NC0005185_Permit (Issuance)_20010730

NPDES DOCUWEMT SCANN1NS COVER SMEET
NPDES Permit: NC0005185
Document Type: ermit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Staff Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: July 30, 2001
Thus document its priaxtecl on reuise paper-i@PMoz-e any
content on the reYerme aside

,OF W A 7F9 Michael F. Easley
s O� pG 'A Governor
©DEAR William G.Ross,Jr.,Secretary
North Carolina Department of Environment and Natural Resources
0 '< Kerr T. Stevens, Director
Division of Water Duality
July 30, 2001
Ms. Joyce Chillingworth
Williams Terminal Holdings, L. P.
One Williams Center
Tulsa, OK 74172
Subject: Issuance of NPDES Permit NC0005185
Paw Creek Terminal
Mecklenburg County
Dear Ms. Chillingworth:
Division of Water Quality (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). Please note the following changes from your draft permit,
some of which are the result of the Paw Creek hearing officer's recommendations and others of which are
in response to the comments submitted by the facility:
• pH monitoring and limits have been removed from the permit. This was an error made in all of
the Paw Creek draft permits. The pH requirement was eliminated in the previous permitting cycle and
should not have been included in the 2001 permits.
• The MTBE limit of 11.6 µg/L has been removed from the permit. As per the hearing officer's
recommendations. a peer-reviewed criterion for MTBE does not exist and will not be included as part of
the permitting strategy for the Paw Creek permits. It is anticipated that a criterion will be in place
when this permit is next renewed. In addition to monthly monitoring of MTBE, please see Part
A.(3) for some additional requirements related to MTBE.
The monthly monitoring requirement for naphthalene has been deleted. Semi-annual
monitoring using EPA Method 625 replaces it. As per the hearing officer's report. 625 Is,he best
method for detecting naphthalene and other middle distillate compounds and is therefore a more
appropriate monitoring requirement.
Flow monitoring frequency changed from monthly to episodic. As per a request by the Mooresville
Regional Office, flow must be measured with each discharge event.
BTEX monitoring will remain as monthly. The monitoring frequency for BTEX was established as
monthly in the 2001 Permitting Strategy for Oil Terminals. Semi-annual monitoring as in the case of
toluene, xylene and ethylbenzene does not provide the Division with sufficient data to assess the risk of
effluent from your facility exceeding the water quality criteria-.- Should the effluent from your facility-
continue to indicate non-detects for BTEX compounds, you may submit a formal request to the
Division for a modification to the permit reducing the monitoring frequency for these compounds.
The benzene limit will remain in the permit. A reasonable potential analysis was performed for
benzene. The analysis predicted that there is reasonable potential for benzene to exceed the water
quality criteria, therefore a limit was included in the permit.
• The limit for phenol has been deleted from the permit. The phenol limit was an error in the
permit. Upon further evaluation of the data presented by the facility it was determined that phenol
does not have reasonable potential to exceed the allowable concentration. Monthly monitoring will still
be required according to the permitting strategy.
N.C.Division of Water Quality/NPDES Unit Phone:[phone]
1617 Mail Service Center,Raleigh,NC 27699-1617 fax:[phone]
Internet:h2o.enr.state.nc.us DENR Customer Service Center.1 800 623-7748

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.
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 Teresa Rodriguez at telephone
number [phone], extension 595.
Sincerely,
jKe . t ens
cc: Mooresville Regional Office/Water Quality Section
�NPDES_Unit____)
Central Files
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Department of Environmental Protection

Permit NC0005185
STATE OF NORTH CAROLINA -
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELMNATION 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,
Williams Terminals Holdings, L. P.
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte II Terminal
NC Highway 27
Paw Creek
Mecklenburg County
to receiving waters designated as an unnamed tributary to Long Creek in the Catawba 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 September 1, 2001.
This permit and authorization to discharge shall expire at midnight on June 30, 2005. ._..
Signed this day July 30, 2001.
—6;�'-— ,I�"".- ,4
Kerr T. Sgater
ns, i r
Division uality
By Authority of a Environmental Management Commission

Permit NC0005185
SUPPLEMENT TO PERMIT COVER SHEET
Williams Terminals Holdings, L. P.
is hereby authorized to:
1. Continue to discharge wastewater consisting of stormwater from loading docks areas treated via
oil/water separators, stormwater from the diked storage tanks areas and city water used for washing
or hydrostatic testing from a facility located at the Charlotte H Terminal, NC Higway 27, Paw
Creek, Mecklenburg County and
2. discharge the combined wastewaters from said treatment facility through Outfall 006 at a specified
location (see attached map) into an unnamed tributary to Long Creek, a waterbody classified as WS-
IV waters within the Catawba River Basin.

'`,S f, •`�r •�- �� '•'[�•yt,�'.ti,.,/ y lr' 1 1 •�1C1Ar`� ' y�V" � i -_ ` ''w 1ru/y,�y/
s j _ .fie '��'� '� ei �1{'rF ..�h _ � ��.r�` / �Y /� � ` Y = •.tj �, W
�.� l A s.-�'"i' S� �v � ti•_.ti- i•• U6 rA C.11 ��5..'� �+tiiN, s'�, +:••S ,:4 1►,•' /r .�R'.`'� i d
�' ,i' � 4 ��� `� y.� :;Z4�' •".f � i �. _'Llz `~ ,f},�y�y �i ♦ �•t�S� :L• :�f �� 1V� �O1
v'r �� •t�7'. � ems¢'" "`�•. Yis i�� :, .h+� x<r ��� ���♦ . ; _ •+' •.- ��L1 -.
•.:{,• L' ' ,�" � try' ' S` :•;` .�; ` a .'•"g'"X}�' ate` i2+ti' ''��.�;y,�u` � S rv�. r 'S ` '�.: �[�
s , •� r � f'� �� f{� 1t, � 1 G = •���' � rQ�µ. tr �,�`� •. } 3r,�i�r�y. �i4 e� n ���� �� f��� � y
• 'e _ .:.r �.,? .r� S'y �i`� ,�T ,:4''1' Y "^ -'*'_ '',' '�°1� �J 7�'° .s.13 \�`T' t`s� ,�''? �?�', �� r �i; � F�-� � .
•'fir fir:• ;1�,. � -r '.� c .,• �f �.• I. �'• .\�'_, r'?!�a � S� uy"5�` s��' ` -�r.�`�S`[�
_ ,.- tf' 11�i c i c.K; C'1Y��L' Y 1 M: 7 S�• ,r �"�. '•*" .
_ � {^{ F a• 3 or �� s [,Yr�• �.I �. �. /a �.. .. r'�,�• '.,?.�I sr1,'� •
�^ '"'j? 4 t� .+ � ,�' :S '� .� b` f � �'. 1��.h ' � � ;�'r '`•'�•.'ti,, qq An s',ti �r >�t �;; i5 i�',�� �'_3?e //�//''+II
,l • r '�� rS•� ' �'�. �+{ � •r y��j �� �;iY �eys�':�-, � .� ��� . L, t� -iti�, «±. -_�w d: *" r i-, ° � N
� " �+ ,; � ,} ,,'� ?�„I• a!,' ,t ( "{iC• •�i:!^'" ',;� �'• x ��"}, y�' �''.y J t rti: Sf IAy
� ` '�� � }'' , � ti � w.''.1 ti.: �Y as •s;. * S' :� y �Y ;_-,. i 4'� �'4 .l y
i % � �t:�` i.`• %r. y` a»,�, '• eY�•,�:,�T:r, >ti "� Y- '�-'� yypp����� FF-aa
,�L. r � �..•.. •..+ �{1L i- � I ,3 ...'..i7ryt,ty S 4 \ �ti� - d ,.� �_ ,r� Swf � •�r: r � ;.) 1 .-+ '
L � * �.},T�'.a � }�yr��� �t�� •i 1 ,4,`,+� *•s � ' � �-:1>3 i! 1SY�- ��• ''' . . - '}i y�. Jr�;- 1` {,.
�,` ' �:s'r ;_ - • R .4��t .. f "', `�•t�' 'ir•� r �1. s � �f•It,'� - �� ��••; ,, a���� '' ��'
�.�� + '. f� � -1 ✓ ;4:� ,, �'� �- _ �` ��•:TI. .,..�.+� '�, ••r r. �- i•` ti fit• J' i
7 p' i �� �•f•:•.': .p'," r - ��.1� Wi' il�+y`a� �r ,��' f 1.Ki•:
�.I:V F � +y ;ff _•'1 i 11'7�4 •'� S• 1� '<.a
'''.1r �lrl{ .., � � � _ve(1�#11^freiff.f ley -^ � ' * f.•-'r � r�� � �i.-f'� •�
- �,�� CJ • �:=�"•f: �� ��l;'�'f� � ";4���✓ � rf�� Iwo �" ; S •^ a
'� _ .�•. �' •, .v "a.i i,,� •�►�'�, '•.,,•ice' .�'�~ ���'•„j1 r � u" � � � �r w� "7� /` r ��`.�,} 4
•• � �� # Illfff111 f_ff_ '� �•�.�{ �y�• r ♦ ..� ' � '• `�' ��1'•�'f:�, - �'' + �'� �' r`� `tip � �I � m
�" , t F•• _�«l~- �.,M `/�•�� }j�J-• _�i, S"'f]Fy ��'• � {�r `� :ir�`iS't'' •..irr'H�-l� .
. �•�� ���bµ'S�-`� -,�u., � ,�y; • ,h��� 4 ��� •S: '�j5 1••v :r '•• r�J i;r � _ `'� z h*r �i'��'��r � � � W
.ems KI ate. y��`eY :�� l�:♦ I �. r .ifL ,�� '� o-, -,. y4r6 , ,�; r - 4 4• � � �a},,
'� C* ••��^ i k� �� ��' ���.r •mil 1✓., - .J' I SJ •T{„ .4 •1}�K � .�� f rH F� •�
�� 4l r'F •• • m ��•+ h.�% �,�"=J 1"� r 'Y f a` w �` ��..'y7'-f'C�� ••,,�.�y � t i a �Y � ~ ..7
+• �' ,rF `�r;".��• • ♦�` � :Ir � �?�� , 1�tii sy�' ~' k ,r 1'�'''r'�:w"� , }+�� '.ff. ^r '�S� r ,-�M�' r Q�
r =.� +'� `�� x- *,.f• +�` SSr 1 •=�' '��•3:� �b,• W+ ,��`'��`%�'���;.* rat, � � + t� O
,�, 4 * � r,��, ri �� r� ,.� I !a 4�i}',`�• ,�•,j �' "i�fS1,N �f'4 ��'�'rJr'; i~ , !`- ,o- n � �a_ � U
�.. 'tk Cr "C _ � k �. i! �.# , r • 3. r :..f Q3
cl 6
ti ,.y 1 f,:• F f'"y, C-,.'} tr} 4'^''•` i 4+ ~�S -* '�I' +i `y F �n ti 1 9 ♦ •.*. ' -f r ,•��y CO FO G+
r •• � i f .� ,F x r �]r}t:'V"': y r�' `n.�j• l'�"'�"., f�.. ,'C' \• r•rr',.; t - "' ' `..J �j ~ to �Cf7
y +�• �;� • c.f r S �• t - - !i-. :, '� '� ��{ � - "4 r r�:�L� ..f •y,��'-r✓ySr`F .��,,;; � •.... Ls.
t•S't4'. _ f,t f/.` t'�q `',��, ty ,•,,r"� .''`, 4�55 -�. 1 �F�., ^t'-� -4` , �",1� r y!t >7�:�ir •,,•"�,�..�..+ •� - ,��� `rj
�J} ,;ry i '� ?f �� f 'ti``' �r� .��'�`sc .5.1 y +f �` .��; ✓� �� '� i - '` r° ,�
7r r .'� ,�i Y'r tlF r 1'" .rt�: �/�,��7'��:%� - s'I -�`" . �:. '�1 -fit `,• � ♦, - S''•-. ".- �, �y-:, �'� •.•.+ � '
S^, r �ti,�''` 1� .�"1'+ � t '�, _ _ .' ;Lc;=�!!;'•Y<.P i45 f' T: .T� .��� :l 'a. >�` n �.. ��—✓,�p�
�t �`�*b ti.+ "`+- •'11" y i.� ... , , ,'\. . f - r.�•• R r, ,` �t 1't SS 4k �.f-V.fC F�
� �� �� •S �• } -�• ' �: 4�• t t �1'�.•.. �• •�� �• '�.Y 't 7•'.^' 1�.4'S �, � �� C Ry
- ` fi, ^j+y� f N. ; �., 1 ^ . i� • r y.. 11' V!' ` •Lil
r `'� `�;�.. � tom['~ 7?�+'��4�� _.,c�yL {• Now �u"�" i ice' ;' � ••titi� .y ,y 4��' -� r� �f �`,f5 �'� �i ' " - k} .,,�+�.��� `}' �` `r�ya�1
)• k'' x to r.. t I` �1 � + • f� � .'r �. � ` •'a �•r � �..` � +� f!1
?d y. ,ti1�.�i�"' •�+ `.s�� f e S{4 � eM+. �I' ''.,- : '_-4?".k...� 1i... .,���:.�.. .!:x..�, �` `'.-:.i 4. .I r�

