Variance Denials

State of North Carolina Department of Justice MICHAEL F EASLEY ATTORNEY GENERAL P.O.BOX629 RALEIGH 27602-0629 Reply to: Judith Robb Bullock Environmental Division intemet:[e-mail] Telephone: [phone] MEMORANDUM TO: /oavid Hance FROM: DATE: RE: Charlie Stehman Judith Robb Bullock ~~ I u,-J Special Deputy Attorney General August 19, 1997 Amoco Corporation FAX: [phone] Enclosed for your information is an Order issued by Judge Phipps in the above-referenced matter. Please advise me when the petition has been finalized so that I might advise the administrative law judge. \D -.J l::a c:: G'") N C) -0 :x .. 0 Cl n1 -C)-~ ;o·l""1 on c:~ :;t:< Orr, ~o ►;;, -i..,_ m.:;: ::c--~ (./) r,, p
MICHAEL F. EASLEY
ATTORNEY GENERAL
TO :
FROM:
DATE:
RE:
Arthur Mouberry
Rick Shiver
Charlie Stehman
Ken Schuster
Bruce Reed
David Hance
State of North Carolina
Department of Justice
P.O. BOX629
RALEIGH
27602-0629
Judith Robb Bullock ¢
Special Deputy Attorney General
April 18, 1997
Amoco Corporation v. NC Department of Environment,
Health and Natural Resources; 96 EHR 1890
This is to advise you that the hearing in the above-referenced case will not be heard next week.
The parties advised the court that a settlement is in progress and, depending on the outcome of
the Division's review of Amoco's submittal, a hearing may not be necessary.
In the motion, Amoco has agreed to submit its petition to the Division for review within 45 days
and I represented that the Division would be able to complete its review of Amoco's petition
within 60 days of submittal.
Please advise me if Amoco does not submit its petition in accordance with this schedule or if you
need additional time to complete the review. I will need to update the administrative law judge by
August 1, 1997 .
JRB/gb
9715rJ5El8 P.[11
.... ' ., ' ·-\
. ·l'
Please note that 15A NCAC 2L. 0113(h) shows that if the final decision of the
Environmental Management Commission is unacceptable to the person requesting the variance,
then the applicant may file a petition for a contested case in accordance with the requirements of
North Carolina General Statute (NCGS) 150B. 15A NCAC 2L .0113 further states that if a
petition is not filed within 60 days, then the decision by the Environmental Management
Commission is "final and binding". Pursuant to 15A NCAC 2L .0113(h) and NCGS 150B,
the Amoco Oil Company has until Monday December 9, 1996 to file a written petition with
the Office of Administrative Hearings to contest the denial o.f this variance request by the
Environmental Management Commission.
The address for the Office of Administrative Hearings is as follows:
Offic~ _ of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
A written petition sent to the Office of Administrative Hearings must be postmarked by
December 9, 1996 in order to meet the 60 day requirements of 15A NCAC 2L ,0113(h).
Attached is a copy ofNCGS 150B and 15A NCAC 2L .0113. Please feel free to contact me at
[phone] if you wish to discuss the denial of your request for variance. If you need to
discuss requirements for this site pursuant to 15A NCAC 2L, please call Mr. Charles Stehman or
Mr. Bruce Reed in the Wilmington Regional Office at [phone].
cc: Preston Howard
Arthur Mouberry
Groundwater Section Assistant Chiefs
Tom Warburton
David Hance
Wilmington Regional Groundwater Supervisor
DWQ-Public Information Officer
2
Sincerely,
~~7
Arthur Mou berry, P .E.,
Chief, Groundwater Section
Ken Schuster
Jennie Odette
Bruce Reed
Dr. Ken Rudo
Phil Telfer
David E. Klemm (S&ME, Inc)
Page 8
Amoco Oil Company
DISCUSSION
1. An adjacent water supply well owned by Atlantic Marine, Inc. is
located approximately 700 feet northwest of the variance request area
and they have submitted information showing that it is not being used
for consumption. Atlantic Diving and Marine Contractors, Inc. have a
contract with a company that provides.bottled water.
Five other water supply wells are located within a½ mile radius
of the variance request area. For these five locations well water use
is presently limited to supply process water or other uses not
associated with drinking water consumption, and each is reported to be
connected to the Wilmington municipal water supply.
2. In establishing that the requirements of the corrective
action/groundwater quality standards cannot be achieved by providing the
best available technology economically reasonable, the variance request
document states that there is free product down gradient (adjacent to
the Koch terminal). Further, that long term restoration is not possible
since re-contamination could occur from the Koch terminal plume. The
Wilmington Regional Office should maintain vigilante efforts to
encourage the responsible party to complete the site assessment and .
corrective action plan for the plume originating on the adjacent Koch
site.
3. It was initially the impression of this hearing officer that the
present remediation system (air-sparging)is located only to the south of
the Amoco property, on the American Crane Corporation property. I have
been informed by additional correspondence from Amoco that an air
biosparging system is being operated on the west side of the Citgo
terminal, up gradient of the variance request area. These sparging
wells were placed on-line in May 1995.
4. The nature of this variance request warranted the request for
additional information from Amoco Oil Company. The additional
information was requested by letter December 15, 1995 and was received
on January 31, 1996. on March 6, 1996 Bruce Reed of the Wilmington
Regional Office Groundwater staff telephoned to inform me that he
received a call from a representative of Amoco Oil Company. They let
him know that they recently had½ to 1 inch of free petroleum product in
one of the monitoring wells (MW-23) located in the variance request
area. on March 28, 1996 I received a copy of the February 26, 1996 well
sampling results. The laboratory analysis conducted on the sample from
the monitoring well MW-23 is reported as 'free product'. The
laboratory's cover letter to the analysis states that 'In summary, the
product found in MW-23 is not similar to fresh gasoline, but was similar
to or contained weathered gasoline'. The other two monitoring wells
located in the area for which the variance is requested also showed an
Page 7
Amoco Oil Company
Corporation's property rights?
(B)How would lenders react to a variance?
(C)How would having a variance on part of our property effect permits
that may be granted by the state and county?
Response to comment #4
The questions are responded to as follows:
(A) As per lSA NCAC 2D.0113(i): a variance shall not operate as a
defense to an action of law based upon a public or private nuisance theory or
any other cause of action.
(B) DEM regulations do not contain any authority to require lending
institutions to respond in a specified manner to variance situations. The
lending institutions may react as they see fit and in accordance with any
other laws or regulations that govern them.
(C) A review by the DEM groundwater staff of the permitting regulations
as they pertain to: Chapter 143, Article 21A, Part 2A and 15A NCAC 2N
(underground storage tanks) does not show any references to 'variances'. 15A
NCAC 2L (Classifications and water quality standards applicable to
groundwaters of NC) do not restrict sites from getting a permit that have
received a variance from the Commission. Well construction rules in 15A NCAC
2C .0100 and .0200 do not contain any additional construction requirements or
location requirements at a site where some of the property has been granted a
variance.
Comment #5:
Since Amoco proposes to rely on the natural process within the earth's
subsurface to reduce contaminant levels, have they proposed a time limit on
this variance?
Response to comment #5
The Company has not proposed a time limit on this variance. The process
of natural attenuation is highly dependent on subterranean features and it is
very difficult to project a time frame in which the process will complete
itself. As stated in response to comment #3, if the sampling results portray a
trend of increasing concentrations then active remediation could be required
as per a condition of a variance approval.
Page 6
Amoco Oil Company
An additional question is the possible re-contamination of the variance
area by the Koch plume. Amoco states that MW-32, where free-phase hydrocarbon
from Koch was obseryed, is located more than 100 feet down gradient from the
area of the variance request. They further believe the potential is small for
the Koch plume to affect the area covered by the variance request.
The risk assessment conducted for the Amoco plume showed that the
observed concentrations of hydrocarbons impacting the area of the variance
request do not constitute a significant risk to the human or environmental
receptors.
Comment #2:
The monitoring well data presented at the hearing is not sufficient to
demonstrate that contaminant levels are being reduced by natural remedial
processes. Not enough monitoring information exists to confirm that this
phenomenon is occurring.
Response to comment #2:
Monitoring data results for the three monitoring wells (MW-22, MW-23,
and MW-24) located on the Koch property have previously been submitted for
9/04/91, 6/15/93, 6/16/93, 2/16/94, and 8/24/95. That data by itself does not
show a trend of rising/decreasing concentrations. However, the analytical
results from sampling conducted on February 26, 1996 show 'free product' in
MW-23 and an increase in several constituent concentrations in MW-22 and MW-
24. The concentration of xylene in MW-22 shows an increase and is in excess of
the groundwater standard in 15A NCAC 2L.0202.
comment #3:
If new technology is developed after a variance is granted is there a
means to rescind a variance?
Response to comment #3
It would not be necessary to 'rescind' a variance. The approval of a
variance could be made conditioned such that if the BTEX or other constituents
increased at significant concentrations, then Amoco would have to amend a
corrective action plan to include active remediation in the area of the
variance. In addition, if groundwater monitoring reveals rising concentrations
of any constituent, or monitoring reveals new substances, the Wilmington
Regional Office can issue a 'Notice of Violation' which wQ~ld require that
corrective actions be implemented.
Comment #4:
Part of the land included in this variance request encompasses property
owned by the American Crane Corporation.
(A)How would the granting of a variance affect American Crane
Page 5
Amoco Oil Company
Response to comment #1:
The granting of a variance does not exempt Amoco Oil company from the
continued responsibility for the site. If a variance is granted at this site,
Amoco must maintain a groundwater monitoring effort as required by the
conditions of a variance and Division directives. Monitoring must continue
for a sufficient period of time to assure that remaining concentrations within
the area of the variance do not increase. If it appears concentrations are
increasing due .to the past actions of Amoco, the company may still be held
responsible for cleanup by the Division. If other property owners in the area
release substances into groundwaters, soil, or land surface within the area
that the variancE;i was granted, then the appropriate responsible parties will
be subject to the cleanup requirements of 15A NCAC 2L.
Active remediation is underway on'portions of the contaminant plume that
have higher pollutant concentrations. Whether Amoco 'knowingly' released
harmful substances into the environment is unknown.
Depending upon constituent concentrations, petroleum products in the
surface waters and groundwaters do have varying degrees of effect on the
environment. The Company has submitted a risk assessment including the
methodologies used to estimate the impacts the variance will have on human
health, the environment, and public welfare. The purpose of the site specific
risk assessment is to evaluate the potential adverse impacts associated with
the concentrations in and around the area of the requested variance. The
concerns of the commenter are noted and additional information was requested
from Amoco with respect to the risk assessment.
Site conditions vary significantly from one site to the next. Hydro-
geologic, chemical/physical pollutant, and physical characteristics all
contribute to the complexity of a site. The risk assessment evaluates these
characteristics and estimates the degree of risk the site poses to human
health and the environment. A risk assessment includes the identification of
exposure scenarios, pathways, and human and ecological receptors. Some common
groundwater exposure scenarios and pathways are ingestion, non-ingestion
contact such as irrigation or swimming, inhalation, and transport to surface
water.
The risk assessment conducted in support of the variance request looks
solely at the effects from the plume originating from the Amoco site. The
plume originating on the Koch property is located between the Amoco plume and
the river. The risk assessment evaluates impacts to several receptors
including the river. It does not include the impact from the Koch Plume.
As hearing officer I felt the need to ask for additional written
information with respect to the risk assessment as it was done. In the Amoco
response it was stated that there are several reasons for not attempting to
evaluate the Koch plume. The Amoco Oil Company does not have responsibility
for, nor control over the releases of petroleum unrelated to its former
operations at the asphalt terminal. They do not have the data that would be
necessary for a qualitative evaluation of risk. Therefore, they do not feel
that it is appropriate for Amoco to attempt to evaluate the risks that may be
posed by releases at the Koch facility.
Page 3
Amoco Oil Company
INTRODUCTION
In 1951 Amoco Oil Company (Amoco) constructed an asphalt blending,
storage, and sales facility. Amoco operated the facility until April 30, 1993,
at which time it was acquired by CITGO Petroleum Corporation (CITGO). The
CITGO terminal facility is located on River Road in Wilmington. The terminal
consists of approximately 31 acres of land and is about 900 feet east of the
Cape Fear River (see diagram attached). As a result of day-to-day terminal
operations occasional spills and leaks have occurred throughout the years and
have caused contamination of the subsurface soils and groundwater. Amoco has
accepted responsibility for delineating, evaluating, and implementing
appropriate remedial measures for the off-site portion of the dissolved
hydrocarbon plume that originated from what is now the CITGO Products
Terminal.
Initial test borings and monitoring wells were installed in 1988. The
Division sent a March 1989 Notice of Violation for the exceedance of
groundwater quality standards in three of the twelve monitorfng wells pursuant
to 15A NCAC 2L. Nine additional monitoring wells were installed in 1990. In
August of 1991 three monitoring wells were installed along the western edge of
the River Road right-of-way (held by NC DOT, see diagram attached). The
intent of the monitoring was to determine if the groundwater plume had
migrated beneath River Road onto the adjacent Koch Refining company (Koch)
terminal property.
In 1992 the DEM, Wilmington Regiqnal Office requested that additional
delineation of the plume be made. In response, seven permanent monitoring
wells were installed on the property owned by Koch Refining Company (Koch) and
12 temporary wells were installed on property owned by the American Crane
Corporation which is south of the CITGO and Koch terminals.
An approved Corrective Action Plan (CAP) is currently being implemented at the
CITGO terminal. Air sparging wells have been installed on site and down
gradient on the adjacent American Crane Corporation property.
A variance from 15A NCAC 2L .0202 (groundwater quality standards) and
15A NCAC 2L .0106(j) (corrective action) is requested by Amoco for the
approximate two acre area located on and across River Road, on properties
owned by the Citgo Products Terminal, The American Crane Corporation, CSX
Transportation, and Koch Refining Company. The land in which the area. of .the
variance encompasses the most offsite property is owned by Koch. Amoco has
made this variance request by filing an application in accordance with part(c)
of 15A NCAC 2L .0113.
Pursuant to 15A NCAC 2L .0113 (d) and (e), public notice of this
variance request was sent to adjacent property owners, the New Hanover County
Health Director, the City Manager for the City of Wilmington, and the Mayor of
Wilmington. Notice of this hearing was also published in the July 2, 1995
26, 1996 well sampling results. The laboratory analysis conducted on the
sample from the monitoring well MW-23 is reported as 'free product'. The
laboratory's cover letter to the analysis states that 'In summary, the product
found in MW-23 is not similar to fresh gasoline, but was similar to or
contained weathered gasoline'. The other two monitoring wells located in the
area for which the variance is requested also showed an increase in several
constituent concentrations between the February 26th and earlier analytical
data.
In light of the most recent February 26, 1996 analytical data, a copy of
which is attached, it would be difficult for me to support the requested
variance and thereby denial is recommended.
Please contact me if you have any questions concerning the report.
TRANSMISSION REPORT
02.[11 .. 2000 (1(1:00
State of North Carolina
Department of Environment,
Ht)alth and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
AVA
DEHNR
October 25, 1996
Mr. Jim Schaeffer, Project Remediation Coordinator
Amoco Corporation
Environment, Health, and Safety
375 Northridge Road, Suite 600
Atlanta, Georgia 30350-3323
Subject: Request for Variance from Groundwater Quality
Standards in 15A NCAC 2L .0202 and Corrective
Action requirements in ISA NCAC 2L .0106G) for
the Citgo Products Terminal on River Road in
Wilmington, North Carolina.
This is to inform you that the Environmental Management Commission, at their October
10, 1996 meeting , denied the subject variance request by Amoco Oil 'Company at the Citgo
Products Terminal (formerly known as the Amoco Asphalt Terminal). The Commission based
it's decision on the follo~ng:
1) Past releases known to have occurred at this site;
2) Past facility operations that have led to releases at this site;
3) The historic presence of free product found in a groundwater monitoring well at
this site;
4) The preseµce of free product that appeared during routine groundwater sampling
of Monitoring Well# 23 on February 26, 1996;
5) The lack of information to disprove or explain the presence of free product in
Monitoring well# 23 since it's discovery on February 26, 1996; and
6) The identity and characteristics of the dissolved hydrocarbons found in
groundwater samples taken at Monitoring Well #23 and other monitoring wells on
February 26, 1996, April 22, 1996, and May 29, 1996.
Groundwater Section,
P.O. Box 29578, Raleigh, North Carolina 27626-0578
2728 Capital Blvd., Raleigh, North Carolina 27604
N{JC
,rew·taee
Voice 919-733-3221 FAX [phone]
An Equal Opportunity/Affinnative Action Employer
50"/o recycles/lO"lo post-consumer paper
Please note that 15A NCAC 2L. 0113(h) shows that if the final decision of the
Environmental Management Commission is unacceptable to the person requesting the variance,
then the applicant may file a petition for a contested case in accordance with the requirements of
North Carolina General Statute (NCGS) 150B. 15A NCAC 2L .0113 further states that if a
petition is not filed within 60 days, then the decision by the Environmental Management
Commission is "final and binding". Pursuant to 15A NCAC 2L .0113(h) and NCGS 150B,
the Amoco Oil Company has until Monday December 9, 1996 to file a written petition with
the Office of Administrative Hearings to contest the denial of this variance request by the
Environmental Management Commission.
The address for the Office of Administrative Hearings is as follows:
Offic~ ,of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
A written petition sent to the Office of Administrative Hearings must be postmarked by
December 9, 1996 in order to meet the 60 day requirements of ISA NCAC 2L .0l 13(h).
Attached is a copy ofNCGS 150B and 15A NCAC 2L .0113. Please feel free to contact me at
[phone] if you wish to discuss the denial of your request for variance. If you need to
discuss requirements for this site pursuant to 15A NCAC 2L, please call Mr. Charles Stehman or
\..fr. Bruce Reed in the Wilmington Regional Office at [phone].
cc: Preston Howard
Arthur Mouberry
Groundwater Section Assistant Chiefs
Tom Warburton
David Hance
Wilmington Regional Groundwater Supervisor
DWQ-Public Information Officer
2
Sincerely,
Arthur Mouberry, P.E.,
Chief, Groundwater Section
Ken Schuster
Jennie Odette
Bruce Reed
Dr. Ken Rudo
Phil Telfer
David E. Klemm (S&ME, Inc)
Page2 of3
10/30/96
Points 1) through 3) are valid issues which Amoco understands must be identified and taken into
consideration. However, the fact that these are issues related to past facility operations are in and
of themselves support to the variance request. The alternative to past operations can only be
current or ongoing operations. In addition, the historic presence of Separate Phase Hydrocarbons
(SPH) was limited to the vicinity of MW-7, was determined to be kerosene, and was located
approximately 480 feet upgradient of the variance request area.
Points 4) through 6) deal with the SPH found in MW-23 and appear to address the dissolved
hydrocarbon concentrations in groundwater taken from other monitoring wells in the area of the
variance request. First, it is very important to consider that the SPH found in MW-23 on
February 26, 1996, was recorded at a thickness of 0.13 feet and has not returned to the monitor
well since its initial discovery. Second, on behalf of Amoco, our consultant S&ME submitted a
report to the NCDEHNR Wilmington Regional Office, dated July 2, 1996, which_ documented
the investigation into the detection of SPH in MW-23. The SPH was identified as a weathered
gasoline and not kerosene. This further substantiates Amoco's contention that the SPH found in
MW-7 is not related to the SPH found in MW-23.
The closest surficial aquifer monitor wells located up gradient and within the area of the variance
request are MW-I, MW-21, MW-22, MW-23, MW-24, MW-38, and MW-39. With the
exception of MW-21, groundwater from these monitor wells was analyzed according to EPA
Method 8020 and 8270 for benzene, toluene, ethylbenzene, and xylene (BTEX) and polynuclear
aromatic hydrocarbon (PAH) constituents, respectively. The results from May 29, 1996 showed
that no benzene was reported above detection limits in any of the sampled monitor wells. Total
BTEX concentrations were within the same order of magnitude relative to historical data with the
exception of MW-23. However, even though MW-23 recently had SPH, the Total BTEX
concentration was only 1,950 micrograms per liter. In addition, the only PAH constituents
reported in any of these monitor wells were naphthalenes, a constituent of gasoline.
Somehow in the past, whether related to on-site or off-site operations, gasoline constituents
entered the subsurface. Since Amoco stopped storing gasoline at the facility around 1988, thei;e .
is no potential future source for gasoline constituents. Therefore, the origin of the gasoline is of
little consequence, as what really matters is the condition of the variance area now. When
discovered in February 1996, the SPH was in a very weathered state as evident by SPH analysis
and the traces left behind in the form of dissolved hydrocarbons.
The following items summarize the main reasons why Amoco feels the variance request should
be approved: 1) The area of the variance request is less than two acres in size and consists
mainly _of River Road, railroad right-of-way, and undeveloped property. It is separated from the
terminal by River Ro~ which poses problems for remediation system installation as discussed
in the variance request; 2) The risk assessment submitted as part of the variance request showed
that the BTEX and P AH groundwater concentrations in the area of the variance request do not
pose a threat to human health or the environment. This still applies, since the increases in
·•
Page 3 of3
10/30/96
concentrations are not significant enough to invalidate the risk assessment; 3) Citgo in
conjunction with Amoco is in the process of effectively remediating groundwater upgradient of
the variance area; 4) SPH has not been identified in MW-23 since its original discovery in
February 1996; and 5) Amoco has met all the requirements applicable to ISA NCAC 2L .0113
for the variance request.
In addition, Amoco has shown an undeniable commitment to address the environmental situation
with moral and legal fortitude. Since the discovery of SPH in MW-23 Amoco has installed two
additional monitor wells and increased sampling frequency to adequately address the concerns of
the Wilmington Regional Office. In the near future a third monitor well will be installed on the
Koch Industries property downgradient of the variance area for further assessment.
Amoco understands that approval of the variance request does not relieve us of our ~h)J.gation to
protect human health and the environment. We merely contend that the installation of a
groundwater treatment system in the area of the variance request is an unsubstantiated and
inappropriate use of resources. We are confident that with a proper monitoring program the
remediation objectives can be achieved at this portion of the site.
Based on the discussion presented above, Amoco would like to request a formal appeal to discuss
the decision of the Environmental Management Commission. Please contact my office at (770)
512-6861 so that a meeting may be arranged.
Respectfully,
~
Jim Schaeffer, P.
Environmental Project Manager
Amoco Corporation
cc: Tom Farrior -Citgo
David Klemm -S&ME
Arthur Mouberry, P.E. -NCDEHNR Division of Water Quality, Raleigh
Kathy Randall, Amoco Government Affairs
Bruce Reed -NCDEHNR Wilmington Regional Office
Ken Schuster, P.E. -NCDEHNR Raleigh Regional Office
Richard Wbisnat, Chief Counsel -NCDEHNR, P.O. Box 29535, Raleigh, NC 27626
Please note that ISA NCAC 2L. Ol 13(h) shows that if the final decision of the
Environmental Management Commission is unacceptable to the person requesting the variance,
then the applicant may file a petition for a contested case in accordance with the requirements of
North Carolina General Statute (NCGS) 150B. ISA NCAC 2L .0113 further states that if a
petition is not filed within 60 days, then the decision by the Environmental Management
Commission is "final and binding". Pursuant to 15A NCAC 2L .0113(h) and NCGS 150B,
the Amoco Oil Company has until Monday December 9, 1996 to file a written petition with
the Office of Administrative Hearings to contest the denial of this variance request by the
Environmental Management Commission.
The address for the Office of Administrative Hearings is as follows:
Office of Administrative Hearings
P.O. Drawer 27447
Raleigh, North Carolina 27611-7447
A written petition sent to the Office of Administrative Hearings must be postmarked by
December 9, 1996 in order to meet the 60 day requirements of 15A NCAC 2L .0113(h).
Attached is a copy ofNCGS 150B and ISA NCAC 2L .0113. Please feel free to contact me at
[phone] if you wish to discuss the denial of your request for variance. If you need to
discuss requirements for this site pursuant to 15A NCAC 2L, please call Mr. Charles Stehman or
Mr. Bruce Reed in the Wilmington Regional Office at [phone].
cc: Preston Howard
Arthur Mouberry
Groundwater Section Assistant Chiefs
Tom Warburton
David Hance
Wilmington Regional Groundwater Supervisor
DWQ-Public Information Officer
2
Sincerely,
Arthur Mouberry, P.E.,
Chief, Groundwater Section
Ken Schuster
Jennie Odette
Bruce Reed
Dr.Ken Rudo
Phil Telfer
David E . Klemm (S&ME, Inc)
' :
l#-1/{)tf .fE ;ff E;ff O:
DATE; 10,2. A$• 'Ji .
TO: ,it,~N A
FROM:J), ·MA r,1..cl,
SUBJECT: m 4 l '
\
Page 1
Amoco Oil Company
Good Morning Mr. Chairman and members of the Commission. My name is Ken
Schuster and I am the Division of Water Quality Supervisor for the Raleigh Regional Office. On
August 3, 1995 I served as hearing officer for a Public Hearing held in Wilmington. The purpose
of the hearing was to receive comments pertaining to a variance requested by the Amoco Oil
Company. The request is for a variance from Groundwater Quality Standards in 15A NCAC 2L
.0202 and Corrective Action as required by 15A NCAC 2L .0106G).
In 1951 Amoco Oil Company constructed an asphalt blending, storage, and sales facility.
Amoco operated the facility until April 30, 1993, at which time it was acquired by CITGO
Petroleum Corporation (CITGO). The CITGO terminal facility is located on River Road in
Wilmington. The terminal consists of approximately 31 acres of land and is about 900 feet east of
the Cape Fear River. As a result of day-to-day terminal operations occasional spills and leaks have
occurred throughout the years and have caused contamination of the subsurface soils and
groundwater. Amoco has accepted responsibility for delineating, evaluating, and implementing
appropriate remedial measures for the off-site portion of the dissolved hydrocarbon plume that
originated from what is now the CITGO Products Terminal.
Initial test borings and monitoring wells were installed in 1988. Since then additional
monitoring wells have been installed. The intent of the monitoring has been to delineate the extent
of the petroleum contaminate plume and to determine if the plume had migrated beneath River
Road onto the adjacent.properties. An approved Corrective Action Plan (CAP) is currently being
11
Page 2
Amoco Oil Company
implemented at the CITGO terminal. Air sparging wells have been installed on site and down
gradient on the adjacent American Crane Corporation property.
A variance from the groundwater quality standards contained in ISA NCAC 2L .0202 and
the corrective action requirements in ISA NCAC 2L.0106G) is requested by Amoco for the
approximate two acre area located: on and across River Road, on properties owned by the Citgo
Products Terminal, The American Crane Corporation, CSX Transportation, and Koch Refining
Company. Page __ of your EMC document contains a ~iagram which shows the adjoining
property owners better than I can describe. The land in which the area of the variance encompasses
the most off site property is owned by Koch Refining Company. Amoco has made. this variance
request by filing an application in accordance with part(c) of ISA NCAC 2L .0113. By requesting
the variance, Amoco is requesting that no active remediation efforts be required of them in the
designated area.
Public notice of this variance request was sent to appropriate parties, including television
and radio stations that serve New Hanover County. A public hearing was held on August 3, 1995. A
total of twelve registered persons attended the hearing, with two people presenting oral comments.
Written comments were submitted by one speaker. No other written comments were received. The
hearing record allowed for written comments to be submitted through September 4, 1995.
One commentor is deeply concerned about the effect of petroleum product pollution on
wetlands, drinking water, surface waters, wildlife, and humans. Skepticism was expressed about the
Page 3
Amoco Oil Company
claims that asphaltic substances and petroleum products found at this site will degrade naturally over
time . Another concern expressed was that the monitoring well data is not sufficient to demonstrate
that contaminant levels are being reduced by natural remedial processes and that not enough
monitoring information exists to confirm that this is occurring. Other questions pertained to
adjoining land owner property rights. Detailed responses to these public comments are contained in
my hearing officer report.
On March 6, 1996 the Wilmington Regional Office Groundwater staff telephoned to inform
me that they had received a call from a representative of Amoco Oil Company. Amoco informed the
Department they recently had½ to 1 inch of free petroleum product in one of the monitoring wells
(MW-23) located in the variance request area. The laboratory's cover letter to the analysis states that
'In summary, the product found in MW-23 is not similar to fresh gasoline, but was similar to or
contained weathered gasoline'. The other two monitoring wells located in the area for which the
variance is requested also showed an increase in several constituent concentrations between the
February 26th and earlier analytical data.
In a September letter to Amoco, the Wilmington Regional Office stated it was their opinion
that the free-phase petroleum in MW-23 must have originated from the former Amoco Ashphalt
Terminal for the following three reasons: l)The summary accompanying the analytical data stated
that the product resembled "weathered gasoline", which indicates the product has been in the
subsurface for some time and is not related to a recent release. 2) The compounds detected in MW-
23 are the same as those found in up gradient well number MW-39, but at slightly lower
Page 4
Amoco Oil Company
concentration, and 3) Free-phase petroleum was historically found in well number MW-7 at the
former Amoco Asphalt Terminal. As a result of the Region's review, they are requesting that a new
monitoring well be constructed.
In light of the February 1996 analytical data showing free-phase petroleum in MW-23 and
elevated concentrations above the MCL's in nearby wells, it is my and the Director's
recommendation that the requested variance be denied. If you have any questions, I or other
Division staff will be glad o try to address them. Thank you.
STOP!!!!!!!!
DISCUSSION
1. An adjacent water supply well owned by Atlantic Marine, Inc. is located
approximately 700 feet northwest of the variance request area and they have submitted
information showing that it is not being used for consumption. Atlantic Diving and Marine
Contractors, Inc. have a contract with a company that provides bottled water.
Five other water supply wells are located within a ½ mile radius of the variance
request area. For these five locations well water use is presently limited to supply process
water or other uses not associated with drinking water consumption, and each is reported to
be connected to the Wilmington municipal water supply.
2. In establishing that the requirements of the corrective action/groundwater quality
standards cannot be achieved by providing the best available technology economically
reasonable, the variance request document states that there is free product down gradient
(adjacent to the Koch terminal). Further, that long term restoration is not possible since re-
contamination could occur from the Koch terminal plume. The Wilmington Regional Office
should maintain vigilante efforts to encourage the responsible party to complete the site
assessment and corrective action plan for the plume originating on the adjacent Koch site.
3. It was initially the impression of this hearing officer that the present remediation
system (air-sparging)is located only to the south of the Amoco property, on the American
Crane Corporation property. I have been informed by additional correspondence from
Pages
Amoco Oil Company
Amoco that an air biosparging system is being operated on the west side of the Citgo
terminal, up gradient of the variance request area. These sparging wells were placed on-line
in May 1995.
4. The nature of this variance request warranted the request for additional information
from Amoco Oil Company. The additional information was requested by letter December 15,
1995 and was received on January 31, 1996. On March 6, 1996 Bruce Reed of the
Wilmington Regional Office Groundwater staff telephoned to inform me that he received a
call from a representative of Amoco Oil Company. They let him know that they recently had
½ to 1 inch of free petroleum product in one of the monitoring wells (MW-23) located in the
variance request area. On March 28, 1996 I received a copy of the February 26, 1996 well
sampling results. The laboratory analysis conducted on the sample from the monitoring well
MW-23 is reported as 'free product'. The laboratory's cover letter to the analysis states that
'In summary, the product found in MW-23 is not similar to fresh gasoline, but was similar to
or contained weathered gasoline'. The other two monitoring wells located in the area for
which the variance is requested also showed an increase in several constituent concentrations
between the February 26th and earlier analytical data. In light of the most recent February
26, 1996 analytical data, a copy of which is attached, it would be difficult for me to support
the requested variance and thereby denial is recommended.
RECOMMENDATION
In taking into account public comment, a review of the documentation submitted for the
request for variance, subsequent discussions with staff, and primarily on the analytical monitoring
data it is recommended that the variance be denied.
*************** The following 3 paragraphs can be skipped over************
The risk assessment conducted by Amoco in support of the variance request looked solely at
the effects from the plume originating from the Amoco site. On the Koch property there is a
contaminate plume, which includes free-phase petroleum product, between the Amoco plume and
the river. The risk assessment evaluated impacts to several receptors including the river. It does not
include any additional impact from the Koch Plume. The risk assessment conducted for the Amoco
plume showed that the observed concentrations of hydrocarbons impacting the area of the variance
request do not constitute a significant risk to the human or environmental receptors.
As hearing officer I felt tlie need to ask for additional written information with respect to the
risk assessment as it was done. In the Amoco response it was stated that there are several reasons for
there not attempting to evaluate the Koch plume, including there not having responsibility for, nor
control over the releases of petroleum unrelated to its former operations at the asphalt terminal.
Further, that they do not have the data that would be necessary for a qualitative evaluation of risk.
' .
Page 6
Amoco Oil Company
Therefore, they do not feel that it is appropriate for Amoco to attempt to evaluate the risks that may
be posed by releases at the Koch facility.
An additional question is the possible re-contamination of the variance area by the Koch
plume, as well as from Amoco. Amoco states that MW-32, where free-phase hydrocarbon from
Koch was observed, is located more than 100 feet down gradient from the area of the variance
request. Amoco believe's the potential is small for the Koch plume to affect the area covered by the
variance request.
************ The above paragraphs can be skipped***********
end report
.,,..
to groundwaters of NC) do not restrict sites from getting a permit that have received a variance the
Commission. Well construction rules in 15A NCAC 2C .0100 and .0200 do not contain any
additional construction requirements or location requirements at a site where some of the property
has been granted a variance.
·,, . . . ,.
WILMINGTON REGIONAL OF Fax:[phone]
~ --... -.
Sep 17 '96 9:42 P.02
Page2
Due to the recent fmdings concerning . this incident, we request that you construct another
monitoring well directly downgradient from MW-23 (betwoonMW-28 and MW-29) to determine the extent
of the groundwater quality standard exceedaitces. Please incorporate this well and well numbers MW-28,
MW-38, and MW-39 into your monitoring plan_
If you have any questions concerning this letter, please call Bruce Reed or myself at {910) 395-
3900.
CFS/J3AR/gjg.'
cc: •. David ~emm
Ken Schuster
WiRO-GWS
CF
bmee\:icbaeff2-.apr
Charles"F. Stehman, Ph.D., P.O.
Environmental Regional Supervisor I
NOTE: 07/15/96
TO: Ken Schuster,
SUBJECT: STATUS OF THE CITGO PRODUCTS TERMINAL VARIANCE .
On July 11, 1996 the Groundwater Committee met to discuss the Citgo Products
Terminal variance. Arthur Mouberry presented your hearing officer's report with a
recommendation that this variance be denied at the September 12, 1996 Environmental
Management Commission Meeting. The Committee members gave their approval to
proceed to the full commission with the recommendation. During the discussion the
Committee had a number of questions concerning the enforcement history of the site that
could not be answered from the report. In preparing your presentation of the hearing
officers report to the EMC at the September meeting, please be ready to discuss the
cleanup activities at this site and the NOV history with the Commission.
Attached is a copy of the Groundwater Committee meeting packet that was
provided at the July meeting. Item # 5 shows the materials presented to the Committee.
If you need to discuss this memo, please feel free to contact me at 715-6189.
David Hance
cc: Carl Bailey
1
~I
Jrnn: d5ruc~ad
M q {) -
·.,.
'.
WI~Mil-¥3TON R~G~OJ'l8L OF F~x:910-350-2004
Page2
Sep 17 '96 9:42 P.02
Due to the recent findings concerning . this incident, we request that you construct another
monitoring well directly downgradient from MW-23 (betweenMW-28 and "MW-29) to detenninc the extent
of the groundwater quality standard exceedances. Ple3se incorporate this well and well numbers MW-28,
MW-38, and MW-39 into your monitoring plan_
If you have any questions concernmg this letter, please call Broce RJ,ed or myself at (910) 395-
3900.
CFS/J3AR/gjg.=
cc: David Klemm
Ken Schuster
WiR.0-.GWS
CF
bmce\sc:baeft2.apr
y~IY·~
Charles'F. Stehman, Ph.D., P.O.
Environmental Regional Supervisor I
---------------------------
.. , ._ .... , ..... ~-•. ··•
.• ,· .• .,, .i: { L·:
• .... r'., .. ,_. -~ ,: -. ·-··
North Carolina Department of Environment,
Health and Natural .Resources--,,.,,.,,, ..
3800 Barrett Drive, Suite 101
Raleigh, North Ca_r()U_na 27609
ATTENTION:
Reference:
Dear Mr. Schuster:
Mr. Kenneth Schuster
VARIANCE AREA ADDITIONAL INVESTIGATION
CITGO Asphalt Terminal
(Formerly Amoco Corporation)
Wilmington, North Carolina
S&ME, Inc. Project 1264-95-243
S&ME, Inc. has completed additional assessment at the CITGO Asphalt terminal property
located on River Road in Wilmington, North Carolina.· The proposed monitoring we.11s
were installed to further evaluate the potential that the free phase hydrocarbons detected
in MW-23 on February 26, 1996 had originated from the CITGO terminal located up-
gradient of that well.
The following report presents the procedures, findings and results of the additional
investigation. If you have any questions following your review of this report, please do
not hesitate to contact us.
Stanfa ummus, P.E.
Senior nvironmental Engineer
S&/v\E. Inc. 155 Trodd Street, Spartanburg, South Carolina 29301, [phone], Fox [phone]
Greenville, South Carolina, [phone]
Variance Area Additional Investigation
Amoco Corporation -Wilmington, NC
---------------------------
BACKGROUND INFORMATION
s&ME Project No. 1264-95-243
July 1996
In April, 1995 Amoco Corporation (Amoco) and CITGO Petroleum Corporation (CITGO)
entered into a joint effort to remediate a dissolved BETX plume originating from the
CITGO terminal (Formerly Amoco Corporation). The agreement between Amoco and
CITGO required CITGO to be responsible for on-site portions of the plume and Amoco
to be responsible for the off-site portions of the plume. An air sparging treatment system
was installed in the southwestern portion of the facility and directly to the south of the
facility property. However, a small strip of land directly west of the facility along River
Road up to the KOCH · property was evaluated for a variance to the groundwater
standards due to low levels of dissolved BETX in the groundwater in that area. A
variance request was prepared by Remediation Technologies, Inc. (ReTech) for the
referenced area under the direction of Amoco. As part of the variance area request,
three monitoring wells (MW-22, MW-23, and MW-24) were to be sampled on a semi-
annual schedule to monitor dissolved hydrocarbon concentrations in the groundwater
within the variance area. The semi-annual sampling schedule was initiated on August 24,
1995. The results of that sampling event compared with historical groundwater data from
these wells. The second semi-annual sampling of these wells was performed on
February 26, 1996. During this sampling event, a thin layer of separate phase
hydrocarbons was detected in monitoring well MW-23 which had never been detected
in the past. A sample of the product was collected and sent to a laboratory for
fingerprinting. The results of the fingerprinting suggested the product was of a weathered
gasoline nature. At the request of Amoco, S&ME initiated weekly gauging of monitoring
well MW-23. At the first well gauging the product was discovered to be absent. S&ME
collected a groundwater sample from MW-23 on April 22, 1996 and had the sample
analyzed for BETX parameters by EPA method 602. The results of this sampling
indicated slightly higher BETX concentrations as compared to historical concentrations
in this well.
Variance Area Additional Investigation
Amoco Corporation -Wilmington, NC
S&M E Project No. 1264-95-243
July 1996
The North Carolina Department of Environment, Health and Natural Resources Division
of Environmental Management (DEM) requested additional assessment be performed
north and south of existing monitoring well MW-1 to evaluate if the product detected in
MW-23 may have migrated from the CITGO terminal across River Road. It was indicated
the final approval of the variance request may be contingent ~pon results of the additional
assessment performed on the CITGO property. The procedures, findings and results of
the assessment are included in the following sections.
MONITORING WELL INSTALLATIONS
On May 24, 1996 S&ME mobilized to the site to install two monitoring wells to the south
(MW-38) and north (MW-39) of existing monitoring well MW-1, directly up gradient of
monitoring well MW-23. The drilling for the monitoring wells was performed by Carolina
Drilling (Wilmington, North Carolina). The monitoring well permit (WM0800215) was
issued by DEM on May 15, 1996. The location of the monitoring wells are shown on the
attached Figure 1.
The bore holes for the monitoring wells were completed using continuous flight, hollow
stem augers. The bore hole for MW-38 was completed to a total depth of 24 feet below
grade which was approximately 6.5 feet below the groundwater table interface. The bore
hole for MW-39 was completed to a total depth of 22 feet below grade which was
approximately 6.0 feet below the groundwater table interface. During drilling, soil cuttings
from the bore holes were evaluated by the field technician for relative lithologic
characteristics, and also were subjected to soil gas screening using a Foxboro, Century
128 organic vapor analyzer. (OVA). At the completion depth of the drilling, a 2-inch
diameter monitoring well was installed in each bore hole. The monitoring wells were
constructed of schedule 40 PVC solid riser and 0.01-inch manufacturer slotted screen.
The screen intervals were 10-feet in length and were installed approximately 6 feet below
2
Variance Area Additional Investigation
Amoco Corporation -Wilmington, NC
s&ME Project No. 1264-95-243
July 1996
and 4 feet above the groundwater surface. A clean, medium grain sand was installed to
approximately one foot above the top of the screen interval. A 1-foot bentonite seal was
installed above the filter pack. The remainder of the bore hole annulus was completed
with a neat cement grout. The monitoring wells were completed with flush grade, steel
protective covers. Each monitoring well was sealed with a Jocking water tight cap.
Monitoring Well Logs were completed for each well which depict the well completion
details, the lithologic information, and the results of soil gas screening. These Monitoring
Well Logs are included in the Appendix.
SOIL GAS SCREENING
During drilling of the monitoring wells, soil cuttings were collected at approximate five foot
intervals and placed in clean re-sealable containers. The soil gas · was allowed to
equilibrate with the head space of the container. The probe of an OVA was then inserted
into the head space of the container and the resulting reading in parts per million (ppm)
was recorded. The OVA readings provide a relative measure of the volatile organic vapor
content of the sample.
The results of the OVA screening indicated that relatively low concentrations of organic
vapors exist in the soil gas from the samples collected from monitoring well MW-38 (0-38
ppm). The OVA screening of the samples collected from MW-39 indicated low
concentrations in the soil gas to 15 feet below land surface (10-30 ppm); however, the
sample collected at 22 feet below land surface resulted in an organic concentration of
>10Cl0 ppm. The field crew indicated the depth to groundwater encountered during
drilling was approximately 16 feet below grade. The OVA readings are included on the
Well Logs.
