NC0078000_Regional Office Historical File Pre 2016

North Carolina Department of Environment and Natural Resources
Pat McCrory Donald van der Vaart
Governor Secretary
January 15, 2015
Mr. Bruce Biehl, Dir. of Regulatory Affairs
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
SUBJECT: Compliance Evaluation Inspection
Brenntag Groundwater Remediation System — Greensboro, NC
NPDES Permit No. NCO078000
Guilford County
Dear Mr. Biehl:
On January 14, 2015, Mike Mickey of this office met with Herman Dixon, Charlie Herron and
Bill Mesar to perform a Compliance Evaluation Inspection on the groundwater remediation system
at the above mentioned facility. The inspection found the Brenntag treatment system to be
compliant with the NPDES permit. The inspection findings are detailed below and an inspection
checklist is attached for your records.
I. Permit
The NPDES permit was issued on October 1, 2011 and expires on May 31, 2016. Please note -that
at the next renewal, it is expected that the new permit will require Brenntag to begin submitting
monthly self -monitoring reports electronically per the new EPA rule.
H. Records/Reports
The monthly self -monitoring reports (DMRs) were reviewed for the period January 2014 through
October 2014. The facility was found to be in compliance with the NPDES effluent limits for the
above period. Brenntag staff performs the on -site monitoring for continuous flow and pH.
ARCADIS collects the quarterly effluent samples for the remainder of the parameters listed in the
permit. All monitoring was performed per the frequencies specified in the permit.
III. Facility Site Review
The groundwater remediation system consists of the following; extraction wells, a single surge
tank, two in line strainers and an air stripping tower. Flow is monitored using the two mechanical
totalizers on the influent lines from the EW-1 and EW-2 recovery wells. The facility appeared to be
competently operated and maintained. The remediation system was currently shut down due to
pump issues at the EW-1 well.
450 West Hanes Mill Road, Suite 300, Winston-Salem, NC 27105
Phone: [phone] \ Internet: www.ncwaterguality.org
An Equal Opportunity\Affirmative Action Employer —Made in partby recycled paper

Mr. Bruce Biehl
Page 2
January 15, 2015
IV. Flow Measurement
The permit requires continuous flow recording. Flow values reported on the DMR are obtained by
adding the mechanical totalizer readings taken from the influent lines for recovery wells EW-1 and
EW-2.
VI. Effluent/Receiving Waters
The system discharges into a tributary of South Buffalo Creek, class "WS-V; NSW" waters of the
Cape Fear River Basin. No discharge was occurring at the time of the inspection.
Your efforts to comply with the permit are appreciated. Should you have any questions
concerning this letter, please contact Mike Mickey or me at [phone].
Sincerely,
Sherri V. Knight, PE
Assistant Regional Supervisor
Water Quality Regional Operations Section
Division of Water Resources
cc: Herman Dixon, Brenntag Mid -South, Inc. (via email: [e-mail])
Dave Twamley, Arcadis, Inc. ([e-mail])
Central Files - SWP
�USRO_0

14,
Brenntag Groundwater Remediation System
NPDES Permit No. NCO084212
Self -Monitoring Data Summary
January 2014 — October 2014
Parameters
Monthly Avg.
Permit Limit
Monthly Avg. Limit
Violations per DMR
Daily Maximum
Permit Limit
Daily Max. Limit
Violations per DMR
Flow (MGD)*
0.216 MGD
None
-
NA
pH (S.U.)
-
NA
(6.0 - 9.0) range
None
Toluene (ug/L)
-
NA
-
NA
Benzene (ug/L)
-
NA
-
NA
Trans 1,2
Dichloroethene (ug/L)
-
NA
-
NA
Trichloroethene (ug/L)
-
NA
-
NA
Chronic Toxicity (P/F)
monitoring only**
NA
-
NA
* Continuous flow recording.
* * Chronic Toxicity monitoring is a pass/fail test @ 90% with no limit.

3
Permit: NCO078000 Owner - Facility: Brenntag / Greensboro remediation
Inspection Date: 01/14/2015 Inspection Type: Compliance Evaluation
Permit
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
❑
❑N
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
0
❑
❑
Is access to the plant site restricted to the general public?
0
❑
❑
'❑
Is the inspector granted access to all areas for inspection?
N
❑
❑
❑
Comment: The Brenntaq groundwater remediation system was found to be compliant with the NPDES
permit for the review period January 2014 through October 2014 The
permit expires on May
31, 2016.
The groundwater remediation (GWR) system consists of the following components:
*Two recovery wells (EW-1 & EW-2).
*Mechanical totalizers on the EW-1 & EW-2 influent lines (for DMR reporting).
*Surge/holding tank.
*Two in line strainers.
*Air stripping tower.
*Ultrasonic flow meter w/parshall flume.
The system appeared to be competently operated and maintained. The GWR unit has been
shut down since late December 2014 due to issues with the pump at recovery well EW-1.
The effluent has passed 36 consecutive quarterly toxicity tests dating back to 2009.
Flow Measurement - Effluent
Yes No NA NE
# Is flow meter used for reporting?
0
❑
❑
❑
Is flow meter calibrated annually?
N
❑
❑
❑
Is the flow meter operational?
0
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
®
❑
Comment: Flow values on the DMR are obtained from the mechanical totalizers on the influent lines of
recovery wells EW-1 and EW-2. There is also an ultrasonic meter with
parshall flume on
the effluent discharge line.
Effluent Pipe
Yes No NA NE
Is right of way to the outfall properly maintained?
0
❑
❑
❑
Are the receiving water free of foam other than trace amounts and other debris?
®
❑
❑
❑
If effluent (diffuser pipes are required) are they operating properly?
❑
❑
S
❑
Comment: Treated effluent is discharged via a PVC pipe into a tributary of South Buffalo Creek, class
"WS-V: NSW' waters in the Cape Fear River Basin. No discharge was occurring at the
time of the inspection.
Page# 3

A'r1*V1
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Resources
Water Quality Regional Operations Section
Pat McCrory Thomas A. Reeder John E. Skvarla, III
Governor Director Secretary
November 14, 2013
Mr. Bruce Biehl, Dir. of Regulatory Affairs'
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
SUBJECT: Compliance Evaluation Inspection
Brenntag Groundwater Remediation System — Greensboro, NC
NPDES Permit No. NCO078000
Guilford County
Dear Mr. Biehl:
On November 13, 2013, Mike Mickey of this office met with Herman Dixon, Operations Manager,
and Bill Mesar, ORC/Laboratory Manager, to perform a Compliance Evaluation . Inspection on the
groundwater remediation system (GWR) at the above mentioned facility. The inspection found the
Brenntag GWR system to be in complete compliance with the NPDES permit. The inspection findings are
detailed below and an inspection checklist is attached for your records.
1. Permit
The NPDES permit was issued on October 1, 2011 and expires next on May 31, 2016. The system
discharges into a tributary of South Buffalo Creek, class "WS-V; NSW" waters of the Cape Fear River
Basin. No discharge was occurring at the time of the inspection.
2. Records/Reports
The monthly self -monitoring reports (DMR's) were reviewed for the period January 2013 through
September 2013. The facility was found to be in complete compliance with the NPDES effluent limits for
the above period. Brenntag staff performs the on -site monitoring for continuous flow and pH. ARCADIS
collects the quarterly effluent samples for the remainder of the parameters listed in the permit. All
monitoring was performed per the frequencies specified in the permit. In regards to reporting continuous
flow values on the DMR, the more accurate daily mechanical totalizer readings from the EW-1 and EW-2
influent lines are used instead of the effluent readings from the parshall flume.
3. Facility Site Review
The groundwater remediation system consists of the following: extraction wells, a single surge tank, two
in line strainers and an air stripping tower. Flow is monitored using the mechanical totalizer readings
from the EW-1 and EW-2 influent lines. The air stripping tower is to be taken out of service in the near
future to clean the packing material. The facility appeared to be competently operated and maintained. .
North Carolina Division of Water Resources, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
One
NofthCarolina
An Equal Opportunity 1 Affirmative Action Employer

Mr. Bruce Biehl
Page 2
November 14, 2013
Your efforts to comply with the permit are appreciated. Should you have any questions
concerning this letter, please contact Mike Mickey or me at [phone].
Sincerely,
a
W. Corey Basinger
Regional Supervisor
Water Quality Regional Operations
Division of Water Resources
cc: Herman Dixon, Brenntag Mid -South, Inc. (via email: [e-mail])
Dave Twamley, Arcadis, Inc. ([e-mail])
Central Files - SWP
WS"Ift

y
•
Permit: NCO078000 Owner - Facility: Brenntag / Greensboro remediation
Inspection Date: 11/13/2013 Inspection Type: Compliance Evaluation
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
❑
■
❑
Is the facility as described in the permit?
■
❑
❑
❑ _
# Are there any special conditions for the permit?
0011
❑
Is access to the plant site restricted to the general public?
■
❑
❑
❑
Is the inspector granted access to all areas for inspection?
■
❑
❑
❑
Comment: The Brenntag groundwater remediation (GWR) system was found to be
compliant with the NPDES permit for the review period January 2013 through
September 2013. The permit expires next on May 31, 2016.
The GWR system consists of the following components:
*Recovery wells.
*Surge/holding tank.
*Two in line strainers.
*Air stripping tower.
*Ultrasonic flow meter w/parshall flume.
The system appeared to be competently operated and maintained.
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
❑
❑
❑
■
Is the flow meter operational?
■
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
■
❑
Comment: Continuous flow values on the DMR are reported using the more accurate
mechanical totalizers on the EW-1 and EW-2 influent lines instead of the effluent values
from the ultrasonic meter at the parshall flume.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? ■ ❑ ❑ ❑
Are the receiving water free of foam other than trace amounts and other debris? ■ ❑ ❑ ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ■ ❑
Comment: Treated effluent is discharged via a PVC pipe into a tributary of. South
Buffalo Creek, class "WS-V: NSW" waters in the Cape Fear River Basin. No discharge
was occurring at the time of the inspection.
Page # 3

