NC0032883_Complete File_19931102

State of North Carolina"r
Department of Environment, IVA
Health and Natural Resources A
• •
Division of Environmental Management
- _00k
James B. Hunt, Jr., r C
dwand
Jonathan B. Howes,, Secretary
C
A. Preston Howard, Jr- P.E., Director
November 2, 1993
QUENTIN C MENDENHALL ENVIRONMENTAL ENGINEER Nov ie
PHILLIPS PIPE LINE COMPANY
3 B11 ADAMS BUILDING
BARTLESVILLE OK 74004 D3 -off.-o?stT 1�R,htl
Subject: Remittance; of Civil Penalty Assessment &
Permit Rescission
Phillips Pipe Line Company
RV 93-064
Permit No. NC003288
Guilford County
Dear Mr. Mendenhall: 1,1T k owre-EQ e a � �-
On September 16, 1993 you requested that your permit be rescinded due to the fact that your
facility is no longer being used. A copy of your request was forwarded to our Winston-Salem Regional
Office for verification. The Winston-Salem Regional Office has now verified that your facility is closed.
Due to this fact, your civil penalty assessment (RV 93-064) has been remitted and your case closed. Also,
as per your request, NPDES Permit No. NCO032883 is hereby rescinded.
If in the future, you determine that you wish to have a discharge, you must first apply for and
receive a new NPDES Permit. Discharging without a valid NPDES permit will subject the discharger to a
civil penalty of up to $10,000.00 per day.
If there is a need for any additional information, please contact Robert Farmer at [phone],
ext. 531.
Sincerely,
A. reston Howard, Jr., P.E.
cc: Winston-Salem Regional Office
Mr. Jim Patrick, EPA
Guilford County Health Department
Winston-Salem Regional Office
Permits & Engineering Unit - Coleen Sullins
Fran McPherson, DEM Budget Office
Operator Training and Certification
Technical Support Branch
Facilities Assessment Unit - Robert Farmer - w/attachments
Central Files - w/attachments
Aquatic Toxicology - Larry Ausley
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
rIM0

NPDES WASTE LOAD ALLOCATION
PERMIT NO.: NCOO 32 853
FACILITY NAME:
--T
Facility Status: 7)%?
PROPMW
(circle one)
Permit Status: /REMIF'ICATION UNPERM TTM NEW
(Circle one)
Major lltinor V_
Pipe No: 003
Design Capacity (MGD):
Domestic (% of Flow):
Industrial (9r of Flow):
Comments:o� ►Mev OC7 -See 5, �.
RECEIVING STREAM: UT4 �VS�P2� Cf"e'e-k,
W 5-M •JSw
Class:
Sub -Basin: 0 3 _ 0(,_0 2
Reference USGS Quad: SW (please attach)
County:
Regional Office: As Fa Mo Ra Wa Wi QWS
(circle errs)
� .SALLI"ate:
Requested By:, ® �"-�
Prepared By: Co Date:
Reviewed By: _T
Date:
Modeler
Date Rec.
# �-
Drainage Area (mi2 ) Avg. Streamflow (cfs):
7Q10 (cfs) Winter 7Q10 (cfs) 30Q2 (cfs)
Toxicity Limits•• IWC N'- % (circle one) Acute / Chronic
Instream Monitoring:
Parameters
Upstream
Downstream
Location
Location
Reco�Mcn� flow Mo��+o��n� ��� all vo(umes of wa +c v►n�icr
�tav�nq %tic �aul��, Con��nuous �on��-or,r9 �r weQkly flo,,,, f-o+ai�2ec
Effluent
Characteristics
Mcj1� Jkverc�Ae
"
Max
Phenols �b/��t
O. oot
tI Su
�-9
Ttk-' , a; N i U
TkJL 9kNc6rAf SWI A
use fiu f 6lJ
e w
rS 40 exceesoiJt ,
IT f V ex&
SO M
8,Ae J0 n&jUlaCkq�011AAJconJ�}ion
�;clna�
e[OM(kpA Z MJnP1
MOntTOr{n o} Ct uEnf
a� 0:G 4 Q �It/10�5
settleable SOl.ds�rug O�c�t+y, And ?M MCC OM Aunt robe 'r "'J TOk
+oluene, heAzLn cwAxvlrn1 be gonn nn JfU Sa1W sc�14) 1411f
AS }% +ok,ci'�y Mon,{ot;nq 1f1'-} S J s�crit �ix�0.r eu�n%s. f reooenc[_
clause S64 ape �(Ace� flu CW'M'-+ allow -ivc Dace
on {o)1iC4n11J 5hou� t u 114y itI wlw(e -e lueni iox:c;�/

FOR APPROPRIATE DISCHARGERS, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
Effluent Characteristics Monthly Daily
Average Maximum Comments
Type of Product Produced I Lbs/Day Produced I Effluent Guideline Reference

(� ^ o
i
—900 1 � �dship�ch
( ♦ , - �� �I ta, IG•• OINT \ e,
Frtdahip �°a k—
ip
/ 90
I
it L
�� �> •� �,�- oaf
Air
00
goo
f, G
\, 6 O Q 1 •f� 1. • \ �I
i CI I \ •• • wlvA7.Z�:)•0/
phl
:� ° � _ _ j� • - l y -- � - 1 < , L _ .ram,
_)7f ,
-� � - �, •-- ;p ,
4.
50 11
4'So"
U.4, 6,4"�ON cl" ��4 L.ti/ �'�tL�•Q l-✓l.✓J T[^oJ lA_T-iv C'eCC' i u lr..7�tr�:7i:r.
°
b
' e50 �•� 0° 100'
' '� % J• 0 U-S
4��e�oi �-(.��� � •• -+v NoS(-',
.�Qi ,�1 , e• CO q1 Svi

