NC0022187_Permit Issuance_20010730

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Ms. Nicola Ellis
Motiva Enterprises, LLC
2232 Ten -Ten Road
Apex, NC 27502
Dear Ms. Ellis:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
July 30, 2001
Subject: Issuance of NPDES Permit NCOO22187
Charlotte -North Terminal
Mecklenburg County
Division of Water Quality (Division) personnel have reviewed and approved your application for renewal of the
subject permit. Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9, 1994 (or as subsequently amended). Please note the
following changes from your draft permit, some of which are the results of the Paw Creek hearing officer's
recommendations and others of which are in response to the comments submitted by the facility. T
• pH monitoring and limits have been removed from your permit. This was an error made in all of the w 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 NME 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 from your permit. 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.
• The monthly monitoring for fluorene and phenantherene has been removed from your permit. EPA Method
625 will provide data for these parameters.
• The permit limit for manganese has been removed from your permit. Manganese is commonly found in the
natural environment. The intent of the manganese monitoring requirement is to indicate the efficacy of the treatment
system and so a limit is not warranted.
• The monitoring frequency for 1,2 Dichloroethane has been reduced to quarterly. This reflects a
change in the general permit requirements for the discharge of remediated groundwater. Moreover,
data from your facility have shown no detects for 1,2 Dichloroethane.
As concerns the monitoring requirements for turbidity and total suspended solids, these are a continuation
of monitoring requirements initiated through an administrative letter in 1999. The 1996 review of the oil terminal
permits across the state of North Carolina revealed large variation in the requirements for monitoring of
suspended solids. As a result, the requirement for all of these permits was changed to monthly total suspended
solids monitoring with a TSS limit of 45 mg/L. Following the issuance of the permits in Paw Creek, the
Environmental Protection Agency (EPA) expressed concern regarding anti -backsliding and the removal of the
turbidity monitoring requirement. In February 1999, an administrative letter was mailed to 12 of the 14 Paw Creek
facilities requiring quarterly turbidity monitoring. For the 2001 renewals, these data were used in reasonable
N. C. Division of Water Quality 1 NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state. nc.us DENR Customer Service Center: 1 800 623-7748

potential calculations. If a facility demonstrated reasonable potential to violate the stream standard of 50 NTU,
then monthly monitoring and a limit of 50 NTU were added to the permit, as in the case of your facility.
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.
Sincerely,
4rr
cc: Mooresville Regional Office/Water Quality Section
NPDES Unit
Central Files
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Department of Environmental Protection
Mr. Eric G. Hetrick Applied Earth Sciences, Inc.
814 Davidson Road
Concord, North Carolina 28025

It
Permit NCO022187
_ ..STATE OF. NORTH CAROLINA . .
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended,
Motiva Enterprises LLC
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte -North Terminal
410 Tom Sadler Road
Paw Creek near Charlotte
Mecklenburg County
to receiving waters designated as an unnamed tributary to Gum Branch in the Catawba River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III and IV hereof.
This permit shall become effective September 1, 2001.
This permit and authorization to discharge shall expire at midnight on ,Tune 30, 2005.
Signed this day July 30, 2001.
Kerr T. J" , erector // /
Divisio Wa r Quality y
By Authority f the Environmental Management Commission

is hereby authorized to:
1. continue to operate the existing water pollution control system consisting of
• an oil/water separator
• a groundwater remediation system
• a detention pond
located at the Charlotte -North Terminal, 410 Tom Sadler Road, Paw Creek, 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.

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Motiva Enterprises, LLC
Charlotte -North Terminal
State Grid/Quad: F15SW / Mountain Island Lake, NC
Latitude: 35° 16' 19" N
Longitude: 800 56' 10" W Permitted Flow: not limited
Receiving Stream: UT to Gum Branch Drainage Basin: Catawba River Basin
Stream Class: WS-IV Sub -Basin: 03-08-34
Facility
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North
NPDES Permit No. NCO022187
Mecklenburg County

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APPLIED EARTH SCIENCES - CAROLINAS, IC. E NMOTIVA ENTERPRISE ' ' ' FIGURE
Facility No. 20-506-5001
Mode •B.P. Date:2-12-Di 410 Tom Sa l,er.. SITE MAP I
069-00093-01 �'' � .,RQAId� :==�:��� •.: {
Checked By:E.H. File:003-01 Charlotte, North Carolina..'

Permit NCO022187
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS =
-= During the'period beginning on the effective date of the permit and lasting until expiration; the Permittee
is authorized to discharge stormwater and treated groundwater from outfall 001. Such discharges
shall be limited and monitored by the Permittee as specified below:
kC]EI RAC.TERISTICS
#E�
i An XIT
Aont ; y
Average��
, ai y
Maxii num�reguencY
-k easurement�
� amp a
�,T P F
ample ocation
W' �.
Flow
Episodic
Effluent
Total Suspended of s
30.0 m
Monthly
raEffluent
Oil and Grease2
Monthly
raEffluent
Turbidity3
Monthly
Cirab
Effluent
Phenol
Monthly
ra
uent
Benzene
1 19 µgo,
Monthly
Ettluent
o uene
11.0 µg/L
Monthly
ra
uent
Ethyl enzene
Monthly
Cirab
Etfluent
y ene
Monthly
ra
went
et y ert- uty ter
(MTBE)4
Monthly
raEffluent
Lead
ont y
Urab
Effluent
1,2 Dichloroethane
uarter y
Effluent
EPA Method
Semi-annually
Effluent
Iron
Monthly
raEffluent
Manganese
Monthly
raEffluent
Acute Toxicity
—Annually
ra
uent
Footnotes:
1. Flow — During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow must be monitored with each discharge and may be
monitored in one of four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; 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.
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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.

vermit NL;uuv,:zizst
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 NC0022187
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) and (2), monthly monitoring of MTBE for the duration of the permit is
required.
2. After one year of monthly monitoring or once twelve data points have been collected, the
Permittee shall review the MTBE data collected. If MTBE has not been detected in any samples
taken during the first year, the facility may request that the monitoring frequency for MTBE be
reduced. This should be done by requesting the NPDES Unit to perform a minor modification to
the NPDES permit. In the case in which MTBE has been detected within the first year of
effluent sampling, the subject facility must submit an MTBE reduction plan. This action plan
may include site -specific BMPs or engineering solutions. A copy of this plan should be
submitted to:
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
3. By the time of the next permit renewal, it is anticipated that surface water criterion for MTBE
will be established. This criterion will be used in conjunction with the facility's effluent MTBE
data to perform a reasonable potential analysis (RPA). The RPA will determine whether effluent
from a facility has the potential to exceed a water quality standard or criterion, thereby requiring
a water quality limit in the NPDES permit.

* ,{TRiE �V I~TO BE HELM BYE (✓'- �1
I`46,cldAnbu THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
1-'llt'l�l� SUBJECT: A public hearing has been scheduled concerning Me�proposed renewal and issuance of
the following NPDES Permits:
- Permitnumber NCO021962 to CITGO Petroleum Corporation for the Paw Creek Terminal located in
Charlotte, N.C. Charlotte (Mecklenburg County) for the discharge of stormw iter into an unnamed tributary to Gum
Branch.
AFFI&AVITOFPUBLICA1
- Permit number NC0022187 to Motiva Enterprises for the Paw P.reek Terminal located in CharlotteNORTH CAROLINA (Mecklenburg County) for the discharge of stormwater and remedied groundwater Into an unnamed
MECKLENBURG COUNTY tributary to Gum Branch.
Befom0. undersigned, Notary l - Permit number NCO032891 to Philips Pipe Line Company for the Chorale Terminal located in
Nodh Carolina, duly commissioner Charlotte (Mecklenburg County) for the discharge of Stormwater into an unnamed tributary to Gum
law to administer oaths, personalty Branch.
Shelby J. Curarn - Permit number N00074705 to William Terminals Holdings,I.P. far tie Chadotte/Southem Facilities
Terminal located in Charlotte (Mecklenburg County) for the discharge of stermwater into an unnamed
THE MuArknh,rg TINES, a nev tributary to Paw Creek.
entitled aasecond-daaa mail in the - Permit number NC0004723 to Valero Marketing 6 Supply Commpany for the Valero Marketing 8
and Statrdrathe/she is authorizedti Supply Facility located in Charlotte (Mecklenburg County) for the discharge of stonnwater into an
ataamenn; drat the notice or other It unnamed tributary to Paw Creek.
NOTICE OF PUBLIC } - Permit number NC0005771 to TransMontaigne Terminating, Inc. forthe Charlotte/Paw Creek Termi-
nal #1 located in Charlotte (Mecklenburg County) for the discharge of stormwater into an unnamed
TO IBE HELD BY THE tributary to Paw Creek.
ENVIRONMENTAL MAN/ - Permit number NCO021971 to TrarlsMontaigne Terminating, Inc $or the Charfotte/Paw Creek Tem*
nal #2 located in Charlotte (Mecklenburg County) for the discharge of stornwater into an unnamed
tributary to Paw Creek -
- Permit number NCO031038 to Colonial Pipeline Company for the Charlotte Delivery Facility located
a true ."ofwhwha attached herd in Charlotte (Mecklenburg County) for the discharge of stonnwater into an unnamed tributary to Gum
lenhurg TINES ES on the following ds Branch.
March 16, 2001 - Permit number NCO046213 to Marathon Ashland Petroleum, LLC for the Marathon Ashland Petro-
leum facility, located in Charlotte (Mecklenburg County) for the. discharge of stornwalerinto an on -
and that lfhe said newspaper in which named tributary to Long Creek.
or legal advertisement was publish, - Permit number N00046531 to Crown Central Petroleum Company for the Paw Creek Terminal
every suds, publication, anewspaper located in Paw Creek (Mecklenburg County) for the discharge of stoe+mvater into an unnamed tributary
and quayations of Section 1-597 r to Gum Branch.
Carolina acid was a qu dified.—p , - Permit nughber NCO046892 to Motiva Enterprises, LLC for the Charlotte Terminal located in Paw
tion 1-597 ofthe General Statutes o Creek (Mecklenburg County) for the discharge of stonnwater and remediated groundwater to an
This 16th day of M. unnamed tributary to Long Creek.
ii
- Permit number NC0004839 to Exxonl Refining 8 SupplyCompany for the Charlotte Terminal
located in Chanotte (Mecklenburg County) for the discharge of stonnwater and remediated groundwa-
G/ ter to an unnamed tributary to Long Creek.
Sworn to and subscribed b ro i., -Permit number N00005185 to Williams Terminals Holdings, LP. for the Paw Creek Terminal located
in Paw Creek (Mecklenburg County) for the discharge of stormwatee to an unnamed tributary to Long
16th. dayuf March 20l Creek.
PURPOSE: Each of these facilities has applied for renewal of their NPDES permit for the discharge
of treated stonnwater and/or remediated groundwater into waters cf the Catawba River basin. On the
Notary Pabtii basis of preliminary staff review and application of ArSde 21 of Ghaptler 143, General Statutes of North
Carolina, and other lawful standards and regulations, the North Cahrofina Environment Management
*01My Coeriaeion Expires: % I7 Commission proposes to issue a NPDES Permit for each facility subject to specific pollutant limitations
and special conditions. The Director of the Division of Water Quality pursuant to NCGS 143-215.1(cx3)
and Regulations 15 NCAC 2H, Section .0100 has determined that tt is in the public interest that a meeting
be held to receive all pertinent public comment on whether to Issue, arrodify, or deny the permit.
PROCEDURE: The hearing will be conducted in the following marsrer:
1. The Division of Waiter Quality will present an explanation of the North Carolina Environment
Management Commission's Permitting procedure.
2. The applicant may make an explanation of the action for which each permit is required.
3. Public Comment - Comments, statements, data and other infontaabon may be submitted in writing
prior to or during the meeting or may be presented orally at the meeting. Persons desiring to speak will
indicate this intent at the time of registration at the meeting. So that all persons desiring to speak may do
so, lengthy statements rfiay be limited at the discretion of the meeting officer. Oral presentatoms that
exceed three minutes should be acxompamed by three written copies, which will be filed with Division
staff at the fine of registration.
- - — - 4. Cross examination of perspns presenting testimony will not be allowed; however, the hearing
officer may ask questions for clarification.
5. The healing record may be closed at the conclusion of the meeting.
WHEN: April 19- at 7:00 p.m.
WHERE: Ctartotte-Mecklenburg Govemment Center
600 East Fourth Street, CH-14
Chadctte, North Carolina
INFORMATION: A copy of the drat NPDES pernri (s) anda map shoieing the location d the dlscharge(s)
are available by -writing ar calling,
Ms. Christie Jackson
NO Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Telephone number: [phone], extension 538
The applica5ons and other information are on file at the Division of 4Yater Quality, 512 North Salisbury
Street, Room 925 of the Archdale Building in Raleigh, North Carolina and at the Division's Mooresville
Regional Office (919 North Main Street in Mooresville, NC). They may be inspected during normal office
.hours. Copies of the information on file are available upon request and payment of the costs of
reproduction. All such comments and requests regarding this matter should make reference to the
permit number(s) listed above.
95084 Mar 16

