A few examples of reponses by the State, to questions in the .doc-
"Estimated ammonia loading to the wastewater treatment plants is expected to be more than doubled as a result of the conversion to process Canadian crudes. Ammonia removal is and will continue to be achieved through stripping of sour water and the wastewater treatment system. The reliability and efficiency of sour water stripping and wastewater treatment will be improved as part of the refinery reconfiguration. These control systems, however, are not specifically designed to remove ammonia, so they cannot be operated to achieve a specific ammonia discharge level, and are not expected allow BP to achieve the current permit limits after reconfiguration. Direct biological treatment of ammonia would require at least 12,000 sq. ft. located in close proximity to the existing Lakefront WWTP aeration tanks. Land area to accommodate new construction and installation of biological ammonia treatment is not available at the BP Lakefront property, and remote location of such a system would not provide sufficient treatment reliability and efficiency to achieve existing permit limits."
The following table illustrates the existing effluent limits for ammonia, the proposed effluent limits for ammonia and the highest limits that BP could possibly receive that meet the federal effluent guidelines and Indiana Water Quality Criteria:
Ammonia Effluent Limitations
___________________Monthly Average_____Daily Maximum
Existing Limits_______1,030 lbs/day________2,060 lbs/day
Proposed Limits______1,584 lbs/day________3,572 lbs/day
Fed Guideline Limits___3,358 lbs/day________7,387 lbs/day
Water Quality Limits___3,215 lbs/day________7,501 lbs/day
IDEM is confident that the increase in the effluent limits for ammonia will not result in any harm to the aquatic life in Lake Michigan and it will not cause any adverse impacts to human health by drinking the water from Lake Michigan.
It is the position of the Indiana Department of Environmental Management that: BP North America, Inc. has demonstrated that the increases in the permit limits for ammonia and total suspended solids are necessary due to the increased loading of those pollutant parameters to the wastewater treatment plant, the current lack of available space does prohibit the construction of any additional treatment facilities to further remove ammonia and TSS. The additional jobs, the long-term viability of the existing jobs/business and the value to our Nation's overall security resulting from utilizing a new source of petroleum from a neighboring friendly country have justified the proposed increase in the effluent limits for ammonia and total suspended solids.
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Response 20:
BP's wastewater treatment plant does have the capacity to treat the wastewater being generated now and when they are processing the heavy Canadian crude oil because the amount of wastewater will not be increasing.
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Total Suspended Solids is a generic pollutant parameter which includes pollutants being discharged such as mercury, selenium, vanadium, etc. The specific pollutants are measured in the effluent and there are limits on the specific pollutants so that none of the specific pollutants will be at a level which is harmful to the environment or human health. The increase in the effluent limits for TSS are justified based on the 645% increase in TSS estimated to be present in the influent wastewater to the WWTP. The monthly average effluent limit is increasing by 35%. BP will initiate additional controls related to assuring optimal and reliable operations of the Lakefront WWTP that will allow further reduction of TSS that includes: pre-treatment of the de-salter effluent, water reduction projects to reduce hydraulic loading to the WWTP, installation of an additional storm water / surge equalization tank to allow more consistent feed to WWTP, and replacing the existing media filters (tertiary treatment) with a higher efficiency filter system.
(Also, I presume how they treat for mercury is what oil/gas refineries usually do. They remove some vapor by using charcaol; incinerate and release some as vapor; and discharge the rest in sludge. The level of mercury in refinery effluents is generally
~10 - 100 ng/L, which is generally orders of magnitude lower than traditional technologies for metals treatment are expected to achieve.)
and
If the effluent limits for ammonia remained equal to the existing limits for ammonia, there is no rule provision for including a schedule of compliance in the permit. If BP violated the effluent limits for ammonia, they would face an enforcement action from IDEM and possibly from EPA. The agreed order resulting from the enforcement action would possibly include a schedule of compliance.
Everyone expects BP to operate their WWTP as efficiently as possible to make their effluent water quality as good as possible. No one at this time knows exactly how the processing of the Canadian crude will impact the ammonia loading to the WWTP other than we expect the loading to be higher than it is now. BP and IDEM worked together to determine what is expected to happen based on data from another refinery that has been processing similar crude. The increase in the ammonia monthly average effluent limit is 53.8% (554 lbs/day). BP requested and sought an increase of 212% (2,185 lbs/day) based on the effluent limit calculated using Indiana water quality criteria when using the high rate diffuser/alternate mixing zone, but that level of increase could not be justified.
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Comment/Question 47:
Expansion of the wastewater treatment plant - perhaps adequate treatment programs can be designed within existing property constraints. With the elimination of the sludge incinerators and existing parking lot, additional room to expand would be available. However, if additional space is needed, we suggest that the use of RCRA licensed areas be evaluated. A more detailed analysis of the existing facility needs to be done.
