Need to return call by / at/between and

. Signature: Project No.: 

### 0 317.0 2 .005.510 Page 1 of 4

Project Name: 

### DMR20 1 3 

## CBI?

Yes

No TELEPHONE CALL RECOR D

Incoming

Outgoing Date: 

### 12/22 /1 4 Time: 

### 2 :3 0 am

pm

Company Name: 

### Valero Refining Co. ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Steve Brewer Contact Phone Number: 

### ( 901)

- 947

- 8360

General Subject: 

### 2013 TRI Hydrogen Sulfide Discharges for Valero Refining in Memphis, TN



## TOPICS DISCUSSED AND ACTION TAKEN

Steve Brewer: 901

- 947

- 8360, steve.brewer@valero.com

I called Mr. Brewer on 12/22 and left a message. He returned my call and left a message requesting that I send

an email with our questions. I sent Mr. Brewer an email on 12/23 and followed up with a call. I spoke with him

and he stated that the facility discharges to a POTW; they do not have a NPDES permit. He said that som eone

will get back to be the week of Jan 5 th 

### . Please see attached email communication.Need to return call by / at/between and

. Signature: 

### Email Communication with Valero Refining in Memphis, TN:

To: cletea.scott

- woodfork@valero.com

From: Kimberly Bartell

CC: Steve Brewer

Date: Friday 1/9/15, 12:46PM

Subject: RE: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Cletea,

Thank you for providing the information below, we will review it and let you know if we have any further questions.

Kimberly

-------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

To: Kimberly.bartell@erg.com

From: Celtea Scott

- Woodfork (cletea.scott

- woodfork@valero.com)

CC: Steve Brewer

Date: Thursday 1/8/15, 9:52AM

Subject: RE: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Ms. Bartell,

Outlined below and attached is follow

- up information, as requested. If yo u have additional questions, please contact me by e

- mail or

phone at (901) 775

- 7296 or Steve Brewer at (901) 947

- 8360.

Regards,

Cletea Scott

- Woodfork

Sr. Environmental Engineer

Valero Refining Company

- Tennessee, L.L.C.

901.775

- 7296 (office)

901.775

- 8862 (fax)

From: Kimberly Bartell [ mailto:Kimberly.Bartell@erg.com ]

Sent: Tuesday, December 23, 2014 1:08 PM

To: Brewer, Steve

Cc: Swietlik, William; Kim Wagoner

Subject: 2013 TRI Clarification for Hydrogen Su lfide Discharges

Dear Mr. Brewer:

Thank you for your time on the phone today. Eastern Research Group, Inc. (ERG) under EPA Contract No. EP

- C

- 12

- 021, is e

- mailing

you to request information for Valero Refining in Memphis, TN. See below for background on w hat the information is used for.

EPA reviews publicly

- available discharge monitoring report (DMR) and toxic release inventory (TRI) data to fulfill its review

obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review and, if appropriate, revise its

water pollution control technology

- based regulations, called "effluent guidelines," that limit the discharge of pollutants to waters of the

U.S. from various categories of industrial facilities. EPA is currently conducting i ts 2015 annual review of existing effluent guidelines

and potential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further information). EPA

will discuss this revie w and the results in its 2015 Effluent Guidelines Program Plan scheduled for publication in the Federal Register

sometime in 2015 or 2016.Need to return call by / at/between and

. Signature: As part of the 2015 annual review, EPA is evaluating the data to the 2013 TRI and needs further information to comp lete the review.

Specifically, we would like to clarify the amount of hydrogen sulfide releases reported to the 2013 TRI from the Valero facil ity.

Please confirm/review the following data and questions below.

1. Please confirm the pounds of hydrogen sulfide released in 2013: 33,003 pounds

The release amount, as reported, is confirmed.

2. Please explain how the hydrogen sulfide load is calculated.

The hydrogen sulfide (H 2 S) as reported, is discharged to the City of Memphis publicly

- owned treatment works facility

(POTW). Per the Refinery’s POTW sewer use agreement, weekly wastewater sample analyses are required. A conservative

approach, assuming all sulfides detected in the Refinery’s w astewater is H 2 S, was used to evaluate the amount of H 2 S

discharged to the POTW. Hence, the mass load of H 2 S was calculated based on the total monthly volume of wastewater

discharged times an average monthly analytical concentration (ppm) of sulfides.

Ple ase call me at (517) 515

- 1721 once you have collected the above information. If you would like to speak directly with EPA

regarding this request, you can contact William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone a t (202)

5 66

- 1129 or by email: swietlik.william@epa.gov

.

Thank you,

Kimberly

---------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

To: steve.brewer@valero.com

From: Kimberly Bartell

CC: William Swietlik, Kim Wagoner

Date: Tuesday 12/23/14 2:08PM

Subject: 2013 TRI Clarification for Hydrogen Sulfide Discharges

Dear Mr. Brewer:

Thank you for your time on the phone today. Eastern Research Group, Inc. (ERG) under EPA Contract No. EP

- C

- 12

- 021, is e

- mailing

you to request information for Valero Refining in Memphis, TN. See below for background on what the information is used for.

EPA reviews publicly

- available discharge monitoring report (DMR) and toxic release inventory (TRI) data to fulfill i ts review

obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA to annually review and, if appropriate, revise i ts

water pollution control technology

- based regulations, called "effluent guidelines," that limit the discharge of pollut ants to waters of the

U.S. from various categories of industrial facilities. EPA is currently conducting its 2015 annual review of existing effluen t guidelines

and potential industrial guidelines which may need to be included (see http://www.epa.gov/guide/304m/ for further information). EPA

will discuss this review and the results in its 2015 Effluent Guidelines Program Plan scheduled for publication in the Federa l Register

sometime in 2015 or 2016.

As part o f the 2015 annual review, EPA is evaluating the data to the 2013 TRI and needs further information to complete the review.

Specifically, we would like to clarify the amount of hydrogen sulfide releases reported to the 2013 TRI from the Valero facil ity.

Ple ase confirm/review the following data and questions below.

1. Please confirm the pounds of hydrogen sulfide released in 2013: 33,003 pounds

2. Please explain how the hydrogen sulfide load is calculated.

Please call me at (517) 515

- 1721 once you have col lected the above information. If you would like to speak directly with EPA

regarding this request, you can contact William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone a t (202)

566

- 1129 or by email: swietlik.william@epa.gov

.Need to return call by / at/between and

. Signature: Thank you,

Kimberly

---------------------------------------- Kimberly D. Bartell

Environmental Engineer

Eastern Research Group, Inc.

kimberly.bart ell@erg.com

Phone: 517

- 515

- 1721