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HomeMy WebLinkAboutNC0000795_Permit (Issuance)_20011217NPDES DOCIMENT SCANNIN` 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: December 17, 2001 This' document is printed on reuse paper - ignore any content on the reiirerse side Michael F. Easley Govemor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources Gregory J. Thorpe, Ph. D., Acting Director Division of Water Quality December 17, 2001 Harold Cramer, Vice President ExxonMobil Oil Corporation P.O. Box 18363, Greensboro, North Carolina 27419 Subject: FINAL -- NPDES Permit No. NC0000795 ExxonMobil, Greensboro Terminal 6907 West Market Street Guilford County Dear Mr. Cramer: This letter transmits your Final NPDES individual discharge permit for the above referenced facility. ExxonMobil's comments on the draft permit (November 7, 2001) regarding system components and flow -measurement methods have been reviewed and included. Please review this draft carefully to ensure thorough understanding of the information, conditions, and requirements of dischargers to water supply (WS) waters contained therein. The Division of Water Quality (the Division) has revised permitting strategies and Standard Operating Procedures (SOP) for this and all bulk -storage petroleum facilities and terminals in North Carolina. As part of permit renewal, the Division has also conducted EPA -required Reasonable Potential Analysis (RPA) on this facility's effluent data to determine the "reasonable potential" for identified parameters to exceed North Carolina in -stream Water Quality Standards and/or federal criteria. The following summarizes changes to your previous permit in compliance with the new 2001 SOP. BTEX. The permittee is now required to monitor monthly for BTEX (benzene, toluene, ethyl benzene and xylene) parameters. Please note that these replace the requirement for EPA Method 624. No parameters have discharge limits because the RPA "maximum predicted" for each parameter did not exceed its "allowable concentration" based on data submitted. EPA Methods 624/625. Method 624 has been eliminated from facility monitoring if it did not detect compounds other than BTEX. However, because the majority of facilities now store, or have stored in the past, heavy -component fuels such as fuel oil and diesel, the Division has retained EPA Method 625 monitoring to detect naphthalene and related indicators of middle distillate compounds commonly found in these heavier fuels. Should the permittee wish to document that the subject facility does not now, nor has ever stored heavier -component fuels, the Division will consider a request to discontinue this monitoring. Phenol. The Division has reviewed ExxonMobil's written comments on the draft permit concerning phenol. ExxonMobil has argued that the permit limit of 0.003 lbs./day is impractical because it is not achievable by current analytical technology. Please understand that the environment dictates the permit limit, not the laboratory. Water -quality based permit limits are established independent of any test -method' practical quantitation limit (PQL). ATA NCDENR N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Customer Service • 1 800 623-7748 ExxonMobil Oil Corporation ExxonMobil, Greensboro Terminal NPDES Permit NC0000795 Page 2 In the absence of a Division -specified PQL, most bulk -storage facilities have submitted data using 5.0 to 10.0 µg/L — some as low as 1.0 µg/L for phenol. However, because ExxonMobil has no record of detecting phenol (albeit at a PQL of 50 µg/L), the Division will suspend compliance to this phenol limit for one (1) year from the permit effective date so that the permittee may establish the required database (see Effluent Limits and Monitoring Requirements). If phenol is not detected at the lowest limit of technology, the Division will consider the permittee's request to remove the phenol limit. ExxonMobil has suggested that phenol is not persistent in surface waters and that the Division limit chlorinated phenol rather than phenol. However, the Division has not received conclusive evidence that phenol biodegrades readily in the receiving stream. ExxonMobil has potential to discharge phenol and therefore the Division must apply phenol limits at the discharge. Moreover, dilution must be applied at some point appropriate to the water supply intake, not at the point of discharge (refer to the rationale provided in the 2001 SOP). MTBE is a gasoline component recently identified by the EPA as a potential human carcinogen. Therefore, monthly monitoring has been added to this and all oil -terminal permits discharging to WS waters within the state. After collecting additional data, ExxonMobil may request the Division to reduce the MTBE monitoring frequency (See Special Condition A. 2.). Granting this request shall constitute a minor modification to the NPDES permit. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing upon written request within thirty (30) days after receiving this letter. Your request must be in the form of a written petition conforming to Chapter 150B of the North Carolina General Statutes, and must be filed with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. This permit is not transferable except after notifying the Division of Water Quality. The Division may require modification, or revocation and re -issuance of this permit. Please notice that this permit does not affect your legal obligation to obtain other permits required by the Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or other federal or local governments. If you have questions, or if we can be of further service, please call Joe Corporon at (919) 733-5083, extension 597. Respectfully, Original Signed By David A. Goodrich Gregory J. Thorpe, Ph.D. Enclosure: NPDES Permit NC0000795 cc: Central Files Winston-Salem Regional Office, Water Quality Section NPDES Unit; Point Source Compliance and Enforcement Unit Technical Assistance and Certification Unit Aquatic Toxicology Unit Permit NC0000795 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution Control Act, as amended, ExxonMobil Oil Corporation is hereby authorized to discharge wastewater from outfalls located at the ExxonMobil, Greensboro Terminal 6907 West Market Street, Greensboro Guilford County to receiving waters designated as an unnamed tributary of East Fork of the Deep River within the Cape • Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. This permit shall become effective February 1, 2002. This permit and authorization to discharge shall expire at midnight on August 31, 2006. Signed this day December 17, 2001. Original Signed By David A. Goodrich Gregory J. Thorpe, Ph.D., Acting Director Division of Water Quality By Authority of the Environmental Management Commission 4 Permit NC0000795 SUPPLEMENT TO PERMIT COVER SHEET ExxonMobil Oil Corporation is hereby authorized: 1. to continue discharging storm water from the existing water pollution control system consisting of • bermed secondary -containment areas (drain to