1、 STD.API/PETRO PUBL 4b95-ENGL 1999 m 0732290 Ob189 142 m American Petroleum Institute Sind-b Td.+ UNDERSTANDING AND PREPARING APPLICATIONS FOR PETROLEUM FACILITY NPDES DISCHARGE ,PERMITS Regulatory and Scientific Affairs Pubication Number 4695 December 1999 American I Petroleum Institute American Pe
2、troleum Institute Environmental, Health, and Safety Mission and Guiding Principles MISSION The members of the American Petroleum Institute are dedicated to continuous efforts to improve the compatibility of our operations with the environment while economically developing energy resources ami supply
3、ing high qualis, products and services to consumers. We recognize ow responsibility to work with the public, the government, and others to develop and to use naturat resources in an environmentally sound manner while protecting the health and safety of our employees and the public. To meet these res
4、ponsibilities, API members pledge to manage our businesses according to the following principles using sound science to prioritize risks ana! to implement cost-effective management practices: e To recognize and to respond to community concerns about our raw materials, products and operations. e To o
5、perate our plants and facilities, and to handle our raw materials and products in a manner that protects the environment, and the safety and health of our employees and the public. PRINCIPLES o To make safety, health and environmental considerations a priority in our planning, and our development of
6、 new products and procsses. o To advise promptly, appropriate officials, employees, customers and the public of information on significant industry-related safety, health and environmental hazards, and to recommend protective measures. e To counsel customers, transportrs and others in the safe use,
7、transportation and disposal of our raw materials, products aod waste materials. o To economically develop and produce natural resources and to conserve those resources by using energy efficiently. o To extend knowledge by conducting or supporting research on the safety, health and environmental effe
8、cts of our raw materials, products, processes and waste materials. i To commit to reduce overall emission and waste generation. e To work with others to resolve problems created by handling and disposal of hazardous substances from our operations. o To participate with government and others in creat
9、ing responsible laws, - regulations and standards b safeguard the community, workplace and environment. o To promote these principles and practices by sharing experiences and offering . assistance to others who produce, handle, use, transport or dispose of similar raw materials, petroleum products a
10、nd wastes. Understanding and Preparing Applications for Petroleum Facility NPDES Discharge Permits Regulatory and Scientific Affairs API PUBLICATION NUMBER 4695 PREPARED UNDER CONTRACT BY: TISCHLEFKOCUREK ROUND ROCK, TEXAS DECEMBER 1999 American Petroleum Institute STD=API/PETRO PUBL 4695-ENGL 1979
11、M 0732290 0bLB712 737 = FOREWORD API PUBLICATIONS NECESSARILY ADDRESS PROBLEMS OF A GENERAL NATURE. WITH RESPECT TO PARTICULAR CIRCUMSTANCES, LOCAL, STATE, AND FEDERAL LAWS AND REGULATIONS SHOULD BE REVIEWED. API IS NOT UNDERTAKING TO MEET THE DUTIES OF EI“LOYEiRS, MANUFAC- TURERS, OR SUPPLIERS TO W
12、ARN AND PROPERLY TRAIN AND EQUIP THEIR EMPLOYEES, AND OTHERS EXPOSED, CONCERNING HEALTH AND SAFETY RISKS AND PRECAUTIONS, NOR UNDERTAKING THEIR OBLIGATIONS UNDER LOCAL, STATE, OR FEDERAL LAWS. NOTHING CONTAINED IN ANY API PUBLICATION IS TO BE CONSTRUED AS FACTURE, SALE, OR USE OF ANY METHOD, APPARAT
