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HomeMy WebLinkAboutNC0031038_WASTELOAD ALLOCATION_19920921NPDES DOCUMENT SCANNING COVER SHEET NPDES Permit: NC0031038 q; Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Correspondence Speculative Limits Instream Assessment (67b) Environmental Assessment (EA) Permit History Document Date: September 21, 1992 This document im Printed on reixea paper - ipgaora any ooatant on the reveW04B Bide DIVISION OF ENVIRONMENTAL MANAGEMENT September 21, 1992 MEMORANDUM TO: Jule Shanklin FROM: Susan A Wilson THROUGH: Carla Sanderson C SUBJECT: Colonial Pipeline NC0031038 Technical Support agrees with Colonail Pipeline's request that the acute toxicity test be conducted as a 24 hour Fathead Minnow test, as specified in Part III, Section D of the text of the pemut. Technical Support concurs with Colonial Pipeline's comments with regard to Part III Section E of the draft permit. Testing for lead should only be required when lead abatement wash waters are discharged. BTEX and MTBE monitoring may be eliminated as a monitoring requirement from lead abatement wash water only. Also, MTBE and lead monitoring may be eliminated as a monitoring requirement from hydrostatic tank test water discharge, if this tank water is restricted to kerosenes and/or fuel oils only, as specified in Colonial Pipeline's comments on the"draft permit. cc: Allen Hardy, MRO SENT BY:COLONIAL PIPELINE i 9- 2-92 12:59 i ENGINEERING DEPT.4 819 733 9919;4 1 PRox: TO: COLONIAL PEPELINE COMIPAW 943 East Paces Perry load Atlanta, Georgia 30326.1123 1yGnMEMO t,pAp.TNW PAX 0404.04L-2464 Pass= TRANBMTAL Q Regular Telephone Number Equipment Telephone Number DATE: _ a - 2-9 7 Time Received Number of Pages (Including Cover) SPECIAL INSTRUCTIONS: SENT 5MOLONIAL PIPELINE ; 9— 2-82 ; 12158 7, ENGINEERING DEPT.4 919 733 8818iti 2 V.A. YAMOROUaH dnr.Yorinpinoo�l�g Colonial Pipeline Company 993URGENS PLAYA OAS 1AV IACH FURY ROAD ATLANTA. GA, 300741123 44 2614QD September 2, 1992 Mr. Jewel Shanklin State of North Carolina Environmental Management Commission P,O. Box 29535 Raleigh, NC 27626 Re: Public Notice of NPDES Permit Renewal Application NPDES Permit Number NCO03ID39 Charlotte Delivery Facility Mecklenburg County Dear Mr. Shanklin: T.W. CEAVINO fAV1fl n(nM1V1 MRnV& Attached is a copy of the letter with comments pertaining to Colonial's NPDES draft permit which you have not been able to locate in your Mos. This letter was both faxed and sent federal express to you on July 31, 1992. As we discussed, please send a copy of the permit tome at the address on the letterhead as well as to Charlotte Delivery Facility. If you have any questions, you may contact me at the address on the letterhead or at 4041941-2399. kit attachments cc: T. W. Cervino R. F. Calupca M. Boyd J. D. Quakenbuah �SiinpmeQly� 4_ O` Vawwr Kelly L. Turner Associate Engineer MAILINO AO0ER11, I.O. 601 '1113 ATbWTA. DA. ]0]2601l1 SENT BY:COLONIAL PIPELINE i 8- 2-92 13100 ENGINEERING DEPT.y, 919 733 8819;# 3 i Colonial Pipeline Company VA. YARBOROUGH Oir60 d1_Erplbb r4 RIRURGINS I{A2A #a RAIT IAQ6 Mly ROAD ATIANTA; GA 5032&1126 14061 261.1470 July 31, 1992 T.W. CERVINO zMW"W A4i Mbr1/pbr Mr. Jewel Shanklin State of North Carolina Environmental Management Commission 812 North Saliebury'Street . . Raleigh, NC 27604 Res Public Notice of NPDES Permit Renewal Application NPDES Permit Number KC0031038 Charlotte Delivery Facility Mecklenburg County Dear Mr. Shanklint In response to the public notice of intent to issue a State NPDES. Permit renewal for Colonial Pipeline Companyra Charlotte Delivery Facility, Colonial requests several modifications to the draft permit. As discussed in our conversation on July 300 the draft permit does not contain a section titled 0011 Terminal and Petroleum Transportation Related Facility" which should' address special consideration for influent quality changes, equipment malfunction, or other circumstances which may result in effluent concentrations exceeding permit limitations despite appropriate care and maintenance measures, taken by the permittee. Also, Colonial 2 Z requests a clause stating that the permittee may declare a percentage of the samples taken by it during a calendar year to be non -representative as is stated in the current NPDES ,Permit for Charlotte Delivery Facility and in other NPDES permits for Colonial facilities in North Carolina. This section should also clarify when the daily maximum is deemed to have been exceeded. In A ffluent Limitations And MnitOrina NAAe am d achargge from outfall 001 of the draft permit, Acutp46 N Toxin ty monitoring i9 required specifying a Daphnid 48 hour test.'