lined settling pond) • truck loading -racks (drain to oil / water separator, then to lined settling pond) • vapor recovery unit (drains to oil / water separator, then to lined settling pond) • pump manifold (drains to oil / water separator, then to lined settling pond) • pump -back area (drains to oil / water separator, then to lined settling pond) • hydrostatic testing of tanks and pipes (drains to oil / water separator, then to lined settling pond) • fire -suppression system testing (drains to oil / water separator, then to lined settling pond) • driveway rinse down (drains to oil / water separator, then to lined settling pond) • Settling Pond (drains to UT of East Fork of the Deep River via a totalizing flow meter or other Division -approved flow recording device or method) located at the ExxonMobil, Greensboro Terminal, 6709 West Market Street, Greensboro, Guilford County, and 2. to discharge from said treatment facility through Outfall 001 at a specified location (see attached map) into an unnamed tributary (UT) of the East Fork of the Deep River, a waterbody classified as WS-IV waters within the Cape Fear River Basin. ExxonMobil Oil Corporation Greensboro Terminal Latitude: 36° 04' 34" N State Grid/Quad: C 19 SW / Guilford, NC Longitude: 79° 55' 42" W Permitted Flow: Episodic -- not limited Stream Class: WS-IV Drainage Basin: Cape Fear River Basin Receiving Stream: UT of E. Fork Deep River Sub -Basin: 03-06-08 Facility Location -- not to scale North NPDES Permit No. NC0000795 Guilford County Permit NC0000795 7 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 CHARACTERISTICS LIMITS MONITORING REQUIREMENTS Sample Type Sample Location Monthly Average Daily Maximum Measurement Frequency Flowl Episodic 1 Effluent Total Suspended Solids 45.0 mg/L Monthly Grab Effluent Oil and Grease2 Monthly Grab Effluent Phenol 0 0.003 lbs./day3 Monthly Grab Effluent Benzene Monthly Grab Effluent Toluene Monthly Grab Effluent Ethyl Benzene Monthly Grab Effluent Xylene • Monthly Grab Effluent EPA 625 2/Year Grab Effluent MTBE4 Monthly Grab Effluent Acute Toxicity5 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. Phenol — Compliance to this limit shall begin one (1) year from the permit effective date. The Division will consider a request to remove this limit if the permittee submits additional data (minimum 12 data points) for Reasonable Potential Analysis. Permittee shall contact a North Carolina -certified laboratory to establish a minimum Practical Quantitation Limit (PQL) for phenol. 4. MTBE — See Part A.(2.) for other requirements relating to MTBE 5. 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. 1 Permit NC0000795 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (2.) MTBE MONITORING For the protection of public health, oil terminals discharging to waters classified as water supplies ("WS" waters) shall adhere to the following action plan: 1. Monthly monitoring for MTBE (except as modified under 2.) is required for the duration of the permit [See Part A. (1.)]. 2. After a one-year Test Period of monthly monitoring or after twelve (12) discharge events have been sampled and analyzed, the Permittee shall review MTBE data. If MTBE is not detected, the facility may request the Division to reduce the MTBE monitoring frequency. Granting this request shall constitute a minor modification to the NPDES permit. 3. If MTBE is detected during the Test Period, the Permittee shall submit an MTBE Reduction Plan. This plan may include site -specific Best Management Practices (BMPs) or engineering solutions. A copy of this plan shall be submitted to: North Carolina Division of Water Quality Water Quality Section Attn: NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 4. The Division anticipates that an MTBE regulatory criterion or Water Quality Standard will be established during the coming permit cycle. For the next cycle of permit renewals, the Division expects to apply this criterion or standard to MTBE data collected during this permit cycle. Should the permittee's MTBE data indicate discharge in excess of this criterion or Water Quality Standard, an MTBE limit will be added to the permit monitoring requirements at renewal. 4 Permit NC0000795 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (3.) ACUTE TOXICITY MONITORING (ANNUAL) The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste treatment. The permittee will conduct one test annually, with the annual period beginning in January of the calendar year of the effective date of the permit. The annual test requirement must be performed and reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this date. Toxicity testing will be performed on the next discharge event for the annual test requirement. The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemicallphysical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re- opened and modified to include alternate monitoring requirements or limits. NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control organism survival and appropriate environmental controls, shall constitute an invalid test and will require immediate follow-up testing to be completed no later than the last day of the month following the month of the initial monitoring. ExxonMobil Refining and Supply Company Greensboro Terminal 6907 West Market Street Greensboro, NC 27409 November 7, 2001 Mr. Joe R. Corporon, P.G. North Carolina Department of Environment and Natural Resources Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Draft NPDES Permit No. NC0000795 ExxonMobil Oil Corporation Greensboro Terminal 6907 West Market Street, Greensboro, NC Dear Mr. Corporon: EonMobil Refining & Supply CD ExxonMobil appreciates this opportunity to submit comments on the draft NPDES permit proposed for our Greensboro, NC terminal. Our comments are divided into general comments and comments on the proposed phenol limit. General Comments 1. Description of Activities: the description of the facility and the location of the discharge on the supplement to the cover sheet are different from the description included in the existing permit and do not completely represent the facility. Specifically, stormwater and wastewater are discharged from the following sources: stormwater runoff from the bermed tank field and containment areas including the loading rack, the v por recovery unit, the pump manifold, and the pump -back area; h droy� static test�ing_of tanks and pipes; testes of the fire suppression system; and, driveway rinse down. Sources other than the tank field flow through an oil/water separator. The separator and the tank field flow to a lined collection basin, which discharges into an unnamed tributary of the East Fork of the Deep River. Please modify the description to reflect these comments or use the description from the existing permit. 