United States      Solid Waste and     EPA530-R-97-037e
         Environmental Protection   Emergency Response    NTIS: PB97-177 463
         Agency        (5305W)       June 1992 	
&EPA   Background Document
         for Capacity Analysis
         for Newly Listed
         Wastes and Hazardous
         Debris to Support 40
         CFR 268 Land Disposal
         Restrictions (Final Rule)
         Volume 5:
         Appendix D - Category 1
         Facilities for the F037 and
         F038 Capacity Analysis
               Printed on paper that contains at lest 20 percent postconsumer fiber

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                                            CD2F-
Background Document for Capacity Analysis for
 Newly Listed Wastes and Hazardous Debris to
Support 40 CFR 26S Land Disposal Restrictions
                (Final Rule)
                                                                        2 a.
 Volume 5: Appendix D - Category 1 Facilities
    for the F037 and F038 Capacity Analysis
 Q
 to
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 O
 O
United States Environmental Protection Agency
            Office of Solid Waste
             401 M Street, N.W.
          Washington, D.C. 20460
c3
                                                                         CO
                June 1992
UJ

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                           APPENDIX D


                      CATKCORY  1  FACILITIES





D.I   Incsrvlew Cuide


D.2   Recent  Infonaacion Obtained from Refinery Visits


Q.3   Recent  Information Subaitted by Category 1  Facilities
      [Sot«:   Some Category 1 facilities have declared their information

      confidential.  This information is in the RCRA CBI docket.i

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D.I Interview Gui«!«
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            STATE:


            COMPA.NT:


            ADDRESS:
                           FOJ: ro.v) WASTE c \P\CITV VNALVSIS •• REFINERY
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CONTACT:


POSITION:


REFERENCE;






DATE:


CALLER:
I'flONE Vl'MBER:


(FAX NUMBER):
                                      TIME:


                                 EXTENSION:
           - CBI claims?


           • Fill out responses to attached interview eu:Je


           - Need ;o fax m for ma lion to contain penon?


           • Items contact will send:
            • Miscellaneous notes:
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                                   FC37 AND F03S CU£S"ONS
      We have developed a preliminary series of questions to aid in our understanding of how the new
      F037 and F03fl waste listing and proposed land ban will affect  refineries.  These questions
      involve not only F037 and F03S wastes, but expand :o KCX3-KC52  and TC wastes, discuss past
      and fjture waste water treatment facility modificatiens, on site treatment, etc.. in order for us to
      get an understanding of the whole picture and how everything interrelates, in addition to gaining
      an overall understanding of the issues, we want to discover any unique problems or treatability
      issues that refineries may have associated with these wastes.  Please complete the questions
      below on separate pieces of paper and mail to Ms Jo-Ann 3assi (U.S. EPA) before June 1, 1991.

 I.O   Waste Water Treatment Facility

      i.i    «    what is your currant configuration (scnematic) ?

      l.l   •    How segregated Is your system, stormwater vs. process water?

      '•3   *    What modifications have been made in the last 5 years?

       1.4   •    What were tne driving forces behind these modifications?

       l,T  •    What future modifications are planned?

      i-fc   •    What are the driving forces behind these modifications?

      1.7   .    HOW haw the K048-K05Z TC and F037/F038 rulings  and land bans affected the
                facility in terms of modifications, operation, capacity, etc.?

2.o   K048-K052 and TC Wastes

      2.1   •    What is yogr estimated rate of generation and land disposal of K048-K052 and TC
                wastes?

      2.i-   •    How do you currently treat, recycle  or dispose of these wastes and are there any
                foreseeable changes in the treatment, recycling or disposal?

      z-3   •     How have the waste generation rates changed wrth the hazardous waste ruling and
                land ban?
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      ^•"   •    Have tnere teen ary ^istream or waste water treatment faelity operating c.-anggs
                to reduce '.he amount of these wastes generated and how effective are tr.ese
                changes?

     Z.f   •    Will ihe proposed  FC27  and F039 land ban affect the amount of these  wastes
                produced?

     2-t    •    How much of these wastes are stockpiled in containers or surface ^rrpcupdrrerus?

     2.1   •    What are the chemical and physical characteristics of the currency generated and
                stockpiled wastes (ie. a-9 they dewatered, do they have significant otu value. etc.;7

     1-1   *    How will these characteristics change wr.h any planned facility modifications and
                operating changes?

      2.1   •    What quantity of your secondary treatment waste, such as  sludge  from  the
                aggressive biological uvti, is categorized as TC waste?

3.0   F037and FOMWasies

     3-1   •    is there a current estimate of the amount  of F037 and F038  wastes generated?

     3-2-   •    Is there an estimate of t* amount of F037 and F038 wastes stockpiled in containers
                or surface impoundmerts?

     3-3   •    What are you currency domg with the stockpiled waste and what are your future
                plans?

     3.4   *    Wtwt are the chemical and physical characteristics of both the currently generated
                and ttw stockpiled wa*w?

     3.5*   •    What is your current treatment, recycle or disposal method and how will this change .
                with the land ban?

      34   •    What are  the capacrt**  of  these treatment, recycle and disposal methods in
                relationship to F037 arxJ F038 wastes?
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      3.7
      3.S
M.o    General
      H.I
Are there any planned changes, either physical or operational, to deal wnn the ;ard
ban and how will these changes affect K048-K052 waste generation?

Is it possible to reduce F037/F038 or K04fl-KOS2 wastes by putting more ol a icaa
on ihe aggressive biological units?
                 What are your offsite treatment options and are the unique features cf your waste
                 that would limit the treatability options?

                 What modifications have seen done or are planned upstream to reduce ;he amount
                 of waste generated in the waste water treatment facility (eg. pretreatrrem, scurce
                 control, segregation, etc.)?

                 Will the B'.F rulings affect any of the current disposal options, onsite, captive or
                 commercial?
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      H'.f   •     Is th&re a preference on producing F037/F038 wastes or K048-K052 wastes in terms
                 of handling or disposal?

      4.5"   •     What is the frequency of deanout for the various waste water treatment units (eg.
                 API. OAF, storage tank, surface impoundments, etc.) ?

      While some of these question* are very specific, we realize mat  initially not ail of the exact
      quantities,  etc. will be available.   The main purpose of trie questions is to get an overall
      understanding, to get a feel tor how much planning is taking place,  how much data is available.
      and what are the unique  problems that the refineries will encounter.
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           D.2  R«c«nt  lafonuticn  obtained from Refinery Visits


The  refineries visited by E?A are listed below.


     •     Chevron  (El SegM-do. CA)

     •     L'ltrasar (Vilaingeon, CA)

     •     Aooco  (Vhiting,  IN)

                 (Texas CUv, TX)
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                    F037  AS2  FD33 '.'ASTE CAPACITY ANALYSIS:
                         DATA "SE AND TRACKING  SHEET
Refinery:    Chevron -  EL  5*;.ir.'J.o Rpfir.ery
Stare:      California
                                                                                                         s
Data scurces
      . _S Petroleum refinery vlsils/voluntar1' -submission

      _x National  Survey of Hazardous Vaste Treatment.  Storage.  disposal,
         and Recycling  Facilities CTSDS survey)

      _ National  Survey c: Ha:arc!e-_;s '.Taste Generators

      _ Biennial  report/s:.\:a ropcrrir.g requirements

      _ " California ha:ardo.i -aste c.:.i:a base

       x pecroliua r« finery T of '-et sludge from holding tanks,  and IAF units  (assuming
      reported  daily quantities are generated 365 days/year).

      Chevron El Segundo reports no other F wastes than those  identified
      above.
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MEMORANDUM
                                         EL SEGUNDO REFINERY
                                         May 23. 1991


                                         FOT7 & F038 Waste I»UM
Mr. Bob Goeltz & James Hsu;
ICF Kaiser Engineers

Listed below are our responses to your list of questions regarding Refinery F Wistes:

Wj\STE  WATER TREATMENT FACILITY
•  What is your current corfigurazcn (schematic) ?
See attached schematic.

*  How segregated is your system, stormwater vs. process -water?
We have rwo systems: one handles process contacted wastewater and the other handles water that
has not had contact with any process streams. They do not meet until after treatment is complete.

•  Wha modifications have betn made i* the last 5 yean?
We have added new storage tanks for wastewater.  These units are used in the event the water
does not meet the effluent standards in our NPDES permit. The treated water is then rerumed to
these tanks for further treatment before discharge. Three new lAFs have been installed, one treats:
the water from the desalten at the crude units and the other two treat water before discharge under
our NPDES permit (it joins mother unit already in this service).

•  What were the driving forces beted that modifications?
NPDES permit compliance.

•  What funtre modifications art planned?
None.

•  Wkuare the driving forces beMnd these modifications?
K/'A

•  How navt K, TC and F rulings and Land Bans affected the facility in terms of modifications,
operations, cmdiy. tic.?
We have made change* to our  operation to provide more segregation between our systems that
produce K and F waste.


K AND  TC BASTES
*   W)ta it yow-esmnaedrau of generate and land disposal efK
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 Mr. Bob Coeltz & limes Hsu         F037 & F038 Waste [ss-es                    2
 ICF Kaiser Engineers

 We do not produce any continuous scrams of TC waste. We expect thai sorae in '.ermine m sources
 will produce TC waste (i.e. spills, tint cleaning sludge. filters), but we do not have estimates
 available for this generation.

 •   How do you currently mat. recycle or dispose of these wastes and are ihere any fortsetzbie
 changes in the treaonent, recycling or disposal?
 We currently feed about 200 BPD of K wasie :o our Coker using the Mobil Oily Sludge Coking
 process. The remaining K waste is dewatered using a centrifuge or filter press  and then  fed to
 TDU.  The solids from TDU reset the landban standards for the organic*. but fail for nickel md
 cyanides.   As a result, the solids are sent off- site for neutralization and stabilization prior to
 disposal.

 TC waste  is currently sent off-site for disposal.  We expect that after we improve the operation of
 TDU, we may have enough capacity to feed sludges or contaminated sod thai fails the benzene TC
 limit We would expect that any benzene contaminated material processed at TDU would piss the
 TC limit and would then be considered non-hazardous.

 •   How hme the HOW generation rates changed with the hazardous waste ruling snd Land Ban?
 The total generation of sludges generated from pur wastewater system has not changed since the
 land ban went into effect. However, we are taking steps to make sure that sludges that are  not K
 waste do not mix with K waste SITCMZJ to minimize the generation of K waste.

 •   Have there been any upstream or waste water ireaffnent facility operating changes x> reduce the
 amount of these waiter generated?
 See above.

 •   Will the new F Waste Lard Ban affect the amount of these wastes produced?
 We expect that we will have improved the operation of TDU by the time the F waste land ban goes
 into effect, so thai there will be capacity to feed F waste.  This will reduce the amount of F waste to
 disposal by 65%

 •   Haw much of these wastes are stockpiled in containers or surface impoundments?
 Since F waste and TC waste go directly to disposal, none of ihii material is stockpiled. Since our
 K waste is fed to TDU, the amount of material stored oo-site vanes depending on the current
 generation of K waste and the feed rate of TDU.

 •   What are the chemical and physical characteristics of the currently generaud and stockpiled
 wastes fie. are they dewatend,  do they have significant btu value,  etc.)?
 The K waste which ii fed to TDU hat been dewttcred (-33%  solids). Testing has shown the
 material has a low BTU vilue between  1000 and 2000 BTU/lb.

 •   How will these characteristics change with any planned'facility modifications and operating
 changes?
 No change U txptcted.

 •  Are any of your secondary treameni waste, such as sludge from the aggressive biological
 units, categoriied as TC waste ?
 No. The btomau from our activated sludge unit has been tested and is noo-hazardous.
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•  Is then a current estimate of the amount of F Wastes generated?
Our current generation of F waste is roughly 700 barrels per day which results in about 7 tons per

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 Mr. Bob Goeltz & James rfsu
 ICF Kaiser Engineer*
F037 & F038 Waste Issues
 •   /J f^ei-e a*  estimate of ihe amount of F Wastes stockpiled in containers or surface
 impoundments?
 We are noc stockpiling any F waste.

 •   What are you currently doing with the stockpiled waste an* what ore youfftoure plans *
 N7A.

 •   Whet are the chemical and physical characteristics of both the currently generated and
 stockpiled wastes?
 N7A.

 •   '.Vhat is your current moment, recycle or disposal method and haw will this change with the
 land ban?
 F «ute is currently dewatered and then sent out for land disposal. By the time the F waste land
 ban goes into effect, we expect then will be capacity at TDU to feed F waste.

 •   What are the capacities of these treatment, recycle and disposal methods in relationship to
 F Waste?
 After the cuneni operating problems at TDU are solved, we expect the TDU feed capacity to be
 approximately 9000 tons per year which will keep up with our F and K waste generation which is
 estimated at 6300 tons per year.

 •  Are there any planned changes, either physical or operational, to deal with the land ban and
 haw witt these changes affect K Wane generation?
 We are looting at various operahocul changes in our Effluent Treatment Plant that may reduce the
 amount of F waste generation.

 •  /; ir possible to reduce F orK Wastes by putting more of a load on the aggressive biological
 anus?
 No, the aggressive biological treatment unit (our Effluent Treatment Plant) is already fully loaded.
 Also, the state of California does ooc allow the treatment or disposal of listed waste in a wastewater
 treatment unit without a Hazardous Waste Treatment permit which the Refinery does not have.

 GENERAL
 •  What are yot^offsitetTvatrniM options a^ art there unique features cf your waste thcu^^
 limit the notability options?
 la our investigation of off-sic treatment options as an alternative to our TDU. we have found that
our K waste has too low of a BTU value to be accepted by cement m««  Incineration is the only
other treatment option we have researched. In general, we  have found very limited incineration
capacity available. Flu several of the incinerators can only accept waste in small containers
 (drums or boxct) which requires repackaging of all our waste.  As a contingency plan, we have
active profiles for incineration at the Pen Arthur incinerator.  However, we would be limited on the
amount we «wld imp due to the high moisture content of our cake.  We were instructed that we
 would have to go through an additional drying step on our cake to send large volumes of our waste
 »the incinerator.

•  What modifications have been done or are planned upstream to reduce the amount of waste
generated in the waste water naomi facility (eg. pretreaonent, source control, segregation, etc.)?
The Refinery has made extensive efforts in the past to reduce the  amount of wastes entering the
drainage systems and to insure our waste streams are properly segregated,

•  Will the BIF rulings affect any of the current disposal options, onsiu. captive or commercial?
No.
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Mr. Bob Goelti & Jan>:s Hsu
ICF FOiiser Engineers
                                F037 & F038 Waste Issues
•  h there a preference on prodjcixg F Waste or K Waste in terms of handling or dispciai?
F Waste is preferred over K Waste ixcause the land bans are not in effect for F Wisws yet

•  What is the frequency ofcle&iout for the \arious *osie water treatment units (eg. .\Pt, DAF.
iterate tank, turface impounds, etc.)?                                 ,
Float from IAf  DAF uniu and the forebay ire generated on a continuous Run as *ell as slop oil
emulsion from the recovered oil system. Sludges from the waste water tanks and API separators
are each cleaned out about once a year.
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                   Refinery:
                   State:
                                      F037 ADD P038 WAST* CAPACITY ANALYSIS!
                                            DATA DSC AND TRACK I HO SKKET
            Ultranar -  Wilmington Refinery
            California
Data sources available:

      _x Petroleum refinery visits/voluntary  submission

       jc National Survey of Hazardous  Uasce Treatment, Storage, Disposal,
         and Recycling Facilities  (TSDR survey)

      _ National Survey of Hazardous  Waste Generators

       ...... Biennial report/state  reporting requirements

       x California hazardous vnste  data base

      _x Petroleum refinery data base  (PRDB)

      _ No-migration petitions


Basis for F037 and F038  vaste
                        EPA used data provided by Ultranar (Uilnlngton refinery) because  it was
                        che most recent and the only source that describes F037 and F038  waste
                        generation and management.  Other sources were used only in comparison
                        with the refinery's data submission.


                  F037 and F038 vaste estimates:

                        F037/8 (routine) - 50 tons/year from PPI and IAF units, and from  sewer
                        cleanouts .

                        F037 - 383 tons/yr. from periodic clean out of Junction box.

                        Ultramar reports no other F unites than those identified above.
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Ultramar Attendees:
EPA Attendees:
REFINERY DESCRIPTION
                                 TRIP REPORT1
                       ULTRAMAR REFINERY VISIT (5/24/91)
Les Norton
Steve Faichncjy
Willy Nakahara

Jo-Ann Bassi (OSW)
Bob Coeltz (ICF Inc.)
James Hsu (ICF Inc.)
                                                                                Ml
                                                                                                        2S
      The Ultramar refinery In Ui1mIngton, California,  previously  owned by
Champion, Is the only refinery in the United States owned by Ultramar, a
British eonpany.  The refinery produces primarily gasoline,  processing up to
69 thousand barrels of crude oil per day.  The crude refining area was built
in 1950.* and the refinery's octane processing area was  built In 1960.  The
facility reports an average water outfall of 850 thousand gallons  per day.

      The facility has reduced the source of sludges by paving and by
segregation of non-contact process water streaas fron contact vastewater •
streams in the last five years.

      Plans for future modifications include:

      *     Increasing surge capacity and primary effluent quality.

      •     More recycling of non-contact waters back to processing.

      •     Keeping dirt out of the system.   By paving,  Ultranar expects that
            wcste sludge generation would decrease by 10 percent.

      •     Retrofitting the basin to reduce vapors.

      According to Ultramar, existing and future regulations  concerned with
water quality hav* resulted in generation of more sludge.  The wastewater
treatment sludge ruling will not change current petroleum refining waste
generation rates.

WASTESATER TREATMEHT SYSTEM

      Exhibit 1 presents a simplified wastewattr treatment flow diagram
showing wastewater treatment sludge generation for the Ultramar Wilmington
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     1  This  report  provides a general description of a particular petroleum
refinery, and then discusses  the  refinery's  wastewater treatment system,
generation of KOA8-K052, F037, and F038  wastes, and vaste management
practices.  This report has been  developed based on observations by EPA (with
support from ICF Inc.}, and has been supplemented by information provided by
the refinery.
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        ""       Refinery.
                                                                        >*<
                       Non-process contacted vasCewaters (containing only about 5-15 ppm oil
        —       and grease but/ having a high total solids concent), including boiler blowdown,
          (       stripped sour water,  cooling cower blovdown.  and other screams, are created in
                 a DAF unit.   The DAF floac. K048,  containing 5X solids,  is sent to the KOSC
        _       (Mobil Oil Sludge Coking) unit.

         ''             Process contacted wastevacers,  which are approximately 15-25! oil and 5-
                 10X solids,  pass through a treatment  train which includes a diversion box,  a.
        "^       parallel plate interceptor (PPI),  IAF units,  and tankage.   The PPI generates a
        a       sludge which Is senc  to the HOSC process (approximately  10X solids).   The oil
                 layer is sent to the  desalter/coker uastevater treataenc train,  and the water
        Tl       layer froo the PPI is sent to an IAF  unit.   The IAF float,  F037,  is sent to
        j       the MOSC unit.

        „             Treated water froa both process contacted and non-contacted screaas is
                 delivered to an air flotation unit lump before being recycled as utility vater
        '••'       or-diverted to the forebay to cha  county sewer.

        ~~             Desalter water, coker vastewater streans,  and crude  and slop tank
                 drainage (which is not particularly "dirty"),  go through a  series of  tanks
                 before being centrifuged to break  the oil/water/solids emulsion.   Sludges from
         —       the centrifuge, an F038 waste containing about 20?  solids,  are  sent to KOSC
                 processing.   Oil is recovered by means sit a second  PPI,  and the water froo
                 chis separation process is finally delivered  to the previously mentioned
                 diversion box that receives process contacted  waters as  .   The  PPI  separator
                 sludge,  an F037 waste,  is sent to  the KOSC unit.

                 PETROLEUM REFINIKC WASTE CEKEUTIOM

                       Non-process contacted wastewater float generated in the DAF unit  is
                 generally  about SX solids.   The  parallel plate  interceptor  sludge  (F037) from
        • .       process  contacted vastevaters U approximately  101  solids.  Sludges from the
                •centrifuge  treating desalter vater are about 202  solids.  These floats  and
                 sludges  generated in  wasteirater  treataent are dewatered  co  201 solids  in a
          ,     - centrifuge before being fed to the  HOSC  process.  Approximately 6  tons/week
                 (312  cons/year)  of sludge are  sent  Co MOSC  processing (222  CA waste). ' The
         "••      HOSC  can handle no Bore than 81  solids in the  feed  streaa.
                      Air flotation units and tankage also generate some sludges.
                does not have an estimate for the generation of these sludges.
Ultramar
                      Ultramar reports  chat all K wastes (DAF and IAF float, and
                oil/water/solids sludges) generated since 1988 and F wastes generated since
                1989 are fed to the Mobil Oily Sludge Coking (HOSC) process.  The KOSC process
                currently treats about  1.750 barrels per nonth of sludge, which is only about
                SOX of capacity.

                      In the past, the  typical generation rate of vascewater treatment sludges
                totalled on average about 800 eons per year.  In 1986, 301 cons of K048. 217
                tons of K051, and 1194  tons of "oily sewer sludge* (now F037-F036) was
                generated.  The high generation rate of sludge that year was due Co a cleanouc
                operation.  In 1987, 723 Cons of K04B. 369 tons of KOS1. and 49 cons of "oily
                                      3 -2.
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sever sludge* was  generated.
cons in 1968.
Generation of "oily sewer sludge* amounted to
      F wastes generated from sever cleanouc are similar to Che PPI separator
sludge.  Petroleun  refining vastes generated ac this facility contain no
chromium or lead,   However, because Ultramar uses hydrofluoric acid
alkylation, some fluorine  is present  in the waste.

      The diversion box is cleaned out as needed.  Ultramar estimated that
1,500 barrels of sludge (F037) are generated from each cleanout.

WASTE MANAGEMENT PRACTICES

      The facility  accepts no offsite wastes.  K. TC. and F wastes are all  •
delivered to the MOSC process.  Ultramar keeps the solids content of the KOSC
feed at less than 8 percent.  The coka produced contains no more than 0.51
ash.  Junction boxes and suops around refinery processes are cleaned out with
a hydroblast vacuum truck and put into temporary storage and subsequently used
in the cokers.  If  a volume of greater than 1000 barrels is generated, then a
contractor with portable treatment capabilities'(e.g.,  filter press,
centrifuge) is called to treat the excess waste and send it off-site Cor
disposal.

      The IAF units tend to be more efficient Chan DAT units.   Both types of
unite are cleaned out once or twice a year.

      Ultramar commented that ceaent kilns in California (Labec systems
designs wa» mentioned) appear to show interest only in  liquid wastes.
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                            ULTRAMAR HAZARDOUS WASTE SUMMARY
                                                                                                  w
                                                 AFU FLOAT
                                                         API SLUDGE
',1
               K wastes
               "Oily Sewers"
               F037.F038
       ft
       • if
1986
1987
1988
1989
1990
1986
1987
1988
1989
1990
301 tons -,
723 tons ' .
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1 194 tons ~
49 tons ^
46 tons \ 7V
-0- f,lM ''
-0- /fciG-'
217 tons' ^
369 tons .-
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               Mobil Oil Sludge Coking Process - 1.750 barrels per month.
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                                      F037 AND F038 WASTE CAPACITY ANALYSIS:
                                           DATA USE AND TRACKING SHEET
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Refinery:   Amoco •
State:      Indiana
                                           ng Refinery
Data sources available:

      _jt Petroleum refinery visiis/voluntary submission

       x National Survey of Hazardous Vastc Treatment, Storage,  Disposal,
         and Recycling Facilities  (TSDR survey)

      	 National Survey of Hazardous Waste Generators

      __ Biennial report/state reporting requirements

      	 California hazardous vnste data base

      _£ Petroleum refinery data base (PRDB)

      _ No-migration petitions


gasjs for F037 and F038  wasteestirantion:

      EPA used data provided by Amoco (Uniting Refinery) because it uas the
      nost recent and the only source that describes F037 and F038 waste
      generation and managenent.  Other sources were used only in comparison
      with the refinery's data submission.


FQ37 and .FS3.8.,w»>t« estimates:

      F038 (routine)  - 405 cons/year from a grit chamber used to remove solids
      from wascewater influent to the primary treatment.

      Episodic F037 sludges are generated in tvo stormwater surge tanks (10.5
      million gallons each).  These tanks were installed a year  ago and have
      never been cleaned out; therefore, Che amount of F037 sludges generated
      is not known.
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                                                    TRIP REPORT1
                                       AMOCO VHXTINC REFINERY VISIT (5/9/91)
                   Aaoco Attendees:        Dave Kalet
                                           Julie Murphy
                                           Robyn Stephens

                   EPA Attendees: •         Jo-Ann Bassl (OSW)
                                           Bob Coeltz (ICF Inc.)
                                           James Hsu (ICF Inc.)
                                           Gary Light (ICF Inc.)
                   REFINERY DESCRIPTION

                         Amoco's Whiting refinery,  builc in the  late  1380's,  Is an  integrated
                   facility (i.e.,  it produces  gasoline,  lube, coke,  etc.) processing up to 350
                   thousand barrels of crude  oil  per  day,  drawing up  to 160 Billion gallons of
                   process water per day from Lake  Michigan (mostly for noncontact  cooling), and
                   has a.water outfall of IS  to 25  million gallons per day to the lake (and up to
                   100 Billion gallons when it  rains).   The refinery  comprises a crude processing
                   section,  a refining and occane building section, and a vastewater treatment
                   plant.


                   VASTEVATE& TREATKENT SYSTEM          _

                         Exhibit 1  presents che wastewater treatment  flow diagram at the Whiting
                   refinery.   In the refinery,  process wastewaters (i.e., contact and noncontact
                   water*)  and stonrwaters collect  In a  common sever  system that drains to the
                   wastewater treatment plane.2   Large pieces of oil-contaminated debris  are
                   removed froa the wastevater  by a bar  screen as it enters the treatment plant.
                   Next,  a hydrocyclone grit  chamber  removes particulars (e.g., sand) remaining
                   in the  wastewater.   The grit chamber  sludge (F038) is currently  sent off site
                   for land disposal.   Storsuatcrs  exceeding the grit chamber and downstream API
                   separators capacities are  diverted to stornwater surge tanks for.storage and
                   subsequent treatment.   Crlt  chamber water effluent enters API separators where
                   olli water,  and  solids undergo gravity  separation.  The oil is removed,  placed
                       1  This report provides n general description of a particular petroleum
                   refinery,  and  then discusses the refinery's wastetfater treatment system,
                   generation of  K048-K052. F037, and F038 wastes, and waste management
                   practices.  This  report his been developed based on observations by EPA (with
                   support froa ICF  Inc.), and has been supplemented by information provided by
                   the refinery,

                       2  The vastewater treatment plant also accepts ballast water,  water
                   bottoms froa terminals, vater froa an underground cavern used to store
                   propane, and wastewater from .1 nearby Amoco petrochemical plant.
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in tanks, and eventually returned to crude processing.  Solids form the API
separator sludge (KOS1). which Is removed froa che separator by scrapers, sent
to belt presses for dewatering, and created In a fluidized-bed incinerator.
Residues from incineration, still carrying the petroleum refining waste codes,
are trucked off-site for stabilization before landfilling.  The water phase
fron the API separator is discharged to stormwater surge tanks vhere it mixes
with diverted stormwaters.  Since oil and solids are part of diverted
stormvaters, and are not completely removed fron Che API separator effluent
water, gravity settling occurs In the stormwater surge tanks, and forms a
sludge (which Day be F037).  Stornwater surge tanks drain to two-stage OAF
units that use flocculants and dissolved air to form an oily DAF float (K048),
which is skinned off, nixed and devatered with the API separator sludge, and
treated in the incinerator.  Vastewater fron the DAF units is pumped to
activated sludge units.  The resulting water is then either used as fire
water, or is sent to clarifiers and filters, and finally discharged to Lake
Michigan via a NPDES permit or Is used as cooling water.  Activated sludge
unit blowdown and filter backwash are pumped back to DAF units for oil
removal.   Aaoco reports that the wastewater treatment system recovers
approximately 500 barrels of oil per day.


PETROLEUM REFINING WASTE CEHEBATIOS                   •

      Amoco Uhitln.g estimates generation of API separator sludge (KOS1) to be
1,800 gallons per day (2,700 com per year), and DAF float (K048) to be 43.200
gallons per day (65,700 tons per year).  Amoco indicates that the largest
contributors to solids in K048 and K051 wastes are dirt washed into the
severs, and precipitation of hardness (calcium carbonate) resulting from
caustic addition to sewer and activated sludge units.  An on-site fluidlzed-
bed incinerator treats K048 and K051 wastes and generates approximately 3,000
tons of Incineration residues (scrubber solids) per year.

      The grit chamber generates between 100 to ISO yards of F038 sludge per
year (approximately 135 to 203 tons per year).  This .sladge has the appearance
of dirty sand and will occasionally contain some asphalt.  This sludge is
currently trucked co an off-site landfill,  but will likely be sent to off-site
treatment (e.g., Incineration) once the F037 and F038 LDR takes effect.
Because of the LDX, Amoco will send oil/water separator sludges (F037),
generated in the refinery from.periodic cleanoucs,  to the grit chamber.  Amoco
estimates these cleanouts will increase, the generation of grit chamber sludge
Co 300 yards per year (approximately 405 tons per year).