° but in the referenced $art IX1 Section D. Acute Toxieity o•K. Monitoring, a- Fathead Minnow 24 hour static test is specifled.,---� Colonial requests that a Fathead Minnow 24 hour test be performed as in part D instead of a Daphnid 48 hour test. MAAUNG ADDRIRN I.O. 102 16I61 AMNIA, OA. 303264666 SENT BY:COLONIAL PIPELINE 9- 2-92 13:01 ENOINEERINO DEPT.-4 919 733 9919i8 4 ^. �d49niaA Vlve31ne COM'72M7 Mr. Jewel ghanklin July 31, 1992' Page 2 In part T Section A Part ITT Section E, Colonial is required to test for organic parameters and lead during the first five discharge events and annually thereafter. Colonial requests that organics testing be limited to benzene, ethylbenzene, toluene, oK- xylens, and methyl tort -butyl ether (MTBE).. Testing for Lead should only be required when bead abatement wash waters are discharged since it is no longer a significant component Of gasolines. Colonial further requests that BTEX and MTBR testing for lead abatement wash waters and that ME testing for hydrostatic test water discharges from fuel oil and kerosene tanks be deleted) Lead should be the only contaminant of concern with oje the lead abatement wash waters and MTBE is not a component of kerosenes or fuel oils. If you have any questions, you may contact as at the address on the bottom of the letterhead or at 404/841-2399. Sincerely,__ 44 �V99awl Kelly L. Turner Associate Engineer klt cc: T. W. cervino R. F. Calupoa J.I. Boyd J. D. Quakenbush l�-ll0 i�piflu�.t.T t�Fo PtTS�Ck4'ti� NPDES WASTE LOAD ALLOCATION PERMIT NO.: NCO031038 PERMITTEE NAME: Colonial Pipeline Company FACILITY NAME: Charlotte Delivery Facility Facility Status: Existing Permit Status: Renewal Major Pipe No.: 001 Minor _q Design Capacity: (0.0045) MGD -- Domestic (% of Flow): Industrial (% of Flow): 100 % Comments: Stormwater through of water separator PLOTTED STREAM INDEX: 11-120-5 RECEIVING STREAM: an unnamed tributary to Gum Branch Class: C Sub -Basin: 03-08-34 Reference USGS Quad: F15SW, Mtn.Isl. Lake (please attach) County: Mecklenburg Regional Office: Mooresville Regional Office Previous Exp. Date: 3/31/92 Treatment Plant Class: Classification changes within three miles: > 3 mi. Requested by:, Prepared by: Reviewed by: Modeler Date Rec. # Drainage Area (mil ) ,-- o .1 Avg. Streamflow (cfs): 7Q10 (cfs) 0 -Winter 7Q10 (cfs) 0 30Q2 (cfs) Toxicity Limits: IWC % Acu /Chronic Instream Monitoring: EPISOD t C Parameters Upstream Location Downstream Location Recort MWd d limits Monthly Averaa . Daily Max-_• MM_FZZ Wp EL Flow (MGD): Oil &Grease m Turbidity QM): K1215. s TSS (mg/l): . Benzene (}tg4): monitor Toluene (µg4): monitor Ethylbenzene (µga): monitor Xylene (µg/1): monitor Lead (�Lg/l): monitor Methyl-tert-butyl ether (MTBE) (µg/l): monitor SPECIAL INSTRUCHONS OR CONDITIONS ++ instantaneous 6-9 2/mon 45 2Anon mon *s ** ** ** ** —7 5eE VuAz ucvc 1` ++ Permit must contain flow monitoring requirement such that all volumes of wastewater leaving the facility are monitored. If continuous monitoring is not feasible, then discharger shall record the approximate times that discharge began and ended, along with instantaneous flow at the time of effluent samping. Monitoring for all toxicants should be performed during the first five discrete discharge events (annually thereafter) after the effective date of the NPDES permit. Monitoring should occur at the same time that the whole -effluent toxicidy sample is collected during the discharge event (samples should be collected within 24 hours of the beginning of the event). *The turbidity in the receiving stream will not exceed 50 NTU. (9r7Q10 = 00, 50 NNT'U applies as an effluent limit.) ** BTEX parameters should be monitored using an EPA approved method to a detection level of at least 1 ppb. Organic parameters and lead should be monitored during the first five events and annually thereafter in correspondence with toxicity testing. Clause should be placed in the permit to allow for additional limits on these or other toxicants should the whole effluent toxicity test indicate toxic effects. BTEX, and MTBE must be monitored after discharge of hydrostatic test water (tank or pipeline) and lead abatement wash H2O. NOTE: Clause should be placed in permit stating that lead abatement wash H2O may only be discharged if tests of the wash H2O show lead levels less than or equal to 25 µg/l. Facility Name: NPDES No.: Type of Waste: Facility Status: Permit Status: Receiving Stream: Stream Classification: Subbasin: County: Regional Office: Requestor: Date of Request: Topo Quad: FACT SHEET FOR WASTELOAD ALLOCATION Colonial Pipeline Co. NCO031038 Industrial - 100% Existing Renewal UT Gum Branch C 030834 Mecklenburg J. Shankhn 11/18/91 F15SW Request # 6601 k n r is r>= -ni cl Stream Characteristic: USGS # est. } Date: Drainage Area (mi2): <0.1 c� Summer 7Q10 (cfs): 0.0 co T.t Winter 7Q10 (cfs): Average Flow (cfs): 30Q2 (cfs): IWC M: Wasteload Allocation Summary (approach taken, correspondence with region, EPA, etc.) Large bulk storage facility. Recommend new stormwater discharge SOP from petroleum storage facilities [ref. 3/15/92 memo to Regional WQ Supervisors]. Per Colonial Pipeline's addendum to permit application (11/13/91), they also discharge wash H2O from lead paint removals, tank hydrotest water, and pipeline hydrotest water. Colonial performs in-house tests on these waters before discharging. The discharge goes into an oil/H20 separator and to a "detention pond". The MRO is in the process of requiring Colonial to eliminate this as a treatment scenario because Colonial has only dammed up the existing tributary and not really created a "detention pond" for treatment. Special Schedule Requirements and additional comments from Reviewers: Recommended by: ate: Reviewed by Instream Assessment: l� Date:0 a Regional Supervisor:Date: Q 6 Permits & Engineering: /! Date: / RETURN TO TECHNICAL SERVICES BY: APR 3 © 1992 2 TOXICS Type of Toxicity Test: Existing Limit: Recommended Test: Acute Epsiodic 24 hr Fathead Minnow Monitoring Schedule: First five events, then annually Existing Limits Mon. v Daily Max pH (SU): 6-9 Oil & Grease (mg/1): 30 60 Recommended Limits Monthly Average Dail_ Mon. Frea. WQLEL Flow (MGD): ++ instantaneous pH (SU): 6-9 2/mon Oil & Grease (mg/1): 45 2/mon Turbidity (NTU): * 2/mon TSS (mg/1): 45 2/mon Benzene (µg/1): monitor ** Toluene (µg/l): monitor ** Ethylbenzene (ggft monitor Xylene (µg/l): monitor ** Lead (µg/l): monitor ** Methyl-tert-butyl ether (MTBE) (µg/l): monitor ** SPECIAL INSTRUCTIONS OR CONDITIONS ++ Permit must contain flow monitoring requirement such that all volumes of wastewater leaving the facility are monitored. If continuous monitoring is not feasible, then discharger shall record the approximate times that discharge began and ended, along with instantaneous flow at the time of effluent samping. Monitoring for all toxicants should be performed during the first five discrete discharge events (annually thereafter) after the effective date of the NPDES permit. Monitoring should occur at the same time that the whole -effluent toxicitiy sample is collected during the discharge event (samples should be collected within 24 hours of the beginning of the event). -�heve�o�e. *The turbidity in the receiving stream will not exceed 50 NTU. (1r7Q10 = 0,k50 NTU applies as an effluent limit.) ** BTEX parameters should be monitored using an EPA approved method to a detection level of at least 1 ppb. Organic parameters and lead should be monitored during the first five events and annually thereafter in correspondence with toxicity testing. Clause should be placed in the permit to allow for additional limits on these or other toxicants should the whole effluent toxicity test indicate toxic effects. BTEX, and MTBE must be monitored after discharge of hydrostatic test water (tank or pipeline) and lead abatement wash H2O. NOTE: Clause should be placed in permit stating that lead abatement wash H2O may only be discharged if tests of the wash H2O show lead levels less than or equal to 25 µg/l. Limits Changes Due To: Parameter(s) Affected New regulations/standards/procedures TSS, O&G,pH,flow New facility information BTEX, Lead The following parameter(s) are water quality limited: For some parameters, the available load capacity of the immediate receiving water will be consumed. This may affect future water quality based effluent limitations for additional dischargers within this portion of the watershed. 0 _X_ No parameters are water quality limited, but this discharge may affect future allocations. MISCELLANEOUS INFORMATION & SPECIAL CONDITIONS Miscellaneous information pertinent to the renewal or new permit for this discharge. Include relationship to the Basinwide Management Plan. WASTELOAD SENT TO EPA? (Major) _N_ (Y or N) (If yes, then attach schematic toxics spreadsheet, copy of model, or if not modeled, then old assumptions that were made, and description of how wasteload fits into basinwide plan.) Additional Information attached? _N_ (Y or N) If yes, explain with attachments. 