ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA 330/2-76-008
REPORT ON
State Implementation Plan
Air Pollution Inspection
of
At Ian tic-Rich field Company
LOS ANGELES COUNTY, CALIFORNIA
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
DENVER. COLORADO
AND
REGION IX, SAN FRANCISCO, CALIFORNIA
FEBRUARY 1976
-------
ENVIRONMENTAL PROTECTION AGENCY
Office of Enforcement
STATE IMPLEMENTATION PLAN
INSPECTION OF
ATLANTIC-RICHFIELD COMPANY
WATSON REFINERY
Carson, California
February 1976
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER - Denver, Colorado
and
REGION IX - San Francisco, California
-------
CONTENTS
Introduction 1
Process Description 3
Potential Sources of Air
Pollution Emissions and
Related Control Equipment ... 6
Emissions Data 14
Summary of Violations 21
Inspection Summary 21
Appendix
A NEIC Request Letter
B LAAPCD Rules
C Process Heater and Steam Boiler Listing
D Internal Combustion Engine Listing
E Storage Tank Listing
F Flare Systems
G Product Loading Racks
H Wastewater Treatment Facilities
I Sulfur Plant Details
J Source Test Results
-------
STATE IMPLEMENTATION PLAN
INSPECTION OF
ATLANTIC-RICHFIELD COMPANY
WATSON REFINERY
1801 E. Sepulveda Blvd.
Carson, California
(213) 834-2521
September 24, 1975
INTRODUCTION
Background
Atlantic-Richfield Company (ARCO) operates an integrated petroleum
refinery at this location with a rated capacity of 29,400 m3 (185,000
bbls) of crude oil per day. Major products from this refinery include
jet fuels, diesel fuel, gasoline, fuel oil, petroleum coke, liquid
petroleum gas (LPG), lube oil blends and a variety of solvents including
benzene, toluene, and xylene (BTX).
The Watson Refinery employs about 1,110 people; of these about 350
are involved in operations, 400 in maintenance, and the remainder in
administration. The facility operates three 8-hour shifts, seven days
per week, year around.
On September 24-25, 1975, a process inspection was conducted at
this facility by NEIC personnel. The inspection was preceded by a
letter to the Company [Appendix A] on September 8, 1975, announcing
NEIC's intention to inspect the facility and requesting substantial
amounts of process and source information. Subsequent to the inspection,
ARCO personnel transmitted the requested information by mail.
-------
During the inspection, an examination was made of the refining
equipment, potential air pollution sources, and air pollution control
equipment. The purpose of this inspection was to evaluate the degree of
compliance of this facility with the requirements of the Federally
approved State Implementation Plan as required by Section 110 of the
Clean Air Act, as amended.
Company personnel were highly cooperative throughout this inspection.
They supplied all information EPA requested during the inspection
interview or by subsequent follow-up letter.
Inspection Participants
Mr. C. L. Heinrich - Manager, Air and Water Conservation (ARCO)
Mr. Raak Veblen - State of California Air Resources Board (ARB)
Mr. Nathan L. Zlasney - Los Angeles County Air Pollution Control
District (LAAPCD)
Mr. Lloyd Kostow - USEPA, Region IX
Dr. Wayne C. Smith - USEPA, NEIC
Mr. David L. Brooman - USEPA, NEIC
Applicable Regulations
The following rules contained in the Rules and Regulations of the
Los Angeles County Air Pollution Control District (LAAPCD) [detailed in
Appendix B] are applicable to the State Implementation Plan for this
facility:
Rule 50. Ringelmann Chart
Rule 51. Nuisance
Rule 52. Particulate Matter - Concentration
-------
Rule 53. Sulfur Compounds - Concentration
Pule 63.2. Sulfur Recovery Units
Rule 54. Solid Particulate Matter - Weight
Rule 56. Storage of Petroleum Products
Rule 59. Effluent Oil/Water Separators
Rule 61. Organic Liquid Loading
Rule 62. Sulfur Content of Fuels
Rule 67. Fuel Burning Equipment
Rule 68. Fuel Burning Equipment - Combustion Contaminants
Rule 69. Vacuum Producing Devices or Systems
Rule 71. Carbon Monoxide
Rule 72. Pumps and Compressors
Rule 73. Safety Pressure Valves
PROCESS DESCRIPTION
The ARCO Watson Refinery processes crude oil received from several
locations. Approximately 50$ of the crude is received from domestic
sources (i.e., California) and the other SQ% from Arabian, Indonesian,
and Alaskan sources. Crude oil is delivered to the refinery location by
pipeline. Primary products include LP6, gasoline, jet fuel, diesel
fuel, fuel oil, petroleum coke, ethylene, and solvents, including
benzene, toluene, and xylene (BTX).
Major processes used at this refinery include crude desalting,
atmospheric distillation, vacuum distillation, delayed coking, thermal
cracking and visbreaking, superfractionation, catalytic cracking, hydro-
cracking, catalytic reforming, hydrotreating, isomerization, alkylation,
polymerization, BTX production, hydrogenation, hydrogen production, and
sulfur recovery. A simplified process block flow diagram for the
facility is shown in Figure 1. Table 1 lists the unit capacities for
each of these processes.
-------
FIGURE 1
ARCO
WATSON REFIHERY
SIMPLIFIED FLOU DIAGRAM
OILS
SOLVENTS
FIVE
CRUDE
DISTILLATION
WITS
STRAIGHT RUN
GASOLINE
LIGHT ENDS
FRACT10NATION
STOVE OIL
DIESEL
Tl/0
VACJUH
DISTILLATION
UNITS
LIGHT GAS
HYDROCRACXER
HEAVY GAS OIL ^
FUELS
THEPI1AL
CRACKING
UiUTS
JL
FLUID
CATALYTIC
CRACKING UNIT
PETROCHEMICAL
STOCKS
BEKZWE
TOLUENE
XYLENE
UNIT
PETROCHEMICALS
TUP
GASOLINE BASE
TWO REFORMERS
JET FUFL STOCK
IS03UTANE
JET FUEL
HYDROTREATER
GASOLINE
BLENDING
JET FUEL
ETUME.
THREE
ALKYLATIOft UNITS
ALKYLATE
CAT. GASOLINE '
ETHYLEME UNIT
RESIDUUM
TWO
DELAYED
COKERS
THF9I1AI I TGHT ENDS
I
JET_FJ1EL_SJQCJL
MYDROGEHATIOn
UNITS
CATALYTIC GASOLIKf
THERMAL
FRACTIOKATIOH
THERMAL GASOLINE
LOU SULFUR FUEL
I COKE
-------
Table 1
PROCESS UNITS AND RATED CAPACITIES
ARCO Watson Refinery
Process Unit
# 2 Crude Unit
# 3 Crude Unit
t 4 Crude Unit ...
* 6 Crude Topping Unit
# 81 Combination Unit
Crude
Visbreaking
# 82 Combination Unit
Crude
Cycle Oil Cracking
# 51 Vacuum Unit.,
* 52 Vacuum UnitTT
Superf racti onati on
Stabilizers (#1 through 12)
Gasoline Splitter
Light Ends Depropanizer
nCg Iso Siv
Solvent Fracti onati on (2 towers)
* 1 Alkylation
# 2 Alkylation
# 3 Alkylation
Napthanic Acid RR
Fluid Catalytic Cracking (FCC Unit)
Catalytic Poly Plant
Tetromer Plant
# 1 Reformer & Desulfurizer
# 2 Reformer & Desulfurizer
Light Cat. Gaso. Hydrogenation
Heavy Cat. Gaso. Hydrogenation
Benzene-Toluene Unit
Udex
Ethylene Unit
# 1 Coker
# 2 Coker
Hydrogen PHant 1
Hydrocracker
Jet Fuel Hydrotreater
Mid-Barrel Desulfurizer
DEA Regenerators. (4)
C,/CC Isom. Unit
D 0
Sulfur Plant
t SD = Stream Day; All units are m /SD
tt Units currently out of service.
(m3/SD)
6,400
4,000
4,500
3,200
6,400
6,700
6,400
2,000
12,000
3,000
4,000
2,900
2,500
320
570 ea.
290
380
480
32
9,100
380
760
2,200
3,200
1,600
1,300
1,000
640
100 M kg/day
3,200
1,600
,400 M m3/SD
3,100
950
2,900
2,300 ea.
2,100
180 m.ton/SD
Capacity
(barrels/SD)1"
40,000
25,000
28,000
20,000
40,000
42,000
40,000
12,500
74,000
19,000
25,000
18,000
16,000
2,000
3,600 ea.
1,850
2,400
3,000
200
57,000
2,400
4,800
14,000
20,000
10,000
8,000
6,500
4,000
220 M Ib/day
20,000
10,000
50,000 MCSF/SD
19,700
6,000
18,000
14,400 ea.
13,000
180 LT/SD
or bbls/SD unless noted.
-------
POTENTIAL SOURCES OF AIR POLLUTION EMISSIONS AND RELATED CONTROL EQUIPMENT
Although the ARCO Watson Refinery is an extremely complex facility,
there are relatively few large discrete potential sources of air pol-
lutant emissions. With the exception of the fluid catalytic cracking
(FCC) unit, the major unit processes at the refinery are closed systems
and release of materials to the atmosphere is discouraged because such
releases would result in loss of product. The process heaters attendant
to these units constitute the main emission sources.
There are also a myriad of relatively small potential sources of
emissions related to the operation of the refinery. Such sources in-
clude leaks from valve seals, pump seals and pipe flanges, and evaporative
losses from storage tanks and process wastewater drains. Potential
sources of emissions and their related control equipment are discussed below.
Process Heaters and Boilers
There are sixty-one process heaters and six steam boilers at this
refinery ranging in size from 0.5 X 106 to 115 X 106 kg cal (2 X 106 to
450 X 10 BTU) per hour. A complete listing of these units is presented
in Appendix C. Two of the boilers are used as spare equipment and nine
of the process heaters are currently idle.
The majority of these units utilize refinery fuel gas as fuel. The
remainder can be fueled with either refinery gas or fuel oil.
Except for the carbon monoxide (CO) boiler at the FCC unit which
will be discussed later, none of the process heaters or boilers are
equipped with emission control devices. Most of those units which can
be fueled with either refinery gas or fuel oil are equipped with stack
gas opacity detectors and indicator alarms which alert the operators to
combustion abnormalities.
-------
Sulfur oxide emissions from these units are controlled by limiting
the sulfur content of the fuels burned. Refinery gas must be desulfur-
3 3
ized to less than 1.1 gm/m (50 grains per 100 ft ) of sulfur compounds.
Fuel oil used in stationary fuel burning equipment is produced in the
refinery from low sulfur crude. The sulfur content of the fuel is less
than 0.5% by weight.
Internal Combustion Engines
Eight stationary internal combustion engines are used at this
refinery. All drive compressors and use natural gas as fuel. Three of
the units are rated at 2,600 kg cal/min (240 Hp) each and are utilized
on the vapor recovery system. The remaining five units are rated at
6,400 kg cal/min (600 Hp) each and are used to pump low pressure process
gas through the di-ethanol-amine (DEA) treatment plant and into the
refinery fuel gas system. Details on these engines are included in
Appendix D. None of these internal combustion engines have emission
control equipment.
Storage Tanks
3
The 200 storage tanks at this facility, ranging in size from 64 m
to 26,000 m3 (400 to 165,000 bbls), are used to store a wide variety of
hydrocarbon materials. Due to the volatile nature of some of these
compounds, the potential exists for substantial emissions of hydrocarbon
vapors from these tanks. Where this potential exists, the materials are
stored in specially constructed tanks, such as pressure vessels, and
floating roof tanks, or in tanks which are hard piped by manifold systems
to vapor recovery systems.
-------
8
The vapor recovery system consists of a pipe network serving 42
hydrocarbon storage tanks, two truck loading facilities, and several
additional connections at the LPG loading racks. Vacuum is maintained
by a bank of compressors (discussed above) which discharge into the
refinery fuel gas system.
A summary of the storage tanks at this facility, their con-
figuration, and the materials stored within is presented in Appendix E.
Slowdown Systems
The majority of process units have emergency relief valves which
are connected to a manifolded header system. Should a situation arise
such that it is necessary to rapidly release quantities of liquids and
gases from a unit, they are routed to the manifold system and ultimately
combusted in a flare.
There are four flares at this refinery. One flare vents the fluid
catalytic cracker, one the delayed coker, one the hydrocracker, and one
is used as a pressure regulation device for the fuel gas system. All
four flares are equipped with John Zink Co. smokeless flare tips.
Details pertaining to the flare units and the processes which blow down
to them are presented in Appendix F.
Most of the blowdown systems are operated only on an as-needed
basis, i.e., intermittently. Only the delayed coker systems are used
continuously. This system scrubs and cools vapors from the coke drums
during the heating and cooling cycles. Scrubbed vapors are subsequently
routed to the coker flare. The steaming cycle for each drum lasts
approximately seven hours. Normally, three drums are decoked each day.
-------
Vacuum Jets
The only vacuum jet systems in use at this facility are located at
the vacuum crude distillation units. These units operate as closed
systems. Gases from the vacuum towers are compressed, scrubbed through
a DEA absorber and discharged to the refinery fuel gas system.
Fluid Catalytic Cracking Unit
Spent catalyst from the FCC unit is continuously removed from the
reactor portion and introduced through piping into the catalyst regenera-
tion portion. Here the petroleum coke, tars, and other residual deposits
which form on the catalyst surface are burned off the catalyst fines.
The recovered catalyst is then recycled to the reactor. Catalyst
particles which are entrained in the exhaust gases are partially captured
by a series of cyclone separators internal to the regenerator unit.
Particles captured by these cyclones are returned to the regenerator.
The regenerator unit exhaust gases contain considerable amounts of
carbon monoxide, particulate matter, aldehydes, sulfur oxides, ammonia,
and oxides of nitrogen. To minimize the emissions of carbon monoxide
(CO) and to recover the fuel value of this material, the regenerator
exhaust gases are combusted in a waste heat boiler. The CO boiler exhaust
gases are then passed through a Buell Model 22 X A-240-1080 electro-
static precipitator (ESP) consisting of two parallel banks with two
stages per bank.
The CO boiler and ESP were installed in 1954. During the last two
years, the ESP units have undergone extensive modifications. The
insulators, wires and plates were all replaced and the electrical
rectifier circuitry was revamped.
