State of California AIR RESOURCES BOARD Jack Tar Hotel Garden Room Geary & Van Ness San Francisco, CA August 24, 1977 10:00 a.m. AGENDA Page 77-18-2 Report on Chevron, USA, Richmond Refinery, Low Sulfur 1 Fuel Oil Facility. 77-18-3 Consideration of Model Upset/Breakdown Regulations. 61 77-18-4 Report on Air Pollution Control Problems at Geothermal 232 Power Plants. 77-18-5 Other Business - a. Executive Session - Personnel & Litigation b. Research Proposals ITEM NO.: 77-18-2 Report on Chevron, USA, Richmond Refinery, Low Sulfur Fuel Oil Facility. RECOMMENDATION That the staff be directed to: 1) Continue to follow the progress of the hearings underway in the BAAPCD on the proposed revoking of Chevron's permit-to-operate its No. 4 Crude Unit. 2) Continue to make the appropriate effort to obtain needed data for emissions calculations from Chevron. 3) Report back to the Board on the outcome of the Hearing Board's proceedings. 4) Subpoena the required information if not supplied to the ARB staff. SUMMARY On October 26, 1973 the Bay Area Air Pollution Control District (BAAPCD) granted Standard Oil of California a permit to construct a low sulfur fuel oil (LSFO) facility at its Richmond refinery which would increase the crude refining capacity of the then existing refinery. Because the refinery's capacity was increased, the District placed the condition on Chevron's permit that when operation of the no. 4 Crude Unit began, two other existing crude units had to be shut down so that the LSFO facility could qualify under the District's replacement rule, 1311. Standard agreed to the condition until operation of an expanded facility if that facility had a significant reduction in all pollutant emissions. The District later changed its regulation to allow this condition by adding Section 1311.2 to its regulations. When Standard applied for permit to operate its No. 4 Crude unit in 1976, the district granted the permit but placed on it the condition that two existing cure units should be shut down when the No. 4 Crude Unit was operating. Standard objected to this condition, stating that since the District had changed its regulation to permit an expanded facility to operate, that Section 1311 of the District's regulations was no longer applicable. Accordingly, Standard did not shut down any other crude units when the No. 4 Crude unit began operating. The District subsequently issued two violation notices to Chevron (Standard Oil changed its name to Chevron U.S.A. Inc. on January 1, 1977) for being in violation of the condition on its permit-to-operate and applied to its Hearing Board to have Chevron's permit to operate its No. 4 Crude Unit revoked. The hearings began April 21, 1977 and are still in progress. In reviewing several tables (emission summaries) of refinery pollutant emissions that Standard had supplied to the BAAPCD between July 20, 1973 and October 26, 1973 to support the firm's contention that levels of various pollutants would be reduced with the building of the LSFO Project, the staff of the ARB noted several discrepancies in emission totals for certain pollutants even though the time periods when the emissions occurred were the same. In addition, a hypothetical analysis performed by the BAAPCD staff indicates that by Chevron's operating the new LSFO facility without decommissioning other crude processing units the Refinery is emitting more particulates than it would have without modifications. To verify the accuracy of the emission summaries, the staff twice requested from Chevron the detailed calculations to support the emission totals in the summaries. Chevron, however, has twice refused to supply all of this information, presenting partial information instead. The staff, in a letter dated August 8, 1977, again requested information to substantiate Chevron's claim of emission reductions. In addition the staff requested that four of Chevron's personnel who had been instrumental in calculating the emission totals voluntarily attend the Boards August 24, 1977 meeting. ITEM NO.: 77-18-3 Further Consideration of Model Upset/Breakdown Rule. RECOMMENDATION Adopt Resolution 77-43 which proposes a Model Upset/Breakdown Rule for all air pollution control districts to adopt. SUMMARY At the May 25, 1977 Board meeting, the Board directed the staff to review the upset/breakdown records of the South Coast Air Quality Management District and the Bay Area Air Pollution Control District in order to determine the manner in which these districts handle upset/breakdowns in industry and based upon this review to make recommendations for changes if necessary, to the previously proposed Model Upset/Breakdown Rule. The staff reviewed the upset/breakdown records of each district for the period June 1, 1976 through May 31, 1977, during which time 3918 upset and/or breakdown occurrences were reported, of which approximately 95 percent were determined to be less than 24 hours in duration. Table S-1 illustrates the action taken by the two districts in response to the reported upsets and/or breakdowns. As shown in this table, out of the 3918 reported upsets and/or breakdowns, only 69 resulted in penalty action. As a result of its study, the staff arrived at the following conclusions and recommendations: 1. Most upset/breakdown occurrences are of short duration. 2. Upsets should be excluded from the model rule. 3. Recurrent breakdown of the same equipment appears to be a major problem. 4. The burden for explaining and justifying why an occurrence is a justifiable upset/breakdown must be placed on the source. 5. The districts need to establish clear, separately identifiable procedures for the investigation and enforcement of upset/breakdown occurrences. 6. Monitoring equipment should be included in the model rule, but treated differently. 7. Nonvisible emissions must be reported and verified. 8. There must be a deterrent to false upset/breakdown reports or claims. 9. All upset/breakdown occurrences must be reported. 10. Some upset/breakdowns do not cause violations of the applicable emission standards.