NC0004839_CORRESPONDENCE_19961121

NPDES POCUWENT SCANNIMO COVER SMEET
NPDES Permit: NC0004839
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Correspondence
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: November 21, 1996
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TURNER
HART &
AWHiCKMAN, P.C.
Environmental Consultants& Engineers
November 21, 1996
North Carolina Department of Environment,
Health and Natural Resources
919 N. Main Street
Mooresville,NC 28115
cJ,
Attention: Mr. Gil Butler -
r,
Re: Remediation System _
Exxon Marketing Distribution Terminal
Charlotte,North Carolina
TH&H Job No. Exxon E013 s `"
Dear Mr. Butler:
On behalf of Exxon Company, U.S.A., Turner Hart & Hickman, P.C. is providing
notification that the soil vapor extraction and ground water extraction remediation systems at the
Exxon Marketing Distribution Terminal in Charlotte have been temporarily shut down for
maintenance to the catalytic oxidizer. The catalytic oxidizer treats the off-gasses from the two
remediation systems. Some corrosion was observed in the catalytic oxidizer heat exchanger and
catalyst beds during recent routine maintenance activities conducted in late October. The system
was shut down at this time. TH&H is currently working with the oxidizer manufacturer
(ThermTech),to determine the cause of the corrosion and the need to repair,or replace potentially
damaged parts to ensure adequate off-gas treatment. The ground water and soil remediation
systems cannot be operated without concurrent operation of the catalytic oxidizer.
The bioventing system located in the former railroad spur area is not operationally
connected to the catalytic oxidizer. The bioventing system will continue to operate during shut
down of the oxidizer.
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4421 Stuart Andrew Boulevard • Suite 300 Charlotre, North Carolina 28217
Mephone 704-523-5280 • Fa.ic 704-523-1037

TURNER HART &WICKMAN, PC.
Mr. Gil Butler
November 21, 1996
Page 2
We anticipate that the remediation systems will resume operation no later than December
31, 1996. If you have any questions concerning this submittal, please contact me or Mr. Vince
Martinelli of Exxon at [phone].
Very truly yours,
TURNER HART& HICKMAN, P.C.
Steven C. Hart, P.G.
Principal
SCH/tcm
cc: Mr. Vince Martinelli
Mr. Steve Pellei -NC DEHNR Raleigh
Mr. Jens Schoenfuss - MCDEP
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AkO( TURNER
HART &
HICKMAN, P.C.
Environmental Consultants & Engineers
November 11, 1996
North Carolina Department of Environment
Health, and Natural Resources
919 North Main Street ='
Mooresville, NC 28115
Attention: Mr. S amar B ou-gh azal e
Re: Follow-Up Notification Letter `=
NPDES Permit NC0004839
Outfall 002
Exxon Marketing Distribution Terminal
Charlotte,North Carolina
TH&H Job Exxon E011
Dear Mr. Bou-ghazale:
On behalf of Exxon Company, U.S.A., Turner Hart & Hickman, P.C. is submitting this
follow-up'letter to our verbal notification of an NPDES permit level exceedance for the ground
water remediation system outfall (Outfall 002) at the Exxon Marketing Distribution terminal
located in Charlotte, North Carolina (NPDES Permit NC 0004839). On November 5, 1996 we
received preliminary results from the analytical laboratory from our regular NPDES monitoring
sample collected from Outfall 002. The results of the analyses indicated that 1,2-dichloroethane
was present at a concentration of 1.8 ug/l, which is slightly above the detection limit of 1.0 ug/l.
The NPDES permit level is 0.38 ug/l. The laboratory was asked to confirm the analytical result
for the compound and the compound's presence and concentration were confirmed. All other
compound coiwentrations were below pen-nitted levels. On November 6, 1996, in accordance
with the provisions of the NPDES permit, we provided 24-hour verbal notification of the
exceedance to you. You indicated that we should provide you with follow-up written
notification of the permit level exceedance.
On November 6, 1996, following confirmation of the analytical data, Exxon took corrective
action steps. The system was shut down and the air stripper ground water treatment system was
modified to increase the air input to the stripper. Past experience indicates that this flow rate
increase is capable of reducing compound concentrations in the effluent.
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4421 Stuart Atitlreu'Boulevard • Suite 300 • Charlotte. North Carolina 28217
Telephone[phone] • fax[phone]

