9
June
2005
Ms.
Susan
Bell
Chevron
Corporation
250
Industrial
Road
Pascagoula,
MS
39581
Dear
Ms.
Bell:

Section
304(
b)
of
the
Clean
Water
Act
requires
EPA
to
annually
review
and,
if
appropriate,
revise
its
technology­
based
regulations,
called
"
effluent
limitations
guidelines"
or
"
effluent
guidelines,"
that
limit
the
discharge
of
pollutants
to
waters
of
the
U.
S.
from
various
categories
of
industrial
facilities.
EPA
is
currently
conducting
its
2005
annual
review
of
existing
effluent
guidelines.
EPA
will
discuss
this
review
and
the
results
in
its
Preliminary
2006
Effluent
Guidelines
Program
Plan
scheduled
for
publication
in
the
Federal
Register
in
late
September
or
early
October
of
this
year.

As
part
of
this
annual
review,
EPA
is
evaluating
data
reported
to
TRI
in
2002
by
facilities
with
existing
effluent
guidelines.
In
some
cases,
EPA
is
contacting
facilities
to
better
understand
the
information
in
TRI.
These
contacts
are
being
made
on
behalf
of
EPA
by
Eastern
Research
Group,
Inc.
(
ERG),
which
is
under
contract
with
us
(
Contract
No.
68­
C­
02­
095).

Recently,
ERG
contacted
you
about
your
2002
TRI
reported
discharges.
We
would
like
to
obtain
additional
information
on
the
basis
of
these
reported
discharges.
The
specific
questions
are
attached.
Please
send
your
responses
to:

TJ
Finseth
14555
Avion
Parkway,
Suite
200
Chantilly,
VA
20151
(
703)
633­
1698
Thomas.
Finseth@
erg.
com
Please
contact
me
at
(
202)
566­
1035
or
matuszko.
jan@
epa.
gov
if
you
have
any
questions
about
this
effort.

Sincerely,

Jan
Matuszko
Chemical
Engineer
Engineering
and
Analysis
Division
Office
of
Water
Environmental
Protection
Agency
Attachment
Dioxin
Your
company
reported
to
TRI
that
you
released
0.086
grams
of
dioxin
and
dioxin­
like
compounds
to
surface
water
(
Mississippi
Sound)
in
2002.
Your
company
reported
that
the
basis
of
estimate
for
this
discharge
was
"
other
approaches".

Could
you
please
explain
how
the
reported
discharge
was
estimated?

In
2002,
did
your
company
ever
analyze
any
wastewater
for
the
dioxin
congeners
listed
below,
either
an
in­
plant
stream,
such
as
catalytic
reformer
regeneration,
or
the
final
discharge
to
Mississippi
Sound?

If
so,
were
any
of
the
dioxins
ever
detected?
If
so,
which
congeners?
How
did
your
company
determine
the
wastewater
flow
associated
with
the
dioxin
discharges
in
order
to
calculate
the
reported
grams
discharged?

If
your
company
did
not
collect
any
monitoring
data,
how
was
the
dioxin
distribution
determined?

Polycyclic
Aromatic
Compounds
(
PACs)
Your
company
reported
to
TRI
that
you
released
110
pounds
of
polycyclic
aromatic
compounds
to
surface
water
(
Mississippi
Sound)
in
TRI
in
2002.
Your
company
reported
that
the
basis
of
estimate
for
this
discharge
was
"
other
approaches".

Could
you
please
explain
how
the
reported
discharge
was
estimated?

In
2002,
did
your
company
ever
analyze
any
wastewater
for
any
of
the
polycyclic
aromatic
compounds
listed
below,
either
an
in­
plant
stream,
such
as
catalytic
reformer
regeneration,
or
the
final
discharge
to
Mississippi
Sound?

If
so,
were
any
polycyclic
aromatic
compounds
ever
detected?
If
so,
which
compounds?
How
did
your
company
determine
the
wastewater
flow
associated
with
the
polycyclic
aromatic
compound
discharges
in
order
to
calculate
the
reported
pounds
discharged?

