Need to return call by / at/between and

. Signature:

___________________________ Project No.: 

### 0172.08.005.604 Page 1 of 1

Project Name: 

### TRI2009 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 01/10/11 Time: 

### 10:00 am

pm

Company Name: 

### Hovensa ERG Staff Name: 

### Elizabeth Sabol

Contact Name: 

### Kent Veron Contact Phone Number: 

### (340 ) 692

- 3698

General Subject: 

### 2009 TRI Dioxin Releases and Distribution



## TOPICS DISCUSSED AND ACTION TAKEN

On January 10, 2011, I called Hovensa to speak with Alexander Moorhead regarding 2009 TRI dioxin discharges and corresponding dioxin distribution. I left a message asking Mr. Moorhead to return my phone

call.

On January 1 0, 2011, Kent Veron returned my phone call. I told Mr. Veron that I was calling to confirm 2009 TRI discharges of dioxin reported by the facility and the corresponding dioxin distribution. Mr. Veron asked that I send the request via e

- mail. Please see the attached e

- mail correspondence.

On January 20, 2011, I left Mr. Veron a message to discuss the information in his e

- mail (sent 01/18/2011) regarding study data used to report dioxin distributions and loads.

On January 28, 2011, I left Mr. Veron a message t o discuss the dioxin distribution reported in 2009. I asked him to return my call as soon as he could.

On February 1, 2011, I e

- mail Mr. Veron asking if he had time to discuss the dioxin distribution reported. Mr.

Veron stated that he was out of the office , but would be available Monday, February 7.

On February 9, 2011 , I called Mr. Veron to discuss the reason why a d ioxin distribution was reported in TRI 2009, but not reported in TRI 2007 and 2008. Mr. Veron stated that the distribution/speciation data is not from any sampling data, rather from literature. He also stated that this literature purely focuses on water distributions for the refining industry. Mr. Veron stated that the source of the speciation literature is not known and that the data is just co pied over for each reporting year. I explained that this is not the way the data appears in TRI, as it

is not the same from 2008 to 2009. He asked that I send him an e

- mail with a request for the industry summary containing the dioxin distribution . He ment ioned he would not be able to look for the study before the end of the first quarter.From: "Veron, Kent" <KVeron@hovensa.com>

To: "Swietlik.William@epamail.epa.gov" <Swietlik.William@epamail.epa.gov>

CC: Elizabeth Sabol <Elizabeth.Sabol@erg.com>

Date: 2/23/2011 11:34 AM Subject: API TRI RY2007 Workshop

- April 2

- 3, 2008 in New Orleans

Mr. Swietlik:

I narrowed down the source of the estimation. The estimate was given in a presentation on Catalytic Reformers by Mr. Ashok Patel during the subject Workshop. Attached is the agenda from that workshop and the slides from Mr. Patel’s prese ntation. As noted on the bottom slide (#26) on page 16 of the attachment (labeled as page 13), the dioxin factor and individual dioxin isomer factors are from Table 2 of an NPRA technical paper prepared by TOSCO. The TOSCO corporation no longer exist bu t at one time

owned several refineries. I believe they were purchased by Conoco Phillips.

As faith would have it, Mr. Patel is a close personal friend of mine so I am confident he will be able to provide a copy of the TOSCO NPRA paper. I will forward t hat paper to you as soon as I receive it.

Regards,

Kent Veron Senior Staff Environmental Engineer

Hovensa LLC

Direct: 340

- 692

- 3698

email: kveron@hovensa.com

From: "Veron, Kent" <KVeron@hovensa.com>

To: "Swietlik.William@epamail.epa.gov" <Swietlik.Willi am@epamail.epa.gov>

CC: Elizabeth Sabol <Elizabeth.Sabol@erg.com>

Date: 2/23/2011 9:48 AM Subject: RE: Teleconference with you regarding Dioxin discharges

Good morning Mr. Swietlik:

The increase from 2008 to 2009 was purely due to the number of times we regenerated reformer catalyst. From 2008 to 2009, the number of regenerations increased from 1 to 3, an increase of 200%. This means the reported dioxin released to water increased 200% as well. The number of regenerations required in a given year ca n vary between 0 and 3 depending on several operating factors.