3
Variance Area Additional Investigation
Amoco Corporation -Wilmington, NC
LIQUID ELEVATION GAUGING
S&ME Project No. 1264-95-243
July 1996
On May 28, 1996 S&ME performed a comprehensive well gauging event at the site. As
part of this well gauging event, monitoring wells MW-38 and MW-39 were checked for
potential free phase hydrocarbons floating on the groundwater surface. Based on the
high OVA readings recorded near the groundwater surface iri MW-39, this well was also
checked by lowering a bailer into the well to the liquid interface, retrieving the bailer, and
observing for the presence of a separate phase layer. No free phase hydrocarbons were
noted in either well. Monitoring well MW-39 was again checked for the presence of free
phase hydrocarbons on June 4, 1996. No free p~ase hydrocarbons were noted in the
well. The well gauging data is included in Table 1..
A Groundwater Surface Map was constructed for the site by entering the May 28, 1996
groundwater elevation data into a computer software contouring program (Surfer, Golden
Software, 1993-1995). This map is included as Figure 1. The groundwater surface
slopes to the southwest with an approximate gradient of 0.014 feet/foot, consistent with
historical data for this site.
GROUNDWATER SAMPLING AND ANALYTICAL TESTING
.
A quarterly groundwater sampling event was perfonned at the site on May 28 and 29,
1996. In accordance with the site Corrective Action Plan, on-site monitoring wells MW-1,
MW-2, MW-21, MW-36 and MW-37, and off-site monitoring wells MW-30 through MW-34
were sampled for volatile organic compounds (BETX/MTBE) by EPA method 602.
Monitoring well MW-11 was also sampled for BETX/MTBE to evaluate dissolved
hydrocarbon concentrations in the northwestern portion of the site near the tanner rail car
loading rack.
4
f"'., r l
Variance Area Additional Investigation
Amoco Corporation • Wilmington, NC
S&ME Project No. 1264·95-243
July 1996
In order to obtain the best representative site data in the vicinity of MW-23, the two new
wells MW-38 and MW-39, in addition to monitoring wells MW-2~, MW-23 and MW-24
were sampled during this event. Note that this sampling event did not correspond to a
semi-annual variance area sampling event. Groundwater samples from these wells were
analyzed for volatile organic compounds BETX/MTBE by ErA 602 and for polynuclear
aromatic hydrocarbons (PAHs) by SW-8270. The groundwater sample obtained from
MW-~ was also analyzed for PAHs.
For purposes of this report, only the analytical data corresponding to this assessment and
the variance area request will be discussed (MW-1, MW-22, MW-23, MW-24, MW-38 and
MW-39). The remaining groundwater data will be presented in the Second Quarter
Monitoring Report under separate cover. A summary of the analytical data is included
as Table 2. Laboratory reports and chain of custody forms are ·attached in the Appendix.
The results of the analytical testing indicate exceedances of the groundwater standard
for ethylbenzene and xylenes in MW-21, MW-22, MW-23 MW-38 and MW-39. Generally,
the data from monitoring wells MW-1, MW-38 and MW-39 do not support off-site
migration of free phase product to monitoring well MW-23. The individual BETX/PAH
constituents in MW-38 are lower than reported in MW-23. The individual BETX/PAH
constituents in MW-39 compare more closely to that reported in MW-23 with sJightly
higher toluene concentrations and lower ethylbenzene concentrations. The data from
MW-1 does not correlate due to influence from a near-by sparge well. The May 28, 1996
and April 24, 1996 data for MW-23 compare reasonably well, indicating an increase in
dissolved SETI< following the isolated detection of free phase product in the well.
5.
Variance Area Additional Investigation
Amoco Corporation -Wilmington, NC
CONCLUSIONS
S&ME Project No. 1264-95-243
July 1996
The data collected during this additional assessment of the variance area do not indicate
dissolved hydrocarbon concentrations inconsistent to the known dissolved hydrocarbon
concentrations across the site. The dissolved BETX/PAH conqentrations in the monitoring
wells along the western border of the CITGO property (MW-22, MW-38, MW-1 and MW-
39) do not appear to support off-site migration of free phase hydrocarbons; free product
has not been detected in any of the on-site monitoring wells bordering the variance area.
The detection of free product in MW-23 is isolated to the February 26, 1996 well gauging
event. The reason for this isolated occurrence is unknown. The only evidence of the free
product is the increased dissolved BETX concentrations reported for MW-23. Please note
that these concentrations are on the same order of magnitude as those historically
reported for monitoring well MW-22 which is also a variance area monitoring well. The
current concentrations of dissolved hydrocarbons reported in MW-21, MW-38, MW-1,
MW-39, MW-22, M-23, and MW-24 which border the variance area do not appear to
warrant withdrawal or refusal of the variance area request.
6
' '
PROJECT: CITGO Petroteu• Corporation WELL LOG MW-38 Wilmington. North C•ollna .
PROJECT NO. : 1284-93-309 ELEVATION: NOTES:
LOGGED BY: R. Connell BORING DEPTH: 24 FEET
TOC Elevation 26.71 msl
DATE DRILLED: 05/24/96 WATER LEVEL: 17.5 feet ~ T0B
DRILLING METHOD: HSA DRILL RIG: Carolina Drilling
u wa:: w WELL DIAGRAM
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Description & Remarks
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trace silt
Boring terminated at 24
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SECOND QUARTER MONITORING
REPORT
APRIL 1 -JUNE 30, 1996
CITGO ASPHALT TERMINAL
(FORMERLY AMOCO CORPORATION)
WILMINGTON, NORTH CAROLINA
S&ME PROJECTS
1264-93-309/1264-95-243
Prepared for.
CITGO PETROLEUM CORPORATION
SAVANNAH, GEORGIA
&
AMOCO CORPORATION
ATLANTA, GEORGIA
, ,::r:tt::_:, 1J
_ ~repared by:
S&ME, Inc.
Spartanburg, South Carolina
July 1996
---------------------------
North Carolina Department of Environment,
Health and Natural Resources
127 Cardinal Drive Extension
Wilmington, North Carolina 28405-3845
ATTENTION:
Reference:
Dear Mr. Reed:
Mr. Bruce A. Reed
SECOND QUARTER MONITORING REPORT
APRIL 1 -JUNE 30, 1996
CITGO Asphalt Terminal
(Formerly Amoco Corporation)
Wilmington, North Carolina
S&ME, Inc. Projects 1264-93-309/1264-95-243
Enclosed is the Second Quarter Monitoring Report (April 1 -June 30, 1996) for the
CITGO Asphalt Terminal (formerly Amoco Corporation) in Wilmington, North Carolina.
This report includes details of the monitoring performed for both the on-site and off-site
1··:: l remediation areas and presents the results of groundwater elevation gauging and
groundwater quality sampling. Also included are the results of the additional assessment
and monitoring of the variance area as a result of the isolated free product occurrence
in MW-23 on February 26, 1996.
If you have any questions or comments, please feel free to contact us at (864) 574~2360. ·
Sincerely,
s!tf~s,P.E.
Senior ~;:~~ntal Engineer
cc:
S&ME, Inc. 155 Tradd Street, Spartanburg, South Carolina 29.301, (864) 574-2.360, Fax [phone]
Greenville, South Carolina, (864) 2.32-8987
' '.
L
Second Quarter Monitoring Report
CITGO Asphalt Tenninal
S&ME Projects 1264-93-309/1264~95-243
July 1996
1.0 INTRODUCTION
A groundwater remediation project was implemented at the site in the second quarter of
1995. The official start-up date of the system was May 18, 1995. Ten monitoring wells
were selected for monitoring water quality within the remediation area. Five of the
monitoring wells are located on the CITGO terminal property (MW-1, MW-2, MW-21, MW-
36, and MW-37). The remaining five monitoring wells (MW-30, MW-31, MW-32, MW-33,
and MW-34) are located south of the terminal on the American Crane property. Baseline
monitoring of these ten wells was performed on March 29, 1995 prior to start up of the
system. The baseline monitoring indicated all five of the on-site monitoring wells had one
or more BETX constituents over the North Carolina groundwater MCLs. Of the off-site
monitoring wells, only MW-30 indicated an exceedance of the groundwater MCL for
ethylbenzene. This exceedance was only 1 µg/L over the groundwater MCL of 29 µg/L.
Three quarterly samplings of the monitoring wells have been completed since start-up of
the system, and prior to this quarter's sampling event. These sampling events were
performed on August 24 and November 15, 1995, and February 26, 1996. The results
of each of these sampling events indicated two on-site monitoring wells contained
dissolved hydrocarbons over the groundwater MCLs. None of the off-site wells indicated
exceedances of the groundwater standards for any of the three referenced Sq,mpling
events. The results of the three sampling events were submitted in formal reports dated
September 28, 1995, January 5, 1996, and April 3, 1996.
A variance request was completed under the direction of Amoco Corporation by
Remediation TechnologiE?S Incorporated (Re Tech) for the area to the west of the CITGO
terminal including River Road and west of River Road to the Koch terminal. Three
monitoring wells (MW-22, MW-23, MW-24) were selected to monitor hydrocarbon
concentrations in the variance area. These wells are sampled on a semi-annual basis.
Second Quarter Monitoring Report
CITGO Asphalt Tenninal
S&ME Projects 1264-93-309/1264-95-243
July 1996
Previous semi-annual sampling events have been completed for these wells on August
24, 1995 and February 26, 1996. The results of the August 24, 1995 sampling event
indicated exceedances of the groundwater MCLs for ethylbenzene and xylenes in MW-22,
and for ethylbenzene in MW-23. There were no groundwater MCL exceedances reported
for MW-24. The results of the February 26, 1996 sampling event indicated exceedance
of the groundwater MCLs for ethylbenzene and xylenes in MW-22. No exceedances were
reported for MW-24. Free product was measured in MW-23 on February 26, 1996 which
was laboratory reported as weathered gasoline. The occurrence of free product in MW-
23 was isolated to only the February 26, 1996 well gauging. A sample of the
groundwater from MW-23 was collected on April 24, 1996 and tested for BETX. The
results of the April 24, 1996 sampling are presented in this report.
In a letter to Amoco Corporation dated April 18, 1996, Mr. Ken Schuster of NCDEHNR
indicated that the variance area request can not be recommended for final approval
unless additional data is presented indicating the product in MW-23 was not a result of
activities related to the CITGO facility. As a result of that letter, Amoco and CITGO
agreed to provide additional assessment up-gradient of MW-23 along the CITGO property
boundary. The proposed assessment consisted of the installation of two monitoring wells
south (MW-38) and north {MW-39) of existing monitoring well MW-1 at the locations
recommended by NCDEHNR. Groundwater sampling and testing of the variance area
was performed on May 29, 1996 in conjunction with the regular quarterly groundwater
monitoring sampling event for the site. The data for the additional assessment was
presented in a Variance Area Additional Investigation report dated July 2; 1996. The
groundwater data for the remediation area and variance area monitoring are presented
in Section 3.0 of this report.
2
Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
2.0 SITE MONITORING PLAN
Groundwater monitoring was performed for both the remediation area and variance area
in the second quarter of 1996. The monitoring for the remediation area was performed
in accordance with the site Corrective Action Plan. The variance area sampling was
-. · performed voluntarily this quarter by Amoco to aid in providing adequate information to
obtain final approval of the variance request. The results and comparison of the data to
previous sampling events are discussed in the following sections.
2.1 GROUNDWATER ELEVATION DATA
One comprehensive set of groundwater level data was collected by S&ME on M~y 28,
1996 to evaluate groundwater flow direction and gradient across the site. Groundwater
levels were measured in all accessible on and off-site monitoring wells. The groundwater
levels were measured relative to each well's top of casing (TOC). The groundwater levels
and the surveyed TOC elevations (relative to mean sea level) were used to convert the
groundwater level data to groundwater elevations.
Groundwater elevations at the site ranged from 12.40 to 25.10 feet above mean sea
level. A Groundwater Surface Map (Figure 1) was generated by entering the grouf!dwater
elevation data into a contouring software program (Golden Software, Surfer, 1995). The
Groundwater Surface Map indicates the groundwater surface slopes to the southwest with
a horizontal gradient of 0.014 feet per foot, consistent with past groundwater, elevation
data. Groundwater elevation data is included in Table 1.
3
! .
r-
' I i
l '
Second Quarter Monitoring Report
CITGO Asphalt Terminal
2.2 GROUNDWATER SAMPLING
S&ME Projects 1264-93-309/1264-95-243
July 1996
Groundwater samples were collected from ten monitoring wells in the remediation area
(MW-1, MW-2, MW-21, MW-30 through MW-34, MW-36 and MW-37), from three
monitoring wells in the variance area (MW-22, MW-23, and MW-24), and from the two
new wells (MW-38 and MW-39) installed as part of the variance area investigation.
Monitoring well MW-11 is not part of the sampling plan, but was also sampled to compare
hydrocarbon concentrations up gradient of the variance area to concentrations within the
variance area. A groundwater sample was also collected from MW-23 on April 24, 1996
after the disappearance of free product from the well.
Each of the groundwater samples were subjected to analysis for purgeable aromatic
hydrocarbons benzene, ethylbenzene, toluene, xylenes (BETX) by EPA method 602. The
remediation area wells were also analyzed for MTBE. The wells used to evaluate the
variance area (MW-1, MW-22, MW-23, MW-24, MW-38 and MW-39) were tested for
BETX/MTBE and polynuclear aromatic hydrocarbons by Solid Waste SW-846 #8270. A
summary of the groundwater quality data is presented in Tables 2 and 3. These tables
provide previous sampling data where available and indicate the parameters which
exceed the current North Carolina groundwater quality standards (15A NCAC 2L .0202).
Laboratory reports and chain-of-custody fonns are attached in the Appendix.
2.3 FREE PRODUCT
On February 26, 1996 groundwater elevation gauging indicated approximately 0.13 feet
(1.5 inches) of product in monitoring well MW-23. This well was one of the wells selected
to monitor water quality in the variance area and historically had not contained free
4
Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
product. The historical groundwater quality data for the well indicates the only BETX
parameter which had exceeded a groundwater MCL was ethylbenzene.
At the request of Amoco, S&ME was to begin a weekly well gauging and hand bailing of
product from monitoring well MW-23. At the first visit to the well, no free product was
measured. Subsequent visits to the well indicate the free product noted in the well was
isolated to the February 26, 1996 well gauging event.
3.0 EVALUATION OF SAMPLING DATA
3.1 REMEDIATION AREA GROUNDWATER QUALITY
Five on-site monitoring wells and five off-site monitoring wells are used to evaluate site
remediation. The following two sections present an evaluation of the current sampling
data. Individual plume maps were not developed due to the sporadic occurrence of BETX
data over their respective groundwater quality standards.
3.1.1 On-site Groundwater Quality Data
The five on-site monitoring wells selected to evaluate groundwater quality include ~W-1,
If MW-2, MW-21, MW-36 and MW-37. The reported laboratory results indicate monitoring
wells MW-21 and MW-37 have excedances of the groundwater standards for
ethylbenzene and xylenes. MW-21 exhibited respective ethylbenzene and xylene
concentrations of 142 micrograms per liter (µg/L) and 941 µg/L. MW-37 exhibited
respective ethylbenzene and xylene concentrations of 208 µg/L and 990 µg/L. The
respective groundwater standards for these chemicals are 29 µg/L and 530 µg/L.
5
Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
A historical comparison of the groundwater quality data for the on-site remediation area
indicates the dissolved BETX concentrations have consistently decreased for monitoring
wells MW-1, MW-2, and MW-36. The dissolved BETX concentrations in MW-21 dropped
to below the groundwater standards for the August and November 1995 sampling events.
The air flow rate to the sparging wells in the vicinity of MW-21 were subsequently
decreased. The last two sampling events have indicated some rebounding BETX
concentrations in this well. Air flow rates will be increased back to more normal operating
conditions (5 cfm). The dissolved concentrations in monitoring well MW-37 have
fluctuated over the course of the project.
The analytical data presented in the last quarterly report suggested that the data for MW-
2 and MW-21 may have been switched. A comparison of the historical sets of data for
these two wells suggested that the data for MW-2 more closely correlated with the
historical data for MW-21, and the data for MW-21 more closely correlated with the
historical data for MW-2. It was stated that this quarters data would provide additional
information to clarify the BETX concentrations in these wells. The data from this quarter
are consJstent with last quarter's data and support that the data presented in the first
quarter for these wells was reported correctly and were not switched.
3.1.2 Off-site Groundwater Quality Data
The five off-site monitoring wells selected to evaluate the effectiveness of remediation
include MW-30, MW-31, MW-32, MW-33, and MW-34. Based on the current groundwater
quality data, no BETX or MTBE was detected in the off-site wells over the quantitation
limit of 0.5 µg/L. This is the fourth quarter in which BETX/MTBE has not been detected
over the groundwater standards in the remediation area to the south of the terminal.
6
Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
3.2 VARIANCE AREA GROUNDWATER QUALITY DATA
The wells which were evaluated for the variance area for this quarter are MW-1, MW-11
MW-22, MW-23, MW-24, MW-38 and MW-39. This quarter does not correspond to a
semi-annual sampling event for the variance area; however, due to the free product
detected in MW-23 on February 26, 1996, NCDEHNR indicated that the variance request
would not be presented for final approval unless it could be demonstrated that the product
did not originate from the CITGO terminal. As part of this demonstration, two additional
monitoring wells were installed (MW-38 and MW-39) to the north and south of MW-1 as
shown on Figure 1. Each of the seven listed monitoring wells were sampled for BETX
by EPA method 602. Groundwater samples from MW-1, MW-22, MW-23, MW-24, MW-
38 and MW-39 were also analyzed for PAHs by solid waste method SW-846 #8270. As
mentioned, a groundwater sample was collected from MW-23 on April 14, 1996 after
disappearance of product from the well. The results of the analytical testing are included
on Table 3. Analytical reports and chain of custody forms are attached in the appendix.
The results of the analytical testing indicate exceedances of the groundwater standard
for ethylbenzene and xylenes in MW-11, MW-21, MW-22, MW-23, MW-38 and MW-39.
MW-11 also indicated an exceedance for benzene by 0.65 µg/L. With the exception of
MW-23, the variance area monitoring wells have resulted in consistent concentrati?ns of
dissolved BETX since the first known sampling of the wells in September 1991. The
increase in MW-23 corresponds with the isolated free product occurrence on February
26, 1996. However, the data from monitoring wells MW-1, MW-38 and MW-39 do not
support off-site migration of free phase product to the variance area or monitoring well
MW-23. The individual BETX/PAH constituents in MW-38 are lower than reported in MW-
23. The individual BETX/PAH constituents in MW-39 compare more closely to that
reported in MW-23 with slightly higher toluene concentrations and lower ethylbenzene
7
L __
Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
concentrations. The data from MW-1 does not correlate due to influence from a near-by
sparge well. No free product was detected in the variance area monitoring wells. The
data from MW-11 (on-site near the rail car loading rack) consistently has yielded
dissolved BETX concentrations lower than in MW-22 (off-site along the west side of River
Road) indicating the rail car loading area is probably not a significant source of dissolved
petroleum hydrocarbons to the variance area.
4.0 SUMMARY OF FINDINGS
The free product discovered in monitoring well MW-23 appears to be an isolated event.
The only date in which free product was detected in the well was February 26 , 1996. The
only current. evidence of the free product appears to be elevated dissolved hydrocarbon
concentrations compared to the historical groundwater quality data from that well. The
additional assessment completed up-gradient of MW-23 does not support off-site
migration of product from the CITGO Property. The dissolved hydrocarbon
concentrations in on-site monitoring wells MW-1 and MW-38 are lower than that detected
in off-site monitoring well MW-23. The dissolved hydrocarbon concentrations in on-site
monitoring well MW-39 are approximately the same as those detected in MW-23. The
hydrocarbon concentrations in on-site monitoring well MW-11 are lower than that detected
in off-site monitoring well MW-22 indicating the rail car loading area is not a sigryificant
~j contributor of dissolved hydrocarbons to the variance area. The current dissolved
hydrocarbon concentrations in MW-23 are on the same order of magnitude as those in
MW-22.
The trend in dissolved hydrocarbons concentrations tends to increase off-site (down
gradient of the terminal). This is true for on-site monitoring wells MW-38, MW-1, and
MW-11 which have lower dissolved hydrocarbons concentrations than the off-site (down
8
Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
gradient) monitoring wells MW-22 and MW-23. The exception is on-site monitoring well
MW-39 which has approximately the same dissolved hydrocarbon concentration as MW-
22 and MW-23. Given the current available data, withdrawal of the variance area request
does not appear appropriate.
Based on the collective monitoring data to date, S&ME recommends continuing air
sparging within the on-site remediation area. The air flow rate to the sparge wells in the
vicinity of MW-21 will be increased to approximately 5 cfm per well. Four consecutive
quarters of data from the American Crane property have yielded purgeable aromatic
hydrocarbon concentrations below their respective 15A NCAC 2L groundwater standards.
S&ME recommends terminating air sparging on _the American Crane property and to
continue monitoring for four more quarters. If four quarters of data without active
1_,_, remediation continue to result in concentrations below the groundwater standards, S&ME
-~ will recommend no further action for the off-site portion of the plume on the American
Crane property.
5.0 OPERATION AND MAINTENANCE
During the quarter low air flow was observed through the manifold system even though
the compressor was operating properly. The three stage air filtration system was
disassembled and observed. It appeared that the first stage particulate filter was
clogging. The second stage coalescing and third stage carbon filter appeared in good
condition. The first stage filter element was changed. In addition, the compressor air
filter was changed.
9
Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
gradient) monitoring wells MW-22 and MW-23. The exception is on-site monitoring well
MW-39 which has approximately the same dissolved hydrocarbon concentration as MW-
22 and MW-23 .. Given the current available data, withdrawal of the variance area request
does not appear appropriate.
Based on the collective monitoring data to date, S&ME recommends continuing air
sparging within the on-site remediation area. The air flow rate to the sparge wells in the
vicinity of MW-21 will be increased to approximately 5 cfm per well. Four consecutive
quarters of data from the American Crane property have yielded purgeable aromatic
hydrocarbon concentrations below their respective 15A NCAC 2L groundwater standards.
S&ME recommends terminating air sparging on the American Crane property and to
continue monitoring for four more quarters. If four quarters of data without active
remediation continue to result in concentrations below the groundwater standards, S&ME
will recommend no further action for the off-site portion of the plume on the American
Crane property.
5.0 OPERATION AND MAINTENANCE
During the quarter low air flow was observed through the manifold system even though
the compressor was operating properly. The three stage air filtration systerp was
?::~~ disassembled and observed. It appeared that the first stage particulate filter was
clogging. The second stage coalescing and third stage carbon filter appeared in good
condition. The first stage filter element was changed. In addition, the compressor air
filter was changed.
L
L
9
I,
WELL :
. : . . . ..
. ......
MW-9
MW-10
MW-11
MW-12
MW-13
MW-14
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
·:·.DATE· :. JO(; :_: _· 'UQUIO ·_ ·· · .. WA;fER .. ' ·_: ··p;r : .. :
. . ELEV __ ·· ... , pr;e.m. ... ,: ::oEPtA'' _··: ·::j
.: ·(MSLJ : -<tt-ie o··: . ,.:::'(ft~):·. ,. flfl: .· ..
. . ·.•.-.. ·.·.·. .. L::.. .. . ..
06/16/93 32.73 17.29 17.29 0.00
09/20/93 32.73 17.37 17.37 0.00
03/29/95 32.73 16.75 16.75 0.00
08/25/95 32.73 17.14 17.14 0.00
11/15/95 32.73 18.39 18.39 0.00
02/26/96 32.73 18.46 18.46 0.00
05/28/96 32.73 18.39 18.39 0.00
06/16/93 42.92 15.55 15.55 0.00
09/20/93 42.92 15.50 15.50 0.00
03/29/95 42.92 14.76 14.76 0.00
08/25/95 42.92 15.54 15.54 0.00
11/15/95 42.92 15.37 15.37 0.00
02/26/96 42.92 15.86 15.86 0.00
05/28/96 42.92 16.12 16.12 0.00
06/16/93 24.68 14.33 14.33 0.00
09/20/93 24.68 14.25 14.25 0.00
03/29/95 24.68 13.75 13.75 0.00
08/25/95 24.68 13.91 13.91 0.00
11/15/95 24.68 13.00 13.00 0.00
02/26/96 24.68 15.62 15.62 0.00
05/28/96 24.68 15.44 15.44 0.00
06/16/93 22.36 11.41 11.41 0.00
09/20/93 22.36 11.44 11.44 0.00
03/29/95 22.36 10.85 10.85 0.00
08/25/95 22.36 11.09 11.09 0.00
11/15/95 22.36 11.02 11.02 0.00
02/26/96 22.36 12.98 12.98 0.00
05/28/96 22.36 12.50 12.50 0.00
06/16/93 29.85 17.25 1725 0.00
09/20/93 29.85 17.22 1722 0.00
03/29/95 29.85 16.65 16.65 0.00
08/25/95 29.85 16.92 16.92 0.00
11/15/95 29.85 16.98 16.98 0.00
02/26/96 29.85 18.25 18.25 0.00
05/28/96 29.85 18.40 18.40 0.00
06/16/93 28.91 15.97 15.97 0.00
09/20/93 28.91 16.04 16.04 0.00
03/29/95 28.91 15.16 15.16 0.00
08/25/95 28.91 15.61 15.61 0.00
11/15/95 28.91 15.65 15.65 0.00
02/26/96 28.91 17.91 17.91 0.00
05/28/96 28.91 17.76 17.76 0.00
; WA'l::ER(
Ir :Et:;J:;\l:
. ···1M.$t): :
15.44
15.36
15.98
15.59
14.34
14.27
14.34
27.37
27.42
28.16
27.38
27.55
27.06
26.80
10.35
10.43
10.93
10.77
11.68
9.06
9.24
10.95
10.92
11.51
11.27
11.34
9.38
9.86
12.60
12.63 •
13.20
12.93
12.87
11.60
11.45
12.94
12.87
13.75
13.30
13.26
11.00
11.15
\:~LL·.
::::: :·_ ·-
MW-15
MW-16
MW-17D
MW-18O
MW-19
MW-20D
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
.. . ·,·-=_oATE T -r~--':'.JJlQW.P:> • ::WATER :·· DEPTH ' :·E:;:::rr.::···;=; .
.. ' · ELE\(:' . ::::,~~nt r: . ..
: I> J MSLl .. : :fft~ -: : =)(tfu? ·:: . :: ---ft;.re l) · ·= ....
::: .. · .... ;-... :-.. _ .. ::::
06/16/93 32.94 14.10 14.10 0.00
09/20/93 32.94 14.18 14.18 0.00
03/29/95 32.94 13.53 13.53 0.00
08/25/95 32.94 13.90 13.90 0.00
11/15/95 32.94 13.76 13.76 0.00
02/26/96 32.94 15.34 15.34 0.00
05/28/96 32.94 15.28 15.28 0.00
06/16/93 33.64 14.06 14.06 0.00
09/20/93 33.64 14.14 14.14 0.00
03/29/95 33.64 13.63 13.63 0.00
08/25/95 33.64 13.92 13.92 0.00
11/15/95 33.64 13.96 13.96 0.00
02/26/96 33.64 15.28 15.28 0.00
05/28/96 33.64 15.45 15.45 0.00
06/16/93 24.22 13.99 13.99 0.00
09/20/93 24.22 13.90 13.90 0.00
03/29/95 24 .22 13.38 13.38 0.00
08/25/95 24.22 13.52 13.52 0.00
11/15/95 24.22 13.32 13.32 0.00
02/26/96 24.22 15.20 15.20 0.00
05/28/96 24.22 15.10 15.10 0.00
06/16/93 33.50 16.88 16.88 0.00
09/20/93 33.50 16.84 16 .84 0.00
03/29/95 33.50 16.27 16.27 0.00
08/25/95 33.50 16.60 16.60 0.00
11/15/95 33.50 16.64 16.64 0.00
02/26/96 33.50 18.13 18.13 0.00
05/28/96 33.50 18.21 18.21 0.00
06/16/93 29 .88 17.17 17.17 0.00
09/20/93 29.88 17.15 17.15 0.00
03/29/95 29.88 16.52 16.52 0.00
08/25/95 29.88 16.70 16.70 0.00
11/15/95 29.88 16.86 16.86 0.00
02/26/96 29.88 18.44 18.44 0.00
05/28/96 29 .88 18.41 18.41 0.00
06/16/93 25.70 15.22 15 .22 0.00
09/20/93 25.70 16.62 16.62 0.00
03/29/95 25.70 15.02 15.02 0.00
08/25/95 25.70 15.00 15.00 0.00
11/15/95 25.70 15.01 15.01 0.00
02/26/96 25 .70 16 .48 16.48 0.00
05/28/96 25.70 16.88 16.88 0.00
. -·:WATER:
'.iELEV'·::
-/t M$.tk = .
18.84
18.76
19.41
19.04
19.18
17.60
17.66
19.58
19.50
20.01
19.72
19.68
18.36
18.19
10.23
10.32
10.84
10.70
10.90
9.02
9.12
16.62
16.66
17.23
16.90
16.86
15.37
15.29
12.71
12.73 .
13.36
13.18
13.02
11.44
11.47
10.48
9.08
10.68
10.70
10.69
9.22
8 .82
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
W§µ.:::;::: :P~Tlt :rQC,T\ ::,LIQUID->' >'WATER:::=. :: ·::pJ:', =-= =:wATER=
:::·:::::: .. ·• .:\:E.Lltv.::,:::: \DEPTH:': ,:=OeeiH.'' ·. : := . _···< : Jtt~j(.
:,:-•:,,::\:. ·· ____ . •·(MStj ::.:i ·:+tn-re ll :::,1::::.1tt~j·:== ·.::fffl ··= •. : J MSL J=··=
MW-27 06/16/93
09/20/93
03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-30 09/20/93
03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-31 03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-32 03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-33 03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-34 03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-36 03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-37 03/29/95
08/25/95
11/15/95
02/26/96
05/28/96
MW-38 05/28/96
MW-39 05/28/96
TOC -top of casing
MSL -mean sea level
ft-rel -feet relative to TOC
33.47
33.47
33.47
33.47
33.47
33.47
33.47
31.13
31.13
31.13
31.13
31.13
31.13
34.46
34.46
34.46
34.46
34.46
33.70
33.70
33.70
33.70
33.70
32.81
32.81
32.81
32.81
32.81
30.03
30.03
30.03
30.03
30.03
28.52
28.52
28.52
28.52
28.52
28.23
28.23
28.23
28.23
28.23
26.71
24.28
1621
16.45
16.20
16.23
17.74
17.90
22.21
21.69
21.83
21.71
22.82
22.98
24.17
24.20
24.15
25.00
25.10
21.59
21.84
21.45
22.86
22.95
23.65
23.60
23.65
24.90
24.56
20.00
20.00
20.00
20.70
20.80
18.02
18.14
1827
19.34
19.47
16.60
16.72
16.77
17.95
18.10
17.74
15.18
16.21
16.45 .....
16.20
16.23
17.74
17.90
2221
21.69
21.83
21.71
22.82
22.98
24.17
24.20
24.15
25.00
25.10
21.59
21.84
21.45
22.86
22.95
23.65
23.60
23.65
24.90
24.56
20.00
20.00
20.00
20.70
20.80
18.02
18.14
1827
19.34
19.47
16.60
16.72
16.77
17.95
18.10
17.74
15.18
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
17.26
17.02
•••
17.27
17.24
15.73
15.57
8.92
9.44
9.30
9.42
8.31
8.15
10.29
10.26
10.31
9.46
9.36
12.11
11.86
12.25
10.84
10.75
9.16
9.21
9.16
7.91
8.25
10.03
10.03
10.03
9.33
9.23
10.50
10.38
10.25
9.18
9.05
11.63
11.51
11.46
10.28
10.13
8.97
9.10
(7
I .:
1.:/
\.
SECOND QUARTER MONITORING
REPORT
APRIL 1 -JUNE 30, 1996
CITGO ASPHALT TERMINAL
(FORMERLY AMOCO CORPORATION)
WILMINGTON,· NORTH CAROLINA
S&ME PROJECTS
1264-93-309/1264-95-243
Prepared for:
CITGO PETROLEUM CORPORATION
SAVANNAH, GEORGIA
&
AMOCO CORPORATION
ATLANTA, GEORGIA
. f>repared by:
S&ME, Inc.
Spartanburg, South Carolina
July 1996
lID rn@~~wrnm1
ill JUL O 5 1996 J1!J
--------------------------·
n
July 2, 1996
North Carolina Department of Environment,
Health and Natural Resources
127 Cardinal Drive Extension
Wilmington, North Carolina 28405-3845
ATTENTION:
Reference:
Dear Mr. Reed:
Mr. Bruce A. Reed
SECOND QUARTER MONITORING REPORT
APRIL 1 -JUNE 30, 1996
CITGO Asphalt Terminal
(Formerly Amoco Corporation)
Wilmington,. North Carolina
S&ME, Inc. Projects 1264-93-309/1264-95-243
Enclosed is the Second Quarter Monitoring Report (April 1 -June 30, 1996) for the
CITGO Asphalt Terminal (formerly Amoco Corporation) in Wilmington, North Carolina.
This report includes details of the monitoring performed for both the on-site and off-site
remediation areas and presents the results of groundwater elevation gauging and
· groundwater quality sampling. Also included are the results of the additional assessment
and monitoring of the variance area as a result of the isolated free product occurrence
in MW-23 on February 26, 1996.
If you have any questions or comments, please feel free to contact us at [phone].
Sincerely,
s&~s,P.E.
Senior ~;i,":,'.;~ntal Eng ineer
S&ME. Inc. 155 Tradd Street. Spartanburg . South Carolina 29301. [phone], Fox [phone]
Greenville, South Carolina. [phone]
n l
J
Fl ' TABLE OF CONTENTS , ....
PAGE
1.0 INTRODUCTION ........... · ................................... 1
2.0 SITE MONITORING PLAN •••••.•••.••.••.••••••••••••••••••••••• 3 n 2.1 GROUNDWATER ELEVATION DATA ••..•••••••••••••••••• ~ • 3
i/.:.-i 2.2 GROUNDWATER SAMPLING .............................. 4
2.3 FREE PRODUCT ....................................... 4
F-;~ 1;.:-:j
& 3.0 EVALUATION OF SAMPLING DATA •.•..•••••••.•.••••••.••••••••• 5
f\
' l t, __ ..
f.-i .
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3.1 REMEDIATION AREA GROUNDWATER QUALITY ••••..•.•..•.• 5
3.1.1 On-Site Groundwater Quality Data ••.•••••••••••••••••• 5
3.1.2 Off-Site Groundwater Quality Data .•.•••••••.••••••••.• 6
3.2 VARIANCE AREA .GROUNDWATER QUALITY DATA •••••.••.••• 7
4.0 SUMMARY OF FINDINGS •••••.••••.•.•••••..•••••••••••..•••.•• 8
5.0 OPERATION AND· MAINTENANCE •••••••••••••••••••••• _ •.••••••.. 9
FIGURES
FIGURE 1 -GROUNDWATER SURFACE MAP
TABLES
TABLE 1 -SUMMARY OF GROUNDWATER ELEVATION DATA
TABLE 2 -GROUNDWATER QUALITY DATA (REMEDIATION AREA)
TABLE 3 -GROUNDWATER QUALITY DATA (VARIANCE AREA)
APPENDIX
LABORATORY REPORTS
CHAIN-OF-CUSTODY
mrn@rnlhwrnm1
ill JUL O 5 1996 ilJj
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Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
1.0 INTRODUCTION
A groundwater remediation project was implemented at the site in the second quarter of
1995. The official start-up date of the system was May 18, 1995. Ten monitoring wells
were selected for monitoring water quality within the remediation area. Five of the
monitoring wells are located on the CITGO terminal property (MW-1, MW-2, MW-21, MW-
36, and MW-37). The remaining five monitoring wells (MW-30, MW-31, MW-32, MW-33,
and MW-34) are located south of the terminal on the American Crane property. Baseline
monitoring of these ten wells was performed on March 29, 1995 prior to start up of the
system. The baseline monitoring indicated all five of the on-site monitoring wells had one
or more BED< constituents over the North Carolina groundwater MCls. Of the off-site
monitoring wells, only MW-30 indicated an exceedance of the groundwater MCL for
ethylbenzene. This exceedance was only 1 µg/L over the groundwater MCL of 29 µg/L.
Three quarterly samplings of the monitoring wells have been completed since start-up of
the system, and prior to this quarter's sampling event. These sampling events were
performed on August 24 and November 15, 1995, and February 26, 1996. The results
of each of these sampling events indicated two on-site monitoring wells contained
dissolved hydrocarbons over the groundwater MCls. None of the off-site wells indicated
exceedances of the groundwater standards for any of the three referenced sampling
events. The results of the three sampling events were submitted in formal reports dated
September 28, 1995, January 5, 1996, and April 3, 1996.
A variance request was completed under the direction of Amoco Corporation by
Remediation Technologi~s Incorporated (Re Tech) for the area to the west of the CITGO
tenninal including River Road and west of River Road to the Koch tenninal. Three
monitoring wells (MW-22, MW-23, MW-24) were selected to monitor hydrocarbon
concentrations in the variance area. These wells are sampled on a semi-annual basis.
r r . Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
Previous semi-annual sampling events have been completed for these wells on August
24, 1995 and February 26, 1996. The results of the August 24, 1995 sampling event
indicated exceedances of the groundwater MCls for ethylbenzene and xylenes in MW-22,
and for ethylbenzene in MW-23. There were no groundwater MCL exceedances reported
for MW-24. The results of the February 26, 1996 sampling event indicated exceedance
of the groundwater MCLs for ethylbenzene and xylenes in MW-22. No exceedances were
reported forMW-24. Free product was measured in MW-23 on February 26, 1996 which
was laboratory reported as weathered gasoline. The occurrence of free product in MW-
23 was isolated to only the February 26, 1996 well gauging. A sample of the
groundwater from MW-23 was collected on April 24, 1996 and tested for BETX. The
results of the April 24, 1996 sampling are presented in this report.
In a letter to Amoco Corporation dated April 18, 1996, Mr. Ken Schuster of NCDEHNR
indicated that the variance area request can not be recommended for final approval
unless additional data is presented indicating the product in MW-23 was not a result of
activities related to the CITGO facility. As a result of that lettar, Amoco and CITGO
agreed to provide additional assessment up-gradient of MW-23 along the CITGO property
boundary. The proposed assessment consisted of the installation of two monitoring wells
south (MW-38) and north (MW-39} of existing monitoring well MW-1 at the locations
recommended by NCDEHNR. Groundwater sampling and testing of the varianc~ area
::\ was performed on May 29, 1996 in conjunction with the regular quarterly groundwater
monitoring sampling event for the site. The data for the additional assessment was
presented in a Variance Area Additional Investigation report dated July 2, 1996. The
groundwater data for the remediation area_ and variance area monitoring are presented
in Section 3.0 of this report.
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Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
2.0 SITE MONITORING PLAN
Groundwater monitoring was performed for both the remediation area and variance area
in the second quarter of 1996. The monitoring for the remediation area was performed
in accordance with the site Corrective Action Plan. The variance area sampling was
performed voluntarily this quarter by Amoco to aid in providing adequate information to
obtain final approval of the variance request. The results and comparison of the data to
previous sampling events are discussed in the following sections.
1 -2.1 GROUNDWATER ELEVATION DATA
One comprehensive set of groundwater level data was collected by S&ME on May 28,
1996 to evaluate groundwater flow direction and gradient across the site: Groundwater
levels were measured in all accessible on and off-site monitoring wells. The groundwater
levels were measured relative to each wall's top of casing (TOC). The groundwater levels
and the surveyed TOC elevations (relative to mean sea level) were used to convert the
groundwater level data to groundwater elevations.
Groundwater elevations at the site ranged from 12.40 to 25.10 feet above mean sea
level. A Groundwater Surface Map (Figure 1) was generated by entering the groundwater
elevation data into a contouring software program (Golden Software, Surfer, 1995). The
Groundwater Surface Map indicates the groundwater surface slopes to the southwest with
a horizontal gradient of 0.014 feet per foot, consistent with past groundwater. elevation
data. ·Groundwater elevation data is included in Table 1.
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Second Quarter Monitoring Report
CITGO Asphalt Terminal
2.2 GROUNDWATER SAMPLING
S&ME Projects 1264-93-309/1264-95-243
July 1996
Groundwater samples were collected from ten monitoring wells in the remediation area
(MW-1, MW-2, MW-21, MW-30 through MW-34, MW-36 and MW~37), from three
monitoring wells in the variance area (MW-22, MW-23, and MW-24), and from the two
new wells (MW-38 and MW-39) installed as part of the variance area investigation.
Monitori_ng well MW-11 is not part of the sampling plan, but was also sampled to compare
hydrocarbon concentrations up gr~dient of the variance area to concentrations within the
variance area. A groundwater sample was also collected from MW-23 on April 24, 1996
after the disappearance of free product from the well.
Each of the groundwater samples were subjected to analysis for purgeable aromatic
hydrocarbons benzene, ethylbenzene, toluene, xylenes (BETX} by EPA method 602. The
remediation area wells were also analyzed for MTBE. The wells used to evaluate the
variance area (MW-1, MW-22, MW-23, MW-24, MW-38 and MW-39) were tested for
BETX/MTBE and polynuclear aromatic hydrocarbons by Solid Waste SW-846 #8270. A
summary of the groundwater quality data is presented in Tables 2 and 3. These tables
provide previous sampling data where available and indicate the parameters which
exceed the current North Carolina groundwater quality standards {15A NCAC 2L .0202).
Laboratory reports and chain-of-custody forms are attached in the Appendix.
2.3 FREE PRODUCT
On February 26, 1996 groundwater elevation gauging indicated approximately 0.13 feet
(1.5 inches) of product in monitoring well MW-23. This well was one of the wells selected
to monitor water quality in the variance area and historically had not contained free
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Second Quarter Monitoring Report
CITGO Asphalt Tem,inal
S&ME Projects 1264-93-309/1264-95-243
July 1996
product. The historical groundwater quality data for the well indicates the only BETX
parameter which had exceeded a groundwater MCL was ethylbenzene.
At the request of Amoco, S&ME was to begin a weekly well gauging and hand bailing of
product from monitoring well MW-23. At the first visit to the well, no free product was
measured. Subsequent visits to the well indicate the free product noted in the well was
r::::: isolated to the February 26, 1996 well gauging event. r:-·.:.:
[ ·.:.
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3.0 EVALUATION OF SAMPLING DATA
n 3.1 REMEDIATION AREA GROUNDWATER QUALITY
r ' U1
Five on-site monitoring wells and five off-site monitoring wells are used to evaluate site
remediation. The following two sections present an evaluation of the current sampling
data. Individual plume maps were not developed due to the sporadic occurrence of BETX
data over their respective groundwater quality standards.
3.1.1 On-site Groundwater Quality Data
The five on-site monitoring wells selected to evaluate groundwater quality includeMW-1,
MW-2, MW-21, MW-36 and MW-37. The reported laboratory results indicate monitoring
wells MW-21 and MW-37 have excedances of the groundwater standards for
ethylbenzene and xylenes. MW-21 exhibited respective ethylbenzene and xylene
concentrations of 142 micrograms per liter (µg/L) and 941 µg/L. MW-37 exhibited
respective ethylbenzene and xylene concentrations of 208 µg/L and 990 µg/L. The
respective groundwater standards for these chemicals are 29 µg/L and 530 µg/L.
