HomeMy WebLinkAboutNC0005771_Permit (Issuance)_20010730 NPDES DOCYNKMT SCAMMIMG COVER SHEET
NPDES Permit: NC0005771
Document Type: i""Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Report
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: July 30, 2001
Tb.i,�dacu.m�ytzt f�priat�d�a r�u�ete paper-i,�ar+e auy
r caxkteat oa t wet X*e,%rqerww-- nide
y 0, VV A r�R Michael F. Easley
" Q ^ Governor
' � p NR William G. Ross,Jr., Secretary
North Carolina Department of Environment and Natural Resources
'< Kerr T. Stevens, Director
Division of Water Quality
July 30, 2001
Ms. Barbara Castleberry
TransMontaigne Terminaling, Inc.
200 Mansell Court East—Suite 600
Roswell,Georgia 30076-4853
Subject: Issuance of NPDES Permit NCO005771
Charlotte/Paw Creek Terminal #1
Mecklenburg County
Dear Ifs. Castleberry:
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,most of which are the result of the Paw Creek hearing officer's
recommendations:
pH monitoring and limits have been removed from your 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 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 the best method for detecting naphthalene
and other middle distillate compounds and is therefore a.more appropriate monitoring requirement_ If your facility
collects eight to ten samples in which none of the 625 compounds are detected,you may submit a request to the
Division that this sampling requirement be eliminated.
• Flow monitoring frequency has been changed from monthly to episodic. As per a request by the Mooresville
Regional Office, flow must be measured with each discharge event
If any parts,rneasutement 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 Natalie Sierra at telephone number(919) 733-
5083, extension 551.
Sincerel
K T to ens
cc; Mooresville Regional Office/Water Quality Section
iNPDES Unit-
Central Files
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Department of Environmental Protection
N.C.Division of Water Quality 1 NPDES Unit Phone:(919)733-5083
1617 mail Service Center,Raleigh,NC 27699-1617 fax:(919)73M719
Intemet:h2o.enr.state.nc.us DENR Customer Service Center.1 800 623-7748
Permit NC000577I.
S ,
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended,
TransMontaigne Terminaling, Inc.
is hereby authorized to discharge wastewater from outfalls Iocated at the
Charlotte/Paw Creek Terminal #1
7615 Old Mount Holly Road
Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Paw 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.
Kerr , Director
Divi 'on o ater Quaii
By Authority of the Environmental Management Commission
Permit NC0005771 M x�
SUPPLEMENT TO PERMIT COVER SHEET
TransMontaigne Terminaling, Inc..
is hereby authorized to:
1. continue to operate the existing water pollution control system consisting of:
• grit removal
• an oil/water separator
• detention ponds
located at the Charlotte/Paw Creek Terminal 41 at 7615 Old Mount Holy Road near Charlotte in
Mecklenburg County, and
2. discharge stormwater and wash water from said treatment facility through Outfall 001 at a specified
location (see attached map) into an unnamed tributary to Paw Creek, a waterbody classified as C
waters within the Catawba River Basin.
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TERMINAL DRAINAGE PLAN - '^'■~T .� 114+044 R01 ICM1 O�O.R yt
Permit NC0005771
A. (1.) EFFLUENT LIMITATIONS AND MONITORING RE UIREMENTS
Beginning on t e effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001; Such discharges shall be limited and monitored by the Permittee as
specified below; J�LI -
�,. ... y CHARACTERISTIC , -� :r-,M onth I y 1-gs. ,ai.y �easurement ampe'-Sam „amp e�Location requencY
IN.
Flow peso is uent
otal Suspe-naed Solids 45.0 m Monthly Ettluent
Oil and Grease2 Monthly ra vent
ur i ity Quarterly ra uent
Benzene Monthly Urab Ettluent
o uene Monthly ra cent
Et5yl Benzene Monthly ra uent
y ene Monthly ra uent
Method .. Semi-annually Ci ab Effluent
Monthly raEffluent
Acute Toxic] nnua y ra went
Footnotes:
1. Flow— During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow should be monitored with each discharge event in one of
four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude built-upon
area(best method for facilities with large runoff-collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease -- Where possible, the grab sample for oil and grease should be skimmed from the
surface of a quiescent(calm water) zone.
3. 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.
4. Acute Toxicity (Fathead Minnow, 24-hour),Annual [see Special Condition A.(2.)].
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 71.4 µg/I and toluene concentration is less than 11 µg/1.
Permit NC0005771
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
EPA1600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas)
24-hour static test. Effluent samples for self-monitoring purposes must be obtained below all waste
treatment. The permittee will conduct one test annually, with the annual period beginning in January of
the calendar year of the effective date of the permit. The annual 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.
- rrV rwt VY YUHaIG HFJ.ft'Na('�!f'P ' -
TEE
p/1 p i.r THE 14ORTHCAROLINAENVIRONMEMTALLUNACEmEN7CommissiON.
t
+ 1 Y .a (� ,. SkJBJECT A PuhGc healing has teen srrietluled tanceming Die proposed renewal and Issuetice of
the fdlass?rS NPdE5 Aertruts "'y✓-j`�+f 1'sse, r
-;°Perm4 rairnbu+NC0o21962 to Cl Petroleum Gorpon,.1_ioit f�See Pa Creek Temmnal located in
E_harlofle,N.C. Chartofte(Maddenburg County(for the.discharge of slmmvrater i.po afi unnamed tnhutafy.to Gum
Branch - :,4'+ .t 4t4 i���'�� -.
