NC0021971_Permit Issuance_20010730

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Ms. Barbara Castleberry
TransMontaigne Terminaling, Inc.
200 Mansell Court East — Suite 600
Roswell, Georgia 300764853
Dear Ms. Castleberry:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
July 30,2001
Subject: Issuance of NPDES Permit NC0021971
Charlotte/Paw Creek Terminal #2
Mecklenburg County
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
May 9,1994 (or as subsequently amended). Please note the following changes from your draft permit, most of which are the result of
the Paw Creek hearing officer's recommendations:
• pH monitoring and limits have been removed from your permit This was an error made in all of the Paw Creek draft
permits. The pH requirement was eliminated in the previous permitting cycle and should not have been included in the 2001
permits.
• The monthly monitoring requirement for naphthalene has been deleted. Semi-annual monitoring using EPA
Method 625 replaces it. As per the hearing officer's report, 625 is the best method for detecting naphthalene and other
middle distillate compounds and is therefore a more appropriate monitoring requirement If your facility collects eight to ten
samples in which none of the 625 compounds are detected, you may submit a request to the Division that this sampling
requirement be eliminated.
• The site address has been corrected on your permit to 7401 Old Mount Holly Road.
Flow monitoring frequency has been changed from monthly to episodic. As per a request by the Mooresville Regional
Office, flow must be measured with each discharge event
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 Quality 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 Natalie Sierra at telephone number [phone],
extension 551.
Kea T
7L"
cc: Mooresville Regional Office/Water Quality Section
NPDES Unit
Central Files
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Department of Environmental Protection
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center..1 800 623.7748

Permit NCO021971
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
AL POLLUTANT DISCHARGE ELIMINATION SYSTEM
r,
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended,
TransMontaigne Terminaling, Inc.
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte/Paw Creek Terminal #2
7401 Old Mount Holly Road
Charlotte
Mecklenburg County
jasPaw°
to receiving waters designate Creek in the Catawba River Basin in accordance with effluent
limitations, monitoring require -and other conditions set forth in Parts I, II, III and IV hereof
This permit shall become effective September 1, 2001.
This permit and authorization to discharge shall expire at midnight on June 30, 2005.
Signed this day July 30, 2001.
Division dt Quality
By Autho ty o the Enviro ental Management Commission

Permit NC00219-A
SUPPLEMENT TO PERMIT COVER SHEET
TransMontaigne Terminaling, Inc.
is hereby authorized to:
1. continue to operate the existing water pollution control system consisting of:
• oil/water separation
• containment basins
located at the Charlotte/Paw Creek Terminal #2 at 7401 Old Mount Holy Road near Charlotte in
Mecklenburg County, and
2. discharge stormwater and loading rack wash water from said treatment facility through Outfall 009
at a specified location (see attached map) into an unnamed tributary to Paw Creek, a waterbody
classified as C waters within the Catawba River Basin.

Latitude: 35016'37" N j ,Longitude: 80056'05" W N C 0 0 219 71 Facility
Quad N F15SW/Mountain Island Lake Location
Receiving Stream: Ur r to Paw Creek
Stream Class:C TransMontaigne Terminaling
Subbasin: 30834
Paw Creek Terminal#2 th q� // NOT TO SCALE
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NCO021971 - Transmontaigne Terminaling, Inc. Facility I : ,
Paw Creek #2 Location
Facility/Site Plan no rt4

Permit NCO021971
A. (1.) EFFLUENT LIN
Beginning on t e et ecttve i
discharge from Outfall 009.
specified below:
TATIONS AND MON
tte of the permit anast
Such discharges shall be
iration, the Permittee is authorized to
monitored by the Permittee as
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total Suspended o i s
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ont y
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Turbidity
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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);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
3. 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. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2.)].
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/l.

Permit NCO021971
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas)
24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste
treatment. The permittee will conduct one test annually, with the annual period beginning in January of
the calendar year of the effective date of the permit. The annual test requirement must be performed and
reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.

n ILDRY RING ^4
7l6 wor�TOBE HLIO BY
Alickle Ibu TE NORTH CAROLINAENVIRONMEMTALMANAGEMEI C4WMMSION
nwU folowi OT'Apu Pennnnrin9 ham been scheduled mnceMinp Me poposed renewal and issuance al
McSUBJEC ApG hears'
- Permit nurMer NC0021962 to CITGO Parulalnt Go lmarmem Me Uie Paw Creak Temoral upec i in
Charlotte, N.C. Charlotte (Mecklembul County) for Me tl uhmoe 0 manmxaler fnW an unnamed moufary to Gum
AFFlnL4V1T0FPUHLICAI Branch,
- Permit nulrtear NCO221B7 to Mon. Eotmosas Mi, Me Paw Creek Terminal bmarl m Chrblle
NORTD CAROWNA (M¢ekl¢npurg County) loin he appoi to o(Srptriwa r and rertle'FLea gmunawaler Into an unnamed
MECKf.ENBURG CCII W mbulery to Gum Branch,
N o«!e andenlancd, Mutiny I " Peme! number NCM32MI to Philips Pipe lire Company M Me Chanolte Terminal lasted In
barrel Camoolim, duty ... Iim in, Charlotte (MecMnNury County) IOY. the discnarpe of abrrnwatN Area an unnamed hjpWary to Gum
Nw maahmummefaalW, I .... all, BanOM.
Shelby J. Comm-Paemommid en NCa0Te(Mo lembu Terminals N hied L.PfoMe ChadoderItolan unnamed
Teminal located rCM1arbre(Madknburg County)ks Me aiscnarRe of sWrmwaler Into an unnamed
?f� MIeWnIWe 1'MR:9, a oev Npulary to Paw Gcek.
mterad r•«ondclau mvlm MeC . Permit number N000 4723 to Valera MarkeBnp A Supply Company for Me Vale. Ma&e6ng A
•nd6Yatr; Matbelshe iv enhanced I. Supply Facility baled in Charlotte (Me kknpuq County) fa Me dmi,hh,r, a slamwnter into an
maremuq"al We entice or nMn L unnamed Miame, to Paw Creek,
NOTICE OF PUBLIC I " Permilnumbm NC0005771 to Tmndvuhumgne Temnnaling,lncbrMeCb.OMaPawGeekThml-
nal %1 heated M Chador. (Mecklenburg Cmnty) M Me doohnnye M slon,wat, mill, an unmoral
TO BE HELD BY THE tributary to Paw Creek.
ENVIRONMENTAL MANE - Permit number NC0021971 to TonsMdnfagne TefrNnalirg, Inc. forte ChandorePaw Geek Tema
met 12 bated M Gnarbtte (Medlenpurg Cdart i Me ink dlh,lori A slwmwater job'di Ni affmad
Inpulary to Paw Crack. -
Penal number NC0031038 to Cdonial Pipeline Company fothe Charlotte Delivery Facility located
•rueaopyefwbidt "a aWuh.dpua in Cholera (Mecklenburg County) Join the di5male of slormwater nW an unnamsl Inrurary to Gum
I.dnvEEMIPS unlbe rellowioa d+ Branch.
Nareh 16, 2001-Permll number NCOOafi213 to MaaMon Asdal Petrdeum, LLCM Me MaraMon Ashlar Pero-
mum Mdity loraka in Charlotte (Meklenble, County) for Medischarge of nexholl him an ur,
and Maaba midnewepapuim whid named tributary W Long Creek,
,
or Ii "wethemere wu pariah, ' Penal numbeg6531 r NCODto Crown Cenral Peholeurn Company to the Paw Creek Terminal
everywNpap4caliary a,tewapMar load in Paw Ge¢k(MeUlenbur9 C0unly)M Me hzMarge N Zlpmwaler into an unnamed lriWlary
andyua4P .of$.im 1-597 r t0 Gum eanah.
Grolhu wmdwu agoa4(ed aewap. - Pgmn number NCON6892 to Wai Enlegnsas, LUC kin Me Charlotte Terminal baled in Paw
film 149g'the Gemmel Smi o Creek (Woldenpurp County) for the dlsoreni of slarmwakr am, mmerided groundwater to an
Thu 16bh yyof H...... bdularylo Long Creek.
�y - Permit nurMa NCO0048391 E onMobil R fiMg A Suppry Company for he Chancre, Terminal
trimmed) —� / / clomaletlt Glarore(Wollt ing County) f. Meanichi of sloratevater and reord'all gmuname
6 MWa annual ebutary toLong Coal
Swam fierotauMmMdb a .Pe 1 trader NC00051B51 Wrlf ens term IS diflin S,LVtor aPaw Geek Teutar, to two
in Paw C ek IMedl hung Cc tyl I M disdrarpe otsldrmval W n col Mb tary W Lmp
IfiLh dam of March 20t Greek.
PURPOSE. EatlINMe fri4Oe ha pPlred for renewal ollM1er NPDES pemdtl M¢tlis,Marge
f Va(ed sb 1e and/ ed Il g! ndv2ter mbwaM m 11p Capwp Riv¢ pa 'n. On Me
bads ca and ry i s a d p4l fig n otum Me
lip C Cenc Eolf I SbW,pagw h
N 1ary 7 / 7 f.aldMa, and Papal
to n nme aNP and re fif for 5, Me Npih Contra Env rmment MpnagNtr¢nr
My Gm�'sian Bvp'ver 1l1 Commissjon prupoe¢zWi55uea NPDES permit lea raU facility sapjttllo spetlf pollutant limitatims
al sprat avgilken, The Olredw d Me RmNon W Water Gaety psrwanl b NCGS tot}215.tIcN3)
alHe.0mm, s15NGC2H,Sublic 0100ha5 r,wr, dnlMatalsbMepudic err,M Malameednp
be PROCEDURE
ncejve all perEnenl pub4c wmmenl on Wtetlier m i55ue.nvpily. «tlemr Me permit.
PROCEDURE TM hat r Quality
premium
M nhp,,,,mr al,
i. The Divlskn d Water GaNry wda present an gplanalbm ,Ache North Carolina Environment
Mragement Crmmissiy makermXtingarmmdure. -
2. The app4anl may ended¢ an erplanagon PI Me action Ip M,pda each penrll is min ame,
1, Pubkc Comment -Comments, sfakmenh, data antl oMer inlortta6on may b. subinrl in wiping
pile to o dump Me meeWa or may to, pronnted Ri at Me menial. Persons desiring to Speak will
Mdimmeohy inl^rtl atty Imrod limited
at eMemdifn;h Maifin, ponstl0.1pbspeak Met
so, krgMy ehamen; i flay be - od al Me rfiscrt. d Inc haebl allgcer. Ohl peW with
BglS tlui
eeeeed Meet mMofm shaat be amonpanil by Mree wlttm c4rves, wM1itlr will be filed wiM Oivis'wn
sUR at Me o.re aireglzbagan.
---- 4, Circle eundnallon of pempns presen8rg minimal will not be allowed, wave, Me hating
otfleef may all, p lmical loin datiiona.
S, The heanrg reo,r,rd may be domed at Me cmtla4m of Me. mail
WHEN. Apr119oall DOpm r
WHERE: Cmaddre-Med,lember, Government Cenib
600 East Kurto Sbeel, CH-14
Charlotte. North Carolina
INFOR"TIM A copy of he halt NIMES Ifii a la map showing Me Motion of Me diedrarge(s)
are .r.nable br_wiNng or all'mg',
Mz. Cf-n1 Judson
NC D,1ion d Watm QiiV1UMPDESUNt
1617 Mail Sm i[a Center -
Raleigh, NOM Carding 27699-1617
Telephone number(919) 733-5083, ri.pr,mm 53A
The applimatoes and pinel inlormavanare on file aVMeDivisiond WaMr Ou slily, 512 %In SatSbury
Speer, Room 925 0l M¢ ArtM1dde Builtling in Raleigk, MOM, CardjnaarM el Me Gvisw'S Mooresv,lle
hours Glyn -
at M -or Main Sbeel In Mmrementa NC). They May redeem mad paymdoing the he oMre
hours. cto, eat M¢ idoomm an pun file are re a r e upon made, and payment o1 M. costs col
re Permit
mumb ris such tapply, and requests regarding MI5. mare Snoultl make relerence b Me
91 AM, 16 (sl6ka adpve.
950� Mar 16 -