      F037 sludges may be generated in the  two stornwater surge tanks (10.5
million gallons each).  These tanks were installed a year ago and have never
been cleaned out; therefore, the amount of  F037 sludges generated is not
known.
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 HASTE MANAGEMENT PRACTICES                                         '

      As  seen Exhibit 2, KOSt waste  sludge  from Che API  separator  is  pumped
 into a desludge  holding tank where decant oil  is recycled back Co  API.
 separators.   Thickened K051 sludge from  the Holding tank is mixed  with K048
 sludges (containing  7. percent solids)  from  the DAF unit, and  pumped to belt
 presses for dewatering prior to treatment in the fluidized-bed incinerator.
 The resulting cake contains between  15 to 20 percent .solids and has an average
 heating value of 3,000 Btu 'per pound.  The filtrate undergoes oil/water  '
 separation to recycle oil back to API  separators.           :

      The fluidized-bed incinerator, rated at  82 Mbtu per hour, was operated
 on a two month on/two month off basis  to burn  belt press cake,  spent  caustic,
 and other liquid hazardous and nonhazardous wastes.  Recently the  incineration
 campaign has  been extended to treat  these wastes because'difficulties in
 operating the incinerator's THC monitors has frequently  caused the incinerator
 to trip off.   Amoco does not expect  to treat grit chamber sludge (F03S) in the
 incinerator because solids ir. the sludge have  shown to cause  excessive wear in
 the incinerator  feed system; therefore, the sludge will continue to be sent
 off-site for  treatment and disposal.   The incinerator has enough capacity to
 treat all wastes  generated on site, but does hot have additional capacity to
 treat off-site wastes.  Exhibit 2 shows Whitings waste incineration system.

      In case  of a major incinerator fro 1lure,  the need arises  for vaste
 treatment alternatives.   Thus far ABOCO Whiting has only considered-sending
 petroleum refining wastes off site for incineration because other alternatives
 (i.e.,' sending wastes to cokers and cement kilns, and using solvent
 extraction! are not viable.   Amoco cannot use refinery cokers  to recycle
 petroleum refining wastes because the cokers are not located on site;1
 therefore the coking exemption does not apply.   The use of petroleum refining
 waste as fuel  for cement kilns ia not viable because Amoco is  concerned about
 the potential  liability  associated with waste residues iii cement being
 interpreted as land placement constituting disposal.   Amoco has not researched
 the potential of reducing KCW8-K052,  F037,  and F038 wastes by> putting  more
 load on activated sludge units because the  current  EPA position on scouring,
 and the recent correction to the  primary sludge rule,  replacing "treated"  with
 "generated" suggests that the nlxture rule  would cause the  biological  sludge
 to become a listed hazardous waste.   Amoco  examined solvent extraction
 technologies (CF Systems and B.E.S.T),  but  does not consider solvent
extraction versatile enough  to handle all the different refinery wastes  chat
vary in composition.   Amoco  has tasked its  WasteTech subsidiary to develop and
examine emerging technologies for treating  or recycling petroleum refining
vastes.  '       •
     3   The  refinery  actually h.is  five  different  facility  identification
numbers.  Cokers are  located  ai  a  part  of the  refinery that has a different
facility identification nuaber  Chan the wastewater treatment plant.
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                          In  che  last  five years, Che refinery has made significant modifications
                    Chat  impact the generation of petroleum refining wastes.  In late 1989 and
                    early 1990, Amoco  installed che grit chamber, and was motivated by hazardous
                    waste regulations  to replace a surface impoundment with tvo stormwater surge
                    tanks.  The grit chamber project improved the operations of moving equipment
                    in the API separators, reduced the production of hazardous waste API sludge,
                    and extended  the-operating life of the incinerator feed delivery system by
                    removing  sand from the feed.  The plant also reduced the amount of precipitate
                    in the wastewater, which ends up in sludges, by controlling the mixing of
                    caustic into  sewers and activated sludge units so that wascewater pH does go
                    above 9.  Amoco*s  refinery modifications and good housekeeping practices
                    coubine to reduce  previous generation of API separator sludge wastes by 33
                    percent.

                        . Amoco Whiting is investigating the replacement of API separators and DAF
                    units with comparable above ground equipment (i.e., plate interceptors).
                    Though API separators and CAT units are considered tanks, Amoco is concerned
                    that,  1C  the  tank  exemption no longer applies, it may be impractical to prove
                    that  they are not  leaking and releasing hazardous waste.  A secondary DAF
                    unit, dedicated for activated sludge unit blowdown, -is also being engineered.
                    Further projects under consideration are segregating the sewer system at a
                    estimated cost of  $140 Billion.
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                               EXHIBIT 1
              Amoco Oil Company Whiting Refinery
            Wastewater Treatment Plant Waters Flows
                                    Oil
-1

J
      Process
      Water"
                            Oil/Water
                           Separators
            Dewatering,
            Tanks, and.
            Incineration
                     DAF Float
             Clarifiad
             Scrubber
             Water

                 Activated
               Sludge Plant
               Slowdown &
                   FiRer
                Backwash
                            Wat*r
                     Storm Surge
                         Tanks
                       Dissolved
                           Air
                        Flotation
                       'Activated
                         Sludge
                          Plant
                                  Final
                                 Filters
Diagram Includes current piping, not         „.
flow. Not all bypasses or chemical   Final CTtlUent
addition are shown.

RBS 8/10/90
    Oil Recycle
    To Refinery
 Cooling
  Tower
Make-Up
                                               Fire Water
                                                Recycle
                                                         Lake
                                                        Water

                                             See Additional Diagram.
                                             •Oewatering. Tank* and Incineration*
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                                 EXHIBIT 2
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Answers to Refinery Question Concerning F, TC,  and K Wastes
                 USEPA/ICF Visit - May 9, 1991
             Amoco Oil Company - Whiting, Indiana
Wastewater Treatment Facility

     What is your current configuration?
           See attached process flow diagram

     How segregated is your system, stormwater vs. process water?
           The only segregated siormwater system in the refinery exists in a
           large tankfield and undeveloped area at the extreme southwest section
           of the property. These stormwater outfalls are separate from the
           process water and non-contact cooling water outfalls.  All refinery
           stormwater and most tankfield stormwater is collected and treated via
           the process sewer.

     What modifications have been made during the last 5 years?
           The grit chamber was put into service in early 1990. The stormwater
           surge tanks were put into* service in late 1989, replacing a surface
           impoundment.  An inground tank, No. 5 Separator, which stored API
           separator sludge, was closed. The API separators are now directly
           desludged into 569  tank. Sludge from 569 tank is now  mixed with
           DAF float and dewatered/deoiled before incineration.

     What were the driving forces behind these modifications?
           The  grit  chamber  project was  implemented  to  (1) .improve the
           operating factor of moving equipment in the API separators, (2)
           reduce the production of hazardous waste API sludge,  (3) remove
           sand  from incinerator feed, and (4) allow for the direct removal of
           API  sludge to  569 tank as  required with the closure of No.  5
           Separator.

           The stormwater surge tanks project was implemented to replace the
           surface impoundment and improve the environmental condition  of the
           facility.

           No. 5. Separator was closed because it was impractical  to install
           secondary containment.
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      What future modifications are planned?
           We are investigating the replacement of the API separators and the
           DAF unit with comparable above ground equipment.  Though these
           devices are recognized as WWTP tanks, there is concern that it may
           be impractical to prove they are  not leaking,  releasing  hazardous
           waste.   A second, separate DAF unit, dedicated for activated sludge
           plant blowdown,  is also being engineered.  Modifications to the
           activated sludge plant's caustic injection system is also being pursued.

      What are the driving forces behind these modifications?
           We feel that the WWTP tank exemption may not exist for very long.
           The  Benzene NESHAP for wastewaters is also a driving force.  The
           caustic injection project should reduce hardness precipitation, DAF
           float production,  and incinerator solids .which end up as incinerator,
           scrubber solids

      How have the K, TC and F rulings and land bans affected the facility
      in terms of modifications, operation, capacity?
           The  new K and TC regulations required  modification the  RCRA
           permit to include these waste codes.  Grit from the grit chamber will
           now be disposed-of as hazardous waste.  Though there is conflicting
           TCLP  data on the  nickel  content,  the  scrubber  solids from the
           incinerator  are stabilized off site prior to disposal.
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K and TC Wastes

      What is your estimated rate of generation and land disposal of K and
      TC  wastes?
           Since September,  1990, approximately 200 cubic yards of new DOI8
           sludges have been land disposed.  Most of this has been from the
           cleaning of a crude tank and some has been from hydrocarbon spills.
           K wastes are produced at about 30 GPM year round.  Disposal of FBI
           residual solids vary from 1700 to 3000 cubic years.

      How do you currently treat, recycle or dispose of these  wastes and are
      there any Foreseeable changes in the treatment, recycling or disposal?
           D018 sludges arc now stored in  roll of boxes. Free liquids are

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      removed in an attempt to deoil and remove  benzene.  This is not
      always successful, depending on the sludge matrix. This practice may
      be jeopardized under the upcoming Benzene NESHAP. Amoco Oil
      Company is currently investigating new technologies to better ensure
      hydrocarbon recovery and recycling.  K wastes are stored, pressed to
      remove oil/water and treated in the incinerator. Changes in treatment
      will reflect changes in incinerator regulations.  They could vary from
      different stack  gas treatments or  replacement of incineration with
      another process.
          +
How have the waste generation rates changed with the hazardous waste
ruling and land  ban?
      The TC rule has increased the amount of wastes which are hazardous.
      The land ban  regulations have not affected K waste production.
      Production of scrubber solids  has reduced steadily over the last-few
      years because of improvements in caustic addition to the sewer and
      activated sludge plant.  However, DAF production has  remained
      relatively constant, not significantly affecting incinerator run time.
      API sludge generation has-also been reduced, but this is due to the
      grit chamber  which now produces primary sludge.  TC waste
      production  is expected to increase with Benzene NESHAP.

Have there been any upstream  or  waste  water treatment  facility
operating changes to reduce the amount of these wastes generated?
      The refinery has continued its training and education of operators to
      pay attention to housekeeping practices, closer  control on caustic
      recycling,  reduction  of sand  losses  to the sewer,  attention for
      hydrocarbon leaks, and quick maintenance on leaks.

Will the  new F waste land ban  affect  the amount of these wastes
produced?
      No, as steps to minimize primary sludge production have already been
      implemented.

How  much  of these wastes are stockpiled  in containers or surface
impoundments?
      No  wastes  are  stockpiled  in containers or surface  impoundments.
      Some TC wastes and grit chamber solids are stored for 90 days at the
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           Lakefront or the refinery awaiting disposal. Some samples may also
           be  found  in the permitted hazardous waste storage building at the
           Lakefront. K wastes are routinely stored in permitted tanks prior to
           treatment.

      How  will  these  characteristics  change with  any  planned  facility
      modifications and operating changes?
           Implementation of hydrocarbon recovery and recycling technologies
           for sludges should reduce the D018  production from tank cleanings
           and hydrocarbon spills.  However, technology limitations may  not
           allow for hydrocarbon recovery of all DOI8 wastes.

      Are any  of your secondary treatment waste, such as sludge from  the
      aggressive biological  units, categorized as TC wastes?
           Testing to date  indicates no.
F Waste
     Is there a current estimate of the amount of F wastes generated?
           Generation is expected to be between 150 - 300 yards per year.

     Is there an estimate of F wastes stockpiled in containers or surface
     impoundments?
           No  F wastes are stockpiled in containers or surface impoundments.

     What are you currently doing with the stockpiled waste and what are
     your future plans?
           There are no stockpiled  F wastes.  If we generate F wastes in the
           refinery, they will be transported to the Lakefront for treatment in the
           Grit Chamber.

     What are the chemical and physical characteristics of both the currently
     generated and the stockpiled wastes?                          .
           Grit from the grit chamber appears as dirty sand. It occasionally will
           contain some asphalt. Tests show it does not exhibit a  hazardous
           characteristic.  It has not been compared to levels found in EPA's
           data used  to  make the F listings, but is believed  to be lower in
           concentration of constituents of concern because it  is so dissimilar to
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           API sludge and DAF float.

      What is your current treatment, recycle or disposal method and how
      will this change with the land ban?
           Grit and primary sludge wilt be land disposed.  When a primary
           sludge land ban is  created, the grit will most probably be taken off
           site  for treatment,  if  necessary.   The incentives  to -modify the
           incinerator or install other treatment technologies for such a small
           stream are not sufficient to support  such projects.
               jr
      What are the capacities of these treatment, recycle and disposal methods
      in relationship to F wastes?
           The treatment capacity of the incinerator for F waste is zero. The off
           site capacity is not  known.

      Are there any planned changes, other physical or operational, to deal
      with the land band and  bow will these changes affect K generation?
           No changes are  planned.   Affects to K waste generation are not
           expected.               „

      Is it possible to reduce F or  K wastes by putting more of a load on the
      aggressive biological units?
           This has not been researched from a technical standpoint.  However,
           the current EPA position on scouring, and the recent correction to the
           primary sludge rule, replacing "treated" with  "generated" would
           indicate that the  mixture rule would cause the biological  sludge to
           become listed hazardous waste.

General
      What are your offsite treatment options and are there unique features
      of your waste that would limit the treatability options?
           In case the need arises for offsite treatment, such as from a major
           incinerator   failure,  off  site  treatment would be  incineration.
           Pumpability and  BTU value  would  limit treatment throughput.
           Availability  of  haulers,  trucks  and   containers would also  be
           questionable.
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What modifications have been done or are planned upstream to reduce
the amount of waste generated in the wastewater treatment facility (eg.
pretreatment, source control, segregation, etc._?
      Items which have been previously mentioned include reducing solids
      loss  to the sewer and improving caustic addition to the activated
      sludge plant.  Reducing  oil and water losses are an ongoing effort.
      Future projects under consideration are segregating the sewer system.

Will the BIF rulings affect any of the current disposal options, onsite,
captive or-commercial?
      The BIF rule alone is not expected to change any current operations.
      However,  it along with  any new  rulings on used motor oil could
      affect its recycling in the Whiting Refinery.

Is there a  preference on producing F wastes or K wastes in terms of
handling or disposal?         x
      The Whiting Refinery has  no onsite treatment capabilities currently
      for F wastes. If a landban standard is adopted, it may require off site
      treatment.   Systems are in place for K wastes currently,  but  are
      difficult to operate.

What is the frequency of cleanout for various wastewater treatment
units?
      API separators are dcsludged continuously. Shutdown and inspection
      of separators and the DAF occur as necessary. Separators are usually
      done yearly and DAF  units when sludge deposits  interfere with
      operation.  Tanks arc emptied every incinerator run.
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                     Amoco Oil Company Whiting Refinery
                   Wastewater Treatment Plant Water Flows
             Water
                                           Oil
 Bar
Screen
v/
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     Recovered
     Oil
                              R>3?
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                               API Sludge
                                 KO*I
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     Tanks, and.
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                 Activated
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                                         Final
                                        Filters
Diagram includes current piping, not         „.
'flow. Not «H bypasses or chemical   Final EfflUCnt
addition are shown.

RBS 8/10/90
                               Oil Recycle
                               To Refinery
                                            Cooling
                                             Tower
                                           Make-Up
                                                      Fire Water
                                                       Recycle
                                                                Lake
                                                               Water
                                                   *
                                                    See Additional Diagram,
                                                    •Oewatering, Tanks and Incineration*

                                                                                     * - >*
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           SAMPLE
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           RUN 3
       _   PUN 1
           RUN 5
        -   RUN 6
           BLANK
                      AMOCO
                 PROJECT  #  1?B9

        WASTE C.'ARACTERIZATICN ANftLVSIS

           WASTE TYPE :  PAF CLOAT



                 ANALYSIS

                                    HEATING
'/. TOTAL    V.               DENSITY   VALUE    FLfiSH
'30LIDS   MOISTURE  '/. ASH   (g/ml)  (BTU/lb)   POINT
                                                    POHC
2.13
6.82
8.09
 6.a
8.64
9.25
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                 MO ANALYSIS FOR T'-ESE PARAMETERS
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                                      DUPLICATE ANALYSIS
                                                         HEATING
            SAMPLE   '/. TOTAL    ','.               DENSITY   VALUE    FLASH
              'D     SOLIDS   lOISTUfVe  •; ASH   (a/ml)   iBTU/l&> ,  POINT    POHC

           PUN i PL-?
           P'JN 2 PUP
           i='UN T. PUP    7.51  	NO ANALYSIS FOR THESE PARAMETERS	
           PUN 4 OOP
           RUN 5 DUP
           FUN 6 OUP
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                                       F037  AXD  MSB KASTK CAPACITY ANALYSIS:
                                            DATA USB AND TRACKING SHEET
                   Refinery:    Amoco -  Texas  City Refinery
                   State:       Texas
                   Data sources available:

                         __x Petroleum refinery visits/voluntary submission

                         _x National Survey  of Hazardous Waste Treatment, Storage, Disposal,
                            and Recycling Facilities  (TSDR  survey)

                         	 National Survey  of Hazardous Waste Generators

                         	 Biennial rsport/state  reporting requirements

                         	 California hazardous waste data base

                         _x Petroleum refinery data base (PRDB)

                          x No-migration petitions

                         _x Comments frost proposed rule

                         	 Organic  TC Survey

                   Basis for F037 and F038 vaste estimation:

                         EPA used data provided by Amoco (Texas City Refinery) because it was the
                         most recent and the only source that describes F037 and F028 waste
                         generation  and management.   Other  sources vere used only in comparison
                         with the refinery's data submission.


                   F037 and F038 waste estimates:

                         FQ38 (routine) — 10.400 tons/year  of dewatered cake estimated by EPA
                         based on large-refinery volume reduction of 80 percent by dewatering,
                         using reported vet  sludge volume of 52,000 tons/year generated as DAF
                         bottoms.

                         F037 (one-time) - 200,000 tons/year from cleanout of stormwater and
                         equalization basins.  Amoco  plans  to replace stormwater and equalization
                         basins with above-ground storage tanks.

                         Amoco Texas City reports no  other  F wastes than those Identified above.

                         According to more recent  Information from the comments to the proposed
                   rule,  this facility indicated that it would generate the following quantities
                   of surface impoundment sludges during the indicated time periods:
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           F037/8  (surface  inpouhdraents) - 0 tons  (7/9Z - 12/92)




           F037/8  (surface  Impoundnents) - 0 tons  (1/93 - 12/93)




           F037/8  (surface  impoundments) - 0 tons  (1/94 - 12/94)




           F037 (routine) - 85.000 tons/yr.          '      .




           F038 (routine) - 52.000 tons/yr.




The assumption used previously concerning devatering of F038  (i.e., 801) was

then applied to these new F037 and F038 volumes.
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          Anoco Attendees:
          EPA Attendees:
                                           TRIP REPORT1
                             AMOCO TEXAS CITY REFINERY VISIT (9/22/91)
                        Carole Engelder
                        Dave Kalec

                        Jo-Ann Bassi 
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 three DAF  units.

      Since  oil  and solids  are  p/irt  of the diverted  stormwaters,  and  are noc
 completely removed from the API atpnrocor effluent water,  gravity settling
 occurs  in  both the storir-'ater storage  impoundments and  equalization basins,
 and  forms  stormwater storage and equalization sludges  (F037).   These  sludges
 are. removed  (as 'the units are donned)  and sent  to an off-site  Amoco  land
 treatment  facility near the refinery.

      DAF  units employ  floeculnnta and dissolved air to form an oily  DAF float
 (K04B), which  is  skimmed off. nixed  nnd dewatered with  the API  separator
 sludgx. 'and  recycled to the coke is.  Small particles are emulsified in-the DAF
 float while  larger oil.-contaratnatcd  particles settle to form DAF  bottoms
 (F038).  "Hits  sludge is nixed and dewatered with the API separator sludge and
 DAF  float, -and used in  the  cokcra.   DAF unit effluent wacer is  transferred to
'another equalization basin  uherc gravity seeding forms an equalization sludge
 (F037).  Plans'are being studied to  close and replace this unit with  an above-
 ground  tank.   AC  that-time,  the F037 sludge would be removed and  sent off site
 to the Amoco land treatment facilities  or to treatment.2  Vastevater from the
 equalization basin is pumped to activated sludge units,  then to clarifiers and
 filters, and finally discharged via  A  NPDES permit.  Amoco reports that the
 wastewater treatment system recovers Approximately 1,500 barrels  of oil per
 day.
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            PETROLEUM REFINING WASTE GENERATION

                  Amoco Texas City estimates9 that generation of API. separator sludge
            (K051) ranges fron 8,000 to  15,500 wet tons* per year, and DAF float (K048)
            ranges front 32.000 to 120,000 wet tons per year.  The trend at the refinery is
            Coward an increase in K048 generation and decrease in K051 generation.  Amoco
            attributes the high variability  in K04B generation to variability in the types
            of crude processed, and to the presence of emulsion-forming substances, such
            as CaF (generated in HF alkylatlon), that decrease oil/water/solids separation
            efficiency in the DAF unit.  Amoco has observed that a decrease in .generation
            of K051 corresponds to an increase in generation of DAF bottoms (F038), and
            vice versa.  Therefore, there la also considerable variability in the
            generation of DAF bottoms, vhlch la estimated at 13,000 to 91,000 wet tons per
            year.  Despite Chese variations, Amoco's combined generation of DAF float and
            bottoms remains relatively constant at 106,000 to 133,000 wet tons per year.
                 2  The F037 sludge will be sent to land treatment facility if closure of
            the equalization basin occurs before the F037/F03S LDR becomes effective.
            Otherwise, the sludge will be sent to treatment.

                 1  Waste generation estimates bused on 1987 to 1990 data.

                 *  Amoco reports wastes.in wet tons, which contain approximately 80
            percent water.
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      F037 sludges from Che stormwater storage impoundments and equalization
basins (i.e.. equalization basins for API separator effluent and DAF unit
effluent) are generated from clean out of these units.  Amoco 's recent clean
out of stormwater storage impoundments generated 205,000 tons of wet sludge.
No data are available on the amount of FOJ7 sludge that would be generated
from closure of the remaining storrcvater impoundment and two equalization
basins; a conservative estimate would put the quantity over 200.000 tons.

      F037 sludges may also be generated in the unit oil/water separators.
However, these sludges are cleaned out periodically by. vacuum trucks and
discharged to API separators, and arc. therefore, accounted Cor in K051 and
K048 waste volumes.

      Other hazardous wastes generated at the refinery include 50 to 230 vet
tons per year of heat exchanger cleaning solids (K050) ,  which is sent to the
.cokers, and 5,000 to 172,000 tons of soil contaminated with K048-KOS2,  F037,
F038 or D018 wastes managed at the land treatment facility.  The refinery
accepts no off -site petroleum refining wastes for treatment or recycling.
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WASTE KAriACKKENT PRACTICES

      Exhibit 3 presents a block Uiagras of the refinery's was'te management
practices.  K048, K050, K051, and F038 vasce sludges are transported to heated
storage, gravity thickening, and conditioning prior to filtration.   The
resulting sludge contains 20 to 30 percent solids.9  Plate and frame  presses
filter oil and water froa the sludge to produce a cake containing
approximately 60 percent solids and a heat content ranging from SO to 1.000
Btu/lo.   The filtrate undergoes oil/vater separation to recycle oil back to
crudo processing.  Prior to November 8, 1990,  when the K048-K052 land disposal
restriction (LDR) became effective, the filter cake (containing K048, K051,
and F038) vas sent to the nearby Amoco land treatment facililty.  The K048-
KOS2 LDR prompted the refinery to install the capacity to recycle, petroleum
refining wastes to their cokers and avoid the cost and liability associated
with land disposing petroleum refining wastes.  The refinery/ has .three coking
units, configured with two drums per unit.  Two units accept petroleum
refining wastes for producing fuel grade coke.  The third unit produces anode
grade coke.  The waste recycling system was designed by Amoco and was brought
on line in October 1990.  In using the cokers. the filter cake is mixed with  a
hydrocarbon to fora a slurry containing 10 percent solids, and is injected
into the cokers.  Amoco designed to process to increase the coke ash content
by no more than three percent when recycling petroleum refining wastes,  but
Araoco reports that the actual increase in coke ash content is well  below three
percent.     ,

      Amoco had start-up problems with the waste recycling system,  which
resulted in an accumulation of filter cake.  At one point in January 1991,
        Solids  may comprise up  to  20  percent  filter aid.
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Amoco counted a backlog of 60 roll-off boxes storing filter cake designated
for cokers,  Amoco contacted Chera Waste Managecent and Rollins for hazardous
waste incineration service, but found that they could only accommodate one to
two roll-off boxes per week.  The backlog, which required the facility to
petition the Texas Water Commission for a 90-day storage extension is
gradually being worked off by correcting the start-up problems, re feeding the
filter cake to the coking system, and sending roll-off boxes to incinerators.
Exhibit 4 presents the methods used to manage the filter cake backlog.  Amoco
expects that by the tine the F037/F038 LDR becoir.es effective in October 1992
nose petroleum refining wastes (i.e., K068. KOS1, F037,  and F038) would be
recycle to the cokers.b

•  •    The use of petroleum refining waste as fuel for cement kilns was not-
considered as a viable option when coker start-up problems occurred because
Amoco is concerned about the potential liability associated with waste
residues in cement being interpreted as land placement constituting disposal.
Furthermore, fluoride, phosphates, and a high ash content in refinery's wastes
preclude the use of Rhone-Foulenc's sludge incineration capacity.

      Amoco is in the process of closing one remaining stormwater storage
impoundment and two equalization basins,  and replacing then with above-ground
tanks because of hazardous waste regulations.  Above-ground tanks would have
similar sludge accumulation rates to~those in impoundments and equalization
basins, but uncertainty in the cleanout frequency presents difficulties in
estimating periodic removal of F037 sludges from tanks.

      The refinery is.considering plans in the next two to six years to
segregate process wascewater and stormwater flows.   This modification will
eliminate a significant amount of water and dirt chat passes through the
wastevater treatment system, and will result in a major reduction in the
amount of petroleum refining wastes generated.
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     *  If the next stomvater  impoundment  or  equalization basin cleanout
occurs prior to the F037/F038 LOR. Amoco indicated that the  F037  sludge
generated would be sent to Amoco's land treatment facility.

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                                                  Amoco Ol Company
                                                  uM Ctty, TOM 77S32
                                                  409-945- 101 1
7 June 1991
Mr. James Hsu
ICF
9300 Lee Highway
Fairfax, Virginia  22031-1207
                                       AIRBILL NO.:  8515501761
                        for Voluntary In formation .on Refining Wastes
Attached are responses to the questions solicited by Ms. J. Bassi of the EPA Office of
Solid Waste in her letter dated 13 May 1991, requesting voluntary information on
petroleum refining wastes. Amoco Oil Company is pleased to give this data to assist (he
EPA in developing land disposal restrictions for F037 and F038 primary sludges.

If you have questions or need clarification on this information or any gathered during
your site visit 22 May 1991, please feel free to contact me at 409/945-1196.

Yours truly,
Carole L. Engelder, PhD, PE
Waste Minimization Coordinator
Attachment

Ms. 7. Bassi
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                                                                                                                 m
                   Voluntary Information on Petroleum Refining Wastes

                        Amoco Oil Company -- Texas City Refinery
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                                             Treatment Facility
 1.  What is your current configuration?
       A flow-diagram of the current wastcwater configuration is shown in Figure 1, with an
       aerial diagram of the facility in Figure 2. Wastcwater from twenty- five process units and
       stormwaier from all  areas of the refinery flow hydrogcologically to one of three main
       API separators.  During storm events, excess flow is diverted by lift station pumps to
       stormwater storage in both surface impoundments and an aboveground storage tank.
       Wastewater flow from the three API separators and stormwater worked out of storage
       (depending oh downstream activated sludge plant capacity) pass  through an equalization
       impoundment on the way to dissolved air flotation (DAF).  The refinery currently
       operates three DAF units in parallel.  After DAF treatment, the wastewater flows into
       another part of the equalization basin, then through mixed-media pressure prefilters, and
       into the activated sludge plant.  Following aeration and clarification, the wastewater is
       filtered again in  mixed-media pressure final filters and discharged into a canal leading to
       Galveston Bay.                        ~

       Solid waste generated during wastewater treatment is managed according to the flow
       diagram given in Figure 3. The wastewater treatment sludges generated in the API
       separators and DAF  units is pumped to heated storage and gravity thickening tanks where
       oil/water is decanted. The sludges are mixed and conditioned before filtration in a plate-
       and-frame filler press.  The filter cake produced from the filter press is currently
       reslurried with a refinery hydrocarbon and pumped to the coker complex for conversion
       to fuel and oil products.  Not shown in the figure, biosludge or sludge .wasted from the
       activated sludge plant to maintain a steady-state bacterial population, is pumped to the
       refinery land treatment facility.
2. How segregated Is your system?
      Currently, the refinery sewer system in not segregated; process unit wastewater and
      refinery stormwater is commingled.
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3. What modifications have been made in the last 5 yean?
       In 1936-87, several upgrades and modifications were made to the wastewaier treatment
       facility.  A third DAF unit was put on line, an additional mixed-media pressure preftlter
      "was added, and a sludge deoiling unit (SOU) was constructed. The SOU was designed
       for refinery sludge dewatering and oil recovery and consists of plate-and-frame pressure
       filters.  In  1989, a 750,000 barrel aboveground stormwater storage tank was built and in
       1990, sludge coker injection facilities were designed and constructed.
4. What were the driving forces behind these modifications?
       DAF capacity was increased to improve wastewater treatment facility operation.  The
       SDU was added to recover additional valuable oil from the wastewater treatment sludges.
       The stormwater tank was built in response to a need for more storage capacity and
       improved stormwater management. The sludge coking system was designed in
       anticipation of the K048-KOS2 land ban.
5. What future modifications an planned?                           •
      Amoco Oil Company is planning several major modifications in the near future:  sewer
      segregation, additional aboveground stormwater storage capacity, aboveground
      equalization to replace the existing equalization basin/surface impoundment, and covering
      all treatment units on the primary side excavated sludge treatment.
6. What are the driving forces behind these modifications?
      Primary sludge, TC, and benzene NESHAP rules.
7. How have the K-Iist, TC, and F-list rulings and land baas affected the facility in terms
      of modifications, operation, capacity, etc?                      >
      These rulings added incentive for development of a company-wide waste minimization
      program for Amoco Oil and the assignment of a facility Coordinator with dudes exclusive
      to waste minimization efforts a the Texas City refinery.  The K048-K052 land ban, as
      mentioned previously, led to the design and construction of a sludge coking process.
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                                 K04&-K052 and TC Wastes

1. What is estimated generation and land disposal rate of K04S-KOS2 and TC wastes?
      Generation ranges for hazardous refinery wastes over the past four years is given in
      Table 1.  Also shown is the current management technique for each stream.  During
      1987-1990, no waste identified as K049, slop oil emulsion solids was generated.  The
      refinery does not produce teaded gasoline, so no K052 waste was generated during  that
      time period either.  All K-list wastes are currently  managed by either on-site recycling to
      the fuel-grade cokers, or to off-site commercial incineration.

