NC0031038_Permit (Issuance)_20010730

NPDES DOCUMENT SCANNIN` COVER SHEET
NPDES Permit:
NC0031038
Document Type: '
Permit Issuance)
Wasteload Allocation
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Correspondence
Speculative Limits
Instream Assessment
(67b)
Environmental Assessment (EA)
Permit
History
Document Date:
July 30, 2001
This document is printed on reuse paper - ignore any
content on the reirerse side

NCDENR
John Culbreath
Colonial Pipeline Company
P.O. Box 87
Paw Creek, North Carolina 28681
Dear Mr. Culbreath:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
July 30, 2001
Subject Issuance of NPDES Permit NC0031038
Charlotte Delivery Facility
Mecklenburg County
Division of Water Quality (Division) personnel have reviewed and approved your application for
renewal of the subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This
permit is issued pursuant to the requirements of North Carolina General Statute 143-215.1 and the
Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated
May 9, 1994 (or as subsequently amended). Please note the following changes from your draft permit, most
of which are the results of the Paw Creek hearing officer's recommendations:
• pH monitoring and limits have been removed from your permit. This was an error made in all
of the Paw Creek draft permits. The pH requirement was eliminated in the previous permitting cycle
and should not have been included in the 2001 permits.
• The monthly monitoring requirement for naphthalene has been deleted. Semi-annual
monitoring using EPA Method 625 replaces it. As per the hearing officer's report, 625 is the
best method for detecting naphthalene and other middle distillate compounds and is therefore a
more appropriate monitoring requirement. If your facility collects eight to ten samples in which
none of the 625 compounds are detected, you may submit a request to the Division that this
sampling requirement be eliminated.
• Flow monitoring frequency has been changed from monthly to episodic. As per a request by
the Mooresville Regional Office, flow must be measured with each discharge event.
• Flow monitoring requirements have been modified to include estimation by instantaneous
flow. This is in accordance with a December 6, 1996 modification to your permit that allowed for
this measurement option.
• The MTBE limit of 11.6 µg/L has been removed from the permit. As per the hearing officer's
recommendations, a peer -reviewed criterion for MTBE does not exist and will not be included as
part of the permitting strategy for the Paw Creek permits. It is anticipated that a criterion will be in
place when this permit is next renewed. In addition to monthly monitoring of MTBE, please
see Part A. (3.) for some additional requirements related to MTBE.
• Special Condition A.(4) has been added to this permit. As discussed with Division staff in a
phone conversation on July 27, 2001, it is unclear as to whether the drainage ditches on site
constitute effluent channels as per 15A NCAC 2B. 0228. If it cannot be demonstrated that these are
effluent channels, you must submit a plan to obtain representative samples of your stormwater
discharge.
ATM
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Customer Service
1 800 623-7748

Colonial Pipeline Company
Charlotte Delivery Facility
NPDES Permit NC0031038
Page 2
If any parts, measurement frequencies or sampling requirements contained in this permit 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 in the form of a written petition, conforming to
Chapter 150B of the North Carolina General Statutes, and 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.
Please note that this permit is not transferable except after notice to the Division. The Division may
require modification or revocation and reissuance of the permit. This permit does not affect the legal
requirements to obtain other permits which may be required by the Division of Water Quality or permits
required by the Division of Land Resources, the Coastal Area Management Act or any other Federal or Local
governmental permit that may be required.
If you have any questions concerning this permit, please contact Natalie Sierra at telephone number
[phone], extension 551.
Sincerely,
cc: Mooresville Regional Office/Water Quality Section
NPDES Unit
Central Files
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Department of Environmental Protection

Permit NC0031038
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,
Colonial Pipeline Company
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte Delivery Facility
7524 Kenstead Circle
Paw Creek
Mecklenburg County
to receiving waters designated as an unnamed tributary of Gum Branch within the Catawba 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 September 1, 2001.
This permit and authorization to discharge shall expire at midnight on June 30, 2005.
Signed this day July 30, 2001.
Kerr ► ' e ' 'recto
Divisi • of ter Quali
By Authority of the Environmental Management Commission

Permit NC0031038
�� •f. Kf'�k"�.. li:�•i •. t • t �� T cy L.r-.c4i.�.".�• •.i: .tK�i.:.�;!:.. :' ...
UPPLEMENT TO PERMIT COVER SHEET_+:
Colonial Pipeline Company
is hereby authorized to:
1. continue discharging storm water and treated effluent from the existing water pollution control
system consisting of
• stormwater runoff
• groundwater remediation discharge (treated)
• surface tank and piping compounds with secondary containment
• oil / water separator
• retention pond
located at the Charlotte Delivery Facility, 7524 Kenstead Circle, Paw Creek, Mecklenburg County, and
2. discharge from said water pollution control system through Outfall 001 at a specified location (see
attached map) into an unnamed tributary of Gum Branch, a waterbody classified as WS-IV
waters within the Catawba River Basin.

Colonial Pipeline Company
Charlotte Delivery Facility
State Grid/Quad: F 15 SW / Mountain Island Lake, NC
Latitude: 35° 17' 15" N
Longitude: 80° 56' 05" W Permitted Flow: Not Limited
Receiving Stream: UT of Gum Branch Drainage Basin: Catawba River Basin
Stream Class: WS-IV Sub -Basin: 03-08-34
r. tut
Facility
Location
not to scale
NPDES Permit No. NC003 1038
Mecklenburg County

1
i;
ti
Colonial Pipeline Company
Charlotte Delivery Facility
State Grid/Quad: F 15 SW / Mountain Island Lake, NC
Latitude: 35° 17' 17" N
Longitude: 80° 56' 08" W Permitted Flow: Not Limited
Receiving Stream: UT of Gum Branch Drainage Basin: Catawba River Basin
Stream Class: WS-IV Sub -Basin: 03-08-34
t 1 t
t�l
Qt
8
Y:
4V4
Facility
Location
not to scale
r0-
:5.
North
NPDES Permit No. NC003103
Catawba County

Permit NC0031038
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:
EFFLUENTS . ' ,;
CHARACTERISTICS
A\-11. ti :,., � ;�." °,?. •. � .?.,�
,• , L, , LIMITS " +
�' �MONITURING RE(ZUIREMENTS��,,;i}
Monthly,,
rt1.A,v.,erage,
JW �.3 Dail •,
. Maximums
Measurement
: Frequency...
Sample:
Type
Sample Location i
Via
Flow1
Episodic
1
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Oil and Grease2
Monthly
Grab
Ettluent
Turbidity3
Quarterly
Grab
Effluent
Phenol
0.17 mg/L
Monthly
Grab
Ettluent
Benzene
119 µgfL
Monthly
Grab
Effluent
Toluene
Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
Xylene
Monthly
Grab
Effluent
EPA Method 625
Semi-annually
Grab
Effluent
MTBE4
Monthly
Grab
Effluent
Acute Toxicity'
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 in one of four
ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude built -upon
area (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.
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. 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.
4. MTBE — Please see Part A.(3.) for other requirements relating to MTBE
5. Acute Toxicity (Fathead Minnow, 24-hour), annual samples to be collected concurrently with BTEX
samples [see Special Condition A.(2.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 1.19 µg/1 and toluene concentration is less than 11 µg/1.

. Permit NC0031038
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
• SPECIAL. CONDITIONS.
A. (2.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as defmitive 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 chemical/physical 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.

Permit NC0031038
A. (3.) MTBE SPECIAL CONDITION..;...,
For the protection of public health, oil terminals that discharge to waters classified as water supplies
("WS" waters) will adhere to the following action plan:
1. As stated in Part A. (1.), monthly monitoring of MTBE for the duration of the permit is required.
2. After one year of monthly monitoring or once twelve data points have been collected, the
Permittee shall review the MTBE data collected. If MTBE has not been detected in any samples
taken during the first year, the facility may request that the monitoring frequency for MTBE be
reduced. This should be done by requesting the NPDES Unit to perform a minor modification to
the NPDES permit: In the case in which MTBE has been detected within the first year of
effluent sampling, the subject facility must submit an MTBE reduction plan. This action plan
may include site -specific BMPs or engineering solutions. A copy of this plan should be
submitted to:
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
3. By the time of the next permit renewal, it is anticipated that surface water criterion for MTBE
will be established. This criterion will be used in conjunction with the facility's effluent MTBE
data to perform a reasonable potential analysis (RPA). The RPA will determine whether effluent
from a facility has the potential to exceed a water quality standard.
A. (4.) ENGINEERING STUDY
The permit holder must demonstrate that the east and west drainage ditches qualify as effluent
channels as per the conditions delineated in 15A NCAC 2B .0228. If it cannot be demonstrated that
these drainage ditches can be construed as effluent channels, the permittee shall submit an
engineering analysis within 180 days of the permit effective date. This analysis must, at a minimum,
designate discrete outfalls/sampling points that provide representative samples of all waters
discharged.

MEMORANDUM
TO:
FROM:
PREPARED BY:
SUBJECT:
DIVISION OF WATER QUALITY
April 5, 2001
Dave Goodrich
D. Rex Gleason
Richard Bridgeman,
Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
0
Oo
0
It is recommended that the effluent sample location be specified in all the permits.
Circumstances at one facility (at least) can be cited as justification for the
recommendation. The permit description of the water pollution control system (WPCS)
for Colonial Pipeline Co. (NC0031038) includes a retention pond. This pond is also
mentioned in the Fact Sheet. Regardless of the 7Q10, 30Q2, and average flow data, this
pond is actually an impoundment fed by three UT's to Gum Branch. According to the
terminal manager, there is flow in these UT's to Gum Branch 12 months per year. The
effluent from the CITGO (NC0021962) facility is discharged to one of the UT's.
Stormwater runoff from at least one other terminal site may also enter the impoundment.
Effluent samples are collected at the outfall for the impoundment.
IAs discussed above, in addition to the sample collection location, the Colonial Pipeline
Co. (NC0031038) permit needs to be reviewed to determine if it is appropriate to include
the impoundment of a UT to Gum Branch as a treatment unit (retention pond).
Consistency is needed in specifying source of wastewater to WPCS.
There are four different methods used in the draft permits, as follows:
Source not specified anywhere.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet,
which describes the WPCS and/or specifies outfall.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet that
specifies receiving water.
Source indicated in Part I, Section A(1) of permit (Effluent Limitations and
Monitoring Requirements Sheet).
The writer's preference, in part because several of the facilities have multiple outfalls, is
to indicate sources on both the Supplement to Permit Cover Sheet (in paragraph which
describes the WPCS and/or outfall) and in Part I, Section A(1). An example of the
writer's preference is in the permit for Motiva Enterprises, LLC (NC0046892).

Dave Goodrich
Page Two
April 5, 2001
Flow measurement/reporting frequency is recommended to be episodic (as in permit
Motiva Enterprises, LLC (NC0022187).
For several design reasons, discharge events basically occur on an as -needed basis; a
decision is usually made when there will be a discharge through an outfall. The only
exception may be Outfall 002 included in the permit for ExxonMobil Refining and
Supply (NC0004839), which is for a groundwater remediation system without any flow
retention capability, and, therefore, subject to daily discharges. Since discharge events
are mostly manually precipitated and occur randomly or as -needed, the range of the flow
data at a facility may vary considerably. Flow data seems to have played a large role in
the development of effluent limits (as in reasonable potential analysis for phenols), and
yet historically flow measurement methods and data have been two of the evaluations of
a compliance inspection subject to much scrutiny and criticism. Given the flow
measurement options specified in the permits, the small number of discharge events
probable each month, the importance of flow data, and the possibility of a wide range in
the flow data, it is not unreasonable to expect flow to be measured and reported for each
flow event.
The Turbidity monitoring requirement does not seem to be complete.
The permits, with two exceptions (discussed under the next item), include either a
quarterly monitoring -only requirement or a monthly monitoring requirement with an
effluent limit. It is not understood how the effluent turbidity monitoring requirement
correlates with the relevant footnote in Part I, Section A(1). Should there not also be an
upstream and downstream monitoring requirement. In fact, those facilities with a
monitoring -only requirement need only conduct stream monitoring to determine if
effluent turbidity levels result in stream standard violations.
One of the exceptions mentioned above under the item for Turbidity Monitoring is
Marathon Ashland Petroleum, LLC (NC0046213). Although the permit cover letter
indicates that the permit includes a monthly monitoring requirement and an effluent limit,
Part I, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring -only
requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is
being required because of the near potential for a stream standard violation. The other
exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being
required because none of the previously required monitoring has been conducted.
Philips Pipe Line Company (NC0032891) — Phenol limit in the other permits is expressed
in mg/L. In the Philips permit, it is expressed in ug/L.
ExxonMobil Refuting and Supply (NC0004839) — Benzene limit is indicated to be 1.2
ug/L; should it not be 1.19 ug/L?