2. Footnote 1 under A (1): this footnote states that method (b), calculation of flow based on rainfall, is the best method for facilities with a large run-off collection pond. However, the recently issued permit for the ExxonMobil Charlotte terminal (NC0004839) includes a footnote that states that the same methochould not be used fnr f cilities ith large runo -cff ollecTion ponds,/� In aion, non the listed met)'iods for calcu atton of flow eciftcally describes the use of a which is the method presently used fo onitoring flow at this facility as identifi in the current permit ease modi is footnote indicate that a totalizing flow meter is us to monitor flow at this facilt /or coaC F 4 641,6 v.c, Lkt (le Er Mr. Joe R. Corporon, P.G. November 7, 2001 Page 2 of 2 3. Footnote 2 under A (1): this footnote, which states that the oil and grease sample should be collected from the surface of the quiescent zone, is not applicable for this facility, where the discharge occurs from a bottom draw discharge pipe. This footnote should be removed. Proposed Phenol Limitation Although phenol has not previously been detected at this facility, a limitation has been imposed in the draft permit. This limitation should be removed for the following reasons. 1. As described in the permit, the phenol limitation is a monthly average mass limit. According to Part II, Section A (5) (a) of the permit, the monthly average discharge is defined as the total mass of all daily discharges sampled and/or measured during a calendar month on which daily discharges are sampled and measured, divided by the number of daily discharges sampled and/or measured during such month. According to Part I (A) (1) and footnote 3, phenol is to be measure once per month with a minimum practical quantitation limit (PQL) of 0.01 mg/L. However, when multiplied by the average daily flow since 1998 of 0.06 mgd, the monthly average discharge with a phenol result of <0.01 mg/L is equivalent to <0.005 lb/day, which is higher than the limit of 0.003 lb/day. It is therefore not practical to limit phenol in this manner. Additionally, although phenol has not been detected at this facility, the decision to impose a limitation was based on a reasonable and .potential analysis (RPA) employing one half of the historical detection limit, which was mostly 0.05 mg/L since neither a PQL nor a specific EPA Method was required by the existing permit. However, as the above analysis demonstrates, treating phenol in this manner imposes impractical limitations. A more practical approach would be to require regular monitoring of phenol with a minimum PQL of 0.01 mg/L. Based on the results of additional monitoring, another RPA could be performed. 2. The necessity of a RPA for phenol was based on 15A NCAC Chapter 2, Subchapter 2B, Section 0.0216(3)(d). This regulation references chlorinated phenols as the technical basis for the 1 µg/L criterion. However phenol, unlike chlorinated phenol, biodegrades readily, is not persistent in surface water, and has not been demonstrated to contribute to equivalent concentrations of chlorinated phenol during water treatment. Chlorinated phenol and not phenol should therefore be limited. Finally, the water balance calculations did not include the effects of dilution in the reservoir. However, dilution will occur in the reservoir, due to other discharges, and due to upstream flows. Based on these reasons and the preceding comments, the phenol limitation should be removed. Thank you again for the opportunity to provide comments. We look forward to your response and would be willing to meet to discuss the comments on the phenol limitation, if necessary. Please contact Jim Hesser, terminal superintendent, at 336-855-4461, and advise whether a meeting will be required. Sin +erely, t►� Steve D. in, P.E. Environmental Advisor Facility Name = EXXON CO, USA -- GREENSBORO Parameter = Phenol NPDES # = NC0000795 Standard = 2.37 µg/l Qw (MGD) = 1.05 7Q10s (cfs)= 0 Date n < Actual Data BDL=1/2DL IWC (%) = 100.00 Jan-98 1 < 50 25 Feb-98 2 < 10 5 FINAL RESULTS Apr-98 3 < 50 25 Phenol May-98 4 < 50 25 Max. Pred Cw 38.0 Aug-98 5 < 50 25 Allowable Cw 0.0 Oct-98 6 < 50 25 Jan-99 7 < 50 25 Apr-99 8 < 50 25 RESULTS Jul-99 9 < 50 25 Std Dev. 5.5470 Sep-99 10 < 50 25 Mean 23.5 Oct-99 11 < 50 25 C.V. 0.2364 Feb-00 12 < 50 25 Apr-00 13 < 50 25 Number of data points 13 HITS none @ 50ugL Mult Factor = - 1.52 Max. Value 2 1 Max. Pred Cw 38.0 µ 1 "reasonable potential" dictated by inappropriate PQLs Allowable Cw 2.3 f gll Add note to cover letter. ,r► 504 L(1,9D, (-) GL �y eg) ExxonMobile — Greensboro, NC0000795 Page 4 wasteload allocation was distributed equally among phenol dischargers as a permit limit, only as each facility's data -set showed reasonable potential to exceed the water quality stream standard. Currently nine (9) bulk storage facilities discharge to either the East Fork Deep River or Long Branch. The confluence of these two drainages was assumed to approximate the headwaters of High Point Lake, the nearest downstream intake waterbody. For purposes of yield calculations, Long Branch was assumed to have a similar runoff coefficient as the East Fork of the Deep River. The Division used published 30Q2 flows from an EPA stream gauge (02099000) located on the East Fork Deep River near the confluence of the two drainages. The 30Q2 flow, not the 7Q10, was deemed appropriate because of the aesthetic standard for phenol. Flow Calculations: Given: Flow (30Q2) East Fork Deep River = 3.8 cfs (USGS Gauging Station) Drainage Area East Fork Deep River = 14.8 mil (USGS) Drainage Area Long Branch = 3.84 mi2 (measured from USGS topo) Total Drainage Area = 14.8 mi2 + 3.84 mi2 = 18.6 mil Yield = East Fork Flow (cfs) East Fork Drainage Area (mi2) = 3.8 cfs 14.8 mil = 0.257 cfs/mi2 Therefore: Total Flow = Yield x Total Drainage Area 0.257 cfs/mil x 18.6 mi2 4.7 cfs Phenol Wasteload Calculation: 4.7 cfs x 0.001 mg/L x 8.34 = 0.025 lbs./day distributed among nine 1.55 dischargers = 0.025 lbs./day 9 dischargers Phenol Limit = 0.003 lbs./day per discharger Because the permittee reported phenol using a Practical Quantitation Level (PQL) of <50 µg/L, there is "reasonable potential" due to the insensitivity of the analytical testing. In the absence of data at a PQL of <10 µg/L, the Division has imposed a phenol limit 0.003 lbs./day as a Monthly Average. A footnote will be added to the permit alloying the permittee to collect additional phenol data (minimum 12 data points) and petition for a new RPA. A minimum PQL of <10 µg/L will be specified for all future analyses consistent with other facilities governed by the 2001 SOP discharging to WS waters. Fact Sheet Renewal -- NPDES NC0000795 Page 4 State of North Carolina Department of Environment and Natural Resources Division of Water Quality Michael F. Easley, Governor William G. Ross, Jr., Secretary Gregory J. Thorpe, Ph.D., Acting Director MEMORANDUM To: From: Subject: October 10, 2001 Lee Spencer NC DENR / DE1-I / Regional Engineer Winston-Salem Regional Office Joe Corporon NPDES Unit Review of Draft NPDES Permit NC0000795 ExxonMobile — Greensboro Terminal Guilford County A7A NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES RECEIVED N.C. Dept. of ENR OCT 122001 Wii Please indicate below your agency's position or viewpoint on the draft permit and return this form by November 9, 2001. If you have any questions on the draft permit, please contact me at the telephone number or e-mail address listed at the bottom of this page. NVAN ww/ivwwww/ivwwwwwwwwvVAN 'wwwwwwwwwww/VVANA ANANNNViAwAiv NANANi RESPONSE: (Check one) R.