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HomeMy WebLinkAboutNC0027006_Draft Permit_20031112^QO Dear Mr. Rhode: The Division made the following changes to your new permit on the bases indicated. N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 (919) 733-7015 Ray Rhode ExxonMobil Oil Corporation 2555 West Oak Street Selma, North Carolina 27576 In 2001 the Division of Water Quality (the Division) revised permitting strategies and standard operating procedures (2001 SOP) for this and for all bulk-storage petroleum facilities and terminals in North Carolina. As part of your permit renewal, the Division has also conducted an EPA-required Reasonable Potential Analysis on this facility's effluent data to determine the "reasonable potential" for identified parameters to exceed North Carolina in-stream water quality standards and/or federal criteria. Nitrogen and phosphorus. The Division reviewed data reported during the previous permit cycle, and concluded that there was sufficient data to support a decision to discontinue monitoring these two nutrients. ERA Method 624. As provided by the 2001 SOP, the Division reviewed data reported during the previous permit cycle, and concluded that there was sufficient data to support a decision to discontinue monitoring for these constituents. BTEX constituents. No change from the previous permit is proposed for benzene and toluene. Monthly monitoring of ethylbenzene has been added based on the provisions of the 2001 SOP. Monitoring requirements for xylene have been changed from semi-annual to monthly, in accordance with the 2001 SOP. Subject: Draft NPDES Permit No. NC0027006 ExxonMobil Selma Terminal 2555 West Oak Street, Selma Johnston County NCDENR Customer Service 1 800 623-7748 Michael F. Easley Governor William G. Ross, Jr. Secretary North Carolina Department of Environment and Natural Resources This letter transmits your draft NPDES individual discharge permit for the above referenced facility. Please review this draft carefully to ensure thorough understanding of the information, conditions, and requirements of dischargers to water supply waters contained therein. A MTBE. Monthly monitoring of MTBE has been added based on the 2001 SOP. After collecting additional data, ExxonMobil may request a reduction in the MTBE monitoring frequency as described in the permit text. Granting the request shall constitute a minor modification to the NPDES permit. Alan Klimek, P. E., Director Division of Water Quality November 12, 2003 Flow. Based on the 2001 SOP and the sporadic nature of the discharges from the facility, the Division has changed the flow reporting requirement from monthly to episodic. In months with no discharge, we still require submission of the Discharge Monitoring Report with the notation, "No Discharge". Respectfully, Enclosure: NPDES Permit NC0027006 cc: The previous permit requirements for TSS, oil & grease, EPA Method 625, and toxicity testing remain unchanged. Lead. The Division reviewed data reported during the previous permit cycle and concluded that there was sufficient basis to remove the lead limit. The monthly monitoring requirement remains. Following the 30-day public comment period, the Division will review all pertinent comments and take appropriate action prior to issuing a final permit. If you have questions concerning the draft, please call me at (919) 733-5083, extension 584, or you may E-mail me at ken.pickle(g)ncmail.net. Phenol. The Division has added a permit limit and monthly monitoring requirement for phenol based on the data reported during the previous permit cycle and the 2001 SOP. NPDES Unit: [Draft Permit; Fact Sheet] Aquatic Toxicology Unit: [Draft Permit; Fact Sheet] DEH: [Draft Permit; Fact Sheet] Mr. Ray Rhode Page 2 11/12/03 With this notification, the Division will solicit public comment on this draft permit by publishing a notice in newspapers having circulation in the general Johnston County area, per EPA requirements. Please provide your comments, if any, to DENR / DWQ / NPDES Unit no later than 30 days after receiving this draft permit. Ken Pickle NPDES Unit Permit NC0027006 DRAFT PERMIT ExxonMobil Oil Corporation is hereby authorized to discharge wastewater from one outfall located at the This permit shall become effective.2003. This permit and authorization to discharge shall expire at midnight on March 31, 2008. Signed this day 2003. to receiving waters designated as an unnamed tributary of Mill Creek within the Neuse River Basin in accordance with effluent limitations, monitoring requirements, and other conditions set forth in Parts I, II, III and IV hereof. 