Dave Goodrich
Page Three
April 5, 2001
Phenol limit development.
The cover letters for four of the six permits with a Phenol limit discuss development of
the limit. In the cover letter, the water quality standard for phenol is indicated to be 1
mg/L; it is actually 1 ug/L for WS waters. The writer is not familiar with the 2001 SOP
used to develop limits for phenol, but considering the fact that five of the six facilities
discharge to streams having a 7Q10, 30Q2, and average stream flow of zero, and the sixth
facility discharges to a stream having a 7Q10 and 30Q2 flow of zero and an average flow
of <1, it is hard to understand the assigned limits. The 3 mg/L Phenol limit for Outfall
002 in the ExxonMobil (NC0004839) permit is almost unimaginable.
Motiva Enterprises, LLC (NC0022187) — The Fact Sheet indicates that there is a
reasonable potential for the stream standard for Lead to be violated, but indicates that no
limit will be assigned because lead is an action level pollutant. A change? If not, should
there be a Lead limit in permit?
TransMontaigne Terminaling, Inc. (NC0021971) — Permit Cover Sheet indicates that
discharge is to Paw Creek. As indicated elsewhere in permit, discharge is to a UT to Paw
Creek.
Williams Terminals Holdings, L.P. (NC0074705) — The permit description includes an
oil/water separator, a carbon filter, and a holding tank. The Fact Sheet indicates that
wastewater and stormwater are routed to a retention pond and released as needed. No
staff report or compliance inspection report mentions this retention pond. MCDEP staff
has confirmed that there is no retention pond at the site.
Valero Marketing & Supply Co. (NC0004723) — Please review discussion in Fact Sheet
concerning the assignment of a Turbidity limit. If the average turbidity value in the past
1.5 years is 7.2 NTU and the maximum 28 NTU, why is there a prediction of a maximum
of110.3NTU?
Williams Energy Ventures (NC0005185) — Permit Cover Sheet indicates that discharge is
to a UT to Gum Branch; as correctly identified on the Supplement Sheet, it is a UT to
Long Creek.
Motiva Enterprises, LLC (NC0046892) — Fact Sheet indicates that the Flow requirement
for Outfall 002 in the previous permit will remain unchanged. There was a Flow limit in
the old permit, but not in the draft permit. The writer does not recommend a limit.
Please advise if you have questions or comments.
RMB

MECKLENBURG COUNTY
Department of Environmental Protection
April 17, 2001
Mr. Dave Goodrich
NCDENR - DWQ - NPDES Unit
1621 Mail Service Center
Raleigh, NC 27699-1617
Subject: Paw Creek Petroleum Terminal NPDES Permit Renewals
Dear Mr. Goodrich:
RECEIVED
WATFP nt i i m' RRITION
APR' U 2E1
Non•Dische,ge Permitting
The Mecklenburg County Department of Environmental Protection (MCDEP) has reviewed the
subject draft permits. As you know. MCDEP has a Memorandum of Agreement with the
Division of Water Quality to conduct inspections of the Paw Creek terminals in order to
determine compliance with the applicable NPDES permits. We offer the following comments
regarding the permits:
General
• Flow Measurement
The flow measurement method by which facilities are allowed to calculate flow based on
the area draining to the outfall, the built -upon area, and total rainfall using the rational
equation is inaccurate in most cases. Most facilities inspected by MCDEP collect
stormwater in earthen secondary containment basins surrounding the above ground
storage tanks (not ponds). The facilities generally hold the stormwater for as long as
possible (several weeks if weather permits) to allow any suspended solids to settle out
and to avoid discharge if possible so that monthly sampling and laboratory analysis does
not have to be performed. Calculating discharge flow by this method is inaccurate
because it does not account for evaporation and ground infiltration during the holding
period.
• Quarterly Turbidity Monitoring
The permits state that "Effluent turbidity shall not cause the receiving stream turbidity to
exceed 50 NTU. If receiving stream background turbidity exceeds 50 NTU, effluent shall
not cause this background value to increase."
PEOPLE • PRIDE • PROGRESS
700 N. Tryon Street • Suite 205 • Charlotte, NC 28202-2236 • [phone] • Fax [phone]

Mr. Dave Goodrich
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Paget
The permits require quarterly turbidity monitoring at the effluent. The permits do not
require upstream or downstream monitoring for turbidity. Without instream monitoring
requirements, compliance cannot be determined.
Individual Facility Comments
• Williams Terminals Holdings, L.P. - Permit # NC0074705
An error was noted on the fact sheet for this facility. The background section refers to a
detention pond which is used to hold wastewater prior to discharge. MCDEP has
determined that the treatment works for this facility do not include a detention pond.
• Exxon Mobil Refining and Supply Company - Permit # NC0004839
Outfall 001-
The daily maximum permit limit for benzene is listed as 1.24g/1. The North Carolina
water quality standard for WS-IV waters is 1.19/4g/l.
• Marathon Ashland Petroleum, LLC - Permit # NC0046213
The last footnote on the Effluent Limitations and Monitoring Requirements
page of the permit states, "There shall be no direct discharge of tank (or pipe) contents
following hydrostatic testing unless benzene concentration is less than 71.4,ug/1 and
toluene concentration is less than 11µg/1." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19.zg11.
Colonial Pipeline Company - Permit # NC0031038
MCDEPs past inspections of this facility indicate that the retention pond located on -site
receives flow from three intermittent streams. While the streams are classified as
intermittent by USGS, terminal personnel have indicated that the streams have perennial
flow. In addition, stormwater discharges from the Citgo facility (NC0021962) and Crown
Central Petroleum Corporation (NC0046531) flow to Colonials' retention pond before
entering the receiving stream. Since these conditions exists prior to the outfall location
(sampling point), MCDEP has concerns that these influences may constitute dilution of
the waste stream and effluent analysis may not be totally representative of the facility's
wastewater characteristics. In addition, Colonial could potentially be liable for impacts
from off -site sources.

Mr. Dave Goodrich •
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 3
If you have any questions regarding these comments, or any other matters, please feel free to give
me a call at 704/336-5500. Thank you.
Sincerely,
1
Rus ; ' ozzelle
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP

Sent By: ;
.919 821 0337; May-2-01 16:32;
Page 2/3
WILLIAM II. WEAMIERsPOON
May 2, 2001
NORTFL CAROLINA
PETROLEUM
COUNCIL
A niUi51011Ofdh American Petroleuet Institute
SUITE 2850 • 150 FAY TTLVIL E SF. MALL
RALEIGH. NC 27601
010 f 828-S438 • FAX [phone]
Mr. Rick Shiver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Ext.
Wilmington, NC 28405-3845
Re: NPDES Pcrrnit Renewals
Paw Creek Petroleum Pipeline and Distribution Terminals
Charlotte (Mecklenburg County), North Carolina
Dear Mr. Shiver:
Thank you for the professional manner in which the public hearing on the petroleum terminals'
NPDES permits was conducted in Charlotte on April 19, 2001.
The purpose of this letter — which I request be included in the official hearing record — is to
express my members' strong concern about the way MTBE is being addressed in the terminals'
draft permits.
The North Carolina Petroleum Council — a division of the American Petroleum Institute, the
trade association for the nation's major fuel suppliers — is committed to insure that the
opportunity for public hearings and comment is an integral pert of government decision -making.
So we simultaneously praise the process that allows us to submit this statement for the record,
while we point with alarm to the proposed MTBE limit of 11.6 ug1L that has been included in the
draft permits without a single hearing or any otficial review by a rulemaking body.
We asked the Department (DENR) to help us understand how this it came about We were
told that there is no surface -water standard for MTBE. Further, we were advised that the
proposed MTBE limit has not been endorsed by the Environmental Management Commission
has not been debated by those publicly appointed members — has not been the subject of public
hearings at all. In fact, the EMC recently dealt with the matter of MTBE and voted not only to
reject a request for aternporary groundwater standard of 70 ppb, but also to reaffirmthe value of
public hearings by calling for a permanent rulemaking process to tighten the MTBE groundwater
di2c td. So sus we sLI await %tvs twaazinis waccissoar tbswevasal, we are now confronted with

Sent By: ;
919 821 0337; May-2-01 16:32;
Page 3/3
Mr. Rick Shiver
May 2, 2001
Page 2
draft NPDES permits that attempt to install an MTBE limit that is at best controversial and at
worst a circumvention of the EMC.
It is my understanding that MTBE was not an issue for the Department in the NPDES permits
issued five years ago.
To be sure, in the intervening years it has been an issue of increasing attention, study, debate and
speculation. Apparently some individuals have been so moved by the growing debate that hasty
changes in risk calculations and other values have occurred. A few advocates within the
Department who sounded the alarm so vigorously in statements to the EMC in support of an
MTBE groundwater standard of 70 ppb have now changed their minds! What had been a
certainty one month was abandoned the next in favor of a new calculation — and a new limit
level. So, if public health considerations arc truly moving this fast, if numbers are hastily
abandoned and recalculated, if the science is in such a state of flux, then our commitment to
reasoned public input is all the more appropriate and needed to insure that the calculations of
today are not abandoned tomorrow.
Recommendations
The Council's members accept that an MTBE limit that has been peer -reviewed and duly
considered via the rulemaking process may be appropriate for inclusion in the terminals' NPDES
permits. Lacking that, however, the Council believes the MTBE limits contained in the draft
permits should be removed.
Importantly, the Council's members with facilities in Charlotte are willing to help the
Department collect MTBE data by monitoring for it on a periodic basis. But the proposed
monthly monitoring requirement is excessive. We are confident that scan -annual monitoring by
each of the terminals will provide the needed representative data to form the basis for future
decision -making.
Sincerely,
William H. Weatherspoon
WHW/jm
c: Ms. Natalie Sierra

SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS
CONTAMINANT
•
CAS #
"C" & "B" WATERS•
(ug/I unless noted
• otherwise)
"WS-I" - "WS-V"
WATERS
"SC", "SB", & "SA"
WATERS (ug/I unless
noted otherwise)
SOURCE OF STANDARD
OR CRITERIA
BENZENE
• 71-43-2
71.4
1.19
71.4
15A NCAC 2B .0211-.0222
n-BUTYL BENZENE
• 104-51-8
36
36
36
ECOTOX 4/98
sec -BUTYL BENZENE
135-98-8
41
41
41
ECOTOX 4/98
CHLOROFORM
67-66-3
470
5.7
470
EPA 4/22/99
ETHYL BENZENE
100-41-4
383
524
130
ECOTOX 1/01
IPE
, 108-20-3
19 mg/L
19
330 mg/I
ECOTOX 1/01
ISOPROPYL BENZENE
98-82-8
316
186
4.6 mg/I
ECOTOX 1/01
p-ISOPROPYL BENZENE
99-87-6
325
325'
1.1 mg/l
ECOTOX
METHYLENE CHLORIDE
75-09-2
1600
4.7 ,
1600
EPA 4/22/99
MTBE
1634-04-4
2393
11.6
2393
NC DHHS 7/11/00
NAPHTHALENE
91-20-3
105
43'
64
ECOTOX 1/01
n-PROPYL BENZENE
103-65-1
77.5
77.5
190
ECOTOX 1/01
1,2,4-TRIMETHYLBENZENE
95-63-6
386
72
218
ECOTOX 1/01
1,3,5-TRIMETHYLBENZENE
108-67-8
626
100 '
215
ECOTOX 1/01
TOLUENE
108-88-3
11 (0.36 Tr)
11 (0.36 Tr)
185
15ANCAC 2B.0211-
.0222/ECOTOX 8/99(SW)*
XYLENE, TOTAL
1330-20-7
88.5
88.5
370
ECOTOX 1/01
Criteria which have a source of EPA ECOTOX were developed using EPA's ECOTOX database per 15A NCAC 2B .0208.
Last update 2/2/01 (DMR) These concentrations are updated regularly.
Questions or criteria for other parameters not found in the 15A NCAC 2B .0200s can be addressed to Dianne Reid at
919.733.5083 extension 568 ([e-mail]) OR Jason Wynn ext. 351 ([e-mail])