----- Concur with the issuance of this permit provided the facility is operated and maintained properly, the stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water quality standards. Concurs with issuance of the above permit, provided the following conditions are met: Opposes the issuance of the above permit, based on reasons stated below, or attached: Signed Date: 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES 919 733-5083, extension 538 (fax) 919 733-0719 Christie.Jackson@ ncmail.net DENR / DWQ / NPDES Unit FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES Permit No. NC0000795 INTRODUCTION ExxonMobil Oil Corporation, (herein referred to as ExxonMobil or the permittee), formerly permitted as Exxon Company, USA, requires a National Pollutant Discharge Elimination System (NPDES) permit to dispose treated wastewater to the surface waters of the state. The Permittee's 5-year NPDES permit has expired and they have requested renewal from the Division of Water Quality (the Division). This Fact Sheet summarizes background information and rationale used by the Division's NPDES Unit to determine permit limits and conditions. This document also contains references to information sources relevant to this permit renewal (superscripted numbers in order of appearance, See References). FACILITY RECORDS REVIEW Facility Description. ExxonMobil (Table 1) operates the ExxonMobil, Greensboro Terminal, a petroleum bulk -storage and fuel -distribution center in Guilford County. Discharge from the facility consists of stormwater runoff controlled by a Water Pollution Control System consisting of: truck -loading rack drains; oil/water separator; waste holding tank with optional offsite disposal; gravity drains to dike containment areas; and discharge control valves. Discharge travels to a drainage ditch, then to an unnamed tributary (UT) to the East Fork of the Deep River. Table 1. ExxonMobil — Water Pollution Control System Facility Information Applicant/Facility Name 1,2 ExxonMobil Oil Corporation / ExxonMobil, Greensboro Terminal Applicant Address 1,2 P.O. Box 18363, Greensboro 27419 Facility Address 1,2 6907 West Market Street, Greensboro 27409 Permitted Flow (MGD) 43 Not limited Type of Waste 1,2,4 Industrial runoff wastewater. SIC Code 5171 WW Code Prim. 37; Second. 39; Facility/Permit Status 1,2,4 Class I, Minor / Renewal Drainage Basin / County 1'2 Cape Fear / Guilford Miscellaneous 3 Receiving Stream 4 UT of the East Fork of the Deep River Regional Office Winston - Salem Stream Classification 1'5 WS-IV State Grid / USGS Topo Quad° C 19 SW / Guilford, NC 303(d) Listed? 6 Not listed Permit Writer Joe R. Corporon Subbasin 5 03-06-08 Date: 080ct01 Drainage Area (sq. mi.) 1 Lat. 36° 04' 34" Long. 79° 55' 42" Summer 7Q10 (cfs) 3'7 0.0 Winter 7Q10 (cfs) 3'7 0.0 30Q2 (cfs) 3'7 0.0 Average Flow (cfs) 3'7 0.0 IWC(%)3'7 100 Fact Sheet Renewal -- NPDES Permit NC0000759 Page 1 This permit became effective August 1, 1996 (with an expiration date of March 31, 2001). The Division extended the expiration date (to stager the renewal workload) to expire August 31, 2001.1,2 On February 1, 2001, the Division received the Permit Renewal/Change of Ownership documents (Exxon Company, USA became ExxonMobil Oil Corporation.) and the name change was acknowledged on October 2, 2001. Waste Load Allocation (WLA). The Division reviewed the WLA in April 1991 and developed effluent limits and monitoring requirements based on an in -stream waste concentration (IWC) of 100% (zero -flow stream). The Division judges these limits and monitoring requirements to be appropriate for this renewal with the exception of additions and deletions listed below (see PERMITTING APPROACH SUMMARY). Verifying Existing Stream Conditions. This facility discharges to a "zero -flow" stream, an unnamed tributary (UT) of the East Fork of the Deep River, a Class WS-IV NSW stream within the Cape Fear River Basin. East Fork of the Deep River is not listed as an "impaired" waterbody [not 303(d) listed].6 COMPLIANCE REVIEW Discharge Monitoring Reports (DMR) -- Effluent Data Review. DMRs were reviewed from January 1997 through July 2001.9 Discharges from Outfall 001 occurred episodically, but approximate 2 to 8 monthly — non -discharge months reported as "no flow." The permittee reported a maximum discharge of 1.050 MGD (September 2000). Therefore, this flow was used for reasonable potential calculations (see below). Monitoring parameter and Reasonable Potential Analysis (RPA) results are summarized in Table 2: Table 2. ExxonMobil -- DMR Review Summar Parameter Samples (n Hits (n) High Mean RP* yln Comments / Action Flow 47 -- 1.050 MGD -- -- High used for RPA Benzene 13 0 -- -- No One (1) test @ PQL <50 Toluene 8 0 -- -- No -- Ethyl benzene 8 0 -- -- No -- Xylene 8 0 -- -- No -- Phenol 13 0 -- -- Yes (?) Test PQL @ 50 µg/1 judged insufficient. Added permit limit. Note to cover letter. Oil & Grease 13 1 2.10 mg/L 0.542 mg/L No BPJ Standard 30 mg/L Eight (8) Added Phenols 8 0 -- -- -- -- TOX (1998 — 2001) 4 (annual) -- -- -- -- All "pass" EPA 624/625 8 0 -- -- -- Retain 625 Delete 624 *RP mg/L µg/l = "Reasonable Potential" to exceed in -stream Water Quality Standard. = milligrams per liter = micrograms per liter Fact Sheet Renewal -- NPDES NC0000795 Page 2 0 w. Based on the Division's our review of the DMRs, twice -annual EPA 624/625 scans did not detect semi -volatile or volatile organic compounds. Total suspended residue (TSR) results do not exceed recommended levels (one-year average 9.47 mg/L; maximum reported 14.4 mg/L, July 1999). Notices of Violation (NOVs). No NOVs were issued to this facility during this permit cycle. Facility Inspections. Due to staff shortages and regional priorities, this Class I Stormwater Treatment System has been assigned lower priority relative to other discharge systems, however starting this permit cycle, the Winston-Salem Regional Office has scheduled regular annual inspections for this and all bulk -petroleum storage facilities in the Greensboro area.'