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Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
A historical comparison of the groundwater quality data for the on-site remediation area
indicates the dissolved BETX concentrations have consistently decreased for monitoring
wells MW-1, MW-2, and MW-36. The dissolved BETX concentrations in MW-21 dropped
to below the groundwater standards for the August and November 1995 sampling events.
The air flow rate to the sparging wells in the vicinity of MW-21 were subsequently
decreased. The last two sampling events have indicated some rebounding BETX
concentrations in this well. Air flow rates will be increased back to more normal operating
conditions (5 cfm). The dissolved concentrations in monitoring well MW-37 have
fluctuated over the course of the project.
The analytical data presented in the last quarterly report suggested that the data for MW-
2 and MW-21 may have been switched. A comparison of the historical sets of data for
these two wells suggested that the data for MW-2 more closely correlated with the
historical data for MW-21, and the data for MW-21 more closely correlated with the
historical data for MW-2. It was stated that this quarter's data would provide additional
information to clarify the BETX concentrations in these wells. The data from this quarter
are consistent with last quarter's data and support that the data presented in the first
quarter for these wells was reported correctly and were not switched.
3.1.2 Off-site Groundwater Quality Data
The five off-site monitoring wells selected to evaluate the effectiveness of remediation
include MW-30, MW-31, MW-32, MW-33, and MW-34. Based on the current groundwater
quality data, no BETX or MTBE was detected in the off-site wells over the quantitation
limit of 0.5 µg/L. This is the fourth quarter in which BETX/MTBE has not been detected
over the groundwater standards in the remediation area to the south of the terminal.
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Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
3.2 VARIANCE AREA GROUNDWATER QUALITY DATA
The wells which were evaluated for the variance area for this quarter are MW-1, MW-11
MW-22, MW-23, MW-24, MW-38 and MW-39. This quarter does not correspond to a
semi-annual sampling event for the variance area; however, due to the free product
detected in MW-23 on February 26, 1996, NCDEHNR indicated that the variance request
would not be presented for final approval unless it could be demonstrated that the product
did not originate from the CITGO terminal. As part of this demonstration, two additional
monitoring wells were installed (MW-38 and MW-39) to the north and south of MW-1 as
shown on Figure 1. Each of the seven listed monitoring wells were sampled for BETX
by EPA method 602. Groundwater samples from MW-1, MW-22, MW-23, MW-24, MW-
38 and MW-39 were also analyzed for PAHs by solid waste method SW-846 #8270. As
mentioned, a groundwater sample was collected from MW-23 on April 14, 1996 after
disappearance of product from the well. The results of the analytical testing are included
on Table 3. Analytical reports and chain of custody forms are attached in the appendix.
The results of the analytical testing indicate exceedances of the groundwater standard
for ethylbenzene and xylenes in MW-11, MW-21, MW-22, MW-23, MW-38 and MW-39.
MW-11 also indicated an exceedance for benzene by 0.65 µg/L. With the exception of
MW-23, the variance area monitoring wells have resulted in consistent concentrations of
dissolved BETX since the first known sampling of the wells in September 1991. The
increase in MW-23 corresponds with the isolated free product occurrence on February
26, 1996. However, the data from monitoring wells MW-1, MW-38 and MW-39 do not
support off-site migration of free phase product to the variance area or monitoring well
MW-23. The individual BETX/PAH constituents in MW-38 are lower than reported in MW-
23. The individual BETX/PAH constituents in MW-39 compare more closely to that
reported in MW-23 with slightly higher toluene concentrations and lower ethylbenzene
7
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Second Quarter Monitoring Report
CITGO Asphalt Tenninal
S&ME Projects 1264-93-309/1264-95-243
July 1996
concentrations. The data from MW-1 does not correlate due to influence from a near-by
sparge well. No free product was detected in the variance area monitoring wells. The
data from MW-11 (on-site near-the rail car loading rack) consistently has yielded
dissolved BETX concentrations lower than in MW-22 (off-site along the west side of River
Road) indicating the rail car loading area is probably not a significant source of dissolved
petroleum hydrocarbons to the variance area.
4.0 SUMMARY OF FINDINGS
The free product discovered in monitoring well MW-23 appears to be an isolated event.
The only date in which free product was detected in the well was February 26 , 1996. The
only current evidence of the free product appears to be elevated dissolved hydrocarbon
concentrations compared to the historical groundwater quality data from that well. The
additional assessment completed up-gradient of MW-23 does not support off-site
migration of product from the CITGO Property. The dissolved hydrocarbon
concentrations in on-site monitoring wells MW-1 and MW-38 are lower than that detected
in off-site monitoring well MW-23. The dissolved hydrocarbon concentrations in on-site
monitoring well MW-39 are approximately the same as those detected in MW-23. The
hydrocarbon concentrations in on-site monitoring well MW-11 are lower than that detected
in off-site monitoring well MW-22 indicating the rail car loading area is not a significant ·
t:;:: , contributor of dissolved hydrocarbons to the variance area. The current dissolved
hydrocarbon concentrations in MW-23 are on the same order of magnitude as those in
MW-22.
The trend in dissolved hydrocarbons concentrations tends to increase off-site (down
gradient of the terminal). This is true for on-site monitoring wells MW-38, MW-1, and
MW-11 which have lower dissolved hydrocarbons concentrations than the off-site (down
8
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Second Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
July 1996
gradient) monitoring wells MW-22 and MW-23. The exception is on-site monitoring well
MW-39 which has approximately the same dissolved hydrocarbon concentration as MW-
22 and MW-23. Given the current available data, withdrawal of the variance area request
does not appear appropriate.
Based on the collective monitoring data to date, S&ME recommends continuing air
sparging within the on-site remediation area. The air flow rate to the sparge wells in the
vicinity of MW-21 will be increased to approximately 5 cfm per well. Four consecutive
quarters of data from the American Crane property have yielded purgeable aromatic
hydrocarbon concentrations below their respective 15A NCAC 2L groundwater standards.
r; S&ME recommends terminating air sparging on the American Crane property and to
1
l _ continue monitoring for four more quarters. If four quarters of data without active
f': remediation continue to result in concentrations below the groundwater standards, S&ME
L~ will recommend no further action for the off-site portion of the plume on the American
1-: Crane property.
1...c
1",: 5.0 OPERATION AND MAINTENANCE
During the quarter low air flow was observed through the manifold system even though
the compressor was operating properly. The three stage air filtration system was
:::::: di sass em bled and observed. It appeared that the first stage particulate filter was
clogging. The second stage coalescing and third stage carbon filter appeared in good
condition. The first stage filter element was changed. In addition, the compressor air
filter was changed.
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26, 1996 well sampling results. The laboratory analysis conducted on the
sample from the monitoring well MW-23 is reported as 'free product'. The
laboratory's cover letter to the analysis states that 'In summary, the product
found in MW-23 is not similar to fresh gasoline, but was similar to or
contained weathered gasoline'. The other two monitoring wells located in the
area for which the variance is requested also showed an increase in several
constituent concentrations between the February 26th and earlier analytical
data.
In light of the most recent February 26, 1996 analytical data, a copy of
which is attached, it would be difficult for me to support the requested
variance and thereby denial is recommended.
Please contact me if you have any questions concerning the report.
Page 3
Amoco Oil Company
INTRODUCTION
In 1951 Amoco Oil Company (Amoco) constructed an asphalt blending,
storage, and sales facility. Amoco operated the facility until April 30, 1993,
at which time it was acquired by CITGO Petroleum Corporation (CITGO). The
CITGO terminal facility is located on River Road in Wilmington. The terminal
consists of approximately 31 acres of land and is about 900 feet east of the
Cape Fear River (see diagram attached). As a result of day-to-day terminal
operations occasional spills and leaks have occurred throughout the years and
have caused contamination of the subsurface soils and groundwater. Amoco has
accepted responsibility for delineating, evaluating, and implementing
appropriate remedial measures for the off-site portion of the dissolved
hydrocarbon plume that originated from what is now the CITGO Products
Terminal.
Initial test borings and monitoring wells were installed in 1988. The
Division sent a March 1989 Notice of Violation for the exceedance of
groundwater quality standards in three of the twelve monitorfng wells pursuant
to 15A NCAC 2L. Nine additional monitoring wells were installed in 1990. In
August of 1991 three monitoring wells were installed along the western edge of
the River Road right-of-way (held by NC DOT, see diagram attached). The
intent of the monitoring was to determine if the groundwater plume had
migrated beneath River Road onto the adjacent Koch Refining Company (Koch)
terminal property.
In 1992 the DEM, Wilmington Regional Office requested that additional
delineation of the plume be made. In response, seven permanent monitoring
wells were installed on the property owned by Koch Refining Company (Koch) and
12 temporary wells were installed on property owned by the American Crane
Corporation which is south of the CITGO and Koch terminals.
An approved Corrective Action Plan (CAP) is currently being implemented at the
CITGO terminal. Air sparging wells have been installed on site and down
gradient on the adjacent American crane Corporation property.
A variance from lSA NCAC 2L .0202 (groundwater quality standards) and
15A NCAC 2L .0106(j) (corrective action) is requested by Amoco for the
approximate two acre area located on and across River Road, on properties
owned by the Citgo Products Terminal, The American Crane Corporation, CSX
Transportation, and Koch Refining Company. The land in which the area of the
variance encompasses the most offsite property is owned by Koch. Amoco has
made this variance request by filing an application in accordance with part(c)
of 15A NCAC 2L .0113.
Pursuant to 15A NCAC 2L .0113 (d) and (e), public notice of this
variance request was sent to adjacent property owners, the New Hanover County
Health Director, the City Manager for the City of Wilmington, and the Mayor of
Wilmington. Notice of this hearing was also published in the July 2, 1995
Page 4
Amoco Oil Company
edition of the Wilmington star-News to meet requirements of 15A NCAC 2L
.0113(e)(l)(A). In addition, approximately 500 notices of this variance
request were sent to persons listed in the 'Groundwater Variance and
Regulatory Actions Mailing List' to meet the requirements of 15A NCAC 2L
.0113(e)(l)(F). Prior to the public Hearing a press release was sent to all
newspaper companies, television stations, and radio stations that serve New
Hanover County.
A public hearing was held on August 3, 1995 at 7:00 at the Cape Fear
Community College, 411 North Front Street, Wilmington by the Department of
Environment, Health and Natural Resources on behalf of the Environmental
Management Commission to receive public comment in response to notice of the
variance request. A total of twelve registered persons attended the hearing,
with two people presenting oral comments. Written comments were submitted by
one of the speakers. No oth~r written comments were received. The hearing
record allowed for written comments to be submitted through September 4, 1995.
Mr. Bruce Reed of the Wilmington Regional Office, DEM initially presented an
overview of the variance request.
SUMMARY OF COMMENTS AND RESPONSES
Written/verbal comments and there respective responses are shown as follows:
comment #1:
One commenter objected to the proposed variance that allows Amoco Oil
Company to leave contamination at this site without performing the corrective
actions necessary to clean-up this area to the state standards. The commenter
stated that Amoco did not promptly cleanup oil and asphaltic product releases
that occurred from decades ago and should not be allowed to walk away from
cleanup responsibilities just because it's going to cost them a substantial
amount of money. He said that Amoco was well aware of it's operations, the
geologic environment and presence of groundwater beneath the terminal, and the
potential impacts of leaks from degrading steel containers. Corporations that
knowingly release harmful substance into the environment have an obligation to
clean-up the environment.
The person commenting is deeply concerned about the effect of petroleum
product pollution on wetlands, drinking water, surface waters, wildlife, and
humans. Skepticism was expressed about the claims that asphaltic substances
and petroleum products found at this site will degrade naturally over time.
Studies of the impacts from petroleum releases have shown that long-term
effects of oil spills are devastating to the environment. In this person's
view the persistence of certain chemical components of petroleum releases is
sufficiently long to cause chronic human health and ecologic problems, and the
mobility of contaminants can expose a vast population to chronic health
effects.
Page 5
Amoco Oil Company
Response to comment #1:
The granting of a variance does not exempt Amoco Oil Company from the
continued responsibility for the site. If a variance is granted at this site,
Amoco must maintain a groundwater monitoring effort as required by the
conditions of a variance and Division directives. Monitoring must continue
for a sufficient period of time to assure that remaining concentrations within
the area of the variance do not increase. If it appears concentrations are
increasing due to the past actions of Amoco, the company may still be held
responsible for cleanup by the Division. If other property owners in the area
release substances into groundwaters, soil, or land surface within the area
that the variance was granted, then the appropriate responsible parties will
be subject to the cleanup requirements of lSA NCAC 2L.
Active remediation is underway on portions of the contaminant plume that ,
have higher pollutant concentrations. Whether Amoco 'knowingly' released
harmful substances into the environment is unknown.
Depending upon constituent concentrations, petroleum products in the
surface waters and groundwaters do have varying degrees of effect on the
environment. The Company has submitted a risk assessment including the
methodologies used to estimate the impacts the variance will have on human
health, the environment, and public welfare. The purpose of the site specific
risk assessment is to evaluate the potential adverse impacts associated with
the concentrations in and around the area of the requested variance. The
concerns of the commenter are noted and additional information was requested
from Amoco with respect to the risk assessment.
Site conditions vary significantly from one site to the next. Hydro-
geologic, chemical/physical pollutant, and physical characteristics all
contribute to the complexity of a site. The risk assessment evaluates these
characteristics and estimates the degree of risk the site poses to human
health and the environment. A risk assessment includes the identification of
exposure scenarios, pathways, and human and ecological receptors. Some common
groundwater exposure scenarios and pathways are ingestion, non-ingestion
contact such as irrigation or swimming, inhalation, and transport to surface
water.
The risk assessment conducted in support of the variance request looks
solely at the effects from the plume originating from the Amoco site. The
plume originating on the Koch property is located between the Amoco plume and
the river. The risk assessment evaluates impacts to several receptors
including the river. It does not include the impact from the Koch Plume.
As hearing officer I felt the need to ask for additional written
information with respect to the risk assessment as it was done. In the Amoco
response it was stated that there are several reasons for not attempting to
evaluate the Koch plume. The Amoco Oil Company does not have responsibility
for, nor control over the releases of petroleum unrelated to its former
operations at the asphalt terminal. They do not have the data that would be
necessary for a qualitative evaluation of risk. Therefore, they do not feel
that it is appropriate for Amoco to attempt to evaluate the risks that may be
posed by releases at the Koch facility.
Page 6
Amoco Oil Company
An additional question is the possible re-contamination of the variance
area by the Koch plume. Amoco states that MW-32, where free-phase hydrocarbon
from Koch was obser~ed, is located more than 100 feet down gradient from the
area of the variance request. They further believe the potential is small for
the Koch plume to affect the area covered by the variance request.
The risk assessment conducted for the Amoco plume showed that the
observed concentrations of hydrocarbons impacting the area of the variance
request do not constitute a significant risk to the human or environmental
receptors.
Comment #2:
The monitoring well data presented at the hearing is not sufficient to
demonstrate that contaminant levels are being reduced by natural remedial
processes. Not enough monitoring information exists to confirm that this
phenomenon is occurring.
Response to comment #2:
Monitoring data results for the three monitoring wells (MW-22, MW-23,
and MW-24) located on the Koch property have previously been submitted for
9/04/91, 6/15/93, 6/16/93, 2/16/94, and 8/24/95. That data by itself does not
show a trend of rising/decreasing concentrations. However, the analytical
results from sampling conducted on February 26, 1996 show 'free product' in
MW-23 and an increase in several constituent concentrations in MW-22 and MW-
24. The concentration of xylene in MW-22 shows an increase and is in excess of
the groundwater standard in 15A NCAC 2L.0202.
Comment #3:
If new technology is developed after a variance is granted is there a
means to rescind a variance?
Response to comment #3
It would not be necessary to 'rescind' a variance. The approval of a
variance could be made conditioned such that if the BTEX or other constituents
increased at significant concentrations, then Amoco would have to amend a
corrective action plan to include active remediation in the area of the
variance. In addition, if groundwater monitoring reveals rising concentrations
of any constituent, or monitoring reveals new substances, the Wilmington
Regional Office can issue a 'Notice of Violation' which would require that
corrective actions be implemented.
Comment #4:
Part of the land included in this variance request encompasses property
owned by the American Crane Corporation.
(A)How would the granting of a variance affect American Crane
Page 7
Amoco Oil Company
Corporation's property rights?
(B)How would lenders react to a variance?
(C)How would having a variance on part of our property effect permits
that may be granted by the state and county?
Response to comment #4
The questions are responded to as follows:
(A) As per 15A NCAC 2D.0113(i): a variance shall not operate as a
defense to an action of law based upon a public or private nuisance theory or
any other cause of action.
(B) DEM regulations do not contain any authority to require lending
institutions to respond in a specified manner to variance situations. The
lending institutions may react as they see fit and in accordance with any
other laws or regulations that govern them.
(C) A review by the DEM groundwater staff of the permitting regulations
as they pertain to: Chapter 143, Article 21A, Part 2A and 15A NCAC 2N
(underground storage tanks) does not show any references to 'variances'. 15A
NCAC -2L (Classifications and water quality standards applicable to
groundwaters of NC) do not restrict sites from getting a permit that have
received a variance from the Commission. Well construction rules in 15A NCAC
2C .0100 and .0200 do not contain any additional construction requirements or
location requirements at a site where some of the property has been granted a
variance.
Comment #5:
Since Amoco proposes to rely on the natural process within the earth's
subsurface to reduce contaminant levels, have they proposed a time limit on
this variance?
Response to comment #5
The Company has not proposed a time limit on this variance. The process
of natural attenuation is highly dependent on subterranean features and it is
very difficult to project a time frame in which the process will complete
itself. As stated in response to comment #3, if the sampling results portray a
trend of increasing concentrations then active remediation could be required
as per a condition of a variance approval.
Page B
Amoco Oil Company
DISCUSSION
1. An adjacent water supply well owned by Atlantic Marine, Inc. is
located approximately 700 feet northwest of the variance request area
and they have submitted information showing that it is not being used
for consumption. Atlantic Diving and Marine Contractors, Inc. have a
contract with a company that provides bottled water.
Five other water supply wells are located within a½ mile radius
of the variance request area. For these five locations well water use
is presently limited to supply process water or other uses not
_associ~ted with drinking water consumption, and each is reported to be
connected to the Wilmington municipal water supply.
2. In establishing that the requirements of the corrective
action/groundwater quality standards cannot be achieved by providing the
best available technology economically reasonable, the variance request
document states that there is free product down gradient (adjacent to
the Koch terminal). Further, that long term restoration is not possible
since re-contamination could occur from the Koch terminal plume. The
Wilmington Regional Office should maintain vigilante efforts to
encourage the responsible party to complete the site assessment and
corrective action plan for the plume originating on the adjacent Koch
site.
3. It was initially the impression of this hearing officer that the
present remediation system (air-sparging)is located only to the south of
the Amoco property, on the American Crane Corporation property. I have
been informed by additional correspondence from Amoco that an air
biosparging system is being operated on the west side of the Citgo
terminal, up gradient of the variance request area. These sparging
wells were placed on-line in May 1995.
4. The nature of this variance request warranted the request for
additional information from Amoco Oil Company. The additional
information was requested by letter December 15, 1995 and was received
on January 31, 1996. On March 6, 1996 Bruce Reed of the Wilmington
Regional Office Groundwater staff telephoned to inform me that he
received a call from a representative of Amoco Oil Company. They let
him know that they recently had½ to 1 inch of free petroleum product in
one of the monitoring wells (MW-23) located in the variance request
area. on March 28, 1996 I received a copy of the February 26, 1996 well
sampling results. The laboratory analysis conducted on the sample from
the monitoring well MW-23 is reported as 'free product'. The
laboratory's cover letter to the analysis states that 'In summary, the
product found in MW-23 is not similar to fresh gasoline, but was similar
to or contained weathered gasoline'. The other two monitoring wells
located in the area for which the variance is requested also showed an
Page 9
Amoco Oil Company
increase in several constituent concentrations between the February 26th
and earlier analytical data. In light of the most recent February 26,
1996 analytical data, a copy of which is attached, it would be difficult
for me to support the requested variance and thereby denial is
recommended.
RECOMMENDATION
In taking into account public comment, a review of the documentation
submitted for the request for variance, subsequent discussions with staff, and
primarily on the analytical monitoring data it is recommended that the
variance be denied.
April 24, 1996
Mr. Kenneth Schuster, P.E.,
Regional Supervisor
North_Carolina Department ofEnvironment,
Health, and Natural Resources
Division of Environmental Management
Raleigh Regional Office
3800 Barrett Drive, Suite 101,
Raleigh, North Carolina 27609
Response to DEM letter dated April 18, 1996
Amoco Corporation
Environment, Health and Safety
375 Northridge Road , Suite 600
Atlanta, Georgia 30350-3323
Remediation Services
404-512-6863
Facsimile : 404-512-6866
Request for Variance from 15A NCA 2L .0202 and 2L .0106(j)
Amoco Corporation at the Citgo Products Terminal
Wilmington, New Hanover Co., North Carolina
Dear Mr. Schuster,
Amoco Corporation (Amoco) has received your letter dated April 18, 1996, regarding recent site
developments at the Citgo Products Terminal (formerly Amoco). Amoco would like to .clarify
some issues, as well as reaffirm our intentions.
As stated in S&ME's First Quarter Monitoring Report January 1 -March 31, 1996,
approximately 0.13 feet (1.5 in.) of separate-phase hydrocarbons (SPH) was discovered in MW-
23 on February 26, 1996. You stated in your letter that you wanted to know if Amoco was still
interested in pursuing a Request for Variance, based on the appearance of SPH. Amoco
understands how the reporting of SPH in a monitor well located in this area might change our
position regarding the Request for Variance. However, other than the fact that Amoco used to
store gasoline in an aboveground storage tank (AST) at the facility, there is little evidence at this
time to show the SPH originated from the former Amoco terminal For example:
• Monitor well MW-1, which is located directly upgradient of MW-23 has never contained
SPH.
• The hydraulic gradient (0.014 to 0.012) and groundwater flow direction (southwest) have
remained relatively constant prior to and during on-site air-sparging operations.
• The diked area which contains the ASTs is located approximately 380 feet due east of MW-
23. Since groundwater flow has historically been to the southwest, MW-23 is not located
directly downgradient of the diked area. In addition, as shown on the attached site map, there
are two monitor wells within the diked area and several other monitor wells adjacent to the
diked area ... SPHs have never been detected on the groundwater in any of these monitor wells
..
Mr. Kenneth Schuster, P.E.
Page 2 of2
4/24/96
• Underground pipelines which were used to transport the gasoline from the loading dock to the
ASTs, are located approximately 240 feet south ofMW-23 and trend parallel to the southern
property boundary of the former Amoco terminal. Again, MW-23 is not located
down.gradient of this potential source.
• Gasoline SPH has never been discovered on the groundwater in any of the 26 monitor wells
located on the former Amoco property.
·• Subsequent site visits since February 26, 1996 have not detected SPH in MW-23:
Based on this information, Amoco wishes to continue to pursue the variance. Amoco will continue to
work closely with the Wilmington Regional Office in an attempt to satisfy concerns related to the
origin of the SPH Amoco understands your office will present the Request for Variance to the
Environmental Groundwater Committee on May 8, 1996, so that it may go to the full Commission in
July 1996. We respectfully request that Amoco be allowed to submit any :further assessment data,
which may be generated in the mean time, to your office and the EMC for review, prior to the meeting
on July 11, 1996. Further assessment of the area may very well show the SPH did not originate from
the former Amoco terminal and Amoco would appreciate the EMC' s review of all available data prior
to issuing a final decision.
Amoco Corporation appreciates your attention to this matter. If you have any questions or
comments, please call my office at [phone].
Respectfully,
Project Remediation Coordinator
Amoco Corporation
Attachment: Groundwater Surface Map
cc: Tom Farrior -Citgo
David Klemm -S&ME
Bruce Reed -NCDEM Wilmington Regional Office
Tom Segar -Koch Industries, Inc.,
..
PROCEEDINGS OF HEARING FOR THE CITGO PRODUCTS TERMINAL
VARIANCE
INTRODUCTION:
A public hearing was held by the Department of Environment,
Health and Natural Resources on behalf of the Environmental
Management Commission to receive public comment on a request for a
variance from the Groundwater Quality Standards of 15A NCAC 2L
.0202 and the Corrective Action requirements of 15A NCAC 2L .0106
(j) for the Citgo Products Terminal in Wilmington, North Carolina.
The variance application was received for review by the Department
on August 25, 1994 from the Amoco Oil Company, 375 Northridge Road,
Suite 350, Atlanta, Georgia, 30350-3296. Prior to April 30, 1993
the Amoco Oil Company was the owner of the tank terminal for which
the variance is requested and is responsible for cleanup of this
release.
The hearing was held on August 3, 1995 at 7:00 PM at the Cape
Fear Community College, 411 North Front Street, Wilmington, North
Carolina. A total of twelve (12) registered persons attended the
hearing, with two people presenting oral comments. One individual
provided comments in writing at the hearing. No additional written
comment was received by the Division by September 4, 1995 which was
the final date to submit comment as specified in the public notice.
Pursuant to 15A NCAC 2L .0113(d) and (e), public notice of
this variance was sent to adjacent property owners, the New Hanover
County Health Director, the City Manager for the City of
Wilmington, and the Mayor of Wilmington on July 2, 1995. Notice of
this hearing was also published in the July 2, 1995 edition of the
Wilming ton Star-News to meet requirements of 15A NCAC 2L
. 0113 (e) (1) (A) . In addition, approximately 500 notices of this
variance request were sent to persons listed in the "Groundwater
Variance and Regulatory Actions Mailing List" to meet the
requirements of 15A NCAC 2L .0113(e) (1) (F). Prior to the public
hearing a press release was sent to all newspaper companies,
television stations, and radio stations that serve New Hanover
County.
1
..
This hearing was chaired by Mr. Ken Schuster, the Regional
Supervisor for the Raleigh Regional Office. It was noted that a
television crew from WECT-TV Channel 6 made a videotape of the
public hearing for the nightly news on August 3, 1995.
Attendees
Citgo Products Terminal Variance Hearing
August 3, 1995
Mr. Steve Becker, Operations Manager, American Crane
Corporation, 202 Raleigh Street, Wilmington, NC 28412
Mr. Howard Greenebaum, 841 Settlers Lane, Kure Beach, NC 28449
Mr. Scott
Technologies,
27513
Keating, Operations Manager, Remediation
Inc., 127 Kingston Drive, Chapel Hill, NC
Mr. Michael E. Mason, Project Engineer,
Associates, P.O. Box 10279, Wilmington, NC
Rick Catlin and
28405-3755
Mr. Michael E. McCarty, Vice-President, Atlantic Diving and
Marine Inc., 3330 River Road, Wilmington, NC 28412
Mr. Allen Neal, Terminal Manager, Citgo Products Terminal,
3345 River Road, Wilmington, NC 28412
Ms. Teri
Associates,
Piver, Project Manager, Richard Catlin
P.O. Box 10279, Wilmington, NC 28405
Mr. Jim Shaeffer, Remediation
Corporation, 375 Northridge Road,
30350
Ms. Brigid Sherman, Environmental
Company, P.O. Box 181, Savannah, GA
Coordinator, Amoco
Suite 600, Atlanta,
Coordinator,
31402
Citgo
and
Oil
GA
Oil
Mr. Kevin Walker, Atlantic Diving and Marine Inc., 3330 River
Road, Wilmington, NC 28412
Ms. Deborah Walker, Atlantic Diving and Marine Inc., 3330
River Road, Wilmington, NC 28412
Mr. Mark Westray,
Technologies, Inc.,
27513
Senior Project Manager, Remediation
127 Kingston Drive, Chapel Hill, NC
2
,,
,
ft
Howard Greenebaum
841 Settlers Lane
Kure Beach, NC 28449
August 3,1995
David Hance
Division of Environmental Management
Groundwater Section
PO BOX 29535
Raleigh, NC 27626-0535
Dear Mr. Hance,
Telephone [phone]
FAX [phone]
I wish to register my objection to AMOCO OIL CO.'S r~quest to not pay
for the clean up of contamination left at their vacated facility on
River Road in Wilmington, North Carolina.
In 1951 when they built their asphalt products terminal on River Road
they possessed the knowledge that steel rusts. This is not a recent
discovery. Consequently they were aware that any steel container would
eventually lea-k--its: contents into the environment. They also possessed
the knowledge in 195!' that drinking water resided under the ground and
that wells were connected to that drinking water, and that any liquid
leaking from rusted containers would seep downward into that
groundwater. Since oil companies employ geologists they are also aware
that groundwater aquifers flow, that contaminated water does not sit
still and surrounding areas are at risk.
Their choice of not removing sources of future contamination were
deliberate, and based on the hope of non discovery of their actions.
AMOCO OIL COMPANY is one of the richest companies in the world and
certainly had then and has today the resources to clean up after their
spills of dangerous materials.
At the school where my wife works is a teacher who lives in a house
that is the victim of another oil spill by another oil company. She
lives in Wrighsboro which is near Wilmington. Her family and her
neighbors have been exposed to contamination to their drinking water
from a spill from a leaking container of .an oil product for many
years. They now are unable to drink water from their well, and their
house is unsaleable. Their health is an unknown quantity due to
exposure from this spill. This oil company has admitted its fault but
also has not as yet compensated the victims of its negligence.
North Carolina spends less on environmental regulation than all but 3
other states in the country. These lengthy spills have been undetected
because our elected officials have been collecting campaign
contributions from these polluting corporations' lobbyists, and as a
consequence, have not passed tough regulations on their contributors,
or voted for adequate funding for the existing regulatory agencies to
enforce the existing laws.
... -' .
North Carolina has suffered the losses of numerous shellfish areas to
closures because of contamination. Oil spill contamination can close
shellfish areas for years not months. We are looking at long term
damages to our environment if we do not force prompt clean ups, and
detect pollution sources earlier.
AMOCO'S contention that this contamination would eventually be reduced
naturally goes into conflict with all of today's knowledge. As we all
know oil is a product of a multi million year process. It just doesn't
go away. Several international studies have shown that long term
effects of oil spills can be devastating. One such study was made on
the Brittany coastline in the years after the AMOCO Cadiz spill !
Several species were altogether eliminated, and the animal numbers
were severely reduced.
Portions of an oil spill can spread over vast areas. Toxic components
may create chronic damage to life. The ecological damage is not
restricted to the sea. It does spread to the inhabitants on land.
The Cape Fear river is the source of drinking water for Wilmington. we
certainly do not want to see it any more polluted than it already is.
The shores of the river contain marshes and wetlands that are the
sources of 1"ife · f o·r the ·fish,: birds, and animals that we North
Carolinians love. We certainly do not want to see their drinking water
poisoned. Remember, their water does not go through the Wilmington
water facility. They have to drink it untreated. They are at grave
risk from pollution, and the lack of clean ups.
Asphaltlike material was discovered in California at the La Brea Tar
Pit by Spanish explorers in 1769 ! We do not know how long it had been
there before discovery. Asphalt has been used as a roofing material
since 1892. It is not a material that we can expect to just peacefully
disappear from ,nature without any damage.
I urge the DEM to force AMOCO to clean up its waste at once.
I also recommend that the DEM advise the public of the real conditions
of our waters, and to present to the public their recommendations for
improvements to their agency so that they can better protect our
environment. Let us know how much better protection will cost us, and
how much limited protection is costing us today. It is time we stopped
treating clean water and clean air as luxuries that we can afford to
neglect.
EHHF' i.J I U-1 ;;;EG OFF I CE TO :3'3197150588 P.02
J
•1>-: -2:::!-1'336 11: le: FROM EHHF: l;.I I L.M Fs:EG OFF I CE TO :3'31 '37150588 F'.03
( :
~?2-23-i996 :i?: [JS FRIJM
0 '-'-~'-. JHU ~Ct'Jaetti:> ... •
,'\rt ;i :z::;. l 99ti
EHNR WILM REG OFFICE TO GROUNDWATER RRC P.D2
· of :tv1'V-l and
,_·0ntunm?.tion, and
· -,'trnn
April 24, 1996
Mr. Kenneth Schuster, P.E.,
Regional Supervisor
North Carolina Department of Environment,
Health, and Natural Resources
Division of Environmental Management
Raleigh Regional Office
3800 Barrett Drive, Suite 101,
Raleigh, North Carolina 27609
Response to DEM letter dated April 18, 1996
Amoco Corporation
Environment, Health and Safety
375 Northridge Road, Suite 600
Atlanta, Georgia 30350-3323
Remediation Services
404-512-6863
Facsimile: 404-512-6866
Request for Variance from 15A NCA 2L .0202 and 2L .01060)
Amoco Corporation at the Citgo Products Terminal
Wilmington, New Hanover Co., North Carolina
Dear Mr. Schuster,
Amoco Corporation {Amoco) has received your letter dated April 18, 1996, regarding recent site
developments at the Citgo Products Terminal (formerly Amoco). Amoco would like to ,clarify
some issues, as well as reaffirm our intentions.
As stated in S&ME's First Quarter Monitoring Report January 1 -March 31, 1996,
approximately 0.13 feet (1.5 in.) of separate-phase hydrocarbons (SPH) was discovered in MW-
23 on February 26, 1996. You stated in your letter that you wanted to know if Amoco was still
interested in pursuing a Request for Variance, based on the appearance of SPH. Amoco
understands how the reporting of SPH in a monitor well located in this area might change our
position regarding the Request for Variance. However, other than the fact that Amoco used to
store gasoline in an aboveground storage tank {AST) at the facility, there is little evidence at this
time to show the SPH originated from the former Amoco terminal. For example:
• Monitor well MW-1, which is located directly upgradient of MW-23 has never contained
SPH.
• The hydraulic gradient ( 0.014 to 0.012) and groundwater flow direction (southwest) have
remained relatively constant prior to and during on-site air-sparging operations.
• The diked area which contains the ASTs is located approximately 380 feet due east ofMW-
23. Since groundwater flow has historically been to the southwest, MW-23 is not located
directly downgradient of the diked area. In addition, as shown on the attached site map, there
are two monitor wells within the diked area and several other monitor wells adjacent to the
diked area. SPHs have never been detected on the groundwater in any of these monitor wells
Mr. Kenneth Schuster, P.E.
Page 2 of2
4/24/96
• Underground pipelines which were used to transport the gasoline from the loading dock to the
ASTs, are located approximately 240 feet south ofMW-23 and trend parallel to the southern
property boundary of the former Amoco terminal. Again, MW-23 is not located
down.gradient of this potential source.
• Gasoline SPH has never been discovered on the groundwater in any of the 26 monitor wells
located on the former Amoco property.
• Subsequent site visits since February 26, 1996 have not detected SPH in MW-23.
Based on this information, Amoco wishes to continue to pursue the variance. Amoco will continue to
work closely with the Wilmington Regional Office in an attempt to satisfy concerns related to the
origin of the SPH Amoco understands your office will present the Request for Variance to the
Environmental Groundwater Committee on May 8, 1996, so that it may go to the full Commission in
July 1996. We respectfully request that Amoco be allowed to submit any further assessment data,
which may be generated in the mean time, to your office and the EMC for review, prior to the meeting
on July 11, 1996. Further assessment of the area may very well show the SPH did not originate from
the former Amoco terminal and Amoco would appreciate the EMC's review of all available data prior
to issuing a final decision.
Amoco Corporation appreciates your attention to this matter. If you have any questions or
comments, please call my office at [phone].
Respectfully,
Project Remediation Coordinator
Amoco Corporation
Attachment: Groundwater Surface Map
cc: Tom Farrior -Citgo
David Klemm -S&ME
Bruce Reed -NCDEM Wilmington Regional Office
Tom Segar -Koch Industries, Inc.,
1
FIRST QUARTER MONITORING
REPORT
JANUARY 1 -
MARCH 31, 1996
CITGO ASPHALT TERMINAL
(FORMERLY AMOCO CORPORATION)
WILMINGTON, NORTH CAROLINA
S&ME PROJECTS
1264-93-309/1264-95-243
Prepared for:
CITGO PETROLEUM CORPORATION
SAVANNAH, GEORGIA
&
AMOCO CORPORATION
ATLANTA, GEORGIA
Prepared by:
S&ME, Inc.
Spartanburg, South Carolina
April 1996
Jil rn@mnwm ffi1 t
ml APR O 8 1996 IJlJ
-------···--····--·------··
. '"'•.::
Cr,
·•@don
~Paper
April 3, 1996
North Carolina Department of Environment,
Health and Natural Resources
127 Cardinal Drive Extension .
Wilmington, North Carolina 28405-3845
ATTENTION:
Reference:
Dear Mr. Reed:
Mr. Bruce A. Reed
FIRST QUARTER MONITORING REPORT
JANUARY 1 -MARCH 31, 1996
CITGO Asphalt Terminal
(Formerly Amoco Corporation)
Wilmington, North Carolina
S&ME, Inc. Projects 1264-93-309/1264-95-243
ffi) U1@ Il8\19II fin
j APR O R 1996 l1!J
-----·-·--···--·---------··
Enclosed is the First Quarter Monitoring Report (January 1 -March 31, 1996) for the
CITGO Asphalt Terminal (formerly Amoco Corporation) in Wilmington, North. Carolina.
This report includes details of the monitoring performed for both the on-site and off-site
remediation areas and presents the results of groundwater elevation gauging and
groundwater quality sampling. Also included are the results of the variance area
monitoring performed for monitoring wells MW-22, MW-23, and MW-24 along the west
side of River Road.
If you have any questions or comments, please feel free to contact us at [phone] .
Sincerely,
S&ME, Inc.
D✓& /£---
David E. Klemm, P.G.
Project Manager
Sta n rd Lummus, P.E.
Senior Environmental Engineer
cc: Tom Farrior -CITGO Petroleum Corporation, Savannah, Georgia
.Jim ~chaeffer, Amoco Corooration -Atlanta, Georqia
S&Mt,lnc. f55.lradd Street, Spartanburg, South Carolina 29301, [phone], Fox [phone]
Greenville, South Carolina [phone]
TABLE OF CONTENTS
PAGE
1.0 INTRODUCTION .............................................. 1
2.0 SITE MONITORING PLAN •••••••.•.•.•...••...•••••••••...•••.•. 2
2.1 GROUNDWATER ELEVATION DATA ..•.•••••..•.••.•••••.•. 2
2.2 GROUNDWATER SAMPLING .•.••.••••••••.•...•..••..•••• 3
2.3 FREE PRODUCT ....................................... 3,.
3.0 EVALUATION OF SAMPLING DATA •••••••••.•...•••••.•.•••••••.• 4
3.1 REMEDIATION AREA GROUNDWATER QUALITY .•••.•••..•••• 4
3.1.1 On-Site Groundwater Quality Data ••••••••.••.•••••.••. 4
3.1.2 Off-Site Groundwater Quality Data •••••..•.•..•••..•.•. 5
4.0 RECOMMENDATIONS •••••••.•••••.•••••••..•• · ••.•..•••..•..••. 6
5.0 COMPRESSOR SERVICE •••••..•••.•.•...•••.••••••.•••••...••• 7
FIGURES
FIGURE 1 -GROUNDWATER SURFACE MAP
TABLES
TABLE 1 -SUMMARY OF GROUNDWATER ELEVATION DATA
TABLE 2 -GROUNDWATER QUALITY DATA (REMEDIATION AREA)
TABLE 3 -GROUNDWATER QUALITY DATA (VARIANCE AREA)
APPENDIX
LABORATORY REPORTS
CHAIN-OF-CUSTODY
First Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
April 1996
1.0 INTRODUCTION
A groundwater remediation project was implemented at the site in the second quarter of
1995. The official start-up date of the system was ~-Ten monitoring wells
were selected for monitoring water quality within the remediation area. Five of the
monitoring wells are located on the CITGO terminal property (MW-1, MW-2, MW-21, MW-..
36, and MW-37). The remaining five monitoring wells {MW-30, MW-31, MW-32, MW-33,
MW-34) are located south of the terminal on the American Crane property. Baseline
monitoring of these ten wells was performed on March 29, 1995 prior to start up of the
system. The baseline monitoring indicated all five of the on-site monitoring wells had one
or more BET)( constituents over the North Carolina groundwater MCLs. Of the off-site
monitoring wells, only MW-30 indicated an exceedance of the groundwater MCL for
ethylbenzene. This exceedance was only 1 µg/L over the groundwater MCL of 29 µg/L.
Two quarterly samplings of the monitoring wells has been completed since start-up of the
system, and prior to this quarter's sampling event. Thes.e sampling events were
performed on August 24, and November 15, 1995. The results of each of these sampling
events indicated two on-site monitoring wells still contained dissolved hydrocarbons over
the groundwater MCLs. None of the off-site· wells indicated any exceedances of the
groundwater standards for either the August 24, 1995 or November 15, 1995 sampling
events. The results of th.e two sampling events were submitted in formal reports dated
September 28, 1995 and January 5, 1996.
A variance request was completed under the direction of Amoco Corporation by
Remediation Technologies Incorporated (ReTech) for the area to the west of the CITGO
terminal including River Road and west of River Road to the Koch terminal. Three
monitoring wells (MW-22, MW-23, MW-24) were selected to monitor hydrocarbon
concentrations in the variance area. These wells are sampled on a semi-annual basis.
First Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
April 1996
The results JI the last sampling event (08/24/95) indicated exceedances of the
groundwater MCLs for ethylbenzene in MW-22, and for ethylbenzene and xylenes in MW-
23. There were no groundwater MCL exceedances reported for MW-24. The results of
the August 24, 1995 variance area sampling were included in the Third Quarter
Monitoring Report dated September 28, 1995. ~
2.0 SITE MONITORING PLAN
Groundwater monitoring was performed for both the remediation area and variance area
ih the first quarter of 1996. The results and comparison of the data to previous sampling
events are discussed in the following sections.
2.1 GROUNDWATER ELEVATION DATA
One comprehensive set of groundwater level data was collected by S&ME on February
26, 1996 to determine groundwater flow direction and gradient across the site.
Groundwater levels were measured in all accessible on and off-site monitoring wells. The
groundwater levels were measured relative to each wall's top of casing {TOC). The
groundwater levels and the surveyed TOC elevations (relative to mean sea level) were
used to convert the groundwater level data to groundwater elevations.
Groundwater elevations at the site ranged from 4.45 to 27.06 feet above mean sea level.
A Groundwater Surface Map (Figure · 1) was generated by entering the groundwater
elevation data into a contouring software program {Golden Software, Surfer, 1995). The
Groundwater Surface Map indicates the Qroundwater surface slopes to the southwest with
a horizontal gradient of 0.015 feet per foot, consistent with past groundwater elevation
data. Groundwater elevation data is included in Table 1.
