NC0022187_Inspection Response_20180820

RECEiVED/NCDENRIDWR
AUG 2 4 2018
wORGs MOT 1 VA
ENTERPRISES LLC
MOORESVILLE REGIONAL OFFICE
August 20, 2018
Mr. Wes Bell
North Carolina Department of Environmental Quality (NCDEQ)
Division of Water Resources
610 East Center Avenue, Suite 301
Mooresville, NC 28115
Mr. Rusty Rozzelle
Mecklenburg County Water Quality Control Program (MCWQP)
2145 Suttle Avenue
Charlotte, NC 28208
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Re: NPDES Inspection
Motiva Enterprises LLC
Charlotte South Terminal — NPDES Permit No. NCO046892
Charlotte North Terminal — NPDES Permit No. NCO022187
Dear Sir:
On July 11, 2018, Chad Broadway of MCWQP conducted a NPDES inspection of the Motiva
Enterprises LLC Charlotte North and South Terminals. During the inspection, Mr. Broadway
noted an issue with secondary containment at the South Terminal and a monitoring well at the
North Terminal. NCDEQ requested a written response by August 24, 2018 explaining how the
two issues will be resolved; A summary of the issues and Motiva's resolution is provided below.
Containment at Charlotte South:
Inspection Note:
The secondary containment dike for the oil -water separator holding tanks was observed to have
two significant areas of separation, and other minor cracks and separations. This condition was
also noted during inspections conducted in 2015 and 2016, and displacement of the concrete
blocks appears to have increased since the previous inspections. Although there was no
evidence of a discharge from the containment wall, the structure should be properly repaired to
ensure adequate secondary containment is provided. Please be advised that the subject permit
requires the permittee to properly operate and maintain the facility at all times (Permit
Reference: Part ll, Section C (2) Proper Operation and Maintenance.
Motiva Enterprises LLC
410 Tom Sadler Road
Charlotte, NC 28214

MOTIVA
ENTERPRISES LLC
The secondary containment area was originally built for Tanks 6 and 7 which were single -walled
tanks and part of the remediation system. These tanks were designed to hold remediation
water, water from the oil water separator, and occasionally tank bottoms. The remediation
system is no longer operational and both Tanks 6 and 7 were removed from the site on
November 3, 2016.
Tank 8 is currently the only tank located in the containment area. The tank has a capacity of
10,000 gallons and stores water from the waterside of the oil water separator. It is equipped
with a hydrocarbon sensor to ensure that water discharged from the tank does not contain oil.
Tank bottoms and water from monitoring wells is not stored in Tank 8.
Motiva has developed a Spill Prevention, Control, and Countermeasure (SPCC) Plan in
accordance with the regulatory requirements of 40 CFR Part 112 for the Charlotte South
Terminal. Tank 8 is a shop -built, double -walled above -ground storage tank that has integral
secondary containment to meet the requirements of 40 CFR 112.7(c), which specifies
secondary containment requirements for bulk storage facilities. Because Tank 8 is double -
walled and Tanks 6 and 7 have been removed from the site, the secondary containment dike
wall is no longer necessary. Motiva is in continuous compliance with the inspection, monitoring,
and containment requirements in the SPCC plan.
Monitoring Well at Charlotte North:
Inspection Note:
During an inspection of the facility grounds, evidence of a discharge from one of the facility's
monitoring wells was observed. The discharge appeared to have resulted in staining of the
surrounding gravel. Facility staff also indicated the monitoring well occasionally discharges
following periods of heavy rainfall. Please be advised that the monitoring well should be
properly capped to prevent any future discharges. In addition, any areas impacted by previous
discharges of petroleum must be properly remediated.
The well in question is MW -4 at the Charlotte North Terminal. The well was inspected by
Motiva's contractor and the well cap appeared secure and tight; regardless, on August 20, 2018,
a well cap was glued onto the well by Motiva's contractor to ensure that groundwater will not be
Motiva Enterprises LLC
410 Tom Sadler Road
Charlotte, NC 28214

MOTIVA
ENTERPRISES LLC
discharged from the well during any rain event. In the next several weeks, a raised well casing
will be installed to allow samples to be taken from the well when needed.
Remediation is on-going at the terminal under two incidents active with the NCDEQ. Incident
#18171 includes the Northwest Area near the dry creek/feature and Incident #7244 includes the
area near the VRU. Motiva will continue to work with NCDEQ until closure is obtained for each
of these incidents. The staining on the surrounding gravel appears to be due to minerals in the
groundwater.
Should you have any questions, please contact Kristine Pelt, Environmental Coordinator at 919-
616-5476 or email [e-mail].
Based on information and belief formed after reasonable inquiry, the statement and information
in the attached documents are true, accurate, and complete.
Very truly yours,
MOTIVA ENTERPRISES LLC
D. Scott Dilling
Complex Manager
cc: K. Pelt, Motiva (electronic)
File: 520-01
Motiva Enterprises LLC
410 Tom Sadler Road
Charlotte, NC 28214