ILLINOIS POLLUTION CONTROL BOARD
June 20, 1974
AMOCO
CHEMICALS
CORP.
PETITIONER
)
PCB 74-121
v.
)
PCB 74—122
)
PCB 74—123
)
ENVIRONMENTAL
PROTECTION
AGENCY
)
RESPONDENT
OPINION
AND
ORDER
OF
THE
BOARD
(by
Mr.
Marder)
These
cases
come
to
the-
Board
on
Petition
of
Amoco
Chemicals
Corp.,
filed
April
21,
1974.
PCB
74—121
requests
a
variance
from
Rule
204
(f)
for
operation
of Petitioner’s multi-purpose additives plant at Amoco Oil’s Wood
River
Refinery,
until
February
28,
1975.
PCB
74-122
requests
variance
from
Rule
205
(g)
for
operation
of
Petitioner’s detergent additives plant,
at Amoco Oil’s Wood River
Refinery, until February 21, 1975.
PCB 74-123 requests variance from Rule 205
(g) for operation of
Petitioner’s multi—purpose additive plant,
at Amoco Oil’s Wood Riv—
er Refinery until March
31,
1975.
These Petitions are related to variances granted in PCB 73-399,
73-400,
73-401.
In these matters the Board granted variances for
the
units
until
June
30, 1974.
The reader is urged to refer to our earlier opinion on these mat-
ters as to the units’ operations and the control methodology being
installed
(PCB 73—397
—
401,
December 20, 1973,
Vol.
10, Pg.
439,
of the Board’s published opinions).
No hearing was held.
PCB 74—121: The Agency in its recommendation suggests that this
variance only be granted until January
21,
1975.
Petitioner states as its reason for variance extension that key
equipment will not~bedelivered on time,
in order to comply with
our earlier Order.
Petitioner further alleges that other than the
proposed control system,
the only other way to comply
is to shut down
the unit.
12
—
595
—2—
Petitioner has submitted documents showing an effort to expeditious-
ly complete its control system (Exhibits A,B, and C attached to Petition)
The Board finds that Petitioner is diligently pursuing its control pro-
gram.
Petitioner alleges, and submits supporting documents,
that at monhior
ing stations surrounding the Wood River Refinery the Federal Primary ~nd
Secondary Ambient Air Quality Criteria are being met for sulphur dioxide
while this unit is operating.
Therefore, Petitioner alleges that
there
will be no adverse environmental impact on the ambient air quality
in
the area
(Petition Pp.
2-3, Exhibit D attached).
The Agency concurs
that Petitioner’s program will aid in attainment of the Federal Mnbient
Air Quality Standards
(Agency Rec.
P.
4).
The Agency further states that it has received no comments from the
public regarding this variance (Agency Rec.
p.
4)
The Agency believes that
as Petitioner’s past compliance has been
timely and cooperative that Petitioner’s action in seeking this variance
extension is
in good faith
(Agency Rec.
P.
3).
The Agency only objects
to the sketchy timetable for completion, and
therefore recommends that variance be granted only until January
31,
1975.
The Board feels that since we are talking about a month~sdelay
only,
that
the Board will grant the variance for the full time requested,
subject
to
the
condition
that
monthly
reports
be filed with the Agency,
and that Petitioner shall complete its project in the shortest possible
time.
PCB
74-122:
The Agency recommends
that this variance be granted only
until December 31,
1974.
Petitioner is requesting an extension of a variance granted by the
Board in PCB 73-400 from Rule 205
(g)
for operation of its detergent
additives plant until February 21,
1975.
Petitioner states as reason for its variance extension request that
after testing and research,
it was not able to eliminate a step in their
processing which was hoped would eliminate the emission problem.
Elim-
ination of the process step caused a product that did not prove adequate
when tested in two series of tests, ending in the fall of 1973 and Feb.
21, 1974
(Pet.
P.
2)
Since Amoco must now return their filtration step in the process, it
feels that 12 months
are necessary in order to bring the unit into
corn—
pliance
(Pet.
p.
3).
This work will entail modifications in the com-
pletely enclosed pressure system (Agency Rec.
P.
2).
Petitioner alleges, and has provided supporting documents
(Exhibit
A attached to Petition)
referring to a study
done in December 1972 and
January 1973, that Petitioner’s hydrocarbon emissions did not cause am
blent concentrations likely to produce damage to vegetation, humans, c
animals.
(Pet.
P.
3)
Amoco also alleges that changes over the year
since the test was conducted would show significant reductions In
emi~
ions ly Petitioner,
and, in fact,
others in the area
(Pet.
P.
3).
—3—
Amoco has assumed that if total ambient hydrocarbon levels were due
to Amoco, the unit in question would still only amount to 0.009 ppm
(Pet.
P.
4).
The Agency states that based on information supplied by the Petition-
er, non-methane hydrocarbons were 2.02 ppm during a test period a year
ago.
The allowable ambient air standard is
.24 ppm hydrocarbons.
The
Agency also mentions Petitioner’s
allegation that hydrocarbon emissions
have been reduced by 2/3 since the tests were conducted
(Agency Rec.
P.
3).
The Agency is of the opinion that the proposed control system will
bring Petitioner’s unit into compliance with Rule 205
(g)
(Agency Rec.
p.
3).
