NC0022209_Comments on Draft Permit_20161107

VIA Email and UPS No. 1 Z71 E42VO294029149
November 07, 2016
Mr. Derek Denard
NC Division of Water Resources
Water Quality Permitting Section — NPDES
1617 Mail Service Center
Raleigh, NC 27699-1617
Re: Comments on Draft NPDES Permit NCO022209
Motiva Enterprises LLC -- Greensboro Terminal
101 South Chimney Rock Road, Greensboro
Dear Mr. Denard:
M®T'VA
ENTERPRISES LLC
RECEIVEMCDENWR
NOV 0 7 2016
Water Quality
Permitting Section
Motiva Enterprises LLC (Motiva) is providing the following comments on Draft NPDES Permit
NCO022209 received via email on October 4, 2016. As stated in your letter dated October 5,
2016, Motiva has made no significant changes to the facility since the last permit renewal and
has had no compliance issues; therefore, Motiva is requesting removal of the new limits and
analysis added to the draft permit. The additional limits create an added burden to the facility
that is not warranted by our historical compliance record.
The addition of the monthly average limit of 30.0 mg/L total suspended solids (TSS) is
effectively lowering the daily maximum from 45.0 mg/L to 30.0 mg/L since sampling is only
required once per month. Furthermore, the 30.0 mg/L TSS level is extremely low compared to
the United States Environmental Protection Agency (EPA) Multi -Sector General Permit (MSGP)
benchmark of 100 mg/L, which the EPA deems appropriate for compliance monitoring of
stormwater discharge from petroleum terminals. Motiva maintains that the current TSS limit is
protective of the receiving stream and the waters of the state of North Carolina and requests
that a more stringent limit is not added to the permit for TSS.
The addition of the turbidity analysis requirement is not warranted as the receiving stream is a
dry creek bed with intermittent flow and often zero flow and, therefore, does not support a fish
population. The existing 45.0 mg/L daily maximum TSS limit provides sufficient protection of
aquatic life in the receiving stream. Motiva requests that the turbidity analysis not be added to
the permit. Alternatively, if turbidity analysis must be added, it should be as a "monitoring only"
parameter as the EPA MSGP includes a benchmark level only for turbidity.
101 S Chimney Rock Rd
Greensboro, NC 27409
Phone: [phone]

Page 2: Comments on Draft NPDES Permit No. NCO022209
Motiva Enterprises LLC Greensboro Terminal
Thank you for the opportunity to provide comments on the draft permit. If you have any
questions, please contact Jennifer Bothwell, Environmental Coordinator at 860-749-2839 or
email Jennifer. bothwell(cD-motivaent.com.
Very truly yours,
MOTIVA ENTERPRISES LLC
Otto Muha�
Terminal Superintendent
Cc: J. Bothwell, Motiva
File: 550-04