National Pollutant Discharge Elimination System Permit

1
National Pollutant Discharge Elimination System
Permit

• B P Products North America
• Whiting Refinery

2
Agenda Public MeetingDraft NPDES Permit forBP
Products

• Opening Remarks
• Presentation of the changes at the Whiting
  Business Unit by BP
• Presentation of the draft NPDES permit by IDEM
• Break, collection of questions from the audience
• Response to questions submitted by the audience
• Closing Remarks

3
Introduction

• The public comment period for the draft NPDES
  permit is open until May 11, 2007.
• Written comments addressing the draft permit will
  be accepted up to May 11, 2007.
• All written comments will be considered by IDEM
  in the preparation of the final permit.
• All written comments will receive a response from
  IDEM.

4
Introduction

• The B P Products NPDES permit/Fact Sheet are
  available on the internet at http//www.in.gov/id
  em/permits/water/wastewater/public_notice/index.ht
  ml.
• Please write out all questions and comments that
  you wish to have addressed at this Public Meeting
  on the form provided.
• Questions will be addressed following this
  presentation.

5
Facility Description

• BP Products North America Inc. owns and operates
  a petroleum refinery located on approximately
  1,700 acres in Whiting, East Chicago and Hammond,
  Indiana near the southern tip of Lake Michigan.
  The refinery employs approximately 1,500 people
  and produces a variety of products including
  gasoline of all grades, diesel fuel, heating
  fuel, jet fuel, asphalt and coke. The refinery
  can process up to 420,000 barrels of crude oil
  per day.

6
Receiving Waters

• Lake Michigan Lake Michigan is the receiving
  water for Outfalls 001 and 002. (Outfall 001
  will be renumbered as Outfall 005 with
  commencement of discharge through effluent
  diffuser).
• Lake George Branch of the Indiana Harbor Ship
  Canal The Lake George Branch of the Indiana
  Harbor Ship Canal is the receiving water for
  Outfalls 003 and 004

7
Lake Michigan

• Lake Michigan is designated as an outstanding
  state resource water, Lake Michigan is also
  designated for full-body contact recreation and
  capable of supporting a well-balanced warm water
  aquatic community. The Indiana portion of the
  open waters of Lake Michigan is designated as
  salmonid waters and shall be capable of
  supporting a salmonid fishery.

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Lake George Branch of the IHSC

• The Lake George Branch of the Indiana Harbor Ship
  Canal is classified as a high quality water that
  is a tributary to an OSRW (Lake Michigan) and is
  also designated for full-body contact recreation
  and capable of supporting a well-balanced warm
  water aquatic community.

9
Outfall 001

• BP Whiting discharges a maximum monthly average
  of 21.4 million gallons per day of treated
  wastewater from water used in the refinery,
  recovered ground water and most of the storm
  water from the site through their wastewater
  treatment plant to Outfall 001.

10
Outfall 001 cont.

• BP also accepts and treats wastewater at the
  wastewater treatment plant from NiSource Whiting
  Clean Energy (approx. 1.2 MGD) and Ineos PIB Unit
  (formerly BP Chemical Plant) (approx. 0.45 MGD).

11
Whiting Clean Energy

• Whiting Clean Energy supplies BP with steam. The
  closed cycle cooling towers operated by Whiting
  Clean Energy have a blowdown which is sent to the
  BP wastewater treatment plant (WWTP).

12
Ineos

• The Ineos facility sends wastewater from a
  polybutene manufacturing/processing unit (PIB
  unit) to the BP wastewater treatment plant. The
  PIB unit has sent their wastewater to the BP WWTP
  for many years.

13
Alternate Mixing Zone

• IDEM is proposing to allow a discharge induced
  mixing zone through a diffuser in Lake Michigan
  which produces a mixing volume of lake water that
  is 37.1 times greater than the discharge volume
  of 21.4 million gallons per day from Outfall 001.
• The alternate mixing zone will encompass a 182
  feet radius from the diffuser.

