NC0046892_Permit Modification_19960311

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
March 11, 1996
Mr. H. James Sewell
Shell Oil Company
Eastern Transportation Region
1415 West 22nd Street
Oak Brook, Illinois 60522-9008
111C5ITA
1:)HNF1
Subject: NPDES Permit Modification
Permit No. NC0046892
Shell Oil/Charlotte Terminal
Mecklenburg County
Dear Mr. Sewell:
The subject permit issued by the Division of Environmental Management on February 28, 1994 has
been modified as per your request. The method of discharge at outfall 002 is now changed from
continuous to intermittent with no discharge to exceed 24 hours nor any discharge event to exceed twice
per month. As a result, the toxicity monitoring requirement is now changed from chronic toxicity testing
(Ceriodaphnia, 7-Day) to acute toxicity testing (Fathead Minnow, 24-Hour). In addition, the discharge
of tank condensate water to the water treatment system will no longer be permitted.
Enclosed please find the modified effluent limitations/monitoring requirements page and the modified
Part III (Other Requirements) paragraph H page for outfall 002. These pages should be inserted into
your permit, replacing the old pages, which should be discarded. This permit modification 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 December 6,
1983.
Please take notice that this permit is not transferable. Part II, E.4. addresses the requirements to be
followed in case of change in ownership or control of this discharge. This permit does not affect the
legal requirement to obtain other permits which may be required by the Division of Environmental
Management or permits required by the Division of Land Resources, 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 Steven Pellei at telephone number 919/733-5083, ext. 516.
Attachment
cc: Central Files
Mooresville Regional Office, Water Quality
Sermits and Engineering Unit
Facility Assessment Unit
Sincerely,
-r✓A. Preston Howard, Jr., P.E.
Section
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

A. (). EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS FINAL
Permit No. NC0046892
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge from
outfall(s) serial number 002 - contaminated groundwater and truck loading rack contaminated stormwater. These waters will pass through an
approved treatment system prior to discharge. Such discharges shall be limited and monitored by the Permittee as specified below:
Effluent Characteristics
Flow**
Oil and Grease
Benzene
Toluene
1,2 Dichloroethane
Lead
Xylene
MTBE
Acute Toxicity ***
**
***
Discharge Limitations
l b s/day Units (specify)
Monthly. Avg. Daily Max. Monthly. Avg. Daily Max.
30.0 mg/I
60.0 mg/I
1.19 µg/l
11.0 µg/I
99.0 µg/l
25.0 µg/I
Measurement
Frequency
Continuous
2/Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Quarterly
Monitoring
Sample
Ty ee
Recording
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Grab
Requirements
*Sample
Location
E
E
E
E
E
E
E
E
E
Sample locations: E - Effluent
Flow shall be limited to intermittent discharges of 24 hours or less, twice per month. Flow shall be monitored continuously during each discharge.
Flow shall be released in such a way that erosion is minimized and no discharge of sediments that may have collected in the bottom of tanks is
released.
Acute Toxicity (Fathead Minnow) P/F at 90%; February, May, August, November, See Part III, Condition H.
BTEX parameters should be monitored using an EPA -approved method to a detection level of 1 ppb. The monitoring for above listed parameters should
coincide with all whole -effluent toxicity monitoring.
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be monitored 2/month at the effluent by grab samples.
There shall be no discharge of floating solids or visible foam in other than trace amounts.

receiving stream indicate that detrimental effects may be expected in the receiving stream as a result
of this discharge.
H. ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QRTRLY)
The permittee shall conduct acute toxicity tests on a quarterly basis using protocols defined in the
North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute
Toxicity In A Single Effluent Concentration." The monitoring shall be performed as a Fathead
Minnow (Pimephales promelas) 24 hour static test, using effluent collected as a single grab
sample. The effluent concentration at which there may be at no time significant acute mortality is
90% (defined as treatment two in the North Carolina procedure document). Effluent samples for
self -monitoring purposes must be obtained during representative effluent discharge below all waste
treatment. The first test will be performed after thirty days from the effective date of this permit
during the months of February, May, August, and November.
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter
code TGE6C. Additionally, DEM Form AT-2 (original) is to be sent to the following address:
Attention:
Environmental Sciences Branch
North Carolina Division of
Environmental Management
4401 Reedy Creek Road
Raleigh, N.C. 27607
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 single quarterly monitoring indicate a failure to meet specified limits, then monthly
monitoring will begin immediately until such time that a single test is passed. Upon passing, this
monthly test requirement will revert to quarterly in the months specified above.
Should any test data from either these monitoring requirements or tests performed by the North
Carolina Division of Environmental Management 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 retesting(within 30 days of initial monitoring event). Failure to submit
suitable test results will constitute noncompliance with monitoring requirements.
I. The daily average limitations for oil and grease stated in Part I, A. shall be deemed to have been
exceeded if either:
a. the arithmetic average of the analyses of all representative samples taken during a calendar
month by the permittee in accordance with monitoring requirements set forth above exceeds 30
mg/1, or
b. the analyses of any two representative grab samples taken by the State at least six hours apart
during any consecutive thirty day period each individually exceeds 30.0 mg/l.
Each sample taken by either the permittee or the State shall be presumed to be representative.