Permit Requirements for Discharges from Oil Ss Petroleum Storage Facilities
2001 Permitting Strategy
Background / Introduction
In 1996, the Permits and Engineering Unit reviewed NPDES permit monitoring requirements for stormwater
discharges at oil terminal facilities located in the Greensboro and Charlotte areas. This review revealed
inconsistencies in monitoring requirements that were subsequently discussed with staff of the Winston-Salem
and Mooresville regional offices. These discussions and a review of past information collected at these facilities
formed the basis for much of the standard monitoring requirements contained in this Standard Operating
Procedure (SOP) for Stormwater Discharges from Oil Terminal Facilities.
In accordance with the basinwide planning schedule, the NPDES permits for the oil terminal facilities are due for
renewal in 2001. The NPDES unit has reviewed the discharge monitoring reports (DMRs) for the facilities in
order to assess the SOP currently in place. This led to some revisions and additions to the existing procedure;
the bulk of the 1996 SOP will be carried over into the 2001 revised SOP.
This document is divided into three sections that delineate the permitting requirements for oil terminal facilities.
The first part describes the minimum requirements for all oil terminal facilities in the state — both monitoring
requirements and permit limits. The second section describes potential additional site -specific requirements that
are based upon the performance of a reasonable potential analysis for the facility. Such requirements are based
upon reported data from the Discharge Monitoring Reports (DMRs) of a given facility. The third and final section
delineates additional requirements for those facilities which discharge to receiving waters carrying a water supply
classification.
I. Minimum Requirements for ALL Oil Terminal Facilities
A. Flow
Episodic Monitoring (monitor with each discharge event)
Measurement of flow is to be representative of a discharge event. Many oil terminal facilities
have storage ponds to collect runoff and therefore, discharges may not always occur during
storm events. Flow should be monitored by one of the following methods:
1. Measure flow continuously, or
2. Calculate flow based on the area draining to the outfall, the built -upon area, and the total rainfall,
using the rational equation (see below), or
3. Estimate by flow measurement at 20 minute intervals during the entire discharge event, or
4. Base flow on pump logs.
The rational equation: Q=KuCIA, where
Q = flow (peak flow rate (cfs or m3/sec)
Ku = units conversation factor = 1.008 for U.S. standard units (usually ignored because it is so close to
1), or 0.278 for SI units
C = dimensionless runoff coefficient for the watershed, loosely defined as the ratio of runoff to rainfall
I = intensity of rainfall taken from the intensity -duration -frequency curves for the specified design
return period at the time of concentration tc, (in/h or mm/h)
tc = time of concentration - time after the beginning of rainfall excess when all portions of the drainage
basin are contributing simultaneously to flow at the outlet
A = area of tributary watershed (acres or km2)
The rational equation is used to calculate the runoff from a region, given:
➢ the runoff coefficient which accounts for infiltration and other potential losses in the region,
➢ the rainfall intensity to the region,
➢ the time it takes for runoff to travel from the region's upper reaches to its outlet, and
➢ the region's drainage area.
For oil terminal facilities with large storage ponds that serve to collect runoff, item 2 listed above and the
rational equation should not be used because the calculations will determine the flow to the storage pond,
rather than the flow from the pond.
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
B. Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual
Monitor annually (assuming first five discrete storm events have already been monitored and
showed no toxic effects)
Monitoring Footnote: acute toxicity monitoring should occur during collection of BTEX
parameters (see item E below)
Products stored at oil terminals may contain a variety of different chemicals (some of which may have
harmful or toxic effects). To verify that toxic chemicals are not discharged to surface water, a periodic
toxicity test will be required. An acute, rather than chronic, toxicity test is required because oil terminal
facility discharges are typically short-term, episodic events. Specifically, an acute 24-hour pass/fail at 90%
waste concentration using fathead minnows is the recommended toxicity test for stormwater discharges.
Facilities that meet one or more of the following criteria will not qualify for annual monitoring and will
be required to monitor for acute toxicity during five storm events:
1. Facilities that have never monitored for acute toxicity during a storm event, or
2. Facilities that monitored for acute toxicity during four or fewer storm events during the last
permit period, or
3. Facilities that completed five acute toxicity tests during five storm events, but did not pass all
five tests.
Facilities that fail an acute toxicity test conducted during one or more of the five storm events or during an
annual monitoring event will be required to conduct quarterly monitoring for the forthcoming permit period,
and must receive State approval for reduced monitoring. For facilities that have not yet conducted acute
toxicity testing for the first five discrete storm events, a statement in the permits will allow for additional
toxicant limits should the toxicity test indicate toxic effects. At the time of permit renewal, only annual
monitoring for toxicity would be required if the facility has performed the five discrete sampling
requirements with no acute toxicity.
C. Total Suspended Solids
Monitor monthly
Daily maximum 45.0 mg/1
Historically, Total Suspended Solids (TSS) has not been a significant problem in stormwater discharges at
oil terminal facilities. A 1996 analysis of TSS data from five stormwater discharges indicated only one event
in excess of the previously permitted 30.0 mg/1 monthly average. A daily maximum limit of 45 mg/L is
recommended as a general indicator of stormwater quality. A daily maximum compliance period is given to
reflect the sporadic nature of these discharges. Should TSS monitoring data indicate any substantial
problems, the Regional Office or county may elect to enforce the instream standard for turbidity.
D. Oil and Grease
Monitor monthly - No Limit
Monitoring Footnote: Where possible, the grab sample for oil and grease should be skimmed from
the water surface of a quiescent (calm water) zone.
Historically, oil and grease has not been a significant problem in stormwater discharges at oil terminal
facilities. However, like TSS, oil and grease is a good general indicator of the quality of a stormwater
coming from a site. Where possible, oil and grease samples should be skimmed from the surface of a
quiescent zone closest to the discharge.
E. BTEX
Monitor monthly — No Limit
Benzene, toluene, ethylbenzene and xylene are toxicants commonly found in petroleum. The previous
permitting strategy for the oil terminals required the EPA 624/625 scan, which, among other contaminants
of concern (see Part I1), detects BTEX compounds. A review of the discharge monitoring report data from
the previous permitting cycle indicates that these four contaminants frequently appear in stormwater from
terminal facilities. For the most part, the other volatiles and semi-volatiles detectable by the EPA 624/625
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Permit Requirements for Discharges from Oil Ss Petroleum Storage Facilities
scan were never detected in the stormwater from these facilities. By monitoring for BTEX and naphthalene
(see part F, below), the facilities are collecting data on those pollutants that are mostly likely to be present
in the water.
F. EPA Method 625
Monitor semi-annually
The intent of this monitoring requirement is to monitor for naphthalene and other indicators of middle
distillate compounds detectable by Method 625. These contaminants are commonly found in heavy
fuels, such as diesel. During site visits of terminal facilities performed by members of the NPDES Unit,
it was observed that the majority of the terminals reserve at least one storage tank for diesel fuel.
Originally, facilities were to have monitored only for naphthalene, but since the most accurate method
of quantifying naphthalene is through Method 625 and other middle distillate compounds can be
detected through this scan, the entire results should be reported to the Division.
If it can be demonstrated by the permittee that diesel fuel is not currently being stored on site, then the
monitoring requirement on the effluent page will have the following footnote:
"Monitoring requirement applies only for facilities storing diesel or other heavy fuels on site."
G. Tank Solids, Tank Bottom Water, and Rag Layer
No direct discharge of tank solids, tank bottom water, or the rag layer is permitted.
There are typically four discrete layers of varying thickness within a storage tank. At the very bottom of the
tank is the solids layer that achieves a 1/2-1 inch thickness over a 5-6 year period. Immediately above the
solids layer is 1-6 inches of tank bottom water that results from rainwater breaching the wall seal in open
roof tanks. Open roof tanks are not completely open, but have a roof floating directly on the product.
There is a seal between the tank walls and floating roof designed to prevent water from entering the tank.
Water breaching this seal and entering the tank is referred to as tank bottom water. The rag layer is at
most 3/4 inch thick and forms the interface between the tank bottom water and the product. The product
is the topmost layer and is 20-25 feet. Normally, the tank bottom water is removed from the tank when it
is 3-4 inches deep. The mixture of water and product in the rag layer is often drawn off when tank water is
removed because water entering tanker trucks must be minimized. As a result of potentially high levels of
organic compounds in the three bottom layers of storage tanks, they are not to be discharged, but instead
should be transported off -site for appropriate treatment and/or disposal or treated/recovered onsite if
treatment technology capabilities occur onsite.
H. Hydrostatic Testing
Hydrostatic testing of oil tanks normally occurs once every five to six years. Prior to the hydrostatic testing,
the tank is completely drained and tank bottom materials are handled as described in the previous section.
The tanks are completely cleaned and then coated and welded (if necessary). The tank is then filled with
water for the hydrostatic test. Some oil terminal facilities use stream or lake water to hydrostatic test their
tanks, while others use potable city water. Because the tank is thoroughly cleaned prior to refilling with
water for the hydrostatic test, water discharged from the tank following the hydrostatic test should be fairly
clean. However, tank discharges following hydrostatic testing may contain contamination. Therefore,
monitoring of the tank water prior to direct discharge will be required. There shall be no direct discharge
from oil terminal facilities following hydrostatic testing if concentrations of benzene and/or toluene are
greater than their respective water quality standards (see effluent pages at end of SOP for details).
I. MTBE Monitoring
Monitor monthly
Within the last year, the Environmental Protection Agency has recommended banning methyl tertiary butyl
ether (MTBE), an ingredient commonly used in gasoline to aid in the reduction of air pollution. MTBE was
originally added to gasoline in response to a 1990 law that required higher oxygen content in gas sold in the
most -polluted cities. It has since become a cause for concern since the EPA now believes that MTBE may
be a carcinogen and is seeking to outlaw the compound.
Since MTBE contamination of water is a public health concern, monthly MTBE monitoring will be added to
all facilities. For those facilities currently monitoring for MTBE, reasonable potential analysis will be
performed to assess the need for an MTBE limit. In non -water supply waters, the instream MTBE standard
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
is 2393 µg/L, and is unlikely to be violated. All facilities discharging to water supply waters will have a
special condition added to the permit that pertains to MTBE monitoring and source reduction (see Part
III.C.)
II. Additional Site -Specific Requirements
A. EPA Method 624
Monitor semi-annually
The entire 624/625 scan was originally included in the SOP to assess which of the petroleum -associated
organic chemicals are found in stormwater. These tests scan for volatile and semi -volatile organics and
cost approximately $700 to run (Ray Kelling, personal communication 2/ 14/01). Currently, the oil
terminal facilities are performing the scan twice a year. Most facilities obtain results consisting entirely of
non -detects, but a few have detected one or more of the compounds on the 624/625 list. Tables 1 and 2
summarize the compounds included in the scans and note those parameters detected during the last
permitting cycle.
After a review of the data and discussions with different members of the Division of Water Quality Point
Source Branch, it has been decided to assign semi-annual monitoring using EPA Method 624 to any of the
facilities that detected any compound listed in Table 1 that is not benzene, toluene, ethylbenzene, xylene or
naphthalene (as these were found in most discharges and are covered by monitoring requirements listed
above).
Table 1. Compounds detectable by EPA Method 624
Acrolein
r .r r
Acrylonitrile
Benzene
✓
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane
✓
Dibromochloromethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
trans-1,2-Dichloroethene
1,2-Dichloro ro ane
cis- 1,3-Dichlororo ene
trans- 1,3-Dichloro ro ene
Eth 1 benzene
J
Methylene chloride
J
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
J
1, 1, 1 -Trichloroethene
1,1,2-Trichloroethene
Trichloroethane
Trichlorofluoromethane
J
Vinyl chloride
J
Page 4 of 8
Version 7/30/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
Table 2. Compounds detectable by EPA Method 625
PARAMETER
Acena hthene
DETECTED IN OIL TERMINAL .-
Acena hth lene
Anthracene
Benzo a anthracene
Benzo b fluoranthene
Benzo k fluoranthene
Benzo a ene
Benzo(ghfterylene
Benzyl butyl phthalate
Bis 2-chloroeth 1 ether
Bis 2-chloroetho methane
Bis 2-eth lh 1)phthalate
Bis 2-chloroiso ro 1 ether
4-Bromophenyl phenyl
ether
2-Chlorona hthalele
4-Chlorophenyl phenyl
ether
Chrysene
Dibenzo a,h anthracene
Di-n-bu 1 hthalate
1,3-Dichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
3, 3'-Dichlorobenzidine
Diethyl phthalate
Dimeth 1 phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octylphthalate
✓
Fluoranthene
Fluorene
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Indeno 1,2,3-cd ene
Iso horone
Naphthalene
✓
Nitrobenzene
N-Nitrowdi-n-propylamine
PCBs
Phenanthrene
✓
Pyrene
Toxa hene
1,2,4-Trichlorobenzene
4-Chloro-3-meth 1 henol
2-Chloro henol
2,4-Dichloro henol
2,4-Dimeth 1 henol
2,4-Dinitro henol
2-Meth 1-4,6-dinitro henol
2-Nitrophenol
4-Nitrophenol
Pentachloro henol
Phenol
J
2,4,6-Trichloro henol
Page 5 of 8
Version 7130101

