MEMORANDUM
DATE:
March
10,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Discharge
status
of
PBST
facilities,
as
enumerated
by
TRI
and
PCS
databases
As
part
of
the
development
of
the
2004/
2005
Effluent
Guidelines
Plan,
a
study
of
the
petroleum
bulk
stations
and
terminal
industry
(
PBST,
SIC
5171)
is
being
conducted.
PBST
was
identified
as
an
industry
of
interest
due
to
stakeholder
comments
and
an
expected
similarity
of
operations
and
wastewater
characteristics
to
those
of
the
petroleum
refining
industry,
which
is
itself
being
evaluated
in
a
very
detailed
manner
by
EPA
for
potential
future
effluent
guidelines
development.
Moreover,
depending
on
the
outcome
of
EPA's
study
of
PBSTs,
a
decision
could
be
made
to
begin
development
of
effluent
guidelines
for
PBSTs
as
a
new
subcategory
under
the
current
petroleum
refining
rule.

Any
assessment
of
PBSTs
will
necessarily
begin
with
an
examination
of
effluent
discharge
characteristics.
Two
EPA
databases,
the
Toxic
Release
Inventory
(
TRI)
and
Permit
Compliance
System
(
PCS)
databases,
are
being
used
to
evaluate
these
wastewaters.
These
databases
were
chosen
because
they
can
identify
toxic
charges
on
a
nationwide
basis
(
TRI)
and
because
they
can
provide
information
about
large
direct
dischargers
in
an
industry
(
PCS).
While
it
is
true
that
there
are
some
limitations
in
both
databases
(
e.
g.,
PCS
does
not
reveal
much
information
about
small
direct
dischargers
and
none
about
indirect
dischargers),
EPA
believes
that
both
are
useful
as
a
"
first­
cut"
examination
tool.

The
attached
MS
Excel
spreadsheet
lists
those
facilities
reporting
discharges
in
TRI
and
PCS.
The
number
of
PBSTs
reporting
discharges
to
TRI
in
2000
was
167
(
the
total
number
of
PBSTs
reporting
to
TRI
was
502),
while,
in
PCS,
eight
PCS
"
major"
dischargers
reported.
Of
the
167
TRI
reporters,
125
were
solely
direct
and
27
were
solely
indirect,
with
the
remaining
15
being
both
direct
and
indirect
dischargers.
The
125
solely
direct
dischargers
accounted
for
5,325
toxicweighted
pound­
equivalents
(
TWPE)
discharged,
while
the
solely
indirect
discharging
facilities
discharged
8
TWPE.
The
15
facilities
that
were
both
direct
and
indirect
dischargers
accounted
for
2,677
TWPE
discharged.
The
eight
PCS
major
dischargers
reported
discharging
5,389
TWPE.

One
final
note
regarding
the
TRI
reports:
with
only
167
of
502
reporting
facilities
reporting
discharges
to
surface
waters,
zero­
dischargers
account
for
nearly
two­
thirds
(
335
of
502)
of
the
reporting
facilities.
Whether
this
proportion
can
be
considered
representative
of
the
industry
as
a
whole
is
not
yet
clear,
though
it
is
clearly
an
item
for
future
study.
