NC0046213_Permit Issuance_20010730

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Mr. Peter A. Reynolds
Marathon Ashland Petroleum, LLC
539 South Main Street
Findlay, Ohio 45840
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
July 30, 2001
Subject: Issuance of NPDES Permit NCO046213
Charlotte Terminal
Mecklenburg County
Dear Mr. Reynolds:
Division of Water Quality (Division) personnel have reviewed and approved your application for renewal of the
subject permit. Accordingly, we are forwarding the attached NPDES discharge permit This permit is issued pursuant to
the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the U.S. Environmental Protection Agency dated May 9,1994 (or as subsequently amended). Please note the
following changes from your draft permit, most of which are the result of the Paw Creek hearing officer's
recommendations:
• pH monitoring and limits have been removed from your permit. This was an error made in all of the Paw Creek
draft permits. The pH requirement was eliminated in the previous permitting cycle and should not have been included
in the 2001 permits.
• The monthly monitoring requirement for naphthalene has been deleted. Semi-annual monitoring using
EPA Method 625 replaces it. As per the hearing officer's report, 625 is the best method for detecting naphthalene
and other middle distillate compounds and is therefore a more appropriate monitoring requirement If your facility
collects eight to ten samples in which none of the 625 compounds are detected, you may submit a request to the
Division that this sampling requirement be eliminated
• EPA Method 624 has been removed from your permit. Based on facility data submitted since this permit was
drafted, it has been established that none of the 624 compounds have ever been measured in your facility's effluent.
As per the 2001 Permitting Strategy for OR Terminals, this requirement has been removed from your permit
• Flow monitoring frequency has been changed from monthly to episodic. As per a request by the Mooresville
Regional Office, flow must be measured with each discharge event
• The MTBE limit of 11.6 µg/L has been removed from the permit. As per the hearing officer's
recommendations, a peer -reviewed criterion for MTBE does not exist and will not be included as part of the
permitting strategy for the Paw Creek permits. It is anticipated that a criterion will be in place when this permit is next
renewed. In addition to monthly monitoring of MTBE, please see Part A. (3.) for some additional
requirements related to MTBE.
The Division believes that monthly monitoring of benzene, toluene, ethylbenzene and xylene (BTF.)g is not
excessive. Semi-annual monitoring through EPA Methods 624/625 does not provide the Division with sufficient data to
assess the risk of effluent from your facility exceeding the water quality criteria. Should the effluent samples at your facility
continue to indicate non -detects for BTEX compounds, you may submit a formal request to the Division for a
modification to the permit reducing the monitoring frequency for these compounds. Additionally, all NPDES permits for
oil terminals from this point onward will carry a monitoring requirement for MTBE. Very little data are available on this
contaminant•, given that it is a potential public health concern, the Division would like to monitor the concentrations of
MTBE in all such discharges.
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center 1800 623-7748

As concerns the monitoring requirements for turbidity and total suspended solids, these are a continuation
of monitoring requirements initiated through an administrative letter in 1999. The 1996 review of the oil terminal
permits across the state of North Carolina revealed large variation in the requirements for monitoring of
suspended solids. As a result, the requirement for all of these permits was changed to monthly total suspended
solids monitoring with a TSS limit of 45 mg/L. Following the issuance of the permits in Paw Creek, the
Environmental Protection Agency (EPA) expressed concern regarding anti -backsliding and the removal of the
turbidity monitoring requirement. In February 1999, an administrative letter was mailed to 12 of the 14 Paw Creek
facilities requiring quarterly turbidity monitoring. For the 2001 renewals, these data were used in reasonable
potential calculations. If a facility demonstrated reasonable potential to violate the stream standard of 50 NTU,
then monthly monitoring and a limit of 50 NTU were added to the permit, as in the case of your facility. It is
important to note that the TSS limit is an effluent limit, while turbidity is a stream standard, so they are not
redundant requirements.
Finally, as discussed with Phil Newton of Marathon Ashland Petroleum, the Division cannot grant permission for
the addition of treated petroleum contact water to the NPDES permit. As per the Federal Clean Water Act, we cannot
allow a direct discharge to surface waters if a viable alternative to discharge exists. Given that the contact water is
currently discharged through a Charlotte -Mecklenburg Utilities Industrial Use Permit, an economically feasible alternative
clearly exists.
If any parts, measurement frequencies or sampling requirements contained in this permit are unacceptable to you,
you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of this letter.
This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina General
Statutes, and fled with the Office of Administrative Hearings (6714 Mail Service Center, Raleigh, North Carolina 27699-
6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit This permit does not affect the legal requirements to obtain
other permits which may be required by the Division of Water Quality or permits required by the Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Natalie Sierra at telephone number (919) 733-
5083, extension 551.
Sincerely,
Ke to s
M. Mooresville Regional Office/Water Quality Section
NPDES Unit i
Central Files
Point Source Branch Compliance and Enforcement Una
Mecklenburg County Department of Envirunmemal Protection
Mr. Pha Newton, Marathon Ashland Pevoleum, LLC

Permit NCO046213
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDE
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended,
Marathon Ashland Petroleum, LLC.
is hereby authorized to discharge wastewater from a facility located at
8035 Mount Holly Road
Paw Creek
Mecklenburg County
to receiving waters designated as an unnamed tributary to Long Creek within the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become effective September 1, 2001.
This permit and authorization to discharge shall expire at midnight on June 30, 2005.
Signed this day July 30, 2001.
-- Kerr T
Divisic
By Aul
of the Environmental Management Commission

is hereby authorized to:
1. continue to operate the existing water pollution system consisting of
• a spill containment area
• a final holding pond
located at 8305 Mount Holly Road, Paw Creek, Mecklenburg County, and
2. discharge from said treatment facility through Outfall 001 at a specified location (see attached map)
into an unnamed tributary to Long Creek, a waterbody classified as WS-IV waters within the
Catawba River Basin.

z

Permit NCO046213
A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001 Such discharges shall be limited and monitored by the Permittee as
specified below:
C ERISTICS
ont ,
veg
Ni
Dail
A-EnENTS
-NJ-Measurement
y
Sample
Type
Sample Location'
Flow
peso is
--Gra67
uent
Total Suspended Solids
m
ont y
Effluent
Oil and Grease
ont y
raEffluent
Turbidity3
Monthly
Grab
Effluent
TE—enor
Monthly
Grabwent
---GrabEffluent
Benzene
1.19 µg/L
----Monthly
o uene
ont y
ra----Effluent
Ethyl enzene
M ont y
Effluent
ene
Montlily
y
ra---Effluent
MTBE
Monthly
I UrabEffluent
EPA Method
Semi-annually
raEffluent
Acute Toxicity
nually
I GraF-1Effluent
Footnotes:
T. Flow- During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow shall be monitored with each discharge event in one of
four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude built -upon
area (best method for facilities with large runoff -collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease- Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
3. Turbidity - Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving
stream background turbidity exceeds 50 NTU, effluent shall not cause this background value to
increase.
4. MTBE - Please see Part A.(3.) for other requirements relating to MTBE
5. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 1.19 µg/l and toluene concentration is less than 11 µg/1.

Permit NCO046213
EFFLUENT LIMITATIONS AND MONIT
ORING, REQUIREMENTS
SPECIAL CONDITIONS:ar _
A. (2.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas)
24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste
treatment. The permittee will conduct one test annually, with the annual period beginning in January of
the calendar year of the effective date of the permit. The annual test requirement must be performed and
reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.

.y
Permit NC0046213
A. (3.) MTBE SPECIAL CONDITION
For the protection of public Health, oil terminals that discharge to waters classified as water supplies
("WS" waters) will adhere to the following action plan:= =` `
1. As stated in Part A. (1.), monthly monitoring of MTBE for the duration of the permit is required.
2. After one year of monthly monitoring or once twelve data points have been collected, the
Permittee shall review the MTBE data collected. If MTBE has not been detected in any samples
taken during the first year, the facility may request that the monitoring frequency for MTBE be
reduced. This should be done by requesting the NPDES Unit to perform a minor modification to
the NPDES permit. In the case in which MTBE has been detected within the first year of
effluent sampling, the subject facility must submit an MTBE reduction plan. This action plan
may include site -specific BMPs or engineering solutions. A copy of this plan should be
submitted to:
North Carolina Division of Water Quality
Water Quality Section
Attn: NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
3. By the time of the next permit renewal, it is anticipated that surface water criterion for MTBE
will be established. This criterion will be used in conjunction with the facility's effluent MTBE
data to perform a reasonable potential analysis (RPA). The RPA will determine whether effluent
from a facility has the potential to exceed a water quality standard