Dioxin
and
Dioxin­
Like
Compounds
CAS
Number
Chemical
Name
Abbreviated
Name
CDDs
1746­
01­
6
2,3,7,8­
tetrachlorodibenzo­
p­
dioxin
2,3,7,8­
TCDD
40321­
76­
4
1,2,3,7,8­
pentachlorodibenzo­
p­
dioxin
1,2,3,7,8­
PeCDD
39227­
28­
6
1,2,3,4,7,8­
hexachlorodibenzo­
p­
dioxin
1,2,3,4,7,8­
HxCDD
57653­
85­
7
1,2,3,6,7,8­
hexachlorodibenzo­
p­
dioxin
1,2,3,6,7,8­
HxCDD
19408­
74­
3
1,2,3,7,8,9­
hexachlorodibenzo­
p­
dioxin
1,2,3,7,8,9­
HxCDD
35822­
46­
9
1,2,3,4,6,7,8­
heptachlorodibenzo­
p­
dioxin
1,2,3,4,6,7,8­
HpCDD
3268­
87­
9
1,2,3,4,6,7,8,9­
octachlorodibenzo­
p­
dioxin
1,2,3,4,6,7,8,9­
OCDD
CDFs
CAS
Number
Chemical
Name
Abbreviated
Name
51207­
31­
9
2,3,7,8­
tetrachlorodibenzofuran
2,3,7,8­
TCDF
57117­
41­
6
1,2,3,7,8­
pentachlorodibenzofuran
1,2,3,7,8­
PeCDF
57117­
31­
4
2,3,4,7,8­
pentachlorodibenzofuran
2,3,4,7,8­
PeCDF
70648­
26­
9
1,2,3,4,7,8­
hexachlorodibenzofuran
1,2,3,4,7,8­
HxCDF
57117­
44­
9
1,2,3,6,7,8­
hexachlorodibenzofuran
1,2,3,6,7,8­
HxCDF
72918­
21­
9
1,2,3,7,8,9­
hexachlorodibenzofuran
1,2,3,7,8,9­
HxCDF
60851­
34­
5
2,3,4,6,7,8­
hexachlorodibenzofuran
2,3,4,6,7,8­
HxCDF
67562­
39­
4
1,2,3,4,6,7,8­
heptachlorodibenzofuran
1,2,3,4,6,7,8­
HpCDF
55673­
89­
7
1,2,3,4,7,8,9­
heptachlorodibenzofuran
1,2,3,4,7,8,9­
HpCDF
39001­
02­
0
1,2,3,4,6,7,8,9­
octachlorodibenzofuran
1,2,3,4,6,7,8,9­
OCDF
Polycyclic
Aromatic
Compounds
PAC
Compound
CAS
Number
Benzo(
a)
anthracene
56­
55­
3
Benzo(
a)
phenanthrene
(
chrysene)
218­
01­
9
Benzo(
a)
pyrene
50­
32­
8
Benzo(
b)
fluoranthene
205­
99­
2
Benzo(
j)
fluoranthene
205­
82­
3
Benzo(
k)
fluoranthene
207­
08­
9
Benzo(
j,
k)
fluorene
(
fluoranthene)
206­
44­
0
Benzo(
r,
s,
t)
pentaphene
189­
55­
9
Dibenz(
a,
h)
acridine
226­
36­
8
Dibenz(
a,
j)
acridine
224­
42­
0
Dibenzo(
a,
h)
anthracene
53­
70­
3
Dibenzo(
a,
e)
fluoranthene
5385­
75­
1
Dibenzo(
a,
e)
pyrene
192­
65­
4
Dibenzo(
a,
h)
pyrene
189­
64­
0
Dibenzo(
a,
l)
pyrene
191­
30­
0
7H­
Dibenzo(
e,
g)
carbazole
194­
59­
2
7,12­
Dimethylbenz(
a)
anthracene
57­
97­
6
Indeno(
1,2,3­
cd)
pyrene
193­
39­
5
3­
Methylcholanthrene
56­
49­
5
5­
Methylchrysene
3697­
24­
3
1­
Nitropyrene
5522­
43­
0