11/13/91 Colonial Pipeline letter is attached. Facility Name "miAt. R PEuge Co. Permit # NC003 10 ,6 Pipe # ACUTE TOXICITY MONITORING (EPISODIC) The permittee shall conduct FIVE acute toxicity tests using protocols defined as definitive in E.P.A. Document 600/4-85/013 entitled '"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, using effluent collected as a single grab sample. Effluent samples for self -monitoring purposes must be obtained below all waste treatment. Sampling and subsequent testing will occur during the first five discrete discharge events after the effective date of this permit. After monitoring of the fast five toxicity tests, the permittee will conduct one test annually, with the annual period beginning in January of the next calendar year. 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, DEM Form AT-1 (original) is to be sent to the following address: Attention: Environmental Sciences Branch North Carolina Division of Environmental Management 4401 Reedy Creek Rd. Raleigh, N.C. 27607 Test data shall be complete and accurate and include all supporting chemical/physical measuremen 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 Environmental Management 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. Failure to submit suitable test results will constitute noncompliance with monitoring requirements. 7Q10 0 cfs Permitted Flow N/R MGD IWC 100.0 % Basin & Sub -basin 03og!% Receiving Stream lxr Bunn Ea. County taAF.cmQ4Ba2y EAM Fathead 24 Version 10191 Recommended by:, n Date 3 1 4L Colonial Pipeline Company 9I Fri! (r F.�• ��. V.F. 'iARoOPO'JCz:I L revar.Engareerng November 13, 1991 VIA FEDERAL EXPRESS NC Department of Environment, Health, and Natural Resources Permits and Engineering Unit Division of Environmental Management 512 North Salisbury Street Raleigh, NC 27604 Re: NPDES Permit Renewal Application Addendum NPDES Permit Number NCO031038 Charlotte Delivery Facility Mecklenburg County Dear Sir or Madam: As an addendum to the 9/30/91 NPDES permit renewal application for the above mentioned facility, Colonial requests that the renewed permit include the following discharges: "Manifold yard stormwater" 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. 2. "Washdown slab water" is an intermittent discharge that is 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. The washdown slab effluent is piped to the facility oil/water separator for treatment prior to its release to the facility retention pond. "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. The calibration water is routed to the oil/water separator for treatment prior to its release to the facility retention pond. 4. "Wash water from the lead abatement decontamination trailer" is generated during lead paint removal operations at the facility. These operations are part of Colonial's lead abatement program. The wastewater from showers and washing machines in the decontamination trailer contains low concentrations of lead (well below hazardous waste levels). Colonial will route this water to the facility oil/water separator prior to its release to the retention pond. COLONIAL PIPELINE COMPANY NC Department of Environment, Health, and Natural Resources November 13, 1991 Page 2 5. "Tank hydrotest water" is generated periodically when it is necessary to confirm the integrity of one or more of the facility's storage tanks. Colonial typically uses city water or water from its facility retention pond as the source of its hydrotest water. After a laboratory analysis of the tank hydrotest water has shown that treatment is not necessary, Colonial will release the tank hydrotest water into the diked area surrounding the tank where it will eventually flow to the retention pond via the tank dike drain(s). 6. "Pipeline hydrotest water" may be generated periodically during hydrotests of the facility piping and/or pipelines that enter and exit the facility. Although Colonial has previously treated its pipeline hydrotest water with a mobile activated carbon treatment unit, necessary treatment of pipeline hydrotest water is determined on a case by case basis. Colonial requests that a clause be included in the renewed permit that grants conditional approval of the discharge of pipeline hydrotest water. Approval will be contingent on NC DEHNR's acceptance of Colonial's proposed treatment system. Colonial makes this request in order to avoid the sometimes lengthy permit modification process. If you have any questions or need any additional information, I can be reached at 404/841-2491 or at the mailing address on the letterhead. Sincerely, Perry`D. Sisk PDS/pds cc: T. W. Cervino R. F. Calupca D. C. Baughn J. D. Quakenbush rJCoo;(o�d 3/Tz f "Ca 03083¢ uT CuhL_g2__.