AFF FM41'Ir OF PURLICAI •;,-Pemvl nurttbei NCOOZ?187 to moGv Enterprise for the Paw_Ueek TI nAnat located in Chaddtfe'
NORTH C.tltnt-fNA {Mecklenburg Cr>unty]for�fhe tl;+barge al slalnwajeyrp antl+erne rd groundwater n16 an unruiried
tributary+.to Gum Branch:": xr i, ,1` Y a;yxr3 s- 4 .c
MECIiLE.Td871RU CUIfNTY `'5 Pemiit mimber NCOo32091 to Ptilips Pgre L1rie Comparry fd.tlx Charbtle 7errir�nal loafed in
tkfnra�e nrrdenigned..Notary l"='
Charlotte(PAce4enburg County]for flte discharge of stdnrnrater info an unnamed tnoutary to Gum
North Caanler.,duly commiasranu)T,. s - r_. s��r f t },=7 r.-Y•t a i
l.w io.deninuter o.th.,penan.Uy F.6ran[h
-Penn[number NCoo747O510 Will am Terminals Hdtlings'L P kx Me Charlolte15ouMem Facratles'
Shelby J. Curtuo Te_rtninal lbC*i;d in[barque jivlq lerthurg Corr)lice the tli_sdiarye of slbmnvater Int0 an_unn5rried
"1916 tibe,4,leiilmN7Th�9,.aer [nbufary.lo Paw Creek-,sr_ -' + +'�l L; r - -%'"t-rrr�f' r .-
en+neA>R..+cend.dr.er.ulia,k.[ryy�( p t -.inter NCtl004723(o Valero NRarkesrxj d Supply Carrpiny Idr Vie Valero ktarfie8ng 8
and stssr tlrdha'.he icauihoriredt•SuippFy Faoliry k7mled IriCharloll_e.(Medcten6ury Caunry)1v the ducharpe'bl starnrwater into an
et.rameatr Ow ib.entice or other h Wlnametl tr cIulary to Paw Creek
NOT-ICE OF PUBLIC Pemu>_number NC O995ML6Transiul6nteighe7einanaling4nc.Im the ChadDtINPaw Creek Terml=t
{{naf#1 loCated�iri Charlotte{Mecklenburg Cauntyj fan the dsdraryr of stamwater into ari unnamW l
TO BE HELD BY TH8`tnbutary,lo Paw Creelc1r•iY�"r t4 �, '�- t'4
ENTIRON41ENTAL MANE e Tennnafnq inc Yo[theChartotlrJPawCreekTemti-
na}#2-ictdled in pi_rIi(MOCklenbrirg County]for the Qstharpe d storm+valer into an unnamed
tnbuta i,to Paw Creek.6, f. 4 gY "siy' 'i` 5 __i"l�y •.,6 a._
a'�Pemalnuirrber NCtlo31 g38 to Cdonial Pied ne cdrripar,y fp Cie Chanoito Oekvery Faolryloralotl
.treccopy afwhrh e.tlached hues�,n Chariohe.(Metitlenhurg Cowdyj far IG+e disrl�argrp of stenhwater rim ar]_unnamed tributary to Gum
.leotva6'Hp>) onthe Collowm6 da5gmn * 4, y,a 7 ';'} ,-K.,k '9 i_
March 16, 2001 + -Aermd number NCOO4fi2t3lo MaratlionA;hlarid Petroeum,LLGfor Ale Marathons AshtanSt Petra
leum fadliiy 1'dated in CharWne(NAecklenburg County]for Vre,disciiarge of 3,iri yatei.i;ttd art gun,
ud7R+r tibo..idnewcP.Per in whick named SridtSary WLong Creek '; t �' ,ts+? Y� 'x.Nr.. '.;•:rYF� Y31,' �=. i
.m Segal..dverwemem waa publirh+ =, Pemw[t,ur*ber NC0o4653i Iq Crvwn Central Yebdeum Corrrpawyfor the Paw Creek Terminal,
every nrdhpuhiic,fioq a ncinp+per i located in Paw Leek(MeIdslenburg CaunlyF ton woo of ststpnnlvateri4l4_an unna_med Iribulary
.ndyu.litAWion.aCSrctim1597 r�td Gum Branr7i' t ":]'at':✓ ,t�. £a t r.3�x a
Cuoliiu r.idwu aqu.lified aew.p.rr'r, Permit nuRtbei NC9046892 to Motiya Enliii4in a LLC for,die aarbtla T¢rminal locatetl In Paw
iioa 1.5917 afdw Ocne..N Staeirte.•lb,epk(Mecklershuro County)forrlhe'disctrarge:01 stormwater and m I'lled'grWntivr2te'r to an. '
'unnamed t{ihuiary O Lon9 meek -+` -s .t -
Thu 16th dayaf M.1.3 - '-i.` '' r v rr � « -
.F perm t mirnbw NC0o67fi391p Exxonktobrl permrtg 8 SupplyCarnpany for the Clrarletfu�Temvnal
(Signed) '�� J Cif In Glsarloile(Mecklenburg Cainty)for the discharge of alor.taw�ter and rt:med+atetl groundva-
/y ,term an unnamed lnbutary-to Long Creek.-;I3� -
Sworn wand euhacribed 6/fo a i i Permit numberNCbOO5185 in WiNiams Ter natsHoldings'L.P.,Ior fha Paw Creek Terminal located ,
-!n Paw Creek lNArrdlenburg County]for the dadrarge of slormwghr to ars unhamed fAbulary`to Loop
16Lh d.ynf March 20t Creek,y �; 7;c-! tYrat
PURPOSE.Eaa.01 These fauYbes has applied foi renewal al lhQ NPOES pemdi for scharge
�`W trpaled StOnnwatdr andior nemedalM gnotuWrater intotvatar}ci Vte Catawba River basin On the t
bans of pr¢I rnlrmry s1aH review and appliratlon of ArtrV6e 21 of f�taupeor143,General StaWteS of Fbrttr;
Notary Public,�rdina arid'ofher 7awful;•stantlards'and regulabdns;_ihe Ndtlt-Ciofma EnVlrprment A7,anagernenl
My�mrs.im fixpire.: 7I7 Commission proposes b rsssue a NPOES ltarmrf Ion crdr fJgNly subted spe[ific 5*i4gl Nm tat T
-and;pedal coridi ions.7124 Oirecldr Of the Divis+ori of[Aloes+Quality parrsuynt 1a NCGS i4}215-1(03)
arttl Regeilatiart515NCAC2H Sec3an.OlOOtus Aele+itdne4 thatttls.l the publietrrferesl thalamee0rq .. '
he lC to nvicerlre all ptYbllpnt pubYc mrniltent en wFrethar Id tssde y7io0rfYRor deny the pemut P '-
PROCEOVRE The lreanrip will be rnMuctud in Cxpl p thefo_R wvrQmrarner d 1 .x�.
