MEMORANDUM
DATE:
August
24,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Meeting
with
PBST
stakeholders
On
March
8,
2004,
several
industry
trade
associations
and
the
Department
of
the
Navy
met
with
EPA
to
discuss
its
effluent
guidelines
planning
process
and
industrial
discharges
from
the
Petroleum
Bulk
Stations
and
Terminals
(
PBST)
industry.
The
list
of
attendees
is
as
follows:

Table
1:
Meeting
attendees
Name
Entity
Represented
Roger
Claff
American
Petroleum
Institute
(
API)

Prentiss
Searles
API
Laura
Stewart
Petroleum
Marketers
of
America
(
PMAA)

David
Doane
Independent
Liquid
Terminals
Association
(
ILTA)

John
Chamberlayne
Department
of
the
Navy
Mary
T.
Smith
EPA
Tom
Wall
EPA
Carey
Johnston
EPA
M.
Ahmar
Siddiqui
EPA
Ms.
Mary
T.
Smith
opened
the
meeting
with
a
brief
overview
of
the
2004/
2005
Effluent
Guidelines
Planning
Process,
noting
that
PBSTs
had
been
identified
as
an
industry
of
interest
due
to
early
assessments
of
discharge
information
from
the
2000
Toxic
Release
Inventory
(
TRI)
and
Permit
Compliance
System
(
PCS)
databases.
She
also
noted
that
EPA
was
assessing
the
possibility
of
considering
PBSTs
as
a
subcategory
of
the
petroleum
refining
industry
as
opposed
to
a
new,
independent
industry.

Mr.
Carey
Johnston
then
pointed
out
that
EPA's
current
thinking
regarding
the
industry
focused
on
how
small
toxic
discharges
were
compared
to
those
of
other
industries,
to
which
Mr.
Prentiss
Searles
added
that
the
discharges
were,
in
fact,
trivial.

Mr.
Johnston
then
proceeded
to
ask
the
trade
associations
about
their
constituencies.
Mr.
Roger
Claff
stated
that
API
represented
major
oil
companies
and
wholesale
terminals,
with
a
membership
of
approximately
400.
Ms.
Laura
Stewart
said
that
PMAA
was
an
umbrella
organization
of
44
state
and
regional
trade
associations
representing
approximately
8,000
facilities.
These
facilities
were
described
as
having
typical
capacities
ranging
from
30,000
to
150,000
gallons.
Mr.
David
Doane
indicated
that
ILTA
represented
75
companies
of
all
sizes
and
that,
in
combination
with
API,
represented
virtually
all
major
entities
in
the
industry.
Mr.
Doane
noted
that
ILTA
represents
facilties
handling
a
broad
range
of
products,
including
chemical
storage
companies,
and
that
total
representation
is
about
500
facilities.

When
asked
by
Mr.
M.
Ahmar
Siddiqui
about
the
industry's
discharges,
Mr.
Doane
noted
that
the
major
source
of
discharges
is
stormwater.
Mr.
Doane
stated
that
contaminated
stormwater
was
treated
by
direct
discharging
facilities
before
discharge,
primarily
through
oil/
water
separation.
Indirect
discharging
facilities,
he
stated,
sent
their
tank
bottoms
water,
sludge,
and
other
discharges
through
treatment
systems
before
discharging
to
their
POTWs.
When
asked
by
Ms.
Smith
about
the
percentage
of
the
industry
that
was
composed
of
direct
dischargers,
Mr.
Doane
could
not
answer,
stating
that
no
one
had
done
the
necessary
survey
work.

Mr.
Johnston
asked
if
large
facilities
were
easily
identified,
to
which
Mr.
Claff
replied
in
the
negative
and
that
API
did
not
keep
throughput
data.

Mr.
Doane
interjected
that
there
was
significant
surprise
in
the
industry
when
the
Preliminary
Plan
was
published
and
selected
PBSTs
for
further
study.
Mr.
Doane
then
proceeded
to
describe
typical
PBST
waste
sources,
among
which
was
dripping
onto
concrete
pads
from
pump
seal
failures.
He
noted
that
this
sort
of
trouble
was
normally
quickly
corrected.
He
went
on
to
identify
truck
loading
racks
as
another
potential
source,
also
noting
that
EPA
Spill
Prevention,
Control,
and
Countermeasures
(
SPCC)
rules
were
beginning
to
have
significant
impacts
on
this
type
of
source.
Mr.
Doane
also
identified
docks
as
a
potential
source:
the
hoses
between
ships
and
docks
could
drip
when
disconnect
occurred
and
that
these
drippings
were
nearly
always
caught.
Finally,
he
noted
that
treatment
normally
consisted
of
oil/
water
separation,
with
some
large
facilities
also
using
dissolved
air
floatation
(
DAF),
and
that
polyaromatic
hydrocarbons
(
PAHs)
may
not
be
monitored.

Mr.
Claff
noted
that
all
terminals
are
regulated
in
some
fashion,
with
stormwater
permits,
and
that
measurements
of
organics
and
oil
and
grease
levels
were
often
extremely
low.
As
to
toxics,
API
felt
that
there
were
no
such
discharges.
Mr.
Claff
went
on
to
note
that
those
more
than
half
of
PBSTs
close
to
refineries
often
send
their
tank
bottoms
waters
to
the
refineries
for
recovery/
recycle.
He
also
said
that
domes,
along
with
flexible
seals,
are
normally
used
over
the
tops
of
tanks
to
prevent
stormwater
infiltration
(
and,
therefore,
tank
bottoms
water
formation).
Finally,
he
noted
that
loading
racks
will
always
have
canopies
to,
again,
prevent
stormwater
contamination.

Mr.
John
Chamberlayne
also
talked
about
stormwater
and
also
noted
that
virtually
all
PBSTs
are
regulated
by
stormwater
permits.
He
went
on
to
enquire
if
EPA
could
even
suggest
technology
to
justify
national
effluent
guidelines.
Mr.
Johnston
noted
that
the
purpose
of
the
meeting
was
strictly
informational
and
that
EPA's
interest
was
in
learning
how
facilities
were
managing
their
wastes.

The
meeting
concluded
with
Mr.
Tom
Wall
emphasizing
the
importance
of
EPA
having
a
legally
defensible
record
and
asking
for
any
information
that
could
be
provided.
