NC0031038_PERMIT ISSUANCE_20060118

WDES DOCYNENT SCANNING COVER SHEET
NPDES Permit:
NC0031038
Document Type:
Permit Issuance �j
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment (67b)
Environmental Assessment (EA)
Permit
History
Document Date:
Januar 18, 2006
This document is printed on reuse paper - ignore any
content on the reverse Bide

L T-A
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director.
January 18, 2006
John W. Culbreath
Colonial Pipeline Company
P.O. Box 87
Paw Creek, North Carolina 28681
Subject: Issuance of NPDES Permit No. NC0031038
Charlotte Delivery Facility
7524 Kenstead Circle
Paw Creek, Mecklenburg County
Dear Mr. Culbreath:
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant
to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between North Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as
subsequently amended). This permit contains no significant changes from the draft permit sent
to you on December 1, 2005. .
If any parts, measurement frequencies or sampling requirementscontained in this permit are
unacceptable to you, you have the right to an adjudicatory hearing upon written request within thirty
(30) days following receipt of this letter. This request must be in the form of a written petition,
conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such
demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, the Coastal Area Management Act or any other
Federal or Local governmental permit that may be required. If you have any questions concerning this
permit, please contact Bob Guerra at telephone number [phone], extension 539.
Sincerely,
/ Oy� ran W. Klimek, P.E.
cc: Central Files
Mooresville Regional Office / Surface Water Protection
N( PDES.Un_itl
Aquatic Toxicology Unit
Mecklenburg County Water Quality Program
700 North Tryon Street, Suite 205
Charlotte, NC 28202
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One
1
512 N. Salisbury St., Raleigh, North Carolina 27604 NorthCaxrohna
Phone: [phone] FAX [phone]Internet: h2o.enr.state.nc.us ���'///�
An Equal Opportunity/Affirmative Action Employer — 50% RecycledKra"110% Post Consumer Paper

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Permit NCO031038
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
In compliance with the provision of North Carolina General Statute 143-2IS. 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,
Colonial Pipeline Company
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte Delivery Facility
7524 Kenstead Circle
Paw Creek, Mecklenburg County
to receiving waters designated as an unnamed tributary of Gum Branch within the
Catawba River Basin.
in accordance with effluent limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III and IV hereof.
This permit shall become effective March 1, 2006.
This permit and authorization to discharge shall expire at midnight on June 30, 2010.
Signed this day January 18, 2006.
�w
an W. Klimek, Director
ivision of Water Quality
By Authority of the Environmental Management Commission

ti Permit NCO031038
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge
are hereby revoked. As of this permit issuance, any previously issued permit bearing
this number is no longer effective. Therefore, the exclusive authority to operate and
discharge from this facility arises under the permit conditions, requirements, terms,
and provisions included herein.
Colonial Pipeline Company is hereby authorized to:
1. Continue discharging storm water and treated effluent from the existing water
pollution control system consisting of:
Stormwater runoff
Groundwater remediation discharge (treated)
• Surface tank and piping compounds with secondary containment
• Oil / water separator
Retention pond
[Reference Condition A. (5.) for Description of Outfalls]
The facility is located at the Charlotte Delivery Facility, 7524 Kenstead Circle, Paw
Creek, Mecklenburg County.
2. Discharge from said water pollution control system through Outfall 001 at a
specified location specified on the attached map into an unnamed tributary of
Gum Branch, classified as WS-IV waters in the Catawba.River Basin.

r
Colonial Pipeline Company Facility
Charlotte Delivery Facility Location
Latitude: 35° 17' 15" N State Grid: Mountain Island lake not to scale
Longitude: 88° 56' 05" W Permitted Flow: Espisodic
Receivine Stream: UT of Gum Branch Drainage Basin: Catawba River Basin NPDES Permit No. NCO031038
Stream Class: WS-W Sub -Basin: 03-08-34 North x4fVlnnl.n .!`.a..n.

Permit NCO031038
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until March 1, 2008, the
Permittee is authorized to discharge from Outfall 001. Such discharges shall be
limited and monitored by the Permittee as specified below:
EFFLUENT
CHARACT STICS
x
LIMIT;$
Monthly
Averase
tx
a MONIT,ORINGREQUIREMENTS-"1 ;:`
D'ally Maximum
Measure en
Fre uen
Sample
T e
Sa"'p
'
a Lrocation
Flow'
Episodic
1
Effluent
Total Suspended Solidsz
45.0 m /L
Monthly
Grab
Effluent
Oil and Grease2
Monthly
Grab
Effluent
Turbidi s
Quarterly
Grab
Effluent
zhmw
Quarterly
Grab
Effluent
Benzene
Monthly
Grab
Effluent
Toluene
Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
X lene
Monthly
Grab
Effluent
MTBE4
Monthly
Grab
Effluent
Acute To)dcity5
Annually
Grab
Effluent
Footnotes:
1. Flow shall be monitored with, each discharge event - During periods of no flow, the
Permittee shall submit a signed, monthly Discharge Monitoring Report (DMR) indicating "No
discharge." Flow may be monitored using any one of four methods:
a) measure flow continuously;
b) calculate flow (see Attachment A. (4.) Rational Equation) based on total rainfall
per unit area draining to the outfall; exclude built -upon areas (best method for
facilities with large runoff -collection ponds);
c). estimate flow at 20-minute intervals during the entire discharge event; or -
d) report flow based on discharge pump logs.
2. TSS/Oil and Grease - Where possible, the grab sample for oil and grease should be skimmed from the surface
of a quiescent (calm water) zone. - -
3. Turbidity - Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving stream
background turbidity exceeds 50 NTU, effluent shall not cause this background value to increase.
4. Facility shall submit a plan to the Division within 12 months of permit issuance detailing how MTBE levels will
be reduced at this facility.
5. Acute Toxicity (Fathead Minnow, 24-hour), annual samples to be collected concurrently with
BTEX samples [see Special Condition A. (3.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.
Direct discharge of tank solids, tank bottom water, or the rag layer is not permitted.
The permittee shall not discharge tank solids, tank bottom water, or the rag layer.
The permittee shall not discharge tank (or pipe) contents following hydrostatic testing unless
benzene concentration is less than 1.19 Ng/1 and toluene concentration is less than 11 pg/l.

PermitNCO031038
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on March 1, 2008 and lasting until expiration, the Permittee is authorized
to discharge from the following outfalls: 002, 003, 004, 005, 006, 0079 008, 009
and (MYO) - Manifold Yard Outfall. Such discharges shall be limited and monitored
by the Permittee as specified below:
R EFFLUENT+
CH RAC ERISTICS
. ' )'IMITSESM
onn"thly `ai y aximum
&—=,VMON-IT,-09!KGIREQ-UIREFAENT5WMWj
Measure ne't
" F_e uenc
Sa ple
T e
Sample L co adon
Flow' .
Episodic
1
Effluent
Total Suspended Solidsa
45.0 m /L
Monthly
Grab
Effluent
Oil and Grease'
Monthly
Grab
Effluent
Turbidi a
Quartedy
Grab
Effluent
Phenol
Monthly
Grab
Effluent
Benzene
1.19 u /L
Monthly
Grab
Effluent
Toluene
Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
X lene
Monthly
Grab
Effluent
MTBE
Monthly
Grab
Effluent
Acute Toxici °
Annually
Grab
Effluent
EPA Method 625
Semi-annually
Grab
Effluent
Footnotes:
1. Flow shall be monitored with each discharge event - During periods of no flow, the .
Permittee shall submit a signed, monthly Discharge Monitoring Report (DMR) indicating "No
discharge." Flow may be monitored using any one of four methods:
b) Measure flow continuously;
b) Calculate flow (see Attachment A. (4.) Rational Equation) based on total rainfall
per unit area draining to the outfall; exclude built -upon areas (best method for
facilities with large runoff -collection ponds);
c). estimate flow at 20-minute intervals during the entire discharge event; or
e) report flow based on discharge pump logs.
2. TSS/Oil and Grease - Where possible, the grab sample for oil and grease should be skimmed from the surface
of a quiescent (calm water) zone.
3. Turbidity - Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving stream
background turbidity exceeds 50 NTU, effluent shall not cause this background value to increase.
4. Acute Toxicity (Fathead Minnow, 24-hour), annual samples to be collected concurrently with
BTEX samples [see Special Condition A. (3.)[.
There shall be no discharge of floating solids or foam visible in other than trace amounts.
Direct discharge of tank solids, tank bottom water, or the rag layer is not permitted.
The permittee shall not discharge tank solids, tank bottom water, or the rag layer.
The permittee shall not discharge tank (or pipe) contents following hydrostatic testing unless
benzene concentration is less than 1.19 pg/L and tolueneconcentration is less than 11 pg/L.

