Terminal Series – Article 8
Terminal Series – Article 8 Contributed by Ned Coleman, Senior Project Manager, PPM Consultants
Adding renewable diesel, ethanol blends, biodiesel, sustainable aviation fuel (SAF), or new fuel additives can unlock meaningful commercial opportunities for petroleum bulk terminals. But these projects can also introduce less-obvious operational and compliance challenges. New fuels may require physical changes, create different material-compatibility risks, and trigger revalidation of prior environmental permitting assumptions.
The fastest, cleanest integrations are the ones that recognize these changes early and align permitting, engineering, and operations before the first gallon moves.
Key takeaways
- Treat SAF/biofuel service changes as projects, not product substitutions. Differences in solvency, water affinity, vapor pressure, and corrosion can change both operations and permitting.
- Expect ripple effects across air, spill planning/emergency response, stormwater/waste handling, and state/federal reporting programs.
- Commissioning is the highest-risk window for missed requirements. Plan for tight coordination between Operations, Maintenance, and environment, health, and safety (EHS).
- Use a structured integration workflow to reduce surprises and shorten the path to stable startup.
Why service changes aren’t “drop-in” projects
Biofuels and SAF can behave differently from traditional petroleum products. Their solvency, water affinity, vapor pressures, and corrosion characteristics can introduce new challenges on both the operational and permitting fronts. Terminals that treat these as simple product substitutions often run into startup delays, compatibility mismatches, or customer complaints.
As PPM Consultants, Inc. (PPM) has seen across multiple Gulf Coast facilities, the most successful projects begin with a practical question:
What changes when this product enters my system?
That mindset helps teams surface hidden operational, mechanical, and environmental impacts early—long before commissioning.
Environmental compliance impacts
Introducing SAF or biofuels almost always triggers some level of environmental permitting action—whether a permit modification, a change in compliance requirements, or a courtesy notification to the agency. Prior emissions estimates and control assumptions rarely remain unchanged.
It’s critical to understand all the changes needed (both physical and operational) to accommodate new products at the terminal, because those changes will trickle down into the site’s environmental compliance programs.
Air permitting: Re-evaluate vapor pressure and controls
Changes in vapor pressure can affect storage tank design requirements, loading rack emissions, vapor recovery/vapor control unit sizing (VRU/VCU), and startup/shutdown processes. As EPA requirements evolve, even minor changes can trigger major impacts—especially when regulations broaden applicability or tighten performance expectations.
Related reading: PPM’s article on throughput-related air permitting considerations.
Spill planning and emergency response updates
Even if the updates are mostly administrative, new products typically require updates to spill plans, contingency plans, and other response procedures. EPA’s Risk Management Program (RMP) is another regulation that can get overlooked—review your existing release scenarios and confirm whether documentation needs to be updated.
Don’t assume a product change is just a simple table update. Take a close look at whether project changes trigger deeper revisions to spill and emergency response programs so the terminal stays compliant.
Stormwater and waste streams
Water and waste considerations may not be top of mind during early planning, but they can become schedule drivers if missed. Commissioning activities such as tank cleaning and pressure testing should be reviewed to confirm proper authorizations are in place.
Depending on the scope, your stormwater pollution prevention plan (SWPPP) may need new best management practices (BMPs) or updated drainage diagrams.
Related reading: PPM’s blog coverage on stormwater changes driven by terminal expansions.
Reporting program impacts
Product shifts can alter your status under state and federal reporting programs. Any time new materials are brought onsite, review Toxic Substances Control Act (TSCA), Toxics Release Inventory (TRI), Tier II, emission inventories, and release-reporting requirements to ensure changes are documented and reporting processes are adjusted accordingly.
Doing this work upfront can prevent last-minute scrambles to meet reporting deadlines.
Commissioning: the make-or-break month
Effective communication is essential during startup. Depending on the project and location, commissioning may require agency notifications, environmental testing, or other compliance actions—and without tight coordination it’s easy to miss a regulatory deadline.
PPM recommends constant communication between operations, maintenance, and EHS personnel during the commissioning window to ensure planning translates into a smooth transition.
Post-startup follow-through
Don’t celebrate too soon—there is still plenty of environmental work after startup. Documenting requirements on paper doesn’t guarantee the process will be picked up seamlessly in the field.
Make time to communicate changes with terminal personnel so everyone understands new processes and responsibilities. Once operations stabilize, conduct a post-startup review to confirm no requirements were missed and to document lessons learned for the next service change.
Removing surprises: a practical integration workflow
The most reliable new product integrations follow a structured sequence:
- Compatibility and integrity review to identify physical changes needed to support the product.
- Air permitting reassessment using accurate vapor pressure data and control-device checks to confirm regulatory applicability.
- Spill Prevention, Control, and Countermeasure (SPCC), Facility Response Plan (FRP), and RMP updates, including revised worst-case discharge and release scenarios.
- Stormwater/SWPPP review incorporating commissioning activities, BMPs, and any drainage changes.
- Reporting assessment to update Tier II, TRI, TSCA, emission inventories, and other applicable reports.
- Commissioning plan with daily cross-functional check-ins and ready spares/contingencies.
- Post-startup review to confirm field adoption of new processes and close out any remaining compliance actions.
How PPM supports product changes at terminals
PPM provides environmental regulatory reviews, emissions-control assessments, spill and response plan updates, and environmental reporting support for terminal projects. Our engineers help clients avoid hidden risks by aligning engineering, permitting, and operations before equipment is purchased.
Call to action
Request an assessment of your proposed terminal project: a focused desktop review that identifies your top five environmental risk areas before you move forward with product changes.