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HomeMy WebLinkAboutNC0088919_Renewal Application_20140922Pat McCrory Governor A� ��. NCDENR North Carolina Department of Environment and Natural Resources September 22, 2014 Mr. Ryan D. Kerins Terraquest Environmental Consultants, P.C. 100 East Ruffin Street Mebane, NC 27302 John E. Skvarla, III Secretary Subject: Issuance of NPDES Permit NCO088919 Quality Oil Company — Former Coliseum Shell GW Remediation System Forsyth County Dear Mr. Kerins: Division personnel have reviewed and approved your application for renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143 -215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). This final permit contains significant changes to its terms from those found in the draft permit sent to you on February 26, 2014. These changes have been made based upon use of corrected low flow data for the receiving stream and in response to comments received during the permit's public notice period. A summary of those changes is listed below. • The facility's flow limit has been changed from 0.036 MGD to 0.004 MGD. • The Whole Effluent Toxicity limit has been changed from 90% to 8.1 %. The lower limit is reflective of a lower instream waste concentration resulting from the discharge that takes into account a corrected (higher) stream flow within the unnamed tributary to Silas Creek and the reduced flow limit. The test method has been changed from a pass /fail test to full range toxicity testing with the reporting of the chronic value derived from the test. Toxicity testing months have been changed to March, June, September and December. • The effluent limits for lead as found in the previous permit have been retained in this final version of the permit in response to commentt received during the draft permit's public notice. You are also reminded of the new condition requiring electronic reporting of discharge monitoring report (DMR) data using the Division's eDMR internet application. This new requirement will become effective on August 1, 2015 (approximately 270 days or nine months following the effective date of the permit). 1617 Mail Service Center, Raleigh, North Carolina 27699 -1617 Phone: 919 - 807 - 6300 \Internet: www.ncwaterquality.org An Equal Opportunity \ Affirmative Action Employer — Made in part by recycled paper Mr. Ryan Kerins NC0088919 Permit Renewal 2014 p. 2 If any parts, measurement frequencies or sampling requirements contained in this permit 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, and filed with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699 - 6714). Unless such demand is made, this decision shall be final and binding. Please note that this permit is not transferable except after notice to the Division. The Division may require modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be required by the Division of Water Resources or permits required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required. If you have any questions concerning this permit, please contact Bob Sledge at telephone number (919) 807 -6398, or via e-mail at bob.sledge @ncdenr.gov. Incer ly, 41 f Thomas A. Reeder, Dire r Division of Water Resources cc: Central Files Winston -Salem Regional Office/Water Quality NPDES File ec: Aquatic Toxicology Unit Permit NCO088919 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions 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, Quality Oil Company is hereby authorized to discharge wastewater from a facility located at the Former Coliseum Shell 3009 University Parkway Winston -Salem Forsyth County to receiving waters designated as an unnamed tributary to Silas Creek in the Yadkin River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III, and IV hereof. The permit shall become effective November 1, 2014. This permit and the authorization to discharge shall expire at midnight on June 30, 2019. Signed this day September 22, 2014. (Z- zz� mas A. Reeder, Director Division of Water Resource By Authority of the Environmental Management Commission Page 1 of 7 Permit NCO088919 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Quality Oil Company is hereby authorized to Continue to discharge treated, gasoline contaminated groundwater from a groundwater remediation system that includes the following components: • Oil -water separator • Air stripper • High pressure sand filter • Particulate bag filters • Activated carbon filters • Associated tanks, pumps and piping This facility is located at the former Coliseum Shell, at 3009 University Parkway, in Winston - Salem, in Forsyth County. 2. Discharge from said treatment works at the location specified on the attached map into unnamed tributary to Silas Creek, a class C water in the Yadkin River Basin. Page 2 of 7 Permit NCO088919 PART I A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to discharge treated groundwater from Outfall 001. Such discharges shall be limited and monitoredt by the Permittee as specified below: EFFLUENT CHARACTERISTICS Parameter Code EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Monthly Average Daily Maximum Measurement Frequency Sample Type Sample Location Flow2 50050 0.004 MGD Continuous Recording Effluent Total Suspended Solids C0530 30.0 mg /L 45.0 mg /L Monthly Grab Effluent Ethylbenzene 34371 Quarterly3 Grab Effluent Xylenes 81551 Quarterly3 Grab Effluent MTBE 22417 Quarterly3 Grab Effluent Isopropyl Ether 77117 Quarterly3 Grab Effluent Naphthalene 34696 Quarterly3 Grab Effluent Isopropyl Benzene 77223 Quarterly3 Grab Effluent Tetrachloroethylene 34475 Quarterly3 Grab Effluent Acetone 81552 Quarterly3 Grab Effluent 1, 2, 4- Tri methyl benzene 77222 Quarterly3 Grab Effluent 1, 3, 5- Tri meth ylbenzene 77226 Quarterly3 Grab Effluent Toluene 78131 Quarterly3 Grab Effluent Benzene 34030 Quarterly3 Grab Effluent 2- Butanone 78356 Quarterly3 Grab Effluent 1, 2 cis - Dichloroethylene 81574 Quarterly3 Grab Effluent Lead 01051 25.0 pg /L 67.0 pg /L Quarterly3 Grab Effluent Chronic Toxicity4 THP3B Quarterly Grab Effluent Nntee- 1. No later than August 1, 2015 (270 days from the effective date of this permit), begin submitting discharge monitoring reports electronically using NC DWR's eDMR application system. See Condition A. (3.). 