NC0081469_NOV-2022-MV-0181_Resp Rvcd_20230112

Colonial Pipeline Company
Maribeth D. Hughes, PE, CSP
Environmental Specialist
January 11, 2023
Ms. Stephanie Goss
Environmental Chemist
NCDEQ — Division of Water Resources
Raleigh Regional Office
3800 Barrett Drive
Raleigh, North Carolina 27609
Phone: [phone]
e-mail: [e-mail]
NC Dept of Environmental Quality
JAN Y 2 2023
Raleigh Regional Office
Re: Colonial Pipeline Company — RDU Station - NPDES Permit No. NC0081469
Notice of Violation NOV-2022-MV-0181
Dear Ms. Goss:
Colonial Pipeline Company (CPC) owns and operates the facility located at 1010 National
Guard Road in Raleigh, North Carolina. The facility is operated under the above -
referenced National Pollutant Discharge Elimination System (NPDES) permit number.
CPC received the above -referenced Notice of Violation (NOV) on January 4, 2023. The
NOV describes CPC's failure to report a value for phenols in the October 2022 Discharge
Monitoring Report (DMR). The subject DMR is enclosed. As noted within the DMR
comment section, the company that CPC uses to analyze its water samples, Pace
Analytical (Pace), forwarded the pertinent samples, which were collected for phenol
analysis, from Pace's Huntersville, North Carolina laboratory to Pace's Asheville, North
Carolina laboratory for analysis via an overnight delivery service, FedEx. That shipment
containing the pertinent samples was lost by FedEx while in transit between Pace's
Huntersville and Asheville laboratory locations. Once CPC became aware of the
situation, plans were made to collect additional samples, however no additional
discharges were occurring during the reporting period. Consequently, no sample
material/liquid was available to collect and analyze, and no data was available to report
for phenol. Colonial would also like to make you aware that the misplaced sample
shipment also contained discharge samples for CPC's Selma, North Carolina facility
(NPDES Permit No. NC0031011). Therefore, the October DMR for CPC's Selma facility
also failed to contain a value for phenols.
Upon CPC becoming aware of the above -described issue, the North Carolina Department
of Environmental Quality (NCDEQ) was immediately notified of the lost sample shipment
on November 18, 2022 via an email communication from Logan Hester of S&ME (CPC's
third -party environmental consultant) to NCDEQ's Tom Moore and Joe Corporon. See
enclosed email correspondence. At that time, guidance was provided to S&ME by
NCDEQ personnel (Tom Moore) regarding the issue; specifically, Mr. Moore explained,
7524 Kenstead Circle, Charlotte, North Carolina 28208 1
.colpipe.com

Colonial Pipeline Company
If [Colonial] experienced issues with [its] samples being lost in transfer to
the labs, [Colonial] would not have any data to report so [it] should provide
an explanation in the Comments of the report explaining why the sample
data is missing. This will provide the necessary information to DWR staff to
take into consideration during their review of the data. [Colonial] can then
proceed with certifying and submitting the report as it normally would.
Following the email exchange between Mr. Hester and Mr. Moore, Mr. Moore's
instructions were followed in preparing and submitting the DMR.
As previously explained, CPC collected the necessary samples, delivered the collected
samples to Pace for analysis using accepted chain -of custody procedures, and submitted
the DMR in a timely manner. Unfortunately, while the samples were in the custody of
FedEx as a result of Pace's activities, the samples were lost in transit; such circumstances
are outside of CPC's control and influence. It is CPC's belief that issuing a NOV to the
company because of mistakes and errors made by an independent third -party is improper
in this instance. Consequently, CPC respectfully requests that NCDEQ rescind the
above -referenced NOV.
If you require any additional information, or have any questions regarding this issue and
request, please contact me directly at [phone].
Sincerely,
'14
Maribeth Hughes, PE, CSP
Enc: October 2022 Discharge Monitoring Report;
November 18, 2022, e-mail correspondence between S&ME and NCDEQ.
Cc: John Wyatt, Colonial Pipeline Company (via email).
7524 Kenstead Circle, Charlotte, North Carolina 28
colpipe.com I Follow us: 0
8

NPDES PERMIT NO.: NC0081469 PERMIT VERSION: 5.0
FACILITY NAME: RDU Delivery facility CLASS: PC-1
OWNER NAME: Colonial Pipeline Company ORC: Stephen M Anderson
GRADE: PC -I ORC HAS CHANGED: No
eDMR PERIOD: 10-2022 (October 2022) VERSION: 1.0
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 00
PERMIT STATUS: Active
COUNTY: Wake
ORC CERT NUMBER: 988377
STATUS: Submitted
1 NO DISCHARGE*: NO
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'••• No Reporting Reason: ENFRUSE=No Flow-Reuse/Recycle; ENVWTHR=No Visitation —Adverse Weather; NOFLOW =No low; HOLIDAY = No Visitation — Holiday
Discharge Monitoring Report - Copy Of Record (COR_NC0081469_V : r 1.0_10_2022.pd1)

NPDES PERMIT NO.: NC0081469 PERMIT VERSION: 5.0
FACILITY NAME: RDU Delivery facility CLASS: PC -I
OWNER NAME: Colonial Pipeline Company ORC: Stephen M Anderson
GRADE: PC -I ORC HAS CHANGED: No
eDMR PERIOD: 10-2022 (October 2022) VERSION: 1.0
PERMIT STATUS: Active
COUNTY: Wake
ORC CERT NUMBER: 988377
STATUS: Submittcd
SAMPLING LOCATION: EFFLUENT DISCHARGE NO.: 001 N DISCHARGE*: NO (Continue)
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•"•' Nu Reporting Reason: ENFRUSE a No Flow-Reuse/Recycle; ENVWTHR = No Visitation — Adverse Weather, NOFLOW = No low: HOLIDAY = No Visitation — Holiday
Discharge Monitoring Report - Copy Of Record (COR_NC0081469 V r_1.0_10_2022.pdf)

