NC0074705_Permit Issuance_20010730

OF INATlo9 Michael F. Easley
Governor
Qr_k � ::� n William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
hNCD
O Kerr T. Stevens, Director
- - - - - Division of Water Quality
July 30, 2001
Mr. Steve Monn
Williams Terminals Holdings, L.P.
One Williams Center
Tulsa, Oklahoma 74172
Subject: Issuance of NPDES Permit NCO074705
Charlotte/Southern Facilities Terminal
Mecklenburg County
Dear Mr. Moan:
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.
• The phenol monitoring requirement was removed from your permit. This is a requirement for facilities discharging to water
supply waters and was incorrectly applied to this 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 Division believes that monthly monitoring of benzene, toluene, ethylbenzene and xylene (BTEX' 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 Divison for a modification to the permit reducing the monitoring
frequency for these compounds. Additionally, all NPDES pernits 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.
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 Sled with the Office of
Administrative Hearings (6714 Matt 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 [phone],
extension 551.
Since
Ke tev ns
cc Mooresrille Regional Office/Water Quality Section
NPDES Unit +
Central Files
Point Source Branch Compliance and Enforcement Unit
Mecklenburg County Dcpamnent of Environmental Protection
N. C. Division of Water Duality / NPDES Unit Phone: [phone]
1617 Mail Service Center, Raleigh, NC 27699-1617 fax: [phone]
Internet: h2o.enr.state.nc.us DENR Customer Service Center. 1 800 623-7748

,r
Permit NC00074705
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and regulations
promulgated and adopted by the North Carolina Environmental Management Commission, and the Federal Water Pollution
Control Act, as amended,
Williams Terminals Holdings, L.P.
is hereby authorized to discharge wastewater from outfalls located at the
Charlotte Southern Facilities Terminal
7145 Old Mount Holly Road
north of Charlotte
Mecklenburg County
to receiving waters designated as unnamed tributary to Paw Creek in the Catawba River Basin in
accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I,
II, III and IV hereof.
This permit shall become effective September 1, 2001.
This permit and authorization to discharge shall expire at midnight on June 30, 2005.
Signed this day July 30, 2001.
Kerr T S irector
Divisi of Wa r Quality
By Authority the Environmental Management Commission

Permit NC00074705
is hereby authorized to:
1. continue to operate a water pollution control system consisting of
• an oil/water separator
• a carbon filter
• a holding tank
located at the Charlotte Southern Facilities Terminal, 7145 Old Mount Holly Road, north of Charlotte,
Mecklenburg County, and
2. discharge from said treatment facility through Outfall 001 at a specified location (see attached map)
into an unnamed tributary to Paw Creek, a waterbody classified as C waters within the Catawba
River Basin.

Latitude: 35016'42" N
Longitude: 8055'30" W N C 0 0 74 7 0 5 Facility
Quad g F15SW/Mountain Island Lake
Receiving Stream: UT to Paw Creek Location
StreamCIUS:C Williams Terminals Holdings,
Subbasin: 30834
L.P. / NOT TO SCALE
�o r t /i

n Permit NC00074705
A. (1.) EFFLUENT LIP
Beginning on e e ective
discharge from Outfall 001
specified below:
TIONS AND MONITORING
Such discharses shall be
iration, the Permitlee is authorized to .
monitored by the Permittee as
«aMo
CIIARACTERISTIont
rt,,
t
y
rlyeragdf
ai
___
, Ma" IOM181
a+ easuremen
Fre uenc
9._..
_,.....
am sample Location,,
p.&
Flowl
Episodic
----Effluent
-Total Suspended o s
m
ont y
raEffluent
Oil and Grease
m
on y
raEffluent
Turbidity
uarter y
raEffluent
enzene
Monthly
ra
uent
o uene
on y—
Urab
Effluent
Ethylenzene
on y
ra
uent
y ene
on y
ra—Effluent
MTBE,
Effluent
EPA Methods
emi-annua y
raEffluent
Acute Toxici
nua y
raEffluent
Footnotes:
T. Flow — During periods of no flow, the Permittee shall submit a monthly Discharge Monitoring Report
(DMR) indicating "No discharge." Flow should 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. 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.

A
Permit NC00074705
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
SPECIAL CONDITIONS
A. (2.) ACUTE TOXICITY MONITORING (ANNUAL)
The Permittee shall conduct annual toxicity tests using protocols defined as definitive in EPA Document
EPA/600/4-90/027 entitled "Methods for Measuring the Acute Toxicity of Effluents to Freshwater and
Marine Organisms." The monitoring shall be performed as a Fathead Minnow (Pimephales promelas)
24-hour static test. Effluent samples for self -monitoring purposes must be obtained below all waste
treatment. The permittee will conduct one test annually, with the annual period beginning in January of
the calendar year of the effective date of the permit. The annual test requirement must be performed and
reported by June 30. If no discharge occurs by June 30, notification will be made to the Division by this
date. Toxicity testing will be performed on the next discharge event for the annual test requirement.
The parameter code for this test is TAE6C. All toxicity testing results required as part of this permit
condition will be entered on the Effluent Discharge Form (MR-1) for the month in which it was
performed, using the appropriate parameter code. Additionally, DWQ Form AT-1 (original) is to be sent
to the following address:
Attention: North Carolina Division of Water Quality
Environmental Sciences Branch
1621 Mail Service Center
Raleigh, North Carolina 27699-1621
Completed Aquatic Toxicity Test Forms shall be filed with the Environmental Sciences Branch no later
than 30 days after the end of the reporting period for which the report is made.
Test data shall be complete and accurate and include all supporting chemical/physical measurements
performed in association with the toxicity tests, as well as all dose/response data. Total residual chlorine
of the effluent toxicity sample must be measured and reported if chlorine is employed for disinfection of
the waste stream.
Should any test data from either these monitoring requirements or tests performed by the North Carolina
Division of Water Quality indicate potential impacts to the receiving stream, this permit may be re-
opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum control
organism survival and appropriate environmental controls, shall constitute an invalid test and will
require immediate follow-up testing to be completed no later than the last day of the month following
the month of the initial monitoring.