Permit NCO031038
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 EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity. of
Effluents to Freshwater and Marine Organisms." The monitoring shallbe 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 Section
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.

Permit NCO031038
A. (4.) FLOW MEASUREMENT RATIONAL
The Rational Equation: Q=KuCIA, where:
Q =
now (peak flow rate (cfs or m3/sec)
Ku =
units conversation factor = 1.008 for U.S. standard
units (usually ignored because it is so close to 1), or
0.278 for SI units
C =
dimensionless runoff coefficient for the watershed,
loosely defined as the ratio of runoff to rainfall
I =
intensity of rainfall taken from the intensity -duration -
frequency curves for the specified design return period
at the time of concentration, tc (in/h or mm/h). tc =
time of concentration (time after the beginning of
rainfall excess when all portions of the drainage basin
are contributing simultaneously to flow at the outlet).
A =
area of tributary watershed (acres or km2)
The rational equation is used to calculate the runoff from a region, given:
• the runoff coefficient which accounts for infiltration
and other potential losses in the region,
• the rainfall intensity to the region,
• the time it takes for runoff to travel from the region's
upper reaches to its outlet, and the region's drainage
area.

Permit NCO031038
A. (5.) OUTFALLS DESCRIPTION AND LOCATION
The following narrative is to clarify which outfalls drains stormwater from
which areas of the facility:
■ Outfall001
o Drains the pond area at the Southern end of the facility.
o Accumulation point for all waters of the state flowing through and
impacted by stormwater run-on / run-off from facility.
■ Outfall002
o Stormwater associated .with tanks containing Gasoline product.
■ Outfall003
o Stormwater associated withtanks containing Gasoline product.
■ Outfall004
o Stormwater associated with tanks containing Gasoline product.
■ Outfall005
o Stormwater associated with tanks containing Gasoline product.
■ Outfall006
o Stormwater associated with tanks containing Gasoline product.
■ Outfall007
o Stormwater associated with tanks containing Distillate product.
■ Outfall008
o Stormwater associated with tanks containing Distillate product.
■ Outfall009
o Stormwater associated with tanks containing Distillate product.
■ Outfall010
o Under -drain network collects and conveys stormwater contacting piping,
control valves, and related appurtenances in the area known as the
Manifold Yard and stormwater run-on and perched groundwater from
the hillsides adjacent to the Manifold Yard.
BMP = Passive baffle -type oil -water separator.

PermitNCO031038
s
A. (6.) SPECIAL SAMPLING CONDITIONS
1. Facility is required to sample from. Outfall 001(Pond discharge) until
February 1, 2008 according to A. (1).
2. Facility is required to sample from outfalls listed in A. (2.) beginning on
February 1, 2008 and discontinue sampling from Outfall 001(Pond
discharge).
3. Facility may request alternative sampling plan with combined sampling
points prior to February 1, 2008 requirement in A. (2). This request must
be in writing with supporting documentation as to how this combination of
sampling points will be accomplished.
4. Facility may request reduced sampling parameters reflected in A. (2). This
request must be in writing with a sufficient number of laboratory sampling
results to conduct a Reasonable Potential Analysis (RPA). This RPA will
determine if any pollutants can/will be removed from the sampling
requirement listed in A. (2).

The Knight Publishing Co., Inc.
Charlotte, NC
North Carolina ) so Affidavit of Publication
Mecklenburg County)
THE CHARLOTTE OBSERVER
NCDENR/DNO/NPDES
CAROLYN BRYANT -
1617 MAIL SERVICE CTR
RALEIGH NC 27699-1617
REFERENCE: 30045571
5536074 NPDES
Before the undersigned, a Notary Public of said
Canty and State, duly authorized to administer
oaths affirmations, eta., personally appeared,
being duly sworn or affirmed according to law,
doth depose and say that he/she is a
representative of the Knight Publishing Company a
corporation organized and doing business under thei
Laws of the State of Delaware, and publishing a
newspaper known as The Charlotte Observer in the
city of Charlotte, County of Mecklenburg and State
of North Carolina and that as such he/she is
familiar with the books, records, files and
business of said Corporation and by reference to
the files of said publication
the attached advertisement was inserted. The
following is correctly copied from the books and
files of the aforesaid Corporation and
Publication. I
PUBLISHED ON: 09/17
AD SPACE: 120 LINE
FILED ON: .09/20/05
NAME: C TITLE:
DATE: 100a
In Testimony Nhe f I have hereunto set my hand and affixed ny seal, the
day and year afore ari .A n Commission Expires May 17, 2006
e
K P*t
Notary //�My Commission Expires: _/_/

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—•••—•••— POND AND STREAM
- - - - - - - DIKE WALLS AND
UNIMPROVED ROADS
IMPROVED ROADS
DRAIN .VALVES
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(1) TANK SECONDARY CONTAINMENT AREA (TSCA) REFERENCE NUMBER �Jv
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OUTFALL 001

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO031038
Facility`Information
Applicant/Facility Name:
Colonial Pipeline Company /. Charlotte Delivery Facility
Applicant Address:
P.O. Box 1624 Alpharetta, Georgia 30009
Facility Address:
7524 Kenstead Circle, Paw Creek, North Carolina 281320
Facility Owner:
Steven E. Jacobs
Facility Contact:
John W. Culbreath, Senior Environmental Technician
Permitted Flow
Not limited
Type of Waste/Active
Permits:
100% Stormwater through oil/water separator
SIC Code 4613
NPDES NCG510207 - GWR
RCRA EPA ID# NCD000623074
ND W00004751 - Spray Irrigation of Tank Bottom Water
NESHAPS Mecklenburg County Air 99-184-627
Facility/Permit Status:
Active; Renewal
-Drainage Basin/County:
Catawba/Mecklenburg
Receiving Stream:
UT to Paw Creek
Regional Office:
Mooresville
Stream Classification:
WS-lv
State Grid / USGS
Quad:
F15SW/Mountain
Island Lake
303 d Listed?
No
Permit Writer:
Bob Guerra
'Subbasin:
03-08-34
Date:
12/16/05
Drainage Area (mil :
<0.01
AOW
Lat. 350 16' 34" N Long. 80' 55'45" W
Summer 7Q10 cfs)
0
Winter 7 , 10 cfs :
0
30 2 (cfs)
0
Average Flow cfs :
0
IWC (%):
100%
BACKGROUND
Bulk storage facilities typically retain and manage stormwater behind secondary -containment dykes. Dyked
areas are designed with sufficient volume to confine product in the event of a surface tank failure.
Stormwater, often comprising several storm events, is held behind these dykes in proximity to the tanks and
appurtenant piping. The permittee holds this stormwater for controlled, monitored release. This facility
does not have a truck -loading terminal but distributes fuel to other distributors through manifold piping.
Effluent water discharged from the outfall consists of the following types of discharger:
1. Manifold yard stormwater, which is collected by the underground drainage system and is routed to
the facility oil/water separator for treatment prior to its release to the facility retention pond (outfall
001).
2. Washdown slab water is an intermittent discharge generated when internal cleaning or inspection
equipment is removed from the facility scraper traps and when equipment is cleaned with water to
remove any refined petroleum products. This wastewater is piped to facility oil/water separator for
treatment prior to its release to the facility retention pond (outfall 001).
3. Prover loop calibration water is an intermittent discharge that is generated during the calibration of
the facility prover loops, which are used to confirm meter accuracy. This wastewater is routed to the
facility oil/water separator for treatment prior to its release to the facility retention pond (outfall 001).
4. Tank Bottom Water is water that accumulates in the petroleum storage tanks and is manually
removed via the facility's "stingwater" system. The stingwater system consists of a piping network
attached to the low point of each individual tank line. The water/product mixture is piped to the
primary oil/water separator where the bulk of the separated product is recovered. The remaining
Fact Sheet
NPDES NCO0312038
Renewal
Page 1

