NC0026247_Permit (Issuance)_20011116

NPDES DOCUMENT :;CANNING COVER SHEET
NC0026247
NPDES Permit:
Document Type: i.
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:
November 16, 2001
This document is pririted on reuse paper - ignore any
content on the resrerece side

Michael F. Easley
Govemor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
November 16, 2001
Barbara Castleberry
TransMontaigne Terminaling, Inc.
2000 Mansell Court East, Suite 600
Roswell, Georgia 30076
Subject: FINAL -- NPDES Permit No. NC0026247
TransMontaigne — Southeast Terminal
6801 West Market Street
Greensboro
Guilford County
Dear Ms. Castleberry:
This letter transmits your final NPDES individual discharge permit for the subject facility. Please
review this final document carefully to ensure thorough understanding of the information, conditions, and
requirements of dischargers to water supply (WS) waters contained therein.
The Division of Water Quality (the Division) has revised permitting strategies and Standard
Operating Procedures (SOP) for this and all bulk storage petroleum facilities and terminals in North
Carolina. As part of permit renewal, the Division has also conducted EPA -required Reasonable Potential
Analysis (RPA) on this facility's effluent data to determine the "reasonable potential" for identified
parameters to exceed North Carolina receiving -stream Water Quality Standards and criteria. The
following explanations summarize changes to your previous permit in compliance with the new 2001
SOP.
BTEX. The permittee is now required to monitor monthly for BTEX (benzene, toluene, ethyl
benzene and xylene) parameters. Please note that this replaces the requirement for EPA Method 624.
Benzene is limited because the RPA "maximum predicted" effluent level of 9.5 µg/L (based on
submitted data) exceeds the allowable concentration of 1.19 µg/L.
EPA Methods 624/625. Method 624 has been eliminated from facility monitoring if it did not
detect compounds other than BTEX. However, because the majority of facilities now store, or have
stored in the past, heavy -component fuels such as fuel oil and diesel, the Division has retained EPA
Method 625 monitoring to detect naphthalene and related indicators of middle distillate compounds
commonly found in these heavier fuels. The Division will consider a request to discontinue this
monitoring if the Permittee can document that the subject facility does not now, nor has ever, stored
heavier -component fuels.
Phenol monitoring remains in the permit, but with an added permit limit due to "reasonable
potential." Please note that this final document has been modified from the draft permit to express the
phenol limit in pounds per day (lbs./day) as a Monthly Average, 0.003 lbsJday, instead of a Daily
Maximum of 2.37 µg/L shown in the draft.
©fin
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 919-733-7015
Customer Service
1-800-623-7748

TransMontaigne Terminaling, Inc.
TransMontaigne — Southeast Terminal, Greensboro
NPDES Permit NC0026247
Page 2
The Division calculated a phenol instream wasteload allocation of 0.025 lbs./day at the confluence of
Long Branch and the East Fork of Deep River — the assumed beginning of High Point Lake Water
Supply. This allocation was distributed equally among eleven (11) bulk -storage petroleum facilities as
0.003 lbs./day per discharger. The Division then calculated an "allowable concentration" of 2.37 µg/L
using TransMontaigne's highest flow reported during the last permit cycle (0.450 MGD, September
2000). Phenol was detected three (3) times in 38 samples. Based on data submitted, this facility's
"predicted maximum" of 84.1 µg/L phenol well exceeds its "allowable concentration" of 1.71 µg/L
(calculations available upon request).
Compliance reporting for phenol should also be expressed in lbs./day. TransMontaigne has reported
a variety of test -method practical quantitation levels (PQLs) for phenol ranging from 2.0 to 50.0 µg/L
during this past permit cycle. Please continue to insist on the lowest possible test -method PQL available
from your North Carolina —certified laboratory.
MTBE is a gasoline component recently identified by the EPA as a potential human carcinogen.
Therefore, monthly monitoring has been added to this and all oil terminal permits discharging to WS
waters within the state. After collecting additional data, the permittee may request the Division to reduce
the MTBE monitoring frequency (See Special Condition A. 2.). Granting this request shall constitute a
minor modification to the NPDES permit.
If any parts, measurement frequencies, or sampling requirements contained in this permit are
unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30) days
after receiving this letter. Your request must be in the form of a written petition, conforming to Chapter
150B of the North Carolina General Statutes, and filed with the office of Administrative Hearings, 6714
Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit
shall be final and binding.
This permit is not transferable except after notifying the Division of Water Quality. The Division may
require modification, or revocation and re -issuance of this permit. Please notice that this permit does not
affect your legal obligation to obtain other permits required by the Division of Water Quality, the Division
of Land Resources, the Coastal Area Management Act, or other federal or local governments.
If you have questions, or if we can be of further service, please call Joe Corporon at [phone],
extension 597.
Respectfully,
Original Signed By
David A. Goodrich
Gregory J. Thorpe, Ph.D.
Enclosure: NPDES Permit NC0026247
cc: Central Files
Winston-Salem Regional Office, Water Quality Section
NPDES Unit;
Point Source Compliance and Enforcement Unit
Technical Assistance and Certification Unit
Aquatic Toxicology Unit
Is

r
Permit NC0026247
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended,
TransMontaigne Terminating, Inc.
is hereby authorized to discharge wastewater from outfalls located at the
TransMontaigne, Southeast Terminal
6801 West Market Street, Greensboro
Guilford County
to receiving waters designated as an unnamed tributary of East Fork of the Deep River within the Cape
Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions
set forth in Parts I, II, III and IV hereof.
This permit shall become effective January 1, 2002.
This permit and authorization to discharge shall expire at midnight on August 31, 2006.
Signed this day November 16, 2001.
Original Signed By
David A_ Goodrich
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0026247
SUPPLEMENT TO PERMIT COVER SHEET
TransMontaigne Terminaling, Inc.
is hereby authorized:
1. to continue discharging storm water from the existing water pollution control system consisting of
• truck loading -rack drains
• oil / water separator
• waste holding tank (with optional pump -out for offsite disposal)
• gravity drains to dike containment areas
• discharge control valves (for pre -tested wastewater)
• dry -ditch drains to UT of Long Branch
located at the TransMontaigne, Southeast Terminal, 6801 West Market Street, Greensboro, Guilford
County, and
2. to discharge from said treatment facility through Outfall 001 at a specified location (see attached
map) into an unnamed tributary of the East Fork of the Deep River, a waterbody classified as
WS-IV waters within the Cape Fear River Basin.

TransMontaigne Terminaling, Inc.
Greensboro Southeast Terminal
Latitude
Longitude
Receiving Stream
Stream Class
36° 04' 27" N State GriciQuad:
79° 55' 23" W Pe rmittxd Flow:
Ur E. Fork Deep River Sob -Basin:
WS-IV DrainageBaatn:
C 19 SW / Guilford, NC
Epiaodic -- rot limited
03-06-08
Cape Fear River Basin
Facility
Location
not to scale
North
x
NPDES Permit No. NC0026247
Guilford County

Permit NC0026247 '
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location
Flows
Episodic
1
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Oil and Grease2
Monthly
Grab
Effluent
Phenol
TQ0 1hs./day7
�6CCIVI
may —Grab
Effluent
Benzene4/
ti ,5
t\ .19 µg/1
Monthly
Grab
Effluent
Toluene
l IJO
Monthly
Grab
Effluent
Ethyl Benzene�S
1,
Monthly
Grab
Effluent
Xylene
Monthly
Grab
Effluent
A 62 is
2/Year
Grab
Effluent
BE3
Monthly
Grab
Effluent
Acute Toxicity4
Annually
Grab
Effluent
/Footnotes:
1. Flow — During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow shall be monitored with each discharge event and may be
monitored in one of four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude built -upon
area (best method for facilities with large runoff -collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
3. MTBE — See Part A.(2.) for other requirements relating to MTBE
4. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(3.)].
Units: mg/L = milligrams per liter
µg/1 = micrograms per liter
lbs./day = pounds per day
MTBE = methyl tertiary butyl ether
The permittee shall not discharge floating solids or foam visible in other than trace amounts.
The permittee shall not discharge tank solids, tank bottom water, or the tank rag layer.
The permittee shall not discharge tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 1.19 µg/L and toluene concentration is less than 11 µg/L.

