NC0046892_Permit Issuance_20010730

NCDENR
Ms. Nicola Ellis
Motiva Enterprises LLC
2232 Ten -Ten Road
Apex, NC 27502
Dear Ms. Ellis:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
•�.....-
•
. July 30, 2001
•
Kerr T. Stevens, Director .• _
Division of Water Quality
Subject: Issuance of NPDES Permit NC0046892
Charlotte South Terminal
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,
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 both outfalls 001 and 002. 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 from both outfalls 001 and 002. 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.(4) for some additional requirements related to MTBE.
• The monthly monitoring requirement for naphthalene has been deleted from outfalls 001 and
002. 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 for outfall 001 and outfall 002 has been changed from monthly to
episodic. As per a request by the Mooresville Regional Office, flow must be measured with each
discharge event.
• The limit for 1,2 Dichloroethane for outfall 002 has been removed and the monitoring frequency
has been reduced to quarterly.- Data from the facility shows 1,2 dichloroethane has not been -- •
detected in the effluent.
• The monthly monitoring for fluorene and phenantherene has been removed from outfall 002.
EPA Method 625 will provide data for these parameters.
• The monthly monitoring for iron and manganese have been removed from outfall 002. The
primary treatment system for the groundwater is the air stripping unit. The carbon absorption units
are used as a polishing step. The requirement to monitor for iron and manganese would be necessary
if the carbon absorption unit was the only form of treatment for the groundwater to monitor the
efficacy of the treatment system.
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..1800 623-7748

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 Teresa Rodriguez at telephone
number [phone], extension 595.
Sincerely,
Steven
cc: Mooresville Regional Office/Water Quality Sec on
NPDES Unit
Central Files
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Department of Environmental Protection

Permit NC0046892
_.... _•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,
Motiva Entrprises, LLC
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte South Terminal
6851 Freedom Drive
Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Long Creek 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.
Kerr to s, Director
Divi • n • ' Water Quality
By Authority of the Environmental Management Commission

is hereby authorized to:
SUPPLEMENT TO PERMIT COVER SHEET
•
Motiva Enterprises, LLC
•
Permit NC0046892
1. Continue to discharge stormwater from diked tank storage areas via outfall 001 and
2. Continue to operate a water pollution control system for the treatment of groundwater and
stormwater from the truck loading racks area and discharge the treated waters via outfall 002. The
treatment system consists of the following components:
• Oil/water separator
• Three Granular Activated Carbon (GAC) absorption units
• Air Stripper •
• Floculation tank
• Clarifier
• Holding tank
This facility is located at the Charlotte South Terminal, 6851 Freedom Drive, Charlotte,
Mecklenburg County and
3. Discharge from said treatment facility at a specified location (see attached map) into an unnamed
tributary to Long Creek, a waterbody classified as WS-IV waters within the Catawba River Basin.

F3:
otiva Enterprises, LLC
Charlotte Terminal
State Grid/quad: F15SW (Mt Island Lake)
Laiitlxdc 35°16'42" N
Longitude 80°56'2T' W
Receiving Stream UP to Long Creek Drainage Basin: Catawba River Basin
Stream Class WS-W Sub -Basin: 30834
•
North
ei
NPDFR Permit No. NC0046892
Mecklenburg County

Permit NC0046892
A. (1).: EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
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Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge stormwater from diked areas from Outfall 001. Such discharges shall be limited and
monitored by the Permittee as specified below:
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A MONITORING
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Flows
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1
Effluent
Turbidity2
Quarterly
Grab
Effluent
Oil and Grease3
Monthly
Grab
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Phenol
0.09 mg/1
Monthly
Grab
Effluent
MTBE4
Monthly
Grab
Effluent
BTEX
Monthly
Grab
Effluent
EPA Methods 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.(4) 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 permittee may request a modification to
the permit that reduces or eliminates the monitoring requirement. _.. .
6. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(3)].- 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 NC0046892
•
A. (2) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS:
Beginning' on the effective date of the permit and lasting until expiration, the Permittee is' authorized to
discharge treated groundwater and stormwater from loading racks from Outfall 002. Such discharges
shall be limited and monitored by the Permittee as specified below:
"w it ,
MONITORING
REQUIREMENTS
Sarit� 1
'it Yh tyl' �
Typ •..
EFFLUE ter f 'i ;, :7:,`
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Flows
Episodic
1
Effluent
Turbidity2
Quarterly
Grab
Effluent
Oil and Grease3 •
Monthly
Grab
Effluent
Total Suspended Solids
30.0 mg/L
Monthly
Grab
Effluent
Phenol
0.07 mg/1
Monthly
Grab
Effluent
MTBE4
Monthly
Grab
Effluent
1,2 Dichloroethane
Quarterly
Grab
Effluent
Monthly
Grab
Effluent
BTEX
EPA Methods 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 Iarge 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.(4) 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 permittee may request a modification to
------ the permit that reduces or eliminates the monitoring requirement. ------------- ------ -------- - -- - _- _....___._
6. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(3)]. 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 NC0046892
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (3) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas)
24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste
treatment. The permittee will conduct one test annually, with the annual period beginning in January of
the calendar year of the effective date of the permit. The annual test requirement must be performed and
reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting 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 NC0046892
A. (4) 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
. By the 'ime •f the next permit renewal, it is anticipated that surface water criterion for MTBE
will be est:blish-d. This criterion will be used in conjunction with the facility's effluent MTBE
data to pe orm a reasonable potential analysis (RPA). The RPA will determine whether effluent
rom a fality ha • the potential to exceed a water quality standard or criterion, thereby requiring
water q ality li in the NPDES permit.

