NC0046531_Permit Issuance_20010730

ATA
NCDENR
Michael F. Easley
Govemor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
. Division of Water Quality
July 30, 2001
Mr. John Funk
Coordinator Regulatory Compliance and Training
Crown Central Petroleum Corporation
P.O. Box 78
Paw Creek, North Carolina 28130
Subject: Issuance of NPDES Permit NC0046531
Paw Creek Terminal
Mecklenburg County
Dear Mr. Funk:
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,
some of which are the result of the Paw Creek hearing officer's recommendations and others of which are
in response to the comments submitted by the facility:
• pH monitoring and limits have been removed from the 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 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.
• 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.
• Flow monitoring frequency changed from monthly to episodic. As per a request by the Mooresville
Regional Office, flow must be measured with each discharge event.
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.
N. C. Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Phone: [phone]
fax: [phone]
DENR Customer Service Center. 1 800 623-7748

If you have any questions concerning this permit, please contact Teresa Rodriguez at telephone
number [phone], extension 595.
Sincerely,
tevens
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 NC0046531
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,
Crown Central Petroleum Corporation
is hereby authorized to discharge wastewater from outfalls located at the .
Paw Creek Terminal
7720 Mt. Holly Road
Paw Creek
Mecklenburg County
to receiving waters designated as an unnamed tributary to Gum Branch in 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
Ke ��.n , Director /54--
Divi n of ater QuaIi
By Autho ' of the Environmental Management Commission

Permit NC00 46531 i
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SUPPLEMENT TO PERMIT COVER SHEET
Crown Central Petroleum Corporation
is hereby authorized to:
1. Continue to operate a water pollution control system for the stormwater from the truck loading racks
consisting of
• Oillwater separator
• Two 5001b carbon absorption units
located at the Paw Creek Terminal, 7720 Mt. Holly Road, Paw Creek, Mecklenburg County and
2. Continue to discharge stormwater from the diked areas and
3. Discharge from said treatment facility through Outfall 001 at a specified location (see attached map)
into an unnamed tributary to Gum Branch, a waterbody classified as WS-IV waters within the
Catawba River Basin.

A ,.
•
13'
_ 4-150
Crown Central Petroleum
Paw Creek Terminal
State Grit' 1,Quad: F15SW (Mt Island Lake)
Latitude 35°16'52" N
LonP3fivii- 80°56' 09° W
Receiving Strewn UP to Gum Smirch Drainage Basile
StreamCasm WS-IV Sub-Basin:3
Facility Location
not to scale
NPDES Permit No. NC0046531
Mecklenburg County

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T[-i'
ermit NC0046531:
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FFLUENT LIMITATIONS ANDVMONITORING REQUhREMENTS:���,�
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Perl..am� ittee s u•"�t1ior+ i'zi Vd tow� f:stnf.
s discharge from Outfall 001:- Such discharges shall+be limited and monitored by the Permittee as .� 1 •
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'-'specified below:
E. FLUE f 7; -y :g7 : ". '
11. -...,4 ' ;;M.'r I.IIVIITS ; =-1-''' ."-4'
= ` , MONITORING
REQUIREMENT
am ,;`
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:,5%%,4.� An.:,.ti-; .n- .
onpptt��il
Average,
''• `�;r: mil _�.
-:,, aximum=.?
Meas semen
Frequency
CHI ' • CTERISTIC `{ ; �'= `
.a . <� - >.
, ,.Type
Flow1.
Episodic .
1
Effluent
Turbidity2
Quarterly
Grab
Effluent
Oil and Grease3 -
•
Monthly -
Grab -
'' Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Phenol
0.16 mg/1
Monthly
' Grab
Effluent
Benzene
1.19 µg/L
Monthly
Grab
Effluent
Toluene
11 µg/L
Monthly
Grab
Effluent
MTBE4
Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
Xylene
Monthly
Grab
Effluent
EPA Method 6255
Semi-annually
Grab
Effluent
Acute Toxicity6
Annually
Grab
Effluent
Footnotes:
1. Flow -= During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow shall be monitored with each discharge event and may be
monitored in one of four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; (this method of flow
measurement should not be used 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. 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.
3. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
4. MTBE — Please see Part A.(3.) for other requirements relating to MTBE
5. EPA Method 625 - Once the facility has collected data for 8 consecutive sample events in; which there
have been —no detections above the •method. detection limit; the perriuttee may request a modification to Y '
the permit that reduces or eliminates the monitoring requirement.
6. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2)]. Samples for Acute
Toxicity shall be collected concurrent with BTEX sampling.
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/l.

Permit NC0046531
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS.
SPECIAL CONDITIONS
A. (2) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas)
24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all' waste
treatment. The permittee will conduct one test annually, with the annual period beginning in January of
the calendar year of the effective date of the permit. The annual test requirement must be performed and
reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include. all supporting 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 datafrom 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 NC0046531
A. (3) MTBE SPECIALCONDITION
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 or criterion, thereby requiring
a water quality limit in the NPDES permit.

