ConocoPhillips Wood River Refinery Located in Wood River, Illinois by tam26166


									                   ConocoPhillips Wood River Refinery
              Located in Wood River, Illinois, Madison County
                 NPDES Permit Responsiveness Summary
                                                  Table of Contents
AGENCY PERMIT DECISION..................................................................................................... 2

   The following modifications were made to the NPDES permit issued April 14, 2004: ............. 2

BACKGROUND ............................................................................................................................ 3

PRE-HEARING PUBLIC OUTREACH ........................................................................................ 3

May 8, 2007 PUBLIC HEARING .................................................................................................. 3

RESPONSES TO COMMENTS, QUESTIONS AND CONCERNS ............................................ 4

   NPDES Permit ............................................................................................................................ 4
   Existing Groundwater Contamination ...................................................................................... 11

ACRONYMS AND INITIALS .................................................................................................... 13

DISTRIBUTION OF RESPONSIVENESS SUMMARY ............................................................ 14

WHO TO CONTACT FOR ANSWERS ...................................................................................... 14

                                             Final February 5, 2009

ConocoPhillips                                  )
Wood River, Illinois                            )
Modified NPDES Permit                           ) DLC File Number: 120-07
Permit Number IL0000205                         )

On February 5, 2009, the Illinois Environmental Protection Agency issued a modified
NPDES permit to ConocoPhillips for the discharge of various wastewaters to the
Mississippi River.

The following modifications were made to the NPDES permit:
1.    Fire water was added to outfall 003

2.    Special Conditions 6, 10, 25, 27, 29 and 30 were removed from the permit and
      the remaining special conditions were renumbered

3.    Language in Special Condition 15 (formerly Special Condition 17), items A, B
      and K(4) were modified to reflect existing regulations regarding construction site

4.    Special Condition 20 (formerly Special Condition 22) concerning the mixing zone
      was modified

5.    Special Condition 25 concerning quarterly sampling requirements was added

6.    Special Condition 26 concerning a Nickel compliance schedule was added

7.    Special Condition 27 concerning Mercury sampling was added

8.    Special Condition 28 concerning a Mercury compliance schedule was added

9.    The permitted discharge from the facility increased from 7.49 to 10.97 MGD for
      outfalls 001 and 001/002 and from 7.24 to 10.82 MGD for outfall 002

10.   Special Condition 10 (formerly Special Condition 12) concerning biomonitoring
      was modified

11.   Special Condition 8 (formerly Special Condition 9) was modified to reflect the
      addition of fire water to outfall 003

12.   Limits for Phosphorus, Mercury, Nickel, and Total Cyanide at outfalls 001,
      001/002, and 002 have been added to the permit

ConocoPhillips operates the Wood River Refinery located in Roxana, Illinois to produce
a variety of petroleum products for distribution in the St. Louis, Chicago, and
Indianapolis metropolitan areas and throughout the Midwest. Wood River is positioned
by refining capacity and by geographical location to process the growing volumes of
heavy crude oil from Canada.

On May 17, 2006, the Illinois EPA, Bureau of Water received an application to modify
ConocoPhillips existing National Pollutant Discharge Elimination System (NPDES)
permit to allow increased wastewater discharges from the Wood River Refinery due to
the Coker and Refinery Expansion (CORE) Project. The CORE Project entails installing
facilities to increase both the total crude processing and percentage of heavier crude at
the Wood River Refinery in order to increase the supply of petroleum products to the
Upper Midwest.

The entire public hearing notice was published thrice (March 24, 31, and April 7, 2007)
in the Alton Telegraph. The public hearing notice was mailed on and after March 20, to
persons on a hearing service list maintained by the Illinois EPA. The notice was mailed
to state legislators, county, township and municipal officials, environmental
organizations and interested citizens. The public hearing notice was also posted
electronically on the Illinois EPA website, and in the Illinois
EPA Collinsville regional office.

Illinois EPA Hearing Officer Rachel L. Doctors opened the hearing at 6 p.m. in the
Hartford Elementary School, West 2nd Street in Hartford, Illinois.

Illinois EPA Permit Engineer Jaime Rabins provided an overview of the draft NPDES

Comments and questions were received from the audience.