      Over thirty waste streams failing the TCLP has been identified, so far, including soils,
      sludges, and aqueous waste streams.   Their generation rates and current management
      techoiquei are also given in Table 1.  Generation of TC contaminated soils is dependent
      on construction and clean-up activities within the refinery.  Although these may be one-
      time generations, much of this activity is planned at the refinery in the future.
                 2. How do you currently treat, recycle, or dispose of these wastes and are there any
                       foreseeable changes?
                       (See previous question and Table 1.) The refinery is actively pursuing additional
                       recycling options for the hazardous sludges as alternatives to off-site incineration, the
                       current back-up option to sludge coking. -These include raw material replacement at a
                       cement kiln, although the state government in Texas may make it difficult to keep our
                       wastes in Texas through permit moratoriums.
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                 3.  How have the waste generation rates changed with the hazardous waste ruling and land
                       ban?                                       .
                       Generation rate of K-tist and TC hazardous wastes has neither increased nor decreased
                       since the November 1990 land ban on third-third wastes.
                 4.  Have there been any upstream or wastewnter treatment facility operating changes to
                       reduce the amount of these wastes generated and how effective are these changes?
                       Upstream source reduction measures have been implemented to prevent solids entering
                       the sewer, especially during storm events, such as street sweeping and area drain
                       retrofitting.  It was estimated that 2000 wet tons of hazardous sludge was prevented
                       through these activities'.  Upstream operating changes include increased clean-out
                       frequency of the HF Alkyiation Unit Calcium Fluoride sludge tank, which prevented an
                       estimated 9770 wet tons of hazardous sludge formation".
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5.  Will the proposed F037 and F038 land ban affect the amount of these wastes produced?
       Referring to Table 1, DAF bonotns sludge is already managed with K-list wastes. Some
       of the TC sludges that are currently land treated,, originate from sewer system cleaning
       and would be considered primary sludges subject to land ban.
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6.  How much of these wastes are stored in containers or surface impoundments?
       Since the November 1990 land ban on K-list wastes, filter cake not able to be recycled
       on-site to the coking complex or sent off-site for commercial incineration {in both -cases
       due to limited actual operating capacities) has been stored at the refinery in lined and
       covered roll-off boxes. Atone point, early in 1991, as many as 60 roll-off boxes
       containing approximately IS wet tons each of filter cake were stored on-site due to lack
       of coHng aad incineration capacity.  By mid-May 1991, eleven boxes of filter cake
       remained in storage on-site.  Figure 4 illustrates the status of all filter cake dropped into
       storage boxes between 11/8/90 and 5/21/91. Slightly over half were able to be worked
       back into the sludge coking process,  while one-third found commercial incineration
       capacity. Ten percent remained in storage on May 21.
7. What are the chemical and physical characteristics of the currently generated and
      stockpiled wastes?
      Raw refinery sludges are generally 10-20%-inert solids, 10-20% oil, and 60-80% water.
      The filter fat* generated at the refinery is approximately 50-60% solids, 5-10% oil, and
      30-40% water.  Net heating value of the filter cake ranges from less than 50 BTU/ib to
      500 BTU/lb.
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8. How will these characteristics change with any planned facility modifications and
      operating changes?
      Planned modifications within the refinery are expected to change the total quantity of
      wastes generated rather than altering the general chemical or physical characteristics.
9. What quantity of your secondary treatment waste, such as sludge from the aggressive
      biological units, is categorized as TC waste?
      To date waste activated sludge has not failed the TCLP, and therefore is not expected to
      be categorized as a TC waste.
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                                    F037 and F038 Wastes
                                                                                                              g 5s
1.  Is there a current estimate of the amount of P037 and F038 wastes generated? .
       See Table 1. DAF bottoms, considered a primary sludge,  have ranged from 13,000 to
       91,000 wet tons/year between  1987 and 1990.  (Note that during this time period, sludge
      from the DAF units I/loot and bottoms combined! ranged 70.000 - 160,000 wet
       tons/year.)  Primary sludges from equalisation and stormwater storage ranged from a
       year when no dredging or clean-out occurred to 205,000 wet tons/year.  Primary sludges
       from process unit oil/water separators and sewer pumping lift stations are removed by
       vacuum truck and taken to one of the main AT' separators, where the quantities are
       already considered as K048 or K051.                             '
Hi
2,  Is there an estimate of the amount of F037 and P03S wastes stored in containers or
       surface impoundments?     .      ,
       Other than the DAF bottoms contained in the filter cake, no primary sludges are being  .
       stored in the refinery. For an estimate of the sludge contained in surface impoundments
       due to the nature and function of the unit, see the previous question.
   What is your current treatment, recycle, or disposal method and how will this change
       with the land ban?
       Referring to Table 1, DAF bottoms are currently managed with the already land banned
       K-list wastes.  Sludges generated from equalization and stormwater storage are being
       dewatered/deoiled and sent to the refinery's land treatment facility for ultimate treatment
       and disposal. After the primary sludge land ban, these sludges will either be recycled to
       the refinery coker or incinerate! off-site.  Primary sludges from  process unit oil/wafer
       separators and sewer pumping lift stations is trucked to the wastewater treatment facility
       and managed along with the K-tist wastes.
4. What are the capacities of these treatment, recycle, and disposal methods In relationship
      to F037 and F03S wastes?
      The sludge coking process is limited by a permit capacity of SO dry tons/day of solids in
      the resluny stream, or approximately 120,000 - 150,000 wet tons/year of hazardous
      sludge3.  Current operating capacity is only 22 dry tons/day, though, or approximately
      50,000 - 65,000 wet tons/year of sludge.  The K-list and DAF bottoms sludges can
      probably be handled on-site with continued optimization of the sludge coking process, but
      excess quantities of equalization and stormwater sludge will probably have to be sent off-
      site.
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5. Are there any planned changes, either physical or operational, to deal with the land ban
       and how these changes affect K048-K052 waste generation?
       Current plans include evaluation of alternate recycling technologies, such as cement kilns.
       From a technical feasibility standpoint, cement kilns appear to adequately treat these
       types of wastes; however, concern exists over the liabilities associated with utilizing kilns
       when the cement product was manufactured using a listed waste and then applied to the
       land. The regulatory status would be clear if the agency ruled that such use docs not
       constitute disposal.
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                 2. What modifications have been done or are planned upstream to reduce the amount of
                       waste generated in the wastewaler treatment facility.
                       Sewer segregation will decrease solids entering (he process wastewater from soil erosion.
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                 3. Will the BFF rulings affect any of the current disposal options, onsite, captive or
                       commercial?
                       With the BTU minimum dropped from the rule, it should theoretically be easier to reuse
                      . our filter cairn in cement manufacturing.
                 4. Is there a preference on producing P037/P038 wastes or K048-K052 wastes in terms of
                       bundling or disposal?
                       Until the land ban, primary sludges can be treated and disposed at the refinery land
                       treatment facility,
                 5. What is the frequency of cleanout for the various wastewater treatment units?
                       The main API separators are cleaned of bottoms sludge approximately twice a year.
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                 1. Will th: Stale of Texas permit moratorium impact national capacity?
                       Cement kilns and other facilities in Texas not already permitted to accept hazardous
                       refinery wastes should probably not be included in the national capacity calculation for
                       F037-F03S and TC wastes,  since a moratorium on new permits is in place in Texas.
                 2.  Can storage boxes of K048-KQ51 filter cake be sent to a commercial incinerator site for
                       storage to avoid exceeding the 90-day limit at the refinery?
                       No.  Chemical Waste Management has refused to accept waste until capacity is
                       imminently available in their incinerator and we are unaware of any commercial storage
                       facility willing to accept roll-off boxes.
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     References


1.    ' 1990 Hazardous Waste Minimization Report' to the Texas Water Commission,

     24 January 1991.


1.    "Amendment to Coter Complex Permit No. R-2315" to the Texas Air Control Board,

     7 March 1990.
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                      Figure 3.  Solid Waste Management
                      Amoco Oil Company — Texas City Refinery
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         D.3  Recent Information Subaitted by Category 1 Facilities1
The refineries  that submitted  recent  Information are listed below.
            Hunt Refining (Tuscaloota, AL)
            Cross Oil and Refining  (Snackover. AR)
            Lion Oil (El  Dorado. AR)
            Chevron (El Segundo. CA)
            Ultranar (Uilnington, CA)
            Marathon (Robinson,  IL)
            Shell Oil (Wood River.  IL)
            Amoco (Whiting, IL)
            Total (Arkansas City. KS)
            BP Oil (Belle Chasse, LA)
            Exxon (Baton  Rouge.  LA)
            Murphy Oil (Keraux,  LA)
            Total (Alaa,  HI)
            Chevron (Pascagoula, MS)
            BP Oil (Llna,  OH)
            BP Oil (Marcus Hook, FA)
            Aatoco (Texas  City, TX)
            Chevron (Fort Arthur, TX)
            El Paso Refining  (El Paio,
            Exxon (Baytown, TX)
            Shell Oil (Deer Park, TX)
            Shell Oil (Odessa, TX)
            BP Oil (Ferndale, UA)
            Shell Oil (Anacortes, U'A)
            Texaco (Anacortes, UA)
            Quaker State  (Newell, UV)
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     1  Two Category  1  facilities have declared cheir submissions confidential
business  Information (CBI)  and  therefore their submissions are in the RCRA CBI
docket.

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                    P037 ADO r038 HASTE CAPACITY ANALYSIS:
                         DATA US! AMD  TRACKING SHEET
Refinery:   Hunt Refining - Tuscaloosa Refinery.
State:      Alabama
Data sources available:

      _x Petroleum refinery visits/voluntary submission

      _x National Survey of Hazardous Waste Treatment,  Storage. Disposal,
         and Recycling Facilities (TSDR survey)

      	 National Survey of Hazardous Waste Generators

         Biennial report/state reporting requirements

      	 California hazardous vaste data.base

      	 Petroleum refinery data base (FRDB)

      	 No-migration petitions

      	 Comments from proposed rule

      _x Organic Toxicity Survey       "*

Basis for F037 and F038 waste estimation:

      EPA used data provided by Hunt Refinery because it was the most recent
      and the only source that describes F037 and F038  waste generation and
      management.  Other sources were used only in comparison with the
      refinery's data submission.

F037 and F038 waste estimates:

      F037 (one-time) - 5,900 tons from closure of surface impoundments.
      These Impoundments vill be replaced by tanks,  which would generate F037
      sludges when cleaned out once every two to five -years.

      Hunt Refining reports no other F wastes than those identified above.

      According to more recent information from the TC  survey, this facility
indicated that It would generate the following quantities of surface
impoundment sludges, during the indicated Cirae periods:

            F037/8 (surface lapoundments)  -     0 tons  (7/92 - 12/92)

            F037/8 (surface izpoundaents)  -  2070 tons  (1/93 - 12/93)

            F037/8 (surface iapoundnents)  -     0 tons  (1/94 - 12/94)
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                                        HC.VT REFINING

 Hum Refining                                     '•'      June 5.1991,3:30 PM
 PO Box 1850
 Tuscaloosa, AL 35403-1850

 REFINERY DESCRIPTION

        The Hunt Refinery in Tuscaloosa, Alabama is an integrated facility (i.e., it produces gasoline.
 diesel fuel, asphalt, etc.) processing 28,000 barrets of erode oil per day, and recycling 9.000 barrels of heavy
 crude to the coker (45,000 barrels/day crude capacity, according to the Annual Refining Survey in ihe Oil'
 and Gas Journal published March 18.1991). Total area covered by the facility is in the neighborhood of
 150-175 acres.  The refinery was built in 1946: the wastewater treatment plant was built in 1975. and
 upgraded to an activated sludge system classification by aeration in 1981.

 WASTEWATER TREATMENT SYSTEM

        In the past, the facility was permitted for a  land treatment unit to handle biosludge bottoms and
 K04&  After the implementation of the K04S-K052 land ban, the facility could no longer land farm  the
 K048, and instead utilized the Mobil OU-slodge coking process to recycle the K048 sludge (the coker had
 been built in 1981).

        The treatment train includes DAF followed by activated sludge biotreaimcnt followed by
 Clarification. Dairy btowdown from the DAF unit (which is an FQ38 waste) goes to surface impoundment
 #1, which already contains FD37-RB8 waste. Surface impoundment #2 would probably also contain both
 FD37 and F038, due to CPI separator sludges it receives. Some oil is skimmed off the surface
 impoundments and returned  to be processed along with etude.  There are two accumulation tanks used 10
 recycle K048 to the coker (K048 is batch loaded since not very much is accumulated on a daily basts).  Any
 water drawn off the accumulation tanks goes back to the WWTP for treatment.

        Since the 1986 TSDR Survey was conducted, some other modifications have been made, including
 rerouting the clarifier sludge to the feed stream into the activated sludge unit At the end of 1989, the
 Hunt Refining Company decided  to cease leaded gas production, therefore K052 is no longer generated.
 Alt leaded lanla were taken out of service, cleaned,  and tanks are now considered unleaded.  Chem Waste
 Management in Emelle, AL received those leaded tank bottoms in the past.

 PETROLEUM REFINING WASTE GENERATION                                   '

        The facility currently generates approximately 4^00-5.000 barrels (after settling out of
 waterMcwateriflg) of K048 annually.  These wastes are approximately 90% water.  Zero K052 is generated
 because Kant Refining stopped making leaded jasolinc-

        The facility anticipates that it will generate 386 torutycar of F037-RB8, based on results of
 sampling and soundings, how long the impoundments have been there, and other parameters. Testing of
'P037 and  F038 revealed the presence of about 1S-22 of the Appendix VIII constituents (40 CFR Part 261).
 The sludges in surface impoundments *1 and #2. which have a thick, oily consistency, are estimated to
 have densities of 100 Ib/tu ft and 65 IWcn ft respectively.  Surface impoundment #1 is about 15 years old:
 surface impoundment #2 is about 9.5 years old.  Using different assumptions as a means of calculating
 sludge generation or build-up  suggest that the sludge in the two impoundments that would be generated
 with the one-time cleaning may be in the neighborhood of 4.825-5,900 tons, but the volumes could actually
 be much higher or much lower.
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        Hunt Refining has identified some streams thai may fail the TCLP, but they are trying 10
 segregate them.  The benzene level in a stream entering one of the surface impoundments that feeds the
 wastewater treatment plant (output of wastewaier from surface impoundment to WWTP totalling 274.S
 tons$ear) has at times exceeded the standard, and due to the mixing rule, the entire content of the surface
 impoundment would be regulated.

 WASTE MANAGEMENT PRACTICES

        The new F037-F038 ruling will have a drastic impact On the refinery. The facility is in the
 decision-making  process where sludge handling is concerned. The full four years time span would be
 highly desirable,  and probably necessary.

        At this time, the facility is uncertain as 10 how the land ban will affect the amount of wastes
 generated.  The same amount may be produced, and this may depend on nature of the crude and degree of
 stormwater separation achievable.  The facility will be taking the two surface impoundments out of service
 and replacing them with tanks (possibly using a combination of 40,000 barrel tanks and an 80.000 barrel
 tank to allow tank cleaning without interruption of wastcwater treatment).  The estimated cost for this
 change is several million dollars. The facility is currently in the process of trying to determine where to
 place the tanks.  These tanks will generate a F037 sludge that wilt collect at the bottom and wilt
 occasionally have to be cleaned from toe tank, but it is unknown as to  how much or how often.  After they
 clean the surface impoundments, they may be able to better estimate the rate of generation.  Hunt
 Refining has submitted a closure plan for the surface impoundment #2 to Region IV and anticipate thai
 they will have (bur yean to close. The closure plan for surface impoundment #1 will be submitted in
 October of 1991.

        In the past,  waste sludge from the #1 clariGer was mixed with  KD48 wastes and landfarmed, due to
 the valuable nutrient contest (primarily ammonia, phosphorus) which aids biodegradation.  Biosludge was
 alw sent to the landfana for the same reason. The #2 clarifjer bottoms are blended on a continual basis
 with the KD4S, making all of it a listed waste. The facility is looking at separating these streams, and this
 is mentioned in die landfana closure plan. Biosludge adds no value to coker feed whereas  it was
 beneficial to the  Uniform, but the facility does not currently have a landfann for that waste.  On March 6.
 1991, a delay of landfann closure was requested. Once approved, the facility intends to begin making the
 process and equipment changes necessary to segregate the streams and  land/arm the biowaste.

       Hunt Refining is looking for ways to achieve more wastestream. segregation, including segregation
of stormwaiers.  Pan of the closure activities for surface impoundment  #2 includes further segregation  to
ease the need for storage.  The biggest need for storage space is for stormwater.  The majority of
stormwaier that falls on storage areas in the west pan of the facility is  drained through a NPDES
permitted firewalls and goes to the river.  According to the  1986 TSDR, this amounts to  169.354,000
gallons annually: All the stormwater that fans otto the processing section of the facility goes to
wastewaier treatment.

       It is hoped that the one-time generation of F037-F038 from the one-time cleaning of the surface
impoundments and F038 from tanks aa be recycled to the coker.  If this proves to be workable, sludge
from future tank  cleanings (after the STt have been replaced by tanks)  will also be recycled to the coker.
The fact that it is 10-15%  oa will make il desirable for recovery in the  coker. perhaps saving a million
dollars.  Although for the  large pan the faculty does not have a choice, it may be easier to treat K048 than
 RB7-F038 in the coker. because it is not as viscous (the KJM8 being mostly water). The oily silt produced
by the stormwater and process wastewater is 'messy to deal with*, and these F wastes may have to be
blended wjitt fuel oil before being recycled in toe coker. The facility will probably do away with CPI
separators when they build the tank.  Lm RB8 should be generated if CPI separators are eliminated. The
CPb are no longer used very much; they are not welt suited for the oily streams.

       Hunt Refining has contracted with ,CH2M Hill to discuss possible modifications.
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                                     F037 AND  FOJ8 VASTE  CAPACITY ANALYSIS:
                                          DATA USE AND TRACKING SHEET
                                                                                                         *3
                 Refinery:    Cross  Oil  -  Snackover Refinery
                 State:       Arkansas
        0
Pata sources available:

      _£ Petroleum refinery visits/voluntary submission

      _X National Survey of Hazardous Waste Treatment.  Storage.  Disposal,
         and Recycling Facilities (TSDR survey)

      	 National Survey of Hazardous Waste Generators

      	 Biennial report/state reporting requirements

      	 California hazardous uasce data base

      _X Petroleum refinery data base (PRDB)

      	 No-migration petitions


Basis for FQ37 and f038 waste estimation:

      EPA used data provided by Cross Oil  (Saackover Refinery) because  it was
      the most recent and the only source  that describes  F037 and F038  waste
      generation and management.  Other sources  were used only  in comparison
      with the refinery's data submission.

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                 F037  and  fpg8  waste  estimates:

                       F037  (routine) -  25  tons/year fron cleanout of the sewers, surge tank,
                       and clarifiers.

                       F037  (one-time) - 1  ton generated fron closure of stormwater retention
                       ponds.   These  ponds  will be  replaced .by  tanks, which will be cleaned out
                       every two  to five years; therefore, the  F037 sludge would not be
                       generated  continuously.

                       Cross Oil  does not appear  to generate any F036 wastes.

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Cross Oil and Refining
End of East 6ih
Smackover, AR  71762

REFINERY DESCRIPTION

       Cross Oil and Refining in Smackover, Arkansas is a refinery that produces primarily lube oils, and
has the capacity to process 6.770 barrels of erode oil per day according to the Annual Refining Survey in
the Ofl and Gas Journal published March 18,1991. The faulty produces no gasoline. The refinery is 68
years old, and the total area covered by the facility is 70 acres.

WASTEWATER TREATMENT SYSTEM

       Since 1986, tome modifications to the wastewater treatment plant have been nude. The five-acre
collection and retention pond has  been eliminated from the treatment train; the only input to the pond is
stormwater.  In the place of the retention pond, a 500,000 gallon surge tank (equipped with a collection
bath) win be used.  In addition, the facility has added another clarifier in front of the  DAF unit. The
driving force behind these modifications was the F037-F03S waste listing. The changes due to the sludge
rulings have made it more difficult for the facility to handle swings in process wastewater output; in the
past, tke retention pond handled the swings.
       Future pitas include changing the NPDES discharge point, as indicated in a new permit Cross Oil
is in the process of receiving.

       All process wastewater systems are now  segregated from stormwater systems.  .

PETROLEUM REFINING WASTE GENERATION   _

Current production rates of K wastes are:

       K048
       KD49
       K050
       KD51
       K052             Olfcyr

One-time deanings generate approximately 2£00 lb
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                                                                                                                                   sir
 WASTE MANAGEMENT PRACTICES

        K wastes are generated in the OAF unit, which is guessiimaied 10 require cleaning on a yearly
 basis, and in the API separator, which may require cleaning several times per year. The darifiers in front
 of the DAF units are periodically batch cleaned approximately on * weekly basis, generating FD37 waste.

        Cross Oil now ships K wastes to ChemWaste Management for incineration after dewaiering onsite.
 F037-F038 wastes will accumulate ia the 500.000 gallon storage tank and darifiers, and will have to
 periodically be cleaned out  These wastes vill also be shipped to ChemWaste Management. The BEF
 rulings will not affect management options.

        There are no changes planned ai far as treatment is concerned, except that the company is
 working on reducing the phenol content so the wastes on be landfilled. It appears,that one of the water
•treatment chemicals that is added as a Cocking agent is contributing to the problem.  Waste sludge from
 the facility is atypical in that there are onry two constituents that cause it to require treatment before
 landfllling..

        At present  FD37-F038 wastes are less expensive to manage than K048-K052 wastes since they are
 not yet banned tram landfills,

        At this time the facility has no plans to remove sludges from the collection and retention pond.

        The facility does not think thai  it Is possible to reduce FD37-F038  or K04S-KOJ2 wastes by pulling
 more of a load on the aggressive  biological units.     ~

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       CONTACT:



       PHONE NUMBER:



       CALLER:



       DATE:



       SUBJECT:
PHONE UW FOR F037 AND F038 CAPACITY ANALYSIS






 E. J.  Doherty (Cross Oil, Smackover,  AR)




  (501)  725-3611




  James Hsu




  9/12/91



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                                     FOJ7 AKD F038  WASTE CAPACITY ANALYSIS:
                                          DATA USE AND TRACKING SHEET
        .
  f ss
                 Refinery:    Lion -  £1 Dorado Refinery
                 State:       Arkansas
                 Data sources available:

                      . x FeCroleua refinery visits/voluntary  submission

                       _2 National Survey  of Hazardous Waste Treatment. Storage.  Disposal,
                          and Recycling Facilities  (TSDR  survty)

                       	 HaCional Survey  of Hazardous Waste Generators

                       	 Biennial report/state  reporting requirements

                       	 California hazardous waste data base

                       	 Petroleun refinery data base (FRDB)

                       	 No-uigration petitions


                 Basis for F037  and F03S vaste estimation?

                       EPA used  data provided by Lion Oil  (EL Dorado Refinery) because it was
                       the most  recent and the only source that describes F037 and F038 waste
                       generation and oanagenent.  Other  sources were used only in conparison
                       with the  refinery's data submission.
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                 F037  and  F038 vaste  «stlaates:

                       F037/8 (routine) - 600 cons/year from the equalization basin and sewer
                       cleanouts.


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                                                                LION OIL
                      1000 McHenry St.
                      El Dorado, AR 71730
                     REFINERY DESCRIPTION

                            The Lion Oil refinery in B Dorado. Arkansas is an integrated facility (t«., it produces gasoline,
                     asphalt, eic) processing 48.000 barrels of erode oil per day. according to the Annual Refining Survey in
                     the Oil and Gas Journal published March 18,1991.  The tout land area of the facility is 391 acres.  The
                     refinery was built in the 1920's, and the wastewater treatment System has been in operation since 1977.

                     WASTEWATER TREATMENT SYSTEM

                            Exhibit 1 presents Uie wasiewater treatment flow diagram at the Lion Oil refinery as submitted in
                     (be TSDR survey In 1986. Since then, some modifications  have been made. The storage impoundments
                     were closed out in 1988. A filter press (generating a filter  cake) was added to handle K wastes. "The
                     equalization basin was replaced with tank*, put into service in April, to handle dry weather process flow.

                     The facility has three stonnwater outfalls, and one WWTP  outfall.

                     PETROLEUM REFINING WASTE GENERATION

                            The toul estimated rate of generation of K04? to K05Z is 1.000 tons^ear (470.000 G ROW and
                     128.003 gallons of K051, according to the  1986 TSDR). The facility generates the same amount of K
                     waste* as ii did in the past.

                            Every time the facility cleans a tank, there is a good chance F waste may be generated.

                            There is no current estimate of F037 and FOJ8 wastes generated, but if one were to just 'pick a
                     number", ii might be on the order Of several hundred tons per year.  The company does not yet have a feel
                     for the rate of generation of HB8 Croat the equalization tank, which may require cleaning once every
                     couple of years, if the sludges from the closed storage impoundment were to be removed in future, this
                     would also generate RB7. An estimate of one-lime  wastes residing in Sis, etc., that would be regulated as
                     huardous if moved, would be 50,000-100,000 tons.

                            There is no preference as to production of K or F  wastes, save for the fact thai f wastes are not
                     yet land banned.

                            There is no waste "stockpiled* per se, but sludges cleaned  from ditches, sewers, links, and sumps
                     wOJ generate a lot of waste, and the facOiry does DO) really  know bow much will be generated until
                     cleaning is begun.

                            The secondary treatment waste from aggressive biological  units is not a TC waste, but it is a listed
                     K waste by the state of AR because filtrate is returned to the WWTP and the state interprets this to be a
                     mixed waste (although, the US EPA does  not consider it as such).

                     WASTE MANAGEMENT PRACTICES

                            The facility refinery, dewaters the K wasie in a niter press, reavers some oil from the filtrate,
                     sends the filtrate water to the wastewaier treatment plant, and sends the filter cake to a recycler.  The
                     recyder. Marine Shale and Aggregates, buns ihe wastes in  a kiln.
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        In addition to the filter press, sone paving has been employed to keep dirt out of the sewers and
thus lessen the volumes of K wastes generated.  In order to further reduce volume, to meet the land ban,
(and) to lessen the economic impact, ihe facility B considering installing a dryer for the filler cake.

        The various wastewaler treatment iaakj (e.g.. DAF, equalization Tanks, slop oil tanks) are cleaned
once every couple of years.

        f wastes will  be mixed with K waste and also he sent 10 Marine Shale lo be burned. In order to
handle the F wastes, the facility may have to run two shifts (rather than ihe current one eight-hour/day   -
shift).  Toe Btu content (1400 Btu/lb) of UK K and F wastes is not high enough for cement kilns. If Lion
Oil decided to install  the proposed drier. Btu content would be raised (but not to the required 5,000
Btu/lb  for cement kilns). Characteristics of the currently generated and stockpiled wastes are similar to
the K wastes, which pass TCLP.

     .   Treating to meet the land ban requirement has been considered. The problem is labs can't analyze
down to land  ban standards due to oil aad grease  content (Le., the detection limits are higher than the
land ban Standards). Lion Oil thinks they axM treat to meet the standards, but can't prove that they
could do so.

