NC0003549_Wasteload Allocation_19880825

NPDES DOCUMENT SCANNING COVER SHEET
NPDES Permit: NC0003549
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Correspondence
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: August 25, 1988
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content on the reverse side

a.
I.
DIVISION OF ENVIRONMENTAL MANAGEMENT
August 25, 1988
MEMORANDUM
TO: Arthur Mouberry
THROUGH: Steve Tedder
FROM: Trevor Clements
SUBJECT: Comments regarding Shell Oil Co. objections
NPDES No. NC0003549, Johnston County
I have reviewed the letter from Shell Oil requesting relief from several
proposed parameters in the permit and a reduction in monitoring requirements.
It should be noted that these parameters are being applied to contaminated
runoff from all tank farms, which recent studies have shown to be of concern.
The par peters should remain in the permit as recommended. The facility may,
after 12 months of monitoring, rerequest an evaluation of these requirments.
With regard to the facility's comments on phenols, the limit must remain
intact. The purpose of the limit is to protect the downstream water supply from
taste and odor problems associated with phenolic compounds. The state standard
for phenyls is 1.0 ug/1 for all WS waters. This facility has already been given
a break ince their limit reflects the BPJ level applied as a maximum to all
discharg s of this type rather than applying the standard at their outfall
(which has no dilution) . The BPJ limitation was coordinated with the Division
of Healt Services in reviewing this and other tank farm discharges. Since the
Town of mithfield's water supply intake is just downstream, it is important
that phe olic compound discharges be held to a minimum.
The oxicity testing requirement is consistent with that being applied to
all tank farm discharges with episodic (i.e. stormwater related) discharges.
The numb r of samples (5) is required to obtain representative information. (It
should b noted that DEM is now recommending and annual toxicity test after the
first 5 events have been monitored) . Continuous discharges are required to
sample oce per quarter during the life of a permit, which corresponds to 20
test sam les. The settleable solids and turbidity limitations are applied to
all sto 'water or retaining pond discharges. These limits reflect state stan-
dards an7 regulations intended to protect aquatic life instream.
Please let me know if further clarification is required.
JTC
cc: Bil Kreutzberger
Ken Eagleson
Central File

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ems.STATEa -
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State of North Carolina
Department of Natural Resources and Communit
y Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martip, Governor July 29, 1988
S. Thomas Rhdd ry
es, Secreta R. Paul Wilms
Director
Mr. Reece L. Andrews
Health, Safety & Environmental Manager - East
Shell Oil Company
P.O. Box 1703
Atlanta, GA 30371
Subject: - DRAFT Permit Comments
NPDES No. N00003549
Shell Oil - Selma
Johnston County
Dear Mr. Andrews:
This 1 tter is to acknowledge receipt of your letter dated Jul
containing co ments on the subject DRAFT Permit. The Division of EnvironmentalY 14' 1t
Management wi 1 consider your comments in making its decision suance
permit. If y u feel that your comments are not addressed in the issuedpermit,issuance u
may request an adjudicatory hearing in accordance with Chapter the1508ofGen you
Statutes of No th Carolina within 30 days of issuance of the General
permit.
If you ave any questions, please contact me at (91.9) 733-5083.
Sincerely,
,9:Qw....,.<,L________.
H. Dale Overcash, P.E.
Supervisor, NPDES Permits Group
cc: Mr. EU.l Kreutzberger g (with attachments)
Mr. Trevor Clements (with attachments)
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
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July 14, 1988 Shell Oil Company 61 qi-/1/.1 fo5
6 P.O.Box 1703
Atlanta,Georgia 30371
320 Interstate North Parkway
Atlanta.Georgia 30339
CERTIFIED MAIL - P794247468 '
i iVii. ►r..
State of North Carolina ['cis''./,:"~
Enviro ental Management Com
mission =�
Post Of ice Box 27687 JUL
Raleigh, North Carolina 27611-7687 20
198$
DIY.0f EAVON,MRSTAI fliANAGEMENT
• Dear Si /Madam:
SUBJECT: „i c•-Pi''' '''•4 I ti
NPDES NO. NC00 r. �: . ► �rZ
Shell Oil Company
t'• Y �... :;,'., �..
Oak Street Extension
JUL 21 1988
Selma, NC
We have reviewed the draft of the m WATER QUALITY
Permit for this facilityodification to the existing N§ 11��and provide the following informd'Cib~rl'' ieir ma
permitconditions. Y
have a significant impact on the final
Shell is in the process of constructing tanka
to prevent the discharge of an ge and a collection system
draft "wastewater" Y "contact water," or, in the terms of the
permit,
wastewater from the facilit
aY, and therefore request that
the permit be reclassified to
monitori g "stormwater only" permit without
This pro ect will be
completed by September 1, 1988, and we
hereby
request t at the monitoring
pstorrmwate o ofons this Draft Permit be han changed to
reflect that the effluent is
ter only, g
It is noted that the limitations and monit
statement that "the permit oring requirements include a
imposes no limitation on the discharge of
storm wat r runoff. . , ," May we assume that th
is also means that no
measureme t or monitoring is required for such discharges?
If this interpretation is comments/ bjections regarding in error, then
consideration,
g g the Draft Permit are esubmitted ng
for your
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1• It is believed that some con l �'
discharge fusion exists as to the designation
g points as the existing permit addresses g ion of
Point 001, although the renewal a only Discharge
Disch rge Point application included an additional
review the a (002) as a stormwater discharge
application dated Mayg point. Please
existing permit without reference 5, 1986. When we accepted the
exas ying were to Discharge Point not addressing storm water discharges atO that 2, e assumed
time.
TAF8819602 - 0001.0.0

