NC0003671_PERMIT ISSUANCE_20011116

NPDES DOCUWKNT SCANNING COVER SHEET
NPDES Permit:
NC0003671
Document Type: 'r
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Correspondence
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date:
November 16, 2001
This daoum eat is pr43Mted 9:01n A-0V RM paper - iMPnrOre aay
coot WMt oa the �-Werse side
0

of W A rE9
Michael F. Easley
� pG Govemor
William G. Ross, Jr., Secretary
�f North Carolina Department of Environment and Natural Resources
Gregory J. Thorpe, Ph. D., Acting Director
Division of Water Quality
November 16, 2001
Steve W. Monn, CHMM, REM
Williams Terminals Holdings, L.P.
P.O. Box 21628
Tulsa, Oklahoma 74101-1628
Subject: FINAL -- NPDES Permit No. NCO003671
Williams Terminals Holdings, Greensboro 11 Terminal
7109 West Market Street
Guilford County
Dear Mr. Morin:
This letter transmits your final NPDES individual discharge permit for the subject facility.
Please review this final document carefully to ensure thorough understanding of the information,
conditions, and requirements of dischargers to water supply (WS) waters contained therein.
The Division of Water Quality (the Division) has revised permitting strategies and Standard
Operating Procedures (SOP) for this and all bulk -storage petroleum facilities and terminals in
North Carolina. As part of permit renewal, the Division has also conducted EPA -required
Reasonable Potential Analyses (RPA) on this facility's effluent data to determine the "reasonable
potential" for identified parameters to exceed North Carolina receiving -stream Water Quality
Standards and criteria. The following explanations summarize changes to your previous permit
in compliance with the new 2001 SOP:
BTEX. Williams Terminals Holdings (Williams) is now required to monitor monthly for
BTEX parameters. Please note that this replaces the previous requirement for EPA Method 624.
A Benzene limit appears in the permit because the RPA indicates "reasonable potential" based
on data submitted, i.e., the "maximum predicted" concentration of 83 µg1L benzene well exceeds
the "allowable concentration" of 1.19 µg/L benzene for WS waters. Williams' comments
(October 25, 2001) regarding the benzene limit have been reviewed and considered. Please
understand that a permit limit is dictated by discharge parameters and receiving stream
conditions — not the test -method practical quantitation limit (PQL). Please continue to insist on
the lowest possible test -method PQL available from your North Carolina —certified laboratory.
'A
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1 800 623-7748

Williams Terminals Holdings
Greensboro II Terminal
NPDES Permit NC0003671
Page 2
EPA Methods 624/625. The Division removed Method 624 monitoring because Method
624 did not detect compounds other than BTEX. However, because the majority of facilities
now store, or have stored in the past, heavy -component fuels such as fuel oil and diesel, the
Division has retained EPA Method 625 monitoring to detect naphthalene and related indicators
of middle distillate compounds commonly found in these heavier fuels. The .Division will
consider a request to discontinue this monitoring if the Permittee can document that the subject
facility does not now, nor has ever, stored heavier -component fuels.
Phenol monitoring remains in the permit, but with an added permit limit due to "reasonable
potential." Please note that this final document has been modified from the draft permit to
express the phenol limit in pounds per day (lbs./day) as a Monthly Average, 0.001 lbsJday,
instead of a Daily Maximum of 0.85 µg/L shown in the draft. Again, the permit limit is dictated
by receiving stream conditions -- not the test -method PQL.
The Division calculated an instream wasteload allocation of 0.002 lbs./day phenol at the
USGS stream gauge (0209400000) on Horsepen Creek — the assumed beginning of Lake Brandt
Water Supply (incorrectly identified in draft documents as Lake Townsend). The 0.002 lbs./day
was distributed equally between two (2),,,bulk-storage facilities within this drainage (0.001
lbs./day per discharger). The Division then calculated an allowable concentration of 0.85 µg/L
using Williams' highest flow reported during the last permit cycle (0.1404 MGD, January 1999).
Phenol was detected four (4) times in 26 samples. Based on data submitted, this facility's
"predicted maximum" of 52.4 µg/L well exceeds its "allowable concentration" of 0.85 µg/L
(calculations have been provided at Williams' request).
Compliance reporting for phenol should also be expressed in tbs./day. Williams has
consistently reported a test -method PQL for phenol of 5.0 µg/L during this past permit cycle.
Please continue to insist on the lowest possible test -method PQL available from your North
Carolina —certified laboratory.
MTBE is a gasoline component recently identified by the EPA as potentially carcinogenic.
Therefore, monthly MTBE monitoring has been added to this and all oil terminal permits
discharging to WS waters of the state. The Permittee's comments on the draft permit (October
25, 2001) noted MTBE Special Conditions but excluded reference to this paragraph. The
Division is greatly concerned that Williams detected MTBE in 14 of 18 sample events. Although
a standard for MTBE has yet to be established for WS waters, this facility's RPA predicts a
"maximum" of 12,026 µg/L MTBE, based on data submitted. This'maximum is —1000 times
greater than 12.0 µg/L, the currently proposed Standard for Class WS waters. Therefore,
Williams shall formulate and implement a MTBE Reduction Plan. This plan may include
site -specific Best Management Practices (BMPs) and/or engineering solutions and shall be
submitted to the NPDES Unit for approval by July 1, 2002, within six (6) months of the permit
effective date.

Williams Terminals Holdings
Greensboro II Terminal
NPDES Permit NCO003671
Page 3
If any parts, measurement frequencies, or sampling requirements contained in this permit
are unacceptable, you have the right to an adjudicatory hearing upon written request within thirty
(30) days after receiving this letter. Your 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 a demand is made, this permit shall be final and binding.
This permit is not transferable except after notifying the Division of Water Quality. The
Division may require modification, or revocation and re -issuance of this permit. Please notice
that this permit does not affect your legal obligation to obtain other permits required by the
Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act,
or other federal or local governments.
If you have questions, or if we can be of further service, please call Joe Corporon at (919)
733-5083, extension 597.
Respectfully,
Original Signed By
David A Goodrich
Gregory J. Thorpe, Ph.D.
Enclosure: NPDES Permit NCO071463
cc: Central Files
Winston-Salem Re Tonal Office Water Quality Section
NPDES Unit;
Point Source Compliance and Enforcement Unit
Technical Assistance and Certification Unit
Aquatic -Toxicology Unit

Permit NC0003671
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
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,
Williams Terminals Holdings, L.P.
is hereby authorized to discharge wastewater from outfalls located at the
Williams Terminals Holdings, Greensboro II Terminal
7109 West Market Street, Greensboro
Guilford County
to receiving waters designated as an unnamed tributary of Horsepen Creek within the Cape Fear River
Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in
Parts I,11, III and IV hereof.
This permit shall become effective January 1, 2002.
This permit and authorization to discharge shall expire at midnight on August 31, 2006.
Signed this day November 16, 2001.
Original Signed By
David A. Goodrich
Gregory J. Thorpe, Ph.D., Acting Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NC0003671� ,
SUPPLEMENT TO PERMIT COVER SHEET
Williams Terminals Holdings, L.P.
is hereby authorized:
1. to continue discharging storm water from the existing water pollution control system consisting of
• truck loading -rack drains
• oil 1 water separator
• waste holding tank (with optional pump -out for offsite disposal)
• gravity drains to dike containment areas
• discharge control valves (for pre -tested wastewater)
• dry -ditch drains to UT of Horsepen Creek
located at the Williams Terminals Holdings, Greensboro II Terminal, 7109 West Market Street,
Greensboro, Guilford County, and
2. to discharge from said treatment facility through Outfall 001 at a specified location (see attached
map) into an unnamed tributary of the Horsepen Creek, a waterbody classified as WS-III, NSW
waters within the Cape Fear River Basin.

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Permit NC0003671
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
CHARACTERISTICS
LIMITS
MONITORING
REQUIREMENTS
Monthly
Avera a
Daily
Maximum '
Measurement
Fre u ncy
Sample
Type
Sample Location
Flowi
Episodic
t
Effluent
Total Suspended Solids
45.0 m
Monthly
Grab
Effluent
Oil and Grease2
Monthly
Grab
Effluent
Phenol
0.001 lbs./day
Monthly
Grab
Effluent
Benzene
1.19 /l
Monthly
Grab
Effluent
Toluene
Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
X lene
Monthly
Grab
Effluent
EPA 625
2/Year
Grab
Effluent
MTBE3
Monthly
Grab
Effluent
Acute Toxicit 4
Annually
Grab
Effluent
Footnotes:
1. Flow -- During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow shall be monitored 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);
b) estimate flow at 20-minute intervals during the entire discharge event; or
c) 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. MTBE — See Special Condition A.(2.) for other requirements relating to MTBE
4. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(3.)].
Units: mg/L = milligrams per liter
pg/1 = micrograms per liter
lbs./day = pounds per day
MTBE = methyl tertiary butyl ether
The permittee shall not discharge floating solids or foam visible in other than trace amounts.
The permittee shall not discharge tank solids, tank bottom water, or the tank rag layer.
The permittee shall not discharge tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 1.19 ug/L and toluene concentration is less than 11 µglL.