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9
THIE
Mecklenbu
TIMES
Charlotte, N.C.
AFFIThAVIT OF PU8LICA1
NORTH CAROLINA
MECKLENBURG COUNTY
Before the andenigned, .Notary I
North Carolina, duly commissioner
law to adlminuter oaths, personally
Shelby J. Cumm
THE heeddenburg TIMES, . nev
entered ass second-ehu mail in the
and Stets; that he/she is authorized e
statement that the notice or other In
NOTICE OF PUBLIC I-'
TO BE HELD BY THE
ENWIRONMENTAL MAN1
a We coma, of which is attached here[
teatime HIDES on the following de
March 16, 2001
and that doe said newspaper in whit[
or legal advertisement was publish.
every suegapublkali.n, a newspaper
andqualifficationa of Sec -lion 1.597c
Carolina and wag a qualified newspe
lion I.3927 of the Oeneral Statutes
min 16 th day of Mr
(Signed) �
Swamis. and subscribed b ore ['
16th dayof Hatch 201
Notary Publk
My Commission Expires: 7 / 7
p
s
Nu me e ye Yt/H1iC hlEARING
TO BEHELOBY _
THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
SUBJECT: A public hearing has been scheduled oxlceming the proposed renewal and issuance of
the following NPDES Permits:
- Permit number N00021962 to CITGO Petroleum Corporation for tie Paw Creek Terminal located in
Charlotte (Mecklenburg County) for the discharge of stormwater into an unnamed tributary to Gum
Branch.
- Pernik number NC0022187 to Motive Enterprises for the Paw Creek Terminal located in Charlotte
(Mecklenburg County) for -the discharge of stormwater and remedialted groundwater Into an unnamed
tributary to Gum Branch. •
- Permit number NC0032$91 to Philips Pipe Line Company for the Charlotte Terminal located in
Charlotte (MecMenburg County) for the discharge el Stcrrnwater ielo an unnamed tributary t0 Gum
Branch.
Petmil number NC0074705 to William Terminals Holdings, L.P. for the Chartotte/Sbulhem Facdities
Terminal located in Charlotte (Mecklenburg Cdunty) for the discharge of stormwater into an unnamed
tributary to Paw Creek. - -
• Pennll number NC0004723 to Valero Marketing 8 Supply Company for the Valero Marketing &
Supply Facility located in Charlotte (Mecklenburg County) for the discharge of stormwater into an
unnamed tributary to Paw Creek.•
• Permit number NC0005771 to TransMontaigne Terminating, Inc. for the Chadotte/Paw Creek Termi-
nal #1 located in Charlotte (Mecklenburg County) for the discharge of stormwater into an unnamed
tributary to Paw Creek. "
- Permit number NC0021971 to TransMontaigne Terminating, Inc. trot the Charlotte/Paw Creek Teniri-
nal #2 located M Charlotte (Mecklenburg County) for the discharge of stormwater into an unnarried
tributary to Paw Creek.
- Persist number NC0031038 to Colonial Pipeline Company for the Charlotte Delivery Facility located
in Charlotte (Mecklenburg County) for the discharge of stormwater Fto an unnarited tributary to Gum
Branch.
- Perrot number NC0046213 to Marathon Ashland Petroleum, LLC for the Marathon Ashland:Petro-
leum facility located in Charlotte (Mecklenburg County) tor the.diseharge of storrnwatec.lntd pan un-
named Tributary to Long Creek. ,
Permit number NC0046531 to Crown Central Petroleum Company for the Paw Creek Terminal
located in Paw Creek (Mecklenburg County) for the discharge of dosimeter Into an unnamed bibulary
to Gum Branch.
- Permit number NC004689210 Motive Enterprises, LLC for the Charlotte Terminal located in Paw
Creek (Mecklenburg County) for the discharge of stomrwater and remodiated groundwater to an
unnamed tnbutary to Long Creek.
-Permit number NC0004839 to ExxonMolil Refining & Supply Company for the Charlotte Terminal
coated in Charlotte (Mecklenburg County) for the discharge of stonwvrater and remediated groundwa
ter to an umrerned tributary to Long Creek.
Permit number N00005189 to 1MMiams Term he's Holdings, L.P. liar the Paw Creek Terminal located
n Paw Creek (Mecklenburg County) for the discharge of slormwaler to an unnamed tributary to Long
Creek.
PURPOSE: Each of these facilities has applied for renewal of orcyr NPDES permit for the discharge
of treated stormwater and/Or remedialed groundwater into waters of the Catawba River basin. On the
basis of preliminary staff review and application of Ar6de 21 of Chapter 143, General Statutes of North
Cardin, and otter 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 Duality pursuant to NCGS 143-215.1(c)(3)
and Regulations 15 NCAC 2H, Section .0100 has determined that it is in the pubic interest theta meeting
be held to receive all pertinent public comment on whether to issue, modify, or deny the permit.
PROCEDURE: The hearing will be conducted in the following manner
1. The Division of Water Quality will present an expfanatkih 01 the North Carolina Environment
Management Commission's permitting procedure.
2. The applicant may make an explanation of the action for which each permit is required,
3. Public Continent • Comnerits, statements, data and other infortwatiln may be submitted in writing
nor to or during the meeting or may be presented orally at the meednu Persons desiring to speak will
ndicate this Intent at the time of registration at the meeting. So that an persons desiring to speak may do
so, lengthy statements ;fay tie !mired at the discretion of the meeting officer. Oral presentations that
steed three minutes shouldbe accompanied by three written copies, which will be filed with Division
tali at the time of registration.
4. Cross examination of persons presenting testimony will not be allowed: however, the hearing
officer may ask questions for clarification.
5. The hearing record may be closed at the conclusion of the. meeting. •
WHEN: April 19. at 7:00 Or ,
WHERE: Charote•Meddentiurg Government Center - 600 East Fourth Street, CH-14
Charlotte, North Carolina
INFORMATION: A copy of the draft NPDES perrit(s) anda reap shoring the cation of the discharge(s)
are evadable by.writing or calling:
Ms. Christie Jackson
NC Division of Water Duality/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617 ..
Telephone number [phone], extension 538 .
The applications and other information are on file at the Division of Water Qualify. 512 North Salisbury
Heel, Room 925 of the Archdale Building in Raleigh, North Carolina and at the Division's Mooresville
egionat Office (919 North Main Street in Mooresville, NC). They may be inspected during normal office
ours. Copies of the information on file are available upon request and payment of the costs of
eproduction. All such camments and requests regarding this matter should make reference to the
ermit number(s) listed above.
$084 Mar 16 _

4
DIVISION OF WATER QUALITY
April 5, 2001
MEMORANDUM
TO: Dave Goodrich
FROM: D. Rex Gleason
PREPARED BY: Richard Bridgeman
SUBJECT: Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
ri===1l
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CC
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.
As discussed above, in addition to the sample collection location, the Colonial Pipeline
Co. (NC003103 8) 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 Refuting 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
WATFR rr nxnnoN
APR U2c1
Nonascharge 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 • (/ 04) 336-5500 • Fax [phone]

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 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 1.2/.2g/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,ug/1 and
toluene concentration is less than 11yg/1." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.194ug/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,
Rus ; ' ozzelle
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP

Svnt By: ; .919 821 0337;
May-2-01 16:32; Page 2/3
WILLIAM 11, WWNMZlERSPOON
EXICUCPR Timmy
May 2, 2001
NORTH CAROLINA
PETROLEUM
COUNCIL
A Di dada of the American Petroleum Institute
surrE 2850 • 150 FAYETT VILLE SF. MALL
AALEIGH. NC 27601
010/8284438 • FAX S11 0/821-03.37
Mr. Rick Shiver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 cardinal Drive Ext.
Wilmington, NC 28405-3845
Re: 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 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 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 ug/L 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 ofpublic
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 rea firm the value of
public hearings by calling for a permanent ruiemaking process to tighten the MTBE groundwater
mod. so aa• We au await the. #»Z:ns yeacAma ov that. Iswesicaat, we are now confronted with

Sent By: ;
919 821 0337; May-2-01 16:32;
Page 3/3-
Mr. lick Shiver
May 2, 2001
Paget
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 individrA1s 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, it 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 sc_ ual monitoring by
each of the terminals will provide the needed representative data to form the basis for future
decision -making.
Sincerely,
Oat' • '
William H. Weatherspoon
WHW/jm
c: Ms. Natalie Sierra

SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS
CONTAMINANT
CAS #
"C" & "B" WATERS
(ugll 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/I
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])

