NC0078000_Draft Permit_20210727

ROY COOPER
Governor
ELIZABETH S. BISER
Secretary
S. DANIEL SMITH
Director
David Grenoble, District Manager
Brenntag Mid -South, Inc.
2000 East Pettigrew Street
Durham, NC 27703
Dear Permittee:
NORTH CAROLINA
Environmental Quality
July 27, 2021
Subject: Draft NPDES Permit NC0078000
Greensboro Groundwater Remediation Site
Grade I Physical Chemical WPCS
Guilford County
The Division has reviewed your request to renew the subject permit. Please review this draft carefully to
ensure your thorough understanding of the information, conditions, and requirements it contains.
The draft permit includes the following significant changes from the existing permit:
1. Language has been updated in Section A. (1) and Section A. (3) to require electronic submission
of effluent data. Federal regulations require electronic submittal of all discharge monitoring
reports (DMRs).
2. Outfall map has been updated.
3. The facility grade has been added in Section A. (1).
4. Monitoring for 1,4-dioxane has been added in Section A. (1) per a letter from the Division dated
October 12, 2020.
5. Toxicity language in Section A. (2) has been updated.
Please note that the receiving stream is listed as impaired for fish community and benthos on the North
Carolina 2018 303(d) Impaired Waters List. Addressing impaired waters is a high priority with the
Division, and instream data will continue to be evaluated. If there is noncompliance with permitted
effluent limits and stream impairment can be attributed to your facility, then mitigative measures may be
required.
The NPDES standard conditions (Parts II, III, and IV) that are a part of the permit are not included in
this draft document (cover, map, and Part I). The conditions are the same as in your current permit
except that agency and division names have been updated. The latest version is available
at https://bit.ly/3k5NFaL and can be viewed online or downloaded as a PDF file.
With this notification, the Division will solicit public comment on this draft permit by publishing a
notice in newspapers having circulation in the general Guilford County area, per EPA requirements.
Please provide your comments, if any, to me no later than 30 days after receiving this draft
permit.
1:1.E
NORTH CAROLINA
Department of Environmental Dualiit
North Carolina Department of Environmental Quality I Division of Water Resources
512 North Salisbury Street 11617 Mail Service Center I Raleigh, North Carolina 27699-1617
919.707.9000

Following the 30-day public comment period, the Division will review all pertinent comments and take
appropriate action prior to issuing a final permit. If you have questions concerning the draft, please
contact me at 919-707-3619, or via e-mail [[e-mail]].
Sincerely,
Brianna Young
NPDES ComplianceExpedited Permitting Unit
cc: NPDES Files (Laserfiche)
Winston-Salem Regional Office
Wastewater Operator Certification Group
WSS/Aquatic Toxicology Branch
DWR/Public Water Supply
James Shilliday, ARCADIS

Permit NC0078000
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF WATER RESOURCES
PERMIT
TO DISCHARGE WASTEWATER UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
(NPDES)
In compliance with the provisions of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Water Quality
Commission, and the Federal Water Pollution Control Act, as amended,
Brenntag Mid -South, Inc.
is hereby authorized to discharge wastewater from a facility located at
Brenntag Greensboro Groundwater Remediation
2 HCI Boulevard
Greensboro
Guilford County
to receiving waters designated as an unnamed tributary to South Buffalo Creek in the Cape Fear
River Basin in accordance with the discharge limitations, monitoring requirements, and other
conditions set forth in Parts I, II, III, and IV hereof.
This permit shall become effective
This permit and the authorization to discharge shall expire at midnight on May 31, 2026.
Signed this day
S. Daniel Smith
Director, Division of Water Resources
By the Authority of the Environmental Management Commission
Page 1 of 7

Permit NC0078000
SUPPLEMENT TO PERMIT COVER SHEET
All previous NPDES Permits issued to this facility, whether for operation or discharge are hereby
revoked. As of this permit issuance, any previously issued permit bearing this number is no longer
effective. Therefore, the exclusive authority to operate and discharge from this facility arises under
the permit conditions, requirements, terms, and provisions included herein.
Brenntag Mid -South, Inc.
is hereby authorized to:
1. Continue to operate facilities to treat a discharge from a groundwater-remediation system for
chlorinated and non -chlorinated solvents. Treatment components consists of:
• Extraction wells
• Surge tank
• In -line strainer
• 2-stage air stripper
This facility is located at 2 HCI Boulevard in Greensboro in Guilford County.
2. Discharge from said treatment works via Outfall 001 at the location specified on the attached
map, into an unnamed tributary (UT) to South Buffalo Creek [Stream segment: 16-11-14-2], a
waterbody currently classified WS-V; NSW within subbasin 03-06-02 [HUC: 030300020104]
of the Cape Fear River Basin.
Page 2 of 7

