1
PBST
Detailed
Study
Plan
­
Revised
December
29,
2003
PETROLEUM
BULK
STATIONS
AND
TERMINALS
(
PBST)
DETAILED
STUDY
PLAN
December
29,
2003
General
Steps
1.
Gather
Information
°
Industry
demographics
(
profile)
°
Baseline
pollutant
loads
°
Identify
pollutants
of
concern
°
Applicable
control
technology
(
includes
wastewater
treatment
and
pollution
reduction
alternatives)

2.
Develop
Model
Facilities
and
Scale­
Up
Procedures
3.
Develop
Control
Options
°
Estimate
costs

Capital
and
operating
costs

Regulatory
costs
°
Estimate
pollutant
reductions
4.
Prepare
Report
and
Documentation
1.
Gather
Information
Information
Needs
°
Discharge
status
(
number
of
facilities
with
direct,
indirect,
and
zero
discharge);
°
Reasons
why/
how
certain
facilities
are
zero
discharge;
°
Identification
of
"
best
performing"
facilities
that
may
be
used
to
identify
best
available
technology
economically
achievable
(
BAT)
control
technologies;
°
Pollution
reduction
technologies,
their
costs,
and
pollutant
reduction
potential;
°
Extent
of
pollution
prevention/
recovery
practices
in
place;
and
°
Impact
of
EPA's
stormwater,
SPCC,
and
other
regulations.

Industry
Profile
and
Identification
of
Pollutants
of
Concern
°
Review
permits
and
fact
sheets
from
states
and
EPA
regions.

°
Review
TRI
for
percent
of
discharged
wastewater
from
storm
water
and
treatment­
in­
place.
2
PBST
Detailed
Study
Plan
­
Revised
December
29,
2003
°
Review
TRI
data
to
estimate
number
of
zero,
indirect,
and
direct
dischargers.

°
Review
the
facility
list
and
capacities
provided
in
the
2001
Bulk
Liquid
Terminals
and
Storage
Facilities
directory
from
the
Independent
Liquid
Terminals
Association.

°
Review
model
facilities
developed
for
the
Gasoline
Distribution
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAPS).

°
Check
for
any
relevant
industry
data
on
the
Energy
Information
Administration
(
EIA)
web
site.

°
Coordinate
with
petroleum
refinery
detailed
study
to
identify
facilities
incorrectly
classified
in
TRI
as
refineries
that
are
PBSTs.

°
Identify
approximately
two
PBST
facilities
for
site
visits.

Questions
to
address:

°
How
should
the
industry
be
divided
for
model
sites?
Possible
factors
may
include:
quantity
of
discharge,
type
of
wastewater
discharged,
petroleum
products
stored,
facility
type,
geographic
particulars,
and
size
of
facility
(
e.
g.,
product
throughput).

°
Are
facilities
not
reporting
wastewater
discharges
to
TRI
because
they
are
zero
discharge
or
because
they
are
not
required
to
report
(
e.
g.,
less
than
10
employees,
below
reporting
thresholds)?

°
What
are
sources
of
wastewater,
their
volumes,
and
relation
to
PBST
operations
or
types
of
products
stored?

°
What
influences
the
volumes
and
pollutant
loads?

°
How
can
these
relationships
be
used
in
developing
model
sites?

Baseline
Pollutant
Loads
°
Revise
baseline
loads
and
assumptions
used
for
the
August
2003
analysis
based
on
additional
information.

°
From
petroleum
refining
detailed
study:
using
references
from
TRI
guidance,
characterize
the
individual
PACs
in
various
petroleum
products
(
mass:
mass
and
mass:
volume)
and
develop
a
petroleum
product
PAC
toxic
weighting
factor.
3
PBST
Detailed
Study
Plan
­
Revised
December
29,
2003
Questions
to
address:

°
What
pollutants
are
discharged
and
how
much
(
base
year
is
2000)?

°
Where
do
the
discharged
pollutants
come
from
(
i.
e.,
is
there
a
sub­
sector
of
the
industry
that
is
responsible
for
high
toxic
loads)?

°
Does
the
industry
discharge
non­
trivial
amounts
of
toxic
pollutants
on
an
industry
and
per
facility
basis?
(
If
the
discharges
from
some
sites
are
trivial,
is
there
a
way
to
classify
this
group
of
sites,
then
exclude
them
from
further
analysis?)

Applicable
Control
Technology
°
Identify
current
control
technology
used
at
PBSTs
(
e.
g.,
oil/
water
separators,
granulated
activated
carbon
(
GAC)).
Use
permit
writer
contacts
and
trade
associations
to
identify
technologies
and
vendors.

°
Identify
vendors
and
talk
to
them
about
current
control
technologies
and
their
use
at
PBSTs.

°
Identify
any
additional
control
technologies
and
pollution
prevention
alternatives
that
can
be
applied
to
PBSTs
to
reduce
discharges
of
toxic
pollutants
through
literature
search
and
talk
with
treatment
control
technology
vendors.

°
For
identified
control
technologies,
evaluate
the
potential
cost
in
terms
of
pound
of
toxic
pollutants
removed.

2.
Develop
Model
PBST
Sites
and
Scale­
up
Procedures
°
Identify
parameters
that
will
be
used
to
define
the
models
(
e.
g.,
capacity,
discharge
status,
processes,
treatment­
in­
place,
wastewater
discharge
types,
products
stored).
These
parameters
will
relate
to
PBST's
pollution
generation
rates,
the
feasibility
of
control
technologies,
and
technology
costs.

°
Develop
3
to
10
"
model
sites,"
defined
in
terms
of
the
parameters
identified.

°
Develop
scheme
to
scale­
up
models
to
full
industry
(
i.
e.,
develop
the
weights
or
scale­
up
factors
that
will
be
applied
to
each
model).

°
To
the
extent
possible
validate
the
model
(
may
be
limited
to
pollutant
discharges
­
do
baseline
model
discharges,
extrapolated
by
scale­
up
procedure,
result
in
the
total
reported
discharges
(
PCS
&
TRI)?).
4
PBST
Detailed
Study
Plan
­
Revised
December
29,
2003
°
Search
for
literature
(
e.
g.,
from
vendors)
or
case
studies
for
potential
use
in
validating
model
costs.

3.
Develop
Control
Options
Including
Estimating
Costs
and
Pollutant
Reductions
°
Identify
applicability
of
existing
stormwater
regulations
and
PBST
general
permits.

°
Identify
feasible
pollution
reduction
technologies.
Investigate:


Internal
waste
stream
management
 
keep
pollutant­
bearing
streams
in
the
process
by
leak
and
spill
prevention
and
divert
clean
stormwater
from
wastewater
treatment
plants.


Process
changes
that
will
eliminate
or
reduce:

S
wastewater
discharge
volume
(
e.
g.,
use
collected
storm
water
or
petroleum
products
for
hydrostatic
testing,
use
of
green
roofs);
or
S
amount
of
pollutants
discharged
to
wastewater
(
leak
and
spill
prevention).


End­
of­
pipe
treatment
(
e.
g.,
oil/
water
separator).

°
Collect
capital
and
operating
cost
and
performance
information
for
relevant
model
site
applications.
Also
collect
information
on
monitoring
and
reporting
requirements.
Data
sources
include
calls
with
permit
writers,
literature
reviews,
and
contacting
equipment
vendors
(
get
prices
for
sizes
that
reflect
the
model
sites).

°
Estimate
costs
and
pollutant
reductions
achievable
by
implementing
the
control
options
at
each
model
site
and
scale­
up
to
estimate
the
costs
and
reductions
achievable
for
the
entire
industry.
Format
of
output
must
be
useable
by
economists
for
analyzing
economic
impact
and
cost
effectiveness.

°
Consider
non­
water
quality
impacts,
particularly
air
emissions
and
Resource
Conservation
and
Recovery
Act
(
RCRA)
hazardous
waste
regulations
(
i.
e.,
would
any
of
the
residues
created
by
wastewater
treatment
be
hazardous
wastes?).

Questions
to
address:

°
Are
there
PBST
sites
that
directly
discharge
wastewater
(
including
contaminated
stormwater)
without
treatment
(
i.
e.,
no
oil/
water
separator)?
5
PBST
Detailed
Study
Plan
­
Revised
December
29,
2003
°
What
percentage
of
the
industry
discharge
tank
bottom
waters?
What
treatment
technology
do
they
use
(
e.
g.,
biological
treatment)?

°
Does
the
treatment
of
wastewater
at
direct
discharging
sites
differ
from
the
treatment
of
wastewater
from
indirect
discharging
sites?

°
Should
other
technologies
be
applied
to
the
industry
(
e.
g.,
to
control
discharge
of
organic
pollutants)?
What
will
they
cost
on
an
industry
and
per
facility
basis?

°
Do
publicly­
owned
treatment
works
(
POTWs)
adequately
treat
wastewater
from
indirect
dischargers
(
i.
e.,
control
discharge
of
organic
pollutants)?

°
How
much
will
implementing
these
solutions
reduce
pollutant
discharges
from
direct
and
indirect
dischargers?
Eliminate
technologies
that
are
too
expensive
from
further
analysis.

4.
Prepare
Report
and
Documentation
Draft
study
report
will
include:

°
Industry
profile;
°
Baseline
pollutant
loads
(
including
TWPE);
°
Descriptions
of
pollution
control
options;
°
Costs
&
removals
for
each
analyzed
option;
°
Documentation
of
the
methodology
used
to
estimate
costs
and
pollutant
reductions;
and
°
Discussion
of
the
quality
of
the
data
used
for
these
estimates,
including
"
data
gaps."
