NC0032891_Permit Issuance_20010730

AI TA
NCDENR
Mr. David Ysebaert
Philips Pipe Line Company
3-B10 Adams Building
Bartlesville, Oklahoma 74004
Dear hir. Ysebaert
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
July 30, 2001
Subject Issuance of NPDES Permit NC0032891
Charlotte Terminal
1•fecklenburg County
Division of Water Quality (Division) personnel have reviewed and approved your application for renewal of the subject
permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the requirements of
North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental
Protection Agency dated May 9, 1994 (or as subsequently amended). Please note the following changes from your draft permit, most
of which are the result of the Paw Creek hearing officer's recommendations:
• pH monitoring and limits have been removed from your permit. This vas an error made in all of the Paw Creek draft
permits. The pH requirement was eliminated in the previous permitting cycle and should not have been included in the 2001
permits.
• The MTBE limit of 11.6 µg/L has been removed from the permit. As per the hearing officer's recommendations, a peer -
reviewed criterion for MTBE does not exist and will not be included as part of the permitting strategy for the Paw Creek permits.
It is anticipated that a criterion will be in place when this permit is next renewed. In addition to monthly monitoring of
MTBE, please see Part A.(3.) for some additional requirements related to MTBE.
• The monthly monitoring requirement for naphthalene has been deleted. Semi-annual monitoring using EPA Method
625 replaces it. As per the hearing officer's report, 625 is the best method for detecting naphthalene and other middle distillate
compounds and is therefore a more appropriate monitoring requirement.. If your facility collects eight to ten samples in which
none of the 625 compounds are detected, you may submit a request to the Division that this sampling requirement be eliminated.
• Flow monitoring frequency has been changed from monthly to episodic. As per a request by the Mooresville Regional
Office, flow must be measured with each discharge event.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you, you have
the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter. This request must be in
the form of a written petition, conforming to Chapter 150B of the North Carolina General Statutes, and filed with the Office of
Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-6714). Unless such demand is made, this decision
shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require modification or
revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land Resources, the Coastal Area Management Act
_ _ or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Natalie Sierra at telephone number [phone],
extension 551.
cc: Mooresville Regional Office/Water Quality Section
NPDES Unit
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Department of Environmental Protection
Central Files
N. C. Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Phone: [phone]
fax: [phone]
DENR Customer Service Center. 1 800 623-7748

Permit NC0032891
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,
Philips Pipe Line Company
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte Terminal
502 Tom Sadler Road
Paw Creek
Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Gum Branch in the Catawba River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III and IV hereof.
This permit shall become effective September 1, 2001.
This permit and authorization to discharge shall expire at midnight on June 30, 2005.
Signed this day July 30, 2001.
Kerr T.
Divisio
By Au
001Viadite YAP
firector
of ter Quality
on of the Environmental Management Commission

o•
Permit NC0032891
•
SUPPLEMENT TO PERMIT COVER SHEET
Philips Pipe Line Company
is hereby authorized to:
1. continue to discharge stormwater from secondary containment areas through outfalls 001 and 002
located at the Charlotte Terminal, 502 Tom Sadler Road, Charlotte, Mecklenburg County, and
2. discharge from said treatment facility at the specified locations (see attached map) into an unnamed
tributary to Gum Branch, a waterbody classified as WS-IV waters within the Catawba River Basin.

Latitude (001) : 35°17'07"
Longitude (001) : 80°56'23"
Latitude (002) : 35°17'08"
Longitude(002) : 80°56'18"
Quad # F15SW
Receiving Stream: UT to Gum Branch
Stream Class: WS-IV
Subbasin: 30834
NC0032891
Philips Pipe Line Company
Charlotte Terminal
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NC0032891 - Phillips PipeLine Company
Charlotte Terminal
Facility/Site Plan

Permit NC003289 1
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT r - -
, "'r L1 1TS
a,'svt, y:, MON!TORINGREQUIREIVIENTS ` . x
CHARACTERISTIC$
• �1 i...%'A.;R+t+ w"'d'�"• .
': .:.
P Monthly
As rag
Daily �
a
.Maximum
..
Measurement?
F r,: ��.f
tlM <a d
Frequency °
.., Sam le v
fps
_ �.
TYP.�
*Sample Locations
_
44 a, , ' '
r �'"i h''t.ecrv> "..S 9,.c
Flowl
Episodic
1
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Oil and Grease2
Monthly
Grab
Effluent
Turbidity3
50 N fU
Monthly
Grab
Effluent
Phenol
100 µg/L
Monthly
Grab
Effluent
Benzene
1.19 µg/L
Monthly
Grab
Effluent
Toluene
Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
Xylene
Monthly
Grab
Effluent
EPA Method 625
Semi -Annually
Grab
Effluent
MTBE4
Monthly
Grab
Effluent
Acute Toxicity5
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 at each discharge event in one of four
ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude built -upon area
(best method for facilities with large runoff -collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
3. Turbidity — Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving stream
background turbidity exceeds 50 NTU, effluent shall not cause this background value to increase.
4. MTBE — Please see Part A.(4.) for additional requirements pertaining to MTBE.
5. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(3.)].
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 1.1g/1.

Permit NC0032891
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 from Outfall 002. Such discharges shall be limited and monitored by the Permittee as
specified below:
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C ' �,CERISTICS
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Monthlyx
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. , TYp
Flow'
Episodic
1
Effluent
Total Suspended Solids
45.0 mg/L
Monthly
Grab
Effluent
Oil and Grease2
Monthly
Grab
Effluent
Turbidity3
50 NTU
Monthly
Grab
Effluent
Phenol
64 µg/L
Monthly
Grab
Effluent
Benzene
1.19 µg/L
Monthly
Grab
Effluent
Toluene
Monthly
Grab
Effluent
Ethyl Benzene
Monthly
Grab
Effluent
Xylene
Monthly
Grab
Effluent
Naphthalene
Monthly
Grab
Effluent
MTBE4
Monthly
Grab
Effluent
Acute Toxicity5
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 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; exclude built -upon
area (best method for facilities with large runoff -collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
3. Turbidity — Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving
stream background turbidity exceeds 50 NTU, effluent shall not cause this background value to
increase.
4. MTBE — Please see Part A.(4.) for additional requirements pertaining to MTBE.
5. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(3.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct -discharge of tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 1.19 µg/1 and toluene concentration is less than 11 µg/1.