Hearing Officer closed the hearing at 10:04 p.m. on May 8, 2007.

Illinois EPA personnel were available before, during and after the hearing to meet with
elected officials, news media and concerned citizens.

A court reporter prepared a transcript of the public hearing which was posted on the
Illinois EPA website at

The hearing record closed on June 15, 2007.

Comments, questions and concerns in regular print

Agency responses in bold

NPDES Permit
1.    Is there any mercury or lead that gets extracted in the refinery and subsequently
      released into the water?

      Yes, lead and mercury is present in the crude oil during refinement.
      However, ConocoPhillips has reported lead concentrations of less than
      0.005 mg/L, which is well below the Title 35 Ill. Adm. Code Section 304.124
      effluent limit of 0.2 mg/L.         Although sampling has shown lead
      concentrations to be quite low, the Agency will require quarterly
      monitoring for lead and other parameters to verify continued compliance
      with the 304.124 effluent standard.

      Recent mercury concentrations in the effluent averaged 12.5 ng/L. The
      Agency found that there is a reasonable potential for mercury to exceed the
      human heath standard, and therefore mercury will be limited to an annual
      average concentration of 12 ng/L at outfalls 001 and 002. The permit
      includes a Special Condition to allow for a compliance schedule for

2.    After reviewing NPDES application for a refinery in Indiana (BP Whiting), it
      appears that mercury is recognized as a pollutant in the waste stream of
      refineries that process Canadian extra heavy crude oil, which ConocoPhillips
      would process. At the hearing, BOW staff denied that mercury should be
      considered in the permit review. However, mercury will be present and should
      be monitored on a monthly basis with the following limits from 35 [IAC] 302.208
      set in the permit: 2.6 ug/L acute and 1.3 ug/L chronic.

      See response to question number one.

3.    Will there be a new pond installed as part of the planned changes to the
      wastewater treatment plant?

      No, a new pond will not be constructed as part of the planned changes to
      the wastewater treatment plant. Rather, a new activated sludge basin will
      be installed within the existing wastewater treatment plant, in the location
      of the existing off-spec pond (Pond 1). The new treatment plant design
      includes the capability to operate Pond 2 as an off-spec pond, if needed.

4.    Under antidegradation regulations, alternatives to reduced loading and
      environmental degradation have not been given due consideration. For example,

     is there an alternative to the addition of phosphorus in the effort to biologically
     remove nutrients? This is a concern because nutrients are a problem in the
     Mississippi River and using additional phosphorus as a method of wastewater
     treatment could contribute to this problem.

     The wastewater is treated biologically using micro-organisms. Phosphorus
     is a necessary nutrient for biological activities. Those micro-organisms
     need a certain amount of phosphorus to survive and provide that function
     of wastewater treatment.       The wastewater is naturally deficient in
     phosphorus, and it must be added to enable the microorganisms to treat
     the wastewater.

5.   What is the current loading of phosphorus from the facility?

     Using the long term average flow discharged from the facility over the last
     two years of 6.63 MGD and historical phosphorus concentrations of 1.0
     mg/L, the current loading of phosphorus from the facility is 55 lbs/day.

6.   Will phosphorus will be kept under 1.0 ppm in the discharge “end of pipe?”

     Yes, the modified permit requires the facility to meet a monthly average
     effluent limit of one mg/L for phosphorus at outfalls 001 and 002.

7.   Is there an opportunity to reduce oil buildup on the onsite impoundment through
     the use of a Best Management Practice (BMP) further upstream in the process?

     Yes, there is an opportunity to reduce oil buildup on the onsite
     impoundment through the use of a Best Management Practice (BMP)
     further upstream in the process.          The onsite impoundment which
     discharges through outfall 003 is required to meet a 15 mg/L daily
     maximum concentration limit for oil and grease. To achieve this, the
     facility must use good materials management practices upstream of the
     impoundment to minimize oil and grease discharges. Any oil which
     inadvertently reaches the southwest property impoundments accumulates
     behind oil collection baffles, and is removed by vacuum truck to ensure no
     excursions occur.