Mickey, Mike
From: [e-mail]
Sent: Wednesday, November 13, 2013 6:05 PM
To: Mickey, Mike
Cc: [e-mail]; [e-mail]
Subject: Fw: DMR flow rates
Mike,
Please see below explanation of the flow reading discrepancies we discussed today during your visit. If you have any
other concerns or questions please let me know.
Thanks,
Herman Dixon
Operations Manager
Brenntag Mid -South
Greensboro, NC
Office: 336-851-6833
Mobile: [phone]
Email: hdixon(a)brenntaq com
--- Forwarded by Herman C Dixon/Mid-South/Brenntag on 11/13/2013 06:00 PM
From: "Twamley, David" <David.TwamleV(a)arcadis-us.com>
To: "BMesar brenntaa.com" <BMesar(o)_brenntag.com>, "hdixon(a)brenntag.com" <hdixon(CDbrenntaq.com>,
Date: 11/13/2013 11:52 AM
Subject: DMR flow rates
Just wanted to clarify the calculation discrepancies between the flow rates reported on the DMR vs. the effluent totalizer recorded
on the data sheet. On the data sheet, the flow rate recorded under "totalizer total' is based off the effluent totalizer, which
measures flow rates inside the flume with a vortex flow meter. The flow rate reported on the DMR is based off the mechanical
totalizers on the EW-1 and EW-2 influent lines.
Most of the time the flow rates between the two methods are very close (i.e. within 10%). However, there are several factors that
can affect the measurements inside the flume and if the detected water height is off by even a centimeter, it can cause a
discrepancy in the reported flow rate. Since the mechanical totalizers are a more accurate form of measuring flow than the vortex
meter, we have always presented the flow rates on the DMR according to the mechanical totalizers.
Thanks,
Dave Twamley, LGI Staff Geologist I davld.twamley(ab-arcadls-us.com
ARCADIS U.S., Inc.[ 801 Corporate Center Drive, Suite 300 1 Raleigh, NC, 27607
T: 919.415.2294 (direct line) I M: 919.949,0461
ARCADIS G&M of North Carolina, Inc.
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NCDENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, PE
Governor
Mr. Bruce Biehl
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
Director
January 26, 2012
Natural Resources
SUBJECT: Compliance Evaluation Inspection
Brenntag Groundwater Remediation System — Greensboro, NC
NPDES Permit No. N00078000
Guilford County
Dear Mr. Biehl:
Dee Freeman
Secretary
On January 25, 2012, Mike Mickey of this office met with Bill Mesar, ORC/Laboratory Manager,
and Charley Herron, . Operations Manager, to perform a Compliance Evaluation Inspection on the
groundwater remediation system (GWR) at the above mentioned facility. This type of inspection consists
of two basic parts: an in office file review and an on -site inspection of the treatment facility. The
inspection found the Brenntag GWR system to be in complete compliance with the NPDES permit. The
attached EPA inspection form notes the eight (8) areas that were evaluated for this inspection. The
findings and observations are outlined below:
I. Permit
The NPDES permit was reissued with an effective date of October 1, 2011. The new permit now has a
chronictoxicity testing concentration of 90% (previously 22%) due to the zero flow classification of the
receiving stream by USGS. Otherwise, the effluent limitations and monitoring requirements remained the
same.
II. Self -Monitoring Program
The monthly self -monitoring reports (DMR's) were reviewed for the period January 2011 through
November 2011. The facility was found to be in complete compliance with final NPDES effluent limits for
the above period. In regards to the permit monitoring requirements, it was noted that all sampling was
performed per the frequencies specified in the permit. It was noted that the words "Guilford County"
were accidently omitted from the self -monitoring reports submitted for non -quarterly sampling months.
Please make sure the county name is included on the effluent page.
III. Flow Measurement
Effluent flow is monitored with a totalizer connected to an ultrasonic meter at the parshall flume. The
totalizer values are cross checked against monitoring well pump rates for accuracy.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107 �oTOne
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748 1v orthCarolina
Internet: www.ncwaterquality.org Naturally
An Equal Opportunity\AffirmativeAction Employer 6d ��JJ��

Mr. Bruce Biehl
Page 2
January 26, 2012
IV. Sludge Handling and Disposal
No solids are generated that require disposal. Grit and precipitate from the wells are collected in one of
two metal baskets located prior to the holding tank.
V. Operations and Maintenance
The facility appeared to be competently operated and maintained. No concerns or problems were noted.
VI. Facility Site Review
The groundwater remediation system consists of extraction wells, a holding/surge tank, in line strainers
(metal baskets), a two stage air stripper and ultrasonic flow meter with parshall flume.
VII. Records/Reports
A review of the facility files showed that all records are being maintained according to the permit. A
comparison of the October DMR with the certified laboratory sheets showed that all data was transcribed
properly.
VIII. Effluent/Receiving Waters
4:,:
The system discharges into unnamed tributary of Buffalo Creek, class "WS-V; NSW' waters of the Cape
Fear River Basin. The effluent was crystal clear on the day of the inspection.
Should you have any questions concerning this report, please contact Mike Mickey or me at (336)
771-5000.
Sincerely,
W. Corey Basinger
Regional Water Quality Supervisor
Surface Water Protection Section
cc: Dave Twamley (Arcadis, Inc., 801 Corporate Center Dr., Suite 300, Raleigh, NC 27607)
Central Files

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
H
OMB No. 2040-0057
Approval expires 8-31-98
Section A: National Data System Coding (i.e., PCS)
Transaction Code NPDES yr/mo/day Inspection Type Inspector Fac Type
1 I N I 2 I, I 31 NCO078000 111 121 12/01/25 117 181 C I 191 c I 201 I
luJ 1uI �J IJ LJ
Remarks
21111111111111111111111111111111111111111111111116
Inspection Work Days Facility Self -Monitoring Evaluation Rating B1 QA -------- -----"---Reserved-------------
671 169 70I 31 71 Lj 72 U N ( 73 � 74 751 I I I I I 1 180
�--�
Section B: Facility Data
Name and Location of Facility Inspected (For Industrial Users discharging to POTW, also include
Entry Time/Date
Permit Effective Date
POTW name and NPDES permit Number)
i
09:00 AM 12/01/25
11/10/01
Brenntag / Greensboro remediation
Exit Time/Date
Permit Expiration Date
2 Segal Blvd
Greensboro NC 27409
10:05 AM 12/01/25
16/05/31
Name(s) of Onsite Representative(s)/Titles(s)/Phone and Fax Number(s)
Other Facility Data
William M Mesar/ORC/336-851-6772/
Name, Address of Responsible OfficiallTitle/Phone and Fax Number
Contacted
Bruce Donald Biehl,2000 E Pettigrew St Durham NC
No
277034049/Director/919-281-2932/9195965441
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement ® Operations & Maintenance ® Records/Reports
Self -Monitoring Program ® Facility Site Review Effluent/Receiving Waters
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
(See attachment summary)
Name(s) and Signature(s) of Inspector(s) Agency/Office/Phone and Fax Numbers Date
Michael M Mickey WSRO WQ//336-771-5000/
tt
Signature��Jyo�f ManagemenQ A Reviewer Age�}n�cy/Office/Phone/y�and Fax N/ umbers D
tt
ya/te ^J
�yf
EPA Form 3560-3 (Rev 9-94) Previous editions are obsolete.
Page # 1

Permit: NCO078000
Inspection Date: 01/25/2012
Permit
Owner • Facility: Brenntag / Greensboro remediation
Inspection Type: Compliance Evaluation
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
Is the facility as described in the permit?
# Are there any special conditions for the permit?
Is access to the plant site restricted to the general public?
Is the inspector granted access to all areas for inspection?
Comment: The NPDES permit was reissued effective October 1, 2011. The new
permit now has a chronic toxicity testing effluent concentration of 90% (previoulsy 22%).
Operations & Maintenance
Is the plant generally clean with acceptable housekeeping? Is ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ ❑ ■ ❑
Judge, and other that are applicable?
Comment: The groundwater remediation system consists of extraction wells,
holding/surge tank, in line strainer with metal baskets, a 2 stage air stripper and
ultrasonic flow meter with parshall flume. No concerns were noted with the operation
and maintenance of the system.
Record Keeping
Yes No
NA NE
Are records kept and maintained as required by the permit?
■ ❑
❑ ❑
Is all required information readily available, complete and current?
®❑
❑ ❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
®❑
❑ ❑
Are analytical results consistent with data reported on DMRs?
®❑
❑ ❑
Is the chain -of -custody complete?
❑ ❑
❑
Dates, times and location of sampling
❑
Name of individual performing the sampling
❑
Results of analysis and calibration
❑
Dates of analysis
❑
Name of person performing analyses
❑
Transported COCs
❑
Are DMRs complete: do they include all permit parameters?
® n
❑ ❑
Has the facility submitted its annual compliance report to users and DWQ?
❑ ❑
® ❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
❑ ❑
■ ❑
Is the ORC visitation log available and current?
❑ ❑
❑ im
Page # 3