DIVISION OF WATER QUALITY
_ Apri15, 2001
MEMORANDUM
TO: $KL:�,,Dave Goodrich;
FROM: D. Rex Gleason
PREPARED BY: Richard BridgemanWL
SUBJECT: Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
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- It is recommended that the effluent sample location be specified in all the permits.
Circumstances at one facility (at least) can be cited as justification for the
recommendation. The permit description of the water pollution control system (WPCS)'
for Colonial Pipeline Co. (NC0031038) includes a retention pond. This pond is also
mentioned in the Fact Sheet. Regardless of the 7Q10, 30Q2, and average flow data, this
pond is actually an impoundment fed by three UT's to Gum Branch. According to the
terminal manager; there is flow in these UT's to Gum Branch 12 months per year. The
effluent from the CITGO (NC0021962) facility is discharged to one of the UT's.
Stormwater runoff from at least one other terminal site may also enter the impoundment.
Effluent samples are collected at the outfall for the impoundment.
As discussed above, in addition to the sample collection location, the Colonial Pipeline
Co. (NC0031038) permit needs to be reviewed to determine if it is appropriate to include
the impoundment of a UT to Gum Branch as a treatment unit (retention pond).
- Consistency is needed in specifying source of wastewater to WPCS.
There are four different methods used in the draft permits, as follows:
Source not specified anywhere.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet,
_ which describes the WPCS and/or specifies outfall.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet that.--------.-.
specifies receiving water.
Source indicated in Part I, Section A(1) of permit (Effluent Limitations and
Monitoring Requirements Sheet).
The writer's preference, in part because several of the facilities have multiple outfalls, is
to indicate sources on both the Supplement to Permit Cover Sheet (in paragraph which
describes the WPCS and/or outfall) and in Part I, Section A(1). An example of the
writer's preference is in the permit for Motiva Enterprises, LLC (NC0046892).

Dave Goodrich
Page Two
April 5, 2001
Flow measurement/reporting frequency is recommended to be episodic (as in permit
Motiva Enterprises, LLC (NC0022187).
For several design reasons, discharge events basically occur on an as -needed basis; a
decision is usually made when there will be a discharge through an outfall. The only
exception may be Outfall 002 included in the permit for ExxonMobil Refining and
Supply (NC0004839), which is for a groundwater remediation system without any flow
retention capability, and, therefore, subject to daily discharges. Since discharge events
are mostly manually precipitated and occur randomly or as -needed, the range of the flow
data at a facility may vary considerably. Flow data seems to have played a large role in
the development of effluent limits (as in reasonable potential analysis for phenols), and
yet historically flow measurement methods and data have been two of the evaluations of
a compliance inspection subject to much scrutiny and criticism. Given the flow
measurement options specified in the permits, the small number of discharge events
probable each month, the importance of flow data, and the possibility of a wide range in
the flow data, it is not unreasonable to expect flow to be measured and reported for each
flow event.
The Turbidity monitoring requirement does not seem to be complete.
The permits, with two exceptions (discussed under the next item), include either a
quarterly monitoring -only requirement or a monthly monitoring requirement with an
effluent limit. It is not understood how the effluent turbidity monitoring requirement
correlates with the relevant footnote in Part I, Section A(1). Should there not also be an
upstream and downstream monitoring requirement. In fact, those facilities with a
monitoring -only requirement need only conduct stream monitoring to determine if
effluent turbidity levels result in stream standard violations.
One of the exceptions mentioned above under the item for Turbidity Monitoring is
Marathon Ashland Petroleum, LLC (NC0046213). Although the permit cover letter
indicates that the permit includes a monthly monitoring requirement and an effluent limit,
Part I, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring -only
requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is
being required because of the near potential for a stream standard violation. The other
exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being
required because none of the previously required monitoring has been conducted.
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 7Q 10, 30Q2, and average stream flow of zero, and the sixth
facility discharges to a stream having a 7Q10 and 30Q2 flow of zero and an average flow
of <1, it is hard to understand the assigned limits. The 3 mg/L Phenol limit for Outfall
002 in the ExxonMobil (NC0004839) permit is almost unimaginable.
Motiva Enterprises, LLC (NC0022187) — The Fact Sheet indicates that there is a
reasonable potential for the stream standard for Lead to be violated, but indicates that no
limit will be assigned because lead is an action level pollutant. A change? If not, should
there be a Lead limit in permit?
TransMontaigne Terminaling, Inc. (NC0021971) — Permit Cover Sheet indicates that
discharge is to Paw Creek. As indicated elsewhere in permit, discharge is to a UT to Paw
Creek.
Williams Terminals Holdings, L.P. (NC0074705) — The permit description includes an
oil/water separator, a carbon filter, and a holding tank. The Fact Sheet indicates that
wastewater and stormwater are routed to a retention pond and released as needed. No
staff report or compliance inspection report mentions this retention pond. MCDEP staff
has confirmed that there is no retention pond at the site.
Valero Marketing & Supply Co. (NC0004723) — Please review discussion in Fact Sheet
concerning the assignment of a Turbidity limit. If the average turbidity value in the past
1.5 years is 7.2 NTU and the maximum 28 NTU, why is there a prediction of a maximum
of 110.3 NTU?
Williams Energy Ventures (NC0005185) — Permit Cover Sheet indicates that discharge is
to a UT to Gum Branch; as correctly identified on the Supplement Sheet, it is a UT to
Long Creek.
Motiva Enterprises, LLC (NC0046892) — Fact Sheet indicates that the Flow requirement
for Outfall 002 in the previous permit will remain unchanged. There was a Flow limit in
the old permit, but not in the draft permit. The writer does not recommend a limit.
Please advise if you have questions or comments.
:_U

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
WATM ry rar nv Sir,.noN.
APR � u 221
Nmr)iwharge PeffnI ng
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 stornwater 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 • [phone] 0 Fax [phone]

- - = Mr: Dave Goodrich-
--,.., .
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 2
The permits require quarterly turbidity monitoring at the effluent. The permits do not
require upstream or downstream monitoring for turbidity. Without instream monitoring
requirements, compliance cannot be determined.
Individual Facility Comments - - -
• Williams Terminals Holdings, L.P. - Permit # NC0074705
An error was noted on the fact sheet for this facility. The background section refers to a
detention pond which is used to hold wastewater prior to discharge. MCDEP has
determined that the treatment works for this facility do not include a detent' n pond.
• Exxon Mobil Refining and Supply Company - Permit # NC0004839
Outfall 001-
The daily maximum permit limit for benzene is listed as 1.2µg/l. The North Carolina
water quality standard for WS-IV waters is 1.19µg/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 71.4,ug/1 and
toluene concentration is less than 1 l,ug/l." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19�zg/l.
• Colonial Pipeline Company - Permit # NC0031038
Y . MCDEPs past inspections of this facility indicate that the retention pond located on -site
receive§ flow from theee intermitient streams. While the streams are classified as ;
intermittent by USES, 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.

0
Mr. Dave Goodrich:.
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 3 -
If you have any questions regarding these comments, or any other matters, please feel free to give
me a call at 704/336-5500. Thank you.
Sincerely, .7
G
Rus ozzelle
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
WII13AM Il. vVCATITUT U100 i
Szecuta: poses
May 2, 2001
COUNCIL
1 r CIL
A 04&16n of rile American Ae&acwn lnstift'
surrE 285D • 150 FAYUMVILLE ST. MALL
RALE10H. NC 27601
010/528-5436 6 FA f G10/821.0=7
Mr. Rick Shiver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Ext.
Wilmington, NC 28405-3845
Re: NPDES Pcrrnit Renewals
Paw Creek Petroleum Pipeline and Distribution Terminals
Charlotte (Mecklenburg Coimty), North Carolina
Dear Mr. Shiver: .
Thank you for.the professional manner in which the public hearing on the petroleum terminals'
NPDES permits was conducted in Charlotte on April 19, 2001.
The purpose of this letter— which 1 request be included in the official hearing record — is to
express my members' strong concern about the way MTBE is being addressed in the terminals'
draft permits.
The North Carolina Petroleum Council — a division of the American Petroleum Institute, the
trade association for the nation's major fuel suppliers -- is committed to insure that the
opportunity for public: hearings and comment is an integral part of govenunent decision -making -
So we simultaneously praise the process that allows us to submit this statement for the record,
while we point with alarm to the proposed MTBE limit of 11-6 ug/L that has been included in the
draft permits without a single hearing or any official review by a ndemaking body.
We asked the Department (DENR) to help us understand how this limit came about. We were
told that there is no surface -water standard for MTBE. Further, we were advised that the
proposed MTBE limit has not been endorsed by the Environmental Management Commission
has not been debated by those publicly appointed members - has not been the subject ofpublic
hearings at all. In fact, the EMC recently dealt with the matter of WBE and voted not only to
reject a request for a temporary groundwater standard of 70 ppb, but also to reaffirm *the vaiuc of
public hearings by calling for a permanent rulemaking process to tighten the MTBE groundwater
aiyd 3 . Soo as -M Ili Wwait 13W tunas ns tha pwavasal, we are now confronted with

Sent By:
919 821 0337; May-2-01 16:32;
Mr. Dick 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 year 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
MTBE groundwater standard of 70 ppb have now changed their minds! What had been a
certainty one month was abandoned the next in favor of a new calculation — and a new limit
level. So, if public health considerations arc truly moving this fast, 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 mare appropriate and needed to ineure that the calculations of
today are not abandoned tomorrow.
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. Tucking 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 monitoring by
each of the terminals will provide the needed representative data to form the basis for future
decision -making.
Sincerely,
f
William H. Weatherspoon
c: Ms. Natalie Sierra

SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS,":
CONTAMINANT
CAS #
"C" & "B" WATERS
(ug/l unless noted
otherwise)
11WS-1" - "WS-V"
WATERS
WATERS (ug/i unless
noted otherwise)
SOURCE OF STANDARD.
OR CRITERIA }
BENZENE
71-43-2
71.4
1.19
71.4
15A NCAC 2B .0211-.0222
n-BUTYL BENZENE
1104-51-8
36
36
36
ECOTOX 4/98
sec -BUTYL BENZENE
1 135-98-8
41
41
41
ECOTOX 4/98
CHLOROFORM
67-66-3
470
5.7
470
EPA 4/22/99
ETHYL BENZENE
1100-41-4
383
524
130
ECOTOX 1/01
IPE
i 108-20-3
19 mg/L
19
330 mg/I
ECOTOX 1/01
ISOPROPYL BENZENE
! 98-82-8
316
186
4.6 mg/I
ECOTOX 1/01
p-ISOPROPYL BENZENE
r 99-87-6
325
325'
1.1 mg/I
ECOTOX
METHYLENE CHLORIDE
1 75-09-2
1600
4.7
1600
EPA4/22/99
MTBE
1634-04-4
2393
11.6
2393
NC DHHS 7/11/00
NAPHTHALENE
i 91-20-3
105
43'
64
ECOTOX 1/01
n-PROPYL BENZENE
i 103-65-1
77.5
77.5
190
ECOTOX 1/01
1,2,4-TRIMETHYLBENZENE
95-63-6
386
72
218
ECOTOX 1/01
1,3,5-TRIMETHYLBENZENE
108-67-8
626
100
215
ECOTOX 1/01
TOLUENE
108-88-3
11 (0.36 Tr)
11 (0.36 Tr)
185
15A NCAC 213.0211-
.0222/ECOTOX 8/99(SW)*
XYLENE, TOTAL
1330-20-7
88.5
88.5
1370
ECOTOX 1/01
i.
Criteria which have a source of EPA ECOTOX were developed using EPA's ECOTOX database per 15A NCAC 2B .0208.
Last update 2/2/01 (DMR) These concentrations are updated regularly.
Questions or criteria for other parameters not found in the 15A NCAC 2B .0200s can be addressed to Dianne Reid at
919.733.5083 extension 568 ([e-mail]) OR Jason Wynn ext. 351 ([e-mail])
s;
i;
i.
s