8.   What about approved treatment for biological oxygen demand (BOD), total
     suspended solids (TSS) and chemical biological oxygen demand (CBOD). For
     example, many facilities remove BOD and TSS to levels well below the limits that
     would be set by the draft permit. What would be the cost to treat lower levels or
     to at least to hold loadings at current levels? In addition, is it necessary to
     increase the loadings of oil and [grease], phenols, ammonia, sulfides and
     chromium? What would be the additional costs for treatment to hold the levels to
     the limits in the current permit?

      The modified permit does not allow any increased loading of BOD5, TSS, oil
      and grease, phenols, ammonia, sulfides and chromium above levels
      specified in the NPDES permit issued April 14, 2004.

9.    A condition should be added to the permit that states that the upgraded refinery
      will be designed and operated to remove nitrogen. Monitoring for total nitrogen in
      the discharge should also be required.

      ConocoPhillips has acknowledged in the application and supporting
      documents dated May 12, 2006 that the improvements to the wastewater
      treatment facility will contain a denitrification capability and that this
      design will be employed to remove nitrogen from the effluent after
      completion of construction. In order to verify the removal of nitrogen, total
      nitrogen monitoring is required by the permit.

10.   According to Attachment J in the NPDES application materials, there are many
      substances that are currently used or manufactured as an intermediate or final
      product or byproduct at the refinery. Monitoring should be conducted for each of
      these materials in the effluent and storm water runoff upon startup of the
      expanded refinery and then periodically during the permit cycle.

      All of the substances listed on attachment J of the application and
      supporting documents dated May 12, 2006 have been reviewed. The
      Agency has determined that these substances are either limited by the
      NPDES permit or that they would not have the reasonable potential to
      violate any existing effluent or water quality limit. In addition, whole
      effluent toxicity testing is required as part of the permit to determine if
      pollutants that are not being monitored are present in harmful amounts.

11.   I am concerned about the provision in the permit allowing a pH level above 9.0.
      Usually, permits set an allowable range for pH of 6.0 or 6.5 to 9.0, which is
      protective of aquatic organisms and water quality standards. In particular, the
      condition provides that a pH of 9.0 may be exceeded if the elevated pH level is
      caused entirely by algae in the treatment lagoons, in which case there is no
      upper pH limit.

      Algae activity may lead to daytime pH values above 9 standard units.
      Discharges of this wastewater is allowed in accordance with 35 Ill. Adm.
      Code Section 304.125(d)(1). Since this is a natural phenomenon, aquatic
      life are tolerant of these pH values over short time frames. No aquatic life
      impact from pH will occur in the Mississippi River due to this source.

12.   What documentation would ConocoPhillips have to assemble to demonstrate the
      pH levels above 9.0 are caused entirely by algae?

      The presence of algae could be confirmed through microscopic
      examination of filterable solids and/or measurement of chlorophyll in these

      solids. pH measurement both upstream and downstream in the lagoons
      would also provide an indication of the presence of algae in the lagoons.

13.   A detailed description of the dimensions and attributes of the mixing zone must
      be included in the NPDES permit. The mixing zone must be re-evaluated for all
      pollutants in light of the changes to the refinery and the new crude oil that will be
      processed. In addition, an updated survey must be conducted in the area of the
      mixing zone to account for threatened and endangered species, mussels, fish-
      spawning habitat and otherwise high-quality aquatic habitat. The size and
      dimensions of the mixing zone must be specified for each of the pollutants for
      which a mixing zone is being granted.

      ConocoPhillips conducted extensive investigations pertaining to this
      comment in the months following the hearing. A mussel survey was
      conducted in the Mississippi River in the vicinity of the effluent outfall and
      a relatively large mussel bed was discovered. No mussel beds this far
      south in the Mississippi River were previously known. The presence of the
      mussel bed required the mixing zone to be reconfigured, as water quality
      standards must be met over mussel beds. A new dilution ratio (9:1) was
      determined from mixing zone delineation studies. The existing zone of
      initial dilution (ZID) was not impacted. The substances recognized as
      having ZID mixing are ammonia, acute whole effluent toxicity and nickel.