Permit NC0003671
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2.) MTBE MONITORING
For the protection of public health, oil terminals discharging to waters classified as water supplies
("WS" waters) shall adhere to the following action plan:
1. Monthly monitoring for MTBE (except as modified under 2.) is required for the duration
of the permit [See Part A. (1.)].
2. After a one-year Test Period of monthly monitoring or after twelve (12) discharge events
have been sampled and analyzed, the Permittee shall review MTBE data. If MTBE is not
detected, the facility may request the Division to reduce the MTBE monitoring
frequency. Granting this request shall constitute a minor modification to the NPDES
permit.
3. If MTBE is detected during the Test Period, the Permittee shall submit an MTBE
Reduction Plan. This plan may include site -specific Best Management Practices (BMPs)
or engineering solutions. A copy of this plan shall be submitted to:
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
4. The Division anticipates that an MTBE regulatory criterion or Water Quality Standard
will be established during the coming permit cycle. For the next cycle of permit renewals,
the Division expects to apply this criterion .or standard to MTBE data collected during
this permit cycle. Should the permittee's MTBE data indicate discharge in excess of this
criterion or Water Quality Standard, an MTBE limit will be added to the permit
monitoring requirements at renewal.

Permit NC000367 V
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (3.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA160014-901027 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.

NPDES PERMIT
DRAFT / FINAL
CHECKLIST CFYQ1fRLY t*�Cz
FILE CONTENTS: Facility wt L L( 4NLS (-bLAS t a�_9 ) L
Left side:
❑Iew Tracking Slip.
a Old Tracking Slip.
Right side:
❑ _Streamline Package Sheet
�ff/ Draft Permit Cover Letter.
C�"/Draft Permit
Q/ Facility Map
L7 -,'Fact Sheet.
C' Permit Writer's Notes
/46 --B /Staff Report from Region
ff iOld Permit
p, ermit Application.
GY Acknowledgement Letter
❑/Permittee Responses
R Waste Load Allocation
Permit No. !V C 3
NPDES Permit
(to region, onjyjlreamlined)
(add new p text; summarize major c nges to permit)
(order: cover, supplement, map, effluen�sheets, special conditions)
(F-Map: Include facility; Outfalls; U and D sample locations)
(document permit writer's issues and re -issue logic)
(if not in Facts Sheet -- chronology, strategy, DMR Review, RPA, etc.)
(as appropriate -- not needed if streamlined)
(Text, Effluent Sheets and Special Conditions)
(New Permit or Renewal; any additional permittee correspondence)
(for Renewal Application, from NPDES Unit)
(to acknowledgement letter, if any)
(reference date; recalculated for current action?)
Note: Italics indicate special conditions not always required or applicable.
R Submitted to for Peer Review: Date lftfFP4�
h� Peer Review completed by Date III �n t
W Permit Mailed / E-Mailed to Regional Staff fwiV� t` ice! �by ._ Date J751W
M Regional Office Review completed by �� � `� ), Date
❑ Additional Review by
❑ Additional Review completed by
initiated by Date
on: Date
8- Updated ubhc Nottcand �atabases. Date Date 6N�o
ubmitted to � CT40 - for Public Notice on Igs�P�`[ : Notice Date
I S 6 If�tStF tti
DI FINAL submitted to Dave Goodrich for signature on
19/ Additional Review

N k
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1�
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VIA FACSIMILE 919/733-0719 i; U
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O
October 25, 2001
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aD
Joe R. Corporon I
o
L-
NPDES Unit n 1
NCDENR , ----'
-�
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Draft NPDES Permit No. NCO003671
Your letter dated September 19, 2001, and received October 1, 2001
Wiiliams Terminals Holdings, L. P.'s Greensboro 11 Terminal
7109 W. Market Street
Guilford County
Dear Mr. Corporon:
wilibiffS
ENERGY SERVICES
1717 Smith Boulder Avenue
P.O. Box 21628
Tulsa, Oklahoma 74121-1628
Please note that while the draft permit is dated September 19, 2001, the postmark on the draft permit
envelope was September 21, 2001, and the permit was not received (at the Tulsa, OK address) until
October 1, 2001.
Regarding subject draft NPDES permit, Williams appreciates the deletion of the requirement to perform
EPA Method 624, but requests an explanation as to the continued semiannual requirement for EPA Method
625. Williams reported in its August 1, 2000 submittal that there had been no EPA Method 624/625
detections since Williams purchased the terminal in January 1999. Furthermore, in the records from the
former owner Amoco, they had no detections during their last semiannual sampling event either. As a
result, Williams requested a change from semiannual to annual for EPA Method 625, but the draft has been
written for semiannual instead. Your compliance review lists zero hits on EPA Method 625 either. The
only possible explanation on the draft is with reference to the 2001 SOP. However, Williams' Greensboro
II NPDES permit is an individual permit, not a general (or generic) permit, but from the discussion about
the revised SOP, it appears that NCDENR has essentially placed all oil terminals into one generic permit
scenario. An explanation as to Departmental thinking would be appreciated. Any written literature with
reference to the 2001 SOP, hard copy or on the Departmental website, would also be appreciated.
Furthermore, Williams asks for an explanation as to the limits placed on benzene and phenol. The benzene
limit is roughly 20% of the federal MCL, and the phenol Iimit is well below what the current EPA
analytical methodologies provide as to detection levels, both for wet chemistry and GC/MS analytical
methods. As a result, the limit placed on phenol is not even capable of being met by the laboratories. The
phenol monitoring and limits calculations have been reviewed, but there are several questions, i.e, what do
1.55 and 0,001 mg/1 represent? Possibly the 0.001 mg/l is phenol's aesthetic limit (stated earlier in the
calculations as 1.0 ugll), but then the question becomes what other phenol limits exist, and why was the
aesthetic limit used? Furthermore, what would prevent the permit being written to allow for compliance
with either a maximum concentration discharge or a maximum wasteload discharge per day? And,
Williams would appreciate an explanation as to how the aesthetic and/or other limits were established,
given that phenol cannot be measured at either the draft or aesthetic limit, and taking into account the above
comment about individual permits versus general permits.
Williams also appreciates the A. (2.) MTBE Monitoring language in the'draft, thereby allowing Williams to
petition for a change in sampling frequency after 12 discharge events with no'MTBE detections. Williams

requests that this same approach be taken relative to the BTEX constituents and phenol, again based on the
fact that the discharge history at the Williams Greensboro II terminal has been exemplary.
If there are any questions with regard to this transmittal, please call, I can be reached at 918/574-8420.
Sincerely,
teve W. Monn - CHMM, REM
Environmental Support
Williams Independent Terminals Group
1/
gbII102501
Ruben Qualls, Greensboro II Terminal
File/Greensboro II/Water Mgmt
14- 5- �-� - f<-? ?-

DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NCO003671
INTRODUCTION
Williams Terminals Holdings, L.P. (formerly Williams Energy Ventures, Inc.), herein referred to as
Williams or the permittee, requires a National Pollutant Discharge Elimination System (NPDES)
permit to dispose treated wastewater to the surface waters of the state. The Permittee's 5-year NPDES
permit has expired and they have requested renewal from the Division of Water Quality (the
Division). This Fact Sheet summarizes background information and rationale used by the Division's
NPDES Unit to determine permit limits and conditions. This document also contains references to
information sources relevant to this permit renewal (superscripted numbers in order of appearance,
See References).
FACILITY RECORDS REVIEW
Facility Description. Williams (Table 1) operates the Williams Greensboro II Terminal (formerly the
Amoco Oil Company Greensboro Terminal), a bulk storage petroleum fuel distribution center in Guilford
County. Discharge from the facility consists of stormwater runoff controlled by a Water Pollution Control
System consisting of: loading rack drains; oil/water separator; waste holding tank with optional offsite
disposal; gravity -drained dike containment areas; and discharge control valves. Discharge travels to an
unnamed tributary (UT) of Horsepen Creek.
Table 1. Williams Terminals Holdings, L.P. -- Water Pollution Control System
Facility Information
Applicant/FacilityApplicant/Facility Nam 1,2
Williams Terminals Holdings, L.P. / Greensboro II Terminal
Apelicant Address
P.O. Box 3448, Tulsa, Oklahoma 74101
Facility Address
7109 West Market Street, Greensboro, NC 27419
Permitted Flow (MGD)
Not limited
Type of Waste '
Industrial runoff wastewater. SIC Code 5171
WW Code Prim. 37; Second. 39;
Facility/Permit Status ' "
Class I, Minor / Renewal
Drainage Basin / Countj
Cape Fear / Guilford
Miscellaneous
Receiving Stream
UT of Horsepen Creek
Regional Office
Winston - Salem
Stream Classification '
-
WS-III, NSW
State Grid /
USGS To o Quad
C 19 SW /
Guilford, NC
303(d) Listed? 5
Not listed
Permit Writer
Joe R. Cor oron
Subbasin
03-06-02
Date:
10Se O1
Drainage Area (sq. mi.)
Lat. 36' 04' 52" Long. 79' 55' 56"
Summer7Q10 (cfs)''
0.0
Winter 7Q10 (cfs) ''
0.0
30Q2 (efs)
0.0
Average Flow (cfs)
0.0
IWC (%) '
100
hact Shea
Renewal -- NPDES Permit NC.0003671
Page I

This permit became effective June 1, 1996 (with an expiration date of January 31, 2001). To stagger
the renewal workload, the Division extended the expiration date to June 30, 2001.
Waste Load Allocation (WLA). The Division conducted a WLA in August 1989 and developed
effluent limits and monitoring requirements based on an in -stream waste concentration (1WC) of
100% (zero -flow stream).b The Division judges these limits and monitoring requirements to be
appropriate for this renewal with the exception of additions and deletions listed below (see
PERMITTING APPROACH SUMMARY).
Verifying Existing Stream Conditions. This facility discharges to a "zero -flow" stream, an
unnamed tributary (UT) Horsepen Creek. This creek is a Class WS-III NSW stream within the Cape
Fear River Basin. Horsepen Creek is not listed as an "impaired" waterbody [not 303(d) listed].$
COMPLIANCE REVIEW
Discharge Monitoring Reports (DMR) -- Effluent Data Review. DMRs were reviewed from
January 1996 through June 2001.' Discharges from Outfall 001 occurred episodically, zero to four
times per monthly — non -discharge months reported as "no flow." The permittee reported a maximum
discharge of 0.1404 MGD (June 2000). Therefore, this flow was used for reasonable potential
calculations (see below). Monitored parameters and RPA data review are summarized in Table 2:
Tahle 2. DMR I RPA -- Data Review Summary
Parameter
,Samples
' Hif`
High
SM n,
4RP
Commeiitss/ Act
Plow
68
--
0.1404
-
--
High flow used for RPA
MGD
Benzene
29
2
14 µg/L
1.02 µg/L
Yes
Previously monitored
Added permit limit
Toluene
29
0
--
--
No
Previously monitored
Ethyl Benzene
29
0
--
--
No
Previously monitored
Xylene
29
1
1.9 L
--
No
Previously monitored
Phenol
26
4
17 µg/L
4.2 µg/L
Yes
Previously monitored
Added permit Limit
TSS
34
31
55.3 m
15.1 m L
--
Limit 45 m L (no change)
Oil & Grease
35
10
13 m L
4.19 mg1L
No
Maintain in permit — no limit
MTBE
18
14
1930 µg/L
283.7 µg/L
?
Criteria/limit in progress --
Warning to cover letter
TOX
6
--
--
--
--
All Pass except
(Acute)
(annual)
1999 @ 50% only__
EPA 624/625
8
0
--
--T
--
Retain 625
Delete 624
I RP = "Reasonable Potential" to exceed receiving -stream Water Quality Standard.
Tact Sheet.
Rcnewal -- NVDES NC0003671
Page 2

Based on the Division's our review of the DMRs, twice annual EPA 624/625 scans did not detect
semi -volatile or volatile organic compounds. Total suspended residue (TSR) results do not exceed
recommended levels.
Notices of Violation (NOVs). An NOV was issued in May 1999 for "failure to submit a DMR
report." No other NOVs were issued to this facility during this permit cycle.$
Facility Inspections. This facility was last inspected in August 22, 1990 in connection with a
request to alter the discharge sampling point. Beginning with this permit cycle, the Winston-Salem
Regional Office has scheduled regular annual inspections for this and all bulk -petroleum storage
facilities in the Greensboro area.9
Whole Effluent Toxicity (WET) Test. The facility has passed its annual acute toxicity test for four
(4) years(1997 through year 2001), except in 1999 at 50% effluent concentration only.
Total Suspended Solids (TSS). Since 1996 only a single TSS level was reported in excess of the
Daily Maximum permit limit (February 2001, 55.3 mg/L). This minor violation was not assessed.
However, according to the Compliance and Enforcement Unit, future discharges in excess of 45 mg/L
will be assessed as a violation.e
PERMITTING STRATEGY
Revised Standard Operating Procedures (SOP). The Division has revised permitting strategies
and SOP for this and all oil terminals in the state based on a 1996 SOP.,This document, hereafter
referred to as the 2001 SOP,10 addresses issues and delineates monitoring frequencies and permit
limits for contaminants commonly found at these facilities.
Summary of Compliance Under 2001 SOP. Under the 2001 SOP, flow monitoring shall be
changed from "monthly" to "episodic" (Parts LA. ). This facility's effluent data shall be evaluated for
compliance with acute toxicity, TSS, and oil and grease (Parts I..B. through LD.). In place of EPA
Methods 624/625 monitoring requirements [eight (8) chlorophenols specified in the previous permit],
the permittee shall now monitor monthly for phenol only (Part I.E.), required for all WS (water
supply) waters, and for BTEX (Part III.A.). The Division shall also require monthly monitoring for
MTBE (2001 SOP Part 1.1.) considering WS waters. 10
Footnotes to the Effluent Limits and Monitoring Requirements page shall reflect no direct discharge
of tanks solids, tank bottom water, or the tank rag layer. Footnotes also stipulate no direct discharge
of hydrostatic test water if benzene and/or toluene concentrations exceed their respective water
quality standard (2001 SOP, Parts I.G. and 1.1).
Phenol — Monitoring and Limits Calculations. When combined with chlorine, phenol can cause
taste and odor (organoleptic) problems in drinking water, and can also result in the tainting of
consumptive fish tissues. Therefore, in accordance with SOP 2001, all dischargers to state water
supply (WS) waters shall conduct monthly effluent monitoring for total phenol. Moreover, if
analytical results suggest "reasonable potential," a phenol limit shall be included in the permit.10
A phenol limit magnitude depends on dilution. Ideally dilution would be calculated at 'the Lake
Brandt water plant intake where chlorine is introduced, but it is impractical at this time to measure
dilution under lake conditions at the intake. Therefore, the Division calculated flow at the assumed
Fact Sheet
Renewal -- MIDE"S NCO00367E
Pan

headwaters of this water supply. Secondly, the Division used 1 µg/L (the aesthetic limit for phenol) to
calculate a wasteload allocation in pounds per day (Ibs./day) at these headwaters. Finally, the
wasteload allocation was distributed equally between two bulk -storage facilities discharging within
this drainage as a permit limit, but only as each facility's data -set showed reasonable potential to
exceed the instream Water Quality Standard.
Currently two bulk storage facilities discharge to Horsepen Creek draining to Lake Brandt, the nearest
downstream WS intake waterbody. An EPA stream gauge (0209400000) located on Horsepen Creek
was assumed for the following calculations to approximate the headwaters of Lake Brandt. The
Division used published 30Q2 flows from this stream gauge to calculate a wasteload allocation for
phenol. The 30Q2 flow, not the 7Q10, was deemed appropriate because the standard for phenol is
aesthetic.
Flow Calculations:
Given: Flow (30Q2) — 3.3 cfs (USGS Gauging Station)
Drainage Area = 16.40 mil (USGS)
Yield — Flow (cfs)
Drainage Area (miZ)
= 3.3 cfs
16.40 miZ
0.20 cfs/miZ
Therefore:
Total Flow
Wasteload Calculation:
3.3 cfs x 0.001 mg/L x 8.34 =
1.55
Phenol Limit: Maximum reported flow
Yield x Total Drainage Area
0.20 cfs/miZ x 16.40 miZ
3.3 cfs
0.002 lbs./day distributed among two (2)
dischargers
0.002 lbs./day
2 dischargers
0.001 lbs./day per discharger
Limit = Allocated wasteload (Ibs./day)
8.34 Ibs./MG
0.001 x 1.0
8.34 0.1404
- .00085 mg/L
0.1404 MGD (January 2000)
x 1.0 mg/L
Highest Reported Flow (MGD)
0.85 pg/L (allowable)
Fact Sheet:
Renewal -- NVD S NCOM671
Paige 4