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.
I. Minimum Requirements for ALL Oil Terminal Facilities
A. Flow
Episodic Monitoring (monitor with each discharge event)
Measurement of flow is to be representative of a discharge event. Many oil terminal facilities
have storage ponds to collect runoff and therefore, discharges may not always occur during
storm events. Flow should be monitored by one of the following methods:
1. Measure flow continuously, or
2. Calculate flow based on the area draining to the outfall, the built -upon area, and the total rainfall,
using the rational equation (see below), or
3. Estimate by flow measurement at 20 minute intervals during the entire discharge event, or
4. Base flow on pump logs.
The rational equation: Q=KuCIA, where
Q = flow (peak flow rate (cfs or m3/sec)
Ku = units conversation factor = 1.008 for U.S. standard units (usually ignored because it is so close to
1), or 0.278 for SI units
C = dimensionless runoff coefficient for the watershed, loosely defined as the ratio of runoff to rainfall
I = intensity of rainfall taken from the intensity -duration -frequency curves for the specified design
return period at the time of concentration tc, (in/h or mm/h)
tc = time of concentration - time after the beginning of rainfall excess when all portions of the drainage
basin are contributing simultaneously to flow at the outlet
A = area of tributary watershed (acres or km2)
The rational equation is used to calculate the runoff from a region, given:
➢ the runoff coefficient which accounts for infiltration and other potential losses in the region,
➢ the rainfall intensity to the region,
➢ the time it takes for runoff to travel from the region's upper reaches to its outlet, and
➢ the region's drainage area.
For oil terminal facilities with large storage ponds that serve to collect runoff, item 2 listed above and the
rational equation should not be used because the calculations will determine the flow to the storage pond,
rather than the flow from the pond.
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Permit Requirements for Discharges from Oil & Petroleum Storage' Facilities
B., Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual
_- Monitor annually (assuming first five discrete storm events have already been monitored and:::_.
showed no toxic effects) L.
'Monitoring Footnote: acute toxicity monitoring should occur during collection of BTEX
parameters (see item E below)
Products stored at oil terminals may contain a variety of different chemicals (some of which may have
harmful or toxic effects). To verify that toxic chemicals are not discharged to surface water, a periodic
toxicity test will be required. An acute, rather than chronic, toxicity test is required because oil terminal
facility discharges are typically. short-term, episodic events. Specifically, an acute.24-hour pass/fail at 90%
waste concentration using fathead minnows is the recommended toxicity test for stormwater discharges.
Facilities that meet one or more of the following criteria will not qualify for annual monitoring and will
be required to monitor for acute toxicity during five storm events:
1. Facilities that have never monitored for acute toxicity during a storm event, or
2. Facilities that monitored for acute toxicity during four or fewer storm events during the last
permit period, or
3. Facilities that completed five acute toxicity tests during five storm events, but did not pass all
five tests.
Facilities that fail an acute toxicity test conducted during one or more of the five storm events or during an
annual monitoring event will be required to conduct quarterly monitoring for the forthcoming permit period,
and must receive State approval for reduced monitoring. For facilities that have not yet conducted acute
toxicity testing for the first five discrete storm events, a statement in the permits will allow for additional
toxicant limits should the toxicity test indicate toxic effects. At the time of permit renewal, only annual
monitoring for toxicity would be required if the facility has performed the five discrete sampling
requirements with no acute toxicity.
C. Total Suspended Solids
Monitor monthly
Daily maximum 45.0 mg/1
Historically, Total Suspended Solids (TSS) has not been a significant problem in stormwater discharges at
oil terminal facilities. A 1996 analysis of TSS data from five stormwater discharges indicated only one event
in excess of the previously permitted 30.0 mg/1 monthly average. A daily maximum limit of 45 mg/L is
recommended as a general indicator of stormwater quality. A daily maximum compliance period is given to
reflect the sporadic nature of these discharges. Should TSS monitoring data indicate any substantial
problems, the Regional Office or county may elect to enforce the instream standard for turbidity.
D. Oil and Grease
Monitor monthly - No Limit
Monitoring Footnote: Where possible, the grab sample for oil and grease should be skimmed from
the water .surface of a quiescent (calm water) zone.
- - Historically; oil and grease has not been a significant problem in stormwater discharges at oil terminal -
facilities. However, like TSS, oil and grease is a good general indicator of the quality of a stormwater
coming from a site. Where possible, oil and grease samples should be skimmed from the surface of a
quiescent zone closest to the discharge.
E. BTEX
Monitor monthly — No Limit
Benzene, toluene, ethylbenzene and xylene are toxicants commonly found in petroleum. The previous
permitting strategy for the oil terminals required the EPA 624/625 scan, which, among other contaminants
of concern (see Part II), detects BTEX compounds. A review of the discharge monitoring report data from
the previous permitting cycle indicates that these four contaminants frequently appear in stormwater from
terminal facilities. For the most part, the other volatiles and semi-volatiles detectable by the EPA 624/625
Page 2 of 8
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` Permit Requirements for Discharges from, Oil & Petroleum Storage Facilities
scan were never detected in the stormwater from these facilities.' By monitoring for BTEX and naphthalene
(see part F, below), the facilities are collecting data on those pollutants that are mostly likely to be present,
in' the water.
F.; EPA Method 625
Monitor semi-annually
The intent of this monitoring requirement is to monitor for naphthalene and other indicators of middle
distillate compounds detectable by Method 625. These contaminants are commonly found in heavy
fuels, such as diesel. During site visits of terminal facilities performed by members of the NPDES Unit,
it was observed that the majority of the terminals reserve at least one storage tank for diesel fuel.
Originally, facilities were to have monitored only for naphthalene, but since the most accurate method
of quantifying naphthalene is through Method 625 and other middle distillate compounds can be
detected through this scan, the entire results should be reported to the Division. '
If it can be demonstrated by the permittee that diesel fuel is not currently being stored on site, then the
monitoring requirement on the effluent page will have the following footnote:
*"Monitoring requirement applies only for facilities storing diesel or other heavy fuels on site."
G. Tank Solids, Tank Bottom Water, and Rag Layer
No direct discharge of tank solids, tank bottom water, or the rag layer is permitted.
There are typically four discrete layers of varying thickness within a storage tank. At the very bottom of the
tank is the solids layer that achieves a 1/2-1 inch thickness over a 5-6 year period. Immediately above the
solids layer is 1-6 inches of tank bottom water that results from rainwater breaching the wall seal in open
roof tanks. Open roof tanks are not.completely open, but have a roof floating directly on the product.
There is a seal between the tank walls and floating roof designed to prevent water from entering the tank.
Water breaching this seal and entering the tank is referred to as tank bottom water. The rag layer is at
most 3/4 inch thick and forms the interface between the tank bottom water and the product. The product
is the topmost layer and is 20-25 feet. Normally, the tank bottom water is removed from the tank when it
is 3-4 inches deep. The mixture of water and product in the rag layer is often drawn off when tank water is
removed because water entering tanker trucks must be minimized. As a result of potentially high levels of
organic compounds in the three bottom layers of storage tanks, they are not to be discharged, but instead
should be transported off -site for appropriate treatment and/or disposal or treated/recovered onsite if
treatment technology capabilities occur onsite.
H. Hydrostatic Testing
Hydrostatic testing of oil tanks normally occurs once every five to six years. Prior to the hydrostatic testing,
the tank is completely drained and tank bottom materials are handled as described in the previous section.
The tanks are completely cleaned and then coated and welded (if necessary). The tank is then filled with
water for the hydrostatic test. Some oil terminal facilities use stream or lake water to hydrostatic test their
tanks, while others use potable city water. Because the tank is thoroughly cleaned prior to refilling with
water for the hydrostatic test, water discharged from the tank following the hydrostatic test should be fairly
clean. However, tank discharges following hydrostatic testing may contain contamination. Therefore,
monitoring of the tank water prior to direct discharge will be required. There shall be no direct discharge
from oil terminal facilities following hydrostatic testing if concentrations of benzene and/or toluene are
greater than their respective water quality standards (see effluent pages at end of SOP for details).
I. MTBE Monitoring
Monitor monthly
Within the last year, the Environmental Protection Agency has recommended banning methyl tertiary butyl
ether (MTBE), an ingredient commonly used in gasoline to aid in the reduction of air pollution. MTBE was
originally added to gasoline in response to a 1990 law that required higher oxygen content in gas sold in the
most -polluted cities. It has since become a cause for concern since the EPA now believes that MTBE may
be a carcinogen and is seeking to outlaw the compound.
Since MTBE contamination of water is a public health concern, monthly MTBE monitoring will be added to
all facilities. For those facilities currently monitoring for MTBE, reasonable potential analysis will be
performed to assess the need for an MTBE limit. In non -water supply waters, the instream MTBE standard
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Permit Requirements for Discharges from Oil & 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
IL>;`Additional Site,. -Specific Requirements
A. EPA Method 624
Monitor semi-annually,
The entire 624/625 scan was originally included in the SOP to assess which of the petroleum -associated
organic chemicals are found in stormwater. These tests scan for volatile and semi -volatile organics and
cost approximately $700 to run (Ray Kelling, personal communication 2/ 14/01). Currently, the oil
terminal facilities are performing the scan twice a year. Most facilities obtain results consisting entirely of
non -detects, but a few have detected one or more of the compounds on the 624/625 list. Tables 1 and 2
summarize the compounds included in the scans and note those parameters detected during the last
permitting cycle. _
After a review of the data and discussions with different members of the Division of Water Quality Point
Source Branch, it has been decided to assign semi-annual monitoring using EPA Method 624 to any of the
facilities that detected any compound listed in Table 1 that is not benzene, toluene, ethylbenzene, xylene or
naphthalene (as these were found in most discharges and are covered by monitoring requirements listed
above).
Table 1. Compounds detectable by EPA Method 624
PARAMETER
Acrolein
DETECTED IN OIL TERMINAL STORMWATER?
Acrylonitrile
Benzene
J
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane
✓
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
Tetrachloroethene
-- -
Toluene - - _.....
1, 1, 1 -Trichloroethene
1,1, 2-Trichloroethene
Trichloroethane
Trichlorofluoromethane
J
Vinyl chloride
J -
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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:
Benzo a anthracene
Benzo b fluoranthene
Benzo k fluoranthene
Benzo a rene
Benzo(ghi)peiylene
Benzyl butyl phthalate
Bis 2-chloroeth 1 ether
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
✓
Fluoranthene
Fluorene
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Indeno 1,2,3-cd ene
Iso horone
Naphthalene
✓
Nitrobenzene
N-Nitrosodi-n-propylamine
PCBs
Phenanthrene
✓
rene
Toxa hene
1,2,4-Trichlorobenzene
4-Chloro-3-meth 1 henol
2-Chloro henol
2,4-Dichloro henoI
2,4-Dimeth 1 henol
2,4-Dinitro henol
2-Meth 1-4,6-dinitro henol
2-Nitrophenol
4-Nitrophenol
Pentachloro henol
Phenol
2,4,6-Trichloro henol
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
B: Reasonable Potential (General)
The reasonable potential procedure is a method used to determine the potential of a discharge to violate a
_ water quality standard for a given parameter based on existing data. If a parameter is determined to have
reasonable potential to violate a water quality standard,'a limit and monthly monitoring will be required. A
parameter is determined to have reasonable potential to violate a water quality standard if a calculated
maximum predicted effluent concentration is greater than the allowable effluent concentration.
Reasonable potential is determined by performing a statistical analysis for each parameter of concern that
has either a state or federal water quality standard. For each parameter, the statistical analysis works best
with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more
accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent
concentration based on the existing data set. A step-by-step procedure for determining whether or not a
parameter should be limited based on reasonable potential determination follows:
STEP
1. Determine the number of sample points (n) -
2. Determine highest value from data set. Best professional judgment should be used by the reviewer so
as not to use an outlier. Since an outlier will not be determined statistically, maximum values should
rarely be discarded in this analysis.
3. Determine the coefficient of variation (CV = STD DEV/MEAN)
4. Determine the appropriate multiplication factor to be used by comparing the number of samples versus
the co -efficient of variation (see Table 3-1)
5. Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to
obtain the maximum predicted effluent concentration.
6. Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable
effluent concentration, which is based on instream dilution and the corresponding water quality
standard. EPA recommends that permitting authorities find reasonable potential when the maximum
predicted effluent concentration is greater than the allowable effluent concentration.
A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet" and is
located on the NPDES server. The spreadsheet requires the input of the facility name and permit number,
the waste flow (Qw), 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.
III. Additional Monitoring Requirements for Water Supply (WS) Waters
A. Phenol
Monitor monthly
(Limit assigned if reasonable potential is demonstrated)
Phenol is a common component of petroleum compounds stored in terminals, can result in tainting of fish
tissue, and can cause taste and odor (organoleptic) problems in drinking water. In addition, phenol
discharged from terminals could combine with chlorine in water treatment facilities to form chlorinated
phenols. Limiting the discharge of phenol into water supply classified waterbodies could reduce
chlorinated phenol formation and their concentration in drinking water. As a result of the expected
occurrence of phenol in oil terminal facility discharges and the possibility of chlorinated phenol formation,
phenol will be monitored on a monthly basis in water supply classified waters.
Based on an extensive review and analysis of data collected during the last permitting cycle, the facilities
are no longer required to monitor for chlorinated phenols, since none were ever detected in oil terminal
effluent. The concern over limiting phenols lies in the need to inhibit formation of chlorinated phenolic
compounds at downstream water treatment plants. Joe Corporon of the NPDES Unit calculated an
allowable phenolic loading for each terminal in Mecklenburg County that will prevent a downstream
violation of the NC State standard for phenols of 1 µg/L. Meg Kerr wrote a similar memo for those
terminals in Guilford County in 1983. Reasonable potential will be performed using these allowable
phenolic loadings (see attached memo).
Be-_-. 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.
REFERENCES
Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering
News.
Kelling, Ray, (Division of Water Quality Chemistry Lab). June 1996. Conversations with P. Clark.
Kelling, Ray, (Division of Water Quality Chemistry Lab). February 2001. Conversations with N. Sierra.
Linville, Ron, (Winston-Salem Regional Office). March 1996. Telephone conversation with P. Clark.
Reid, Dianne, (Division of Water Quality - Planning Branch). June 1996. Conversations with P. Clark.
Shiver, Rick, (Wilmington Regional Office). July 2001. Findings and Recommendations for Public Hearing
Held on April 19, 2001.
USEPA. March 1991. Technical Support Document For Water Quality -Based Toxics Control. EPA/505/2-
90-001.
Page 8 of 8
Version 7/30/01

