NC0031038_Response to NOV2014LV0336_20141210

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North Carolina Department of Environment and Natural Resources
Pat McCrory John E. Skvarla, Ill
Governor Secretary
December 10, 2014 RECEr�Ep�pENR/pwQ
Mr. John Culbreath DEC 1 5 2014
Environmental Specialist
Colonial Pipeline Company Permater Quality
P.O. Box 87tn.9 Section
Paw Creek, North Carolina 28130
Subject: Review of Colonial Pipeline response to Notice of Violation NOV-2014-LV-0336
Charlotte Delivery Facility
NPDES Permit No. NC0031038
Mecklenburg County
Dear Mr. Culbreath:
On August 19, 2014, this office received a response to the above referenced Notice of Violation (NOV). The
NOV was issued for exceeding the permit limit for total phenolic compounds at Outfall 009 On February 7,
2014. Colonial Pipeline's NOV response requested that the Division consider reducing the NOV to a Notice of
Deficiency (NOD). The response included an assertion that the elevated total phenols result might be attributed
to laboratory error or naturally occurring phenolic compounds from an algal bloom that had formed in the diked
area that drains through Outfall 009.
Upon receipt of your correspondence staff from the Division's Laboratory Certification Branch was contacted to
review the supporting documentation included with your response. The Laboratory Certification program serves
as a vital component in the effort to ensure the quality of analytical data used for regulatory decisions by
multiple divisions within the Department of Environment and Natural Resources (DENR) including the Division
of Water Resource's NPDES discharge program. The Laboratory Certification program operates pursuant to
authority contained in G.S. 143-215.3(a)(1) and 143-215.3(a)(10) and enacts requirements for certified
laboratories through the rules found in North Carolina Administrative Code, 15A NCAC 2H .0800. The program
certifies approximately 700 environmental laboratories in North Carolina and throughout the United States.
The review completed by the Laboratory Certification program's staff did not find grounds to invalidate the
February 7, 2014, sample result based on the performed analytical procedures or the possible interference from
naturally occurring algae. Therefore, the Division cannot reduce the issued Notice of Violation to a Notice of
Deficiency.
If you have questions concerning this matter please do not hesitate to contact Ms. Marcia Allocco or myself at
[phone].
Sicerely,',
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Michael L. Parker, Regional Supervisor
`c Water Quality Regional Operations Section
Division of Water Resources, NCDENR
cc: Wastewater Branch Central Files (MSC 1617-basement)
Mooresville Regional Office
Location:610 East Center Ave.,Suite 301 Mooresville,NC 28115
Phone:[phone] Fax:[phone] Customer Service:1-877-623-6748
Internet:http:l/portal.ncdenr.orglwebtwq