This calculated phenol level (0.85 µg/L) was used to establish "reasonable potential" (see RPA
spreadsheets). Because there is "reasonable potential" for phenol at Outfall 001, the Division has
included the permit limit per discharger as a.Monthly Average of 0.001 lbsJday.
Summary of Reasonable Potential Analysis (RPA).. The Division, conducted an EPA -mandated
RPA on Williams's reported data for BTEX, phenols, MTBE, and oil & grease. Results are
summarized as follows:
Maximum Predicted Allowable Reasonable Potential
Benzene 83.0 µg/L 1.19 µg/L Yes
Toluene not detected -- No
Ethyl Benzene
not detected
--
No
Xylene
8.8 µg/L
88.5 µg/L
No
Phenol
52.4 µg/L
0.85 µg/L
Yes
Oil and Grease
27.0 µg/L
30.0 µg/L .
No
MTBE
12,026 µg/L
70.0 µg/L (?)*
Yes (?)
* based on Class C waters -- Standard/criteria in progress for WS waters
PERMITTING APPROACH SUMMARY
Per DWQ/NPDES Unit's 2001 SOP:
• Incorporated BTEX monitoring, frequency Monthly per SOP 2001.
• Benzene remains in the permit; added limit due to "reasonable potential"
• Removed EPA Method 624 monitoring; "no parameters detected."
• Method EPA 625 monitoring remains at 2/Year per SOP 2001.
• Phenol remains in permit -- limit added as a Monthly Average in lbs./day; no change in Monthly
monitoring frequency.
• Per requirement for WS waters, added Monthly MTBE monitoring, no limit.
• Oil and Grease -- continue to monitor Monthly; no limit.
PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: September 21, 2001,
Permit Scheduled to Issue: November 16, 2001
Fact Slice(
Renewal -- NPDES NC0003671
Page 5

NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Joe Corporon at [phone] ext. 597.
NAME' DATE:
REFERENCES
1. 1999. NPDES Permit Application Short Form C, NPDES Permit NC0003671, Williams Terminals
Holdings, L.P.
2. 1996. NPDES Permit NC0003671, previously issued to Amoco Oil Company, now operated by
Williams Terminals Holdings, L.P, expired January 31, 2001 (extended by the Division to June
30 2001). Copies may be obtained through The Division of Water Quality, Central Files,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
3. 2000. Active NPDES Permits List, North Carolina Division of Water Quality, NPDES Unit, on the
web at http:/h2o.enr.state.nc.us/NPDES/NPDESweb.htmi.
4. 2000, Cape Fear Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water
Quality Section, July.
5. 2000. 303 d List of North Carolina Impaired Waters - Draft. North Carolina Division of Water
Quality, Water Quality Section. Copies may be obtained through the Planning Branch,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
6. 1989. NPDES Waste Load Allocation Work Sheet, NPDES Permit NC0003671, conducted for
Amoco Oil Company, now operated by Williams Terminals Holdings, L.P., modeled by
Permits and Engineering Unit, September 18.
7. 1996-2001. Discharge Monitoring Reports (DMR} for Effluent (DEM Form MR-1), initially submitted
by Amoco Oil Company, now operated by Williams Terminals Holdings, L.P., beginning
January 1996 through June 2001.
8. 2001 Personal Communication from Marcia Lieber (Point Source Compliance and Enforcement
Unit) to Joe Corporon (NPDES Unit), Apex Oil Company, Greensboro Terminal, NPDES
Permit NC0071463, DMR records, September 4.
9. 2001 Personal Communication from Jenny Rankin (WSRO) to Joe Corporon (NPDES Unit),
Greensboro oil -terminal site visits and records, August 22.
10. 200I Standard Operating Procedures -- Permit Requirements for Discharges from Oil and Petroleum
Storage Facilities (2001 SOP), NPDES Unit, Natalie Sierra, July 30.
1'UCL StieeL
Renewal -- INPI)FS NCO003671
Page 6

REGIONAL OFFICE COMMENTS
No 069cm fAk Rtr"
NAME: Rwvk,
DATE:
REGIONAL SUPERVISOR DATE:
NPDES SUPERVISOR: DATE:
fuel Slice[
Renewal -- NI'DI-S NC01 10,307
pnue7

.
State of North Carolina
�It-°�EIPaf�:D
r� � �4ot o� ���
Department of Environment
and Natural Resources
OCT 2 4 2001
Division of Water Quality
Michael F. Easley, Governor
'
Recdonal Office
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
September 19, 2001
MEMORANDUM
To: Lee.Spencer
NC DENR /iDEH�/ Regional Engineer
Regional Office
w- SA&-"
From: Joe Corporon
NPDES Unit
Subject: Review of Draft NPDES Permit NCO00367
Williams Terminals Holdings, Greensboro
Guliford County
onft4ftownF?W'A/ •
0
1111111111111110� IL
ODE R
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Please indicate below your agency's position or viewpoint on the draft permit and return this form by October 19,
2001. If you have any questions on the draft permit, please contact me at the telephone number or e-mail address
listed at the bottom of this page.
RESPONSE: (Check one)
2 oncur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits
ate met prior to discharge, and the discharge does not contravene the designated water quality standards.
F-1
Concurs with issuance of the above permit, provided the following conditions ate met:
S Z-!4 /- E b l�.t.J D T Al n - sf r co nJ S d.J D .
71 Opposes the issuance of the above permit, based on reasons stated below, or attached:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
VISIT Us ON THE INTERNET @ http://h2o,enr.state,nc.us/NPDES
Q�EIVE�
oc� or zoos
�Q jj�3y� 5483, a er�A
;ha
1 (fax) 919 733-0719
net