Permit NCOOO5185� -
A. (1};, EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS '
Beginning�on the effective date of the" errnit and lasting until expiration, the Permittee is authorized to'{:
} discharge from Outfall 006.. Such discharge5*shall be limited and monitored by the Permittee as
specified 6ciow: -
EFFLUENT` t t w �t. r f , - c, ,
UEN # ; � 0 Vt�.::��!,,;s LIMITS) x MONITORING;REQUIREMENTSTM s
GH RACTERISTICS Monthlytj t< Datly_ :Measuremenea. amp0 Sample l ocation.
' �'��w4���.'�.`��{�.�`� 71�',.��1....,,, '"(set-."•�'7e4'a �k ?iC:` 13',"'; r»� '''"'G'i••••-.,�%�'��'C:b;fl•',�,i Y��'Y'a . t
�. mot, :- Avera a"":�. .Maximum ° Fre uenc .;� : T- e`r a �it s .;
Flow l' Episodic 1 Effluent
Turbidit 2 Quarterly Grab Effluent
Oil and Greasd Monthly Grab Effluent
Total Suspended Solids 45.0 m Monthly Grab Effluent
Benzene 1.19 µ Monthly Grab Effluent
Phenol Monthly Grab Effluent
MTBE4 Monthly Grab Effluent
Toluene Monthly Grab Effluent
Ethyl Benzene Monthly Grab Effluent
X lene Monthly Grab Effluent
EPA Methods 6255 Semi-Annually Grab Effluent
Acute Toxicit 6 AnnualIy Grab Effluent
Footnotes:
I. Flow — During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report (I)MR)
indicating "No discharge." Flow shall be monitored with each discharge event and may be monitored in one of
four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; (this method of flow
measurement should not be used 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.
2. Turbidity —Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving stream
background turbidity exceeds 50 NTU,effluent shall not cause this background value to increase.
3. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from the
surface of a quiescent(calm water)zone.
4. MTBE-Please see Part A.(3) for other requirements relating to MTBE.
5. EPA Method 625 - Once the facility has collected data for 8 consecutive sample events in which there have been
no detections above the method detection limit,the permittee may request a modification to the permit that reduces
or eliminates the monitoring requirement.
6. Acute Toxicity (Fathead Minnow; 24-hour), Annual [see Special Condition A.(2)]. Samples for Acute Toxicity '-
shall be collected concurrent 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 I 1 µgll.

Permit NC0005185
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA/600/4-901027 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 test requirement must be performed and
reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch 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.

Permit NC00051 S6
A. (3) MTBE SPECIAL CONDITION
For the protection of public health, oil terminals that discharge to waters classified as water supplies
("WS" waters) will adhere to the following action plan:
L As stated in Part A. (1) and (2), monthly monitoring of MTBE for the duration of the permit is
required.
2. After one year of monthly monitoring or once twelve data points have been collected, the
Permittee shall review the MTBE data collected. If MTBE has not been detected in any samples
taken during the first year, the facility may request that the monitoring frequency for MTBE be
reduced. This should be done by requesting the NPDES Unit to perform a minor modification to
the NPDES permit. In the case in which MTBE has been detected within the first year of
effluent sampling, the subject facility must subnvt an MTBE reduction plan. This action plan
may include site-specific BMPs or engineering solutions. A copy of this plan should be
submitted to:
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
3. By the time of the next permit renewal, it is anticipated that surface water criterion for MTBE
will be established. This criterion will be used in conjunction with the facility's effluent MTBE
data to perform a reasonable potential analysis (RPA). The RPA will determine whether effluent
from a facility has the potential to exceed a water quality standard or criterion, thereby requiring
a water quality limit in the NPDES permit.

DIVISION OF WATER QUALITY
April S; 2001
MEMORANDUM
o
�x
TO: Dave Goodrich r�� CXM
(`U✓ � cr_w
CXM
w i,3
FROM: D. Rex Gleason r Q
PREPARED BY: Richard Bridgeman\
W�
SUBJECT: Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
It is recommended that the effluent sample Iocation be specified in all the permits.
Circumstances at one facility (at least) can be cited as justification for the
recommendation. The permit description of the water pollution control system (WPCS)
for Colonial Pipeline Co. (NC0031038) includes a retention pond. This pond is also
mentioned in the Fact Sheet. Regardless of the 7Q10, 30Q2, and average flow data, this
pond is actually an impoundment fed by three UT's to Gum Branch. According to the
terminal manager, there is flow in these UT's to Gum Branch 12 months per year. The
effluent from the CITGO (NC0021962) facility is discharged to one of the UT's.
Stormwater runoff from at least one other terminal site may also enter the impoundment.
Effluent samples are collected at the outfall for the impoundment.
As discussed above, in addition to the sample collection location, the Colonial Pipeline
Co. (NC0031038) permit needs to be reviewed to determine if it is appropriate to include
the impoundment of a UT to Gum Branch as a treatment unit (retention pond).
Consistency is needed in specifying source of wastewater to WPCS.
There are four different methods used in the draft permits, as follows:
- Source not specified anywhere.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet,
which describes the WPCS and/or specifies outfall.
Source indicated in the paragraph on the Supplement to Permit Cover✓Sheet that
specifies receiving water.
Source indicated in Part I, Section A(1) of permit (Effluent Limitations and
Monitoring Requirements Sheet).
The writer's preference, in part because several of the facilities have multiple outfalls, is
to indicate sources on both the Supplement to Permit Cover Sheet (in paragraph which
describes the WPCS and/or outfall) and in Part 1, Section A(1). An example of the
writer's preference is in the permit for Motiva Enterprises, LLC (NC0046892).