Permit Requirements for Discharges from Oil 86 Petroleum Storage Facilities
2001 Permitting Strategy
Background / Introduction
In 1996, the Permits and Engineering Unit reviewed NPDES permit monitoring requirements for stormwater
discharges 'at oil terminal facilities located in the Greensboro and Charlotte areas. This review revealed
inconsistencies in monitoring requirements that were subsequently discussed with staff of the Winston-Salem
and Mooresville regional offices. These discussions and a review of past information collected at these facilities
formed the basis for much of the standard monitoring requirements contained in this Standard Operating
Procedure (SOP) for Stormwater Discharges from Oil Terminal Facilities.
In accordance with the basinwide planning schedule, the NPDES permits for the oil terminal facilities are due for
renewal in 2001. The NPDES unit has reviewed the discharge monitoring reports (DMRs) for the facilities in
order to assess the SOP currently in place. This led to some revisions and additions to the existing procedure;
the bulk of the 1996 SOP will be carried over into the 2001 revised SOP.
This document is divided into three sections that delineate the permitting requirements for oil terminal facilities.
The first part describes the minimum requirements for all oil terminal facilities in the state — both monitoring
requirements and permit limits. The second section describes potential additional site -specific requirements that
are based upon the performance of a reasonable potential analysis for the facility. Such requirements are based
upon reported data from the Discharge Monitoring Reports (DMRs) of a given facility. The third and final section
delineates additional requirements for those facilities which discharge to receiving waters carrying a water supply
classification.
I. Minimum Requirements for ALL Oil Terminal Facilities
A. Flow
Episodic Monitoring (monitor with each discharge event)
Measurement of flow is to be representative of a discharge event. Many oil terminal facilities
have storage ponds to collect runoff and therefore, discharges may not always occur during
storm events. Flow should be monitored by one of the following methods:
1. Measure flow continuously, or
2. Calculate flow based on the area draining to the outfall, the built -upon area, and the total rainfall,
using the rational equation (see below), or
3. Estimate by flow measurement at 20 minute intervals during the entire discharge event, or
4. Base flow on pump logs.
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.
For oil terminal facilities with large storage ponds that serve to collect runoff, item 2 listed above and the
rational equation should not be used because the calculations will determine the flow to the storage pond,
rather than the flow from the pond.
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Permit Requirements for Discharges from Oil as Petroleum Storage Facilities
B. Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual
Monitor annually (assuming first five discrete storm events have already been monitored and
showed no toxic effects)
Monitoring Footnote: acute toxicity monitoring should occur during collection of BTEX
parameters (see item E below)
Products stored at oil terminals may contain a variety of different chemicals (some of which may have
harmful or toxic effects). To verify that toxic chemicals are not discharged to surface water, a periodic
toxicity test will be required. An acute, rather than chronic, toxicity test is required because oil terminal
facility discharges are typically short-term, episodic events. Specifically, an acute 24-hour pass/fail at 90%
waste concentration using fathead minnows is the recommended toxicity test for stormwater discharges.
Facilities that meet one or more of the following criteria will not qualify for annual monitoring and will
be required to monitor for acute toxicity during five storm events:
1. Facilities that have never monitored for acute toxicity during a storm event, or
2. Facilities that monitored for acute toxicity during four or fewer storm events during the last
permit period, or
3. Facilities that completed five acute toxicity tests during five storm events, but did not pass all
five tests.
Facilities that fail an acute toxicity test conducted during one or more of the five storm events or during an
annual monitoring event will be required to conduct quarterly monitoring for the forthcoming permit period,
and must receive State approval for reduced monitoring. For facilities that have not yet conducted acute
toxicity testing for the first five discrete storm events, a statement in the permits will allow for additional
toxicant limits should the toxicity test indicate toxic effects. At the time of permit renewal, only annual
monitoring for toxicity would be required if the facility has performed the five discrete sampling
requirements with no acute toxicity.
C. Total Suspended Solids
Monitor monthly
Daily maximum 45.0 mg/1
Historically, Total Suspended Solids (TSS) has not been a significant problem in stormwater discharges at
oil terminal facilities. A 1996 analysis of TSS data from five stormwater discharges indicated only one event
in excess of the previously permitted 30.0 mg/1 monthly average. A daily maximum limit of 45 mg/L is
recommended as a general indicator of stormwater quality. A daily maximum compliance period is given to
reflect the sporadic nature of these discharges. Should TSS monitoring data indicate any substantial
problems, the Regional Office or county may elect to enforce the instream standard for turbidity.
D. Oil and Grease
Monitor monthly - No Limit
Monitoring Footnote: Where possible, the grab sample for oil and grease should be skimmed from
the water surface of a quiescent (calm water) zone.
Historically, oil and grease has not been a significant problem in stormwater discharges at oil terminal
facilities. However, like TSS, oil and grease is a good general indicator of the quality of a stormwater
coming from a site. Where possible, oil and grease samples should be skimmed from the surface of a
quiescent zone closest to the discharge.
E. BTEX
Monitor monthly - No Limit
Benzene, toluene, ethylbenzene and xylene are toxicants commonly found in petroleum. The previous
permitting strategy for the oil terminals required the EPA 624/625 scan, which, among other contaminants
of concern (see Part II), detects BTEX compounds. A review of the discharge monitoring report data from
the previous permitting cycle indicates that these four contaminants frequently appear in stormwater from
terminal facilities. For the most part, the other volatiles and semi-volatiles detectable by the EPA 624/625
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
scan were never detected in the stormwater from these facilities. By monitoring for BTEX and naphthalene
(see part F, below), the facilities are collecting data on those pollutants that are mostly likely to be present
in the water.
F. EPA Method 625
Monitor semi-annually
The intent of this monitoring requirement is to monitor for naphthalene and other indicators of middle
distillate compounds detectable by Method 625. These contaminants are commonly found in heavy
fuels, such as diesel. During site visits of terminal facilities performed by members of the NPDES Unit,
it was observed that the majority of the terminals reserve at least one storage tank for diesel fuel.
Originally, facilities were to have monitored only for naphthalene, but since the most accurate method
of quantifying naphthalene is through Method 625 and other middle distillate compounds can be
detected through this scan, the entire results should be reported to the Division. •
If it can be demonstrated by the permittee that diesel fuel is not currently being stored on site, then the
monitoring requirement on the effluent page will have the following footnote:
"Monitoring requirement applies only for facilities storing diesel or other heavy fuels on site."
G. Tank Solids, Tank Bottom Water, and Rag Layer
No direct discharge of tank solids, tank bottom water, or the rag layer is permitted.
There are typically four discrete layers of varying thickness within a storage tank. At the very bottom of the
tank is the solids layer that achieves a 1/2-1 inch thickness over a 5-6 year period. Immediately above the
solids layer is 1-6 inches of tank bottom water that results from rainwater breaching the wall seal in open
roof tanks. Open roof tanks are not completely open, but have a roof floating directly on the product.
There is a seal between the tank walls and floating roof designed to prevent water from entering the tank.
Water breaching this seal and entering the tank is referred to as tank bottom water. The rag layer is at
most 3/4 inch thick and forms the interface between the tank bottom water and the product. The product
is the topmost layer and is 20-25 feet. Normally, the tank bottom water is removed from the tank when it
is 3-4 inches deep. The mixture of water and product in the rag layer is often drawn off when tank water is
removed because water entering tanker trucks must be minimized. As a result of potentially high levels of
organic compounds in the three bottom layers of storage tanks, they are not to be discharged, but instead
should be transported off -site for appropriate treatment and/or disposal or treated/recovered onsite if
treatment technology capabilities occur onsite.
H. Hydrostatic Testing
Hydrostatic testing of oil tanks normally occurs once every five to six years. Prior to the hydrostatic testing,
the tank is completely drained and tank bottom materials are handled as described in the previous section.
The tanks are completely cleaned and then coated and welded (if necessary). The tank is then filled with
water for the hydrostatic test. Some oil terminal facilities use stream or lake water to hydrostatic test their
tanks, while others use potable city water. Because the tank is thoroughly cleaned prior to refilling with
water for the hydrostatic test, water discharged from the tank following the hydrostatic test should be fairly
clean. However, tank discharges following hydrostatic testing may contain contamination. Therefore,
monitoring of the tank water prior to direct discharge will be required. There shall be no direct discharge
from oil terminal facilities following hydrostatic testing if concentrations of benzene and/or toluene are
greater than their respective water quality standards (see effluent pages at end of SOP for details).
I. MTBE Monitoring
Monitor monthly
Within the last year, the Environmental Protection Agency has recommended banning methyl tertiary butyl
ether (MTBE), an ingredient commonly used in gasoline to aid in the reduction of air pollution. MTBE was
originally added to gasoline in response to a 1990 law that required higher oxygen content in gas sold in the
most -polluted cities. It has since become a cause for concern since the EPA now believes that MTBE may
be a carcinogen and is seeking to outlaw the compound.
Since MTBE contamination of water is a public health concern, monthly MTBE monitoring will be added to
all facilities. For those facilities currently monitoring for MTBE, reasonable potential analysis will be
performed to assess the need for an MTBE limit. In non -water supply waters, the instream MTBE standard
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
is 2393 µg/ L, and is unlikely to be violated. All facilities discharging to water supply waters will have a
special condition added to the permit that pertains to MTBE monitoring and source reduction (see Part
III.C.)
II. Additional Site -Specific Requirements
A. EPA Method 624
Monitor semi-annually
The entire 624/625 scan was originally included in the SOP to assess which of the petroleum -associated
organic chemicals are found in stormwater. These tests scan for volatile and semi -volatile organics and
cost approximately $700 to run (Ray Kelling, personal communication 2/14/01). Currently, the oil
terminal facilities are performing the scan twice a year. Most facilities obtain results consisting entirely of
non -detects, but a few have detected one or more of the compounds on the 624/625 list. Tables 1 and 2
summarize the compounds included in the scans and note those parameters detected during the last
permitting cycle.
After a review of the data and discussions with different members of the Division of Water Quality Point
Source Branch, it has been decided to assign semi-annual monitoring using EPA Method 624 to any of the
facilities that detected any compound listed in Table 1 that is not benzene, toluene, ethylbenzene, xylene or
naphthalene (as these were found in most discharges and are covered by monitoring requirements listed
above) .
Table 1. Compounds detectable by EPA Method 624
PARAMETER
DETECTED IN OIL TERMINAL STORMWATER?
Acrolein
Acrylonitrile
Benzene
1
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane
✓
Dibromochloromethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1, 1-Dichloroethane
trans- 1 ,2-Dichloroethene
1,2-Dichloropropane
cis- 1,3-Dichloropropene
trans- 1,3-Dichioropropene
Ethyl benzene
1
Methylene chloride
1
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
1
1, 1, 1-Trichloroethene
1,1,2-Trichloroethene
Trichloroethane
Trichlorofluoromethane
1
Vinyl chloride
✓
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
Table 2. Compounds detectable by EPA Method 625
aPARAMETER r .
Acenaphthene
DETECTED IN OIL TERMINAL STORMWATER?
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene•
Benzo(a)pyrene
Benzo(ghi)perylene
Benzyl butyl phthalate
Bis(2-chloroethyl)ether
Bis(2-chloroethoxy)methane
Bis(2-e thylhexyl)phthalate
Bis(2-chloroisopropyl)ether
4-Bromophenyl phenyl
ether
2-Chloronaphthalele
4-Chlorophenyl phenyl
ether
Chrysene
Dibenzo (a, h) an thracene
Di-n-butylphthalate
1, 3-Dichlorobenzene
1,2-Dichlorobenzene
1, 4-Dick lorobenzene
_ 3,3'-Dichlorobenzidine
Diethyl phthalate
Dimethyl phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octylphthalate
1
Fluoranthene
Fluorene
_ Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Indeno(1,2, 3-cd)pyrene
Isophorone
_ Naphthalene
1
Nitrobenzene
N-Nitrosodi-n-propylamine
PCBs
Phenanthrene
1
Pyrene
Toxaphene
1,2,4-Trichlorobenzene
_
4-Chloro-3-methylphenol
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dini phenol
2-Me___y1-4,6-dinitrophenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
1
2,4,6-Trichlorophenol
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
B. Reasonable Potential (General)
The reasonable potential procedure is a method used to determine the potential of a discharge to violate a
water quality standard for a given parameter based on existing data. If a parameter is determined to have
reasonable potential to violate a water quality standard, a limit and monthly monitoring will be required. A
parameter is determined to have reasonable potential to violate a water quality standard if a calculated
maximum predicted effluent concentration is greater than the allowable effluent concentration.
Reasonable potential is determined by performing a statistical analysis for each parameter of concern that
has either a state or federal water quality standard. For each parameter, the statistical analysis works best
with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more
accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent
concentration based on the existing data set. A step-by-step procedure for determining whether or not a
parameter should be limited based on reasonable potential determination follows:
STEP
1. Determine the number of sample points (n)
2. Determine highest value from data set. Best professional judgment should be used by the reviewer so
as not to use an outlier. Since an outlier will not be determined statistically, maximum values should
rarely be discarded in this analysis.
3. Determine the coefficient of variation (CV = STD DEV/MEAN)
4. Determine the appropriate multiplication factor to be used by comparing the number of samples versus
the co -efficient of variation (see Table 3-1)
5. Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to
obtain the maximum predicted effluent concentration.
6. Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable
effluent concentration, which is based on instream dilution and the corresponding water quality
standard. EPA recommends that permitting authorities find reasonable potential when the maximum
predicted effluent concentration is greater than the allowable effluent concentration.
A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet" and is
located on the NPDES server. The spreadsheet requires the input of the facility name and permit number,
the waste flow (Qw), 7Q 10 flow, pollutant name, state or federal water quality standard, and the DMR data
points with appropriate units. The spreadsheet then computes the standard deviation, mean, and
coefficient of variation for the entered data points. The coefficient of variation is then used along with n
(the number of data points entered in the spreadsheet) to determine the Multiplication Factor. This
Multiplication Factor is entered into the Toxicant Spreadsheet to calculate the maximum predicted
concentration.
If the maximum predicted effluent concentration is greater than or equal to the allowable effluent
concentration, (or in other words, if there is reasonable potential for a water quality standard violation), the
parameter should be limited (as a daily maximum) and monitored on a monthly basis. The daily maximum
limit shall be equal to the standard for that parameter multiplied by the dilution of the receiving stream
under summer 7Q 10 conditions for non -carcinogens. Average flow should be used for carcinogens and
30Q2 flow should be used for aesthetic standards.
If a facility monitors semi-annually (twice/year), 10 data points would be obtained over a five-year permit
period which is slightly more than the minimum number of data points which will accurately characterize
an effluent discharge (USEPA March 1991).
In cases where a facility requests reconsideration of a limit requirement, monthly monitoring should be
required for at least 10 months so that 10 data points can be obtained and a second reasonable potential
calculation can be conducted. If there is no reasonable potential for a water quality violation, monitoring
should be reduced (to semi-annually).
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. Turbidity Monitoring (Paw Creek terminals)
Monitor quarterly
(Monthly monitoring and limit of 50 NTU if facility demonstrates reasonable potential)
Based on concerns regarding anti -backsliding, the EPA requested the Division re-examine the basis for the
elimination of turbidity monitoring for 12 of the 14 Paw Creek oil terminals that were required to monitor
for turbidity prior to the most recent permit renewal. This second examination of the data showed that
there were turbidity standard violations since the last analysis at several of the oil terminals. The Division
therefore acknowledges that its second evaluation resulted in a different outcome from the initial
investigation and agrees that turbidity monitoring should be added to the discharge permits for the oil
terminals in Paw Creek. Facilities were sent notice in February 1999 that quarterly turbidity monitoring
would be required at the facility effective March 1, 1999. If sufficient data exist, then reasonable
potential should be performed to assess the need for more frequent monitoring and a limit of 50
NTU. For all facilities, the following footnote will be placed on the effluent limits page:
*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.
III. Additional Monitoring Requirements for Water Supply (WS) Waters
A. Phenol
Monitor monthly
(Limit assigned if reasonable potential is demonstrated)
Phenol is a common component of petroleum compounds stored in terminals, can result in tainting of fish
tissue, and can cause taste and odor (organoleptic) problems in drinking water. In addition, phenol
discharged from terminals could combine with chlorine in water treatment facilities to form chlorinated
phenols. Limiting the discharge of phenol into water supply classified waterbodies could reduce
chlorinated phenol formation and their concentration in drinking water. As a result of the expected
occurrence of phenol in oil terminal facility discharges and the possibility of chlorinated phenol formation,
phenol will be monitored on a monthly basis in water supply classified waters.
Based on an extensive review and analysis of data collected during the last permitting cycle, the facilities
are no longer required to monitor for chlorinated phenols, since none were ever detected in oil terminal
effluent. The concern over limiting phenols lies in the need to inhibit formation of chlorinated phenolic
compounds at downstream water treatment plants. Joe Corporon of the NPDES Unit calculated an
allowable phenolic loading for each terminal in Mecklenburg County that will prevent a downstream
violation of the NC State standard for phenols of 1 gg/L. Meg Kerr wrote a similar memo for those
terminals in Guilford County in 1983. Reasonable potential will be performed using these allowable
phenolic loadings (see attached memo).
B. Benzene
Monitor monthly
Daily maximum limit - 1.19 14/1 * dilution of the receiving stream under average flow conditions
Benzene is a known carcinogen and can pose a potential health risk to humans consuming water with
benzene. The water quality standard for benzene in waters classified as water supplies is 1.19 µg/1. The
daily maximum limit for these facilities is therefore 1.19 multiplied by the dilution of the receiving stream
under average flow conditions (rounded to two significant digits). This limit may be excluded from the
permit only if there are sufficient data (eight sampling events) to demonstrate "no reasonable potential." If
there is no reasonable potential, there will only be a monthly monitoring requirement.
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities •
C. MTBE
Monitor monthly
MTBE special condition
Given that thiscompound is considered a possible carcinogen, there should be a greater effort to keep high
levels of MTBE out of water supply waters. As per the Paw Creek Hearing Officer's Report, after one year of
monthly MTBE samples have been recorded, the facility must review the MTBE data. If no MTBE has been
detected in the effluent samples, the facility may request a minor modification to the permit reducing the
frequency of MTBE monitoring. If, however, MTBE has been detected during any of the discharge events,
the Permittee must develop a plan of action to reduce the levels of MTBE entering the receiving stream.
It is anticipated that an MTBE criterion for surface waters will be established at the time of the next permit
renewal. At that time, sufficient data will be available to assess the reasonable potential for a facility to
exceed any such standard or criterion.
REFERENCES
Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering
News.
Kelling, Ray, (Division of Water Quality Chemistry Lab). June 1996. Conversations with P. Clark.
Kelling, Ray, (Division of Water Quality Chemistry Lab). February 2001. Conversations with N. Sierra.
Linville, Ron, (Winston-Salem Regional Office). March 1996. Telephone conversation with P. Clark.
Reid, Dianne, (Division of Water Quality - Planning Branch). June 1996. Conversations with P. Clark.
Shiver, Rick, (Wilmington Regional Office). July 2001. Findings and Recommendations for Public Hearing
Held on April 19, 2001.
USEPA. March 1991. Technical Support Document For Water Quality -Based Toxics Control. EPA/ 505 / 2-
90-001.
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DENR / DWQ / NPDES Unit
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES Permit No: NC0031038
INTRODUCTION
Colonial Pipeline Company (also herein referred to as the permittee) 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. Colonial Pipeline Company (Table 1) operates the Charlotte Delivery Facility,
a petroleum bulk -storage and fuel distribution center in Mecklenburg County. This facility does not
have a truck -loading terminal but distributes fuel to other distributors through manifold
piping. Regulated discharge consists of stormwater runoff, slab-washdown water, hydrostatic test
water, and impound water from bulk -storage tank secondary containment. All runoff drains to a
retention pond. A groundwater remediation system also discharges to the retention pond under permit
NCG510207. The permittee monitors continuous flow weekly through Outfall 001.
Table 1.
Colonial Pipeline Company — Water Pollution Control System
Facility Information
Applicant/FaciIity Name 1,2
Colonial Pipeline Company / Charlotte Delivery Facility
Applicant Address 1'2
P.O. Box 87, Paw Creek, NC 28130
Facility Address 1,2
7524 Kenstead Circle, Paw Creek
Permitted Flow (MGD) 2
Outfall 001 - Not limited
Type of Waste 1,3
Industrial runoff wastewater. SIC Code 5157
Ground Water REM: Permit NCG510207
Facility/Permit Status 1'3
Oil Terminal Pollution Prevention Control System / Renewal
Drainage Basin / County 1'2
Catawba / Mecklenburg
Miscellaneous
Receiving Stream 44
UT of Gum Branch
Regional Office
Mooresville
Stream Classification 1,5
WS-IV
State Grid /
USGS Topo Quad'
F 15 SW / Mtn.
Island Lake, NC
303(d) Listed? °
Not listed
Permit Writer '
Joe R. Corporon
Subbasin 5
03-08-34
Date: _
08Mar01
Drainage. Area (sq. ini.)7
<0.1
Summer 7Q10 (cfs)
0.0
•
Lat. 35° 17' 15" Lona. 80° 56' 05"
Winter 7Q10 (cfs)
0.0
30Q2 (cfs)
0.0
Average Flow (cfs)
0.0
IWC(%)7
100
Fact Sheet
Renewal — NPDES Permit NC0031038
Page 1

