NC0004839_Permit (Modification)_20000914

WDES DOCUWEMT SCAMMiMS COVER :MEET
NPDES Permit: NC0004839
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Plan of Action
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: September 14, 2000
Thies document lie printed on reume paper-ignore any
content<XIM the rev�r�e amide

State of North Carolina
t Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor NCDENR
Bill Holman, Secretary NORTH CAROL-INA DEPARTMENT OF
Kerr T. Stevens, Director ENVIRONMENT AND NATURAL_ RESOURCES
September 14, 2000
Mr.R.T. Harvin
Exxon Oil Company
Charlotte Marketing Terminal
P.O. Box 82
Paw Creek, North Carolina 28130
Subject: NPDES Permit Modification
Permit Number N00004839
Charotte Marketing Terminal
Mecklenburg County
Dear Mr. Harvin:
The Division issued NPDES permit NC0004839 to the Exxon Oil Company on August 2, 1996. The
Division has reviewed your request for permit modification at the subject facility. Specifically, you requested that
the flow monitoring frequency be modified to weekly estimates using a totalizing flow meter. In accordance with
your permit modification request, the Division is forwarding herewith a modification to the subject permit.
Enclosed please find the modified effluent limitations page for outfall 002. This page should be inserted
into your permit and the old one discarded. This permit modification 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 December 6, 1983.
Please take notice that this permit is not transferable. Part II, EA. addresses the requirements to be
followed in case of change in ownership or control of this discharge. This permit does not affect the legal
requirement to obtain other permits which may be required by the Division of Water Quality or permits required by
the Division of Land Resources, Coastal Area Management Act or any other Federal or Local government permit
that may be required.
If any parts, measurement frequencies or sampling requirements contained in this permit modification 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 a written petition conforming to chapter 150B of the North
Carolina General Statutes, filed with the Office of Administrative Hearings, Post Office Drawer 27447, Raleigh,
North Carolina 27611-7447. Unless such demand is made, this decision shall be final and binding.
If you have any questions concerning this permit, please contact Mr. Michael Myers at telephone number
[phone],extension 508.
Sincerely_ f
err T. Stevens
cc: NPDES Permit File
Mooresville Regional Office Regional Office
Central Files
1617 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617;TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER- 50%RECYCLED/ 100/6 POST-CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS Permit No. NCO004839
During the period beginning on ctive date of the permit and lasting until expiration, the Permittee is authorized to
discharge from outfall(s) serial numbe .002 j eated groundwater. These waters will pass through an approved treatment system
prior to discharge. Such discharges shall--be- ted and monitored by the Permittee as specified below:
Effluent Characteristics Discharee Limitations Monitoring Requirements
Measurement Sample Sample
Monthly. Avg, Daily Max. Frequency Type Location
Flow' 0.057 MGD Weekly Estimate Effluent
Total Suspended Solids 30.0 mg/1 Monthly Grab Effluent
Oil and Grease Monthly Grab Effluent
Benzene 1.19 ugll Monthly Grab Effluent
Toluene _ I1.0 µgll Monthly Grab Effluent
Ethylbenzene Monthly Grab Effluent
Xylene Monthly Grab Effluent
I, 2 Dichloroethane 0.38 µg/I Monthly Grab Effluent
Chloroform g/l `` Monthly Grab Effluent
Phenol Monthly Grab Effluent
Methyl Tert-Butyl Ether' T Monthly Grab Effluent
Fluorene r Monthly Grab Effluent
Naphthalene Monthly Grab Effluent
Phenanthrene Monthly Grab Effluent
Iron Monthly Grab Effluent
Manganese Monthly Grab Effluent
Footnotes:
1 All volumes of treated groundwater leaving the facility shall be monitored. The permittee (or designated
representative) shall record the approximate time of flow measurements and calculate the volume of treated
wastewater discharged based on totalizing flow meter records.
The grab sample for oil and grease should be skimmed from the surface in a quiescent zone, such as a holding tank, if possible.
3' If MTBE is recorded at levels greater than 200.µg/l, the Mooresville Regional Office,Groundwater Section shall be notified.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