14
Alternate Mixing Zone cont.

• Diffuser design basics
• 330 feet long.
• 12 ports facing upward.
• Port diameter is 6 inches.
• Ports spaced 30 feet apart.
• Distance from shore is 3,500 feet.
• Lake depth at diffuser is 28.5 feet.

15
Alternate Mixing Zone cont.

• In accordance with 327 IAC 5-2-11.4(b)(4), the
  mixing zone shall not
• Interfere with or block passage of fish or
  aquatic life
• jeopardize the continued existence of an
  endangered or threatened species or result in the
  destruction or adverse modification of such
  species habitats
• extend to drinking water intakes
• impair or otherwise interfere with the designated
  uses of the receiving water

16
Alternate Mixing Zone cont.

• promote undesirable aquatic life or result in a
  dominance of nuisance species
• allow substances to settle to form objectionable
  deposits
• allow floating debris, oil, scum, and other
  matter in concentrations that form nuisances
• allow objectionable color, odor, taste or
  turbidity, or
• cause adverse effects to human health, aquatic
  life or wildlife.

17
Alternate Mixing Zone cont.

• The following concerns were raised about the
  alternate mixing zone by IDEMs Assessment
  Branch
• Toxicity of the Effluent
• The support structure of the diffuser becoming an
  attraction to aquatic life
• Maintenance of the Diffuser
• Biological monitoring to ensure efficient
  diffuser operation.

18
Alternate Mixing Zone cont.

• Compliance with effluent limitations and Whole
  Effluent Toxicity testing requirements will
  ensure that the discharge after mixing does not
  demonstrate toxicity to aquatic life.
• Approval of the design of the support structure
  is under the jurisdiction of the IDNR Division of
  Water, US Army Corps of Engineers (Detroit
  District), and IDEMs Water Quality Certification
  Program.
• Part II.B.1 of the permit requires the permittee
  to maintain in good working order and efficiently
  operate all facilities and systems including the
  diffuser.

19
Alternate Mixing Zone cont.

• Efficient diffuser operation will be ensured by
  proper operation and maintenance requirements
  under Part II.B.1.
• There will be a written maintenance procedure
  developed by BP addressing proper operation and
  maintenance of diffuser.
• Proper operation and maintenance will be verified
  through periodic inspections by BP Products and
  IDEM.

20
Alternate Mixing Zone cont.

• IDEM has evaluated all available information
  relevant to the consideration of harm to human
  health, aquatic life, or wildlife, and has
  determined that the alternate mixing zone will
  not cause any of the adverse impacts identified
  in 327 IAC 5-2-11.4(b)(4).
• Implementation of an alternate mixing zone
  significantly reduces the potential for BP's
  discharge to adversely affect aquatic life,
  because the magnitude and duration of exposure
  will be reduced as a result of more rapid and
  immediate mixing.

21
Outfall 002

• In the past, BP Whiting has discharged a maximum
  monthly average of 119.6 million gallons per day
  (11-99 through 10-01 data) of non-contact cooling
  water to Lake Michigan through Outfall 002.
• Outfall 002 currently has a maximum monthly
  average discharge of 96.4 MGD of non contact
  cooling water (7-02 through 12-05 data).
• After the refinery has been configured to process
  CXHO, the maximum monthly average discharge from
  Outfall 002 will be 81.8 MGD.

22
Outfalls 003 and 004

• BP Whiting discharges storm water to Outfalls 003
  and 004 using a manually controlled valve.
• The storm water is managed through the use of a
  Spill Prevention, Control and Countermeasure
  Plan, a Facility Response Plan, and Agreed Order
  No. H-11187 which defined eight interim measures
  to be implemented at the J L site in which
  Outfalls 003 and 004 are located.

