NC0046892_Authorization to Operate_20090825

AwA
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
August 25, 2009
Mr. Ken Watson, Terminal Manager
Motiva Enterprises, LLC
410 Tom Sadler Road
Charlotte, NC 28214
Subject: Authorization to Operate/Removal of Treatment Units
Motiva Enterprises, LLC
NPDES Permit NC0046892; Outfall 002
Mecklenburg County
Dear Mr. Watson:
The Division of Water Quality has received your request of July 16, 2009 (submitted on your behalf by
Groundwater & Environmental Services of North Carolina, Inc.), seeking approval for operation of the
existing treatment system for the subject permit's outfall 002 with removal of the flocculation tank and
clarifier from that system. Your representatives have subsequently contacted this office to add the
holding tank to the number of treatment units to be removed. An analysis performed by your
consultants has concluded these final treatment units do not provide tangible improvement to the
effluent quality, and due to the particular circumstances of this discharge, may actually degrade the
quality of the effluent. Data provided by your consultants provide a strong indication that the system
can meet permit limits without its flow passing through the above -mentioned treatment units.
Based upon the information provided, your request to remove the flocculation tank, clarifier and the
holding tank from service within the treatment system is approved as of the date of this letter. This
approval is granted to allow a pilot study to be conducted on the modified treatment system. The
changes can be made permanent pending the results of effluent sampling performed over the next six
months. Please be aware that nothing in this letter absolves your company of its responsibility to
comply with the terms, conditions and limitations of the NPDES permit, or those of North Carolina's
environmental laws. Should the results of effluent monitoring from the modified system indicate
noncompliance with effluent limits or reasonable potential that the discharge may cause water quality
standards to be exceeded, you will be expected to promptly make the necessary operational and/or
structural changes to your facility that will return it to a compliant status.
Concurrently with the submittal of the renewal application for the NPDES permit, you must submit a
request to the Construction Grants & Loans Section for an Authorization to Construct (ATC) permit that
will accurately describe the system that will remain on -site. The facility should include statements
regarding the efficiency of the modified treatment system as a part of both the ATC request and the
NPDES permit renewal application. The facility description in the permit will be updated when the
permit is renewed (scheduled for summer 2010).
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Equal Opportunity 1 Affirmative Action Employer
One
NorthCarolina
Naturally

Mr. Ken Watson
NC0046892 — Outfall 002 Removal of Treatment Units .
p. 2
It has been discussed that the company wishes to convert the holding tank's use to that of ethanol
storage. This letter places no restrictions upon the future use of the treatment components taken out of
service at the site. However, their uses could affect the terms included in future NPDES permits issued
for the facility. Please keep the Surface Water Protection Section of the Mooresville Regional Office
advised as to changes in operations at the site.
Thank you for your cooperation in this matter. If you have any questions about this letter, please contact
Bob Sledge at [phone], or via e-mail at [e-mail].
Sincerely,
om Belnick, Supervisor
NPDES Western Program
cc: NPDES Permit File
Central Files
Mooresville Regional Office — SWP Section
Construction Grants& Loans Section — Seth Robertson
Mecklenburg County — Water Quality Program
Hugh Nelson
Brittany Robinson

Sledge, Bob
From: Robertson, Seth
Sent: Thursday, August 20, 2009 1:17 PM
To: Sledge, Bob
Subject: RE: That Motiva Thing
Bob,
Sorry I didn't get back to you yesterday. We are willing to consider this a operational issue and let the regional office
make the determination regarding the removal from service of the treatment units. However, if the regional office has
any questions or needs any assistance we will be glad to assist. Let me know if we can provide any additional assistance.
Thanks,
Seth
From: Sledge, Bob
Sent: Wednesday, August 19, 2009 2:29 PM
To: Robertson, Seth
Subject: That Motiva Thing
I mentioned this when we spoke, but it may not have had the same impact as the other items we'd spoken about
before. Their consultant has told me the company now wants to have the final unit, the holding tank, removed from the
permit. As of now, that seems to be their primary interest because they want to use the tank for another purpose at the
site. They'd understand a longer review period for the other treatment units being removed, but they'd like to get
approval for removal of the tank as quickly as they can. I don't know if that changes the shape of the discussion y'all are
having or your own thinking on the matter, but I thought I'd pass it along too.
Thanks again,
Bob
Bob Sledge
Environmental Specialist
NPDES Western Unit
NC Division of Water Quality
[e-mail]
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
1

