ILLINOIS POLLUTION CONTROL BOARD
    May 29,
    1975
    AMOCO OIL COMPANY,
    Petitioner,
    vs.
    )
    PCB 75—104
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    AMOCO OIL COMPANY,
    Petitioner,
    VS.
    )
    PCB 75—105
    (Consolidated)
    ENVIRONMENTAL PROTECTION AGENCY,
    Respondent.
    OPINION AND ORDER OF THE BOARD
    (by Mr. Henss)
    Amoco Oil Company operates a refinery in Wood River,
    Madison County,
    Illinois which
    is capable of processing
    up
    to 110,000 barrels of crude petroleum per day.
    Operations
    at this refinery include:
    atmospheric fractionation, vacuum
    fractionation,
    fluid catalytic cracking, catalytic reforming,
    butene polymerization, sulfuric acid alkylation, distillate
    oil and gasoline treating, gasoline blending, distillate fuel
    blending, residual fuel blending, asphalt manufacture and the
    manufacture of additives for gasoline, distillates, motor oils
    and diesel lubricating oils.
    The Wood River refinery is Amoco’s third largest refinery
    and one of ten in the Amoco system.
    Products from this
    re-
    finery include:
    non—saleable fuel gasses for consumption by
    Amoco, LPG,
    chemical grade propylene concentrate,
    special
    naphthas, motor gasolines,
    jet fuels, distillate fuels, diesel
    fuels, residual fuels, road oils and paving asphalts, industrial
    asphalts, polybutenes,
    cable oils and various fuel and lubricant
    additives.
    17
    203

    —2—
    In PCB 75-104 Amoco seeks a one-year variance from Rule
    204(d)
    of the Air Pollution Control Regulations for continued
    operation of fuel combustion equipment pending completion of
    its compliance program.
    Rule 204(d)
    limits
    the emission of
    sulfur dioxide from the burning of combined fuels.
    Affected
    equipment in this
    case includes 6 steam boilers,
    11 process
    furnaces,
    2 fume destructors and
    3 safety flares.
    In PCB 75—
    105 Amoco seeks va~riancefrom Rule 203(d) (1) from May 30, 1975
    through November 30,
    1975 to allow operation of
    a fluid cata-
    lytic cracking unit pending installation of particulate emission
    control equipment.
    Rule 203(d) (1) provides particulate emission
    rates for catalyst regenerators of fluidized catalytic converters.
    These Petitions for Variance were consolidated by Board Order.
    PCB 75-104
    Sulfur dioxide emissions from Petitioner’s refinery averaged
    3,800 lbs./hr.
    in 1973 and 3,260 lbs./hr. in 1974.
    Petitioner
    does not supply information on the types and combinations of fuels
    burned, the actual heat input from these fuels or the applicable
    sulfur dioxide emission standard for the fuels involved.
    The
    Agency states that ~etitioner’s
    1974 SO2 emissions are e9uivalent
    to 1.99 lbs. per 10
    Btu in contrast to the 1
    lb. per l0~Btu
    limit imposed by Rule
    204(d) based upon the type of
    fuels utilized
    at the refinery.
    Petitioner states that its SO2 emission will be
    about 1500 lbs./hr. when compliance is achieved, depending on the
    level of operations and consequent heat input
    (Petitioner Exhibit
    F).
    On April
    16, 1975 the U.
    S. Supreme Court handed down its
    Opinion in Train, Administrator, Environmental Protection Agency,
    et al vs. N&tural ~esources Defense Council, Inc.,
    et al
    (No.
    73-1742).
    In brief, the U.
    S.
    Supreme Court ruled that the Clean
    Air Act authorizes states to grant variances from implementation
    plan requirements if such variances do not interfere with the
    attainment or maintenance of national ambient air quality standards.
    Illinois
    is required to attain the ambient air standards by
    July 31, 1975 but the Illinois Implementation Plan provides for
    the grant of variances
    in accordance with the provisions of the
    Illinois Environmental Protection Act.
    Therefore,
    this Board can
    grant individual variances beyond July 31, 1975 if the variances
    do not interfere with the attainment and subsequent maintenance
    of national ambient air quality standards.
    (See:
    Opinion and
    Order of the Board in Texaco,
    Inc. vs. EPA, PCB 75-59, May
    8,
    1975)
    The record in this case contains SO2 ambient air quality data
    obtained from the Agency’s Wood River Station 03 for the period
    1969 through 1973 and Amoco’s Mobile Van for 1972 through 1974.
    These data were tabulated by Petitioner as follows
    (Petitioner Exhibit
    F):
    17
    204

