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Home My WebLink AboutNC0021962_Permit Issuance_20010730ATF 0� j Nit. Scott Eaton CITGO Petroleum Corporation P.O. Box 47427 Doraville, GA 30362 Dear Mr. Eaton: Awn NCDENR Michael F. Easley Governor William G. Ross, Jr., Secretary North Carolina Department of Environment and Natural Resources July 30, 2001 Kerr T. Stevens, Director Division of Water Quality Subject. Issuance of NPDES Permit NCO021962 Paw Creek Terminal Mecklenburg County Division of Water Quality 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 was an error made in all of the Paw Creek draft permits. The pH requirement was eliminated in the previous permitting cycle and should not have been included in the 2001 permits. • The MTBE limit of 11.6 µg/L has been removed from the permit. As per the hearing officer's recommendations, a peer -reviewed criterion for 1%l BE 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 (919) 733-5083, extension 551. cc hlooresmille Regional Office/Water Quality Section NPDES Unit Central Files Meddenburg County Departrnent of Environmental Protection Point Source Btanch Compliance, and Enforcement Unit N. C. Division of Water Quality, / NPDES Unit 1617 Mail Service Center, Raleigh, NO 27699-1617 Internet: h2o.enr.state.nc.us Phone: (919) 733-5083 fax: (919) 733-0719 DENR Customer Service Center..1 800 623.7748 Permit NCO021962 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELR IINATION 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, CITGO Petroleum Corporation is hereby authorized to discharge wastewater from outfalls located at the Paw Creek Terminal 7600 Mount Holly Road Charlotte Mecklenburg County to receiving waters designated as an unnamed tributary to Gum Branch within 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 V Ateveft , Director / Divi i n ofWater Quality By Authority of the Environmental Management Commission ` * Permit NCO021962 SUPPLEMENT TO PERMIT COVER SHEET CITGO Petroleum Corporation is hereby authorized to: 1. continue to operate the existing water pollution control system consisting of • an oil/water separator • an equalization tank • a second oil/water separator • a diffused aeration system • a detention pond with an underflow siphon located at the Paw Creek Terminal, 7600 Mount Holly Road (NCSR 1784), Charlotte, Mecklenburg County, and 2. discharge from said treatment facility through Outfall 001 at a specified location (see attached map) into an unnamed tributary to Gum Branch, a waterbody classified as WS-IV waters within the Catawba River Basin. Discharge point aa Latitude:35"I6'52" N Longitude: 8036'02" W N C 0 0 21 9 6 2 Quad # FOSW/Mountain Island Lake Receiving Scram: UT to Gum Stanch Stream class: WS-Iv CITGO Petroleum Corp. Subbasin: 30834 Facility Location �o r Eh MAP NOT TO SCALE Permit NCO021962 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: GTERISTI • . ,.. _.RWQ _ ._ _,__..�Ibnw.__ . on Xerag- ai y Maximum easarement4A Fequenc amp Typ am a canon Flowl piso is Effluent otal SuspendedSolids m on y raEffluent Oil and Greas Font y-' urab Effluent Turbidi on y raEffluent ThemoT Monthly Urab Effluent benzene 1 19 µgo ont y ra uent o uene 11 µg2 on y ra Effluent Eth y Benzene on y ra uent y ene ont y ra vent EPA Method Semt- nua y- Urab Eftluent Monthly- ra uent Acute Toxicitys I Annua y raI Effluent Footnotes: I oow- During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report (DMR) indicating 'No discharge." Flow shall be monitored at each flow 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.(3.) for other requirements relating to MTBE 5. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2.)]. There shall be no discharge of floating solids or foam visible in other than trace amounts. There shall be no direct discharge of tank solids, tank bottom water, or the rag layer. There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene concentration is less than 1.19 µg/1 and toluene concentration is less than 11 µg/l. Permit NCO021962 EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS A. (2.) ACUTE TOXICITY MONITORING (ANNUAL) The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste treatment. The permittee will conduct one test annually, with the annual period beginning in January of the calendar year of the effective date of the permit. The annual test requirement must be performed and reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this date. Toxicity testing will be performed on the next discharge event for the annual test requirement. The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later than 30 days after the end of the reporting period for which the report is made. Test data shall be complete and accurate and include all supporting chemical/physical measurements performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of the waste stream. Should any test 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 NC0021962 A. (3.) 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 pen -nit. 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 • i vueulCHEARING THE TOBEMELOBY McCklCnbU T ENORTN CARCLH AENVIFONMENTAL NANAGwoneenernmen CONN SSION fNI �� SUBJECT' A public hearing has been scheduled carper MefdkwArg NPpESPerreils: 9 gvpnsed r¢rrewal and issuances - P¢rind number NCorii to CITGO Petroleum GirppaliU b the Paw Creole Tennnul IOwted in Chaslpne, N.0 GM1artel (Mectledi County) for the discharye of sfnMlwattal held an doormen Inflicter, to Gum AFFID14VJTOFPUBLICAI Branch - Permit member NCOo2216] to MOliva Enterprises for Me Paw Creek Terminal dated In Chanotte NNIUDI C"COL[NA (Mec*ImWrg Coldi for the d;actso roe pf alamwabr and reribd1abed M undevat er into an unnamed MECKLANBURD COUNTY fnbutary to Gum Bland. BefmmlamndempmAallotaryl - Permit number NCW32NI to Philips Pipe Lire Company M the Corneille Terminal located in North Cairotua, duly wmmesionee CbarlObe (Memtlenburg County) for Me d;scharge of sbm raver sold an Unnarrled military to Gum bwto adhninuur eallu, Pessai Branch. Shelby J. C.."Pm'milnuer-0er NCW]4)951p William Termkus Ndtlings,LP.Aargre ChaddaoYSudieeenFBcifires Ttrmina1located ;n CrandXe(Moddembur9 CdenM) for Medvfiarge of slormwater into an unnamed TB Mzklmbva TNB!9, a nev eibutary to Paw Cri. on"vavmnd-dav rnaltintbe C . Permit number NC0004723 Id Valero Markri b Supply Company for Me Valero Markeung 8 andsrate;revheM1he in onewr od 1, ytipply Family keated in Chadded (Medlendury County) for Me M1vo.a,c a ste mxakr ;nfo an natem•>, rear rh< entice or olhm 11u mamed Visual to Paw Col NOTICE OF PUBLIC Y -PermilnumpeTNCON5]]ibTmn$M to eTam;nahrg,Inc lku Me ChirohePaw Geek Teo m0. TO BE HELD BY THE not N1 ideated In Charlotte (Mecbmtiurg County) sor rare doctrinal a sfumowaler on. an unnamed tributary to Paw Creek, ENtPTRONMRNTAL MAN! Permit nddaer NC00219]1 to Transhcn[algne Termnafrq,lno.6rlheCbarlotterPawGeexTenty- me #2 crated M Chookethe (Mecklenbum Count,) for Me doodl arge Of sl0rmwa4r into an unnamed tributary to Paw Comes. - -Per it number NCO031OMW Cdonial P;pel;neC[mpany}a Ml CNarMMe Delivery Facility located awm°^p�"f"friulrsawdr°dhmi in Charlene(MMMeburg Camtr)for Me disini of summoner Yob an unnamed tribNa to Gum IeoGeS'HgUS on her brothers, id, Batch. ry March 16, 2001 Permit number NC0046213 to Marathon Ashland Petroeum, LLCM Me Marathon Ashland Petro- lotion hand Icy cphN ;n Ch nlotte (stridulation, County) Mr Me. d'miou" of st. Ill il. un- andduitesmMrwwrp.p.rm whim named trnulary W Long Creekver m lepat adree oomero was Nblabr - P rmst number NCpo4fi531 to Crown Central Petroleum Company for Me Paw Creek Terminal everymcWpublicatioganineVi located in Paw Codes(Meddentiury COoifor' the dsmuoge of slaamvarei(nb an unnamed Mundary rndymYdurdmuaf Sed;m 1 397t t0 Gum Brand. C&rolinsassidneon,ouldiadiri - Perrot number NCON6892 to Mofva Posteriori LLC M Me Churiden Terminal loafed in Paw film 1 d"of Me Unrest Saudrea u Greek (M¢cMcnburg Couri for the Mucera ge. of slormwater arY remadsonel groundwater to an Thu 16th "yet M. unnamed mburary to doe, Creek. �y -Pe t bumbeir N0000itoE 0MO&I Refrfalg B Supply Compaq for Me Chad lh Terminal Merced In ChadolR (M¢ckl b g Co NI M the doodhource M didernessafter and reormandived Wounder. "A terba om¢d mbubryr Into Creex. S.