Permit Requirements for Discharges from Oil 8v 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 & 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 as 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
Acrolein
DETECTED IN OIL TERMINAL STORMWATER?
Acrylonitrile
Benzene
1
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane
1
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-Dichloropropene
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
1
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
Table 2. Compounds detectable by EPA Method 625
APA 2AMETER .
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-ethylhexyl)phthalate
Bis(2-chloroisopropyl)ether
4-Bromophenyl phenyl
ether
_ 2-Chloronaphthalele
4-Chlorophenyl phenyl
ether
Chrysene
Dibenzo (a,h)anthracene
Di-n-butylphthalate
1,3-Dichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
_
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
_]. ,2,4-Trichlorobenzene
4-C:hloro-3-methylphenol
2-Chlorophenol
2,4-Dichlorophenol
2,4-Diinethylphenol
_
_2,4-Dinitrophenol
2-Methyl-4,6-dinitrophenol
2-Nitrophenol
4-Nitrophenol
_
Pentachlorophenol
Phenol
1
2, 4 , 6-Trich lorophenol
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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), 7Q10 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 7Q10 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).
Page 6 of 8
Version 7/30/01

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 µg/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 µg/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.
Page 7 of 8
Version 7/30/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. MTBE
Monitor monthly
MTBE special condition
Given that this compound 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.
Page 8 of 8
Version 7/30/01

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0046892
- Facility Information
Applicant/Facility Name:
Motiva Enterprises LLC /Charlotte Terminal
Applicant Address:
P.O. Box 4540, Houston, TX 77210-4540
Facility Address:
_
6851 Freedom Drive, Paw Creek, N.C.
Permitted Flow
Outfall 001 is not limited
Outfall 002 is limited to 0.864 MGD per discharge
Type of Waste:
Stromwater from diked areas and groundwater and stormwater from the
loading racks areas
FacilitylPermit Status:
Active; Renewal
County:
Mecklenburg
Miscellaneous
Receiving Stream:
UT to Long
Creek
Regional Office:
Mooresville
Stream Classification:
WS-IV
State Grid / USGS Quad:
F15SW.(Mt.Island
Lake)
303(d) Listed?
No
Permit Writer:
Teresa Rodriguez
3/9/01
Subbasin:
03-08-34
Date:
Drainage Area (mi2):
0.01
.... - 4 .1,. : -•
Summer 7Q10 (cfs)
0
_, r ' r '
== ;7`"^ 3 " ,
`=<,k r
Lat. 35° 16' 42" N Long.
` " 41.-'
'
Winter 7Q10 (cfs):
0
.
y •
•
80° 56' 27" W
30Q2 (cfs)
0
Average Flow (cfs):
0
IWC (%):
100%
BACKGROUND
This facility changed ownership from Shell'Oil Company to Motiva Enterprises, LLC in October 1998.
They have two outfalls:
Outfall 001- discharges stormwater from the storage tanks dikes.
Outfall 002 - discharges treated groundwater and stormwater from the loading racks area. The treatment
system consists of Oil/water separator, three Granular Activated Carbon (GAC).absorption units,
an Air Stripper, a floculation tank, a clarifier and a holding tank.
FILE REVIEW
Correspondence
The Mecklenburg County Department of Environmental Protection (MCDEP) has performed 3
inspections since 1996. A deficiency was reported on January 1997 for reporting values as non detects in the
DMRs. Other areas inspected were rated as satisfactory.
DMR Review:
Outfall 001 - DMRs were reviewed for the period of January 1997 to December 2000. The mean
flow was 0.210 MGD. The maximum flow (used below in the reasonable potential calculations) was 0.576
MGD. Total suspended solids during this time averaged 7.2 mg/L for all the values above quantitation level,
the maximum value was .12 mg/L. Oil and Grease was detected twice at 1 lmg/L and 9 mg/L. Phenol was
detected four times with a maximum of 0.98 µg/L. The facility only reported results for three acute toxicity
test, 1997, 1998 and 1999, all of them pass. The DMRs indicated the dates the facility had done the EPA
624/625 test but the reports were not found in the files.
Fact Sheet
NPDES NC0046892
Renewal
Page 1
•

Y
1'
Outfal1002 - DMRs were reviewed for the period of January 1997 to December 2000. The mean flow
was 0.336 MGD. The maximum flow (used below in the reasonable potential calculations) was 0.7379 MGD.
Total suspended solids was below quantitation level on all samples. Oil and Grease during this time averaged
8.75 mg/L for all the values above quantitation level, the maximum value was 11 mg/L. Phenol was detected
twice at 0.08 µg/L and 0.06 µg/L. MTBE was detected four times with a maximum of 180 µg/L. They pass all
the quarterly toxicity tests. Naphtalene, Fluorene, phenantarene and 1,2 Dichloroethane were below
quantitation limit for all samples.
Reasonable Potential Analysis:
Outfall 001 — No reasonable potential was done for this outfall. Benzene and Xylene were always
reported below quantitaiton level.
Outfall 002 — Reasonable potential was run for toluene, xylene, and MTBE. The only parameter that
presented a reasonable potential to exceed water quality standards was MTBE. The maximum predicted
concentration for MTBE was 1134 µg/L, the allowable concentration is 11.6 µg/L.
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. Hereafter, this
document is referred to as the "2001 SOP."
Waste Load Allocation (WLA)
The last waste load allocation was performed in 1993. The Division judges this WLA to be reasonable.
for this permit renewal except as noted below in summary of proposed changes.
Oil Terminal SOP:
For Outfall 001 the flow, toxicity, TSS, EPA Methods 624/625 and oil and grease requirements
specified in the previous permit and the 2001 SOP (Parts I.A. — I.D.) remain unchanged. A daily maximum
limit of 0.09 mg/L was included for phenol based on the allocation for the Paw Creek area. The limit for phenol
was calculated using the maximum flow discharged for the evaluation period (0.5768 MGD) and the allocation
of 0.43 lbs/day for each discharger. The requirements in Part I.E and F of the 2001 SOP of monitoring for
BTEX and naphtalene were incorporated into the permit. 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.
For Outfall 002 the flow, toxicity, TSS, oil and grease, naphtalene, iron and manganese requirements
specified in the previous permit and the 2001 SOP (Parts I.A. — I.D.) remain unchanged. A daily maximum
limit of 0.07 mg/L was included for phenol based on the allocation for the Paw Creek area. The limit for phenol
was calculated using the maximum flow discharged for the evaluation period (0.7379 MGD) and the allocation
of 0.43 lbs/day for each discharger. EPA Method 624/625 was added to the permit as per Part II.A of the 2001
SOP. The toluene limit was eliminated since it does not present reasonable potential to exceed water quality
standards. Monitoring for benzene, toluene, ethylebnzene and xylene (BTEX) will be required as per Part I.E
of 2001 SOP. The limit for lead was eliminated. As indicated in the footnotes for the previous permit lead
monitoring is not required if it was not detected during the first eight sample events. A limit was added for
MTBE as specified in Part III.0 of 2001 SOP for dischargers to WS waters. This parameter also presented
reasonable potential to exceed the water quality standard. 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
Outfall 001
• Addition of MTBE limit.
• Addition of phenol limit.
Fact Sheet
NPDES NC0046892
Renewal
Page 2

