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Home My WebLink AboutNC0081469_Fact Sheet_20230831DENR/DWR EXPEDITED FACT SHEET - NPDES PERMIT DEVELOPMENT NPDES Permit: NCO081469 2023 Renewal This form must be completed by Permit Writers for all expedited permits which do not require full Fact Sheets. Expedited permits are generally simple 100% domestics (e.g., schools, mobile home parks, etc.) that can be administratively renewed with minor changes, but can include facilities with more complex issues (Special Conditions, 303(d) listed water, toxicity testing, instream monitoring, compliance concerns). Facility and Stream Information Applicant/ Facility Name: Colonial Pipeline Company / RDU Delivery Facility Applicant Address: 411 Gallimore Dairy Road, Greensboro, NC Facility Address: 1010 National Guard Road, Raleigh, NC Facility Class/Permit Status: Grade I - Physical Chemical WPCS / Renewal Permitted Flow [as built] Not Limited Type of Waste 10% Ind. / 90% SW Receiving Stream UT to Crabtree Creek Stream Class / ID B; NSW / 27-33-(3.5) River Basin Neuse Subbasin 03-04-02 HUC 030202010801 USGSToo Car D23SE 7Q10 Sum Win cfs 0 0 1 30Q2 cfs 0 Avg. Stream Flow cfs 0 IWC % s/w [as -built] 100 County Wake Regional Office RRO Basic Information for Expedited Permit Renewal Permit Writer / Date Bradley Bennett / June 23, 2023 updated August 28, 2023 Does permit need daily max NH3 limits? No Does permit need TRC limits/language? No Does permit have toxicity testing? Yes Does permit have Special Conditions? Yes -Acute Toxicity, Rational Method and 625.1 Monitoring & Reporting Does permit have instream monitoring? No Stream on 303 d List? For w arameter? Only state-wide mercury Any compliance concerns? None Any modifications since last permit? None noted in the application New expiration date: i March 31, 2028 FACILITY OVERVIEW: The facility distributes refined petroleum products (jet fuel) through a pipeline and one onsite storage tank. The facility has an oil/water separator that collects drainage from the pipeline and appurtenances and then flows to a retention pond. Other onsite drainage flows directly to the retention pond. The pond discharges periodically. Flows associated with the system are mainly from stormwater but may also contain spills, washdown slab water, hydrostatic test water and prover loop calibration water. Facility treatment system components consist of: Underdrain system that collects stormwater, prover loop calibration water, slab washdown water, tank and pipeline hydrotest water Oil/water separator Retention pond APPLICATION The permittee originally submitted only EPA Form 2F with their renewal. In their application the facility had asked if they could be covered under the stormwater general transportation permit (NCG080000). They only have one small storage tank and are below 1 million gallons of storage. After discussion with the stormwater staff and review of past information it appears that the facility sometimes has wash water, prover loop water and tank and pipeline hydrostatic test water. The facility also has an oil/water separator accepting these, so it is best for the facility to stay under the wastewater permit. The permittee was asked to submit the proper forms - Form 1 and 2E (emails on June 1, 2023 and June 20, 2023). The facility provided these forms. The permittee notes that the facility is a fuel facility for RDU and that all fuel is contained in pipelines and one single fuel tank onsite. The applications note the use of one oil/water separator for treatment of stormwater and wastewater collected from around the pipeline and storage tank. The application notes discharge occurs during and after storm events. The outfall location is given as 35°51'10.1" /-78°47'38.13". The application indicates discharge of stormwater only, but previous applications and regional office inspection reports outline the existence of situations where wastewater from slab washdown, prover loop calibration test water and tank and pipeline hydrostatic test waters are also discharged. INSPECTION The most recent inspections occurred on February 27, 2020. There were no issues noted with the operation of the facility, or the receiving stream and only one data error was noted from a 2019 report. The inspection notes the onsite oil/water separator that collects flow and then sends to the retention basin as treatment components. Some area drainage is noted as flowing directly to the retention basin. The basin is outlined as discharging periodically. MONITORING DATA REVIEW: Parameter Units Min Max Avg Permit Limit Comments 21 values in 58 months or 0.36 per Flow (mg/L) 0.01 0.38 0.11 month TSS [E] (mg/L) < 2.5 21.55 7.12 30 MA / 45 DM 10 values less than; Highest actual value is 13.3 Turbidity ntu 1.40 17.00 6.94 50 instream No value > 17 Oil & Grease m L ( g/) < 0.49 5.56 2.51 All All but one value reported as less than; value was 5.56 Benzene µ L < 1.0 24.50 2.89 16 of 22 values less than 1 Toluene (µg/L) < 1.0 145.00 15.46 11 of 21 values less than 1; but 5 values> Allowable Cw - See RPA Discussion Eth lbenzene µ L < 1.0 37.90 4.25 14 of 22 values less than 1 Xylene (µg/L) < 1.0 226.00 29.19 11 of 22 values reported less than 1,2 or 3 MTBE µ L < 1.0 2.50 1.61 All values reported less than 1, 2 or 5 Phenolics (µg/L) 0.01 20.00 3.89 18 of 21 values reported less than but 2 > Allowable Cw- See RPA Discussion Naphthalene < 1.0 22.90 4.24 16 of 22 values less than 1 or 5; but 2 > Allowable Cw - See RPA Discussion MA -Monthly Average DM - Daily Max QA -Quarterly Average DA - Daily Average Summer - April through Oct Winter - Nov through March The data reviewed for the renewal is from August 2018 through May 2023. Colonial Pipeline Company / RDU Delivery Facility Fact Sheet NPDES Renewal 2023 - June 21, 2023 - Updated August 28, 2023 Page 2 REVIEW OF PERMIT PARAMETERS AND LIMITS: An RPA evaluation was done using the Bulk Terminals RPA spreadsheet. The standards used in the evaluation were for Human Health concerns where the parameter is noted as a carcinogen and freshwater standard where the parameter is a non -carcinogen. RPA results are discussed under the various parameters below. Flow -When discharging the facility is operating on average at around 0.11MGD. The facility reported 21 discharge events over the 58 reporting months evaluated in the permit renewal. This is an average of around one discharge event every three (3) months. The maximum daily discharge reported was 0.38 MG and the maximum monthly average discharge was 0.208 MGD. This maximum monthly average was used in the Reasonable Potential Analysis (RPA) review. TSS- The were no violations for TSS in this permit cycle and 50% of reporting values were less than the reporting level (less than level varied). TSS still remains a good general indicator for this type of facility. Turbidity - No turbidity value was reported above 17 NTU. The RPA evaluation estimated a max value of 26.2 which is below the standard of 50 NTU. Maintain quarterly monitoring. In accordance with bulk terminal guidance the footnote for compliance with the instream 50 NTU standard has been added to the permit. Oil and Grease - The oil and grease results for this permit cycle did not show as being a problem area. Oil and grease still remains a good general indicator for this type of facility. Benzene. Toluene. Ethylbenzene & Xylene (BTEX) - For each of these parameters at least half of the reported results came in at "less than" values. However, they all had detected levels in six or more of the samples so monthly monitoring should remain for all. In the RPA evaluation for these parameters Toluene did show reasonable potential with five (5) values higher than the allowable Cw and a maximum predicted value almost thirty (30) times the allowable level. Toluene will have a limit of 11µg/L added to the permit with a compliance schedule. See Supplement to Fact Sheet MTBE - All sampling results were below detection level and no reasonable potential was noted in the RPA analysis. By the bulk terminal guidance, monitoring frequency will be maintained at quarterly. Phenolic Compounds - The reported Phenolic Compound data was a little questionable as some data was reported as mg/L and some as µg/L. The permittee was asked to verify this data in an email on June 21, 2023. The permittee responded by email June 21, 2023 and corrected two of the values. All values were converted to µg/L for the RPA analysis. There were two reported values that may be inaccurate since they were two and three orders of magnitude above other reported values. In the RPA evaluation data did show reasonable potential with two (2) values above the allowable Cw and a maximum predicted value eighty (8) times the allowable Cw. A limit of 300µg/L will be added to the permit for Total Recoverable Phenols with a compliance schedule. See Supplement to Fact Sheet - Limit removed from final permit. Method 625.1 Parameters - No information was included in the application material or in submitted DMR data to indicate detection of any of the 625 parameters other than ones that were already being monitored in the permit (BTEX for example). DMRs that indicated completion of the semi-annual tests were reviewed to see if any comments were added to indicate any detections. Those reviews did not show any detected parameters. Language in the permit has been updated to more accurately reference EPA Method 625.1. Naphthalene - Sixteen (16) of twenty-two (22) reported results came in at "less than" values. However, some of the remaining 6 values were relatively elevated and the RPA evaluation did show reasonable potential with two (2) values higher than the allowable Cw and a maximum predicted value three (3) times the allowable level. Naphthalene will have a limit of 12 µg/L added to the permit with a compliance schedule. See Supplement to Fact Sheet WET Testing - The facility has passed all its annual toxicity tests. The 2018 permit renewal had indicated a change to quarterly WET monitoring. There was no reason given for that change and the facility had been Colonial Pipeline Company / RDU Delivery Facility Fact Sheet NPDES Renewal 2023 — June 