—es sand aubsmL db and .lewd umber NCON51MI W; amp Term yb lk ,LP Paw CmekT inarlaated Paw Credit (Mosoldrurbour, County) On no director, a snomrwacer to an unnamed Inc Lary I0 Lmg 16th all March 20, Creek PURPOSEchsMe el Gt sn pplretl to rmewalaitma pppESpmedlf M tsdurge of Veal d sb c anah ed led Werindaydres rob—i a bane Cabwba river bear . Gn Me basis Of Preliminary San review and application a A+pde 21 aChap6143, General Statures of North N Ivy Publi, Cafdna, and Other lawful noticed- and regulaums, Me Nod Caadcma Euvuonrrent Management My C. is Eapveo: 7/7 Commission Potatoes to doup aNPDES comm;t for lad hui su[ject to sPemfc poluicnt lim;napms deed special conditions. The Director a Me Civil a Water Goal Pavlant b NCGS 141215.1(c)(3) prop RepNlkMt 15 NGO 2H, Senscr 91 W has detimiI Rut h s it Me pud;d Micron that a meeEn9 be hem to Ie¢Iw all perunea Public comment m whether he Lowe. modiry or deny He perms. PROCEDURE The hover, art he concluded in in fdcw;ig mpleh, f. The Dedsen of Mine Costly wY present an s`dNmddde A the Nq Gmtina Emeronment Management Cdylirissi0n's pwrmii, posol 2. The applicant may make an conflo don of Me action for which each Permit Is occurred, mild3.PubkcoMenl-Commr'0- s6lemen6, data andother mfddift. emaybesubmhedm,en, Io auto, Me meetir, or mar be presented wady at a rrcoYrg. Persons ifir, s, to speak will dlcateth tteme the force regsruat eMarneeen 0M Met mantes Bence tle r, prOspeak Met s0, see! sfateiixmis may b adennrm al ri tl y three wi tee Meeting sdCm. Ohl pre wffi gls that teat M m ubs shodo be accwrpanietl by three written cOo®. whin wtf be reed wuth Oivislm sUH at Me line a/re01sba0on. -- — 4. Crass eurrinalid r of WMne r esento, Iestimony'a1H opt be altw.ed; 1pe¢veq Me heath, aficer may ask pursuers for darificadon. 5. The beano, more may de Agreed ar Me contluslon Or Me rnMing. WHEN: April19oa110dpm WHERE'. Ohaiblb-Me&Ienburg Government Centre 6g0 East Fdonfi Struet, OW 14 Chabone.No9i Caml'ma INFORMATION AmPyol Med Aft NPDESpe t(s)wdamdpshs Mohair da dlscharye(s) vailable by_wnWa g or ut, rooms. Chos roe Jaceson NC Gives— me Water OcadryMPOES Unit 1617 Mail ServiM Center Raleigh, NdMCaro6ma 276931617 Telephone member (919) 733-5083. ektensim 530 - Theappl'rafiorasantOMerinfeme of areohfib at mdavisim attestation, Quality, 512 Nosh Salisbury Steel. Room 925 of Me A¢htl le B Iding in Ral ,h, Never GrWo red 1 the Dl from a Moores lle Reactor ONce(919 North Man Sim tin Mwres P¢,NC). They may m M,r ten tlontig normal office hours. Copan of Me Inrgmaoon 0m file are avauaWn upon reverent and Payment of the were of no,ver.rdum NI such cmmormin and repuesls rer,i Mls malls scout make reference b the Permit mi mbeer(s) holed above s50¢4 did, rob _ _ Permit Requirements for Discharges from Oil & 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. 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 te, (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 6 Version 7130/01 Permit Requirements for Discharges from Oil &. Petroleum Storage Facilities B. Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual Monitor annually (assuming first five discrete storm events have already been monitored and showed no toxic effects) Monitoring Footnote: acute toxicity monitoring should occur during collection of BTEX parameters (see item E below) Products stored at oil terminals may contain a variety of different chemicals (some of which may have harmful or toxic effects). To verify that toxic chemicals are not discharged to surface water, a periodic toxicity test will be required. An acute, rather than chronic, toxicity test is required because oil terminal facility discharges are typically short-term, episodic events. Specifically, an acute 24-hour pass/fail at 90% waste concentration using fathead minnows is the recommended toxicity test for stormwater discharges. Facilities that meet one or more of the following criteria will not qualify for annual monitoring and will be required to monitor for acute toxicity during five storm events: 1. Facilities that have never monitored for acute toxicity during a storm event, or 2. Facilities that monitored for acute toxicity during four or fewer storm events during the last permit period, or 3. Facilities that completed five acute toxicity tests during five storm events, but did not pass all five tests. Facilities that fail an acute toxicity test conducted during one or more of the five storm events or during an annual monitoring event will be required to conduct quarterly monitoring for the forthcoming permit period, and must receive State approval for reduced monitoring. For facilities that have not yet conducted acute toxicity testing for the first five discrete storm events, a statement in the permits will allow for additional toxicant limits should the toxicity test indicate toxic effects. At the time of permit renewal, only annual monitoring for toxicity would be required if the facility has performed the five discrete sampling requirements with no acute toxicity. C. Total Suspended Solids Monitor monthly Daily maximum 45.0 mg/l 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 Page 2 of 8 Version 7/30/01 Permit Requirements for Discharges from Oil & Petroleum Storage Facilities scan were never detected in the stormwater from these facilities. By monitoring for BTEX and naphthalene (see part F, below), the facilities are collecting data on those pollutants that are mostly likely to be present in the water. F. EPA Method 625 Monitor semi-annually The intent of this monitoring requirement is to monitor for naphthalene and other indicators of middle distillate compounds detectable by Method 625. These contaminants are commonly found in heavy fuels, such as diesel. During site visits of terminal facilities performed by members of the NPDES Unit, it was observed that the majority of the terminals reserve at least one storage tank for diesel fuel. Originally, facilities were to have monitored only for naphthalene, but since the most accurate method of quantifying naphthalene is through Method 625 and other middle distillate compounds can be detected through this scan, the entire results should be reported to the Division. If it can be demonstrated by the permittee that diesel fuel is not currently being stored on site, then the monitoring requirement on the effluent page will have the following footnote: "Monitoring requirement applies only for facilities storing diesel or other heavy fuels on site.' G. Tank Solids, Tank Bottom Water, and Rag Layer No direct discharge of tank solids, tank bottom water, or the rag layer is permitted. There are typically four discrete layers of varying thickness within a storage tank. At the very bottom of the tank is the solids layer that achieves a 1/2-1 inch thickness over a 5-6 year period. Immediately above the solids layer is 1-6 inches of tank botto& 