Dave Goodrich_ .. . .
Page.Two: ,— -F
April S,2001 ` ,. : .
- Flow measurement/reporting frequency is recommended to be episodic (as in permit
Motiva Enterprises, LLC (NC0022187).
For several design reasons, discharge events basically occur on an as-needed basis; a
decision is usually made when there will be a discharge through an outfall. The only
exception may be Outfall 002 included in the permit for ExxonMobil Refining and
Supply (NC0004839), which is for a groundwater remediation system without any flow
retention capability, and, therefore, subject to daily discharges. Since discharge events
are mostly manually precipitated and occur randomly or as-needed, the range of the flow
data at a facility may vary considerably. Flow data seems to have played a large role in
the development of effluent limits (as in reasonable potential analysis for phenols), and
yet historically flow measurement methods and data have been two of the evaluations of
a compliance inspection subject to much scrutiny and criticism. Given the flow
measurement options specified in the permits, the small number of discharge events
probable each month, the importance of flow data, and the possibility of a wide range in
the flow data, it is not unreasonable to expect flow to be measured and reported for each
flow event.
- The Turbidity monitoring requirement.does not seem to be complete.
The permits, with two exceptions (discussed under the next item), include either a
quarterly monitoring-only requirement or a monthly monitoring requirement with an
effluent limit. It is not understood how the effluent turbidity monitoring requirement
correlates with the relevant footnote in Part I, Section A(1). Should there not also be an
upstream and downstream monitoring requirement. In fact, those facilities with a
monitoring-only requirement need only conduct stream monitoring to determine if
effluent turbidity levels result in stream standard violations.
- One of the exceptions mentioned above under the item for Turbidity Monitoring is
Marathon Ashland Petroleum, LLC (NC0046213). Although the permit cover letter
indicates that the permit includes a monthly monitoring requirement and an effluent limit;
Part 1, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring-only
requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is.
being required because of the near potential for a stream standard violation.. The other
exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being
required because none of the previously required monitoring has been conducted.
Philips Pipe Line Company (NC0032891)—Phenol limit in the other permits is expressed
in mg/L. In the Philips permit, it is expressed in ug/L.
ExxonMobil Refining and Supply (NC0004839)—Benzene limit is indicated to be 1.2
ug/L; should it not be 1.19 ug/L?

Dave Goodrich.... _.
W Page Three
April 5, 2001
Phenol limit development.
The cover letters for four of the six permits with a Phenol limit discuss development of
the limit. In the cover Ietter, the water quality standard for phenol is indicated to be I
mg/L; it is actually 1 ug/L for WS waters. The writer is not familiar with the 2001 SOP
used to develop limits for phenol, but considering the fact that five of the six facilities
discharge to streams having a 7Q 10, 30Q2, and average stream flow of zero, and the sixth
facility discharges to a stream having a 7Q10 and 30Q2 flow of zero and an average flow
of<1, it is hard to understand the assigned limits. The 3 mg/L Phenol limit for Outfall
002 in the ExxonMobil (NC0004839) permit is almost unimaginable.
Motiva Enterprises, LLC (NC0022187)—The Fact Sheet indicates that there is a
reasonable potential for the stream standard for Lead to be violated, but indicates that no
limit will be assigned because lead is an action level pollutant. A change? If not, should
there be a Lead limit in permit?
TransMontaigne Terminaling, Inc. (NC0021971)—Permit Cover Sheet indicates that
discharge is to Paw Creek. As indicated elsewhere in permit, discharge is to a UT to Paw
Creek.
Williams Terminals Holdings, L.P. (NC0074705)—The permit description includes an
oil/water separator, a carbon filter, and a holding tank. The Fact Sheet indicates that
wastewater and stormwater are-routed to a retention pond and released as needed. No
staff report or compliance inspection report mentions this retention pond. MCDEP staff
has confirmed that there is no retention pond at the site.
Valero Marketing & Supply Co. (NC0004723)--Please review discussion in Fact Sheet
concerning the assignment of a Turbidity limit. If the average turbidity value in the past
1.5 years is 7.2 NTU and the maximum 28 NTU, why is there a prediction of a maximum
of 110.3 NTU?
'j Williams Energy Ventures T
C0005185)—Permit Cover Sheet indicates that discharge is '
-- ---- to a UT to Gum Branch; as rrectly identified on the Supplement Sheet, it is a UT to -
ILong Creek.
Motiva Enterprises, LLC (NC0046892)— Fact Sheet indicates that the Flow requirement
for Outfall 002 in the previous permit will remain unchanged. There was a Flow limit in
the old permit, but not in the draft permit. The writer does not recommend a limit.
Please advise if you have questions or comments.
RMB

"S U�Q
U G
W
Tt,o , ILA WATM nt tw m+.SFrmpN
Th CAF1O r
APR � U 2031
MECKLENBURG COUNTY
Department of Environmental Protection Non-DiwimMePermltVna
April 17, 2001
Mr. Dave Goodrich
NCDENR - DWQ - NPDES Unit
1621 Mail Service Center
Raleigh, NC 27699-1617
Subject: Paw Creek Petroleum Terminal NPDES Permit Renewals
Dear Mr. Goodrich:
The Mecklenburg County Department of Environmental Protection (MCDEP) has reviewed the
subject draft permits. As you know. MCDEP has a Memorandum of Agreement with the
Division of Water Quality to conduct inspections of the Paw Creek terminals in order to
determine compliance with the applicable NPDES permits. We offer the following comments
regarding the permits:
General
• Flow Measurement
The flow measurement method by which facilities are allowed to calculate flow based on
the area draining to the outfall, the built-upon area, and total rainfall using the rational
equation is inaccurate in most cases. Most facilities inspected by MCDEP collect
stormwater in earthen secondary containment basins surrounding the above ground
storage tanks (not ponds). The facilities generally hold the storrnwater for as long as
possible (several weeks if weather permits) to allow any suspended solids to settle out
and to avoid discharge if possible so that monthly sampling and laboratory analysis does
- not have to be performed. Calculating discharge flow by this method is inaccurate
because it does not account for evaporation and ground infiltration during the holding
period.
• Quarterly Turbidity Monitoring
The permits state that."Effluent turbidity shall-not cause the receiving stream turbidity to
exceed 50.NTU. If receiving stream background turbidity exceeds 50 NTU, effluent shall
not cause this background value to increase."
PEOPLE • PRIDE • PROGRESS
700 N. Tryon Srreer • Suite 205 • Charlorre, NC 28202-7736 (,104) 336-5500 • Fax [phone]

Mr. Dave Goodrich
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 2
The permits require quarterly turbidity monitoring at the effluent. The permits do not
require upstream or downstream monitoring for turbidity. Without instream monitoring
requirements, compliance cannot be determined.
Individual Facility Comments
• Williams Terminals Holdings, L.P. - Permit 4 NC0074705
An error was noted on the fact sheet for this facility. The background section refers to a
detention pond which is used to hold wastewater prior to discharge. MCDEP has
determined that the treatment works for this facility do not include a detent' n pond.
• Exxon Mobil Ruining and Supply Company - Permit 4 NC0004839
Outfall 001-
The daily maximum permit limit for benzene is listed as 1.2µg/l. The North Carolina
water quality standard for WS-IV waters is 1.19µgli.
• Marathon Ashland Petroleum, LLC- Permit 4 NC0046213
The last footnote on the Effluent Limitations and Monitoring Requirements
page of the permit states, "There shall be no direct discharge of tank (or pipe) contents
following hydrostatic testing unless benzene concentration is less than 71.4µg/l and
toluene concentration is less than 1 lµg/l." Since the receiving stream is a class WS-IV
water, the benzene Iimit should be 1.19µgll.
• Colonial Pipeline Company - Permit # NC0031038
MCDEPs past inspections of this facility indicate that the retention pond located on-site
receives flow from three intermittent streams. "While the streams-'are classified as
intermittent by USGS, terminal personnel have indicated that the streams have perennial
flow. In addition, stormwater discharges from the Citgo facility (NC0021962) and Crown
Central Petroleum Corporation (NC0046531) flow to Colonials' retention pond before
entering the receiving stream. •Since these conditions exists prior to the outfall location
(sampling point), MCDEP has concerns that these influences may constitute dilution of
the waste stream and effluent analysis may not be totally representative of the facility's
wastewater characteristics. In addition, Colonial could potentially be liable for impacts
from off-site sources.

Mr: Dave Goodrich"
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 3
If you have any questions regarding these comments, or any other matters, please feel free to give
me a call at 704/336-5500. Thank you.
Sincerely, 7
jV
Rush ozzelle
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP

Sent- By: ; gig 821 0337; May-2-01 16:32; Page 2/3
`. NORTH-- CAROLINA, -
PETROLEUM
COUNCIL
A Mdsfon of tht Amerilcan A-trolewn buttttA
W1I13AM I1.WEA711G1aV100N SUITE 285D • 150 FAYE=ViLIE S7:MALL
Zbommm Daacur RALEIGH.NC 27601
oioJasa-Sd�t1 �wxoto/tr�t�7
May 2, 2001
Mr.Rick Shiver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Ext.
Wilmington, NC 28405-3845
Rc: NPDES Pcrmit Renewals
Paw Creek Petroleum Pipeline and Distribution Terminals
Charlotte(Mecklenburg County), North Carolina
Dear Mr. Shiver: .
Thank you for the professional manner in which the public hearing on the petroleum terminals'
NPDES permits was conducted in Charlotte on April 19, 2001.
The purpose of this letter—which 1 request be included in the official hearing record—is to
express my members' strong concern about the way MTBE is being addressed in the terminals'
draft permits.
The North Carolina Petroleum Council--a division of the American Petroleum Institute,the
trade association for the nation's major fuel suppliers—is committed to insure that the
opportunity for public hearings and comment is an integral,part of government decision-malcing.
So we simultaneously praise the process that allows us to submit this statement for the record,
while we point with alarms to the proposed MTBE limit of l l.6 ug/L that has been included in the
draft permits without a single hearing or any official review by a nilemakinl,body.
We asked the Department(DENR)to help us understand how this limit came about. We were
told that there is no surface-water standard for MTBE. Further, we were advised that the
purposed MTBE limit has not been endorsed by the Environmental Management Commission
has not been debated by those publicly appointed members—has not been the subject of public
hearings at all. In fact, the EMC recently dealt with the matter of MTBE and voted not only to
reject a request for it temporary groundwater standard of 70 ppb, but also to rcaf irm'the value of
public hearings by calling for a permanent rulemaking process to tighten the MTBE groundwater
aWamd2�xd. so as We.VA awatc 4W kr=a U%p ire on t"t wovosal..we are rww confronted with