1223389 Date 09/20/2001 Time 11:39 AM
AU BLIC NOT"
STATE OF NORTH CA ROUM
ENVIRONMENTAL
COMM ISSIONN/�P�DES U NIT
161 l MA L S ERVIC E CENT ER
RA LEI CH, NC 276 99.1617
NOTIFICATION OF WENT TO
6SUEA NPOES
W ASTEW AT ER PERM R
0n the baslsaIInorough staI
review and application of
NC General Statute 143-21,
Pu by c law 92- 500 and other
lawful standards and regguia-
IIons, he North Carolina Envl-
room enlal Monagem ont Co m-
misslon proposes to Issue it
National Pollutant Discharge
Elimination System (NPDES)
wastewalt d isdtarge Perm gto
the person(s) listed below af.
feelm 45 days cam the pub-
Idi deleofthis noloe.
Wilen earn meals legerdijig the
proposed permit will be ac-
cepted untA 30 days after the
pub Esh date of this notl W, All
comments race ked prior to
Ihatdate ale considered Inthe
final deteminatWns remding
the poposed permit. The 04
recl or 0
1 the f3C Division of
Water Quality meydecide to
hold a public meeytin for the
proposedpermitshoup the
Division receke a significant
degne of public Inpmst.
Coppies of fie draft permitand
athe i su pPo ding Information
on fie used to delermk+e con.
ddions present In the draft
perm It am aval la bla upon re-
quest and payment of the
co sts of to pro du ction, Me it
Comm ents and /a 1 requests er
ialoan ation to the NC D i vl tf on
of WaterQualy at the above
address or call Ms. Christie
Jackson at(919) T33.5083,
extension 538,Please indude
the NPDES permit number
lattached)'n any communica-
ltion. Interested persons may
also visa Me DWslon of Water
Quality at 512 N. Salisbury
Street, Raleigh, NC
27604-1148 between the
hoursof8:DO a.m. and 5:00
P, m. to review intonation on
file.
NPDES Permit Number
000003671. WlkamsTerml•
pals Holdings, L:P. G eens-
Loro II Terminal, P. b. Box
3448, Tulsa OK 74101,
Greensboro, WC 2 74 19 has
on.pllcd for a peonit renew al
foa facility located in Gu1F
tad County dishagingtiealed
wastewater into a UT of
Namepen Creek in the Ca pit
Fear giver Basin, Currently
To tal S uspended So lids (TS S),
total p henols, and benzene are
walerq uaigr Invited. This dis-
charge may affect future allo-
cations in thisporpon of the
iamkng stream.
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Before the undersigned, a Notary Public of said Counry and State, duly coamlissioned, qualified and authorized by law to administer oaths,
persomlly appeared Ashley fiowles who being first duly sworn, deposed and says-
sT •>E oreilos cstrouas 1. Thm she is the Publishes Representative of the Greensboro News & loc. a co ratio m
ral�or�ws epresen Record, rpo >ti gaged in the publication of newsptglets
WMEI64tr�lly s u1L1 Imown m "News & Recard", published, issued and entered as second class mail in the City of GTccmboro in said County and State.
162e IML SEIMEECOLER
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Iran cow a WKESs s vet 2. 'That she is authorized to asakc this affidavit and sworn staternent; that the notice or other legal adve seen m a copy of which is attached
wuRw rrFA r4wsr hereto, was published in the News & Record on the above listed dates.
rr r i smo.i wwi 3. That the said newspaper (or newspapers) in which such no i advertisenra published was, m the time of
each and every such publication, a newspaper meeting all of c req ' is quali of Section 1- 7 of the General Statues of
'•""'��•'""r,,, �',ao ; North Carolina and was a qualified newspaper within the ing - 7 of a ew Worth orth Carolina.
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DENR / DWQ 1 NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No. NCO003671
INTRODUCTION
Williams Terminals Holdings, L.P. (formerly Williams Energy Ventures, Inc.), herein referred to as
Williams or the permittee, requires a National Pollutant Discharge Elimination System (NPDES)
permit to dispose treated wastewater to the surface waters of the state. The Permittee's 5-year NPDES
permit has expired and they have requested renewal from the Division of Water Quality (the
Division). This Fact Sheet summarizes background information and rationale used by the Division's
NPDES Unit to determine permit limits and conditions. This document also contains references to
information sources relevant to this permit renewal (superscripted numbers in order of appearance,
See References).
FACILITY RECORDS REVIEW
Facility Description. Williams (Table 1) operates the Williams Greensboro II Terminal (formerly the
Amoco Oil Company Greensboro Terminal), a bulk storage petroleum fuel distribution center in Guilford
County. Discharge from the facility consists of stormwater runoff controlled by a Water Pollution Control
System consisting of: loading rack drains; oil/water separator; waste holding tank with optional offsite
disposal; gravity -drained dike containment areas; and discharge control valves. Discharge travels to an
unnamed tributary (UT) of Horsepen Creek.
Table 1. Williams Terminals Holdings, L.P. — Water Pollution Control System
Facility Information
Ap2licant/Facility Name 1,2Williams
Terminals Holdings, L.P. / Greensboro II Terminal
Applicant Address '
P.O. Box 3448, Tulsa, Oklahoma 74101
Facility Address
7109 West Market Street, Greensboro, NC 27419
Permitted Flow (MGD)
Not limited
Type of Waste
Industrial runoff wastewater. SIC Code 5171
WW Code Prim. 37; Second. 39;
Facility/Permit Status ' '
Class I, Minor / Renewal
Drainage Basin / Count
Cape Fear / Guilford
Miscellaneous
Receiving Stream
UT of Horsepen Creek
Regional Office
Winston - Salem
Stream Classification
WS-III, NSW
State Grid / • I
USGS Too Quad
C 19 SW /
Guilford, NC
303(d) Listed?
Not listed
Permit Writer
Joe R. Cor oron
Subbasin 403-06-02
Date:
IOSe 01
Drainage Area (sq. mi.)
'
Lat. 36' 04' 52" Long. 79' 55' 56"
Summer 7Q10 (cfs)
0.0
Winter 7Q10 (cfs) "
0.0'
30Q2 (cfs) "
0.0
Average Flow (cfs) "
0.0
IWC (%) "
100
E`ao Sheet
Renewal -- NPDES Peunit NC0003671
/'age 1

This permit became effective June 1, 1996 (with an expiration date of January 31, 2001). To stagger
the renewal workload, the Division extended the expiration date to June 30, 200L
Waste Load Allocation (WLA). The Division conducted a WLA in August 1989 and developed
effluent limits and monitoring requirements based on an in -stream waste concentration (IWC) of
100% (zero -flow stream).6 The Division judges these limits and monitoring requirements to be
appropriate for this renewal with the exception of additions and deletions listed below (see
PERMITTING APPROACH SUMMARY).
Verifying Existing Stream Conditions. This facility discharges to a "zero -flow" stream, an
unnamed tributary (UT) Horsepen Creek. This creek is a Class WS-III NSW stream within the Cape
Fear River Basin. Horsepen Creek is not listed as an "impaired" waterbody [not 303(d) listed].s
COMPLIANCE REVIEW
Discharge Monitoring Reports (DMR) -- Effluent Data Review. DMRs were reviewed from
January 1996 through June 2001.' Discharges from Outfall 001 occurred episodically, zero to four
times per monthly — non -discharge months reported as "no flow." The permittee reported a maximum
discharge of 0.1404 MGD (June 2000). Therefore, this flow was used for reasonable potential
calculations (see below). Monitored parameters and RPA data review are summarized in Table 2:
Table 2. DMR / RPA -- Data Review Summary
Parameter
Samples
HItS P a�HiMean
RP
comments `/'Action
I
_...
Flow
68
--
0.1404
--
--
High flow used for RPA
MGD
Benzene
29
2
14 µg/L
1.02 µg/L
Yes
Previously monitored
Added permit limit
Toluene
29
0
--
--
No
Previously monitored
Ethyl Benzene
29
0
--
--
No
Previously monitored
Xylene
29
1
1.9
--
No
Previously monitored
Phenol
26
4
17 µglL
4.2 µglL
Yes
Previously monitored
Added Rermit Limit
TSS
34
31
55.3 m L
15.1 m L
--
Limit 45 m L (no change)
Oil & Grease
35
10
13 m L
4.19 m L
No
Maintain in permit — no limit
MTBE
18
14
1930 µg/L
283.7 µg/L
?
Criteria/limit in progress --
Warning to cover letter
TOX
6
--
--
--
--
All Pass except
(Acute)
(annual)
1999 @ 50%n only
EPA 624/625
8
0
--
--
--
Retain 625
Delete 624
r RP = "Reasonable Potential" to exceed receiving -stream Water Quality Standard.
fact Slicer
Renewal -- NUDES NIC:0003671
Pace 2

Based on the Division's our review of the DMRs, twice annual EPA 624/625 scans did not detect
semi -volatile or volatile organic compounds. Total suspended residue (TSR) results do not exceed
recommended levels. r.1VOLV�Z %.k nA(I 19
Notices of Violation (NOVs). OVs were issued to this facility during this permit cycle.8
Facility Inspections. This facility was last inspected in August 22, 1990 in connection with a
request to alter the discharge sampling point. Beginning with this permit cycle, the Winston-Salem
Regional Office has scheduled regular annual inspections for this and all bulk -petroleum storage
facilities in the Greensboro area.9
Whole Effluent Toxicity (WET) Test. The facility has passed its annual acute toxicity test for four
(4) years(1997 through year 2001), except in 1999 at 50% effluent concentration only.
Total Suspended Solids (TSS). Since 1996 only a single TSS level was reported in excess of the
Daily Maximum permit limit (February 2001, 55.3 mg/L). This minor violation was not assessed.
However, according to the Compliance and Enforcement Unit, future discharges in excess of 45 mg/L
will be assessed as a violation.8
PERMITTING STRATEGY
Revised Standard Operating Procedures (SOP). The Division has revised permitting strategies
and SOP for this and all oil terminals in the state based on a 1996 SOP. This document, hereafter
referred to as the 2001 SOP,10 addresses issues and delineates monitoring frequencies and permit
limits for contaminants commonly found at these facilities.
Summary of Compliance Under 2001 SOP. Under the 2001 SOP, flow monitoring shall be
changed from "monthly" to "episodic" (Parts L.A. ). This facility's effluent data shall be evaluated for
compliance with acute toxicity, TSS, and oil and grease (Parts L.B. through LD.). In place of EPA
Methods 624/625 monitoring requirements [eight (8) chlorophenols specified in the previous permit],
the permittee shall now monitor monthly for phenol only (Part LE.), required for all WS (water
supply) waters, and for BTEX (Part III.A.). The Division shall also require monthly monitoring for
MTBE (2001 SOP Part LL) considering WS waters. 10
Footnotes to the Effluent Limits and Monitoring Requirements page shall reflect no direct discharge
of tanks solids, tank bottom water, or the tank rag layer. Footnotes also stipulate no direct discharge
of hydrostatic test water if benzene and/or toluene concentrations exceed their respective water
quality standard (2001 SOP, Parts LG. and LH).
Phenol — Monitoring and Limits Calculations. When combined with chlorine, phenol can cause
taste and odor (organoteptic) problems in drinking water, and can also result in the tainting of
consumptive fish tissues. Therefore, in accordance with SOP 2001, all dischargers to state water
supply (WS) waters shall conduct monthly effluent monitoring for total phenol. Moreover, if
analytical results suggest "reasonable potential," a phenol limit shall be included in the permit.14
imit rpdgnitude depends on dilution. Ideally dilution would be calculated at the Lake
d water plant intake where chlorine is introduced, but it is impractical at this time to
i ution under lake conditions at the intake. Therefore, the Division calculated flow at the
headwaters of this water supply. Secondly, the Division used 1 µg/L (the aesthetic limit for
Rao Sheep
Kcncw3] -- NPI?ES NC0003671
Page 3

