NC0032875_Wasteload Allocation_19890113

Class:
PERMIT NO.: NCO()
FACILITY NAME: 1 /1' Ily 5 1-7<=-
Se�rno- T.evw,,.:s, o,l
PUSIM
Facility Status:
(circle one)
PROPOSED
Permit Status: = RENEWAL MODIFICATION
(circle one) '-
Major minor, /
Pipe No:
Design Capacity (MGD):
Domestic (% of Flows
Industrial (X of Flow): /UU •
' oo
Comments: 6.0 s Oa ( u °-
a r> Abl2
NPDES WASTE LOAD ALLOCATION
11NPERMDTED NEW
PLOTTE
iL�
-tk 441
142-4-4141,
sc-M 1/6(89
17 RECEIVING STREAM: 7a1 f:)
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-US
Sub -Basin -
Reference USGS Quad: r 5E
County:
Regional Office: As Fa Mo (a
(circle ems)
03 -vy-0Z
Requested By:
Prepared By:
Reviewed By:
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Date: 9'
Date:
Date:
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Drainage Area (m12)
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-1 f3s
Date Rec.
Avg. Streamflow (cfs)•
7Q10 (cfs) 0 Winter 7.Q10 (cfs) 30Q2 (cfs)
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DEC!J )u��
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Request No.: 4794
PEU|TS &[NTUV[[Kn
WASTELOAD ALLOCATION APPROVAL FORM -------------------
Facility Name:
NPDES No.:
Type of Waste:
Status:
Receiving Stream:
Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Quad:
Phillips Pipe Line
NC0032875
Industrial
Exit/ s
UT to-�.JAZRiver
��
030402 (� '`
Johnston
Raleigh
Luis Harris
080288
E 25 SE
&A a
Company
Drainage
Summer �]
Winter 7Q
Average flo
30021"'
-------------------- RECOMMENDED EFFLUENT LIMITS ----------------
MONTHLY DAILY Min./Max. MONIT.
AVG. MAX' FREQ.
Wasteflow (mgd):
Settleable Solids (ml/l):
pH (su):
Oil & Grease (
Phenols
Lead (ug/l>:
Toxicity Testing Req.:
Turbidity (NTU):
0.1 0.2
6-9
30
2/mo.
2/mo.
2/mo.
2/mo.
2/mo.
Acute Toxicity Testing (EPISODIC)
Effluent turbidity shall not exceed 50
sq mi
cfs
cfs
cfs
cfs
NTU
C� �
a.X�
---------------------------- MONITORING ----------------------------
Upstream (Y/N): N Location:
Downstream (Y/N): N Location:
----------------------------- COMMENTS ---------- --------------------
The following products are stored: leaded and unleaded gasoline,
kerosene, and diesel fuel.
Behzene, toluene, xylene, napthalene monitoring requirements attached.
Requirement for one-time organic scan attached.
Flow monitoring requirement attached.
This facility discharges into a dry ditch ( Re: Staff Report }.
-------------
Recommended by:
Reviewed by
Tech Support Supervisor:
Regional Supervisor:
Permits & Engineering:
Date:�
Date:
Date:
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RETURN TO
TO TECHNICAL SERVICES BY: ������_1��
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Flow -- Permit must contain flow monitoring requirement such that all
volumes of wastewater leaving the facility are monitored. If continu-
ous monitoring is not feasible, then discharger shall record the
approximate times that discharge began and ended, along with the
instantaneous flow at the time of effluent sampling.
Monitoring --Recommend monitoring for benzene, toluene, and xylene
(BTX) during the first 5 discrete discharge events (and then annually
to coincide with whole -effluent toxicity test) after the effective
date of the NPDES permit. Monitoring should occur at the same time
that the whole -effluent toxicity sample is taken during the discharge
event (samples should be collected within 24 hours of the beginning
of the event). A reopener clause should be placed in the permit to
allow for additional limits on these or other toxicants should the
facility fail its whole -effluent toxicity tests. Also, the following
requirement should be included: "Within 60 days of the first discharge
event the permittee shall also submit the results of the following
analyses. These analyses shall be performed on a representative
sample of the stormwater effluent discharge, taken after any treatment
(required one time only) :
a. EPA Method 625 - Acid and base/neutral extractable organics
b. EPA Method 624 - Purgeable Organics