:= 15 llie'.Oivisron of Walex OuaNry wIH resent an Jn�ildq bill
Bte NOAti',Carofina Environment
Management Commrssion�pentattrq piowtlula .
'i appkr�nt may ma a an e.plariahon pF the actan fu riAica eadi pEr>,riil is rcquEretl_' -
_-. 3 PrthYC Corrmenl'Cdrrniahls stalanen�dap and outer lnfamglror]riiay be stibnxtted in wntri+g..,. - '
1pno,to or diii.ig the meeting or presented oraly at the mee6yYPefsOr s desiring 10 speak drill
indicate lhsinteiit at the timedregisliation atlherttaeirig SO giaRp�spyf tleynng to speak maydo -
.. .,.sa°lengthy statements+lord be Ilmi[e6 at ttio drsrietim of Ne�f+l'ec4wg o18ZerOra!Pr�dnlations Ihatt - - .
- ,exr�ed dxae inutos Should be arwmpa i d by tfireq wbhm rSbpiQ,wfsr]i will be filed%;61h Division-
..- �slaff at 1ti .pine of registahon r ,�' �'�•�'t ' '�' �s+�"�*t%. -.`�,'t
-«<a Crass ezarr>♦riauonof persons lxrsenbng tesiNrnriy Y not On allowed:tivwe4er tl1e hearing
PffiCer nay ask piestlont�for tlaPfiraLon ii-+'�`� -� c) � ¢-� f 4-r . .
' The heaiing record.may ire dosed at the coritdrislort of the me " as t yam• .A'
' _WHEN Apnt19"at700 rtt i-s 4 1�,A xp -
WHIFIRE Chadibtlie icFenburgGovemment Center -y, .•S, a�rxra '
GOD East FP rrtt Stree6 CH to W,1%
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"RINFORhL4TiON Ampy of tlteoraflNPtiES Pomtlsl amapsM jhe brab6n of the dst3iarge($)
'area adaWe�hy wdbng ar-calking :
$,lyiMs�Chnsseuadc son� i , 3i F� --j a'<,Si
yt•;.tNC Division tlWater qua6tyMPAE$UnN _ 434
,y�Bale gh-Norfh Card na 27699.1 fii7 R� P � �i 3'z•t'° r s -
ati Telephone number (919)733.5M.exlensiCn 53�'C�'rlf s 3 krti wz
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.Y e aPpl,rahans andoSherinfattlatlrnarC an flleal the➢ivesWn of.Water Ouabry.512 Nvlih Safistiury
SVeol Room 925_of Bie'Archtlale Bwfck rl Role gh;fi0rtti Caioli, and etOms+on's Mooresville
,Reg anal O(fce(919 North Ma n Strael in Mooresv Ile,NCl.They may_"inspected during ri0fnial office '
.hours Copies oftthe in1'Qnnabars on:file are availatfe trpori requestl+and,payment o1'IhC casts;:of
-ieproduCaon_'q,t such comments.and requests-reijarWng M"inaha should make reference to the
.Perm!numlier(sl kste0 abovepi's?Er
DIVISION OF WATER QUALITY
April 5, 2001
MEMORANDUM
_U
TO: «- Dave Goodrich
am
w�
FROM: D. Rex Gleason
PREPARED BY: Richard BridgemUJ
an Q a
SUBJECT: Draft Permits for Paw Creek Facilities — ~�-
Following is a discussion of the draft permits:
It is recommended that the effluent sample location 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 Ieast 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-.- 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 I, Section A(l). An example of the
writer's preference is in the permit for Motiva Enterprises, LLC (NC0046892).
' Dave Good_rich; =
Page Two
April 5, 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. FIow 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 I, 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-, _
- - 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 letter, the water quality standard for phenol is indicated to be 1
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 7Q10, 30Q2, and average stream flow of zero, and the sixth
facility discharges to a stream having a 7Q 10 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?-
- Williams Energy Ventures (NC0005185) —Permit Cover Sheet indicates that discharge is
to a UT to Gum Branch; as correctly identified on the Supplement Sheet, it is a UT to--
Long 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
9 V'7G it
Ie
: RECEIVED ...
o • � s WATFP N rm trYppr rrON
4
}b. CA�� APR � U ?� a
MECKLENBURG COUNTY
Department of Environmental Protection NOr1"0i$dMroe PeWtung
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:
Genera!
• 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 T---
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 Srreet • Suire 205 • Charlotte, NC 28202-2236 • (104) 336-5500 • Fax (704) 336-4391
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 # NCO074705
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 Ref ning and Supply Company- Permit # NC0004839
Outfall 001-
The daily maximum permit limit for benzene is listed as 1.2ug/l. The North Carolina
water quality standard for WS-IV waters is 1.19,ug/l.
• Marathon Ashland Petroleum, LLC- Permit # NC0046.213
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 71.4µgll and
toluene concentration is less than 11µg/i." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19kig/l.