Waste Load Allocation (WLA). Colonial Pipeline Company's permit became effective September 1,
1996 with an expiration date of August 31, 2001.1'2 The Division prepared a WLA in May 1992 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 the additions and deletions listed below (see
PERMITTING APPROACH SUMMARY).
Verifying Existing Stream Conditions. This facility discharges to an unnamed tributary of Gum
Branch, a Class WS-IV stream within the Catawba River Basin. Gum Branch is not listed as an
"impaired" waterbody [not 303(d) listed].6
COMPLIANCE REVIEW
Notices of Violation (NOVs). The Division has issued no NOVs to this facility during the previous
permit cycle.
Whole Effluent Toxicity (WET) Test. Division records indicate that this facility has passed its
annual acute toxicity test (>100) for four years, from 1997 through year 2000.
Discharge Monitoring Reports (DMR) — Effluent Data Review. DMRs were reviewed from
January 1996 through December 2000. Discharges from Outfall 001 occurred irregularly, but
approximately four times per month. The permittee reported discharge monthly at rates ranging from
0.003 to 0.03 MGD. Therefore, 0.03 MGD was used as a maximum flow for reasonable potential
calculations (see below). Total Residual Solids (TRS) during this time period were detected 31 times
in 40 sampling events ranging in concentration from 2 mg/L to 24 mg/L TRS.
Twice -annual EPA 624/625 scans did not detect semi -volatile or volatile organic compounds except
phenols. Phenols were detected four times in 39 sample events with concentrations ranging from 4 to
70 µg/L. Required monitoring for xylene did not detect in 21 sampling events.This facility monitored
benzene monthly. Benzene was detected once (3.6 µg/L) in 40 events. In five years, oil and grease
were detected 16 times ranging in concentration from 0.15 to 9.02 mg/L with an average
concentration of 0.9 mg/L through 40 sample events.
Reasonable Potential Analysis. Because benzene and phenols were detected, the Division
conducted Reasonable Potential Analyses. These analyses indicate that there is reasonable potential
for both compounds to exceed Water Quality Stream Standards therefore monitoring limits for phenol
(0.17 mg/L) and benzene (1.19 µg/L) will be included in the permit (per SOP 2001) to protect the
designated WS-IV receiving stream classification.
Fact Sheet
Renewal -- NPDES NC0031038
Page 2

