11

National Pollutant Discharge National Pollutant Discharge Elimination System PermitElimination System Permit

B P Products North America B P Products North America

Whiting RefineryWhiting Refinery

22

AgendaAgenda Public Meeting Public Meeting

Draft NPDES Permit forDraft NPDES Permit forBP ProductsBP Products

• Opening RemarksOpening Remarks• Presentation of the changes at the Whiting Presentation of the changes at the Whiting

Business Unit by BPBusiness Unit by BP• Presentation of the draft NPDES permit by IDEMPresentation of the draft NPDES permit by IDEM• Break, collection of questions from the audienceBreak, collection of questions from the audience• Response to questions submitted by the Response to questions submitted by the

audienceaudience• Closing RemarksClosing Remarks

33

IntroductionIntroduction

• The public comment period for the draft The public comment period for the draft NPDES permit is open until May 11, 2007.NPDES permit is open until May 11, 2007.

• Written comments addressing the draft Written comments addressing the draft permit will be accepted up to May 11, permit will be accepted up to May 11, 2007.2007.

• All written comments will be considered by All written comments will be considered by IDEM in the preparation of the final permit.IDEM in the preparation of the final permit.

• All written comments will receive a All written comments will receive a response from IDEM.response from IDEM.

44

IntroductionIntroduction

• The B P Products NPDES permit/Fact Sheet The B P Products NPDES permit/Fact Sheet are available on the internet at: are available on the internet at: http://www.in.gov/idem/permits/water/wasthttp://www.in.gov/idem/permits/water/wastewater/public_notice/index.html. ewater/public_notice/index.html.

• Please write out all questions and Please write out all questions and comments that you wish to have addressed comments that you wish to have addressed at this Public Meeting on the form provided.at this Public Meeting on the form provided.

• Questions will be addressed following this Questions will be addressed following this presentation.presentation.

55

Facility DescriptionFacility Description• BP Products North America Inc. owns and BP Products North America Inc. owns and

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

66

Receiving WatersReceiving Waters

• Lake MichiganLake Michigan – Lake Michigan is the – Lake Michigan is the receiving water for Outfalls 001 and 002. receiving water for Outfalls 001 and 002. (Outfall 001 will be renumbered as Outfall (Outfall 001 will be renumbered as Outfall 005 with commencement of discharge 005 with commencement of discharge through effluent diffuser). through effluent diffuser).

• Lake George Branch of the Indiana Harbor Lake George Branch of the Indiana Harbor Ship CanalShip Canal – The Lake George Branch of – The Lake George Branch of the Indiana Harbor Ship Canal is the the Indiana Harbor Ship Canal is the receiving water for Outfalls 003 and 004 receiving water for Outfalls 003 and 004

77

Lake MichiganLake Michigan

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

88

Lake George Branch of the Lake George Branch of the IHSCIHSC

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

99

Outfall 001Outfall 001

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

1010

Outfall 001 cont.Outfall 001 cont.

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

1111

Whiting Clean EnergyWhiting Clean Energy

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

1212

IneosIneos

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

1313

Alternate Mixing ZoneAlternate Mixing Zone

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

• The alternate mixing zone will encompass The alternate mixing zone will encompass a 182 feet radius from the diffuser.a 182 feet radius from the diffuser.

1414

Alternate Mixing Zone cont.Alternate Mixing Zone cont.

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

1515

Alternate Mixing Zone cont.Alternate Mixing Zone cont.

• In accordance with 327 IAC 5-2-11.4(b)In accordance with 327 IAC 5-2-11.4(b)(4), the mixing zone shall not:(4), the mixing zone shall not:

• Interfere with or block passage of fish or Interfere with or block passage of fish or aquatic lifeaquatic life

• jeopardize the continued existence of an jeopardize the continued existence of an endangered or threatened species or endangered or threatened species or result in the destruction or adverse result in the destruction or adverse modification of such species’ habitatsmodification of such species’ habitats

• extend to drinking water intakesextend to drinking water intakes• impair or otherwise interfere with the impair or otherwise interfere with the

designated uses of the receiving water designated uses of the receiving water

1616

Alternate Mixing Zone cont.Alternate Mixing Zone cont.