• Colonial Pipeline Company - Permit # NC0031038
MCDEPs past inspections of this facility indicate that the retention pond located on-site_
receives flow from three intermittent streariis. While the streams are cIassifled 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 (NC004653 I) flow to Colonials' retention pond before
entering the receiving stream. Since these conditions exists prior to the outfaIl 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,
RTz?,-
I
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP
Sent By: ; 919 821 0337; May-2-01 16:32; Page 213
-- - 11TOR'1`I- _CAROLINA
PE'MOLEUM
COUNCIL
A r WUlon of the Amman Pptr�Inst
WILLI M I1.WCA111GRSPOON Burr£2850 a 150 FAME=ViLIE-Sr. MALL
RALE10H.IVC 27601
Dia/sus-Sd38 FAStS11eJR2I�337
May 2, 2001
Mr.Rick Shiver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Ext.
Wilmington, NC; 28405-3845
Re: NPDES Pcrrnit Renewals
Paw Creek Petroleum Pipeline and Distribution Terminals
Charlotte(Mecklenburg County), North Carolina
Dear Mr. Shiver: .
Thank you for.the professional mariner in which the public bearing on the petroleum terminals'
NPDES permits was Conducted in Charlotte on April 19, 2001.
The purpose of this letter—which I 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 oFthe 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-making.
So we simultaneously praise the process that allows us to submit this statement for the record,
while we point with alarm to the proposed MTBE limit of 11.6 ug/L that has been included in the
- - draft permits without a single hearing or any official review by a ruletnaking 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
proposed 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 a temporary groundwater standard of 70 ppb, but also to reaffirm the value of
public hearings by calling for a permanent ruiemaking process to tighten the MTBE groundwater
mod. Spa V'a WCO s,Lt avtait A w VIQWEi,*ino—ts our dotet proposal,we are now confronted with
Sent 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 mid at
worst a circumvention of the EMC.
It is my understanding thnt 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 wldhin the
Department who sounded the alarm so vigorously in statements to the EMC In support of an
MTRE., groundwater standard of 70 ppb have now changed their minds! What Eaa.d been a
certainty one month was abandoned the next in favor of a new calculation--and a new limit
level. So, if public health considerations are truly moving this fast, if numbers are hastily
abandoned and recalculated, if the science is in such a state of flux,then our commitment to
neasozied public input is all the more appropriate and needed to insure that the calculations of
today are not abandoned tomorrow.
Recommendations
The Council's member;accept that an MTBE limit that has been peer-reviewed and duly
considered via the ruiemaking process may be appropriate for inclusion in the terminals'NPDES
permits. Lacking that, however,the Council believes the M ME 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 scum-annual manij9rinZ by
each of the terminals will provide the needed represcntative data to form the basis for future
decision-making.
Sincerely,
i
William H. Weatherspooa
-- _ WHW/jm - - -- -_-_- - - -- -- - -
c: Ms. Natalie Sierra
f'
SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM-RELATED CONTAMINANTS , .
C" &"B"WATERS
(ugll unless noted 11WS-111 -I�WS-V,l WATERS (ugll unless SOURCE OF STANDARD ,
CONTAMINANT CAS# otherwise) WATERS noted otherwise) OR CRITERIA
BENZENE 7143-2 71.4 1.19 71.4 15A NCAC 2B .0211-.0222
n-BUTYL BENZENE l 104-51-8 36 36 36 ECOTOX 4198
sec-BUTYL BENZENE 1 135-98-8 41 41 41 ECOTOX 4198
CHLOROFORM 167-66-3 470 5.7 470 EPA 4/22/99
ETHYL BENZENE 1 100-41-4 383 524 130 ECOTOX 1101
IPE 108-20-3 19 mg/L 19 330 mg11 ECOTOX 1101
ISOPROPYL BENZENE 98-82-8 316 186 4.6 mgll ECOTOX 1101
p-ISOPROPYL BENZENE 99-87-6 325 325' 1.1 mgll ECOTOX
METHYLENE CHLORIDE 75-09-2 1600 4.7 1600 EPA 4/22199
MTBE 1634-04-4 2393 11.6 2393 NC DHHS 7/11/00
NAPHTHALENE 91-20-3 105 43' 64 ECOTOX 1101
n-PROPYL BENZENE .103-65-1 77.5 77.5 190 ECOTOX 1101
1,2,4-TRIMETHYLBENZENE 95-63-6 386 72 218 ECOTOX 1101
1,3,5-TRIMETHYLBENZENE f 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 8199(SW)'
t
XYLENE, TOTAL 1330-20-7 88.5 88.5 370 ECOTOX 1101
t
Criteria which have a source of EPA ECOTOX were developed using EPA's ECOTOX database per 15A NCAC 2B .0208.
Last update 212101 (DMR) These concentrations are updated regularly.
Questions or criteria for other parameters not found in the 15A NCAC 213 .0200s can be addressed to Dianne Reid at
919.733.5083 extension 568 (Dianne.Reid@ncmail.net) OR Jason Wynn ext. 351 (Jason.Wynn@ncmail.net) ;
k
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.
L 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:
➢ the runoff coefficient which accounts for infiltration and other potential losses in the region,
➢ the rainfall intensity to the region,
➢ the time it takes for runoff to travel from the region's upper reaches to its outlet, and
➢ the region's drainage area.
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 7130/01
Permit Requirements for Discharges from Oil &'Petroleum Storage Facilities
B. Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual
-� Monitor. annually (assuming first_ five discrete storm events have already been monitored and
- showed rio 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
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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).
1. 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
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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
- TII.C�) •
11. Additional Site-Specific Requirements
A. EPA Method 624
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
PARAPdETER DETECTED IN OEL TERMEDIAL STORMWATER?
