2.
Petroleum
Storage
and
Transportation
a.
Permitting
Strategy
(
1)
Facility
Type:
The
permitting
recommendations
described
below
are
for
wet
weather
flows
from
facilities
that
store
petroleum
products
(
bulk
oil
facilities)
and
pipeline
companies.
Effluents
from
petroleum
storage
facilities
and
pipelines
have
similar
characteristics
and
can
be
permitted
with
similar
limitations
and
monitoring
requirements.
If
the
facility
has
dry
weather
flows,
the
permit
writer
should
consider
different
effluent
parameters,
limits
and/
or
monitoring
frequencies.
Dry
weather
flows
should
have
been
identified
on
the
permit
application
or
site
inspection
report.
Hydrostatic
test
discharges
are
addressed
by
this
guidance.
(
2)
Colonial
Pipeline
Colonial
Pipeline
Co.
has
numerous
facilities
scattered
throughout
the
state
serving
as
booster
pump
stations.
They
are
similarly
constructed,
have
similar
sources
of
waste
and
similar
treatment.
Most
discharge
into
a
dry
ditch
or
small
stream
that
provides
little
or
no
dilution
at
the
discharge
point.
However,
if
the
facility
does
not
have
a
discharge,
no
permit
is
required.
The
sources
of
wastewater
are:
(
a)
Wash
pad
water
­
needs
to
meet
BPJ
technology
limits
for
TPH;
(
b)
Contaminated
water
from
manifold
yard
­
needs
to
meet
BPJ
technology
limits
for
TPH;
(
c)
Uncontaminated
site
runoff
­
no
limits
at
this
time;
or
(
d)
Hydrostatic
test
water.
Sources
(
a)
and
(
b)
are
treated
by
an
oil
water
separator
which
discharges
into
a
retention
basin.
Source
(
c)
enters
the
retention
basin
untreated.
Source
(
d)
receives
unspecified
treatment
and
then
enters
the
retention
basin.
The
final
discharge
of
all
waters
is
from
the
retention
basin.
Write
these
permits
according
to
the
following
guidelines:
Define
the
oil/
water
separator
effluent
as
internal
outfall
101
and
apply
to
it
BPJ
technology
limits
for
TPH
of
15
mg/
l
maximum.
Define
the
effluent
from
the
retention
basin
as
outfall
001
and
apply
any
needed
water
quality
standard
limits
to
it.
If
the
permit
is
written
according
to
the
above
guidance,
no
TMP
is
needed
at
this
time.
If
the
discharge
is
such
that
significant
dilution
is
available
then
WQS
limits
may
be
calculated
for
BTEX
based
on
that
dilution.
(
3)
Individual
vs
General
Permit:
Bulk
oil
facilities
(
SIC
Code
5171
with
vehicle
maintenance)
may
be
covered
under
a
General
Storm
Water
Permit
instead
of
an
individual
VPDES
permit
unless
antibacksliding
prevents
converting
those
with
an
existing
individual
permit.
If
the
facility
does
not
qualify
for
the
general
permit
and
vehicle
maintenance
or
equipment
cleaning
activities
take
place
on
site,
include
the
section
on
Storm
Water
Management
with
the
individual
permit.
Vehicle
maintenance
includes
vehicle
rehabilitation,
mechanical
repairs,
painting,
fueling
and
lubrication
(
4)
Tank
bottom
waters:
Tank
bottom
water
discharges
should
be
classified
as
process
wastewater,
due
to
their
high
level
of
pollutants.
No
direct
discharge
of
tank
bottom
waters
is
allowed.
The
permittee
who
questions
this
restriction
has
3
options,
which
should
be
discussed
with
them:
(
a)
Pump
and
haul
with
offsite
treatment
and
disposal;
(
b)
Discharge
through
a
permitted
outfall
after
appropriate
treatment
in
addition
to
an
oil/
water
separator.
The
type
of
treatment
is
left
to
the
permittee,
bearing
in
mind
that
the
higher
degree
of
treatment
would
lessen
the
probability
of
toxic
effects;
or
(
c)
Discharge
to
a
"
holding
area"
for
evaporation.
The
"
holding
area"
may
be
a
pond
or
diked
area
which
has
a
10­
6
cm/
sec
coefficient
of
permeability.
This
alternative
would
also
require
ground
water
monitoring,
which
could
be
part
of
the
VPDES
permit
or
the
AST
regulation
requirements.
For
tank
bottom
waters,
an
internal
outfall
with
limits
for
BTEX
(
and
naphthalene
and
lead,
if
applicable)
should
be
established.
Virginia
Water
Quality
Standards
do
not
address
acute
and
chronic
toxicity
for
BTEX
and
naphthalene,
thus
DEQ
has
established
chronic
aquatic
toxicity,
instream
values
for
these
chemicals.
The
final
effluent
limits
in
the
General
VPDES
Permit
for
Discharges
from
Petroleum
Contaminated
Sites,
VAG83
are
established
as
instream
values
and
should
be
used
as
permit
maximums.
The
general
permit
limits
assume
zero
dilution
in
the
receiving
stream.
Where
dilution
exists,
the
limits
can
be
adjusted
as
long
as
the
resulting
mix
will
not
exceed
the
instream
values
listed.
(
5)
Ground
Water
Monitoring:
The
purpose
of
a
ground
water
monitoring
program
is
to
determine
if
activities
at
the
site
are
resulting
in
violations
of
the
Board's
Ground
Water
Standards.
The
ground
water
monitoring
program
should
concentrate
on
at
least
the
two
following
parameters:
Total
Petroleum
Hydrocarbons
(
TPH)
and
Total
Organic
Carbon
(
TOC).
These
parameters
should
provide
an
indication
of
the
presence
and
amount
of
pollution,
plus
numeric
values
with
which
a
comparison
can
be
made,
in
order
to
evaluate
the
need
for
remediation.
Ground
water
monitoring
at
jobber
type
oil
facilities
is
optional
and
should
be
evaluated
on
a
case­
bycase
basis.
Note:
Omit
this
requirement
for
facilities
subject
to
a
ground
water
monitoring
plan
requirement
as
part
of
the
AST,
ODCP
regulations
(
having
>
1
million
gallon
aggregate
storage
capacity).
(
6)
Toxics
Management
Program
(
TMP):
A
TMP
is
required
for
facilities
that
are
large
bulk
oil
storage
or
distribution
centers
and
for
pipeline
terminals.
Smaller,
petroleum
jobber­
type
storage
facilities
that
provide
petroleum
products
to
end
consumers
may
need
a
TMP,
depending
on
various
factors,
including
the
site
characteristics
(
presence
of
oil/
water
separators,
etc),
age
and
condition
of
facilities,
and
past
performance.
(
7)
Hydrostatic
Tank
Testing:
If
it
is
anticipated
that
hydrostatic
testing
will
be
performed
and
a
discharge
produced,
include
a
limit
for
TPH.
If
hydrostatic
test
discharges
will
occur
more
than
once
every
three
years,
the
permit
writer
should
consider
including
limits
for
BTEX
parameters
similar
to
those
in
the
Petroleum
Discharges
General
Permit,
VAG83.
Depending
on
site
characteristics
and
the
potential
for
public
concern,
the
permit
can
include
a
requirement
for
notification
of
and
approval
from
the
DEQ
Regional
Office
prior
to
the
discharge
actually
taking
place.
Address
hydrostatic
tank
testing
discharges
either
as
a
special
condition
or
label
the
discharge
as
an
internal
outfall
and
limit
it
on
a
separate
Part
I
A
page.
In
order
to
avoid
problems
with
CEDS
and
PCS,
these
infrequent
discharges
may
be
better
handled
in
special
conditions
rather
than
as
internal
outfalls.
Internal
outfalls
require
monthly
DMRs
whereas
special
condition
reporting
can
be
on
a
per
discharge
basis.
In
either
case,
the
limits
are
only
applicable
when
there
is
a
discharge
of
hydrostatic
test
water.

