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Project
No.:
0172.01.005.062
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Project
Name:
304m
Petroleum
Refinery
Detailed
Investigation
TELEPHONE
CALL
RECORD
Incoming
Call
Date:
Nov
18,
2003
Time:
11
AM
EST
Company
Name:
Washington
Department
of
Ecology
Contact
Name:
Nancy
Kmet
Phone
No.:
(
360)
407­
6941
nkme461@
ecy.
wa.
gov
Name:
Betsy
Bicknell
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
Background
on
Water
Pollution
Prevention
Opportunities
in
Petroleum
Refineries
TOPICS
DISCUSSED
AND
ACTION
TAKEN
Background
information
about
refinery
wastewater
generation
includes
the
Washington
Ecology
Publication
No.
02­
07­
017,"
Water
Pollution
Prevention
Opportunities
in
Petroleum
Refineries,"
November
2002.

Nancy
Kmet,
Industrial
Section,
Washington
Dept.
of
Ecology,
responded
to
my
e­
mail
request
for
additional
information
about
this
report.

Who
at
Jacobs
Consultancy
was
the
main
author
of
the
report?
Ms.
Kmet
remembered
that
Lloyd
Posey
and
another
man
whose
name
she
didn't
recall
were
the
main
staff
responsible
for
the
report.

*
How
did
the
report
come
to
be
written
and
what
has
been
done
with
the
findings?
Washington
initiated
a
NPDES
permit
requirement
for
the
refineries
to
prepare
pollution
prevention
plans.
Ecology
was
not
entirely
satisfied
with
the
refineries'
first
attempts
­
they
were
too
facility­
specific.
Stan
Springer
(
now
retired
from
Ecology)
obtained
a
Federal
"
PPIS"
grant
to
hire
a
petroleum
industry
consultant
to
prepare
the
industry
report.
Jacobs
Consultancy
was
selected
because
of
their
experience
in
the
industry.
Ms.
Kmet
reported
that
Ecology
was
happy
with
their
product.
The
refineries
are
now
working
on
their
next
generation
P2
plans,
and
will
have
the
opportunity
to
include
practices
described
in
the
report
in
their
own
facility
plans.

*
What
are
the
biggest
wastewater
pollution
problems
associated
with
refinery
wastewaters?
Ms.
Kmet
reported
that
in
general,
the
biggest
problem
is
keeping
oil
&
grease
out
of
stormwater.
Stormwater
that
does
not
originate
in
the
immediate
process
area
is
not
routed
to
the
activated
sludge
treatment
system,
though
it
may
contain
excessive
amounts
of
oil
and
grease.

In
terms
of
toxic
releases,
the
biggest
problem
is
dioxins.
For
this
permit
cycle,
Ecology
required
refineries
to
conduct
a
dioxin
study.
Dioxins
were
detected
in
samples
collected
by
all
refineries
that
had
submitted
data
to
Signature:
date.
At
least
one
refinery
had
detected
dioxins
in
its
final
effluent.
She
thinks
it
is
different
than
the
other
refineries
because
of
its
catalytic
reformer
regeneration
practices
(
continuous
regeneration?).
Dioxins
were
also
detected
in
reformer
wastewaters
and
in
API
separator
sludges.

To
obtain
the
dioxin
data,
Ms.
Kmet
suggested
that
I
contact
Kathy
Vermillion
(
360)
407­
6919.
I
called
Ms.
Vermillion
and
requested
the
data.
Ms
Vermillion
thought
it
would
be
shipped
to
me
by
Nov.
21.

*
Do
you
have
any
concerns
about
the
existing
petroleum
refining
effluent
limitations
guidelines
(
40
CFR
Part
419)?
Ms.
Kmet
mentioned
that
Ecology
had
previously
commented
to
EPA
that
the
regulations
for
conventional
pollutants
should
be
updated.
Refineries
presently
discharge
far
below
their
permit
limits
(
which
are
based
on
the
existing
guidelines).
I
discussed
issues
related
to
the
BCT
cost
test
and
lack
of
precedent
for
revising
BPT.
Ms.
Kmet
said
she
didn't
understand
all
the
Clean
Water
Act
issues,
but
that
when
Ecology
sets
permit
limits
that
are
far
higher
than
refinery
discharges,
they
receive
adverse
comments.
Ecology
was
disappointed
that
the
proposed
revised
conventional
limits
for
the
pulp
and
paper
category
were
not
promulgated.

Ms.
Kmet
also
suggested
that
it
wouldn't
hurt
to
have
limitations
guidelines
for
dioxins.
Ecology
may
push
inplant
dioxin
controls
for
reformer
regenerant
wastewaters.
In­
plant
limits
analogous
to
the
pulp
mill
bleach
plant
limits
would
be
useful.

*
What
factors
would
influence
whether
a
refinery
discharges
dioxins?
Do
you
know
why
Washington
state
refineries
do
not
report
dioxin
releases
while
other
refineries
do?
Ms.
Kmet
suggested
that
refineries
that
had
not
monitored
for
and/
or
detected
dioxins
in
their
effluents
would
not
report
dioxin
releases
to
TRI.

*
The
report
describes
some
process
modifications
(
diversion
of
flue
gasses
to
fireboxes)
that
could
be
implemented
at
refineries
to
reduce
the
generation
of
dioxins
(
p.
53).
Have
the
Washington
refineries
made
these
kinds
of
modifications?
Ms.
Kmet
was
not
aware
that
any
of
the
refineries
had
yet
made
any
adjustments
to
their
operations
to
control
dioxins.
They
may
need
to
do
so
to
meet
potential
new
permit
requirements.

*
What
equipment
vendors
are
experienced
in
solving
refinery
wastewater
problems?
Ms.
Kmet
suggested
that
I
talk
to
Jacobs
about
this.

*
Are
wastewater
discharges
of
polycyclic
aromatic
compounds
(
PACs)
typical
of
the
industry?
What
factors
would
influence
whether
a
refinery
discharges
PACs?
In
2000,
none
of
the
Washington
state
refineries
reported
wastewater
releases
of
PACs,
but
nationwide,
in
2000,
19
refineries
reported
surface
water
and
POTW
releases
of
PACs
while
164
refineries
did
not
report
releases.
Ms.
Kmet
was
not
familiar
with
the
term
PAC.
She
uses
the
term
PAHs
(
polynuclear
aromatic
hydrocarbons).
She
was
not
familiar
with
any
issues
related
to
their
discharge.

*
Do
you
think
discharges
of
toxic
metals
are
a
problem
for
the
Washington
refineries?
Ms.
Kmet
said
that
the
only
metal
that
is
sometimes
a
problem
is
mercury.
She
recalled
that
one
refinery
had
turned
back
a
shipment
of
crude
oil
with
a
mercury
concentration
that
was
too
high.
She
mentioned
that
because
Washington
allows
a
dilution
zone
for
compliance
with
water
quality
standards,
their
metals
limits
may
not
be
as
low
as
some
other
states.

*
What
toxic
chemicals
are
released
from
refineries,
but
not
reported
to
TRI
or
PCS?
Ms.
Kmet
was
not
aware
of
any
un­
reported
releases.