       The facility is currently in the process of obtaining a Pan B post-closure permit work plan 10
address the problem of residual waste sluifes that will be generated from one-time cleaning. .In the past,
dry weather flow generated some wastes tiat «itl probably need to be removed.  The volumes generated in
this cleaning are not known.

       The facility is in the process of segregating sewage waters in order to decrease volumes of F and K
wastes  generated. Measures they are taking to reduce F and K waste generation include paving roads,
keeping sand blast out of sewer system, and general improvement in housekeeping practices.

       Offcite treatment options are limited. The wastes do not meet  the Btu requirements for cement
kilos. In addition. Boiler and Industrial Ftveace (BIF)  rulings may possibly affect the available capacity.
Contractors they have contacted, such as Cbem Waste Management and Rollins, are either running at full
capacity or the equipment is not operating properly.  The  cost of off-site incineration is prohibitive as well;
the 'red tape* required for oa-site uttioerauon keeps it  from being worth the
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                                                                                                          ..S
                 PHONE LOG  FOR  F037 AMD  F03B CAPACITY ANALYSIS
CONTACT:          Chuck Hammock (Lion Oil. El Dorado, AR)

PHONE NUMBER:     (501) 862-6111

CALLER:           James Hsu

DATE:             9/12/91

SUBJECT:          Status of impoundments
Kr. Hatweck indicated that the refinery has submitted a workplan for a Part E
post-closure permit to address waste sludges that will be generated from a
one-tiao cleaning of the impoundment.   They replaced the iapoundaent with
tanks.  Mr. Hamock indicated that waste, sludge* probably accumulate in the
tanks.  He also Indicated that they will be closing a diversion pond and
replacing it with tanks.  He does not  have an estimate of wastes sludges
quantities from diversion pond clean out.
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2
                            F037 AND FOM WASTE CAPACITY ANALYSIS:
                                 DATA USE AND TRACKING SHEET
        Refinery:    Marathon  Fetroleua - Robinson Refinery
        State:      Illinois
Data sources  available:

      _X Petroleum refinery visits/voluntary submission

      _X National Survey of Hazardous  UasCe  Treatment. Storage, Disposal,
         and  Recycling Facilities (TSDR survey)

      _ National Survey of Hazardous  Waste  Generators

    .  _ Biennial report/state reporting requirements

      _ California hazardous vaste data base

      _25 Petroleum refinery data base  (PRDB)

      _2 No -migration petitions


Basis ,for F037 and F038 vaste estimation:

      EFA used data provided by Marathon Petroleum (Robinson Refinery) because
      it vas  the most recent and the only source thac describes F037  and F038
      wast* generation and management.   Other sources were used only  in
      comparison with the refinery's data submission.


F037 and F038 waste gsr^natej:
                                                                                                          SS Ji 
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                            OIL COMPANY
                ILLINOIS REFINING DIVISION
                ENVIRONMENTAL DEPARTMENT
                ROBINSON,  ILLINOIS  62454
                  PHONE (618) 544-2121
                 TELEFAX (618)  544-8116.
                      ALT. 544-2735
                 &ROUTINE
                             QURGENT, DELIVER  IMMEDIATELY
DATE/TIME'
TO-
COMPANYi
    TELEFAX NUMBERi    703-jZ/8-.266?
    FROM*
     tV» a/* transmitting ,£_ pages irKiuding^this cover page

    If transmission is incompletv, ceil (618) Stt-2121, Ext. S3t, or Ext.
    CDMMENTSi
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•91-39-07 13!36   MOC_ROBINSON_ENUIRO



                             F037/F038 Questions
 (1.0)     Waste Water Treatment  Facility

          1.1   Stt «tUch»d schematic.
          1.2   Sewers are  conblned.
          1.3   All process waters rerouted  to  Inlet to API  separator.
          1.4   F037/F038 regulations.
          1.5   Replace existing  activated Kludge system with above grade
                tankage.
          1.6   TCLP regulations.
          1.7   K04B-K052 waste stream* are  now shipped off-site for
                Incineration, prior treatment was conducted on-slte at the
                land trtataent facility.

 (2.0)     K048-K052 and TC Hastes
          	—
          2.1   K048-K052 generation rate 1s ZWTton per year and TC waste
                1s  > 10,000 ton par year.
          2.2   K-Vasts stream are Incinerated off-site and TC wastes are
                applied to  en-s1te lend treatmnt facility.  BOAT treatment
                system will  b« Incorporated  Into our system.
          2.3   None
          2.«   None
          2.5   None
          2.6   None
          2.7   Watte  Generated are dewatered and low Btu value.
          2.8   Unknown at  this tine.
          2.9   None

(3.0)     F037  and  F038 Waste*

          3.1   < SO ton per year.-^-J.. ; "•--• ••'.••-'.
          3.2   None
          3.3   N.A.
          3.4   -—
          3,5  On-aUe land treatment,  land  faan will require off-site
               disposal.
          3.6  Capacity Available.
          3.7  N.A.
          3.8  No

(4.0)     General

          4.1  Incineration
          4.2  Source Control
          4.3  Unknown
          4.4  No
          4,5  0*2 tines per year.
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                             Marathon
                             Oil Company
                                                                Illinois Refining Division
                                          Robinson. Illinois 62454
                                          Telephone 618/S44-2121
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(I *• •» llft m
                     July 9. 1991
Ms. Mary Compton
1CF Corporation
9300 Let Highway
Fairfax, VA  22031-1207

RE:  F037/F038 Questionnaire

Dear Ms. Compton:

Pleas* find enclosed the completed questionnaire regarding
F037/F038.
                     Sincerely,
                     David R.  Saad
                     Environmental Coordinator

                     DRSrckm

                     Enclosure

                     cc:  File
                      A subsidiary of USX Corporation
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                   (1.0)
        5
                   (2.0)
                   (3.0)
                   (4.0)
                                              F037/F038 Questions
Haste Water Treatment Facility

1.1  See attached schematic.
1.2  Sewers are combined.
1.3  All process waters rerouted to Inlet to API separator.
1.4  F037/F038 regulations.
1.5  Replace existing activated sludge system with above grade
     tankage.
1.6  TCLP regulations.
1.7  K048-K052 waste streams are now shipped off-site for
     incineration, prior treatment was conducted on-site at  the
     land treatment facility.

K048-K052 and TC Wastes

2.1  K048-K052 generation rate 1s ZOO ton per year and TC.waste
     1s > 10,000 ton per year.
2.2  K-Waste streams are Incinerated off-site and TC wastes  are
     applied to on-site land treatment facility.  BOAT treatment
     system will be incorporated Into our system.
2.3  None
2.4  None
2.5  None
2.6  None
2.7  Haste Generated are dewatered and low Btu value.
2.8  Unknown at this time.
2.9  None

F037 and F038 Wastes
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                             3.1
                             3.2
                             3.3
                             3.4
                             3.5

                             3.6
                             3.7
                             3.8
     < 50 ton per year.
     None
     N.A.

     On-site land treatment, land ban will  require off-site
     disposal.
     Capacity Available.
     N.A.
     No
General

4.1  'Incineration
4.2  Source Control
4.3  Unknown
4.4  No
4.5  0-2 times per year.

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                    F037 AKO F038 WASTE CAPACITY ANALYSIS:
                          DATA  USE AND TRACKING SHEET
                                                                                                       tf  <»
Refinery:
State:
Shell Oil
Illinois
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        1
                  PHONE IOC FOR F037 AND F038 CAPACITT ANALYSIS


 CONTACT:   .       Eric Peterson/Jay Rankin (Shell Oil, Uood River, IL)

 PHONE NUMBER:     (618)  254-7371

 CALLER:           Janes  Hsu

 DATE:             9/6/91 and 9/17/91

 SUBJECT:          F037/8 waste  generation and management


 The refinery's vastewater treatment system comprises the following units:

 Neutralization -- Bar screen --  CPI separators  -- DAP units -- Diversion tank
 -- equalization pond --  trickling filter  -- activated sludge -- secondary
 clarification -- sludge  thickener -•  lagoons -- SPDES outfall

 The CPI separators generate  an  F037 waste, which is removed at 30
 gallons/ainute.  This waste  is dewatered  using a plate and frame filter press
 resulting in  filter cake consisting of £0 percent solids.  The dry weight of
 the filter caked is 2 to 3  tons/day.  The estimated maxima heating value of
 the cake is approximately 2,500  btu/lb.

 The equalization pond was put in service  m 1955, and was cleaned in 1987.
 This cleaning generated  approximately 13,000 tons.  The equalization pond will
 be replaced by tankage in the future.

 Shell Oil,  wood River, does  not  have  an estimation of how much F wastes would
 be generated  fron sewer  cleanout.

 Currently F wastes are devatered and  sent off site to a hazardous waste
'landfill.   Once the F waste  land ban  becomes effective, the F wastes would be
 sent off site for incineration.
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                 Refinery:
                 State:
                                     F037 AKD F03B WASTE CAPACITY ANALYSIS:
                                           DATA USE AND TRACKING SHEET
Total Pecroleua - Arkansas City
Kansas
                 Data sources available:

                       _S Petroleum refinery visits/voluntary submission

                       _jj National Survey of Hazardous Uaste Treatment, Storage, Disposal,
                          and Recycling Facilities (TSDR survey)

                       	 National Survey of Hazardous Uaste Generators

                       ^_ Biennial report/state reporting requirements

                       	 California-hazardous waste data base

                       _2 Petroleum refinery data base (PROB)

                       	 No-oigration petitions


                 Basis for F037 arid F03B waste estimation:

                       EPA used data provided by Total Petroleum (Arkansas City, KS) because it
                       vas th« most recent and the only source that describes F037 and F038
                       uaste generation and management.  Other sources were used only in
                       comparison with the refinery's data submission.


                 F037 and F03B waste estimates:

                       In Total Petroleum's voluntary submission, they did not have an estimate
                       of F037 and F038 vaste generation; however, their schematic shovs that
                       an IAF unic is in operation.  Assuming they included the F03B sludge
                       from the IAF unit In their total combined K waste generation of 400 to  •
                       500 tons/year, then continuous F038 waste generation from the IAF unit
                       can be estimated at 250 Cons/year.  This estimate is obtained by
                       assuming the IAF unit generates as much F038 waste as the DAF unit
                       generates K048 wastes.  It does not appear from the schematic that any
                       other F waste generation occurs.'
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3
                                           Information Guideline Interview
                                               Total Petroleum, Inc
                                                   MOOS. M St.
                                          Arkansas City, Kansas 67(X)5-3568
                                                  (316) 442-5100
July 5,1991, 2:15 pm
Conversation with Patricia Morgan. Environmental Specialist
Conducted by Mary Compton

Land Area: 300 acres
Refinery Afe: 74 yean

1.0    Waste Water Treatment Facility

       1.1    What is your current configuration (schematic)?

       To be sent.

       1.2    How segregated is your system, slormwater vs. process water?

       50% or the stormwater joes to storrowater drainage, 50% goes to process water drainage; 100% of
       process water goes to process water drainage.

       1J    What modifications have been made in the last 5 years?

       In 1988 a drainage ditch was built and sealed with cement so that the storm water now goes
       directly to the outfalL Levelling and surveying of surfaces are continuous activities in an effort to
       segregate the stonnwater.  Cementing Is taking place within units to get rid of din in
       somarmnated  materials. Three of the ponds (including aerated units 3a and 3b) were cleaned and
       closed two hazardous waste surface impoundments in 1986. Ponds la and ib were cleaned as was
       pan of oxidation pond i Pond 3 was separated into ponds 3a and 3b, Aeration was added to 3a
       to insure active biological treatment. A surge control unk was installed before pond 3 to catch oil
       surges before they enter the system.

       1.4    What  were the driving forces behind these modifications?

       An effort to reduce the amount of water going to the API and, for financial reasons, an effort to
       generate less K wastes.

       1.S    What  future  modifications are planned?

       The cementing of the units and road grading and levelling will continue.  Lift pumps will be added
       at the lower units to  pump stonnwater to the siorrawaier ponds.  A general waste minimization
       policy is being implemented at the plant.

       1.6    What  are the driving forces behind these modifications?

       To reduce the load on the API  and to reduce the expense to the facility of treating hazardous
       waste.

       1.7    How nave the K048-KOS2. TC and F037/F038 rulings and land bans affected the facility in
              terms of modifications, operation, capacity, etc?
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       Class 1 and 3 modifications were, required for the RCRA permit as pond 3 contains TC wastes.  A
       centrifuge was previously used lo dewater the wasies.  Now a Tiller press is used on site (or
       dewatering and the wastes are sent off sile for incineration. The K wastes are currently being
       incinerated and other options (such as recycling to a cement kiln) are being explored. The
       lagoons were cleaned prior to the effective date o! the land ban so that these wastes could be land
       treated..  Aeration was added to the 3a lagoon and in extra aerator was added in case of down
       time on the first so that this unit would be considered aggressive biological treatment.

10    K048-KQ52 and TC Wastes

       2.1     What is your estimated rate of generation and land disposal of K048-K052 and TC wastes?

       None are land disposed. Approximately 400-500 tons of these wastes combined are generated.
       The TC wastes are only a small portion  of this number as only one source of TC wastes exists.

       22     How do you currently treat, recycle, or dispose of tbese wastes and are there any
               foreseeable changes in the treatment, recycling, or disposal?.

       The wastes were sent through a centrifuge for de-oiling and de-watering. However, because they
       were still fairly high in water content a filter pressing step was added and the wastes are sent off
       site for incineration.
       23
               How have the waste generation rates changed with the hazardous waste ruling and land
               ban?
      • They have not changed and the assumption is that they will remain the same.  Although filtering
       reduces the volume of the wastes, the addition of the filter aid negates this reduction. Waste
       minimization efforts have reduced waste volfllhe but the listing of additional wastes has resulted in
       no net change in waste generation.

       2.4     Have there been any upstream or waste water treatment facility operating changes to
              reduce the amount of these wastes generated and how effective are these changes?

       Zero-sample draw valves have been added and are very effective as they have a continuous purging.
       system, eliminating the need lo  flush  ihe valves prior to taking a sample. Efforts are being made
       (o dry-clean the units whenever possible to remove uncontaminated sand and debris prior to
       washing with water.  The sludge control tank was added to help keep oil out of the ponds and
       reduce the amount of benzene.                                          '
       15

       No.

       2.6
Will the proposed F037 and F038 land ban affect the amount of these wastes produced?
              How much of these wastes are stockpiled in containers or surface impoundments?
       All Of it is in surface impoundments, not in containers. An estimate of the relevant quantity is
       not available.  Since the impoundments were cleaned fast summer the amount is probably
       relatively small

       2.7    . What are the chemical and physical characteristics of the currently generated and
              stockpiled wastes (ie,, are the)- dewalered, do they have significant btu value, etc.')?

       According to the TC test, these wastes are not hazardous.  The pond bottoms are not classified as
       TC.wastes.  The btu value fluctuates, but for the FC07 and P038 wastes, the btu value is less than
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                    3.0
5000.

2.8     Mow will these characteristics change with any planned facility modifications and
        operating changes?

The answer 10 ibis question is not dear ai this point in lime.

FD37 and FD38 Wastes             ,

3.1     Is there a current estimate of the amount of F037 and F038 wastes generated?
No.

3.2


No.
Is there an estimate of the amount of F037 and F038 wastes stockpiled tit containers or
surface impoundments?
33     What are you currently doing with the stockpiled waste and what are your future plans?

There are apparently no stockpiled F037 and F038 wastes.

3.4     What are the chemical and physical characteristics of both the currently generated and the
        stockpiled wastes?

According to previous tests, none of the wastes are hazardous by TCLP.

3.5     What is your current treatment, recycle,lnd disposal methods in relationship to F037 and
        FD38 wastes?

In the past all of these wastes were treated and land fanned.  In the future they will be incinerated
oUsiie.
                            3.6
                                   What are the capacities of these treatment, recycle and disposal methods in relationship to
                                   F037 and F9J8 wastes?
                    4.0
The answer to this is not dear at this point. It appears that there could be shortcomings in
treatment capacity.

3.7    Are (here any planned cnanges, either physical or operational, to deal wjin the land ban
       and how wilt these changes affect K048-K052 waste generation?

Physical changes include conuneing enit segregation, cementing the units, and roadgrading.
Operational changes include completing installation of the Zero-sample draw valves and  recycling
the samples taken and putting them back into the system for treatment.

3.8    Is it possible to reduce F037/RD8 or K04S-K032 wastes by pulling more of a load on the
       aggressive biological units?

J"robab)y not.

General

4.1    What are your offciie treatment options and are there unique features of your waste that
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        would limit the trcatability options?

The only offsite option cnrrenily is incineration, which is limited by the btu value, which must be
less than 5000.  Recycling to a cement kiln may be an option, but it requires a btu value of at least
5000.                                                                   .

4.2     What modifications have been done or are planned upstream (o reduce the amount fo
        waste generated in the waste water treatment facility (e.g., pretreaiment, source control.
        segregation, etc.}?

Sec response to section 3,7.

4.3     Will the BIF rulings affect any of the current disposal options, onsite. captive, or
        commercial?

No. but if the cement kiln option is exercised, there could be some effect.

4.4     Is there a preference on producing FD37/P03S wastes or K04&KOS2 wastes in icrms of
        handling or disposal?

No. The facility is not generating any F037/P03S wastes.

4.5     What is the frequency of cleanoui for the various waste water treatment units (e.g., API,
        DAF, storage tank, surface impoundments, etc)?

The API and IAF units are cleaned annually. Tanks used in conjunction with these are cleaned
annually when possible and, otherwise, as needed. The hazardous waste tanks are cleaned
annually for their certification inspection? The surface impoundments are cleaned as needed,
which is seldom.
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MaTCK*
           TOTAL
           T otfll
                      Inc.
           IJOa SOUTH II (TIICT
           ARKANSAS CTTT. KANSAS S7OOS
                                                     MAIUHC AOQUCSS:
                                                      'O (OX SST
                                                  ARKANSAS CITY. KAMIA* ITDOS
                                                    July 8, 1991
                                                                                                  *l*
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MS. Mary Compton                                    s
ICF Incorporated
Office 471
9300 Lee Highway
Fairfax, VA 22031

Dear Ms. Compton,,

     Enclosed is  the  information you requested  during our conver-
sation  on  July 3,  1991 to complete the F037/F038  questionnaire.
Included for the  Total Petroleum, Inc.  Arkansas  City  Refinery
are:  1) Refinery Water Flow Schematic and  2}   Waste Minimization
Policy.

     If  you have  any  questions, please do not hesitate to call.

     Thank  you.
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                                           Sincerely,

                                       TOTAL PETROLEUM, INC.

                                       P. Oi> TTOC/tA
                                           P. A. Morgan  (\

                                           Chief Chemist
             cc:  PAL
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                   TOTAL PETROLEUM,  INC.

                Arkansas City, KS Facility

                     December 4, 1990



                 WASTE MINIMIZATION  POLICY


I.   OBJECTIVES

    A.   Compliance with RCRA regulations mandating that every
        generator of hazardous waste  "have a program in place
        to  reduce the volume and toxicity of waste generated
        to  the extent that is economically practical."

    B.   Economic benefits.by reducing waste treatment and dis-
        posal costs, raw material purchases, and other operat-
        ing costs may be realized.

    C.   Reduce potential environmental liabilities

    C.   Protect the public health and the environment

    £.   Improved public image
^ ^ £ j S

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            II.   ORGANIZATION
       '4
       '4
Although all employees will be involved in TPI's waste
minimization program, the program will be overseen and
administered by a program task force.  The task force
will consist of the following personnel or department
representatives on a volunteer or individual depart-
ment selection basis.

i.  Refinery Manager

2.  Manager of Operations

3.  Operations

4.  Process Engineer

5.  Project Engineer

6.  Laboratory

7.  Maintenance        __

8.  Safety

9.  Environmental
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           III.  GOALS AND  INCENTIVES
                    'At a minimum, the waste  minimization program task force
                    will meet annually to establish realistic goals for the
                    following year.  Accurate  production and.waste figures
                    will be mandatory to determine goals and to track the
                    program's   success.  All waste reduction efforts will
                    be thoroughly documented and be measured on a pound
                    waste/1000  barrel feed basis.  More frequent meetings
                    of the task force will be  conducted to assess the suc-
                    cess or identify any problems associated with the waste
                    minimization program.

                    The most  effective waste  minimization program will
                    require the input and participation of all employees.
                    Various incentives to promote cooperation, communica-
                    tion, and motivation will  be examined.

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                                                                                          n
       y
IV.   ANNUAL ASSESSMENT

     A.   Before  goals can  be  established,  a thorough assessment
         of the  facility's waste streams  oust be made.   The as-
         sessment  will identify  and  characterize the individual
         waste streams,  the processes  involved in generating the
         streamsi  the amounts  generated,  the inputs and outputs
         of the  different  processes, and whether the waste  is
         classified  as hazardous or  not and if it is hazardous,
         the characteristic!a) which make  it hazardous.  Where
         feasible, flow  diagrams arid material balances  will be
         employed  to assist the  assessment  phase.

     9.   During  the  assessment phase it will become apparent
         to the  task  force which waste  stream(s)  should   be
         given priority  with consideration  of the following:

         1.   Compliance  with current and future  regulations,

         2.   Costs of waste management.

         3.   Potential environmental and safety  liability.

         4.   Quantity of waste.  _

         5.   Hazardous properties of waste.

         6.   Ease of implementation.

         7.   Potential for  removing bottlenecks  in  production or

             waste treatment.

         8.   Potential recovery  of valuable  by-products.

         9.   Costa associated with potential  waste  minimization

             projects.
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                                                                                   fit
    The third phase of the annual assessment  will  involve
    generating waste minimization options.  Much of  the  re-r
    quisite knowledge will come from on-the-job experience
    and education.   However,  other sources  of background
    information such as published literature,  equipment,
    vendors, consultants,  and plant engineers and  operators
    will prove useful.

    Some generic waste minimization options to be  consid-
    ered include:

    1.  Substitution of less  hazardous  raw  materials of

        production.

    2.  More efficient technology and equipment.

    3.  Optimization of production operations and  proce-

        dures.

    4.  In-pl'ant recycling.

    5.  Changing plant practices  to generate  less  hazardous

        wasteuater.          ~

f
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-------
-     V.  FEASIBILITY ANALYSIS

         A.  A technical  evaluation of   the   proposed  options  is
             necessary to determine which if  any of  the options  are
"" '.          compatible with the  facility's operations and physical
-t            constraints and if the option(s)  will work.  A ranking
             of the various options in relation to technical feasi-
-)            bility will then be  performed helping to aid in the
,,}            identification of the most  desirable options.

....        B.  The options will also undergo an  economic evaluation.
'•!            The economic evaluation will consider capital and
'**            operating costs and 'any potential saving*.  Also,
             adjustment* for environmental and safety risks and
"1            liabilities will be  considered.
'-rt        .'•..:••
         C.  At the conclusion of the feasibility analysis, the task
—            force  will  make a  determination of   the  technical
             and economic feasibility of the various waste minimi-
             zation options proposed.  If'the  benefits outweigh the
             costs then a particular, option will be  chosen to be im-
             plemented.                                   '...'.


    VI.  IMPLEHENTATION                        .

         A.  Funding must be obtained 'for the  chosen option.

         B.  Options that do not  require  any additional equipment
             will be implemented  as soon  as possible.

         C.  Follow-up evaluations on the performance of the chosen
             option will be conducted periodically.       ,

         D.  Will be an ongoing program.

         E.  New production processes .will be  subjected to the as-
             sessment, technical, and economic feasibility phases
             before construction begins.
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                   OWN
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                            Total Petrol«um. Inc.    Arkansas City. Kans,
                                REFINERY WATER FLOW
                           DAWN.

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           QUESTIONNAIRE A       GENERAL FACILITY INFORMATION        .PAGE 30
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                                     F037 AMD F038  WASTE CAPACITY ANALYSIS:
                                          DATA USE AND TRACKING SHEET
                 Refinery:    BP Oil - Alliance  Refinery,  Belle  Chasse
                 State:      Louisiana
gss

                 Data sources available:

                       _x Petroleum refinery visits/voluntary submission

                       _x National Survey of Hazardous Waste Treatment. Storage, Disposal,
                          and Recycling Facilities  (TSDR  survey)

                       	 Rational Survey of Hazardous Waste Generators

                       _x Biennial report/state  reporting requirements

                       	 California hazardous waste  data base

                      . _a Petroleum refinery data base (PRDB)

                       _2 No-migration petitions


                 Basts for F037 and F038  vaste estimation:

                       EPA used data provided by BP Oil (Alliance Refinery) because .it was the
                       nost recent and the only source that describes F037 and F038 waste
                       generation and nanageaent.  Other  sources were used only in comparison
                       With the refinery's data submission.
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                 F037  and  F038 waste estimates:

                       F037  (routine) - 1,000 tons/year from cleanout of sewer and equalization
                       ponds.                                                  '

                       F037  (one-cine)  - 10,000 cons from closure of stormwater/process water
                       impoundments,  which had not been cleaned for about five years.  The
                       impoundments  will be replaced by tanks, which will be cleaned out every
                       tvo co five years; therefore, the F037 sludge would not be generated
                       continuously.

                       BP  Oil Alliance  does not anticipate generating F038 wastes.

-------
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                          Mo. m ta MMb*. Ifw ntn pupen a(.«w qualiia ta M g* «
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                                      F037 AMD  F038 WASTE  CAPACITY ANALYSIS:
                                           DATA USE AND TRACKING SHEET

                  Refinery;    Exxon -  Baton Rouge Refinery
                  State:       Louisiana
                  Data sources  available:

                       _S Petroleum refinery visits/voluntary  submission

                       _& National Survey  of Hazardous Waste Treatment, Storage,  Disposal.
                           and  Recycling  Facilities  (TSDR  survey)

                       	 National Survey  of Hazardous Waste Generators

                        .jt Siennial report/state  reporting requirements

                       	 California hazardous vaste data base

                       _S Petroleum refinery data base (PRDB)

                       	 Ho-nigration petitions


                  Easts for F037  and F038 waste estimation:

                       EPA used  data provided by Exxon (Baton Rouge Refinery) because it was
                       the most  recent and the only source that describes F037 and F038 vaste
                       generation and  manageaent.  Other  sources were used only in comparison
                       with the  refinery's data  submission.


                  F037 and FQ38 waste estimates:

                       F037 (routine)  -  6.000 tons/year of devatered cake from an average
                       annual  clean out of 32,500 tons of sludge froa Impoundments.

                       F037 (one-tine) - 30.000  tons in catch basins.
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-------
JU*-2~-19Si 13; 12 PBCM S-:.-CH SS.
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               COMPANY USA
            FACSIMILE


       TRANSMISSION FORM
     iNc21|<99l
                     PAGES TO FOLLOW
                             PLEASE CALL
covea
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    1C F- INC.
WTURK OftKIKU: TES
           IF YES, NAKl MO ROOK
                                ROBERT
                                EXXQN CMPAW USA.
                           i Itel 656-5049
                          MtP<:ut
                            KtCHllff
                                                        4

-------
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       9
                           MPANY USA

                           • NOUSTCn.tlXXTnSl.2tW
                                                         June 27.1991
                By Pax
                Mr. Jamwt Hsu

                iCF.lne.
                930O LM Highway

                Fairfax, Virginia  22031


                Dear Mr. Hsu:  '


                Enclosed are tha completed F037 and F038 questionnaires for fha Exxon Baytown and

                Baton flcjuge refinartas.


                Pl«asa call ma at (713) 656-5049 if you hava any questions.