r r• TOBEEL0REED NEwWNG
wMr�8Y
k idden u THE NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
i,
SUBJECT: A public heannB has tieen stlledukd tmcernirg the Tw'WPsetl renewal and issuance of
YMS the fdlawing NODES Permits:
Permit number NC N21962 to CIT GO PehoN Mn Corpora ran lot fie Paw Grad, Terminal located In
6Lgtlolle, N.C. Charlene (Mecklenburg County) (.(Me dirolon,e of slafinwater into an unnamed arbitrary 11 Gum
AFF1A4VIT0FPUBLIl Branch.
• Permit number NC0022187 to Motive Entemrite, to, Me Paw Greek Terminal located In Chadshe
NOR'RECAROLINA IMebNlerWug CWny)for Me discharge olsMrmwaler and remeSMM grmandansWr into an unnamed
MECKI&NBUROCOUNTY 4ib41ary to Gum Braorn,
Setae-bendeniyrW,eNoluyl ' Pi mkt number NCW32891 to Philips Pipa line Company In Me Catalano Terminal lmlM in
Nigh Carely, duly mrmmiumu, Charlotte (Mecklenburg County) for Me distlrogle of smarwat,r into an unnamed mdUMry, to Gum
hwmaAmirdNroMs. PasmnillY Branch.
Shelby J. Cum 'Penal number NCN74705 to William Term tens ldddmgs;LP forme ChadolMoSoulhern Fadlities
Terminal located w Charbtle (Macklentiurg'Founy) for Me discharge of storm orter into an unnamed
TEhpeH W TME9, a oev tfoutary to Paw Creek.
mumW--sad-cppanal in M. C . Permit number NC0004I2310 Valero Managing B SUPPIY Company for Me Valero Marketing &
and5latrmMpdape ilaulhaacz dlSupply Faufty ouated in Cathode (Mecklenburg Carry) for me desharg, of stpmweler into an
alaremeeq ¢stow rwriee a oNC I, unn"d Iribulary to Paw Creek.
NOTICE OF PUBLIC ! -Permit nmroer NCOo05]]t fo hansMmtapne Terminal'rrg.Inc4rMe0hanogePawCreeNTemli-
TO BE HELD By
THE hat lit located M Chanute, (Mecklenburg CaunM for the dud ligne of stolmwaran into an unnamed
hlbutary to Paw Creek.
ENICTRONMENTAL MANI-P¢rmil number NCO021971to TransMonbigneTmmnaling.lnc.6rmeChadohelPawCreekTarmi-
nal 112 bcand M Craning, (Mecklemarg County fair Me discharge of sti m onter into an unnamed
tributary to Paw Creek.
Permit aunt et NCO031038 to Cdenul "(Pekoe Company fame Charade Delivery Faulty located
Werrgpafwh'vL's Y4e8edhvaa in Chagrin. (MR*knt., County) for Me diaa rarge Of stamwater Fb an Mra wed tributary W Gum
lenbru;11116r8on mvfaltawio5 de BmnrA.
Maa'eh 16, 2001 -Permit number NC0046213 to Marathon Ashland Petroleum, LLC for the Mdmmgn Ashland' Petro
Pon hi l ry located In Gh flOtle (Mecklenburg Covey) for MedisiJurge of slamwater into an on.mdmLLSW lid newapapurmwmd named Malian, W long Creek. T I
w legal rvadremere was pubinhi Permit number N00045531 to Crown Central Petroleum Company far Me Paw GeeN T.Me l
rveryochpoberatim,armmpaper leaned in Paw Creek( Mecklenburg Coontyy at the discharge of zlumrhvater lnb an unnamed tributary
and quapB¢Yiom of Section 1-597. IO Gum Smash.
fik"Mokiieawar-lung( i—la -Permit nuorber NCON6892 to Motive Enbrmunt.LLC for Me Chaden, Temhinai located in Paw
ern Lfp]afdn Oenad Sldmea r Creek (Meck1¢npurg County) for the discharge al ormanwaler aW remotlialed groundwaler to an
The 16th "yor M. unnamed tributary, to Long Creek.
�/"'ate"
Permitn ninrNCo004939 toE oa Mobil Refining 8 Sunay Company for M, Charlotte Tern l
(Shgmd) Z_; /"A C l ': te" Charlene lie (Mecklenburg C a y)1 thedischarge of alomswm(¢r and mmedialed gmundwa-
��"A t m a coed mm.M to Lang Creek
Swommndaobaurib db d Pe It umberNC0005105 bYWe ins Term al IkMlrgs,LP. lithe P,ns a TemiaMNotal¢d
PawC ek(Medl npprg Cou y)lm dsMarge of stamwataba unwmed ltM tan, lD Lonp
1fibR daY of March 20 Creek.
� of PatsrtalenoVa�PUfamGoLdM ehda ppl eel nlrewalollhef NPDcS pemYt lO M disearge
go"adwalm into Wahl m the Catawba Rive Kash . On me
N tarY Wpl basis ofp dnf ry tan, rev w tl ppl'dad of Article 21 of Chaderr 143, General SfaWles Ol North
God na-ad OBKY lawful standards and regulations, Me Norm boa Envlronment Maoagmrmnt
My Cumumlm R"plm 7/7 �ominis on prryoses lD issue NPOES permit la eadr Mullty subkec a Sued, "loans limitations
6 aim lcandill The groan d Me Division&Water Ouagy corsuanl to NCGS 143-215.1 h,X3)
and ReW blions 15 NCAC 2H, Se Xorr ol00 has delenhphed Math isire Me pudic Internet Mal a m seing
be held lO otherm all pertinent Page sommenl On wfgmer P issue, mo ily, a deny Me pennil.
PROCEDURE: The hearing Mll be PP,,vclN In Me ltlbnirg mamr
1. The Owhion of Wdta Guany, win present an nllaaafcra dfhe Nor, Csiali or EnWonmenl
Management Can routs.'s pemmtlng gro®•)ure.
2. The appliont may make an explanation of Me 20100 for wlr a earn perrnll is remand.
3. Purd COg MCpmyma he
p w.h, data aM tMer=ting. Pn may sd curettes in akwg
poor to a during Me meeerg or may be presented or"a0Y al tam rreebg. Persons dgsinrg to speak w,ll
indiGl<Mis totem alma limn Mrmnrr�nnn ar x,en..� � .�. e___. ..
may 9e"moreas me asrxeem d MCMee,, often, Oral neonhUda, that
emceed three minutes should be a arripa o by tare, wi,lopies, w,P, we W lad with Diosbn
1LdR at Me brow dclonabon.
—_. 4. Gross eoaninaeon of -
--- Oil ma k pagans presen5rg IestimonY will MI be, allowed; however, Me heaMg
5. y aannanns1 by, drad a l -
WTheM "9recorAmay be gonad at Me'arch condtanrrhapnq.
WHEN. AmlCmwI rma My*Jor
WHERE: Fouithe'-en, d 14 Gmemment CenW
600 East Foiiym Street CHl4 -
INFORMATION: A ropy M Me draft NPOES panmks)antla map lh--a )tlw Iea6m done diedargelsl
are evadable by-watling a ruling.
Ms. Chnsee Jackscn
NC Division M Wafer OualllyrNPDES Unit
1617 Mail Sarri. Center
Raleigh, North Carolina 2]6g9-161] -
Telephone mother (919) 733 Wag, extension 531
To, appli-whow and o0herinlama8anare on ga at Me Oiwsimdf Wale(Qhaliy, 512 Nome Salisbury
Sahel. Room 925 aline Archdale BUdoing in Raleigh, NCrM Carding and al the Orvl12 W Mooresville
Regional OMw (919 NwM Main Sheaf to Mop,,ke, N o They maybe hsspeded daring npm01 s,"M
M1Ours. Copies of Me Inlarmafrgn on file are availaoffloc
be upog iayam, and payment of the costs CI
repmOucuon. All such Ormmenls and IOMOsto regarding this mafte, shduM make reference to Me
pehmlt number($)&fed above,
95Q64 Mai 16. _.

MEMORANDUM
TO:
FROM:
PREPARED BY:
SUBJECT:
DIVISION OF WATER QUALITY
April 5, 2001
Dave Goodrich
D. Rex Gleason
Richard BridgemanWj�3
Draft Permits for Paw Creek Facilities
Following is a discussion of the draft permits:
N
am
0UJ
Q
o
�
� N
Cl-
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 permit includes a monthly monitoring requirement and an effluent limit;
Part I, Section A(1) of the permit and the Fact Sheet indicate a monthly monitoring -only
requirement. The permit and Fact Sheet appear to be correct; monthly monitoring is.
being required because of the near potential for a stream standard violation. The other
exception is Motiva Enterprises, LLC (NC0022187); monthly monitoring is being
required because none of the previously required monitoring has been conducted.
Philips Pipe Line Company (NC0032891) — Phenol limit in the other permits is expressed
in mg/L. In the Philips permit, it is expressed in ug/L.
ExxonMobil Refining and Supply (NC0004839) — Benzene limit is indicated to be 1.2
ug/L; should it not be 1.19 ug/L?

Dave Goodrich
Page Three
April 5, 2001
Phenol limit development.
The cover letters for four of the six permits with a Phenol limit discuss development of
the limit. In the cover letter, the water quality standard for phenol is indicated to be 1
mg/L; it is actually 1 ug/L for WS waters. The writer is not familiar with the 2001 SOP
used to develop limits for phenol, but considering the fact that five of the six facilities
discharge to streams having a 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 <l, 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.
Motive 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. v
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 Outfa11002 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:
RECEIVED
%%Tmrw is mrgrm. ON
APR � U 20?1
*&0iWJ ar9e peawtow
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 stormwater 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
Willian.s Terminals Holdings, L.P. - Permit # NCO074705
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 r///
Outfall 001-
The daily maximum permit limit for benzene is listed as 1.2µg/l. The North Carolina
water quality standard for WS-IV waters is 1.191cg/l.
Marathon Ashland Petroleum, LLC - Permit # NCO046213
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 71.4µg/l and
toluene concentration is less than 1 lµg/l." Since the receiving stream is a class WS-IV
water, the benzene limit should be 1.19µg/1.
Colonial Pipeline Company - Permit # NCO031038
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
entral 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.

4
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,
i
Rus ozzelle
Water Quality Program Manager
cc: Teresa Rodriguez - DWQ
Natalie Sierra - DWQ
Derrick Harris - MCDEP

13
Sent By: ; .919 821 0337; May-2-01 16:32; Page 2/3
%IUL E1R If. wM- MMFEWOON
fps Aar
May 2, 2001
NORTH CAROL-7-INA
PETROLEUM
COUNCIL
A Olublan 4 the AWrimn POWe1Lli't Institute
SUITE 2850 • 150 FA1i=VnM S7 . MAIL.
I AM011. NC 276O i
019JEUSX" • MC GI u/821- 37
Mr. Rick Sliver
Water Quality Regional Supervisor
Division of Water Quality
NC DENR
127 Cardinal Drive Exit.
Wilmington, NC 29405-3845
Rc: NPDES Permit Renewals
Paw Creek 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 major fuel suppliers -- is committed to insure that the
opportunity for public: hearings and comment is an integral part of government decision -making.
So we simultaneously praise the process that allows us to submit this statmnent for the record,
while we point with alarm to the proposed MTBE limit of 11-6 ug/L that has been included in the
draft permits without a single hearing or any official review by a 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 MTEE. Further, we were advised that the
proposed MTBE limit has not been endorsed by the Environmental Management Commission --
has not been debated by those publicly appointed members - has not been the subject 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 ittempoM groundwater standard of 70 ppb. but also to waffinn'the value of
public hearings by calling for a permanent ruiemaking process to tighten the MT13E groundwater
WMIAW4L So M me on W"Sk t1, WMASS A 00 that vosaL we are now confronted with

