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P2 for Chemical Distribution/Petroleum Bulk Storage

We are interested in sources of information concerning P2 opportunities for
reducing EPCRA Section 313 (TRI Form R) chemical releases and media transfers
within the Chemical Distribution Industry (SIC code 5169) and Petroleum Bulk
Storage Industry (SIC code 5171).  Basically, we are interested in tables or
matrices of P2 solutions that are directly linked to specific industrial activities that
generate EPCRA Section 313 chemical releases or media transfers.  

For example, the use of dry disconnects on transfer hoses can reduce leaks
and drips of chemicals during bulk transfer.  We have already reviewed the
EPA Industry Sector Notebooks for Petroleum Refining and Chemical
Manufacturing Industries as well as the EPA guidance documents for these two
new TRI reporting industries.    

Chemical distribution facilities are involved in the warehousing, storage, and
refrigeration of products such as acids, industrial and heavy chemicals,
dyestuffs, industrial salts, rosins, and turpentines.  These facilities are also
engaged in the formulation and repackaging of bulk or packaged materials to
be transferred offsite.  In addition, chemical distribution facilities perform plant
maintenance activities and wastewater treatment. 

The primary activity at Petroleum Bulk Terminals is the bulk storage and
transfer of petroleum products prior to further distribution in commerce.  The
facility also may engage in mixing or blending of the petroleum products prior
to distribution off-site.  

Please send responses to:

Gordon I. Townsend, P.E., R.S.
Internet:  gtownsen@tnrcc.state.tx.us

Engineering & Technical Assistance Team
Office of Pollution Prevention & Recycling
Texas Natural Resource Conservation Commission
MC-112, P.O. Box 13087, Austin, Texas  78711-3087
Phone:  512/239-3179
Fax:  512/239-3165