.Seat By: ; 919 821 0337; May-2-01 16:32; Page 313
Mr. Rick Shiver
May 2, 2001
Page 2
draft NPDES permits that attempt to install an MTBE limit that is at best controversial and at
worst a circumvention of the EMC.
It is my understanding that MTBE was not an issue for the Department in the NPDES permits
issued five years ago.
To be sure, in the intervening years it has been an issue of increasing attention, study, debate and
speculation. Apparently some individuals have been so moved by the growing debate that hasty
changes in risk calculations and other values have occurred. A few advocates within the
Department who sounded the alarm so vigorously in statements to the EMC to support of an
MT 3F groundwater standard of 70 ppb have now changed their minds! What had been a
certainty one month was abandoned the next in favor of a new calculation—and a new limit
level. So, if public health wnsiderations arc truly moving this fti4t, it numbem are hastily
abandoned and recalculated, if the science is in such a state of flux,then our commitment to
reasoned public input is all the Tnore appropriate and needed to insure that the calculations of
today are not abandoned tomorrow.
i
RecomMendations
The Council's members awept that an MTBE limit that has been peer-reviewed and duly
considered via the rulemaking process may be appropriate for inclusion in the terminals'NPDES
permits. Lacking that, however,the Council believes the MTBE limits contained in the draft
permits should be removed.
Importantly,the Council's members with facilities in Charlotte are willing to help the
Department collect MTBE data by monitoring for it on a periodic basis. But the proposed
monthly monitoring requirement is excessive. We are confident that semi-annual munitorinn by
each of the terminals will provide the needed representative data to form the basis for future
decision-making.
Sincerely,
William H. Weatherspoon
----- W H W/jm ---- - - - -.. -. -- ---- _.
c: Ms. Natalie Sierra

SURFACE WATER�QUALITY STANDARDS OR CRITERIA FOR PETROLEUM-RELATED CONTAMINANTSii,,�..A;� ,.
„C" &"B"WATERS
(ug/1 unless noted "WS-i" -"WS-V WATERS (ug/I unless SOURCE OF STANDARD '
CONTAMINANT CAS # otherwise) WATERS noted otherwise) OR CRITERIA
BENZENE 171-43-2 71.4 1.19 71.4 15A NCAC 2B .0211-.0222
n-BUTYL BENZENE 1104-51-8 36 36 36 ECOTOX 4/98
sec-BUTYL BENZENE 1 135-98-8 41 41 41 ECOTOX 4/98
CHLOROFORM 1 67-66-3 470 5.7 470 EPA 4/22/99 l
ETHYL BENZENE 1100-41-4 383 524 130 ECOTOX 1/01
IPE i 108-20-3 19 mg/L 19 330 mg/I ECOTOX 1/01
ISOPROPYL BENZENE I 98-82-8 316 186 4.6 mg/I ECOTOX 1/01
p-ISOPROPYL BENZENE 99-87-6 325 325' 1.1 mg/I ECOTOX
METHYLENE CHLORIDE 75-09-2 1600 4.7 1600 EPA 4/22/99
MTBE 1634-04-4 2393 11.6 2393 NC DHHS 7/11/00
NAPHTHALENE 91-20-3 105 43' 64 ECOTOX 1/01
n-PROPYL BENZENE ' 103-65-1 77.5 77.5 190 ECOTOX 1/01
1,2,4-TRIMETHYLBENZENE 95-63-6 386 72 218 ECOTOX 1/01
1,3,5-TRIMETHYLBENZENE ' 108-67-8 626 100 215 ECOTOX 1101
15A NCAC 2B .0211-
TOLUENE ' 108-88-3 11 (0.36 Tr) 11 (0.36 Tr) 185 .0222/ECOTOX 8/99(SW)"
XYLENE, TOTAL 1330-20-7 88.5 88.5 370 ECOTOX 1/0 1
Criteria which have a source of EPA ECOTOX were developed using EPA's ECOTOX database per 15A NCAC 2B .0208.
Last update 2/2/01 (DMR) These concentrations are updated regularly.
Questions or criteria for other parameters not found in the 15A NCAC 26 .0200s can be addressed to Dianne Reid at
919.733.5083 extension 568 (Dianne.Reid @ncmail.net) OR Jason Wynn ext. 351 ([e-mail])
I

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
2001 Permitting Strategy
Background-I Introduction
In 1996, the Permits and Engineering Unit reviewed NPDES permit monitoring requirements for stormwater
discharges at oil terminal facilities located in the Greensboro and Charlotte areas. This review revealed
inconsistencies in monitoring requirements that were subsequently discussed with staff of the Winston-Salem
and Mooresville regional offices. These discussions and a review of past information collected at these facilities
formed the basis for much of the standard monitoring requirements contained in this Standard Operating
Procedure (SOP) for Stormwater Discharges from Oil Terminal Facilities.
In accordance with the basinwide planning schedule, the NPDES permits for the oil terminal facilities are due for
renewal in 2001. The NPDES unit has reviewed the discharge monitoring reports (DMRs) for the facilities in
order to assess the SOP currently in place. This led to some revisions and additions to the existing procedure;
the bulk of the 1996 SOP will be carried over into the 2001 revised SOP.
This document is divided into three sections that delineate the permitting requirements for oil terminal facilities.
The first part describes the minimum requirements for all oil terminal facilities in the state- both monitoring
requirements and permit limits. The second section describes potential additional site-specific requirements that
are based upon the performance of a reasonable potential analysis for the facility. Such requirements are based
upon reported data from the Discharge Monitoring Reports (DMRs) of a given facility. The third and final section
delineates additional requirements for those facilities which discharge to receiving waters carrying a water supply
classification.
I. Minimum Requirements for ALL Oil Terminal Facilities
A. Flow
Episodic Monitoring (monitor with each discharge event)
Measurement of flow is to be representative of a discharge event. Many oil terminal facilities
have storage ponds to collect runoff and therefore, discharges may not always occur during
storm events. Flow should be monitored by one of the following methods:
1. Measure flow continuously, or
2. Calculate flow based on the area draining to the outfall, the built-upon area, and the total rainfall,
using the rational equation (see below), or
3. Estimate by flow measurement at 20 minute intervals during the entire discharge event, or
4. Base flow on 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)
The rational equation is used to calculate the runoff from a region, given:
7 the runoff coefficient which accounts for infiltration and other potential losses in the region,
7 the rainfall intensity to the region,
➢ the time it takes for runoff to travel from the region's upper reaches to its outlet, and
7 the region's drainage area.
For oil terminal facilities with large storage ponds that serve to collect runoff, item 2 listed above and the
rational equation should.not be used because the calculations will determine the flow to the storage pond,
rather than the flow from the pond.
Page 1 of 8
Version 7/30/01

Permit Requirements for Discharges from Oil &'Petroleum Storage Facilities
.r' .
B: Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual
Monitor annually (assuming first five discrete storm events have already been monitored and
7:-z:'showed-rib toxic effects) .
~'• ': Monitoring Footnote: acute toxicity monitoring should occur during collection of BTEX
parameters (see item E below)
Products stored at oil terminals may contain a variety of different chemicals (some of which may have
harmful or toxic effects). To verify that toxic chemicals are not discharged to surface water, a periodic
toxicity test will be required. An acute, rather than chronic, toxicity test is required because oil terminal
facility discharges are typically short-term, episodic events. Specifically, an acute 24-hour pass/fail at 90%
waste concentration using fathead minnows is the recommended toxicity test for stormwater discharges.
Facilities that meet one or more of the following criteria will not qualify for annual monitoring and will
be required to monitor for acute toxicity during five storm events:
1. Facilities that have never monitored for acute toxicity during a storm event, or
2. Facilities that monitored for acute toxicity during four or fewer storm events during the last
permit period, or
3. Facilities that completed five acute toxicity tests during five storm events, but did not pass all
five tests.
Facilities that fail an acute toxicity test conducted during one or more of the five storm events or during an
annual monitoring event will be required to conduct quarterly monitoring for the forthcoming permit period,
and must receive State approval for reduced monitoring. For facilities that have not yet conducted acute
toxicity testing for the first five discrete storm events, a statement in the permits will allow for additional
toxicant limits should the toxicity test indicate toxic effects. At the time of permit renewal, only annual
monitoring for toxicity would be required if the facility has performed the five discrete sampling
requirements with no acute toxicity.
C: Total Suspended Solids
Monitor monthly
Daily maximum 45.0 mg/1
Historically, Total Suspended Solids (TSS) has not been a significant problem in stormwater discharges at
oil terminal facilities. A 1996 analysis of TSS data from five stormwater discharges indicated only one event
in excess of the previously permitted 30.0 mg/1 monthly average. A daily maximum limit of 45 mg/L is
recommended as a general indicator of stormwater quality. A daily maximum compliance period is given to
reflect the sporadic nature of these discharges. Should TSS monitoring data indicate any substantial
problems, the Regional Office or county may elect to enforce the instream standard for turbidity.
D. • Oil and Grease
Monitor monthly - No Limit
Monitoring Footnote: Where possible, the grab sample for oil and grease should be skimmed from
the water surface of a quiescent (calm water) zone.
- -- Historically, oil and grease has not been a significant problem in stormwater discharges at oil terminal-
facilities. However, like TSS, oil and grease is a good general indicator of the quality of a stormwater
coming from a site. Where possible, oil and grease samples should be skimmed from the surface of a
quiescent zone closest to the discharge.
E. BTEX
Monitor monthly- No Limit
Benzene, toluene, ethylbenzene and xylene are toxicants commonly found in petroleum. The previous
permitting strategy for the oil terminals required the EPA 624/625 scan, ,which,-among other contaminants
of concern (see Part II), detects BTEX compounds. A review of the discharge.monitoring report data from
the previous permitting cycle indicates that these four contaminants frequently appear in stormwater from
terminal facilities. For the most part, the other volatiles and semi-volatiles detectable by the EPA 624/625
Page 2 of 8
Version 7/30101

-Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
scan were never detected in the stormwater from these facilities. By monitoring for BTEX and naphthalene
(see part F, below), the facilities are collecting data on those pollutants that are mostly likely to be present
in the'water.
F.', EPA Method 625..
Monitor semi-annually
The intent of this monitoring requirement is to monitor for naphthalene and other indicators of middle
'distillate compounds detectable by Method 625. These contaminants are commonly found in heavy
fuels, such as diesel. During site visits of terminal facilities performed by members of the NPDES Unit,
it was observed that the majority of the terminals reserve at least one storage tank for diesel fuel.
Originally, facilities were to have monitored only for naphthalene, but since the most accurate method
of quantifying naphthalene is through Method 625 and other middle distillate compounds can be
detected through this scan, the entire results should be reported to the Division.
If it can be demonstrated by the permittee that diesel fuel is not currently being stored on site, then the
monitoring requirement on the effluent page will have the following footnote:
'Monitoring requirement applies only for facilities storing diesel or other heavy fuels on site."
G. Tank Solids, Tank Bottom Water, and Rag Layer
No direct discharge of tank solids, tank bottom water, or the rag layer is permitted.
There are typically four discrete layers of varying thickness within a storage tank. At the very bottom of the
tank is the solids layer that achieves a 1/2-1 inch thickness over a 5-6 year period. Immediately above the
solids layer is 1-6 inches of tank bottom water that results from rainwater breaching the-wall seal in open
roof tanks. Open roof tanks are not completely open, but have a roof floating directly on the product.
There is a seal between the tank walls and floating roof designed to prevent water from entering the tank.
Water breaching this seal and entering the tank is referred to as tank bottom water. The rag layer is at
most 3/4 inch thick and forms the interface between the tank bottom water and the product. The product
is the topmost layer and is 20-25 feet. Normally, the tank bottom water is removed from the tank when it
is 3-4 inches deep. The mixture of water and product in the rag layer is often drawn off when tank water is
removed because water entering tanker trucks must be minimized. As a result of potentially high levels of
organic compounds in the three bottom layers of storage tanks, they are not to be discharged, but instead
should be transported off-site for appropriate treatment and/or disposal or treated/recovered onsite if
treatment technology capabilities occur onsite.
H. Hydrostatic Testing
Hydrostatic testing of oil tanks normally occurs once every five to six years. Prior to the hydrostatic testing,
the tank is completely drained and tank bottom materials are handled as described in the previous section.
The tanks are completely cleaned and then coated and welded (if necessary). The tank is then filled with
water for the hydrostatic test. Some oil terminal facilities use stream or lake water to hydrostatic test their
tanks, while others use potable city water. Because the tank is thoroughly cleaned prior to refilling with
water for the hydrostatic test, water discharged from the tank following the hydrostatic test should be fairly
clean. However, tank discharges following hydrostatic testing may contain contamination. Therefore,
monitoring of the tank water prior to direct discharge will be required. There shall be no direct discharge
from oil terminal facilities following hydrostatic testing if concentrations of benzene and/or toluene are
greater than their respective water quality standards (see effluent pages at end of SOP for details).
I. MTBE Monitoring
Monitor monthly
Within the last year, the Environmental Protection Agency has recommended banning methyl tertiary butyl
ether (MTBE), an ingredient commonly used in gasoline to aid in the reduction of air pollution. MTBE was
originally added to gasoline in response to a 1990 law that required higher oxygen content in gas sold in the
most-polluted cities. It has since become a cause for concern since the EPA now believes that MTBE may
be a carcinogen and is seeking to outlaw the compound.
Since MTBE contamination of water is a public health concern, monthly MTBE monitoring will be added to
all facilities. For those facilities currently monitoring for MTBE, reasonable potential analysis will be
performed to assess the need for an MTBE limit.- In non-water supply waters, the instream MTBE standard
Page 3 of B
Version 7l30I01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
is 2393 µg/L, and is unlikely to be violated. All facilities discharging to water supply waters will have a
special condition*added to the permit that pertains to MTBE monitoring and source reduction (see Part
III.C.),
II., Additional Site Specific Requirements \
A. EPA Method 6244
Monitor semi-annually-
The entire 624/625 scan was originally included in the SOP to assess which of the petroleum-associated
organic chemicals are found in stormwater. These tests scan for volatile and semi-volatile organics and
cost approximately $700 to run (Ray Kelling, personal communication 2/14/01). Currently, the oil
terminal facilities are performing the scan twice a year. Most facilities obtain results consisting entirely of
non-detects, but a few have detected one or more of the compounds on the 624/625 list. Tables 1 and 2
summarize the compounds included in the scans and note those parameters detected during the last
permitting cycle. -
After a review of the data and discussions with different members of the Division of Water Quality Point
Source Branch, it has been decided to assign semi-annual monitoring using EPA Method 624 to any of the
facilities that detected any compound listed in Table 1 that is not benzene, toluene, ethylbenzene, xylene or
naphthalene (as these were found in most discharges and are covered by monitoring requirements listed
above).
Table 1. Compounds detectable by EPA Method 624
TERMINALPARAMETER DETECTED IN OIL
Acrolein
Acrylonitrile
Benzene J
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane ✓
Dibromochloromethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1,1-Dichloroethane
trans-1,2-Dichloroethene
1,2-Dichloro ro ane
cis-1,3-Dichloro ro ene
trans-l,3-Dichloro ro ene
Ethyl benzene ✓
Methylene chloride ✓
1,1,2,2-Tetrachloroethane
Tetrachloroethane
Toluene-
1,1,1-Tr-ichloroethene
1,1,2-Trichloroethene
Trichloroethane
Trichlorofluoromethane ./
Vinyl chloride
Page 4 of 8
Version 7/30101

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
Table 2. Compounds detectable by EPA Method 625
PARAMETER DETECTED IN OIL TERMINAL STORMWATER?
Acena hthene
Acena hth lene
Anthracene
Benzo a anthracene
Benzo b fluoranthene
Benzo k fluoranthene
Benzo a rene
Benzo hi a lene
Ben ] bu 1 phthalate
Bis 2-chloroeth ] ether
Bis 2-chloroetho methane
Bis 2-eth the 1 hthalate
Bis 2-chloroiso ro 1 ether
4-Bromophenyl phenyl
ether
2-Chlorona hthalele
4-Chlorophenyl phenyl
ether
Chrysene
Dibenzo a,h anthracene
Di-n-bu 1 hthalate
1,3-Dichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dick lorobenzidine
Diethyl phthalate
Dimeth 1 phthalate
2,4-Dinitrotoluene
2,6-Din itrotoluene
Di-n-octylphthalate ✓
)~luoranthene
Fluorene
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
lndeno 1,2,3-cd ene
lso horone
Naphthalene ✓
Nitrobenzene
N-Nitrosodi-n-propylamine
PCBs
Phenanthrene ✓
rene
Toxa hene _
1,2,4-Trichlorobenzene
4-Chloro-3-meth I henol
2-Chloro henol
2,4-Dichloro henol
2,4-Dime th 1 henol
2,4-Dinitro phenol
2-Meth 1-4,6-dinitro henol
2-Nitro phenol
4-Nitro phenol
Pentachloro henol
Phenol ✓
2,4,6-Trichloro henol
Page 5 of B
Version 7130/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
B. Reasonable Potential (General)
_,_The reasonable potential procedure is a method used to determine the potential of a discharge to violate a
water quality standard for a given parameter based on existing data. If a parameter is determined to have
reasonable potential to violate a water quality standard; a limit arid monthly monitoring will be required. A
parameter is determined to have reasonable potential to violate a water quality standard if a calculated
maximum predicted effluent concentration is greater than the allowable effluent concentration.
Reasonable potential is determined by performing a statistical analysis for each parameter of concern that
has either a state or federal water quality standard. For each parameter, the statistical analysis works best
with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more
accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent
concentration based on the existing data set. A step-by-step procedure for determining whether or not a
parameter should be limited based on reasonable potential determination follows:
STEP
1. Determine the number of sample points (n)
2. Determine highest value from data set. Best professional judgment should be used by the reviewer so
as not to use an outlier. Since an outlier will not be determined statistically, maximum values should
rarely be discarded in this analysis.
3. Determine the coefficient of variation (CV = STD DEV/MEAN)
4. Determine the appropriate multiplication factor to be used by comparing the number of samples versus
the co-efficient of variation (see Table 3-1)
S. Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to
obtain the maximum predicted effluent concentration.
6. Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable
effluent concentration, which is based on instream dilution and the corresponding water quality
standard. EPA recommends that permitting authorities find reasonable potential when the maximum
predicted effluent concentration is greater than the allowable effluent concentration.
A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet" and is
located on the NPDES server. The spreadsheet requires the input of the facility name and permit number,
the waste flow (Qw), 7Q 10 flow, pollutant name, state or federal water quality standard, and the DMR data
points with appropriate units. The spreadsheet then computes the standard deviation, mean, and
coefficient of variation for the entered data points. The coefficient of variation is then used along with n
(the number of data points entered in the spreadsheet) to determine the Multiplication Factor. This
Multiplication Factor is entered into the Toxicant Spreadsheet to calculate the maximum predicted
concentration.
If the maximum predicted effluent concentration is greater than or equal to the allowable effluent
concentration, (or in other words, if there is reasonable potential for a water quality standard violation), the
parameter should be limited (as a'daily maximum) and monitored on a monthly basis. The daily maximum
limit shall be equal to the standard for that parameter multiplied by the dilution of the receiving stream
under summer 7Q 10 conditions for non-carcinogens. Average flow should be used for carcinogens and
30Q2 flow should be used for aesthetic standards.
If a facility monitors semi-annually (twice/year), 10 data points would be obtained over a five-year permit
period which is slightly more than the minimum number of data points which will accurately characterize
an effluent discharge (USEPA March 1991).
In cases where a facility requests reconsideration of a limit requirement, monthly monitoring should be
required for at least 10 months so that 10 data points can be obtained and a second reasonable potential
calculation can be conducted. If there is no reasonable potential for a water quality violation, monitoring
should be reduced (to semi-annually).
Page 6 of 8
Version 7l30101