� f� � Cor.pNlA r. prPc4tNE %. 4i � ENr,. a. 0 n S%ORM WA7E%L Dt$IAIA 6 CoutF���`2a�x oM-StTc' Y/teyw- ZgAl ��ryNt bfFAu� ,f FK.c_ r- o[L '2 .. Io.�cN� _• b, -. .r. . A L As V`U7MC-nlT is 0/s/O SF.OFICLA�/1 0/� �l.T`_-�dA4='L7= ANE/t fENcy 4a�-conl, 4 94T GRc- 4 TY SuST DAMAACD UP STAS6^ To Fo/Ln2 Qr--rCATn.., M,.IN ...I)— _ r.. — . — .-.,cam. 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Facility and Address: Colonial Pipeline Company Post Office Box 87 Paw Creek, North Carolina 28130 2. Date of Investigation: 04-03-96 3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer I 4. Persons Contacted and Telephone Number: Mr. Dan Miller, District Environmental Engineer; (70.4) 399-8266 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. Proceed on Kenstead Circle 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: 350 17' 17" Longitude: 80" 56' 08" Attach a U.S.G.S. map extract and indicate treatment facility l 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: 8. Topography (relationship to flood plain included): Moderately hilly, with slopes of 3 to 7%. 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 Subbasin No.: Catawba River Basin; 030834 C. Describe receiving stream features and pertinent downstream uses: Discharge will take place into an unnamed tributary to Gum Branch. General C classification uses downstream. One water supply intake is located on Lake Wylie. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. Type of wastewater to be permitted: 0% Domestic 100% Industrial a. Volume of Wastewater: * MGD (Design Capacity) b. What is the current permitted capacity of the wastewater treatment facility? * 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 NPDES Permit Staff Report Version 10/92 Page 2 system as the result of a spill or from wash down slab water. 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: An Authorization to construct for the groundwater remediation system was issued under Permit No. NCG510207 on July 29, 1994 and was amended on December 1, 1995.. e. Please provide a description of existing or substantially constructed wastewater treatment facilities: The existing treatment consists of an oil water separator followed by a pond which is fed by several tributaries. The pond is also being used as an emergency oil water separator. 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. h. Pretreatment Program (POTWs only): N/A. 2. Residuals handling and utilization/disposal scheme: Sludge accumulates in the oil/water separator at a rate such that cleaning only needs to be done every five to ten years. When cleaning is done the company contracts a licensed waste disposal facility for removal and disposal. 3. Treatment plant classification (attach completed rating sheet): Proposed, no rating given. 4. SIC Code(s): 5171 Primary: 39 Main Treatment Unit Code:' 53000 NPDES Permit Staff Report Version 10/92 J Page 3 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. Please provide regional perspective for each option evaluated. Spray irrigation: N/A Connection to regional Sewer System: N/A Discharge to an infiltration gallery:N/A 5. Air Quality and/or Groundwater concerns or hazardous material utilized at this facility that may impact water quality, air quality or groundwater? Contaminated groundwater already exists at the site. •Hazardous material stored at the site may pose a threat to groundwater. Air Quality Permit for this facility may be 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-was.tewater-a outfall-- 0.01._is_generated--from--storm-_water_thatTf-a11s_in—the manifold,area,-from-wash-down-slab .water-,.-or---fr-omf-spfiTY_ .=-Theme hydrotest=water---is-- dischar-ged�at=outfa dl_ -Q 2DBoth discharges eventually enter the pond. The tank bottom water is treated on site as approved by Permit No. WQ0004751. NPDES Permit Staff Report Version 10/92 Page 4 0 It is recommended that the NPDES Permit be renewed once the above mentioned concern regarding toxicity has been addressed and comments from the GW Section have been received. Signature ojrRep�rt Preparer Water Quality FWgional Supervisor NPDES Permit Staff Report Version 10/92 J Page 5. Date L- Date