• Addition of naphthalene monitoring.
• Addition of BTEX monitoring.
• Addition of quarterly turbidity monitoring.
Outfall 002
• Addition of MTBE limit.
• Addition of phenol limit
• Addition of quarterly turbidity monitoring
• Addition of semi-annual monitoring for EPA Method 624/625
• Elimination of toluene limit
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice:
Permit Scheduled to Issue:
March 14, 2001
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: --C—// /
SUPERVISOR: / J . l ;�' 1 /1��% DATE:
4
Fr-1 cq [E [r1-.7k
MAY - 2 2001 it
DENR - WATER IALITY
POINT SOURCE brtAfiCH
Fact Sheet
NPDES NC0046892
Renewal
Page 3

C1�eLtila r�Cci YtSL
GPR �t l /� 2.� U 1..4-(_F dv 2
MOTIVA
VIA AIRBORNE EXPRESS #6356635950
May 23, 2001
Ms. Teresa Rodriguez
North Carolina Department of Environment and Natural Resources
Division of Water Quality — NPDES Unit
512 N. Salisbury St., Room 925
Raleigh, NC 27604
ENTERPRISES LLC
Shell, Texaco & Saudi Aramco Working Together
Subject: Draft NPDES Permit - NC0046892
Motiva Enterprises LLC — Charlotte South Terminal
Charlotte, Mecklenburg County, North Carolina
Dear Ms. Rodriguez:
Per your e-mail dated April 26, 2001, Motiva Enterprises LLC (Motiva) hereby submits the following
comments addressing revisions to Draft NPDES Permit NC0046892 for our Charlotte -South Terminal in
Charlotte, North Carolina. As per my conversation with Ms. Valery Stephens on April 26, 2001, the
comment period for Motiva was extended to May 23, 2001.
• Please change contact name/mailing address for the new permit to:
Ms. Nicola Ellis
Environmental Engineer
Motiva Enterprises LLC
2232 Ten -Ten Road
Apex, NC 27502
• Motiva refers to this facility as the Charlotte -South Terminal, due to the fact that Motiva operates two
facilities in the Paw Creek area. Please change all references to the facility name in the permit from
`Charlotte Terminal' to `Charlotte -South Terminal';
• Per your cover letter, Semi -Annual monitoring for EPA method 624/625 was added to the
requirements for Outfall 002 as per Division policy to assess which of the petroleum associated
chemicals are found in stormwater'. Motiva would like to point out that Outfall 002 is not designated
specifically for stormwater. This outfall receives treated commingled water from the truck loading
rack area and groundwater system. Motvia requests that this monitoring requirement be removed
from this Outfall;
Motiva respectfully requests that the above listed comments be addressed prior to issuance of the final
NPDES permit. If you have questions, please contact me at 919-387-5764.
Sincerely,
Motiva Enterprises LLC
4/41,4z,
Nicola A. Ellis
Environmental Engineer
2232 Ten Ten Road
Apex, NC 27502
Phone: [phone] Fax: [phone]

REASONABLE POTENTIAL ANALYSIS
Prepared by: Teresa Rodriguez 3/8/01
Facility Name = Motiva Enterprises
NPDES # = I NC0046892/outfall 001
Qw (MGD) = 0.577
Qw (cfs) =
7Q 10s (cfs).
IWC (%) =
0.892425
0
100.00
Parameter
Chronic CCC w/s7Q10 dil. Acute CMC w/no dil.
FINAL RESULTS, ug/1 FINAL RESULTS, ug/I
Frequency of Detection
#Samples # Detects
Toluene
Max. Pred Cw
Allowable Cw
Xylene
Max. Pred Cw
Allowable Cw
Benzene
Max. Pred Cw
Allowable Cw
Phenol
Max. Pred Cw
Allowable Cw
MTBE
Max. Pred Cw
Allowable Cw
0.0
11.0
0.0
88.5
0.0
1.2
5.782
0.089
0.0
11.6
0 0
0 0
0 0
34 0
0 0
Modified Data: Use 0.5 Detection Limit for non -detects
Parameter= Phenol
Standard = 0.089 mg/I
Dataset=
ModifiedData Nondetects RESULTS
0.025 <.05 Std Dev. 0.164
0.025 <.05 Mean 0.056
0.025 <.05 C.V. 2.927
0.025 <.05 Sample# 34.000
0.025 <.05
0.025 <.05 Mult Factor =
0.025 <.05 Max. Value 0.980 mg/I
0.025 <.05 Max. Pred Cw 5.782 mg/I
0.025 <.05 Allowable Cw 0.089 mg/I
5.900
0.025 <.05
0.06 0.06
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.05 0.05
0.025 <.05
0.025 <.05
0.98 0.98
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.06 0.06
0.025 <.05

REASONABLE POTENTIAL ANALYSIS
Prepared by: Teresa Rodriguez 3/7/01
Facility Name =
NPDES # =
Ow (MGD) =
Ow (cfs) =
7010s (cfs)=
IWC (%) =
NC0046892/outfall 002
0.738
1.141679
0
100.00
Parameter
Toluene
Max. Pred Cw
Allowable Cw
Xylene
Max. Pred Cw
Allowable Cw
Phenol
Max. Pred Cw
Allowable Cw
MTBE
Max. Pred Cw
Allowable Cw
Chronic CCC w/s7Q10 dil. Acute CMC w/no dil.
FINAL RESULTS, ug/1 FINAL RESULTS, ug/I
6.0
11.0
8.5
88.5
0.128
0.069
1134.0
11.6
Modified Data: Use 0.5 Detection Limit for non -detects
Frequency of Detection
#Samples # Detects
32
32
31
32
2
2
2
4
Parameter = Toluene
Standard =
Dataset=
11
p94
Modified Data Nondetects RESULTS
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
2.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
2
0.5
0.5
0.5
0.5
0.5
0.5
2.3
0.5
0.5
0.5
0.5
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<5
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
<1
Std Dev.
Mean
C.V.
Sample#
Mull Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.527
0.666
0.792
32.000
2.400
2.500 pg/I
6.000 pg/I
11.000 pg/I
Parameter = Xylene
Standard =
Dataset=
88.5
DMR97-00
pg/I
Modified Data Nondetects RESULTS
1.5 <3 Std Dev.
1.5 <3 Mean
1.5 <3 C.V.
1.5 <3 Sample#
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <5
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
5
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
3.2
1.5 <3
Mutt Factor =
Max. Value
Max. Pred Cw
Allowable Cw
0.679
1.663
0.408
32.000
1.7001
5.000 pg/I
8.500 pg/I
88.500 pg/I

Parameter =
Standard
Dataset=
Phenol
0.069
mg/I
ModifiedData Nondetects RESULTS
0.025 <.05
0.025 <.05
0.025.<.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.08
0.025 <.05
0.025 <.05
0.06
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.01
0.025 <.05
0.025 <.05
0.025 <.05
Std Dev. 0.012
Mean 0.028
C.V. 0.413
Sample# 31.000
Mult Factor
Max. Value 0.080 mg/i
Max. Pred Cw 0.128 mg/I
Allowable Cw 0.069 mg/I
1.600
Parameter = MTBE
Standard = 11.6 pg/I
Dataset=
ModifiedData Nondetects RESULTS
2.5 <5 Std Dev.
2.5 <5 Mean
2.5 <5 C.V.
2.5 <5 Sample#
2.5 <5
2.5 <5 Mult Factor =
2.5 <5 Max. Value
2.5 <5 Max. Pred Cw
2.5 <5 Allowable Cw
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
18
180
100
7.4
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5
2.5 <5'
35.264
11.731
3.006
32.000
6.300
180.0 pg/I
1134.0 pg/I
11.6 pg/I