Page 1
Note for Dave Goodrich
From: Matt Mathews
Date: Tue, Jan 2, 1996 10:16 AM
Subject: Shell Oil
To: Dave Goodrich
I've talked with Larry about this and he is agreeable to a Pass/fail @ 90% (quarterly) given
the discharge conditions we discussed (twice per month at 0.5 mgd).
He suggested bmps ONLY if you all wanted to include them.

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DIVISION OF ENVIRONMENTAL MANAGEMENT
December 7, 1995
MEMORANDUM
To: Rex Gleason
Thin: Larry Ausley
Matt Matthews r`''"
From: Kevin Bowden
RE: Pilot Test Results and Toxicity Reduction Evaluation - November 1995
Shell Oil Products Company
NPDES Permit No. NC0046892 - Outfall 2
Mecklenburg County
This office has completed a review of the subject Toxicity Reduction Evaluation submitted by the
company's contractor Coggin and Fairchild, Environmental Consultants, dated November 1995. This report
provides results of small scale and full scale pilot tests conducted on the effluent and proposes several treatment
technologies which would enable the facility to achieve compliance with its current chronic toxicity limitation of
90%. The report is divided into seven sections including: Introduction, Treatment Technologies, Small Scale
Pilot Test Results, Conclusions and Recommendations, Full Scale Pilot Testing, Full Scale Test Results, and a
Toxicity Evaluation Summary.
Section 1.0 briefly describes the main objectives of the pilot testing procedures which included
identification of the cause(s) of chronic toxicity and development of system design parameters. The current
groundwater remediation system consists of a 1,000 gallon oil/water separator, bag filters, and liquid phase
granular activated carbon (GAC) The system has an average flow rate of 20 gpm with a maximum flow of 40
gpm. Acute toxicity testing is required by the NPDES Permit for the stormwater discharge from Outfall 001
while a chronic toxicity testing requirement is required for the groundwater remediation discharge from outfall
002. A Toxicity Identification Evaluation performed by the Advent Group (Advent) suggested naturally
occurring manganese and iron to be potential contributors to chronic toxicity. Manganese concentrations in the
effluent typically ranged from 5.5 mg/l to 6.0 mg/1. Bench scale studies conducted by Advent to determine a
treatment technology for manganese removal identified greensand filtration as the technology best suited for this
site. Additional treatment technologies addressing inorganic metals removal were also investigated and included:
aeration, sodium hydroxide addition, potassium permanganate addition, and greensand filtration. Table 1
presents the individual small scale treatment processes while Table 2 presents a summary of toxicity test results,
Ceriodaphnia reproduction numbers, and results for several parameters (metals and hardness) analyzed during the
pilot testing procedures.
The existing groundwater remediation system was operated for approximately two days prior to initiating
pilot testing to allow the system to reach steady state conditions. Effluent used for testing in the various pilot
Systems was treated by the existing groundwater remediation system (oil/water separator. bag filters. and GAC)
prior to pilot testing. All the pilot systems were aerated via an Ejector Systems five tray low profile air stripper
with the exception of greensand filter. Effluent samples from each pilot test were shipped to EnviroSystems,
Inc., Hampton, New Hampshire for toxicity testing and metals analysis.
Section 3.0 addresses results and observations from the small scale pilot tests.
3.1 Aeration - Influent pH to the air stripper ranged from 6.6 to 7.0 s.u. and effluent pH
ranged from 8.6 to 8.7 s.u. Field testing showed a 50% reduction between influent and effluent
manganese concentrations (5.0-6.0 mg/1) and(3.0 mg/1), respectively. Water hardness determinations
prior to aeration measured 305 mg/I and 290 mg/1 after aeration. In addition, a light brown floc was
observed in the floc and sedimentation tank. This treatment is identified as SS1 in Tables 1 and 2. No
acute or chronic toxicity was observed in this treatment.

