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HomeMy WebLinkAboutNC0031046_PERMIT ISSUANCE_20061215WDES DOCUMENT SCANNIMS COVER SHEET NPDES Permit: NC0031046 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: December 15, 2006 This dooumeat 10 printed on reu®e paper - ignore nay ooateat on t ke reverise aside i- - �pF Vv ^ I rqQ Michael F. Easley, Governor William G. Ross Jr., Secretary 03 r North Carolina Department of Environment and Natural Resources J Alan W. Klimek, P.E. Director Division of Water Quality December 15, 2006 Mr. Faron D. Leigh Colonial Pipeline Company 411 Gallimore Dairy Road Greensboro, NC 27409 Subject: Issuance of NPDES Permit NCO031046 Colonial Pipeline Company Guilford County Dear Mr. Leigh: 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 final permit includes no significant changes from the draft permit sent to you on October 25, 2006. However, there are terms within this permit that are different from the one that is currently effective. These changes are primarily with regard to removal of limitations and reductions in monitoring frequencies for various parameters at each of the outfalls. These changes were made based upon a reasonable potential analysis of effluent data submitted by the facility, and were detailed in the October 25, 2006 cover letter accompanying the draft permit. One change not noted in that letter (but shown in the permit's terms) was that the limit for Xylene has been removed for outfalls 003, 004 and 005. A typographical error was corrected within footnote 4 following the monitoring requirements to refer you to Section A. (8) of the permit for details on the toxicity testing requirement. Because of the number of changes made to the permit, you are encouraged to read the permit carefully and familiarize yourself with its terms in order to help ensure compliance with its conditions. Specific attention should be given to Section A. (7.), a new requirement calling for Colonial Pipeline to prepare and submit a plan detailing steps it will take to reduce or eliminate concentrations of MTBE in its discharge. Additionally, the facility is directed by this condition to implement the plan after it has been developed. If any parts, measurement frequencies or sampling requirements contained 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. Caro ina rtly North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Customer Service Internet: www ncwateraualitv.orR location: 512 N. Salisbury St. Raleigh, NC 27604 Fax (919) 733-2496 1-877-623-6748 An Equal Opportunity/Alhmwtive Action Employer — 50 % RecycleNl O% Post consumer Paper Mr. Faron D. Leigh NPDES Permit NC0031046 Renewal p. 2 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 Sledge at telephone number (919) 733-5083, extension 547. . Sincerely, Aan .:tk, P.E. cc: Central Files Winston-Salem Regional Office/Surface Water Protection Section �NP:DES_Jnit Permit N00031046 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, Colonial Pipeline Company is hereby authorized to discharge wastewater from outfalls located at the Colonial Pipeline Company 411 Gallimore Dairy Road Guilford County to receiving waters designated as an unnamed tributary of East Fork of the Deep River within the Cape Fear 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 February 1, 2007. This permit and authorization to discharge shall expire at midnight on August 31, 2011. Signed this day December 15, 2006. Alan W. Klimek, P.E., Director Division of Water Quality By Authority of the Environmental Management Commission Permit NCO031046 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 continue discharging stormwater runoff, slab wash -down water, Prover-loopTM (or similar) calibration water, and hydrostatic tank -testing water (through Outfalls 001 through 005) from the existing Water -Pollution Control System consisting of gravity -drained diked secondary -containment structures and soil remediation landfarm; a system utilizing ponds, oil/water separators, and discharge control valves; servicing manmade confinements identified as: Confinement Area Size (Acres) Oil / Water Separator Outfall Number Fuel Oil Tank Area / Kerosene and Jet Fuel Area 22.2 2 001 Fuel Oil Tank -Manifold Area 7.4 1 002 Pump Area 2.2 1 003 Gasoline & Utility Tanks / Gas Manifold Area 35.9 1 004 Meter -Out Area 1.6 1 004 Oily -Waste Landfill / Meter -In Area 13.3 1 005 located at the Colonial Pipeline Company, 411 Gallimore Dairy Road, Greensboro, Guilford County, .and; 2. to discharge from said treatment facility through Outfalls 001 through 005 at specified locations (see attached map) into an unnamed tributary of the East Fork of the Deep River, a waterbody classified as WS-IV waters within the Cape Fear River Basin. Permit NCO031046 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT47F CHARACTERISTICS$ �� LIMITS �� � '�'� , r Monthly k� + yf Dady t f +. ea s�Maximum r, MONITORING REQUIREMENTSf5+" MeasUrement{,'`� 'kSample?; 'Sample ,*'n^"5,: ,F �# FFs sn1 ;t v,Fre uenc � : r�T e „ .nLocatton , Flowl Episodic 1 Effluent Total Suspended Solids 45.0 mgfL Monthly Grab Effluent Oil and Grease2 Quarterly Grab Effluent Phenol Monthly Grab Effluent Benzene Quarterly Grab Effluent Toluene Quarterly Grab Effluent Ethyl Benzene Quarterly Grab Effluent X lene Quarterly Grab Effluent MTBE3 Quarterly Grab Effluent Acute Toxicity4 Annually Grab Effluent A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 002. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENT + CHARACTERISTICS `'Monthly 't,. .,=MONITORING•REQUIREIVIENTSm. tAvera e ' T Datly ' -;Maximum.•„� Measurements ,r.'F�e denc . t, E Sample ' r , _ e..,r Sampler; z - ,� +Locadou,z Flowl Episodic 1 Effluent Total Suspended Solids 45.0 m Monthly Grab Effluent Oil and Grease2 Quarterly Grab Effluent Phenol Monthly Grab Effluent Benzene Quarterly Grab Effluent Toluene Quarterly Grab Effluent Ethyl Benzene Quarterly Grab Effluent X lene Quarterly Grab Effluent MTBE3 Quarterly Grab Effluent Acute Toxicit 4 Annually Grab Effluent Permit NCO031046 A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 003. Such discharges shall be limited and monitored by the Pen-nittee as specified below: '�,MONITORING'iREQUIREMENTSY,� Mobthly-13'f .