J
Permit: NCO078000 Owner - Facility: Brenntag / Greensboro remediation
Inspection Date: 01/25/2012 Inspection Type: Compliance Evaluation
Record Keeping Yes No NA NE
Is the ORC certified at grade equal to or higher than the facility classification? ❑ ❑ ❑ ■
Is the backup operator certified at one grade less or greater than the facility classification? ❑ ❑ ❑ ■
Is a copy of the current NPDES permit available on site? ®❑ ❑ ❑
Facility has copy of previous year's Annual Report on file for review? ❑ ❑ ® ❑
Comment: The GWR systems is classified as PC-1. All records (pH calibration, flow
totalizer volumes) were thorough and complete. A comparison of the October 2011
self -monitoring report with the corresponding analytical results showed that the
laboratory values were transcribed onto the DMR properly. It was noted that some of
the monthly self -monitoring reports did not have "Guilford County" listed on the effluent
page. Please make sure that the county name is listed on the DMR.
Flow Measurement - Effluent Yes No NA Nt
# Is flow meter used for reporting? ®❑ ❑ ❑
Is flow meter calibrated annually? ®❑ ❑ ❑
Is the flow meter operational? 12000
(If units are separated) Does the chart recorder match the flow meter? 00130
Comment: The system has a totalizer connected to the ultrasonic meter located at the
parshall flume.
Effluent Pipe Yes No NA NE
Is right of way to the outfall properly maintained? ®❑ ❑ Cl
Are the receiving water free of foam other than trace amounts and other debris? ®❑ Cl ❑
If effluent (diffuser pipes are required) are they operating properly? ❑ ❑ ® ❑
54
Comment: The effluent discharge into the unnamed tributary to Buffalo Creek, class
WS-V; NSW waters, was crystal clear.
Effluent Sampling Yes No NA NE
Is composite sampling flow proportional? ❑ ❑ ® ❑
Is sample collected below all treatment units? ®❑ ❑ ❑
Is proper volume collected? ®❑ ❑ Cl
Is the tubing clean? ❑ ❑ ® ❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)? ❑ ❑ ® ❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)? ©❑ ❑ ❑
Comment: The permit specifies grab samples for all parameters. Effluent sampling
occurs at the parshall flume.
Page # 4

Mickey, Mike
From: Twamley, David [[e-mail]]
Sent: Wednesday, January 25, 2012 3:21 PM
To: Mickey, Mike
Subject: RE: Brenntag DMR's
Thanks, Mike. I have revised our DMR template to include "Guilford County" in the appropriate location, so this will not
be a problem moving forward.
Best regards,
PLEASE NOTE THE NEW DIRECT DIAL PHONE NUMBER BELOW
Dave Twamley, LG I Staff Geologist I david.twamley(cc)-arcadis-us.com
ARCADIS U.S., Inc. 801 Corporate Center Drive, Suite 300 1 Raleigh, NC, 27607
T. 919.415.2294 1 M. 919.949.0461 1 F. 919.854.5448
www.arcadis-us.com
ARCADIS G&M of North Carolina, Inc.
From: Mickey, Mike [mailto:[e-mail]]
Sent: Wednesday, January 25, 2012 3:08 PM
To: Twamley, David
Subject: Brenntag DMR's
Dave —Just a heads up on one thing I forgot to mention. The non -quarterly DMR's for Brenntag are missing the words
"Guilford County" at the top of the Effluent page. I believe Bill Mesar said he was going to get you to make this
correction. Thanks, Mike.
�'EFFLUENT
NPDES 11bRMITN0, NC,0078000.. D1SC1-1ARGE NO, 001..___ i\+1ON11I November YEAR 2
UA0I ITY'NA1%,1E1 i;rcnlitag Southeast, Inc CLASS—PC-1-
CE.RTW IE D L A 110RA'I'ORY (E) C:ER-111"ICATION NO. -
(list additional Iaboriltories on the backside/page 7 of this iornl) �
OPERATOR IN RESPONSIBLE CHARCiE (ORC) Bill Mesar GRADE PC• 1 CERTIV10 ION N0. 9
C.'lil:.,'K 1104 II; 0HC11AS tall
Pd.CA-gf
IN -lad ORIGINAL and ONP E f 11Y t3.
A*J-I'N: CENTRAL FILES
011VISIONOF Wt VVR Qtl,at,ITV
I617,1rAll—SERVICECt:1''1Ell Vditts4o
RA1,1 GII, ;\'C 27691)9 I.617
av1� 13 -.�n ua Southeast)Y,��� OR(' PHONE,�u(3 'G�?9�-51 tit,
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b7111V

Mike Mickey
[e-mail]
NC Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
FAX: [phone]
E-mail correspondence to and from this address may be subject to the North
Carolina Public Records Law and may be disclosed to third parties.
NOTICE: This e-mail and any files transmitted with it are the property of ARCADIS U.S., Inc. and its affiliates. All rights,
including without limitation copyright, are reserved. The proprietary information contained in this e-mail message, and any
files transmitted with it, is intended for the use of the recipient(s) named above. If the reader of this e-mail is not the
intended recipient, you are hereby notified that you have received this e-mail in error and that any review, distribution or
copying of this e-mail or any files transmitted with it is strictly prohibited. If you have received this e-mail in error, please
notify the sender immediately and delete the original message and any files transmitted. The unauthorized use of this e-
mail or any files transmitted with it is prohibited and disclaimed by ARCADIS U.S., Inc. and its affiliates. Nothing herein is
intended to constitute the offering or performance of services where otherwise restricted by law.

Mickey, Mike
From: Pickle, Ken
Sent: Wednesday, January 18, 2012 3:15 PM
To: Mickey, Mike
Subject: RE: Brenntag NCS
Attachments: image001.png,
Hi Mike,
Nice to hear from you: NCS000551 is on my desk and in review. It is for the Durham facility, which is under SOC with
RRO.
ken
Ken Pickle
Environmental Engineer
NCDENR I DWQ I Stormwater Permitting Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http://port6l.ncdenr.org/web/wg/ws/su
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
From: Mickey, Mike
Sent: Wednesday, January 18, 2012 3:06 PM
To: Pickle, Ken
Subject: Brenntag NCS
Ken — Inspecting the individual NPDES groundwater remediation system at Brenntag's Greensboro facility next week.
Noticed that there is an individual stormwater permit (NCS000551) that is under review. Is that for the Greensboro or
Durham facility? Thanks, Mike.

Owner Incidents. Owner Enforcements Owner -Violations Owner Projects Owner History - . .
Owner Details r Owner Delegations r Owner Affiliations r Owner Facilities `' Owner Permits Owner Inspections
Owner: Brenntag Southeast Inc
Permit
Version
Status
TYP e
Facility
0078000AC
1.0
Active
Authorization to Construct NPDES Wa...
Brenntag I Greensboro remediation
086827ACA
1.0
Active
Authorization to Construct NPDES Wa...
Brenntag I Durham remediation
NCO078000
1.0
Inactive
Groundwater Remediation Discharge
Brenntag I Greensboro remediation
NCO078000
1.1
Inactive
Groundwater Remediation Discharge
Brenntag I Greensboro remediation
NCO078000
2.0
Inactive
Groundwater Remediation Discharge
Brenntag I Greensboro remediation
N00078000
3.0
Active
Groundwater Remediation Discharge
Brenntag I Greensboro remediation
NCO086827
1.0
Inactive
Groundwater Remediation Discharge
Brenntag I Durham remediation
NCO086827
2.0
Inactive
Groundwater Remediation Discharge
Brenntag I Durham remediation
NCO086827
3.0
Active
Groundwater Remediation Discharge
Brenntag I Durham remediation
NCG510142
1.0
Inactive
Groundwater Remediation Wastewat...
Brenntag I Greensboro remediation
I'review— "
StormSAatbr Dischii g96"�llndiuidual ' . '
Br,66'6 ags 'oufhea'st ln`c7;
NCS000007
1.0
Active
Tracking number for nonpermited 50...
Brenntag Southeast Inc.
WM0300381
1.0
Inactive
Monitoring Well Construction
Brenntag Southeast, Inc. - Tuckas...
Details...
Help I < Bask I Ne'd = Finish Cancel
1113 Permits found. l Ready I 1 SID: OWPT
Mike Mickey
Mike.Mickev(@NCDENR.eov
NC Division of Water Quality
585 Waughtown Street
Winston-Salem, NC 27107
Phone: [phone]
FAX: [phone]
.E-mail correspondence to and from this address may be subject to the North
Carolina Public Records Law and may be disclosed to third parties.
2