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. Turbidity Monitoring (Paw Creek terminals)
Monitor quarterly - - -
(Monthly monitoring and limit of 50 NTU if facility demonstrates reasonable potential)
Based on concerns regarding anti-backsliding, the EPA requested the Division re-examine the basis for the
elimination of turbidity monitoring for 12 of the 14 Paw Creek oil terminals that were required to monitor
for turbidity prior to the most recent permit renewal. This second examination of the data showed that
there were turbidity standard violations since the last analysis at several of the oil terminals. The Division
therefore acknowledges that its second evaluation resulted in a different outcome from the initial
investigation and agrees that turbidity monitoring should be added to the discharge permits for the oil
terminals in Paw Creek. Facilities were sent notice in February 1999 that quarterly turbidity monitoring
would be required at the facility effective March 1, 1999. If sufficient data exist, then reasonable
potential should be performed to assess the need for more frequent monitoring and a limit of 50
NTU. For all facilities, the following footnote will be placed on the effluent limits page:
*Turbidity—Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving stream
background turbidity exceeds 50 NTU, effluent shall not cause this background value to increase.
III. Additional Monitoring Requirements for Water Supply (WS) Waters
A. Phenol
Monitor monthly
(Limit assigned if reasonable potential is demonstrated)
Phenol is a common component of petroleum compounds stored in terminals, can result in tainting of fish
tissue, and can cause taste and odor (organoIeptic) problems in drinking water. In addition, phenol
discharged from terminals could combine with chlorine in water treatment facilities to form chlorinated
phenols. Limiting the discharge of phenol into water supply classified waterbodies could reduce
chlorinated phenol formation and their concentration in drinking water. As a result of the expected
occurrence of phenol in oil terminal facility discharges and the possibility of chlorinated phenol formation,
phenol will be monitored on a monthly basis in water supply classified waters.
Based on an extensive review and analysis of data collected during the last permitting cycle, the facilities
are no longer required to monitor for chlorinated phenols, since none were ever detected in oil terminal
effluent. The concern over limiting phenols lies in the need to inhibit formation of chlorinated phenolic
compounds at downstream water treatment plants. Joe Corporon of the NPDES Unit calculated an
allowable phenolic loading for each terminal in Mecklenburg County that will prevent a downstream
violation of the NC State standard for phenols of 1 ug/L. Meg Kerr wrote a similar memo for those
terminals in Guilford County in 1983. Reasonable potential will be performed using these allowable
phenolic loadings (see attached memo).
_-. Benzene-_'
Monitor monthly
Daily maximum limit - 1.19 pg/l * dilution of the receiving stream under average flow conditions
Benzene is a known carcinogen and can pose a potential health risk to humans consuming water with
benzene. The water quality standard for benzene in waters classified as water supplies is 1.19 Ng/l. The
daily maximum limit for these facilities is therefore 1.19 multiplied by the dilution of the receiving stream
under average flow conditions (rounded to two significant digits). This limit may be excluded from the
permit only if there are sufficient data (eight sampling events) to demonstrate "no reasonable potential." If
there is no reasonable potential, there will only be a monthly monitoring requirement.
Page 7 of 8
Version 7l30101

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. MTBE
. Monitor monthly
MTBE special condition
Given that this compound is considered a possible carcinogen, there should be a greater effort to keep high
levels of MTBE out of water supply waters. As per the Paw Creek Hearing Officer's Report, after one year of
monthly MTBE samples have been recorded, the facility must review the MTBE data. If no MTBE has been
detected in the effluent samples, the facility may request a minor modification to the permit reducing the
frequency of MTBE monitoring. If, however, MTBE has been detected during any of the discharge events,
the Permittee must develop a plan of action to reduce the levels of MTBE entering the receiving stream.
It is anticipated that an MTBE criterion for surface waters will be established at the time of the next permit
renewal. At that time, sufficient data will be available to assess the reasonable potential for a facility to
exceed any such standard or criterion.
REFERENCES
Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering
News.
Kelling, Ray, (Division of Water Quality Chemistry Lab). June 1996. Conversations with P. Clark_
Kelling, Ray, (Division of Water Quality Chemistry Lab). February 2001. Conversations with N. Sierra.
Linville, Ron, (Winston-Salem Regional Office). March 1996. Telephone conversation with P. Clark.
Reid, Dianne, (Division of Water Quality - Planning Branch). June 1996. Conversations with P. Clark.
Shiver, Rick, (Wilmington Regional Office). July 2001. Findings and Recommendations for Public Hearing
Held on April 19, 2001.
USEPA. March 1991. Technical Support Document For Water Quality-Based Toxics Control. EPA/505/2-
90-001.
Page 8 of 8
Version 7I30101

��
LJh ay) c I)`L"4t)r n �l�•I�j LU-1'l C�{ -o S"r�,� ��-6l✓I�LJ�LCY
W►ll�ams
VIA 1'ACSFNIILE 919/733-0719 ENERGY SERVICES
1717 South Bnuidcr Ave[ILIC
1?0. Box 21628
May 2, 2001 Tulsa,Oklahoma 741 21-1 628
NCDENR— DWQ—NPDES Unit
1621 Mail Service Center l
Raleigh, NC 27699-1617
1i
Re: Draft NPDES Permit NCO005185 MAY — 3 2001
Williams Terminals Holdings, L. P.'s Charlotte lI Terminal
7924 Mount Holly Road
D 11R - 1"I,;TI.R C.;!.LITY
Mecklenburg County POINT SOUKt [11P.M d w.a
Dear Ms, Rodriguez:
In response to subject draft NPDES permit, Williams Terminals Foldings, L. P. (Williams)has the
following general comments:
1. Williams purchased this terminal from Amoco in January 1999, Comments made in this letter are
relative to Williams' term of operation of the terminal only.
2. On the permit cover sheet, it is noted that it should say Williams Terminals Holdings, L. P. rather than (7
Williams Energy Ventures.
3. On the"Supplement to Permit Cover Sheet", the incorrect(former) company name is again listed, and
it is further noted that Long Creek is mentioned relative to the point of discharge, whereas Gum
Branch is listed on the prior page.
Relative to the proposed permit itself, Williams has the following additional comments:
,1. Benzene, toluene, ethylbenzene and xylene have been measured semi-annually in accordance with the
current NPDES permit,and there have been no detections. .
2. Benzene has been measured monthly in accordance with the current NPDES permit, with only two
h0z9 a— detections. One detection(18 ug/1) was shortly after Williams took over operation of the terminal, and
rIw>u11 the other was in January 2001 (only 3.8 ltg/l),
i��t° cj.-3. Naphthalene has been measured semi-annually in accordance with the current NPDES permit, and
there have been no detections.
i4. MTBE: was measured February 1999, and was not detected at 5 µg/l.
5. Phenol has been measured both semi-annually and monthly, in accordance with the current NPDES
no�t� ti � permit, and there have been no detections.
�U7 Givcn that the above-listed parameters have been measured either monthly or semi-annually, or both,since
issuance of the current NPDES permit(with the exception of MT13E which was measured in February
1999, outside of the permit),and that there have only been two detections, one of which was very minor,
Williams sees no clear reason for the draft requirement for monthly analyses at its Charlotte 11 Terminal.
Williams understands that the Department may have concern relative to these parameters and the potential
for their detection at bulk petroleum facilities. However, at Williams' Charlotte 11 Terminal, there have
been only two detections out of dozens of analyses. Williams believes that this fact is directly attributable
to the exemplary manner in which the terminal is maintained.

i One other comment is with regard to the limits placed on benzene and MTBE. Your cover letter mentions
the need for a benzene limit because of a reasonable potential to exceed the water quality standard,but does
not discus the MTBE limit other than to say that it is being added to all oil terminal permits in the state.
While both limits are of concern, the MTBE limit is of particular concern. Williams is not aware of an
MTBE standard anywhere close to 11.6 µg/l.
In closing, Williams is in agreement with the continuation of quarterly turbidity monitoring and the
inclusion of pH monitoring. However,Williams continues to believe that requiring monthly(versus the
current semi-annual)monitoring(at an additional annual cost of several thousand dollars) for the BTEX
parameters,naphthalene,phenol and MT13E is unnecessary,and therefore respectfully requests that the
Department reconsider this issue. Williams believes continuation of current semi-annual monitoring of
these parameters is more appropriate. It would also be appreciated if the benzene and MTBE limits were
given additional consideration, given my comment above.
If there are any questions relative to this transmittal,please call. I can be reached at 918/574-8420.
Sincerely,
teve W. Mon-REM, CHMM
Sr. Environmental Specialist
H
c1W050201
c: Mark Bowen
File/Charlotte II/Water Mgmt