Sledge, Bob
From: Robertson, Seth
Sent: Friday, July 24, 2009 3:05 PM
To: Sledge, Bob
Subject: RE: NC0046892 Request
Bob,
This is an interesting question. I'm fine with this being a "pilot study" as long as it is in coordination with someone (RO,
CG&L, NPDES) with frequent reporting on results, in addition to DMRs, and a prescribed end date. If the "pilot study" is
a success I believe an ATC should be issued to remove the items from service since this is a modification to the
treatment process.
However, I don't understand why they couldn't "pilot" this idea just by taking samples before the flocculation tank and
clarifier since this should be equivalent to the finished water in their proposal (based upon the process description as I
understand it). I would be interested in seeing this data and other upfront engineering justification providing some
reasonable assurance that they will remain in compliance with their NPDES permit prior to giving them permission to
proceed.
Let me know if I can provide any assistance.
Thanks,
Seth
From: Sledge, Bob
Sent: Thursday, July 23, 2009 2:15 PM
To: Robertson, Seth
Subject: NC0046892 Request
Hi Seth,
I wanted to get your/CG&L's opinion on a matter that's come across my desk. The attached letter is a request from a
consultant wanting to temporarily remove two components from a treatment system to see if it would function within
permit limits without them (he believes it can). If things work out as they plan, they would ask for the permit to be
modified next year when it comes up for renewal. Please note the request refers only to outfall 002. As I've quizzed my
comrades around here about this matter, I've heard two general types of responses:
1. An AtoC was applied for, reviewed and approved for the existing system, essentially concurring with the permittee
that this is what will get the job done. Any physical change to the system would require review by CG&L to see if it
believes the modified system will still meet limits/protect water quality, followed by issuance of a modified AtoC.
2. This is to some degree an operations question and the operator should know what's best about running the system
and have the flexibility to not use some of these units if they are not needed. It is suggested we call this a "pilot study"
(as opposed to a "bypass") and allow the facility to take the units off line. They'll still be liable for enforcement if it
doesn't perform as they expect.
The system treats remediated groundwater and stormwater from loading racks at an oil terminal.. ,I've attached a copy
of the permit too.
I'II be out of the office on Friday, but 1 plan to be in all next week. Let me know what you think if you get the chance. I'd
like to get back in touch with the consultant to give him an idea of the process the request will go through and how long
1

it might take. I probably have some questions for him too. And when I first heard from this guy on the phone, I though
this was going to be easy...
Thank you,
Bob
Bob Sledge
Environmental Specialist
NPDES Western Unit
NC Division of Water Quality
[e-mail]
[phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be
disclosed to third parties.
2

Summary of Groundwater Reaediatka System Sampling
(All results amassed as micrograms pe liter (RAD
Motive Charlotte South Hulk Datt131wiaa Tannins!
Medea Cent Cana 0058503
6851 Freedom Drive
Charlotte, Mecklenburg County, North Carolina
NCDENR 1D 0 5740
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NS
NS
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NS
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Summary of Groundwater Rcmcdiation System Sampling
(All results expressed as micrograms per Titer (Ng/1.))
Motiva Charlotte South Bulk Distribution Terminal
Motiva Cost Center # 058503
6851 Frccdom Drive
Charlotte, Mecklenburg County. North Carolina
NCDENR ID # 5740
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Total BTEX + MTBE 2900.2 1209.1 1647.1 3278.4 3783 2106.4 2148.5 1858.8 2052 1325.8 1452.6 1388.6 1454.4 1175.6 2258.6 139.8 106.9
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MTBE - Methyl reetiaryburyl ether
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39 247.7 245.52 3631 2372 2631
GES Page I at 1 WW1- July 07

Summary ofGr undwaIer Ranad1a0os System Sampling
(All result* expressed as micrograms pa lily (p81L].1
Motive Clarion* Sacs Bull DissrilraLm Terminal
Maliva Cool Cana a OS8303
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Groundwater
11® & Environmental Services of North Carolina, Inc.
3344 Hillsborough Street • Suite 150 • Raleigh, North Carolina 27607 • [phone] • Fax [phone]
July 16, 2009
Mr. Bob Sledge
Division of Water Quality
NPDES Unit
North Carolina Department of Environment and Natural Resource
R Ec E ivE D
1617 Mail Service Center
Raleigh, NC 27699-1617
Subject: Temporary Bypass of System Components
Charlotte South Terminal
6851 Freedom Drive.
Charlotte, NC
NPDES Permit NC0046892
Dear Mr. Sledge:
UL 1 i 2 Op
DENR - WATER QUALITY
POINT SOURCE BRANCH
On behalf of Motiva Enterprises LLC (Motiva), Groundwater & Environmental Resources of North
Carolina, Inc., (GES) seeks permission to temporarily bypass two components of the onsite Water
Pollution Control System for the treatment of groundwater listed in National Pollution Discharge
Elimination System (NPDES) permit NC0046892.
The current treatment system for Outfall 002 consists of:
• Oil/water separator
• Three Granular Activated Carbon (GAC) adsorption units
• Air Stripper
• Flocculation Tank
• Clarifier
• Holding tank
A temporary bypass of the Flocculation Tank and Clarifier is sought at this time for a period of 6 months
to evaluate the impact of those units to the overall quality of treatment. Modifications to the system will
be made in such a manner that those components can be brought back online at the end of the 6 month
period if the absence of those components influences the treatment quality. If no influence or a positive
affect to the quality of treatment is noted then GES may petition for a permit modification.
Environmental Solutions and Liabi//fy Management

The modification request would likely be timed to coincide with the renewal process for the existing
permit. A request for continued temporary bypass would also be made to cover the projected time period
from permit submittal to permit modification approval.
We look forward to working with the NC DWQ NPDES Unit in the future. If you have any questions or
concerns regarding this request please call [phone] extension 4303.
Sincerely,
Groundwater & Environmental Services, Inc.
Hugh Nelson
Project Manager
Cc: Scott Burkey — Shell Oil Products US
File
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