Aj�LA re*-
WDEN R 7
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
BRUCE BIEHL
DIRECTOR OF REGULATORY AFFAIRS
BRENNTAG SOUTHEAST INC
2000 EAST PETTIGREW STREET
DURI IAM NC 27703
Dear Mr. Biehl:
Division of Water Quality
Coleen H. Sullins
Director
December 1, 2010
RECEIVED Dee Freeman
N.C. oect. of _"JR Secretary
DEC 0 7 2010
Winston-Saler,
Regional Office
Subject: Receipt of permit renewal application
NPDES Permit NCO078000
Brenntag/Greensboro Remediation
Guilford County
The NPDES Unit received your permit renewal application on November 29, 2010. A member of the
NPDES Unit will review your application. They will contact you if additional information is required to complete
your permit renewal. You should expect to receive a draft permit approximately 30-45 days before your existing
permit expires.
If you have any additional questions concerning renewal of the subject permit, please contact Jeff Poupart at
[phone].
Sincerely,
Dina Sprinkle
Point Source Branch
cc: CENTRAL FILES
1in'S[cIteg>"onal Office/Surface Water Protection
NPDES Unit
James E. Shilliday, III, L.G., Principal Scientist/Project Manager, ARCADIS G&M of North Carolina, Inc.,
801 Corporate Center Drive, Suite 300, Raleigh, NC 27607-5073
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] \ FAX: [phone] \ Customer Service: 1-877-623-6748
Internet: wvrj.ncvvaterquality.org
An Equal Opportunity , Affirmative Action Employer
NorthCarolina
Naturallff

'Jin;ton-Salern
RECEIVED
N.C. Dent. of ENR
DECS0 � �0 i�
Regional Office
ARCADIS
Subject: Date:
NPDES Permit Renewal Application, Groundwater Remediation System, Brenntag November 23, 2010
Southeast, Inc., (Former Worth Chemical Facility), Greensboro, North Carolina.
NPDES Permit No. NCO078000 Contact:
Jim Shilliday
Dear Mrs. Sprinkle: extension:
246
On behalf of Brenntag Southeast, Inc. (Brenntag Southeast), ARCADIS G&M of E-mail:
North Carolina, Inc. (ARCADIS) has enclosed one original and two copies of the jshilliday@arcadis-
National Pollutant Discharge Elimination System (NPDES) permit renewal us.com
application for the continued discharge of effluent from a groundwater remediation
system at the Brenntag Southeast facility (formerly Worth Chemical facility) in Our ref:
Greensboro, North Carolina. Treated groundwater from the remediation system is NC102030.0010
discharged directly to an un-named tributary of South Buffalo Creek located along
the eastern boundary of the site. Other items enclosed with this letter in support of
the NPDES permit renewal application include: a copy of the October 2010
Discharge Monitoring Report (Attachment A) which summarizes the most recent
analytical data for the system effluent; a USGS topographic map of the project area
that depicts the location of the system outfall (Figure 1); and a site map that depicts
the route of the treated water to the discharge point (Figure 2).
Sludge is neither generated nor discharged by the groundwater remediation system;
therefore, a sludge management plan has not been included with this application.
Any solids (i.e. silt, iron and manganese precipitate) generated during the
groundwater extraction process are filtered from the treatment stream using bag
filters. The existing NPDES permit for the facility does not have an effluent
monitoring requirement for suspended solids.
Part of a bigger picture

If you have any questions regarding the information presented in the NPDES permit
application or any of the supporting material, please call us at [phone].
Sincerely,
ARCADIS G&M of North Carolina, Inc.
E. Shilliday, III, L.G.
)al Scientist/Project Man er
Copies:
Mr. Bruce Biehl, Brenntag Southeast, Inc.
Mr. Bill Mesar, Brenntag Southeast, Inc.
File
GAENV\Wonh Chemical\Greensboro Facility\NC102030.0010\NPDES Permit Renewal Application\Cover Letter for NPDES Permit Renewal.doc
Page:
2/2

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
RECEIVED
N.C. Deot. of ENR
DEC 0 7 2010
Winston-Salem
Regional office
NPDES Permit Number INCO078000
If you are completing this form in computer use the TAB key or the up - down arrows to move from one.
field to the next. To check the boxes, click your mouse on top of the box. Otherwise, please print or type.
1. Contact Information:
Owner Name
Facility Name
Mailing Address
City
State / Zip Code
Telephone Number
Fax Number
e-mail Address
Bruce Biehl
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham
North Carolina 27703
[phone]
[phone]
[e-mail]
2. Location of facility producing discharge:
Check here if same as above ❑
Street Address or State Road
City
State / Zip Code
County
2 HCI Boulevard
Greensboro
North Carolina/27409
Guilford
3. Operator Information:
Name of the f tn4 consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC) F-a
Name ARCADIS a; t' ;a
Fg
Mailing Address 801 Corporate Center Drive, Suite 300 11 0
City Raleigh I I
AUTY
State / Zip Code North Carolina 27607 f -;;; r SOURCE `3R(aNG hi
Telephone Number [phone]
Fax Number [phone]
4. Ownership Status:
Federal ❑ State ❑ Private ® Public ❑
Page 1 of 3 C-GW 03/05

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ® Other chlorinated and
nonchlorinated solvents
6. Number of separate discharge points: 1
Outfall Identification number(s) 001
7. Frequency of discharge: Continuous ® Intermittent ❑
If intermittent:
Days per week discharge occurs: Duration:
S. Treatment System Design flow 0.216 MGD
9. Name of receiving stream(s) (Provide a map showing the exact location of each outfail, including
latitude and longitude):
Unnamed Tributary to South Buffalo Creek
36 03 51.92N
79 52 37.38W
10. Please list all additives to the treatment system, including chemicals or nutrients, that have
the potential to be discharged.
No chemical additives are addeded to the treatment system
11. Is this facility located on Indian country? (check one)
Yes ❑ No
12. Additional Information
All applicants (including renewals):
A USGS topographical map (or copy of the relevant portion) which shows all outfalls
A summary of the most recent analytical results (effluent data, if available) containing the
maximum values for each chemical detected
NEW Applicants only:
Engineering Alternative Analysis
Description of remediation treatment system components, capacities, and removal efficiency
for detected compounds.
If the treatment system will discharge to a storm sewer, written approval from the
municipality responsible for the sewer.
A list of any chemicals found in detectable amounts at the site, with the maximum observed
concentration reported for each chemical (the most recent sample must be collected less
than one year prior to the date of this application)
For petroleum -contaminated sites - Analyses for Volatile Organic Compounds (VOC) should
be performed. Analyses for any fuel additives likely to be present at the site and for phenol
and lead should also be performed.
For sites contaminated with solvents or other contaminants - EPA Method 624/625
analysis should be performed.
Page 2 of 3 C-GW 03/05

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Bruce Biehl Director of Regulatory Affairs
Printed name of Person Signing Title
Signature of Applicant
Date
1k Z3/Zo 10
North Carolina General Statute 143-215.6 (b)(2) provides that: Any person who knowingly makes any false
statement representation, or certification in any application, record, report, plan, or other document files or
required to be maintained under Article 21 or regulations of the Environmental Management Commission
implementing that Article, or who falsifies, tampers with, or knowingly renders inaccurate any recording or
monitoring device or method required to be operated or maintained under Article 21 or regulations of the
Environmental Management Commission implementing that Article, shall be guilty of a misdemeanor punishable
by a fine not to exceed $25,000, or by imprisonment not to exceed six months, or by both. (18 U.S.C. Section
1001 provides a punishment by a fine of not more than $25,000 or imprisonment not more than 5 years, or both,
for a similar offense.)
Page 3 of 3 C-GW 03105

ATTACHMENT A
DISCHARGE MONITORING
REPORT - OCTOBER 2010
gAenWworth chemicallgreensboro fact ityft102030.00101mpdes permit renewal applicationicover letter for npdes permit renewal.doc

Infrastructure, environment, facilities ARCADIS G&M of North Carolina,
Inc.
801 Corporate Center Drive
ATTN: Central Files Suite 300Raleigh,
Division of Water Quality North Carolina 27607-5073
North Carolina Department of Environment and Natural Resources Tel [phone]
1617 Mail Service Center Fax [phone]
Raleigh, North Carolina 27699-1617 www.arcadis-us.com
Subject: ENVIRONMENTAL
Discharge Monitoring Report for October 2010, Brenntag Southeast Facility
2 HCI Boulevard, Greensboro, North Carolina
NPDES Permit No. NCO078000
Guilford County
Date:
Dear Sir or Madam:
November 23, 2010
ARCADIS is pleased to submit the attached Discharge Monitoring Report (DMR) for Contact: Jim S
m Shilliday
the month of October 2010 on behalf of Brenntag Southeast, Inc. for the facility
located at 2 HCI Boulevard in Greensboro, North Carolina. Also attached is the Phone:
laboratory analytical data report for the parameters shown on the DMR and a copy of Ext. 246
the Effluent Aquatic Toxicity Report Form (Form AT-1).
Email:
During October 2010, the groundwater remediation system operated throughout the [e-mail]
month with no downtime. A total of 1,401,951 gallons of water were extracted and
treated by the groundwater remediation system from September 29, 2010 to October Our ref:
29, 2010. As of October 29, 2010, approximately 303,799,521 gallons of water had NC102030.0010
been extracted and treated by the groundwater remediation system since activation of
the system in October 1992.
The pH of the effluent from the groundwater remediation system was analyzed on
October 25, 2010. The measurement indicated an effluent pH of 7.32 standard units,
which is in compliance with the stipulated range of 6 to 9 standard units.
The groundwater remediation system effluent was sampled on October 19, 2010, and
the effluent sample was analyzed for selected volatile organic compounds (VOCs) by
EPA Method 8260 as required by the NPDES permit. All parameters were in
compliance with permit requirements.
The remediation system effluent was sampled for the chronic toxicity test on October
19 and 22, 2010. The grab samples were transported on ice to Research & Analytical
Laboratories, Inc. in Kemersville, North Carolina. The samples were analyzed in
accordance with the test procedures outlined in the North Carolina C'eriodaphnia
Chronic Effluent Toxicity Procedure (revised February 1998). The effluent samples
passed the chronic toxicity test.
Part of a bigger picture