Sent By: ; 919 821 0337; [day-2-01 16:32; Page 3/3'
Mr. Rick Shiver
May 2, 7001
Page 2
draft NPDES permits that attempt to install an MTBE limit that is at best controversial and at
worst a circumvention of the EMC.
It is my understanding that MTBE was not an issue for the Department in the NPDES permits
issued five 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 bave occurred. A few advocates within the
Department who sounded the alarm so vigorously in statements to the EMC in support of an
MTBE groundwater standard of 70 ppb have now changed their minds! What heal been a
certainty one month was abandoned the next in favor of a now calculation — and a new limit
level. So, if public health considerations are truly moving this fast, if numbers are hastily
abandoned and recalculated, if the science is in such a state of flux, then our commitment to
reasoned public input is all the 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 ruiemaking process may be appropriate for inclusion in the terminals' NPDES
permits. Tacking that, however, the Council believes the MTBE limits contained in the draft
permits should be
Importantly, the Council's members with facilities in Charlotte are willing to help the
Deput meet collect MTBE data by monitoring for it on a periodic basis. But the proposed
monthly monitoring requirement is excessive. We are confident that scam -annual monitoring by
each of the terminals will providc the needed represcntative data to form the basis for future
decision -making.
Sincerely,
�t1 • rJ�'p`-'
William H. Wentherspoon
-- wHW/jm - --- --
c: Ms. Natalie Sierra

MAY-02-2001 18:04 WILLIAMS ENERGY GROUP P.01/02
WHIZ 6611147.
VIA FACSI 4UM 919f7.33-0719 ENERGY SERVICES
1717 South Bouldu Avenue
PO. Box 21628
May 2, 2001 Tulsa, Oklahoma 74121.1629
Ms. Natalie V. Siena
NCDfiNR— DWQ — NPDES Unit
1621 Mail Service Center
Raleigh. NC 27699-1617
Re; Draft NPDES Permit NCO074705
Williams Terminals Holdings, L. P 's Charlotte southern Facilities Terminal
7145 Old Mount Holly Road
Mecklenburg County
Dear Ms. Sierra:
in response to subject draft NPDES permit, Williams Terminals Holdings, L. P. ('Williams) has the
following comments relative to information listed on the Fact Sheet:
1. Under "Facility Information", it is noted that the correct name of the applicant has an "Cat the end of
the word `Teaninal", i.o., Williams Terminals Holdings, L. P.
2. Also under "Facility Information", it is noted that hydrostatic test water should be added at "Type of
waste".
3. Under "Background", it is noted that "Energy Ventures" should be stricken after the word "Conoco".
4_ Also cinder "Background", it is noted that the Iasi sentence should read "This water then flows into the
secondary containment area (where it combine% with sta mwater). and is released as needed."
Relative to the proposed permit itself, Williams has the following additional comments:
I. Benzene, toluene, cthylbcnzene and xylanc have boon moammil scyni-annually in accordance with the
cunt NPD]GS permit, and there have been no deteetions.
2. Naphthalene has been measured semi-annually in accordance with the current NPDES permit, and
there have been no detections.
3. MTBE was measured in the last semi-annual EPA Method 624 nun (September 2000). with no
detection.
4. Phenol fins been measured semi-annually in accordance with the current NPDES permit, and there
have been no detections. The inclusion of phenol was not nzntioned in your cover letter or the
"Summary of Proposed Changes" on the Fact Sheet, but it is on the "Effluent Limitations and
Monitoring Requirements" page within the draft permit.
Given that the above -listed parameters have been measured semi-annually since the issuance of the current
NPDES permit (with the exception of MTBE which was only recently added to the EPA Method 624 run)
and that there have been no detections, Williams sees no clear reason for the draft requirement for monthly
analyses at its Charlotte Southern Facilities Terminal. Williams understands that the Department may have
concern relative to these parameters and tho potontial for their detection at bulk petroleum facilities.
However, at Williams' Charlotte Southern Facilities Tertninal, there have been no detections. Williams
believes that this fact is directly attributable io the exemplary manner in which the terminal is maintained.
The results of this maintenance regime are readily observable upon inspection of the terminal, and has
fmquontly drawn favorable comment from Departmental personacl, most recently on the afternoon of April
19. 2001 prior to an evening Paw Creek public hearing.

• MAY-02-2001 18:05 WILLIAMS ENERGY GROUP P.02/02
in closing, Williams is in agreement with the limit placed on oil and grease, the continuation of quarterly
turbidity monitoring, and the inclusion of pH monitoring. However, Williams continues to believe that
requiring monthly (versus the current semi-annual) =nitoring (at an additional annual cost of several
thousand dollars) for the BTEX parameters, naphthalene, phenol and MTBE is unnecessary, and therefore
respectfully requests that the D*partment reconsider this issue. Williams believes continuation of current
semi-annual monitoring of these parameters is more appropriate.
If there are any questions relative to this transmittal, please call. I can be reached at 918/574-8420.
Sincar+�ly,
teve W. Mom - REM, C 04M
Sr. Environmental Specialist
1!
c1050201
r: Mark Bowen
FiWCharloue SQFAC/Water Mgmt
TOTAL P.02

SURFACE WATER :QUALITY STANDARDS OR CRITERIA FOR PETROLEUM -RELATED CONTAMINANTS
i
a
CONTAMINANT
`
i CAS #
"C" & "B" WATERS
(ug/l unless noted
otherwise)
11V11S-I" - "WS-V"
WATERS
,
WATERS (ug/I unless
noted otherwise)
SOURCE OF STANDARD
OR CRITERIA
BENZENE
71-43-2
71.4
1.19
71.4
15A NCAC 2B .0211-.0222
n-BUTYL BENZENE
! 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
51
470
EPA 4/22/99
ETHYL BENZENE
100-41-4
383
524
130
ECOTOX 1/01
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 2B .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 213.0208.
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])

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/l monthly average. A daily maximum limit of 45 mg/L is
recommended as a general indicator of stormwater quality. A daily maximum compliance period is given to
reflect the sporadic nature of these discharges. Should TSS monitoring data indicate any substantial
problems, the Regional Office or county may elect to enforce the instream standard for turbidity.
D. Oil and Grease
Monitor monthly - No Limit
Monitoring Footnote: Where possible, the grab sample for oil and grease should be skimmed from
the water surface of a quiescent (calm water) zone.
Historically, oil and grease has not been a significant problem in stormwater discharges at oil terminal
facilities. However, like TSS, oil and grease is a good general indicator of the quality of a stormwater
coming from a site. Where possible, oil and grease samples should be skimmed from the surface of a
quiescent zone closest to the discharge.
E. BTEX
Monitor monthly — No Limit
Benzene, toluene, ethylbenzene and xylene are toxicants commonly found in petroleum. The previous
permitting strategy for the oil terminals required the EPA 624/625 scan, which, among other contaminants
of concern (see Part II), detects BTEX compounds. A review of the discharge monitoring report data from
the previous permitting cycle indicates that these four contaminants frequently appear in stormwater from
terminal facilities. For the most part, the other volatiles and semi-volatiles detectable by the EPA 624/625
Page 2 of 8
Version 7130/01

Permit Requirements for Discharges from OR & 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
Page 3 of 8
Version 7/30/01