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
B. Reasonable Potential (General)
The reasonable potential procedure is a method used to determine the potential of a discharge to violate a
water quality standard for a given parameter based on existing data. If a parameter is determined to have
reasonable potential to violate a water quality standard, a limit and monthly monitoring will be required. A
parameter is determined to have reasonable potential to violate a water quality standard if a calculated
maximum predicted effluent concentration is greater than the allowable effluent concentration.
Reasonable potential is determined by performing a statistical analysis for each parameter of concern that
has either a state or federal water quality standard. For each parameter, the statistical analysis works best
with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more
accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent
concentration based on the existing data set. A step-by-step procedure for determining whether or not a
parameter should be limited based on reasonable potential determination follows:
STEP
1. Determine the number of sample points (n)
2. Determine highest value from data set. Best professional judgment should be used by the reviewer so
as not to use an outlier. Since an outlier will not be determined statistically, maximum values should
rarely be discarded in this analysis.
3. Determine the coefficient of variation (CV = STD DEV/MEAN)
4. Determine the appropriate multiplication factor to be used by comparing the number of samples versus
the co -efficient of variation (see Table 3-1)
5. Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to
obtain the maximum predicted effluent concentration.
6. Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable
effluent concentration, which is based on instream dilution and the corresponding water quality
standard. EPA recommends that permitting authorities find reasonable potential when the maximum
predicted effluent concentration is greater than the allowable effluent concentration.
A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet" and is
located on the NPDES server. The spreadsheet requires the input of the facility name and permit number,
the waste flow (Qw), 7Q 10 flow, pollutant name, state or federal water quality standard, and the DMR data
points with appropriate units. The spreadsheet then computes the standard deviation, mean, and
coefficient of variation for the entered data points. The coefficient of variation is then used along with n
(the number of data points entered in the spreadsheet) to determine the Multiplication Factor. This
Multiplication Factor is entered into the Toxicant Spreadsheet to calculate the maximum predicted
concentration.
If the maximum predicted effluent concentration is greater than or equal to the allowable effluent
concentration, (or in other words, if there is reasonable potential for a water quality standard violation), the
parameter should be limited (as a daily maximum) and monitored on a monthly basis. The daily maximum
limit shall be equal to the standard for that parameter multiplied by the dilution of the receiving stream
under summer 7Q10 conditions for non -carcinogens. Average flow should be used for carcinogens and
30Q2 flow should be used for aesthetic standards.
If a facility monitors semi-annually (twice/year), 10 data points would be obtained over a five-year permit
period which is slightly more than the minimum number of data points which will accurately characterize
an effluent discharge (USEPA March 1991).
In cases where a facility requests reconsideration of a limit requirement, monthly monitoring should be
required for at least 10 months so that 10 data points can be obtained and a second reasonable potential
calculation can be conducted. If there is no reasonable potential for a water quality violation, monitoring
should be reduced (to semi-annually).
Page 6 of 8
Version 7130/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. Turbidity Monitoring (Paw Creek terminals)
Monitor quarterly
(Monthly monitoring and limit of 50 NTU if facility demonstrates reasonable potential)
Based on concerns regarding anti -backsliding, the EPA requested the Division re-examine the basis for the
elimination of turbidity monitoring for 12 of the 14 Paw Creek oil terminals that were required to monitor
for turbidity prior to the most recent permit renewal. This second examination of the data showed that
there were turbidity standard violations since the last analysis at several of the oil terminals. The Division
therefore acknowledges that its second evaluation resulted in a different outcome from the initial
investigation and agrees that turbidity monitoring should be added to the discharge permits for the oil
terminals in Paw Creek. Facilities were sent notice in February 1999 that quarterly turbidity monitoring
would be required at the facility effective March 1, 1999. If sufficient data exist, then reasonable
potential should be performed to assess the need for more frequent monitoring and a limit of SO
NTU. For all facilities, the following footnote will be placed on the effluent limits page:
*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.
III. Additional Monitoring Requirements for Water Supply (WS) Waters
A. Phenol
Monitor monthly
(Limit assigned if reasonable potential is demonstrated)
Phenol is a common component of petroleum compounds stored in terminals, can result in tainting of fish
tissue, and can cause taste and odor (organoleptic) problems in drinking water. In addition, phenol
discharged from terminals could combine with chlorine in water treatment facilities to form chlorinated
phenols. Limiting the discharge of phenol into water supply classified waterbodies could reduce
chlorinated phenol formation and their concentration in drinking water. As a result of the expected
occurrence of phenol in oil terminal facility discharges and the possibility of chlorinated phenol formation,
phenol will be monitored on a monthly basis in water supply classified waters.
Based on an extensive review and analysis of data collected during the last permitting cycle, the facilities
are no longer required to monitor for chlorinated phenols, since none were ever detected in oil terminal
effluent. The concern over limiting phenols lies in the need to inhibit formation of chlorinated phenolic
compounds at downstream water treatment plants. Joe Corporon of the NPDES Unit calculated an
allowable phenolic loading for each terminal in Mecklenburg County that will prevent a downstream
violation of the NC State standard for phenols of I µg/L. Meg Kerr wrote a similar memo for those
terminals in Guilford County in 1983. Reasonable potential will be performed using these allowable
phenolic loadings (see attached memo).
B. Benzene
Monitor monthly
Daily maximum limit - 1.19 µg/1 * dilution of the receiving stream under average flow conditions
Benzene is a known carcinogen and can pose a potential health risk to humans consuming water with
benzene. The water quality standard for benzene in waters classified as water supplies is 1.19 µg/1. The
daily maximum limit for these facilities is therefore 1.19 multiplied by the dilution of the receiving stream
under average flow conditions (rounded to two significant digits). This limit may be excluded from the
permit only if there are sufficient data (eight sampling events) to demonstrate "no reasonable potential." If
there is no reasonable potential, there will only be a monthly monitoring requirement.
Page 7 of 8
Version 7/30/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. MTBE
Monitor monthly
MTBE special condition
Given that this compound is considered a possible carcinogen, there should be a greater effort to keep high
levels of MTBE out of water supply waters. As per the Paw Creek Hearing Officer's Report, after one year of
monthly MTBE samples have been recorded, the facility must review the MTBE data. If no MTBE has been
detected in the effluent samples, the facility may request a minor modification to the permit reducing the
frequency of MTBE monitoring. If, however, MTBE has been detected during any of the discharge events,
the Permittee must develop a plan of action to reduce the levels of MTBE entering the receiving stream.
It is anticipated that an MTBE criterion for surface waters will be established at the time of the next permit
renewal. At that time, sufficient data will be available to assess the reasonable potential for a facility to
exceed any such standard or criterion.
REFERENCES
Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering
News.
Kelling, Ray, (Division of Water Quality Chemistry Lab). June 1996. Conversations with P. Clark.
Kelling, Ray, (Division of Water Quality Chemistry Lab). February 2001. Conversations with N. Sierra.
Linville, Ron, (Winston-Salem Regional Office). March 1996. Telephone conversation with P. Clark.
Reid, Dianne, (Division of Water Quality - Planning Branch). June 1996. Conversations with P. Clark.
Shiver, Rick, (Wilmington Regional Office). July 2001. Findings and Recommendations for Public Hearing
Held on April 19, 2001.
USEPA. March 1991. Technical Support Document For Water Quality -Based Toxics Control. EPA/505/2-
90-001.
Page 8 of 8
Version 7/30/01

