WQ0005809_CEI_20211122

ROY COOPER.
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
NORTH CAROLINA
Environmental Quality
November 22, 2021
Brian L. Smith — Operations Manager
Colonial Pipeline Company
411 Gallimore Dairy Road
Greensboro, North Carolina 27409
SUBJECT: Compliance Evaluation Inspection
Permit No. WQ0005809
Colonial Pipeline Company Residuals Land Application
Guilford County
Dear Mr. Smith:
On November 3, 2021, Division of Water Resources staff person Caitlin Caudle
performed a scheduled compliance inspection for the purpose of reviewing the facility
after a request for permit recission was submitted. Maribeth Hughes of Colonial Pipeline
was present during the entire inspection. A review of available records, application site,
and four of the five monitoring wells was completed. This review reflected compliance
with the subject permit, but the following items of concern were noted:
1. When reviewing the monitoring wells associated with the subject permit, it was
noted that three of the four wells reviewed were not secured with proper well caps
or locking mechanisms. A plastic container was placed over the well casing and
secured with a metal clamp. Per 15A NCAC 02C .0108(1) "all non -water supply
wells, including temporary wells, shall be securing with a locking well cap to ensure
against unauthorized access and use." Within sixty (60) days of receipt of this
letter replace the plastic containers with the appropriate well caps and install
locks for monitoring wells 1, 3, and 6. Please inspect monitoring well 4 and
replace the well cap and install a lock if needed.
2. It was also noted that all monitoring wells reviewed did not have a clearly marked
well identification number as designated in Attachment C of the subject permit. Per
15A NCAC 02C .0108(p)(6) each non -water supply well shall have a permanently
affixed identification plate with specific information, including the well identification
number or name assigned by the well owner. Please install clear well
identification numbers that correspond to the information provided in
Attachment C within sixty (60) days of receipt of this letter.
NORTH
D E
Dopartmem of ln.imnmomni au.i`
North Carolina Department of Environmental Quality Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

These concerns must be addressed before the permit will be rescinded. Please refer to
the attached inspection report for additional observations. If you have any questions
regarding this letter please contact me or Caitlin Caudle at the letter head address or
phone number or by email at [e-mail] or [e-mail].
Sincerely,
1- DocuSiiggned by:<
145B49E225C94 EA...
Lon T. Snider, Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources, NCDEQ-WSRO
Enc: Inspection Report
Cc: Maribeth Hughes ([e-mail])
Guilford County Environmental Health([e-mail])
WSRO Electronic Files
Laserfiche Permit File WQ0005809
LD_E
NORTH CAROLINA
Department of Environmental quaky
North Carolina Department of Environmental Quality j Division of Water Resources
Winston-Salem Regional Office 1450 West Hanes Mill Road, Suite 300 I Winston-Salem, North Carolina 27105
336.776.9800

Compliance Inspection Report
Permit: WQ0005809 Effective: 07/27/17
SOC: Effective:
County: Guilford
Region: Winston-Salem
Contact Person: John M Wyatt
Directions to Facility:
System Classifications: LA,
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
NCG510210
WQ0006317
0031046AC
NC0031046
Expiration: 06/30/22
Expiration:
Title:
Colonial Pipeline Company -
Colonial Pipeline Company -
Colonial Pipeline Company -
Colonial Pipeline Company -
Certification:
Colonial Pipeline
Colonial Pipeline
Colonial Pipeline
Colonial Pipeline
Inspection Date: 11/03/2021 Entry Time 10:03AM
Primary Inspector: Caitlin Caudle
Secondary Inspector(s):
Reason for Inspection: Routine
Owner : Colonial Pipeline Company
Facility: Colonial Pipeline Company RLAP
411 Gallimore Dairy Rd
Greensboro NC 27409
Phone: [phone]
Phone:
- Greensboro Junction WWTF
- Greensboro Junction WWTF
- Greensboro Junction WWTF
- Greensboro Junction WWTF
Exit Time: 10:54AM
Phone: [phone]
Inspection Type: Compliance Evaluation
Permit Inspection Type: Land Application of Residual Solids (503 Exempt)
Facility Status:
Question Areas:
Compliant ❑ Not Compliant
▪ Miscellaneous Questions Record Keeping
▪ Wells
(See attachment summary)
Land Application Site
Page 1 of 4