21, 2023 — Updated August 28, 2023 Page 3 passing all of it's WET sampling. The quarterly change did not take place in the BIMS settings for the permit and the permitee continued to report annually. Since there does not appear to be a reason for quarterly testing, this permit has taken the requirement back to annual. The special condition in the permit has been modified to address annual WET requirements and has added language related to electronic submittal of the AT form. Other Parameter / Limit Issues • The 2018 permit did not contain the footnote requiring turbidity to meet the instream standard. • The 2018 permit did not contain the footnote associated with oil and grease monitoring from a quiescent pool. • The 2018 permit removed the footnote requiring certain parameters to be sampled concurrently with WET sampling. The Aquatic Toxicology Branch staff have verified that they want to maintain this connection for these parameters to assess any potential toxicity issues. COMPLIANCE: This facility has not had any assessed violations and has not had an enforcement action since 1993. CIUTFALL LOCATION: The outfall location has been changed to be consistent with the location noted in the permittee's application, which appears to more accurately reflect the location of the outfall point. FILE HISTORY REVIEW SUMMARY Original application information from 1991 indicated stormwater from the manifold yard collected by underground drainage system and routed to an oil/water separator. Intermittent discharge also noted from prover loop calibration water, washdown slab water, and drainage generated during deliveries of product to shipper. These flows were all noted as going to the o/w separator (outfall 001). The application also notes potential tank hydrotest water from a single onsite utility/relief tank and from pipeline hydrotest water. These flows were requested for direct discharge possibly after any needed treatment (outfall 0O2). April 3, 1992 - Wasteload Allocation (WLA)- Established same limits for both outfalls based on discharge to zero flow stream. SS Oil & Grease Turbidity pH (mg/L) (mg/L) (NTU) (std units) MA DM MA DM DM DM 0.1 0.2 30 60 50 6-9 Also included Episodic Acute toxicity monitoring and monitoring for BTEX and a list of chemicals under approved EPA methods. Requested a reopener in permit to add other parameters based on toxicity results. June 5, 1992 - Permit Issuance - The permit was issued with conditions relating to the construction of the treatment system prior to dischar e. The permit included Outfalls 001 and 002 with identical parameters: SS Oil & Grease Turbidity pH (mg/L) (mg/L) (NTU) (std units) MA DM MA/DM DM DM 0.1 0.2 30 60 50 6-9 Permit also required episodic WET sampling, monthly lead monitoring and monitoring for a number of organics. The permittee adjudicated this permit and the Division made changes to remove ATC requirements since the system was already built, modify the WET testing requirements, remove monitoring for lead, dibromoethane, 1, 2 -dichloro ethane, isopropyl ether and MTBE. • March 8, 1993 - - WLA - TSS Oil & Grease Turbidity pH (m /L) m L NTU std units Colonial Pipeline Company / RDU Delivery Facility Fact Sheet NPDES Renewal 2023 — June 21, 2023 — Updated August 28, 2023 Page 4 DM DM DM DM 45 45 50 6-9 Also monitoring for Phenols, Naphthalene and BTEX. Toxicity test required for first five events and then annually. The document notes that the previous permit is in adjudication. • May 26, 1999 -Permit Renewal -(no information is in the file for permit between the original 1992 permit and this one) Permit has two outfalls with the same effluent requirements: TSS Oil & Turbidity (mg/L) Grease Total N Total P DM m /L (NTU) Report concentration 45 Monitor Monitor and monthly and Monitor annual Load The permit also required annual WET sampling and semi-annual sampling of EPA 624/625 parameters. The permit effluent pages outlined the treated wastewater discharged was described as primarily stormwater, prover loop calibration water, washdown slab water and tank and pipeline hydrotest water. Changes in the permit were consistent with SOP for Oil Storage Facilities. September 3, 1999 - Clarification letter to the permittee to answer questions about implementation of permit requirements. March 16, 2004 - Permit Renewal - This renewal utilized updated 2001 SOP Oil and Petroleum Storage Facilities. The permit included the following effluent limit requirements: TSS Oil & Grease* Turbidity Benzene* Toluene* Ethylbenzene* Xylene* (mg/L) (mg/L) (NTU) (µg/L) (µg/L) (µg/L) (µg/L) DM DM DM DM DM DM meet 45 45 instream 71.4 11 383 88.5 50 *These parameters have added or modified limits. The permit also continued to require annual WET testing, and EPA Method 625(2/year) and added monitoring for MTBE (monthly) The permit moved reference to the wastewater sources (stormwater, hydrostatic test water, slab washdown water and prover loop water) from the effluent page to the supplement page. The permit removed outfall 002 based on input from the regional office that all flow could be directed to 001. Based on monitoring results and no indication of sources, nutrient monitoring (TN and TP) was removed from the permit. April 16, 2008 - Permit Renewal - This permit appears to have been reissued essentially the same as the 2004 permit. The permit cover letter had some inaccurate references to another unrelated facility. September 19, 2013 - Permit Renewal - This permit added Naphthalene monitoring to assess presence of diesel fuel; removed the oil and grease footnote for sampling a quiescent zone; removed limits for BTEX and Oil and Grease but maintained monthly monitoring; required monitoring of certain parameters along with WET sampling; added parameter codes; removed the turbidity footnote referencing 50 NTU standard and removed the reference in the supplement page to sources other than stormwater (application noted the continued presence of test waters and washdown water). July 15, 2018 - Permit Renewal - This renewal added requirements for electronic submittal of DMR data; added clarification on use of the Rational Method for flow calculation; changed the oil and grease parameter code to 00556; updated WET sampling to quarterly (there is no reason given for the change and the permittee had passed all previous test, it does not look like this was updated in BIMS requirements); removed footnote requiring sampling of some parameters in conjunction with WET testing; added regulatory citations and updated effluent table measurements. PROPOSED PERMIT CHANGES: • Updated eDMR requirements to be consistent with final EPA rule. • Added or updated regulatory citations throughout permit as needed. • Language in the Supplement to Permit Cover Page has been updated for clarity. Colonial Pipeline Company / RDU Delivery Facility Fact Sheet NPDES Renewal 2023 — June 21, 2023 — Updated August 28, 2023 Page 5 • Monitoring for the EPA Method 625 has been updated to reflect EPA Method 625.1. • Based on RPA evaluations permit limits with two-year compliance schedules have been added for Tolunen (11 µg/L); Total Recoverable Phenolics (300 µg/L) and Naphthalene (12 µg/L) • Footnotes have been added in the effluent table for: - Turbidity requirement to meet instream 50 NTU - Oil and Grease monitoring from a quiescent pool - Parameters that must be sampled concurrently with WET sampling - Reference to new Section A.(4.) that provides information on monitoring and reporting EPA 625.1 parameters. - Compliance Schedule for added permit limits. • With the addition of these footnotes some of the effluent table footnotes have been renumbered. • Footnote 7 for Toxicity has been modified to include reference to the specific parameters that WET testing should be done concurrently with. • Special Condition A.(3.) - This condition has been updated to be consistent with the required annual WET requirements. The language also notes the ability to now submit AT forms electronically. • Section A.(4) outlining specific monitoring and reporting requirements for EPA Method 625.1 has been added to the permit. • Permit Map - Map information has been updated. PROPOSED SCHEDULE FOR PERMIT ISSUANCE: Draft Permit to Public Notice: June 27, 2023 Permit Scheduled Effective Date: October 1, 2023 STATE CONTACT: If you have questions concerning the above or the attached documents, please contact Bradley Bennett at bradley.bennett@deq.nc.gov. . SUPPLEMENT TO FACT SHEET - RESPONSE TO PERMITTEE COMMENTS: Resolve Environmental submitted comments on the draft permit on behalf of Colonial Pipeline (August 9, 2023 letter). The Division reviewed these comments and provided responses through an email on August 16, 2023 (copy attached in the Fact Sheet). • Colonial questioned the inclusion of a limit in the permit for total recoverable phenolics and noted a data point that was inaccurately reported. In subsequent correspondence with Resolve and Colonial staff it was found that five (5) data points were inaccurately reported over the permit cycle. The correct data was provided and DWR staff re -ran the RPA analysis and found that no reasonable potential exists for total recoverable phenolics. (See pages 8-14 of Fact Sheet for RPA analysis with corrected data) Monitoring will be maintained in the permit, but the proposed limit has been removed. References to Total Recoverable Phenolics in the Compliance Schedule in Section A.(5.) have been removed. The permittee was advised to ensure that all monitoring data is reported accurately in the eDMR system for future submittals. • Colonial's comments noted a discrepancy in the reporting frequency for Method 625.1 parameters in the draft permit. The final permit has been corrected so that the monitoring frequency for these parameters in the Effluent Table and in Section A.