13、US, OR PRODUCT COV- ERED BY LETTERS PATENT. NEITHER SHOULD ANYTHING CONTAINED IN ITY FOR INFRINGEMENT OF LETIERS PATENT. GRANTING ANY RIGHT, BY IMPLICATION OR OTHERWISE, FOR THE MANU- THE PUBLICATION BE CONSTRUED AS INSURING ANYONE AGAINST LIABIL- All rights reserved. No part of this work may be rep
14、roduced, stored in a retrieval system, or transmitted by any means, electronic, mechanical, photocopying, recording, or otherwise, without prior written permission from the publishex Contact the publisher. API Publishing Services, 1220 L Street, N. W, Washington, D.C. 20005. Copyright Q 1999 America
15、n Petroleum Institute iii STD.API/PETRO PUBL 4675-ENGL 1799 0732290 Ob187L3 673 ACKNOWLEDGMENTS THE FOLLOWING PEOPLE ARE RECOGNIZED FOR THEIR CONTRIBUTIONS OF TIME AND EXPERTISE DURING THIS STUDY AND IN THE PREPARATION OF THISREPORT . API STAFF CONTAC Roger Claff, Regulatory and Scientific Affairs M
16、EMBERS OF THE WATER TECHNOLOGY TASK FORCE Robert Goodrich, Exxon Research and Engineering Company, Chairperson David Pierce, Chevron Research and Technology Company, Vice Chairperson Terrie Blackburn, Williams Pipeline Company Deborah Bolton, Chevron Products Marketing Company Vic Carlstrom, Mobil E
17、xploration and Production US Incorporated Leanne Kunce, BP Oil Company Jim Mahon, FINA Company William Martin, ARCO Products Company Gary Morris, Mobil Technology Company Arnold Marsden, Jr., Equiva Services LLC Barbara Padlo, Amoco Research Center Gerry Sheely, Marathon Ashland Petroleum LLC Paul S
18、un, Equilon Enterprises LLC iv STD.API/PETRO PUBL 4b95-ENGL 1999 m 0732290 Ob18714 SOT m Preface The American Petroleum Institutes (APIs) Health and Environmental Sciences Department, through the API Water Technology Task Force, has been conducting a multi-year research program to evaluate and ident
19、iSr practical and environmentally sound technologies for petroleum facility wastewater treatment. The Task Force has also been sponsoring research to help petroleum facilities and government agencies to improve efficiencies and to change and comply with regulations. The results of this program are i
20、ntended to provide industry and regulatory agencies with technical information to make informed decisions on appropriate alternatives for individual petroleum manufacturing and distribution facilities. The Task Force has sponsored and published a significant amount of work in prior years on handling
21、 and treating petroleum waters. A listing of some key published reports is summarized below. This report is aimed at helping individual petroleum facilities understand the NPDES (National Pollutant Discharge Elimination System) permitting process, and how to cost- effectively prepare permit applicat
22、ions under this system, whether done by in- house staff or through a consulting firm or other resource. This comprehensive report goes beyond explaining how to prepare the NPDES permit application. It provides strategies for improving facility operation as personnel go through the permit application
23、; raises possible issues and resolutions for negotiation and appeals with government regulators; provides example case histories; discusses stormwater permits; and provides a “tool box to help work through areas such as effluent limit calculations, mixing zones, waste load allocations, sampling/anal
24、ytical data, and biomonitoring. The Task Force greatly acknowledges and appreciates the fine work performed by Tischler/Kocurek, Round Rock, Texas in preparing this comprehensive study and for the expert guidance of Mr. David Pierce, Chevron, in overseeing the development of this report. Studies Spo
25、nsored by the Water Technology Task Force Publ. 16 12 Guidance Document for Discharging of Petroleum Distribution Terminal Effluents to Publicly Owned Treatment Works, November 1996. Publ. 4665 Analysis and Reduction of Toxicity in Biologically Treated Petroleum Product Terminal Tank Bottoms Water,
