MEMORANDUM
DATE:
April
7,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Characteristics
of
PBST
wastewaters
As
part
of
the
development
of
the
2004/
2005
Effluent
Guidelines
Plan,
a
study
of
the
petroleum
bulk
stations
and
terminal
industry
(
PBST,
SIC
5171)
is
being
conducted.
PBST
was
identified
as
an
industry
of
interest
due
to
stakeholder
comments
and
an
expected
similarity
of
operations
and
wastewater
characteristics
to
those
of
the
petroleum
refining
industry,
which
is
being
evaluated
by
EPA
for
potential
future
effluent
guidelines
revision.
Moreover,
depending
on
the
outcome
of
EPA's
study
of
PBSTs,
a
decision
could
be
made
to
begin
development
of
effluent
guidelines
for
PBSTs
as
a
new
subcategory
under
the
current
petroleum
refining
rule
(
40
CFR
Part
419).

As
part
of
its
development
of
a
PBST
industry
profile,
EPA
is
engaged
with
various
stakeholders,
including
industry
groups
and
control
authorities.
All
have
identified
stormwater
as
the
largest
volume
of
wastewater
discharge
from
PBSTs
(
please
see
comments
to
the
Preliminary
Plan
referred
to
in
this
memorandum
and
the
earlier
memorandum
titled
"
Summary
of
discussions
with
permit
writers
about
PBST
facilities").
In
addition,
the
following
have
been
identified
as
possible
sources
of
toxic
discharges
from
PBSTs:

°
Tank
bottoms
water
°
Ballast
water
°
Equipment
wash
water
Stormwater
is
the
overwhelming
source
of
water
discharges
from
PBSTs,
according
to
commenters.
According
to
the
Independent
Fuel
Terminal
Operators
Association
(
IFTOA)
and
the
New
England
Fuel
Institute
(
NEFI),
facilities,
by
and
large,
only
discharge
stormwater.
Amerada
Hess,
in
its
comments,
estimated
that
95
percent
of
discharges
from
PBSTs
is
stormwater.
The
American
Petroleum
Institute
(
API),
in
a
1988
study
of
57
PBSTs,
estimated
that
only
about
0.6
percent
of
all
stormwater
is
contaminated
through
contact
with
polluted
surfaces
or
loading
racks
at
PBSTs.
Specific
pollutant
types
or
levels
could
not
be
identified,
since
sites
handle
a
wide
variety
of
products
at
different
times,
but
it
is
reasonable
to
expect
that
contamination
will
be
by
petroleum
hydrocarbons.

Tank
bottoms
water
is
the
water
that
collects
in
the
bottoms
of
petroleum
product
tanks
from
stormwater
that
seeps
through
tank
roofs,
from
tank
breathing
and
condensation
of
moisture
in
the
air,
from
moisture
in
the
stored
product
itself,
or,
occasionally,
from
groundwater
rising
up
into
tanks.
Tank
bottom
water
is
not
normally
present
in
large
volumes:
API,
in
its
1988
study
estimated
that,
on
average,
approximately
one
inch
of
tank
bottoms
water
accumulates
annually.
A
tank
with
a
100
foot
diameter,
therefore,
collects
nearly
5,000
gallons
annually
of
tank
bottoms
water.
API
estimated
that
this
represents
approximately
one
percent
of
PBST
wastewater.
The
composition
of
tank
bottoms
water
is
highly
dependent
on
the
products
stored
in
the
tank,
but,
given
the
nature
of
the
industry,
can
contain
oil
and
grease,
oxygenates,
PACs,
BTEX,
etc.

Ballast
water
is
water
that
has
been
used
by
unladen
ships
and
barges
for
ballast
and
has
been
offloaded
at
a
PBST.
It
is
likely
similar
in
composition
to
equipment
wash
water
or
dilute
tank
bottoms
water.
Alyeska
Pipeline
Services
Company,
in
its
comments
to
the
Preliminary
Plan,
stated
that
its
Valdez
Marine
Terminal
recovers
approximately
0.4
percent
of
its
ballast
receipts
of
9.6
millions
gallons
per
day
in
the
form
of
oil.
Ballast
water
can
be
contaminated
with
any
number
of
pollutants,
including
TPH,
PACs,
and
invasive
species.

Equipment
wash
water
consists
of
water
generated
during
the
washing
of
equipment
at
PBSTs,
including
tanks,
truck
washes,
and
transfer
racks.
These
wastes
contain
detergents
(
surfactants),
and
petroleum
products
of
various
types,
depending,
for
instance,
on
what
the
tanks
store
or
on
what
the
trucks
carry.
Amerada
Hess,
in
its
comments
to
the
Preliminary
Plan,
stated
that
these
wastes
were
small
in
volume
and
API
estimated,
in
its
1988
study,
that
these
wastes
accounted
for
about
four
percent
of
all
PBST
wastewaters.

It
is
not
believed
that
any
particular
type
of
facility
contributes
an
especially
large
portion
of
this
industry's
toxic
discharges.
This
is
due
to
two
main
reasons.
First,
these
facilities
collect
for
distribution
a
very
wide
range
of
products,
with
the
range
changing
as
market
conditions
change.
As
a
result,
no
particular
product
is
able
to
drive
loads,
except
in
the
very
broadest
sense
(
petroleum
products
causing
the
introduction
of
oil
and
grease,
PACs,
BTEX,
MTBE,
etc.).
Secondly,
as
Region
9'
s
compliance
office
noteed,
turnover
at
PBSTs
can
be
very
high,
in
that
products
can
come
in
and
leave
the
facilities
rather
quickly,
making
it
difficult
to
link
any
product/
process
to
toxic
loads.
However,
it
can
be
said
that
large
facilities
are
likely
the
source
of
the
largest
portions
of
toxic
discharges,
simply
by
virtue
of
their
size.

The
stakeholders,
including
industry
trade
associations
and
control
authorities,
agreed
that
discharges
from
PBSTs,
treated
or
untreated,
are
intermittent
in
nature,
since
they
are
mostly
driven
by
stormwater.
NEFI,
Amerada
Hess,
the
Independent
Liquid
Terminal
Association
(
ILTA),
the
Petroleum
Marketers
Association
of
America
(
PMAA),
and
IFTOA
all
stated
in
their
comments
that
discharges
are
intermittent
and
tied
to
storm
events.
It
should
be
remembered
that,
while
leaks
and
spills
generally
do
not
result
in
a
discharge,
if
they
are
not
cleaned
up,
they
can
contribute
pollutants
during
a
rain
event
in
the
form
of
contaminated
stormwater.
In
addition,
because
of
its
small
volume,
tank
bottoms
water
is
typically
only
drained
from
tanks
occasionally.
Therefore,
its
contribution
to
PBST
wastewater
loading
is
also
going
to
be
intermittent.
Finally,
the
other
significant
sources
of
wastewater
at
these
facilities,
equipment
wash
water,
is
another
periodically
generated
wastewater.