Permit NC0032891
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 NC0032891
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
3. By the time of the next permit renewal, it is anticipated that surface water criterion for MTBE will be
established. This criterion will be used in conjunction with the facility's effluent MTBE data to perform
a reasonable potential analysis (RPA). The RPA will determine whether effluent from a facility has the
potential to exceed a water quality standard or criterion, thereby requiring

Mecklenbu
TTIVIE
NU r ice VY rusQ.Jc HEARING
TIBE TO BE HELD BY
THE NORTH CAROUNA £NVIRONhf ENTALMANAGBAEffTCOMMISSION
asweria
S SUBJECT: A public hearing has been scheduled Concerning the proposed renewal and Issuance of
the following NPDES Pemhits:
- Permit number NC0021962 to CITGO Petroleum Corporation fce the Paw Creek Terminal located in
Charlotte, N.C. Charlotte (Mecklenburg County) for the discharge of stormwater into an unnamed liutary to Gum
AFFIDIAVIT OF PUBLICA7 Branch,
located Permit number NC0022187(o Motive Enterprises for the Paw Creek Terminal I ted in Charlotte
W'C NORTAROLINA (Mecklenburg County) for the discharge of stormwater and rernetfased groundwater into an unnamed
MECKLENBURG COUNTY
mtributary to Gum Breach.
Beforrenndenigned,eNotaryl th - Permit number NC0032891 to Philips Pipe Line Company for e Charlotte Ter 'nal located in
North Carolina, duly commissioner Chartohe (Mecklenburg County) for the discharge of stormwater Into an unnamed tributary to Gum
law to adiminiater oaths, penonally Branch.
m
nl
Shelby J. COtnn - Permit number NC0074705 to William Terminals Holdings, L.P. Sat the Charlotte/Southern Facilities
Terminal located in Charlotte (Mecklenburg County) for thedischargeof stormwater i o an unnamed
THE Mecklenburg T1MES, a new tributary to Paw Creek.
entered assecend•clus mail in the C - Permit number NC0004723 to Valero. Marketing & Supply Company for the Valero Marketing &
and State„the he/sho is authorizedu located
Supply Facility loted in Charlotte (Mecklenburg County) for the discharge of stormwater into an
statements; that the notice or other k
NOTICE OF PUBLIC 1
TO BE HELD BY THE
ENVIRONMENTAL MANE
•true coplyof which is attached here(
loubrn TIMES on the following cis
Marsh 16, 2001
and ihattlhe said newspaper in whiel
or legal advertisement was pubfohr
every sueth publication, &newspaper
and quali rications of Section 1.597
Carolina and was a qualified newapa
lion I.592 of the General Statutes o
This 16th day of M:
(Signed)
Swom ee and aubscribed b ore
1
16th day of March 20i
unnamed tributary to Paw Creek.
- Permit number NC0005771 to TransMontaigne Terminating, Inc. for the ChadottelPew 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 TransMontagne Terminating. tni. for the Charlotte/Paw Creek Termi-
nal 732 located in Charlotte (Mecklenburg County) for the discharge of stormwater intro an unnamed
tributary to Paw Creek.
- Pemit number NC0031038 to Colonial Pipeline Company for the Charlotte Delivery Facility located
in Charlotte (Mecklenburg County) for the discharge of stormwater into an Unnamed tributary to Gum
Branch.
- Permit number NC0046213 to Marathon Ashland Petroleum, LLC for the Marathon Ashland Petro-
leunm facility located in Charlotte (Mecklenburg County) for the discharge of slormwalerirad an un-
named tributary to Long Creek. ;,; j•:
Notary Publi
ConsolationMConsolation Expires: 7 / 7
S
R
h
re
p
• Permit number NC0046531 to Crown Central Petroleum Company for the Paw Creek Terminal
located in Paw Creek (Mecklenburg County) for the discharge of sterrnwater Into an unnamed tributary
to Gum Branch.
- Pemhil number NC0046892 to Motive Enterprises, LLC for the Charlotte Terminal located In Paw
Creek (Mecklenburg County) for the discharge of stormwater and remodiated groundwater to an
unnamed tributary to Long Creek.
-.Permit number NC0004839 to ExxonMobil Refiring & Supply Company for the Chadolle Terminal
located in Chartolle (Mecklenburg County) for the discharge of stornowate( and remedialed groundwa-
ter to an unnamed tributary to Long Creek.
Permit number NC0005165 to Mt ems Terminals Holdings, L.P. Ibr the Paw Creek Terminal located
n Paw Creek (Mecklenburg County) for the discharge of stamwaler to an unnamed tributary to Long
Creek.
PURPOSE: Each of these facilities has applied for renewal of their NPDES permit for the discharge
Of treated stormwater and/or rerneoialed groundwater into waters of the Catawba River basin. On the
basis of preliminary staff review and application of Arbde 21 of Chapter 143, General Statutes. of North
Carolina. and other lawful standards and regulations, the North Carolina Environment Management
Commission proposes to issue a NPDES permit for each facility subeect to specific pollutant limitations
and special conditions. The Director of the Division of Water Ouakty pursuant to NCGS 143-215.1(c)(3)
and Regulations 15NCAC 2H, Section .0100 has determined that it isin the pudic interest that a meeting
be held to receive all pertinent public comment on whether to issue, modify, or deny the pemrit.
PROCEDURE: The hearing wilt be conducted in the following manner.
1. The Division of Water 'Quality wit present an espianalker of the North Carolina Environment
Management Commission's permihino procedure.
2. The applicant may make an explanation of the action for wtrida each permit is required.
3. Public Comment -Comments, statements, data and otthernfonaation may be submitted in writing
prior to or during the meeting or may be presented oraly at the meeting Persons desiring to speak will
indicate this intent at the time of registration at tie meeting. SO that a#persons desiring to speak may do
so, lengthy statements they be firmted at the discretion of the meeting officer. Oral presentations that
exceed three minutes should be accompanied by three written canes,, which will be filed wish Division
staff at the time of registration.
4. Crass examination of persons presenting testimony wit not be allowed: however. the hearing
officer may ask questions for clarification.
5. The hearing record may be dosed at the conclusion of (Inc. meeting.
WHEN: April 19e a17:00 p.m: -
WHERE: Charlotte -Mecklenburg Government Center
600 East Fourth Street, CH-14 -
Charlotte, North Carolina
INFORMATION: A copy of the draft NPDES pemtit(s) ands reap showwg the location of the discharge(s)
are available by -writing or calling:
Ms. Christie Jackson _
NC Division or WaterQuality/NPDES Unit
1617 Mail Servke 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
treat, Room 925 of the Archdale Building in Raleigh, North Carolina and at the Division's Mooresville
egionaf Office (919 North Main Street in Mooresville, NC). They may be inspected during normal office
ours. Copies of the inforrnabon on file are available upon request and payment of the costs of
production. All such tormnents and requests regarding this matter should make reference to Inc
ermil numbers) listed above,
45i384 Mar 16 .