FACILITY INSPECTION
The Mecklenburg County Department of Environmental Protection (MCDEP) has performed several
inspections within this permitting cycle. The facility was rated "in compliance" during these
inspections and was described as "well maintained with no discrepancies noted."
PERMITTING STRATEGY
Revised Standard Operating Procedures. The Division of water Quality has revised permitting
strategies and Standard Operating Procedures (SOP) for this and all oil terminals in the state. 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 upon 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.
Compliance with the 2001 SOP. Colonial Pipeline's compliance with the 2001 SOP will remain
unchanged from the previous permit for flow, toxicity, TSS, and oil and grease (Parts I.A. through
ID.). In place of EPA Methods 624/625 monitoring requirements, the permittee must now monitor
monthly for BTEX, naphthalene and MTBE (Parts I. E, I.F and I1). Toluene was limited in the
previous permit (11.0 µg/L). Because toluene was not detected over the last permit cycle, the Division
has removed this limit. As stated above however, phenol and benzene will have discharge limits,
based on reasonable potential, as defined by the EPA.
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, and no direct discharge of hydrostatic test
water if benzene and/or toluene concentrations exceed the respective water quality standard (2001
SOP, Parts I.G. and III). Per requirements specific to Paw Creek terminals (Part II.C), Colonial
Pipeline must monitor turbidity quarterly, as mandated by the EPA.
PERMITTING APPROACH SUMMARY
• Remove toluene limit
• Incorporate benzene and xylene into monthly BTEX monitoring
• Remove the EPA Methods 624/625 monitoring requirement
• Add naphthalene monitoring
• Add MTBE monitoring
• Add quarterly turbidity monitoring
Fact Sheet
Renewal — NPDES NC0031038
Page 3

PROPOSED SCHEDULE OF ISSUANCE
Draft Permit to Public Notice: February 28, 2001.
Permit Scheduled to Issue: April 2, 2001
NPDES UNIT CONTACT
If you have questions regarding any of the above information or on the attached permit, please
contact Joe Corporon at [phone] ext. 597.
NAME: DATE:
REFERENCES
1. 2001. NPDES Permit Application Short Form C. Colonial Pipeline Company, P.O. Box 87, Paw
Creek, Permit NC003 1 038.
1995. NPDES Permit No.NC003 1038, issued to Colonial Pipeline Company, expires August 31,
2001. Copies obtained , through The Division of Water Quality, Central Files, Archdale
Building, 512 N. Salisbury St., Raleigh, North Carolina.
3. 2001. NPDES Regional Staff Report and Compliance Evaluation Inspection, for Colonial Pipeline
Company, Charlotte Delivery Terminal, NPDES Permit No. NC0031038, Mooresville Regional
Office.
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. 1999. Catawba Basinwide Water Quality Plan. North Carolina Division of Water Quality, Water
Quality Section.
6. 2000. 303(d) List of North Carolina Impaired Waters - Draft. North Carolina Division of Water
Quality, Water Quality Section. Copies obtained through Planning Branch, Archdale Building,
512 N. Salisbury St., Raleigh, North Carolina.
7. 1995. NPDES Waste Load Allocation Work Sheet, NPDES Permit No. NC0031038, conducted for the
Colonial Pipeline Company, prepared by Susan Wilson, May 7.
8. 1996-2000. Discharge Monitoring Reports (DMR) for Effluent (DEM Form MR-1), Colonial Pipeline
Company, January 1996 through December 2000.
MAY - 2 2001
UE':R — WATER ; MLITY
POii4T SOURCE Es;tARCH
Fact Sheet
Renewal -- NPDES NC0031038
Page 4

REGIONAL OFFICE COMMENTS
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NAME:
NPDES SUPERVISOR:
DATE:
tee
DATE:
Fact Sheet
Renewal — NPDES NC0031038
Page 5
s/ d
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State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
MEMORANDUM
Io:
From:
Subject:
April 2, 2001
Britt Setzer
NC DENR / DEH / Regional Engineer
Mooresville Regional Office
Natalie Sierra
NPDES Unit
ATA
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
RECEIVED
APR 0 4 2001
NCDENR
Divis on of Environmental Health
i ':j il^, Water Supply Section
Mo,-.t'.f=:ville Regional Office
Review of Draft NPDES Permit NC0031038
Colonial Pipeline Company — Charlotte Delivery Facility
Mecklenburg County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
May 2, 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.
/NNVNVNVNVNVNV/VVNVANAN/WNV.wNw//VoWNV /NV/VVANAN NANNV wNwM./wM•NV/VVNV/WNVAwININVAN w
NV NVNVNVNV NVNVNVNVNVNVNVNVNVNVANNV/WIVV/VVM//W/W/VVANNVIW/W/W/V//v//VV/VVANNVNV/W/WAN/VV/W
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.
Signed
Concurs with issuance of the above permit. provided the following conditions are met:
I
I'
III
Opposes the issuance of the above permit, based on reasons stated
below,
APR 1 1 2001
or attached:
,
DENR - WATER QUALITY
POINT SOURCE GR,1t:Cll
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.uslNPDES
919 733-5083, extension 551 (fax) 919 733-0719
Natalie.Sierra@ ncmail.net

Charles
John W. Culbreath
Sr. Environmental Technician
Mid Atlantic District
April 25, 2001
Ms. Natalie Sierra
NCDENR / Water Quality /NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Colonial Pipeline Company
Office — 704-399-5259
Fax — 704-399 9029
/PR 27 2001
DENR - WATER OU,.I.I T Y
POINT SOURCE BRAT CH
Re: NPDES Permit No. NC0031038 -Draft Permit Modification Request
Colonial Pipeline Company
Mecklenburg County
Dear Ms. Sierra:
After reviewing the above referenced draft permit, Colonial requests that the following option regarding
flow rate be included:
"Estimate by instantaneous flow rate measurement at weekly intervals"
The above option was added to the previous permit and is the most feasible for the Colonial facility.
Please consider this request before issuing the final permit.
If you have any questions or need additional information please contact me at 704-399-5259.
Very truly yours,
John W. Culbreath
7524 Kenstead Circle Paw Creek, NC 28130
P.O. Box 87 Paw Creek, NC 28130

04/19/01 13:42 FAX [phone]
CPC OPERATIONS-ENVIRON.
a 002
State of North Carolina
Department of Environment, .
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. C.W. Crider
Colonial Pipeline
P.O. Box 87
Paw Creek, North Carolina 28130
A 41 'X
p HNR
December 6, 1996
Subject: NPDES Permit Modifiation
Permit No. NC0031038
Colonial Pipeline/Charlotte Facility
Mecklenburg County
Dear Mr. Crider:
On August 2, 1996, the Division of Water Quality issued NPDES Permit No. NC0031038
to Colonial Pipeline. Per Mr. John Culbreath's written request, received November 4, 1996 and
modification fee ($100, check #198518) received December 2, 1996, the following m ofitanstaneion
has been made to the permit. Flow may be estimated at the effluent by taking Y
measurements.
Please find enclosed an amended effluent sheet which should be inserted into your permit.
The old effluent page should be discarded. All other terms and conditions contained in the original
permit remain unchanged and in full effect. This permit modification is issued pursuant to the
requirements of North and the UeSeBn �ironme Environmental Protection and
Agency.morandum of Agreement
between North C
If you have any questions, Mary Cabe can be contacted at [phone], extension 518.
Sincerely yours,
. Preston Howard, Jr.,
cc: Central Files
Facility Assessment Unit
Permits & Engineering Unit
Sohn W. Culbreath, Colonial Pipeline
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

CPC OPERATIONS-ENVIRON.
7043999029
A. O. EFFLUENT AND MUNfJ URINU REQUIREMENTS Iiermit No. NC'UtW31U311
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge
stormwater, washdown slab water, prover loop calibration water, and hydrostatic test water from the pond outfall, serial number 001. Such
discharge shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Flow'
Total Suspended Solids
Oil and Grease2
Phenol
Benzene
Toluene
Xylene
EPA Methods 624/6253
Acute Toxicity4
Discharge Limitations Monitoring Requirements
Measurement Sample Sample
Monthlv Avg. Weekly Avg, Daily Max, frequency Tune _imation
Monthly
45.0 mg/I Monthly Grab
Monthly Grab
Monthly Grab
Monthly Grab
11.0 ug/1 Monthly Grab
Semi-annually Grab
Semi-annually Grab
Annually Grab
•
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Eft
Effluent
1 Where no measurable discharge occurs, "no discharge" should be clearly noted on the submitted monthly discharge monitoring report.
Flow may be monitored in one of five ways: a) Measure flow continuously, b) Calculate flow based on the area draining to the outfall, the built upon
area, and the total rainfall (this method of :flow measurement should not be used at facilities that have large ponds to collect
surface water runoff), c) Estimate by flow measurement at 20 minute intervals during the entire discharge event, d) Base flow on pump logsor
pir e) Estimate by instantaneous flow measurement at weekly intervals.
2 Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone. .
'' 3 EPA Method 625 includes five (5) chlo ophenols. If one or more chlorophenol(s) is detected at concentrations greater than or equal to 50 tgil, the
will be required to analyze for the eight chlorophenols (listed below) in addition to EPA Method 625. This additional required monitoring will
with the pern ittee's next scheduled monitoring event, occur on a semi-annual basis, and will last for the duration of the permit. The eight
_..__._phenols include the following. 3-chlorophenol, 4-chlorophenol, 2,3-dichlorophenol, 2,5-dichlorophenol, 2,6-dichlorophenol, 3,4 .
dichlorophenol, 2,3,4,6-tetrachlorophenol, and 3-methy1-6-chlorophenol.
4 Acute Toxicity (Fathead Minnow, 24-hour) Monitoring, Annual, See Part III, Condition E.
2 There shall be no discharge of floating solids or visible foam in other than trace amounts.
�' There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct discharge of tank contents following hydrostatic testing unless the benzene
concentrarion is less than 1.19 ug/I and toluene concentration is less than 11 ug11.