Acrolein
Ncrylonitrile
Benzene ✓
Bromod ichlorome th an e
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chlorocthane ✓
Dibromochloromethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
I,1-Dichloroethane
trans-l,2-Dichloroe then e
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
Tctrachloroethene
Toluene - - ---
1,1,1-Trichloroethene
1,1,2-Trichloroethene
Trichloroethane
Trichlorofluoromethane ✓
Vinyl chloride ✓
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
Table 2. Compounds detectable by EPA Method 625
DETECTED IN .1
Acena hthene
Acena hth lene
Anthracene
Benzo a anthracene
Benzo b fluoranthene
Benzo k fluoranthene
Benzo a rene
Benzo(ghi)perylene
Benzyl butyl phthalate
Bis 2-chloroeth 1 ether
Bis 2-chloroetho methane
Bis 2-eth the 1 hthalate
Bis 2-chloroiso ro l 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'-Dichlorobenzidin e
Dicth 1 phthalate
Dimeth ! phthalate
2,4-0initrotoluene
2,6-Dinitrotoluene
Di-n-octylphthalate
Fuuoranthene
Fluorene
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Indeno 1,2,3-cd rene
Iso horone
Naphthalene 1
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 henol
2-Meth 1-4,6-dinitro henol
2-Nitro phenol
4-Nitro phenol
Pentachloro henol
Phenol /
2,4,6-Trichlor0 henol
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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 and 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)
5. 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).
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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 (organoleptic) 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 pirevent a downstream
violation of the NC State standard for phenols of 1 lig/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).
-- - -
Monitor monthly
Daily maximum limit - 1.19 pg/l * dilution of the receiving stream under average now 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 pg/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.
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. MTEE
Monitor monthly
'MTBE'special conditionY Y
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 7/30I01
SOC PRIORITY PROJECT: Yes_ No X
If Yes, SOC No.
To: Permits and Engineering Unit
Water Quality Section .
Attention: Christ' 'L`-}
Date: February 12, 2001
NPDES STAFF REPORT AND RECOMMENDATION
County: Mecklenburg
Permit No. NCO005771
MRO No. 0 1-04
PART I - GENERAL INFORMATION
I. Facility and Address: Transmontaigne Terminaling, Inc.
7615 Old Mount Holly Road
Charlotte, North Carolina 28214
2. Date of Investigation: 02-09-2001
3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. George Lambert, Terminal Manager, tel#
(704) 399-8378.
5. Directions to Site: From the junction of NC Hwy 27 and SR 1691 (Old Mt. Holly Road),
travel east on SR 1691 approximately 0.2 mile. The terminal is located on the right side of
the road.
6. Discharge Point(s). List for all discharge points:
Latitude: 35' 16' 37" Longitude: 80' 56 05"
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on
map.
USGS Quad No.: F 15 SW USGS Name: Mountain Island Lake; NC
7. Site size and expansion are consistent with application?
� � � � � N '
Yes X No_ If No, explain: OFFE9
2 1 2001
8. Topography (relationship to flood plain included): Terraced. The WWT facilities are not
located within the 100 year flood plain.
9. Location of nearest dwelling: The nearest dwelling is located approximately 1000 feet of the
facility.
10. Receiving stream or affected surface waters: Unnamed tributary to Paw Creek
a. Classification: C
b. River Basin and Subbasin No.: Catawba and 03-08-34
C. Describe receiving stream features and pertinent downstream uses: The receiving
stream is a wet weather ditch. General "C" classification uses downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1, a. Volume of wastewater to be permitted: Dependent on rainfall.
b. What is the current permitted capacity of the wastewater treatment facility? N/A .
C. Actual treatment capacity of the current facility (current design capacity)? NIA
d. Date(s) and construction activities allowed by previous Authorizations to
Construct issued in the previous two years: None.
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: The existing treatment consist of an oil/water separator at the
loading/unloading area and two settlings basins in series.
f. Please provide a description of proposed wastewater treatment facilities: NIA.
g. Possible toxic impacts to surface waters. Those typically associated with bulk
storage facilities.
h. Pretreatment Program (POTWs only): N/A.
2. Residuals handling and utilization/disposal scheme: N/A. (No solid waste is generated
from this facility.)
a. If residuals are being land applied, please specify
D WQ: NIA
Page .2
b. Permit No: NIA
C. Residuals stabilization: N/A
D. Landfill: NIA
d. Other disposal/utilization scheme (specify): NIA
3. Treatment plant classification (attach completed rating sheet): No rating at this time.
SIC Code(s): 5171
Primary: 39 Secondary: 73
Main Treatment Unit Code: 53500
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? NIA.
2. Special monitoring or limitations (including toxicity) requests: None.
3. Important SOC, JOC or Compliance Schedule dates: (please indicate) NIA.
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non-discharge
options available. Please provide regional perspective for each option evaluated. NIA.
5. Air Quality and/or Groundwater concerns or hazardous materials utilized at this facility
that may impact water quality, air quality or groundwater? The facility stores a variety of
fuel oil, typically associated with bulk storage facilities, which if spilled could impact
WQ, GW, & AQ.
6. Other Special Items: NIA
Page 3
PART IV - EVALUATION AND RECOMMENDATIONS
The permittee, Transmontaigne Terminaling, Inc., has applied for permit renewal for the
subject facility. No detrimental impact was observed in the receiving stream.
It is recommended that the NPDES Permit be renewed as requested.
Z6�',
Signature of Repo reparer
Water Quality4kegional Supervisor
2-- U
Date
Page 4
DENR/DW Q
FACT.SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No.NCO005771
aci i -Information . -
pp ican -act tty., ame: —1 ransmontaigne ermma ing Inc./Paw Creek
Applicant ress: S. Barbara Castleberry; 200 MansellCourt, Suite ; Roswe ,
act ity. ress ount Flolly Road; Charlotte, 78214
ermitte - . ow is not smite
11 ype of rite: tormwater, loading rack water
act tty ermit: tatus: Active; Renewal
County: . Mecklenburcy
. - Miscellaneous -
ecewmg' tream: Ul to - :aw Creek- egiona ; ice:- Mooresville
. Stream.Classification: State:Grid '. , ua :7- F15SW
3 iste No ermtt rrter ata to Sierra
gate.-
-Drainage"Area nit: 11 's 0.01
ummer c s
triter c s :
<� rr. '
0 0
Lat. 350 16' 37"N Long. 90'56'06"W
BACKGROUND
This agility is one of two in the Paw Creek area owned by Transmontaigne Terminaling, Inc.
