STATE OF WASHINGTON 

DEPARTMENT OF ECOLOGY 

PO Box 47600 • Olympia, WA 98504-7600 • 360-407-6000 

711 for Washington Relay Service o Persons with a speech flisability can ca/1877-833~6341 

September 26,2014 

Mr. Neil Norcross 

Tesoro Nmthwest Company 

POBox 700 

Anacortes, Washington 98221 

Re: Class 2 Water Quality Inspection, June 3-4, 2014 

Dear Mr. Norcross: 

Enclosed is a copy of the repott for the above referenced inspection. No problems were noted 

during the inspection. 

If you have any questions, please contact me at (360) 407-6937 or Mark.Dirkx@ecy.wa.gov. 

Sincerely, 

Oc~~---~ , L? r:-· I 

J. Mark Dirkx, P.E. 

Industrial Section 

Waste 2 Resources Program 

Enclosures 
INDUSTRIAL SECTION 

Tesoro Class II Inspection 

Name & Address of Entity: Tesoro Refining & Marketing Company 

Post Office Box 700 

NPDES Permit Number: 

Date ofinspection: 

Type of Inspection: 

Inspection Personnel: 

Date of Report: 

Report By: 

Anacortes, Washington 98221 

WA 000076-1 

June 3 and 4, 2014 

Class II Wastewater Inspection, unannounced 

Mark Dirkx, Ecology 

Neil Norcross, Tesoro 

September 26f~) 

J.MarkDir~ 

On June 3 and 4, 2014 I conducted a water quality sampling inspection of the Tesoro 

refinery at Anacortes. I arrived at the facility at approximately 12:30 on June 3 and met 

with Neil Norcross. This was an unannounced inspection and we set the agenda for it. On 

June 3, I inspected the wastewater treatment system. On June 4, I collected samples and 

reviewed the laboratory procedures. 

Description of Facility: 

Process water is treated in primary and secondary systems consisting of an API oil/water 

separator, neutralization pit, primary clarifiers, bioreactor, secondary clarifiers, and 

settling ponds. They also have a pond to collect stormwater and have the capability of 

skimming oil from the top. The storm water can be sent through treatment, if needed. 

Jnne 3, 2014 

Site Inspection: 

We checked in with the wastewater treatment operator. Operators work 12-hour shifts, 

pulling samples every two hours to check how well treatment is going. They can respond 

quickly when something does not look good. 

We walked through the treatment plant sequentially, starting with the APis. The two APis 

are covered to contain benzene vapors. Skimmers collect the oil off the top while a rake 

automatically collects sludge. API sludge is discharged to a covered thickener unit. The 

air emissions from these units are scrubbed with a water scrubber then discharged to a 

carbon scrubber. Water is used as a seal on the API covers. 
Tesoro Class 2 Inspection Report Page2 of4 

At the end of the APis is the neutralization pit. Sanitary wastewater is collected from the 

refinery and treated in a septic tank. The effluent from the septic tank is discharged into 

the neutralization pit where spent process acid is added. The pH of the spent acid ranges 

from 2 to 4. The spent acid is added once or twice a day in a batch process which keeps 

the neutralization pit at a low enough pH to effectively kill the microorganisms in the 

septic tank effluent. A local septic hauler periodically pumps septic tank solids, which 

are then treated at a local publicly owned treatment facility. 

The contents of the neutralization pit are continuously pumped to the head ofthe 

industrial wastewater treatment system where they neutralize the process wastewater 

influent, which ranges from pH 10 -12. The neutralizion pit effluent is added to the end 

of the API separators (the after bay). The pH of the wastewater is monitored downstream 

of the neutralization pit addition in the after bay of the API separator. 

The next units in the treatment system are two primary clarifiers. These units have 

aluminum covers with a water seal. They discharge solids into a sludge reservoir. The 

solids from the reservoir are discharged to the thickener unit. The air emissions from the 

primary clarifiers are scrubbed with a carbon and water scrubber. The capacity of the 

thickener unit is approximately 1500 barrels. 