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04/ 19/01 13 : 43 FAX [phone] CPC OPERATIONS-ENVIRON. Ia 004
• a
Colonial Pipeline Company
• Creating Excellence In Transportation Services
John W. Culbreath Office - 704-399-5259
Associate Environmental Technician Fax - 704-399-9029
October 25, 1996
Ms. Mary Cabe
NCDEI1NR / Water Quality Section
P. O. Box• 29535
Raleigh, NC 27626-0535
RE: Request for Modification of NPDES Permit No. NC0031038
Colonial Pipeline Company / Mecklenburg County
Dear Ms. Cabe:
Colonial requests modification to the above referenced permit regarding the current requirement of
continuous flow measurement of the effluent from the retention pond. The pond is spring -fed and
discharges continuously. In order to measure the flow continuously, major modifications would be
required, including installation of a chart recorder, associated wiring, shelter for the unit, and a flume
Or weir equipped with a stilling well. I discussed this with Paul Clark of NCDEHNR on August 29,
1996, who granted Colonial temporary approval to use instantaneous flow measurements taken at
weekly intervals from the discharge pipe of the pond as an alternative. He was to discuss the smatter
further with other members of the department before making a permanent change to the permit.
Colonial requests your permission to continue using -the alternative method on a permanent basis.
Thank you for your cooperation regarding this matter. If you have any questions or require any
additional information, I can be reached at 704-399-5259.
cc: D. C. Miller
J. D. Quakenbush
Sincerely,
John W. Culbreath
Asso. Environmental Technician
P. O. Box 87 Paw Creek, NC 28130

Colonial Pipeline Company
John W. Culbreath
Environmental Technician
Mid -Atlantic District
March 23, 2001
Ms. Natalie Sierra
NCDENR / Water Quality /NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit No. NC0031038 -Permit renewal -additional items
Colonial Pipeline Company
Mecklenburg County
Dear Ms. Sierra:
Office — 704-399-5259
Fax — 704-399 9029
r
Ca
Attached you will find the additional information requested by your department concerning the above
referenced permit renewal:
1) Site plan indicating all sources of stormwater, washwater, and other wastewater
2) A brief description of tank bottom water and sludge removal
Per our phone conversation, the DMR data for the past five years is not included since the draft permit
has already been written.
If you need additional information feel free to give me a call.
Very truly yours,
John W. Culbreath
Enclosures
7524 Kenstead Circle Paw Creek, NC 28130
P.O. Box 87 Paw Creek, NC 28130

Colonial Pipeline Company
TANK BOTTOM WATER AND SLUDGE DISPOSAL SI IMMARY
CHARLOTTE DELIVERY FACILITY
Water that accumulates in the petroleum storage tanks is manually removed via the
facility's "stingwater" system. The stingwater system consists of a piping network attached to
the low point of each individual tank line. The water/product mixture is piped to the primary
oil/water separator where the bulk of the separated product is recovered. The remaining
petroleum contact water (PCW) is pumped into one of two available phase separation tanks.
The water from the phase separation tanks can be handled two different ways:
1) It is processed on site and disposed of under the facility spray irrigation permit
2) It is off-loaded and shipped to one of Colonial's approved reclamation facilities.
These facilities are able to recover additional product and dispose of the water
under their respective discharge permits
Tank bottom sludge is mixed with water during the tank cleaning process to form a pumpable
slurry. The slurry is removed from the tank via a vacuum/tanker truck and transported to a
Colonial approved reclamation facility. Liquids are processed as described above. The
residual solids are processed by the reclamation facilities in a manner that extracts additional
recoverable product, and renders the remaining sludge -cake a non -hazardous waste.
C:\My Documents\Charlotte\NPDES\Tank Bottom Water Disposal Plan.doc

SOC PRIORITY PROJECT: Yes_ No X
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: April 9, 2001
NPDES STAFF REPORT AND RECOMMENDATION
County: Mecklenburg
MRO No.: 01-52
Permit No. NC0031038
PART I - GENERAL INFORMATION
1. Facility and Address: Colonial Pipeline Company
Post Office Box 87
Paw Creek, North Carolina 28130
2. Date of Investigation: 04-03-96
3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. John Culbreath, Environmental Engineer;
[phone]
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5. Directions to Site: From the junction of Highway I-85 and Highway 27 in Charlotte, travel
west on Highway 27 (Freedom Drive) approximately three (3) miles to Old Mt. Holly Road.
Turn right onto Old Mt. Holly Road and travel approximately 0.2 mile to intersection with
Kenstead Circle. Turn right on Kenstead Cirle and travel approximately 200 feet. The
entrance to Colonial Pipeline Company is located on the left side of the road.
6. Discharge Point(s). List for all discharge points:
Latitude: 35° 17' 17" Longitude: 80° 56' 08"
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on
map.
USGS Quad No.: F 15 SW USGS Quad Name: Mountain Island Lake
7. Site size and expansion are consistent with application?

Yes X No_ If No, explain:
8. Topography (relationship to flood plain included): Moderately hilly, with slopes of 3 to 7%.
The site is not located in a flood plain.
9. Location of nearest dwelling: None within 500 feet of the discharge point.
10. Receiving stream or affected surface waters: Unnamed tributary to Gum Branch.
a. Classification: WS-IV
b. River Basin and Subbasin No.: Catawba River Basin; 030834
c. Describe receiving stream features and pertinent downstream uses: Discharge will
take place into an unnamed tributary to Gum Branch. General C classification uses
downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Type of wastewater to be permitted:
0% Domestic
100% Industrial
a. Volume of Wastewater: The wastewater is generated from storm water that falls into
the manifold area and is collected in a french drainage system. Petroleum constituents
are introduced into the storm water from any free phase petroleum that enters the
underground drainage system as the result of a spill or from slab wash down water.
The current permitted capacity for groundwater remediation is 0.0648 MGD.
b. What is the current permitted capacity of the wastewater treatment facility? The
current permitted capacity for groundwater remediation is 0.0648 MGD.
c. Actual treatment capacity of the current facility (current design capacity)? N/A.
d. Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two years: N/A
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: The existing treatment consists of an oil water separator(at the
manifold area) that discharges to an unnamed tributary, located on the north side
of the property, leading to the main pond located on the property. A ground water
remediation system consisting of an oil/water separator, diffused air unit, and
NPDES Permit Staff Report
Page 2

activated carbon adsorption unit, discharges to an unnamed tributary, located on
the south side of the property, that leads to the main pond. Storm water run-off
from the tank area located on the south side of the property discharges to a smaller
pond above the main pond (The smaller pond discharges to the unnamed tributary
located on the south side and subsequently to the main pond). Also, Storm water
run-off from the tank area located on the north side of the property discharges via
a pipe to the main pond (without treatment).
f. Please provide a description of proposed wastewater treatment facilities: N/A
g. Possible toxic impacts to surface waters: Due to nature of the wastewater there
could be some toxicity concern.
h. Pretreatment Program (POTWs only): N/A.
2. Residuals handling and utilization/disposal scheme: Sludge accumulates in the oil/water
separator at a rate such that cleaning only needs to be done every five to ten years. When
cleaning is done the company contracts a licensed waste disposal facility for removal and
disposal. The tank bottom water is treated/disposed on site as approved by Permit No.
WQ0004751.
3. Treatment plant classification (attach completed rating sheet): Proposed, no rating
given.
4. SIC Code(s): 5171
Primary: 39
Main Treatment Unit Code: 53000
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? N/A.
2. Special monitoring or limitations (including toxicity) requests: Toxicity may need to be
limited/monitored due to the suspected toxic nature of such discharges.
3. Important SOC, JOC or Compliance Schedule dates: (please indicate) N/A.
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge
options available. Please provide regional perspective for each option evaluated.
NPDES Permit Staff Report
Page 3

Spray irrigation: N/A
Connection to regional Sewer System: N/A
Discharge to an infiltration gallery:N/A
5. Air Quality and/or Groundwater concerns or hazardous material utilized at this facility that
may impact water quality, air quality or groundwater? Contaminated groundwater already
exists at the site. Air Quality Permit for this facility is required by Mecklenburg County.
6. Other Special Items: As mentioned above, there are 4 separate discharges that lead to the
main pond located on the property. During the investigation, it was learned that the
samples are collected at the effluent of the main pond. It should be noted that this pond is
considered to be an impoundment since it is fed by three unnamed tributaries. The samples
collected at this pond might not be a representative samples due to dilution.
PART IV - EVALUATION AND RECOMMENDATIONS
Colonial Pipeline Company is requesting an NPDES Permit renewal for the discharge of
treated wastewater. The wastewater is generated from a ground water remediation system, an oil
water separator (located at the manifold area), and stormwater runoff.
It is recommended that the NPDES Permit be renewed to include sampling at each
discharge location.
( 6/A-Pe,--7 Z `c-- /0 _ Iv
Signature of Repo Preparer Date
f---10/0/
Water Quality Regional Supervisor Date
NPDES Permit Staff Report
Page 4

REASONABLE POTENTIAL ANALYSIS
Prepared by: Natalie Sierra, 9/12/00 .0 rA `AAyr (� L�
`t"t �I �C�
Facility Name =
NPDES # =
Qw (MGD) =
Qw (cfs) =
7Q 10s (cfs)=
IWC (gib) =
Colonial Pipeline - G'boro
0
NC0031038
0.3000
0.4642
0
100.00
Chronic CCC w/s7Q10 dil. Acute CMC w/no dil.
Frequency of Detection
Parameter
FINAL RESULTS, ug/I FINAL RESULTS, ug/I
#Samples # Detects
Phenols
Max. Pred Cw
22.4
Allowable Cw
1.0
35 2
Xylene
Max. Pred Cw
ND
Allowable Cw
88.5
20 0
Benzene
Max. Pred Cw
8.5
Allowable Cw
1.2 .
36 1
Toluene
Max. Pred Cw
ND
Allowable Cw
11.0
0 0
Ethylbenzene
Max. Pred Cw
ND
Allowable Cw
524.0
0 0
Napthalene
Max. Pred Cw
ND
Allowable Cw
43.0
0 0
MTBE
Max. Pred Cw
ND
Allowable Cw
11.6
0 0
Phenanthrene
Max. Pred Cw
�
ND ..- L. C.'
Allowable Cw
no limit tNfl
0 0
Methylene Chloride
"
Max. Pred Cw
ND 1 `%
Allowable Cw
4.7 JQ
0 0
Dl-n-Octylphthalate
Max. Pred Cw
33.0
Allowable Cw
0.012
7 1
0
Max. Pred Cw
0.0
Allowable Cw
NA
0 0
0
Max. Pred Cw
0.0
Allowable Cw
0.0
0 c
0
Max. Pred Cw
0.0
Allowable Cw
0.0
0 0
0
Max. Pred Cw
0.0
Allowable Cw
0.0
0 0
Modified Data: Use 0.5 Detection Limit for non -detects
OCT (4 SfG�5
.,-0-k
Parameter =
Standard =
Dataset=
Modified Data
3.9
0.5
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
5
5
2.5
5
8
0.5
5
2.5
0.5
0.5
0.5
0.5
0.5

