MEMORANDUM
DATE:
April
29,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Telephone
discussion
regarding
PBSTs
with
Jim
Ball
and
Eric
Beck,
Rhode
Island
Department
of
the
Environment,
Providence,
RI
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
March
31,
2004,
Mr.
M.
Ahmar
Siddiqui
contacted
Messrs.
Jim
Ball
and
Eric
Beck
of
the
Rhode
Island
Department
of
the
Environment
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).

When
asked
about
wastewater
sources
at
PBSTs,
Mr.
Ball
stated
that
stormwater
was
the
largest
source.
Among
process
water
sources,
Mr.
Ball
identified
tank
bottoms
water,
hydrostatic
test
water,
and
truck
wash
water
(
though
this
volume
is
very
small).
Mr.
Ball
also
identified
spills
and
leachate
as
another
source.
He
said
that
this
was
due
in
large
part
to
the
fact
that
many
tanks
in
Rhode
Island
are
now
rather
old
and
becoming
less
structurally
sound
with
age.
Mr.
Beck
added
that
many
facilities
discharge
PAHs
and
that
the
discharge
of
individual
PAHs
was
generally
tied
to
the
products
handled
by
the
PBST.

Mr.
Beck
could
not
enumerate
the
number
of
facilities
that
sent
their
wastewaters
to
refineries
for
reuse.
This
question
arose
from
an
assertion
by
the
American
Petroleum
Institute
that
more
than
50
percent
of
PBSTs
associated
with
refineries
sent
their
tank
bottoms
waters
to
refineries
for
recycle/
oil
recovery
purposes.
Mr.
Beck
did
say,
however,
that
the
Exxon
East
Providence,
RI
PBST
(
ranked
number
one
in
the
2000
PCS
database
for
toxic
discharges)
sent
its
wastes
tank
bottoms
water
to
a
co­
located
Exxon
refinery's
groundwater
treatment
system.

Mr.
Ball
stated
that
treatment­
in­
place
at
most
PBSTs
is
limited
to
oil/
water
separation,
with
a
discharge
standard
of
15
mg/
L
of
oil
and
grease.
For
those
facilities
that
had
groundwater
contamination
issues,
Mr.
Beck
said
that
treatment
systems
might
be
more
elaborate,
though
he
could
not
say
how.
However,
he
did
note
that,
in
Rhode
Island,
new
permits
are
now
being
issued
using
activated
carbon
as
a
technology
basis,
with
the
expectation
that
performance
would
continue
to
improve.

As
to
the
question
of
pollution
prevention,
Mr.
Beck
noted
that
it
was
largely
limited
to
the
use
of
dikes
and
improved
emergency
controls.
The
use
of
pollution
prevention,
he
said,
was
driven
by
EPA
SPCC
and
stormwater
rules.
He
could
not,
however,
quantify
the
impact
of
these
practices
on
pollutant
discharges
from
PBSTs.
Mr.
Beck
said
that
Rhode
Island
does
not
face
any
particular
difficulties
with
permitting
PBSTs,
largely
because
the
state
has
only
seven
permitted
facilities
and,
even
then,
two
are
in
the
process
of
shutting
down.
