Need to return call by / at/between and

. Signature: Project No.: 

### 0317.00.005.522 Page 1 of 1

Project Name: 

### TRI20 11 

## CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 

### 01/07/13 Time: 

### 2 : 30 am

pm

Company Name: 

### St. Paul Park Refining ERG Staff Name: 

### Kimberly Bartell

Contact Name: 

### Herbert Owen Contact Phone Number: 

### ( 651 ) 458

- 2616

General Subject: 

### 2011 TRI Dioxin Discharges



## TOPICS DISCUSSED AND ACTION TAKEN

On January 7, 2013 at 2 :30 pm, I called St. Paul Park Refining to speak with Anne Liming (651

- 458

- 2694). She stated that she is not the correct contact for TRI data and she transferred me to Kristen Hoopmaker. I left a message for Ms. Hoopmaker.

On January 14, 2013, Herbie Owen (651

- 458

- 2616) returned my call and requested that we email him the dioxin data so that he can verify it with his records. Email address: Herbert.owen@ntenergy.com Please see

attached email communication.

On January 16, 2013, Herbie Owen called and requested some clarification on the dioxin discharges. We reviewed what data we have and he stated that in 2002 the facility took measurements (sampling data) and has been using that data ever sense to estimate their dioxin discharges. He said that the dioxin discharges are from the regeneration of catalytic ref ormers and that the facility has 2 reformers. One reformer is regenerated each year and one of the units is larger than the other. Therefore, every other year the dioxin discharges should be slightly higher than the previous year (due to the larger reforme r). He believes that in 2011 the smaller unit was regenerated and is unsure why the TWF has increased from previous years. He is looking into the data and will get back to me soon.

### St. Paul Park Refining Email Communication

From: Kimberly Bartell

To: Herbert.owen@ntenergy.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 1/31/2013 2:05 PM Subject: RE: 2011 TRI Clarification for Dioxin Discharges

Mr. Owen,

Thank you very much for sending your response. We will review the information and let you know if we have any further questions.

Thank you, Kimberly

---------------------------------------- Kimberly D. Bar tell Environmental Engineer Eastern Research Group, Inc. kimberly.bartell@erg.com

Phone: 517

- 515

- 1721

From: “Owen, Herbert” Herbert.Owen@NTEnergy.com

To: Bartell, Kimberly CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 1/30/2013 2:13 PM Subject: RE: 2011 TRI Clarification for Dioxin Discharges

Ms. Bartell,

The following response has been compiled to address the questions in your email dated 1/22/13.

1. What is the source of the dioxin compounds in the wastewater?

The source of the dioxins in the wastewater reported in 2011 was the regeneration of catalyst in a semi

- regen catalytic reforming unit (#1 Reformer).

2. If you used monitoring data to determine the dioxin distribution,

a. where was the monitoring conducted?

b. how are non

- detect results included in the distribution?

c. If available, please provide a copy of the monitoring results.

SPPRC operates two separate catalytic reformer units with throughputs of 14,500 barrels per day (#1 Reformer) and 10,100 bpd (#2 Reformer), respectively. The catalyst in each unit is typically regenerated every two years and the regenerations are alternate d so that only one unit is regenerated each year.

In 2007, the refinery conducted dioxin testing of the wash water generated during the regeneration of the #2 Reformer. Samples were collected at various stages during the regeneration process including th e carbon burn phase and at the end of the oxidization stage. During the carbon burn, grab samples of wash water were collected at various intervals prior to discharge to the refinery’s wastewater treatment plant. The total amount

of dioxins and the distrib ution of the individual congeners were calculated based on sample results and waterquantities. None of the sample results were “non detect”. The attached spreadsheet provides this data and the

calculation methodology.

The objectives of the 2007 sampling program were 1) to quantify the dioxins from that particular regeneration event and 2) to produce site

- specific data that could be used to estimate the generation of dioxins from future regenerations in both reformer units. There has been no additional sa mpling since 2007 to confirm whether the 2007 #2 Reformer data is representative of subsequent regeneration events or relevant/representative to regeneration events for the #1 Reformer. The quantity of dioxins reported in the RY 2011 TRI was based on

the r esults from the 2007 testing.

