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MEMORANDUM
TO:
EPA
Docket
OW­
2003­
0074,
Effluent
Guidelines
Program
Plan
for
2004/
2005
FROM:
Betsy
Bicknell,
ERG
DATE:
16
February
2003
SUBJECT:
Meeting
Between
EPA
and
Representatives
of
the
American
Petroleum
Institute
and
National
Petrochemical
and
Refiners
Association
On
Wednesday,
11
February
2004,
representatives
of
the
American
Petroleum
Institute
(
API)
and
National
Petrochemical
and
Refiners
Association
(
NPRA)
met
with
EPA/
EAD
and
their
contractors.

Attendees:

Name
Affiliation
Roger
E.
Claff,
P.
E.
Senior
Environmental
Scientist
Regulatory
and
Scientific
Affairs
American
Petroleum
Institute
Norbert
Dee,
Ph.
D.
Director,
Environment
and
Safety
National
Petrochemical
&
Refiners
Association
Tom
Wall
Chief,
Chemical
Engineering
Branch
EPA,
Office
of
Water
Engineering
and
Analysis
Division
Marvin
Rubin
Chief,
Environmental
Engineering
Branch
EPA,
Office
of
Water
Engineering
and
Analysis
Division
Carey
Johnston
Engineering
and
Analysis
Division
Jan
Matuszko
Engineering
and
Analysis
Division
Deb
Bartram
ERG
(
contractor)

Betsy
Bicknell
ERG
(
contractor)

Arash
Hooshangi
ERG
(
contractor)
Memorandum
16
February
2004
Page
2
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Issues
Discussed
EPA/
EAD
met
with
representatives
of
API
and
NPRA
to
discuss
EPA's
Effluent
Guidelines
Program
Plan
for
2004/
2005.
A
draft
of
this
plan
was
published
in
the
Federal
Register
on
December
31,
2003.
This
meeting
took
place
during
the
comment
period
for
the
draft
plan.
Prior
to
the
meeting,
API
forwarded
a
list
of
questions
they
were
interested
in
discussing
at
the
meeting.
This
list
is
attached.

Mr.
Rubin
reviewed
the
issues
identified
in
EPA's
1996
Petroleum
Refining
Preliminary
Data
Summary,
and
EPA's
decision
not
to
pursue
additional
regulations
for
the
petroleum
refining
industry,
at
that
time.

EAD
explained
the
screening
level
analysis
and
the
calculations
of
toxic
weighted
pounds
of
pollutants
discharged
by
the
petroleum
refining
industry.
ERG
explained
that
work
on
the
detailed
study,
undertaken
after
the
screening
level
review,
included
revising
assumptions
about
the
identity
of
polycyclic
aromatic
compounds
and
dioxin
and
dioxin­
like
compounds
discharged
by
petroleum
refineries.
The
changes
in
these
assumptions
will
result
in
changes
to
the
EAD's
estimates
of
the
toxic
equivalent
pounds
discharged
by
petroleum
refineries.

EAD
emphasized
that
the
petroleum
refinery
study
is
a
work
in
progress.
EAD
intends
to
use
data
from
the
1996
Petroleum
Refining
Preliminary
Data
Summary,
other
studies,
as
well
as
data
submitted
with
comments.

EAD
reiterated
the
requests
for
additional
information
that
were
included
in
the
December
31,
2003
Federal
Register
Notice.
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Meeting
with
API/
NRPA
February
11,
2004
EPA
Headquarters,
Washington,
DC
Questions
from
AP/
NRPA
1.
How
have
the
two
work
plans
changed
since
you
sent
them
to
us?
Where
are
you
in
the
process
and
what
is
the
current
schedule
to
complete
a
draft
of
the
detailed
investigation?
Can
we
walk
through
the
work
plans
and
discuss
each
step.

2.
How
do
you
plan
to
model
the
3­
10
refineries
that
you
mention
in
the
workplan?

3.
In
particular,
was
the
Lyondell­
Citgo
Refining
Company
in
Houston,
Texas
contacted
regarding
PACs?
If
so,
what
were
the
results
of
contact?

4.
What
pollutants
are
you
considering
for
new
or
modified
possible
effluent
guidelines?

5.
How
will
you
establish
the
treatability,
and
treatability
economics,
for
these
pollutants?

6.
At
this
stage,
what
technologies
are
you
considering
to
supplement
the
current
technology
model
for
BAT?
How/
why
did
you
select
these
technologies?
Where
are
they
being
used
today?

7.
To
what
extent
will
existing
water
quality,
or
water
quality
impairments,
be
considered
during
the
detailed
review
(
per
Factor
1
of
the
Strategy)?
How
will
these
factors
be
used
to
define
or
limit
the
scope
of
the
effluent
guidelines?

8.
To
what
extent
will
the
1991­
1996
guideline
review
information
be
examined
during
the
detailed
investigation?

9.
Which
refineries
have
you
contacted,
both
during
the
screening
assessment
for
the
preliminary
plan
and
during
the
detailed
investigation?
What
was
the
outcome
of
your
discussions
with
each
of
them?

10.
During
the
screening
assessment,
how
were
the
weighting
factors
developed
for
dioxins
and
PACs?

11.
For
the
screening
assessment,
what
was
the
dioxin
TRI
loading
used
for
each
refinery?
What
was
the
PAC
loading
for
each
refinery?
How
were
these
numbers
confirmed?

12.
Can
you
confirm
that
88%
of
the
TWPE
is
attributable
to
PACs
and
7%
to
dioxins,
per
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the
docket
report
(
Docket
No.
618,
Table
3.6­
2)?
How
were
these
percentages
derived?
What
is
the
implication
of
this
finding
to
your
detailed
investigation?

13.
What
was
the
technical
basis
or
environmental
concern
behind
the
consideration
of
a
terminals
and
bulk
plants
subcategory?
What
changed
since
August,
when
EAD
told
us
it
was
no
longer
pursuing
terminal/
bulk
plant
effluent
guidelines?

14.
What
is
the
schedule
for
the
"
detailed
investigation"
given
the
30
day
extension
on
comments?

15.
Impact
of
the
extension
on
the
date
for
publishing
the
final
plan?

16.
Is
the
e­
docket
complete?
Does
it
now
include
every
document
in
the
paper
docket?
