NC0026247_Correspondence_19890407

NPDES DOCUWENT SCANNING COVER SHEET
NPDES Permit: NC0026247
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date: April 7, 1989
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Unocal Refining & Marketing Division
Unocal Corporation
13 Corporate Square, N.E.
P.O. Box 4147
/ Atlanta.Georgia 30302
Telephone[phone]
UNOCAL S M
W.E. Herchline
Division Distribution Manager,Atlanta March 20, 1989
Eastern Marketing
FEDERAL EXPRESS
Mr. R. P. Wilms, Director
North Carolina Department of Natural -
Resources and Community Development
512 North Salisbury
Raleigh, NC 27611
Dear Mr. Wilms :
We have received your March 1, 1989, letter of transmittal for the new NPDES permit
for the Southeast Terminal at Greensboro, North Carolina . We feel that our previous
comments on the subject permit have not been addressed. We request that implementation
of the new permit be delayed until such time as our concerns and comments are addressed.
In September of 1988 we received the draft of the permit for this terminal . On
September 29 , 1988, following a meeting with Mr. Arthur Mouberry, we submitted our
comments on the proposed permit. A copy of our comments is attached.
The new permit is virtually unchanged from the draft on which we submitted comments.
Our concerns and comments remain unchanged from our previous submittal ; and, we request
that they be addressed prior to implementation of the new permit.
We would be happy to meet with you or your staff to discuss our concerns. If you
have any questions or would like to arrange a meeting, please call Mr. David R. Keasey
at 404/320-2272.
ly yours,
W. E. Herchline
WEh/cjf
Attachment
cc: C. E. Wells
R. E. Van Deusen
Lula Harris
\_Arthur Mouberry

DIVISION OF ENVIRONMENTAL MANAGEMENT
November 10, 1998
MEMORANGIM
TO: Aurthur Mouberry
FROM: Trevor Clements t(l
Mike Scoville Cbj-
THRU: Steve Tedder i
SUBJECT : DRAFT Permit Comments from Unocal (NPDES # NCO026247, Guilford County)
Technical Services has reviewed Mr . W.E. Herchline's comments regarding
the NPDES Draft permit for the Unocal Southeast Terminal . Responses to his
comments are listed below:
1 . glow Measurement :
The requirement for recording discharge flow rates should not be
deleted . Since Unocal discharges to WSIII waters and it 's discharge
interacts with numerous other oil terminal discharges, it is
essential that DEN have accurate discharge flow measurements to
determine total loading to the East Fork Deep River and thus to
assure adequate protection of the downstream water supply. However ,
combining discharges 002 and 003 with 001 for a single metered dis-
charge point is acceptable and advisable.
2. Settleable Solids:
The settleable solids parameter was added to the list of North Caro-
lina water quality standards specifically with discharges from set-
tling ponds in mind, regardless of the function of the discharging
facility. Since the Unocal discharge is from a retention pond, this
oarameter is very appropriate and should not be deleted . However , if
Unocal would accept a TSS limit of 30 mg/I in lieu of the settle-
able solids limit, Technical Services would not object to it ' s
removal .
3. Turbidity:
The turbidity requirement should also not be deleted. Since Unocal
discharges to the headwaters of a UT to the East Fork Deep River , it
is likely that there will be discharge events when there is zero
flow upstream. Because of this fact, Technical Services recommends
that the turbidity limitation be applied directly to the effluent.
"The turbidity of the discharge shall not exceed SO NTU. "
4. Phenols:
Phenols are limited in Unocal 's effluent based upon the water quality

1
standard for phenols. The 1 .0 ug/1 standard reflects the level
needed to avoid taste and odor problems in the downstream water sup-
ply. It is the goal of DEM to protect the water quality of the WSIII
waters downstream from Unocal . This is complicated, however, by the
numerous other oil terminals in the immediate vicinity whose dis-
charges all interact in the East Fork Deep River. The taste and
odor potential of phenolic compounds is critical at the water supply
below the interaction; to study the taste and odor potential of just
one discharge would serve no purpose.
Unocal 's self-monitoring data from November 1985 to September 1987
reveals that 84% of Unocal 's discharge events exceeded their NPDES
phenolic compounds limit of 0.001 lb/day, and that half of these
non-compliant discharge events occurred while the flow in the East
Fork Deep River was two-thirds of the average flow or less. 38% of
the phenol loading violations were at least one order of magnitude
greater than the loading allowed by their NPDES permit. Such ex-
. ceedences are unacceptable in such close upstream proximity of a
water supply intake, especially given the number of interacting
discharges also containing phenolic compounds.
5. Proposed Compliance Schedule:
Technical Services has no authority to answer to the proposed com-
pliance schedule, although it appears reasonable. Administration
must address Unocal 's comments regarding this matter.
Please let me know if you have any questions or comments regarding these
matters.
cc: Dale Overcash
Winston-Salem Regional Office

a,.STAT[
'fir q„�.W"
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary October 28, 1988 Director
Mr. W. E. llerchline
Division Distribution Manager., Atlanta
Eastern Marketing
Unocal. Corporation
13 Corporate Square, N.E.
P.O. Box 41.47
Atlanta, GA 30302
Subject: DRAFT Permit Comments
NPDES No. NCO026247
Union Oil - Southeast Terminals
Guilford County
Dear Mr. lterchli.ne:
This letter is to acknowledge receipt of your letter dated September 29, 1988,
containing comments on the subject DRAFT Permit. The Division of Environmental
Management will consider your comments in making, its decision on the issuance of the
permit. If you feet that your comments are not addressed in the issued permit, you
may request an adjudicatory hearing in accordance with Chapter. 1.50B of. the General
Statutes of North Carolina within 30 days of :issuance of the permit.
If you have any questions, please contact me at (91.9) 733-5083.
fSSi erely
z L
M. Dale Overcash, P.E.
Supervisor, NPDES Permits Group
cc: Mr. Larry Coble (with attachments)
Mr. Trevor Clements (with attachments)
smk
Pollution Prevention Pays
P.O. Box 27687, Ralcigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

