NC0082970_staff comments_20200422 (2)

Weaver, Charles
From: Weaver, Charles
Sent: Wednesday, April 22, 2020 8:42 AM
To: Bilski, Sarah
Cc: Hennessy, John; Tharrington, Tom; Georgoulias, Bethany
Subject: RE: Public Records Request - A. Turley - 1002 S. Front St / Wilmington
Attachments: NC0082970 Monitoring Report Violations Export.xls; NC0082970 Permit Enforcement History By
Permit.xls
Sarah — the problem you've encountered is a common one when dealing with oil terminals.
There are 4 clusters of oil terminals in NC:
Selma
Paw Creek (near Charlotte)
Greensboro
Wilmington
Each cluster has many permits of various types. Our problem is the constant mergers and restructuring of the oil
companies. Nearly all of the terminals have changed hands multiple times, sometimes twice within one permit cycle. If
the company personnel don't know all of the permits that the facility holds, they may not request a change of ownership
for all of them. Or, depending upon the permit type, some permits get transferred and some don't; groundwater
remediation systems (and their permits) tend to stay with the original owner (responsible party or "RP") regardless of
other transactions.
There have been 3 permits issued for the terminal at 1002 S. Front St in Wilmington:
NCG510043 was a groundwater remediation permit issued to JLM Terminals in May 1993. It was allowed to expire in
2001.
NC0082970 is an NPDES individual permit originally issued to CTI of North Carolina, Inc. in June 1993. It was last
renewed in December 2016 and expires 12/31/2021. NC0082970 includes a groundwater remediation discharge, so it's
possible JLM Terminals got CTI to take over the old NCG510043 discharge, or JLM may have been purchased by CTI.
SW8170123 was issued to Colonial Terminals, Inc. in January 2017. It's a state stormwater permit for a facility named
"Colonial Terminals Maintenance Dredging", though the facility address is 1002 S Front St.
I've attached a permit enforcement history and violation history for NC0082970.
I've copied Bethany Georgoulias in the SW program to see if she has any violation/enforcement history for SW8170123.
I've also copied Tom Tharrington in the WiRO in case he can share any info about how/why the permits are spread
among multiple owners.
Let me know if you need anything else.
CHW
From: Hennessy, John <[e-mail]>
Sent: Tuesday, April 21, 2020 1:52 PM
To: Weaver, Charles <[e-mail]>
Subject: Fw: Public Records Request - A. Turley - 1002 S. Front St
Charles,
i

Can you look into this please?
From: Bilski, Sarah <[e-mail]>
Sent: Tuesday, April 14, 2020 11:29 AM
To: Hennessy, John <[e-mail]>
Cc: Mack, Janet <[e-mail]>; Johnson, Robert E <[e-mail]>
Subject: Public Records Request - A. Turley - 1002 S. Front St
Hi John,
I hope you and your team are staying safe during these uncertain times.
I am going back and cross checking all open requests. I must've missed this one where Sarah Young suggests
forwarding the information to your team to pull the information. I'm not sure if being away from physical files
would affect pulling data, but let me know if I should put this one on hold until after the shutdown.
Thank you!
Sarah Bilski
pu' = Records Officer
North Carolina Department of Environmental Quality
Division of Water Resources
919.7.7.9141
[e-mail]
Erna correspondence sent to and from this address may be subject to the provisions of ( r :32-1, the North
Caggire pUINIC Retor 5 Lavin and may bt autijtzt to h14rlitct ring arc' disokocil to dike c r: - .1%.7tuf.lioir
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From: Young, Sarah
Sent: Thursday, March 26, 2020 3:02 PM
To: Bilski, Sarah <[e-mail]>
Subject: Re: *quick question* Public Records Request - A. Turley - 1002 S. Front St
John Hennessy
Get Outlook for iOS
From: Bilski, Sarah <[e-mail]>
Sent: Thursday, March 26, 2020 2:53:42 PM
To: Young, Sarah <[e-mail]>
Subject: RE: *quick question* Public Records Request - A. Turley - 1002 S. Front St
I looked under the enforcement tabs and only the NPDES WW permit has anything listed. I attached a
screenshot. Would this be an appropriate question for Julie's staff?
Thanks!
2