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
III.C.)
II. 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
✓
Page 4 of 8
Version 7/30/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
Table 2. Compounds detectable by EPA Method 625
Acena hthene
DETECTEDPARAMETER IN OIL TERMINAL STORMWATER?
Acena hth lene
Anthracene
Benzo a anthracene
Benzo b fluoranthene
Benzo k fluoranthene
Benzo a ene
Benzo(ghi)perylene
BenzyI butyl phthalate
Bis 2-chloroeth I ether
Bis 2-chloroetho methane
Bis 2-eth the 1 hthalate
Bis 2-chloroiso ro 1 ether
4-Bromophenyl phenyl
ether
2-Chlorona hthalele
4-Chlorophenyl phenyl
ether
Chrysene,
Dibenzo a,h anthracene
Di-n-bu 1 hthalate
1,3-Dichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene
3, 3'-Dichlorobenzidine
Diethyl phthalate
Dimeth 1 phthaIate
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 I-4,6-dinitro henol
2-Nitrophenol
4-Nitrophenol
Pentachloro henol
Phenol
✓
2,4,6-Trichloro henol
Page 5 of 8
Version 7130/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
B. Reasonable Potential (General)
The reasonable potential procedure is a method used to determine the potential of a discharge to violate a
water quality standard for a given parameter based on existing data. If a parameter is determined to have
reasonable potential to violate a water quality standard, a limit and monthly monitoring will be required. A
parameter is determined to have reasonable potential to violate a water quality standard if a calculated
maximum predicted effluent concentration is greater than the allowable effluent concentration.
Reasonable potential is determined by performing a statistical analysis for each parameter of concern that
has either a state or federal water quality standard. For each parameter, the statistical analysis works best
with a minimum of eight to twelve data points (from DMRs) although the more data points used, the more
accurate the analysis. The statistical analysis allows one to calculate a maximum predicted effluent
concentration based on the existing data set. A step-by-step procedure for determining whether or not a
parameter should be limited based on reasonable potential determination follows:
STEP
1. Determine the number of sample points (n)
2. Determine highest value from data set. Best professional judgment should be used by the reviewer so
as not to use an outlier. Since an outlier will not be determined statistically, maximum values should
rarely be discarded in this analysis.
3. Determine the coefficient of variation (CV = STD DEV/MEAN)
4. Determine the appropriate multiplication factor to be used by comparing the number of samples versus
the co -efficient of variation (see Table 3-1)
5. Multiply the highest value from the data set (Step 2) by the multiplication factor determined in step 4 to
obtain the maximum predicted effluent concentration.
6. Compare the value from Step 5 (the maximum predicted effluent concentration) with the allowable
effluent concentration, which is based on instream dilution and the corresponding water quality
standard. EPA recommends that permitting authorities find reasonable potential when the maximum
predicted effluent concentration is greater than the allowable effluent concentration.
A spreadsheet has been developed to expedite this analysis. It is titled "Toxicant Spreadsheet" and is
located on the NPDES server. The spreadsheet requires the input of the facility name and permit number,
the waste flow (Qw), 7Q 10 flow, pollutant name, state or federal water quality standard, and the DMR data
points with appropriate units. The spreadsheet then computes the standard deviation, mean, and
coefficient of variation for the entered data points. The coefficient of variation is then used along with n
(the number of data points entered in the spreadsheet) to determine the Multiplication Factor. This
Multiplication Factor is entered into the Toxicant Spreadsheet to calculate the maximum predicted
concentration.
If the maximum predicted effluent concentration is greater than or equal to the allowable effluent
concentration, (or in other words, if there is reasonable potential for a water quality standard violation), the
parameter should be limited (as a daily maximum) and monitored on a monthly basis. The daily maximum
limit shall be equal to the standard for that parameter multiplied by the dilution of the receiving stream
under summer 7Q 10 conditions for non -carcinogens. Average flow should be used for carcinogens and
30Q2 flow should be used for aesthetic standards.
If a facility monitors semi-annually (twice/year), 10 data points would be obtained over a five-year permit
period which is slightly more than the minimum number of data points which will accurately characterize
an effluent discharge (USEPA March 1991).
In cases where a facility requests reconsideration of a limit requirement, monthly monitoring should be
required for at least 10 months so that 10 data points can be obtained and a second reasonable potential
calculation can be conducted. If there is no reasonable potential for a water quality violation, monitoring
should be reduced (to semi-annually) .
Page 6 of 8
Version 7/30101

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/ 1. The
daily maximum limit for these facilities is therefore 1.19 multiplied by the dilution of the receiving stream
under average flow conditions (rounded to two significant digits). This limit may be excluded from the
permit only if there are sufficient data (eight sampling events) to demonstrate "no reasonable potential." If
there is no reasonable potential, there will only be a monthly monitoring requirement.
Page 7 of 8
Version 7/30/01

Permit Requirements for Discharges from Oil & Petroleum Storage Facilities
C. MTBE
Monitor monthly
MTBE special condition
Given that this compound is considered a possible carcinogen, there should be a greater effort to keep high
levels of MTBE out of water supply waters. As per the Paw Creek Hearing Officer's Report, after one year of
monthly MTBE samples have been recorded, the facility must review the MTBE data. If no MTBE has been
detected in the effluent samples, the facility may request a minor modification to the permit reducing the
frequency of MTBE monitoring. If, however, MTBE has been detected during any of the discharge events,
the Permittee must develop a plan of action to reduce the levels of MTBE entering the receiving stream.
It is anticipated that an MTBE criterion for surface waters will be established at the time of the next permit
renewal. At that time, sufficient data will be available to assess the reasonable potential for a facility to
exceed any such standard or criterion.
REFERENCES
Dodson, Roy D., January 1996. Computing Peak Flow: Which Method Is Most Rational?. Civil Engineering
News.
Kelling, Ray, (Division of Water Quality Chemistry Lab). June 1996. Conversations with P. Clark.
Kelling, Ray, (Division of Water Quality Chemistry Lab). February 2001. Conversations with N. Sierra.
Linville, Ron, (Winston-Salem Regional Office). March 1996. Telephone conversation with P. Clark.
Reid, Dianne, (Division of Water Quality - Planning Branch). June 1996. Conversations with P. Clark.
Shiver, Rick, (Wilmington Regional Office). July 2001. Findings and Recommendations for Public Hearing
Held on April 19, 2001.
USEPA. March 1991. Technical Support Document For Water Quality -Based Toxics Control. EPA/ 505/ 2-
90-001.
Page 8 of 8
Version 7/30/01

. 7
VIA FACSIMILE 919/733-0719
May 2, 2001
Ms. Natalie V. Sierra
NCDENR— DWQ —NPDES Unit
1621 Mail Service Center
Raleigh, NC 27699-1617
MAY -3 200,
DEN
Re: Draft NPDES Permit NCO074705
Williams Terminals Holdings, L. P.'s Charlotte Southern Facilities Terminal
7145 Old Mount Holly Road
Mecklenburg County
Dear Ms. Sierra:
ENERGY SERVICES
1717 South Boulder Avenue
EO. Box 21628
Tulsa, Oklahoma 74121-1628
In response to subject draft NPDES permit, Williams Terminals Holdings, L. P. (Williams) has the
following comments relative to information listed on the Fact Sheet:
1. Under "Facility Information", it is noted that the correct name of the applicant has an "s" at the end of
the word "Terminal", i.e., Williams Terminals Holdings, L. P.
2. Also under "Facility Information", it is noted that hydrostatic test water should be added at "Type of
Waste".
3. Under "Background", it is noted that "Energy Ventures" should be stricken after the word "Conoco".
4. Also under "Background", it is noted that the last sentence should read "This water then flows into the
secondary containment area (where it combines with stormwater) and is released as needed."
Relative to the proposed permit itself, Williams has the following additional comments:
1. Benzene, toluene, ethylbenzene and xylene have been measured semi-annually in accordance with the
current NPDES permit, and there have been no detections.
2. Naphthalene has been measured semi-annually in accordance with the current NPDES permit, and
there have been no detections.
3. MTBE was measured in the last semi-annual EPA Method 624 nm (September 2000), with no
detection.
4. Phenol has been measured semi-annually in accordance with the current NPDES permit, and there
have been no detections. The inclusion of phenol was not mentioned in your cover letter or the
"Summary of Proposed Changes" on the Fact Sheet, but it is on the "Effluent Limitations and
Monitoring Requirements" page within the draft permit.
Given that the above -listed parameters have been measured semi-annually since the issuance of the current
NPDES permit (with the exception of MTBE which was only recently added to the EPA Method 624 run)
and that there have been no detections, Williams sees no clear reason for the draft requirement for monthly
analyses at its Charlotte Southern Facilities Terminal. Williams understands that the Department may have
concern relative to these parameters and the potential for their detection at bulk petroleum facilities.
However, at Williams' Charlotte Southern Facilities Terminal, there have been no detections. Williams
believes that this fact is directly attributable to the exemplary manner in which the terminal is maintained.
The results of this maintenance regime are readily observable upon inspection of the terminal, and has
frequently drawn favorable comment from Departmental personnel, most recently on the afternoon of April
19, 2001 prior to an evening Paw Creek public hearing.

In closing, Williams is in agreement with the limit placed on oil and grease, the continuation of quarterly
turbidity monitoring, and the inclusion of pH monitoring. However, Williams continues to believe that
requiring monthly (versus the current semi-annual) monitoring (at an additional annual cost of several
thousand dollars) for the BTEX parameters, naphthalene, phenol and MTBE is unnecessary, and therefore
respectfully requests that the Department reconsider this issue. Williams believes continuation of current
semi-annual monitoring of these parameters is more appropriate.
If there are any questions relative to this transmittal, please call. I can be reached at 918/574-8420.
Sincerely,
jteveW. Monn - REM, CHMM
Sr. Environmental Specialist
//
6050201
c: Mark Bowen
File/Charlotte SOFAC/Water Mgmt