nu sue yr YUUUIJC HEARING
711E TO BE HELD BY
THE NORTH CAROLINAENVIRONMENTAL MANAGEMENT COMMISSION 3
M klenbu
TIMES
Expires:
My Commission Exp.
. SUBJECT: A public hearing has been scheduled concerning theproposed renewal and Issuance of
the following NPDES Permits:
- Permit number NC0021962 to CITGO Petroleum Corporation for the Paw Creek Terminal located in
Charlotte, N.0 Charlotte (Mecklenburg County) for the discharge of smrmwater into an unnamed tributary to Gum
AFFIDLfVITOFPUBLICA7 Branch.
- Permit number NC0022187 to Motive Enterprises for the Paw Creak Terminal located in Charlotte
NORTH CAROIINA (Mecklenburg County) for the discharge of slormwater and rernerhated groundwater into an unnamed
MECKLENBURG COUNTY tributary 10 Gum Branch.
Befontdxundeni6tred,allohary•
l Permit number NC0032891 10 Philips Pipe Line Company far the Charlotte Terminal haled in
Noah Carolina. July oemmunioau Charlotte (Mecklenburg County) for the discharge of Stormwater Nato an unnamed tributary to Gum
law to sdtminirter oaths, personally Branch.
Shelby J. Gaucho • Permit number N00074705 to William Terminals Hold ings,LP. kir the Charlotte/Southern Facilities
Terminal located in Charlotte (Mecklenburg County) for the discharge of stormwater into an unnamed
THE Mecklenburg TIMES, a rev tributary to Paw Creek.
entered areaecond-char mail in the C - Permit number NC0004723 W Valero Marketing & Supply Company for the Valero Marketing &
and Stara; thathehhe is authorized b Supply Facility located In Chadote (Mecklenburg County) for -the discharge of stornnvater into an
atatemee v did the notice or atber k unnamed tributary to Paw Creek. -
NOTICB OF PUBLIC } -Permit number NC000577110 TransMontaigne Terminating. lnc_Torthe Charlote/PawCreek Termi-
nal N1 looted in Charlotte (Mecklenburg County),fer the discharge of storrmvater into an unnamed
TO BE HELD BY THE tributary to Paw Creek.
ENWIRONMENTAL HAN/ Perrnt number NC0021971 to TransMonhiigne Terminafng.MO. for the Charrdte/PawCreek
TerrN-
nal #2 located in Charlotte (Mecklenburg County) for the discharge of slormwater into en unnamed
tributary to Paw Creek. -
• Permit number NC0031038 to Colonial Pipeline Company for the Charlotte Oegvery Facility located
a true copy of which u attached beet in Charlotte (Mecklenburg County) for the discharge of stornwater into an unnamed tributary to Gum
Iceberg TIMES on the fell owrne de Branch.
March 16, 2001 • Permit number NC004621310 Marathon Ashland Petroleum, LLC for the Marathon Ashland Petro-
leum facility located in Charlotte (Mecklenburg County) for the. discharge of stomntaler into an un-
andthe dkeaaidnewepapuinwhid named tributary to Long Creek.
or kgal advertisement was publishr - Permit number NC0046531 to Crown Central Petroleum Company for the Paw Creek Terminal
every eredh publication, a newspaper located in Paw Creek (Mecklenburg County) for the r5scharge of stmmwater tnlo an unnamed tributary
and qualitficati0ru of Section I-S97r to Gum Branch.
Carolina and was a qualified nowise - Permit number NC0046892 to Motiva Enterprises, LLC for the Charlotte Terminal located In Paw
lion 14917 onto General Statutes a Creek (Mecklenburg County) for the discharge of stormwater and remedialed groundwater to an
Mit 16th day of M:
(Signed)
twemha and subscribed b fore •
16th dayof Hatch 201
Notary Pub1L
7 / 7
a
unnamed tributary 10 Long Creek,
- Permit number NC0004839 to ExxonMobil Refining 8 Supply Company for the Charlotte Terminal
oersted in Charlotte (Mecklenburg County) for the discharge of stormwater and remedialed groundwa-
ter to an unnamed tributary to Long Creek.
Permit number N00005165 to Williams Terminals Holdings, L.P. for the Paw Creek Terminal located
n Paw Creek (Moddenburg County) for rho discharge of storm+ater to an unnamed tributary to Long
Creek.
PURPOSE: Each of these facilities has applied for renewal of their NPDES permit for the discharge
01 treated stomlwater and/or remedialed groundwaler into waters of the Catawba Rine, basin. On the
basis of preliminary staff review and application of Article 21 of Chaffer 143, General Statutes of North
Carolina, and other lawful standards and regulations, the North Carolina Environment Management
Commission proposes to issue a NPDES permit for each facility subject to specific pollutant limitations
and special conditions. The Director of the Division of Water Quality pursuant W NCGS 143-215.1(ch3)
nd Regulations 15 NCAC 2H, Secfon .0100 has determined that It is Fri the pubic interest that a meeting
be held to receive all pertinent public comment on whether to issue. modify, or deny the permiL
PROCEDURE: The hearing will be conducted in the following manner:
1. The Division of Water Quality will present an explanation ice the North Carolina Environment
Management Commission's pe milting procedure. 2. The applicant may make an explanation of the action for which each permit is required.
3. Public Comment - Comments, statements, data and otter inlomsatian maybe submitted in writing
prior to or during the meeting or may be presented orally at the meeting. Persons desiring to speak will
indicate this intent al the time of registration at the meeting. So that alpersons desiring to speak may do
so, lengthy statements rhay be limited at the discretion of the meeting officer. Oral presentatops.that
acted Three minutes should be accompanied by three written copi®, which will be filed with Division
lac at the time of registration.
4. Cross examination of persens presenting testimony wit riot be allowed; however, the hearing
officer may ask questions for clarification, - -
5. The hearing record may be runsed at the conclusion of the meeting.
WHEN: Apri119e at 7:00 p.ri .
WHERE:Charlotte-Meak(entiurg Government Center - -
600 East Fourth Street CH-14
Charlotte. North Carolina
INFORMATION:A copy of die drat NPDES permit(s)ands map shoving the location of the discha rge(s)
are available by_writing or calling:
Ms. Christie Jackson
NC Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27694-1617 -
Telephone number [phone], extension 538
The applications and other inornallon are on file at the Division of Water Quality, 512 North Salisbury
Street, Room 925 of the Archdale Building in Raleigh, North Cardina and et the Division's Mooresville
Regional Office (919 North Main Seed in MOoresvite, NC): They may be inspected during normal office
hours. Copies of the information on file are available upon request and payment of the costs of
reproduction. All parch comments and requests regarding this matter should make reference to the
permit numbers) listed above.
83g84 Mar 16 .