�W,-Awraje*X�'. Wf% ,DMY` Oil 8 tun A, ;-,MeisZfVih6t �-XNT Flowl Episodic 1 Effluent Total Suspended Solids 45.0 mgfL Monthly Grab Effluent Oil and Grease2 Quarterly Grab Effluent Phenol Monthly Grab Effluent Benzene 1 1.19 AgIl Monthly I Grab Effluent Toluene 11.0 AgIl Monthly Grab Effluent Ethyl Benzene Monthly Grab Effluent Xylene Monthly Grab Effluent MTBE3 Monthly Grab Effluent I Acute Toxicity4 Annually Grab Effluent A. (4.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of the permit and lasting until expiiation, the Permittee is authorized to discharge from Outfall 004. Such discharges shall be limited and monitored by the Permittee as specified below: 'EFFLUENT. W -CHARACTERJSTICS TO 1D@IY' rN UAN i ....... 'M RI REQU �k ONITO NG IREMENTSM, Mea remen ',M 8, 1Sample'' &M eq ency 'Cii*0 Flowl Episodic l Effluent Total Suspended Solids 45.0 mg/L Monthly Grab Effluent Oil and Grease2 Quarterly Grab Effluent Phenol Monthly Grab Effluent Benzene 1.19 ILgIl Monthly Grab Effluent Toluene 11.0 ILgIl Monthly Grab Effluent Ethyl Benzene Monthly Grab Effluent Xylene Monthly Grab Effluent MTBE3 Monthly Grab Effluent I Acute Toxicity, Annually Grab Effluent Permit NCO031046 A. (5.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from Outfall 005. Such discharges shall be limited and monitored by the Permittee as specified below: EFFLUENTS 4f %�,,' 4 ,''' CIIARACTERISTICS r t bLIMITS ta_: y?MontFilyfi "u,Datly, MON1. ITORING REQUIREMENTS yMeasurement, Sample ` Samples t,Fre enc e I ocahon+ Flowl Episodic 1 Effluent Total Suspended Solids 45.0 m Monthly Grab Effluent Oil and Grease2 Quarterly Grab Effluent Phenol Monthly Grab Effluent Benzene Quarterly I Grab Effluent Toluene Quarterly Grab Effluent Ethyl Benzene Quarterly Grab Effluent X lene Quarterly Grab Effluent MTBE3 Monthly Grab Effluent Acute Toxicit 4 Annually Grab Effluent Footnotes for All Outfalls 1. Flow — 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 Rational Equation below) 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." The Rational Equation: Q=KuCIA, where: Q = flow (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) Permit NCO031046 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. 2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone. 3. MTBE— See Condition A. (7) for additional details. 4. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A. (8.)]. The Permittee shall collect Acute Toxicity samples concurrently with BTEX sampling. There shall be no discharge of floating solids or foam visible in other than trace amounts. There shall be no direct discharge of tank solids, tank bottom water, or the rag layer. There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene concentration is less than 1.19 µg/l and toluene concentration is less than 11 µg/l. A. (6.) INSTREAM SAMPLING AND MONITORING REQUIREMENTS Beginning on the effective date of the permit and lasting until expiration, the Permittee shall collect instream samples and provide analyses as needed to evaluate the existing Water Pollution Prevention System. Such instream sampling shall be limited and monitored by the Permittee, as specified below. EFFLUENTtr •,Q,A R CHARACTERISTICS i a, LIMITS �t'' �vlYIONITO%NGtiRE UIREMENTS �: ,Monthly wd,?'c xux r Ave n" ( Dady4; 4t w w MaxtmumGv: 6SMeasurement t" #,t�vti + '�. r(t Frequency ;'Sample e w 9 s^ %yp „ 1Samples r Loc ti Total Suspended Solids Monthly Grab U,D Oil and Grease2 Monthly Grab U,D Phenol Monthly Grab U,D Benzene Monthly Grab U,D Toluene Monthly Grat_j U,D Ethyl Benzene Monty Grab U,D X lene MonthlyGrab U,D MTBE3 Monthly Grab U,D Footnotes: 1. Sample Location: U = Upstream; —75 feet above the influent pipe to the UT Pond located within the unnamed tributary (UT) to the East Fork of the Deep River (see Site Map). D = Downstream; immediately downstream of the UT Pond (formerly Outfall 006). 2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone. 3. MTBE — see Special Condition A. (7.) for other requirements relating to MTBE Permit NCO031046 A. (7.) MTBE SPECIAL CONDITION Methyl Tertiary Butyl Ether (MTBE) has been identified by the EPA as a potential human carcinogen. Although North Carolina has not established water quality standards for this compound, the state has concern about the discharge of treated wastewater with even small concentrations of MTBE, especially when the discharge is to water supply (WS) waters. Because MTBE has shown to be present in discharge from the outfalls permitted by NC0031046, monitoring for this parameter shall continue pursuant to the terms established in sections A (1) through A (6). Additionally, the permittee is required to submit a MTBE Reduction Plan within six months of the effective date of this permit. This plan may include site -specific Best Management Practices (BMPs) or engineering solutions. A copy of this plan shall be submitted to: North Carolina Division of Water Quality Surface Water Protection Section Attn: NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 The plan should be implemented without delay. The Division will review the plan and the results of monitoring to determine whether additional measures must be taken to deal with the discharge of MTBE. Permit NCO031046 A. (8.) ACUTE TOXICITY MONITORING (ANNUAL) The permittee shall conduct annual toxicity tests using protocols defined as definitive in E.P.A. Document EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste treatment. The permittee will conduct one test annually, with the annual period beginning in January of the calendar year of the effective date of the permit. The annual toxicity test must be performed by June 30. Should there be no discharge of flow from the facility during the six month period January 1-June 30, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number, county and in the comments section indicate "No Flow for January 1-June 30, (calendar year)." The report must be signed and submitted to the Environmental Sciences Section at the address noted below. If no discharge event occurs from January 1-June 30, vet a discharge event occurs from July 1-December 31, then the facility must perform toxicity monitoring and report the data as noted below. 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, N.C. 