Sludge from the sludge thickener unit is periodically withdrawn, dewatered and sent offsite as hazardous waste. If supernatant is generated from the dewatering process, it is 

discharged to the beginning of the wastewater treatment process. The thickener sludge 

(API sludge) is regulated by dangerous waste rules. 

Activated sludge basins comprise the secondary treatment system. The basins are 

operated in series. Since a buildup of foam sometimes flows over the side and onto the 

ground, Tesoro has installed a foam gate/corral to keep it within the basins. The basins 

have DO probes, which automatically adjust the blowers to provide adequate aeration. 

Aeration basin effluent is discharged into two secondary clarifiers. The incoming treated 

wastewater looked clean. 

The wastewater is pumped from the secondary clarifiers into the west pond for settling 

and then into the east pond when the pumpout lowers its level. The final effluent from the 

holding ponds is pumped through an outfall line at the refinery's dock. The effluent is 

pumped out in batches. The length of time Tesoro pumps depends upon the level of the 

ponds. During wet weather, effluent is pumped over a longer period in order to discharge 

the extra volume of storm water. The two ponds are cleaned about every four years. 

This is done by charting the depths in the ponds and then vacuuming the areas with a lot 

of build up of silt. 

A diversion tank is used to store diverted off-spec final effluent or diversions from units 

down for maintenance. The stored wastewater can then be slowly bled into the 

wastewater system for additional treatment in order to meet permit limits. 
Tesoro Class 2 Inspection Report Page 3 of4 

A belt filter press with polymer addition thickens secondary sludge. The solids are 

approximately 10% after processing. The sludge is land applied to the biosludge 

landfann facilities (bug farms). The Skagit County Health Department regulates the 

biosludge landfann facility. 

We checked back into the control room of the wastewater treatment plant. They have 

manuals for the wastewater treatment system equipment available in the control room for 

easy reference. To make the transition easier between shifts, a bound log is maintained 

for operator comments on the system. This allows tracking of trends and problems. 

I departed the facility at approximately 14:15. 

June 4, 2014 

I checked in with the guard at approximately 11:05 and received a badge to pass onto 

refinery property. 

Tesoro is accredited for the following parameters: ammonia, BOD, COD, Total residual 

chlorine, dissolved oxygen, hexane extractable O&G, pH, total phenolics, TSS, sulfide, 

and fecal coliform. 

Raw data for NPDES parameters are entered into a logbook. The lab has two logbooks 

for NPDES parameters. One logbook is in the biological area and covers BOD and fecal 

coliform testing. The other logbook is in the chemical testing area. The logbooks are 

bound and a stamp has been specifically designed with the necessary information for 

each parameter. The pages are stamped for each parameter and the required information 

is directly filled into the logbook. The lab results are entered into the computer system, 

WINBLISS, to provide information to the operators and environmental personnel. They 

periodically check the logbooks to ensure completeness and quality work. The logbooks 

are filled in completely with ink. Control charting is done, but no duplicates are run. 

Tesoro employs a good chain of custody. The samples are tagged when collected with 

pH, flow temperature, pumping time and the amount pumped all logged onto the tag and 

signed by the collector. 

Tesoro discharges its wastewater by the batch during late morning and early afternoon. A 

grab sample is collected early in the morning and analyzed. If there is a problem, treated 

wastewater is not pumped to the bay. Discharge pumping takes place after the test results 

have been examined for that batch of process water. Required composite and grab 

samples are taken during the discharge. 
Tesoro Class 2 Inspection Report Page4 of 4 

I split a Tesoro's composite sample. The tag displayed the temperature and pH 

instrument readings at the time of the pickup. 

We proceeded to Tesoro's outfall where I collected grab samples of effluent. Tesoro has 

a small pump that runs continuously pulling water from the final holding pond and 

allowing it to run back into the pond. 