-------
10
ARCO is currently constructing a new Research Cottrell ESP unit.
This unit will operate in place of, or in parallel with, the existing
ESP. The new unit is anticipated to be on line by mid-1976. An authority
to construct (ATC) has been issued to ARCO by the LAAPCD for this new
unit.
The existing Buell ESP unit requires ammonia injection; that is,
ammonia gas is injected into the inlet gas stream to the ESP to improve
the ionization of the gas. The new Research Cottrell unit will not
require ammonia injection.
Each bank of the Buell ESP discharges to its own 1.8 m (6 ft)
diameter stack which is equipped with a Bailey opacity meter. These
units have recorders and alarms located in the CO boiler control room.
Product Loading Racks
LP gas, various grades of gasoline, solvents, jet fuel, diesel
fuel, and light and heavy distillates are all shipped from the refinery
by truck or rail car. Except for the diesel fuel and the light and
heavy distillates, all of these materials have vapor pressures greater
p
than 0.105 kg/cm (1.5 psia) at actual loading conditions. Hence, the
loading racks for these materials must be equipped with vapor recovery
systems.
At ARCO the truck and rail loading racks for LP gas use an equal-
izing line during loading. After the filling operation is completed,
the loading hoses are back-evacuated through the vapor recovery system.
The truck loading facilities for gasoline, solvent, and jet fuel
loading are equipped with tight neoprene seals for the truck hatches and
vapor return lines to the main vapor recovery system. The recovery
system discharges into the refinery fuel gas system.
-------
11
Appendix G summarizes the information available on the various
product loading racks.
Odor Abatement Incinerator
ARCO operates an odor abatement incinerator used to burn sour gases
which are considered unusable or non-recoverable. The unit is rated at
1.3 X 106 kg cal (5 X 106 BTU) per hr and uses supplemental fuel gas at
a rate of approximately 65 std. m3/hr (2,300 SCFH).
Wastewater Treatment Facilities
A schematic drawing of the ARCO wastewater treatment facilities is
presented in Appendix H. Essentially, there are four types of waste-
water flow; sour water drainage, process drainage, tank farm drainage,
and blowdowns from cooling towers, boilers, softeners, etc.
The blowdowns receive essentially no treatment before being dis-
charged directly to the Dominguez Channel. This flow amounts to approxi-
mately 1,200 m3 (320,000 gal)/day.
The sour water is treated in sour water strippers and sour water
oxidizers before being discharged to the County Sanitation District
sewer system.
The process area wastewaters and tank farm drainage normally pass
through a series of oil traps and API oil separators, and skimmed oil is
recovered and sent to slop storage tanks for reprocessing in the refinery.
Oil traps No. 4 and 6 are covered with floating roofs as is the forebay
-------
12
of the API separator No. 7. The combined process wastewater flow
leaving the API separators is neutralized with caustic or acid, floc-
culated with alum and polymers, and subjected to air flotation for
additional oil removal. The effluent from the air flotation unit is
discharged to the County Sanitation District sewers. The total flow
rate to these sewers from ARCO amounts to 18,000 m (4.7 X 10 gal) per
day. The oil skimmings from the flotation unit are sent to slop storage.
During storm periods, all process wastewaters, sour water after
stripping and oxidizing, runoff from tank farm areas and blowdowns can
53 6
be diverted to a 1.9 X 10 m (50 X 10 gal) storage reservoir. Any,oil
which appears on the surface of this reservoir is skimmed off and
returned to slop storage. The wastewater is then returned to the County
sewer lines at off-peak periods.
ARCO has installed an activated carbon adsorption plant for the
removal of oils and other organic materials from the wastewater. In
*? 6
theory, up to 16,000 m (4.2 X 10 gal) per day of wastewater could be
treated through the activated carbon beds and discharged directly to the
Dominguez Channel. The activated carbon would be regenerated in a
furnace on site. As of the date of this inspection, ARCO was not using
the activated carbon system because the chromium content of the treated
wastewater exceeded the levels allowable for wastewaters discharged to
the Channel.
Sulfur plant
There are three 3-stage Claus units at ARCO's sulfur recovery
plant. Each is rated at 90 m. tons (90 long tons) per stream day of
elemental sulfur. Normal operations necessitate that only two units be
on stream at any time with the third unit being held in reserve. A
schematic diagram of a typical Claus plant is shown in Appendix I.
-------
13
In the Glaus process, hydrogen sulfide (H2S) is burned to form
sulfur dioxide (S02). The S02 and H2S react in the presence of a
bauxite catalyst to form elemental sulfur and water vapor. Typical
sulfur recovery efficiencies for Claus plants are 85% for one catalytic
stage, 94% for two stages, and 97% for three stages.
Currently the tail gases (i.e. exhaust emissions) from the Claus
plants are routed to an incinerator unit. Here, any hLS which is not
converted in the Claus units is burned to S02- The current S02
emissions from this incinerator vary from approximately 5,500 to 7,000
ppmv [Appendix I].
In order to comply with the requirements of Rule 53.2 of the LAAPCD
regulations, the tail gas sulfur concentration must be less than 500
ppmv calculated as sulfur dioxide. In order to achieve this level, ARCO
contracted with J. F. Pritchard and Co. for the installation of a
Cleanair tail gas treatment unit. The Cleanair system is also shown
schematically in Appendix I.
In the first stage of the Cleanair process, carbonyl sulfide (COS)
and carbon disulfide (C$2), which are formed in the Claus plant, are
converted to H2$ by use of a reducing and hydrolysis catalyst. Carbon
dioxide is also decomposed to CO to prevent the recurrence of COS.
In the next stage, the first stage effluent gases are quenched to
reduce temperature and remove water and entrained sulfur. The cooled
gas is fed into a reactor where S02 and H2S react to form both water and
sulfur and are removed.
The effluent gases from the second stage are routed to a Stretford
solution absorption unit. Here, any residual H^S is absorbed and
oxidized to elemental sulfur. The resulting colloidal sulfur is removed
-------
14
from the solution by froth flotation. The purified gases are then sent
to an incinerator to oxidize residual sulfur to SOg and CO to C02.
ARCO has had considerable trouble with the start-up and operation
of the Cleanair system. To date, the unit has not had a complete day of
successful operation. J. F. Pritchard & Co. is continuing to affect
modifications to the units but has not been successful to date.
When it became evident that the Cleanair system would not operate
satisfactorily, ARCO undertook the design of a completely new tail gas
clean-up unit. The unit is proprietary and, hence, no design or operating
details are available.
ARCO first petitioned the LAAPCD Hearing Board for a variance from
Rule 53.2 on June 19, 1973. Rule 53.2 requires that sulfur recovery
plants discharge no more than 500 ppmv of sulfur compounds measured as
SOp. Subsequently, several additional variances have been granted to
ARCO as they have attempted to bring one or the other of the tail gas
plants on stream. The current variance runs through February 19, 1976.
Copies of the most recent variances are attached in Appendix I.
EMISSIONS DATA
Source Test Data
NEIC personnel requested that ARCO supply copies of all stack tests
conducted at the facility since 1972. The LAAPCD was requested to do
likewise. The data obtained is summarized below.
FCC Unit Emissions. ARCO submitted a copy of the source test
conducted on the two electrostatic precipitator (ESP) exhaust stacks
-------
15
attendant to the FCC unit CO boiler. These tests were conducted on May
7, 1975 by Truesdail Laboratories, Inc. of Los Angeles, California. A
copy of the test results is included in Appendix J. No details are
given for the operating conditions for the FCC unit and/or the CO
boiler during the test run. It also is not possible to determine from
the data whether the test was conducted at start-of-run conditions on
the FCC unit or near the turnaround time.
According to the Truesdail test results, the total emissions from
both stacks of the ESP unit amounted to 4,490 dry m3/minute (158,400
DSCFM) and a particulate emission rate of 4.9 kg (10.8 lb)/hour using
EPA Method 5 sampling techniques.
It should be pointed out that Truesdail adjusted the weight of
material collected during the sampling run for ammonium sulfate concen-
tration. The particulate matter collected was analyzed for ammonium
(NH. ) ion. All ammonium ion found was considered to be complexed as
ammonium sulfate. The calculated weight of ammonium sulfate was sub-
tracted from the total weight of sample collected before the emission
rates were calculated.
Truesdail's rationale for making this "correction" is not directly
stated in the test results. However, it appears that the reason is
related to the fact that ARCO must inject ammonia gas into the ESP unit
to obtain desirable operating conditions. The ammonia apparently
improves the ionization of the gases within the ESP. The injected
ammonia reportedly reacts with sulfur compounds present in the FCC
regenerator off-gases to form ammonium sulfate. Since ARCO must add the
ammonia in order to obtain the desired ESP operating efficiency, Truesdail
apparently rationalizes that they should not be penalized for the
resulting formation of ammonium sulfate.
-------
16
Truesdail also obtained limited nitrogen oxides emission data on
this unit during the test program. Nitrogen oxides concentrations of
141 to 146 ppmv as N02 were found.
From July 1972 to June 1973, ARCO participated in a comprehensive
study of oxides of nitrogen (NO ) emissions from stationary sources in
A
the South Coast Air Basin. The study was conducted by KVB Engineering,
Inc. under contract to the State of California Air Resources Board
(ARB). The exhaust from the FCC unit CO boiler was analyzed during this
study. N02 emissions ranged from 90 to 99 kg (197 to 217 Ib) per hour
at concentrations of 126 to 138 ppmv corrected to 3% oxygen in the flue
gas.
ARCO analyzes the exhaust gases from several refinery processes on
a semi-annual basis to determine the sulfur oxide emissions from these
units. The FCC exhaust is one such unit. The results of the tests
conducted during January-February, 1975 are shown in Appendix J. The
range of data obtained from the FCC units during these tests was from
325 to 475 ppmv as sulfur dioxide (S02).
Process Heaters and Boilers. Exhaust gases from four process
heaters and two process steam boilers were analyzed for NO emissions
during the previously referenced KVB Engineering, Inc. study. Table 2
summarizes the results of this study.
Odor Abatement Incinerator. The odor abatement incinerator exhaust
was analyzed for S02 emissions during the aforementioned ARCO semi-
annual test program. S02 emissions were found to range from 105 to 365
ppmv.
-------
Table 2
SUM1AR3 OF KVB ENGINEERING, INC. SOURCE TEST DATA
ARCO Watson Refinery - Process Heaters and Steam Boilers
Unit
MM
Process Steam
Boiler #42
Process Steam
Boiler #31
Test 1
Test 2
Test 3
Test 4
B-T Heater
Crude Heater #22
Process Heater #81-1
Process Heater #81-2
Test 1
Test 2
Heat Input
During
kg cal/hr
100
86
81
93
76
19
15
16
10
14
to Unit
Test
MM BTU/hr
397
342
320
369
301
74
60
62
39
55
Nitrogen Oxide
Emissions @ 3% 02
N02 ppmv
290
282
297
288
245
86
138
333
797
326
Emission Rate
N02/hr
kg
66
56
54
60
33
3.2
4.8
11.5
18.1
10.8
Ib
145
124
119
133
72.4
7.1
10.6
25.3
39.8
23.8
-------
18
Sulfur plant. The exhaust from the incinerator stack at the Claus
sulfur recovery plant was also analyzed for SOg during the ARCO tests of
January-February, 1975. S(L concentrations ranged from 5,455 to 6,995
ppmv. These values are in excess of the limitations of the LAAPCD Rule
52.3. As previously discussed, the sulfur plant is currently under a
variance until February 1976, at which time the tail gas treatment plant
shall be on line.
Computed Emission Rates
Theoretical emission factors for various emission sources found at
petroleum refineries are listed in Table 9.1-1 on page 9.1-3 of the EPA
publication AP-42 Compilation of Air Pollutant Emission Factors, Second
Edition (second printing with Supplements 1-4). These emission factors
were used to compute the following emission rates. Emissions from
hydrocarbon storage tanks have not been calculated for this report.
They will be included in a separate report being prepared by NEIC which
will summarize storage tank emissions from all refineries in Los Angeles
County.
Boilers and Process Heaters. As can be seen from the listing of
process heaters and steam boilers shown in Appendix C, a substantial
number of these units can be fired with both fuel gas and fuel oil.
Also, several of the units are either out of service or are on standby
status. Theoretical emissions from these units are calculated using
different factors for each fuel type used. It can be seen that a wide
range of emissions can exist depending on the available fuel situation.
Table 3 summarizes the theoretical emissions for three possible situations:
1} only those units normally in operation are being utilized and all
units are fueled with fuel gas; 2) all units are in operation and fuel
gas is curtailed so that fuel oil is being used in those units which can
-------
Table 3
CALCULATED EMISSION KATES FRW VARIOUS UNIT OPERATIONS
ARCO - Watson, California, Refinery
Calculated
Emissions
Emission Source Participates Sulfur Oxides (SO*) Carbon Monoxide (CO) Hydrocarbons Nitrogen Oxides (N02) Aldehydes Ammonia
(kg/hrMlb/hr) (kg/hr)(lb/hr)
Process Heaters
1* 31.6 69.5 18 40
2TT. 160 350 580 1,280
3ttT 130 290 470 1,050
Steam Boilers
it. 15.9 35 9 19.8
2™. 86 190 320 700
3TTT 84 185 320 700
Fluid Catalytic
Cracking Unit 49 107 540 1.180
Compressor Internal
Combustion
Engines Neg. 0.07 0.15
Slowdown Systems to
Vapor Recovery
or Flares Neg. Neg.
Wastewater Treatment Neg. Neg.
Pipeline Valves and
Flanges Neg. Neg.
Vessel Relief Valves Neg. Neg.
Pump Seals Neg. Neg.
Compressor Seals Neg. Neg.
Miscellaneous Neg. Neg.
Totalstm 263 582 1,330 2,930
(kg/hr)(lb/hr)
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
Neg.
(kg/hr)(lb/hr)
47
48
41
24
22
20
240
1.2
17
17
100
36
60
18
35
585
100
105
90
52
48
44
530
2.6
38
38
220
80
130
40
77
1,290
(kg/hr)(lb/hr) (kg/hr)(lb/hr) (kg/hr)(lb/hr)
360 790 4.7 10.3 Neg.