NOTKE OF PUBLIC NEARING
TM TOBEHMID BY
A IT�,S Q�L� THE NORTN CAROUNA EWRONMEWTAL MANAGEtAENT COMMISSION �
'1�'1Cjl." li�� �r,
SUBJECT: A pubic hearing has been scheduled concerningBeeproposed renewal and issuance of
Me fdlowbt NPOESP00219
Permit donated NC0021nty)52 For for PehokumfWardenoterhker aie PawClockrrome NationallocatedGum
CJIdrlPffe, N.C. Chaddle IMerJdmbury County) Ipr the Ondarge of SMrnrwdlef headed unnamed mbuMry b Gum
AFFID14VITOFPUBLICAI Branch.
- Permit number NCW22187 b MOEva Enterprises for the Paw O'eek Terminal loaned in Charlotte
NORTIT'C"UUNA (Mecktenburg County) (of one diecrougeolwarreaterand remewfiaeed Imundwaler lntoanumnamed
MECKI9NBUROCOLINTY btbulary to Gum Barren.
BefonWcundeniened,aNeteryl - Permit number NCM32891 to Philips Pipe Line Company Me Me Chadolle Terminal located in
None cerebral, dul y eommheionea Ci1adotle (Macbenburg County) for Me discharge of floodwater Into an unnamed traitary b Gum
hwmedminbmro Shou Penmdly Branch. _
Shelby J. Comm - PemylnurMer NCo0Tg05to Will... TemNaisHoldings. L.P. mrbe CharphouSoulhem Feeffies
Terminal Imated b GarloRe (MBGleMurg CWnty)W Me tlistharge of sMrmwalm into an unnamed
THE Mlxtl mg TB.106B, a need tributary, he Paw Creek,
mlmedmaec°oa-deu mailinme t . Pentd number NCDI W Velour Wde§W 8 Supply Carnal for the Valero Marketing 8
and SaM Malhdam iaautMnxedl' Supply Findlay bated in Chances (Mecklenburg Camty) for the discharge of stpmwaler into an
eatemernn; drat Me mane w alhu I` unnamed trialtery to Paw Creek,
NOTICE OP PUBLIC L ' Permdnumbei NCOW5TT1 bTmnsMo gn Tmninalm9.Inc.brMeCbadohelPawCreekTem�i-
nal 91 treated M Charlotte (Mecklenburg County) for the discharge, Of sbrinwaler into an unnamed
TO HE HELD BY THE Whole, to Paw Creek.
ERWIRONMENTAL MAN/ PermilnurMer NC00219)l mironsMonblgne Tefmtnagng, Inc, locthe C6adotlerrav, Creek Tram.
not Iry bto el in Charades (Mecklenburg County) In Me d eplowge of woinw rear into an unnamed
tributary to Paw Creek.
. Permit number NCW310M to Colonial Pipeline Gcanpany for Me ChanaBe Oe6very Fadliry looted
• Wewpgeftahbh°avaahed Md in Charlotte (Mecklenburg County) for Me dindeq a of stamxaler into an unnamed Idoutary to Gum
IndwrBi1111FS on lie folbrinB din Brandt.
March 16, 2001-Pernutnumb NCOW6213to MatddtdnMMand Patde M.LLCfOr Me Maalha Athla Pena'
Inure facility looted in Channel, lMetkbnbur9 County) for thadireeiiage of stndraide [ {'rd��{�, Y3i�'on.
and Mulheaaid newapepnmwM1la named b:butary to Lang Creek \9ixY
or beef ederbion enl wu publbh, - Permit number NCM46531 Ip Crown Central Pebpleum Company for Me Paw Creek Terminal
every eueMpubliceiii amwapaper 'mated in Pm, Creek (Mecbenburg CW nly) for be discharge of stionevater Into an unnamed Rlbubry
and yuekMce1lom of Section 1-597 ( to Gum Bandt,
Cnoihewpdwm 9udif d newepa . Permit number NMN6892 to Molne Enterprisea, U-C W he Charblle Terminal located In Paw
uun IdYD ofMe Gnarl internal c Creek (Mecklenburg County) for he eisdul Of stamwakr and remediated groundwater to an
Thor 16 th fef M. """ tnbutary b Long Creek.
�y y° . Permit number NCOOO4B39 to ExxonMobil Resper, Al Sully Cpenpany far the Crue llc Teminal
(Si6ned) �—� / //o van Wln ChadoRe(MecklenNeg Ca tY)br MedlsdlaMg Oo lmwwateraM,, di2kd Woundwa
L /p(y, =t an unnamed tribudry MILM, Creek.
9wunmmdsuMaibedh rz1 'Permit numberNCO0o51E51oWlsome Tore irRISHddirgs.L.P. Lorthe Paw Creek Terminal heated
in Paw Creek (Meckl aborg County) far Me diSchartin olsbmnnim b an orinardand! tributary to Long
16th dayof March 201 Creek
PURPOSE: Each ofM eldlMs has plililiked far rmowal off Mean NPOES licaut for Me discharge
off, of bound! ft n leand/ ereedated groudeater into waters m Rte Calf Him,Wsn On Me
basis of preliminary sale review andappldpO Of Argde 21 of Ch pen 143 Ge eml SlaWes of Noah
Nper,libi Carolina and othn lawful steneards and regulations, Me None CarMna Environment kbrdi ement
My Gam"aim Bipna: 7/7 Commlourm properses no issue a NPOES permit for cads ladlily Subject to spetlfuol puhnl Nmiations
d special conewded. The Die— aMe Gilled of Water Grapay pursuant to NCGS 143Q15.1(c)(3)
and Repuhims 15 NCAC 21-1, Se6W .Ot lip has delnmMM Mat d is in Me pubicproper Mat a meeting
be held b recede as pearrom Public comment on whether In Lcsue, mddity, on dany Me permit.
PROCEDURE: The hearing win too poModed In the following maser;
1. The Divam of Water Quality wg present an explanation of Me North Carding Environment
Management Cormtiseioh'e majdar, procedure.
2. The applicant may make an explanation Of Me adlW InwMda eadl Permit is Nodded.
3.Publa Coimneat Convrenk sMtemenM, data aM oMmbldtmafia mayhe submitted In wrifinp
poortondumg Memee6Vnmaybepreaenk O yat Mem tfiV.Persons:de,innospoakwrit
indicate this intent Me time olregistratun at Memberm, SO that 2"rebsms desiring 0 Speak may do
So . lugay statements any be fmited at Me discreboa of Me Menu., officer. Oral presimanons that
coed Mrce minutes should be accomdanieE by three Waltm cooked, wHdi win ber rdW win Divislon
i at Me 6. of regisoabou
-- - -- -'-- 4. Cross examnabmn of persons pricam tip ludi mpny war dot be allowed: reervever, Me hearing
officer may Ssk Washore fn dadjeace.
5. The hearing recgrd may be than d at the con boded of en eating.
WHEN: April 19^ at 7:001t.m
Our east Fourth Street. CH-14
Charlotte, Ni Carolina
INFORMATION: A any d the draft NPDES Permits)ands nap Shoeing Me Oration done iischoo els)
are available tolver ing or alGn9'.
Ms. Chdsbe JadlsM
NC Division d Water Qudllty ifili Unit
1617 Mail Send. Curler
Raleigh. Noah Carolina 27699-1617
Telephone pioneer(919) 733 5083, extension 538
The appfrrph— end othe,Itedawton a, afile at Me Give. d Walef Goolity, 512 North Salisbury
Smal. Room 925 el Me Arcndale Ruildirg in Raleigh, NOM Carolina Mad at Me ordeal, Mppresvthe
Regional Oflce (919 NO, Main Street In MCpresvtlle. NCf. They may be impeged during normal office
haute. Copies of Me Ofonnalion on file are avagabio .,on repuest and payment o1 the posts of
rmrodue eir. All such ammenls and remucsts R9arding M1z mabe, Should make reference 10 Me
Permit nurraegs) listed w eve,
950M Mar 16-

M6ddeaurg
TMS
Charlotte, N.C.
AFFIDAVIT OF PUBLICATION
NORTH CAROLINA
MECKLENBURG COUNTY
Before the undersigned, a Notary public of Mecklenburg County,
Korth Carolina, duly commissioned, qualified, and authorized by
law to administer oaths, personally appeared
Shelby J. Cummings of
TM Mecklenburg TIMM, a newspaper published, issued, and
entered as second-class mail in the City of Charlotte, in said County
and State; that he/she is authorized to make this affidavit and swam
tatement; that the notice or other legal advertisement of
NOTICE OF PUBLIC HEARING
TO BE HELD BY THE NORTH CAROLINA
ENVIRONMENTAL MANAGEMENT COMMISSION
a true copy of which is attached hereto, was published in THEMeek-
lenburg 7I11VIES on the following dates:
March 16, 2001
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, anewspapermeeting all ofthe requirements
and qualifications of Section 1-597 of the General Statutes of North .
Carolina and was a qualified newspaper within the meaningvf Soc-
tion 1-597 of the General Statutes of North Carolina.
ibis 16th dayof March 2001
(Signed) � /
P�
Sworn to and subscribed b fore
16 th day of March 2001
4 6—jq
0"
Notary Public
My Commission Expires: 7 / 7 / 2004
1 tacai�e� -in
isY to oum
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4 do DIVIsion
it l a[tt}� itciv�ver, fits hearing

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
2001 Permitting Strategy
Background' / Introduction
In 1996, the Permits and Engineering Unit reviewed NPDES permit monitoring requirements for stormwater
discharges at oil terminal facilities located in the Greensboro and Charlotte areas. This review revealed
inconsistencies in monitoring requirements that were subsequently discussed with staff of the Winston-Salem
and Mooresville regional offices. These discussions and a review of past information collected at these facilities
formed the basis for much of the standard monitoring requirements contained in this Standard Operating
Procedure (SOP) for Stormwater Discharges from Oil Terminal Facilities.
In accordance with the basinwide planning schedule, the NPDES permits for the oil terminal facilities are due for
renewal in 2001. The NPDES unit has reviewed the discharge monitoring reports (DMRs) for the facilities in
order to assess the SOP currently in place. This led to some revisions and additions to the existing procedure;
the bulk of the 1996 SOP will be carried over into the 2001 revised SOP.
This document is divided into three sections that delineate the permitting requirements for oil terminal facilities.
The first part describes the minimum requirements for all oil terminal facilities in the state - both monitoring
requirements and permit limits. The second section describes potential additional site -specific requirements that
are based upon the performance of a reasonable potential analysis for the facility. Such requirements are based
upon reported data from the Discharge Monitoring Reports (DMRs) of a given facility. The third and final section
delineates additional requirements for those facilities which discharge to receiving waters carrying a water supply
classification.
I. Minimum Requirements for ALL Oil Terminal Facilities
A. Flow
Episodic Monitoring (monitor with each discharge event)
Measurement of flow is to be representative of a discharge event. Many oil terminal facilities
have storage ponds to collect runoff and therefore, discharges may not always occur during
storm events. Flow should be monitored by one of the following methods:
1. Measure flow continuously, or
2. Calculate flow based on the area draining to the outfall, the built -upon area, and the total rainfall,
using the rational equation (see below), or
3. Estimate by flow measurement at 20 minute intervals during the entire discharge event, or
4. Base flow on pump logs.
The rational equation: Q=KuCIA, where
Q = flow (peak flow rate (cfs or m3/sec)
Ku = units conversation factor = 1.008 for U.S. standard units (usually ignored because it is so close to
1), or 0.278 for SI units
C = dimensionless runoff coefficient for the watershed, loosely defined as the ratio of runoff to rainfall
I = intensity of rainfall taken from the intensity -duration -frequency curves for the specified design
return period at the time of concentration tc, (in/h or mm/h)
tc = time of concentration - time after the beginning of rainfall excess when all portions of the drainage
basin are contributing simultaneously to flow at the outlet
A = area of tributary watershed (acres or km2)
The rational equation is used to calculate the runoff from a region, given:
➢ the runoff coefficient which accounts for infiltration and other potential losses in the region,
➢ the rainfall intensity to the region,
➢ the time it takes for runoff to travel from the region's upper reaches to its outlet, and
➢ the region's drainage area.
For oil terminal facilities with large storage ponds that serve to collect runoff, item 2 listed above and the
rational equation should not be used because the calculations will determine the flow to the storage pond,
rather than the flow from the pond.
Page 1 of 8
Version 7/30/01