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Section 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. o�oF warF9QG Michael F. Easley, Governor � William G. Ross Jr., Secretary UJ North Carolina Department of Environment and Natural Resources p( Alan W. Klimek, P.E. Director Division of Water Quality October 25, 2006 MEMORANDUMRECEIVED - [� r-. _ Ln _^ I i1 N.C. Copt of ENR To: Lee Spencer J J ! , OCT 2 6 2006 NC DENR / DEH / Regional Engineer I1 I' NOV 2 9 2006 Winston. Salem Winston-Salem Regional Office Raelonalof i From: Bob Sledge NPDES Western Unit Subject: Review of Draft NPDES Permit NCO031046 µ Colonial Pipeline Company Guilford County Please indicate below your agency's position or viewpoint on the draft permit and return this form by December 6, 2006. If you have any questions about the draft permit, please contact me at (919) 733- 5083, extension 547, or via e-mail at bob.sledge@ncmail.net. RESPONSE: (Check one) �Concur with the issuance of this permit provided the facility is operated and maintained properly, —I 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: attachment cc: NPDES Permit File N�oor�ieh olina dvatura!/il North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone (919) 733-7015 Internet: www.ncwateiguality.org Location: 512 N. Salisbury St. Raleigh, NC 27604 Fax (919) 733-2496 An Equal Opportunity/Affirmative Action Employer — 501% Recycled/10% Post consumer Paper Customer Service 1-877-623-6748 Invoice Date: Fri, Oct 27, 2006 Invoice No: 8810061 Duplicate Customer Invoice NEWS & RECORD CLASSIFIED Acct: 9197335088NCD Phone: 9197335083 200 E. Market St., Greensboro, N.C. 27401 Client: NCDENR DWQ NPDES Copy Line: PUBLIC NOTICESTAT Invoice Name: NCDENR DWQ NPDES Address: ATTN CAROLYN BRYANT 1617 MAIL SERVICE CENTER County: NC PostCode: 27699 1617 Start 10/27/2006 Days I Lines... 58.00 Depth... 5.66 Columns... 2 Discount 0.00 Commission 0.00 Nett 282.96 VAT 0.00 Total 282.96 Payment 0.00 Agreed 0.00 Source FX Standby Type: Receipt No: Reply Request A P O q NPDES PERMIT Paytype BL Stop 10/27/2006 F4anC HOM STNE0FaquaCANDUaa 4aftalaaaExruM1waa EMENFmrla�aav NPD64aEr mr f4fAILSERVCECOM RNEKK W21MMU r1OFP nrD15�wWAN a�waremm arFearr0m A dksr On the bdsofthordr9haaffrrm Wanda bode of IJC General5tatutB 143g1, fNbiclax92-500 and othw lawful standard, and regulatwiL the North Carolina 5twmmantl Mngamnt Cammi bon pcpow ro iwe a Navml Pollutant Dizhrga 9lminaum 9reetn MWES)wart"atn di,dtrgapannRto tha W Mined bill" effedrva 45 dair, from tha ryJo%Ede of thmnotim 0ittn o>,nmannrgrd'myy thapapotd permit will bexcaptodwd30day, amn thalwdihdan, th, node. Al comment, racwad pinto the dea ra cmtldard in the fml denmindm,r ardny the ppopo,e�dp� mit Tha Diredaoftha N�Dmimof Wrtn tTrrt maydddatohddapudicmaadngfor rhapgz,d pwnk thodd th4Diuivm raoana a v9- nd'tmt deg« dM1rCiranea Comil Rpdin4 Camppxrihaf Vid fwrw"l of NPDESprmhlK0Bt04 witsGGan$poiamihln Gurlfpd County. Thi, permitted faaliey dixhrge, 4krmwrtnto an wnamd tnb~o the Eaa Fork Dare Rlvwlntha Cape FerRive9ain. Cw aan- vraryryandT fwn�d.oroaalan inti'd T'w.f Aacape FvM Gdn. pwemo Raraa%m Pipe Una Corn1 fyhnaOiedfa r~aiof W ES paaB R NMI l a b Geam1>ao f W dwm Breakwt Fa4lrtyin Cuilfwd Canry Thi, nrmiad fa th.Eathageago". i manalmF. RvvarB n the Eat Fork Deap Rionx Ira Cape Far Rivn Bdn. dtd�a'm a�certfwnimallaaoorn in 'piwti This dtaGpFaifinnlldn. A po-hm of Ad shown is not actual print size Rep 077 Class 400 This is A Duplicate Invoice 08:30:18 Please Include Invoice No. on your check. DENR / DWQ / NPDES Unit FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES Permit No. NCO031046 Facility Information Applicant/Facility Name Colonial Pipeline Company /Colonial Pipeline Greensboro Terminal Applicant Address 411 Gallimore Dairy Road, Greensboro 27409 Facility Address Same Permitted Flow (MOD) Five (5) Outfalls -- Not limited Type of Waste Industrial runoff wastewater. SIC Code 4613 W W Code Prim. 37; Second. 39; Main treat. Code 535_3 Facility/Permit Status Class I, Minor / Renewal Drain a Basin / County Cape Fear / Guilford Miscellaneous Receiving Stream UT of the East Fork of the Deep River Regional Office Winston - Salem Stream Classification WS-IV State Grid / USGS To o Quad C 19 SW / Guilford, NC 303(d) Listed? Yes Permit Writer Bob Sledge Subbasin 03-06-08 Date: May 29, 2006 Drainage Area (sq. mi.) 1.0 Summer 7Q 10 (cfs) 0.15 Winter 7Q10 (cfs) 0.20 30Q2 (cfs) 0.20 Average Flow (cfs) 1.0 IWC (%) Introduction Colonial Pipeline Company (herein referred to as Colonial Pipeline or the Permittee) requires a National Pollutant Discharge Elimination System (NPDES) permit to dispose treated wastewater to the surface waters of the state. The Permittee's 5-year NPDES permit has expired and they have requested renewal from the Division of Water Quality (the Division). This Fact Sheet summarizes background information and rationale used by the Division's NPDES Unit to determine permit limits and conditions. Facility Description Colonial Pipeline operates the Colonial Pipeline Greensboro Terminal, a petroleum pipeline - distribution and surface bulk -storage facility in Guilford County. This facility is permitted to discharge stormwater runoff, slab wash -down water, Prover-loopTM (or similar) calibration water, and hydrostatic tank -testing water through Outfalls 001 through 005 from the existing Water -Pollution Control System consisting of gravity -drained diked secondary -containment structures and soil remediation landfarm; a system utilizing ponds, oil/water separators, and discharge control valves; servicing manmade confinements identified as: Fact Sheet Renewal -- NPDES Peirnil NC00,31046 Page I Confinement Area Size (Acres) Oil / Water Separator Outfall Number Fuel Oil Tank Area / Kerosene and Jet Fuel Area 22.2 2 001 Fuel Oil Tank -Manifold Area 7.4 1 002 Pump Area 2.2 1 003 Gasoline & Utility Tanks / Gas Manifold Area 35.9 1 004 Meter -Out Area 1.6 1 004 Oily -Waste Landfill / Meter -In Area 13.3 1 005 Outfall Locations 001 1 002 003 004 005 Latitude 36.04.18 36.04.11 36.04.25 36.04.19 36.04.02 Longitude 59.56.11 79.56.18 79.56.15 79.56.29 79.56.36 Each of the permitted outfalls discharge into a(n approximately) 12 acre pond located on the Colonial Pipeline property that has been created by an impoundment of an unnamed tributary to the East Fork of the Deep River. In some previous permit