670 1,500 6.5 14.3 Neg.
570 1,250 5.6 12.3 Neg.
180 400 2.4 5.3 Neg.
350 770 3.2 7 Neg.
290 640 3 7 Neg.
78 170 21 46 59 130
5.4 11.9 0.6 1.3 1.2 2.6
Neg. Neg. Neg.
Neg. Neg. Neg.
Neg. Neg. Neg.
Neg. Neg. Neg.
Neg. Neg. Neg.
Neg. Neg. Neg.
Neg. Neg. Neg.
944 2,072 30 66 60 133
t Mode 1. Unite normally operated are in use and all on fuel gas
tt Mode 2. All units in refinery operated and those units which can are burning fuel oil
ttt Mode 3. Units normally operated are in use and those which can are using fuel oil
tttt Totals include only situation (3) for boilers and process heaters. Considered worst normal operating mode.
-------
20
use oil; and, 3) only those units normally operated are being utilized
and fuel oil is being used where possible. Realizing that a wide
variety of unit/fuel combinations exist, for this analysis, situation
(1) is considered the most frequent operating mode, situation (2) is
considered the least probable mode, and situation (3) an operating mode
which is possible but used infrequently during fuel gas curtailment.
For these calculations, the heat content of refinery fuel gas was
assumed to be 8,900 kg cal/m3 (1,000 BTU,
be 9,860 kg cal/liter (148,000 BTU/gal).
assumed to be 8,900 kg cal/m3 (1,000 BTU/CF) and that of the fuel oil to
The process heaters and boilers are major contributors of nitrogen
oxides. Depending on the fuel use pattern at the refinery, calculated
nitrogen dioxide emissions for these units range from 540 to 860 kg/hr
(1,190 to 1,890 Ib/hr) as N02- If the refinery is on fuel gas curtail-
ment, these units are also potential large sources of particulate
matter, 214 to 246 kg/hr (475 to 540 Ib/hr) and sulfur oxides, 790 to
900 kg/hr (1,750 to 1,980 Ib/hr) as S02.
Fluid Catalytic Cracking Unit. Table 3 summarizes the calculated
theoretical emissions from this unit. These figures were also calcu-
lated using AP-42 emission factors for FCC units with attendant CO
boilers and electrostatic precipitators. The calculated value for
particulate emissions using the average emission factor value listed in
AP-42 is 49 kg/hr (107 Ib/hr). This value is in excess of the maximum
allowable emission rate under the LAAPCD Rule 54 which is 13.6 kg/hr (30
Ib/hr). However, it should be emphasized that the AP-42 emission factor
is an average value for the industry and that the ARCO precipitator may
be more efficient than the average unit. Truesdail Laboratories' test
in May 1975 indicated a much lower emission rate, well within the
limitations of Rule 54. As noted before, Truesdail's calculations are
subject to varying interpretations.
-------
21
The calculated emission rates for other pollutants from the FCC
unit indicate that substantial amounts of sulfur dioxide, hydrocarbon,
and nitrogen dioxide are emitted from this unit. The calculated theoretical
values are 540 kg/hr (1,180 Ib/hr), 240 kg/hr (530 Ib/hr) and 78 kg/hr
(170 Ib/hr), respectively.
Other Sources. Table 3 summarizes the calculated theoretical
emission rates from other sources within the refinery. In general, AP-
42 gives only hydrocarbon emission factors for these sources. The major
source appears to be leakage from pipeline valves and flanges which
amounts to 100 kg/hr (220 Ib/hr).
SUMMARY OF VIOLATIONS
A review of the LAAPCD records indicates that a citation was
issued to ARCO on February 6, 1974 for excessive visible emissions from
No. 21 process heater serving the No. 2 crude unit. The company pleaded
nolo contendre. Another citation was issued on April 21, 1975 for
excessive visible emissions from the flare system serving the FCC unit.
A third citation for excessive visible emissions from the No. 1 catalytic
reformer heater and from a desulfurizer heater was issued on May 25,
1975. The disposition of these citations is not known.
A citation was issued on April 25, 1975 for excessive odors from
the FCC flare system. The disposition of this citation is also unknown.
INSPECTION SUMMARY
At the time of this inspection, all major process units were in
operation with the exception of the isomerization plant, No. 6 crude
-------
22
atmospheric distillation unit, No. 52 vacuum distillation unit, and the
two sulfur plant tail gas units.
All process units, storage vessels, potential pollution emission
points and pollution control devices in use at the refinery were observed
during the inspection. No visible emissions were detected from any of
the process heaters or incinerators. The flare systems also appeared to
be operating correctly.
Visible emissions were noted from the stacks which discharge
exhaust gases from the CO boiler attendant to the FCC unit. Due to the
sun angle, wind direction, and tight spacing of process equipment in the
immediate area, it was not possible to obtain an accurate visible
emission observation (VEO) on these stacks. However, it was noted that
the opacity meter strip chart recorder in the boiler house was reading
consistently above 20% opacity, in the range of 23-25%.
After discussing the situation with the operating personnel, it was
determined that there were electrical control problems on one stage of
one bank of the electrostatic precipitator. The stage was apparently
arcing and was operating at much reduced efficiency.
It should also be noted that the annunciator alarm for the opacity
recorder had been disconnected such that the operators would not receive
an alarm signal if the opacity of the exhaust gases exceeded 20%. The
exhaust gases routinely exceed 20% when the tubes in the CO boiler are
lanced on an hourly basis. Approximately 1/8 of all tubes are lanced
every hour for about 2-1/2 minutes. The operators apparently tired of
the hourly annunciator alarm caused by the lancing cycle and discon-
nected the alarm unit.
General housekeeping at the refinery appeared to be very good. The
main process areas were neat with no noticeable spills, leaks, etc.
-------
APPENDIX A
NEIC Information Request Letter to ARCO
-------
. r .,. .. - . PA
OFFICE OF ENFORCEMENT
NATIONAL FIELD INVESTIGATIONS CENTER-DENVER
BUILDING 53. BOX 25227. DENVER FEDERAL CENTER
DENVER. COLORADO 80225
September 8, 1975
Dear
Pursuant to the authority contained in Section 114 of the Clean Air
Act, as amended, representatives of the EPA will conduct, within the
next year, inspections of the Allied Chemical Corp. operations to
ascertain compliance with the Federally approved California State
Implementation Plan.
Representatives from the Environmental Protection Agency will
Observe the facility's process operations, inspect monitoring and
laboratory equipment and analytical methods, review source test data,
examine appropriate records, etc. A process and air pollution flow
diagram or a blueprint of the facility and production information should
be available for the EPA personnel at the start of the inspections.
Detailed information about air pollution sources will be discussed
during these inspections. Attached is a partial list of the information
that will be needed in order to complete these inspections. We would
appreciate it if you could inform the appropriate company personnel
about the forthcoming inspections so that the necessary information will
be readily available and the inspection can be expedited.
If you have any questions concerning these inspections, please feel
free to contact Arnold Den, Chief, Air Investigations Section, Region
IX. San Francisco, at 415/556-8752.
A representative of the EPA (Dr. Wayne Smith or Mr. David Brooman,
303/234-4658) will contact you within the next 30 days concerning this
Visit.
Sincerely,
Thomas P. Gallagher
Director
Attachments
-------
A. Refinery Capacity in Barrels/Day
B. Furnaces, Boilers and Process Heaters (for each furnace boiler
and heater)
1. Rated capacity in 106 BTU/hr heat input.
2. Maximum capacity as per cent of rated capacity.
3. For oil fired units:
a: Rated capacity in gals/hr or 10^ bbl/hr.
b. Heating value in BTU's/gal.
C« Per cent sulfur and ash in oil by wt.
d. Specific gravity of oil.
e. Firing pattern (atomization, etc. for furnaces).
4* For gas fired units:
a. Rated capacity in 10^ SCF/hr.
b. Type of gas burned (list principal constituents in % by
weight).
C. Density Ib/SCF.
d. Heating value of gas in BTU's/SCF.
e. Sulfur content of gas in-% S by vol and grains/SCF.
5. Type(s) of control equipment and collection efficiency(s)
(design and actual).
6. Pressure drop (inches of water) across collection devices(s),
7. Elevation above grade of stack outlets and other discharge
points.
8. Identification of stacks equipped with recording monitors
for determining opacities of stack effluents.
9. Existing stack test data. The full test reports describing
methods used, test data, calculations, test results and
process weights should be available.
'10. Inside diameters of each stack (ft).
11, Temperature of effluent gas stream from each stack (°F).
12. Exit velocity of each stack effluent (ft/sec).
C. Incinerators: (For each incinerator)
1. Rated capacity in 106 BTU's/hr; include auxiliary burners
separately.
2* Auxiliary burner fuels:
oil - 10^ bbl/hr and specific gravity.
gas - 103 SCF/hr and density in Ib/SCF.
Other - (describe) - Ibs/hr (Heating value of each fuel).
-------
-2-
3, Maximum capacity as per cent of rated capacity for auxiliary
burners.
4. Sulfur and ash content of fuel as Z by weight for auxiliary
turners.
5. Type of material incinerated.
6. Rated capacity for material incinerated In lb/hr.
7. Sulfur and ash content of material incinerated as % by weight.
6* Heating value of material incinerated.
9. The gas flow rate reported at dry standard conditions (DSCFH).
10. Type(s) of control equipment and collection efficiency(s)
(design and actual).
11. Pressure drop (inches of water) across collection device(s).
12. Elevation above grade of stack outlets and other discharge
points (ft).
13. Identification of stacks equipped with recording monitors
for determining opacities of stack effluents.
14. Existing stack test data. Data should include the full test
reports describing methods used, test data, calculations,
test results and process weights.
15. Inside diameter of each stack (ft).
16. Exit velocity of each stack effluent (ft/sec.).
17. Temperature of effluent gas stream from each stack in °F.
D. Catalytic Cracking Units, Coker Units: (For each unit)
1, Rated capacity - 10^ BTU/hr and indicate the type of unit such
ae PCC, Coker, etc.
2. Maximum capacity as per cent of rated capacity.
3. Type of feed-stock used and barrels of fresh feed used per yr.
4. Sulfur content of feed-stock (% by weight).
5. Types of control equipment and collection efficiency(s) (design
and actual).
6. Pressure drop (inches of water) across collection devices(s).
7. Elevation above grade of stack outlets and other discharge
points (ft).
8. Identification of stacks equipped with recording monitors
for determining opacities of stack effluents.
,9. Existing stack test data. Data should include the full test
reports describing methods used, test data, calculations, test
results and process weights.
10. Inside diameter of each stack (ft).
11. Exit velocity of each stack effluent (ft/sec).
12. Total flow through unit in 103 bbl/hr and ton/hr.
13. Temperature of effluent gas stream from each stack in °F.
14. Indicate disposition of waste gas stream, i.e., burned in
afterburner, etc.
-------
-3-
15* Average hours of operation per month and average monthly
catalyst makeup for the catalytic cracking units.
16. Indicate date of installation or latest modification.
E. Biovdown Systems:
1. Indicate type and efficiency of each air pollution control
device.
F« Flares: (For each flare)
1. Type
2. Height and diameter of stack (ft).
3. Velocity of stack effluent (ft/sec).
4. Temperature of gas effluent (°F).
5. Rated capacity 106 BTU/hr and tons/hr (of flared material).
6. Amount of material flared and percent of time material being
flared.
7. Maximum capacity as per cent of rated capacity.
8. Type of flare ignition device at top of stack.
9. Sulfur content of flared input (% by wt).
10. Where material comes from that is burned in flare.
6. Storage Vessels: (For each vessel)
1* Indicate type of tank (fixed roof, floating roof, vapor recovery,
etc.)
2* Give storage capacity of each tank in 1(P gallons or barrels.
3. Indicate type of material stored in each tank (crude oil, gasoline,
finished petroleum product) and give annual average .true vapor
pressure (TVP) and seasonal maximum for actual storage condition
of product stored in Ibs/sq. in. absolute.
4. State tank diameter (ft).
5. Indicate if tank is equipped with submerged fill pipe.
6* Indicate if the tank is a pressure tank capable of maintaining
working pressure sufficient at all times to prevent vapor or gas
loss to the atmosphere.
7. State type of air pollution control equipment on each tank, i.e.,
conservation vent, vapor recovery system, etc.
8. Indicate average and seasonal maximum temperature of each tank.
9. Indicate date of installation or latest modifications.
10. Indicate if tank is used for multiple product storage.
B. Wastewater Treatment Systems:
1. Indicate gallons of waste water discharged daily.
2. Indicate source of such drains (process discharged).
-------
-4-
3* Indicate type and efficiency of each air pollution control
device and any existing test data indicating actual emissions.
Data should include the full test reports describing methods
used, test data, calculations, test results and process weight.
X. Internal Combustion Engines: (Stationary)
1. Type of engine.
2. Amount of fuel burned per day.
3. Type of fuel.
J« Vacuum Jets and/or Barometric Condensers
1. Indicate type and efficiency of each air pollution control
device.
2. Indicate disposition of exhaust gases-(eg. To afterburners,
fireboxes, etc.).
K. Loading Rack Vapor Recovery:
1. Actual product throughput in 10 gallons per day and year.
2. Type of material loaded.
3. Type of vapor recovery system and rated collection efficiency.
4. Existing test data. The full test reports describing methods
used, test data, calculations and test results should be
submitted.
L« Submit schematic diagrams showing stacks and their respective
process associations and control equipment.
H. List any other significant (25 tons/yr. potential uncontrolled
emission) sources of participates, sulfur dioxide, carbon monoxide,
oxides of nitrogen, and hydrocarbons not covered by Items B-L.
Include:
1. Type of process and rated capacity.
2. Type of material processed.
3. Types of collection equipment and collection efficiency(s)
(design and actual).
4. Pressure drop (inches of water) across collection devices.
5. Existing stack test data applicable to current operating
conditions. The full test reports describing methods used,
•test data, calculations, test results and process weights
should be submitted.
-------
APPENDIX B
Select LAAPCD Rules and Regulations
-------
APPENDIX B
County of Los Angeles
Air Pollution Control District
-------
IV
Prohibitions
-------
Rule 50. Ringelmann Chart.
(Effective January 6, 1972 for any source not completed and put into
service. Effective for all sources on January 1, 1973.)