As required by the NPDES permit, the remediation system effluent will be sampled
again for VOCs and chronic toxicity testing during the next quarterly sampling event
in January 2011.
If you have any questions regarding the information presented in this letter or on the
DMR, please call one of the individuals listed below.
Sincerely,
ARCADIS G&M of North Carolina, Inc.
David Twamley, L.G.
Staff Scientist
Copies:
Bruce Biehl—Brenntag Southeast (Durham)
Bill Mesar—Brenntag Southeast (Greensboro)
Project File
Ja5hes E. Shilliday,
ncipal Scientist/
Project Manager
Page:
G:\ENV\Worth ChemicahGreensboro Facility\NC102030.0010\NPDES\10-2010 October DMR and chronic tox\Oct 2010 - DWQ letter.doc 2/2

EC...-- d s1... r
EFFLUENT K`;0V? 1 ' 2010
NPDES PERMIT NO. NCO078000 DISCHARGE NO. 001 MONTH October YEAR 2010
FACILITY NAME Brenntag Southeast. Inc CLASS PC-1 COUNTY Guilford
CERTIFIED LABORATORY (1) Test America. Inc. CERTIFICATION NO. 269
(list additional laboratories on the backside/page 2 of this form)
OPERATOR IN RESPONSIBLE CHARGE (ORC) Bill Mesar GRADE PC-1 CERTIFICATION NO.985455
PERSON(S) COLLECTING SAMPLES Dave Twamlev (ARCADIS G & M) ORC PHONE [phone]
CHECK BOX IF ORC HAS CHANGED * ® NO FLOW / DISCHARGE FROM SITE
Mail ORIGINAL and ONE COPY to:
ATTN: CENTRAL FILES
DIVISION OF WATER QUALITY
1617 MAIL SERVICE CENTER
RALEIGH, NC 27699-1617
BY THIS SIGNATURE, I CERTIFY THAT THIS REPORT IS
ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE.
II•II
•I I
1 I
���--_-_--
11 •
______-
1 .
DWQ Form MR-1.1 (11/04)

Facility Status: (Please check one of the following)
All monitoring data and sampling frequencies meet permit requirements
(including weekly averages, if applicable)
Compliant
All monitoring data and sampling frequencies do NOT meet permit requirements F-1
Noncompliant
The permittee shall report to the Director or the appropriate Regional Office any noncompliance that potentially
threatens public health or the environment. Any information shall be provided orally within 24 hours from the time the
permittee became aware of the circumstances. A written submission shall also be provided within 5 days of the time the
permittee becomes aware of the circumstances.
If the facility is noncompliant, please attach a list of corrective actions being taken and a time -table for
improvements to be made as required by Part II.E.6 of the NPDES permit.
.1 certity, under penalty of law, that this document and all attachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who managed the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I am aware that there are significant penalties for submitting false information, including the
possibility of fines and imprisonment for knowing violations"
Bill Mesar
Permittee (Please print or type)
Signature Pe ittee** Date
(Required unless submitted electronically)
Brenntag Southeast, Inc. 2000 East Pettigrew
Street, Durham, NC 27703 [phone] May 31, 2011
Permittee Address Phone Number e-mail address Permit Expiration Date
Certified Laboratory (2)
ADDITIONAL CERTIFIED LABORATORIES
R&A Laboratories Certification No.
Certified Laboratory (3) Certification No.
Certified Laboratory (4) Certification No.
Certified Laboratory (5)
PARAMETER CODES
Certification No.
34
Parameter Code assistance may be obtained by calling the NPDES Unit at [phone] or by visiting the Surface
Water Protection Section's web site at h2o.enr.state.nc.us/was and linking to the unit's information pages.
Use only units of measurement designated in the reporting facility's NPDES permit for reporting data.
* No Flow/Discharge From Site: Check this box if no discharge occurs and, as a result, there are no data to be
entered for all of the parameters on the DMR for the entire monitoring period.
** ORC On Site?: ORC must visit facility and document visitation of facility as required per 15A NCAC 8G .0204.
*** Signature of Permittee: If signed by other than the permittee, then the delegation of the signatory authority must be on
file with the state per 15A NCAC 2B .0506(b)(2)(D).
Page 2

Analytical Data
Client: ARCADIS U.S., Inc. Job Number. 680-62361-1
Client Sample ID: Effluent
Lab Sample ID: 680-62361-1
Date Sampled: 10/19/20101030
Client Matrix: Water
Date Received: 10/20/2010 0927
8260B Volatile Organic Compounds (GCIMS)
Method: 8260B
Analysis Batch: 680-184305
Instrument ID: MSP
Preparation: 5030B
Lab File ID: p0083.d
Dilution: 1.0
Initial Weight/Volume: 5 mL
Date Analyzed: 10/27/2010 1335
Final Weight/Volume: 5 mL
Date Prepared: 10/27=10 1335
Analyte
Result (ug/L)
Qualifier RL
Benzene
1.0
U 1.0
Toluene
1.0
U 1.0
trans-1,2-Dichloroethene
1.0
U 1.0
Trichloroethene
1.0
U 1.0
Surrogate
%Rec
Qualifier Acceptance Limits
4-Bromoiluorobenzene
94
75 -120
Dibromofluoromethane
100
75 -121
Toluene-d8 (Surr)
101
75 -120
TestAmerica Savannah Page 6 of 11

Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 10/28/10
Facility: BRENNTAG SOUTHEAST NPDES#: NCO078000 Pipe#: 001 County: GUILFORD
Laboratory P i Test: R & A LABORATORIES, INC.
Comments: Final Effluent
X
tur o 015-er-atoV in Responsible Charge An Arcadis Project
IX i v
STqngt-Are bot Laboratory Supervisor * PASSED: 2.12% Reduction
Work Order: 686618/68698 Environmental Sciences Branch
MAIL ORIGINAL TO: Div. of Environmental Management
N.C. Dept. of EHNR
1621 Mail Service Ctr
Raleigh, North Carolina 27699-1621
I
Torun uarolina L:er3.0aap1uua
Chronic Pass/Fail Reproduction Toxicity Test
!ONTROL ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced II21I25I22I27I23I24I22I23I23I24I26I23
Adult (L)ive (D)ead IIL IL IL IL IL IL IL IL IL IL IL IL
affluent %: 22%
VREATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12
# Young Produced II25I24I22I21I24I25I22I23I24I21I23I23
Adult (L)ive (D)ead IIL IL IL IL IL IL IL IL IL IL IL IL
Chronic Test Results
Calculated t = 0.783
Tabular t = 2.508
Reduction = 2.12
Mortality
Avg.Reprod.
0.00
23.58
Control
Control
0.00
1 23.08
Treatment 2
Treatment 2
Control CV
7.335% PASS FAIL
control orgs X
producing 3rd
brood Check One
100%
1st sample lst sample 2nd sample Complete This For Either Test
pH Test Start Date: 10/20/10
Control 6.92 !7].02
6.94 7.03 6.95 7.04 Collection (Start) Date
Sample 1: 10/19/10 Sample 2: 10/22/10
Treatment 2 6.94 6.96 7.06 6.97 7.05 Sample Type/Duration 2nd
1st P/F
s s s Grab Comp. Duration D
t e t e t e I I S S
a n a n a n Sample i X hrs L A A
r d r d r d I U M M
t t t Sample 2 X hrs T P P
1st sample 1st sample 2nd sample
D.O. Hardness (mg/1) 48 ....,,. ........
Control 8.6 g8.4 8.6 8.3 8.6 8.4Spec. Cond.(µmhos) 182 411 409
Treatment 2 8.5 8.6 8.2 8.6 8.3
Chlorine (mg/1) ........ 0.04 0.02
LC50/Acute Toxicity Test Sample temp. at receipt (0C) ....... 2.4 2.6
Wnrtnlity exnressed as %, combining replicates)
Note: Please
Concentration Complete This
Section Also
Mortality
start/end start/end
LC50 = % Method of Determination
95% confidence Limits Moving Average _ Probit _
-- % Spearman Karber _ Other
Organism Tested: Ceriodaphnia dubia Duration(hrs):
Control
EEI
High
r^n r,
pH
•
Copied from DEM form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.32)

FIGURES
gAemAworlh chemical\greensboro facilit\Anc102030.0010\npdes permit renewal applicallon\cover letter for npdes permit renewal.doc

QUADRANGLE LOCATION
SCALE 1:24000
0 2000 4000
6=mmmm� i
SOURCE: TOPOGRAPHY TAKEN FROM USGS 7.5 MINUTE QUADRANGLE
GUILFORD AND GREENSBORO, NC MAPS
1951 AND PHOTOREVISED IN 1994
V2 ARCADIS
Infrastructure buildings, environme
REV. DRAWING DATE:
1 /9/06
801 Corporate Center Drive,
Suite 300
Raleigh, NC 27607
919.854-1282
FILE:
SITE LOCATION MAP
CLIENT: BRENNTAG SOUTHEAST, INC. Pm: is
LOCATION: 2 HCI BOULEVARD PE/RG:
GREENSBORO,NC
DESIGNED: I DETAILED: I PROJECT NO: FIGURE:
CJK
NC102030.0010

