ILLINOIS POLLUTION CONTROL BOARD
October 11,
1973
TEXACO,
INC.
)
(LAWRENCEVILLE REFINERY)
)
)
)
PCB 73-14
)
ENVIRONMENTAL PROTECTION AGENCY
)
Mr. Edwin J.
Buckley appeared for Texaco,
inc.;
Mr. Larry Eaton,
Special Assistant Attorney General, appeared
for the Environmental Protection Agency.
OPINION AND ORDER OF
TFJE BOARD
(by Nr. Dumelle):
Texaco filed
a Petition for Variance from Rule
205(a)
of the Pollution Control Board Regulations, Chapter
2,
Part
II
(Air Rules)
on January
17,
1973.
The Environmental Pro-
tection Agency filed a recommendation on April
9,
1973 to deny
the variance or,
in the alternative,
to grant the variance sub-
ject to certain qualifications.
A hearing was held on May
24,
1973.
Petitioner owns
a refinery immediately adjacent to the
southern boundary of Lawrenceville, Lawrence County,
Illinois,
where
it employs
600 people
in the refining of 92,000 barrels
of crude
oil per day.
Texaco seeks
a variance from the
December 31,
1973 compliance date for control
of hydrocarbon
emissions
from storage tanks, found in Air Rule
205(a), which
prohibits
the storage of volatile organic material in
tanks
larger than 40,000 gallons, unless the tank
is pressurized or
equipped with
a floating roof.
Texaco has
41 stationary tanks larger than 40,000 gallons
located at the Lawrenceville Refinery which
are used
to store
volatile hydrocarbons.
Eight of these
tanks
are pressurized
tanks, and nine have floating roofs.
In addition, three tanks
will be equipped with floating roofs by the i)ecember 31, 1973
compliance date set out in Air Rule
205(a)(2).
Thus,
21 sta-
tionary tanks used
to store volatile organic materials will not
be
in compliance with Air Rule
205(a)
on December 31,
1973,
and
Texaco will be subject to enforcement actions.
It
is for these
21
tanks
that Texaco
is seeking
a variance.
9—441
-2-
These
21 tanks are currently equipped with submerged fill
pipes
and pressure vacuum vents
to limit hydrocarbon emissions.
Hydrocarbon emissions from the
21
tanks are approximately 800
pounds per hour
(R.
11, May 24, 1973).
Texaco alleges that the
emissions
are not significantly reactive
(R.
11, May 24, 1973),
while at the same time,
its
tests
showed that at
least the
aviation gas
is approximately
59o
aromatic
(photochemically
reactive)
(R.
12, May 24, 1973).
Texaco states it will continue
the current program
to remove
tanks from service and equip
them
with floating roofs
so that
it will be
in compliance by July 1.
1977,
at
a cost
of $1,100,000.
Texaco argues
that to force compliance by December 31, 1973
would result in
a significant hardship because Texaco would have
to close down its refinery with the resultant
loss
of l0~of
Texaco’s system-wide production.
The Board finds that Texaco
has established the need for a variance as
to
the five crude oil
tanks
(##579,
582,
578,
583, and 584)
in that
to remove more than
one crude
tank from service would place
a restriction upon the
refinery operations.
Mr. Robert
B. McBride, Texaco’s Chief Engineer, testified
that it would be possible to accelerate the compliance schedule
if Texaco had more than one field and two shop engineers
(R.
467,
May
24,
1973).
Mr.
Lester A.
Wilkes, Supervisor
of Operations
for Texaco, testified that
there
is
no reason why the
work
could not be accelerated on~the aviation gas tanks
except for
engineering
manpower
limitations
(R.
59,
May
24,
1973),
He
further testified
that
it would be possible to take more than two
motor gas tanks
out of service toward the end of the summer peak
demand period without extremely adversely affecting the refinery
(R.
65, May 24, 1973).
The Board finds
that Texaco has not met the burden of show-
ing that
it
is entitled to
a variance for the aviation gas, motor
gas and miscellaneous.tanks.
It has not clearly shown that
additional
engineering manpower is not available.
Texaco’s own
witness’
testimony clearly shows
that
it would be possible to
accelerate
the compliance
of
the aviation gas, motor gas, and
miscellaneous tanks provided additional engineering manpower was
used
This Opinion constitutes the findings
of fact and conclu-
sions
of
law of the Board.
-3-
ORDER
The Pollution Control Board hereby grants
a variance until
October
11, 1974 from Air Rule 205(a) for five crude oil tanks
(Numbers:
579,
582,
578,
583 and 584).
The Board denies,
without prejudice,
a variance from Air Rule
205(a) for the
motor gas, aviation gas and miscellaneous tanks.
This Order
is subject
to the following conditions:
1.
Texaco
is
to submit
a list of those tanks
to be refitted
prior to October 11, 1974
to the Agency;
2.
Texaco
is to submit progress reports
at 60-day intervals
to the Agency;
3.
Texaco is to post, within
35 days of the date
of this Order,
in a form satisfactory
to the Agency,
a performance bond
equal to $100,000, which bond shall be released in the
amount of $20,000 for each crude
tank that
is refitted, said
bond shall be sent to:
Illinois Environmental Protection
Agency,
Fiscal
Services
Section,
2200
Churchill
Road,’
Springfield,
Illinois
62706.
I, Christan L. Moffett, Clerk of the Illinois Pollution Control
Board, hereby certify the above Opinion and Order were adopted on
the
j/’~’
day of October,
1973 by
a vote of
~—O
rk
Illinois Pollution
rol Board
9
643
V
V