A person shall not discharge into the atmosphere from any single
source of emission whatsoever any air contaminant for a period or periods
aggregating more than three minutes in any one hour which is:
a. As dark or darker in shade as that designated No. 1 on the Ringel-
mann Chart, as published by the Untied States Bureau of Mines, or
b. Of such opacity as to obscure an observer's view to a degree
equal to or greater than does smoke described in subsection (a) of this
Rule.
This amendment shafl be effective on the date of its adoption for any
source of emission not then completed and put into service. As to all other
sources of emission this amendment shall be effective on January 1, 1973.
Rule 51. Nuisance.
A person shall not discharge from any source whatsoever such quanti-
ties of air contaminants or other material which cause injury, detriment,
nuisance or annoyance to any considerable number of persons or to the
public or which endanger the comfort, repose, health or safety of any such
persons or the public or which cause or have a natural tendency to cause
injury or damage to business or property.
Rule 52.. Particulate Matter - Concentration.
(Effective January 6. 1972 for any equipment not completed and put
>into service. Effective for all equipment on January 1, 1973.)
A person shall not discharge into the atmosphere from any source par-
ticulate matter in excess of the concentration shown in the following table:
(See Rule 52 Table)
Where the volume discharged falls between figures listed in the table,
the exact concentration permitted to be discharged shall be determined by
linear interpolation.
The provisions of this rule shall not apply to emissions resulting from
the combustion of liquid or gaseous fuels in steam generators or gas turbines.
For the purposes of this rule "paniculate matter" includes any material
which would become paniculate matter if cooled to standard conditions.
This amendment shall be effective on the date of its adoption for any
-------
equipment not then completed and put into service. As to all other equip-
ment this amendment shall be effective on January 1, 1973.
Table For Rule 52
Volume Discharged-
Cubic Feet Per Minute
Calculated as Dry Gas
tt Standard Conditions
1000 or less
1200
1400
1600
1800
2000
2500
3000
3500
4000
5000
6000
7000
8000
10000
15000
Maximum Concentra-
tion of Particulate Mat-
ter Allowed in Dis-
charged Gas-Grams Per
Cubic Foot of Dry Gas
•t Standard Conditions
0.200
.187
.176
.167
.160
.153
.141
.131
.124
.118
.108
.101
.0949
.0902
.0828
.0709
Volume Discharged--
Cubic Feet Per Minute
Calculated as Dry Gas
at Standard Conditions
20000
30000
40000
50000
60000
70000
80000
100000
200000
400000
600000
800000
1000000
1500000
2000000
Maximum Concentra-
tion of Paniculate Mat-
ter Allowed in Dis-
chared Gas-Grams Per
Cubic Foot of Dry Gas
•t Standard Conditions
0.0635
.0544
.0487
.0447
.0417
.0393
.0374
.0343
.0263
.0202
.0173
.0155
.0142
.0122
.0109
2500000 or more .0100
Rule 53. Sulfur Compounds - Concentration.
A person shall not discharge into the atmosphere sulfur compounds,
which would exist as a liquid or gas at standard conditions, exceeding in
concentration at the point of discharge. 0.2 per cent by volume calculated
as sulfur dioxide (SC>2).
Rule 53.1 Scavenger Plants.
Where a separate source of air pollution is a scavenger or recovery
-------
plant, recovering pollutants which would otherwise be emitted to the atmos-
phere, the Air Pollution Control Officer may grant a permit to operate
where the total emission cf pollutants is substantially less with the plant in
operation than when closed, even though the concentration exceeds that
permitted by Rule 53(a). The Air Pollution Control Officer shall report
immediately in writing to the Air Pollution Control Board the granting of
any such permit, together with the facts and reasons therefor.
Effective July 1. 1973. this Rule is repealed for sulfur recovery units.
Effective January 1, 1974. this Rule is repealed for sulfuric acid units.
•Rule 53.2. Sulfur Recovery Units.
A person shall not, after June 30, 1973, discharge into the atmosphere
from any sulfur recovery unit producing elemental sulfur, effluent process
gas containing more than:
1. 500 parts per million by volume of sulfur compounds calculated
as sulfur dioxide.
2. 10 parts per million by volume of hydrogen sulfide.
3. 200 pounds per hour of sulfur compounds calculated as sulfur
dioxide.
-Any sulfur recovery unit having an effluent process gas discharge con-
taining less than 10 pounds per hour of sulfur compounds calculated as sul-
fur dioxide may dilute to meet the provision of number (1) above.
Rule 53.3. Sulfuric Acid Units.
A person shall not, after December 31,1973. discharge into the atmos-
phere from any sulfuric acid unit, effluent process gas containing more than:
1. 500 parts per million by volume of sulfur compounds calculated
as sulfur dioxide.
200 pounds per hour of sulfur compounds calculated as sulfur
dioxide.
-------
Rule 54. Solid Paniculate Matter - Weight.
(Effective January 6, 1972 for any equipment not completed and put
Into service. Effective for all equipment on January t. 1973.)
A person shall not discharge into the atmosphere from any source
solid particulate matter, including lead and lead compounds, in excess of
the rate shown in the following table: (See Rule 54 Table}
TABLE FOR RULE 54
(Amended January 6. 1972)
Process Weight
Pur Hour-
Pounds Per Hour
250 or less
300
350
400
450
500
600
700
800
900
1000
1200
1400
1600
1800
2000
2500
3000
3500
4000
4500
5000
5500
6000
6500
7000
7500
8000
8500
9000
9500
10000
Maximum Discharge
Rate Allowed for Solid
Particular Matter
(Aggregate Discharged
From All Points of
ProcessI-Pounds
Per Hour
1.00
1.12
1.23
1.34
1.44
1.54
1.73
1.90
2.07
2.22
2.38
2.66
2.93
3.19
3.43
3.66
4.21
4.72
5.19
5.64
6.07
6.49
6.89
7.27
7.64
8.00
8.36
8.70
9.04
9.36
9.68
10.00
Process Weight
Per Hour-
Pounds Per Hour
12000
14000
16000
18000
20000
25000
30000
35000
40000
45000
50000
60000
70000
80000
90000
100000
120000
140000
160000
180000
200000
250000
300000
350000
400000
450000
500000
600000
700000
800000
900000
1000000 or
Maximum Discharge
Rate Allowed for Solid
Paniculate Matter
(Aggregate Discharged
From All Points of
Pvoeess)-Pounds
Per Hour
10.4
10.8
11.2
11.5
11.8
12.4
13.0
13.5
13.9
14.3
14.7
15.3
15.9
16.4
16.9
17.3
18.1
18.8
19.4
19.9
20.4
21.6
22.5
23.4
24.1
24.8
25.4
26.6
27.6
28.4
29.3
more 30.0
-------
Where the process weight per hour falls between figures listed in the
table, the exact weight of permitted discharge shall be determined by linear
interpolation.
For the purposes of this rule "solid particulate matter" includes any
material which would become solid particulate matter if cooled to standard
conditions.
This amendment shall be effective on the date of its adoption for any
equipment not then completed and put into service. As to all other equip-
ment this amendment shall be effective on January 1, 1973.
Rule 55. Exceptions.
The provisions of Rule 50 do not apply to:
a. Smoke from fires set by or permitted by any public officer
if such fire is set or permission given in the performance of the official
duty of such officer, and such fire in the opinion of such officer is
necessary:
1. For the purpose of the prevention of a fire hazard
which cannot be abated by any other means, or
2. The instruction of public employees in the methods of
fighting fire.
b. Smoke from fires set pursuant to permit on property used
for industrial purposes for the purpose of instruction of employees in
•methods of fighting fire.
C. Agricultural operations in the growing of crops, or raising of
fowls oranimals.
d. The use of an orchard or citrus grove heater which does not
produce unconsumed solid carbonaceous matter at a rate in excess of
one(1) gram per minute.
e. The use of other equipment in agricultural operations in the
growing of crops, or raising of fowls or animals.
-------
Rule 56. Storage of Petroleum Products.
A person shall not place, store or hold in any stationary tank, reser-
voir or other container of more than 40.000 gallons capacity any gasoline
or any petroleum distillate having a vapor pressure of 1.5 pounds per square
inch absolute or greater under actual storage conditions, unless such tank,
reservoir or other container is a pressure tank maintaining working pressures
sufficient at all times to prevent hydrocarbon vapor or gas loss to the atmos-
phere, or is designed and equipped with one of the following vapor loss con-
trot devices, properly installed, in good working order and in operation:
a. A floating roof, consisting of a pontoon type or double-deck
type roof, resting on the surface of the liquid contents and equipped
with a closure seal, or seals, to close the space between the roof edge
and tank wall. The control equipment provided for in this paragraph
shall not be used if the gasoline or petroleum distillate has a vapor pres-
sure of 11.0 pounds per square inch absolute or greater under actual
Storage conditions. All tank gauging and sampling devices shall be gas-
tight except when gauging or sampling is taking place.
b. A vapor recovery system, consisting of a vapor gathering sys-
tem capable of collecting the hydrocarbon vapors and gases discharged
and a vapor disposal system capable of processing such hydrocarbon
vapors and gases so as to prevent their emission to the atmosphere and
with all tank gauging and sampling devices gas-tight except when gaug-
ing or sampling is taking place.
C. Other equipment of equal efficiency, provided such equip-
ment is submitted to and approved by the Air Pollution Control Offi-
cer.
-------
Rule 59. Effluent Oil Water Separators.
(Effective June 29, 1971 for any equipment not completed and put
Into service. Effective for air equipment after July 1, 1972)
A person shall not use any compartment of any vessel or device operat-
ed for the recovery of oil from effluent water which recovers 200 gallons a
day or more of any petroleum products from any equipment which proc-
esses, refines, stores or handles hydrocarbons with a Reid vapor pressure
of 0.5 pound or greater, unless such compartment is equipped with one of
the following vapor loss control devices, except when gauging or sampling
is taking place:
a. A solid cover with a!J openings sealed and totally enclosing
the liquid contents of that compartment.
b. A floating pontoon or double-deck type cover, equipped
with closure seals to enclose any space between the cover's edye and
compartment wall.
C. A vapor recovery system, which reduces the emission of all
hydrocarbon vapors and gases into the atmosphere by at least 90 per
cent by weight.
d. Other equipment of an efficiency equal to or greater than
a, b, or c. if approved by the Air Pollution Control Officer.
This rule shall not apply to any oil-effluent water separator used ex-
clusively in conjunction with the production of crude oil, if the water
fraction of the oil-water effluent entering the separator contains less than
5 parts per. million hydrogen sulfide, organic su If ides, or a combination
thereof.
This amendment shall be effective at the date of its adoption for any
'equipment not then completed and put into service. As to all other equip-
ment this amendment shall be effective on July 1,1972.
-------
Rule 60. Circumvention.
A person shall not build, erect, install, or use any article, machine,
equipment or other contrivance, the use of which, without resulting in a
reduction in the total release of air contaminants to the atmosphere, re-
duces or conceals an emission which would otherwise constitute a violation
of Division 20, Chapter 2 of the Health and Safety Code of the Stale of
California or of these Rules and Regulations. This Rule shall not apply to
cases in which the only violation involved is of Section 24243 of the Health
and Safety Code of the State of California, or of Rule 51 of these Rules and
Regulations.
Rule 61. Organic Liquid Loading.
(Effective June 29, 1971 for any equipment not completed and put
into service. Effective for all equipment after July 1, 1972)
A person shall not load organic liquids having a vapor pressure of 1.5
psia or greater under actual loading conditions into any tank truck, trailer,
or railroad tank car from any loading facility unless the loading facility is
equipped with a vapor collection and disposal system or its equivalent ap-
proved by the Air Pollution Control Officer.
Loading shall be accomplished in such a manner that all displaced
vapor and air will be vented only to the vapor collection system. Measures
shall be taken to prevent liquid drainage from the loading device when it is
not in use or to accomplish complete drainage before the loading device is
disconnected.
The vapor disposal portion of the vapor collection and disposal system
shall consist of one of the following:
a. An absorber system or condensation system which processes
all vapors and recovers at least 90 per cent by weight of the organic
vapors and gases from the equipment being controlled.
b. A vapor handling system which directs all vapors to a fuel gas
system.
c. Other equipment of an efficiency equal to or greater than a
or b if approved by the Air Pollution Control Officer.
This rule shall apply only to the loading of organic liquids having a
-------
vapor pressure of 1.5 psia or greater under actual loading conditions at a
facility from which at least 20,000 gallons of such organic liquids are loaded
in any one day.
"Loading facility", for the purpose of this rule, shall mean any aggre-
gation or combination of organic liquid loading equipment which is both
(1) possessed by one person, and (2) located so that all the organic liquid
loading outlets for such aggregation or combination of loading equipment
can be encompassed within any circle of 300 feet in diameter.
This amendment shall be effective at the date of its adoption for any
equipment not then completed and put into service. As to all other equip-
ment this amendment shall be effective on July 1, 1972.
Rule 62. Sulfur Contents of Fuels.
A person shall not burn within the Los Angeles Basin at any time be-
tween May 1 and September 30. both dates inclusive, during the calendar
year 1959, and each year thereafter between April 15 and November 15,
both inclusive, of the same calendar year, any gaseous fuel containing sulfur
compounds in excess of 50 grains per 100 cubic feet of gaseous fuel, calcu-
lated as hydrogen sulfide at standard conditions, or any liquid fuel or solid
fuel having a sulfur content in excess of 0.5 per cent by weight.
The provisions of this rule shall ncjt apply to:
a. The burning of sulfur, hydrogen sulfide, acid sludge or other
sulfur-compounds in the manufacturing of sulfur or sulfur compounds.
b. The incinerating of waste gases provided that the gross heat-
ing value of such gases is less than 300 British Thermal Units per cubic
foot at standard conditions and the fuel used to incinerate such waste
gases does not contain sulfur or sulfur compounds in excess of the a-
*
mount specified in this rule.
-------
C. The use of solid fuels in any metallurgical process.
d. The use of fuels where the gaseous products of combustion
are used as raw materials for other processes.
e. The use of liquid or solid fuel to propel or test any vehicle.
aircraft, missile, locomotive, boat or ship.
f. The use of liquid fuel whenever the supply of gaseous fuel,
the burning of which is permitted by this rule, is not physically avail-
able to the user due to accident, act of God, act of war, act of the
public enemy, or failure of the supplier.