Permit Requirements for Discharges' from Oil &, Petroleum Storage Facilities
B. Acute Toxicity: Fathead Minnow (Pimephales promelas) 24-hr, Annual
Monitor annually (assuming first five discrete storm events have already been monitored and
showed no toxic effects)
Monitoring Footnote: acute toxicity monitoring should occur during collection of BTEX
parameters (see item E below)
Products stored at oil terminals may contain a variety of different chemicals (some of which may have
harmful or toxic effects). To verify that toxic chemicals are not discharged to surface water, a periodic
toxicity test will be required. An acute, rather than chronic, toxicity test is required because oil terminal
facility discharges are typically short-term, episodic events. Specifically, an acute 24-hour pass/fail at 90%
waste concentration using fathead minnows is the recommended toxicity test for stormwater discharges.
Facilities that meet one or more of the following criteria will not qualify for annual monitoring and will
be required to monitor for acute toxicity during five storm events:
1. Facilities that have never monitored for acute toxicity during a storm event, or
2. Facilities that monitored for acute toxicity during four or fewer storm events during the last
permit period, or
3. Facilities that completed five acute toxicity tests during five storm events, but did not pass all
five tests.
Facilities that fail an acute toxicity test conducted during one or more of the five storm events or during an
annual monitoring event will be required to conduct quarterly monitoring for the forthcoming permit period,
and must receive State approval for reduced monitoring. For facilities that have not yet conducted acute
toxicity testing for the first five discrete storm events, a statement in the permits will allow for additional
toxicant limits should the toxicity test indicate toxic effects. At the time of permit renewal, only annual
monitoring for toxicity would be required if the facility has performed the five discrete sampling
requirements with no acute toxicity.
C. Total Suspended Solids
Monitor monthly
Daily maximum 45.0 mg/1
Historically, Total Suspended Solids (TSS) has not been a significant problem in stormwater discharges at
oil terminal facilities. A 1996 analysis of TSS data from five stormwater discharges indicated only one event
in excess of the previously permitted 30.0 mg/1 monthly average. A daily maximum limit of 45 mg/ L is
recommended as a general indicator of stormwater quality. A daily maximum compliance period is given to
reflect the sporadic nature of these discharges. Should TSS monitoring data indicate any substantial
problems, the Regional Office or county may elect to enforce the instream standard for turbidity.
D. Oil and Grease
Monitor monthly - No Limit
Monitoring Footnote: Where possible, the grab sample for oil and grease should be skimmed from
the water surface of a quiescent (calm water) zone.
Historically, oil and grease has not been a significant problem in stormwater discharges at oil terminal
facilities. However, like TSS, oil and grease is a good general indicator of the quality of a stormwater
coming from a site. Where possible, oil and grease samples should be skimmed from the surface of a
quiescent zone closest to the discharge.
E. BTEX
Monitor monthly — No Limit
Benzene, toluene, ethylbenzene and xylene are toxicants commonly found in petroleum. The previous
permitting strategy for the oil terminals required the EPA 624/625 scan, which, among other contaminants
of concern (see Part II), detects BTEX compounds. A review of the discharge monitoring report data from
the previous permitting cycle indicates that these four contaminants frequently appear in stormwater from
terminal facilities. For the most part, the other volatiles and semi-volatiles detectable by the EPA 624/ 625
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
scan were never detected in the stormwater from these facilities. By monitoring for BTEX and naphthalene
(see part F, below), the facilities are collecting data on those pollutants that are mostly likely to be present
in the water.
F: ` EPA Method 625
Monitor semi-annually
The intent of this monitoring requirement is to monitor for naphthalene and other indicators of middle
distillate compounds detectable by Method 625. These contaminants are commonly found in heavy
fuels, such as diesel. During site visits of terminal facilities performed by members of the NPDES Unit,
it was observed that the majority of the terminals reserve at least one storage tank for diesel fuel.
Originally, facilities were to have monitored only for naphthalene, but since the most accurate method
of quantifying naphthalene is through Method 625 and other middle distillate compounds can be
detected through this scan, the entire results should be reported to the Division. '
If it can be demonstrated by the permittee that diesel fuel is not currently being stored on site, then the
monitoring requirement on the effluent page will have the following footnote:
'"Monitoring requirement applies only for facilities storing diesel or other heavy fuels on site."
G. Tank Solids, Tank Bottom Water, and Rag Layer
No direct discharge of tank solids, tank bottom water, or the rag layer is permitted.
There are typically four discrete layers of varying thickness within a storage tank. At the very bottom of the
tank is the solids layer that achieves a 1/2-1 inch thickness over a 5-6 year period. Immediately above the
solids layer is 1-6 inches of tank bottom water that results from rainwater breaching the wall seal in open
roof tanks. Open roof tanks are not completely open, but have a roof floating directly on the product.
There is a seal between the tank walls and floating roof designed to prevent water from entering the tank.
Water breaching this seal and entering the tank is referred to as tank bottom water. The rag layer is at
most 3/4 inch thick and forms the interface between the tank bottom water and the product. The product
is the topmost layer and is 20-25 feet. Normally, the tank bottom water is removed from the tank when it
is 3-4 inches deep. The mixture of water and product in the rag layer is often drawn off when tank water is
removed because water entering tanker trucks must be minimized. As a result of potentially high levels of
organic compounds in the three bottom layers of storage tanks, they are not to be discharged, but instead
should be transported off -site for appropriate treatment and/or disposal or treated/recovered onsite if
treatment technology capabilities occur onsite.
H. Hydrostatic Testing
Hydrostatic testing of oil tanks normally occurs once every five to six years. Prior to the hydrostatic testing,
the tank is completely drained and tank bottom materials are handled as described in the previous section.
The tanks are completely cleaned and then coated and welded (if necessary). The tank is then filled with
water for the hydrostatic test. Some oil terminal facilities use stream or lake water to hydrostatic test their
tanks, while others use potable city water. Because the tank is thoroughly cleaned prior to refilling with
water for the hydrostatic test, water discharged from the tank following the hydrostatic test should be fairly
clean. However, tank discharges following hydrostatic testing may contain contamination. Therefore,
monitoring of the tank water prior to direct discharge will be required. There shall be no direct discharge
from oil terminal facilities following hydrostatic testing if concentrations of benzene and/or toluene are
greater than their respective water quality standards (see effluent pages at end of SOP for details).
I. MTBE Monitoring
Monitor monthly
Within the last year, the Environmental Protection Agency has recommended banning methyl tertiary butyl
ether (MTBE), an ingredient commonly used in gasoline to aid in the reduction of air pollution. MTBE was
originally added to gasoline in response to a 1990 law that required higher oxygen content in gas sold in the
most -polluted cities. It has since become a cause for concern since the EPA now believes that MTBE may
be a carcinogen and is seeking to outlaw the compound.
Since MTBE contamination of water is a public health concern, monthly MTBE monitoring will be added to
all facilities. For those facilities currently monitoring for MTBE, reasonable potential analysis will be
performed to assess the need for an MTBE limit. In non -water supply waters, the instream MTBE standard
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
is 2393 µg/ L, and is unlikely to be violated. All facilities discharging to water supply waters will have a
special condition added to the permit that pertains to MTBE monitoring and source reduction (see Part
IILC.)
H. Additional Site -Specific Requirements
A. EPA Method 624
Monitor semi-annually
The entire 624/625 scan was originally included in the SOP to assess which of the petroleum -associated
organic chemicals are found in stormwater. These tests scan for volatile and semi -volatile organics and
cost approximately $700 to run (Ray Kelling, personal communication 2/ 14/01). Currently, the oil
terminal facilities are performing the scan twice a year. Most facilities obtain results consisting entirely of
non -detects, but a few have detected one or more of the compounds on the 624/625 list. Tables 1 and 2
summarize the compounds included in the scans and note those parameters detected during the last
permitting cycle.
After a review of the data and discussions with different members of the Division of Water Quality Point
Source Branch, it has been decided to assign semi-annual monitoring using EPA Method 624 to any of the
facilities that detected any compound listed in Table 1 that is not benzene, toluene, ethylbenzene, xylene or
naphthalene (as these were found in most discharges and are covered by monitoring requirements listed
above).
Table 1. Compounds detectable by EPA Method 624
PARAMETER
DETECTED IN OIL TERMINAL STORMWATER?
Acrolein
Acrylonitrile
Benzene
✓
Bromodichloromethane
Bromoform
Bromomethane
Carbon tetrachloride
Chlorobenzene
Chloroethane
✓
Dibromochloromethane
1,2-Dichlorobenzene
1,3-Dichlorobenzene
1,4-Dichlorobenzene
1, 1 -Dichloroethane
trans-1,2-Dichloroethene
1,2-Dichloro ro ane
cis- 1,3-Dichloro ro ene
trans- 1,3-Dichloro ro ene
Ethyl benzene
✓
Methylene chloride
✓
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
✓
1, 1, 1 -Trichloroethene
1,1,2-Trichloroethene
Trichloroethane
Trichlorofluoromethane
✓
Vinyl chloride
✓
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
Table 2. Compounds detectable by EPA Method 625
iPARAMETER
Acena hthene
DETECTED IN OIL TERMINAL•-
Acena hth lene
Anthracene., ,.
Benzo a anthracene
Benzo b fluoranthene
Benzo k fluoranthene
Benzo a ene
Benzo(ghi)perylene
Benzyl butyl phthalate
Bis 2-chloroeth 1 ether
Bis 2-chloroetho methane
Bis 2-eth the 1 hthalate
Bis 2-chloroiso ro 1 ether
4-Bromophenyl phenyl
ether
2-Chlorona hthalele
4-Chlorophenyl phenyl
ether
Chrysene
Dibenzo a,h anthracene
Di-n-bu 1 hthalate
1,3-Dichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
3, T-Dichlorobenzidine
Diethyl phthalate
Dimeth 1 phthalate
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octylphthalate
/
Fluoranthene
Fluorene
Heptachlor
Hexachlorobenzene
Hexachlorobutadiene
Hexachloroethane
Indeno 1,2,3-cd ene
Iso horone
Naphthalene
Nitrobenzene
N-Nitrosodi-n-propylamine
PCBs
Phenanthrene
/
PYrene
Toxa hene
1, 2, 4-Trichlorobenzene
4-Chloro-3-meth 1 henol
2-Chloro henol
2,4-Dichloro henol
2,4-Dimeth 1 henol
2,4-Dinitro henol
2-Meth 1-4,6-dinitro henol
2-Nitrophenol
4-Nitrophenol
Pentachloro henol
Phenol
/
2,4,6-Trichloro henol
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
B. Reasonable Potential (General)
The reasonable potential procedure is a method used to determine the potential of a discharge to violate a
water quality standard for a given parameter based on existing data. If a parameter is determined to have
reasonable potential to violate a water quality standard, a limit and monthly monitoring will be required. A
parameter is determined to have reasonable potential to violate a water quality standard if a calculated
maximum predicted effluent concentration is greater than the allowable effluent concentration.
Reasonable potential is determined by performing a statistical analysis for each parameter of concern that
has either a state or federal water quality standard. For each parameter, the statistical analysis works best
with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more
accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent
concentration based on the existing data set. A step-by-step procedure for determining whether or not a
parameter should be limited based on reasonable potential determination follows:
STEP
1. Determine the number of sample points (n)
2. Determine highest value from data set. Best professional judgment should be used by the reviewer so
as not to use an outlier. Since an outlier will not be determined statistically, maximum values should
rarely be discarded in this analysis.
3. Determine the coefficient of variation (CV = STD DEV/ MEAN)
4. Determine the appropriate multiplication factor to be used by comparing the number of samples versus
the co -efficient of variation (see Table 3-1)
5. Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to
obtain the maximum predicted effluent concentration.
6. Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable
effluent concentration, which is based on instream dilution and the corresponding water quality
standard. EPA recommends that permitting authorities find reasonable potential when the maximum
predicted effluent concentration is greater than the allowable effluent concentration.
A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet" and is
located on the NPDES server. The spreadsheet requires the input of the facility name and permit number,
the waste flow (Qw), 7Q 10 flow, pollutant name, state or federal water quality standard, and the DMR data
points with appropriate units. The spreadsheet then computes the standard deviation, mean, and
coefficient of variation for the entered data points. The coefficient of variation is then used along with n
(the number of data points entered in the spreadsheet) to determine the Multiplication Factor. This
Multiplication Factor is entered into the Toxicant Spreadsheet to calculate the maximum predicted
concentration.
If the maximum predicted effluent concentration is greater than or equal to the allowable effluent
concentration, (or in other words, if there is reasonable potential for a water quality standard violation), the
parameter should be limited (as a daily maximum) and monitored on a monthly basis. The daily maximum
limit shall be equal to the standard for that parameter multiplied by the dilution of the receiving stream
under summer 7Q 10 conditions for non -carcinogens. Average flow should be used for carcinogens and
30Q2 flow should be used for aesthetic standards.
If a facility monitors semi-annually (twice/year), 10 data points would be obtained over a five-year permit
period which is slightly more than the minimum number of data points which will accurately characterize
an effluent discharge (USEPA March 1991).
In cases where a facility requests reconsideration of a limit requirement, monthly monitoring should be
required for at least 10 months so that 10 data points can be obtained and a second reasonable potential
calculation can be conducted. If there is no reasonable potential for a water quality violation, monitoring
should be reduced (to semi-annually).
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. Turbidity Monitoring (Paw Creek terminals)
Monitor quarterly
(Monthly monitoring and limit of 50 NTU if facility demonstrates reasonable potential)
Based on concerns regarding anti -backsliding, the EPA requested the Division re-examine the basis for the
elimination of turbidity monitoring for 12 of the 14 Paw Creek oil terminals that were required to monitor
for turbidity prior to the most recent permit renewal. This second examination of the data showed that
there were turbidity standard violations since the last analysis at several of the oil terminals. The Division
therefore acknowledges that its second evaluation resulted in a different outcome from the initial
investigation and agrees that turbidity monitoring should be added to the discharge permits for the oil
terminals in Paw Creek. Facilities were sent notice in February 1999 that quarterly turbidity monitoring
would be required at the facility effective March 1, 1999. If sufficient data exist, then reasonable
potential should be performed to assess the need for more frequent monitoring and a limit of 50
NTU. For all facilities, the following footnote will be placed on the effluent limits page:
*Turbidity - Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving stream
background turbidity exceeds 50 NTU, effluent shall not cause this background value to increase.
III. Additional Monitoring Requirements for Water Supply (WS) Waters
A. Phenol
Monitor monthly
(Limit assigned if reasonable potential is demonstrated)
Phenol is a common component of petroleum compounds stored in terminals, can result in tainting of fish
tissue, and can cause taste and odor (organoleptic) problems in drinking water. In addition, phenol
discharged from terminals could combine with chlorine in water treatment facilities to form chlorinated
phenols. Limiting the discharge of phenol into water supply classified waterbodies could reduce
chlorinated phenol formation and their concentration in drinking water. As a result of the expected
occurrence of phenol in oil terminal facility discharges and the possibility of chlorinated phenol formation,
phenol will be monitored on a monthly basis in water supply classified waters.
Based on an extensive review and analysis of data collected during the last permitting cycle, the facilities
are no longer required to monitor for chlorinated phenols, since none were ever detected in oil terminal
effluent. The concern over limiting phenols lies in the need to inhibit formation of chlorinated phenolic
compounds at downstream water treatment plants. Joe Corporon of the NPDES Unit calculated an
allowable phenolic loading for each terminal in Mecklenburg County that will prevent a downstream
violation of the NC State standard for phenols of 1 µg/L. Meg Kerr wrote a similar memo for those
terminals in Guilford County in 1983. Reasonable potential will be performed using these allowable
phenolic loadings (see attached memo).
B. _ Benzene
Monitor monthly
Daily maximum limit - 1.19 µg/l * dilution of the receiving stream under average flow conditions
Benzene is a known carcinogen and can pose a potential health risk to humans consuming water with
benzene. The water quality standard for benzene in waters classified as water supplies is 1.19 µg/l. The
daily maximum limit for these facilities is therefore 1.19 multiplied by the dilution of the receiving stream
under average flow conditions (rounded to two significant digits). This limit may be excluded from the
permit only if there are sufficient data (eight sampling events) to demonstrate "no reasonable potential." If
there is no reasonable potential, there will only be a monthly monitoring requirement.
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Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. MTBE
Monitor monthly
MTBE special condition
Given that this compound is considered a possible carcinogen, there should be a greater effort to keep high
levels of MTBE out of water supply waters. As per the Paw Creek Hearing Officer's Report, after one year of
monthly MTBE samples have been recorded, the facility must review the MTBE data. If no MTBE has been
detected in the effluent samples, the facility may request a minor modification to the permit reducing the
frequency of MTBE monitoring. If, however, MTBE has been detected during any of the discharge events,
the Permittee must develop a plan of action to reduce the levels of MTBE entering the receiving stream.
It is anticipated that an MTBE criterion for surface waters will be established at the time of the next permit
renewal. At that time, sufficient data will be available to assess the reasonable potential for a facility to
exceed any such standard or criterion.
REFERENCES
Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering
News.
Kelling, Ray, (Division of Water Quality Chemistry Lab). June 1996. Conversations with P. Clark.
Kelling, Ray, (Division of Water Quality Chemistry Lab) . February 2001. Conversations with N. Sierra.
Linville, Ron, (Winston-Salem Regional Office). March 1996. Telephone conversation with P. Clark.
Reid, Dianne, (Division of Water Quality - Planning Branch). June 1996. Conversations with P. Clark.
Shiver, Rick, (Wilmington Regional Office). July 2001. Findings and Recommendations for Public Hearing
Held on April 19, 2001.
USEPA. March 1991. Technical Support Document For Water Quality -Based Toxics Control. EPA/ 505/ 2-
90-001.
Page 8 of 8
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DIVISION OF WATER QUALITY
April 5, 2001
MEMORANDUM
TO: Dave Goodrich
FROM: D. Rex Gleason
1
PREPARED BY: Richard Bridgeman\
SUBJECT: Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
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It is recommended that the effluent sample location be specified in all the permits.
Circumstances at one facility (at least) can be cited as justification for the
recommendation. The permit description of the water pollution control system (WPCS)
for Colonial Pipeline Co. (NC0031038) includes a retention pond. This pond is also
mentioned in the Fact Sheet. Regardless of the 7Q10, 30Q2, and average flow data, this
pond is actually an impoundment fed by three UT's to Gum Branch. According to the
terminal manager, there is flow in these UT's to Gum Branch 12 months per year. The
effluent from the CITGO (NC0021962) facility is discharged to one of the UT's.
Stormwater runoff from at least one other terminal site may also enter the impoundment.
Effluent samples are collected at the outfall for the impoundment.
As discussed above, in addition to the sample collection location, the Colonial Pipeline
Co. (NC003103 8) permit needs to be reviewed to determine if it is appropriate to include
the impoundment of a UT to Gum Branch as a treatment unit (retention pond).
Consistency is needed in specifying source of wastewater to WPCS.
There are four different methods used in the draft permits, as follows:
Source not specified anywhere.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet,
which describes the WPCS and/or specifies outfall.
Source indicated in the paragraph on the Supplement to Permit Cover Sheet that
specifies receiving water.
Source indicated in Part I, Section A(1) of permit (Effluent Limitations and
Monitoring Requirements Sheet).
The writer's preference, in part because several of the facilities have multiple outfalls, is
to indicate sources on both the Supplement to Permit Cover Sheet (in paragraph which
describes the WPCS and/or outfall) and in Part I, Section A(1). An example of the
writer's preference is in the permit for Motiva Enterprises, LLC (NC0046892).