Page 2
Shell Oil Company Pilot Test Results and THE - November 1995
December 7, 1995
4 3.2 Sodium Hydroxide Addition - Influent to the floc tank after aeration was between 8.6 and
8.7 s.u. The pH in the floc tank was adjusted with 0.05N NaOH to between 9.5 and.9.6 s.u. Field
testing showed manganese concentrations were between 0.5 mg/1 and 1.0 mg/1 indicating a significant
reduction in manganese concentrations. Water hardness concentrations decreased slightly from 305
mg/I to approximately 200 mg/1. A well formed reddish brown floc was noted in the floc tank. A
small decrease in pH to 9.2 s.u. was observed and the facility attributes the decrease to either
"continuing reactions with the hydroxide or reabsorption of carbon dioxide from the air." Test results
from sodium hydroxide addition at pH 9.5 and subsequent neutralization with either HCl or HNO3 are
identified as samples SS2, SS3, and SS4 in Tables 1 and 2. Sample SSS was manipulated to pH 10.5
and neutralized with HNO3. No acute toxicity was noted in the sodium hydroxide treatments. A
"sublethal response" was noted for the SS5 treatment; the remaining sodium hydroxide treatments
produced NOECs > 100%.
4 3.3 Permanganate Addition - Addition of 6.0 mg/1 KMn04 to the floc tank influent did not
significantly affect the pH and did not reduce manganese concentrations. The KMn04 feed rate was
increased to 12.0 mg/1 and field tests showed reductions in manganese concentrations from 5.0-6.0
mg/1 to 3.0 mil. Water hardness concentrations decreased slightly from 305 mg/1 to 290 mg/l. This
sample is identified as SS6 in Tables 1 and 2. No acute or chronic toxicity was observed in this
treatment.
3.4 Greensand filter - Influent pH (unaerated) to the filter measured 6.6-6.7 s.u. Initial
influent manganese concentrations measured 6.0 mg/1. After 24 hours of operation the system was
backflushed and effluent manganese concentrations measured 3.25 mg/1. This sample is identified as
SS7 in Tables 1 and 2. No acute or chronic toxicity was observed in this treatment.
kW Way To GET 1 to of: ZACIc.1vilV b�TL`R-
In Section 4.0 the report indicates that all the treatment technologies evaluated for this site produced
favorable acute and chronic toxicity testing results. Cost comparison of the technologies indicates that aeration
only or aeration followed by pH adjustment would be most practicable. Greensand filtration has operating
requirements which would limit its effectiveness at this site including production of a wastestream comprising
approximately 10% of the original influent flow which would require treatment.
Section 5.0 discusses full scale pilot testing and methodology. Full scale testing was conducted from
September 1 through September 25, 1995. An existing containment dike was used as the sedimentation tank.
The full scale pilot test was conducted with (1) aeration only and (2) sodium hydroxide addition with final nitric
acid pH adjustment. Schematic diagrams of the full scale pilot tests are depicted as Figures 7 and 8.
Section 6.0 presents full scale test results.
4 6.1 Aeration Only - The air stripper influent pH varied between 6.6 and 6.7 s.u. The pH of the
effluent from the air stripper ranged between 8.5 and 8.6 s.u_ Air stripper influent manganese
concentrations measured between 5.0 mg/1 and 7.0 mg/1 while field testing of the effluent from the
sedimentation tank ranged from 3.67 mg/1 to 4.18 mg/1. This represents an approximate 30%
reduction in manganese concentrations which corresponds with results obtained in bench scale pilot
testing. Full scale test samples are identified as FS6, FS7, FS8, and FS9 in Tables 3 and 4. Chronic
test results for all treatments (aeration only) were reported as 'Tail".
4 6.2 Aeration with Sodium Hydroxide Addition - In this full scale test the wastestream was air
stripped and sodium hydroxide was added to the influent of the floc tank to increase the pH to
approximately 9.3 s.u. Influent manganese concentrations ranged from 5.0-7.0 mg/1 and effluent
manganese concentrations ranged from 1.0 to 1.5 mg/1. These samples are identified in Tables 3 and 4
as FS 1, FS2, FS3, FS4 and FSS.
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Page 3
Shell Oil Company Pilot Test Results and TRE - November 1995
December 7, 1995
Samples FS1, FS2, and FS3 were collected from the clarifier discharge during normal operating
conditions. No acute or chronic toxicity was observed in samples FS1, FS2, or FS3. It is unclear
from the information presented on page 10 whether sample FS4 (composite) was collected under
normal operating conditions or whether it was collected during a time which the system was operated
under varying conditions. Sample FS5 (grab) apparently was collected under varying conditions.
Although no acute toxicity was observed in samples FS4 or FS5, both samples exhibited chronic
toxicity.
In Section 7.0 the report presents the results (Tables 5-12) of neonate reproduction rate versus total metal
concentration for iron, zinc, nickel, manganese, copper, magnesium, calcium, and total hardness. Information is
presented in Tables 5-12 based upon an observed threshold concentration below which a toxicity sample would
be expected to pass and above which a sample would be expected to fail. The report suggests the data shows a
"strong correlation" between juvenile production and manganese, hardness, magnesium, iron, and zinc
concentrations. The report also states, "Below a threshold concentration, the juvenile production rate was not
significantly different than the control juvenile production rate." This correlation does not appear as strong for
nickel and cadmium. It is suggested that this effect may be due to toxicity associated with the individual metals or
to a combined effect with other constituents within the sample. A statement is made in this section that, "There
appears to be no correlation between aluminum and chronic toxicity (Table 6) in the samples collected." While
we agree with this statement we believe the correct citation should be Table 4 and not Table 6 as indicated.
In summary, the company should be congratulated on its efforts to commit the necessary resources to
investigate the cause(s) of toxicity and to propose a treatment alternative. The TIE/TRE work conducted to date
has provided the facility with a good deal of chemical analysis and acute/chronic toxicity testing data. The facility
has investigated several treatment technologies which have the potential to enable outfall 002 to achieve
compliance with a 90% chronic limitation. Due to cost/operational considerations, the facility has chosen aeration
with sodium hydroxide addition as the technology best suited for this site. Shell Oil Company and its toxicity
consultant have requested a meeting with Divisional staff to present the TRE results and discuss other pertinent
issues involving this groundwater remediation project. The meeting has been tentatively scheduled for December
11 at 1:00 pm at the Water Quality Laboratory. We welcome representation from the Mooresville Regional Office
at this meeting and look forward to interacting with company representatives and hearing additional details on the
proposed treatment technology.
If you have any questions, please feel free to contact me at [phone].
cc: John Lesley -Mooresville Regional Office
Dave Goodrich -Permits and Engineering
Phil Bethea
Aquatic Survey and Toxicology Unit Files
Central Files

