MEMORANDUM
DATE:
April
2,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Discharge
status
of
PBST
facilities
and
possible
reasons
for
the
prevalence
of
zerodischarge
of
toxic
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).

Any
assessment
of
PBSTs
will
begin
with
an
examination
of
effluent
discharge
characteristics
and
attempt
to
account
for
the
reasons
that
facilities
choose
to
discharge
in
particular
ways
.
Two
EPA
databases,
the
Toxic
Release
Inventory
(
TRI)
and
Permit
Compliance
System
(
PCS)
databases,
are
being
used
to
evaluate
these
wastewaters.
These
databases
were
chosen
because
they
can
identify
toxic
discharges
on
a
nationwide
basis
(
TRI)
and
because
they
can
provide
information
about
large
direct
dischargers
in
an
industry
(
PCS).
While
it
is
true
that
there
are
some
limitations
in
both
databases
(
e.
g.,
PCS
does
not
reveal
much
information
about
small
direct
dischargers
and
none
about
indirect
dischargers;
TRI
also
provides
little
information
about
small
facilities),
EPA
believes
that
both
are
useful
as
a
"
first­
cut"
examination
tool.

In
addition
to
relying
on
the
TRI
and
PCS
databases
while
developing
a
PBST
industry
profile,
EPA
engaged
in
discussions
with
State
and
Regional
permitting
and
compliance
authorities
and
evaluated
comments
to
the
Preliminary
Plan.
The
Agency
hoped
that,
using
these
resources,
it
could
more
readily
understand
local
factors
that
drive
PBSTs
to
operate
and
discharge
in
a
particular
way.

As
noted
in
an
earlier
memorandum
("
Discharge
status
of
PBST
facilities,
as
enumerated
by
TRI
and
PCS
databases"),
TRI
data
from
the
year
2000
suggest
that
two­
thirds
of
the
industry
is
made
up
of
zero­
dischargers
(
only
167
of
502
reporting
facilities
reported
discharges
to
surface
waters).
In
addition,
eight
"
major"
dischargers
were
identified
in
the
PCS
database
for
the
same
year.

All
stakeholders
(
control
authorities
and
commenters)
identified
stormwater
as
the
largest
portion
of
water
discharges
from
PBSTs.
For
example,
in
their
comments
to
the
Preliminary
Plan,
the
Independent
Fuel
Terminal
Operators
Association
(
IFTOA)
and
the
New
England
Fuel
Institute
(
NEFI)
said
that
facilities,
by
and
large,
only
discharge
stormwater.
Amerada
Hess,
in
its
comments,
estimated
that
95
percent
of
discharges
from
PBSTs
is
stormwater.
In
addition,
the
following
have
been
identified
as
possible
sources
of
toxic
discharges
from
PBSTs,
though
of
much
smaller
volumes,
by
these
same
stakeholders:

°
Tank
bottoms
water
°
Equipment
wash
water
°
Product
spills
°
Ballast
water
It
should
be
noted
that
in
Massachusetts,
where
permits
are
written
by
EPA
Region
1,
the
discharge
of
tank
bottoms
water
without
treatment
is
strictly
prohibited.
This
is
due
to
the
toxic
nature
of
tank
bottoms
in
general:
recall
that
tank
bottoms
is
water
that
is
either
in
the
stored
products
itself
or
is
water
that
has
seeped
into
the
tanks
(
from
rain
or
high
humidity)
and
has
settled
onto
the
tank
bottom.
As
a
result
of
this
prolonged
contact,
this
water
is
often
laden
with
petroleum
hydrocarbons,
including
BTEX,
MTBE,
and
PACs.

EPA
Region
9
notes
that,
in
some
cases,
tank
bottoms
water
may
also
be
significant
in
volume.
This
can
happen
at
PBSTs
that
receive
off­
spec
products.
If
the
products
contains
large
quantities
of
water,
it
will
settle
to
the
bottom
of
the
tanks
and
augment
the
tank
bottoms
water
already
being
formed
through
stormwater
infiltration.

Especially
with
respect
to
tank
bottoms
water,
offsite
treatment
has
been
reported
to
be
a
widely
used
practice
by
several
industry
stakeholders.
In
its
comments
to
the
Preliminary
Plan,
ConocoPhillips
states
that
the
vast
majority
of
its
terminals
send
their
tank
bottoms
water
either
offsite
or
to
one
of
its
refineries
for
treatment.
Amerada
Hess,
in
its
comments
to
the
Preliminary
Plan,
states
that
its
terminals
send
their
tank
bottoms
waters
off­
site
for
treatment
and
disposal.
The
American
Petroleum
Institute
(
API)
claims
that
more
than
50
percent
of
PBST
facilities
in
close
proximity
to
oil
refineries
send
their
tank
bottoms
waters
to
the
refineries
specifically
for
oil
recovery,
though
EPA
has
not
been
able
to
verify
this.

Two
commenters
stated
outright
that
PBSTs
do
not
discharge
toxic
wastes:
in
their
comments,
IFTOA
and
NEFI
asserted
that
PBSTs
do
not
discharge
toxic
pollutants
at
all.

Given
two
factors,
that
discharges
seems
to
be
completely
dominated
by
stormwater
and
that
tank
bottoms
waters
are
generally
treated
offsite,
EPA
believes
it
can
explain
the
2000
TRI
data's
implication
that
large
segments
of
the
PBST
industry
are
zero­
discharge:
the
remaining
toxic
wastewater
sources,
by
and
large,
are
too
small
to
trigger
TRI
reporting
requirements
for
toxic
discharges
to
surface
waters.
