NC0000795_Permit Modification_20051114

NPDES DOCUHENT :SCANNING COVER SHEET
NPDES Permit:
NC0000795
Document Type:
Permit Issuance
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Permit
History
Document Date:
November 14, 2005
This document la printed on reuse paper - ignore any
content on the re'erse aide

Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
November 14, 2005
Mr. Matthew E. Marra
Kinder Morgan Southeast Terminals LLC
1435 Windward Concourse
Alpharetta, Ga 30005
Subject: Modification of Permit No. NC0000795
Kinder Morgan Southeast Terminals LLC
Guilford County
Dear Mr. Marra:
The Division of Water Quality has reviewed your request for modification of the
subject permit by deletion of the phenols limit of 0.003 lbs/day. The existing permit
for the Kinder Morgan SE Terminal facility was effective February 2002 and a twelve-
month schedule was given for compliance with the phenols limit. A permit effluent
page notation indicated that removal of the limit could be requested upon submission
of a minimum of twelve datapoints for a reasonable potential analysis. The practical
quantitation limit for phenol was to be determined by the facility by contacting a North
Carolina certified laboratory.
A review of the discharge monitoring reports submitted to the Division of Water
Quality provided the data used in the updated reasonable potential analysis. It was
determined that since March 2003, the facility has reported twelve values for phenol
below the detection level. Based on this information, we will recommend deletion of
the monthly limit of 0.003 lbs/day for phenols. Phenol must continue to be monitored
monthly or whenever the facility discharges, however a limit is no longer applicable.
The continuation of monitoring is based on the Division of Water Quality's guidance
for Petroleum Bulk Storage Facilities and the protection of the receiving stream's water
supply classification. No other changes to the permit have been made.
Please find enclosed the revised page, which should be inserted into your
permit. The old page may then be discarded. All other terms and conditions
contained in the original permit remain unchanged and in full effect. This permit
modification is issued under the requirements of North Carolina General Statutes 143-
215.1 and the Memorandum of Agreement between North Carolina and the U.S.
Environmental Protection Agency.
N. C. Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Phone: [phone]
fax: [phone]
DENR Customer Service Center..1800 623-7748

Letter to Mr. Marra
Page 2
If any parts, measurement frequencies or sampling requirements contained in
this permit modification 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 a written petition conforming to Chapter 150B of the
North Carolina General Statutes, 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. If you have any questions concerning
this permit modification, please contact Jackie Nowell of the NPDES Unit at (919) 733-
5083, extension 512.
Sincerely,
fa, Alan W. Klimek, P.E.
Attachment
cc: Winston Salem Regional Office/Attn: Steve Tedder
NPDES Permit File
Central Files

Permit NC0000795
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT; _ _
CHr. FA.ACTERISTIC_
r _
S :. = f ?= :'.
MONITING=REQUIREMENTS
`_ OR
', °LIIVIIT
MonthlAvraga
_ y
�tu, ;
M-aDil um
�,g__.,�
e'rasuremen
equency..
p
e
.2Typ _
-me
"oi',
_ catoi_.
,Flows
Episodic
1
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
'Oil and Grease2
Monthly
Grab
Effluent
(Phenol
Monthly
Grab
Effluent
yenzene
Monthly
Grab
Effluent
'oluene
Monthly
Grab
Effluent
thyl Benzene
Monthly
Grab
Effluent
Xylene
Monthly
Grab
Effluent
EPA 625
2/Year
Grab
Effluent
MTBE3
Monthly
Grab
Effluent
Acute Toxicity4
Annually
Grab
Effluent
Footnotes:
1. Flow — During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow shall be monitored with each discharge event and may be
monitored in one of four ways:
a) measure flow continuously;
b) Rational Method -- calculate flow based on total rainfall per area including built -on area
draining to the outfall (shall not be used at sites 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. MTBE — See Part A.(2.) for other requirements relating to MTBE
4. Acute Toxicity (Fathead Minnow, 24-hour), annually [see Special Condition A.(3.)].
Units: mg/L = milligrams per liter µg/1 = micrograms per liter
lbs./day = pounds per day MTBE = methyl tertiary butyl ether
The permittee shall discharge no floating solids or foam visible in other than trace amounts.
The permittee shall not discharge tank solids, tank bottom water, or the tank rag layer.
The permittee shall not discharge tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 1.19 µg/L and toluene concentration is less than 11 µg/L.