° Whole Effluent Toxicity (WET) Test. The facility has passed its annual acute toxicity test for four (4) years, from 1998 through year 2001. PERMITTING STRATEGY Revised Standard Operating Procedures (SOP). The Division of Water Quality has revised permitting strategies and SOP for this and all oil terminals in the state.8 A new document has been generated by the NPDES Unit entitled, "Standard Operating Procedures — Permit Requirements for Discharges from Oil and Petroleum Storage Facilities" (based on a 1996 SOP). This document, hereafter referred to as the 2001 SOP, addresses issues and delineates monitoring frequencies and permit limits for contaminants commonly found at these facilities. Summary of Compliance Under 2001 SOP. Under the 2001 SOP, flow monitoring will be changed from "monthly" to "episodic" (Parts L.A.). This facility's effluent data shall be evaluated for compliance with acute toxicity, TSS, and oil and grease (Parts L.B. through I.D.). In place of EPA Methods 624/625 monitoring requirements, and/or eight (8) chlorophenols specified in a previous permit, the permittee shall now monitor monthly for total phenolic compounds only (Phenols -- Part I.E.), as required for all WS (water supply) waters. Monthly monitoring shall include benzene, toluene, ethyl benzene, and xylene (BTEX — Part MLA.). The Division shall also require monthly monitoring for MTBE (2001 SOP Part 1.1.) considering WS waters. 8 Footnotes to the Effluent Limits and Monitoring Requirements page shall reflect no direct discharge of tanks solids, tank bottom water, or the tank rag layer. Footnotes also stipulate no direct discharge of hydrostatic test water if benzene and/or toluene concentrations exceed their respective water quality standard (2001 SOP, Parts I.G. and LH). Phenol — Monitoring and Limits Calculations. When combined with chlorine, phenol can cause taste and odor (organoleptic) problems in drinking water, and can also result in the tainting of fish tissues. Therefore, in accordance with the 2001 SOP, all dischargers to state water supply (WS) waters shall conduct monthly effluent monitoring for total phenol. Moreover, if analytical results suggest "reasonable potential," a phenol limit shall be included in the permits A phenol limit magnitude depends on dilution. Ideally dilution would be calculated at the High Point Dam water plant intake where chlorine is introduced, but it is impractical at this time to measure dilution under lake conditions at the intake. Therefore, the Division calculated flow at the assumed headwaters of this water supply. Secondly, the Division used 1 µg/L (the aesthetic limit for phenol) to calculate a wasteload allocation in pounds per day (lbs./day) at these headwaters. Finally, the Fact Sheet Renewal -- NPDES NC0000795 Page wasteload allocation was distributed equally among phenol dischargers as a permit limit, only as each facility's data -set showed reasonable potential to exceed the water quality stream standard. Currently nine (9) bulk storage facilities discharge to either the East Fork Deep River or Long Branch. The confluence of these two drainages was assumed to approximate the headwaters of High Point Lake, the nearest downstream intake waterbody. For purposes of yield calculations, Long Branch was assumed to have a similar runoff coefficient as the East Fork of the Deep River. The Division used published 30Q2 flows from an EPA stream gauge (02099000) located on the East Fork Deep River near the confluence of the two drainages. The 30Q2 flow, not the 7Q10, was deemed appropriate because of the aesthetic standard for phenol. Flow Calculations: Given: Flow (30Q2) East Fork Deep River = 3.8 cfs (USGS Gauging Station) Drainage Area East Fork Deep River = 14.8 mil (USGS) Drainage Area Long Branch = 3.84 mi2 (measured from USGS topo) Total Drainage Area = 14.8 mi2 + 3.84 mi2 = 18.6 mi2 Yield = East Fork Flow (cfs) East Fork Drainage Area (mi2) = 3.8cfs 14.8 mil 0.257 cfs/mi2 Therefore: Total Flow = Yield x Total Drainage Area 0.257 cfs/mi2 x 18.6 mi2 4.7 cfs Phenol Wasteload Calculation: 4.7 cfs x 0.001 mg/L x 8.34 = 0.025 lbs./day distributed among nine 1.55 dischargers 0.025 lbs./day 9 dischargers Phenol Limit = 0.003 lbsJday per discharger Because the permittee reported phenol using a Practical Quantitation Level (PQL) of <50 µg/L, there is "reasonable potential" due to the insensitivity of the analytical testing. In the absence of data at a PQL of <10 µg/L, the Division has imposed a phenol limit 0.003 lbs./day as a Monthly Average. A footnote will be added to the permit alloying the permittee to collect additional phenol data (minimum 12 data points) and petition for a new RPA. A minimum PQL of <10 µg/L will be specified for all future analyses consistent with other facilities governed by the 2001 SOP discharging to WS waters. Fact Sheet Renewal -- NPDES NC0000795 Page 4 Summary of Reasonable Potential Analysis (RPA). The Division conducted an EPA -mandated RPA on ExxonMobil's reported data for BTEX, total phenols, and oil and grease (O&G). Results indicate no "reasonable potential" for BTEX and O&G parameters, however there is "reasonable potential" for phenol to exceed in -stream Water Quality Standards. Therefore, the allocation of 0.003 lbs./day phenol will be included as a permit limit, per the 2001 SOP. PERMITTING APPROACH SUMMARY Per DWQ/NPDES Unit's 2001 SOP: • Incorporated BTEX monitoring (replaces benzene/xylene), frequency Monthly per the 2001 SOP. • Removed EPA Method 624 monitoring; "no parameters detected." • Method EPA 625 monitoring remains at 2/Year per the 2001 SOP. • Phenol remains in permit with added permit limit due to questionable "reasonable potential;" no change in Monthly monitoring frequency. • Per requirement for WS waters, added Monthly MTBE monitoring, no limit. PROPOSED SCHEDULE OF ISSUANCE Draft Permit to Public Notice: October 10, 2001. Permit Scheduled to Issue: November 26, 2001 NPDES UNIT CONTACT If you have questions regarding any of the above information or on the attached permit, please contact Joe Corporon at (919) 733-5083 ext. 597. NAME: ,4425K Fact Sheet Renewal -- NPDES NC0000795 Page 5 DATE: /1 (-6( REFERENCES 1. 2001. NPDES Permit Application Short Form C. for ExxonMobil Oil Corporation, NC0000795, February 27. 2. 2001. NPDES Permit Name / Ownership Change Form, for ExxonMobil Oil Corporation, previously owned by Exxon Company, USA, August 24. 3. 1996. NPDES Permit NC0000795, issued to Exxon Company, USA (now ExxonMobil Oil Corporation), expired March 31, 2001 — extended by the Division to August 31, 2001. Copies may be obtained through The Division of Water Quality, Central Files, Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina. 4. 2000. Active NPDES Permits List, North Carolina Division of Water Quality, NPDES Unit, on the web at http:/h2o.enr.state.nc.us/NPDES/NPDESweb.html. 5. 2000. Cape Fear Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water Quality Section, July. 6. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of Water Quality, Water Quality Section. Copies may be obtained through the Planning Branch, Archdale Building, 512 N. Salisbury St., Raleigh, North Carolina. 7. 1991. NPDES Waste Load Allocation Work Sheet, NPDES Permit NC0000795, conducted for Exxon Company, USA, permit now issued to ExxonMobil Oil Corporation, modeled by Permits and Engineering Unit, April 3. 8. 2001 Standard Operating Procedures (Revised), 2001 NPDES Permitting Strategy, North Carolina Bulk Storage Oil Terminals, NPDES Unit, Natalie Sierra, July 30. 9. 1998-2001. Discharge Monitoring Reports (DMR) for Effluent (DEM Form MR-1), Exxon Company, USA, permit now issued to ExxonMobil Oil Corporation beginning January 1998 through July 2001. 10. 