NC0005771_COMPLIANCE_19890726

NPDES DOCUMENT SCANNING COVER SNEET
NPDES Permit: NC0005771
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
j"C�ompfiance
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: July 26, 1989
This doc�mexat is printed oau�reuse paper-ignore any
r coate�t oa tl�e reverse side

o" STATEq
State of North Carolina
Department of Natural Resources and Community Development
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor Joseph E. Slate, Jr., Director
William W. Cobey, Jr., Secretary Office of regal Affairs
2 6 Jul 19 8 9 Thomas Hilliard, III Judith Robb Bullock
y Edwin 1_ Cavin 11 Robert R. Gdblum
David G. a 6". Robin N. Mk+.ad
James C. Holloway Elizabeth E. Rouse
Yvonne C. Bailey
Ms. Sharon A. Sturges -' ''• - yi
Womble, Carlyle, Sandridge, and Rice : ''
Post Office Drawer 84
Winston-Salem, NC 27102 WQUL
i
RE: Amerada Hess v. NRCD WATER +�` '.� ._� � �
11
File Nos. 89 NRC 0383 and 89 NRC 0550 N SECTt 'iw
Dear Ms. Sturges:.
Enclosed is your copy of the Stipulation to and Request for
Consolidation of the above-referenced cases.
Also enclosed is draft permit language which the Division of
Environmental Management is offering in settlement of the cases.
I have underlined and starred the changes. In addition, the
Division will agree to take out the provision requiring hookup to
a POTW.
If we need to set up a meeting to discuss settlement, please
let me know. I will be back in my office on Monday, July 31st,
and expect to be in the office most of that week.
Very truly yours,
Y onne C. Bailey
YCB:ev
Enclosures
1` cc : CSteve_Tedd=er
Ken Eagleson
Larry Coble
i
Brenda Smith
iPO. Box 27697, RakigK North CAno$rra 27611-76R7 Telephone [phone] —
An Equai oppo twity Affimu8ae Action Emplayer

a r
State of North Carolina
Department of Natural Resources and Community Development
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor Joseph E. Slate, Jr., Director
Office of Legal Affairs
William W, Cobey, Jr-, Secretary 9 June 1989
Thomas Hilliard, fll Judith Robb Bullock
Edwin L. Gavin 11 Robert R. C,elblum
David G. Fleeter Robin N. Michael
James C. Holloway Elizabeth E. Rouse
Fred G. Morrison, Jr. Yvonne C. Bailey
Administrative Law Judge
Office of Administrative Hearings
Post Office Drawer 11666
Raleigh, North Carolina 27604
RE: Amerada Hess Corporation v. Department of
Natural Resources and Community Development, Division
of Environmental Management, File No. 89 NRC 0383
Dear Judge Morrison:
Enclosed please find a copy of the Prehearing Statements of
Respondent in the above-referenced matter.
Thank you for your cooperation in this matter.
Sincerely,
*-13"
Y onne C. Bailey
A ency Legal Specialist
YB/
attachment
cc: Paul Wilms
Steve Tedder
Dennis Ramsey/Arthur Mouberry
Sharon Sturges
Brenda Smith
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

STATE OF NORTH CAROLINA IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
COUNTY OF MECKLENBURG FILE NO. 89 NRC 0383
AMERADA HESS CORPORATION, )
Petitioner )
V. ) PREHEARING STATEMENTS
OF RESPONDENT
NORTH CAROLINA DEPARTMENT )
OF NATURAL RESOURCES AND )
COMMUNITY DEVELOPMENT, )
DIVISION OF ENVIRONMENTAL )
MANAGEMENT }
Respondent. }
NOW COMES the Division of Environmental Management of the
North Carolina Department of Natural Resources and Community
Development, Respondent, by and through the undersigned pursuant
to G.S. 150B-33 (b) (4) and Rule 26 NCAC 3 . 0004 and files
prehearing statements in the above-captioned matter with the
Office of Administrative Hearings in accordance with its Order of
May 10, 1989 .
1 . The issue to be resolved is whether Respondent properly
imposed the effluent limitations and monitoring requirements for
toxicity in Petitioner's Water Quality National Pollutant
Discharge Elimination System (NPDES) Permit No. NC 0005771.
Respondent submits that Petitioner's rights have not been
substantially prejudiced because the acute toxicity requirements
are for monitoring_ only for the purpose of collecting additional
information on the waste characteristics; there is no specific
effluent limitation imposed upon Petitioner. The statute involved
is G.S. 143-215. 1; the rules involved are 15 NCAC 2H Section
. 0100 and 15 NCAC 2B . 0200. The Federal statute involved is 33
U. S.C. 1251 et seq. ; the federal regulations involved are 40 CFR
part 100. ' The legal precedent involved includes Natural
Resources Defense Council v. Environmental Protection Agency_, 859
F. 2d 156 (D. C. Circuit 1988) .
2 . The facts are as follows: Respondent issued
Petitioner's NPDES Permit No. NC 0005771 on March 30, 1989 . On
April 5, 1989 , Respondent made a decision on Petitioner's request
for modification of the subject permit and declined to modify the
permit conditions. The reasons supporting Respondent's decision
are set out in the March 2 , 1989 , memorandum from Trevor Clements
of the Technical Support Branch of the Water Quality Section to
Dale Overcash of the Permits and Engineering Unit of the Water
Quality Section which is attached and marked "Exhibit A" .

