1
TELECON
Call
To:
Raj
Shah
New
Jersey
Department
of
Environmental
Protection
(
609)
633
­
7021
Call
From:
Jill
Lucy,
ERG,
Inc.
Project:
Office
of
Water's
Engineering
and
Analysis
Division
­
304M
Support:
Detailed
Investigation
of
Petroleum
Bulk
Stations
and
Terminals
(
Charge
#
0172.01.005.063)
Date:
October
24,
2003
Subject:
Information
on
State
Permitting
of
Petroleum
Bulk
Stations
and
Terminals
Background
The
purpose
of
the
call
was
to
gather
the
following
information
for
petroleum
bulk
stations
and
terminals:

°
Wastewater
sources
and
discharge
volumes;
°
Common
wastewater
problems
state
has
encountered;
°
Current
state
permitting
practices;
°
Site
wastewater
treatment,
pollution
prevention,
and
recovery
practices;
°
Discharge
status;
°
Obtain
available
permits,
fact
sheets,
and
data;
and
°
Identify
PBSTs
for
site
visits.

Call
Summary
I
spoke
with
Raj
Shah
who
has
issued
permits
to
petroleum
bulk
stations
and
terminals
(
tank
farms)
for
the
New
Jersey
Department
of
Environmental
Protection.
I
wanted
to
discuss
his
state's
current
permitting
practice
for
PBSTs
and
to
gather
general
information
on
wastewater
discharges
from
the
industry
(
see
Background
above).

Mr.
Shah
asked
if
I
would
like
to
meet
to
go
over
the
questions
or
to
talk
over
the
phone.
I
told
Mr.
Shah
that
we
could
discuss
the
questions
over
the
phone
and
that
I
could
e­
mail
the
questions
so
he
would
have
some
time
to
look
at
them
(
and
respond
via
e­
mail
or
phone).
He
said
that
would
be
best;
his
e­
mail
address
is:
raj.
shah@
dep.
state.
nj.
us.
The
e­
mail
with
questions
is
attached
to
this
telecon.

I
asked
Mr.
Shah
if
he
had
any
permits
or
permit
fact
sheets
available
that
he
could
send
to
me.
2
Telecon
­
October
24,
2003
(
NJ
DEP)
He
said
he
would
look
into
it
and
e­
mail
any
electronic
files.
I
also
asked
him
to
look
into
some
potential
sites
that
EPA
could
visit.
Mr.
Shah
will
e­
mail
a
list
of
potential
sites
to
visit
and
said
he
may
be
able
to
attend
the
visits
as
well.
3
Telecon
­
October
24,
2003
(
NJ
DEP)
Attachment:
E­
mail
From:
Jill
Lucy
To:
raj.
shah@
dep.
state.
nj.
us
Date:
Friday
­
October
24,
2003
1:
26
PM
Subject:
Questions
on
Wastewater
Discharges
from
Petroleum
Stations
and
Terminals
Dear
Mr.
Shah,

As
discussed
in
our
phone
call
earlier,
here
are
the
questions
concerning
wastewater
discharges
from
petroleum
bulk
stations
and
terminals
(
PBSTs).
You
do
not
need
to
find
answers
to
every
question,
but
any
information
would
be
greatly
appreciated.

Also,
if
you
have
any
available
permits
or
fact
sheets
for
PBST
sites
that
you
could
send
me
(
either
by
mail
or
electronically),
that
would
be
great.
I
would
appreciate
any
concentration
or
pollutant
loading
data
for
PBST
sites
that
your
state
has
(
either
treated
or
untreated
wastewater
data).

In
addition,
we
are
hoping
to
visit
a
couple
of
PBST
sites
to
tour
their
facility
and
learn
about
any
wastewater
treatment
and
discharge
practices
common
to
the
industry.
If
you
know
of
any
good
sites
to
visit,
that
would
be
great.
We
are
hoping
to
do
that
as
soon
as
possible
so
if
you
identify
any
sites,
please
let
me
know.

