NC0027227_NOV-2021-LV-0241_20210421

Hayes, Mitch
From: Smith, Ben <[e-mail]>
Sent: Monday, March 15, 2021 2:19 PM
To: Danhof, Andrew; Grey, Kevin
Cc: Fountain, Bridget
Subject: RE: Selma - Total Suspended Solids Exceedance
Honestly besides the heavy rainfall I don't know. I do know that when we opened the sample bottle container that the
seals were already broken on the bottles and there was no paperwork which was unusual. I did let Sarah Graham know
of this issue.
From: Danhof, Andrew <[e-mail]>
Sent: Monday, March 15, 2021 2:12 PM
To: Grey, Kevin <[e-mail]>
Cc: Smith, Ben <[e-mail]>; Fountain, Bridget <[e-mail]>
Subject: Re: Selma - Total Suspended Solids Exceedance
Basically, if the water was really stirred up when discharged or the if sample was collected prior to flushing out the
outfall. Honestly though, it wasn't a much of an exceedance and could be an outlier. Since this seems to be the first
time it's happened, I not that worried about it. Again, I am just checking to see if there is anything on your end that
provide an explanation.
Andrew G. Danhof, Jr.,P.E.
Zenith Energy Terminals
[phone]
On Mar 15, 2021, at 1:58 PM, Grey, Kevin <[e-mail]> wrote:
Also, we had historically high levels of rainfall in February. Is that something that could result in an
increase to TSS?
From: Danhof, Andrew <[e-mail]>
Sent: Monday, March 15, 2021 1:45 PM
To: Smith, Ben <[e-mail]>
Cc: Grey, Kevin <[e-mail]>; Fountain, Bridget
<[e-mail]>
Subject: Selma - Total Suspended Solids Exceedance
Ben,
We had an exceedance of our stormwater total suspended solids limit in February. Can you think of
anything out of the ordinary for that sample? I need to add an explanation for the exceedance to the
February DMR.
Thanks,
<image001.jpg>
1

Hayes, Mitch
From: Danhof, Andrew <[e-mail]>
Sent: Wednesday, April 21, 2021 3:38 PM
To: Hayes, Mitch
Cc: Caldwell, Shannon
Subject: [External] FW: Permit No. NC0027227 - Response to NOV-2021-LV-0241
Attachments: Permit No. NC0027227 Solids Total Suspended vs Time.pdf; RE: Selma - Total
Suspended Solids Exceedance
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Mr. Hayes,
Thank you for taking my call earlier this morning. This email is Zenith Energy's response to the Notice of Violation letter
(Tracking Number NOV-2021-LV-0241) received April 19, 2021 for a solids, total suspended (TSS) permit level
exceedance associated with stormwater discharged on February 8, 2021 from Zenith Energy's Selma, North Carolina
facility. An investigation conducted by Zenith Energy when the analytical results associated with the February 8th
discharge were received concluded the exceedance was most likely an anomaly, caused by historically heavy rainfall
prior to the February 8th stormwater discharge, or caused by an issue with the sample bottles. The reasons for this
conclusion are:
1. A review of past TSS concentrations in stormwater discharged from the facility indicates this is the first TSS
exceedance (see attached graph of stormwater TSS concentrations vs. time).
2. The most recent discharge (April 7, 2021) had a TSS concentration of 6.0 mg/L which indicates the TSS
concentration has returned to expected levels.
3. On -site personnel stated there was historically high levels of rainfall in February 2021. A review of weather data
indicates there was approximately 1.7 inches of rainfall in the area between February 1— February 8, 2021.
4. On -site personnel stated: "when we opened the sample bottle container the seals on the sample bottles were
broken and there was no paperwork which was unusual" (see attached 3/15/2021 from Ben Smith). Based on
this statement, it seems possible that the TSS sample bottle could have been contaminated with dust or some
other foreign matter.
Corrective actions associated with the broken sample bottle seals were:
1. Informing Pace Analytical of this issue, and
2. Instructing the on -site personnel to only collect samples using pre -sealed sampled bottles.
Please do not hesitate to contact me if you need any additional information on this matter.
Thank you,
zENITH ENE tC?
Andrew G. Danhof, Jr., P.E.
Manager, Environmental and Regulatory
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40
20
10
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10/27/201a 2J+/2019
Solids, Total Suspended vs Time
Zenith Energy Terminals Selma, NC
Permit No. NC0027227
Notes:
1) T55 - Solids, Total Suspended
2) A T55 concentration of zero Indicates there was no discharge during the reporting period.
3) Non -detected TSS concentrations are graphed at the reporting limit.
5/15/2019
8/23/2019
12/1/2019 3/10/2020 6/18/2020
—9—T55 (mg/L) —TSS Limit (ma/LL
9/26/2020
1/4/2021
4/14/2021 7/23/2021