NC0032875_NOV-2024-MV-0024_20240326

KINDER�MORGAN
March 25, 2024
SENT VIA EMAIL AND FED EX
Mr. Michael Hall, Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources
North Carolina Department of Environmental Quality
3800 Barrett Drive
Raleigh, NC 27609
Subject: Kinder Morgan Southeast Terminals, LLC — Selma Terminals
Response to Notice of Violations
Dear Mr. Hall:
On March 13, 2024, Kinder Morgan Southeast Terminals, LLC (KMST) received the first of three
Notice of Violation (NOV) and Intent to Assess Civil Penalty letters. The letters were issued based
on NCDEQ's review of the December 2023 Discharge monitoring reports with violations for the
following:
NPDES Permit NC0088218, KMST Selma Terminal #2
Monitoring Violations, 001 Effluent, MTBE and Turbidity, 12131/2023, Frequency Violation
NOV Dated 2/29/2024
NPDES Permit NC0076457, KMST Selma Terminal #3
Monitoring Violations, 001 Effluent, MTBE and Turbidity, 12131/2023, Frequency Violation
NOV Dated 3/6/2024
NPDES Permit NC0032875, KMST Selma Terminal #4
Monitoring Violation, 001 and 002 Effluents, Turbidity, 12/31/2023, Frequency Violation
NOV Dated 2/26/2024
KMST submitted responses to these NOVs, via email, on 2/16/2024, to Mr. Donald Smith of your
office. KMST would now like to submit the following written response, within your requested 10-
day period, for consideration.
Quarterly MTBE and Turbidity Samples
NPDES Permit NCO088218 (Selma Terminal #2, Outfall 001) and NPDES Permit NCO076457
(Selma Terminal #3, Outfall 001) both require quarterly grab samples for MTBE and turbidity.
Similarly, NPDES Permit NCO032875 (Selma Terminal #4, Outfall 001 and Outfall 002) requires a
quarterly grab sample for turbidity.

Mr. Michael Hall
NCDEQ — Division of Water Resources
KMST Selma Terminals NOV Response
Page 2
The electronically submitted discharge monitoring reports for December 2023 for the three
terminals were correct and did not include quarterly monitoring requirements for parameters
MTBE or turbidity.
The quarterly samples for MTBE and turbidity were initially planned to be collected in October
2023. Typically, quarterly samples are scheduled to be collected in the first quarter of each
monitoring period. However, in October, there was insufficient stormwater at the terminals to
discharge due to the lack of rainfall. November was also "dry", with insufficient stormwater
available to collect samples. When the water sampling technician went to collect December's
required samples, they inadvertently did not bring the sample kit for the quarterly sampling
parameters, MTBE and turbidity. All the required monthly grab samples for December were
collected reported, and were in compliance with permit limits.
To avoid this oversight in the future, the third party who collects samples has implemented
corrective actions. These corrective actions include steps to properly label laboratory coolers,
field notes on current sampling requirements, and a comparison of samples collected against
permit requirements. These actions will insure that proper sample collection containers are
available each month, including periods when sampling is delayed due to insufficient volume. In
addition, Kinder Morgan has implemented an additional system to track completion of sample
collection and reporting.
Please note that the January 2024 (Monthly), and 1s' Quarter 2024 (Quarterly) samples for the
Selma terminals were all collected in January 2024. Please do not hesitate to contact myself or
Mr. Gordon Terhune at 404-326-8842 or Gordon Terhune(a)kindermoroan.coml if you have any
questions or require additional information:
Regards,
Wayne Harvey
Manager - Operations
770-751-4116 office
470-426-9734 cell
1000 Windward Concourse Suite 450 1 Alpharetta, GA 30005
Cc: Mr. Donald Smith, NCDEQ, DWR, via email Donald. Smith (o dea.nc.gov