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Home My WebLink AboutNCG510207_Correspondence_20090623n(D 4/C�jq 5/v 207 John W. Culbreath Environmental Specialist Southeast District CERTIFIED MAIL # 7006 0100 0003 2791 0473 June 23, 2009 Colonial Pipeline Company Office - 704-399-5259 Fax - 704-399-9029 E-mail-jculbrea@colpipe.com Alan W. Klimek NCDENR — Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Re: Colonial Pipeline Company - Delegation of Authority North Carolina NPDES and Non -Discharge Permits Submittal of Duly Authorized Representative Delegation Dear Mr. Klimek: This letter is to inform you of personnel changes for the Operations Manager positions at Colonial Pipeline Company facilities in North Carolina. The Operations Manager at Greensboro/Selma is now Michael N. Cutting; the Operations Manager for Charlotte/SC is now Michael A. Martin (Andy). Attached is a memo from Doug Belden, now Vice President of Operations authorizing those holding these positions to act as duly authorized representatives regarding signatory requirements associated with the above referenced permits. Please contact me if you have any questions or need additional information. Sincerely, John W. Culbreath Environmental Specialist Southeast District Enclosures 1 JUII 2 s DENR - WATER QUALITY POINT SOURCE BRANCH P.O. Box 87 Paw Creek, NC 28130 Cp Colonial Pipeline Company Memo Date: November 1, 2007 To: File Greg Glaze, Operations Manager - Texas Choung Vo, Operations Manager — Louisiana David Peeler, Operations Manager— Mississippi Mike Cutting, Operations Manager — Tenn/Alabama Steve Walsh, Operations Manager —Georgia Ken Bartmo, Operations Manager— Charlotte//SC Darren Pruitt, Operations Manager — Greensboro/Selma Trent Allen, Operations Manager— Virginia Steve Bames, Operations Manager — Baltimore Danika Yeager, Operations Manager —Woodbury Ed Weirsky, Operations Manager — Linden Randy Smith, Environmental Project Manager — Gulf Coast District Jeff Richards, Environmental Project Manager — Southeast District John Wolf, Environmental Project Manager — Northeast District CC: Tom Cervino, Tom Kelly, Rob Barbeauld, Butch Lee, Jane Pajak, Carole Sims From: Doug Belden, General Manager - Operations Re: Duly Authorized Representation Delegation "Responsible Official" and "Responsible Corporate Officer" EPA Administered Permit Programs Background Intmductory Note. In August 2t107, Colonial added a new posit m within its organization titled General Manager - Operations mporting d n,vdy to Coloraalls President and Ctuet Execulke OtTrcer Responsribriths of the now position indude day-to-day oversight over Colonial's operations systemwide. RepoWng to tlua Gem-ral Manager - Operations are Coonial's three District Leaders, the Transportation Services Leader, and Health, Safety and Securfty. The General Manager - Operations represents Operations orr the Leadership Team. Prior to August 2007. each of Cob bars three District Leaders had documented in rnenro's their delegation of duly m4horized tWesentatim" lfor purposes of EPA AdnrinWored Permit Programs} to the Operations Managers within their respective districts. Givon Colonial's recent restructuring, Urns memo is to ro-affirm (and re-dologate to tho oxtont necessary) each of thoso delegations previously made. This memo serves to my document my delegation of authority to the positions set out below to act as Colonial's "responsible official" and/or Colonial's "responsible corporate officer" for purposes of EPA Administered Permit Programs (i.e. 40 CFR 570.2 (Air Program) and 40 CFR §122.22 (NPDES Program)): Operations Manager - Texas Operations Manager— Louisiana Operations Manager— Mississippi y Operations Manager — Tenn/Alabama Operations Manager— Georgia Operations Manager— ChadotteflSC Operations Manager— Greensboro/Selma Operations Manager —Virginia Operations Manager— Baltimore r Operations Manager —Woodbury Operations Manager— Linden My Status of "Responsible Official" and "Responsible Corporate Officer" I am making this delegation as a Colonial "responsible official' and "responsible corporate officer" as those terms are defined in 40 CFR §70.2 and 40 CFR §122.22(a)(1), respectfully. 