DENR/DWQ
FACT SHEET FOR NPDES PERAUT DEVELOPMENT
NPDES No. NC0074705
Facility Information
pp scan
aci tyName:
NCO0747U5 — Williams
erminal Holdings, L.P. — Paw Creek
ApplicantAddress:
Mr. Steve onn; One Williams
enter; u sa, Ok
FacilityAddress:Mount
Holly Road;
Charlotte, NU
Permitted
ow
Not limited
ype of Waste:
Stormwater, loading rack
water
Facility/PermitStatus:
cave; Renewal
County:
Mecklenburg
BACKGROUND
Formerly owned by Conoco Energy Ventures, this facility changed ownership and name to become
Williams Energy Ventures in October 1996. This February, it changed names once again to become Williams
Terminals Holdings, L.P. Effluent water discharged from the outfall consists of runoff from the loading rack,
stormwater from the secondary containment areas (around the individual tanks) and discharge water following
hydrostatic testing. Loading rack water is run through an oil water separator, a carbon filter and a holding
tank. This water then flows into a detention pond (where it combines with stormwater) and is released as
needed.
FILE REVIEW
Correspondence
Correspondence files from 1997-2000 were reviewed. During this time period, the Mecklenburg
County Department of Environmental Protection (MCDEP) performed our inspections. The facility received
a satisfactory rating on all of these inspections.
Grab samples taken during the MCDEP compliance inspections indicate low levels of total suspended
solids (TSS) and non -detects for the volatiles and semi-volatiles detectable by the EPA 624/625 scan.
The facility received one notice of violation (NOV) in December 1997 for non -submittal of July 1997
DMRs.
DMR Review:
DMRs were reviewed from October 1996 through January 2001. Discharges from 001 are sporadic in
nature; the mean flow for those months in which there was discharge was 0.006 MGD. The maximum flow
(used below in the reasonable potential calculations) was 0.015 MGD. Total' suspended solids during this time
averased 8.1 mg/L with a maximum of 31.4 mg/L. The average oil and grease concentration was 9.1 mg/L
with a maximum concentration of 200.0 mg/L.
The twice -annual EPA 624/625 scan revealed non -detects for nearly all of the semi-volatiles and
vo]atiles tested. The May 1999 sample had several detects: vinyl chloride, chloroethane,
trichlorofluoromethane, methylene chloride, and bromomethane. Three of these detects — those for vinyl
chloride, chloroethane, and trichlorofluoromethane -were apparently due to laboratory contamination (the
method blanks showed detects) or error. The facility has passed its acute toxicity test since 1997.
Fad Sheet
NPDES NC0074705
Renewal
Page 1

Since March 1999, the facility has been required to sample for turbidity quarterlyas per an EPA
ce th
directive. They have sampled during each discharge event sine requirement was instilled - the average
turbidity value in the past year and a half is 4.2 NTU and the maximum was 9.0 NTU.
Reasonable Potential Analysis:
Most of the volatiles and semi-volatiles detected do not have associated water quality based limits;
reasonable potential was not run for these contaminants. Methylene chloride and vinyl chloride do have EPA
standards -1600 ug/L and 525 ug/L, respectively. The detects of these two compounds were well below the
national standard, however, and so reasonable potential was not performed. It should be noted, however, that
the 624/625 scan will be reassigned to this permit as a result of the detects.
Reasonable potential was performed for oil and grease, due to the detect of 200 mg/L. The analysis
indicated a potential to violate the standard of 45 mg/L.
PERMITTING STRATEGY
The permitting strategy for this and all oil terminals in the state is based upon a 2001 NPDES
document entitled, "Permit Requirements for Discharges from Oil and Petroleum Storage Facilities." This
document is based upon a 1996 SOP and has been updated after a data review and internal discussions. It
delineates monitoring frequencies and permitting limits for contaminants commonly found at these sites.
Below, it is referred to as the "2001 SOP."
Waste Load Allocation (WLA).
The last waste load allocation was performed in 1993, when the facility was then under different
ownership. This WLA recommends BTEX and lead monitoring and TSS, turbidity, and oil and grease 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. Since the DMRs indicated several detects in the reporting of EPA
Methods 624/625, this requirement will be continue to be a part of the permit as per Part II.A. of the SOP.
Naphthalene and MTBE monthly monitoring will be added to the permit as per Parts I.F and I.I of the 2001
SOP. As per parts I.G. and I.H. of the 2001 SOP, there can be no direct discharge of tanks solids, tank bottom
water or the rag layer, and no direct discharge of hydrostatic test water if concentrations of benzene and/or
toluene exceed the water quality standard. Part II.C. lists a requirement specific to the Paw Creek terminals -
quarterly turbidity monitoring as mandated by the EPA. After performing a RPA for oil and grease, a limit of
45.0 mg/L will be added to this permit.
A note should 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. - --- -- - --
j
SUMMARY OF PROPOSED CHANGES N 0 W)- _ -
Addition o naphthalene monitoring I `i
Addition of MTBE monitoring U i MAY - 2 2001
Addition of quarterly turbidity monitoring
Addition of oil and grease limit
Addition of monthly BTEX monitoring OENR - WATER ', ALM
POINT SOURCE mcr,!iCH
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
DraftPermit to PublicNotice: March 14, 2001
Permit Scheduled to Issue: April 27, 2001
NPDES DIVISION CONTACT
If you ave questions regar mg any of the above information or on the attached permit, please contact Natalie
Sierra at [phone] ext. 551.
DATE:
Fad Sheet
NPDES NCO074705
Renewal
Page 2

I REGIONAL OFFICE COMMENTS
NA
jVjFpS S Ac f vAc LL y
o C .A T( Cf+7 !� i T v � l
DATE: S — /--
SUPERVISOR: // `''� /�I DATE:
Fact Sheet
NPDES NCO074705
Renewal
Page 3

n�),r-
SOC PRIORITY PROJECT: Yes No X
To: Permits and Engineering Unit
Water Quality Section
Attention: Valery Stephens
Date: April 17, 2001
NPDES STAFF REPORT AND RECOMMENDATION
County: Mecklenburg
=_
MRO No.: 01-38
Permit No. NCO074705
PART I - GENERAL INFORMATION
30
1. Facility and Address: Williams Energy Ventures
I a
7145 Old Mount Holly Road
Q L
Charlotte, North Carolina 28130
i
I�
2. Date of Investigation: 04-03-96
3. Report Prepared By: Samar Bou-Ghazale, Env. Engineer I
4. Persons Contacted and Telephone Number: Mr. Mike Harris, Lead Operator; (704) 399-
8457.
5. Directions to Site: From the junction of I-85 and Highway 27 in Charlotte, travel west on
Highway 27 (Freedom Drive) approximately three (3) miles to Old Mt. Holly Road. Turn
right onto Old Mt. Holly Road and travel approximately 0.75 mile to facility located on the
right (south) side of the road.
6. Discharge Point(s). List for all discharge points:
Latitude: 35' 16' 42" Longitude: 80' 55' 30"
Attach a U.S.G.S. map extract and indicate treatment facility site and discharge point on
map.
USGS Quad No.: F 15 SW USGS Quad Name: Mountain Island Lake
Site size and expansion are consistent with application?
Yes X No_ If No, explain:

8. Topography (relationship to flood plain included): Sloping south toward an unnamed
tributary to Paw Creek at the rate of 3 to 5%. The site is not located in a flood plain.
9. Location of nearest dwelling: None within 1000 feet of the discharge point.
10. Receiving stream or affected surface waters: Unnamed tributary to Paw Creek.
a. Classification: C
b. River Basin and Subbasin No.: Catawba River Basin; 030834
C. Describe receiving stream features and pertinent downstream uses: The receiving
stream is a narrow and shallow drainage ditch. General C classification uses
downstream.
PART II - DESCRIPTION OF DISCHARGE AND TREATMENT WORKS
1. Type of wastewater to be permitted:
0% Domestic
100% Industrial
a. Volume of Wastewater: The wastewater is generated from storm water that falls on
the entire site.
b. What is the current permitted capacity of the wastewater treatment facility? N/A.
C. Actual treatment capacity of the current facility (current design capacity)? N/A.
d. Date(s) and construction activities allowed by previous Authorizations to Construct
issued in the previous two years: N/A
e. Please provide a description of existing or substantially constructed wastewater
treatment facilities: Wastewater from the loading rack is directed to an oil water
separator, a carbon filter and a holding tank. Storm water run-off from the tank
area discharges to a containment area located on the south side of the property.
f. Please provide a description of proposed wastewater treatment facilities: N/A
g. Possible toxic impacts to surface waters: Due to nature of the wastewater there
could be some toxicity concern.
h. Pretreatment Program (POTWs only): N/A.
NPDES Permit Staff Report
Page 2

2. Residuals handling and utilization/disposal scheme: Sludge accumulates in the oil/water
separator at a rate such that cleaning only needs to be done every five to ten years. When
cleaning is done the company contracts a licensed waste disposal facility for removal and
disposal. The tank bottom water is handled by Shamrock Environmental, Tel# [phone]-
1098.
3. Treatment plant classification (attach completed rating sheet): Class I
4. SIC Code(s): 5171
Primary: 39
Main Treatment Unit Code: 53000
PART III - OTHER PERTINENT INFORMATION
1. Is this facility being constructed with Construction Grant Funds or are any public monies
involved (municipals only)? N/A.
2. Special monitoring or limitations (including toxicity) requests: N/A.
3. Important SOC, JOC or Compliance Schedule dates: (please indicate) N/A.
4. Alternative Analysis Evaluation: Has the facility evaluated all of the non -discharge
options available. Please provide regional perspective for each option evaluated.
Spray irrigation: N/A
Connection to regional Sewer System: N/A
Discharge to an infiltration gallery:N/A
5. Air Quality and/or Groundwater concerns or hazardous material utilized at this facility that
may impact water quality, air quality or groundwater? Contaminated groundwater already
exists at the site. Air Quality Permit for this facility is not required by Mecklenburg
County.
6. Other Special Items: A question was raised by Richard Bridgmen of this Office during
the review of the Draft Permit regarding the existence of a retention pond on this site.
During the investigation it was noted that a containment area is provided at the lower end
of this site and not a retention pond.
NPDES Permit Staff Report
Page 3

