NC0004839_Permit (Modification)_19990222

MPDES DOCUWEMT SCAMMIM& COVER SHEET
NPDES Permit: NC0004839
Document Type: Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Speculative Limits
Plan of Action
Instream Assessment (67B)
Environmental Assessment (EA)
Permit
History
Document Date: February 22, 1999
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State of North Carolina
Department of Environment
and Natural Resources 0
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
NCDENR -
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
February 22, 1999
Mr. R. T. Harvin
Exxon Company
Charlotte Marketing Terminal
Post Office Box 82
Paw Creek, North Carolina 28130
Subject: Letter to Require Effluent
Turbidity Monitoring
Permit No. NC0004839
Exxon Oil Company
Mecklenburg County
Dear Mr. Harviri:
As you are aware, the turbidity monitoring requirement was eliminated from your
permit upon renewal in August 1996. Although turbidity monitoring was eliminated, total
suspended solids (TSS) monitoring with a limit remains in the permit. It was the Division's
contention that should monitoring data indicate TSS problems, the state has the option of
enforcing the instream standard for turbidity. However, the EPA is still concerned with the
removal of the turbidity monitoring requirement from several oil terminal discharge permits.
The following paragraphs address that concern.
During the research phase required for permit development, it was noted that the 14
permits in the Paw Creek area had vastly different requirements for solids measurements.
Permits contained any combination of total suspended solids (TSS), turbidity, and settleable
solids monitoring and/or limits. In an effort to provide consistency, TSS, turbidity, and
settleable solids results from six oil terminals in the Paw Creek area were examined from
July 1994 through September 1995. Results showed that TSS and turbidity exhibited
similar trends. Both pollutants appeared to increase and decrease at the same time. In
addition, for the period examined,there were no turbidity violations, although there were a
few TSS violations. These data resulted in the Division questioning whether monitoring
was necessary for both solids parameters. Was there an added benefit to requiring turbidity
monitoring in addition to TSS monitoring? The Division concluded that turbidity was
correlated with TSS results, and thus, only TSS monitoring with a limit was required. In
addition,North Carolina-has a water quality standard for turbidity. Therefore, although
turbidity monitoring is not required in the discharge permits, the State still has the authority
to enforce the instream turbidity standard.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/10% post-consumer paper

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Mr. Harvin '
February 22, 1999
Page 2
Based on concerns regarding anti-backsliding, the EPA requested the Division re-
examine the basis for the elimination of turbidity monitoring for 12 of the 14 Paw Creek
oil terminals that were required to monitor for turbidity prior to the most recent permit
renewal. This second examination of the data showed that there were turbidity standard
violations since the last analysis at several of the oil terminals. The Division will
investigate the causes of these violations to determine what steps may be necessary to
control solids levels at these sites. Therefore, the Division acknowledges that its second
evaluation resulted in a different outcome from the initial investigation and agrees that
turbidity monitoring should be added to the discharge permits for several of the oil
terminals. This letter serves as the official notice that quarterly turbidity monitoring
will be required at the facility effective March 1, 1999. If monitoring data show a
reasonable potential to violate water quality standards, then limits will be imposed upon
renewal.
If you have any questions concerning this change, please contact Bethany Bolt at
[phone], extension 551.
Sincerely,
. Preston Howard, Jr., E.
I
I
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Poinf Source Compliance Enforcement Unit

EXOM COMPANY, U.S.A. '
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POST OFFICE 80X 82•PAW CREEK,NORTH CAROLINA 28130
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MARKETING DEPARTMENT ITT R-j
May 29 1998 3 �
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Mr. D. Rex Gleason, P. E _'"_
State of North Carolina
Department of Environment, And Natural Resources
919 North Main Street
Mooresville, North Carolina 281 15
r
Re: Your Letter Dated May 14, 1998
Exxon Marketing Distribution Terminal
Charlotte, North Carolina
HC0001
Dear Mr. Gleason:
This is in response to your letter dated May 14, 1998 concerning Exxon's Charlotte, North
Carolina Terminal. Exxon understands that while analytical results indicate that the facility is
complying with Permit effluent limitations, potential exceedances of the water quality standard for
benzene (1 .19 ug/I) need to be addressed.
Per a telephone discussion between you and Vince Martinelli with Exxon on May 28, 1998, we
will be completing the following steps to further reduce the volatile organics in the facility's water
discharge:
• An "out-of-service" interior inspection and cleaning of the oil/water separator will be
completed by June 30, 1998. The treatment unit will be evacuated, water and sludge
removed, and each compartment will be thoroughly washed. Any residual material will be
transported off-site in compliance with State and Federal laws and regulations.
• To reduce water loading through the oil/water separator all dike field containment water will
be re-routed around the facility's oil/water separator by June 30, 1998. The large volumes
of "clean" water originating from the dike field containment area may be causing the
oil/water separator to operate at less than optimal levels. Per a May 28, 1998 telephone
discussion with Mr. Steve Pellei, North Carolina NPDES Permit Section, it is permissible for
Exxon to re-route such water without the possibility of a Permit re-opener since there will be
no change in the outfall location or in the amount of flow from the facility. To support
Exxon's plans to re-route such water, effluent testing has been performed during the period
December 1997 through April 1998 (sample results attached). During the test period
benzene was not detected down to a detection limit of 1.0 ug/I for water sampled from the
dike field containment area. To continue to route virtually "clean" water through an oil
treatment unit could be counter-productive to the benefits that could result from routing oil-
contaminated water through the same unit. Certainly, a reduction of water volume,
combined with the treatment of only potentially oil-contaminated water, could possibly
improve the overall effectiveness of the oil/water separator.
A,DIVISION OF EXXON CORPORATION
necvcLso

