NC0021962_Comments_20210525

A CITGO Petroleum Corporation
36th Street&Delaware River,Box 655
Pennsauken,NJ 08065
CITGO.
May 18, 2021 RECEIVED
MAY 2 5 2021
N. C. Division of Water Resources
Water Quality Permitting Section-NPDES NCDEQIDWRINPDES
1617 Mail Service Center
Raleigh,NC 27699-1617
RE: Charlotte Terminal Draft NPDES Permit NC 0021962 Comments
FedEx— 7737 5400 5830
Dear Mr. Denard:
CITGO Petroleum is submitting a permit modification request for the draft NPDES permit
NC0021962. Regarding the sampling requirements as outlined in Section A. (1) Effluent
Limitations and Monitoring Requirements, CITGO is requesting MTBE be removed from the
monitoring requirements since MTBE has not been used in gasoline since the early 2000s, is not
used in any products stored onsite and has not been detected in NPDES monitoring for at least
the last 5 years and beyond. CITGO is also requesting that the sampling frequencies for EPA
Method 625 (semi-volatiles)be reduced from semi-annual monitoring to annual monitoring as all
semi-volatile monitoring parameters were undetected or below the Reported Detection Limit
(RDL) for at least the last 5 years and beyond.
CITGO believes that through the implementation of stormwater Best Management Practices,
Spill, Prevention, Control and Countermeasure plan, routine equipment maintenance and
inspections, it has minimized the potential for pollutants to enter the stormwater. Additionally,
all products are contained in sealed tanks and hard piped to the loading rack, all rack stormwater
is contained in an aboveground storage tank and hauled offsite for treatment and terminal
personnel complete inspection of stormwater daily and prior to any discharge. As such, the
possibility of the tank dike area contributing pollutants to stormwater is minimal as highlighted
by our monitoring results.
CITGO appreciate you taking these requests under consideration. If you have any questions or
need additional information,please feel free to contact me at(484) 587-6524.
Respectfully
ye
ichael Santee, CSP, CPP
Environmental,Health, Safety and Security Manager
Cc: CITGO Charlotte Terminal