Permit Requirements for Discharges from Oil as 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.
Page 1 of 8
Version 7/30/01

Permit Requirements for Discharges from Oil 8s 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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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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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
✓
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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Table 2. Compounds detectable by EPA Method 625
PARAMETER
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
1,2,4-Trichlorobenzene
4-Chloro-3-methylphenol
2-Chlorophenol
2,4-Dichlorophenol
2,4-Dimethylphenol
2,4-Dinitrophenol
2-Methyl-4,6-dinitrophenol
2-Nitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol
1
2,4,6-Trichlorophenol
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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).
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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.
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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.
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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:
O
V
N
L
d
It is recommended that the effluent sample location be specified in all the permits.
Circumstances at one facility (at least) can be cited as justification for the
recommendation. The permit description of the water pollution control system (WPCS)
for Colonial Pipeline Co. (NC0031038) includes a retention pond. This pond is also
mentioned in the Fact Sheet. Regardless of the 7Q10, 30Q2, and average flow data, this
pond is actually an impoundment fed by three UT's to Gum Branch. According to the
terminal manager, there is flow in these UT's to Gum Branch 12 months per year. The
effluent from the CITGO (NC0021962) facility is discharged to one of the UT's.
Stormwater runoff from at least one other terminal site may also enter the impoundment.
Effluent samples are collected at the outfall for the impoundment.
As discussed above, in addition to the sample collection location, the Colonial Pipeline
Co. (NC0031038) permit needs to be reviewed to determine if it is appropriate to include
the impoundment of a UT to Gum Branch as a treatment unit (retention pond).
Consistency is needed in specifying source of wastewater to WPCS.
There are four different methods used in the draft permits, as follows:
Source not specified anywhere.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet,
which describes the WPCS and/or specifies outfall.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet that
specifies receiving water.
Source indicated in Part I, Section A(1) of permit (Effluent Limitations and
Monitoring Requirements Sheet).
The writer's preference, in part because several of the facilities have multiple outfalls, is
to indicate sources on both the Supplement to Permit Cover Sheet (in paragraph which
describes the WPCS and/or outfall) and in Part I, Section A(1). An example of the
writer's preference is in the permit for Motiva Enterprises, LLC (NC0046892).

Dave Goodrich
Page Two
April 5, 2001
Flow measurement/reporting frequency is recommended to be episodic (as in permit
Motiva Enterprises, LLC (NC0022187).
For several design reasons, discharge events basically occur on an as -needed basis; a
decision is usually made when there will be a discharge through an outfall. The only
exception may be Outfall 002 included in the permit for ExxonMobil Refining and
Supply (NC0004839), which is for a groundwater remediation system without any flow
retention capability, and, therefore, subject to daily discharges. Since discharge events
are mostly manually precipitated and occur randomly or as -needed, the range of the flow
data at a facility may vary considerably. Flow data seems to have played a large role in
the development of effluent limits (as in reasonable potential analysis for phenols), and
yet historically flow measurement methods and data have been two of the evaluations of
a compliance inspection subject to much scrutiny and criticism. Given the flow
measurement options specified in the permits, the small number of discharge events
probable each month, the importance of flow data, and the possibility of a wide range in
the flow data, it is not unreasonable to expect flow to be measured and reported for each
flow event.
The Turbidity monitoring requirement does not seem to be complete.
The permits, with two exceptions (discussed under the next item), include either a
quarterly monitoring -only requirement or a monthly monitoring requirement with an
effluent limit. It is not understood how the effluent turbidity monitoring requirement
correlates with the relevant footnote in Part I, Section A(1). Should there not also be an
upstream and downstream monitoring requirement. In fact, those facilities with a
monitoring -only requirement need only conduct stream monitoring to determine if
effluent turbidity levels result in stream standard violations.
One of the exceptions mentioned above under the item for Turbidity Monitoring is
Marathon Ashland Petroleum, LLC (NC0046213). Although the permit cover letter
indicates that the permit includes a monthly monitoring requirement and an effluent limit,
Part I, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring -only
requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is
being required because of the near potential for a stream standard violation. The other
exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being
required because none of the previously required monitoring has been conducted.
I 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 r w is r v SrrynoN
APR U 2G1
Non -Discharge Permitting
The Mecklenburg County Department of Environmental Protection (MCDEP) has reviewed the
subject draft permits. As you know. MCDEP has a Memorandum of Agreement with the
Division of Water Quality to conduct inspections of the Paw Creek terminals in order to
determine compliance with the applicable NPDES permits. We offer the following comments
regarding the permits:
General
• Flow Measurement
The flow measurement method by which facilities are allowed to calculate flow based on
the area draining to the outfall, the built -upon area, and total rainfall using the rational
equation is inaccurate in most cases. Most facilities inspected by MCDEP collect
stormwater in earthen secondary containment basins surrounding the above ground
storage tanks (not ponds). The facilities generally hold the stormwater for as long as
possible (several weeks if weather permits) to allow any suspended solids to settle out
and to avoid discharge if possible so that monthly sampling and laboratory analysis does
not have to be performed. Calculating discharge flow by this method is inaccurate
because it does not account for evaporation and ground infiltration during the holding
period.
• Quarterly Turbidity Monitoring
The permits state that "Effluent turbidity shall not cause the receiving stream turbidity to
exceed 50 NTU. If receiving stream background turbidity exceeds 50 NTU, effluent shall
not cause this background value to increase."
PEOPLE • PRIDE • PROGRESS
700 N. Tryon Street • Suite 205 • Charlotte, NC 28202-2236 • (-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 detent. n pond.
• Exxon Mobil Refining and Supply Company - Permit # NC0004839
Outfal1001-
The daily maximum permit limit for benzene is listed as 1.24g/l. The North Carolina
water quality standard for WS-IV waters is 1.19µg/1.
• Marathon Ashland Petroleum, LLC - Permit # NC0D46213
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 71.44g/I and
toluene concentration is less than 1112g/1." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19ug/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,
Rust zzelle
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP

Sent By: ;
919 821 0337;
May-2-01 16:32; Page 2/3
WILLIAM IL WC TIIEnerooN
swim' POUSar
May 2, 2001
NORTH CAROLINA
PETROLEUM
COUNCIL
A DII IEIon of rile Amerf*an Petroleum Institute
SUtFE 2850 • 150 FAYETIEVIL E sr. MALL
RALEIQPI. NC 27601
010/e28-5438 • VAX 010/921-03.19
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 of public
hearings at an. 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 reaffirm the value of
public hearings by calling for a permanent rulemaking process to tighten the MTBE groundwater
steadaatd. So % ' at avoat gst, besainv, vsoimaso f tlwt cooposat. we are now confronted with

Sent By: ; 919 821 0337;
May-2-01 16:32;
Page 3/3
Mr. Rick Shiver
May 2, 2001
Page 2
draft NPDES permits that attempt to install an MTBE limit that is at best controversial and at
worst a circumvention of the EMC.
It is my understanding that MTBE was not an issue for the Department in the NPDES permits
issued five years ago.
To be sure, in the intervening years it has been an issue of increasing attention, study, debate and
speculation, Apparently some individuals have been so moved by the growing debate that hasty
changes in risk calculations and other values have occurred. A few advocates within the
Department who sounded the alarm so vigorously in statements to the EMC in support of an
MTI3F groundwater standard of 70 ppb have now changed their minds! What had been a
certainty one month was abandoned the next in favor of a new calculation — and a new limit
level, So, if public health considerations arc truly moving this fast, if numbers are hastily
abandoned and recalculated, if the science is in such a state of flux, then our commitment to
reasoned public input is all the more appropriate and needed to insure that the calculations of
today are not abandoned tomorrow.
Recommendations
The Council's members accept that an MTBE limit that has been peer -reviewed and duly
considered via the rulenxaking 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 scmi-annual 'monitoring by
each of the terminals will provide the needed representative data to form the basis for future
decision -making.
Sincerely,
William H. Weatherspoon
WHW/jm
c: Ms. Natalie Sierra
gear

SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS
CONTAMINANT
CAS #
"C" & "B" WATERS
(ug/I unless noted
• otherwise)
•
"WS-I" - "WS-V"
WATERS
"SC", "SB", & "SA"
WATERS (ug/I unless
noted otherwise)
SOURCE OF STANDARD
OR CRITERIA
BENZENE
; 71-43-2
71.4
1.19
71.4
15A NCAC 2B .0211-.0222
n-BUTYL BENZENE
104-51-8
36
36
36
ECOTOX 4/98
sec -BUTYL BENZENE
135-98-8
41
41
41
ECOTOX 4/98
CHLOROFORM
67-66-3
470
5.7
470
EPA 4/22/99
ETHYL BENZENE
' 100-41-4
383
524
130
ECOTOX 1/01
IPE
` 108-20-3
19 mg/L
19
330 mg/I
ECOTOX 1/01
ISOPROPYL BENZENE
98-82-8
316
186
4.6 mg/I
ECOTOX 1/01 •
p-ISOPROPYL BENZENE
99-87-6
325
325'
1.1 mg/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])

SOC PRIORITY PROJECT: NO
!' n
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: June 14, 2001
NPDES STAFF REPORT AND RECOMMENDAT
County: Mecklenburg
NPDES Permit No.: NC0032891
MRO No.: 01-30
PART I - GENERAL INFORMATION
1. Facility and Address: Phillips Pipe Line Company
PO Box 66
Paw Creek, NC 28130
2. Date of Investigation: May 24, 2001
3. Report Prepared By: B. Dee Browder, Environ. Engr.I
4. Person Contacted and Telephone Number: E P Floyd, [phone]
DENR-WATER QUALITY
POINT SOURCE BRANCH
5. Directions to Site: From the intersection of Rozzells Ferry Road and Tom Saddler Road
travel north on Tom Sadler Road approximately 0.4 miles. Phillips Pipe Line Company
is located on the right.
6. Discharge Point(s), List for all discharge Points: -
Outfall 001
Latitude: 35 ° 17' 07"
Longitude: 80° 56' 18"
Outfall 002
Latitude: 35 ° 17' 08"
Longitude: 80° 56' 18"
Attach a USGS Map Extract and indicate treatment plant site and discharge point on map.
USGS Quad No.: F 15 SW Mountain Island Lake, NC
7. Site size and expansion area consistent with application: Yes.
8. Topography (relationship to flood plain included): Flat Slopes; none of the facilities
appear to be in the flood plain.

Page 2
9. Location of Nearest Dwelling: None within 500 feet.
10. Receiving Stream or Affected Surface Waters: U.T. to Gum Branch
a. Classification: C
b. River Basin and Subbasin No.: Catawba 030834
c. Describe receiving stream features and pertinent downstream uses: General Class
C uses.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of Wastewater: N/A (See Recommendations)
b. What is the current permitted capacity: N/A (See Recommendations)
c. Actual treatment capacity of current facility (current design capacity): N/A (See
Recommendations)
d. Date(s) and construction activities allowed by previous ATCs issued in the
previous two years: N/A
e. Description of existing or substantially constructed WWT facilities: The existing
facilities discharge stormwater from a secondary containment area through
outfalls 001 and 002 located at this terminal.
f. Description of proposed WWT facilities: N/A
g. Possible toxic impacts to surface waters: There are no toxic impacts expected.
h. Pretreatment Program (POTWs only): Not Needed.
2. Residual handling and utilization/disposal scheme:
a. If residuals are being land applied specify DEM Permit No. N/A.
Residuals Contractor: N/A
Telephone No. N/A
b. Residuals stabilization: PSRP PFRP
c. Landfill: N/A
3. Treatment Plant Classification: Class I (no change from previous rating).
4. SIC Code(s): 5171 Wastewater Code(s): 73
5. MTU Code(s): 53000

Page 3
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? No
2. Special monitoring or limitations (including toxicity) requests: None at this time.
3. Important SOC/JOC or Compliance Schedule dates: N/A
Submission of plans and specifications
Begin Construction
Complete construction
4. Alternative Analysis Evaluation
a. Spray Irrigation: N/A
b. Connect to regional sewer system: N/A
c. Subsurface: N/A
d. Other disposal options: N/A
PART IV - EVALUATION AND RECOMMENDATIONS
Phillips Pipe Line Company has requested renewal of its NPDES permit. Please note that the
discharge from this facility is for stormwater only. This office recommends that the current
NPDES Permit not be renewed but a General Stormwater Permit issued provided that the
parameters monitored at this facili may be listed as test parameters of the Stormwater Permit.
Signature of Report Preparer
,r /4,
Water Quality Regi
h:ldsr\dsr991
61 rii 6 I
Date
,g0-000-) IS// --/a/
Supervisor Date

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NC0032891
Facility Information
Applicant/Facility Name:
NC0032891 — Phillips Pipe Line Company — Charlotte Terminal
Applicant Address:
Mr. David Ysebaert; 3-B10 Adams Building; Bartlesville, OK 74004
Facility Address:
502 Tom Sadler Road; Charlotte, NC
Permitted Flow
Outfalls 001 and 002 are not limited
Type of Waste:
Outfalls 001 and 002: stormwater, loading rack water
Facility/Permit Status:
Active; Renewal
County:
Mecklenburg
iscellaneous
Receiving Stream:
UT to Gum
Branch
Regional Office:
Mooresville
Stream Classification:
W S-I V
State Grid / USGS Quad:
F 15 S W/Mountain
Island Lake
303(d) Listed?
No
Permit Writer:
Natalie Sierra
Subbasin:
Drainage Area (mi2):
03-08-34
Date:
3/6/01
0.1
Summer 7Q10 (cts)
0
Winter 7Q10 (cfs):
0
30Q2 (cfs)
0
Average Flow (cfs):
<►
1 WC (%):
100%
001: Lat. 35° 17' 07" N Long. 80° 56'23" W
002: Lat. 35° 17' 08" N Long. 80° 56' 18" W
BACKGROUND
Philips Pipe Line Co. owns several bulk storage facilities in the state of North Carolina — this is their
only facility in Mecklenburg County. Effluent water discharged from the outfall consists of stormwater from
the secondary containment areas (around the individual tanks) and discharge water following hydrostatic
testing. The facility ceased discharge of runoff from the loading rack area in 1996. This water is now stored
in a tank in the secondary containment area and hauled off -site by Industrial Waste Services of Jacksonville,
FL. The stormwater is released via one of two outfalls on site.
FILE REVIEW
Correspondence
Correspondence files from 1996-2000 were reviewed. During this time period, the Mecklenburg
County Department of Environmental Protection (MCDEP) performed five inspections. The facility received
a satisfactory rating on all of these inspections with the exception of the "Flow Measurement" category, for
which it received a marginal rating three times for inaccurate flow measureemtns..
Grab samples taken during the MCDEP compliance inspections indicate low levels of total suspended
solids (TSS) and non -detects for the volatiles and semi-volatiles detectable by the EPA 624/625 scan.
The facility received one notice of violation (NOV) in July 2000 for the violation of the total
suspended residue limit at each outfall. It was also noted that the data were reported as "ND" instead of "<
detection limit" in the DMRs.
DMR Review:
DMRs were reviewed from January 1997 through January 2001. The average discharge flow at 001
was 0.14 MGD; at 002 it was 0.10 MGD. Both have the same frequency of discharge. Total suspended solids
(TSS) during this time averaged 12.54 mg/L with a maximum of 160.0 mg/L at 001. At 002, the TSS
averaged 11.80 mg/L with a maximum of 90.0 mg/L. The average oil and grease concentration at 001 was
5.76 mg/L with a maximum concentration of 15.0 mg/L. The average oil and grease concentration at 002 was
21.14 mg/L with a maximum of 58.0 mg/L.
The twice -annual EPA 624/625 scan revealed non -detects for nearly all of the semi-volatiles and
volatiles tested. There was one detect of methylene chloride (7.1 ug/L — just above the detection level of 5
ug/L) but it was marked by Pace Laboratories as a laboratory contaminant.
Fact Sheet
NPDES NC0032891
Renewal
Page 1

Since March 1999, the facility has been required to sample for turbidity quarterly as per an EPA
directive. They have sampled during each discharge event since the requirement was instilled — the average
turbidity value in the past year and a half is 12.92 NTU at 001 and 7.75 NTU at 002. The maximum turbidity
value was 40.0 NTU at 001 and 18.0 NTU at 002.
The facility has passed its acute toxicity test since 1997.
Reasonable Potential Analysis:
Reasonable potential was performed for turbidity as a check for the necessity of including a limit of 50
NTU in the permit. Turbidity data indicate that effluent from both outfalls have the potential to exceed the
stream standard of 50 NTU. The maximum predicted turbidity at 001 was 331.2 NTU; the maximum
predicted turbidity at 002 was 114 NTU.
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 by the NPDES Unit after a data review and internal
discussions. It delineates monitoring frequencies and permitting limits for contaminants commonly found at
these sites. This document is heretofore referred to as the "2001 SOP."
Waste Load Allocation (WLA).
The last waste load allocation was performed in 1991, when the receiving stream was classified C
waters. Gum Branch has since been re-classified to WS-IV waters (confirmed with Aldridge Renn of the
Classifications and Standards Unit, 3/5/01). This WLA recommends BTE, lead and MTBE monitoring and
TSS and oil and grease limits.
Oil Terminal SOP:
The flow, toxicity, TSS, and oil and grease requirements specified in the previous permit and the 2001
SOP (Parts I.A. — I.D.) remain unchanged. Previously, the permit required semi-annual monitoring of xylene
in conjunction with EPA Methods 624/625, the facility will now be required to monitor monthly for the BTEX
parameters as per Part I.E. of the SOP. Benzene will be limited as per Part III.B of the SOP for facilities
discharging to water supply waters. This facility discharges to water supply waters, phenol monitoring and
MTBE monitoring and limits (Part III.A-C) are therefore required. Since the receiving stream was erroneously
identified as "C" under the previous permit, the facility has not been monitoring for phenol on a monthly
basis. A phenol limit will be placed in the permit, though a note will be placed in the cover letter informing
the facility that they may request a permit modification to eliminate the phenol limit once they have collected
twelve months of data. The phenol limits for the two outfalls will be different, however. The calculation is
based upon a 2/23/01 memo by Joe Corporon of the NPDES Unit that specifies a 0.43 lbs./day phenol loading
for each terminal discharging to WS waters in the Paw Creek area.
Calculation for 001:
0.431bs / day x 1 -0.10m I
8.34 0.5MGD g
Calculation for 002:
0.431 bs / day x 1 - 0.064m / L
8.34 0.8MGD g
Since the DMRs indicated no detects in the reporting of EPA Methods 624/625, this requirement will
be eliminated from the permit as per Part II.A. of the SOP. Naphthalene monthly monitoring will be added to
the permit as per Part I.F. of the 2001 SOP. Turbidity monitoring will be increased to monthly and a limit of
50 NTU will be added as per Part II.C. 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.
Fact Sheet
NPDES NC0032891
Renewal
Page 2

5
A note will be placed in the permit that reminds the facility to report all detection limits on the DMRs.
There are several occasions on which this was not done.
SUMMARY OF PROPOSED CHANGES
• Removal of EPA Methods 624/625 monitoring requirement
• Addition of naphthalene monitoring
• Addition of MTBE monitoring and limit
• Addition of quarterly turbidity monitoring
• Addition of oil and grease limit
• Addition of monthly BTEX monitoring
• Addition of benzene 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 Natalie
Sierra at [phone] ext. 551.
NAME: DATE:
REGIONAL OFFICE COMMENTS
NAME: DATE:
Fact Sheet
NPDES NC0032891
Renewal
Page 3

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
to
From:
Subject:
April 2, 2001
Britt Setzer
NC DENR / DEH / Regional Engineer
Mooresville Regional Office
Natalie Sierra
NPDES Unit
Review of Draft NPDES Permit NC0032891
Philips Pipe Line Company
Mecklenburg County
A7A
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
RECEIVED
APR 0 4 2001
NCDENR
Division of Environmental Health
Publi; Water Supply Section
Morrisville 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.
wwIiANi.'Vwwivwwwwn�ivwwwwANNV�v/VV/VVANA/V/Vv/vwAv�iwwwwwwwwwwww
RESPONSE: (Check one)
V---
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. _.____--.----
Concurs with issuance of the above permit, provided the following co tkl tions- re-m- t:
Signed
Opposes the issuance of the above permit. based on reasons stated be
APR 1 1 2001
l- pE'IR _ WATER QUALITY
POINT, SOURCE BRANCH
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Date: %
/‘'
919 733-5083, extension 551 (fax) 919 733-0719
6/
VISIT us ON THE INTERNET @ http://h2o.enr.state.nc.usINPDES Natalie.Sierra@ ncmail.net

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REASONABLE POTENTIAL ANALYSIS
Prepared by: Natalie Sierra, 3/6/01
Facility Name =
NPDES # =
Qw (MGD) =
Qw (cfs) =
7Q 10s (cfs) =
!WC (%) =
Philips Petroleum
NC0032891
0.8
1.237760
0
100.00
Outfall 002
Parameter
Turbidity
Max. Pred Cw
Allowable Cw
Chronic CCC w/s7Q10 dil. Acute CMC w/no dil.
FINAL RESULTS, ugll FINAL RESULTS, ug/l
114.5
50.0
Frequency of Detection
#Samples # Detects
6 6
Parameter = Turbidity
Standard = 50 NTU
Modified Data Nondetects RESULTS
15
4.3
5
1.7
2.5
18
Std Dev. 6.946
Mean 7.750
C.V. 0.896
Sample# 6.000
Mult Factor =
Max. Value
Max. Pred Cw
Allowable Cw
sample# nondetects detects
6 0 6
6.360
18.000 pg/I
114.480 pg/l
50.000 pg/l

REASONABLE POTENTIAL ANALYSIS
Prepared by:
Natalie Sierra, 3/6/01
Facility Name =
Philips Petroleum
Outfall 001
Parameter =
Turbidity
NPDES # =
NC0032891
Standard =
50
NTU
Qw (MGD) =
0.4971
Qw (cfs) =
0.769113
7Q1Os (cfs)=
0
Modified Data
Nondetects
RESULTS
/WC (%) =
100.00
40
Std Dev.
13.750
14
Mean
12.917
Chronic CCC w/s7Q10 dil.
Acute CMC w/no dil.
Frequency of Detection
8.6
C.V.
1.064
Parameter
FINAL RESULTS, ug/I
FINAL RESULTS, ugll
#Samples
# Detects
4.2
Sample#
6.000
Turbidity
6.2
Max. Pred Cw
331.2
4.5
Mult Factor =
8.280
Allowable Cw
50.0
6
6
Max. Value
40.000
lag/I
Max. Pred Cw
331.200
lag/I
Allowable Cw
50.000
lag/I
sample#
nondetects
detects
6
0
6

NC0032891
001
Philips Petroleum Company
Date Flow TSS Oil and Grease Xylene Turbidity
MGD (mg/L) (mg/L) (ug/L) (NTU)
002
Flow TSS Oil and Grease Xylene Turbidity
MGD (mg/L) (mg/L) (ug/L) (NTU)
1/15/97 0.1098 4 <0.5 <0.010 0.0614 4 <0.5 <0.01
3/3/97 0.2917 1 <1.0 0.1631 0.6 <1.0
4/23/97 0.2202 1.6 <1.0 0.1231 1.4 <1.0
6/5/98 0.0427 1.4 <1.0 0.0239 1.8 <1.0
7/23/98 0.4974 8 <0.50 <0.010 0.278 10 <0.50 <0.010
10/1/98 0.389 1 <1.0 0.0217 1 <1.0
12/1/97 0.0588 0.4 <1.0 0.0329 0.8 <1.0
1/14/98 0.0773 1.2 <1.0 <0.10 0.0428 1.5 <1.0 <0.010
2/12/98 0.0958 2 <1.0 0.0535 3 <1.0
3/23/98 0.0579 1.4 <1.0 0.0323 1.3 <1.0
4/6/98 0.0447 42 0.51 0.025 12 1.9
5/8/98 0.04457 3.5 1.95 0.7974 28.1 1.33
6/7/98 0.0452 11 <5 <5 0.1248 <10 <5 <5
8/17/98 0.1142 2 1.08 0.0639 2 4.82
1/4/99 0.0777 <5 <5 <5 0.0435 2 <5.0 <5.0
3/4/99 0.0758 10 <5 0.0424 28 27
6/14/99 0.0059 160 5.9 <5 40 0.0041 90 21 <5.0 15
10/12/99 0.4695 7 <5 14 0.2477 6.8 58 4.3
1/5/00 0.305 3.5 <5 <5 8.6 0.0045 2.7 <5.0 <5.0 5
2/16/00 0.1396 5.4 <5 0.0449 33 <5.0
3/21/00 0.2145 12 6.1 0.0224 5.4 5.1
4/17/00 0.0582 14 <5 0.0205 21 <5.0
7/27/00 0.0344 3.8 <5 <5 4.2 0.01 5.4 <5.0 <5.0 1.7
9/25/00 0.0497 3 9.8 0.016 <1 <5
12/1/00 0.0411 1.7 15 6.2 0.0269 <0.1 50 2.5
1/24/01 0.0825 <1 <1 <1 4.5 0.1868 9.6 <1 <1 18
ave. 0.14 12.54 5.76 12.92
max 0.50 160.00 15.00 40.00