Permit NC0026247
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
. (2.) MTBE MONITORING
For the protection of public health, oil terminals discharging to waters classified as water supplies
("WS" waters) shall adhere to the following action plan:
1. Monthly monitoring for MTBE (except as modified under 2.) is required for the duration
of the permit [See Part A. (1.)].
2. After a one-year Test Period of monthly monitoring or after twelve (12) discharge events
have been sampled and analyzed, the Permittee shall review MTBE data. If MTBE is not
detected, the facility may request the Division to reduce the MTBE monitoring
frequency. Granting this request shall constitute a minor modification to the NPDES
permit.
3. If MTBE is detected during the Test Period, the Permittee shall submit an MTBE
Reduction Plan. This plan may include site -specific Best Management Practices (BMPs)
or engineering solutions. A copy of this plan shall be submitted to:
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
he Division a ticipates that an MTBE regulatory. riterion Water ality tandard
w 1 be establishe during th coming pe ; t cycle. Fo the ne t c cle of pe 't re wals,
the Division expe is to appl this criterion or standar to B data col cted ring
this i ermit cycle. S ould the p ittee's ; E data in 'care isch ge in a cess o this
criteri • or Water uality Sta ard, an M : E limit ill beaded to he pe 't
monito +g requireme at renewa
ffi (7- 5p CeX,�
�vF

Permit NC0026247
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (3.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas)
24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste
treatment. The permittee will conduct one test annually, with the annual period beginning in January of
the calendar year of the effective date of the permit. The annual test requirement must be performed and
reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival and appropriate environmental controls, shall constitute an invalid test.
and will require immediate follow-up testing to be completed no later than the last day of the
month following the month of the initial monitoring.

•
VIkikvidy
/Wws 67 ail
NPDES PERMIT
DRAFT / FINAL
FILE CONTENTS:
Left side:
❑ ,,„-New Tracking Slip.
L9' Old Tracking Slip.
Right side:
❑ Streamline Package Sheet
[� Draft Permit Cover Letter.
lDraft Permit
❑/ Facility Map
5i Fact Sheet.
`'E Permit Writer's Notes
O❑—Staff Report from Region
L Old Permit
Er:, Permit Application.
G✓ Acknowledgement Letter
❑ Permittee Responses
1' Waste Load Allocation
CHECK LIST
1
Facility
- �'r/ V, HMG"'
i i k2ttlfrt l y f v c.
y
Permit No. W—(SO
NPDES Permit Writer:
(to region, only if strea tned)
(add new policy text• ummarize major ' anges to permit)
(order: cover, sup ement, map, efflue t sheets, special conditions)
(E-Map: Incl facility; Outfalls; U nd D sample locations)
(document permit writer's issues and re -issue logic)
(if not in Facts Sheet -- chronology, strategy, DMR Review, RPA, etc.)
(as appropriate -- not needed if streamlined)
(Text, Effluent Sheets and Special Conditions)
(New Permit or Renewal; any additional permittee correspondence)
(for Renewal Application, from NPDES Unit)
(to acknowledgement letter, if any)
(reference date; recalculated for current action?)
Note: Italics indicate special conditions not always required or applicable.
EKbmitted to PIRA -LC 5(6 4`4 for Peer Review: Date 2 t A-11=ev-44t)(
Er —Peer Review completed by Date
-`A
Perm -Mail d i• Regional Staff Ayr', MI" - by
VRegional Office Review completed by P5 t)1' (i'. Date
)
Date 36"16- I
❑ Additional Review by initiated by Date
❑ Additional Review completed by on: Date
Er"
Submitted to ate` l t `z-Ilia for Public Notice on 1 1sr-- ` : Notice Date !' 3 S l /
e' i
E9' pdated ' ublic Notic. and fM • atabases. Date f
I FINALsubmitted to Dave Goodrich for signaturet� Ier rr (A1 (06 G o o on 1 J�
6-4* )
L9- Additional Review ,t�l»`C 150do J (
(2 -5(-4(
Date TIC h S d\JE)-'

Permit NC0026247
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample
Type
Sample Location
Flow1
Episodjc '
1
Effluent
Total Suspended Solids
45.0 mg/L
onfhly
b
Effluent
Oil and Grease2
Monthly' ;›
b.
Effluent
Phenol
Q.('®
2.37
\ Monthly
Grab
Effluent
Benzene
tb9
. µg/1
\NN nthly
Grab
Effluent
Toluene
—
\ \ Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
Xylene
\\
Monthly
Grab
Effluent
EPA 625
2/Year
Grab
Effluent
MTBE3
Monthly
Grab
Effluent
Acute Toxicity4
Annually
Grab
Effluent
Footnotes: �, : ,:1 /)
1. Flow — During periods of no flow, the Pe ttee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow shall be monitored with each discharge event and may be
monitored in one of four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude built -upon
area (best method for facilities with large runoff -collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
3. MTBE — See Part A.(2.) for other requirements relating to MTBE
4. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(3.)].
Units: mg/L = milligrams per liter
µg/1 = micrograms per liter
MTBE = methyl tertiary butyl ether
The permittee shall not discharge floating solids or foam visible in other than trace amounts.
The permittee shall not discharge tank solids, tank bottom water, or the tank rag layer.
The permittee shall not discharge tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 1.19 µg/L and toluene concentration is Less than 11 AWL.

Permit NC0026247
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2.) MTBE MONITORING
For the protection of public health, oil terminals discharging to waters classified as water supplies
("WS" waters) shall adhere to the following action plan:
1. Monthly monitoring for MTBE (except as modified under 2'r'g fired for the duration
of the permit [See Part A. (1.)].
2. After a one-year Test Period of monthly monitoring or t1ve (12) scharge events
have been sampled and analyzed, the Permittee ev, ie BE data. If MTBE is not
detected, the facilityrequest the Divisi t `rthe MTBE monitoring
may ed � g�
frequency. Granting this request sha ns�t ute \ \ ixfor�ldification to the NPDES
permit.
3. If MTBE is detected duri ermittee shall submit an MTBE
Reduction Plan. This plan . inclu {t s ecific Best Management Practices (BMPs)
or engineering solutions. A co ► Hof this Ian all be submitted to:
Nort tC . 'olina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
4. The Division anticipates that an MTBE regulatory criterion or Water Quality Standard
will be established during the coming permit cycle. For the next cycle of permit renewals,
the Division expects to apply this criterion or standard to MTBE data collected during
this permit cycle. Should the permittee's MTBE data indicate discharge in excess of this
criterion or Water Quality Standard, an MTBE limit will be added to the permit
monitoring requirements at renewal.

• Permit NC0026247
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (3.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols def e ' definitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute x'city o fluents to Freshwater and
Marine Organisms." The monitoring shall be performed as tliead Minn o (Pimephales promelas)
24-hour static test. Effluent samples for self -monitoring pu4) es t be o t 'ned below all waste
treatment. The permittee will conduct one test annually 'th thew \ ual period beginning in January of
the calendar year of the effective date of the permit. The teste uirement must be performed and
reported by June 30. If no discharge occurs by �J e- 0, n o 'fic. t'o 'l be made to the Division by this
date. Toxicity testing will be performed on the'p�'xt des h . .e(ent the annual test requirement.
The parameter code for this test is T . •
condition will be entered on the ufl n
performed, using the appropriate p .: eter co
to the following address:
ng results required as part of this permit
Form (MR-1) for the month in which it was
ionally, DWQ Form AT-1 (original) is to be sent
Attention: North 'arolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include altemate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following the
month of the initial monitoring.

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
MEMORANDUM
To:
From:
Subject:
September 12, 2001
Lee Spencer
NC DENR / DEH / Regional Engineer
Joe Corporon
NPDES Unit
A7A
CDENR
NORTH CARQLINA DEPARTMENT OF
ENVIRONMENT 'AND .j>tATURAL RESOURCES
.It, Dept.,
Review of Draft NPDES Permit NC0026247
Trans Montaigne- Southeast Terminal
Guilford County
CO
c=;
t- S 4 `' '1i
s, W
Reg onai Office
Please indicate below your agency's position or viewpoint on the draft permit and return this form by October 12,
2001. If you have any questions on the draft permit, please contact me at the telephone number or e- - • ss
listed at the bottom of this page. fGE.Iv,ED
RESPONSE: (Check one)
H,...-" oncur with the issuance of this permit provided the facility is operated and maintained properl
are met prior to discharge, and the discharge does not contravene the designated water quality sta
Signed
Concurs with issuance of the above permit, provided the following conditions are met:
Opposes the issuance of the above permit, based on reasons stated below, or attached:
•
stated effluent
T6 eU?F�i
OCR 1 C+-a°
Oi
Date:
00/
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 511 (tax) 919 733.0719
VISIT us ON THE INTERNET @ http://h20.enr.state.nc.us/NPDES Charles.Weaver@ ncmail.net
0