Permit: WQ0005809 Owner - Facility: Colonial Pipeline Company
Inspection Date: 11/03/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Inspection Summary:
On November 3, 2021, Division of Water Resources staff person Caitlin Caudle performed a scheduled compliance
inspection for the purpose of reviewing the facility after a permit recission request. Maribeth Hughes of Colonial Pipeline was
present during the entire inspection. A review of available records, the application site, and four of the five monitoring wells
was completed.
The residuals generated at this facility are sludges removed from the gas and oil tanks as they are cleaned and repaired
every 10 years. Ms. Hughes stated that only a few barrels of material are removed when the tanks are cleaned out. Land
application at this facility has not occurred since 2014, as a result no residuals analysis has been conducted in the form of
nutrient analysis or TCLP, and no soil analysis has been completed. In 2014 1,557.72 dry tons were generated, and land
applied on the four fields permitted at this facility. Seven tanks were reportedly emptied in 2014.
Ms. Hughes stated that all residuals generated when tanks are cleaned will be managed by a hazardous waste company.
There are no residuals generating equipment or storage areas that need to be decommissioned.
Of the four monitoring wells reviewed, all were found to be noncompliant with the subject permit. Monitoring wells 3 and 4 are
unique to the land application permit. Monitoring wells 1, 3, and 6 did not have a cap. A plastic jug had been placed over the
well casings with a metal clamp keeping it in place. All four monitoring wells did not have a clear label marking the well
number. This is a violation of 15A NCAC 02C .0108(1) and 15A NCAC 02C .0108(p)(6) which require locking well caps to
ensure against unauthorized access and use, and a clear label of the well identification number or name. Please replace the
metal caps on the well casings, as needed, and clear labels before the permit can be rescinded.
Ms. Hughes inquired what will happen to the monitoring well 3 and 4 after the RLAP permit is rescinded.
Page 2 of 4

Permit: WQ0005809 Owner - Facility: Colonial Pipeline Company
Inspection Date: 11/03/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Type
Distribution and Marketing
Land Application
Record Keeping
Is GW monitoring being conducted, if required?
Are GW samples from all MWs sampled for all required parameters?
Are there any GW quality violations?
Is GW-59A certification form completed for facility?
Is a copy of current permit on -site?
Are current metals and nutrient analysis available?
Are nutrient and metal loading calculating most limiting parameters?
a. TCLP analysis?
b. SSFA (Standard Soil Fertility Analysis)?
Are PAN balances being maintained?
Are PAN balances within permit limits?
Has land application equipment been calibrated?
Are there pH records for alkaline stabilization?
Are there pH records for the land application site?
Are nutrient/crop removal practices in place?
Do lab sheets support data reported on Residual Analysis Summary?
Are hauling records available?
Are hauling records maintained and up-to-date?
# Has permittee been free of public complaints in last 12 months?
Has application occurred during Seasonal Restriction window?
Comment: Applicaiton has not occurred since 2018. There
monitoring wells.
Land Application Site
Is a copy of the permit on -site during application events?
Is the application site in overall good condition?
Is the site free of runoff/ponding?
If present, is the application equipment in good operating condition?
Are buffers being maintained?
Are limiting slopes buffered?
10% for surface application
18% for subsurface application
Yes No NA NE
•
Yes No NA NE
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
❑ ❑ • ❑
• ❑ ❑ ❑
❑ ❑•❑
have been past exceedences in pH for all
Yes No NA NE
• ❑ ❑ ❑
❑ ❑ • ❑
Page 3 of 4

Permit: WQ0005809 Owner - Facility: Colonial Pipeline Company
Inspection Date: 11/03/2021 Inspection Type : Compliance Evaluation
Reason for Visit: Routine
Are there access restrictions and/or signs?
Is the application site free of odors or vectors?
Have performance requirements for application method been met?
For injection?
For incorporation?
Does permit require monitoring wells?
Have required MWs been installed?
Are MWs properly located w/ respect to RB and CB?
Are MWs properly constructed (including screened interval)?
Is the surrounding area served by public water?
If Annual Report indicates overapplication of PAN, are wells nearby that may be impacted?
Are soil types consistent w/ Soil Scientist report/evaluation?
Is the water table greater than 1'/3' bls.
Is application occurring at the time of the inspection?
Comment: No application has occurred since 2014.
❑ ❑ • ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
• ❑ ❑ ❑
❑ ❑ ❑ •
Page 4 of 4

