NC0082970_Permit Modification_20060120

Michael F. Easley, Governor
State of North Carolina
January 20, 2006
Mr. William Baker, Jr., Vice President of Operations
CTI of North Carolina, Inc.
P.O. Box 576
Savannah, Georgia 31402
Dear Mr. Baker:
William G. Ross, Jr., Secretary
Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
Subject: Permit Modification to Reroute Discharge
from Outfall 002 to Outfall 001
NPDES Permit NCO082970
CTI of North Carolina
1002 South Front Street
Wilmington North Carolina
New Hanover County
The Division of Water Quality (the Division) has received and reviewed your written request to modify the subject
permit. Your permit modification is hereby granted.
The Division understands that you intend to re -rout the discharge from Outfall 002 (treated groundwater
remediation effluent) for further treatment through Outfall 001, and that you wish to abandon Outfall 002. The
Division has therefore combined effluent limits and monitoring requirements for discharge at Outfall 001. Please
find attached, corrections and modifications as change pages for your existing permit.
Please insert these change -pages into your existing permit and discard the old pages.
This permit is not transferable except after notice to the Division, and the Division may modify or revoke and re-
issue the permit. This permit does not affect your legal requirements to obtain other permits required by the
Division of Water Quality, the Division of Land Resources, the Coastal Area Management Act, or any other federal
or local government.
If you have any questions concerning this permit, please contact Joe R. Corporon, L.G. at telephone number (919)
733-5083, extension 597.
Sincerely,
zV k�
Alan W. Klimek, P.E.
cc: Wilmington Regional Office, Surface Water Protection
Central Files
NPDES Program, East '
Aquatic Toxicology Unit
Mr. Ron Hart, Terminal Manager —1002 S. Front Street, Wilmington, North Carolina 28401
North Carolina Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699=1617
[phone]
FAX [phone]
On the Internet at htto://h2o.enr.state.nc.us/
A��
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NCDENR
Customer Service
1800 623-7748

Permit NCO082970
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or
discharge are hereby revoked, and as of this issuance, any previously issued permit
bearing this number is no longer effective. Therefore, the exclusive authority to
operate and discharge from this facility arises under the permit conditions,
requirements, terms, and provisions described herein.
CTI of North Carolina, Inc.
is hereby authorized to:
1. Continue to discharge treated groundwater (formerly released through Outfall
002, hereby abandoned) from a 0.014 MGD treatment system, consisting of
• an oil/water separator,
• air stripper,
• particulate filters, and
• activated carbon;
and continue to discharge stormwater runoff, diesel tank -bottom waters and
boiler blowdown from a treatment system consisting of
• a gravity -type oil/water separator,
• mechanical skimmer and
• product holding tank,
and combine these discharges through Outfall 001;
2. Continue to discharge stormwater runoff from a treatment system consisting
of a gravity flow oil/water separator with a mechanical skimmer and product
storage tank discharging through Outfall 003;
3. Discharge from said treatment works, located at 1002 Front Street,
Wilmington, New Hanover County, at the locations specified on the attached
map into the Cape Fear River, classified SC waters in the Cape Fear River
Basin.