(4.) each reference semi-annual (2/year) monitoring. • Colonial raised issues associated with the inclusion of limits for toluene and naphthalene in the permit. The permittee requested a copy of the RPA analysis and noted that the discharge outfall included stormwater runoff from offsite that could impact the discharge. A copy of the RPA results was provided with the August 16t" email and the email outlined the RPA process in accordance with 40 CFR 122.44 (d) (i). The Division understands Colonial's concerns with potential offsite contributions, but is required to address discharges in a manner that assures proper limitations are established where discharge of a Colonial Pipeline Company / RDU Delivery Facility Fact Sheet NPDES Renewal 2023 — June 21, 2023 — Updated August 28, 2023 Page 6 pollutant has reasonable potential to impact water quality standards. Colonial has been given a five-year compliance schedule and may choose to review alternatives that could remove offsite contributions from the discharge during this compliance window. As long as these levels of pollutants are a part of the discharge the Division is obligated to include these limitations in the permit. Colonial Pipeline Company / RDU Delivery Facility Fact Sheet NPDES Renewal 2023 — June 21, 2023 — Updated August 28, 2023 Page 7 2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY Table 1. Project Information ❑ CHECK IF HQW OR ORW Facility Name WWTP/WTP Class NPDES Permit Outfall Flow, Qw (MGD) Receiving Stream Stream Class 7Q10s (cfs) 7Q10w (cfs) 30Q2 (cfs) CIA (cfs) 1Q10s (cfs) Data Source(s) ❑ CHECK TO APPLY MODEL Colonial Pipeline Company LP Grade I PC WPCS NCO081469 001 0.20800 UT to Crabtree Creek B; NSW 0.00 0.00 0.00 0.00 0.00 BIMS data from Aug 2018 to May 2023 Flow is Maximum Monthly Flow => 0.208 MGD Follow directions for data entry. In some cases a comment menu list the available choices or a dropdown menu will provide a list you may select from. Error message occur if data entry does not meet input criteria. Par01 Par02 Par03 Par04 Par05 Par06 Par07 Par08 Par09 Par10 Par11 Par12 Par13 Par14 Par15 Par16 Par17 Par18 Par19 Par20 Par21 Par22 Table 2. Parameters of Concern Name Tye Chronic Modifier Acute PQL Units Benzene C 1.19 WS pg/L Benzene C 51 HH pg/L Toluene NC 11 FW pg/L Toluene NC 57 WS pg/L Toluene NC 520 HH pg/L Ethylbenzene NC 68 WS pg/L Ethylbenzene NC 130 HH pg/L Ethylbenzene NC 97 FW pg/L Xylenes Mixture NC 6200 WS pg/L Xylenes Mixture NC 670 FW pg/L Xylenes Mixture NC 57000 HH pg/L Napthalene NC 400 WS pg/L Napthalene NC 12 FW pg/L Napthalene NC 950 HH pg/L MTBE (Methyl Tertiary -butyl Ether) C 19 WS pg/L MTBE (Methyl Tertiary -butyl Ether) C 34000 FW pg/L MTBE (Methyl Tertiary -butyl Ether) C 1500 HH pg/L Phenolic Compounds NC 300 FW pg/L Phenol NC 4000 WS pg/L Phenol NC 300000 HH pg/L Turbidity NC 50 FW NTU NCO081469_Bulk-Storage FW - 9595 GENERIC non —hardness RPA2016_53_20230827, input 8/28/2023 Colonial Pipeline Company LP REASONABLE POTENTIAL ANALYSIS Outfall 001 NCO081469 2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence QW = 0.208 MGD MAXIMUM DATA POINTS = 58 Qw (MGD) = 0.20800 WWTP/WTP Class: Grade I PC WPCS 1Q10S (cfs) = 0.00 IWC @ 1Q10S = 100.000000% 7Q10S (cfs) = 0.00 IWC @ 7Q10S = 100.000000% 7Q10W (cfs) = 0.00 IWC @ 7Q10W = 100.000000% 30Q2 (cfs) = 0.00 IWC @ 30Q2 = 100.000000% Avg. Stream Flow, QA (cfs) = 0.00 IWC @ QA = 100.000000% Receiving Stream: UT to Crabtree Creek Stream Class: B; NSW PARAMETER STANDARDS & CRITERIA (2) w REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE 11) J a Zri NC WQS / Applied '/z FAV / Chronic Standard Acute # Det. Max Pred Cw Allowable Cw Acute: NO WQS Benzene C 51 HH µg/L 22 6 46.3 No RP; Max Pred > 50 % Allowable _ _ --Chronic: ---- 51.00 -- --------------------------- No value > Allowable Cw Acute: NO WQS Toluene NC 11 FW µg/L 21 10 295.8 RP shown - apply Monthly Monitoring with Limit _ _ ---- _ _ --Ch-- Chronic: -11.00 --------------------------- 5 values > Allowable Cw Acute: NO WQS Ethylbenzene NC 97 FW µg/L 22 8 73.5 _ _ _ _ --Chronic: ---- -- No RP; Max Pred > 50 % Allowable --------------------------- 97.00 No value > Allowable Cw Acute: NO WQS Xylenes Mixture NC 670 FW µg/L 22 11 422.E _ --Chronic:-- No RP; Max Pred > 50 % Allowable --------------------------- No value > Allowable Cw Acute: NO WQS Napthalene NC 12 FW µg/L 22 6 37.1 -- ------- _ro_ _ _ RP shown - apply Monthly Monitoring with Limit --------------------------- 1 Chnic:12.00 2 values > Allowable Cw Acute: NO WQS MTBE (Methyl Tertiary -butyl Ether) C 1500 HH µg/L 22 0 NO DETECTS No detects _ _ --- _ _ _ —Ch— Chronic: 1,500.00 --------------------------- Max MDL = 5 Acute: NO WQS No RP, Predicted Max < 50 % of Allowbale Cw - Phenolic Compounds NC 300 FW µg/L 21 2 61.2 No Monitoring required —Chronic: — —30-- -- --------------------------- No value > Allowable Cw Acute: NO WQS No RP; Max Pred > 50 % Allowable Turbidity NC 50 FW NTU 14 14 26.2 _ _ --Chronic: ---- 50.00 -- --------------------------- No value > Allowable Cw Acute: 0 0 N/A _ ronic:------------------- — Chronic: NC0081469_Bulk-Storage FW - 9595 GENERIC non hardness RPA2016_53_20230827, rpa Page 1 of 1 8/28/2023 REASONABLE POTENTIAL ANALYSIS z Use "PASTE SPECIAL Benzene Values" then "COPY". Maximum data points = 58 Date Data BDL=1/2DL Results 1 10/12/2018 < 1.000 0.5 Std Dev. 5.7238 2 2/21/2019 < 1.000 0.5 Mean 2.8909 3 2/11/2020 11.000 11 C.V. 1.9799 4 6/25/2020 < 1.000 0.5 n 22 5 12/15/2020 < 1.000 0.5 6 8/18/2021 < 1.000 0.5 Mult Factor = 1.8900 7 9/23/2021 < 1.000 0.5 Max. Value 24.5 Ng/L 8 10/29/2021 < 1.000 0.5 Max. Pred Cw 46.3 gg/L 9 2/9/2022 < 1.000 0.5 10 3/11/2022 < 1.000 0.5 11 4/7/2022 < 1.000 0.5 12 5/24/2022 < 1.000 0.5 13 7/11/2022 < 1.000 0.5 14 8/22/2022 < 1.000 0.5 15 10/3/2022 < 1.000 0.5 16 11/16/2022 3.800 3.8 17 12/1/2022 2.300 2.3 18 1 /5/2023 10.800 10.8 19 2/1/2023 24.500 24.5 20 3/13/2023 3.200 3.2 21 4/10/2023 < 1.000 0.5 22 5/19/2023 < 1.000 0.5 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 NCO081469_Bulk-Storage FW - 9595 GENERIC non —hardness RPA2016_53_20230827, data - 1 - 8/28/2023 REASONABLE POTENTIAL ANALYSIS 3 Toluene Use "PASTE SPECIAL Values" then "COPY". 8 Ethylbenzene Use "PASTE SPECIAL Values" then "COPY". 10 Maximum data points Maximum data points = 58 = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 10/12/2018 < 1.000 0.5 Std Dev. 34.6359 1 10/12/2018 < 1.000 0.5 Std Dev. 9.1394 1 2 2/21/2019 < 1.000 0.5 Mean 15.4633 2 2/21/2019 < 1.000 0.5 Mean 4.2509 2 3 2/11/2020 68.200 68.2 C.V. 2.2399 3 2/11/2020 23.300 23.3 C.V. 2.1500 3 4 6/25/2020 < 1.000 0.5 n 21 4 6/25/2020 < 1.000 0.5 n 22 4 5 12/15/2020 < 1.000 0.5 5 12/15/2020 1.100 1.1 5 6 8/18/2021 < 1.000 0.5 Mult Factor = 2.0400 6 8/18/2021 < 1.000 0.5 Mult Factor = 1.9400 6 7 9/23/2021 < 1.000 0.5 Max. Value 145.0 Ng/L 7 9/23/2021 < 1.000 0.5 Max. Value 37.9 Ng/L 7 8 10/29/2021 1.300 1.3 Max. Pred Cw 295.8 gg/L 8 10/29/2021 < 1.000 0.5 Max. Pred Cw 73.5 gg/L 8 9 2/9/2022 < 1.000 0.5 9 2/9/2022 < 1.000 0.5 9 10 3/11/2022 1.900 1.9 10 3/11/2022 1.100 1.1 10 11 4/7/2022 < 1.000 0.5 11 4/7/2022 < 1.000 0.5 11 12 5/24/2022 1.700 1.7 12 5/24/2022 2.500 2.5 12 13 7/11/2022 < 1.000 0.5 13 7/11/2022 < 1.000 0.5 13 14 10/3/2022 < 1.000 0.5 14 8/22/2022 < 1.000 0.5 14 15 11/16/2022 24.600 24.6 15 10/3/2022 < 1.000 0.5 15 16 12/1/2022 10.200 10.2 16 11/16/2022 9.600 9.6 16 17 1 /5/2023 48.800 48.8 17 12/1 /2022 < 1.000 0.5 17 18 2/1/2023 145.000 145 18 1/5/2023 7.420 7.42 18 19 3/13/2023 15.200 15.2 19 2/1/2023 37.900 37.9 19 20 4/10/2023 2.330 2.33 20 3/13/2023 3.600 3.6 20 21 5/19/2023 < 1.000 0.5 21 4/10/2023 < 1.000 0.5 21 22 22 5/19/2023 < 1.000 0.5 22 23 23 23 24 24 24 25 25 25 26 26 26 27 27 27 28 28 28 29 29 29 30 30 30 31 31 31 32 32 32 33 33 33 34 34 34 35 35 35 36 36 36 37 37 37 38 38 38 39 39 39 40 40 40 41 41 41 42 42 42 43 43 43 44 44 44 45 45 45 46 46 46 47 47 47 48 48 48 49 49 49 50 50 50 51 51 51 52 52 52 53 53 53 54 54 54 55 55 55 56 56 56 57 57 57 58 1 58 1 58 NC0081469_Bulk-Storage FW - 9595 GENERIC non -hardness RPA2016_53_20230827, data -2- 8/28/2023 REASONABLE POTENTIAL ANALYSIS Xylenes Mixture Use "PASTE SPECIAL Values" then "COPY". 13 Napthalene Use "PASTE SPECIAL Values" then "COPY". 17 Maximum data points Maximum data points = 58 = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 10/12/2018 < 1.000 0.5 Std Dev. 55.69 1 10/12/2018 < 1.000 0.5 Std Dev. 5.1200 1 2/21/2019 1.700 1.7 Mean 29.19 2 2/21/2019 < 1.000 0.5 Mean 4.2377 2 2/11/2020 96.600 96.6 C.V. 1.9078 3 2/11/2020 14.100 14.1 C.V. 1.2082 3 6/25/2020 < 2.000 1 n 22 4 6/25/2020 < 1.000 0.5 n 22 4 12/15/2020 7.600 7.6 5 12/15/2020 2.200 2.2 5 8/18/2021 < 3.000 1.5 Mult Factor = 1.8700 6 8/18/2021 < 5.000 2.5 Mult Factor = 1.6200 6 9/23/2021 < 3.000 1.5 Max. Value 226.0 tlg/L 7 9/23/2021 < 5.000 2.5 Max. Value 22.9 ug/L 7 10/29/2021 < 3.000 1.5 Max. Fred Cw 422.6 Ng/L 8 10/29/2021 < 5.000 2.5 Max. Fred Cw 37.1 Ng/L 8 2/9/2022 < 3.000 1.5 9 2/9/2022 < 5.000 2.5 9 3/11/2022 5.800 5.8 10 3/11/2022 < 5.000 2.5 10 4/7/2022 < 3.000 1.5 11 4/7/2022 < 5.000 2.5 11 5/24/2022 19.200 19.2 12 5/24/2022 < 5.000 2.5 12 7/11/2022 < 3.000 1.5 13 7/11/2022 < 5.000 2.5 13 8/22/2022 < 3.000 1.5 14 8/22/2022 < 5.000 2.5 14 10/3/2022 < 3.000 1.5 15 10/3/2022 < 5.000 2.5 15 11/16/2022 74.700 74.7 16 11/16/2022 5.900 5.9 16 12/1 /2022 15.100 15.1 17 12/1 /2022 < 5.000 2.5 17 1 /5/2023 117.000 117 18 1 /5/2023 7.730 7.73 18 2/1/2023 226.000 226 19 2/1/2023 22.900 22.9 19 3/13/2023 58.800 58.8 20 3/13/2023 6.400 6.4 20 4/10/2023 4.670 4.67 21 4/10/2023 < 5.000 2.5 21 5/19/2023 < 3.000 1.5 22 5/19/2023 < 5.000 2.5 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 NC0081469 Bulk -Storage FW - 9595 GENERIC non -hardness RPA2016_53_20230827, data -3- 8/28/2023 REASONABLE POTENTIAL ANALYSIS MTBE (Methyl Tertiary -butyl Ether) Use "PASTE SPECIAL Values" then "COPY". 18 Phenolic Compounds Use "PASTE SPECIAL Values" then "COPY". 