Dave Goodrich
Page Two
April 5, 2001
Flow measurement/reporting frequency is recommended to be episodic (as in permit
Motiva Enterprises, LLC (NC0022187).
For several design reasons, discharge events basically occur on an as -needed basis; a
decision is usually made when there will be a discharge through an outfall. The only
exception may be Outfall 002 included in the permit for ExxonMobil Refining and
Supply (NC0004839), which is for a groundwater remediation system without any flow
retention capability, and, therefore, subject to daily discharges. Since discharge events
are mostly manually precipitated and occur randomly or as -needed, the range of the flow
data at a facility may vary considerably. Flow data seems to have played a large role in
the development of effluent limits (as in reasonable potential analysis for phenols), and
yet historically flow measurement methods and data have been two of the evaluations of
a compliance inspection subject to much scrutiny and criticism. Given the flow
measurement options specified in the permits, the small number of discharge events
probable each month, the importance of flow data, and the possibility of a wide range in
the flow data, it is not unreasonable to expect flow to be measured and reported for each
flow event.
The Turbidity monitoring requirement does not seem to be complete.
The permits, with two exceptions (discussed under the next item), include either a
quarterly monitoring -only requirement or a monthly monitoring requirement with an
effluent limit. It is not understood how the effluent turbidity monitoring requirement
correlates with the relevant footnote in Part I, Section A(1). Should there not also be an
upstream and downstream monitoring requirement. In fact, those facilities with a
monitoring -only requirement need only conduct stream monitoring to determine if
effluent turbidity levels result in stream standard violations.
One of the exceptions mentioned above under the item for Turbidity Monitoring is
Marathon Ashland Petroleum, LLC (NC0046213). Although the permit cover letter
indicates that the pemut includes a monthly monitoring requirement and an effluent limit,
Part I, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring -only
requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is
being required because of the near potential for a stream standard violation. The other
exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being
required because none of the previously required monitoring has been conducted.
Philips Pipe Line Company (NC0032891) — Phenol limit in the other permits is expressed
in mg/L. In the Philips permit, it is expressed in ug/L.
ExxonMobil Refining and Supply (NC0004839) — Benzene limit is indicated to be 1.2
ug/L; should it not be 1.19 ug/L?