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BUILDINGS/STRUCTURES
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Auction Shop
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laa Too
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Uae �
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PropedY
PRJT MANAGER, CHECKED BY, DRAFTER,
SHILLIDAY C. KALINOVSKY A VARREN
PROJECT NUMBER-
NC102030.0005
FIGURE:
ARCADIS
NOTES:
I. Bwmne y Dumckl 8 uDu hmP.C.Locations ar based on site map
provided by Duncktee 6 Dunham P.C. May 2002.
BRENNTAG SOUTHEAST, INC.
SITE MAP
2
ARcaws cxu ar NwN carc6aa. iaa.
eo1 camo,ah c-t" D,i a -tx aoo
GREENSBORO, NORTH CAROLINA
R-i9h, NC 27607
iel: 919-854—ITD2 F94: 919-054-5448
�N�arcatlia—ua.com

XA
WDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
9 April 2010
Mr. Bruce D. Biehl, Director of Engineering
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
SUBJECT: Compliance Evaluation Inspection
Brenntag Southeast, Inc.
NPDES Permit No. NCO078000
Guilford County
Dear Mr. Biehl:
A Compliance Evaluation Inspection was performed on Brenntag Southeast, Inc. wastewater treatment facility on April 9,
2010 by Corey Basinger of the Winston-Salem Regional Office. Mr. Bill Mesar, ORC, Mr. Charley Herron, Back-up ORC
and Mr. David Twamley (ARCADIS) were present for the subject inspection. The inspection consisted of two parts: an
on -site inspection of the treatment facility and an in -office file review. The following are the findings from the subject
inspection.
I. Permit
The NPDES permit for Brenntag Southeast, Inc. became effective on July 1, 2006 and expires on May 31, 2011.
II. Records/Reports
:A review of the laboratory reports and Discharge Monitoring Reports (DMRs) revealed no discrepancy between the
generated data and the data submitted to DWQ. A copy of the laboratory data is kept on file. All applicable data is
collected as per the NPDES permit requirements.
III. Facility Site Review
The permit states that the treatment works consist of a groundwater remediation system with extraction wells, surge tank,
in -line strainer, a 2-stage air stripper and discharge to an unnamed tributary to South Buffalo Creek.
IV. Effluent & Receiving Waters
The Brenntag Southeast, Inc. discharges to an unnamed tributary to South Buffalo Creek (Class C NSW waters in the Cape
Fear River Basin). On the date of the inspection, the stream was free of solids, grease, and foam. It had rained
approximately 2.25 inches the day prior to the inspection. The discharge location was confirmed with via GPS with the
following coordinates: 36°03'52"N and 79°52'38"W.
V. Flow Measurement
Flow is measured utilizing meter readings from extraction wells. An ultrasonic flow measurement device is also utilized.
VI. Self -Monitoring Program
A review of the discharge monitoring reports (DMRs) for the time period of January 2009 through January 2010 showed
that Brenntag Southeast, Inc. experienced no permit effluent limitation violations.
VII. Compliance Schedules
No compliance schedule to evaluate.
VIII. Laboratory
All of the samples are taken to a contract lab (TestAmerican Savannah) for analysis.
North Carolina Division of Water Quality, Winston-Salem Regional Office
Location: 585 Waughtown St. Winston-Salem, North Carolina 27107
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
011C
NorthCarollna
An Equal Oppoaunily 1 Affirmative Action Employer .

IX. Operations and Maintenance
No problems noted with respect to operation. Maintenance is performed as needed.
X. Sludge Utilization/Disposal, Pretreatment, Pollution Prevention, and Multimedia
Not applicable for this inspection.
XI. Stormwater
Not evaluated during this inspection.
XII. Sewer Overflow
None to report.
XIII. Other
None.
Previous inspection was conducted by Corey Basinger on January 30, 2008. If you should have any questions or concerns
regarding this report, please contact this Office at [phone].
Sincerely,
Steve W. Tedder
Water Quality Supervisor
Cc: Mr. Bill Mesar and Mr. Charley Herron (Brenntag Southeast, Inc., 2 HCI Boulevard, G'boro, NC 27409)
Mr. David Twamley, LG (Arcadis, 801 Corporate Center Drive, Suite 300, Raleigh, NC 27607)
Central Files
$sfl

Form Approved
r^A�,
9
OMB No.2040-0057
Approval Expires
8-31-98
United States Environmental Protection Agency, Washington, D.C. 20460
Section A: National Data System Coding
Transaction Code NPDES No.
Yr/Mo/Day Inspection Type Inspector
FacilityType
N 5 NCO078000
10-04-09 C S
2
Facility Evaluation Rating
BI QA ..........Reserved...........
4
N N
Section B: Facility Data
Name and Location of Facility Inspected:
Entry Time:
Permit Effective
Brenntag Southeast, Inc.
0955 hrs.
Date: July 1, 2006
Located at HCI Boulevard in Greensboro NC.
Exit Time:
Permit Expiration
1035 hrs. I
Date: May 31, 2011
Name(s) of On -Site Representative(s):
Title(s): Phone No(s):
Mr. Bill Mesar
ORC 336-292-5166
Mr. Charley Herron
Back-up ORD 336-851-6833
Mr. David Twamley
ARCADIS 919-854-1282
'Mr. Bruce D. Biehl
Title: Director of Engineering
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
Phone No.
Contacted? No
Section C: Areas Evaluated During Inspection (check only those areas evaluated)
X Permit X
Flow Measurement X Operations/Maintenance NA
Sewer Overflow
X Records/Reports X
Self -Monitoring Program NA Sludge Handling/Disposal _
Pollution Prevention
X Facility Site Review NA
Compliance Schedules NA Pretreatment
X Effluent/Receiving Waters NA
Laboratory Stormwater
Section D: Summary of Findings/Comments
See attached letter for further details regarding the subject inspection.
Name(s and Signature(s) of Inspectors:
Agency/Office/Telephone:
Date:
DWQ / WSRO / [phone]
Signature of viewer:
Agency/Office:
Date:
DWQ / WSRO / [phone]
rj1,2- '_ / 0

2
Permit: NCO078000
Inspection Date: 04/09/2010
Owner - Facility: Brenntag / Greensboro remediation
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ n n n
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge n n ■ n
Judge, and other that are applicable?
Comment:
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
❑
Cl
■
❑
Is the facility as described in the permit?
■
n
n
n
# Are there any special conditions for the permit?
❑
n
■
n
Is access to the plant site restricted to the general public?
■
❑
n
El
Is the inspector granted access to all areas for inspection?
■
n
n
n
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
Is -all required information readily available, complete and current?
■
n
n
❑.
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
n
n
n
Are analytical results consistent with data reported on DMRs?
■
n
n
n
Is the chain -of -custody complete?
■
n
n
n
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
n
n
n
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
■
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
❑
n
■
❑
Is the ORC visitation log available and current?
■
n
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
❑
Is a copy of the current NPDES permit available on site?
■
❑
n
❑
Page # 3

Permit: NC0078000 Owner - Facility: Brenntag / Greensboro remediation
Inspection Date: 04/09/2010 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Facility has copy of previous year's Annual Report on file for review?
❑
Cl
■
❑
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
■
❑
❑
❑
Is flow meter calibrated annually?
■
❑
❑
❑
Is the flow meter operational?
■
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
❑
❑
■
❑
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
❑
■
❑
Is sample collected below all treatment units?
■
❑
❑
❑
Is proper volume collected?
■
❑
❑
❑
Is the tubing clean?
Cl
❑
■
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees Celsius)?
■
❑
Cl
❑
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
❑
❑
❑
Comment:
Page # 4

r OF W ATF
7
Mr. Bruce D. Biehl, Director of Engineering
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
SUBJECT: Compliance Evaluation Inspection
Brenntag Southeast, Inc.
NPDES Permit No. NCO078000
Guilford County
Dear Mr. Biehl:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
30 January 2008
Coleen H. Sullins, Director
Division of Water Quality
A Compliance Evaluation Inspection was performed on Brenntag Southeast, Inc. wastewater treatment facility on January
30, 2008 by Corey Basinger of the Winston-Salem Regional Office. Mr. Herman Dixon, ORC was present for the subject
inspection. The inspection consisted of two parts: an on -site inspection of the treatment facility and an in -office file
review. The following are the findings from the subject inspection.
I. Permit
The NPDES permit for Brenntag Southeast, Inc. became effective on July 1, 2006 and expires on May 31, 2011.
II. Records/Reports
A review of the laboratory reports and Discharge Monitoring Reports (DMRs) revealed no discrepancy between the
generated data and the data submitted to DWQ. A copy of the laboratory data is kept on file. All applicable data is
collected as per the NPDES permit requirements.
III. Facility Site Review
The permit states that the treatment works consist of a groundwater remediation system with extraction wells, surge tank,
in -line strainer, a 2-stage air stripper and discharge to an unnamed tributary to South Buffalo Creek.
IV. Effluent & Receiving Waters
The Brenntag Southeast, Inc. discharges to an unnamed tributary to South Buffalo Creek (Class C NSW waters in the Cape
Fear River Basin). On the date of the inspection, the stream was free of solids, grease, and foam. The discharge location
was confirmed with via GPS with the following coordinates: 36°03'52"N and 79°52'38"W.
V. Flow Measurement
Flow is measured utilizing meter readings from extraction wells. An ultrasonic flow measurement device is also utilized.
VI. Self -Monitoring Program
A review of the discharge monitoring reports (DMRs) for the time period of January 2007 through December 2007 showed
that Brenntag Southeast, Inc. experienced no permit effluent limitation violations.
VII. Compliance Schedules
No compliance schedule to evaluate.
VIII. Laboratory
All of the samples are taken to a contract lab (Pace Analytical) for analysis.
NonrthCarolina
Naturally
North Carolina Division of Water Quality 585 Waughtown Street Phone [phone] Customer Service
Winston-Salem Regional Office Winston-Salem, NC 27107 Fax [phone]
Internet: www.ncwaterquality.org
An Equal Opportunity/Affirmative Action Employer— 50% Recycledl10% Post Consumer Paper