DENR/DWQ
FACT SKEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO022187
BACKGROUND
Mofiva Enterprises purchased the subject facility from Star Enterprises in September 1998. At the
time, the facility was only discharging stormwater collected in the diked areas surrounding the bulk storage
tanks. Water from the truck loading area drains to a holding tank and is hauled off -site. In December 1999, a
permit modification was issued that combined an existing general permit (NCG510177). for groundwater
remediation and. NCO022187 (for stormwater). The groundwater permit was rescinded and the discharges
combined under NC0022187. The 'facility now discharges both remediated groundwater and stormwater
through outfall 001. Prior to release, the two flows are combined and held in a containment basin. The water
is then manually released as needed.
FILE REVIEW
Correspondence
Correspondence files from August 1996-2000 were reviewed. During this time period, the
Mecklenburc, County Department of Environmental Protection (MCDEP) performed four inspections. The
facility received satisfactory ratings for all of these inspections. Grab samples taken during the MCDEP
compliance inspections indicate low levels of total suspended solids (TSS) and non -detects for the volatiles
and semi-volatiles detectable by the EPA 624/625 scan.
This facility is one of twelve in Paw Creek that received a February 22, 1999 letter requiring effluent
turbidity monitoring on a quarterly basis.
DNM Review:
DMRs were reviewed from August 1996 through January 2001. Discharges from 001 occur
approximately once per month; the mean flow for the period reviewed was 0.061 MGD. The maximum flow
(used below in the reasonable potential calculations) was 0.257 MGD. The addition of the groundwater
remediation effluent has increased the average flow by about 30%. Total suspended solids during this time
averaged 6.7 mg/L with a maximum of 33 mg/L. Oil and grease was not detected in the effluent (with
detection levels ranging from 0.5 mQ/L to 5 mg/L).
The twice -annual EPA 62A25 scan did not detect most of the semi-volatiles and volatiles tested.
There was one ethyl benzene detect of 6 ug/L in April 1998. The facility passed its acute toxicity test from
1997 — 1999; the organisms from the 2000 sample had an 86.1% survival rate (which does not appear to have
been counted as a "fail" by the Aquatic Toxicology Unit).
Fact Sheet
NPDES NCO022187
Renewal
Page 1

SinceMarch 1999, the facility has been required to sample for turbidity quarterly as per, an EPA -
directive. They have not sampled at all since this requirement was made.
Reasonable Potential Analysis:
Reasonable Potential Analysis was run for phenol, ethyl benzene, MTBE, manganese, iron, lead, and
toluene. All other measured parameters were not detected during the four and half year period of data review,
and therefore indicate no reasonable potential to cause a violation. Reasonable potential to violate NC
standards was found for the following:
• MTBE
• Manganese
• Iron
• Lead
Iron and lead are action level pollutants; since no toxicity violations have occurred, they will not be
limited.
PERMITTING STRATEGY
The permitting strategy for this and all oil terminals in the state is based upon a 2001 NPDES
document entitled, "Permit Requirements for Discharges from Oil and Petroleum Storage Facilities." This
document is based upon a 1996 SOP and has been updated after a data review and internal discussions. It
delineates monitoring frequencies and permitting limits for contaminants commonly found at these sites.
Below, it is referred to as the "2001 SOP."
Waste Load Allocation (WLA).
The last waste load allocation was performed. in 1994. The facility was not only under different
ownership, but only discharging stormwater. Turbidity, BTEX, MTBE, and naphthalene monitoring are
recommended along with phenol, TSS, and oil and grease limits.
Oil Terminal SOP:
The toxicity, TSS, and oil and grease requirements specified in the previous permit and the 2001 SOP
(Parts I.A. — I.D.) remain unchanged. The facility will be required to monitor monthly for the BTEX
parameters as per Part I.E. of the SOP. Since the DMRs indicated only a detect of ethyl benzene (monitored
through the BTEX requirement and not demonstrating reasonable potential) in the reporting of EPA Methods
624/625, this requirement will be removed as per Part II.A. of the SOP. Limits will be required for MTBE and
manganese duet to demonstration of reasonable potential (as per. Part II.B). As per parts I.G. and I.H. of the
2001 SOP, there can be no direct discharge of tanks solids, tank bottom water or the rag layer, and no direct
discharge of hydrostatic test water if concentrations of benzene and/or toluene exceed the water quality
standard. Part H.C. lists a requirement specific to the Paw Creek terminals — quarterly turbidity monitoring as
mandated by the EPA. Because this facility has not performed the turbidity monitoring as required, reasonable
potential cannot be assessed and monthly monitoring shall be assigned. The requirements of the groundwater
general permit (NCG5 1 0000are included in this permit as follows:
• Monthly lead monitoring
• Monthly 1,2 Dichloroethane monitoring
• Monthly fluorene monitoring
• Monthly naphthalene monitoring
• Monthly phenanthrene monitoring
• Monthly phenol monitoring
Monthly iron monitoring
• Monthly manganese monitoring
A December 2000 request for a permit modification put forth the suggestion that flow be monitored as
in all the permits for bulk oil storage in the state (Part I.A. of the SOP). This can be done, but the monitoring
frequency will be listed as "episodic" instead of monthly since there have been occasions when the facility
discharges two or more times in a given month.
SUMMARY OF PROPOSED CHANGES
• Addition of MTBE limit
• Addition of manganese limit
Fact Sheet
NPDES NCO022187
Renewal
Page 2

Addition of monthly turbidity monitoring
Removal of EPA Methods 624/625
Change flow requirement to episodic with sample type identical to that of the other bulk storage
facilities.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: March 14, 2001
Permit Scheduled to Issue: April 27, 2001
NPDES DIVISION CONTACT
I you have questions regarding any of the above information or on the attached permit, please contact Natalie
Sierra at [phone] ext. 551.
NAME:
REGIONAL OFFICE COMMENTS
DATE:
k(L) C 0 M M
NAME: //1�EUGu
i �D .
_. M AY - 2 2001
DFHR - W,1TEI IALIiY
P-OiMT L;jiL:7-'; H
DATE:
SUPERVISOR: DATE: G�
Fact Sheet
NPDES NCO022187
Renewal
Page 3

f
SOC PRIORITY PROJECT: Yes No X
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: April 11, 2001G��
NPDES STAFF REPORT AND RECOMMENDATION
0
om
County: Mecklenburg I o W W
00
MRO No.: 01-53
Permit No. NCO022187 !� N
PART I - GENERAL INFORMATION
1.
2.
3.
Facility and Address:
Ie:3 ¢ Uo
o�
Motiva Enterprises ��-v`773-�
410 Tom Sadler Rd.
Paw Creek, North Carolina 28214
Date of Investigation: 04-03-01
Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. Larry Couch,
Terminal Manager; [phone]
5. Directions to Site: From the junction of Highway I-85 and
Highway 27 in Charlotte, travel west on Highway 27 (Freedom
Drive) approximately three (3) miles to Old Mt. Holly Road.
Turn right onto Old Mt. Holly Road and travel approximately
0.2 mile to Tom Sadler Road. Turn left onto Tom Sadler Road
and travel approximately 0.2 mile. Motiva Enterprises is
located on the right (north) side of Tom Sadler Road.
6. Discharge Point(s). List for all discharge points:
Latitude: 35' 16' 59"
Longitude: 800 56' 10"
Attach a U.S.G.S. map extract and indicate treatment facility
site and discharge point on map.
USGS Quad No.: F 15 SW USGS Quad Name: Mountain Island
7. Site size and expansion are consistent with application?
Yes X No If No, explain:
8. Topography (relationship to flood plain included): Sloping
north toward an intermittent stream at the rate of 2 to 60.

4
The site is not located in a flood plain.
9. Location of nearest dwelling: None within 1000 feet of the
discharge point.
10. Receiving stream or affected surface waters: Unnamed
tributary to Gum Branch.
a. Classification: WS IV
b. River Basin and Subbasin No.: Catawba River Basin;
030834
C. Describe receiving stream features and pertinent
downstream uses: Discharge is into an intermittent
stream on the north side of the site. This stream
flows through an undeveloped area prior to merging with
a tributary to Gum Branch. There are several other
industrial and domestic wastewater discharges into Gum
Branch.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. a. Volume of wastewater to be permitted:
Discharge is intermittent depending on rainfall.
The types of fuels stored are regular unleaded, premium
unleaded and mid -grade gasoline (which is a mixture of
regular unleaded and premium unleaded), high sulfur
diesel, and low sulfur diesel. The permitted discharge
from the Groundwater remediation system is 0.0144 MGD.
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 an oil/water separator located below the
loading/unloading area and a pond constructed at the
NPDES Permit Staff Report
Page 2

lower end of the facility. The existing pond receives
runoff water from the entire site as well as from the
oil/water separator and the ground water remediation
system.
f. Please provide a description of proposed wastewater
treatment facilities: N/A
g. Possible toxic impacts to surface waters: Due to
nature of the wastewater there could be some toxicity
concern.
h. Pretreatment Program (POTWs only): N/A.
2. Residuals handling and utilization/disposal scheme: Tank
water bottom is handled by Four Seasons Environmental, tel#
704-527-1293. Tank solids are handled by Aaron Oil Company,
Tel# [phone].
3. Treatment plant classification: Class I.
4. SIC Code (s): 5171
Primary: 53
Main Treatment Unit Code: 53000
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant
Funds or are any public monies involved (municipals only)?
N/A.
2. Special monitoring or limitations (including toxicity)
requests: Acute toxicity monitoring is already included in
the permit.
3. Important SOC, JOC or Compliance Schedule dates: (please
indicate) N/A.
4. Alternative Analysis Evaluation: Has the facility evaluated
all of the non -discharge options available. Please provide
regional perspective for each option evaluated.
Spray irrigation: N/A
Connection to regional Sewer System: N/A
NPDES Permit Staff Report
Page 3

5. Air Quality and/or Groundwater concerns or hazardous
material utilized at this facility that may impact water
quality, air quality or groundwater? Contaminated
groundwater already exists at the site. Hazardous material
stored at the site may be a constant threat to the
groundwater. Air Quality Permits required by Mecklenburg
County.
PART IV - EVALUATION AND RECONblENDATIONS
The wastewater from Motiva Enterprise sales terminal is
treated by an oil/water separator, an oil storage tank, and a
settling pond prior to discharge into an unnamed tributary to Gum
Branch. From the oil storage tank the discharge travels
approximately 500 feet (on the ground) around the spill
containment area before entering the settling pond. The
discharge from the pond is controlled by an outfall control
valve, and the amount of discharge depends on rainfall. Storm
water is also directed to the pond via the storm water drainage
system. Also, discharge from the groundwater remediation system
permit # NCG510177 is being directed to the pond.
It is recommended that the NPDES permit for this facility be
renewed pending review by the Groundwater section.
ignature of
ti. Y �— u
Water Quali
reparer
Regional Supervisor
NPDES Permit Staff Report
Page 4
Date
Date

VIA AIRBORNE EXPRESS # 6356636053
May 23, 2001
M TIVA
ENTERPRISES LLC
Shell, Texaco & Saudi Aramco Working Together
,I
Ms. Natalie Sierra
c�
North Carolina Department of Environment and Natural Resources
CD
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Division of Water Quality — NPDES Unit
512 N. Salisbury St.
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Raleigh, NC 27604
e�
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o
Subject: Draft NPDES Permit - NCO022187
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Motiva Enterprises LLC — Charlotte North Terminal
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Charlotte, Mecklenburg County, North Carolina
Dear Ms. Sierra:
Per your e-mail dated April 26, 2001, Motiva Enterprises LLC (Motiva) hereby submits the following
comments addressing revisions to Draft NPDES Permit NCO022187 for our Charlotte -North Terminal in
Charlotte, North Carolina. As per my conversation with Ms. Valery Stephens on April 26, 2001, the
comment period for Motiva was extended to May 23, 2001.
Please change contact name/mailing address for the new permit to:
Ms. Nicola Ellis
Environmental Engineer
Motiva Enterprises LLC
2232 Ten -Ten Road
Apex, NC 27502
• Motiva refers to this facility as the Charlotte -North Terminal, due to the fact that Motiva operates two
facilities in the Paw Creek area. Please change all references to the facility name in the permit from
`Paw Creek Terminal' to `Charlotte -North Terminal';
Per your cover letter, turbidity monitoring has been added to all oil terminal facilities in the Paw
Creek area. The draft permit for this facility adds a monthly requirement for testing turbidity. Motiva
would like to request that the frequency of this monitoring be changed to quarterly. Motiva operates
another facility, referred to as the Charlotte -South Terminal in the Paw Creek area (NPDES Permit
No. NC0046892). The draft permit for the Charlotte -South facility requires quarterly turbidity
monitoring;
Motiva previously operated under two NPDES permits for this facility (NC0022187 & NCG510177).
Since the permits were combined into one permit in January, 2000, the average MTBE effluent
concentration is calculated to be 12.5 ug/L. This average value is in excess of the proposed permit
limit value of 11.6 ug/L. Of the 15 discharge sampling events since the combination of the permits,
seven would be in excess of the proposed limit value. Motiva requests that the limit for MTBE be
raised to 25.0 ug/L to more accurately designate what the facility will be able to maintain compliance
with.
2232 Ten Ten Road Apex, NC 27502 Phone: [phone] Fax: [phone]

w
• The draft permit adds a manganese limit of 0.2 mg/L. Motiva understands that manganese occurs
naturally in the environment and can be present in a suspended, particulate state, resulting in high
"total" manganese results. Motiva requests that the N �' ENR uRlj at tth S amples can be filtered
prior to analysis for manganese.
Motiva respectfully requests that the above ist d comments be addressed prior o issuance of the final
NPDES permit. If you have questions, please contact me at 919-387-5764.
Sincerely,
Motiva Enterprises LLC
Nicola A. Ellis
Environmental Engineer
� �,Wtvc-s � �V�
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y�u�'

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
l,o: Britt Setzer
NC DENR / DEH / Regional Engineer
Mooresville Regional Office
From: Natalie Sierra
NPDES Unit
Subject: Review of Draft NPDES Permit NCO022187
Motiva Enterprises LLC — Paw Creek Terminal
Mecklenburg County
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
� 3 k•. .fir �a4� '�
APR 0 4 2001
NCDE_NR
Division of Environmental Health
rldl,li V,Iater Supply Section
P !C IL
ville Regional Office
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
May 2, 2001. If you have any questions on the draft permit, please contact me at the telephone number
or e-mail address listed at the bottom of this page.
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properly, the
stated effluent limits are met prior to discharge, and the discharge does not contravene the designated
water quality standards.
Concurs with issuance of the above permit, provided the following cKDENR
U
ll
Ulu APR
❑ - WAUALITY
C11 BRANCHOpposes the issuance of the above permit, based on reasons stated b
Signe
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 551 (tax) 919 733-0719
VISIT us ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES Natalie.Sierra@ ncmail.net

February 27, 2001 ny Y
NCDENR f�/]\\/r
Division of Water Quality/NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
RE: NPDES Permit Applications — Short Form C Renewal Applications
North Carolina Motiva Enterprise Facilities
A'0
To Whom It May Concern;
On behalf of Equiva Services, LLC, Applied Earth Sciences, Inc (AES) has
prepared the attached National Pollutant Discharge Elimination System (NPDES)
renewal permits using the Short Form C templates. The renewal applications have. been
prepared for the following four Motiva Enterprise facilities:
101 South Chimney -Rock Road
Greensboro, NC 27409
6851 Freedom Drive
Charlotte, NC 28214
2232 Ten -Ten. -Road ,
Apex, NC 27502-8115
410 Tom Sadler Road
Charlotte, NC 28214
Should you have any questions regarding the attached permit renewal
applications, please contact Ms. Anna Tillman of Equiva Services, LLC at (404) 321-
0695.
Sincerely;
APPLIED_F ARTH SCIENCES, INC.
Eric G. Hetrick
Project Geologist
814 Davidson Road e Concord, North Carolina 28025 • Tel: [phone] • Fax: [phone]

M
MW-32 W-31
MW 30
-19
MW-15 0 MW-20
MW-280 IV Retention
Pond
Remedii3tio-n
MW-13
e 0 150
OMW-14 Shed 0 1
OMW-22 R -7
0 MW-21 St
Drain Scale in Feet
Storm MW-23 0
Drain :: — -16V
Office/ ------- MW 1-6 DO MW-1
Mw i i (D W-5
Warehouse (8)
wPump oomw i RW-2 0
Hous MW-17
O MW-240 Sum
RW-3
Concrete MW-12 Premium @
(9 Unleaded 0 Unleaded
RW-40 MW-189 mw-9
0
MW-11 0 MW-7
Empty
(9 -9
9 Mw-6 (9 Unleaded
MW-8 Plus
Diesel MW-5
u Diesel
r.
0
OFire LEGEND
E Ra
ck
Tr
uck
0
0
Building Containment MW-4 0 0 Air Sporge Well Location
Dike 0 Shallow Monitor Well Location
(0 MW-25 MW- , 20 0 Deep Monitor Well Location
0 MW-3 MW-27(9 0 sump
0 MW-26 8 Recovery Well Location
K 0 Inactive Well Location
S Storm Drain Line
-*- -*- Fence
-------------
Plantation Pipeline —it— Property Line
NAME MOTIVA ENTERPRISE FIGURE
E C
'APPLIED EARTH SCIENCES CAROLINAS, INC. Facility No. 20-506-5001 SITE MAP
069-00093-021 Made By: B.P. Date: 2-12-01 410 Tom Sadler Road
Chocked By: E.H. File: 003-01 Charlotte, North Carolina

MOTIVA
ENTERPRISES LLG
Stull, Texaco S. Saud Aramco Working Together
CERTIFIED MAIL Z 324 454 836
RETURN RECEIPT REQUESTED
September 7, 2000
Mr. David Goodrich,
Supervisor NPDES Unit
Division of Water Quality
1617 Mail Service Center - — ----- —
Raleigh, NC 27699-1617
ii
RE: NPDES Permit No. NCO022187 DEC i 9 Z�00
Request Modification of Flow Monitoring type
Motiva Enterprises Charlotte North Terminal
Mecklenburg County I DENR - WATER QUALITY
POINT SOURCE BRANCH
Dear Mr. Goodrich:
This letter serves to request that the subject NPDES permit be reopened in order to modify the flow
measurement requirements. The subject permit was reissued on December 23, 1999, combining the
requirements of facility with that of the groundwater remediation system. Prior to the re -issuance of
the permit, the facility was required to submit a total flow volume. The groundwater remediation
system was required to have a flow totalizer.
The major source of discharge from the facility is due to stormwater. Prior to discharge, the
stormwater is collected in a surface impoundment of known volume. This provides the facility the
ability to determine the true discharge volumes with a maximum deviation of less than 10 percent as
required by 15 NCAC 02B .0505. The volume of wastewater generated by the groundwater
remediation is insignificant compared to the volume of stormwater. The remediation system does have
a flow totalizer and this was required to be reported under its own permit. When the two permits were
combined, it appears that the remediation permit was used as the template and did not take into
consideration the flow monitoring requirements of the facility's stormwater flow monitoring
requirements.
Since the facility retains the majority of the effluent in a surface impoundment of known size, the
requirement of installing a flow meter to determine the volumes discharged is redundant and will not
afford the environment any greater protection than is provided by the current system.
1717 — 61 11 Avenue, North Nashville, Tennessee 37209 Phone: [phone] Fax: [phone]

Mr. Dave Goodrich
September 7, 2000
Page 2 of 2
Therefore, Motiva Enterprises requests immediate relief from the flow measurement requirements
pending the modification and re -issuance of the subject NPDES permit.
If you have any questions, please call me at [phone].
Very truly yours,
MOTIVA ENTERPRISES
Jil J. Norman,
Field Environmental Coordinator
CC: Mr. Richard Bridgeman — NCDENR
Mr. Rusty Rozzelle — MCDEP
Larry Couch — Motiva Enterprises

\JO J e _
CERTIFIED MAIL Z 324 454 837
RETURN RECEIPT REQUESTED
September 7, 2000
Mr. Richard Bridgeman
Division of Water Quality
919 North Main Street
Mooresville, NC 28115
RE: Notice of Violation
Motiva Enterprises LLC
Charlotte North Terminal
NPDES Permit No. NCO022187
Mecklenburg County
Dear Mr. Bridgeman:
MOTIVA
ENTERPRISES LLC
Shell, Texaco & Saudi Aremco Working Together
19 2000
I regret the tardiness of this letter. As I mentioned in our telephone conversation, I have been dealing
with a serious illness within my family. This letter serves to address the flow measurement violation
noted by Mr. John McCulloch of Mecklenburg County DEP during his June 26, 2000 inspection of the
subject facility. Motiva Enterprises plans to submit a request to Mr. Dave Goodrich asking that the
permit be reopened and modified to reflect the flow measurement requirements of the original facility
NPDES before it was combined with the remediation system.
The primary source of effluent generated at the facility is from stormwater. Prior to discharge, the
stormwater is stored in a surface impoundment of a known volume. This provides the facility the
ability to determine the true discharge volumes with the maximum deviation of less than 10 percent as
required by 15 NCAC 02B .0505.
Motiva Enterprises will request that Mr. Goodrich suspend the new flow measurement requirements
and allow the facility to continue the flow measurement requirements under the old permit.
If you have any questions, please call me at [phone].
Very truly yours,
MOTIVA ENTERPRISES LLC
Ja J �-
Jil J. Norman,
Field Environmental Specialist
Cc: Rusty Rozzelle — MCDEP
Dave Goodrich — Water Quality Division
Larry Couch — Motiva Enterprises
1717 - 615f Avenue, North Nashville, Tennessee 37209 Phone: [phone] Fax: [phone]

Whole Effluent Toxicity Testing Self -Monitoring Summary February 16, 2001
FACILITY REQUIREMENT
YEAR JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
Morehead City WWTP PERM 24HR AC P/F LIM: 901%MYSJD
1997 --
Pass
--
>100
Pass
--
--
Pass
---
---
Fall
Fail
NCO0266111001 Begin:5/1/1993 Frequency: Q + Feb May Aug Nov
NonComp:SINGLE
1998 Fail
Pass
--
-
Pass
--
--
Fail
Pass
-
Pass
---
County: Carteret Region: WIRO Subbasim WOK03
1999 --
Pass
-
--
Pass
--
--
Pass
--
-
Bt
--
PF: 1.7 Special
2000 --
Pass
--
-
Pass
--
--
Fail
Pass
--
Pass
--
7QIO: TIDAL IWC(%):NA Order:
2001
Morganton Perm chr lim: 9%; if pf 10.5 chr lim 121%; if pf 13 chr lim 15%
1997 Pass
--
--
Fail
Pass
--
Pass
--
--
Pass
---
--
NCO026573/001 Begin:2/t/1995 Frequency: QP/F + Jan Apr Jul Oct
NonComp:Single
1998 Pas.
--
--
Pass
--
--
Pass
--
--
Fail,Pass
--
--
County: Burke Region: ARO Subbasin: CTB31
1999 Pass
-
--
Pass
--
--
Pass
--
--
Pass
--
--
PF: 8.0 Special
2000 Pass
--
-
Pass
--
--
Pass
--
--
Pass
--
--
7QIO: 126 IWC(%):8.96 Order:
2001
Motive Enterprises -Paw Creek Perm 24hr LC50 ac monit epis Ohd (gab)
1997 -
--
-
-
>100
--
--
-
--
-
--
--
NCO022187/001 Begin:9/l/1996 Frequency: A
NonComp:
1998 -
--
---
---
>100
--
--
--
--
--
--
--
County: Mecklenburg Region: MRO Subbasin: CTB34
1999 -
--
Pass
Pass
-
-
--
-
--
---
--
--
PF: NA Special
2000 86.1
--
--
--
-
--
--
--
-
--
--
--
7QI0:0.0 IWC(%):100 Order:
2001
Nit. Airy WWTP Perm chr lim: 42%
V 1997 Pass
-
--
Fail
Pass
--
Pass
--
--
Pass
-
--
NCO021121/001 Begin:2/l/2000 Frequency: Q P/F Jan Apr Jul Oct
+ NonComp:Single
1998 Fail
Pass
--
Pass
--
--
Pass
-
--
Pass
-
--
County: Sorry Region: WSRO Subbmin: YAD03
1999 Pass
---
--
Pass
--
--
Pass
--
--
Pass
--
--
PF: 7.0 Special
2000 Pass
--
--
Pass
--
-
Pass
--
--
Pass
---
--
7Q10: 14.9 IWC(%):42.0 Order:
2001 Fail
Mt. Gilead WWTP Perm chr lim: 3.2%
1997 -
-
Pass
--
--
Fail
Pass
--
Pass
--
--
Pass
NCO021105/001 Begire3/1/2000 Frequency:Q Mar Jun Sep Dec
+ NonComp:Single
1998 -
-
Fail
Late
Fail-
Late
Pass
--
Pass,Pass
---
--
Pass
County: Montgomery Region: FRO Subbasin: YAD10
1999 -
--
Pass
--
-
-
--
--
Late
Pass
--
Pass
PF: 0.85 Special
2000 --
-
Pass
-
--
NR
Pass
--
H
Pass
--
Passsig
7Qt0: 40 IWC(%):3.2 Order
2001
Mt. Holly W WTP Penn cl r lim: 6%
1997 -
Pass
--
--
Pass
-
--
Pass
---
---
Pass
---
NCO021156/001 Begin:9/I/1996 Frequency: Q P/F + Feb May Aug Nov
NonComp: Single
1998 --
Pass
--
--
Pass
--
--
Late
Pass
---
Pass
--
County: Gaston Region: MRO Subbasin: CTB33
1999 --
Pass
--
--
Pass
--
--
Pass
---
--
Pass
--
PF: 4.0 Special
2000 _-
Pass
-
--
Pass
-
--
Pass
--
--
Pass
--
7Q10:95.0 IWC(%):6.0 Order:
2001
Mt. Olive Pickle P-2 perm car monit (100, 75, 50,25, 12.5, 6.25)
Y 1997 8.a4
---
--
8.84
--
--
8.84
--
--
35.36
--
-
NC0001074/001 Begin:2/1/1996 Frequency: Q Jan Apr Jul Oct
NonComp:
1998 17,68
-
--
8.83
-
-
17.67
--
--
8,84
--
---
County: Wayne Region: WARD Subbasin: CPF21
1999 35.4
--
--
17.68
-
--
8.84
--
--
35.4
--
--
PF: 0.40 Special
2000 8.84
--
-
35.4
-
--
NR/Late
3643
--
35.4
-
--
7QI0:0.0 IWC(%):100 Order:
2001
Mt. Olive WWTP Perm chr lim: 90%
1997 --
--
Pa.$
-
--
Pass
---
--
Late
Fail
Pass
Pass
NCO020575/001 Begin:9/i/1996 Frequency: QP/F + Mar Jun Sep Dec
NonComp: Single
1998 --
--
Pass
-
--
Pass
---
--
Fail
Fail,Fail
>100
Pass
County: Wayne Region: WARO Subbasin: CPF21
1999 --
-
Late
Pass
--
Pass
-
-
Pass
--
--
Late
PF: 1.0 Special
2000 pass
--
Pass
--
--
Pass
-
-
Pass
-
-
Pass
7Q10:0.0 IWC(%):100 Order:
2001
Mt. Pisgah Lodge/Recreation Area Perm chr lim: 25%
1997 -
H
--
-
Pass(s)
--
--
Fail
Fail
Pass(s)
H
---
NCO072729/001 Begin: 12/1/1996 Frequency: Q P/F + Feb May Aug Nov
NonComp:Single
1998 --
H
--
Pass
Fail
Pass(s)
--
Pass(s)
--
---
Pass
--
County: Haywood Region: ARO Subbasin: FRB05
1999 --
NR/H
H
--
Late
Pass
--
Pass
--
--
Fail
--
PF: 0.032 Special
2000 H
H
--
Pass,>75
61.2
--
--
NR/Fail
61.2
61.2
Pass
--
7Q10:0.15 IWC(%):25 Order:
2001
Murphy W WTP Penn chr lim: 1.5%
1997 -
-
Pass
--
--
Fail
Fail
Pass
Pass
--
--
Pass
NCDO20940/001 Begin:3/l/1998 Frequency: Q P/F + Mar Jun Sep Dec
+ NonComp:Single
1998 -
-
Pass
-
--
Pass
--
--
Pass
--
--
Pass
County: Cherokee Region: ARO Subbasin: HIW02
1999 --
---
Pass
--
--
Pass
--
--
Pass
---
--
Pass
PF: 0.925 SW6.1
2000 _.
-
Pass
-
--
Pass
---
--
Pass
--
--
Pass
7QIO: %.9 IWC(%):1.5 Order:
2001
N. Buncombe High School Penn chr lim: 90%
1997 Pass
--
--
Fail
NR
NR
Pass
-
-
Pass
--
--
NCO061182/001 Begin: l0/1/1995 Frequency: Q P/F + Jan Apr Jul Oct
NonComp:Single
1998 Late
Late
Late
Late
Fail
Pass
Pass
-
-
Pass
-
--
County: Buncombe Region: ARO Subbasin: FRBO2
1999 NR/Pass
--
--
Pass
--
--
Fail
Late
Fail
Fail
>100
92.5
PF: 0.025 Special
2000 Fail
92.5
>100
Pass
--
---
Fall
>100
>100
Pass
--
--
7Q10:0.0 IWC(%):100 Order:
2001
4 Pre 1997 Data Available
LEGEND:
PERM = Permit Requirement LET = Administrative Letter - Target Frequency = Monitoring frequency: Q- Quarterly; M- Monthly; BM- Bimonthly; SA- Semiannually; A- Annually; OWD- Only when discharging; D- Discontinued monitoring requirement
Begin = First month required 7Q I O = Receiving stream low Bow criterion (cfs) + - quarterly monitoring increases to monthly upon failure or NR Months that testing must occur - ex. Jan, Apr, Jul, Oct NonComp = Current Compliance Requirement
PF = Permitted Bow (MGD) IWC%= Instream waste concentration P/F = Pass/Fail test AC = Acute CHR = Chronic
Data Notation: f - Fathead Minnow; • - Ceriodaphnia sp.; my - Mysid shrimp; ChV - Chronic value; P - Mortality of stated percentage at highest concentration; at - Performed by DWQ Aquatic Tox Unit; bt - Bad test
Reporting Notation: -•- = Data not required; NR - Not reported Facility Activity Status: I - Inactive, N - Newly Issued(To construct); H - Active but not discharging; 1-More data available for month in question; • = ORC signature needed
32

REASONABLE POTENTIAL ANALYSIS
Prepared by: Natalie Sierra, 3/7/01
Facility Name =
NPDES # _
Qw (MGD) _
Qw (cfs) _
7Q10s (cfs)=
/WC (%) _
Parameter
Phenols
Max. Pred Cw
Allowable Cw
Ethyl benzene
Max. Pred Cw
Allowable Cw
MTBE
Max. Pred Cw
Allowable Cw
Manganese
Max. Pred Cw (mg/L)
Allowable Cw (mg/L)
Iron (A.L.)
Max. Pred Cw (mg/L)
Allowable Cw (mg/L)
Lead (A. L. )
Max. Pred Cw (mg/L)
Allowable Cw (mg/L)
Toluene
Max. Pred Cw
Allowable Cw
Motiva Enterprises
NC0022187
0.257
0.397630
0
100.00
FINAL RESULTS, ug/I
122.8
200.6
18.1
524.0
177.6
11.6
4.3
0.2
10.8
1.0
10.8
1.0
8.2
11.0
Frequency of Detection
OSamples # Detects
5.5
19
M
p7
9
53
53
1
1
0
5
0
S
1

,arameter =
Standard =
Dataset=
Modified Data Nondetects RESULTS
0.5 <1.0
Std Dev.
8.177
0.5 <1.0
Mean
4.613
0.5 <1.0
C.V.
1.773
0.5 <1.0
Sample#
53.000
0.5 <1.0
0.5 <1.0
Mult Factor =
3.070
5 <10.0
Max. Value
40.000 pg/I
0.5 <1.0
Max. Pred Cw
122.800 pg/I
0.5 <1.0
Allowable Cw
200.600 pg/I
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
2.5 <5.0
0.5 <1.0
25 <50
25 <50
25 <50
25 <50
5 <10
5 <10
5 <10
5 <10
5.5 <11
5 <10
5.5 <11
5 <10
40
5 <10
5 <10
5 <10
10 <20
5.5 <11
5 <10
5 <10
sample# nondetects detects
53 52 1
Parameter= jEthylbenzene
Standard = I 524 pg/I
Dataset= DMR99
Modified Data Nondetects
RESULTS
2.5 <5
Std Dev.
1.437
2.5 <5
Mean
1.737
2.5 <5
C.V.
0.828
2.5 <5
Sample#
19.000
6
2.5 <5
Mult Factor =
3.010
2.5 <5
Max. Value
6.000 pg/I
2.5 <5
Max. Pred Cw
18.060 pg/I
2.5 <5
Allowable Cw
524.000 pg/I
2.5 <5
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
nondetects detects
19 18 1

Parameter = MTBE
Standard = 11.6 ug/L
ModifiedData
Nondetects RESULTS
46
Std Dev.
12.409
7.6
Mean
17.078
18
C.V.
0.727
5.5
Sample#
9.000
22
11
Mult Factor =
F 3.860
21
Max. Value
46.000 pg/I
7.6
Max. Pred Cw
177.560 pg/I
15
Allowable Cw
11.600 pg/I
sample# nondetects detects
9 0 9
Parameter = IManganese
Standard= 1 0.'
ModifiedData Nondetects
0.05 <0.10
0.05 <0.10
0.14
0.62
0.2
0.17'
0.14
0.05 <0.10
0.05 <0.10
sample# nondetects
9 4
mg/L
RESULTS
Std Dev.
0.181
Mean
0.1.63
C.V.
1.109
Sample#
9.000
Mult Factor =
6.980
Max. Value
0.620 mg/L
Max. Pred Cw
4.328 mg/L
Allowable Cw
0.200 mg/L
detects
61

Parameter= Iron (A.L.)
Standard = I mg/L
ModifiedData Nondetects RESULTS
0.78
Std Dev.
0.766
0.51
Mean
1.128
0.68
C.V.
0.679
1.1
Sample#
9.000
3
1.2
Mult Factor
1.4
Max. Value
3.000 pg/I
0.51
Max. Pred Cw
10:800 pg/I
0.97
Allowable Cw
1.000 pg/I
,aramerer =
Standard =
ModifiedData Nondetects
5 <10.0
5 <10.0
25, <50.0
25 <50.0
25 <50.0
12.5 <25.0
25 <50.0
5 <10.0
0.01 <0.02
0.01 <0.02
0.01 <0.02
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
2.5 <5.0
0.5 <1.0
0.5 <1
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
0.5 <1.0
6
25 <50
2.5 <5
2.5 <5
3
6
5
1 <2
1 <2
mg/L
RESULTS
Std Dev.
6.823
Mean
5.435
C.V.
1.255
Sample#
53.000
Mult Factor =
2.455
Max. Value
25.000 pg/I
Max. Pred Cw
61.375 pg/I
Allowable Cw
0.025 pg/I
sample# nondetects detects sample# nondetects detects
9 0 9 53 49
4

Parameter = IToluene
Standard = 1 11 ug/L
ModifiedData Nondetects RESULTS
0.5 <1.0
Std Dev.
1.841
2.5 <5.0
Mean
3.400
5 <10.0
C.V.
0.541
5 <10.0
Sample#
53.000
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
0.5 <1.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
5 <10.0
0.5 <1.0
5 <10.0
5 <10.0
5 <10.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.5 <5.0
2.2
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
0.5 <1
Mult Factor =
1.641
Max. Value
5.000 pg/I
Max. Pred Cw
8.205 pg/I
Allowable Cw
11.000 pg/I
sample# nondetects detects
53 52

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Star Enterprises
NC0022187
Permit issued Aug-96
Date
Flow TSR
Oil and Grease
Phenols
Benzene
Lead
Toluene
Xylene
Ethylbenzene MTBE
-(MGD) (mg/L)
(mg/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(ug/L) (ug/L)
8/1/96
0.019
8 <1.0
<1.0
<1.0
<10.0
<1.0
<1.0
8/6/96
0.046
14 <1.0
<1.0
<5.0
<10.0
<5.0
<5.0
9/4/96
0.069
5 <0.5
<1.0
<10.0
<50.0
<10.0
<10.0
10/7/96
0.035
4 <0.5
<1.0
<10.0
<50.0
<10.0
11/5/96
0.079
4 <0.50
<1.0
<10.0
<50.0
<10.0
12/5/96
0.079
3 <0.5
<1.0
<1.0
<25.0
<10.0
1/8/97
0.038
6 <0.50
<10.0
<10.0
<50.0
<10.0
2/7/97
0.044
4 <0.5
<1.0
<10.0
<10.0
<10.0
3/7/97
0.071
4 <0.5
<1.0
<1.0
<0.02
<10.0
3/18/97
0.064
3 <0.5
<1.0
<1.0
<0.02
<10.0
<10.0
4/7/97
0.068
3 <0.5
<1.0
<1.0
<0.02
<1.0
5/15/97
0.036
3 <0.5
<1.0
<1.0
<10.0
<10.0
6/23/97
0.017
3 <0.5
<1.0
<1.0
<10.0
<10.0
<10.0
7/2/97
0.044 <0.001
<0.5
<1.0
<1.0
<10.0
<10.0
<10.0
8/4/97
0.021
4 <0.5
<1.0
<1.0
<10.0
<10.0
<10.0
9/15/97
0.048
4 <0.5
<1.0
<1.0
<10.0
<10.0
<10.0
10/15/97
0.022
4 <1.0
<1.0
<1.0
<10.0
<10.0
11/5/97
0.065
3 <1.0
<1.0
<1.0
<10.0
<10.0
12/11/97
0.084
4 <1.0
<1.0
<1.0
<10.0
<10.0
<10.0
1/5/98
0.022
3 <1.0
<1.0
<1.0
<10.0
<10.0
<10.0
2/10/98
0.02
2 <1.0
<1.0
<1.0
<10.0
<10.0
3/13/98
0.036
2 <1.0
<1.0
<10.0
<10.0
<10.0
4/7/98
0.084
3 <1.0
<1.0
<1.0
<10.0
<10.0
4/15/98
0.024
1.8 <1.0
<1.0
<1.0
<10.0
<10.0
5/4/98
0.053
4 <1.0
<1.0
<1.0
<10.0
<10.0
6/8/98
0.047
2 <1.0
<1.0
<1.0
<10.0
<10.0
7/13/98
0.031
3.6 <1.0
<1.0
<1.0
<10.0
<10.0
<10.0
8/7/98
0.051
4.2 <1.0
<1.0
<1.0
<10.0
<10.0
9/4/98
0.257
4.2 <1.0
<1.0
<1.0
<10.0
<1.0
10/6/98
0.041
2 <1.0
<1.0
<1.0
<10.0
<10.0
11/10/98
0.065
2 <1.0
<1.0
<1.0
<10.0
<10.0
12/14/98
0.089 <10
<5.0
<5.0
<1.0
<5.0
<10.0
1/18/99
0.103
5 <5.0
<1.0
<1.0
<1.0
<5.0
<3
2/17/99
0.029 <10
<5.0
<50
<1.0
<1
<5.0
3/12/99
0.058 <10
<5
<50
<1.0
<1.0
<5.0
4/7/99
0.065 <10
<5
<50
<1.0
<1.0
<5.0
5/19/99
0.049 <10
<6
<50
<1.0
<1.0
<5.0
6/11/99
0.036
11 <5
<10
<1.0
<1.0
<5.0
7/13/99
0.08
5 <5
<10
<1.0
<1.0
<5.0
<3
9/14/99
0.055
4.5 <5
<10
<1.0
<1.0
<5.0
10/12/99
0.055
8 <5
<10
<1.0
<1.0
<5.0
11/23/99
0.036 <10.0
<5
<11
<1.0
<1.0
<5.0
12/22/99
0.062
6 <5
<10
<1.0
<1.0
<5.0
1/10/00
0.11
11 <5
<11
<1.0
<1.0
<5.0
<3
2/18/00
0.091
6 <6
<10
<1.0
6 2.2 <3
<1 46
3/14/00
0.058
6 <5
40 <1.0
<50
<1
<3
<1 7.6
4/11/00
0.108
8 <6
<10
<1.0
<5
<1
<3
<1 18
5/8/00
0.062
11 <5
<10
<1.0
<5
<1
<3
<1 5.5
7/11/00
0.088
22 <5
<10
<1.0
3 <1
<3
<1 22
8/1/00
0.065
33 <5
<20
<1.0
6 <1
<3
<1 11
9/19/00
0.05
28 <5
<11
<1.0
5 <1
<3
<1 21
11/20/00
0.104
15 <5
<10
<1.0
<2
<1
<3
<1 7.6
1/25/01
0.101
14 <5.0
<10
<1.0
<2
<1
<3
<1 15
average
0.061019 6.745652
max
0.257
33

1,2-DCA
Fluorene
Naphthalene Phenanthrene Manganese Iron
Date
(ug/L)
(ug/L)
(ug/L)
(ug/L)
(mg/L)
(mg/L)
-
8/1 /96
8/6/96
9/4/96
1017/96
1'1/5/96
12/5/96
1 /8/97
2/7/97
3/7/97
3/18/97
4/7/97
5/15/97
6/23/97
7/2/97
8/4/97
9/15/97
10/15/97
11 /5/97
12/11/97
1 /5/98
2/10/98
3/13/98
4/7/98
4/15/98
5/4/98
6/8/98
7/13/98
8/7/98
9/4/98
1016198
11/10/98
12/14/98
1 /18/99
2/17/99
3/12/99
417/99
5/19/99
6/11 /99
7/13/99
9/14/99
10/12/99
11 /23/99
12/22/99
1 /10/00
<1
<10
<10
<10
<0.10
0.78
2/18/00
<1
<10
<10
<10
<0.10
0.51
3/14/00
<1
<10
<10
<10
0.14
0.68
4/11/00
<1
<10
<10
<10
0.62
1.1
5/8/00
<1
<10
<10
<10
0.2
3
7/11/00
<1
<10
<10
<10
0.17
1.2
8/1/00
<1
<10
<10
<10
0.14
1.4
9/19/00
<1
<10
<10
<10
<0.10
0.51
11/20/00
<1
<10
<10
<10
<0.10
0.97
1/25/01

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
Mr. Larry Couch
Motiva Enterprises LLC
410 Tom Sadler Rd.
Paw Creek, North Carolina 28130
Dear Mr. Couch:
M?W'A
IT 0 0
A&4 IV 2
1111111111L� - -
NCDENR
NORTH CAROLINA DEPARTMENT OF -
ENVIRONMENT AND NATURAL RESOURCES
December 23, 1999
Subject: NPDES Permit Modification
Permit NumberNC0022187/NCG510177
Paw Creek Terminal
Mecklenburg County
The Division issued NPDES permit NCO022187 on August 2, 1996 and NPDES Permit
NCG510177 on April 25, 1997 to the Star Enterprises (now Motiva Enterprises LLC). The Division has
reviewed your request for permit modification at the subject facility. Specifically, you requested the
combining of the NPDES individual permit (NC0022187) and the NPDES general permit (NCG510177),
resulting in the elimination of the general permit. In accordance with your permit modification request,
the Division is forwarding herewith a modification to the subject permit.
In accordance with this approved permit modification to the NPDES individual permit, the
NPDES general permit NCG510177 is hereby rescinded.
Enclosed please find the modified effluent limitations page. This page should be inserted into
your permit and the old one discarded. This permit modification is conditional upon the combining of
the flow streams as indicated in .the August 24, 1999 proposal letter. This permit modification is issued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between North Carolina and the U. S. Environmental Protection Agency dated December 6,
1983.
Please take notice that this permit is not transferable. Part II, E.4. addresses the requirements to
be followed in case of change in ownership or control of this discharge. This permit does not affect the
legal requirement to obtain other permits which may be required by the Division of Water Quality or
permits required by the Division of Land Resources, Coastal Area Management Act or any other Federal
or Local government permit that may be required.
1 61 7 MAIL SERVICE CENTER, RALEIGH, NORTH CAROLINA 27699-1617 - TELEPHONE [phone]/FAX [phone]
AN EQUAL OPPORTUNITY AFFIRMATIVE ACTION EMPLOYER - 50% RECYCLED/ 10% POST -CONSUMER PAPER
VISIT US ON THE INTERNET @ http://h2o.enr.state.nc.us/NPDES

Mr. Larry Couch
Motiva Enterprises
NC0022187/NCG510177
If any parts, measurement frequencies or sampling requirements contained in this permit
modification 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 a written petition conforming
to chapter 150B of the North Carolina General Statutes, filed with the Office of Administrative Hearings,
Post Office Drawer 27447, Raleigh, North Carolina 27611-7447. Unless such demand is made, this
decision shall be final and binding.
If you have any questions concerning this permit, please contact Mr. Michael Myers at telephone
number [phone], extension 508.
Sincerely
rr T. Stevens
cc: Central Files
NPDES Permit File
Stormwater/General Permits Unit
Mooresville Regional Office
Point Source Compliance/Enforcement
Aquatic Toxicology Unit
Edward Henke — Equiva Service LLC
4127 Winters Chapel Road
Doraville, GA 30360

Permit Number: NCO022187
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS — Final
During the period beginning on the effective date of the permit and lasting until expiration, the Permittee is
authorized to discharge stormwater and treated groundwater from outfall 001. Such discharges shall be
limited and monitored by the Permittee as specified below:
FFCUENT $"
�CHAFI�GTERiI'tGS
ors e
LiM[TS f r
j �,�$
g MQNITORINt�
E0 i R'E1VlENf"
IT
q ' l ocatton ,
Flow
Continuous
Recorder
Effluent
Total Suspended Residue
30.0 m /1
Monthly
Grab
Effluent
Oil and Grease
Monthly
Grab
Effluent
Phenol
Monthly
Grab
Effluent
Benzene
1.19 u
Monthly
Grab
Effluent
Toluene
11.0 ug/1
Monthly
Grab
Effluent
Ethylbenzene
Monthly
Grab
Effluent
Xylene
Monthly
Grab
Effluent
Methyl Tert-Butyl Ether
Monthly
Grab
Effluent
Lead
Monthly
Grab
Effluent
1,2 Dichloroethane
Monthly
Grab
Effluent
Fluorene
Monthly
Grab
Effluent
Naphthalene
Monthly
Grab
Effluent
Phenanthrene
Monthly
Grab
Effluent
Iron
Monthly
Grab
Effluent
Manganese
Monthly
Grab
Effluent
EPA Method 624/625
Semi-annually
Grab
Effluent
Acute toxicity
Episodic
Grab
Effluent
Footnotes:
1. If flow is not continuous, flow may be monitored weekly in one of three ways: 1.)Continuous flow
measurement, 2.) Base flow on pump logs 3.) Estimate flow measurement using a totalizing flow meter at the
point of discharge, recording flow at the start of discharge, at the end of the first 20-minute interval and
immediately after discharge has ceased.
2. Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm
water) zone.
3. EPA Method 625 includes five (5) chlorophenols. If one or more chlorophenol(s) is detected at
concentrations greater than or equal to 50 µg/l, the permittee will be required to analyze for the eight
chlorophenols (listed below) in addition to EPA Method 625. This additional required monitoring will begin
with the permittee's next scheduled monitoring event, occur.on a semi-annual basis, and will last for the
duration of the permit. Eight chlorophenols include the following: 3-chlorophenol, 4-chlorophenol, 2,3-
dichlorophenol, 2,5-dichlorophenol, 2,6-dichlorophenol, 3,4-dichlorophenol, 2,3,4,6-tetrachlorophenol, and
3-methyl-6-chlorophenol.
4. Acute Toxicity (Fathead Minnow, 24-hour) Monitoring, Annual, See Part III, Condition E.
There shall be no discharge of floating solids or visible foam 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 ug/l and toluene concentration is less than 11 ug/1.

;y.
Permit NCO022187
Part III.
Condition E. ACUTE TOXICITY MONITORING (ANNUAL)
The permittee shall conduct annual toxicity tests using protocols defined as definitive in E.P.A. 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.
AAM Fathead 24 Version 9196

Motiva Biterprises
'A
Subject: Motiva Enterprises
Date: Mon, 04 Oct 1999 13:25:04 -0400
From: Richard Bridgeman <[e-mail]>
Organization: NC DENR - Mooresville Regional Office
To: Charles Weaver <[e-mail]>
Follow-up: Mike Parker/Rex Gleason have no problem with the Motiva request. Rexsays to route a/,
requests/inquiries through him. Sorry.
Richard Bridgeman - [e-mail]
Environmental Chemist II
North Carolina Dept. of Environment & Natural Resources
Div. of Water Quality
919 N. Main St.
Mooresville, NC 28115
Ph:704/663-1699 Fax:[phone]
1 of 1 10/4/99 1:27 PM

1
4 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
September 22, 1998
Ms. Jil J. Norman
Star Enterprise
1717 61st Avenue North
Nashville, Tennessee 37209
Subject: NPDES Permits - Ownership Change
Permit NC0022187
Charlotte Sales Terminal
Mecklenburg County
Dear Ms. Norman:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Permit NC0022217
Raleigh Sales Terminal
Wake County
The Division received your notification that the facilities covered by the subject permits are
being transferred to a new owner. Upon completion of the ownership changes, complete and return
the enclosed Permit Name / Ownership Change forms with a fee of $100.00 for each facility ($200.00
total). The Division will transfer the subject permits when the necessary fees and documentation have
been received.
All terms and conditions in the existing permits will remain in effect until the transfer of
ownership is complete, or until other action is taken by the Division.
Thanks for notifying us of this impending change in advance. If you have any additional
questions during this process, please contact me at the telephone number or address listed below.
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Raleigh Regional Office, Water Quality Section
Mooresville Regional Office, Water Quality Section
NPDES File
P.O. Box 29535, Raleigh, North Carolina 27626-0535 919 733-5083, extension 511 (fax) 919 733-0719
An Equal Opportunity Affirmative Action Employer [e-mail]

CERTIFIED MAIL Z 065 292 808
RETURN RECIEPT REQUESTED
August 27, 1998
1998 U
of W4TR
..� .
p'RIECl'ph.S prlGET y
Mr. A. Preston Howard, Jr., P.E.
Director
North Carolina Department of Environment and Natural Resources
Division of Water Quality
P. O. Box 29535
Raleigh, NC 27626
RE: NPDES NCO022187
Transfer of Ownership
Star Enterprise Charlotte Sales Terminal
410 Tom Sadler Rd.
Paw Creek, NC 28130
Mecklenburg County
Dear Mr. Howard, Jr., P.E.:
1717 — 61' Avenue, North
Nashville, Tennessee 37209
[phone]
FAX [phone]
This letter is to notify you that the above referenced Star Enterprise facility is in the process of being transferred to a
new owner, Motiva Enterprises LLC. This change in ownership and operational control is the result of the
formation of a new joint venture between Shell Oil Company and the parents of Star Enterprise.
Effective October 1, 1998, ownership and operational control of this facility and the subject permit will transfer
from Star Enterprise to Motiva Enterprise LLC. Effective that date, Motiva Enterprises LLC shall assume
responsibility and liability under the permit in question. The operations of the facility, the production levels,
products produced, and rates of discharge will not be affected by the change in ownership. The name and address of
the new owner of the facility is:
Motiva Enterprises LLC
410 Tom Sadler Rd.
Paw Creek, NC 28130
Mr. Larry Couch has been assigned as the terminal manager for the facility under the new ownership. If you have
any further questions regarding this matter, please contact me at [phone].
Very truly yours,
STAR ENTERPRISE
JLP J 00'1
Jil J. Norman,
Sr. Field Environmental Specialist
Cc: LMC
�tP _ 4 19y�
UHLITY
Vvr1 � ►_�
SECTION

.•
StarEnterprise
Ao%k
Ut
CERTIFIED MAIL Z 065 292 808
RETURN RECIEPT REQUESTED
August 27, 1998
.� TZPARZ�!'
s 1998 / l
DIV, pF
D'REC OR S OFUA /ry
FACE
Mr. A. Preston Howard, Jr., P.E.
Director
North Carolina Department of Environment and Natural Resources
Division of Water Quality
P. O. Box 29535
Raleigh, NC 27626
RE: NPDES NCO022187
Transfer of Ownership
Star Enterprise Charlotte Sales Terminal
410 Tom Sadler Rd.
Paw Creek, NC 28130
Mecklenburg County
Dear Mr. Howard, Jr., P.E.:
1717 — 61" Avenue, North
Nashville, Tennessee 37209
[phone]
FAX [phone]
This letter is to notify you that the above referenced Star Enterprise facility is in the process of being transferred to a
new owner, Motiva Enterprises LLC. This change in ownership and operational control is the result of the
formation of a new joint venture between Shell Oil Company and the parents of Star Enterprise.
Effective October 1, 1998, ownership and operational control of this facility and the subject permit will transfer
from Star Enterprise to Motiva Enterprise LLC. Effective that date, Motiva Enterprises LLC shall assume
responsibility and liability under the permit in question. The operations of the facility, the production levels,
products produced, and rates of discharge will not be affected by the change in ownership. The name and address of
the new owner of the facility is:
Motiva Enterprises LLC
410 Tom Sadler Rd.
Paw Creek, NC 28130
Mr. Larry Couch has been assigned as the terminal manager for the facility under the new ownership. If you have
any further questions regarding this matter, please contact me at [phone].
Very truly yours,
STAR ENTERPRISE
JLP \ J Poc)v tl��
Jil J. Norman,
Sr. Field Environmental Specialist
Cc: LMC
stP
UHLITY
Wvr, S CTION

1
StarE�tervrrse
A190
WI#
August 24, 1998
Dear Sir or Madam:
12700 Northborough Drive
Houston TX 77067-2508
281 8747000
This letter serves to notify you that Star Enterprise (Star) is in process of being
transferred to a new owner, Motiva Enterprises LLC. This change in ownership and
operational control is the result of the formation of a new joint venture between Shell Oil
Company and the parents of Star.
Star Enterprise and Motiva Enterprises LLC hereby provide notice that effective October
1, 1998, ownership and operational control of the facility and the permit referenced in the
attached document(s) will transfer from Star Enterprise to Motiva Enterprises LLC.
Effective October 1, 1998 Motiva Enterprises LLC shall assume responsibility and
liability under the referenced permit. The operations of the facility and the production
levels, products produced, rates of discharge, and wastewater characteristics will not be
affected by the change in ownership.
Sincerely,
M. L. Omer
Assistant Secretary
Saudi Refining, Inc.
R. J. Grimmer
Vice President - Commercial Marketing &
Distribution
Motiva Enterprises LLC

J
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. Darvin E. Mayo
Star Enterprise
Coordinator Environmental Marketing
333 Research Court
Norcross, Georgia 30092
Dear Mr. Mayo:
r
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Letter to Require Effluent
Turbidity Monitoring
Permit No. -NC0022187
Star Enterprise - Paw Creek
Mecklenburg County
As you are aware, the turbidity monitoring. requirement was eliminated from your
permit upon renewal in August 1996. Although turbidity monitoring was eliminated, total
suspended solids (TSS) monitoring with a limit remains in the permit. It was the Division's
contention that should monitoring data indicate TSS problems, the state has the option of
enforcing the instream standard for turbidity. However, the EPA is still concerned with the
removal of the turbidity monitoring requirement from several oil terminal discharge permits.
The following paragraphs address that concern.
During the research phase required for permit development,,it was noted that the 14
permits in the Paw Creek area had vastly different requirements for solids measurements.
Permits contained any combination of total suspended solids (TSS), turbidity, and settleable
solids monitoring and/or limits. In an effort to provide consistency, TSS, turbidity, and .
settleable solids results from six oil terminals in the Paw Creek area were examined from
July 1994 through September 1995. Results showed that TSS and turbidity exhibited
similar trends. Both pollutants appeared to increase and decrease at the same time. In
addition, for the period examined, there were no turbidity violations, although there were a
few TSS violations. These data resulted in the Division questioning whether monitoring
was necessary for both solids parameters. Was there an added benefit to requiring turbidity
monitoring in addition to TSS monitoring? The Division concluded that turbidity was
correlated with TSS results, and thus, only TSS monitoring with a limit was required. In
--addition, North Carolina has a water quality standard for turbidity. Therefore, although
turbidity monitoring is not required in the discharge permits,, the State still has the authority
to enforce the instream turbidity standard.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Mr. Mayo
February 22, 1999
Page 2
Based on concerns regarding anti -backsliding, the EPA requested the Division re-
examine the basis for the elimination of turbidity monitoring for 12 of the 14 Paw Creek
oil terminals that were required to monitor for turbidity prior to the most recent permit
renewal. This second examination of the data showed that there were turbidity standard
violations since the last analysis at several of the oil terminals. The Division will
investigate the causes of these violations to determine what steps may be necessary to
control solids levels at these sites. Therefore, the Division acknowledges that its second
evaluation resulted in a different outcome from the initial investigation and agrees that
turbidity monitoring should be added to the discharge permits for several of the oil
terminals. This letter serves as the official notice that quarterly turbidity monitoring
will be required at the facility effective March 1, 1999. If monitoring data show a
reasonable potential to violate water quality standards, then limits will be imposed upon
renewal.
If you have any questions concerning this change, please contact Bethany Bolt at
[phone], extension 551.
Sincerely,
/�rw� '4�
t-11, Preston Howard, Jr., P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Point Source Compliance Enforcement Unit