DIVISION OF WATER QUALITY
April 5, 2001
MEMORANDUM
TO: Dave Goodrich
FROM: D. Rex Gleason \\J
PREPARED BY: Richard Bridgeman\
SUBJECT: Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
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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.
As 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 Refining 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
of 110.3 NTU?
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
WATT n+ia irtsprrON
APRU221
Non -Discharge 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 • (i 04) 336-5500 • Fax [phone]

a
Mr. Dave Goodrich
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 2
The permits require quarterly turbidity monitoring at the effluent. The permits do not
require upstream or downstream monitoring for turbidity. Without instrearn 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 detenion pond.
• Exxon Mobil Refining and Supply Company - Permit # NC0004839
Outfall 001-
The daily maximum permit limit for benzene is listed as 1.2pg/1. The North Carolina
water quality standard for WS-IV waters is 1.19pg/1.
• 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 71.4,4g/1 and
toluene concentration is less than 11,ug/1." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.191ug/1.
• 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,
Ruszzelle
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
WIL LIAM 11. wCATI;ERS'OON
IMAM.
May 2, 2001
NORTH CAROLINA
PETROLEUM
COUNCIL
A DM„fsfon of the American Petroleum Institute
SU= 2850 • 150 FAYETIEVILI.E S7 . MALL.
RALEIGH. NC 27601
O10/848.8438 • FAX 431 O/8'21-0337
Mr. Rick Shiver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Fact.
Wilmington, NC 28405-3845
Inc: NPDES Permit 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 1 request be included in the official hearing record — is to
express my member' 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 part 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 ugfL that has been included in the
draft permits without a single hearing or any official review by a rulemaking body.
We asked the Department (DENR) to help us understand how this limit 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 a temporary groundwater standard of 70 ppb, but also to reaffumtthe value of
public hearings by calling for a permanent rulemaking process to tighten the MTBE groundwater
mod. so ea w% all %welt tth %aiding T+Wwsse, oab that w:ow:sal. we are now confronted with

Sent By: ; .919 821 0337;
May-2-01 16:32; Page 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 ingtus that the calculations of
today are not abandoned tomorrow.
Recommendation
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 sc� ual monitoring by
each of the terminals will provide the needed representative data to form the basis for future
decision -making.
Sincerely,
Watt
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/1 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
15A NCAC 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])

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0046531
Facility Information
Applicant/Facility Name:
Crown Central Petroleum Co./Paw Creek Terminal
Applicant Address:
P.O. Box 78, Paw Creek, NC 28130
Facility Address:
7720 Mt. Holly Rd., Paw Creek, N.C.
Permitted Flow
Outfall 001 is not limited
Type of Waste:
Stormwater and wash water from loading racks
Facility/Permit Status:
Active; Renewal
County:
1 Mecklenburg
Miscellaneous
Receiving Stream:
UT to Gum
Branch
Regional Office:
Mooresville
Stream Classification:
WS-IV
State Grid / USGS Quad:
F15SW (Mt. Island
Lake)
303(d) Listed?
No
Permit Writer:
Teresa Rodriguez
Subbasin:
03-08-34
Date:
3/2/01
Drainage Area (mi2):
0.01
i
-'
Lat. 35° 16' 52" N Long. 80° 56' 09" W
Summer 7Q10 (cfs)
0
Winter 7Q10 (cfs):
0
30Q2 (cfs)
0
Average Flow (cfs):
0
1WC (b):
100 )
BACKGROUND
The stormwater and washwater collected from the loading rack area is treated in an oil/water separator
and a carbon filter, the stormwater collected in the diked areas is combined with the effluent from the carbon
filters and discharged from Outfall 001. The capacity of the treatment system is 0.0432 MGD.
FILE REVIEW
Correspondence
The Mecklenburg County Department of Environmental Protection (MCDEP) has performed 6
inspections since 1996. The results of the inspections were all satisfactory.
DMR Review:
DMRs were reviewed for the period of January 1997 to December 2000. Discharges from 001 are
sporadic in nature; for those months in which flow was recorded, the mean flow was 0.089 MGD. The
maximum flow (used below in the reasonable potential calculations) was 0.318 MGD. Total suspended solids
during this time averaged 9.2 mg/L for all the values above quantitation level, the maximum value was 38
mg/L. Oil and Grease averaged 8.5 mg/L with a maximum of 25.4 mg/L. On the EPA 624/625 scan
phenanthrene was detected once at 2.88 µg/L and fluorene once at 3.1 µg/L. Phenol was detected four times
with a maximum of 84 µg/L. Toluene was detected twice at 2.4 µg/L and 5.37 µg/L, Benzene once at lµg/L and
Xylene once at 2.27 µg/L. The facility has passed its annual acute toxicity test since 1996.
Reasonable Potential Analysis:
Reasonable Potential Analysis was run for benzene, xylene, phenol, toluene and MTBE. Xylene was
the only parameter that did not present reasonable potential. A daily maximum limit of 11.6 µg/L will be
implemented for MTBE. Benzene and toluene limits will remain unchanged since they present reasonable
potential to exceed the established limits. A daily maximum limit of 0.16 mg/L will be implemented for phenol
based on the allocation for the Paw Creek area.
Fact Sheet
NPDES NC'OO465 1
Renewal