I
IX. Operations and Maintenance
No problems noted with respect to operation. Maintenance is performed as needed.
X. Sludge Utilization/Disposal, Pretreatment, Pollution Prevention, and Multimedia
Not applicable for this inspection.
XI. Stormwater
Not evaluated during this inspection.
XII. Sewer Overflow
None to report.
XIII. Other
None.
Previous inspection was conducted by Corey Basinger on February 28, 2007. If you should have any questions or concerns
regarding this report, please contact this Office at [phone]. -
Sincerely,
Steve W. Tedder
Water Quality Supervisor
Cc: Mr. Herman Dixon (Brenntag Southeast, Inc., 2 HCI Boulevard, G'boro, NC 27409)
Mr. James E. Shilliday, III (Arcadis, 801 Corporate Center Drive, Suite 300, Raleigh, NC 27607)
Central Files
W��'T+

Form Approved
OMB vo.2040-0057
Approval Expires
8-31-98
United States Environmental Protection Agency- Washington- D.C.. 20460
Section A: National Data System Coding
Transaction Code NPDES No. Yr/1tilo/Day Inspection Type Inspector FacilityType
N 5 NCO078000 08-01-30 C S 2
Facility Evaluation Rating BI QA ..........Reserved...........
4 N N
Section B: Facility Data
Name and Location of Facility Inspected:
Entry Time:
Permit Effective
Brenntag Southeast, Inc.
0950 Ins.
Date: July 1, 2006
Located at HCI Boulevard in Greensboro NC.
Exit Time:
Permit Expiration
1050 firs.
Date: May 31, 2011
Name(s) of On -Site Representative(s): Title(s): Phone No(s):
Mr. Heenan Dixon ORC 336-210-0162
Name, Address of Responsible Official:
Title: Director of Engineering
Mr. Bruce D. Biehl
Phone No.
Contacted. No
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
Section C: Areas Evaluated During Inspection (check only those areas evaluated)
X Permit X Flow Measurement X Operations/Maintenance NA Sewer Overflow
X Records/Reports X Self -Monitoring Program NA Sludge Handling/Disposal _ Pollution Prevention
X Facility Site Review NA Compliance Schedules NA Pretreatment
X Effluent/Receiving Waters NA Laboratory Stormwater
Section D: Summary of Findings/Comments
See attached letter for further details regarding the subject inspection.
Name( ) and Signature(s) of Inspectors:
Agency/Office/Telephone:
Date:
DWQ / WSRO / [phone]
�P Jd�
Signature of Re fewer:
Agency/Office:
Date:
DWQ / WSRO / [phone]
d.
¢v

:V
Permit: NCO078000
Inspection Date: 01/30/2008
Owner - Facility: Brenntag / Greensboro remediation
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? ■ D f 1 D
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ ❑ ■ D
Judge, and other that are applicable?
Comment:
V.. Mn Ne NF
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
n
n
■
n
Is the facility as described in the permit?
■
n
n
n
# Are there any special conditions for the permit?
D
D
■
n
Is access to the plant site restricted to the general public?
■
n
n
n
Is the inspector granted access to all areas for inspection?
®
n
n
n
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
®n
n
n
Is all required information readily available, complete and current?
■
n
n
n
Are all records maintained for 3 years (lab. reg. required 5 years)?
®n
n
n
Are analytical results consistent with data reported on DMRs?
❑
n
Is the chain -of -custody complete?
®
n
n
n
Dates, times and location of sampling
Name of individual performing the sampling
Results of analysis and calibration
Dates of analysis
Name of person performing analyses
Transported COCs
Are DMRs complete: do they include all permit parameters?
■
n
n
n
Has the facility submitted its annual compliance report to users and DWQ?
n
❑
■
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
n
D
■
D
Is the ORC visitation log available and current?
®n
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
tan
n
n
is the backup operator certified at one grade less or greater than the facility classification?
®n
n
n
Is a copy of the current NPDES permit available on site?
®
n
n
n
Page # 3

a
Permit: NCO078000 Owner - Facility: Brenntag / Greensboro remediation
Inspection Date: 01/30/2008 Inspection Type: Compliance Evaluation
Record Keeping
Yes
No
NA
NE
Facility has copy of previous year's Annual Report on file for review?
❑
❑
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
# Is flow meter used for reporting?
®n
n
n
Is flow meter calibrated annually?
fl
Is the flow meter operational?
❑
❑
❑
(If units are separated) Does the chart recorder match the flow meter?
n
n
®
❑
Comment:
Effluent Sampling
Yes
No
NA
NE
Is composite sampling flow proportional?
❑
❑
®
0
Is sample collected below all treatment units?
❑
❑
Is proper volume collected?
®n
n
n
Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
n
n
n
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
n
n
n
Comment:
Page # 4

o�OF W ATF9pG
r
> y
d �
Mr. Bruce D. Biehl, Director of Engineering
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NO 27703
SUBJECT: Compliance Evaluation Inspection
Brenntag Southeast, Inc.
NPDES Permit No. NCO078000
Guilford County
Dear Mr. Biehl:
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
6 March 2007
Alan W. Klimek, P.E. Director
Division of Water Quality
A Compliance Evaluation Inspection was performed on Brenntag Southeast, Inc. wastewater treatment facility on February
28, 2007 by Corey Basinger of the Winston-Salem Regional Office. Mr. Herman Dixon, ORC and Mr. Chris Kalinowski
(Arcadis Contultant) were present for the subject inspection. The inspection consisted of two parts: an on -site inspection
of the treatment facility and'an in -office file review. The following are the findings from the subject inspection.
I. Permit
The NPDES permit for Brenntag Southeast, Inc. became effective on July 1, 2006 and expires on May 31, 2011.
II. Records/Reports
A review of the laboratory reports and Discharge Monitoring Reports (DMRs) revealed no discrepancy between the
generated data and the data submitted to DWQ. A copy of the laboratory data is kept on file. All applicable data is
collected as per the NPDES permit requirements.
IIl: Facility Site Review
The permit states that the treatment works consist of a groundwater remediation system with extraction. wells, surge tank,
in -line strainer, a 2-stage air stripper and discharge to an unnamed tributary to South Buffalo Creek.
IV. Effluent & Receiving Waters
The Brenntag Southeast, Inc. discharges to an unnamed tributary to South Buffalo Creek (Class C NSW waters in the Cape
Fear River Basin). On the date of the inspection, the stream was free of solids, grease, and foam. The discharge location
was confirmed with via GPS with the following coordinates: 36°03'52"N and 79°52'38"W.
V. Flow Measurement
Flow is measured utilizing meter readings from extraction wells. An ultrasonic flow measurement device is also utilized..
VI. Self -Monitoring Program
A review of the discharge monitoring reports (DMRs) for the time period of January 2006 through December 2006 showed
that Brenntag Southeast, Inc. experienced no permit effluent limitation violations.
VII. Compliance Schedules
No compliance schedule to evaluate.
VIII. Laboratory
All of the samples are taken to a contract lab (Pace Analytical) for analysis.
Nof` Carolina
;atundl.ff
North Carolina Division of Water Quality 585 Waughtown Street Phone [phone] Customer Service
Winston-Salem Regional Office Winston-Salem, NC 27107 Fax [phone]
Internet: www.ncwaterquality.org
An Equal Opportunity/Affirmative Action Employer— 50% Recycled/10% Post Consumer Paper

IX. Operations and Maintenance
No problems noted with respect to operation. Maintenance is performed as needed.
X. Sludge Utilization/Disposal Pretreatment, Pollution Prevention, and Multimedia
Not applicable for this inspection.
XI. Stormwater
Not evaluated during this inspection.
XII. Sewer Overflow
None to report.
XIII. Other
None.
Previous inspection was conducted by Corey Basinger on August 3, 2005. If you should have any questions or concerns
regarding this report, please contact this Office at [phone].
Sincerely,
6 -
Steve W. Tedder
Water Quality Supervisor
Cc: Mr, Herman Dixon (Brenntag Southeast, Inc., 2 HCI Boulevard, G'boro, NC 27409)
Mr. James E. Shilliday, III (Arcadis, 801 Corporate Center Drive, Suite 300, Raleigh, NC 27607)
Central Files
ti rS' W11

