NC0004723_Permit (Issuance)_20010730

WDES DOCUNEMT SCANNIMO COVER SMEET
NPDES Permit: NC0004723
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Correspondence
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: July 30, 2001
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ca 0� WArF,9 Michael F. Easley
\O`a QGA Governor
CO ©ENR William G. Ross,Jr., Secretary
North Carolina Department of Environment and Natural Resources
D Kerr T. Stevens, Director
Division of Water Quality':'."..' '.
July 30,2001
Mr, Norman Renfro
Valero Marketing&Supply Co.
P.O. Box 500
San Antonio,Texas 78212
Subject: Issuance of NPDES Permit NCO004723
Valero Marketing&Supply Co.
Mecklenburg County
Dear Mr.Renfro:
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 results 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 middIe 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.
The Division believes that monthly monitoring of benzene, toluene,ethylbenzene and xylene (BTEX)is not
excessive. Semi-annual monitoring through EPA Methods 624/625 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 samples at 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. Additionally, all NPDES permits for
oil terminals from this point onward will carry a monitoring requirement for MTBE: Very little data are available on this
contaminant;given that it is a potential public health concern, the Division would like to monitor the concentrations of
MTBE in all such discharges.
The permit for your facility was assigned an oil and grease limit after a statistical analysis of your effluent data was
performed which indicated that effluent from your facility shows reasonable potential to exceed an oil and grease limit of
45 mg/L. As with BTEX,after collecting one year or twelve points of data,you may submit a request to have the limit re-
evaluated.
N.C.Division of Water Quality I 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

As concerns the monitoring requirements for turbidity and total suspended solids,these are a continuation
of monitoring requirements initiated through an administrative letter in 1999. The 1996 review of the oil terminal
permits across the state of North Carolina revealed large variation in the requirements for monitoring of
suspended solids. As a result,the requirement for all of these permits was changed to monthly total suspended
solids monitoring with a TSS limit of 45 mg/L. Following the issuance of the permits in Paw Creels,the
Environmental Protection Agency(EPA) expressed concern regarding anti-backsliding and the removal of the
turbidity monitoring requirement. In February 1999,an administrative letter was mailed to 12 of the 14 Paw Creels
facilities requiring quarterly turbidity monitoring. For the 2001 renewals,these data were used in reasonable
potential calculations. If a facility demonstrated reasonable potential to violate the stream standard of 50 NTU,
then monthly monitoring and a limit of 50 NTU were added to the permit,as in the case of your facility. It is
important to note that the TSS limit is an effluent limit,while turbidity is a stream standard, so they are not
redundant requirements.
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,confomung 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.
Sincerely,
itevenrs
K
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 NC0004723
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,
Valero Marketing & Supply Company
is hereby authorized to discharge wastewater from outfalls located at the
Valero Marketing & Supply Co.
NCSR 1619
Northeast of Paw Creek
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.Tune 30, 2005.
Signed this day July 30, 2001.
Kerr T. irector
Divisi of ater Quali
By Author' of the Environmental Management Commission

Permit NC0004723
= SUPPLEMENT TO PERMIT COVER SHEET
Valero Marketing & Supply Company
is hereby authorized to:
1. continue to operate the existing water pollution control system consisting of:
• two oil/water separators
• a holding tank
• two inline filters
• carbon adsorption
• a polishing pond
located at the Valero Marketing & Supply Co. facility at NCSR 1619 near Charlotte in Mecklenburg
County, and
2. discharge stormwater and loading rack 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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Permit NC0004723
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date o the permit and lasting until expiration, is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
CHARACTERISTIES�„ ont yam.^F0025
ai y easurement r a_mp e p e w cationp
�mum. ,_' ° ` Frequency: TYPt `+�4
Flowl Episodic Effluent
l'otal SuspendedSolids 45.0 m Monthly Grab Effluent
Oil and Grease m Monthly Urab --Effluent
Turbidity Monthly raEffluent
enzene Monthly_ Cirab Effluent
o uene Monthly Urab Effluent
Ethyl enzene Monthly ra vent
y ene Monthly ra went
MTBh Monthly-- raEffluent
EPA Methods 5Semi-anua y Urab uent
Acute Toxicity4 F Xn—nuaily Urab Effluent
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/l and toluene concentration is less than 11 µg/l.