Dave Goodrich .
Page Three
April 5, 2001
Phenol limit development.
The cover letters for four of the six permits with a Phenol limit discuss development of
the limit. In the cover letter, the water quality standard for phenol is indicated to be 1
mg/L; it is actually 1 ug/L for WS waters. The, writer is not familiar with the 2001 SOP
used to develop limits for phenol, but considering the fact that five of the six facilities
discharge to streams having a 7Q10, 30Q2, and average stream flow of zero, and the sixth
facility discharges to a stream having a 7Q 10 and 30Q2 flow of zero and an average flow
of <1, it is hard to understand the assigned limits. The 3 mg/L Phenol limit for Outfall
002 in the ExxonMobil (NC0004839) permit is almost unimaginable.
Motiva Enterprises, LLC (NC0022187) — The Fact Sheet indicates that there is a
reasonable potential for the stream standard for Lead to be violated, but indicates that no
limit will be assigned because lead is an action level pollutant. A change? If not, should
there be a Lead limit in permit?
TransMontaigne Terminaling, Inc. (NC0021971) — Permit Cover Sheet indicates that
discharge is to Paw Creek. As indicated elsewhere in permit, discharge is to a UT to Paw
Creek.
Williams Terminals Holdings, L.P. (NC0074705) — The permit description includes an
oil/water separator, a carbon filter, and a holding tank. The Fact Sheet indicates that
wastewater and stormwater are -routed to a retention pond and released as needed. No
staff report or compliance inspection report mentions this retention pond. MCDEP staff
has confirmed that there is no retention pond at the site.
Valero Marketing & Supply Co. (NC0004723) — Please review discussion in Fact Sheet
concerning the assignment of a Turbidity limit. If the average turbidity value in the past
1.5 years is 7.2 NTU and the maximum 28 NTU, why is there a prediction of a maximum
of 110.3 NTU?
Williams Energy Ventures (NC0005185) — Permit Cover Sheet indicates that discharge is
to a UT to Gum Branch; as correctly identified on the Supplement Sheet, it is a UT to
Long Creek.
Motiva Enterprises, LLC (NC0046892) — Fact Sheet indicates that the Flow requirement
for Outfall 002 in the previous permit will remain unchanged. There was a Flow limit in
the old permit, but not in the draft permit. The writer does not recommend a limit.
Please advise if you have questions or comments.

MECKLENBURG COUNTY
Department of Environmental Protection
April 17, 2001
Mr. Dave Goodrich
NCDENR - DWQ - NPDES Unit
1621 Mail Service Center
Raleigh, NC 27699-1617
Subject: Paw Creek Petroleum Terminal NPDES Permit Renewals
Dear Mr. Goodrich:
V
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RECEIVED
WATFR rw to ny Sr.r. PON
APR � U 2021
*1108marge Pemary
The Mecklenburg County Department of Environmental Protection (MCDEP) has reviewed the
subject draft permits. As you know. MCDEP has a Memorandum of Agreement with the
Division of Water Quality to conduct inspections of the Paw Creek terminals in order to
determine compliance with the applicable NPDES permits. We offer the following comments
regarding the permits:
General
- Flow Measurement
The flow measurement method by which facilities are allowed to calculate flow based on
the area draining to the outfall, the built -upon area, and total rainfall using the rational
equation is inaccurate in most cases. Most facilities inspected by MCDEP collect
stormwater in earthen secondary containment basins surrounding the above ground
storage tanks (not ponds). The facilities generally hold the storn:water for as long as
possible (several weeks if weather permits) to allow any suspended solids to settle out
and to avoid discharge if possible so that monthly sampling and laboratory analysis does
not have to be performed. Calculating discharge flow by this method is inaccurate
because it does not account for evaporation and ground infiltration during the holding
period.
• Quarterly Turbidity Monitoring
The permits state that "Effluent turbidity shall not cause the receiving stream turbidity to
exceed 50 NTU. If receiving stream background turbidity exceeds 50 NTU, effluent shall
not cause this background value to increase."
PEOPLE • PRIDE • PROGRESS
700 N. Tryon Street - Suite 205 - Charlotte, NC 28202-2236 - (; 04) 336-5500 - Fax [phone]

Mr. Dave Goodrich
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 2
The permits require quarterly turbidity monitoring at the effluent. The permits do not
require upstream or downstream monitoring for turbidity. Without instream monitoring
requirements, compliance cannot be determined.
Individual Facility Comments
Williams Terminals Holdings, L.P. - Permit # NC0074705
An error was noted on the fact sheet for this facility. The background section refers to a
detention pond which is used to hold wastewater prior to discharge. MCDEP has
determined that the treatment works for this facility do not include a detenti n pond.
Exxon Mobil Refining and Supply Company - Permit # NC0004839 v//
Outfal1001-
The daily maximum permit limit for benzene is listed as 1.2µg/1. The North Carolina
water quality standard for WS-IV waters is 1.19µg/l.
Marathon Ashland Petroleum, LLC - Permit # NC0046213
The last footnote on the Effluent Limitations and Monitoring Requirements
page of the permit states, "There shall be no direct discharge of tank (or pipe) contents
following hydrostatic testing unless benzene concentration is less than 71.4k41 and
toluene concentration is less than 1 l/ug/1." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19µg/l.
Colonial Pipeline Company - Permit # NC0031038
MCDEPs past inspections of this facility indicate that the retention pond located on -site
receives flow from three intermittent streams. While the streams are classified as
intermittent by USGS, terminal personnel have indicated that the streams have perennial
flow. In addition, stormwater discharges from the Citgo facility (NC0021962) and Crown
Central Petroleum Corporation (NC0046531) flow to Colonials' retention pond before
entering the receiving stream. Since these conditions exists prior to the outfall location
(sampling point), MCDEP has concerns that these influences may constitute dilution of
the waste stream and effluent analysis may not be totally representative of the facility's
wastewater characteristics. In addition, Colonial could potentially be liable for impacts
from off -site sources.

Mr. Dave Goodrich
Paw Creek Petroleum Terminal NPDES Permit Renewals
April 17, 2001
Page 3
If you have any questions regarding these comments, or any other matters, please feel free to give
me a call at 704/336-5500. Thank you.
Sincerely,
Rus ozzelle ,
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP
4

Sent By: ;
M 821 0337; May-2-01 16:32; Page 213
WI11iAM II. wGA'RIr[i4['OON
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May 29 2001
NORTH--CAROLINA
PETROLEUM
COUNCIL
A Vb&fdn of the Amatm Ae&*k= buttt ft
SUMS 2850 • 150 FAYETMVnJZ ST. MALL
RALEIGH. KC 27601
O 1A f 8'28-5438 • RAX9] 9 f 8'21-=7
Mr. Rick Sliver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Ext.
Wilmington, NC 28405-3845
Rc: NPDES Permit Renewals
Paw Greek Petroleum Pipeline and Distribution Terminals
Charlotte (Mecklenburg County), North Carolina
Dear Mr. Shiver:
Thank you for the professional manner in which the public hearing on the petroleum terminals'
NPDES permits was conducted in Charlotte on April 19, 2001.
The purpose of this letter— which ! request be included in the official hearing record — is to
express my members' strong concern about the way MTBE is being addressed in the terminals'
draft permits.
The North Carolina Petroleum Council — a division of the American Pctroleum Institute, the
trade association for the nation's m'or fuel suppliers -- is committed to insure that the
oppormaity for public: hearings and comment is an integral pact of government decision -malting.
So we simultaneously praise the process that allows us to submit this statement for the record,
while we point with alarm to the proposed MTBE limit of 11.6 ug/L that has been included in the
dram permits without a single hearing or any official review by a rulemaking body.
We asked the Department (DENR) to help us understand how this limit came about. We were
told that there is no surface -water standard for MTBE. Further, we were advised that the
pmposed MTBE limit has not been endorsed by tho Environmental Management Commission
has not been debated by those publicly appointed members — has not been the subject of public
hearings at all. In fact, the EMC recently dealt with the matter of MTBE and voted not only to
reject a request for a temporary groundwater standard of 70 ppb, but also to re ffmn'the value of
public hearings by calling for a permanent ndemaking process to tighten the MTBE groundwater
mod. So ea vm i4l Wxeit the ha&s nV, vwawma oa that wmvozal, we are now confronted with

Sent By: ; 919 821 0337; May-2-01 16:32;
Page 3/3 '
Mr. Rick Shiver
May 2312001
Page 2
draft NPDES permits that attempt to install an MTBF, limit that is at best controversial and at
worst a circumvention of the EMC.
It is my understanding that MTBE was not an issue for the Department in the NPDES permits
issued five years ago.
To be sure, in the intervening years it has been an issue of increasing attention, study, debate and
speculation. Apparently some individuals have been so moved by the growing debate that hasty
changes in risk calculations and other values have occurred. A few advocates within the
Department who sounded the alarm so vigorously in statements to the EMC in support of an
MTflE groundwater standard of 70 ppb have now changed their minds! What had been a
certainty one month was abandoned the next in favor of it new calculation — and a new limit
level. So, if public hcalth considerations are truly moving this fowt, it numbers are hastily
abandoncd and recalculated, if the science is in such a state of flux, then our commitment to
reasoned public input is all the more appropriate and needed to insure that the calculations of
today are not abandoned tomorrow.
The Council's members accept that an MTBE limit that has been peer -reviewed and duly
considered via the rulemaking process may be appropriate for inclusion in the terminals' NPDES
permits. Lacking that, however, the Council believes the MTBE limits contained in the draft
permits should be removed.
Importantly, the Council's members with facilities in Charlotte are willing to help the
Department collect MTBE data by monitoring for it on a periodic basis. But the proposed
monthly monitoring requirement is excessive. We are confident that scmi-annual monitoring by
each of the terminals will providc the needed representative data to form the basis for future
decision -making.
Sincerely,
Ch• M'
William H. Weatherspoon
WHWIjm -
c: Ms. Natalie Sierra

