NC0042501_Fact Sheet_20211015

Fact Sheet for Renewal
October 2021 -- NPDES Permit NC0042501
Page 1

DEQ / DWR / NPDES
EXPEDITED FACT SHEET - NPDES PERMIT RENEWAL
NPDES Permit NC0042501

Joe R. Corporon, P.G., Compliance & Expedited Permitting Unit / 919-807-6394 15Oct2021
Table 1 - Facility Information
Applicant/Facility Name Kinder Morgan Southeast Terminals, LLC /
Greensboro 2 Terminal
Applicant Address 6376 Burnt Poplar Road, Greensboro, NC 27409
Facility Address 6376 Burnt Poplar Road, Greensboro, NC 27409
Permitted Flow (MGD) not limited
Type of Waste 100% Industrial, stormwater in proximity to fuel bulk storage
Facility Class PC-1 County Guilford
Permit Status Renewal Regional Office WSRO
Stream Characteristics
Receiving Stream UT to East Fork
Deep River Stream Class: WS-IV; *
Stream Segment 17-2-(0.3) Drainage Basin Cape Fear River Basin
Summer 7Q10 (cfs) 0.0 Hydrological Unit
[HUC]
03-06-08
30300030102
Winter 7Q10 (cfs) 0.0 Use Support Impaired (Cat. 4): Fish
Tissue Hg; Fecal Coliform 30Q2 (cfs) 0.0 303(d) Listed
Average Flow (cfs) 0.0 State Grid C19SW
IWC (%) 100% USGS Topo Quad Guilford, NC
Facility Summary - Kinder Morgan Southeast Terminals, LLC / Greensboro 1 Terminal is a minor
industrial facility (flow <1 MGD) operating an existing Surface-Water Pollution Control System for
stormwater in proximity to above-ground storage tanks (ASTs) with surface bulk-storage of petroleum
hydrocarbon fuels and ethanol exceeding one million gallons [exempt from NC Stormwater Rules]. This
facility utilizes:
• diked areas (secondary containment of ASTs and piping)
• truck loading-rack drains routed to a 10,000-gallon oil/water separator
with hydrocarbon sensor (contents pumped to settling pond)
• lined settling pond (with outfall)
• effluent pumps and totalizing flow meter
• discharge control valve, manually operated, normally closed [a point-source
discharge].
• Truck-loading rack - spillage diverted to an oil/water separator directing oil
to a carbon-filtration system; water discharge via Outfall 001
Receiving Stream – Outfall 001 discharges to an unnamed tributary (UT) to East Fork Deep River
[Segment 17-2-(0.3)], a waterbody currently classified WS-IV; * located within hydrological unit 03-06-08
[HUC: 030300030102] of the Cape Fear River Basin. The stream segment [17-2-(0.3)b] is listed as
impaired (Cat. 4): for Fish Tissue, Hg, and Fecal Coliform. The stream segment begins at its source
extending downstream to a point 0.4 miles upstream of Guilford County Road SR 1541.
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October 2021 -- NPDES NC0042501
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Compliance History -- According to BIMS, this facility received no permit violations during the
previous permit cycle.
Reasonable Potential Analyses (RPA) – The need for toxicant limits is based upon an evaluation
of reasonable potential to exceed surface water-quality standards (SWQS). The RPA is a statistical
evaluation utilizing a minimum three (3)-year database of the most recently reported effluent data [40 CFR
122.44 (d) (i)]. This procedure utilizes:
1. 95% Confidence Level / 95% probability
2. an assumption of background-zero metals concentrations
3. use of ½ detection limit for “less than” values; and
4. streamflows to consider dilution [15A NCAC 2B.0206] and
5. dissolved metals criteria, effective April 6, 2016 [see permit Section A. (4.)].
RPA Monitor Only – Monthly vs. Quarterly. Although this facility’s parameters of concern (POCs) are
dictated by historical storage of hydrocarbon fuels, many POCs were not detected during sampling and
analysis. Therefore, their recent effluent databases did not show reasonable potential. These POCs include
Benzene, Toluene, Ethylbenzene, Xylenes, Naphthalene, MTBE and Total Recoverable Phenolics.
However, DWR judges two POCs (not detected) to be less threating to the environment; these are
MTBE [a fuel additive, no longer used] and Total Recoverable Phenolics [an esthetic (organoleptic)
parameter]. Because these were not detected (See RPA), DWR hereby reduces the monitoring
frequencies for these two from Monthly to Quarterly [see permit Section A. (1.)]. The remaining POCs
(listed above) will remain at the Monthly frequency (no permit limit). Considering the number of
regularly reported discharges, they continue as POCs deemed significant to ongoing facility operations
(see Table 4).
Table 2 Monitoring Data Summary – Effluent (Sep2018 – Jul2021) [42 Months]
Parameter Max Min Average Count Units
00556 - Oil & Grease 6.25 5.15 5.65 42 mg/l
22417 - Methyl Tert-Butyl Ether <1 <1 <1 17 µg/l
32730 - Phenolics, Total Recoverable 40 40 40 42 µg/l
34010 - Toluene <1 <1 <1 42 µg/l
34030 – Benzene <1 <1 <1 42 µg/l
34371 - Ethylbenzene <1 <1 <1 42 µg/l
34696 - Naphthalene <5 <5 <5 42 µg/l
00070 - Turbidity 28.1 1.25 9.16 42 mg/L
81551 – Total Xylenes <3 <3 <3 42 µg/l
CO530 - Solids, Total Suspended 10.2 <2.5 3.46 42 mg/l
Table 3 – Annual flows in MGD (Jan2018 – Jul2021 = 42 Months)
Year Maximum
Flow
Minimum
Flow
Average
Flow
Number of
Discharges
2018 0.609 0.0003 0.124 120
2019 0.635 0.0001 0.143 95
2020 0.979 0.0011 0.223 80
2021 0.561 0.0021 0.172 41

