MEMORANDUM
DATE:
April
29,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Summary
of
discussions
with
permit
writers
about
PBST
facilities
As
part
of
the
detailed
study
examining
the
Petroleum
Bulk
Stations
and
Terminals
(
PBST)
industry,
discussions
are
taking
place
with
permit
writers
and
compliance
authorities
from
across
the
US.
In
addition,
permits
from
"
heavy
hitter"
facilities,
as
identified
by
the
TRI
and
PCS
databases
are
being
studied.

The
following
permit
writers
and
compliance
officials
have
spoken
with
EPA
as
part
of
this
effort:

°
Jim
Ball
and
Eric
Beck,
Rhode
Island
Department
of
the
Environment,
Providence,
RI;
°
George
Papadopoulos,
EPA
Region
1,
Boston,
MA;
°
Dave
Basinger,
EPA
Region
9,
San
Francisco,
CA;
°
Lila
Tang,
California
State
Water
Control
Board
(
CSWCB),
San
Francisco,
CA;
and
°
Phil
Isorena,
CSWCB,
Sacramento,
CA.

These
individuals
have
been
selected
for
one
of
several
reasons,
as
follows:

°
"
Heavy
hitter"
facilities
are
in
their
jurisdiction
°
Permit
controls
are
ambitious
in
their
jurisdiction
°
Identification
of
expertise
by
stakeholders
Conversations
with
all
those
contacted
have
used
a
standard
phone
script
as
a
guide,
a
copy
of
which
is
attached
to
this
memorandum.

Not
surprisingly,
given
the
simplicity
of
the
operations
of
the
industry,
observations
by
control
authorities
tend
to
be
fairly
homogeneous.
Contaminated
stormwater,
tank
bottoms
water,
and
equipment
wash
water
are
identified
as
the
main
sources
of
toxic
pollutant
discharges.
Dave
Basinger,
of
EPA
Region
9'
s
Compliance
Office,
also
notes
that
ballast
water
is
a
significant
source
of
wastewater,
by
volume,
at
those
PBSTs
that
are
close
to
bodies
of
water.
Basinger
also
speculates
that,
at
very
active
PBSTs
with
high
product
turnover,
tank
bottoms
water
can
be
the
largest
source
of
wastewater.
In
this
case,
the
tank
bottoms
will
be
composed
of
water
that
was
in
the
product
to
begin
with.
Such
PBSTs
would
have
unusually
toxic
and
voluminous
tank
bottoms
wastestreams.

In
the
northeastern
United
States,
where
PBSTs
tend
to
be
rather
old,
a
significant
problem
seems
to
be
groundwater
contamination.
In
cases
where
tanks
rest
directly
on
the
ground,
pollutants
can
spill
onto
the
ground
or
actually
leach
out
of
the
tanks
and
into
the
ground.
Jim
Ball,
of
Rhode
Island,
and
George
Papadopoulos,
of
EPA
Region
1,
note
that
this
has
been
observed
to
allow
the
introduction
of
oxygenates,
like
MTBE,
into
groundwater.

Since
PBSTs
handle
petroleum
products,
it
is
not
surprising
that
petroleum
hydrocarbons
and
additives
are
identified
as
the
main
pollutants
discharged.
Oil
and
grease,
BTEX,
PACs,
diesel
and
gasoline
constituents,
oxygenates,
and
TSS
are
widely
monitored
for
in
permits.
Unfortunately,
no
control
authority
spoken
with
could
identify
any
specific
PAC
as
a
particular
source
of
trouble.
Interestingly,
George
Papadopoulos,
of
EPA
Region
1,
notes
that
current
methods
are
having
difficulty
isolating
PACs
in
wastewater
samples
in
the
Northeast.
The
Region
1
office
is
in
the
process
of
collecting
analytical
laboratory
reports
and,
absent
any
further
guidance,
will
consider
using
TPH
as
an
indicator.
PACs
are
of
special
interest
to
EPA
due
to
their
high
toxic
weights.
The
reason
most
commonly
given
for
the
inability
to
target
any
particular
PACs
is
that
PBSTs
handle
a
wide
variety
of
products,
with
each
having
its
own
unique
components.

