1
TELECON
Call
To:
Jim
Nelson,
BP
Oil
Company
­
Toledo
Refinery
Roger
Claff,
American
Petroleum
Institute
(
202­
682­
8399)
Call
From:
Jan
Matuszko,
U.
S.
EPA/
EAD
Jill
Lucy,
ERG,
Inc.
Project:
Office
of
Water's
Engineering
and
Analysis
Division
­
304M
Support:
Detailed
Investigation
of
Petroleum
Refining
(
Charge
#
0172.01.005.062)
Date:
July
26,
2004
Subject:
Dioxin
Discharges
from
BP
Oil
Company's
Toledo
Refinery
Background
For
the
2004/
2005
Plan,
EPA
reviewed
data
from
the
2000
Toxic
Release
Inventory
(
TRI)
program.
The
BP
Toledo
Refinery
in
Oregon,
OH
reported
0.2859
grams
of
dioxin
and
dioxinlike
compounds
discharged
to
surface
water.

In
comments
submitted
by
the
American
Petroleum
Institute
(
API)
(
dated
March
18,
2004)
on
the
Preliminary
Effluent
Guidelines
Program
Plan,
Table
2
states
that
the
BP
Toledo
Refinery
based
the
dioxin
discharges
reported
to
2000
TRI
on
one
set
of
samples
with
nine
congeners
detected.

Call
Summary
Jill
Lucy
(
ERG,
Inc.)
contacted
Roger
Claff
(
API)
to
ask
if
he
could
direct
her
to
a
contact
from
BP
Oil
Company.
EPA
hoped
to
receive
a
copy
of
the
wastewater
analytical
report
showing
the
dioxin
discharges
(
and
which
congeners
were
detected
in
the
final
effluent).
Mr.
Claff
set
up
a
conference
call.
(
See
e­
mail
in
Attachment
1).

Mr.
Claff
asked
Jan
Matuszko
(
EPA)
about
the
Agency's
final
Effluent
Guidelines
Plan
(
in
regards
to
the
petroleum
refining
industry).
Ms.
Matuszko
explained
that
EPA
was
looking
at
actual
measured
data
(
i.
e.,
dioxin
analytical
data)
to
finalize
the
petroleum
refining
industry
review.

Jim
Nelson
(
BP)
offered
to
send
EPA
a
copy
of
the
analytical
report,
performed
in
2000.
Mr.
Nelson
also
provided
general
information
about
the
dioxin
discharges
and
analytical
data.

The
source
of
dioxins
from
the
BP
Toledo
Refinery
is
catalytic
reformer
regeneration.
As
noted
in
some
reports,
there
may
be
dioxin
generation
from
isomerization;
however,
the
refinery
2
sampled
only
the
wastewater
from
catalytic
reformer
regeneration.
The
refinery
operates
two
reformer
units
(
cyclic
process)
with
the
following
regeneration
cycle
times:
1)
36
hours
and
2)
24
hours.
The
wastewater
discharge
from
catalytic
reformer
regeneration
is
continuous,
and
the
flow
rates
are:
1)
100
gallons
per
minute
(
gpm)
and
2)
400
gpm.
The
reformers
operate
essentially
all
year
long
(
i.
e.,
365
days
per
year,
with
occasional
shut­
down
times).

The
analytical
data
available
from
the
site
includes
one
set
of
data
taken
in
2000;
the
refinery
has
not
performed
any
subsequent
analysis.
The
lab
results
note
any
nondetect
dioxin
congeners,
with
their
detection
limit.
The
lab
did
some
revisions
to
EPA
Method
1613b
to
report
concentrations
lower
than
the
standard
method
(
details
in
lab
report).

For
estimates
reported
to
TRI
in
2000,
the
refinery
used
the
average
flow
rate
from
the
wastewater
treatment
plant
(
5,480
gpm)
and
set
lab
results
of
"
nondetect"
equal
to
zero
for
the
dioxin
congener.
For
estimates
reported
to
TRI
in
2001
and
2002,
the
refinery
used
an
average
wastewater
treatment
plan
flow
rate
of
5,520
gpm
and
set
lab
results
of
"
nondetect"
equal
to
onehalf
the
detection
limit
for
the
dioxin
congener.

Mr.
Claff
asked
that
EPA
let
API
know
what
conclusions
EPA
reaches
after
reviewing
the
report.

