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HomeMy WebLinkAboutNC0078000_Permit Issuance_20161109PAT MCCRORY Governor t (+ Water Resources ENVIRONMENTAL QUALITY November 9, 2016 Bruce Biehl, Director of Regulatory Affairs Brenntag Southeast, Inc. 2000 East Pettigrew Street Durham, North Carolina 27703 Dear Mr. Biehl: DONALD R. VAN DER VAART Sewtoy S. JAY ZIMMERMAN Director Subject: Issuance of NPDES Permit NCO078000 Brenntag Greensboro GW-REM, Class 1 2 HCI Boulevard, Greensboro Guilford County The Division of Water Resources (the Division) hereby issues the attached NPDES permit for the subject facility. We issue this permit pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the U.S. Environmental Protection Agency dated October 15, 2007, or as subsequently amended. Changes for Renewal. The Division understands that you have made no significant changes to your processes since last renewal. We have therefore made only minimal changes to your permit by updating your permit format and site map. However, please note that electronic reporting of Discharge Monitoring Reports (DMRs) is now required. Implementing Electronic Discharge Monitoring Reports (eDMRs). Please be advised that the Division has implemented an electronic Discharge Monitoring Report (eDMR) program, in accord with recently promulgated requirements by the Environmental Protection Agency (EPA). We include the details to implement the eDMR program in this permit [see Section A. (10.)]. Federal regulations require electronic submittal of all DMRs and specify that, if North Carolina does not establish a program to receive such submittals, Permittees must then submit eDMRs directly to EPA. For more information on eDMRs, registering for eDMR submittal, and obtaining an eDMR user account, please visit DWR's webpage: http://portal nedenr or web/wq/admin/bog/ivu/edmr For information on EPA's proposed NPDES Electronic Reporting Rule, please visit EPA's website: htty://www2 gpa gov/co=liance/i)rot)osed-nt)des-electronic-reporting-rule State of North Carolina I Environmental Quality I Water Resources 1611 Mail service Center I Raleigh, North Caroline 27699-1611 919 707 9000 Bruce Biehl Brenntag Southeast, Inc. September 14, 2016 Page 2 If any parts, measurement frequencies, or sampling requirements contained in this permit are unacceptable, you have the right to an adjudicatory hearing, upon written request submitted within thirty (30) days after receiving this letter. Your request must take the form of a written petition conforming to Chapter 150B of the North Carolina General Statutes, and you must file it with the office of Administrative Hearings, 6714 Mail Service Center, Raleigh, North Carolina 27699-6714. Unless such a demand is made, this permit shall be final and binding. This permit is not transferable except after notifying the Division of Water Resources. The Division may require permit modification, or revocation and re -issuance. Please note that this permit does not affect your legal obligation to obtain other permits required by the Division of Water Resources, the Division of Land Resources, the Coastal Area Management Act, or other federal or local governments. If you have questions, or if we can further assist you, please contact Joe Corporon at fioe.comoron(il cn denr.govl or call (919) 807-6394. e4spfully,esp fully, 2 S. Jay Zimmerman, P.G Enclosure: NPDES Permit NCO078000 (issuance final) hc: WSRO/SWPS, Sherri Knight, Supervisor NPDES Program Files Central Files ec: WSRO/SWPS, Sherri Knight; George Smith OCU, Maureen Kinney ATU, Cindy Moore; Susan Meadows Permit NCO078000 STATE OF NORTH CAROLINA DEPARTMENT OF ENVIRONMENTAL QUALITY DIVISION OF WATER RESOURCES PERMIT TO DISCHARGE WASTEWATER UNDER THE NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM PDES 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 Groundwater Remediation GE -REM Greensboro Site, 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 December 1, 2016. This permit and the authorization to discharge shall expire at midnight on May 31, 2021. Signed this day November 9, 2016. r S Zimmerman, P.G. Director, Division of Water Resources By the Authority of the Environmental Management Commission Page 1 of 7 Permit NCO078000 , 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, consisting of • extraction wells • surge tank • in -line strainer, and • a 2-stage air stripper located at 2 HCI Boulevard, Greensboro, Guilford County, and 2. discharge from said treatment works via Outfall 001, a 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: 03030002] of the Cape Fear River Basin. Page 2 of 7 Permit NCO078000 Part I A. (L) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS [NCAC 0213.0400 et seq., 0213.0500 et seq.] 