In
response
to
a
question
about
API's
contention
that
in
excess
of
50
percent
of
PBSTs
closely
associated
with
an
oil
refinery
send
their
tank
bottoms
water
to
the
refineries,
several
control
authorities
(
Lila
Tang
and
Phil
Isorena,
of
the
California
State
Water
Control
Board,
Eric
Beck,
of
Rhode
Island,
and
Basinger)
were
able
to
verify
the
existence
of
the
practice,
though
none
was
able
to
identify
its
prevalence.
All
noted
that
a
PBST
doing
this
would
be
paying
the
refinery
for
treatment
(
in
this
case,
the
refinery
would
be
operating
as
a
centralized
waste
treatment
facility).
None
are
able
to
comment
about
API's
contention
that
tank
bottoms
water
is
used
as
feedstock
to
distillation
columns
for
oil
recovery
operations.

On
the
question
of
treatment­
in­
place,
to
a
great
extent
it
depends
on
the
size
of
the
facility.
It
seems
that
very
small
facilities
are
fairly
likely
to
have
their
wastewater
shipped
off­
site,
with
larger
facilities
using,
at
a
minimum,
oil/
water
separation.
Those
in
the
Northeast
and
California
have
noted
the
increasing
use
of
activated
carbon
beds
a
as
polishing
step
before
discharge.
Beck
notes
that,
in
Rhode
Island,
this
is
because
an
internal
consensus
has
been
reached
that,
at
this
time,
the
use
of
activated
carbon
is
now
an
appropriate
technology
basis
for
effluent
limitations.
Groundwater
contamination
should
not
be
considered
a
driver,
in
this
case,
because,
after
all,
effluent
limits
don't
impact
groundwater
profiles.

In
California,
extremely
tight
discharge
limits
at
PBSTs
(
and
other
industrial
sites,
for
that
matter)
are
largely
the
result
of
the
1988
State
Water
Control
Board
Resolution
declaring
that
all
California
surface
waters
are
to
be
considered
suitable
or
potentially
suitable
drinking
water
supplies
(
Resolution
No.
88­
63,
Adoption
of
Policy
Entitled
"
Sources
of
Drinking
Water").
Isorena
states
that
limits
for
BTEX,
MTBE,
and
many
other
constituents
are
often
set
below
10
ppb.
Basinger
states
that
biological
treatment
is
not
widely
used
at
PBSTs
because
the
widely
varying
stored
products
lead
to
widely
varying
wastestream
pollutant
profiles,
a
potentially
damaging
situation
for
the
microorganism
typically
used
in
these
types
of
systems.
Basinger
also
notes
that,
where
multiple
tank
farms
are
part
of
a
very
large
oil
refinery
site
and
are
widely
spread
out,
each
PBST
is
likely
to
have
its
own
treatment
system
(
rather
than
a
combined
system).

Pollution
prevention
is
become
more
widely
used
at
PBSTs,
if
for
no
other
reason
than
in
response
to
EPA
spill
control
rules.
Along
with
the
construction
of
dikes
around
tank
areas
to
control
the
flow
around
tanks
of
contaminated
stormwater
and,
in
catastrohic
cases,
product
itself,
the
use
of
BMPs
is
now
becoming
more
common.
Isorena
states
that
facilities
no
longer
drain
tank
bottoms
water
directly
to
the
ground.
Basinger
notes
that
spills
from
the
barges
and
trucks
handling
the
products
are
now
handled
in
a
much
improved
manner
and
that
facilities
are
now
becoming
more
vigilant
about
accepting
out­
of­
spec
materials.
In
the
event
that
an
out­
ofspec
material
is
received,
PBSTs
will
now
send
the
product
back
to
the
producing
refinery.

All
agree
that,
along
with
SPCC,
EPA's
stormwater
rules
have
lowered
the
discharges
of
toxic
pollutants
from
PBSTs,
through
segregation
and
better
waste
management.
However,
none
was
able
to
quantify
this
assertion
to
any
great
extent.