ExxonMobil Steve Giffin, P.E.
Refining and Supply Company Cnviror.mental Advisor
Exxon Charlotte Terminal Downstream SHBE
P.O.Box 82
Paw Creek,NC 28130
E�onMobil
May 31, 2000 Refining & Supply
Mr. Charles Weaver)
NC-DENR-DWQ-NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617 r << �V `
Re: Request for Modification _
NPDES Permit No. NC0004839 I""t � ZaQ�
U
Exxon Charlotte Terminal ?k
WATER QUALITY
Dear Mr. Weaver: FOUR„k aRAfdCH
Pursuant to the attached Notice of Violation, dated April 25, 2000, ExxonMobil is requesting a minor
modification of the above-referenced permit to reflect guidance previously given on behalf of the
Division of Water Qualitv. Specifically, ExxonMobil is requesting that the permit be modified to
indicate that flow meter readings are to be collected and reported on the discharge monitoring reports for
Outfall 002 on a weekly basis with a totalizing flow meter. This guidance is documented in the attached
letter sent to Mr. Pellei of the Division on August 29, 1996 and is referenced in our response to the NOV,
dated May t2. 2000, which is also attached.
ExxonMobil believes that weekly reading of a totalizing flow meter is sufficient to monitor flow at
Outfall 002 for the following reasons:
1. A totalizing flow meter records each gallon of water discharged from the facility and allows the
calculation of flow rates for any desired recording period (i.e., per minute, average per day, average
per month, etc.);
2. The discharge limit in the permit is based upon an average monthly flow rate of 0.057 MGD
(approximately 40 gpm). Therefore, there is no permit limit for flow that would necessitate the
collection of daily flow meter readings or the use of a continuous chart recorder; and,
3. The furthest downstream system flow component cannot discharge at a rate greater than
approximately 15 gpm (0,022 MGD). Therefore there is no means by which the system could
discharge at a greater rate than the permitted monthly average limit of 40 gpm. Additionally,
operational records indicate that the system has consistently operated in the range of 6 to 10 gpm or
lower.
Please direct further correspondence to my attention at the letterhead address. If you have any questions
regarding this facility, please call me at 410-280-9750.
Sincerely,
<W;5__-�*__
C: Mr. Richard Bridgeman, Division of Water Quality, Morresville Regional Office
Erwin Gaston, Exxon Charlotte Terminal

May--01-00 09 : 38A
P_01
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
MOORESWILL•E REGIONAL OrrILE
�V
.IAM4sd B..!•IUN7 dR.GOVRRNOR April 25, 2000
CERTIFIED MAIL o
9i6L HOLMAN RETURN RECEIPT REQUESTED
SecRETARY
Mr. Robert E. Gaston,•terminal Superintendent '
Exxon Company, USA ` BtBtii �
�cena. ns7S' P.O. Box 82
Paw Creek,NC 2$130
a' t'
SUBJECT: NOTICE OF VIOLATION
Compliance Evaluation Inspection
w.: Exxon Company, USA
Charlotte Terminal
NPI)ES Permit No. NCO004939
Mecklenburg County,NC
Dear Mr. Gaston:
On March 29, 2000,Mr. John McCulloch and Ms. Lori Doster of'thc
Mecklenburg County Department of Environmental Protection conducted an
inspection at the subject facility. This inspection was conducted as part of a
cooperative working agreement between Mecklenburg County and the Division of
Water Quality.
This Report is being issued as a Notice of Violation(NOV) because of
violations ofthe subject permit and North Carolina General Statute (N('GS) 143-
215.1, as detailed under the Rec:urdslRcports,Flow Measurement and Sclf-
Monitoring Program headings of the enclosed report. None of the cited violations
have previously been cited under either an NOV or a civil penalty assessment
document. Pursuant to NCGS 143-215.6A,a civil penalty of not inure than twenty-
�' five thousand dollars($25,000.00), or twenty-tivc thousand dollars ($25,000)per day
t`�.,F ' if the violation is of a continuing nature,may be asscssed against any person who
violates or fails to act in accordance with the terms, conditions, or requirements of
any permit required by NCGS 143-215.1. Should this Office make an enforcement
recommendation relative to the violations,you will be advised in writing.
010 NORTH MAIN STREET, MOORESVILLE, NORTH CAROL[N®
Pr,Ona 704-669-1699 FAX [phone]O�10
AN EQUAL, OP"PTUNITY !AFFIRMATIVC ACTION EMPLOYER - 509E RF__eU/10% PonT-V4N>1V Wert raven