2
First Quarter Monitoring Report
CITGO Asphalt Terminal
2.2 GROUNDWATER SAMPLING
S&ME Projects 1264~93-309/1264-95-243
April 1996
Groundwater samples were collected from ten monitoring wells in the remediation area
(MW-1, MW-2, MW-21, MW-30 through MW-34, MW-36 and MW-37) and from three
monitoring wells in the variance area (MW-11, MW-22, and MW-24). Monitoring well MW--.
11 is not part of the sampling plan, but was sampled to compare hydrocarbon
concentrations up gradient of the variance area to concentrations within the variance
area. A groundwater sample was not collected from MW-23 due to th .e appearance of -
free product in the well (See Section 2.3}.
Each of the groundwater samples were subjected to analysis for purgeable aromatic
hydrocarbons benzene, ethyl benzene, toluene, xylenes (BETX) by EPA method 602. The
remediation area wells were also analyzed for MTBE. A summary of the groundwater
quality data is presented in Tables 2 and 3. These tables provide previous sampling data
where available and indicate the parameters which exceed the current North Carolina
groundwater quality standards (15A NCAC 2L .0202}. Laboratory reports and chain-of-
custody forms are attached in the Appendix.
2.3 FREE PRODUCT
The results of the February 26, 1996 ~roundwater elevation gauging indicated
approximately 0.13 feet (1.5 inches) of product in monitoring well MW-23. This well was
one of the wells selected to monitor water quality in the variance area and historically has
not contained free product. The historical groundwater quality data for the well indicates
the only BETX parameter which has exceeded a groundwater MCL was ethylbenzene.
The most recent ethylbenzene concentration in. the well was reported at 159 µg/L.
3
First Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
April 1996
A sample of the product was collected from the well and was sent to Savannah Labs in
Mobile, Alabama in attempt to identify the product type. The results of the analysis
indicated that the product appears to be of a weather gasoline nature. The laboratory
reports of the analysis are attached in the appendix.
3.0 EVALUATION OF SAMPLING DATA
3.1 REMEDIATION AREA GROUNDWATER QUALITY
Five on-site monitoring wells and five off-site monitoring wells are used to evaluate site
remediation. The following two sections present an evaluation of the current sampling
data. Individual plume.maps were not devefoped due to the sporadic occurrence of BET)(
data over their respective groundwater quality standards.
3.1.1 On-site Groundwater Quality Data
The five on-site monitoring wells selected to evaluate groundwater quality include MW-1,
MW-2, MW-21, MW-36 and MW-37. The reported laboratory results indicate monitoring
wells MW-21 and MW-37 have exceedances of the groundwater standards for
ethylbenzene and xylenes. MW-21 exhibited respective ethylbenzene and xylene
concentrations of 87.1 micrograms per liter (µg/L) and 809 µg/L. MW-37 exhibited
respective ethylbenzene and xylene concentrations of 307µg/L and 1490 µg/L. The
respective groundwater standards for these chemicals are 29 µg/L and 530 µg/L.
The reported concentrations indicate monitoring well MW-21 now exhibits exceedances
for both eythlbenzene and xylenes where it had not in the last two quarters of sampling
following initiation of air sparging. Also, MW-2 no longer contains ethylbenzene or xylene
4
First Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
April 1996
concentrations over the groundwater MCLs where it had in all past sampling events. A
comparison of the historical sets of data for these two wells suggests that the data for this
sampling event may have been switched. The reported data for MW-2 more closely
correlates with the historical data for MW-21, and the data for MW-21 more closely
correlates with the historical data for MW-2. If the two sets of data were switched, MW-..
21 would still be a "clean well" and MW-2 would still contain ethylbenzene and xylenes
over the groundwater MCL with a decreasing trend consistent with site remediation.
The field sampling technicians were questioned for any indication that a labeling error
may have occurred with the two samples. The technician indicated a well sampling order
consistent with times recorded on the chain-of-custody. The laboratory re-analyzed the
two samples to check for error in the laboratory. The re-runs exhibited similar results to
the o~iginal tests. Although the two sets of data would "fit" better if they were switched,
an indication of sampling or analytical error is not obvious. The next set of quarterly
sampling data should provide clarification on the BET)( concentrations in these wells.
3.1.2 Off-site Groundwater Quality Data
The five off-site monitoring wells selected to evaluate the effectiveness of remediation
include MW-30, MW-31, MW-32, MW-33, and MW-34. Based on the current groundwater
quality data, no BETX was detected in the off-site wells over the quantitation limit of 0.5
µg/L. MTBE was detected ranging from <0.5 to 2.5 µg/L. This is the third quarter in
which BETX/MTBE has not been detected over the groundwater standards.
5
First Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
April 1996
4.0 SUMMARY OF FINDINGS
Based on the collective monitoring data to date, S&ME recommends continuing air
sparging at the current flow rates both on and off-site. If one more quarter of data yields
off-site BETX concentrations below the 15A NCAC 2L groundwater standards, S&ME will ~
recommend termination of off-site corrective action based on four consecutive quarters
of data below the standards.
Two on-site wells are still indicating ethylbenzene and xylene concentrations over the
groundwater MCLs for these constituents. As mentioned above, it appears that the data
for MW-2 and MW-21 may have been inadvertently switched, although an obvious error
was not found. Next quarter's sampling event should provide verification concerning the
hydrocarbon concentrations in these two wells.
The free product discovered in monitoring well MW-23 appears to be of a weathered
gasoline nature. The apparent source of this product is ambiguous. The monitoring wells
on each side of MW-23 do not indicate the presence of free product. Monitoring well
MW-1, which lies immediately up-gradient of MW-23, does not contain free product or
dissolved BETX in · excess of the current North Carolina groundwater MCLs. Thus, it
does not appear that this product is a result of activities associated wit~ operations of
either Amoco or CITGO. Alternate potential sources of the product, including pipelines
along River Road may be considered.
At this time Amoco has proposed to gauge and hand bail MW-23 on a weekly basis. At
the next sampling event mo"nitoring well MW-23 will be sampled for BETX and MTBE.
The next sampling event is scheduled for May, 1996. The information gathered over the
next two months may provide more data to better evaluate this situation.
6
First Quarter Monitoring Report
CITGO Asphalt Terminal
S&ME Projects 1264-93-309/1264-95-243
April 1996
5.0 COMPRESSOR SERVICE
Based on recommendations of Sullair representatives, the compressor oil filter is being
changed on a quarterly basis and the air filter is being changed monthly. A full
maintenance service was performed by a representative of Sulair on January 11, 1996.•
During this service, the oil in the compressor was changed to an 8,000 hour synthetic oil
(Sullube 32). S&ME is continuing to monitor operation of the treatment system on a
weekly basis.
7
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
ililI1Blii1Blil■~-•-11ra1
MW-1 06/16/93 25.11 15.14 15.14 0.00 9.97
09/20/93 25.11 15.04 15.04 0.00 10.07 •
03/29/95 25.11 14.57 14.57 0.00 10.54
08/25/95 25.11 14.59 14.59 0.00 10.52
11/15/95 25.11 13.60 13.60 0.00 11.51
02/26/96 25.11 15.84 15.84 0.00 9.27
MW-2 06/16/93 29.84 18.40 18.40 0.00 11.44
MW-4
MW-5
MW-6
MW-8
09/20/93 29.84 18.35 18.35 0.00 11.49
03/29/95 29.84 17.83 17.83 0.00 12.01
08/25/95
11/15/95
02/26/96
06/16/93
09/20/93
03/29/95
08/25/95
11/15/95
02/26/96
06/16/93
09/20/93
03/29/95
08/25/95
11/15/95
02/26/96
06/16/93
09/20/93
03/29/95
08/25/95
11/15/95
02/26/96
06/16/93
09/20/93
03/29/95
08/25/95
11/15/95
02/26/96
29.84
29.84
29.84
29.47
29.47
29.47
29.47
29.47
29.47
32.11
32.11
32.11
32.11
32.11
32.11
37.26
37.26
37.26
37.26
37.26
37.26
37.76
37.76
37.76
37.76
37.76
37.76
19.06
18.87
19.23
15.83
16.11
15.17
15.65
15.75
17.91
15.93
15.94
15.32
15.50
15.60
17.16
17.77
17.90
17.51
17.63
17.62
19.03
18.44
18.53
17.78
18.10
18.15
19.63
Page 1 of 5
19.06 0.00 10.78
18.87 0.00 10.97
19.23 0.00 10.61
15.83 0.00 13.64
16.11 0.00 13.36
15.17 0.00 14.30
15.65 0.00 13.82
15.75 0.00 13.72
17.91 0.00 11.56
15.93 0.00 16.18
15.9.4 0.00 16.17
15.32 0.00 16.79
15.50 0.00 16.61
15.60 0.00 16.51
17.16 0.00 14.95
17.77 0.00 19.49
17.90 0.00 19.36
17.51 0.00 19.75
17.63 0.00 19.63
17.62 0.00 19.64
19.03 0.00 18.23
18.44 0.00 19.32
18.53 0.00 19.23
17.78 0.00 19.98
18.10 0 .00 19.66
18.15 0.00 19.61
19.63 0.00 18.13
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
iflll~&ll11 illl l■•1 ■t~il-:IJ!ft .
MW-9 06/16/93 32.73 17.29 17.29 0.00 15.44
09/20/93 32.73 17.37 17.37 0.00 15.36
03/29/95 32.73 16.75 16.75 0.00 15.98
08/25/95 32.73 17.14 17.14 0.00 15.59
11/15/95 32.73 18.39 18.39 0.00 14.34
02/26/96 32.73 18.46 18.46 0.00 14.27
MW-10 06/16/93 42.92 15.55 15.55 0.00 27.37
09/20/93 42.92 15.50 15.50 0.00 27.42
03/29/95 42.92 14.76 14.76 0.00 28.16
08/25/95 42.92 15.54 15.54 0.00 27.38
11/15/95 42.92 15.37 15.37 0.00 27 .55
02/26/96 42.92 15.86 15.86 0.00 27.06
MW-11 06/16/93 24.68 14.33 14.33 0.00 10.35
09/20/93 24.68 14.25 14.25 0.00 10.43
03/29/95 24.68 13.75 13.75 0.00 10.93
08/25/95 24.68 13 .91 13.91 0.00 10.77
11/15/95 24.68 13.00 13.00 0.00 11.68
02/26/96 24.68 15.62 15.62 0.00 9.06
MW-12 06/16/93 22.36 11.41 11.41 0.00 10.95
09/20/93 22.36 11.44 11.44 0.00 10.92
03/29/95 22.36 10.85 10.85 0.00 11.51
08/25/95 22.36 11.09 11.09 0.00 11.27
11/15/95 22.36 11.02 11.02 0.00 11.34
02/26/96 22.36 12.98 12.98 0.00 9.38
MW-13 06/16/93 29.85 17.25 17.25 0.00 12 .60
09/20/93 29.85 17.22 17.22 0.00 12.63
03/29/95 29.85 16.65 16.65 0.00 13.20
08/25/95 29.85 16.92 16.92 0.00 12.93
11/15/95 29.85 16.98 16.98 0.00 12.87
02/26/96 29.85 18.25 18.25 0.00 11.60
MW-14 06/16/93 28.91 15.97 15.97 0.00 12.94
09/20/93 28.91 16.04 16.04 0.00 12.87
03/29/95 28.91 15.16 15.16 0.00 13.75
08/25/95 28.91 15.61 15.61 0.00 13.30
11/15/95 28.91 15.65 15.65 0.00 13.26
02/26/96 28.91 17.91 17.91 0.00 11.00
Page 2 of 5
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
(Nf l}rl! [{ iii~,!: .i\li\:lf f ti! f iilli:, hi::• f ~l,1! 1~-,~ijx
MW-15 06/16/93 32.94 14.10 14.10 0.00 18.84
09/20/93 32.94 14.18 14.18 0 .00 18.76 ~
03/29/95 32.94 13.53 13.53 0.00 19.41
08/25/95 32.94 13.90 13.90 0 .00 19.04
11/15/95 32.94 13.76 13.76 0.00 19.18
02/26/96 32.94 15.34 15.34 0.00 17.60
MW-16 06/16/93 33.64 14.06 14.06 0.00 19.58
09/20/93 33.64 14.14 14.14 0.00 19.50
03/29/95 33.64 13 .63 13.63 0.00 20.01
08/25/95 33.64 13.92 13.92 0 .00 19.72
11/15/95 33.64 13.96 13.96 0 .00 19.68
02/26/96 33.64 15.28 15.28 0.00 18.36
MW-17D 06/16/93 24.22 13.99 13.99 0.00 10.23
09/20/93 24.22 13.90 13.90 0.00 10.32
03/29/95 24.22 13.38 13.38 0 .00 10.84
08/25/95 24.22 13.52 13.52 0 .00 10.70
11/15/95 24.22 13.32 13.32 0 .00 10.90
02/26/96 24.22 15.20 15.20 0 .00 9.02
MW-18D 06/16/93 33.50 16.88 16.88 0.00 16.62
09/20/93 33.50 16 .84 16.84 0.00 16.66
03/29/95 33.50 16.27 16.27 0 .00 17.23
08/25/95 33.50 16.60 16.60 0.00 16.90
11/15/95 33.50 16.64 16.64 0.00 16.86
02/26/96 33.50 18.13 18.13 0 .00 15.37
MW-19 06/16/93 29.88 17.17 17.17 0.00 12.71
09/20/93 29.88 17.15 17.15 0.00 12.73
03/29/95 29.88 16.52 16.52 0.00 13.36
08/25/95 29.88 16.70 16.70 0 .00 13.18
11/15/95 29.88 16.86 16.86 0 .00 13.02
02/26/96 29.88 18 .44 18.44 0 .00 11.44
MW-20D 06/16/93 25.70 1522 15.22 0 .00 10.48
09/20/93 25.70 16.62 16.62 0 .00 9.08
03/29/95 25.70 15.02 15.02 0.00 10 .68
08/25/95 25.70 15.00 15.00 0.00 10.70
11/15/95 25.70 15.01 15.01 0.00 10.69
02/26/96 25.70 16.48 16.48 0.00 9.22
Page 3 of 5
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
lill la :■1 111 ;:fJll llii1lilffili::·
MW-21 06/16/93 28.18 18.68 18.68 0.00 9.50
09/20/93 28.18 18.61 18.61 0.00 9.57
03/29/95 28.18 18.12 18.12 0.00 10.06
08/25/95 28.18 18.10 18.10 0.00 10.08
11/15/95 28.18 18.31 18.31 0.00 9.87
02/26/96 28.18 19.45 19.45 0.00 8.73
MW-22 06/16/93 20.68 11.38 11.38 0.00 9.30
09/20/93 20.68 11.28 11 .28 0 .00 9.40
03/29/95 20.68 10.86 10.86 0 .00 9.82
08/25/95 20.68 10.89 10.89 0.00 9.79
11/15/95 20.68 10.98 10.98 0.00 9.70
02/26/96 20.68 12.44 12.44 0 .00 8.24
MW-23 06/16/93 24.44 15.26 15.26 0.00 9.18
09/20/93 24.44 15.16 15.16 0.00 9.28
03/29/95 24.44 14 .75 14.75 0 .00 9.69
08/25/95 24.44 14.66 14.66 0.00 9.78
11/15/95 20.68 14.74 14.74 0.00 5.94
02/26/96 20.68 16.23 16.10 0.13 4.68
MW-24 06/16/93 26.20 17.43 17.43 0.00 8.77
09/20/93 26.20 17.33 17.33 0 .00 8.87
03/29/95 26.20 16 .88 16.88 0 .00 9.32
08/25/95 26.20 16.98 16.98 0.00 9.22
11/15/95 26.20 17.01 17.01 0.00 9.19
02/26/96 26.20 18.13 18.13 0 .00 8.07
MW-25 06/16/93 33 .55 18.48 18.48 0.00 15.07
09/20/93 33.55 18.60 18.60 0 .00 14.95
03/29/95 33.55 17.95 17.95 0 .00 15.60
08/25/95 33.55 18.36 18.36 0.00 15.19
11/15/95 33.55 18.41 18.41 0 .00 15.14
02/26/96 33.55 19.70 19.70 0 .00 13.85
MW-26 06/16/93 31.28 16.45 16.45 0 .00 14.83
09/20/93 31.28 16.41 16.41 0 .00 14.87
03/29/95 31.28 15.81 15.81 0.00 15 .47
08/25/95 31.28 16.15 16.15 0 .00 15.13
11/15/95 31.28 16.15 16.15 0.00 15.13
02/26/96 31.28 17 .62 17.62 0 .00 13.66
Page 4 of 5
.-
~;~-~
~-~:"•'
,~ ~. ,.:.,·•·
~f;.~~
TABLE 1
SUMMARY OF GROUNDWATER ELEVATION DATA
CITGO PETROLEUM TERMINAL
WILMINGTON, NORTH CAROLINA
S&ME PROJECT 1264-93-309
iliil l 11 119:lll l■~!l;■J111Sl ll!IJi?t 1iB ;;i
MW-27 06/16/93 33.47 16.21 16.21 0.00 17.26
09/20/93 33.47 16.45 16.45 0.00 17.02
03/29/95 33.47
08/25/95 33.47
11/15/95 33.47
02/26/96 33.47
MW-30 09/20/93 31.13
03/29/95 31. 13
08/25/95 31.13
11/15/95 31.13
02/26/96 31. 13
MW-31 03/29/95 34.46
08/25/95 34.46
11/15/95 34.46
02/26/96 34.46
MW-32 03/29/95 33. 70
08/25/95
11/15/95
02/26/96
MW-33 03/29/95
08/25/95
11/15/95
02/26/96
MW-34 03/29/95
08/25/95
11/15/95
02/26/96
MW-36 03/29/95
08/25/95
11/15/95
02/26/96
MW-37 03/29/95
08/25/95
11/15/95
02/26/96
*** -could not open well lock
TOC -top of casing
MSL -mean sea level
ft-rel -feet relative to TOC
33.70
33.70
33.70
32.81
32.81
32.81
32.81
30.03
30.03
30.03
30.03
28.52
28.52
28.52
28.52
28.23
28.23
28.23
28.23
'***
16.20
16.23
17.74
22.21
21.69
21.83
21.71
22.82
24.17
24.20
24.15
25.00
21.59
21.84
21.45
22.86
23;55
23.60
23.65
24.90
20.00
20.00
20.00
20.70
18.02
18.14
18.27
19.34
16.60
16.72
16.77
17.95
Page 5 of 5
'*** *** ***
16.20 0.00 17.27
16.23 0.00 17.24
17.74 0.00 15.73
22.21 0.00 8.92
21.69 0.00 9.44
21.83 0.00 9.30
21.71 0.00 9.42
22.82 0.00 8.31
24.17 0.00 10.29
24.20 0.00 10.26
24.15 0.00 10.31
25.00 0.00 9.46
21.59 0.00 12.11
21.84 0.00 11.86
21.45 0.00 12.25
22.86 0.00 10.84
23.65 0.00 9.16
23.60 0.00 9.21
23.65 0.00 9.16
24.90 0.00 7.91
20.00 0.00 10.03
20.00 0.00 10.03
20.00 0.00 10.03
20.70 0.00 9.33
18.02 0.00 10.50
18.14 0.00 10.38
18.27 0.00 10.25
19.34 0.00 9.18
16.60 0.00 11.63
16.72 0.00 11.51
16.77 0.00 11.46
17.95 0.00 10.28
WELL BATE
NUMBER
MW-1 08/23/90
09/04/91
06/16/93
03/29/95
08/24/95
11/15/95
02/26/96
MW-2 08/23/90
09/04/91
06/16/93
03/29/95
08/24/95
11/15/95
02/26/96
MW-11 08/23/90
09/04/91
06/11/93
08/24/95
02/26/96
MW-21 08/23/90
09/04/91
06/15/93
03/29/95
08/24/95
11/15/95
02/26/96
MW-30 09/20/93
03/29/95
08/24/95
11/15/95
02/26/96
TABLE 2
GROUNDWATER QUALITY DATA
(REMEDIATION AREA}
CITGO ASPHALT TERMINAL
(FORMERLY AMOCO CORPORATION)
WILMIMGTON, NORTH CAROLINA
S&ME PROJECTS 1264-93-309/1264-95-243
··s T E .. X
(ug(L) (Og/L) JugfL) (u g /L)
6.00 10.00 132.00 119.00
<1.0 <1.0 <1.0 <1.0
1.50 20.00 89.00 280.00
<1.0 6.80 60.00 220.00
<0.5 <0.5 0.62 3.72
<0.5 <0.5 <0.5 2.45
<0.5 <0.5 <0.5 0.55
32.00 2250.00 783.00 4400.00
<10 3530.00 600.00 3400.00
< 5.0 2900.00 800.00 6100.00
<1.0 980.00 410.00 3500.00
<0.5 357.00 246.00 2240.00
<0.5 196.00 169.00 2191.00
<0.5 4.21 <0.5 262.00
<2 50.00 258.00 824.00
<1 <1 2.00 10.10
11.00 42.00 440.00 1100.00
<5 7.59 158.00 354.00
<5 8.71 206.00 343.00
11.00 205.00 491.00 2530.00
< 1.0 25.20 4.60 1.00
< 1.0 43.00 150.00 870.00
< 1.0 100.00 150.00 1300.00
<0.5 1.26 17.20 108.00
<0.5 5.08 24.40 187.00
<0.5 63.10· 87.10 809.00
<10 25.00 290.00 2000.00
<1.0 1.80 30.00 160.00
<0.5 <0.5 <0.5 0.63
<0.5 <0.5 <0.5 <0.5
<0.5 <0.5 <0.5 <0.5
BETX .MTBE:
(ug/L). . (ug/L)
267.00 <20
ND <-1.0
390.50 < 10
286.80 <1.0
4.34 1.56
2.45 <0.5
0.55 <0.5
7465.00 20.00
7530.00 < 10
9800.00 < 100
4890.00 <1.0
2840.00 <0.5
2255.00 <0.5
266.00 <0.5
1130.00 <2
12.10 <1
1593.00 20.00
520.00 <5
558.00 <5
3237.00 30.00
30.80 46.50
1063.00 < 10
1550.00 < 1.0
126.00 <0.5
217.00 <0.5
959.00 <0.5
2315.00 ---
191.80 <1.0
0.63 <0.5
<0.5 2.25
<0.5 1.73
~ t=LOW~I:?§ Clil:MICAL
~ '-4.130124 TOl21~§.l~C.
S·ection 1
Surrogate
Compound
Reco ve ry
Client:
Project Number:
P.O. Number:
Date Sampled:
Lab Numbers:
S&ME-Spartanburg
Citgo
1264-93-309
26-Feb-96
8271 -8276
PID_Spike for EPA602
Unit of measure: ug/L
Surrogate Expected: 100
Acceptability Limits: 75.2 -116
Laboratory Site Surrogate Percent
Number Descri otion Recovered Recovered
"'!'"',~~~ W"&'@,S4~9 C :;t;,;t"'.;;(61 . ~ .. :iw...at it; :w; ® ,;ffffJ. ~ ~,-
8271 MW-1 96.6 96.6
8272 MW-2 102 102
8273 MW-11 101 101
8274 MW-21 107 107
8275 MW-36 97.0 97.0
8276 MW-37 115 115
~ t=LOW~l2S Ctil:MICAL ~ • A.130124 TOVl~~~l~C.
_)ection 2
Matri x
Spi ke
Reco very
Analyte Unit
£: ~C. ~</Hf#"'~
R .~•~~., .,_
Benzene ug/L
Toluene ug/L
Ethylbenzene ug/L
Xylene ug/L
Total BTEX ug/L
Methyl-tert-butylether ug/L
Client:
Project Number:
S&ME-Spartanburg
Citgo
P .0. Number:
Date Sampled:
Lab Numbers:
Analysis Date Spike
Method ~ddec
~~, f• ,~.i'°-""" ... /ft '=··.,
EPA602 02-28-96 40.0
EPA602 02-28-96 40.0
EPA602 02-28-96 40.0
EPA602 02-28-96 120
EPA602 02-28-96 240
EPA602 02-28-96 40.0
1264-93-309
26-Feb-96
8271 -8276
SamplE MS MS MSD
Cone. Cone. Rec. Cone. -........ _ -''~",i =-'•
<0.5 38.5 96.3% 38.0
<0.5 38.5 96.3% 37.9
<0.5 37.3 93.3% 36.5
<0.5 108 90.0% 106
<0.5 222 92.5% 219
<0.5 33.2 83.0% 33.1
MSD
Rec.
~
95.0%
94.8%
91.3%
88.3%
91.3%
82.8%
Acceptable RSD Acceptable . .
Limits Rec. Limits
~~J~ __..,_ 11<,,,.-; ~~~ j #,,,,.,m
"-), .. ~'?tii
32.0-47.4 0.354 0-4.96
31 .9-47.4 0.424 0-6.40
31 .6-47.3 0.566 0-4.73
94.7-140 1.41 0 -12.7
196 • 277 2.12 0 • 21.0
29.2-48.4 0.071 0-4.87
J
~ t=LOWl:l?§ CtilMICM
~ IA.130l?ATOl?ll:i~l~C.
Section 4
aces
Sample
Reco very
Client: S&ME-Spartanburg
Analyte
kw~ ... .,,, ........ . -~ -:~,
Benzene
Toluene
Ethylbenzene
Xylene
Total BTEX
Methyl-tert-butylether
Projed Number: Citgo
P .0. Number: 1264-93-309
Date Sampled: 26-Feb-96
Lab Numbers: 8271 -8276
Unit Method Date aces
Exoected
w-=---~Ai . _ .. .,. -... ·ci. ... .,.,.. ~ -,, ,.,_., --
Ug/L EPA602 02-28-96 40.0
ug/L EPA602 02-28-96 40.0
Ug/L EPA602 02-28-96 40.0
ug/L EPA602 02-28-96 120
ug/L EPA602 02-28-96 240
ug/L EPA602 02-28-96 40.0
aces
Measured
• ··$
,... --....,_ , .
44.3
44.6
43.3
119
251
39.6
Rec. Acceptable ..
% Limits
-~•»I·-~:;~: ~=!'# ;I{':·"'=
···"'' .-· .•, e,s;,
111% 34.6-47.8
112% 33.9 -47.7
108% 32.9-47.9
99.2% 97.9-134
105% 208-268
99.0% 32.4-48.4
ANA L YT ICAl RESU LTS FOR M HRS N urrber 83139
MW-30 MW-31 MW-32 MW-33 MW -3'1 MW-22 V-24 QA Section -Parameter "°rnl>ol Unft 8277 8278 8279 8280 8281 8282 o.!83 Melt.xi MOL %RSD %Rec Ana tv• L -•"'
Ollutlon Focior # 1 1 1 1 I 10 1 IEPA602 11 DO 02-26-116
Benzene . uQ/l <0.5 <0.5 <0.5 <0.5 ..o.s <0.5 <0.5 EPA602 o.s 3.59 102 DO 02-28-96
Toluene . uQ/l <0.5 <0.5 <0.5 <0.5 <0.5 10.5 20.9 EPA602 0.5 2.23 107 DO 02-28-96
Etllvlben •e"" . unll <0.& <0.6 dl.6 <0.S l..o .~ 843 16.82 IEPAMl> 0.5 10 .11 108 DO m..~s-96
x ~lene . unn <0.5 <0.5 <0.5 <0.5 <O.S 1023 419 EPA602 o.s 3.27 113 DO 02-28-96
Total BTEX . uQ/l <0.5 <0.5 <0.5 <0.5 <0.5 1877 446 EPA602 0.5 0.816 109 DO 02-28-96
Me1 hv~1erl -buMethe r . un11 i173 12.S <0.5 <0.6 1.411 <0 .5 ..i'l,I. EPA602 0.5 1S.S 89 .7 no 02-2S-96
PID Solke . '"'" 102 101 102 102 102 114 112 EPA602 o.s 1.19 106 DO 02-28-96
. . . .
Date Received: 0?-?8-911 T\IDQd · IN.IIA.98 SAnl ' 03-04-!lfl
Proled Number AMSESC-
PO Number 1264-95-243
Dale Sampled 1 02-28-96 •
Dale Analyzed 0
Corq>acled
Formal NormRR
UnllCoal Exted
BTEXM 8500 7.
,.,,_,,. ... -""71. 1 .
· ~ -=LOWl:12~ Cl-il:MICAL
~ I Al3012A TOVl~~~l~C.
Section 1
Surrog ate
Compound
Recovery
Client:
Project Number:
P.O. Number.
Date Sampled:
Lab Numbers:
S&ME-Spartanburg
AMSESC-
1264-95-243
26-Feb-96
82TT-8283
PID_Spike for EPA602
Unit of measure: ug/L
Surrogate Expected: 100
Acceptability Limits: 7 4.9 -117
Laboratory Site Surrogate Percent
Number Description Recovered Recovered
l \o~~~~ ;~;,. ,$.~>J..'•"'11 ~ -1-~ Iii -~~ -r..-~.;,.;,; ~~ ,;;1.l, '1;. -\If,~
a2n MW-30 102 102
8278 MW-31 101 101
8279 MW-32 102 102
8280 MW-33 102 102
8281 MW-34 102 102
8282 MW-22 114 114
8283 MW-24 112 112
i
i : .,
j
I
J
j
J
l
J
~ t=LOW~VS CtiHllCAL
~ lA130~~ TOVl~~!)l~C.
Section 4
aces
Sample
Recov ery
Client: S&ME-Spartanburg
Analyte
If'¾ ~(''~ ...,.;ill ~-,; .'fl'i ~-~ $ fh ~
Benzene
Toluene
Ethy lbenzene
Xylene
Total BTEX
Methyl-tert-butylether
Project Number: AMSESC-
P .O. Number: 1264-95-243
Date Sampled: 26-Feb-96
Lab Numbers: a2n -8283
Unit Method Date aces
Expected
. , "°-=4&~---$, ~~~t. >i,Jii:,.-,.......,..-'· -~ 'J'll!~"',
ug/L EPA602 02-28-96 10.0
uwt EPA602 02-28-96 10.0
ug.lL EPA602 02-28-96 10.0
u g/L EPA602 02-28-96 30.0
u g/L EPA602 02-28-96 60.0
u g/L EPA602 02-28-96 10.0
aces Rec.
Measured o/o
M .. '-t?i.;, ~.~~-i ,.,. '...¥ .~ ...... -.
10.2 102o/o
10.8 108o/o
8.88 88.So/o
30.8 103%
60.7 101o/o
10.9 109o/o
Acceptable
~
Limits
~ ~z:@,,
8.68 -12.1
8.51 -12.1
8.23-12.0
24.6-33.4
52.1 -67.3
8.07 -12.1
S .L SAVANNAH LABORATORIES
& ENVIRONMENTAL SERVICES. INC.
9,0_Q Lakeside Drive • Mobile, Alabama 36693-5118 • [phone] • Fax [phone]
March 19, 1996
Mr. David Klemm.
Soil & Material Engineers
155 Trodd Street
Spartanburg, SC 29301
Re: Product sample from MW-23 CITGO/Amoco
Dear David:
The MW-23 sample received contained primarily water with a petroleum product layer floating on the
surface. The upper product sample from MW-23 was analyzed using GC-flame ionization detector and
capillary column technique to identify the type of upper petroleum layer in the well water. Since the
sample was assumed to be diesel, GC conditions to test for diesel were used.
The sample chromatogram revealed that the product was not similar to diesel. The hydrocarbon pattern
, lamed much earlier eluting compounds than diesel; however, there were Cs, C10, Cu alkanes in the
sample which are the early boiling hydrocarbons in diesel fuel. The 1-metbylnaptbalene and 2-
methylnapthalene peaks normally associated with diesel were absent.
The product sample from MW-23 was analyzed _ for gasoline range organics using GC-flame ionization
detector and capillary column technique coupled with purge and trap sample concentrator. The sample
gave a GC fingerprint somewhat similar to gasoline; however, the early eluting components of gasoline
were much reduced indicating possibly weathered gasoline product. Benzene, toluene and ethylbenzene
were present at much reduced levels normally associated with gasoline. Xylenes were present at a higher
concentration than the other simple aromatic components of gasoline.
In summary, the product found in MW-23 is not similar to fresh gasoline, but was similar to or contained
weathered gasoline. Enclosed are the chromatograms for your review.
If you should have further questions or need additional information, please call me.
~r;;~(Y~
j.~se L. Smith
Laboratory Director
J:L-6/lps
enclosures
Laboratories in Savannah, GA• Tallahassee, FL• Tampa, FL• Deerfield Beach , FL• Mobile, AL • New Orleans, LA
...
Division of Environmental Management
Raleigh Regional Office
April 25, 1996
MEMORANDUM
To:
From:
Subject:
A. Preston Howard, Jr., P.E.
Director
Kenneth Schuster, P.E.
Regional Supervisor
Hearing Officer's Report and Recommendations
Variance request.from 15A NCAC 2L .0202 and
15A NCAC 2L .0106(j)
Amoco Oil Company at the Citgo Products Terminal
Wilmington, New Hanover County
Your July 21, 1995 memo designated me as the hear_ing officer for the
subj act variance request. A hearing was held _on August 3:, 199 5°'-'at 7 : 00pm in
the auditorium at Cape Fear Community College. Attached to this memo are:
l)an introduction to the variance request, 2)a summary of the comments made at
and in respon·se to the public hearing/notice and the response to comments
made, 3)a discussion of relevant issues, and 4)recommendations to the
Environmental Management Commission (EMC).
The issue concerns whether the EMC should approve or deny a request for
a variance from 15A NCAC 2L .0202 (groundwater quality standards) and 15A NCAC
2L .0106(j) (corrective action). In accordance with 15A NCAC 2L .0113(a) and
North Carolina General Statute 143-215.J(e), the EMC has the authority to
approve or deny variance requests.
The nature of the request warranted the request for additional
information from Amoco Oil Company. The additional information was requested
by letter December 15, 1995 and was received on January 31, 1996. On March 6,
1996 Bruce Reed of the Wilmington Regional Office Groundwater staff telephoned
to inform me that he received a call from a representative of Amoco Oil
Company. They let him know that they recently had i to 1 inch of free
petroleum product in one of the monitoring wells (MW-23) located in the
variance request area. On March 28, 1996 I received a copy of the February
-
Page 3
Amoco Oil Company
INTRODUCTION
In 1951 Amoco Oil Company (Amoco) constructed an asphalt blending,
storage, and sales facility. Amoco operated the facility until April 30, 1993,
at which time it was acquired by CITGO Petroleum Corporation (CITGO). The
CITGO terminal facility is located on River Road in Wilmington. The terminal
consists of approximately 31 acres of land and is about 900 feet east of the
Cape Fear River (see diagram attached). As a result of day-to-day terminal
operations occasional spills and leaks have occurred throughout the years and
have caused contamination of the subsurface soils and groundwater. Amoco has
accepted responsibility for delineating, evaluating, and.implementing
appropriate remedial measures for the off-site portion of the dissolved
hydrocarbon plume that originated from what is now the CITGO Products
Terminal.
Initial test borings and monitoring wells were installed in 1988. The
Division sent a March 1989 Notice of Violation for the exceedance of
groundwater quality standards in three of the twelve monitoring wells pursuant
to 15A NCAC 2L. Nine additional monitoring wells were installed in 1990. In
August of 1991 three monitoring wells were installed along the western edge of
the River Road right-of-way (held by NC DOT, see diagram attached). The
intent of the monitoring was to determine if the groundwater plume had
migrated beneath River Road onto the adjacent Koch Refining Company (Koch)
terminal property.
In 1992 the DEM, Wilmington Regional Office requested that additional
delineation of the plume be made. In res~onse, seven permanent_~nitoring
wells were installed on the property owned by Koch Refining Company (Koch) and
12 temporaryJ"ells were installed on property owned by the American Crane. ,.,Jv/. J
Corporation~~hich is south of the CITGO and Koch terminalo/• NG p ... -..,...cf,1,'-u 1
An approved Corrective Action Plan (CAP) is currently being implemented at the
CITGO terminal. Air sparging wells have been installed on site and down
gradient on the adjacent American Crane Corporation property.
~~ .
A variance J:,( 15A NCAC 2L .0202 (groundwater quality standards) and 15A
NCAC 2L .0106(j) (corrective action) is requested by Amoco for the approximate
two acre area located on and across River Road, on properties owned by the
Citgo Products Terminal, The American Crane Corporation, CSX Transportation,
and Koch Refining company. The land in which the area of the variance
encompasses the most offsite property is owned by Koch. Amoco has made ~-r{:-Jt,,~
variance request by filing.ct,n application in accordance with part(c) of 15A
NCAC 2 0113 ··,~~~., f.,
L • • :~. l !f/J;i-rl)
Pursuant to 15A NCAC 2L .0113 (d) and (e), public notice of this
variance request was sent to adjacent property owners, the New Hanover County
Health Director, the City Manager for the City of Wilmington, and the Mayor of
Wilmington. Notice of this hearing was also published in the July 2, 1995
Page 4
Amoco Oil Company
edition of the Wilmin gton star-News to meet requirements of 15A NCAC 2L
.Oll3(e)(l)(A). In addition, approximately 500 notices of this variance
request were sent to persons .listed in the 'Groundwater Variance and
Regulatory Actions Mailing List' to meet the requirements of 15A NCAC 2L
.0113(e)(l)(F). Prior to the public Hearing a press release was sent to all
newspaper companies, television stations, and radio stations that serve New
Hanover County.
A public hearing was held on August 3, 1995 at 7:00 at the Cape Fear
Community College, 411 North Front street, Wilmington by the Department of
Environment, Health and Natural Resources on behalf of the Environmental
Management Commission to receive public comment in response to notice of the
variance request. A total of twelve registered persons attended the hearing,
with two people presenting oral comments. Written comments were submitted by
one of the speakers. No other written comments were received. The hearing
record allowed for written comments to be submitted through~ September 4,
1995. Mr. Bruce Reed of the Wilmington Regional Office, DEM initially
presented an overview of the variance request.
SUMMARY OF COMMENTS AND RESPONSES
Written/verbal comments and there respective responses are shown as follows:
Comment #1:
one commenter objected to the proposed variance that ai~o~~_Amoco Oil
Company to leave contamination at this site without performing the corrective
actions necessa~y to clean-up this area to the state standards. The commenter
stated that Amoco did not promptly cleanup oil and asphaltic product releases
that occurred from decades ago and should not be allowed to walk away from
cleanup responsibilities just because it's going to cost them a substantial
amount of money. He said that Amoco was well aware of it's operations, t~~~
geologic environment beneath the terminal, the presence of groundwate~nd \.,
the potential impacts of leaks from degrading steel containers. Corporations -~
that knowingly release harmful substance into the environment have an ~.
obligation to clean-up the environment.
The person commenting is deeply concerned about the effect of petroleum
product pollution on wetlands, drinking water, surface waters, wildlife, and
humans. Skepticism was expressed about the claims that asphaltic substances
and petroleum products found at this site will degrade naturally over time.
Studies of the impacts from petroleum releases have shown that long-term
effects of oil spills are devastating to the environment. In this person's
view the persistence of certain chemical components of petroleum releases is
sufficiently long to cause chronic human health and ecologic problems, and the
mobility of contaminants can expose a vast population to chronic health
effects.
Page 7
Amoco Oil Company
Corporation's property rights?
(B)How would lenders react to a variance?
(C)How would having a variance on part of our property effect permits
that may be granted by the state and county?
Response to comment #4
The questions are responded to as follows:
(A) As per 15A NCAC 2D.0113(i): a variance shall not operate as a
defense to an action of law based upon a public or private nuisance theory or
any other cause of action.
(B) DEM regulations do not contain any authority to require lending
institutions to respond in a specified manner to variance situations. The
lending institutions may react as they see fit and in accordance with any
other laws or regulations that govern them.
(C) A review by the DEM groundwater staff of the permitting regulations
as they pertain to: Chapter 143, Article 21A, Part 2A and 15A NCAC 2N
(underground storage tanks) does not show any references to 'variances•. 15A
NCAC 2L (Classifications and water quality standards applicable to
groundwaters of NC) do not restrict sites from getting a permit that have
received a variance.from the Commission. Well construction rules in 15A NCAC
2C .0100 and .0200 do not contain any additional construction requirements or
location requirements at a site where some of the property has been granted a
variance.
Comment #5:
Since Amoco proposes to rely on the natural process . .-with~~:the earth's
subsurface to reduce contaminant levels, have they proposed a time limit on
this variance?
Response to comment #5
The Company has not proposed a time limit on this variance. The process
of natural attenuation is highly dependent on subterranean features and it is
very difficult to project a time frame in which the process will complete
itself. As stated in response to comment #3, if the sampling results portray a
trend of increasing concentrations then active remediation could be required
as per a condition of a variance approval.
Page 8
Amoco Oil Company
DISCUSSION
1. An adjacent water supply well owned by Atlantic Marine, Inc. is
located approximately 700 feet northwest of the variance request area
and they have submitted information showing that it is not being used
for consumption. Atlantic Diving and Marine Contractors, Inc. have a
contract with a company that provides bottled water.
Five other water supply wells are located within a½ mile radius
of the variance request area. For these five locations well water use
-is -presently limited to supply process water or other uses not
associated with drinking water consumption, and each is reported to be
connected to the Wilmington municipal water supply.
2. In establishing that the requirements of the corrective
3.
action/groundwater quality standards cannot be achieved by providing the
best available technology economically reasonable, the variance request
document states .that there is free product down gradient (adjacent to
the Koch terminal). Further, that long term restoration is not possible
since re-contamination could occur from the Koch terminal plume. The
Wilmin~ton Regional Office should maintain vigilante efforts to
encourage the responsible party to complete the site assessment and
corrective action plan for the plume originating on the adjacent Koch
site.
It was initially the impression of this hearing officer that the
present remediation system (air-sparging)is located only to the south of
the Amoco property, on the American Crane corporation p~on~rty. I have
been informed by additional correspondence from Amoco that an air
biosparging system is being operated on the west side of the Citgo
terminal, up gradient of the variance request area. These sparging )
wells were placed on-line in May 19~5-_ h--e.£ Froe:loc....,T ~ C N<1.ed d,sc.oSS tanc5/
RECOMMENDATION
Based on the above public comment, a review of the issues, subsequent
discussions with staff, and the monitoring results it is recommended that the
variance be denied •
• ,.,J Nf•rl
, l'I l ·-·--_,
1 '
Mr. Jim Schaeffer
Amoco Corporation
375 Northridge Road, Suite 600
Atlanta, GA 30350
Subject:
Dear Mr. Schaeffer,
April 16, 1996
Information Regarding the Hearing Officer's
Recommendation and Final Action on the Variance
Requested by the Amoco Oil Company at the Citgo
Products Terminal in Wilmington, North Carolina.