Rule 62.1 Sulfur Contents of Fuels.
a. A person shall not burn within the Los Angeles Basin at any
time between the days of November 16 of any year and April 14 of the
next succeeding calendar year, both dates inclusive, any fuel described in the
first paragraph of Rule 62 of these Rules and Regulations.
b. The provisions of this Rule do not apply to:
1. Any use of fuel described in Subsections a,b,c,d,e, and f of
said Rule 62 under the conditions and for the uses set forth
in said Subsections.
2. The use of liquid fuel during a period for which the supplier
of gaseous fuel, the burning of which is not prohibited by
this Rule, interrupts the delivery of gaseous fuel to the user.
C. Every holder of, and every applicant for a permit to operate fuel-
burning equipment under these Rules and Regulations shall notify the Air
Pollution Control Officer in the manner and form prescribed by him, of each
interruption in and resumption of delivery of gaseous fuel to his equipment.
Rule 62.2 Sulfur Contents of Fuels.
Notwithstanding the provisions of Section (f) of Rule 62 or any pro-
-------
Rule 66.1. Architectural Coatings.
a. A person shall not sell or offer for sale for use in Los Angeles
County, in containers of one quart capacity or larger, any architectural
coating containing photochemically reactive solvent, as defined in Rule
66(k).
b. A person shall not employ, apply, evaporate or dry in Los Angeles
County any architectural coating, purchased in containers of one quart
capacity or larger, containing photochemically reactive solvent, as defined
in Rule 66 (k).
C. A person shall not thin or dilute any architectural coating with a
photochemically reactive solvent, as defined in Rule 66(k).
d. For the purposes of this rule, an architectural coating is defined as
a.coating used for residential or commercial buildings and their appurte-
nances; or industrial buildings.
Rule 66.2.Disposal and Evaporation of Solvents
A person shall not during any one day dispose of a total of more than
114 gallons of any photochemically reactive solvent, as defined in Rule 66(k),
or of any material containing more than V/a gallons of any such photochemi-
cally reactive solvent by any means which will permit the evaporation of
such solvent into the atmosphere.
Rule 67. Fuel Burning Equipment.
A person shall not build, erect, install or expand any non-mobile fuel
burning equipment unit unless the discharge into the atmosphere of contam-
jnants will not and does not exceed any one or more of the following
rates:
1. 200 pounds per hour of sulfur compounds, calculated as sulfur
-------
dioxide (S02);
2. 140 pounds per hour of nitrogen oxides, calculated as nitrogen
dioxide (N02);
3. 10 pounds per hour of combustion contaminants as defined in
Rule 2m and derived from the fuel.
For the purpose of this rule, a fuel burning equipment unit shall be
Comprised of the minimum number of boilers, furnaces, jet engines or other
fuel burning equipment, the simultaneous operations of which are required
for the production of useful heat or power.
Fuel burning equipment serving primarily as air pollution control
equipment by using a combustion process to destroy air contaminants
Shall be exempt from the provisions of this rule.
Nothing in this rule shall be construed as preventing the maintenance
or preventing the alteration or modification of an existing fuel burning
equipment unit which will reduce its mass rate of air contaminant emissions.
Rule 68. Fuel Burning Equipment - Oxides of Nitrogen.
A person shall not discharge into the atmosphere from any non-
mobile fuel burning article, machine, equipment or other contrivance, having
a maximum heat input rate of more than 1775 million British Thermal
Units (BTU) per hour (gross), flue gas having a concentration of nitrogen
oxides, calculated as nitrogen dioxide (N02) at 3 per cent oxygen, in ex-
cess of that shown in the following table:
NITROGEN OXIDES - PARTS PER MILLION PARTS OF FLUE GAS
FUEL
Gas
Liquid or Solid
EFFECTIVE DATE
DECEMBER 31, 1971
225
325
DECEMBER 31.1974
125
225
-------
Rule 68.1. Fuel Burning Equipment • Combustion Contaminants.
A person shall not discharge into the atmosphere combustion contami-
nants exceeding in concentration at the point of discharge. 0.3 grain per
cubic foot of gas calculated to 12 per cent of carbon dioxide (CC^) at
standard conditions.
Rule 69. Vacuum Producing Devices or Systems.
A person shall not discharge into the atmosphere more than 3 pounds
of organic materials in any one hour from any vacuum producing devices or
systems including hot wells and accumulators, unless said discharge has been
reduced by at least 90 per cent.
This rule shall be effective at the date of its adoption for any equip-
ment not then completed and put into service. As to all other equipment
this rule shall be effective on July 1. 1972.
Rule 70. Asphalt Air Blowing.
A person shall not operate or use any article, machine, equipment or
Other contrivance for the air blowing of asphalt unless all gases, vapors and
gas-entrained effluents from such an article, machine, equipment or other
contrivance are:
a. Incinerated at temperatures of not less than 1400 degrees
Fahrenheit for a period of not less than 0.3 second, or
b. -Processed in such a manner determined by the Air Pollution
Control Officer to be equally, or more, effective for the purpose of air
pollution control than (a) above.
This rule shall be effective at the date of its adoption for any equip-
ment not then completed and put into service. As to all other equipment
this rule shall be effective on July 1. 1972.
Rule 71. Carbon Monoxide.
A person shall not. after December 31. 1971. discharge into the atmos-
phere carbon monoxide (CO) in concentrations exceeding 0.2 per cent by
volume measured on a dry basis.
The provisions of this rule shall not apply to emissions from internal
-------
combustion engines.
Rule 72. Pumps and Compressors.
A person shall not. after July 1. 1973, use any pump or compressor
handling organic materials having a Reid Vapor Pressure of 1.5 pounds or
greater unless such pump or compressor is equipped with a mechanical seal
or other device of equal or greater efficiency approved by the Air Pollution
Control Officer.
The provisions of this rule shall not apply to any pump or compressor
which has a driver of less than one (1) horsepower motor or equivalent
rated energy or to any pump or compressor operating at temperatures in
excess of 500°F.
Rule 73. Safety Pressure Relief Valves.
A person shall not, after July 1. 1973. use any safety pressure
relief valve on any equipment handling organic materials above 15 pounds
per square inch absolute pressure unless the safety pressure relief valve is
vented to a vapor recovery or disposal system, protected by a rupture disc.
or is maintained by an inspection system approved by the Air Pollution
Control Officer.
The provisions of this rule shall not apply to any safety pressure relief
valve of one (1) inch pipe size or less.
-------
APPENDIX C
Process Heater and Steam Boiler Listing
-------
ATLANTIC RICHFIELD COMPANY
WATSON REFINERY
CARSON. CALIFORNIA
PROCESS HEATERS. BOILERS AND INCINERATORS
NO.
1
2
3
4
5
6
7
8
9
TO
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Identification
Location
Fuel 011 Heater
21 Heater
22 Heater
31 Heater
41 Heater
Vacuum Heater
Naph. Acid Heater
Slop Oil Heater
1 Heater
2 Heater
Alcorn Heater
1 DeFlorez
2 DeFlorez
3 DeFlorez
Alcorn Heater
1 DeFlorez
2 DeFlorez
3 DeFlorez
Fuel Oil Heater
1 Heater
2 Heater
1 Heater
31 Boiler
32 Boiler
33 Boiler
Reservoir 507
No. 2 Crude
No. 2 Crude
No. 3 Crude
No. 4 Crude
No. 52 Vacuum
Naphthenic Acid
Slop Oil
No. 51 Vacuum
No. 51 Vacuum
No. 81 Combination
No. 81 Combination
No. 81 Combination
No. 81 Combination
No. 82 Combination
No. 82 Combination
No. 82 Combination
No. 82 Combination
No. 2 Pumphouse
No. 1 Coker
No. 1 Coker
No. 2 Coker
No. 3 Steam Plant
No. 3 Steam Plant
No. 3 Steam Plant
Rated Capacity
MM Btu/Hr.
10
125
85
80
70
82
5
9
97
97
80
80
80
80
80
80
80
80
20
100
100
100
300
300
300
Stack I.D.&H
Feet
4 x 76.3
6.5 x 127*
6 x 78.1*
6.5 x 118.5*
7.5 x 114*
6.5 x 183.9*
2 x 40
2.5 x 59*
4.5 x 85*
4.5 x 85*
4.5 x 100*
4.5 x 100*
4.5 x 100*
4.5 x 100*
4.5 x 100*
4.5 x 100*
4.5 x 100*
4.5 x 100*
3 x 39.7*
7 x 165*
7 x 165*
7 x 165*
9 x 119*
9 x 119*
9 x 119*
Stack Temp.
OF
N.A.
850
950
725
720
N.A.
935
600
315
320
875
375
375
320
920
420
385
430
N.A.
475
480
475
375
380
350
Estimated
Stack Veloc.
Ft/Sec.
N.A.
32.2
27.6
18.6
12.2
17.1
14.5
13.0
24.0
25.1
28.0
17.3
18.9
17.4
36.6
21.9
22.9
23.2
22.5
13.9
13.5
13.1
17.2
17.0
16.2
Fuel Gas
or Fuel
011 Fired
FG
Both
n
ii
n
"**
FG
Both
n
11
ii
n
n
11
n
n
n
ii
FG
Both
ii
n
ii
ii
n
* Equipped with opacity Indicator and alarm
** Out of service
N.A. Not Available
Data on Maximum capacity, percent of rated, not available
-------
PAGE 2
No. ^IdentjM catl o_n__j
26 2 Heater
27 1 Incinerator
28 2 Incinerator
29 Stripper Reboller
30 Iso-Siv Heater
31 Splitter Reboller
32 Heat Med. Heater
33 Odor Incinerator
34 Carbon Regenerator
35 1 Heater
36 2 Heater
37 41 Boiler (CO)
38 42 Boiler
39 FCC Feed Heater
40 51 Boiler
41 52 Boiler
42 Heat Ned. Heater
43 Hydrodesul Heater
44 Hydro. Heater
45 Sieve Dryer
46 H-l
47 H-2
48 H-3
49 H-4
50 H-5
Location
PROCESS HEATERS. BOILERS AND INCINERATORS
Rated Capacity
MM Btii/Hr.
Fuel Oil Loading 11
Sulfur Plant 25
Sulfur Plant 30
Sulfur Plant 60
SFIA 10
SFIA 31
SFIA 130
SFIA 5
Adsorption Unit 3
No. 6 Crude 60
No. 6 Crude 60
FCC Area 450
No. 4 Steam Plant 400
FCC Area 55
No. 5 Steam Plant 90
No. 5 Steam Plant 90
Isomerizatjon 300
Isomerization 11
Isomerization 17
Isomerization 3
Ethylene 26
Ethylene 26
Ethylene 26
Ethylene 2
Ethylene 4
Stack I.D.&H
Feet
3 x 40
5.5 x 200
8-11 x 200
6 x 151.8
2.5 x 51.5
4.5 x 74.4*
7 x 130*
5.5 x 130
1.5 x 66.8
4 x 100
4 x 100
6 x 89(two)*
8 x 90
6.5 x 110
5 x 50*
5 x 50*
9.5 x 175*
3 x 90*
3 x 90*
2.5 x
3.8 x 125
3.8 x 125
3.8 x 125
2.5 x 60
1.5 x 60
Stack Temp,
OF
N.A.
1100
N.A.
330
N.A.
660
600
450
N.A.
N.A.
N.A.
520
320
555
N.A.
N.A.
N.A.
N.A.
N.A.
N.A.
615
590
640
N.A.
N.A.
Estimated
Stack Veloc.
Ft/Sec.
3.3
62.0
_
6.9
19.3
22.3
22.9
N.A.
N.A.
26.4
26.4
108.0
23.3
11.0
22.1
22.1
24.5
9.7
15.0
3.1
32.5
32.8
34.3
2.0
5.4
Fuel Gas
or Fuel
011 Fired
FG
FG
FG**
Both
FG
Both
11
FG
FG**
FG**
FG**
FG
Both
FG
FG**
FG**
Both**
ii **
« **
FG**
FG
FG
FG
FG
FG
* Equipped with opacity Indicator and alarm
** Out of service
N.A. > Not Available
-------
PAGE 3
PROCESS HEATERS. BOILERS AND INCINERATORS
No. Identification
51 Reformer Heater
52 Desulf. Heater
53 Lt. Hydro Heater
54 Hvy. Hydro Heater
55 Mid Bbl. Heater
56 Mid Bbl. Reboiler
57 Reformer Heater
58 2A Desul Heater
59 26 Desul Heater
60 B-T Heater
61 Tetramer Heater
62 Hydro Reformer
63 H-1401
64 H-1402
65 H-1403
65 H-1404
67 Fract. Reboiler
68 Jet Oesul Heater
69 Jet Trtr. Heater
70 Jet Stab. Reboiler
Location
No. 1 Reformer
No. 1 Reformer
No. 1 Reformer
Mo. 1 Reformer
No. 1 Reformer
No. 1 Reformer
No. 2 Reformer
No. 2 Reformer
No. 2 Reformer
B-T-X Area
FCC Area
Hydroqen Plant
Hydrocracker
Hydrocracker
Hydrocracker
Hydrocracker
Hydrocracker
Hydrocracker
Hydrocracker
Hydrocracker
Rated Capacity
MM Btu/Hr.
227
38
15
13
65
42
277
31
31
106
6
450
27
17
24
17
154
14
6
4
Stack I.O.&H
Feet
7 x 88
5 x 88
3 x 84
3.3 x 95.5
6 x 129
5 x 105.7
6.8 x 88
4 x 93
4 x 93
5 x 89
2.3 x 34.8
12.5 x 240'
3.5 x 110
3 x 110
3.5 x 110
3 x 110
8 x 160
3.5 x 81.3
2.5 x 72.5
2.5 x 71
Stack Temp.
OF
520
615
650
550
580
500
615
575
575
590
N.A.
450
585
500
575
785
660
650
590
625
Estimated
Stack Veloc.
Ft/Sec.
7.0
9.0
18.2
2.7
4.7
6.3
17.5
8.7
16.8
7.8
1.7
19.1
18.9
12.9
17.6
16.4
17.7
14.2
8.8
10.5
Fuel Gas
or Fuel
Oil Fired
FG
FG
Both
FG
N.A. - Not Available
pv 10/24/75
-------
APPENDIX D
Internal Combustion Engine Listing
-------
ATLANTIC RICHFIELD COMPANY
WATSON REFINERY
CARSON, CALIFORNIA
Designation
Compressor
(1)
H
II
II
II
II
STATIONARY INTERNAL COMBUSTION ENGINES
Type
4 Cycle
11
"
"
"
"
"
»
Design H.P.