2001 Personal Communication from Jenny Rankin (WSRO) to Joe Corporon (NPDES Unit), Greensboro oil terminal site visits and records, August 22. Fact Sheet Renewal -- NPDES NC0000795 Page 6 roit REGIONAL OFFICE COMMENTS No Crn \ xv\ A,.. ij fayi b R_Q_Cte.Pn C11* J . ``^ JuvuiveiltitLa a�ro Mov, 2; 2000. v oh- i't. k. ' s hoLi - a. ' o i (UCLtx SJL+c>,nc --cn ° c c 1iOJ 6C XL L4' _ d i Jd4k rc'U p&A -o,3,�1rLk & d- .k-wL iU( UVr- Juz.. f U S L7li-til C \ C ,A NL ?moo 6cZkAN&A A -wc C''u 0-6 vAciAkkiazi UJ1-6 tvotiLi' cruin9 p olf/J i° 5FiLej-i CA/U T-tfiu- ct 9' 141110 0 9-A, bxvU-24) 00 Cr(,t �'- C( ' 1� iQLth1 d i C/ %J C% t h e rc j'QUvu} \,ui, L' f c/cu'-, cfl'VJ . NAME: '1L11�y tRLkL V\ REGIONAL SUPERVISOR: DATE: 1 a ' 2 - C! l DATE: / M C7-6,7-` G NPDES SUPERVISOR: DATE: Fact Short Renex%al -- IDES M:00 079►5 Page 7 IhtWS OL RCC0r11 Published by News & Record, Inc. Greensboro, North Carolina North Carolina, Guilford County Affidavit of Publication Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to administer oaths, personally appeared Ashley Bowles who being first duly sworn, deposed and says: IN12/01 I. That she is the Publisher's Representative of the Greensboro News & Record, Inc. a corporation, engaged in the publication of newspapers known as "News & Record", published, issued and entered as second class mail in the City of Greensboro in said County and State. 2. That she is authorized to make this affidavit and sworn statement; that the noticc or other legal advertisement, a copy of which is attached hereto, was published in the News & Record on the above listed dates. 3. That the said newspaper (or newspapers) in which such notice, p , document each and every such publication, a newspaper meeting all of the req North Carolina and was a qualified newspaper within the meaning Publishers Roprosentalivo Sworn to and subscribed before me, this Nc t Ica c Notary Public My commission expires: August 23. 2005 vertiselnent was published was, at the time of of -Section 1-597 of the General Statutes of al Statut of No Carolina. NCDENRJDWQMPDES VALERIE MCNEII. NOTARY PUBLIC GUILFORD COUNTY, NC Commission f.,«,» 0.73.10105 ¥dltl02 rla<f 1�.e 1233955 i:1 i i ' News & Record 400 NC0000795 PUBLIC NOTICE STATE PUBLIC NOFCE STAn?, N111(010OUIN ma[YNK51M%IPRs UNT tALEI0. NC7 /�1817 NOrr 55UE A NPo15 r n) WASIEWATER PERU 0 On IM band spo.Omagh at NCrar f n0a1 S•1eN l4]•r t. Pubic F• 12.50lawful slan and totals, tont. IN North Cocain EWE eat to. raislo* p aaaaopesea la lama a Nallenal Pelol.ntDlaM,t. n.nl.,0on Sp.l.m INPDCSI in: wr..M it a w1e a:1 Ia aa: m l.4tna" 1"' p.b. W l uppn0ecom comments r0 Prdl lye its ipt.s..l1V40 E:p':li:FIM comment: wi: �. d ileum that dab an <and dotal loth* that del.nlnapbne t. dine in011P11n0 N0 tap dine Me:5,4l*51 1,1 n,lu ants of ...It IMr.•. s5p4. , d.6,l*rmie:V *. !14 aed.e a•rmam con. ilea Pn..nl 1. 1h. mLI1sN jawatl.M P.rflnl tl * a ot�elanpI. aulset iWo.B F. iA0N110rajwgwli nuia6.r it t 5k9 II.099o5al 55 N av5l Do Malabo al Waal Quality a1 512 N, Sa ,4 0 2,604., R.1.IBh, NC O0,5511I0 . nd ,00 pour to.t*00..• at S:on le acne. n b naon on Ik IMer C0000195 ES remit Ito NIO GreinTt 1e, NC.1/.19 NOi .e r rnrona( ll v4 • .aNrint. Urot I.[E.a rorw..M Peg B.I ."me Irmo 9,a.ad188!w. MneSd M95.10t[w0a .rb<t blot. e..lbn em w n.n a M t•a..,e •corn 11 Or5 Permit W 05 5911. F ONR00S 40. OUIL(CNON( PA O Oxk0AD. 5111 M4INCBIR Iw . tacitly located Ia GUN, FORD County discharging b.a.d.nbnm.001[cal n1E(A9I.Maaa00�ARtU0Rw, .0t i 04.t1It *echo. iF Mdbd.,hb 0• .0 0* p 0 ocean. abman un north. .ItM mania, StIOAL ROES 5.ralt N.•b. Ad shown is not actual print size Re: Draftpermit for ExxonMobi]. Greensboro Subject: Re: Draft permit for ExxonMobil, Greensboro Date: Thu, 18 Oct 2001 10:43:54 -0400 From: Joe Corporon <joe.corporon@ncmail.net> To: steve.d.giffin@exxonmobil.com Steve, please find attached the Fact Sheet (includes phenol assumptions and calculations) and the RPA Summary for parameters of concern. As discussed, the Division would appreciate your providing comments, if any, by November 15 to facilitate a Final Permit before the end of the year. Thanks, --Joe Corporon, P.G. NPDES Unit steve.d.giffin@exxonmobil.com wrote: > Joe, > I am the technical advisor who will be coordinating the review and > development of comments for the draft permit for Greensboro. To facilitate > our review, could you provide a copy of the Fact Sheet, RPA, phenol loading > calculations? Additionally, could you clarify the date by which comments > are due? The letter accompanying the permit is dated October 10, 2001. > However, we would like to have 30 days to review the permit and the Fact > Sheet. > Please give me a call at 410-280-9750 or feel free to reply to this e-mail. > > Thanks, > Steve D. Giffin, P.E. > Environmental Advisor > Downstream SHE Field Support > 1009 Bay Ridge Avenue, PMB 110 > Annapolis, MD 21403 > 410-280-9750 (9751 - fax) > steve.d.giffinL?exxonmobil.com RPA Summary.doc Name: RPA Summary.doc Type: Microsoft Word Document (application/msword) Encoding: base64 Exxon 00795 -- Fact Sheet DRAFT.doc Name: Exxon 00795 -- Fact Sheet DRAFT.doc Type: Microsoft Word Document (application/msword) Encoding: base64 1 of 1 10/18/01 10:52 AM NOTE TO FILE NC0000795 ExxonMobile Oil Corporation, Greensboro Terminal Joe Corporon 150ct01 -- Received call from Jim Hesser (Permittee, Terminal Supervisor); "received Draft Permit; looks ok, but addressed to wrong person (Cramer); send all future correspondence to me." t2PA Reasonable Potential Request Form Facility Name EXXON Co, USA -- Greensboro NPDES Number NC0000795 Permitted Flow Rate (MGD) Not limited - intermittent 7Q10 Stream Flow (cfs) 0 Receiving Stream UT of East Fork of the Deep River ( 6688) et,SW Stream Classification WS-IV 30Q2 Stream Flow (cfs) 0 Average Stream Flow (Qavg) (cfs) 0 TWC/,Z100 Date Requested: August 1, 2001 Projected Date for Completion (add one week to date requested): August 15, 2001 Requested Parameters (Spell out): Phenols Benzene Xylene 1EPA 624 - list number of hits by parameter EPA 625 - list number of hits by parameter Oil and grease Check-TOX compliance .sJ rioZ, NC0000795.xls Subject: NC0000795.xls Date: Wed, 03 Oct 2001 10:02:03 -0400 From: shahnaz.lotfi@ncmail.net To: Mike Myers <Mike.Myers@ncmail.net> CC: Joe Corporon <Joe.Corporon@ncmail.net> ND with no attachment: Phenols,Benzene,Xylene,Oil&Grease for 3/98, 5/98-7/98,9/98,11/98,12/98,2/99,3/99,5/99,6/99, 8/99,11/99-1/00, 3/00,5/00-12/00. Missing data: 11/2000, 1/01-9/01. BDL with no attachment: Phenols,Benzene,Xylene,Oil&Grease for 1/1998. Thank you, Shahnaz } Name: NC0000795.xls NC0000795.xls Type: Microsoft Excel Worksheet (application/vnd.ms-excel); Encoding: base64 Q05,94M 1 of 1 10/3/01 10:03 NC0000.795.xls Subject: NC0000795.xls Date: Mon, 27 Aug 2001 10:14:21 -0400 From: shahnaz.lotfi@ncmail.net To: Mike Myers <Mike.Myers@ncmail.net> Effluent for November 2000 is missing. For Jan 1999-Dec 1999, Jan 2000, March 2000-October 2000 and December 2000 Phenols, Benzene, Xylene and Oil&Grease are For Februay 2000 