cycles, discharge from the pond was referred to as Outfall 006. However, with the last permit reissuance, the pond was re- defined as "waters of the state," mainly because the Permittee does not control the entire discharge area to the pond as required for "discharge channels" [12A NCAN 02B.0228(1)]. The UT, and therefore, the pond receives storm water from offsite plus effluent from several other permitted dischargers upstream. While it is appropriate for the Permittee to use pond water for hydrostatic tank testing or other stated uses, it is not appropriate to return this water to the pond without first sampling, analyzing, and reporting. The pond's outfall has been designated as a downstream sampling point, and is to be monitored regularly (without permit limits). Considering the potential for unauthorized releases upstream, the Division also judges it prudent to monitor upstream of the pond. Waste Load Allocation (WLA) The Division reviewed the WLA completed in May 1991 and developed effluent limits and monitoring requirements. The Division judges these limits and monitoring requirements to be appropriate for this renewal with the exception of additions and deletions listed below (see PERMITTING APPROACH SUMMARY). Verifying Existing Stream Conditions This facility discharges to an unnamed tributary (UT) of the East Fork of the Deep River, a Class WS-IV stream within the Cape Fear River Basin. The East Fork of the Deep River is listed as an impaired waterbody on North Carolina's 303(d) list. This reach of the river has been placed on the list due to exceedence of water quality standards being observed for Turbidity and Fecal Coliform, and the observation of impaired biological integrity in the stream. The 2006 draft 303d list lists "MS4 NPDES" as the potential source for the impairment. The 2004 list showed "Urban Runoff/Storm Sewers" and "Industrial Permitted" as potential sources. Fact Sheet Renewal -- NPDFS NCO031046 Page 2 Compliance Review Discharge Monitoring Reports (DMR) -- Effluent Data Review. DMRs were reviewed from January 2002 through November 2005 (in some cases through March 2006). Discharges from Outfall 001 through 005 occurred episodically — non - discharge months were reported as "no flow." EPA 625 scans detected volatile organic compounds other than benzene, toluene, ethyl benzene, and xylene (BTEX) on only one occasion (Di-N-Octyl-phthalate detected at 14 ug/I from outfall 003 in March 2006). Benzene and Toluene exceeded permit limits for outfalls 003 and 004 on a number of occasions. Total suspended solids (TSS) levels occasionally exceeded permit limits at all outfalls. Notices of Violation (NOVs). The facility was issued NOVs for single event violations of the TSS limit for outfall 002 that occurred during August 2003 and November 2005. It has also been assessed civil penalties on 11 different occasions during the past permit cycle (another penalty case was withdrawn). BIMS shows one case (LV-2002-0226) is still unpaid and open. Most penalties were assessed for violations of TSS, benzene and toluene limits. Facility Inspections The Winston-Salem Regional Office (WSRO) last inspected this facility on October 20, 2005. On that date and on two previous inspections during the permit cycle, the facility was found to be in compliance with the terms of the NPDES permit. Whole Effluent Toxicity (WET) Test The facility has passed its annual acute toxicity test at all outfalls for the past eleven years (1996 through 2006). Permitting Strategy The permit was developed using a strategy and guidance found in a Point Source Branch document entitled "NPDES Permitting Requirements for Petroleum Bulk Storage: Surface Storage Greater than One Million Gallons — 2005 Permitting Strategy." This document is an update to the 2001 SOP for petroleum bulk storage facilities that guided development of the current permit. The document provides guidance specifically targeted toward the circumstances surrounding stormwater and other types of discharges common to petroleum storage facilities. As part of the permitting process, a Reasonable Potential Analysis (RPA) was run at each outfall for those parameters that had a limit or standard established and showed some detection for the parameter during the period of review. If a parameter was reported as the test method's minimum detection level for all sampling events, the RPA was not run, but decisions regarding limits and monitoring frequencies were made based upon that record of performance. Fa Slice[ Renewal -- NI>ptis NC0031046 PaEc 3 Phenol — Monitoring and Limits Calculations When combined with chlorine, phenol can cause taste and odor problems in drinking water, and can also result in the tainting of fish tissues. Therefore, in accordance with 2005 Permitting Strategy, all dischargers to state water supply (WS) waters shall conduct monthly effluent monitoring for phenol. Moreover, if analytical results suggest "reasonable potential," a phenol limit shall be included in the permit. A phenol limit magnitude depends on dilution. Ideally dilution would be calculated at the High Point Dam water plant intake where chlorine is introduced, but it is impractical at this time to measure dilution under lake conditions at the intake. Therefore, the Division calculated flow at the assumed headwaters of this water supply. Secondly, the Division used I µg/L (the aesthetic limit for phenol) to calculate a wasteload allocation in pounds per day' (lbs./day) at these headwaters. Finally, the wasteload allocation was distributed equally among phenol dischargers as a permit limit, only as each facility's data -set showed reasonable potential to exceed the water quality stream standard. Currently nine (9) bulk storage facilities discharge to either the East Fork Deep River or Long Branch. The confluence of these two drainages was assumed to approximate the headwaters of High Point Lake, the nearest downstream intake waterbody. For purposes of yield calculations, Long Branch was assumed to have a similar runoff coefficient as the East Fork of the Deep River. The Division used published 30Q2 flows from an EPA stream gauge (02099000) located on the East Fork Deep River near the confluence of the two drainages. The 30Q2 flow, not the 7Q10, was deemed appropriate because of the