DIVISION OF WATER QUALITY
April 5, 2001
MEMORANDUM
TO: Dave Goodrich r
FROM: D. Rex Gleason
PREPARED BY: Richard BridgemanW
SUBJECT: Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
9
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It is recommended that the effluent sample location be specified in all the permits.
Circumstances at one facility (at least) can be cited as justification for the
recommendation. The permit description of the water pollution control system (WPCS)
for Colonial Pipeline Co. (NC0031038) includes a retention pond. This pond is also
mentioned in the Fact Sheet. Regardless of the 7Q10, 30Q2, and average flow data, this
pond is actually an impoundment fed by three UT's to Gum Branch. According to the
terminal manager, there is flow in these UT's to Gum Branch 12 months per year. The
effluent from the CITGO (NC0021962) facility is discharged to one of the UT's.
Stormwater runoff from at least one other temvnal site may also enter the impoundment.
Effluent samples are collected at the outfall for the impoundment.
As discussed above, in addition to the sample collection location, the Colonial Pipeline
Co. (NC0031038) permit needs to be reviewed to determine if it is appropriate to include
the impoundment of a UT to Gum Branch as a treatment unit (retention pond).
Consistency is needed in specifying source of wastewater to WPCS.
There are four different methods used in the draft permits, as follows:
- Source not specified anywhere.
- Source indicated in the paragraph on the Supplement to Permit Cover Sheet,
which describes the WPCS and/or specifies outfall.
- Source indicated in the paragraph on the Supplement to Permit Cover Sheet that
specifies receiving water.
- Source indicated in Part I, Section A(1) of permit (Effluent Limitations and
Monitoring Requirements Sheet).
The writer's preference, in part because several of the facilities have multiple outfalls, is
to indicate sources on both the Supplement to Permit Cover Sheet (in paragraph which
describes the WPCS and/or outfall) and in Part I, Section A(1). An example of the
writer's preference is in the permit for Motiva Enterprises, LLC (NC0046892).

Dave Goodrich
Page Two
April 5, 2001
Flow measurement/reporting frequency is recommended to be episodic (as in permit
Motiva Enterprises, LLC (NC0022187).
For several design reasons, discharge events basically occur on an as -needed basis; a
decision is usually made when there will be a discharge through an outfall. The only
exception may be Outfall 002 included in the permit for ExxonMobil Refining and
Supply (NC0004839), which is for a groundwater remediation system without any flow
retention capability, and, therefore, subject to daily discharges. Since discharge events
are mostly manually precipitated and occur randomly or as -needed, the range of the flow
data at a facility may vary considerably. Flow data seems to have played a large role in
the development of effluent limits (as in reasonable potential analysis for phenols), and
yet historically flow measurement methods and data have been two of the evaluations of
a compliance inspection subject to much scrutiny and criticism. Given the flow
measurement options specified in the permits, the small number of discharge events
probable each month, the importance of flow data, and the possibility of a wide range in
the flow data, it is not unreasonable to expect flow to be measured and reported for each
flow event.
The Turbidity monitoring requirement does not seem to be complete.
The permits, with two exceptions (discussed under the next item), include either a
quarterly monitoring -only requirement or a monthly monitoring requirement with an
effluent limit. It is not understood how the effluent turbidity monitoring requirement
correlates with the relevant footnote in Part I, Section A(1). Should there not also be an
upstream and downstream monitoring requirement. In fact, those facilities with a
monitoring -only requirement need only conduct stream monitoring to determine if
effluent turbidity levels result in stream standard violations.
One of the exceptions mentioned above under the item for Turbidity Monitoring is
Marathon Ashland Petroleum, LLC (NC0046213). Although the perrrrit cover letter
indicates that the permit includes a monthly monitoring requirement and an effluent limit,
Part I, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring -only
requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is
being required because of the near potential for a stream standard violation. The other
exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being
required because none of the previously required monitoring has been conducted.
Philips Pipe Line Company (NC0032891) — Phenol limit in the other permits is expressed
in mg/L. In the Philips permit, it is expressed in ug/L.
ExxonMobil Refining and Supply (NC0004839) — Benzene limit is indicated to be 1.2
ug/L; should it not be 1.19 ug/L?

Dave Goodrich
Page Three
April 5, 2001
Phenol limit development.
The cover letters for four of the six permits with a Phenol limit discuss development of
the limit. In the cover letter, the water quality standard for phenol is indicated to be 1
mg/L; it is actually 1 ug/L for WS waters. The writer is not familiar with the 2001 SOP
used to develop limits for phenol, but considering the fact that five of the six facilities
discharge to streams having a 7Q10, 30Q2, and average stream flow of zero, and the sixth
facility discharges to a stream having a 7Q10 and 30Q2 flow of zero and an average flow
of <l, it is hard to understand the assigned limits. The 3 mg/L Phenol limit for Outfall
002 in the ExxonMobil (NC0004839) permit is almost unimaginable.
Motiva Enterprises, LLC (NC0022187) — The Fact Sheet indicates that there is a
reasonable potential for the stream standard for Lead to be violated, but indicates that no
limit will be assigned because lead is an action level pollutant. A change? If not, should
there be a Lead limit in permit?
TransMontaigne Terminaling, Inc. (NC0021971) — Permit Cover Sheet indicates that
discharge is to Paw Creek. As indicated elsewhere in permit, discharge is to a UT to Paw
Creek.
Williams Terminals Holdings, L.P. (NC0074705) —The permit description includes an
oil/water separator, a carbon filter, and a holding tank. The Fact Sheet indicates that
wastewater and stormwater are routed to a retention pond and released as needed. No
staff report or compliance inspection report mentions this retention pond. MCDEP staff
has confirmed that there is no retention pond at the site.
Valero Marketing & Supply Co. (NC0004723) — Please review discussion in Fact Sheet
concerning the assignment of a Turbidity limit. If the average turbidity value in the past
1.5 years is 7.2 NTU and the maximum 28 NTU, why is there a prediction of a maximum
of 110.3 NTU?
Williams Energy Ventures (NC0005185) — Permit Cover Sheet indicates that discharge is
to a UT to Gum Branch; as correctly identified on the Supplement Sheet, it is a UT to
Long Creek.
Motiva Enterprises, LLC (NC0046892) — Fact Sheet indicates that the Flow requirement
for Outfall 002 in the previous permit will remain unchanged. There was a Flow limit in
the old permit, but not in the draft permit. The writer does not recommend a limit.
Please advise if you have questions or comments.

MECKLENBURG COUNTY
Department of Environmental Protection
April 17, 2001
Mr. Dave Goodrich
NCDENR - DWQ - NPDES Unit
1621 Mail Service Center
Raleigh, NC 27699-1617
Subject: Paw Creek Petroleum Terminal NPDES Permit Renewals
Dear Mr. Goodrich:
RECEIVED
WATFa"141 lry.gFrnON
APR 1 U Hr.�1
Nor> -Discharge Permitting
The Mecklenburg County Department of Environmental Protection (MCDEP) has reviewed the
subject draft permits. As you know. MCDEP has a Memorandum of Agreement with the
Division of Water Quality to conduct inspections of the Paw Creek terminals in order to
determine compliance with the applicable NPDES permits. We offer the following comments
regarding the permits:
Genera/
Flow Measurement
The flow measurement method by which facilities are allowed to calculate flow based on
the area draining to the outfall, the built -upon area, and total rainfall using the rational
equation is inaccurate in most cases. Most facilities inspected by MCDEP collect
stormwater in earthen secondary containment basins surrounding the above ground
storage tanks (not ponds). The facilities generally hold the stormwater for as long as
possible (several weeks if weather permits) to allow any suspended solids to settle out
and to avoid discharge if possible so that monthly sampling and laboratory analysis does
not have to be performed. Calculating discharge flow by this method is inaccurate
because it does not account for evaporation and ground infiltration during the holding
period.
Quarterly Turbidity Monitoring
The permits state that "Effluent turbidity shall not cause the receiving stream turbidity to
exceed 50 NTU. If receiving stream background turbidity exceeds 50 NTU, effluent shall
not cause this background value to increase."
PEOPLE • PRIDE • PROGRESS
700 N. Tryon Street • Suite 205 • Charlotte, NC 28202-2236 • [phone] • Fax [phone]

Mr. Dave Goodrich
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 2
The permits require quarterly turbidity monitoring at the effluent. The permits do not
require upstream or downstream monitoring for turbidity. Without instream monitoring
requirements, compliance cannot be determined.
Individual Facility Comments
Williams Terminals Holdings, L.P. - Permit # NC0074705
An error was noted on the fact sheet for this facility. The background section refers to a
detention pond which is used to hold wastewater prior to discharge. MCDEP has
determined that the treatment works for this facility do not include a deten ' n pond.
Exxon Mobil Refining and Supply Company - Permit # NC0004839
Outfall 001-
The daily maximum permit limit for benzene is listed as 1.2µg/I. The North Carolina
water quality standard for WS-IV waters is 1.19pg/l.
Marathon Ashland Petroleum, LLC - Permit # NC0046213
The last footnote on the Effluent Limitations and Monitoring Requirements
page of the permit states, "There shall be no direct discharge of tank (or pipe) contents
following hydrostatic testing unless benzene concentration is less than 71.4µg/l and
toluene concentration is less than 1 lµg/1." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19ug/l.
Colonial Pipeline Company - Permit # NC0031038
MCDEPs past inspections of this facility indicate that the retention pond located on -site
receives flow from three intermittent streams. While the streams are classified as
intermittent by USGS, terminal personnel have indicated that the streams have perennial
flow. In addition, stormwater discharges from the Citgo facility (NC0021962) and Crown
Central Petroleum Corporation (NC0046531) flow to Colonials' retention pond before
entering the receiving stream. Since these conditions exists prior to the outfall location
(sampling point), MCDEP has concerns that these influences may constitute dilution of
the waste stream and effluent analysis may not be totally representative of the facility's
wastewater characteristics. In addition, Colonial could potentially be liable for impacts
from off -site sources.

Mr. Dave Goodrich
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 3
If you have any questions regarding these comments, or any other matters, please feel free to give
me a call at 704/336-5500. Thank you.
C1nrpr.IV
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP

Sent By: ;
919 821 0337; May-2-01 16:32; Page 2/3
%l LAM IL WENTITERSPOON
s>rcwv mm
May 2, 2001
NORTH CAROLINA
PETROLEUM
COUNCIL
A tlWfefen of dw Amalam Pkaoieum kutlti,
SUrrE 2850 • 150 PAYE1'18VILIE Sr. MALL
NAMOn. NC 27601
OIOf8Z8-6498 • CAX OIOJH21b147
Mr. Rick Shiver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Ext.
Wilmington, NC 28405-3845
Re: NPDES Permit Renewals
Paw Creek Petroleum Pipeline and Distribution Terminals
Charlotte (Meoklenburg County), North Carolina
Dear Mr. Shiver:
Thank you for the professional marmer in which the public hearing on the petroleum terminals'
NPDES permits was conducted in Charlotte on April 19, 2001.
The purpose of this letter - which 1 request be included in the official hearing record - is to
express my members' strong concern about the way MTBE is being addressed in the terminals'
draft permits.
The North Carolina Petrolown Council - a division of the American Petroleum Institute, the
trade association for the nation's major fuel suppliers - is committed to insure that the
opportunity for public hearings and comment is an integral part of government decision -making -
So we simultaneously praise the process that allows us to submit this statement for the record,
while we point with alarm to the proposed MTBE limit of 11.6 ug/L that has been included in the
draft permits without a single hearing or any official review by a rulemaking body.
We asked the Department (DENR) to help us understand how this limit came about. We were
told that there is no surface -water standard for MTBE. Further, we were advised that the
proposed MTBE limit has not been endorsed by the Environmental Management Commission -
has not been debated by those publicly appointed members - has not been the subject of public
hearings at all. In fact, the EMC recently dealt with the matter of MTBE and voted not only to
reject a request for a temporary groundwater standard of 70 ppb, but also to reaffirm the value of
public hearings by calling for a permanent rulemaking process to tighten the MTBE groundwater
%%M dw& So as we ski await tits: Vvas� pov *& on that wovos&L we an now confronted with

Sent By: ; 919 821 0337; May-2-01 16:32; Page 3/3
Mr. Rick Shiver
May 2, 2001
Page 2
draft NPDES permits that attempt to install an MTBE limit that is at best controversial and at
worst a circumvention of the EMC.
It is my understanding that MTBE was not an issue for the Department in the NPDES permits
issued five years ago.
To be sure, in the intervening years it has been an issue of increasing attention, study, debate and
speculation. Apparently some individuals have been so moved by the growing debate that hasty
changes in risk calculations and other values have occurred. A few advocates within the
Department who sounded the alarm so vigorously in statements to the EMC in support of an
MTBF groundwater standard of 70 ppb have now changed their minds! What had been a
certainty one month was abandoned the next in favor of a new calculation — and a new limit
level. So, if public health considerations are truly moving this fast, if numbers are hastily
abandoned and recalculated, if the science is in such a state of flux, then our commitment to
reasoned public input is all the more appropriate and needed to insure that the calculations of
today are not abandoned tomorrow.
The Council's members accept that an MTBE limit that has been peer -reviewed and duly
considered via the rulemaking process may be appropriate for inclusion in the terminals' NPDES
permits. Lacking that, however, the Council believes the MTBE limits contained in the draft
permits should be removed.
Importantly, the Council's members with facilities in Charlotte are willing to help the
Department collect MTBE data by monitoring for it on a periodic basis. But the proposed
monthly monitoring requirement is excessive. We are confident that semi-annual monitoring by
each of the terminals will provide the needed representative data to form the basis for future
decision -making.
Sincerely,
a;.41 t �
William H. Weatherspoon
WHW/jm
c: Ms. Natalie Sierra

SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS
CONTAMINANT
CAS #
"C" & "B" WATERS
(ug/I unless noted
otherwise)
"WS-11, - "WS-V"
WATERS
WATERS (ugrl unless
noted otherwise)
SOURCE OF STANDARD
OR CRITERIA
BENZENE
71-43-2
71.4
1.19
71.4
15A NCAC 2B .0211-.0222
n-BUTYL BENZENE
104-51-8
36
36
36
ECOTOX4/98
sec -BUTYL BENZENE
135-98-8
41
41
41
ECOTOX4/98
CHLOROFORM
67-66-3
470
5.7
470
EPA4/22/99
ETHYL BENZENE
100-41-4
383
524
130
ECOTOX 1101
IPE
108-20-3
19 mg/L
19
330 mg/I
ECOTOX 1/01
ISOPROPYL BENZENE
98-82-8
316
186
4.6 mg/I
ECOTOX 1/01
p-ISOPROPYL BENZENE
99-87-6
325
325
1.1 mg/I
ECOTOX
METHYLENE CHLORIDE
75-09-2
1600
4.7
1600
EPA4/22/99
MTBE
1634-04-4
2393
11.6
2393
NC DHHS 7/11/00
NAPHTHALENE
91-20-3
105
43
64
ECOTOX 1/01
n-PROPYL BENZENE
103-65-11
77.5
77.5
190
ECOTOX 1/01
1,2,4-TRIMETHYLBENZENE
95-63-6
386
72
218
ECOTOX 1/01
1,3,5-TRIMETHYLBENZENE
108-67-8
626
100
215
ECOTOX 1/01
TOLUENE
108-88-3
11 (0.36 Tr)
11 (0.36 Tr)
185
15A NCAC 2B .0211-
.0222/ECOTOX 8199(SW)`
XYLENE, TOTAL
1330-20-7
88.5
88.5
370
ECOTOX 1/01
Criteria which have a source of EPA ECOTOX were developed using EPA's ECOTOX database per 15A NCAC 2B .0208.
Last update 2/2/01 (DMR) These concentrations are updated regularly.
Questions or criteria for other parameters not found in the 15A NCAC 2B .0200s can be addressed to Dianne Reid at
919.733.5083 extension 568 ([e-mail]) OR Jason Wynn ext. 351 ([e-mail])

TransMontaigne Permit NCO021971 Paw Creek #2
Subject: TransMontaigne Permit NCO021971 Paw Creek #2
Date: Mon, 16 Apr 2001 13:43:15 -0400
From: [e-mail]
To: [e-mail]
CC: [e-mail]
Dear Natalie,
The address shown on the above referenced draft NPDES permit is incorrect. Please
change the address to read:
7401 Old Mount Holly Road
Also TransMontaigne purchased this facility from Louis Dreyfus Energy in October,
1998, not April, 1999. Please correct the date in the Background information
section on the Fact Sheet for this permit.
If you have any questions, please call me at 770/518-3671.
Thank you.
Barbara Castleberry
TransMontaigne
Confidentiality: The information contained in this electronic mail message
and any attachments is intended only for the use of the individual or entity
to whom it is addressed and may contain legally privileged, confidential
information or work product. If the reader of this message is not the
intended recipient, you are hereby notified that any use, dissemination,
distribution, or forwarding of this email message is strictly prohibited. If
you have received this message in error, please notify me by email reply and
delete the original message from your system.
1 of 1 4/16/01 3:04 PM

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0021971
Facility Information
Applicant/FacilityName:
— I ransmontaigne I ermma mg nc. aw ree
Applicant ress:
Ms. Barbara Castleberry; 200 MansellCourt, Suite oswe ,
Facility ress:Mount
HollyRoad; Charlotte, NC 28214
e nitted Flow
009 is not limited
ype ot Waste:
Stormwater, loading rack water
Facility/PermitStatus:Active;
Renewal
County:
Mecklenburg
Miscellaneous
Receiving treami
UT to Paw Creek
Regionalice:
ooreso i le
Stream ass[ [cation:
C
State rt ua
ountam
Island Lake
iste
o
etmit nter.
Natalie terra
u asin:
-
ate:312/01
Drainage Area (mi ):
0.3
Lat. 360 16' 37" N Long. 800 56'06" W
c s
SummWinter
inter c s :
cs
Average Flow c s :
o :
o
BACKGROUND
tfifi s faciity is one of two in the Paw Creek area owned by Transmontaigne Terminaling, Inc. The
facility was purchased from Louis Dreyfus Energy in April 1999. Effluent water discharged from the outfall
consists of runoff from the loading rack and stormwater from the secondary containment areas (around the
individual tanks). Loading rack water is run through an oil water separator. This water then flows into
containment basins (where it combines with stormwater) and is released from these basins manually as
needed.
FILE REVIEW
Correspondence
Correspondence files from 1998-2000 were reviewed. During this time period, the Mecklenburg
County Department of Environmental Protection (MCDEP) performed three inspections (one per year). The
facility has largely been in compliance during these inspections. In May 1999, shortly after the ownership
transfer, the facility received a marginal rating in two categories of the compliance inspection: flow
measurements and self -monitoring program. Flow was being measured improperly and the facility had failed
to report the monitoring of EPA Methods 624/625 two times. It would appear that any similar problems have
since been resolved given that the facility received a satisfactory rating from MCDEP on its July 2000.
Grab samples taken during the MCDEP compliance inspections indicate low levels of total suspended
solids (TSS) and non -detects for the volatiles and semi-volatiles detectable by the EPA 624/625 scan. No
NOVs were found in the file.
DMR Review:
DMRs were reviewed from January 1997 through January 2001. Discharges from 009 are sporadic in
nature; the mean flow for those months in which there was discharge was 0.219 MGD. The maximum flow
(used below in the reasonable potential calculations) was 0.548 MGD. Total suspended solids during this time
averaged 21.9 mg/L with a maximum of 326 mg/L. The average oil and grease concentration was 1.56 mg/L
with a maximum concentration of 10.5 mg/L.
The twice annual EPA 624/625 scan revealed non -detects for all the semi-volatiles and volatiles tested.
The facility is currently required to test monthly for benzene, toluene, ethyl benzene and xylene — for the entire
permitting cycle, there were five or fewer detects of each. The facility has passed its acute toxicity test since
1997.
Fact Sheet
NPDES NCO021971
Renewal
Page 1

Since March 1999, the facility has been required to sample for turbidity quarterly as per an EPA
ce th directive. They have sampled during each discharge event sine requirement was instilled — the average
turbidity value in the past year and a half is 12.39 NTU and the maximum was 28.2 NTU.
Reasonable Potential Analysis:
Reasonable Potential Analysis was run for benzene, xylene, toluene, ethyl benzene and turbidity. With
few detects for the BTEX contaminants, not one of these four demonstrated reasonable potential for effluent
contamination. The reasonable potential analysis for turbidity, however, predicted a maximum effluent
turbidity of 92.2 NTU, which is above the state standard of 50 NTU.
PERMITTING STRATEGY
The permitting strategy for this and all oil terminals in the state is based upon a 2001 NPDES
document entitled, "Permit Requirements for Discharges from Oil and Petroleum Storage Facilities." This
document is based upon a 1996 SOP and has been updated after a data review and internal discussions. It
delineates monitoring frequencies and permitting limits for contaminants commonly found at these sites.
Below, it is referred to as the "2001 SOP."
Waste Load Allocation (WLA).
The last waste load allocation was performed in 1994. The facility was not only under different
ownership, but also discharging from eight separate outfalls. This WLA indicates that the region requested
that benzene and toluene limits be assigned the permit. It also expresses concern over historical turbidity
problems on the site.
Oil Terminal SOP:
The flow, toxicity, TSS, and oil and grease requirements specified in the previous permit and the 2001
SOP (Parts I.A. — I.D.) remain unchanged. The previous permit limited benzene to 71.4 µg/L, toluene to 11.0
µg/l, and ethyl benzene to 325.0 µg/L. The facility has since adequately demonstrated that these parameters
are not a cause for concern. These limits will therefore be removed but the facility will still be required to
monitor monthly for the BTEX parameters as per Part I.E. of the SOP. Since the DMRs indicated non -detects
in the reporting of EPA Methods 624/625, this requirement will be removed as per Part II.A. of the SOP.
Naphthalene and MTBE monthly monitoring will be added to the permit as per Parts IX and I.I of the 2001
SOP. As per parts I.G. and I.H. of the 2001 SOP, there can be no direct discharge of tanks solids, tank bottom
water or the rag layer, and no direct discharge of hydrostatic test water if concentrations of benzene and/or
toluene exceed the water quality standard. Part II.C. lists a requirement specific to the Paw Creek ternnals —
turbidity monitoring as mandated by the EPA. After performing a RPA for turbidity, it has been determined
that a turbidity limit of 50 NTU will be placed in the permit and the frequency of turbidity monitoring will be
monthly.
SUMMARY OF PROPOSED CHANGES
Removal of benzene, to uene, ethyl benzene and xylene limits
Removal of EPA Methods 624/625 monitoring requirement
Addition of naphthalene monitoring
Addition of MTBE monitoring
Addition of quarterly turbidity monitoring
Addition of turbidity limit of 50 NTU
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to PublicNotice: March 14, 2001
Permit Scheduled to Issue: April 27, 2001
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact Natalie
Sierra at [phone] ext. 551.
NAME: DATE:
Fact Sheet
NPDES NC0021971
Renewal
Page 2

REGIONAL OFFICE COMMENTS
NAME:
TE:
SUPERVISOR: DATE:
Fact Sheet
NPDES NCO021971
Renewal
Page 3

REASONABLE POTENTIAL ANALYSIS
Prepared by:
Natalie Sierra, 3/1/01
Facility Name =
Transmontaigne #2, Charlotte
NPDES # =
NC0021971
Qw (MGD) =
0.5475
Qw (cfs) =
0.847092
7Q10s (cfs)=
0
IWC (%) =
100.00
Chronic CCC w/s7Q10 dil.
Frequency of Detection
Parameter
FINAL RESULTS, ug/I
#Samples
# Detects
Xylene
Max. Pred Cw
7.9
Allowable Cw
88.5
29
3
Benzene
Max. Pred Cw
5.3
Allowable Cw
71.4
35
5
Toluene
Max. Pred Cw
7.5
Allowable Cw
11.0
35
2
Ethylbenzene
Max. Pred Cw
13.6
Allowable Cw
383.0
35
3
Turbidity
Max. Pred Cw
92.2
Allowable Cw
60.0
14
14

Parameter-
IXylene
NgA
Parameter =
Benzene
Standard =
88.5
Standard =
1.19
pgA
Dataset=
Dataset=
DMR99
Modified Data Nondetects
1 <2.0
RESULTS
Modified Data Nondetects
0.5 <1.0
1.6
0.5 <1.0
I 0.5 <1.0
1.3
L6
0 5 <1.0
0.5 <1.0
0.5 <1.0
RESULTS
Std Dev.
0.847
Std Dev.
0.492
Mean
1.321
Mean
0.703
C.V.
0.642
C.V.
0.700
1
<2.0
Sample#
29.000
Sample#
35.000
1
<2.0
MultFactor=
2.080
MultFactor=
2.100
1.5
<3.0
Max. Value
3.800
pg/1
Max. Value
2.500
pgA
1
<2.0
Max. Pred Cw
7.904
pgA
Max. Pred Cw
5.250
pg/l
1
<2.0
Allowable Cw
88.500
pgA
Allowable Cw
1.190
pgA
1
<2.0
2' -
0.5 <1.0
0.5 <1.0
1.5
<3.0
1.5
<3.0
0.5
<1.0
0.5
<1.0
1.5
<3.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.6
<1.0
0.5
<1.0
0.5
<1.0
1.5
<3.0
0.5
<1.0
1.5
<3.0
0.5
<1
2.5
<5.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
1.5
<3.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
1.5
<3.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
2.5
<5.0
0.5
<5.0
1.5
<3.01
0.5
<1.0
0.5
<1.01
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
2.5
<5.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
sample#
nondetects
detects
sample#
nondetects
detects
291
28131
35
30
5

Parameter=
Toluene
Parameter=
Ethylbenzene
Standard =
11
pgA
Standard =
3100
pg/I
Dataset=
DMR99
Dataset-
ModifiedData
Nondetects
RESULTS
ModifiedData
Nondetects
RESULTS
0.5
<1.0
Std Dev.
0.651
0.5
<1.0
Std Dev.
1.006
Mean
0.726
0.5
<1.0
Mean
0.880
0.5
<1.0
C.V.
0.898
0.5
<1.0
C.V.
1.144
0.5
<1.0
Sample#
35.000
0.5 <1.0
0.5 <1.0
4.71'
0.5 <1.0
214e
0.51 <7.0
0.5 <1.0
Sample#
35.000
0.5
<1.0
0.5
<1.0
Mult Factor =
2.500
Mult Factor =
2.890
0.5
<1.0
Max. Value
3.000
pg/I
pg/I
Ng/I
Max. Value
4.700
pgA
0.5
<1.0
Max. Pred Cw
7.500
Max. Pred Cw
13.583
pgA
0.5
<1.0
Allowable Cw
11.000
Allowable Cw
3100.000
pgA
0.5
<1.0
0.5
<1.0
0.5 <1.0
0.5
<1.0
0.5
<1.0
0.5
<1.01
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.6
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<7.0
0.5
<1.01
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
2.5
<5.0
2.5
<5.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.01
0.5
<1.0
0.5
<1.0
0.5
<1.0
2.5
<5.0
2.5
<5.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
sample#
nondetects
detects
sample#
nondetect
detects
351
331
21
1
1
35
32
3

Parameter=
Turbidity
Standard =
50
NTU
Dataset=
DMR99
Modified Data
Nondetects
RESULTS
15.3
Std Dev.
8.521
24.4
Mean
11.099
1.9
C.V.
0.768
21.2
Sample#
14.000
1.15
6
Mutt Factor
3.270
12.2
Max. Value
28.200
pg/l
28.2
Max. Pred Gpj
92.214
pg/I
5.3
Allowable Cy
50.000
pg/I
8.2
10.3
10.2
9.88
1.15
sample#
nondetects
detects
14
0
14

Louis Dreyfus Energy/BP (Charlotte)
N C0021971
Discharge 009
Date Ave. Flow TSR Oil & Grease Benzene Xylene Ethylbenzene Toluene
(mg/L) (mg/L) (ug/L) (ug/L) (ug/L) (ug/L)
1/9/97 0.219 16.6 4.32 <1.0 <1.0 <1.0
2/5/97
0.0547
19.4
<1.0®
<1.0
3/6/97
0.3285
17.8
3.67
<1.0
<2 0
<1.0
<1.0
4/30/97
0.4162
40.7
<1.0
<1.0
<1.0
<1.0
5/31/97
0.278
2.8
1.94
<1.0
<1.0
9/29/97
0.325
326
<1.0
<1.0
10/20/97
0.438
22.6
<1.0
<1.0
0.0
<1.0
11/13/97
0.219
33.2
0.0
<1.0
<1.0
12/16/97
0.219
<2.0
6.2
<1.0
<2.0
<1.0
<1.0
1/20/98
0.219
32.6
3.09
2/5/98
0.219
17.2
10.5
<1.0
®
<1.0
<1.0
4/9/98
0.5475
5.6
1.2
<1.0
<2.0
<1.0
<1.0
5/12/98
0.073
12
1.2
<1.0
<3.0
<1.0
<1.0
6/9/98
0.108
<2.0
1.1
<1.0
<2.0
<1.0
<1.0
8/18/98
0.36
24.8
0.0
<1.0
<2.0
<1.0
<1.0
11/30/98
0.109
2.2
<1.0®
<2.0
<1.0
0.0
12/11/98
0.219
31
2.04
<1.0
<3.0
<1.0
0.0
1/25/99
0.108
18.4
1.11
<1.0
<3.0
<1.0
0.0
3/15/99
0.2737
5
0.0
<1
<1.0
<1.0
<1.0
4/15/99
0.054
<2.00
1.09
<1.0
<3.0
<1.0
0.0
6/29/99
0.219
8.4
0.24
<1.0
0.0
<1.0
0.0
8/30/99
0.219
6
0.9
<1.0
<1.0
<1.0
<1.0
9/30/99
0.3285
13
1.3
<1.0
<1.0
<1.0
0.0
10/31/99
0.0547
<4.0
0.8
<1.0
<3.0
<1.0
<1.0
11/30/99
0.219
2
0.9
<1.0
<3.0
<1.0
<1.0
1/14/00
0.0821
3.4
0.291
<5.0
<5.0
<5.0
<5.0
2/28/00
0.1642
2.6
0.11
<1.0
0.0
<1.0
<1.0
3/20/00
0.1642
2.4
1.4
<1.0
<3.0
<1.0
0.0
4/6/00
0.219
<1.0
0.14
<1.0
<1.0
<1.0
<1.0
5/24/00
0.0547
3.2
0.35
<1.0
<3.0
<1.0
<1.0
6/29/00
0.2737
3.6
0.39
0.0
<1.0
<1.0
0.0
8/14/00
0.0821
3.4
0.291
<5.0
<5.0
<5.0
<5.0
9/28/00
0.219
<1.0
<5.0
<1.0
<3.0
<1.0
0.0
11/30/00
0.219
4.4
5.88
0.0
0.0
<1.0
0.0
1/16/01
0.108
<1.0
<5.0
0.0
0.0
<1.0
<1.0
average
0.2189
max
0.5475
1996 All compounds listed below detection level
1997 All compounds listed below detection level
1998 All compounds listed below detection level
1999 All compounds listed below detection level
2000 All compounds listed below detection level
2001 All compounds listed below detection level