21 Maximum data points Maximum data points = 58 = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 10/12/2018 < 2.000 1 Std Dev. 0.9992 1 10/12/2018 < 10 5 Std Dev. 8.5063 1 2/21/2019 < 1.000 0.5 Mean 1.6136 2 2/21/2019 < 20 10 Mean 13.4286 2 2/11/2020 < 1.000 0.5 C.V. 0.6192 3 2/11/2020 < 20 10 C.V. 0.6334 3 6/25/2020 < 1.000 0.5 n 22 4 6/25/2020 < 20 10 n 21 4 12/15/2020 < 1.000 0.5 5 12/15/2020 < 20 10 5 8/18/2021 < 5.000 2.5 Mult Factor = 1.3300 6 8/18/2021 < 20 10 Mult Factor = 1.3600 6 9/23/2021 < 1.000 0.5 Max. Value 2.5 tlg/L 7 9/23/2021 < 20 10 Max. Value 45.0 tlg/L 7 10/29/2021 < 5.000 2.5 Max. Fred Cw O DETECTS Ng/L 8 10/29/2021 < 20 10 Max. Fred Cw 61.2 Ng/L 8 2/9/2022 < 5.000 2.5 9 2/9/2022 < 20 10 9 3/11/2022 < 5.000 2.5 10 3/11/2022 22 22 10 4/7/2022 < 5.000 2.5 11 4/7/2022 < 20 10 11 5/24/2022 < 5.000 2.5 12 5/24/2022 < 20 10 12 7/11/2022 < 5.000 2.5 13 7/11/2022 < 20 10 13 8/22/2022 < 1.000 0.5 14 8/22/2022 < 20 10 14 10/3/2022 < 5.000 2.5 15 11 /16/2022 < 20 10 15 11/16/2022 < 5.000 2.5 16 12/1/2022 < 20 10 16 12/1 /2022 < 5.000 2.5 17 1 /5/2023 < 40 20 17 1 /5/2023 < 1.000 0.5 18 2/1 /2023 45 45 18 2/1/2023 < 5.000 2.5 19 3/13/2023 < 20 10 19 3/13/2023 < 5.000 2.5 20 4/10/2023 < 40 20 20 4/10/2023 < 1.000 0.5 21 5/19/2023 < 40 20 21 5/19/2023 < 1.000 0.5 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 NCO081469_Bulk-Storage FW - 9595 GENERIC non -hardness RPA2016_53_20230827, data 4 8/28/2023 REASONABLE POTENTIAL ANALYSIS Use "PASTE SPECIAL Turbidity Values" then "COPY" Maximum data points = 58 Date Data BDL=1/2DL Results 10/12/2018 8.500 8.5 Std Dev. 4.1396 2/21/2019 7.100 7.1 Mean 6.9357 2/11/2020 9.300 9.3 C.V. 0.5969 6/25/2020 2.700 2.7 n 14 12/15/2020 10.400 10.4 9/23/2021 3.200 3.2 Mult Factor = 1.5400 10/29/2021 3.700 3.7 Max. Value 17.0 NTU 2/9/2022 6.600 6.6 Max. Fred Cw 26.2 NTU 3/ 11 /2022 1.400 1.4 4/7/2022 8.300 8.3 8/22/2022 2.200 2.2 11/16/2022 8.300 8.3 1 /5/2023 17.000 17 4/10/2023 8.400 8.4 NCO081469 Bulk -Storage FW - 9595 GENERIC non —hardness RPA2016_53_20230827, data - 5 - 8/28/2023 AFFIDAVIT OF PUBLICATION Account # Order Number Identification Order PO Amount Cols Depth 19489 443772 i_ Print Legal Ad-IPL01312000 - IPLO131200 $444.40 1 44 L Attention: Wren Thedford DEPARTMENT OF WATER RESOURCES - RALEIGH 1617 MAIL SERVICE CENTER RALEIGH, NC 276991617 meagen.benton@ncdenr.gov Public Notice North Carolina Environmental Man- agement Commission/NPDES Unit 1617 Mail Service Center Raleigh, NC 27699-1617 Notice of Intent to Issue a NPDES Wastewater Permit NCO081469 RDU Delivery Facility. The North Carolina Environmental Management Com- mission proposes to issue a NPDES wastewater discharge permit to the person(s) listed below. Written com- ments regarding the proposed permit will be accepted until 30 days after the publish date of this notice. The Director of the NC Division of Water Resources (DWR) may hold a public hearing should there be a significant degree of public interest. Please mail comments and/or information re- quests to DWR at the above address. Interested persons may visit the DWR at 512 N. Salisbury Street, Raleigh, NC 27604 to review the information on file. Additional intormation on NP- DES permits and this notice may be found on our website: https://deq. nc.gov/public-notices-hearings,or by calling (919) 707-3601. . Colonial Pipeline Company [4111 Gallimore Dairy Road; Greensboro, NC 28214] has requested renewal of NPDES per- mit NCO081469 for its RDU Delivery Facility, located in Wake County. This permitted facility discharges treated wastewater to a UT to Crabtree Creek, a class B; NSW water in the Neuse River Basin. Some of the parameters in the permit are water quality limited. This discharge may affect future al- locations in this segment of Crabtree Creek. IPLO131200 Jul 14 2023 STATE OF NORTH CAROLINA COUNTY OF WAKE, COUNTY OF DURHAM Before the undersigned, a Notary Public of Dallas County, Texas, duly commissioned and authorized to administer oaths, affirmations, etc., personally appeared Tara Pennington, who being duly sworn or affirmed, according to law, cloth depose and say that he or she is Accounts Receivable Specialist of the News & Observer Publishing Company, a corporation organized and doing business under the Laws of the State of North Carolina, and publishing a newspaper known as The News & Observer, Wake and State aforesaid, the said newspaper in which such notice, paper, document, or legal advertisement was published was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of Section 1- 597 of the General Statutes of North Carolina and was a qualified newspaper within the meaning of Section 1-597 of the General Statutes of North Carolina, and that as such he or she makes this affidavit; and is familiar with the books, files and business of said corporation and by reference to the files of said publication the attached advertisement for DEPARTMENT OF WATER RESOURCES - RALEIGH was inserted in the aforesaid newspaper on dates as follows: 1 insertion(s) published on: 07/14/23 �((Y'3 1 certify or declare) under penalty of perjury that the foregoing is true and correct. t Notary Public in and for the state of Texas, residing in Dallas County '''' `r• STEPW4IE RAKHER =• "= My Notary ID # 133,534406 Expires January 14, 2026 Extra dmrge for lost or duplicate affidavits. Legal document please do not destroy! Bennett, Bradley From: Hughes, Maribeth <MHughes@colpipe.com> Sent: Thursday, August 31, 2023 12:37 PM To: Bennett, Bradley Cc: Reedy, David; Boyan, Kyle; Ian Lundberg Subject: [External] RE: [External Message]Final Issuance of NPDES Permit - Colonial Pipeline Company / RDU Delivery Facility - NCO081469 CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. I am able to download, view and print. Thank you. 0 Maribeth Hughes, PE, CSP Environmental Specialist Colonial Pipeline Company m. 704-458-3993 1 mhuphes(a)colpipe.com 0 From: Bennett, Bradley <bradley.bennett@deq.nc.gov> Sent: Thursday, August 31, 2023 11:52 AM To: Hughes, Maribeth <MHughes@colpipe.com> Cc: Reedy, David <DReedy@col pipe.com>; Boyan, Kyle <KDBoyan@colpipe.com>; Ian Lundberg <resolveenvironmental@gmail.com> Subject: [External Message]Final Issuance of NPDES Permit - Colonial Pipeline Company / RDU Delivery Facility - NC0081469 WARNING: This email originated outside of Colonial Pipeline. DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe. Ms. Hughes, Attached is the your final issued permit for the RDU Delivery Facility — NC0081469. This permit will become effective October 1, 2023. Until that time please continue to abide by your current permit. Colonial provided comments on the draft permit. We responded in an earlier email and have also included responses in the cover letter for this final permit. Thanks for all the assistance from various staff in working through this permit renewal. If you have any questions, feel free to contact me or staff in our Raleigh Regional Office. Please respond to this email to verify that you were able to open, download, view and print the attached permit for your records. Thanks again for the assistance during our review. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: brad ley. ben nett ,deq.nc.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 91h 2023. Employee email addresses may look different, but email performance will not be impacted. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. Colonial Pipeline Notice - This e-mail message (including any attachment) contains information that may be confidential, be protected by attorney -client or other privilege, or constitute non-public information. If you are not the intended recipient, please notify the sender by electronic mail or telephone and delete the original message without making any copies. Use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful. Bennett, Bradley From: Bennett, Bradley Sent: Thursday, August 31, 2023 2:58 PM To: Manuel, Vanessa Subject: Permit Issuance - Colonial Pipeline Co - RDU Delivery Facility - NC0081469 Hi Vanessa, Just wanted to pass along that this permit has been issued. The permit and fact sheet are in Laserfiche. The permit will be effective October 1, 2023. 1 emailed the permit to the permittee this morning. Hope you are doing okay! Are you keeping Susan (Wilson) busy over there? Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@deq.nc.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. Bennett, Bradley From: Reedy, David <DReedy@colpipe.com> Sent: Sunday, August 27, 2023 10:50 PM To: Bennett, Bradley; Ian Lundberg Cc: Wyatt, John M.; Verdon, Michael A.; Hughes, Maribeth Subject: RE: [External Message]RE: [External] Comments on Draft NPDES Permit: NCO081469 Colonial Pipeline Company — RDU Delivery Facility Attachments: RDU Delivery NPDES 8-22.pdf CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Mr. Bennett, Thank you for giving us the opportunity to verify the 8/22/22 total phenolics concentration. As before, the concentration was entered incorrectly and was non -detect with a detection limit of 0.02 mg/L. I have revised the eDMR to match the lab report. We will be more diligent at reviewing the eDMR entries before submittal going forward. We appreciate your assistance throughout this permit renewal process. Dusty a David "Dusty" Y. Reedy II, PG Environmental Specialist Colonial Pipeline Company m. 678-213-7365 1 dreedy@colpipe.com u From: Bennett, Bradley <bradley.bennett@deq.nc.gov> Sent: Sunday, August 27, 2023 5:26 PM To: Ian Lundberg <resolveenvironmental@gmail.com> Cc: Wyatt, John M. <JMWyatt@colpipe.com>; Reedy, David <DReedy@colpipe.com>; Verdon, Michael A. <mverdon@colpipe.com>; Hughes, Maribeth <MHughes@colpipe.com> Subject: [External Message]RE: [External] Comments on Draft NPDES Permit: NCO081469 Colonial Pipeline Company — RDU Delivery Facility WARNING: This email originated outside of Colonial Pipeline. DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe. Mr. Lundberg, In working to finalize your permit I also noted that your reported data for total recoverable phenolics for August 22, 2022 was reported as 1.2 mg/L. This value would continue to produce Reasonable Potential for total recoverable phenolics. I'm sorry I didn't point this value out in the earlier email. Given your response on the previous values I wanted to give you an opportunity to check this reported value to see if it was reported in error like the others. Please check this and respond to me so we can move forward in our process. Thanks for your review. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: brad Iey.ben nett()deg.nc.