NC0082970_Comments_20220715

r ,
-100 YEARS-
CTI of North Carolina, Inc.
Colonial A Subsidiary of Colonial Group, Inc.
July 7, 2022 RECEIVED
Jul 15 2022
Wren Thedford
NCDEQ/DWR/NPDES Permitting NCD,EQ/D NCDEQ I Division of Water Resources UNPDES
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Re: Comments to Draft NPDES Permit NC0082970
CTI of North Carolina, Inc.
Ms. Thedford:
The following comments are being provided in response to the Draft NPDES Permit, NC0082970,
issued to the CTI of North Carolina, Inc. terminal in Wilmington.
Supplement to Permit Cover Sheet,#1 (page 2 of 17): To clarify this condition, boiler blowdown
includes steam condensate from traps on the steam circulation system.
Part 1.A.(1.) and Part 1.A.(2.), Total Suspended Solids (page 3 and 4 of 17): As stated in the
summary of changes for renewal, total suspended solids (TSS) needs to be removed from the
effluent limitations and monitoring requirement tables for Outfalls 001 and 003. TSS monitoring
is being discontinued because the receiving stream is not impaired for TSS.
Part 1.A.(1.), Methanol and BOD-5 testing requirement (page 3 of 17): Due to a methanol
release that occurred on November 29, 2015, monitoring for methanol and BOD5 were added to
the monitoring requirements for Outfall 001 in the permit that became effective January 1, 2017.
There has been no monthly sample collected with detectable levels of methanol in Outfall 001
since February 2020. Results from the BOD5 analysis conducted over this same period also show
results well under the daily and monthly average maximum. There no longer exists a concern
with methanol being discharged. As such, we request that the methanol and BOD-5 testing
requirements be removed from the permit for Outfall 001.
Part 1.A.(1.), Benzene, Toluene, Ethyl Benzene and Xylene (page 3 of 17): Benzene, Toluene,
Ethyl Benzene and Xylene monthly results from Outfall 001 have been under the detection limit
since March 2018. Based on these monthly results, there is no reasonable potential for these
parameters to be discharged from this outfall. We request that these parameters be reduced in
monitoring frequency to semi-annual to match Outfall 003's monitoring requirements.
1002 South Front Street,Wilmington, NC 28401 Office:910.762.2271 Fax:[phone]
• colonialterminals.com

Part 1.A.(1.), Chronic WET Testing (page 3 of 17): WET testing for Outfall 001 was changed from
Acute WET testing to Chronic WET testing with the rationale that Outfall 001 is a complex waste
stream with continuous flow. Outfall 001 does not have continuous flow. The flow is episodic
and is largely dependent on rainfall. Therefore, based on the definition given, Outfall 001 should
continue with Acute WET testing.
Part 1.A.(1.)and Part 1.A.(2.) Footnotes,Turbidity (page 3 and 4 of 17): In footnote 4 for Outfall
001 and footnote 3 for Outfall 003, the turbidity limits are listed as 25 NTU. This is incorrect and
the limit should be listed as 50 NTU to reflect the change made to the turbidity limit. The footnote
should read, "Effluent turbidity shall not cause receiving-stream turbidity to exceed 50 NTU. If
background turbidity naturally exceeds 50 NTU,the effluent shall not cause background turbidity
to increase."
If you have any questions concerning this submittal, please contact me at 912-443-6645. We
would appreciate a response during the comment period, which would afford us the ability to
correct issues of concern before the permit is issued.
Sin el
Tom Dolan
Environmental Manager
C: Ryan Chandler, Pratt Summers, Rigel Rodriguez, Philip Watts