Permit NCO004723
=_ 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/600/4-90/027 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.

u+rr.c qr vuwac 1E�draurc r
� TO BE HIat]BY .t�ty,tf�f.Ch,
�� - THENORTHCAROLIINNAEN,"RONIt WALMANAGMENTCOMiAtS5ION
l ecklenbu `19 if, =_ 4 l;41d _- � rt �r
'I S .�S,y0Aq A plbkt hearlrtg has been soteduled Conte- lfie WnPoaed+er>ewayl and lssuance o1
1 C e FGlar ng NP[LES Pertruls }+kY iS' Y V 3:�t isc"l Z`1.+ S�T
Perm0 number NC002 t9e2 td CITGO Petroleum Guporalron fd 8ie Paw Creek(Terminal loixteilln
FJrorldffe,N.C. C"rlpHe fMerlck sbufp CaunyF fa therd rjp�'W lm�nmate nnarn
err FOciian�ue bi utary.lo�G_um
AFF1D!4l?T0FPUA11CR7 Branches :, FI,; �. �, c +rtaT I16 l hi
,cE•Petrol number NC0022187 to Mapva Enteiprlsrs fa Fhe Paw Citek sTerm!nal lowted ih Charlotte
NORTH�CAROLINA (Mecklenburg Ccunty)for,the disctiarge of stamnvale'vnd rel iaWag,roundwater{ntt an unnamed
Ilitiulary to Gum'Brarteh t..�, 1t x, t rr ,fi.., 't^r¢ ris7:
MECKLENBURG COUNTY v.,, +M k„" c,t .
[tefoee the mdex,Ii N 1'^ =Penrx!number NCD03289t-10 Phlipa Pipe Urte Cwnpany,fos 4he Cnadolle,Terrmnal looted In
North Caroms,duly minus ryu'rh�ette(Mewen4urrtf County)forlthe discharge d-5t4n1rn'ater,fats an vnnamed tnbulary'to Gum
JBfanth y y y r � ,.yYyy'§t+ �tS-'h.�cb'ljb(�[nix
kw to adtrnfnirter osthr,P.—OlY— +,,* .f:' •.!i. .i.r ..}. ;tr,+dGi3l✓i n'!•5...6. }. 4. r�i -
She16y J. Cutntq `-;Pernatnumber NCO074705 to Wrlliairs Terminals HoWugs LP.for the Cl adodelSbuthem Faaliliea
-7erminaf I'ocated n Charldde(Mecklenburg County)for the Gs— I-e of 59elmrater ante an unnamed
THB filedrler+hur6 T01�9,a new tributary W Paw Geek�1'• .•'h 1 -,.�C�,�.f.�tn�,rr'����r,r yy°A:., ; '
sneered eaecand clew mad sn du Cr�e:P rm,l number NCOOOd72]W V lero Mark tirg 8 SanPplYrranPa y ran NetVa1 m Markelliig 6
and S+ar�e.ar helshe is evth rucdt Supply Faukty healed,In Charlotte_(Mectenburg County For Me.discharge d starmwater n!o a
etatcmeatL Y+ar+he nwtics or olhar 1 unnamed d but3ry to Paw Creek r r p--"^� -f
N0T'ICE OF PUBLIC t",; 'r Pemnt nurrrfierNC000577,1 to TransMontaigne TemYnaung Inc tlprfheChadotteJPnwCrick T"i-
rial,rF1 lorafedn Chahntle(Mecklenburg County)Tor:the`aschaigdtot stormwaloF into an.unnamM
TO SE HELD BY THE Sributary�ta +.w+5"u.i n,.l4fy RG�4 �3 e'°-et r rf+7'-nw.ry:2r
ENWIRONMENTAL MNEA Permttnvnib0rNCO021971toTransMoritalgneTcirrunal_ng,fnc�.forllreCharlotlelPawGeekTshnf-
naS'rr2 heated in GharloiSe(Meckler�wg Caunryf lar,the dLsrhar9.of stamivatci into tan unnamed
tributary to l aw,Creek f ':;�ry j_ 4 �' r s-s:r• .
^ �;Perrot number NC0031038 W Colonial Pipekne Company for the Charbtte Delivery Fap4ty forested'
.Wecgry ofwhuh a anachcd hud�lri Chadohe(Meeklenburp CamtyJ for ttto disdnarge d`s[arrnratar No an unnamed Inbulary to Glim
aeraanr'�u�soadefduawm:a,'Brdeeh »,7ar , ':1�,_. xFR-X y . �gy �sraFx, 'F 1-
March 15, 2001 d PermitnvmtierNCO0n6273toMaraltwnAshlandPebdeum'LCCfdmeMarathoiAshl6rip etro-
leuin Faal�ty loraletl in ha 1Mecklenburg Co+etlyl or the drxtltarge of stornv srater"1(titlAan.un
a ndthalthwceidncwepaper I wh named tnhufary to Long Creekti�� r E mkc-H,}'+ -:F� f1^�ti
or legal advertieemem was publaFu, w�„Permd.rturrnber NC0046531}to CmMm Central petroleum Cartrpy for Ilse Paw.Creek Terminal.
every nrcTh pvblicaeoik a nawspapee(located VP Paw Creek(Medckk!nburg Counlyl for Cie dsci��large ogf s;armvater Into an unnamed tributary
end yuatirFicafioro of Scnion]797 r'.to Gum Branch-.�}r$�'��s`�.2•,•* �dr r3.,r.t t-'M��::L"� Yam.."•r+i- y.{?�ui t -°.
Carog,u aad wa.•gvaled pr^r ;:penNl nugtber NCOOafi892 to MotnVa Enterp,rses LLC for tl+e[3,artolfe Terminal located In Paw
t�n I-547 aFthc t3enval Slataler (Creek(Mecklenburg CdunryS for the dosrhargerof slomry alec'aea remedra+ed praundwater to an
unnamed tributary to Long Creek t. ,'TW.9 �.�f y I i, n�• y
Thu 16 th d.y of M�1,4'G-'Permu Itumbir N01101148V W ElusonMebiS�efirretg 8 Supply Company fdr_tttd ChaMlla.Teminal
�� dslorated In CharlotW{Macklentiurp County)for the drscttatpe d trtorr�water and remediated groundwa-
(Signed) —� /L/ Oman wmemed tnbulary to Long Creek sty ;i?pt'Y1{`rt' )s
")3
Swammand euhacrihedh fore>< Penmtnumhermaoo0i185 to 4Wdiams 7emn Hats Holdings LP fur the Paw Creek Terminallocated
-inwree tM gCquaty)Wr tha drsdtarge o�f,}stomYwaler to an 4unnam6d tnbvia'Fj fi Long
3 6th daY of March 201 Creek° E .�! �'g'i� �6.e1yil"P'�,-e�
PURPOSE Eaai of these FacPubned has applied fa renewal d$Heir NPOES pemdt fa dse ducltarge
