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Project
No.:
0172.01.005.062
DISTRIBUTION
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Project
Name:
Petroleum
Refining
Detailed
Study
TELEPHONE
CALL
RECORD
Outgoing
Call
Date:
10/
22/
2003
Time:
2
PM
Company
Name:
U.
S.
EPA,
Region
6,
Dallas,
TX
Contact
Name:
Scott
Wilson
Phone
No.:
214­
665­
7511
Name:
Betsy
Bicknell
Eastern
Research
Group,
Inc.

GENERAL
SUBJECT
:
Petroleum
Refinery
Wastewater
Issues
TOPICS
DISCUSSED
AND
ACTION
TAKEN
EAD
described
Scott
Wilson,
EPA
Region
6,
as
experienced
in
writing
and
reviewing
NPDES
permits
for
petroleum
refineries.
I
called
Mr.
Wilson
and
discussed
the
following
issues.

Dioxins:
Although
EPA
studied
dioxin
releases
at
refineries
10
years
ago,
Mr.
Wilson
has
never
seen
a
refinery
permit
with
limits
for
dioxins.
He
was
not
aware
of
any
refinery
that
employed
dioxin
control
technology
and
doubted
if
any
refinery
had
in­
process
controls
(
because
they
have
no
permit
limits
for
dioxin).

Polycyclic
Aromatic
Compounds
(
PACs):
Mr.
Wilson
said
that
he
did
not
know
if
states
had
water
quality
standards
for
any
of
the
PACs
­
perhaps
benzo(
a)
pyrene.
Some
refinery
permits
have
some
limits
for
some
PACs.
It
was
Mr.
Wilson's
impression
that
the
current
guidelines
are
so
old
they
did
not
thoroughly
cover
toxic
pollutants.
Mr.
Wilson
noted
that
the
coke
refinery
at
Corpus
Christie,
TX
had
some
toxicity
problems.
He
did
not
know
if
they
were
associated
with
PAC
releases.

Metals.
Mr.
Wilson
noted
that
selenium
presents
a
hazard
to
sheep
and
cattle,
so
selenium
controls
may
be
important
where
wastewater
is
applied
to
grazing
lands.
The
Houston
Ship
Channel
has
a
TMDL
for
nickel,
so
refineries
that
discharge
to
it
would
face
permit
limits
for
nickel.
Mr.
Wilson
wrote
a
permit
for
the
Conoco
refinery
in
Lake
Charles,
LA
that
included
some
metals
limits
(
zinc
and
nickel).
His
recollection
was
that
the
refinery
improved
its
solids
removal
by
adding
flocculant
to
existing
clarifiers
and
was
able
to
meet
the
limits.
Mr.
Wilson
didn't
know
of
any
water
quality
standards
for
vanadium,
but
thought
that
New
Mexico
might
limit
its
release
to
POTWs.

Concerns
with
Existing
Guidelines:
Mr.
Wilson
feels
that
the
limits
in
the
existing
petroleum
refining
effluent
guidelines
are
too
loose.
For
many
refineries,
the
guidelines­
based
permit
limits
are
3
to
4
times
greater
than
the
refineries
actual
discharges.

Stormwater
and
runoff:
One
refinery
tried
to
combine
process
and
stormwarter
for
treatment
and
found
the
treatment
system
overflowed
during
wet
periods.
Mr.
Wilson
felt
that
commingling
un­
contaminated
or
lightly
?
Need
to
return
call
by
/
at/
between
and
.
Signature:
contaminated
stormwater
runoff
with
more
highly
contaminated
process
wastewater
led
to
dilution
and
inefficient
treatment
of
process
wastewater.

Vendors:
Mr.
Wilson
had
no
suggestions
for
wastewater
treatment
equipment
vendors
that
focus
on
the
petroleum
refining
industry.