May-01-00 09 : 39A P-02
Mr. Robert E. Gaston
Exxon Company, USA
Page Two
April 25, 2000
It is requested that a written resprnise he submitted to this Office by no later than May
15, 2000, addressing the violations and deficiencies noted under the Rccords/Rcports,Flow
Measurement, and Self-Monitoring headings of the attached Report. Please direct your
response to Mr. Richard Bridgeman of this Office. Additionally, please send a copy of this
response to Mr. Rusty Roz elle of MCDEP at 700 N. Tryon Street, Suite 205, Charlotte, NC
28202.
Relative to the Flow monitoring/reporting violations, if Exxon Company, USA thinks
there is sufficient justification for the permit to be reopened to modify the Flow monitoring type
and/or frequency,then such a request should be forwarded to the attention of Mr. Dave Goodrich,
Supervisor, NUDES Unit, Division of Water Quality, 1617 Mail Service Center, Raleigh,NC
27699-1617.
`t'he enclosed report should be self-explanatory; however, if you have any questions
concerning this Notice, inspection report or any other matters, please do not hesitate to call Mr.
Bridgernau or me at 704/663-1699.
Sincerely,
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Enclosure
cc: Rusty Rozzclle, MCDEP
JRM
rilz:wry 0004839.300

i
ExxonMobil Steve Glffln,P.E.
Refining and Supply Company Environmental Advisor
P.Q.Box 82 Downstream 5H&E
Paw Creek,NC 28130
EvzonMobil
Refining & Supply
May 12,2000
Mr. Richard Bridgeman
North Carolina Department of Environment and Natural Resources
Division of Water Quality, Mooresville Regional Office
919 North Main Street
Mooresville,NC 28115
Re: Notice of Violation
Exxon Charlotte Terminal
NPDES Permit No.:NC0004839
Dear Mr. Bridgeman:
ExxonMobil is hereby responding to the Notice of Violation (NOV) dated April 25, 2000, which was
issued by the Division of Water Quality to the Exxon Charlotte terminal pursuant to a March 29, 2000
inspection for compliance with NPDES permit,NC0004839.
ExxonMobil believes that reporting daily values of flow from Outfall 002 on the Discharge Monitoring
Report(DMR) is not necessary for the following reasons:
1. The flow totalizer, which currently monitors the flow at the facility, records each gallon discharged
through the treatment system and also demonstrates compliance with the monthly average flow
limitation when readings are taken on a less frequent basis(e.g.,weekly);
2. The maximum possible discharge rate of the system is less than 40 gpm, which corresponds to the
monthly average limitation of 0.057 MGD;
3. Existing operational records show that the system consistently operates at a rate of 6 to 10 gpm; and,
4. The attached letter to Mr. Pellei, dated August 29, 1996, documents a conversation with the Division
confirming that the practice of taking weekly totalizer readings was considered sufficient to meet the
requirements in the permit. Mr. Pellei did not indicate that a permit modification was necessary as
long as the flow was metered with weekly values reported on the DMR.
Based on these reasons, ExxonMobil respectfully requests that the Department rescind the NOV.
Additionally, to resolve the issue, we will submit a formal request to modify the permit to include
language that more explicitly reflects the guidance given on behalf of the Division by Mr. Pellei. In
accordance with the guidance presented in the inspection report, we will also commence daily totalizer
reading,which will continue until the permit modification is received.

t
Mr. Richard Bridgeman
May 12,2000
Page 2
It is ExxonMobil's intent that this letter and the actions described herein serve as a complete and
satisfactory response to the NOV. Consequentially, we respectfully request that the Division respond to
this letter, in writing, rescinding the NOV for the reasons presented above and accepting the commitment
made by ExxonMobil in this letter as a complete and satisfactory response.
If you require any additional information regarding this issue, please do not hesitate to contact me at 410-
280-9750.
Sincerely,
Steve Giffin, .E.
Environmental Advisor
C: Mr.Robert E. Gaston
Mr.Rusty Rozzelle
Mecklenburg County DEP
700 North Tryon Street, Suite 205
Charlotte,NC 28202
Attachment—August 29, 1996 letter to North Carolina Department of Environment,Health and Natural
Resources