State of North Carolina ,
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
Mr. H. James Sewell
Shell Oil Company
1415 West 22nd Street
Oak Brook, IL 60522-9008
74;741:1A
EDIEF-INI I
July 24, 1995
Subject: Enforcement Action
Shell Oil Company
Case No: LV 95-04
NPDES Permit No. NC0046892
Mecklenburg County
Dear Mr. Sewell:
In a letter from the Mooresville Regional Office, you received notice that the Division of
Environmental Management was considering an enforcement action against Shell Oil Company for
permit limit violations which occurred from May 1994 through Novemb.r 1994. After reviewing the
enforcement case, I have chosen not to assess civil penalties for these violations at this time. Please be
advised that this letter does not preclude the Division from assessing civil penalties for the noted
violations at a future date. Additional assessments may be levied for violations of the NPDES permit
should they occur.
If you have any questions concerning this matter, please call Linda Forehand at (919) 733-
5083, ext. 526.
cc: Enforcement File
Mooresville Regional Office
Central Files
Sincerely,
Preston oward, Jr., P.
JUL-
O1VI ' , OF r�:�,{ ra; T
Moee11 E Yttic
y�lY j►L'JI J...1
P.Q. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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• 4
Shell Oil Company
1415 West 22nd Street
Oak Brook, Illinois 60522-9008
March 2, 1995
Kevin Bowden
State of North Carolina
Department of Health Environment and Natural Resources
Division Of Environmental Management
Environmental Sciences Branch
4401 Reedy Creek Road
Raleigh, North Carolina 27607
Subject: Shell Oil Company, Charlotte Distribution Terminal
6851 Freedom Drive, Charlotte, NC 28214
NPDES PERMIT # NC0046892/002- TOXICITY IDENTIFICATION EVALUATION
Dear Kevin:
Thank you for your comments concerning our preliminary work plan to determine the cause of effluent
toxicity at the subject location. As we discussed on the phone today several of your comments have been
incorporated into the work plan. The samples for chemical analysis and toxicity testing will be taken
concurrently to establish data correlation. Also, a chronic toxicity test will be run on a sample of ambient
groundwater to establish baseline toxicity.
We do not feel separate toxicity test on the tank condensate/truck loading rack waste stream is necessary
as we do not feel this waste stream has a bearing on the effluent toxicity test failures. This waste stream
was last processed through the treatment system in late October 1994. Our test results for November,
December, January and February have continued to indicate effluent toxicity even though the carbon beds
have been changed and the amount of groundwater treated should have flushed the system many times
over. If we are able to resolve the toxicity issue and revert to quarterly chronic toxicity testing, installation
of a 24 hour composite sampler is not cost effective. Last summer we had our laboratory review our
manual sampling methods to ensure a representative sample is collected.
Your letter mentioned that we questioned the requirement for chronic toxicity versus acute toxicity testing
at outfall 002. Our question deals more with consistency of regulating NPDES discharges in the Paw
Creek terminal complex. In my efforts to resolve our chronic toxicity issue, I found that apparently the
chronic toxicity test requirement applies only to Shell outfall 002. Shell feels there are similar or identical
discharges in the area, some of which were p_e itted x.,K issued—thal aruaQUegItied
perform this test. Our question is whether or not our inl nt was g, rP ,.m__ S Can bemodifi fw-ther
characterized to eliminate the chronic toxici test r uirement. Our other question comungd stream,
classifications in the area:. ur We, eve a _ t�_, ooterminal w.rrwr��nr+as denied covers under North Carolina General
roseo��r� ��rrrr,. �� err��w ori+��r.i siwr.e�'•
NPDES Permit # NCG510000 tr did not
carry a stream classification that is consistent with the x. _ Thile this issue is relativel m
now we still feel that the General Permit was either erroneously applied to other terminal___s in the Pa
Creek area or the streams in the area are incorrectly clan ifis ed.
mf502281 page 1 of 2
RECEIVED
M4R 0 31995
ENVIRONMENTAL