Permit NC0078000
PART I.
A. (1) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[NCAC 02B.0400 et seq., 02B.0500 et seq.]
[Grade I Physical Chemical WPCS [15A NCAC 08G .0302]]
During the period beginning on the effective date of the permit and lasting until expiration, the
Permittee is authorized to discharge treated, remediated groundwater via Outfall 001. Such
discharges shall be limited, monitored and reported' by the Permittee as specified below:
EFFLUENT CHARACTERISTICS
Parameter Codes
LIMITS
MONITORING REQUIREMENTS
Monthly
Average
Daily
Maximum
Measurement
Frequency
Sample Type
Sample
Location
Flow 50050
0.216 MGD
Continuous
RecordingInfluent
or
Effluent
pH 00400
Not < 6.0 nor > 9.0 s. u.
Monthly
Grab
Effluent
1,4-dioxane 82388
Monthly
Grab
Effluent
Toluene 2 34010
Quarterly
Grab
Effluent
Benzene 2 34030
Quarterly
Grab
Effluent
Trans-1,2-Dichloroethene 2 34546
Quarterly
Grab
Effluent
Trichloroethene 2 78391
Quarterly
Grab
Effluent
Whole Effluent Toxicity TGP3B
Test 3 THP3B
QuarterlyGrab
Effluent
Footnotes:
1. The permittee shall submit discharge monitoring reports electronically using the NC DWR's eDMR
application system [see Section A. (3)].
2. Sample shall be collected concurrently with toxicity sampling.
3. Chronic WET test (Ceriodaphnia dubia) Pass/Fail at 90% collected during the months of January,
April, July, and October [see Section A. (2)].
The Permittee shall discharge no floating solids or foam visible in more than trace amounts.
Page 3 of 7

Permit NC0078000
A. (2) CHRONIC TOXICITY PERMIT LIMIT (QUARTERLY)
[15A NCAC 02B .0200 et seq.]
The effluent discharge shall at no time exhibit observable inhibition of reproduction or significant
mortality to Ceriodaphnia dubia at an effluent concentration of 90 %.
The permit holder shall perform at a minimum, quarterly monitoring using test procedures outlined
in the "North Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," (Revised December
2010, or subsequent versions) or "North Carolina Phase II Chronic Whole Effluent Toxicity Test
Procedure" (Revised December 2010, or subsequent versions). The tests will be performed during
the months of January, April, July, and October. These months signify the first month of each
three-month toxicity testing quarter assigned to the facility. Effluent sampling for this testing must
be obtained during representative effluent discharge and shall be performed at the NPDES permitted
final effluent discharge below all treatment processes.
If the test procedure performed as the first test of any single quarter results in a failure or
ChV below the permit limit, then multiple -concentration testing shall be performed at a
minimum, in each of the two following months as described in "North Carolina Phase II
Chronic Whole Effluent Toxicity Test Procedure" (Revised -December 2010, or subsequent
versions).
All toxicity testing results required as part of this permit condition will be entered on the Effluent
Discharge Monitoring Form (MR-1) for the months in which tests were performed, using the
parameter code TGP3B for the pass/fail results and THP3B for the Chronic Value. Additionally,
DWR Form AT-3 (original) is to be sent to the following address:
North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1621 Mail Service Center
Raleigh, NC 27699-1621
Or, results can be sent to the email, ATForms.ATB(a,ncdenr.gov.
Completed Aquatic Toxicity Test Forms shall be filed with the Water Sciences Section no later than
30 days after the end of the reporting period for which the report is made.
Test data shall be complete, accurate, include all supporting chemical/physical measurements and
all concentration/response data, and be certified by laboratory supervisor and ORC or approved
designate signature. Total residual chlorine of the effluent toxicity sample must be measured and
reported if chlorine is employed for disinfection of the waste stream.
Should there be no discharge of flow from the facility during a month in which toxicity monitoring
is required, the permittee will complete the information located at the top of the aquatic toxicity
(AT) test form indicating the facility name, permit number, pipe number, county, and the
month/year of the report with the notation of "No Flow" in the comment area of the form. The
report shall be submitted to the Water Sciences Section at the address cited above.
Should the permittee fail to monitor during a month in which toxicity monitoring is required,
monitoring will be required during the following month. Assessment of toxicity compliance is
Page 4 of 7