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, STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES DIVISION OF WATER QUALITY TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) ExxonMobil Selma Terminal 2555 West Oak Street Selma, North Carolina Johnston County DRAFT Alan W. Klimek, P. E. Division of Water Quality By Authority of the Environmental Management Commission Permit NC0027006 DRAFT SUPPLEMENT TO PERMIT COVER SHEET ExxonMobil Oil Corporation is hereby authorized: 1. 2. 3. 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. to continue to operate the existing Water Pollution Control System consisting of: • two oil/water separators, • an aerated pond, and • v-notch weir located at the ExxonMobil Selma Terminal, 2555 West Oak Street, Selma, North Carolina; to continue to discharge stormwater runoff from the aboveground storage tank containment area, the yard, the truck loading rack, and the product pump area via Outfall 001; to discharge at the locations specified on the attached map into an unnamed tributary to Mill Creek in the Neuse River Basin, a WS-IV NSW class stream. asoneK ExxonMobil Oil Corporation North Sub-Basin: 03-04-02 Stream Class: WS-IV,NSW Drainage Basin: Neuse River Basin it 1 Facility Location not to scale Outfall 001 (flows south) 35° 33’ 02” N 78° 18’ 44” W NPDES Permit No. NC0027006 _____Johnston County______ G W ' - r S vj'- / H > >i II II n U Sewage------~4-‘ — Disposal Y1900 f!'* V" Z ~.. Jf'’ a. ' > X ! /( \ J ' Nsq- N '"-''^ssgk^ Selma Terminal State GricVQuad: E 25 SE / Selma, NC Permitted Flow. Episodic - not limited Receiving Stream: UT of Mill Creek \ 8 X P'f ' '''■/ //X; >1 tA JXA / (v / o \ 'A Permit NC0027006 A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 45.0 mg/L 0.118 Ibs/day 1. 2. 3. 4. Beginning on the effective date of the permit and lasting until expiration, the permittee is authorized to discharge from Outfall 001. Such discharges shall be limited and monitored by the permittee as specified below: The permittee shall not discharge floating solids or foam visible in other than trace amounts. The permittee shall not discharge tank solids, tank bottom water, or the tank rag layer. The permittee shall not discharge tank (or pipe) contents following hydrostatic testing unless benzene concentration is less than 1.19 gg/L and toluene concentration is less than 11 /ig/L. EFFLUENT CHARACTERISTICS Daily Maximum a. b. DRAFT PARTI c. d. I. 19 ug/L II. 0 ug/L Sample Type 1 Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Flow1_____________ Total suspended solids Oil and grease2______ Benzene___________ Toluene___________ Ethylbenzene_______ Xylene____________ Phenol_____________ MTBE3____________ Lead______________ EPA 625___________ Acute toxicity4 LIMITS Monthly Average Footnotes: Flow - During periods of no flow, the permittee shall submit a monthly Discharge Monitoring Report (DMR) indicating “No discharge." Flow shall be monitored with each discharge event and may be monitored in one of four ways: measure flow continuously; Rational Method — calculate flow based on total rainfall per area including built-on area draining to the outfall (This method shall not be used at sites with large runoff-collection ponds); estimate flow at 20-minute intervals during the entire discharge event; or report flow based on discharge pump logs. Oil and Grease - Where possible, the grab sample for oil and grease should be skimmed from the surface of a quiescent (calm water) zone. MTBE - See section A. (2.) Effluent Limitations and Monitoring Requirements Special Conditions - MTBE Monitoring for other requirements relating to MTBE. Acute Toxicity - Annual, Fathead Minnow, 24-hour. See section A. (3.) Effluent Limitations and Monitoring Requirements Special Conditions - Acute Toxicity Monitoring I\lONITdRI] Jtflpdsurement //Frequency j / Episodic / / Monthly/7 ^-Monthly Monthly Monthly Monthly Monthly Monthly Monthly ____Monthly 2/Year Annually ING REQUIREMENTS Sample Location Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent Effluent Permit NC0027006 DRAFT 1. 