Also as we discussed today the first round of samples for our TIE phase II will be completed this week
We would like to schedule a conference call with you next week to discuss the results of this testing and
any resultant changes to our work plan. I suggest we set up the call for Wednesday, March 8, 1995 at 2:00
PM EST. Please let me know if this is acceptable to you. If you have question or need more information
concerning these matters prior to the conference call, please contact me at 708-572-5628.
Sincerely,
C. Matthew Foster
Environmental Engineer
.cc A.H. Brooks
G.D. Mazar
C.O. Gast
T..J. Franceschini
K.C. Gillmore
W.T. Tang
SFI: WP CHA 02
Handex of the Carolinas
3600-G Wood Park Blvd.
Charlotte, NC 28206
John Lesley
State of North Carolina
Department of Environment, Health and Natural Resources
919 North Main Street
Mooresville, NC 28115
mf502281 page 2 of 2

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard,Jr., P.E., Director
February 17, 1995
Mr. Matt Foster
Shell Oil Company
1415 West 22nd Street
Oak Brook, IL 60522-9008
Subject: Toxicity Identification Evaluation
NPDES Permit No. NC0046892/002
Shell Oil Company Ground water Remediation Treatment System
Mecklenburg County
Dear Mr. Foster:
Susan Carroll and I appreciated the opportunity to meet with you, Robbie Ettinger, and staff from
the Mooresville Regional Office on February 9, 1995, concerning the facility's efforts to address toxicity
noncompliance associated with outfall 002 (groundwater remediation treatment s} _item) currently in use at
the Paw Creek Terminal. Our files indicate that Phase I Toxicity Identification Evaluation results were
transmitted by cover letter dared December 12, 1994, from you to the Environmental Sciences Branch.
This letter also requested a meeting to discuss Toxicity Identification Evaluation findings and possible
treatment options. As you know, this office did not prepare a formal written response to the initial Phase
I TIE findings as we were anticipating a meeting during January to discuss the fadlity's progress to date.
It would be appropriate to briefly discuss Phase I TIE investigations which were begun on an
effluent sample collected August 22-23, 1994. Your contract laboratory assistir in these efforts, ETT
Environmental, conducted several effluent manipulation tests to characterize potential toxicants. Tests
included pH adjustment, filtered/pH adjustment, aeration/pH adjustment, Solid Phase Extraction with pH
adjustment, Sodium Thiosulfate addition, EDTA chelation, and graduated pH nesting. Results of the
characterization tests showed reduced toxicity in three manipulations: pH 11 adjustment, filtered pH 11
adjustment and EDTA chelation. In the Discussion section (5.0), the report indicates a color change and
the formation of a precipitate upon addition of sodium hydroxide to increase the pH to 11. The report
also suggests the likelihood that toxicity is being contributed to, if not caused solely by one or more
metals. Iron was suggested as being a primary toxicant and recommendations were offered which
included spiking the effluent with iron and conducting an effluent EDTA chronic test.
Correspondence from ETT to you dated October 14, 1994, highlighted several metals of concern
which were detected at or above the EPA water quality criteria for those parameters. Targeted metals
included iron detected at a concentration of 2960 µg/1 and manganese detected at _ concentration of 3990
nil. A recommendation from ETT was made to conduct additional acute toxicity testing with iron and
manganese to confirm if concentrations are present which may account for toxicity in the effluent.
Upon our arrival in Mooresville on the morning of 9 February, Ms. Carroll and I were handed
copies of a work plan proposal entitled, "Work Plan for Resolving the Chronic Toxicity of the Treated
Effluent at the Charlotte Distribution Terminal." At that time we leamed the facility conducted a chronic
test in late December and the result was reported as "Fail". Iron and manganese concentrations measured
at the time the toxicity test was performed were <0.01 mg/l and 0.05 mg/1, respectively. We would agree