NPDES PERMIT NO.: NC0081469 PERMIT VERSION: 5.0 PERMIT STATUS: Active
FACILITY NAME: RDU Delivery facility CLASS: PC-1 COUNTY: Wake
OWNER NAME: Colonial Pipeline Company ORC: Stephen M Anderson ORC CERT NUMBER: 988377
GRADE: PC -I ORC HAS CHANGED: No
eDMR PERIOD: 10-2022 (October 2022) VERSION: 1.0 STATUS: Submitted
COMPLIANCE STATUS: Compliant CONTACT PHONE #: [phone] SUBMISSION DATE: 11/18/2022
Electronically Certified by Gary Simcox on 2022-11-18 15:07:46.288
ORC/Certifier Signature:Gary Simcox
I certify that this report is accurate and complete to the best of my knowledge.
Phone #:[phone] Date
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially threatens public health or the environment.
Any information shall be provided orally within 24 hours from the time the permittee became aware of the circumstances. A written submission shall also be
provided within 5 days of the time the permittee becomes aware of the circumstances. The written submission shall be made as required by part I1.E.6 of the
NPDES permit.
Electronically Signed by Brian Smith on 2022-11-18 16:18:30.967
Permittee/Submitter Signature: ***Brian Smith
Phone #:[phone] Date
Permittee Address: 1010 National Guard Dr Raleigh NC 27605 Permit Expiration Date: 03/31/2023
I certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who managed the
system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for
knowing violations.
LAB NAME: Pace National
CERTIFIED LAB #: 12
PERSON(s) COLLECTING SAMPLES: Ben Kelly
CERTIFIED LABORATORIES
PARAMETER CODES
Parameter Code assistance may be obtained by visiting https://deq.nc.gov/about/divisions/water-resources/edmr/user-documentation.
FOOTNOTES
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: YES indicates that No Flow/Discharge occurred and, as a result, no data Is reported for any parameter on the DMR for the
entire monitoring period.
** ORC on Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then delegation of the signatory authority must be on file with the state per 15A NCAC 2B
.0506(b)(2XD).
Discharge Monitoring Report - Copy Of Record(COR_NC0081469_Ver_1.0_10_2022.pdf)

NPDES PERMIT NO.: NC0081469 PERMIT VERSION: 5.0
FACILITY NAME: RDU Delivery facility CLASS: PC-1
OWNER NAME: Colonial Pipeline Company ORC: Stephen M Anderson
GRADE: PC-1 ORC HAS CHANGED: No
eDMR PERIOD: 10-2022 (October 2022) VERSION: 1.0
Report Comments:
Samples were collected and delivered to thc Lab but Pace shipped thc samples for Phenols to their Asheville lab via Fe
submit for this event.
HERMIT STATUS: Active
COUNTY: Wake
ORC CERT NUMBER: 988377
TATUS: Submitted
x and they got lost during transit. We don't have data to

Hughes, Maribeth
From: Moore, Tom <[e-mail]>
Sent: Friday, November 18, 2022 2:34 PM
To: John Logan Hester
Cc: Michael Pfeifer; Hughes, Maribeth; Corporon, Joe
Subject: RE: [External] Issue with eDMR Validation - Colonial Pipeline
This message originated outside of S&ME. Please report this as phishing if it implies it is from an S&ME employee.
Mr. Hester,
The Validation is strictly a data check feature and validation warnings do not prevent the report from being
submitted. If you experienced issues with your samples being lost in transfer to the labs, you would not have any data
to report so you should provide an explanation in the Comments of the report explaining why the sample data is
missing. This will provide the necessary information to DWR staff to take into consideration during their review of the
data. You can then proceed with certifying and submitting the report as you normally would.
Thomas F. Moore
IT Business Systems Analyst II
NC DEQ/ Division of Water Resources
North Carolina Department of Information Technology
NCDIT
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: John Logan Hester <[e-mail]>
Sent: Friday, November 18, 2022 2:05 PM
To: Moore, Tom <[e-mail]>; Corporon, Joe <[e-mail]>
Cc: Michael Pfeifer <[e-mail]>; Hughes, Maribeth <[e-mail]>
Subject: [External] Issue with eDMR Validation - Colonial Pipeline
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to
Report Spam.
Good afternoon Tom,
We are running into an issue with the validation of two eDMRs for Colonial Pipeline: Selma Facility (# NC0031011) and
RDU Delivery Facility (# NC0081469) for the month of October. Samples were collected for the month and sent off for
laboratory analysis but were lost in transition with FedEx and therefore did not make it to the lab. Unfortunately, we
were unable to collect another sample as the outfalls were dry for the remainder of the month. S&ME is attempting to
complete the eDMR for these facilities now, but as we do not have results for certain constituents, the system does not
allow us to validate the eDMR. Could you please advise on how we should proceed?
1

Thank you!
Logan Hester
Environmental Staff Professional
r®r
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iMIIIWIr
S&ME
3201 Spring Forest Road
Raleigh, NC 27616 map
0: 919.872.2660
M: 910.640.7440
www.smeinc.com
2