c,
3 . Witnesses for the Respondent include, but are not
limited to, the following Division of Environmental Management
(DEM) employees: Steve Tedder, Ken Eagleson, Trevor Clements,
Arthur Mouberry, Rex Gleason and W. Allen Hardy; and the
following employees of the Environmental Protection Agency: Bill
Peltier, John Marlar, Don Mount, Rick Brandes and Jim Gallup.
4 . Respondent, pursuant to G. S . IA-1 , Rules of Civil
Procedures, Article 5, plans to limit its discovery to Requests
for Admissions, Production of Documents and Things and
Interrogatories to Parties. Discovery is estimated to take ninety
(90) days.
5 . Respondent will discuss the location of the hearing
with Petitioner at the Prehearing Conference.
6 . The hearing length is estimated at two days.
7 . Not applicable.
8 . Respondent will be prepared to have a hearing in this
case after November 6, 1989 .
9 . There are no other special matters.
Respectfully submitted this the 9th day of June, 1989 .
YvAbnne C. Bailey, No. 9683
Agency Legal Specialist
Office of Legal Affairs
N. C. Department of Natural Resources and
Community Development
Post Office Box 27687
Raleigh, North Carolina 27611
(919) 733-7247

CERTIFICATE OF SERVICE
I hereby certify that I have caused the attached PREHEARING
STATEMENTS OF RESPONDENT to be served on Petitioner, by having
same deposited in the United States Mail bearing sufficient
postage for delivery by first class mail and addressed as
follows :
Sharon A. Sturges
John M. Loper
Post Office Drawer 84
Winston-Salem, NC 27102
D
D to Yv nne C. Bailey
A ncy Legal Specialist
O fice of Legal Affairs
N.C. Department of Natural Resources and
Community Development
Post Office Box 27687
Raleigh, North Carolina 27611
(919) 733-7247

Dl�;TS10N OF ENVIRONMENTAL MANAGEMENT
llarch 2. 198%
MEMORANDUM
TO: Dale Overcash
V
FROM- Trevor C l emen's
Mike Scoville M6
THRU: Ken Eagleson.4j6
SUBJECT: DRAFT Permit Comments from Amerada Hess
(NPDES No. N?0005771 , Mecklenburg County)
Technical Services has reviewed Mr . Ronald W. Van Zandt ' = comments
regarding the NPDES Draft permit for the Amerada Hess oil storage terminal
in Mecklenburg County. The following is in response to his =omments:
The NPDES Draft permit requires weekly effluent monitoring of flow and
oil and grease. Given the intermittent nature of this discharge, Technical
Services recommends that mon.itorina these parameters be required during each
discharge, as Mr. Van Eandt has proposed, rather than weekly. The permit
should still require !=-e facility to record the approximate times that the
discharge begins and e: �s, along with an instantaneous flow ,measurement
taken at the same time as the effluent sampling.
Effluent monitorin , requirements for lead and aromatic compounds should
not _be changed . Mr . Yzn Zandt states that previous NPDES 2C analyses have
indicated that "these arameters are not present in excessi%_ concentra-
tions. " DEM, however , has no such analyses on record, ar ar:. other data
that characterizes Ame-ada 's effluent. Technical Services be glad to
review any data or doc-._mentation that Amerada submits, but recommends that
effluent monitoring for benzene, toluene, xylene, lead, and napthalene be
maintained for 12 mont _s or until several samples are availal-le for- examina-
tion. At the request L-f Amerada Hess, Technical Services will reevaluate
their NPDES monitoring requirements at that time.
Turbidity and settleable solids are both North Carolina rater duality
standards. Settleable solids was made 'a standard specificaliv with dis-
charges from settling ends in mind. Both of these parameters are uniformly
applied to oil terminal facilities that discharge from storm-.g3ter retention
ponds. Since Amerada discharges to a stream with is likely -o often have
zero flow, the turbid! `;, standard (50 NTU) should be direct!,.. applied to the
ffluer,!- .-ind therefor-_ must be maintained . Technical Servi.--es recommends
that a. limitation on =_-lids should also be required, but would not object to
a TSS limit of 30 mg/1 if Amerada would accept it in lieu of the settleable
solids limit .
Whole-effluent toxicity testing is routinely required of oil storage
terminal discharges based on Division procedures for evaluat_no complex
wastewater . The testiro is necessary to reduce the uncertainty that exists
as to the seriousness •=f the impact of the discharge. Note -hat the requi-