23
Effluent Limitations for 001

• The permit places effluent limitations on the
  following pollutant parameters BOD, TSS, COD,
  Benzo-A-pyrene, Chloride, Copper, Total Dissolved
  Solids, Fluoride, Lead, Oil and Grease,
  Phenolics, Ammonia, Strontium, Selenium, Sulfate,
  Sulfide, T. Chrome, H. Chrome, Mercury, Vanadium,
  pH, Phosphorus and Whole Effluent Toxicity

24
Effluent Limitations Rationale for Outfall 001

• BP is allowed up to three years to either install
  and operate the diffuser or meet the final
  effluent limitations that are based on Indiana
  Water Quality Criteria calculated into effluent
  limitations without the benefit of the mixing
  zone.
• Limits from the existing permit are carried
  forward at the same levels and will remain
  applicable as interim limits during the
  compliance period, until the diffuser is
  operational.

25
Effluent Limitations Rationale for Outfall 005

• When the diffuser becomes operational, Outfall
  001 will become Outfall 005 for data tracking
  purposes. The actual monitoring point will
  remain the same.
• The effluent limitations for BOD, COD, oil and
  grease, phenolics, Sulfide, T. Chrome, H. Chrome
  and pH will be identical to the effluent
  limitations contained in the existing permit.
• Phosphorus is limited to a daily maximum
  concentration of 1 mg/l.

26
Effluent Limitations Rationale for Outfall 005
cont.

• The effluent limitations for Fecal Coliform and
  Total Residual Chlorine have been removed from
  the permit because the sanitary wastewater is now
  being sent to the City of Whiting for treatment.
• BP is required to monitor the effluent from
  Outfall 001 for Acute and Chronic Toxicity until
  the diffuser is operational and then BP will be
  required to monitor the effluent from Outfall 005
  for chronic toxicity only.
• If toxicity is demonstrated, a Toxicity Reduction
  Evaluation is required.

27
Effluent Limitations Rationale for Outfall 005
cont.

• BP will be allowed up to five years to achieve
  compliance with the new final limitations for
  Vanadium and Mercury.
• IDEM anticipates BP will apply for a Streamlined
  Mercury Variance which will require BP to
  implement a pollutant minimization program to
  reduce Mercury in their discharge.
• IDEM anticipates BP will develop additional
  toxicological data for Vanadium which will be
  used to revise the water quality criterion for
  aquatic life.

28
Effluent Limitations Rationale for Outfall 005
cont.

• The effluent limitations for ammonia as N and
  Total Suspended Solids (TSS) are being increased
  due to the increased loading of these pollutants
  to the WWTP resulting from refining the Canadian
  Extra Heavy Crude (CXHO) and increasing the
  coking capacity. BP submitted an Antidegradation
  Demonstration to IDEM to justify these increased
  permit limitations.

29
Antidegradation Rule for OSRWs

• Discharge flow volume will not increase as a
  result of CHXO refining proposed by BP Products.
• 327 IAC 5-2-11.7(a)(1)(B)(iv) allows the
  Commissioner of IDEM to calculate increased
  effluent limitations on a case-by case basis when
  the proposed increase in mass is not a result of
  an increase in discharge flow.

30
Antidegradation Implementation

• IDEM required BP to submit an antidegradation
  demonstration which shows the increase is
  necessary, that the activity responsible for the
  increase accommodates important social or
  economic benefits to the area where the discharge
  occurs and that it is limited to the minimum
  necessary to allow the activity to occur.

31
Antidegradation Demonstration

• BP will implement the following projects as part
  of the CXHO Project to minimize TSS and ammonia
  in the effluent
• Desalter Brine Treatment to remove emulsified
  solids from the brine wastewater prior to
  entering the process sewer.
• Expansion of the sour water stripping system for
  handling the increased ammonia loading from the
  processing of Canadian crudes.

32
Antidegradation Demonstration cont.

• Installation of an additional 10 million gallon
  equalization/storm water tank to allow more
  consistent feed to the WWTP.
• Upgrading the final filters at the WWTP to
  improve hydraulics and reliability.
• Implementing flow reduction projects to maintain
  the WWTP discharge at current level of 21.4 MGD.

