NC0021971_Permit Modification_20080418

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NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Coleen H. Sullins, Director
April 18, 2008
Ms. Maribeth Dobbins
BP Products North America, Inc.
7401 Old Mount Holly Road
Charlotte, N.C. 28214
Subject: Modification of NPDES Permit NC0021971
Paw Creek Terminal
Mecklenburg County
Dear Ms. Dobbins:
Division staff have reviewed and approved your two requests to modify the subject permit. References to
the oil / water separator have been removed as you requested. Also, quarterly ethanol monitoring has been
added. The potential toxicity of ethanol has not been determined for your location; no ethanol limit will be
imposed at this time. No other changes to the permit have been made.
Please find enclosed the revised pages, which should be inserted into your permit. The old pages may
then be discarded. All other terms 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.
If any 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 a written petition conforming to Chapter 150B of
the North Carolina General Statutes, 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.
If you have any questions concerning this permit modification, please contact Charles Weaver of the
NPDES Unit at [phone], extension 511. If you wish to discuss the removal process for the oil / water
separators with the Mooresville Regional Office, contact Mike Parker at [phone] [or
michael.parker@ncmail. net] .
Sincerely,
oleen H. Sullins
cc: Central Files
Mooresville Regional Office / Mike Parker
NPDES Unit
Aquatic Toxicology Unit
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
512 N. Salisbury St., Raleigh, North Carolina 27604
Phone: [phone] / FAX [phone] / www.ncwaterquality.org
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
NorthCarolina
Naturally

Permit NC0021971
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked,
and as of this 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 described herein.
BP Products North America is hereby authorized to:
1. Continue to operate the existing water pollution control system that includes the
following components:
• containment basins
This permitted facility is located at the Charlotte BP Terminal/Paw Creek off Old
Mount Holy Road near Charlotte in Mecklenburg County.
2. Discharge stormwater and loading rack wash water through Outfall 009 at a specified
location (see attached map) into an unnamed tributary to Paw Creek, a class C stream
within the Catawba River Basin.

Permit NC0021971
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 009. Such discharges shall be limited and monitored
by the Permittee as specified below:
PARAMETER
LIMITS
MONITORING
REQUIREMENTS
Sample
Type
Sample
Location
Monthly
Average
Daily
Maximum
Measurement
Frequency
FIow1
Episodic
1
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Oil and Grease2
Monthly
Grab
Effluent
Turbidity3
50 NTU
Monthly
Grab
Effluent
Benzene
Quarterly
Grab
Effluent
Toluene
Quarterly
Grab
Effluent
Ethyl Benzene
Quarterly
Grab
Effluent
Xylene
Quarterly
Grab
Effluent
Ethanol
Quarterly
Grab
Effluent
Naphthalene4
Monthly
Grab
Effluent
Acute Toxicity5
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 must be measured 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); see special
condition A.(3.) for rational equation.
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 zone.
3. Turbidity - Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving
stream background turbidity exceeds 50 NTU, effluent shall not cause this background value to
increase.
4. Naphthalene - Monitoring requirement applies to facilities that store, or historically stored, diesel
or other heavy fuels on site.
5. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2.)]. Permit holder
shall sample for acute toxicity and BTEX concurrently.
There shall be no discharge of floating solids or foam visible in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing
unless benzene concentration is less than 71.4 µg/1 and toluene concentration is less than
11 µg/1.

Re: mod request for NC0021971
Subject: Re: mod request for NC0021971
From: Michael Parker <[e-mail]>
Date: Thu, 17 Apr 2008 15:09:27 -0400
To: Charles Weaver <[e-mail]>
Charles,
After reviewing this matter, I don't have any objections to moving forward with this
request. It doesn't appear that the old loading rack area is now a significant
source of pollutants, and the company plans to route any water coming from this area
into a vegetated part of the property anyway, which would help remove/mitigate any
constituents that may be present. In other words, I don't see a problem with it.
If you have any questions, just let me know.
Mike
Charles Weaver wrote:
Michael Parker wrote:
IDid you ever get a chance to fax us the second modification request? If you
did, I don't remember receiving it.
I sent it before sending the e-mail. I'll send it again.
CHW
Michael Parker - [e-mail]
Environmental Engineer II
North Carolina Dept. of Environment & Natural Resources
Division of Water Quality
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
1 of 1 4/18/2008 8:34 AM