Please
give
me
a
call
(
757­
301­
2076)
or
send
me
an
e­
mail
(
jill.
lucy@
erg.
com)
if
you
have
any
questions
or
want
to
discuss
anything.
Thank
you
very
much
for
your
time.
 
Jill
Wastewater
Problems
1.
Does
your
state
have
any
common
wastewater
problems
at
PBST
sites
(
e.
g.,
discharge
of
untreated
wastewater,
storm
water
contamination,
exceeding
permit/
pretreatment
limits)
or
major
incidents
where
discharges
from
PBSTs
caused
damage
to
the
property
or
environment?

If
yes,
are
there
certain
factors
(
e.
g.,
type
of
product,
type
of
tank,
tank
material,
tank
age)
that
tend
to
cause
the
most
wastewater
problems?

2.
Are
there
any
publicly­
owned
treatment
works
(
POTW)
interference
problems
caused
by
wastewater
discharges
from
PBSTs
(
e.
g.,
exceeding
limits,
inhibiting
treatment
due
to
high
pollutant
concentrations)?
4
Telecon
­
October
24,
2003
(
NJ
DEP)
Permits
3.
For
your
state,
what
are
the
permit
requirements
for
PBSTs?
Do
you
have
a
general
permit
(
specific
to
the
industry)
or
do
you
prepare
individual
permits
for
each
site?

4.
How
are(
were)
NPDES
permit
limits
developed
(
e.
g.,
wastewater
treatment
technology,
water
quality
standards,
etc.)?

Types
of
Discharge
5.
Do
you
have
an
idea
of
the
number
(
or
percent)
of
PBST
sites
that
are:
A.
Direct
dischargers;
B.
Indirect
dischargers;
and
C.
No
discharge
sites.

6.
Do
you
have
any
information
on
the
discharge
volume
from
this
industry
(
on
an
industry
and/
or
per
site
basis)?

If
yes,
how
does
this
industry's
discharges
compare
to
other
industries?

7.
How
is
no
discharge
achieved
by
PBSTs
(
e.
g.,
contract
haul
contaminated
water,
reuse/
recycle)?

Wastewater
Sources
and
Pollutants
8.
What
wastewater
sources
and
pollutants
are
you
most
concerned
with
for
this
industry?
What
wastewater
sources
and
pollutants
have
permit
limits
currently?

Treatment
and
Pollution
Prevention
at
PBST
Facilities
9.
Is
the
wastewater
typically
treated
prior
to
discharge?
Are
only
certain
wastewater
streams
treated
(
if
so,
which
ones)?

10.
What
percentage
of
PBST
facilities
have
on­
site
wastewater
treatment
plants?
What
types
of
on­
site
treatment
facilities
are
common
at
petroleum
bulk
stations
and
terminals
(
e.
g.,
oil/
water
separation)?

11.
What
types
of
off­
site
treatment
facilities
are
used
to
treat
wastewater
from
PBSTs?

12.
What
types
of
pollution
prevention/
recovery
practices
are
performed
at
petroleum
bulk
stations
and
terminals?
5
Telecon
­
October
24,
2003
(
NJ
DEP)
Other
State
Permitting
Information
13.
Do
you
have
any
information
available
on
the
annual
number
and/
or
annual
cost
of
permits
or
permit
modifications
for
the
PBST
industry?
How
does
this
compare
to
other
industries?

14.
How
many
PBST
inspections
occur
on
average
each
year
for
your
state?
How
does
this
compare
to
the
number
of
inspections
performed
for
other
industries?

15.
What
percentage
of
PBST
sites
have
a
storm
water
discharge
permit?
For
your
state,
what
are
the
permit
requirements?

16.
How
have
other
EPA
regulations
(
e.
g.,
storm
water,
Clean
Air
Act,
and
Spill
Prevention
Countermeasures
and
Controls
regulations)
affected
wastewater
discharges?

Jill
M.
Lucy
Chemical
Engineer
ERG,
Inc.
(
757)
301­
2076
jill.
lucy@
erg.
com