North Carolina Department of Environmental Quality
Division of Water Resources
Water Quality Section
NON -DISCHARGE COMPLIANCE INSPECTION REPORT
CLASS B RESIDUALS LAND APPLICATION
General Information
Facility Name: Colonial Pipeline RLAP
Permit No.: WQ005809
County: Guilford
Permit Issuance Date: 07/27/2017
Owner: Brian Smith (Operations Manager) Permit Expiration Date: 06/30/2022
Plant ORC Name: Faron Leigh
Telephone No.: 336-669-7903
LA ORC / Contract Company: Telephone No.:
Other Contact(s): Telephone No.:
Facility Location (address, gps or directions): 411 Gallimore Dairy Rd, Greensboro NC 27409
Reason for Inspection
OUTINE ❑ FOLLOW-UP ❑ COMPLAINT ❑ PERMITTING ❑ Other:
Comments (attach additional pages as necessary)
- Are the contacts right?
-Any land application planned for the future? I
- Doeis4nything need to be done to decomission this permit? Any equipment that needs to be removed?
- No pat g n�lnctor requirements? r 16\ft
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Is a follow-up inspection necessary? ❑ Yes
I
Primary Inspector: Caitlin Caudle
Date of Inspection:
Secondary Inspector: r
Entry Time: I b ', 7 cx Exit Time: ) 0 rSi a

Non -Discharge Compliance inspection Report
Residuals Generating Facility
Was the residuals generating facility inspected? ❑ Yes ❑ No
Residuals Storage:
Describe storage:
Number of days/weeks/months of storage:
Residuals Sampling:
Is sampling adequate and representative for each sample type?
Describe Sampling (Pathogens, VAR, Nutrients/Metals, TCLP):
Transport Vehicle:
Is transport occurring at time of inspection?
Are necessary records (spill plan) present in vehicle? ID of observed vehicle(s):
Record Keeping and Reporting Information:
Is current permit and prior annual reports available upon request?
Has the facility been free of public complaints for the last 12 months?
TCLP analysis conducted and results available? Frequency? ® 1/yr or ❑ 1/permit cycle
Residuals metals and nutrient analysis conducted? Frequency? An nual (See permit for frequency)
Nutrient and metals loading calculations? (to determine most limiting parameter)
Do lab sheets support data reported on Residuals Analysis Summary?
Are PAN balance records available and within permit limits?
Are there nutrient (crop) removal practices in place?
Are hauling records available? (gal and/or tons hauled during calendar year to date)
Are field loading records available?
Are field inspections conducted and are records available?
Are soil sample results available?
Did soil results call for lime amendment? If so, are there records of application?
Soil results indicate that Cu & Zn indices are <3,000 (ideally <2,000)?
Soil results indicate Na <0.5 meq/100 cm3, and Exchangeable Sodium Percentage (ESP) <15%?
Does the permit require groundwater monitoring? •
Are groundwater lab results present?
There are no 2L GW standard violations indicated in the lab results?
Pathogen and Vector Attraction Reduction Records
Pathogen Reduction:
Which Alternative was used to demonstrate compliance?
❑ Alternative 1 Fecal Coliform Density.
Were 7 samples collected and geometric mean <2 million mpn/cfu?
❑ Alternative 2 Process to Significantly Reduce Pathogens (5 options)
❑ Alternative 3 Use of Equivalent to RSRP (Not commonly used - See White House Manual)
If Alternative 2 was used, select which Option was utilized and complete the section below.
❑ Option 1 - Aerobic Digestion
Are logs present showing time and temperature?
Was the time & temp. between 40 days at 68°F (20°C) and 60 days at 59° F (15°C)?
❑ Option 2 - Air Drying
❑ Option 3 - Anaerobic Digestion
Are logs present showing time and temperature?
Was the time & temp. between 15 days at 95° F — 131° F (35°-55° C) and
60 days at >68° F (20° C)?
❑ Option 4 — Composting (Not commonly used - See White House Manual)
❑ Option 5 - Lime Stabilization
Are logs present showing time and temperature?
Was the pH raised to > 12 after two hrs of contact?
Was the temperature corrected to 25° C (77° F) (by calculation, NOT auto correct)?
Page 2 of 4
Y
❑
❑❑❑❑❑❑❑❑❑❑❑ z ❑z
NA
NA
Y N NA NE
❑ ❑ ,t ❑
NE
NE
Y N NA NE
❑X ❑
Y N NA NE
❑ ❑ X❑ ❑
❑ ❑ a ❑
❑ ❑ © ❑
❑ ❑ © ❑
DEED
❑ LI
O DIED

