NC0022187_Correspondence_20031013

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
October 13, 2003
Nicola E. Cloutier
Environmental Engineer
Motiva Enterprises, LLC
2232 Ten Ten Road
Apex, North Carolina 27539
Subject: MTBE Reduction Plans
NPDES Permit #NC0046892
Motiva Enterprises LLC — Charlotte South Terminal
NPDES Permit #NC0022187
Motiva Enterprises LLC — Charlotte North Terminal
Mecklenburg County
Dear Ms. Cloutier:
This letter is in response to your report providing follow-up information on two NME reduction plans for the above referenced
facilities.
Information provided in your report indicates that MTBE has been detected during one sampling event at Charlotte South
Terminal (NPDES Permit #NC0046892). According to your letter, this exceedence could be attributed to a power failure as a result
of an ice storm. Due to the low likelihood of such an event being repeated on a regular basis, DWQ shall not require Plan of .action
for M'TBE reduction at this time.
Monitoring at the Charlotte North Terminal (NPDES Permit #NC0022187) has shown the presence of MIBE in Outfall 001 on a
more frequent basis. Therefore, DWQ shall require a Plan of Action for MTBE reduction for the Charlotte North Terminal.
Such a plan might include installation of a filtration device at the point of discharge and/or elimination of the source of MTBE.
Should you have any questions about these decisions or MTBE policy, please feel free to contact Sergei Chernikov at (919) 733-
5083, extension 594.
incerely,
t - David A. Goodrich
r Supervisor, NPDES Unit
cc: Mooresville Regional Office, Water Quality Section
Central Files
NPDES Permit File, NCO046892
NPDES Permit File, NCO022187
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone]
Customer Service 1 800 623-7748

CERTIFIED MAIL #7002 0460 0002 7707 6758
RETURN RECEIPT REQUESTED
August 5, 2003
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: MTBE Reduction Plan
NPDES Permit - NCO022187
Motiva Enterprises LLC — Charlotte North Terminal
To Whom It May Concern;
M TIVA
ENTERPRISES LLC
Per Permit Condition A.(4) of NPDES Permit NC0022187, Motiva Enterprises LLC — Charlotte North
Terminal is providing follow-up information on the status of the MTBE reduction plan for the facility.
Monthly monitoring of MTBE at Outfall 001 has been in effect since issuance of the permit on September
1, 2001.
Attachment A indicates that during the period of September 2001 through July 2003 MTBE has been
detected in Outfall 001 at levels ranging from non -detect to 27 ug/L. The latest sampling result for
MTBE in Outfall 001, in July of 2003, reported a value of 9.5 ug/l. Motiva has been investigating the
possible effluent sources at that facility that may impact the water quality condition at Outfall 001 with
respect to MTBE. Prior to preparing a sampling plan for sources upstream of Outfall 001, Motiva is
requesting that the NCDENR provide feedback as to what level the MTBE at the facility needs to be
reduced to. It is Motiva's understanding that there has been no surface water criterion established to date
for MTBE, and therefore it is not known whether the results of sampling on Outfall 001, would meet
future limits.
Motiva respectfully requests that a response be provided as soon as practical on this matter. If you have
questions pertaining to this submittal, please contact me at 919-387-5764.
Sincerely,
Motiva Enterprises LLC
4"411 �o
Nicola E. Cloutier
Environmental Engineer
Attachment
cc: Charlotte North Terminal Files
N. E. Cloutier
2232 Ten Ten Road Apex, North Carolina 27539 Phone: [phone] Fax: [phone]

Attachment A - MTBE Monitoring
Motiva Enterprises LLC - Charlotte North Terminal
NPDES Permit #NC0022187
Month
Year
Outfall001
MTBE ug/I
September
2001
<5 (ND)
October
2001
No Discharge
November
2001
No Discharge
December
2001
5.5
Janauary
2002
<5 ND
February
2002
18
March
2002
20
April
2002
26
May
2002
19
June
2002
16
July
2002
12
August
2002
<5 ND
September
2002
11
October
2002
<5 (ND)
November
2002
21
December
2002
25
Janauary
2003
22
February
2003
27
March
2003
22
April
2003
27
May
2003
7.5
June
2003
24
July
2003
9.5
Note: <5 (ND) = Not Detected in Sample at a reporting limit of 5 ug/I
MTBE Monitoring.xls Page 1 of 1 8/5/2003