    —3—
    1969
    1970
    1971
    1972
    1973
    1974
    IEPA, WR Station
    03
    Annual Arith. Mean, ppm
    0.040
    0.017
    0.018
    0.028
    0.027
    NA
    Mas.
    24-Hr. Avg., ppm
    -
    -
    -
    0.173
    NA
    Amoco Mobile Van
    Annual Arith. Mean, ppm
    0.021
    0-.014
    0 3~T3
    Max.
    24—Hr. Avg., ppm
    0.16
    0.13
    ~
    No. Days Above 0.14 ppm
    -
    1
    0
    These data indicate that the primary ambient SO7 standars
    (an
    annual arithmetic mean not to exceed 0.03 ppm and a 24—hour aerage
    of 0.14 ppm not to be exceeded more than once
    a year) were met in
    1972 and 1973.
    Data from the Mobile Van indicates that both
    standards were exceeded in 1974.
    Noting that the 24—hour standard was exceeded on 13 occasions
    in 1974, Petitioner states that the wind never blew from Amoco
    sources to the monitor on six of the dates.
    On two other datc~,
    no significant concentrations of SO2 were recorded during periods
    when the wind carried emissions from Amoco sources toward the
    monitor, according to Petitioner.
    On the remaining five dates, Petitioner states that the wind
    passed through the refinery to the monitor, although not necessarily
    directly from an Amoco source to the monitor.
    While admitting that
    Amoco sources made some contribution
    to the ambient concentrations,
    Amoco believes that it “can be reasoned” that these
    “excursions”
    were not caused by fuel combustion in the refinery.
    Petitioner
    further reasons that,
    since 1972 and 1974 operations constituted
    about 91
    of the peak 1973 operations, the refinery’s SO7 emission
    “could not have been the cause of poorer ambient air quality in
    1974”.
    Petitioner states that the national ambient air standard for
    SO? “has been achieved in the Wood River area with uncontrolled
    emissions
    of sulfur dioxide from fuel combustion
    in Amoco’s
    7
    River refinery”.
    On this basis, Amoco submits that fuel combustion
    operations at its Wood River refinery, prior to compliance with
    Rule 204(d),
    “will not have an adverse effect on the health and
    well-being of the community”.
    The Board is unable to reach the same conclusions as
    Petitioner especially in view of Petitioner’s own monitoring
    results.
    Amoco data showing an annual averageof 0,039 ppm and
    a maximum 24~-houraverage of
    0.54 ppm and 13 days above 0.14
    pm
    do not constitute proof that the primary standard has been met
    in Wood River.
    On the contrary the data clearly show that the
    standards are not being met.
    Agency monitoring data for the
    Wood River area of 1974
    is not a part of this record.
    17—205