26、April 1998. STDmAPIIPETRO PUBL 4b95-ENGL 1999 E 0732290 Ob18715 44b Publ. 4664 Publ. 4606 Publ. 4602 Publ. 4582 Publ. 4581 Mixing Zone Modeling and Dilution Analysis for Water- Quality-Based NPDES Permit Limits, April 1998. Source Control and Treatment of Contaminants Found in Petroleum Product Term
27、inal Tank Bottoms, August 1994. Minimization, Handling, Treatment, and Disposal of Petroleum Product Terminal Wastewaters, September 1994. Comparative Evaluation of Biological Treatment of Petroleum Product Terminal Wastewater by the Sequencing Batch Reactor Process and the Rotating Biological Conta
28、ctor Process, June 1993. Evaluation of Technologies for the Treatment of Petroleum Product Marketing Terminal Wastewater, June 1993. STDmAPI/PETRO PUBL 4b75-ENGL 1777 0732270 ObLB71b 382 Abstract A manual is presented by the American Petroleum Institute (API) to assist member companies and others in
29、 preparing applications and negotiating with permit authorities for National Pollutant Discharge Elimination System (NPDES) permits for wastewater discharges. The manual is intended to help permittees and permit applicants to understand the permit process from application to final permit, and to pro
30、vide tools and strategies for assuring that the permit is fair and properly implements the applicable regulations. The manual documents issues that may arise during the preparation of permit applications and the negotiation of permit conditions with permit writers. It also describes administrative a
31、nd judicial mechanisms that are available to permittees to challenge permit conditions and limits that are technically unsound or do not comport with the applicable regulations. Much of the information in this manual is based on practical experience with many NPDES permits and applications. Examples
32、 and case histories are provided to help the user understand the permit application process. STD-API/PETRO PUBL 4b95-ENGL L999 0732290 Ob38737 237 Contents Section 1 Introduction Objective Scope Using This Manual Whats in This Manual Overview of Manual Quick Start 2 NPDES Program Basics Permit Proce
33、ss Regulatory Authority and Duties Overview of Clean Water Act Provisions Federal Authority State and Local Authority 3 Types of Permits Individual Permits General Permits 4 NPDES Permit Elements Cover Page Effluent Limitations and Monitoring Requirements Technology-Based Limits Water-Quality-Based
34、Limits Internal Outfalls Narrative Permit Limits Flow Limits Monitoring Compliance Schedule Reporting of Monitoring Results Standard Conditions Upset Provision Bypass Notification of Changes in Discharge Page 1-1 1-1 1-2 1-3 1-3 1-4 2-1 2-3 2-3 2-4 2-7 3-1 3-1 4-1 4-1 4-3 4-5 4-6 4-6 4-7 4-7 4-8 4-9
35、 4-9 4-1 1 4-12 4-13 sTD.API/PETRO PUBL 4695-ENGL 1999 0732290 0638738 155 Section Page Other Conditions 4-14 5 Permit Applications Application Forms Individual Permits Deadlines Preparation Time Individual Permit Application Forms Individual Permit Application Contents Form 1 Form 2C General Permit
36、s Baseline or Multi-Sector Permit Deadlines Notice of Intent Notice of Termination Application Submittal 6 The Draft Permit How the Permit Writer Develops a Permit Fact Sheets Reviewing Prepublication Draft Permits Submitting Comments on Draft Permit Reviewing the Discharge Description Reviewing Eff
37、luent Limitations Technology-Based Limits Water-Quality-Based Limits Monitoring Requirements Compliance Schedules Reviewing Standard Conditions Reviewing Other Conditions Preparing the Comments Errors in Permit Comments by Environmental Groups 7 Hearings and Appeals Hearings EPA Regulatory Requireme