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 Page 3 of 8 Version 7/30/01 Permit Requirements for Discharges fiom Oil & Petroleum Storage Facilities is 2393 µg/L, and is unlikely to be violated. All facilities discharging to water supply waters will have a special condition added to the permit that pertains to MTBE monitoring and source reduction (see Part III.C.) II. Additional Site -Specific Requirements A. EPA Method 624 Monitor semi-annually The entire 624/625 scan was originally included in the SOP to assess which of the petroleum -associated organic chemicals are found in stormwater. These tests scan for volatile and semi -volatile organics and cost approximately $700 to run (Ray Kelling, personal communication 2/ 14/01). Currently, the oil terminal facilities axe 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 030L TERNMIAL. . Acrylonitrile Benzene Bromodichloromethane Bromoform Bromomethane Carbon tetrachloride Chlorobenzene Chioroethane V Dibromochloromethane 1,2-Dichlorobenzene 1,3-Dichlorobenzene 1 4-Dichlorobenzene 1,1-Dichloroethane trans-1,2-Dichloroethene 1,2-Dichloro ro ane cis- 1,3-Dichloro ro ene trans- 1,3-Dichloro ro ene Ethyl benzene Methylene chloride 1,1,2,2-Tetrachloroethane Tetrachloroethee Toluene V 1, 1, 1 -Trichloroethene 1,1,2-Trichloroethene Trichloroethane Trichlorofluoromethane / Vinyl chloride / Page 4 of 8 Version 7/30/01 Permit Requirements for Discharges from Oil & Petroleum Storage Facilities Table 2. Compounds detectable by EPA Method 625 PARAMETER Acena hthene DETECTED IN OIL TERMINAL .- Acena hth lene Anthracene Benno a anthracene Benno fluoranthene Benno k fluoranthene Benno a ene Benzo(ghi)perylene Benzyl butyl phthalate Bis 2-chloroeth Tether Bis 2-chloroetho methane Bis 2-eth the 1 hthalate Bis 2-chloroiso ro 1 ether 4-Bromophenyl phenyl ether 2-Chlorona hthalele 4-Chlorophenyl phenyl ether Chrysene Dibenzo a,h anthracene Di-n-bu 1 hthalate 1,3-Dichlorobenzene 1,2-Dichlorobenzene 1,4-Dichlorobenzene 3, 3'-Dichlorobenzidine Diethyl phthalate Dimeth 1 phthalate 2,4-Dinitrotoluene 2,6-Dinitrotoluene Di-n-octylphthalate J Fluoranthene Fluorene Heptachlor Hexachlorobenzene Hexachlorobutadiene Hexachloroethane Indeno 1,2,3-cd ene Iso horone Naphthalene ✓ Nitrobenzene N-Nitmsodi-n-propylamine PCBs Phenanthrene J Pyrene Toxa hene 1,2,4-Trichlorobenzene 4-Chloro-3-meth 1 henol 2-Chloro henol 2,4-Dichloro henol 2,4-Dimeth I henol 2,4-Dinitro henol 2-Meth 1-4,6-dinitro henol 2-Nitrophenol 4-Nitrophenol Pentachloro henol Phenol J 2,4,6-Trichloro henol Page 5 of 8 Version 7/30/01 Permit Requirements for Discharges from Oil & Petroleum Storage Facilities B. Reasonable Potential (General) The reasonable potential procedure is a method used to determine the potential of a discharge to violate a water quality standard for a given parameter based on existing data. If a parameter is determined to have reasonable potential to violate a water quality standard, a limit and monthly monitoring will be required. A parameter is determined to have reasonable potential to violate a water quality standard if a calculated maximum predicted effluent concentration is greater than the allowable effluent concentration. Reasonable potential is determined by performing a statistical analysis for each parameter of concern that has either a state or federal water quality standard. For each parameter, the statistical analysis works best with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent concentration based on the existing data set. A step-by-step procedure for determining whether or not a parameter should be limited based on reasonable potential determination follows: STEP 1. Determine the number of sample points (n) 2. Determine highest value from data set. Best professional judgment should be used by the reviewer so as not to use an outlier. Since an outlier will not be determined statistically, maximum values should rarely be discarded in this analysis. 3. Determine the coefficient of variation (CV = STD DEV/MEAN) 4. Determine the appropriate multiplication factor to be used by comparing the number of samples versus the co -efficient of variation (see Table 3-1) 5. Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to obtain the maximum predicted effluent concentration. 6. Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable effluent concentration, which is based on instream dilution and the corresponding water quality standard. EPA recommends that permitting authorities find reasonable potential when the maximum predicted effluent concentration is greater than the allowable effluent concentration. A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet' and is located on the NPDES server. The spreadsheet requires the input of the facility name and permit number, the waste flow (Qw), 7Q 10 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 7Q 10 conditions for non -carcinogens. Average flow should be used for carcinogens and 30Q2 flow should be used for aesthetic standards. If a facility monitors semi-annually (twice/year), 10 data points would be obtained over a five-year permit period which is slightly more than the minimum number of data points which will accurately characterize an effluent discharge (USEPA March 1991). In cases where a facility requests reconsideration of a limit requirement, monthly monitoring should be required for at least 10 months so that 10 data points can be obtained and a second reasonable potential calculation can be conducted. If there is no reasonable potential for a water quality violation, monitoring should be reduced (to semi-annually). Page 6 of 8 Version 7/30/01 Permit Requirements for Discharges from Oil & Petroleum Storage Facilities C. Turbidity Monitoring (Paw Creek terminals) Monitor quarterly (Monthly monitoring and limit of 50 NTU if facility demonstrates reasonable potential) Based on concerns regarding anti -backsliding, the EPA requested the Division re-examine the basis for the elimination of turbidity monitoring for 12 of the 14 Paw Creek oil terminals that were required to monitor for turbidity prior to the most recent permit renewal. This second examination of the data showed that there were turbidity standard violations since the last analysis at several of the oil terminals. The Division therefore acknowledges that its second evaluation resulted in a different outcome from the initial investigation and agrees that turbidity monitoring should be added to the discharge permits for the oil terminals in Paw Creek. Facilities were sent notice in February 1999 that quarterly turbidity monitoring would be required at the facility effective March 1, 1999. If sufficient data exist, then reasonable potential should be performed to assess the need for more frequent monitoring and a limit of 50 NTU. For all facilities, the following footnote will be placed on the effluent limits page: *Turbidity — Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving stream background turbidity exceeds 50 NTU, effluent shall not cause this background value to increase. Ill. 