State of California
                            AIR RESOURCES BOARD
                               Jack Tar Hotel
                                Garden Room
                              Geary & Van Ness
                             San Francisco, CA
                              August 24, 1977
                                 10:00 a.m.

77-18-2   Report on Chevron, USA, Richmond Refinery, Low Sulfur         1
          Fuel Oil Facility.

77-18-3   Consideration of Model Upset/Breakdown Regulations.           61

77-18-4   Report on Air Pollution Control Problems at Geothermal        232
          Power Plants.                                       

77-18-5   Other Business -
          a.   Executive Session - Personnel & Litigation
          b.   Research Proposals

                        ITEM NO.:  77-18-2

Report on Chevron, USA, Richmond Refinery, Low Sulfur Fuel Oil


That the staff be directed to:

     1)   Continue to follow the progress of the hearings
          underway in the BAAPCD on the proposed revoking of
          Chevron's permit-to-operate its No. 4 Crude Unit.

     2)   Continue to make the appropriate effort to obtain
          needed data for emissions calculations from Chevron.

     3)   Report back to the Board on the outcome of the Hearing
          Board's proceedings.

     4)   Subpoena the required information if not supplied to
          the ARB staff.


On October 26, 1973 the Bay Area Air Pollution Control District
(BAAPCD) granted Standard Oil of California a permit to construct
a low sulfur fuel oil (LSFO) facility at its Richmond refinery
which would increase the crude refining capacity of the then
existing refinery.  Because the refinery's capacity was
increased, the District placed the condition on Chevron's permit
that when operation of the no. 4 Crude Unit began, two other
existing crude units had to be shut down so that the LSFO
facility could qualify under the District's replacement rule,
1311.  Standard agreed to the condition until operation of an
expanded facility if that facility had a significant reduction in
all pollutant emissions.  The District later changed its
regulation to allow this condition by adding Section 1311.2 to
its regulations.  When Standard applied for permit to operate its
No. 4 Crude unit in 1976, the district granted the permit but
placed on it the condition that two existing cure units should be
shut down when the No. 4 Crude Unit was operating.  Standard
objected to this condition, stating that since the District had
changed its regulation to permit an expanded facility to operate,
that Section 1311 of the District's regulations was no longer
applicable.  Accordingly, Standard did not shut down any other
crude units when the No. 4 Crude unit began operating.  The
District subsequently issued two violation notices to Chevron
(Standard Oil changed its name to Chevron U.S.A. Inc. on January
1, 1977) for being in violation of the condition on its permit-to-operate 
and applied to its Hearing Board to have Chevron's
permit to operate its No. 4 Crude Unit revoked.  The hearings
began April 21, 1977 and are still in progress.

In reviewing several tables (emission summaries) of refinery
pollutant emissions that Standard had supplied to the BAAPCD
between July 20, 1973 and October 26, 1973 to support the firm's
contention that levels of various pollutants would be reduced
with the building of the LSFO Project, the staff of the ARB noted
several discrepancies in emission totals for certain pollutants
even though the time periods when the emissions occurred were the
same.  In addition, a hypothetical analysis performed by the
BAAPCD staff indicates that by Chevron's operating the new LSFO
facility without decommissioning other crude processing units the
Refinery is emitting more particulates than it would have without
modifications.  To verify the accuracy of the emission summaries,
the staff twice requested from Chevron the detailed calculations
to support the emission totals in the summaries.  Chevron,
however, has twice refused to supply all of this information,
presenting partial information instead.  The staff, in a letter
dated August 8, 1977, again requested information to substantiate
Chevron's claim of emission reductions.  In addition the staff
requested that four of Chevron's personnel who had been
instrumental in calculating the emission totals voluntarily
attend the Boards August 24, 1977 meeting.

                        ITEM NO.:  77-18-3

Further Consideration of Model Upset/Breakdown Rule.


Adopt Resolution 77-43 which proposes a Model Upset/Breakdown
Rule for all air pollution control districts to adopt.


At the May 25, 1977 Board meeting, the Board directed the staff
to review the upset/breakdown records of the South Coast Air
Quality Management District and the Bay Area Air Pollution
Control District in order to determine the manner in which these
districts handle upset/breakdowns in industry and based upon this
review to make recommendations for changes if necessary, to the
previously proposed Model Upset/Breakdown Rule.  The staff
reviewed the upset/breakdown records of each district for the
period June 1, 1976 through May 31, 1977, during which time 3918
upset and/or breakdown occurrences were reported, of which
approximately 95 percent were determined to be less than 24 hours
in duration.  Table S-1 illustrates the action taken by the two
districts in response to the reported upsets and/or breakdowns. 
As shown in this table, out of the 3918 reported upsets and/or
breakdowns, only 69 resulted in penalty action.  As a result of
its study, the staff arrived at the following conclusions and

1.   Most upset/breakdown occurrences are of short duration.

2.   Upsets should be excluded from the model rule.

3.   Recurrent breakdown of the same equipment appears to be a
     major problem.

4.   The burden for explaining and justifying why an occurrence
     is a justifiable upset/breakdown must be placed on the

5.   The districts need to establish clear, separately
     identifiable procedures for the investigation and
     enforcement of upset/breakdown occurrences.

6.   Monitoring equipment should be included in the model rule,
     but treated differently.

7.   Nonvisible emissions must be reported and verified.

8.   There must be a deterrent to false upset/breakdown reports
     or claims.

9.   All upset/breakdown occurrences must be reported.

10.  Some upset/breakdowns do not cause violations of the
     applicable emission standards.