b.
Form
2C
Minimum
Testing
Requirements
(
For
process
water
discharge
[
tank
bottom
waters,
hydrostatic
test
waters,
loading
rack
washdown
waters])
The
applicant
must
test
for
and
report
all
parameters
unless
a
written
waiver
request
has
been
submitted
and
granted.
The
applicant
may
request
and
be
granted
a
waiver
for
all
except
the
following
parameters:
(
1)
Part
A
­
BOD
TOC
TSS
pH
Flow
(
2)
Part
B
­
must
provide
results
for
Oil
&
Grease
and
any
other
parameters
"
believed
present".
(
3)
Part
C
­
must
provide
results
for
any
parameters
"
believed
present".
OWPP
recommends
testing
for
BTEX.

c.
Form
2F
Minimum
Testing
Requirements
(
For
point
source
discharge
of
storm
water
associated
with
industrial
activity)
(
1)
Part
A
­
must
test
for
and
report
all
parameters
listed.
(
2)
Part
B
&
C
­
must
provide
results
for
any
parameters
"
believed
present".
(
3)
Part
D
­
must
provide
storm
event
data
corresponding
to
the
maximum
values
given
in
Parts
A,
B,
&
C.

d.
Suggested
Effluent
Limitations
&
Basis
These
limits
assume
the
discharge
is
treated
with
a
minimum
treatment
technology
comparable
to
an
oil/
water
separator.