Ms.
Lucy
also
sent
a
follow­
up
e­
mail
to
Mr.
Nelson
asking
for
some
clarification
of
in­
process
samples.
See
Attachment
2.
3
Attachment
1
From:
Jill
Lucy
To:
nelsonja@
bp.
com,
matuszko.
jan@
epa.
gov,
Claff@
api.
org
Date:
Monday
­
July
26,
2004
7:
46
AM
Subject:
RE:
Question
regarding
comments
on
the
EPA's
Effluent
GuidelinesProgram
Plan
Roger,

Thanks
for
setting
up
the
call.
Jan
Matuszko
from
EPA
will
also
be
joining
the
call.
I
thought
I
would
send
everyone
a
quick
e­
mail
with
a
few
talking
points.
We
are
primarily
interested
in
the
dioxin
discharges
to
wastewater
from
the
BP
Toledo
Refinery
(
2000).

1.
Is
a
copy
of
the
dioxin
analytical
data
available?

2.
How
is
the
annual
mass
of
dioxin
discharged?
(
e.
g.,
For
catalytic
reformer
regeneration:
gallons
per
regeneration
episode,
number
of
episodes
per
year).

3.
What
are
the
sources
of
dioxins
at
the
refinery
(
i.
e.,
other
than
catalytic
reformer
regeneration)?

4.
Catalytic
Reformer
Regeneration:
Confirm
number
&
type
of
units
(
1,
cyclic)

5.
TRI
Reporting.
In
2000,
the
refinery
reported
0.286
grams
of
dioxins
discharged
to
Maumee
Bay.
For
both
2001
and
2002,
the
quantity
reported
was
0.36
grams
of
dioxins.
Is
there
a
particular
reason
for
the
increase
in
dioxin
discharges?

Thank
you
very
much
for
your
time!
Jill
Jill
M.
Lucy
Chemical
Engineer
ERG
www.
erg.
com
jill.
lucy@
erg.
com
>>>
"
Roger
Claff"
<
Claff@
api.
org>
07/
22/
04
2:
40
PM
>>>
Jill
and
Jim,

Let's
hold
a
conference
call
to
discuss
the
BP
Toledo
dioxin
data.
The
call
will
be
Monday
(
7/
26)
at
10
AM
Eastern.
Dial­
in
informantion
is
as
follows:

866­
448­
6756
access
6828399#

Thanks!
I
look
forward
to
hearing
you
on
the
call.

Roger
E.
Claff,
P.
E.
American
Petroleum
Institute
Washington,
DC
20005
(
202)
682­
8399
(
202)
682­
8270
(
FAX)
claff@
api.
org
www.
api.
org
4
­­­­­
Original
Message­­­­­
From:
Jill
Lucy
[
mailto:
Jill.
Lucy@
erg.
com]
Sent:
Wednesday,
July
21,
2004
12:
29
PM
To:
Roger
Claff
Cc:
matuszko.
jan@
epa.
gov;
Johnston.
Carey@
epamail.
epa.
gov;
Betsy
Bicknell;
Deborah
Bartram;
Teresa
Medley
Subject:
Question
regarding
comments
on
the
EPA's
Effluent
GuidelinesProgram
Plan
Dear
Mr.
Claff,

Hello,
my
name
is
Jill
Lucy.
I
work
for
Eastern
Research
Group,
Inc.
*
a
technical
contractor
for
the
U.
S.
EPA's
Office
of
Water
(
under
Contract
No.
68­
C­
02­
095).
Your
March
18,
2004
comments
on
EPA's
Preliminary
Effluent
Guidelines
Program
Plan
in
the
December
31,
2003
FRN
[
FRL­
7604­
7]
included
information
on
TRI
dioxin
loadings
for
petroleum
refineries
(
Table
2).

I
would
like
to
contact
someone
at
the
BP
Toledo
Refinery
for
more
information
on
their
dioxin
discharges
reported
to
TRI
in
2000
(
9
congeners
were
above
the
detection
limit
for
their
monitoring
data).
Specifically,
EPA
wanted
to
receive
a
copy
of
the
dioxin
monitoring
data,
flow
rates
during
sampling,
and
general
catalytic
reformer
regeneration
process
data.

I
was
hoping
you
could
pass
a
long
a
contact
name
and
e­
mail
address
for
the
appropriate
person
at
BP
Toledo.
Please
feel
free
to
contact
the
EPA
project
manager,
Carey
Johnston
(
202­
566­
1014)
if
you
have
any
questions
on
the
Agency's
effluent
guidelines
planning
process.