38、nts Public Hearings in Delegated States 5-1 5-1 5-1 5-2 5-2 5-5 5-5 5-7 5-13 5-13 5-13 5-14 5-15 5-15 6-1 6-4 6-5 6-6 6-7 6-7 6-7 6-9 6-9 6-12 6-12 6-12 6-13 6-13 6-14 7-1 7-1 7-2 STD-API/PETRO PUBL 4b75-ENGL 3797 m 0732270 06%8719 O91 m Section Page The Applicants Approach to Public Hearings 7-2 Ap
39、peals 7-3 EPA Appeals Process 7-3 State Appeals Process 7-6 The Applicants Approach to Permit Appeals 7-7 Settlement of Contested Issues 7-9 Appeals by the Public or Government Agencies 7-10 8 Variances Variances from Technology Standards 8-1 Fundamentally Different Factors Variance 8-2 Variance for
40、 Nonconventional Pollutants 8-6 Economic Achievability Variance from BAT 8-8 Alternative Effluent Limitations for Thermal 8-9 Discharges 8-1 1 8-1 1 8-13 Variances from Water Quality Standards Section 302(b)(2) Economic and Social Variance Temporary Variances from Water Quality Standards 9 Tool Box
41、Effluent Limit Calculations Types of Limits Data Distributions Outliers Nondetects (Censored Data) Confidence Intervals Effluent Guideline Limits Water-Quality-Based Effluent Limits Seasonally-Based Limits Sample Analyses Choosing an Analytical Method Permit Applications Permit Compliance Analysis Q
42、uantitation and Detection Limits Alternative Analytical Methods Quality Assurance/Quality Control Auditing the Laboratory Biomonitoring WET Tests 9-1 9-1 9-1 9-3 9-4 9-4 9-7 9-10 9-1 1 9-13 9-13 9-14 9-16 9-19 9-22 9-23 9-24 9-25 9-25 STD-APIIPETRO PUBL 4b95-ENGL 1997 I 0732290 Ob18720 803 = Section
43、 WET Test Data for Applications WET Testing in NPDES Permits Aquatic Organism Testing Mixing Zones Regulatory Mixing Zones Site-Specific Dilution Estimates Mixing Zone Modeling Tracer Studies Diffusers TMDLs and Waste Load Allocations Site-Specific Water Quality Criteria Bioavailability Adjustments
44、to Water Quality Criteria Partitioning Coefficients The Water-Effect Ratio Procedure Recalculation Procedure Resident Species Procedure Technology-Based Limits Water-Quality-Based Limits Indicator Parameters Acronyms and Abbreviations Bibliography Appendices 1 2 3 4 Individual Permit Application For
45、ms 5 EPA Correspondence on Baseline and Multi-Sector EPA Memo on Permit as Shield Example of Standard Conditions in NPDES Permit General Storm Water Permit NO1 and NOT Forms Storm Water General Permits Page 9-28 9-29 9-32 9-33 9-34 9-38 9-38 9-41 9-42 9-44 9-46 9-47 9-47 9-49 9-52 9-53 9-53 9-54 9-5
46、5 Table Page 3-2 3- 1 Examples of Types of Discharges Covered by General Permits 3 -2 Petroleum Industry Sectors in the NPDES Multi-Sector Storm Water Permit 3-5 4- 1 5- 1 5 -2 5-3 Outline of Standard Conditions of NPDES Permit 4-9 5-3 5-3 5-3 EPA Application Forms for Individual Permits Contents of
47、 Form 1, General Information Contents of Form 2C, Existing Facilities with Process Wastewater Contents of Form 2D, New Facilities with Process Wastewater 5-4 5-4 Contents of Form 2E, Facilities with Only Nonprocess Wastewater 5-4 5-5 5 -6 Contents of Form 2F, Storm Water from Industrial Activity 5-4
48、 5-7 Subcategories of Petroleum Refining in National EMuent Guidelines 5-9 Petroleum Refining Processes Listed in National Effluent Guidelines 5-10 5-8 5 -9 Example of Production Data for Petroleum Refinery With Petrochemical Operations 5-1 1 6- 1 Reference Materials Commonly Used to Develop NPDES P
49、ermits 6- 1 Information Typically Included in Fact Sheets 6-5 8-3 6-2 8- 1 Factors Which may be Considered Fundamentally Different for an FDF Variance Table Page 9- 1 Example Information and Instructions That Should 9-15 be Given to a Laboratory When Requesting NPDES Analyses 9-2 Aquatic Species Used in Standardized Acute 9-26 WET Tests 9-3 Aquatic Species Used in Standardized Chronic 9-27 WET Tests 9-4 Examples of Allowable Mixing Zone Dilution (Default) 9-36 STD-API/PETRO PUBL 4b95-ENGL 3999 0732270 Ob38723 532 = Figure Page 2- 1 Overview of the NPDES Permit Pr