The Agency also feels that Petitioner
is exercising good faith and
diligence in seeking the variance extension (Agency Rec.
P.
3).
The Agency only objects to the length of time requested by Petition-
er for the variance.
The Agency feels the variance should only be ex-
tended until December 31, 1974, because of Petitioner’s
failure to
allege a proper time schedule for project completion.
Also,
the Agency
feels that Petitioner’s emissions are so much above the standard that
the unit should be brought into compliance as soon as possible.
The
Board
will
grant
Amoco
the
variance
for
the
time
requested,
subject
to
its
filing
a
project
completion
schedule
with
the
Board
and
the
Agency
within 21 days of the issuance of this Order.
PCB 74-123: The Agency tecommends that this variance be granted un-
til December 31, 1974.
Petitioner states as its reason for extensionof its previously
granted variance that late equipment delivery precludes
completion of
the control project before the expiration of the previously granted
variance.
Amoco
has
experienced
difficulty
in
preparation
of
a
cost
estimate.
There was also a two—month delay in an appropriation approval from the
company
headquarters.
Amoco has also experienced numerous delays
in receiving approval
drawings
from
its
supplier.
An
order
was
placed
on
December
7,
1973.
Approval
drawings
were
to
be
received by Petitioner six weeks
after
placing the order, but to the date of the Petition they had not been
received.
Amoco alleged that certain of the equipment would be delivered in
early
May,
1974.
If
this equipment is received and installed,
over
one—half of the emissions will be eliminated by June
30, 1974
(Pet.
P.
2)
Petitioner alleges that emissions from the entire refinery are not
dangerous
to
vegetation,
humans,
or
animals.
Hourly
concentrations
12—59~
—4—
in
excess
of
0.08
ppm
could
have
been
expected
only
twice
a
year
stead of only once as permitted by the national primary and ambient
air quality standards.
(Pet.
P.
3)
Assuming Petitioner is responsible
for
ambient
hydrocarbons,
taking this unit as a
3.4
contributor
total refinery, this unit’s contribution can be estimated at .069
ambient concentration
(Pet.
P.
3, Exhibit A attached to Petition),
The
Agency
in
its
recommendation
states
that
there
are
numerous
other
sources
in
the
area.
While the allowable ambient
air
standard
is
0.24,
testing
last
year
by Petitioner showed the average non-methane
hydrocarbon
level
at
2.02
ppm
(Agency
Rec.
p.
3).
The
Agency
is
of
the
opinion
that
this
control
program
will
about
compliance
with
Rule
205
(g).
The
Agency
also
states its belief that Petitioner is
exercising
good faith in its request for this variance (Agency Rec.
P.
3).
The Agency’s sole objection to the requested variance is to
length.
The Agency
believes
that
Petitioner
should
be
able
to
work on
the
control system by December 31, 1974 (Agency Rec.
P.
whereas Petitioner is requesting additional time to allow for
ment delivery slippage
(Pet. P~
~).
The
Board finds that Amoco shall be granted a variance from
205
(g) for the full time requested,
subject
to
the
condition
equipment
is
received,
it
shall
be
installed
as
soon
as
possible
placed
in
operation.
Hardship
for
granting
these
variances
was
adequately
proved
earlier
cases,
but
as
a
brief
resume,
the
~oard
found
that
should
these
variances
not
be
granted,
the
only
method
of
controlling
emissions
from
these
units
is
by
shut.ting
them
down.
Such
shutdown
would
then
necessitate
closing
the
entire
refinezy,
thereby
causing
lack
ot
110,000
barrels
of
oil
being
refined.
This
would
cause
stantial loss
to the Petitioner and to the public.
This Opinion constitutes the
findings
of
fact
and
conclusions
law
of
the
Board.
ORDER
IT
IS
THE
ORDER of the Pollution Control Board that:
1)
Petitioner
is granted
a variance
from
Rule
204
(f)
of
the
Board’s Rules and Aegulations
for
its
multi-purpose
additiv
plant until Februari
2B,
1075,
or to the
date
when
the
posed control equipment
Is installed, whichever is shorter.
2)
Petitioner
is granted
a variance from Rule 205
(g)
of the
Board’s
Rules an~r~eguiaticnsfor its detergent additives
plant, until February ~
1~75 or
to
the
date,
when
the
—5—
proposed control system is completed, whichever is shorter,
subject to the condition that Petitioner submit within 21
days of the issuance of this Order a project completion
schedule as to its compliance program.
3)
Petitioner
is granted variance from Rule 205
(g)
for oper-
ation of its multi-purpose additives plant until March
31,
1975, or to the date when the proposed control equipment
is installed, whichever is shorter, subject to the condition
that
as such control equipment is received,
it shall be put
into service as
soon as possible.
Orders 1,
2, and
3 above are conditioned by the following:
A)
Petitioner shall apply for all necessary construction and
operating permits from the Agency.
B)
Petitioner shall supply monthly progress reports to the
Agency on the control equipment projects for the three
units and a final report upon completion of each project.
C)
Petitioner shall keep in effect the bond ordered in the
previous opinion of the Board for $50,000
to guarantee
installation of air pollution control equipment as ord-
ered above.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board,
certify that the above Opinion and Order was adopted by the
Board on the 20th day of
June,
1974,
by a vote of
5 to
0,
12
599