Phenols, Benzene, Xylene are ND . , nalltieWai, Jan 1999, April 1999, July 1999, Sept 1999, Oct 1999, Feb 2000, April 2000, Total Suspended Solids = 12.7 Total Suspended Solids = 4.8 Total Suspended Solids = 14.4 Total Suspended Solids = 15 Total Suspended Solids = 11 Total Suspended Solids = 4.8 Total Suspended Solids = 3.6 Oil&Grease = 2.1 FINC0000795.xls Name: NC0000795.xls Type: Microsoft Excel Worksheet (application/vnd.ms-excel) Encoding: base64 1 of 1 8/27/01 10:16 Whole Effluent Toxicity Testing Self -Monitoring Summary FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC ft September 25, 2001 Ellerbe WWTP Perm chr lim: 61% NC0021784/001 Bcgin:3/1/1999 Frequency: Q Jan Apr Jul Oct County: Richmond Region: FRO Subbasin: YADIO PF: 0.18 Special 7Q10: 0.18 IWC(%)61.0 Order: + NonComp:Single 1997 Fail Pass — Pass — Pass — — Fad Pass 1998 Pass — — Fail Pass — Pass — — Pass — — 1999 Pass — — Pass — -- Pass — — Pass — — 2000 Late Fad 27.4,45.96 Fail 84.9 81 >90,Pass — — Pass 2001 Pass — — Pass — — Pass Enfield WWTP Penn chr lim: 7% 1997 — 66 66 35 >100 >100 >100 >100 >100 — >100 Late NC0025402/001 Begin:12/1/2000 Frequency: Q Feb May Aug Nov + NonComp:Singlc 1998 Late Late >100 — -- 40 — — 20 -- >100 County: Halifax Region: RRO Subbasin: TAR04 1999 — — NR/35 — — >100 — Late >100 — 71 — PF: 1.0 Special 2000 — >100 — — >100 — — Late >100 — >100 7QI0: 20 IWC(a/.):7.0 Order: 2001 — <7 >54 >28 >100 — Erwin WWII' I'ezm 48hr LC50 ac lim: 30% Carlo or Daph 1997 >100 — — 88.4 — — >100 -- -- >100 NC0064521/001 Begin:8/1/1996 Frequency:Q + Jan Apr Jul Oct NonComp:Single 1998 67.3 — — 64.5 — — >100 --- — >100 — — County: Haman Region: FRO Subbasin: CPFI3 1999 >100 — — 61,65.7 — — >100 — — 55 — — PF: 1.2 Special 2000 30.8 — — >100 — — >100 — — 46.5 — 7Q10:586 IWC(%):0.32 Order: 2001 35.4 — — >100 — >100 Etowah W WCP Pcrm chr lim: 54H.; when relocate to French Broad no tox 1997 — — Pass — — Pass — — Fan Pass — Pass NC0071323/001 Bcgin:10/I11995 Frequency: Q P/F + Mar Jun Sep Dec NonComp:Single 1998 — — Pass — — Pass — — Pass — — Fail County: Henderson Region: ARO Subbasin: FRB02 1999 Pass — Pass — — Pass — — Pass — — Pass PF: 0.065 Special 2000 — — Pass — — Pass — — Pass -- Pass 7QI0:0.08 IWC(%)54 Order: 2001 — — Pass — — Pass — Express Fond Mart Pam chr lim: 90% (New peon 10/I2001) 1997 — NC0085545/001 Bcgin:7/1/1996 Frequency: Q P/F + MarJun Sep De NonComp:Singlc 1998 — County: Catawba Region: MRO Subbasin: CTB32 1999 — PF: 0.0115 Special 2000 — 7Q10:0.0 IWC(S:):100 Order: 2001 H — Pa- ss H H — — Fail — -- Pass — NR Fait <60sigt Btsig <30 H H H H Pass H Exxon Co -Charlotte Marketing Terminal Pcrm 24hr LC50 ac monit cpis fthd (grab) (New perm 9/12001) 1997 — — >t00 — — — — — — NC0004839/001 Begin:9/1/1996 Frequency: A NonComp: 1998 — — — >100,>100 -- — — — — County: Mecklenburg Region: MRO Subbasin: CTB34 1999 — — >100 — — — — — — PF: NA Special 2000 — — >100 — — — — — >100 7QI0:0.0 IWC(%)NA Order: 2001 — — Bt — — — — Exxon Co. Selma Pcrm 24hr LC50 ae mend( cpis fthd (grab) 1997 >100 — — — — — NC0027006/001 Begin:9/1/1999 Frequency: A NonComp: 1998 BI — — >100 — •— County: Johnston Region: RRO Subbasin: NEU02 1999 — >100 — •— — PF: VAR Special 2000 — — — — >100 — — 7Q10: 0 IWC(%):100 Order: 2001 -- — >100 — — — — Exxon USA Wilmington Terminal Penn 24hr LC50 ac monit erns fthd (grab) 1997 — — — — — — — — — — H NC0073 18 1 /001 Begin:7/1/1996 Frequency: A NonComp: 1998 — — >100 — — — — — — County. New Hanover Region: WIRO Subbasin: CPF17 1999 -- — — — >100 — — -- — PF: VAR Special 2000 — — — -- — -- >100 7QI0: TIDAL IWC(%)NA Order: 2001 — — — — — Exxon/Greensboro Marketing Terminal Parn 24hr LC50 ac monit cpis Rini (Grab) 1997 — >100 — — — NC0000795/001 Bcgin:6/I/1996 Frequency: A NonComp: 1998 Bt — — >100,4.100 — County: Guilford Region: WSRO Subbasin: CPF08 1999 >100 -- — — — PF: NA Special 2000 — >100 — 7Q10: 0.0 IWC(Y.):100 Order 2001 — — >100sig Fair Bluff WWTP Pcrm chr dim: 0.26°/. 1997 — NR/<12.5 >100 •— NR <12.5 — 32.01• -- — >52 NC0020729/001 Begin:1/12000 Frequency. Q Feb May Aug Nov + NonComp: Single 1998 — >52 — — >52 — — 4431 — — >52 County: Columbus Region: WIRO Subbasin: LUM51 1999 — >52 — — >52 — — >52 — — >52 PF: 023 Spacial 2000 — Bt — — Pass — — Pass — — Pass 7Q10: 138 IWC(%):0.257 Order. 2001 — Pass — — Pass — — Pass Fairfield Harbor Subdivision Pcrm 24hr p/f ac lim: 90% fthd(no tox until (a) I.OMGD) 1997 NC00331 11/001 Begin:9/12000 Frequency: Q + Mar Jun Sep Dv + NonComp:Single 1998 County: Craven Region: WARO Subbasin: NEUIO 1999 PF: 1.00 Special 2000 7Q10: TIDAL IWC(%)NA Order. 2001 9 Pm 1997 Data Available LEGEND: PERM = Permit Requirement LET= Administrative Letter - Target Frequency -Monitoring frequency. Q- Quarterly; M- Monthly; BM- Bimonthly, SA- Semiannually; A- Annually, OWD- Only when discharging D- Discontinued monitoring requirement Begin - First month required 7Q10 = Receiving stream low flow criterion (efs) += quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan. Apr, Jul, Oct NonComp = Current Compliance Requirement PF - Pcrmincd flow (MCI)) IWC% = Ingram waste concentration P/F v Pass/Fail test AC = Acutc CHR — Chronic Data Notation: f - Fathead Minnow; • - Ccriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test Reporting Notation: -- = Data not required; NR - Not reported Facility Activity Status: I - Inactive. N - Newly Issued(fo construct); H - Active but not discharging t-Mote data available for month in question; • = ORC signature needed 19 ismt Facility Name = NPDES # = Qw (MGD) = Average Q (cfs)= EXXON CO, USA -- GREENSBORO NC0000795 1.05 0 FINAL RESULTS Benzene Max. Pred Cw Allowable Cw 308.4 1.2 RESULTS Std Dev. Mean C.V. Number of data points HITS Mult Factor = Max. Value Max. Pred Cw Allowable Cw 6.7318 2.7 2.4652 13 None 12.33 25.0 µgll 308.4 AO 1.19 µg/1 Parameter = Standard = Benzene 1.19 µgn Date n < Actual Data BDL=1/2DL Jan-98 1 < 5.0 2.50 Feb-98 2 < 1.0 0.50 Apr-98 3 < 50.0 25.0 high PQL! May-98 4 < 1.0 0.50 Aug-98 5 < 1.0 0.50 Oct-98 6 < 1.0 0.50 Jan-99 7 < 1.0 0.50 Apr-99 8 < 2.0 1.00 Ju1-99 9 < 1.0 0.50 Sep-99 10 < 1.0 0.50 Oct-99 11 < 1.0 0.50 Feb-00 12 < 1.0 0.50 Apr-00 13 < 5.0 2.50 "reasonable potential" dictated by inappropriate PQLs a e. fa� /4"b, Facility Name = NPDES # = Qw (MGD) = 7Q10s (cfs)= 1WC (%) = EXXON CO, USA -- GREENSBORO NC0000795 1.05 0 100.00 FINAL RESULTS Toluene Max. Pred Cw Allowable Cw 10.8 11.0 RESULTS Std Dev. Mean C.V. Number of data points HITS Mult Factor = Max. Value Max. Pred Cw Allowable Cw 0.9978 1.3 0.7602 8 None 4.33 2.5 µg/1 10.8 µg/1 11.0 µg/1 Parameter = Standard = Toluene 11A Date n < Actual Data BDL=1/2DL Oct-98 1 < 1.0 0.5 Aug-98 2 < 1.0 0.5 Oct-99 3 < 5.0 2.5 Sep-99 4 < 1.0 0.5 Apr-00 5 < 5.0 2.5 Feb-00 6 < 1.0 0.5 Mar-01 7 < 5.0 2.5 Apr-99 8 < 2.0 1.0 4 Facility Name = NPDES # = Qw (MGD) = Average Q (cfs)= EXXON CO, USA -- GREENSBORO NC0000795 1.05 0 FINAL RESULTS Ethylbenzene Max. Pred Cw Allowable Cw 10.8 383.0 RESULTS Std Dev. Mean C.V. Number of data points HITS Mull Factor = Max. Value Max. Pred Cw Allowable Cw 0.9978 1.3 0.7602 8 None 