phenol) to calculate a wasteload allocation in pounds per day (tbs./day) at these headwaters. Finally,
the wasteload allocation was distributed equally among phenol dischargers as a permit limit, but only
as each facility's data -set showed reasonable potential to exceed the water quality stream standard. RWD �
Currently two (2) bulk storage facilities discharge to Horsepen Creek draining to Lake nsand, e J
nearest downstream WS intake waterbody. An EPA stream gauge (0209400000) located on Horsepen
Creek was assumed for the following calculations to approximate the headwaters of Lak ownsan .
The Division used published 30Q2 flows from this stream gauge to calculate a wasteload _aRbratkyrr
for phenol. The 30Q2 flow, not the 7Q10, was deemed appropriate because the standard for phenol is J
aesthetic.
Flow Calculations:
Given: Flow (30Q2) —
3.3 cfs (USGS Gauging Station)
Drainage Area =
16.40 mil (USGS)
Yield =
Flow (cfs)
Drainage Area (miZ)
3.3 cfs
16.40 mil
=
0.20 cfs/miZ
Therefore:
Total Flow =
Yield x Total Drainage Area
=
0.20 cfs/mil x 16.40 miZ
=
3.3 cfs
Wasteload Calculation:
3.3 cfs x 0.001 mg/L x 8.34 =
0.002 lbs./day distributed among two (2)
1.55
dischargers
=
0.002lbs./day
2 dischargers
=
0.001 lbsJday per discharger
Phenol Limit: Maximum reported flow =
Limit = Allocated wasteload Obs./day)
8.34 lbs./MG
0.001 x 1.0
8.34 0.1404
-- .00085 mg/L
0.85 µg/L (allowable)
0.1404 MGD (January 2000)
x 1.0 mg(L, —
Highest Reported Flow (MGD)
fact Sheet
Renewal -- NPDES NC[1[103671
Page 4

Using 0.001 lbs. per day as the wasteload allocation for phenol, does th
maximum predicted concentration exceed the allowable concentration { r the
calculated limit) for this facility?
ANSWER: YES.
Summary of Reasonable Potential Analysis (RPA). The Division conducted an EPA -mandated
RPA on Williams's reported data for BTEX, phenols, MTBE, and oil & grease. Results are P�-
summarized as follows: }�j►.-
Maximum Predicted Allowable Reasonable Potential
Benzene 83.0 µg/i. 1.19 µg/L Yes
Toluene not detected -- No
Ethyl Benzene not detected -- No
Xylene 8.8 µg/L 88.5 µg/L No
Phenol 52.4 upJL 0.85 ue/L Yes
Oil and Grease 27.0 µg/L 30.0 µg/L No
MTBE 12,026 µg/L 70.0 µg/L (?)* ?
* Standard/ priter in_progres-A --
�v5 end c�a �t--w�-- C, �S' C � �s `ma`s
Therefore, the allowable concentrations for benzene and phenol will be included as limits in the
permit, per the 2001 SOP.
Permitting Approach Summary
Per DWQ/NPDES Unit's 2001 SOP: 4IS �4(,
• Incorporated BTEX monitoring, frequency Monthly per SOP 2001.
• Benzene remains in the permit; added limit du�aramelers
reasonable potential"
• Removed EPA Method 624 monitoring; "no detected."
• Method EPA 625 monitoring remains at ear per SOP 2001.
• Phenol remains in permit — limit adde • no change in Monthly monitoring frequency
• Per requirement for WS waters, added onthly MTBE monitoring, no limit.
• Oil and Grease — continue to monitor Monthly; no limit.
PROPOSED SCHEDULE OF ISSUANCE 2
Draft Permit to Public Notice: September 1e2001.
Permit Scheduled to Issue: , 2001
o ((Q
Fact shcct
RenCW,'d -- NPDES NC0003671
1'ag . 5

NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Joe Corporon at [phone] ext. 597.
NAME
ENCES
TE: / / ✓fJ'�T
L 1999, NPDES Permit Application Short Form C, NPDES Permit NC0003671, Williams Terminals
Holdings, L.P.
2. 1996. NPDES Permit NC0003671, previously issued to Amoco Oil Company, now operated by
Williams Terminals Holdings, L.P, expired January 31, 2001 (extended by the Division to June
30 2001). Copies may be obtained through The Division of Water Quality, Central Files,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
3. 2000. Active NPDES Permits List, North Carolina Division of Water Quality, NPDES Unit, on the
web at http:/h2o.enr.state.ne.us/NPDES/NPDESweb.html.
4. 2000. Cape Fear Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water
Quality Section, July.
5. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of Water
Quality, Water Quality Section. Copies may be obtained through the Planning Branch,
Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina.
6. 1989. NPDES Waste Load Allocation Work Sheet, NPDES Permit „NC0003671, conducted for
Amoco Oil Company, now operated by Williams Terminals Holdings, L.P., modeled by
Permits and Engineering Unit, September 18.
7. 1996-2001. Discharge Monitoring Reports (DMR) for Effluent (DEM Form MR-1), initially submitted
by Amoco Oil Company, now operated by Williams Terminals Holdings, L.P., beginning
January 1996 through June 2001.
8. 2001 Personal Communication from Marcia Lieber (Point Source Compliance and Enforcement
Unit) to Joe Corporon (NPDES Unit), Apex Oil Company, Greensboro Terminal, NPDES
Permit NC0071463, DMR records, September 4.
9. 2001 Personal Communication from Jenny Rankin (WSRO) to Joe Corporon (NPDES Unit),
Greensboro oil -terminal site visits and records, August 22.
10. 2001 Standard Operating Procedures -- Permit Requirements for Discharges from Oil and Petroleum
Storage Facilities (2001 SOP), NPDES Unit, Natalie Sierra, July 30.
l aet Sheer
Rc!newal -- NPD17S NCO003071
Page 6