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E)J(®iV COMPANY, U.S.A.
POST OFFICE BOX 82•PAW CREEK,NORTH CAROLINA 28130
MARKETING DEPARTMENT
Mr. D. Rex Gleason, P. E.
North Carolina DENR
Page 2 of 2
• We are in the process of securing an Authorization to Construct Permit to allow-for the
installation of a 30 gallon per minute (gpm) carbon-polishing unit to treat potentially oil-
contaminated water at the terminal coming from the loading rack, pump pad and pipeline
receipt manifold areas. The potentially oil-contaminated water coming from the above-
mentioned areas will first pass through the oil/water separator and will then be pumped to a
carbon-polishing unit. Fallowing polishing, the treated water will then mix with the "clean"
water from the dike field containment area. Both the "polished" water coming from the
carbon unit and the "clean" water coming from the dike field containment area would then
be piped together so that all required NPDES Permit monitoring at Outfall 001 would be
representative of the combined input streams.
• After completion of the re-routing of dike field containment water as described above,
followed by one to two months of sampling at Outfall 001, Exxon will determine whether a
carbon-polishing unit will be necessary. The decision to install the carbon-polishing unit, of
course, will be dependent upon additional investigation and our ability to meet NPDES permit
parameters as well as state water quality standards.
We are committed to working with you to address your concerns. Please be reminded, however,
that surface water sampling performed by the Paw Creek Pact demonstrates that surface waters
were not found to contain pollutants in excess of what one would expect to find in an urban
environment.
Should you have any questions or require additional information please contact me at (704)
399-5696.
Sincerely,
xk�_aT
R. E. Gaston
Terminal Superintendent
C:IDATAIWINWORDICHARLOTTIBENZENE EXCEEDANCES MAY 14, 1998 LETTER TWO.DOC
Attachments
A DIVISION OF EXXON CORPORATION
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SPECIALIZED ASSAYS,INC.
2960 Foster Creighlon Dr.
P.O.Box 40566
Nashville.TN 37204-0566
Phone [phone] A N A L Y T I C A L FR JE F'(1]R T
EXXON CO. , U. S. A. 7466 Lab Number: 97--AII921P
ATTN: GEORGE REAGAN Sample ID: TANKFIELD POND
P. O. BOX 82 Sample Type: Water
PAW CREEK, NC 28130 Site ID:
Date Collected : 12/29/97
Project: Time Collected: 9: 25
Project Name: Date Received : 12/30/97
Sampler: DENTON HOLLIFLELD Time Received : 8: 30
Report Ruin Dil
Analyte Result Units unit Limit Factor Date Time Analyst Method (latch
NORGUIC PARAMETERS](
Benzene RD ug/1 1.01 1.0 1 1/ 1198 11:47 Duncan, J. 602 3463
Toluene NO ug/l 1.0 1.0 1 1/ 1/98 11:47 Duncan, J. 602 3463
Ethoenzene RD ug/l 1.0 1.0 1 1/ 1/98 11:47 Duncan, J. 602 3463
Xglenes:, total RD u9/1 1.0 1.0 1 1/ 1/98 11:47 Duncan, J. 602 3463
10 = clot detected at the report limit.
Surrogate X Recovery Target Range
BTEX/6R0 Surr., a,a,a-trifluorotoluene 111. 50. - 150.
Report Approved By: MA*4. 4 Report Date: 1/ 6/98
Theodore J. Duel lo, Ph. D. , G.A. Officer
Michael H. Dunn, M. S. , Technical Director
Danny B. Hale, M. S. Laboratory Director
Laboratory Certification Number: 887