240
240
.240
600
600
600
600
600
Average
Fuel Corns umpt ion
Type Fuel CF/Hr.
Natural Gas 485
2,184
2,184
1,669
1,669
1,669
1,669
1 ,669
Use Frequency
Percent of Time
10
80
80
20
20
20
20
20
(1) The 240 HP compressors operate as part of the vapor recovery system. The 600 HP compressors
pump low pressure process gas through a DEA treatment plant and into the refinery fuel gas
system.
-------
APPENDIX E
Storage Tank Listing
-------
ATLANTIC RICHFIELD COMPANY
WATSON REFINERY
CARSON, CALIFORNIA
ORGANIC MATERIAL STORAGE TANKS
TANK NO.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
MATERIAL
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Crude Oil
SR Residuum
Refin. Slops
Refin. Slops
Hvy Cat. Gaso.
Cracking Fd.
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Crude Oil
Cracking Fd.
Low Sul. Fuel
Low Sul. Fuel
Cutter Stk.
Jet Tuel
Jet Fuel
Toluene
Toluene
Toluene
Arom. Cone.
Sr Gaso.
Gaso Base
Jet Fuel
Jet Fuel
Gaso. Comp,
Prop. Polymer
Jet Fuel
Isopentane
Isohexane
Jet Fuel
Jet Fuel
Jet Fuel
Benzene
Jet Fuel
CAPACITY
Mbbls
80.2
84.5
83.3
78.2
78.5
77.6
79.0
79.3
76.5
78.0
80.2
79.8
79.6
78.8
78.8
97.0
97.2
79.9
142.3
140.1
78.7
78.0
78.9
96.1
96.2
96.1
23.8
23.8
23.8
23.8
78.7
75.6
75.9
99.5
100.0
14.8
14.8
31.5
32.5
99.6
118.8
90.8
79.6
102.6
TYPICAL
THROUGHPUT
bbls/DAY
7500
24.700
24,700
10,000
10,950
6550
5400
8500
2100
4400
6000
85
800
8000
9860
17,500
17,500
6000
13,200
6000
8000
822
5000
5000
1000
2000
400
400
130
150
3635
1750
2000
7000
4500
650
1000
-
1450
2500
2500
2000
1000
6000
VAPOR PRESSURE
PSIA
2.8
2.8
2.8
3.7
3.7
5.5
3.7
5.2
4.7
4.6
0.1
0.5
2.0
0.5
0.3
7.4
7.2
3.7
3.6
3.6
0.3
0.1
0.1
0.1
0.3
0.3
0.7
0.7
0.7
0.8
4.0
3.0
0.2
0.2
7.0
5.5
3.5
-
4.0
1.8
1.7
0.2
1.7
0.2
ROOF *
VR
FR
FR
FR
FR
VR
VR
VR
FR
FR
CR
CR
VR
VR
VR
VR
VR
VR
PR
PR
CR
CR
CR
CR
CR
CR
FR
FR
FR
PR
FR
FR
FR
FR
FR
VR
VR
PV
FR
FR
FR
FR
VR
VR
* FR - Floating Poof, CR - Cone Roof, VR - Vapor Recovery, PV - Pressure Vessel
-------
-2-
IAHK NO.
45
47
48
49
50
51
52
53
54
55
56
57
56
59
£0
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
77
78
79
S3
84
86
87
88
89
90
91
93
96
97
101
MATERIAL
Alkylate
Solvent
Solvent
Low Sul. Fuel
Gasoline
Reformate
Gasoline
Gasoline
Gasoline
Gasoline
Ned. Distillate
Lt. Cat. Caso.
Med. Distillate
Hed. Distillate
Med. Distillate
Chem. Fd. Stk.
Lt. Cat. Gaso
Refomate
Cat. Gaso.
Rvy. Cat. Gaso.
Gasoline
Gasoline
Gasoline
Gasoline
Gasoline
Gasoline
Butane
Butane
Lt. Gaso.
Lt. Gaso.
Lt. Gaso.
Butanes
Butane
Hed. Distillate
Cutter Stock
Butane
Butane
Butanes
Butane
Reformer Fd.
Evy Naphtha
Jet Feed
Solvent
Solvent
Gas Oil
.4
.7
CAPACITY
Mbbls
99.6
15.0
16.6
100.8
118.0
100.0
122.
112.
103.0
102.8
102.8
97.6
103.0
101.0
102.8
102.9
100.8
100.6
100.2
102.6
122.4
122.2
122.7
121.9
119.0
121.9
5.0
5.0
15.0
15.9
30.0
10.2
5.1
54.2
54.2
15.3
15.3
15.3
15.3
79.9
79.9
78.9
23.9
23.9
15.1
TYPICAL
THROUGHPUT
bbls/JAY
4000
SOO
700
2500
1915
1915
11,000
12,000
750
7700
7000
1000
7000
9000
9000
5900
2000
5000
5000
5000
10,000
10,000
10,000
8000
7200
7200
1800
1800
1000
1000
800
400
2000
2000
3500
1500
4000
1500
630
630
400
VAPOR PRESSURE
PSIA
3.6
0.2
0.2
0.1
4.1
4.0
7.4
5.8
5.6
5.0
0.1
1.0
0.1
0.1
0.1
2.2
1.0
3.2
0.4
0.4
5.7
5.2
5.7
5.7
6.0
5.4
0.1
0.1
1.5
0.3
0.1
0.2
0.2
0.1
ROOF*
FR
CR
CR
CR
FR
FR
FR
FR
"TO
FR
CR
FR
CR
CR
CR
VR
VR
VR
FR
VR
FR
FR
FR
FR
FR
FR
PV
FV
PV
PV
PV
PV
PV
CR
CR
PV
PV
PV
PV
VR
VR
VR
FR
FR
CR
* FR - Floating Roof, CR - Cone Roof, VR - Vapor Recovery, PV - Pressure Vessel
-------
-3-
TANK NO.
102
103
104
105
121
122
123
124
125
126
129
132
133
134
142
143
144
145
146
147
149
150
151
152
153
154
155
156
157
158
160
161
162
163
164
165
166
167
168
169
170
174
175
181
MATERIAL
Diesel
Solvents
Gas Oil
Gas Oil
Diesel
Solvent
Solvent
Solvent
Solvent
Gas Oil
Abs. Oil
Lt. Distillate
Lt. Distillate
Solvent
Diesel
Refinery Slops
Cracking Fd.
Solvent
Cracking Fd.
Cracking Fd.
Heating Oil
Heating Oil
Cutter STock
Weedkiller
Xylene
Lt. Distillate
Solvent
Hexane
Solvent
Abs. Oil
Gaso. Additive
Gasoline
Gasoline
Jet Fuel
Solvent
Jet Fuel
Solvent
Gaso. Additive
Jet Fuel
Kerosene
Solvent
Slop Oil
Reformate
Gasoline Base
.3
.7
CAPACITY
Mbbls
15.1
15.1
2.2
2.2
7.6
7.5
5.0
2.2
2.2
2.2
2.2
2.2
4.4
4.
16.
7.4
5.0
3.4
2.2
5.0
2.2
2.2
2.2
2.2
8.8
8.8
8.8
5.0
11.7
5.0
2.0
3.7
3.8
3.6
3.7
3.7
3.7
3.8
3.8
3.6
3.8
3.6
0.5
0.5
14.7
TYPICAL
THROUGHPUT VAPOR PRESSURE
bbls/DAY PSIA
1000
180
200
800
350
200
200
200
Out of Service
190
20
25
25
1300
300
100
125
125
125
120
120
150
150
300
160
225
3500
400
220
100
300
5
35
40
250
150
300
100
5
225
75
50
10
20
550
0.1
0.5
0.1
0.1
0.1
0.2
0.2
0.2
0.2
0.1
0.2
0.1
0.1
0.2
0.1
2.0
0.1
0.2
0.1
0.1
0.1
0.1
0.1
0.1
0.5
0.1
0.2
3.0
0.3
0.1
0.3
4.5
3.8
0.1
0.3
0.2
0.3
0.3
0.2
0.3
4.0
1.3
4.2
7.5
ROOF*
CR
CR
CR
CR
CR
CR
CR
CR
CR
CR
CR
CR
CR
CR
CR
CR
VR
VR
VR
FR
CR
CR
CR
CR
CR
FR
FR
CR
FR
CR
VR
VR
VR
FR
FR
FR
FR
CR
CR
FR
CR
FR
CR
CR
VR
*FR -Floating Roof, CR - Cone Roof, VR - Vapor Recovery
-------
TANK NO.
182
183
184
185
186
187
188
189
190
191
192
193
205
211
213
214-
243
247
261
262
263
268
269
270
271
272
273
274
275
276
277
278
280
281
282
283
284
285
286
287
288
289
298
301
302
303
MATERIAL
Jet Fuel
Solvent
Gasoline
Gasoline Base
Te trainer
Tetramer
Tiimers
Gasoline
Solvent
Gasoline Base
Lt. Distillate
Slop Oil
Low Sul. Fuel
Cat. Gaso.
Low Sul. Fuel
Low Sul. Fuel
Low Sul. Fuel
Refinery Slop
Solvent
Solvent
Solvent
Benzine
Solvent
Solvent
Solvent
Solvent
Solvent
LPG
LPG
LPG
Slop Oil
Kerosene
Solvent
Hexane
Solvent
Solvent
Toluene
Solvent
Xylene
Solvent
Toluene
Low Sulfur
LPG
LPG
LPG
CAPACITY
Mbbls
23.9
24.0
23.8
42.1
15.1
23.8
23.8
23.8
42.5
24.1
24.1
3.0
1.3
2.9
1.9
1.9
1.5
0.3
0.6
0.6
0.6
10.7
3.9
2.3
2.3
3.8
3.8
0.9
0.9
0.9
0.6
0.6
1.3
2.3
2.3
2.2
8.9
1.3
3.6
1.3
3.7
3.7
0.4
0.4
0.9
0.9
TYPICAL
THROUGHPUT
bbls/DAY
250
250
300
5500
144
144
500
380
4000
5000
150
250
200
1500
200
200
200
20
50
50
50
485
250
60
135
135
400
200
200
200
50
30
20
Out of Service
1000
15
35
200
265
20
300
10
100
200
200
200
VAPOR PRESSURE
PSIA
0.2
0.3
5.4
6.7
0.2
0.2
0.3
4.7
0.2
9.2
0.1
-
0.1
0.2
0.1
0.1
0.1
2.3
0.2
0.2
0.3
1.8
1.1
4.0
0.6
0.6
0.6
-
—
-
1.0
0.3
0.2
4.0
0,1
0.2
0.7
0.3
0.6
0.2
0.8
0.1
-
-
-
ROOF'
FR
CR
FR
FR
VR
FR
FR
FR
FR
VR
CR
PV
CR
CR
CR
CR
CR
VR
CR
CR
CR
VR
FR
FR
CR
CR
CR
PV
PV
PV
CR
CR
CR
VR
VR
CR
CR
CR
FR
CR
CR
VR
CR
PV
PV
PV
* FR - Floating Roof, CR - Cone Roof, VR - Vapor Recovery, PV - Pressure Vessel
-------
-5-
TANK NO.
325
326
327
396
397
399
611
612
616
700
773
789
790
791
903
904
905
955
956
957
958
959
968
969
MATERIAL
Propylene
Propylene
Propylene
Cracked Residuum
Cracked Residuum
Refinery Slop
Cutter Stock
Refinery Slop
Low Sul. Fuel
Refinery Slops
Cracking Feed
Low Sul. Fuel
Low Sul. Fuel
Low Sul. Fuel
Low Sul. Fuel
Low Sul. Fuel
Gas Oil
Isomer Feed
Gasoline Base
Desul. Feed
Desul. Feed
Cracking Feed
Lt. Cycle Oil
Reformer Feed
CAPACITY
Mbbls
1.0
1.0
1.0
20.1
20.1
3.8
2.2
2.2
1.1
15.3
100.6
15.2
16.0
14.9
2.1
2.1
10.7
37.2
152.2
152.1
151.7
165.0
151.2
165.6
TYPICAL
THROUGHOUT
bbls/DAY
150
150
150
330
330
15
100
15
100
25
18,000
167
220
204
40
40
15
Out of Service
8000
2000
7000
56,000
7000
9000
VAPOR PRESSURE
PSIA
_
-
-
0.1
0.1
0.3
0.1
0.2
0.1
0.4
0.1
0.1
0.1
0.1
0.1
0.1
0.1
-
0.3
0.1
0.1
0.1
0.1
0.4
ROOF*
PV
PV
PV
CR
CR
CR
CR
CR
CR
CR
VR
CR
CR
CR
CR
CR
CR
PV
VR
VR
VR
CR
VR
VR
* FR - Floating Roof, CR - Cone Roof, VR - Vapor Recovery, PV - Pressure Vessel
-------
APPENDIX F
Flare Systems
-------
DESIGN DATA
ATLANTIC RICHFIELD1COMPANY
WATSON REFINERY
PROCESS EMERGENCY HARES
Design Cti IUt«, SCFH
Oetlga Cat Race, Ib/Hr
Kalecular Velght
Sceaa Required For SooV*-
le«t. Burning, Ib/Hr*
Contributor* - CM S*Mt
Model 'Number
Stack Height - feet
Tip Diameter - inches
FCC FUSE
2,000,000
211.000
40
22.000
FCC lit Stg. Conor. -
200,500
FCC 2nd Stg. Compr* ••
126,500
Cthylcae Pit. - 32,100
tl DEA Unit - 4,900
12 DEA Unit - 4,900
ADDITIONAL STREAMS
U/IIYU'lOCIlACKhX FLARE DOUR
11 Reformer - 174.200
It. Hydrosenatlpa - 100,300
fl Reformer - 44.000
Rvy. Hydrogenttlon - 32,200
B-T Unit - 15,'7CO
Kid-Barrel Dejulf. - 11.600
104,000
STF-S-24
143
24
•IIYDSOCRACK™ VIMS
13,200,000
189,000
4.69
28,000**
Ejrdraerackar Raaet. Sect* -
168,800
Hydrogen Plant - 18.800
Jet Fuel !tydrotreet«e -
6,100
#2 Reformer - 174',200
It. HydrogenaClon •
100, SOO
fl Reformer - 44.000
Uvy. Hydrogatlttlon -
32,200
B-T Unit - 13,700
Mid-Barrel Desalt. -
11,600
106,000 •
STF-S-30
200
30
COKES PURE
1,855.000
'147,200
29. S
22,000***
11 Coker 8.0. Sytt. -
38.300
f 1 t 9 2 Coker Off eu -
53,600
Coker Cue Pleat - 33.600
TCC T-l - 39,800
12 Cokor D.D. ft OH CM -
29,300
TPA - 22.100
• 181 & 082 Cobb. Vet CM -
18,500
Alkylatlon - 10.600
KCU - Start-Up Fuel Gu -
6,300
13 DEA Untc - 4,900
14 DEA Volt - 4.900
STF-S-24
225
24
ABSORPTION FLARE
6,000 to 20,000
Refinery fuel gas
(
STF-12
125-
12
*•
P«eor.« Co! Deliga
JL-iJ TTierc.'oro Wai:ua Stcas la Scijulied.