40 CFR §70.2 provides, in part, as follows: Responsible of fccial means one of the following: (1) For a corporation: a president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy or decision -making functions for the corporation, or a duty authorized representative of such person if the representative is responsible for the overall operation of one or more manufacturing, production, or operating facilities applying for or subject to a permit and either. (i) The facilities employ more than 250 persons or have gross annual sales or expenditures exceeding $25 million (in second quarter 1980 dollars); or (ii) The delegation of authority to such representatives is approved in advance by the permitting authority; 40 CFR §122.22(a)(1) provides as follows: Sec. 122.22 Signatories to permit appli-;ations and reports (a) Applications. All permit applications shall be signed as follows: (1) For a corporation. By a responsible corporate officer. For the purpose of this section, a responsible corporate officer means: (i) A president, secretary, treasurer, or vice-president of the corporation in charge of a principal business function, or any other person who performs similar policy- or decision - making functions for the corporation, or (ii) the manager of one or more manufacturing, production, or operating facilities, provided, the manager is authorized to make management decisions which govern the operation of the regulated facility including having the explicit or implicit duty of making major capital investment recommendations, and initiating and directing other comprehensive measures to assure long term environmental compliance with environmental laws and regulations; the manager can ensure that the necessary systems are established or actions taken to gather complete and accurate information for permit application requirements; and where authority to sign documents has been assigned or delegated to the manager in accordance with corporate procedures. While I do not have the title of president, secretary, treasurer or vice-president I should nevertheless be considered a responsible official under §70.2 and a responsible corporate officer under §122.22(a)(1)(i) due to the fact that I perform similar policy -or decision -making functions for the corporation. I serve as a vital member on various Colonial policy/decision making teams, including Colonials Leadership Team. My responsibilities' include day -today oversight over Colonial's operations system -wide. Reporting to me are Colonial's three District Leaders, the Transportation Services Leader, and Health, Safety and Security. Delegation of Authority to Colonial's Operations Manager - Texas, Operations Manager - Louisiana, Operations Manager- Mississippi, Operations Manager- Tenn/Alabama, Operations Manager - Georgia, Operations Manager - Charlotte!/SC, Operations Manager- Greensboro/Selma, Operations Manager -Virginia, Operations Manager -Baltimore, Operations Manager -Woodbury, and Operations Manager- Linden . Air Program For the Far Program, as provided above in 40 CFR f,70.2(1), a duly authorized representative can act as a 'responsible official" if that person is responsible for the overall operation of one or more operating facilities applying for or subject to a permit and the delegation of authority to such representative is approved ,n advance by the permitting authority. Set out below are Colonial's Operations Managers and each Operations Manager's area of responsibility: ♦ The Operations Manager - Texas is responsible for the overall operation of Colonial's Texas facilities and Colonial's Lake Charles facility. ♦ The Operations Manager - Louisiana is responsible for the overall operations of Colonial's Louisiana facilities (excluding Colonial's Lake Charles facility). a The Operations Manager - Mississippi is responsible for the overall operations of Colonial's Mississippi facilities and Coloniars Epes Station in Alabama. ♦ The Operations Manager - Tenn/Alabama is responsible for the overall operations or Colonial's facilities in Tennessee, overall operation of Colonial's facilities in Alabama (excluding Colonial's Epes Station), and Colonial's Chattanooga Junction and Lookout Mountain Delivery Facility in Georgia. ♦ The Operations Manager - Georgia is responsible for the overall operations of Colonial's Georgia facilities from Alabama to the Big Bear Creek BLV (which is upstream of Athens). The Operations Manager - Georgia is also responsible for the