petroleum contact water is pumped into one of two available phase separation tanks. The water from
the phase separation tanks can be handled two different ways.
■ It is processed on site and disposed of under the facility spray irrigation permit (ND
W00004751) or
■ It is off-loaded and shipped to one of Colonials approved reclamation facilities.
This Subbasin is in the Southern Outer Piedmont ecoreaion and contains the Sugar Creek watershed, a
portion of Lake Wylie and much of the City of Charlotte metropolitan area. This is the most heavily
urbanized region of the basin and the state, and its population is expected to increase over 30% by 2010.
Only 52% of the Subbasin is forested - the smallest percent of any of the basins. Use support ratings in
Subbasin 03-08-34 were assigned for aquatic life, fish consumption, recreation and water supply. All water
supply waters are Supporting on an evaluated basis based on reports from DEH regional water treatment
plant consultants.
FILE REVIEW
Notices of Violation (NOVs)
NOV-2004-LV-0005 was issued on January 8, 2004 for a Benzene limit violation in April 2003. The
Mecklenburg Regional Office issued a "Notice of Deficiency" on June 3, 2004 for failure to report Aquatic
Toxicity testing on the May 2003 Discharge Monitoring Report (DMR). The facility submitted an amended
DMR with the Aquatic Toxicity results.
Whole Effluent Toxicity (WET) Test.
Division records indicate that this facility has passed its annual acute toxicity test (>100) for four years,
from 2000 through year 2004.
DMR Review
DMRs were reviewed from February 2003 through April 2005. Discharges from 001 were consistent with
only November 2004 being reported as "No Discharge". The monthly flow rate was 0.0661 MGD. The highest
daily flow occurred in September 2004 at 0.204609. Total suspended solids during this time averaged 4.61
mg/L with a maximum of 8.0 mg/L. The average oil and grease concentration was <5.0 mg/L with a
maximum concentration of <5.0 mg/L. The average Turbidity during this time averaged 8.94 ntu with a high
value of 33 ntu. The facility has passed its acute toxicity test during this permitting cycle.
SITE INSPECTIONS
Facility Inspection
Correspondence files from 2001-2005 were reviewed. On 2-28-05 Mecklenburg Regional office conducted a
site inspection and submitted a NPDES Staff Report and Recommendation report, which indicated that the
facility has been in compliance during these inspections. The MRO staff report also stated that it was
deferring action relating to the sampling site request from the permittee to the NPDES Unit.
On June 3, 2005, the Mecklenburg County Water Quality Program conducted a site inspection and reported
that the facility appeared well operated and maintained and that the facility and outfall are visually
inspected daily by facility staff to ensure proper operation and safety.
Fact Sheet
NPDES NCO0312038
Renewal
Page 2

REASONABLE POTENTIAL ANALYSIS:
A review of the last three years of semi-annual 625 test data indicated that all parameters were at 'Non -
Detect" limits. As a result of this review no RPA was run and the Semi-annual Monitoring Requirement is
being removed from the permit during this renewal cycle.
An RPA was run for BTEX, Phenols and MTBE.
Colonial Pipeline Company -Charlotte Delivery Facility -Paw Creek
NCO031038 Qw = MGD
Time Period
0
Qw (MGD)
0
WWTP Class
Class 1
7010S (cfs)
0
IWC (9/) @
N/A
7Q10S
7010W(cfs)
0
Qu 7Q10W
N/A
30Q2 (cfs)
0
Q 30Q2
N/A
Avg. Stream
0
Q QA
N/A
Flow, QA (cfs)
Rec'ving Stream
UT of Gum Creek
Stream Class
Ws -IV
Outfall MYO
PARAMETER
TYPE
STANDARDS& CRITERIA (2)
OL
jUnitsl
RP RESULTS
RECOMMENDED ACTION
(1)
NChmnic / FAV
UNITS
n Allowable Cw
Acute
Det
cute:
N/A
Remove Limit / Monthly Monitoring
Phenols
C
0.17
ug/I
24
0
Chronic:
#DIV/01t
Requirement
cute:
N/A
elate Limit / Continue Monthly
Benzene
C
1.2
ug/I
24
0
Chronic:
#DIV/01
Monitoring
Acute:
N/A
elate Limit / Continue Monthly
Toluene
NC
11
ug/I
24
1
Chronic:
#DIV/0!
Monitoring
Ethyl
cute:
N/A
Delete Limit / Continue Monthly
Benzene
NC
524
ug/I
24
1
hronic:
#DIV/01
Monitoring
Xylene
NC
88.5
ug/I
25
1
cute:
N/A
Delete Limit /Continue Monthly
Chronic:
#DIV/01
Monitoring
ute:
N/1AContinue
Monthly Monitoring I Submi
MTBE
C
24
5
Fhronic:
an Action Plan within 12 months fron
DI
permit effective date
Fact Sheet
NPDES NCO0312038
Renewal
Page 3

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Date
May-03
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May-04
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Date
May-03
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Mar-05
Apr-2005
BDL=1/2DL
0.1. 0.0
0.1 0.0
0.1 0.0
0.1 0.0
0.11 0.0
0.1' 0.0
0.11 0.0
0.1i 0.0
0.11 0.0
0.11 0.0
0.1` 0.0
0.1 0.0
0.1 0.0
0.1! 0.0
0.P 0.0
0.1i 0.0
0.11 0.0
0.11 0.0
0.1I 0.0
0.1; 0.0
0.1! 0.0
0.11 0.0
0.1t 0.0
0.11 0.0
Data
Results
Std Dev.
1.4379
Mean
1.0922
C.V.
1.3165
n
150
Mull Factor =
N/A
Max. Value
11.0
Max. Fred Cw
N/A
Benzene
BDL=1/2DL
0.5
0.5
0.5
.. 1.
j 0.5
0.5
............1.
i 0.5
-1,
f 0.5
......1
I 0.5
,. ,... 1.
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
1
0.5
Fact Sheet
NPDES NC00312038
Renewal
Page 4
Units
Results
Std Dev.
1.4379
Mean
1.0922
C.V.
1.3165
n
125
Mull Factor = N/A
Max. Value 11.0
Max. Fred Cw N/A
ug/I
ug/I
Units
ugli
ug/I

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
4
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Date
May-03
Jun-03
Jul-03
Aug-03
Sep-03
Oct-03
Nov-05
Dec-03
Jan-04
Feb-04
Mar-04
Apr-04
May-04
Jun-04
Jul-04
Aug-04
Sep-04
Oct-04
Nov-04
Dec-04
Jan-05
Feb-05
Mar-05
Apr-2005
Date
May-03
Jun-03
Jul-03
Aug-03
Sep-03
Oct-03
Nov-05
Dec-03
Jan-04
Feb-04
Mar-04
Apr-04
May-04
Jun-04
Jul-04
Aug-04
Sep-04
Oct-04
Nov-04
Deo04
Jan-05
Feb-05
Mar-05
Apr-2005
Data
BDL=1/2DL Results
1
0.5
Sid Dev.
1
0.5
Mean
1
0.5
C.V.
- 1
0.5
n
1
0.5
- 1
0.5
Mult Factor =
1
0.5
Max. Value
1
0.5
Max. Pred Cw
1 "
0.50
1
0.50
.. 1
0.50
`1
0.50
1'
0.50
1
0.50
/
,."2 i..
2.00
0.50
--- 1
0.50
1
0.50
1�
0.50
1
0.50
1.,,01 `�,:'.i
0.50
`,
1 �,
0.50
0.50
0,50
Ethyl Benzene
BDL=1/2DL
Results
1 Tz ��,`.� ;
0.5
Std Dev.
1 'ra,c'J
0.5
Mean
nil
0.5
C.V.
a,,
11 1
0.5
n
'1
0.5
1 '
0.5
Mull Factor =
L�..r
0.5
Max. Value
1. 1'>
0.5
Max. Fred Cw
1 �.;i, :.
0.5
1
0.5
1 =`
0.5
1 '� I
0.5
1
0.5
1
0.5
1
0.5 /
1.2
1.2
1
0.5
1
0.5
1
0.5
1
0.5
1' `
0.5
1
0.5
1
0.5
1
0.5
Units
1.4379
1.0922
1.3165
100
N/A
11.0
ug/I
N/A
ug/I
Units
1.4379
1.0922
1.3165
75
N/A
11.0
ugh
N/A
ug/I
Fact Sheet
NPDES NC00312038
Renewal
Page 5