••* S:cta Jctt Actv«ll7 Sized For 30.CCJ Ib Ste*=/BLr.
Ib Byoroc«kon/Er tod 28~,000 Ib Szw/Ss For
Burnlag. ^rdrog«a-Te-C«rboa Oatio Of Gas la
(24.9
-------
APPENDIX G
Product Loading Racks
-------
ATLANTIC RICHFIELD COMPANY
WATSON REFINERY
CARSON, CALIFORNIA
LOADING RACK
BULK TRANSFER OPERATIONS
Product
LP Gas
LP Gas
Aviation Gasoline
Premium Gasoline
Regular Gasoline
Solvents
Light Distillates
Diesel Fuel
Jet Fuel
Heavy Distillates
Heavy Distillates
Vapor Pressure
PSIA
140
140
4.0
5.8
5.B
2.0
(1)
(1)
1.7
U)
(1)
Carrier
Truck
Rail
Truck
Truck
Truck
Truck
Truck
Truck
Truck
Truck
Rail
Control
Equipment
(2)
(2)
Vapor Recovery
Vapor Recovery
None
None
Vapor Recovery
None
None
(1) Less than 0.5 PSIA vapor pressure.
(2) Equalizing line used while loading.
vapor recovery system.
Loading hoses evacuated through
-------
APPENDIX H
Wastewater Treatment Facilities
-------
f^-V^-F31--^
-H '." '"•'•' "'I COD *t~0,*t\
>""
: • f ' .!. i',*.- •
'.••• •
•
rt**t
lOO.OOOJfo
r0 O^-n.^fu
/ • *V." '
*~*e / jX^
X/o/v I
76 GO {fr\
ATLANTIC RICHFIELD COMPANY
RICHFIELD DIVISION
WATSON REFINERY
WASTE \.ATEK S^STEi
EFFLUENT Y/AT^IK TREATMENT
FLO1/1/ DIAGRAM
7-J/-6*
e-o L ;V.A...
trp •/•. i /
-'dr^ri.'
ALJ-H-'
BinuiCMMiir taaama IOMM
-------
APPENDIX I
Sulfur Plant Details
-------
ACID G« FMM
AKINE RECEH- ~
ERATOS AND SOUR
WATER STRIPPER
°
So
SOUR WATER
SOUR WATER SURGE
TO TREATMENT
SECONDARY COHVEirrt
STEM
WASTE HEATv
BURNER
PRIMARY CONVERTER
STEAM'
CONDENSERS-
-—
a
-J.
BOILER FEED WATER
AIR BLOREft
STEAM,
h-
-U.
L_
.TAIL CM TO
INCINERATOR OR
TAIL CAS PROCESSING
Q
c:::::eH
•UQUID SULFUR PRODUCt
SULFUR TANK AND SUMP PUMP
Typical packaged claus ptanl (2 stage).x.
-------
"CLAW TAIL GAS
(BEFORE INCINERATOR)
H2S
iS02
CS2
COS.
s
CO;
PACKED _^
REACTIO!T\
TOWER \
TRACES COS
CS2
QUENCH REACTION SOLUTION
RETURN SOLUTIOr
STRETFORD SOLUTION
RECYCLE REACTANT SOLUTION
STRETFORD ABSORBER
MAKE-UP
STRETFCRO
REGENERATOR
.1. 0,
STRETFORD SOLUTION
SULFUR
REACTION
SOLUTION.
RETURN STRETFORD
SOLUTION
FIXEO-BED
REACTOR (CO/MO
CATALYST t HYDROLYSIS
CATALYST)
STRETFOW)
PURGE
COOLER
PURGE STREAM
TO COOLING TOWER
BLOWER ' --LIQUID SULFUR TO STORAGE_
Flow diagram for the Cleanalr Claus tall-gas treatment process.
-------
iMkftttcltlc»iln.UIConniaay liKiHP.il C.vtiw idcnco
Palo:
To:
From:
Subject:
File:
Hatch 27, 2975
llr. C. L. Uclnricli (2)
1. Owcno
Scn5-Amm.il Survey of Sulfur Hloxldc Emitted
To The Alnio'-.p1\ei'c Vror> IV. finery l.'tu:cr Opcr.itlon*
10B
CC-2
Date Saoplcd - 1975
Sulfur Dioxide Emitted from Stacks:
FCC Unit Stacks:
Bast, Ten?., "F
Vel., ft./nin
SOfc. pp:a (Vol.)
Vest, Tenp., "F
Vel., ft./mitt.
.Odor Abatement Stack
TCDIJ>. , *F
Vel., ft./nin.
Sulfur Plnnt Incinerator Stack
Temp., °F
Vel., ft./min.
CVol.)
Ucrcaptan Sulfur in Extractive
Treaters:
TPA Debut. Mcrox Extractor
Gas to Odor Abatement Line!
Water, Vol. Z
Oxyp.cn, Vol. Z
HitroCp.n, Vol. 7.
i, Vol. Z
1/17
1/28 2/5
TEA Mcrox Oxidlxcr rate,
cu ft./mln.
490
6370
440
490
6540
325
1130
1565
365
720
3080
6200
it'.j 468
... ', 5860
L |> 475
» ) 468
£.' 6100
•; , «s
' >
r'"7 1075
• 1 1375
\J 300
. , 1 715
') 4265
f-.$ 6995
482
6820
415
482
6785
405
1230
1095
105
740
4175
5455
0.1*
6.2
83.8
1.2
3
il •'
'
i f
i
4 '
0.1*
12.0
82.7
1.1
2
0.1*
11.8
81.6
1.1
3
40
80
*Lcsn tli.in.
-------
BEFORE WE HEARING BOARD
of the
AIR POLLUnOH CONTROL DISTRICT
Of
LOS ANKLES COUNTY
In the Matter of
ATLANTIC RICHFIZLD COMPANY
Regular Variance—Section 24301 of
the California Health end Safety Code
Case Ho. 1011-38
JTIWPIKCS AMD DZCISIOV OF THS HSASIHO BOARn
Shis petition for a variance vas heard May 15, 1975,
pursuant to notice la accordance vita the provisions of the
California Health and Safety Code Section 24295(a), (b), and
(e). All Hearing Board members were present. Petitioner was
represented by Jeffrey R. Pendergraft, Attorney at Law.
Respondent, Air Pollution Control Officer, vas represented by
John B. Larson, County Counsel, by his deputy John V. Nhltsett.
Evidence vaa received, the case submitted, end the Hearing
Board finds end decides as follows:
Petitioner la operating an oil refinery end in
connection therewith is constructing a sulfur recovery plant
for the purpose of reducing the emissions of sulfur compounds
-to the atnosphere. Increoents of progress have been adopted
«nd February 19, 1976, has been established as the conpllance
date. Petitioner has heretofore been granted a variance fron
Rules 50, 53.2 and 10(b) of the Rules end Regulations of the
Air Pollution Control District and is now before the Hearing
Board to report progress. Reference is made to Findings of
previous bearings for full particulars.
The evidence shows that* as of the date of this
-hearing, petitioner is on or slightly ahead of schedule.
Engineering work is 96# complete, major equipnent has been
procured or is on order, and delivery dates have been
established that conform to the increaenta of progress. The
-1-
-------
•teel construction la now 2454 coaplete instead of 20K as
shown by the increments of progress.
The emissions of hydrogen sulfide no longer violate
Rule 53.2(2) end there is no longer a violation of Rule 50.
Thus a variance from Rules 50 and 53.2(2) is no longer necessary.
Tests have established that the effluent gases contain up to
7(000 parts per «<•»•»««« of sulfur compounds calculated as
sulfur dioxide—Rule 53.2(1}—end 665 pounds per hour of
sulfur compounds calculated as sulfur dioxide—Rule 53.2(3).
The Hearing Board further finds as follows: that
petitioner is la violation of Rules 53.2(1), 53.2(3), and
10(b) of the Rules and Regulations of the Air Pollution Control
District} that, due to conditions beyond the reasonable control
Of petitioner, requiring conpUnnca would result in -the practical
Closing and elimination of a lawful business; and that such
Closing would be vlthout a corresponding benefit in reducing
&lr contaminants.
KOV, TK5t£FOR£, the variance heretofore granted frca
ftuleo 53.2(1) and 53.2(3) of the Rules and Regulations of the
Air Pollution Control District is hereby extended until
February 19, 1976 and the variance froa Rule 10(b) is extended
until April 19, 1976. Petitioner's increnents of progress
shall continue in force *** effect as heretofore adopted, and
dta compliance date of February 19. 1976 is unchanged.
frr^ie the period of this variance petitioner shall
not discharge into the ataosphere effluent process gas
-containing more **\"n 7,000 parts per million by voluae of
sulfur compounds calculated as sulfur dioxide and 665 pounds
-------
hour of sulfur compounds calculated as sulfur dioxide.
Vot«: Aye — Parka, Schooling, Vivian; No— Koch, Washington
Dated: Kay 15, 197?
AIR POLLUTION CONTROL KZARIJiC BOARD
£L
Veni
Vcrdell \,. Sch
endel1 a. Schooling,
'«/ San K. Parks, ".P.
£
K. Parks, M.D.
Tt. ~. Vlvl.in
1. JM Vivian
WStlb
Ve dissent.
In view of the fact that none of the conditions
-have changed In this matter, we wish to make reference to the
dissenting Decision dated January 16, 1975 and Introduce
those facts again aa our reason Tor voting "Ho" on this date.
's/ "gyth C. Koch
;. Koch
/s/ rou?la9 C. Vaahln-ton
Douglas G.
KK:DCV:ib
-------
BEFORE THE KEAF.IHG BOARD
of the
AIR POLLUTION CONTROL DISTRICT
Of
LOS ANGZLZ3 COUNTY'
In the Katter of
ATLANTIC RICHFIELD COIIFANY
Regular Variance—Section 24301 of
the California Health end Safeiy Code.
Case No. 1011-30
AND DZCISION CF THS i{SA3i:;s SCARP
This petition for a variance vas heard January 16,
1975. pursuant to notice in accordance vith the provisions of
the California Health and Safety Code Section 24295(a), (b).
and (c). All Hearing Board members were present. Petitioner
vas represented by Jeffrey R. Pendergraft, Attorney at LEW.
Respondent, Air Pollution Control Officer, vaa represented by
John H. Larson, County Counsel, by his deputy John V. Whitsett.
Evidence was received, the case subaitted, and the Hearing
Board finds and decides aa follows:
Petitioner operates a petroleum refinery at 1801 East
Sepulveda Boulevard, Carson. California, vith a capacity of
150,000 barrels of crude oil per day and producing about
1,000,000 gallons of gasoline per day. The equipment involved
in the present petition .a the tall-gas unit of the sulfur
recovery system, which is needed to meet the requirements of
Rule 53.2 of the Rules and Regulations of the Air Pollution
Control District. The three-stage Cleus units of the sulfur
recovery system reaove about 97* of tho sulfur from the gases
produced in the refining of the petroleum, but the stack gases
from the Cleus units still have emissions that run 1,500 ppn
of sulfur gases, whereas the allowable emissions under
Rule 53.2 is less than 500 ppm.
A contract vas given by petitioner to the J. F.
Pritchard Coxpany to build and install a tail-gas unit to meet
-1-
-------
Rule 53.2. Vbea installed, thla unit foiled to perform satis-
factorily and the Pritchard Company went back to more pilot
plant work. Meanwhile, petitioner began developing its own
tail-fas unit in its laboratories. Reference is hereby cade
to the several prior Decisions on this matter beginning with
the first one dated Juno 19, 1973 through the last one dated
November 19, 1974.
The project manager for Pritchard Cocpany testified
today as to the progress cade on thl« problea since the
November 19, 1974 hearing. The process design work is finished
and the Pritchard Cocpany is working on the mechanical design
•nd ordering equipaent. Sone of the equlpcent cczmot be
ordered until the final design worlz is completed. Critical
iteas ara the T-325 H2S stainless steel absorption tower oa
which bids have Just been received and eight months1 delivery
tine is estinated; also the K-324 clean air slurry tarJs riie
frnff not been purchased yet and bids quote nine conths for
delivery. There has been six weeks' tine lost due to uncertain-
ties, ""* the final date for purchase of all components for the
Pritchard unit is new estimated as June 15, 1975 with oa-site
construction to start Juno 1, 1975 and a compliance date of
January 21,.1976.
Petitioner's manager of process engineerinc testified
that he was familiar with the Pritchard tail-cas unit; also
the ARCO unit being built by the Parsons Company on which
construction started on December 1, 1974 wJ.th conviction
estimated to bo Decenber 19, 1975. Thereafter, two conths
will be needed for start up and testing. Purchase orders
have been Issued for all major equipment iteas.
Project schedules have been submitted today for both
the Pritchard unit and the ARCO unit, but the schedule for the
Pritchard unit is less certain. Installation of these two
units cannot be done simultaneously since the space for
-------
installation is Halted end there would be Interference c&used
thereby. It was testified that the ARCO-Farsons unit will give
a eonevhat earlier coop"! •!=»"** with Rule 53-2 end has a flraer
schedule with more reliable operation expected.