Ueated sWmiwalor andlor temadlakd groundwater fnW wafef-p be t4 Catawba River basin t]n dre;
basis W Prehm nary 51afl A W and ap;Rzflon of Ar6da 21 of CHapiar ia3,General Stalmi bf No*.
Notary Puhls Card na'anddh¢r lawful aundards anO regWatro�+s,Me North Cadlna.Erlvlrtn-moot AAanagement
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
2001 Permitting Strategy
Background / 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:
➢ 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.
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B. Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual
- -� Monitor annually (assuming first five discrete storm events have already been monitored and
showed no 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/l
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/l 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).
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
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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
II. 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
PARAMETER DETECTED IN OIL TERMINAL STORMWATER?
Acrolein
Acrylonitrile
Benzene J
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane J
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 ra ene
trans-l,3-Dichloro ro ene
Ethyl benzene ✓
Methylene chloride J
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1,1,1-Trichloroethene
1,1,2-Trichloroethene
Trichloroethane
Trichlorofluoromethane ✓
Vinyl chloride
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Table 2. Compounds detectable by EPA Method 625
PARAMETER DETECTED IN OIL TERMINAL STORMWATER?
Acena h hene
Acena hth lease =_.
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-cth ]he 1 hthalate
Bis 2-chloroiso ro 1 ether
4-Bromophenyl phenyl
ether
2-Chlorona hthalele
4-Chlorophenyl phenyl
ether
Ch sene
Dibenzo a,h anthracene
Di-n-bu 1 hthalate
1,3-Dichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
3,3'-Dichlorobenzidine
Diethyl phthalate
Dimeth I phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octylphthalate J
Fluoranthene
Fluorene
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
lndeno 1,2,3-cd rene
Iso horone
Naphthalene ✓
Nitrobenzene
N-Nitro sodi-n- ro lamine
PCBs
Phenanthrene ✓
rene
Toxa hene
1,2,4-Trichlorobenzene
4-Chloro-3-meth l henol
2-Chloro henol
2,4-Dichloro henol
2,4-Dimeth I henof
2,4-Dinitro henol
2-Meth 1-4,6-dinitra henol
2-Nitro phenol
4-Nitro phenol
Pentachloro henol
Phenol ✓
2,4,6-Trichloro 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 existirig'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
I. 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), 7QI0 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,.
r (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.
#II. 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 prevent a downstream
violation of the NC State standard for phenols of 1 pg/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).
B. Benzene
Monitor monthly
Daily maximum limit - 1.19 pg/1 * 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 µg/1. 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. 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.
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SOC PRIORITY PROJECT:NO
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: July 11, 200I
NPDES STAFF REPORT AND RECOMMENDATIONS
County: Mecklenburg
NPDES Permit No.: NC-0 42-74
MRO No.: 01-32
PART I - GENERAL INFORMATION
1. Facility and Address: Valero Marketing and Supply company
PO Box 500
San Antonio, Texas 78212
2. Date of Investigation: May 21, 2001
3. Report Prepared By: B. Dee Browder, Environ. EnAr. 1
4. Person Contacted and Telephone Number: Frank White, [phone].
5. Directions to Site: From the jct. of Highway 27 (Freedom Drive) and Old Mount Holly
Road in northwest Charlotte, travel east on Old Mt. Holly Road approximately 0.5 mile.
Valero is located on the right (south) side of the road.
6. Discharge Point(s), List for all discharge Points: -
Latitude: 35° 16' 34"
Longitude: 80° 55' 45"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: F 15 SW Mtn. Island Lake
7. Site size and expansion area consistent with application: Yes.
8. Topography (relationship to flood plain included): Relatively flat; the WWT facilities are
not in a flood plain.
9. Location of Nearest Dwelling: None within 500 feet.