I collected grab samples at 11:45. Tesoro chose not to split grab samples. 

I conducted an exit interview but had not observed anything during the inspection that 

needed to be addressed. 

Sampling Results: 

The attached table shows the results of the samples analyzed by Ecology and Tesoro. 

Samples were analyzed for all of the parameters in the NPDES permit and priority 

pollutant metals. All permit parameters met limits. 

Metals data are comparable with previously reported data. 

Conclusions: 

With Tesoro's chronic dilution factor, all priority pollutant metal results are below water 

quality criteria. 

The wastewater treatment system appeared to be functioning properly and Tesoro was in 

compliance with their NPDES permit on the day of the inspection. 
Tesoro 

Class 2 Inspection 

*Values are below WQ criteria levels when chronic dilution factor is applied. 

U The analyte was not detected at or above the reported result 

NA The sample was not analyzed for parameter 
oEPA 

United States Environmental Protection Agency Form Approved Washington, DC 20460 OMB No. 2040-0057 

Water Compliance Inspection Report Approval Expires 10-31-95 

Section A: National Data System Coding (i.e., PCS) 

Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type 

,,~, 2jQj aiWIAIOIOIOIOI71611111 12j1j41Qj6j0j4j17 1ajl! 19jSj 2oj2j 

Remarks 

211Jli!:::!181~1~1QI!li!:::!IQI!;_IQLIQI!,I81l21l2LI6LLLLLLLLLLLLLLLLLLLLLLLLLLLI66 

Inspection Work Days Facility Self~Monitoring Evaluation Rating 81 QA --------------------Reserved---------------------

•'111ZIQI•• 7oj4j ,,INI niNI 73j_IJ74 7siJ_LLLLLiao 

Section B: Facility Data 

Name and Location of Facility Inspected (For industrial users discharging to POTw, a/so Entry Time/Date Permit EffeCtive Date 

include POTW name and NPDES pennn number) 6/3/14, 12:30 5/1/2006 

6/4/14, 11:05 

Tesoro Refining & Marketing Company Exit Time/Date Permit Expiration Date 

PO Box700 6/3/14, 14:15 5/1/2011 

Anacortes WA 98221 6/4/14, 11:45 

Name(s) of On-Site Representative(s)!Tille(s)/Phone and Fax Number(s) Other Facility Data 

Neil Norcross, EHS Staff 

(360) 293-9177 

Name, Address of Responsible OfficiaVTitle/Phone and Fax Number. 

Dave Cameron, Vice President, Refining 

(360) 293-9119 

Contacted 

DYes cgj No 

Section C: Areas Evaluated During Inspection (Check only those areas evaluated) 

IZ'l_Permit 18J.Fiow Measurement 18J.operations & Maintenance Ocso/SSO (Sewer Overflow) 

18J.Records/Reports 18J.seJfwMonitoring Program JZlsludge Handling/Disposal 0Pollution Prevention 

£8l.Facility Site Review Ocompliance Schedules 0Pretreatment 0Multimedia 

[8lEffluenUReceiving Waters l:8J.Laboratory Ostonn Water Oother: 

Section D: Summary of Findings/Comments (Attach additional sheets of narrative and checklists as necessary) 

See attached report. 

Name(s) and Signature(s) of lnspector(s) Agency/Office/Phone and Fax Numbers Date 

f ~~·. I 

J. Mark Dirkx '\. .. ·- ----~·-·-"' ;) WA Dept. of Ecology (360) 407-6937 9 /zc,/J?-' 

f f / 

Sign~ ,'J(e~MW,e!"ent fl~~view r Ar~cy;f~ce/Phone:~ FSx Nu::r,~rs Dat~ 1

. ·~! '-" & to oq V X e oh 10 /~ EPA Form 3560-3,ReL 9f~4) Previou editions are obsolete .. J I ( ~(,o) lfq-6n r 
Sections F thru L: Complete on all inspections, as appropriate. N/A = Not Applicable I PERMIT NO. 