• promote undesirable aquatic life or result promote undesirable aquatic life or result in a dominance of nuisance speciesin a dominance of nuisance species

• allow substances to settle to form allow substances to settle to form objectionable depositsobjectionable deposits

• allow floating debris, oil, scum, and other allow floating debris, oil, scum, and other matter in concentrations that form matter in concentrations that form nuisancesnuisances

• allow objectionable color, odor, taste or allow objectionable color, odor, taste or turbidity, orturbidity, or

• cause adverse effects to human health, cause adverse effects to human health, aquatic life or wildlife.aquatic life or wildlife.

1717

Alternate Mixing Zone cont.Alternate Mixing Zone cont.

• The following concerns were raised The following concerns were raised about the alternate mixing zone by about the alternate mixing zone by IDEM’s Assessment Branch:IDEM’s Assessment Branch:– Toxicity of the EffluentToxicity of the Effluent– The support structure of the diffuser The support structure of the diffuser

becoming an attraction to aquatic lifebecoming an attraction to aquatic life– Maintenance of the DiffuserMaintenance of the Diffuser– Biological monitoring to ensure efficient Biological monitoring to ensure efficient

diffuser operation.diffuser operation.

1818

Alternate Mixing Zone cont.Alternate Mixing Zone cont.

• Compliance with effluent limitations and Whole Compliance with effluent limitations and Whole Effluent Toxicity testing requirements will ensure Effluent Toxicity testing requirements will ensure that the discharge after mixing does not that the discharge after mixing does not demonstrate toxicity to aquatic life.demonstrate toxicity to aquatic life.

• Approval of the design of the support structure is Approval of the design of the support structure is under the jurisdiction of the IDNR Division of Water, under the jurisdiction of the IDNR Division of Water, US Army Corps of Engineers (Detroit District), and US Army Corps of Engineers (Detroit District), and IDEM’s Water Quality Certification Program.IDEM’s Water Quality Certification Program.

• Part II.B.1 of the permit requires the permittee to Part II.B.1 of the permit requires the permittee to maintain in good working order and efficiently maintain in good working order and efficiently operate all facilities and systems including the operate all facilities and systems including the diffuser.diffuser.

1919

Alternate Mixing Zone cont.Alternate Mixing Zone cont.

– Efficient diffuser operation will be ensured by Efficient diffuser operation will be ensured by proper operation and maintenance proper operation and maintenance requirements under Part II.B.1. requirements under Part II.B.1.

– There will be a written maintenance There will be a written maintenance procedure developed by BP addressing procedure developed by BP addressing proper operation and maintenance of proper operation and maintenance of diffuser.diffuser.

– Proper operation and maintenance will be Proper operation and maintenance will be verified through periodic inspections by BP verified through periodic inspections by BP Products and IDEM.Products and IDEM.

2020

Alternate Mixing Zone cont.Alternate Mixing Zone cont.

• IDEM has evaluated all available information IDEM has evaluated all available information relevant to the consideration of harm to human relevant to the consideration of harm to human health, aquatic life, or wildlife, and has health, aquatic life, or wildlife, and has determined that the alternate mixing zone will determined that the alternate mixing zone will not cause any of the adverse impacts identified in not cause any of the adverse impacts identified in 327 IAC 5-2-11.4(b)(4).327 IAC 5-2-11.4(b)(4).

• Implementation of an alternate mixing zone Implementation of an alternate mixing zone significantly reduces the potential for BP's significantly reduces the potential for BP's discharge to adversely affect aquatic life, discharge to adversely affect aquatic life, because the magnitude and duration of exposure because the magnitude and duration of exposure will be reduced as a result of more rapid and will be reduced as a result of more rapid and immediate mixing.immediate mixing.

2121

Outfall 002Outfall 002

• In the past, BP Whiting has discharged a In the past, BP Whiting has discharged a maximum monthly average of 119.6 million maximum monthly average of 119.6 million gallons per day (11-99 through 10-01 data) of gallons per day (11-99 through 10-01 data) of non-contact cooling water to Lake Michigan non-contact cooling water to Lake Michigan through Outfall 002.through Outfall 002.

• Outfall 002 currently has a maximum monthly Outfall 002 currently has a maximum monthly average discharge of 96.4 MGD of non contact average discharge of 96.4 MGD of non contact cooling water (7-02 through 12-05 data).cooling water (7-02 through 12-05 data).