3. Please confirm the pounds of dioxin released in 2011: 0.00074 pounds (0.336 grams)

The calculation of amount of dioxins generated during 2011 which was discharged to our wastewater treatment plant was reviewed and revised t o 0.19703 grams (0.000434 pounds). Please see the attached spreadsheet for the breakdown of this quantity by congener. During the data review, SPPRC determined that the total quantity of water discharged during the regeneration process was originally misca lculated. This error resulted in the total quantity being over reported by approximately 2.6 times. This error has been corrected in the submission and will be corrected in a subsequent revision to the RY 2011 TRI submission.

4. Please confirm the facility r eported dioxin distribution in the attached spreadsheet.

The revised distribution of dioxins is provided in the attached spreadsheet.

5. If you don't have monitoring data, please describe how the distribution and pounds were reported

in 2011.

The 2007 data was used to develop an emission factor based upon the volume of water measured from the carbon burn and oxidization steps in the regeneration process. The 2011 estimate used this emission factor and

the estimated volume of water to calculate the mass of dioxins introduced to the wastewater treatment plant.

Please refer to Cells D8

– D17 on the attached spreadsheet.

In addition to the explanation provided above, SPPRC assumed that all of the dioxins in the regeneration water

which entered the wastewate r treatment system passed through the treatment processes untreated and were discharged through the NPDES outfall. This is a conservative assumption. It is our understanding that studies have shown or suggested that a portion of the dioxin is retained in t he sludge, float, and oil removed from the various wastewater treatment steps (oil

- water separation, dissolved air flotation, biological treatment, etc.), and that granular activated carbon filtration also removes a portion of any dioxin. Please note that SPPRC’s wastewater undergoes all of these treatment steps prior to its discharge.

To our knowledge, there are no approved or recommended treatment or removal efficiencies by which to estimate any reduction in dioxin concentrations. SPPRC has not sampled t hese various streams for dioxins during or after reformer catalyst regenerations and the fate of the dioxin in the wash water discharged to the wastewater treatment system was not/has not been evaluated.

Please let me know if this response does not adequa tely address your questions or if you have any additional questions.

Herbert E. Owen, Jr. , M.S.E., P.E.

Senior HES Professional St. Paul Park Refining Co. LLC

301 St. Paul Park Road St. Paul Park, MN 55071

Ofc: 651/458

- 2616

Fax: 651/458

- 2699

Cell: 651/470

- 6217From: Kimberly Bartell

To: Herbert.owen@ntenergy.com CC: Sabol, Elizabeth; Swietlik, William; Wagoner, Kim

Date: 1/15/2013 9:57 AM Subject: 2011 TRI Clarification for Dioxin Discharges

Dear Mr. Owen,

Thank you for returning my phone call. As discussed, EPA is requesting clarification of 2011 TRI data as part of our 2013 annual review of industrial discharges under Section 304 of the Clean Water Act. I am writing to request

clarification for the St. Pau l Park Refining Co., on behalf of EPA under Contract No. EP

- C

- 12

- 021. Please see below for further background.

EPA, Office of Water (OW), reviews TRI data to fulfill its review obligation under Section 304(b) of the Clean Water Act. The CWA requires EPA t o 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 facilities. EPA is currently conducting its 2013 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 2013 Effluent Guidelines Program Plan scheduled for publication in the Federal Register sometime in

2013 or 2014.

As part of the 2013 annual review, EPA is evaluating the data reported to the 2011 TRI and needs further information to complete the review. Specifically, we would like to clarify the amount of dioxin compounds reported to the 2011 TRI. Please confirm/review the following data and questions below.

1. Please confirm the pounds of dioxin released in 2011: 0.00074 pounds (0.336 grams) 2. Please confirm the facility reported dioxin distribution in the attached spreadsheet. 3. If you used monitoring data to determine the dioxin distribution, where was the monitoring cond ucted and how

are non

- detect results included in the distribution? If available, please provide a copy of the monitoring results. 4. If you don't have monitoring data, please describe how the distribution and pounds were reported in 2011.

5. What is the source of the dioxin compounds in the wastewater?

We appreciate your help in interpreting TRI data correctly. If you have any questions regarding this request, please call me at (517) 515

- 1721. If you would like to speak directly with EPA regarding this r equest, you can contact William F. Swietlik of EPA's Office of Water/Engineering Analysis Division by phone at (202) 566

- 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