Whole Effluent Toxicity Testing Self -Monitoring Summary August 16, 2001
FACILITY REQUIREMENT
YEAR JAN
FEB
MAR
APR
MAY JUN JUL
AUG SEP OCT
NOV DEC
Alcaa4*5 Pam dr litre 901%
1997 Pass
—
Paw
—
— Pans) —
— Pass —
-- paws)
NC000430R1005 Begin:1211/1995 Frequmey:QPIF + Mar Jun Sep Dec NuoComp:Single
19M —
—
Fnes)s)
—
— pass(s) —
— Pass(s) —
— Pass
County. Stanly Region: MRO Suhbzdn: YADDB
1999 —
—
Pass
—
— Pass —
— Fad(s) �Ws)
.too Pass
PF: NA Special
20M „-
...
Pawls)
_
_ paws) —
— pass(s) —
— Pass(s)
7Q10:0.0 lWC(%...100 Order.
2001 —
—
Pans)
—
— Pcess(s)
Alcoa 011 Perm 24hr LC50 ac mortit cpis tthd (grab)
1997 —
—
—
>100(s)
— — —
— —
NC0004308/011 Begin: 12/1/1995 Frequency: 50WD/A NonCornp:
1998 —
—
—
-100(s)
— — —
— —
County: Stanly Region: MRO Subbasov YAD08
1999 —
`
PF: VAR spout
20M —-
7Q10: NA 1WC(5:):NA Order.
2W1 —
-»
-100
--
— —
Aleo&*12 Perm der l6n 16%
1997 —
—
pass
—
— Pans) —
— pass —
.- pass(s)
1
NC000430810l2 Begin 1211lI995 Frcgetcacy. Q P!F +Mar Jun Sep Dec No amp: Single
7998
--
Paa*5)
—
— Pans) —
— Pess(s) —
— Pass(s)
County- Sealy Rcgion: MRO Su66ain: YAD08
1999 —
—
Pa 0
—
-- Pass —
— Fal -24
24 Pass
PF: NA Specw
20M _
_
Paws)
_
_ Pass(s) —
— "a) —
— Pass(s)
7Q10: NA IWC(°/.)NA Order:
2001 —
—
Pass(sY
-^
- Pass(s)
Alcsa-013 Pam 24hr u plf Can: 901% Ohd
1997 —
Pass(s)
Pass(s)
Pass(s)
— Pass(s)
NC0004308/(713 Begin k21111995 Frequency: Q PIF + Mar Jem Sep Dee NonComp:5in&
19M —
—
Pa3a(s)
—
_
— Feasts)
_
= Pass(s)
Passes)
County. Stanly Region: MRO Subbasire YAD08
19N —
Pasa(s)
Pawls)
P
PF: NA Special
2� —
Pasa(sl
Pass(s) ...
— Pass(s —
pt
—
7010: NA IWC(-/.)NA Ord—
2001 ---
—
Pan(sl
—
— Pass(s)
Amend. Hon Corp. Perm 24hr LC50 ac monh epic fthd (grab)
NC0066711/001 Begin:911/1996 Frequency: A NmCamp:
1997 —
19M —
--
>100
—
—
—
— >100 —
— — —
— — —
— — —
—Is)
— —
Coma), New Hanover Region: WIRO Subbasin: CPF17
19N —
�100
--
—
-» -100
/1
PF: SPeeiri
2000 —
>100
—
—
— — —
— -- —
— —
[�/
7010: NA 1WC(%)NA ONrr.
2001 —
—
>100
--
— —
Amemda Hess-Gmmbaro Terminal Perm 24hr LC50 ac monit epis W (Grab)
1997 Ill
—
—
—
— — —
>100 — —
— —
NC0069256%1 Begia:611/1996 Froquency. A NonComp:
1998 >100
—
—
—
-- -- -»
— — —
— —
Camty: Guilford Region: WSRO Su66amc CPF08
190 '100
—
—
—
— — —
-» -- —
— —
PF: NA speew
2000 —
-100
—
—
— — —
— — —
-- —
7Q10:0.0 IWC(%)NA Order:
2001 —
�100
—
--
-- --
t Amerieao Treetzs.aier, Ine. Perm chr lim: 90%(grab)
1997 N
N
N
Fa8Fa3
Pus
—
— Paw —
—
Pas
—
NC0085928/001 Bcgm 1/1/1997 Frequency. Q P/F + Feb May Aug Nov
No-Comp:SirNk
19" —
FadP M
—
—
Pali
—
— Pass —
—
Fal
Pass
County: Mccldcnborg Rcpm: MRO Suhhastn: CTB34
1999 —
Paw
—
—
lam
Pam
— Paw —
—
Pass
Fail
PF: 0.05 Spew
20M <45,76.5t
Fad
Fad($)
H
—
—
H H —
—
H
—
7Q10:0.0 IWC(%)A00 Order:
2001 —
H
—
—
H
—
Amoeo Oil Co. Perm 24hr LC50 ac monh epis ftbd (Grab)
1997 >100
—
—
—
—
—
— — —
—
—
—
NC00036711001 Begim&1/1996 Frequency: A
Noacomp:
19M >100
—
—
—
—
—
-- -- »-
—
—
—
County: Guilford Rcgiwr: WSRO Subbasin: CPF02
1999 —
53.76
—
—
—
— — —
—
—
—
PF: NA Spww
2000 :•100
—
U-rA-Au
-
7Q10.0.0 IWC(y):1DO Order:
2001 —
—
—
—
—
r"
V�
(VZU2en7�&s
(r4
Aadreiea WWTP Perm chr]hn: 135E
T 1997 —
—
Pest
—
—
Pass
— — Pass
—
—
pass
NCO0208001001 Begev3/l/1998 Frequency: Q PIF + Mar Jun Scp Dec
+ NonComp:5ingle
1998 —
—
Pass
—
—
Pass
— — Paw
—
—
Pass
County. Cherokee Region: ARO Subhuin: 14IWO2
IN9 —
—
Pena
—
—
Pass
— -- Fad
>26
16.1
Pass
PF: 1.5 spww
2000 —
—
Pass
—
—
Pass
— — Fail
11.4
18.4
Pass
7QW 15.0 IWC('/.):13.0 Order:
2001 -26
152
NPJFad
�52
31.6
Pass
Anna Co. W WTP Perm chr hm: 36%
1997 Pass
—
--
Pus
---
—
pass _ _
Pass
_
—
NC00414uRW1 Begin:411/1999 Frequency: QP/F + Jan Apr Jul Oct
+ NonCarn+:Singk
1988 Late
Pass
—
Paso
—
—
Pass — —
Pass
—
—
Co nty: Anson Region: FRO Sts66ashn: YAD16
19" Pala
—
—
Pass
—
—
Pass — —
Pass
—
--
PF. 3.5 special
2000 Late
Pass
—
Pass
—
—
Pass — —
Pass
—
—
7Qt0:1755 IWC(•/.)2.99 order:
2001 Pass
—
—
pens
—
—
Ape; Oil Company PERM: 24HR LC50 AC MONIT EPIS FTHD (GRAB) 1997 — — — — — — — — — — — ---
NCO071463/001 Begin9/I11994 Frequency. 5OWD7A NoaComp: 19M — — — — — >100 -100 Oot >100 — — — —
Cuumy Guilford Region: WSRO Subhasm: CPF02 t999 — — — — — >100 — — — — —
PF: NA special 2000 — — — — �1()Dsig — — — — — — —
7Q1R 0.0 IWC(6):100 Order: 2001 — — — — — —
Y Pre 1997 Data Available
LEGEND:
PERM = Pemvt Rcclurremem LET - Administrative Letter - Target Frequency = Monitoring hcqumcy: Q- Quarterly: M- Monthly; BM- Bbnonthly; $A- Semi vounAly; A- Annually; OWD- Only when dischwgmg; D- Discoruinued monitanng rcquircmcni
Begin = First month required 7Q10 - Receiving stream low flow criterion (cfs) += quarterly manitrning increases to monthly upon failure or NR Mnnrbs that testing must occur - cc. Jan. Apr. Jul, Oct NonCourp = Current Compliance Requirement
PF = Pertained flow (MGD) I W CNh = Insaesat waste concentration PIF = Pass/Fail test AC - Acute CHR = Chronic
Data Notation: f - Fathead Mama—, ' - Caiodwhma sp„ my - Mysid shrimp; ChV - Chronic value; P - Mortality of sated percentage at lughm concentration: at - Performed by DW Q Aquatic Tax Unit; bt - Bad test
Reporting Notation: — - Data not required, NR - Not reported FacihTy Activity Status: I - Inactive, N - Newly Issued(To construct); H - Active bat not discharging; t-Mort data avaihble for month in question; - = ORC signauve needed
2