• After the refinery has been configured to After the refinery has been configured to process CXHO, the maximum monthly average process CXHO, the maximum monthly average discharge from Outfall 002 will be 81.8 MGD.discharge from Outfall 002 will be 81.8 MGD.

2222

Outfalls 003 and 004Outfalls 003 and 004

• BP Whiting discharges storm water to BP Whiting discharges storm water to Outfalls 003 and 004 using a manually Outfalls 003 and 004 using a manually controlled valve.controlled valve.

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

2323

Effluent Limitations for 001Effluent Limitations for 001

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

2424

Effluent Limitations Rationale Effluent Limitations Rationale for Outfall 001for Outfall 001

• BP is allowed up to three years to either BP is allowed up to three years to either install and operate the diffuser or meet the install and operate the diffuser or meet the final effluent limitations that are based on final effluent limitations that are based on Indiana Water Quality Criteria calculated Indiana Water Quality Criteria calculated into effluent limitations without the benefit into effluent limitations without the benefit of the mixing zone. of the mixing zone.

• Limits from the existing permit are carried Limits from the existing permit are carried forward at the same levels and will remain forward at the same levels and will remain applicable as interim limits during the applicable as interim limits during the compliance period, until the diffuser is compliance period, until the diffuser is operational.operational.

2525

Effluent Limitations Rationale Effluent Limitations Rationale for Outfall 005for Outfall 005

• When the diffuser becomes operational, When the diffuser becomes operational, Outfall 001 will become Outfall 005 for data Outfall 001 will become Outfall 005 for data tracking purposes. The actual monitoring tracking purposes. The actual monitoring point will remain the same.point will remain the same.

• The effluent limitations for BOD, COD, oil and The effluent limitations for BOD, COD, oil and grease, phenolics, Sulfide, T. Chrome, H. grease, phenolics, Sulfide, T. Chrome, H. Chrome and pH will be identical to the Chrome and pH will be identical to the effluent limitations contained in the existing effluent limitations contained in the existing permit.permit.

• Phosphorus is limited to a daily maximum Phosphorus is limited to a daily maximum concentration of 1 mg/l.concentration of 1 mg/l.

2626

Effluent Limitations Rationale Effluent Limitations Rationale for Outfall 005 cont.for Outfall 005 cont.

• The effluent limitations for Fecal Coliform and The effluent limitations for Fecal Coliform and Total Residual Chlorine have been removed from Total Residual Chlorine have been removed from the permit because the sanitary wastewater is the permit because the sanitary wastewater is now being sent to the City of Whiting for now being sent to the City of Whiting for treatment.treatment.

• BP is required to monitor the effluent from Outfall BP is required to monitor the effluent from Outfall 001 for Acute and Chronic Toxicity until the 001 for Acute and Chronic Toxicity until the diffuser is operational and then BP will be diffuser is operational and then BP will be required to monitor the effluent from Outfall 005 required to monitor the effluent from Outfall 005 for chronic toxicity only. for chronic toxicity only.

• If toxicity is demonstrated, a Toxicity Reduction If toxicity is demonstrated, a Toxicity Reduction Evaluation is required.Evaluation is required.

2727

Effluent Limitations Rationale Effluent Limitations Rationale for Outfall 005 cont.for Outfall 005 cont.

• BP will be allowed up to five years to BP will be allowed up to five years to achieve compliance with the new final achieve compliance with the new final limitations for Vanadium and Mercury. limitations for Vanadium and Mercury.

• IDEM anticipates BP will apply for a IDEM anticipates BP will apply for a Streamlined Mercury Variance which will Streamlined Mercury Variance which will require BP to implement a pollutant require BP to implement a pollutant minimization program to reduce Mercury minimization program to reduce Mercury in their discharge.in their discharge.

• IDEM anticipates BP will develop additional IDEM anticipates BP will develop additional toxicological data for Vanadium which will toxicological data for Vanadium which will be used to revise the water quality be used to revise the water quality criterion for aquatic life.criterion for aquatic life.

2828

Effluent Limitations Rationale Effluent Limitations Rationale for Outfall 005 cont.for Outfall 005 cont.