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October 2021 -- NPDES NC0042501
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Table 4 – MONTHLY FLOWS - Database Jan2018-Jul2021
To facilitate a reasonable potential analysis (RPA) required by EPA, DWR documents the highest reported
monthly average flow as conservative to protect the environment.
2018 Average
Flow
Number of
Discharges
Per Month (episodic) MGD n
Jan 0.204 5
Feb 0.051 13
Mar 0.122 9
Apr 0.103 11
May 0.088 11
Jun 0.083 7
Jul 0.033 6
Aug 0.177 10
Sep 0.166 13
Oct 0.322 6
Nov 0.118 14
Dec 0.113 15
2019 Average
Flow
Number of
Discharges
Per Month (episodic) MGD
Jan 0.098 10
Feb 0.155 10
Mar 0.130 6
Apr 0.121 10
May 0.119 3
Jun 0.270 12
Jul 0.175 5
Aug 0.152 9
Sep ~ No flow
Oct 0.155 10
Nov 0.082 10
Dec 0.095 11
2020 Average
Flow
Number of
Discharges
Jan 0.152 8
Feb 0.173 11
Mar 0.235 3
Apr 0.164 6
May 0.186 13
Jun 0.167 3
Jul 0.031 2
Aug 0.537 7
Sep 0.173 7
Oct 0.202 6
Nov 0.199 7
Dec 0.221 7
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October 2021 -- NPDES NC0042501
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2021 Average
Flow
Number of
Discharges
Jan 0.087 4
Feb 0.189 10
Mar 0.175 7
Apr 0.127 1
May 0.303 3
Jun 0.154 8
Jul 0.165 8
* Highest Monthly Average [as required by EPA] during the last thirty-four (34) month
period = 0.322 MGD (Oct2018). This figure is used to evaluate reasonable potential to
exceed SWQ standards [See RPA].