Page Two
10, Receiving Stream or Affected Surface Waters: UT to Paw Creels
a. Classification: C
b. River Basin and Subbasin No.: Catawba 03-08-34
C. Describe receiving stream features and pertinent downstream uses: Downstream
users are unknown.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater: Intermittent Discharge
b. What is the current permitted capacity: NIA
C. Actual treatment capacity of current facility (current design capacity): NIA
d. Date(s) and construction activities allowed by previous ATCs issued in the
previous two years: NIA
e. Description of existing or substantially constructed WWT facilities: The facility is
engaged in diesel fuel and kerosene storage and distribution. Discharges from the
facility include stormwater collected in the above ground storage tank
containment basin and drainage from the truck loading rack area. The treatment
works consists of dual oil/water separators (in series), air stripper not in use), an
8,000 n holdin tank one arti ate filter three carbon filters and one
yolishin2 filter to treat water from the loading rack area.
f. Description of proposed WWT facilities: NIA
g. Possible toxic impacts to surface waters: There are no toxic impacts expected.
h. Pretreatment Program (POTWs only): Not Needed.
2. Residual handling and utilization/disposal scheme:
a. If residuals are being land applied specify DEM Permit No. NIA.
Residuals Contractor: NIA
Telephone No. NIA
b. Residuals stabilization: PSRP PFRP
C. Landfill: NIA
3. Treatment Plant Classification: Class I (no change from previous rating).
4. SIC Code(s): 6171 Wastewater Code(s): 3973
5. MTU Code(s): 53208,