REASONABLE POTENTIAL ANALYSIS
Kinder Morgan
< NC0000795 >
Time Period 3/2003-7/2005
Ow (MGD) 0.242
7Q 10S (cfs) 0
7Q10W (cfs) 0
3002 (cfs) 0
Avg. Stream Flow, QA (cfs) 0
Rec'ving Stream UT East Fork Deep River
WWTP Class 1
IWC (%) 0 7010S 100
® 7Q 10W 100
@ 3002 100
QA 100
Stream Class WS-IV
Outfall 001
Ow = 0.242 MGD
TYPE
(1)
STANDARDS &
CRITERIA (2)
PCL
Units
REASONABLE POTENTIAL RESULTS
RECOMMENDED ACTION
PARAMETER
NCWQS/ !SPAY/
Punk Acute
n IDeL Max ProdCw Mom*
Phenols
A
ug/L
15 0
6.9
ute: N/A
_ _- _-_
Chronic. 1.0
_ _ _ ___ ___-_-_ _-_- _
All 15 values below detection. Recommend removal of limit,
Review atlocatiom of phenols to other 8 bulk storage plants,
1 N I)I.
• Legend:
C = Carcinogenic
NC = Non -carcinogenic
A = Aesthetic
" Freshwater Discharge
ti��rY+�irhq� � Its
erg
,,9,,i s .
795phenolrpa2005, rpa
11/9/2005

REASONABLE POTENTIAL ANALYSIS
12
13
Phenols
Date Data BDL=1/2DL Results
1 Jul-2005 < 10 5.0 Std Dev. 0.8797
2 Apr-2005 < 5 2.5 Mean 4.6667
3 Feb-2005 < 5 2.5 C.V. 0.1885
4 Dec-2004 < 10 5.0 n 15
5 Oct-2004 < 10 5.0
6 Sep-2004 < 10 5.0 Mult Factor = 1.3700
7 Jul-2004 < 10 5.0 Max. Value 5.0 ug/L
8 Mar-2004 < 10 5.0 Max. Pred Cw 6.9 ug/L
9 Dec-2003 < 10 5.0
10 Sep-2003 < 10 5.0
11 Aug-2003 < 10 5.0
12 Jun-2003 < 10 5.0
13 May-2003 < 10 5.0
14 Mar-2003 < 10 5.0
15 Apr-2003 < 10 5.0
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
795phenolrpa2005, data
- 1 - 11/9/2005

Kinder Morgan Phenols Data
Date Phenols Flow
JuI-05 <10 ug/I 0.239
Apr-05 <5 ug/I 0.178
Feb-05 <5 ug/I 0.129
Sep-04 <10 ug/I 0.264
Oct-04 <10 u g/I 0.131
Dec-04 <10 ug/I 0.191
JuI-04 <10 ug/I 0.193
Mar-04 <10 ug/I 0.233
Dec-03 <10 ug/I 0.279
Sep-03 <10 ug/I 0.357
Aug-03 <10 ug/I 0.268
Jun-03 <10 ug/I 0.400
Apr-03 <10 u g/I 0.229
Mar-03 <12.3 ug/I 0.299
Average 0.242

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NPDE Permitting Requirements for
Petroleum Bulk -Storage
Surface Storage Greater than One Million Gallons
2005 -- Permitting Strategy
Introduction / Background
North Carolina's Division of Water Quality issues individual, point -source NPDES permits for
stormwater to all vehicle -fuel and petroleum terminals with aboveground storage capacities exceeding
one million gallons. Storages exceeding this volume are specifically excluded from Stormwater
General Permit NCG080000, and therefore require a point -source discharge permit.
This document is intended to update the 2001 strategy for up -coming permit cycles. (For a history of
this permitting strategy, see the Division's 2001 Permitting Strategy: Permit Requirements for
Discharges from Oil and Petroleum Storage Facilities, version. 30Jul2001.)
Bulk -storage facilities typically retain and manage stormwater behind secondary -containment dikes.
Diked areas are designed with sufficient volume to confine product in the event of a tank failure.
Stormwater, often comprising several storm events, is held behind these dikes in proximity to the
tanks and appurtenant piping. The permittee typically holds this stormwater for controlled release.
Permitting Requirements
1. Flow -- Discharge Rate and Duration
Instructions to Permit Writer: Establish average and maximum flows for the previous cycle for the
purpose of calculating limits for various parameters of concern. These should be noted in the Fact
Sheet.
Stormwater flow in bulk -storage permits in limited. Flow measurements are required, however, and
methods shall reflect a typical controlled release discharge event. Flow shall be monitored, reported,
and recorded using one of four approved methods. The following instructions shall appear as a
footnote in permit section A.(1.) Effluent Limits and Monitoring Conditions:
"Flow shall be monitored with each discharge event — During periods of no
flow, the Permittee shall submit a signed, monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow may be monitored using any one of
four methods:
a) measure flow continuously;
b) calculate flow (see Rational Equation below) based on total rainfall per
unit area draining to the outfall; exclude built -upon areas (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."
Page 1 of 6
Version 27JuI 2005