aesthetic standard for phenol. Flow Calculations: Given: Flow (30Q2) East Fork Deep River = 3.8 cfs (USGS Gauging Station) Drainage Area East Fork Deep River = 14.8 mil (USGS) Drainage Area Long Branch = 3.84 mil (measured from USGS topo) Total Drainage Area = 14.8 mil + 3.84 miZ = 18.6 miZ Yield = East Fork Flow (cfs) East Fork Drainage Area (miZ) = 3.8 cfs 14.8 miZ 0.257 cfs/miZ Therefore: Total Flow = Yield x Total Drainage Area 0.257 cfs/miZ x 18.6 miZ 4.7 cfs Fact Shed Renewal -- NPDFS NC0031046 Page 4 Wasteload Calculation: 4.7 cfs x 0.001 mg/L 1.55 8.34 = 0.025 lbs./day distributed among nine dischargers = 0.025lbs./day 9 dischargers 0.003 lbsJday per discharger The allocation is then distributed equally among all outfalls to determine "reasonable potential" for phenol. With 5 outfalls, the allocation per outfall becomes 0.0006 Ibs/day. Outfall 001 Phenol Limit Example: Maximum reported flow: Limit = Allocated wasteload (Ibs./day) 8.34 lbs./MG 0.0006lbs./day x 1.00 8.34 0.2676 0.00007 mg/L = 0.07 µg/L 0.2676 MGD (for Outfall 001) 1.00 mgIL Maximum Reported Flow (MGD) In this example, a maximum allowable concentration (based upon the allocation and the highest flow reported during the period of review) was determined (0.07 µg/L) and included as an input in the analysis in order to determine whether there is "reasonable potential" that the discharge from Outfall 001 may cause the water quality standard for phenol to be exceeded. Similarly for the remaining outfalls, the Division calculated corresponding phenol levels (based on maximum flow) as a "standard" against which to determine "reasonable potential." These numbers are: 002: 1.42 ug/L 003 0.95 ug/L 004 0.08 ug/L 005 1.42 ug/L Reasonable Potential Analysis (RPA) The Division conducted the EPA -mandated RPA on Colonial Pipeline's reported data for four of its five outfalls (where discreet values were reported). The RPA compares the "allowable concentration" (based on water quality standard or criteria) against the "maximum predicted" concentration based on data submitted (January 2002 through March 2006). Significant results of the RPA, and the decisions those results led to, are summarized below. Outfall 061 Oil & Grease 2005 strategy does not call for inclusion of limit. Additionally, reasonable potential not found. Removed limit. Decreased monitoring from Monthly to Quarterly due to consistent performance, reporting less than detect for all months except July 2002 (5.3 mg/L). Fact Shect Renewal -- NPDES NC00? 1046 Page 5 Phenol All values except one (December 2002) were reported as less than detect. RPA did show reasonable potential (program would show reasonable potential if no phenol was detected), but outfall shows long-term good performance for the parameter. Removed limit; retained monthly monitoring, in line with the permitting strategy. BTEX Only two instances of detection for these parameters noted during the period of review, and these were not significant. Reduced monitoring to quarterly for each parameter. MTBE Though it has been identified as a potential carcinogen, no standard has been established for this parameter. Outfall showed 5 hits out of 47 samples during POR. One did equal the proposed water quality standard for MTBE in water supply waters (12 ug/L); the other four were well below. The last reported hit was in March 2004 (1.1 ug/L v. MDL of 1.0). Based upon overall performance, especially most recent performance, reduced monitoring to quarterly. EPA 625 Analysis Each test taken during the permit cycle came back with no detection for all parameters. Removed per terms of strategy. Outfall 002 A RPA was not performed on data from Outfall 002. All reported values were less than detection levels for all parameters, except where noted below. Oil & Grease Removed limit. Decreased monitoring from Monthly to Quarterly due to consistent performance. Phenol Removed limit; retained monthly monitoring, in line with the permitting strategy. BTEX Reduced monitoring to quarterly for each parameter. MTBE Outfall showed 3 hits out of 35 samples during POR, each at 1.5 ug/L, the last hit reported from February 2004. Based upon overall performance, especially most recent performance, reduced monitoring to quarterly. EPA 625 Analysis Each test taken during the permit cycle came back with no detection for all parameters. Removed per terms of strategy. Outfall 003 Oil & Grease Removed limit. Decreased monitoring from Monthly to Quarterly due to consistent, compliant performance. F= sheel Renewal -- NPDES NC003I046 Page 6 Xylene Removed limit. RPA showed no reasonable potential for discharge to lead to violation of water quality standards. EPA 625 Analysis Each test taken during the permit cycle came back with no detection for all parameters. Removed per terms of strategy. All other monitoring frequencies and limits retained as shown in current permit. Outfall 004 Oil & Grease Removed limit. Decreased monitoring from Monthly to Quarterly due to consistent, compliant performance. Xylene Removed limit. RPA showed no reasonable potential for discharge to lead to violation of water quality standards. EPA 625 Analysis Each test taken during the permit cycle came back with no detection for all parameters. Removed per terms of strategy. All other monitoring frequencies and limits retained as shown in current permit. Outfall 005 A RPA was not performed for all parameters reported for Outfall 005. All reported values were less than detection levels for all parameters, except where noted below. Oil & Grease Removed limit. Decreased monitoring from Monthly to Quarterly due to consistent performance. Only 2 discreet hits during POR; neither significant, no reasonable potential. Phenol All values except one (December 2002) were reported as less than detect. RPA did show reasonable potential (program would show reasonable potential if no phenol was detected), but outfall shows long-term good performance for the parameter. Removed limit; retained monthly monitoring, in line with the permitting strategy. BTEX Removed limits for benzene, toluene and xylene. Reduced monitoring to quarterly for each parameter. EPA 625 Analysis Each test taken during the permit cycle came back with no detection for all parameters. Removed per terms of strategy. All other monitoring frequencies and limits retained as shown in current permit. Fact sheet Rene%cai -- NPDGS NC0031046 Page 7 For all outfalls A more detailed footnote has been added regarding the calculation of flow. Nothing has changed in the matter of substance. Because MTBE was detected at each outfall during the past permit cycle, and because the facility did not submit,a MTBE action plan during the permit cycle, Colonial Pipeline will be required to submit a plan to inform DWQ how it will work to reduce or eliminate the discharge of MTBE in its effluent. Proposed Schedule of Issuance Draft Permit to Public Notice: October 25, 2006. Permit Scheduled to Issue: December 18, 2006 NPDES Unit Contact If you have questions regarding any of the above information or on the attached permit, please contact Bob Sledge at (919) 733-5083 ext. 547. (e-mail: bob.sledge@ncmail.net) Pact Shcc1 Renewal -- NPDGS NC00. 