The facility was purchased from'Amerada Hess in July 1999. Effluent water discharged from the
outfall consists of runoff from the loading rack and stormwater from the secondary containment areas
(around the individual tanks). Loading rack water is run through grit screens and an oil water
separator. This water then flows into two retention ponds (where it combines with stormwater) and is
released from the second retention pond manually as needed.
FILE REVIEW
Correspondence
The Mecklenburg County Department of Environmental Protection (MCDEP) has performed five
inspections (one per year) within this permitting cycle. The facility has always been in compliance during these
inspections. Upon two occasions when effluent water was released in the presence of an inspector, it was
described as clear and having no visible impact downstream. Grab samples taken during these inspections
indicate low levels of total suspended solids (TSS) and non-detects for oil and grease as well as the volatiles and
semi-volatiles detectable by the EPA 624/625 scan-
Under the previous owner, Amerada Hess, the facility received only one NOV, for non-payment of fees.
This NOV was issued in 1999,just prior to the ownership change.
DMR Review:
DMRs were reviewed from September 1996 through January 2001. Discharges from 001 are sporadic
in nature; for those months in which flow was recorded, the mean flow was 0.186 MGD. The maximum flow
(used below in the reasonable potential calculations) was 0.36 MGD. Total suspended solids during this time
averaged 14.9 mg/L with a maximum of 40 mg/L. There were only two oil and grease detects, 21 mg/L and 6.5
ma/L, the remainder were below the detection level of 5 mg/L.
The twice annual EPA 624/625 scan revealed non-detects for all the semi-volatiles and volatiles tested.
The facility is currently required to test monthly for benzene and xylene— for the entire permitting cycle, there
was only one benzene detect (7.4 ug/L). The facility has passed its acute toxicity test since 1996.
Reasonable Potential Analysis:
Reasonable Potential Analysis was run for benzene and xylene. Since there were no xylene detects,
there was no reasonable potential for xylene contamination from this effluent. The analysis predicted a
Fact Sheet
NPDES NC0005771
Renewal
Page 1
maximum benzene concentration of 11,2 }tg/L, well below the allowable concentration of 71.4 for class C
waters.
PERMITTING STRATEGY
T e permitting strategy or this and all oil terminals in the state is based upon a 2001 NPDES document
entitled, "Permit Requirements for Discharges from Oil and Petroleum Storage Facilities." This document is
based upon a 1996 SOP and has been updated after a data review and internal discussions. It delineates
monitoring frequencies and permitting limits for contaminants commonly found at these sites. Below, it is
referred to as the "2001 SOP,"
Waste Load Allocation (WLA).
The last waste load allocation was performed in 1993. This WLA establishes the storage capacity of the
facility as above 1 MGD.
Oil Terminal SOP:
The flow, toxicity, TSS, and oil and grease requirements specified in the previous permit and the 2001
SOP (Parts I.A. — I.D.) remain unchanged. The previous permit limited benzene to 71.4 µg/L—the facility has
adequately demonstrated that this parameter is not a cause for concern_ This limit will therefore be removed. In
place of the xylene, benzene and EPA Methods 624/625 monitoring requirements,the facility is now required to
monitor monthly for BTEX, naphthalene and MTBE as per Parts I. E, 11 and 1.1 of the 2001 SOP. As per parts
I.G. and J.H. of the 2001 SOP, there can be no direct discharge of tanks solids, tank bottom water or the rag
layer, and no direct discharge of hydrostatic test water if concentrations of benzene and/or toluene exceed the
water quality standard. Part II.C. lists a requirement specific to the Paw Creek terminals— quarterly turbidity
monitoring as mandated by the EPA.
SUMMARY OF PROPOSED CHANGES
• Removal of benzene limit
• Incorporation of benzene and xylene monitoring into monthly BTEX monitoring
Removal of EPA Methods 624/625 monitoring requirement
Addition of naphthalene monitoring
• Addition of MTBE monitoring
• Addition of quarterly turbidity monitoring
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: March 14, 2001
Permit Scheduled to Issue: April 27, 2001
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact Natalie
Sierra at (919) 733-5083 ext. 551.