Reques
------------------- WASTELOAD ALLOCATION APPROVAL FOR
Facility Name:
NPDES No.:
Type of Waste:
Status:
Receiving Stream:
Classification:
Subbasin:
County:
Regional Office:
Requestor:
Date of Request:
Quad:
PHILLIPS PIPELINE COMPANY
NC0O32883
INDUSTRIAL
EXISTING
UT TO HORSEPEN CREEK
WSIII-NSW
No. : WaMD
N.C. Dept. NRCD
-----------------
JUL 27 1968
Uivision of
Environmental Management
Winston-Salem Reg. office
030602 Drainage area:
GUILFORD Summer 7Q10:
WINSTON-SALEM Winter 7Q10:
JULE SHANKLIN Average flow:
4/4/88 3002:
-------------------- C19SW
RECOMMENDED EFFLUENT LIMITS--------------�---�
cpc%
Mo . Avg. Daily Max. xis
Oil & Grease (mg/1): 30 60 b
Settleable Solids (ml/l) : 0.1 0.2
N6
Phenols (lb/day): 0.001
pH (su): 6-9 6-9
Turbidity (NTU): The discharge shall not cause the turbidity of
the receiving waters to exceed 50 NTU. If the
turbidity exceeds 50 NTU due to natural back-
ground conditions the discharge can not cause
any increase in turbidity of the receiving water.
Toxicity Testing Req.: Acute, Episodic Monitoring (See Attached)
sq mi
cfs
cfs
cfs
cfs
---------------------------- MONITORING ----------------------------------
Upstream (Y/N): N Location:
Downstream (Y/N): N Location:
----------------------------- COMMENTS -----------------------------------
RECOMMEND FLOW MONITORING FOR ALL VOLUMES OF WASTEWATER LEAVING THE
FACILITY. CONTINUOUS MONITORING OR WEEKLY FLOW TOTALIZER DATA ARE
ACCEPTABLE. RECOMMEND 2/MONTH MONITORING FOR OIL & GREASE, SETTLEABLE
SOLIDS, TURBIDITY,pH, AND PHENOLS. RECOMMEND MONITORING FOR TOLUENE,
BENZENE, AND XYLENE BE DONE ON THE SAME SCHEDULE AS THE TOXICITY
MONITORING (1st 5 DISCRETE DISCHARGE EVENTS). A REOPENER CLAUSE SHOULD
BE PLACED IN THE PERMIT TO ALLOW FOR LIMITS TO BE PLACED ON TOXICANTS
SHOULD THE FACILITY FAIL ITS WHOLE -EFFLUENT TOXICITY TEST.
Recommended by:
4j11�-------- Date:
Reviewed by
-fvt,Tech Support Supervisor: _
Q Regional Supervisor: _ _
'lVqD
Permits & Engineering: ___
------ Date:
Date-
C .r5
Date F
RETURN TO TECHNICAL SERVICES BY: ------
AUG 2 1�
■

x
Facility Name PhJIs ?I In, 1 CoM - 003 Permit # NCOo 32883
ACUTE TOXICITY TESTING REQUIREMENT
Daphnid 48 hr - Monitoring for Episodic Events
The permittee shall conduct FIVE acute toxicity tests using protocols defined in E.P.A. Document
600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and Marine Organisms".
The monitoring shall be performed as a 12gphnia lmix or Ceriodaphnia 48 hour static test, using
effluent collected as a single grab sample. Effluent samples for self -monitoring purposes must be
obtained below all waste treatment. Sampling and subsequent testing will occur during the first five
discrete discharge events after the effective date of this permit.
The parameter code for this test if using Daphnia pulex is TAA3D. The parameter code for this test
if using Ceriodaphnia is TAA3B. 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, DEM Form AT-1 (original) is to
be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
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 Environmental Management 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.
Failure to submit suitable test results will constitute a failure of permit condition.
7Q10 r]A cfs
Permitted Flow ► A MGD
IWC% NA
Basin & Sub -Basin o30602-
Receiving Stream tjT' to Igor syn Creek
County C-AA, i �o r A
Recommended by:
,4;4a � S A u,
v
Date z
"Acute Toxicity(Daphnid 48 hr) Monitoring, EPISODIC, See Part , Condition G .

NPDES WASTE LOAD ALLOCATION
NCoo 32 g0 � Modeler Date Rec. ' #
PERMIT NO.: I I -
O 9 I +
FACILITY NAME: � 1 (lips ► 2c h �_e
Facility Status: PROPOSED
(circle one)
Permit Status: ;'RENEW MODIFICATION UNPERMrrrED NEW
(circle one) �. _
Major Ninoi
Pipe No: OC) * OD 2
Design Capacity (MGD):
Domestic (% of Flow):
Industrial (% of Flow):` l d
2
Drainage Area (mi) Avg. Streamflow (cfs):
7Q10 (cfs) Winter 7Q10 (cfs) 30Q2 (cfs)
Toxicity Limits: IWC % (circle one) , cut` / Chronic
Instream Monitoring: I
Parameters
003 t_o de__
Comments: Vio"S��i
pr2y 1,0
w 00
;��_C 00'�Z��'3
LIT 0"o Q-sa-D E /3 &C-6
RECEIVING STREAM: L �I — % Ov k „3 "109.51: -
Class: WSJ 41� Cecc�Jw� S-��ca
Sub -Basin: O 3 -061- -
Reference USGS Quad: C, 19 J W poi.'
County: Gu I ITO�
No kA Cp
Regional Office: As Fa Mo Re
(circle ewe)
Requested By: J P� �G" - Date: � v
Prepared By: f Sc0 Date:
Reviewed By: Date:
L/
Location
A
3
tm Location
monc4oc,,�� ;o+ a('t �;,1N:,�cS c!, waSiL•.,c\+�cc leau.:�l ��cc iacl,i'`1.
►'1LnG ✓✓tDn•+or.>77 tJ� b¢1�2�+'IG � +O�A(G✓LL� A.�l� ft'yte.ne
r d+cr',PJO_
Ics
-OZ. SeL )
'�r�tauarl
WLT 0ml)
g1a9lti5,
PUB %,71JI
- -
o„ v JC iA,
d, sc
coot
I I tu
Sei}l�a�e S61t�15 M(
p. I
O 1 2
0. ova
• s
T-AC ,Ak . rece\,i.n
c �.,�c �t1Ull not u5c
wwkr-� f� excecct ' o NT'4
t o t\tr� d;� c r
. I 4tA +;,r y
Comments' O'SLI 1141 nno+ cr��tSG an- nct�a
ce(_e.v,n
,;r;kr
Co
erlet clan e_
I
be plot,!
n �V�
fy U��C�✓
�O �t.Mtt� �J,}1
�5ho.�z
be p laced 'on
orz t c(A n :S
40\.t «
f�v hc�c \ �• TY �A+
t t7
v 110�t - c' rltACtr1 1

FOR APPROPRIATE DISCHARGERS, LIST COMPLETE GUIDELINE LIMITATIONS BELOW
Effluent Characteristics Monthly Daily
Average Maximum Comments
� •yam.+, i! � �i "E s . Y�
Type of Product Produced I Lbs/Day Produced I Effluent Guideline Reference

/\ o
n °
9 (rr
07,
660
° 1 riendehi
IGw DINT
WINS
F ad014 r -
i
�. ° _ 1
0
J \ • , U/ �/off •• i • � _ _ � A" 1 N
G•foline :* a \ • •_� 11 I ,� �`
7 -� � , _ as 4• -�,- � �
9 Ste\ a 900 O�. •� •.� ��� •• • • '
UD \ 7
g5 '' O' 4{•� � • � `_ `/ \ �h' ��I,D�' Pl�e �.li•Q_ oMP<<�'.�� ll'j I •,�,
•� I `p' • CL©�3Ug�
ai,e/ i' /�✓t� • • •,.
So (� et S + r, L Deee i v3/l
CEO 1 r��`�.�� :���� 002�
Jj
-
o° Aso r �• 0 2 (SocCnul y 0s 32
-795-
�
u."r-Iv C'rrC�luir.� �tlt7iir. 01 -D� -v Ij ��
�0 4, �_1 C.;/,
850 ✓ A I OM2?i FVv _Lil �` p^Ai Q/s`A . W1A
� N, e —J "6 (>`S 421 +6A, Wert- +0 Sn:2-Z flr,
V.,1. oiz :��J L°. C I9 .SVJ ,W57m g�
11 '71 % �dw, ' - %�I � !�(._ 1c� I �; c �m.ri� l' / A` t���� `�,, ^� V