NC0046892 Motiva Enterprises LLC
Mecklenburg County
Date Flow TSS 0 & G Benzene T l �n � *Rio Ethylben • I Ith o,1';`=,,,w 1,2DCE NTitia,.; I Naphta
(MGD) (mg/L) (mg/L) (ug/L) (ug/L) (ug/L) (ug/L) (mg/L) (ug/L) (ug/L) (ug/L)
Jan-97 0.501944 <10 9 <.05
Feb-97
Mar-97 0.195301 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
0.226915
Apr-97 0.6842 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
May-97 0.3284 <10
Jun-97 0.5838 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Jul-97 0.2736 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Aug-97 0.2462 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Sep-97 0.1488 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Oct-97 0.3648 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
0.1687
Nov-97 0.2189 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Dec-97 0.3283 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Jan-98
Feb-98 0.3604 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Mar-98 0.2987 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Apr-98
May-98 0.431 <10 <5 <5 <5 <5 <5 <.05 <5 <5 <10
Jun-98 0.2367 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Jul-98 0.3426 <10 <5 <1 <1 <3 <1 <1 <5 <10
Aug-98 0.2536 <10 <5 <1 <1 <3 <1 0.08 <5 <5 <10
Sep-98
Oct-98 0.4151 <10 <5 <1 <1 <3 <1 <.05 <1 <5 <10
Nov-98 0.3992 <10 7 <1 <1 <3 <1 <.05 <1 18 <10
Dec-98 0.2189 <10 <5 <1 <1 <3 <1 0.06 <1 180 <10
Outfall 002
Jan-99 0.2919 <10 8 <1 <1 <3 <1 <.05 <1 100
0.501
Feb-99
Mar-98
Apr-99
May-99
Jun-99
Jul-99
Aug-99
Sep-99
Oct-99
Nov-99
Dec-99
0.4006
0.7379
0.364
0.317
0.378
0.3558
0.2668
0.317
0.285
0.22
0.4265
<10
<10
<10
<10
<10
<10
<10
<10
<5 <1 <1 <3 <1 <.05 <1 <5 <10
Fluoren
(ug/L)
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
Phenar
(ug/L)
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10 <10
<5 <1 2 5 <1 <.05 <1 <5 <10 <10 <10
<5 <1 <1 <3 <1 <.05 <1 <5 <10 <10 <10
<5 <1 <1 <3 <1 <.05 <1 <5 <10 <10 <10
<5 <1 <1 <3 <1 <.05 <1 <5 <10 <10 <10
<5 <1 <1 <3 <1 <.05 <1 <5 <10 <10 <10
<5 <1 <1 <3 <1 <1 7.4 <10 <10 <10
11 <1 <1 <3 <1 <.05 <1 <5 <10
<10 <10
Jan-00

Feb-00
Mar-00
Apr-00
May-00
Jun-00
JuI-00
Aug-00
Sep-00
Oct-00
Nov-00
Dec-00
0.3125
0.3056
0.3352
0.3718
0.0889
0.2981
<10
<10
<10
<2
<2
<6
<5
<5
<5
<5
<1
<1
<1
<1
<1
<1
<1
<1
<1
2.3
<3
<3
<3
<3
3.2
<1
<1
<1
<1
<1
<.05
<.05
<.05
<.01
<.05
<1
<1
<1
<1
<1
<5
<5
<5
<5
<5
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
MMARY
Flow
(MGD)
TSS
(mg/L)
0 & G
(mg/L)
Benzene
(ug/L)
TqN
(ug/L)
(ug/L)
Ethylbenz
(ug/L)
p,l;ii ,.
(mg/L)
1,2DCE
(ug/L)
Mgt_E,;E,r
(ug/L)
Naphta
(ug/L)
Fluoren
(ug/L)
Phenar
(ug/L)
Tox
Ave
0.336577
0.7379
8.75
2.15
4.1
0.07
76.35
Max
11
2.3
5
0.08
180
# samples
33
33
32
32
32
32\
31
32
32_ 32
32
32
15
#detects
0
4
0
2
2
0,
2
0
4 0
0
0
Phenol limit calculation
Max flow 0.7379 MGD
Limit = 0.069872 mg/I

NC0046892 Motiva Enterprises LLC Outfall 001
Mecklenburg County
Date
Flow
TSS
0 & G
Phenol
Benzene
Xylene
EPA 624/i
Tox
(MGD)
(mg/L)
(mg/L)
(mg/L)
(ug/L)
(ug/L)
(ug/L)
Jan-97
0.2135
<10
11
<.05
Feb-97
Mar-97
Apr-97
0.215
<10
<5
<.05
<5
May-97
0.2467
-•••:•:•:•:.:•:•:•:•:•:•
<10
<5
<.05
<1
P
Jun-97
iiiiiiiiiiiiiiii!:
*
JuI-97
<10
<5
<.05
<1
<1
•6.19
Aug-970:piii:iiiiiii:iiiii:
Sep-97
Oct-97
iiitiiii
<10
<5
<.05
<1
<3
*
Nov-97
Dec-97
iiiiik
<10
<5
<.05
<1
0.1588
0.0921
0.2639
Jan-98
0.1817
<10
<5
<.05
<1
Feb-98
0.2444
<10
<5
<.05
<1
0.1676
0.082
0.0901
Mar-98
0.3001
<10
<5
<.05
<1
<3
*
Apr-98
0.3323
12
<5
<.05
<1
0.1072
0.1071
May-98
0.1759
<10
<5
0.06
<1
<3
P
Jun-98
0.2367
<10
<5
<.05
<1
JuI-98
0.0865
2
<5
<.05
<1
0.3713
Aug-98
0.161
<10
<5
<.05
<1
Sep-98
0.2789
<10
<6
<.05
<1
<3
*
0.1246
Oct-98
0.1234
<10
<5
<.05
<1
Nov-98
Dec-98
0.2966
<10
<5
0.05
<1
<3
Jan-99
0.1678
<10
<5
<.05
<1
<3
0.1539
0.0904
Feb-99
0.289
<10
<5
<.05
<1
Mar-98i!iiiiiiiiiiiiiiiiiiiiiii
Apr-99
May-99
0.4122
<10
<5
0.98
<1
<3
P
Jun-99
0.2556
<10
<6
<.05
<1
<3
0.1806
JuI-99
0.1548
<10
<5
<.05
<1
Aug-99
Sep-99
iiiiiiii
<10
<5
<.05
<1
<3
*
Oct-99
0.199
<10
<5
<.05
<1
0.5768
Nov-99
Dec-99
6.1766
<10
<5
<.05
<1
*
0.1405
Jan-00
0.3371
<10
<5
<.05
<1
Feb-00
0.1448
<10
<6
<.05
<1
0.1822
Mar-00
0.3843
<10
<5
<.05
<1
<3
*
Apr-00
0.1982
<10
9
<.05
<1
<3
0.2581
May-00
<10
<5
<.05
<1
*
....0:078
Jun-00iiiiiiiinii;iiiii..iii
.
Jul-001. 0.1533
12
<5
<.05
<1
* test was done data wasn't in DMR
No disch