'1220515
Date 109/13/2001 Time 13:35 PM
PUBLIC NOTICE
STATE OF NORTH CA RDO NA
ENVIRONMENTAL
MANAGEMENT
COMMISSION/NPDES UHT
1617 Mail Service Cenitr
Raleigh, NC 27699-1617
NOTIFICATION OF INTENT TO
ISSUE NPDES
WASTEWATER PERM R
0n the b asis of tho rough slat
review and application of
NC General Statute 143-21.
Public law 92- 500 an d other
lawful slan dard s a nd regula-
tions, he North Carolina Envi-
ronmental Management Com-
mission proposes to issue a
National Polutan1Discharge
Elimination System (NPDES)
wastewater discharge perm it to
the persons) listed below ee-
lective 45 days from the pub -
Ida date of this notce.
Witten comments regarding the
proposed permit will be ac-
cepted anti 30 days after the
pub fish dale of this notice. All
comments rece Ne d p rb r to
that dale are conddereil In the
final deteanlnations rem eiIng
the proposed permit. The Di-
rector of the NC Division of
Water Qua lily ma y d ecid a to
hold a public meeting for the
pro posed permit shou k1 the
Division receNe a significant
degree of public f ntrest.
Copies of h e draft perm 11 a nd
oche r supporting information
on fie used to determine con-
ditlons present in the draft
permltare available upon re-
quest and payment of the
costs of re pro du cti on. Mail
comments and /o r requests for
information to the NC Division
o1 Water Qua NV at the above
address or call Ms. Christie
Jackson at(919) 733.5083.
extension 538. Please indude
the NPDES permit number
(attached) in any communica-
tion. Interested persons ma y
also vlsf fre Division of Wa ler
Quality at 512 N. Salisbury
Street, Raleigh. NC
27604.1148 between the
hours of 8:00 a.m. and 5:00
p.m. to review nbnation on
life.
NPDES Permit Number
NC0071465. Apex Dil Com-
pany, 2801 Rock Road Gmnet
City, Illinois 26040, Greens-
bo io, NC 27409 has app bed
fora permit renewal fora facil-
ity located in Guilbrd County
discharging treated wastewa-
ter into UT of Horsepen Creek
in he Cape Fear River Basin.
Currently Total Suspended
Solids (TSS), oil a nd grease,
and lead are wabr quaitylim-
ited. This discharge may ailed
future alloca tons in his por-
tion of the receiving stream.
NPDES Permit Number
N00026247. TransMon tsigne
Terminahng.Inc. Southeast
Terminal 200 ManseN Court
Suite 200, Roswell, GA 30076
has ape Iled for a per rNt re-
newal fora ladllty located in
Guilford Co unty d sch argr rig
treated wastewater into UT of
the East Fork Deep RNer In the
Cap e Fear River Basin. Cur.
renty benzene and total phe-
nol are water quality limited.
This discharge may affect fu-
ture albmtionsinlhspoil on
of thereceMngstream.
Ad shown is not actual print size

7
MANSMONTAIGNE
TERMINALING INC.
Certified Mail Return Receipt Requested
7099 3400 0009 6878 0631
October 8, 2001
Mr. Joe R. Corporon
NC DENR
Division of Water Quality — NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Draft NPDES Permit NC0026247
TransMontaigne Terminaling Inc.
Greensboro Terminal
Dear Mr. Corporon:
TransMontaigne Terminaling, Inc. has completed its review of the draft NPDES permit for its
Greensboro facility and makes the following comments.
Item A.(1) EPA 625 Monitoring
TransMontaigne requests discontinuation of EPA 625 monitoring requirements after a total of 4
analyses have been performed and analytical results are reported to be below the detection limit.
TransMontaigne's EPA 625 analytical results on file with DENR for the past 3 years, have shown
monitoring results to be below the detection limit.
Item A.(2) MTBE Monitoring
TransMontaigne requests removal of MTBE monitoring if test results during the one-year Test
Period are at or below DENR's proposed 11.6 ug/1 limit.
Thank you for the opportunity to comment on the draft permit. We appreciate the Department's
response to our requests.
If you have any questions, please call me at 770/518-3671.
cerely,
(75
Barbara Castleberry
Environmental Coordinator
copy: Trey Rhodes
Don Griffin
200 Mansell Court
Suite 600
Roswell, GA 30076-4853
Phone: [phone]
Fax: [phone]

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Whole Effluent Toxicity Testing Self -Monitoring Summary June 18, 2001
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Lenoir- Gunpowder Creek WWTP Penn chr lim: 529.E 1997 NB/Pass Pass - Pass
NC0023736/001 Bcgin:1/1/2001 Frequency: Q Mar Jun Sep Dec + NonComp:Single 1998 Pass - Pass - - Pass
County: Caldwell Region: ARO Subbasin: CTB32 1999 - - Pass - Pass
PF: 2.0 Spacial 2000 - Pass Pass - Pass
7010: 3.0 IWC(%)52.0 Order: 2001 - - Pass
Pas - - late
Pass - - Pas
Pass - Bt
Pass - - Pass
Lenoir- Lower Creek WWTP Pcnn chr lim: 44% (Ncw perm 6/1/2001) 1997 - Pass - - Pass - Pass -- Pass
NC0023981/001 Begin:11/1/1998 Frequency: Q P/F + Feb May Aug Nov + NonComp:Single 1998 -- Pass - - Fall,Pass - -- Fail Pass -- Fnil,Pass
County: Caldwell Region: ARO Subbasin: CTB3I 1999 - Pass - - Fall 89.4 .20 01 - NR Pass
PF: 6.0 Special 2000 - Pass - - Pass - - Pass - -- Pass
7QI0: 11.75 IWC(%):44 Order: 2001 - Pass - -
Lexington Regional WWTP PERM CHR LIM: 56% Y 1997 - Pass - - Pass - - Pass - - Pass
NC0055786/001 Begin:6/1/1994 Frequency: Q P/F + Feb May Aug Nov NonComp:SINGLE 1998 - Pass - - Pass - - Pass - Pass
Comity: Davidson Region: WSRO Subbasin: YADO7 1999 - Pass - - Pass - - >100.Fa8 - - Pass
PF: 5.5 Special 2000 .- Pass - - Pass - - Fail>90 39.6 >90,Passt Pas
7010: 6.7 IWC(%)55.99 order: 2001 - Pass - -
Libbey-Owens Ford Co. Pcmt 24 hr (✓f ac lim: 90°/. flhd (grab) 1997 - Pass - - Pass - -- Pass - H -
NC0049514/001 Begin:12/1/1999 Frequency: Q P/F + Jan Apr Jul Oct + NonComp:Single 1998 - Pass - - Pass - - Pass - - Pass
County: Scotland Region: FRO Subbasin: LUM55 1999 -- Pas - - Pass - -- -- Pas - Pass -
PF: VAR Special 2000 Late Pass - Pass - - Pass - Pass 7Q10: 0.0 IWC(%.):100 Order: 2001 Pass -- - Pass
Liberty Fabrics, Inc. Perm 24hr WI' ac lim: 90% fthd
NC0023710/001 Begin:6/I/1997 Frequency: Q + Marlon Scp Dec
County. Martin Region: WARO Subbasin: ROA09
PF: 0.45 Special
7Q10: 1200 IWC(%):0.06 Order:
4 NonComp:Singlc
1997 - - Pass - - Pass - - Pass -- -- Pass
1998 - - Pass - - Pass - - Pass -- -- Pass
1999 - - Pass - - Pass - - Pass -- .- Pass.>90
2000 - - Pass,>90 - - Pass - - Pass - -- Pass.>90
2001 - - Pass.>90 -
Lilliogton WWTP Penn 24 hr p/f ac lim: 90% 1997 Pass - - Pass - - Pass - - Pass
NC0021636/001 Begin:5/1/1996 Ftequcncy:Q + Jan Apr Jul Oct NonComp:Singlc 1998 Pass - - Pass - - Pass - - Pass
County. Hamctt Region: FRO Subbasin: CPF07 1999 Pass - - Pass - - Pass - Pass
PF: 0.6 Special 2000 Pass - - Pass - Pass - - Pass
7010:550.0 IWC(%)d).17 Order: 2001 Pass - Pass
Lincoloton WWTP Perm chr lim: 11%
NC0025496/00I Begin:9/1/1995 Frequency: Q P/F + Mar Jun Scp Dec
County. Lincoln Region: MRO Subbasin: CTB35
PF: 6.0 Special
7Q10: 77.0 IWC(%):11.0 Oak
NonComp:Singlc
1997 - - Fail Pass - Pass - - Pass -- Pass
1998 - - Pass - Pass - - Pass -- -- Pass
1999 - - Pass - - Pass - - Pass -- Pass
2000 - - Pass - - Pass - - Pass - Nr2Pass
2001 - - Pass -
Linville Resorts, Inc. Pecan chr lim: 7Y.; if cap to 0.15 chr lim 10% 1997 - - -
NC0039446/001 Begin:12/1/2000 Frequency: Q Jan Apr Jul Oct + NonComp:Single 1998 - - -
County. Avery Region: ARO Subbasin: CTB30 1999 - - - -
PF: 0.10 Special 2000 - - - -
7Q10:2.1 IWC(%):10.0 Order: 2001 Pass - - Pass
Lithium Corp Pcrm chr lim: 78%gaf 0.7 chr lim 80%;pf 0.8 chr lim 82%;pf 0.9 Y 1997 >100(s) - - 88(s) - -- 61>100(s) -- 76.5.80.3 78.5(s) >100(s)
NC0005177/001 Bcgin:5/I/1997 Frequency: Q P/F + Jan Apr Jul Oct + NonComp:Single 1998 >100(s) - - >100 -- >100 -- - 88.3 - -
County. Gaston Region: MRO Subbasin: CTB37 1999 >100 - - >100 -- >160 H >100
PF: 0.615 Special 2000 >100 - - >100 -- - >100 - >100 --
7010:0.27 IWC(%):78 Order: 2001 >100 - - >100
Livingstone Coating Corporation Pcrm chr lim: 90*!
NC0086002/001 Begin:10/1/1997 Frequency: Q P/F + Jan Apr Jul Oct
County: Mecklenburg Region: MRO Subbasin: CTB34
PF: 0.0216 Special
7Q10: 0.0 IWC(%):100 Order:
+ NonComp:Single
1997 - - - - -. - - .- - H
1998 H -- - Pass - - Pass -- - P355
1999 Pass - - Pass - - Pass -- - Pass
2000 Pass - - Pass - - Pass - Pass
2001 Pass - - Pass
Louis Dreyfus Energy Corp. Perm 24hr LC50 ac monit (pis flhd (grab) 1997 -
NC0026247/001 Bcgin:8/111996 Frequency: A NonComp: 1998 >100
County: Guilford Region: WSRO Subbasin: CPF08 1999 >100
PF: NA Special 2000 >100
7Q10: 0.0 IWC(%):100 Order: 2001 >100
>100
Y Pre 1997 Data Available
LEGEND:
PERM = Permit Requirement LET = Administrative Letter -Target Frequency = Monitoring frequency: Q- Quarterly; M- Monthly; BM- Bimonthly, SA- Semiannually; A• Annually; OWD- Only when discharging; D. Discontinued monitoring rcquircment
Begin = First month required 7Q10 = Receiving stream low flow criterion (cfs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur • ex. Jan, Apr. Jul, Oct NonComp = Current Compliance Requirement
PF= Permitted flow (MGD) IWC%= lnstream waste concentration P/F= Pass/Fail test AC=Acute CHR =Chronic
Data Notation: f- Fathead Minnow; * - Ccriodaphnia sp.; my • Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported Facility Activity Status: 1 - Inactive, N - Newly I.Ssued(To construct); H • Active but not discharging; f•Morc data available for month in question; • = ORC signature needed
29