SURFACE WATER QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS
is
CONTAMINANT
CAS #
"C" & "B" WATERS
(ug/l unless noted
otherwise)
"WS-I" - "1NS-V"
WATERS
WATERS (ug/l unless
noted otherwise)
SOURCE OF STANDARD
OR CRITERIA
BENZENE
71-43-2
71.4
1.19
71.4
15A NCAC 2B .0211-.0222
n-BUTYL BENZENE
104-51-8
36
36
36
ECOTOX 4/98
sec -BUTYL BENZENE
135-98-8
41
41
41
ECOTOX 4/98
CHLOROFORM
67-66-3
470
5.7
470
EPA 4/22/99
ETHYL BENZENE
100-41-4
383
524
130
ECOTOX 1101
IPE
- 108-20-3
19 mg/L
19
330 mg/I
ECOTOX 1/01
ISOPROPYL BENZENE
98-82-8
316
186
4.6 mg/I
ECOTOX 1/01
p-ISOPROPYL BENZENE
99-87-6
325
325'
1.1 mg/I
ECOTOX
METHYLENE CHLORIDE
75-09-2
1600
4.7
1600
EPA 4/22/99
MTBE
1634-04-4
2393
11.6
2393
NC DHHS 7/11/00
NAPHTHALENE
91-20-3
105
43•
64
ECOTOX 1/01
n-PROPYL BENZENE
103-65-1
77.5
77.5
190
ECOTOX 1/01
1,2,4-TRIMETHYLBENZENE
95-63-6
386
72
218
ECOTOX 1/01
1,3,5-TRIMETHYLBENZENE
108-67-8
626
100
215
ECOTOX 1/01
TOLUENE
108-88-3
11 (0.36 Tr)
11 (0.36 Tr)
185
15A NCAC 213.0211-
.0222/ECOTOX 8/99(SW)*
XYLENE, TOTAL
1330-20-7
88.5
88.5
370
ECOTOX 1/01
Criteria which have a source of EPA ECOTOX were developed using EPA's ECOTOX database per 15A NCAC 2B .0208.
Last update 2/2/01 (DMR) These concentrations are updated regularly.
Questions or criteria for other parameters not found in the 15A NCAC 2B .0200s can be addressed to Dianne Reid at
919.733.5083 extension 568 ([e-mail]) OR Jason Wynn ext. 351 ([e-mail])

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. NCO046213
Facility Information
Applicant/FacilityName:
NCO046213 — Marathon Ashland Petroleum, LCC
Applicant
ress:
Mr. Peter A. Reynolds — 539 SouthamStreet; Findlay,
FacilityAddress:
8035 Mount Holly Road; Paw Creek
Permitted
ow
not limited
Type of Waste:
stormwater, loading rack water
Facility/PermitStatus:Active;
Renewal
County:
Mecklenburg
BACKGROUND
FILE REVIEW
Correspondence
Correspondence files from 1996-2000 were reviewed. During this time period, the Mecklenburg
County Department of Environmental Protection (MCDEP) performed three inspections. The facility received
a satisfactory rating on all of these inspections with the exception of a marginal rating during the 1997
inspection in the `Self -Monitoring Program" category. This was given because the facility had been
monitoring once a month for TSR, phenol, turbidly, and oil and grease instead of the twice -monthly frequency
required by the April 1996 permit.
Grab samples taken during the MCDEP compliance inspections indicate low levels of total suspended
solids (TSS) and non -detects for the volatiles and semi-volatiles detectable by the EPA 624/625 scan.
The facility received one notice of violation (NOV) in March 1997 for non -submittal of the toxicity
test results. It was also noted that the data were reported as "ND" instead of "< detection limit' in the
DMRs.
DMR Review:
DMRs were reviewed from September 1997 through January 2001. The average discharge flow at 001
was 0.14 MGD. Total suspended solids (TSS) during this time averaged 6.3 mg/L with a maximum of 20.0
mg/L. The average oil and grease concentration was 7.05 mg/L with a maximum concentration of 63.0 mg/L.
The data for the twice -annual EPA 624/625 scan were missing from the DMR folder. The data have
been requested from the facility but had not been received in time for the public notice.
Since March 1999, the facility has been required to sample for turbidity quarterl as per an EPA
directive. They have sampled during each discharge event since the requirement was instilled — the average
turbidity value in the past year and a half is 13.68 NTU with a maximum of 21 NTU.
The facility has passed its acute toxicity test since 1997.
Reasonable Potential Analysis:
Reasonable potential was performed for turbidity as a check for the necessity of including a limit of 50
NTU in the permit. Turbidity data indicate that effluent does not have the potential to exceed the stream
Fad Sheet
NPDES NCO046213
Renewal
Page 1

standard of 50 NTU. The maximum predicted turbidity at 001 was 49 NTU; due to the proximity of that value
to the stream standard, monitoring frequency should be increased from quarterly to monthly.
Reasonable potential was also performed for phenols and benzene. The maximum predicted benzene
concentration was 6.9 ug/L, which is in exceedence of the standard. The maximum predicted phenol
concentration was 0.088 mg/L, which does not exceed the loading as determined by the calculation below
(based upon a 2/23/01 memo by Joe Corporon of the NPDES Unit that specifies a 0.43 lbs./day phenol loading
for each terminal discharging to WS waters in the Paw Creek area):
Calculation for 001:
0.43lbs I day x 1 = 0.199m / L
8.34 0.26MGD g
PERMITTING STRATEGY
The permitting strategy for this and all oil terminals in the state is based upon a 2001 NPDES
document entitled, "Permit Requirements for Discharges from Oil and Petroleum Storage Facilities." This
document is based upon a 1996 SOP and has been updated by the NPDES Unit after a data review and internal
discussions. It delineates monitoring frequencies and permitting limits for contaminants commonly found at
these sites. This document is hereafter referred to as the "2001 SOP."
Waste Load Allocation (WLA).
The last waste load allocation was performed in 1989. This WLA recommends TSS, oil and grease,
pH, turbidity and lead limits.
Oil Terminal SOP:
The flow, toxicity, TSS, and oil and grease requirements specified in the previous permit and the 2001
SOP (Parts I.A. — I.D.) remain unchanged. Previously, the permit required semi-annual monitoring of xylene
in conjunction with EPA Methods 624/625, the facility will now be required to monitor monthly for the BTEX
parameters as per Part I.E. of the SOP. Benzene will be limited as per Part III.B of the SOP for facilities
discharging to water supply waters. This facility discharges to water supply waters, phenol monitoring and
MTBE monitoring and limits (Part III.A-C) are therefore required.
Since the data reports of EPA Methods 624/625 were missing from the DMR files, this requirement
will stay in the permit as per Part II.A. of the SOP. A request was made that the facility submit the appropriate
data for assessment. It has yet to be received, but upon receipt, it is possible that the 624/625 monitoring
requirement will be lifted. Naphthalene monthly monitoring will be added to the permit as per Part I.F. of the
2001 SOP. Turbidity monitoring will be increased to monthly as per Part II.C. As per parts I.G. and I.H. of
the 2001 SOP, there can be no direct discharge of tanks solids, tank bottom water or the rag layer, and no
direct discharge of hydrostatic test water if concentrations of benzene and/or toluene exceed the water quality
standard.
A note will be placed in the permit that reminds the facility to report all detection limits on the DMRs.
There are several occasions on which this was not done.
SUMMARY OF PROPOSED CHANGES
• Addition of naphthalene monitoring
• Addition of MTBE monitoring and limit
• Addition of monthly turbidity monitoring
• Addition of monthly BTEX monitoring
• Addition of benzene limit
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: March 14, 2001
Permit Scheduled to Issue: April 27, 2001
Fact Sheet
NPDES NCO046213
Renewal
Page 2

REASONABLE POTENTIAL ANALYSIS
Prepared by: Natalie Sierra, 3/7/01
Facility Name =
NPDES # _
Qw (MGD) _
Qw (cfs) _
7Q10s (cfs)=
! WC (%) _
Marathon/Ashland
NC0046213
0.2592
0.401034
0
100.00
Frequency of Detection
Parameter I FINAL RESULTS. ua/l #Samples # Detects
Phenols
Max. Pred Cw (mg/L) 0.088
Allowable Cw (mg/L) 0.2 24 3
Benzene
Max. Pred Cw 6.9
Allowable Cw 1.2 24 1
rbidity
Max. Pred Cw 49.4
Allowable Cw 50.0 6 6

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04/30/2001 16:17 7704272607 MAPLLC
PAGE 01
o� -
M FAX [phone] and OVERNIGHT MAL
April 30, 2001
NU. Natalie SlexTa
NCDENR 1 Water Qualiity / NPDF-S Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Manta District
Tarminal & Transport rNnent
MARATHON MLA
1625 WiQiams Drive
Suite 210
Marietta, GA 30066
Telephone [phone]
Fax [phone]
Re: Draft NPDES Permit Renewal - N'CO046213
Marathon Ashland Petroleum LLC's Charlotte, ETC Terminal
8035 Mt. Holly Road, State Hwy #27, Paw Creek, NC 28130
Dear Ms. Sierra:
The purpose of this letter is to provide comments on the Draft NPDES Penxit fax
Petroleum (MAP) facility. The Draft permit contains many changes that do no
MAP wishes to express concerns over these,
MTB)K
The new permit constraints for methyl tertiary butyl ether 04TBE) are unwarran
the new requirement to sample, document and report this now paramet
adnak' nistrativc burden without benefit. The regulated community is often burd+
chemicals of concern so that the regulating agency can gather data. In order
permits become more cumbersome and complicated.
Sampling for this new parameter every month is a wasteful martial Ini vestigation.
approach would include sampling the streams upgradient of the Paw Creek facil
point sources in the terminal complex once or twice. This information would pro,
to dctcrmiinc concentrations of NME in the surfacc waters. MAP understanc
Water Quality wishes to deter nine if detrimental concentrations of MT13E are p
the state. However, MAP does not believe that the stormwater runoff from the l
concentrations in receiving streams.
Petroleum LLC
c Marathon Ashland
seem, warranted, and
MAP believes that
every month is an
I with sampling new
obtain this data, the
A more appropriate
ies, and sampli% the
'de the necessary data
that the Division of
esent in the waters of
�Rity is impacting the