2. 3. A. (2.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS - MTBE MONITORING . The Division anticipates that an MTBE regulatory criterion or Water Quality Standard will be established during the coming permit cycle. For the next cycle of permit renewals, i.e., 2006, the Division expects to apply this criterion or standard to MTBE data collected during this permit cycle. Should the permittee’s MTBE data indicate discharge in excess of this criterion or Water Quality Standard, an MTBE limit will be added to the permit monitoring requirements at renewal. / Monthly monitoring for MTBE (except as modified under 2.) is required for the duration of the permit. See Part A. (1.). If MTBE is detected during the test period, the permittee shall submit an MTBE Reduction Plan. This plan may include site-specific Best Management Practices (BMPs) or engineering solutions. A copy of this plan shall be submitted to: After a one-year test period of monthly monitoring or after twelve (12) discharge events have been sampled and analyzed, the permittee shall review MTBE data. If MTBE is not detected, the facility may request the Division to reduce the MTBE monitoring frequency. Granting this request shall constitute a minor modification to the NPDES permit. North Carolina Division of Water Quality Water Quality Section Attn: NPDES Unit 1617 Mail Service Center RaleighJSlC27699-1^17 --------------------- For the protection of public health, oil terminals discharging to waters classified as water supplies (“WS” waters) shall adhere to the following action plan: Permit NC0027006 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: 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. 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. 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. Attention: North Carolina Division of Water Quality Environmental Sciences Branch 1621 Mail Service Center Raleigh, North Carolina 27699-1621 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. DRAFT A. (3.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS SPECIAL CONDITIONS - ACUTE TOXICITY MONITORING (ANNUAL) 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. Facility Information Applicant/facility name ExxonMobil Oil Corporation /ExxonMobil Selma Terminal Receiving stream and basin Regional office Raleigh Stream classification and segment 001 Lat. 35° 33' 02” Long. 78° I8‘ 44" Introduction Facility Records Review L Summary Information ExxonMobil Selma Terminal - Water Pollution Control System ExxonMobil Oil Corporation (herein referred to as Exxon or the permittee) requires a National Pollutant Discharge Elimination System (NPDES) permit to dispose treated wastewater to the surface waters of the state. The permittee’s 5-year NPDES permit has expired and they have requested renewal from the Division of Water Quality (the Division). This Fact Sheet summarizes background information and rationale used by the Division’s NPDES Unit to determine permit limits and conditions. Facility Description. Exxon operates the ExxonMobil Selma Terminal, a petroleum bulk-storage and fuel­ distribution center in Johnston County. Discharge from the facility is from a single outfall. DENR / DWQ / NPDES Unit FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES Permit No. NC0027006 October 29, 2003 Discharge from Outfall 001 consists of two general flows: stormwater runoff from the AST containment areas and yard, and stormwater runoff and spillage and leakage from the truck rack and product pump areas. The Hows from the AST containment area and the yard drain to the Pinal oil/water separator, to an aerated pond, through a broad-crested v-notch weir, and finally off the property as Discharge 001. The flows from Fact Sheet Renewal - NPDES Permit NC0027006 Page I Applicant address Facility address______ Permitted flow (MGD) Type of waste Facility/pcrmit status County 2555 West Oak Street, Selma, North Carolina 27576 2555 West Oak Street, Selma. North Carolina 27576 Not limited__________________________________ Industrial runoff wastewater. SIC Code 5171 State grid / USGS topo quad Permit writer Date: Grade 1, minor / renewal___________ Johnston________________________ Receiving Water Information 303(d) listed?