VP/A 2s/-
1 /20/99 Detect of Methylene Chloride at 7.1 ug/L
No detects for 001 in No detects for 002 in
Jan '00 Jan '00
July' 00 July' 00
June'99 June'99
Jan '99 (except see above)
June '98
Jan '98
June '97
Jan '97
June '98
Jan '98
June '97
Jan '97
Detection level is 5 ug/L Reported as lab contaminant by
Pace Analytical

r
Whole Effluent Toxicity Testing Self -Monitoring Summary February 16, 2001
FACILITY REQUIREMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 'a
Pharr Yarns, Inc. Perm chr lira: 1.2% 1997 Pass - - Pass - - Pass - - Fail.Pass
NC0004812/001 Begin:2/1/1997 Frequency: Q P/F + Jan Apr Jul Oct + NonComp:Single 1998 Pass - - Pass - Pass - - Pass
County: Gaston Region: MRO Subbasin: CTB36 1999 Pass - - Pass - - Pass - - Pass
PF: 1.0 Special 2000 Pass - - Pass - Pass - - Pass
7Q10: 125.0 IWC(%):1.22 Order 2001
Phillips Petroleum Penn 24hr p/f ac lira: 90%
NC0084697/001 Begin:5/1/2000 Frequency: Q P/F + Jan Apr Jul Oct
County: Edgecombe Region: RRO Subbasin: TAR02
PF: 0.0432 Spccisl
7Q10: 36.4 I\VC(%):0.18 order:
+ NanComp:Single
1997 N - - H Pass - NRLPass - - Pass
1998 NRM H H H H H Pass.Pass Pass Pass.Pass Pass - -
1999 Pass - - Pass - - Pass - - Late Late Late
2000 Late H H Pass H Late Fail Pass Pass - H
2001
Phillips Pipe Line Co. PERM: 24HR LC50 AC MONIT EPIS FTHD (GRAB) 1997 - - - - -- - - - - - - -
NC0032875/002 Begin:7/1/1994 Frequency: 5 OWD/A NonComp: 199E -- - - - - - - - - - NMI
County: Johnston Region: RRO Subbasin: NEU02 1999 -- - - H H H H H - H H H
PF: VAR Special 2000 H H H H H H H - - H H H
7Q10: 0.0 IWC(%)90 Order. 2001
Phillips Pipeline Co. Perm 24hr se monk epis Bhd (grab)
N00032875/001 Begin:8/1/1999 Frequency: 5 OWD/A
County: Johnston Region: RRO Subbasin: NEU02
PF: N/A Special
7Q10: 0.0 IWC(%):100.0 Order.
NonComp:
1997 - - -- - -- - - - - - - -
199B -- - - - - - - 21.71,10.0
1999 --- -- H H H H H H >100.28 H H H
2000 H 54.7 H H H H H - - H H H
2001
Phillips Pipeline Co. 001 - Penn 24hr LC50 ac monit epis Ilhd (grab) 1997 NR/>100
NC0032891/00I Begin:9/1/1996 Frequency: A NonComp: 1998 >100
County: Mecklenburg Region: MRO Subbasin: CTB34 1999 70.7
PF: VAR Special 2000 >100
7Q10: 0.0 IWC(%):100 Order. - 2001
Phillips Plating Co. Petra 24hr ac p/f lim: 90%
NC0001881/001 Begin:9/1/2000 Frequency: Q + Mar Jun Sep Dec
County: Craven Region: WARO Subbasin: NEUIO
PF: 0.10 Special
7Q10: TIDAL IWC(%):100 Order:
+ NonComp: Single
Y 1997 -- Pass -- -- Pass - - Pass - -- Pass
1998 -- --- Pass Pass - - Pass - - Pass
- Pass - - Pass - - Pass - - Pass
- Pass - - Pass - - Fail Pass - Pass
1999 --
2000 -
2001
Piece Dye Acquisition Corp. -001 Penn 241w ac p/f lim: 90% 1997 - Pass
NC0003867/001 Begin:4/1/1998 Frequency: Q + Feb May Aug Nov + NonComp:Single 1998 - Pass -
County: Chowan Region: WARO Subbasin: CHO03 1999 Pass NR NR
PF: 1.5 Special 2000 - Pass -
7Q10: TIDAL IWC(%):NA Order 2001
Pass
Pass - - Pass - - Pass
Pass - Fail,Fail Fail >100 Pass -
Pass - - Pass - - Pass -
Pass - - Pass - - NR Pass
Pilot Mountain WWTP Perm chr Iim:3%; if pf 3.0MGD chr lim 5 % Y 1997 Pass - - Pass - -- Fait Pass - Pass
NC0026646/001 Begin:3/1/1998 Frequency: Q PIF + tan Apr Jul Oct + NanComp:Singlc 1998 Pass - - Late NR NR Pass - - NR/Pass
County: Sony Region: WSRO Subbasin: YADO3 1999 NR/Pass - - Pass -- - Pass - - Pass
PF: 1.5 Special 2000 Pass - - Pass - - Pass - - Pass
7Q10: 82.2 IWC(%)2.75 Ord. 2001
Pittsbero WWTP Perm chr lim: 90%
NC0020354/001 Begin:9/25/1998 Frequency: Q P/F Mar Jun Sep De
County. Chatham Region: RRO Subbasin: CPF04
PF: 0.75 Special
7Q10: 0.000 1 WC(%):100 Order.
+ NonComp:Single
1997 - - - - - - - -
1998 - - - - - - - - - - - Pass
1999 - - Fail NR/Pass - Pass - - Pass - - Pass
2000 - - Pass - - Pass - - NR/Pass - - Pass
2001
Plantation Pipeline Co. (001) Perm 24hr LC50 ac monk epic Ithd (grab) 1997 - - - - - - - - - - - >100
NC005I l6I/001 Begim7/I/1996 Frequency: A NonComp: 1998 - - - - - >100 - - - - - >100
County. Guilford Region: WSRO Subbasin: CPFOB 1999 -- - - - - >100 - - - - - >100
PF: Special 2000 - - - - - >100 - - - - - >100
7Q10: 0.0 IWC(%):NA Order: 2001
Plantation Pipeline Co. (002) Perm 24hr LC50 ac monit epis Bhd (grab) 1997 - - - - - - - - - - - >100
NC0051161/002 Begin:7/1/1996 Frequency: A NonComp: 1998 - - - - - >100 - - - - - >100
County. Guilford Region: WSRO Subbasin: CPF08 1999 - - - - - >100 - - - - - >100
PF: Special 2000 - - - - - >100 - - - - - >100
7Q10: 0.00 IWC(%):NA Order: 2001
Y Pre 1997 Data Available
LEGEND:
PERM - Permit Requirement LET = Administrative Leiter - Target Frequency = Monitoring frequency. Q- Quarterly; M• Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin - First month required 7QI0 = Receiving stream low Bow criterion (cfs) + = quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan, Apr, Jul, Oct NonComp = Current Compliance Requirement
PF - Permitted flow (MGD) IWC•/a = lnatream waste concentration P/F = Pass,Fail test AC - Acute CHR - Chronic
Data Notation: f - Fathead Minnow; • - Ccriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P P. Mortality of slated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: --- = Data not required; NR - Not reported Facility Activity Status: I - Inactive, N - Newly Issued(To construct); H - Active but not discharging; f•Mare data available for month in question; • = ORC signature needed
36