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 1 by the Permittee as specified below: EFFLUENT CHARACTERISTICS (Parameter Codes) PERMIT LIMITS MONITORING REQUIREMENTS Monthly Average Weekly Average Daily Maximum Measurement Frequency Sample Type Sample Location 2 Flow [MGD] 50050 0.216 Continuous Recording I or E pH 00400 Not < 6.0 nor > 9.0 s. u. Monthly Grab E Toluene 3 34010 Quarterly Grab E Benzene 3 34030 Quarterly Grab E Trans 1,2 Dichloroethene 3 34546 Quarterly Grab E Trichloroethene 3 78391 Quarterly Grab E WET -Testing, Chronic 4 TH3PB Quarterly Grab E Footnotes: 1. Beginning no later than December 21, 2016, the Pennittee shall submit discharge Monitoring Reports electronically using DWR's eDMR submittal system [See Section A. (3.)]. 2. I = Influent; E = Effluent 3. Sample shall be collected concurrently with toxicity sampling. 4. Whole Effluent Toxicity (WET) testing [TGP3B]; Chronic (Ceriodaphnia dubia) P/F at 90%; samples to be collected during January, April, July, and October [see A. (2)]. Condition: The Permittee shall discharge no floating solids or foam visible in more than trace amounts. Page 3 of 7 Permit NCO078000 A. (2.) CHRONIC TOXICITY - PERMIT LIMIT (QUARTERLY) [15A NCAC 02B .0500 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 February 1998, or subsequent versions or "North Carolina Phase H Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The tests will be performed during the months of January, April, July, and October. Effluent sampling for this testing 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 H Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) or subsequent versions. The chronic value for multiple concentration tests will be determined using the geometric mean of the highest concentration having no detectable impairment of reproduction or survival and the lowest concentration that does have a detectable impairment of reproduction or survival. The definition of "detectable impairment," collection methods, exposure regimes, and further statistical methods are specified in the "North Carolina Phase II Chronic Whole Effluent Toxicity Test Procedure" (Revised -February 1998) 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, DWQ Form AT-3 (original) is to be sent to the following address: Attention: North Carolina Division of Water Quality Environmental Sciences Section 1621 Mail Service Center Raleigh, North Carolina 27699-1621 Completed Aquatic Toxicity Test Forms shall be filed with the Environmental 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 Environmental 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. Should any test data from this monitoring requirement or tests performed by the North Carolina Division of Water Quality 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. Page 4 of 7 Permit NCO078000 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 and specify that, if a state does not establish a system to receive such submittals, then permittees must submit monitoring data and reports electronically to the Environmental Protection Agency (EPA). 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.) • Section D. (6.) • Section E. (5.) Reporting Records Retention Monitoring Reports 1. Reporting Requirements (Supersedes Section D. (2.) and Section E. (5.) (a)1 Effective December 21, 2016, 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. Until such time that the state's eDMR application is compliant with EPA's Cross -Media Electronic Reporting Regulation (CROMERR), Permittee will be required to submit all discharge monitoring data to the state electronically using eDMR and will be required to complete the eDMR submission by printing, signing, and submitting one signed original and a copy of the computer printed eDMR to the following address: NC DENR / Division of Water Resources / Water Quality Permitting Section ATTENTION: Central Files 1617 Mail Service Center Raleigh, North Carolina 27699-1617 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 mailing address above. 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. Page 5of7 Permit NC0078000 Starting on December 21, 2020, 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. 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. 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: hlW://portal.ncdenr.or web/wq/admin/bog%ipu/edmr 3. Signatory Requirements (Supplements Section B. (11.) (b) and Supersedes Section B. (11.) M 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://yortal.nedenr.or web/wq/admin/bog/ipu/edmr Page 6of7 Permit NC0078000 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: 7 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. " 4. Records Retention [Supplements Section D. (6.)] 