_______ Subbasin___________ Drainage area (sq. mi.) Summer 7Q10 (cfs) Winter 7Q10(cfs) 30Q2 (cfs)__________ Average flow (cfs) fWC (%) UT to Mill Creek, Neuse River basin___________ WS-1V NSW, 27-40 Not listed 03-04-02 0.1______ 0.0 0.0 0.0 0.0_____ 100 E25SE/ Selma, NC Ken Pickle 29Oct03 Compliance Review Parameter Hits Allowable Comments / Action Flow 43 Benzene 43 5 Yes Xylene 43 7 46 ug/L 885 ug/L No Phenol 43 9 281 ug/L 38 ug/L Yes Oil & Grease 43 4 15 mg/L 30 mg/L No Toluene 43 32 ug/l I I 0 ug/l.Yes6 Lead 43 3 7 3 ug/L 25 ug/l No Verifying Existing Stream Conditions. This facility discharges to a “zero-flow” stream, an unnamed tributary (UT) to Mill Creek, segment number 27-40, a class WS-IV NSW stream within the Neuse River Basin. Mill Creek is not listed as an impaired waterbody in the 2002 Integrated 305(b) and 303(d) Report. the truck rack and product pump areas are directed to a separate oil water separator, then to the final oil/water separator (commingling with the flows from the AST containment and yard), then to the aerated pond, across the v-notch weir, and finally leaving the property with the other flow as Discharge 001. The discharge leaves the property in a ditch at the rear of the property which then enters an unnamed tributary (UT) to Mill Creek. The existing permit became effective September 1, 1999 (with an expiration date of March 31, 2003). On August 22, 2002, the Division received Exxon’s permit renewal request. Fact Sheet Renewal - NPDES NC0027006 Page 2 Max. Predicted Waste Load Allocation (WLA). The Division reviewed the December 1992 WLA that developed effluent limits and monitoring requirements based on an in-stream waste concentration (IWC) of 100% (zero-flow stream). The Division judges these limits and monitoring requirements to be appropriate for this renewal with the exception of the additions and deletions listed below (see PERMITTING APPROACH SUMMARY). RP* y/n Summary of Reasonable Potential Analysis (RPA). The Division conducted an EPA-mandated RPA on Exxon’s reported data for benzene, lead, oil & grease, phenol, toluene, and xylene. Monitoring parameters and the reasonable potential analysis (RPA) results are summarized in Table 1. .369 MGD measured 5 ug/L Max. reported value used lor RPA ________Episodic monitoring._______ Retain permit limit per RPA and 2001 _____SOP. Monthly monitoring. Increase to monthly monitoring per ____________2001 SOP. Assign permit limit per RPA and 2001 _____SOP. Month!) monitoring. Retain monthly monitoring per 2001 SOP._______ Retain permit limit per RPA and 2001 SOP_____________________________ Drop limit based on RPA. Retain No limit — 1.19 ug/L Discharge Monitoring Reports (DMR) - Effluent Data Review. DMRs were reviewed from September 1999 through September 2003. Discharges generally occurred on a regular basis, with occasional months with no discharge related to drought conditions. Those monthly DMRs were submitted with the notation “no flow.” The permittee reported a maximum discharge of 0.369 MGD in August 2000. This maximum flow was used for the reasonable potential calculations (see below). Table 1. Exxon Selma Terminal, Outfall 001 - DMR Review Summary, RPA Results, and SOP Limitations Samples 37 45 nig/L 5/5 0/0 XD/XD Total phosphorus 43 5 Total nitrogen 3943 Notices of Violation (NOVs).No NOVs were issued to this facility during this permit cycle. Permitting Strategy Renewal Facility Inspections. The Raleigh Regional Office (RRO) inspected this facility on October 9, 2002. Significant findings for the purposes of this permit renewal included the following: RRO noted that a phenol limit as a concentration limit rather than a mass limit is preferable. A mass limit is deemed appropriate since the flow is variable and no permitted flow limit is established. Furthermore, previous oil terminal permits have included mass limits on phenol, and the Division will continue this precedent. Whole Effluent Toxicity (WET) Test. The facility has passed an annual acute toxicity test five times during the permit period. One year was skipped (2001). but two tests were conducted in another year (2003). Revised Standard Operating Procedures (SOP). The Division of Water Quality has revised the permitting strategies and the SOP for this and all oil terminals in the state. A new document has been generated by the NPDES Unit entitled, “Permit Requirements for Discharges from Oil and Petroleum Storage Facilities 2001 Permitting Strategy” (based on a 1996 SOP). This document, hereafter referred to as the 2001 SOP. addresses issues and delineates monitoring frequencies and permit limits for contaminants commonly found at these facilities. = “Reasonable Potential” to exceed in-stream Water Quality Standard. = milligrams per liter = micrograms per liter = not detected Fact Sheet NPDES NC0027006 Page 3 TSS________ TOX (1999- 2003) EP/\ 624/625 43 5 Ethylbenzene MTBE *RP mg/L pg/L ND Summary of Compliance Under 2001 SOP. Under the 2001 SOP. flow monitoring will be changed from “monthly” to “episodic” (2001 SOP Part I.A.). This facility’s effluent shall be analyzed monthly (unless there is no discharge during the month) for TSS (I.C.), oil and grease (I.D.), phenol (III.A.), BTEX (I E., I1I.B ), and MTBE (I.I., 1I1.C.). Lead will be monitored monthly. This facility's effluents shall be analyzed twice per year by EPA Method 625 (I.F.). This facility’s effluent shall be tested annually for acute toxicity (I.B.). Footnotes to the Effluent Limits and Monitoring Requirements page shall reflect no direct discharge of tanks solids, lank bottom water, or the tank rag layer. Footnotes will also stipulate no direct discharge monthly monitoring based on 3 hits.____ Retain permit limit based on 2001 SOP. All passed at >100%. Retain per 2001 W ______________SOP._______________ 1 Retain 625 per 2001 SOP. Drop 624 based on no delected constituents. Note that even though Exxon submitted only half of the ten (semi-annually for five years) required analyses, the database is ____________sufficient._____________ Remove from permit based on analysis ___________of database.____________ Remove from permit based on analysis of database.________________________ Add monthly monitoring per 2001 SOP. Add monthly monitoring per 2001 SOP. Flow calculations: of hydrostatic test water if benzene and/or toluene concentrations exceed their respective water quality standard (I.G. and l.H). Given: Flow (30Q2) Neuse River Flow (30Q2) Buffalo Creek Estimated 30Q2 at raw water intake f act Sheet Renewal - NPDES NCOO27OO6 Page 4 Neuse River Basin Nutrient Limitations. Nitrogen. The Environmental Management Commission has established nutrient reduction goals and strategies for the Neuse River basin (I5A NCAC 2B .O232ff). Section 2B .0234(5)(i) provides that dischargers with permitted flows less than 0.5 MGD shall be assigned collectively an annual discharge allocation of 138,000 pounds. For the permit period from September 1999 through September 2003, Exxon has reported only two annual nitrogen totals of 185.2#N/yr (2001) and 29.13#N/yr (2002). These values represent an annual contribution of less than 0.15% and less than 0.02%, respectively, of the annual allocation for this class of permittees (approximately 120 permittees). Data values this low support the NPDES Unit’s internal designation of Exxon’s discharge as a non-nutrient bearing wastestream. Further, the database is sufficient to support the elimination of the nitrogen monitoring and reporting requirement in the current permit. Neither the Division nor the permittee has identified a nitrogen source on this site. No nitrogen limits, monitoring, or reporting are proposed for the new pennit. 219 cfs 0.18 cfs 218.8 cfs (USGS Gauging Station) (USGS data) (Neuse - Buffalo Ck flow) Phenol - Monitoring and Limits Calculations. When combined with chlorine, phenol can cause taste and odor (organoleptic) problems in drinking water, and can also result in the tainting of fish tissues. Therefore, in accordance with the 2001 SOP. all dischargers to state water supply (WS) waters shall conduct monthly effluent monitoring for phenol. Moreover, if analytical results suggest “reasonable potential,” a phenol limit shall be included in the permit. A phenol limit magnitude depends on dilution. Dilution has been calculated at the Smithfield water plant