5
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
6 MTBE
1
2
3
4
5
6
7
8
9
,g
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Date
May-03
Jun-03
Jul-03
Aug-03
Sep-03
Oct-03
Nov-05
Dec-03
Jan-04
Feb-04
Mar-04
Apr-04
May-04
Jun-04
Jul-04
Aug-04
Sep-04
Oct-04
Nov-04
Dec-04
Jan-05
Feb-05
Mar-05
Apr-2005
Date
May-03
Jun-03
Jul-03
Aug-03
Sep-03
Oct-03
Nov-05
Dec-03
Jan-04
Feb-04
Mar-04
Apr-04
May-04
Jun-04
Jul-04
Aug-04
Sep-04
Oct-04
Nov-04
Dec-04
Jan-05
Feb-05
Mar-05
Apr-2005
BDL=1/2DL Results
3
1.5
Std Dev.
3
'.. 1.5
Mean
3
1.5
C.V.
3 -
1.5
n
3
1.5
3
1.5
Mult Factor =
3
1.5
Max. Value
3
1.5
Max. Pred Cw
3
1.5
3
1.5
3
1.5
3
1.5
3
1.5
3
1.5
3
1.5
4
3.7
3
1.5
3
1.5
3
1.5
3
1.5
3
1.5
3
1.5
3
1.5
3
1.5
BDL=II2DL
Results
5
i
2.5
Sld Dev.
5
2.5
Mean
5
2.5
C.V.
5
2.5
n
5
2.5
5
2.5
Mult Factor=
5
2.5
Max. Value
5
2.5
Max. Fred Cw
5
2.500
/
L
11
11.000
5
2.500
5
2.500
5
2.500
5
2.5
5
2.5
5
2.5
5
2.5
5
2.5
5
2.5
5.6
5.6
6.2
6.2
5.7
5.7
7
7.3
5
2.5
Units
1.4379
1.0922
1.3165
50
N/A
11.0
ugA
N/A
ugA
Units
1.4379
1.0922
1.3165
25
N/A
11.0
0
N/A
0
Fact Sheet
NPDES N000312038
Renewal
Page 6

Revised Standard Operating Procedures.
The Division of Water Quality has revised the permitting strategies and Standard Operating
Procedures (SOP) for this and all oil terminals in the state. The 2001 SOP has been updated and is now titled
the `2005 Permitting Strategy Addendum NPDES Permit Requirements for Discharges from Petroleum Bulk -
Storage Surface Storage Greater than One Million Gallons." (9-9-05). This document is based upon 1996 and
2001 Permit Requirements from Oil and Petroleum Storage Facilities. It delineates monitoring frequencies and
permitting limits for contaminants commonly found at these sites.
2005 NPDES Permitting Requirements for Petroleum Bulk Storage Greater than One
Million Gallons OR Terminal SOP:
The following Pollutants of Concern were reviewed with subsequent changes made from previous the
previous 2001 Permit Requirements from Oil and Petroleum Storage Facilities:
1. Flow -Discharge Rate and Duration
2. Acute toxicity
3. TSS
4. Oil and grease
5. BTEX
6. Napthalene (for Diesel)
7. EPA Methods 624/635 (as applicable)
8. Tank Solids, Tank Bottom Water and Rag Later
9. Hydrostatic Tank testing
10. MTBE
11. Benzene in Water Supply
12. Phenol in Water Supply
13. Turbidity Monitoring (Paw Creek Terminals).
SUMMARY OF PROPOSED CHANGES
1. Effluent Limitations and Monitoring Requirement
1. Setting a deadline for cessation of sampling from Outfall to two years after permit
issuance.
2. Addition of permit condition A (2):
i. Beginning on February 1, 2008 and lasting until expiration, the Permittee is
authorized to discharge from the following outfalls: Tank Storage Containment Area
(TSCA)-001, TSCA-002, TSCA-003, TSCA-004A, TSCA-00413, TSCA-005, TSCA-006,
TSCA-007 and Manifold Yard Outfall -MYO.
3. Addition of permit condition A (5):
i. Narrative to clarify which outfalls drain stormwater from which areas of the facility.
4. Addition of permit condition A (6):
i. Special sampling conditions
2. Deletion of EPA Method 625 monitoring requirement.
1. The twice -annual EPA 625 scans since 2000 reported non -detect results for napthalene and
other middle distillate compound and semi -volatile or volatile organic compound. Because of
nine (9) non -detect sampling events the semi-annual monitoring requirement using EPA
Method 625 has been deleted from this permit renewal.
Changes required by new 2005 SOP Permitting Requirements for Petroleum Bulk Storage Greater than
One Million Gallons
1. Removal of Phenols Limit and change monitoring requirement to Quarterly.
2. Removal of Benzene Limit with monthly monitoring requirement.
3. MTBE monitoring has been included in this permit with a monthly monitoring frequency.
4. Addition of an action plan for its elimination to be submitted 12 months from permit
issuance date.
Fact Sheet
NPDES NCO0312038
Renewal
Page 7

PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: September 14, 2005
Permit Scheduled to Issue: February 1, 2006 (est)
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact Bob
Guerra at [phone] ext. 539.
REGIONAL OFFICE COMMENTS
NAME: DATE:
SUPERVISOR: DATE:
Fact Sheet
NPDES NCO0312038
Renewal
Page 8

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John W. Culbreath
Senior Environmental Technician
Southeast District
November 1, 2005
Mr. Bob Guerra
NCDENR / Water Quality /NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Colonial Pipeline Company
_ Office = 704-399-5259
x:- 704-399 9029
Iis � �, � ! �.
I NOV - 7 2005 IIII��
_--- ---�
DENR - Yi;tTER LiTY
r(,INT SOURCE BRANCH
Re: Draft NPDES Permit No. NC0031038 — Comments
Colonial Pipeline Company
Mecklenburg County
Dear Mr. Guerra:
I have reviewed the draft permit for the facility referenced above. Based on the revisions that have
been made with respect to the current permit, Colonial is willing to accept the draft permit and continue
sampling Outfall 001 as the point of compliance. Previous correspondences were sent during the
renewal process requesting representative outfall status and the elimination of Outfall 001 as a point of
compliance and would still be the preferred option. Analytical data from each outfall was submitted
with the permit application. Please review the attached facility map. The preferred option sampling
requirements would include three outfalls; TSCA - 6, TSCA — 2, and the Manifold Yard Ouffall (MYO).
TSCA-6 would be representative of distillate storage areas which flow to the east channel. TSCA-2
would be representative of gasoline storage areas that discharge to the west channel. The MYO would
be representative of runoff from the piping manifold area. Please advise me, in writing, as to what
additional measures need to be taken to implement this option.
If you have any questions or need any additional information I can be reached at 704-399-5259.
Very truly yours,
ohn W. Culbreath
Senior Environmental Technician
Enclosure
7524 Kenstead Circle Paw Creek, NC 28130
P.O. Box 87 Paw Creek, NC 28130

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Alan W. Klimek, P.E., Director
MEMORANDUM
To: Brit Setzer
From:
Subject:
September 14, 2005
NC DENR I DEH I Regional Engineer
Mooresville Regional Office
Robert Guerra
NPDES Unit
1, •a
-V
NCDENR
NORTH CAROUNA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Review of Draft NPDES Permit NCO031038
Paw Creek Water System / Colonial Pipeline Company WWTP
Mecklenburg County
RECEIVED
1." oresvilln R:.lrnel f
SEP I &
r:i.e.i71 S
Please indicate below your agency's position or viewpoint on the draft permit and return this form by March 16, 2005.
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. il
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits
are met prior to discharge, and the discharge does not contravene the designated water quality standards.
❑ Concurs with issuance of the above permit, provided the following conditions are met:
❑ Opposes the issuance of the above permit, based on reasons stated below, or attached:
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 539 (fax) 919 733-0719
VISIT USONTHEINTERNET@http:llh2o.encstate.nc.us/NPDES [e-mail]