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2. Our records indicate that we have requested a modification of the
phenol limits which exist in the present permit as 1.0 u/1 as a
da ly maximum and daily average. The date of our request is
Oc ober 2, 1986; and according to Mr. Mouberry's reply dated
Oc ober 8, 1986, we were to be informed of the outcome of the
Di ision's review of the matter. The .only response to date is the
Dr ft Permit with a phenol limit of .001 lbs/day as well as other
ver stringent monitoring requirements.
3. The modification of the monitoring requirements for Outfall 002
(be ieve this should read 001) appear to be unduly onerous given the
typ of discharge. As stated in the original permit application,
the discharges from this facility are the result of storm water and
not due to the plant process, which means that they are intermittent
and not continuous in nature. The imposition of a daily maximum
qua tity of phenol rather than a per unit volume limit is unfair to
a f cility of this type and fails to recognize that the only time
phenol (or any other constituent) is being discharged is during a
period when the receiving stream(s) is under heavy flow conditions
which provide maximum dilution and therefore the least effect on the
environment.
4. The requirement for five (5) acute toxicity tests appears to be a
matter of overkill in that our experience has shown that such
eff ents are not acutely toxic. It is therefore requested that
this requirement be removed or at least be reduced to a more
real nable number. It should not require that many tests to
establish the character of the effluent.
In conclusion, it is Shell's considered opinion that as of September
1988 the only discharges from this facility will be of stormwater runoff
and the issue becomes a matter of whether your Division requires an NPDES
permit fo stormwater discharges. It is our understandingthatthe USEPA
regulations require a permit but our contention is that it wo
uld not
require monitoring and testing, certainly not to the extent contained in
If there are any questions, or if we can provide more information, lease
contact this office at 404-955-4734. p
Yours very truly,
/,/; ;;-Z, ,2:15 ..."..40 ....
Reece L. Alidrews
Health, Sa. ety & Environmental Manager-East
TAF8819602 - 0002.0.0

NPDES WASTE LOAD ALLOCATION
Modeler Date Rec. #
PERMIT NO.: NCO() p 3 S "/ 9
j (c-- 3 i zs1 8 S y 50
FACILITY NAME: S-Ae i/ (),'/ f,ta.,,,t ' f'
Facility Status: E?CTSI�IG PROPOSED
Area (mil) �''S Avg. Streamflow (cfs): C'-'" i
(circle one) 9
7Q10 (cfs) C Winter 7Q10 (cfs) ° 30Q2 (cfs) 0
Permit Status: RENEWAL(-MODIFICATION-1)UNPERMiTTED NEW
(circle one) Toxicity Limits: IWC � �s%c (circle one) cute i Chronic
Major Minor t-------
Pipe No- 00 / Instream Monitoring:
Design Capacity (MGD): Parameters
Domestic (S of Flow): — Upstream Location
0
Industrial (% of Flow): /00
Downstream Location
Comments: c.�c...f.4l n f �t fd,e t ilstlI 4,4,A
AP/ 0 it/L)itt±4,. $P Qn Or -
rt/.t-c el ct.L.
L
Effluent
Characteristics �VS4k `4\1 ba --ax
RECEIVING STREAM: t"T 5 PX. / s4 /2,•..AK
Ph
L L.� � c.N c�v�o t S [�.,o i ��ca
Class:
Gt1�=-- �
Sub-Basin: Q 3 DY 0 ,Z , evg q 0_�',,+iJ� &II �``6 e_�( 2` 3C� yI (r,G Olt
Reference USGS Quad: Se-li1...e,, (please attach) `x'�ililQ0.� `'a��s v►1�1�
County: -ToAn•s 74tr,., Pil
VI .- ���-�1 (©--C{ SO
Regional Office: As Fa Mo Wa Wi WS (��y
(circle .sel ECiJ Ono0t+Dc kN --PC)C +0(
1 U c�vP vile J
Re ested Arr-Z. _ r / rA I `w c,...,cre- .� - ii - ft
qu By: �,. gate: ��� �/ k� � � `� W ..1lL-�Il�. -k--
Prepared By: _— 1- Date: /,"aiAg-t? ,,
C1 v r i �� c 0ok Cc".A.f2 :,,,Gt'ce.U.srvi &)ti c O,u t4 -wt
Reviewed By: Date:
0ef Comments: Pri \1o'�'virtec- o7C L G- L ki(