intake where chlorine is introduced. The Division used 1 j-tg/L (the aesthetic limit for phenol) at the raw water intake to calculate a waste load allocation in pounds per day (Ibs./day). Finally, the waste load allocation was distributed equally among phenol dischargers as a permit limit, only as each facility’s data set showed reasonable potential to exceed the water quality stream standard. Currently ten bulk storage facilities discharge to unnamed tributaries to Mill Creek. The Division used published 30Q2 flows from an EPA stream gauge located on the Neuse River at the US Highway 70 bridge in Smithfield. The 30Q2 flow, not the 7Q10. was deemed appropriate because of the aesthetic standard for phenol. Phosphorus. Section 2B .0234(6) establishes a quarterly average phosphorus discharge limit of 2.0 mg/L for two categories of dischargers in the Neuse basin, not including Exxon. However, applying the 2.0 mg/L as guidance as to what level may be significant in supporting the Neuse River basin nutrient reduction goals and strategies is helpful in evaluating the Exxon permit renewal. Exxon averaged less than 0.17 mg/L for the preceding permit period, and only one of the 43 reported values exceeded the 2.0 mg/L quarterly average value applied to other dischargers. Data values this low support the NPDES Unit’s internal designation of Exxon’s discharge as a non-nutrient bearing wastestream. Further, the database is sufficient to support the elimination of the phosphorus monitoring and reporting requirement in the current permit. Neither the Division nor the permittee has identified a phosphorus source on this site. No phosphorus limits, monitoring, or reporting are proposed for the new permit. IM7P Phenol waste load calculation: 1.177 lbs./day distributed among ten dischargers Phenol allocation 0.118 Ibs./day per discharger site Phenol limit Phenol limit 0.118 Ibs./day Permitting Approach Summary 1.177 Ibs./day 10 dischargers Based on a review of the monitoring data from the last permit cycle and per the DWQ/NPDES Unit’s 2001 SOP the following permit renewal decisions are proposed: 0.118 Ibs./day per discharger site 1 outfall at Exxon For Outfall 001: • Add a phenol limit based on the RPA and the 2001 SOP. Monthly monitoring. • Add an ethylbenzene monthly monitoring requirement based on the 2001 SOP. No permit limit. • Add an MTBE monthly monitoring requirement based on the 2001 SOP. No permit limit. • Increase the xylene monitoring requirement from semi-annual to monthly based on the 2001 SOP. No permit limit. • Change the flow reporting requirement to episodic, rather than monthly, based on the 2001 SOP. • Drop the lead limit. Retain monthly monitoring based on three hits during the permit period. • Drop the nitrogen monitoring requirement based on data analysis. • Drop the phosphorus monitoring requirement based on data analysis. • Drop the 624 semi-annual testing requirement based on the 2001 SOP. • Retain the 625 semi-annual testing requirement per the 2001 SOP. No permit limits. • Retain the toluene limit based on the RPA. • Retain the oil & grease limit based on the 2001 SOP. • Retain the TSS limit based on the 2001 SOP • Retain the benzene limit based on the RPA. • Retain the annual toxicib testing requirement based on the 2001 SOP. 218.8 cfs x (0.001 mg/L) x 8.34 1.55 Phenol allocation Fact Sheet Renewal - NPDES NC0027006 Page 5 Based on the RPA and 2001 SOP, the Division has assigned a phenol limit of 0.118 lbs./day as a Monthly Average to Outfall 001 at the ExxonMobil Selma Terminal. A monthly average limit is consistent with the use of the 30Q2 flow for organoleptic parameters. A footnote will be added to the permit allowing the permittee to collect additional phenol data (minimum 12 data points) and petition for a new RPA. Proposed Schedule of Issuance NPDES Unit Contact Name: Date: Renewal Draft Permit to Public Notice: Permit Scheduled to Issue: November 12, 2003. December 27, 2003 If you have questions regarding any of the above information or on the attached permit, please contact Ken Pickle at (919) 733-5083 ext. 584. Fact Sheet NPDES NC0027006 Page 6 Regional Office Comments DATE: Name: Date: Regional Supervisor: Date: NPDES Supervisor: Fact Sheet Renewal - NPDES NC0027006 Page 7