%41"11 i4141
NPDED Permitting Requirements for
Petroleum Bulk -Storage
Surface Storage Greater than One Million Gallons
2005 -- Permitting Strategy
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.
2. Acute Toxicity.
Instructions to Permit Writer: Evaluate compliance to toxicity. Replace toxicity test, if different from
24-hr definitive, LC-50>100% (TAE6C); consider the following text for cover letter, as appropriate.
[Toxicity test methods have changed from your previous permit.] All Permittees shall monitor for
Acute Toxicity [Fathead Minnow (Pimephales promelas), 24-hr definitive (LC-50>100%)], at a
minimum, annually, but some facilities may not qualify. During the forthcoming permit cycle,
Permittees that fail to qualify for annual monitoring must test quarterly. These include:
• New facilities that have never monitored for acute toxicity,
• Facilities that monitored four or fewer discharge events for toxicity, or
• Facilities that monitored five or more discharge events, but did not "pass"
the five most recent, or did not produce LC-50 >100% in the most recent
five tests.
To restate, a permittee's five most recent toxicity tests must document "pass" or LC-50 > 100% to
qualify for annual monitoring. Qualified Permittees may apply to the Division to modify their
permit.
Rationale: Acute toxicity testing (as opposed to chronic testing) is deemed appropriate to evaluate
the end -of -pipe immediate impact of short-term, episodic discharges. All Permit Effluent Limitations
and Monitoring Conditions shall include the following footnote:
Page 2 of 6
Version 27JuI 2005

NPDE0 Permitting Requirements for
Petroleum Bulk -Storage
Surface Storage Greater than One Million Gallons
2005 -- Permitting Strategy
"The Permittee shall collect samples concurrently for Acute Toxicity and BTEX."
[Reference item 4. below] :
3. Total Suspended Solids (TSS) / Oil and Grease
Instructions to Permit Writer: Oil and Grease - Monitor monthly - No Limit
Instructions to Permit Writer: TSS - Monitor monthly; Daily Maximum Limit, 45.0 mg/l.
Monitoring Footnote: "Where possible, the grab sample for Oil and
Grease should be skimmed from the water surface of a quiescent (calm
water) zone."
Rationale: A daily maximum TSS limit of 45 mg/L is recommended as a minimum stormwater
management practice. Although historically, TSS and Oil and Grease have not been significant
problems in oil -terminal stormwater discharges. TSS and Oil and Grease are deemed good general
indicators of effluent stormwater quality for these facilities.
4. BTEX
Instructions to Permit Writer: Monitor monthly — No Limit.
If data indicate RP, add limit and monitor monthly.
Rationale: Benzene, toluene, ethylbenzene and xylene (BTEX) are common toxicants found in fuel
petroleum. Previous scans for volatile and semi -volatile compounds included BTEX (methods EPA
624/625). A review of these scans revealed BTEX frequently in stormwater, while other 624/625
parameters were uncommon or never detected. Therefore, future permits shall require BTEX
monitoring for lighter fuels and naphthalene for diesel fuel (see 6.).
5. Naphthalene (for Diesel)
Instructions to Permit Writer: Monitor monthly — No limit
Rationale: Naphthalene is commonly found in heavier fuels, such as fuel oil or diesel. Most bulk -
terminals store heavier fuels. (NOTE: If the permittee can demonstrate to the Division that its facility
does not now, nor has ever, stored diesel fuel or other heavy fuels, it may petition to remove this
requirement from the permit.)
Page 3 of 6
Version 27JuI 2005