WA000076-1 

SECTION F- Facility and Permit Background 

ADDRESS OF PERMITTEE IF DIFFERENT FROM FACILITY DATE OF lAST PREVIOUS INVESTIGATION BY EPNSTATE 

(Including City, County and ZIP code) June 2013 

FINDINGS 

In compliance 

SECTION G- Records and Reports 

RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT. C8:]YES 0No 0 N/A (Further explanation affached ___) 

DETAILS: 

(a) ADEQUATE RECORDS MAINTAINED OF: 

(i) SAMPLING DATE, TIME, EXACT LOCATION [gj YES 0No ON/A 

(ii) ANALYSES DATES, TIMES . [gj YES 0No ON/A 

(iii) INDIVIDUAL PERFORMING ANALYSIS [gj YES 0No ON/A 

(iv) ANALYTICAL METHODS/TECHNIQUES USED [gj YES 0No ON/A 

(v) ANALYTICAL RESULTS (e.g., consistent with self-monitoring report data) [gj YES 0No ON/A 

(b) MONITORING RECORDS (e.g., flow, pH, D.O., etc.) MAINTAINED FORA MINIMUM OF THREE YEARS 

INCLUDING ALL ORIGINAL STRIP CHART RECORDINGS (e.g., continuous monitoring instrumentation, 

[gj YES 0No ON/A 

calibration and maintenance records). 

(c) lAB EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT. [gj YES 0No ON/A 

(d) FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT 

UNIT. 

[gj YES 0No ON/A 

(e) QUALITY ASSURANCE RECORDS KEPT. [gj YES 0No ON/A 

(f) RECORDS MAINTAINED OF MAJOR CONTRIBUTING INDUSTRIES (and their compliance status) DYES 0No [gj N/A 

USING PUBLICLY OWNED TREATMENT WORKS. 

SECTION H -Permit Verification 

INSPECTION OBSERVATIONS VERIFY THE PERMIT. [8JYES ONO ON/A (Further explanation affached J 

DETAILS: 

(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE. [gj YES 0No ON/A 

(b) FACILITY IS AS DESCRIBED IN PERMIT. [gj YES 0No ON/A 

(c) PRINCIPAL PRODUCT(S) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN 

PERMIT APPLICATION. 

[gj YES 0No ON/A 

(d) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION. [gj YES 0No ON/A 

(e) NOTIFICATION GIVEN TO EPNSTATE OF NEW, DIFFERENT OR INCREASED DISCHARGES. [gj YES 0No ON/A 

(f) ACCURATE RECORDS OF RAW WATER VOLUME MAINTAINED. [gj YES 0No ON/A 

(g) NUMBER AND LOCATION OF DISCHARGE POINTS ARE AS DESCRIBED IN PERMIT. [gj YES 0No ON/A 

(h) CORRECT NAME AND LOCATION OF RECEIVING WATERS. [gj YES 0No ON/A 

(i) ALL DISCHARGES ARE PERMITTED. [gj YES 0No ON/A 

SECTION I -Operation and Maintenance 

TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED. [8J YES ONO 0 N/A (Further explanation affached 

DETAILS: 

(a) STANDBY POWER OR OTHER EQUIVALENT PROVISIONS PROVIDED. [gj YES 0No ON/A 

(b) ADEQUATE AlARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE. [gj YES 0No ON/A 

(c) REPORTS ON ALTERNATIVES SOURCE OF POWER SENT TO EPNSTATE AS REQUIRED BY [gj YES 0No ON/A 

PERMIT. 

(d) SLUDGES AND SOLIDS ADEQUATELY DISPOSED. [gj YES 0No ON/A 

(e) ALL TREATMENT UNITS IN SERVICE. [gj YES 0No ON/A 

(f) CONSULTING ENGINEER RETAINED OR AVAILABLE FOR CONSULTATION ON OPERATION AND 

MAINTENANCE PROBLEMS. 