Facility Name
ltt�s PINLt Q Go.
to. ee„ 00 t 4. 06 y/
ACUTE TOXICITY TESTING REQUIREMENT
Daphnid 48 hr - Monitoring for Episodic Events
Pe.rnnit iJC 00 3_ 15
The permittee shall conduct FIVE acute toxicity tests using protocols defined in E.P.A. Document
600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and Marine Organisms".
The monitoring shall be performed as a Daphnia pulex or Ceriodaphnia 48 hour static test, using
effluent collected as a single grab sample. Effluent samples for self -monitoring purposes must be
obtained below all waste treatment. Sampling and subsequent testing will occur during the first five
discrete discharge events after the effective date of this permit. After monitoring of the first five
toxicity tests, the perrittee will conduct one test annually, with the annual period beginning in
January of the next calendar year. 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 if using Daphnia pulex is TAA3D. The parameter code for this test
if using Ceriodaphnia is TAA3B. 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, DEM Form AT-1 (original) is to
be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
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 Environmental Management 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.
Failure to submit suitable test results will constitute a failure of permit condition.
7Q10 0 cfs
Permitted Flgw W / R MGD
IWC% l 0 0 7.
Basin & Sub -Basin 0 3040 2, ,
Receiving Stream T A-o to Q J v, 19rvak
County 1.o4^v► S LONA Date 11 10/ r
**Acute Toxicity(Daphnid 48 hr) Monitoring, EPISODIC, See Part 3 , Condition
Recommended by:

DIVISION OF ENVIRONMENTAL MANAGEMENT
January 9, 1989
MEMORANDUM
f0: Arthur Mouberry
FROM: Trevor Clementsc
Mike Scoville OD
THRU: Steve TedderV'
SUBJECT: Oil S Petroleum Storage Facilities Dischargino t•c Mill Creek
(030402, Johnston County?
Technical Services has recently learned that a UT to the Meuse River
classified as WS1I: NSi- is actually ,lamed Mi l i Creek and ie c1a==_ifilad as
C-NSW. ,ccor-ding to the Raleigh Regional Office, Mill Creek receives th::
wastewa:= of nine oil and petroleum storage termiral5:
Shell Oil NC1:0O 5 i'=
L 1 co NCOOE 1 95 +
E x d o �9C( O2 00
-Ina Oil and Chemical NC002 722^
Colonial Pipeline Nl,0031011
Fh i : 1. L os Petroleum :Z0032875
=r 0,1 Co. / kC0O3614.5
Oil i :C;.l:)+9, 01;
corn NC005211
Current Divisional procedure a reouires a phenols limit _-1 It'%c:�•,
for cUCr facilities that discharge to WS1 . 1 .raters. Howe. =r . l t-' i .oht o
the i mill Cree^ . lec rlra. Sec.:ices _cep H-':a t ti't i1
phenol: limit for . of these facilities be iric'.:ased .:: `.1. •ca• as
their - .._ t5 _otrE "J',7:7 renewal. The c pf Mill the
tieuss f"::.er :3r?or: :lmateiv two miles upstream of _ -:lthfIeld 5i•.a -- s::.31J1t
intake. •:.t the wateJ supply intai e a phenols cocentraticn: of _ 4:L; Or jUSE,
must b ,,aintained at low flow condition:: (controlled low flow at Smithfield
184 _ . the proposed 0.01 lb/day phen_ls limit will meet this ..-itericn.
In fact. the e=1imatsd .gorse case phenols loadings meets the ter_or.
of 1 1'. '1 thc- tc:._ . allowable phenols load for this W1 1 . lave it
up to .. whether to communicate this recommend iticn and :1'1c1n7.1E t`ri. _ lF'?lQ •-1
limit of Chose facilities Whose permits do not expire' i the ile. r 'ft:t•_ir i=.
cc: Dale 0vercash
Bill kreutzburoer. RRO
Mill Creek Subbasin File