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/l. The daily maximum limit for these facilities is therefore 1.19 multiplied by the dilution of the receiving stream under average flow conditions (rounded to two significant digits). This limit may be excluded from the permit only if there are sufficient data (eight sampling events) to demonstrate "no reasonable potential." If there is no reasonable potential, there will only be a monthly monitoring requirement. Page 7 of 8 Version 7130/01 Permit Requirements for Discharges from Oil & Petroleum Storage Facilities C. MTBE Monitor monthly MTBE special condition Given that this compound is considered a possible carcinogen, there should be a greater effort to keep high levels of MTBE out of water supply waters. As per the Paw Creek Hearing Officer's Report, after one year of monthly MTBE samples have been recorded, the facility must review the MTBE data. If no MTBE has been detected in the effluent samples, the facility may request a minor modification to the permit reducing the frequency of MTBE monitoring. If, however, MTBE has been detected during any of the discharge events, the Permittee must develop a plan of action to reduce the levels of MTBE entering the receiving stream. It is anticipated that an MTBE criterion for surface waters will be established at the time of the next permit renewal. At that time, sufficient data will be available to assess the reasonable potential for a facility to exceed any such standard or criterion. Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering News. Kelling, Ray, (Division of Water Quality Chemistry Lab). June 1996. Conversations with P. Clark. Kelling, Ray, (Division of Water Quality Chemistry Lab). February 2001. Conversations with N. Sierra. Linville, Ron, (Winston-Salem Regional Office). March 1996. Telephone conversation with P. Clark. Reid, Dianne, (Division of Water Quality - Planning Branch). June 1996. Conversations with P. Clark. Shiver, Rick, (Wilmington Regional Office). July 2001. Findings and Recommendations for Public Hearing Held on April 19, 2001. USEPA. March 1991. Technical Support Document For Water Quality -Based Toxics Control. EPA/ 505/2- 90-001. Page 8 of 8 Version 7/30/01 SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS CONTAMINANT CAS # "C" & "B" WATERS (ug/I unless noted otherwise) "WS4. - ,WS-V" WATERS WATERS (ug/I unless noted otherwise) SOURCE OF STANDARD OR CRITERIA BENZENE 7143-2 71.4 1.19 71.4 15A NCAC 28.0211-.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 100414 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/1 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 EPA4/22/99 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-TRIMETHYL BENZENE 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 1330-20-71 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 213.0208. 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 (Dianne.Reid@ncmail.net) OR Jason Wynn ext. 351 (Jason.Wynn@ncmail.net) MEMORANDUM TO: FROM: PREPARED BY: SUBJECT: DIVISION OF WATER QUALITY April 5, 2001 Dave Goodrich D. Rex Gleason Richard Bridgeman*�) Draft Permits for Paw Creek Facilities Following is a discussion of the draft permits: N Om O 1'W H� =— a WO 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 1, Section A(1). Should there not also be an upstream and downstream monitoring requirement. In fact, those facilities with a monitoring -only requirement need only conduct stream monitoring to determine if effluent turbidity levels result in stream standard violations. One of the exceptions mentioned above under the item for Turbidity Monitoring is Marathon Ashland Petroleum, LLC (NC0046213). Although the permit cover letter indicates that the permit includes a monthly monitoring requirement and an effluent limit, Part I, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring -only requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is being required because of the near potential for a stream standard violation. The other exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being required because none of the previously required monitoring has been conducted. Philips Pipe Line Company (NC0032891) — Phenol limit in the other permits is expressed in mg/L. In the Philips permit, it is expressed in ug/L. ExxonMobil Refining and Supply (NC0004839) — Benzene limit is indicated to be 1.2 ug/L; should it not be 1.19 ug/L? Dave Goodrich Page Three April 5, 2001 Phenol limit development. The cover letters for four of the six permits with a Phenol limit discuss development of the limit. In the cover letter, the water quality standard for phenol is indicated to be 1 mg/L; it is actually 1 ug/L for WS waters. The writer is not familiar with the 2001 SOP used to develop limits for phenol, but considering the fact that five of the six facilities discharge to streams having a 7Q10, 30Q2, and average stream flow of zero, and the sixth facility discharges to a stream having a 7Q10 and 30Q2 flow of zero and an average flow of <l, 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. 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 WATFa rN is nY.-qFrn0N APR � U 2,v1 Non"D wharoe PermItti g 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 stomtwater 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 0 Fax (704) 336-4391 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 deten ' n pond. Exxon Mobil Refining and Supply Company -Permit # NC0004839 Outfal1001- The daily maximum permit limit for benzene is listed as 1.2µg/l. The North Carolina water quality standard for WS-IV waters is 1.194g/l. Marathon Ashland Petroleum, LLC - Permit # NC0046213 The last footnote on the Effluent Limitations and Monitoring Requirements page of the permit states, "There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene concentration is less than 71.4yg/l and toluene concentration is less than I lug/I." Since the receiving stream is a class WS-IV water, the benzene limit should be 1.194g/l. 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. Qinrarnki 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 WII�3AM II. wG77rGRa1'n0N BVscIWe mm May 2, 2001 NORTH CAROLINA PETROLEUM COUNCIL A Ojuwbn of the Amwkan Perms= krtitz, SUME 2850 • 150 FAY9=VILIE Sr. MALL AALEIGH. NC 27601 o1C/97e-643e . CAx91e/R2]-G=7 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 oi'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 -malting. 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 all. In fact, the EMC recently dealt with the matter of MIKE and voted not only to reject a request for atemporary 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 ate A=,&. So as we all wm U Arn tl=tug pv c *& oa that woposal. we are now confronted with Sent By: ; 919 821 0337; May-2-Oi 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 MTBF, 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. 1.:... ,, The Council's members accept that an MTBE limit that has been peer -reviewed and duly considered via the rulemaking process may be appropriate for inclusion in the terminals' NPDES permits. Lacking that, however, the Council believes the MTBE limits contained in the draft permits should be removed. Importantly, the Council's members with facilities in Charlotte are willing to help the Department collect MTBE data by monitoring for it on a periodic basis. But the proposed monthly monitoring requirement is excessive. We are confident that semi-annual monitorby each of the terminals will provide the needed representative data to form the basis for future decision -making. Sincerely, Wes; ." William H. Weatherspoon WHW/jm c: Ms. Natalie Sierra CITGO BOX 47427 DORAVILLE, GA. 30362 MS. NATALIE SIERRA NCDENR - DWQ -NPDES UNIT 1621 MAIL SERVICE CENTER RALEIGH, NC. 27699-1617 RE:CITGO PETROLEUM CORP. NPDES PERMIT #NC0021962 DEAR MS. SIERRA, I WISH TO RECORD MY OBJECTION TO THE MTBE MONTHLY MONITORING REQUIREMENT THAT WAS INCLUDED IN THE DRAFT NPDES PERMIT ISSUED TO THE CITGO PETROLEUM CORP. BULK STORAGE TERMINAL IN PAW CREEK, NC. (PERMIT # NC0021962). THE I 1 PPB REGULATORY LIMIT IS UNREASONABLE AND IS NOT BASED ON SOUND, PEER REVIEWED, REPRODUCIBLE SCIENTIFIC METHODS. I THEREFOR REQUEST THAT THE NORTH CAROLINA DIVISION OF WATER QUALITY REMOVE THE MTBE MONITORING REQUIREMENT FROM THE PROPOSED CITGO PETROLEUM CORP. PERMIT. SINCERELY, 9�Lfll�l SCOTT EATON REGIONAL E/S MANAGER SOC PRIORITY PROJECT: Yes No X To: Permits and Engineering Unit Water Quality Section Attention: Valery Stephens Date: April 18, 2001 NPDES STAFF REPORT AND RECOMMENDATION County: Mecklenburg MRO No. 01-58 Permit No. NCO021962 PART I - GENERAL INFORMATION 1. Facility and Address: `4 3. 