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

2929

Antidegradation Rule for Antidegradation Rule for OSRWsOSRWs

• Discharge flow volume will not increase as Discharge flow volume will not increase as a result of CHXO refining proposed by BP a result of CHXO refining proposed by BP Products.Products.

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

3030

Antidegradation Antidegradation ImplementationImplementation• IDEM required BP to submit an IDEM required BP to submit an

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

3131

Antidegradation Antidegradation DemonstrationDemonstration• BP will implement the following BP will implement the following

projects as part of the CXHO Project to projects as part of the CXHO Project to minimize TSS and ammonia in the minimize TSS and ammonia in the effluent:effluent:

•Desalter Brine Treatment to remove Desalter Brine Treatment to remove emulsified solids from the brine wastewater emulsified solids from the brine wastewater prior to entering the process sewer.prior to entering the process sewer.

•Expansion of the sour water stripping system Expansion of the sour water stripping system for handling the increased ammonia loading for handling the increased ammonia loading from the processing of Canadian crudes.from the processing of Canadian crudes.

3232

Antidegradation Demonstration Antidegradation Demonstration cont.cont.

• Installation of an additional 10 million gallon Installation of an additional 10 million gallon equalization/storm water tank to allow more equalization/storm water tank to allow more consistent feed to the WWTP. consistent feed to the WWTP.

•Upgrading the final filters at the WWTP to Upgrading the final filters at the WWTP to improve hydraulics and reliability.improve hydraulics and reliability.

• Implementing flow reduction projects to Implementing flow reduction projects to maintain the WWTP discharge at current maintain the WWTP discharge at current level of 21.4 MGD.level of 21.4 MGD.

3333

Antidegradation for Antidegradation for AmmoniaAmmonia

• Ammonia effluent limitationsAmmonia effluent limitations Monthly Average Daily MaximumMonthly Average Daily Maximum

• Existing 1,030 lbs/dayExisting 1,030 lbs/day 2,060 lbs/day 2,060 lbs/day

• Proposed 1,584 lbs/day 3,572 lbs/dayProposed 1,584 lbs/day 3,572 lbs/day

• Fed ELGs 3,358 lbs/day 7,387 lbs/dayFed ELGs 3,358 lbs/day 7,387 lbs/day

• WQBELs 3,215 lbs/day 7,501 lbs/day WQBELs 3,215 lbs/day 7,501 lbs/day

3434

Antidegradation Demonstration Antidegradation Demonstration for Ammoniafor Ammonia

Demonstrated ammonia removal efficiency = Demonstrated ammonia removal efficiency = 70%70%

• Existing loading of ammonia to the WWTP = Existing loading of ammonia to the WWTP = 1,668 lbs/day1,668 lbs/day

• Estimated loading of ammonia to the WWTP Estimated loading of ammonia to the WWTP using CXHO = 3,822 lbs/dayusing CXHO = 3,822 lbs/day

• 0.3 x 3,822 lbs/day = 1,147 lbs/day0.3 x 3,822 lbs/day = 1,147 lbs/day• Monthly average limit based on 95% Monthly average limit based on 95%

probability of achieving compliance with 1,147 probability of achieving compliance with 1,147 lbs/day = 1,584 lbs/day using EPA guidance.lbs/day = 1,584 lbs/day using EPA guidance.

3535

Antidegradation for TSSAntidegradation for TSS

• TSS effluent limitationsTSS effluent limitations Monthly Average Daily MaximumMonthly Average Daily Maximum

• Existing 3,646 lbs/dayExisting 3,646 lbs/day 5,694 5,694 lbs/daylbs/day

• Proposed 4,925 lbs/day 7,723 lbs/dayProposed 4,925 lbs/day 7,723 lbs/day

• Fed ELGs 4,925 lbs/day 7,723 lbs/dayFed ELGs 4,925 lbs/day 7,723 lbs/day

• WQBELs TSS does not have numeric WQBELs TSS does not have numeric water quality criteria.water quality criteria.

3636

Antidegradation Demonstration Antidegradation Demonstration for TSSfor TSS

• TSS influent loading to WWTP has the TSS influent loading to WWTP has the potential to increase by as much as 654% potential to increase by as much as 654% based on data from another refinery which based on data from another refinery which has processed the CXHO (Toledo, OH).has processed the CXHO (Toledo, OH).