1046 Page S REASONABLE POTENTIAL ANALYSIS Colinial Pipeline WWTP NCO031046 Time Period January 2002 - March 2005 0W(MGD) 0.2676 WWTP Class 1 701 OS (cls) 0.15 IWC (%) is 7010S 73.441 7010W (cis) 0.2 @ 701OW 67.468 3002 (cis) 0.2 O 3002 67.468 Avg. Stream Flow, OA (cis) 1 ® OA 29.318 Reeving Simem UT to East Fork Deep River Stream Class WS-1v Outfall 001 Ow = 0.2676 MGD STANDARDS a PARAMETER TYPE CRITERIA(2) POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION DI Nc W0.1/ aFAY/ TpL Y4F nNM AWwEYL1 Tomb A[ub Acute: WA Phenol A 0.07 uyL 47 1 55.5 Chronk:.__O._ Acute: WA Be. C 12 ug/L 47 D 4.2 Chronic 4._ Mule'. WA Toluene NC 11 ug'L 47 1 47 Chromic: 15_ Mule', WA Ethyl Berchene NC 520 ug'L 46 0 0.5 Chronic:-_.70 Acute: WA Xyl.. NC 780 ug4. 47 1 54,7 Chronic'. 1,062 Acute: WA WINE NC 12 uyL 46 5 27.7 Chronic _fi Mute: WA Oil S Grease NO 30 mg4 47 1 6.2 Chronic:__.41_ Mute: WA 0 0 WA Chronic, ahor o True Mute: WA 0 0 WA Chrouk: 9ra 0 TYPe Mute'. WA 0 0 WA Cli chic: ins O Trier Mute: WA 0 0 WA Chros,k: 'nor O Type Mute'. WA 0 0 WA Chronic: i..OType -_._-_-_-_._._.___.............. Mute: WA 0 0 WA Chronic'. Frio, O True -------------_ Acute: WA 0 0 WA Chronic'. irror 0 Type --------�-- '-_-------- — Mute: WA 0 0 WA LegeM: " FeshweteF O'scherye C. Cercimeenlc NC. Ns, ,hohcperac A. M4rhelk 3 t046001 loss, 05162006, rm 12/1412006 REASONABLE POTENTIAL ANALYSIS Colinial PipelineWWTP NCO031046 Time Period January 2002-March 2006 OW(MGD) 0.0507 WWTP Class 1 70105 (ds) 0.15 IWC (%) ® 7010S 34.379 7010W (c/s) 0.2 0 701OW 28.2D9 3002 (c/5) 0.2 03002 28.209 Avg. Slmam Flow, OA (cls) 1 O OA 7.2859 Rec'ving Stream UT to East Fork Deep River Stream Class WS-IV Outfall 002 Qw = 0.0507 MGD STANDARDS& PARAMETER TYPE CRITERIA 2) POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION M No M, *'AV' Tdt kii.�L1r A4anaMM, C —1. Aeub Mute'. WA Phenol A 1.42 ugL 42 1 Its Chronic.._. 5._ Mute: WA Be.. C 1.2 ugrL 43 4 143.0 Chronic '_-16 _ Mute: WA Toluene NC 11 ug/L 42 11 124.7 ._.32 Chronic: Mute: WA Ethyl aufmlp NC 520 ug'L 0 0 WA Chronic: 1,513 Mute: WA %ylgue NC 750 Ug'L 0 0 WA Chronic: 2,269 Mule: WA MTBE NO 12 up'L 0 0 WA Chrmic:- -35 _. _._____._._ Mute: WA 0 0 WA Chrmic: Dror 0 Typo Mule: WA 0 0 WA _ _ _ _ Chronic: }rm O Type . Mute: WA 0 0 WA Chronic: 31.10 Type Mute'. WA 0 0 WA _ Chronic: irror O Typo_._._. _._._._._._._.__ Mute: WA 0 0 WA Chronic:-nar OType ._._._.___._._._._._._._. Mute: WA 0 0 WA Chronic: 'nor O TYPe ._. _._._._._._._._._._._. _._.___ Muto: WA 0 0 WA Chrmic: --nor 0Type ACule: WA 0 0 WA Chr. Sror 0Type MNe: WA 0 0 WA Chronic: inor O Tyce 'Legend. "Freshwater Di No e Ca Carovopank NC- Nm<eminogenlc A . Aeslhetk 31 WB 002 rpa 05162006, rpa 1VIQ2006 REASONABLE POTENTIAL ANALYSIS Colinial PipelineWWTP NC0031O46 Time Period January 2002 - March 2006 0.(MGD) 0.76 WWIP Class 1 70IDS (c(s) 0.15 IWC (%) 0 7010s 88.65 7O 10W (015) 0.20 O 7O10W 85.42 3002 (cIs) 0.20 03002 85.42 Avg. Stream Flow, OA Ida) 1.00 O CA 53.96 Roc'ving Stream UT to East Fork Deep River Stream Class wS4V 0ulfall 003 Ow = 0.756 MGD 9TANOARDS 4 PARAMETER TYPE CRITERIA(2) POL Units REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION II) wmf 6FAY1 Fp[ araRMM dNnN/M Llxmb AM Mute: WA Phenol A 0.95 u{yL 42.0 1.00 12,25 Chronic'. --I'll Mule: WA Sermons C 1.19 cool 43.00 4.00 142,97 CM1orric .2.21 Mule: WA Toluene NC 1I'M uooL 42.0011.00 10642 Chronic'. 12.41 Mute: WA Moll Bacon NC 520.00 ug/L 42.00 201) 4.85 _ Chronic 5W 56 Mule: WA %yMno NC 780.M uooL 43.00 S00 250.88 _ Chronic: 879.85 Mute: WA MTBE NC 12.M uool 37.002100 134547 Chronic: 13.51 Mule: WA OII6 Graeae NC 30.M ong442.001.00 7.32 Chronic: 33.04 Mule: WA D.00 am WA Chronic: 9mr O Type Muto: WA 0.00 0.00 WA " Chronic irrar 0 Type ._._ _ _._._._._._ Mule: WA 0.00 0.00 WA Chmnb: irrar O Type ._._.___._._._._._._._._._._._ _ Mule'. WA 0.00 0.00 WA Chronic: :nor O Typo_. -._._. _._._._._. _.__ Mute: WA am am WA Chronic wor 0 Tyye . Mule'. WA 0.00 0.00 WA Chronic: irrar O Type Mule: WA 0.00 D.00 WA CMonic:1.O Tyya Mule: WA 0.00 0.00 WA I _ I Chronic. Error 0 Trip Legand: "Fhwh.MrDhchaW C- Cominoganic NC- Nencarchrogenk MNS DOD roe 05172006, rpa 12114 006 REASONABLE POTENTIAL ANALYSIS Colonial PipelineWWTP NC0031046 Tine Period January 2002 - March 2006 OW(MGD) 0.9084 WWTPCIess I 7O10S (Cis) 0.15 /WC (%) O 7O10S 90.372 7010W (cis) 0.2 O 7O1OW 87.562 3002 (cis) 0.2 03002 87,562 Avg. Stmen Flow, OA (cis) 1 O OA 58.472 .Rec'ving Shan. UT to East Fork Deep River - Streen Class W84V Outfall 004 Ow = 0.9064 MGD STANDARDS & PARAMETER TYPE CRRERIA(2) POL Unite REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION waa Nf,1Y/ RMrent MUCV 1Wo54M III m—k kub Aculc: WA Phenol A t ualL 0 0 WA Chronk: 1 Mute'. WA Benders C 1.2 ug . 47 6 7.8 Chronic :__. 2._ Mute: WA Toluene NO It uA 46 3 310 Chronk: 12 _.__.___._._._._._._._._._._.___ MNO: WA Ethyl Beneers NC 520 Up1. 0 0 WA — Chmmc: 575-- _---- Mute: WA kylene NO 780 uWL 0 0 WA Chronic: 863_- Mute: WA MTSE NC 12 uWL 0 0 WA Mute: WA Oil &Oners NC 30 mall. 47 1 K2 ' __ Chmnb: 33__ _._._ _._._._ _ _._._._____._ _ Mute', WA 0&COOS NC 30 mWL 37 2 12.9 Mute'. WA 0 0 WA Chonic::nOr O Type Mute'. WA 0 0 WA Chronic::rrar O Typo Mute: WA 0 0 WA Chr0nic irrar0 Tyy6 _._._._.