ILLINOIS POLLUTION CONTROL BOARD

August 1, 1974

TEXACO, INC. (Lawrenceville Refinery),

Petitioner,

V.

)

PCB 74—135

ENVIRONMENTAL PROTECTION AGENCY,

Respondent.

James P. Peyton, attorney for Petitioner.

John Palinscar, attorney for Respondent.

OPINION AND ORDER OF THE BOARD (by Dr. Odell)

On April 11, 1974, Texaco, Incorporated (Texaco) filed

with the Illinois Pollution Control Board (Board) a Petition for

Variance from Rule 206(c) of Air Pollution Regulations, Chapter 2

(Chapter 2) until September 15, 1974.

Texaco operates a petroleum refinery adjacent to the

southern boundary of Lawrenceviile, Illinois, which has a population

of 5,900. This refinery manufactures principally liquified

petroleum gas, motor gasolines, aviation fuels, diesel and heating

oils, heavy fuel oil, and asphalt, utilizing approximately 84,000

barrels of crude oil per calendar day in the manufacturing process.

The refined products are distributed for consumption in southern

Illinois, as well as in Indiana, Kentucky, Ohio, Missouri, and

other states. Approximately 600 persons are employed at this

refinery.

The specific emission source which is the subject of this

Petit.ion.for Variance is the catalyst regeneration section of a

Fluid Catalytic Cracking Unit. By a combination of thermal and

catalytic cracking, this unit converts high boili~ig—range gas oils

intoLP gas, gasolines, furnace oil, fuel oil, and coke~. The con-

version is accomplished by mixing the gas oils with air and burn-

ing them in a regenerator vessel. During this process carbon

monoxide is released to the atmosphere in a concentration of

62,000 parts of CO per million parts of air.

Texaco is installing a Carbon Monoxide Boiler, at a cost

of $3,270,000, to control the carbon monoxide emissions which are

the subject of this Petition for Variance. Originally, Texaco

had planned to have its Carbon Monoxide Boiler operative by

December 31, 1973. However, equipment delivery delays and scarcity

of critical craft manpower has revised Texaco’s time schedule as

follows:

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January 20, 1972

Awarded construction contract

October 18, 1972

Commenced construction

June 15, 1974

Complete construction

September 15, 1974

Commence operahion

Texaco alleges that the period from June 15 to September 15, 1974,

is needed to inspect and test the new equipment to avoid possible

injury to personnel or the equipment.

Petitioner stated that the construction delays, which were

due to tardy equipment deliveries and scarcity of critical craft

manpower, were beyond the control of Texaco and their construction

contractor, Bechtel. Texaco alleges that compliance with “Rule

206(c)

prior to the forecasted operational date (September 15, 1974) of

the Carbon Monoxide Boiler would necessitate shutdown of the Fluid

Catalytic Cracking Unit” because of limited storage for charge stock

for the latter Unit, “Cessation of operations would result in a

most unreasonable and arbitrary hardship not only on Petitioner,

but also on Texaco’s distributors and retailers, its employees, and

the general public.” Petitioner claimed that granting this Variance

would have no adverse effect on the public because there is very

little difference in the ca~rbonmonoxide concentration upwind and

downwind from the refinery, as shown by the following results from.

a survey by an outside firm, Air Resources Incorporated, of ambient

air at the perimeter of the plant:

~nMonoxide~oncentration~rn~

~einterval

~indof

~nw~of

~iner~

~iner

1 hour max.

8 hour max.

15 mm. arithmetic mean

A Recommendation was received from the Environmental

Protection Agency (Agency) on June 10, 1974. On the basis of the

catalytic unit charge of 45,000 barrels per day of gas oil, the

Agency calculated carbon monoxide emissions as 25,800 pounds per

hour in a concentration of 62,000 parts of carbon monoxide per

million parts air. Thus, Petitioner currently operates in violation

of Rule 206(c), However, Petitioner is installing a Carbon Monoxide

Boiler to control its emissions by September 15, 1974. There are no

other similar CO sources in the area, and no citizen interviews

were conducted by the Agency because carbon monoxide is odorless and

can be detected only by instrumentation. “The Agency is of the

opinion that the proposed control program, if properly designed and

operating, will achieve compliance with Rule 206(c),” The Agency

(I) denies Petitioner’s alleged economic hardship in this case, but

(2) recognizes that “the hardships caused by a plant shutdown would

be a loss of earnings for Petitioner’s employees, and a disruption

of gasoline and,.other important fuel supplies for the public.” The

Agency recommended that Petitioner be granted a Variance from Rule

206(c)~untilSeptember 15, 1974, subject to certain conditions,

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A hearing was held in Lawrenceville, Illinois, on June

13, 1974, Three Texaco employees testified concerning the

operation of the refinery. Robert B. McBride, Chief Engineer,

explained the delays in the construction of the Carbon Monoxide

Boiler. The first notification of delay from the construction

contractor (Bechtel) was in their progress report for the month

ending September 30, 1973 (Exhibit 2; R,9), At this late date,

no ~alternate solution was available except to complete installation

of the CO Boiler as soon as possible.

Mr. Joe W. Garrison, Supervisor of Air and Water Conservation,

described the ambient air survey that was conducted at the refinery

by Air Resources Incorporated. The samples were taken over a 30~

day period on the top of a van, both upwind and downwind, around

the perimeter of the refinery (R,l9, 21). The amounts of carbon

monoxide measured (with a gas chromatograph) were~tonsiderably

below levels which would be dangerous to human health (R,20), The

carbon monoxide is dispersed from stacks approximately 200 feet

Mr. A.L, Bishop, Plant Manager, explained the highly inte-

grated operation of the refinery and, therefore, if the Fluid

Catalytic Cracking Unit were,shut down cessation of all operations

would necessarily soon follow.

The “Agency is convinced of Petitioner’s good faith efforts”

and recommends that the Variance be granted “subject to the con-

ditions expressed in the Agency Recommendation as amended” (R.30).

The Board concurs except that the suggested condition con-

cerning a Performance Bond ~does not seem necessary at this time,

Texaco committed itself in 1972 to installing a $3,270,000 Carbon

Monoxide Boiler and construction of it was to be completed by

June 15, 1974, according to the record in this case, The main

objective now is proper operation of the equipment to adequately

control carbon monoxide emissions, This Opinion constitutes the

findings ~of fact and conclusions of law of the Board,

IT IS THE ORDER of the Illinois PollutioB Control Board

that Petitioner is hereby granted a Variance from Rule 206(c)

of Air Pollution Regulations, Chapter 2, for its Fluid Catalytic

Cracking Unit at Lawrencevilie, Illinois, from January 1, 1974,

to September 15, 1974, subject to the following conditions:

(a) Petitioner shall make timely application for all

necessary operating permits.

(b) Petitioner shall submit a progress report on

August 10, 1974, to the Agency at the following

address:

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—4

Environmental Protection Agency

Division of Air Pollution Control

2200 Churchill Road

Springfield, Illinois 62706

I, Christan L. Moffett, Clerk of the Illinois Pollution

Control Board, hereby certify that the ove Opinion and Order

was adopted on the j~±dayof

,

1974, by a vote of

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~stanL,Mt

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