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 a hAk Approximate Property r' V_ j�rn Boundary �4%% 0 of Edwardia Drive CHI Blvd .=t1:':nt `.,•i9t� �i Sri^ �=i,,,ry.� • In Ir . t • -- Wendover Ave West F Outfa11001 (flows E) UT to South Buffalo Creek (flows S) i�'I= ' O South Buffalo Creek (Flows SE) Brenntag Southeast, Inc. Facility GW REM — WWTP, 2 CHI Boulevard, Greensboro Location (not to scale) State Grid / USGS Ouad: C 19SW /Guilford, NC Receivine Stream: UT to South Buffalo Creek [segment 16-11-14-2] Latitude: N 36' 03' 52" HUC: 03030004 NPDES Permit NC0078000 Loneitude: W 79' 52' 37" Drainage Basin: Cape FcarRiver Basin Sub -Basin: 03-06-02 Stream Class: WS-V; NSW North Guilford County DEQ/DWR/NPDES COMPLEX -EXPIDITED FACT SHEET FOR NPDES PERMIT DEVELOPMENT NPDES Permit NCO078000 Facility Information Applicant/FacilityName: Brenntag Southeast, Inc. GW Remediation (GW-REM) Applicant Address: 2000 East Pettigrew Street; Durham, NC 27703 Facility Address: 2 HCl Boulevard; Greensboro, NC 27409 Permitted Flow 0.216 MGD Type of Waste: Treated groundwater (GW remediation of non -chlorinated and chlorinated organic solvents — DCE, TCE Facility Class/Permit Status: Class 1 PC / Renewal County: Guilford Miscellaneous Receiving Stream: UT to S. Buffalo Creek Regional Office: Winston-Salem Stream Classification: WS-V; NSW State Grid / USGS Quad: C19SW/Guilford 303(d) Listed? No — see notes below Permit Writer: Joe R. Corporon, L.G. Subbasin: 03-06-02 Date: 02Ju12016 Drainage Area (mil): 1.34 i Lat. N 36° 03' 52" Long. W79° 52' 37" Summer 7Q 10 cfs 0 Winter 7Q10 (cfs): 0.09 30Q2 cfs 0.11 Average Flow cfs : 1.2 IWC (%): 100% Primary SIC Code 4952 BACKGROUND Brenntag Southeast, Inc. is the owner/operator of a groundwater remediation system (GW-REM) located at its Greensboro site. This former Worth Chemical Corporation site became known as Brenntag following a merger of the two companies in 2001. Groundwater contamination resulted from spills to the former Worth Chemical's containment pond (now cleaned and filled for many years). Groundwater contaminants include chlorinated and non -chlorinated organic solvents. This remediation system operated continuously during the previous permit cycle (see Flow Summary 2012-2016). Receiving Stream — This facility discharges to a UT to South Buffalo Creek classified (WS-V; NSW). The defining waterbody (from the headwaters to McConnell Road) is not impaired. The lower portion of this stream segment is impaired (303d listed ; nutrient sensitive waters), however stream -impairment begins some 12 or more river miles downstream of the subject outfall [see 2011 renewal Fact Sheet, 303d list]. Fact Sheet NPDES NCO078000 Renewa12016 Page I FILE REVIEW / COMPLIANCE SUMMARY Reasonable Potential Analyses (RPA) - Flow history, averages, and maximums, are summarized in Table 2. DMR data were reviewed from Jan2012 through Apr2016. Throughout this period, the Permittee reported no parameter limit exceedances - no parameter was detected above its method -detection limit. Table 2. Flow Summary Jan2012 thru Apr2016 YEAR Samples (n) AVERAGE FLOW (MGDFLOW MAXIMUM (MGD) 2012 311 0.038 0.091 2013 342 0.029 0.063 2014 360 0.046 0.07 2015 315 0.043 0.078 2016 121 0.047 0.057 Receiving Stream / Toxicant Analyses. South Buffalo Creek is listed as impaired; nutrient sensitive waters (NSW), unrelated to this discharge. A Reasonable Potential Analysis (RPA) was not conducted because all analytical values were reported as "not detected." Current WET testing: Chronic P/F @ 90% (Jan., Apr., July, Oct.). All WET -tests "Pass" (last 18 Quarters). Table 3. DMR Review Summa — Jan2006 thru March 2011 Parameter Samples n Hits n Comments / Action Benzene 18 0 Not detected; no change to pennit Toluene 18 0 Not detected; no change to permit DCE Trans 1, 2 Dichloroethene 18 0 Not detected; no change to permit TCE Trichloroethene 18 0 Not detected; no thane to permit Chronic Toxicity [TGP3131 18 0 All Pass; no change to permit pH 64 _ MAX = 8.17 s.u.; Min = 6.89 s.u. no change to permit SUMMARY OF PROPOSED CHANGES Updated facility description (see Supplement to Cover Sheet) and facility map; add eDMR footnote and text. PROPOSED SCHEDULE FOR PERMIT ISSUANCE Draft Permit to Public Notice: Permit Scheduled to Issue: NPDES UNIT CONTACT July 27, 2016 September 9, 2016 If you have questions regarding any of the above information or on the attached permit, please contact Joe Corporon 919-807-6394. ,p; 66 � TE: Fact Sheet NPDES NCO078000 Renewal 2016 Page 2 ARCADIS Infrastructure, environment facilities MR Ms. Wren Thedford ., NCDEQ Division of Water Resources