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Ian Lundberg<resolveenvironmental @gmail.com> Sent: Thursday, August 17, 2023 9:08 AM To: Bennett, Bradley <bradley.ben nett@deg.nc.gov> Cc: Wyatt, John M. <JmWvatt@colpipe.com>; Reedy, David <dreedv@colpipe.com>; Verdon, Michael A. <mverdon@colpipe.com>; Hughes, Maribeth <MHughes@colpipe.com> Subject: Re: [External] Comments on Draft NPDES Permit: NCO081469 Colonial Pipeline Company — RDU Delivery Facility CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Mr. Bennett, Thank you for the prompt review of and response to our comments. With regard to the reported total recoverable phenolics concentrations, we have reviewed the RPA and the laboratory reports and found several values were reported inaccurately, with improper units conversion for non -detect samples, as follows: 2/21/2019: Correct total recoverable phenolics concentration <0.020 mg/I 2/11/2020: Correct total recoverable phenolics concentration <0.020 mg/I 6/25/2020: Correct total recoverable phenolics concentration <0.020 mg/I 8/18/2021: Correct total recoverable phenolics concentration <0.020 mg/I Laboratory reports for each of these four samples are attached. Colonial will correct inaccurate data in the eDMR system. We appreciate your consideration of these corrected values in your final assessment. Please let us know if you need anything else, Ian Lundberg, PE Resolve Environmental Engineering, Inc. 213 Alderwood Point, Atlanta, GA 30328 p. 770-650-9990 c. 404-660-0699 e. Iundberg(@resolve.cc or resolveenvironmental(a�gmail.com On Wed, Aug 16, 2023 at 2:00 PM Bennett, Bradley <bradley. ben nett@deg.nc.gov> wrote: Mr. Lundberg, Thank you for providing the comments on the draft Colonial Pipeline — RDU Delivery Facility (NC0081469) permit. I wanted to pass along the following initial brief responses to these comments. Total Recoverable Phenolics —Thanks for providing the information on the incorrect data for the August 22, 2022, DMR report. We will consider that in our final assessment. Please also note that for August 18, 2021, Colonial reported a Total Recoverable Phenolics value of less than 20 mg/L. This value would still result in reasonable potential and lead to a permit limit. If that value was reported inaccurately also, please let us know. Inaccurate data should be corrected by Colonial in the eDMR system. Method 625 Monitoring Frequency - Thanks for noting the discrepancy in the monitoring frequency. We will update A.(4.) to reflect semiannual monitoring as noted in the Effluent Table. Toluene and Naphthalene — You requested a copy of the RPA analysis. A copy of the final results is attached. Please note that the Division does not give out the full calculations associated with our RPA procedure. The Division utilizes procedures conducted in accordance with 40 CFR 122.44 (d) (i). The NC RPA procedure utilizes the following: 1) 95% Confidence Level/95% Probability; 2) assumption of zero background; 3) use of % detection limit for "less than" values. The Division understands Colonial's concerns with potential offsite contributions, but we are required to address discharges in a manner that assure proper limitations are established where discharges of a pollutant has reasonable potential to impact water quality standards. Colonial has been given a five-year compliance schedule as you have mentioned in your comments. Colonial may choice to review alternatives that could remove offsite contributions from your discharge during this compliance window, but as long as these levels of pollutants are a part of your discharge the Division is obligated to include these limitations in the permit. L7* Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradIev.bennett(@deg.nc.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Ian Lundberg<resolveenvironmental @gmail.com> Sent: Wednesday, August 9, 2023 7:15 PM To: Bennett, Bradley <bradley.ben nett@deg.nc.gov> Cc: Wyatt, John M. <JmWvatt@colpipe.com>; Reedy, David <dreedv@colpipe.com>; Verdon, Michael A. <mverdon@colpipe.com> Subject: [External] Comments on Draft NPDES Permit: NCO081469 Colonial Pipeline Company— RDU Delivery Facility CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Dear Mr. Bennett, On behalf of Colonial Pipeline Company, Resolve is hereby submitting the attached comments on the draft NPDES permit renewal for the Colonial RDU Delivery Facility, NPDES Permit No. NC0081469. We appreciate your consideration of these comments. Please let me know if you have any questions or need any additional information, Ian Lundberg, PE I Resolve Environmental Engineering, Inc. 213 Alderwood Point, Atlanta, GA 30328 p. 770-650-9990 c. 404-660-0699 e. IundbergCo)resolve. cc or resolveenvironmental(a�gmail.com Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. Colonial Pipeline Notice - This e-mail message (including any attachment) contains information that may be confidential, be protected by attorney -client or other privilege, or constitute non-public information. If you are not the intended recipient, please notify the sender by electronic mail or telephone and delete the original message without making any copies. Use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful. RESOLVE Environmental Engineering August 9, 2023 North Carolina Department of Environmental Quality Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Attention: Bradley Bennett Compliance and Expedited Permitting Unit Delivered via UPS, Waybill No. lZlY048R0298432360 And via email to bradley.bennett@deq.nc.gov Subject: Comments on Draft NPDES Permit NCO081469 Colonial Pipeline Company— RDU Delivery Facility On behalf of Colonial Pipeline Company (Colonial), Resolve Environmental Engineering, Inc. (Resolve) appreciates the opportunity to provide these comments on the proposed draft renewal of NPDES Permit NC0081469 for the Colonial RDU Delivery Facility. This letter is in response to the draft permit sent to Colonial dated July 11, 2023. During a review of Discharge Monitoring Reports, it was determined that the reported detection of total recoverable phenolics in a sample collected on August 22, 2022, was in error. The laboratory analytical report for that sample is attached. As noted in the report, total recoverable phenolics concentrations were below the laboratory detection limit of 0.020 mg/I. Using this corrected data, there have been no detections of total recoverable phenolics during the period reviewed by Resolve (since the start of 2021). Therefore, there is not a reasonable concern that facility discharges of total recoverable phenolics have the potential to impact instream water quality. We therefore request removal of the total recoverable phenolics permit limit and removal of references to total recoverable phenolics in Part I.A.(5.) of the permit. We note that, for EPA Method 625, Part I.A.(1.) of the permit lists a monitoring frequency of "2/Year" and Part I.A.(4.)(a) lists a monitoring frequency of "Monthly". We request clarification on the intended monitoring frequency. Resolve believes a monitoring frequency of 2/Year is appropriate based upon past data. If NCDEQ believes a monitoring frequency of monthly is 213 Alderwood Pt, Atlanta, GA 30328, p. 770-650-9990, www.resolve.cc Comments on Draft NPDES Permit NCO081469 August 9, 2023 Colonial Pipeline Company RDU Delivery Facility Page 2 of 2 appropriate, we request a copy of the Reasonable Potential Analysis (RPA) that was completed to make this determination. We understand the addition of postponed permit limits for toluene and naphthalene was based upon detections of these parameters in the previous 12 months. We would like to receive a copy of the RPAs that were completed for these parameters. We note that the facility is an intermittent discharger, with discharges consisting substantially of stormwater runoff. We believe that RPAs performed for this discharge should account for the intermittent nature of the discharges. We also note the permitted outfall receives stormwater runoff from offsite sources, including roads, office buildings and parking areas on adjacent and nearby properties. The National Urban Runoff Program determined that toluene and naphthalene are periodically found in stormwater runoff from such urban developments. As part of the compliance reports required under Part I.A.(5.) of the permit, Colonial may assess the impact of these offsite sources on discharge parameters. If pollutant sources are located offsite, it may affect Colonial's ability to control those sources. Resolve appreciates the opportunity to submit these comments. If you require any clarifications, please do not hesitate to contact Mr. Ian Lundberg of Resolve at 770-650-9990 or Mr. David Reedy of Colonial at 678-213-7365. Sincerely, Resolve Environmental Engineering Ian Lundberg, PE Principal Engineer Attachment: Pace Analytical Report; RDU Delivery Monthly; September 1, 2022 cc: David Reedy, Colonial Pipeline Company John Wyatt, Colonial Pipeline Company RES�LVE Environmental Engineering Bennett, Bradley From: Bennett, Bradley Sent: Monday, July 10, 2023 9:47 AM To: Zhang, Cheng Cc: Manuel, Vanessa Subject: Draft Permit To Notice - Colonial Pipeline - RDU Delivery Facility - NCO081469 Attachments: NC0081469_Draft Permit and Cover Ltr_20230703.pdf, NC0081469_Fact Sheet Binder 20230703.pdf Hey Cheng, Just wanted to send a not to let you know that this draft permit is going to notice this week. I will be emailing it to the permittee tomorrow. I sent an earlier draft for your review. Since that time I have updated a couple of things — gave them the full permit term before new limits kick in and also removed some references to EPA 624.1 monitoring since they only have to do 625.1. The draft permit and Fact Sheet are attached the permit is also in Laserfiche. Thanks L3.3 Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@deq.nc.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. Bennett, Bradley From: Kinney, Maureen Sent: Monday, July 10, 2023 10:26 AM To: Bennett, Bradley Subject: RE: Draft permit for Colonial Pipeline - RDU Delivery Facility - NCO081469 Hi Bradley! Doing well, hope you are. This one looks good, thank you! From: Bennett, Bradley <bradley.bennett@deq.nc.gov> Sent: Monday, July 10, 2023 9:49 AM To: Kinney, Maureen <Maureen.Kin ney@deq.nc.gov> Subject: Draft permit for Colonial Pipeline - RDU Delivery Facility - NCO081469 Hey Maureen, Hope you are doing okay. Here is another draft for your review. This one will go to notice later this week. Thanks No Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: brad ley. ben nett ,deq.nc.