under

the

laws

of

the

State

of California and authorized

to

do

business

in

the

State

of

Illinois.

Union

Oil

owns

and

operates

a

petroleum

refinery,

known

as

the

Chicago

Refinery,

which

is

located

near

Lemont, Illinois in Will County.

The Petitioner’s refinery,

which

was

constructed

during

the

1967

through

1970

time

period,

became

operational

in

the

spring

of

1970.

(1st

Amended

Pet.

2).

The Chicago Refinery

was

the

first

major

new

petroleum

refinery

built in the United States during the 1970’s.

The Petitioner’s

refinery

takes

about

3.6

million

gallons

of

water

daily

(mgd)

from

the

Chicago

B

&

B

Canal

and

discharges

approximately 3.3 mgd

of

effluent into this canal (the

•

3 mgd difference

between

influent

intake

and

effluent

discharge

is

due

to

cooling

tower

evaporation

and

steam

losses).

The Chicftgo Refinery, which has a rated

capacity

of 154,000

barrels of crude oil per day and employs approximately 705 people,

produces about .25 different petroleum-related products including

conventional gasolines,

jet airliner turbine fuel, diesel fuels,

furnace oils for home heat, petroleum coke, and various specialty

naphthas.

The specialty naphthas that are produced can be

manufactured into 200 intermediate products such as antifreeze,

59-453

---

—2—

dac

pla..t

90*

gear

L.0

Re.

ev,

)u1.4t

ret

a.ic

irP

po”

thy or

the

lir~

C

resu

wit

hao

a-

have

b

ords

mix;n

pumpi.

insta

vat-’

,~c

r;ent

industrial

alcohols

‘~

the.tic

rubber, and

-

~.0tMended

Pet.

2)

•

The

Get

~-.tc,rer

estimates

that

e Ct.Lcago

Rcfinery’s

output

a’

‘‘

t

o

making

automobile

-

,

~ra

heating oils, turbire L

..

and diesel fuels for

Th

is

ar~d

other

midwestern

:~-...°

•,

23,

1984

substantia

~0

the

Chicago

-

‘

.e

damaged

and

destroyed

as

r

t

of

an

explosion

3ec.ausc of

this

accident

s

age

occurred

to

‘Lb

urjt

ard

the

b

ate

•

meit

plant

at

the

re Pet~tznez has irdic

ter

cstruction

of Its

ZtlCdb

ed

substa

itia

of

sulfuric

acid

-n water tasin and cauqad

±

the

water

ir

some

-

3opbelowapflof2.

(1.

1

aedPet.3).When

-

~

teapted

to

raise

the

pH

rm

water

basin

by

of

a

caustic,

its

attempt

~tv

~lization

met

with

~ r’

because

of

a

lack

of

i-c

$

ti-ich

apparently

-

a

stratification

with

ove

-

°

r

ization

occurring

~,s

~g from

5

to

13.

In

its

tcoinendation,

the

Agency

that

it

believes

‘better

ope- a

tcntl

control

could

‘i’d

in

the

neutralization

pv

ces

.‘

(Mc.

3).

In

ieve

proper

neutralization,

i

‘arts

to

improve

the

-

continuing.

A

special

mixing

sperger

capable

ot

~

0

gallons

per

minute

of

wat.

a° been

fabricated

and

3

a-id

emergency

power

has

been

ssta’f ished

for

the

storm

‘~“t..ng pump.

(1st

Mended

Pt

a”

•

(ae’

vaf

arc

I

Per’~.-

is

“

fir

•

r the previously mention’

fl

‘evels,

water

from

the

st~.

-

i

a the WWTP

•

without

sevcro

~3ssary

to

effect

biolqir

•

let.

3).

Moreover,

the

pr

‘

tensively

damaged

as

a

resul

v

necessitating

numerous

tej

-

•

;rac&s

ii

the

equalizac ~r.

V.

unkwillbeabletoholdws

•y

25

of

the

circumferenci

-

-~

wed

and

replaced,

along

wi’

v

~rof

the

tank.