Nmi
CERTIFIED MAIL #7000 1670 0006 9212 7527
RETURN RECEIPT REQUESTED
December 2, 2002
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
M TIVA
ENTERPRISES LLC
Shell, Texaco 6 Saudi Aramco Working Together
Subject: MTBE Reduction Plan
NPDES Permit - NCO022187
Motiva Enterprises LLC — Charlotte North Terminal
To Whom It May Concern:
DEC - 6 ,W
Per Permit Condition A.(4) of NPDES Permit NC0046892, Motiva Enterprises LLC — Charlotte North
Terminal is hereby submitting a MTBE reduction plan. Monthly monitoring of MTBE has been in effect
since issuance of the permit on September 1, 2001. Attachment A indicates that during the period of
September 2001 through November 2002 MTBE has been detected in Outfall 001 during nine (9)
sampling events. MTBE values noted during the sampling period ranged from non -detect to 26 ug/l.
As per condition A.(4), after one year of monthly monitoring of MTBE the Permittee is required to
review the MTBE data. If MTBE has been detected within the first year of effluent sampling, the facility
must submit an MTBE reduction plan. Motiva Enterprises is in the process of reviewing the water
sources at the facility to determine the source of MTBE in Outfall 001. Upon determining the source(s)
of MTBE, best management practices will be reviewed to determine the feasibility of reducing or,
eliminating MTBE from the facility effluent. Data will be submitted to the Water Quality Section
detailing the plan upon completion of source testing.
If you have questions pertaining to this submittal, please contact me at 919-387-5764.
Sincerely,
Motiva Enterprises LLC
Nicola A. Ellis
Environmental Engineer
Attachment
cc: Charlotte North Terminal Files
N. A. Ellis
2232 Ten Ten Road Apex, NC 27502 Phone: [phone] Fax: [phone]

Attachment A
MTBE Monitoring 09/2001-11/2002
Month
Date Sampled
Outfall 001
MTBE ug/I
Sep-01
09/07/01
Not Detected
Oct-01
No Discharge
N/A
Nov-01
No Discharge
N/A
Dec-01
12/14/01
5.5
Jan-01
01/11/02
Not Detected
Feb-02
02/13/02
18
Mar-02
03/05/02
20
Apr-02
04/03/02
26
May-02
05/13/02
19
Jun-02
06/06/02
16
Jul-02
07/10/02
12
Aug-02
08/21/02
Not Detected
Sep-02
09/18/02
11
Oct-02
10/14/02
Not Detected
Nov-02
11 /07/02
21
MTBE Monitoring.xls Page 1 of 1 12/2/2002

s' Cr/
DRINKING WATER ADVISORY: CONSUMER ACCEPTABILITY
ADVICE AND HEALTH EFFECTS ANALYSIS ON
METHYL TERTIARY -BUTYL ETHER (MtBE)
EXECUTIVE SUMMARY
MtBE
MtBE is a volatile, organic chemical. Since the late 1970's, MtBE has been used
as an octane enhancer in gasoline. MtBE promotes more complete burning of
gasoline, thereby reducing carbon monoxide and ozone levels. Hence, MtBE is
commonly used as a gasoline additive in localities that participate in the Winter
Oxygenated Fuels program and/or the Reformulated Gasoline program to achieve
or maintain compliance with the National Ambient Air Quality Standards. A
limited number of instances of significant contamination of drinking water with
MtBE have occurred due to leaks from underground and above ground petroleum
storage tank systems and pipelines. MtBE, due to its small molecular size and
solubility in water, moves rapidly into groundwater, faster than other constituents
of gasoline. Public and private wells have been contaminated in this manner. Non -
point sources, such as recreational watercraft, are most likely to be the cause of
small amounts of contamination of surface waters. Air deposition through
precipitation of industrial or vehicular emissions may also contribute to surface and
ground water contamination. The extent of any potential for build-up in the
environment from such deposition is uncertain.
This Advisory
The EPA Office of Water is issuing this Advisory to provide guidance for
communities that may be exposed to drinking water contaminated with MtBE. The
Advisory provides an analysis of current health hazard information and an
evaluation of currently available data on taste and odor problems associated with
MtBE contamination of water, as the latter affect consumer acceptance of the
water resource. This Advisory does not recommend either a low -dose oral cancer
risk number or a reference dose (RfD)' due to certain limitations of available data
' Reference Dose is defined as "an estimate (with uncertainty spanning approximately an order of magnitude) of a
daily exposure to the human population (including sensitive subgroups) that is likely to be without appreciable risk of
deleterious effects over a lifetime" (U.S. EPA, 1987).
December 1997

