Attachment
1
Response
to
Questions
Chevron
Hawaii
Refinery
Polycyclic
Aromatic
Compounds
(
PACs)
Your
company
reported
to
TRI
that
you
released
277
pounds
of
polycyclic
aromatic
compounds
to
surface
water
(
Pacific
Ocean)
in
2002.
Your
company
reported
that
the
basis
of
estimate
for
this
discharge
was
"
measurements".

Could
you
please
explain
how
the
reported
discharge
was
estimated?

We
based
the
Polycyclic
Aromatic
Compounds
(
PACs)
release
to
water
in
the
2002
TRI
report
for
the
Chevron
Hawaii
Refinery
on
the
total
volume
of
water
discharged
and
the
sum
of
all
TRI
reportable
PAC's
sampled
in
2000
for
NPDES
permit
renewal.
All
of
the
PACs
analytical
results
were
non­
detect;
therefore,
we
used
½
the
detection
limit.

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

No.

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?

Not
applicable,
see
response
to
previous
question.

What
was
the
reason
for
the
increase
in
PACs
discharge
from
2000
to
2001,
20
pounds
and
253
pounds,
respectively?

In
2000,
the
TRI
reportable
PACs
were
estimated
based
on
the
assumption
that
they
were
equivalent
to
the
amount
of
naphthalene
in
the
refinery's
effluent
discharge.
The
naphthalene
release
was
estimated
from
½
the
detection
limit
from
the
2000
NPDES
permit
renewal
sampling.
In
2001,
PAC's
were
estimated
by
summing
all
of
the
reportable
PACs
analyzed
in
2000
for
NPDES
permit
renewal.
All
of
the
PACs
were
non­
detect;
therefore,
we
used
½
the
detection
limit
for
the
calculation.
There
were
no
process
changes
in
the
refinery
between
2000
and
2001
that
would
affect
the
actual
release
of
PACs.