UnionOil,c

rquisite

repairs

to

the

pren

a

?~sto

accomplish.

(1st

Me c-

ob ems in

maintaining

ater

basin

cannot

be

i

olting

the

micro—

r

a’

aent

of

the

wastewater.’

~a -nent

section

of

the

c,(

he explosion and

to this

equipment.

~1

wall

mast

be

rs~aired

tdditionally,

tie

sedimentation

tank

-

r

repairs

to

the

‘tted

that

it

estirates

ant

system will

take

Ut

3).

I,

the

di’

C

(I

MU

fr

F’,

b4

apt

T L.

‘Si-

t’

-

a

of

the

extensive damage

to

:‘.e

refinery’s

process

-

SJW?P,

the

Petitioner

is

currcr

-

nable

to

meet

the

~13 stions

set

forth

in its

\

Perait

No.

1L001589

.At

A).

Thus,

Union

Oil

ha’

r’uested

a

provisional

~1

low

it

to

bypass

its

wrr

ischarge

water

-

-

the

Chicago

S

&

S

Canal

u

1

the

necessary

repairs

..

and

nor-nal

operation

of

~

£

:an

be

resumed.

t’

storm

water

basin

is

al-non

:

‘

tnd

additional

water

‘

being

received

fran

rain

-

a~

stell

as

from

its

Ian

system),

the

Petition~

e’

to

discharge

water

59454

---

~-

~ant..

If the Petitioner does not discharge this water,

an e ~

~o~iinto the Illinois and Michigan

(I &

M) Canal might

result

ch could

have

potentially serioun environmental con~

sciuc~ ~

due to the low flow rate ~f th~I

& M Canals

Accordingly,

han discharged limited amounts

-E untreated water from

the

a

~ator basin to the Chicago

S

& ~

anal pursuant to the

maltn?

;

-n and breakdown provisions

ot ~

NPDES Permit

in order

to

~-‘~:

~rf low of the storm water ba~r to the

I

& M CanaL

Baae

Lkn

storm water basin being fuJ ~nd additions due to

the

f

n~ntionsystem during a ~wo~-~k

period, the estimated

voliun

‘-er which will probably ha (uL~ehdrgedinto the Chicago

S

&

I

--

~-

na approximately 70 milliot

cr~-~

ions~ The Petitioner

antii

~L

that. this volume of water cn he discharged at an

averac~rate of 3~000gallons per minute

1i~e~,

4~3mgd)

in

about

two ~ec

r more (depending on whether o~not significant rainfall

occur~dn ing this time period)e

rp~

~

~itionerhas indicated that it wIll continue to

re~entahi-iahappropriate biological activity at its WWTP as soon

as praut~nab~e~Union Oil has already r~t~rnedemergency power

to thu ~iezc-~tiun

basin

and

~a small populdLion of microorganisms

has be

maLtained by feeding them contrnlled quantities of

metha~c~and phosphoric acid~

(1st Amended Pete

5)~

In an

effoit

t~

b~iild~up

the population of micro organisms,

a small

flow cn

~

-er from the

storm

water basin

i~n

being charged directly

to Lie ~n

~on

basin along

with sanitary sowagee

As long as

micro~r~anis~

growth

is not inhibited,

tne charge rate will be

gradu~ ~y increased~

The flow

rate to the WWTP will

be

gradually

increa~adafter the pretreatment system is returned

to

service

unt~

operating conditions are a~nt e~tablished~Nonetheless,

tIe

-

~ris currently unable to d~Lt~nehow quickly the

WWTP

a be returned to operation at a hi~hflow rate while

mair1a~n ~ effective biological

treat!-tenr,

However, the Petitioner

has

i~

i~-~t~te~d

that there is no other imt.hcd by which it can

treat

~

w~stewatersince,

should Union Oil not be allowed tne

diechi an

-here could be an unavoidable overflow into the

I

&

M

Canal

! ating potentially serious conse~in’naeedue

to the

low flow

rate

tr:3

I

&

M CanaL

(1st Amended

£-~-~.

