Signature:
Project
No.:
0172.01.005.062
DISTRIBUTION
Page
__
1_
of
_
2
Project
Name:
Petroleum
Refining
Detailed
Study
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
10/
22/
2003
Time:
11:
00
Am
Company
Name:
Amendola
Eng.
Contact
Name:
Gary
Amendola
Phone
No.:
(
440)
808­
6960
Name:
Betsy
Bicknell
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
Petroleum
Refining
Wastewater
Issues
TOPICS
DISCUSSED
AND
ACTION
TAKEN
Because
Gary
Amendola
worked
on
refinery
dioxin
issues
with
EPA
in
the
1990s,
I
called
him
to
discuss
the
issues
related
to
refinery
toxic
discharges
we
had
identified
in
the
analysis
of
TRI
release
data.

Dioxins.
Mr.
Amendola
described
how
dioxins
are
generated
from
regeneration
of
catalyst
used
in
naphtha
reformers.
He
explained
that
there
are
three
types
of
catalyst
regeneration:
1.
Semi
regenerative
­
discharges
1500
gal/
yr
in
1
­
2,
batches/
year.
2.
Cyclic
regeneration
­
refinery
has
5
or
so
units,
with
one
taken
down
for
regeneration
at
a
time.
Discharges
approx.
8
million
gallons/
year.
3.
Continuous
regeneration
­
catalyst
operated
in
a
fluid
bed
state,
with
a
slip
stream
taken
of
continuously
for
regeneration.

Regeneration
includes
several
steps:
­
evacuate
catalyst
unit;
­
burn
off
accumulated
coke
;
­
apply
regenerant,
one
of
several
chlorinated
compounds,
such
as
carbon
tetrachloride,
hydrochloric
acid,
chlorine
gas,
trichloroethane,
dichloropropane,
to
"
reactivate"
the
catalyst;
­
carry
out
a
final
oxidative
stage.

Off
gases
from
the
regeneration
process
pass
through
a
caustic
scrubber.
Scrubber
wastewaters
capture
dioxins
are
other
bi­
products
of
the
regeneration
process.
Mr.
Amendola
indicated
that
there
may
be
washing
steps,
with
water
and
caustic,
between
the
regeneration
stages.

Because
dioxins
are
hydrophobic,
Mr.
Amendola
indicated
that
they
were
attached
to
small
(<
5
micron)
particulate
matter.
A
possible
treatment
approach
is
to
pass
the
regenerate
wastewater
through
a
filter
sock
and
through
granulated
activated
carbon
canisters.
Mr.
Amendola
thought
that
this
treatment
may
have
been
practiced
by
a
Chevron­
Texaco
refinery
in
California
and
a
Valero
refinery.
Spent
filter
material
would
need
to
be
disposed
of
as
a
dioxin­
contaminated
hazardous
waste.
Signature:
Amendola
thought
that
any
producer
of
higher
octane
gasoline
would
have
a
naphtha
reformer.
Those
with
cyclic
or
semi­
regenerative
process
would
generate
dioxin­
contaminated
wastewaters.
Possibly,
dioxins
would
be
present
only
below
analytical
detection
limits
or
TRI­
reporting
thresholds
at
facilities
with
lower
flow
volumes.

Polycyclic
Aromatic
Compounds
(
PACs).
Mr.
Amendola
explained
that
typical
refinery
wastewater
treatment
includes
in­
process
steam
strippers
to
remove
sulfide
and
ammonia
from
sour
water
and
oil
separation
on
oily
wastewaters.
End­
of­
pipe
treatment
of
combined
wastewaters
is
biological
treatment.
Most
refineries
have
aerated
basins,
while
some
have
activated
sludge
carried
out
in
tanks.
Many
refineries
follow
biological
treatment
with
sand
filters
for
extra
solids
removal,
followed
by
activated
carbon
adsorption
columns.
Amendola
thought
that
refineries
with
good
solids
removal
would
be
unlikely
to
detect
PACs
in
their
final
effluent.
This
suggests
that
refineries
that
discharge
to
POTWs
may
have
higher
levels
of
PACs,
because
they
have
less
effective
solids
removal.

Metals.
Of
the
metals
with
high
toxic­
weighted
reported
discharges
(
selenium,
mercury,
and
vanadium),
Mr.
Amendola
had
a
passing
familiarity
with
selenium
issues
at
refineries.
His
recollection
was
that
selenium
was
difficult
to
treat
(
it
is
doesn't
precipitate
with
lime).

General
Issues.
Mr.
Amendola
thought
there
may
be
some
housekeeping
issues
at
some
refineries.
At
many
refineries,
all
process
areas
are
covered
with
concrete,
to
effect
a
good
separation
between
process
area
(
contaminated)
stormwater
and
stormwater
from
undeveloped
areas
of
the
refinery
site.
He
recalled
that
Chevron­
Texaco
in
Los
Angeles
had
a
separate
stormwater
collection
system.
This
collected
stormwater
is
stored
in
two
14
million
gallon
tanks
and
treated
by
induced
air
flotation.

NPDES
Permits
for
Contaminated
Groundwater
Discharges.
More
and
more
refineries
are
treating
contaminated
groundwater
recovered
from
the
refinery
site.
Limits
for
the
discharge
of
this
treated
groundwater
are
included
in
the
same
NPDES
permit
as
process
wastewater.
Permit
writers
have
stretched
the
existing
effluent
guidelines
to
develop
limits,
for
example,
by
converting
the
groundwater
flows
to
"
equivalent
barrels
of
crude
oil,"
and
then
applying
the
per
barrel
limitations
guidelines
to
calculate
the
pounds
of
pollutant/
day
discharge
limits.

References:
Mr.
Amendola
offered
to
provide
some
background
references
on
wastewater
issues
at
petroleum
refineries,
including
the
1991
MISA
BAT
report
prepared
for
the
Ontario,
Canada
Ministry
of
Environment.

TRI
Dioxin
Issues.
Mr.
Amendola
has
been
working
with
the
2000
and
2001
TRI
dioxin
release
data.
He
mentioned
that
facilities
estimate
their
releases
using
whatever
tools
they
have
available
­
monitoring
results,
sitespecific
emission
factors,
category
emission
factors,
etc.
For
example,
Dow
Chemical
(
a
major
dioxin
discharger)
monitors
its
wastestreams
and
analyzes
dioxin
content
in
its
own
labs.
In
1995
Dow
committed
to
a
90
percent
reduction
in
corporate
dioxin
releases
by
2005,
and
they
are
progressing
towards
this
goal.
Mr.
Amendola
also
noted
that
members
of
the
Chlorine
Chemistry
Council
(
CCC)
are
concerned
about
the
way
they
are
required
to
report
to
TRI
the
distribution
of
the
17
dioxin
and
dioxin­
like
compounds.
TRI
asks
for
one
distribution
per
facility
or
for
the
facility's
one
best
media­
specific
distribution.
Where
distributions
vary
significantly
between
release
media,
CCC
members
are
concerned
that
this
can
mis­
characterize
their
releases.
Dow
and
other
CCC
members
have
been
providing
media­
specific
calculated
2,3,7,8­
TCDD
toxic­
equivalents
to
Dwain
Winters,
of
EPA's
National
Program
Chemical
Division,
Office
of
Pollution
Prevention
and
Toxics
(
202.566.1977).
The
reported
TEQ
are
found
on
a
Chlorine
Chemistry
Council
website:
http://
www.
c3.
org/
sitedata/
test3/
dir.
html
(
note
EPA's
TRI
website
links
to
this
site
through
the
2000
TRI
data
release
site
page).