33
Antidegradation for Ammonia

• Ammonia effluent limitations
• Monthly Average Daily Maximum
• Existing 1,030 lbs/day 2,060 lbs/day
• Proposed 1,584 lbs/day 3,572 lbs/day
• Fed ELGs 3,358 lbs/day 7,387 lbs/day
• WQBELs 3,215 lbs/day 7,501 lbs/day

34
Antidegradation Demonstration for Ammonia

• Demonstrated ammonia removal efficiency 70
• Existing loading of ammonia to the WWTP 1,668
  lbs/day
• Estimated loading of ammonia to the WWTP using
  CXHO 3,822 lbs/day
• 0.3 x 3,822 lbs/day 1,147 lbs/day
• Monthly average limit based on 95 probability of
  achieving compliance with 1,147 lbs/day 1,584
  lbs/day using EPA guidance.

35
Antidegradation for TSS

• TSS effluent limitations
• Monthly Average Daily Maximum
• Existing 3,646 lbs/day 5,694 lbs/day
• Proposed 4,925 lbs/day 7,723 lbs/day
• Fed ELGs 4,925 lbs/day 7,723 lbs/day
• WQBELs TSS does not have numeric water quality
  criteria.

36
Antidegradation Demonstration for TSS

• TSS influent loading to WWTP has the potential to
  increase by as much as 654 based on data from
  another refinery which has processed the CXHO
  (Toledo, OH).
• Proposed increase from the existing monthly
  average limit of 3,646 lbs/day to 4,925 lbs/day
  is a 35 increase.
• Increase reflects the increase in the coking
  operations.

37
Antidegradation Demonstration

• This project will
• Increase the diversity and security of oil
  supplies to the Midwestern United States
• Allow the Whiting Refinery to continue to operate
  as a viable business and significant employer of
  northwest Indiana
• Contribute to the tax bases of the cities of East
  Chicago, Whiting and Hammond
• Create 70 to 80 new full time positions in the
  refinery and will also result in thousands of
  temporary construction jobs

38
Proposed BP Permit Limits Monthly Average

• TBL WQBEL Current Draft
• lbs/day lbs/day lbs/day lbs/day
• BOD 6,156 N/A 4,161 4,161
• COD 42,980 N/A 30,323 30,323
• OG 1,791 N/A 1,368 1,368
• Phenolics 32.8 N/A 20.33 20.33
• Sulfide 32.5 N/A 23.1 23.1
• Total Chromium 38.1 627 23.9 23.9
• Hex Chrom 3.13 54 2.01 2.01
• TSS 4,925 N/A 3,646 4,925
• Ammonia 3,358 3,215 1,030 1,584

39
Effluent Limitations Rationale for Outfall 002

• The effluent limitations for Total Organic Carbon
  (TOC), Total Residual Chlorine, pH and
  Temperature are identical to the limits in the
  existing permit.
• Oil and Grease has the same daily maximum
  effluent limitation of 5 mg/l, but it is no
  longer a net limitation (BP no longer receives
  credit for amounts of oil and grease in the
  influent, making the proposed limit more
  stringent).

40
Effluent Limitations Rationale for Outfalls 003
and 004

• The effluent limitations for Oil and Grease, TOC
  and pH are identical to the limitations in the
  existing permit.
• BP must develop a Storm Water Pollution
  Prevention Program within eighteen (18) months
  from the permits effective date.

41
Submit your Questions Comments

• Please complete the forms provided to submit your
  questions and comments.
• When completed, submit the forms to a member of
  IDEM.
• Questions will be addressed this evening, if
  possible.
• Comments will be considered in the final permit
  decision.

42
Questions? Comments

• IDEM will now answer questions about the Draft
  NPDES Permit
• Comments that you want IDEM to consider in the
  final permit decision should be submitted in
  writing to
• IDEM - Office of Water Quality
• Industrial NPDES Permits Section
• Attention Mr. Bill Stenner or Mr. Steve Roush
• MC 65-42 IGCN Room 1255
• 100 North Senate Avenue
• Indianapolis, IN 46204-2251