4. Citgo Petroleum Corporation P.O. Box 58 Paw Creek, N.C. 28130 Date of Investigation: 04-03-01 Report Prepared By: Samar Bou-Ghazale, Env. Engineer I rU APR 2 5 2001 DENR - WATER QUALITY POINT SOURCE BRANCH Persons Contacted and Telephone Number: Mr. Jim Utke, Terminal Manager; tel# (704)392-3236. 5. Directions to Site: Travel Highway 27 north from Charlotte to the community of Paw Creek The terminal is located at the intersection of Tom Sadler Road, Mount Holly Road, and Kenstead Circle in the Paw Creek Community. 6. Discharge Point(s). List for all discharge points: Latitude: 35 ° 16' 52" Longitude: 80` 56' 02" Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on map. USGS Quad No.: F 15 SW USGS Quad Name: Mountain Island Lake 7. Site size and expansion are consistent with application? Yes X No_ If No, explain: Topography (relationship to flood plain included): Sloping at the rate of 1 to 2%. The site is not located in a flood plain. 9. Location of nearest dwelling: The nearest dwelling is approximately 500 feet from the site. 10. Receiving stream or affected surface waters: Unnamed Tributary to Gum Branch. a. Classification: WS IV b. River Basin and Subbasin No.: Catawba; 03-08-34 C. Describe receiving stream features and pertinent downstream uses: The receiving stream is a wet weather ditch tributary to Gum Branch. PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS 1. a. Volume of wastewater to be permitted: The discharge from the groundwater treatment system has been ceased. The stormwater flow is not limited. b. What is the current permitted capacity of the wastewater treatment facility? N/A. C. Actual treatment capacity of the current facility (current design capacity)? N/A. d. Date(s) and construction activities allowed by previous Authorizations to Construct issued in the previous two years: N/A e. Please provide a description of existing or substantially constructed wastewater treatment facilities: The existing treatment facilities consist of two oil/water separators, an equalization tank, a diffused air system, a carbon filtration system and a detention pond. The oil/water separators are separated by the equalization tank. f. Please provide a description of proposed wastewater treatment facilities: N/A g. Possible toxic impacts to surface waters: Discharges of this nature have been shown to be toxic. h. Pretreatment Program (POTWs only): N/A. 2. Residuals handling and utilization/disposal scheme: The tank bottom water is pumped and hauled by Allied Energy Corporation, tel# 1-205-929-0501. The tank solids is handled by PSC Industrial Outscoring, tel# 1-770-607-3107. NPDES Permit Staff Report Page 2 Treatment plant classification: Class I 4. SIC Code(s): 5171 Primary:39 Secondary:73 Main Treatment Unit Code: 53000 PART III - OTHER PERTINENT INFORMATION Is this facility being constructed with Construction Grant Funds or are any public monies involved (municipals only)? N/A. 2. Special monitoring or limitations (including toxicity) requests: N/A Important SOC, JOC or Compliance Schedule dates: (please indicate) N/A. 4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge options available. Please provide regional perspective for each option evaluated. Spray irrigation: N/A Connection to regional Sewer System: There is no areawide sewer system near the site; connection to a regional sewer is not an option. Discharge to an infiltration gallery: N/A 5. Air Quality and/or Groundwater concerns or hazardous waste utilized at this facility that may impact water quality, air quality or groundwater? Contaminated groundwater already exists at the site. No hazardous materials concern. Air quality permit for this site may be required by Mecklenburg County. PART IV - EVALUATION AND RECOMMENDATIONS Citgo Petroleum Corporation is requesting NPDES Permit renewal for the discharge of treated stormwater from the subject facility. It is recommended that the NPDES permit be renewed. NPDES Permit Staff Report Page 3 I Signature o z4--lf 0 Preparer Date z) /i-� / e/ Water Quali Regional Supervisof ate NPDES Permit Staff Report Page 4 DENR/DWQ FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES No. NC0021962 Facility Information NCOMI962 — Citgo Petroleum Corporauon — aw ree ermma pp scan aci ityName: ApplicantAddress: Mr. Scott ton; P.O. Box Doraville, GA 30362 aci ityAddress: 7600 mt. Holly oa ar otte, NC 28214 Permitted ow of 1mite ype ot Waste: Stormwater, loading rack water Facility/PermitStatus: curve; enewa County: ec en urg BACKGROUND Cttgo Petroleum Corporation stores several million gallons of gasoline and diesel on the site of the subject permit. Effluent water discharged from the outfall consists of stormwater from the secondary containment areas (around the individual tanks), runoff from the loading rack, and discharge water following hydrostatic testing. Water from the loading rack goes through an oil water separator and then goes to a containment basin where it combines with the stormwater. The water is released manually as need through outfall 001. The cover letter to the permit renewal application indicated that Citgo is pursuing a non -discharge (spray irrigation) option for discharge of the stormwater. 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 "Self -monitoring" category, for which it received a marginal rating three times and an unsatisfactory rating once. These ratings were given for permit violations, failure to monitor (analytically) manual releases from the storage tank containment basins, failure to monitor at correct detection levels, and reporting "less than" values as "ND." Two NOVs have been issued for the findings in the self -monitoring category, one in April 1997 and one in June 2000. Permit violations discovered during the compliance inspections tend to be for benzene and total suspended solids (TSS). One toluene violation was noted in 1999. Grab samples taken during the MCDEP compliance inspections, however indicate low levels of total suspended solids (TSS) and non -detects for the volatiles and semi-volatiles detectable by the EPA 624/625 scan. In addition to the NOVs mentioned above, the facility has received on e NOV for violations of the daily maximum limits for benzene (January and February 2000) and one for exceedence of the daily maximum limit for TSS (November 1997). DMR Review: DMRs were reviewed from January 1997 through January 2001. The average discharge flow at 001 was 0.164 MGD with a maximum flow of 0.0618 MGD. Total suspended solids (TSS) during this time Fact Sheet NPDES NC0021962 Renewal Page 1 averaged 22.85 mg/L with a maximum of 360.0 mg/L. The majority of the oil and grease samples resulted it non -detects; the maximum concentration of oil and grease for the sampling period was 22 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 (6 ug/L — just above the detection level of 5 ug/L); this has been identified as a potential laboratory contaminant by Savannah Laboratories. 