04/30/2001 16:17 7704272607
MAPLLC
PAGE 03
This chemical of concern has not been present in the past yeus' samples. So,
a component of heavier fuels it has not been detected in effluent from the MAP
should be removed.
Finally, as outlined in the original renewal application, MAP is requesting to add
petroleum contact water to the NPDES permit. In order to consolidate the mull
the facility, the proposal was submitted it with the signed form C. Currently, the
using an oil -water separator and an air stripping system, The treated ovate
discharged to the sanitary sewer under an industrial use permit (Charlotte
Department Permit #3015). The contact water is primarily impacted rainwater tl
loading rack area, but routine rinsing of the equipment (hoses, pipes, trucks) u
contributes to the contact water volume. The impacted water flows into tren
fraction of petroleum product is separated and returned to an on -site storage tan
then is pumped to an accumulation tank, where it is aerated to remove organic cA
of secondary treatment, granular activated carbon can be used to process
accumulation tanks and the pond.
;h naphthalene is
. This parameter
to discharge of treated
N of pennits covering
intact water is treated
is then analyzed and
Aecidenburg Utilities
: falls within the truck-
1er the load -rack also
k drains, and then the
The remaining water
pounds. As a method
e water between the
MAP respectfully submits these comments and urges your consideration of a issue. The concerns
listed above concern the additional adrrtiuisfirative burden of a more complicated rmi�t. Please note that
as always MAP is committed to enviurownental stewardship and compliance 1th North Carolka's
regulations and appreciates your attention to this facility.
I look forward to hearing from you on these issues. If you have any
770/427-3 500, ext. 608.
Sincerely,
Phil Newton
Environmental Engineer
Att — DRMT Permit
W. P.A.. Reynolds w/ att
T.L. Swick w/ att
Please, call me at

04/30/2001 16:17 7704272607
MAPLLC
PAGE 02
AdditionaU.y, the 1Vi'I'$E limit imposed by the permit is not justified. The permit
uA but this value is not supported. I am not aware of any health -based drinl
MME under the Federal Safe DrinidnS Water Act or under NCDF-NR regul
shown that MTBE doses rcquircd to produce illness in laboratory animal are ord
than humans could conceivably be exposed to through consumption of drink
advisory published in 1997 indicated that although 1vITIBE may affect the tas
rposes a Wt of 11.6
g water standard for
ons. Research has
of magnitude higher
water. The EPA's
or odor of water at
concentrations of about 40 ug/l, this value is 20,000 to 100,000 times lower th the range of exposure
levels in which health affects were observed in laboratory animals. Even North aroli�na's 15A, NCAC
2L standard for MME in groundwater is 200 ug/l. No drinking water or su ater quality standard
has been established.
MAP understands the groundwater standard was established by using an expos
per day as a systemic threshold where no adverse effects were observed in ar
divided by an uncertainty factor of 3,000 to correlate the number to humans.
value is conservative. This conservative value has been reviewed by the Envit
Commission and established by the traditional rulemaking process. The 11.6 ug4
draft permit has not been through the same scr tiny.
Turbidity
MAID asserts that results for Total Suspended Solids correlate with the t
are, redundant. If the turbidity monitoring must be performed in order to
for modeling, quarterly turbidity testing should be sufficient.
IBTEX
Currm ly MAP samples for benzene monthly and the other parameters sovn a=
method analyses. The Draft permit proposes monthly sampling of each, and ]
for this additional data. The semiannual sampling data for the past few years i
in only one sample in 1997. That result was 3.6 ug/l. Toluene and et)ylbenze
and the past testing data should support the decision to remove these pars
requirements.
624/625
The EPA, methods 624 & 625 analyses are burdensome and expensive. M
methods for the past few years and has shown that these ckrwcals are not
stormwater discharge. Therefore, although these chemicals do exist in the pe
has submitted enough data to show there is no reasonable potential for the sto
impacted.
Napthnlene
value of 100 kg/mg
9s. This value was
such, the threshold
nental Management
it unposed in MAP's
and that the two test
additional data points
in the ) 'PA.624162S
questions the need
rted xylenes present
ve not been present,
;rs from the permit
has employed these
sent in the facility's
eum products, MAP
eater discharge to be

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
Michael F. Easley, Governor
William G. Ross, Jr., Secretary
Kerr T. Stevens, Director
April 2, 2001
MEMORANDUM
,&74#6 2
�� �
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCE5
PR E CEIVu
10 Britt setter APR 0 4 2001
NC DENR / DEH / Regional Engineer
Mooresville Regional Office NCDENR
Division of Environmental Health
From: Natalie Sierra Public Water Supply Section
NPDES Unit Mooresville Regional Office
Subject: Review of Draft NPDES Permit NCO046213
Marathon Ashland Petroleum, LLC — Charlotte Terminal
Mecklenburg County
Please indicate below your agency's position or viewpoint on the draft permit and return this form by
May 2, 2001. If you have any questions on the draft permit, please contact me at the telephone number
or e-mail address listed at the bottom of this page.
RESPONSE: (Check one)
Concur with the issuance of this permit provided the facility is operated and maintained properly, the
stated effluent limits are met prior to discharge, and the discharge does not contravene the designated
water quality standards. _ .-
❑ Concurs with issuance of the above permit, provided the following
❑ Opposes the issuance of the above permit, based on reasons stated
Sri
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 919 733-5083, extension 551 (lax) 919733-0719
VISIT US ON THE INTERNET@ httpJ1h2o.enrstate.nc.us/NPDES Natalie.Sierra0 ncmail.net
U

of WArfi�
r NC ENR
Mr. Peter A. Reynolds
Marathon Ashland Petroleum, LLC
539 South Main Street
Findlay, Ohio 45840
Dear Mr. Reynolds:
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Kerr T. Stevens, Director
Division of Water Quality
March 14, 2001
Subject: Draft NPDES Permit
Permit NCO046213
Charlotte Terminal
Mecklenburg County
Enclosed with this letter is a copy of the draft NPDES permit for the above referenced facility. I
encourage you to review the draft carefully to ensure thorough understanding of the information,
conditions, and requirements contained therein.
A new permitting strategy has been developed by the Division of Water Quality to address the
specific issues related to oil and petroleum storage facilities. Some changes have been made to this permit
as a result of the 2001 strategy. In addition, the receiving stream for your facility's outfall - an unnamed
tributary to Gum Branch - was erroneously classified as "C" waters in your last permit. The receiving
stream is actually class WS-IV waters, and as such, requires specific limits and monitoring requirements
applicable to water supply waters. Please pay particular attention to the following changes that have been
made from your previous permit:
• You are now required to monitor monthly for BTEX (benzene, toluene, ethyl benzene and
xylene) parameters. This is a new requirement applicable to all bulk storage facilities in the
state of North Carolina. In addition, a benzene limit of 1.19 µg/L has been added due to the
water supply classification (WS-IV) of the receiving stream.
• Naphthalene monthly monitoring has been added to this and all oil terminal permits in the
state. A component of heavier fuels such as diesel, naphthalene has been detected in the
effluent of a number of facilities across the state. There is therefore concern that a potential
exists for a violation of the naphthalene water quality standard.
MTBE monthly monitoring has been added to this and all oil terminal permits in the state.
MTBE is a gasoline component that has recently been identified by the Environmental
Protection Agency (EPA) as a potential carcinogen. The Division of Water Quality has added
this monitoring requirement to ensure that detrimental concentrations of MTBE are not
contaminating the waters of the state. In addition, because the receiving stream is a water
supply water, a MTBE limit of 11.6 µg/L has been added to your permit.
As a result of EPA concerns over turbidity, turbidity monitoring has been added to all oil
terminal facilities in the Paw Creek area. A Division evaluation of turbidity and total suspended
solids data led to a 1999 decision to require quarterly turbidity monitoring in Paw Creek. Your
facility received a letter in February 1999 indicating that quarterly turbidity monitoring would
become effective in March 1999. A reasonable potential analysis was performed using these
data and it was determined that effluent from your facility demonstrated the potential to violate
the stream standard for turbidity. Monthly turbidity monitoring and a limit of 50 NTU have
been added to your permit.
N. C. Division of Water Quality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center 1800 623-7748

In addition, please note that you must include all detection limits on your DMRs. A parameter
should never be reported as "ND" or zero. Proper reporting of a non -detect of a monitored parameter
should read "<" followed by the detection level provided by a North Carolina certified laboratory.
Please submit any comments or questions concerning this draft permit no later than thirty (30)
days following receipt of this letter. Comments should be sent to:
Ms. Natalie Sierra
NCDENR — DWQ -NPDES Unit
1621 Mail Service Center
Raleigh, North Carolina 27699-1617
If you have any questions or comments concerning this draft permit, please contact me at
919-733-5083 extension 551 or via e-mail at: Natalie.Sierra@,ncmail.net.
Sincerely,
Natalie V. Sierra
NPDES Unit
cc: Mooresville Regional Office/Water Quality Section
NPDES Unit
Aquatic Toxicology Unit
Mecklenburg County Department of Environmental Protection
NC - DEH

Permit NCO046213
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-,1,2
promulgated and adopted by the North Carolina Environmental Managed
Control Act, as amende , \
Marathon Ashland "eole
is hereby authorized to di
other I' Wful standards and regulations
mission�the Federal Water Pollution
0 57GI�u'geek
oTNy Road
Pa1y
M Oburg County
LLC.
ilitv located at
to receiving waters designated as an unnamed tributary to Long Creek within the Catawba River Basin
in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts
I, II, III and IV hereof.
This permit shall become effective September 1, 2001.
This permit and authorization to discharge shall expire at midnight on June 30, 2005.
Signed this day
Kerr T. Stevens, Director
Division of Water Quality
By Authority of the Environmental Management Commission

Permit NCO046213
SUPPLEMENT TO PERMIT COVER SHEET
Marathon Ashland Petroleum, LLC
is hereby authorized to:
1. continue to o erate the existing water pollution system co m ling
,\& Z/�>
• a spill containment area
• a final holding pond
located at 8305 Mount Holly Road
and
2. discharge from said treatment facility through Outfall 001 at a specified location (see attached map)
into an unnamed tributary to Long Creek, a waterbody classified as WS-1V waters within the
Catawba River Basin.

