Effluent Limitation Guidelines, Pretreatment Standards, and New Source Performance Standards for the Centralized Waste Treatment Point Source Category

October 10, 2003 Water Docket Attention: Docket ID No. OW-2003-0075 Environmental Protection Agency Mailcode 4101T 1200 Pennsylvania Avenue, NW Washington, DC 20460 Re:Proposed Effluent Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards for the Centralized Waste Treatment Point Source Category (68 Fed. Reg. 53431), Docket ID No. OW-2003-0075 Dear Mr. Forsht: The American Petroleum Institute (API) appreciates the opportunity to provide comments on the proposed revisions to U.S. Environmental Protection Agency's (EPA) Proposed Effluent Limitations Guidelines, Pretreatment Standards, and New Source Performance Standards for the Centralized Waste Treatment Point Source Category (68 Fed. Reg. 53431, September 10, 2003). As a national trade association representing more than 400 member companies involved in all aspects of the oil and natural gas industry, API has a direct and substantial interest in any changes that may be made to regulations implementing the National Pollutant Discharge Elimination System (NPDES). API has been engaged with EPA on effluent guidelines for nearly 30 years, now, and we consider the effluent guidelines program one of the most successful at EPA. API supports deletion of selenium from all portions of these guidelines. API members over the years have come to understand that the chemistry of selenium in our industry is complex, challenging to understand, challenging to predict, and challenging to manage. EPA acknowledges that in the model technology used in developing the guidelines, selenium is only removed in the final treatment step, sand filtration [68 FR 53435]. This suggests that the selenium being removed is in a precipitated or solid form, or is otherwise associated with suspended solids. However, in our industry, several species of selenium (including SeCN-, HSeO3-, SeO4=) are soluble and not removed by sand filtration. Although discharge levels of dissolved species are typically lower than guideline limits, these levels are a complex function of factors such as pH, temperature, the history of the wastewater, the nature of the treatment system, etc., and so are highly variable and difficult to determine. Since the model technology does not remove dissolved selenium, and discharge levels of dissolved selenium are not predictable, API recommends deletion of selenium altogether from these effluent guidelines. API appreciates the opportunity to comment on the proposed revisions to the effluent guidelines for the centralized waste treatment subcategory. Please contact me if you have any questions concerning our comments (202-682-8399). Sincerely, Roger E. Claff, P.E. Senior Environmental Scientist cc: M. Koch