MAY-03-2000 10:58 FROM` •. . , . TO:757 545 842E r- P.002,005
` TURNER
HART &
HrcKmAm, P.c.
Environ rcentar Consulranrs 4e Engfneers
August 29, 1996
North Carolina Department of Environment,
Health,and Natural Resources
Division of Water Quality
PO Box 29533
Raleigh,North Carolina 27626-0535
Attention: Mr. Steve Pellei
Re: NPDES Permit
Exxon Marketing Distribution Termival
Charlotte,North Carolina
Permit No.NC0004839
M &H j2h Na-B=n�QZ 3
Dcar Mr.Pellei:
This letter will serve to memorialize our conversation on August 20, 199b concerning the
NPDES permit for the Exxon Marketing Distribution terminal in Charlotte. The following is a
summary and understanding of the issues we discussed.
I. Incorrect Discharge Map. As we discussed, the map in the NPDES permit indicated
the incorrect NPDES discharge location for the Exxon terminal. Exxon has recently
received a corrected mag from the NC DEHNR. This revised map will replace the
incorrect map previously issued.
2. OMR Flow Reporting for Outfall 002. The NPDES permit indicates that flow from.
Qutfall 002 should be monitored continuously. For the discharge monitoring report
(DMR),you indicated that flow rate should be reported every week,as was conducted
on past DMRs. In addition, we should report an average monthly flow rate for
comparison to the permit level of 0.057 MOD(monthly average).
3. Part 111, Paragraph C - Changes in Discharges of Toxic Substances. We understand
that Part III, Paragraph C of the NPDES permit applies to notification requirements
for compounds for which monitoring is conducted but for which there is no permitted
level specified in the permit. You indicated that the 100 ugfi notification level was
for occurrences of a routine or frequent basis, and the 500 ug/l notification level was
for occurrences of a non-routine or infrequent basis. We understand that non-routine
c.41a1mnSeMaYa.c+�+'�m.
THH-11601
4421 Stuart Andrrw ftoj(jevard • Suirr 30O • Charlolre.Norih Carolina 28217 w
TeleAono 7O4-S23-S280 - Fac 7W-j23-1Dj7

MAY-03-2000 10:58 FROM: ' T0:757 545 0428 P.003/005
` TURNER HART& HICKMAM P.C.
'Mr. Steve Pellei
August 29, 1996
Page 2
or infrequent means occurring during one monitoring event only due to a slug or ot4er
similar condition. We understand that routine or frequent means occurring in three or
more monitoring events.
4. Carbon-Polishing System. Exxon received the Authorisation to Construct for the
carbon polishing treatment unit addition for the ground water remediation system on
August 18, 1996. As we discussed, it is unlikely that Exxon could construct the
system by September 1 because there is construction involved, lead time on carbon
vessels, etc. You indicated that it was acceptable to discharge beginning in
September without the carbon polishing unit in place even though the permit included
carbon polishing in the treatment train for the ground water r+emediation system. You
further indicated that Exxon should attempt to get the carbon polishing unit
constructed as soon as possible. As you mentioned,past monitoring data indicate that
the existing system can meet the new permit levels without the carbon polishing unit
in place.
If you have any questions concerning this letter,please do not hesitate to contact me.
Very truly yours,
Tut sERHART& HICKMAN P.C.
,i gk.,
Steven C.Hart,P.C .
Principal
SCfUtcm
cc: Vince Martinelli
Gerald Truesdalr
THH-1 i 202

'HRY-12-1999 10:31 FROM: TO:919 733 0719 P.001f004
TuRNER HA R T HICKA11A.V, PC
FACSIMILE TRANSMISSION
From:�'j I*Z I I<K A ,%J To: 14 A_,L (--A ko,V-T .
Date: 5//Z-/49 Firm:
Job Code: Fax No: q!9- 73 3 r 0 1 I
E-Mail: No. Pages:
Ph 704-523-5280 Fax [phone] CC:
Message::
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Turner Hart&Hickman, PC 4421 Stuart Andrew Blvd. 5ulte 300
Charlotte, North Ceralina 28217
THE INFORMATION CONTAINER IN THIS FACSIMILE MESSAGE IS PRIVILEGED AND/OR CONFIDENTIAL OR PROPRIETARY OR TRADE
SECRET INFORMAMON, INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY NAMED ABOVE. IF THE RIrADEE;OP THIS
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c%d=vcoavar caver.coc