                                                        Vary truly yours.
                                                        Robert M. Nolan


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JU4-26-1991  13'
                   WASTE WATER
                                      DOCN ISO IfC BOTOI FCUE  TO


                                           Exxon Baton Rouge Refinery
                                                                           3ESE£677   P. 82
                   tWtaf ft ro«r eunat eenOguntfen?
                   SM ttt«ch»d
   •«BO Roupt
                                    »«*•*
                   N« dtnHfetm mo««e«lcn« in tht latt I ytwi.
                   N/A
    eonttterino tp8i dhtreh
                                                             	
                                              snd itofntwctef te$f9Qvt>Ofl
                   NiSHAPS «ntf TC witttwttW.
                                      «nd prim«rrf!v0Q* oonc«m» «nd irwttiUno tMmnt Mrtpptr for
                   TC, Wnwy Shirfot tod BMONW NS8HAP8 ru**.
                   Pert A p*rmh* htvt bten fiM on «urfac« knpotndmtm* tfut to TC/Pricrwy $mtfgt rales.
                   fMkwry Is punwing wort tggr*$*iv« dtw*teifn0/tftoiliflfl
                   KD4B-K    and TC
   Itott of o^nrrton for K w
                                            utimtttd to be 1 TOfc vnt ton«/yr (20-2Bk diwaterad
                                            ortoBOATtrtMmomerneycrina. For TC teW
                                             . •ntoImddtepOMl. Refinery prooM* w«tt*w«ttra •«
                   ewrtotfy TC hBontow •nd* in ownaovo' to KPOES trMOiMRt tyttom Impoundment*. TWs
                   v«lumoi>«etlinitidtota13mHonton*/vMr. Until feeXtiM to oompfywWiBenxtnt
                   NeSHAP8ra9uMonoMvon4netntfdem«r«tr«t«tf»yDwieff«eth«(y mduoe beraetM
                   below .8 ppm. meet WMtnrtten mat be ;ne«»^#d M TC Keurfoue wntet.
                   Mudgn awtfmrtteivd ons>tr, oT« are racovwod for !«finlng end remeWng toRd* «rt eem
                   for ofMt* ditpeeti 1^., tondfll. Indowetion or cwnem bin*, etc pending iludf*
                   Jj*i—Al.
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JlH-36-1991
                      F-:-CN •::. WISA            T

                      P04H US* IN: BPTTtM SQUQE TO
                                                                            P.34

                                                                3SSG6677   P. 83
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              wwtt
                                  flgftf MM Ifl* MflMftM MHft IV*VM4 IVXt
   tan?
   tontnten ntM htv» net chang^ •wbmtmictty. Agsmitvo dowattring/diolllna I*
   ntfudno velum* Mtn etflto. -CondnginB w tvriuttt optlora luch w Mtvtnt «xtr»ctioo,
   th«nr«l wwtmtm and othtr *Jv»ncwJ tMhnolegl ** to fgrtfiw wlue* tftepowltorw.
   ndbet 4»m*mt of (ftw* wntMftntntftf tf* *#w
          •on vorion to ita wnr
                           «n« oontimiing to tv^uct*
         sMflM from MfK«lmp9un«Mmiiavt not tunduTChnardoui. fnknracrf
   TCwMtMintinkafl»(t>nltWmt}i»7tkw«ttant (SM dtwiaratf tons). Cttlmntdlth
   Htu *>«t tont of K040 utd K0»1 wastn to 1 8-20k tent Ok devratmd tanrt,

        on Mv flftMitaf M^pAfitof cAMCfcMfef Of6>t tiftmwfgtiHntta tM
                    ,
   Aa gtMrtttt hv«hu wann «r» hiflft !«i wtt«f contint wHh no tignfficwrt btu vtK*.
            wH gignWemtly ntfUM vdgmt» to ba rantpttf. Btu vikM of dew»w«d
   mttfritte nwy or m«y net mwtf 5k.
                            sr

   WPW WBr cVAttl tinWCttnMwV CRflAfV IMw IV^pMNlWw ftO^Vy AMBnnDMWRv ttt9
   MqdHtertcnt meh a btravw NE8HAP8 facMtiw m^ « wetJy ratfuM votttOt
   eenMtttMrrts: tht •Iu40c wBI, hewtw, «tB b« en «ny miwtel. Btu vmh* m«y ta radgc«d.
   but DOt QUIIlUlMu
   Nona. §r*ttvaUVtte~iw»9t~«how it tfon net M TC.
   F037 tnd FO38 WASTES
          Y«, •peronmMHy 30-3BK wtt kv«itu tens (We dow
          trnpaundmcnt and rtfbwy MWW syattm catch ta«in*.
                                               on*) to thi turfict
                                                                                               2-a
                                                                                               Eon
                                                                                                        d
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.'•jh-"-:r51  13: U

 jw-!6-:99i  12:41  PCM
                          uea INC BBTCN ROJQE
                                                            36566677   P. 04
                                                                                                       I'!'-
tt «•« *t astfcatf* of fftawicuif off037ta4?OU wtstK i»c*pfcrf*t ocntafeaa or
XMm    cytpouffi
Yea. about 30k wtt iMtoi tew (6* ««w»tarad toa»l in a surtaca Iropowvimarrt and catch
basin* an) en additional 10-50* wtt hv*ftu tonHUk dawatacad tcn« ewnjinwJ in ttw
NPOS8 ««vtr «y«um.
       nimntfy »w»d In Mrfte* impowndmm. NPDE5 trMtmfot«ytrtm tank. *tf
Mwtrs. Currtmty pUnrtng to *»4C« lmixK«Jm»m »nd dwn out of »me •twtr» prior to
ttfldbtn,
ttoelipitdwittmt
Wattt* an currtntfy eocttvined in tha aurfwt hnpountfmtm and sawar baains, !t i*
baaioaSy an eBy atudge eoncwmtion whh lew btu vaiua. Cumntty gtnantad waiti li
dww*«K««and  aanc to orhhaiMrffltmattriali* 80-70* aofida. Metarial btu vilut may
or may iwt RMMt Gk/lb.
Currant mathod ia to ao^raMivtiy tfawatar, daeil tnd fandffl. Wfth landban. waata may
undacgc firttwr aggrtsiivt dawatafing prior to offato treat»n»nt
                       t»*tt
Currvtt eapcdty t» OmKad w oortraK dawatarinQ aarvtoaa. Cmrantly aaataalns additional
tachnalogy aueh aa ttannal daaorpdon/trvatnwn, aoivant extmctica ate.
    Cutvantly
                                      • 9f 9ptfftrOft9ff * O wMr WftR V99 Jlffv aMlf
                                       wMMMatnnfeff?
                              diwratartng/daollina tadvwto0^a and additional
upatratm watt* mWmJiatJen praetfcaa such aa aaMrar aaaragatfon and arotioh control.
Primary aMga tendban wM not affact IC04HCOB2 Qamration, howavar, traatnwnt and
diapoaaJ option* for *F* waataa may and up balng NmiMd to a«mt t» thoaa w« now use f or
*K" wastw, which may raduca cspawty avalabb for *K* waata atraems.
Bloloajcal ttwarant may ba an afftctiva tachndogy to traat tha onjanio conttituanb) of
ttaa waataa.  *nw aggrtntv* bMooJcat units, howavar, ara not dasfrnad to managa tha
addWenat toflda ajaaoeiatad wHh tfiaaa wattat. Addttiohaly. currant regutationa do not
allow a eaftyovar of Bstad wastva into downstraacn untw without RCftA ragulating tha
antin NPOES iiaaUnant train.
                                                                                                         a &
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       AH-96-1991 12*42 PSCM
                                  U9fi INC BSTtN ROUE
                                                        36565677    P.BS

 Primary Option la to aand ^ggrwrrt
 f« fttu v«Ii» wwtM w «mer« tftw •* • finl.
          K04»4M8t wMtn M BWMtad at apKHIo point tourets tnd wwt« htixfling JteilWtt
          •rteurrcntfystt up to h«id)aOWMvvMte*trMm$ttihoM location*. Ifthenwnaway
          totNftthag«wrtonof P087ff03« wute« to thtwpcinti.lt wotfd fadtatt handing.
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            JlW-21-1991  VIS  R5EJ1  BOON iSR IK BOTCH RQUZ TO
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                 PHOSE LOG FOR F037 AND F038 CAPACITY ANALYSIS


 CONTACT:          Robert Nolan  (Exxon:  Houston, TX; Baytown, TX; and Bacon
                  Rouge. LA)
                   \
 PHONE  NUMBER:     (713) 656-5049

 CALLER:           James Hsu

 DATE-             9/10/91

 SUBJECT:          The use of cokers and thermal dryers Co recycle petroleum
                  wastes
Mr. Nolan indicated that the Baycovm refinery does not recycle petroleum
wastes using its on-site gasifying coker because the technology co recycle
petroleum wastes using this type of coker is not yet available.  The Baton
Rouge refinery cannot recycle petroleum wastes using its on-site coker because
addition of wastes to their anode-grade coke would degrade its purity.

The Baytown refinery had operated a first-generation thermal dryer,  but
discontinued the use of the dryer because of safety and operational  problems.
Mr. Nolan mentioned thst on several occasions oxygen leaked into the dryer and
caused explosions.  He indicated that major redesign of the dryer would be
needed to overcone the problems.

The Baton Rouge refinery is operating a new thermal dryer on a trial basis.
The operation has also encountered several problems (e.g., feed becomes tacky
during drying; heat transfer problems;  and cooling problems with the
residuals).   The vendor is redesigning the thermal dryer.to overcome these
problems.  The dryer at Baton Rouge is  rated to process 50 tons/day  of wastes,
but is currently capable of processing 35 tons/day.

Mr. Nolan indicated that DAT floats (K068),  which has a relatively high water'
content (average 82 percent vater), i«  easily processed in the dryer.
However, API separator sludges, which contain less water (average 65 percent
water),  is mechanically more difficult  to process.  Primary sludges  (F037  and
F038), which are similar to API separator sludges, would also be more
difficult to process u^ing the thermal  dryer.

The thermal dryers are classified as recycling/recovery units and are  exempt
from hazardous waste permitting.  The most time consuming activities for
starting up a dryer is to construct a concrete pad to support the dryer and to
obtain an air permit.

Exxon's objective in using .thermal drying is to reduce waste volumes rather
than neet BDAT standards.   Since the operation of thermal dryers have  not  yet
Exxon's expectations,  the company has not ruled out other vaste recycling
technologies,  such as solvent extraction and thermal distillation.         •

Mr. Nolan also indicated the surface impoundments in Baytown and Baton Rouge
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           would be  dredged before  the F vaste land ban.  There arc no future plans to
           elose these stornvater inpoundaen;& since they are an Integral part of the
           wasteuater treatment process.  Hovever, Exxon is planning to segregate these
           storavater impoundments  so that they will receive only vet weather flows.
  •J

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                    F037 AND F038 WASTE CAPACITY ANALYSIS:
                          DATA USE AND TRACKING  SHEET
  ss
Refinery:   Murphy Oil - Meraux Refinery
State:      Louisiana
Data sources available:

      _X Petroleum refinery visits/voluntary submission

       x National Survey of Hazardous Waste Treatment,  Storage.  Disposal.
         and Recycling Facilities (TSDR survey)

      	 National -Survey of Hazardouo Waste Generators

      	, Biennial report/state reporting requirements

      	 California hazardous waste  data base

      _S Petroleum refinery data b«»« (PRDB)

      	 No-migration petitions


Basts for F037 and F038 uaste 
-------
                                    MURPHY OIL USA, INC.

2500 E St Bernard Highway
Menus, LA 70075                            .

REFINERY DESCRIPTION

       Murphy Oil in Mereaux. LA is • refinery thu produces primarily gasoline, kerosene, #6 oil, etc.,
processing 97,000 barrels of crude oil per day, according to the Annual Refining Survey in the Oil and Gas
Journal published March 18,1991.  Toe refinery site is 70 years old (Murphy Oil acquired it in the 1960's).
The total area covered by the facility is 564 acres.

WASTEWATER TREATMENT SYSTEM

       Since 1986, some modifications to the wasicwater treatment pUnt have been made.  The driving
force behind these modifications was the legislation of HD37-F038 and TC wastes. In the past, the stream
from API separator was sent to the equalization baste first, but it has been rerouted directly to the units
to avoid PQ37-HB8 waste generation.

       Murphy is considering replacing the API separator with a modern covered CPi separator.  The
cover would preclude volatile emissions, «nd the existing API unit cannot be covered. The same volumes
of waste would be generated in the API or CPL

       The Surge Basin does not receive dry weather Dow, and therefore Murphy Oil believes it to be
exempt.

PETROLEUM REFINING WASTE GENERATION

       K waste {eneration currently totals to 2000-2200 tonsftear.  The elimination of the equalization
basin wOl lessen generation of F wastes.  However, when the basin is taken ont of the treatment train, this
win have IB aflea on the stream catering the DAF units.  The resulting impact on the K048 waste
generation is not yet known, but is anticipated that KD48 waste generation will increase significantly.

       The BKfliqr has not yet treated or disposed of any F037-FBJ8 wastes. Dredging from the units that
would possibly be generators of F wastes was highly infrequent la the past. If the equalization basin and
surge basin had to be cleaned, it is estimated they might generate 400 tons and 1,000 tons of sludge,
respectively.

WASTE MANAGEMENT PRACTICES


       K048-KD52 wastes were first disposed on a landfium, which is now closed. Then they were sent to
CbemWaste Management Currently, doe to BDAT, they are recycled to a commercial otttiie cement kiln.

       The equalization basin and surge basin would typically be cleaned once every six years at most
The facility does not have any frmmiHwl wastes  to manage. The wastewater treatment units (e.g. API,
DAF) that would generate K wastes were also very Infrequently cleaned.

       Most changes thai would affect F or K waste generation at the Murpby Oil facility in Mereaux are
stffl in the planning stage. No further wasiewater system modifications or upstream modifications affecting
F and K waste generation have been initiated. There as no preference in terms of handling or disposal of
F or K wastes,

       A Waste Reduction Program is submitted  annually.
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5!
                             F037 AND F038 WASTE CAPACITY ANALYSIS:
                                   DATA USE AND TRACKING SHEET
         Refinery:
         State:
            Total Petroleun
            Michigan
f.la.3 Refinery
Data sources available:

      _X Petroleum refinery visits/voluntary submission

      _x National Survey of Hazardous Uaste Treatment.  Storage,  Disposal.
         and Recycling Facilities (TSDR survey)

      	 National Survey of Hazardous Waste Generators

      	 Biennial report/state reporting requirements

      	 California hazardous waste data base

      _J£ Petroleum refinery data base (PRDB)

      _ No-migration petitions


Basis for F037 and F038 waste estimation^

      EPA used data provided by Total Petroleun (Alma Refinery)  because  it was
      the nost recent and the only source that describes F037 and F038 waste '
      generation and management.  Other sources were, used only in comparison
      with the refinery's data submission.


F037andF038 waste estimates:

      Even chough Total Petroleun has ah 1AF unit in operation,  they do  not
      report any generation of F038 wastes  because the  sludge is returned to
      the API separator where it reports as either the  K051 sludge or the oil
      layer that is recovered in the slop oil system.

      Total petroleum reports no F037 waste generation  from the  equalization
      pond because vigorous areation in the pond prevents settling of
      particulates.
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                              F037/F038 WASTE CAPACITY ANALYSIS - REFINERY INTERVIEW
               STATE:
         ]
         «*
               ADDRESS:
CONTACT: "%&-&



POSITION:



REFERENCE:







DATE: feifO
£>OfV -^
     TIME:



EXTENSION:
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               • CBI claims?



               - Fill out responses to »iuched inierview guide



               - Need 10 fax information to contact person?



               • Items contact will send:
               - Miscellaneous, notes:
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                                   F037 AND F038 QUESTIONS
                                                                                                                    -
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       We have developed a preliminary series of questions to aid in our understanding of how the new
       F037 and F038 waste fisting and proposed land ban will affect refineries. These questions
       involve not only F037 and F038 wastes, but expand to K04e-K052 and TC wastes, discuss past
       and future waste water treatment tacffity modifications, on site treatment, etc., in order for us to
       get an understanding of the whole picture and how everything interrelates. In addition to gaining
       an overall understanding of the issues, we want, to discover any unique problems or treatability
       issues that refineries may have associated with these wastes.  Please complete the questions
       below on separate pieces of paper and mail to Ms. Jo-Ann Bassl (U.S. EPA) before June 1. 1991.

 10    Waste Water Treatment Facility    '

       '•'    •    What b your current configuration {schematic} ?
2.0
      2.3
                 How segregated to your system, stormwaler vs. process water?
What modification* have been made in^the last 5 years?
    CUB-  T"Aje-a-v^itja-''^*v\_s      f.,  i
What were the driving forces behind these modificatfona?

What future modifications are planned?
                                                                      „„-(.«••- w.tt>
                                                                      --' *"• *
                WhatwetheoYh^twcwbermdff^modrfkaltons?

                How nave the KM8-KOS2. TC and F037/F033 rulings and land bans affected the
                faeBty In terms of modMcattons. operation, capacity, etc.?              ,  -.  .,.,
                ~             .XXt-Au**-  C'.'*-.-""-1! - &&-tc,_..-hr- iVaJ-^'t  J'-''-w   -7'
                What k your estimated rate of generation and land disposal of K048-KDS2 andTC
                waste*?      
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        2.f




       2-f


       tt
 Have there been any upstream or waste water treatment facility operating changes
 to reduce the amount of these wastes generated  and how effective  are these
 changes?   r •:•«-
            ,>»—I   iYvtl-i-v"s~  »-*C-*V
 How much of these wastes are stockpiled in containers or surface impoundments?

 What are the chemical and physical characteristics of the currently generated and
 stockpiled wastes fie. are they dewatered, do they have significant btu value, etc.)?
iVjs, MVJL* 0>--.«<	-aOU-d O,f«_-^.L-+»^<— (if CSiUCt
 How whrftese ch'an&er^bcs change' wfth'any planned facility modifications and
 operating changes?
        2.\  •    What quantity of your secondary treatment waste, such as  sludge from  the
                  aggressive biological units, is categorized as TC waste?

•  3.0   F037 and TOM Wastes

        3.1   •    is there a current estimate of the amount of F037 and F038 wastes generated?

        3-2-  •    Is there an^estimate of tf»amoUn'ftilrF037 and F036 wastes stocVpiledSn containers
                  or surface impoundments?     _ , -v_

        3-3   •    What are you currently doing with the stockpiled waste and what are your future
                  Wfwt are the chemical and physical characteristics of both the currently generated
                  and the stockpied wastes?
       3.;
What is your current treatment recycle or disposal method and how will this change
with the land ban? -  •r'_A>j^\34-*Ov^-  o?*.sr-  er-  i-£...i— j^'.."^^^

What are  the  capacities of these treatment recycle and disposal  methods in
relationship to F037 and F038 wastes?
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      3.1
      3.S
4.0    General
      H-3
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Are there any planned changes, either physical or operational, to deal with the land
ban and how will these changes affect KQ48-K052 waste generation?
         \\£~<\£_                       .                     •

Is it possible to reduce F037/F038 or K048-K052 wastes by putting more of a load
on the aggressive biological units?
                 What are your offstte treatment options and are the unique features of your waste
                 that would limit the testability options? •
                                                       •
                                                                     _
                 W^"!.\_ Vu-Li-< *- •=>*•» •J>i->- /oi-ot r
                 What moarfications have been done or are planned upstream to reduce the amount
                 of waste  generated In the waste water treatment facility (eg. pretreatment, source
                 control, segregation, etc.)?  4r^  •i=-a-is.iv..4>.oJ3.'  finJfirc  e. ti
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 PTAV.  "PeTROL-BOPl  ACMA MICH.    WAfcTC FLOW     0^44QjQ
                    SYSTEM  * I
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                                                                                                                         i
                                     F037 ACT F038 VASTE CAPACITY ANALYSIS:
                                          DATA USE AND TRACKING SHEET
      i   -.
                 Refinery:    Chevron -  Pascagoula Refinery
                 Scace:       Mississippi
                 Data sources available:

                       _H Petroleum refinery visits/voluntary submission

                       _3S National Survey, of Hazardous tfaste Treatment, Scorage.  Disposal,
                          and. Recycling Facilities  (TSDR sunrey)

                       _ National Survey of Hazardous tfaste Generators

                       _ • Biennial report/state  reporting requirements

                       _ California hazarded waste data base*

                       _2S Petroleum refinery data base (PRDB)

                       _ No-nigration petitions
                       for F037
                                               st Imatton:
      EPA used data provided by Chevron  (Pascagoula refinery) because  it was
      the no*t recent and the only source that describes F037 and F038 vaste
      generation and nanagettent.  Other  sources were used only in comparison
      vith the refinery's data submission.
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F037 and F038 waste estinates:

      f037/8 (routine)  - 1,000  tons/year fron CPI and IAF units,  and from
      sewer eleanouts.

      Chevron reports no other  F wastes than those identified above.
                                                                                                                        C3
                                                                                                                        cm

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           TO:
         DATE:


         NAME:

         COMPANY:

         CITY:

         FAX*



         NAME:

         PHONE:
                                           A FAX FROIfc

                                          Chevron U.&A. Inc.
                                            P.O. Box 1300
                                      Pascsgouta. MS  39566-1300

                                         FAX #(601) 938-4230
                                                 or
                                            CTN 938-4230
                                                   Pascafloula Refinery
           ' Number of P«g«a (including covei):
. MESSAGE:
                                          /&ter-
                                  Confim>atk>n # (601) 638*4202 or 4228
                                                                             /
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                                                            '.; 4:3*4:30 :
                                                Pa»c«goul«, Ms.
                                                  June 21, i79i
  M».  Mary Compton
  ICF  Incorporated   •

  Reeponee to FO37 and  F03S Questionnaire

  1.0 'Maeff Hater Treatment facility

    1.1 Mhat ia youc current eonf inuration"'
      See  Schematic.
           segregated  it veuc s vet em.  ctormwater
      _        .
     Storm water and precmmt  watar  are totally  t»gr«g*tod.

   1.3 What modification* hava bg»p maijff ifl. ^ftf
                     • •
                       •
   Thr»« curfac* lmpouncJ«»nt» w*r« r»cnov»d  from ••rvie»|a
 •tar«M«t*r ditch warn cl*an*
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  2.0  K048-KOS2 and T£ Hastes
    2.1  a hat  is vour e«tm>ated rate of peneratjpn ana land
  disposal of KO4B-KOS2 and  TC 'wastes? 2^2 How fia you currently
  trea^. reeveljt or dispose  of these waaty and are there any
  foreseeable changes; in the treatment,  recycling or disposal?
    K043 is recycled in a closed  loop system.  Rate of
  generation  is 17,000 tons  per year.  K049 and KOS1 are
  recycled in the Mobil Oil  Sludge  Coking (MOSC) system.
  Approximately BOO tons are recycled •   KOS2 is generated at
  approximately 100 tons per year and is sent off -site to a
  Subtitle C  facility.   Approximately 200 tons of KOSO is
  handled in  the MOSC system or the waste water treatment
  system.  Approximately 1300 tans  of TC sludges are generated
  per year and  are  handled In  MOSC.

   2.3 How have the  Haste generation- rates changed  nith the
  hazardous waste ral/no ang land ban?
   TC has increased  hazardous waste classification  by 1700
  tons per year.

   2 . f Have there fcfiejl any uostreaun gc:-»ia«t» M«1;er  treatment
  facility operating chances to reduce |hc  amount; pj  these
 nastes oeneratcd and hop effective  arq  these changes?
   Me  have discontinued use of ««ndb«g«  to veal sewer drains
 during maintenance work and have gone to mats and Hater
 filled bags.

   2.5 mil  the, proposed F037 and FO38 land  Ban affect  1^hj»
 amount gf. theee wastes produced?
   Proposed  land ban for FO37 and F038 Mill not affect  the
 amount of TC or K-liated waste*  produced.            <
                                                                                        .-."
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       How much of thete waitus zrjc ctockoiled in. centainer
PP  surface i m pound men t «7
  None.
      Mha? 2.B How
                           change  MiJ^ any planned facll ttv •
    .
modi f i
  Does not apply.
              and operating changes?
  Zjyg Mhat quantity Qf_ ypur aecong'arv  treatmen Jfc waste,  such
a£. sladoe f roq> the anoreBSive^ biological  unite.  i«
cateaorizeif as TQ naste">
  "tone.

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   *;!• AH :r-3A
                                                                                     III
3.0 FO37 4Qd, FO3B
  3.J. |s there a. current estimate
FO3B wastes generated?
  Approximately 1000 ton* per  year.
                                     the •mount el FQ?7 and
                                                                                   « o 2,0
                                                                                   IK52
                                                                                    •ill
               an estimate p_f. thg amount al F037 and. F03B
washes stockpiled in contalngrK g£. surfaca impffundBiente?
  We do not believe that we have any «ludg*» in our surface
impoundment* that meet th« qualifications for F037 and  F03B.

•' ?j? Unat frj vpu currently flp^nfl tiilil tilft etockoilBd  waste
and what are yoop future plans?
    _  Mha^ apf fehu chemical and physical  ffharaetgrlstiea el
both the currently generated and the etoe)tpil»d  masses?
  RAM Kludge.

  3.3 Hhat if yeur current trgatment. recycle gf, disposal
method and ho* Mill this cfiano* irith the  land ban?
  Huch of the F057 end F038 waste* will be recycled  in the
MOSC sv*t««.  Some fflay be possible candidates for a  fuel
blending program in a properly permitted  off-site industrial
.furnace.  When land ban sets constituent  limits  on the
organic*, any off-site treatment/disposal will probably be
through incineration in a Subtitle C facility.

  2a& tiH4£ are- the capacities of these treatment,  recycle.
4DJt disposal methods in. relationship tg. F037 an.fl FO3B wastes?
  The M06C system was originally sized for the K-listed
wastes with some additional capacity for  characteristic
wastes.  The inclusion of Toxlcity Characteristic  and
F037/F03Q Haste will tax the system to its limit.  Any excess
will have to be treated and/or disposed in a subtitle C
facility. -Recycle priorities will b« based in part  on the
cost of treatment and disposal in off-site facilities.

      Are there- any planned changes, either physical or
             tq da«l with thf land ban and bow will
                                                                                       o
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changes affect KQ4B-K03S waste generation?
  No plans have been formulated at this time.

  3.8 if. ii. possible ifl reduce FO37/FO5B Qr. KO4H-KO32
feX putting mora of £ load gn. the aporeasive biological units?
  NO.
                                                                                      CD
                                                                                       CD

-------
4.0 GeneraI
  4.J Mhat are vour off»ite treatment options  and  arf there
unique features of vour w«ate that *ou^d  1 imit the
traatabiJitv ootiena?
  Solidification/encapsulation prior to laodfilling,  fuel
blending if BTU value i* high enough in A  property permitted
off-site industrial furnace".  There are no unique  feature* of
our w*«tP» that Mould limit the treatability option*.
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  4.2 Mhat modif ieation« haye heart done si arg plannad
up«tream to reduce the amount of xaate nengrated ic. tf;
water treatment facility tea, ore treatment, source  control .
segregation, etc. 1?
  Segregation has already been effected.  We are working
toward source control wherever possible.
  4.J Mill th» B^f ruling* affect any of the current di«po«al
option*. on*lte. captive or commercial?
  BIF rulings may .increase the cost of fuel blending as an
alternative to incineration.

  4.4 la there a_ prafgreoo on nrodueira FO37/FO3B  xantga or
K046-KC52 Ha«te^ ^n. terms of hand 1 ino gr disposal?
  Nona .
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      Hh«t i* the -f ranuanrv of cl»«nout for- the various xa«te
xater treatment unit* tea. ftP^. PflF. storage tank, surf »f»
impoundmentp. ate . >?
  Cleanout is dependent on operational parameters.  K048 is
recycled continuoualy.  API* areschedulvd to be cleaned., at
a minimum, quarterly.                              '   '

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                                    F037 AND F03B WASTE CAPACITY ANALYSIS:
                                          DATA USE AND  TRACKING  SHEET
                                                                                                                             o
                 Refinery:   BP Oil  - Lima Refinery
                 State:      Ohio
                 Data sources available:

                      _X Petroleum  refinery visits/voluntary submission

                      _£ National Survey of Hazardous Waste Treatment,  Storage,  Disposal.
                          and Recycling Facilities (TSDR survey)

                      _ National Survey of Hazardous Waste Generators

                      _1_ Biennial report/state reporting requirements

                      _ California hazardous vaite data base

                      _2 Petroleum  refinery data base (PRDB)

                      _ No-migration petitions
                                                                                                                       e ?
                                                                                                                       • S
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 to
                 Basts  for  F037 and FOI8 vascc estimation*:

                       EPA  used data provided by BP Oil (Lima Refinery)  because it was  the nose
                       recent and the only source that describes F037 and F038  waste  generation
                       and  management.  Other sources were used only in  comparison with the
                       refinery's data subnission.


                 F037 and F038 waste estimates:

                       P037 (routine) - 3,600 tons/year from stornvater/process water
                       impoundments, which will close with' waste in place.   The F037  sludges
                       would then be generated in tanks .

                       F037 (one-time) - 10,000 tons from closure of stormwater/process water
                       impoundments , which had not been cleaned for about two years.

                       BP Oil Lima does not anticipate generating F038 wastes.
CD
                                                                                                                        uu

-------
r
i :NT BYiXtrox Ttlicopiir 7021 '• 6-20-91 ;  |:2BPH i
                                                              iH22627*0-
        n
       3
                                                     BP OIL
                                                  UNA REFINERY
                                            1160 SOUTH KETCALF STREET
                                                LIKA, OHIO  45604
            DATE:  Jyi» gQt


              TO:
                                 Coanta
                            ICf. Incomoritad
                      FROH:
                            BP OH  - HM C«fln«rv
                     Tottl pigu being »tnt (Including thtt pige)
                                                                                 7032182669:1 1
                     If,th«r; Is • preblM i»nh thli ftx, pluu eont*et LeAnn Ktson,
                     (419) 226-2386 (ftx phew nu-fctr (419) 226-2740).
                                                                                                               •• **
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-------
. SENT BY;xtrcx Ttl»caoi
-------
SENT BYJXerox Ttliecpl«r 7021  !  S-2G-91 I  *:28PK
                                                 41822627*0-
7032162669;* 3
1.0   Vaste Vater Treatment Facility


1.1   See attached


1.2   Storawater and process water are currently conblned.
 i

1.3   Modifications to the sewer systee) 1n the last five years
 t

 ''     A.   Installation of a 54* - 60* diversion line froa the Korth sewer to
 ;         Prleary Pond (see attached).
 !         '         •            .

114   Driving  forces behind these Bonifications

 •     -    Reaoval  of one stomrater/process water Ispoundlng pond prior to the
 •         TC rule  taking effect
       1)5
        i
        i
        I
      •    Lower VOC emissions

      -    Envlronewital awareness by B? (proactive approach)


      Future codifications

      A.   Twin  2fH gal off-spec tanks are currently under construction and
          should be coMtssloned this fall.

      B.   Close Prlawry and C Ponds - replace with tankage and/or OTR
          lepoundemtSi then reeave both ponds fn» service.  ,


      Driving Forces

     A.   NESHAP/Benzena Regs

      B.  TC Rule/Primary Sludge
      1.7   A.
            8.
         K04S-52 land disposal  restrictions nave Increased disposal costs for
         these wastes.   The operation associated with the preparation of the
         Mterlal for disposal  Is anre t1s» consmlng and costs tore as well.