Page Three
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No
2. Special monitoring or limitations (including toxicity) requests: None at this time.
3. Important SOC/JOC or Compliance Schedule dates: NIA
Submission of plans and specifications
Begin Construction
Complete construction
4. Alternative Analysis Evaluation
a. Spray Irrigation: NIA
b. Connect to regional sewer system: NIA
c. Subsurface: NIA
d. Other disposal options: NIA
r
PART IV- EVALUATION AND RECOMMENDATIONS
It is recommended that the Permit be renewed as requested by the applicant.
�l
Signature of Report Preparer /Date
Water Quality Re 'anal Supervisor Date
h:\&Ad091&T

Sent By: ; . 919 821 0337; May-2-01 16:32; Page 2/3
NORTH- CAROLINA
PE'I`ROLEUM
COUNCIL,
A Blum lm of the Ammium Peaulsm Institute
WIL LAM 11.WDA7tu'RSPOON SUME 285D • 150 FAYL=Vn E Sr.MAIL.
1aaUMN DUEMW RALEIGH.NC 27601
41Of829-6438 • rAXQ19/M1-0_37
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 Pttmit Renewals
Paw Creek Petroleum Pipeline and Distribution Tern-iinals
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 is the terminals'
draft permits.
The North Carolina Petroleum Council—a division or the Amcrican PcWleurn 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 rulemaking 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 rulemaking process to tighten the MTBE groundwater
%%WW=4. 3o me Wr.n&l await 4W oa th"vl ovosaL we Are now confronted with

Sent By: ; .919 821 0337; May-2-01 16:32; Page 313.
Mr. fiche Shiver
May Z,2001
Page 2 .r.±�....aw.. . � r....
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 in support of an
MTBE 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 considerations are truly moving this fazt, if numbers 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 more appropriate and needed to insure'that the calculations of
today are not abandoned tomorrow.
Recommendations
The Council's members accept 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 scmEi-annual rnonitg nn by
each of the terminals will provide the needed representative data to farm the basis for future
decision-making.
Sincerely,
Wry
William H. Weatherspoon
- WHW/jm — — -- - - -- - - -
c: Ms. Natalie Sierra