NC DENR - DIVISON OF WATER QUALITY 2B . 0300
.0311
CAPE FEAR RIVER BASIN
Name of Stream
Description
Class
Classification
Date Index No.
Weaver Creek
HAW RIVER
Shaddox Creek
DEEP RIVER (including
High Point Lake at
normal pool
elevation)
East Fork Deep River
East Fork Deep River
Long Branch
Long Branch
West Fork Deep River
West Fork Deep River
(Oak Hollow
Reservoir)
Hiatt Branch
Hiatt Branch
West Fork Deep River
Goulding Branch
From a point 0.5 mile
upstream of mouth to New
Hope River Arm of B.
Everett Jordan Lake
From dam at B. Everett
Jordan Lake to Cape Fear
River (junction with Deep
River)
From source to Haw River
From source in backwaters
of High Point Lake to dam
at High Point Lake (City of
High Point water supply
;.,ratio}
WS-IV NSW CA 08/03/92 16-41-12-(2)
Ws -Iv
08/03/92 16-(42)
WS-IV 08/03/92 16-43
WS-IV CA * 04/01/99 17-(1)
From source to a point 0.4 WS-IV * 04/01/99 17-2-(0.3)
mile downstream of Guilford
County SR 1541
From a point 0.4 mile
downstream of Guilford
County SR 1541 to High
Point Lake, Deep River
From source to a point 0.5
mile downstream of Guilford
County SR 1541
WS-IV CA * 04/01/99 17-2-(0.7)
WS-IV * 04/01/99 17-2-1-(1)
From a point 0.5 mile WS-IV CA * 04/01/99 17-2-1-(2)
downstream of Guilford
County SR 1541 to East Fork
Deep River
From source to a point 0.3
mile downstream of Guilford
County SR 1850
From a point 0.3 mile
downstream of Guilford
County SR 1850 to dam at
Oak Hollow Reservoir
From
mile
WS-IV * 04/01/99 17-3-(0.3)
WS-IV CA * 04/01/99 17-3-(0.7)
source to a point 0.6 WS-IV * 04/01/99 17-3-1-(1)
upstream of mouth
From a point 0.6 mile WS-IV CA * 04/01/99 17-3-1-(2)
upstream of mouth to Oak
Hollow Reservoir, West Fork
Deep River
From dam at Oak Hollow
Reservoir to Boulding Branch
From source to West Fork
Deep River
18
WS-IV * 04/01/99 17-3-(1.5)
WS-IV * 04/01/99 17-3-2

CAPE FEAR RIVER BASIN
Name of Stream
Subbasin Stream Index Number Map Number
Class
Dry Creek
Dry Creek
Dry Fork Creek
Duck Pond Branch (Duck Pond)
Duff Creek
Duff Creek (Lake Tut)
Duncans Creek
Duncans Creek
Dunham Creek
Dutchman Creek
Dutchman Creek (North side of Intracoastal
Waterway)
Dutchman Creek Outlet Channel
Dutchman Creek Shellfish Area
Dye Branch
East Branch Price Creek
East Branch Price Creek
East Buies Creek
East Bu es Crack
East Fork Deep River
East Fork Deep River
CPF07
CPF13
CPF11
CPF13
CPF22
CPF22
CPF13
CPF14
CPF14
CPF17
CPF17
CPF17
CPF17
CPF03
CPF06
CPF06
CPF07
CPF07
CPF08
CPF08
18-17-(2)
18-20-13-3-5
17-37-2
18-20-13-3-1
18-74-29-2-(2)
18-74-29-2-(1)
18-20-25
18-23-18-1
18-23-16-2
18-88-9-3-(2.5)
18-88-9-3-(1)
18-88-9-3-3
18-88-9-3-(4)
16-19-11-1-1
16-41-2-4-1-(1)
16-41-2-4-1-(2)
18-18-1-(1)
18-18-1-(2)
17-2-(0.3)
17-2-(0.7)
F23NE6
F22SE1
F21NE6
F22SW6
H26SE6
H26SE8
F23NW9
F22SE7
F21SW6
L26NE5
L26NE5
L26NE5
L26NE9
C21SW2
D22SE1
D22SE1
F24NW4
F24NW2
C19SW1
C19SW8
WS
C
C
C
C Sw
B Sw
C
WS-III
WS-III
SA
SC Sw HQW
SA
SA
C NSW
WS-II NSW
WS-II NSW CA
C
Ws -Iv
WS-IV
ws-Iv
CA
East Mingo Creek
Elder Branch
Elizabeth River
Elizabeth River Shellfishing Area
Ellis Creek
Ennis Pond
Enoch Mill Creek
Evans Lake
Everett Bay
Everett Creek
Fairy Fair Creek
Fall Creek
Falls Creek
Fan Branch
Field Branch
Field Creek
First Silver Run
Fish Creek
Fishing Creek
Fishing Creek
Fishing Creek
Fishing Creek
Flat Creek
Flat Creek
Flat Swamp
Flat Swamp Ditch
Flyrod Lake
Folkner Branch
Folkner Branch
Fork Creek
Foust Creek
Fox Grape Branch
Frank Creek
CPF18
CPF22
CPF17
CPF17
CPF16
CPF14
CPF18
CPF15
CPF24
CPF24
CPF14
CPF07
CPF10
CPF06
CPF15
CPF20
CPF13
CPF07
CPF23
CPF23
CPF17
CPF17
CPF09
CPF14
CPF23
CPF15
CPF14
CPF05
CPF05
CPF09
CPF04
CPF17
CPF02
18-68-12-2-1
18-74-24-1-2
18-88-9-2-(1)
18-88-9-2-(2)
18-44
18-23-31
18-68-12-17
18-25
18-87-2
18-87-29
18-23-32-4
18-8
17-27
16-41-2-6-1
18-31-7
18-68-22-2
18-20-33
18-14
18-74-35
18-74-59
18-88-1-4-1
18-88-8-4-1
17-24
18-23-15
18-74-33-4-1-2
18-28-1-1
18-23-4
16-41-3-(1)
16-41-3-(2)
17-25
16-28-4
18-64-15-2
16-18-2-1
r24NE5
H27NW7
L26NE8
L26NE9
H24SW8
F23SE8
I25NE8
G23SE1
J29NW1
K27SW3
F23SE7
F22NE2
E21SW4
D22SE2
G21SE5
J26SE1
F23SE3
F23NW6
I27SE5
J27SW4
L27NW1
L27SW2
E2OSE5
G22NW7
I28SE4
G23SE2
F21SW9
D23SW7
D23SW7
E20SW4
D21NW9
J25SW5
C22NW1
C Sw
C Sw
SA
SA
C
C
C Sw
ws-Iv
SA ORW
SA
C
C
C
WS-IV NSW
C
C Sw
WS-IV
ws-Iv
C Sw
C Sw
SC Sw HQW
SA
C
wS-III
C Sw
C
wS-III
WS-IV NSW
WS-IV NSW CA
C
C NSW
C Sw
WS-II NSW
Page 9 of 30