;)
PHILLIPS
PIPE LINE
COMPANY
March 6, 2001
Valery Stephens
Point Source Unit
Division of Water Quality
NC Department of Environment
& Natural Resources
1618 Mail Service Center
Raleigh, NC 27699-1618
RE: NPDES Permit Renewal
Permit NC0032891
Phillips Pipe Line Company -Charlotte Terminal, Mecklenburg County
Ms. Stephens:
As requested by your letter dated February 27, 2001, the following information is attached to help aid in
the permit renewal process.
• A site plan indicating all sources of stormwater, washwater and other wastewater (including discharge
from a groundwater remediation system) being discharged from the permitted outfall(s).
Charlotte Terminal discharges stormwater only. No groundwater remediation system discharges exist.
See Figure 1 and 1 a for sources of stormwater (attached).
• Disk or electronic copy of the past five years worth of discharge monitoring report data from the
facility.
Electronic data is available from January 1, 1997 to current (enclosed).
• A brief description of the manner in which tank solids, tank bottom water, rag layer and any other
waters are disposed.
The Charlotte Terminal discharges exclusively stormwater from the tank diked areas. All tanks are either
cone roof tanks or have geodesic domes, therefore, no stormwater comes into contact with petroleum
products in the tank diked areas. All surface water contained inside the dikes is inspected by the terminal
supervisor or authorized personnel before the manual valve is unlocked and opened to permit discharge.
Driveway drains are provided in the truck loading area, which are connected to a gathering sump tank.
Liquids from this tank are automatically pumped to a product storage tank. All tank bottom
waters/sludges are collected and sent to Allied Energy or Aaron Oil for product recovery.
BARTLESVILLE. OKLAHOMA 74004 918 661-6600

4
If you have questions or require additional information, please contact me at 918-661-1407.
Sincerely,
809-49
Becky Hesslen
Environmental Scientist
3-B10 Adams Building
Bartlesville, OK 74004
Attachments
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PHIE LIIPNELLS
PIP
COMPANY
CERTIFIED MAIL #7000-0520-0024-1774-4216
NC Department of Environmental
& Natural Resources
Water Quality Division/NPDES Unit
1617 Mail Service Center
Raleigh NC 27699-1617
RE: NPDES Permit renewal request for Charlotte Terminal
Permit No.: NC0032891
January 22, 2001
JAN 2 9 2001
L_________________
DENR - Vi if.:: kll]Y
POINT SOURCE bk;sii
As required by permit NC0032891 Section B10, Phillips Pipe Line Company is submitting the
NPDES Permit Application Renewal — Short Form C. The permit expires August 31, 2001 and
requires submittal 180 days prior to expiration.
The terminal's discharged water still remains to be stormwater only, from the tank dike areas.
There have been no process changes nor do we anticipate any process changes that would
affect the quality of the discharged water.
Your consideration is requested to reduce the frequency of the 624/625 analysis from semi-
annually to annually. In the past five years the terminal has reported Non -Detect for all
parameters in the analysis except for the January 1999 analysis for 624/625 which detected
methylene chloride which the lab considered to be a contaminate from the lab. Methylene
chloride is not used in any processes at our facility and has not been detected since.
If you have any questions or require additional information, please contact me at 918-661-1407.
Sincerely
Becky Hesslen
Environmental Scientist
3-B10 Adams Building
Barltesville, OK 74004
Attachments
BARTLESVILLE, OKLAHOMA 74004 918 661-6600

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 22, 1999
Mr. Tom Rich
Phillips Pipeline Company
Post Office Box 66
Paw Creek, North Carolina 28130
Dear Mr. Rich:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Letter to Require Effluent
Turbidity Monitoring
Permit No. NC0032891
Paw Creek Terminal
Mecklenburg County
As you are aware, the turbidity monitoring requirement was eliminated from your
permit upon renewal in August 1996. Although turbidity monitoring was eliminated, total
suspended solids (TSS) monitoring with a limit remains in the permit. It was the Division's
contention that should monitoring data indicate TSS problems, the state has the option of
enforcing the instream standard for turbidity. However, the EPA is still concerned with the
removal of the turbidity monitoring requirement from several oil terminal discharge permits.
The following paragraphs address that concern.
During the research phase required for permit development, it was noted that the 14
permits in the Paw Creek area had vastly different requirements for solids measurements.
Permits contained any combination of total suspended solids (TSS), turbidity, and settleable
solids monitoring and/or limits. In an effort to provide consistency, TSS, turbidity, and
settleable solids results from six oil terminals in the Paw Creek area were examined from
July 1994 through September 1995. Results showed that TSS and turbidity exhibited
similar trends. Both pollutants appeared to increase and decrease at the same time. In
addition, for the period examined, there were no turbidity violations, although there were a
few TSS violations. These data resulted in the Division questioning whether monitoring
was necessary for both solids parameters. Was there an added benefit to requiring turbidity
monitoring in addition to TSS monitoring? The Division concluded that turbidity was
correlated with TSS results, and thus, only TSS monitoring with a limit was required. In
addition, North Carolina has a water quality standard for turbidity. Therefore, although
turbidity monitoring is not required in the discharge permits, the State still has the authority
to enforce the instream turbidity standard.
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

Mr. Rich
February 22, 1999
Page 2
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 will
investigate the causes of these violations to determine what steps may be necessary to
control solids levels at these sites. Therefore, the Division 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 several of the oil
terminals. This letter serves as the official notice that quarterly turbidity monitoring
will be required at the facility effective March 1, 1999. If monitoring data show a
reasonable potential to violate water quality standards, then limits will be imposed upon
renewal.
If you have any questions concerning this change, please contact Bethany Bolt at
[phone], extension 551.
Sincerely,
. Preston Howard, Jr., P.E.
rek""
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Point Source Compliance Enforcement Unit