NC0031038_NOV-2020-LV-0303 Response_20200625

Jeff Titus
Operations Manager
June 25, 2020
1
li
Phone: [phone]
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. NC0031038
Colonial Pipeline Company - Charlotte Delivery Facility
Mecklenburg County
Dear Mr. Basinger:
MENRI
WQ OS
`u REGIONAL
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 I 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.
Sin erely,
J/ff Titus
Manager, Operations
Enclosure
Cc: John W. Culbreath - Environmental Specialist; Operator -in -Responsible Charge
Colonial Pipeline Company

HaloKlear®
NATURAL FLOCCULANTS
The best water treatment system for
your business and the environment
DUAL PRODUCT SYSTEM (DPS)

HaloKlear products are used to treat storm, industrial and municipal
water, including pollutants in construction site runoff, by reversing
the process of water contamination through a combination of
advanced, environmentally friendly, natural flocculant technologies.
When it comes to handling dirty water, HaloKlear has built its
reputation on creating reliable, effective and safe solutions that
can solve all kinds of sediment control problems. HaloKlear's Dual
Product System (DPS) uses natural flocculants that completely
biodegrade through simple enzymatic activity, resulting in no
bioaccumulation. The primary active ingredients are commonly used
in the dietary supplement and food industries.
The HaloKlear Residual Test Kit is used to ensure excess flocculants
are not leaving the site. This knowledge is comforting for regulators,
f=f
contractors and the general public, who can rest assured that the
products are not going to cause harm to the environment.
Most importantly, HaloKlear's DPS has a best -in -class performance
and has proven itself under vastly varied conditions around the
world. It is used in systems ranging from active treatment for mobile
water treatment, semi -passive pumped water incorporating coarse
filtration and geotextile bags, and completely passive models, such
as bio-filtration and check dams, HaloKlear DPS is designed to
give contractors and industries in need of water treatment solutions
the essential tool they need to meet state and national discharge
regulations, as well as EPA Effluent Limitation Guidelines (ELGs).
EA R ADVANT AGE FOR YOUR OPERATION
We'll help you choose from a portfolio of HaloKlear biobased flocculants-from 100cvo biodegradable natural
flocculants to hybrid flocculants—all of which offer a greener alternative to commodity chemicals.
Effective alone or paired with other chemistries
Appropriate for active, semi -passive and passive applications
Use with existing equipment or as part of a customized product
✓` Ensure regulatory compliance with on -site residual testing capabilities

T
HaloKlear Dry and Liquid Formula Flocculants
The Dual Product System (DPS) uses biodegradable, natural flocculants that perform on a wide array of soil types and
pH ranges. In contrast to other products on the market, the HaloKlear Dual Product System creates dense flocs with
great shear strength and a low water content that settle very quickly. Solids can be efficiently removed from the water
column — increasing performance and productivity while keeping costs low. In addition, the HaloKlear DPS is extremely
flexible with a successful track record in active, passive, and semi -passive deployment.
LIQUID
DPS SYSTEM
• LBP-2101
• LiquiFloc
O Functions in active
treatment systems
DPS SYSTEM
• DBP-2100 socks
O GelFloc socks
• Functions in active
semi -passive and passive
treatment environments
LS
DPS SYSTEM
• MB Kits
n Functions in
passive treatment
environments
PART ONE
LBP-2101 = Liquid
DBP-2100 = Dry socks
DBP=2100 MB = Loose, dry
PART TWO
LiquiFloc = Liquid
GelFloc = Dry socks
GelFloc MB = Loose, dry
VARIABLES
Soil Types
Soil
Samples
Dose Rate
Calculation
Organic &
Biodegradable
Residual
Testing
Application
Range
COMPARISONS
---=HALOKLEAR DPS
The H
Kie
e is rio.n
works`on"
Dose rates can
HaloKlear:DP"S;
Yes- manufactured-f t
degrade through, enzyi
s.4n :ellcofi
HaloKlear offersan affordatile,resldual-te
used in the field for:Immedlate''resuhs
HaloKlearDRS Can
actiye"treatment-s ems,(Sand
Screens; ;etc.), A: et)
type of-flockgenerat
abilityto-retain fin_ ers
(i.e. driersOlids)
rtridges;"
rtefit due i the
er gtlf), i#s
et
PAMs (POLYACRYLAMIDES) GRANULAR,
POWDER & BLOCKS
Highly soil -specific (100s of different formulations)
The majority of soil samples must be collected and shipped to
manufacturer's lab for specific polyacrylamide selection, adding
time and cost
Dose rate calculation must be made by manufacturer after soil
sample is received at factory and analyzed, adding time and cost
Yes —derived from petroleum -based products
Laboratory analysis is needed, which can take several days,
adding time and cost
Polyacrylamides can only be used with passive and semi -
passive systems and not with active treatment systems,
because they will usually produce a gelatinous flock which
contains a high percentage of water and will stick/bind to the
filtration media (Le. Sand, Screens, etc.) making it difficult to
backwash and clean