         TC rule - Increased costs associated with the davelopnant of closure
         plans for the two lapoundswntt that are required to be reeoved fro*
         service by 3/94.  The  replacement units will require significant
         capital expenditures for construction - also, swst find a suitable
         site of adequate site  for construction of new unit.
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-------
4MMP?t
        _SiNT 3w:x«r«x T«ticosi«r 7021 !  6-20-S1 !  i:29P« :          4192262740-          703218286918 *
                                                       -2-
                       C.  F037/38 • Preparation of a Cltis 2  Per»1t Modification  - this effort
                           will be required for the two Impounding ponds already destined to be
                           closed under the TC rule • duplication of effort due to overlap of
                           rulings.
                 2.0   K048-52 and TC Wastes
2.2   Rate of Generation

                   K048-K-S2

      w/o Sludge Dryer • 11-12  tons/day
                         or 4H  tons/yr
                       w   Sludge Dryer
                          5-6  tons/day
                         or 2N tons/yr
           TC

Nfsc. Dnns • 30 tons/yr


Fitter Clays- 75-150 tons/yr
                                                                                                                         8
                                                                                                                         KJ
O
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                 2.2
                  i
                 2.3
                 2.4
      KOU-52 wastes net ilnlm heating value criteria of 9,000 BTU/».

      Belt press cake Is blended  with  oil Into a heavy waste oil awtrlx and Is
      sent to a ceswnt kiln for resource recovery as a supplemental fuel.

      TC wattes are sent to disposal facilities for incineration or to be fuel
      blended.  Do not typically  landfill unless no other choice.


      Haste generation rates have not  changed with the hazardous waste ruling
      and land ban.  Vhen the sludge dryer  1s operational, the belt press cake
      should be reduced SOS (estimated).  With the sludge dryer operational,
      this will allow the refinery to  pursue a broker to handle the dried belt
      press cake as a product,  not a hazardous waste subject to regulation;
      under a recently granted  coker exception by OCPA.

      TC waste generation rates have Increased due to the TC Rule regulating
      two surface Impoundments  as hazardous waste management units. These
      wastes, however, are treited at  the wastewater treitaent piint.


      Upstream or wastewater treatatnt facility operating changes to reduce
      the aieount of these waste generated: •            >

      •  Elimination of the coke  pile
               Coke was previously stored on the ground prior to being
         (89)  loaded for sMp«ant (ZO-ZSX reduction In K-wastes generated)

      -  troluwn staging on a  concrete pad
               Previously stored  on the ground prior to handling
         (90)  (10-I5X reduction  in ((-waste generation)
                                                       uu

                                                       —i

-------
SENT BY:Xirex Tdmoitr 7021  : 8-20-H :  *:J9PH
                                                 41B22S2?iO-
1032162861:* 5
                                             -3-
       2.5   Proposed F037/38 land ban Mill  not affect  the Mount  of these wastes
             produced.  Evan though the origin  of  these wastes art fro« essentially
             the saw process, they currently can  be handled differently, I.e.,
             K-wastes nave LDRs and F037/38  do  not.  Also, the K-wastes do not test
             hazardous for lead or chroaw  under TCLP even though they are listed
             hazardous for these constituents;  therefore any and all wastes should be
             subject only to TC regs and handled accordingly.
                                                                                                         .« e Ss-o
                                                                                                          38-2
                                                                                                          a o.
                                                                                                     St
 2.6   X-wastes •  500 tons currently 1n Inventory at the Haste Pile Building

      TC tastes                                                        .

      •  H1sc. druu awaiting analytical  results (not significant)

      -  30,000 yd3 of stabilized sludge  1n 0-Pond (needs to be tested
         for TCLP).

 2.7   K-Hastas • ran through a belt press (sludge dryer not In operation yet)

      -  5,000 + BTU/f before drying process
         Again, they do not test hazardous for lead or chroae  analysis and to
         date shows TC hazardous for two  other constituents.

      -  Stabllfeed waste in D-Pond has been dewatered

      -  Doubtful as to significant heating value

      -  Still to be tested for TCLP


 2.8   Installation of a segregated NESHAP/Beniene sewer wy reduce TC
      characteristic noted 1n K-wastes  (needs  to  be looked at)  and will lower
      benzene loading to TC regulated surface  l^wundMnts.


2.9   Mo quantity of sludge froa the aggressive biological units Is
      categorized as TC waste.


3.0   FOJ7 and F038 Hastes
       3.1   Current estlntod aaeunt of generation

                                         lit Iriin
                                         ww^^^wra
                                         -f-tee-
      As noted In Part A
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-------
  SENT BY!X«rox T«ltcopi«r 7021 ! B-20-»l  '•  *!33PM !
                                                          41822627*0-
                                                                    7032182669:« 8
                                                                                                    IK
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3.2   There i* no amount of those wastes  stockpiled  In containers or surface
      impoundments.  Above estimates ire  for the TC  reguUted impoundments
      thit also fall under Primary Sludge regs.

      Question is —»  How will  these regs affect closed impoundments?
                 I.e., Are they subject to TC ind/or Primary Sludge?


3.3   There ere no stockpiled wastes,  but the wastes that accumulate In these
      impoundments prior to their reaoval from service will be closed In place
      through risk assessment,
8
          3.4   No information on pond bottom sludges subsequent to TC rule effective
           i     date.


          31$   Currently,  these wastes would be stabll Ized/tostod/sent to a Class I
                landfill  since no LDR$, but our Intent Is to risk assess by in-sltu
           :     closure.


          3;6   No Information available regarding capacities for methods of treatment,
                recycle,  or disposal for these wastes to my knowledge.


          3L7   The same  upstream changes for K-wastes Impact the generation of these
                wtxte*.   The origin Is the samet 1t is more a function  of where the
                wastes are collected.  The key 1s keeping the sewer loading of solids to
                a minimum.
           l

          3^8   Most K-wastes will test hazardous due to the oily constituents.
                Biological treatment has shown to be an effective means of treating
                these compounds.  Allowing more otty particulate pass through upstream
           ,     process units could potentially reduce K-wastos  and not have an adverse
           i     impact on wastewater.

          410   General

           t
          4'.1    In general, fuel blending Is proving to be a successful  disposal option
           '     for K-wastes.  Not certain why F037 and 038 are  regulated.   Is 1t
                benzene?  Are these wastes subject to TC regs as well?


          4i2    Source Control
           i
                •  Elimination of coke pile                •
                •  Trolumen staging 1ri a concrete  bay
               -  N£SHAP/Benzene imr
                                                                                                     CD
                                                                                                     UD

-------
SENT BY!X*rox TtlicoDier 7025 :  8-20-91  :  *:30PH ;
                                                      418Z2827«0-
                                                                         7032182889:• 7  ~
        3   BIF Mill have no  lipact.  If BIF IneorperaUt currtnt kHn, thin t ujor
4 4
      4 S
            nthlnk of K-wasto MnagMwnt 1s nitded.
            Prtftr to call  It F037/38 virtus K-wistt slnci thtr* trt no LOR*.  Mm
            LDRt tn final Iztd for F037/38 wittts. It Mkit no dtffortnct u both
            «v frw thi sot systM and not HkiTy that «1thtr  falls TCLP (at Itatt
            not what th«y art llittd for).
     Clianout frtqumcy - not on a sat schadula
     operation or for Mlnttnanct activities.
                                                          rtqufrtd for tff 1e!tnt
      6/20/Bl
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             BY!X«rox Tl!t«P3i«r 7021 1 8-20-S1
                                                        1192252740-
70321826B9!« 8

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ScNT BY:x»rox Tilicopiir 7021 :  6-20-91  :  4I31PM i
4182262740-
                                                                                 703216288B:« I  -
                                                                                                                   £53
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                                PHOM LOC FOR F037 AND F038  CAPACITY ANALYSIS


                CONTACT:          Gary Vonderembse  (B? Oil. Lioa.  OH)

                PHONE 8UHBER:     (419)  226*2744

                CALLER:           James  Hsu

                DATE:             8/19/91

                SUBJECT:          F037/8 waste generation and management
                Voluntary information cubmite«d to EFA reports 166 tons of F waste generation
                In surface impoundments.  This amount was underestimated and should be
                replaced by the following estimation:

                     BP Oil I-iiM estimates that 3,400 tons/yr of F037 sludge accumulates in
                     their impoundments.  These impoundments, which vill close in 1994, have
                     not bean cleaned out for about 2 years;  therefore, if the impoundments
                     are dredged prior to the land ban in 1992 will have accumulated 3 years
                     of sludge, which amounts to a clean out  quantity of 10,000 tons.
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                 Refinery:
                 State:
                                     F037 AND F038 WASTE CAPACITY ANALYSIS:
                                          DATA USE AND TRACKING  SHEET
Chevron - Cincinnati Refinery
Ohio
  e 5
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" -   2
g-x zo.z
*• a S • 9
SSS
                 Data sources available:

                       _jj Petroleun refinery visits/voluntary subnission

                       _S National Survey of Hazardous Waste Treatment.  Storage,  Disposal.
                          and Recycling Facilities (TSDR survey)

                       	 National Survey of Hazardous Waste Generators

                     •  	 Biennial report/state reporting requireaents

                       	 California hazardous waste data base

                       JS Fetroleua refinery data base (PRDB)

                       _ No-aigration .petitions


                 Basis for F037 and F038 uaste estimation:

                       EPA used data provided by Chevron (Cincinnati Refinery)  because  it was
                       Che nose recent and the only cource that describes  F037  and F038 waste
                       generation.and nanageaenC.  Other sources v«re used only in comparison
                       with the refinery's daca lubnicslon.


                 F037 and F038 wast* estimates:

                       So F wastes are generated at the Chevron Cincinnati Refinery because  the
                       facility has shutdown.
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        i
                  Refinery:
                  Scate:
                                      F037 AND F03B  WASTZ CAPACITY ANALYSIS:
                                           DATA OSB AMD TRACKING SHEET
            BP Oil  - Marcus Hook Refinery
            Pennsylvania
                                                                                                 Mi*«
                                                                                                 S**-3
                                                                                                 £S »» A M *?
Data sources available:

      _x Petroleum refinery visits/voluntary submission

      _x National  Survey of Hazardous Waste Treatment, Storage, Disposal,
         and Recycling Facilities (TSDR survey)

      	 National  Survey of Hazardous Waste Generators

      _x Biennial  report/state reporting requirements

      	 California hazardous waste data base

      _x Petroleum refinery data base (PRDB)

      __ No-migration petitions

      _x Comments  form proposed rule

      _ Organic TC Survey
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                  Basis for F037 and F038 waste  estimation:

                        EPA used data provided by  BP Oil  (Marcus Hook Refinery) because it was
                        the most recent and the  only .source  that describes F037 and F038 waste
                        generation and management.  Other sources were used only in comparison
                        with the refinery's data submission.
                  F037 and FO38 waste estimates:

                        F038 (routine) - 200 tons/yr  of  sludge generated from primary filters.

                        F038 (one-time) - 9,400 tons  fron closure of a surface impoundment.   The
                        surface inpoundment will be replaced by holding tanks, however,  these
                        tanks are cleaned out every tvo  to  five years, and thus,  the tank
                        cleanout sludge would be generated  periodically.

                        BP Oil reports no other F wastes than those identified above.

                        According to more recent Information from the comments to the proposed
                  rule, this facility indicated that  it  would generate the following quantities
                  of surface impoundment sludges during  the indicated time periods:
                                                                                                    ^.c

-------
                              6229
                                            IIES
SEW BY:
6-13-91 :  23:53  :
                                                       Iff. INC.-
                                                                            C&O03
                                                                           •••MM

                                                                412 281 5220;* 3/ S
                          F037 AND FOW QUESTIONS


Wa htv* davafopad • ftaflmlnary »«Ui or qu*«Vort* to aid h our undemanding of ftowma raw
POT and F039 wa*ta Siting and propoatd land ban wtt altoa r«finar/«». Thaw quartern
Involva flot orty POar and FOM waiUa. but a»pand to K044-KOK and TC waatta. dl«euaa put
art Mure waato wafer (rtctrrwrt (adHty modtncitlORt, on sha traatmant. tta. in ordar tor us to
ytt an undaraUAdBi^ of tfn wHol* plciura and now mfymtng lntafr«lat«a. In addKlon to gaining
an ov»*«n undanrtindlng ot tttt lasuav, wi want to dlacowr «ny unlqu* ptobtama or twMMHy
toauaa ttMl rtflrMrfaa may Mva ataoolitad wtm ttMM wasna.
     •    What ia your curtam oonOgundton (aehamado) ?

     •    Howaao/aflatadlay«ur«yatam.a(orRnimiMVf.proc«««t
          Cv*Pk(iA4I  4%aX1*****V**1 aw"^ ^*Vi>C4l| *f« — f«'~j   -v—ti  *^-w «•*./-««  -
                          .Wr  frwj*.--Jt« ••.•*-.  XWy4«,K«f r
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                                              Iff
  ,  INC.*       412 281 5220:* 4/ 5
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                                PHONE LOG FOR F037 AND F038 CAPACITY ANALYSIS


                CONTACT:          Colin Franks (BP Oil,  Marcus Hook,  PA)

                PHONE NUMBER:      (215) 499-7023

                CALLER:           Janes Hsu

                DATE:            9/12/91

                SUBJECT:          F waste generation and status of  impoundments
                Mr.  Franks  indicated that their primary filter generates 200 tons of F038
                vastes  per  year.  This facility originally planned  to dredge, close and
                replace their surface Inpoundaenc with tanks prior  to the F waste land ban.
                However,  they now indicate that this plan has  been  rescheduled until the
                spring  of 1993.
8
to
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>
                                       F037 AND F038 WASTE CAPACITY ANALYSIS:
                                             DATA USE  AND  TRACKING  SHEET
                    Refinery:   Chevron - Philadelphia Refinery
                    State:      Pennsylvania
Data sources available:                                              x

      _B Petroleum refinery visits/voluntary submission

      _X National Survey  of Hazardous Waste Treatment, Storage, disposal,
         and Recycling Facilities  (TSDR survey)

      _ national Survey  of Hazardous Waste Generators

      _ Biennial report/state reporting requirements

      _^_ California hazardous vaste data base

      _2 Petroleum refinery data base (PRDB)

      _ No-migration petitions
                                                                                                                              -*
                                                                                                                       •* o 2 a- o
                                                                                                                         sir
                   Basis {qr^fOB? and F038 waste estlnatlon: —

                         EPA used data provided by Chevron (Philadelphia Refinery) because it was
                         the most recent and the only source that describes F037 and F038 waste
                         generation and nanagement.  Other sources were used only in comparison
                         with the refinery's data submission.


                   F037 and F038 waste estimates:

                         F037 (routine) - 500 tons/year from sever cleanouts.

                         Chevron Philadelphia expects the F037 wastes  to be treated in an on-site
                         incinerator.

                         Chevron Philadelphia does not anticipate generating either one-time F037
                         sludges (no inpoundaents) or any F038 wastes.
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            Chevron
                    Chevron U.S.A. Inc.
                    PC. Boi ."408. Pfiaaoslpha. PA 191G1
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                                                       June 21,  1991
       3
      it
 ICF Incorporated
 Four Gateway center
 15th Floor
 Pittsburgh,  PA.  15222
 Attention: Mr. Kunal Banerjee

 Dear Mr.  Banerjee:
                  Keenest for voluntary information
                   Oa Petroleum  Refinery Wastes
                    EPA I.D. Kb. PADO<9791098

 In response to EPA's request for information on Petroleum Refinery
 Hastes, we are pleased to provide the following information.

                 ' Wast;cvater Treatment Facility

 o    What is your current configuration (schematic)?
     See Figure I.

 o    How segregated is your system,  stormwater vs.  process  water?
     Non-segregated system.

 o    What modifications have been made in  the last  5 years?
     Increased stormvater surge  capacity,  modified  flow pattern
     through separators and surge tankage, enhanced slop oil
     recovery  capability,  eliminated 2 separators , and modified
     separators to allow removal of  one half  for cleaning.

o    What were the driving forces behind these aodifications?
     Reduce NFDES exceedences and increase reliability  of ffWTP
     operation.

o    what future modifications are planned?
     upgrade sewer system to HSPfl as required by Benzene Waste
     Heshap,  cover roughing filters  and vent  to  a control device,
     and vent separators to a control device.

o    what are the driving, forces behind these aodifications?
     Benzene Waste Heshap Regulations.

o    Row have the K048-K052, TC and F037/F038 rulings and land bans
     affected the facility in terms of modifications,  operation,
     capacity,  etc.?
     Mo modifications or changes in  operating procedures are
     anticipated.
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                                       D48-K052 and TC Hastes
•
 What Is your estimated rate of generation and land disposal of
 K048-K052 and TC wastes?
 Generated - 8,500 Tons/Year
 Land  Disposed -  4,000  Tons/Year of  which 2,500  Tons  are
 incinerator Ash from on-site Incineration.

 How do  you currently treat,  recycle,  or -dispose of  these
 wastes and  are  there foreseeable changes  in the  treatment,
 recycling or disposal?
 a.   K049 - Hot generated,  X050  - Treatment at the  on-site
      Wastevater Treatment Plant, xosi - on-site  incineration,
      £052 and TC wastes  - Treatment and disposal off-site.
 b.   A Class XX  permit modification has been submitted to  EPA
      requesting approval for the treatment of K049-K052, ros?
      and TC wastes  through  the on-site Sludge incinerator.
      Modifications are planned to the incinerator that will
      accommodate all pnmpable materials. All unpumpable wastes
      (i.e.. Catalysts, refractory/ etc.) will still  require
      off-site  treatment and disposal.

 How have the waste generation rates changed with  the hazardous
 waste ruling and land ban?
 Ho changes in wasts generation rates but significant, increase
 in proportion  of waste classified as hazardous waste due to
 the TC regulation.   A waste minimisation program has  been in
 place at the Refinery sinee 1987.

 Have there been any upstream or wastewater treatment facility
 operating changes  to 'reduce  the  amount   of   these  wastes
 generated and how effective are these changes?
 Source control limits the  quantity  and types  of materials
 discharged to the  sewer system.  Xinimal   effectiveness  in
 reducing waste generation rates.

 Hill the proposed F037 and F038 land ban affect the amount of
 these  wastes produced?
 Mo.

 How much of these wastes  are  stockpiled  in containers  or
 surface impoundments?                     ,
 Zero   stockpiled - in  containers^  There   axe   no  surface
 impoundments at the refinery.

What  are the chemical and  physical  characteristics  of the
currently  generated and  stockpiled wastes  (i.e.,  are  they
dewatered, do they have significant BTU value,  etc.)?
Physical  characteristic* I   sludge  type materials,  10-15%
solids, not dewatered.

Chemical character is ticas
                                                                                                       "-* 2
                          BTU/Lb.
                          pB
                          Flash Point
                          Men Reactive
                     2.0 or < 12.S
                    > 140 "F
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How  will  these  characteristics  change  with  any  planned
facility modifications and operating changes?
Ho changes are expected.

What  quantity of  your secondary treatment  waste,  such  as
sludge from the aggressive biological units, is categorized as
TC waste?
Zero.

                  Ffl?7  and F038 Wastes

la there  a  current estimate of the amount of F037 and  F038
wastes generated?
F037 - 500 Tons/Year, P038 - zero.

Is there  an estimate of the amount of F037 and  F038  wastes .
stockpiled in containers or surface impoundments?
Zero.

What are  you currently doing with the stockpiled waste and
what are your future plans?
zero stockpiled.

what are the chemical and physical characteristics of both the
currently generated and the  stockpiled wastes?
see typical lab analysis attached.

What is .your current treatment, recycle or disposal method and
how will this.change with the land ban?
Materials ax* currently shipped  off-site for  disposal  in
landfill. With En  approval  of  our  permit modification,
materials will be treated through the on-site Incinerator.

What  are the  capacities of  these  treatment,  recycle and
disposal methods in relationship to F037 and  F038 wastes?
A permit  modification  has been submitted to BPA requesting
approval to treat 100%  of the 7037 wastes througl} our on-site
Incinerator.

Are there any planned changes,  either physical or operational,
to deal with the land  ban and how will these changes  affect
K048-XOS2 waste generation?
Modifications to the on-site Sludge Incinerator will allow for
the on-site treatment of all X049-KOS2 wastes. The volume  of
these  waste   requiring  off-site  treatment/disposal  will
decrease.

Is it  possible to reduce F037/F038  or K048-K052 wastes  by
putting more of a load on the aggressive biological units?
Ho.
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                                           General

               o   What are your  off-site treatment options and  are  the unique
                   features  of your  waste  that would  limit  the  treatability
                   options?
                   a.   Off-site  treatment   options  include  Incineration and
                        Solvent Extraction followed by Stabilisation for metals.
                        Treatment standards  and Land Baa dates nave not yet been
                        established for TC wastes or 7037/7038 vaates.
                   b.   Certain waste streams (i.e./ catalysts, refractory,  etc.)
                        are'unpumpable.
                                                                          s
               o   What modifications have been done or are planned upstreaa to
                   reduce  the  amount of waste generated  in  the wastewater
                   treatment  facility  (e.g.,   pretreataent,  source  control,
                   segregation, etc.)?
                   Source control, sealed sewers in benzene areas  (Bensene waste
                   NE8HAP).

               o   Will the  BXF  rulings  affect any  of  the  current disposal
                   options, on-site,  captive or commercial?
                   Kay limit our option of using certain waste oils as fuels at
                   our Boilerhouse.

               o   Is there a preference on  producing F037/F038 wastes or K048-
                   X052 vaste in terms of  handling or disposal?
                   Ho preference.

               o   What is the frequency of  cleanout for the various wastewater
                   treatment  units  (e.g.,  API,  DAP,  storage   tank,  surface
                   impoundments, etc.
                   A?I separators are  cleaned  at 2-year  intervals and storage
                   tanks at 10-year intervals.


              If you have any questions or need additional information, please
              contact our  Mr. Mike Manigly (Environmental Specialist - Waste)  at
               (215)  339-7466.
                                                     Very truly yours,
                                                     E. V. Schneider
                                                Supervisor - Environmental
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                  FIGURE    I

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        i
                    F037 AND F038 WASTE CAPACITY ANALYSIS:
                         DATA USE AND TRACKING SHEET

Refinery:   Chevron - Port  Arthur Refinery
State:      Texas

Data sources available:

      _x, Petroleun refinery visits/voluntary submission

      _5 National Survey of Hazardous Waste  Treatnent, Storage, Disposal.
         and Recycling Facilities (TSDR survey)

      	 National Survey of Hazardous Waste  Generators

      	 Biennial report/state  reporting requirements

      	 California hazardous waste  data base

      _g Petroleum refinery data base  (PROS)

      	 No-migration petitions

Basis for F037 and F038 waste estimation:

      EPA used data provided by  Chevron (Fort Arthur Refinery) because it was
      the most recent and the only source  that describes F037 and F038 waste •
      generation and nanagenent.   Other^ources were used only in comparison
      with the refinery's data  submission.
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                 F037 and F038 waste estimates:

                       Routine F037 vaste generation is from sewer cleanouts.   Chevron  did not
                       know the estimated sewer cleanout quantity; therefore, based on  sewer
                       cleanout calculations, EPA estimated the sludge  generation  to be .2,500
                       tons/year.  These calculations,  which are the sane  as  those.used for
                       several Category 2 refineries (see Appendix B),  are as follows:  •

                       (121.000 tons/year total K waste generation1}/^21.000,000 gallons/day
                       wastewater flow) - O.OOS76 solids loading of refinery

                       (0.00576) x (3.000 acres facility surface area)  x (143.7 tons/(yr/acre)
                       (for solids loading of 1.0 calculated fron known refinery)  - 2.500
                       tons/yr.

                       Other than the F037 wast* fron sewer cleanouts,'  Chevron  Port Arthur does.
                       not appear to generate any other F037 and F03S wastes.
                      1  Based on information provided  in the TSDR Survey submitted by Chevron,
                 Port Arthur.
                                                                                                       en

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                               F037/8 (surface inspoundraencs) -      0 tons  (7/92  - 12/92)



                               F037/8 (surface inpoundnencs) -  5,364 tons  (1/93  - 12/93)



                               F037/8 (surface iitpounditents) -      0 tons  (1/94  - 12/94)
        3

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Chevron
          Chevron U.S.A. Inc.
          P.O Bo» 701, Pen Artlw.TX77B41
                                          July 11, 1991
                                          QUESTIONNAIRE ON F037 AND F038 WASTES
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Mr. James Hsu
ICF Incorporated
9300 Lee Highway
Fairfax, Virginia

Dear Hr. Hsu:
22031-1207
In response to Ms. Jo-Ann Bassi's  (U.S.EPA)  request dated June  12, 1991, we submit to
you the following answers  to the questionnaire regarding  our refinery F Wastes:


1.0  Hastewatcr Treatment  Facility

     1.1  What is your current configuration  (schematic)?  See the attached flow
          diagram entitled "Vastewater Treating."

     1.2  How   segregated   is  your   system,   stonnwater   vs.   process  water?
          Partially  segregated.   Approximately 4.5  MGD treated  wastewater  and
          16.5  MGD   stormwater.    Proposed  plans  are  to  totally  segregate
          wastewater  and stonnwater in three years.

     1.3  What modifications have been made in the  last five years?

          A.   Constructed a new 5,000  GPH clarifier.  (S1.7MM)

          B.   Installed baffles 1n the oxidation ponds to reduce channelling.

          C.   Added  an aeration  system  to  surface drainage  and new  outfall.
              (J2.0MM)

          0.   Constructed  an  aeration  and biological  treatment  system to  the
              wastewater  drainage4 system.    (Hastewater  is  a nix  of  process
              wastewater and surface drainage).  (S2.0KM)

          E.   Changed  cooling  water  treatment  from a  chrornate to a  phosphate
              treating system.

          F.   Put  in operation an ammonia stripping system to remove  the ammonia
             from the wastewater system.   (S2.1MM)

          G.   Installed a water draw collection  system for all tanks.
                                                                                       §
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                                                                                      CTf

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 Mr. James Hsu
 ICF Incorporated
-2-
Jujy. 11,  1991
          H.  Implemented a  "Source Control" program which  Includes a department
              of employees who review problem areas in the  refinery and seek out
              solutions.

          I.  Installed  a  C02 injection  system in front  of  the  Bio Treatment
              Unit to control pH at the  No.  2 Storm Surge Sasin.

          J.  Constructed curbs,  slabs,  drainage systems,  etc.,  in response to
              the F wastes Primary Sludge Regulation..   ($5.OHM)

     1.4  What  were  the  driving  forces  behind   these  modifications?  NESHAP
          Regulations, TCLP  Regulations  and  Primary Sludge Listing Regulations.

     l.S  What future modifications are  planned?

          A.  Segregate the stormater and wastewater system.

          B.  Construct a new activated  sludge unit.

     1.6  What are the driving forces behind these modifications?   NESHAP,  TCLP
          and. Primary Sludge Regulations.

     1.7  How have K,  TC and F  Rulings  and  Land Bans affected -the  facility in
          terms of modifications, operations, capacity, etc.?

          A.  Implemented control  of all wastewaters.

          Ef.  Increased manpower  to comply  with  the  regulations  and  added  a
              "Source Control" department,

          C.  Proceeded with  a  three-year project  to  segregate wastewater  and
              stormwater.

          0.  Increased capacity of the wastewater  treatment  facility to  handle
              the additional  volumes.

          E.  Operational costs have and will have a significant increase.

          F.  Requirement to  obtain a RCRA permit.

2.0  KQ46 -  KOS2 and  TC Wastes

     2.1  What is your estimated rate of generation and land disposal  of K048 -
          K052 and TC wastes? In 1990, K wastes were 7,700 cubic yards.

     2.2  How do you  currently treat, recycle, or dispose of these wastes and are
          their any foreseeable  changes  in the  treatment,  recycling or disposal?
          Some K  wastes  are  dewatered  and  incinerated  and  the  remaining  are
          processed through  the  HOSC  system.   Plans  are  being proposed for  a
          thermal  treatment unit.  Presently a  contractor  is  mechanically sepa-
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                                                                 cn

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M«V*
             Mr.  James Hsu
             ICF  Incorporated
-3-
July 11, 1991   _
I"
                      rating  the water, recovering the oil,  and incinerating the remaining
                      solids of some of our K wastes.                    .   .

                  2.3  How  have  the waste generation rates changed  with  the hazardous waste
                      ruling  and land  ban?   The  wastewater  and process  water  have become
                      hazardous  wastes streams  requiring control  to comply with  the  new
                      regulations.  The amount  of  wastes  generated  is the same although the
                      amount  of  hazardous waste  has  Increased  due  to  the TC  and  Primary
                      Sludge Regulations.