      New effluent monitoring was conducted for parameters not previously
      sampled on a routine basis. The new data, along with that previously
      available, was analyzed using USEPA’s Reasonable Potential
      methodology. Two substances not previously regulated in the NPDES
      permit were found to need permit limits; nickel and mercury. The newly
      recognized smaller mixing zone still provides enough dilution to allow
      water quality standards to be met at the edge of the mixing zone (mussel
      bed). A mixing zone will be recognized for pH, ammonia, manganese,
      nickel, zinc, sulfate, chloride, fluoride and total dissolved solids. The
      reasonable potential analysis found that only nickel had reasonable
      potential to exceed the water quality standard at the edge of the mixing
      zone and therefore a permit limit is necessary. No mixing zone is being
      granted for mercury.

      The other ecological characteristics mentioned in this comment are not
      believed present at the discharge location, given the discharge has been at
      this location for many years and these features have not been reported.
      Therefore, no other mixing zone provision impacts the mixing zone
      dimensions as the mussel bed does. At this time the mixing zone is
      described as occupying the river from the outfall to the edge of the mussel
      bed and providing a dilution ratio to the effluent (10.97 MGD) of 9:1.
      Reasonable potential analysis indicates mixing for nickel occupies the
      entire mixing zone, but standards for other substances are met using less
      than the entire mixing zone. There is no requirement to further delineate

      the area in the mixing zone where the water quality standard is not met, nor
      is there any need to establish permit limits for other substances given that
      no reasonable potential to exceed standards exists after application of the
      9:1 mixing zone. ConocoPhillips has indicated that they intend to extend
      the outfall past the mussel bed to again achieve a larger dilution ratio
      within the mixing zone. This may allow the permit limits for nickel to be
      removed if a revised reasonable potential analysis indicates that this is
      appropriate. A special condition has been included in the permit to
      recognize a larger mixing zone for nickel should this come about.

14.   What are the other uses of the segment of the Mississippi River that will receive
      the discharges from this facility?

      The Mississippi River at the point of discharge is a General Use water.
      Uses protected in General Use waters are listed at Title 35 Ill. Adm. Code
      Section 302.202.     These are aquatic life, wildlife, agricultural uses,
      secondary contact use, most industrial uses and primary contact use.
      There are no public or food processing water supply waters in the area
      around the ConocoPhillips discharge. The ConocoPhillips effluent will
      meet all General Use water quality standards after mixing, which are
      designed to protect the designated uses listed above.

15.   Oil refining is a water intensive industry. How much water is used by the Wood
      River refinery, including both ground and surface water, per barrel of petroleum

      ConocoPhillips has identified in their NPDES permit application that 12.8
      MGD (million gallons per day) of well water is used to process petroleum at
      the facility. ConocoPhillips does not utilize surface water to process

16.   Condition 6 of the draft NPDES permit addresses removal (e.g. by dredging) of
      deposits or obstructions caused by the refinery’s wastewater discharge. What
      are these deposits and what can be done to minimize them?

      The deposits are an accumulation of solids in the discharge. The refinery
      maintains low total suspended solids levels in order to minimize such
      deposits and obstructions, thus decreasing the need for dredging of the
      river.  Due to ConocoPhillips continued compliance with the total
      suspended solids limit, it is unlikely that solids would be discharged at
      such a rate as to require dredging. Therefore, special condition 6 of the
      draft permit was removed and the remaining special conditions were

17.   Condition 10 of the NPDES permit deals with storm-water credits. How will this

      The stormwater credits in special condition 9 (formerly special condition
      10) are applicable to stormwater which is treated in the wastewater
      treatment facility and only apply to load limits. No credit is given towards
      concentration limits. The permittee will multiply the quantity of stormwater
      times the multiplier listed in first section of the special condition. This will
      be the credit which will be averaged with the process load limits over a 30
      day period. The credits will not be allowed to exceed the limits specified in
      the special condition. The stormwater credits were developed pursuant to
      40 CFR 419.22(e)(2), 40 CFR 419.23(e)(2) and 40 CFR 419.24(e)(2).

18.   The last mussel survey conducted in the vicinity of the refinery’s outfalls that was
      used in review of this facility’s expansion was conducted in 1991. From personal
      communications with Army Corps personnel and others familiar with the segment
      of the Mississippi River receiving wastewater from the Wood River Refinery, I
      understand that a mussel bed exists in the near vicinity o f the refinery’s outfalls.
      In addition, the presence of mussel beds and pallid sturgeon habitat in the
      Mississippi River was discussed at the May 30-31 meeting of the Middle
      Mississippi River Planning Section at which representatives of the Army Corps,
      USFWS and IDNR were in attendance. Another aquatic life and habitat survey
      should be conducted at the proposed outfalls location. If mussel beds or
      important aquatic life habitat are found, mixing must not be allowed.