2. Flow may be measured using a totalizing flow meter. 3. Monitoring is to be conducted in conjunction with whole effluent toxicity monitoring. 4. Chronic Toxicity (Ceriodaphnia dubia) full range testing with chronic value limit of 8.1 %. Testing is to be conducted during the months of March, June, September and December (see A. (2.)). There shall be no discharge of floating solids or visible foam in other than trace amounts. Page 3 of 7 Permit NCO088919 A. (2.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant mortality to Ceriodaphnia dubia at an effluent concentration of 8.1 %. The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 20 10) or subsequent versions. The tests will be performed during the months of December, March, June, and September. These months signify the first month of each three month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. If the test procedure performed as the first test of any single quarter results in a.ChV below the permit limit, then multiple- concentration testing shall be performed at a minimum, in each of the two following months as described in "North Carolina Phase H Chronic Whole Effluent Toxicity Test Procedure" (Revised- December 2010) or subsequent versions. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR -1) for the months in which tests were performed using the parameter code T1HP3B for the Chronic Value. Additionally, DWQ Form AT -3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Water Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699 -1621 Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete, accurate, include all supporting chemical/physical measurements and all concentration/response data, and be certified by laboratory supervisor and ORC or approved designate signature. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month /year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, monitoring will be required during the following month. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Resources 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, minimum control organism reproduction, 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. Page 4 of 7 Permit NCO088919 A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will be adopted and is beginning implementation in late 2013. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) • Section D. (2.) • Section D. (6.) • Section E. (5.) Signatory Requirements Reporting Records Retention Monitoring Reports 1. Reporting (Supersedes Section D. (2.) and Section E. (5.) (a)1 Beginning no later than August 1, 2015 (270 days from the effective date of this permit), the permittee shall begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / DWR / Information Processing Unit ATTENTION: Central Files / eDMR 1617 Mail Service Center Raleigh, North Carolina 27699 -1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the permittee re- applies for and is granted a new temporary waiver by the Division. Page 5 of 7 Permit NCO088919 A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS, continued Information on eDMR and application for a temporary waiver from the NPDES electronic reporting requirements is found on the following web page: http://Portal.ncdenr.org/web/wq/adminibog/ipu/edmr Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. 2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)1 All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part I1, Section B. (I 1.)(a) or by a duly authorized representative of that person as described in Part 11, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http: / /portal.ncdenr.org /web /wq /admin/bog/ipu/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " 3. Records Retention [Supplements Section D. (6.)] The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. A. (4.) NUTRIENT REOPENER FOR HIGH ROCK LAKE This permit may be reopened and modified to implement nutrient requirements in accordance with any future TMDL and /or nutrient management strategy for High Rock Lake. Page 6 of 7 Permit NCO088919 Page 7 of 7 "ill I 7"W� roto g. MR." - - v AN i � -i i s tai v y� Mal / �t,t �� %jJ / /�) /i� \a Vii, Mal / L \ 1 �;. • yr! y� . Ilr l�f 1. ^� � � j'49 � '�,,•` c i I%f/���'j_1��I . � +:! ��� �",�. ' ii/ � t •�',�"� � •y}y��g`1jyd���/�t�+! i��it�ei,°+s� iti`���r������'t� / �f.�.�:�*�i�. �' �►� '` �����;� � y �f:iit:", � '�, �� /•�f;,., a�r sib: __•"s''. �/ , '11 ii I a `►.i/ S� IF�•'n .�il.� :��, lb' _..:►,rr::- A :.ail tj � % !$��`�'.. �`1� 1�j t� p ! et..�a d.R; �r��� „ ...�sp�� � `;r�1% !�i4y�'�'j. d s'Adll��4�,��s,;�'o� 'a,� '•,'� r i�ffr tf I�/ r All [[�/ %...� �l7 Pyc`t"y „+.+'d�S.. S_ 3 �1 C h 1� �k��1 �(�65 -!!• x' b, -- a°+ra` !