PART IV - EVALUATION AND RECOMMENDATIONS
Williams Energy is requesting an NPDES Permit renewal for the discharge of treated
wastewater. The wastewater is generated from an oil water separator and stormwater runoff.
It is recommended that the NPDES Permit be renewed.
Signature of FYe� Preparer Date
Water Quality Zegional Supervisor Date
NPDES Permit Staff Report
Page 4

March 9, 2001
North Carolina Department of Environment and Natural Resources
Division of Water Quality-NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
RE: Notification of Change to Permit Holder
NPDES Permit No. NCO074705
Williams Energy Ventures' Charlotte SOFAC Terminal
WH $
ENERGYSERVICES
1717 South Boulder Avenue
P.O. Box 21628
Tulsa, Oklahoma 74121-1628
Williams Energy Ventures, Inc., a Delaware corporation ("WEV Inc."), owns and operates a bulk
petroleum terminal located at 7145 Old Mt Holly Road, Charlotte, NC 28130. The facility
operates in accordance with NPDES Permit No. NC0074705. WEV Inc. is converting itself from
a Delaware corporation to a Delaware limited partnership that will be known as Williams
Terminals Holdings, L.P., as allowed by Delaware general corporate law Section 266.
Under Delaware law, the conversion of WEV Inc. to Williams Terminals Holdings, L.P. does not
interrupt the existence of the legal "person" of WEV Inc. Rather, such legal "person" will continue
to exist in Williams Terminals Holdings, L.P. upon the conversion in the same fashion that a legal
entity that changes its name continues to exist as the same legal "person" under its new name.
The only change at the facility will be the name of the permitee; the operations and personnel will
not change. Accordingly, WEV Inc. requests that the above -referenced permit be amended to
reflect the conversion of WEV Inc. to Williams Terminals Holdings, L.P. If such conversion is
deemed to constitute a transfer of the above -referenced permit from WEV to Williams Terminals
Holdings L.P., then such a transfer is hereby requested.
As noted above, personnel will not change and therefore my signature below serves for both WEV
Inc. and Williams Terminals Holdings, L.P. The effective date of transfer was February 9, 2001.
Please find enclosed the completed NPDES Permit Name/Ownership Change Form. My
understanding is that this form and letter fulfills the notification requirement for transferring the
above -referenced permit, if required. Please call Stacy Kisler at 918/574-8022 or Steve Monn at
918/574-8420 if you need anything further.
Sincerely,-- L--- _
i
/1 r
- - _
Rob Hawksworth MAR 1 4 2001
Director - Safety, Environmental and Training Services
Enclosure
cc: Charlotte SOFAC Water File
Water File/Charlotte SOFAC Terminal
S:\IndependentTerminals\MLPtransfer\CharlotteSOFAC\NC-CharSOFACW ater.do,

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Bill Holman, Secretary
Kerr T. Stevens, Director
NC ENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
PERMIT NAME/OWNERSHIP CHANGE FORM
CURRENT PERMIT INFORMATION: n
Permit Number: NC00_j/J/ (! 0/ 6
1. Permit holder's name:
2. Permit's signing official's name and title:
V?_n4tjftS'ckw-ro
(Verson iegaiiy responsible for permit)
-0it, &irommWiT
mi.im 3&Ulto
(Title)
3. Mailing address: ?o bn)(3qg� City: T
ULCL
State: Zip Code: 1 Phone: ( 9 ( 8 ) 6 7T' ES ( 3
,
E-mail address: lob• A&Wkawrfh(?��rJl�l lr
(OAS-- (&v
NEW OWNER/NAME INFORMATION:
1. This request for a name change is a result of:
a. Change in ownership of property/company
_)Lb. Name change only
c. Other (please explain):
2. New owner's name (name to be put on permit):
U, Ll ianj TtrMlylos 1A % —
3. New owner's or signing official's name and title: 4bfhA,&kU0r*
(Person legally responsible for permit)
� � Ser�cer
(Title)
4. Mailing address: po p)(pACity: TUSa.
Stater Zip Code: q_10 I Phone: ( q t S ) 574 -gS Eg
IC E-mail address: Ob , �� LoOMI P Willi CW_V Cf0/Y)
1617 Mail Service Center, Raleigh, North Carolina 27699-1617 Telephone (919) 733ZO83 FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled / 10% post -consumer paper

PERMIT NAME / OWNERSHIP CHANGE FORM
THIS APPLICATION PACKAGE WILL NOT BE ACCEPTED BY THE DIVISION OF WATER QUALITY UNLESS
ALL OF THE APPLICABLE ITEMS LISTED BELOW ARE INCLUDED WITH THE SUBMITTAL.
REQUIRED ITEMS:
1. This completed application form
2. Legal documentation of the transfer of ownership (such as a contract, deed, articles of
incorporation)
For changes of ownership, this form must be completed and signed by both the current permit
holder and the new owner of the facility.
For name change only, the current permit holder must complete and sign the Applicant's
Certification.
Current Permittee's Certification:
I, :fob f1'Clw-Swori- 1 , attest that this application for
name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: !/Z,� 4 . Date: d c<<
Applicant's Certification:
I, {doh TTILW -SWur-ti \ , attest that this application for a
name/ownership change has been reviewed and is accurate and complete to the best of my
knowledge. I understand that if all required parts of this application are not completed and that
if all required supporting information and attachments are not included, this application
package will be returned as incomplete.
Signature: I& t`^ • 1 Date:
THE COMPLETED APPLICATION PACKAGE, INCLUDING ALL SUPPORTING
INFORMATION & MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDDRESS:
NC DENR / DWQ
NPDES Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Version 9-99

REASONABLE POTENTIAL
ANALYSIS
Prepared by:
Natalie Sierra, 3/5/01
Facility Name =
Williams Energy Ventures
NPDES # =
NCO074705
Qw (MGD) =
0.015
Qw (cfs) =
0.023208
7Q10s (cfs)=
0
IWC (%) =
100.00
Organism Exposure only
lWater + Organism Expos.
Frequency of Detection
Parameter
FINAL RESULTS, ug/I FINAL RESULTS, ug/l
#Samples
# Detects
Vinyl Chloride
Max. Pred Cw
13.4
Allowable Cw
525.0
2
7
1
Chloroethane
Max. Pred Cw
32.5
Allowable Cw
no limit est.
7
1
Trichlorofluoromethane
Max. Pred Cw
15.0
Allowable Cw
no limit est.
8
1
Oil and Grease
Max. Pred Cw
1188.0
Allowable Cw
45.0
0
0

■
Vinyl Chloride
hloroethane
C..._
,___Standar
,...
..
111MR-RIM-111sm..._
ig
-
�m
Modified.._
..__
�.
moon
PM
'Allowable Cw
C
MEN
C
�•
C

i
i
Parameter =
Trichlorofluoromethane
Parameter =
Oil and Grease
Standard =
pg/l
Standard =
45
mg/L
Dataset=
DMR99
Dataset=
DMR99
ModifedData
Nondetects
RESULTS
ModifledData
Nondetects
RESULTS
2.5
<5
Std Dev.
1.202
_
0.5
<1.0
Std Dev.
32.164
2.5
<5
Mean
2.925
0.5
<1.0
Mean
8.836
2.5
<5
C.V.
0.411
0.5
<1.0
C.V.
3.640
2.5
<5
Sample#
8.000
0.5
<1.0
Sample#
41.000
5.9
0.5
<1.0
2.5
<5
Mult Factor =
2.550
0.5
<1.0
Mult Factor
5.940
2.5
<5
Max. Value
5.900
pg/
0.5
<1.0
Max. Value
200.000
pg/l
2.5
<5
Max. Pred Cw
15.045
pg/
0.5
<1.0
Max. Pred ON
1188.000
pg/I
Allowable Cw
0.000
pg/
0.5
<1.0
Allowable Cvi
45.000
pg/I
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
1.75
0.6
0.5
<1.0
0.5
<1.0
0.67
0.53
1.39
0.34
2.5
<5.0
0.5
<1.0
0.5
<1.0
0.5
<1.0
2.5
<5.0
2.5
<5.0
14
2.5
<5
17
24
2.5
<5.0
2.5
<5.0
200
2.5
<5
2.5
<5
9
58
3
2.5
<5
sample#
nondetects
detects
sample#
nondetects
detects
8
7
1
411
28
13