Changes from the Previous Permit: For renewal, DWR has made the following changes:
1. updated facility description (see Supplement to Permit Cover Sheet)
2. updated text for WET testing [Condition A. (3.)]
3. updated facility map
4. monitoring frequencies for the analytes MTBE and Total Recoverable
Phenolics are hereby reduced from Monthly to Quarterly. [see above:
RPA Monitor Only – Monthly vs. Quarterly.
5. increased Whole Effluent Toxicity (WET) testing frequency from
Annually to Quarterly, in accord with revised statewide policy to
protect surface water quality.
Rationale for Increased WET-Testing - During the previous permit cycle, DWR judged “Annual”
WET-testing insufficiently frequent to protect surface water quality and is currently revising monitoring
frequencies in all NPDES permits statewide. Therefore, this renewal reflects sampling Quarterly of an
episodic discharge, Acute monitoring using Fathead Minnow (Pimephales promelas), [TAE6C] as 24-hr
definitive, LC-50 >100%. The previous Acute WET-test database does not demonstrate toxicity issues
[Annual “pass”] for years 2019, 2020, and 2021 [See BIMS monitoring data].
This facility combines stormwater with potential product-contact wastewaters herein judged a complex
wastestream discharging episodically to a local ditch under zero-flow receiving-stream conditions, 7Q10
and 30Q2 = 0.0 cfs (IWC = 100%). Acute WET testing @ 90% effluent concentration is therefore deemed
appropriate to adequately evaluate end-of-pipe short-term impacts of episodic discharges, conducted. [REF
Memo: Coleen Sullins, Director, DWR, 1999].

Proposed Schedule for Permit Issuance:

Public Notice (estimated): October 26, 2021
Issuance (estimated): December 3, 2021
Effective Date (estimated): January 1, 2021
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October 2021 -- NPDES NC0042501
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NPDES DIVISION CONTACT

If you have questions regarding any of the above or the attached permit, please contact Joe R.
Corporon, P.G., email preferred [[e-mail]].

NAME: _____ DATE: 15OCT2021

NPDES Implementation of Instream Dissolved Metals Standards – Freshwater Standards

The NC 2007-2015 Water Quality Standard (WQS) Triennial Review was approved by the NC
Environmental Management Commission (EMC) on November 13, 2014. The US EPA subsequently
approved the WQS revisions on April 6, 2016, with some exceptions. Therefore, metal limits in draft
permits out to public notice after April 6, 2016 must be calculated to protect the new standards - as
approved.

Table 5. NC Dissolved Metals Water Quality Standards/Aquatic Life Protection
Parameter Acute FW, µg/l
(Dissolved)
Chronic FW,
µg/l
(Dissolved)
Acute SW, µg/l
(Dissolved)
Chronic SW,
µg/l
(Dissolved)

Arsenic 340 150 69 36
Beryllium 65 6.5 --- ---
Cadmium Calculation Calculation 40 8.8
Chromium III Calculation Calculation --- ---
Chromium VI 16 11 1100 50
Copper Calculation Calculation 4.8 3.1
Lead Calculation Calculation 210 8.1
Nickel Calculation Calculation 74 8.2
Silver Calculation 0.06 1.9 0.1
Zinc Calculation Calculation 90 81

Table 5 Notes:
1. FW= Freshwater, SW= Saltwater
2. Calculation = Hardness dependent standard
3. Only the aquatic life standards listed above are expressed in dissolved form. Aquatic life standards
for Mercury and selenium are still expressed as Total Recoverable Metals due to bioaccumulative
concerns (as are all human health standards for all metals). It is still necessary to evaluate total
recoverable aquatic life and human health standards listed in 15A NCAC 2B.0200 (e.g., arsenic at
10 µg/l for human health protection; cyanide at 5 µg/L and fluoride at 1.8 mg/L for aquatic life
protection).

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October 2021 -- NPDES NC0042501
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Table 6. Dissolved Freshwater Standards for Hardness-Dependent Metals
The Water Effects Ratio (WER) is equal to one unless determined otherwise under 15A NCAC
02B .0211 Subparagraph (11)(d)

Metal NC Dissolved Standard, µg/l
Cadmium, Acute WER*{1.136672-[ln hardness](0.041838)} ∙ e^{0.9151 [ln hardness]-3.1485}
Cadmium, Acute Trout waters WER*{1.136672-[ln hardness](0.041838)} ∙ e^{0.9151[ln hardness]-3.6236}
Cadmium, Chronic WER*{1.101672-[ln hardness](0.041838)} ∙ e^{0.7998[ln hardness]-4.4451}
Chromium III, Acute WER*0.316 ∙ e^{0.8190[ln hardness]+3.7256}
Chromium III, Chronic WER*0.860 ∙ e^{0.8190[ln hardness]+0.6848}
Copper, Acute WER*0.960 ∙ e^{0.9422[ln hardness]-1.700}
Copper, Chronic WER*0.960 ∙ e^{0.8545[ln hardness]-1.702}
Lead, Acute WER*{1.46203-[ln hardness](0.145712)} ∙ e^{1.273[ln hardness]-1.460}
Lead, Chronic WER*{1.46203-[ln hardness](0.145712)} ∙ e^{1.273[ln hardness]-4.705}
Nickel, Acute WER*0.998 ∙ e^{0.8460[ln hardness]+2.255}
Nickel, Chronic WER*0.997 ∙ e^{0.8460[ln hardness]+0.0584}
Silver, Acute WER*0.85 ∙ e^{1.72[ln hardness]-6.59}
Silver, Chronic Not applicable
Zinc, Acute WER*0.978 ∙ e^{0.8473[ln hardness]+0.884}
Zinc, Chronic WER*0.986 ∙ e^{0.8473[ln hardness]+0.884}