PERMITTING STRATEGY
The permitting strategy for this and all oil terminals in the state is based upon a 2001 NPDES document
entitled, "Permit Requirements for Discharges from Oil and Petroleum Storage Facilities." This document is
based upon a 1996 SOP and has been updated after a data review and internal discussions. It delineates
monitoring frequencies and permitting limits for contaminants commonly found at these sites. Below, it is
referred to as the "2001 SOP."
Waste Load Allocation (WLA).
The last waste load allocation was performed in 1994.
Oil Terminal SOP:
The flow, toxicity, TSS, EPA Methods 625/624 and oil and grease requirements specified in the
previous permit and the 2001 SOP (Parts I.A. — I.D.) remain unchanged. The facility detected two additional
parameters (phenanthrene and fluorene) additional to the BTEX parameters in EPA Methods 624/625 during
the last permit cycle therefore the requirement for EPA Methods 624/625 will remain in the permit as per Part
II A. of the 2001 SOP. The limit for phenol was calculated using the maximum flow discharged in the last
permit cycle (.318 MGD) and the allocation of 0.43 lbs/day for each discharger. As per parts I.G. and I.H. of
the 2001 SOP, there can be no direct discharge of tanks solids, tank bottom water or the rag layer, and no direct
discharge of hydrostatic test water if concentrations of benzene and/or toluene exceed the water quality
standard. Part II.C. lists a requirement specific to the Paw Creek terminals — quarterly turbidity monitoring as
mandated by the EPA.
SUMMARY OF PROPOSED CHANGES
• Addition of MTBE limit.
• Addition of phenol limit.
• Addition of naphthalene monitoring.
• Addition of ethylbenzene monitoring.
• Addition of quarterly turbidity monitoring.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: March 14, 2001
Permit Scheduled to Issue: April 27, 2001
NPDES DIVISION CONTACT
If you have questions regarding any of the above information or on the attached permit, please contact Teresa
Rodriguez at [phone] ext. 595.
NAME: DATE:
REGIONAL OFFICE COMMENTS
NAME: DATE:
Fad Sheet
NPDES V.:0 465 ;1
Renewal
Page

REASONABLE POTENTIAL
Prepared by:
Facility Name =
NPDES # =
Ow (MGD) =
Ow (cfs) =
7Q10s (cfs)=
IWC (%) =
ANALYSIS - AMENDED
Teresa Rodriguez
7/30/01
Crown Central Petroleum
NC0046531
0.935
0.492000
0
100.00
Chronic CCC w/s7Q10 dil. Acute CMC wino dil.
Frequency of Detection
Parameter
FINAL RESULTS, ug/I FINAL RESULTS, ug/I
#Samples # Detects
Xylene
Max. Pred Cw
7.3
Allowable Cw
88.5
14 1
Benzene
Max. Pred Cw
1.40
Allowable Cw
1.19
14 1
Toluene
Max. Pred Cw
29.0
Allowable Cw
11.0
14 2
Phenol
Max. Pred Cw
0.36
Allowable Cw
0.16
14 4
MTBE
Max. Pred Cw
15.0
Allowable Cw
11.6
14 1
Modified Data: Use 0.5 Detection Limit for non -detects

Parameter =
Standard =
Dataset=
Xylene
88.5
pg/
DATE Modified Data Nondetects RESULTS
2/25/97 0.5 <1.0 Std Dev.
4/10/97 0.5 <1.0 Mean
7/8/97 0.5 <1.0 C.V.
10/27/97 0.5 <1.0 Sample#
12/18/97 0.5 <1.0
1 /21 /98 2.27 2.27 Mult Factor =
2/19/98 0.5 <1.0 Max. Value
4/8/98 0.5 <1.0 Max. Pred Cw
9/1/98 0.5 <1.0 Allowable Cw
1/12/99 0.5 <1.0
3/16/99 0.5 <5.0
10/14/99 0.5 <1.0
2/22/00 0.5 <1.0
4/21/00 0.5 <1.0
0.473
0.626
0.755
14.000
3.220
2.270 pg/i
7.309 pg/l
88.500 pg/i
Benzene
1.19
Modified Data Nondetects
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
1 1 Mult Factor =
0.5 <1.0 Max. Value
0.5 <1.0 Max. Pred Cw
0.5 <1.0 Allowable Cw
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
pg/l
RESULTS
Std Dev. 0.134
Mean 0.536
C.V. 0.249
Sample# 14.000
1.400
1.000 pgll
1.400 pgll
1.190 pgll
Parameter= Toluene
Standard = 11 pg/i
Dataset= DMR99
ModifiedData Nondetects RESULTS
2.43 2.43 Std Dev. 1.363
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
5.37
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <5.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
Mean 0.986
C.V. 1.382
Sample# 14.000
5.37 Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
5.400
5.370 pg/l
28.998 pg/i
11.000 pg/i
Parameter =
Standard =
Dataset= DMR97-00

