MEMORANDUM
DATE:
April
20,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Current
levels
of
treatment­
in­
place
and
the
use
of
pollution
prevention
and
recovery
practices
in
the
PBST
industry
As
part
of
the
assessment
of
the
petroleum
bulk
stations
and
terminals
(
PBST)
industry,
EPA
is
evaluating
the
current
level
of
treatment­
in­
place
and
the
use
of
pollution
prevention
and
recovery
practices.
This
information
sets
a
baseline
that
allows
EPA
to
determine
the
need
to
do
a
national
guideline
and
to
estimate
the
costs
and
benefits
said
potential
discharge
standards.

EPA
has
been
in
discussions
with
control
authorities
from
across
the
country
to
identify
the
technologies
used
by
PBSTs
to
treat
their
wastewaters
and
to
prevent
pollution.
In
addition,
commenters
to
the
2004/
2005
Preliminary
Effluent
Guidelines
Plan
have
provided
valuable
information
on
this
subject.

The
consensus
is
that,
for
those
facilities
that
treat
their
wastewater
(
rather
than,
for
example,
have
it
shipped
offsite
for
treatment),
oil/
water
separation
is
the
most
common
method
of
treatment.
PBSTs,
for
the
most
part,
handle
petroleum
products
and,
thus,
the
largest
pollutant
loadings
come
from
petroleum
hydrocarbons
and
associated
compounds
(
oxygenates,
PACs,
etc.).
Depending
on
a
facility's
permit
limitations,
size,
and
volume
of
wastewater
generated,
this
may
be
the
only
treatment
technology
used.
In
Texas,
where
PBSTs
are
permitted
using
a
general
permit
and
the
total
petroleum
hydrocarbons
limit
is
15
mg/
L,
this
is
often
the
case.
Jim
Rice,
of
the
Texas
Commission
on
Environmental
Quality,
notes
that
some
very
large
facilities
in
the
Houston
Ship
Channel
area
may
have
biological
treatment
or
dissolved
air
flotation
systems
in
addition
to
oil/
water
separators
because
the
more
diverse
product
mixes
and
larger
volumes
handled
at
these
facilities
leads
to
greater
wastewater
generation.
Amerada
Hess,
in
its
comments
to
the
Preliminary
Plan,
noted
that
its
sites
use
oil/
water/
separation.
The
Independent
Liquid
Terminals
Association
(
ILTA),
in
its
comments,
stated
that
virtually
all
on­
site
treatment
facilities
used
oil/
water
separation.

California
has
established
very
tight
limits
(<
10
ppb)
for
many
constituents
of
PBST
wastwaters.
As
a
result,
facilities
often
use
activated
carbon
beds
to
further
capture
organic
pollutants.
In
the
Central
Valley,
Phil
Isorena,
of
the
California
State
Water
Control
Board,
notes
that
virtually
all
PBSTs
use
activated
carbon
in
their
treatment
systems.

In
individual
cases,
treatment
systems
can
be
even
more
complex:
Alyeska
Pipelines
Service
Company
reported
in
its
comments
to
the
Preliminary
Plan
that
its
Valdez
Marine
Terminal
uses
dissolved
air
flotation,
biological
treatment,
and
air
stripping
to
treat
up
to
10,000,000
gallons
per
day
of
oily
ballast
water.
Some
facilities
send
their
tank
bottoms
waters
off­
site
or
to
refineries
for
treatment.
Control
authorities
in
Rhode
Island
and
California
have
been
able
to
verify
the
use
of
this
practice,
though
are
unable
to
assess
how
widespread
it
is.
ConocoPhillips,
in
its
comments
to
the
Preliminary
Plan,
stated
that
its
terminals
send
their
tank
bottoms
waters
either
off­
cite
for
treatment
or
to
refineries
for
oil
recovery.
The
Petroleum
Marketers
Association
of
America
(
PMAA)
also
states
that
this
practice
is
used
and
depends
on
individual
facilities.
The
Independent
Fuel
Terminal
Operators
Association
(
IFTOA)
notes
that
most
facilities
send
their
tank
bottoms
waters
off­
site,
but,
since
this
process
is
rather
costly,
all
try
to
minimize
the
formation
of
tank
bottoms
water
in
the
first
place.

Pollution
prevention
practices
at
PBSTs
are
rather
homogeneous
across
the
United
States.
All
control
authorities
spoken
to
and
referred
in
an
earlier
memorandum
(
please
see
the
memorandum
titled
"
Summary
of
discussions
with
permit
writers
about
PBST
facilities")
note
that,
in
response
to
EPA's
spill
control
rules,
most
facilities
have
built
dikes
around
their
tanks
to
capture
potentially
contaminated
stormwater.
Generally,
after
rain
events,
facility
personnel
will
examine
the
collected
stormwater
for
evidence
of
contamination,
like
oil
sheens.
If
the
wastewater
is
deemed
to
be
contaminated,
it
can
either
be
treated
or
collected
for
treatment,
depending
on
the
facility's
operation
and
discharge
status.
On
the
other
hand,
if
no
sheen
is
found,
the
wastewater
will
likely
be
discharged
directly
to
surface
waters.

Commenters
to
the
Preliminary
Plan
verified
the
widespread
use
of
pollution
prevention
at
PBSTs,
largely
in
response
to
EPA's
Spill
Prevention,
Control,
and
Countermeasures
(
SPCC)
and
stormwater
rules.
According
to
PMAA,
in
addition
to
the
construction
of
dikes,
an
increasingly
common
method
of
spill
containment
is
the
use
of
double­
bottomed
tanks.
Facility
operators
can
now
use
manual
drains
to
check
and
see
if
the
inner
tanks
are
leaking.

Those
facilities
that
receive
or
transfer
products
to
ships
now
attempt
to
capture
spills
that
can
occur
when
the
ship
and
the
PBST
disconnect
or
leakage
from
the
hoses
and
fittings.
Virtually
always,
spilled
product
is
captured
and
then
pumped
to
the
proper
storage
tanks,
rather
than
allowed
to
run
into
the
treatment
system.
Amerada
Hess,
in
its
comments
to
the
Preliminary
Plan,
noted
the
use
of
spill
containment
in
loading
rack
area.

BMPs
are
now
also
being
used
to
minimize
pollution,
with
Amerada
Hess
reporting
ths
use
of
leak
monitoring
and
correction.