    The Agency Recommendation does not discuss the ambient
    air quality data except to state, without detail, that com-
    plaints had been received concerning emissions from the re-
    finery.
    The Agency does note however, that the U.
    S. EPA
    issued
    a Notice of Violation pursuant to Section 113(a) (1)
    of the Clean Air Act to Amoco on January
    29, 1975 concerning
    the SO2 emissions from Amoco’s boilers.
    Amoco has submitted
    its schedule for achieving compliance to the U,
    S.
    EPA.
    No
    order has been issued by the U.
    S. EPA in this matter.
    The record is simply not sufficient, under the guidelines
    of the recent U.
    S.
    Supreme Court decision, for the allowance
    of this variance concerning SO2 emissions.
    Data from Petitioner’s
    own monitors indicate that the Wood River area has not yet
    attained either of the primary SO2 standards.
    We are unable to
    conclude that Amoco’s emissions will not interfere with attain-
    ment or maintenance of national ambient air quality standards.
    Economic data submitted by Petitioner indicates that Amoco’s
    Wood River refinery constitutes about 10
    of the total Illinois
    refinery capacity.
    Petitioner states that the shutting down of
    its refinery would increase refinery product importation into
    the midwest by about 10,
    cause Petitioner
    to lose
    the only
    Amoco location where additives from motor oils and diesel luhes
    are produced,
    and cause
    a loss of jobs and income for 225 re-
    finery employees.
    Petitioner
    is advised, however, that the
    denial of variance is not an order to shut down operations, but
    is simply our determination that the record does not justify a
    shield from prosecution.
    Amoco plans to meet the SO2 standard of Rule 204(d) by
    constructing fuel oil desulfurization equipment and by using the
    expanded desulfurizing facilities of the Anlin Company for
    treating refinery fuel gas.
    The liquid fuel desulfurization
    unit is scheduled to be completed in September 1975.
    Anlin
    projects that
    it will start up its expanded desulfurization
    facilities during September 1976.
    The Agency believes that
    Petitioner’s program will reduce SO2 to the level allowed by
    Rule 204(d)
    and that the time schedule for achieving compliance
    submitted by Amoco
    is reasonable.
    The record in PCB 75—104
    is not adequate for the allowance
    of
    a variance from Rule
    204(d) and the Petition will be denied
    without prejudice.
    If Amoco decides to submit a new petition
    for variances from Rule 204(d)
    such petition must more adequately
    address the air quality issue.
    17
    206

    —5—
    PCB 75—105
    In this case Amoco seeks
    a varian,ce from Rule 203(d) (1;
    of the Air Pollution Control Regulations from May 30,
    1975
    to November 30,
    1975 pending installation of an electrostati
    precipitator to control particulate emissior~from a catalytic
    cracking unit.
    Amoco originally scheduled completion of the electro-
    static precipitator project by May 1,
    1975
    so that the cracking
    unit would be in compliance by May 20,
    1975.
    Mechanical con-
    struction of the precipitator is reported to be essentially
    complete and electrical construction is in progress.
    Late
    delivery of the waste heat recovery unit and necessary duct
    work has caused Amoco to revise its Project Completion Schedule.
    The Schedule now shows completion of the precipitator by
    August 1,
    1975, start-up by August 15,
    1975 and compliance
    achieved by August 31,
    1975.
    Amoco submits that its failure
    to achieve compliance rests solely with the equipment delivery
    delays over which it had no control.
    Fine catalyst particles fluidized in the catalyst re-
    generator tend to exit the regenerator with the effluent flue
    gas.
    Dual internal cyclones with a calculated over—all efficiency
    of 99.99+
    recover catalyst from the flue gas.
    Using a material
    balance method,
    it
    is calculated that particulate emissions
    average
    92
    lbs. per hour.
    Based on a catalytic circulation
    rate of 1200 to 1500 tons per hour,
    Rule 203(d) (1)
    limits
    Amoco to emissions from the catalytic regenerator of
    80
    to 83
    lbs./hr.
    When completed,
    the 94
    efficient precipitator should
    reduce these particulate emissions to less than 10
    lbs. per hour.
    Petitioner has submitted suspended particulate data taken
    from the Agency’s 1973 Illinois Air Sampling Network Report as
    follows:
    Alton-Wood River Trends
    Annual Geometric Mean
    ug/M3
    Year
    1967
    1968
    1969
    1970
    1971
    1972
    1973
    Sampling Station
    Alton 01
    100
    93
    106
    86
    80
    88
    69
    Wood River 01
    111
    83
    134
    116
    102
    03
    158
    115
    101
    94
    79
    Sewer Plant
    106
    17
    207

