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Home My WebLink AboutNC0000795_Correspondence_19800804NPDES DOCIMENT SCANNING; COVER SHEET NPDES Permit: NC0000795 Document Type: Permit Issuance Wasteload Allocation Authorization to Construct (AtC) Permit Modification Complete File - Historical Engineering Alternatives (EAA) C.- Correspondence Instream Assessment (67b) Speculative Limits Environmental Assessment (EA) Permit History Document Date: August 4, 1980 This document is printed on reuse paper - igpnore any content on the resrerise side NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES & COMMUNITY DEVELOPMENT DIVISION OF ENVIRONMENTAL MANAGEMENT Winston-Salem Regional Office August 4, 1980 MEMORANDUM TO: Mr. Forrest Westall Technical Serivces THRU: Russell D. Radford Assistant Regional Supervisor FROM: M. Steven Mauney Permits & Engineering Coordinator SUBJECT: Exxon Company Greensboro Guilford County This memo is in regard to an earlier discussion between you and Mr. Russell Radford, Assistant Regional Supervisor. It is requested that you review the sampling data attached and advise if it is possible to establish effluent phenol limits. Any degradation of the phenol from the discharge points to the lake would be worth considering. A recent letter from Exxon (dated 4/21/80) included a request to drop the stream sampling. This appears reasonable as the stream is _dry except L -r.k during and immediately after_a rainfall. Exxon would normally only dis (-� charge during favorable weather ^conditions as they must manually unlock the A,_,._ gate valve to begin the discharge through the pump initiated siphon system. If stream sampling is dropped, it appears necessary to establish an effluent limitation for phenol and their sampling shows that they could not meet the 0.001 mg/1 of phenol. An effluent limitation of that value appears impractical as the actual usage of this water for domestic purposes will not occur until it reaches the water intake on High Point's lake. Memo to Mr. Forrest Westall Page 2 A map is attached giving the name and location of the other terminals. It must be noted that #8, #11 and #12 do not pass through the Colonial Pipe- line pond. Stream flow data is given below for Sites A & B: USGS #/DA(sq.mi.) /7-10(CFS) Site B - (East Fork Deep River Near High Point, at bridge 3.3 mile above High Point Dam) 2A0990.00/14.7/2.146 p 03) Site A - (East Fork Deep River, at NC Hwy. 68) 2A0988.33/ 3.91/1.23 The 7-10 flow for site A was calculated using the 7-10 runoff of 0.31 cfs/sq.mi. from USGS Water -Supply Paper 1761 (page 195). The 7-10 flow for site B was calculated using the 7-10 runoff of 0.146 cfs/sq.mi. from same source (index #120, page 108). cs cc: A. C. Turnage --. IYYN.r.. RCK E)'(ON COMPANY, U.S.A. . IITE 200 • 5601 77 CENTER DRIVE • CHARLO7 1 E_, N.C. 28210 MARKETING DEPARTMENT SOUTHERN REGION G.G. JOHNS. JR. OPERATIONS MANAGER (CHARLOTTE) Dr. Neil S. Grigg Director N. C. Department of Natural Resources and Community Development Division of Environmental Management P. 0. Box 27687 Raleigh, N. C. 27611 April 21, 1980 Request for Monitoring Exceptions Exxon NPDES Permit NC0000795 Greensboro, North Carolina RECEIVED North Pindmont Regional Offles APP 22 1980 WATER QUALITY DIV. Dear Sir: When Exxon received renewal of the above -cited permit in December 1979, this office overlooked the fact that certain monitoring requirements which had been deleted from the previous Federal and State permits, as a result of appeal actions by Exxon, had been reinstituted in the renewed permit. Specifically, the renewal requires continuous flow monitoring and downstream sampling for phenols in the nearest flowing stream, requiring a guarantee by Exxon that their operations will not cause phenol content of this stream to exceed one part per billion. In our previous letter to you dated April 8, 1980, we outlined our reasons for believing that flow rate reporting for all Exxon installations in North Carolina is statistically meaningless, and requested a general waiver of this provision in all permits. Out of the entire group, Greensboro Terminal's effluent system is uniquely unsuited for a continuous flow monitoring requirement. Storm water runoff from the tank field, water drawn off from tankage, and loading rack storm water runoff and spillage (.this latter stream via a 20,000 gallon oil/water separator) flow to a trapezoidal impounding pond averaging 165' x 425' in area, and originally about 711' deep. This pond is drawn down to a dry ditch,which ultimately flows to a tributary of the Deep River very infrequently. During the period 1976-1980, annual draw -down frequency has varied from two times in 1977 to seven times in 1979, largely dependent on rainfall in the area, and the degree of draw -down feasible when coordinated with other terminal activities. (Complete draw -down requires about three eight -hour supervised discharges, during daylight hours only, using a hand -pump actuated submerged siphon.) Two feet of outage are always maintained in the pond to accomodate the largest foreseeable product spill. The pond is never drawn below 11/2' to avoid discharge of any incipient oil slick on the pond surface. The most recent two draw -downs of the pond were November 8, 1979 and March 26, 1980. ...cont'd. A DIVISION OF EXXON CORPORATION Dr. Neil S. Grig, Page Two April 21, 1980 Assuming the pond is still dredged to its original depth (a very conservative assumption in view of substantial siltation at the upstream side), each complete draw -down produces a discharge of 3,317,000 gallons. For the maximum reported seven drawdowns annually, total calculated volume would be 23,219,000 gallons. Given the most recent phenol analysis on effluent, 68 micrograms/liter, total annual phenol discharged from Exxon's facility would be 13.1 ib . , discharged during periods of high rainfall when flow in the Deep River system is at a maximum. We submit that, under circumstances described above, Exxon's phenol contribution to the raw water pool is insignificant. Effluent discharged from Exxon's pond flows into a normally dry ditch, thence through a storm sewer under the Hess Terminal into a fish pond abutting the Plantation Pipeline pumping station. Effluent from the pond flows under Interstate 40 via a normally dry ditch into another pond on Colonial Pipeline property. Effluent from Colonial's pond flows some distance through a normally dry ditch before it reaches the first running stream, an unnamed tributary of Deep River. Given the large number of other operations intermittently discharging into the same drainage system, runoff from the interstate, and random variability of the two downstream pond levels, it is submitted that an analysis of water from the running stream cannot be statistically related to the characteristics of Exxon's effluent, and therefore proposed downstream monitoring and analysis is meaningless and serves no purpose. Therefore, on the basis of information discussed above, it is requested that the requirement for continuous effluent flow monitoring and downstream sampling for phenol analysis be deleted from this permit. A file of previous correspondence with the State and Federal EPA is attached for your information. Yours very truly, JJS/ndr cc: Mr. Fin Johnson Winston-Salem Regional Office N. C. Department of Natural Resources 8003 Silas Creek Parkway Extension Winston-Salem, N. C. 27106 (w/a) cc: Mr. Wilbur Suggs - Law Department (w/a) Memphis