Non -Discharge Compliance Inspection Report
Vector Attraction Reduction:
Select which Option was used to demonstrate compliance and complete answer associated questions.
❑ Option 1 - 38% Volatile Solids Reduction Y N NA NE
Are lab results and calculations present? DEED
Was the reduction on volatile solids (not total solids)? DOED
Were samples collected at correct locations? ❑ ❑ ® ❑
(beginning of digestion process & before land application)
Was there a >38% reduction? ❑ ❑ © ❑
❑ Option 2 - 40-Day Bench Scale Test Y N NA NE
Were residuals from an anaerobic digester with average temp. 30°C — 40°C? ❑ ❑ x❑ ❑
Are lab results and calculations present? ❑ ❑ © ❑
Was the test anaerobically digested in lab, and test run for 40 days? ❑ ❑ x❑ ❑
Was the lab bench -scale test done between 30°C (86°F) and 37°C (99°F)? ❑ ❑ © ❑
Was the reduction of on volatile solids (not total solids)? ❑ ❑ © ❑
Was the reduction less than 17%? ❑ ❑ 1 ❑
❑ Option 3 - 30-Day Bench Scale Test Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑x ❑
Are lab results and calculations present? ❑ ❑ ® ❑
Were residuals 2% or less total solids? ❑ ❑ ® ❑
If not 2% total solids, was the test ran on a sample diluted to 2%
with unchlorinated effluent? DUEL
Was the test run for 30 days? ❑ ❑ ® ❑
Was the test done at 20°C (68°F)? ❑ ❑ ❑x ❑
Was the reduction of on volatile solids (not total solids)? ❑ ❑ x❑ ❑
Was the reduction less than 15%? ❑ ❑ ® ❑
❑ Option 4 - Specific Oxygen Uptake Rate (SOUR Test) Y N NA NE
Were residuals from aerobic digestion? ❑ ❑ ❑x ❑
Were residuals <2% total solids (dry weight basis) (not diluted)? ❑ ❑ ® ❑
Was the test done between 10°C (50°F) and 30°C (86°F)? ❑ ❑ ❑x ❑
Was the temperature corrected to 20°C (68°F)? ❑ ❑ x❑ ❑
Was the sampling holding time <2 hours? ❑ ❑ x❑ ❑
Was the test started within 15 minutes of sampling or aeration maintained? ❑ ❑ © ❑
Was the SOUR equal to or less than 1.5 mg of oxygen per hour per gram of
total residual solids (dry weight basis)? ❑ ❑ ❑
❑ Option 5 - 14-Day Aerobic Process Y N NA NE
Were the residuals from aerobic digestion? DEED
Was the average residuals temperature higher than 45°C (113°F)? ODED
Were the residuals treated for 14 days and temperature maintained higher
than 40°C (104°F) for the 14-day period? DEED
❑ Option 6 - Alkaline Stabilization Y N NA NE
Was the pH of the residuals raised to > I2 and maintained for two hours
without addition of more alkali? DDEO
Did the pH of residuals remain at >11.5 an additional twenty-two hours
(i.e. 24 hours total) without the addition of more alkali? ❑ ❑ x❑ ❑
Was the pH corrected to 25°C (77°F) (by calculation, NOT auto correct)? DOED
❑ Option 7 - Drying of Stabilized Residuals Y N NA NE
The residuals do not contain unstabilized residuals? ❑ ❑ x❑ ❑
Were the residuals mixed with any other materials? DDED
Were the residuals dried >75% total solids? ODED
❑ Option 8 - Drying ofUnstabilized Residuals Y N NA NE
Were the residuals mixed with any other materials? DODD
Were the residuals dried >90% total solids? DOWD
❑ Option 9/10 — Injection/ Incorporation of Residuals (Not commonly used - See White House Manual)
Page 3 of 4