Permitting
Joe Corporon
August 24, 2001
TransMontaigne T
NC0026247
Regarding
April 197
May 17,1996
June 26 1996
naling, In
nitoring for P
December 16,1996
April 23,1997
July 26, 1999
August 23, 2001
nols
revious draft permit noticed; draft included "other 8" phenols
-- permittee's draft comments requested that "other 8" be removed
-- the Division issued the final permit including "other 8" — no phenol
comments included in cover letter.
- - Following the "Paw Creek Oil Terminals" public hearing, the Division
issued a letter explaining that the "other 8" would be necessary only if hits
were detected through initial screening by EPA 624/625.
- - Division [apparently] issued a MOD to this facility (in keeping with the
letter of 16Dec) removing the "other 8" and substituting EPA 624/625.
MOD documentation — Paul Clark submitted four pages (stamped by Central
Files "Received April 26, 1999"):
• a FAX cover letter (23Apr97) from Clark to Castleberry with;
• the Division's letter (16Dec96) unsigned; and with
• an effluent page requiring 624/625, but excluding the "other 8."
(RE: date discrepancy, Mike Templeton says Paul may have submitted the
letters to Central Files two years later when he left the Unit). I can find no
other notes or MOD cover letter documentation. Judging from the DMRs
(1996 to present), the permittee submitted no "other 8" phenol data, only
624/625, from 1996 to the present.
- - Division finalized a state-wide Oil Terminals SOP, semi-annual 624/625
required, with "other 8" listed as footnote, "...only if phenols detected by
screening."
-- I asked the permittee's representative, Barbara Castleberry, about her
current permit and she said there are no "other 8" listed. She faxed me an
influent page with 624/625 (no "other 8" parameters) attached to a "change
of ownership" cover letter dated August 13, 2000.
Assuming therefore, that the Division did modify this permit in April 1997 from the original June
1996, I will renew it according to the new 2001 SOP and will not include "other 8" monitoring.
However, based on submitted data for phenol, there is "reasonable potential," therefore phenol
monitoring will include a permit limit (see Fact Sheet for limit calculations).

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NC0026247
INTRODUCTION
TransMontaigne Terminaling, Inc. (herein referred to as TransMontaigne or the permittee) requires a
National Pollutant Discharge Elimination System (NPDES) permit to dispose treated wastewater to
the surface waters of the state. The Permittee's 5-year NPDES permit has expired and they have
requested renewal from the Division of Water Quality (the Division). This Fact Sheet summarizes
background information and rationale used by the Division's NPDES Unit to determine permit limits
and conditions. This document also contains references to information sources relevant to this permit
renewal (superscripted numbers in order of appearance, See References).
FACILITY RECORDS REVIEW
Facility Description. TransMontaigne (Table 1) operates the TransMontaigne, Southeast Terminal
(formerly Louis Dreyfus Energy Corporation / BP Oil prior to April 22, 1999), a bulk storage petroleum
fuel distribution center in Guilford County. Discharge from the facility consists of stormwater runoff
controlled by a Water Pollution Control System consisting of: loading rack drains; oil/water separator;
waste holding tank with optional offsite disposal; gravity drains to dike containment areas; and discharge
control valves. Discharge travels to a drainage ditch, then to an unnamed tributary (UT) to the East Fork of
the Deep River.
Table 1.
TransMontaigne — Water Pollution Control System
Facility Information
Applicant/Facility Name 1,2
TransMontaigne Terminaling, Inc. /
TransMontaigne, Southeast Terminal
Applicant Address 1'2
200 Mansell Court East, Suite 600, Roswell Georgia 30076
Facility Address 1,2
6801 West Market Street, Greensboro 27409-1829
Permitted Flow (MGD) 43
Not limited
Type of Waste 1'2'4
Industrial runoff wastewater. SIC Code 5171
WW Code Prim. 37; Second. 39;
Facility/Permit Status 1'2'4
Class I, Minor / Renewal
Drainage Basin / County 1,2
Cape Fear / Guilford
Miscellaneous
Receiving Stream 1'3
UT of the East Fork of
the Deep River
Regional Office
Winston - Salem
Stream Classification 1,5
WS-IV
State Grid /
USGS Topo Quad4
C 19 SW /
Guilford, NC
303(d) Listed? 6
Not listed
Permit Writer
Joe R. Corporon
Subbasin 5
03-06-08
Date:
06Aug01
Drainage Area (sq. mi.)
j
ice'
Lat. 36° 04' 27" Long. 79° 55' 23"
Summer 7Q10 (cfs) 3'8
0.0
Winter 7Q10 (cfs) 3'8
0.0
30Q2 (cfs) 3'S
0.0
Average Flow (cfs) 3'8
0.0
IWC (%) 3'8
O
MO
tact Shea
Renewal -- NPDES Permit NC0026247
Page 1

This permit became effective August 1, 1996 (with an expiration date of March 31, 2001). The
Division extended the expiration date (to stager the renewal workload) to expire August 31, 2001.1,2
On April 14, 2000, the Division received the Permit Renewal/Change of Ownership documents
(Louis Dreyfus Energy became TransMontaigne Terminaling, Inc.) and the name change was
acknowledged on April 22, 2000.
Waste Load Allocation (WLA). The Division reviewed the WLA in November 1994 and developed
effluent limits and monitoring requirements based on an in -stream waste concentration (IWC) of
100% (zero -flow stream).8 The Division judges these limits and monitoring requirements to be
appropriate for this renewal with the exception of additions and deletions listed below (see
PERMITTING APPROACH SUMMARY).
Verifying Existing Stream Conditions. This facility discharges to a "zero -flow" stream, an
unnamed tributary (UT) of the East Fork of the Deep River, a Class WS-IV NSW stream within the
Cape Fear River Basin. East Fork of the Deep River is not listed as an "impaired" waterbody [not
303(d) listed].6
COMPLIANCE REVIEW
Discharge Monitoring Reports (DMR) -- Effluent Data Review. DMRs were reviewed from
January 1996 through December 2000.9 Discharges from Outfall 001 occurred episodically, but
approximate monthly — non -discharge months reported as "no flow." The permittee reported a
maximum discharge of 0.450 MGD (September 2000). Therefore, this flow was used for reasonable
potential calculations (see below). Monitoring parameter results are summarized in Table 2:
Table 2.
TransMontaiane, Southeast Terminal DMR Review Summar
Parameter
Samples
(n)
Hits
(n)
High
Average
RP*
y/n
Comments /
Action
Flow
60
--
0.450
MGD
0.055
MGD
--
High used for
RPA
B
37
1
3.6 µg/L
3.6 µg/L
Yes
Include Limit
(See RPA)
T
10
0
No
E
10
0
No
X
18
0
No
Phenol
38
8
8.0 µg/L
2.0 µg/L
Yes
Include Limit
(See RPA)
TSR
49
34
24 mg/L
6.5 mg/L
--
Oil & Grease
49
8
11.3 mg/L
3.16 mg/L
No
BPJ Standard
30 mg/L
Eight (8) Additional Phenols
0
--
--
--
--
No data
TOX
6 (annual)
--
--
--
--
All "pass"
EPA 624/625
10
0
--
Retain 625
Delete 624
*RP = "Reasonable Potential" to exceed Water Quality Stream Standard.
Fact Sheet
Renewal -- NPDES NC0026247
Page 2