Sarah Bilski
Puhrrc Records Officer
rcer
North Carolina Department of Environmental Quality
Division of Water Resources
919.707.9141
[e-mail]
Errai correspondence sent to and from this address may be subject fo the provisions of &S. 132-1, the islorth
tagfrne pUNIC Rccaa?s LffOir and may be Subject fiCtrLtidarrfg and Cis t wer to tilled Pa11 r o rsudire raw
enforeerrentpersonne{ byarrawtbolted state o roar,
From: Young, Sarah
Sent: Thursday, March 26, 2020 1:35 PM
To: Bilski, Sarah <[e-mail]>
Subject: Re: *quick question* Public Records Request - A. Turley - 1002 S. Front St
The person entering the info in bins apparently used two different names. I would look under the violation
history or enforcement the tabs before reaching out to staff. Thanks!
Get Outlook for iOS
From: Bilski, Sarah <[e-mail]>
Sent: Thursday, March 26, 2020 1:28:25 PM
To: Young, Sarah <[e-mail]>
Subject: *quick question* Public Records Request - A. Turley - 1002 S. Front St
Hey Sarah,
Is it normal for an address (in this instance 1002 S. Front St) to have two separate active permits under two
separate facility names? For example, I searched the address and came up with 2 hits in BIMS but for two
separate permits (one for NPDES WW & the other SW) which isn't uncommon, but my question is why would
they be labeled under different facility names? A google search didn't provide a clear address name for the
site/facility.
(1) Wilmington Terminal Facility has an active NPDES WW permit NC0082970
(2) Colonial Terminal Maintenance has an active SW permit SW8170123
I figure I will reach out to Annette and Julie respectively for each of the permits enforcement data since I did
see some for both permits in BIMS. Just wondering if this is normal, or who I should ask for these answers.
Thanks!
Sarah Bilski
Puhrrc records Officer
North Carolina Department of Environmental Quality
Division of Water Resources
919.707.9141
sarah.bilskiginccienr.gov
Errei correspondence sent to and from this address may be subject to the provisions of as. 132-1, the North
▪ Pi.mc Recard5 Law,. and may be autijtzt fiCtri ti ibig and diadawd tO Chia? Pastim, incrudri aw
• -=reentpersonne{ by art authorized state o roar,
From: Young, Sarah
Sent: Thursday, March 26, 2020 1:24 PM
3

To: Bilski, Sarah <[e-mail]>
Subject: Re: [External] Public Records Request - Adam Turley - 3-26-2020
Cool, sounds good!
Get Outlook for iOS
From: Bilski, Sarah <[e-mail]>
Sent: Thursday, March 26, 2020 12:54:31 PM
To: Young, Sarah <[e-mail]>
Subject: RE: [External] Public Records Request - Adam Turley - 3-26-2020
Will do! Also, FYI, I am in the process of working with staff and Kyle to complete his other submitted request
from March 12.
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Sarah Bilski
North Carolina Department of Environmental Quality
Division of Water Resources
919.707.9 .4'
sarah.bilski. ncdenr.gov
Errai correspondence sent to and from this address may be subject to the proOsians of QS.:52-1, the North
121‘01indi PUNICRe[ It Law, aria may oase pa to MOM tdfirfgarid Gi3cidSCG tG d1.ifU' oarte5, o crudrr g oaw
enforcementperswtnei byanavthorized state offroia+,
From: Young, Sarah
Sent: Thursday, March 26, 2020 12:13 PM
To: Bilski, Sarah <[e-mail]>
Subject: Fwd: [External] Public Records Request - Adam Turley - 3-26-2020
Please see if there is anything enforcement related for the addresses in this public records request.
Thanks.
Get Outlook for iOS
From: Adam Turley <[e-mail]>
Sent: Thursday, March 26, 2020 12:08:07 PM
To: Nasif, Zaynab R <[e-mail]>; Leonard, Laura <[e-mail]>; Young, Sarah
<[e-mail]>; Johnson, Robert E <[e-mail]>
Subject: [External] Public Records Request - Adam Turley - 3-26-2020
CAUTION:
External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
ncov
Please find attached a public records request for various EH&S documents you may have on file for the addresses listed
in the attached request. Please let me know if you have any questions about the request.
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Thank you for your assistance in this matter.
Best,
SLR"""
Adam Turley
Staff Consultant
lel 832-698-3028
CO 281-351-2856
ID 281-467-4181
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