1. Indiana Department of Environmental Management
BP Products North America
Whiting Refinery
2013 Draft NPDES Permits

2. Citizen Summary Content
Background on NPDES permits
Brief description of the permit process
Wastewater sources and treatment by outfall
Effluent limitations and other requirements
What is different about this permit compared to the current permit?
Next Steps

3. NPDES Permits NPDES Permits:
Ensure that all existing uses of the receiving water are maintained and protected.
Contain water quality-based effluent limits for the pollutants that have the potential to cause or contribute to an exceedance of the water quality standards.
Contain effluent limits for the pollutants identified in federal effluent limitation guidelines as needing technology-based effluent limits representing the minimum amount of treatment required.
Are renewed every five (5) years to keep the permit conditions up to date with any changes to the water quality criteria and the federal effluent limitation guidelines.

4. NPDES Permit Process Review of permit application for completeness.
Determine if the discharge will cause a significant lowering of water quality, which triggers antidegradation.
If antidegradation is triggered, then IDEM must decide if the new or increased discharge is necessary.
If the new or increased discharge is necessary or if the permit is being renewed without any new or increased discharge, IDEM will place the draft NPDES permit on public notice for thirty (30) days.
A public hearing may be held if requested where the public can present oral and written comments to IDEM.
A final permit decision is made which can be appealed by any affected party.

5. Public Participation
The public is provided a minimum of 30 days to submit comments about the draft NPDES permit.
Comments addressing the technical or legal basis of the permit conditions or additional suggestions to control water pollution are most helpful.
IDEM will review and consider all comments submitted during the public comment period, including oral statements made during the public hearing, and provide its formal responses to comments in a document that will be included with the final permit decision.

6. Public Participation
Copies of the technical Briefing Memo and draft NPDES permit are available for public view at these locations:
IDEM’s Northwest Regional Office
Lake County Health Department
IDEM’s Indianapolis Office

7. How to Submit Comments
Comments may be submitted by U.S. mail or by June 14, 2013.
Mail comments to:
Steve Roush
IDEM, Office of Water Quality
MC IGCN 1255
100 N Senate Ave
Indianapolis, IN or
Send comments to:

8. BP Products North America Wastewater Discharges
BP Whiting discharges three types of wastewater: treated effluent, once-through non­contact cooling water, and storm water.
The refinery discharges a long-term average of 15.7 million gallons per day (MGD) of treated effluent through Outfall 005 into Lake Michigan.
The refinery discharges a long-term average of 73.7 MGD of once-through non-contact cooling water through Outfall 002 into Lake Michigan.
The refinery intermittently discharges the balance of its storm water through Outfalls 003 and 004 into the Lake George Branch of the Indiana Harbor Ship Canal.

9. BP Products North America Wastewater Sources and Treatment – Outfall 005
The WWTP that discharges through Outfall 005 receives and treats wastewater from normal refinery operations including maintenance, turnaround activities, excavation, dewatering, construction activities, tank cleaning, and temporary flows from upsets or downtime. BP also accepts and treats wastewater at the wastewater treatment plant from Praxair and Ineos PIB Unit (formerly BP Chemical Plant).
The wastewater treatment plant is an advanced biological treatment system, which occupies twenty acres and includes a grit chamber, oil/water separators, dissolved air flotation, an activated sludge plant and final filtering processes.

10. BP Products North America Wastewater Sources and Treatment – Outfall 002
Over the past five years, BP Whiting has discharged a long-term average of 73.7 MGD and a maximum monthly average of 86.2 MGD of non-contact cooling water to Outfall 002.
The cooling water receives treatment from an oil/water separator and de-chlorination chemicals (Sodium Bisulfite). The oil/water separator is utilized to capture and remove any petroleum product that may leak into the system.

11. BP Products North America Wastewater Sources and Treatment – Outfalls 003 and 004
BP Whiting discharges storm water associated with industrial activity from an area on the south side of the BP Whiting property through Outfalls 003 and 004 using a manually controlled valve. When the level of water in the ditch is high, the water is released to the canal.
The storm water is managed through the use of a Spill Prevention, Control, and Countermeasure Plan, a Storm Water Pollution Prevention Plan, a Facility Response Plan, and Agreed Order No. H-11187, which defined eight interim measures to be implemented at the J & L site where Outfalls 003 and 004 are located.

12. Basis for Effluent Limitations
Please refer to pages 6 and 7 of the Citizen Summary to view the effluent limitations for Outfalls 002, 003/004 and 005.
Effluent Limitations in this permit are based on one of the following:
Technology-based effluent limits from federal effluent guidelines.
Water quality-based effluent limits calculated to meet acute water quality standards within the mixing zone and chronic water quality standards at the edge of the mixing zone.
Limits that are more stringent than either the technology-based or water quality-based permit limits that are carried over from the existing permit due to antibacksliding rules.
A variance from a water quality-based effluent limit such as the limits for total mercury and temperature.

13. Special Permit Conditions and Considerations
Whole Effluent Toxicity Testing – pages 7 & 8
Antidegradation – pages 8 & 9
Alternate Thermal Effluent Limits – pages 9-10
Streamlined Mercury Variance – page 10

14. What is different about this draft permit compared to the current permit?
The effluent limitations for ammonia as (N) and Total Suspended Solids (TSS) at Outfall 005 have been reduced to the level allowed in the NPDES permit that was effective prior to the current NPDES permit issued in June 2007.
Biological survey of the diffuser—The frequency of the biological survey of the area surrounding the diffuser contained in Part I.H.2 of the existing permit has been reduced from annually to the first, third, and fifth year of the renewed permit due to no finding of harm.
There are no schedules of compliance for any pollutants in this permit.

15. What is different about this draft permit compared to the current permit?
IDEM has reviewed the results of the thermal impact study and the application for alternate thermal effluent limits (ATEL) in accordance with 327 IAC 5-7 and IDEM proposes to allow BP Products North America to continue using the existing ATEL at Outfall 002.
IDEM has made a Best Technology Available (BTA) determination that the existing cooling water intake structures represent best technology available to minimize adverse environmental impacts in accordance with Section 316(b) of the federal Clean Water Act (33 U.S.C. section 1326) at this time.

16. What is different about this draft permit compared to the current permit?
Streamlined Mercury Variance (SMV) requirements were incorporated into the permit by modification dated February 17, The permittee submitted a renewal application for an SMV with the NPDES Permit renewal application on February 6, 2012, in accordance with the provisions of 327 IAC
The Permit now includes updated non-numeric storm water limits and SWPPP requirements.
The effluent limitations for Total Vanadium have become effective.
Outfall 001 has been removed from the permit.

17. Next Steps Comment period ends June 14, 2013.
IDEM and the U.S. Environmental Protection Agency (U.S. EPA) will review the public comments.
IDEM will respond to all comments and make necessary permit changes to ensure the final permit meets federal and state requirements.
Permit issuance.
Permit appeal period (eighteen (18) days).

18. Questions Paul Higginbotham Chief of the Permits Branch
Office of Water Quality
Indiana Department of Environmental Management
(317)