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor
William W. Cobey, Jr., Secretary
March 31, 1989
Mr. M. W. Holcomb
Senior Environmental Specialist
Phillips Pipe Line Company
3 B10 Adams Bulding
Bartlesville, OK 74004
SUBJECT: Draft Permit Comments
NPDES Permit No. NC0032875
Phillips Pipe Line Company
Selma Terminal
Subbasin 030402
Johnston County
R. Paul Wilms
Director
Per your request, the Division has reviewed your comments submitted
to me by letter dated February 27, 1989, concerning a draft copy of the
subject NPDES permit. Our response to these comments is as follows:
1. Permittee Designation:
Phillips Pipe Line Company will be designated as the permittee.
2. Napthalene, Toxicity and Organics:
These requirements should remain as set forth in the permit.
They are based on current Divisional procedures for oil termi-
nals and tank farms, and they are being consistently applied to
all facilities of this type throughout the State. Napthalene is
present in diesel fuel which is stored in the terminal. The
whole effluent toxicity testing is necessary to evaluate the
potential toxic impact of the discharge. Note that the require-
ment is for acute toxicity testing for episodic events and that
there is no chronic target.
Regarding the comment about Part III, Condition H in the permit,
this condition should read: "Within 60 days of the first dis-
charge event, the permittee shall also submit the results of the
following analyses. These analyses shall be performed on a rep-
resentative sample of the stormwater effluent discharge, taken
after any treatment (required one time only):
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

Mr. M. W. Holcomb
March 31, 1989
Page Two
1) EPA Method 625 -Acid and Base/Neutral Extractable
Organics and;
2) EPA Method 624-Purgeable Organics."
3. Phenols:
This facility discharges approximately two miles upstream from
surface waters classified "WSIII-NSW" which denotes a source of
water supply for drinking, culinary, or food processing pur-
poses. This classification protects the Town of Smithfield's
water supply. Therefore, under North Carolina Administrative
Code Title 15 2B. 0203, current Divisional procedure requires a
0.01 lb/day phenols effluent limitation to all oil terminals
discharging into Mill Creek and its unnamed tributaries. At the
water supply intake a phenols concentration of 1.0 ug/1 or less
must be maintained at low flow conditions; the 0.01 lb/day phe-
nols limit meets this criterion considering all other oil termi-
nals discharging into the Mill Creek watershed.
4. Settleable Solids and Turbidity:
Stormwater run-off is expected to contain solids and to be tur-
bid by nature. The limitations contained in the permit for
these two effluent parameters are based on North Carolina water
quality standards. They are both applied to all oil terminals
and tank farms by current Divisional procedure. Therefore, they
should remain in the permit. However, the Division would not
object to a 30 mg/1 TSS limit if Phillips Pipe Line Co. would
accept it in lieu of the settleable solids limitation.
5. BOD5 and MBAS:
According to our Raleigh Regional Office, a field investigation
indicated that trucks are washed in the terminal, and the pro-
cess wastewater is disposed of through the permitted outfalls.
Therefore, based on a Division's study of wastewater character-
istics, BOD5 and MBAS monitoring is appropriate to determine the
extent of the impact of the truckwashing operation which is very
unclear at this point. The Division would not object a permit
condition indicating that no car wash or other process waste-
water should be disposed of through the permitted outfalls in
lieu of the monitoring requirements for BOD5 and MBAS. In this
case, the Raleigh Regional Office will enforce compliance with
this permit condition or any illegal discharges of process
wastewater.

Mr. M. W. Holcomb
March 31, 1989
Page Three
You may request all monitoring frequencies be revised after twelve
months of data. At that time, any monitoring frequency may be reduced to
1/month should the data for a given parameter indicate that the concen-
tration of such parameter is consistently well below the permit limita-
tion.
Please notify Mr. Arthur Mouberry, of the Permit and Engineering
Unit, by April 14, 1989 should you accept the proposed TSS limitation
and/or the permit condition regarding the process wastewater discharge.
If you have any questions concerning the Division's position in
these issues, please contact Mr. Trevor Clements or Mr. Arthur Mouberry
at 919-733-5083. Should you feel your comments are not addressed in the
issued permit, you may request an adjudicatory hearing in accordance with
Chapter 150B of the General Statues of North Carolina within 30 days of
issuance of the permit.
i
Si.ncerely,/
R. 'Paul Wilms
cc:
Trevor Clements
Bill Kreutzberger
Juan C. Mangles
Arthur Mouberry
Phillips Pipe Line WLA File
Central Files
JCM/JTC