MAY-12-1999 10:31 FROM: T0:919 733 0719 P.002/004
W.HICKMAN,
�IJRIV,�RHART c P.C.
Envirownenral ConsidtanrS& Engineers
April 14, 1999
NCDENR
Permits&Engineering Unit
PO Box 29535
Raleigh,NC 27626-0535
Attention: Steve Pellei
Re: Stormwater Discharge Upgrade
NPDES Permit No,NC0004839, Outfall 001
Exxon Terminal, Charlotte
IE&A Jrob No. EXX-0047
Dear Steve,
Please find enclosed design documents describing stormwater system upgrades to be
implemented at the Exxon Marketing Distribution Terminal at 6801 Freedom Drive in Charlotte.
Per your telephone discussions with our Steve Hart on October 30, 1998, we understand that a
request for Authorization to Construct is not required for this system upgrade. Further, we
understand that an NPDES petrnit modification is not required.
Systom U�ra,4e_Description
As currently gonduoted, the segregated containment pad and loading area run-off are routed to
the existing oil-water separator(refer to Drawinb C-L•-AF-040), but will now be of a lesser flow
rate due to grading modifications that will divert surficial nm-off from entering the containment
pads. The containment pad and loading area nin-off will be pumped from the oil-water separator
to a new 12,000-gallon surge tank and then to a new granular activated carbon (GAC) system.
The water discharging from the GAC system wall be tied into the discharge line from the tank
farm containment area,just upstream of NPDES Outfall 001.
c:�oa+carlGrhkxMWi7 OCRr 17.c1oe
442!SmarrAndrew Boulevard - SUW 300 9 Charlotte,North Gamlina28217
Telephone [phone] - Pax 704-523-1037

MAY-12-1999 10:31 FROM: TO:919 733 0719 P.003/004
TURNER HART& H1CICMAN, P.C.
Mr, Steve Pellei
April 14, 1999
Page 2
As an additional preventative measure,the existing,downgradient, concrete outfall basin is being
retrofitted with a hydrocarbon sensor to detect free hydrocarbon that could reach the basin. during
an extraordinary evonx. The hydrocarbon sensor is interlocked to the facility cQntrol system and
should a detection occur, the sensor interlocks will interrupt all flow to the oulfall.
DesigaRarameters
The package, being submitted for DENR files, includes full-size design drawings, reduced size
drawings, specifications, and vendor data, The design drawings have bccn stamped by a licensed
engineer. As requcsted in your discussion with Steve Hart, the system desigzl parameters are
provided below:
Parameter Value
Design Storm Interval 10-Year, I-Hour
Flow Rate to N-Water Separator 0 to 160 gpm
Plow hate to Surge Tank 0 to 200 gpm
Flow Rate to GAC 25 to 50 gpm
Design GAC Influent Concentration 2 mall benzene
GAC Quantity I000 lbs
Design GAC Effluent Concentration 1,19 ug/1 benzene
Schedule
Exxon is proceeding with equipment procurement and construction is expected to begin within
two to four weeks after receipt of major equipment,
In addition to presenting the system upgrades noted in the enclosed package, this letter serves to
confirm your earlier verbal authorization to Exxon's Vince Martinelli allowing Exxon to bypass
tank farm stormwatcr around the oil-water separator. Consistent with DENR's verbal approval,
c:ramticoMbkh%=x- 474mr fit 4w

MAY-12-1999 10:31 FROM: T0:919 733 0719 P.004/004
TURNER HART& HICKMAN, PC.
Mr. Steve Pellei
April 14, 1 999
Page 3
the collected tank farm stormwater is visually inspected before discharge and is tested for permit
parameters at the outfall.
Please contact me should you have any questions.
Very truly yours,
TwcNeft HART&HICKMAN9 PC
Bruce K. Hickman,PE
Manager, Design Services
BKR/daw
Attachments
cc: Jerry Crawfor1d
Steve Giffin
Erwin Gaston
dC ItrAm