Colonial Pipeline - Charlotte
DMR Data
Discharge 001
NC0031038
Date Ave. Flow TSR
Oil & Grease Benzene Phenol JXylene
(MGD) (mg/L) (mg/L) (mg/L) (mg/L) (mg/L)
8/8/96
0.0063
7
<1.00
<0.001
9/10/96
0.0069
2
9.02
<0.001
0.0039
10/8/96
0.0058
14.4
<1.00
<0.001
<0.001
12/5/96
0.01
<2.0
1.1
<0.001
<0.004
3/5/97
0.0042
3.4
<1.0
<0.001
<0.002
4/14/97
0.0039
<2.0
<1.0
<0.001
<0.002
5/27/97
0.0057
4
<1.0
<0.001
<0.002
<0.003
7/28/97
0.0178
6.8
<1.0
<0.001
<0.002
8/25/97
0.015
4.6
<1.0
<0.001
<0.002
9/16/97
0.0059
<2.0
<1.0
<0.001
<0.002
10/22/97
0.0135
2.4
5.7
<0.001
<0.002
11/25/97
0.0115
<2.0
<1.0
<0.001
<0.002
2/9/98
0.0685
<2.0
<1.0
<0.001
<0.002
3/10/98
0.0335
9.4
<1.0
<0.001
<0.002
4/22/98
0.0425
14
<1.0
<0.001
<0.002
5/13/98
0.073
2.2
1
<0.001
<0.002
<0.002
6/15/98
0.061
2
5.5
<0.001
<0.002
8/11/98
0.055
3
<1.0
<0.001
<0.002
10/22/98
0.081
4.8
2.5
<0.001
<0.002
12/15/98
0.105
8.4
1.89
<0.001
<0.002
1/12/99
0.092
<2.0
<1.0
<0.001
<0.002
<0.003
3/16/99
0.0875
7
1.96
<0.001
<0.002
<0.003
4/5/99
0.0975
8.6
5.27
<0.001
<0.002
<0.003
5/4/99
0.087
<1.0
<1.0
<0.001
<0.01
<0.001
6/23/99
0.082
3.2
<0.8
<0.001
<0.01
<0.001
8/18/99
0.078
5
1.15
<0.001
<0.05
<0.001
9/23/99
0.082
2
<1.0
<0.001
<0.01
<0.001
10/13/99
0.003
24
<5.0
0.0036
0.008
12/9/99
0.075
9.6
<0.9
<0.001
<1
<1
1 /11 /00
0.15
17.6
0.21
<0.005
<0.01
<0.005
2/10/00
0.3
<2.0
0.15
<0.001
<0.05
<0.001
3/22/00
0.175
12.8
0.2
<0.001
<0.01
<0.001
4/12/00
0.05
3
0.25
<0.001
<0.01
<0.001
5/24/00
0.153
<1.0
0.32
<0.001
<0.01
<0.001
6/20/00
0.16
4
<1
<0.001
<0.01
<0.001
7/26/00
0.05
4
0.181
<0.001
<0.01
<0.001
8/18/00
0.0245
17
<5
<0.001
0.07
<0.001
9/11/00
0.0245
6
<5
<0.005
0.02
<0.005
10/18/00
0.049
5
<5
<0.001
<0.01
<0.001
12/27/00
0.049
16
<5
<0.001
<0.01
<0.001
average
max
0.062
0.3

Date : Oct-96
EPA 624
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon Tetrachloride
Chlorobenzene
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
1,2-Dibromoethane
1,1-Dichloroethane
1,2-Dichloroehtane
1,4-Dichlorobenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,1-Dichloroethene
trans-1,2-dichloroethane
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethyl benzene
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethane
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethane
Trichlorofluoromethane
Vinyl chloride
Xylene
Acrolein
Acrylonitrile
Outfall 1
<1
<5
<5
<10
<5
<2
<10
<5
<2
<10
<5
<5
<5
<2
<2
<2
<5
<5
<5
<2
<2
<1
<5
<5
<5
<1
<5
<5
<5
<5
<5
<2
<25
<25
EPA 625
Acenaphthene
Acenaphthylene
Anthracene
Benzo(a)anthracene
Benzo(a)pyrene
Benzl butyl phthalate
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
2-Chloronapthalene
2-chlorophenol
4-Chlorophenyl phenyl ether
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
Date : Mar-97
Nov-97
Outfall 1 Outfall 1
EPA 624
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon Tetrachloride
Chlorobenzene
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
1,2-Dibromoethane
1,1-Dichloroethane
1,2-Dichloroehtane
1,4-Dichlorobenzene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,1-Dichloroethene
trans-1,2-dichloroethane
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethyl benzene
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethane
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethane
Trichlorofluoromethane
Vinyl chloride
Xylene
Acrolein
Acrylonitrile
EPA 625
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(a)pyrene
Benzo(g,h, I)perylene
Benzo(k)fluoranthene
Bis(2-chloroethoxy)rnethane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Benzl butyl phthalate
<2 <2
<5 <5
<10 <10
<10 <10
<5 <5
<2 <2
<10 <10
<5 <5
<2 <2
<10 <10
<5 <5
<5 <5
<5 <5
<2 <2
<2 <2
<2 <2
<5 <5
<5 <5
<5 <5
<2 <2
<2 <2
<1 <1
<5 <5
<5 <5
<5 <5
<1 <1
<5 <5
<5 <5
<5 <5
<5 <5
<5 <5
<2 <2
<25 <25
<25 <25
<10 <10
<10 <10
<10 <10
<80
<10 <10
<10 <10
<10 <10
<10 <10
<10 <10
<10 <10
<10 <10
<10 <10
<10 <10
<10 <10

2-Chloronapthalene <10
2-chlorophenol <10
4-Chlorophenyl phenyl ether <10
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
Diethyl phthalate
Dimethylphthalate
Di-n-octylphthalate
1,2-Diphenylhydrazine
Fluoroanthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
Napthalene
Nitrobenzene
N-Nitrosodimethylamine
N-Nitrosodi-n-propylamine
N-Nitrosodiphenylamine
Phenanthrene
1,2,4-Triclorobenzene
3,3'-Dichlorobenzidine
Benzidine
3,3-Benzofluoranthene
1-Methylnaphthalene
2-Methylnaphthalene
2,4-Dichlorophenol
2,4-Dimethylphenol
4,6-Dinitro-2-methylphenol
2,4-Dinitrophenol
2-Nitrophenol
4-Nitrophenol
p-Chloro-m-cresol
Pentachlorophenol'
Pyrene
2,4,6-Trichlorophenol
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<20
<80
<10
<10
<10
<10
<10
<50
<50
<10
<50
<10
<50
<10
<10
'Date :
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Benzl butyl phthalate
2-Chloronapthalene
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1.3-Dichlorobenzene
1,4-Dichlorobenzene
3, 3'-Dichlorobenzidine
Diethyl phthalate
Dimethylphthalate
Di-n-butylphthalate
2.4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octylphthalate
1,2-Diphenylhydrazine
Fluoroanthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
Napthalene
Nitrobenzene
N-Nitrosodimethylamine
N-Nitrosodi-n-propylamine
N-Nitrosodiphenylamine
Phenanthrene
Pyrene
1,2,4-Triclorobenzene
2-chlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
4,6-Dinitro-2-methylphenol
2,4-Dinitrophenol
2-Nitrophenol
4-Nitrophenol
p-Chloro-m-cresol
Pentachlorophenol'
2,4,6-Trichlorophenol
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
NA
<10
<10
<10
<50
<10
<10
<10
<10
<10
NA
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<10
<20
<10
Jan-98 May-98 Date : Jan-99 Sep-99
Out fall 1 1Outfalll
Outfall 1 Outfall 1

Bromomethane
Carbon Tetrachloride
Chlorobenzene
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
1,1-Dichloromethane
1,2-Dichloromethane
1,1-Dichloroethane
cis-1,2-Dichloroethene
trans-1,2-dichloroethene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethyl benzene
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethane
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethane
Trichlorofluoromethane
Vinyl chloride
Xylene
EPA 625
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Benzo(g,h,l) perylene
Benzl butyl phthalate
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
4-Chloro-3-methylphenol
2-Chloronapthalene
2-chlorophenol
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
<10
<5
<5
<10
<10
<5
<10
<5
<5
<5
<5
<5
<2
<2
<5
<2
<2
<1
<5
<5
<5
<1
<5
<5
<5
<5
<5
<2
<10
00110111 <10
<10
<80
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<5
<5
<10
<10
<5
<10
<5
<5
<5
<5
<5
<2
<2
<5
<2
<2
<1
<5
<5
<5
<1
<5
<5
<5
<5
<5
<2
<10
<10
<10
<80
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
Bromomethane
Carbon Tetrachloride
Chlorobenzene
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
1,1-Dichloromethane
1,2-Dichloromethane
1,1-Dichloroethane
cis-1,2-Dichloroethene
trans-1,2-dichloroethene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethyl benzene
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethane
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethane
Trichlorofluoromethane
Vinyl chloride
Xylene
EPA 625
<10
<5
<5
<10
<10
<5
<10
<5
<5
<5
<5
<5
<2
<2
<5
<2
<2
<1
<5
<5
<5
<1
<5
<5
<5
<5
<5
<2
<10
<5
<5
<10
<10
<5
<10
<5
<5
<5
<5
<5
<2
<2
<5
<2
<2
<1
<5
<5
<5
<1
<5
<5
<5
<5
<5
<2
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Benzo(g,h,l) perylene
Benzl butyl phthalate
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
4-Chloro-3-methylphenol
2-Chloronapthalene
2-chlorophenol
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
<10
<10
<10
<80
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<80
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10

1,4-Dichlorobenzene
2,4-Dichlorophenol
Diethyl phthalate
2,4-Dinitrophenol
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Fluoroanthene
Fluorene
Hexachlorobenzene -064
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
2-Methyl-4,6-Dinitrophenol
Napthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
N-Nitrosodimethylamine
N-Nitrosodi-n-propylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
1,2,4-Triclorobenzene
2,4,6-Trichlorophenol
3,3-Dichlorobenzidine
1,2-Diphenylhydrazine
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<50
<10
<10
<50
<10
<10
<10
<10
<10
<20
<20
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<50
<10
<10
<50
<10
<10
<10
<10
<10
<20
<20
Date :
Jan-00
EPA 624
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromoform
Bromomethane
Carbon Tetrachloride
Chlorobenzene
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
1,1-Dichloromethane
1,2-Dichloromethane
1.1-Dichloroethane
Icis-1,2-Dichloroethene
Outfall 1
<25
<25
<1
<5
<5
<10
<5
<5
<10
<10
<5
<10
<5
<5
<5
<5
1,4-Dichlorobenzene
2,4-Dichlorophenol
Diethyl phthalate
2,4-Dinitrophenol
2,4-Dim ethyl phenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Fluoroanthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
2-Methyl-4,6-Dinitrophenol
Napthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
N-Nitrosodimethylamine
N-Nitrosodi-n-propylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
1,2,4-Triclorobenzene
2,4,6-Trichlorophenol
3,3-Dichlorobenzidine
1,2-Diphenylhydrazine
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<50
<10
<10
<50
<10
<10
<10
<10
<10
<20
<20
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<50
<10
<10
<50
<10
<10
<10
<10
<10
<20
<20

trans-1,2-dichloroethene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,2-Dichloropropane
cis-1,3-Dichloropropene
trans-1,3-Dichloropropene
Ethyl benzene
Methylene chloride
1,1,2,2-Tetrachloroethane
Tetrachloroethane
Toluene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethane
Trichlorofluoromethane
Vinyl chloride
Xylene
EPA 625
Acenaphthene
Acenaphthylene
Anthracene
Benzidine
Benzo(a)anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Benzo(a)pyrene
Benzo(g,h,l) perylene
Benzl butyl phthalate
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
4-Chloro-3-methylphenol
2-Chloronapthalene
2-chlorophenol
4-Chlorophenyl phenyl ether
Chrysene
Dibenzo(a,h)anthracene
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
2,4-Dichlorophenol
Diethyl phthalate
2,4-Dinitrophenol
2,4-Dimethylphenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Fluoroanthene
Fluorene
Hexachlorobenzene
<5
<2
<2
<5
<2
<2
<1
<5
<5
<5
<1
<5
<5
<5
<5
<5
<2
<10
<10
<10
<80
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<50
<10
<10
<10
<10
<10
<10
<10

Hexachiorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Indeno(1,2,3-cd)pyrene
Isophorone
2-Methyl-4,6-Dinitrophenol
Napthalene
Nitrobenzene
2-Nitrophenol
4-Nitrophenol
N-Nitrosodimethylamine
N-Nitrosodi-n-propylamine
Pentachlorophenol
Phenanthrene
Phenol
Pyrene
1,2,4-Triclorobenzene
2,4,6-Trichlorophenol
3,3-Dichlorobenzidine
1,2-Diphenylhydrazine
3,3-Dichlorobenzidine
1,2-Diphenylhydrazine
<10
<10
<10
<10
<10
<50
<10
<10
<10
<50
<10
<10
<50
<10
<10
<10
<10
<10
<20
<20
NA
<100