that the reported concentrations of iron and manganese should not cause a resultant increase in toxicity.
Step I of the plan proposes additional chemical characterizations to be performed. Step If addresses those
manipulations effective in reducing effluent toxicity and also specifies the use o;: chronic testing versus
acute testing in this phase of the study. Step III actions include spiking the dilution water with those
toxicants identified in Step 1Z Step IV actions include modification of the treatment system to remove or
reduce toxicity to acceptable levels. Step V actions involve testing a treated effluent sample after
modifications are complete to determine if the modifications allow the facility to a.hieve compliance with
the 90% chronic toxicity permit limitation.
Environmental Sciences Branch • 4401 Reedy Creek Road • Raleigh, North Caroina 27607
Telephone [phone] FAX r 733-9959
An Equal Opportunity Affirmative Acibn Employer 50% recycled/10% pow consumer paper

Page 2
Shell Oil Company
February 17, 1995
We have had an opportunity to study the work plan in greater detail and offer the following
comments and recommendations. We would encourage all chemical analyses be conducted concurrently
with toxicity testing to establish data con -elation among the analyses and specific toxicity sampling events.; -
Apparently outfall 002 is configured such that tank condensate water and truck loading rack water is
collected and sent to the oil -water separator. As expected, this discharge is not continuous; whereas, the
treated groundwater discharge is continuous. You may consider collecting a sample from the tank
condensate/truck loading rack wastestream to determine the level of toxicity present, if any. You may
also consider performing a toxicity test on an ambient groundwater sample. Step IV of the proposed
work plan discusses modification to the treatment system once the root cause for toxicity is identified and
confirmed. We would encourage, once the causative toxicants are identified, a bench scale study be
conducted to determine if proposed treatment modifications will assist in toxicity reduction. You also
mentioned during our meeting that the facility does not have a composite sampler. We would suggest that
you acquire a 24 hour composite sampler for future analyses at the Paw Creek Terminal to eliminate any
variables possibly associated with sample collection. It is extremely important that wastewater treatment
efficiency be maximized during this process and that any changes in the system are documented
accordingly.
The sample progress report containing analytical data on an effluent sample collected 3 February
showed elevated concentrations of certain metals in excess of the action levels established for those
parameters. Copper was detected at 20 14/1(action level - 7 µg/1) and zinc at 100 1.tg/1(action level - 50
µg/1. Manganese was also detected at 6340 ug/1(water quality standard - 200 µg/1 in WS-I through WS-
V waters).
The role of the Aquatic Survey and Toxicology Unit during this process will be to provide
comments on the logic and direction of toxicity reduction and identification efforts taken. As discussed,
we cannot position ourselves to direct those activities but are willing to assist you by reviewing plans and
providing appropriate comment(s).
Another question which arose at the beginning of the meeting centered around the requirement for
the Paw Creek Terminal to conduct chronic toxicity testing versus acute testing at outfall 002. We have
reviewed the facility file information and the chronic toxicity testing requirement as it appears in the
NPDES Permit is appropriate.
In summary, we are encouraged by the facility's efforts to address toxicity noncompliance and to
begin toxicity identification work. Please feel free to contact me at [phone] or Mr. John Lesley in
our Mooresville Regional Office at [phone] should you have any questions concerning this
correspondence.
Sincerely,
/6, etau,a-ii
M. Kevin Bowden
Environmental Biologist
cc: Steve Tedder
John Lesley -Mooresville Regional Office
Aquatic Toxicology Unit Files -
Central Files