� �,: `, y� t._J. I / pi +l _ XF {zx m tub. « 1iMIZ Mi Y Pr f \ �, �7 1 .69` 'k, Ai If i11114 lip, >� +: Ylk, .r” Fsp•�x�� i 1�(,li 3 6 v+ Yh.. B�'+.y. ti y .. �" j � ^' 1 R r 1 rC i%dJ Latitude� 36*07'54" Quality Oil Company Facility Longitude: 80015AT Location 71 Quad Former • Stream Class: C GW Remediation Receiving Stream: UT to Silas Creek 0410tth Forsyth County Page 7 of 7 FACT SHEET FOR EXPEDITED PERMIT RENEWALS Basic Information for Expedited Permit Renewals Permit Writer/Date Bob Sledge 2/21/2014; updated 9/22/2014 Permit Number NCO088919 Facility Name Quality Oil Company — Former Coliseum Shell GWR Basin Name /Sub -basin number Yadkin -Pee Dee 030704 Receiving Stream UT to Silas Creek Stream Classification in Permit C Does permit need Daily Max NH3 limits? No Does permit need TRC limits /language? No Does permit have toxicity testing? Yes Does permit have Special Conditions? Added eDMR condition and High Rock Lake reo ever Does permit have instream monitoring? No Is the stream impaired (on 303(d ) list)? No Any obvious compliance concerns? Toxicity. Facility has been issued a SOC to address tox. Compliant with parameters of concern Any permit mods since last permit? No Current expiration date June 30, 2014 New expiration date June 30, 2019 Comments received on Draft Permit? Yes, from Clean Water For North Carolina This permit is for a groundwater remediation system in Winston - Salem. The site is a former gas station. The groundwater is contaminated by gasoline, but groundwater monitoring also detected the presence of PERC (thought to have migrated to the site from a nearby dry cleaner). This is why the individual permit has been issued instead of the general permit for remediation of petroleum contaminated groundwater. The treatment system contains multiple components, and is well operated and maintained. The effluent quality is excellent. Apart from some higher numbers associated with startup, the facility typically yields non - detect results for constituent parameters. A RPA was run for those parameters for which discreet values were reported. No reasonable potential for violating water quality standards was shown per the analysis for all the parameters, with the exception of lead. For these reasons, limits have been removed from the permit or all the organic compounds and monitoring frequencies have been reduced to quarterly, to be conducted along with toxicity testing. Both the Winston -Salem Regional Office and the Aquatic Toxicology Unit have been consulted about this change and both have noted their approval. Lead did show reasonable potential with the inclusion of a 140 gg/L value associated with the start up of the system on July 25, 2011. If this value is removed, the maximum predicted value drops from 267.4 gg/L to 38.5 gg/L. Because the first sampling event is seen as not representative of the facility's standard and long term performance, the decision regarding the limit is based upon the RPA not including that value. The limit has been removed and monitoring frequency has been reduced to quarterly. It is forecast that remediation at the site will soon be concluded and improvement at the site will be left to natural attenuation. If this occurs, the GWR system will be removed and the permit rescinded. UPDATE (9/22/2014) Comments were received from Clean Water For North Carolina requesting most constituent parameter limits be retained in the permit and that monitoring frequencies either be retained or increased. Most of the CWFNC recommendations were not adopted because they were not grounded in the facts and history of the situation, but were based upon emotional speculation. For most parameters, monitoring frequencies and limits were kept as they were set in the draft permit, with reduced frequencies and no effluent limits as guided by results of reported data and the RPA. The exception to this is that limits have been restored for lead in response to the CWFNC comments. Another parameter that is significantly changed in the final version of the permit is Whole Effluent Toxicity. During the initial evaluation of the situation it was believed the effluent failed tox tests because the treated groundwater did not contain sufficient nutrient value to sustain the test organisms during the test cycle. However, extensive testing and analysis by the facility consultant and the Aquatic Toxicology Branch indicate other factors may be contributing to toxicity (mostly likely some form of ion imbalance). The toxicity monitoring requirement was looked at from many angles in an effort to keep meaningful toxicity testing in the permit without leading the facility into permit noncompliance and placing it into jeopardy of receiving civil penalties. Civil assessments would cause the owner to shut down the remediation system, thus denying the environment the benefits of a process that has made significant progress in cleaning up the contaminated groundwater in the area. At the same time those factors were being considered, other factors surrounding the discharge were examined. In initial permitting, USGS calculated stream flow was not used in establishment of the IWC and development of the tox limit; instead the discharge was assumed to be 100% of stream flow during low flow conditions. Additionally, the actual discharge volume of the discharge was considered instead of the design flow of the system. Actual flow values were consistently about one -tenth of the permitted flow. In the renewed permit, the permitted flow has been reduced to near the flow values reported during the last permit cycle (0.004 MGD). Considered with positive stream flow, this yields an IWC and toxicity limit of 8.1 %, which should be attainable by the permittee. The test has been changed to full range testing (code THP3B) in March, June, September and December, with the result reported as a chronic value. All changes to the permit have been discussed with the permittee and the Aquatic Toxicology Branch. All parties are satisfied with the terms of the final permit. Former Coliseum Shell 2014 Freshwater RPA- 95% Probability/95% Confidence Outfall 001 NC0088919 MAXIMUM DATA POINTS = 58 Qw= 0.004 MGD • Qw(MGD)= 0.00 W WTP/WTP Class: PC-1 