for quantifying risk. Guidance is given on the concentrations at which taste and
odor problems likely would be averted, and how far these are from MtBE
concentrations at which toxic effects have been seen in test animals. (The measure
used is called a "margin of exposure" or MoE. For instance, if a measured
concentration is 100,000 times less than the range of observation of effects in test
animals, the margin of exposure is 100,000.
Conclusion and Recommendation
This Advisory recommends that keeping levels of contamination in the range of 20
to 40 µg/L or below to protect consumer acceptance of the water resource would
also provide a large margin of exposure (safety) from toxic effects.
Taste and odor values are presented as a range, since human responses vary
depending upon the sensitivities of the particular individual and the site -specific
water quality conditions. These values are provided as guidance recognizing that
water suppliers determine the level of treatment required for aesthetics based upon
the customers they serve and the particular site -specific water quality conditions.
There are over four to five orders of magnitude between the 20 to 40 µg/L range
and concentrations associated with observed cancer and noncancer effects in
animals. There is little likelihood that an MtBE concentration of 20 to 40 Ag/L in
drinking water would cause adverse health effects in humans, recognizing that
some people may detect the chemical below this range. It can be noted that at this
range of concentrations, the margins of exposure are about 10 to 100 times greater
than would be provided by an EPA reference dose (RfD) for noncancer effects.
Additionally, they are in the range of margins of exposure typically provided by
National Primary Drinking Water Standards under the Federal Safe Drinking Water
Act to protect people from potential carcinogenic effects.
When adequate data become available, the Office of Water will publish another
Advisory that includes quantitative estimates for health risks. This Advisory gives
practical guidelines for addressing contamination problems and supersedes
previous draft advisories. An Advisory does not mandate a standard for action.
Studies of MtBE Effects
There are no studies of effects on humans of long-term exposure to MtBE. All of
the studies available for hazard assessment are laboratory animal studies.
Cancer effects. There are studies in rodents of the carcinogenicity of MtBE, as
well as its metabolites, tertiary- butyl alcohol (TBA) and formaldehyde. The only
oral cancer exposure study was conducted by Belpoggi and coworkers (1995).
2