Shell Oil Company
RECEIVED
FEB 2119951
AIRBORNE EXPRESS:' 6949318316 ENVIRONMENTAL SCIENCES
February 10, 1995
B. Keith Overcash, P.E.
State of North Carolina
Department of Environment, Health and Natural Resources
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
Subject: Shell Oil Company, Charlotte Distribution Terminal
6851 Freedom Drive, Charlotte, NC 28214
NPDES Permit No. NC0046892
Dear Mr. Overcash:
1415 West 22nd Street
Oak Brook, Illinois 60522-9008
Prior to receiving your attached letter of February 6, 1995 I had scheduled a February 9, 1995
meeting with John Lesley and Rex Gleason concerning the toxicity tests under the subject permit.
Also in attendance were Robbie Ettinger with Shell, Rob Krebs from your office, Kevin Bowden
from the Water Quality Section in Raleigh and others. During the course of the meeting we
explained Shell's position concerning the chronic toxicity test results and we described the latest
phase in our continuing efforts to determine the cause of toxicity in the effluent stream. The
discussions below summarize our position in this matter for your consideration.
1) Shell has been and continues to be proactive in investigating the chronic toxicity issue at
this site. The attached letter dated June 28, 1994 shows that our investigation began promptly
after the initial chronic toxicity failure. Early in the process our efforts concentrated on ensuring
the treatment method or the sampling method was not the cause. We tested for dissolved oxygen
in the effluent and we ensured samples were taken using fresh carbon. We then contacted our lab
to ensure nothing in the testing process could be the cause. In July 1994 we met with our contract
lab to discuss ways to resolve the toxicity issue and decided to conduct a Toxicity Identification
Evaluation (TIE) during the August 1994 sampling event. The preliminary results from the
August 1994 TIE indicated toxicity was most likely caused by iron. Subsequent analysis of the
effluent water did not confirm iron at toxic levels and we determined that further TIE is required.
The results of the TIE and other information concerning this site were forwarded to you and John
Ausley, see attached letter dated December 12, 1994. Our work plan, detailing further TIE, was
sent to your Mr. Lesley prior to the February 9, 1995 meeting for distribution and review and
ideas for improvements to the plan were solicited from the meeting participants. Shell will
implement the plan as soon as possible and the results of this second phase TIE will be available
by March 24, 1995.
mf502091 page 1 of 4

2) Based on the initial TIE results and analysis of additional effluent samples taken on
February 3, 1995 we now believe that the cause of the effluent toxicity is possibly naturally
occurring in the groundwater. The water table elevations for the site indicate the discharge stream
is fed by the groundwater. In light of this we feel thatAl_minating>;outeffluent ill-togetherwilP
have no Affect on the ac tual stream toxicity: The attached Shell memo dated February 16, 1995
presents new information from our Westhollow Technology Center, summarizes the results of our
investigations to date and details our work plan for further TIE. Some of the information in this
memo has been developed since the February 9, 1995 meeting. We believe that elimination of the
effluent is not the best solution because turning the site's water treatment system off to eliminate
the discharge will not allow representative samples for further TIE and could be detrimental to the
site remediation effort. In a discussion with Mr. Bowden on February 14, 1995, he shared these
concerns and indicated that in a case like this chronic toxicity test failures-,vouldzbe.expected
during the investigation phase.
In view of the foregoing, Shell believes that the chronic toxicity failure is most likely caused by
concentrations of naturally occurring elements in the groundwater unrelated to our treatment
system operation and should therefore" not be a violationattributable to Shell pursuant to North
h
Caarolina�General.Statute 143-215.1 (a) (6). Further, we ask that you reconsider pursuing any
potential^ enforcement action while our good faith efforts to investigate the cause of toxicity are in
progress and while you evaluate new information that we are providing. Pending resolution of this
matter we plan to discontinue all discharges from outfall 002 as of February 28, 1995. Any treated
water generated for TIE sampling in March will be stored in an existing empty tank
until proper disposal is arranged.
3) As indicated in the attached letter dated March 14, 1994 Shell believes that NPDES
discharge permits for the Paw Creek terminal area may be inconsistent Originally we designed the
treatment system using an air stripper as the primary treatment method and we applied for the
general NPDES permit NCG5510000. Our general NPDES permit application was rejected, we
were told, because the intermittent stream into which our effluent discharges has a different
classification than is called for in the general permit. At that time we pointed out that other
companies covered under the general permit have discharges into streams with the same
classification. We were told in telephone conversations that these permits were issued in error and
that actions would be taken to correct this inconsistency. As explained at the February 9, 1995
meeting we do not believe this situation has been resolved.
Another apparent inconsistency came to light during my efforts to resolve the chronic
toxicity issue. I contacted several other oil companies to determine if they were having similar
problems and found that apparently Shell is the only company required to perform chronic toxicity
tests on the NPDES effluent. At the February 9, 1995 meeting we asked if there was something
different about our influent stream that would justify this. Although no one could answer for
certain, Mr. Gleason and Mr. Bowden felt the presence of tank condensate water and contact
mf502091 page 2 of 4