1997 All compounds listed below detection level
1998 All compounds listed below detection level
1999 All compounds listed below detection level except vinyl chloride, chloroethane, Trichlorofluoromethane (see below)
2000 All compounds listed below detection level
Date
Compound "
3/4/97
9/25/97
5/28/98
12/14/98
5/28/99
11/11/99
04/27/00
9/29/00
Vinyl Chloride
<5
I
<5
<5
<5
5.6
<5
<5
<5
Chloroethane
<5
<5
<5
<5
8.3
<5
<5
<5
Trichlorofluoromethane
<5
<5
<5
5.9
<5
<5
<5
Detections at Pace Labs 5/28/99 (for method blanks)
Vinyi Chloride 6.1
Chloroethane 8.8
Trichlorofluoromethane 6.2
But on duplicates for 5128/99, there were then detects for vinyl chloride (5.9 ug/L), bromomethane (8.9 ug/L), chloroethane (8.4 ug/L),
trichlorofluormethane (6.0 ug/L), methylene chloride (5.2 ug/L)
QA/Qc data from lab do not indicate that the method blanks for bromomethane and methylene chloride were anything other than non -detects.
Limit for methylene chloride is 1600 ug/L - do not need to perform RPA for this parameter
There is no limitistandard for bromomethane.

r•
Mar-97
0 0
5 5
10 5
20 0
40 0
70 0
100 0
Oct-98
0 0
5 0
10 0
20 0
40 0
70 0
100 0
May-99
0 0
5 0
10 0
20 0
40 0
70 0
100 0
Apr-00
0 0
5 0
10 0
20 0
40 0
70 0
100 0

Whole Effluent Toxicity Testing Self -Monitoring Summary February 16, 2001
FACILITY REQUIREMENT
YEAR JAN
FED
MAR
APR
MAY
AM
JUL
AUG
SEP
OCT
NOV
DEC
Weyerbrurcr-Near Bern Parm chr HIS: I3%(New perm IVIVQ00)
1997 Fail
Pau
—
Pau
—
—
Pan
—
—
Prs
—
—
NC0003191J001 Begin:5/111995 FarquerlQ P/F + Jan Apr Jul Oct N=Comp:Single
19m Las,
Pau
—
Pm
—
—
Pam
—
—
Pre
—
—
County. Co. Region: WARD Sobbaim NEU08
1999 Peas
—
—
Pass
—
—
72
—
—
72
—
—
FF. 32.0 SPxW
Not) )2
—
—
36.8
—
—
72.1
—
—
72.1
—
—
7Q10:329 IWC(%yl3 ruder.
2m1
Weyerhaeuser-Plymout6(Rrnoke) Penn chr lion: 6.8%
91997 —
Pa..
—
—
Pus
—
—
Par
—
—
Fall
Pea.
NCWW68W001 Begiml/I/1997 Flequal Q P/F + Feb May Aug Nov + NonC.mp:Singla
1998 —
Pass
—
—
Pr.
—
—
Pam
—
—
Pas.
—
Comar.. Martin Region: WARD Subbrin: ROA09
INS —
Pass
—
—
Pam
—
—
>1 W
—
—
74
—
PF: 55.0 SpmW
2900 _
738
—
—
>100
—
—
Lam
-IN
—
IN
—
7Q10:1160 IWC(%)6S IJmer:
MI
Weyerhauser Pmn cW IIm:905S (Grob)
1997 —
Pau
—
—
Pr.
Pau
—
P.
—
NCWQe29hWI Begimill 1996 Frequemr..i + Feb May Aug Nmv NonComp:Single
19m —
P.
—
—
Pam
—
—
Pam
—
—
Pre
—
County. Mechlenurg ftione MRO Subbrin: 1
19% —
Pau
—
—
NR
—
—
Nat
—
—
NRM
—
PF:O.W72 SpcW
20m _
H
_.
_
H
_
—
H
_
_
H
_
7QI0: 0.0 IWC(%):IW.O (nter:
2001
IVklmv lx)xWJP-001 peordrlim:50%
1m) Pau
—
—
Pa..
--
—
Pas.
—
—
Peas
—
—
NCO021920N01 BegimVlal)O Frequency:Q Jon Apr Jul Od + NonComp:Single
19m Pass
—
--
Pass
--
—
Pas.
—
—
Pas.
—
—
County: Columbus Region: MRO Subbmim LUM59
man Pau
—
--
Pau
--
—
Pau
—
—
Pars
—
—
PF: 3.0 screw
20W Prs
—
—
Pau
--
—
Fail
a12.5
<125
a125
.12.5
17m
714.7 IWC(%):50 (tNee
2Wt
Wlldwosd Gran P. chr him: 72%
1997 —
P.
—
—
Farm
—
—
Pass
—
—
Pm
—
NC0063614/001 Begim611RI K) Frequency:Q Feb May Aug Nov + NonComp:sbrgle
INS —
Pars
—
—
Pam
—
—
Pass
—
—
Pm
—
Cown". Wake Region: no Subbrim NEU01
19% —
Pau
—
—
Pass
—
—
Pau
—
—
Poll
Fail
PF: 0.1 S,W
2CW Pm
Pass
—
—
Pass
—
—
Pau
—
—
Pre
—
7QIO:O.W IWC(%).72 Coda:
2WI
Wilkesboro WWTP Peon chr lim: 3.7%
107 —
—
Pass
—
—
Pre
—
—
Pass
—
--
Pass
NC0011717I001 Begin:5/l/1999 Fmquency: Q PIP + MmJm Sep Dec + NonComp:Single
INS —
--
Pase
—
--
Pass
—
--
Pass
—
—
Pas.
Comely: Wilke Region: WSRO Subbasin: YAD01
1999 —
--
Pea.
—
--
Pass
—
--
Pass
—
--
Pass
PF: 4.9 Special
2999 _
—
Pus
—
--
Pr.
—
--
Pass
—
—
Per
7Q10: 196 IWC(%)5.n ore-
M01
William Energy Ventura -Seim. Perm: 24hr LC50 to namit epis W(glab)
107 —
—
—
—
--
H
—
—
—
—
—
—
NOW52311/001 Begim9/lAM Flequancy:A NNComp:
19m —
—
—
—
—
.100
_
County. Jmbmlmn Region: RRO Snllbrim: NEU02
INS —
—
—
—
—
>1005q
—
—
—
—
—
—
PF: -- Special
2000 —
_
7Q10: 0.0 IWC(%):IW.O Orden
2Wt
Williams Energy Ventures Penn 24hr LC50 am mmnt apis Md(g/ab)
1997 —
—
—
>1m
—
—
—
—
—
—
—
—
NN005l85/W6 Begin:9/1/1996 Fleponry:A Noncomp:
IWO —
—
—
—
——
Counry: Mecklenburg Ragion: MRO Subbuire Cf034
1m9 —
—
—
-IN
—
—
—
—
—
--
—
_
PF: NA S"au
200 —
—
—
>100
--
—
—
—
—
--
--
—
7Q10:0.0 IWC(/s):IUU oNa:
Nor
WIIOams Energy Venmrr-Cbarlo0e Penn 24hr LC$0 am monk epos Md (gmb)
1997 —
—
Mlp
-
—
NCM74705N01 Begitg9/111996 Frequency:A NmnComp:
1m0 —
—
—
—
soul
—
—
—
—
>I00
—
—
County. Makimburg Regime: MRO Subbaain: C H34
19m —
—
—
—
>looY,
—
—
—
—
—
—
—
PF: 0 speeid
2090 —
—
—
a100
—
—
—
—
—
—
—
—
7(jui0 IWC(%):IW (har-
2001
wiiWams Energy Vg.ha Green.bam Perm 24hr LC50 se moat ape Md(gsab)
1997 _
_
_
>1m
—
—-
14CW74578/W2 Begin:dl/1996 Freamency:A N.Cmmp:
1m9 —
—
—
—
>1W
—
County: Guilron Regimm WSRO Subbrim CPFGS
190 —
—
»W
—
—
—
—
—
—
--
—
_
PF: 0.11067 Special
NX >m0
—
7QIU: 0.0 IWC(Y.):IW loads.
=1
Vllll.mrton WWFP Penn chr lien: 0.26%; ifpf2.4 chr lion 0.32%
NC0020044N01 Begim V11098 Frequrncy:Q + Mar Jog Scp Dee + NnnCaanp:Shme
Cowry: Martin Region: WARD School.: ROA09
Ple: 20 SPi
71 1170 iWC(Yr)U.26 lack.
1997 — —
1990
1999
2900
ml
Pass —
Pan —
Pan P. —
Data Nanning: f-Falluml Minnow; 4-CeriodapMis sp.; my- Mysid shrimp; ChV - Chronic va1r; P- Mortally ofnmed percens,ge, at highest concentmlion; al- Path
Reporting Notation:— � Dam not mquirmk NR-Not naught Facility AcOvity Smtma- busence, N- Newly lasued(T. construct); N- Active but Ml diacharging;
50
Pass. Prs Peres
Pr Pus Pau
— Prs — -- Later Pass — Pass
— P. — - Pass — — Prs
A. Annually; OWD- Only when diseheBing; D- Disemminuel monitoring requirement
ug=or- es. Jan, Apr, Jul, Oct NonCmmp- Current Compliance Requirement
Tax Unit; be- Bad teat
ummntuiar,onton;--ORCsigrtureneedrd