1Q10S(cfs)= 0.06 IWC ®1Q10S = 9.37% 7Q10S(cfs)= 0.07 IWC (4)7Q10S= 8.14% 7Q1OW(cfs)= NO 7Q10w DATA IWC(4)7Q1OW= N/A 30Q2(cfs)= 0.17 IWC(a3 30Q2= 3.52% Avg.Stream Flow,QA(cfs)= NO QA DATA IWC®QA= N/A Receiving Stream: UT to Silas Creek Stream Class: C PARAMETER TYPE STANDARDS&CRITERIA(2) J F REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION (1) NC WQS/ Applied r/2 FAV/ Z Chronic Standard Acute n #Det. Max Pred Cw Allowable Cw Acute: 360.73 Lead NC 25 FW(7Q 10s) 33.8 ug/L 25 5 267.40 _ _ Chronic: 307.13 Quarterly monitoring;retain limit No value>Allowable Cw Acute: NO WQS Acetone NC 2000 FW(7Q10s) ug/L 25 4 1049.20 Chronic: — — — — — — — — — — — — --- — — 24570.02 Quarterly Monitoring No value>Allowable Cw Acute: NO WQS MTBE NC 1500 HH(7Q10s) ug/L 25 2 7.70 Chronic: 18427.52 Quarterly Monitoring No value>Allowable Cw Acute: 0 0 N/A Chronic — — - --------------- Acute: 0 0 N/A - - ------- - - - - - - - - - - - Chronic • • • NC0088919 RP 2014 v4(0.004),rpa Page 1 of 1 9/23/2014 Sledge, Bob From: Hollenkamp, Carol Sent: Thursday, September 18, 2014 2:59 PM To: Ryan Kerins; Sledge, Bob; Moore, Cindy Cc: Moore, Thomas; Hennessy, John Subject: RE: shell coliseum conference call Hi everyone, We can use this number for a conference call tomorrow to discuss the permit for Shell Coliseum (NC0088919). Let's plan on 1030. If anyone has any time conflicts, just let me know. Ryan, could you call into this number instead of us calling you? 1. Dial 1-919-743-8484 2. You will be prompted to enter a pass code. Enter 000111, then press #. Enter the number 000111 somewhat slowly. For some reason, we get an error if typed in too rapidly. 3. You will be welcomed to the conference bridge and asked to say your name, then press #. 4. You will be announced to the conference call and will be told what number caller you are. Thanks, Carol Hollenkamp Aquatic Toxicology Branch /Water Sciences Section North Carolina Division of Water Resources /DENR 1621 Mail Service Center, Raleigh, NC 27699 -1621 Please NOTE NEW PHONE # Phone: (919) 743 -8440 Fax: (919) 743 -8517 Website: http: / /portal.ncdenr.org /web /wq /ess /atu E -mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Ryan Kerins [ mai Ito: rdkerins @terraquestpc.comI Sent: Thursday, September 18, 2014 2:34 PM To: Hollenkamp, Carol Cc: Moore, Thomas Subject: RE: shell coliseum conference call 3/7.O�Y No�r�nL�M�lr rP .c-.e- i V Z-k- i 4 �� r, A3311 J t e c.., s "(I Kof elool/ur-74W TIE A 1* (e IWrxr tO oe) JI-M, (- dotdkr7 4x ..o' & r 4a4 I Ire 74z4r A&Ir 1 n LI) IA. Ad, Li W AV w IV 4F 2, f ��w 110 - rep i'- i `, Clean Water for North Carolina 291/2 Page Ave Asheville NC 28801 Bob Sledge DWR /Water Quality Permit Section Wastewater Branch 1617 Mail Service Center Raleigh, NC 27699 -1617 Dear Mr. Sledge, �"'.' I � ''`"J � ` `•"'tai March 26, 2014 Please accept this document as the official comments of Clean Water for NC regarding draft Permit # NC0088919 for the Quality Oil Company LLC's Former Coliseum Shell Station. Clean Water for NC is an environmental justice nonprofit organization with members statewide who care about the state's water resources, including over 40 supporters in the greater Winston -Salem area. We are aware that this facility has been remediating groundwater polluted with PERC and petroleum related chemicals, and discharging the wastewater in a storm drainage tunnel that leads into Silas Creek. We are also aware that limits are proposed to be removed for several parameters, including lead. After having reviewed the discharge data for this facility, we offer the following comments about this draft permit: - Limits for lead should not be removed for this facility, as it has surpassed allowed daily values for 5 months since it started reporting in July 2011. The facility last surpassed maximum values in December 2012. Although they have been in compliance with lead limits since then, this does not constitute sufficient time in compliance to justify lifting limits for lead. - Monitoring and testing requirements should continue to be on monthly time period, not reduced to a quarterly, for the following parameters: Ethylbenzene, xylenes, MTBE, Isoproply Ether, Naphthalene, Isopropyl Benzene, Tetrachloroethylene, Acetone, 1,2,4- Trimethylbenzene, 1,2,5 - Trimethylbenzene, Toluene, Benzene, 2- Butaone, 1,2 cis- Dichloroethylene, Lead, and Chronic Toxicity. We understand the Division's determination to remove limits based on reasonable potential to exceed water quality standards, but lowering the frequency of monitoring of these parameters would reduce the Division's ability to quickly act if certain parameters become problematic once again and warrant reinstated limits. It is the responsibility of NC DENR's Department of Water Resources to protect the integrity of our state's surface water. Though the remediation system appears to be functioning efficiently, DWR must hold Quality Oil Company LLC accountable to the fullest extent of Clean Water Act standards. We believe continuing monthly testing and including an enforceable limit for Lead are necessary to protect Silas Creek for downstream uses. Thank you for this opportunity to submit comments. Respectfully, Sally Morgan Energy & Water Justice Researcher Clean Water for NC sally @cwfnc.org NORTH CAROLINA FORSYTH COUNTY AFFIDAVIT OF PUBLICATION Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified, and authorized by law to administer oaths, personally appeared D.H. Stanfield, who being duly sworn, deposes and says: that he is Controller of the Winston -Salem Journal, engaged in the publishing of a newspaper known as the Winston -Salem Journal, published, issued and entered as second class mail in the City of Winston - Salem, in