NPDE, Permitting Requirements for
Petroleum Bulk -Storage
Surface Storage Greater than One Million Gallons
2005 -- Permitting Strategy
6. EPA Methods 624/625 (as applicable)
Instructions to Permit Writer: Conduct RPA on parameter "hits," but only those with NC stream
standards and /or federal criteria*.
• if RP, monitor monthly and add permit limit.
• if detected (but no RP), Monitor semi-annually.
• if no parameters detected other than BTEX, delete 624/625 from permit.
Rational: This strategy serves to resolve previous investigations into the need to conduct EPA
screening by test Methods 624/625. For Permittees assigned to conduct volatile and semi -volatile
scans who did not comply with the permit, assessment will be considered. RPA will be restricted to
parameters of concern (POC) with North Carolina State water quality standards and federal criteria.
*NOTE: the Permit Writer shall use aquatic life or Human Health standards as appropriate.
7. Tank Solids, Tank Bottom Water, and Rag Layer
Instructions to Permit Writer: Keep the footnote:
"Direct discharge of tank solids, tank bottom water, or the rag layer is not
permitted."
Rationale: Tank -bottom sediments accumulate over 4-5 years (typically V2- to 1-inch thick) and
invasive rainwater (1-6 inches thick) regularly settles to the bottom of any bulk -storage container.
These layers typically mix at the interface with overlying fuel to form a 3/4-inch-thick foamy waste
called a "rag layer." Because of the relatively high levels of hydrocarbon compounds contained in
these three wastes layers, their untreated discharge is not permitted.
8. Hydrostatic Tank Testing
Instructions to Permit Writer: Keep the footnote:
The permittee shall not discharge tank solids, tank bottom water, or the
tank rag layer. The permittee shall not discharge tank (or pipe) contents
following hydrostatic testing unless benzene concentration is less than
1.19 µg/L and toluene concentration is less than 11 pg/L.
Rationale: As routine container maintenance, bulk -storage Permittees typically conduct hydrostatic
tank testing every five to six years. Prior to testing, the Permittee empties the tank of product, and
properly disposes of tank -bottom wastes (see 7. above). Tanks are cleaned, coated, and welded (as
Page 4 of 6
Version 27JuI 2005

i11Qi1 r"'•
NPDE.. Permitting Requirements for
Petroleum Bulk -Storage
Surface Storage Greater than One Million Gallons
2005 -- Permitting Strategy
necessary), then refilled with water for hydrostatic pressure testing. Some facilities use stream or lake
water, while others use potable city water. Testing water is then drained from the tank.
Because this test -water may contain hydrocarbons or other toxicants, the Permittee shall sample and
analyze this waste prior to direct discharge. Should benzene, toluene, and/or other parameter levels
exceed their respective water quality standard, direct discharge of this waste is not permitted.
Permitting Special Considerations
9. Methyl Tertiary Butyl Ether (MTBE) in Water Supply (WS) Waters
Instructions to Permit Writer: Continue monitoring monthly in all permits. If no hits, consider
lowering monitoring frequency to quarterly. Document database in Fact Sheet.
Rationale: In 2001, the EPA tagged MTBE as a potential human carcinogen. North Carolina
responded to EPA's ongoing evaluations of this "anti -knock" additive by implementing efforts to limit
MTBE in discharges to water supply (WS) waters. Although North Carolina has not yet adopted a
water quality standard for MTBE, monitoring of this potential human health risk will continue in order
to provide data for future evaluation.
10. Benzene in Water Supply (WS) Waters
Instructions to Permit Writer: Monitor: monthly. Evaluate RP using Human Health Standard 1.19 /rglL
• If RP, add limit: Daily Max -1.19 /rglL (allow dilution using "annual average" flow)
• If no RP, delete limit; continue monitoring monthly.
Rationale: Benzene is identified as a human carcinogen and therefore poses potential health risk to
drinking water. Therefore, a limit of 1.19 pg/L (Water Quality Standard) shall apply to all WS-
classified waters. The Division shall consider dilution i.e., multiply this standard time dilution under
"average annual flow" conditions to calculate the permit limit. If the permittee discharges under "zero -
flow" conditions, the standard shall become the permit limit.
Page 5 of 6
Version 27JuI 2005

