NC0082970_Correspondence_20170216

Water Resources
ENVIRONMENTAL QUALITY
February 16, 2017
Mr. T. Pratt Summers, Vice President, Operations
CTI of North Carolina, Inc.
P.O. Box 576
Savannah, GA 31402
Dear Mr. Summers:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretory
S. JAY ZIMMERMAN
Director
Subject: Instream Monitoring for Turbidity
NPDES Permit NCO082970
CTI of North Carolina, Inc.
Wilmington Terminal
1002 S. Front St, Wilmington, NC 28401
New Hanover County
Bulk -storage facilities have potential to discharge turbid effluents. Considering that North Carolina has
established standards for Turbidity relevant to your facilities receiving -stream classification. Monitoring
and permit limits are deemed appropriate to evaluate effluent compliance for saltwater [NCAC 02B.
0211(19)]. For the latest permit renewal, Footnote 4 was added to the effluent pages [Part I, A. (L) & A
(2.)] for Outfalls 001 & 003 at follows:
Turbidity — Effluent turbidity shall not cause receiving -stream turbidity to exceed 25 NTU. If
background turbidity naturally exceeds 25 NTU, the effluent shall not cause background turbidity to
increase. Any discharge exceeding this permit limit will require sufficient instream sampling
(upstream and/or downstream) to verify compliance (effluent vs. background). [NCAC 02B.
0220(19)]
For January monitoring, the Wilmington Regional Office was contacted regarding Turbidity results for
Outfills 001 & 003 that were greater than 25 NTU. Pursuant to Footnote 4, instream sampling will be
required to verify compliance. Please note that Instream monitoring should be conducted at the same
frequency as the effluent monitoring. The Division will update our database to add instream monitoring
with the following locations designated as Outfalls for the purpose of reporting in eDMR:
Outfall 004 — a location no less than 50-ft upstream of Outfall 003
Outfall 005 — a midpoint between Outfalls 001 & 003 located no less than 50-ft downstream of
Outfall 003 and no less than 50-ft upstream of Outfall 001
Outfall 006 — a location no less than 50-ft downstream of Outfall 001.
<- "Nothing Compares,.
State of North Carolina I Environmental Quality
1617 Mail Service Center I Raleigh, North Carolina 27699-1617
919-707-9000

Mr. Summers
February 16, 2017
Page 2 of 2
Once you and your staff have identified instream locations within these guidelines, please provide us the
coordinates for the permit file.
If you have questions, or if we can be of finther service, please contact Derek Denard at
[[e-mail]] or call [phone].
Respectfully,
Derek Denard, Environmental Specialist
Compliance & Expedited Permitting Unit
Division of Water Resources, NCDEQ
Enclosure: NPDES Permit NCO082970
he: Central Files
NPDES Program Files
WiRO Files/ Attn: Jim Gregson
ec: Tom Dolan, CTI of North Carolina, Inc. [[e-mail]]
Jim Gregson Uim.gregson@ncdencgov]
Dean Hunkele [[e-mail]]
Anndell Ottaway [[e-mail]]

Denard, Derek
From: Denard, Derek
Sent: Thursday, February 16, 2017 11:34 AM
To: 'Anndell Ottaway'
Cc: Gregson, Jim; Tharrington, Tom; Moore, Tom; Hunkele, Dean;
'T D O LA N @ CO LO NIA LG RO U PI N C. CO M'
Subject: Instream Monitoring for Turbidity - NPDES Permit NC0082970 - CTI of North Carolina,
Inc.
Attachments: NC0082970Instream Turbidity Montioring.pdf
Please find the attached letter concerning instream monitoring for turbidity for NPDES Permit NC0082970 -CTI of North
Carolina, Inc. If you have any questions, please contact me.
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard a(�ncdenr.cov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
N:_ Nothing Compares -.,`
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.