Permit NCO082970
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - OutfaU 001
During the period beginning on the effective date of this permit and lasting until expiration, the Permittee is
authorized to discharge treated stormwater from outfall 001. Such discharges shall be limited and monitored
by the Permittee as specified below:
e e~ �fiiC `A�4�OTS IC_�' Y
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Flows
Monthly
1
Effluent
Oil and Grease2
30.0 mg/L
60.0 mg/L
2/Month
Grab
Effluent
Total Suspended Solids
45.0 m /L
Monthly
Grab
Effluent
Benzene
Monthly
Grab
Effluent
Eth benzene
Monthly
Grab
Effluent
Toluene
Monthly
Grab
Effluent
X lene
Monthly
Grab
Effluent
Naphthalene
Quartedy
Grab
Effluent
Meth I -tech -bu I -ether MTBE
Quartedy
Grab
Effluent
EPA Method 624/625
Semi-annual)
Grab
Effluent
Acute To)kity3
Annual
Grab
Effluent
Footnotes:
1. Flow - Flow shall be monitored with every discharge event. During periods of no flow, the
Permittee shall submit a monthly Discharge Monitoring Report (DMR) indicating "No
discharge." Flow may be monitored in one of four ways:
a) measure flow continuously;
b) calculate flow based on total rainfall per area draining to the outfall; exclude
built -upon area (best method for facilities with large runoff -collection ponds);
c) estimate flow at 20-minute intervals during the entire discharge event; or
d) report flow based on discharge pump logs.
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. Acute Toxicity - Whole effluent toxicity shall be monitored annually using the acute
toxicity (fathead minnow, 24-hour) test. Please see Part A. (4).
There shall be no discharge of floating solids or visible foam in other than trace amounts.
There shall be no direct discharge of tank solids, tank bottom water, or the rag layer.
There shall be no direct discharge of tank contents following hydrostatic testing unless
benzene concentration is less than 71.4 µg/L and toluene concentration is less. than 11
µg/ L.
A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS - Outfan 002
Outfa11002 is hereby abandoned by routing its effluent for treatment at Outfall 001 [See A.(1.) above].

CTI OF NORTH CAROLINA,
IMS
NORTH LATHROP AVENUE pTER Q�pL1-fy
DN OF y�
POST OFFICE BOX 576 p�E(•TOR S OFFICE
PHONE [phone] SAVANNAH, GEORGIA 31402-0576 AX 912-235-3873
February 18, 2005
CERTIFIED MAIL #70023150000378684507
RETURN RECEIPT REQUESTED
Mr. Alan W. Klimek, P.E.
NCDENR Division of Water Quality
1617 Mail Service Center
Raleigh, N.C. 27699-1617
RE: NPDES Permit No NCO082970
CTI of North Carolina/Wilmington Terminal
New Hanover County
Dear Mr. Klimek:
This is to request a modification of the referenced permit for our Wilmington terminal. Our permit
currently allows discharge from three outfalls. Outfall No. I is for an oil water separator receiving
stormwater, boiler blowdown and diesel tank water bottoms. Outfall No. 2 is for treated
groundwater. Outfall No. 3 is for an oil water separator receiving stormwater.
Since 2003, we have experienced three TSS violations from the oil water separator designated as
Outfall No. 1. Mr. Moore of your Wilmington office has suggested that the cause of those violations
might be related to the intermittent operation of that system and that we consider routing our
continuous groundwater treatment system discharge (Outfall #002) to the influent of our oil water
separator (Outfall #001). Please consider this our request to modify the permit in order to combine
these two discharges into one outfall.
Upon receipt of that modification, our plan would be to install the piping necessary to route the
groundwater treatment system flow into the oil water separator, but also to install a valve so that the
discharges could be separated. That valve could then be used if we find that this change does not
alleviate our TSS issues or could be used to continue to discharge our treated groundwater during
those periods of time when the oil water separator is taken out of service for cleaning.
We ask thus that the permit provide that flexibility for separate or combined discharge. The permit
modification would need to address the change in sampling for separate or combined discharges.

Mr. Alan W. Klimek
February 18, 2005
Page 2
We appreciate your cooperation and look forward to your response. If you have any questions,
please call Jim Baker of my staff at [phone].
Sincerely,
William A. Baker, Jr.
Vice President, Operations
Cc: Mr. Thomas Moore, Wilmington Regional Office
James R. Baker, EHS Manager
Ron Hart, Terminal Manager