On August 3, 1995 a Public Hearing was held on a variance request from the Amoco Oil
Company in accordance with the requirements of title 15A NCAC 2L .0113. Th.is variance
request concerned property that was once owned by the Amoco Oil Company located at River
Road in Wilmington, North Carolina. The Director of the Division of Environmental
Management designated me the hearing officer for this variance request from Groundwater
Quality Standards in 15A NCAC 2L .0202 and Corrective Action as required by 15A NCAC 2L
.0106(j).
Th.is site near a petroleum products terminal that was built by Amoco Oil Company in
1951. Over many decades of operation numerous accidental releases of petroleum occurred at this
from routine storage and loading operations at the terminal. You will recall that in April 1993
Amoco sold this site and it is now known as the Citgo Products Terminal. Th.is variance was
requested for an area of groundwater contamination located to the west of the Citgo Products
Terminal and partly owned by the Citgo Oil Company and other adjacent property owners. The
CSX Transportation Railway line and a public road managed by the NC Department Of
Transportation are also within this area. Several monitoring wells are located within the area of
the variance. You will also recall that I requested additional groundwater sampling and analysis
1
from these monitoring wells to assist me in making my recommendation to the Environmental
Management Commission, pUFsuant to the requirements of 15A NCAC 2L .0113.
On February 28, 1996 the Amoco Oil Company contacted the Wihnington Regional
Office and reported that free product had been found in Monitoring Well# 23. This monitoring
well is located within the area proposed for variance. On March 11, 1996, I informed
Groundwater Section and Division of Environmental Management staff that the hearing officer's
review and report would be delayed pending the outcome of laboratory analysis by the Amoco
Oil Company. Amoco Oil Company wanted to perform chemical analysis of the monitoring well
sample to ascertain if the free product found was actually weathered diesel fuel or weathered
gasoline from another site. On March 26, 1996 the Amoco Oil Company submitted a report of
this laboratory analysis to the Wilmington Regional Office.
The Regional Office has reviewed this information sent by the Amoco Oil Company and
deems that the company has not sufficiently demonstrated that the free product liquid found in
the February 28, 1996 groundwater analysis is diesel fuel. Based on analysis of groundwater
sampling results reported by the Amoco Oil Company's contract laboratory, the Wilmington
Regional Office has concluded that the free product found in Monitoring Well# 23 demonstrates
the characteristics of weathered gasoline. However, Amoco Oil Company has not provided
information showing that the free product did not originate from past operations during the time
the Amoco Oil Company operated the terminal now owned by·the Citgo Oil Company. Based
on this new monitoring well information, Groundwater Section staff at the Wilmington Regional
Office have indicated that they cannot support a recommendation in favor of granting the
requested variance.
I have recently examined the Groundwater Section records in regards to this variance and
have found there had been no correspondence from the Amoco Oil Company or it's consultant
Remediation Technologies Incorporated (RETEC) since January 30, 1996. We have not obtained
any information indicating that the Amoco Oil Company intends to continue pursuing the
variance at this location. It must be noted that the 15A NCAC 2L .0113 rule state that the
Environmental Management Commission (EMC) must take final action on variances to
groundwater rules in 15A NCAC 2L. Prior to presentation to the full EMC this variance must
go before the Environmental Management Commission's Groundwater Committee for review.
The next three meetings of the Groundwater Committee are on May 8, 1996, July 11, 1996 and
September 12, 1996. Unless the variance is withdrawn by Amoco Oil Company, it is my
intention to present this variance request to the EMC Groundwater Committee at the May 8, 1996
meeting so that it may go to the full Commission in July 1996. If the company wishes to
continue pursuing this variance, wishes to withdraw the request, or wants a reasonable
delay in the review of this variance in order to complete additional site assessments and
groundwater analysis, please inform me of this in writing no later than April 25, 1996.
In light of finding free product at monitoring well# 23 and no information to substantiate the
origin of this groundwater contaminant, I cannot make a recommendation to the Environmental
Management Commission to approve of this variance.
2
All variance requests must conform to the format found in 15A NCAC 2L. This includes
variances to Groundwater Quality Standards in 15A NCAC 2L .0202 and Corrective Action
requirements in 15A NCAC 2L .0106. These requirements include the October 1993 revisions
that allow for the submission of corrective action plans that propose alternate cleanup strategies.
Alternate cleanup plans may be submitted for sites that meet the criteria under 15A NCAC 2L
.0106(k),(l) and (m). The act of withdrawing a variance by the responsible party or denial of a
variance by the Environmental Management Commission does not preclude a responsible party
from seeking a separate variance for the same site at a later date. However, conditions at the site
must change to the extent that a new proposed variance will meet the criteria of 15A NCAC 2L
.0113.
Please send your response to me, Kenneth Schuster, P.E., Regional Supervisor, NC
Department of Environment, Health and Natural Resources, Division of Environmental
Management, Raleigh Regional Office, 3800 Barrett Drive, Suite 101, Raleigh, North Carolina
27609. If you have any questions about this letter, please feel free to call me at [phone]
{Fax Number: [phone]). If you wish to discuss technical issues regarding this site and
variance, please contact Mr. Bruce Reed or Mr. Charles Stehman in the Wilmington Regional
Office at [phone].
cc: Arthur Mouberry
Carl Bailey
David Hance
Bruce Reed
Wilmington Regional Groundwater Supervisor
Sincerely yours,
Kenneth Schuster, P.E.,
Regional Supervisor,
DEM Raleigh Regional Office
3
Division of Environmental Management
Raleigh Regional Office
March 11, 1996
MEMORANDUM
To: A. Preston Howard, Jr., P.E.
Director
From: Kenneth Schuster, P.E.K
Regional Supervisor
Subject: Status update
Variance request from 15A NCAC 2L .0202 and
15A NCAC 2L .0106(j)
Amoco Oil Company at the Citgo Products Terminal
Wilmington, New Hanover County
-,.
C.Jl
0
Your July 21, 1995 memo designated me as the hearing officer for the
subject variance request. A hearing was held on August 3, 1995 at 7:00pm in
the auditorium at Cape Fear Community c _ollege.
The issue concerns whether the EMC should approve or deny a request for
a variance from 15A NCAC 2L .0202 (groundwater quality standards) and 15A NCAC
2L .0106(j) (corrective action). Several issues have caused a delay in my
presenting recommendations to you. The initial presentation of well sampling
data was sparse and I had requested information pertaining to additional
sampling events. I also had questions concerning the risk assessment that was
conducted. The additional information was requested by letter December 15,
1995 and Amoco Oil Company submitted the information on January 31, 1996.
Bruce Reed of the Wilmington Regional Office, Groundwater staff recently
telephoned to inform me that he received a call from a representative of Amoco
Oil Company. They let him know that they recently had i to 1 inch of free
product in one of the monitoring wells located in the variance request area.
Amoco is presently analyzing for sample constituents, etc. and will be
updating Bruce in a couple of weeks.
Based on the present situation, I am awaiting the results of the
additional analyses prior to completing my recommendations to you.Please
contact me if you have any questions concerning the report.
cc: Harlan Britt
Arthur Mouberry
Bruce Reed (WiRO)
David Hance
NOTE: 02/29/96
TO: Ken Schuster,
SUBJECT: DISCUSSION OF THE FEBRUARY 20, 1996 DRAFT HEARING OFFICER'S
REPORT FOR THE VARIANCE AT THE CITGO PRODUCTS TERMINAL IN
WILMINGTON, NC.
On February 22, 1996 you gave me a copy of the DRAFT hearing officer's report
for the Citgo Products Terminal Variance request by the Amoco Oil Company. This
hearing officers report contains responses to the comments made at the August 3, 1995
public hearing held in Wilmington, NC. You requested that I examine these responses
and make appropriate suggestions. I found that a number of editorial and formatting
changes are needed. I believe that these changes will assist the hearing officer in making
final recommendations to the EMC Groundwater Committee when they examine this
report. This review is tentatively scheduled for April 1996. I also found some significant
areas of the report that I think need to be further addressed and are these listed below
with the identifying page numbers:
1) At the bottom of page # 3, the response to comment # 1 stated that
"Amoco is not totally void of having to cleanup the site .... ". The use of the
word "void" does not communicate what I believe was your intent. If the
sentence was re-phrased to read as "This variance, if granted, will not
exempt Amoco Oil Company from the continued responsibility for the
site. Follow this sentence by saying something like this: "If a variance is
granted at this site, the Amoco Oil Company must maintain a
groundwater monitoring effort as required by the conditions of a variance
and Division directives. Monitoring must continue for a sufficient period
of time to assure that remaining concentrations within the area of the
variance do not increase. If it appears concentrations are increasing due
to the past actions of the Amoco Oil Company, the company may still be
held responsible for cleanup by the Division. If another property owner
in the area releases substances into groundwaters, soil, or land surface
within the area that the variance was granted, the appropriate responsible
party or parties will subject to the cleanup requirements of 15A NCAC
2L." Do we need more discussion of the types of enforcement actions
DEM could take in this circumstance?
1
2) At the top of page# 4, the response to comment# 1 discusses the risk
assessment that Amoco performed. No definitive conclusion is given in the
report showing the value of the risk assessment. There is no mention of
what the risk assessment means to the variance. The response to comment
# 1 needs to show that the demonstration made by the company is
sufficient to meet the requirements of 15A NCAC 2L .0113 and reasons
why this is so need to be stated.
3) On page# 6 under Number 1 of the DISCUSSION, the report gives a
recommendation for "semiannual monitoring" at this site. If you are
recommending semiannual monitoring does it not belong on page# 8
only?
4) On page# 6 under Number 2 of the DISCUSSION, the report gives a
recommendation that the site assessment and corrective action plan be
completed for the ad jacent Koch Refining Company site. I believe that
making this kind of a recommendation may cause the variance to be
unworkable. This recommendation makes the granting of Amoco's variance
request contingent on the actions of a separate responsible party for which
Amoco Oil Company has no control over. Since this is a recommendation
does it not belong on page # 8 only?
5) On page# 7 through # 8 under Number 5 of the DISCUSSION, the report
begins to address the requirements of 15A NCAC 2L .0113 (c). It states that
nine items need to be addressed but it only addresses 1 SA NCAC 2L
.0113(c)(5) and 15A NCAC 2L .0113(c)(7) in the narrative. If the format of
the report is to show how items 1 through 9 of 15A NCAC 2L .0113(c)
were addressed then it must do so for all the items for the sake of
consistency and readability.
6) On page# 8 under the RECOMMENDATIONS section of this report, you
have recommended that the site assessment and corrective action plan be
completed for the ad jacent Koch Refining Company site. I believe that
making this kind of a recommendation will make it difficult to fully
2
implement. This is because only part of the property in the area of the
variance is owned by Koch Refining Company. Assuming Koch Oil
Company continues to be the responsible party for the other release
identified in the variance request, the company will only have access,
control and the ability to implement corrective actions within the confines
of Koch Refining Company land. The other land owners or future owners
may not be willing to allow timely remediation if portions of the plume
migrate onto their properties due to litigation, delays in negotiating
agreements, or other third party liability issues. The recommendation, as
written, makes Amoco Oil Company's variance request contingent on the
actions of a separate responsible party and other persons for which Amoco
Oil Company has no control over. If agree it is important to prevent the
area for which the variance has been requested from becoming re-
contaminated. I think you will need to discuss the issue of the Koch
Refining Company cleanup with the Wilmington Regional Office, Arthur
Mouberry and Preston Howard. They may feel that the cleanup
requirements under 1 SA NCAC 2L .0106 are sufficient to reach the level of
protection that you feel is needed. On the other hand they may have other
suggested regulatory vehicles the will require cleanup of the Koch site on a
scheduled basis and greater oversight by the regional office, if needed. It is
important to note that Special Orders by Consent (SOC) can be used as a
vehicle to cleanup sites. They have been used where the responsible party
refuses to remediate sites. SOCs have also been established through
negotiations between DEM and the responsible party. The Washington
Regional Office has been extensively involved in one (EMC GW SOC # 95-
01).
In addition, the draft report requested additional information regarding applicable
laws governing variances, sampling, information on property restrictions, and the effect
the variance will have on permitting. Here is my best effort at answering your questions:
A) The correct statute governing groundwater variances is NCGS 143-
215.3(e).
B) I do not believe that we have the ability to restrict the use of the
property through zoning. I am not sure about deed restrictions
either. The working group that has met to develop the EHNR
3
protocol on risk assessment and management functions has found
that there is little statutory basis for using these methods in the NC
General Statutes. (Phil Telfer ma v be able to talk about these issues
in more detail). Restricting physical access through gates and
barriers to the site is impractical because a public road and railroad
line runs right through the area of the variance. The only thing
that I know could be done through the groundwater rules is for the
Director to designate the groundwaters within the area of the
variance as Restricted (RS) pursuant to 1 SA NCAC 2L .0104(a)(2).
This will prevent the present property owner, the Citgo Oil
Company, or adjacent property owners from using the groundwaters
within the area of the variance as a source of water for drinking •
without treatment. These waters will remain RS until they are
restored to the level of the groundwater quality standards or are
reclassified by the EMC pursuant to 1 SA NCAC 2L .0201. Do you
want to recommend the groundwaters beneath the area of the
variance be designated RS? This will need to be discussed with
Arthur and the DEM Director!
C) I suggest you contact the Wilmington Regional Office about the
question concerning the reasons why groundwater sampling was
done out-of-sequence as shown on page 4.
D) In response to your question concerning the effect the variance
would have on permits issued by the DEM Water Quality Section,
the rules do not show any restrictions water quality permits just
because a property has an area of land included in a variance. I can
find no restrictions in getting a permit in the 1 SA NCAC 28 water
quality rules after a variance has been granted under 1 SA NCAC 2L
.0113. The word variance does not appear 1 SA NCAC 2H .0200
rules (Waste Not Discharged to Surface Waters). A discussion with
Air Quality Section permitted staff revealed that the mere fact a
variance to groundwater rules has been granted in accordance with
1 SA NCAC 2L .0113 will not prevent the property owner from
obtaining air quality permits or add any new restrictions to a permit.
4
E) RECOMMENDATION# 4 requires that the variance be "re-
evaluated" five (5) years after it has been granted. It may not be
necessary to review all the information associated with this variance.
Attached is some language from a previous hearing officers report
from the AMOCO T-MART variance in 1993. The last
recommendation may help you develop this recommendation more
accurately. This is from Jim Bales (FRO) hearing officers report.
If you need additional information or need to discuss these issues, please feel free to
contact me at 715-6189.
David Hance
cc: Carl Bailey
5
our groundwater rules. The statute that covers variances (NCGS 143-
215.3(e)) does not contain any restrictions on granting of permits to sites
that have _been granted a variance. I have also looked at Chapter 143,
Article 21A, Part 2A that covers the regulation of underground storage
tanks and the recent amendments to this statute in Senate Bill 101 2 that
was enacted in July 1995. I cannot see a restriction in the new statute that
prevents a person from obtain an "operating permit" for a new
underground storage tank if a variance has been granted for the site. 1 SA
NCAC 2N (UST Rules) does not contain any references to "variances". 1 SA
NCAC 2L rules do not restrict sites from getting a permit that have received
a variance from a Commission. Well construction rules in 1 SA NCAC 2C
.0100 and .0200 do not contain any additional construction requirements
or location requirements to a site where some of the property has been
granted a variance. YOU MAY WANT TO PASS THIS INFORMATION TO
PHIL TELFER TO SEE IF HE AGREES WITH THIS OR KNOWS OF ANY
OTHER STATUTES THAT WILL APPLY IN THIS SITUATION. I have not
been able to locate any state statutes related to construction and building
codes in our office. The Attorney General's Office will have these laws.
Attached is a copy of Senate Bill 1012. If you need additional information or need
to discuss these issues, please feel free to contact me at 715-6189 .
THANK YOU
David Hance
cc: Carl Bailey
2
I
j ..
c.. ..
~
State of North Carolina
Department of Environment,
Health and Natural Resources
Raleigh Regional Office NA
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary D E HNR
DIVISION OF ENVIRONMENTAL MANAGEMENT
April 18, 1996
· Mr. Jim Schaeffer
Amoco Corporation
375 Northridge Road, Suite 600
Atlanta, GA 30350
Subject:
Dear Mr. Schaeffer,
--· 0
Information Regarding the Hearing Officer's
Recommendation and Final Action on the Variance
Requested by the Amoco Oil Company at the Citgo
Products Terminal in Wilmington, North Carolina.
C'\J On August 3, 1995 a Public Hearing was held on a variance request from the Amoco Oil
.Comf>'any in accordance with the requirements of title 15A NCAC 2L .0113. This variance
req~t concerned property that was once owned by the Amoco Oil Company located at River
Ro~in Wilmington, North Carolina. The Director of the Division of Environmental
M anagement designated me the hearing officer for this variance request from Groundwater
0-Q~ity Standards in 15A NCAC 2L .0202 and Corrective Action as required by 15A NCAC 2L
.010,60).
; C,
This site is near a petroleum products terminal that was built by Amoco Oil Company in
1951. Over many decades of operation numerous accidental releases of petroleum occurred at
this site from routine storage and loading operations at the terminal. You will recall that in April
1993 Amoco sold this site and it is now known as the Citgo Products Terminal. This variance
was requested for an area of groundwater contamination located to the west of the Citgo Products
Terminal and partly owned by the Citgo Oil Company and other adjacent property owners: The
CSX Transportation Railway line . and puqlic road managed by the NC Department of
Transportation are also within this area. Several monitoring wells are located within·the area of
the variance. You will also recall that I requested additional groundwater sampling and analysis
from these monitoring wells to assist me in making my recommendation to the Environmental
Management Commission, pursuant to the requirements of 15A NCAC 2L .0113.
On February 28, 1996, the Amoco Oil Company contacted the Wilmington Regional
Office and reported that free product had been found in Monitoring Well# 23. This monitoring
well is located within the area proposed for variance. On March 11, 1996, I informed
3800 Barrett Drive, Suite 101,
Raleigh. North Carolina 27609
Voice 919-571-4700 N!iC ,,.,. . ., FAX [phone]
An Equal Opportunity Affirmative Action Employer
50"k recycled/ l O"k post-consumer paper
Page2
Amoco Oil Company
April 18, 1996
Groundwater Section and Division of Environmental Management staff that the hearing officer's
review and report would be delayed pending the outcome of laboratory analysis by the Amoco Oil
Company. Amoco Oil Company wanted to perform chemical analysis of the monitoring well
sample to ascertain if the free product found was actually weathered diesel fuel or weathered
gasoline from another site. On March 26, 1996, the Amoco Company submitted a report of this
laboratory analysis to the Wilmington Regional Office. ·
The Regional Office has reviewed this information sent by the Amoco Oil Company and
deems that the company has not sufficiently demonstrated that the free product liquid found in the
February 28, 1996 groundwater analysis is diesel fuel. Based on the analysis of groundwater
sampling results reported by the Amoco Oil Company's contract laboratory, the Wilmington
Regional Office has concluded that the free product found in Monitoring Well #23 demonstrates
the characteristics of weathered gasoline. However, Amoco Oil Company has not provided
information showing that the free product did not originate from past operations during the time
Amoco Oil Company operated the terminal now owned by the Citgo Oil Compay. Based on this
new monitoring well information, Groundwater Section staff at the Wilmington Regional Office
have indicated that they cannot support a recommendation in favor of granting the requested
vanance.
I have recently examined the Groundwater Section records in regards to this variance and
have found there had been no correspondence from the Amoco Oil Company or it's consultant,
Remediation Technologies Incorporated (RETEC) since January 30, 1996. We have not obtained
any information indicating that the Amoco Oil Company intends to continue pusuing the variance
at this location. It must be noted that the 15A NCAC 2L .0113 rule states that the Environmental
Management Commission (EMC) must take final action on variances to groundwater rules in 15A
NCAC 2L. Prior to presentation to the full EMC this variance must go before the Environmental
Management Commission's Groundwater Committee for review. The next three meetings of the
Groundwater Committee are on May 8, 1996, July 11, 1996 and September 12, 1996. Unless the
variance is withdrawn by Amoco Oil Company, it is my intention to present this variance request
to the EMC Ground Committee at the May 8, 1996 meeting so that it may go to the full
Commission in July 1996. If the company wishes to continue pursuing this variance or
wishes to withdraw the request, please inform me of this in writing no later that April 29,
1996. In light of finding free product at monitoring well #23 and no information to substaintiate
the origin of this groundwater contaminant, I cannot make a recommendation to the
Environmental Management Commission to approve of this variance.
All variance requests must conform to the format found in 15A NCAC 2L. This includes
variances to Groundwater Quality Standards in 15A NCAC 2L .0202 and Corrective Action
requirements in 15A NCAC 2L .0106. These requrements include the October 1993 revisions
that allow for athe submission of corrective action plans that proposed alternate cleanup
strategies. Alternate cleanup plans may be submitted for sites that meet the criteria under ISA
Page 3
Amoco Oil Company
April 18, 1996
NCAC 2L .0106(k), (1) and(m). The act of withdrawing a variance by the responsible party or
denial of a variance by the Environmental Management Commmission does not preclude a
responsible party from seeking a separate variance for the same site at a later date. However,
conditions at the site must change to the extent that a new proposed variance will meet the
criteria of 15A NCAC 2L .0113.
-Please send your response to me, Kenneth Schuster, P.E., Regional Supervisor, NC
Department of Environment, Health, and Natural Resources, Division of Environmental
Management, Raleigh Regional Office, 3800 Barrett Drive, Suite 101, Raleigh, North Carolina
27609. If you have any questions about this letter, please feel free to call me at [phone]
(Fax Number [phone]). If you wish to discuss technical issues regarding this site and
variance, please contact Mr. Bruce Reed or Mr. Charles Stehman in the Wilmington Regional
Office at [phone].
cc: Preston Howard
Arthur Mouberry
Carl Bailey
David Hance
Bruce Reed
Sincerely yours,
Kenneth Schuster, P.E.,
Regional Supervisor
Wilmington Regional Office Groundwater Supervisor
Mr. Kenneth Schuster, P.E.
January 30, 1996
Page2
and a HI of less than or equal to I are considered by USEPA to be acceptable and protective of human
health. Additionally, the predicted in-stream constituent concentrations resulting from the discharge of
impacted groundwater to the Cape Fear River were at least 1,000 times lower than the applicable stream
water quality standards set forth in 15A NCAC 2B .0208 and .0211. Consequently, the extremely low risk
values calculated from the risk assessment support the conclusion that this plume could not significantly
contribute to any risks that may be posed by the Koch plume. Furthermore, the low concentrations of
dissolved hydrocarbons impacting the area of the Variance Request would not compromise the
effectiveness .of any remedial measures that may eventually be implemented by Koch to mitigate the
effects of the plume adjacent to their tank farm.
The comment on the relevance of the Koch plume, or other nearby plumes, to the risk assessment
perfonned for the Variance Request also suggests the possibility that such plumes could potentially impact
the area of the Variance Request. However, the monitoring well adjacent to the Koch tank farm in which
free-phase hydrocarbon was observed (MW-32) is located more than 100 feet downgradient from the area
of the Variance Request. The measurement of groundwater elevations during groundwater sampling
events have consistently demonstrated a groundwater gradient oriented in a west-southwest direction. We
therefore believe that the potential for the Koch plume to affect the Variance Request area is
infinitesimally low. Additionally, we know of no other plumes in the vicinity of the CITGO Products
Terminal or the Koch South Tenninal that have a reasonable potential for affecting the Variance Request
area. For these reasons, and the reasons stated in the previous paragraphs, we believe that it is both
reasonable and appropriate to limit the scope of the risk assessment to the dissolved hydrocarbon plume
that has emanated from the CITGO Products Terminal and which is affecting the area of the Variance
Request.
The second comment in your letter calls into question the areas of the CITGO Products Terminal
where air biosparging is being implemented, and the potential for re-contamination from the Koch plume.
These issues require some clarification. First of all, air biosparging has been implemented on the west side
of the CITGO Products Terminal, as well in the south/southwest portion of the site. These sparging wells
were placed on-line on May I 8, 1995. The attached figure shows the final locations of all of the sparging
wells that have been installed at the site. The operation of the sparging wells on the west side of the
CITGO property is expected to halt the migration of the dissolved hydrocarbon plume in this area of the
site, which will result in gradual restoration of groundwater quality within the Variance Request area
through natural attenuation mechanisms.
Second, the issue ofre-contamination from the Koch floating product plume needs to be restated.
The implementation of remedial technologies, such as air biosparging, within the area of the Variance
Request are potentially capable of achieving significant reductions in the concentrations of dissolved
hydrocarbons within this relatively small area. However, as this groundwater migrates downgradient and
encounters the Koch floating product plume, it will become re-contaminated. We do not contend that
constituents from the Koch plume would migrate upgradient to affect groundwater quality within the
Variance Request area if an air biosparging remedy was implemented (although it is likely that the
implementation of a pump-and-treat process in this area could locally reverse the natural groundwater
, gradient and thus draw constituents from the Koch plume into the Variance Request area). Nevertheless,
the fundamental point that we wish to emphasize is that the expenditure of significant financial resources
to remediate groundwater that poses an insignificant risk to human health and the environment does not
benefit the public interests and, therefore, is neither a productive nor appropriate response to this situation.
The existence of a larger hydrocarbon mass a short distance downgradient from the Variance Request
area, and the impact of this material on the quality of groundwater after it leaves Variance Request area,
provides additional evidence that an aggressive remedial response in this specific situation is not justified.
Mr. Kenneth Schuster, P.E.
January 30, 1996
Page 3
In response to the final comment in your letter, the groundwater quality data included in the Third
Quarter 1995 monitoring report and the April 1995 Variance Request document represents the extent of
groundwater data from the site that is currently available. The next sampling event at the site is scheduled
to take place in February 1996, and will include monitoring wells MW-22, 23, and 24. You will be added
to the distribution list for this report.
We believe that the information presented in the Variance Request and expanded upon in this letter
strongly supports the validity ofa variance from 15A NCAC 2L .0202 and .01060). The principal factors
that justify the issuance of a variance for this site include:
• the insignificant level of risk posed by the observed concentrations of
hydrocarbons, as demonstrated by a quantitative, site-specific risk assessment
performed using standard EPA methodology;
• the effect of the air biosparging corrective action system on the CITGO terminal
property, which will halt the further migration of hydrocarbons from the source
area, and which will facilitate the natural recovery of groundwater quality within
the area of the Variance Request;
• the presence of free-phase hydrocarbons adjacent to the Koch terminal tank farm,
downgradient from the Variance Request area; and
• the fact that an aggressive, engineered approach to groundwater remediation
within the Variance Request area would not achieve a greater degree of protection
to human health and the environment compared to a program based on natural
attenuation and regular groundwater monitoring.
We hope that this response answers the questions and clarifies the issues that have been raised in
your letter. However, in the event that questions remain, please contact Jim Schaeffer at [phone],
or me at [phone].
Sincerely,
REMEDIATION TECHNOLOGIES, INC.
/?{~~
Mark S. Westray
Senior Project Manager
Attachment: Figure 1 -Sparging Well Location Map
cc: David Klemm -S&ME, Spartenburg, SC
Bruce Reed -NCDEM Wilmington Regional Office
J.T. Schaeffer-Amoco Corporation, Atlanta, GA
T.W. Segar -Koch Industries, Inc., St. Paul, MN
..
Page 2
Amoco Oil Company
December 15, 1995
concerns from the Koch plume?
Groundwater Quality Data submitted as Table 3 with the third quarter 1995
monitoring report lists data for 8/23/90, 9/04/91, 6/16/93, 3/29/95, 8/24/95.
Is data available for the first two quarters of 1995 also and all four quarters
of the earlier years? If so, please submit a table with the data far the
additional quarters included for monitoring wells MW-22,23,and 24.
Please respond to the questions in this letter by January 31, 1996. If you
have any questions please call me at [phone].
cc: Preston Howard
Harlan Britt
Arthur Mouberry
Rick Shiver
Bruce Reed
David Hance
Sincerely,
X .3f±Q
Kenneth Schuster, P.E.
Regional Supervisor
Raleigh Regional Office
♦ We would suggest that either the second sentence of the third ·paragraph be deleted or re-
phrased, as it may be possible to treat the variance area via air sparging. This was addressed
in the most recent variance request. However, in our opinion, this may require treatment over
a long period of time because it may not be feasible to achieve a recommended radius of
influence beneath River Road or the CSX railroad. Both of these areas are within the proposed
variance area. Easements would be required to construct sparge wells in these areas, and
easements from CSX are reportedly very difficult to obtain. There is also an underground
paraxylene pipeline and buried fiber optic cable in the variance area. Is it appropriate to cleanup
this area when virtually no risk or public benefit will be gained, and groundwaters flowing
toward the Cape Fear River will become re-contaminated by a separate downgradient incident?
♦ The word "recovery" in the third paragraph should be changed to "sparge" or air-sparging.
♦ The last paragraph is good, but we believe Amoco will advise that ·this is all of the monitoring
data that they have reported. No scheduled monitoring was ever performed in regard to this
incident, and the off-site wells are relatively new compared to the on-site wells. WiRO's
emphasis with the applicant has been a completion of the groundwater assessment and the
submittal of a Corrective Action Plan.
We hope that these comments have been useful to you. If you have any questions concerning this
memo, please advise.
I
RSS/CFS/BAR
cc: Preston Howard
Arthur Mouberry
David Hance
WiRO-GWS
•
..
ATLANTIC DIVING & MARINE CONTRACTORS, INC.
3330 RIVER ROAD • WILMINGTON, NORTH CAROLINA 28412
September 13, 1995
Mr. David Hance
EHNR-DEM-Groundwater Section
P.O. Box 29535
Raleigh, North Carolina 27626-0535
RE: Request for Information Regarding the Status and Use of a Water Well at 3330
River Road
Dear Mr. Hance:
In response to your letter dated September 1, 1995 for information regarding the
Atlantic Diving & Marine Contractors, Inc. drinking source, the following applies.
As of 1993, Atlantic Diving & Marine Contractors, Inc. has been contracted with Indian
Springs [phone] to have bottled water in the office location at 3330 River Road.
The water well that is presently on the property is not used for consumption.
Enclosed please find last invoice to Atlantic Diving & Marine Contractors, Inc. from
Indian Springs Water Company
If additional information is needed, please do not hesitate to call.
Sincerely,
i\~il c:&\cU~
Mi 1hael Mccarley ·
Vice President
ATLANTIC DIVING & MARINE CONTRACTORS, INC.
Enclosure
[phone] • FAX [phone] • [phone] WHEELING, WV
NOTE: IMPORTANT!!!
09/12/95
TO: Ken Schuster
SUBJECT: Hearing Officer's Review of Citgo Products Terminal Variance Request and
DRAFT of Public Comment Summaries and Proceedings of the Hearing.
Here is the information to support the variance request for the Citgo Products Terminal
supplied by the Amoco Oil Company. In addition, I have supplied a DRAFT of the Summary
of Comments that were made at the hearing. No written comments, other than those provided
at the hearing, were received by the Groundwater Section on this issue. A DRAFT of the
information regarding public notices and list of attendees is also included in "The Proceedings
of the Hearing" for your review.
Upon receiving your review these documents stamped "DRAFT SUBJECT TO
REVISION", I will make any necessary corrections. You will recall that a hearing officers
review of the variance request for the Citgo Products Terminal is needed so that a hearing
officer's report and recommendation may be provided to the Envirorunental Management
Commission so that final action may be taken on this variance pursuant to 15A NCAC 2L
.0113. lfyou will need me to develop an initial draft of a hearing officer's report to help
facilitate the review process, please let me know. If you need to discuss this with me call
715-6189 between the hours of 9am to 6pm Monday thru Friday.
cc: Carl Bailey
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
September 1, 1995
Mr. Kevin Walker
Atlantic Diving and Marine Contractors
Incorporated
3330 River Road
Wilmington, NC 28412
Subject: Request for Information Regarding the Status and Use
of a Water Well at 3330 River Road.
Dear Mr. Walker:
You will recall that on August 3, 1995 you attended the public hearing to discuss a
proposed variance from Groundwater Quality Standards and Corrective Action in 15A
NCAC 2L for the Amoco Oil Company. Amoco Oil Company is the responsible party for
a site now owned by the Citgo Oil Company. At that public hearing the Groundwater
Section staff presented the results of groundwater monitoring and modeling of contaminant
levels and information on water uses near the Citgo Products Terminal. The information
in the variance request presented at the hearing showed that your company is using a water
well on your property for the purpose of a drinking water supply. A statement made at the
hearing by an employee of the Atlantic Diving and Marine Contractors Incorporated
indicated that the water well is no longer in use as a drinking water supply and that the
company is obtaining drinking water from another potable source.
Final decision-making authority for variances to the 15A NCAC 2L rules rests with
the Environmental Management Commission as shown in 15A NCAC 2L .0113(f). In order
to best assist the Commission in making a decision on this variance, the hearing record
needs to reflect the most updated information, including water use information. Please send
the Groundwater Section updated information on water use for the Atlantic Diving and
Marine Contractors Incorporated.
P.O. Box 29535 , Raleigh, North Carolina 27626-0535
An Equal Opportunity Affirmative Action Employer
Telephone [phone] FAX [phone]
50'I. recycled/ 10% post-consumer paper
If available, you may include a copy of the latest bill of sale for bottled water, a copy of
the company's contract with a bottled water supplier, a copy of a tax record or other
record showing that a new point-of-entry public water supply system has been installed, or
a well abandonment record showing that this water supply is no longer in use. If possible,
please send this material to the Groundwater Section by September 15, 1995. You may send
the available information to the following address:
David Hance
EHNR-DEM-Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Phone: [phone]
Fax: [phone]
Upon completion of the review of all comments and issues from the public hearing
and written comments received on this variance request, I will make a recommendation to
the Environmental Management Commission. Your assistance in this matter will help
facilitate final action on this request. As the hearing officer for this variance request and
on behalf of the Groundwater Section, your participation and cooperation are greatly
appreciated.
cc: Arthur Mouberry
David Hance
Sincerely Yours,
LM
Ken Schuster,
Division of Environmental
Management
Raleigh Regional Office
Howard Greenebaum
841 Settlers Lane
Kure Beach, NC 28449
August 3,1995
David Hance
Division of Environmental Management
Groundwater Section
PO BOX 29535
Raleigh, NC 27626-0535
Dear Mr. Hance,
Telephone [phone]
FAX [phone]
I wish to register my objection to AMOCO OIL CO.'S request to not pay
for the clean up of contamination left at their vacated facility on
River Road in Wilmington, North Carolina.
In 1951 when they built their asphalt products terminal on River Road
they possessed the knowledge that steel rusts. This is not a recent
discovery. Consequently they were aware that any steel container would
eventually leak its contents into the environment. They also possessed
the knowledge in 1951 that drinking water resided under the ground and
that wells were connected to that drinking water, and that any liquid
leaking from rusted containers would seep downward into that
groundwater. Since oil companies employ geologists they are also aware
that groundwater aquifers flow, that contaminated water does not sit
still and surrounding areas are at risk.
Their choice of not removing sources of future contamination were
deliberate, and based on the hope of non discovery of their actions.
AMOCO OIL COMPANY is one of the richest companies in the world and
certainly had then and has today the resources to clean up after their
spill& of dangerous materials.
At the school where my wife works is a teacher who lives in a house
that is the victim of another oil spill by another oil company. She
lives in Wrighsboro which is near Wilmington. Her family and her
neighbors have been exposed to contamination to their drinking water
from a spill from a leaking container of an oil product for many
years. They now are unable to drink water from their well, and their
house is unsaleable. Their health is an unknown quantity due to
exposure from this spill. This oil company has admitted its fault but
also has not as yet compensated the victims of its negligence.
North Carolina spends less on environmental regulation than all but 3
other states in the country. These lengthy spills have been undetected
because our elected officials have been collecting campaign
contributions from these polluting corporations' lobbyists, and as a
consequence, have not passed tough regulations on their contributors,
or voted for adequate · funding for the existing regulatory agencies to
enforce the existing laws.
•
North Carolina has suffered the losses of numerous shellfish areas to
closures because of contamination. Oil spill contamination can close
shellfish areas for years not months. We are looking at long term
damages to our environment if we do not force prompt clean ups, and
detect pollution sources earlier.
AMOCO'S contention that this contamination would eventually be reduced
naturally goes into conflict with all of today's knowledge. As we all
know oil is a product of a multi million year process. It just doesn't
go away. Several international studies have shown that long term
effects of oil spills can be devastating. One such study was made on
the Brittany coastline in the years after the AMOCO Cadiz spill !
Several species were altogether eliminated, and the animal numbers
were severely reduced.
Portions of an oil spill can spread over vast areas. Toxic components
may create chronic damage to life. The ecological damage is not
restricted to the sea. It does spread to the inhabitants on land.
The Cape Fear river is the source of drinking water for Wilmington. We
certainly do not want to see it any more polluted than it already is.
The shores of the river contain marshes and wetlands that are the
sources of life for the fish, birds,and animals that we North
Carolinians love. We certainly do not want to see their drinking water
poisoned. Remember, their water does not go through the Wilmington
water facility. They have to drink it untreated. They are at grave
risk from p ollution, and the lack of clean ups.
Asphaltlike material was discovered in California at the La Brea Tar
Pit by Spanish explorers in 1769 ! We do not know how long it had been
there before discovery. Asphalt has been used as a roofing material
since 1892. It is not a material that we can expect to just peacefully
disappear from nature without any damage.
I urge the DEM to force AMOCO to clean up its waste at once.
I also recommend that the DEM advise the public of the real conditions
of our waters, and to · present to the public their recommendations for
improvements to their agency so that they can better protect our
environment. Let us know how much better protection will cost us, and
how much limited protection is costing us today. It is time we stopped
treating clean water and clean air as luxuries that we can afford to
neglect.
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
~~-~ ~ ... -an n
D E HNR
August 28, 1995
Dear Groundwater Mail Recipient:
. On August 7, 1995 the Director of the Division of Environmental Management
estaolished an Interim Maximum Allowable Concentrations for Isopropyl Ether
{Diisopropyl Ether) in. Class GA and GSA Groundwaters in accordance with
requirements contained in 15A NCAC 2L .0202. The typical uses of this substance
is shown below:
1) lsopropyl Ether {Diisopropyl Ether) -lsopropyl ether is a colorless, volatile liquid used as
a solvent for animal oils, vegetable oils, mineral oils, waxes, and resins. It is also used as
a solvent for dyes. In addition, isopropyl ether may be used as a paint or varnish remover,
as a component in rubber cement, or for the extraction of acetic acid from aqueous
solutions.
Attached is the public notice showing the Interim Maximum Allowable
Concentration with other important information. If you need additional
information please contact Mr. David Hance at 733-3221 (extension 428).
Attachment
cc: Arthur Mouberry
David Hance
Sincerely yours,
~~-~~
M. Carl Ba~{~y ,¥.,
Assistant Chief for
Planning,
Groundwater Section
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
Public Hearing Regisfrati.<;>n Form
(Legibly print. please!) /
Hearing 'fm.......,_.. /4,wc ., k~ ~= ,t=-f--oate ?'/3/ts-
Please furnish the information requested below and indicate whether you wish to be heard during this
public hearing. This Information is necessary in order that you be given an opportunity to speak and so
that your name and affiliation will be correctly entered In the hearing record. ·
Name /??A,,,,/( M .s~v Title Sr. fte,/e,::.;l er-~ r e.-I V d
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fX Do you wish to be rieard? If your presentation will exceed three minutes, please submit
three copies of your statement to the hearing clerk along with this registration form.
k_ Do you wish to receive a copy of regulations, if any. resulting from this hearing?
Division of Environmental Mancgement.
North Carolina Department of Environment. Health. end Natural Resources
;C Hearing Registration Form
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Hearing F.2c,,.,rA ,,,, «, A '{?h, / f 7;c,,,. ,-~ I Vvr,; n" /4'11 •" 1 { Date ....::'lf")c+j;--r~ ............. .C-----
Please furnish the information requested below and indicate whether you wish to be heard during this
public hearing. This Information is necessary In order that you be given an opportunity to speak and so
that your n~me and ?flillatian will be correctly entered In the hearing record ~ •
Name j, •x\ S,,~& ~kr Title ~e~&o,.., &:"t>dorJr
Employer/Representing -----'IJ'---'-',01'--"-'...,,()C....:{_:::..,,O.,__Cii.,,.....,:"'-:'>,:-,,,.+f'.!.b--'-:i--"'-"=-+,="'=a '-'-"-----------------
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Do you wish to be heard? If your presentation will exceed three minutes, please submit
three copies of your statement to the hearing clerk along with this registration form.
Do you wish to receive a copy of regulations, If any, resulting from this hearing?
Division of Environmental Management,
North Carolina Department of Environment, Health, and Natural Resources
Pu c Hearing Registration Form
(Legibly print. please!)
Hearing --=-d-________:_l-_ ___.,!~-----'--'--M---'--'o:::......,;::c..::.....;D=----------Date ~ { 3 l 9 S---
Please furnish the information requested below and Indicate whether you wish to be heard during this
public hearing. This Information Is necessary In order that you be given on opportunity to speak and so
that your name and affiliation will be correctly entered In the hearing record.
Name ]3(<... l 6-lb SHe..~v\r\A f'-:) Title E,-.JVI (<.., Ce;. O~b 1 ~t\:-TO~
Employer/Representing __ c_ __ l_l _G. __ O __________________ _
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City and State S f\\/ A N t-::>f\ ~ 1 &k
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Zip Code S ( Y O l
✓
v Do you wish to be heard? If your presentation will exceed three minutes, please submit
three copies of your statement to the hearing clerk along with this registration form.
--Do you wish to receive a copy of regulations. If any. resulting from this hearing?
Division of Environmental Management.
North Carolina Department of Environment. Health, and Natural Resources
F. c Hearing Registration Form
cJlL-A1vi.oc.u (Legiblyprint.please!)
Hearing ___:,,_V_:,_rtfl-"---{_:,_A-_10_(-=(_~_.!,_fo_r2._-=G~(<,=-=o=~~l,.,:,,,_~ ____ Date ~ < 3 , (7 ~ < 8' I
Please furnish the Information requested below and Indicate whether you wish to be heard during this
public hearing. This Information is necessary In order that you be given an opportunity to speak and so
that your name and affiliation will be correctly entered In the hearing record.
Name <{:t v I LJ ~l K,.t:t2-TIiie _______ _
Employer/Representing ~ 8 ,vi-1 L -Pc V 1.0 G
Mailing Address --S 3 ~ {< \ u £. e_ 8-o ~D
City and State _CP __ , _L_~_, _"'_Cl,::,,.,.,.,:_T2>_~ _ __,fj'--"-( _. _L __ Zip Code _2E_~_Y_( _L--_-__
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~ Do you wish to be heard? If your presentation will exceed three minutes, please submit
three copies of your statement to the hearing clerk along with this registration form.
~ Do you wish to receive a copy of regulations, If any, resulting from this hearing?
Division of Environmental Management.
North Carolina Department of Environment, Health. and Natural Resources
Public Hearing Registration Form
(Legibly print, please!)