                  2.4  Have   there  been  any  upstream  or  wastewater  treatment  facility
                      operating  changes to  reduce  the amount of  these wastes generated and
                      how effective are these changes?  The amount of total wastes generated
                      remains approximately the  same.   See 1.3 above.  An increase in hazard-
                      ous wastes have  occurred  due to new  regulations.   A "Source Control"
                      department and Primary Sludge Project have  been  implemented.

                  2.5  Will  the  proposed F037 and  F038 land  ban affect the  amount of these
                      wastes produced?  No.                   ,

                  2.6  How  much  of  these wastes  are —stockpiled in  containers  or  surface
                      impoundments?  Presently the  f wastes are not stockpiled.

                  2.7  Hhat  are  the chemical  and  physical characteristics of  the  currently
                      generated and stockpiled wastes  (I.e.  are  they dewatered, do  they have
                      significant  BTU  value,  etc.)?     Currently  generated  wastes   are
                      dewatered and sent to  landfill or  Incinerated.   The BTU value  is  very
                      low.

                  2.8  How  will  these  characteristics  change  with  any  planned  facility
                      modifications and operating changes?  No change is expected.

                 2.9  What quantity of your  secondary  treatment waste, such  as  sludge  from
                      the aggressive 'biological  units Is  categorized as  TC waste?    None.
            3.0  F037 and F038 Hastes
                                                                                    ._«.•*
                 3.1  Is there  a current  estimate .of the  amount of  F037  and F038  wastes
                      generated?    In  1990,  46,00(7  tons  of  Middle  Layer— Emulsion  which
                      resulted  in  3,700  tons ofcoke  after dewatering, _71. "tons  of  API
                      Separator  Sludge  after  dewatering,   160  tons  of Exchanger  Cleaning
                      Sludge after dewatering.                 *..:«•

                 3.2  Is there an estimate  of  the amount of F037  and F038  wastes  stockpiled
                      in containers  or  surface impoundments?  No F wastes  are  stockpiled.

                 3.3  What  are you  doing with  the stockpiled  waste  and what are your  future
                      plans?  N.A.
                                                                 o
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                                                                C3

                                                                cn

                                                                CO

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r
            Mr. James Hsu
            ICF Incorporated
                                                     -4-
                                                                        11,  1991
                                                                                                                        t s o
        3
3.4  What  are  the  chemical  and  physical  characteristics  of  both  the
     currently generated and the stockpiled wastes?  N.A.

3,5  What  1s  your current treatment,  recycle  or  disposal  method and  how
     will this change with  the land ban?

     Methods used are:

     A.  Centrifuge and incinerate (F and K wastes)

     B.  Recycle through MOSC system (K wastes)

     A change due to the land ban is not expected.

     A thermal treating unit is proposed for the future.

3.6  What  are the  capacities  of  these  treatment,  recycle  and  disposal
     methods in relationship to F037 and  F038 wastes?   MOSC 1s 100 bbls/day
     {K Wastes)  Centrifuge is 10,000 bbls/day (F and K Wastes)

3.7  Are there any planned changes either  physical or operational to deal
     with the  land ban  and how will these  changes  affect K048 - K052 waste
     generation?  No definite  plans other than possibly  a  thermal  treating
     unit on site.

3.8  Is  It possible  to reduce  F037-F038  or K048-K052  wastes  by putting
     more of  a load on  the aggressive biological  units?  No.   Presently,
     the units are close to capacity and additional volumes might constitute
     •scouring."
            4.0  General
                 4.1 What  are  your off site  treatment options  and  are the  unique  features of
                     your  waste that would limit the treatabllity options?

                     A.  Fuel  blending

                     8.  Centrifuge and Incinerate

                 4.2 What  modifications  have been  done  or are  planned  upstream to reduce
                     the  amount  of waste generated  in the  wastewater  treatment facility
                     (e.g. pretreatment, source control,  segregation, etc.)?

                     A.  Segregation of wastewaters within the next three  years.

                     B.  Completed modifications are:

                         1.  fteclrculattng sampling systems.
                         2.  A Source Control department
                         3.  Installed sour water ammonia stripper.
                                                                                                                      §:?
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            >)r. James Hsu
            ICF Incorporated
                                                     -5-
Jujy 11, 1991
                                                                                                                    * o 2 a- o
                          4.  Reduce water  usage when possible.
                          S.  Tank water draw collection system for a1! tanks.

                 4.3  Will  the 6IF rulings affect  any  of  the  current  disposal  options
                      onsite, captive or cooroerclal?  No.

                 4.3  Will  the B1F rulings affect  any  of  the  current  disposal  options
                      onsite, captive or comnercial?  No.

                 4.3  Is  there  a  preference on producing  F037-F038  or K048-K052  wastes In
                      terns of  handling or disposal?   The F wastes  can now  be landfilled
                      and the K wastes can  not.

                 4.5  What 1s the frequency of  cleanout for the various wastewater treatment
                      units (e.g.  API, OAF, storage tank, surface impoundments, etc.)?

                      API Is approximately  every' 2 to 3 years.
                      DAF 1s about daily-
                      Dirty water sumps about dally.
                      Tanks 1912 and 1913 - approximately every 2 to 3 years.

            If you  have  any  questions regarding  thlf response,  please  contact E.  H.  Rader  at
            (409) 985-1681.
                                    I
                                    o
                                    o-
                                                       1. L. Textor
                                                       Supervisor, Utilities
                                                       and Environmental Section
            £HR:1j

            Attachment

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                                     F037 AND F038 WASTE CAPACITY ANALYSIS:
                                          DATA USE AMD TRACKING SHEET
                 Refinery:    El Paso Refinery
                 State:    .   Texas
         Data sources available:

;*^             _s Petroleum refinery visits/voluntary  suboission

               _5 National Survey of Hazardous Waste Treatment, Storage,  Disposal,
rt                and Recycling Facilities  (TSDR  survey)

               __ National Survey of Hazardous Waste Generators

'.''             „£ Biennial report/state  reporting requirements

_^             __ California hazardous waste data base

               _X Petroieun refinery data base (FRDB)

"*             __ No-migration petitions
                                                                                                                       . & •*• i
                                                                                                                        2 " j
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                                                                                                                        i*
                                                                                                                          8
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                 Bails for F037 and F038 waste  estlpat;(,qn:

                       E?A used data provided by Cha El  Paso Refinery because  it was  the most
                       recent and the only source that describes  F037 and F038 waste  generation
                       and nanageoenc.   Ocber sources were  used only in comparison with the
                       refinery's data submission.
                 F03l7,,and F03B  waste estimates:

                       F037/8  (routine)  - 65 tons/year  from  cleanout of sewers  and  tanks.

                       The £1 Paso Refinery reports  no  other F waste than  that  identified
                       above.
                                                                                                                         «..*!

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      3.
      y
     i
                               FO37.AUP F035"
.  Q:
'-.'; A;
                           FAOUTV
          is V0u/e  C^X^EAJT  doMFi OujfJ AND UlSCJH AX'S 62) TD A
                                 SVSTE.M STB/«MW/»TE/£ v/s.
                                                      API.
 : A*
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                      SYSTEM IS *J01- SEGitEfiATED  AT ALL,
                  Muter  MOD, PICA no AJS HAVE. OEEW Mrtoe  /fcfTh£z/«sr 5
                  ALL O/*EW rowps HAVE. OEEU  ^EMOVEP. Two su*6E
                  A WEUTRAi.fZj»T)0*J  SVSTEJ^, AfJP  A
                  KECiAcutATiOAJ -SVSTFM HAl/E. 6EFW (WSTT^UED. A fot.tMEf.tS
                  APT>BI> "TO  tuASTFO/ATC*. TO ElOHAJ^CE  Ori>
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                                  LCAKA«E  C«MUC£K.(US  IMC ACT*
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                 At*. CMlSSrOMS  AWT)
                                                           •       .
                 OF THE AJEWJ F WASTE i-ia-nws J.EP TO *EMov/*t or
                            •
                       . OTHEA  MoPiPicA-nous  WE*E  *Eau««££> TO
                    MECT fonu LIMITS AFTt/e Sujtae  /"OAJTW
                                WOI>IPICATJOA«  A«e
                             *WSTJTKTJON> AWP
                  STREAMS  ro3sioi_e AfX. SEPA^ATD*
                 WHAT Atte.
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-	—j.._ 3>Ec*eA3ET>._Fi£xfaii.iTY _ Aw-p-iwcxEAses
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                                                   AWD.LAWP £> IS/" 03 At.
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      U
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       . Q:
~      ..    THE AMOUA/r
      ... A.1  Wo.      ....     	
 t
•*      '.. Q'. .HOuJ MUCH. OJ= THE^E  WASTES
               ARE. THE  OiEM iCA/. AWD l°«yS'[CAj_
                                                        AFTE.CT
     —I A'... K- WASTES- AieE.;DEifATE/esi},..(?e'Me'jeAu-Y HAVE
     ..;	&TUL.. l/ALUE
                                tfASTES (^St*AU-y.7>o AJCTT
                                ^._  ......
              tuijj._THE»£.CriA«.AcrErjeisncs CHAAXJE WITH  AA/Y
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                        A*£ THE -CHEMICAL AAJP /"HVS/CA-L
    Cu«*£/s/n.Y



          J3TU.
                                          - PASTES ___  .
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            is



     METHOD AWU
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                                               . A AJJ> . .t^ WDP* U~_TD M EEt!
:1 Q:  U/HAT  A*E_THe:. CAPACITIES OP
                                                                         WASTES
             ,j     &AfJ  AWI> .HOUJ-



             i| A'^0  I'lAWWED -CHAAJGCS, \»O  //W^ACT-OAJ -K WASTE
           	A.:
                      IT jOo5SlSLe._Tt)_«BDutE-F 0<. K. WASTES. 5X_ Perm MS
                  FE'A*TV«ES_C>F PASTEL. THAT L»MlTr.-ne.EAT"fl8'i/TV  OPnoMS ..
              A.'
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.JO,' tUHAT MODjF/CATlO/vS.HAVE fiEEW "PO/VE tfjC A/tE
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A: VES"
 -.-'••••                             '
Q'. 3~S _TH£KE._A-/'*£FEVeeAJCE. 0A->-ft€OE>OC/AX. F.UJftSTES .o£

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            IS .THE—F/^E.G^JEA-'CY- OF. CJ-CAUOUT.. FOK. VAJC'IOUS
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        •a
                                       P037 Mm P038 WASTE CAPACITY ANALYSIS:
                                            DATA USE AND TRACKING SHEET
                   Refinery:    Exxon -  Baytovn Refinery
                   State:       Texas     '
Data sources available:

      ^x Petroleum refinery visits/voluntary submission

      _x National Survey of Hazardous Waste Treatment,  Storage,  Disposal,
         and Recycling Facilities (TSDR survey)  •        .

      	 National Survey of Hazardous Waste Generators

      _x Biennial report/state reporting requirements

      	 California hazardous waste data base

      _x Petroleum refinery data base (PRDBJ

   .    x No-migration petitions

      	 Comments fron proposed rule                     • '

       x Organic TC Survey

Basisfor F037 and F038 waste estimation:

      EPA used data provided by Exxon (Baytown Refinery)  because it was  the
      most recent and the.only source that describes F037 and F038 waste
      generation and management.  Other sources  were used only in comparison
      with the refinery's data submission.


F037  and F038 waste estimates:                   '

      F037. (routine) - 10,000 tons/year from surface impoundments and
      separators; another 2,000 tons/year from sewer cleanouts.

      F037 (one-time) - SO.000 tons/year stockpiled in  stormwater
      impoundments; A3,000 tons/year stockpiled in refinery severs.

      According to more recent information from the TC  survey, this facility
indicated that it would generate cho following quantities of surface
impoundment sludges during the indicated time periods:

            F037/8 (surface impoundments) - 95,563 tons (7/92 -  12/92)

            F037/8 (surface' impoundments) - 95,000 tons (1/93 -  12/93)
                                                                                                                          o
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                          F037/8 (surface impoundments) -



                          F037 (routine) - 2.000 tons/yr.
0 tons (1/94 -  12/94)
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                   Refinery:
                   State:
                                       7037 AMD «38 WAST* CAPACITY ANALYSIS:
                                            DATA DSC AND TRACKING SHUT
BP Oil • Feradale  Refinery
Washington
                   Data sources  available:

                         _x  Petroleum refinery visits/voluntary submission

                         _x  National Survey of Hazardous Waste Treatment.  Storage,  Disposal,
                            and  Recycling Facilities (TSDR survey)

                            National Survey of Hazardous Waste Generators

                         _  Biennial report/state reporting requirements

                         u  California hazardous waste data base

                         _x  Pecroleua refinery data base (PRfiB)

                         _X  No-migration petitions                                            -

                         __  Comments from proposed rule —

                         _S  Organic 1C Survey

                   Basis  for F037 and F038 vaste estimation:          ,                       .

                         EPA used data provided by BF Oil (Ferndale Refinery) because ic was  the
                         most recent and the only source that describes F037 and F038 waste
                         generation and management.  Other sources were used only in comparison
                         with the.refinery's data submission.


                   F037 and  F038 waste estimates:

                         F037 (one-time) - 6,000 tons from clean out (5,500 tons from surge
                         basins  and SOO froa impoundment).   The surge basins will be replaced by
                         tanks, which will be cleaned out every cvo to five years;  therefore, the
                         F037 sludge would no; be generated continuously.

                         BP  Oil  Ferndale does not anticipate generating F038 wastes.

                         According to more recent information from the TC survey, this facility
                   indicated that it would generate the following quantities of surface
                   Impoundment sludges during the indicated time periods:   •

                              F037/8 (surface impoundments) - 1,040 tons (7/92 - 12/92)
                                                                                         Ill
                                                                                        !*f?H
                              F037/8 (surface inpoundnents) -
                                   0 tons (1/93 - 12/93)
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F037/8 (surface Impoundments) -    0 tons (1/94 - 12/94)

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        3
        3
        3
        3
                 PHONE LOG FOR F037 AND F038 CAPACITY ANALYSIS


CONTACT:          Dick Breaer (BP OH. Ferndale, WA)

PHONE NUMBER:     (206) 384-8243

CALLER:           James Hsu

DATE:             9/12/91

SUBJECT:          Status of surface impoundments
Inpoundnents at Che refinery are to be cleaned out and replaced with tanks in
the next few years.  Hovever, it la not feasible to clean out the Impoundments
before 1992, because the refinery ta not ready to stop refining operations to
accommodate clean out of the impoundments.
8
                                                                                                                           o
                                                                                                                           o

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                 js 9:
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                                                                                                                           .
                                                                                                                      SI..
                             F037/T038 fc-ASII CAPACITT ASAlXSIS - - IZ
           « on
           ae oil
                  STATE;

                  CQHZAkT:

                  ABBKESS:
                  comet:    Dick
                  posmmr:
                                                                                                                      -«.«
                    fiafliwry
           P.O. Box 8
                                                         PBQSE
                                                                          1-204-364-8243
SEEBUSCE:  Kla iad»r*oa, =«
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* *«**«
                                                             KE
                                                                                                 ^ JO.l
                      OIL,
                           TO37
                                                       F038 GOESHOSS
                   (T* turn G*r«lop«d * pralialaaxv »«ri«» o£ quudons  to aid la cur
                   uadaxceaadiag of hov  dia nav TO/31 aad F038 vuca lijclag jad proposad leal ben
                   will jiffacc nficariM.  QUM guaadein inralva ooc calj  FW7 cad F038
                   vu-ca*, bttc czpaad to D44-0>32 ud 1C v«c««.  di»eu«» poac cod tasus* vuct
                   V«CM: nuawne fieilley •a4t£iciciansr oa »it» trutacnt.  «cc..  la, order £er
                   u> to (*c «n md*nc*adlag e£ tfa» vtol* plccur*
                   ^iipmiiii»lM vac to discover auj"  »oiqc» problus or tr**ribilley t»«n«» tb»t rvfiuiica
                   »«y be** uaociBtcd vttta tlma macu.

                                                                                                         o
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                   l.t
1.2
                         Choc is jour  CULIBUL.

                         SM «.CC4uti>»d.

                         Hov mgncwad If yoor •JVCKI, stom ¥»c*nn. prDcvn* «r»t«rf
                         lbaz« era
                   ollj
                                                     : a. *tan *nmr cad tva prouu
                                                        d ta» ptunelic
                        Ho B«jor
                   1.4
                   1.3
                                      drirlag forea* b«hind
                        Boc
          ClXbCQpB VOdLCvG&tiO

          th* nazt few
                                                ths following vlll eccar:
                                          buliu •will ")>• r«pl»c*d rtch ehr«« *eor*g» twta.
                        - Hi* op«a AFC wit vill «ir*i«r b«  ctmnd or rcpUecd wich *
                        eov«z*d wale.
                        - Tb» OAT isilci will b* r*pUe«d vith. ladneod Air Floudoa ualcs.
                        - DM blo-era*c«r» vlll probably b* eonnd ad to* •ffluuc clr
                        will b* *«oe eo *u BceiTtcad uzbea (C1C) talc or co « vapor
                  1.6
      • S*ala will ba iarcallad on *«v«r aubela cormn.

         . «r« the drtTtag force* btbicd cawa a»dt21ea,cloiul

         HESEAP baoxBaa rola Bxi by tba 1C nil*.

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                  ;j.oo
                                    an
                                                 :CF JCE
                                                                                        a 001
            t.7   Sow hen th» K04S-K032, TC 4nd F037-F038 rulings aad land boas afftetad
                 ch» facility la t«a« of Dodi£ic*don*. cpaT«loa, capacity, ere.?
|   _
                 1C (aad HESHtf) caasad eha facility changa*.  Ih« C «nd f
                 Juse -^-Tittit ho* eha m*±»rt»l is haadlad.
2.0

2.1
                   -MM?     Tr ?ut»
                       » yoor
                 04 TC nacmla chaajpa In to* craatDaut. racycliag or dlcpoaalT
                                                                                                                   o
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                                                                                                                   LO
                               it.
                                    Is raatrietad Co
                                  .  Oaaal Uaate
vlthfa ttutlz
eaaa oa
           2.3
                 USA. Pus B pvmie.
                 aod prMMd th« cbtdc* s« dut th« 10000 bbl «£ taol K vista
                          is 1990 wu rwlacad to 736 bbl.  Thia ptMMd eak*
                                       ctunfed vidi ths> haurdaiu vest*
                 Ear hm tiw *s«t« g«o>r*rion
                       cad. lead bat
     1h* 9XM**d ok* h
     tb* «tz*«B of u»w
                                     « inch »«U«r ««!»••. utd such !*•* oil.
                                                 eaaltccat s^etm*   For
                    pl*. In 1989, •. £Uld scadj m» p«rfomad for tba
                Star* 0«p£. of EeoLaxr •• P«^t of a, Bo-1* cca
                b« doa» by ynaataft cbaa hot ««e*C vuUO( ttw eaka.  in t*»
                        , tfa* poopl* «t Eeolosj hroifl tr; tfaa ao-oigr*.cioa pacicion
                     ca d*eid« if « o«v fiald saitff la nqulzod.
                                                                                                                  en

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                                        ICF KE
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         Bar* thara b«*n my u?straam or
         cbaofaa t» raduca tha neune of
         ara ch*»e
vtttr tTMtaaac facility o?«rattng
	(•eatacad and bov **ficciv«
        Tea, tfaaca ha* b«an «oaa aauUloa braikiag aaiczaaa of th* BUTT.
        UJT»« UK bbL uaks «ak> «ee\ttulxt*d K048  unit*,  ttl* i« lurAd-nly d«v*t«r»4 aad allerad Co
        •«p«r«C*.  tb* oil pb«M t« r*cycl»d ta tfaa'cat cxcckar *p«rmcers ae ch« bcuodurj- o£
        procmu tnit,  bat cfait ejtton vu prohibitively cxpcndra, u
                   at tht ODTT, ;rw>lag tlu sludg* r*due«B tiw
        th» SOt oil wpOttaa U r.dac«d to A 12Z ell c*k«.
   2.S   Will cha prope*«4 T037 rf«e«
                                         ch«r«ec»ri«tlca of ttw eurr«atljr
                                                           .  do
                            , «ce?)
                     oka La 12Z ell. ad hu in«u£fl£t«at BTtT -vmlu* ,to
               u « hncdotu »»«• fu»l (IljdLt 1* 3500 MO/11).  Drying
           c«ka would <"**'-*— tiM BTU
  2.8   HowvlU
        ~>^***>'»^x««Tit *~* «.p»i «t-t»sg ebancmc?

        if a* fata
                                                    pl»nn»d facility
                                              !• r*pUe*d vitfa coto ,
                                              •MttdouiLy.  Al*«. oil
            t* •xometxd fciB a fcreicuUr vurei , c«a b« added back la to
       1nrr»i«a it* heads* T»!U«.
  2.9
    of your *Bcocdax7 tctanuat vuca, «och «s
 biologic*! tnita,  1* utacoclud u TC vacta?
                                                                    froa tt«
       KOB», it tvu ca
-------
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                -2t tl
                                                       ICF KE
                 WOU,

                 3,0
 3.1   !• tha» » cuzr»ne »«eis*c* of elui
       genarxtad?
                                                               of F037 ud F038
                       tt* bulk of th« f VUM vill con* £raa th» rurg* baaln boctomj.
                           trrvblnuA Z mat fjamt* . .»bould ba.&bcrue_£f.TB elm* tbcc of aha
                                         "
                                                   F038
                       Abouc 500 tan*.

                 3.3   BIM.C «e« yea cuzreatly dolnj with th» «todcpll«d
                 9.2   !• dm* a «rctm«c« o£ ti« uiauae of Ft) 37
                       «ont«±ti«t»  or «ur£«o«
                       Ic vlU b« Und ftzwd tatil this Is no lou«»r illovtd.   After
                       ti»c tc will ben co bt ahifpcd offiit* to to. incln§r»cor.  It
                       could «!M b* u«i la  th* b^urdooi fuel ptvgam..  this  lJ
                                   f iiiliff^rt*^ 111! ^ buc rtsulxftt A
                 3.4  Bh*c 4E» titi* rhanfril cad pbymlul ch*r«et«rti=tc« of both th» esxrtaciy
                      g»t»rjr«d cad tiui caeetyLLa vucu?

                      tc luw no «i(nl£tc«BC JTff valu* wtebeuz pruslag «ad diylag.  Ic
                      I* Bendy diet,  dUr, Mad, p«bbl«s nd rutt vlth TUJ  llttl* oil.

                 3.5  Ch«r is TOUT cuxnat mctavnc, neyel* or di*po*U. a«chod. in
                                   to  F037 ad F038 «uta»?
                      Lead faxvlBf.  One* dut Und b*a catiM Into efface tad If ' tb> no
                      Bt|z»clea petition 1* not fnac*d.  thu* v**eu will brr» ce b«
3.6  Vbafc «• cfaa op»elel»» o£ eb«««
     la r>1irf
-------
u* »e
          :j 01
                                         :CF
                                                                                                       .» e 2 t O
   a ou,  r*n4ii*, to.

   3.8
       Is Ic possible to ndssa F037/F03I or CO&J-K032 vistas by putting
       of « load on tJia aggr«*iT* biological imicj?

       Ho.  All sludgu «x» produced upsmsa of ch« bio units.  Th«
       inpaUtxs: an£ ptivps: cskft A bf.cizi£ j*u* yh* *£ficioo^y of ?*+ bijo
       uait* drop off if r&* upimaa unit* don't rvnor* «n«rugi of the
       •olid*.

 4.0

 4.1




 4.2





 4.3   BUI  tli* BIT ruLta^ «£f*et 07 of-efe* cm.T»at 'dispoMl option*, on»it«.
       C«ptiT» OZ CCIMII'Ctllf

       Bo.

 4.4   Is tbtt* a pr*f«mc« ea pcodaciaf F037/T03I VUCM in t«aa of
     4£O VIHUt OfftijCtt t^TSTTiSUff OptiOUV CBd SJTB C&A IBicVM fAA£tt7&S Of
     «ue» thae «eo]4 llale th* erucabilicr epdons}

                      kilft.

                  turn b*«a oooo or tr* plsnattf upsenuut eo rcdaca tha
      . of maco t»nari'»i1 in dia vuic* vacar truaMac facility («g.
pr»tr«»ta«nr.  fooru  control, iBfrcgadoa,  recr)

    .  It wu  too
                 «x» pr«f«rabl« imrtl th* l«nd b«a COM* into «£f«ct.
        Oth»rirt»»,  no.  It Ic bcxd «o uadanewd v!^ liad tr»*o««nt «
        poorly epuud; wby «w It lia^od tog«tb*r vith
                           «ero«» tha country ta  ha*"" **•
              enrwr«llT
                                                                                                             _
                                                                                                       o. a .- «
                                                                                                       '  S   !T
                                                                                                         8 is
                                                                                                           O
                                                                                                           o
                                                                                                           to
                                                                                                           o
                                                                                                           o
                                                                                                           U)

        Bb*c !• tb» fnqowKT- «f clua ouc for tba
              («g. in, DiT, ctenf* uak,  »arf«e»
                                                        wuc* mtar
                                                            . •«.)

      8b*c of tiMM *n clwowd ooe "-r-illy   Th« API «ad DA7 units a«y
    .  go tvo TMMTB tMx da*.  Tb» siirg* 'buin* ir* vwy l*«i«, ead >o
      •z* <-T«»n»d tbeot: wrw-f  IS 7U nduitaadlaf. to j«C • fo«l for bow auch
                                   ^^-                          r« th« unlqiu

-------
                    F037 AND FOBB  WASTE CAPACITY ANALYSIS:
                         DATA USB AND TRACKING SHEET
Refinery:   Shell Oil - Anacortes Refinery
State:      Washington
Data sources available:

      _x Petroleum refinery visits/voluntary  submission

      _x National Survey of Hazardous Waste Treatment, Storage. Disposal,
         and Recycling Facilities  (TSDR survey)

      	 National Survey of Hazardous Waste Generators

      	 Biennial report/state  reporting requirements

      	 California hazardous vaste  data base .

      _x Petroleum refinery data base (FRDB)

      _x No-migration petitions

      	 Comments form proposed rule

      _x Organic TC Survey

Basis for F037 and F038  waste estimation:

      EPA used data provided by Shell Oil (Anacortes Refinery) because it was
      the most recent and the only source that describes F037 and F038 waste
      generation and management.   Other sources were used only in comparison
      with the refinery's data  submission.


F037 and FQ38 waste estimates:

      F037 (routine) -'125 tons/year from gravity clarifiers and sewer
      cleanouts. (100 tons/year from sever cleanout and 25 tons/year from
      elarifiers).

      F037 (one-time) -  200 tons from closure of a diversion impoundment.  The
      Impoundment will be replaced by a tank, which will be cleaned out every
      two to five years; therefore,  the F037  sludge would not be generated
      continuously.  (Shell Oil expects that  F037 sludge generation in the
      tank would be less than 200  tons).

      Shell Oil Anacortes does  not anticipate generating F038 wastes.

      According to more  recent  information from the 1C survey, this facility
indicated that it would  generate the following quantities of surface
'•.
-------
r
                 inpoundment rludgcs during the Indicated time periods:



                           F037/8 (surface Impoundments) - 0 Cons (7/92 -  12/92)



                           F037/8 (surface Impoundments) - 0 cons (1/93 -  12/93)



                           F037/B (surface impoundments) - 0 cons (1/96 -  12/96)



                           F037 (routine) - 192 tons/yr.
                                                                                                            jrt
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-------

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                                                                                           -5
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          ENGINEERS
           A&susszt's ram
                CZXT/8UII


                     10.


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-------
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              0« 07 Jl   10:41    TJSO« titi
                                                         KF  5E
                                                                                                  £002
                             F037/T038 CASTE CAZAdl? AStLTSIS  -- 1ZFDJE1T
STATE;




CffiffAHT:




A2Kt£SS:









COBZACX:
                              Sh.ll Oil
                              SHell Oil Conpoj

                              March Poinc Ro*4

                                       ,  Bi.  98221
                             SdEca.
                                                EBDHE BTHBIS:
                                                                 1-20S-293-1S18

                                                                 1-20S-293-9190
                 CALLOL:
            Oa AmUwou, Wub. Sttta tape, of Eaelesy,  ladusezUl S.ctioa



            6/6/91            tUflt: 3:20 - 6:10 pa p.t:



                    JToaM     CtzeSSIOS:  5D9-9W-2U7
                                                                                                        • A •^ *" --
                                                                                                        a <• 5   m

                                                                                                        o. a. M.M
                                                                                                                             8
                                                                                                                             to
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-------
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               09-07
                        10:41
                                          3141
                                                       KF IE
                                                                                              a 003
                  shall OU, laaoortaa HI. cent.