The only supporting info I could find so far simply states "Data suggests 0.1

- 1g dioxin released to water with each regeneration". We use the average of 0.55 mg per regeneration. Naturally, this is a very imprecise estimation and the actual amount released could be more or 0. The amount we report in a given year can vary from 0.00 to 1.65 grams per year.

I need to do some additional research to identify the study. I have identified a few employees that could shed some light on the source of the study. I will contact them today to discuss and let you know what I

determine.

I did find a supporting spreadsheet with the distribution of congeners for 2008 (see image below). The

water distrib ution below is the same as was used in the 2009 report (precisely 1/3 of those figures). I can't say for sure why the distribution data was not included in the 2008 TRI submittal but perhaps it wasjust an inadvertent omission. I will look into this as well.

Regards,

Kent Veron Senior Staff Environmental Engineer

Hovensa LLC

Direct: 340

- 692

- 3698

email: kveron@hovensa.com

----- Original Message

----- From: Swietlik.William@epamail.epa.gov [mailto:Swietlik.William@epamail.epa.gov] Sent: Tuesday, Febru ary 22, 2011 3:44 PM To: Veron, Kent

Cc: Elizabeth Sabol Subject: Teleconference with you regarding Dioxin discharges

Mr. Kent Veron Hovensa, LLC

Dear Mr. Veron:

In an effort to clarify and bring to closure the high level of dioxins reported by the Hovensa, LLC

-- Christiansted, VI facility in TRI for 2009, I'd like to schedule a conference call with you and Elizabeth Sabol of ERG, who has been in contact with you on several occasions recently.

We would like to get a better understanding of the ind ustry study that provided the dioxin distribution that you used, or an explanation of why a distribution was reported in 2009 and not in 2008. It is important that we are able to explain the high dioxin discharges reported to TRI

in 2009 as data like this , if accurate, could lead EPA to review itseffluent limitations guidelines for the discharge of dioxins from the petroleum refining industry.

Would you please identify a date and time this week when we could give you a call.

Thank you.

_________________

Bill Swietlik

US EPA

Office of Water Engineering and Analysis Division (4303T) 1200 Pennsylvania Ave., NW Washington, DC 20460

202

- 566

- 1129: Phone

202

- 566

- 1053: FAX

______________________________ Hovensa Disclaimer: This message and any attachment to it is intended only for the use of the individual or entity to whom it is addressed; it contains information that is proprietary and confidential, and may be privileged and exempt from disclosure under applic able law. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication i s strictly prohibited. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE: (A)

DO NOT READ THIS E

- MAIL MESSAGE, FORWARD IT TO ANY PERSON, SAVE IT, PRINT IT, OR OTHERWISE USE IT; (B) DELETE IT FROM YOUR COMPUTER SYSTEM; AND (C) NOTIFY THE SENDER, BY R ETURN E

- MAIL, OF THE MISTAKEN TRANSMISSION.

From: "Veron, Kent" <KVeron@hovensa.com>

To: "'Elizabeth.Sabol@erg.com'" <Elizabeth.Sabol@erg.com>

Date: 2/1/2011 1:41 PM Subject: Re: Request for 2009 TRI Data Clarification

There was no sampling as that would be cost prohibitive. The data used, both amount and speciation, is from old tech literature that only suggests these values. I would not put much faith in these values for scientific purposes. Suffice it to say the actua l amounts are insignificant. This is why we don't put more effort into dioxin reporting. I hope this helps. Ill be back next week if u wish to discuss.