Hearing __ .:2. __ '--__ yq_~ __ -o_c.._~ _____________ Date __ [f_·_'3_-_1_S" ___ _
Please furnish the information requested below and indicate whether you wish to be heard during this
public hearing. This Information is necessary In order that you be given an opportunity to speak and so
that your name and affiliation wlll be correctly entered In the hearing record.
Name /-1-1 1 -e. rJ ,'1 C?4l-Title Te v ~ -yY"'-0 iL · --------------------
Employer/Representing __ C_l_\_l,_o _____________________ _
Moiling Address • 3 's 4 S R \ '-.l G-rl. IC D
City and State _U-J_· _~_L_"r---_,_,,_._\.,_, -\--u---'--_.-.J_--+-i _r,...J __ c._~ __ Zip Code __ 2..._i_-__,_l/_-_1_2---__ _
Yas blQ
/ Do you wish to be heard? If your presentation will exceed three minutes, please submit
three copies of your statement to the hearing clerk along with this registration form .
./ _ Do you wish to receive a copy of regulations. If any, resulting from this hearing?
Division of Environmental Management,
North Carolina Department of Environment, Health, and I\ ral Resources
NOTICE OF VARIANCE APPLICATION AND .HEARING
· DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL
RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
Notice is hereby gtven of a variance application and public hearing to be held by the
Department of Environment, Health and Natural Resources on behalf of the Environmental
Management Commission. The hearing concerns a request for a variance from the Groundwater
Quality Standards of 15A NCAC 2L .0202 and the Corrective Action requirements of 15A NCAC
2L .0106 (j) for the Citgo Products Terminal in Wilmington, North Carolina. The variance
application was received for review by the Department on August 25, 1994 from the Amoco Oil
Company, 375 Northridge Road, Suite 350, Atlanta, Georgia, 30350-3296. Prior to April 30, 1993
the Amoco Oil Company was the owner of the tank terminal for which the variance ls requested
and is responsible for cleanup of this release.
The property where the release of petroleum product bas OCCUITed Is located as follows: Enter the
City of Wilmington from Interstate 40 and take U.S. 17-74 toward the U.S.S. North Carolina
Battleship Memorial. Turn south onto U.S. 421 and turn west onto Shipyard Boulevard toward the
States Ports Authority and then turn south onto River Road. The Citgo Products Terminal is mile
on the left hand side of River Road at a distance of approximately one-half mile.
The Amoco Oil Company requests that the Environmental Management Commission grant
this variance so that it does the following:
( 1) Allow concentrations of Benzene, Toluene, Ethylbenzene, Xylenes (BTEX),
Naphthalene, Fluorene, Anthracene, Benzo(a)anthracene, Phenanthrene, and Lead to
remain at levels above 15A . NCAC 2L .0202 standards as analyzed on December 12,
1994. These concentrations will be allowed to remain within an area consisting of
properties owned by the American Crane Corporation, the Citgo Products Terminal, and
the Koch Refining Company South Terminal. Right-of-ways exist within these properties
for the North Carolina Department of Transportation and CSX Transportation. The
Citgo Products Terminal, the area proposed for a variance, and all adjacent properties
are zoned by the City of Wilmington as "HM -Heavy Industrial District".
In 1951 Amoco Oil Company constructed an asphalt products terminal at this
location. Due to routine loading and storage activities releases of petroleum products
occurred at the terminal over a number of years. In July 1988 the company conducted
a site assessment of soils and· groundwater at the facility. In 1989 the Department
required that the Amoco Oil Company conduct a Comprehensive Site Assessment. The
Citgo Oil Company acquired this terminal from the Amoco Oil Company on April 30,
1993. Pursuant to investigative activities to complete a Comprehensive Site
Assessment, the Amoco Oil Company found petroleum hydrocarbons and lead in
groundwaters on adjacent properties to the west of the terminal on March 31, 1994. On
April 12, 1994 the Division of Environmental Management concurred with the Amoco
Oil Company that the source of groundwater contamination _had been adequately
assessed and that the Comprehensive Site Assessment was complete. On August 25, 1994 •
the Amoco Oil Company requested this variance in accordance with l SA NCAC 2L
.0113(a) and (b).
Analysis of groundwater samples from monitoring wells within the area of the
proposed variance have demonstrated a progressive decrease in BTEX concentrations
since August 19, 1994. No increases in groundwater concentrations for Anthracene,
Benzo(a)anthracene, Fluorene, Lead, Naphthalene, and Phenanthrene have been reported
since that time. During the last semi-annual groundwater analysis one well showed
Benzene at approximately 0.010 milligrams/Liter and Ethylbenzene at 0.340
milligrams/Liter. The 1 SA NCAC 2L .0202 Groundwater Quality Standards allow a
maximum of 0.001 milligrams/liter for Benzene and 0.029 milligrams/liter for
Ethylbenzene. The company has conducted a health-risk assessment and have
demonstrated through environmental modeling and calculations that the risks to public
health and safety from granting a variance for this location are minimal. Computer
modeling does not indicate contaminant will exceed the 15A NCAC 2B .0200 Water
Quality Standards when migrating groundwaters discharge into the Class SC Tidal
Surface Water of the Cape Fear River. .
Six water supply wells exist within a 1/2 mile radius of the Citgo ·Products
Terminal. Five of these water supply wells are used to provide industrial process water
and are not used for drinking. Orily Atlantic Marine Incorporated uses a well for
drinking. This water supply well was constructed in the Castle Hayne Aquifer, is
approximately 700 feet from the area proposed for variance, and is located "cross-
gradient" from the direction of groundwater flow. The Amoco Oil Company does not
believe that this variance will effect the water supply well owned by Atlantic Marine
Incorporated. There are no other known public or private water supply wells within a 1/2
mile radius of this location. The City of Wilmington Engineering Department has
confirmed that underground water supply utility lines are set at a depth too shallow to
be impacted by granting this variance.
2) Allow for the restoration of groundwater without requiring remedial actions
in accordance with 15A NCAC 2L .0106(j). The Amoco Oil Company has demonstrated
that requirements of the groundwater rules cannot be achieved by using best available
technology (BAT). Cleanup using best available technology would require pumping the
groundwaters from beneath the land, treating these groundwaters to remove
contaminants, and returning the treated water. Another kind of best available
technology relies on the introduction of air into the subsurface to stimulate the growth
of naturally occurring microorganisms that breakdown petroleum hydrocarbons. The
Amoco Oil Company believes that using technology that relies on pumping groundwaters
or the introduction of air will not effectively reduce concentrations of petrolewn
hydrocarbons and lead due to the presence of adjacent plumes of contaminated
groundwater on nearby properties.
There is an area of groundwater contamination to the west of the Citgo
Products Terminal. This plume of contaminated groundwater was identified as a release
of gasoline and lead from the Koch Refining Company South Terminal. Another area
approximately 100 feet to the south and east of this location has a separate plume of
groundwater contaminated with petroleum hydrocarbons. These unassociated areas of
groundwater contamination have much higher concentrations of petroleum hydrocarbons
than the area of contamination from the Citgo Products Terminal. The company believes
that re-contamination of the groundwaters within the area of the proposed variance will
likely result if a best available technology is relied on as a cleanup option.
The Amoco Oil Company has estimated that the total costs of implementing
best available technologies to cleanup this area ranges from $ 294,000 dollars to $
3,100,000. The company believes that if cleanup using best available technology is
implemented a serious financial impact would be incurred without equal or greater
public benefit.
Amoco Oil Company maintains that conditions exist within the area proposed
for a variance that will allow for the natural processes of dilution, filtration, chemical
transformation, and biodegradation to eventually reduce levels of these contaminants
below the Groundwater Quality Standards of ISA NCAC 2L .0202. Groundwater
monitoring will continue to be required by the Division of Environmental Management
if this variance is granted. On February 6, 1995 the Wilmington Regional Office
confirmed that other known sources of groundwater contamination around the location
proposed for a variance have been assessed and are being remedlated under separate
regulatory actions.
The bearing will be held as follows:
MLMINGTON
August 3, 1995
7:00 PM
Cape Fear Community College
411 North Front Street
Auditorium
Oral Comments may be made during the hearing, or written statements may be
submitted to the agency by September 4, 1995. Written copies of oral statements exceeding three
minutes are requested. Oral statements may be limited at the discretion of the hearing officers.
Please forward comments or information requests to:
David Hance
EHNR-DEM-Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Phone: [phone]
Fax: [phone]
I
This proposed variance request is available for public Inspection at the locations listed j
below. Copies may be obtained at each location for a charge of ten cents per page.
' !
I
A. Preston Howard, J ., P.E.
Director, Division of Environmental
Management
Dept. of Environment, Health and Natural Resources
Div. of Env. Management
512 North Salisbury Street
Archdale Building, P.O. Box 29535
Raleigh, NC 27626-0535
[phone]
Dept. of Environment, Health and Natural Resources
Div. of Env. Management
Wilmington Regional Office
127 Cardinal Drive
Wilmington, NC
[phone]
27609
James B. Hunt, Jr., Governor NA Jonathan B. Howes, Secretary
DEHNA
North Carolina
Department of Environment, Health, and Natural Resources
Release: IMMEDIATE
Date: July 27. 1995
Contact: Don Reuter, PIO, 919/733-7015
Distribution: Targeted
DEM TO CONDUCT PUBLIC HEARING ON VARIANCE REQUEST
RALEIGH -,. The N.C. Division of Environmental Management will conduct a public
hearing August 3 in Wilmington to receive comments on an oil company's variance request
from groundwater quality standards and corrective action requirements. The hearing will be
held at 7 p.m. in the Cape Fear Community College Auditorium, 411 Front Street.
In 1951, Amoco Oil Company constructed an asphalt products terminal on River Road
in Wilmington. Petroleum products were released at the facility during loading and storage
activities over a number of years. Citgo Oil Company acquired the terminal, now known as
the Citgo Products Terminal, from Amoco Oil Company on April 30, 1993. Since Amoco
was the owner at the time of the releases, it is responsible for the cleanup. Amoco has
requested the variance.
Oral comments may be made at the hearing, or written statements may be submitted to
the Division of Environmental Management (DEM) prior to September 4, 1995. Comments
or information requests should be forwarded to David Hance, DEM Groundwater Section.
P.O. Box 29535, Raleigh, N.C. 27626-0535.
Public Affairs Office
P.O. Box 27687, Raleigh, N. C. 27611
[phone]. -FAX# [phone]
# # #
An Equal Opportunity / Affirmative Action Employer
Debbie Crane
Director, Office of Public Affairs
J~~s B. Hunt, Jr., Governor · NA Jonathan B. Howes, Secretary
►
DEHNR
North Carolina
Department of Environment, Health, and Natural Resources
Release: IMMEDIATE
Date: July 27, 1995
Contact: Don Reuter, PIO, 919/733-7015
Distribution: Targeted
DEM TO CONDUCT PUBLIC HEARING ON VARIANCE REOUEST
RALEIGH -,. The N.C. Division of Environmental Management will conduct a public
. hearing August 3 in Wilmington to receive comments on an oil company's variance request
from groundwater quality standards and corrective action requirements. The hearing will be
held at 7 p.m. in the Cape Fear Community College Auditorium, 411 Front Street.
·. In 1951, Amoco Oil Company constructed an asphalt products terminal on River Road
in Wilmington. Petroleum products were released at the facility during loading and storage
activities over a number of years. Citgo Oil Company acquired the termirtal, now known as
the Citgo Products Terminal, from Amoco Oil Company on April 30, 1993. Since Amoco
was the owner at the time of the releases, it is responsible for the cleanup. Amoco has
requested the variance.
Oral comments may be made at the hearing, or written statements may be submitted to
the Division of Environmental Management (DEM) prior to September 4, 1995. Comments
or information requests should be forwarded to David Hance, DEM Groundwater Section.
P.O. Box 29535, Raleigh, N.C. 27626-0535.
Public Affairs Office
P.O. Box 27687, Raleigh, N. C. 27611
[phone]. -FAX# [phone]
# # #
An Equal Opportunity / Affirmative Action Employer
Debbie Crane
Director, Office of Public Affairs
Public Hearing-Variance Request
Variance to 15A NCAC 2L .0202 and 15A NCAC 2L .0106(j)
Citgo Products Terntlnal, Wilmington, North Carolina
HEARING LOCATED AT:
Cape Fear Community College
411 North Front Street
Wilmington, NC
August 3, 1995 (7:00 PM)~
HEARING OFFICER'S SPEECH
HEARING OFFICER: Ken Schuster, Division of Environmental Management
Regional Supervisor (Raleigh Regional Office)
8:ll.1M8C@Omt'.;mtt GOOD EVENING, I WOULD LIKE TO CALL THIS -.-.-.-.-.... -•-.·•··· .. ·· .. ., .............................. ;. ...
PUBLIC HEARING TO ORDER. MY NAME IS KEN SCHUSTER, AND I AM THE
DIVISION OF ENVIRONMENTAL MANAGEMENT'S REGIONAL SUPERVISOR IN
THE RALEIGH REGIONAL OFFICE. I HA VE BEEN DESIGNATED HEARING
OFFICER FOR THIS EVENING'S HEARING.
THIS HEARING IS BEING HELD PURSUANT TO NORTH CAROLINA
GENERAL STATUTE 150B-21.2. IN ACCORDANCE WITH THE GE_NERAL
STATUTES, A PUBLIC NOTICE OF THIS HEARING WAS PUBLISHED IN
CONFORMITY WITH 15A NCAC 2L .0113 OF THE GROUNDWATER RULES
AND GENERAL NOTICE HAS BEEN GIVEN IN LOCAL PAPERS ACCORDING
1
TO PROCEDURES IN 15A NCAC 2L .0113(e)(l). NOTICES WERE ALSO
DISTRIBUTED TO THE PUBLIC AT LARGE, LOCAL GOVERNMENT OFFICIALS,
AND PROPERTY HOLDERS WITHIN AND NEAR THE AREA OF THE
PROPOSED VARIANCE.
THE PURPOSE OF THIS HEARING IS TO OBTAIN PUBLIC COMMENT AND
PARTICIPATION IN THE CONSIDERATION OF THE VARIANCE REQUEST FOR
THE AMOCO OIL COMPANY OF ATLANTA, GEORGIA. THE AMOCO OIL
COMPANY IS REQUESTING THIS VARIANCE FROM RULES CONTAINED IN
15A NCAC 2L GROUNDWATER CLASSIFICATION AND STANDARDS FOR THE
CITGO PRODUCTS TERMINAL. THE AMOCO OIL COMPANY WAS THE
PREVIOUS OWNER OF THE TANK TERMINAL FOR WHICH THIS VARIANCE
HAS BEEN REQUESTED AND IS RESPONSIBLE FOR CLEANUP OF THIS
RELEASE OF PETROLEUM PRODUCTS. THIS PROPOSED VARIANCE WILL
APPLY ONLY TO AN AREA CONSISTING OF PORTIONS OF PROPERTIES
OWNED BY THREE PROPERTY OWNERS. THESE PROPERTY OWNERS ARE
THE AMERICAN CRANE CORPORATION, THE CITGO PRODUCTS TERMINAL,
AND THE KOCH REFINING COMPANY SOUTH TERMINAL. RIGHT-OF-WAYS
FOR THE NORTH CAROLINA DEPARTMENT OF TRANSPORTATION AND THE
CSX TRANSPORTATION COMPANY TRANSECT THE .AREA FOR WHICH THE
VARIANCE IS REQUESTED. THE AMOCO OIL COMPANY ESTIMATES THE
2
TOTAL AREA · OF LAND FOR WHICH THIS VARIANCE IS REQUESTED IS
APPROXIMATELY 90,500 SQUARE FEET OR 2.0 ACRES.
IN THE SUPPORTING INFORMATION SUBMITTED IN THIS VARIANCE
REQUEST, THE AMOCO OIL COMPANY INFORMED THE DIVISION THAT THE
AREA PROPOSED FOR A VARIANCE AND ALL ADJACENT PROPERTIES ARE
ZONED BY THE CITY OF WILMINGTON AS "HM -HEAVY INDUSTRIAL
DISTRICT".
THE APPLICANT PROPOSES TO ALLOW THOSE CONCENTRATIONS OF
BENZENE, TOLUENE, ETHYLBENZENE AND XYLENES, NAPHTHALENE,
FLUORENE,ANTHRACENE, BENZO(A)ANTHRACENE,PHENANTHRENE, AND
LEAD TO REMAIN AT LEVELS AS FOUND DURING THE DECEMBER 12, 1994
GROUNDWATER ANALYSIS, WITHIN THE BOUNDARIES OF THE AREA
PROPOSED FOR THE VARIANCE. THE AMOCO OIL COMPANY ALSO
PROPOSES THAT CORRECTIVE ACTIONS REQUIRING THE APPLICATION OF
BEST AVAILABLE TECHNOLOGY IN 15A NCAC 2L .0106 (j) NOT BE APPLIED
TO THE AREA WITHIN THE BOUNDARIES OF THE PROPOSED VARIANCE.
THE AMOCO OIL COMPANY BELIEVES THAT, DUE TO THE PRESENCE OF
PLUMES OF PETROLEUM CONTAMINATED GROUNDWATER ADJACENT TO
THE SITE PROPOSED FOR A VARIANCE FROM OTHER SOURCES, IT IS
UNLIKELY THAT BEST AVAILABLE TECHNOLOGY WILL PROVIDE ANY
3
LONG-TERM EFFECTIVE GROUNDWATER CLEANUP. THFSE DISTINCT
SOURCES OF GROUNDWATER CONTAMINATION HAVE MUCH HIGHER
CONCENTRATIONS OF PETROLEUM HYDROCARBONS. THE COMPANY
BELIEVES THAT APPLICATION OF BEST AVAILABLE TECHNOLOGY AT THIS
LOCATION IS A SEmous FINANCIAL IMPACT WITHOUT EQUAL OR
GREATER PUBLIC BENEFIT. THE AMOCO OIL . COMPANY ALSO ASSERTS
THAT CONDITIONS WITHIN THE SUBSURFACE OF THE AREA PROPOSED
FOR THIS VARIANCE WILL ALLOW FOR THE NATURAL PROCESSES OF
DILUTION, FILTRATION, CHEMICAL TRANSFORMATION, AND
BIODEGRADATION TO EVENTUALLY REDUCE CONTAMINANT LEVELS
BELOW GROUNDWATER QUALITY STANDARDS IN 15A NCAC 2L .0202.
THIS HEARING WILL CONFORM TO PROCEDURES IN 15A NCAC 2L
.0113. ADDITIONAL COPIES OF THE NOTICE OF VARIANCE APPLICATION
AND HEARING ARE LOCATED IN THIS BUILDING AND ARE AVAILABLE FOR
PUBLIC REVIEW.
A WRITTEN RECORD OF THIS HEARING WILL BE PREPARED WHICH
WILL INCLUDE ALL THE RELEVANT COMMENTS, QUESTIONS, AND
DISCUSSIONS. FOR THIS REASON, THE HEARING IS BEING TAPE
RECORDED. WRITTEN COMMENTS RECEIVED THROUGH SEPTEMBER 4,
4
1995 WILL ALSO BE INCLUDED IN THE RECORD. BASED ON THESE PUBLIC
COMMENTS AND ON ANALYSIS BY THE GROUNDWATER STAFF, I WILL
MAKE A RECOMMENDATION TO THE ENVIRONMENTAL MANAGEMENT
COMMISSION. IN MAKING THE FINAL DECISION, THE ENVIRONMENTAL
MANAGEMENT COMMISSION CONSIDERS THE WRITTEN RECORD, THE
RECOMMENDATION OF THE HEARING OFFICER, THE RECOMMENDATIONS
OF DIVISION STAFF, AND THE CONCERNS OF ITS MEMBERS. THE
COMMISSION MUST ALSO CONSIDER WHETHER THE APPLICANT HAS
COMPLIED WITH 15A NCAC 2L .0113(g).
IF THE APPLICANT DECIDES THAT THE COMMISSION'S DECISION IS
UNACCEPTABLE, A PETITION MAY BE FILED ACCORDING TO PROCEDURES
IN 15A NCAC 2L .0113(h). THE DECISION ON THE VARIANCE BY THE
ENVIRONMENTAL MANAGEMENT COMMISSION IS FINAL AND BINDING
ACCORDING TO THE CONDITIONS SHOWN IN 15A NCAC 2L .0113(h).
AT THIS TIME I WOULD LIKE TO RECOGNIZE (names of local and state
officials) AND THANK YOU FOR ATTENDING THIS HEARING. I WOULD ALSO
LIKE TO RECOGNIZE THE FOLLOWING PEOPLE FROM THE DMSION OF
ENVIRONMENT AL MANAGEMENT (DEM central office and DEM regional office
personnel).
5
MR.(staff speaker) OF THE DIVISION OF ENVIRONMENTAL MANAGEMENT-
GROUNDWATER SECTION'S WILMINGTON REGIONAL OFFICE WILL NOW
SUMMARIZE THE PROPOSED VARIANCE WHICH IS THE SUBJECT OF THIS
HEARING.
STAFF SPEAKER: (sblff speaker summarizes variance request).
!~!!~:I~!!!!~!· THANK YOU. WE WILL NOW ACCEPT PUBLIC
COMMENT ON THE PROPOSED VARIANCE. I WOULD LIKE TO REQUEST
THAT EVERYONE FILL OUT A REGISTRATION FORM. AFTER ALL
REGISTERED SPEAKERS HAVE HAD AN OPPORTUNITY TO COMMENT, I
WILL ALLOW ADDITIONAL SPEAKERS AS TIME PERMITS. WHEN YOUR
NAME IS CALLED, PLEASE COME UP TO THE MICROPHONE AND STATE
YOUR NAME AND AFFILIATION. ALL COMMENTS SHOULD BE LIMITED TO
MATTERS THAT ARE RELATIVE TO THE PROPOSED ADOPTION OF THIS
VARIANCE. IF YOUR COMMENTS ARE LONGER THAN THREE MINUTES, I
WOULD LIKE TO REQUEST THAT THEY BE SUBMITTED IN WRITING. I
RESERVE THE RIGHT TO QUESTION SPEAKERS IF THE NEED SHOULD ARISE.
6
DMSION OF ENVIRONMENTAL MANAGEMENT STAFF WILL BE AVAILABLE
TO ANSWER YOUR QUESTIONS IF NECESSARY. I WOULD NOW LIKE TO
CALL [first speaker].
[speakers. •• ]
(the hearing officer, ieferring to THE REGISTRATION CARDS. calls each speaker
to the microphone in tum )
Q~~~'1\!¥1.~~'.J.M THANK YOU [last speaker]. ARE THERE ANY
ADDITIONAL COMMENTS? SINCE THERE ARE NO MORE COMMENTS, I
DECLARE THE HEARING CLOSED. THE HEARING RECORD WILL REMAIN
OPEN UNTIL MIDNIGHT (12:00 AM) ON SEPTEMBER 4, 1995. ANYONE
WISHING TO SUBMIT WRITTEN COMMENTS MAY DO SO UP TO THAT DATE.
AFTER WHICH TIME, THE COMMENTS WILL BE MADE PART OF THE PUBLIC
RECORD AND I SHALL MAKE MY RECOMMENDATION TO THE
ENVIRONMENTAL MANAGEMENT COMMISSION. IT IS THE DESIRE OF THE
COMMISSION TO ALWAYS ACT IN THE BEST POSSIBLE INTEREST OF THE
PUBLIC. THEREFORE, PUBLIC PARTICIPATION IS A VERY IMPORTANT
PART OF THE VARIANCE EVALUATION PROCESS. WE WOULD LIKE TO
THANK YOU FOR ATTENDING THE HEARING AND OFFERING YOUR
COMMENTS.
7
DIRECTIONS TO VARIANCE
HEARING FOR THE CITGO
PRODUCTS TERMINAL
FROM RALEIGH, NO:
Take Interstate 1-40 into Wilmington, NC. Get on US 74-17 (Market Street) and
proceed east into town. Continue on Market Street as it becomes US 17(Busine~). Tum
right (north) onto Front Street and go five blocks to Red Cross Street and tum left; then
tum into Cape Fear Community College (CFCC). The Auditorium is located in the
South Wing of the School. You may reach David Hance at 93-3221 extension 428 to
discuss these direction prior to August 3, 1995. The contact person for the CFCC is Ms.
Linda Flowers 910-251-5100 and is at work until 4:00 pm.
(MAPS ARE ATTACHED)
NOTE: 07/19/95
TO: Ken Schuster,
SUBJECT: Information to help you make corrections to the Citgo
Products Terminal Hearing Officer's speech and a
"sample" hearing officers report.
Here is the "Benson T-Mart" hearing officers report for you
to examine as a format you may wish to consider using for the
Citgo Products Terminal Variance request.
In order to address you question about the "area of the
proposed variance" for the Citgo Products Terminal, this
introduction and maps have been supplied to help you visualize
the properties included in this request. Mr. Bruce Reid has
informed me that he will be the staff presenter for the
Wilmington Regional Office and will provide more detailed
information about the variance request at the hearing. An Amoco
Oil Company representative has also informed me that he will
attend the hearing.
I hope this helps you make any necessary corrections to the
hearing officers speech I sent you last week and to give you a
more clearer understanding. Once you are satisfied with the
speech, a final draft will be sent to you with directions to the
Cape Fear Community College. If you need to discuss this, please
feel free to call me at 733-3221 ext. 428. See you at the
hearing on August 3, 1995.
David Hance
cc: Carl Bailey
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OCF-5
7/1/95 -
Vendor Number:
Vendor Name:
Vendor Address :
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL RESOURCES
CASH DISBURSEMEN1:S.CODE SHEET
Shaded fields (i.e., Terms Code, SAS Item No., & 1099 Code) will be completed by the Controller's Office
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re-amtaminatlall ril the irroundwaten within the •-of ihe pro-l"'!'lc! varlence will likely nnlt If a beet available lechnoloa 18
relied OD -• deanup option.
The Amoco Oil Comj!lliy baa ettlmated that the total coata of
hnplementlnlr beat avallatile tec:lmololriea to deanup this a.. ran,e
froin S294 ,00!I dollan to 13,100,000. "'nle CIIIIIJIIIDJ' bellevea that if
ileanUJI IISiq but available tec1mo1:r.,:.1 illipleiaanted a NriOIII
~~• impact-aid be inr:uned wi t equal or peatar ~
Amoco Oil Companymaintainl thatcondltlonlellilt within the
area~ for a Y■riance that will allow for the natural~ =~.:::~1~:=:i=.r~==i.-C~~
....... Quality lltandardl of lllA NCAC 2L .0202. Grounclwaw • ':w will continue co be required by the Diviaion of Emiinm•
• 1.......,...tifW.,,.;ancai,ll'l!Dted. OnF~&.11191l 1..,.. . ....mibl'On RaalonaJ Offlce amftniiad that otber lmon IOU-
• Iii' ai,,unclwater cmiwnination 8l'Olllld the lacatian F.OJIGl!lld f'or a
variance haft been a--i and an being remedlatid iincler aepa.
rate re,ulatory iu:tiolw.
The heuta, will be beld • filllowa:
WILMINGTON
Au,u11t 3, 19911
7:00 P.M.
Cape Faar Co-unl~le,e ·
411 North Front
Auditorium
Oral CGllllDelllll may be made duriq the llearlna., or writttln
.natemenle may b9 aubmltt.ed to the Bl9!lCY by Septeaiber •• 11196.
Written -~ of o7'al atatemenle ueeediq tnree mlnut.ea an re-
queated, Oral lltalllmmtl may be limited at the dilcration of the
heari• offl-■.
Pleue &nr81,eommmte or information n,queala ~:
EJINR.D~~~ter Sedion
P.O. Boa 291135 ~(:p.,,2~~
Fu: 19191 716-0588
Thi,~~ Nq1Ulat 18 available for public lnapec-
tlon at the lai:aticm lilted below. Copiea may be ablalned at each
location for a charp of ten centl per pej!e.
A. Pre.ton Howard, Ir., P.E.
Dlnctor
Dlvllion of
Envlnmmentll MBJ18111mml
DeD■rtmmt of EnYironment,
Hea1th and Natural Reeaun:m
Dlviilon of Envinm-ntll Mn-,,t
512 North Saliabun' Strwf
Ardldala Buildi"' P.O.Boa:29&36 ·
Ralelah. NC 2782fl..0536
(~191 733-3221
Deiarlment of EllYlrollDIIDI,
Jfaaltb and Natural a-u-
Divlalaa of Environment,,! Man ■pment
WI~~~
Wilmillllton. NC 9MOII
!11111JS95-SIIOO
;-n~entrationa 01 P.9U-U1 .. .,._ -., . nation from the Citgo Producta Terminal. Tne wu.~--, _. re-contamination ,if' the groundwaten within the area of the pro-poeed variance will likely ""'111 if a beat available technology is relil'd on as a clean1111 option. To. Amoco Oil Company has estimated that the total coats of i111pl,menting beat available technologi_eo to cleanup thi1 area ranp from $2!M.OOO dollan to $3. 100,000. The company believes that If cleanup using beat available technology la implemented a aerioua
finsnc1al impact would be incurred without equal or greater public
lx-nefit.
Amoco Oil CompaDY maintains that conditiona exist within the
area propoeecl for a variance that will allow for the natural proceNft
of d1 lution. filtration. chemical tranafonnation, and biodeg?adation
to eve-ntuallr. reduce levela of theoe contaminants below the Ground-
walP• Quahtr, Standarda of 15A NCAC 2L .0202. Groundwater
' ·ng will continue to be required by the Division of Environ-
4ana,ement ifthit variance ia granted. On February 6, 1996
~ -'lf • .,mington Regional Office confirmed that other known aourcea
' of g,-,,undwater contamination around the location pl'Op018d for a
variance have been aaaeued and are being remediated under aep&•
rate regi,latory actiona.
The hnrlllf will be held aa follows:
WJUIINGTON
A11111at 3, 1996
7:00 P.M.
Ca":i~°N~~~~~~lege
Auditorium
Oral comments may be made during the hearing or written
statements may be tubmitted to the apney by Septemi,,;r 4, 1995 .
Written copiee of oral statements Hceeding three minutes are re-
gueoted . Oral statements may be limited al the diacretion of the
heari1111 officen.
Plnae forw■;.commenta or information requeeta to:
Da,-id Hance
EHNR-DEM-Groundwater Section
P.O . Boll 29635
Raleigh. NC 27626-0535
Phone: t!H9l 733-3221
Fu: 1919• 715-0588
This proposed vanance requeet ia available for public inapec-
tion al the location liated below. C<>1>iee may be obtained at each
location for a charge of ten cents per paile ,
A. Pre.ton Howard, Jr., P.E.
Director
Division of
Environmental Manapment
o.i,a,tment of Environment,
Health and Natural Reeourcee
Dhialon of EnY!ronmental Manapment
612 '1~rth Saliabury Street
An:hdale Building
P .O. Bos 29535
Ral~lgh, NC 27626-0535
1919) ;33-3221
Dei,ertmeot of Envirnnment.
HP8lth and Natural Reeourcee
Divilion of En'rironmeotal Manqffl1811t
Wilminllton Jwajonal Offi~
12'1" Canlinal Drive
Wilmia,ton, NC 28406
19101~900
DIRECTIONS TO VARIANCE
HEARING FOR THE CITGO
PRODUCTS TERMINAL
FROM RALEIGH, NC:
Take Interstate 1-40 into Wilmington, NC. Get on US 74-17 (Market Street) and
proceed east into town. Continue on Market Street as it becomes US 17(Busine~). Tum
right (north) onto Front Street and go five blocks to Red Cross Street and tum left; then
tum into Cape Fear Community College (CFCC). The Auditorium is located in the
South Wing of the School. You may reach David Hance at 93-3221 extension 428 to
discuss these direction prior to August 3, 1995. The contact person for the CFCC is Ms.
Linda Flowers 910-251-5100 and is at work until 4:00 pm.
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RECEIVED/EHNR
OEM. GROU~m WATER SEC.
95 JUN 20 PH 3: 22
Attached is an information packet that contains the memoranda and public notice
for this proposed variance. The hearing will be held as follows:
WILMINGTON
August 3, 1995
7:00 PM
Cape Fear Community College
411 North Front Streets
Auditorium
Additional information about this variance will be provided at the public hearing.
After the public hearing and comments have been addressed in accordance with 15A
NCAC 2L .0113(f), the Environmental Management Commission will be provided all the
necessary information to make a decision on this variance. If you have any questions,
please call Mr. Arthur Mouberry at [phone] (extension 400).
cc: Dr. David Moreau
Arthur Mouberry
David Hance
Jennie Odette
Don Reuter
NOTE: Time Sensitive!!!! 06/23/95
TO: Lauri Arntsen-Metz,
SUBJECT: Printing of the PUBLIC NOTICE of a Proposed Variance to
the Groundwater Rules for persons on the GROUNDWATER
RULES MAIL LIST.
Attached is ·a notice for the proposed variance for the Citgo
Products Terminal in Wilmington, NC. We need to send this packet
to persons on the GROUNDWATER RULES MAILING LIST. We will need
six hundred (600) copies of this packet printed DOUBLE-SIDED. It
is appropriate to use fund number# 1655 for this printing. If
it is possible, please get the printed copies back to
the Groundwater Section by June 29, 1995. · If you need
to discuss this informati9n, please call me at 733-3221 extension
428.
David Hance
cc: Carl Bailey
·7VOTE: IMPORTANT-time sensitive!!! 06/21/95
TO: Donna Pi~tman,
SUBJECT: DIRE9TOR'S REVIEW AND SIGNATURE ON THE PUBLIC NOTICE
FOR THE CITGO PRODUCTS TERMINAL VARIANCE AND A LETTER
INFORMING THE EMC GROUNDWATER COMMITTEE
Here is a public notice concerning the Citgo Products
Terminal variance request to Groundwater Quality Standards and
Corrective Action. This notice needs the Director's review and
signature. I _n addition, a memorandum has been provided for
Director's signature to give notice to the Groundwater Committee
of this activity and to generate discussion on the necessity for
a July 1995 meeting. Arthur Mouberry has reviewed the
information contained in both items. IF THIS NOTICE AND MEMORANDUM
MEET THE DIRECTOR'S SATISFACTION, PLEASE RETURN THEM TO ME.
Please note that we are required to give thirty days notice
of the hearing in accordance with 15A NCAC 2L .0113 and will need
to get a large volume copies in the mail to adjacent property
holders, county officials, the newspaper, and persons on the
·Groundwater Mailing List prior to July 4, 1995. IF HIS REVIEW CAN
8E COMPLETED BY THURSDAY I WOULD GREATLY APPRECIATE IT. If you
need any assistance please contact me at extension 428.
David Hance
cc: Carl Bailey
..
State of North Carolina
Department of Environment
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
July 28, 1995
Exxon Chemical Company
Performance Products Group
P.O. Box 3272
Houston, TX 77253-3272
AW'A
DE HNR
Subject: Property at 3340 River Road in
Wilmington, North Carolina.
TO WHOM IT MAY CONCERN:
The North Carolina Department of Environment, Health and Natural
Resources has received a request for a variance from the Groundwater Quality
Standards of 15A NCAC 2L .0202 and Corrective Action requirements of 15A
NCAC 2L .0106(j). 15A NCAC 2L .0113(e)(l)(E) requires adequate notice be given
to area properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
refer to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Enclosure
S cerely J
.~~ t1r{ M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
P.O. Box 29536, Raleigh, North Carolina 27626--0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
..
State of North Carolina
Department of Environment
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
July 28, 1995
Exxon Chemical Company
Performance Products Group
P.O. Box 3272
Houston, TX 77253-3272
AVA
D E HNR
Subject: Property at 3340 River Road in
Wilmington, North Carolina.
TO WHOM IT MAY CONCERN:
The North Carolina Department of Environment, Health and Natural
Resources has received a request for a variance from the Groundwater Quality
Standards of 15A NCAC 2L .0202 and Corrective Action requirements of 15A
NCAC 2L .0106(j). 15A NCAC 2L .0113(e)(l)(E) requires adequate notice be given
to area properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
refer to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Enclosure
·~J]l,L frJ{ M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
P.O. Box 29536, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
NOTICE OF VARIANCE APPLICATION AND HEARING
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL
RESOURCES .
DIVISION OF ENVIRONMENTAL MANAGEMENT
Notice is hereby given of a variance application and public hearing to be held by the
Department of Environment, Health and Natural Resources . on behalf of the Environmental
Management Commission. The hearing concerns a request for a variance from the Groundwater
Quality Standards of 15A NCAC 2L .0202 and the Corrective Action requirements of 15A NCAC
2L .0106 (j) for the Citgo Products Terminal in Wilmington, North Carolina. The variance
application was received for review by the Department on August 25, 1994 from the Amoco Oil
Company, 375 Northridge Road, Suite 350, Atlanta, Georgia, 30350-3296. Prior to April 30, 1993
the Amoco Oil Company was the owner of the tank terminal for which the variance is requested
and is responsible for cleanup of this release.
The property where the release of petroleum product has occurred is located as fallows: Enter the
City of Wilmington from Interstate 40 and take U.S. 17-74 toward the U.S.S. North Carolina
Battleship Memorial. Turn south onto U.S. 421 and turn west onto Shipyard Boulevard toward the
States Ports Authority and then turn south onto River Road. The Citgo Products Terminal is mile
on the left hand side of River Road at a distance of approximately one-half mile.
The Amoco Oil Company requests that the Environmental Management Commission grant
this variance so that it does the following:
(1) Allow concentrations of Benzene, Toluene, Ethylbenzene, Xylenes (BTEX),
Naphthalene, Fluorene, Anthracene, Benzo(a)anthracene, Phenanthrene, and Lead to
remain at levels above 15A NCAC 2L .0202 standards as analyzed on December 12,
1994. These concentrations will be allowed to remain within an area consisting of
properties owned by the American Crane Corporation, the Citgo Products Terminal, and
the Koch Refining Company South Terminal. Right-of-ways exist within these properties
for the North Carolina Department of Transportation and CSX Transportation. The
Citgo Products Terminal, the area proposed for a variance, and all adjacent properties
are zoned by the City of Wilmington as "HM -Heavy Industrial District".
In 1951 Amoco Oil Company constructed an asphalt products terminal at this
location. Due to routine loading and storage activities releases of petroleum products
occurred at the terminal over a number of years. In July 1988 the company conducted
a site assessment of soils and· groundwater at the facility. In 1989 the Department
required that the Amoco Oil Company conduct a Comprehensive Site Assessment. The
Citgo Oil Company acquired this terminal from the Amoco Oil Company on April 30,
1993. Pursuant to investigative activities to complete a Comprehensive Site
Assessment, the Amoco Oil_ Company found petroleum hydrocarbons and lead in
groundwaters on adjacent properties to the west of the terminal on March 31, 1994. On
April 12, 1994 the Division of Environmental Management concurred with the Amoco
Oil Company that the source of groundwater contamination had been adequately
assessed and that the Comprehensive Site Assessment was complete. On August 25, 1994
the Amoco Oil Company requested this variance in accordance with 15A NCAC 2L
.0113(a) and (b).
Analysis of groundwater samples from monitoring wells within the area of the
proposed variance have demonstrated a progressive decrease in BTEX concentrations
since August 19, 1994. No increases in groundwater concentrations for Anthracene,
Benzo(a)anthracene, Fluorene, Lead, Naphthalene, and Phenanthrene have been reported
since that time. During the last semi-annual groundwater analysis one well showed
Benzene at approximately 0.010 milligrams/Liter · and Ethylbenzene at 0.340
milligrams/Liter. The 15A NCAC 2L .0202 Groundwater Quality Standards allow a
maximum of 0.001 milligrams/liter for Benzene and 0.029 milligrams/liter for
Ethylbenzene. The company has conducted a health-risk assessment and have
demonstrated through environmental modeling and calculations that the risks to public
health and safety from granting a variance for this location are minimal. Computer
modeling does not indicate contaminant will exceed the 15A NCAC 2B .0200 Water
Quality Standards when migrating groundwaters discharge into the Class SC Tidal
Surface Water of the Cape Fear River.
Six water supply wells exist within a 1/2 'mile radius of the Citgo Products
Terminal. Five of these water supply wells are used to provide industrial process water
and are not used for drinking. Only Atlantic Marine Incorporated uses a well for
drinking. This water supply well was constructed in the Castle Hayne Aquifer, is
approximately 700 feet from the area proposed for variance, and is located "cross-
gradient" from the direction of groundwater flow. The Amoco Oil Company does not
believe that this variance will effect the water supply well owned by Atlantic Marine
Incorporated. There are no other known public or private water supply wells within a 1/2
mile radius of this location. The City of Wilmington Engineering Department has
confirmed that underground water supply utility lines are set at a depth too shallow to
be impacted by granting this variance.
2) Allow for the restoration of groundwater without requiring remedial actions
in accordance with 15A NCAC 2L .0106(j). The Amoco Oil Company has demonstrated
that requirements of the groundwater rules cannot be achieved by using best available
technology (BAT). Cleanup using best available technology would require pumping the
groundwaters from beneath the land, treating these groundwaters to remove
contaminants, and returning the treated water~ Another kind of best available
technology relies on the introduction of air into the subsurface to stimulate the growth
of naturally occurring microorganisms that breakdown petroleum hydrocarbons~ The
Amoco Oil Company believes that using technology that relies on pumping groundwaters
or the introduction of air will not effectively reduce concentrations of petroleum
hydrocarbons and lead due to the presence of adjacent plumes of contaminated
groundwater on nearby properties.
There is an area of groundwater contamination to the west of the Citgo
Products Terminal. This plume of co.ntaminated groundwater was identified as a release
of gasoline and lead from the Koch Refining Company South Terminal. Another area
approximately 100 feet to the south and east of this location has a separate plume of
groundwater contaminated with petroleum hydrocarbons. These unassociated areas of
groundwater contamination have much higher concentrations of petroleum hydrocarbons
than the area of contamination from the Citgo Products Terminal. The company believes
that re-contamination of the groundwaters within the area of the proposed variance will
likely result if a best available technology is relied on as a cleanup option.
The Amoco Oil Company has estimated that the total costs of implementing
best available technologies to cleanup this area ranges from $ 294,000 dollars to $
3,100,000. The company believes that if cleanup using best available technology is
implemented a serious financial impact would be incurred without equal or greater
public benefit.
Amoco Oil Company maintains that conditions exist within the area proposed
for a variance that will allow for the natural processes of dilution, filtration, chemical
transformation, and biodegradation to eventually reduce levels of these contaminants
below the Groundwater Quality Standards of 15A NCAC 2L .0202. Groundwater
monitoring will continue to be required by the Division of Environmental Management
if this variance is granted. On February 6, 1995 the Wilmington Regional Office
confirmed that other known sources of groundwater contamination around the location
proposed for a variance have been assessed and are being remediated under separate
regulatory actions.