Aug-00
Sep-00
Oct-00
Nov-00
Dec-00
iiiiii
0.0947
0.327
0.243
0.1451
0.222
0.162
0.21
0.1336
5
<2
SUMMARY
3
<5
<5
<5
<.05
0.06
<.05
<1
<1
<1
<3
Flow
(MGD)
TSS
(mg/L)
0 & G
(mg/L)
Phenol
(mg/L)
Benzene
(ug/L)
Xylene
(ug/L)
EPA 624/1
(ug/L)
Tox
Ave
Max
0.210257
0.5768
6.8
10
0.2875
12
11
0.98
# samples
38
38
38
35
15
11
4
#detects
5
2
4
0
0
Phenol limit calculation
Max flow 0.5768 MGD
Limit = 0.089388 mg/1

REASONABLE POTENTIAL
Prepared by:
Facility Name =
NPDES # =
Ow (MG()) =
Ow (cfs) =
7010s (cfs)=
IWC (%) =
ANALYSIS
Teresa Rodriguez 3/7/01
Motiva Enterprises
tNC0046892/outfall 002
0.738
1.141679
0
100.00
Chronic CCC w/s7010 dil. Acute CMC w/no dil.
Frequency of Detection
Parameter
FINAL RESULTS, ug/I FINAL RESULTS, ug/I
#Samples # Detects
Toluene
Max. Pred Cw
6.0
Allowable Cw
11.0
32 2
Xylene
Max. Pred Cw
8.5
Allowable Cw
88.5
27 1
0
Max. Pred Cw
0 0
Allowable Cw
0.0
0 0
Phenol
Max Pred Cw
0 1
Allowable Cw
1 0
31 2
MTBE
Max. Pred Cw
1134.0
Allowable Cw
11.6
32 4

Parameter =
Standard =
Dataset=
Toluene
11
Modified Data Nondetects
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0,5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
2.5 <5
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5<1
0.5 <1
0.5 <1
0.5 <1
2
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
2.3
0.5 <1
0.5 <1
0.5 <1
0.5 <1
pg/I
RESULTS
Std Dev. 0.527
Mean 0.666
C.V. 0.792
Sample# 32.000
Mult Factor =
Max. Value 2.500 pgA
Max. Pred Cw 6.000 ug/i
Allowable Cw 11.000 pg/i
2.400
Parameter = 12Cylene
Standard = 88.5
Dataset= DMR97-00
pg/
Modified Data Nondetects RESULTS
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <5
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
5
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
1.5 <3
Std Dev. 0.674
Mean 1.630
C.V. 0.413
Sample# 27.000
Mult Factor =
Max. Value 5.000 pgA
Max. Pred Cw 8.500 pgA
Allowable Cw 88.500 pgA
1.700
Parameter = Phenol
Standard
Dataset=
1 pg/I
ModifiedData Nondetects RESULTS
0.025 <.05 Std Dev. 0.012
0.025 <.05 Mean 0.028
0.025 <.05 C.V. 0.413
0.025 <.05 Sample# 31.000
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.08
0.025 <.05
0.025 <.05
0.06
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.05
0.025 <.01
0.025 <.05
0.025 <.05
0.025 <.05
Mull Factor =
Max. Value 0.080 pgA
Max. Pred Cw 0.128 pgA
Allowable Cw 1.000 pgA
1.600
Parameter =
Standard =
Dataset=
ModifiedData
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
18
180
100
7.4
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
2.5
MTBE
11.6
Nondetects
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
<5
pg/I
RESULTS
Std Dev.
Mean
C.V.
Sample#
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
35.264
11.731
3.006
32.000
6.300
180.000 pg/i
1134.000 pg/i
11.600 PO

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
From:
Subject:
April 2, 2001
Britt Setzer
NC DENR / DEH / Regional Engineer
Mooresville Regional Office
Teresa Rodriguez
NPDES Unit
Review of Draft NPDES Permit NC0046892
Motiva Enterprises LLC — Charlotte Terminal
Mecklenburg County
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
RECEIVED
APR 0 4 2001
NCDENR
Division of Environmental Health
['Al--; Water Supply Section
►Me _ . ;ville Regional Office
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.
,^�,wwwww,v'wwwwwwwwwwS AAINVwwwANANNV VAN/V wS �wwwwwww w
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.
l ��Concurs with issuance of the above permit. provided the following con liti ins (t�l� d
An 11 2001
Opposes the issuance of the above permit, based on reasons stated belo
or
DENR - WATER DUALITY
• T..OURCE BRANCH
Signed
Date: 2ffDld I
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 595 (fax) 919 733-0719
VISIT us ON THE INTERNET © http://h2o.enr.state.nc.us/NPDES Teresa.Rodriguez@ ncmail.net

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
March 7, 2001
Mr. Eric Hetrick
Motiva Enterprises, LLC
6851 Freedom Drive
Charlotte, North Carolina 28214
A;r1
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: NPDES Permit Renewal Application
Permit NC0046892
Motiva Enterprises LLC
Mecklenburg County
Dear Mr. Hetrick:
The NPDES Unit received your permit renewal application on March 1, 2001. Thank you for submitting this package.
The permit renewal for this facility will be assigned to a member of the NPDES Unit staff. That staff member will contact you if
further information is needed to complete the permit renewal. Please note that the NPDES Unit has several vacant positions. This
staff shortage has lasted for over a year and is delaying all permit renewals. Our remaining permit writers are currently reviewing
Authorizations to Construct, speculative limit requests, major permit modifications and 201 plan updates ahead of permit renewals.
This is necessary due to a variety of factors, including mandatory deadlines in the statutes which govern our program.
To facilitate permit renewal, the NPDES Unit is requesting that oil terminal bulk storage facilities submit a few additional items. As
soon as possible, please submit the following items:
• A site plan indicating all sources of stormwater, washwater, and other wastewater (including any discharge from a
groundwater remediation system) being discharged from the permitted outfall(s).
• If available, a disk or electronic copy of the past five year's worth of discharge monitoring report data from your
facility. Microsoft Excel is the preferred format for such data.
• A brief description of the manner in which tank solids, tank bottom water, the rag layer, and any other waters are
disposed.
If the staff shortage delays reissuance of NC0046892 the existing requirements in your permit will remain in effect until the permit is
renewed (or the Division takes other action). We appreciate your patience and understanding while we operate with a severely
depleted staff If you have any additional questions concerning renewal of the subject permit, please contact me at [phone],
extension 520.
Sincerely,
avizA.A.1 pk,„,c7
Valery Stephens
Point Source Unit
cc: Mooresville Regional Office, Water Quality Section
NPDES File