TURNER HART & HICKMAN, P.C.
Mr. Samar Bou-ghazale
November 11, 1996
Page 2
As we discussed, Exxon is also in the process of installing a carbon polishing unit for the
ground water remediation system discharge. This project has been slightly delayed due to severe
damage to the carbon unit skid during transport to the site. We anticipate receipt and start-up of
the re-built carbon unit skid by the week of November 18, 1996. Installation of the carbon units
will provide an additional factor of safety in the ground water remediation system treatment
train.
The results of the sampling events reported herein will be documented in the November
Discharge Monitoring Report for Outfall 002. If you have any questions concerning this
submittal, please do not hesitate to contact me or Vince Martinelli at Exxon at [phone].
Very truly yours,
TURNER HART& HICKMAN, P.C.
ff �Jc-
Steven C. Hart, F.G.
Principal
SCH/tcm
cc: Mr. Steve Pellei -NC DEHNR Raleigh
Mr. Gerald Truesdale - Exxon
Mr. Vince Martinelli-Exxon
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_ AWTURNER
HART &
HICKMAN, PC.
Environmental Consultants & Engineers
October 28, 1996
,-,
North Carolina Department of Environment,
TO
Health, and Natural Resources -�
s,
Division of Water Quality
PO Box 29533 '
Raleigh, North Carolina 27626-0535 =,
Attention: Ms. Jennifer Wolfe
Re: NPDES Permit
Exxon Marketing Distribution Terminal
Charlotte, North Carolina
Permit No. NCO004839
TH&H Job No. Exxon-0O25
Dear Ms. Wolfe:
This letter will serve to memorialize our conversation on October 28, 1996 concerning
the NPDES ground water remediation system discharge for the Exxon Marketing Distribution
terminal in Charlotte. As we discussed, Exxon is currently in the process of adding a carbon
polishing treatment train to the existing ground water remediation system (permit outfall 002) in
accordance with the Authorization to Construct dated August 16, 1996.
Exxon's revised NPDES permit became effective on September 1, 1996 and includes the
addition of carbon polishing in the ground water remediation system treatment train. As
discussed previously with Mr. Steve Pellei on August 20, 1996, it was acceptable to continue
discharge of treated ground water while the carbon polishing units were being fabricated and
constructed. We indicated at this time that we anticipated that the carbon units would be
operational in October.
As we discussed, the carbon system skid unit was received damaged today, which has
resulted in delays in start-up of the carbon polishing units. The skid unit was delivered to the site
today and the system was to have been operational by the end of this week. However, upon
delivery at the site, it was noted that the skid for the carbon units, which houses the transfer
pump, control panel, interconnected piping, filters, etc., had been severely damaged in transport
by the trucking company and was not useable. The system is being returned to the manufacturer
on.a rush basis so that parts can be salvaged and a new skid can be manufactured. The concrete
pad has been poured and the carbon vessels have been delivered and are on-site.
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4421 Stuart Andrew Boulevard • Suite 300 • Charlotte, Nortlz Carolina 28217
Telephone [phone] • Far 704-52.3-1037

96
TURNER HART & HICKMAN, P.C.
Ms. Jennifer Wolfe
October 28, 1996
Page 2
The skid manufacturer anticipates that it will take two to three weeks to fabricate another
skid. We will make attempts to have the equipment fabricated as soon as possible. We
anticipate that the carbon units will be operational no later than the end of November.
Per our discussion, we understand that it is acceptable to continue to discharge treated
ground water in the month of November while the skid unit is re-fabricated. As mentioned, the
monthly sampling conducted in September indicated that the existing treatment train was capable
of meeting the revised permit parameters without the carbon polishing units.
If you have questions concerning this submittal, please do not hesitate to contact me.
Very truly yours,
TURNER HART& HICKMAN, P.C.
Ste en C. Hart, P.G.
Principal
SCHAcm
CC" Vince Martinelli
Gerald Truesdale
Steve Pellei
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