NC00051.85 Williams Energy Ventures Outtall 006
Mecklenb rg Count ,
Date Flow TSS O& G Phenol Benzene Toluene Xylene Tox EPA624/625 Turbidity
MGD nn /L m /L m /L (u /L) (u /L (u IL
Dec-97 0.037737 <10 <5 <10 <1
Nov-97 0.050544 <10 <5 <10 <1
Oct-97 0.058372 <10 <5 <10 <1
Sep-97 0.082104 <10 <5 <10 <1
Jul-97 0.107879 <10 <5 <10 <1
Jun-97 0.053787 <10 <5 <10 <1
0.168541
May-97 0.018527 <10 <5 <10 <1 P
Apr-97 0.019397 <10 7 <10 <1 <10 non detect
Mar-97 0.085221 12 7 <10 <1
0.154599 <10 <5 <10 <1
Feb-97 0.101564 10 <5 <10 <1
0.180721
Jan-97 0.00864 <10 <5 <10 <1
Dec-98 0.197865 <10 <5 <10 <1
0.073251
Nov-98 0,107094 <10 <5 <10 <5 non detect
0.092125
Sep-98 0.037713
0.119591 4 <5 <10 <1
0.084219
0.067289
Aug-98 0,104917 4 <5 <10 <1
Jul-98 0.11211 50 <5 <10 72
Jun-98 0.068829 <10 <5 <10 <1 P
Apr-98 0.112758 <10 <5 <10 <1
0.150693
Mar-98 0.087009 <10 <5 <10 8
0.06886
0.11554
0.131824
Feb-98 0.116654 <10 <5 <10 <1
0.074284
0.127
Jan-98 0.118376
0.148134 <10 <5 <10 <1
0.893369
0.034328
0.099556
0.135958
0,110272
0,091418
0.117365
0.16827
0.014883
Dec-99 0.147954 <10 <5 <10 <1
Nov-99 0.23145
0.317894
0.289147
0.312441
0.188101
0.277895
0,141004
0.173121
0.031204 <1
0,128914 <10 <5 <10 <1 <5 non detect
Oct-99 0.0221
0.0368
0.0375 <10 <5 <10 <1
0,007

15� o p k P> Z- fiv 4 . k�� T.
�Szp-99 0.3705 <10 <5 <10 <1
Aug-99 0,93572 14 <5 <10 <1
Jul-99 0.929769 72 <5 <10 18
Jun-99 0.889028 <10 <5 <10 <1
May-99 0.097573 <10 <6 <10 <1
0.08309
0.048075
Apr-99 0.064602 <10 <5 <10 <1 <3 . P
0,025661
0.144658
Feb-99 0.107724 <10 <5 <10 <1 non detect
0.092068
0,071919
0.112884
0.078127
Jan-99 0.116367 <10 <5 <10 <1
0.087832
Nov-00 0.001194 <2 <5 <10 <1 8.4
0.066232
0.124491
Sep-00 0,22324 0.5
0.336379 <5 <10 <5
Aug-00 0,135675
0.065342 5 <5 <10 <1
0.133184
Jul-00 0.005545 4 <5 <10 <10 7.6
0.049484
0.10146
0.064084
0.10561
0.098102
0.03622
Apr-00 0.13239 78 17 <10 <5 <5 P non detect
0.056623
Mar-00 0.234373 12 <5 <.1 <1
0.022621
Feb-00 0.283797 18
0,091374 <5 <10 <1
0.24
0.048327
0.021375
Jan-00 0,73612 <5 <10 <1
0.69
0.1833
0.3251
SUMMARY
Flow TSS O& G Phenol Benzene Toluene Xylene Tox EPA624/625 Turbidity
MGD m /L m /L m /L u /L u /L u /L)
averse 0,155419 24.09 10.3333 32.6667 8.625
max 0.93572 78 17 72 18
# samples 38 41 41 41 1 3 4 5 4
#detects 11 3 0 31 01 0 0 0 4
Phenol limit calculation
Max flow 0.93572 MGD
Limit= 0,055101 m /I

REASONABLE POTENTIAL ANALYSIS
Prepared by: Teresa Rodriguez 3/02/01
Facility Name= Williams Energy Ventures
NPDES#i= NC0005185
Ow(MGD) = 0.935
Qw(cfs)= 1.446632
701 Os (cfs)= 0
I WC(%)= 100.00
Chronic CCC w/s7Q10 dil. Acute CIVIC wlno dil. Frequency of Detection
Parameter FINAL RESULTS, ug/l FINAL RESULTS, ug/l #Samples # Detects
Xylene
Max. Fred Cw - 0.0
Allowable Cw 88.5 0 0
Benzene
Max. Pred Cw C-4217123
Allowable Cw 1.2 41 0
Toluene
Max. Pred Cw 0.0
Allowable Cw 11.0 0 0
Phenol
Max. Pred Cw 0.0
Allowable Cw 1.0 0 0
MTBE
Max. Fred Cw 0.0
Allowable Cwj 11.6 0 0
Modified Data: Use 0.5 Detection Limit for non-detects

Parameter= 113enzene
Standard= 1.19 pg/l
Dataset= DMR97-00
Modified Data Nondetects RESULTS
0.5 <1 Std Dev. 11.432
0.5 <1 Mean 3.110
0.5 <1 C.V. 3.676
0.5 <1 Sample# 41.000
0.5 <1
0.5 <1 Mult Factor 1 5.850
0.5 <1 Max. Value 72.000 ggll
0.5 <1 Max. Pred Cw 421.200 ug/l
0.5 <1 Allowable Cw 1.190 ugll
0.5 <1
0.5 <1
0.5 <1
0.5 <1
2.5 <5
0.5 <1
0.5 <1
72 72
0.5 <1
0.5 <1
8 8
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
18 18
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
2.5 <5
0.5 <1
5 <10
2.5 <5
0.5 <1
0.5 <1
0.5 <1

State of North Carolina
Department of Environment +
and Natural Resources a
Division of Water Quality
Michael F. Easley, Governor NCDENR
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
April 2, 2001
MEMORANDUM RECEIVED
To: Britt setzer
NC DEN12 / DE'I-1 / Regional Engineer
klaoresvillc Regional Office APR 0 4 2001
From: 'Teresa Rodriguez NCDENR
N1)1)ES unit Division of Environmental Health
PiJhl?� Water Sil Section
Subject: Review of Draft NPDES Permit NCO005185 h1Cj'. -,:::,viIle Regional Office
Willams Energy Venture - Paw Creek Terminal
Mecklenburg County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
May 2, 2001. 11' you have any questions on the draft permit, please contact me at the telephone number
or e-mail address listed at the bottom of this page.
wwww.w�,•,�ww��www,ww�ww�w,,Hw�ww��w�www�w�ww�ww�w.w�w�w�w�w�ww
w�w�w�ww,w�www�w�ww�w,ww�ww�w�ww�www�w.ww�w�w.www��.,�.w�.wn"�.ww
REsPON,5E- (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properly, the
stated effluent limits are met prior to discharge, and the discharge does not contravene the designated
water quality standards.
F-1 Concurs with issuance of the above permit, provided the Following conditions-are-r�el:� M
4i'ttlLU
u�
F-1 Opposes the issuance of the above permit, based on reasons stated 1) ow, r DER pUAL1"
gENR - RCE gRANCN
Signed Dates
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 919 733-5083,extension 595 (fax)919 733-0719
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.usINPDES Teresa Rodriguez@ ncmail-net

4/ 0 ,,-w
W►llas
March 9, 2001
ENERGY SERVICES
1717 South Boulder Avenue
P.O. Box 21 r2A
North Carolina Department of Environment and Natural Resources Tuka,OkLilooina 74121-1628
Division of Water Quality-NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Notification of Change to Permit Holder
NPDES Permit No. NC0005185
Williams Energy Ventures' Charlotte II Terminal
Williams Energy Ventures, Inc., a Delaware corporation ("WEV Inc."), owns and operates a bulk
petroleum terminal located at 7924 Mt. Holly Road, Charlotte, NC 28214. The facility operates in
accordance with NPDES Permit No. NC0005185. WEV Inc. is converting itself from a Delaware
corporation to a Delaware limited partnership that will be known as Williams Terminals Holdings,
L.P., as allowed by Delaware general corporate law Section 266.
Under Delaware law, the conversion of WEV Inc. to Williams Terminals Holdings, L.P. does not
interrupt the existence of the legal "person" of WEV Inc. Rather, such legal "person"will continue
to exist in Williams Terminals Holdings, L.P. upon the conversion in the same fashion that a legal
entity that changes its name continues to exist as the same legal "person" under its new name.
The only change at the facility will be the name of the permitee; the operations and personnel will
not change. Accordingly, WEV Inc. requests that the above-referenced permit be amended to
reflect the conversion of WEV Inc. to Williams Terminals Holdings, L.P. If such conversion is
deemed to constitute a transfer of the above-referenced permit from WEV to Williams Terminals
Holdings L.P., then such a transfer is hereby requested.
As noted above, personnel will not change and therefore my signature below serves for both WEV
Inc. and Williams Terminals Holdings, L.P. The effective date of transfer was February 9, 2001.
Please find enclosed the completed NPDES Permit Name/Ownership Change Form. My
understanding is that this form and letter fulfills the notification requirement for transferring the
above-referenced permit, if required. Please call Stacy Kisler at 918/574-8022 or Steve Monn at
918/574-8420 if you need anything further.
Sincerely,
ti
Rob Hawksworth
Director- Safety, Environmental and Training Services
Enclosure
cc: Charlotte II Water File
Water File)Charlotte II Terminal
SAI n depend entTermin21sWLPtransfer\CharlotteI I\NC-CharAmocWater.doc