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. Bennett, Bradley From: Deuterman, Sydney Sent: Friday, June 30, 2023 9:13 AM To: Bennett, Bradley Subject: Re: Draft For Review - Colonial Pipeline Company - RDU Delivery Facility - NC0081469 Thanks Bradley! Definitely feeling better today. For compliance schedules, if it's a new limit (like metals for WTPs), I usually give the full permit cycle to come into compliance. I'm not sure if we have written out guidance anywhere or not. I had a terminal that I issued last year (nc0031038) with only 625.1 monitoring, so I removed all mention of 624.1 from the condition. No one seemed to have a comment on it, so I'd assume it's okay! Happy Friday! Sydney Deuterman (she/her) Environmental Specialist II Compliance and Expedited Permitting Unit Division of Water Resources N.C. Department of Environmental Quality Office: 919-707-3712 NEWEMAIL ADDRESS.- sydney.deuterman@deq.nc.gov 1617 Mail Service Center Raleigh, NC 27699-1617 M Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley.bennett@deq.nc.gov> Sent: Thursday, June 29, 2023 8:00 PM To: Deuterman, Sydney <sydney.deuterman@deq.nc.gov> Subject: RE: Draft For Review - Colonial Pipeline Company - RDU Delivery Facility - NCO081469 Thanks Sydney. Sorry you haven't been feeling well. Hope you are on the way to being over whatever it was. I have a few notes below on your comments. Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradley.bennett@deq.nc.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Deuterman, Sydney <sydney.deuterman@deq.nc.gov> Sent: Thursday, June 29, 2023 1:45 PM To: Bennett, Bradley <bradley.bennett@deq.nc.gov> Subject: RE: Draft For Review - Colonial Pipeline Company - RDU Delivery Facility - NC0081469 Hey Bradley, Sorry for the delay on this one —I haven't been feeling well this week and ended up taking some sick leave, so I'm playing a bit of catch up. Here's what I found during my review: Permit • Compliance Schedule —just curious, but why did you only give the permittee 2 years instead of 5 years? I also noticed that you didn't add a special condition for the compliance schedule either. I have never been sure how to handle the schedules. Some of the ones I have had just strengthened existing limits, so I just made up two years or they asked for two years etc. I wonder if there is an approach spelled out somewhere. I'd look but I get in trouble when I look at rules, statutes or guidance! When you add an entirely new limit do you usually give a full permit cycle? I'd say if anything it should be the permit cycle since most of these end up being less than five years and we wouldn't want it to stretch into another permit cycle. • EPA Methods 625.1 Condition — since the permittee only needs to monitor for 625.1, have you thought about removing the parts relevant to 624.1 from the condition in the permit? Yea, I wondered about this and meant to ask you what you thought. Have you taken stuff out of any of yours? • Font type/sizing — very minor, but I noticed the font size seemed to be slightly smaller for a few of the footnotes and the rule citation for condition A. (4) appears to be in Arial or non -Times I'll check this out. Some of the places I made the font small was to try and keep all the footnotes on one page. Fact Sheet • You mentioned that the outfall coordinates have been updated to match what was provided in the app. as they're more accurate. Just a remember to update BIMS as well, as I think the old Lat is still in there. Thanks, I'll make that change. • The list of treatment components has two more items than what's in the permit. Is there a reason you didn't add them to the permit? Reason - I'm old and I forgot! I'll make that change to be consistent with the Fact Sheet. Great job on this one! I hope to have a draft coming your way soon. Thanks, Sydney Deuterman (Carpenter) (she/her) Environmental Specialist II Compliance and Expedited Permitting Unit Division of Water Resources N.C. Department of Environmental Quality Office: 919-707-3712 NEWEMAILADDRESS: svdnev.deuterman@deq.nc.gov 1617 Mail Service Center Raleigh, NC 27699-1617 Email correspondence to and from this address is subject to the FEI North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@deg.nc.gov> Sent: Friday, June 23, 2023 11:41 AM To: Deuterman, Sydney <sydney.deuterman@deg.nc.gov> Subject: Draft For Review - Colonial Pipeline Company - RDU Delivery Facility - NCO081469 Hey Sydney, Here is another Bulk Terminal Renewal for your review. There are more files on this one because I had to ask for more EPA Application forms to be submitted. So there are actually three separate application files. M NCO081469 - Colonial Pipeline Company - RDU Delivery Facility Thanks, and have a good weekend! fi:3 Bradley Bennett Compliance and Expedited Permitting Phone: (919) 707-3629 NC Division of Water Resources 1617 Mail Service Center Email: bradlev.bennett(@deg.nc.gov Raleigh, NC 27699-1617 Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. Bennett, Bradley From: Bennett, Bradley Sent: Friday, June 23, 2023 11:43 AM To: Zhang, Cheng Cc: Manuel, Vanessa Subject: Draft Permit Renewal for Colonial Pipeline Company - RDU Delivery Facility - NC0081469 Attachments: NC0081469_Fact Sheet Binder_20230623.pdf; NC0081469_Draft Permit and Cover Ltr_ 20230623.pdf Hey Cheng, Hope you guys are doing well! Here is a draft permit for this facility. Draft and fact sheet are attached. Let me know if you have any comments or questions. fi:3 Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@deq.nc.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. 1 Bennett, Bradley From: Hughes, Maribeth <MHughes@colpipe.com> Sent: Wednesday, June 21, 2023 1:41 PM To: Bennett, Bradley Cc: Reedy, David Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 Attachments: Phenol Data 2023.xlsx CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. f3:3 I made two changes to your sheet. What is noted as ug/L on the sheet was really mg/L, but the noted value was correct. I will make sure that it is entered as ug/L in the future. Maribeth Hughes, PE, CSP Environmental Specialist Colonial Pipeline Company m. 704-458-3993 1 mhughes(a�colpipe.com From: Bennett, Bradley <bradley.bennett@deq.nc.gov> Sent: Tuesday, June 20, 2023 5:11 PM To: Hughes, Maribeth <MHughes@colpipe.com>; Reedy, David <DReedy@colpipe.com> Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 Sorry to keep bugging you, but could you look into one other thing for us. On your submitted data for Total Phenolic Compounds the data was entered in the eDMR system inconsistently. I have attached a spreadsheet with the data. The data should be reported in µg/L. Some of the data show mg/L as the Unit of Measure. I'm not sure if those values are really mg/L or if they are really µg/L? If you could verify the values for us I'd appreciate it. Thanks m Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradIev.bennettC@clecl.nc.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Hughes, Maribeth <MHughes@colpipe.com> Sent: Tuesday, June 20, 2023 2:56 PM To: Bennett, Bradley <bradley.ben nett@deq.nc.gov>; Reedy, David <DReedy@colpipe.com> Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Will do! OO Maribeth Hughes, PE, CSP Environmental Specialist Colonial Pipeline Company m. 704-458-3993 1 mhughes(a)colpipe.com From: Bennett, Bradley <bradley. ben nett@deq.nc.gov> Sent: Tuesday, June 20, 2023 2:55 PM To: Hughes, Maribeth <MHughes@colpipe.com>; Reedy, David <DReedy@colpipe.com> Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 Thanks. Could you also mail the signed hard copy? By we need to have the hardcopy version also to meet federal requirements. You can mail to the address below in my email signature block. Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.bennett@deg.nc.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Hughes, Maribeth <MHughes@colpipe.com> Sent: Tuesday, June 20, 2023 2:52 PM To: Bennett, Bradley <bradley.ben nett@deq.nc.gov>; Reedy, David <DReedy@colpipe.com> Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Signed copy. Let me know if you need anything else. 0 Maribeth Hughes, PE, CSP Environmental Specialist Colonial Pipeline Company m. 704-458-3993 1 mhughes(a)colpipe.com From: Bennett, Bradley <bradley. ben nett@deg.nc.gov> Sent: Tuesday, June 20, 2023 12:25 PM To: Reedy, David <DReedy@colpipe.com> Cc: Hughes, Maribeth <MHughes@colpipe.com> Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 Mr. Reedy, Thanks for your submittal of the Form 2E information. I am currently working on the draft permit for the RDU facility (NC0081469). I mentioned in previous emails the need for Forms 1 and 2E for the renewal. I thought that you guys had already previously submitted Form 1. As I look back it does not appear that this form was submitted, you had previously submitted Form 2F. I apologize to have to ask for another form at this point, but we do need Form 1 to complete federal application requirements. This will not detain the review of the renewal for the RDU facility as I will continue to work through that permit for public notice hopefully next week. If you can submit Form 1 we will add that to the package. The form is attached here and is mainly an information form about your facility. I'm sorry for this additional request. I have also attached a report that shows contact information we currently have in our database for this facility. Could you please take a look at this report and let me know if we need to make any changes, additions, or subtractions from this report? Thanks for your help with this process. m Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.ben nett&ncdenr.