Based on the Division's our review of the DMRs, twice annual EPA 624/625 scans did not detect
semi -volatile or volatile organic compounds. Total suspended residue (TSR) results do not exceed
recommended levels.
Notices of Violation (NOVs). No NOVs were issued to this facility during this permit cycle.
Facility Inspections. Due to staff shortages and regional priorities, this Class I Stormwater
Treatment System has been assigned lower priority relative to other discharge systems, however
starting this permit cycle, the Winston-Salem Regional Office has scheduled regular annual
inspections for this and all bulk -petroleum storage facilities in the Greensboro area.'°
Whole Effluent Toxicity (WET) Test. The facility has passed its annual acute toxicity test for six
(6) years, from 1996 through year 2001.
PERMITTING STRATEGY
Revised Standard Operating Procedures (SOP). The Division of Water Quality has revised
permitting strategies and SOP for this and all oil terminals in the state.' A new document has been
generated by the NPDES Unit entitled, "Standard Operating Procedures -- Permit Requirements for
Discharges from Oil and Petroleum Storage Facilities" (based on a 1996 SOP). This document,
hereafter referred to as the 2001 SOP, addresses issues and delineates monitoring frequencies and
permit limits for contaminants commonly found at these facilities.
Summary of Compliance Under 2001 SOP. Under the 2001 SOP, flow monitoring will be
changed from "monthly" to "episodic" (Parts L.A. ). Compliance for acute toxicity, TSS, and oil and
grease (Parts L.B. through LD.). In place of EPA Methods 624/625 monitoring requirements [eight
(8) chlorophenols specified in the previous permit], the permittee shall now monitor monthly for
phenol only (Part LE.), required for all WS (water supply) waters, and for BTEX (Part MLA.). The
Division shall also require monthly monitoring for MTBE (2001 SOP Part 1.1.) considering WS
waters. 7
Footnotes to the Effluent Limits and Monitoring Requirements page shall reflect no direct discharge
of tanks solids, tank bottom water, or the tank rag layer. Footnotes also stipulate no direct discharge
of hydrostatic test water if benzene and/or toluene concentrations exceed their respective water
quality standard (2001 SOP, Parts I.G. and I.H).
Phenol — Monitoring and Limits Calculations. When combined with chlorine, phenol can cause
taste and odor (organoleptic) problems in drinking water, and can also result in the tainting of fish
tissues. Therefore, in accordance with SOP 2001, all dischargers to state water supply (WS) waters
shall conduct monthly effluent monitoring for total phenol. Moreover, if analytical results suggest
"reasonable potential," a phenol limit shall be included in the permit.'
A phenol limit magnitude depends on dilution. Ideally dilution would be calculated at the High Point
Dam water plant intake where chlorine is introduced, but it is impractical at this time to measure
dilution under lake conditions at the intake. Therefore, the Division calculated flow at the assumed
headwaters of this water supply. Secondly, the Division used 1 µg/L (the aesthetic limit for phenol) to
calculate a wasteload allocation in pounds per day (lbs./day) at these headwaters. Finally, the
wasteload allocation was distributed equally among phenol dischargers as a permit limit, only as each
facility's data -set showed reasonable potential to exceed the water quality stream standard.
Fact Sheet
Renewal -- NPDES NC0026247
Page

Currently nine (9) bulk storage facilities discharge to either the East Fork Deep River or Long
Branch. The confluence of these two drainages was assumed to approximate the headwaters of High
Point Lake, the nearest downstream intake waterbody. For purposes of yield calculations, Long
Branch was assumed to have a similar runoff coefficient as the East Fork of the Deep River. The
Division used published 30Q2 flows from an EPA stream gauge (02099000) located on the East Fork
Deep River near the confluence of the two drainages. The 30Q2 flow, not the 7Q10, was deemed
appropriate because of the aesthetic standard for phenol.
Flow Calculations:
Given: Flow (30Q2) East Fork Deep River = 3.8 cfs (USGS Gauging Station)
Drainage Area East Fork Deep River = 14.8 mil (USGS)
Drainage Area Long Branch = 3.84 mi2 (measured from USGS topo)
Total Drainage Area = 14.8 mi2 + 3.84 mi2
= 18.6 mil
Yield = East Fork Flow (cfs)
East Fork Drainage Area (mi2)
= 3.8 cfs
14.8 mil
0.257 cfs/mi2
Therefore:
Total Flow = Yield x Total Drainage Area
0.257 cfs/nut x 18.6 mil
4.7 cfs
Wasteload Calculation:
4.7 cfs x 0.001 mg/L x 8.34 = 0.025 lbs./day distributed among nine
1.55 dischargers
0.025 lbs./day
9 dischargers
= 0.003 lbs./day per discharger
Phenol Limit: Maximum reported flow = 0.1404 MGD
Limit = Allocated wasteload (lbs./day) x 1.0 mg/L
8.34 lbs./MG Highest Reported Flow (MGD)
= 0.003 lbs./day x 1.0
8.34 0.1404
_ .00237 mg/L
= 237 µg/L
Fact Sheet
Renewal -- NPDES NC0026247
Page 4

This calculated phenol level (2.37 µg/L) was used to establish "reasonable potential" (see RPA
spreadsheets). Because there is "reasonable potential" for phenol at Outfall 001, the Division has
included the permit limit per discharger as a Monthly Average of 0.003 lbs.day.
Summary of Reasonable Potential Analysis (RPA). The Division conducted a EPA -mandated
RPA on TransMontaigne's reported data for benzene and total phenols. Results indicate that there is
"reasonable potential" to exceed water quality stream standards for these parameters. The "maximum
predicted" concentration for phenol was significantly influence by detection at 8.0 µg/L (130ct99)
and by less sensitive method detection limits of 10 µg/L and, on two occasions, 50.0 µg/L.
Maximum Predicted Allowable Reasonable Potential
Benzene 9.5 µg/L 1.19 µg/L Yes
Phenol 84.1 µg/L 2.37 µg/L Yes
Permitting Approach Summary
Per DWQ/NPDES Unit's 2001 SOP:
• Incorporated BTEX monitoring, frequency Monthly per SOP 2001.
• Benzene remains in the permit; added limit due to "reasonable potential"
• Removed EPA Method 624 monitoring; "no parameters detected."
• Method EPA 625 monitoring remains at 2/Year per SOP 2001.
• Phenol remains in permit with added permit limit (lbs./day) due to "reasonable potential;" no
change in Monthly monitoring frequency.
• Per requirement for WS waters, added Monthly MTBE monitoring, no limit.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
September 13, 2001.
November 16, 2001
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Joe Corporon; ' 19) 733-5ext. 597.
NAME: �� �7 DATE: DU V "V V
i,e4
Fact Sheet
Renewal -- NPDES NC0026247
Page 5

REFERENCES
1. 1999. NPDES Permit Application Short Form C. for TransMontaigne Terminaling, Inc.
2. 1999. NPDES Permit Name / Ownership Change Form, for TransMontaigne Terminaling, Inc.,
previously owned Louis Dreyfus Energy Corporation / BP Oil.
3. 1995. NPDES Permit NC0026247, previously issued to Louis Dreyfus Energy Corporation / BP Oil,
now issued to TransMontaigne Terminaling, Inc., expired March 31, 2001. Copies may be
obtained through The Division of Water Quality, Central Files, Archdale Building, 512 N.
Salisbury St., Raleigh, North Carolina.
4. 2000. Active NPDES Permits List, North Carolina Division of Water Quality, NPDES Unit, on the
web at http:/h2o.enr.state.nc.us/NPDES/NPDESweb.html.
5. 2000. Cape Fear Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water
Quality Section, July.
6. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of Water
Quality, Water Quality Section. Copies may be obtained through the Planning Branch,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
7. 2001 Standard Operating Procedures (Revised), 2001 NPDES Permitting Strategy, North Carolina
Bulk Storage Oil Terminals, NPDES Unit, Natalie Sierra, July 30.
8. 1991. NPDES Waste Load Allocation Work Sheet, NPDES Permit NC0026247, conducted for Louis
Dreyfus Energy Corporation / BP Oil, permit now issued to TransMontaigne Terminaling, Inc.,
modeled by Permits and Engineering Unit, August 11.
9. 1998-2000. Discharge Monitoring Reports (DMR) for Effluent (DEM Form MR-1), Louis Dreyfus
Energy Corporation / BP Oil, January 1996 through January 1999; TransMontaigne
Terminaling, Inc. beginning February 1999 through December 2000.
10. 2001 Personal Communication from Jenny Rankin (WSRO) to Joe Corporon (NPDES Unit),
Greensboro oil terminal site visits and records, August 22.
Fact Sheet
Renewal -- NPDES NC0026247
Page 6

TRANSMONTAIGNE
200 Mansell Court East, Suite 600
Roswell, GA 30076-4853
Telephone: [phone]
Facsimile: [phone]
FACSIMILE TRANSMITTAL.
TO; OC'_ 0,e'poe0/l FAX NO: 5*! ^ 7_33 �O77?
1E7t101viC oast i[ c
DATE_ � ! �C �--(U FD %-pD(s cJ)Pi
c
Total number of pages
(including this cover): `•
susp - FF.PAS
Gb2 L( Tha
IF YOU DO NOT RECEIVE ALL OF kIE PAGES OR DA,VE ANY QUESTIONS, PLEASE NOTIFY TRU
OFFICE AT [phone].
CONFIDENI'I6LITY; The information contained in this teIecopy message is legally privileged, confidential
information or work product intended only for the use of the individual or entity named above. If the reader of
this message is not the intended recipient, you are hereby notified that any use, dissemination, distribution, or
copying of this telecopy is strictly prohibited. If you have received this telecopy in error. please immediately
notify us by telephone and return the original message to us at the address above via the United States Postal
Service.
900/T001j1 ;)NI21HilNI`]Nia 222C ST2 OLL XV,3 g0:TT fILL TOOZ/CZ/90