The hearing will be held as follows:
WILMINGTON
August 3, 1995
7:00 PM
Cape Fear Community College
411 North Front Street
Auditorium
Oral Comments may be made during the hearing, or written statements may be
submitted to the agency by September 4, 1995. Written copies of oral statements exceeding three
minutes are requested. Oral statements may be limited at the discretion of the hearing officers.
Please forward comments or information requests to:
David Hance
EHNR-DEM-Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Phone: [phone]
Fax: [phone]
This proposed variance request is available for public inspection -at the locations listed
belo~. Copies may be obtained at each location for a charge of ten cents per page.
•' . . 1
/Ud)~
A. Preston Howar~~E.
Director, Division of Environmental
Management
Dept. of Environment, Health and Natural Resources
Div. of Env. Management
512 North Salisbury Street
Archdale Building, P.O. Box 29535
Raleigh, NC 27626-0535
[phone]
Dept. of Environment, Health and Natural Resources
Div. of Env. Management
Wilmington Regional Office
127 Cardinal Drive
Wilmington, NC
[phone]
27609
State of North Carolina
i;>epartment of Environment
Plealth and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
AVA
D E HNR
July 28, 1995
Koch Refining Company
P.O. Box 2338
Wichita, Kansas 67201
TO WHOM IT MAY CONCERN:
Subject: Property at 3334 River Road in
Wilmington, North Carolina.
The North Carolina Department of Environment, Health and Natural
Resources has received a request for a variance from the Groundwater Quality
Standards of 15A NCAC 2L .0202 and Corrective Action requirements of 15A
NCAC 2L .0106(j). 15A NCAC 2L .0113(e)(l)(E) requires adequate notice be given
to area properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
refer to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Enclosure
Sincerely,// J
. ~1t'-lf~ rb M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
P.O. Box 29536, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
' ., · " State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
.AVA
DEHNR
July 28, 1995
The Honorable Don Betz
City of Wilmington
Mayor's Office
P. 0. Box 1810
Wilmington, NC 28402
Dear Mayor Betz:
The Department of Environment, Health and Natural Resources has
received a request for a variance from the Groundwater Quality Standards of
15A NCAC 2L .0202 and Corrective Action requirements of 15A NCAC 2L
.01060) (Groundwater Classifications and Standards). 15A NCAC 2L
.0113(e)(1)(D) requires adequate notice be given to governmental units having
jurisdiction over the geographical area covered by the variance prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing.
Please refer to the enclosure for additional information.
Enclosure
Sincerely, /_ j ~
fw (/-4-lt'
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
State of North Carolina
Department of Environment
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
June 28, 1995
CSX Transportation
500 Water Street
Jacksonville, Florida 32202
TO WHOM IT MAY CONCERN:
AWA
D E HNR
The North Carolina Department of Environment, Health and Natural
Resources has received a request for a variance from the Groundwater Quality
Standards of 15A NCAC 2L .0202 and Corrective Action requirements of 15A
NCAC 2L .0106(j). 15A NCAC 2L .0113(e){l)(E) requires adequate notice be given
to area properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
refer to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Sincerely~ /
~
/~,94:,,1~
( )
;1 1 ii , 1/' M. C ar Bailey, Jr . .f✓o ( Assistant Chief for Planning
f Groundwater Section
Enclosure
P.O. Box 29535, Raleigh, North Carolina 27626-0535
An Equal Opportunity Affirmative Action Employer
Telephone [phone] FAX [phone]
50% recycled/ l 0% post-consumer paper
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Apex Oil Company
3314 River Road
Wilmington, NC 28403
July 28, 1995
TO WHOM IT MAY CONCERN:
AVA
DE HNR
The Department of Environment, Health and Natural Resources has
received a request for a variance from the Groundwater Quality Standards of
15A NCAC 2L .0202 and Corrective Action requirements of 15A NCAC 2L
.0106(j). 15A NCAC 2L .Ol 13(e)(l)(E) requires adequate notice be given to area
properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
ref er to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Enclosure
s'./e!YII
~1-~--
/2-r M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
P.O. Box 29536, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper
State of North Carolina
DepartQ')ent of Environment
Hetilth and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
July 28, 1995
The American Crane Corporation
202 Raleigh Street
Wilmington, NC 28403
TO WHOM IT MAY CONCERN:
.AVA
D E HNR
The Department of Environment, Health and Natural Resources has
received a request for a variance from the Groundwater Quality Standards of
15A NCAC 2L .0202 and Corrective Action requirements of 15A NCAC 2L
.0106(j). 15A NCAC 2L .0113(e)(l)(E) requires adequate notice be given to area
properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
refer to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Enclosure
P.O. Box 29535, Raleigh, North Carolina 27626-0535
An Equal Opportunity Affirmative Action Employer
Sin~erely~/J /4 /i /4 .
I,,
t:iJr_ .
M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
Telephone [phone] FAX [phone]
50''/4, recycled/ 10% post-consumer paper
State of North Carolina
Department of Environment
Health and-Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
July 28, 1995
AVA
DE HNR
North Carolina Department of Transportation
Division of Highways
P.O. Box 25201
Raleigh, NC 27611
TO WHOM IT MAY CONCERN:
The Department of Environment, Health and Natural Resources has
received a request for a variance from the Groundwater Quality Standards of
15A NCAC 2L .0202 and Corrective Action requirements of 15A NCAC 2L
.0106(j). 15A NCAC 2L .0113(e)(l)(E) requires adequate notice be given to area
properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
refer to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Enclosure
Sincerely, f 1 L ~~ /TJr M. Carl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
P.O. Box 29536, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 Oo/o post-consumer paper
f
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
July 28, 1995
Atlantic Diving and Marine Contractors
Incorportated
3330 River Road
Wilmington, NC 28412
TO WHOM IT MAY CONCERN:
AVA
DEHNR
The Department of Environment, Health and Natural Resources has
received a request for a variance from the Groundwater Quality Standards of
15A NCAC 2L .0202 and Corrective Action requirements of 15A NCAC 2L
.0106(j). 15A NCAC 2L .0113(e)(l)(E) requires adequate notice be given to area
properties and adjacent property owners prior to hearing.
You will find enclosed a Public Notice regarding the variance hearing. Please
ref er to the enclosure for additional information. If you have any questions
concerning this variance request, please contact David Hance at [phone]
(ext. 428).
Enclosure
S1.·ncerely~/ I/
f rxt Ii , /)/Ji. I -0
! 7 /"f'/~
'--
M. C arl Bailey, Jr.
Assistant Chief for Planning
Groundwater Section
P.O. Box 29536, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l()"fo post-consumer paper
MEMORANDUM· 06/05/95
TO:
FROM:
Carl Bailey
David Hance ¥
SUBJECT: DRAFT OF CITGO PRODUCTS TERMINAL VARIANCE NOTICE, DRAFT
OF NOTICE TO THE EMC-GWC, AND DISCUSSION OF HEARING.
I have completed the first draft of a public notice and a draft of a letter to the
Groundwater Committee members concerning the Citgo Products Terminal variance
request. Please review these and get any needed corrections to me.
I have had discussions with the property manager in New Hanover County
concerning a hearing location. The Old Courthouse in Wilmington sounds great (225
people capacity). So far~ July 18, 20, 25, 27, August 2, and August 3 are available in the
evenings. We need to get a Groundwater Supervisor from region outside WIRO to serve
as hearing officer for this meeting. PEOPLE WHO HA VE SERVED AS HEARING
OFFICERS FOR VARIANCES INCLUDE JAY ZIMMERMANN (when he was GWsupervisor
for the RRO), JIM BALES (FRO), AND WILLIE HARDISON (WARO). Below is a list of
Groundwater Supervisors in the Regions who have never been a hearing officer for a
variance:
Don Link (ARO)
Barbara Christian (MRO)
Ken Schuster (RRO)
Sherri Knight (WSRO)
If we can get a hearing officer a date for a hearing can easily be established
from there.
The Director's approval memo is dated for JUNE 15, 1995. If we can get
everything squared away and the notice signed off by then we can get this information
out through the Groundwater Rules Mailing List shortly thereafter.
If you wish to discuss this report and memo please call me at extension 428.
ATTACHMENT:
cc: David Hance
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
June 15, 1995
MEMORANDUM
TO: Arthur Mouberry, P.E.
Chief, Groundwater Section
FROM: A. Preston Howard, Jr. P.E.M
NA
D E HNR
SUBJECT: Variance Request for the Citgo Products Terminal in Wilmington, North
Carolina.
I have reviewed the attached package submitted in support of a request for a
variance as outlined in 15A NCAC 2L .0113. Based on the information that has been
submitted, I have determined that sufficient information exists to concur that this variance
should proceed with public notice and hearing as outlined in the rules. Please provide public
notice in accordance with 15A NCAC 2L .0113(e) so that the Division can receive public
input prior to final action on this variance request.
cc: Groundwater Section Assistant Chiefs
David Hance
Wilmington Regional Hydrogeologic Supervisor
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ l 0% post-consumer paper
'I,
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
June 15, 1995
MEMORANDUM
TO: Arthur Mouberry, P .E.
Chief, Groundwater Section
FROM: A. Preston Howard, Jr. P.E.~
NA
D E HNR
SUBJECT: Variance Request for the Citgo Products Terminal in Wilmington, North
Carolina.
I have reviewed the attached package submitted in support of a request for a
variance as outlined in 15A NCAC 2L .0113. Based on the information that has been
submitted, I have determined that sufficient information exists to concur that this variance
should proceed with public notice and hearing as outlined in the rules. Please provide public
notice in accordance with 15A NCAC 2L .0113(e) so that the Division can receive public
input prior to final action on this variance request.
cc: Groundwater Section Assistant Chiefs
David Hance
Wilmington Regional Hydrogeologic Supervisor
P.O. Box 29535, Raleigh. North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
DIVISION OF ENVIRONMENTAL MANAGEMENT
Groundwater Section
May 29, 1995
MEMORANDUM
TO: A. Preston Howard, Jr. P.E.
TIIROUGH: Arthur Mouberry, P.E. U
Chief, Groundwater Sectio!fY"
FROM: Carl Bailey (.-0
Assistant Chief for Planning, Groundwater Section
SUBJECT: Variance Request for the Citgo Products Tenninal in Wilmington, North Carolina.
The Groundwater Section is in the process of reviewing a request for variance from Title
15A Nonh Carolina General Statutes, Subchapter 2L "Classi fi cations and Water Oun li ty
Sta,ulards A pp licable to the Groundwaters o f Nonh Carolina" for the subject site. The petitioner,
Amoco Oil Company, requests a variance from 15A NCAC 2L .0202 (Groundwater Quality
Standards) and 15A NCAC 2L .0106(j) (Corrective Action Plans).
Attached for your consideration is a memorandum in which staff have provided comments
concerning the information required to be submitted in support of the request in accordance with
15A NCAC 2L. 0113(c) and which must be considered by the Environmental Management
Commission (EMC) prior to granting a variance. Based on the information received thus far, this
facility seems to be a good candidate for a variance. Your concurrence is needed so that the
Division can proceed with public notice of hearing in accordance with procedures set out in 15A
NCAC 2L .0113(d) and (e) and for subsequent review by the Environmental Management
Commission. The Groundwater Section would like present this request as an information
item to the Groundwater Committee at the September 13, 1995 meeting. If you have any
questions concerning this matter please contact me at 733-3221.
Attachments
cc: Arthur Mouberry
Groundwater Section Assistant Chiefs
David Hance
DIVISION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
May 29, 1995
MEMORANDUM
To:
From:
Subject:
Preston Howard
Arthur Mooberry#
Request for Variance from 15A NCAC 2L .0202 and 15A
NCAC 2L .0106(j) for a Site at the Amoco Oil Company Citgo Products
Terminal in Wilmington, North Carolina (New Hanover County).
In 1951 Amoco Oil Company constructed an asphalt products terminal in
Wilmington, North Carolina. In July 1988 a Comprehensive Site Assessment (CSA) of the
terminal was conducted to evaluate the presence of hydrocarbons in subsurface soils and
groundwater. Pursuant to the findings of this CSA, the Amoco Oil Company received a
Notice of Violation from the Department of Environment, Health and Natural Resources
for the Citgo Products Tank Terminal in March of 1989. On April 30, 1993 the Citgo
Oil Company acquired the terminal from the Amoco Oil Company. On March 31, 1994
Amoco Oil Company completed an assessment of groundwater contamination. It was
found that dissolved hydrocarbons in concentrations exceeding Groundwater Quality
Standards under 15A NCAC 2L .0202 were found on the adjacent properties to the west
and southwest. On April 12, 1994 the Division of Environmental Management concurred
that the source of groundwater contamination from the Citgo Products Terminal had
been adequately a_ssessed. Upon completing this Comprehensive Site Assessment to the
satisfaction of the Division, the Amoco Oil Company requested a variance on August 25,
1994 in accordance with the requirements of 15A NCAC 2L .0113(a) and (b).
Pursuant to title 15A NCAC 2L .0113(c) variance applications are required to
contain specific information in order to adequately review a request. Amoco Oil
Company's variance application is contained in a report titled "Request for Variance to
NCAC Title 15A , Subchapter 2L -Groundwater Classifications and Standards". The
information submitted by the Amoco Oil Company appears to meet the requirements of
15A NCAC 2L .0113(c) and is summarized as follows:
1
Rule .0113(c )(l): Resolution b y the County or governing Board:
The Citgo Products Terminal has always been a privately owned facility.
No resolution is necessary.
Rule .0113(c ){2 ): A descri ption of p ast , existing or proposed activities that would result
in a discharge of contaminants into groundwater:
The Citgo Products Terminal is located inside the city limits of
Wilmington, North Carolina. This facility and all adjacent properties are in an
area zoned as an "HM -Heavy Industrial District". The Citgo Products Terminal
consists of approximately 31 acres of land of which 25 acres have been developed
for terminal operations. Seventeen above-ground bulk storage tanks have been
installed and used to store liquid asphaltic cement, naphtha, and other petroleum
products. A loading facility consisting of two truck loading racks are used to
convey petroleum products for transport. Over the last several decades soils and
groundwater in the area have been accidentally contaminated by dissolved
hydrocarbons from routine storage and loading operations at the terminal.
In August 1991 the Division of Environmental Management required
Amoco Oil Company to perform additional groundwater monitoring to delineate
the extent of contamination on adjacent properties. This land is an area west and
southwest of the terminal. From July 22, 1988 to March 31, 1994 a total of 40
monitoring wells were installed to delineate the vertical and . lateral extent of the
contamination plume from the Citgo Products Terminal and assess the impact on
the adjacent properties. On April 12, 1994 the Division of Environmental
Management conctnTed that the source of groundwater contamination from the
Citgo Products Terminal had been adequately assessed. Other plumes of
hydrocarbon contaminated groundwaters located on adjacent properties were
determined to be the result of separate releases from sources other than the
Citgo Products Terminal. One plume of groundwater contamination west of the
area for which the variance has been requested was identified as a release of
gasoline and lead from the Koch Refining Company South Terminal. Another area
to the south and east of the site has been impacted by separate plume of
groundwater contaminated with petroleum hydrocarbons. According to
information supplied by the applicant all known sources of groundwater
contamination are "being assessed and have been, or are being abated." On
February 6, 1995 the Wilmington Regional Office informed the Groundwater
Section that all known sources of groundwater contamination have been assessed
and are under separate regulatory actions.
2
Potential SOlD"ces of groundwater contamination in the area are shown in
Figure 2-2 of the report titled "Request for Variance to NCAC Title 15A,
Subchapter 2L -Groundwater Classifications and Standards" and includes the
following:
1) Underground petroleum pipelines that extend from the Cape Fear
River and deliver product to the Koch Refining Company South
Terminal and the Citgo Products Terminal;
2) A pipeline used to transport paraxyleoe. This pipeline originates on
property to the southwest of the Citgo Products Terminal and is
owned by the Exxon Oil Company -Exxon Terminal. The pipeline
extends from the Exxon Terminal and runs almost directly north
and parallel to the River Road. A portion of this pipeline is buried
beneath the land for which this variance has been requested;
3) Ao active railroad line owned by CSX Transportation;
4) River Road (a public roadway); and
5) A 1986 groundwater and soil contamination incident at The Koch
Refining Company Terminal. Gasoline and lead was release dlD"ing
this incident. Contaminated soils were removed between 1989 and
1990.
Rule .0113(c )(3): Description of the proposed area for which the variance is requested:
This variance is for the adjacent property west of the Citgo Products
Terminal. A map,.,(FiglD"e 2-2) of the report titled "Request for Variance to NCAC
Title 15A, Subchapter 2L -Groundwater Classifications and Standards" shows the
area for which this variance is requested. The specific area is on land owned by
the Koch Refining Company South Terminal and is bounded to the north and east
by River Road and the west by a CSX Transportation railroad right-of-way. The
southern boundary crosses onto a portion of land owned by the American Crane
Corporation. The Cape Fear River is located approximately 800 to 1,000 feet to
the west. No other properties owned by Amoco Oil Company or properties owned
by other persons are being included in this application for variance. (refer to
pages 2-5 through 2-9 of the report).
3
The concentration of contaminants in groundwater is primarily influenced
by the direction and rate of groundwater flow. Modeling and groundwater
monitoring data shows that contaminants are moving in .a westerly direction
toward property owned by the Koch Refining Company South Terminal.
Groundwater is estimated to move at a horizontal flow velocity of approximately
one foot per day and occurs at an average depth to groundwater of 15 feet below
land surf ace (see page 2-6).
Rule .0113 (c ){4 ): Supporting information to establish that the variance will not
endanger the public health and safety ... :
The part of the variance concerning Groundwater Quality Standards shown
in 15A NCAC 2L. 0202 has been requested for Benzene, Ethylbenzene, Toluene,
Xylene(-o,-m, and p), Naphthalene, Fluorene, Anthracene, Benzo(a)anthracene,
Phenanthrene, and Lead. The August 19, 1994 Risk Assessment has been included
in the "Request for Variance to NCAC Title 15A, Subcbapter 2L -Groundwater
Classifications and Standards". Page 13 of the Risk Assessment shows that 15A
NCAC 2L .0202 Groundwater Quality Standards have been exceeded for
Anthracene, Benzo(a)anthracene, Ethylbenzene, Lead, Naphthalene, and Xylene(-
o,-m, and p). A number of human receptors under a variety of different scenarios
were examined in this assessment. Environmental modeling and calculations
demonstrate that risks to public health and safety from the presence of these
substances, compared to other risks associated with the environment, are
minimal.
In Table 2-1 of the report, groundwater quality data from the December
12, 1994 semi-annual monitoring event .shows the concentrations of Ethylbenzene
and Xylene decreasing below the Groundwater Quality Standard in 15A NCAC 2L
.0202 for monitoring wells within the area of the proposed variance.
Amoco Oil Company submitted information on the impact that
contaminant levels would have on the Cape Fear River in the event groundwaters
co11taioing the plume would reach the river. Groundwater modeling and
environmental fate calculations were performed to assess the effect these
contaminant concentrations would have on Class SC Tidal Surface Water of the
Cape Fear River when migrating groundwaters discharge into the river. The
projected instream concentrations of Combined Polycyclic Aromatic
Hydrocarbons (PAHs), Ethylbenzene, Lead, and Xylenes(-o,-m, and p) are below
the water quality standards contained in 15A NCAC 2B .0200 for that
classification.
4
Six water supply wells exist within a 1/2 mile radius of the Citgo Products
Terminal. The owners of these wells are listed on page 2-9 through 2-10 of the
report. Five of these water supply wells are used to provide process water for
industrial operations and are not used for drinking. Only Atlantic Marine
Incorporated uses a water well for drinking. This company's well Is approximately
700 feet from the area of the proposed variance and is located "cross gradient"
to the direction of groundwater flow. This well is believed to have been
constructed in the Castle Hayne Aquifer. On September 16, 1994 the Wilmington
Regional Office concluded that the information submitted by Amoco Oil
Company demonstrates that only the Surficial Aquifer in the area of the
proposed variance has been impacted by petroleum hydrocarbons from the Citgo
Products Terminal. It is highly unlikely that the Atlantic Marine Incorporated
drinking water well will be impacted by this variance.
According to the City of Wilmington F.ngineering Department, numerous
water supply lines and other utilities are present throughout the area. These
utilities occur between 4 to 9 feet below land surface. The average depth at
which groundwater occurs in this area Is 15 feet with a seasonal variation of
approximately one foot. The existence of the surface utilities will not present a
significant pathway for migration of contaminants. Further the report states that
contaminants at his facility are not expected to present a risk to public health,
safety, or the environment. In addition, the structures themselves are not
considered at risk.
Rule .0113(c )(5): Supporting information to establish that requirements of the rule
cannot be achieved by providing best available technology economically reasonable:
The part of the request that concerns variance to Corrective Action in
ISA NCAC 2L .0106(j) is based on the fact that the requirements of the rule
cannot be achieved by providing the best available technology (BAT)
economically reasonable. Amoco Oil Company has submitted supporting
information demonstrating that the application of BAT will not result in
significant long term remediation of the site to the Groundwater Quality
Standards, contained in ISA NCAC 2L .0202. This is due to the high probability
of re-contamination from adjacent plumes. Elevated concentrations of dissolved
hydrocarbons exist in monitoring wells to the west of the area for which the
variance has been requested. Because of these highly elevated levels Amoco Oil
Company was unable to assess the western edge of the contaminant plume for
which the variance Is requested. On February 6, 1995 the Wilmington Regional
Office informed the Groundwater Section Chief that this groundwater
5
contamination is being managed under a separate Notice of Violation because
fact the Koch Refining Company is the responsible party. It is believed that
hydrocarbon concentrations in wells on Koch Refining Company South Terminal
property are the result of co-mingling of plumes from different sources. In
addition, there is another adjacent property on which petroleum hydrocarbons are
present in groundwater at concentrations above the standards. This area is south
of the Citgo Products Terminal on property owned by the American Crane
Corporation. This plume is located 100 feet downgradient from the area that is
encompassed in the Amoco Oil Company's variance requests and has received a
separate Notice of Violation from the Division of Environmental Management.
In order to demonstrate that the requirements of the rule cannot be
achieved using best available technology Title ISA NCAC 2L .0113(c)(5) requires
that specific technology considered be identified, the costs of implementing the
technology be shown, and the impacts of the costs on the applicant be provided.
The Amoco Oil Company has furnished this information for applicable
technologies on pages 2-13 through 2-20 of the "Request for Variance to NCAC
Title 15A, Subchap ter 2L -Groundwater Classifications and Standards". This cost
information is summarized as follows:
Technology Total Cost ($) Pro jected Number of
Years of Operating
Treatment Technology to
Reach the "Total Cost ($)"
PUMP AND TREAT SYSI'EM
(with air stripping)
SOIL VAPOR EXTRACTION
(with a pump-and-treat system)
SLURRY WALL
(with a pump-and-treat system)
Am BIOSPARGING
greater than
$1,000,000
$1,250,000
$3,100,000
$ 294,000
5
30
5
The cost estimates for these best available technologies include
expenditures for construction, operation, and maintenance. The costs for Air
Biosparging Technology includes additional costs unique to this site. Due to the
fact that the area proposed for variance is transcected by River Road and the
CSX Transportation railroad.
6
A separate air delivery system with electric power lines would need to be
installed if this technology were applied. Construction of this air supply system
for air biosparging technology may necessitate the temporary disruption of the
utilities that are presently located· near the railroad and River Road. The Amoco
Oil Company has demonstrated that all these remediation options are a major
investment of environmental cleanup funds with no certainty that any of them
will effectively remediate this site to the level of the Groundwater Quality
Standards in 15A NCAC 2L .0202. The Amoco Oil Company believes that the
geologic characteristics of the site will serve to naturally remediate these
groundwaters to the level of the standards in 15A NCAC 2L .0202.
Rule .0113(c )(6 ): Supp orting information to establish that comp liance would produce
serious financial hardship on the a pp licant:
In pages 2-13 through 2-20 "Request for Variance to NCAC Title 15A.
Subchap ter 2L -Groundwater Classifications and Standards" the Amoco Oil
Company has shown that applying best available technology to this site would be
a prohibitively expensive method of remediating groundwater contamination.
There is immense uncertainty that this site could ever be successfully remediated
to the Groundwater Quality Standards due to the likelihood of re-contamination
from adjacent plumes.
Rule .0113(c )(7 ): Supporting information that comp liance would produce serious
financial hardship without e qual or greater public benefit:
The company has sufficiently demonstrated in the variance request that
the environment, safety and public health would not be impacted by this
variance. Due to the high probability of re-contamination from adjacent plumes,
it is highly unlikely that groundwater in the area proposed for variance will ever
be remediated to the standards in 15A NCAC 2L .0202. The Groundwater Section
believes that the public will not benefit from compelling the Amoco Oil Company
to remediate this site using best available technology.
Rule .0113(c )(8 ): "A co py of any Special Order ... ":
No Special Order by Consent has been issued for this site.
7
Rule .0113(c )(9 ): "A list of names and addresses of property owners ... ":
The property owners within the proposed area of the variance include the
Koch Refining Company South Terminal, CSX Transportation, The American
Crane Corporation, and the North Carolina Department of Transportation.
Adjacent property owners are the Koch Refining Company South Terminal, CSX
Transportation, The American Crane Corporation, the North Carolina
Department of Transportation, Atlantic Marine Incorporated, Carolina Power and
Light, and the Exxon Corporation. Title 15A NCAC 2L .0113(e)(E) requires that
notification of a public hearing on this variance be given to these adjacent
property owners "at least 30 days prior to the date of the hearing".
It is the recommendation of the Groundwater Section that the subject variance
request to Corrective Action requirements of 15A NCAC 2L .0106(j) and Groundwater
Quality Standards contained in 15A NCAC 2L .0202, as stated in the petition, proceed
to public notice in accordance with 15A NCAC 2L .0113(e). Upon your concurrence
with our recommendation, the Groundwater Section will proceed with the preparation of
the required public notice and hearing. Upon completing of the requirements of 15A
NCAC 2L .0113(d -f), with a recommendation to grant this variance from the
Environmental Management Commission Groundwater Committee, this request will
proceed to the Environmental Management Commission for final action in 15A NCAC
2L .0113(g). If there are any questions regarding this matter or if any additional
information is needed, please let me know.
ATTACHMENTS:
cc: Groundwater Section Assistant Chiefs
Wilmington Regional Groundwater Supervisor
Dr. Ken Rudo
David Hance
8
Attached is an information packet that contains the memoranda and public notice
for this proposed variance. The hearing will be held as follows:
WILMINGTON
August 3, 1995
7:00 PM
Cape Fear Community College
411 North Front Streets
Auditorium
Additional information about this variance will be provided at the public hearing.
After the public hearing and comments have been addressed in accordance with 15A
NCAC 2L .0113{f), the Environmental Management Commission will be provided all the
necessary information to make a decision on this variance. If you have any questions,
please call Mr. Arthur Mouberry at {919) 733-3221 (extension 400).
cc: Dr. David Moreau
Arthur Mouberry
David Hance
Jennie Odette
Don Reuter
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
June 15, 1995
MEMORANDUM
TO: Arthur Mouberry, P .E.
Chief, Groundwater Section
FROM: A. Preston Howard, Jr. P.E.~
NA
D E HNA
SUBJECT: Variance Request for the Citgo Products Terminal in Wilmington, North
Carolina.
I have reviewed the attached package submitted in support of a request for a
variance as outlined in 15A NCAC 2L .0113. Based on the information that has been
submitted, I have determined that sufficient information exists to concur that this variance
should proceed with public notice and hearing as outlined in the rules. Please provide public
notice in accordance with 15A NCAC 2L .0113(e) so that the Division can receive public
input prior to final action on this variance request.
cc: Groundwater Section Assistant Chiefs
David Hance
Wilmington Regional Hydrogeologic Supervisor
P.O. Box 29535. Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post-consumer paper
I
\
DMSION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
May 29, 1995
MEMORANDUM
To:
From:
Subject:
Preston Howard
Arthur Mouberry #'
Request for Variance from 15A NCAC 2L .0202 and 15A
NCAC 2L .0106(j) for a Site at the Amoco Oil Company Citgo Products
Terminal in Wilmington, North Carolina (New Hanover County).
In 1951 Amoco Oil Company constructed an asphalt products terminal in
Wilmington, North Carolina. In July 1988 a Comprehensive Site Assessment (CSA) of the
terminal was conducted to evaluate the presence of hydrocarbons in subsurface soils and
groundwater. Pursuant to the findings of this CSA, the Amoco Oil Company received a
Notice of Violation from the Department of Environment, Health and Natural Resources
for the Citgo Products Tank Terminal in March of 1989. On April 30, 1993 the Citgo
Oil Company acquired the terminal from the Amoco Oil Company. On March 31, 1994
Amoco Oil Company completed an assessment of groundwater contamination. It was
found that dissolved hydrocarbons in concentrations exceeding Groundwater Quality
Standards under 15A NCAC 2L .0202 were found on the adjacent properties to the west
and southwest. On April 12, 1994 the Division of Environmental Management concurred
that the source of groundwater contamination from the Citgo Products Terminal had
been adequately assessed. Upon completing this Comprehensive Site Assessment to the
satisfaction of the Division, the Amoco Oil Company requested a variance on August 25,
1994 in accordance with the requirements of 15A NCAC 2L .0ll3(a) and (b).
Pursuant to title 15A NCAC 2L .0113(c) variance applications are required to
contain specific information in order to adequately review a request. Amoco Oil
Company's variance application is contained in a report titled "Request for Variance to
NCAC Title 15A . Subchapter 2L -Groundwater Classifications and Standards". The
information submitted by the Amoco Oil Company appears to meet the requirements of
15A NCAC 2L .0113(c) and is summarized as follows:
1
Rule .0113(c )(l ): Resolution by the County or g overning Board:
The Citgo Products Terminal has always been a privately owned facility.
No resolution is necessary.
Rule .0113(c )(2): A descri ption of p ast, existing or prop osed activities that would result
in a discharge of contaminants into groundwater:
The Citgo Products Terminal is located inside the city limits of
Wilmington, North Carolina. This facility and all adjacent properties are in an
area zoned as an "HM -Heavy Industrial District". The Citgo Products Terminal
consists of approximately 31 acres of land of which 25 acres have been developed
for terminal operations. Seventeen above-ground bulk storage tanks have been
installed and used to store liquid asphaltic cement, naphtha, and other petroleum
products. A loading facility consisting of two truck loading racks are used to
convey petroleum products for transport. Over the last several decades soils and
groundwater in the area have been accidentally contaminated by dissolved
hydrocarbons from routine storage and loading operations at the terminal.
In August 1991 the Division of Environmental Management required
Amoco Oil Company to perform additional groundwater monitoring to delineate
the extent of contamination on adjacent properties. This land is an area west and
southwest of the terminal. From July 22, 1988 to March 31, 1994 a total of 40
monitoring wells were installed to delineate the vertical and lateral extent of the
contamination plume from the Citgo Products Terminal and assess the impact on
the adjacent properties. On April 12, 1994 the Division of Environmental
Management conCWTed that the source of groundwater contamination from the
Citgo Products Terminal had been adequately assessed. Other plumes of
hydrocarbon contaminated groundwaters located on adjacent properties were
determined to be the result of separate releases from sources other than the
Citgo Products Terminal. One plume of groundwater contamination west of the
area for which the variance has been requested was identified as a release of
gasoline and lead from the Koch Refining Company South Terminal. Another area
to the south and east of the site has been impacted by separate plume of
groundwater contaminated with petroleum hydrocarbons. According to
information supplied by the applicant all known sources of groundwater
contamination are "being assessed and have been, or are being abated." On
February 6, 1995 the Wilmington Regional Office informed the Groundwater
Section that all known sources of groundwater contamination have been assessed
and are under separate regulatory actions.
2
Potential sources of groundwater contamination in the area are shown in
Figure 2-2 of the report titled "Request for Variance to NCAC Title 15A,
Subchapter 2L -Groundwater Classifications and Standards" and includes the
following:
1) Underground petroleum pipelines that extend from the Cape Fear
River and deliver product to the Koch Refining Company South
Terminal and the Citgo Products Terminal;
2) A pipeline used to transport paraxylene. This pipeline originates on
property to the southwest of the Citgo Products Terminal and is
owned by the Exxon Oil Company -Exxon Terminal. The pipeline
extends from the Exxon Terminal and runs almost directly north
and parallel to the River Road. A portion of this pipeline is buried
beneath the land for which this variance has been requested;
3) An active railroad line owned by CSX Transportation;
4) River Road (a public roadway); and
5) A 1986 groundwater and soil contamination·incident at The Koch
Refining Company Terminal. Gasoline and lead was release during
this incident. Contaminated soils were removed between 1989 and
1990.
Rule .0113(c }(3): Description of the proposed area for which the variance is requested:
This variance is for the adjacent property west of the Citgo Products
Terminal. A map (Figure 2-2) of the report titled "Request for Variance to NCAC
Title 15A. Subchapter 2L -Groundwater Classifications and Standards" shows the
area for which this variance is requested. The specific area is on land owned by
the Koch Refining Company South Terminal and is bounded to the north and east
by River Road and the west by a CSX Transportation railroad right-of-way. The
southern boundary crosses onto a portion of land owned by the American Crane
Corporation. The Cape Fear River is located approximately 800 to 1,000 feet to
the west. No other properties owned by Amoco Oil Company or properties owned
by other persons are being included in this application for variance. (refer to
pages 2-5 through 2-9 of the report).
3
The concentration of contaminants in groundwater is primarily influenced
by the direction and rate of groundwater flow. Modeling and groundwater
monitoring data shows that contaminant-c; are moving in a westerly direction
toward property owned by the Koch Refining Company South Terminal.
Groundwater is estimated to move at a horizontal flow velocity of approximately
one foot per day and occurs at an average depth to groundwater of 15 feet below
land surface (see page 2--6).
Rule .0113 (c )(4 ): Supporting information to establish that the variance will not
endanger the public health and safety ... :
The part of the variance concerning Groundwater Quality Standards shown
in ISA NCAC 2L. 0202 has been requested for Benzene, Ethylbenzene, Toluene,
Xylene(-o,-m, and p), Naphthalene, Fluorene, Anthracene, Benzo(a)anthracene,
Phenanthrene, and Lead. The August 19, 1994 Risk Assessment has been included
in the "Request for Variance to NCAC Title 15A. Subchapter 2L -Groundwater
Classifications and Standards". Page 13 of the Risk Assessment shows that 15A
NCAC 2L .0202 Groundwater Quality Standards have been exceeded for
Anthracene, Benzo(a)anthracene, Ethylbenzene, Lead, Naphthalene, and Xylene(-
o,-m, and p). A number of human receptors under a variety of different scenarios
were examined in this assessment. F.nvironmental modeling and calculations
demonstrate that risks to public health and safety from the presence of these
substances, compared to other risks associated with the environment, are
rninimru.
1n Table 2-1 of the report, groundwater quality data from the December
12, 1994 semi-annual monitoring event shows the concentrations of Ethylbenzene
and Xylene decreasing below the Groundwater Quality Standard in 15A NCAC 2L
.0202 for monitoring wells within the area of the proposed variance.
Amoco Oil Company submitted information on the impact that
contaminant levels would have on the Cape Fear River in the event groundwaters
containing the plume would reach the river. Groundwater modeling and
environmental fate calculations were performed to assess the effect these
contaminant concentrations would have on Class SC Tidal Surface Water of the
Cape Fear River when migrating groundwaters discharge into the river. The
projected instream concentrations of Combined Polycyclic Aromatic
Hydrocarbons (PAHs), Ethylbenzene, Lead, and Xylenes(-o,-m, and p) are below
the water quality standards contained in 15A NCAC 2B .0200 for that
classification.
4
,'
'
Six water supply wells exist within a 1/2 mile radius of the Citgo Products
Tenninal. The owners of these wells are listed on page 2-9 through 2-10 of the
report. Five of these water supply wells are used to provide process water for
industrial operations and are not used for drinking. Only Atlantic Marine
Incorporated uses a water well for drinking. This company's well is approximately
700 feet from the area of the proposed variance and is located "cross gradient"
to the direction of groundwater flow. This well is believed to have been
constructed in the Castle Hayne Aquifer. On September 16, 1994 the Wilmington
Regional Office concluded that the information submitted by Amoco Oil
Company demonstrates that only the Surficial Aquifer in the area of the
proposed variance has been impacted by petroleum hydrocarbons from the Citgo
Products Terminal. It is highly unlikely that the Atlantic Marine Incorporated
drinking water well will be impacted by this variance.
According to the City of Wilmington F.ngineering Department, numerous
water supply lines and other utilities are present throughout the area. These
utilities occur between 4 to 9 feet below land surface. The average depth at
which groundwater occurs in this area is 15 feet with a seasonal variation of
approximately one foot. The existence of the surface utilities will not present a
significant pathway for migration of contaminants. Further the report states that
contaminants at his facility are not expected to present a risk to public health,
safety, or the environment. In addition, the structures themselves are not
considered at risk.
Rule .0113(c )(5): Supporting information to establish that requirements of the rule
cannot be achieved by providing best available technology economically reasonable:
The part of the request that concerns variance to Corrective Action in
15A NCAC 2L .0106(j) is based on the fact that the requirements of the rule
cannot be achieved by providing the best available technology (BAT)
economically reasonable. Amoco Oil Company has submitted supporting
information demonstrating that the application of BAT will not result in
significant long term remediation of the site to the Groundwater Quality
Standards, contained in 15A NCAC 2L .0202. This is due to the high probability
of re-contamination from adjacent plumes. Elevated concentrations of dissolved
hydrocarbons exist in monitoring wells to the west of the area for which the
variance has been requested. Because of these highly elevated levels Amoco Oil
Company was unable to assess the western edge of the contaminant plume for
which the variance is requested. On February 6, 1995 the Wilmington Regional
Office informed the Groundwater Section Chief that this groundwater
5
contamination is being managed under a separate Notice of Violation because
fact the Koch Refining Company is the responsible party. It is believed that
hydrocarbon concentrations in wells on Koch Refining Company South Terminal
property are the result of co-mingling of plumes from different sources. In
addition, there is another adjacent property on which petroleum hydrocarbons are
present in groundwater at concentrations above the standards. This area is south
of the Citgo Products Terminal on property owned by the American Crane
Corporation. This plume is located 100 feet downgradient from the area that is
encompassed in the Amoco Oil Company's variance requests and has received a
separate Notice of Violation from the Division of Environmental Management.
In order to demonstrate that the requirements of the rule cannot be
achieved using best available technology Title 15A NCAC 2L .0113(c)(5) requires
that specific technology considered be identified, the costs of implementing the
technology be shown, and the impacts of the costs on the applicant be provided.
The Amoco Oil Company has furnished this information for applicable
technologies on pages 2-13 through 2-20 of the "Request for Variance to NCAC
Title l SA. Subchapter 2L -Groundwater Classifications and Standards". This cost
information is smnmarized as follows:
Technology Total Cost ($) Pro jected Number of
Years of Operating
Treatment Technology to
Reach the "Total Cost ($)"
PUMP AND TREAT SYSTEM
(with air stripping)
SOIL VAPOR EXTRACTION
(with a pump-and-treat system)
SLURRY WALL
(with a pump-and-treat system)
Am BIOSPARGING
greater than
$1,000,000
$1,250,000
$3,100,000
$ 294,000
10
5
30
5
The cost estimates for these best available technologies include
expenditures for construction, operation, and maintenance. The costs for Air
Biosparging Technology includes additional costs unique to this site. Due to the
fact that the area proposed for variance is transcected by River Road and the
CSX Transportation railroad.
6
A separate air delivery system with electric power lines would need to be
installed if this technology were applied. Construction of this air supply system
for air biosparging technology may necessitate the temporary disruption of the
utilities that are presently located-near the railroad and River Road. The Amoco
Oil Company has demonstrated that all these remediation options are a major
investment of environmental cleanup funds with no certainty that any of them
will effectively remediate this site to the level of the Groundwater Quality
Standards in 15A NCAC 2L .0202. The Amoco Oil Company believes that the
geologic characteristics of the site will serve to naturally remediate these
groundwaters to the level of the standards in 15A NCAC 2L .0202.
Rule .0113(c )(6 ): Supp orting information to establish that comp liance would produce
serious financial hardship on the a pp licant:
1n pages 2-13 through 2-20 "Request for Variance to NCAC Title 15A,
Subchapter 2L -Groundwater Classifications and Standards" the Amoco Oil
Company has shown that applying best available technology to this site would be
a prohibitively expensive method of remediating groundwater contamination.
There is immense uncertainty that this site could ever be successfully remediated
to the Groundwater Quality Standards due to the likelihood of re-contamination
from adjacent plumes.
Rule .0113(c )(7 ): Supporting information that compliance would p roduce serious
financial hardshi p without e qual or greater public benefit:
The company has sufficiently demonstrated in the variance request that
the environment, safety and public health would not be impacted by this
variance. Due to the high probability of re-contamination from adjacent plumes,
it is highly unlikely that groundwater in the area proposed for variance will ever
be remediated to the standards in 15A NCAC 2L .0202. The Groundwater Section
believes that the public will not benefit from compelling the Amoco Oil Company
to remediate this site using best available technology.
Rule .0113{c )(8 ): "A copy of any S pecial Order ... ":
No Special Order by Consent bas been issued for this site.
7
Rule .0113(c )(9 ): "A list of names and addresses of property owners ... ":
The property owners within the proposed area of the variance include the
Koch Refining Company South Terminal, CSX Transportation, The American
Crane Corporation, and the North Carolina Department of Tr~portation.
Adjacent property owners are the Koch Refining Company South Terminal, CSX
Transportation, The American Crane Corporation, the North Carolina
Department of Transportation, Atlantic Marine Incorporated, Carolina Power and
Light, and the Exxon Corporation. Title 15A NCAC 2L .0113(e)(E) requires that
notification of a public hearing on this variance be given to these adjacent
property owners "at least 30 days prior to the date of the hearing".
It is the recommendation of the Groundwater Section that the subject variance
request to Corrective Action requirements of 15A NCAC 2L .0106(j) and Groundwater
Quality Standards contained in ISA NCAC 2L .0202, as stated in the petition, proceed
to public notice in accordance with 15A NCAC 2L .0113(e). Upon your concurrence
with our recommendation, the Groundwater Section will proceed with the preparation of
the required public notice and hearing. Upon completing of the requirements of 15A
NCAC 2L .0113(d -f), with a recommendation to grant this variance from the
Environmental Management Commission Groundwater Committee, this request will
proceed to the Environmental Management Commission for final action in 15A NCAC
2L .0113(g). If there are any questions regarding this matter or if any additional
information is needed, please let me know.