From : Elizabeth Sabol

To : Veron, Kent

Sent : Tue Feb 01 14:17:08 2011 Subject : RE: Request for 2009 TR I Data Clarification

Kent,

Thank you for all the information that you've provided regarding the Hovensa dioxin discharges. I have

one follow

- up question for you regarding the dioxin distribution reported by the facility and how it was determined (throu gh sampling or study data). If you could please call me to discuss at your earliest convenience, my number is 703

- 633

- 1659. I look forward to hearing from you.Thank you for your time,

Elizabeth

Elizabeth A. Sabol Environmental Engineer

Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com

Phone:703

- 633

- 1659

From: "Veron, Kent" <KVeron@hovensa.com>

To: Elizabeth Sabol <Elizabeth.Sabol@erg.com>

CC: "swietlik.william@epa.gov" <swietlik.william@epa.gov>, Eleanor Codding <Eleanor.Codding@erg.com>, Jessica Gray <Jessica.Gray@erg.com>, "Antoine,Kathleen"

<KAntoine@hovensa.com>

Date: 1/18/2011 3:19 PM Subject: RE: Request for 2009 TRI Data Clarification

Elizabeth,

I could not find the precise study but I did confirm our calculation is based on a single technical study/survey from years ago. As you are aware, info on dioxin concentrations from refinery catalytic reformers is very scarce. Here are a few references which may provide some insight:

1. Fiedler, H., ``Sources of PCDD/PCDF and Impact on the Environment.'' Chemosphere v. 32(1), (1996), pp. 55

- 64.

2. International Programme on Chemical Safety (IPCS). 1989. Environmental Health Crit eria 88, Polychlorinated Dibenzo

- paradioxins and Dibenzofurans, World Health Organization, Geneva.

3. Canadian Environmental Protection Act. 1990. Priority Substances List Assessment Report No. 1: Polychlorinated Dibenzodioxins and Polychlorinated Dibenzofurans.

4. API 4506 Revision / Edition: 90 Date: 03/00/90 DIOXIN AND FURANS

- A PRIMER

5. Apparently a study conducted in May of 1994 led the EPA to believe that catalytic reformers are not a significant source of dioxin rele ase into the environment. Also, our industry trade associations, NPRA and API may be able to assist you with this info.

Regards,

Kent Veron Senior Staff Environmental Engineer

Hovensa LLC

Direct: 340

- 692

- 3698

email: kveron@hovensa.com

From: Elizabeth S abol [mailto:Elizabeth.Sabol@erg.com] Sent: Tuesday, January 18, 2011 3:08 PM To: Veron, KentCc: swietlik.william@epa.gov; Eleanor Codding; Jessica Gray; Antoine, Kathleen Subject: RE: Request for 2009 TRI Data Clarification

Kent,

I have a few remaining questions regarding the 2009 TRI dioxin data, particularly dealing with the data obtained from the industry study that you referenced yesterday. Please find the questions below.

1. What industry study was used to calculate the dioxin load for 2009?

2. Ho w is the study data used to calculate the load? For example, are industry study data provided as concentrations that are used in conjunction with the facility flow to estimate a load? Or is a certain dioxin amount (i.e., mg) associated with each regenerati on cycle combined with facility data to estimate a load? Did this methodology or study data change since 2008 TRI data was reported? 3. Does the study data have any concentrations reported as below the detection limit? If yes, how do you incorporate those data?

If this information is better discussed via phone, please contact me directly at 703

- 633

- 1659. I look forward to hearing from you.

Thanks,

Elizabeth

From: "Veron, Kent" <KVeron@hovensa.com>

To: Elizabeth Sabol <Elizabeth.Sabol@erg.com>

CC: "swiet lik.william@epa.gov" <swietlik.william@epa.gov>, Eleanor Codding <Eleanor.Codding@erg.com>, Jessica Gray <Jessica.Gray@erg.com>, "Antoine,Kathleen"

<KAntoine@hovensa.com>

Date: 1/17/2011 8:04 AM Subject: RE: Request for 2009 TRI Data Clarification

Elizabeth,

Here are the answers to the 2 remaining questions: 3. Is the mass released based on actual sampling data, and were dioxins/furans detected? Or, were releases estimated based on values below the detection limit? ANSWER: No actual sampling data is available so the concentration data was obtained from a prior industry study. 5. Can you estimate which congeners were released? ANSWER: No. Speciation of the congeners is also based on data obtained from a prior industry study.