Parameter =
Standard =
Dataset=
Phenol
0.16
mg/I
ModifiedData Nondetects RESULTS
0.0025 <0.005 Std Dev.
0.0025 <0.005 Mean
0.009 0.009 C.V.
0.048 0.048 Sample#
0.067 0.067
0.0025 <0.005 Mult Factor =
0.0025 <0.005 Max. Value
0.084 0.084 Max. Pred Cw
0.0025 <0.005 Allowable Cw
0.025 <0.05
0.025 <0.05
0.025 <0.05
0.025 <0.05
0.025 <0.05
0.026
0.025
1.040
14.000
4.300
0.084 mg/I
0.361 mg/I
0.160 mg/1
Parameter= MTBE
Standard = 11.6 pg/l
Dataset=
ModifiedData Nondetects RESULTS
0.5 <1.0 Std Dev.
0.5 <1.0 Mean
C.V.
4.34 Sample#
2.5 <5
4.34
5 <10.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
0.5 <1.0
5 <10.0
2.5 <5.0
0.5 <1.0
0.5 <1.0
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
1.645
2.274
0.723
14.000
3.000
5.000 pg/1
15.000 pg/1
11.600 pgll

NC0046531 Crown Central Petroleum Corp Outfall 1
Mecklenburg County
Date
Flow
(MGD)
TSS
(mg/L)
0 & G
(mg/L)
Phenol
(mg/L)
Benzene
(ug/L)
Toluene
(ug/L)
Xylene
(ug/L)
Ethylbenzen
(ug/L)
Iron
(mg/L)
Manganese
(mg/L)
Phenanthrene
(ug/L)
Fluorene
(ug/L)
Napthalene
(ug/L)
MTBE
(ug/L)
Tox
2/25/97
4/10/97
7/8/97
10/27/97
12/18/97
1 /21 /98
2/19/98
4/8/98
9/1/98
1/12/99
3/16/99
10/14/99
2/22/00
4/21/00
0.00083
0.00145
0.0097
0.00139
0.00546
0.1015
0.168
0.149
0.318
0.079
0.075
0.1228
0.1281
3
<1.0
1
3
<1.0
8
2
38
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
10.6
3.3
1.4
5.3
4.9
25.4
<0.005
<0.005
0.009
0.048
0.067
<0.005
<0.005
0.084
<0.005
<0.05
<0.05
<0.05
<0.05
<0.05
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
1
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<5.0
<1.0
<1.0
<1.0
2.43
5.37
<1.0
<1.0
<1.0
<1.0
<1.0
2.27
<1.0
<1.0
<1.0
<1.0
<5.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
0.15
<0.05
<0.05
<0.05
0.05
0.23
0.18
<0.05
<0.05
0.0031
0.0013
0.0031
<0.005
0.01
0.0022
0.0024
0.0021
<0.005
<3.0
<2.0
<2.0
<3.0
<2.0
<2.0
<5.0
<2.0
2.88
<3.0
<2.0
<2.0
<3.0
<2.0
<2.0
<2.0
<2.0
3.1
<2.0
<3.0
<2.0
<2.0
<3.00
<2.0
<2.0
<2.0
<5.0
<1.0
<1.0
<5
4.34
<10.0
<5.0
<5.0
<5.0
<5.0
<1.0
<10.0
<5.0
<1.0
<1.0
P
P
P
P
Flow
(MGD)
TSS
(mg/L)
0 & G
(mg/L)
Phenol
(mg/L)
Benzene
(ug/L)
Toluene
(ug/L)
Xylene
(ug/L)
Ethylbenzen
(ug/L)
Iron
(mg/L)
Manganese
(mg/L)
Phenanthrene
(ug/L)
Fluorene
(ug/L)
Napthalene
(ug/L)
MTBE
(ug/L)
Tox
average
0.089248
9.167
8.48333
0.052
1
3.9
2.27
0.153
0.00345714
2.88
3.1
4.34
max
0.318
38
25.4
0.084
1
5.37
2.27
0.23
0.01
2.88
3.1
4.34
# samples
14
14
14
14
14
14
9
9
9
9
9
9
14
# detects
6
6
4
1
2
1
0
4
7
1
1
0
1
Phenol limit calculation
Max flow 0.318 MGD
Limit = 0.162134 mg/I

REASONABLE POTENTIAL ANALYSIS
Prepared by: Natalie Sierra, 10/10/00
Facility Name = Crown Central Petroleum Corp
NPDES # =
Ow (MGD) _
Ow (cfs) =
7010s (cfs)=
IWC (%) =
NC0046531
0.318
0.492010
0
100.00
Parameter
Chronic CCC w/s7Q10 dil. Acute CMC w/no dil.
FINAL RESULTS, ug/I FINAL RESULTS, ug/I
Frequency of Detection
#Samples # Detects
Xylene
Max. Pred Cw
Allowable Cw
Benzene
Max. Pred Cw
Allowable Cw
Toluene
Max. Pred Cw
Allowable Cw
Phenol
Max. Pred Cw
Allowable Cw
MTBE
Max. Pred Cw
Allowable Cw
7.3
88.5
1.5
1.2
29.0
11.0
374.6
1.0
15.5
11.6
Modified Data: Use 0.5 Detection Limit for non -detects
14
14
14
14
1
1
2
4
14 1
DATE
2/25/97
4/10/97
7/8/97
10/27/97
12/18/97
1 /21 /98
2/19/98
4/8/98
9/1/98
1/12/99
3/16/99
10/14/99
2/22/00
4/21/00
Parameter =
Standard =
Dataset=
Xylene
88.5
pg/I
Modified Data Nondetects RESULTS
0.5 <1.0 Std Dev.
0.5 <1.0 Mean
0.5 <1.0 C.V.
0.5 <1.0 Sample#
0.5 <1.0
2.27 Mult Factor =
0.5 <1.0 Max. Value
0.5 <1.0 Max. Pred Cw
0.5 <1.0 Allowable Cw
0.5 <1.0
0.5 <5.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.473
0.626
0.755
14.000
3.220
2.270 pg/I
7.309 pg/I
88.500 pg/I