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Colonial Pipeline Company
John W. Culbreath
Senior Environmental Technician
Southeast District
Iuly.j.9;a2005
Mr. Bob Guerra
NCDENR / Water Quality /NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit No. NCO031038 - Renewal Supplement
Colonial Pipeline Company
Mecklenburg County
Dear Mr. Guerra:
Office - 704-399-5259
Fax - 704-399 9029
In the renewal submittal letter dated December 22, 2004 for the above referenced permit, the request
was made that your department consider representative outfall status for the Colonial facility. A table
of analytical data compiled from sample results of each outfall was provided in the original renewal
submittal. The data collection began in September 2004 with intentions of collecting at least 12
samples from each outfall prior to the renewal date of December 31, 2005. Due to below average
rainfall events and unforeseen circumstances, only 9 samples were collected for 5 ouffalls, 8 for one
outfall, and 7 for two outfalls.CColonial'understands.ttib'oreference of -the depaitinentto:have,Y12 sets•of
Cdata—_but requeststhat-representative-outfall.status>still, be,considered based on the data that was
to_ btained.
ColonialF,also requests permissiomto:.modify,or eliminate the, Sampling.and:'Analysis Plan: that -was,.
developed for the site. <The.Plan- identified-a,sampling schedule that, was followed in the.collectionr of
representative outfaffstatus data If a plan is still necessary, the Plan would.be.revised to reflect actual
requireriients.of the new permit Colonial also requests that the new permit require only one acute
toxicity,sample annually per ouffall.
Wfinal:request would be to allow flow rates from each outfall to be calculated based on total rainfall per
area draining to the outfall.
Thank you for considering these requests. If you have any questions or need any additional
information I can be reached at 704-399-5259.
Very truly yours,
John W. Culbreath
Senior Environmental Technician
JUL 2 1 2005 D
DENR - WATER QUALITY
POINT SOURCE BRANCH
7524 Kenstead Circle Paw Creek, NC 28130
P.O. Box 87 Paw Creek, NC 2813.0 .n

SOC PRIORITY PROJECT: Yes No X
f
To: Permits and Engineering Unit
Water Quality Section
Attention: Carolyn Bryant
Date: March 23, 2005
NPDES STAFF REPORT AND RECOMMENDATION
County. Mecklenburg
MRO No.: 05-02
Permit No. NCO031038
PART I - GENERAL INFORMATION
1. Facility and Address: Colonial Pipeline Company
Post Office Box 87
Paw Creek, North Carolina 28130
2. Date of Investigation: 02-28-05
3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. John Gilbreath, Environmental Engineer,
[phone]
5. Directions to Site: From the junction of Highway I-85 and Highway 27 in Charlotte, travel
west on Highway 27 (Freedom Drive) approximately three (3) miles to Old Mt. Holly Road.
Turn right onto Old Mt. Holly Road and travel approximately 0.2 mile to intersection with
Kenstead Circle. Turn right on Kenstead Cirle and travel approximately 200 feet. The
entrance to Colonial Pipeline Company is located on the left side of the road
6. Discharge Point(s). List for all discharge points:
Latitude: 3501717 Longitude: 800 56' 08"
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map.
USGS Quad No.: F 15 SW USGS Quad Name: Mountain Island Lake
7. Site size and expansion are consistent with application?
Yes X No_ If No, explain:

S. Topography (relationship to flood plain included): Moderately hilly, with slopes of 3 to 70/6.
The site is not located in a flood plain.
9. Location of nearest dwelling: None within 500 feet of the discharge point.
10. Receiving stream or affected surface waters: Unnamed tributary to Gum Branch.
a. Classification WS-IV
b. River Basin and SubbasinNo.: Catawba River Basin; 030834
c. Describe receiving stream features and pertinent downstream uses: Discbarge is
taking place into an unnamed tributary to Gum Branch. General C classification uses
downstream.
PART H - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Type of wastewater to be permitted:
0% Domestic
1000/6 Industrial
Volume of Wastewater. The wastewater is generated from storm water that falls into
the manifold area and is collected in a french drainage system. Petroleum constituents
are introduced into the storm water from any free phase petroleum that enters the
underground drainage system as the result of a spill or from slab wash down water.
The current permitted capacity for groundwater remediation is 0.0648 MGD.
b. What is the current permitted capacity of the wastewatef treatment facrb' . The
. current permitted capacity for groundwater remediation is 0.0648 MGD.
C. Actual treatment capacity of the current facility (current design capacity)? N/A.
d Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two years: N/A
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: The existing wastewater treatment consists of An oil water
separator (at the manifold area) that discharges to an unnamed tributary, located
on the north side of the property, that discharges into the main pond located on the
property; A groundwater remediation system consisting of an oil/water separator,
diffused air unit, and activated carbon adsorption unit that discharges to an
unnamed tributary, located on the south side of the property, that discharges into
Page 2

- the main pond. Storm water run-off from the tank area located on the south side
of the property discharges to a smaller pond above the main pond (The smaller
pond discharges to the unnamed tributary located on the south side and
subsequently to the main pond). Also, Storm water rim -off from the tank area
located on the north side of the property discharges via a pipe to the main pond
(without treatment).
f Please provide a description of proposed wastewater treatment facilities: N/A
g. Possible toxic impacts to surface waters: Due to nature of the wastewater there
could be some toxicity concern.
IL Pretreatment Program (POTWs only): N/A.
2. Residuals handling and utilization/disposal scheme: Sludge that accumulates in the
oil/water separator is pumped and disposed by Hamnat Transportation & Disposal Inc.,
Tel # [phone]. Carbon canisters are handled by A & D Environmental, Tel # 336-
434-7750. The tank bottom water is treated/disposed on site as approved by Permit No.
W00004751.
3. Treatment plant classification (attach completed rating sheet): Class I
4. SIC Code(s): 5171
Primary: 39
Main Treatment Unit Code: 53000
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? N/A.
2. Special monitoring or limitations (including toxicity) requests: Toxicity may need to be
limited/monitored due to the suspected toxic nature of such discharges.
3. Important SOC, JOC or Compliance Schedule dates: (please indicate) N/A.
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge
options available. N/A
Page 3

5. Air Quality and/or Groundwater concerns or hazardous material utilized at this facility that
may irrpact water quality, air quality or groundwater? Contaminated groundwater exists
at the site. Air Quality Permit for this facility is required by Mecklenburg County.
PART IV - EVALUATION AND RECOMMENDATIONS
Colonial Pipeline Company is requesting an NPDES Permit renewal for the discharge of
treated wastewater. The wastewater is generated from a ground water remediation system and
stormwater nmoff
A letter to Charles Weaver regarding sampling locations was submitted with the renewal
application. The Mooresville Regional Office defers action on this matter to the NPDES Unit.
Upon resolution of the above, it is recommended that the permit be renewed.
Signature 'Report P parer
G6a�
Water QuaUtAegional Supervisor
3�2.77/0
Date
so a- ad
sTJdL).a t

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c�

John W. Culbreath
Senior Environmental Technician
Southeast District
December 22, 2004
Mr. Charles H. Weaver, Jr.
NCDENR / Water Quality /NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Colonial
Pipeline Company
i
04-399-5259
04;3999029
VM
AN
JJ
6 2005
DENR
- WATER QUALITY
i
:. POINT
SOURCE BRANCH
Re: NPDES Permit No. NCO031038 — Renewal Submittal
Colonial Pipeline Company
Mecklenburg County .
Dear Mr. Weaver:
Colonial Pipeline Company requests renewal of the above referenced permit which will expire on July
31, 2005. The Responsible Corporate Officer for the purpose of this renewal is now Mr. Steve E.
Jacobs, General Manager -Operations for Colonial Pipeline Company.
The -current compliance point, is, the, discharge at the facility retention pond (Outfall 001). All
stormwater run-off from the facility flows into the pond. However, run-off from other off -site industrial
areas and subdivisions also flows through the pond. #Dudng-the_reneviwaliprocess:in 2001_ Colonial -met
not
status In hopes of. reducing:hid.. number _of: compliance outfalls, to'_three._ The _ouffall6:.would:.be
rep[esentative.of, a.distillate TSCA, a gasoline TSCA, and the.MYO_ NCDENR denied the request due
to lack of analytical data from the individual ouffalis. A Sampling and Analysis Plan was then submitted
to Mr. -Good6cli outlining a program to sample the eight separate outfall areas. The enclosed response
letter from Mr. Goodrich stated that Colonial should continue monitoring Outfall 001 to maintain
compliance._He also suggested that Colonial implement the Sampling and Analysis Plan at least a
year prior to, this application to collect data from the individual outfalls so that a permitting strategy and
possible representative outfall status could be considered. A-tablewith the results of each individual
outfall is attached for your review.
Colonial requests that your department' consider the enclosed information and approve the
representative outfall option mentioned above. Colonial also requests a meeting with members of your
department to discuss the permitting strategy and the analytical parameters that will be required for the
facility.
7524 Kenstead Circle Paw Creek, NC 28130
P.O. Box. 87 Paw Creek, NC 28130