    —6—
    1973 Suspended Particulate
    ug/M3
    Number
    Maximum
    Annual
    of
    24 Hour
    Geometric
    Sampling Station
    Samples
    Average
    Mean
    Alton 01
    46
    146
    69
    Wood River
    03
    57
    153
    79
    National Primary
    Standard
    (260)
    (75)
    The above data indicate
    that suspended particulates in the
    Wood River area have been on the decline since 1967.
    The 1973
    data show that the Wood River area was only slightly above the
    annual prim~rystandard of
    75 ug/M3.
    The maximum 24-hour standard
    of 260 ug/M3 was not exceeded in the Wood River area during 1973.
    The continuation of the downward trend would have brought the area
    within the annual primary standard by this date.
    As Petitioner notes, the declining ambient concentrations of
    particulate matter have occurred despite the fact that emissions
    from the cracking unit have remained relatively unchanged during
    the same period of time.
    Emissions now are only slightly above
    both the allowable rate under Rule
    203(d) (b) and the primary
    standard.
    On the record presented,
    the Board finds that Petitioner
    has
    met the burden of proof required to obtain
    a variance from
    Rule
    203(d) (1).
    Petitioner’s good faith efforts
    to achieve
    compliance has been delayed through no fault
    of
    its own,
    ~ata indicate
    that
    Petitioner’s particulate emissions
    do
    not
    pose
    a
    threat
    to the attainment and maintenance
    of
    the
    primary
    standard for particulate matter.
    Although Amoco believes that compliance with the emission
    standard can be achieved by August 31,
    1975, variance is sought
    until November
    30, 1975 to “cover possible further delivery delays
    that cannot be foreseen”.
    The Agency recommends the grant of var—
    lance
    until November 30, 1975 or such earlier date as
    the
    electric precipitator project is completed.
    The Board certainly
    recognizes Petitioner’s delivery problems, but a cushion of
    3
    months in meeting the schedule is excessive.
    We will allow one
    extra month for delivery delays.
    Variance from Rule
    203(d) (1)
    will be allowed until September 30, 1975 or such earlier date
    as compliance is achieved.
    This Opinion constitutes the findings of
    fact and conclusions
    of law of the Illinois Pollution Control Board.

    —7—
    ORDER
    It is the Order of the Pollution Control Board that:
    1.
    The variance petition of
    Amoco
    Oil Company from
    Rule 204(d)
    of the Air Pollution Control Regulations is
    denied without prejudice.
    2.
    Amoco Oil Company
    is granted variance from Rule
    203(d) (1)
    of the Air Pollution Control Regulations until
    September 30, 1975 for the purpose of completing in-
    stallation of an electrostatic precipitator on a catalytic
    cracking unit at Amoco’s Wood River refinery.
    This
    variance is subject to the following conditions:
    A.
    Petitioner shall apply for and obtain all
    necessary permits for installation of the
    electrostatic precipitator.
    B.
    Petitioner shall submit progress reports to
    the Environmental Protection Agency on June 30,
    1975,
    July
    31, 1975 and August 31,
    1975.
    Said progress reports shall provide details
    of Amoco’s progress towards completion of the
    electrostatic precipitator project.
    Mr. Dumelle concurs in PCB 75—104 a~iddissents in PCB 75—105.
    I, Christan L. Moffett, Clerk of the Illinois Pollution Control
    Board, hereby certify the above Opinion and Order were a~opted
    on the ~~~day
    of ~
    .,
    1975 by a vote of
    ~—O
    in PCB75—l04 and,1~J
    ii~ ~75—l05.
    Christan L. Moff
    ler
    Illinois Pollutio
    ntrol Board
    17 —209

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