Parameter =
Standard =
Dataset=
Modified Data
0.5
0.5
0.5
0.5
0.5
1
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
Benzene
1.19
DMR99
Nondetects
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
pg/I
RESULTS
Std Dev.
Mean
C.V.
Sample#
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.134
0.536
0.249
14.000
1.547
1.000 pg/I
1.547 pg/I
1.190 pg/I
Parameter =
Standard =
Toluene
Dataset= DMR99
ModifiedData
2.43
0.5
0.5
0.5
0.5
5.37
0.5
0.5
0.5
0.5
2.5
0.5
0.5
0.5
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<1.0
<5.0
<1.0
<1.0
<1.0
11 pg/I
Nondetects RESULTS
Std Dev.
Mean
C.V.
Sample#
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
1.412
1.129
1.251
14.000
5.400
5.370 pg/I
28.998 pg/I
11.000 pgll
Parameter =
Standard =
Dataset=
Phenol
1
pg/I
ModifiedData Nondetects RESULTS
2.5 <5 Std Dev.
2.5 <5 Mean
9 C.V.
48 Sample#
67
2.5 <5 Mult Factor =
2.5 <5 Max. Value
84 Max. Pred Cw
2.5 <5 Allowable Cw
25 <50
25 <50
25 <50
25 <50
25 <50
25.660
24.679
1.040
14.000
4.460
84.000 pg/I
374.640 pg/I
pg/I

Parameter =
Standard =
Dataset=
MTBE
11.6
pg/I
ModifiedData Nondetects RESULTS
0.5 <1.0 Sid Dev.
0.5 <1.0 Mean
2.5 <5 C.V.
4.34 Sample#
5 <10.0
2.5 <5.0 Mutt Factor
2.5 <5.0 Max. Value
2.5 <5.0 Max. Pred Cw
2.5 <5.0 Allowable Cw
0.5 <1.0
5 <10.0
2.5 <5.0
0.5 <1.0
0.5 <1.0
1.645
2.274
0.723
14.000
3.090
5.000 pg/I
15.450 erg/I
11.600 pg/I

SOC PRIORITY PROJECT: Yes_ No X
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: April 18, 2001
NPDES STAFF REPORT AND RECOMMEND
County: Mecklenburg
MRO No. 01-39
Permit No. NC0046531
PART I - GENERAL INFORMATION
1. Facility and Address: Crown Central Charlotte Terminal
Crown Central Petroleum Corporation
P.O. Box 78
Paw Creek, N.C. 28130
2. Date of Investigation: 04-03-01
3. Report Prepared By: Samar Bou-Gha7s1e, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. Floyd Reid, Terminal Manager; tel# (704)
392-2320
5. Directions to Site: Travel Highway 27 north from Charlotte to the community of Paw Creek
The Crown Central Terminal is located at the junction of Highway 27 (Mt. Holly Road) and
Tom Sadler Road (SR 1784).
6. Discharge Point(s). List for all discharge points:
Latitude: 35 ° 16' 50" Longitude: 80' 56' 09"
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): Sloping at the rate of 1 to 2%. The site
is not located in a flood plain.
9. Location of nearest dwelling: The nearest dwelling is approximately 1000 feet from the site.
10. Receiving stream or affected surface waters: Unnamed Tributary to Gum Branch.
a. Classification: WS IV
b. River Basin and Subbasin No.: Catawba; 03-08-34
c. Describe receiving stream features and pertinent downstream uses: The receiving
stream is a wet weather ditch tributary to Gum Branch. Citgo Charlotte Terminal
also discharges to the same UT.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted: The groundwater treatment system has been
removed. The stormwater flow is not limited.
b. What is the current permitted capacity of the wastewater treatment facility? N/A.
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 facilities consist of an oil/water
separator, carbon adsorption and a polishing pond.
f. Please provide a description of proposed wastewater treatment facilities: N/A
g•
Possible toxic impacts to surface waters: Discharges of this nature have been shown
to be toxic.
h. Pretreatment Program (POTWs only): N/A.
2. Residuals handling and utilization/disposal scheme: The tank bottom water is pumped and
hauled by Industrial Water Services, Inc., tel# [phone]. The tank solids is handled by
Clean Harbors Environmental Services, Inc., tel# [phone].
NPDES Permit Staff Report
Page 2