cc: NPDESV"'�
Guilford County Health Department
WSRO
Central Files
Date March 28, 1988
Phillips Pipeline Company
NPDES STAFF REPORT AND RECOMMENDATIONS
County Guilford
NPDES Permit No. NC002 -E• 3D$, S
GENERAL INFORMATION (Permit Renewal)
1. Facility and Address: Phillips Pipeline Company is
located in the SE corner of the intersection of
Gallimore Dairy Road (SR1555) and US421 across from the
Piedmont International Airport. Mailing Address: Mr.
B.L. Thornman, Vice-president, Phillips Pipeline
Company, P.O. Box 8327, Greensboro, NC 27419. The
terminal's address is 7121 West Market Street and the
telephone number is [phone].
2. Date of Investigation: March 7, 1988; Mr. Tim Lee,
Terminal Attendant
3. Report Prepared By: A.R. Hagstrom, Environmental
Engineer, DEM, WQ
ION AND RECOMMENDATIONS
This terminal remains essentially the same as when
originally evaluated. In earlier permits, the terminal had
four discharges namely 001, 002, 003, to the south via over
land flow to wet weather ditches, storm drainage systems,
and eventually to UT to East Prong Deep River (03-06-08) and
004 to the north via over -land flow, wet weather ditches and
pipes (under the rail road track, under US421, into a small
lake approximately 1/2 mile due north, and then via
over -land flow and ditches to a UT to Horsepen Creek
(03-06-02). Several years ago, they took the 001 discharge
and placed it into the diked area that made up the 002
discharge. Our compliance group later asked that we
re -number the outfalls. The original 001 and 002 discharges
are now 001 and 003 is now 002 (still going south) and the
004 is now 003 (still going north).
The 001 discharge has the water separated from the oil
water separator which is pumped to the diked area from which
the discharge originates.
All three discharges are intermittent and are rain
dependent. Discharges are not needed unless high water
threatens the dike or tank bases and they are controlled by
valves.

a
Page 2 of
Phillips
March 28,
PA
Pipeline Company
1988
Because of the distance to the flowing streams via
over -land flow, the need for phenol limits is questionable.
Monitoring for phenol concentration should be adequate for
all three (3) discharges.
Flow should be determined and reported and is currently
estimated using a time pipeflow method. pH limits should be
set and then reported. Oil and grease limits should be
maintained at the current level. Monitoring of all
parameters shall be done for each discharge for a maximum of
two discharges/month. All discharges shall be reported and
flows determined and reported.
The WSRO recommends the re -issuance of this permit with
the changes indicated. No toxicity test appears to be
practical for this type of intermittent discharge that is
essentially rain dependent and not process dependent.
Copies of earlier staff reports dated September 10,
1976, April 29, 1982, and June 19, 1986, are attached to the
NPDES and WSRO copies only.
SIC Code 5171
Wastewater Codes 37 39
Signature o eport Preparer
Water Quality SuperviAfor

NORTH CAROLINA DEPARTMENT OF NATURAL RESOURCES AND -COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
Winston-Salem Regional Office
June 19, 1986
MEMORANDUM
TO: Mr. Arthur Mouberry, Supervisor
Permits and Engineering Unit
THROUGH: Mr. M. Steven Mauney
Regional Water Quality S pervisor
FROM: Mr. A. R. Hagstrom
Environmental Engineer
SUBJECT: Phillips Pipe Line Company NPDES Permit No. NC0032883,
Mr. B. F. Ballard's Questions Regarding the Permit Issued
'February 5, 1986
The letter brings out many good questions regarding the "oil
tank farms" in Guilford County and anywhere in North Carolina.
Generally, they are intermittent dischargers from multiple points,
they do not discharge each month, each discharge point should be numbered,
and meaningful flow measurement ranges from difficult to impossible.
The discharges are collected rain water that collects behind safety
it k b tt to s ecial hazardous waste disposal
dikes. Genera y, tan o oms go p
companies.
The WSRO comments regarding Mr. Ballard's letter follow and are
numbered to correspond to his letter as close as possible.
c�'\� ,
1. Part 1 A(1) Effluent Limitations and Monitoring Requirements
Flow - The measurement frequency (whenever discharges occur)
vim' 0�1
a. They discharge intermittently (via manual valves) when the �O �1,
in them. Flow is determined
dike areas have too much water
by using time and volume passed through the standard pipe
Ob \
size (GPM). Flow should be measured when it occurs.
p 1
0
b. There are now 3 discharge points. The 001 discharge is now
,Lk°
pumped to the dike that generates the 002 flow. The diverted
flow that was 001 consists of water that has oil/grease/gasoline
is into the holding dike.
o°
4..
separated from it and which pumped
If there is no rain it evaporates. The separated oils are
aka
pumped into a holding tank for re -use. The discharges 003
`,N��
� �r
and 004 are from separate dikes, but no water from a separator
discharges are also controlled
ov
4+
is placed in them. These
�0
by manually operated valves and are rarely opened.
L1.7'

Mr. Arthur Mouberry
Page Two
June 19, 1986
Now, there are three discharges from this tank farm; namely
002 and 003 that flow to the East Prong Deep River (03-06-08) and
004 that flows to Horsepen Creek (03-06-02). All flow over-
land to drainage ditches and eventually may get to flowing
water. The daily flows can be controlled with the valves
and are intermittent. The flow should be measured whenever
discharges occur. Most of the flow is rain water with little
washdown water.
Oil and Grease - The frequency of sampling should be prior to
each discbhrge with a maximum of twice/month.
Phenols'- The frequency of sampling should be prior to each
discharge with a maximum of twice/month. Limits should be in
lbs./day and ppb shall also be reported.
pH - The frequency of sampling should be prior to each discharge
with a maximum of twice/month.
Other
a. The statement regarding floating solids or visible foam statement
appears OK.
b. The statement regarding reporting a non -detectable concentration
needn't be included. It may, if our Cary Lab indicated that
the method they are to use is OK.
�S
2. Part III C. Certified Operators - Certified operators haven't
been required for this type of facility. The system has
D�
1. Variable flow (1), an oil grease separator system, (2),
a transfer pump, (3), and holding lagoons (diked area) and ca);5_ ti k`j
staged discharge or no discharge (5). With a total of
approximately 11 points it appears that we could require
an operator but our certification program doesn't relate t.a
to these systems and oil terminal operations. Delete certi-
fied operator requirement at this time. A''
D. The possibility of Groundwater monitoring should be left
in the Permit shince the bermed areas are not lined.
ARH/cm
cc: Central Files
WSRO L/