Response 47:
There are no known or proposed plans from BP to eliminate their hazardous waste incinerator, so that space will not be available. The RCRA area cannot be built upon, so that space is not available.
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Response 55:
The refinery is not expanding, it is being re-configured to process the heavy crude from Canada. The existing and proposed limits in the permit are far below the limits that are protective of all existing aquatic life and uses of the water such as drinking water. The amount of profit that an industry makes is not a factor in setting NPDES permit limits. BP's existing wastewater treatment plant produces wastewater quality that is at least three times better than the quality required to be protective of Lake Michigan.
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Response 63:
This is the first high rate diffuser being placed into the Indiana Waters of Lake Michigan. IDEM's Biological Studies Section reviewed the application and the revisions to the application for an alternate mixing zone/diffuser submitted by BP on August, 1994, March, 1998 and April 8, 2002.
The evaluation by the IDEM, OWQ Biological Studies Section recommends the following:
1. A comprehensive Toxicity Identification Evaluation and Toxicity Reduction Evaluation should be conducted prior to the diffuser being implemented
2. Careful consideration should be made on the support structure for the diffuser head to avoid creating attractive habitat that would draw aquatic life into the mixing zone
3. A monitoring and preventative maintenance program should be developed that prevents damage or failure of the diffuser heads, and
4. A chemical and biological monitoring program should be implemented that demonstrates the ongoing efficacy of the diffuser operation.
The effluent from the process wastewater treatment plant has demonstrated periodic toxicity. However, the mixing zone will mitigate the toxicity through the quick dispersion and mixing of the effluent. Although there is no longer as much concern about the toxicity of the effluent after the diffuser becomes operational, the permit will contain a requirement to test the effluent for chronic toxicity prior to the operation of the diffuser and for chronic toxicity after the diffuser becomes operational.
IDEM does not possess the authority to adjust the construction of the diffuser head support structure due to Indiana Statute IC 13-14-8-11.6. The statute states that a discharger is not required to obtain a state permit for the modification or construction of a water pollution treatment or control facility if the discharger has an effective NPDES permit.
Part II.B.1 of the permit requires the following: The permittee shall at all times maintain in good working order and efficiently operate all facilities and systems (and related appurtenances) for the collection and treatment which are installed or used by the permittee and which are necessary for achieving compliance with the terms and conditions of this permit in accordance with 327 IAC 5-2-8(8). BP will be required to submit their operation and maintenance plan for the diffuser to IDEM.
The permit contains effluent monitoring and limitations for the pollutants that are expected to be present and for Whole Effluent Toxicity. The maintenance of the diffuser should maintain the efficacy of the diffuser. However, to ensure that the diffuser is not causing harm to the aquatic life near the diffuser, BP will be required to conduct an annual survey of the aquatic life in the vicinity of the diffuser.
There was a public meeting in 1994 in Whiting regarding the original submittal of an application for an alternate mixing zone. This information was also made known to the public when the permit was public noticed on March 7, 2007.
Nothing is being done to prevent exposure of aquatic life to the effluent in the discharged induced mixing zone just like nothing is being done to prevent aquatic life from being exposed to the effluent mixing zone from Outfall 001 that has been discharging on the bank of Lake Michigan for several decades without the benefit of the rapid mixing that will occur out in the lake.
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Response 65:
IDEM is aware of the presence of Lake Sturgeon in the near shore environment of Lake Michigan. The size of the mixing zone (a radius 182 feet from the diffuser) is not very large and the diffuser ports will be pointed up. The rapid mixing of the effluent caused by the high rate of discharge from the diffuser will create a mixing zone that is much better for aquatic life than the existing situation where the effluent is discharged at the shore of Lake Michigan and it slowly mixes with the water of Lake Michigan. The existing discharge has not caused any fish kills, and using a high rate diffuser will reduce the amount of exposure and concentration of pollutants that may be present whenever a fish wanders into the mixing zone. The proposed mass effluent limits for ammonia are approximately ½ the mass allowed for this discharge to meet Indiana water quality criteria for ammonia,
so it is well below the level deemed to be protective of all aquatic life.and
Response 87:
The anticipated increase in the loading of ammonia to BP's wastewater treatment plant is an estimate based on the information available at this time. The increases in the loading of ammonia to Lake Michigan will be well below the allowable loading calculated using Indiana water quality criteria for ammonia. Therefore, the increase in ammonia loading will not have substantial, negative impacts on the health and vitality of Lake Michigan.
PUBLIC NOTICE ADDENDUM (QUESTIONS/RESPONSES)