3. Treatment plant classification: Class I
4. SIC Code(s): 5171
Primary: 39 Secondary: 73
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: N/A
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.
Spray irrigation: N/A
Connection to regional Sewer System: There is no sewer main near the site and connection
to a regional sewer is not an option.
Discharge to an infiltration gallery: N/A
5. Air Quality and/or Groundwater concerns or hazardous waste utilized at this facility that
may impact water quality, air quality or groundwater? Contaminated groundwater
already exists at the site. No hazardous materials concern. Air quality permit for this site
is not required by Mecklenburg County.
PART IV - EVALUATION AND RECOMMENDATIONS
Crown Central Petroleum Corporation is requesting NPDES Permit renewal for the
discharge of treated stormwater from the subject facility.
Stormwater runoff and washwater from the loading rack is pumped into an above ground
equalization tank via an oil/water separator. The combined waste stream is then treated by
carbon adsorption before being discharged to the polishing pond. Stormwater collected in the
diked tank farm is also discharged to the polishing pond (without treatment).
NPDES Permit Staff Report
Page 3

It is recommended that the NPDES permit be renewed.
Signature o
eport Preparer
Date
,D, A
Water Quality Re ional Supervisor D to
NPDES Permit Staff Report
Page 4

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
April 2, 2001
MEMORANDUM
"Fo: Britt Setzer
NC DENR / DEH / Regional Engineer
Mooresville Regional Office
From: Teresa Rodriguez
NPDES Unit
Subject:
Atrn
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
RECEIVED
APR 0 4 2001
NCDENR
Division of Environmental Health
F'uhli^ 1N ter Supply Section
Moi7rwville Regional Office
Review of Draft NPDES Permit NC0046531
Crown Central Petroleum Corporation — Paw Creek Terminal
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.
wwwwwwwwwwwwwww�,vww�VAN/VVv�nAivwwn�vwwwwww�ivwwNV/VV�ivwww
RESPONSE: (Check one)
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
17)
permit, provided the following cohtlitions aye net:
•
F 1 1 2 (l01
DENR - WATER QUALITY
POINT SOURCE BRANCH
Opposes the issuance of the above permit. based on reasons stated Woo', or attac111.t"
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
VISIT US ON THE INTERNET @ http:/lh2o.enr.state.nc.us/NPDES
919 733-5083, extension 595 (fax) 919 733-0719
Teresa.Rodriguez@ ncmail.net

rn ovs_. flit . (z `{/fo z S
Fli756i=
Crown Central Petroleum Corporation
Refiners / marketers of petroleum products & petrochemicals
One North Charles Street • P.O. Box 1168 • Baltimore, Maryland 21203 • [phone]
P.O. Box 78 • Paw Creek, North Carolina 28130
April 18, 2001
Ms. Teresa Rodriguez
NC DENR — DWQ-NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit Renewal
Crown - NC0046531
Dear Ms. Rodriguez:
On March 29, 2001 industry representatives met with Mr. David Goodrich and Ms. Natalie Sierra
in Charlotte to discuss draft permits. Draft permits and your letter of March 29, 2001 were
received at that time. After reviewing the draft permit we find it necessary to offer the following
comments/concerns relative to our draft permit conditions/limits.
Based on discussions at the 3/29/01 meeting, it our understanding that for facilities where there
was no detection of any compounds on the 624/625 tests during the current permit period that
there would be no requirement to do the 624/625s test in the new permit. I have carefully
reviewed Crown's monthly discharge monitoring reports for the current permit period and have
determined that the results were either non detect or below detection limit for all constituents
with the exception of benzene, ethylbenzene, toluene, and xylene. Inasmuch as these
compounds will be individually monitored in the new permit Crown requests that the requirement
to do semiannual 624/625 tests be removed from Crown's new NPDES permit.
In respect to the proposed daily limit for MTBE, Crown would like the to discuss the State's
rational for setting the limit at 11.6 ug/I. Inasmuch as we are unaware of any regulatory or
scientific basis for this determination, we request consideration for a limit more representative of
the State's current 2L standard.
Thank you for your attention to this matter. If you have any questions please contact me at
704.392.2320.
Sincerely,
W. Floyd eid
Terminal Superintendent
cc: Mooresville Regional Office / Water Quality Section / NPDES Unit
Mr. David Rimer Mecklenburg County Department of Environmental Protection
Mr. John Funk Crown Central Petroleum Corp.

Ms. Teresa Rodriguez
NC DENR — DWQ-NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit Renewal
Crown - NC0046531
Dear Ms. Rodriguez:
Crown Central Petroleum Corporation
Refiners / marketers of petroleum products & petrochemicals
One North Charles Street • P.O. Box 1168 • Baltimore, Maryland 21203 • [phone]
P.O. Box 78 • Paw Creek, North Carolina 28130
April 20, 2001
M I t`� ?moo
Based on our discussion during your terminal visit on April 19 I am submitting copies of the
625/625 test results for the current permit period. You should not find any compounds detected
except those in the BTEX group. Please review Crown's draft permit and remove the 624/625 test
requirement in the new permit.
Thank you for your attention to this matter. If you need any further information or have any
questions please contact me at 704.392.2320.
Sincerely,
. Floyd R
Terminal Su.erintendent
cc: Mr. John Funk Crown Central Petroleum Corp.
(TL-t: Ase__ ELA Ve Ey-v• Inc (---
INA -2_ c)I

