NC0031038_NOV-2020-LV-0303_20200625

June 25, 2020 USPS Certified Mail # 7016 2710 0000 0681 9754
W. Corey Basinger
Regional Supervisor
Water Quality Regional Operations Section
NCDEQ — Division of Water Resources
Mooresville Regional Office
610 East Center Avenue Suite 301
Mooresville, NC 28115
Re: Notice of Violation & Intent to Assess Civil Penalty
Tracking Number NOV-2020-LV-0303
Permit No. NCO031038
Colonial Pipeline Company - Charlotte Delivery Facility
Mecklenburg County
Dear Mr. Basinger:
, i t,J1N L' e;0 C
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This letter is in response to the above referenced Notice of Violation (NOV) received April 27,
2020. Upon reviewing the lab report(s) for the February 2020 sampling events, John Culbreath,
the Operator -in -Responsible Charge for the NPDES permit made a telephonic notification to
Wes Bell with NCDEQ — Mooresville Regional Office on March 10, 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 was an above -average rainfall amount between
February 6 and February 25, 2020 that totaled approximately 9.2 inches.
The two outfall locations at the Charlotte facility where the exceedances occurred are part of
two 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 construction
activities 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:
The above referenced exceedances at Outfalls 007 and 009 occurred during the discharge /
sampling event that took place on February 19, 2020. Stormwater that collected in these two
diked areas after February 19 (approximately 1.5 inches of rainfall), was pumped into frac tanks
that were staged in each dike area. A vendor was contacted about treating the stored
stormwater with a product called "Haloklear", which consists of natural flocculants used to
reduce turbidity and TSS. (A copy of the brochure for this product is attached). After treating the
P.O. Box 87 Paw Creek, NC 28130

2 1 Notice of Violation NOV-2020-LV-0303
Colonial Pipeline Company
Charlotte Delivery Facility
stored stormwater from the Outfall 009 dike the turbidity result was 23 ntu and the TSS result
was <25 mg/I. In March 2020 the stormwater from the Outfall 007 and Outfall 009 areas
continued to be stored in the frac tanks and was held for the entire month of March 2020
pending treatment.
Soil disturbing activities in and around the Outfall 007 and 009 dike areas ended in March 2020.
The silty ballast (gravel) was removed from these two diked areas. A layer of geotextile fabric
was installed in both dikes and covered with clean, new ballast. A vegetative cover has been re-
established along the dike walls and adjacent areas where the disturbed soil run-off had been
contributing to the exceedances.
There were no new exceedances for the months of March, April, or May 2020.
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.
Spilsy,
J
Manager, Operations
Enclosure
Cc: John W. Culbreath - Environmental Specialist; Operator -in -Responsible Charge