(
)
Final
Limits
(
)
Interim
Limits
Outfall
No.
Design
Flow
Effective
Dates:
EFFLUENT
LIMITATIONS
MONITORING
REQUIREMENTS
PARAMETER
BASIS
FOR
LIMITS
MONTHLY
AVERAGE
MINIMUM
MAXIMUM
FREQUENCY
SAMPLE
TYPE
Flow
NA
NL
NA
NL
1/
M
Estimate
TPH
(
mg/
l)
BPJ
NL
NA
15
1/
M
Grab
pH
(
s.
u.)
3
NA
*
*
1/
M
Grab
Technology­
based
Limits:
BPJ
Water
Quality­
based
Limits:
1.
208
Plan
2.
303(
e)
Plan
3.
Water
Quality
Standards
4.
Other
(
e.
g.
wasteload
allocation
model)

NL
=
No
Limitation,
monitoring
required
NA
=
Not
Applicable
a.
The
effluent
shall
be
free
of
sheens.
There
shall
be
no
discharge
of
floating
solids
or
visible
foam
in
other
than
trace
amounts.
b.
There
shall
be
no
discharge
of
tank
bottom
waters
c.
All
samples
shall
be
collected
from
the
discharge
resulting
from
a
storm
event.
The
grab
samples
shall
be
taken
during
the
first
3
hours
30
minutes
of
discharge
*
Establish
pH
limits
that
will
maintain
water
quality
standards
in
the
receiving
stream
Hydrostatic
Test
Waters
are
subject
to
the
following
effluent
limitations
and
monitoring
requirements:

(
)
Final
Limits
(
)
Interim
Limits
Outfall
No.
Design
Flow
Effective
Dates:
to
EFFLUENT
LIMITATIONS
MONITORING
REQUIREMENTS
PARAMETER
BASIS
FOR
LIMITS
MONTHLY
AVERAGE
MINIMUM
MAXIMUM
FREQUENCY
SAMPLE
TYPE
Flow
NA
NL
NA
NL
1/
Discharge
Estimate
TPH
(
mg/
l)
BPJ
NL
NA
15
1/
Discharge
Grab
Technology­
based
Limits:
BPJ
NL
=
No
Limitation,
monitoring
required
NA
=
Not
Applicable
Add
limits
for
BTEX,
naphthalene,
lead,
etc
if
discharge
will
occur
more
than
once
in
three
years.

a.
The
effluent
shall
be
free
of
sheens.
There
shall
be
no
discharge
of
floating
solids
or
visible
foam
in
other
than
trace
amounts.
b.
See
Part
I
B
for
Quantification
Levels
and
reporting
instructions.

e.
Special
Conditions
The
following
special
conditions
should
be
included
in
permits
for
petroleum
storage
or
transportation
facilities.
See
the
earlier
parts
of
Section
IN
for
rationale
and
special
condition
language
unless
specified
below.
 
Notification
Levels
 
Materials
Handling/
Storage
 
Operation
and
Maintenance
Manual
Requirement
 
Toxic
Management
Program
(
TMP)
 
Water
Quality
Criteria
Monitoring
(
Include
for
all
facilities
which
require
a
TMP)
 
Quantification
Levels
(
Include
for
water
quality­
based
parameters,
if
applicable.
Adapt
for
BTEX,
lead
and
naphthalene)
 
Ground
water
Monitoring
Program
Oil
Storage
Ground
Water
Monitoring
Reopener
(
for
facilities
covered
under
UST
or
AST
program)
As
this
facility
currently
manages
ground
water
in
accordance
with
9
VAC
25­
90­
10
et
seq.,
Oil
Discharge
Contingency
Plans
and
Administration
Fees
for
Approval
the
Facility
and
Aboveground
Storage
Tank
Regulation,
this
permit
does
not
presently
impose
ground
water
monitoring
requirements.
However,
this
permit
may
be
modified
or
alternately
revoked
and
reissued
to
include
ground
water
monitoring
not
required
by
the
ODCP
this
regulation.
 
Hydrostatic
Testing
Hydrostatic
Testing
(
this
special
condition
is
required
for
hydrostatic
testing
if
it
is
not
set
up
as
an
internal
outfall
on
a
Part
I
A.
page).
[
Include
this
part
if
necessary:
The
permittee
shall
obtain
approval
from
the
DEQ
Regional
Office
forty­
eight
hours
in
advance
of
any
discharge
resulting
from
hydrostatic
testing.
The
conditions
of
approval
will
be
contingent
on
the
volume
and
duration
of
the
proposed
discharge,
and
the
nature
of
the
residual
product.]
Every
discharge
of
hydrostatic
testing
waters
shall
be
monitored
and
limited
as
specified
below.
Sampling
will
be
required
for
characterization
of
the
"
first
flush",
as
a
minimum.
Report
results
with
the
DMR
for
the
month
in
which
hydrostatic
testing
and
sampling
occurred.
Such
discharges
shall
be
limited
as
follows:
Parameter
Maximum
Limitation
Flow
Report
flow
volume
as
MGD
TPH
15
mg/
l
Add
limits
for
BTEX,
naphthalene,
lead,
etc
if
discharge
will
occur
more
than
once
in
three
years.

All
samples
shall
be
grab
samples.
The
effluent
shall
be
free
of
sheens.

Rationale:
(
TPH
limit
is
BPJ.
See
the
fact
sheet
for
the
VPDES
general
permit
for
Discharges
from
Petroleum
Contaminated
Sites,
VAG83
for
the
basis
for
effluent
limits
for
BTEX,
lead
and
naphthalene
if
discharge
is
more
than
once
per
three
years.)