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 91h 2023. Employee email addresses may look different, but email performance will not be impacted. From: Reedy, David <DReedy@colpipe.com> Sent: Friday, June 9, 2023 2:19 PM To: Bennett, Bradley <bradley.ben nett@deq.nc.gov>; Hughes, Maribeth <MHughes@colpipe.com> Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message button located on your Outlook menu bar on the Home tab. Mr. Bennett, As requested, I have attached the EPA Form 2E for the Selma and RDU facilities. Hardcopies will be mailed as well. Please let us know if we can be of further assistance. Dusty OO David "Dusty" Y. Reedy II, PG Environmental Specialist Colonial Pipeline Company m. 678-213-7365 1 dreedy(a colpipe.com From: Bennett, Bradley <bradley. ben nett@deg.nc.gov> Sent: Thursday, June 1, 2023 4:10 PM To: Hughes, Maribeth <MHughes@colpipe.com> Cc: Reedy, David <DReedy@colpipe.com> Subject: RE: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 Ms. Hughes, Looking at the information provided it appears that these facilities have indicated some wastewaters possible at the sites (tank hydro test water, prover loop calibration water, pipeline hydro test water, washdown slab water, etc.) which would make them ineligible for coverage under the stormwater permit. These facilities should move forward with the wastewater permit renewals. Could you please also provide us with EPA form 2E for the facilities as this is also required along with the From 1 that you have already submitted. You can email a pdf copy to me to speed the process up, but we will still need to get you to send in a signed hardcopy to meet federal requirements as well. Thanks Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.ben nett()deg.nc.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. From: Hughes, Maribeth <MHughes@colpipe.com> Sent: Wednesday, April 5, 2023 9:52 AM To: Bennett, Bradley <bradley.ben nett@ncdenr.gov> Cc: Reedy, David <DReedy@colpipe.com> Subject: [External] RE: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NC0081469 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. Mr. Bennett: There is only 1 storage tank on this property. The capacity of that tank is 26,500 gallons. The property is a petroleum pipeline booster station. Please note that I requested the same for our Selma station (Permit NC0031011) when I recently submitted the renewal forms for that facility's permit. There is only one tank on that property and it is 230,000 gallons in capacity. Please let me know if you need any additional information. Maribeth Hughes, PE, CSP Environmental Specialist Colonial Pipeline Company m. 704-458-3993 1 mhuohes0kolpipe.com 0009 From: Bennett, Bradley <bradley.bennett@ncdenr.gov> Sent: Monday, April 3, 2023 4:22 PM To: Hughes, Maribeth <MHughes@colpipe.com> Subject: [External Message]Additional Information Request - Permit Renewal for RDU Delivery Facility - NCO081469 WARNING: This email originated outside of Colonial Pipeline. DO NOT CLICK links or attachments unless you recognize the sender and know the content is safe. Ms. Hughes, In your permit renewal application for this facility you requested consideration for permit coverage under general permit NCG080000. This general permit is only available to bulk storage terminals with total petroleum storage capacity of less than one million gallons. Could you please provide information on your facility's storage capacity? If your facility has a capacity of one million gallons or more then you will be required to renew the individual permit (NC0081469) and will be required to submit the following renewal application forms to complete your renewal request — EPA Form 1 and EPA Form 2E. Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3692 Email: brad Iey.ben nett(a.ncdenr.gov Email correspondence to and from this address may be subject to public records laws Colonial Pipeline Notice - This e-mail message (including any attachment) contains information that may be confidential, be protected by attorney -client or other privilege, or constitute non-public information. If you are not the intended recipient, please notify the sender by electronic mail or telephone and delete the original message without making any copies. Use, dissemination, distribution, or reproduction of this message by unintended recipients is not authorized and may be unlawful. Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized state official. Bennett, Bradley From: Zhang, Cheng Sent: Tuesday, May 9, 2023 9:11 AM To: Bennett, Bradley Cc: Manuel, Vanessa Subject: RE: Permit Renewals for Kinder Morgan Southeast Terminals and Colonial Pipeline Company Bradley, Colonial / RDU Delivery Facility — NC0081469, what is their SIC, is it 5171? NCG080000 might be applicable to the facility, however, with the fact that they have wastewater discharges from an oil water separator, it is probably more appropriate for them to have a NPDES individual permit. Just my thoughts, thanks. Cheng Zhang Environmental Specialist II Raleigh Regional Operations Section Division of Water Resources 919 791 4259 office 919 817 3856 cell 919 788 7159 fax cheng.zhang(a�ncdenr.gov 1628 Mail Service Center Raleigh, NC 27699-1628 �..., D E QF:� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Sent: Tuesday, May 9, 2023 8:48 AM To: Zhang, Cheng <cheng.zhang@ncdenr.gov> Cc: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: FW: Permit Renewals for Kinder Morgan Southeast Terminals and Colonial Pipeline Company Hey Cheng, See Bradley's email below. Please provide comments as needed. Thanks, Vanessa E. Manuel Assistant Regional Supervisor Division of Water Resources — Raleigh Regional Office Department of Environmental Quality 919 791-4232 Office; 919 817-1256 Mobile vanessa.manuel(cDncdenr.gov Physical: 3800 Barrett Drive, Raleigh, NC 27609 Mailing: 1628 Mail Service Center, Raleigh, NC 27699-1628 N, �Ndothing Compares Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. From: Bennett, Bradley <bradley. ben nett@ncdenr.gov> Sent: Monday, May 8, 2023 2:56 PM To: Manuel, Vanessa <vanessa.manuel@ncdenr.gov> Subject: Permit Renewals for Kinder Morgan Southeast Terminals and Colonial Pipeline Company Hey Vanessa, Hope you are doing okay. I know there is a lot going on and not enough people to do it right now. I just wanted to make you aware that I was starting to work on permit renewals for a few Bulk Terminal facilities. They are listed below and renewal applications are in Laserfiche. If you guys have any input on these please reach out to me and let me know. Please forward this along if there is someone else in the region you want me to work with on these. • Kinder Morgan / Selma Terminal 1— NCO049204 • Kinder Morgan / Selma Terminal 2 — NCO088218 • Kinder Morgan / Selma Terminal 3 — NCO076457 • Colonial / RDU Delivery Facility — NCO081469 - This facility has questioned whether they would qualify for the Stormwater GP (NCG080000) so I'm looking into that right now on this one. Would like to hear any feedback you guys have on this. They say they only have one 23K gallon tank, but they may have wastewater that excludes them. Let me know if there is anything that I can help you guys with right now. I know you are really stretched. Thanks m Bradley Bennett Compliance and Expedited Permitting NC Division of Water Resources 1617 Mail Service Center Raleigh, NC 27699-1617 Phone: (919) 707-3629 Email: bradley.ben nett()ncdenr.gov Email correspondence to and from this address may be subject to public records laws DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th 2023. Employee email addresses may look different, but email performance will not be impacted. 2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence MAXIMUM DATA POINTS = 58 REQUIRED DATA ENTRY Table 1. Project Information ❑ CHECK IF HQW OR ORW Facility Name WWTP/WTP Class NPDES Permit Outfall Flow, Qw (MGD) Receiving Stream Stream Class 7Q10s (cfs) 7Q10w (cfs) 30Q2 (cfs) CIA (cfs) 1Q10s (cfs) Data Source(s) ❑ CHECK TO APPLY MODEL Colonial Pipeline Company LP Grade I PC WPCS NCO081469 001 0.20800 UT to Crabtree Creek B; NSW 0.00 0.00 0.00 0.00 0.00 BIMS data from Aug 2018 to May 2023 Flow is Maximum Monthly Flow => 0.208 MGD Follow directions for data entry. In some cases a comment menu list the available choices or a dropdown menu will provide a list you may select from. Error message occur if data entry does not meet input criteria. Par01 Par02 Par03 Par04 Par05 Par06 Par07 Par08 Par09 Par10 Par11 Par12 Par13 Par14 Par15 Par16 Par17 Par18 Par19 Par20 Par21 Par22 Table 2. Parameters of Concern Name Tye Chronic Modifier Acute PQL Units Benzene C 1.19 WS pg/L Benzene C 51 HH pg/L Toluene NC 11 FW pg/L Toluene NC 57 WS pg/L Toluene NC 520 HH pg/L Ethylbenzene NC 68 WS pg/L Ethylbenzene NC 130 HH pg/L Ethylbenzene NC 97 FW pg/L Xylenes Mixture NC 6200 WS pg/L Xylenes Mixture NC 670 FW pg/L Xylenes Mixture NC 57000 HH pg/L Napthalene NC 400 WS pg/L Napthalene NC 12 FW pg/L Napthalene NC 950 HH pg/L MTBE (Methyl Tertiary -butyl Ether) C 19 WS pg/L MTBE (Methyl Tertiary -butyl Ether) C 34000 FW pg/L MTBE (Methyl Tertiary -butyl Ether) C 1500 HH pg/L Phenolic Compounds NC 300 FW pg/L Phenol NC 4000 WS pg/L Phenol NC 300000 HH pg/L Turbidity NC 50 FW NTU NCO081469_Bulk-Storage FW - 9595 GENERIC non —hardness RPA2016_53_2023, input 6/22/2023 REASONABLE POTENTIAL ANALYSIS z Use "PASTE SPECIAL Benzene Values" then "COPY". Maximum data points = 58 Date Data BDL=1/2DL Results 1 10/12/2018 < 1.000 0.5 Std Dev. 5.7238 2 2/21/2019 < 1.000 0.5 Mean 2.8909 3 2/11/2020 11.000 11 C.V. 1.9799 4 6/25/2020 < 1.000 0.5 n 22 5 12/15/2020 < 1.000 0.5 6 8/18/2021 < 1.000 0.5 Mult Factor = 1.8900 7 9/23/2021 < 1.000 0.5 Max. Value 24.5 Ng/L 8 10/29/2021 < 1.000 0.5 Max. Pred Cw 46.3 gg/L 9 2/9/2022 < 1.000 0.5 10 3/11/2022 < 1.000 0.5 11 4/7/2022 < 1.000 0.5 12 5/24/2022 < 1.000 0.5 13 7/11/2022 < 1.000 0.5 14 8/22/2022 < 1.000 0.5 15 10/3/2022 < 1.000 0.5 16 11/16/2022 3.800 3.8 17 12/1/2022 2.300 2.3 18 1 /5/2023 10.800 10.8 19 2/1/2023 24.500 24.5 20 3/13/2023 3.200 3.2 21 4/10/2023 < 1.000 0.5 22 5/19/2023 < 1.000 0.5 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 NC0081469_Bulk-Storage FW - 9595 GENERIC non —hardness RPA2016_53_2023, data - 1 - 6/22/2023 REASONABLE POTENTIAL ANALYSIS 3 Toluene Use "PASTE SPECIAL Values" then "COPY". 8 Ethylbenzene Use "PASTE SPECIAL Values" then "COPY". 