State of North Carolina IT
Department of Environment A
00
and Natural Resources4va
Division of Water Quality r-►-r�+-
James B. Hunt, Jr., Governor NCDENR
Bill Holman, Secretary
Kerr T. Stevens, Director NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
PERMIT NAME/OWNERSHIP CHANGE FORM
1. CURRENT PERMIT INFORMATION:
Permit Number: NC00 n1:1�11 5 f
! t J
1. Permit holder's name: m
2. Permit's signing official's name and title: S
(Person legally responsible for permit)
i fonm aM Kra n i &Pwus
! , (Title)
3. Mailing address: `i City:. Tom`Sq
State: Zip Code: l 0 ff ,,rrP��hone: ( 1 f� ) 3
E-mail address: _ R�H aw 1 swor`i`� )W 1 jL GlIm • km
II. NEW OWNERINAME INFORMATION:
1. This request for a name change is a result of:
a. Change in ownership of property/company
_X—b. Name change only
c. Other(please explain):
2. New owner's name (name to be put on permit):
i4o Id irigs L. ot�. 17 Tflmiad
3. New owner's or signing official's name and title: ?C;-. cuAjkS r &-0)
(Person legally responsible for permit)
J' �-�1�1 i rrlru'rit:Cl.(a��r�ni nQ�ertl�S'
I (Title) J
4. Mailing address: �.� , �'7 City: 118a.
p,
State: Zip Code: 7q101 Phone: (Q f q
E-mail address: • 4ztW ki W70r'T'K' -4_ W I'C t(aYls_-_ctfn
1617 Mail Service Center,Raleigh,North Carolina 27699-1617 Telephone[phone] FAX[phone]
An Equal Opportunity Affirmative Action Employer 50%recycled 110%post-consumer paper

PERMIT NAME / OWNERSHIP CHANGE FORM
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF WATER QUALITY UNLESS
ALL OF THE APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a contract, deed, articles of
incorporation)
For changes of ownership, this form must be completed and signed by both the current permit
holder and the new owner of the facility.
For name change only, the current permit holder must complete and sign the Applicant's
Certification.
Current Permmittee's Certification:
I, lob I`T kWa - _ T, attest that this application for
name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: /'( - /-'-- - Date: o "
Applicant's Certification:
I, ' J" I -ate.l Kj Ia L ,._ , attest that this application for a
name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: //Zlv/ �-- . Date: 4 d r
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING
INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DENR I DWQ
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 9-99

REC E H E Williams
FEB z M01
ENERGY SERVICES
1717 South Boulder Avenue
February 21,2001 DENR-WATER QUALITY CO. Box 21628
POINT SOURCE BRANCH Tultia,Oklahoma 74 1 2 1-1 628
Mr. Charles H. Weaver,Jr.
NC DENR 1 Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh,NC 27699-1617
Re: NPDES Permit NC0005185 Renewal Application
Williams Terminals Holdings, L.P. Charlotte lI Terminal,Mecklenburg County
(NC DFNR's Paw Creek terminal-site#2)
Dear Mr. Weaver:
This transmittal represents formal submittal for renewal of subject NPDES permit, since it is currently due
to expire on August 31, 2001. This submittal is being made prior to the 180-day pre-expiration submittal
requirement. To this end, attached please find a completed original application(Short Form C),and two
complete copies of this cover letter and the application form. Furthermore, enclosed please find copies of
my authorization to prepare and submit the application for renewal.
Please note(at the subject listing above)that since our last correspondence,Williams Energy Ventures, Inc,
converted itself from a corporation to a partnership named Williams Terminals Holdings, L.P. A complete
notice per NC DENR requirement will follow in the very near future. However, since formation of the
partnership occurred on February 9, 2001, this letter and the enclosed Short Form C list the applicant as
Williams Terminals Holdings, L.P.
There have been no changes at the terminal that would affect operation under the NPDES permit since
issuance of the last NPDES permit. Furthermore, the terminal generates no sludge as a result of wastewater
treatment, so there is no NPDES sludge management plan for the terminal.
If there are any questions with regard to this submittal, I can be contacted at 918/574-8420.
Sincerely,
j
W. Morn—REM, CfiA1M
nvironmental Specialist
11
c1W022101
c: Mark Bowen, Charlotte II Terminal
Charlotte 11 Water Mgmt File-Tulsa

Williams Energy Venture 05195
Subject: Williams Energy Venture 05185
Date: Wed, 11 Apr 2001 14:49:56 -0400
From: Kristie Robeson <[e-mail]>
To: Teresa Rodriguez <Teresa.Rodriguez@nc mail.net>
I have reviewed their draft and the only problem I found was the
receiving stream was incorrect on the first page of the draft. It has
UT to Gum Creek. Should be UT tong Creek. All the others you sent me
were fine.
1 of 1 5/29/01 2:27 PM

RE: NPDES Permit NCO005185
Subject: RE: NPDES Permit NCO005185
Date: Wed, 10 Nov 1999 15:11:20 -0600
From: "Kisler, Stacy" <[e-mail]>
To: 'Charles Weaver' <[e-mail]>
Mr. Weaver,
Williams' has delegated authority for the Charlotte Terminal to Mr. Steve W.
Monn, Senior Environmental Specialist. Steve can be contacted at:
Williams Energy Services
One Williams Center, MD 36-40
Tulsa, OK 74101
918/573-6582 (phone)
918/573-6790 (fax)
[e-mail] (e-mail)
Please send the revised permit to him. If you have additional questions,
please contact me at 918/573-6395 or via this e-mail address. Thank you for
your assistance.
Stacy Kisler
-----Original Message-----
From: Charles Weaver [mailto:charles.weaver ncmail.net]
Sent: Tuesday, November 02, 1999 11:59 AM
To: Kisler, Stacy
Subject: Re: NPDES Permit NCO005185
Stacy, our current plan is to change the name and ownership of permit
NC0005185 from Amoco to WEV. At that time, the groundwater remediation
outfall and monitoring requirements in NC0005185 will be transferred to
coverage under General Permit NCG510d00. Amoco will be responsible for the
groundwater remediation system, and the Certificate of Coverage under
NCG510000 will be issued to them.
No public notice will benecessary for these two actions. Once I have
complete effluent data for the first 3 quarters of 1999 - and I'm only
missing the September data - I can complete this modification.
I'll let you know if anything changes in this scenario. You should expect
to receive the Name & Ownership change modification within this month.
Please confirm whose name & address I should put on the revised permit - I
currently have David Killingsworth in Ft. Lauderdale as the WEV contact.
Let me know if someone else should receive the cover letter.
CHW
r
1 of 1 11/15/99 11:18 AM

State of North CarolinaIT V
Department of Environment
and Natural Resources 02
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCE5
February 22, 1999
Mr. J.W. Scrivner
Amoco Oil Company
375 Northridge Road, Suite 350
Atlanta, Georgia 30350-3296
Subject: Letter to Require Effluent
Turbidity Monitoring
Permit No. NCO005185
Amoco Oil Company
Mecklenburg County
Dear Mr. Scrivner:
As you are aware, the turbidity monitoring requirement was eliminated from your
permit upon renewal in August 1996. Although turbidity monitoring was eliminated, total
suspended solids (TSS) monitoring with a limit remains in the permit. It was the Division's
contention that should monitoring data indicate TSS problems, the state has the option of
enforcing the instream standard for turbidity. However, the EPA is still concerned with the
removal of the turbidity monitoring requirement from several oil terminal discharge permits.
The following paragraphs address that concern.
During the research phase required for permit development, it was noted that the 14
permits in the Paw Creek area had vastly different requirements for solids measurements.
Permits contained any combination of total suspended solids (TSS), turbidity, and settleable
solids monitoring and/or limits. In an effort to provide consistency, TSS, turbidity, and
settleable solids results from six oil terminals in the Paw Creek area were examined from
July 1994 through September 1995. Results showed that TSS and turbidity exhibited
similar trends. Both pollutants appeared to increase and decrease at the same time. In
addition, for the period examined, there were no turbidity violations, although there were a
few TSS violations. These data resulted in the Division questioning whether monitoring
was necessary for both solids parameters. Was there an added benefit to requiring turbidity
monitoring in addition to TSS monitoring? The Division concluded that turbidity was
correlated with TSS results, and thus, only TSS monitoring with a limit was required. In
addition, North Carolina has a water quality standard for turbidity. Therefore, although
turbidity monitoring is not required in the discharge permits, the State still has the authority
to enforce the instream turbidity standard.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper

Mr. Scrivner
February 22, 1999
Page 2
Based on concerns regarding anti-backsliding, the EPA requested the Division re-
examine the basis for the elimination of turbidity monitoring for 12 of the 14 Paw Creek
oil terminals that were required to monitor for turbidity prior to the most recent permit
renewal. This second examination of the data showed that there were turbidity standard
violations since the last analysis at several of the oil terminals. The Division will
investigate the causes of these violations to determine what steps may be necessary to
control solids levels at these sites. Therefore, the Division acknowledges that its second
evaluation resulted in a different outcome from the initial investigation and agrees that
turbidity monitoring should be added to the discharge permits for several of the oil
terminals. This letter serves as the official notice that quarterly turbidity monitoring
will be required at the facility effective March 1,1999. If monitoring data show a
reasonable potential to violate water quality standards, then limits will be imposed upon
renewal.
If you have any questions concerning this change, please contact Bethany Bolt at
[phone], extension 551.
Sincerely,
reston Howard, Jr., P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit '
Point Source Compliance Enforcement Unit
p,l_ E/C U.S.POSTAGE A
F1,hRl3: 00.261
RETURN SERVICE , Wl;
REQUESTED n METER SE EiiE,l
f
re 5' .
-�%r'=' �'� -� �!k!l1111lI1��E!!!l1711�11�ilFil�k+!!l111t11�il�kllf