Permit NCO046213
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Beginning on the effective date of the permit and lasting until expiration, the Permittee is authorized to
discharge from Outfall 001. Such discharges shall be limited and monitored by the Permittee as
specified below:
EFFLUENT
C$ARACTERISTICS
,; „ ont
Avet`ge _
,; ai...
,
easurement
Frequency.
am a
=TYPe
am e. ocahon
Flowl
Monthly
Eftluent
'Yotal SuspendedSolids
m
ont y ,,
Grabuent
Oil and Grease
on
\\Cirab
Effluent
Turbidity
ont ' y
\, ra
Effluent
Phenolnt
y,/,\
GKA
Effluent
Benzene
1.19 µg/L
., c� ]V
Urftbr
Effluent
o uene
\\ onfi , y,
GrabEffluent
Ethyl Benzene
nqt \Grab
Effluent
y ene
,f" \
,ont, y,, V
Grab
uent
Naphthalene
MontGrab
'---Effluent
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EPA Methods
\" '--,azini-annually
Grab
Ettluent
PH4
Monthly
Grabuent
Acute Toxicity5
nnually
Grab
uent
Footnotes:
1. Flow — During periods of no flow, the P ittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow m - be monitored in one of four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude built -upon
area (best method for facilities with large runoff -collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
2. Oil and Grease — Where possible, the grab sample for oil and grease should be skimmed from
the surface of a quiescent (calm water) zone.
3. Turbidity — Effluent shall not cause receiving stream turbidity to exceed 50 NTU. If receiving
stream background turbidity exceeds 50 NTU, effluent shall not cause this background value to
increase.
4. pH shall not fall below 6.0 nor exceed 9.0 standard units.
5. Acute Toxicity (Fathead Minnow, 24-hour), Annual [see Special Condition A.(2.)].
There shall be no discharge of floating solids or foam visible in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct discharge of tank (or pipe) contents following hydrostatic testing unless benzene
concentration is less than 71.4 µg/1 and toluene concentration is less than 11 µg/l.

Permit NCO046213
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined a: �Sefinitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity^ .T Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fa ado ow (Pimephales promelas)
24-hour static test. Effluent samples for self-monitoringse must b btained below all waste
treatment. The ermittee will conduct one test annually, pth I annual erid e innin in January of
p Y� p �g g asY
the calendar year of the effective date of the permit. The annual,es� rq. iirement,rust be performed and
reported by June 30. If no discharge occurs by June 30, no:eyenjr
cattill be made to the Division by this
date. Toxicit testin will be erformed on the next disc the annual test re uirement.
Y g P q
The parameter code for this test is TAE6C.
condition will be entered on the Effluent <
performed, using the appropriate parameter c
to the following address:
Attention: \North
ty esting"T, ti required as part of this permit
Fo (MR- ) for the month in which it was
i ,pal � DWQ Form AT-1 (original) is to be sent
of Water Quality
Branch
ervice Center
orth Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.

May 11, 2001
Ms. Valery Stephens
NCDENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
p
EC EIME
MAY 2 3 gatD
DENR-WAT ER QUALITY
POINT SOURCE BRANCH
Atlanta District
Terminal & Transport Department
MARATHON ASHLAND Petroleum LLC
1625 Williams Drive
Suite 210
Marietta, GA 30066
Telephone [phone]
Fax [phone]
Re: NPDES Permit Renewal - NCO046213
Marathon Ashland Petroleum LLC's Charlotte, NC Terminal
8035 Mt. Holly Road, State Hwy #27, Paw Creek, NC 28130
Dear Ms. Stephens:
n
Marathon Ashland Petroleum (MAP) is submitting this letter to provide additional information that the NCDENR
requested to process the NPDES permit renewal.
A site plan is enclosed indicating all sources of stormwater. Currently, only stormwater runoff is discharged
through the permitted outfall. Please note however that MAP is requesting in the renewal application to
discharge processed petroleum contact water through this outfall as well.
• Electronic copies of much of the past years' monitoring data has been forwarded to Natalie Sierra for review.
Stormwater runoff from the tank farm is diverted to a retention pond then discharged through the permitted
outfall. Rainwater that falls in the area of the truck loading area is collected and treated using an oil -water
separator and an air stripping system. The treated water is then analyzed and discharged to the sanitary sewer
under an industrial use permit. The contact water is primarily impacted rainwater that falls within the truck -
loading rack area, but routine rinsing of the equipment (hoses, pipes, trucks) under the load rack also contributes
to the contact water volume. The impacted water flows into trench drains, and then the fraction of petroleum
product is separated and returned to an on -site storage tank. The remaining water then is pumped to an
accumulation tank, where it is aerated to remove organic compounds.
Tank materials (solids, bottom water, and the rag layer) are drawn from the tanks and handled off -site. MAP
primarily contracts with a service contractor to reclaim the usable product from these materials. These materials
are typically removed from the tanks using vacuum tanker through "water -draw" valve on the tank. The
contractor will ensure a tight connection to the valve. When a tank is taken out of service for cleaning and/or
inspection, these materials may be removed from the tank through the manway.
Domestic wastewater from the office restrooms and sinks is discharged to the city sewer.
I appreciate your attention to this facility. If you have any questions, please call me at 770/427-3800, ext. 608.
2�
Phil Newton
Environmental Engineer
Enclosure
cc: R-L. Householder w/att via regular mail
T.L. Swick w/att via regular mail

I
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DESCRIPTION OF SITE
SITUATED IN PAN CREEK TOWNSHIP
C%XTI OF NECKLENBERG, STATE OF
NORTH CARDLINA, WITH A STREET
ADDRESS OF bI61 TIT HOLII RD.
151. HIM •211 CHARLOTTE. N.C.
LEGEND
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Attachment #1
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M ,�
April 3, 2001
!� Mr. Kerr T. Stevens
GGG NCDENR / Water Quality / NPDES Unit
`1617 Mail Service Center
Raleigh, NC 27699-1617
Atlanta District
Terminal & Transport Department
MARATHON ASH
1625 Williams Drive
Suite 210
Marietta, GA 30066
Telephone [phone]
Fax [phone]
O,c��RG
LCC-
a•
:• �7• 1 Ida � 1 _'
�1?;mx'�3_�•:::^:�.t_:c::-.xxx�uxcxxuxxxxxaxaxxuxuxu�v?x�
Re: NPDES Permit Renewal - NCO046213
Marathon Ashland Petroleum LLC's Charlotte, NC Terminal
8035 Mt. Holly Road, State Hwy 427, Paw Creek, NC 28130
Dear Mr. Stevens:
Marathon Ashland Petroleum (MAP) has received your letter dated March 27, 2001, which indicated
the NCDENR did not receive this facility's permit renewal application. Please note that this application
package was sent via overnight mail on February 27th to the Mail Service Center. According to the
Airborne Express mail ticket, the package was received the next day (February 28') at 11:22 am.
Someone named B. Washington signed for the package.
For your use, I have enclosed another copy of the renewal application. I have also sent a copy of this
to Natalie Sierra since she is working on the draft permits. I spoke with Ms. Sierra yesterday about
sending the application directly to her, but was told that all mail must be sent to the mail center for
distribution.
MAP strives to comply with all regulatory requirements, and takes a notice of violation (NOV) very
seriously. Since the renewal application was mailed before the due date, this NOV is in error and it needs
to be rescinded.
I appreciate your help with this matter. If you have any questions or need additional information, please
call me at 770/427-3800, ext. 608.
Phil Newton
Environmental Engineer
Enclosure
cc: R.L. Householder w/o enc - via regular mail
T.L. Swick w/o enc — via regular mail
PA. Reynolds w/o ene - via regular mail
Mooresville Regional Office Water Quality Section w/ enc. — via Certified Mail
919 North Main Street, Mooresville, North Carolina 28115

VIA OVERNIGHT MAIL
February 23, 2001
Mr. Charles H. Weaver, Jr.
NCDENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
Re:
Atlanta District
Terminal & Transport Department
MARATHON ASHLAND Petroleum LLC
1625 Williams Drive
Suite 210
Marietta, GA 30066
Fax
NPDES Permit Renewal - NCO046213
Marathon Ashland Petroleum LLC's Charlotte, NC Termini
8035 Mt. Holly Road, State Hwy #27, Paw Creek, NC 28130
Dear Mr. Weaver:
CE0dL1 r.
WWI
POINT
Marathon Ashland Petroleum (MAP) requests to renew the subject NPDES permit. Enclosed is an
original and two (2) copies of the completed Short Form C Permit Application. In accordance with
requirements of the renewal package, please note the following:
There have been no substantive changes to the facility since the last renewal.
• The permit application requests coverage of controlled stormwater discharges. No sanitary, cooling
water, or industrial process water is discharged to surface waters.
• The facility does not generate any solids. So, a sludge management plan has not been developed.
In addition to maintaining coverage for the storm water discharge, MAP is requesting to add the
discharge of treated petroleum contact water to the NPDES permit. I spoke with Mr. Michael Myers
of the NCDENR this week and informed him that MAP wishes to discharge the treated contact water
under the subject permit. In order to consolidate the number of permits covering the facility, Mr. Myers
said to outline the proposal and submit it with the signed form C.
Currently, the contact water is treated using an oil -water separator and an air stripping system. The
treated water is then analyzed and discharged to the sanitary sewer under an industrial use permit
(Charlotte -Mecklenburg Utilities Department Permit #3015). Attachment #1 is a plot plan of the
facility. The contact water is primarily impacted rainwater that falls within the truck -loading rack area,
but routine rinsing of the equipment (hoses, pipes, trucks) under the load rack also contributes to the
contact water volume. The impacted water flows into trench drains, then the fraction of petroleum
product is separated and returned to an on -site storage tank. The remaining water then is pumped to
an accumulation tank, where it is aerated to remove organic compounds. See Attachment #2 for a
schematic of the contact water flow.
Please note that the contact water has been analyzed in accordance with the current sanitary sewer
permit. A copy of recent analyses is enclosed. Also enclosed is a copy of a technical report,
Attachment #3, supporting MAP's use of air stripping technology to remove hydrocarbons from the
contact water.
is
1

In order to discharge to the NPDES outfall, MAP would disconnect from the sanitary sewer and route
the treated water to the stormwater retention pond (refer to Figure 1). As a method of secondary
treatment, granular activated carbon can be used to process the water between the accumulation tanks
and the pond. The carbon treatment equipment is already available at the site. It was previously used
as part of a groundwater remediation program. Note that MAP is not proposing to mix the contact
water with the treated groundwater. Attachment #4 depicts the carbon treatment equipment.
I appreciate your attention to this facility. If you have any questions, please call me at 770/427-3800,
ext. 608.
Sincerely)
Phil Newton
Environmental Engineer
Enclosure
cc: R.A. Richard w/attsend regular mail
T.L. Swick w/att send regular mail

M
R
N
. Marathon Oil Company - Pretreatment system
Typical Block Flow Diagram
Hydrocarbon/Watet
Milt From Loading
Rack Area
Oil
storage tanks
Hydrocarbon/Warr Mix
Loi,lwAtQr
separator
Vent to Water Vent to
Atmosphere Atmosphere
Compressed Process Tank Process Tank
Air Source
Alt
Processed Water
Ptooessed Water
Piped to
Sanitary
Sewer system

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