said County and State: that he is authorized to make this affidavit and sworn statement: that the notice or other legal advertisement, a true copy of which is attached hereto, was published in the Winston -Salem Journal on the following dates: March 1, 2014 and that the said newspaper in which such notice, paper document, or legal ldvertisement was published was, at the time of each and every such publication, a newspaper meeting all the requirements and qualifications of Section 1 -597 of the General Statutes of North Carolina and was a qualified iewspaper within the meaning of Section 1 -597 of the General Statutes of forth Carolina. PUBLIC NOTICE his 3rd day of March, 2014 North Carolina Environmental Management Commission/NPDES Unit 1617 Mail Service Center (signature of pe so making affidavit) Raleigh, NC 27699 -1617 Notice of Intent to Issue a i NPDES Wastewater Permit worn to and subscribed before me, this 3rd day of March 2014 'The North Carolina Environmental Management Commission proposes to issue a NPDES wastewa- ter discharge permit to the person(s) listed below:' Written comments regarding the proposed permit will be accepted until 30 days after the publish date of this notice. The Director of the NC Div of Water Resources (DWR) may hold a public f Nota P ZlC ing should there be a s eg ignificant dree of p l interest. Please mail comments and /or informal tion requests to DWR at the above address. Inters? ly Commission expires: September 28, 2015 ested persons may visit the DWR at 512 N. Salis -it bury Street, Raleigh, NC to review information ont file. Additional Information on NPDES permits and this notice may be found on our website: http: //.t portal.ncdenr.org /web /wq /swp /ps /npdes /calenj dar, or by calling (919) 807 -6390. The City of Kind, (P.O. Box 719, King, NC 27021) has requested 9t permit NCO088897 for its Water Treatment Plane in Forsyth County. This permitted facility will dis:� charge treated wastewater to old Richmond Cree in the Yadkin -Pee Dee River Basin. Total residu chlorine is a parameter regulated in the permits which is water quality limited. This discharge mays affect future allocations in this segment of Olds KIMALEY JOHNSON appliednfor Crenewaluof NPDESCpermit NC 0889 0.. NOTARY PUBLIC for the Former Coliseum Shell Station in Forsyth ' FORSYTH COUNTY County. Thi s P4r + „� �❑ STATE OF NORTH CAR LI MY COMMISSION EXPIRES named tribut Basin. Currently, - es, naphtalene, isopropyl benzene tetrachoro=, ethylene, acetone, trimethylbenzene 1,2 4, tol- uene, and benzene are water quality limited. However due to the performance of the treatment system, limits are proposed to be removed in the draft permit. This discharge may affect future al- locations in this portion of the Yadkin River Basin. The Town of East Bend has applied for renewal of NPDES permit NCO064726 for its East Bend Indus- trial Park WWTP in Yadkin County. This permitted facility discharges treated domestic and commer- cial wastewater to an unnamed tributary to the Yadkin River in the Yadkin -Pee Dee River Basin. Currently ammonia nitrogen, dissolved oxygen and total residual chlorine are water quality limit- ed. This discharge may affect future allocations In this portion of the watershed. WSJ: March 1, 2014 NCDENR North Carolina Department of Environment and Division of Water Resources Water Quality Programs Pat McCrory Thomas A. Reeder Governor Director February 26, 2014 Mr. Ryan D. Kerins Terraquest Environmental Consultants, P.C. 100 East Ruffin Street Mebane, NC 27302 Subject: Draft NPDES Permit Permit Number NCO088919 Dear Mr. Kerins: Natural Resources John E. Skvada, III Secretary OPOE s %lam Cady Quality Oil Company — Former Coliseum Shell G., -- ....,.. 0y3«111 Facility Rating: PC -1 Forsyth County Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very carefully to ensure thorough understanding of the conditions and requirements it contains. The draft permit contains a number of changes in its terms from those found in your current permit. A summary of those changes follows: • For most of the constituent parameters that contain limits in the existing permit, those limits have been removed, and their monitoring frequencies have been reduced to quarterly, with monitoring to be performed in conjunction with whole effluent toxicity testing • A new condition requiring electronic reporting of data collected pursuant to the terms of this permit has been added. Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will be adopted and is beginning implementation. The requirement to begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your NPDES permit. [See Condition A. (3.)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http: / /portal.ncdenr. org /web /wq /admin/bog/ipu/edmr. 1617 Mail Service Center, Ralegh, North Carolina 27699 -1617 Location: 512 N. Salisbury St Raleigh, North Carolina 27604 Phone: 919 -807 -63001 FAX: 919 - 807 -6492 Intemet: www.ncwaterquality.org An Equal Opportunity 1 Affirmative Action Employer Mr. Ryan Kerins NC0088919Renewal Draft p. 2 For information on EPA's proposed NPDES Electronic Reporting Rule, please visit the following web site: http: / /www2.epa.p,ov /compliance /proposed- npdes- electronic- reportin -rule. • A new condition has been added to the permit stating "This permit may be reopened and modified to implement nutrient requirements in accordance with any future TMDL and/or nutrient management strategy for High Rock Lake." Please submit any comments to me no later than thirty days following your receipt of the draft. Comments should be sent to the address listed at the bottom of this page. If no adverse comments are received from the public or from you, this permit will likely be