___ Mute: WA 0 0 WA Chronic: Inor 0 TYW Mv1e: WA 0 0 WA Chronic: ln.OType Mute: WA 0 0 WA Chronic: irror O Tyne MWe: WA 0 0 WA Chronk:!nor O TYpa Legend: " Freehweler Dlschage CCeminogenk NC. Non-d rcinoge A MsM.Ud 31 Due 004 no 051 M006, r, t014/T006 MapQuest: Maps http://www.mapquest.com/maps/print.adp?mapdata=IkA%252fomiQ PAPkPQVESr [144-159] Thatcher Rd Greensboro NC 27409 US Notes: Colonial Pipeline site in the SE quadrant of this map, south of I-40 CaKI or Triad or "vier Jed a t zry� 43 Ir C.unNp .3 Prs+fihrerN ai o Tr1bm►InCI FrfWKWOV AOorr r7 m a w a �i Cwl4sI7a Dr y �o -l!G II1Ql��S.__Va�r �a C ZWG Maoowt• In 02006 NAVTEQ All rights reserved. Use Subject to License/Copyright This map is informational only. No representation is made or warranty given as to its content. User assumes all risk of use. MapQuest and its suppliers assume no responsibility for any loss or delay resulting from such use. Iof1 5/30/2006 2:15 PM Colonial Pipeline Company Creating Excellence in Transportation Services FARON D. LEIGH Environmental Specialist Friday, February 10, 2006 Mr. Bob Guerra NCDENR/Water Quality/NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Colonial Pipeline Company - Renewal Application NPDES Permit NCO031046 Greensboro Terminal Guilford County Mr. Guerra: Telephone: 336-294-9737 Facsimile: 336-292-6462 FEB 1 5 2006 Colonial Pipeline Company requests renewal of the above referenced NPDES permit. Please find enclosed one original and two (2) copies of the renewal application. We have a total of five (5) outfalls at this facility that mainly treat stone water through oil/water separators and/or retention ponds and basins. Other than storm water, we sporadically generate wastewater from equipment wash down slabs, hydrostatic test water, and prover -loop calibration water. Our operation does not generate sludge and/or solids and, therefore, we do not have a sludge management plan. 1 have included a copy of our watershed runoff— effluent Flow with this application. While we are in the renewal process, I respectfully request consideration for the following changes and/or amendments to our new permit: Because of new EPA regulations regarding sulfur content in diesel fuel, we are currently constructing two (2) new tanks at this facility. They are both being built in the area of our facility that discharge through outfall 001, adding approximately 46,000 square feet of impervious surface in this area. This will result in an increase of approximately 7 percent (.07) to our storm water discharge total through this outfall. This change will be included in the spreadsheet we use to calculate stone water runoff using the rational method and a runoff coefficient of 50 percent. Included with this renewal package are blank copies of the spreadsheets used to calculate storm water discharges based on rainfall results found in the Detailed Reports at the Piedmont Triad Weather website. • Since we have never had a detection of the single -compound phenol in any of our discharge water samples, would like to request that the monitoring frequency for phenol be reduced from monthly to semi-annually. This could be included with our EPA 625 requirement. We feel that analyzing total phenolics as an indicator for phenol on a monthly basis adds little value. Due to the sensitive characteristics of much laboratory analytical equipment, we would like for our benzene concentration limit be increased from 1.19 micrograms per liter (ug/L) to 2.0 ug/L. There have been a few times in the past where our discharge samples from certain outfalls have resulted in concentrations of benzene ranging from 1.2 ug/L to 1.6 ug/L, resulting in non -compliances. Although we fully understand the need to protect all surface water bodies, especially WS-IV classified waters, and we definitely do not want to have a negative impact on any of our receiving streams, it is somewhat difficult to believe that there isn't laboratory error associated with some of these results. Also, since we have never had a detection of benzene in any of our downstream samples, we believe that if these low levels of benzene truly are present, they are dissipated/evaporated or fully diluted before they actually leave our property. 411 Gallimore Dairy Road Greensboro, North Carolina 27409 Colonial Pipeline Company Creating Excellence in Transportation Services One last consideration involves Total Suspended Solids (TSS). Although we believe we have excellent Best Management Practices (BMPs) implemented with regards to our erosion control program, there are times during significant rain events where our TSS concentrations exceed our permit limit of 45 milligrams per liter (mg/L). However, even though we have had minor exceedences, the concentrations from our outfalls are generally much lower than the concentrations from our upstream samples. In addition, in most cases, the downstream samples are below our permit limit. I guess basically what I am trying to say is that, although we have had exceedences from time to time, because the size of our main lakes and their retention time capabilities, we have actually mitigated impacts to our downstream waters. I would like to include a condition or some additional language in the permit that reads something like; "If the TSS concentration exceeds 45 mg/L due to natural background conditions, the discharge level cannot cause any increase in the TSS concentration in the receiving water." One of Colonial's core values is the protection of our environment and we certainly want to continue in our efforts to comply with all permit limits and conditions and we also understand there are accountabilities to our neighbors and the public in general, as there should be. I also realize I have looked into some of the above areas of concern from more of a practical standpoint and I certainly don't want it to appear that we are asking for special allowances or concessions that would negatively impact the waters of the state or our downstream neighbors. It may be that these permit conditions are non-negotiable and, if that's the case, I fully understand. However, I would appreciate it if you could look into these requests and see if any of them could be considered. Please note that we will continue discharging hydrostatic test water directly to the main lake after receiving results from representative sampling that the water in the tank and/or pipe is below the permit limits for Benzene, Toluene, Ethyl Benzene and Xylene (BTEX). As