rement is for acute toxicity testing for episodic events and that there is
no chronic target.
Please let me know if you have any questions or co,rments regarding these
matters.
cc : Mooresville
Central Piles

CERTIFICATE OF SERVICiE
I hereby certify that I have caused the attached
RESPONDENT'S RESPONSE TO MOTION TO STAY to be served on
Petitioner, by having same deposited in the United States Mail
bearing sufficient postage for delivery by first class mail and
addressed as follows:
Sharon A. Sturges
John M. Loper
Post Office Drawer 84
Winston-Salem, NC 27102
lqlp
ti
tDatle Yv nne C. Bailey
A ency Legal Specialist
Office of Legal Affairs
N. C. Department of Natural Resources and
Community Development
Post Office Box 27687
Raleigh, North Carolina 27611
(919) 733-7247

STATE OF NORTH CAROLINA IN THE OFFICE OF
ADMINISTRATIVE HEARINGS
COUNTY OF MECKLENBURG FILE NO. 89 NRC 0383
AMERADA HESS CORPORATION, )
}
Petitioner )
V. ) RESPONDENT'S RESPONSE TO
MOTION TO STAY
NORTH CAROLINA DEPARTMENT )
OF NATURAL RESOURCES AND )
COMMUNITY DEVELOPMENT, }
DIVISION OF ENVIRONMENTAL }
MANAGEMENT )
Respondent. }
NOW COMES the Division of Environmental Management of the
North Carolina Department of Natural Resources and Community
Development, Respondent, by and through the undersigned and files
this Response to Petitioner's Motion to Stay Contested Agency
Action in Re NPDES Permit No. NC 0005771 as follows: Respondent
does not object to issuance of the stay provided that the stay
only applies to the effluent limitation and monitoring
requirements for acute. toxicity and Part III , Section G for said
Permit; and that the effluent limitations and monitoring
requirements for the rest of the parameters and the remainder of
the permit conditions and are in full force and effect.
This the 9th day of June, 1989 .
Yvon e C. Bailey, No. 9683
Agen y Legal Specialist
Office of Legal Affairs
N. C. Department of Natural Resources and
Community Development
Post Office Box 27687
Raleigh, North Carolina 27611
(919) 733-7247

y • � FCD �
STATE OF NORTH CAROLINA pIN THE OFFICE OF
r
L ADMINISTRATIVE HEARINGS
COUNTY OF MECKLENBURG �� 89RCd38=3;�
` OFFICE_ OF THE SECRETARY
MAY 12 1989
AMERADA HESS CORPORATION )
Petitioner )
VERSUS ) ORDR FOR-PRE-HEARING
} I STATEMENTS
N. C. DEPARTMENT OF NATURAL RESOURCES )AND COMMUNITY DEVELOPMENT )
Respondent )
In order to permit the prompt preparation of this case for
hearing,
IT IS HEREBY ORDERED, pursuant to 26 NCAC 3 . 0004, that each
party file with the Office of Administrative Hearings and serve upon
the other parties a Prehearing Statement containing your present:
position with regard to the following:
1 . The issues to be resolved, and the statutes, rules, and legal
precedent involved;
2 . A brief statement of the facts and reasons supporting the
party' s position on each matter in dispute;
3 . A list of proposed witnesses;
4. Whether you wish to pursue discovery. If so, the length of time
required;
5 . Requested location of hearing( s) ;
6 . Estimated length of hearing;
7 . If you do not have an attorney, your home and business addresses
and telephone numbers;
8. The date by which you will be ready to have a hearing in this
case; and
9 . Other special matters .
This Prehearing Statement must be filed and served within 30
days of the date of this ORDER.
This the !Uz� day of YVAIX, 1989 .
4 S
Fred G. Morrison Jr.
REAMED Administrative Law Judge
MAY 121989
1-4 QNRCD
LEGAL A�TAIRS
t� o�

STATE OF NORTH CAROLINA IN THE OFFICE OF
S
ADMINISTRATIVE HEARINGS
COUNTY OF MECKLENBURG G ❑ 89 NRC 0383
AMERADA HESS CORPORATION )
Petitioner }
VERSUS } NOTICE OF CONTESTED CASE
AND ASSIGNMENT
N. C. DEPARTMENT OF NATURAL RESOURCES ) G. S . 15OB-23 , 33 (b) (4)
AND COMMUNITY DEVELOPMENT }
Respondent )
NOTICE IS HEREBY GIVEN that a petition for a contested case
hearing pursuant to G. S. 15OB-23 ( a) was filed in and accepted by the
Office of Administrative Hearings on May 3 , 1989 . In accordance
with G. S . 150B-23(a) and 26 NCAC 3 . 0003, Fred G. Morrison Jr. ,
Administrative Law Judge, has been assigned to preside in this case .
The administrative law judge may be contacted by mail at P . 0. Drawer
11666, Raleigh, N.C. 27604, and the telephone number is 919/733-2698.
The Respondent shall submit within 10 des a copy of the
document constituting agency action which caused the filing of the
Petition.
A copy of any document or other item filed with the Office of
Administrative Hearings should be sent to the other party at the time
of filing.
NOTE: You may receive an Order for Prehearing Statements to
which you must respond within 30 days .
This the day of V 1989 .
Robert A. Melott
_ Chief Administrative Law Judge
S
MAY .121989 'a By:
r+ DNRCD Dean C. Farrar
LEGALA.FTFAMRS Chief Hearings Clerk
P . O. Drawer 11666
Raleigh, N. C. 27604
919/733-2698

IN THE STATE OF NORTH CAROLINA z df cS 79
4Y
IN THE COUNTY OF WAKE Le4�'j 98,9
IN THE OFFICE OF ADMINISTRATIVE HEARINGS
AMERADA HESS CORPORATION, ) ?'
Petitioner, )
} PETITION
VS . ) FOR A
CONTESTED CASE HEARING
THE STATE OF NORTH CAROLINA, ) IN RE NPDES PERMIT
DEPARTMENT OF NATURAL } NO. NCO005771
RESOURCES AND COMMUNITY )
DEVELOPMENT, }
Respondent. )
}
Petitioner, herein, Amerada Hess Corporation ( "Amerada
Hess" ) files this Petition and the accompanying Affidavit of F.
Lamar Clark, Vice President , Terminals of Amerada Hess , pursuant
to Article 3 of Chapter 150B of the North Carolina General Stat-
utes and requests a contested case hearing based on the following
facts :
1 . Amerada Hess owns -and operates a facility located
in the City of Charlotte, County of Mecklenburg, in the State of
North Carolina ( "Mecklenburg County Facility" ) , the main purpose
of which is the storage of bulk oil .
2 . In September, 1988 Amerada Hess filed an applica-
tion for a National Pollution Discharge Elimination System
( "NPDES" ) permit with the Department of Natural Resources and
Community Development of the State of North Carolina for purposes
related to the operation of the Mecklenburg County Facility.
3 . On February 8 , 1989, Amerada Hess notified the
State of North Carolina Department of Natural Resources and Com-
munity Development ( "NRCD" ) of its comments to the draft NPDES