5~8)~

hi-

~il~s waste treatment facilit~iinclude a flow

equn

-

t~i~n

and storm water retention p !Ld~two oil

and water

seuar~t

~-

a primary clarifier, activathd sludge units, and

a

ool~i.

~p~nd~.Aerators, which are powernd by a portable

gen~

-

~nd artificial nutrient adthtia~iare currently keeping

tie

~

-i

~-~ru,

in the activated sludge

~

alivee

(RêCe

2)e

The ~-~e

nelieves that the flow oquaIia~tJ.onand storm water

pond-

~j

with the polishing pond,

are pr.~aentlyoperable

Jasp

-t

~ damage sustained, and that f tows can be circulated

th~

ia’

c.

-enimary tank to increase mixing for neutralization

puruo~

some sedimentation~

(Roe.

2

~Iowever,Agency

~r~i

of these facilities

since t~ef~reand explosion have

reveai~

ii~t

electrical power was diar ~ç ad and that inflaent

oumps

-b~.~WTP are currently inoper~.L

---

Bec~n*

vice

must

still be

restored

LL.

ther

parts of

the

refi~

urovision of permanent electric

1 service is expected

to

L~Ju~

ne t.me~

Although

Union

Oil

h~sprovided emergency

elect

~.

service

via

portable

generator~

there

is

insufficient

deL

c--~l puwor ~o

operate

all

equipmei~t

aid

the

generators

provi

~y enough

electrical

power tu

orate

some aeration

L

~nd

some

pumpse

(Rec~

3)~

I

~

Recommendation,

the Agency

~oS

noted

that

it

“prey

y

r~quested

a

commitment

froit

Petitioner

to

provide

the

beet

-

onal

control

possible

and

a

schedule

for

returning

the

-

~

cervice

(Rec~3)~

B~cause neither

of

these

coma

Se

were

provided,

the

Agency

h~s suggested

that

the

Board

r~o~ise

a

condition

in

its

Order

“to

assure

that

the

facLl

t~e~

are

operated

as

well

as

possible

and

returned

to

service

quickly~”

(Rec~

3)~

The

Agency

has

also

indicated

that

it

is

~t

~ersuaded

by

Union

OiPs

assertions

pertaining

to

the

relL

1

y

and

representativeness

of

~aii-pling

data

and

emphasizes

that

tL

company

has

requested

effluent

limits

far

in

excess

of

the

~

mun

values

of

samples

collectea

by

Petitioner.~

(Rec~ 3)~

Accorir

ly,

the

Agency

has

recommended

various

effluent

limits

which

it

believes

are

more

appropriates

The

Agency has received

no

oIji~

Ions

from

members

of

the

public

to

the

Petitioner~s

proviai~il

variance

request

and

believ~

that

a

provisional

varia

is

warranted~

a

Agency

has

concluded

that,

due

to

the

severe

damage

to

the

~

c

j

Refinery

by

an

explosion

and

fire

on July 23,

1984,

comp

i

~i

on

a

short~term

basis

with

effluent

limitations

in

35

I

~Li

lade

304e120~

304-.124,

304.)25,

and

3O4~141(a) would

ir ?

~~5itrary

or

unreasonable

hardship

upon

the

Petitioner~

The

believes

that

any

adverse

environmental

impact

on

the

Chi

a

~

~

S

Canal

should be minimized

by

the

expeditious

repair

of

u

-~

itioner~s

WWTP

and associated facilities0

It,

therefore,

recar~

a

Jiat

the

Board

grant

Union

°il

~-~pany

of

California a

pro~i

~

variance

from

Sections

304

12),

304~124,

304,125

and

304

14’(a)

for

a

period

of

45

days

to

allow

it

to

bypass

its

was

~

treatment

plant

and

discharge

water

into

the

Chicago

~an~

cy

a~d Ship

Canal

until

repairs

are

completed

and

normal

operati.

r

of

its

WWTP

can

be

resumed,

3ubje~t

to

certain

conditions.