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Unocal Refining&Marketing Division
Unocal Corporation jb64t-41�
13 Corporate Square,N.E.
P.O.Box 4147
Atlanta,Georgia 30302
Telephone[phone]
UNOCALU6
RECEIVED
SEP 1988
September 29 1PET*6b& ENGINEERING
W.E. Herchline r
Division Distribution Manager,Atlanta
Eastern Marketing FEDERAL_EXPRESS
North Carolina Department of
Natural Resources and
Community Development
Division of Environmental Management
P. 0. Box 27687
Raleigh , North Carolina 27611
Attention: Mr. Arthur Mouberry
X
RE: NPDES Permit #NCO026/47
Union Oil Company
Greensboro, Gui l ford County
Dear Mr. Mouberry:
Our comments on the draft NPDES permit for the Southeast Terminal which we
operate at Greensboro, North Carolina, are detailed below:
Flow Measurement: We request that the requirement for recording discharge
flow rates bedeleted. Discharges from -the facility are infrequent, making
flow rate monitoring inappropriate. Discharges 002 and C.)03 do not currently
have flow totalizing meters. We propose a compliance schedule to either
install new metering capacity or combine all outf al l s into a single,
metered discharge point.
Settleable Solids: We feel that settleable solids is an inappropriate
monitoring parameter for a petroleum marketing facility, and request that
it be deleted.
Turbidity: Upstream measurement of turbidity cannot be made at this
facility, since it discharges to the headwaters of an open ditch which
subsequently discharges via an unnamed tributary to the Deep River. Since
differential turbidity measurements cannot be made and since the turbidity
of the receiving water is likely to be high at the time of discharge
(almost all discharged water results from accumulation of stormwater
runoff) , we request that turbidity monitoring be deleted. If the
requirement cannot be deleted, we request that a monitoring-only
requirement be placed upon the discharge (rather than on receiving waters) .
Phenols_ The proposed phenol limit of 0. 001 pounds per- day (0.00033 pounds
per day for each e:,i sti ng discharge point) is the most onerous of the
proposed discharge limitations. Typical storm event discharges are
expected -to be on the order of 70,000 to 100,000 gallons. To maintain
compliance, phenol concentrations would need to be less than 1. 7 to 1 . 2
micrograms per liter , a level that we do not believe is achievable' without
cost prohibitive treatment and/or source segregation.

Page 2
Mr. Arthur Mouberry
September 29, 1988
It is our understanding that the proposed phenol limits are based upon the
taste and odor potential of phenolic compounds that are subject to
chl on nati ons in a water treatment plant. Since taste and odor problems
are highly dependent upon the class of phenolic compound being chlorinated ,
a more appropriate requirement would be to base the discharge limit more
directly upon the actual taste and odor potential of the discharge. we
propose a compliance schedule to determine a more appropriate discharge
limit for phenol .
PROPOSED COMPLIANCE SCHEDULE
Flow Measurement and Di scharge_Ftout i ng; Current discharge is via out+all s
0011 002, and 003. Only out+al 1 C)0 i s now equipped with a flow totalizing
meter. We request that we be allowed a compliance schedule to determine
the feasibility of combining the discharges of the three existing out+al 1 s
or to provide separate metering capability for each of discharge points and
then to install the required new facilities. We suggest the following
schedul e.
2 months a+'ter a+f ecti ve Commit to combining all discharges into
date of permit one, or providing separate metering
for discharges.
4 months after date o+ Preliminary engineering design
permit complete on new facilities.
6 months after date of Final engineering complete
permit on new +aci 1 i ti es.
9 months after date of Begin construction
permit
12 months after date of Complete construction
permit.
Phenol_Limits: We estimate that an initial study of the taste and odor
potential of our discharges would take several months to complete. I+
additional facilities are required we would need additional time for design
and construction. We suggest the following schedule:
6 months after date of permit Taste and odor study
completed. Alternate
permit limits developed.
Determine if new facilities
are required.

•t
Page 3
Mr. Arthur Mouberry
September 29, 1988
If new_facilities_ere_reguired
9 months after date of permit Preliminary engineering
design completed
12 months after date of permit Final engineering completed
15 months after date of permit Begin construction
18 months after date of permit Complete construction
Basic_Monitoring_Rgguirements:
We request that new monitoring requirements for flow, acute to;:i c i ty,
settleable solids, phenols, turbidity, benzene, toluene, and :•:ylene, not be
i mp.osed until such time as any new facilities are completed and on line.
If you have any questions, please call Mr. David R. k%easey at 404/3.220--2272.
Very trul yours,
w r.
W. E. Herchl i ne
WEH/cjf