bp
February 7, 2008
0
BP Products North America Inc.
7401 Old Mount Holly Road
,Clharlotte, North Carolina 28214
Manager RE: BP Products North America
State of North Carolina NPDES Permit # NC0021971
Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
To Whom It May Concern:
BP Products North America In. (BP) owns and operates the petroleum bulk storage and
distribution facility located at 7401 Old Mt. Holly Road in Charlotte. The facility is
operated under the above -referenced National Pollution Discharge Elimination System
(NPDES) Permit.
BP is in the process of preparing the terminal to store and distribute denatured ethanol, in
addition to the refined petroleum products and additives already handled at the facility. It
is anticipated that the first shipments of denatured ethanol will arrive at the facility during
the summer of 2008.
BP is hereby notifying the Division of the addition of denatured ethanol to the list of
products handled at the facility. The material will be stored in an above -ground bulk
storage tank and distributed via a new loading/unloading area. In addition, once the
denatured ethanol arrived onsite, all gasoline distributed from the property will contain
approximately 10% denatured ethanol.
Material Safety Data Sheets (MSDS) for both denatured ethanol and gasoline containing
denatured ethanol are attached for your reference.
If the Division requires any modifications to the above -referenced permit, please contact
me at 704-399-3925 or at Maribeth.DobbinsAbp.com.
Sincerely,
Maribeth Dobbins, PE, CSP
Environmental Coordinator

bp
BP Products North America Inc.
7401 Old Mount Holly Road
Charlotte, North Carolina 28214
February 6, 2008
Manager RE: BP Products North America
State of North Carolina NPDES Permit #NC0021971
Department of Environment and Natural Resources
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
To Whom It May Concern:
BP Products North America Inc. (BP) owns and operates the petroleum bulk storage and
distribution terminal located at 7401 Old Mt. Holly Road in Charlotte. The facility is operated
under the above -referenced National Pollutant Discharge Elimination System (NPDES)
Permit.
BP purchased the subject facility on February 1, 2006 from TransMontaigne. At that time, the
NPDES permit was in place. BP applied to have the NPDES permit transferred to the BP
name immediately following the property transfer and that request was granted.
Following review of the subject permit, it seems that a change has occurred at the facility that
is not reflected in the current permit. This change is the relocation of the facility loading rack.
The loading rack was formerly located in an area that is now an overflow parking lot for
passenger vehicles (see attached photo).
The current loading rack is operated as a closed -loop system. The entire structure is covered
by a canopy (see attached photo). Any surface water that does manage to enter the loading
rack drain system is contained onsite and recycled off -site as petroleum contact water.
The water drains in the former loading rack area currently drain into two oil -water separators
(see attached photo). The oil -water separator then drains to the facility's secondary
containment basins. The operation of the oil -water separators is cited in the subject NPDES
permit.
The oil -water separators are not necessary to treat the stormwater that collects in the former
loading rack area, as this area is no longer a potential petroleum contact point. BP is therefore
requesting permission to remove the two oil -water separators and pave over the influent drains
in the parking lot. The paving will alter the surface water flow in the parking area and direct
it into surrounding unpaved and vegetated areas. Therefore, the removal of the separators will
not increase the effluent flow rate or negatively affect the effluent quality at the facility.

Removing the oil -water separators will necessitate a modification to the subject permit. BP
hereby requests that the requested change be made to the NPDES permit so that removal of
the separators can commence as soon as possible.
If you have any questions, or require any additional information, please feel free to contact me
at 704-399-3925 or at Maribeth.Dobbinsgbp.com.
Sincerely,
h iflaCt
Maribeth Dobbins, PE, CSP
Environmental Coordinator
cc: Keith Lewis — BP

Current Loading Rack:
_
Old Loading Rack/Current Overflow Passenger Vehicle Parking Area:

Oil -Water Se , . ators:
Oil -Water Separator Outfall into Facility Bulk Tank
Secondary Containment: