NCS000530_2019 Staff Report_20191227

NC Division of Energy, Mineral and Land Resources
Review for Permit — NCS000530
Carolina Marine Terminal
Facility Activities and Processes:
• SIC Code: 4491— Marine Cargo Handling
• The facility was excluded from the NCG08 because there is no vehicle maintenance and because
of the pollutant potential of the onsite materials.
• The adjoining property owner was responsible for an offsite release of paraxylene which
contaminated groundwater on the CMT property.
• The facility transfers raw materials from ship or barge to covered conveyor dome, covered pile,
or open pile storage. Stored materials are mechanically loaded from storage to truck or railcar
for shipping to customer.
• Industrial activity creating exposure to stormwater include:
o Open storage piles of chromite ore
o Covered storage piles of commercial/industrial grade salt (not covered)
o Covered storage pile of aggregate
o Contained, hurricane proof storage facility for storage or urea and potassium chloride
o Unloading, transfer, and loading of raw materials listed above
o Operation of powered industrial equipment
Monitoring Information:
• There are two sampled outfalls at the site: Outfall 001 and Outfall 002.
o Outfall 001 drains from a wet detention pond located on the east side of the highway.
o Outfall 002 drains from existing wet detention pond to the Cape Fear River.
• Primary concern with the analytical results in the application are a COD value of 8,340 mg/L at
Outfall 001. It is possible this is caused by surfacing groundwater that is contaminated with
paraxylene.
• The facility currently samples for iron; however, iron is listed as "Removed" from our benchmark
rationale.
• The 2008 Multi Multi -Sector General permit in Sector Q Water Transportation recommends
monitoring for total Aluminum, total iron, total lead, and total zinc, based on the SIC code of
4491. However, other parameters will apply based on types of materials stored.
• The receiving stream is classified as SC. Therefore, the Classifications and Standards Unit was
contacted in order to see if the benchmarks need to be adjusted for a salt water environment.
• Recommended saltwater benchmarks:
o Iron: 4.5 mg/I
o Chromium: 1 mg/L
o Zinc: 0.095 mg/L
o Aluminum: No saltwater data is available for aluminum
o Lead: 0.022 mg/L
• Recommended monitoring includes Oil & Grease, COD, TSS, TN, TKN, Ammonia, TP, Fe, Cr,
Xylene, Zn, Al, Pb, and temperature.

The analytical parameters TN, TKN, and ammonia were added to the permit because the site
stores similar materials to PCS Phosphate (NCS000520). The staff report from March 19, 2008
for NCS000520 states the DWQ Planning Section found there is not an appropriate benchmark
for ammonia for saline waters at the time (toxicity highly variable depending on pH and
temperature; Final Acute Value (FAV) can change significantly based on these conditions.
Planning staff recommend monitoring only for ammonia, along with pH and temperature, to
assess toxicity potential after more data collected. Because ammonia is a component of TKN, a
TKN benchmark will not be included either. The draft permit keeps the 30 mg/L TN benchmarks
to serve as trigger for investigating potential problems of excessive nitrogen.
o TN=TKN (nitrate+nitrite); TKN=ammonia+organic nitrogen. Measuring TN and TKN will
provide information about nitrate/nitrite levels. Also, measuring ammonia will indicate
how much TKN is organic.
o Cr was included in the analytical monitoring because of the chromite ore storage onsite.
Impairment:
• The adjacent facility owned by Flint Mills (used to be Koch) had a paraxylene spill whose plum
migrated to the CMT site several years ago. The consultant working on that groundwater
remediation (using air sparge) indicates their attempts have proven successful.
• The Cape Fear River is on the 2006 303(d) for Standard violation: Low Dissolved Oxygen and Low
pH. The Basinwide Plan indicated turbidity is a stressor as well as low dissolved oxygen and low
pH.
• This section of the Cape Fear River is listed as an impaired water experiencing issues with fecal
coliform, iron, pH, arsenic, chromium, water temperature, nickel, chlorophyll a, cadmium,
copper, zinc, fish tissue mercury, lead, dissolved oxygen, and turbidity.
Threatened or Endangered:
• Shortnose sturgeon and the West Indian Manatee