water from the Ioading rack in our influent stream is'the most likely reason for this additional test
requirement. We pointed out that these influent waters are held in storage tanks and treated in
batches and that few if any of the chronic toxicity samples were taken immediately after these
influent waters were treated. We suggested to Mr. Gleason that if the chronic toxicity test
requirement can be eliminated by removing these influent waters from the permit, this can be done
immediately. In fact, the last time these influent waters were treated was October 26, 1994. Since
the treatment times and sample dates do not coincide, we do not, however, believe these influent
waters have any bearing on the chronic toxicity test results. Additionally, we tried to clarify that
we do not believe our effluent water nor the discharge stream differ from those of other
companies that are not required to perform chronic toxicity tests.
In light of new information we have provided we respectfully request a conference call or another
meeting in Mooresville as soon as possible. If you have more immediate questions or require
further information concerning this matter I can be reached at the address listed above or at
708-572-5628.
Yours truly,
C. Matthew Foster
Environmental Engineer
.cc A.H. Brooks
G.D. Mazar
C.O. Gast
K.C. Gillmore
T.E. Green
T.J. Franceschini
E.H. Hsu
W.T. Tang
Kevin Bowden
Environmental Biologist
Division of Environmental Management
Water Quality Section
4401 Reedy Creek Road
Raleigh, NC 27607
mf502091 page 3 of 4

Rob Krebs
State of North Carolina
Department of Environment, Health and Natural Resources
Mooresville Regional Office
919 North Main Street
Mooresville, North Carolina 28115
mf502091 page 4 of 4

/. ,e(i/ r12 y e s fry/
Shell Oil Company
CERTIFIED MAIL: P 303 226 872
March 14, 1994
State of North Carolina
Department of Environment, Health
and Natural Resources
Division of Environmental Management
Attention: Randy Kepler
P.O. Box 29535
Raleigh, NC 27626-0535
1415 West 22nd Street
Oak Brook, Illinois 60522-9008
Subject: Shell Oil Company, Charlotte Distribution Plant
6851 Freedom Drive, Charlotte, NC 28214, Mecklenburg County
NPDES Permit 11NC0046892
Dear Mr. Kepler:
We have decided not to seek resolution to our concerns about the sampling frequencies and
discharge limits listed in the subject permit through the adjudicative hearing process described
in your letter of February 28, 1994. We would, however, like to reiterate the concern that
discharges into receiving waters in the Paw Creek area are not regulated consistently. It
appears that some of the groundwater remediation systems in this area were allowed coverage
under general NPDES permit #NCG510000. We feel that all of the surface streams in the Paw
Creek area should carry the same WS-IV classification and have the same discharge limits as
the "unnamed tributary to Long Creek in the Catawba River Basin" listed as the receiving
waterin the subject permit. During your March 11, 1994 telephone conversation with Shell's
Matt Foster you indicated your office is currently attempting to Ater the general permit to
include discharge limits for class WS-IV streams. We understanc that the benzene discharge
limits listed in the general permit are not suitable for some of the ground water remediation
system receiving waters in the Paw Creek area that were granted inclusion under the general
permit. We would like the opportunity to revisit this issue if charges to the general permit are
not completed in a timely manner.
If you have questions or require further information concerning this matter, please contact
Matt Foster at 708-572-5628.
/4&
C.O. Gast
Manager, Environmental and Technical
m f407301