Non -Discharge Compliance Inspection Report
Land Application Site(s)
Were application site(s) inspected? If so, please list Site ID(s) below.
Application Site ID(s): 1A, 1B, 1C, 1D
Yes ❑ No
Is application occurring at the time of inspection? ❑ Yes ❑ No If no, note the date of the last event:
Was the Division notified of the application event(s)? ❑ Yes ❑ No
Weather Conditions:
❑ Sunny ❑ Partly Cloudy ❑ Cloudy
❑ Windy (wind direction: ) ❑ Breeze
❑ No Precipitation ❑ Drizzle ❑ Rain
Is there a rain gauge onsite? ❑ Yes ❑ No
Weather Notes (i.e. Significant Changes, Forecasts, etc):
Temp. (° F): ❑ <32
❑ 32 — 40 ❑ 40 — 60
Permit and Spill Plan onsite during application? ❑ Yes
❑ Overcast
❑ Calm
❑ Cloudburst
❑ Stormy
(If applicable, precipitation measurement:
❑ 60 — 80 ❑ >80
❑ No
Application Observations: [Type of application: ❑ Liquid ❑ Cake ❑ Other
Application Site —Field 1D(s):
Intended Crop: PAN Requirement: Ibs/ac
Application Rate (tons or gallons/acre):
Nutrient Content:
% of total field area utilized or anticipated for this event?
Application occurring at time of visit: ❑ Yes p No
Application Method: ❑ Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes ❑ No 0 N/A
Vegetative Buffer description: ❑None ['Grass ❑Crop ❑ Shrub
['Tree 0 Other
Current Field Conditions:
0 Bare 0 Stubble ❑ Planted terns) ❑ Pasture
Soil Condition:
0 Dry ❑ Moist ❑ Wet ❑ Saturated
0 Not -Frozen 0 Frost 0 Frozen ❑ Snow -Covered
Slope: 0 0-3% ❑ 3-6% 0 6-10% ❑ 10-18% ❑ >18%
Odor: 0 None ❑ Mild 0 Moderate ❑ Strong
Vectors: 0 None 0 Few ❑ Many ❑ Excessive
Application Details:
Application areas clearly marked?
Application within authorized area?
Application method appropriate?
Application is even (no ponding)?
Sufficient setbacks from wells/residences?
Sufficient setbacks from surface waters?
Slopes >10% avoided (Surface App.) ?
Slopes >18% avoided (Incorp/Inject) ?
Incorp./Injection within time -frame?
Biosolids visible on surface?
Site Restrictions
Public access is restricted / Signage present?
Grazing restrictions are met?
Transfer of biosolids is in permitted area?
No evidence of shallow GW?
Sufficient timing for harvest restrictions?
Off Site Transport
Tracking is prevented?
Biosolids run-off is prevented?
Windblown biosolids prevented?
Vegetative buffers exist?
Y N NA NE
O 000
DODD
❑ ❑❑❑
O 000
O 000
❑ ❑❑❑
O 000
O 000
O 000
O 000
Y N NA NE
O 000
❑ ❑❑❑
O 000
O 000
O 000
Y N NA NE
❑ ❑❑❑
O 000
O 000
O 000
Application Site —Field 1D(s):
Intended Crop: PAN Requirement: Ibs/ac
Application Rate (tons or gallons/acre):
Nutrient Content:
% of total field area utilized or anticipated for this event?
Application occurring at time of visit: ❑ Yes 0 No
Application Method: ❑ Surface ❑ Incorp/Injection
Incorporation/Injection during visit: ❑ Yes ❑ No ❑ N/A
Vegetative Buffer description: 0None 0Grass ['Crop ❑ Shrub
['Tree 0 Other
Current Field Conditions:
❑ Bare 0 Stubble 0 Planted moo) ❑ Pasture
Soil Condition:
❑ Dry ❑ Moist ❑ Wet ❑ Saturated
❑ Not -Frozen ❑ Frost ❑ Frozen ❑ Snow -Covered
Slope: 0 0-3% ❑ 3-6% ❑ 6-10% 0 10-18% 0 >I8%
Odor: 0 None 0 Mild ❑Moderate 0 Strong
Vectors: 0 None ❑ Few 0 Many 0 Excessive
Application Details: Y N NA NE
Application areas clearly marked? 0000
Application within authorized area? 0000
Application method appropriate? 0 0 0 ❑
Application is even (no ponding)? ❑ ❑ ❑ ❑
Sufficient setbacks from wells/residences? 0000
Sufficient setbacks from surface waters? 0000
Slopes >10% avoided (Surface App.) ? ❑ ❑ ❑ ❑
Slopes >18% avoided (Incorp/Inject) ? 0000
Incorp./Injection within time -frame? 0000
Biosolids visible on surface? 0000
Site Restrictions
Public access is restricted / Signage present?
Grazing restrictions are met?
Transfer of biosolids is in permitted area?
No evidence of shallow GW?
Sufficient timing for harvest restrictions?
Off Site Transport
Tracking is prevented?
Biosolids run-off is prevented?
Windblown biosolids prevented?
Vegetative buffers exist?
Y N NA NE
O 000
O 000
O 000
O 000
O 000
Y N NA NE
O 000
O 000
O 000
O 000
Page 4 of 4