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 7.79 NTU with a maximum turbidity value of 22 NTU The facility has passed its acute toxicity test since 1997. Reasonable Potential Analysis (RPA): Reasonable potential was performed for benzene, toluene, turbidity, xylene and phenol. The analysis indicated that effluent from this facility shows reasonable potential to violate water quality standards for benzene, toluene and turbidity. Given that the facility has received NOVs for benzene, toluene and TSS (which is related to turbidity), it is somewhat expected that this would be the case. RPA predicted a maximum xylene concentration of 62.7 ug/L, this is below the water quality based allowable concentration of 88.5 ug/L. The allowable phenol concentration 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. The allowable concentration at this facility is 834 ug/L; RPA predicted a maximum concentration of 229.4 ug/L. Allowable Phenol Concentration Calculation for 001: 0.431bs/dayx 1= 0.83m lL 8.34 0.062MGD S 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 1994. Concerns were expressed over excessive turbidity, benzene and toluene in the effluent. It recommends limits for benzene, toluene and TSS and monthly monitoring for BTEX, lead, phenol and MTBE. 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 IH.B of the SOP for facilities discharging to water supply waters. This facilitydischarges to water supply waters - phenol monitoring and MTBE monitoring and limits (Part III.A-C) are therefore required. A toluene limit will be necessary due to a finding of reasonable potential (Part H.B). Since the DMRs indicated only the one detect in the reporting of EPA Methods 624/625, and this detect can be explained by laboratory contamination (being only just above the detection level), 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 NCO021962 Renewal Page 2 The toxicity requirement is currently specified as episodic in the permit. Given that the last five toxicity tests were reported as "Pass," the monitoring frequency will be reported as "annual." 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 emov o PA Me o s 4/625 monitoring requirement Addition of naphthalene monitoring Addition of MTBE monitoring and limit Addition of monthly turbidity monitoring Addition of monthly BTEX monitoring Change frequency of toxicity test from "episodic" to "annual' PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to PublicNotice: March 14, 2001 Permit Scheduled to Issue: April 27, 2001 NPDES DIVISION CONTACT If you have questions regaz g any of the above information or on the attached permit, please contact Natalie Sierra at (919) 733-5083 ext. 551. NAME: DATE: REGIONAL OFFICE COMMENTS lti/� cJF LfL A (J NAME: SSG DATE: S I ,L MAY - 2 2MI DE JURCE I RANCH Fact Sheet NPDES NCO021962 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 April 2, 2001 MEMORANDUM To: Britt Setzer NC DENR / DEH / Regional Engineer Mooresville Regional Office From: Natalie Sierra NPDES Unit e NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES APR 0 4 2001 NCDENR Division of Environmental Health Publi - Water Supply Section Moofesville Regional Office Subject: Review of Draft NPDES Permit NCO021962 CITGO Petroleum Corporation — Paw Creek Terminal Mecklenburg County Please indicate below your agencys 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. 7SN5E:(Check one) Concurwith the issuance of this permit provided the facility is operated and maintained properly, the tated 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 conditions are met: ❑ Opposes the issuance of the above permit, based on reasons stated hejpw. Qf Rualhtd:2001 74 1/ Date: 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5063, extension 551 (fax) 919 733-0719 VISIT US ON THE INTERNEr@http:/th2o.enr.state,nc.us/NPDES Natalie.Sierra®ncmail.net Whole Effluent Toxicity Testing Self -Monitoring Summary February 16, 2001 FACILffY REQUIRLMENT YEAR JAN FEB MAR APR MAY JUN JUL AUG SEP OLT NOV DEC Charbgte Terminal 10112 1. 24ltr LC50 uc mono epC, Md(gmb) 1997 Nw>lW - NM3289UW2 Degitn Wl/1996 Fnaaory:A Noo(Con, 1998 >100 - County Meckleni Regina: NB20 Sublasin: M34 1999 -IN — — — — — — — — — — — PR VAR Sow ZOO 7QI0: 0.0 IWC(%):IW qdm =I Chorloth,13ougka Airport Perm 20hr LC50p mount ryas lWd(gob) 1997 -100 -100 - -- - - - - - -- - - NC11083887/0,0I Begin:10/1/1996 FraNy:50WD/A NoWomp: im9 W.5 - 70.71 - - - - - - - - - Cmmty: MeckienbuB Region: MRO Subbmin: CTBJI 1909 >IN - - - - - - - - -- -- - PF: VAR sP•'ai.l 2090 25.5 _ _ 7QI0: 0.0 IWC(%)NA qde= Net Ch®Ieal Spnkllky IOC. Perm cbr It. B%% Y INT -IN - - -IN - - -IN - - -IN - - NLDOW351s001 Begmlll/1999 Frtqu y:QP/F + Jon AM lW Oct + NonCari, Singic 1998 w - - %.a - - H - - H - - Cauoty. Cabarrue Regi.: N1RD Sudsuin: YADI I Im9 N H H H PF: 0.025 Spcal 2UW H _ _ H _ _ H _ _ TQIO: 4.0 IWC(%)0.% qdw: 2001 Cherryv111e WWTP Pnnn chr lam: 34% 1m2 - - Para - - Pm - - Pan - - Pao NC Q`001 B<gin:Wl/1995 Frequmry: Q P/F + ManJur Scp@c NooCmnp:Single INS - - Pass - -- Plan -- -- Pm - - late County: G.W. Raga.: MRO Subbrin: UB35 Im9 Fail Par Fail Pass - - et - - Pill - - pun PF: 2.0 Sprees 2000 _ _. Feu - ... Pne _ _ Pr _ _ Pan 7Q16 6.1 IWC(%)34 qdm MI Ckeil. Kkla CC,Tkree First Data. Pmn CN lam: M Bob) INT - - - - - - - - - - - - N0008620)N01 Begin:VIWI998 Fro u :QP/F + MarJw Sep OCc + N,oAonp:Shlgk Im8 - - H - - NRAI NRM - H - - H Cmmty MrkleMurg Region MRO Subba.in LTB34 19m _ _ N _ _ H _ _ H _ _ H PR 0On SW NW - Fall 173 NR Fell Fml Fan Pms Pass - - Fall )QIO: 0.0 IWC(%):IW gder 2W, CkrW School ItWTP Pe_ chr dim: 90%(Grab) I"T - - Pao - - Fal NR NR Pass - - Pun NM3303MI Bagin:10/1/1995 Foo,,=U:QP/F + MaJunSep Dee NonCamp:ShW, im9 - - Pap - - Fen Pun _. pan _ _ Fan County: Buttcmnbe Region: ARO Subbrin'. FRBO2 I999 Pun - NWPa a - - et - Fan Prn - - Pan PR 0.02 Spit 290 - - Fall -IN 97.5 Pont - - Pas; - - Fall 7QIO: 0.0 IWC(%):IW Ordee 2001 at, Petroleum aW I Perm: 24hr LC50 at mount Class; B1ul (grab) I"T - - -IN - - - - - - - - - NCW219541WI Begin7/1/1999 Fnquy:A NonCemp. 191 - -IN - >IW >1011 - - - - - - - County lohmmn Raga.: RRO Subbanrc NEU02 Ism - - - -IN -- PF: VAR sl»ia 200 m B 1Q10: 0.0 IWC(%):IW qdv: Not Cltgo Petroleum 9002 Perm: 241r LC50n mane epu Bhd(grab) lmT - - - - - - - - - - - - NCU021954110' Begin:71I/1999 Frequy:5 OWD/A NDnComp: 1999 - - - - - - - - - - - NFOR Count' Jahn. nnl Region: RND Subbalin: NEU02 19m - -. _ >1W NW - -IN -IN -IN - -100 - PF % %R S''..l 2000 >100 >IDO 7Q10 00 IM ("ill 00 OW'. 2001 Cltgo-Pow Crk Bulk Terminal PC..: 20,1450o1m0nalryis flal(gob) t -- - - >1. - - - - - - - NCXXQI%N01 Ba,0n:9/1/I996 Frcqutai 50W31n NonCanp: County: Mecklmburg Rcgim: MRO Sublownin CTWa 19" - - - -- - a,N- - - - - - - - PF: NA spn;.l 20W ' —I . -_ ( IW Utlm 1 2.1 CLremwt Nonh Ill Perm ela, Rm: 13%Maw pmnl 4/If20UD 1997 Pass -. -- Pass _ Pe _ _ Pap _ _ NCV03266 l lkpn:7/1/1995 Frequency: QP/F' + tan Apr JWW NonCanP:SanglC 1. pass -- - Pasa - - Pun - - Pao - - Canot,Catawba Region: MRO Subtotal": CM32 19m Pass - -- Pro Poo Pun PF: 0.10 Special 2000 Pass - -- Pun Pu Pan ]QIO: 1.0 IWCVA):13 order tom Claramop gook WWTP P.,lor lam: 61% 1991 1 _ _. 1 _ _. I _ _ I _ _ NW026549N01 Begin:WUMI Fnquy:Q Ian Apr Jul Oct + NDn(foun,gitlgle toe I - - I - - I - - I - - Camly. Catawba Regan: MRO Subbevin: CTB32 1999 1 - - 1 _ _ I _ _ I _ _ PF: BAB Spew- TQIU; 0.10 lWQ%):60.18 gder'. Nm LEGEND: PERM- Permit Reuiretnul LU= Admanaswtive Lana -Targn Frequency - Mwitonng fmgmmy:Q-Quaoely; Mon Moodily;BM- BimonNly;SA- Semiannually A- Annually; OW0. Only when dixhargingg:D- DixunlinoW monimnng rrquimmml Begin=Fim mondh required TQIO=Re.iving mm�m low Row cntmion (cis) +=quarterly monidonng lncreansmmondhly upon feature or NR Months the,doing mum occur -ex. Jen, Apr, lulu at N9nComp-Currcm Camplknu RCquimmcm PF=Permilud Bow (MGD) IWC%=Insvom waste conccn0uuon P/F-PeWFeil test AC=Acute CHR-Chmnic Data Notation: f- Fm6ead Minnow. 