An engineer for the District testified that authori-
ties to construct have been granted for both the Fritchard unit
end the ARCO unit. A violation of Tcule 53.2 has been established
fjiA as much as 2,000 pounds of sulfur gases per hour, calculated
as SO-, nay be enltted during a variance.
Counsel for petitioner requested adoption of the
schedule for the ARCC unl-t with a ccnpllence date of February 19,
1976, and a varicnce froa Eules 10(b), 50 cad 53.2 i=vtil that
tioe. Respondent's counsel recossended a further hearing; in
l!ay 1975 if & variance was granted.
The Hearing Board further finds as follows: that
petitioner is in violation of Rules 10(b). 50 sad 53.2 of ths
Rules and Regulations of -the Air Pollution Control District;
that! due to conditions beyond the reasonable control of
petitioner, requiring coc^jlifisce would result in the practical
closing end eliniaation of a lawful business; and that such
Closing would be without a corresponding benefit in reducing
air contaalnants.
NOW, TKSSSFORS, petitioner's variance fron Rules 10(b),
50 and 53.2 of the Rules and Regulations of the Air Pollution
Control District is extended until Kay 15, 1975, at vhich tiae
at 2:00 p.m. there will be a further hesrJas vitaout further
notice In Roon 903, 33.3 Horth Figueroa Street, Los Angeles,
California.
Petitioner's fMspn»"«*-* schedule and increaents of
progress adopted by this Hearing Board on July 10, 197A for
its Prltchard Coapany unit la hereby vacated.
Petitioner's compliance schedule and incroaents of
progress for its X=JCO-Parsona unit are adopted by this Hearing
-3-
-------
Board as follows, and petitioner la ordered to conply there-
with i
It Awarded contracts May 1, 1974
2. Submitted applications for authority
to construct to the Air Pollution
Control District June 21, 1974
3. CD-site construction began December 2, 1974
4. On-site construction completed December 19, 1975
5. Final compliance date is February 19, 1976
Petitioner's final compliance date is February 19, 1976.
Votei Aye—Parks, Schooling, Vivian; Mo—Koch, Washington
Datedi January 16, 1975
AIR POLLUTION CGIITROL HEARING BOARD
/a/ Kcndoll i . -:et-coli.-.T
'endeil V. Schooling, Caoinnan
Sen K. Perks. >!.C.
K7 Fanes, i..D.
V R. r. Vivlrn
R. £. Vivian
REVtiD
Ve dissent.
This natter first case before tho Hearing Board on
June 19. 1973. At that tine, evidence showed that authorities
to construct.had been granted on December 23, 1972 to construct
a eulfur recovery plant referred to as the Pritchard three-
etage Claus unit. It was estimated that construction of the
volt would be completed by July 15. 1973 end start up by
Auauot 1. 1973. Since Rule 53.2 went into'effect July 1, 1973,
petitioner was granted a variance.
On Septeobcr ?&, 1973 petitioner requested an
additional 60 days, for testing and evaluating, to solve
unforeseen process problems. On October 30, 1973, petitioner
filed an amendment to petition for modification.of its variance
requesting an additional 150 days.
-------
On November 5, 1973. the Air Pollution Control District
issued a letter of denial for permits to operate the sulfur
recovery plant. Two days later a petition was filed to review
the denial and a request vas made to extend the variance to
March 1, 1974. This matter wae heard on Deceaber ft. 1973.
Evidence ehowed that chucks of sulfur vere being foraed vhlch
caused the unit to plug up. Exports were consulted and addi-
tional testing needed to be done. It was anticipated at that
•tlse to take approximately three months to solve the problem.
the variance was extended to April 4, 1974.
On April 4, 1974, petitioner testified that it was
coveting a second tail-gas unit to be operated vhen the
Frltchard unit is shut down for maintenance. Evidence showed
that a contract was to be let on Kay 1, 1974 end construction
to start by Deceaber 1, 1974, with a coupletion date of
Peeeabcr 1. 1975. end final compliance on February 1, 1976.
It vas the opinion of the Hearing Board that a final compliance
data of February 1, 1975 vas entirely too long end that
petitioner should therefore cosplete the Pritehard unit. The
•variance was extended to July 10, 1974, for a further hearing
en the progress of the Pritchard unit.
On June 7. 1974, a letter from the Refinery Manager
•indicated that petitioner vas evaluating test data on the
Pritchard unit but that Pritchard had not as yet submitted
••design modifications. A compliance schedule vas also filed
.outlining date of construction of the Kcw Unit to begin
December 1, 1974 and cc=?lctlon on December 1, 1975. A supple-
mental compliance schedule vac also filed shoving on-elte
construction for the Pritchard modifications to begin Deceaber 1,
1974 vith a completion date of June 1. 1975.
On July 10, 1974, evidence showed that the Pritchard
Company bad completed its pilot plant program end that codifi-
cations would soon be recosaendcd. A progress report was also
-------
Offered on the N'ev Unit; however, it vas the opinion of the
Hearing Board that the Pritchard unit vaa the natter under
consideration and that the progress of the new back-up unit
vas not the concern of the Board. The variance vas extended
vith a further hearing scheduled for November 19, 1974. On
Septcabcr 15. 197**, two conths after the hearing, a cocpliccce
schedule for the Pritchord unit vas suboitted showing a find
compliance date of July 1. 1975.
At the November 19, 1974 hearing, a witness from the
Pritchard Company testified that since the last hearing-, Ms
company finalized the process design on the tail-gas unit and
gave this to petitioner on October 30, 1974. He further
testified that difficulty vas encountered by unanticipated
problems in converting froa pilot plant work to full scale
design for petitioner's plant. Evidence again was introduced
relating to the Kev Ur.lt but the Hearing Board held the opinion
that petitioner should complete its plans of the Pritchard unit
first since it vas a proven method of control and that prior
testimony indicated compliance at a much earlier date than that
of the New Unit. The variance was extended and a new final
compliance date adopted for July 1, 1975.
CD'January 16, 1975, IS months after Rule 53.2 went
Into effect, petitioner testified that the now conpllance date
on the Pritchard unit would now be January 21, 197C; therefore,
It vas abandoning the Pritchard unit for its New Unit. The
•evidence showed that the Installation of these two units could
not be done simultaneously although the compliance schedule
-submitted on June 7, 1974 indicated that construction would
•tart on both units on December 1, 1974. The evidence also
showed that the emissions of S02 are 2,000 pounds per hour and
that Rule 53.2 sets limits of 500 pounds per hour. Between
July 1, 1973. (the date that Rule 53.2 vent into effect) and
February 19, 1976. (petitioner's final compliance date)
-------
petitioner will have caJ-tted^h6.080,000 pountia of sulfurf
Into the ataosphere.
In suznary, the Hearing Board stated In the Decision
of April 4, 1974, vhen evidence ot a final cocpllance of
February 1. 1976 was Introduced, that this was unacceptable and
yeti nine souths later, by majority vote, the Board voted to
accept this coopliance acbecule Baking the variance a total of
two years end eight ccntha.
Ve believe that petitioner.knew in April 1974 that its
priorities bad changed. The new tall-gas unit was proceeding at
aa accelerated pc.ee while core end aore deleys were being experi-
enced with the Prltchcrd unit. Although petitioner wee repeatedly
told by the Board that it vas interested only in the Pritchard
unit, petitioner continued to introduce, over tho months, aore
and oore information related to its Uev Unit. We believe that
the Beard vss deliberately aisled and had tho true facts been
-Introduced as far back as April 4, 1974, in all probability, a
perfornance bond would have been required aa a condition of the
variance.
Another sejor sisleedine fact was that both units could
be constructed sirultaneously. Kov, we are told that this is a
physical icpossibility. Surely, petitioner must have been
avare of this fact frcn the very beginning.
In view of the known health hazard of S02 gases,
'especially in the South Coast Basin, we cannot in true conscience
agrco-to continue this variance. V.Tiat proof is there that
petitioner will be in cospliance by February 1S76. We know of
none; therefore, we vote to deny petitioner a further extension
of its variance fron Rule 53.2
Mvth C. "cch
tb. C. r.ccn
/»/ Douflaa C. Vpghir.etoa
LougloB U. '«asnjjigton
-7-
-------
APPENDIX J
Source Test Results
-------
REPORT
TRUESDAIL LABORATORIES, INC.
CHEMISTS - MICROBIOLOGISTS - ENGINEERS
•CBCARCH - DEVELOPMENT - TESTING
DUPLICATE
4IOI N. FIQUEROA 3T1CE7
LOB ANOELES 9 O 0 & S
AREA CODE 213 • 225-1*64
CABLE: TRUELABS
CLIENT
SAMPLE
Atlantic Richfield Co.
P. 0. Box 737
Ullciacton, CA S0744
Attention: 1-lr. Carl L. Heinrick
Contract Work Order CA-222
DATE Kay 22, 1975
RECEIVED ;.prii ig, 1575
LABORATORY NO.
INVESTIGATION
Pcrticulate natter emissions on each of the two (2) stacks of the
F.C.C. unit precisiiator, ujir.^ the Los Angeles County AFCD ncthod
and also us ins the EPA :i2thod No. 5.
RESULTS
On May 7, 1975, representatives of Truesdail Laboratories, Inc.
raade air pollution source tests on eaissions froa both stacks of the Fluid
catalytic crtcliins (F.C.C.) unit located at tha Atlantic Richfield (A.\CO)
Watscrr r.c£ir.ery, 1301 C. Cazulveda Llvd., Carson, California. ui--rulta:iacus
tests vare ttcde cr. ooth £tac.:s. The tests were conducted to detemina
concentrations ar.d emission races of participate =atter. Test locations
vere 1.5 stcck dia-iters belai; the top of die stacks. The stack hsi.r:iit i:as
85 feet. The unit was operating at consal production rate during tna testify.
The tests vere cade by tt?o cethoda— Z?A 1 let hod No. 5, and the Los
Angeles County Al'CD r^thc-d (wst inpin^encnt). Doth sets of tests were
conducted simultaneously in both stacks.
The EP£ particulate Batter scnple was collected across occ dia.-r.etcr of
the str.sk froa six travcrss points. Ihe vet i=pingeccnt ccthod sacpie MZS
collected frca a single point representing the average flue gas velocity in
the
The partleulcte cattcr collected In the pnrticulatc catter sa
trains "as ccalyzcd for "-=»niun 0"-l4^) ion, to determine a=ior.iua cui.atc
collected in th.c particulate emitter cauplc. The a-noniuai sullate found vas
subtracted froa the co-c.1 pcrticulate cattsr collection for the calculcticr.c.
The results vcrc c!.ec!:cd by heating part of the sample at bOO°r to drive off
n salts. Eoth results agreed veil.
An Orsnt cnalyoia for CO-j and 02 v;as cade on the nitrogen o::idc
eanplcs token every 3V minutes during the tvo hour particulate i=attcr testing
period.
The culxur dioxido (GOo) scsplo was collected in the inDinj-.cro of the L?.'
eaisplii-.."1, train. A 3« H-,02 solution -was used to oxidize S02 to culfuric r.cid
in the
Thb rrpon uppl-n only :o itir umptr. or umplri. invtitip.urd nnj ii not nrcruiirily indicnivc of I he quality or condition of .ipp in •• !.•
Adcnlical or uuiLir pru.uctA. «\J j ntueu.il pro:&i::ion la ^iuiiu. die public niiii ilicsc Laborjlonci, iJus rrjjarc M lubmiiccd nnti ILL i >•!
fof ihr rxcluurr uw ai' :l-f client ci> »!iom u u aJJ.i-iird nnj upon uir cnminiun cli u u 11 not (o be unil, in »liule or in parr, m un/
oc publ^uy n^anvr wuiioui prior written uuthoiizjuon fioni ilicac Laboratories
-------
DUPLICATE
TRUESDAIL LABORATORIES. INC.
Page 2
Lab. No. 4232
The results vcre as follows:
Testing Period: 1:55 to 3:55 Rt
Particulate Matter: E.P.A. Tests (Method Ho. 5)
past Strck Vest StrcV:
Flue Gas:
Tenperaturo, °F 530 563
Velocity, ft/sec. 105.0 111.3
Static pressure, Inches 1^0 -0.8 -O.S
Flue dieneter, inches 72. 72.
Flue area, sq. ft. 28.27 26.27
Flue gas flow rate:
ACTS 178.100 188,800
SCFM 95,000 97,400
DSCFH «3 70°F) 78.000 80,400
Water Vapor, Z by vol. 17.9 17.5
Total Emission, DSCEM 158,400
Particulate Hatter:
Smple collection, c^fcns 0.0287 0.0374
Sanple volv=:e, C3C7 64.77 64.43
Test duration, ziiitutss 120 Z20
Percent isokicctic cspling 102.1 100.2
Concentration, grains/DSCF O.OO58 O.CC09
Emission Rate, Lbc/hour 4.6 _ 6. 2
Total Enission Rate, Ibs/hour 10.8
Partieulate Matter: Los Angeles County APC3 Method C'et Iicpingcacat)
collection, grcas 0.0301 O.C309
Sanple volume, D3CF 61.86 63.36
Concentration, graias/C3CP 0.0075 0.0075
Emission rate, Ibs/aour 4.9 5.1
Total Enlsclon Kate, Ibs/hour 10.0
Flue gas flow rate, T;5CTM <9 60" F) 76,500 78,900
Total Enission, DSCFM 155,400
-------
DUPLICATE
TRUESDAIU LABORATORIES. INC. pogc 3
Lab. No. 4232
East St?ck West Stack
Mitror.cn Oxides (MO.,).
Concentration, pnn 146 141
Emission Rate, Iba/hour (as N(>2) 81 ____ ___ 81
local Emission Rate, Ibs/hour
(as K02) 162 •
Cos Analysis (Orsnt)
Carbon dioxide (C02) , 1 15.4 15.2
Oxygen (02) , 7. 1.3 1.3
Total Anhydrous fjxsoTiin (XH3) , Ibs/hour 36
(determined in a V.'cc Lrpingemcnt sanpling train)
Photocopies of field data and calculation sheets are appended to
this report.
Respectfully submitted,
TRDESDAIL LABOrATCRISS , TIC.
cs Sandziulis
Supervisor,
Air Pollution Testing
------- |