February 27, 2001
NCDENR
cn
Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
1_
RE: NPDES Permit Applications — Short Form C Renewal Applications
North Carolina Motiva Enterprise Facilities
To Whom It May Concern;
On behalf of Equiva Services, LLC, Applied Earth Sciences, Inc (AES) has
prepared the attached National Pollutant Discharge Elimination System (NPDES)
renewal permits using the Short Form C templates. The renewal applications have been
prepared for the following four Motiva Enterprise facilities:
101 South Chimney Rock Road 2232 Ten -Ten Road
Greensboro, NC 27409 Apex, NC 27502-8115
6851 Freedom Drive 410 Tom Sadler Road
Charlotte, NC 28214 Charlotte, NC 28214
Should you have any questions regarding the attached permit renewal
applications, please contact Ms. Anna Tillman of Equiva Services, LLC at (404) 321-
0695.
Sincerely;
APPLIED • RTH SCIENCES, INC.
Eric G. Hetrick
Project Geologist
814 Davidson Road • Concord, North Carolina 28025 • Tel: [phone] • Fax: [phone]

( ct�C�CI
SOC PRIORITY PROJECT: Yes No X
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: April 11, 2001
NPDES STAFF REPORT AND RECOMMENDATION
County: Mecklenburg
MRO No.: 01-54
Permit No. NC0046892
PART I - GENERAL INFORMATION
c--� ,
co
0
r�
1. Facility and Address: Motiva Enterprises
6851 Freedom Drive
Charlotte, North Carolina 28214
2. Date of Investigation: 04-03-01
3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. Larry Couch,
Terminal Manager; [phone]
5. Directions to Site: From the junction of I-85 and Highway
27 in Charlotte, travel west on Highway 27 (Freedom Drive)
approximately three (3) miles to Old Mt. Holly Road. Motiva
Enterprises is located on the left at the intersection of
Old Mt. Holly Road and Freedom Drive.
6. Discharge Point(s). List for all discharge points:
Latitude: 35° 16' 42" Longitude: 80° 56' 27"
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
7. Site size and expansion are consistent with application?
Yes X No If No, explain:
8. Topography (relationship to flood plain included): Flat to
gently sloping. 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 Long Creek.
a. Classification: WS IV
b. River Basin and Subbasin No.: Catawba River Basin;
030834
c. Describe receiving stream features and pertinent
downstream uses: The receiving stream is a dry ditch.
Typical Class C uses downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted:
Stormwater discharge from the tank farm area is
intermittent depending on rainfall. The permitted
discharge from the Groundwater remediation system and
the truck loading rack stormwater is 0.058 MGD.
b. What is the current permitted capacity of the
wastewater treatment facility? 0.058 MGD
c. Actual treatment capacity of the current facility
(current design capacity)? 0.058 MGD
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 groundwater treatment
facilities consist of an oil/water separator, an air
stripper, two flocculation tanks, a clarifying basin,
carbon filtration and a holding tank. The wastewater
treatment at the loading/unloading area consists of an
oil/water separator and a holding tank. From the
holding tank the wastewater is directed through the
groundwater remediation system.
f. Please provide a description of proposed wastewater
treatment facilities: N/A
NPDES Permit Staff Report
Page 2

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: Tank
bottom water is pumped to a holding tank and is treated
through the ground remediation system. Tank solids are
handled by Ensco, Inc., Tel# [phone].
3. Treatment plant classification: Class I.
4. SIC Code(s): 5171
Primary: 53
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: Acute toxicity monitoring is already included in
the permit.
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: 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. Hazardous material
stored at the site may be a constant threat to the
groundwater. Air Quality Permits required by Mecklenburg
NPDES Permit Staff Report
Page 3

County.
PART IV - EVALUATION AND RECOMMENDATIONS
Motiva Enterprises, has applied for renewal of its NPDES
permit.
During the inspection, the facilities appear to be well
operated and maintained.
It is recommended that the NPDES permit for this facility be
renewed pending review by the Groundwater section.
Signature of Sep drt Preparer
Water Quali
Regional Supervisor
NPDES Permit Staff Report
Page 4
— 6
Date
ate

(2,3)
She!! Oil Products Company
Two Shell Plaza
P. O. Box 2099
Houston, TX 77252-2099
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
•
March 4, 1997 .,;.: '
w `.,
D. Rex Gleason, P.E. : -
CO 1' i
Water Quality Regional Supervisor r �: ,-;
State of North Carolina �' ran rn
Department of Environment, iL--)rn
3
Health and Natural Resources ,v x
Ca
919 North Main Street c.n -
Mooresville, North Carolina 28115 co -''
Subject: Compliance Evaluation Inspection Written Response
NPDES Permit No. NC0046892
Dear Mr. Gleason:
As requested, the following is our written response addressing the deficiencies noted in
the inspection report conducted by Mr. David Caldwell of the MCDEP on January 27,
1997. A copy of the MCDEP inspection report is attached.
Records/Reports Section: "It was noted that "ND" (not detected) was recorded on
DMRs for several parameters during the review period. Where appropriate the data
should be reported as less than (<) the detection limit of the laboratory. "ND" is not an
acceptable reporting method on the DMR. This was also noted on the previous inspection
dated May 13, 1996."
Response: The facility has been recording the laboratory results (ie: not -
detected) on the DMRs as they appear in the laboratory report. In
order to facilitate the confirmation of the detection limit used for the
analysis, the plant operator has been instructed to use less than (<) the
detection limit, not ND, when filling in the laboratory data on the
DMR form.
Self -Monitoring Program Section: "Self -monitoring reports (DMRs) were reviewed for
the period April through December 1996. The reports indicate that the facility was in
compliance with permit effluent limits during this period, except for the following:
1. The (2) exceedances in violations of monthly average permit effluent limit for
flow rate were noted for Outfall 002. These occurred for the months of 10/96
and 11/96.

Records indicate that all parameters are being monitored at the proper frequency and
location as required by the permit. Sample collection techniques appear adequate."
Response: We discussed the above noted flow deficiency with the permit writer,
Mr. Steve Pellei, Division of Water, in Raleigh, North Carolina. He
has concurred that we are not out of compliance with the permit flow
limitation. However, the permit at Outfall 002 will be modified to
clarify the flow limit. It is our understanding that the permit will state
that flow will be limited to intermittent discharges of 24 hours or less,
twice per month, not to exceed 0.864 MG per discharge. The
discharges at Outfall 002 meet these limitations for flow.
If you have any questions or require additional information, please feel free to contact me
at 713/241-2011.
Sincerely,
H. James Sewell
Sr. Environmental Engineer
Transportation Engineering
Environmental Engineering
attachment
cc: Mr. Rusty Rozzelle
Mecklenburg County DEP
700 N. Tryon Street
Suite 205
Charlotte, NC 28202
Mr. Steve Pellei
State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
P.O. Box 29535
Raleigh, North Carolina 27626-0535