I trust these resp onses meet your needs. If not, please feel free to contact me.

Regards,

Kent Veron Senior Staff Environmental Engineer

Hovensa LLC

Direct: 340

- 692

- 3698

email: kveron@hovensa.com<mailto:kveron@hovensa.com>

From: "Veron, Kent" <KVeron@hovensa.com>

To: Elizabeth Sabol <Elizabeth.Sabol@erg.com>

Date: 1/11/2011 9:05 AMSubject: RE: Request for 2009 TRI Data Clarification

Elizabeth, It was a please speaking with you. I have answers to 3 of your questions below but need to dig a little

further for the ot her 2. I should have a response to those by Friday.

1. Please confirm the mass of dioxin reported in 2009.

Correct.

2. Please confirm the water based dioxin distribution reported in 2009.

Correct.

4. What is the source of the dioxin s released in the water?

Wash water from the regeneration of the platinum catalyst in the refinery’s 3 Platformer (catalytic reforming) process units.

Regards,
Kent Veron, P.E. Senior Staff Environmental Engineer

Hovensa LLC

Direct: 340

- 692

- 3698

email: k veron@hovensa.com

From: Elizabeth Sabol [mailto:Elizabeth.Sabol@erg.com] Sent: Monday, January 10, 2011 4:47 PM To: Veron, Kent Cc: swietlik.william@epa.gov; Eleanor Codding; Jessica Gray Subject: Request for 2009 TRI Data Clarification

Kent,

Thank you for your time on the phone earlier today. As discussed, EPA is requesting clarification of 2009 TRI data as part of our 2011 annual review of industrial discharges under Section 304 of the Clean Water Act. I am writing to request clarification of dioxin di scharges and distribution, on EPA's behalf under

Contract No. 68

- C

- 02

- 095. Please see below for further background.

EPA reviews 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 limitations guidelines” or "effluent guidelines,” that limit the discharge of pollutants to waters of the U.S. from various categories of industrial faci lities. EPA is currently conducting its 2011 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 review and the results in its 2011 Effluent Guidelines Program Plan scheduled for publication in the Federal Register in 2011.

As part of the 2011 annual review, EPA is evaluating the data reported to the 2009 TRI and needs further information to complete the review. S pecifically, we would like to clarify the amount of dioxin reported and the corresponding water congener distribution reported to the 2009 TRI. Please confirm/review thefollowing data and questions on the attached spreadsheet.

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call me at (703) 633

- 1659. If you would like to speak directly with EPA regarding this request, you can contact William F. Swietlik of EPA's Office of Water/Engineer ing Analysis Division by phone at (202) 566

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

Thanks,

Elizabeth

Elizabeth A. Sabol Environmental Engineer Eastern Research Group, Inc. 14555 Avion Parkway, Suite 200 Chantilly, VA 20151 elizabeth.sabol@erg.com<mailto:elizabeth.sabol@erg.com>

Phone:703

- 633

- 1659

________________________________ Hovensa Disclaimer: This message and any attachment to it is intended only for the use of the individual or entity to whom it is addressed; it contains information that is proprietary and confidential, and may be privileged and exempt from disclosure under applic able law. If the reader of this message is not the intended recipient or the employee or agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication i s strictly prohibited. IF YOU HAVE RECEIVED THIS COMMUNICATION IN ERROR, PLEASE: (A)

DO NOT READ THIS E

- MAIL MESSAGE, FORWARD IT TO ANY PERSON, SAVE IT, PRINT IT, OR OTHERWISE USE IT; (B) DELETE IT FROM YOUR COMPUTER SYSTEM; AND (C) NOTIFY THE SENDER, BY R ETURN E

- MAIL, OF THE MISTAKEN TRANSMISSION.