• ..
SPECIALIZED ASSAYS, INC.
2960 Foster Creighton Ur.
P.O.Box 40566
Neshviile,TN 37204-0566
Phone [phone] p IV A L Y T I G A L_.. Ft E_=F=D ©R T
EXXON CO. , U. S. A. 7466 Lab Number: 98--AO14224
GEORGE REAGAN Sample ID: POND
P. O. BOX 92 Sample Type: Water
PAW CREEK, NC 28130 Site ID:
Date Collected: 2/11/99
Project: Time Collected: 13: 10
Project Name: Date Received : 2/ 12/98
Sampler: DENTON HOLLIFIELD Time Received : 9: 00
Report Quan Dil
Anilgte Result Units Limit Limit factor Date Time Analyst Method Batch
*ORGANIC PARARETERSm
Denxeae RD ug/l 1.0 1.0 1 2/19/98 11:49 Duncan, J. 602 2490
ND = Not detected it the report linit.
+arrogate I Recovery Target Range
BTEXISRO Surr., i,i,a-trifluorotoluene 104. 50. - 150.
Report Approved By: Report Date: 2/23/98
Theodore J. Duello, Ph. D. , G.A. Officer
Michael H. Dunn, M. S. , Technical Director
Danny B. Hale, M. S. , Laboratory Director
Laboratory Certification Number: 387

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SPECIALIZED ASSAYS, INC.
`
�60 Poster u"ighionDr.
no Box 4036^
Nash..x".TNnn+o566 F%J L_ -1F 1E C L— F? IE F=' C3 FZ -r
^ nwor /,mx'rzwx/r
CO, , V SA �46b Lab Nomber� 98—A�8246
�EU|��5 HEA0AN Sample ID: SAMpLE
BOX 82 Ge/np ]e Tgpe�
�'A14 CREEK, NC 11 B1110 Sj te ID:
D�te Coll�� te� �
njec e ("ol )ect9 f I �
ert N;-lme ")ate Received 3/17/98
SamvLer : D. HOLLlr�BLU Time Received
_______________________
' Reyort Aow 0il
�xdWLe KmoY1: Uoits Lb)it Lix/t Fmior Date Uvw Ao�]in\ Upth*A kotoh
-------------' ------ ---- ---- ---- --- ----- --- ------` ----- ----
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9KAUIC PARAMETERS*
Vpozoon O 1.0 1 4127/98 20Y01 k lie rFoI'd 602 Y4B
H0 Hot dotvxte4 at the report Unit.
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��[X/CRD Svrr , ^,o,�{ri800' \o]vpe 11l 5y - 13U
Report Approved by: Rmporl� Datp: 3/28/98
Theodore J. Due lio, Ph, D TA. Of-Ficer
�ichael H, Donn, M. S. , Technical Diret�tor
D: vny V� Hale. M. S. , Laboratory Director
UIouriAory Certification Number: 387
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SPECIALIZED ASSAYS, INC. r'
2960 Foster Creighton Dr.
P.O.Box 40566
Nashville,TN 37204-0566
Phone [phone] P Q Ft -IF
EXXON CO. , U�_S. A. 7466- Lab Numbev : 1'8—A401_16`
r EORGE REAGAN Sample ID: POND
P. ❑. BOX 82 Sample Type: Water
PAW CREEK, NC 28130 Site ID:
Date Collected: 4! .14:'98
Project-, Time Collected-, 16: 40
Pro j"ect Name: Date Received: 4/15?El
Sampler: GEORGE REAGAN Time ReceiVedL 9: {10
TCLP Results
Matrix Spike
Analyte Result Units Reg Limit Recoverg (7) Date #lethod
Benzene ( 0.100 ngll 0.5 104 4120/90 9021
RD = Not detected at the report linit.
Curroyate '1, Recovery Target Range
V0A Surrogate, 1,2-0ichlaroethane, d4 92. 70. - 131.
VQA Surrogate, Toluene d8 109. 78. - 122.
VRA Surrogate, 4-Dronafluorobenzene 83, 77. - 118.
Report Approved By: Report Date: 4J20/''8
Theodore J. Duello, Ph. D. , G. A. Officer
Michael H. Dunn, M. S. , Technical Director
Danny 11, Hale, M. 5. ) Laboratory Director
Laboratory Certification Number: 387
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