FROM SHELL OIL COMPANY -CHARLOTTE PLANT
02.20.1997 12:18 P. 1
State of Norl h Carolina
Department of Environment,
Health and Natural Resources
Mooresville Regional Office
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
Mr. Craig King
Shell 0i1 Company
6851 Freedom Drive
Charlotte, NC 28214
Ar;IrA
EDEHNR
DIVISION OF WATER QUALITY
February 18, 1997
Subject: Compliance Evaluation
Inspection
Shell Oil Company
NPDES Permit No. NC0046892
Mecklenburg County, N.C.
Dear Mr. King:
On January 27, 1997 Mr. David Caldwell of the Mecklenburg
County Department of Environmental Protection (MCDEP) conducted an
inspection at the subject facility. This inspection was conducted
as part of a cooperative working agreement between Mecklenburg
County and the Division of Water Quality. The enclosed report
should be self-explanatory.
It is requested that a written response be submitted to this
office by no later than March 10, 1997 addressing the deficiencies
noted in the Records/Reports and Self -Monitoring Program sections
of the attached Report. Please direct your response to Mr. Richard
Bridgeman of this Office. Additionally, please send a copy of the
response to Mr. Rusty Rozzelle of MCDEP at 700 N. Tryon St., Suite
205, Charlotte, NC 28202.
If you have any questions concerning this report or any other
matters, please do not hesitate to call Mr. Richard Bridgeman or me
at this Office.
Enclosure
cc.
DMC
sincerely,
f� 1?--re 6-4'n444 `t
D. Rex Gleason, P.E.
Water Quality Regional Supervisor
Rusty Rozzelle, MCDEP
Paw Creek Environmental Health and Safety Committee
919 North Moln Strout,
Mooresville, North Carolina 28115
Voice 704-663-1699
N*C
FAX [phone]
An Equal Opportunity/Affirmalivo Action Employer
50% recycled/10% post-consurnor popor

'FROM SHELL OIL COMPANY -CHARLOTTE PLANT
02.20.1997 12:19
P. 4
Facility: Shell Oil Company
NPDES Permit No.: NC0046892
Inspection Date: January 27, 1997
GENERAL:
This facility was last inspected on April 15, 1996 by Ms.
Barbara Wiggins of the Mecklenburg County Department of
Environmental Protection (MCDEP).
PERMIT:
The current permit became effective o Siaincludes Ptem Outfall 1, 1996 (6tand
expires August 31, 2001. The permit groundwater and truck loading rack
m
water) and Outfall 002 (treated
storm water). The permit appears adequate for the waste stream
being treated.
RECORDS/REPORTS:
The Permittee maintains daily logs and records/reports
relative to self -monitoring, laboratory results and discharge
events. Discharge Monitoring Reports (DMRs) were reviewed for the
period April 1996 through December 1996 for both Outfalls.
It was noted that "ND" (not detected)..was recorded on DMRs for
several parameters during the review period. Where appropriate,
the data should be reported as lees than (<) the detection limit of
the laboratory. "ND" is not an acceptable reporting method on the
DMR. This was also noted on the previous inspection dated May 13,
1996.
FACILITY SITE REVIEW:
The facility is engaged in gasoline and diesel fuel storage
and distribution.
The treatment works for Outfall 001 consists of containment
basins surrounding the above ground storage tanks. Storm water is
held in these basins until it is manually released.
The treatment works for Outfall 002 consists of a groundwater
remediation system. The system includes an oil/water separator,
particulate filters, three 2000 lb. carbon vessels, five tray air
stripper, flocculation tank, clarifier with overflow weir, and
final holding tank.
Discharges from the loading rack area go into an oil/water
separator which discharges into a holding tank until shipment off
site fcr disposal.
A11 of the major components -of Outfall 001 and 002 treatment
works were in service and appeared to be operating properly at the
time of the inspection.

`FROM SHELL OIL COMPANY -CHARLOTTE PLANT 82.20.1997 12:19 P. 3
Facility: Shell Oil Company
NPDEB Permit No.: NC0046892
Inspection Date: January 27, 1997
FACILITY SITE REVIEW: continued
Both Outfalls discharge to an unnamed tributary to Long Creek,
which is classified as Class "WS-IV" waters in the Catawba River
Basin.
FLOW MEASUREMENT:
Flow is -monitored from Outfall-001-usIng a flow meter. Flow
from Outfall 002 is monitored using tank gauges.
LABORATORY:
Analysis of effluent samples is performed by Prism
Laboratories, Inc. E.T.T. Laboratories performed Acute and Chronic
Toxicity testing. Prism and E.T.T. Laboratories were not
evaluated under this inspection.
EFFLUENT/RECEIVING WATERS:
At the time of the inspection, there was no discharge from
either outfall.
SELF -MONITORING PROGRAM:
Self --monitoring reports (DMRs) were reviewed for the period
April 1996 through December 1996. The reports indicate that the
facility was in compliance with permit effluent limits during this
period, except for the following:
1. Two (2) exceedances in violation of monthly average permit
effluent limit for Flow rate were noted for Outfall 002.
These occurred for the months of 10/96 and 11/96.
Records indicate that all parameters are being monitored at
the proper frequency and location as required by the permit.
Sample collection techniques appear adequate.

.4 "•
FROM SHELL OIL COMPANY -CHARLOTTE PLANT
82.28.1997 12:18
P. 2
united, States Environmental Protection Agency
Washington, D.C. 20460
NPDES COMPLIANCE EVALUATION REPORT
t Section At National Data System Coding
Transaction Code NPDES yr/mo/day Inspection Type Inspector
18LEJ 19U
1LJ 2151
U 3�.i.C1010141G1819�2I11 1219171011,Z17117
Face Type Remarks
' 11°l°I ' 1 JD.l�I!J 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 J 66
20U 211MIE1C1KI
Facility
Reserved Eval. Rating DI QA Reserved
I 169 U �J 751 1 1 1 1 1 180
671 70 716 721___1 73 74
Section 8i Facility Data
Name and Location of Facility Inspected
Shell Oil Company
Entry Time
11:00
EAM
LiPM
Permit Effective Date
September 1, 1996
6851 Freedom Dr.
Charlotte
Mecklenburg County, N.C.
Exit-Time/Date
12:00 January 27, 1997
Permit Expiration Date
August 31, 2001
Name(n) of On -Site Representative(e)
Title(s)u Terminal Receiver in Charge
Mr. Craig King
Phone No. (s) $
[phone]
Name% Address of Responsible Official
Mr. Craig King
Titles
Terminal Receiver
Phone No.(a):
[phone]
Shell Oil Company
6851 Freedom Dr.
Charlotte N.C. 28214
[xi
Contacted
Yes NoyM-�_
!
1
Section Ct Areas Evaluated During Inspection
(S=Satisfactory, M=Marginal, UaUnsatiefactory, N=Not Evaluated)
S
Permit
S
Flow Measurement
NA
Pretreatment
S
Operations &
Maintenance
S
Records/Reports
8
Laboratory
NA
Compliance Schedules
NA
Sludge Disposal
S
Facility Site Review
S
Eff/Reo. Waters
M
Self -Monitoring
.
Other
. --- Program
Section Di Summary of Findings/Comments
SEE ATTACHED PAGE(S)
Name(s) and Signature (a) of Inspector (s)
David Caldwell 90444;Gjulismila-
Agency/Office/Telephone
MCDEP/Charlotte/
[phone]
Date
1'ebruary 13, 1997
4
Signature of Reviewer
•
Agency/Office
Date
__�.-.._........ ...._ ....... - Regulatory Office Use Only
Action Taken
Date
--
Compliance Statue
Noncompliance
Compliance .