State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W. Cobey, Jr., Secretary Director
March 15, 1989
Mr. M. W. Holcomb
Senior Environmental Specialist
Phillips Pipe Line Company
3 B10 Adams Building
Bartlesville, OK 74004
SUBJECT: Draft Permit Comments
NPDES No. NC0032875
Phillips Pipe Line Company -Selma
Johnston County
Dear Mr. Holcomb:
This letter is to acknowledge receipt of your letter dated February 27, 1989,
containing comments on the subject DRAFT permit. The Division of Environmental
Management will consider your comments in making its decision on the issuance of the
permit. If you feel that your comments are not addressed in the issued permit, you
may request an adjudicatory hearing in accordance with Chapter 150B of the General
Statutes of North Carolina within 30 days of issuance of the permit.
If you have any questions, please contact me at 919/733-5083.
M. Dale 0vercash, P.E.
Supervisor, NPDES Permit Group
cc: Mr. Bill Kreutzberger (with attachments)
Mr. Trevor Clements (with attachments)
do/ jk
MAR '89
TE'CHIViCAL L:is,r,CLS BRANCH
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

61\24A(6:10 \)&--
pe.A,
3/2461
February 27, 1989
Selma Terminal
NPDES Permit No. NC0032875
Comments on Draft Permit
Mr. R. Paul Wilms, Director
Division of Environmental Management
State of North Carolina
Environmental Management Commission
P.O. Box 27687
Raleigh, NC 27611-7687
Dear Mr. Wilms:
MhR �>
£)r fF£i..,
P,.I,re,gr, NC r,4.iG£ £NT
Phillips Pipe Line Company submits the enclosed comments on the draft NPDES
permit issued for the Selma Terminal.
Phillips appreciates the opportunity to comment on the draft permit prior to
final issuance and the Commission's careful consideration of the comments.
If you have any questions regarding these comments, please contact me at
[phone].
Sincerely,
M. W. Holcomb
Senior Environmental Specialist
3 B10 Adams Building
Bartlesville, OK 74004
MWH:rs:trs06:01
Enclosure
cc: N. R. Brown - Selma Terminal
BARTLESVILLE, OKLAHOMA 74004 918 661-6600

PHILLIPS PIPE LINE COMPANY
SELMA TERMINAL
COMMENTS ON DRAFT NPDES PERMIT NC0032875
Phillips Pipe Line Company submits` the following comments on the draft NPDES
permit for the Selma Terminal.
General Facility Information
Facility Function
Phillips believes it is important to clearly understand the operations of the
Selma Terminal so that appropriate effluent limitations and permit conditions
can be established for the facility. Selma Terminal is a facility that
receives refined petroleum products by pipeline, stores these products
temporarily in product storage tanks and transfers these products to transport
trucks of various distributors for eventual sale to the public. Selma
Terminal does not refine, treat or otherwise process crude oil or any
intermediate petroleum product. The facility, therefore, does not generate
process wastewaters. Of course, occasional drainage of water from the product
storage tanks may, at times, be included in the discharge. Selma Terminal
discharges primarily excess stormwater that accumulates inside the diked
storage tank areas. The terminal also discharges stormwater that falls onto
the covered truck loading dock pad and the small quantity of water used at the
facility to wash down the loading dock pad.
Hours of Operation
The facility is manned 5 days per week, 8 hours per day. Because the product
loading system is automated, the facility is open 7 days per week, 24 hours
per day to qualified distributors. Transport truck drivers are carefully
trained to conduct loading operations at the Terminal in a safe manner.
Additional training of these drivers is done at scheduled intervals so that
loading operations are carried out safely.
Stormwater System
As previously mentioned, the product storage tanks are located within areas
surrounded by earthen dikes. Two such diked areas, from which Outfalls 001
and 002 originates, exist at the Terminal. The primary purpose of these diked
areas is to provide a containment area for the stored products in the unlikely
event of a.tank rupture, line break or similar incident. As these areas
retain the stormwater falling within the dikes, they occasionally must be
drained of water so that their emergency product containment function is
preserved. While such stormwater contacts the outside of the product storage
tanks, piping and similar equipment, it does not come into direct contact with
the stored product. Therefore, the chance of significant stormwater
contamination is slight.
Stormwater and washdown water from the truck loading dock is treated in an
oil -water separator with the water effluent routed to the diked area from
which Outfall 001 originates. It is possible that some hydrocarbon product
remaining in the water effluent at a low parts per million range may contact
stormwater accumulated in that diked area. Phillips believes that routing of