' � 1
5 l'7 l5 i
N 1J
APR 25 2001
Crown Central Petroleum Corporation
Refiners / marketers of petroleum products & petrochemicals
DERR - WATER gQUALirt
One North Charles Street • P.O. Box 1168 • Baltimore, Maryland(2120iQW"c(E4 400-
P.O. Box 78 • Paw Creek, North Carolina 28130
April 18, 2001
Ms. Teresa Rodriguez
NC DENR — DWQ-NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES Permit Renewal
Crown - NC0046531
Dear Ms. Rodriguez:
On March 29, 2001 industry representatives met with Mr. David Goodrich and Ms. Natalie Sierra
in Charlotte to discuss draft permits. Draft permits and your letter of March 29, 2001 were
received at that time. After reviewing the draft permit we find it necessary to offer the following
comments/concerns relative to our draft permit conditions/limits.
Based on discussions at the 3/29/01 meeting, it our understanding that for facilities where there
was no detection of any compounds on the 624/625 tests during the current permit period that
there would be no requirement to do the 624/625s test in the new permit. I have carefully
reviewed Crown's monthly discharge monitoring reports for the current permit period and have
determined that the results were either non detect or below detection limit for all constituents
with the exception of benzene, ethylbenzene, toluene, and xylene. Inasmuch as these
compounds will be individually monitored in the new permit Crown requests that the requirement
to do semiannual 624/625 tests be removed from Crown's new NPDES permit.
In respect to the proposed daily limit for MTBE, Crown would like the to discuss the State's
rational for setting the limit at 11.6 ug/I. Inasmuch as we are unaware of any regulatory or
scientific basis for this determination, we request consideration for a limit more representative of
the State's current 2L standard.
Thank you for your attention to this matter. If you have any questions please contact me at
704.392.2320.
Sipcerely,
W. Floyd Rei
Terminal Superintend
cc: Mooresville Regional Office / Water Quality Section / NPDES Unit
Mr. David Rimer Mecklenburg County Department of Environmental Protection
Mr. John Funk Crown Central Petroleum Corp.

Crown Central Petroleum Corporation
Refiners / marketers of petroleum products & petrochemicals
One North Charles Street • P.O. Box 1168 • Baltimore, Maryland 21203 • [phone]
P.O. Box 78 • Paw Creek, North Carolina 28130
March 21, 2001
Ms. Valery Stephens
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: NPDES NC0046531
Permit Renewal
Dear Ms. Stephens,
The following is in response to your request for additional information to facilitate our
NPDES permit renewal.
• A site plan is enclosed. Stormwater from the load rack area flows through the oil/water
separator and is pumped under Tom Sadler Rd. into the equalization tank. It is then
pumped through the carbon vessels and is discharged into the north tank farm for later
release via outfall DP1. Uncontaminated stormwater that accumulates in the south tank
farm area is piped under Tom Sadler Rd. where it commingles with uncontaminated
storm water that accumulates in the north tank farm. This water is also released at
outfall DP1. The groundwater remediation system has been removed.
• Past discharge monitoring reports are not available electronically. Only paper copies are
maintained by Crown.
• Any tank bottom material or water withdrawn from a storage tank is trucked offsite and
disposed of in accordance with all applicable regulations. None of this material is
discharged to the ground or through the NPDES outfall.
If you have any further questions or need any additional information please contact me.
Sincerely,
W. Floyd' eid
Cc: John Funk Crown Central Petroleum
Mooresville Regional Office, Water Quality Section, NPDES fil
e111 IS lei LS 0 V IS
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j MAR 2 7 2001
L
DENR-WATER QUALITY
POINT SOURCE BRANCH
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•
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Crown Central Petroleum Corporation
Refiners / marketers of petroleum products & petrochemicals
One North Charles Street • P.O. Box 1168 • Baltimore, Maryland 21203 • [phone]
P.O. Box 78 • Paw Creek, North Carolina 28130
February 13, 2001
Mr. Charles H. Weaver, Jr.
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: NPDES NC0046531
Dear Mr. Weaver,
Crown Central Petroleum is requesting renewal of our NPDES permit,
NC0046531. The required original application and the original Sludge
Management Plan plus two copies of each are enclosed.
The permit modification issued in August of 1998 addresses the most
recent changes to treatment system with regards to the removal of the
groundwater remediation system. However, the effluent sheet still says, "The
flow contribution from ground water remediation system shall not exceed 0.0432
MGD at any time." This sentence should be removed inasmuch as the
groundwater treatment system has been removed.
If there are any problems or questions concerning our renewal application
please contact me. That you for your handling of this renewal.
Cc: John Funk
Sincerely,
W
W. Floyd Reid
I
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1
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N
CCI
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1

SLUDGE MANAGEMENT PLAN
CROWN CENTRAL PETROLEUM CORP.
CHARLOTTE, NC
NPDES NC0046531
The terminal is operated in such a fashion as to minimize the quantity of
solids entering the storm water treatment system. This system collects storm
water at the truck loading rack from which it flows to the oil/water separator.
Any product that is gravity separated is returned to a product storage tank and
the remaining storm water is filtered through through two carbon vessels prior to
discharge. The only opportunity for dirt and debris to enter the system is at the
load rack drain.
Drivers who load at the terminal are trained not to put debris, trash, or
other solids into the trench drain at the load rack. Drivers are also prohibited
from washing their trucks at the load rack. Plant personnel monitor compliance
either directly or via the closed circuit television system.
Unless testing indicates any sludge or solids that accumulate in the load
rack trench drain, oil/water separator, or any other point in the system are
nonhazardous, they are disposed of as a hazardous waste in accordance with all
applicable laws and regulations.