Permit NC0078000
based on the toxicity testing quarter, which is the three-month time interval that begins on the first
day of the month in which toxicity testing is required by this permit and continues until the final day
of the third month.
Should any test data from this monitoring requirement or tests performed by the North Carolina
Division of Water Resources indicate potential impacts to the receiving stream, this permit may be
re -opened and modified to include alternate monitoring requirements or limits.
NOTE: Failure to achieve test conditions as specified in the cited document, such as minimum
control organism survival, minimum control organism reproduction, and appropriate environmental
controls, shall constitute an invalid test and will require immediate follow-up testing to be
completed no later than the last day of the month following the month of the initial monitoring.
A. (3) ELECTRONIC REPORTING - DISCHARGE MONITORING REPORTS
[G.S. 143-215.1 (b)]
Federal regulations require electronic submittal of all discharge monitoring reports (DMRs) and
program reports. The final NPDES Electronic Reporting Rule was adopted and became effective on
December 21, 2015.
NOTE: This special condition supplements or supersedes the following sections within Part II of
this permit (Standard Conditions for NPDES Permits):
• Section B. (11.) Signatory Requirements
• Section D. (2.) Reporting
• Section D. (6.) Records Retention
• Section E. (5.) Monitoring Reports
1. Reporting Requirements [Supersedes Section D. (2.) and Section E. (5.) (a)1
The permittee shall report discharge monitoring data electronically using the NC DWR's
Electronic Discharge Monitoring Report (eDMR) internet application.
Monitoring results obtained during the previous month(s) shall be summarized for each month
and submitted electronically using eDMR. The eDMR system allows permitted facilities to
enter monitoring data and submit DMRs electronically using the internet. The eDMR system
may be accessed at: https://deq.nc.gov/about/divisions/water-resources/edmr.
If a permittee is unable to use the eDMR system due to a demonstrated hardship or due to the
facility being physically located in an area where less than 10 percent of the households have
broadband access, then a temporary waiver from the NPDES electronic reporting requirements
may be granted and discharge monitoring data may be submitted on paper DMR forms (MR 1,
1.1, 2, 3) or alternative forms approved by the Director. Duplicate signed copies shall be
submitted to the following address:
NC DEQ / Division of Water Resources / Water Quality Permitting Section
ATTENTION: Central Files
Page 5 of 7

Permit NC0078000
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
See "How to Request a Waiver from Electronic Reporting" section below.
Regardless of the submission method, the first DMR is due on the last day of the month
following the issuance of the permit or in the case of a new facility, on the last day of the month
following the commencement of discharge.
Starting on December 21, 2025, the permittee must electronically report the following
compliance monitoring data and reports, when applicable:
• Sewer Overflow/Bypass Event Reports;
• Pretreatment Program Annual Reports; and
• Clean Water Act (CWA) Section 316(b) Annual Reports.
The permittee may seek an electronic reporting waiver from the Division (see "How to Request
a Waiver from Electronic Reporting" section below).
2. Electronic Submissions
In accordance with 40 CFR 122.41(1)(9), the permittee must identify the initial recipient at the
time of each electronic submission. The permittee should use the EPA's website resources to
identify the initial recipient for the electronic submission.
Initial recipient of electronic NPDES information from NPDES-regulated facilities means the
entity (EPA or the state authorized by EPA to implement the NPDES program) that is the
designated entity for receiving electronic NPDES data [see 40 CFR 127.2(b)].
EPA plans to establish a website that will also link to the appropriate electronic reporting tool
for each type of electronic submission and for each state. Instructions on how to access and use
the appropriate electronic reporting tool will be available as well. Information on EPA's
NPDES Electronic Reporting Rule is found at:
https://www.federalregister.gov/documents/2015/ 10/22/2015-24954/national-pollutant-
discharge-elimination-system-npdes-electronic-reporting-rule
Electronic submissions must start by the dates listed in the "Reporting Requirements" section
above.
3. How to Request a Waiver from Electronic Reporting
The permittee may seek a temporary electronic reporting waiver from the Division. To obtain
an electronic reporting waiver, a permittee must first submit an electronic reporting waiver
request to the Division. Requests for temporary electronic reporting waivers must be submitted
in writing to the Division for written approval at least sixty (60) days prior to the date the
facility would be required under this permit to begin submitting monitoring data and reports.
Page 6 of 7

Permit NC0078000
The duration of a temporary waiver shall not exceed 5 years and shall thereupon expire. At
such time, monitoring data and reports shall be submitted electronically to the Division unless
the permittee re -applies for and is granted a new temporary electronic reporting waiver by the
Division. Approved electronic reporting waivers are not transferrable. Only permittees with an
approved reporting waiver request may submit monitoring data and reports on paper to the
Division for the period that the approved reporting waiver request is effective.
Information on eDMR and the application for a temporary electronic reporting waiver are found
on the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
4. Signatory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.)
All eDMRs submitted to the permit issuing authority shall be signed by a person described in
Part II, Section B. (11.)(a) or by a duly authorized representative of that person as described in
Part II, Section B. (11.)(b). A person, and not a position, must be delegated signatory authority
for eDMR reporting purposes.
For eDMR submissions, the person signing and submitting the DMR must obtain an eDMR user
account and login credentials to access the eDMR system. For more information on North
Carolina's eDMR system, registering for eDMR and obtaining an eDMR user account, please
visit the following web page:
http://deq.nc.gov/about/divisions/water-resources/edmr
Certification. Any person submitting an electronic DMR using the state's eDMR system shall
make the following certification [40 CFR 122.22]. NO OTHER STATEMENTS OF
CERTIFICATION WILL BE ACCEPTED:
"I certify, under penalty of law, that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my inquiry of the person or
persons who manage 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."
5. Records Retention [Supplements Section D. (6.)1
The permittee shall retain records of all Discharge Monitoring Reports, including eDMR
submissions. These records or copies shall be maintained for a period of at least 3 years from
the date of the report. This period may be extended by request of the Director at any time [40
CFR 122.41].
Page 7 of 7

Cop.yright:i0:2013 NatiErTd1 G'eo.graphic-Societyl
Brenntag Mid -South, Inc.
Brenntag Greensboro Groundwater Remediation
NPDES Permit NC0078000