MEMORANDUM
DATE:
April
29,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Telephone
discussion
regarding
PBSTs
with
George
Papadopoulos,
EPA
Region
1
As
part
of
its
study
of
the
Petroleum
Bulk
Stations
and
Terminals
(
PBST,
SIC
5171)
industry,
EPA
contacted
permit
writers
and
compliance
officials
to
discuss
permitting
and
other
issues
unique
to
PBSTs.
On
April
12,
2004,
Mr.
M.
Ahmar
Siddiqui
contacted
Mr.
George
Papadopoulos
of
EPA
Region
1
to
discuss
these
facilities.
The
telephone
script,
which
served
as
a
guide
to
the
conversation,
is
part
of
another
memorandum
to
the
Effluent
Guidelines
Planning
Record
(
Summary
of
discussions
with
permit
writers
about
PBST
facilities,
April
29,
2004).

When
asked
about
wastewater
discharges
at
PBSTs,
Mr.
Papadopoulos
said
that
all
facilities
have
stormwater
discharges
but
that
the
discharge
of
tank
bottoms
waster
was
not
allowed.
He
noted
that
contaminated
stormwater
is
treated
by
oil/
water
separation
and
that
the
primary
pollutants
found
were
BTEX,
MTBE,
and
oil
and
grease.
He
said
that
Region
1
was
uncertain
about
what
to
do
with
PAHs,
because
of
problems
with
detections
using
current
methods.
He
said
that
there
were
very
few
detects
of
PAHs
and
that
the
Region
is
considering
using
TPH
as
an
indicator.

Mr.
Papadopoulos
was
uncertain
about
the
use
of
oil
refineries
to
treat
PBST
tank
bottoms
waters,
a
practice
that
API
asserts
is
widespread.

As
to
the
question
of
individual
operation
driving
pollutant
loads,
Mr.
Papadopoulos
stated
that
this
is
entirely
dependent
on
how
well
the
PBST
operates.
He
went
on
to
say
that
treatment
is
largely
limited
to
oil/
water
separation,
though
the
Exxon
Everett
PBST,
asignificant
reporter
in
the
2000
PCS
database,
may
have
more
extensive
treatment.
He
also
stated
that,
in
Massachusetts,
most
facilities
treat
their
wastewaters
before
discharging
them.

Mr.
Papadopoulos
also
said
that
all
facilities
have
SPCC
and
stormwater
pollution
prevention
plans.
He
was
not
sure
if
any
particular
economic
factors
were
driving
the
use
of
pollution
prevention
methods.
He
also
said
that
all
permits
in
Massachusetts
are
developed
on
an
individual
basis
due
to
the
different
products
handled
by
the
facilities.