issued in April 2014, with an effective date of July 1, 2014. If you have any questions or comments concerning this draft permit, call me at (919) 807 -6398, or via e- mail at bob.sledge @ncdenr.gov. Sincerely, 'e- Bob Sledge Compliance & Expedited Permitting Unit cc: NPDES Files ec: Winston -Salem Regional Office — DWR Water Quality Programs Aquatic Toxicology Unit Steve Reid Permit NCO088919 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER RESOURCES 199RUVW1 TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM In compliance with the provisions 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, Quality Oil Company is hereby authorized to discharge wastewater from a facility located at the Former Coliseum Shell 3009 University Parkway Winston -Salem Forsyth County to receiving waters designated as an unnamed tributary to Silas Creek in the Yadkin River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, Il, Ill, and IV hereof. The permit shall become effective This permit and the authorization to discharge shall expire at midnight on June 30, 2019. Signed this day 1111t,"K, all Thomas A. Reeder, Director Division of Water Resources By Authority of the Environmental Management Commission Page 1 of 7 Permit NCO088919 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. Quality Oil Company is hereby authorized to 1. Continue to discharge treated, gasoline contaminated groundwater from a groundwater remediation system that includes the following components: • Oil -water separator • Air stripper • High pressure sand filter • Particulate bag filters • Activated carbon filters • Associated tanks, pumps and piping This facility is located at the former Coliseum Shell, at 3009 University Parkway, in Winston - Salem, in Forsyth County. 2. Discharge from said treatment works at the location specified on the attached map into unnamed tributary to Silas Creek, a class C water in the Yadkin River Basin. Page 2 of 7 Permit NCO088919 A. (2.) CHRONIC TOXICITY PERMIT LIMIT (Quarterly) The permittee shall conduct acute toxicity tests on a guarterlX basis using protocols defined in the North Carolina Procedure Document entitled "Pass /Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (revised December 2010 or subsequent versions). The monitoring shall be performed as a Ceriodaphnia dubia 24 -hour static test. The effluent concentration at which there may be at no time significant acute mortality is 90% (defined as treatment two in the procedure document). The tests will be performed during the months of January, April, July and October. These months signify the first month of each three -month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR -1) for the month in which it was performed, using the parameter code TGE313. Additionally, DWR Form AT -2 (original) is to be sent to the following address: Attention: NC DENR / DWR / Environmental Sciences Section 1621 Mail Service Center Raleigh, NC 27699 -1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section 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 there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county, and the month /year of the report with the notation of "No Flow" in the continent area of the form. The report shall be submitted to the Environmental Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Resources indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. If the Permittee monitors any pollutant more frequently than required by this permit, the results of such monitoring shall be included in the calculation & reporting of the data submitted on the DMR & all AT Form submitted. 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. Page 4 of 7 Permit NCO088919 A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS Proposed federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The Division anticipates that these regulations will be adopted and is beginning implementation in late 2013. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) • Section D. (6.) • Section E. (5.) Reporting Records Retention Monitoring Reports 1. Reporting [Supersedes Section D. (2.) and Section E. (5.) (a)1 Beginning no later than 270 days from the effective date of this permit, the permittee shall begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / DWR / Information Processing Unit ATTENTION: Central Files / eDMR 1617 Mail Service Center Raleigh, North Carolina 27699 -1617 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1. 1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. Requests for temporary waivers from the NPDES electronic reporting requirements must be submitted in writing to the Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin using eDMR. Temporary waivers shall be valid for twelve (12) months and shall thereupon expire. At such time, DMRs shall be submitted electronically to the Division unless the permittee re- applies for and is granted a new temporary waiver by the Division. Page 5 of 7 Permit NCO088919 A. (3.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS, continued Information on eDMR and application for a temporary waiver from the NPDES electronic reporting requirements is found on the following web page: http: / /portal.nedenr.org /web /wq /admin/bog /ipu/edmr Regardless of the submission method, the first DMR is due on the last day of the month following the issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. 