Colonial Pipeline Company
December 22, 2004
Page 2
Below is a list of the renewal package:
1. Cover letter requesting permit renewal and documentation of any changes since issuance of
the last permit (signed original and two copies)
2. The completed application form signed by the permittee (signed original and two copies)
3. The stormwater outfall analytical results table
4. Copy of the letter dated September 23, 2002 from Mr. David Goodrich of NCDENR
5. A narrative description of the sludge management plan for the facility (signed original and
two copies)
6. Facility maps
If you have any questions or need any additional information I can be reached at 704-399-5259.
Very truly yours,
John W. Culbreath
Senior Environmental Technician
Enclosures
Colonial Pipeline Company

Colonial Plineline Company
Charlotte Delivery Facility
Stormwater Outfall Analytical Results
OUTFALL
DATE
TSS/mg/I
O&G/mg/I
PHENOL/mg/I
SW-MYO
9/29/2003
8
BDL
BDL -
10/7/2003
6
BDL
BDL
1/6/2004
6..
BDL
BDL
2/13/2004
14..
BDL
BDL
3/31/2004
12 •
BDL
BDL
6/15/2004
4 .
BDL
0.07
•
7/27/2004
20.
BDL
BDL
•
8/31/2004
5 -
BDL
BDL
11/5/2004
100
BDL
BDL
SW-TSCA-1
9/29/2003
BDL
BDL
BDL
�°14S�u
10/7/2003
BDL
BDL
BDL
1/6/2004
13
BDL
BDL.
2/13/2004
28
BDL
LAB ERROR
C
3/31/2004
9
BDL
BDL.
�j}Nle S
6/15/2004
14
BDL
0.07
711
7/27/2004
20
BDL
BDL.
7/0'-
8/31/2004
31
BDL
BDL
717
11/5/2004
37
BDL
0.054
SW-TSCA-2
9/29/2003
3 ` '
BDL
BDL
10/7/2003
10
BDL
BDL
a�}'30L[W
1/6/2004
a. NS
NS
NS
2/13/2004
28
BDL
LAB ERROR
3/31/2004
13
BDL
BDL
7!
6/15/2004
NS
NS .
NS
�5
7/27/2004
15
BDL
BDL
7�5
8/31/2004
16
BDL �
BDL
11/5/2004
25
BDL
BDL
SW-TSCA-3
9/29/2003
4
BDL
BDL
6A5a4b1-
10/7/2003
61
BDL
BDL
1/6/2004
4
NS
NS
2/13/2004
8
BDL
LAB ERROR
7
3/31/2004
5
BDL
0.05
3
6/15/2004
4
BDL
BDL
?
7/27/2004
2
BDL
BDL
?3
8/31/2004
2
BDL
0.05
11/512004
BDL
BDL
BDL
- MYO -
MANIFOLD YARD OUTFALL
BDL - BELOW DETECTION LIMIT
NS- NOT SAMPLED
SW - STORMWATER
TSCA -
TANK SECONDARY CONTAINMENT AREA
PARAMETER/RESULTS
BETX/ug/I
MTBE/ug/I
ACUTE TOXICITY / %
BDL,
BDL
0
BDL
BDL
A
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
9.4
BDL
BDL
7.5
BDL
BDL
34.7
3.6(TOLUtNfj
BDL
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
25.2
BDL
BDL
8.8
BDL
BDL
64.6
BDL
BDL
0
BDL
BDL
0
NS
NS
0
BDL
BDL
0
BDL
BDL
0
NS
NS
NS
BDL
BDL
80
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
NS
NS
0
BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
_ BDL
BDL
0
BDL
BDL
0
BDL
BDL
0
TI
IRBIDITY/NTU NAPHTHALENE/ug/l
13
NS•
NS
NS
NS-
NS
NS
NS
NS
NS
NS
30
10
8.1
2.1
NS
NS
NS
BDL
NS
BDL
NS
NS
NS
NS
NS
NS
40
10
NS
NS
NS
NS
NS
4
5.4
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
21
14
29
NS
NS
NS
NS
1.1
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
5
NS
NS
3.1
5
NS
NS

Colonial Pipeline
Company
Charlotte Delivery
Facility
Stormwater
Outfall
Analytical
Results
PARAMETER
RESULTS
OUTFACE
DATE
TSSlmgll
O&G/mg/I
PHENOL/mg/1
BETX/ug/I
MTBE/u /1
ACUTE TOX
SW-TSCA-4
9/29/2003
2
BDL
BDL
BDL
BDL
0
i0/W4(,U--
10/7/2003
1/6/2004
3
BDL
BDL
BDL
BDL
0
62
NS
NS,
NS
NS
p
2/13/2004
16
BDL
LAB ERROR
BDL
BDL
p
3/31/2004
19
BDL
BDL
BDL
BDL
p
6/15/2004
6
BDL
0.07•
BDL
BDL
0
7O
,5
7/27/2004•
5
BDL
BDL-
BDL
BDL
0
73
8/31/2004-
4
BDL
0.06.
BDL
BDL
p
11/5/2004
2
BDL
BDL
BDL
BDL
p
SW-TSCA-5
9/29/2003
NS
NS
NS
NS
NS
NS
10/7/2003
NS
NS
NS
NS
NS
NS
1/6/2004
3
BDL
BDL
BDL
BDL
0
2/13/2004
52
BDL
LAB ERROR
BDL
BDL
0
3/31/2004
140
BDL
BDL
BDL
BDL
0
6/15/2004
9
BDL
0.07
BDL
BDL
p
770
7/27/2004
17
BDL
BDL
BDL
BDL
p
8/31/2004
60
BDL
0.06
BDL
BDL
p
11/5/2004
7.5
BDL
BDL
BDL
BDL
p
SWOTSCA-6
9/29/2003
3
6
BDL
BDL
BDL
p
&48a4VE"
10/7/2003
6
BDL
BDL
BDL
BDL
p
°F-
1/6/2004
2
BDL
BDL
BDL
BDL
p
ft5n -
2/13/2004
7
BDL
BDL
BDL
BDL
p
3/31/2004
11
BDL
BDL
BDL
BDL
p
�5D
1
6/15/2004
6
BDL
0.05
BDL
BDL
p
760
7/27/2004
8
BDL
BDL
BDL
BDL
0
8/31/2004
4
BDL
0.06
BDL
BDL
0
11/5/2004
2.8
BDL
BDL
BDL
BDL
0
SW-TSCA-7
9/29/2003
BDL
BDL
BDL
BDL
BDL
70.7
10/7/2003
20
BDL
BDL
BDL
BDL
61.8
1/6/2004
2
BDL
BDL
BDL
BDL
72
2/13/2004
3
BDL
LAB ERROR
BDL
BDL
79.4
70X
3/31/2004
3
BDL
BDL
BDL
BDL
68.3
6/15/2004
13
BDL
BDL
BDL
BDL
p
7/27/2004
4
BDL
BDL
BDL
BDL
70.7
8/31/2004
2
BDL
0.05
BDL
BDL
15A
11/5/2004
4
BDL
BDL
BDL
BDL
p
MYO -
MANIFOLD YARD
OUTFALL
BDL - BELOW
DETECTION
LIMIT
NS- NOT
SAMPLED
SW - STORMWATER
TSCA -
TANK SECONDARY
CONTAINMENT
AREA
ICITY / % TURBIDITY/NTU NAPHTHALENE/ug/l
0.42 NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
8.6
NS
7.6
NS
11
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
16
BDL
32
NS
8
BDL
0.61
NS
NS
NS
NS
NS
NS
NS
NS
NS
N9
NS
12
BDL
5
NS
5.7
BDL
0.5
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
14
BDL
3.1
NS
20
BDL