�L 'IA,LERO Kirk A. Saffell
?^� MARKETING AND SUPPLY COMPANY Corporate Environmental Director
Post Office Box 500• San Antonio, Texas 78292-0500 • Telephone [phone]
April 30, 2001
Ms. Natalie V. Sierra VIA FEDERAL EXPRESS
NCDENR—D WQ - NPDES Unit
1621 Mail Service Center
Raleigh, NC 27699-1617
Subject: Draft NPDES Permit#NC0004723 ti Y
Valero Marketing & Supply Company ("Valero") ;. A
Mecklenburg County I}
WATER Q'�AUTY
Dear Ms. Sierra: FDI'T SOURCE f21.
This letter provides Valero's comments on the above referenced draft permit. Valero received
this draft on April 2, 2001.
1. Benzene, Toluene, Ethyl Benzene, Xylenes and MTBE— Valero requests that the
requirement for monthly testing for these parameters be removed. This testing is unnecessary
because Valero does not manage gasoline at this terminal. In addition, the current permit
language requires semi-annual testing for these parameters by EPA Methods 624/625,
2. Turbidity and Total Suspended Solids (TSS)—Valero requests that the Daily Maximum
Limit (DML) for Turbidity be removed. We feel this testing is duplicative of the current 45
mg/1 DML for Total Suspended Solids.
3. Oil and Grease Limit---Valero believes that the proposed DML for Oil and Grease is
unnecessary and should be removed. Valero proposes to continue monthly testing for Oil and
Grease as required by the current permit. We believe that imposition of a DML is
unnecessary based on historic testing results and the fact that there have been no changes in
the operation of the terminal since the last NPDES permit renewal.
If you have any questions regarding these comments, please contact Frank White at (704) 399-
3041.
Sincerely,
Kirk A. Saffell

DIVISION OF WATER QUALITY
April 5, 2001
MEMORANDUM
TO: Dave Goodrich a o q
ter/ �UJ
Q co
1 0 �W
w U
FROM: D. Rex Gleason rW1_9 o
PREPARED BY: Richard Bridgeman�
e �z
w o
SUBJECT: Draft Permits for Paw Creek Facilities _��
t
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 7Q 10, 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 (NC002196 2) 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 1, 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
'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 Iimits (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 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?
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

r
SURC l/
e
= ti Ili RECEIVED
ly LJ r WATFJ?ni iw m►SFrP0N
RTh CA110 m
APR l U 20)l
MECKLENBURG COUNTY
Department of Environmental Protection Nartawmrga Petntlt6ng
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 storrmwater 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 Street - Suire 205 • Charlotre, NC 25202-2236 [phone] • Fax (;04) 336-4391

- • .,.� ' .. ,;,�., '..��._.M.:= •�.._ ;sue ::i.a:•_�.t - :.. --- .-
Mr Dav`Goodrich'�
{T 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 #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 detention pond.
• Exxon Mobil Refining and Supply Company- Permit # 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 1.19µg/l.
• Marathon Ashland Petroleum, LLC- Permit #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/1 and
toluene concentration is less than 1 lµg/l." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19µg/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 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.

A
t: Mr. Dave Goodrich' "'-'' ,
Pa`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,
Rus€y- ozzeIIe "
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP
0

�L WEK0 Norman L. Renfro
^� MARKETING AND SUPPLY COMPANY Vice President
Environmental and Safety Affairs
March 9, 2001
Ms. Valery Stephens [VW
0 V
North Carolina Department of Environment
and Natural Resource (NCDENR) 2001
Division of Water Quality, NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 IDENR.WATER QUALITY
POINT SOURCE BRANCHi
Re: NPDES Permit Renewal
Valero Marketing and Supply Company
7325 Old Mount Holly Road
Paw Creek, North Carolina (Mecklenburg County)
NPDES Permit No. NC0004723
Dear Ms. Stephens:
Per your letter dated February 27, 2001, enclosed is the information you requested:
a) a site plan indicating all sources of stormwater, washwater, and other wastewater being
discharged from the permitted outfall,
b) there is no electronic copy of DMRs,
c) all tank solids, tank bottoms water, the rag layer, and any other waters are disposed off
through Shamrock Environmental (via vacuum truck), in other words no discharge to the
outfall.
If you have any questions or require further information, please contact Winson Low at (210) 370-
2432.
Sincerely,
Norman Renfro
One Valero Place • San Antonio, Texas 78212
Post Office Box 500 • San Antonio, Texas 78292-0500 •Telephone [phone] • Facsimile [phone]

STORMWATER STORMwATER
FROM FROM
LOADING RACK TAN% FARM
FREE PRODUCT
RE VERY CLEAN STORMwATUR t
FREE PROOUCT
vuvE
T
CARBON
BAFFLE TANK BAFFLE TANK ROLDwG TANK CANISTERS (J)
STORM WATER OIL/WATER OR/WATT R
FROM SEPARATOR SEPARATOR SUMP PUMP NPOES
IOALTIHG RACK GRANTY FEED CAPACITY CAPACITY CAPACITY ��
NO. AL
600 001
DAL. A•DOO GAL. 6.000 CAl-
�. NO. I NO. 2 r
SNIPUNG SAMPLING
PCIMT POINT
c LAW ENVIRONMENTAL, INC.
CHARLOTTE, NORTH CAROLINA
6
eTOlW WATZRf rA$TUWAT= FLOW sCHEMATIC
P10B60 ENERGY USA_ WC.
CHARLarm NORTH CAROTINA
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REASONABLE POTENTIAL ANALYSIS
Prepared by: N�ataiie•Sierra-3/1101
Facility Name = Valero Marketing and Supply
NPDES# = NC0005771
Qw(MGD) = 0.195 max flow
Qw(cfs) = 0.301704
7Q10s (cfs)= 0
1 WC (%) 1100.00
Chronic CCC w/s7Q10 dil. Frequency of Detection
Parameter FINAL RESULTS, ugll #Samples # Detects
bis(2-E thy Ihexyl)phthalate
Max. Pred Cw 121 A
Allowable Cw 5.9 10 2
Methylene chloride
Max. Pred Cw 15.7
Allowable Cw 1600.0 9 1
Turbidity
Max. Pred Cw 92.2
Allowable Cw 50.0 14 14

Parameter= bis(2-Ethylhexyl)p h tha late Parameter= IMethylene chloride
Standard= - vgll Standard= 1600 pgll
Dataset= Dataset= DMR99
Modified Data Nondetects RESULTS Modified Data Nondetects RESULTS
2.5 <5 Std Dev. 6.552 2.5 <5.0 Std Dev. 1.133
2.5 <5 Mean 5.600 2.5 <5.0 Mean 2.878
2.5 <5 C,V. 1,170 2.5 <5.0 C.V. 0.394
2.5 <5 Sample# 10.000 2.5 <5.0 Sample# 9.000
2.5 <5 2.5 <5.0
17 Mult Factor= 6.390 2.5 <5 Mult Factor= 2.660
2.5 <5 Max.Value 19.000 pg/l 2.5 <5 Max.Value 5.900 pgll
2.5 <5 Max. Pred Cw ###### pg/l 5.9 Max. Pred Cw 15.694 pg/l
19 Allowable Cw 5.900 pg/l 2,5 <5.0 Allowable Cw 1600.000 pgll
2.5 <5
sample# nondetects detects sample# nondetects detects
10 8 2 9 8 1

Valero NC0004723
Discharge 001
Date Ave. Flow T5R 10il&Grease Toxicity Turbidity
(mg1L) (mglL) (P1F) (NTU
4129197 0.00257 <1 <1
7/23/97 0.00228 21.6 <1
9/25/97 0.00777 12.5 <10
10/27/97 0.00164 5.8 <10 P
1211197 0.00140 3.5 <10
1119198 0,00305 6.3 <1
215198 0.00654 9.2 <10
3/11/98 0,00087 14,6 <1
4113198 0.00015 5.1 <1
619198 0,00005 10 <5
7120/98 0.19500 <1 <1 P
7128198 0.001508 2.9 1.7
8119/98 0,001207 20.3 <1
918198 0.001495 3.2 <1
11098 0.000045 16 <1
12/28198 0.0001208 13 56
118199 0.0000229 7 13
2118199 0.0033155 5 16 P
4/30199 0.147553 16 47 28
6/18/99 0.152441 5 <5 4.5
8127199 0.069126 4.3 21 2.3
9124199 0.086553 4 <5 2.3
10/11/99 0.181892 3.6 <5 4.3
12/17/99 0.115007 <2 <5 2.7
1119100 0.057226 16 <5 16
2114100 0.098656 10 9.4 7.5
3120100 0.130087 16 37 6.5
4/17/00 0.171847 4.4 35 1.5
6/23100 0.002795 8 7.7 16
7113/00 0.040521 9.6 12 3.8
816100 0.058957 3.4 25 2.3
9/19/00 0.163245 5.2 8.3 3.9
12/20/00 0.045984 7.2 <5 5.5
1115/01 0.033078 11 70 8
average 0.0525 9.0226 7.1938
max 0.19500 21.6 70 28
EPA Methods 6241625:
1997 All compounds listed below detection level
1998 All compounds listed below detection level
1999 All compounds listed below detection level except bis(2-Ethylhexyi)phthalate at 17 ug1L-detection limit=5 ug1L
2000 All compounds listed below detection level except methylene chlorinde(5.9 ug1L)-d election limit=5 uglL
bis(2-Ethylhexyl)phihalate at 19 ug1L-detection limit=5 uglL
2001 All compounds listed below detection level(only one sample event)