Form Approved
OMB No. 2040-0057
A
.°
Approval Expires
8-31-98
United States Environmental Protection ALYencv. Washineton. D.C.. 20460
Section A: National Data System Coding
Transaction Code NPDES No. Yr/Mo/Day Inspection Type_ Inspector FacilityType
N _5 , NCO078000 07-02-28 C S 2
Facility Evaluation Rating BI QA ..........Reserved...........
4 N N
Section B: Facility Data
Name and -Location of Facility Inspected:
Entry Time:
Permit Effective
Brenntag Southeast, Inc.
0930 hrs.
Date: July 1, 2006
Located at HCI Boulevard in Greensboro NC.
Exit Time:
Permit Expiration
1035 hrs.
Date: May 31, 2011
Name(s) of On -Site Representative(s): Title(s): Phone No(s):
Mr. Herman Dixon ORC 336-210-0162
Mr. Chris Kalinowski Arcadis Consultant 919-854-1282
Name, Address of Responsible Official:
Title: Director of Engineering
Mr. Bruce D. Biehl
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Phone No.
Contacted? No
Durham, NC 27703
Section C: Areas Evaluated During Inspection (check only those areas evaluated)
X Permit X Flow Measurement X Operations/Maintenance NA Sewer Overflow
X Records/Reports X 'Self -Monitoring Program NA Sludge Handling/Disposal _ Pollution Prevention
X Facility Site Review NA Compliance Schedules NA Pretreatment
X Effluent/Receiving Waters NA . Laboratory Stormwater
Section D:_ Summary of Findings/Comments..
See attached letter for further details regarding the subject inspection.
Names) and Signatures) gfInspectors:
Agency/Office/Telephone:
Date:
DWQ / WSRO / [phone]j�.
Signature of Reviewer:
Agency/Office:
Date:
DWQ / WSRO./ [phone]
2 �7

Permit: NCO078000
Inspection Date: 02/28/2006
Owner - Facility: Brenntag / Greensboro remediation
Inspection Type: Compliance Evaluation
Operations & Maintenance Yes No NA NE.
Is the plant generally clean with acceptable housekeeping? ■ rl ❑ fl
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable Solids, pH, DO, Sludge ❑ ❑ ■
Judge, and other that are applicable?
Comment:
Yes No NA NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new application?
n
n ■
n
Is the facility as described in the permit?
■
rl
n
rl
# Are there any special conditions for the permit?
❑
❑
■
fl
Is access to the plant site restricted to the general public?
■
❑
❑
f_I
Is the inspector granted access to all areas for inspection?
■
rl
❑
rl
Comment:
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
■
El
0
n
Is all required information readily available, complete and current?
■
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
■
❑
❑
Are analytical results consistent with data reported on DMRs?
■
❑
n
Is the chain -of -custody complete?
■
fl
❑
Dates, times and location of sampling
■
Name of individual performing the sampling
■
Results of analysis and calibration
■
Dates of analysis
■
Name of person performing analyses
■
Transported COCs
■
Are DMRs complete: do they include all permit parameters?
■
❑
rl
rl
Has the facility submitted its annual compliance report to users and DWQ?
n
n
■
n
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operator on each shift?
n
n
■
Is the ORC visitation log available and current?
■
n
n
n
Is the ORC certified at grade equal to or higher than the facility classification?
■
n
n
n
Is the backup operator certified at one grade less or greater than the facility classification?
■
n
n
n
Is a copy of the current NPDES permit available on site?
■
n
n
n
Page # 3

Permit: NCO078000 owner - Facility: Brenntag / Greensboro remediation
Inspection Date: 02/28/2006 Inspection Type: Compliance Evaluation
Yes No
NA
NE
Record Keeping
Facility has copy of previous year's Annual Report on file for review?
nn■•n
Comment:
Yes
No
NA
NE
Effluent Pipe
■•n
n
n
Is right of way to the outfall properly maintained?
Are the receiving water free of foam other than trace amounts and other debris?
■nnn
If effluent (diffuser pipes are required) are the operating proerl ?
n
n
■
n
Comment:
Flow Measurement - Effluent
Yes
No
NA
NE
nnn
# Is flow meter used for reporting?
■
❑
❑
n
Is flow meter calibrated annually?
■nnn
Is the flow meter operational? •
(If units are separated). Does the chart recorder match the flow meter?
El
Comment:
Comment:
Yes
No
NA
NE
Effluent Sampling
Is composite sampling flow proportional?
❑
n
■
❑
■nnn
Is sample collected below all treatment units?
•
■nnn
Is proper volume collected?
❑
❑
■
Is the tubing clean?
Is proper temperature set for sample storage (kept at 1.0 to 4.4 degrees Celsius)?
■
❑
rl
fl
Is the facility sampling performed as required by the permit (frequency, sampling type representative)?
■
nnn
Comment:
Page # 4

North Carolina Department of Environment and Natural Resources
Division of Water Quality
Michael F. Easley, Governor William G. Ross, Jr., Secretary
Coleen H. Sullins, Director
October 4, 2007
CERTIFIED MAIL - RETURN RECEIPT REQUESTED
Mr. Bruce D. Biehl
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, NC 27703
SUBJECT:
Dear Mr. Biehl:
RECEIVED
1' Dept. of ENR
OCT t 120(y
t,:nston-Salem
Regional office
Final Notice - Delinquent Annual Fee
NPDES Permit NCO078000
Guilford County
All NPDES permittees must pay an Annual Compliance Monitoring Fee. This requirement is documented in
your current permit at Part II. B. 14. The 2007 fee for your company's Greensboro remediation site has not
been paid. The total amount owed is $715.00; a copy of the invoice previously sent to you is attached.
Failure to pay the annual fee is grounds for revocation of your permit, as documented in part II.
B. 13 and II. B. 14. This letter serves as final notice that the Division will refer the fees noted
above to the North Carolina Attorney General's Office for collection through the courts unless
payment in the amount of $715.00 is received by November 2, 2007.
Make checks payable to NC DENR; include the permit numbers and invoice numbers on the check. Send the
feepayment to:
Fran McPherson
Annual Administering and Compliance Fee Coordinator
1617 Mail Service Center
Raleigh, NC 27699-1617
If you have evidence that the fee has already been paid, please contact Mrs. McPherson at 919 733-5083,
extension 210. <
Sincerely,
Charles H. Weaver, Jr.
NPDES Unit
cc: Central Files
Win 'ston�Sal"em:Regonal; Office./Corey Basinger
NPDES file
1617 Mail Service Center, Raleigh, North Carolina 27699-1.617
One
512 North Salisbury Street, Raleigh, North Carolina 27604
Nol'tolina
Phone: [phone] / FAX [phone] / Internet; www.ncwaterquality.org hC
An Equal Opportunity/Affirmative Action Employer — 50% Recycled/10% Post Consumer Paper ;Uffimliff

Tributary A of
South Buffaloe Creek
B-49 a B-51
+
AREA B 50 ( I
OF I 'I
-- —__ --__ CONCERN
a
0
m /co
a
B-21� —SWMU #6
0 ,e
B-20
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i
o
I ,
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# I—SWMU#3 `;`x�x�x ` B-�14X B-36—BY3�-b-35x—X—X—
ii Spill
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:>:% 1' Basin
New
Diked AST $ B-11 i
:.>:.: Area
B-31 B-12 a B-34 /
+ B-33
.>' M B-30 • B-1 EW-2 El
2 _ B 6
POC-1s /.;';� +B-39
Closed Surface B-38
Impoundment (: Treatment o
-3 POC-1 (Abandoned) B 32 o r i System B-40
NPDES
\ /POC-2d EW-1 1 B 7II Discharge
o B-25 ' , Point
B-2 ° POC-2s B-10 RAS \,\
Building
B-23 B 8�
B-41�B-2
V.Allen
—� MW-1
0
H.V Allf
MW-4
B-53
GAA
M W-8s
Greensboro Auto -
Auction Shop
Tributary A of
South Buffaloe Creek
Underground in (Culvert
i
B-43 �44
B-45
B-26 + B-29
B-27 + B-28
Guilford Mills, Inc.
X X _ X _ X X X X - X X _ X
Greensboro
Auto Auction
Center
LEGEND
BUILDINGS/STRUCTURES
— RAILROAD TRACKS
—X—X— FENCE
---- PROPERTY LINE
— — — CREEK
CULVERTED SECTION OF
CREEK
AREA OF CONCERN
SWMU LOCATION
o SAPROLITE MONITOR WELL
+ FRACTURED BEDROCK
MONITOR WELL
p COMPETENT BEDROCK
MONITOR WELL
® EXTRACTION WELL
SCALE IN FEET
0 160 320
PRJT MANAGER,
CHECKED BY-
DRAFTER,
PROJECT NUMBER,
NC102030,0003
FIGURE:
C�
J. SHILLIDAY
P. BRADLEY
A, NORTON
s.
RR)i'C� AN D
NOTES:
DRAWING,
SITE
1. Bullding Locations & Well Locations are. based
on site map provided by Duncklee & Dunham
BRENNTAG SOUTHEAST, INC.
q
ARCADIS G&M of North Carolina, Inc.
801 Corporate Center Drive, Suite 300
P.C. May 2002,
BSE-GNC4-03
GREENSBORO, NORTH CAROLINA
LAYOUT
I —�
Raleigh, NC 27607
Tel: [phone] Fax: [phone]
DATE-
www.orcodis-us.com
29MAY03