Ci k
Derek
/U C 00 9
0O1
From: Denard, Derek
Sent: Thursday, February 09, 2017 1:22 PM
To: Hunkele, Dean; Anndell Ottaway
Cc: Gregson, Jim; Tharrington, Tom; Moore, Tom
Subject: RE: Location not meeting Turbidity requirement
2q -79
r M
We will send them a letter requesting that they start instream turbidity monitoring in accordance with Footnote 4
effective for March. By that time, we can update BIMS so that eDMR reporting is possible for Turbidity as an instream
parameter.
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denard()ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
In. -:-Nothing Compares....
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Hunkele, Dean
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Sent: Thursday, February 09, 201712:16 PM
To: Denard, Derek <[e-mail]>; Anndell Ottaway <[e-mail]>
Cc: Gregson, Jim <[e-mail]>; Tharrington, Tom <[e-mail]>; Moore, Tom
<tom.f.moore @ ncden r.gov>
Subject: RE: Location not meeting Turbidity requirement
Derek,
It appears that BIMS does need to have an upstream and downstream monitoring added with optional Turbidity
reporting so that a-DMR will have them as available for CTI to report so we and they can assess compliance versus the
effluent of each outfall.

I think you will need to talk with someone on how EPA's system will handle this? We know that BIMS can't do it
directly. If they report the data presented below, it will flag them as violations of the 25 NTU limit and I would have to
then look at the stream monitoring data to determine if any action will take place by us. However, the EPA's system will
also like flag them as violations and land them on the SNC list after a certain number of violations. EPA likely will have
no way to analyze or indication to do so using stream data based on a simple transmittal of data to them.
Dean Hunkele
Senior Environmental Specialist
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7380 Direct
910.350.2004 Fax
Dean. H [e-mail]
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
M. !�Nothing Compares —
Email correspondence to and from this address is subject to the
North Carolina Public Records Low and may be disclosed to third parties
The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from receipt of a complete application and if
no additional information has to be requested upon full review. Please use the Department's Permit Application Tracker to determine the official
application receipt date to allow you to estimate a date for issuance and find the reviewer's name. Once Issued, the record stays on the site for 30
days.
For previously issued sewer permit info or to check on sewer certification receipt status, please use the Division's Sewer Extension Permit
Tracker. Using the Issue Date on top of the Engineer Certification Form Is best way to ensure getting what you want especially for multi -version
permits; using today's date only gives Info on the latest permit version. Confirmation using this method will replace letters and emods: it is
recommended that confirmation be printed and/or saved.
Links to both trackers can be found on the sewer permitting site here: https://deg.nc.gov/about/divisions/water-resources/water-resources-
pe rmits/peres/col lectio n-system s-perm its
Subscribe to Collection System Updates listserve to receive automatic alerts for changes to applications, policies, regulations, etc.
From: Denard, Derek
Sent: Wednesday, February 08, 2017 4:24 PM
To: Hunkele, Dean <dean.hunkele(&ncdenr.eov>; Anndell Ottaway<AOttawav6DcoloniaRerminals.com>
Cc; Gregson, Jim <im.greasonCa)ncdenr.eov>; Tharrington, Tom <tom.tharrin¢[e-mail]>
Subject: RE: Location not meeting Turbidity requirement
Bulk -storage facilities have potential to discharge turbid effluents. Considering that North Carolina has established
standards for Turbidity in accord with receiving -stream classification, monitoring and permit limits are deemed
appropriate to evaluate effluent compliance for saltwater [NCAC 02B. 0211(19)]. The Turbidity limit of 25 NTU is from
the narrative standard for saltwater. For narrative standards instream dilution is not applicable as with numerical

