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HomeMy WebLinkAboutNC0022209_Permit Issuance_20161215-1: Water Resources ENVIRONMENTAL QUALITY PAT MCCRORY Governor DONALD R. VAN DER VAART Secretory S. JAY ZIMMERMAN Director December 15, 2016 Mr. Otto Muha, Terminal Superintendent Motiva Enterprises, LLC 101 S. Chimney Rock Road Greensboro; NC 27409 Subject: Issuance of NPDES Permit NCO022209 Motiva Enterprises, LLC Greensboro Terminal, PCNC 101 S. Chimney Rock Road, Greensboro 27409 Guilford County Dear Mr. Muha: The Division of Water Resources (the Division) hereby issues the attached NPDES permit for the subject facility. 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 October 15, 2007, or as subsequently amended. The Division understands that you have added a water holding tank after the oil/water separator to your facility since the last permit renewal. We have made the following updates in the August 10, 2016 and October 5, 2016 drafts to your previous permit: 1. updated facility description on the supplement to permit cover sheet including removal of the groundwater remediation treatment and discharge, a waste -holding tank (with optional pump -out for offsite disposal), and an oil / water separator 2. added updates to facility map including adjustment of Outfall 001 coordinates to 36.074074,-79.917382 3. added flow rational equation [see Footnote 2 and Special Condition A. (2.)] 4. changed annual toxicity monitoring to Acute Whole Effluent Toxicity (WET) testing [TGE6G] at 90%; 24 hour static and inserted Footnote 6 [Condition A. (3.)] 5. added monthly effluent Turbidity monitoring including 50 NTU effluent limits (both daily maximum & monthly average) along with Footnote 3 regarding receiving stream turbidity [NCAC 02B. 0211 (21)] 6. added electronic reporting of discharge monitoring reports (eDMR) in Section A. (4.) 7. removed MTBE monitoring special condition because there was not reasonable potential to exceed the water quality standard of 19 µg/L for streams classified as water supply. Changes made since the October 5, 2016 draft permit include the following: 8. added Footnote 4 regarding sampling for O&G as in the previous permit; however, the O&G parameter code [00556] remains the same for submitting DMR/eDMR, but uses test EPA method 1664 (SGT-HEM) with results in mg/L 9. removed footnote regarding samples being collected concurrently with annual Acute Toxicity State of North Carolina I Environmental Quality I Water Resources 1617 Mail service Center I Raleigh, North Carolina 27699-1617 919-707-9000 Mr. Gatewood December 15, 2016 Page 2 of 3 10. added Footnote 5 which requires that all practical quantitation limits (PQL) must be sufficiently sensitive considering the respective water quality standard for each parameter [see Part II. Section D. Regarding comments on the October 5, 2016 draft permit please note the following: • Bulk -storage facilities have potential to discharge turbid effluents. Considering that North Carolina has established standards for Turbidity in accord with receiving -stream classification, monitoring and permit limits are deemed appropriate to evaluate effluent compliance for freshwater [NCAC 02B. 0211(21)]. The Turbidity limit of 50 NTU is a narrative standard; therefore, instream dilution is not applicable. As Footnote 3 states, compliance is verified by instream sampling in the nearest waters of the state. In cases where instream sampling is not available or cannot be determined due to flow conditions, the limit applies at the point of discharge. • The TSS bench mark of 100 mg/L applies to stormwater permits such as federal and state stormwater permits such as US EPA Multi -Sector General Permit (MSGP) and the state issued General Permit NCG080000. Your facility requires an individual NPDES wastewater permit, and does not qualify for general stormwater General Permit NCG080000 because: 0 onsite petroleum -hydrocarbon bulk storage capacity is equal to, or exceeds, one million gallons, and; o secondary containment dikes (for product spills) confine stormwater in close proximity to product tanks and appurtenant piping, potentially creating product -contact wastewater [CWA Sec. 502(6), 33U.S.C. §1362 (6)], and; o routine operations require the manual discharge of stormwater (via a pipe through secondary containment) to waterbodies of the state, i.e., the release constitutes a point -source discharge [CWA Sec. 502(14), 33U.S.C. §1362 (14)]. North Carolina therefore concludes that this is a wastewater point source and as such, its discharge to the natural environment must be permitted under the NPDES wastewater program. The level of treatment for wastewater system is expected to be greater than a stormwater non - point source discharge. The TSS limits applied for wastewater treatment are a monthly average limit of 30 mg/1 and a daily maximum limit of 45 mg/l. The US EPA requires both a Monthly Average and a Daily Maximum for all parameters that are limited. Review of the last 4 and %z years (Oct 2011 to Mar 2016) gives a maximum TSS result of 27.1 mg/l. We do not anticipate that this facility will have issues with meeting compliance with the daily maximum limit. However, if the monthly average limit of 30 mg/1 is ever exceeded with results above 30 mg/l additional daily resampling can be averaged to meet compliance for a given month if monitoring. Starting December 21, 2016, federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and specify that, if a state does not establish a system to receive such submittals, then permittees must submit DMRs electronically to the Environmental Protection Agency (EPA). The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. The requirement to begin reporting discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application has been added to your final NPDES permit. [See Special Condition A. (6.)] For information on eDMR, registering for eDMR and obtaining an eDMR user account, please visit the following web page: http://deq.nc.gov/about/divisions/water-resources/edmr. Mr. Gatewood December 15, 2016 Page 3 of 3 For more information on EPA's final NPDES Electronic Reporting Rule, please visit the following web site: http://www2.epa. ov/compliance/fmal-national-pollutant-discharge-elimination-s. stem=npdes-electronic- reporting-rule. If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty (30) days after receiving this letter. Your request must take the form of a written petition conforming to Chapter 150B of North Carolina General Statutes, and you must file it with the Office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall remain 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 Resources or any other Federal, State, or Local governmental permits that may be required. If you have questions, or if we can be of further service, please contact Derek Denard at [derek.denard@ncdenr.gov] or call (919) 807-6307. espec lly, Jay Zimmerman, P.G., to Division of Water Resources, NCDEQ Enclosure: NPDES Permit NCO022209 (Issuance Final) hc: Central Files NPDES Program Files WSRO Files/ Attn: Sherri Knight ec: Aquatic Toxicology Branch / Susan Meadows [susan.meadows@ncdenr.gov] Otto Muha, Terminal Superintendent, Motiva Enterprises, LLC [otto.muha@motivaent.com] Jennifer L. Bothwell, Environmental Coordinator, Motiva Enterprises, LLC [Jennifer.Bothwell@motivaent.com] NPDES Permit NCO022209 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPa-- In compliance with the provisions 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 Motiva Enterprises, LLC — Greensboro Terminal 101 S. Chimney Rock Road, Greensboro, NC 27409 Guilford County to receiving waters designated as an unnamed tributary (UT) of Long Branch within the Cape Fear River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,11,111 and IV hereof. This permit shall become effective January 1, 2017. This permit and authorization to discharge shall expire at midnight on August 31, 2021. Signed this day, December 15, 2016. S,,�i(y Zimmerman, P.G., Director — Division of Water Resources ' By Authority of the Environmental Management Page 1 of 8 NPDES Permit NCO022209 SUPPLEMENT TO PERMIT COVER SHEET All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby revoked. As of this permit issuance, any previously issued permit bearing this number is no longer effective. Therefore, the exclusive authority to operate and discharge from this facility arises under the permit conditions, requirements, terms, and provisions included herein. MOtiva Enterprises, LLC is hereby authorized to: 1. continue operating an existing Surface -Water Pollution Control System for stormwater in proximity to above -ground storage tanks (ASTs) in excess of one million gallons,. surface bulk -storage of petroleum hydrocarbon fuels and Ethanol and utilizing; • diked areas (secondary containment of ASTs and piping) • truck loading -rack drains that flow to a concrete pit with sump pump to transfer to AST • a 8,000 gallon AST with hydrocarbon detector (contents are typically released into diked area but can be hauled off -site if contaminated) • settling pond (with point source outfall) • discharge control valve, manually operated (normally closed) located at the Motiva Enterprises, LLC — Greensboro Terminal, 101 South Chimney Rock Road, Greensboro, Guilford County, and 2. discharge from said treatment works via Outfall 001, a location specified on the attached map, into an unnamed tributary (UT) of Long Branch [stream segment 17-2-1-(1)], a waterbody currently classified WS-IV:* within Subbasin 03-06-08 [HUC: 030300030102] of the Cape Fear River Basin. Page 2 of 8 NPDES Permit NCO022209 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [15A NCAC 02B .0400 et seq., 02B .0500 et seq.] Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to discharge treated stormwater from Outfall 001. Such discharges shall be limited, monitored and reported' by the Permittee as specified below: `EF_ F_LUENT CHARACTERISTICS [PARAMETER CODES] ` . ` LIlVIITS, MQNITORING_:REQUIRE_ MENTSi. Mbi thly-. Avera a D"aily Kgiimum, Measurement ` Frequency'.. Sample T. _e" , Sample' Location Flow 2 (MGD) 50050 Episodic 2 Effluent Total Suspended Solids (TSS) (mg/L) C0530 30.0 mg/L 45.0 mg/L Monthly Grab Effluent Turbidity 3 (NTLD 00070 50 NTU 50 NTU Monthly Grab Effluent Oil & Grease 4 (mg/L) EPA Method 1664 [SGT-HEM] 00556 Monthly Grab Effluent Benzene 5 (µg/L) 34030 Monthly Grab Effluent Toluene 5 (µg/L) 34010 Monthly Grab Effluent Ethyl Benzene 5 µg/L) 34371 Monthly Grab Effluent Naphthalene 5 (µg/L) 34696 Monthly Grab Effluent Xylene 5 (µg/L) 81551 Monthly Grab Effluent Total Recoverable Phenolics 5 (µg/L) 32730 Quarterly Grab Effluent MTBE 5 (µg/L) 22417 Quarterly Grab Effluent Acute WET Testing 6 TGE6C Annually 6 Grab Effluent Footnotes: 1. Starting on December 21, 2016, begin submitting Discharge Monitoring Reports electronically using NC DWR's eDMR application system. See Condition A. (4.). 2. Each discharge event shall be monitored for Flow volume and duration — During periods of no flow, the Permittee shall submit a signed, monthly Discharge Monitoring Report (DMR) indicating "No discharge." Flow may be documented using any one of the following four (4) methods: 1) measure flow continuously via weir or flow meter (totalizer preferred); 2) estimate flow at 20-minute intervals during the entire discharge event; 3) report flow based on discharge pump logs; or 4) calculate flow based on total rainfall per unit area draining to the outfall using the Rational Method [see formula, Section A. (2.)]. 3. Turbidity — Effluent turbidity shall not cause receiving -stream turbidity to exceed 50 NTU. If background turbidity naturally exceeds 50 NTU, the effluent shall not cause background turbidity to increase. Any discharge exceeding this permit limit will require sufficient instream sampling (upstream and/or downstream) to verify compliance (effluent vs. background). [NCAC 02B. 0211(21)] Page 3 of 8 NPDES Permit NCO022209 4. Where possible, the grab sample for Oil & Grease should be skimmed from the water surface of a quiescent (calm water) zone. 5. All practical quantitation limits (PQL) must be sufficiently sensitive considering the respective water quality standard for each parameter [see Part II. Section D. (4)]. 6. If Acute WET -test fails [TAE6C], the Permittee shall test each subsequent discharge event until testing indicates "pass," after which Quarterly monitoring shall resume in accord with Section A. (3). If after a subsequent five (5) consecutive Quarterly events, WET results demonstrate no toxicity (i.e., "pass"), the Permittee may petition the Division to relax monitoring, as data may warrant. WET -test samples shall be collected concurrently with other POC samples, as appropriate to monitoring frequencies. Conditions: • The Permittee shall discharge no floating solids or foam. • Direct discharge of tank solids, tank -bottom water, or the rag layer is not permitted. • Hydrostatic Tank Testing: The Permittee shall discharge no tank solids, no tank bottom -water, no tank rag -layer; no tank [or pipe] contents, unless Benzene concentration tests less than 1.19 µg/L and Toluene concentration tests less than 11 µg/L. A. (2.) FLOW MEASUREMENT RATIONAL [G.S. 143-215. 1 (b)] The Rational Method - Determination of Peak Runoff: [REF: FHWA Urban Drainage Design Manual, 3.2.2. Rational Method (3-1)] Q=KuCIA, where: Q = flow (peak flow rate in cfs or m3/sec) Ku = unit conversation factor = 1.008 for U.S. standard units (usually ignored because it is so close to 1), or 0.278 for metric 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 beginning rainfall excess when all portions of the drainage basin are contributing simultaneously to outlet flow). A = area of tributary watershed (acres or km2) The rational equation is used to calculate the runoff from a region, given: . • the runoff coefficient (accounts for infiltration losses in the region), • the rainfall intensity to the region, • the time for runoff to travel from the region's upper reaches to its outlet, and • the region's drainage area. Page 4 of 8 NPDES Permit NCO022209 A. (3.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY) [15A NCAC 02B .0200 et seq.] The permittee,shall conduct acute toxicity tests on a quarterly basis using protocols defined in the North Carolina Procedure Document entitled "Pass/Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised December 2010 or subsequent versions). The monitoring shall be performed as a Fathead Minnow (Pimephales promelas) 24 hour static test. The effluent concentration at which there may be at no time significant acute mortality is 90% (defined as treatment two in the procedure document). The tests will be performed during the months of January, April, July and October. These months signify the first month of each three month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must be obtained during representative effluent discharge and shall be performed at the NPDES permitted final effluent discharge below all treatment processes. Should any single quarterly monitoring indicate a failure to meet specified limits, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. All toxicity testing results required as part of this permit condition will be entered on the Effluent Discharge Monitoring Form (MR-1) for the month in which it was performed, using the parameter code TGE6C.'Additionally, DWR Form AT-2 (original) is to be sent to the following address: Attention: North Carolina Division of Water Resources Water Sciences Section/Aquatic Toxicology Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section 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 there be no discharge of flow from the facility during a month in which toxicity monitoring is required, the permittee will complete the information located at the top of the aquatic toxicity (AT) test form indicating the facility name, permit number, pipe number,'county, and the month/year of the report with the notation of "No Flow" in the comment area of the form. The report shall be submitted to the Water Sciences Section at the address cited above. Should the permittee fail to monitor during a month in which toxicity monitoring is required, then monthly monitoring will begin immediately until such time that a single test is passed. Upon passing, this monthly test requirement will revert to quarterly in the months specified above. Assessment of toxicity compliance is based on the toxicity testing quarter, which is the three month time interval that begins on the first day of the month in which toxicity testing is required by this permit and continues until the final day of the third month. Page 5 of 8 NPDES Permit NCO022209 Should any test data from either these monitoring requirements or tests performed by the North Carolina Division of Water Resources 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. A. (4.) ELECTRONIC REPORTING OF DISCHARGE MONITORING REPORTS [G.S. 143-215.1(b)] Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and program reports and specify that, if a state does not establish a system to receive such submittals, then permittees must submit monitoring data and reports electronically to the Environmental Protection Agency (EPA). The final NPDES Electronic Reporting Rule was adopted and became effective on December 21, 2015. NOTE: This special condition supplements or supersedes the following sections within Part II of this permit (Standard Conditions for NPDES Permits): • Section B. (11.) Signatory Requirements • Section D. (2.) • Section D. (6.) • Section E. (5.) Reporting Records Retention Monitoring Reports 1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)] Effective December 21, 2016, the permittee shall report discharge monitoring data electronically using the NC DWR's Electronic Discharge Monitoring Report (eDMR) internet application. Monitoring results obtained during the previous month(s) shall be summarized for each month and submitted electronically using eDMR. The eDMR system allows permitted facilities to enter monitoring data and submit DMRs electronically using the internet. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), permittees will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Page 6 of 8 NPDES Permit NCO022209 If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the facility being physically located in an area where less than 10 percent of the households have broadband access, then a temporary waiver from the NPDES electronic reporting requirements may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1, 1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be submitted to the mailing address above. See "How to Request a Waiver from Electronic Reporting" section below. Regardless of the submission method, the first DMR is due on the last day of the month following the. issuance of the permit or in the case of a new facility, on the last day of the month following the commencement of discharge. Starting on December 21, 2020, the permittee must electronically report the following compliance monitoring data and reports, when applicable: • Sewer Overflow/Bypass Event Reports; • Pretreatment Program Annual Reports; and • Clean Water Act (CWA) Section 316(b) Annual Reports. The permittee may seek an electronic reporting waiver from the Division (see "How to Request a Waiver from Electronic Reporting" section below). 2. Electronic Submissions In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the time of each electronic submission. The permittee should use the EPA's website resources to identify the initial recipient for the electronic submission. , Initial recipient of electronic NPDES information from NPDES-regulated facilities means the entity (EPA or the state authorized by EPA to implement the NPDES program) that is the designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)]. EPA plans to establish a website that will also link to the appropriate electronic reporting tool for each type of electronic submission and for each state. Instructions on how to access and use the appropriate electronic reporting tool will be available as well. Information on EPA's NPDES Electronic Reporting Rule is found at: http://www2.epa.gov/compliance%final-national-pollutant- discharge-elimination-system-npdes-electronic-reporting-rule. Electronic submissions must start by the dates listed in the "Reporting Requirements" section above. 3. How to Request a Waiver from Electronic Reporting The permittee may seek a temporary electronic reporting waiver from the Division. To obtain an electronic reporting waiver, a permittee must first submit an electronic reporting waiver request to the Division. Requests for temporary electronic reporting waivers must be submitted in writing to the Page 7 of 8 NPDES Permit NC0022209 Division for written approval at least sixty (60) days prior to the date the facility would be required under this permit to begin submitting monitoring data and reports. The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At such time, monitoring data and reports shall be submitted electronically to the Division unless the permittee re -applies for and is granted a new temporary electronic reporting waiver by the Division. Approved electronic reporting waivers are not transferrable. Only permittees with an approved reporting waiver request may submit monitoring data and reports on paper to the Division for the period that the approved reporting waiver request is effective. Information on eDMR and the application for a temporary electronic reporting waiver are found on the following web page: httv://deg.nc.gov/about/divisions/water-resources/edmr 4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)l All eDMRs submitted to the permit issuing authority shall be signed by a person described in Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in Part II, Section B. (I 1.)(b). A person, and not a position, must be delegated signatory authority for eDMR reporting purposes. For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user account and login credentials to access the eDMR system. For more information on North Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please visit the following web page: hLtp://dpg.nc.gov/about/divisions/water-resources/edmr Certification. Any person submitting an electronic DMR using the state's eDMR system shall make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF CERTIFICATION WILL BE ACCEPTED: "I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. " 5. Records Retention [Supplements Section D. (6.)] The permittee shall retain records of all Discharge Monitoring Reports, including eDMR submissions. These records or copies shall be maintained for a period of at least 3 years from the date of the report. This period may be extended by request of the Director at any time [40 CFR 122.41 ]. Page 8 of 8 Motiva Enterprises, LLC Greensboro Terminal ' NPDES Permit NCO022209 101 S. Chimney Rock Road, Greensboro, NC 27409 Receiving Stream: UT to Long Branch Stream Class: WS-IV:* Stream Segment: 17-2-1-(1) Sub -Basin #: 03-06-08 River Basin: Cape Fear HUC: 030300030102 County: Guilford N SCALE 1:10,000 NC Grid/USGS Quad: C19SW / Guilford, r DEQ / DWR / NPDES EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit NCO022209 Derek Denard, Compliance & Expedited Permitting Unit / 919-807-6307 131)ec2016 Facility Information Applicant/Facility Name Motiva Enterprises, LLC Greensboro Terminal Applicant Address 101 S. Chimney Rock Road, Greensboro, NC 27409 Facility Address 101 S. Chimney Rock Road, Greensboro, NC 27409 Permitted Flow (MGD) not limited Type of Waste 100% Industrial, fuel (bulk storage) Facility Class PCNC County Guilford Permit, Status Renewal Regional Office WSRO Stream Characteristics Receiving Stream UT to Long Branch Stream Classification WS-IV:* Stream Segment [17-2-1-(1)] Drainage basin Cape Fear Summer 7Q10 (cfs) 0 Subbasin [HUC] 03-06-08 [HUC: 0303000301021 Winter 7Q10 (cfs) 0 Use Support Impaired (Cat 5): Fish Tissue Hg, Benthos Fair, Fish Community Fair. 30Q2 (cfs) 0 303(d) Listed Average Flow (cfs) 0 State Grid C19SW IWC (%) 100% USGS Topo Quad Guilford, NC Facility Summary This facility is an industrial (flow <1 MGD) operating an existing Surface -Water Pollution Control System for stormwater in proximity to above -ground storage tanks (ASTs) in excess of one million gallons, surface bulk -storage of petroleum hydrocarbon fuels and Ethanol and utilizing: • diked areas (secondary containment of ASTs and piping) • truck loading -rack drains that flow to a concrete pit with sump pump to transfer to AST • a 8,000 gallon AST with hydrocarbon detector (contents are typically released into diked area but can be hauled off -site if contaminated) • settling pond (with point source outfall) • discharge control valve, manually operated (normally closed) Since the last permit renewal one change has been made to the facility A water holding tank was added after the oil/water separator. For Renewal — This permit reflects discharge at Outfall 001. DWR updated the following: 1. updated facility description on the supplement to permit cover sheet including removal of the groundwater remediation treatment and discharge, a waste -holding tank (with optional pump -out for offsite disposal), and an oil / water separator 2. added updates to facility map including adjustment of Outfall 001 coordinates to 36.074074,-79.917382 3. added flow rational equation [see Footnote 2 and Special Condition A. (2.)] Fact Sheet Renewal 2016 -- NPDES Permit NCO022209 Page 1 4. changed annual toxicity monitoring to Acute Whole Effluent Toxicity (WET) testing [TGE6G] at 90%; 24 hour static and inserted Footnote 6 [Condition A. (3.)] 5. added monthly effluent Turbidity monitoring including 50 NTU effluent limits (both daily maximum & monthly average) along with Footnote 3 regarding receiving stream turbidity [NCAC 02B. 0211 (21)] 6. added electronic reporting of discharge monitoring reports (eDMR) in Section A. (4.) 7. removed MTBE monitoring special condition because there was not reasonable potential to exceed the water quality standard of 19 µg/L for streams classified as water supply. Changes made since the October 5, 2016 draft permit include the following: 8. added Footnote 4 regarding sampling for O&G as in the previous permit; however, the O&G parameter code [00556] remains the same for submitting DMR/eDMR, but uses test EPA method 1664 (SGT-HEM) with results in mg/L 9. removed footnote regarding samples being collected concurrently with annual Acute Toxicity 10. added Footnote 5 which requires that all practical quantitation limits (PQL) must be sufficiently sensitive considering the respective water quality standard for each parameter [see Part II. Section D. (4•)] Re ag rding comments on the October 5, 2016 draft permit please note the following: • Bulk -storage facilities have potential to discharge turbid effluents. Considering that North Carolina has established standards for Turbidity in accord with receiving -stream classification, monitoring and permit limits are deemed appropriate to evaluate effluent compliance for freshwater [NCAC 02B. 0211(21)]. The Turbidity limit of 50 NTU is a narrative standard; therefore, instream dilution is not applicable. As Footnote 3 states, compliance is verified by instream sampling in the nearest waters of the state. In cases where instream sampling is not available or cannot be determined due to flow conditions, the limit applies at the point of discharge. • The TSS bench mark of 100 mg/L applies to stormwater permits such as federal and state stormwater permits such as US EPA Multi -Sector General Permit (MSGP) and the state issued General Permit NCG080000. Your facility requires an individual NPDES wastewater permit, and does not qualify for general stormwater General Permit NCG080000 because: 0 onsite petroleum -hydrocarbon bulk storage capacity is equal to, or exceeds, one million gallons, and; o secondary containment dikes (for product spills) confine stormwater in close proximity to product tanks and appurtenant piping, potentially creating product - contact wastewater [CWA Sec. 502(6), 33U.S.C. §1362 (6)], and; o routine operations require the manual discharge of stormwater (via a pipe through secondary containment) to waterbodies of the state, i.e., the release constitutes a point -source discharge [CWA Sec. 502(14), 33U.S.C. §1362 (14)]. North Carolina therefore concludes that this is a wastewater point source and as such, its discharge to the natural environment must be permitted under the NPDES wastewater program. The level of treatment for wastewater system is expected to be greater than a stormwater non -point source discharge. The TSS limits applied for wastewater treatment are a monthly average limit of 30 mg/1 and a daily maximum limit of 45 mg/l. The US EPA requires both a Monthly Average and a Daily Maximum for all parameters that are limited. Review of the last 4 and %2 years (Oct 2011 to Mar 2016) gives a maximum TSS result of 27.1 mg/l. We do not anticipate that this facility will have issues with meeting compliance with the daily maximum limit. However, if the monthly average limit of 30 mg/1 is ever exceeded with results above 30 mg/1 additional daily resampling can be averaged to meet compliance for a given month if monitoring. Stream — Discharge from Outfall 001 is into an unnamed tributary (UT) to Long Branch [Stream Segment 17-2-1-(1)], a waterbody classified WS-IV:* located within Subbasin 03-06-08 [HUC: 030300030102] of the Cape Fear River Basin. The segment [17-2-1-(1)] is listed as Impaired (Cat 5) for Fish Tissue Hg, Fact Sheet Renewal 2016 -- NPDES NC0022209 Page 2 Benthos Fair, Fish Community Fair. The description for Stream Segment 17-2-1-(1) description is from source to a point 0.5 mile downstream of Guilford County SR 1541. RPA - The need for toxicant limits is based upon a demonstration of reasonable potential to exceed water quality standards, a statistical evaluation that is conducted during every permit renewal utilizing the most recent effluent data for each outfall. The RPA is conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero background; 3) use of V2 detection limit for "less than" values; and 4) streamflows used for dilution consideration based on 15A NCAC 2B.0206. Effective April 6, 2016, NC began implementation of dissolved metals criteria in the RPA process in accordance with guidance titled NPDES Implementation of Instream Dissolved Metals Standards, dated June 10, 2016. A reasonable potential analysis was conducted on effluent toxicant data collected between Oct2011- Mar2016. Pollutants of concern included toxicants with positive detections and associated water quality standards/criteria. Based on this analysis, the following permitting actions are proposed for this permit: S Monitoring Only. The following parameters will receive a monitor -only requirement since they did not demonstrate reasonable potential to exceed applicable water quality standards/criteria, but the maximum predicted concentration was >50% of the allowable concentration or remains as a parameter of concern included in the permitting strategy for this type of facility: Benzene, Toluene, Ethylbenzene, Xylenes, Naphthalene, MTBE and Phenolics. [see attached RPA Spreadsheets] Data Summary - Effluent Data (Oct 2011 - Mar2016) [four and one half years (4 V2)]. Parameter Max Of Value Min of Value Average of Value Count of Value UoM 00556 - Oil & Grease 9.8 5 5.2 53 mg/I 22417 - Methyl Tert-Butyl Ether 10 5 7 26 pg/1 32730 - Phenolics, Total Recoverable 5 5 5 24 pg/I 34010 - Toluene 2 1 1 53 1 pg/1 34030 - Benzene 1 1 1 53 pg/1 34371 - Ethylbenzene 1 1 1 53 pg/1 34696 - Naphthalene 1 1 1 53 pg/I 81551 - Xylene 3 1 1 53 pg/1 CO530 - Solids, Total Suspended - Concentration 21.7 1 5.73 52 mg/I Flow - Effluent Data (Oct 2011 - Mar2016) [four and one half years (4 V2)]. This facility is combined stormwater and groundwater [complex wastestream] that flows to a retention pond that discharges episodically. Parameter Year Max of Value Min of Value Average of Value Count of Value 50050 - Flow, in conduit or thru treatment plant 20113 0.9008 0.0004 0.1188 20 2012 0.1868 0.0240 0.0851 38 2013 0.2064 0.0240 0.0961 69 2014 0.1453 0.0005 0.0799 44 2015 0.1561 0.0041 0.0785 56 20163 0.1194 0.0513 0.0841 10 Max/Min/Average/Total 1 0.9008 1 0.0004 0.0886 237 3 three (3) months of data Whole Effluent Toxicity(WET) - This facility is combined stormwater and groundwater [complex wastestream] that flows to a retention pond that discharges episodically. Currently WET testing is Acute Fact Sheet Renewal 2016 -- NPDES NC0022209 Page 3 WET [TAE6C] Fathead Minnow (Pimephales promelas), 24-hr definitive, LC-50 > 100%. Acute test history demonstrates no toxicity issues [See attached data summary]. Acute WET testing is deemed appropriate to evaluate end -of -pipe short-term impacts of episodic discharges. Chronic WET testing is applied to onsite groundwater remediation because these waste streams are deemed complex and can be non -episodic. These facilities typically discharge under zero flow conditions (IWC = 100%), therefore WET testing is conducted @ 90% effluent concentration. [REF Memo: Coleen Sullins, DWQ, 1999]. For renewal Changed annual toxicity monitoring to Acute Whole Effluent Toxicity (WET) testing [TGE6G] at 90%; 24 hour static with the following Footnote 5: If Acute Whole Effluent Toxicity (WET) test fails [TGE6C], the Permittee shall test each subsequent discharge event until testing indicates "pass," after which Quarterly monitoring shall resume in accord with Section A. (3.). If after a subsequent five (5) consecutive Quarterly events, WET results demonstrate no toxicity (i.e., "pass"), the Permittee may petition the Division to relax monitoring, as data may warrant. WET -test samples shall be collected concurrently with other POC samples, as appropriate to monitoring frequencies. Compliance History — See attached compliance history for Oct2011 to June2016. Outfa11001 —Adjusted Coordinates to 36' 4' 26.666", -79' 55' 2.575" [36.074074,-79.917382] (see below). Fact Sheet Renewal 2016 -- NPDES NC0022209 Page 4 Motiva Enterprises LLC Greensboro Terminal NCO022209 REASONABLE POTENTIAL ANALYSIS 2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence MAXIMUM DATA POINTS = 58 Qw (MGD) = 0.90080 1Q10S(cfs)= 0.00 7QIOS(cf1s)= 0.00 7Q10W (cfs) = 0.00 30Q2 (cfs) = 0.00 Avg. Stream Flow, QA (cfs) = 0.00 Receiving Stream: UT of Long Branch WWTP/WTPClass: PCNC IWC @ 1Q10S = 100.00% IWC @ 7Q10S = 100.00% IWC @ 7QIOW = 100.00% 1WC @ 30Q2 = 100.00% IWC @ QA = 100.00% Stream Class: WS-IV:` Outfall 001 Qw = 0.9008 MGD PARAMETER STANDARDS 8 CRITERIA (2) rn REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION T ( )E Qa z NC WQS / Applied h FAV / n # Det. Max Pred Cw Allowable Cw Chronic Standard Acute Acute: NO WQS Benzene C 1.19 WS µg/L 53 0 NODETECTS ___________________ _ _-_ _ _-_ _ _ Chi0I 1.19 No detects - maintain monthly monitoring Max MDL= 1 Acute: NO WQS Benzene C 51 fill ug1. 53 0 NO DETECTS _-_ _-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _ Chronic: 51.00 No detects - maintain monthly monitoring Max MDL = I Acute: NO WQS Toluene NC 11 1 lrg 1 53 1 2.0 Chronic: 11.00 No RP, Predicted Max < 50 % of Allowbale Cw - No value > Allowable Cw maintain monthly monitoring Acute: NO WQS Ethylbenzene NC 97 I \ ug 1 53 0 NO DETECTS _ _ _ Chronic: 97•015 No detects - maintain monthly monitoring Max MDL = I Acute: NO WQS Xylenes, Mixture NC 670 IAV ug'1 53 4 3.1 _ _-_ Chronic: 670.00 No RP, Predicted Max < 50 % of Allowbale Cw - No value > Allowable Cw maintain monthly monitoring Acute: NO WQS Napthalene NC 12 I'U µg I_ 53 0 NO DETECTS _ _- _-___ _ _ _-________________________ Chronic: 12.00 No detects - maintain monthly monitoring Max MDL Acute: NO WQS MTBE (Methyl Tertiary -butyl Ether) NC 19 WS Ng1 16 0 NO DETECTS _ _ _ Chronic: 19.00 No detects - maintain quarterly monitoring Max MDL = 10 Acute: NO WQS MTBE (Methyl Tertiary -butyl Ether) NC 1500 fill ug'l_ 26 0 NO DETECTS _ _-_ Chronic: I,50(l.011 No detects - maintain quarterly monitoring Max MDl I0 Acute: NO WQS Phenolics, Total Recoverable NC 300 1'W ug't 24 0 NO DETECTS Chronic: 300.00 No detects - maintain quarterly monitoring Max MDL = 5 NCO022209 Bulk -Storage 9595 GENERIC non -hardness RPA2016_53.xlsm, rpa Page 1 of 1 8/9/2016 2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY Table 1. Project Information ❑CHECK IF HQW OR ORW Facility Name Motiva Enterprises LLC Greensboro Terminal WWTP/WTP Class PCNC NPDES Permit NCO022209 Outfall 001 Flow, Qw (MGD) 0.90080 Receiving Stream UT of Long Branch Stream Class WS-IV. 7Q10s (cfs) 0.00 7Q10w (cfs) 0.00 30Q2 (cfs) 0.00 QA (cfs) 0.00 1Q10s (cfs) 0.00 Data Source(s) BIMS Oct2011 to Mar2016 ❑CHECK TO APPLY MODEL Follow directions for data entry. In some cases a comment menu list the available choices or a dropdown menu will provide a list you may select from. Error message occur if data entry does not meet input criteria. Par01 Par02 Par03 Par04 Par05 Par06 Par07 Par08 Par09 Par10 Par11 Par12 Par13 Par14 Par15 Par16 Par17 Par18 Par19 Par20 Par21 Par22 Table 2. Parameters of Concern Name Tyre Chronic Modifier Acute PQL Units Benzene C 1.19 WS pg/L Benzene C 51 HH pg/L Toluene NC 11 FW pg/L Ethylbenzene NC 97 FW pg/L Xylenes, Mixture NC 670 FW pg/L Napthalene NC 12 FW pg/L MTBE (Methyl Tertiary -butyl Ether) NC 19 WS pg/L MTBE (Methyl Tertiary -butyl Ether) NC 1500 HH pg/L Phenolics, Total Recoverable NC 300 FW pg/L NCO022209 Bulk -Storage 9595 GENERIC non hardness RPA2016_53.xlsm, input 8/9/2016 REASONABLE POTENTIAL ANALYSIS 5 Date Data 1 10/13/2011 < 2 11/3/2011 < 3 12/19/2011 < 4 1/12/2012 < 5 2/20/2012 < 6 3/5/2012 < 7 4/23/2012 < 8 5/10/2012 < 9 6/13/2012 < 10 7/10/2012 < 11 8/10/2012 < 12 9/13/2012 < 13 10/2/2012 < 14 12/26/2012 < 15 1 /7/2013 < 16 2/13/2013 < 17 3/13/2013 < 18 4/3/2013 < 19 5/8/2013 < 20 6/5/2013 < 21 7/2/2013 < 22 7/12/2013 < 23 8/1/2013 < 24 9/20/2013 < 25 10/9/2013 < 26 11/27/2013 < 27 12/3/2013 < 28 1 /6/2014 < 29 2/17/2014 < 30 3/10/2014 < 31 4/7/2014 < 32 5/16/2014 < 33 6/11/2014 < 34 7/16/2014 < 35 8/4/2014 < 36 9/4/2014 < 37 10/15/2014 < 38 11 /3/2014 < 39 12/1/2014 < 40 1 /12/2015 < 41 2/2/2015 < 42 3/2/2015 < 43 4/9/2015 < 44 5/4/2015 < 45 7/1/2015 < 46 8/11/2015 < 47 9/25/2015 < 48 10/5/2015 < 49 11 /2/2015 < 50 12/17/2015 < 51 1/11/2016 < 52 2/4/2016 < 53 3/28/2016 < 54 55 56 57 58 Use"PASTE SPECIAL Benzene Values" then "COPY" . Maximum data points = 58 BDL=112DL Results 1 0.5 Std Dev. 0.0000 1 0.5 Mean 0.5000 1 0.5 C.V. 0.0000 1 0.5 In 53 1 0.5 1 0.5 Mult Factor = 1.0000 1 0.5 Max. Value 0.5 ug/L 1 0.5 Max. Pred Cw O DETECTS Ng/L 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 6 Date Data 1 10/13/2011 < 2 11 /3/2011 < 3 12/19/2011 < 4 1/12/2012 < 5 2/20/2012 < 6 3/5/2012 < 7 4/23/2012 < 8 5/10/2012 < 9 6/13/2012 < 10 7/10/2012 < 11 8/10/2012 < 12 9/13/2012 < 13 10/2/2012 < 14 12/26/2012 < 15 1 /7/2013 < 16 2/13/2013 < 17 3/13/2013 < 18 4/3/2013 < 19 5/8/2013 < 20 6/5/2013 < 21 7/2/2013 < 22 7/12/2013 < 23 8/1/2013 < 24 9/20/2013 < 25 10/9/2013 < 26 11 /27/2013 < 27 12/3/2013 < 28 1/6/2014 < 29 2/17/2014 < 30 3/10/2014 < 31 4/7/2014 < 32 5/16/2014 < 33 6/11/2014 < 34 7/16/2014 < 35 8/4/2014 < 36 9/4/2014 < 37 10/15/2014 < 38 11 /3/2014 < 39 12/1/2014 < 40 1/12/2015 < 41 2/2/2015 < 42 3/2/2015 < 43 4/9/2015 < 44 5/4/2015 < 45 7/1/2015 < 46 8/11 /2015 < 47 9/25/2015 < 48 10/5/2015 < 49 11 /2/2015 < 50 12/17/2015 < 51 1/11/2016 < 52 2/4/2016 < 53 3/28/2016 < 54 55 56 57 58 Use "PASTE 5PECIALI Benzene Values" then .COPY" Maximum data points = 58 BDL=1/2DL Results 1 0.5 Std Dev. 0.0000 1 0.5 Mean 0.5000 1 0.5 C.V. 0.0000 1 0.5 n 53 1 0.5 1 0.5 Mult Factor = 1.0000 1 0.5 Max. Value 0.5 Ng/L 1 0.5 Max. Pred Cw O DETECTS Ng/L 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 NCO022209 Bulk -Storage 9595 GENERIC non_hardness RPA2016_53.xlsm, data - 1 - 8/9/2016 REASONABLE POTENTIAL ANALYSIS 7 Use"PASTE SPECIAL 10 Use"PASTE SPECIAL Toluene Vales, then "COPY• Ethylbenzene Values" then "COPY" . Maximum data . Maximum data points = 58 points = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 10/13/2011 < 1 0.5 Std Dev. 0.2060 1 10/13/2011 < 1 0.5 Std Dev. 0.00 2 11/3/2011 < 1 0.5 Mean 0.5283 2 11/3/2011 < 1 0.5 Mean 0.50 3 12/19/2011 < 1 0.5 C.V. 0.3900 3 12/19/2011 < 1 0.5 C.V. 0.0000 4 1/12/2012 < 1 0.5 n 53 4 1/12/2012 < 1 0.5 n 53 5 2/20/2012 < 1 0.5 5 2/20/2012 < 1 0.5 6 3/5/2012 < 1 0.5 Mult Factor = 1.0200 6 3/5/2012 < 1 0.5 Mult Factor = 1.0000 7 4/23/2012 < 1 0.5 Max. Value 2.0 Ng/L 7 4/23/2012 < 1 0.5 Max. Value 0.5 Ng/L 8 5/10/2012 < 1 0.5 Max. Pred Cw 2.0 Ng/L 8 5/10/2012 < 1 0.5 Max. Pred Cw O DETECTS Ng/L 9 6/13/2012 < 1 0.5 9 6/13/2012 < 1 0.5 10 7/10/2012 < 1 0.5 10 7/10/2012 < 1 0.5 11 8/10/2012 < 1 0.5 11 8/10/2012 < 1 0.5 12 9/13/2012 < 1 0.5 12 9/13/2012 < 1 0.5 13 10/2/2012 < 1 0.5 13 10/2/2012 < 1 0.5 14 12/26/2012 < 1 0.5 14 12/26/2012 < 1 0.5 15 1 /7/2013 < 1 0.5 15 1 /7/2013 < 1 0.5 16 2/13/2013 < 1 0.5 16 2/13/2013 < 1 0.5 17 3/13/2013 < 1 0.5 17 3/13/2013 < 1 0.5 18 4/3/2013 < 1 0.5 18 4/3/2013 < 1 0.5 19 5/8/2013 < 1 0.5 19 5/8/2013 < 1 0.5 20 6/5/2013 < 1 0.5 20 6/5/2013 < 1 0.5 21 7/2/2013 < 1 0.5 21 7/2/2013 < 1 0.5 22 7/12/2013 < 1 0.5 22 7/12/2013 < 1 0.5 23 8/1/2013 < 1 0.5 23 8/1/2013 < 1 0.5 24 9/20/2013 < 1 0.5 24 9/20/2013 < 1 0.5 25 10/9/2013 < 1 0.5 25 10/9/2013 < 1 0.5 26 11 /27/2013 < 1 0.5 26 11 /27/2013 < 1 0.5 27 12/3/2013 < 1 0.5 27 12/3/2013 < 1 0.5 28 1/6/2014 < 1 0.5 28 1/6/2014 < 1 0.5 29 2/17/2014 < 1 0.5 29 2/17/2014 < 1 0.5 30 3/10/2014 < 1 0.5 30 3/10/2014 < 1 0.5 31 4/7/2014 < 1 0.5 31 4/7/2014 < 1 0.5 32 5/16/2014 < 1 0.5 32 5/16/2014 < 1 0.5 33 6/11/2014 < 1 0.5 33 6/11/2014 < 1 0.5 34 7/16/2014 < 1 0.5 34 7/16/2014 < 1 0.5 35 8/4/2014 < 1 0.5 35 8/4/2014 < 1 0.5 36 9/4/2014 < 1 0.5 36 9/4I2014 < 1 0.5 37 10/15/2014 < 1 0.5 37 10/15/2014 < 1 0.5 38 11/3/2014 < 1 0.5 38 11/3/2014 < 1 0.5 39 12/1/2014 < 1 0.5 39 12/1/2014 < 1 0.5 40 1/12/2015 < 1 0.5 40 1/12/2015 < 1 0.5 41 2/2/2015 < 1 0.5 41 2/2/2015 < 1 0.5 42 3/2/2015 < 1 0.5 42 3/2/2015 < 1 0.5 43 4/9/2015 < 1 0.5 43 4/9/2015 < 1 0.5 44 5/4/2015 < 1 0.5 44 5/4/2015 < 1 0.5 45 7/1/2015 < 1 0.5 45 7/1/2015 < 1 0.5 46 8/11/2015 < 1 0.5 46 8/11/2015 < 1 0.5 47 9/25/2015 < 1 0.5 47 9/25/2015 < 1 0.5 48 10/5/2015 < 1 0.5 48 10/5/2015 < 1 0.5 49 11 /2/2015 < 1 0.5 49 11 /2/2015 < 1 0.5 50 12/17/2015 < 1 0.5 50 12/17/2015 < 1 0.5 51 1/11/2016 < 1 0.5 51 1/11/2016 < 1 0.5 52 2/4/2016 2 2 52 2/4/2016 < 1 0.5 53 3/28/2016 < 1 0.5 53 3/28/2016 < 1 0.5 54 54 55 55 56 56 57 57 58 58 NCO022209 Bulk -Storage 9595 GENERIC non_hardness RPA2016_53.xlsm, data -2- 8/9/2016 REASONABLE POTENTIAL ANALYSIS 12 Xylenes, Mixture Date Data BDL=1/2DL Results 1 10/13/2011 < 1 0.5 Std Dev. 2 11/3/2011 3 3 Mean 3 12/19/2011 < 1 0.5 C.V. 4 1/12/2012 1.1 1.1 n 5 2/20/2012 < 1 0.5 6 3/5/2012 < 1 0.5 Mult Factor = 7 4/23/2012 < 1 0.5 Max. Value 8 5/10/2012 < 1 0.5 Max. Pred Cw 9 6/13/2012 < 1 0.5 10 7/10/2012 < 1 0.5 11 8/10/2012 < 1 0.5 12 9/13/2012 1 1 13 10/2/2012 < 1 0.5 14 12/26/2012 < 1 0.5 15 1 /7/2013 < 1 0.5 16 2/13/2013 < 1 0.5 17 3/13/2013 < 1 0.5 18 4/3/2013 < 1 0.5 19 5/8/2013 < 1 0.5 20 6/5/2013 < 1 0.5 21 7/2/2013 < 1 0.5 22 7/12/2013 < 1 0.5 23 8/1/2013 < 1 0.5 24 9/20/2013 < 1 0.5 25 10/9/2013 < 1 0.5 26 11 /27/2013 < 1 0.5 27 12/3/2013 < 1 0.5 28 1 /6/2014 < 1 0.5 29 2/17/2014 < 1 0.5 30 3/10/2014 < 1 0.5 31 4/7/2014 < 1 0.5 32 5/16/2014 < 1 0.5 33 6/11/2014 < 1 0.5 34 7/16/2014 < 1 0.5 35 8/4/2014 < 1 0.5 36 9/4/2014 < 1 0.5 37 10/15/2014 < 1 0.5 38 11 /3/2014 < 1 0.5 39 12/1/2014 < 1 0.5 40 1/12/2015 < 1 0.5 41 2/2/2015 < 1 0.5 42 3/2/2015 < 1 0.5 43 4/9/2015 < 1 0.5 44 5/4/2015 < 1 0.5 45 7/1/2015 < 1 0.5 46 8/11/2015 < 1 0.5 47 9/25/2015 < 1 0.5 48 10/5/2015 < 1 0.5 49 11 /2/2015 < 1 0.5 50 12/17/2015 < 1 0.5 51 1/11/2016 < 1 0.5 52 2/4/2016 2 2 53 3/28/2016 < 1 0.5 54 55 56 57 Use"PASTE SPECIAL Values" then "COPY" . Maximum data points = 58 0.4071 0.5962 0.6828 53 1.0300 3.0 Ng/L 3.1 Ng/L 14 Date Data 1 10/13/2011 < 2 11 /3/2011 < 3 12/19/2011 < 4 1/12/2012 < 5 2/20/2012 < 6 3/5/2012 < 7 4/23/2012 < 8 5/10/2012 < 9 6/13/2012 < 10 7/10/2012 < 11 8/10/2012 < 12 9/13/2012 < 13 10/2/2012 < 14 12/26/2012 < 15 1/7/2013 < 16 2/13/2013 < 17 3/13/2013 < 18 4/3/2013 < 19 5/8/2013 < 20 6/5/2013 < 21 7/2/2013 < 22 7/12/2013 < 23 8/1/2013 < 24 9/20/2013 < 25 10/9/2013 < 26 11/27/2013 < 27 12/3/2013 < 28 1/6/2014 < 29 2/17/2014 < 30 3/10/2014 < 31 4/7/2014 < 32 5/16/2014 < 33 6/11/2014 < 34 7/16/2014 < 35 8/4/2014 < 36 9/4/2014 < 37 10/15/2014 < 38 11 /3/2014 < 39 12/1/2014 < 40 1/12/2015 < 41 2/2/2015 < 42 3/2/2015 < 43 4/9/2015 < 44 5/4/2015 < 45 7/1 /2015 < 46 8/11/2015 < 47 9/25/2015 < 48 10/5/2015 < 49 11 /2/2015 < 50 12/17/2015 < 51 1/11/2016 < 52 2/4/2016 < 53 3/28/2016 < 54 55 56 57 58 Use"PASTE SPECIAL{ Napthalene Values" then "COPY" . Maximum data BDL=1/2DL Results 1 0.5 Std Dev. 0.0000 1 0.5 Mean 0.5000 1 0.5 C.V. 0.0000 1 0.5 n 53 1 0.5 1 0.5 Mult Factor = 1.0000 1 0.5 Max. Value 0.5 Ng/L 1 0.5 Max. Pred Cw O DETECTS Ng/L 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 1 0.5 NCO022209 Bulk -Storage 9595 GENERIC non_hardness RPA2016_53.xlsm, data -3- 8/9/2016 REASONABLE POTENTIAL ANALYSIS 16 Use "PASTE SPECIA 17 'use "PASTE SPECIAL MTBE (Methyl Tertiary -butyl Ether) Values" then "COPY i . Maximum data � MTBE (Methyl Tertiary -butyl Ether) values" titan data .Maximum data points = 58 points = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 10/13/2011 < 5 2.5 Std Dev. 1.2596 1 10/13/2011 < 5 2.5 Std Dev. 1.2596 2 11/3/2011 < 5 2.5 Mean 3.5577 2 11/3/2011 < 5 2.5 Mean 3.5577 3 12/19/2011 < 5 2.5 C.V. 0.3540 3 12/19/2011 < 5 2.5 C.V. 0.3540 4 1/12/2012 < 10 5 n 26 4 1/12/2012 < 10 5 n 26 5 3/5/2012 < 5 2.5 5 3/5/2012 < 5 2.5 6 4/23/2012 < 5 2.5 Mult Factor = 1.1500 6 4/23/2012 < 5 2.5 Mult Factor = 1.1500 7 9/13/2012 < 10 5 Max. Value 5.0 ug/L 7 9/13/2012 < 10 5 Max. Value 5.0 ug/L 8 10/2/2012 < 5 2.5 Max. Fred Cw O DETECTS pg/L 8 10/2/2012 < 5 2.5 Max. Pred Cw O DETECTS pg/L 9 12/26/2012 < 5 2.5 9 12/26/2012 < 5 2.5 10 1 /7/2013 < 5 2.5 10 1/7/2013 < 5 2.5 11 2/13/2013 < 10 5 11 2/13/2013 < 10 5 12 4/3/2013 < 10 5 12 4/3/2013 < 10 5 13 7/2/2013 < 10 5 13 7/2/2013 < 10 5 14 7/12/2013 < 10 5 14 7/12/2013 < 10 5 15 8/1/2013 < 10 5 15 8/1/2013 < 10 5 16 10/9/2013 < 5 2.5 16 10/9/2013 < 5 2.5 17 11/27/2013 < 10 5 17 11/27/2013 < 10 5 18 1 /6/2014 < 10 5 18 1 /6/2014 < 10 5 19 4/7/2014 < 10 5 19 4/7/2014 < 10 5 20 7/16/2014 < 10 5 20 7/16/2014 < 10 5 21 10/15/2014 < 5 2.5 21 10/15/2014 < 5 2.5 22 3/2/2015 < 5 2.5 22 3/2/2015 < 5 2.5 23 4/9/2015 < 5 2.5 23 4/9/2015 < 5 2.5 24 7/1/2015 < 5 2.5 24 7/1/2015 < 5 2.5 25 10/5/2015 < 5 2.5 25 10/5/2015 < 5 2.5 26 1/11/2016 < 5 2.5 26 1/11/2016 < 5 2.5 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 NCO022209 Bulk -Storage 9595 GENERIC non_hardness RPA2016_53.xlsm, data -4- 8/9/2016 REASONABLE POTENTIAL ANALYSIS 18 "PASTE SPECIAL Phenolics, Total Recoverable Values" then "COPY" . Maximum data points = 58 Date Data BDL=1/2DL Results 1 10/13/2011 < 5 2.5 Std Dev. 0.0000 2 11/3/2011 < 5 2.5 Mean 2.5000 3 12/19/2011 < 5 2.5 C.V. 0.0000 4 1/12/2012 < 5 2.5 n 24 5 4/23/2012 < 5 2.5 6 9/24/2012 < 5 2.5 Mult Factor = 1.0000 7 10/2/2012 < 5 2.5 Max. Value 2.5 Ng/L 8 12/26/2012 < 5 2.5 Max. Pred Cw O DETECTS Ng/L 9 1 /712013 < 5 2.5 10 2/13/2013 < 5 2.5 11 4/3/2013 < 5 2.5 12 7/2/2013 < 5 2.5 13 7/12/2013 < 5 2.5 14 8/1/2013 < 5 2.5 15 10/9/2013 < 5 2.5 16 1 /6/2014 < 5 2.5 17 4/7/2014 < 5 2.5 18 7/16/2014 < 5 2.5 19 10/15/2014 < 5 2.5 20 3/2/2015 < 5 2.5 21 4/9/2015 < 5 2.5 22 7/1/2015 < 5 2.5 23 10/5/2015 < 5 2.5 24 1/11/2016 < 5 2.5 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 NCO022209 Bulk -Storage 9595 GENERIC non —hardness RPA2016_53.xlsm, data -5- 8/9/2016 Denard, Derek From: Smith, George Sent: Monday, October 10, 2016 2:42 PM To: Denard, Derek Subject: RE: Resubmission for Public Notice Draft Permi NC22209 Motiva Enterprises, LLC - Greensboro Terminal Derek, Recommend the permit be issued. George Smith, Assistant Regional Supervisor email: george.smith@ncdenr.gov Division of Water Resources 450 West Hanes Mill Road, Suite 300 Winston-Salem, NC 27105 Direct phone: (336) 776-9700 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Tuesday, October 04, 2016 5:48 PM To: otto.muha@motivaent.com;'jennifer.bothwell@motivaent.com' <jennifer.bothwell@motivaent.com> Cc: Knight, Sherri <sherri.knight@ncdenr.gov>; Smith, George <george.smith@ncdenr.gov>; Kinney, Maureen <Maureen.Kinney@ncdenr.gov>; Meadows, Susan <susan.meadows@ncdenr.gov> Subject: Resubmission for Public Notice Draft Permit NC22209 Motiva Enterprises, LLC - Greensboro Terminal Mr. Muha & Ms. Bothwell, Please find the attached draft NC22209 Motiva Enterprises, LLC - Greensboro Terminal that will be resubmitted for public notice. Please provide your comments, if any, to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ/ DWR / NPDES Program no later than November 11, 2016. Sincerely, Derek C Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard(oncdenr.gov N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 l e ) /(JC 00 2 2?0 5 Denard, Derek From: Meadows, Susan Sent: Wednesday, October O5, 2016 10:56 AM To: Corporon, Joe; Denard, Derek C. Knight Sherri; Belnick, Tom; Moore, Cindy; Hennessy, John Subject RE: Draft Permit NC0071463 Center Point Co., LLC-Greensboro Terminal No, that's good. I just mentioned the cover letter for understandability purposes, trying to read all of that in the body of the permit is probably quite confusing, so I thought I would suggest just a simple statement, so It's easy to understand. Thanks. Susie SusanMeadows Environmental Biologist Aquatic Toxicology Branch DWR/Water Sciences Section Department of Environmental Quality tel: (919) 743-8439 fax: (919) 743-8517 susan.meadows@ncdenr.eov 4401 Reedy Creek Road Raleigh, NC 27607 n-- " Not hmy Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Corporon, Joe Sent: Wednesday, October 05, 2016 10:49 AM To: Meadows, Susan <susan.meadows@ncdenr.gov>; Denard, Derek <derek.denard@ncdenr.gov> Cc: Knight, Sherri <sherri.knight@ncdenr.gov>; Belnick, Tom <tom.belnick@ncdenr.gov>; Moore, Cindy <cindy.a.moore@ncdenr.gov>; Hennessy, John <john.hennessy@ncdenr.gov> Subject: RE: Draft Permit NC0071463 Center Point Co., LLC-Greensboro Terminal Joe's two cents: Susan - yes, 1 feel you and Cindy have correctly assessed our permitting goals, with two minor clarifications: 1. We have thus far (through several permit cycles) required five (5) quarters of "pass," not four (as episodic data are available) - perhaps arbitrary but consistent; and 2. 1 believe we were advised by EPA that the permit cover letter may "explain," but is not "defensible" as part of the permit, so we have to be clear to define conditions in the permit body. Respectfully, Joe R. Corporon, L.G. NCDEQ fc—Nothing Compares E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties From: Meadows, Susan Sent: Wednesday, October 05, 2016 10:19 AM To: Denard, Derek <derek.denard@ncdenr.gov> Cc: Corporon, Joe <joe.corporon@ncdenr.gov>; Knight, Sherri <sherri.knight@ncdenr.Rov>; Belnick, Tom <tom.belnick@ncdenr.Rov>; Moore, Cindy <cindv.a.moore@ncdenr.Rov> Subject: RE: Draft Permit NC0071463 Center Point Co., LLC-Greensboro Terminal Okay, I just want to have a good understanding about this as I am the one that is running Compliance on these facilities with respect to WET testing, so I need to have be clear on what is expected. So, the intent is to change them from Annual Monitoring Only to an Annual Limit - Correct? And if they fail they will revert to quarterly testing permanently until the Division says they can go back to Annual testing — correct? Just wondering... Why can't they run 4 quarterly test (and if they pass all of them) automatically go back to Annual testing? In talking with Cindy Moore about this, we agree that we don't have a problem with it we just need to stay consistent as well as adhering to EPA. So, if this is the intent then we do not have separate language page for this, but I would explain it clearly and simply in the cover letter. By stating: If the annual test results in a fail, then the facility will revert to quarterly testing. Susie Susan Meadows Environmental Biologist Aquatic Toxicology Branch DWR/Water Sciences Section Department of Environmental Quality tel: (919) 743-8439 fax: (919) 743-8517 susan.meadows@ncdenr.Rov Question: Have we acheved this? 4401 Reedy Creek Road Raleigh, NC 27607 1C. " Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Wednesday, October 05, 2016 9:53 AM To: Meadows, Susan <susan.meadows@ncdenr.gov> Cc: Corporon, Joe <ioe.corooron@ncdenr.gov>; Knight, Sherri <sherrLknight@ncdenr.gov> Subject: Re: Draft Permit NCO071463 Center Point Co., LLC-Greensboro Terminal Susan, We gave them annual monitoring in the effluent table. According to the footnote, once they fail they revert to quarterly following Condition A.3. Joe's thinking is that annual monitoring is conditional upon pass/fail. If we change the TOX page to annual there would be no guidelines for what months we require because we would want them to monitoring quarterly going forward. Would inserting a special condition into the permit better explain what we are trying to do here? Is there an Annual Acute TOX page that requires them to do quarterly sampling upon failure and remain at quarterly until they request to go back to annual? I'm not sure we have anything parameter code wise and TOX page wise that captures this. Derek Derek Denard Environmental Specialist N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office d e re k. d e n a rd tM n cd e n r. a o v 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Meadows, Susan Sent: Wednesday, October 5, 2016 8:52 AM To: Denard, Derek Cc- Knight, Sherri Subject: RE: Draft Permit NCO071463 Center Point Co., LLC-Greensboro Terminal Hi Derek, I am still confused. I thought these were going to remain as Annual Monitoring only tests? All of the permits show conflicting information. It's listing Annual testing in the Table, then Quarterly Limit language in the footnote and WET Section A(3), see below. Haas see7' Tatinee� rrTP.eC ---1 nraar.tly Arab Em� 6. If Acare WET -tat fails ITGE6C1, the Permittee shall test each subsequent discharge event until testing indicates "pass," after which Quan�rly momtonn(? shill resume m accord with Section A. (3.). If after a subsequent five (5) consecutive Quarterly events. Wf: r results demonstrate no toxicity (i.e., "pass's, the Pennittee may petition the Division to relax monitoring, as data may warrant. W E'r-test templesshall be colleetod eurx•u ily with other IK)C sampka, as app rriate to monitoring ftequencies. A. (3.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY) 115A NCAC 02B .0500 et seq.J The permtttee shall conduct acute toxicity tcsta on a quarterly basis using protocols defined in the North Carolina Proc ochre Document entitled "Pass'Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised December 2010 or subsequent versions). The monitoring shall be Performed as a Fathead Minnow (Pirnephules prumefnr) 24 hour static test. "Ihc effluent concentration at which there may be at no time significant acute mortality is 5111116/9 (defined as treatment two in the procodurc document). The tests will be Performed during the months of January, ApnT, July and October. These months signify, the first month of each three month toxicity testing quarter asvigned to the facility. Effluent sampling for this testing roast be obtained during representative effluent discharge and shall be perfonneri at the \PIES permitted final eftluertt discharge below all treatment (nm«sees Should any single quarterly monitoring indicate a failure to meet specified limits, then monthl, nronlloring will bettin immedinteiv until such time that a single het is passed. Upon passing. this monthly test requirement will revert to quarterly in the months specified above. NC0000795 - Kinder Morgan- Greensboro Terminal NCO031046 - Colonial Pipeline/001 NCO022209 - Motiva Enterprises LLC-Greensboro NCO026247 - TransMontaige Operating Company NCO074578 - Magellan Terminal Holdings Greensboro I Terminal NCO069256 - TransMontaigne-Piedmont Terminal NCO051161 - Plantation Pipeline Co. (001 x002) NCO042501 - Kinder Morgan Southeast Terminals LLC NCO071463 - Center Point Co., LLC -Greensboro Terminal NC0003671 - Magellan Terminals Holdings, L.P.-Greensboro II Terminal Susan Meadows Environmental Biologist Aquatic Toxicology Branch DWR/Water Sciences Section Department of Environmental Quality tel: (919) 743-8439 fax: (919) 743-8517 Susan. meadows@ ncdenr. eov 4401 Reedy Creek Road Raleigh, NC 27607 M, —Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Tuesday, October 04, 2016 6:06 PM To: bshelil@aoexoil.com; reyansgrn@gmail.com Cc: Knight, Sherri <sherri.knight@ncdenr.gov>; Smith, George <george.smith@ncdenr.gov>; Meadows, Susan <susan.meadows @ncdenr.gov>; Kinney, Maureen <Maureen.Kinney@ncdenr.gov> Subject: Draft Permit NC0071463 Center Point Co., LLC-Greensboro Terminal Please find the attached draft permit NC0071463 for Center Point Co., LLC -Greensboro Terminal that will be submitted for public notice. A hard copy will be mailed to the permittee shortly. Please provide your comments, if any, to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ / DWR / NPDES Program no later than November 11, 2016. Sincerely Derek C Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office d erek.denard An od en r. g ov N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 'Nothing Compares - Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Denard, Derek From: Meadows, Susan Sent Wednesday, October 05, 2016 10:36 AM To: Denard, Derek Cc: Corporon, Joe; Knight Sherri; Belnick, Tom; Moore, Cindy Subject RE: Draft Permit NCO071463 Center Point Co., LLC-Greensboro Terminal Okay, that sounds reasonable to me. Susie Susan Meadows Environmental Biologist Aquatic Toxicology Branch DWR/Water Sciences Section Department of Environmental Quality tel: (919) 743-8439 fax: (919) 743-8517 susan.meadows(@ ncdenr.eov 4401 Reedy Creek Road Raleigh, NC 27607 0. "Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Wednesday, October 05, 201610:32 AM To: Meadows, Susan <susan.meadows @ncdenr.gov> Cc: Corporon, Joe <joe.corporon@ncdenr.gov>; Knight, Sherri <sherri.knight@ncdenr.gov>; Belnick, Tom <tom.belnick@ncdenr.gov>; Moore, Cindy <cindy.a.moore@ncdenr.gov> Subject: Re: Draft Permit N00071463 Center Point Co., LLC-Greensboro Terminal If I understand this correctly, the reason we don't want them to automatically revert back to annual after passing 4 quarters is that they discharge episodically. They may not be able to sample in the given months on the TOX page. By the time the permit is up for renewal, we would have enough data to determine if they could go back to annual. In other words, automatically reverting back to annual after passing 4 quarters would only work if they had monthly discharges. Derek Denard Environmental Specialist N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard (Mncdenr.aov 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Meadows, Susan Sent: Wednesday, October 5, 201610:18:41 AM To: Denard, Derek Cc: Corporon, Joe; Knight, Sherri; Belnick, Tom; Moore, Cindy Subject: RE: Draft Permit NCO071463 Center Point Co., LLC-Greensboro Terminal Okay, I just want to have a good understanding about this as I am the one that is running Compliance on these facilities with respect to WET testing, so I need to have be clear on what is expected. So, the intent is to change them from Annual Monitoring Only to an Annual Limit - Correct? And if they fail they will revert to quarterly testing permanently until the Division says they can go back to Annual testing — correct? Just wondering... Why can't they run 4 quarterly test (and if they pass all of them) automatically go back to Annual testing? In talking with Cindy Moore about this, we agree that we don't have a problem with it we just need to stay consistent as well as adhering to EPA. So, if this is the intent then we do not have separate language page for this, but 1 would explain it clearly and simply in the cover letter. By stating: If the annual test results in a fail, then the facility will revert to quarterly testing. Susie Susan Meadows Environmental Biologist Aquatic Toxicology Branch DWR/Water Sciences Section Department of Environmental Quality tel: (919) 743-8439 fax: (919) 743-8517 susan. meadows(alncdenr.gov 4401 Reedy Creek Road Raleigh, NC 27607 wo. "Nothing Compares -- . Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Wednesday, October 05, 2016 9:53 AM To: Meadows, Susan <susan.meadows@ncdenr.gov> Cc: Corporon, Joe <ioe.corooron@ncdenr.Rov>; Knight, Sherri <sherri.knight@ncdenr.gov> Subject: Re: Draft Permit NCO071463 Center Point Co., LLC-Greensboro Terminal Susan, We gave them annual monitoring in the effluent table. According to the footnote, once they fail they revert to quarterly following Condition A.3. Joe's thinking is that annual monitoring is conditional upon pass/fail. If we change the TOX page to annual there would be no guidelines for what months we require because we would want them to monitoring quarterly going forward. Would inserting a special condition Into the permit better explain what we are trying to do here? Is there an Annual Acute TOX page that requires them to do quarterly sampling upon failure and remain at quarterly until they request to go back to annual? I'm not sure we have anything parameter code wise and TOX page wise that captures this. Derek Derek Denard Environmental Specialist N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek. denard On cde n r. o ov 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Meadows, Susan Sent: Wednesday, October 5, 2016 8:52 AM To: Denard, Derek Cc: Knight, Sherri Subject: RE: Draft Permit NCO071463 Center Point Co., LLC-Greensboro Terminal Hi Derek, I am still confused. I thought these were going to remain as Annual Monitoring only tests? All of the permits show conflicting information. It's listing Annual testing in the Table, then Quarterly Limit language in the footnote and WET Section AI see below. Acute WET runste lGE6C - Aamr ay Grab Emseel 6. If Acare WE r4ed fails (Tt7EWI, the Perminee shall test each euhsequan discharge event until lellia/ Indicates -pm- after which gwrierIv momtonng shall resume in scomt with Sects m A. (3.). Ifafter ■ subsequent five (5) consecutive Quarterly events, WP.1 results demonstrate no toxicity (i.e.. "peas-). the Permitter may pesitim the Mvisrm to relax monitoring, as data msy warrant. WET -test samples shall be collected com u rently with other P(W samples, as appropriate to morolorins fiequenei— A. (3.) ACUTE TOXICITY PASS/PAIL PERMIT LIMIT (QUARTERLY) [15A NCAC 02B .0500 et seq.] The permitt e, shall conduct acute toxicity tests on a quarterly basis using protocols definod in the North Carolina Procedure Document entitled "Pass`Fail Methodology For Determining Acute Toxicity In A Single Effluent Concentration" (Revised December 2010 or subsequent versions). The monitoring shall be performed sa a Fathcad Minnow (Pirnepholes prtrmelar) 24 hour static test. the effluent concentration at which there may be at no time significant acute mortality is 90:. (defined as treatmcni two in the procedure document). The tests will be performed during the months of January. April, July sod October. These months signify, the first month of each throe month toxicity testing quarter assigned to the facility. Effluent sampling for this testing mutt he obtained dunng representative effluettr discharge and shell he performed at the NI'I)FS permitted final effluent dsscharge helow all treatment pmccs xs. Should an single quarterly coon poring indicate ■ faillure to meet specified limits, then month monitoring will begin Immediately until such time flat a single test Is passed. Upon passing. this monthly test requirement will revert to quarterly in the monlYs specified abos e. NC0000795 - Kinder Morgan- Greensboro Terminal NCO031046 - Colonial Pipeline/001 NCO022209 - Motiva Enterprises LLC-Greensboro NCO026247 - Translvlontaige Operating Company NCO074578 - Magellan Terminal Holdings Greensboro 1 Terminal NCO069256 - TransMontaigne-Piedmont Terminal NCO051161 - Plantation Pipeline Co. (001)(002) NCO042501 - Kinder Morgan Southeast Terminals LLC NCO071463 - Center Point Co., LLC -Greensboro Terminal NC0003671 - Magellan Terminals Holdings, L.P.-Greensboro II Terminal Susan Meadows Environmental Biologist Aquatic Toxicology Branch DWR/Water Sciences Section Department of Environmental Quality tel: (919) 743-8439 fax: (919) 743-8517 susan.meadows@ncdenr.eov 4401 Reedy Creek Road Raleigh, NC 27607 0 " Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Tuesday, October 04, 2016 6:06 PM To: bshelil@aoexoil.com; revansgrn@gmail.com Cc: Knight, Sherri <sherri.knight@ncdenr.Rov>; Smith, George <Reoree.smith@ncdenr.eov>; Meadows, Susan <susan.meadows@ncdenr.eov>; Kinney, Maureen <Maureen.Kinney@ncdenr.eov> Subject: Draft Permit NC0071463 Center Point Co., LLC-Greensboro Terminal Please find the attached draft permit NC0071463 for Center Point Co., LLC -Greensboro Terminal that will be submitted for public notice. A hard copy will be mailed to the permittee shortly. Please provide your comments, if any, to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ / DWR / NPDES Program no later than November 11, 2016. Sincerely, Derek C Denard Environmental Specialist Compliance 8 Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office d erek.denard (Mn cd e n r. oov N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Kr.-V "'Nothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. 11 12 M TIVA ENTERPRISES LLC VIA Email and UPS No. 1 Z71 E42VO294029149 November 07, 2016 Mr. Derek Denard NC Division of Water Resources Water Quality Permitting Section — NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Comments on Draft NPDES Permit NCO022209 Motiva Enterprises LLC -- Greensboro Terminal 101 South Chimney Rock Road, Greensboro Dear Mr. Denard: Motiva Enterprises LLC (Motiva) is providing the following comments on Draft NPDES Permit NCO022209 received via email on October 4, 2016. As stated in your letter dated October 5, 2016, Motiva has made no significant changes to the facility since the last permit renewal and has had no compliance issues; therefore, Motiva is requesting removal of the new limits and analysis added to the draft permit. The additional limits create an added burden to the facility that is not warranted by our historical compliance record. The addition of the monthly average limit of 30.0 mg/L total suspended solids (TSS) is effectively lowering the daily maximum from 45.0 mg/L to 30.0 mg/L since sampling is only required once per month. Furthermore, the 30.0 mg/L TSS level is extremely low compared to the United States Environmental Protection Agency (EPA) Multi -Sector General Permit (MSGP) benchmark of 100 mg/L, which the EPA deems appropriate for compliance monitoring of stormwater discharge from petroleum terminals. Motiva maintains that the current TSS limit is protective of the receiving stream and the waters of the state of North Carolina and requests that a more stringent limit is not added to the permit for TSS. The addition of the turbidity analysis requirement is not warranted as the receiving stream is a dry creek bed with intermittent flow and often zero flow and, therefore, does not support a fish population. The existing 45.0 mg/L daily maximum TSS limit provides sufficient protection of aquatic life in the receiving stream. Motiva requests that the turbidity analysis not be added to the permit. Alternatively, if turbidity analysis must be added, it should be as a "monitoring only" parameter as the EPA MSGP includes a benchmark level only for turbidity. 101 S Chimney Rock Rd Greensboro, NC 27409 Phone: 336-299-0331 Page 2: Comments on Draft NPDES Permit No. NCO022209 Motiva Enterprises LLC Greensboro Terminal Thank you for the opportunity to provide comments on the draft permit. If you have any questions, please contact Jennifer Bothwell, Environmental Coordinator at 860-749-2839 or email Jennifer. bothwell(-motivaent.com. Very truly yours, MOTIVA ENTERPRISES LLC C �. Otto Muha Terminal Superintendent Cc: J. Bothwell, Motiva File: 550-04 Denard, Derek From: jennifer.bothwell@motivaent.com Sent: Monday, November 07, 2016 1:36 PM To: Denard, Derek Subject: RE: Resubmission for Public Notice Draft Permit NC22209 Motiva Enterprises, LLC - Greensboro Terminal Attachments: GBO NPDES Renewal Comment Ltr 110716.pdf Derek, The attached letter contains Motiva's comments on the Draft Discharge Permit NC22209. Thank you for the opportunity to provide comments on this draft permit. Jennifer Bothwell Environmental Coordinator Motiva Enterprises LLC 481 East Shore Parkway New Haven, CT 06512 Office: 860-749-2839 From: Denard, Derek [mailto:derek.denard@ncdenr.gov] Sent: Tuesday, October 04, 2016 5:48 PM To: Muha, Otto P MOTIVA-DVM/613/362; Bothwell, Jennifer L MOTIVA-DVM/613/12 Cc: Knight, Sherri; Smith, George; Kinney, Maureen; Meadows, Susan Subject: Resubmission for Public Notice Draft Permit NC22209 Motiva Enterprises, LLC - Greensboro Terminal Mr. Muha & Ms. Bothwell, Please find the attached draft NC22209 Motiva Enterprises, LLC - Greensboro Terminal that will be resubmitted for public notice. Please provide your comments, if any, to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ/ DWR / NPDES Program no later than November 11, 2016. Sincerely, Derek C Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard(o)ncdenr.gov N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 1 VIA Email and UPS No. 1 Z71 E42VO294029149 November 07, 2016 Mr. Derek Denard NC Division of Water Resources Water Quality Permitting Section — NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Comments on Draft NPDES Permit NCO022209 Motiva Enterprises LLC -- Greensboro Terminal 101 South Chimney Rock Road, Greensboro Dear Mr. Denard: M TIVA ENTERPRISES LLC RECEIVED/NCDEWWR NOV 0 7 2016 Water Quality Permitting Section Motiva Enterprises LLC (Motiva) is providing the following comments on Draft NPDES Permit NCO022209 received via email on October 4, 2016. As stated in your letter dated October 5, 2016, Motiva has made no significant changes to the facility since the last permit renewal and has had no compliance issues; therefore, Motiva is requesting removal of the new limits and analysis added to the draft permit. The additional limits create an added burden to the facility that is not warranted by our historical compliance record. The addition of the monthly average limit of 30.0 mg/L total suspended solids (TSS) is effectively lowering the daily maximum from 45.0 mg/L to 30.0 mg/L since sampling is only required once per month. Furthermore, the 30.0 mg/L TSS level is extremely low compared to the United States Environmental Protection Agency (EPA) Multi -Sector General Permit (MSGP) benchmark of 100 mg/L, which the EPA deems appropriate for compliance monitoring of stormwater discharge from petroleum terminals. Motiva maintains that the current TSS limit is protective of the receiving stream and the waters of the state of North Carolina and requests that a more stringent limit is not added to the permit for TSS. The addition of the turbidity analysis requirement is not warranted as the receiving stream is a dry creek bed with intermittent flow and often zero flow and, therefore, does not support a fish population. The existing 45.0 mg/L daily maximum TSS limit provides sufficient protection of aquatic life in the receiving stream. Motiva requests that the turbidity analysis not be added to the permit. Alternatively, if turbidity analysis must be added, it should be as a "monitoring only" parameter as the EPA MSGP includes a benchmark level only for turbidity. 101 S Chimney Rock Rd Greensboro, NC 27409 Phone: 336-299-0331 Page 2: Comments on Draft NPDES Permit No. NCO022209 Motiva Enterprises LLC Greensboro Terminal Thank you for the opportunity to provide comments on the draft permit. If you have any questions, please contact Jennifer Bothwell, Environmental Coordinator at 860-749-2839 or email Jennifer. bothwellC&-motivaent.com. Very truly yours, MOTIVA ENTERPRISES LLC Otto Muha Terminal Superintendent Cc: J. Bothwell, Motiva File: 550-04 Greensboro News Record Advertising Affidavit 200 E. Market St Greensboro, NC. 27401 (336)373-7287 NCDENR - DIVISION OF WATER RESOURCES IBT PROGRAM, WATER SUPPLY PLANNING BRANCH 1611 MAIL SERVICE CENTER RALEIGH, NC 27699 Account Number 4019534 Date October 10, 2016 PO Number Order Category Description 0000273814 Legal Notices Public Notice North Carolina Environmental Management Commission/ NPDES Ur Publisher of the Greensboro News Record Before the undersigned, a Notary Public of Guilford, North Carolina, duly commissioned, qualified, and authorized by law to administer oaths, personally appeared the Publisher Representative who by being duly swom deposes and says: that he/she is the Publisher's Representative of the Greensboro News Record, engaged in the publishing of a newspaper known as Greensboro News Record, published, issued and entered as second class mail in the City of Greensboro, in said County and State: that he/she is authorized to make this affidavit and swom statement: that the notice or other legal advertisement, a copy of which is attached hereto, was published in the Greensboro News Record on the following dates: 10110/2016 and that the said newspaper in which such notice, paper document, or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all the requirements and qualifications of Section 1-597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning of Section 1-597 of the General Statutes of North Carolina. signature ofperso, m ng affidavit) Swom to and subscribed before me the V day oCC;b 4,4 20 RO LEA ANNE LAMB (Notary Public) NOTARY PUBLIC STATE OF NORTH CAROLINA GUILFORD COUNTY MY COMMISSION EXPIRES 06-15-19 THIS IS NOT A BILL. PLEASE PAY FROM INVOICE. THANK YOU _,ewtx- Deep River, Cape Fear River Basin Kinder Morgan Southeast Terminals, LLC applied to renew NPDES permit for the Greensboro 2 Terminal [NC0042501), 6376 Burnt Poplar Rd, Guilford County, surface -water pol- lution prevention system discharging treated stormwater/wastewater to East Fork Deep River, Cape Fear Riv- er Basin. Plantation Pipe Line Company ap- plied to renew NPDES permit for the Greensboro Breakout Tank Farm [NC0051161], 6907-A W Market St, Guilford County, surface -water pol- lution prevention system discharging treated stormwater/wastewater to East Fork Deep River, Cape Fear Riv- er Basin. TransMontaigne Operating Compa- ny, L.P. applied to renew NPDES per- mit for the Piedmont Greensboro Terminal [NC00692561, 6907E W Market St, Guilford County, surface - water pollution prevention system discharging treated stormwater/wastewater to East Fork Deep River, Cape Fear River Basin. Center Point Terminal Company, LLC applied to renew NPDES permit for the Greensboro Terminal [NC00714631, 6900 W. Market St., Guilford County, surface -water pol- lution prevention system discharging treated stormwater/wastewater to Horsepen Creek, Cape Fear River Ba. sin. Magellan Terminals Holdings, L.P. applied to renew NPDES permit for the Greensboro I Terminal [NC00745781, 115 Chimneyrock Rd, Guilford County, surface -water pol- lution prevention system discharging treated storm water/wastewater to Long Branch, Cape Fear River Basin. Motiva Enterprises, LLC applied to renew NPDES permit for the Greens. boro Terminal [NC00222091, 101 S. Chimney Rock Rd, Guilford County, surface -water pollution prevention system discharging treated stormwater/wastewater to Long Branch, Cape Fear River Basin. M TIVA ENTERPRISES LLC VIA Email and UPS No. 1 Z71 E42VO299034384 September 15, 2016 Mr. Derek Denard NC Division of Water Resources Water Quality Permitting Section — NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Comments on Draft NPDES Permit NCO022209 Motiva Enterprises LLC -- Greensboro Terminal 101 South Chimney Rock Road, Greensboro Dear Mr. Denard: Motiva Enterprises LLC (Motiva) is providing the following comments on Draft NPDES Permit NCO022209 received via email on August 11, 2016. As stated in your letter dated August 10, 2016, Motiva has made no significant changes to the facility since the last permit renewal and has had no compliance issues; therefore, Motiva is requesting removal of the new limits and analysis added to the draft permit. The additional limits create an added burden to the facility that is not warranted by our historical compliance record. The addition of turbidity analysis requirement is not warranted as the receiving stream is a dry creek bed that has intermittent flow and often zero flow, and therefore does not support a fish population. The existing total suspended solids limit should provide sufficient protection of aquatic life in the receiving stream. Motiva requests that the turbidity analysis not be added to the permit or that the turbidity analysis be added as a "monitoring only" parameter. Oil & Grease has rarely been detected in the effluent stream and the highest reported level during the current permit term was 9.8 mg/L, which is well below the proposed limit of 15 mg/L. Motiva requests that Oil & Grease continue to be a "monitoring only" parameter in the permit. 101 S Chimney Rock Rd Greensboro, NC 27409 Phone: 336-299-0331 Page 2: Draft NPDES Permit No. NCO022209 Motiva Enterprises LLC Greensboro Terminal Thank you for the opportunity to provide comments on the draft permit. If you have any questions, please contact Jennifer Bothwell, Environmental Coordinator at 860-749-2839 or email Jennifer. bothwell(-motivaent com. Very truly yours, MOTIVA ENTERPRISES LLC Otto Muha Terminal Superintendent Cc: J. Bothwell, Motiva File: 550-04 Denard, Derek From: jennifer.bothwelI@motivaent.com Sent: Thursday, September 15, 2016 8:31 AM To: Denard, Derek Cc: Otto.Muha@motivaent.com; Kristine.Pelt@motivaent.com Subject: RE: Draft NPDES Permit NCO022209 - Motiva Enterprises, LLC - Greensboro Terminal Attachments: GBO NPDES Renewal Comment Ltr 091516.pdf Follow Up Flag: Follow up Flag Status: Flagged Derek, Attached are Motiva's comments on the draft NPDES permit for the Greensboro Terminal. Thank you for the opportunity to provide comments on this draft permit. Jennifer Bothwell Environmental Coordinator Motiva Enterprises LLC 481 East Shore Parkway New Haven, CT 06512 Office: 860-749-2839 From: Denard, Derek [mailto:derek.denard@ncdenr.gov] Sent: Thursday, August 11, 2016 2:04 PM To: Muha, Otto P MOTIVA-DVM/613/362; Bothwell, Jennifer L MOTIVA-DVM/613/12 Cc: Knight, Sherri; Smith, George; Mickey, Mike; Hudson, Eric; Kinney, Maureen; Meadows, Susan Subject: Draft NPDES Permit NCO022209 - Motiva Enterprises, LLC - Greensboro Terminal Mr. Muha, Please find the attached copy of the draft permit and factsheet for Draft NPDES Permit NCO022209 - Motiva Enterprises, LLC - Greensboro Terminal. A hard copy will be mailed to the permittee shortly. Please provide your comments, if any, to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ / DWR / NPDES Program no later than September 16, 2016. Sincerely, Derek C Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard(a)ncdenr.gov N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center PAT MCCRORY Governor DONALD R. VAN DER VAART WaterResources ENVIRONMENTAL QUALITY August 10, 2016 10 1040, Lei RIZ1 W To: E ' son Regional Engineer (DWR/PWSS)�s Winston-Salem Regional Office From: Derek Denard DWR / Water Quality Permitting Section 919-807-6307; Fax 919-807-6495; derek.denard@ncdenr.gov Secretary S. JAY ZIMMERMAN Director Subject: Review of Discharge from for Outfall 001 into an unnamed tributary (UT) to Long Branch [17-2-1-(1)], a waterbody classified WS-IV:* located within Subbasin 03-06-08 WC: 030300030102] of the Cape Fear River Basin for: NPDES permit NC0022209 Motiva Enterprises, LLC — Greensboro Terminal Industrial Process & Commercial -- Petroleum Bulk -Storage Facility located at 101 S. Chimney Rock Road, Greensboro, NC 27409 Please provide your comments by September 16, 2016 [email OK] RESPONSE: A-1000 I concur with the issuance of this permit provided the Permittee properly operates and maintains the facility; the Permittee meets the stated effluent limits prior to discharge; and the discharge does not contravene the designated water quality standards. I concur with issuance of the above permit provided the following conditions are met: I oppose the issuance of the above permit based on reasons stated below, or attached: Signed: - cc: file Date: State of North Carolina I Environmental Quality I water Resources 1617 Mail service Center I Raleigh, North Carolina 27699-1617 919 807 6300 IA/ Denard, Derek From: Mickey, Mike Sent: Monday, August 15, 2016 3:38 PM To: Denard, Derek Subject: RE: Draft NPDES Permit NCO022209 - Motiva Enterprises, LLC - Greensboro Terminal Correct. No groundwater remediation. The incorrect wording has been carried over for many permit cycles. Mike.Mickev@NCDENR.gov NC DEQ Winston-Salem Regional Office Division of Water Resources — Water Quality Programs 450 W. Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 Phone: (336) 776-9697 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Monday, August 15, 2016 3:27 PM To: Mickey, Mike <mike.mickey@ncdenr.gov> Subject: RE: Draft NPDES Permit NCO022209 - Motiva Enterprises, LLC - Greensboro Terminal Mike, So no groundwater remediation for this one? I inherited some stuff from many renewals ago. Glad to get it right this time. Wish I would have caught the C0530. The last person did it but I should have caught it. Derek From: Mickey, Mike Sent: Monday, August 15, 2016 3:13 PM To: Denard, Derek <derek.denard@ncdenr.gov> Subject: RE: Draft NPDES Permit NCO022209 - Motiva Enterprises, LLC - Greensboro Terminal Derek — The parameter code for TSS is wrong. It should be C0530. Suggested changes in to description of system: • Diked areas (secondary containment of ASTs and piping) Truck loading -rack drains that flow to a concrete pit with sump pump. The pit water is transferred to a 8,000 gallon AST with hydrocarbon detector (the tank contents is typically released into diked area but can be hauled off -site if contaminated). • Settling pond (with point source outfall) • Discharge control valve, manually operated (normally closed) 1 FYI - There is no groundwater remediation system present. There is no oil water separator. Sorry for all these changes. Noboby ever bothered to read the system descriptions in past drafts. Mike.Mickey@NCDENR.gov NC DEQ Winston-Salem Regional Office Division of Water Resources — Water Quality Programs 450 W. Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 Phone: (336) 776-9697 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Thursday, August 11, 2016 2:04 PM To: otto.muha@motivaent.com; Jennifer.Bothwell@motivaent.com Cc: Knight, Sherri <sherri.knight@ncdenr.gov>; Smith, George <george.smith@ncdenr.gov>; Mickey, Mike <mike.mickey@ncdenr.gov>; Hudson, Eric <eric.hudson@ncdenr.gov>; Kinney, Maureen <Maureen.Kinney@ncdenr.gov>; Meadows, Susan <susan.meadows@ncdenr.gov> Subject: Draft NPDES Permit NC0022209 - Motiva Enterprises, LLC - Greensboro Terminal Mr. Muha, Please find the attached copy of the draft permit and factsheet for Draft NPDES Permit NC0022209 - Motiva Enterprises, LLC - Greensboro Terminal. A hard copy will be mailed to the permittee shortly. Please provide your comments, if any, to me via email [derek.denard@ncdenr.gov] or write to my attention care of DEQ / DWR / NPDES Program no later than September 16, 2016. Sincerely, Derek C Denard Environmental Specialist Compliance & Expedited Permitting Unit N.C. Division of Water Resources N.C. Department of Environmental Quality 919 807 6307 office derek.denard(cDncdenr.gov N. C. Division of Water Resources Water Quality Permitting Section - NPDES 1617 Mail Service Center Raleigh, NC 27699-1617 h1 0-. Nothing Compares -� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. Denard, Derek From: Mickey, Mike Sent: Monday, August 15, 2016 2:09 PM To: Denard, Derek Subject: RE: Tank Farm Drafts Makes sense. Thanks for digging up the additional info. Mike. Mike.Mickey@NCDENR.Qov NC DEQ Winston-Salem Regional Office Division of Water Resources — Water Quality Programs 450 W. Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 Phone: (336) 776-9697 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Denard, Derek Sent: Monday, August 15, 2016 1:55 PM To: Mickey, Mike <mike.mickey@ncdenr.gov> Subject: RE: Tank Farm Drafts Mike, See below what Joe Corporon wrote up so far as a rational for turbidity and O&G. Please but read on afterward below as I dig deeper. 4. Oil & Grease [00556] vs. EPA 1664 [STG-HEM] Because these facilities have potential to discharge heavy hydrocarbons, they shall monitor O&G._ Recommendations: Under table EFFLUENT CHARACTERISTICS [permit section A. (1.)]: ➢ Monitor Monthly— if not present, add permit limit of 15 mg/L. ➢ replace test method for "Oil & Grease" with "Oil & Grease - EPA Method 1664 [STG-HEM]." ➢ Include number EPA 1664 [column 11; 00556 in column 2 stays the same until 1BIMS is updated). ➢ in BIMS, retain the parameter code 00556 [1664 will not appear] ➢ Based on the current narrative, 0&G shall be limited by a Daily Max only (if discharge is episodic); If continuous, add both DM and MA limits. Delete existing O&G footnote >: "Where possible, the grab sample for Oil & Grease should be skimmed from the water surface of a quiescent (calm water) zone." 1 Rationale: Previously used test method for Oil & Grease targets animal and vegetable fats, oils and greases typical for 100% domestic discharges. Method 1664 -STG-HEM [silica gel transfer -hexane extraction method] targets non - polar oil and grease more typical of industrial waste discharges. The previous footnote directing samplers to "...skim from the water surface of a quiescent zone..." is hereby deemed inappropriate and shall be deleted. 5. Turbidity Because it has a standard (50 NTU), facilities shall monitor Turbidity._ Recommendations: • If no data exist, monitor Quarterly, minimum. • To evaluate compliance, use all available data. • If RP exists (based on 50 NTU) - add limit based on RP; increase monitor to Monthly. Include the following footnote: "Effluent turbidity shall not cause receiving stream turbidity to exceed 50 NTU. If effluent turbidity exceeds 50 NTU, the Permittee shall sample upstream and downstream (as appropriate considering zero -flow receiving -stream conditions). Non-compliance with this Standard may require additional stream monitoring and a Turbidity Corrective Action Plan (TCAP)." Rationale: EPA questioned the potential for these facilities to violate stream standards because little or no turbidity data were available. If sufficient data exists, evaluate reasonable potential. If no data, add monitoring and include footnote to Table A. (1.), and others as appropriate (see above). However, digging deeper into O&G, which is a native limit found in 15A NCAC 026 .0211(12). Since we are asking them to use Method 1664 -STG-HEM, which is a for non -polar hydrocarbons then we have a better measure of 0&G for a facility that stores millions of gallons of non -polar hydrocarbons. For O&G with a limit, we have seen this before in other permits including stormwater. For wastewater NPDES I found one example. This in a factsheet for the NC500000 for cooling water that explains what we are thinking of as far as a native limit: Oil & Grease limits are governed by 15A NCAC 26.0211 (3)(f). The specific limit of 20 mg/I is a numeric interpretation of the minimum standard listed in .0211(3)(f). A discharge of 20 mg/I into the receiving stream would cause a visible sheen (as described in .0211 (3)(f)) and would constitute an unacceptable contamination of the receiving stream. Please note 2B was rewritten with O&G found at (12) not (3)(f). So, the best rationale for 0&G is 15A NCAC 02B .0211(12). 0&G is a parameter of concern and has a native limit. The best rationale for Turbidity is 15A NCAC 02B .0211(21). It is pretty clear that they have to meet 50 NTU and yes they can look at up and down stream for comparison for compliance. However, these facilities discharge to zero flow conditions. So the stream limit of 50 NTU applies at the end of the pipe. Hope this makes sense. We can discuss further. Derek From: Mickey, Mike Sent: Monday, August 15, 2016 11:08 AM To: Denard, Derek <derek.denard@ncdenr.gov> Subject: Tank Farm Drafts Derek — Was surprised to see that turbidity (monitoring and limit) was added to all the permits as well as a limit for O&G. What was the rational? The cover letters did not mention a reason for the change? Thanks, Mike. Mike.Mickey@NCDENR.gov NC DEQ Winston-Salem Regional Office Division of Water Resources — Water Quality Programs 450 W. Hanes Mill Road, Suite 300, Winston-Salem, NC 27105 Phone: (336) 776-9697 E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. M TIVA ENTERPRISES LLC VIA UPS No. I Z7 I E42VO296211723 23 February 2016 Director NCDENR, Division of Water Quality NPDES Unit 1617 Mail Service Center Raleigh, North Carolina 27699-1617 RE: NPDES Permit No. NCO022209 Renewal Application Motiva Enterprises LLC Greensboro Terminal 101 South Chimney Rock Road, Greensboro Dear Director: RECEIVEMCDEUDWR FEB 2 b 20' water Quality permitting Section Motiva Enterprises LLC (Motiva) owns and operates a petroleum bulk storage terminal at 101 South Chimney Rock Road, Greensboro, Guilford County, NC. This facility discharges storm water under NPDES Permit No. NC0022209. Motiva is requesting renewal of this permit. Attached is a copy of the NPDES Permit Application — Short Form C, a table summarizing discharge analytical results in 2015, a conceptual flow diagram, and a facility location map. Please note the following: • The contributions to this discharge have not changed; however, a water holding tank has been added after the oil/water separator as indicated on the attached Figure 1. • The facility does not generate sludge and therefore is not required to submit a sludge management plan. If you have any questions upon receipt of this package, please contact me at 860-749-2839 or email Jennifer.bothwell@motivaent.com. Very truly yours, MOTIVA ENTERPRISES LLC 01(--���� Jennifer L. Bothwell Environmental Coordinator Attachments File: 550-03 101 S. Chimney Rock Rd Greensboro, NC 27409 Phone: 336-299-0331 NPDES PERMIT APPLICATION — SHORT FORM C — Minor Industrial Minor industrial, manufacturing and commercial facilities. Mail the complete application to: N. C. DENR / Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 NPDES Permit Number INCO022209 If you are completing this form in computer use the TAB key or the up - down arrows to move from one field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type. 1. Contact Information: Owner Name Facility Name Mailing Address City State / Zip Code Telephone Number Fax Number e-mail Address RECEIVED/NCDEQUOR Motiva Enterprises LLC FEB 2 6 2016 Motiva Enterprises LLC Greensboro Terminal water Quality 101 S. Chimney Rock Road Permitting Section Greensboro NC, 27409 (336) 299-0331 (336) 292-4494 otto.muha@motivaent.com 2. Location of facility producing discharge: Check here if same as above Street Address or State Road City State / Zip Code County 3. Operator Information: Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the Operator in Responsible Charge or ORC) Name Motiva Enterprises LLC Mailing Address 101 S. Chimney Rock Road City Greensboro State / Zip Code NC, 27409 Telephone Number (336) 299-0331 Fax Number (336) 292-4494 Page 1 of 5 C-MI 05/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 4. Ownership Status: Federal ❑ State ❑ Private ED 5. Standard Industrial Classification (SIC) code(s): 5171 6. Number of employees: 3 Public ❑ 7. Describe the treatment system List all installed waste treatment components with capacities, describe the processes that generate wastewaters. If the space provided is not sufficient attach a separate sheet of paper with the system description. Stormwater from the loading rack area gravity flows to an 11,500 gallon in -ground SPCC Tank (oil/water separator). Water flows from the separator via gravity to an 8,000 gallon above- ground tank within the tank farm diked area. This tank is equipped with a hydrocarbon sensor and level gauging system. After confirming no hydrocarbons are present, a normally closed valve is opened to release water to the tank farm diked area. The water flows via gravity to the retention pond and comingles with stormwater collected within the diked area. Water from the retention pond is discharged as need under operator supervision via gravity flow through Outfall 001. Recovered product from the SPCC Tank is removed via vacuum truck for off -site disposal. S. Is facility covered under federal effluent limitation guidelines? No ® Yes ❑ If yes, specify the category? 9. Principal product(s) produced: No products are produced — the facility is a terminal that stores gasoline and petroleum distillates Principal raw material(s) consumed: Not Applicable (the values below are based on throughput of the storage facility) Briefly describe the manufacturing process[es]: The facility is a distribution terminal for gasoline and petroleum distillates. It does not produce, manufacture, or consume products or raw materials. Gasoline and distillates are received via pipeline and stored in aboveground storage tanks. Gasoline and distillate additives are received via truck. All products leave the terminal by tanker trucks loaded through the terminal's loading rack. 10. Amount of principal product produced or raw material consumed (List specific amounts consumed and/or units of production over the last three nears) Product Produced or Raw Material Product Produced or Raw Material Consumed Consumed AVERAGE E per Day 750,422 gallons 1,174,163 gallons 25,783,569 gallons per Month 22,825,342 gallons 281,329,027 gallons per Year 273,904,104 gallons 11. Frequency of discharge: Continuous ❑ Intermittent Page 2 of 5 GMI 05/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. If intermittent: Days per week & Duration discharge occurs: Varies with rainfall 12. Types of wastewater discharged to surface waters only Discharge Flow GALLONS PER DAY) Sanitary - monthly average N/A Utility water, etc. - monthly average N/A Process water - monthly average N/A 328,600 gallons per month Stormwater - monthly average 79,660 gal per discharge (gallons and number of day of discharge are dependent on rainfall Other - monthly average Explain: N/A Monthly Average 328,600 gallons per month total discharge (all types) 79,660 gal per discharge (gallons and number of day of discharge are dependent on rainfall 13. Number of separate discharge points: 1 Outfall Identification number(s) 001 14. Name of receiving stream(s) (Provide a map showing the exact location of each outfall, including latitude and longitudes Unnamed Tributary to Long Branch in the Cape Fear River Basin 15. Effluent Data Provide data for the parameters listed. Temperature and pH shall be grab samples, for all other parameters 24-hour composite sampling shall be used. If multiple analyses are reported, report daily maximum and monthly average. If only one analysis is reported, report as daily maximum. Parameter Daily Maximum Monthly Average Units of Measurement Biochemical Oxygen Demand (BOD5) See Attached Table Chemical Oxygen Demand (COD) Total Organic Carbon Total Suspended Solids Ammonia as N Temperature (Summer) Temperature (Winter) pH Fecal Coliform (If sanitary waste is present) Total Residual Chlorine (if chlorine is used) Page 3 of 5 GMI 05/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 16. List all permits, construction approvals and/or applications (check all that apply and provide permit numbers or check none if not applicabler Type Permit Number Type Permit Number Hazardous Waste (RCRA) NCD096165121 NESHAPS (CAA) None UIC (SDWA) None Ocean Dumping (MPRSA) None NPDES NCO022209 Dredge or fill (Section 404 or CWA) None PSD (CAA) None Title V For Greensboro Complex None Non -attainment program (CAA) None Other: Synthetic Minor Air Permit 04468R17 17. List any chemicals that may be discharged (Please list and explain source and potential amounts.) None in addition to compounds being analyzed. 18. Is this facility located on Indian country? (check one) Yes ❑ No Page 4 of 5 C-MI 05/08 NPDES PERMIT APPLICATION - SHORT FORM C - Minor Industrial Minor industrial, manufacturing and commercial facilities. 19. Applicant Certification I certify that I am familiar with the information contained in the application and that to the best of my knowledge and belief such information is true, complete, and accurate. Otto Muha Terminal Superintendent Printed name of Person Signing Title Signature of Applicant ,/l8/��t(.,-e Date North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false.statement representation, or certification in any application, record, report, plan, or other document files or required to be maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device or method required to be operated or maintained under Article 21 or regulations of the Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable by a. fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section 1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both, for a similar offense.) Page 5 of 5 C-MI 05/08 Figure 1 Conceptual Flow Diagram Motiva Enterprises LLC Greensboro Terminal NPDES Permit No. NCO022209 7- Loading Rack Stormwater Recovered Off -site SPCC Tank disposal (Oil/Water Separator) Water Water Holding Tank Tank Farm Stormwater (Diked Area) Retention Pond Outfall 001 Unnamed Tributary to Long Branch Table 1. Outfall 001 Analytical Data January to December 2015 Motiva Enterprises LLC Greensboro Terminal NPDES Permit No. NCO022209 Ethyl Acute Date TSS O&G Phenol Benzene Toluene Benzene Xylenes MTBE Naphthalene Toxicity mg/L mg/L ug/I ug/l ug/I ug/l ug/I ug/l ug/I January <5.00 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0 February <5.00 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0 March <5.00 <5.00 <5.0 <1.0 <1.0 <1.0 <1.0 <5.0 <1.0 April 21.7 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0 May <5.00 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0 >100 June No discharge July <5.00 <5.00 <5.0 <1.0 <1.0 <1.0 <1.0 <5.0 <1.0 August <5.00 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0 September <5.00 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0 October <5.00 <5.00 <5.0 <1.0 <1.0 <1.0 <1.0 <5.0 <1.0 November <5.00 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0 December <5.00 <5.00 <1.0 <1.0 <1.0 <1.0 <1.0