HORTH CA oLIKA DEPARTMENT OF NATURAL RESOURM b COMMUNITY DTVELMYNM
DIVISION OF ENVIROWMAL MANAGMUNT
Winston-EalSm Legioaal Office
April 29, 1982
HIMORANDUX
TO: Lao Flaming
Permits 4 Engineering
THROUGH: Russell D. Radford
AetAng Regional Supervisor
THROUGH: M. Stevan Mauney
Permtts & Engineering ordinator
FROM: Charles Fiero /
Chemist (`,�',� -
SUBJECT: Update to September 10, 1976 Site Evaluation,
Phillips Pipe Line Company, Greensboro,
Guilford County
The subject site evaluation was updated on April 23, 1982 by Charles Fiero.
The facility is as it was described in the original 1976 report. There is one
minor change, however, in the locked gate valves for discharge points 2, 3 and 4.
These values are not "locked" as such, but have numbered seals which are broken
When the valves are opened. A check-out system is used aid all opening,, f+..
valves are legged with the old and new tag numbers. Mr. Parr said durins't14 !
last visit that they would be willing to utilise a "lock" system for these:
valves if ve request it.
Also, it is recommended that the facility classification be changed from
7 pts., Class I to 2 pts., no certified operator required. This reflects the
deletion of (9)(c), "Holding Pond for Effluent Flow Equalization..." !s it is
felt that this does not apply to this system. There is no adequate method
available to reliably deteradtio the flow, therefore, the only applicable
classification is 2 pts. for the oil -grease separator.
It is recoasnaded that the permit be issued as soon as practical.
\3
,�tl
Vob31
A�Qd3 p °

NORTH CAROLINA DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
' OFFICE OF WATER AND AIR RESOURCES
Water Quality Division
P. 0. Fk)x 27687
Raleigh, North Carolina 27611
REPORTOF --- ------------------------------------------------------- P--
Place visited ------Yh1Pl_nP_� 1�pg_Comglans,_GrettsborQ,_N._ C. ____ Date _ September 10� xY9__76
AddrevEa:91- &Q _$$ g9abQxq Azr1L_Z741O River Basin
By Whom III Time Spent -------
Persons Contacted _hr-,,- G.-E.._PArr,-Terminal -Suprziuten ext---------------------------------------
------------------------------------------------------------------------------------------------------
Reason for Visit _-_ Can duct-zLm1te_eval.uaUQn-prlor_i.aauaace_of_.&AQttb_i arp) iia__.______________
--------=-------'=-_D$S_Discharge_Permit-=--=-=-=------_--------=---`------------=---=---1:._ :...
Copies to: Bill Mills/Central Files
Winston-Salem Regional Office
REPORT:
The following Staff Report and Recommendations pertain to the site
evaluation conducted at the Phillips 66 Oil Storage Terminal, Greensboro,
North Carolina, on September 8, 1976.
PART I - INSPECTION OF EXISTING FACILITIES
1. Directions to Site: From Winston-Salem, proceed east on
N. C. Highway 421 approximately 16 miles. The Phillips Oil
Storage Terminal is on the right at the junction of Hwy. 421
and Gallimore Dairy Road (NCSR 1555, Guilford County).
LATITUDE: 36° 04' 55" LONGITUDE: 79° 56' 15"'t V\
�C
2. Location of Points of Effluent Discharges The points of
effluent discharges are as follows:
Am west- v;-, 47 di+e
side of terminal (b
Lot: 360 04'. 00, Long.: 79° 56' A"
b0 _900
Aa - Sout Voiceo' ten na
Lat: 360 04' Long.: 79° 561'1!}a!� 90Q
_ - Center of terminal with discharge to the north.
u � Lat: 366 04' 56 N Long.: 79° 56' W'`
is
wQ rl')
Re%% ,ed 4 26/72

3. Size: The installation is situated on high ground which
has approximately 17 acres of fenced area. About 5.5 acres
is diked around the tank farm that has a storage capacity
of approximately 190,000 barrels with a annual through -put
of approximately 1,700,000 barrels of petroleum products.
4.
Topography: The storage facility is situated atop a general
high broad land mass that has a uniform slope of 0-3% to the
North, West and South.
Location of Nearest Dwelling: The nearest dwelling is located
in excess of 3000 feet away from the terminal. Numerous build-
ings of commercial nature are located'at various distances from
400 feet. All of the buildings are generally related to func-
tional or support activities relating to the oil Industry or
the transport thereof.
6. Receiving Waters. col OOZ_
A. Discharge ;
A6
(1)
East Prong Deep
River
(2)
Class A -II
(4)
7-10 Low Flow:
0.01 cfs (Field Estimate)_
(5)
River Basin: Cape Fear
B. Discharge CYj3sw4b
c�ha,r,;�a.�c��-i� t u�►�d�c.
s o u_�1Z M 4"A wVJ L"- k-S ¢ 2 I JM a- SniAk
(1)
Horsepen Creek
Vo.,., g,A &.,P_ a.+CC ,w +b
(2)
Class A -IT
+CK
e
(4)
7-10 Low Flow:
0.01 cfs (Field Estimate) cQi V.Co+J;11-"4
(5)
River Basin: Cape Fear 2.8-$
PART II - DESCRIPTION OF TREATMENT FACILITIES
Several catch basins and grated troughs are located around
the tuck loading dock. Any spilled product is carried to a
two compartment gravity steel oil/water separator at discharge
001. The seperated product is piped to a nearby underground gl
holding sump which is pumped on a scheduled basis to a large �5-
5000 barrel storage tank within the diked area. The seperated
water from discharge 001 is pa�r�paQ-�
bi � ate.
Dra. inag from the diked areagvia dischargeS"2; 6W3;1 and' � ~
rarely occurs. These discharges are controlled by a six (6) inch
gate valve5that4k locked shut. If the need for discharge arises,
J the flow will follow natural drainage lines and must travel a mini-
mum of at least 0.-3�3 miles prior to reaching running water.

PART III - OTHER PERTINENT INFORMATION
1. A review of records indicates this facility is properly
registered in the State of North Carolina as an oil
terminal facility - No. 41002105.
2• An adequate amount of emergency materials are available
at this facility to be utilized in the event a spill
occurs. As a back-up measure, all of the terminals in
Greensboro, N. C., area are members of an Emergency Co -Op
which has mobile units available to respond to oil spill
incidents.
3• The permit application indicates the oil terminal utilizes
a septic tank for disposal of domestic wastewater. This
is not a discharging system; therefore, should not be con-
sidered an issue for this discharge permit.
PART IV - EVALUATION AND RECOMMENDATIONS
A. EVALUATION:
1. From actual observation of the oil/water seperator now
in operation, the system is functioning well and appears,, -,,,-
to provide adequate treatment prior discharging any water.
2. The diked region has appropriate pipes and locked gate
valves for drainage of storm water and product draw -off
water. The diked area, however, is hardly ever drained
and the accumulated water is left to evaporate or be
absorbed into the soil.
3. An adequate amount of emergency materials are maintained
on the premises for oil spillage if needed. As a back-up
v measure, emergency mobile units are available for oil
spill containment and clean-up should the situation arise.
B. Recommend the permit be issued as soon as practical.
LLA/bht