2. Signatory Requirements [Supplements Section B. (11.) (b) and supersedes Section B. (11.) (d)1 All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http: / /portal.ncdenr.or web /wq /adminibo ipu/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility offines and imprisonment for knowing violations. " 3. Records Retention [Supplements Section D. (6.)] The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41]. A. (4.) NUTRIENT REOPENER FOR HIGH ROCK LAKE This permit may be reopened and modified to implement nutrient requirements in accordance with any future TMDL and/or nutrient management strategy for High Rock Lake. Page 6 of 7 Permit NCO088919 Page 7 of 7 !` '-� ?� - •u- .-�',; V ���<�' -•�-'' i �..t 1'� i 1s7,1�"l sryy'6' /t � ��`� \'"!- ,.J�jf is •;��� � %jj t`_'.y •'!" ' V ............... IVA VM j YUI 1 )I Latitude: 36007'54" Quality Oil Company Facility Longitude: 80015'47" Location Quad #: C1 7SE Former Coliseum Shell Stream Class: C GW Remediation NPDES Permit NCO08891 Subbasin: 030704 Receiving Stream: UT to Silas Creek cft -0 t tIL Forsyth County Page 7 of 7 FACT SHEET FOR EXPEDITED PERMIT RENEWALS This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Basic Information for Expedited Permit Renewals Permit Writer/Date Bob Sledge 2/21/2014 Permit Number NCO088919 Facility Name Quality Oil Company — Former Coliseum Shell GWR Basin Name /Sub -basin number Yadkin -Pee Dee 030704 Receiving Stream UT to Silas Creek Stream Classification in Permit C Does permit need Daily Max NH3 limits? No Does permit need TRC limits/language? No Does permit have toxicity testing? Yes Does permit have Special Conditions? Added eDMR condition and High Rock Lake reo ever Does permit have instream monitoring? No Is the stream impaired on 303(d) list)? No Any obvious compliance concerns? Toxicity. Facility has been issued a SOC to address tox. Compliant with parameters of concern Any permit mods since last permit? No Current expiration date June 30, 2014 New expiration date June 30, 2019 Comments received on Draft Permit? Yes No If Yes, discuss response with Supervisor This permit is for a groundwater remediation system in Winston - Salem. The site is a former gas station. The groundwater is contaminated by gasoline, but groundwater monitoring also detected the presence of PERC (thought to have migrated to the site from a nearby dry cleaner). This is why the individual permit has been issued instead of the general permit for remediation of petroleum contaminated groundwater. The treatment system is contains multiple components, and is well operated and maintained. The effluent quality is excellent. Apart from some higher numbers associated with startup, the facility typically yields non - detect results for constituent parameters. A RPA was run for those parameters for which discreet values were reported. No reasonable potential for violating water quality standards was shown per the analysis for all the parameters, with the exception of lead. For these reasons, limits have been removed from the permit or all the organic compounds and monitoring frequencies have been reduced to quarterly, to be conducted along with toxicity testing. Both the Winston -Salem Regional Office and the Aquatic Toxicology Unit have been consulted about this change and both have noted their approval. Lead did show reasonable potential with the inclusion of a 140 µg/L value associated with the start up of the system on July 25, 2011. If this value is removed, the maximum predicted value drops from 267.4 gg/L to 38.5 pg/L. Because the first sampling event is seen as not representative of the facility's standard and long term performance, the decision regarding the limit is based upon the RPA not including that value. The limit has been removed and monitoring frequency has been reduced to quarterly. It is forecast that remediation at the site will soon be concluded and improvement at the site will be left to natural attenuation. If this occurs, the GWR system will be removed and the permit rescinded. A t"A" NCDENR North Carolina Department of Environment and Natural Resources Division of Water Resources Pat McCrory Thomas A. Reeder John E. Skvarla, III Governor Director Secretary December 17, 2013 Attn: Ryan D. Kerins Terraquest Environmental Consultants, P.C. 100 E. Ruffin St Mebane, NC 27302 Subject: Receipt of permit renewal Permit NCO088919 Forsyth County Dear Mr. Kerins: The NPDES Unit received your permit renewal application on December 16, 2013. A member of the NPDES Unit will review your application. They will contact you if additional information is required to complete your permit renewal. You should expect to receive a draft permit approximately 30 -45 days before your existing permit expires. If you have any additional questions concerning renewal of the subject permit, please contact Bob Sledge (919) 807 -6398. Sincerely, k' 4W Wren Thedford Point Source Branch cc: Central Files Winston -Salem Regional Office NPDES Unit 1617 Mail Service Center, Raleigh, North Carolina 27699 -1617 Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919 -807-63001 Fax: 919 - 807- 6492/Customer Service: 1-877-623-6748 Internet: www.ncwater.oro An Equal OpportunitylAffirmative Action Employer TERRA uest ENVIRONMENTAL CONSULTANTS, P.C. December 11, 2013 CERTIFIED MAIL ARTICLE NO.: 701 Wren Thedford NC DENR / DWR / NPDES Unit 1617 Mail Service Center DEC 1. 