Re: [Fwd! Re: [Fwd: Permit Question]]
Subject: Re: [Fwd: Re: [Fwd: Permit Question]]
From: Tom Moore <[e-mail]>
Date: Tue, 04 Jan 2005 14:36:22 -0500
To: Teresa Rodriguez <[e-mail]>
Thank you very much Teresa. I will notify the permittee.
Teresa Rodriguez wrote:
Tom, If they want to pursue it, the permittee needs to submit a permit modification
request to consolidate the outfalls into one. As Charles mentioned in his response,
we don't reopen permits unless mandated by the Director, but if the request comes
from the permittee we will work on it.
Teresa
Tom Moore wrote:
OK ... Teresa,
Seems like I'm getting kicked all around on this one. I hope you can help me
out. Please read the emails below.
Thanks,
Tom
Joe Corporon wrote:
Tom, I'm not the permit writer for this one -- please contact Teresa Rodriguez
Tom Moore wrote:
Hi Joe,
I just wanted to follow up on this issue. The permittee has responded to my
inspection report and would like to pursue this as they were issued another NOV
for TSS. Let me know what we need to do to address this issue.
If you have any questions, please call me.
Charles Weaver wrote:
Joe, please help Mr. Moore with this question. You worked on the most recent
permit renewal, so you're the best one to advise him.
Tom - I'll add your suggestion to the permit file. Chaning outfalls without the
request of the permittee requires the permit to be re -opened by the Director.
That's only done in extreme cases, and won't likely be done in this case. Thsi
issue will be revisited when the permit is next up for renewal.
If the Permittee feels as strongly about it as you do, they can request a permit
modification and we can address the issue sooner.
CHW
-------- Original Message --------
Subject: Permit Question
Date: Tue, 09 Nov 2004 10:57:30 -0500
From: Tom Moore <[e-mail]>
To: Charles Weaver <[e-mail]>
Hi Charles,
I have another issue with a facility I recently inspected. CTI of North
1 of 4 1/5/2005 8:17 AM

Re: [Fwdc Re: [Fwd: Permit Question]]
Carolina, Permit No. NC0082970, currently has 3 permitted outfalls but only have
two actual discharge points. The 001 and 002 are combined to one stream and
then discharge to a common point. Why is the facility required to sample to
independent streams when they discharge from a single point? NPDES limits are
based on discharge points otherwise using this rationale we could go back up
into many processes and require additional monitoring for unlimited numbers of
"outfalls". Currently the 001 Outfall utilizes an oil/water separator for the
influent stream that is predominantly stormwater. This stream is an
intermittent discharge and not continuous while 002 is a continuos stream from
groundwater remediation. This type of Oil/water separator is designed for
continuous flow application in order to get optimum performance. Because of the
way the system accumulates water prior to discharge, the system is allowed to
concentrate solids in the bottom prior to discharge. They may have a discharge
once a month depending on the amount of rain. The facility has experienced a
couple of TSS excursions over the past year and they are baffled as to why.
During my inspection, I reviewed the system thoroughly and have concluded the
j following:
*This system receives 100% storm water, which contains mostly fines and small
dust particles (i.e. microscopic size). When a rain event occurs and collects
in the diked areas, the water is conveyed to the oil/water separator and is
stored there until the unit reaches a level to be discharged. This allows
sufficient time for any suspended solids to settle and allows a build-up of
solids in the separator. Once the discharge valve is opened and flow is
achieved through the separator, the settled solids are possibly being disturbed
and become suspended again. Discharge may only occur for several hours once a
month on the average depending on rainfall during which a sample is taken and
'., therefore, containing a high concentration of suspended solids. **The mode of
j operation of this unit is not representative of what would actually be
discharged on a continuous basis and what is actually being discharged through ✓
the combined discharge point. The system should be operated with a continuous
flow through the unit to achieve optimum performance and provide a more
representative sample.** *
My recommendation is to consider combining the 001 and 002 streams prior to the
001 Oil/Water Separator rather than after the unit as currently configured.
This would provide a continuous flow through the system and eliminate the need
for monitoring of two separate streams that are combined for discharge from a
single point.
Please give me your thoughts on this.
Thanks..... Tom
Subject:
Re: [Fwd: Permit Question]
From:
Joe Corporon <[e-mail]>
Date:
Tue, 04 Jan 2005 12:31:18 -0500
To:
Tom Moore <[e-mail]>
To:
Tom Moore <[e-mail]>
CC:
Teresa Rodriguez <[e-mail]>
Tom, I'm not the permit writer for this one -- please contact Teresa Rodriguez
2 of 4 1/5/2005 8:17 AM