10 Maximum data points Maximum data points = 58 = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 1 10/12/2018 < 1.000 0.5 Std Dev. 34.6359 1 10/12/2018 < 1.000 0.5 Std Dev. 9.1394 1 2 2/21/2019 < 1.000 0.5 Mean 15.4633 2 2/21/2019 < 1.000 0.5 Mean 4.2509 2 3 2/11/2020 68.200 68.2 C.V. 2.2399 3 2/11/2020 23.300 23.3 C.V. 2.1500 3 4 6/25/2020 < 1.000 0.5 n 21 4 6/25/2020 < 1.000 0.5 n 22 4 5 12/15/2020 < 1.000 0.5 5 12/15/2020 1.100 1.1 5 6 8/18/2021 < 1.000 0.5 Mult Factor = 2.0400 6 8/18/2021 < 1.000 0.5 Mult Factor = 1.9400 6 7 9/23/2021 < 1.000 0.5 Max. Value 145.0 Ng/L 7 9/23/2021 < 1.000 0.5 Max. Value 37.9 Ng/L 7 8 10/29/2021 1.300 1.3 Max. Pred Cw 295.8 gg/L 8 10/29/2021 < 1.000 0.5 Max. Pred Cw 73.5 gg/L 8 9 2/9/2022 < 1.000 0.5 9 2/9/2022 < 1.000 0.5 9 10 3/11/2022 1.900 1.9 10 3/11/2022 1.100 1.1 10 11 4/7/2022 < 1.000 0.5 11 4/7/2022 < 1.000 0.5 11 12 5/24/2022 1.700 1.7 12 5/24/2022 2.500 2.5 12 13 7/11/2022 < 1.000 0.5 13 7/11/2022 < 1.000 0.5 13 14 10/3/2022 < 1.000 0.5 14 8/22/2022 < 1.000 0.5 14 15 11/16/2022 24.600 24.6 15 10/3/2022 < 1.000 0.5 15 16 12/1/2022 10.200 10.2 16 11/16/2022 9.600 9.6 16 17 1 /5/2023 48.800 48.8 17 12/1 /2022 < 1.000 0.5 17 18 2/1/2023 145.000 145 18 1/5/2023 7.420 7.42 18 19 3/13/2023 15.200 15.2 19 2/1/2023 37.900 37.9 19 20 4/10/2023 2.330 2.33 20 3/13/2023 3.600 3.6 20 21 5/19/2023 < 1.000 0.5 21 4/10/2023 < 1.000 0.5 21 22 22 5/19/2023 < 1.000 0.5 22 23 23 23 24 24 24 25 25 25 26 26 26 27 27 27 28 28 28 29 29 29 30 30 30 31 31 31 32 32 32 33 33 33 34 34 34 35 35 35 36 36 36 37 37 37 38 38 38 39 39 39 40 40 40 41 41 41 42 42 42 43 43 43 44 44 44 45 45 45 46 46 46 47 47 47 48 48 48 49 49 49 50 50 50 51 51 51 52 52 52 53 53 53 54 54 54 55 55 55 56 56 56 57 57 57 58 1 58 1 58 NC0081469_Bulk-Storage FW - 9595 GENERIC non -hardness RPA2016_53_2023, data -2- 6/22/2023 REASONABLE POTENTIAL ANALYSIS Xylenes Mixture Use "PASTE SPECIAL Values" then "COPY". 13 Napthalene Use "PASTE SPECIAL Values" then "COPY". 17 Maximum data points Maximum data points = 58 = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 10/12/2018 < 1.000 0.5 Std Dev. 55.69 1 10/12/2018 < 1.000 0.5 Std Dev. 5.1200 1 2/21/2019 1.700 1.7 Mean 29.19 2 2/21/2019 < 1.000 0.5 Mean 4.2377 2 2/11/2020 96.600 96.6 C.V. 1.9078 3 2/11/2020 14.100 14.1 C.V. 1.2082 3 6/25/2020 < 2.000 1 n 22 4 6/25/2020 < 1.000 0.5 n 22 4 12/15/2020 7.600 7.6 5 12/15/2020 2.200 2.2 5 8/18/2021 < 3.000 1.5 Mult Factor = 1.8700 6 8/18/2021 < 5.000 2.5 Mult Factor = 1.6200 6 9/23/2021 < 3.000 1.5 Max. Value 226.0 tlg/L 7 9/23/2021 < 5.000 2.5 Max. Value 22.9 ug/L 7 10/29/2021 < 3.000 1.5 Max. Fred Cw 422.6 Ng/L 8 10/29/2021 < 5.000 2.5 Max. Fred Cw 37.1 Ng/L 8 2/9/2022 < 3.000 1.5 9 2/9/2022 < 5.000 2.5 9 3/11/2022 5.800 5.8 10 3/11/2022 < 5.000 2.5 10 4/7/2022 < 3.000 1.5 11 4/7/2022 < 5.000 2.5 11 5/24/2022 19.200 19.2 12 5/24/2022 < 5.000 2.5 12 7/11/2022 < 3.000 1.5 13 7/11/2022 < 5.000 2.5 13 8/22/2022 < 3.000 1.5 14 8/22/2022 < 5.000 2.5 14 10/3/2022 < 3.000 1.5 15 10/3/2022 < 5.000 2.5 15 11/16/2022 74.700 74.7 16 11/16/2022 5.900 5.9 16 12/1 /2022 15.100 15.1 17 12/1 /2022 < 5.000 2.5 17 1 /5/2023 117.000 117 18 1 /5/2023 7.730 7.73 18 2/1/2023 226.000 226 19 2/1/2023 22.900 22.9 19 3/13/2023 58.800 58.8 20 3/13/2023 6.400 6.4 20 4/10/2023 4.670 4.67 21 4/10/2023 < 5.000 2.5 21 5/19/2023 < 3.000 1.5 22 5/19/2023 < 5.000 2.5 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 NC0081469_Bulk-Storage FW - 9595 GENERIC non -hardness RPA2016_53_2023, data -3- 6/22/2023 REASONABLE POTENTIAL ANALYSIS MTBE (Methyl Tertiary -butyl Ether) Use "PASTE SPECIAL Values" then "COPY". 18 Phenolic Compounds Use "PASTE SPECIAL Values" then "COPY". 21 Maximum data points Maximum data points = 58 = 58 Date Data BDL=1/2DL Results Date Data BDL=1/2DL Results 10/12/2018 < 2.000 1 Std Dev. 0.9992 1 10/12/2018 < 10 5 Std Dev. 2178.5369 1 2/21/2019 < 1.000 0.5 Mean 1.6136 2 2/21/2019 < 200 100 Mean 558.6667 2 2/11/2020 < 1.000 0.5 C.V. 0.6192 3 2/11/2020 < 200 100 C.V. 3.8995 3 6/25/2020 < 1.000 0.5 n 22 4 6/25/2020 < 200 100 n 21 4 12/15/2020 < 1.000 0.5 5 12/15/2020 < 20 10 5 8/18/2021 < 5.000 2.5 Mult Factor = 1.3300 6 8/18/2021 < 20000 10000 Mult Factor = 2.4300 6 9/23/2021 < 1.000 0.5 Max. Value 2.5 tlg/L 7 9/23/2021 < 20 10 Max. Value 10000.0 tlg/L 7 10/29/2021 < 5.000 2.5 Max. Fred Cw O DETECTS Ng/L 8 10/29/2021 < 20 10 Max. Fred Cw 24300.0 Ng/L 8 2/9/2022 < 5.000 2.5 9 2/9/2022 < 20 10 9 3/11/2022 < 5.000 2.5 10 3/11/2022 22 22 10 4/7/2022 < 5.000 2.5 11 4/7/2022 < 20 10 11 5/24/2022 < 5.000 2.5 12 5/24/2022 < 20 10 12 7/11/2022 < 5.000 2.5 13 7/11/2022 < 20 10 13 8/22/2022 < 1.000 0.5 14 8/22/2022 1200 1200 14 10/3/2022 < 5.000 2.5 15 11 /16/2022 < 20 10 15 11/16/2022 < 5.000 2.5 16 12/1/2022 < 20 10 16 12/1 /2022 < 5.000 2.5 17 1 /5/2023 < 40 20 17 1 /5/2023 < 1.000 0.5 18 2/1 /2023 45 45 18 2/1/2023 < 5.000 2.5 19 3/13/2023 < 20 10 19 3/13/2023 < 5.000 2.5 20 4/10/2023 < 40 20 20 4/10/2023 < 1.000 0.5 21 5/19/2023 < 40 20 21 5/19/2023 < 1.000 0.5 22 22 23 23 24 24 25 25 26 26 27 27 28 28 29 29 30 30 31 31 32 32 33 33 34 34 35 35 36 36 37 37 38 38 39 39 40 40 41 41 42 42 43 43 44 44 45 45 46 46 47 47 48 48 49 49 50 50 51 51 52 52 53 53 54 54 55 55 56 56 57 57 58 58 NC0081469_Bulk-Storage FW - 9595 GENERIC non -hardness RPA2016_53_2023, data -4- 6/22/2023 REASONABLE POTENTIAL ANALYSIS Use "PASTE SPECIAL Turbidity Values" then "COPY" Maximum data points = 58 Date Data BDL=1/2DL Results 10/12/2018 8.500 8.5 Std Dev. 4.1396 2/21/2019 7.100 7.1 Mean 6.9357 2/11/2020 9.300 9.3 C.V. 0.5969 6/25/2020 2.700 2.7 n 14 12/15/2020 10.400 10.4 9/23/2021 3.200 3.2 Mult Factor = 1.5400 10/29/2021 3.700 3.7 Max. Value 17.0 NTU 2/9/2022 6.600 6.6 Max. Fred Cw 26.2 NTU 3/ 11 /2022 1.400 1.4 4/7/2022 8.300 8.3 8/22/2022 2.200 2.2 11/16/2022 8.300 8.3 1 /5/2023 17.000 17 4/10/2023 8.400 8.4 NC0081469_Bulk-Storage FW - 9595 GENERIC non —hardness RPA2016_53_2023, data - 5 - 6/22/2023 Colonial Pipeline Company LP REASONABLE POTENTIAL ANALYSIS Outfall 001 NCO081469 2016 Generic RPA (non -hardness dependent) - 95% Probability/95% Confidence QW = 0.208 MGD MAXIMUM DATA POINTS = 58 Qw (MGD) = 0.20800 WWTP/WTP Class: Grade I PC WPCS 1Q10S (cfs) = 0.00 IWC @ 1Q10S = 100.000000% 7Q10S (cfs) = 0.00 IWC @ 7Q10S = 100.000000% 7Q10W (cfs) = 0.00 IWC @ 7Q10W = 100.000000% 30Q2 (cfs) = 0.00 IWC @ 30Q2 = 100.000000% Avg. Stream Flow, QA (cfs) = 0.00 IWC @ QA = 100.000000% Receiving Stream: UT to Crabtree Creek Stream Class: B; NSW PARAMETER STANDARDS & CRITERIA (2) w REASONABLE POTENTIAL RESULTS RECOMMENDED ACTION TYPE 11) J a Zri NC WQS / Applied '/z FAV / Chronic Standard Acute # Det. Max Pred Cw Allowable Cw Acute: NO WQS Benzene C 51 HH µg/L 22 6 46.3 No RP; Max Pred > 50 % Allowable _ _ --Chronic: ---- 51.00 -- --------------------------- No value > Allowable Cw Acute: NO WQS Toluene NC 11 FW µg/L 21 10 295.8 RP shown - apply Monthly Monitoring with Limit _ _ ---- _ _ --Ch-- Chronic: -11.00 --------------------------- 5 values > Allowable Cw Acute: NO WQS Ethylbenzene NC 97 FW µg/L 22 8 73.5 _ _ _ _ --Chronic: ---- -- No RP; Max Pred > 50 % Allowable --------------------------- 97.00 No value > Allowable Cw Acute: NO WQS Xylenes Mixture NC 670 FW µg/L 22 11 422.E _ --Chronic:-- No RP; Max Pred > 50 % Allowable --------------------------- No value > Allowable Cw Acute: NO WQS Napthalene NC 12 FW µg/L 22 6 37.1 -- ------- _ro_ _ _ RP shown - apply Monthly Monitoring with Limit --------------------------- Chnic:12.00 2 values > Allowable Cw Acute: NO WQS MTBE (Methyl Tertiary -butyl Ether) C 1500 HH µg/L 22 0 NO DETECTS No detects _ _ --- _ _ _ ................... Ch— Chronic: 1,500.00 --------------------------- Max MDL = 5 Acute: NO WQS Phenolic Compounds NC 300 FW µg,'L 21 3 24300.0 RP shown - apply Monthly Monitoring with Limit _ _ _ _ --Chronic:----300.00-- --------------------------- 2 values > Allowable Cw Acute: NO WQS No RP; Max Pred > 50 % Allowable Turbidity NC 50 FW NTU 14 14 26.2 _ _ ronic:—-------------- — Ch No value > Allowable Cw Acute: 0 0 N/A — Ch_ _ ronic:------------------- NCO081469_Bulk-Storage FW - 9595 GENERIC non hardness RPA2016_53_2023, rpa Page 1 of 1 6/22/2023 Whole Effluent Toxicity Testing and Self Monitoring Summary Coddle Creek WTP NCO083119/001 County: Cabarrus Ceri7dPF Begin: 12/1/2013 90% chr mont NonComp: J F M A M 2019 Pass - - Pass - 2020 Pass - - Pass - 2021 Pass - - Pass - 2022 Pass - - Pass - 2023 Pass - - Pass - Cofield facility (RO & Cooling Water) NCO089516/001 County: Hertford Ceri7dPF Begin: 9/1/2020 Chr Limit: 90% NonComp: J F M A M 2019 Pass - - Pass - 2020 Pass - - Pass - 2021 Pass - - Pass - 2022 Pass - - Pass - 2023 Fail <25 94.9 Fail - Colonial Pipeline- RDU/001 NCO081469/001 County: Wake Fthd24Ac Begin: 11/1/2013 24hr LC50 ac monit a NonComp: J F M A M 2019 - >100 - - - 2020 - >100 - - - 2021 - Colonial Pipeline/001 NCO031046/001 County: Guilford Fthd24PF Begin: 6/1/2022 Acu Fthd 24hr PF Lim NonComp: J F M A M 2019 - >100 - - - 2020 - >100 - - - 2021 - >100 - - - Colonial Pipeline/002 NCO031046/002 County: Guilford Fthd24PF Begin: 6/1/2022 Acu Fthd 24hr PF Lim NonComp: J F M A M 2019 - >100 - - - 2020 - >100 - - - 2021 - >100 - - - Colonial Pipeline/003 NCO031046/003 County: Guilford Fthd24PF Begin: 6/1/2022 Acu Fthd 24hr PF Lim NonComp: J F M A M 2019 - >100 - - - 2020 - >100 - - - 2021 - >100 - - - Region: MRO Basin: YAD11 Jan Apr Jul Oct SOC JOC: 7Q30: PF: 0.30 IWC: Freq: Q l J A S O N D - Pass - - Pass - - Fail Pass - Pass - - Pass - - Pass - - Pass - - Pass - Region: WARO Basin: CH001 Jan Apr Jul Oct SOC JOC: 7Q10: PF: IWC: Freq: Q l J A S O N D - Pass - - Fail H - - Pass - - Pass - - - Pass - - Fail Fail 94.9>100 - Pass - - Pass - - Region: RRO Basin: NEU02 SOC JOC: 7Q10: NA PF: N/A IWC: 100 Freq: A J J A S O N D - - - >100 - - - Region: WSRO Basin: CPF08 SOC JOC: 7Q10: 0.0 PF: NA IWC: 100 Freq: A J J A S O N D - - - Pass - - - Region: WSRO Basin: CPF08 SOC JOC: 7Q10: 0.0 PF: NA IWC: 100 Freq: A J J A S O N D Pass Region: WSRO Basin: CPF08 SOC JOC: 7Q10: 0.0 PF: NA IWC: 100.0 Freq: A J J A S O N D Pass Legend: P= Fathead minnow (Pimohales Dromelas). H=No Flow (facilitv is active), s = Split test between Certified Labs Page 24 of 115