HaloKlear DPS "Passive" Treatment Model:
• Acrylamide-free treatment system
• Lowest maintenance requirement
• No mechanized equipment requirement
• Can reduce footprint by up to 50%
• Minimizes or eliminates need for water storage
• Actual flow range dependent on Best Management
Practice (BMP) design and frequency/severity of
storm events
• Uses natural filtration and settling to reduce costs
• A cost-effective model for meeting EPA & ELG
requirements
• Easily applied to new and existing BMPs
• Lowest cost treatment system

HaloKlear DPS "Semi -Passive" Treatment Model:
• Delivers consistent results
• Acrylamide-free treatment system
Low maintenance requirement
Low mechanized equipment requirement
Significantly reduces footprint compared to
traditional active treatment systems
• Does not require backwashing
PICALRE$
• Requires HaloKlear SockMasterTM Manifold kit & pump; rated
100-500 GPM
• Low cost compared to traditional active treatment systems
• May use coarse filtration, settling, or both to improve cost
effectiveness
• Plug -in -play a variety of configurations including: BMPs,
dewatering bags, and recirculation systems
• May be used in conjunction with passive treatment models
• May involve contaminant and nutrient removal
HaloKlear DPS "Active" Treatment Model:
• Delivers consistent results
• Acrylamide-free treatment system
• Identical footprint to traditional active
treatment systems
• Reduced frequency of backwashing compared to traditional
active treatment systems
Actual flow range dependent on mechanized equipment and
pumping capabilities
Can reduce operational costs compared to traditional active
treatment systems
The use of HaloKlear natural flocculants enhances the
efficiency of most filtration equipment used in active
treatment systems, by aiding the capture of finer solids,
reducing the frequency of back -wash, allowing faster
settling of particles in settling tanks, and providing solids/
contaminants that have a lower percentage of water, which
reduces hauling and disposal costs.

INDUSTRIES
In the field, we all face the same problem — we must return water to the environment that meets discharge guidelines.
HaloKlear products are a complete line of cost-effective, innovative products that will meet your needs today. These
products are not only safe for the environment, but they have helped our customers solve their discharge problems,
while enhancing project economics in industries like:

ACCESSORIES
Convenient
Economical
Reliable
Dependable
Added Safety Layer
HaloKlear Residual Test Kit
The HaloKlear Residual Test Kit uses proven test
methods for detecting the presence of free residual
chitosan before it can leave the job site. Compared
to other test kits, this kit improves accuracy by
up to 25%. You can achieve results without the
hassle of using outside labs, while ensuring you
are compliant with local and federal discharge
regulations.
ACCREDITATIONS
Water QuGallotdl Seal Association
Zr
regon
epartment
of Transportation
Cal -EPA
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CDE
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HaLoKL
NATURAL FLOCCULANTS
e= provide °education and development for your sales team. Our team encourages you -_
io reach out to schedule a joint sales call or request access to our Dober Digital Lab:_
n addition to your: sales team,we provide_ on=site=training and development
for your field staff,
• e "treat your sample in our lab, and then work with you to apply our findings
to your field =site.
We will work directly with you _on -site '-and -in our
corporate lab to make sure you have the -best
O 11230 Katherine's Crossing I Woodridge, IL 60517
• Phone: [phone] I Toll Free: 800.323.4983
• www.dober.com
DIJBER
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