Request No . : 4St,2
WASTELOAD ALLOCATION APPROVAL FORM
Facility Name : SHELL OIL COMPANY 2
NPDES No. : NC0003549 MAILn `) 0 1988
Type of Waste : STORMWATER
Status : EXISTING - MODIFICATION _
Receiving Stream: UT TO NEUSE RIVER
Classification: WS-III
Subbasin: 030402 Drainage area: 0. 150 sq mi
County: JOHNSTON Summer 7Q10 : 0. 00 cfs
Regional Office : RALEIGH Winter 7Q10: 0 . 00 cfs
Requestor: ART MOUBERRY Average flow: 0 . 10 cfs
Date of Request: 4/24/87 30Q2 : 0 . 00 cfs
Quad: SELMA
RECOMMENDED EFFLUENT LIMITS
mn avg dy max � ;
Wasteflow (mgd) :
phenols (lbs/day) : 0. 001
oil & grease (mg/1) : . .e-30 (Qa r41AY a : .1988
settleable solids (m1/1) : 0 . 1
pH (su) . 6-9 6-9
Ac.`te L- �
Toxicity Testing Req. : iodaphnia, 99 perC_ent_,.—Qua-rye-r-ry
Turbidity: Shall not cause the instream turbidity to exceed 50 NTU
Effluent monitoring: .Lo. -thy monitoring for toluene , benzene , and xylene .
MITORING
Upstream (Y/N) : N Location :
Downstream (Y/N) : N Location :
COMMENTS
Permit must contain flow monitoring requirement such that all volumes of wastewater
leaving the facility are monitored . Recommend weekly monitoring for phenols ,
oil & grease, settleable solids and pH.
A reopener clause should be placed in the permit to allow for limits to be
placed on toxicants should the facility fail its whole-effluent toxicity tests .
Recommended by: _ 8 AqA ___(.1...C2_,
Date: 32 8C�
Reviewed by
Tech Support /Su ervisor: Date ::� .+ �/
CJ!WIC__ ---d
G✓9ro Regional S ervisor: __ .e__ /__y_ _ Date: S' _Z7
Permits & Engineering: __LOS. L 0t ta'/ Date : 61/l d b
RETURN TO TECHNICAL SERVICES BY: APR 2 2 198$,_

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Facility Name ,S►AaJ C I C o . Permit# C-(D)C3C) Lfcl
ACUTE TOXICITY TESTING REQUIREMENT
Daphnid 48 hr- Monitoring for Episodic Events
The permittee shall conduct FIVE acute toxicity tests using protocols defined 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 Daphnia nulex or Ceriodaphnia 48 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.
The parameter code for this test if using Daphnia pulex is TAA3D. The parameter code for this test
if using Ceriodaphnia is TAA3B. 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: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
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 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 a failure of permit condition.
7Q 10 6.0 c1f§
Permitted Flow vad-:e.W.c MGD Recommended by:
IWC% (o
Basin & Sub-Basin 6304 oZ
Receiving Stream uT Muse ,(Z<<,e.,e S--/°,�rn
County �o�.�•s tee. Date �l(o
//
**Acute Toxicity(Daphnid 48 hr) Monitoring, EPISODIC, See Part3 , Condition(r .