6 2013 I Raleigh, North Carolina 27699 -1617 —UA 1 DENR- WAl'E�: C)JALITY POINT SOURCE BRANCF Re: Permit Renewal Request NPDES Permit NC0088919, Former Coliseum Shell Station, Winston - Salem, Forsyth County, NC NCDWM -UST Incident No.: 15260 Terraquest Project No.: 01195 Dear Mr. Thedford: Terraquest Environmental Consultants, P.C. hereby requests renewal of the subject permit as detailed on the enclosed application form including Figure 1 — Site Location Map and Groundwater Analytical History - Effluent. Terraquest is authorized to make this renewal request as evidenced by the enclosed Delegation of Signature Authority. Additionally enclosed is the Special Order by Consent EMC SOC WQ S -12 -004 that this facility operates under. The minor volume of sludge that accumulates at this facility is removed by a vacuum truck subcontractor. Vacuum events are typically scheduled every six months but are adjusted as needed. Terraquest generally uses Shamrock Environmental Corporation who removes the sludge and disposes of it in an environmentally - friendly manner. Waste manifests and disposal sheets are routinely provided to NCDENR following the events. I can be reached at 919 563 -9091 or rdkerins@terraguestpc.com terraquestpc.com with any questions or concerns you may have. Thank you. Sincerely, TERRAQUEST ENVIRONMENTAL CONSULTANTS, P.C. 1 certify under penalty of law that this document and all attachments were prepared under my !i direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the �.% person or persons who manage the system, or those persons directly responsible for gathering \� ! the information, the information submitted is, to the best of my knowledge and belief, true, j accurate, and complete. 1 am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for knowing violations. Ryan D. Kerins Project Manager Enclosed: NPDES Permit Application - Short Form C — GW, Figure 1— Site Location Map (topographic map), Groundwater Analytical History - Effluent , Delegation of Signature Authority, Special Order by Consent EMC SOC WQ S -12 -004 cc: Quality Oil Company, LLC — BradleySnover, NCDWM- UST — Thomas Moore, NCDENR -DWQ — Ron Boone 100 E. Ruffin Street • Mebane, North Carolina 27302 Telephone (919) 563 -9091 • Facsimile (919) 563 -9095 www.terraquestpc.com NPDES PERMIT APPLICATION - SHORT FORM C - GW For discharges associated with groundwater treatment facilities. Mail the complete application to: N. C. Department of Environment and Natural Resources Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699 -1617 NPDES Permit Number INCO088919 If you are completing this form in computer use the TAB key or the up - down arrows to move from one field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type. 1. Contact Information: Owner Name Facility Name Mailing Address City State / Zip Code Telephone Number Fax Number e -mail Address Quality Oil Company Former Coliseum Shell PO Box 2736 Winston -Salem NC 27102 -2736 (336)722 -3441 (336)721 -9520 rdkerins@terraque stpc. com 2. Location of facility producing discharge: Check here if same as above ❑ Street Address or State Road City State / Zip Code County 3009 University Pkwy Winston -Salem NC 27105 Forsyth 3. Operator Information: Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the Operator in Responsible Charge or ORC) Name Terraquest Environmental Consultants, P.C. Mailing Address 100 E Ruffin St City Mebane State / Zip Code NC 27302 Telephone Number (919)563 -9091 Fax Number (919)563 -9095 4. Ownership Status: Federal ❑ State ❑ Private Public ❑ Page 1 of 3 C -GW 03105 NPDES PERMIT APPLICATION - SHORT FORM C - GW For discharges associated with groundwater treatment facilities. 5. Products recovered: Gasoline ® Diesel fuel ❑ Solvents ❑ Other 6. Number of separate discharge points: 1 Outfall Identification number(s) "Effluent" 7. Frequency of discharge: Continuous ❑ Intermittent If intermittent: Days per week discharge occurs: 7 Duration: effluent pumps several times per hour for 5 -15 minutes a cycle. 8. Treatment System Design flow 0.036 MGD 9. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including latitude and longitude): Silas Creek (36.132173,- 80.262971) 10. Please list all additives to the treatment system, including chemicals or nutrients, that have the potential to be discharged. 11. Is this facility located on Indian country? (check one) Yes ❑ No 12. Additional Information All applicants (including renewals): A USGS topographical map (or copy of the relevant portion) which shows all outfalls A summary of the most recent analytical results (effluent data, if available) containing the maximum values for each chemical detected NEW Applicants only: y Engineering Alternative Analysis Description of remediation treatment system components, capacities, and removal efficiency for detected compounds. y If the treatment system will discharge to a storm sewer, written approval from the municipality responsible for the sewer. A list of any chemicals found in detectable amounts at the site, with the maximum observed concentration reported for each chemical (the most recent sample must be collected less than one year prior to the date of this application) For petroleum- contaminated sites - Analyses for Volatile Organic Compounds (VOC) should be performed. Analyses for any fuel additives likely to be present at the site and for phenol and lead should also be performed. For sites contaminated with solvents or other contaminants - EPA Method 624/625 analysis should be performed. Pa-e 2 of 3 C -GW 03105 NPDES PERMIT APPLICATION - SHORT FORM C - GW For discharges associated with groundwater treatment facilities. 13. Applicant Certification I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed Signature cf Applicant Title Date !1/13 North Carolina General Statute 143 -215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides .a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) 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Name Ryan Kerins Andy Wrenn Megan Webster Title Operator in Responsible Charge Backup ORC Support Staff If you have any questions regarding this letter, please feel free to contact me at 919 -563- 9091. Sincerely, Ernie Rhymer Senior lice President cc: Winston -Salem Regional Office, Surface Water Protection Section Technical Assistance and Certification Unit