4.33 2.5 µg/1 10.8 µg/1 383.0 µg/1 Parameter = Standard = Ethylbenzene 383.0 Date n < Actual Data BDL=1/2DL Oct-98 1 < 1.0 0.5 Aug-98 2 < 1.0 0.5 Oct-99 3 < 5.0 2.5 Sep-99 4 < 1.0 0.5 Apr-00 5 < 5.0 2.5 Feb-00 6 < 1.0 0.5 Mar-01 7 < 5.0 2.5 Apr-99 8 < 2.0 1.0 Facility Name = NPDES # = Qw (MGD) = 7Q10s (cfs)= 1WC(%) = EXXON CO, USA -- GREENSBORO NC0000795 1.05 0 100.00 FINAL RESULTS xylene Max. Pred Cw Allowable Cw Allowable #/day 10.8 88.5 0.0 RESULTS Std Dev. Mean C.V. Number of data points HITS Mult Factor = Max. Value Max. Pred Cw Allowable Cw 0.9978 1.3 0.7602 8 None 4.33 2.5 µg/1 10.8 µg/1 88.5 µg/1 Parameter = Standard = xylene 88 5 Date n < Actual Data BDL=1/2DL Oct-98 1 < 1.0 0.5 Aug-98 2 < 1.0 0.5 Oct-99 3 < 5.0 2.5 Sep-99 4 < 1.0 0.5 Apr-00 5 < 5.0 2.5 Feb-00 6 < 1.0 0.5 Mar-01 7 < 5.0 2.5 Apr-99 8 < 2.0 1.0 µg/1 ramoN Facility Name = NPDES # = Qw (MGD) = 7Q10s (cfs)= IWC (%) = EXXON CO, USA -- GREENSBORO NC0000795 1.05 0 100.00 FINAL RESULTS Phenol Max. Pred Cw Allowable Cw 38.0 0.0 RESULTS Std Dev. Mean C.V. Number of data points HITS Mult Factor = Max. Value Max. Pred Cw Allowable Cw 5.5470 23.5 0.2364 13 none @ 50ug/L 1.52 25.0 µg/1 38.0 µg/1 2.37 µg/1 Parameter = Standard = Phenol 2.37 Date n < Actual Data BDL=1/2DL Jan-98 1 < 50 25 Feb-98 2 < 10 5 Apr-98 3 < 50 25 May-98 4 < 50 25 Aug-98 5 < 50 25 Oct-98 6 < 50 25 Jan-99 7 < 50 25 Apr-99 8 < 50 25 Jul-99 9 < 50 25 Sep-99 10 < 50 25 Oct-99 11 < 50 25 Feb-00 12 < 50 25 Apr-00 13 < 50 25 ILO "reasonable potential" dictated by inappropriate PQL Add note to cover letter. Facility Name = NPDES # = Qw (MGD) = 7Q10s (cfs)= 1WC (%) = EXXON CO, USA -- GREENSBOR O NC0000795 1.05 0 100.00 FINAL RESULTS Oil & Grease Max. Pred Cw Allowable Cw 8315.5 30.0 RESULTS Std Dev. Mean C.V. Number of data points HITS Mult Factor = Max. Value Max. Pred Cw Allowable Cw 484.7019 542.3 0.8938 13 1 3.96 2100.0 µg/1 8315.5 µg/1 30.0 mg/L I Parameter = Standard = µg/1 Oil & Grease 30.0 Date n < Actual Data BDL=1/2DL Jan-98 1 < 1000 500 Feb-98 2 < 1000 500 Apr-98 3 < 1000 500 May-98 4 < 1000 500 Aug-98 5 < 1000 500 Oct-98 6 < 1000 500 Jan-99 7 < 800 400 Apr-99 8 < 800 400 Jul-99 9 < 100 50 Sep-99 10 < 800 400 Oct-99 11 < 600 300 Feb-00 12 2100 2100 Apr-00 13 < 800 400 no "reasonable potential" Exxon Mobil Corporation 3225 Gallows Road Fairfax, Virginia 22037 E(onMobil August 24, 2001 VIA OVERNIGHT MAIL North Carolina Department of Environment and Natural Resources Division of Environmental Management NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Re: Exxon Company, Inc. ExxonMobil Greensboro Terminal NPDES Permit No. NC 0000795 Permit Transfer Dear Sir or Madam: - WATER QUALITY POINT SOURCE BRANCH Exxon Mobil Corporation, also known as Exxon Company, Inc. ("ExxonMobil"), currently owns and operates the terminal located at 6907 West Market Street, Greensboro, North Carolina (the "Facility"); and holds National Pollutant Discharge Elimination System ("NPDES") Permit No. NC 0000795 issued by the North Carolina Department of Environment and Natural Resources. This letter is to inform you that effective October 1, 2001, ExxonMobil will lease the Facility to its subsidiary, ExxonMobil Oil Corporation ("EMOC"). Accordingly, this is a request to transfer NPDES Permit No. NC0000795 to EMOC as the operator of the Facility, effective October 1, 2001. We anticipate no changes in the immediate future to discharges from the Facility and are not requesting any change in permit terms or conditions. A completed North Carolina Department of Environment and Natural Resources "Permit Name/Ownership Change Form" and a check for $100 are also included. The Facility address will continue to serve as the address for permit -related correspondence. The Facility's Supervisor, Jim Hesser, will continue to be the primary contact person with respect to this permit. Please contact Daphne Trotter of McDermott, Will & Emery, 600 13th Street, N.W., Washington, D.C. 20005, telephone (202) 756-8043 as soon as possible if you have any questions, need additional information, or are aware of any reason why the transfer may not be effective October 1. Thank you for your assistance. Very truly yours, . S. Simon Vice President Exxon Mobil Corporation r State of North Carolina Department of Environment and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Bill Holman, Secretary Kerr T. Stevens, Director AC;741i NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES PERMIT NAME/OWNERSHIP CHANGE FORM I. CURRENT PERMIT INFORMATION: Permit Number: NC00 0 / 0 / 7 / 9 / 5 1. Permit holder's name: Exxon Mobil Corporation, also known as Exxon Company, U.S.A. 2. Permit's signing official's name and title: J. S. Simon (Person legally responsible for permit) Vice President, Exxon Mobil Corporation (Title) 3. Mailing address: 6907 West Market Street City: Greensboro State: NC Zip Code: 27409 Phone: ( 336) 855-4461 E-mail address: II. NEW OWNER/NAME INFORMATION: 1. This request for a name change is a result of: a. Change in ownership of property/company b. Name change only Xc. Other (please explain): Lease facility to subsidiary 2. New owner's name (name to be put on permit): ExxonMobil Oil Corporation 3. New owner's or signing official's name and title: Harold Cramer (Person legally responsible for permit) Vice President, ExxonMobil Oil Corporation (Title) 4. Mailing address: 6907 West Market Street City: Greensboro State: NC Zip Code: 27409 Phone: ( 336) 855-4461 E-mail address: 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 An Equal Opportunity Affirmative Action Employer Telephone (919) 733-5083 FAX (919) 733-0719 50% recycled / 10% post -consumer paper PERMIT NAME / OWNERSHIP CHANGE FORM THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF WATER QUALITY UNLESS ALL OF THE APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL. REQUIRED ITEMS: 1. This completed application form 2. Legal documentation of the transfer of ownership (such as a contract, deed, articles of incorporation) For changes of ownership, this form must be completed and signed by both the current permit holder and the new owner of the facility. For name change only, the current permit holder must complete and sign the Applicant's Certification. Current Permittee's Certification: I, J. S. Simon , attest that this application for name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information and attachments are not included, this application package will be returned as incomplete. Signature: Date: 8/24/2001 Applicant's Certification: I, Harold Cramer , attest that this application for a name/ownership change has been reviewed and is accurate and complete to the best of my knowledge. I understand that if all required parts of this application are not completed and that if all required supporting information and attachments are not included, this application package will be returned as incomplete. Signature: --`— Date: 8/24/2001 THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS: NC DENR / DWQ NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Version 9-99