      A mussel survey was conducted (see response to Comment #13) and a
      mussel bed was discovered off shore from the ConocoPhillips outfall. No
      threatened or endangered species of mussels were found. The Illinois
      Department of Natural Resources was consulted on endangered species
      issues and on August 15, 2006 a termination of consultation notice was
      given. There are no known influences affecting the size and shape of the
      mixing zone other than the mussel bed.

19.   USEPA’s Permit Compliance System contains information regarding repeated
      permit violations due to excursions of permit limits for oil and grease. It is
      unclear why enforcement actions were not taken to address the permit violations,
      and why instead increased loading of oil and grease will be allowed as part of
      this expansion.

      There were two incidents reported where the oil and grease limit was
      exceeded. The first incident occurred on July 30, 2004 and was due to
      sparse precipitation in the area. That led to a reduced water level in the
      stormwater impoundment upstream of outfall 003, below the bottom of the
      underflow weirs which normally collect any oil present in the
      impoundment. As part of a modification to their NPDES permit, the facility
      will be able to utilize fire water to keep the water level in the stormwater
      impoundment, upstream of outfall 003, above the bottom of the underflow
      weirs, which will prevent future oil and grease limit violations. The second
      incident occurred on October 27 and 28, 2005 and was due to a two day
      outage of the DNF-3 unit upstream of outfall 001, which was taken out of

      service in to perform required maintenance on the pressure relief valve. No
      increases in loading are allowed as part of the modified permit.

20.   The information provided by ConocoPhillips in the C-P in Form 1 clearly indicates
      that the daily maximum and monthly average loads for BOD, COD, TSS,
      ammonia, sulfide, chromium and phenol are well below current permit limits.
      However, the daily and monthly maximum loads for oil and [grease] exceeded
      permit levels, and what is being done to address that level?

      It is the Agency’s understanding that the commentor is asking how can
      ConocoPhillips meet the daily maximum and monthly average limits for
      BOD, COD, TSS, ammonia, sulfide, chromium and phenols but not meet the
      oil and grease limit. There were only two oil and grease excursions since
      the last permit renewal. The circumstances that caused these excursions
      are described in question 19. To address continued oil and grease
      excursions the modified permit will continue to require the permittee meet
      monthly average and daily maximum concentration limits of 15 mg/L and
      30 mg/L respectively.

21.   Through FOIA, I requested a copy of the refinery’s stormwater pollution
      prevention plan and received a plan entitled Docks Storm Water Pollution
      Prevention Plan. Is this the sole stormwater pollution prevention plan developed
      for the refinery?

      Yes. ConocoPhillips is only required to develop a Storm Water Pollution
      Prevention Plan for Outfalls 004 through 008 (the dock area). This is
      because this wastewater consists solely of stormwater runoff and is not
      treated before discharge. Stormwater from all other parts of the refinery is
      treated, either in the refinery's wastewater treatment plant or at the
      southwest property impoundment, and must meet state/federal discharge

22.   The Docks Storm Water Pollution Prevention Plan states that this facility has no
      preventative maintenance plan (There seems to be confusion that such a plan
      applies only to equipment.) and that no oil and grease separation is in use.
      Given the facility’s documented problems meeting its permit limits for oil and
      grease, improvements in this facility’s stormwater management plan are clearly

      Section 2 labeled Preventative Maintenance in the facilities stormwater
      pollution prevention plan (SWPPP) does refer to equipment. However,
      there are several preventative measures the facility has outlined in their
      SWPPP to prevent and minimize contamination of stormwater at the
      facility. The documented problems meeting the oil and grease limits have
      been addressed in question 19.

Existing Groundwater Contamination
23.   Will the cone of depression under our towns get larger with the additional
      groundwater that will be pumped and used for the proposed project?