Permitting
these
facilities
is
mostly
done
on
a
per­
facility
basis.
Texas
has
a
general
permit,
which
is
used
as
the
basis
for
all
permits
in
that
state,
but
other
states
have
no
such
guide
to
ease
permit
development.
Rhode
Island
notes
that
permit
development
is
no
great
burden
as
there
are
only
seven
PBSTs
(
according
to
Beck)
in
the
state,
while
Tang
notes
that,
in
the
San
Francisco
Bay
area
of
California,
virtually
all
PBSTs
have
become
indirect
dischargers,
with
the
relevant
POTWs
issuing
the
permits.

Finally,
all
had
great
difficulty
addressing
the
issue
of
the
prevalence
of
zero­
discharge
in
this
industry.
Beck
speculated
that
small
facilities
are
the
most
likely
to
be
zero­
discharge,
with
it
being
likely
that
such
facilities
are
unable
to
afford
the
operation
of
a
treatment
system.
However,
in
the
case
of
the
Exxon
East
Providence
Terminal,
he
notes,
since
it
is
associated
with
an
Exxon
refinery,
it
sends
its
wastewater
through
the
refinery's
groundwater
treatment
system.
Possible
Questions
for
Permit
Writers
regarding
PBSTs
9.
What
are
the
wastewater
sources
at
the
permitted
facilities?
Which
wastestreams
contribute
the
majority
of
the
pollutants
discharged?
In
what
quantities/
volumes
are
they
discharged
(
address
all
pollutants,
including
those
that
are
toxic)?
Do
any
of
the
permitted
facilities
discharge
their
tank
bottoms
waters?
If
possible,
can
individual
PACs
be
identified?
Also,
at
least
one
state
(
Arkansas)
regulates
ammonia
discharges
from
PBSTs.
Is
ammonia
found
in
wastewaters
and,
if
so,
where
does
it
come
from
and
in
what
quantities?

10.
API
indicated
in
the
March
8th
meeting
that
many
facilities
send
their
tank
bottoms
water,
at
a
minimum,
to
petroleum
refiners
for
use
as
feedstock.
How
widespread
is
this
practice
and
is
it
limited
to
zero
dischargers?

11.
Are
there
any
particular
types
of
facilities
that
have
unusually
large
pollutant
discharges,
i.
e.
are
particular
product/
operation
mixes
responsible
for
toxic
loads?

12.
What
is
the
current
level
of
treatment­
in­
place?
Is
it
pretty
much
limited
to
oil/
water
separation
or
does
anyone
use
any
more
advanced
treatment?
Do
any
facilities
discharge
wastewater
without
treatment?
For
those
that
use
advanced
treatment,
why?
Do
they
have
particular
issues?
And
do
they
use
advanced
treatment
to
treat
only
specific
portions
of
their
wastewaters,
e.
g.
tank
bottoms?

13.
Are
pollution
prevention/
recovery
practices
in
wide
use?
If
so,
what/
how?
Are
these
consequences
of,
among
other
things,
EPA's
spill
control
rules
(
SPCC)?
Or
have
facilities
been
using
them
for
other
reasons,
e.
g.
economic?

14.
Are
discharges
impacted
by
other
EPA
rules?
SPCC
may
have
been
addressed
in
the
previous
question,
but
what
about
air
rules,
water
quality
standards,
stormwater
rules,
etc.?
And
specifically,
how
are
toxic
discharges
affected?

15.
Are
there
any
difficulties
in
developing
permits
for
these
facilities?
If
so,
why?
Are
all
permits
site­
specific
or
are
there
general
criteria
used
to
develop
all
permits
for
PBSTs
in
a
state
(
addressed
to
a
state
permit
writer)?

16.
TRI
data
imply
that
nearly
two­
thirds
of
PBSTs
are
zero
discharge.
Is
this
actually
reflective
of
the
industry?

17.
For
those
that
are
zero
discharge,
why
are
they
zero
discharge
and
how
are
they
handling
their
wastewaters?
Are
they
shipping
the
wastes
offsite
for
treatment?
Or
do
they
simply
not
have
much
wastewater
to
begin
with?
If
wastewater
generation
is
low,
why?

18.
What
are
the
percentages
of
the
zero
discharge
facilities
sending
their
wastes
offsite?
