NC0052311_NOV-2024-LV-0036 Response 10 Day_20240205

BUCKEYE SE TERMINALS LP

6161 Hamilton Blvd ∙ Allentown, PA 18106 ∙ Tel [phone] ∙ Fax [phone]

February 5, 2024

Mr. Kevin Fowler
NC DEQ / Division of Water Resources / Water Quality Permtting Section
ATTENTION: Central Files
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Subject: NOTICE OF VIOLATION & INTENT TO ASSES CIVIL PENALTY
Tracking Number: NOV-2024-LV0036
Permit No. NC0052311
Selma Terminal
Johnston County

Dear Mr. Fowler,

As requested in the issued notice of violation, Buckeye SE Terminals LP (Buckeye) is providing this 10-
Day respond letter with additional information regarding the limit exceedance violation.

Event Summary
On November 30, 2023, Buckeye received the monthly stormwater compliance sample results from
Outfall 001 which revealed an elevated level for benzene at 27.7 micrograms per liter (ug/L). No unusual
conditions or sheen were noted in the two (2) stormwater retention ponds or at the outfall at the time of
the sample collection on November 22, 2023. Upon receipt of the sample results, Buckeye completed
further investigation around the site, including checking the ponds and storm drains. No sheen or evidence
of petroleum impacts were identified during the site inspection.

On December 9, 2023, a small area of sheen was observed emanating from a crack in the concrete
southwest of the Facility’s Vapor Recovery Unit. The sheen appeared weathered and was thought to be
historical in nature and mobilized to the surface by recent heavy rains. Adsorbent pads were used to contain
and clean up the impacted crack in the concrete. At this time, the observation was presumed to be the
likely cause of the elevated benzene concentration that was observed in the November discharge sample
that was collected at Outfall 001.

As required by the Facility’s water permit, the December 2023 compliance sample was collected on
December 18, 2023, and again no sheen or impacts were noted in the ponds or at the outfall (Outfall 001)
during the sampling event. Adsorbent pads were still being maintained at the crack in the concrete where
petroleum was observed on December 9, 2023. On December 26, 2023, the analytic sample results of the
outfall were received and the benzene concentration was reported to be 33.1 ug/L.

On January 4, 2024, what appeared to be non-weathered petroleum product, believed to be gasoline, was
found in the storm drain, indicating a potential subsurface release. Buckeye’s local operations personnel
began isolating and pressure testing the gasoline lines in the area. On January 5, 2023, 15 gallons of
recovered product from the storm drain was reported to the North Carolina Department of Environmental
Quality (NC DEQ). Buckeye’s local operations personnel continued to isolate and pressure test lines and
rubber spill control mats were placed over the impacted storm drain to prevent stormwater runoff from
entering the drain. No sheen was noted in the stormwater retention ponds. No additional product appeared
in the storm drain until January 8, 2024, following another heavy rainfall event. The product was recovered
and there was no sheen noted in the ponds.

On January 10, 2024, pressure testing of all gasoline lines continued and all existing onsite monitoring
wells were gauged for the presence of light non-aqueous phase liquid (LNAPL). No LNAPL was observed
in any of the wells.

On January 11, 2024, the impacted storm drain was plugged as an additional preventive measure and
probing and potholing was conducted in areas around the site to assist in identifying a leak. Potholing
identified a French drain on January 16, 2024 as a likely conduit to the impacted storm drain. Another
parallel French drain was identifed on a historical drawing a few days later.

On January 12, 2024, a pressure test of the inbound product delivery line failed, confirming that a release
had occurred. This catholically protected line was subsequently excavated and a small hole was confirmed
to be present in the pipe. Following the identification of the hole, as section of the pipe was removed and
replaced. Buckeye estimates that approximately 37 barrels of gasoline were released at the site, and to
date, approximately 35 barrels have been recovered.

Mitigative Action Summary
Throughout the course of the investigation and repair activities, product recovery continued as needed,
and Buckeye completed regular inspections of the ponds and the creek downgradient of Outfall 001. To
date, Buckeye has not observed any sheen on the water downgradient of Outfall 001. Stormwater from the
dike areas is being rerouted directly to the outfall to avoid sending additional water to the ponds. The
most recent discharge sample from the pond at Outfall 001 was collected on January 20, 2024, and
Buckeye is still awaiting the laboratory results.

The stormwater drain that was plugged is being used as a recovery point for remaining product. Currently,
any product/water mixture that accumulates within the storm drain is being transferred to a frac tank onsite.
Additionally, adsorbent material remains in place in the ponds as a precaution as well as adsorbent booms
at the pond outfall and below the outfall in the stream itself.. No sheen is present in the ponds or stream.

Petroleum impacted soil around the leak location has been excavated and, along with recovered
product/water mixtures, are being transported off-site for proper recovery and disposal.

In addition to continued monitoring and recovery activities, an aerator has been purchased and installed in
the second pond on January 24, 2024 to support biodegradation of the dissolved phase petroleum impacts.
An additional aerator was purchased and installed in the first pond on February 5th, 2024. Remedial
options for the impacted storm drains and surrounding soil and groundwater are currently being evaluated.
The details of these evaluations and future remedial recommendations will be provide to the NC DEQ
when available.

Follow-up samples were collected from the both ponds and the discharge outfall on January 22 and 29,
2024. The analytical sample results were received and the benzene was non-detectable with a detection
limit of 1.19 microgram per liter.

Attached are copies of both analytical results for the samples.Should you have any questions about the
information provided, please do not hesitate to contact me at [e-mail] or [phone].

Sincerely,

Travis Pinnock
Sr. Specialist, South Region Environmental Compliance