[gj YES 0No ON/A 

(g) QUALIFIED OPERATING STAFF PROVIDED. [gj YES 0No ON/A 

(h) ESTABLISHED PROCEDURES AVAILABLE FOR TRAINING NEW OPERATORS. [gj YES 0No ON/A 

(i) FILES MAINTAINED ON SPARE PARTS INVENTORY, MAJOR EQUIPMENT SPECIFICATIONS, AND 

PARTS AND EQUIPMENT SUPPLIERS. 

[gj YES 0No ON/A 

fj) INSTRUCTIONS FILES KEPT FOR OPERATION AND MAINTENANCE OF EACH ITEM OF MAJOR 

EQUIPMENT. 

· [gj YES 0No ON/A 

(k) OPERATION AND MAINTENANCE MANUAL MAINTAINED. [gj YES 0No ON/A 

(I) SPCC PlAN AVAILABLE. [gj YES 0No ON/A 

(m) REGULATORY AGENCY NOTIFIED OF BY PASSING. (Dates l DYES 0No ,[gj N/A 

(n) ANY BY-PASSING SINCE lAST INSPECTION. DYES [gj NO ON/A 

(o) ANY HYDRAULIC AND/OR ORGANIC OVERLOADS EXPERIENCED. DYES [gj NO ON/A 

EPA FORM 3560-3 (9-77) PAGE20F 4 
: ............. '?!;:--, i·{~ i ............... -...... ,; ) .... ·····•······························ .···. =7 I PERMIT NO. : ..... . • .,· .. ·•····.•··•·•·······.· .. ·.· .. ·. WA 000076-1 

SECTION J -Compliance Schedules 

PERMITTEE IS MEETING COMPLIANCE SCHEDULE. DYES 0NO [8J N/A (Furlher explanation attached 

CHECK APPROPRIATE PHASE(S): 

0 (a) THE PERMITTEE HAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE AUTHORITIES TO BEGIN 

CONSTRUCTION. 

D (bJ PROPER ARRANGEMENT HAS BEEN MADE FOR FINANCING (morlgage commitments, grants, etc.). 

0 (c) CONTRACTS FOR ENGINEERING SERVICES HAVE BEEN EXECUTED. 

D (dJ DESIGN PLANS AND SPECIFICATIONS HAVE BEEN COMPLETED. 

0 (e) CONSTRUCTION HAS COMMENCED. 

o <n CONSTRUCTION AND/OR EQUIPMENT ACQUISITION IS ON SCHEDULE. 

D (g) CONSTRUCTION HAS BEEN COMPLETED. 

D (hJ START-UP HAS COMMENCED. 

D (i) THE PERMITTEE HAS REQUESTED AN EXTENSION OF TIME. 

SECTION K- Self-Monitoring Program 

Part 1 -Flow measurement (Further explanation attached 

PERMITTEE FLOW MEASUREMENT MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. 12] YES 0No ON/A 

DETAILS: 

(a) PRIMARY MEASURING DEVICE PROPERLY INSTALLED. 12] YES 0No ON/A 

TYPE OF DEVICE: 0 WEIR 0 PARSHALL FLUME 0MAGMETER 0VENTURI METER [8JOTHER: (Specify) 

(b) CALIBRATION FREQUENCY ADEQUATE. (Date of last calibration) 12] YES 0No ON/A 

(c) PRIMARY FLOW MEASURING DEVICE PROPERLY OPERATED AND MAINTAINED. 12] YES 0NO ON/A 

(d) SECONDARY INSTRUMENTS (totalizers, recorders, etc.) PROPERLY OPERATED AND MAINTAINED. 12] YES 0NO ON/A 

(e) FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW 12] YES 0No ON/A 

RATES. 

