MEMORANDUM
DATE:
April
29,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Telephone
discussion
regarding
PBSTs
with
Lila
Tang
and
Phil
Isorena,
California
State
Water
Control
Board
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
15
and
16,
2004,
Mr.
M.
Ahmar
Siddiqui
contacted
Ms.
Lila
Tang
and
Mr.
Phil
Isorena
of
the
California
State
Water
Control
Board
to
discuss
these
facilities.
The
telephone
script,
which
served
as
a
guide
to
the
conversations,
is
part
of
another
memorandum
to
the
Effluent
Guidelines
Planning
Record
(
Summary
of
discussions
with
permit
writers
about
PBST
facilities,
April
29,
2004).

Ms.
Tang
noted
that
PBST
discharges
largely
consist
of
stormwater
and
some
process
water.
The
process
water
normally
consists
of
some
wash
water
and
tank
bottoms
water.
She
also
said
that
California
monitors
mostly
for
organics,
with
Mr.
Isorena
stating
that
the
discharge
of
MTBE,
oxygenates,
benzene,
PAHs,
and
diesel
and
gasoline
constituents
being
limited
by
permits.
Ms.
Tang
also
noted
that,
in
the
San
Francisco
Bay
area,
PBSTs
were
now
overwhelmingly
indirect
dischargers.
In
the
same
vein,
Mr.
Isorena
stated
that
there
are
very
few
direct
dischargers
in
California
(
though
he
could
not
provide
any
data)
and
that
the
2000
TRI
data's
implication
that
as
much
as
two­
thirds
of
the
industry
practices
zero­
discharge
may
be
true.
For
those
that
are
zero­
discharge,
Mr.
Isorena
stated
that
treatment
probably
consisted
of
off­
site
shipment.

Ms.
Tang
and
Mr.
Isorena
both
stated
that
some
PBSTs
send
some
of
their
wastes
to
refineries
for
treatment,
with
Mr.
Isorena
saying
that
PBSTs
usually
pay
the
refineries
for
their
services.
Ms.
Tang
noted
that
PBSTs
co­
located
with
refineries
mostly
commingle
their
wastewaters
with
refinery
wastestreams.
Neither
could
say,
however,
how
widespread
this
practice
was
generally.

As
to
the
question
of
treatment­
in­
place,
both
said
that
oil/
water
separation
is
universally
used,
with
those
PBSTs
co­
located
at
refineries
using
the
refineries'
treatment
systems.
Mr.
Isorena
also
noted
that
the
use
of
activated
carbon
is
widespread
in
the
Central
Valley
and
that
discharge
limits
are
very
tight
(
BTEX,
MTBE,
and
many
other
constituents
below
10
ppb).
He
said
that
this
is
due
to
California
environmental
law,
which
states
that
all
waters
in
California
are
potential
drinking
water
sources
(
see
Effluent
Guidelines
Planning
record
for
State
Water
Resources
Control
Board,
Resolution
No.
88­
63,
Adoption
of
Policy
Entitled
"
Sources
of
Drinking
Water").

Mr.
Isorena
went
on
to
say
that
pollution
prevention
methods
are
now
becoming
widely
used.
For
example,
he
noted
that
facilities
no
longer
drain
tank
bottoms
waters
to
the
ground
and
that
dikes,
roofs,
and
berms
are
used
to
mitigate
stormwater
contamination.