�
Request No.: 4582
------------------- WASTELOAD ALLOCATION APPROVAL FORM -------------------
Facility Name: PHILLIPS PIPELINE COMPANY
NPDES No.: NC0032883 ow[ +002
Type of Waste: INDUSTRIAL
Status: EXISTING
Receiving Stream: UT TO EAST FORK DEEP RIVER
Classification: WSIII
Subbasin: 030608 Drainage area: sq mi.
County: GUILFORD Summer 7010: cfs
Regional Office: WINSTON-SALEM Winter 7010: cfs
Requestor: JULE SHANKLIN Average flow: cfs
Date of Request: 4/4/88 30Q2: cfs
Quad: C19SW
-------------------- RECOMMENDED EFFLUENT LIMITS --------------------------
Mo Avg Daily Max
Wasteflow (mgd):
Oil & Grease (mg/1): 30 60
Settleable Solids (ml/l): 0.1 0.2
Phenols (lb/day): 0.001
pH (SU): 6-9
Turbidity (NTU): The discharge shall not cause the turbidity of the
receiving waters to exceed 50 NTU. If the turbidity
exceeds these levels due to natural background cond-
itions, the discharge can not cause any increase in
the turbidity of the receiving water.
Toxicity Testing Req.: Acute, Episodic Monitoring (see attached)
---------------------------- MONITORING -------------------------------------
Upstream (Y/N): N Location: 6=v&_L�«�
Downstream (Y/N): N Location,
'—
own f* ~��������~
`~� �ymu� �^~~' `
- "~^� '
`COMMENTS ----- '----' -------------------------
Recommend flow monitoring ll volumes of wastewater leaving the facility.
Recommend 2/month monitori r oil & grease, settleable solids, pH, phenols,
and turbidity. Recommend monitoring for benzene, toulene, and xylene be done
on the same schedule as toxicity monitoring (1st 5 discrete discharge events).
A reopener clause should be placed in the permit to allow for limits to be
placed on toxicants should the facility fail its whole -effluent toxicity test.
___________________________________________________________________________
7\
Recommended by: ............ _________ Date: _^�����ei______
Reviewed by
Tech Suppoupervisor:
�
'8Regional Supervisor:
Permits & Engineering:
ate:
Date:
Date:
MAY----+~~-~��~-�---~---MAY-------/ 14 ^9�wD�
RETURN TO TO TECHNICAL SERVICES BY: ___________________

ACUTE TOXICITY TESTING REQUIREMENT
Daphnid 48 hr - Monitoring for Episodic Events
The permittee shall conduct FIVE acute toxicity tests using protocols defined in E.P.A. Document
600/4-85/013 entitled "The Acute Toxicity of Effluents to Freshwater and Marine Organisms".
The monitoring shall be performed as a Daphnia Dulex or Ceriodaphnia 48 hour static test, using
effluent collected as a single grab sample. Effluent samples for self -monitoring purposes must be
obtained below all waste treatment. Sampling and subsequent testing will occur during the first five
discrete discharge events after the effective date of this permit.
The parameter code for this test if using Daphnia ulex is TAA3D. The parameter code for this test
if using Ceriodaphnia is TAA313. 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, DEM Form AT-1 (original) is to
be sent to the following address:
Attention: Technical Services Branch
North Carolina Division of
Environmental Management
P.O. Box 27687
Raleigh, N.C. 27611
Test dam 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 Environmental Management 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.
Failure to submit suitable test results will constitute a failure of permit condition.
7Q10 O cfs
Permitted Flow — � 6 MGD
IWC% ti 4
Basin &Sub -Basin D 3 0 6 0 b
Receiving Stream U i {, Fa,+ Fo, k Ote, Re'jer
County L— , I G �
Recommended by:
Xlk i - S
Date
"Acute Toxicity(Daphnid 48 hr) Monitoring, EPISODIC, See Part 3 , Condition l

A

LlM-;fs
�To %4- To r k -Deef 2, ✓c r
WSm
ODAITn �j u< , -k
O"I d` 6K0.sL (MA/O 30 60
SeNt-Wt soles (MI/1) I o•z
H (SUS 6-q
1001
TixrLj,.' y
CpMMd�l
1 1}I r +6i-M 4tCAnC4 � j( 0.s
a(G 'ioC k _ TS9M fk PtS eat 14"dOZ
r- Rtcommel; ' qvj moll4of.�� -ter al( 001,4,VV5 of „qS4-f wine r ICAJ�✓'� 4,, -Qc;l,f
\\�C.O M^'�.(/I� Z/MOn(,1 ✓rl O'l fin �Jr ��1 P �Kn� / SQ itA6IC
��tnu�s Qv4 `�C�i C1'�� l\CiJMml/�� MO✓1 YOf:jitq ? Ot �ZC✓lt
ml Zy�e a ILL A0r-L 'fhn fro`^ S(J,(A Il K$ ToJC C-, MDn/T�
tit
A, reorne-r c�ausc �%oNl� �Ru� �n fivL �� �b allow �or
I�J+�� 40 �(- D(OLot� oo *aKc'C4✓ITS �h6UIs tb�, C�Z,((�y t••�I !IS

So pC4rcr <<,un
�S r.rhern A tlrbr aw itivcr r
Co
H
B. -ke i LQke Br M1 \ o
� 1Q BraDdt\0
co
Gt e�0 / to YANC[ C
0
�S o ` so fi
se Rrchlan Mr!! poJ Ree�'/,F Cr r
d ke
�g Cr �Q Bv�lalo
v p k N gull °
G\ I6O41hern � � Bur Lake Cr �
v o GRE
l p � SeOR0
Loke n $uJf a70
s
a lamance Cr
PO N , es �y G
T D Cr make
311 \ram°c0 � � Ji
L to
Prong
J✓ oJe¢4t
oa 0802 �
� 10 Statute Afiln 4 '
o !rry ton Deep / toptad
Bpgl INST Q
n /
� I
If
e 9 �
a larrt o sff`rr of
e
i
/Stinki rt
Gr \et Gt Cr °� Sevenfiile C
Quarte QLLpr `
r G Cr l
Vrnats

DIVISION OF ENVIRONMENTAL MANAGEMENT
November 10, 1988
MEMORANDUM
TO: Aurthur Mouberry
C_
FROM: Trevor Clements
Mike Scoville
THRU: Steve Tedder
SUBJECT: DRAFT Permit Comments from Pillips Pipeline Company (NPDES #
NCO032883, Guilford County)
Technical Services has reviewed Mr. T.R. Stall's comments regarding the
NPDES Draft permit for the Phillips Pipeline Greensboro terminal. Responses
to his comments are listed below:
1. Acute Toxicity:
A whole effluent toxicity testing requirement is routinely given to
oil terminal facilities based upon Division procedures for evaluat-
ing complex wastewaters. The testing is necessary to reduce the
uncertainty that exists as to the seriousness of the impact of these
discharges. Note that the requirement is for acute toxicity testing
for episodic events and that there is no chronic target.
2. Phenols:
The phenols limit is a water quality standard and should not be
deleted from the permit. Phenol limits are placed on discharges to
WSIII waters to protect the downstream water supply from taste and
odor problems. The assimilative capacity of this system with
respect to the downstream water supply water quality standard has
been allocated among the existing permitted dischargers equally.
Due to the number of dischargers on the East Fork Deep River and the
interaction of their -effluents it is very important that each facil-
ity receive and comply with a phenols limit to restrict the allow-
able phenols loading.
3. Settleable Solids:
The settleable solids parameter was added to the list of North Caro-
lina water quality standards specifically with discharges from set-
tling ponds in mind. This limit is applied uniformly to stormwater
retention pond discharges and is very appropriate for for oil termi-
nal facilities. A limitation on solids discharge should not be
dropped from the permit, although Technical Services would not
object to a TSS limit of 30 mg/l if Phillips would accept it in lieu
of the settleable solids limit.