      The proposed project will not expand the cone of depression as the
      pumping rate will not increase with this project. The cone of depression is
      the intentional result of actions taken to prevent the migration of existing
      soil contamination under certain areas of the refinery. By pumping
      groundwater from under the refinery and maintaining a cone of depression,
      groundwater flows toward the refinery, rather than away from the refinery,
      which prevents the spread of contamination. Collected groundwater is
      then treated to remove contamination.

24.   Is there a reason that that contamination is not being remediated in another way
      instead of just pulling the water down far enough so it is not coming into contact
      with contaminated soil? Given ConocoPhillips stated goal of protecting the local
      community and the environment, it should find another approach to the
      contamination instead of wasting this much groundwater, which could be
      otherwise used for productive purposes.

      Equilon Enterprises LLC d/b/a Shell Products US is required by a RCRA
      permit issued by the Illinois EPA, Bureau of Land to maintain a gradient
      control under the refinery. This is done by maintaining a cone of
      depression that prevents contamination from migrating off-site.
      ConocoPhillips is maintaining the cone of depression for Equilon, as it is
      required to do under a contract with Equilon. When the RCRA permit was
      issued, this approach was determined to be an acceptable approach for
      containing contamination. This approach is both feasible and cost-
      effective as it does not disrupt the operation of the refinery. The
      groundwater that is pumped is used productively, as it is one of the
      sources of water for the refinery

25.   How is the groundwater contamination in the Hartford area, where a layer of oil
      floats on the top of groundwater, being addressed?

      The groundwater contamination in the Hartford area is being remediated by
      the Hartford Working Group under an Administrative Order on Consent
      from USEPA (No. R7003-5-04-001). The Hartford Working Group is a
      consortium of the companies that have been found to be responsible for
      this contamination and are subject to this Order. ConocoPhillips is not one
      of these companies.

26.   Further explanation is needed on the nature of the situation that leads the
      refinery to pump 3,000 gallons per minute of groundwater to maintain a cone of
      depression to comply with a RCRA permit. Water use in the State of Illinois

follows the reasonable use doctrine. This hardly seems like a legally defensible,
reasonable use of water.

Illinois EPA does not regulate water use in the State of Illinois. As
explained by ConocoPhillips at the public hearing, this water withdrawal is
a requirement on the previous owner of the refinery in a RCRA permit. The
purpose is to prevent the migration of contaminated groundwater by
maintaining a cone of depression under the refinery. ConocoPhillips acts
on behalf of the previous owner of the refinery in managing the subject
system to comply with this requirement.

  BOD            Biochemical Oxygen Demand

  COD            Chemical Oxygen Demand

  CFR            Code of Federal Regulations

  DMR            Discharge Monitoring Report

  IDNR           Illinois Department of Natural Resources

  IEPA           Illinois Environmental Protection Agency

  ILCS           Illinois Combined Statutes

  Ill. Adm. Code Illinois Administrative Code

  mg/L           Milligrams per liter

  MGD            Million Gallons per Day

  NPDES          National Pollutant Discharge Elimination System

  pH             A Measure of Acidity or Alkalinity of a Solution

  S.U.           Standard Units

  TDS            Total Dissolved Solids

  TMDL           Total Maximum Daily Load

  TRC            Total Residual Chlorine

  TSS            Total Suspended Solids

  US EPA         United States Environmental Protection Agency

  303(d)         Section of federal Clean Water Act dealing with impaired waters in
                 the State

An announcement, that the NPDES permit decision and accompanying responsiveness
summary is available on the Agency website, and was mailed to all who registered at
the hearing or who sent in written comments. Printed copies of this responsiveness
summary are available from Bill Hammel, IEPA Office of Community Relations, 217-
785-3924, e-mail:

Illinois EPA NPDES Permit:

       Illinois EPA NPDES technical decisions ........ Jaime Rabins ........... 217-782-0610

       Legal questions ............................................. Connie Tonsor.......... 217-782-5544

       Surface water quality issues .......................... Bob Mosher .............. 217-782-3362

       Public hearing of May 8, 2007 ....................... Rachel L. Doctors..... 217-782-5544

The public hearing notice, the hearing transcript, the NPDES permit and the
responsiveness summary are available on the Illinois EPA website:
J:\Responsiveness Summaries\ConocoPhillips RS_DWPC.doc


To top