Part 2- Sampling (Furlher explanation attached ) 

PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. 12] YES 0No ON/A 

DETAILS: 

(a) LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES. 12] YES 0No ON/A 

(b) PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT. 12] YES 0NO ON/A 

(c) PERMITTEE IS USING METHOD OF SAMPLE COLLECTION REQUIRED BY PERMIT. 12] YES 0NO ON/A 

IF NO, 0GRAB 0MANUAL COMPOSITE OAUTOMATIC COMPOSITE FREQUENCY 

(d) SAMPLE COLLECTION PROCEDURES ARE ADEQUATE 12] YES 0No ON/A 

(i) SAMPLES REFRIGERATED DURING COMPOSITING 12] YES 0NO ON/A 

(ii) PROPER PRESERVATION TECHNIQUES USED 12] YES 0No ON/A 

(iii) FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED BY PERMIT 12] YES 0No ON/A 

(iv) SAMPLE HOLDING TIMES PRIOR TO ANALYSES IN CONFORMANCE WITH 40 CFR 136.3 12] YES 0No ON/A 

(e) MONITORING AND ANALYSES BEING PERFORMED MORE FREQUENTLY THAN REQUIRED BY DYES 12] NO ON/A 

PERMIT. 

<n IF (e) IF YES, RESULTS ARE REPORTED IN PERMITTEE'S SELF-MONITORING REPORT. DYES 0No 12] N/A 

Part 3- Laboratory (Further explanation attached ) 

PERMITTEE LABORATORY PROCEDURES MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. 12] YES 0No ON/A 

DETAILS: 

(a) EPA APPROVED ANALYTICAL TESTING PROCEDURES USED. (40 CFR 136.6) 12] YES 0No ON/A 

(b) IF ALTERNATE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN 12] YES 0No ON/A 

OBTAINED. 

(c) PARAMETERS OTHER THAN THOSE REQUIRED BY THE PERMIT ARE ANALYZED. DYES 12] NO ON/A 

(d) SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT. 12] YES 0No ON/A 

(e) QUALITY CONTROL PROCEDURES USED. 12] YES 0No ON/A 

<n DUPLICATE SAMPLES ARE ANALYZED. %OF TIME 12] YES 0No ON/A 

(g) SPIKED SAMPLES ARE USED. %OF TIME 12] YES 0No ON/A 

(h) COMMERCIAL LABORATORY USED. 12] YES 0NO ON/A 

(i) COMMERCIAL LABORATORY STATE CERTIFIED. 12] YES 0No ON/A 

LAB NAME Edge Analytical in Burlington for chemistry and BC Research in Vancouver, BC, for bioassays. 

LAB ADDRESS 

EPA FORM 3560-3 (9-77) PAGE 30F 4 
Form Approved 

OMB No 158-R0073 

~ ( ici~. ii ;:;;;;T']' ~ PcHMifNO. '[. )f•:··,_ •··_. )c' . ;• •-/ >.-.••.•••••. (}•.•••··.············1 WA 000076-1 

:St:<; II UN l I JWater uuse• v•uu• •• 1r"'"'"' 

OUTFALL NO.' -OILSfiEEi'.f Tl IY oFOAM I OTHER 

FLOAT SOL 

001 no no no no no 

oo2 no 

003 no 

I 

004 no 

; M and N: 'as l!Of i 

SECTION M -Sampling Inspection ~r· ; and uuserv•uuus (Furlhe;, ) 

-~-GRAB I 

COMPOSITE OBTAINED 

1:81 FLOW PROPORTIONED SAMPLE 

1:81 AUTOMATIC SAMPLER USED 

0 SAMPLE SPLIT WITH PERMITTEE 

1:81 CHAIN OF CUSTODY EMPLOYED 

1:81 SAMPLE OBTAINED FROM FACILITY SAMPLING DEVICE 

COMPOSITING FREQUENCY 1/15min PRESERVATION 4deg C 

SAMPLE REFRIGERATED DURING COMPOSITING: 1:81 YES ONO 

SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE YES 

""" nurl'N ~ 

See attached report. 

EPA FORM 3560-3 19-77) PAGE 4 OF 4