Analytical Results Summary
Annual Whole Effluent Toxicity (WET) Testing
Colonial Pipeline -- Permit NC0031038
-G ria RoTPRl
Aug-96
0%
0%
5.00%
0%
10.00%
0%
20%
0%
40%
0%
70%
0%
100%
0%
Jan-97
0%
0%
5.00%
0%
10.00%
0%
20%
0%
40%
0%
70%
0%
100%
0%
Mar-97
0%
0%
5.00%
0%
10.00%
0%
20%
0%
40%
0%
70%
0%
100%
0%
Jan-98
0%
0%
5.00%
0%
10.00%
0%
20%
0%
40%
0%
70%
0%
100%
0%
Jan-99
0%
0%
5.00%
0%
10.00%
0%
20%
0%
40%
0%
70%
O%
100%
0%
Jan-00
0%
0%
5.00%
0%
10.00%
0%
20%
0%
40%
0%
70%
O%
100%
O%

Whole Effluent Toxicity Testing Self -Monitoring Summary
February 16, 2001
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
Colonial Pipeline- RDW002 PERM: 24 HR AC MONIT EPIS FTHD (GRAB) 1997 - - - - - - - - -
NC0081469/002 Begin:7/I/1999 Frequency: A NonComp: 1999 - - - - - - - - - - NRM
County: Woke Region: RRO Subbasin: NEU02 1999 - - - - - - - - - NR
PF: VAR Special 2000 - - - - - - - - - - NR
7Q10:0.0 IWC(%):100.0 Omer: 2001
Colonial Pipeline -Charlotte Perm 24hr LC50 ac monit cpis Ithd (grab) 1997 >100 -
NC0031038/001 Bcgin:9/1/I996 Frequency: A NonComp: 1998 Pass >100
County: Mecklenburg Region: MRO Subbasin: CTB34 1999 -- >100 -
PF: N/A Spacial 2000 - - >100
7Q10: 0 IWC(%):100.0 Order: 2001
Colonial Pipeline -Selma Pcrm 24hr LCSO tic rnonit epic (Bid (grab) 1997 >100 -
NC003I011/001 Bcgin:7/1/1999 Frequency: A NonComp: 1998 >100 -
County: Johnston Region: RRO Subbasin: NEU02 1999 - >100
PF: VAR Spacial 2000 BI -
7Q10:0.0 IWC("%):100.0 Orden 2001
>100
Colonial Pipeline/001 Pcnn 24hr LC50 ac mono cpis Rhd (grab) 1997 >100
NC0031046/001 Begin:7/1/1996 Frequency: A NonComp: 1998 >100
County: Guilford Region: WSRO Subbasin: CPF08 1999 >100
PF: NA Special 2000 Bt
7010: 0.0 IWC(%):100 Order: 2001
>100
N.
Colonial Pipeline/002 Penn 24hr LC50 ac monit epic Rhd (grab) 1997 >100
\00031046/002 Begin: 7/ I/1 995 Frequency: A NonComp: 1998 >100
County' Guilford Region: WSRO Subbasin: CPF08 1999 >100
I'F NA Special 2000 BI
7O111 0.0 IWC(•.):I(10 rider 2001
>100
Colonial Pipeline/003 Pcm, 24hr LC50 ac mom cpis Rhd (grab) 1997 >100
N00031046v0(11 Begin 7/111999 Frequency. A NonComp: 1998 >100
County: Guilford Rcgron. WSRO Su66asrrt: CPF08 1999 >100
PF- NA Spocbl 2000 BI
7QI0.. 0.0 IWC(":):100.0 Omer. 2001
- >100 - -
Colonial Pipeline/004 Pcrm 24hr LC50 tic mono epic (Rid (grab) 1997 >100
NC0031046/004 Bcgin:7/1/I996 Frequency: A NonComp: 1998 >100
County: Guilford Region: WSRO Subbasin: CPF08 1999 >100 - -
PF: NA Special 2000 Bt - >100
7010: 0.0 IWC(%):100.0 Order: 2001
Colonial Pipeline/005 Penn 24hr LC50 ac monit cpis RIr1(grab) 1997 >100
NC0031046/005 Begin:7/1/1996 Frequency: A NonComp: 1998 >100
County: Guilford Region: WSRO Subbasin: CPF08 1999 >100
PF: NA Spacial 2000 Bt
7QI0:0.0 IWC(/,):100.0 Order: 2001
>100
Colonial Pipeline/006 Perm 24hr LC50 ac monit epis Rhd (grab)
NC0031046/006 Bcgin:7/1/1996 Frequency: A NonComp:
Colony: Guilford Region: WSRO Subbasin: CPF08
PF: NA Special
7010: 0.0 1WC('/.):100 Order:
1997 --
1998 - >100
1999 - >100
2000 - -
2001
>100
>100
Color -Tex Finishing Corp. Perm chr lint: 12•/.
NC0005487/001 Begin:12/1/1999 Frequency: Q Feb May Aug Nov
County: Rowan Region: MRO Subbasin: YADO4
PF: 4.25 Special
7010: 1030 IWC(%):0.64 Onkn
+ NooComp:Singlc
y 1997 ---
1998 -
1999 -
2000 -
2001
94.57
85.54,62.37
66.80.62.37
Pass
77.37 --- 88.45 60.21 74.82 78.05
80.90 93.82 - - 73.05
92.83 -- - >100 - at
Pass - NR/Pass - - Fall
Fan
Columbus WWTP Perot chr dim: 37%
NC0021369/001 Begin:12/1/1998 Frequency: Q P/F + Mar Jun Sep Dec
County: Polk Region: ARO Subbasin: BRD02
PF: 0.8 Special
7010: 2.1 IWC(%)97.08 Order:
+ NonComp:Sing(e
Y 1997 Pass -- Pau -• Pass
1998 - -- Pass Pass
1999 - -- Pass - Pass
2000 - -- Pass - -- Pass
2001
Pass
Pass
Pass
Pass
Pass
PaS5
Pass
Pass
9 Pre 1997 Data Available
LEGEND:
PERM = Pena 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 7010 - Receiving stream low flow critcnon (cfs) -• = quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan. Apt. Jul. Oct NonComp = Current Compliance Requirement
PF = ['emitted flow (MGD) I WCS: = lastream waste concentration P/F = Pass/Fail test AC = Acute CHR = Chronic
Data Noraunn: f • Fathead Minnow; • • Cenodaphnia sp.; my • Mysid shnmp; ChV • Chronic value; P - Mortality of stated percentage at highest concentration: at - Performed by DWQ Aquatic Ton Unit; bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported Facility Activity Status: 1 - Inactive. N • Newly Issued(To construct); H - Active but nal discharging; 1-More data available for month in question: • = ORC signature needed
12

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Colonial Pipeline Company
John W. Culbreath
Environmental Technician
Mid -Atlantic District
February 9, 2001
Mr. Charles H. Weaver, Jr.
NCDENR / Water Quality /NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit No. NC0031038 - Renewal Request
Colonial Pipeline Company
Mecklenburg County DE:1R - WATER )i;A IlY
POINT SOURCE Ci ANCH
Office — 704-399-5259
Fax — 704-399 9029
Dear Mr. Weaver:
-6
Colonial Pipeline Company requests permission from your Department to renew the above referenced
permit, which will expire on August 31, 2001. The Responsible Corporate Officer for the purpose of
this renewal is now Mr. T. J. Guzikowski, General Manager -Operations for Colonial Pipeline Company.
There have been no changes to the treatment works at the facility since the last permit application.
Below is a list of the renewal package:
1. Cover letter requesting permit renewal and documentation of any changes since issuance
of the last permit (signed original and two copies)
2. The completed application form signed by the permittee (signed original and two copies)
3. A narrative description of the sludge management plan for the facility (signed original and
two copies)
The current permit includes a requirement to collect samples semi-annually for EPA Methods 624 and
625. None of the 624 / 625 compounds have ever been present in the semi-annual outfall samples
since the permit went into effect. Colonial requests that this requirement be omitted from the new
permit if possible. I will be glad to submit additional documentation regarding past results if needed.
If you have any questions or need any additional information, I can be reached at 704-399-5259.
Very truly yours,
John W. Culbreath
Environmental Technician
Enclosures
7524 Kenstead Circle Paw Creek, NC 28130
P.O. Box 87 Paw Creek, NC 28130

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. C.W. Crider
Colonial Pipeline
P.O. Box 87
Paw Creek, North Carolina 28130
Dear Mr. Crider:
Altli;54rA
C)EHNR
December 6, 1996
Subject: NPDES Permit Modifiation
Permit No. NC0031038
Colonial Pipeline/Charlotte Facility
Mecklenburg County
On August 2, 1996, the Division of Water Quality issued NPDES Permit No. NC0031038
to Colonial Pipeline. Per Mr. John Culbreath's written request, received November 4, 1996 and
modification fee ($100, check #198518) received December 2, 1996, the following modification
has been made to the permit. Flow may be estimated at the effluent by taking weekly instantaneous
measurements.
Please find enclosed an amended effluent sheet which should be inserted into your permit.
The old effluent page should be discarded. All other terms and conditions contained in the original
permit remain unchanged and in full effect. This permit modification is issued pursuant to 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.
If you have any questions, Mary Cabe can be contacted at [phone], extension 518.
Sincerely yours,
Preston Howard, Jr.,
cc: Central Files
Facility Assessment Unit
Permits & Engineering Unit
John W. Culbreath, Colonial Pipeline
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

A. (). EFFLUENT LIMITATIONS AND MONfl'URING REQUIREMENTS Permit No. N CUU31U3
Duringtheperiod beginning on the effective date of thepermit and lastinguntil expiration, authorized gi g p the Permzttee is authorized to discharge
stormwater, washdown slab water, prover loop calibration water, and hydrostatic test water from the pond outfall, serial number 001. Such
discharge shall be limited and monitored by the Pennittee as specified below:
Effluent Characteristics Discharge Limitations
Monthly Avg. Weekly Avg, Daily Max.
Flow'
Total Suspended Solids
Oil and Grease2
Phenol
Benzene
Toluene
Xylene
EPA Methods 624/6253
Acute Toxicity4
45.0 mg/1
11.0 ug/1
Monitoring Requirements
Measurement Sample
Frequency Type
Monthly 1
Monthly Grab
Monthly Grab
Monthly Grab
Monthly Grab
Monthly Grab
Semi-annually Grab
Semi-annually Grab
Annually Grab
Sample
Location
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
Effluent
1 Where no measurable discharge occurs, "no discharge" should be clearly noted on the submitted monthly discharge monitoring report.
Flow may be monitored in one of five ways: a) Measure flow continuously, b) Calculate flow based on the area draining to the outfall, the built upon
area, and the total rainfall (this method of flow measurement should not be used at facilities that have large ponds to collect
surface water runoff), c) Estimate by flow measurement at 20 minute intervals during the entire discharge event, d) Base flow on pump lop or
e) Estimate by instantaneous flow measurement at weeldy intervals.
2 Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone.
3 EPA Method 625 includes five (5) chlorophenols. If one or more chlorophenol(s) is detected at concentrations greater than or equal to 50 µg/1, the
permittee will be required to analyze for the eight chlorophenols (listed below) in addition to EPA Method 625. This additional required monitoring will
begin with the pern ittee's next scheduled monitoring event, occur on a semi-annual basis, and will last for the duration of the permit. The eight
chlorophenols include the following: 3-chlorophenol, 4-chlorophenol, 2,3-dichlorophenol, 2,5-dichlorophenol, 2,6-dichlorophenol, 3,4-
dichlorophenol, 2,3,4,6-tetrachlorophenol, and 3-methyl-6-chlorophenol.
4 Acute Toxicity (Fathead Minnow, 24-hour) Monitoring, Annual, See Part III, Condition E.
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct discharge of tank contents following hydrostatic testing unless the benzene
concentration is less than 1.19 ug/1 and toluene concentration is less than 11 ug/1.