MEMORANDUM
DATE:
April
29,
2004
TO:
Effluent
Guidelines
Planning
Record
FROM:
M.
Ahmar
Siddiqui
RE:
Telephone
discussion
regarding
PBSTs
with
Dave
Basinger,
EPA
Region
9
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
5,
2004,
Mr.
M.
Ahmar
Siddiqui
contacted
Mr.
Dave
Basinger
of
the
Region
9
Office
of
Compliance
to
discuss
these
facilities.
The
telephone
script,
which
served
as
a
guide
to
the
conversation,
is
part
of
another
memorandum
to
the
Effluent
Guidelines
Planning
Record
(
Summary
of
discussions
with
permit
writers
about
PBST
facilities,
April
29,
2004).

Mr,
Basinger
identified
contaminated
stormwater,
tank
bottoms
water,
occasional
ballast
water
(
if
products
arrive
by
barge)
and
groundwater
seepage
up
into
tanks
as
particular
sources
of
polluted
wastewaters
at
PBSTs.
Depending
on
the
volume
of
materials
transferred,
tank
bottoms
water
may
be
very
significant
in
volume
and
toxic
(
in
the
event
that
received
products
have
significant
amounts
of
water
in
them).
Mr.
Basinger
could
not
identify
the
quantities
of
polyaromatic
hydrocarbons
(
PAHs)
or
other
pollutants
in
typical
wastestreams,
noting
that
this
was
largely
a
function
of
the
products
handled
by
the
PBST.

To
the
question
of
the
recycling
of
tank
bottoms
waters
to
recover
petroleum
products,
Mr.
Basinger
stated
that
this
practice
often
occurs
at
those
facilities
associated
with
oil
refineries.
He
could
not
guess
how
widespread
the
practice
is,
though
he
noted
that
larger
facilities
were
more
likely
to
engage
in
it.
Mr.
Basinger
went
on
to
note
that
he
didn't
believe
that
refineries
paid
for
tank
bottoms
waters:
instead,
those
PBSTs
that
sent
their
tank
bottoms
waters
to
refineries,
paid
the
refineries
for
(
effectively)
treating
their
wastewaters.

Mr.
Basinger
stated
that,
for
those
PBSTs
with
treatment
systems,
oil/
water
separation,
by
itself,
is
most
commonly
used.
He
went
on
to
say
that
differences
may
exist
based
on
size
and
other
economic
factors:
those
PBSTs
that
are
co­
located
with
refineries
will
have
local
treatment
(
oil/
water
separation)
in
the
event
that
the
refineries
tank
farms
were
spread
out.
He
also
noted
that
treatment
beyond
oil/
water
separation
is
rare
and
is
largely
due
to
local
limits.
In
addition,
he
noted
that
biological
treatment
is
not
widely
used
due
to
the
fact
that
PBSTs
accept
varying
products:
the
variety
of
wastestreams
that
result
cannot
be
easily
treated
this
way
due
to
damage
to
the
treatment
system's
microorganisms,
which
are
acclimated
to
specific
pollutants
profiles.

Mr.
Basinger
stated
that,
among
the
pollution
prevention
methods
used
by
PBSTs,
spill
management
and
products
recycle
are
fairly
common.
He
also
stated
that
current
EPA
rules,
like
the
Spill
Prevenetion,
Control,
and
Countermeasures
(
SPCC)
rules
and
stormwater
rules
have
lowered
toxic
discharges,
though
he
was
unable
to
guess
the
extent
of
reduction.
As
to
the
discharge
status
of
the
industry,
Mr.
Basinger
was
unable
to
verify
the
implication
of
the
2000
TRI
database,
which
suggested
that
as
much
as
two­
thirds
of
the
industry
practiced
zerodischarge
He
did
guess,
however,
that
small,
independent
facilities
were
likely
to
be
doing
treatment.