They gave MtBE to Sprague-Dawley rats (gavage in olive oil, at doses up to 1,000
mg/kg/day, 4 days per week for two years). Exposure caused a dose -related
increase in the incidence of combined leukemia and lymphomas in the female rats
and an increase in Leydig cell adenomas (benign testicular tumors) in the high -dose
male rats. Use of this study to quantitatively assess risks from drinking water
exposure has limitations. There are potential differences in bolus versus drinking
water exposures and possible vehicle (olive oil) effects. Moreover, there are few
details on the actual reported tumor response data provided in the report. The lack
of histopathological diagnoses and of individual animal data were reasons that the
National Research Council panel recommended not using these tumor data in risk
estimation until after a thorough peer review of this study.
There are two studies on the potential carcinogenicity of MtBE after inhalation
exposure.
Chun et al. (1992) administered MtBE to F344 rats at concentrations up to 8,000
ppm for 2 years. Exposure to MtBE caused an increase in the incidence of
combined renal tubular adenomas and carcinomas, as well as Leydig cell adenomas
of the testes in the male rats. The mild induction of a-2u-globulin by MtBE
suggested that this protein may have played a role in male rat kidney tumorigenesis.
The increase in the incidence of Leydig cell adenomas of the male rats in this study
was not significantly different from the historical control value, although the
difference from the concurrent controls was significant. Induction of Leydig cell
tumors was also observed in Sprague-Dawley rats after oral exposure by gavage
(Belpoggi et al., 1995) and lends support to the conclusion that the appearance of
the tumor in both studies is treatment -related.
In the other inhalation study, Burleigh-Flayer et al. (1992) gave MtBE to CD-1
mice at concentrations up to 8,000 ppm for 18 months. This exposure was
associated with a statistically significant increase in the incidence of hepatocellular
carcinomas in male mice and of hepatocellular adenomas in female mice. , The
Chun et al. (1992) and the Burleigh-Flayer et. al. (1992) studies currently cannot
be used to calculate adequate hazard advisory values since we have no well -
developed pharmacokinetic model for converting a chronic inhalation exposure of
MtBE to an equivalent oral exposure. On -going work may support route -to -route
extrapolation in the future.
The potential carcinogenicity of two metabolites of MtBE, TBA and formaldehyde
has also been examined. In F344 rats, TBA has provided some evidence of
carcinogenic activity in the males (but not in the female rats). In B6C3F1 mice,
TBA exposure gave equivocal evidence of carcinogenic activity in male mice based
on marginally increased incidence of thyroid tumors, and some evidence of
carcinogenicity in female mice, based on an increased incidence of follicular cell
hyperplasia and follicular cell adenomas of the thyroid gland. Data for
3

r
carcinogenic activity is ambiguous for drinking water exposure to formaldehyde. A
study by Soffritti et al. (1989) reported a dose -related increase in the incidence of
leukemia and intestinal tumors in Sprague-Dawley rats. However, the
experimental data presented in this publication was limited. Another drinking
water study on formaldehyde by Til and coworkers (1989), using Wistar rats,
found no evidence of carcinogenicity.
The carcinogenicity data support a conclusion that MtBE poses a potential for
carcinogenicity to -humans at high doses. The data do not support confident,
quantitative estimation of risk at low exposure due to the limitations described
above.
Noncancer toxicity. The collective evaluation of the reproductive and
developmental studies of MtBE in animals indicate that inhalation exposure can
result in maternal toxicity and adverse effects on the developing fetus (Bushy Run
Research Center, 1991, 1989a, 1989b; Conaway et al., 1985). The fetal toxicity in
the mouse developmental studies indicate that it may be more sensitive to
inhalation of MtBE vapors than the rat or rabbit during gestation. However, it is
possible to conclude that, at low concentrations, MtBE does not cause a
developmental or reproductive hazard by inhalation in three different animal
species. This also suggests that humans may not be at risk when exposed to very
low concentrations of MtBE.
Effects on the kidney were observed in rats after oral and inhalation exposure to
MtBE. The most pertinent noncancer toxicity data come from a 90-day oral
exposure study in rats. The authors reported minimal effects on the kidneys at
doses of 300 mg/kg/day and above (Robinson et al., 1990). In these animals, the
MtBE was given once a day, as a bolus dose in corn oil. A single oral dose of
MtBE in corn oil would not be considered representative of an intermittent
exposure to MtBE that one would normally obtain from drinking water containing
MtBE. In a longer term inhalation study, histopathological abnormalities were
apparent (Chun et al., 1992). Uncertainties exist in quantifying risk from the oral
data in the short-term study because of the bolus gavage dosing regime and the
less -than -lifetime duration of the study. The uncertainty in extrapolating between
routes affects the interpretation of the inhalation data.
The studies support a conclusion that MtBE can pose a hazard of noncancer effects
to humans at high doses. The data do not support confident quantitative
estimation of risk at low exposure.
Taste and Odor. Studies were conducted on the concentrations of MtBE in
drinking water at which individuals respond to the odor or taste of the chemical.
Human responses vary widely in this respect. Some who are sensitive can detect
rd