General Information on the Reasonable Potential Analysis (RPA)

The RPA process itself did not change as the result of the new metals standards. However,
application of the dissolved and hardness-dependent standards requires additional consideration in
order to establish the numeric standard for each metal of concern of each individual discharge.

The hardness-based standards require some knowledge of the effluent and instream (upstream)
hardness and so must be calculated case-by-case for each discharge.

Metals limits must be expressed as ‘total recoverable’ metals in accordance with 40 CFR
122.45(c). The discharge-specific standards must be converted to the equivalent total values for
use in the RPA calculations. We will generally rely on default translator values developed for each
metal (more on that below), but it is also possible to consider case-specific translators developed in
accordance with established methodology.

RPA Permitting Guidance/WQBELs for Hardness-Dependent Metals - Freshwater

The RPA is designed to predict the maximum likely effluent concentrations for each metal of
concern, based on recent effluent data, and calculate the allowable effluent concentrations, based
on applicable standards and the critical low-flow values for the receiving stream.

If the maximum predicted value is greater than the maximum allowed value (chronic or acute), the
discharge has reasonable potential to exceed the standard, which warrants a permit limit in most
cases. If monitoring for a particular pollutant indicates that the pollutant is not present (i.e.
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October 2021 -- NPDES NC0042501
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consistently below detection level), then the Division may remove the monitoring requirement in
the reissued permit.

1. To perform a RPA on the Freshwater hardness-dependent metals the Permit Writer
compiles the following information:
• Critical low flow of the receiving stream, 7Q10 (the spreadsheet automatically
calculates the 1Q10 using the formula 1Q10 = 0.843 (s7Q10, cfs) 0.993
• Effluent hardness and upstream hardness, site-specific data is preferred
• Permitted flow
• Receiving stream classification

2. In order to establish the numeric standard for each hardness-dependent metal of concern
and for each individual discharge, the Permit Writer must first determine what effluent and
instream (upstream) hardness values to use in the equations.

The permit writer reviews DMR’s, Effluent Pollutant Scans, and Toxicity Test results for
any hardness data and contacts the Permittee to see if any additional data is available for
instream hardness values, upstream of the discharge.

If no hardness data is available, the permit writer may choose to do an initial evaluation
using a default hardness of 25 mg/L (CaCO3 or (Ca + Mg)). Minimum and maximum
limits on the hardness value used for water quality calculations are 25 mg/L and 400 mg/L,
respectively.

If the use of a default hardness value results in a hardness-dependent metal showing
reasonable potential, the permit writer contacts the Permittee and requests 5 site-specific
effluent and upstream hardness samples over a period of one week. The RPA is rerun using
the new data.

The overall hardness value used in the water quality calculations is calculated as follows:
Combined Hardness (chronic)
= (Permitted Flow, cfs *Avg. Effluent Hardness, mg/L) x (s7Q10, cfs *Avg. Upstream Hardness,
mg/L)
(Permitted Flow, cfs + s7Q10, cfs)

The Combined Hardness for acute is the same but the calculation uses the 1Q10 flow.

3. The permit writer converts the numeric standard for each metal of concern to a total
recoverable metal, using the EPA Default Partition Coefficients (DPCs) or site-specific
translators, if any have been developed using federally approved methodology.

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October 2021 -- NPDES NC0042501
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4. The numeric standard for each metal of concern is divided by the default partition
coefficient (or site-specific translator) to obtain a Total Recoverable Metal at ambient
conditions.