1�'
Williams Energy Ventures (Charlotte NC0074705
Discharge 009
Date
Ave. Flow
TSR
Oil & Grease
Xylenes
Turbidity
(mg/L)
(mg/L)
I(mg/L)
(NTU)
10/1 /96
0.009
0.5
<1.0
11/8/96
0.008
1
<1.0
1212/96
0.009
0.4
<1.0
1/8/97
0.003
0.8
<1.0
2/10/97
0.009
1.4
<1.0
314/97
0.007
4.1
<1.0 <10
4/14/97
0.006
0.6
<1.0
5/5/97
0.01
0.8
<1.0
6/18/97
0.007
1.6
<1.0
7/25/97
0.007
3
<1.0
9/25/97
0.015
6
<1.0 <10
10/21/97
0.007
0.8
<1.0
11 /1 /97
0.008
1.5
<1.0
1/8/98
0.003
0.01
<1.0
2/18/98
0.008
26
1.75
3/23/98
0.003
2.5
0.6
4/28/98
0.002
21
<1.0
5/28/98
0.005
26.5
<1.0 <10
6/30/98
0.003
26
0.67
7/29/98
0.01
16.9
0.53
8/11/98
0.005
27
1.39
10/5/98
0.005
24
0.34
11/16/98
0.005
<10
<5.0
12/14/98
0.007
<1.0 <10
1/7/99
0.003
6
<1.0
2/2/99
0.007
8
<1.0
3/16/99
0.003
34
<5.0
4/29/99
0.01
10
<5.0
9
5/19/99
0.003
<5
14 <10
6/16/99
0.007
4.5
<5
7/12/99
0.005
2
17
2
8/26/99
0.005
11
24
9/8/99
0.005
2.3
<5.0
10/27/99
0.003
3.8
<5.0
4.5
11 /11 /99
0.003
8
200
3/1 /00
0.003
1
<5
4.1
4/27/00
0.007
3.8
<5 <5
6/28/00
0.005
2.2
9
1.5
7/31 /00
0.006
3.8
58
9/29/00
0.004
0
3 <5
2.4
11 /30/00
0.004
<5
<5
average
0.0061
average
4.2200
max
0.015
max
9
Corrected data
Oil and Grease
(mg/L)
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
0.5
1.75
0.6
0.5
0.5
0.67
0.53
1.39
0.34
2.5
0.5
0.5
0.5
2.5
2.5
14
2.5
17
24
2.5
2.5
200
2.5
2.5
9
58
0
2.5
9.1482
200

APD->q,s -ferll
-J- 12/06t
O cck CorT pc,d
'hack c�ect;w le"c(
�—N7(D�
W /a, �KlNrS
-_ — 0lll�vE�--S
No
tfc) yam---
-- -------- ------------- -
al � r�

-�
� ,- - � l v
- � --
,eG..C�,UO'r�ii__7.�i�ryrirz-
f = -
�� 0)2�`Bt�,��o

L,j I L- L.I iaM C
7/1-7 G . E>iv yl W-b
T-0ck1441cieI�tivl�ticv�� Glw\a pct-c-hcJc,(f,�I�-
h Icy 1
G',1 -�vo.nw OIL,)
Mcpv
ho collieyu� voi r t
'Ac I LiTi S}j�
1 ��Z�lot�s L�v>r1 ow
JbOA
�� 5�1i �al✓o�o 1, �.
fo/2c�
Nov -(�r rwl-svbm,(, y Q
C" E. Z � y`1 MC D r-v
SpnsT-ACT &V
&AfA Ruh �7wiZ+ �o
Lei-P/-ti �O b
�s (oL�lc�� coo

vaNt-rn
February 21, 2001
Mr. Charles H. Weaver, Jr.
NC DENR / Water Quality / NPDES Unit
1617 Mail Service Center
Raleigh, NC 27699-1617
u`u FEB 2 3 2001
DENR - Y':TE3 011%+LiTY
POINT S0111,?r 11V_: 4
Re: NPDES Permit NC0074705 Renewal Application
Williams Terminals Holdings, L.P. Charlotte Southern Facilities Terminal
Mecklenburg County
(NC DENR's Paw Creek terminal)
Dear Mr. Weaver:
'South Boulder Avenue
Box 21628
,,Oklahoma 74121-1G28
This transmittal represents formal submittal for renewal of subject NPDES permit, since it is currently due
to expire on August 31, 2001. This submittal is being made prior to the 180-day pre -expiration submittal
requirement. To this end, attached please find a completed original application (Short Form C), and two
complete copies of this cover letter and the application form. Furthermore, enclosed please find copies of
my authorization to prepare and submit the application for renewal.
Please note (at the subject listing above) that since our last correspondence, Williams Energy Ventures, Inc.
converted itself from a corporation to a partnership named Williams Terminals Holdings, L.P. A complete
notice per NC DENR requirement will follow in the very near future. However, since formation of the
partnership occurred on February 9, 2001, this letter and the enclosed Short Form C list the applicant as
Williams Terminals Holdings, L.P.
There have been no changes at the terminal that would affect operation under the NPDES permit since
issuance of the last NPDES permit. Furthermore, the terminal generates no sludge as a result of wastewater
treatment, so there is no NPDES sludge management plan for the terminal.
Please note that the enclosed Short Form C, at #10, lists the discharge point as "outfall 001". On the
"Effluent Limitations and Monitoring Requirements" page of the current NPDES permit, the outfall is
listed as "serial number 001" whereas on the "Supplement to Permit Cover Sheet", the outfall is listed as
"serial number 002". With regard to this permit, there is only one discharge point.
If there are any questions with regard to this submittal, I can be contacted at 918/574-8420.
Sincerely,
Steve W. Monn - REM, CHMM
Sr. Environmental Specialist
//
0022101
c: Mark Bowen, Charlotte SOFAC Terminal
Charlotte SOFAC Water Mgmt File - Tulsa

State of North Carolina
Department of Environment
and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor
Wayne McDevitt, Secretary
A. Preston Howard, Jr., P.E., Director
February 22, 1999
Ms. Courtney Baugher
William Energy Ventures, Inc.
Post Office Box 70
Tulsa, Oklahoma 28603
Dear Ms. Baugher:
NCDENR
NORTH CAROLINA DEPARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Subject: Letter to Require Effluent
Turbidity Monitoring
Permit No. NCO074705
Charlotte Products Terminal
Mecklenburg County
As you are aware, the turbidity monitoring requirement was eliminated from your
permit upon renewal in August 1996. Although turbidity monitoring was eliminated, total
suspended solids (TSS) monitoring with a limit remains in the permit. It was the Division's
contention that should monitoring data indicate TSS problems, the state has the option of
enforcing the instream standard for turbidity. However, the EPA is still concerned with the
removal of the turbidity monitoring requirement from several oil terminal discharge permits.
The following paragraphs address that concern.
During the research phase required for permit development, it was noted that the 14
permits in the Paw Creek area had vastly different requirements for solids measurements.
Permits contained any combination of total suspended solids (TSS), turbidity, and settleable
solids monitoring and/or limits. In an effort to provide consistency, TSS, turbidity, and
settleable solids results from six oil terminals in the Paw Creek area were examined from
July 1994 through September 1995. Results showed that TSS and turbidity exhibited
similar trends. Both pollutants appeared to increase and decrease at the same time. In
addition, for the period examined, there were no turbidity violations, although there were a
few TSS violations. These data resulted in the Division questioning whether monitoring
was necessary for both solids parameters. Was there an added benefit to requiring turbidity
monitoring in addition to TSS monitoring? The Division concluded that turbidity was
correlated with TSS results, and thus, only TSS monitoring with a limit was required. In
addition, North Carolina has a water quality standard for turbidity. Therefore, although
turbidity monitoring is not required in the discharge permits, the State still has the authority
to enforce the instream turbidity standard.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

Ms. Baugher
February 22, 1999
Page 2
Based on concerns regarding anti -backsliding, the EPA requested the Division re-
examine the basis for the elimination of turbidity monitoring for 12 of the 14 Paw Creek
oil terminals that were required to monitor for turbidity prior to the most recent permit
renewal. This second examination of the data showed that there were turbidity standard
violations since the last analysis at several of the oil terminals. The Division will
investigate the causes of these violations to determine what steps may be necessary to
control solids levels at these sites. Therefore, the Division acknowledges that its second
evaluation resulted in a different outcome from the initial investigation and agrees that
turbidity monitoring should be added to the discharge permits for several of the oil
terminals. This letter serves as the official notice that quarterly turbidity monitoring
will be required at the facility effective March 1,1999. If monitoring data show a
reasonable potential to violate water quality standards, then limits will be imposed upon
renewal.
If you have any questions concerning this change, please contact Bethany Bolt at
[phone], extension 551.
Sincerely,
Preston Howard, Jr., P.E.
cc: Central Files
Mooresville Regional Office, Water Quality Section
NPDES Unit
Point Source Compliance Enforcement Unit