NCO021971
Illy •'�'
Nov-97
0
0
5
0
10
0
20
0
40
0
70
0
100
0
Jun-98
0
0
5
0
10
0
20
0
40
0
70
0
100
0
Apr-99
0
0
5
0
10
0
20
0
40
0
70
0
100
0
May-00
0
0
5
0
10
0
20
0
40
0
70
0
100
0

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Whole Effluent Toxicity Testing Self -Monitoring Summary February 16, 2001
FACILITY REQUIREMENT
YEAR lAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
Lenoir -lower CrakWWFP Perm cN lion: 40%; whm pf6MGD chr In 44%
tw) -
Pm
-
-
Pau
-
-
Ppa
-
-
Pep
-
NCW23981/WI BeDW11/1/1998 Ftoo, me QP/F + Feb May Aug Nov + N.oCor,:Sw Ie
tots -
Pm
-
-
F.i.Pm
-
-
Feu
Pep
-
F.n,Pm
-
Couny Caldwell Region ARO SWbpin: CTB31
tot -
Pm
-
-
Fan
NA
aD
o
—
Nit
Pm
-
PF:6.0 SP od
alW _
P®
_
_
pep
_
_
Pew
-
_
Pr.
-
1QI0:I1]5 IWC(%):a adrr:
001
U.Ingto. Regional W WTp PERM CHR LIM: 56-A
9 101 -
plum
-
--
post
-
-
pave
-
-
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29

SOC PRIORITY PROJECT: Yes_ No X
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section
Attention: Christie-daekson-
Date: February 20, 2001
NPDES STAFF REPORT AND RECOMMENDATION
County: Mecklenburg
Permit No. NCO021971
MRO No. 01-02
PART I- GENERAL INFORMATION
I. Facility and Address: Transmontaigne Terminaling, Inc.
Southeast Terminal
7401 Old Mount Holly Road
Charlotte, North Carolina 28214
F1
3.
4.
Date of Investigation: 02-09-2001
Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
1-
L
i
-
Persons Contacted and Telephone Number: Mr. Keith Lewis, Terminal Manager, tel# (704)-
399-3371.
5. Directions to Site: From the junction of NC Hwy 27 and SR 1691 (Old Mt. Holly Road),
travel east on SR 1691 approximately 0.4 mile. The terminal is located on the right side of
the road.
6. Discharge Point(s). List for all discharge points:
Latitude: 35' 16' 38" Longitude: 80° 55' 52"
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on
map.
USGS Quad No.: F 15 SW USGS Name: Mountain Island Lake, NC
7. Site size and expansion are consistent with application?
Yes X No_ If No, explain:

8. Topography (relationship to flood plain included): Flat to moderate sloping; the WWT
facilities are not located within the 100 year flood plain.
9. Location of nearest dwelling: The nearest dwelling is located approximately 500 feet from
the facility.
10. Receiving stream or affected surface waters: Unnamed tributary to Paw Creek
a. Classification: C
b. River Basin and Subbasin No.: Catawba and 03-08-34
C. Describe receiving stream features and pertinent downstream uses: The receiving
stream is a wet weather ditch. General "C" classification uses downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
a. Volume of wastewater to be permitted: Dependent on rainfall.
b. What is the current permitted capacity of the wastewater treatment facility? N/A .
C. Actual treatment capacity of the current facility (current design capacity)? N/A
d. Date(s) and construction activities allowed by previous Authorizations to
Construct issued in the previous. two years: None.
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: The existing wastewater facility consists of an oil/water
separator located at the receiving pipe line manifold, and a 10,000 gallon storage
tank. The storage tank replaced the oil/water separator that was installed for the
truck loading/unloading operation.
f. Please provide a description of proposed wastewater treatment facilities: N/A.
g. Possible toxic impacts to surface waters: Those typically associated with bulk
storage facilities.
h. Pretreatment Program (POTWs only): N/A.
2. Residuals handling and utilization/disposal scheme: N/A. (No solid waste is generated
by this facility.)
a. If residuals are being land applied, please specify
Page 2

DWQ: N/A
b. Permit No: N/A
C. Residuals stabilization: N/A
d. Landfill: N/A
e. Other disposal/utilization scheme (specify): The storage tank is pumped as needed
by Alternate Energy Resources, Inc., (tel# [phone]) and transported to
Georgia.
3. Treatment plant classification (attach completed rating sheet): No rating at this time.
4. SIC Code(s): 5171
Primary:39 Secondary:73
Main Treatment Unit Code: 50000
PART III - OTHER PERTINENT INFORMATION
Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? N/A.
2. Special monitoring or limitations (including toxicity) requests: None.
Important SOC, JOC or Compliance Schedule dates: (please indicate) N/A.
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge
options available. Please provide regional perspective for each option evaluated. N/A.
Air Quality and/or Groundwater concerns or hazardous materials utilized at this facility
that may impact water quality, air quality or groundwater? The facility stores a variety of
fuel oil, typically associated with bulk storage facilities, which if spilled could impact
WQ,GW, and AQ.
6. Other Special Items: N/A
Page 3

PART IV - EVALUATION AND RECOMMENDATIONS
The permittee, Transmontaigne Terminaling, Inc., has applied for permit renewal for the
subject facility. No detrimental impact was observed in the receiving stream.
It is recommended that the NPDES Permit be renewed as requested.
DP, . ,
Water Qu ty Regional Supervisor
Date
Page 4

■�■ TRANSMONTAIGNE
■.■ TERMMAUNG INC.
Certified Mail Return Receipt Requested
7099 3400 0010 6086 0894
December 7, 2000
Mr. Charles Weaver
NC Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
TransMontaigne Terminating Inc. — Southeast Terminal
7401 Old Mount Holly Road
Charlotte (Mecklenburg County)
NPDES Permit Number NCO021971
Renewal Application — Short Form C
Dear Mr. Weaver:
DEC i 1 2000 L.,
' I
DENR • WATER QUALITY
POINT SOURCE PnAHCH
Enclosed are three (3) copies of Short Form C for renewal of the referenced NPDES
permit.
Should you have any questions, please call me at 770/518-3671.
V ry truly yours, 11 I h I
Barbara Castleberry
Environmental Coordinator
Enclosure
Copy: Keith Lewis, w/attachment
200 Mansell Court Phone:[phone]
Suite 600 Fax: [phone]
Roswell, GA 30076-4853

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 22, 1999
Ms. Barbara Castleberry
Louis Dreyfus Energy
8800 Roswell Road, Suite 200
Atlanta, Georgia 30350
Dear Ms. Castleberry:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Letter to Require Effluent
Turbidity Monitoring
Permit No. NCO021971
Southeast Terminal
Mecklenburg County
As you are aware, the turbidity monitoring requirement was eliminated from your
permit upon renewal in August 1996. Although turbidity monitoring was eliminated, total
suspended solids (TSS) monitoring with a limit remains in the permit. It was the Division's
contention that should monitoring data indicate TSS problems, the state has the option of
enforcing the instream standard for turbidity. However, the EPA is still concerned with the
removal of the turbidity monitoring requirement from several oil terminal discharge permits.
The following paragraphs address that concern.
During the research phase required for permit development, it was noted that the 14
permits in the Paw Creek area had vastly different requirements for solids measurements.
Permits contained any combination of total suspended solids (TSS), turbidity, and settleable
solids monitoring and/or limits. In an effort to provide consistency, TSS, turbidity, and
settleable solids results from six oil terminals in the Paw Creek area were examined from
July 1994 through September 1995. Results showed that TSS and turbidity exhibited
similar trends. Both pollutants appeared to increase and decrease at the same time. In
addition, for the period examined, there were no turbidity violations, although there were a
few TSS violations. These data resulted in the Division questioning whether monitoring
was necessary for both solids parameters. Was there an added benefit to requiring turbidity
monitoring in addition to TSS monitoring? The Division concluded that turbidity was
correlated with TSS results, and thus, only TSS monitoring with a limit was required. In
addition, North Carolina has a water quality standard for turbidity. Therefore, although
turbidity monitoring is not required in the discharge permits, the State still has the authority
to enforce the instream turbidity standard.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post -consumer paper

Ms. Castleberry
February 22, 1999
Page 2
Based on concerns regarding anti -backsliding, the EPA requested the Division re-
examine the basis for the elimination of turbidity monitoring for 12 of the 14 Paw Creek
oil terminals that were required to monitor for turbidity prior to the most recent permit
renewal. This second examination of the data showed that there were turbidity standard
violations since the last analysis at several of the oil terminals. The Division will
investigate the causes of these violations to determine what steps may be necessary to
control solids levels at these sites. Therefore, the Division acknowledges that its second
evaluation resulted in a different outcome from the initial investigation and agrees that
turbidity monitoring should be added to the discharge permits for several of the oil
terminals. This letter serves as the official notice that quarterly turbidity monitoring
will be required at the facility effective March 1,1999. If monitoring data show a
reasonable potential to violate water quality standards, then limits will be imposed upon
renewal.
If you have any questions concerning this change, please contact Bethany Bolt at
[phone], extension 551.
fora K
Sincerely,
t,�-A�Preston Howard, Jr., P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Point Source Compliance Enforcement Unit