Permit No. NC0005771 via a letter from Ronald VanZandt , Manager,
Environmental Systems for Amerada Hess .
4 . In the February 8 letter mentioned above, Amerada
Hess commented, inter alia, that the requirement in the draft
permit for acute toxicity testing on storm water discharge
effluent from the Mecklenburg County Facility was inappropriate
on the grounds that such discharge is intermittent , of low volume
and that the storm water was not significantly contaminated and
requested NRCD to modify the draft permit deleting such require-
ments.
5. On April 3 , 1989, NRCD sent a letter to Amerada
Hess which included the final NPDES Permit No. NC0005771 for the
Mecklenburg County Facility but such letter failed to address
Amerada Hess' comments to the draft permit or Amerada Hess'
request to modify the permit conditions with respect to the acute
toxicity testing requirements.
b. Amerada Hess received no response from NRCD as to
Amerada Hess' comments and request included in the February 8 ,
1989 letter either at or before the time of receipt of the
March 20, 1989 letter and final NPDES permit.
. 7. On April 10, 1989, Amerada Hess received a letter
from NRCD dated April 5, 1989 in which NRCD responded to Amerada
Hess ' comments made in the letter dated February 8 , 1989. In the
response, NRCD declined to modify the permit conditions as
contained in the draft NPDES or final version of Permit No.
NC0005571 in accordance with Amerada Hess' comments and request.
-2-

8 . The foregoing facts are set forth in the accom-
panying facsimile reproduction of the Affidavit of S. Lamar
Clark, Vice President , Terminals of Amerada Hess. Such facsimile
will be supplemented with the original Affidavit in a timely man-
ner.
9. By failing to address Amerada Hess ' particular
comments to NPDES Permit No. NC0005771 and by NRCD' s failure to
fully understand the intermediate nature of the acute toxicity
discharges, NRCD has substantially prejudiced the Petitioner' s
rights and has acted erroneously in its imposition of acute
toxicity testing in Amerada Hess ' NPDES Permit No. NC0005771 .
WHEREFORE, Amerada Hess, Respondent herein, respect-
fully requests this Administrative Body to grant its Petition for
a contested case hearing.
Respectfully submitted,
WOMBLE CARLYLE SANDRIDGE & RICE
By: . :56NJ "Ie
Sha on A. Stur e
4k, M- iooe(;
M. Loper
Pos Office Drawer 84
Winston-Salem, NC 27102
Phone: ( 919) 721-3600
Counsel for Petitioner,
Amerada Hess Corporation
-3-

AYF=DAVIT
. f. Low Clark, otinq duly sworn, upon his oath depos:s and
says:
1 . My position Mith Am*r406 Kim sf 'Corporation is Yiea
President , Terminals and I make this Affidavit on Syr own personal
knowledge.
3. On februarr 1, 1 gb9, Amorada Kolas Vy 1 witwr rrwo
Ronald Va1Zarldt, 11ol;ifled the Worth Caroline o*pertmont of MalIvral
Aosolrces and CotP#nunity Development (IINCONR') of Its coassents with
regard to the draft NP10tS Permit, hv, NCM5771 , for Airerads He*&
Corporation' s Charlotte , North Carolina ttrMinal . AMo1+q other
Points raised, AmeraJa Mess eumm►enteo that the raquirvssent in the
di eft permit for acute toxl61ty tooting on the stormweter
owLharge erflvent from this termin#1 was inappropriate an the
ql ouiids that the di icharge Is ref lvv volume and Intermittent and
that the stormwater was not significantly contaminated.
3, On April 3, 1981 Amarada Itfsi Corporation received
MCONR' s letter dated March 20, 1564 inclvdinb :he final permit for
Amerada Heis ' s Charlotte, North Carolina terminal ,
4. No response to AEeereda 1411:' s cowen=s of ►ebruary S,
19d9 had been received either at or before the time of receipt of
the March 20, 1159 totter and the permit,
S. On April 10, 1959, Mir, Vantandt received a totter from
the NCONR dated April 5, 1989, raipsnoiny to Amerada Mess 's
commants mede In tRe letter dated February f, 1009, The substance
of the response was to decline to m*4i fy the permit tpndl tians In
aCcordancR with Amerads Nest' s comments .
3
I

a� 3�89 la;45Wr j
w2vp
d, by fO lUte to address thtso 9articular house ind
Including ecuts toxicity tviting roquirswents, the NCCOR hos
subs#ontielly prtJudited the petltiontr's rl$hts and acted
errOneuusly, spOclfically by imposing *cut@ toxicity testinb
requirements on in intermitttnt, low vo)Vnq Viicharve which sloes
not Contort 31Brlrlcant emownts of eontamins."ts,
LAMA MIRK
vial fmidentt Tdrminal Oporattont
Subscribed and tworn to
bti'Ore MO this Stj Oly a¢
�IOtiry Pub1 t •O ear r y
My COMISSion Expire$ c
on Dec.