NPDE,, Permitting Requirements for
Petroleum Bulk -Storage
Surface Storage Greater than One Million Gallons
200E -- Permitting Strategy
11. Phenol in Water Supply (WS) Waters
Instructions to Permit Writer: Monitor: monthly. Evaluate "drainage -specific" RP. * See attached
revised guidance calculations for the Paw Creek area (total: 8 dischargers), Memorandum from Joe
Corporon, July 27, 2005.
• If RP, add limit: Daily Maximum distributed equally among all outfalls showing RP.
• If no RP, delete limit (as appropriate); continue monitoring monthly.
The Division shall determine permit limits by "reasonable potential" based on a NC State standard for
chlorinated phenolic compounds of 1 µg/L. The Division shall evaluate each permittee's "reasonable
potential" using drainage -specific calculations for allowable phenol loading. This strategy dates from
the 1980s [see Division memos for Guilford County (1983); updated calculations governing
dischargers to the Catawba River Basin (2001) and Cape Fear River Basin (2003)].
Rationale: Discharges from fuel hydrocarbon bulk -storage facilities have a potential to contain
phenol, based on previous data statewide. Phenol, when combined with chlorine, forms chlorinated
phenolic compounds with potential to taint fish tissue and drinking water, thus degrading taste and
odor (organoleptic issues). As a result, permittees with discharges to WS waters shall monitor'
effluent phenol on a monthly basis.
12. Turbidity Monitoring
Instructions to Permit Writer:
• if detected, Monitor Quarterly
• if not detected, delete from permit.
• If RP exists (based on 50 NTU) - add limit and Monthly monitoring.
0+1
Rationale: EPA questioned the potential of these facilities to violate stream standards because little
data were available. Sufficient data now exists to evaluate "reasonable potential" for a facility to
exceed 50 NTU. The Permit writer shall use the entire permit cycle database (for those monitoring
quarterly), and the most recent two years of data (for those monitoring monthly). For all facilities, the
following shall appear on the Effluent Limitations and Monitoring page as a footnote:
"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."
Page 6 of 6
Version 27JuI 2005

KINDER --MORGAN
SOUTHEAST TERMINALS
June 20th, 2005
VIA CERTIFIED MAIURRR
Mr. Alan W. Klimek, "E., Director
NCDENR
Division of W.. er Quality
1617 Mail ' ervice Center
Raleigr, NC 27699-1617
RE: Kinder Morgan Southeast Terminals LLC (KMST)
6907 W. Market Street
Greensboro, NC 27419
NPDES Permit Number: NC 0000795
Dear Mr. Klimek:
LLC.
Pursuant to Note 3, Part A (1) of the above -referenced permit, I am writing to request that the sampling
requirement for phenol and its associated limit of 0.0003 Ibs/day be deleted from the permit. I have
enclosed a substantial amount of information demonstrating that phenol has not been detected in the
facility's effluent. I have also enclosed a letter dated September 10, 2003 from ExxonMobil (the prior
owner of the facility) to the Division of Water Quality that further supports the absence of phenol in the
facility's effluent.
If you require any additional information in support of this request or have any questions, please do not
hesitate to contact me at [phone]. I look forward to working with the Division of Water Quality on
this matter.
incerely,
' Matthew E. Marra
Senior Engineer
cc: Jerry Aycock/KMST Files
Barry Furr
Cliff McCowan
Jeff Neal
Enclosure
c;... �::. _w �' ass='• `3ri� se N w+at Ma4.�,
f
J U N 2 7 2005
DENR - WATER QUALITY
POINT SOURCE BRANCH
1435 Windward Concourse, Alpharetta, GA 30005 770-751-4000 770-751-4230 - Fax

9/03
10/03
11/03
12/03
1/04
2/04
3/04
4/04
5/04
6/04
7/04
8/04
9/04
10/04
11/04
12/04
Non -Detect
No Discharge
No Discharge
Non -Detect
No Discharge
No Discharge
Non -Detect
No Discharge
No Discharge
No Discharge
BQL <0.0019 lbs.
No Discharge
BQL <10.0 Ug/I
BQL <10.0 Ug/I
No Discharge
BQL <10.0 Ug/I
1/05 No Discharge
2/05 BQL <10.0 Ug/I
3/05 No Discharge
4/05 BQL <0.0009 lbs.
5/05 No Discharge
dorry
Historical Phenol Results
Kinder Morgan Southeast Terminals LLC
Greensboro Terminal
6907 W. Market Street
Greensboro, NC 27419
NPDES Permit Number NC0000795
Phenol EPA 625
Phenol EPA 625
Phenol EPA 625
Phenol EPA 625 (Starts Research & Analytical
Sampling/Testing)
Phenol EPA 625
Phenol EPA 625
Phenol EPA 625
Phenol EPA 625
Phenols/Parameter #34694
?log' No DI'I,v-
ifror eisawyttrify a9
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