O
Colonial Pipeline Company
SLUDGE MANAGEMENT PLAN — CHARLOTTE DELIVERY FACILITY
Colonial's treatment works for stormwater runoff at the Charlotte Delivery Facility consists of
one oil / water separator (Manifold Yard Outfall-MYO) and a retention pond which acts as a
sedimentation basin and an emergency oil / water separator for the Tank Secondary Containment
Areas (TSACs) and the MYO.
The oil / water separator has been designed to capture any refined petroleum products that
may be present in the wastewater flowing through the separator. All refined petroleum products that
accumulate in the oil / water separator are returned to Colonial's pipeline system. The oil / water
separator is equipped with high level alarms for both product and water. These alarms are tested
annually to ensure proper operation.
Sludge accumulates on the oil / water separator floor, and the sludge accumulation rate is such
that it needs to be removed approximately once a year. Since influent to the oil / water separator is
minimal during dry weather, cleaning can be scheduled so that flow bypassing is unnecessary. After
the oil / water separator is cleaned, the sludge is transported to a licensed waste disposal facility by a
permitted waste transporter. An appropriate transporter and disposal facility are selected just prior to
cleaning.
Although sediment accumulates at the bottom of the facility retention pond, it accumulates at a
rate such that the pond seldom needs to be dredged. If the retention pond is dredged in the future,
Colonial will contact the North Carolina Department of Environment and Natural Resources concerning
disposal of the dredged material.
Date /z -/ 5/-O y
John W. Culbreath
Senior Environmental Technician
Date 3 oS
Steve E.bs
General nager- Operations
CADocuments and SettingsUCulbreaNy Documents\Chadot1e\NP0ES\2005 renewal\Sludge Management Plan 2005.doc

TSCA-1
_ — ' \ • • ` ' �� N 350 17.067 W 0W 56.142,
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712 \�x TSCA-2
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GROUND WATER REMEDIATION I
SYSTEM OUTFALL
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N 35017.095 W 0800 56.066' 731•
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TSCA4B
N 35017.153 W 0800 56.031'
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TSCA-5
N 35017.088 W osr 55.964'
LEGEND
PROPERTY LINE
FENCES
POND AND STREAM
DIKE WALLS AND
UNIMPROVED ROADS
IMPROVED ROADS
DRAIN VALVES
ABOVE GROUND BREAKOUT TANK
DISTILLATE PRODUCT
ABOVE GROUND BREAKOUT TANK
GASOLINE PRODUCT
POINT SOURCE DISCHARGE
MANIFOLD YARD
AREA
MANIFOLD YARD
AREA OUTFALL—
MYO
N 35017.176 W 0800 55.968'
TANK SECONDARY CONTAINMENT AREA (TSCA) REFERENCE NUMBER
\ 1/
TSCA-4
N 35017.227 W 0800 56.017'
—,./WEST CHANNEL
TSCA-3
N 350 17.268 W 0800 56.099'
/ POND /
0 200
I I
SCALE IN FEET
OUTFALL 001

March 29, 2004
1321:33f/ k"LWI/IlluI
TO: Dave•Goodrich
NPDES Unit �•/
FROM: D. Rex Gleason
PREPARED BY: Richard Bridgeman 1
�'1 LS jt
1 jU'
MAR 3 1 2004
OR OU,1LITY
I Kv,T so�kcE okAd:6H
SUBJECT: Colonial Pipeline — Charlotte Delivery Facility
NPDES Permit No. NCO031038
Mecklenburg County, NC
Attached please find a request from the attorneys for Colonial Pipeline for this Office to rescind a
Notice of Violation (NOV-2004-LV-0005) issued on January 8, 2004. The Notice was issued in response
to a Benzene limit violation occurring during April 2003.
As you will note in the letter from Mr. Gaskins, of Hamilton Gaskins Fay & Moon, it is the
assertion of Colonial that the violation occurred as the direct result of a release of free product from an
oil/water separator at the CITGO facility. The CITGO facility also has a permitted discharge (NPDES
Permit No. NC0021962) to a UT to Gum Branch.
Unfortunately, the UT to which the CITGO facility discharges is 1 of 3 UT's to Gum Branch
which feed a retention pond identified in the facility description for the Colonial facility. According to
the Colonial terminal manager, all 3 UT's have flow 12 months per year. The retention pond appears to
be an impoundment, but Permit Part 1, A.(4.) concerning a requirement for an engineering study would
seem to suggest that the DWQ does not think so. Even so, the fact remains that the permitted discharge
and runoff from the CITGO facility ultimately enter Colonial's retention pond.
Colonial has previously requested that the designated effluent sampling location be relocated to a
point unaffected by another discharge. It is the contention of Colonial that the request was denied by
letter from Alan Klimek (signed by Dave Goodrich) dated September 23, 2002.
As required in the effective permit, Colonial should monitor the discharge at a point downstream
of the retention pond's outfall. This being so, Colonial is presently required to treat its own wastewater
and that of any other dischargers to the 3 UT's which feed the retention pond. Based on the permit, the
subject violation is valid, as was issuance of the Notice of Violation. It is not the intention of this Office
to rescind the Notice unless it is likely that the Division will modify the designated effluent sampling
location.
Mr. Gaskins will be notified of our intention with respect to the Notice, and of our
correspondence to you. Please contact us with any questions or comments.
Attachment
I ul'7

ATTORNEYS AT LAW
ami Iton (� 2020 Charlotte Plaza • 201 South College Street
G�aSklns Charlotte, North Carolina 28244-2020
\ ' Telephone: [phone]
& ` Facsimile: 704.344.1483
oon, PLLC Richard C. Gaskins, Jr.
Email: [e-mail]
704-227-1046
March 22, 2004 '
6fiO OFFICE.
Mr. D. Rex Gleason
Water Quality Regional Supervisor MAR 2 4 2004
Division of Water Quality
North Carolina Department of Environment
and Natural Resources
Mooresville Regional Office a
919 North Main Street IVA
Mooresville, North Carolina 28115
Re: Colonial Pipeline - Charlotte Delivery Facility
NPDES Permit No. NCO031038
NOV-2004-LV-0005
Mecklenburg County
Dear Rex:
In January, Colonial Pipeline Company ("Colonial") received a Notice of Violation
("NOV") signed by you for alleged effluent limitations at its Charlotte Delivery Facility in Paw
Creek, North Carolina. As indicated in prior correspondence and discussions between Colonial
and the Department of Environment and Natural Resources ("DENIV), the alleged violations
were the result of an overflow of free products from an oil water separator at the CITGO facility
in Paw Creek. Because the CITGO facility is located upstream from the Colonial Pipeline
facility, petroleum constituents from the CITGO release were detected in stream samples taken
by Colonial immediately after the release at the CITGO facility. At the time of the sampling,
Colonial had no ongoing discharges which would have contributed to the constituents detected in
the sampling. Thus, Colonial respectfully requests that the NOV be rescinded and that the record
also renews its request to be allowed to
Facts
an upset condition caused by a third party. Colonial
ale a location that is representative of Colonial's
ves
petroleum facilities.
On April 21, 2003, Colonial personnel discovered what appeared to be a release of a
petroleum product flowing onto the Colonial property from the CITGO facility through a small
tributary that flows into Colonial's stonnwater retention pond. Subsequent investigation
suggested that an oillwater separator tank on CITGO's property had overflowed into the
tributary. The appropriate governmental authorities and CITGO were immediately notified of
the release. Colonial and CITGO mobilized their response teams and absorbent material was