4. Turbidity:
The turbidity requirement is also a water quality standard appli-
cible to these types of discharges and should not be deleted from the
permit. Since Phillips Pipeline Company discharges to the headwat-
ers of a UT to the East Fork Deep River, it is likely that there
will be discharge events when there is zero flow upstream. Because
of this fact, Technical Services recommends that the turbidity limi-
tation be applied directly to the effluent. "The turbidity of the
discharge shall not exceed 50 NTU."
5. Flow Measurement and Frequency Type
Since Phillips discharges to WSIII waters and it's discharge inter-
acts with numerous other oil terminal discharges, it is essential
that DEM have accurate discharge flow measurements to determine
total loading to the East Fork Deep River and thus to assure ade-
quate protection of the downstream water supply. Phillips has con-
cluded that the "best method of providing reasonable flow data" is
through "estimation based on established and accepted engineering
techniques." However, in order for any changes to be made in their
flow monitoring requirements Phillips must first provide details of
their proposed methods to DEM. DEM will determine the appropriat-
eness of the flow estimation techniques and will agree or disagree
to permit changes accordingly.
Please let me know if you have any questions or comments regarding these
matters.
cc: Dale Overcash
Winston-Salem Regional Office
t�
i

STA7F
NOV
TCHNIC',AL SERVICES S A'KP
State of North Carolina
Department of Natural Resources and Community Development
Division of Environmental Management
512 North Salisbury Street • Raleigh, North Carolina 27611
James G. Martin, Governor R. Paul Wilms
S. Thomas Rhodes, Secretary October 27, 1988 Director
Mr. T. R. Stall
Environmental Control
Phillips Petroleum Company
12 A2 Phillips Building
Bartlesville, OK 74004
Subject: DRAFT Permit Comments
NPDES No. NC0032883
Phillips Petroleum Company
Guilford County
Dear Mr. Stall:
This letter is to acknowledge receipt of your letter dated October 11, 1988,
containing comments on the subject DRAFT Permit. The Division of Environmental
Management will consider your comments in making its decision on the issuance of the
permit. If you feel that your comments are not addressed in the issued permit, you
may request an adjudicatory hearing in accordance with Chapter 150B of the General
Statutes of North Carolina within 30 days of issuance of the permit.
If you have any questions, please contact me at [phone].
Sincerely,
9. a L�
M. Dale Overcash, P.E.
Supervisor, NPDES Permits Group
cc: Mr. Larry Coble (with attachments)
Mr. Trevor Clements (with attachments)
smk
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

PHILLIPS PIPE LINE COMPANY
GREENSBORO TERMINAL
COMMENTS ON DRAFT NPDES PERMIT NCO032883
Phillips Petroleum Company, on behalf of Phillips Pipe Line Company, submits
the following comments on the draft NPDES permit for the Greensboro Terminal.
General Facility Information
Facility Function
Phillips believes it is important to clearly understand the operations of the
Greensboro Terminal so that appropriate effluent limitations and permit
conditions can be established for the facility. Greensboro Terminal is a
facility that receives refined petroleum products by pipeline, stores these
products temporarily in product storage tanks and distributes these products
by transport truck to various distributors for eventual sale to the public.
Greensboro Terminal does not refine, treat or otherwise process crude oil or
any intermediate petroleum product. The facility, therefore, does not
generate process wastewaters other than occasional drainage of water from the
product storage tanks. Greensboro Terminal discharges primarily excess
stormwater that accumulatcs inside the diked storage tank areas. The terminal
also discharges stormwater that falls onto the covered truck loading dock pad
and the small quantity of water used at the facility to wash down the loading
dock pad.
Hours of Operation
The facility is manned S days per week, 8 hours per day. Because the product
loading system is automated, the facility is open 7 days per week, 24 hours
per day to qualified distributors. Transport truck drivers are carefully
trained to conduct loading operations at the Terminal in a safe manner.
Additional training of these drivers is done at scheduled intervals so that
loading operations are carried out safely.
Stormwater S stem_
As previously mentioned, the product storage tanks are located within areas
surrounded by earthen dikes. Three such diked areas exist at the Terminal.
The primary purpose of these diked areas is to provide a containment area for
the stored products in the unlikely event of a tank rupture, line break or
similar incident. As these areas retain the stormwater falling within the
dikes, they occasionally must be drained of water so that their emergency
product containment function is preserved. While such stormwater contacts the
outside of the product storage tanks, piping and similar equipment, it does
not come into direct contact with the stored product. Therefore, the chance
of significant stormwater contamination is slight.
Stormwater and washdown water from the truck loading dock is treated in an
oil -water separator with the water effluent routed to the diked area from
which Outfall 001 originates. It is possible that some hydrocarbon product
remaining in the water effluent at a low parts per million range may contact
the accumulated stormwater. Phillips believes that routing of such effluent
to a diked area is environmentally sound in that it provides a temporary

Phillips Pipe Line Company Page 2
Greensboro Terminal
NPDES Permit No. NCO032883
holding area for the separator effluent so that it can be visually checked for
the presence of hydrocarbons prior to release.
All waters released from the three diked storage areas are checked visually
for the presence of hydrocarbon products prior to release in accordance with
written procedures required by the facility's Spill Prevention, Control and
Countermeasure (SPCC) Plan. Traces of floating hydrocarbons are removed prior
to release. Phillips believes that in view of the low solubility of these
products in water and the time allowed for physical separation of the
hydrocarbon from the water in the diked areas, terminal discharge offer an
extremely low potential for adverse impact on receiving waters.
Comments on Specific Permit Conditions
The following comments on the specific draft permit conditions should be
considered in light of the above facility information and the limited
potential for adverse environmental impact resulting from the facility's
discharge. These comments apply to all three outfalls (001, 002 and 003)
unless otherwise noted.
A Acute Toxicity
While Phillips supports the goal of eliminating or limiting toxic
discharges to the waters of the United States, we believe that reasonable
judgement must be exercised in achieving this goal.
Measurement of acute toxicity of wastewater is not a straightforward or
precise technique. Acute toxicity testing is both a time consuming and
costly procedure. Phillips, therefore, believes that acute toxicity
testing should not be required of every discharger. Monitoring of
effluent toxicity is appropriate for major municipal or industrial
dischargers (such as a petroleum refinery) whose discharge may contribute
significantly to the amount of toxic pollutants in a waterway. We do not
believe that such monitoring is necessary or appropriate for a product
terminal's stormwater discharge. The Greensboro Terminal's discharges
are primarily stormwater and generally are only slightly contaminated.
Such discharges do not contain process wastewater which could be a
significant source of toxic pollutants. The Greensboro Terminal's
stormwater effluent is a minor source of discharge to the receiving
streams and does not represent a significant threat to the water quality
of those receiving streams.
Toxicity testing is not a mandatory requirement for NPDES permits. The
Agency has the discretion to require whole effluent toxicity testing when
appropriate. Phillips believes that whole effluent toxicity testing is
appropriate only for potentially significant contributors of toxic
pollutants. Clearly, Greensboro Terminal is not a potentially
significant contributor of toxic pollutants to the waters of the State.
Phillips encourages the State to prioritize its requirements for whole
effluent toxicity testing in a manner consistent with other states and
EPA Regional offices. Such prioritization, in descending order for
toxicity testing requirements, follows:

Phillips Pipe Line Company
Greensboro Terminal
NPDES Permit No. NC0032883
Page 3
1. Major industrial, municipal and federal facilities.
2. Selected minor industrial and federal facilities associated with
toxic problems.
3. Selected minor municipal facilities associated with toxic
problems.
4. Other minor municipal facilities.
5. Other minor industrial facilities.
Phillips believes that Greensboro Terminal clearly falls in the last
category and should not be required to perform the requested acute
toxicity testing because:
1. Greensboro Terminal is not a major industrial facility.
2. Greensboro Terminal is not a major contributor of wastewater to
the receiving streams.
3. Greensboro Terminal is not a facility associated with toxic
pollution problems.
4. Greensboro Terminal does not employ processes or operations that
result in significant contributions of toxic pollutants to its
discharges or the receiving streams.
Phillips therefore requests that the requirement to pel N
toxicity tests on the first five discrete discharge evE D�
from the final permit. V
B . Phenols
Phillips recognizes that the State maintains the followJ. NG�
compound requirements for Class WS-III waters: �y „�
Phenolic compounds: not greater than 1.0 ug/L (phenols) to protect
water supplies from taste and odor problems from chlorinated
phenols; specific phenolic compounds may be given a different limit
if it is demonstrated not to cause taste and odor problems and not
to be detrimental to other best usage.
Phillips believes that the historic effluent monitoring data generated by
the Greensboro Terminal has shown that the quantity of phenols in the
facility's discharges are insignificant in view of the Class WS-III
requirements. This is especially true since such discharges are
intermittent and infrequent.
Greensboro Terminal operations do not add phenols to the wastewater by
any manufacturing process. Phenols exist in the facility's stormwater
only to the extent that such stormwater comes into limited contact with
hydrocarbon product. Since contact with hydrocarbon product is minimal,
the potential for significant phenol levels in the stormwater should be
very low.

Phillips Pipe Line Company
Greensboro Terminal
NPDES Permit No. N00032883
Page 4
Phillips also notes that the proposed phenol limit is greatly reduced
from the existing permit limitations of 0.0012 pounds per day daily
average and 0.0024 pounds per day daily maximum. The proposed permit
limit places the Terminal in a very difficult compliance position.
First, the proposed limit requires the facility to measure the flow with
a high degree of accuracy which exceed the capabilities of proven
measurement equipment operating in actual field installations. Secondly,
the proposed limit requires that the phenol concentration be at or very
near the detection limit of the phenol test procedure to achieve
compliance. For instance, if the Terminal's discharge volume was 35,000
gallons per day, a phenol concentration of less than or equal to
3.4 parts per billion is required to be in compliance. Clearly, the
proposed permit limit could result in apparent violations due simply to
the inherent inaccuracies of either flow or phenol measurement. This is
not a desirable situation for either the Greensboro Terminal or the
Agency.
Because the potential for significant phenol levels is low. and
historical data indicates the facility's discharges hay �10
significant water quality problems, Phillips requests
limitation for phenols be dropped from the final permi
a requirement to measure and report the phenol concent: G,,��-�w���.
Such a requirement will allow the Agency to revise the C
future should a phenol problem develop. t47 Q n�
C. Settl
0
The draf- U _e solids in the Greensboro Terminal's
discharg al effluent limitation for a product
termina' -k; acL�`� ppropriate to limit settleable solids for
a munic 1 arger which employs some type of
biologi 3p ise adds settleable type solids to the
wastew� )ro Terminal neither employs such treatment
nor otnc... solids. Here, the principal settleable
solids are prime _ : particles such as soil or dirt
(essentially nonvolatile anded solids). In the diked areas, the
stormwater is retained long enough for this material to settle. However,
the stormwater is not retained long enough for algal growth or any other
biological material (if it would grow at all) to develop.
Therefore, Phillips requests that the requirement to measure and report
settleable solids and the specified effluent limitations for this
parameter be deleted from the final permit.
D. Turbidity
As with the settleable solids effluent limit, this is a most unusual
requirement for a terminal permit. Please refer to arguments presented
for settleable solids as they apply to this parameter also.

Phillips Pipe Line Company
Greensboro Terminal
NPDES Permit No. NCO032883
Page S
The specified turbidity requiremei � in the State s
water quality standards which are pater bodies in
the State. It is not necessary to tULDICllty water quality
standard as a permit condition. Phillips, therefore, requests that this
parameter be deleted from the measurement and reporting requirements of
the final permit.
E. Flow Measurement Frequency and Sample Type
It is unclear from the draft permit wording what is being proposed for
flow measurement frequency and sample type. Phillips has interpreted the
draft permit to require either (1) continuous flow measurement with flow
recording or (2) weekly flow measurement with flow totalization.
Phillips believes that neither requirement is inappropriate for the
Greensboro Terminal's discharges.
In setting an appropriate monitoring requirement for flow, reasons for
requiring flow measurement and the required accuracy of this measurement
must be considered. Since a daily mass limit for the discharge of
phenols has been proposed, it could be that the Agency intends the flow
measurement will provide a basis for making the mass calculation. It
should be noted, however, that the proposed mass limit for phenols is
only 0.001 pounds per day (an extremely small quantity of material). For
a meaningful calculation, this would require an exceptionally high degree
of accuracy in the flow measurement. Phillips believes that this purpose
could be achieved without requiring continuous measurement and flow
recording or totalizing.
The Agency's proposed flow measurements are not appropriate for the
Greensboro Terminal's discharge. The following points should be
considered in establishing this facility's flow measurement requirement:
1. The discharges are intermittent (not continuous) and are
relatively infrequent.
Intermittent discharges pose technically difficult problems in
flow measurement. Instrument calibration is significantly more
difficult to maintain. The infrequent nature of the discharge
(seasonal variations resulting from rainfall and evaporation)
complicates this matter also.
Continuous discharges better lend themselves to continuous flow
measurement. Instruments in constant use yield better
measurement accuracy simply because they are in constant
operation.
2. The flowrate through each valved outlet pipe is a function of the
water head in the diked storage area which decreases with time.
Therefore, flow measurement devices requiring differential head are
unsuitable for such measurement.
Flowmeters such as Parshall flumes, weirs or other similar type
devices could be used in such measurement service but with
certain restrictions. Because of the very small flows to be
measured, the primary elements will be very small. These small