In some cases, where an EPA default partition coefficient translator does not exist (ie.
silver), the dissolved numeric standard for each metal of concern is divided by the EPA
conversion factor to obtain a Total Recoverable Metal at ambient conditions. This method
presumes that the metal is dissolved to the same extent as it was during EPA’s criteria
development for metals. For more information on conversion factors see the June, 1996
EPA Translator Guidance Document.

5. The RPA spreadsheet uses a mass balance equation to determine the total allowable
concentration (permit limits) for each pollutant using the following equation:

Ca = (s7Q10 + Qw) (Cwqs) – (s7Q10) (Cb)
Qw
Where: Ca = allowable effluent concentration (µg/L or mg/L)
Cwqs = NC Water Quality Standard or federal criteria (µg/L or mg/L)
Cb = background concentration: assume zero for all toxicants except NH3* (µg/L or
mg/L)
Qw = permitted effluent flow (cfs, match s7Q10)
s7Q10 = summer low flow used to protect aquatic life from chronic toxicity and human
health through the consumption of water, fish, and shellfish from noncarcinogens (cfs)
* Discussions are on-going with EPA on how best to address background
concentrations

Flows other than s7Q10 may be incorporated as applicable:
1Q10 = used in the equation to protect aquatic life from acute toxicity
QA = used in the equation to protect human health through the consumption of
water, fish, and shellfish from carcinogens
30Q2 = used in the equation to protect aesthetic quality

EPA default partition coefficients or the “Fraction Dissolved” converts the valu e for
dissolved metal at laboratory conditions to total recoverable metal at in-stream ambient
conditions. This factor is calculated using the linear partition coefficients found in The
Metals Translator: Guidance for Calculating a Total Recoverable Permi t Limit from a
Dissolved Criterion (EPA 823-B-96-007, June 1996) and the equation:

_Cdiss__ = _______1_______________
Ctotal 1 + { [Kpo] [ss(1+a)] [10-6] }

Where:
ss = in-stream suspended solids concentration [mg/l], minimum of 10 mg/L used, and
Kpo and a = constants that express the equilibrium relationship between dissolved and
adsorbed forms of metals. A list of constants used for each hardness-dependent metal can
also be found in the RPA program under a sheet labeled DPCs.

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October 2021 -- NPDES NC0042501
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6. The permit writer enters the most recent 2-3 years of effluent data for each pollutant of
concern. Data entered must have been taken within four and one-half years prior to the date
of the permit application (40 CFR 122.21). The RPA spreadsheet estimates the 95th
percentile upper concentration of each pollutant. The Predicted Max concentrations are
compared to the Total allowable concentrations to determine if a permit limit is necessary.
If the predicted max exceeds the acute or chronic Total allowable concentrations, the
discharge is considered to show reasonable potential to violate the water quality standard,
and a permit limit (Total allowable concentration) is included in the permit in accordance
with the U.S. EPA Technical Support Document for Water Quality-Based Toxics Control
published in 1991.

7. When appropriate, permit writers develop facility specific compliance schedules in
accordance with the EPA Headquarters Memo dated May 10, 2007 from James Hanlon to
Alexis Strauss on 40 CFR 122.47 Compliance Schedule Requirements.

8. The Total Chromium NC WQS was removed and replaced with trivalent chromium and
hexavalent chromium Water Quality Standards. As a cost savings measure, total chromium
data results may be used as a conservative surrogate in cases where there are no analytical
results based on chromium III or VI. In these cases, the projected maximum concentration
(95th %) for total chromium will be compared against water quality standards for
chromium III and chromium VI.

9. Effluent hardness sampling and instream hardness sampling, upstream of the discharge, are
inserted into all permits with facilities monitoring for hardness-dependent metals to ensure
the accuracy of the permit limits and to build a more robust hardness dataset.

10. Hardness and flow values used in the Reasonable Potential Analysis for this permit
included:

Table 7 - Parameter Value Comments (Data Source)
Average Effluent Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)] N/A No Metals Monitoring
Average Upstream Hardness (mg/L)
[Total as, CaCO3 or (Ca+Mg)] N/A No Metals Monitoring
7Q10 summer (cfs) N/A No Metals Monitoring
1Q10 (cfs) N/A No Metals Monitoring
Permitted Flow (MGD) 0.0 No Metals Monitoring