4 - CcnndopMia up.; my - Mynd ehnmp; aV -Chmnic value; P - Mortality of HahW pamenta, at highrt concmtmtion; at - PmformM by DWQ Aquatic Tot, Unit; N - But tail Repaning Nowfimi--Dmetotrryuimd;NR-NetmpFaf Fxility A<Oviry Sdmra-hwctive,N-NCwlylmcd(To comwm);H-AcOvCbm.t discharging;l-Mom vov eveilabk for momhmquMiOn;•-ORCOanaonaneeded 9 REASONABLE POTENTIAL ANALYSIS Prepared by: Natalie Sierra, 3/1/01 Facility Name = Citgo Petroleum raramerer= nenzene raramerer = i omene Standard = I 1.19 pg/I Standard = Dataset= Dataset= DMR99 Modified Data Nondetects RESULTS Modified Data Nondetects 0.5 <1 Std Dev. 3.424 0.5 <1 0.5 <1 Mean 1.578 0.5 <1 0.5 <1 C.V. 2.169 0.5 <1 0.5 <1 Sample# 37.000 0.5 <1 0.5 <1 0.5 <1 0.5 <1 Mult Factor= 4.469 0.5 <1 0.5 <1 Max. Value 20.000 pg/I 0.5 <1 20 Max. Pred Cw 89.380 pg/I 37 0.5 <t Allowable Cw 1.190 pg/I 1.5 0.5 <1 1.3 0.5 <1 0.5 <1 2.9 6.9 0.5 <1 0.5 <1 0.5 <1 1.1 1.7 1.6 8 6 0.5 <1 1.5 0.5 <1 1.7 0.5 <1 0.5 <1 0.5 <1 0.5 <1 1.5 4.9 0.5 <1 3.8 3.9 7.9 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 0.5 <1 2.8 7.9 2.1 3.6 0.5 <1 0.5 <1 1.5 2.7 0.5 <1 1.5 0.5 <1 0.5 <1 0.5 <1 0.5 <1 pg/I RESULTS Std Dev. 6.188 Mean 2.741 C.V. 2.258 Sample# 37.000 Mult Factor= 4.620 Max. Value 37.000 pg/I Max. Pred Cw 170.940 pg/I Allowable Cw 11.000 pg/I nondetects detects sample# nondetects detects 37 28 9 37 21 16 -arameter= Humidity i aramerer= Standard = I 50 NTU Standard = Dataset= DMR99 I Dataset= Modified Data Nondetects RESULTS Modified Data Nondetects RESULTS 3.6 Std Dev. 7.640 2.9 Std Dev. 3.310 4 Mean 7.794 6.20 Mean 3.375 4.5 C.V. 0.980 8.6 C.V. 0.981 5.2 Sample# 9.000 1.00 <2 Sample# 6.000 5.4 1.00 20 Mult Factor = 5.540 0.55 <2 Mult Factor 22 Max. Value 22.000 pg/I Max. Value 8.600 pg/I 0.55 Max. Pred Cw 121.880 pg/I Max. Pred Cw 62.694 pg/I 4.9 Allowable Cw 50.000 pg/I Allowable Cw 88.500 pg/I sample# nondetects detects sample# nondetects detects 9 0 9 6 2 4 Standard = Dataset= Modified Data Nondetects RESULTS 5 <10 Std Dev. 5 <10 Mean 5 <10 C.V. 5 <10 Sample# 5 <10 5 <10 Mu/t Factor = 5 <10 Max. Value 5 <10 Max. Pred Cw 5 <10 Allowable Cw 5 <10 5 <10 5 <10 5 <10 5 <10 5 <10 5 <10 5 <10 1.4 5 <10 5 <10 68 5 <10 5 <10 5 <10 28 5 <10 5 <10 5 <10 5 <10 5 <10 5 <10 5 <10 14 5 <10 5 <10 5 <10 5 <10 sample# nondetects detects 37 33 4 11.013 7.470 1.474 37.000 3.374 68.000 pg/I 229.432 pg/I 834.000 pg/I Citgo NC0021962 Discharge 001 Date Ave. Flow TSR 10il & Grease jPhenol Benzene iToluene Xylene Turbidity (MGD) (mg/L) (mg/L) (ug/L) (ug/L) (ug/L) (ug/L) (NTU) 1/9/97 0.0057 <2 <1 <10 <1 <1 2/24/97 0.0058 4.8 <1 <10 <1 <1 3/17/97 0.0053 2 <1 <10 <1 <1 417/97 0.0042 <2 <1 <10 <1 <1 5/7/97 0.0031 2 1.5 <10 <1 <1 6/26/97 0.0040 <2 <1 <10 <1 <1 7/31/97 0.0014 <2 <1 <10 <1 <1 9/24/97 0.0618 84 1.8 <10 20 37 10/20/97 0.0351 4.8 2.8 <10 <1 1.5 11/18/97 0.0182 4 22 <10 <1 1.3 12/3/97 0.0213 7 1.4 <10 <1 <1 2.9 1/28/98 0.0222 <2 6.2 <10 2.9 6.9 2/11/98 0.0069 8 <1 <10 <1 <1 3/30/98 0.0232 2.4 <1 <10 <1 1.1 4/27/98 0.0256 <2 2.2 <10 1.7 1.6 6/9/98 0.0049 8 <1 <10 8 6 6.20 7/29/98 0.0131 4 1.6 <10 <1 1.5 8/18198 0.0101 6 <1 1.4 <1 1.7 9/24/98 0.0068 7 <1 <10 <1 <1 10/13/98 0.0225 <1 <10 <1 <1 11/16/98 0.0330 49 <1 68 1.5 4.9 8.6 12/17/98 0.0165 6 <1 <10 <1 3.8 1/25/99 0.0191 360 <2 <10 3.9 7.9 2/23/99 0.0165 9.7 <2 <10 <1 <1 4/15/99 0.0066 6.7 <1 28 <1 <1 6/28/99 0.0096 5 <2 <10 <1 <1 <2 3.6 7/13199 0.0165 2.3 <5 <10 <1 <1 4 9/8/99 0.0132 2.7 <5 <10 <1 <1 4.5 10/20/99 0.0144 6 <5 <10 <1 <1 5.2 12/6/99 0.0108 2 <5 <10 <1 <1 <2 5.4 1/27/00 0.0198 <2 <5 <10 2.8 7.9 20 2/17100 0.0132 20 <5 <10 2.1 3.6 3/27100 0.0420 2 <5 14 <1 <1 4/3/00 0.0181 15 <5 <10 1.5 2.7 22 7/13100 0.0149 5.7 <5 <10 <1 1.5 9/14/00 0.0231 <2 <5 <10 <1 <1 0.55 0.55 12/6/00 0.0198 3.7 <5 <10 <1 <1 4.9 average 0.0164 22.8500 4.9333 max 0.0618 360 22 68 20 37 8.6 22 EPA 624/625: 1997 All compounds listed below detection level 1998 All compounds listed below detection level except methylene chloride (6.Oug/L) -detection limit = 5 ug/L 1999 All compounds listed below detection level - November 1998 sample 2000 All compounds listed below detection level Fu BOX 47427 DORAVILLE, GA. 30362 MARCH 7, 2001 NATALIE SIERRA NORTH CAROLINA DENR NPDES SECTION RE: CTTGO PETROLEUM CORP. NPDES PERMIT # NC0021962 DEAR. MS. SIERRA, CITGO PETROLEUM REPORTED AN EXCEEDENCE OF 1 PPB METHYLENE CHLORIDE ON OUR REQUIRED METHOD 624 / 625 TESTING PERFORMED IN 1998. THE EXCEEDENCE WAS REPORTED AS 6 PPB AND THE DETECTION LIMIT WAS 5 PPS. I HAVE DISCUSSED THIS WITH MR IESSE SMITH, LABORATORY DIRECTOR SAVANNAH LABORATORIES AND HAVE THE FOLLOWING FINDINGS. METHYLENE CHLORIDE IS USED VERY EXTENSIVELY IN ALL LABORATORIES, AND THEREFOR IS A PRIME LABORATORY CONTAMINANT. THE QA/QC SHEET FROM THIS LABORATORY RI IN DOES NOT REPORT ANY METHYLENE CHLORIDE IN THE TRIP BLANK, BUT IT MAY HAVE BEEN INTRODUCED INTO THE SAMPLE BY HUMAN ERROR OR VIA AN IMPROPERLY CLEANED OR CALIBRATED INSTRUMENT. ALSO, CITGO DOES NOT USE ANY METHYLENE CHLORIDE IN THE PROCESS OF STORING AND DISTRIBUTING PETROLEUM PRODUCTS. THANK YOU FOR YOUR ATTENTION IN THIS MATTER PLEASE CONTACT ME IF 1 CAN BE OF FURTHER HELP. SINCERELY, SCOTTEATON CITGO PETROLEUM S�SAVANNAH LABORATORIES & ENVIRONMENTAL SERVICES. INC. 900 Lakeside Drive • Mobile, Alabama 36693-5118 • (334) 666-6633 • Fax (334) 666-6696 LOG NO: MS-25980 Received: 17 NOV 98 Reported: 09 DEC 98 Mr. Scott Eaton CITGO Petroleum Corporation Client PO. No-: 21-62-04 P.O. Box 47427 Doraville, GA 30362 CC: Mr. Jim Utke Project: Charlotte - Semiannual NPDES Sampled By: R. Durham Code: 175981214 REPORT OF RESULTS Page 1 DATE/ LOG NO SAMPLE DESCRIPTION , LIQUID SAMPLES TIME SAMPLED ----------------------- --------------------------------------------------- 25980-1 etormwater Discharge --------- 11-16-98/1115 ----------------------- ------------------------------------------------------------- PARAMETER -------------------- 25980-1 ---------- -------------------- ----------------------------- Purgeables (624) Benzene, ug/l <5.0 Bromodichloromethane, ug/1 <5.0 Bromoform, ug/1 <5.0 Bromomethane, ug/l <10 Carbon tetrachloride, ug/l <5.0 Chlorobenzene, ug/1 <5.0 Chloroethane, ug/l <10 2-Chloroethylvinyl ether, ug/l <50 Chloroform, ug/1 <5.0 Chloromethane, ug/1 <10 Dibromochloromethane, ug/1 <5.0 1,2-Dichlorobenzene, ug/1 <5.0 1,3-Dichlorobenzene, ug/1 <5.0 1,4-Dichlorobenzene, ug/1 <5.0 1,1-Dichloroethane, ug/1 <5.0 1,2-Dichloroethane, ug/1 45.0 1,1-Dichloroethene, ug/l <5.0 trans-1,2-Dichloroethylene, ug/1 <5.0 1,2-Dichloropropane, ug/1 <5.0 cis-1,3-Dichloropropene, ug/l <5.0 trans-1,3-Dichloropropene, ug/l <5.0 Ethylbenzene, ug/l <5.0 Methylene chloride (Dichloromethane), ug/1 --------------------------------------- ---------- %*M' ---------- ------------------ S�SAVANNAH LABORATORIES & ENVIRONMENTAL SERVICES. INC. 900 Lakeside Drive • Mobile, Alabama 36693-5118 • (334) 666-6633 • Fax (334) 666-6696 LOG NO: MS-25980 Received: 17 NOV 98 Reported: 09 DEC 98 Mr. Scott Eaton CITGO Petroleum Corporation Client PO. No.: 21-62-04 P.O. Box 47427 Doraville, GA 30362 CC: Mr. Jim Utke Project: Charlotte - Semiannual NPDES Sampled By: R. Durham Code: 175981214 REPORT OF RESULTS Page 8 DATE/ LOG NO SAMPLE DESCRIPTION , QC REPORT FOR LIQUID SAMPLES ------------ TIME SAMPLED -- — — — —------------ ---------------------------------------------- 25980-2 Method Blank 25980-3 Lab