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Project
No.:
0172.01.005.062
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Project
Name:
304m
Petroleum
Refinery
Detailed
Investigation
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
11/
25/
2003
Time:
11:
45
­
12:
45
Company
Name:
Jacobs
Consultancy,
Houston
TX
Contact
Name:
Mickey
Reeves
Phone
No.:
(
832)
351­
7807
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,
identified
Lloyd
Posey
with
Jacobs
as
an
author
of
the
report.
Mr.
Posey
replied
to
my
voice
mail
message
by
voice
mail
that
Mickey
Reeves
was
the
most
knowledgeable
within
Jacobs
about
the
water
pollution
prevention
issues.
I
called
Mr.
Reeves
and
he
spent
about
an
hour
talking
with
me
and
freely
answered
all
of
my
questions.

I
explained
that
ERG
was
an
EPA
contractor
supporting
Office
of
Water,
EAD
with
their
review
of
existing
effluent
guidelines
and
developing
a
plan
for
additional
guidelines.
I
explained
that
the
petroleum
refining
was,
along
with
some
other
categories,
at
the
top
of
EAD's
list
due
to
reported
releases
of
dioxins,
PAHs
(
PACs)
and
toxic
metals.
Mr.
Reeves
agreed
that
dioxins
were
present
in
wastewaters
from
reforming
catalyst
regeneration.

PAHs
(
PACs).
Mr.
Reeves
opined
that
PAHs
were
present
in
"
lots
of
products,"
particularly
the
heavy
materials
(
petroleum
coke
and
slurry
oil
from
catalytic
cracking).
When
I
wondered
why
of
the
180
or
so
refineries
that
reported
to
TRI,
only
19
reported
PAC
releases
to
wastewater,
Mr.
Reeves
speculated
that
most
refineries
don't
monitor
wastewater
for
PACs.

Mr.
Reeves
mentioned
that
because
PACs
are
not
very
soluble
in
water,
releases
were
likely
associated
with
discharged
oil
and
suspended
solids.
We
speculated
that
improved
oil
and
solids
separation
might
reduce
total
plant
PAC
releases.
Mr.
Reeves
could
not
suggest
a
specific
waste
stream
that
would
likely
be
high
in
PACs,
but
he
wondered
if
facilities
that
reported
PAC
releases
also
used
delayed
coking
operations.
Delayed
coking
is
a
batch
process
that
generates
a
heavy
residue
that
cannot
be
cracked
further.
This
material
is
"
basically
a
carbon
by­
product
(
petroleum
coke)
containing
absorbed
high
boiling
hydrocarbons,"
such
as
the
PACs.
The
coke
also
accumulates
metals
that
are
present
in
the
crude
oil.
High
grade
petroleum
coke
is
used
to
make
electrodes
for
primary
aluminum
smelting.
Lower
grade
coke
is
burned,
combined
with
coal,
in
power
plants.
Mr.
Reeves
Signature:
mentioned
that
the
coke
is
cut
out
of
the
coke
drum
with
water,
but
that
this
water
is
re­
used
(
closed
water
system).
If
there
are
any
discharged
coking
wastewaters
they
will
likely
contain
relatively
high
amounts
of
PACs
and
potentially
also
crude­
derived
metals,
such
as
nickel,
copper,
iron,
vanadium,
and
selenium.

We
discussed
coke
fines
that
accumulate
on
catalysts.
Mr.
Reeves
explained
that
coke
is
mostly
carbon,
with
very
hydrogen­
deficient
hydrocarbons
(
i.
e.,
PAHs);
however,
there
is
no
direct
way
for
the
coke
fines
on
catalysts
to
enter
the
wastewater
system,
because
the
catalysts
are
never
water­
washed.

Wastewater
pollution
issues.
When
I
asked
what,
in
his
opinion,
were
the
biggest
pollution
problems
associated
with
refinery
wastewaters,
Mr.
Reeves
explained
that
he
had
spent
10
years
in
the
environmental
department
for
a
refinery.
From
his
perspective,
the
biggest
problems
were
upsets
to
the
wastewater
treatment
plant,
from
process
failures,
or
something
getting
into
the
system
that
it
was
not
designed
to
handle.
The
main
tool
for
preventing
these
upsets
is
communication
with
staff.

Mr.
Reeves
went
on
to
stress
the
importance
of
keeping
sludge­
forming
materials
out
of
the
oily
sewer.
Refinery
API
separator
sludge
is
a
listed
hazardous
waste.
At
the
time
Reeves
was
managing
its
disposal,
it
cost
$
1,000/
ton
for
hazardous
waste
incineration.
A
direct
money
saver
was
to
simply
keep
non­
hazardous
materials,
such
as
street
sweepings,
out
of
the
sewer.
Reeves
said
he
knows
of
several
refineries
that
had
invested
in
street
sweepers,
to
keep
operators
from
hosing
dirt
and
sand
from
the
street
into
the
sewer.

Reeves
mentioned
that
he
had
seen
designs
of
new
refinery
units
that
had
maintenance
sewers
hard­
piped
to
oil
product
recovery
systems,
instead
of
the
wastewater
sewer.
The
aim
is
to
keep
high­
oil
wastewaters
out
of
the
wastewater
treatment
system.

Vendors.
Mr.
Reeves
couldn't
name
top
vendors
that
sold
wastewater
treatment
equipment
to
petroleum
refineries.
He
referred
me
to
Andy
Edwards,
ERM
Southwest,
Houston
TX
(
281)
579­
8999
as
a
refinery
wastewater
treatment
expert.

Dioxins.
In
Mr.
Reeves'
experience,
refineries
that
employ
continuous
regeneration
of
reformer
catalyst
don't
have
a
wastewater
discharge
from
the
regeneration
operation,
and
thus
no
dioxin
releases
from
regenerations.
As
described
on
p
53
of
the
Ecology
report,
this
is
because
in
the
continuous
processes
the
regenerator
flue
gas
is
routed
directly
to
the
reformer
heater
firebox,
while
in
the
cyclic
or
semi­
continuous
process
the
chloridecontaining
regeneration
exhaust
gas
is
washed
in
a
caustic
solution
prior
to
venting.
The
report
suggested
that
cyclic
or
semi­
continuous
operations
could
be
retrofitted
to
eliminate
neutralization
and
route
the
exhaust
gases
to
the
firebox.
I
asked
Mr.
Reeves
if
he
knew
of
any
refineries
that
had
done
this.
He
referred
me
to
a
paper
in
the
April
2003
edition
of
Environmental
Progress,
which
he
forwarded
by
e­
mail
(
attached
and
see
file
cruemissions.
pdf).

We
discussed
the
possibility
of
treating
the
reformer
catalyst
regeneration
wastewaters.
I
mentioned
that
the
Ontario,
Canada
MISA
report
had
suggested
using
granulated
activated
carbon
canisters
(
mini­
columns)
to
remove
dioxins.
Mr.
Reeves
agreed
that
the
only
reasonable
location
for
the
treatment
is
at
the
point
of
wastewater
generation.
However,
he
didn't
know
of
any
refinery
that
employed
this
treatment.
He
noted
that
the
cyclic
units
generated
wastewaters
amounting
to
thousands
of
gallons
1
­
2
times
per
year,
and
that
it
would
likely
be
just
as
economical
to
truck
the
wastewater
for
off­
site
treatment
and
disposal
as
to
operate
treatment
and
monitor
its
performance.

Metals.
Some
metals
in
refinery
wastes
are
derived
from
crude:
nickel,
copper,
iron,
vanadium,
selenium,
sometimes
mercury.
Antimony
is
a
catalyst
additive,
used
in
fluid
catalytic
cracking
(
FCC)
units.
FCC
catalyst
accumulates
metals
(
that
is,
metals
are
removed
from
the
oil
during
FCC
and
accumulate
on
the
catalyst).
However,
catalyst
should
not
be
in
the
wastewater.
Spent
FCC
catalyst
is
a
solid
waste,
typically
transferred
to
Signature:
cement
kilns.
Lead
is
not
typically
found
in
crude
oil.
It
was
a
gasoline
additive
until
about
15
years
ago,
and
may
still
be
present
in
tank
bottoms.
Also,
some
paints
used
at
refineries
were
up
to
20
­
30%
lead.
Soils
near
equipment
repeatedly
sand­
blasted
to
remove
paint
can
be
contaminated
with
lead.
Neither
of
these
sources
are
likely
to
contaminate
wastewaters
on
a
regular
basis.

Chromium
is
also
not
found
in
crude
oil.
It
was
used
as
a
cooling
water
biocide
and
has
mostly
been
phased
out.
There
may
still
be
chromium
present
in
old
tanks
and
equipment
and
cooling
tower
basis.

I
asked
Mr.
Reeves
if
metals
would
be
concentrated
in
desalting
wastewaters.
He
had
never
heard
this.[
Note
that
metals
are
not
included
in
the
list
of
desalting
wastewater
pollutants
found
on
page
67
of
the
report.]
Mr.
Reeves
explained
that
desalting
wastewaters
typically
pass
through
a
cyclone
separator
for
oil
removal.