• Proposed increase from the existing Proposed increase from the existing monthly average limit of 3,646 lbs/day to monthly average limit of 3,646 lbs/day to 4,925 lbs/day is a 35% increase.4,925 lbs/day is a 35% increase.

• Increase reflects the increase in the coking Increase reflects the increase in the coking operations.operations.

3737

Antidegradation Antidegradation DemonstrationDemonstration

• This project will:This project will:• Increase the diversity and security of oil Increase the diversity and security of oil

supplies to the Midwestern United States supplies to the Midwestern United States • Allow the Whiting Refinery to continue to operate Allow the Whiting Refinery to continue to operate

as a viable business and significant employer of as a viable business and significant employer of northwest Indiana northwest Indiana

• Contribute to the tax bases of the cities of East Contribute to the tax bases of the cities of East Chicago, Whiting and Hammond Chicago, Whiting and Hammond

• Create 70 to 80 new full time positions in the Create 70 to 80 new full time positions in the refinery and will also result in thousands of refinery and will also result in thousands of temporary construction jobs temporary construction jobs

3838

Proposed BP Permit Limits Monthly Average

•• TBL WQBEL Current Draft• lbs/day lbs/day lbs/day lbs/day• BOD 6,156 N/A 4,161 4,161• COD 42,980 N/A 30,323

30,323• O&G 1,791 N/A 1,368 1,368• Phenolics 32.8 N/A 20.33 20.33• Sulfide 32.5 N/A 23.1 23.1• Total Chromium 38.1 627 23.9 23.9• Hex Chrom 3.13 54 2.01 2.01• TSS 4,925 N/A 3,646 4,925• Ammonia 3,358 3,215 1,030 1,584

3939

Effluent Limitations Rationale Effluent Limitations Rationale for Outfall 002for Outfall 002

• The effluent limitations for Total Organic The effluent limitations for Total Organic Carbon (TOC), Total Residual Chlorine, pH Carbon (TOC), Total Residual Chlorine, pH and Temperature are identical to the limits and Temperature are identical to the limits in the existing permit.in the existing permit.

• Oil and Grease has the same daily maximum Oil and Grease has the same daily maximum effluent limitation of 5 mg/l, but it is no effluent limitation of 5 mg/l, but it is no longer a net limitation (BP no longer longer a net limitation (BP no longer receives credit for amounts of oil and grease receives credit for amounts of oil and grease in the influent, making the proposed limit in the influent, making the proposed limit more stringent).more stringent).

4040

Effluent Limitations Rationale Effluent Limitations Rationale for Outfalls 003 and 004for Outfalls 003 and 004

• The effluent limitations for Oil and The effluent limitations for Oil and Grease, TOC and pH are identical to Grease, TOC and pH are identical to the limitations in the existing permit.the limitations in the existing permit.

• BP must develop a Storm Water BP must develop a Storm Water Pollution Prevention Program within Pollution Prevention Program within eighteen (18) months from the eighteen (18) months from the permits effective date.permits effective date.

4141

Submit your Questions & Submit your Questions & CommentsComments

• Please complete the forms provided to Please complete the forms provided to submit your questions and comments.submit your questions and comments.

• When completed, submit the forms to When completed, submit the forms to a member of IDEM.a member of IDEM.

• Questions will be addressed this Questions will be addressed this evening, if possible.evening, if possible.

• Comments will be considered in the Comments will be considered in the final permit decision.final permit decision.

4242

Questions? & CommentsQuestions? & Comments• IDEM will now answer questions about the IDEM will now answer questions about the

Draft NPDES PermitDraft NPDES Permit• Comments that you want IDEM to consider Comments that you want IDEM to consider

in the final permit decision should be in the final permit decision should be submitted in writing to:submitted in writing to:

IDEM - Office of Water Quality IDEM - Office of Water Quality Industrial NPDES Permits SectionIndustrial NPDES Permits Section

Attention: Mr. Bill Stenner or Mr. Steve Attention: Mr. Bill Stenner or Mr. Steve RoushRoush

MC 65-42 IGCN Room 1255 MC 65-42 IGCN Room 1255 100 North Senate Avenue 100 North Senate Avenue

Indianapolis, IN 46204-2251Indianapolis, IN 46204-2251