                  I feud a copy of t&a tacarvlav tocaa to Ed acd advtsad tia caac l£ deaind,
                  chm lafoxaaclon would ba eon*ida;ad CBI.  H* did me iadlcaca th*e this vas
                  aaeacsaxy. I will follow op CO  aafca. sure.
                                            POJ7 AMD f036 QDZS11USB
                                                                                                      *-*t
                                                                        bta
                     iura doTalopad « pnllnlnaxjr cariM of quaatioiu to «id la our
                    d«Mtn41ac of bow cb* ww F037 aid F038 v**e» lifting end pra;o<«d
                       <£f*et r»fla«ri«».  1KM* qoanioas inrolv* not only C037 and 7038
                      •*,  bat «xg«nd to KMS-K05Z md.TC vaiccs, di«eta» p«st «od fucur*
                          maaMae £»e titty •odt£tucLoa«. oa *lta nrMCaaoc, «cc., in ordst fox
                  o§ co gat Ml und«r«t«a4tnj of ch« viola ptecura «n4 how avarytiicg
                  Iacarr«l«tM.  In addltian ce ftlnfng «a erarall uadcncodlag of tha Isiuu.
                  •w* wme  so dUecmr «sf nnlqua pcoblau or treatabliiejr is«ue> thic r«fln»riei
                  nqr hn* ««aeei«tad wtdi cHaaa wuca* .
                                                                                                        o
                                                                                                        d
                                                                                                        to
                  1.1
                  1.2
                  1.3
      Uhat
      Sa*
                               JMIT currant:
                                              aftjurtttcc?
      How ««|t»fK*d is jour tjmeea, scost w»car v«. procait

      Scam wmcar aamc eollacrlttn la (aparaea £r«M dsa procaii  tawac.

      Vhac »odif tc*tlen« lie** baaa s«da Is tb* Luc 5
o
o
u>
                       K wa>-£aa uaad CO ba Laid f«r»ed: tba alndg* wu 
-------
08-07.81   111:42
                                            KE
tatii an,  kurort** a. eon:

1.6   Sh»t  *£• a*

      KZSHAP and TC.

1.7
                                   b«hlnd ttuts» modifications?
         How hn» the M48-XQ3J.  1C «=d F037-F038 «lts«« «nd land baas tf fiend
         tU futility In saeu of Mdtf tcaelonj ,  operation. capacity. »tc.T
            r«go
        Co laad
CffiCLl tniJic«ti«
                         ceaftuiag.  Ic 1* h*rd Co uateracud c
                              faclllcle*.   You c«a'C landfara
                                               a davlr&ble.
                                                                   lead b«n «<
                                                                         T»C
   2.0 ICPtf*
   2.L
     oh«t t« your
     tod rc
                                   of g»c»ricion tad Itwl dlnos«l of K04l-r052
           «x* eh* ««a««tloc. wa±»r».  K vuui «r» f«ae to
     Irtkut ittttnontor.  TC v«*t*«  «i« noc cridnd ••
                                   co tfa» on§ic« laad
                    1C
        f«rX
    051 IM tbm only
           p*rlsd
  2.2
           do
                                    C«a«r*nd «tr»«a. ch« rue occur
                  eurmtly BUC, rtcytl. or 
-------
******
               oe/07
                                      »43  S143
                                                       ICF EE
                   shall on, »— - — *— u, coat.

                   2.4   Here there beca any up»tr««i or *uca vatar creeoune ftcLUcj operating
                        cbangea t» reduc* the eaounc of tfcaae wucw generated acd hew effective
                        are

      S«a 2.3

2.5   nil tta f>ropo««d 1037 «nd F038 land bafl affect the •oauae of che»«
            produced?.

                   F *Ut»« «otlelp«.ced M» £raa cmr eluaiagc.  T!ur»
                    b4*ia «Iwa4 of th» API •*p«r»cor. >o no  categorized u tc vmete?
                       t£e
                                                     buia Is ootduj«rdcro» by TO?.
                  3.0
                  3.1  !• tbu« « emiene eetictce of ttae aaa«&e of F037 end F038 vuce*

                                                      ..
-------
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                        io.4i   t»so»
                                                       icr IE
                                                                                              Joo«_
                                                                                                                        £5
                                                                                                                        a <•
                        Oil, lnaocnrt*a ta, coac.

                  3.2   I« thara 01 aatloaea of et« aaaiat eS F037 and ?038 vaacaa atockalU din
                        coatalnan or atirfacai                                       .      ^^
                        Thar* la oo» diwalM poad that vlll bav.  to b* cloaed.  do«ura «tll
                        probably guarata a oaa eia. «aoimc of t v«*c..  Tha poad ta uauallr
                        dry, buc tba clar Miitr coacaisa COM oil.   ('   .
                                                                  V?ei.
3.3  - Chae ar* yoa currently dotaf rtsh. tfaa •taelcpll*d vaxta aad what aza jaat
      flitiig* plaaaf  •

     Hut poad will b* elaaa cloa«i by the a&d of 1993.

3.4   %at ac* tha rta*i,cil aad phyaleal charaecarlrdea of both tba curranely
              |. 	_M — *- -  _-	*	«^	^	A                                  '
                       .tb* pood elasur* vlll gtaaraM aocM oil eonEaiolac macarlal, but
                       is "111 not tzfct»r EC ruin ( < 0.5 ppn BawcMM).  QIB F nata
                       from tb* a«w i* MBrfjr Uka and will pcebibly cricc«r TC ruUa.
                  3.5  Ihac la jour cnrraae tnaaMat, racycla or dlapotal Bathed In
                       raTartonahip ta 1037 aad F01I vucuT

                      ^ It Is cnrrancly land ecsa*d aa daacribad aaxliar.   Hhan tha
                       baa CBM» Into a££act It vlll ba aaat to tb» ioctaazator.
                  3.6  tbat ax* tha capaeitlw ot chaia erMnact, raeyela or dlapoaal aadioda
                       la ~i.»«~.».«r ta FD37 aad WJ8 vmataaf
3.7.   a£* thar* aa?
      «ltfat±*Uad
                                            rhmfaa, altbar pbyvtcal or opoxmcioiua., te daal
                                        aad bov «1U ch*>*  ebn^M «££*ee K044.EOS2 we*
                             tlon.
                plaaaad,  areapt to «tep land
                                                                      Ko chant* la K «ut»
                 3.«   !• it powlbl* to indue* I037/T03I or KJM-KOS2 w-taa by puctlaK norm
                       c£ a load on O* aotMatm biological uaitst
                            	L vaataa ar* Moatly laadr, faarc •«nr1«t aad tiara la not aucb
                       ttat * bio vole caa do.  tt»y ar* cunmtly TnoHag ae a •lurry raaetoz,
                       but doa-e knov If It woold Mat craataaac
                                                                                                                    MJ^.-
                                                                                                                    - a =» P
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                                                                                                                        d
                                                                                                       O
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                                                                                                      UO
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-------
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               08/07. «L  10:43   tJJ«« »41 31O
                                                       ICF
                                                                             ace?   __
                        on, iMoaztu w, cone.
                  4.0
                  4.1  flint *r« TOOT off«lt» cxiufaaae option* u>4 «r« clw unisja* f*at»e«« of
                       JDOT vut* chit would llalt tb* truubility epclon*?
             of
                               In the
                    •earea cancxol, »»gr»ff«clon, etc?)
                                                                            m to
                                                                            f«eiliey
           hn* tn««tt«ead Mare* eoatzel rcdccttens — ••• section 1.

                                    of di« ccrr«ac dlipecal opetoia, outc*.
                 4.3   Bill &• BIT xnUag «££«et
                       fttpti-™ «r i1 HIM 1 1 til?

                       Jfa

                 4.4   la
               go«« Co tb«*« cjp«j  of •ual.t*.

               « pr*£«xac« on prrxbielng FOJ7/T03J
4,5
                                                                         In ctru of
                                    clMoouc voa't b« bandLsd with. eb» API

                            la tiba fcwjo«j
-------
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                                              £33


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                                              C3


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  4 TV!»t*-^
                                      F037 AMD P03B WASTt CAPACITY ANALYSIS:
                                           DATA USB AND TRACKING SHEET
                                                                                                                    »       Z
                                                                                                                    •» o 2 jf o
        •J
        n
                  Refinery:   Texaco * Anacortes
                  State:      Washington
Data sources available:

      _jj Petroleum refinery visits/voluntary submission

      _x National Survey of Hazardous Uasce Treatment, Storage.  Disposal,
         and Recycling Facilities  (TSDR survey)

      	 National Survey of Hazardous Waste Generators

      	 Biennial report/state  reporting requirements

      	 California hazardous waste data base

      _x Petroleum refinery data base (FRDB)

       x No-migration petitions

      _x Conments Corn proposed rule   —

      	 Organic TC Survey

Basisfor F037and F038 waste estimation:

      EPA used data provided by Texaco (Anacortes Refinery)  because  it was the
      most recent and the only  source that describes F037 and F038 waste
      generation and management.  Other sources were used only in comparison
      with the refinery's data  submission.


F037 and F038 waste estimates:

      F037 (routine) - 3,000 tons/year from sewer and equalization tank
      (install by 1992)  cleanout.

      F037 (one-time) — 25,000  tons from closure of stormwater/process water
      Impoundments, and equalization baslti (to be closed by  1992).

      Texaco Anacortes does not anticipate generating F038 wastes.

      According to more recent  information from the comments to  the  proposed
rule, this facility indicated that it would generate the following quantities
of surface Impoundment sludges during the Indicated time periods:

            F037/8 (surface Impoundments) - 0 tons (7/92 - 12/92)
                                                                                                                        sj
                                                                                                                        n
O
o
to
hd
o
o
u>
                                                                                                                       CD

                                                                                                                       WO
                                                                                                                       LO

-------
I' _
                    F037/8 (surface impoundments) - 0 cons (1/93  - 12/93)



                    F037/8 (surface iopoundncnts) - 0 tons (1/94  - 12/94)
isi
                                                                                         Si8£~
                                                                                         S*»i8
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-------
US 13-91   10:J»    OSOt Hi S14J
                                    ICF IE
                                                                                              ir
   iCF KAISER
  ENGINEERS
                                            19 KJL.-M* ZNG.NCCXI me
                                            Ml MntLUMS B1.VO. ATM FU>S»
                          niZCOlT (301) 9O-J14S
                                   (30«) 943-MM
                                                        2 r o
                                                    ' 81s-


         cm/sun

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              ftrac

        s ronx HO.

         CKUUB HO.


                sns
QiS
                            mi OOBTOII or.
                                                  USES
                          CXKUIBXB6 COTD. UCE)

                        man ?ACSS

-------
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                                 ICF
           STAIE:



           COH?WK:
                           •»
                                                  S-293-06IS
            OOSTACX:
            DiXE:
                                     .*.--•«
                                                                         !«
                                                                        .Ill
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             04 !)•>!   10: S»    ft"* 9*3 JUJ
                                                     UP KE
                                                    12 00 2
                           F037/F038 HASTE OLZACXIT A3AIXSIS -- RETISBIY
                ST4IE:

                COHTASV:
                           Taxjico
                ADDSISS:    T«uco, USA.
                           P.O. Box 622
CQStfcCX:    V«m
nSXIZQV:   Saslor
                                          9(221
                     BU3CER:
               FAX MOHBE&:
 S4f»CT tad Bultii. Dope.
ROTXEHCE:   KU

DATE:       6/11/91

            Stuum* J<
                                                                         1-20S-2J3-06M
                                                                         1-206-293-L5J4
                                                    .Depe. of Ecology. Xa4u*trl*l Scecioa

                                                        8:45-8:30 AM, PST

                                            HHSSICH:  509-94<-2ii7
                 NOM

- Sf««d to fee laforaatio


- Ic«ma contact vill
tn coauee p«r»onT Sent c"P7 of lnc*rvi«*
                  J. 8uil  cor«c
                                                         sch«a«tlc
                                                                                      «nd
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                                                                              o
                                                                                                                      O
                                                                                                                      OJ
                                                                                                                     CD

                                                                                                                     UU

-------
        11:00
                OJOS I4J 1143
                                        ICF KE
                                                                          a 003
 S*kaco,  loaeortaa MA
                            F037 AKD F038 QUISTIOSS
 Ve bara davalopad a prallalsary sarlaa of qua* dons to aid In our
 undaraeaadinc •* bow  cba nav FJ37 aad ITJ38 vaata Uctiag and propoaad land ban
 will affiact zm£lBariaa.  Tbaaa qca*cloa« Involve not only F037 and F03I
 vaaeaa. but axpaad to KD4B-KOS2 «ai TC vuua. dLiciuB puc cud fucar* v«iu
 vatar erutwac fielliqr aodtfltaclona, on *Lce tr«*tB«nt, «cc., in order for
 U* CO g*C tO.  tautermr^nAItt^ of thff vtwl* ptcttll* md heir CrTClJT Lhillf
 inc«rr«LftU*.  In Addition to g«fTifn| «n overall und«r«oa«,
 v« wane to discover may unlqu* proOl«a» or treitiJaUlty Icmw* that r«flaarte»
 Q»y  hava «s»oci*ted with cfacx* vucac.
                Tr**ri"*gg FaelUrr
                                                                                                      §*» ^
                                                                                                      £ff



                                                                                                  a?»E» "
                                                                                                  O " •• ^ Bl
                                                                                                  a a «.«
                                                                                                      :
 l.l   Slut Is joor current configuxmcionf

      SM
                                                                                                      8
1.2   How
                     t( your «7*CMt, item. v*t«r TS.  proeau vacarf
      Own ara tan *avir cyitvu.  the ptocvst i«v«r talca* pzoeau
      vanca mcar and ateca wuar rvaoff from procau tato and avidi  It
      to tfa» bio CT*C*OI.  thar* 1* a »«p*r»t« «tora vater smr foe tha
      r*«t of tha itom wear runoff.  TMa 1_» »«or to » boldlog pood
      and is dlsehargod wlti txaasad proeaaa water.

1.3   Chat BoOtfLcabiooa hcva baaa Bad* ia tha Lut S

      No aajox
What vac* tba

Soc
                            fore** babiad thasa aodlflcadoM?
                                                                                                                  !
1.5   What futura oodlfieaetons ara platoiad?
      By April 1992. tfca follo^cf «1U ba tnacallad:
      -  Iba CJ«0 oxarflo* bade* irlll b«  raplacad by tm 80.000 bbl.
      ti7iV».  Xbaaa batin* eartancly taka off tut n.tar, or waear that
      it la «xe*H of tha bio «y»t*a capacity.
      -  Iba aquallxatlon bajln vtll ba raplaead by m 20.000 bbl. eank.
      •  Zb* AS! cad OAF «oiu will  ba cowrad.   A third DAF unit vlll
      ba ia»tallad.  Haw aarteera «ad eUxlflar* •vllL ba added.
      -  Iba aaracion pood and aatcllny pond* will b« raaorad ficea
      Mrvfea.
      -  Iba outfall puap< vtll be cbangad, and  dlffusacc will ba
      lutallad ac ch* dock.

-------
        11:00    tJ509  HI SHI
                                        1CF IDE
                                                                                2 CO 4   *-•
                                                                                                            "
 I'.S   'Shee are the drlvtnj forces behind ch«sa eodlf tensions ?
1.7
 2.0

 2.1
2.:
2.*
       frfTM. DCV perfoxaaacs (esadardc. SFDZS.

       How have t±* £0*4-15032. 1C «od K»37-?038 ruling *ad i-™< bus aff«ce*4
       the fsrtiltr la tear- of modification* .  operation,  capacity,  ere'. 7

       Cattl BOW, all K vasos ••r* Isad f cnud, vith ch«  eaccepciea of
       sloe oil «BiLsloas and OAF QJMC.  Tb« lucEar swo go co di* cofcar.
       Ho«t: of efal* i* omr (Olac ta tb» cok«r (kboae 200 T/>r) .   *FI
       bottoas vtll ben to b« s«oc offsic* co  so.  laebwrmcor.

       TC: casks vLLL nor b* tts*d Co bald effcue  r*x»x sad for
                      Ibo e£flc*nt yl«nt v&ccc  is  fc«"'^™«-. so
                                                                                                         e r «
                                                           .
             b*cos»s a v**C* v»t*r czaAeaanC voilz. tics ep«T4C«rs will
       bcv* co b» trmlaad sad eerclfl«d.
               »rvd TC g<«e*»
                                                                                                          O
                                                                                                          u
                                                                                                          to
                                                                                                          ^Tj
                                                                                                          O
                                                                                                          O
      Bhat it your estiaated 'race of (tnaratioa sad laad disposal of E048-KD52
      sad TC vsseas?                    —

      (Quantities la Tons)
      BW (CAT float)
      X049 (Slop oil
      xoso (SET
      051 <»»I
      K052 (Pb  Sk

                                      .,   * eo

      How  do you currently Crest, recycle or dispose of These vutes sad are
      chore cay foreseeable: casnc*s In the ereetaeac, recyellag er dlsyosair

      The DAT fleet end slop oil had been laad fsaed.  DAT float ii
      also seas to tie oakez.  Currently,  sludge sichse foe* to die   .
      eoker or  is pressed eai sscfc co aa iacioersxae IB Nortb Cazoliae.
IMf^
0
> 0
1.4.
317.2
32.0
1989
15.0
S0.2
14.0
917.3
0
1990
231*
714
2
76
0
1901
9*
-700
-10
-450
-10
     HOT h«.v« tba vasts j*a«MClon rscu changed irlth tha t"t*r-i'~M
     nillna; and lead ban?
                           ben nat
                                                 tiia mcfcod of
                                                                     vuca
                                                                        hss.
           chara been ay upttran er vase* vater tseataaoe faclllcy
      ehsage* CO zedaee cha «»oear of these wastes gtaereted sad bov
                chtngtsT            '

-------
r
              09.13 91
                                 O5C9 Hi
                                                        ICF KE
                 2.6   Hov nueh of th*s« vast** *r» «toclcpU«cl la container* or surfite
                 T»»co,
                                   Ml
                 2.5   ttlll th* propoc*d F037 asd F03B lend boa *ff«c: the Mount of th«e«
                       vaaeas produced?

                       Only la the cnwa that ei«y h*v« ba«n reclaulfied frou non-

                       HUM.

                 2.7   Chit «r» tb» cb«aieAL «o* pty«ic*l chmracterlatle*  of cha currsntly
                       g*ner*eod 
-------
r
                         11:01
                                 9301 H) JI4J
                                                        ICF IX
                  xtxaco, fta*oert*« fa
 3.4
                        Ace ir« th* ch«alc*l cad pbjciul cfaarteteritrics of both the currmelv
                                  Od th«
                        It Ic th« sa« « th» API battm*.  Ic la huvlaz th«T> w«e«r.
                        «bouc SOX ub md und, 201 oil tnd lurry crmadu,  «
       in C*l*CiM*faXp Co F037 «nd F03S mutxc?
                       Zb* l«ad Cam em luiudl* 1,0,000 con* of oil per ytur.
                                                                                      ••diode
      Ar« cb«c* *af planed clunges,  elchtr physical or optxacimul, co d«tl
      vith tb« Uod ben aad faov rtll  dw«« ebnfH t££*et K0i8-K052 vtxcm
                  3.S
                  3.6
                  3.7
                   c*n raduca to* load on Cta API unit, «g. by cleaning
      oat tibw mtx* an. m. roacian but*,  putting tad bags in tba  •
      procaat mumf to balp tba telidc nttla out. «nt«p up ch* dirt on
      dw vrococc Q&i>tfl radwr ^Vfn vajSbi  It into ttu aovor, •TM< icaap1 ^^^
      eolnr *elld» oat of ti» t*v»r.

3.8   !• it po««lil« to rwbc« F037/T038  or K048-KOS2 n«tu by pattinf
      of a load on th» aggresaiv* biological units f

      Bo.

4.0 &m«r.I

4-1   Bbat cr* your oCfsita tr«at«*BC opcioaa and what an dw unique f«ator*>
      of your vaata Uiat would' limit  tba

      Th«
      Ic to a

4.2   Boat Bodlflcatlotti bcv» bean dona or ara placnad upstraa* to radnea tba
             of n*ta cuaaratad lo d>« ttaata nacar craataaoc facility («g.
                                ol, »«graj*tlon. ace?)
                                     option* en ca pru« «ad z«4uea ti» wue*, tbcn s«ad
                                        '   or iaelaanacac.  Thar« shoaid IM oo llniu .
4.3   VU1 t-ba nil ruling aff.ct
              or
                                                     of tb* current dicpoial option! , onaite,
9
to
                                                                                                                          o
                                                                                                                          o
                                                                                                                               j

-------
r
              OM3.-9I   11:02
                                          5H3
                                                        ICF KE
BOOT
                 Xacaea, laacoxtaa xx

                 4.4   I< there a preference on producing F037/T038  vastat  la earns o£
                       or dlxpocalT

                       Cuxreccly, Ic i* preferable to generate F VMM because you can
                       •till Land farm It.

                       la general, It Ic hard to see hov laetnerieloa c*a be preferable
                       CD land faming - bo* can a* Ing up charcoal In cne practtag *c«p,
                       shipping tha prasaad eak« clear across  tha councry, chan
                     .  iBctoaradna; Ic iiith no produce racavvrj ba eha baccar
                       alunaclva?
                                                                                                                          *      *
                                                                                                                        •• o 2 jr o
                        a. a -.«•
                            i* tha £r« elaaaad avary thr«a aoacha, cha DAT.
                             two year*,  rank* ara conclnuoualy drltaad and sludge la
                                 £ abouc av«7 otbar J»ar.  X* for ponda, rha orarflov
                       baatn is claaaed rrary tl» antha. buc tbasa arm to be rapLtead by
                       eatdci.   Slap oil amlslon la aaoc dally eo eba eekar.  Tba ba«c
                       axehaagoca ara elaaaad during mra«rouoda, aboat arary 5 years or
                       laas.

                Hbile teiM of tbaaa qQasdom «ra Tuy spaelJTlc, va realize that: Initially DOC
                all of eba axaftt 
-------
08-15.31   11:02    0S«« »4J SHJ
           LCCOICH
           SUBJKT
                                   [CF KE
                  DISSOLVED >UR
                  FIOATION UNITS
           EOUAItZATlON
           I   iASN   I
          200,000 CU FT
1
API
rt— |
! !
,
I j
        *•-".
                                              ACUftD
                                              IAGOCN
                                            aaxooocuir
                            ABUTtS* CUWTERS
                               a,080 cu rr
                                    OffiM 0VBWJSW
                                    TORIUUOBAV

      OVERFLOW
_^j    BASN
f* 300.000 CU R
                                                     OVEWLOW
                                                      BASN
                                               -* 500.000 CU FT
       OCAM WATCH
         FUME
      104000 CU FT
                  CHLORWATCS
                  1000 l£/tAY
  STORM
  WATER
1
                                                      SK 11/18/88
                                                                                            ss
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                                            U)
                                                                                          C3

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-------
r
        J

        3
                                    F037 AKO F03B WASTE CAPACITY ANALYSIS:
                                         DATA BSE ASD TRACKING  SHEET
                                                                                                                        f ss
                Refinery:   Quaker State - Newell Refinery
                State:      West Virginia
Data sources available:

       x Petroleum refinery visits/voluntary submission

       x National Survey of Hazardous Waste Treatment.  Storage. Disposal,
         and Recycling Facilities (TSDR survey)

      	 National Survey of Hazardous Waste Generators

      	 Biennial report/state report ing requirements

      __ California hazardous waste data base .

       x Petroleum refinery data base (PRDB)

       _ No-migration petitions


Basis for F037 and F038  waste estimation:

      EPA used data provided by Quaker State (KcKean Refinery)  because  it vac
      Che nose recent and the only source  that describes  F037 and F038  waste
      generation and management.  Other sources  were used only  in comparison
      with the refinery's data submission.


F037 and F038 waste estimates:

      F037 (routine) — 100 tons/year is from sewer cleanouts.

      Other than the F037 waste from sewer  cleanouts, Quaker  State does not
      appear'to generate any other F037 and F038 wastes.
                                                                                                                          n
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                                                                                                                                i' tji.

-------
 67x2^91  13-56    O412 281 5220
                                       I WES
SSI sy:x(pox Telecopier rc»;  7-2H1: 1M7  :
W6767030-
                                                                           2)002  _
                                corn unu
                            741 I (114) 676-7030
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          ruuuis DtLtTBt m mumx ?AfiB(8)
          MXZl
          TOTAL man or riant
                                    «^.1..x<«t ClXlf
          IMTOUUTIOT
          nan mnaa or ssmnt
                IF TOO CO ROT fttCEZTZ ALL T8Z PACtS TRDTCATt!)
               »lf »SZ CALl *f)«T»F» >T
                                        KCHBCT LTSTCD
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-------
***»;*
              87-24/91   13--S7   0412 231 5220
                                                  ires
             ScRT BYKirw Tlltwlfr 7020 : 1-2H1  : UM1  I
                                          W876703IH
412 211 5220!! 2
                                                                                                     •° « ">
                                                                                                     II?
                                                                                                    •
                               waate la auitabl* for fuela blandlng. The KOSl baa
                  ne Btu conttnt and the K04ft baa • vary lew fitu that variaa widaly
                  batvaan ahlpntnta. Neither wast* ia atorad or atookpiked oaalta.
                  Th« KOfil it dawatared at fenaratlon to a aolidg content of
                  approx. SOX. Tbt K04I J* about UX vater. l/nfortunattly, our
                  Inatnarator can not bantfl* bulk aolida In other than drut
                                                                                    o   ^-
                                                                                     »!
                  cu*ntiUei>. There la BA eoonoiic Incentive to dewatar tba HO 48
                  for 'aide-door  lociRaratiea and •* hecltat* to awlteh froa a
           T30.
     Moo* of our aeeeadarr treatment waate ia charactariatte.

         FOJfl Vaatae

     Ka eatUata 100 tona/yaar of FOST 4 P03S. Nona of thia waata
!• itookpllad, On ftatratioa, uiually during naintanaaoa or
elaaa-aut, the «lud*a trill ba dawaterad and diapeied of. Any oil
raoovarad will ba re*ehari»d to our uaita. In fanaral, th* waat«
will ba 40X aolida after d«vat£rla«. neo-iinitabJa,non-raaativ«,
and non- TCI.P toxjo. j(OMt of thia waata will ba ludfillad until
a land ban* Aftarwarda, w» will probably hav« it incinaratad
ratfardleaa of aiaiMl oontaainant It vela.
     Aialni w« do not expaet K048 4 K061  volunaa to cbanfa dua
to th* F03T/F038 ruliafa. Wo could bowevar »Haiaate our K04S
atraaa by ditcontlauinf dlaaolvad air flotation. Tho effect on
naoondarr traatsant would ba baraly aotieaabl*.
                      *•  prafar ineinaration far our "X" waatva.  Therefora  th*«v
                 waatta,  having no •coaealo/fu*! valua,  will  eontlaua  to ba
                 inoinermt'wd  aa lor><  aa w*  oan aooaaa oapaoitr* K«  poliol«a bava
                 baan davtlopad l&-bouaa  conoarninf the  F037/F038 p«ndinf *ara
                 inforvation.  Ira htvt ae  prafaranoa rafardinr "K" va *F" vaatcc.Wa
                 do aot baljeva nodiflcatlona upatraai to tba API'a will
                 AifnifictnUr reduce voluaaa.  At praaant wa  elaan  the API'a «e«i-
                 annuallr and tha  DAF Float Accumulation taaka avtrr 8 waaka.
                 Uflita eontainlnf  POJ7/»03i will  ba elaanad aa naadad.
                                                                                                       O
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                                                                                     •y


-------
      13;66
                     5228
                                  IIES
                                                                    Bees
SMI 8Y!Xir«
              f 7C20 : 1-2H1 : U:1J :
                                            9U8767030«

                                       07/16/91 «!B9
281 S220II 3
                                                                                     »
                                                                                     - a £ • °
                                                                                     S  " • 2
                                                                                     £:•<»•« X
                                                                                     * ? _» 2
                                                                                     , 75 «or«§ oonniit of roads and und»v«lop«d
      y fields draining into tho uncont&ainattd nwtr eyitea,
      Aftvr the API separator* , our treatment seheM inoludtf dual
      lvad Air Flotation Units, biological treatnent *ia extended
 attrition. «»nd filtration (2-unit«),  *nd hydrogen peroxidt
 dlilnfectlon.  ?ht> taod fDtratloa and peroxide dlsinfsotJen were
 added Just over 0 rears Mo for NPDC6 pei-altting. There are no
 current plans  to alter our treetaent configuration.
      Tha  K04S-XOS2 and TCLP rtilinfs hnv* not affected operation.
 our wastes are not characteristic under the new test procedures
 and we h«va been incinerating these w««te« si nee IBM. Please
 note  however that •«»» scheduling prebl«e,s for incineration »f«
 now beihg eneountftreO due to shortfall* in cap»»ltr> We are
 unsure how »unh P037 - F03B will be generated under the new
 nilinga.  However,  we expect these waste* to be non-charaoteriatic
 ae well .


 Ktua  - K082 and TC Wastes

      Our  K04*  - X05t waste* aneunt. t.o approx. 250 tons/year and
 should refinin  so for th« forseeable future.  Again, these wastes
 are incinerated and hav« b««n for ease tim*.  t'ndev tbe new
 toxiea.tr  para«eterit  wo expect to generate another 100 tons /rear
under 0018  (gasoline contaminated wastes).  Tbe D016 will be
 incinerated or landfilled li*»*d  on concentration und voluse of
each generated  aaount.
     Our  *K" wejites  are cosprieed of  upprox.  90X OAF Float and
                                                                                            o
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-------
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thP»o
ta *u
t« Ii
Uttl
«oly
or
"
  to •!<»» «««r*tlon of th».»
  B«W content.  ObvlouBly w»
ilh etud. .«ppJl.«
                             Extiniitd Put   3,
                                                                             iitd FIJI
                                                                             M. il
                                                                            not «l»h
                                                                            «. have
If!
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-------