agreed upon in the past, this greatly reduces environmental impact because it removes the possibility of soil erosion that could occur when discharging through the earthen dike areas. We will continue reporting hydrostatic test water discharges on individual Discharge Monitoring Reports (DMRs) and they will be identified as "Hydrostatic Test Water — Tank # ????". An example of the DMR is included with this package. Thank you very much for your assistance with this permit renewal and also for considering our requests for changes. If you have questions or require additional information, please contact me at (336) 294-9737 or at the letterhead address. Sincerely, Faron D. Leigh Enclosures cc: Jeff W. Richards, Colonial Pipeline Company, District Environmental Project Manager - w/enclosures 411 Gallimore Dairy Road Greensboro, North Carolina 27409 Q�X__Iv NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities ; Mail the complete application to: N. C. Department of Environment and Natural R Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699 NPDES Permit Number INCO031046 If you are completing this form in computer use the TAB key or the up field to the next. To check the boxes, click your mouse on top of the box..;0 1. Contact Information: Owner Name Facility Name Mailing Address City State / Zip Code Telephone Number Fax Number e-mail Address Colonial Pipeline Company Colonial Pipeline Company 411 Gallimore Dairy Road Greensboro NC / 27409 (336)294-9737 (336)292-6462 FLeigh@Colpipe.com 2. Location of facility producing discharge: Check here if same as above Street Address or State Road City State / Zip Code County urces F E B 1 5 2006 t c , xm-arrows to_move` .;,m one nofserpleaseprint .or;type h, 3. Operator Information: Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the Operator in Responsible Charge or ORC) Name Mailing Address City State / Zip Code Telephone Number ( ) Fax Number Page 1 of 4 C-MI 03105 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 4. Ownership Status: Federal ❑ State ❑ Private ® Public ❑ 5. Standard Industrial Classification (SIC) code(s): 4613 6. Number of employees: 45 7. Describe the treatment system List all installed waste treatment components with capacities, describe the processes that generate wastewaters. If the space prodded is not sufficient attach a separate sheet of paper with the system description. This facility discharges stormwater runoff, slab wash -down water, prover -loop (or similar) calibration water, and hydrostatic test water (through Outfalls 001 through 005) from the existing Water -Pollution Control System consisting of gravity -drained diked secondary - containment structures and soil remediation landfarm; a system utilizing ponds, oil/water separators, and discharge control valves. S. Is facility covered under federal effluent limitation guidelines? No ® Yes ❑ If yes, specify the category? 9. Principal product(s) produced: N/A Principal raw material(s) consumed: N/A Briefly describe the manufacturing process(es): Transportation of refined petroleum products by pipeline. Page 2 of 4 C-MI 03/05 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 10. Amount of principal product produced or raw material consumed [List soecific amounts consumed and/or units of vroduction over the last three nears) Product Produced or Raw Material Consumed AVERAGE Product Produced or Raw Material Consumed PEAK per Day N/A N/A per Month N/A N/A per Year N/A N/A 11. Frequency of discharge: Continuous ❑ Intermittent If intermittent: Days per week discharge occurs: Varies Duration: Varies 12. Types of wastewater discharged to surface waters only Discharge Flow GALLONS PER DAY Sanitary - monthly average 0 Utility water, etc. - monthly average 0 Process water- monthly average 0 Stormwater - monthly average 56,000 Other - monthly average Explain: Hydrostatic Test and Calibration Water 86,000 Monthly Average total discharge (all types) 142,000 13. Number of separate discharge points: 5 Outfall Identification numbers) 001, 002, 003, 004, 005 14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including latitude and longitude): Un-named tributary to East Fork Deep River Page 7 of 4 C-MI 03/05 l NPDES PERMIT APPLICATION — SHORT FORM C — Minor Industrial Minor industrial, manufacturing and commercial facilities. 15. Effluent Data Provide data for the parameters listed. Temperature and pl-I shall be grab samples, for all other parameters 24-hour composite sampling shall be used. If more than one analysis is reported, report daily maximum and monthly average. If only one analysis is reported, report as daily maximum. Parameter Daily Maximum Monthly Average Units of Measurement Biochemical Oxygen Demand (BOD5) N/A N/A N/A Chemical Oxygen Demand (COD) N/A N/A N/A Total Organic Carbon N/A N/A N/A Total Suspended Solids 45.0 26.0 mg/L Ammonia as N N/A N/A N/A Temperature (Summer) N/A N/A N/A Temperature (Winter) N/A N/A N/A pH N/A N/A N/A Fecal Coliform (If sanitary waste is present) N/A N/A N/A Total Residual Chlorine (if chlorine is used) N/A N/A N/A 16. List all permits, construction approvals and/or applications (check all that apply and provide permit numbers or check none if not applicable}. Type Permit Number Type Permit Number Hazardous Waste (RCRA) UIC (SDWA) NPDES PSD (CAA) Non -attainment program (CAA) NCDO57038168 NESHAPS(CAA) Ocean Dumping (MPRSA) NCO031046 Dredge or fill (Section 404 or CWA) Other 02939Y19 17. List any chemicals that may be discharged (Please list and explain source and potential amounts.) Benzene - Constituent of gasoline - <5.0 ug/L Ethyl Benzene - Constituent of gasoline - <5.0 ug/L Toluene - Constituent of gasoline - <5.0 ug/L Xylene - Constituent of gasoline - <5.0 ug/L MTBE - Constituent of gasoline - <5.0 ug/L 18. Is this facility located on Indian country? (check one) Page 4 of 4 C-MI 03/05 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. Yes ❑ No 19. Applicant Certification I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. Printed name of Person Date North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false statement representation, or certification in any application, record, report, plan, or other document files or requiredto be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) Page 5 of 4 C-MI 03105