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Ms. Barbara Castleberry
TransMontaigne Terminals
200 Mansell Court East - Suite 600
Roswell, GA 30076
Dear Ms. Castleberry:
RECP1VED
AUG 2000
T.OIT
August 18, 2000
eVA
NCDENR
NOr ni CAROLINA OftPARTmz,NT or
ENVIRONMENT AND NATURAL„ RESOURCES
dc :-12A
Subject NPDES Permit Modification
Permit NC0026247
Southeast Terminal
Guilford County
The Division is beginning the cycle of permit renewals for the Cape Fear river basin. An examination of the Cape
Fear basin plan and the NPDES permit schedule has revealed that the existing expiration dates in Cape FcarNPDE,S
permits do not coincide with the revised permit expiration dates for the basin. This discrepancy could create unnecessary
delays in the processing of over 200 permit renewals. Accordingly, the Division is changing the permit expiration dates for
NPDES permits in the Capc Fear river basin.
This permit modification changes the expiration date of the subject permit in subbasin 30608 to August 31, 2001,
Please find enclosed the revised permit cover page. Insert the new cover page into your permit and discard the old page.
All other tears and conditions contained in the original permit remain unchanged and in full effect. This permit
modification is issued under the requirements of North Carolina General Statutes 143-215.1 and the Memorandum of
Agreement between North Carolina and the U. S. Environmental Protection Agency.
In accordance with the modification of the permit expiration date, the new due date for your renewal application is
March 4, 2001. Renewal application forms will be sent to you approximately 6-8 weeks in advance of the new due date pr
you may download the forms from the NPDES web site at http://h2o.enr.state.netts/NPDES/documents.ht ml. You
will need to download Short Form C. If you have already submitted a permit renewal form, there is no need to submit
any other forms to the Division; the application will be processed during the renewal period for your subbasia.
If any part of this permit modification are unacceptable to you, you have the right to an adjudzcatory hearing upon
written request within thirty (30) clays following receipt of this letter. This request must be a -written petition conforming
to Chapter 150E of the North Carolina General Statutes, filed with the Office of Administrative 7-Tearings (6714 Mail
Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
If you have any questions concerning this permit modification, please contact Natalie Sierra at (91) 733-5083,
extension 551.
cc; Central Files
Winston-Salem Regional Office, Water Quality Section
Point Source Compliance Enforcement Unit
NPDES Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
An Equal Opportunity Affirmative Action Employer
Sincerely,
Kerr T. Stevens
Telephone [phone] FAX [phone]
VISIT us of rrle I anti ter LT. httg/Ih2o.enr.slate.ne,us1NPDES
900/Z0012
0NI2IaaaNlDNa SSLC 9TS OLL XVd ZO:TT !113,1, TOOZ/CZ/80

Permit NC0026247
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER 'UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the FederalWater Pollution Control Act, as amended,
TransMontaigne Terminals
is hereby authorized to discharge wastewater from a facility ldated at the '
Southeast terminal
6801 West Market Street
Greensboro
Guilford County
to receiving waters designated as an unnamed tributary to the East Pork Deep River
in the Cape Fear River Basin
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Ports I, Ili III and IV hereof.
This permit shall become effective September 1, 2000.
This permit and authorization to discharge shall expire at midnight on August 31, 2001.
Signed this day August 18, 2000.
Kerr T. Stevens, ' ector
Division of Water Quality
By Authority of the Environmental Management Commission
900 C00Ij
DNIIIMNIDN3 99LC 9T9 OLL X,1 CO:TT au TOOZ/CZ/90

Penult NC0026247
SUPPLEMENT TO PERMIT COVER SHEET •
TransMontaigne Terxninaling, Inc., is hereby authorized to:
1. Continue to discharge stormwater from the following collection systems:
• An oil / water separator
• The general terminal basin
This facility is located at the Southeast Terminal (6801 West Market Street),
Greensboro, in Guilford County.
•
2. Discharge at the location specified on the attached map into as an unnamed
tributary to East Fork Deep River, classified WS-IV waters in the Cape Fear River
Basin.
900/1700 e DNI I EMI ma 88LC 8T5 OLL XVd CO:TT I1EL TOOZ/CZ/80

Iatitnde: 96'04.27"
tie:79'55.23•
c14SW
&aotivn►g Stream: UT Fast
Rat [op River
Stream Class: WS-N
Subbasi 30608
900/90011
Gnome •• �, „� a ��_ , :fi �� .[•r-.
•- pint ';�• tehr. mmon Grove •
Discharge
p ch _� -
1.
r . _ • f: •- r. .'tea
NC0026247
TransMontaigne
Terminating, Inc.
SCALE 1:24000
9NIMNIONa 99LC 8T5 OLL XVd CO:TT 11H,L TOOZ/CZ/80

A. Q. EFFLT mmr LIMITATIONS AND MONITORING REQU NT' Permit No, NC0026247
o During the beginning on the effective date of the permit and rusting until expiration, the Permirtee is authorized to discharge
wastewater (consisting primarily of stornnwaterr and city water used for washing and hydrostatic testing) from outfall(s)
serial numberOOl. Such eischarges shall be limited and monitored by the Perrnittee as specified below:
ENGINEERING
Effluent Chaaac.teristics Discharge Limitations Monitoring Requirements
Measurement Sample S unp1e
Monthly Avg, WggIcly_ ' Avg, D411y Max, frequency TY8e
FIowl .Monthly 1 Effluent
Total Suspended Solids 45.0 mgtl Monthly Grab Effluent
Oil and Grease2 Monthly Grab Effluent
Phenol Monthly -Grab Effluent
Benzene _ Monthly Grab Effluent
1e ie _ �oGdm!�1�3` tc��'( c —,t/ /2c c_�
Xy �c �,G / / col Semi+annually Grab Effluent
3 /-' ,Fo2 (tF�460 c AJk tAi O EPA Methods 62 /625 Semiannually Grab Effluent
•
Acute Toxicity ` 5rY �`0�E L4� f2�: 69.E 'Annually Grab Effluent
(aJcp . q,avL cawcj FeA-� I`lbsb ( c-
Footnotes; vt: a-�Cr-� 2-3cr2•'
1 Where no measurable discharge occurs, "no discharge" should be clearly noted on thesubm tted monthly discharge monitoringrt.
Flow may be monitored in one of four ways: a) Measure flow continuously, b) Calculate flow based on the atca draining to the outfa11, the built upon
area, and the total rainfall (this method of flow measurement should mot be used at facilities that have large fronds to collect
surface water runoff), c) Estimate by flow measurement at 20 minute intervals during the entire discharge event, or d) Base flow or pagnp logs.
2 Where possible, the grab sample for oil and grease should be slimmed from the surface of a quiescent (calm water) zone.
3 EPA Method 625 incIuces five (5) chioropbenols. Won;, or more cblorophenol(s) is detected at concentrations greater than or equal to 50 pgll, the
peimittev will be required to analyze for the eight chlorophenots (listed below) in additton.tg EPA Method 625. This additional required monitoring will
begin with the permittee's next. scheduled monitoring event., occur orl. a semi-annual basis, and will Iast for the duration of the permit, Eaght
chlorophcnols include the following: 3-chlorophenol, 4-chlorophenot, 2,3-dichlorophenot, 2,5-dichlorophenol, 2,6-1ichlorophenol, 3,4-
dichlorophenol, 2,3,4,5-tetrach orophenol, and 3-methyl-6-chlorophettol.
4 Acute Toxicity (Fathead Minnow, 74-hour) Monitoring, An ual, See Part III, Condition. E.
w Them sha':l be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
L There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene concentration is less than 1.19 ugjl and toluene
concentration is less than l 1 ugll.
N