Hamilton Gaskins Fay & Moon, PLLC
Mr. D. Rex Gleason
March 22, 2004
Page 2
deployed to prevent free product from reaching the retention pond. Because of the quick
response, the impact of the release was minimal.
Although the response by Colonial and CITGO appeared to prevent any free product
from reaching the retention pond, odors were detected near the outfall from the retention pond on .
April 22, 2003. Although not required, Mecklenburg County Department of Environmental
Protection ("MCDEP") requested that Colonial collect samples at the retention pond outfall and
at a location near the CITGO property line that was upstream of any possible sources of
contamination on the Colonial property. An analysis of the samples found that there were
elevated levels of BTEX, MTBE and naphthalene at both locations. The levels of all
constituents except benzene were below the effluent standards in Colonial's NPDES permit at
the retention pond outfall. The level of benzene at the retention pond outfall (3.1 ug/1) was
slightly in excess of the permit limit of 1.19 ug/l. The upstream sample was almost 100 times
higher than the downstream sample; it contained 330 ug/l of benzene. Subsequent samples were
within the permit limits.
On May 27, 2003, the monitoring results were submitted to DENR with the regular
effluent sampling results. A cover letter that accompanied the data explained that the incident at
the CITGO facility caused an upset condition reflected in the April 22, 2003 monitoring results.
Rather than receiving any word of thanks for assisting with the cleanup and monitoring of the
CITGO release, Colonial was surprised to receive a Notice of Violation dated January 8, 2004,
for the release from the CITGO facility.
As you probably know, during the permit renewal process, Colonial expressed concerns
that it might be held accountable for releases from other facilities if it was required to sample a
location that received runoff from other facilities. In particular, Colonial objected to adding a
sampling location at the retention pond outfall because of concerns that the retention pond
received runoff from other petroleum facilities in the area. Instead, Colonial requested that it be
allowed to take a representative sample of the runoff from its diked areas. DENR denied
Colonial's request to be allowed to sample representative outfalls from Colonial's facility at that
time because DENR contended that there was insufficient data. Since that time, Colonial has
gathered additional data pursuant to an approved sampling and analysis plan. The additional
sampling demonstrates that there is no significant difference between the runoff from any of the
diked areas at Colonial's facility.
Discussion
The NOV will create problems for Colonial because it is a non -appealable decision that
will be used by others as evidence that Colonial has violated the law. A company's record of
compliance is significant when government agencies are making decisions about allowing new
projects, issuing permits, or assessing penalties. Furthermore, it is our understanding that there is
the potential that DENR will issue a penalty based upon this NOV. The NOV issued against
Colonial should be rescinded and no penalty should be issued because it is well established under

Hamilton Gaskins Fay & Moon, PLLC
Mr. D. Rex Gleason
March 22, 2004
Page 3
North Carolina law and the NPDES program that a permitee should not be cited for a violation
caused by a third party.
It is not a violation of Colonial's NPDES permit if a discharge fi-om anotherfacility
causes an exceedance of an effluent limit in Colonial's permit.
Nothing in the Clean Water Act or North Carolina law allows DENR to require Colonial
to treat, cleanup, or otherwise be responsible for discharges caused by third parties. In general,
the Clean Water Act, and related North Carolina law impose liability on the person or persons
who had ownership or control of a regulated substance immediately prior to its release into the
environment. The Clean Water Act and North Carolina law make it illegal to discharge a
pollutant without a permit. See 42 U.S.C. §§ 1311 and 1342. Under the Clean Water Act, a
"discharge" is defined as "the addition of a pollutant" to a waterbody. See 42 U.S.C.
§ 1362(12). North Carolina law requires permits for activities that "increase the quantity of
waste discharge through any outlet ... to any extent which would result in any violation of the
effluent standards or limitations established for any point source ...." N.C. Gen. Stat. § 143-
215.1(4). A "discharge" is defined as "emission spillage, leakage, pumping, pouring, emptying,
or dumping of oil or other hazardous substances into waters of the State ...." Id. § 143-
215.77(4). Moreover, "discharge" does not include a release of less than a reportable quantity of
oil or a hazardous substance. Id.
Merely allowing contaminated water in a stream to flow through a facility is not a
"discharge of a pollutant" and is not a violation of the law. Colonial did not cause an increase
the quantity of benzene in the tributary to an extent that would have resulted in a violation of the
effluent limitations, and Colonial did not release a reportable quantity of either oil or benzene
during the relevant time period. Therefore, the Clean Water Act and North Carolina law do not
authorize any action to be taken against Colonial for the exceedance caused by CITGO's release.
Although not a violation of either federal or State law, DENR issued a Notice of
Violation to Colonial for CITGO's release. In essence, DENR is saying that the law and the
NPDES permit required Colonial to cleanup CITGO's release. Because DENR lacks statutory
authority to require Colonial to cleanup effluent from a third party, the NPDES permit is
unenforceable to the extent that DENR contends that the permit requires Colonial to cleanup the
CITGO discharge so that it complied with the effluent limitations contained in the permit. Thus,
it cannot be a violation of the permit to have an exceedance caused solely by the acts of a third
ply.
The Third Party Defense is built into the Clean Water Act and North Carolina law
Just in case there is any question about liability for third -party releases, the Clean Water
Act and North Carolina law also contain an explicit third -party defense to liability. The Clean
Water Act provides that "notwithstanding any other provision of law" an owner or operator of a
facility is not liable "where such discharge was caused solely by (A) an act of God, (B) an act of
war, (C) negligence on the part of the United States Government, or (D) an act or omission of

Hamilton Gaskins Fay & Moon, PLLC
Mr. D. Rex Gleason
March 22, 2004
Page 4
another party without regard to whether such act or omission was or was not negligent, or any
combination of the foregoing clauses." 42 U.S.C. §§ 1321(f), (g). North Carolina law contains a
similar third -party defense. Specifically, section 143-215.83(b)(2)(d) of the North Carolina
General Statutes provides that a discharge is not unlawful if the discharge was caused solely by
"an act or omission of a third party, whether any such act or omission was or was not negligent."
The CITGO release was an upset condition under the terms of Colonial's NPDES permit
The concept of a third -party defense is built into every NPDES permit through the
,....standard upset condition provision. Colonial's NPDES permit, like every other NPDES permit,
contains a provision that creates a defense for upset conditions. Section II.C.5 of the NPDES '
permit defines an "upset" as "an exceptional incident in which there is unintentional and
temporary noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permitee." The release from the CITGO terminal was
certainly unintentional and temporary. Moreover, it was beyond the reasonable control of
Colonial. There is no practical way for Colonial to prevent water from flowing onto Colonial's
property from CITGO's property. Although the benzene limit may not be a technology -based
limitation, the inclusion of the upset provision demonstrates that the permit is not intended to
apply to actions of a third party.
It is the policy of the Clean Water Act to exempt persons from liabilityfor actions taken
in response to release by another party.
The Clean Water Act contains an exemption from liability for response actions that are
consistent with the National Contingency Plan or otherwise directed by the government agency
with authority over the release. See 42 U.S.C. § 1321(c)(4). The North Carolina General
Statutes contain an exemption for "any act or omission by or at the direction of a law -
enforcement officer or fireman." N.C. Gen. Stat. § 143-215.83(b)(2)(e). Any action taken by
Colonial relating to the CITGO release was consistent with the National Contingency Plan and
the directions of DENR and MCDEP. In particular, the sampling and analysis that for the basis
of the NOV was done at the explicit direction of MCDEP personnel.
It is against public policy to issue the NOV to Colonial for a release by a third pain.
The State has an interest in encouraging companies to act in an environmentally
responsible manner. This is the point of most environmental laws. It would create a disincentive
for companies to cooperate with other facilities and regulators if DENR penalized a company for
a release from a third party. Colonial was not required to take a sample on April 23, but it
assisted with the cleanup, and took a sample of the impacted tributary to assist MCDEP's
investigation. From an environmental perspective, it is not beneficial to create an incentive for
Colonial to route the effluent from other facilities around the Colonial retention pond or to create
an incentive for Colonial to fail to sample the effluent from the retention pond when there is a
suspected release from another facility. However, unless the proposed NOV is rescinded,
Colonial would have been better off if it had routed CITGO's effluent around the retention pond

Hamilton Gaskins Fay & Moon, PLLC
Mr. D. Rex Gleason
March 22, 2004
Page 5
and ignored MCDEP's request to conduct sampling. In essence, Colonial is being penalized for
acting in an environmentally responsible manner. DENR should use its discretion to refrain
from issuing a Notice of Violation in this situation.
Conclusion
Colonial respectfully requests that the Notice of Violation issued to Colonial be rescinded
and that the record reflect that the exceedance was the result of an upset condition caused by a
third party. To avoid a similar problem in the future, Colonial also renews its request to be
...wallowed to sample a location that is representative of Colonial's operations rather than a location
that receives discharges from other petroleum facilities.
C. Gaskins, Jr.
RCG/dsw
cc: DENR Point Source Compliance / Enforcement Unit