NAME: DATE:
REGIONAL OFFICE COMMENTS n
Af—
V/
M AY - 2 2001 ! Z,1"
DENR - WATER `,JALIlY
POINT SOURCE bRANCH
NAME: —�� � DATE: S 6,
Fact Sheet
NPDES NC0005771
Renewal
Page 2
REASONABLE POTENTIAL ANALYSIS
Prepared by: Natalie Sierra, 2/28/01
Facility Name = Transmontaigne, Paw Creek#1
NPDES# = NC0005771
Qw(MGD) = 0.36 max flow
Qw(cfs) = 0.556992
7Q10s (cfs)= 0
lWC (%) = 100.00
Chronic CCC w/s7Q10 dil. Frequency of Detection
Parameter FINAL RESULTS, ugtl #Samples # Detects
Xylene
Max. Pred Cw 17.2
Allowable Cw 88.5 23 0
Benzene
Max. Pred Cw 11.2
Allowable Cw 71.4 42 0
no E:PA c':;'ZA bZG 19q l�-Zcco
Parameter= Xylene Parameter= Benzene
Standard= I 88.5 pgtl Standard= 71.4 pgll
Dataset= Dataset= DMR99
Modified Data Nondetects RESULTS Modified Data Nondetects RESULTS
10 <20.0 Std Dev. 2.480 2.5 <5.0 Std Dev. 0.985
7.5 <15.0 Mean 6.087 2.5 <5.0 Mean 2.426
7.5 <15.0 C.V. 0.407 2.5 <5.0 C.V. 0.406
7.5 <15.0 Sample# 23.000 2.5 <5.0 Sample# 42.000
7.5 <15.0 2.5 <5.0
7.5 <15.0 Mutt Factor= 1.720 0.5 <1.0 Mutt Factor= 1.510
7.5 <15 Max.Value 10.000 pgll 2.5 <5.0 Max.Value 7.400 pgll
7.5 <15 Max. Pred Cw 17.200 pgll 2.5 <5 Max. Pred Cw 11.174 pgll
7.5 <15 Allowable Cw 88.500 pgll 2.5 <5.0 Allowable Cw 71.400 pgll
7.5 <15 0.5 <1.0
7.5 <15 0.5 <1.0
7.5 <15 2.5 <5
7.5 <15 2.5 <5
7.5 <15 2.5 <5
7.5 <15 2.5 <5
2.5 <5 2.5 <5
7.5 <15 2.5 <5
2.5 <5 2.5 <5
2.5 <5 2.5 <5
2.5 <5 2.5 <5
2.5 <5 2.5 <5
2.5 <5 2.5 <5
2.5 <5 2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
0.5 <1.0
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
7.4 7.4
2.5 <5.0
2.5 <5.0
sample# nondetects detects sample# nondetects detects
23 23 0 42 42 0
Whole Effluent Toxicity Testing Self-Monitoring Summary February 16,2001
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Alcoa-011 Pcrm 24hr LC50 ac monh pis Bhd(grab) 1997 •— »- >10G(s) — — — -- — -- -- --
NCOIX)43WV011 Bcgin;l2/111995 I're(4ucncy:5OWD7A NonComp: 1996 — — — >100Is) — -- — -- — — — —
County:Stardy Region:MRO Subbasin:YAM8 190 — — — >t001s) — — — -- — — — —
PF: VAR special 2000 — — >1o01a1 — — -- —• — — — — —
7QI0:NA 1WC(%):NA Order: 2001
Alcoa•012 Penn chr lim:16-,. 1997 — — Pena — — Pass(s) — — Pass — -- Peseta)
NCIA)WAW012 Begiml2l111995 Frequency:Q P1F + Mar Jun Sep Dec NonComp:Single 1998 -- --- Pam(s) -- -» Pass(s) Pass(a) — --- Pass($)
County:Study Region:MRO Subbasin:YAWS 1999 -- — Pawls) — — Pass — -- Fad >24 >24 Pass
PF.NA sprei.l 20DO — —. Pass(.) —. — Pass(.) — -- Prim(s) — — PIndia)
7Q10',NA IWC(%):NA order. 2001
Alcoa 013 Perm 24hr ac p7f Iim:9u%hhd 1997 — — Pasts) — -- Paurs) — -- Pm(s) -- — Pa.(.)
NC00043OW 13 Ilcgin:1 211 11 99 5 Frequency:Q P1F + Mar Jun Sep Dec NonCumprsingle 199e — --- Pasts) -- — pass(s) -- — par-(.) — — Pawls)
Counly;Stanly Region:MRO Suh6asin:YAD08 1999 — — Paui(s) — — Nma .) —. — Pas.(.) — — fit
rF: NA Special 2000 — — Pass(s) — -- Pass(s) --- --- Pm(s) -- — Pass(s)
7QIU:NA IWC(%):NA Order: DO
Amerada Hess Corp. Penn 24hr LC50 ac monit epis(lhd(grab) 1997 — -- — »- -- >100 -- -- --- —
NCW(j671l0)I ISegin:Nif1996 Frequcicy:A NonComp: 190 — >100 — -- -- — —• —• — — -- —
County;New Hari—er Region:WIRO Subba_sin;CPF17 190 — >1D0 — — -- >700 -- -- -- — —
PF: Special 2000 _- >100 — — -- — -- — -- — — --
7Q10:NA IWC(%)',NA Order. 2001
'Amerada Iles Corp1Paw Cr Terminal Perm 24hr LC50 ac monht epis(lhd(grab) 1997 --- >100 — »- »- »• -» —• -- ---
NC000577110U1 Regin:91111996— .4cricy:A NonComp: 1999 >100 — -- -- _- — — --- —
Counly:Mecklenburg Region-MRO Subhasim:CTB34 t999 — >100 -- — — — — — — — — —
PF;VARMS special 2000 — — -- Wo -- — — — — — — —
7Q10:0.0 1 WC(%):I00 Order: 2001
Amerada lless-Greensboro Termlaal Perm 24hr LC50 ac monh epis Rhd(Grab) 1997 at --- --- -- -- -- »- >100 -» »• -» --
NCW692561UU1 Begin:61171996 Frequenry:A NonComp: 1998 >100 — -- -- — -- -- — — — — ---
County:Guilford Rcgion:WSRO Subbasin:CPF08 1999 >IGO -- -- -- — -- — — — — — —
PF:NA sp"I 2000 — >100 —• — — — — — — — — —
7Q10:0.0 IWC(%);NA Orden 2130t
Amcrlcan'fructrschlcr,Inc. Perm chr lim:90%(grab) 1997 N N N Fad,Fail Pass -- -- Pass — Pass —
NC008592117UU1 Begin:11111997 Frequency:Q P!F + Feb May Aug Nov Noncomp:Single 1998 — Fail,Pass — -- Pass -- -- Pass --- — Fail Pass
County:Mecklenburg Region:MRO Subbasin:CTB34 1999 — Pass --- --- Let. Pass — Paso -» Paso Fail
PF:0.05 special 2000 <45,75.5t Fail Nit(a) H --- -- H H — — H --
70I0:LIM IWC(%):IW Order: 2001
Amnrn Oil Co, Perm 24hr LC50 ac monic epis tthd(Grab) 1997 .100 — —• -- -- — — — — — — —