�s
Oa 96
MAL
Nu
a

VIA CERTIFIED MAIL
August 1, 2000
Mr. Charles Weaver
NC-DENR
Division of Water Quality
P.O. Box 29535
Raleigh, NC 27626-0535
Re: NPDEr Permit No: NCO003671 Renewal Application
Williants Energy Ventures' Greensboro ll Terminal
Dear K'1, . Vv'eaver,
W►ll�ams
ENERGY SERVICES
1717 South Boulder Avenue
P.O. Box 21628
Tulsa, Oklahoma 74121-1628
Wiiiiams Fnergy ontures (William;,) operates its Greensboro, li Terminal in accordance 'vith NPC)ES
Permit No. NC0003671, which expires on January 31, 2001. In accordance with, Per ll,it Condition II.13.10,
W liiam,, t • requesting renewal of this permit 180 days prior to its expiration. Enclosed please. find the
criy::;ai rigs oni: 1.) copy of NPDES Permit Application Short Foe m C.
vL'il:i.i�n:- �a,.quired this terminal from Amoco Oil Company in 1999, and subsequently. requested irensfe, of
NUPE:---; permit by submitting ar, NPDES Permit Name/Ownership Change Form on Marro, 19, 1999.
"I r, continues to discharge Ytydrostatk, test water and stormwater from both he.diked tank :storage
area track loading raci; area. The oill;vater separator is operated as well. The -only ;hange to
vvhich affects the NP.nES Permit and this F'erroit Renewal application- is, that MTRE. is not a
tho petroleurn products nranaged. As such. Williams requesis. that the. .3emi-gnnual
ic, s::,1a'P;r,ient for MTBE oe removed frorn the rev, Permit
;rlilliams ha:root detec+:ed any of the Method 624/625 constituents or xylenfj dosing thee. Bast
ual monitoring events. Williams also has a copy of one 'nf--Arnnco's s.errti•manliva!
'Jui;e '1996) with no detection of these constituents. Wiiliarro thee' fore.requests inat
monitoring be reduced to annual monitoring. Likewise, phenol has not been detected by
YR:iarns a, a concentration higher titan 0.015 rr,g/t_. Therefore, since phenol is included. in they Method
62: cons;itu,-,rt list which will be completed at least annually, Williams requests that the monthly phenol
m-onitorinq be; r moved.
lf" there are any questions, please contact Ms. Stacy Kisler at 918/574-8022 o! me at 918/574-8420
Sin;.erpiy,
ji"eve Torn —REM, C;HMM
r. Enmental Specialist
swm/sak
//gbW080100
Enclosure
c: Ruben Qualls, Greensboro it Terminal
Greensboro II Water Management File
S:IW EV_Terminals\Kisler\Greensboro{Wms.}IgbW080100.doc

Reasonable Potential Request Form
Facility Name
Williams Energy Services
(formerly AMOCO Oil Company)
NPDES Number
NCO003671
Permitted Flow Rate MGD
Not limited — intermittent
7Q10 Stream Flow cfs
&
Receiving Stream
UT of Horse en Creek
Stream Classification
WS-I1I NSW
30Q2 Stream Flow cfs
p
Average Stream Flow Qav cfs
Date Requested: August 1, 2001
Projected Date for Completion (add one week to date requested): August 15, 2001
Requested Parameters (Spell out):
Phenol
Benzene ✓
Xylene
MTBE (Methyl Tert Butyl Ether)
Ijo jPA (EPA 624 —list number of hits by parameter
L EPA 625 —list number of hits by parameter
z Oil and grease
fur c ,
00 / 1 � to 1
a
L

Division of Water Qaafity
MEMO From: ��� :7 �— - -. -- Date-, i24Q
To: _ M64 M Subject: _ LI efe96 a 3LlI
�I o DM R Far year Zoo I
Mn 200r is M F 55�
81j"7/Zoo
s
Ail,�Ia
NCDENR
North Carolina Department of Environment and Natural Resources
PO Box 29535, Raleigh, North Carolina 27626-0535 / Phone: [phone]

March 9, 2001
North Carolina Department of Environment and Natural Resources
Division of Water Quality-NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Notification of Change to Permit Holder
NPDES Permit No. NCO003671
Williams Energy Ventures' Greensboro II Terminal
ENERGY SERVICES
1717 South Boulder Avenue
PO. Box 21628
Tulsa, Oklahoma 74121-1628
Williams Energy Ventures, Inc., a Delaware corporation ("WEV Inc."), owns and operates a bulk
petroleum terminal located at 7109 W. Market St., Greensboro, NC 27419. The facility operates
in accordance with NPDES Permit No. NC0003671. WEV Inc. is converting itself from a
Delaware corporation to a Delaware limited partnership that will be known as Williams Terminals
Holdings, L.P., as allowed by Delaware general corporate law Section 266.
Under Delaware law, the conversion of WEV Inc. to Williams Terminals Holdings, L.P. does not
interrupt the existence of the legal "person" of WEV Inc. Rather, such legal "person" will continue
to exist in Williams Terminals Holdings, L.P. upon the conversion in the same fashion that a legal
entity that changes its name continues to exist as the same legal "person" under its new name.
The only change at the facility will be the name of the permitee; the operations and personnel will
not change. Accordingly, WEV Inc. requests that the above -referenced permit be amended to
reflect the conversion of WEV Inc. to Williams Terminals Holdings, L.P. If such conversion is
deemed to constitute a transfer of the above -referenced permit from WEV to Williams Terminals
Holdings L.P., then such a transfer is hereby requested.
As noted above, personnel will not change and therefore my signature below serves for both WEV
Inc. and Williams Terminals Holdings, L.P. The effective date of transfer was February 9, 2001.
Please find enclosed the completed NPDES Permit Name/Ownership Change Form. My
understanding is that this form and letter fulfills the notification requirement for transferring the
above -referenced permit, if required. Please call Stacy Kisler at 918/574-8022 or Steve Monn at
9181574-8420 if you need anything further.
Sincerely,
Rob Hawksworth
Director - Safety, Environmental and Training Services
Enclosure
cc: Greensboro II Water File
Water File/Greensboro It Terminal
S:\I ndependentTerminalslMLPtransferlGreensborolHNC-GrnsbAmocWater .doc

` State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RE50URCF-5
PERMIT NAME/OWNERSHIP CHANGE FORM
CURRENT PERMIT INFORMATION: I_
Permit Number: NC00 0 1 3 1 171
1. Permit holder's name:
2. Permit's signing offici
[ ' r ermkial
aI's name and title: O
(Person legally responsib a Tor permit)
EAVfeon03f�W !Ln t.ini�_'irkcs
(Title)
3. Mailing address: ( 5qqR City:TUja
State: zip Code:_11410Phone: 57�{- 2583
E-mail address: RCb . KAW�—S u�Or''rr,( (j)! 1 I I,0,1'pS • XM
NEW OWNERMAME INFORMATION:
1. This request for a name change is a result of:
a. Change in ownership of property/company
�b. Name change only
c. Other (please explain):
2. New owner's name (name to be put on permit):
I, I i. _ ^r I It ,,. _ I r. n 1 7-h' .-,— k
of
3. New owners or signing official's name and title:
(Person legally responsible for permit)
�irEhyj r(Tiflcn i rrtq � v1['P,�'
2 6 e �j
4. Mailing address:_ PO 6 ®x Jq'4 4 City: T j5a_ NI �
State: Zip Code: 411 Phone: ( q I ? ) J 7�7 ~- 2-0
E-mail address:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled 110% post -consumer paper

PERMIT NAME / OWNERSHIP CHANGE FORM
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF WATER QUALITY UNLESS
ALL OF THE APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a contract, deed, articles of
incorporation)
For changes of ownership, this form must be completed and signed by both the current permit
holder and the new owner of the facility.
For name change only, the current permit holder must complete and sign the Applicant's
Certification.
Current Permittee's Certification:
I, Fob ) KS IL , attest that this application for
name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: . GL� Date: 4 d
Applicant's Certification:
I, Rpb AnwKsLortf) , attest that this application for a
name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: A� Gc—.. Date: 3 &01
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING
INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DENR 1 DWQ
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 9-99

January 12, 1999
A. Preston Howard, Jr., P.E., Director
Division of Water Quality
North Carolina Department of Environment, Health and Natural Resources
P.O. Box 29535
Raleigh, North Carolina 27828-0535
Re: NPDES Permit No. NCO003671
1
Williams
2728 PRuton Road
St. Paul, Minnesota 55113
612/633-1555
012/633-5464 fax
Williams Energy Ventures completed a Purchase Agreement with Amoco for several pipeline
terminals on January 7, 1999, including the facility located at :
Amoco Oil Company
P.O. Box 18048
7109 West Market Street
Greensboro, Guilford County, North Carolina 27419
The Purchase Agreement provides for up to a 6-month transition period. Amoco will continue to
operate the facilities during the transition period. Williams Energy Ventures is seeking transfer of
the permits so that we can operate the facilities under the current permits.
Williams Energy Ventures staff are currently reviewing and evaluating existing permit documents.
Williams would like to submit appropriate documents to change the owner/operator on the above
referenced permit from Amoco to Williams Energy Ventures within 90 days.
Williams Energy Ventures Staff and/or our consultant may be contacting you for information to
make permit transfers.
Sincerely,
WILLIAMS ENERGY VENTURES
K 1�d'nMll r
Senior Environmental Specialist
cc: Jay Scrivner, Environmental Coordinator, Amoco, Atlanta, Georgia
Gave Kiliingsworih, Environmentai Coordinaior, Amoco, Fort Lauderdale, FL
1i7Dgn
JAN 2 5 1999
VVA I ER QUALITY
SECTION