NC0031038_NOV-2020-LV-0079 Response_20200220

Jeff Titus
Operations Manager
Priority Mail #EJ 051 653 664 US
February 20, 2020
W. Corey Basinger
Regional Supervisor
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
Mooresville Regional Office
610 East Center Street Suite 301
Mooresville, NC 28115
Re: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number NOV-2020-LV-0079
Permit No. NCO031038
Colonial Pipeline Company - Charlotte Delivery Facility
Mecklenburg County
Dear Mr. Basinger:
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This letter is in response to the above referenced Notice of Violation (NOV) received February
12, 2020. Upon reviewing the lab report(s) for the December 2019 sampling events, John
Culbreath, the Operator -in -Responsible Charge for the NPDES permit made a telephonic
notification (voice mail) to Wes Bell with NCDEQ — Mooresville Regional Office on January 14,
2020 regarding the exceedances that are listed in the NOV. The exceedances were attributed to
ongoing excavation and construction activities that began in September 2019 for the removal of
petroleum impacted soil and replacement of several hundred feet of a defective 30-inch
petroleum storage tank line. Additionally, there were a number of above -average rainfall events
that totaled approximately 6.4 inches during the 30-day period prior to the December sampling
events.
The three outfall locations at the Charlotte facility where the exceedances occurred are part of
three separate petroleum storage tank containment areas (dikes). The dike areas are
constructed with earthen banks and ballast ground cover (stone/gravel). Valves located at each
dike are kept closed at all times and only manually opened to drain accumulated stormwater
through those outfalls. In order to preserve the integrity of the tanks accumulated stormwater
must be released or removed whenever the volume of water in the dike reaches a level that
causes it to come into contact with the base of the storage tanks. The contractor performing the
work had implemented sediment and erosion control measures (silt fence, hay bales, filter bags,
etc.) throughout the facility. However much of the excavation and construction activity took
place in or adjacent to these dike areas. Soil disturbance activities and excessive stormwater
events resulted in abnormal amounts of silt being deposited into the ballast ground cover of
these dike areas and subsequently in the discharged water, resulting in the exceedances.
Remedial Actions:
In January 2020, the turbid stormwater that accumulated in the Outfall 007 and 009 dike areas
was removed via tanker trucks and transported to Heritage -Crystal Clean in Concord, NC for
disposal. By doing so Colonial avoided the chance of another exceedance from those outfalls.
P.O. Box 87 Paw Creek, NC 28130

Notice of Violation NOV-202-LV-0079
Colonial Pipeline Company
Charlotte Delivery Facility
Soil disturbing activity is expected to continue for several months in and around the Outfall 007
and 009 dike areas. The removal and offsite disposal of stormwater from those areas is not a
practical option given the amount of rainfall currently in the region. Additional erosion control
measures around Outfall 008 were successful in mitigating turbidity. The measures included
additional silt fencing installation around the dike, floc and wattle log placement around the
outfall inlet, the addition of clean gravel, and some re -seeding on the part of the dike wall. The
water from that dike area was able to be discharged, sampled, and within limits. More
aggressive remediation plans for Outfall 007 and 009 are currently being considered and
evaluated by Colonial and the contractor.
An on -site meeting and inspection with Wes Bell from NCDEQ — Mooresville Regional Office
has been scheduled for February 25, 2020. The purpose of the meeting will be to discuss
options and obtain guidance on additional measures Colonial can implement to prevent future
exceedances.
Based on information provided and belief formed after a reasonable inquiry, I certify that the
information contained above for this facility is accurate and true to the best of my knowledge.
If you should have any questions or require additional information, I can be contacted at (678)
314-2006.
Sincerely,
eff Titus
Manager, Operations
Cc: John W. Culbreath - Environmental Specialist; Operator -in -Responsible Charge
Colonial Pipeline Company