Your
help
is
greatly
appreciated.
Thank
you.

Jill
M.
Lucy
Chemical
Engineer
ERG
www.
erg.
com
jill.
lucy@
erg.
com
5
Attachment
2
From:
"
Nelson,
James
A"
<
NelsonJA@
BP.
COM>
To:
Jill
Lucy
Date:
Monday
­
August
16,
2004
12:
31
PM
Subject:
RE:
Follow­
up
on
BP
Toledo
Refinery
dioxin
analytical
data
Jill,

Please
excuse
the
slow
response
time
on
your
request.
I
was
attempting
to
get
historic
information
on
the
exact
start
and
stop
points
of
the
various
reformer
catalyst
regeneration
sub­
cycles
that
define
the
sample
names
about
which
you
have
requested
information.
This
is
all
the
information
available
regarding
your
question.

REGEN
H20
BURN
CYCLE
­­
This
sample
name
was
applied
to
a
wastewater
sample
collected
at
the
discharge
from
the
reformer
chloride
scrubber
to
the
process
sewer
during
the
time
when
a
reformer
reactor
was
being
regenerated.
The
burn
cycle
reference
probably
refers
the
period
of
time
when
the
coke
on
the
reactor
catalyst
is
being
burned
off.

TREAT
/
SOAK
­­
This
sample
name
was
applied
to
a
wastewater
sample
collected
at
the
discharge
from
the
reformer
chloride
scrubber
to
the
process
sewer
during
the
time
when
a
reformer
reactor
was
being
regenerated.
The
treat
/
soak
reference
probably
refers
the
period
of
time
when
the
reactor
catalyst
is
being
prepared
for
reuse
by
subjecting
it
to
a
prescribed
mix
of
gases
being
passed
through
the
catalyst
accompanied
by
a
period
of
time
when
a
temperature
program
is
applied.
These
actions
further
prepare
the
catalyst
for
re­
use.

FINAL
­­
This
sample
name
was
applied
to
a
wastewater
sample
collected
at
the
discharge
from
the
reformer
chloride
scrubber
to
the
process
sewer
during
the
time
when
a
reformer
reactor
was
being
regenerated.
The
FINAL
reference
probably
refers
to
a
period
of
time
following
TREAT
/
SOAK
and
before
the
time
when
the
regenerating
reactor
in
question
is
put
back
on
line
and
connected
to
normal
hydrocarbon
feed.

WASTEWATER
TREATMENT
EFFLUENT
­­
This
sample
name
was
applied
to
effluent
from
our
process
wastewater
treatment
system,
not
the
final
discharge
to
the
receiving
water
body.
The
sample
point
would
roughly
correspond
to
our
Outfall
601
location;
however,
the
sample
was
not
collected
at
the
compliance
sampling
point,
but
rather
at
a
point
farther
upstream.
Treated
process
wastewater
(
601
effluent)
then
mixes
with
the
Outfall
602
effluent
(
non­
contact
cooling
water
effluent)
prior
to
becoming
refinery
effluent
(
Outfall
002).
Outfall
002
is
the
final
effluent
discharged
to
the
receiving
water
body.

I
hope
this
information
is
satisfactory
for
your
needs.

...
Jim
Nelson
X­
6339
­­­­­
Original
Message­­­­­
From:
Jill
Lucy
[
mailto:
Jill.
Lucy@
erg.
com]
Sent:
Tuesday,
August
10,
2004
12:
19
PM
To:
Nelson,
James
A
Subject:
Follow­
up
on
BP
Toledo
Refinery
dioxin
analytical
data
6
Dear
Jim,

Thank
you
very
much
for
sending
the
BP
Toledo
Refinery
dioxin
sampling
report.
I
was
hoping
you
could
explain
the
sample
titles
and
how
they
correspond
to
the
catalytic
reformer
regeneration
process
at
the
refinery.
The
sample
titles
include:

REGN
H20
BURN
CYCLE
TREAT/
SOAK
FINAL
(
confirm
discharge
to
refinery
wastewater
treatment
system)

WASTEWATER
TREATMENT
EFFLUENT
(
confirm
final
effluent)

Thank
you
very
much
for
your
time.
Please
feel
free
to
call
or
e­
mail
any
questions.

Jill
Jill
M.
Lucy
Chemical
Engineer
Eastern
Research
Group,
Inc.
www.
erg.
com
jill.
lucy@
erg.
com