Louis Dreyfus Energy
North America
8800 Roswell Road
Suite 200
Atlanta, Georgia
30350-1843
r
Telephone [phone] •
Fax [phone]
Certified Mail Return Receipt Requested
P 608 661 940
Louis Dreyfus Energy May 17, 1996
Mr. Dave Goodrich
NPDES Permits Group
North Carolina Dept. of Environment, Health and Natural Resources
Division of Environmental Management
P. O. Box 29535
Raleigh, NC 27626-0535
DRAFT NPDES PERMIT NC0026247
SOUTHEAST TERMINAL
6801 WEST MARKET STREET
GREENSBORO GTJILFORD COUNTY
Dear Mr. Goodrich:
In connection with your letter of May 7, 1996, Louis Dreyfus Energy has reviewed the
draft NPDES permit for our Greensboro facility. We wish to make the following
comment:
2,6 Dichlorophenol and 2,3,4,6 - Tetrachlorophenol are found only in Methods 8040A
and 8270B respectively. There are no approved methods listed in Part 136 40 CFR ,
December 1995 edition for the analysis of the following compounds:
3-chlorophenol
4-chlorophenol
2,3 - dichlorophenol
2,5 - dichlorophenol
3,4 - dichlorophenol
3 - methyl - 6 - chlorophenol
We request that these compounds be removed from the permit as Phenol will be
monitored on a monthly basis.
Thank you for the opportunity to comment on the draft permit. If you have any
questions, please call me at 770/518-3671.
Sincerely yours,
Barbara Castleberry
Environmental Coordinator
copy: Don Griffin, w/attachment
Rob Piatt, w/attachment
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Apr 18 '97 15:39
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87705183671
y/23r1ts 4 `coNt� -"IM
State of North Carolina
Department of Environment, Health and Natural Resources
Division of Water Quality
512 North Salisbury Street • Raleigh, North Carolina 27611
James B, Hunt. Jr., Governor
Facsimile Cover Sheet
• Jonathan B. Howes, Secretary
To: tan A e iic k PY
Fax: -s1g— 3 1a
From:
Phone; [phone] 'ycatoto
Fax: [phone]
_pages, including this cover sheet.
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Comments; ( afr97 ram` `
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sw6

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NC0026247
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge
wastewater (consisting primarily of stormwater and city water used for washing and hydrostatic testing) from outfall(s)
serial number 001. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Flow 1
Total Suspended Solids
Oil and Grease2
Phenol
Benzene
Xylene
EPA Methods 624/6253
Acute Toxicity4
Discharge Limitations Monitoring Requirements
Measurement Sample Sample
Monthly Avg. Weekly Avg. Daily Max. Frequency Type Location
Monthly 1 Effluent
45.0 mg/1 Monthly Grab Effluent
Monthly Grab Effluent
Monthly Grab Effluent
Monthly Grab Effluent
Semi-annually Grab Effluent
Semi-annually Grab Effluent
Annually Grab Effluent
Footnotes:
1 Where no measurable discharge occurs, "no discharge" should be clearly noted on the submitted monthly discharge monitoring report.
Flow.may be monitored in one of four ways: a) Measure flow continuously, b) Calculate flow based on the area draining to the outfall, the built u
area, and the total rainfall (this method of flow measurement should not be used at facilities that have large ponds to collect
surface water runoff), c) Estimate by flow measurement at 20 minute intervals during the entire discharge event, or d) Base flow on pump logs.
2 Where possle, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone.
3 EPA Metho 25 includes five (5) chlorophenols. If one or more chlorophenol(s) is detected at concentrations greater than or equal to 50 µg/1, the
permittee wine required to analyze for the eight chlorophenols (listed below) in addition to EPA Method 625. This additional required monitoring
begin Aith tli;permittee's next scheduled monitoring event, occur on a semi-annual basis, and will last for the duration of the permit. Eight
chlorophenols include the following: 3-chlorophenol, 4-chlorophenol, 2,3-dichlorophenol, 2,5-dichlorophenol, 2,6-dichlorophenol, 3,4-
dichlorophenol, 2,3,4,6-tetrachlorophenol, and 3-methyl-6-chlorophenol.
4 Acute Toxicity (Fathead Minnow, 24-hour) Monitoring, Annual, See Part III, Condition E.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
Them shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene concentration is less than 1.19 ug/1 and tol
concentration is less than 11 ug/l.

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Govemor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
(vls. Barbara Castleberry
;Louis Dreyfus Energy
('�' 800 Roswell Road, Suite 200
V, Atlanta, Georgia 30350-1843
EDIEF-INJI
December 16,1996
Subject Permit Modification
NPDES Permit NC0026247
Southeast Terminal
Guilford County
Dear Ms. Castleberry:
As you may be aware, the public in the Paw Creek area near Charlotte is very concerned with
any activities associated with the oil terminals (including renewal of NPDES permits). The Division
held a public hearing on May 16, 1996, for the renewal of several oil terminal NPDES permits in the
Paw Creek area. Many people attended the hearing and the Division received numerous comments at
the hearing and during the public comment period. As a result of these comments, the Division re-
examined and researched several issues, including chlorophenols. Chlorophenols required a more
extensive research effort than other issues raised during the public comment period. This letter
documents and summarizes changes to chlorophenols requirements in your permit, and also addresses
some other changes to the permit which reflect concerns raised by the public.
It should be noted that changes to permits pertain to facilities that discharge to water -supply
classified waters only. Permits will not change for facilities discharging to non -water -supply waters.
In response to comments pertaining to the chlorophenol monitoring requirements in the draft
permits, the Division re -investigated the following two questions: (1) Why was there a requirement to
monitor for eight individual chlorophenols in addition to those specified in EPA Method 625; and (2)
What is the proper laboratory procedure to analyze for these eight chlorophenols?
After some additional research and discussion, two determinations were made. First, although
all chlorophenols have the potential to cause taste and odor problems in drinking water supplies and
tainting of fish tissue, the eight chlorophenols nal covered by EPA Method 625 (and singled out for
individual monitoring in the permit) are not considered to be carcinogens. Second, when phenol is
exposed to chlorine, certain chlorophenols form before others. This is significant because a few key
"early -forming" chlorophenols can be used to "screen" the stormwater discharge for the presence of
chlorophenols. Specifically, the five chlorophenols included in EPA Method 625 can be used as
indicators of all chlorophenols because these five compounds would be the first to form when chlorine
reacts with phenol.
Therefore, EPA Method 625 will be used as an initial screen. If no chlorophenols are detected,
no additional monitoring will be required. However, if one or more chlorophenols are detected at
concentrations greater than 50 µg/1, then the oil terminal would be required to monitor for the eight
additional chlorophenols beginning with the next scheduled monitgring.eveit and continue to monitor
yyt ti JCC c7
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

semi-annually until the permit expired. The additional chlorophenol monitoring would include
identifying and quantifying all chlorophenols present in the sample(s).
Although the chlorophenol monitoring requirement change was the most significant, another
concern raised by the public pertained to xylene monitoring. Several members of the public noticed that
xylene monitoring was not required in the draft permits. Xylene is not included in EPA Methods 624/625
and therefore, the Division acknowledges that xylene monitoring should and will be included in the oil
terminals' final NPDES permits.
Please find enclosed the modified section of the permit referenced in the preceding paragraphs.
Replace the original sections in your permit with the newer enclosed sections and discard the original
sections. All other terms and conditions contained in the original permit remain unchanged and in full
effect. These permit modifications are issued pursuant to the requirements of North Carolina General
Statutes 143-215.1 and the Memorandum of Agreement Between North Carolina and the U.S.
Environmental Protection Agency.
If any parts, measurement frequencies or sampling requirements contained in this permit
modification are unacceptable to you, you have the right to an adjudicatory hearing upon written
request within thirty (30) days following receipt of this letter. This request must be in the form of a
written petition, conforming to Chapter 150B of the North Carolina General Statutes, an filed with the
Office of Administrative Hearings, Post Office Drawer 27447, Raleigh, North Carolina 27611-7447.
Unless such demand is made this decision shall be final and binding.
If you have any questions, please contact Charles Weaver at [phone] extension 511.
Sincerely,
A. Preston Howard, Jr., P.E.
cc Central Files
Winston-Salem Regional Office, Water Quality Section
Roosevelt Childress, EPA
Permits and Engineering Unit
Fa ' 'ty Assessment Unit
Aquatic Survey and Toxicology Unit

RECD BY Mirk. FILES
APR 26 99

CS1Qf le 5
r
U'11
TRANSMONTAIGNE
TERMINALING INC.
Certified Mail Return Receipt Requested
P 373 807 623
April 11, 2000
NC Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
NC NPDES Permit Number NC0026247
TransMontaigne Terminaling Inc.
Southeast Terminal
To Whom It May Concern:
a
c
a_
Enclosed are three (3) copies of Short Form C for renewal of the referenced NPDES
permit.
Should you have any questions, please call me at 770/518-3671.
V - , truly yours,
e I !
CCCA
Barbara Castleberry
Environmental Coordinator
Enclosure
Copy: Trey Rhodes, w/attachment
200 Mansell Court
Suite 600
Roswell, GA 30076-4853
Phone: [phone]
Fax: [phone]

SOUTHEAST TERMINALS
.rs£ rrserr
FACILITIES OUT
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MO. NO. W!-OPN-131-003 o
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