NCUUU36717Wf Begin:61111996 Frequency:A NonComp: 1998 >100 -- -- -- — -- — — — — — —
County:Guilford Region:WSRO Subbasin:CPF02 1999 -- 53,76 --- _- — — -- -- -- ---
PF:NA Spwisl 2000 >100 -- — — — — — — — — — —
7Q10:0.0 IWC(1/.):1(0 Order: 2D01
Andre-s WWIT Perm chr lim:13% Y 1997 — -- Pass -- -- Pass — -- Peso — — Pass
NCU02080011101 Begin:31111998 Frequency:Q NF + Mar Jun Sep Dec + NanComp:Single 1998 -- -- Pass -- — Pass — --- Pam. — — Pass
County.Cherokee Region:ARO Subbasin:H1W02 1999 -- -- Pass -- --- Pass -- — Fail >26 t6.1 Pass
PF; 1.5 Specal 2000 -- -- Pass -- — Pass — — Fall 11.4 18.4 fall
7Q10:15.0 IWC(%):t3,0 Order: 2001
AnSoa Cu,\Y\',-I'P Perm chr lim:3% 1997 Pass -- -- Pass -- -- Pam — — Pass — --
NCW41408M) 13cgin:411/1999 Frequency:Q NF + Jan Apr Jul Oct + N-Comp:Single 1908 L.I. Pass »- Pasa — — Pass — — Pass -- --
County:Anson Region:FRO Subbasin:YAD16 1999 Pass -- — Pass --- — Pass -- — Pass _ --
PF:3.5 SI-W 2000 I-Ma Pass — Pass — — Paso --
7QIU:175.5 IWC(G):299 Order. 2001
Apex Oil Cumpaay PERM:24HR LC50 AC MONIT i:PIS FIND(GRAB) 1997 -- -- -- — -- — — —
NCW714637Wt 1jegin:9y1119W4 Frequency:SOWDIA NonComp: 1995 -- — — — — >100 >100,>100t >100 -- — — --
County:Guilford Region:WSRO Subbasin:CPF02 1699 -- »- -- — -- >IOU — --- -- — -- ---
PF: NA W'ial 20W — — — — >100 — — — — — --- _.
7QIU:0.0 IWC(%):100 0rdcr. 2001
Y Pre I997 Dada Available
LEGEND:
PERM r Permit Requirernenl LET=Adminislrative Letter-Target Frequency.Monitoring frequency:Q-Quarterly;M•Monthly;IIM-Bununthly;SA-Semiannually;A-Annually;OWD•Only when discharging;D-Discoutinued monitoring requiremrnt
Begin-First month required 7QIU—Receiving sire=low flow criterion(efs) +-quarterly monitoring increases to monthly upon failure or NR Months that testing must occur-ex.Jan,Apr,Jul,Oct NonComp=Current Compliance Requirement
PF=Permitted Row(hSGD) IWC/-Instream waste concentration PIF-PasslFail lest AC=Acute CHR=Chronic
Data Notation:f•Fathead Minnow;.-Ceriodaphnia sp.;my-Mysid shrimp,ChV-Chronic value;P-Moriility of staled percentage at highest concentration;at-Performed by DWQ Aquatic Tax Unit;bl-Bad test
Reporting Notation:•---Data not required;NR-Not reported Facilily Activity Status;I-Inactive,N-Newly Issued(To comtruct);H-Active hul not discharging;t-More data available for month in question;A -ORC signature needed
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ThANSMONTAIGNE
TERMINALING INC.
Certified Mail Return Receipt Requested
7099 3400 0010 6086 0887
December 7, 2000
Mr. Charles Weaver
NC Department of Environment and Natural Resources
Division of Water Quality/NPDES Unit
1617 Mail SenTice Center
Raleigh, NC 27699-1617
TransMontaigne Terminaling Inc.—Paw Creek Terminal
7615 Old Mount Holly Road
Charlotte (Mecklenburg County)
NPDES Permit Number NCO005771
Renewal Application — Short Form C
Dear Mr. Weaver;
Enclosed are three (3) copies of Short Form C for renewal of the referenced NPDES
permit.
Should you have any questions, please call me at 770/518-3671.
V ry truly yours,Ogji-'dd
CAACCU ( DE
Cz t ��Barbara Castleberry w4,TE� QL,ALrTYEnvironmental Coordinator URCE Pr ArtrH _ f
Enclosure
Copy: GeorgeLambert, w/attachment
200 Mansell Court Phone: (770) 518-3500
Suite 600 Fax: (770) 518-3567
Roswell, GA 30076-4853
TRANSMONTAIGNE
TERMINALING INC.
Certified Mail Return Receipt Requested
7099 3400 0010 6086 1587
January 10, 2001
Ms. Christie R. Jackson
NC Dept. of Environment and Natural Resources
NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
TransMontaigne Terminating Inc.
Paw Creep Terminal
Sludge Management Plan
NPDES Permit Renewal Application --NC0005771
Dear Ms. Jackson:
In response to your December 27, 2000, letter requesting a sludge management plan, the
following describes sludge handling and disposal for the referenced facility.
Any sludge generated from tank cleaning activities and oil/water separator cleaning
activities is pumped directly into a vacuum truck and hauled offsite by an authorized
hauler to a recycling facility. The facility processes the sludge and recovers any
hydrocarbons that might be present in the sludge. No sludge is stored onsite at the
facility.
Should you have any questions, please call me at 770/518-3671.
Ve truly yours,
&Q-& - - Z.
Barbara Castleberry
Environmental Coordinator
200 Mansell Court Phone: (770)518-3500
Suite 600 Fax: (770) 518-3567
Roswell, GA 30076-4853