Parameter= Turbidity
Standard= 501 NTU
Dataset= DMR99
Modified Data Nondetects RESULTS
28 Std Dev. 7.092
4.5 Mean 7.194
2.3 C.V. 0.986
2.3 Sample# 16.000
4.3
2.7 Mult Factor
16 Max. Value 28.000 pgll
7.5 Max. Pred Cw 110.320 pgll
6.5 Allowable Cw 50.000 pgll
1.5
16
3.8
2.3
3.9
5.5
8
sample# nondetects detects
16 0 16

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1ALER0 Norman L. Renfro
?^� MARKETING AND SUPPLY COMPANY Vice President
Environmental and Safety Affairs
January 30, 2001
North Carolina Department of Environment -and Natural Resource (NCDENR)
Division of Water Quality, NPDES Unit FEB - 6 2001 i, >,
1617 Mail Service Center y
Raleigh, North Carolina 27699-1617 U�NR POINT S20RCE BRANCH
Re: NPDES Permit Renewal
Valero Marketing and Supply Company
7325 Old Mount Holly Road
Paw Creek, North Carolina
NPDES Permit No. NCO004723
Enclosed you will find the completed Short Form C (submitted in triplicate) for the referenced
facility requesting renewal of the facility's National Pollutant Discharge Elimination System
(NPDES) discharge permit. The facility has been operating in compliance with the discharge
permit and no significant changes have been made at the facility since the last permit renewal.
However, we would like to take this opportunity to clarify the treatment scheme.
As the referenced permit states, the treatment scheme includes "two oil/water separators, an air
stripper, a holding tank, and carbon adsorption for treatment of wastewater from truck loading
racks (stormwater from diked storage tank areas bypasses treatment units)". However, the air
stripper is no longer used at the facility and has not been used for numerous years. The air
stripper was installed to treat water from the tank bottoms prior to discharge. Discharge from tank
bottoms no longer occurs. Based upon review of inspection reports as old as 1994, NCDENR is
already aware that the air stripper is not in use.
To further clarify the treatment scheme, two small inline filters are used at the facility. One filter is
installed prior to the first carbon drum, and the other filter is installed after the last carbon drum.
These filters help to ensure compliance with suspended solids effluent limitations.
Finally, we want to clarify that the majority of the site's discharge results from stormwater
collected in diked areas. This stormwater typically bypasses treatment, as is allowed by the
NPDES discharge permit. Only a small portion of the wastewater, that generated from the truck
loading rack area, requires treatment.
We request that you renew the referenced permit. If you have any questions or require further
information, please contact Winson Low at(210) 370-2432.
Sincerely,
Norman Renfro
One Valero Place• San Antonio, Texas 78212
Post Office Box 500 • San Antonio, Texas 78292-0500•Telephone [phone]• Facsimile [phone]