Phillips Pipe Line Company, '
Selma Terminal
NPDES Permit No. NC0032875
Page 2
such effluent to a diked area is environmentally sound in that it provides a
temporary holding area for the separator effluent so that it can be visually
checked for the presence of hydrocarbons prior to release.
All waters released from the two diked storage areas are checked visually for
the presence of hydrocarbon products prior to release in accordance with
written procedures required by the facility's Spill Prevention, Control and
Countermeasure (SPCC) Plan. Traces of floating hydrocarbons are removed prior
to release. Phillips believes that in view of the low solubility of these
products in water and the time allowed for physical separation of the
hydrocarbon from the water in the diked areas, the terminal's discharges offer
an extremely low potential for adverse impact on receiving waters.
Comments on Specific Permit Conditions
The following comments on the specific draft permit conditions should be
considered in light of the above facility information and the limited
potential for adverse environmental impactresulting from the facility's
discharge. These comments apply to both outfalls 001 and 002 unless otherwise
noted.
A. Permittee Designation
Selma Terminal is owned and operated by Phillips Pipe Line Company. Please
change the permit's cover sheet to indicate that Phillips Pipe Line Company is
the permittee rather than Phillips Petroleum Company.
B. Acute Toxicity
While Phillips supports the goal of limiting or, if possible, eliminating
toxic discharges to the waters of the United States, we believe that
reasonable judgement must be exercised in achieving this goal.
Measurement of acute toxicity of wastewater is not a straightforward or
precise technique. Acute toxicity testing is both a time consuming and costly
procedure. Phillips, therefore, believes that acute toxicity testing should
not be required of every discharger. Monitoring of effluent toxicity is
appropriate for major municipal or industrial dischargers whose discharge may
contribute significantly to the amount of toxic pollutants in a waterway. We
do not believe that such monitoring is necessary or appropriate for a product
terminal's discharge. The Selma Terminal's discharges are primarily
stormwater and generally are only slightly contaminated. Such discharges do
not contain process wastewater which could be a significant source of toxic
pollutants. The Selma Terminal's stormwater effluent is a minor source of
discharge to the receiving streams and does not represent a significant threat
to the water quality of those receiving streams.
Toxicity testing is not a mandatory requirement for NPDES permits. The Agency
has the discretion to require whole effluent toxicity testing when
appropriate. Phillips believes that whole effluent toxicity testing is
appropriate only for potentially significant contributors of toxic pollutants.
Clearly, Selma Terminal is not a potentially significant contributor of toxic
pollutants to the waters of the State.

Phillips Pipe Line Company.
Selma Terminal
NPDES Permit No. NC0032875
Page 3
Phillips encourages the State to prioritize its requirements for whole
effluent toxicity testing in a manner consistent with other states and EPA
Regional offices. Such prioritization, in descending order for toxicity
testing requirements, follows:
1. Major industrial, municipal and federal facilities.
2. Selected minor industrial and federal facilities associated with toxic
problems.
3. Selected minor municipal facilities associated with toxic problems.
4. Other minor municipal facilities.
5. Other minor industrial facilities.
Phillips believes that Selma Terminal <
should not be required to perform the i
because:
1. Selma Terminal is not a major i
2. Selma Terminal is not a major c
receiving streams.
uos
t category and
testing
to the
3. Selma Terminal is not a facility associated with toxic pollution
problems.
4. Selma Terminal does not employ processes or operations that result in
significant contributions of toxic pollutants to its discharges or the
receiving streams.
Phillips therefore requests that the requirement to perform acute toxicity
tests on the first five discrete discharge events be deleted from the final
permit.
C. Phenols
Phillips recognizes that the State maintains the following phenolic compound
requirements for Class C waters:
Phenolic compounds: only such levels as will not result in fish -flesh
tainting or impairment of other best usage.
Selma Terminal operations do not add phenols to the wastewater by any
manufacturing process. Phenols exist in the facility's stormwater only to the
extent that such stormwater comes into limited contact with hydrocarbon
product. Since contact with hydrocarbon product is minimal, the potential for
significant phenol levels in the stormwater should be very low.
Since (1) the discharge from Selma Terminal is extremely infrequent, (2) the
potential for significant phenol levels is low, and (3) Phillips is not aware
of any evidence that indicates the facility's discharges have caused
significant water quality problems relating to phenols, Phillips requests that
the proposed numerical limitation for phenols be dropped from the final permit