ATTACHMENTS:
cc: Groundwater Section Assistant Chiefs
Wilmington Regional Groundwater Supervisor
Dr. Ken Rudo
David Hance
8
.,
NOTICE OF VARIANCE APPLICATION AND HEARING
DEPARTMENT OF ENVIRONMENT, HEALTH AND NATURAL
RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
Notice is hereby given of a variance application and public hearing to be held by the
Department of Environment, Health and Natural Resources. on behalf of the Environmental
Management Commission. The hearing concerns a request for a variance from the Groundwater
Quality Standards of 15A NCAC 2L .0202 and the Corrective Action requirements of 15A NCAC
2L .0106 (j) for the Citgo Products Terminal in Wilmington, North Carolina. The variance
application was received for review by the Department on August 25, 1994 from the Amoco Oil
Company, 375 Northridge Road, Suite 350, Atlanta, Georgia, 30350-3296. Prior to April 30, 1993
the Amoco Oil Company was the owner of the tank terminal for which the variance is requested
and is responsible for cleanup of this release.
The property where the release of petroleum product has occurred is located as follows: Enter the
City of Wilmington from Interstate 40 and take U.S. 17-74 toward the U.S.S. North Carolina
Battleship Memorial. Turn south onto U.S. 421 and turn west onto Shipyard Boulevard toward the
States Ports Authority and then turn south onto River Road. The Citgo Products Terminal is mile
on the left hand side of River Road at a distance of approximately one-half mile.
The Amoco Oil Company requests that the Environmental Management Commission grant
this variance so that it does the following:
(1) Allow concentrations of Benzene, Toluene, Ethylbenzene, Xylenes (BTEX),
Naphthalene, Fluorene, Anthracene, Benzo(a)anthracene, Phenanthrene, and Lead to
remain at levels above 15A NCAC 2L .0202 standards as analyzed on December 12,
1994. These concentrations will be allowed to remain within an area consisting of
properties owned by the American Crane Corporation, the Citgo Products Terminal, and
the Koch Refining Company South Terminal. Right-of-ways exist within these properties
for the North Carolina Department of Transportation and CSX Transportation. The
Citgo Products Terminal, the area proposed for a variance, and all adjacent properties
are zoned by the City of Wilmington as "HM -Heavy Industrial District".
In 1951 Amoco Oil Company constructed an asphalt products terminal at this
location. Due to routine loading and storage activities releases of petroleum, products
occurred at the terminal over a number of years. In July 1988 the company conducted
a site assessment of soils and· groundwater at the facility. In 1989 the Department
required that the Amoco Oil Company conduct a Comprehensive Site Assessment. The
Citgo Oil Company acquired this terminal from the Amoco Oil Company on April 30,
1993. Pursuant to investigative activities to complete a Comprehensive Site
Assessment, the Amoco Oil Company found petroleum hydrocarbons and lead in
groundwaters on adjacent properties to the west of the terminal on March 31, 1994. On
April 12, 1994 the Division of Environmental Management concurred with the Amoco
Oil Company that the source of groundwater contamination had been adequately
assessed and that the Comprehensive Site Assessment was complete. On August 25, 1994
the Amoco Oil Company requested this variance in accordance with 15A NCAC 2L
.0113(a) and (b).
Analysis of groundwater samples from monitoring wells within the area of the
proposed variance have demonstrated a progressive decrease in BTEX concentrations
since August 19, 1994. No increases in groundwater concentrations for Anthracene,
Benzo(a)anthracene, Fluorene, Lead, Naphthalene, and Phenanthrene have been reported
since that time. During the last semi-annual groundwater analysis one well showed
Benzene at approximately 0.010 milligrams/Liter and Ethylbenzene at 0.340
milligrams/Liter. The 15A NCAC 2L .0202 Groundwater Quality Standards allow a
maximum of 0.001 milligrams/liter for Benzene and 0.029 milligrams/liter for
Ethylbenzene. The company has conducted a health-risk assessment and have
demonstrated through environmental modeling and calculations that the risks to public
health and safety from granting a variance for this location are minimal. Computer
modeling does not indicate contaminant will exceed the 15A NCAC 2B .0200 Water
Quality Standards when migrating groundwaters discharge into the Class SC Tidal
Surface Water of the Cape Fear River.
Six water supply wells exist within a 1/2 mile radius of the Citgo Products
Terminal. Five of these water supply wells are used to provide industrial process water
and are not used for drinking. Only Atlantic Marine Incorporated uses a well for
drinking. This water supply well was constructed in the Castle Hayne Aquifer, is
approximately 700 feet from the area proposed for variance, and is located "cross-
gradient" from the direction of groundwater flow. The Amoco Oil Company does not
believe that this variance will effect the water supply well owned by Atlantic Marine
Incorporated. There are no other known public or private water supply wells within a 1/2
mile radius of this location. The City of Wilmington Engineering Department has
confirmed that underground water supply utility lines are set at a depth too shallow to
be impacted by granting this variance.
2) Allow for the restoration of groundwater without requiring remedial actions
in accordance with 15A NCAC 2L .0106(j). The Amoco Oil Company has demonstrated
that requirements of the groundwater rules cannot be achieved by using best available
technology (BAT). Cleanup using best available technology would require pumping the
groundwaters from beneath the land, treating these groundwaters to remove
contaminants, and returning the treated water. Another kind of best available
technology relies on the introduction of air into the subsurface to stimulate the growth
of naturally occurring microorganisms that breakdown petroleum hydrocarbons. The
Amoco Oil Company believes that using technology that relies on pumping groundwaters
or the introduction of air will not effectively reduce concentrations of petroleum
hydrocarbons and lead due to the presence of adjacent plumes of contaminated
groundwater on nearby properties.
There is an area of groundwater contamination to the west of the Citgo
Products Terminal. This plume of contaminated groundwater was identified as a release
of gasoline and lead from the Koch Refining Company South Terminal. Another area
approximately 100 feet to the south and east of this location has a separate plume of
groundwater contaminated with petroleum hydrocarbons. These unassociated areas of
groundwater contamination have much higher concentrations of petroleum hydrocarbons
than the area of contamination from the Citgo Products Terminal. The company believes
that re-contamination of the groundwaters within the area of the proposed variance will
likely result if a best available technology is relied on as a cleanup option.
The Amoco Oil Company has estimated that the total costs of implementing
best available technologies to cleanup this area ranges from $ 294,000 dollars to $
3,100,000. The company believes that if cleanup using best available technology is
implemented a serious financial impact would be incurred without equal or greater
public benefit.
Amoco Oil Company maintains that conditions exist within the area proposed
for a variance that will allow for the natural processes of dilution, filtration, chemical
transformation, and biodegradation to eventually reduce levels of these contaminants
below the Groundwater Quality Standards of 15A NCAC 2L .0202. Groundwater
monitoring will continue to be required by the Division of Environmental Management
if this variance is granted. On February 6, 1995 the Wilmington Regional Office
confirmed that other known sources of groundwater contamination around the location
proposed for a variance have been assessed and are being remediated under separate
regulatory actions.
The hearing will be held as follows:
WILMINGTON
August 3, 1995
7:00 PM
Cape Fear Community College
411 North Front Street
Auditorium
Oral Comments may be made during the hearing, or written statements may be
submitted to the agency by September 4, 1995. Written copies of oral statements exceeding three
minutes are requested. Oral statements may be limited at the discretion of the hearing officers.
Please forward comments or information requests to:
David Hance
EHNR-DEM-Groundwater Section
P.O. Box 29535
Raleigh, NC 27626-0535
Phone: [phone]
Fax: [phone]
MEMORANDUM· 05/05/95
TO:
FROM:
SUBJECT:
Carl Bailey
David Hance~-
Dr. Ken Rudo's response to the Proposed Variance for the Amoco Oil
Company-Citgo Products Terminal Facility.
On May 2, 1995 the Groundwater Section sent a letter to Dr. Ken Rudo
concerning a proposed variance for the Amoco Oil Company-Citgo Products Terminal.
The letter stated that all necessary activities were completed to meet the requirements
of 15A NCAC 2L .0113 and that the variance was ready to proceed to the Director of
the Division of Environmental Management for review in accordance with 15A NCAC
2L .0113(d). The letter also informed Dr. Rudo that if the Division of Epidemiology still
had concerns about this variance request they coufd contact the Groundwater Section
Chief to discuss the request, if necessary.
At 9:39 AM on May 4, 1995 Or; Rudo informed me by telephone that the Division
of Epidemiology has "no problem" with the Groundwater Section proceeding with the
approval process, as outlined in 15A NCAC 2L .0113, for a variance at the Citgo
Products Terminal Facility. He said that the Division of Epidemiology felt that the
"work that the Groundwater Section staff has done on this variance was good'. Dr.
Rudo stated that the Division of Epidemiology felt that "risk management decisions"
should be "the ca_ll of the Division of Environmental Management!'. He further stated
that in response to the letter "no meeting was necessary between him and the
Groundwater Section (staff/'. Dr. Rudo informed me that he did not feel a written
response to the May 2, 1995 letter was needed.
If this phone contact is deemed sufficient to address our May 2, 1995 letter then
there is no further need for discussion of this variance with the Division of
Epidemiology prior to public notice. Since no other outstanding issues have been
identified by the Groundwater Section staff in the Wilmington Regional Office or the
Division of Epidemiology, this variance should proceed with the reviews and public
notice in accordance with 15A NCAC 2L .0113(d-h). If you wish to discuss this note
please call me at extension 428.
cc: David Hance
..
♦ An additional round of groundwater sampling, copy of results attached, was recently conducted
in the proposed variance area. Concentrations for ethylbenzene, and xylenes decreased in
groundwater analyzed from MW-22. Concentrations decreased for toluene, and increased for
ethylbenzene and xylenes in groundwater analyzed from MW-23. Concentrations were found
to be not detected at the reporting limit of 1.0 ug/1 in groundwater analyzed from MW-24. Only
concentrations of ethylbenzene remains to be detected above the 15A NCAC 2L standard of 29
ug/1. The attached Table 2-1, from the variance application, shows a history of groundwater
data from the subject variance area.
In conclusion, we are not withdrawing our recommendation for a variance on the basis of Ken's
commentary. The Koch well is cross-gradient and about 220 feet away from the variance area, not in the
projected down-gradient flow path of the plume. A second plume, recently discovered at the Koch terminal,
is legally a separate issue, and must be addressed as such. If you feel that a meeting is necessary with the
Division of Epidemiology, we will be glad to meet in Raleigh to discuss this matter. If any additional
infonnation is needed in the interim, please let us know.
Attachments
RSS/CFS/BAR
cc: WiRO-GWS
s: \gws\bruce \mou.jan
I
Mr. Arthur Mouberry
Page 2
December 8, 1994
The EES feels that these health-based concerns warrant the
recommendation not to grant a variance at this site. The EES
looks forward to evaluating any future information from the
terminal site that may assist the Groundwater Section in
reviewing any further variance requests from AMOCO at the Citgo
Terminal.
If you have any questions, please feel free to contact me at 733-
3410.
cc: Dr. John Freeman
® rn@ m rcv:Pm rm
DMSION OF ENVIRONMENTAL MANAG~ DEC 1 6 1994 mJ
GROUNDWATER SECTION
December 15, 1994
··--·--------·-------------
MEMORANDUM:
TO:
FROM:
Charles stehman, Regional Groundwater Hydrogeological
Supervisor, Wilmington Regional Office
Arthur Mouberry, P.E., A;)
Chief, Groundwater Section~
SUBJECT: The Division of Epidemiology Risk Assessment Method
Recommendation Concerning the Variance Application for
the Citgo Products Terminal in Wilmington, North
Carolina.
On November 22, 1994 the Wilmington Regional Office sent a
technical review of the request for a variance from the Citgo
Products Terminal in Wilmington, North Carolina to the Groundwater
Section Chief. The Groundwater Section has since received a review
of the risk assessment methodology for the contaminant levels found
at the Citgo Products Terminal on December 8, 1994. ~he Division.
of EpideMiology has .reco,aended that a variance for this site not
be granted based on. concerns expressed in Dr. Rudo's letter.
Attached is the letter containing Dr. Rudo' s comments and the
original information submitted by the responsible party. P1ease
review this variance in terms of the requirements of 15A NCAC 2L
.0113(c)(1-9) and (d) with a consideration of these comments from
the Division of Epidemio1ogy.
If you have any questions concerning the information contained
in the attachments, please contact Dr. Ken Rudo at the Division of
Epidemiology at [phone].
cc: Carl Bailey
Dr. Burrie Boshoff
David Hance
Dr. Ken Rudo
.. JAN 05 '94 02=49PM REMEDIATION TECH INC
Mr. Reed
Januaiy S, 199S
Page2
P.3/9
as 11 DUP''), which exhibited a total BTEX concentration of 428 µ,g/L. These data represent
a slight increase compared to the BTEX concentration recorded for this well in February
1994 (308 µ,g/L). The sample from MW-22 exhibited a tot.al B1EX concentration of 700
µ,g!L, This value is 40% lower than the BTEX concentration observed in February 1994
(1,170 µ,g/L ), and continues the downward trend in constituent concentrations that has
occurred at each sampling event since September 1991, The cuITent BTEX concentration
at MW-22 is only 35% of the concentration recorded in the September 1991 sample (1,999
µ.g/L).
It should be pointed out that ethylbenzene is the only volatile organic compound
that exceeds the 15A NCAC 2L standards in the December 1994 samples, which is
consistent with the February 1994 sampling event. Additionally, benzene was not detected
in any of the December 1994 samples, which also is consistent with the February 1994
sampling event Despite the absence of benzene at detectable levels within the area of the
variance request, however, the variance request risk assessment did evaluate the results of
benzene transport and exposure, assuming a benzene concentration of 5 µg/L (the sample
quantitation limit). EPA risk assessment guidance. recommends that the SQL be used as
a conservative value when a non-detectable compound has previously been reported at a
site.
The data from the December 1994 sampling event demonstrate that natural
attenuation mechanisms are effectively reducing hydrocarbon concentrations at the site.
Amoco and RE1EC believe that these data are strongly supportive of variance request for
this area. If you have any questions or comments, please call Jim Schaeffer, Amoco's
project representative at [phone], or me at (919) 967•3723.
Sincerelyt
REMEDIATION TECHNOLOGIES, INC.
/1(-C~Z::,
Mark S. Westray
Senior Project Manager
Attachment
cc: T.W. Farrior, Jr. -CITGO, Savannah, GA
G.L. Gihnan -Amoco, Chicago, IL
R.E. Hannah~ Koch, Wichita, KS
D.E. Klemm -S&:ME, Spart.anbur& SC
J.T. Schaeffer -Ecova/Amoco, Atlanta, GA
T.W. Segar -Koch, St. Paul, MN
msw\amoco 1757\gwdata.let
•
Mr. David Monroe
North Carolina Environmental Management Commission
August 25, 1994
Page 2
Additionally, proposed remedial measures at the Citgo Products Terminal will mitigate the
source of hydrocarbons affecting the groundwater in the area of the variance request,
which will facilitate gradual restoration of groundwater quality in this area through natural
attenuation .· Therefore, Amoco considers that approval of this variance request and
implementation of a groundwater monitoring program is consistent with the risks posed
by the site and the current and future uses of the properties in the area, and is protective
of human health and environmental quality.
We appreciate the thoughtful consideration of this request by the Environmental
Management Commission. If you have any questions, or require additional information,
please _contact Jim Schaeffer at [phone].
Sincerely,
r~-&o!~
Manager -Remediation Services
ST:js
Endosure
cc. G. L. Gilman -Amoco Oil, Chicago
R. E. Hannah -Koch Material Company
S. S. Innes -Ecova, Alpharetta
L. A Quirk -Ecova, Golden, CO
J. T. Schaeffer -Ecova/Amoco Oil, Atlanta
T. W . Segar -Koch Industries Inc., St. Paul, MN
C. F. Stehman -NCDEM, Wilmington Regional Office
M. S. Westray -ReTec, Chapel Hill, NC
s P.2/2
The Groundwater Section has completed its review of this variance request.
Please note that based on all present materials in the variance application, the
Groundwater Section believes that the information submitted meets the requirements
of 15A NCAC 2L .0113 (b-d) and that this request for variance for the Citgo Products
Terminal should proceed to the Director of the Division of Environmental
Management for approval in accordance with 15A NCAC 2L .0113(d).
If you would like to discuss this matter further and the attached information, please
call me at 733-3221. If you think a meeting between you and staff at the Wilmington
Regional Office is necessary, I would be glad to host such a meeting. Included the
attached information is groundwater monitoring information from the semi-annual
monitoring event in December 1994.
ATTACHMENTS:
cc: Carl Bailey
Dr. Burrie Boshoff
David Hance
Wilmington Regional Office Groundwater Supervisor
@
RECE\VED
April 10, 1995 APR 1 2 1995
Arthur Mouberry, P.E. )OLLU1ION r.nNTROI RRANrl
Chief, Groundwater Section
North Carolina Department of Environment, Health and Natural Resources
Division of Environmental Management
l;l~h:-1
127 Kingston Drive
Chapel Hill, NC 27514
[phone]
FAX [phone]
C,
r-,1 -512 North Salisbury Street .,_o
c.Y1
~ '-0
...>
Raleigh, North Carolina 27604
RE: Revised Request for Variance Under 15A NCAC 2L .0113 for Amoco Oil Company
CITGO Products Terminal (Formerly Amoco Asphalt Terminal)
~
• ?')
G°)-<'''''(l
--:.O'c-> om C--;
:: §~~
Wilmington, North Carolina
.,,. ,,__, ,..,,.,,. ___
~ ¾~1 (,:) ?J:.;-o
Dear Mr. Mouberry:
... c.r,
{'.) ,-;1
6' ·o
On behalf of Amoco Oil Company (Amoco), Remediation Technologies, Inc. (RETEC) is submitting
this revised request for a variance to Groundwater Classification and Standards in accordance with the
provisions of 15A NCAC 2L .0113. The original variance request was submitted on August 25, 1994 and has
been revised subsequent to the receipt of comments from the Division of Environmental Management (DEM)
in the letter dated February 17, 1995. Sections 2.5, 2.6, and 2.7 of this request have been revised to supply
the additional information requirements identified by the DEM. Additionally, Table 2-1 has been revised
to incorporate the results of groundwater sampling performed in the area of the variance request in
December 1994. These results demonstrate that groundwater in this area slightly exceeds the 15A NCAC
2L standard for ethylbenzene only.
It is important to recognize that, in the time since the original variance request was submitted,
implementation of the Corrective Action Plan at the CITGO Products Terminal has begun. This fact is
noteworthy since remediation of upgradient hydrocarbon sources that have impacted the groundwater in the
area of the variance request will facilitate improved groundwater quality in this area through natural
attenuation processes. Therefore, approval of this variance request is consistent with the risks currently posed
by the site, is protective of human health and environmental quality, and is benefited by the operation of the
Corrective Action program at the CITGO terminal.
We appreciate the continued review of this request by the DEM. If you have any questions or
require additional information, please contact Jim Schaeffer at [phone].
Sincerely,
~~ms,rnc.
Mark S. Westray
Senior Project Manager
Enclosure
cc: G.L. Gilman -Amoco Oil, Chicago, IL
R.E. Hannah -Koch Materials Company, Wichita, KS
J.T. Schaeffer -Ecova/Amoco Oil, Atlanta, GA
T.W. Segar -Koch Industries, Inc., St. Paul, MN
C.F. Stehman -NCDEM, Wilmington Regional Office
REMEDIATION TECHNOLOGIES INCORPORATED
OFFICES NATIONWIDE
I,
achieve Groundwater Quality Standards at this site,
include projections of construction and yearly
maintenance costs for groundwater remediation.
3) Supporting information to establish that compliance would
produce a serious financial hardship must be included in
the application to meet ~he requirements of 15A ~CAC 2L
.0113(c)(6).
4) S_upporting information to establish that compliance would
produce a serious financial hardship without equal or
greater public benefit must be included in the
application to meet the requirements of 1 SA NCAC 2L
.0113(c)(7).
The additional information in items I 1 through I 4 must be
provided so that the Groundwater Section can properly evaluate the
technical information and verify to the Director that it meets the
requirements of 1 SA NCAC 2L • 0113 (c). Once the Groundwater Section
deems a variance request has met these requirements, it can proceed
to the Director for review in accordance with -15A NCAC 2L .0113
(d). For these reasons the variance request is being returned to
you. If you wish to pursue a variance to -the Subchapter 2L rules
you will need to submit information that -addresses items #1 through
#4~
If you have any questions concerning this letter, please
contact Mr. Charles Stehman at the · Wilmington Regional Office,
Groundwater Section at ( 910) 395--3900.
AM/dah
cc: Arthur Mouberry
Carl Bailey
Burrie Boshoff
Sincerely,
~~½
Arthur Mouberry, P.E.t:{
Chief, Groundwater Section
Wilmington Regional Groundwater Supervisor
David Hance
Dr. Ken Rudo
Jim Schaeffer (Amoco Oil Company)
2
On September 27, 1994 a copy of this variance request was sent to Dr. Ken Rudo,
Division of Epidemiology, for review of the risk assessment methodology. Comments on this
variance from Dr. Rudo will be provided upon completion of this review.
In addition, the memorandum indicated that a plume of petroleum free product was
discovered by Koch Industries " ... just ~ul°h of the requested variance area" on August 29,
1994. You indicated that this contamination did not appear to be a part of the petroleum
release considered. in this variance request. The party(s) responsible for this second free
product plume must complete site assessment and initiate corrective actions according to
15A NCAC 2L. 0106 or apply for a variance in accordance with the requirements of 15A
NCAC 2L. 0113.
cc: Carl Bailey
Dr. Burrie Boshoff
David Hance
I ;1/-1/()?f cf E ;If E;lf O.·
\-OATE: r~ '2~/(J -/4~ TO:
FROM: ~-I/
SUBJECT:
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YLO CJMSi'Yv(t,m \,,
NC DEHNR ~"ds
DEM-GR?UNDWATER SECTION -;:-
j f-I-' kl1~ +1-(,s WI/> C!llr--. * ,~ c.f:1.-CAs+/eJ.A~
.. •
August 25, 1994
Mr. David Monroe, Chairman
North Carolina Environmental Management Commission
c/o Preston Howard, Director
North Carolina Division of Environmental Management
512 North Salisbury Street
Raleigh, North Carolina 27604
Request for Variance to NCAC Title 15A, Subchapter 2L-Groundwater Classification
and Standards
Citgo Products Terminal (Formerly Amoco Asphalt Terminal)
Wilmington, North Carolina
-----Oear Mr: Monroe,------··-·---------· --~
Amoco Oil Company (Amoco) is submitting this request for a variance to the North
Carolina Administrative Code (NCAC) Title 15A, Subchapter 2L -Groundwater
Classification and Standards, in accordance with the provisions of 15A NCAC 2L §.0113.
The area for this variance request is predominantly located on the property of the Kc;>ch
Refining Company South Terminal within a heavily industrialized section of the City of
Wilmington. The entire area is zoned "HM -Heavy Industrial District", and the nearest
area zoned for residential development is approximately one-half mile northeast
(hydraulically upgradient) from the area of this variance request.
The groundwater within the area of the variance request has apparently been impacted
by past releases of petroleum hydrocarbons from upgradient sources on the Former
Amoco Asphalt Terminal (now the Citgo Products Terminal). Currently, the groundwater
within this area slightly exceeds the 15A NCAC 2L standards for ethylbenzene, and total
xylenes. However, as detailed in Appendix A of the attached variance request, a
thorough site-specific risk assessment has demonstrated that the observed concentrations
of hydrocarbons in the groundwater do not pose a significant risk to human health or the
environment. Based on the highest hydrocarbon concentrations present, the results show
that the estimated individual excess lifetime carcinogenic risk (IELCR) and hazard index
(HI) are less than 1 x 10-e, and 0.1, respectively, for all potential pathways and receptors.
An IELCR and HI less than 1 x 10-e, and 1.0, respectively, are considered by the USEPA
to be protective of human health.
..
Mr. David Monroe
North Carolina Environmental Management Commission
August 25, 1994
Page 2
Additionally, proposed remedial measures at the Citgo Products Terminal will mitigate the
source . of hydrocarbons affecting the groundwater in the area of the variance request,
which will facilitate gradual restoration of groundwater quality in this area through natural
attenuation.· Therefore, Amoco considers that approval of this variance request and
implementation of a groundwater monitoring program is consistent with the risks posed
by the site and the current and future uses of the properties in the area, and is protective
of human health and environmental quality.
We appreciate the thoughtful consideration of this request by the Environmental
Management Commission. If you have any questions, or require additional information,
please ~ntact Jim Schaeffer at [phone].
1 70 Sincerely,
f~·&o!~
Manager -Remediation Services
ST:js
Enclosure
cc. G. L. Gilman -Amoco Oil, Chicago
R. E. Hannah -Koch Material Company
S. S. Innes -Ecova, Alpharetta
L. A. Quirk -Ecova, Golden, CO
J. T. Schaeffer -Ecova/Amoco Oil, Atlanta
T. W. Segar -Koch Industries Inc., St. Paul, MN
C. F. Stehman -NCDEM, Wilmington Regional Office
M. S. Westray -ReTec, Chapel Hill, NC
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. S. B. Thomas, Manager-Environmental Services
Amoco Oil Company
375 Northridge Road, Suite 350
Atlanta, Georgia 30350-3296
Dear Mr. Thomas:
Subject: Additional Information Request
Variance to I SA NCAC 2L
Amoco Oil Company
Wilmington
New Hanover County
The Division has reviewed the subject variance request. The Division asks that Amoco Oil
Company provide a direct answer to the information required by ISA NCAC 2L .0113(c)(6) and (7). Once
the additional information is received, the Division will review and proceed appropriately.
Please submit the requested information within 60 days to the attention of Mr. Arthur Mouberry,
Chief of the Groundwater Section, at the address found at the bottom of this letter.
If you have any questions concerning this letter, please contact Mr. David Hance at [phone].
cc: Arthur Mouberry
Rick Shiver
Sincerely,
A. Preston Howard, Jr., P.E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer
DMSION OF ENVIRONMENTAL MANAGEMENT
GROUNDWATER SECTION
October 19, 1994
MEMORANDUM:
TO:
FROM:
SUBJECT:
Charles Stehman, Regional Groundwater Hydrogeological
Supervisor, Wilmington Regional Office
Arthur Mouberry, P.E., ~
Chief, Groundwater Section (!J:/"
Review of Request for Variance from 15A NCAC 2L .0106 Corrective Action
Plans and 15A NCAC 2L .0202 Groundwater Quality Standards by the Amoco
Oil Company at the Citgo Products Terminal in Wilmington, North Carolina
On August 25, 1994 the Amoco Oil Company submitted a request for a variance to
the Wilmington Regional Office. You will recall this request was for a variance from
Corrective Action requirements of 15A NCAC 2L .0106(g) and Groundwater Quality
Standards in 15A NCAC 2L .0202 at the Citgo Products Terminal. In a September 16, 1994
memorandum the Wilmington Regional Office (WIRO) provided· comments and a
recommendation on this variance request. The WIRO restricted its comments to an
evaluation of drinking water wells and a discussion of the presence of hydrocarbon
constituents within the vicinity of the proposed variance.
'ii,
It is important to note that 15A NCAC 2L .0113(d) requires the Director to review
this variance request for completeness prior to proceeding with public notice, public
hearing and Environmental Management Commission review. In order to provide a
comprehensive examination of this variance application in accordance with 15A NCAC 2L
.0113, please review the request in terms of the requirements of 15A NCAC 2L .0106
Corrective Action to determine if a no corrective action would be as effective as an active
CAP to remediate groundwaters at this site. If a determination is made that a CAP
involving active groundwater remediation is not necessary, please review the request for
a variance in terms of the requirements itemized in 15A NCAC 2L .0113, (c) {1-9), and (d).
Verify technical data provided in support of the request.
Please prepare a letter for the Director's signature providing your conclusions
regarding the request for relief from corrective action plans under 15A NCAC 2L .0106,
the variance request, and any additional requirements that are deemed appropriate.
If possible, please return your recommendation to me by Tuesday, November 18, 1994.
On September 27, 1994 a copy of this. variance request was sent to Dr. Ken Rudo,
Division of Epidemiology, for review of the risk assessment methodology. Comments on this
variance from Dr. Rudo will be provided upon completion of this review.
In addition, the memorandum indicated that a plume of petroleum free product was
discovered by Koch Industries " ... just south of the requested variance area" on August 29,
1994. You indicated that this contamination did not appear to be a part of the petroleum
release considered in this variance request. The party(s) responsible for this second free
product plume must complete site assessment and initiate corrective actions according to
15A NCAC 2L. 0106 or apply for a variance in accordance with the requirements of 15A
NCAC 2L. 0113.
cc: Carl Bailey
Dr. Burrie Boshof f
David Hance
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A Preston Howard, Jr., P.E., Director
RA
D E HNR
September 27, 1994
MEMORANDUM:
TO:
FROM:
Dr. Ken Rudo, Ph.D, Toxicologist,
Environmental Epidemiology Section
Arthur Mouberry, P.E., Chief ,N /
Groundwater Section ~
SUBJECT: Amoco Oil Company Request for Variance from
15A NCAC 2L .0202 Groundwater Quality Standards
for the Citgo Products Terminal in Wilmington, North
Carolina
Attached is a variance request on behalf of the Amoco Oil
Company of Atlanta, Georgia from Remediation Technologies
Incorporated. The request for variance is to groundwater standards
for Benzene, Ethylbenzene, Toluene, Xylene (-o,-m, and -p),
Naphthalene, Fluorene, Anthracene, Benzo(a)anthracene, Phenanthrene
and Lead. The request is for a site contaminated by a petroleum
storage product terminal. The area for which the variance is
requested is owned by the Koch Refining Company and is believed by
the Amoco Oil Company to be downgradient from the Citgo Products
Terminal. The Citgo Products Terminal has been primarily used as an
asphalt blending and storage facility. According to information
submitted by the company, the Citgo Products Terminal and the area
for the proposed variance are in a heavily industrialized zone that
is surrounded by numerous operating petroleum product storage
facilities. Monitoring well data indicates contamination in excess
of groundwater standards in 15A NCAC 2L .0202. Numerous product
transmission lines and water lines can be found thr.oughout the
area. The Amoco Oil Company does not believe that any public
benefit can be gained through groundwater remediation efforts.
Please review the attached report and provide the Groundwater
Section with a recommendation regarding this request. If possible,
the Section would like to receive your recommended response by
November 1, 1994. Upon receiving your recommendation, the Section
will forward a recommendation to the Director of the Division of
Environmental Management.
If you need additional assistance or information please call
me at 733-3221.
cc: Carl Bailey
Dr. Burrie Boshoff
David Hance
Wilmington Regional Office Groundwater Supervisor
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 1 0% post-consumer paper
P,-;:'/16
8
26; 1996 well sampling results. The laboratory analysis conducted on the
sample from the monitoring well MW-23 is reported as 'free product•. The
laboratory's cover letter to the analysis states that 'In summary, the product
found in MW-~~ is not similar to fresh gasoline, but was similar to or
c,,nta.i.ned wea-=.her=d ::a~oline'. The other two monitoring w~l1e located in the
area for which the va:::'iance is requested also showed an increase in several
conatituent concentrations between the February 26th and earlier analytical
Tn i, 0ht o-F -the most recent February 25·, 1996 analytical data, a copy of
,,.,.; rh , "' ,,, .... t:"l•~hio,d, it would be <lifficult fer me to support the :requested
·, ',;r,r~ .;_n.:'i t.hPreby a'?nial is r~commended.
Pleas~ cnntact rr.~ if yo~ have any questions concerning the report.
'
)
, ..
9
P.1 ,:e 3
Anr.1co !';L' C:,rn_pany
INT"Fl.ODUCTION
In 1;s: ~~oco Oil company (Amooc) constructed an asphalt blending,
st~raqe~ an" ==~es f.acility. P.mcoo operated t~e facility until April 30, 1993,
at. w~ich t.l.L':,A l.~ was ~c~.li.red by CITGO Petroleum CGrporation {CITGO). '!'he
,:::r,:,r.,o tP-rrni •\;<. i rAt:1 l i t.·,1 is lccated on River Road in Wilmington. The terminal
,,:,nsists cf a.~,9ro.i{i:natP.:.Y 31 acres of land and is about 900 :feet e2st of the
Ca-'?"" Fear .-'.iv0::: { :;ee di-e1q:::-am attached). As a result of day~to-day terminal
o r,e".".'J.tions ccc.?.Eional ~?ills and leaks have occurred throughout the years and
hav,-,. r..c;1u,;@ci r.n~:-.e..m i .,,,,t ~.on cf the subsurface soils and. groundwater. Amoco has
"ICl'! .. :1r .... ri ri=>t-'"f'i,:1~ i rd 1 j tv for delineating, evaluating, and implementing
:;,:r,,roo::iate, remedial rnea$i;;-;;-es fc::: the off-site portion of the dissolved.
r .... ~.~\,:-;:-;r~.7'8t:"Jr r-1 nm@ '!':hnt (').'t"icrinated from what is now the CITGO Producte
!ni~~a1 tP-s~ ~ori~g£ gnd monitoring wells we~e in~talled in 1988. The
~-•~ion s?.~t a ¥.arc~ 1939 Notice of Violation for ths exceedance of
i::..::·.:m::,:'.wate.!..· a'.la:d ::y standa:::-ds in three of -c.he twelve monitor_ing wells pursuant
.. ,.,, 1-,:,, ~CAC :?T,. Ni r:::; adcit!.onal monitoring v,rell5 wer12 installed in 1990. In
~-1:.::.-:a"t. .;f 1g91 three monitoring wells were installed along the western ed.,;e of
r~~ ~i,7pr Ro~d r.i~ht-cf-way (hsld by NC DOT, see diagram attached}. The
, nt"'r-+-nf t;h.,.. mc-F1 i t..od ng was to determine if the groundwater plume had
x:arateC ber&~ath Riv·e:::i Road ontc the adjacent Koch Refining Company (Koc.hJ
Tn ,~n the "OEM. Wilmington Regional Office requested that additional
~ •·-, ,-jr,., o;= t.hP. ~,u'Tle bP. made. In response, seven permanent rnonitorinq
·•(' ~::..~ w~re i:.stallad on ths property ow~ed by Koch Refining Con1pany (Koch} and
1..2 t.e::nporarv •-1elle weire installed on property owned by tne American Crane
r~rnorat;"" w~,c~ ~s ~our~ nf the CITGO and Koch terminals.
;.!" ap~,,..OV!";ci Cor.rect-.ivs A:::::tion Plan (CAP) is r:•.1rrently b2ing implemented at t:he
r:: 0 -F-;_,.. ~parqina walls have been instal.J.ed on site and down
<1:::t.dii=.:1t en the adiacent hmerican Crane Corporation prope.rty.
A va,ie~cP. f~om ,5A NCAC 2L .0202 {groundwater quality standards} and
'.::11, NC?C 2L .Cll06{"1) {correctiv@ action) is requested by Amoco for the
.,r,·cn:,.,.ximate -ewe acre <;.~ea located on and acroas Ri,•er Roao, on propert.ie5
Ol-,;'r,ect bv tl"i"" C:.i ':.:,"'"' Prnduc-:s Ter.mina.l, Ths American crane CO.?:pcration, CSX
'rr;=,,ns9ot;"~,a-:-i,;1n, ar.c ~och Refining Company. The land !.n which the area of the
~~r.iar.c~ en~o~ca~s~s the most offsite property ~5 owr.ed by Koch. Amoco has
~~de r.hLs v~r1fn~~ c~c-ue5t by filing an application in accordanc~ with part1 ~)
Pu~=uR~t to lS~ Nc~c 2L .0113 (d) and (e), public notice cf this
v "'rit":f'! rPqIJP5·t w;.s 5f!11t tc, adjacent property owner5, the New Hanover Count.
r l~~ Dire~tor. the C~ty Manager for the City of WLlming~on, and the Mayor of
l' ~n,_., • -; c.e: of' t.hi f; h"!,eiri ng was also published in the July 2, 199S
._1n11 c..,.=1 :::ir J.J. • .1.c.r-11·1
10
edition a~ the fil1D'J..p__gt:,pr1._§~~..§¥.§. to meet requirements of lSA NCAC 2L
,0113{~)(11(A). In accition, approximately 500 notices of this variance
reqi~est were ee~t to persons listed in the 'Groundwater Variance and
R~gulatory Actions Mailing List' to meet the ;requirements of l5A NCAC 2L
.0113(-"!) (1) (:n. Prior tc t:ie p~blic Hearing a press ;release was sent to all
newspaper companies television stations, and radio stations that serve New
11. rmh1 tr-: h9=.ir-ng wa~ h~ld on August 3, J995 at 7:00 at the Cape !c'ear
(:o~.:::unity co.Llege, 411 North Front Street, Wi,1::ni.ngton by the Department of
F:"lvir.onrr'.E>nt, ~P!:l1.·l"h .-.1nd NaturAl Rll!source.s en behalf of the Environ.-nental
Y.;aiT'aqem~""it Co"'_m5 ~sion t'.o receive public com.,nent in re5ponee to notice of the
variance reouest. A total of tw@lve registered persons attended the hearing,
with t~o people presenting oral comments. W~itten comments were submitted by
one cf the speakers. No other written comments were received. The hearing
record allowed for written comrriepts to be submitted through September 4, 1995.
M~-Bruce Reed of the Wilmington Regional Office, DEM initially presented an
SUMt1ARY OF COMMENTS AND RESPONSES
WrLtten/verbai commenta and there respective respons~s are ehown as tollows:
one Gommentcr objected tc the proposed variance that allowg P..~ooo Oil
Ccm~any to 1eave contamination at this site without performing the corrective
actions n~cessa~y to clean-up this area to the state standards. The commentor
~~~ted that Amoco did not prom~tly cleanup oil and asphaltic product release$
~nat occur~~d from decades ago and should not be allowed to walk away trom
cleanup res"Oons1.oiL;i..ties "iust. because it's 90.in9 to cost them a substantial
-:.., -';C ~ r"' ,;;:; i.c, that Amoco was well aware of it's operations, the
oeo~ocic ervironment and presence of groundwa~er oeneath the terr.iinal, and the
nctential i.mpact.s of' 1~.~k!'I frnm [e-mail] AtP.el C('.')ntainers. Corporations that
:.:.nowi.ngly rel@ase harmfu'.:. s1..1bstance -into the environ.me.mt have an obligation to
The ~@.rson con-.menting is deeply concerned about the effect of pe·.::roleuro
·:n:odcc,;: pol] ution on wetland.s, drinking water, surfac,;i waters, wildlife, and
,'l121.t11!.ns. Sl.::Pp+-i,-1 !-lrn waia1 f'""rr-ess1;>d <3.bout the cJ.air:ns that asrihci.1tic eublf'ltances
and petrolel.!:r, ~:;roducts found at this site will degrade naturally over i:.ime.
~tudie2 c:f thf" 1-rnpaci"r:: :=.~n:n 'l?etroleum releases have shc,wn th1;1.t J nng~term
~ffect~ ot Oil spills ar~ devastating to the environment. In this person's
"\.ew '=ne persi5tence of certain chemical components of petrol~urn releases is
51.:fiicientJ.y long to cause chronic: human heal.th and ecologic probl-erris, and t:-ie
PO/:Jl..~ity er c~~~·t..ami.nanti;: can expose a vast population to chronic he.alt:h
.Jt-·11'1 C.-.:..'..i :::ir l..l • l.-.::IHl'I r'. H'.1/ J.t:,
11
ra•ge 5
A.rr:.cco Oil Compan:,'
F:<-.:spa:1;,e to co::r.ment. # 1
Th@ granting of a variance does not exempt Amoco Oil Company from the
r.ont1r.uP.d rP.5-;->0n~ibi1ity for the site. If a variancei is granted at this site ,
Am::Jco must ma,nta.::..n i'!. gr-oundwater monitoring effort a5 required by the
conditions of a variance and Division directives. Monitoring must continue
for a sufficient period of time to assure that remaining concentrations within
the area of the ~.u:-iance do not increase. It it appears concentrations are
increa:"li.ng due to the past actions of Amoco, the company may ati.l..l :be held
re.!'.pcnsi"ble fer cleanup by th~ Division. If other property owners in the area
r'c!1~a5e substanceR into groundwaters, soil, or land surface within the area
that. the variance was granted, then the appropriate responsible parties will
t-e subject to t;hFI clfl':!anup requirements of 1511. NCAC 2L-
1\,:otive rPm@.diat.ion is underway on portions of the contaminant plume that
~~v~ high~r pollutant concentrations. Whether Amoco 'knowingly' released
t:~,.rnfnl anb!".tnnces 1.nto the environment is unknown.
DP.pe1v;l.ing upon consti.tuent concentrations, petroleum products in the
!'mrfa~e wate:-s and groundwaters do have varying degrees of effect on the
~nvj.rnnTTJ!?J'l+-.. The Co!Tlp~ny has submitted a rii.;k assessment including the
TT1!"-tr;odnl,.,,g-if'-;; uc:,ed ta ~l'lt.imate the impact~ the variance will. have on human
r,o=-;;1th~ th:? envfr.onme>nt, and public welfare. The purpose ot the site specific
~isk assessment is to evaluate the potential adverse impacts associated with
the concentrations in and around the ar~a of the requested variance. ~he
c8~cerr.s of the commentor are noted and additional information was requesteci
f,nrr, Amoco w~ th rel".pect tc the risk assessment.
St~P ,onnitinn~ vnry sjgnificantly from one site to the next. Hydro-
,;iecl.oqiC' chemical/physical pollutant, and physical characteristics all
ro,:,ntribqtt? tr f:'ri!;! r.nmpl.:.·dty of a site. Th@ risk assessment evaluates theee
c~~racter1stics a~d estimates the degree cf risk the site poses to human
~P.~lth and the ~nvironrnent. A risk assessment includ~s the identification o!
exposu~e scenarios, pathways, and human and ecological receptors. Some common
q~cundwater exposure scenarios and pathways are ingestion, non-ingestion
r:-,,1r:ort ,;ucti ai= ir-,:f~..i.t J.on nr swi.nuning, inhalat1.on, and transport to surface
.,,,.:l;'r.
r~ r•~k as~~~~ment conducted in support of the variance request looks
{"'j <" thf'! efft"lct!'I from the plume originating from the Amoco site. 'l'he
pl~m~ origina~ing on the Koch property is located betwe~n the Amoco plume ana
i"b•~ river. The risk assessment evaluates impacts to several rece'Ptore
.i..Itc.l•.tdinq the river. :i.t ooas not include the impact from the Koch Plum~.
~ h~Prcng n~fi~P.r r felt.the need to ask for additional written
infor~~r.ior wj~h r.~~pect to the risk assessment as it was done. In the Amoco
resuonse it was stated that there are several reasons tor not attempting to
-t ~ thA ~o~h ~l~m~. The Amoco Oil Company does not have responsibility
:o:., no::-~cntrol ove:i:-tne releases of petroleum unrelated to ~t5 former
operations at the as~halt terminal. T.hey do not have the data that would be
<=cess-1. fo:r a quaJ itative evaluation cf risk. Therefore, they do not feel
~nat ;s aourouriate for Amoco to attempt to evaluate the ~isks that may
n~~P ; ·h~ ·~ch ·~c j i ty.