overall operations of Colonial's facilities from Atlanta Junction to the Etowah River BLV (which is downstream of Rome). ♦ The Operations Manager - Charlotte/SC is responsible for the overall operations of Colonial's facilities downstream of the Big Bear Creek BLV (which is upstream of Athens and includes Colonial's Athens and Danielsvilie facilities), Charlotte, Kannapolis and Gastonia facilities in North Carolina and of all Colonial's facilities in South Carolina. o The Operations Manager - Greensboro/Selma is responsible for the overall operation of all of Colonial's facilities in North Carolina (with the exception of Colonial's Charlotte, Kannapolis and Gastonia facilities) and of Colonial's Hickory Grove and Witt facilities in Virginia. o Operations Manager - Virginia is responsible for the overall operation of all of Colonial's facilities in Virginia (with the exception of Colonial's Witt, Hickory Grove, Remington, Bull Run, Chantilly, and Dulles facilities). ♦ Operations Manager - Baltimore is responsible for the overall operations of Colonial's facilities in Maryland and Colonial's Remington, Bull Run, Chantilly, and Dulles facilities located in Virginia. ♦ Operations Manager - Woodbury is responsible for the overall operations of Colonial's New Jersey facilities (with the exception of Colonial's Linden facility) and of Colonial's facilites in Pennsylvania. ♦ Operations Manager - Linden is responsible for the overall operations of Colonial's facilities in Linden, New Jersey, As required by 40 CFR o70.2(1)(ii), Colonial intends to obtain the approval of this delegation from the applicable permitting authorities. NPOES Program For the NPDES Program, under 40 CFR 5122(a)(ii), Colonial's Operations Manager - Texas, Operations Manager - Louisiana, Operations Manager - Mississippi, Operations Manager - Tenn/Alabama, Operations Manager - Georgia, Operations Manager - Charlottel/SC, Operations Manager - Greensboro/Selma, Operations Manager -Virginia, Operations Manager - Baltimore, Operations Manager - Woodbury. and Operations Manager - Linden should be within the definition of "responsible corporate officer. Each Operations Manager is responsible for operations in their respective areas, and are authorized to make management decisions which govern the operation of the regulated facilities under their responsibility including (a) having the explicit or implicit duty of making major capital investment recommendations: (b) initiating and directing other comprehensive measures to assure tong tern environmental compliance with environmental laws and regulations; (c) ensuring that the necessary. systems are established or actions taken to gather complete and accurate information for permit application requirements; and (d) having been delegated authority to sign documents in accordance with corporate procedures. Under some state NPDES Programs, however, Colonial's Operations Manager — Texas, Operations Manager — Louisiana, Operations Manager — Mississippi, Operations Manager — Tenn/Alabama, Operations Manager — Georgia, Operations Manager — Chartotte/SC, Operations Manager — Greensboro/Selma, Operations Manager — Virginia, Operations Manager — Baltimore, Operations Manager — Woodbury, and Operations Manager — Unden may not be considered "responsible corporate officer", as that term is defined under the respective state program. To the extent a delegation of authority is required for Colonial's Operations Manager — Texas, Operations Manager — Louisiana, Operations Manager — Mississippi, Operations Manager — Tenn/Alabama, Operations Manager — Georgia, Operations Manager — Chadotte1/SC, Operations Manager — Greensboro/Selma, Operations Manager — Virginia, Operations Manager — Baltimore, Operations Manager — Woodbury, and Operations Manager — Linden to be considered a duly authorized representative to act as a "responsible corporate officer' for purposes of the applicable state NPDES programs (or other state water programs), this memo is intended to document such delegation. /A Signed this day of November, 2007. z IL Doug Belden General Manager — Operations "This revises my similar memo of October 10, 2007 and corrects the territories listed as being covered by the Operations Manager — TenryAlabama, the Operations Manager — Georgia, and the Operations Manager — Charlottee/SC.