j Phillips Pipe Line Company.
Selma Terminal
NPDES Permit No. NC0032875
Page 4
and be replaced with a requirement to measure and report phenol concentration
of the discharge.
Such a requirement will allow the development of a good data baseupon which,
if a phenol problem is indicated, the Agency may base a future revision of the
permit.
D. Settleable Solids
The draft permit limits settleable solids in the Selma Terminal's discharge.
This is a most unusual effluent limitation for a product terminal discharge.
It may be appropriate to limit settleable solids for a municipal or industrial
discharger which employs some type of biological treatment (or otherwise adds
settleable type solids to the wastewater). However, Selma Terminal neither
employs such treatment nor otherwise adds settleable solids. Here, the
principal settleable solids are primarily inorganic particles such as soil or
dirt (essentially nonvolatile suspended solids). In the diked areas, the
stormwater is retained long enough for this material to settle. However, the
stormwater is not retained long enough for algal growth or any other
biological material to develop.
Therefore, Phillips requests that the requirement to measure and report
settleable solids and the specified effluent limitations for this parameter be
deleted from the final permit.
E. Turbidity
As with the settleable solids effluent limit, this is a most unusual
requirement for a terminal permit. Please refer to arguments presented for
settleable solids as they apply to this parameter also.
The specified turbidity requirement is adequately covered in the State's water
quality standards which are applicable to all freshwater bodies in the State.
It is not necessary to include the turbidity water quality standard as a
permit condition. Phillips, therefore, requests that this parameter be
deleted from the measurement and reporting requirements of the final permit.
F. Acid and Base/Neutral Extractable Organics
Purgeable Organics
Napthalene
Part III. Condition H
It is unclear from the draft permit wording what is being proposed in
Part III, Condition H. First, there is no "groundwater effluent discharge"
from this facility. There are two surface discharge points as described in
the General Facility Information above. Second, because of the intermittent
nature of these discharges, it could be physically impossible to comply with
the 60 day submittal requirement unless a significant rainfall event occurs
which results in a discharge.
Phillips does not believe that the nature of Selma Terminal's discharges
warrants the monitoring of the full slate of parameters included in the Acid
and Base/Neutral Extractable Organics or the Purgeable Organics. Phillips
also does not believe the discharge warrants the monitoring of napthalene.
Testing results from other Phillips' product terminals and from stormwater

Phillips Pipe Line Company, •
Selma Terminal
NPDES Permit No. NC0032875
Page 5
effluents from Phillips 66 Company's refineries have showed that nearly every
compound covered by these two groups are below the detectable limit of the
test procedures. Phillips believes that monitoring of toluene, benzene and
xylene is adequate for this type of discharge.
Phillips can provide the test results that have been obtained for these
product terminals and refinery discharges as supporting evidence of these
positions if requested to do so.
Phillips requests that Part III, Condition H of the proposed permit be
deleted. Also, Phillips requests that the Acid and Base/Neutral Extractable
Organics, Purgeable Organics and Napthalene be deleted from the effluent
limitations and monitoring requirements for both discharge points.
G. BOD5
Phillips does not believe that the BOD5 parameter is appropriate for these two
discharge points. The organic content of the stormwater will be adequately
monitored through the oil and grease test and by measuring the toluene,
benzene and xylene content. Since the nature of the Terminal's operations
does not contribute or add organic material to the stormwater except through
the incidental contact of the stormwater with small quantities of product, the
measurement of BOD5 is not justified. Futhermore, no treatment facilities
specifically designed to reduce the BOD5 content are provided since there is
no need to do so because of the low levels present.
Therefore, Phillips requests that B0D5 be deleted from the effluent
limitations and monitoring requirements for both outfalls.
H. MBAS
As with BOD5, Phillips does not believe the nature of the Terminal operations
supports the need to monitor the MBAS levels in the two outfalls.
Therefore, Phillips requests that MBAS be deleted from the effluent
limitations and monitoring requirements for both outfalls.