Phillips Pipe Line Company
Greensboro Terminal
NPDES Permit No. NCO032883
Page 6
v P CON X
elements will be extremely sensitive to
from ideal measurement conditions. The
be it a float or ultrasonic device, will
difficulty operating in a non -continuous
Floats will stick or become balky, which
data. Ultrasonic devices become fouled,
poor data.
the slightest deviation
level detection device,
have inherent
mode of operation.
will lead to erroneous
which also leads to
Flow totalizers and recorders perform best when operating on
continuous flow streams. Long periods in inactivity inherently
lead to inaccurate measurement even with the closest of
maintenance.
3. Since each discharge comes from a very limited, well-defined
area, it is possible to estimate the maximum quantity of stormwater
available for discharge during any given discharge event.
This estimate alone should be of sufficient accuracy for
whatever purposes the Agency desires to use the flow
information.
4. The discharge from each outfall occurs only during periods when
the facility is manned.
As previously mentioned, the primary function of the diked
storage areas is to provide spill containment in the unlikely
event of a product loss from a tank or associated piping. The
outlet valves are closed and locked at all times when the
facility is unmanned to provide this protection. Therefore,
the stormwater discharge from an outfall will be no longer than
approximately 8 hours on any given day.
_ore, Phillips
reasonable flow data
based on established
is currently making
must conclude that the best method of providing
for the three outfalls is through flow estimation
and accepted engineering techniques. The facility
such estimates.
Phillips must point out that at Phillips 66 Company's major refineries,
where stormwater discharges are many times larger than those from the
Greensboro Terminal, have no obligation to measure and record flow.
These refinery facilities, at most, record the number of days each month
that a stormwater discharge occurs.
Phillips requests that the proposed measurement frequencies and sample
types be dropped and replaced with the following requirements:
Measurement Frequency: When Discharging.
Sample Type: Instantaneous (By estimation).
Phillips believes that these requirements are appropriate for the
Terminal's discharge and provides the Agency with sufficient information
for monitoring purposes.

Facility Name:
NPDES WASTE LOAD ALLOCATION
ITAN07 �
m �z
`�* a 7
Date:
E
o
v
Existing
I (�' �
Permit No. da�00 32 8$3 PipeNo.:00,002,00S County: 6tji c
o
Proposed
-'
Design Capacity (MGD):
Industrial (% of Flow): 10 O c Domestic (% of Flow): _
O
Receiving
Stream: � A � �
((11
&^kl 12Qp �� �`- Class: Sub -Basin: C)2 - 06 — 0 22
R
C
Reference
USGS Quad: �-
8 �C.J (Please attach) Requestor_. 45 1`� 1 Office
(Guideline limitations, if applicable, are to be listed on the back of this form.)
Design Temp.: Drainage Area: Avg. Streamflow:
7Q10: Winter 7Q10: 30Q2:
r'
� Location of D.O.minimum (miles below outfall): Slope:.
E Velocity (fps): Kl (base e, per day, 200C): K2 (base e, per day, 200C):
0
Effluent
Characteristics
Monthly
Average
Comments
6- ?, J`,
&nc)l
0, 00la
#
r) by5
i/
Effluent Monthly
Characteristics I Average I Comments
Original Allocation F]
Revised Allocation El_ Date(s) of Revision(s)
(Please attach previous allocation)
po
!� Prepared By:
i
Reviewed By:!>>> C.� Date: 7����
V

For Appropriate Dischargers, list Complete Guideline Limitations Below
Effluent Monthly Maximum Daily
Characteristics Average Average Comments
Type of Product Produced Lbs/Day Produced Effluent Guideline Reference

NPDES WASTE LOAD ALLOCATION
a
Facility Name: �� `� D5 '
R� ��^'�-�'Y`+'
Date:
CL
EExistingQ
Permit No.:
\\
Pipe No.: County: C'U , t t�
Proposed
Design Capacity (MGD):
Industrial (% of
! Oy�� c�
Flow)Domestic (% of Flow:. )
Receiving Stream: f.-7- 1Yt'ksP.J ( eke- -L
Class: Sub -Basin:
i
c
C- ��
Reference USGS Quad: �
(Please attach)
L s Office
Requestor• •
(Guideline limitations, if applicable, are
to be listed on the
back of this form.)
04)
Design Temp.: Drainage Area: Avg. Streamflow:
7Q10: Winter 7Q10: 30Q2:
Location of D.O.minimum (miles below outfall): Slope:.
Velocity (fps): Kl (base e, per day, 200C): K2 (base e, per day, 200C):
Effluent Monthly
Characteristics Average Comments
1
I
Effluent Monthly '
Characteristics Averaize Comments I
Original Allocation
Revised Allocation Date(s) of Revision(s)
(Please attach previous allocation)
Prepared By: Reviewed By:
Date:

For Appropriate Dischargers, list Complete Guideline Limitations Below
Effluent Monthly Maximum Daily
Characteristics Average Average Comments
Type of Product Produced Lbs/Day Produced Effluent Guideline Reference

x REQUEST NO. : 427
WASTELOAD A►_LOCATION APPROVAL FORM ***************
FACILITY NAME
TYPE OF WASTE
COUNTY
REGIONAL OFFICE
RECEIVING STREAM
7010 : 0 CFS
DRAINAGE AREA
PHILLIPS PIPELINE CO
OIL STORAGE
GUILFORD
: WINSTON—SALEM
EAST FORK DEEP R
W7010 :
: 0.1 SO.MI.
REQUESTOR : LAVE ADKINS
SUBBASIN : 03-06-02
CFS 3002 : CFS
STREAM CLASS :Ail
*********************** RECOMMENDED EFFLUENT LIMITS
WASTEFLOW(S)
BOD-5
NH3—N
D.O.
PH
FECAL COLIFORM
TSS
PHENOL
( MGD )
: <0 .005
(MG/L)
: —
( MG/L )
: --
(MG/L)
: —
(SU)
: 6-8.5
(/100ML):
—
(MG/L)
: —
LBS/D
: 0.0012
OIL AND GREASE:
10 MG/L DAILY AVG
15 MG/ L DAILY MAX
PLEASE SEE THE ATTACHED MEMO
FOR A DISCUSST.ON OF THE PHENOL
LIMITAIONS.
FACILITY IS : PROPOSED ( ) EXISTING (--) NEW ( )
LIMITS ARE : REVISION ( 'CONFIRMATION ( ) OF THOSE PREVIOUSLY ISSUED
REVIEWED AND RECOMMENDER BY:
MODELER
SUPERVISORrMODELING GROUP
REGIONAL SUPERVISOR
PERMITS MANAGER
APPROVED BY :
DIVISION DIRECTOR
--�--- — — — ---__DATE
LIIdC+ DATE :
_DATE :
j y
9 A— --------- DATE
LATE/7/4
3

MEMO.-
D
TE: -
TO: SUBJECT:
eYr �c0 5��
/"---l-7
,Abli North Carolina Department of Natural
V4W Resources &Community Development

DIVISION OF ENVIRONMENTAL MANAGEMENT
May 24, 1983
M E M O R A N D U M
TO: Russell Radford, Supervisor
Winston-Salem Regional Office
FROM: Meg Kerr /�
SUBJECT: Phenol Limitations for Guilford County
Oil Terminal Facilities
My notes indicate that twelve different oil storage facilities
discharge into the East Fork Deep River above High Point Lake. The
7Q10 above the lake is estimated to be 2.63 cfs. With an allowed
instream concentration of 1.0 ug/l, 0.014 #/d of phenols can be allowed
in the headwaters of the lake. This loading was equally distributed
among the twelve dischargers, so each is allowed 0.0012 #/d of phenol.
Effluent limitations were based on this calculation.
MK:cs