Control Standard t Recovery 25980-4 Precision (%RPD) of LCS/LCSD ----------------------- ----------- ------------------------------------------------- PARAMETER 25980-2 ---------- 25980-3 -------------------- 25980-4 -------------------------- — ----------- ---------- Ethylbenzene, ug/l <5.0 --- --- Methylene chloride (Dichloromethane), ug/l SxSA --- --- 1,1,2,2-Tetrachloroethane, ug/l <5.0 --- --- Tetrachloroethene, ug/l <5.0 --- --- Toluene, ug/l <5.0 100 0.75 1,1,1-Trichloroethane, ug/1 <5.0 --- --- 1,1,2-Trichloroethane, ug/l <5.0 --- --- Trichloroethylene, ug/l <5.0 96 %7 2.6 It Trichlorofluoromethane, ug/l <5.0 --- --- Vinyl chloride, ug/l <10 --- --- Xylenes, ug/l <5.0 --- --- Purgeable Aromatics (602) Benzene, ug/1 <1.0 104 6.7 Ethylbenzene, ug/1 <1.0 --- -- Toluene, ug/l <1.0 88 t 6.8 Xylenes, ug/l <2.0 86 t 6.9 % Date/Time Analyzed 11.24/0859 11.24/0938 --- Analyst ------------------------------------------------- `w ---------- -------------------- Serial Number I (1i J �j J. e SAVANNAH LABORATORIES rl 5102 LaRoche Avenue, Savannah, GA 31404 Phone: (904) 878-3994 Fart: (S12) 352-9504 Phone: (954) Fax: (954) S L & ENVIRONMENTAL SERVICES, INC. 421-2594 Q 2846 Industrial Plaza Drive, Tallahassee, L33 42 421-3994 O gXd SW 121h Avenue, Deerfield Bead1, FL33442 Phone: (954) 421-7400 Fax: (954) 421-2564 Fax: (334) 666-M 9�900 Lakeside Drive. Mobile, AL 36893 Phone: (334) 666-6633 Fax! (813)8B5.7D49 ANALYSIS REQUESTAND CHAIN OF CUSTODY RECORD 06712BenimklRoad, Suite 100,Tanrpa,FL33634 Phone:(8131885-7427 Fax: (504) 725-1163 O 100 Alpha Drive. Suite 110. Destrehan, LA 70047 Phone: (504) 764-1100 PROJECT REFERENCE PROJECT NO. P.O. NUMBER- MATRIX REOUIREDANALYSES PAGE OF NP Df-�) TYPE PROJECT LOG. LER(s)NAME PHON 9Z Z 6 m a b (slate) NL 3 ILIit9+^ FAX - 676 P 'V ro STANDARD t REPORT CLIENT NAME CLIENT MANAGER Q� < d O V 3 s El DELIVERY �^ GTGo , Ztk(mvi,- �P JCAr Trod Q Q� Q� EXPEDITED REPORT CLIENT gpDiESS(Cf7V,STATE, ZIP) �I� eg J O ['' K! v ❑CELIVERV(surcharge) �[ `OO mrHA! 1 4YZLFf£ tjL ZIS ✓ PLIn SAMPLE IDENTIFICATION \¢ = NUMBER OFrCONTAINERS SUBMITTED REMARKS pq r � r= ,a= 41 "t ELL r' DATE TIME RELINQUISHED BV:(SIGNATURE) DATE TIME RELNOUISHED BY: (SIGNATURE) DATE TIME : (S NATURE) AEON .... . t;•�.. DATE TIME GATE TIME RECEIVEDBY:(SIGNATURE) RECENEDBY (SIONATLKiE) DATE TIME RECEIVED BY:(SIGNATURE) fY 6 r C Frcto �-7e-o ��2�0� No �r1rve ASP. 2j.c-1NBC `1Co2 -21 zz 199 �1 ��dtu�i1 - 81 FLUW O+ ! ti�NOL� X Il r7�x (o2.41(�25 �R \i� ID c-laN 1 WZI �llA I+H 7MN A:o.oz M-1z Av6 sseowtf:L a .uzcFs o$!� �lrrwn ana l` C6tvC�2h( Od e 1,azos> IT`I �CGGSSIv� �X Gr3S,vc "'$EN�F1nl�, h Ip��y �j U!-t) ReC- t16w �taC 1 r�E 13,T O l.j"141�If 1i�V UL SAS ! -3 Igb Z a4 o dlu�cnsl GuJ u/Aud; ) ij65cR 3E5 T w ral o /,s: c/w Sc�P FC2 �wev � 2" o)VO DESic,W CAPn = —7 ritib . _LOjQ4p- 5f SA�,SFflc � cozy �.A--n`v�J Esc"Cl. acc�> stvOc`weE� �r cc�-�r>L Sw�v,� l Dt cz�� t�aE (S-S)L) -gu-TNo co2yIG2rj 612AI9(, "cow c_G,1,fz0 i5flnSo 2 TlN� L?cCGYT# !N Sti1F—KOt�\TL7lttty� i��6C,KAM —1 Pti-TlO�, viuL_[iniq�t5) 1VCCx�a 1c1�oZ l>�ia NO V -(or TSS (8v.o B/L-) -ba),Ly ►-tax 4110 y caneevrl ��Urnr�cffa�i� „� 80T ate( From nTC1 (NOV i�t�co/6 �I\ yd /YJ jd i n ccn vncfiatn cul SlC� Aso 2anNct Ex�� '+•'a -� 6� Sa�s�croRy r,xcc�� nna�, ?itIEVO, ra-� cue.rkzr '��c.TorJ LeVQ- �L\ t TSS j�q �y Mnx V A- -1-T-6Z..vejj�.-. < k " lggl 51z9 CaSo1 o b l McDc�� 3�C o9Q meao. �� IL Ao \1 6 VGI Ap � t� CoJ�1a by MC p �i VIO-u out Sq- I t jA x Vio Li ?�_ (a I(n NOV-FaIlo� r-S 1 MCD-lp �Al�y (tXIX V�G1S. 4t1 '73RN.t co Iee- I �TE� this IGAi Es �}VA7 r� �� A�2� -fLlr-S-A PI� A No N — l�S�ttfiRbc (uAND glop ) Z �J 04 t Z Cc�vT��rv1 ��_1T H+'a0v;�7-sty -l)'SC-k1Cj . Tb S C VN(e3 4 E THy %_- -?�v — i2Pm'�o�o Qo-P (02-�1 I �Z3 un la ; d, IVIGv� + l &Lj- Cx re cc) i -- 6�,A 6 e `'� L9 FEBRUARY 26, 2001 MR. CHARLES WEAVER, JR. NORTH CAROLINA DENR NPDES UNIT 1617 MAIL SERVICE CENTER RALEIGH, NC. 27699-1617 RE: NPDES PERMIT # NCO021962 CITGO BOX 47427 DORAVILLE, GA. 30362 MAR - 2 2001 LR - WATER DUALITY Pol NTT SOURCE BRANCH DEAR MR- WEAVER, PLEASE FIND THE ENCLOSED NPDES RENEWAL FORM FOR THE CITGO PETROLEUM CORP. TERMINAL IN PAW CREEK. IN ADDITION TO THE NPDES RENEWAL, CITGO IS PERUSING A NON DISCHARGE STATUS FOR THE STORM WATER THAT ACCUMULATES IN THE DIKED SECONDARY CONTAINMENT AREAS. IT IS OUR INTENTION TO LAND APPLY STORM WATER TO SUITABLE AREAS OF THE TERMINAL, AND WE ARE CURRENTLY APPLYING FOR A NON DISCHARGE PERMIT. CITGO HAS COMPLIED WITH THE PERMIT TESTING REQUIREMENT REGARDING EPA METHOD 624 / 625 ANALYSIS OF STORM WATER FOR THE LIFE OF THE PERMIT. DURING THAT TIME, ALL CONSTITUENTS HAVE BEEN REPORTED AS NON DETECT. CITGO IS THEREFOR REQUESTING THAT THE REQUIREMENT FOR METHOD 624 / 625 TESTING BE DISCONTINUED. THE NPDES SYSTEM AT THE TERMINAL PRODUCES VERY LITTLE SLUDGE. THE ONLY SLUDGE GENERATED AT THE TERMINAL IS IN THE DRAIN SYSTEM TO THE OIL / WATER SEPARATOR AND IN THE OIL / WATER SEPARATOR THE DRAINS AND SEPARATOR ARE CLEANED INFREQUENTLY, ON AN AS NEEDED BASIS. SLUDGE DISPOSAL IS HANDLED THROUGH A QUALIFIED VENDOR, HAULED OFF SITE, AND TREATED IN COMPLIANCE WITH APPLICABLE REGULATIONS. THANK YOU FOR YOUR ATTENTION IN THIS MATTER IF THERE ARE ANY QUESTIONS, PLEASE CONTACT ME AT 770-458-8322. SINCERELY, TT EAT N REGIONAL ENVIRONMENTAL AND SAFETY MANAGER �tfl) 5 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. Scott Eaton Southeast Environmental and Safety Manager Citgo Petroleum Corporation Post Office Box 47427 5 Doraville, Georgia 30362 Dear Mr. Eaton: Ame " �� NCDENR NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES Subject: Letter to Require Effluent Turbidity Monitoring Permit No. NCO021962 Charlotte NC 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 temunal 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 919-733-5083 FAX 919-733-9919 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper Mr. Eaton 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 (919) 733-5083, extension 551. Sincerely, .J��Preston Howard, Jr.,� cc: Central Files Mooresville Regional Office, Water Quality Section NPDES Unit Point Source Compliance Enforcement Unit State of North Carolina Department of Environment, Health and Natural Resources Division of Water Quality James B. Hunt, Jr., Governor Jonathan B. Howes, Secretary A. Preston Howard, Jr., P.E., Director July 7, 1997 Mr. Scott Eaton Southeast Environmental and Safety Manager Citgo Petroleum Corporation P. O. Box 47427 Doraville, Georgia 30362 Subject: NPDES Permit Sampling Permit No. NCO021962 Charlotte, NC Terminal Mecklenburg County Dear Mr. Eaton: The Division acknowledges receipt of your correspondance dated June 13, 1997 regarding NPDES permit sampling at the above referenced facility. With this letter, the Division approves Citgo Petroleum's plan to make necessary changes to the on -site collection system so as to ensure mixing of the dike water and treated stormwater from the rack containment area. It is the Division's understanding that sampling to meet the requirements of the NPDES permit will take place after adequate mixing of the two sources of water has occurred. If you have any questions or concerns regarding this, or any other, matter, please do not hesitate to contact Mark McIntire at telephone number (919) 733-5083, extension 553. Sincerely, ) Preston Howard, Jr., P.E. cc: Central Files Mooresville Regional Office / Water Quality Section (with attachments) Permits & Engineering Unit / Permit File P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-5083/FAX 919-733-0719 An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper