HomeMy WebLinkAboutNC0046892_Technical Correction_20150819NCDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. James W. Lintz, Complex Manager
Motiva Enterprises, LLC
410 Tom Sadler Road
Charlotte, NC 28214
Dear Mr. Lintz:
Donald R. van der Vaart
Secretary
August 19, 2015
Subject: Change-Page(s) to Correct Error
NPDES Permit NCO046892
Motiva Enterprises, LLC
Charlotte South Terminal
6851 Freedom Drive, Charlotte 28214
Mecklenburg County
The Division of Water Resources (the Division) was notified by Jennifer Bothwell, Environmental
Coordinator with Motiva Enterprises, LLC, that quarterly sampling for Chronic Toxicity
(Ceriodaphnia dubia) (TGP3B/TBP3B) would be problematic due to the episodic duration of the
discharges at this facility. Chronic Toxicity was a new requirement in your recently issued permit
(July 20, 2015). The Division's Aquatic Toxicity Branch recommends that monitoring be changed
to Acute Toxicity (Ceriodaphnia dubia) (TGE3B).
Accordingly, we hereby forward the modified permit pages to amend Sections A.(1.) and A.(2.) of
your permit with the following:
Acute Toxicity (Ceriodaphnia dubia) Pass/Fail permit limit (as a grab sample) quarterly
during the months of January, April, July and October.
Please insert these change pages into your existing permit and discard the old pages. We regret any
inconvenience this causes your organization.
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.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Phone: 919-807-63001 Internet: www.ncwaterquality.org
An Equal OpporWnity I Afirmabve Action Employer— Made in part by recycled paper
Mr. Lintz
August 19, 2015
Page 2 of 2
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.
pec ly,�
. Jay Zimmerman, D'
Division of Water Resources, NCDENR
Enclosure: NPDES Permit NCO046892 (Corrected Pages)
he: Central Files
NPDES Program Files
MRO Files/ Attn: Michael Parker
ec: Richard Farmer [Richard.fanner@mecklenburgcountync.gov] [draft permit, Fact Sheet]
Aquatic Toxicology Unit/ Susan Meadows [susan.meadows@ncdenr.gov] [draft permit, Fact Sheet]
Jennifer L. Bothwell, Environmental Coordinator, Motiva Enterprises LLC Dennifer.bothwell@motivaent.com]
James W. Lintz, Complex Manager, Motiva Enterprises LLC dames.lintz@motivaent.com]
Joseph Gorman, Superintendent, Motiva Enterprises LLC Ooseph.gorman@motivaent.com]
Permit NCO046892
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 stormwater from diked areas via Outfall 001. Such discharges shall be limited, monitored and
reported' by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
[par atnetex77,
.Codes]
LIlVIITS
.
MONITORING REQUII2EMENTS1-
Mon`th1
Avera a
` Daily
1Vlazimum`
Measurement
Fre gene
Sample
-
"e
., "Sample
Location
Flow 2 (MGD)
50050
Episodic
2
Effluent
Total Suspended Solids m
C0530
30.0 nWL
45.0 mW1
Monthly
Grab
Effluent
Benzene 3 (µg/L)
34030
1.19 µg/L
Monthly
Grab
Effluent
Toluene 3 (µg/L)
34010
11 µg/L
Monthly
Grab
Effluent
Oil and Grease 4 (mg/L)
EPA Method 1664 SGT-HE
00556
Monthly
Grab
Effluent
Naphthalene 3, 5 (µg/L)
34696
Monthly
Grab
Effluent
Total Recoverable Phenolics 3 (µg/L)
32730
Monthly
Grab
Effluent
Ethyl Benzene 3 (µg/L)
34371
Monthly
Grab
Effluent
Xylene 3 (µg/L)
81551
Monthly
Grab
Effluent
MTBE 3 (µg/L)
22417
Monthly
Grab
Effluent
Turbid' 6(NTU)
00070
50 NTU
Quarterly
Grab
Effluent
Acute Toxicity 7
TGE3B
Quarterly
Grab
Effluent
Footnotes:
1. No late than 270 days from the effective date of this permit, the permittee shall begin submitting
discharge monitoring reports electronically using the Division's eDMR application system [see A.
(4•)]•
2. Flow shall be monitored with each discharge event — During periods of no flow, the
Permittee shall submit a signed, monthly Discharge Monitoring Report (DMR) indicating
"No discharge." Flow may be monitored using any one of four methods:
a) measure flow continuously via weir or flow meter (totalizer preferred);
b) calculate flow (see .Rational Equation ) [see A. (3.)] based on total
rainfall per unit area draining to the outfall;
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
3. WET -test samples shall be collected concurrently with other POC samples, as appropriate to
monitoring frequencies.
4. Oil and Grease with EPA Method 1664 [SGT-HEM] — Where possible, the grab sample for oil and
grease should be skimmed from the surface of a quiescent (calm water) zone.
5. Naphthalene — Provided that the Permittee can demonstrate to the Division that its facility does not
now, nor has ever, stored diesel fuel or other heavy fuels, it may petition to remove monitoring for
naphthalene.
6. Turbidity —Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving -stream
background exceeds 50 NTU, the effluent shall not increase background levels. Non-compliance with
Page 3 of 8
Permit NC0046892
this Standard may require additional stream monitoring and a Turbidity Corrective Action Plan
(TCAP).
7. Acute Toxicity (Ceriodaphnia dubia) Pass/Fail Limit, Quarterly during the months of January,
April, July and October [see section A. (2)].
Conditions:
• There shall be no discharge of floating solids or foam visible in other than trace amounts.
• There shall be no oily sheen traceable from the receiving stream to this outfall.
• Direct discharge of tank solids, tank -bottom water, or the rag Iayer 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.
Wage 4 of 8
Is
Permit NCO046892
A. (2.) ACUTE TOXICITY PASS/FAIL PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0500 et seq.]
The permittee shall conduct acute toxicity tests on a!Yuarterlv basis using protocols defined in the North
Carolina Procedure Document entitled "PasslFail Methodology For Determining Acute Toxicity In A
Single Effluent Concentration" (Revised December 2010 or subsequent versions). The monitoring shall
be performed as a Ceriodaphnia dubia 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
TGE3B. 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
1623 Mail Service Center
Raleigh, North Carolina 27699-1623
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
Permit NCO046892
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. (3.) FLOW MEASUREMENT RATIONAL [G.S. 143-215.1(b)]
The Rational Equation: Q=KuCIA, where:
Q = flow (peak flow rate (cfs or m3/sec)
Ku = units conversation factor =1.008 for U.S. standard units (usually
ignored because it is so close to 1), or 0.278 for SI units
C = dimensionless runoff coefficient for the watershed, loosely defined
as the ratio of runoff to rainfall
I = intensity of rainfall taken from the intensity -duration -frequency
curves for the specified design return period at the time of
concentration, tc (in/h or mm/h). tc = time of concentration (time
after 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 regimes drainage area.
Page 6 of 8
DENR / DWR / NPDES
EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT
NPDES Permit NCO046892
Derek Denard, Compliance & Expedited Permitting Unit / 919-807-6307 18Aug2015
Facility Information
Applicant/Facility Name
Motiva Enterprises, LLC/Charlotte South Terminal
Applicant Address
410 Tom Sadler Rd, Charlotte NC 28214
Facility Address
6851 Freedom Drive, Charlotte NC 28214
Permitted Flow (MGD)
not limited
Type of Waste
100% Industrial, fuel (bulk storage), groundwater remediation
Facility Class
PC-1
County
Mecklenburg
Permit Status
Renewal
.Regional
...Office.
MRO
Stream Characteristics.
Receiving Stream
UT to Long Creek
Stream Classification
WS-IV
Stream Segment
[11-120-(2.5)]
Drainage basin
Catawba
Summer 7Q10 (cfs).
0
Subbasin
03-08-34
Winter 7Q10 (cfs)
0
Use Support
Supporting
30Q2 (cfs).
0
303(d) Listed
No
Average Flow (cfs)
0
-State Grid
F 15 S W
IWC (%)
100%
USGS Topo Quad
Mt. Island Lake, NC
Facility SummM
This facility is an industrial (flow <1 MGD) collecting stormwater from a Surface -Water Pollution
Prevention System in proximity to above -ground storage tanks (ASTs). Facilities include surface bulk -
storage of petroleum hydrocarbon fuels in excess of one million gallons, fuel -truck loading racks and
discharge form a GW-REM system. There are no significant changes to your facility the last permit
renewal. The facility consists of the following wastewater treatment units:
• bermed areas (secondary containment for ASTs)
• oil -water separator [1,500-gallons]
(truck -loading rack wastes disposed at a permitted facility off -site)
• oil -water separator (GW remediation)
• three (3) granulated carbon filters (GW remediation)
• air stripper (GW remediation)
• detention pond (with hand -operated discharge valve, normally closed)
Monthly average FLOW (MGD) — Last 36 months Mar2012-1762015:
[Ave 0.155 MGD; Maximum, Monthly average flow = 0.297 MGD;
Minimum, Monthly average flow = 0.004]
Year
Maximum flow (daily)
Minimum flow(daily)
Average (daily)
Number Discharges (daily)
2012
0.3712
0.0347
0.1758
30
2013
0.4761
0.0004
0.1784
43
2014
0.5829
0.0001
0.1471
41
Fact Sheet
Renewal 2015 -- NPDES Permit NCO046892
Page
Toxici —The previous permit required Acute Toxicity Monitoring testing using Pimephales promelas to
be performed on an annual basis as a 24-hour static [TAE6C]. The facility has passed toxicity monitoring
over the past four and a half years. Chronic [TGP3B] (Ceriodaphnia dubia) is required for groundwater
remediation discharges since on -site groundwater remediation (GW-REM) wastestreams are deemed
complex and not episodic. However, since discharges at this facility are managed as batch discharges
(episodic) along with stormwater, Acute Toxicity (Ceriodaphnia dubia) Pass/Fail permit limit (as a grab
sample) quarterly during the months of January, April, July and October is recommend by the Aquatic
Toxicity Branch for this permit.
Compliance History —The facility has been compliant for the past five (5) years.
For Renewal — This permit reflects discharge at Outfall 001. DWR updated the following:
• added updates to facility map, outfall locations and parameter codes
• total Suspended Solids (TSS) monitored monthly with a Monthly Average Limit of 30.0 mg/L and a
Daily Average Limit of 45.0 mg/L
• total Benzene monitoring Monthly with a monthly average limit of 1.19 µg/L
• total Toluene monitoring Monthly with a monthly average limit of 11 µg/L
• replaced Phenol (single compound) [34694] with Total Recoverable Phenolics [32730].
• for Oil & Grease [00556) the parameter code remains the same for submitting DMR/eDMR, but
EPA method 1664 (SGT-HEM) is used with results in mg/L
• changed toxicity monitoring to Acute Toxicity (Ceriodaphnia dubia) Pass/Fail permit limit (as a grab
sample) quarterly during the months of January, April, July and October [Section A. (2.)]
• added Electronic Reporting - Discharge Monitoring Reports page Section A. (4.).
Stream — Discharge from WWTP for Outfall 001 is into an unnamed tributary to Long Creek [Stream
Segment 11-120-(2.5)]. The segment is listed as "supporting" it's in the 2014 North Carolina Integrated
report and 303(d) list.
RPA — A Reasonable Potential Analysis (RPA) was conducted on toluene, benzene, ethyl benzene,
naphthalene, xylene (mixture), total phenolic compounds, MTBE, Manganese and Iron effluent parameters
because Discharge Monitoring Reports (DMRs) reported concentration above method -detection levels
(MDLs) for the past four and a half (4 '/2) years Sept2011-Feb2015 data. [See attached RPA summary
sheets.]
• Benzene effluent data suggest reasonable potential to exceed its standard of 1.19 µg /L. Renewal
will require monthly monitoring of Benzene with a Daily Average Limit of 1.19 µg /L.
• Toluene effluent data suggest reasonable potential to exceed its standard of 11 µg /L. Renewal will
require monthly monitoring of Toluene with a Daily Average Limit of 11 µg /L.
• Turbidity effluent did not show reasonable potential to exceed 50 NTU. Monitoring was left as
monthly with 50 NTU limit due to Manganese issues and consistency with other parameters.
Fact Sheet
Renewal 2015 -- NPDES NCO046892
Page 2
Pe
Denard, Derek
From: jennifer.bothwell@motivaent.com
Sent: Thursday, August 13, 2015 10:29 AM
To: Meadows, Susan; Denard, Derek
Subject: RE: Motiva Enterprises Charlotte North Terminal Permit NC0022187
Yes I agree.
Thank you,
Jennifer
From: Meadows, Susan[mailto:susan.meadowsCabncdenr.aovl
Sent: Thursday, August 13, 2015 9:21 AM
To: Denard, Derek
Cc: Bothwell, Jennifer L MOTIVA-DVM/613/12
Subject: RE: Motiva Enterprises Charlotte North Terminal Permit NC0022187
Hi Derek,
It appears that NC0046892 - Motiva South is also in the predicament. They just do not have enough flow to support a
chronic, multi -day sampling schedule.
Susie
Susan Meadows, Environmental Biologist
Aquatic Toxicology Branch
DWR/Water Sciences Section
4401 Reedy Creek Road Raleigh, NC 27607
susa n. meadows@ncdenr.gov
tel: (919) 743-8439
fax: (919) 743-8517
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: Wednesday, August 12, 2015 4:03 PM
To: iennifer.bothwell@motivaent.com
Cc: Hennessy, John <iohn.hen nessy@ncdenr.eov>; Meadows, Susan <susan.meadows@ncdenr.gov>; Moore, Cindy
<ci nd v. a. moo re @ ncde n r.eov>
Subject: RE: Motiva Enterprises Charlotte North Terminal Permit NC0022187
Jennifer,
Sorry for any misunderstanding, but the final copy (see attached) that was e-mail to you had been signed (July 20, 2015),
issued and processed before our discussion with the Aquatic Toxicology Branch. Sorry, there was a delay in mailing that
final hard copy. A permit correction to change to Chronic (Ceriodaphnia dubia) to Acute (Ceriodaphnia dubia) is being
reviewed by my supervisor with comments from the Susan Meadows with the Aquatic Toxicology Branch. The permit
correction has not been approved and issued yet.
I would like to further clarify that the Aquatic Toxicology Branch recommended Acute (Ceriodaphnia dubia)-grab and
not Acute (Fathead Minnow) as required in the previous permit.
While we are on the subject are you ok with sampling Chronic (Ceriodaphnia dubia) for NC0046892 Motiva South (see
attached)? Do you have the same issues with multiple day sampling as Chronic? Otherwise, Chronic Toxicity
(Ceriodaphnia dubia) sampling is consistent with our strategy for groundwater remediation discharges. Please let me
know if you have any comments for that permit as well.
Again, I'm sorry for any misunderstanding or inconvenience.
Sincerely,
Derek
Derek C Denard
EmironmemalSpecvi;t
NCDENR UN,,km of Water Resource;
Water Quardy Pere mng season
Compliance& Expadrted Permitting Una
(919) W7.6307
derekdenard@ncdeacgcr
1617 Mil Ssni:a Canto.. R vgk WZM9,1617
httD-l/DortaLncdanaorylwabh.7hv.91W npdos
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: iennifer.bothwell(a)motivaent.com rmailto:iennifer.bothwell(almotivaent.coml
Sent: Wednesday, August 12, 2015 2:54 PM
To: Moore, Cindy
Cc: Denard, Derek
Subject: Motiva Enterprises Charlotte North Terminal Permit NC0022187
Ms. Moore,
The last time we spoke on the phone you said that the subject permit had been pulled and would not be issued until the
question of the appropriate toxicity test is resolved; however, we received the new permit today. The permit requires
collection of one monthly grab sample, which is appropriate for periodic discharges from the facility's holding
pond. The sampling requirements of the Chronic Toxicity test are inconsistent with the monthly grab sample
requirement.
Motiva is again requesting a return to the Acute Toxicity method of analysis in order to maintain compliance.
Please contact me by phone or email if you would like to discuss this request.
Thank you,
Jennifer Bothwell
Environmental Coordinator
Motiva Enterprises LLC
PMB 282
Denard, Derek If OK 64 A411wt,��
From:
Meadows, Susan
Sent:
Thursday, August 13, 2015 9:21 AM
To:
Denard, Derek
Cc:
jennifer.bothwell@motivaent.com'
Subject:
RE: Motiva Enterprises Charlotte North Terminal Permit NC0022187
Hi Derek,
It appears that NC0046892 - Motiva South is also in the predicament. They just do not have enough flow to support a
chronic, multi -day sampling schedule.
Susie
Susan Meadows, Environmental Biologist
Aquatic Toxicology Branch
DWR/Water Sciences Section
4401 Reedy Creek Road Raleigh, NC 27607
susan. meadows@ncdenr.gov
tel: (919) 743-8439
fax: (919) 743-8517
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: Wednesday, August 12, 2015 4:03 PM
To: iennifer.bothwell@motivaent.com
Cc: Hennessy, John <iohn.hennessv@ncdenr.eov>; Meadows, Susan <susan.meadows@ncdenr.¢ov>; Moore, Cindy
<ci nd v.a. moo re @ n cd e n r. aov>
Subject: RE: Motiva Enterprises Charlotte North Terminal Permit NC0022187
Jennifer,
Sorry for any misunderstanding, but the final copy (see attached) that was e-mail to you had been signed (July 20, 2015),
issued and processed before our discussion with the Aquatic Toxicology Branch. Sorry, there was a delay in mailing that
final hard copy. A permit correction to change to Chronic (Ceriodaphnia dubia) to Acute (Ceriodaphnia dubia) is being
reviewed by my supervisor with comments from the Susan Meadows with the Aquatic Toxicology Branch. The permit
correction has not been approved and issued yet.
I would like to further clarify that the Aquatic Toxicology Branch recommended Acute (Ceriodaphnia dubia)-grab and
not Acute (Fathead Minnow) as required in the previous permit.
While we are on the subject are you ok with sampling Chronic (Ceriodaphnia dubia) for NC0046892 Motiva South (see
attached)? Do you have the same issues with multiple day sampling as Chronic? Otherwise, Chronic Toxicity
(Ceriodaphnia dubia) sampling is consistent with our strategy for groundwater remediation discharges. Please let me
know if you have any comments for that permit as well.
Again, I'm sorry for any misunderstanding or inconvenience.
Sincerely,
Derek
l DerekCDenard
Emironmerdal Specia:ot
NCDENRDYsioncf Water Rewurce,
WaterQu Iky PemruNsecrgn
CompSerce & E.-pedrted Permitting Unit
(919) 807.6307
derekdenardCnnienrgo.•
1617)&USxrmCentsr. Aaayh, NC2709-UV
AttD'l.✓��cd�r.argPw�Pw7hwpJpu^pdas
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: iennifer.bothwell@motivaent.com rmailto:iennifer.bothwell@motivaent.coml
Sent: Wednesday, August 12, 2015 2:54 PM
To: Moore, Cindy
Cc: Denard, Derek
Subject: Motiva Enterprises Charlotte North Terminal Permit NC0022187
Ms. Moore,
The last time we spoke on the phone you said that the subject permit had been pulled and would not be issued until the
question of the appropriate toxicity test is resolved; however, we received the new permit today. The permit requires
collection of one monthly grab sample, which is appropriate for periodic discharges from the facility's holding
pond. The sampling requirements of the Chronic Toxicity test are inconsistent with the monthly grab sample
requirement.
Motiva is again requesting a return to the Acute Toxicity method of analysis in order to maintain compliance.
Please contact me by phone or email if you would like to discuss this request.
Thank you,
Jennifer Bothwell
Environmental Coordinator
Motiva Enterprises LLC
PMB 282
35-31 Talcottville Road
Vernon, CT 06066
Office: 860-749-2839