standards such as the aquatic life standards for the BTEX parameters in this permit. As Footnote 4 states, for Turbidity
compliance with 25 NTU is verified by instream sampling in the nearest waters of the state which is what make this a
narrative standard. In cases where instream sampling is not available or cannot be determined due to flow conditions,
the permit limit applies at the point of discharge.
The discharge location for this facility is in the Cape Fear River. If possible find an upstream and downstream location for
turbidity sampling of the Cape Fear River. If we need to update our database for instream monitoring so that you can
enter instream turbidity into eDMR, please let me know.
Sincerely,
Derek C Denard
Environmental Specialist
Compliance & Expedited Permitting Unit
N.C. Division of Water Resources
N.C. Department of Environmental Quality
919 807 6307 office
derek.denardCa)ncdenr.gov
N. C. Division of Water Resources
Water Quality Permitting Section - NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
F Nothing Compares,..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Hunkele, Dean
Sent: Tuesday, February 07, 2017 5:19 PM
To: Anndell Ottaway <[e-mail]>
Cc: Gregson, Jim <iim.aresson@ncdenr.¢ov>; Tharrington, Tom <[e-mail]>; Denard, Derek
<[e-mail]>
Subject: RE: Location not meeting Turbidity requirement
Anndell,
I wasn't aware that they added that to the permit since I did not review the site for renewal nor review the draft
permit. I looked at the permit and the fact sheet form Raleigh's server and I'm not real clear on why it was added after
all this time. I assume it was mentioned in the draft, but the draft is not on the server to see how it was covered and I
do not see that it was asked about in C ri's response to the draft that is on the server.
I have only been to your facility once in 7-2011 and not sure what you may or not be able to do without a compliance
schedule to implement some sort of treatment to address it. It appears that you may be able to sample the river to

show the background turbidity is higher than the limit consistently to show compliance but not sure how would"work for
input into a-DMR or for how data would need to be collected to deactivate the limit.
I would suggest you talk with the permit writer Derek Denard whom I have copied for guidance.
Dean Hunkele
Senior Environmental Specialist
Water Quality Regional Operations Section
Division of Water Resources
Department of Environmental Quality
910.796.7215 Reception Desk
910.796.7380 Direct
910.350.2004 Fax
Dean. H unkeleCd ncden r.gov
Wilmington Regional Office
127 Cardinal Drive Ext
Wilmington, NC 28405
M- !''Nothing Compares -
Email correspondence to and from this address is subject to the
North Carolina Public Records Low and may be disclosed to third parties
The goal of the Fast Track sewer permit program is to issue a permit in no more than 30 business days from receipt of a complete application and if
no additlonal information has to be requested upon full review. Please use the Department's Permit Application Tracker to determine the official
application receipt date to allow you to estimate a date for issuance and find the reviewer's name. Once issued, the record stays on the site for 30
days.
For previously issued sewer permit info or to check on sewer certification receipt status, please use the Division's Sewer Extension Permit
Tracker. Using the Issue Date on top of the Engineer Certification Form is best way to ensure getting what you want especially for multi -version
permits; using today's date only gives info on the latest permit version. Confirmation using this method will replace letters and emails; it is
recommended that confirmation be printed and/orsaved
Links to both trackers can be found on the sewer permitting site here: httos://dea.nc.Rov/about/divisions/water-resources/water-resources-
perm its/oeres/col lection-systems-oe rm its
Subscribe to Collection System Updates listserve to receive automatic alerts for changes to applications, policies, regulations, etc.
From: Anndell Ottaway[mailto:[e-mail]]
Sent: Friday, February 03, 2017 3:30 PM
To: Hunkele, Dean <[e-mail]>
Subject: Location not meeting Turbidity requirement
Hi Dean,
I wanted to reach out for some advice you may have requarding the Turbidity limits for our new permit. We had our
monthly test preformed January 16`h, 2017 and we failed turbidity on both locations (001 Soutside and 003

Northsid'e). Tests results were received January 27th, and I made a request for additional tests. These additional test
were preformed on Friday, January 2711, and Monday January 315% 2017. Results are in, on the additional tests, and
again we do not meet requirements. Below are the test results.
January 16`h, 2017 January 271h, 2017 January 31s`, 2017
001)southside ......66.7 NTU ..............37.7 NTU .............88.6 NTU
003)Northside .......43.6 NTU .............30.2 NTU ............29.3 NTU
Any advice would be helpful. This system is not treated, and only annual cleanouts preformed (not permit required).
Thanks in advance Dean
Anndella B. Ottaway
Colonial Terminal
1002 South Front Street
Wilmington, North Carolina 28401
Office: 910-762-6615 Ext 6111
Fax: [phone]
Abarefoot@Colonial Terminals. com
s