NC0078000_Permit Modification_19900312

0
MAR 2 1 1990..
State of North Carolina T� t iY "�`'- 4 " BRANCH
Department of Natural Resources and Community Development
Division of Environmental Management
512 North SalisburyStreet • Raleigh, North Carolin 327611
g
James G. Martin, Governor George T. Everett, Ph. D.
William W. Cobey, Jr., Secretary Director
March 12, 1990
Mr. William H. Cobb
Worth Chemical Corporation
2 Segal Boulevard
Greensboro, NC 27409
Subject: Modification to NPDES
Permit No. NC0078000
Worth Chemical Corporation
Guilford County
Dear Mr. Cobb:
In accordance with one of your requests for permit modification, the Division of
Environmental Management will modify the subject permit. This modification will require the
analytical testing for organics to be performed by Method SW-846 Third Edition 8240 and 8270
rather than the 600 series GC methods. A revised Part III, Condition H will be included in the
subject permit.
Your request to delete the monitoring requirement for dibromoethane (ethylene dibromide
or EDB) is hereby denied since the Division does not have effluent data that indicates that this
requirement is not necessary. If, after twelve months, your effluent data indicates that it is not
necessary to require effluent monitoring for dibromethane, you may again request that the Division
delete this parameter from the subject permit.
Also, oil and grease is a routine monitoring requirement for groundwater remediation
facilities. The Division will not delete the oil and grease effluent limitation at this time but will
consider doing so after data has been collected for one year if you request the Division to do so at
that time. The Division will change the monitoring frequency, however for oil and grease from
twice per month to monthly since the effluent concentration is expected to be much lower than 30.0
mg/1. The effluent page of the subject permit will be revised to reflect this change in the monitoring
frequency for oil and grease.
If this decision is unacceptable to you, you will have the right to an adjudicatory hearing
upon written request within thirty (30) days following receipt of the final permit. The Division is
completing its review of the subject permit, and it is expected to be issued in the near future.
Pollution Prevention Pays
P.O. Box 27687, Raleigh, North Carolina 27611-7687 Telephone [phone]
An Equal Opportunity Affirmative Action Employer

If you have any questions concerning this permit, please contact Mr. Dale Overcash at
telephone number [phone].
Enclosure
cc: Central Files
Winston-Salem Regional Office
Technical Support Branch
Mr. Jim Patrick, EPA

DIVISION OF ENVIRONMENTAL MANAGEMENT
MEMORANDUM
TO: Dale Overcash
THRU: Ruth Swanek 12.C.S
Trevor Clement
FROM:
Mike Scoville ps
March 1,1990
SUBJECT: Comments on Draft permit for Worth Chemical Corporation
(NPDES No. NC0078018, Guilford County)
This memo is in response to Worth Chemical Corporation's requests for
modification of their NPDES draft permit. The recommendations of Technical
Support regarding each of these requests are as follows
1) The effluent monitoring requirement for dibromoethane (ethylene dibro-
mide or EDB) should not be deleted from the list of organic to be monitored
quarterly in the effluent. This compound is an additive for gasoline, and
no data indicate its presence or absence in the effluent. If, after twelve
months, the effluent data indicate this requirement is unnecessary, the
Company can request DEM to reevaluate it at that time.
2) Oil and Grease is a routine monitoring requirement for these types of
discharges. The monitoring frequency may reduced from twice/month to
monthly since the effluent concentration is expected to be much lower than
the 30 mg/1 limit. However, the limit will not be deleted until a year's
worth of effluent data have been collected by the facility and evaluated by
DEM.
3) It is recommended that the analytical testing for organics be performed
by method SW-846 Third Edition 8240 and 8270 rather than the 600 series GC
method proposed in the draft permit. This analytical method is probably
more appropriate for this specific discharge, and will provide consistency
with the data collected by the facility since 1986.
If you have any questions or comments, please feel free to contact me.

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EXECUTIVE OFFICES @ ?LAWT•••vREE17S8 , N.C. mYL.
FE•CEIVED
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`� 0 8 1990
PERMITS & ENGINEERING
INDUSTR:AL
6tAvicah:071/
CHEMICALS SINCE 1930
P.C. BOX 20725 • 2 SEGAL BOULEVARD AT EDWARD:A UR • GREENSBORO NORTH CAROLINA 274120
PHONE. r 919 292-5166
February 6, 1990
Mr. Don Safrit, P. E.
Supervisor of Permits and Engineering
State of North Carolina
Environmental Management Commission
P. O. Box 27687
Raleigh, N. C. 27611-7687
RE: DRAFT PERMIT NO. NC 0078000
Dear Mr. Safrit:
WORTH CHEMICAL CORPORATION has reviewed the draft permit
referenced above and respectfully recuests the following
modifications be made to the proposed permit:
1) Deletion of the requirement for quarterly
sampling and E:ralysis of the effluent for
dibnomoethane (Ethylene Dibror ide or EDB)
from the organics monitoring section.
WORTH CHEMICAL CORPORATION's corrective
action plan is designed to rer-.ediate ground
water contamir..ated by a former surface
impoundment and various solid .taste manage-
ment units. This compound is not among the
list of chlorinated organic compounds being
monitored at the facility. Additionally,
there are no records of this compound being
handled at the facility and no analyses of
the ground water have indicate: its presence.
Accordingly, there does not acpear to be a
need for this requirement.
2) Deletion of the requirement for twice a month
sampling and analysis of the effluent for oil and
grease from the parameter list.
GREENSBORO, N. C.. CHARLOTTE N. C. SPARTA•.BURG :, C. DURHAM, N. C.

Mr. Don Safrit, P. E. February 6, 1990
State of North Carolina Page 2
Based on ground water sampling data and
observations of the ground water waste
stream currently being treated and discharged
via a POTW permit, the contaminants of
concern are dissolved and are not phase
separated as are materials measured by the
oil and grease analysis. Because of the
strict reauirements of the Permit, extensive
treatment will be required of the waste stream.
Therefore, it is unlikely the effluent would
contain oil and grease in the 30 mg/1 range
followinu such treatment. Additionally, the
oil and crease analysis is a "freon extractables"
:;rocedure which does not have the ability to
differentiate between petroleum hydrocarbons,
animal fat, and/or mineral oils, thereby
rendering it useless as a monitoring para-
meter in this case.
3) We request that the analytical testing for organics
be performed by Method SW-846 Third Edition 8240 and
8270 rather than the 600 series GC methods proposed
in the draft permit. �a C,L-
1ft- VA
The SW-846 methods 8240 and 82 ) are GC/MF procedures
which are recognized as more accurate than the 600
series GC methods. By utilizing these methods con-
sistency with the ground water monitoring data
collected since 1986 can be maintained.
WORTH CHEMICAL CORPORATION appreciates the timely response to our
permit application and requests your approval of the modifications
set forth above. If you have any questions, please do not
hesitate to call.
Sincerely,
WORTH CHEMICAL CORPORATION
60-6e) 714
William H. (Billy) Cobb, III
Director of Regulatory Affairs
WH C : j s f
cc: Phil Segal, Jr.
Joel P. Liebling
Cal Lynch
William Naylor
Bruce Dungan