V
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and
accurate copy of the foregoing was served on Joseph Slate,
authroized service agent for the Department of Natural Resources
and Community Development Agency for the State of North Carolina,
by depositing a copy of same with the United States Postal Ser-
vice with sufficient postage for first class delivery.
This the M day of May, 1989.
Served on: Joseph Slate
Office of Legal Affairs
North Carolina Department of Natural
Resources and Community Development
P.O. Box 27687
Raleigh, North Carolina 27611
din M. Loper

STATE
r-�a i
State of North Carolina
Department of Natural Resources and Community Development
Division of Frivironinental Nlana,t,ement
512 .tiorth Salisbury Sneer • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
William W Cobey, Jr., Secretan, Director
February 21, 1989
Mr, Ronald W. Van7,andt, Manager
Environmental Systems
Amerada Hess Corporation
1 Hess Plaza
Woodbridge, NJ 07095-0961
SUBJECT: Draft Permit Comments
NPDFS No. NC0005771
Amerada Hess- Charlotte Terminal
Mecklenburg County
Dear Mr. VanZandt:
This letter is to acknowledge receipt of your letter dated February 8, 1989,
containing comments of the subject Draft Permit. The Division of. Environmental
Management will consider your comments in making its decision on the issuance of the
permit. If you feel that your comments are not addressed in the issued permit, you
may request an adjudicatory hearing in accordance with Chapter 150B of the General
Statutes of North Carolina within 30 days of issuance of the permit.
If you have any questions, please contact me at (9.19) 733-5083.
Sincerely,
A' 4 &4t
M. Dale Overcash
Supervisor, NPDES Permits Group
MDO/ads
cc.Mr. Rex Gleason (with attachment)
Y r�
Mr. Trevor Clements (with attachment)
lc'
Y t
Vr
1'0 nqx 27637, P-lcioh, north Carolina 27611-7687 Telephone 919.733W5
An Egtml Opportunity Affirmative Action Employer

RMERRDR HESS CORPORATION ASO.
February 8 , 1989 1 HESS PLAZA
ELETYPE:710-998-0f373 r WOODBRIDGE,N-J.07095-0961
CABLE ADDRESS:HESSOIL [phone]
�C I] �
Mr. R. Paul Wilms - ��`���'� LOU
NCDNR
Division of Environmental Management fE8 9 1989
Archdale Building ;
Raleigh, NC 2761 1--7687 4
Re: Draft NPDES Permit No. NC0005771
Charlotte, NC Terminal
Dear Mr. Wilms:
Amerada Hess Corporation (ANC) .is in receipt of the subject draft NPDES
permit. While periodic discharge monitoring is warranted, many of the
proposed conditions specified in Section AA . , Effluent Limitations and
Monitoring Requirements , are unnecessary considering the specific nature
of this water treatment system.
The ANC Charlotte Terminal is a Bulk Petroleum Storage Facility,
consisting of a tankfarm, loading rack and associated equipment.
Stormwater is collected in a series of catch basins located throughout
the terminal and conveyed to an oil /water separator. Although all of the
suspended oil is removed in this gravity separation process , as an
additional precaution the water then passes through a two-stage lagoon,
providing additional residence time for removing very small
(approximately 20 micron) oil globules . In addition, since only
stormwater is collected/ treated in this system (no chemical processing
is conducted at this site) , discharge is intermittent and significant
contamination of influent stormwater does not occur (see DMR'S for period
1 /l/84 through 1131/89) .
Considering these facts , please modify the proposed monitoring
requirements to include flow measurement and sampling for 01- 1 and grease
during each discharge only. Measuring settleable solids. , turbidity,
acute toxicity, lead and aromatic compounds is an unnecessary,
burdensome, requirement. These parameters are not present in excessive
concentrations (as indicated in previous NPDES 2C analyses) while
providing no additional useful information for protecting the environment.
If there are any questions concerning this matter, please do not hesitate
to contact me at (201 ) 750-6555.
Very truly yours ,
AMERADA HESS CORPORATION _
Ronald W. VanZandt, Manager
' Environmental Systems
N _
RWV/rg