E

~aant

to

Section

35(b)

of

the

Illinois

Environmental

Pro~ctL

Act,

the

Board

hereby

grants

~he

provisional

variance

as

cn~

~tded~

i’~L

Jpinion

constitutes

the

BoarnPn

findings

of fact

and

car;

.-i~.

e of

law

in

this

matter0

ORDER

1

Oil

Company

of

California

i-~ no

eby

granted a

variance

from

35 Ill~

Adm~.

od-~304~120,

304~124,

59~456

---

304.125,

and 304,141(a)

to allow

it to bypass its wastewater

treatment

plant

at

the

Chicago Refinery

near

Lemont,

Illinois and

discharge

water

into

the Chicago

Sanitary

and

Ship Canal until

repairs are completed and normal operation of its wastewater

treatment plant can be resumed, subject to

the

following conditions:

1.

The period of the variance shall extend for a period of

45

days,

or until the treatment plant is operational,

whichever is

less,

2~

The

existing

facilities

shall

he operated as efficiently

as

possible

and

shall

include

the

use

of as

many

units

as

possible

to

minimize

the

impacts

of the discharge.

3.

The

treatment

plant

shall

be

returned

to

service

as

quickly

as

possible.

4.

At

all times during the period

of

the

variance

the

outfalls shall be limited as follows:

Outfall

001

pH

5-13

Standard Units1

TSS

30

mg/i

COD

750

mg/i

BOD

115

mg/i

Chromium

Total

5.0

mg/I

Oil,

Fats

& Grease 26.0

mg/i

20.0

mg/i

Phenol

14.0

mg/i

Cyanide

0.080

mg/i

Sulfide

5.5

mg/i

1The period of variance for pH ~

shall be

2

weeks

from the

date

of the Order to allow the Petitioner adequate

time

to

complete the mixing of its storm water basin contents.

Outfall 002

There shall he no discharge from outfall 002 during the

period

of

the

variance,

5.

The Petitioner shall sample the discharge

from

Outfall

OOi with

a

composite sample

collected

each

day

that

there is a

discharge.

6.

Until the end

of

the

variance period,

the Petitioner

shall

report

to

the

Agency

every

fourteen

(14)

days on

the progress made in repairing the plant.

These

reports

may be made by telephone to Mr. Theodore Denning at

3i2/345—9780.

59-457

---

70

Within

ten

(10)

days

after

the

end

of

the

variance

period,

the

Petitioner

shall

submit

a

written

report

to

the

Agency

of

the

activities

completed

during

the

variance

period0

The

Petitioner

shall

also

submit

its

laboratory

test

results

for

the

samples

taken,

8~

Within

10

days

of

the

date

of the Board~sOrder, Union

Oil

Company

of

California

shall

execute

a

Certificate

of Acceptance

and

Agreement

to be bound

to

all

terms

and

conditions

of

this

provisional

variance

which

shall

be sent to:

Mr. James Frost, Illinois Environmental

Protection Agency, Division of Water Pollution Control,

Compliance Assurance Section,

2200 Churchill Road,

Springfield,

Illinois

62706. This certification shall

have

the

following form:

CERTIF ICATION

I,

(We)

_________________________

__________,

having

read

the

Order

of

the

Illinois

Pollution

Control

Board

in

PCB

84~129 dated

August

22,

1984,

understand

and

accept

said

Order,

realizing that such acceptance

renders

all

terms

and

conditions thereto binding

and

enforceable0

Petitioner

By:

Authorized Agent

Title

Date

IT

IS SO

ORDERED,

I,

Dorothy M. Gunn, Clerk of

the

Illinois

Pollution

Control

Board

hereby

c~rtify

that

the

above

Opinion

and

Order

was

adopted

on

the

of

~

1984 by a vote of

5~M.~nn,cler

Illinois

Pollution

Control

Board

59~45~