NPDES Unit .,, 1617 Mail Service Center Raleigh, NC 27699-1617 RECEIVEDINCDEOIDWR FEB 17 2018 Water Quality permitting Section subject: NPDES Permit Renewal Application, Groundwater Remediation System, Brenmag Mid -South, Inc., (Former Worth Chemical Facility), Greensboro, North Carolina. NPDES Permit No. NCO078000 Dear Ms. Thedford: On behalf of Brenmag Mid -South, Inc. (Brenntag), Arcadis G&M of North Carolina, Inc. (Arcadis) has enclosed one original and two copies of the National Pollutant Discharge Elimination System (NPDES) permit renewal application for the continued discharge of effluent from a groundwater remediation system at the Brenntag facility (former Worth Chemical facility) in Greensboro, North Carolina. Treated groundwater from the remediation system is discharged directly to an un- named tributary of South Buffalo Creek located along the eastern boundary of the site. No significant changes have been made to the existing treatment facility since issuance of the last permit. .., Please note that 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. Other items enclosed with this letter in support of the NPDES permit renewal application include the following: • Figure 1 - USGS topographic map of the project area that depicts the location of the system outfall; • Figure 2 - site map that depicts the route of the treated water to the discharge point; Arcadis G&M of North Carolina, Inc. 801 Corporate Center Drive Suite 300 Raleigh, North Carolina 27607-5073 Tel 919 854 1282 Fax 919 854 5448 vmv.arcadis.com ENVIRONMENTAL Date: February 9, 2016 Contact: Jim Shilliday Phone: 919-854-1282 E-mall: jshilliday@arcadis.com Our ref: NC102030.0015 ARCADIS • Attachment A — a copy of the October 2015 Discharge Monitoring Report which summarizes the most recent analytical data for the system effluent. If you have any questions regarding the information presented in the NPDES permit application or any of the supporting material, please call us at (919)854-1282. Sincerely, Arcadis G&M of North Carolina, Inc. V""VVvV 10 David Twamley, L.G. Staff Scientist copim Mr. Bruce Biehl (Brenntag Mid -South) Mr. Bill Mesar (Brenntag Mid -South) NCDEQ / DWR / NPDES Unit File E. Shilliday, III, VG \ )al Scientist, Pro ), ct Manager D±EWWOM CMM ree mFdyWNCI]O.WIPDES1Po Ren lApplimtionlDaver Lell fw NPDES Pe Rmw.siOov Page: 2/2 NPDES PERMIT APPLICATION - SHORT FORM C - GW For discharges associated with groundwater treatment facilities. no Mail the complete application to: N. C. Department of Environment and Natural Resources am Division of Water Quality / NPDES Unit 1617 Mail Service Center, Raleigh, NC 27699-1617 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 Bruce Biehl Facility Name Brenntag Mid -South, Inc. ^ Mailing Address 2000 East Pettigrew Street City Durham ^ State / Zip Code North Carolina 27703 Telephone Number (919)596 0681 RECEIVED/NCDEQIDWR Fax Number (919)596 5441 FF-R t 7�G e-mail Address Bbiehl@brenntag.com Water 8uaiify 2. Location of facility producing discharge: Permitting Section _ Check here if same as above ❑ Street Address or State Road 2 HCI Boulevard City Greensboro ^ State / Zip Code North Carolina / 27409 County Guilford 3. Operator Information: Name of the firm, consultant or other entity that operates the facility. (Note that this is not referring to the ^ Operator in Responsible Charge or ORC) Name Arcadia ^ Mailing Address 801 Corporate Center Drive, Suite 300 City Raleigh .. State / Zip Code North Carolina / 27607 Telephone Number (919)854 1282 Fax Number (919)854 5448 4. Ownership Status: Federal ❑ State ❑ Private ® Public ❑ Page I of 3 C-GW 03/05 NPDES PERMIT APPLICATION - SHORT FORM C - GW For discharges associated with groundwater treatment facilities. S. Products recovered: Gasoline ❑ Diesel fuel ❑ Solvents ® Other chlorinated and nonchlorinated solvents fW 6. Number of separate discharge points: 1 OutfoR Identification number(s) 001 MM 7. Frequency of discharge: Continuous ® Intermittent ❑ MM 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 outfall, including latitude and longitude Unnamed Tributary to South Buffalo Creek 36 03 51.92N 79 52 37.3SW 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 renewalsft 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. a" Page 2 of 3 C-GW 03/05 NPDES PERMIT APPLICATION - SHORT FORM C - GW For discharges associated with groundwater treatment facilities. 0" R" 13. Applicant Certification I certify that I am familiar with the information contained in the application and that to the M+ best of my knowledge and belief such information is true, complete, and accurate. Bruce Biehl Director of Regulatory Affairs oft Printed name of Person Signing Title M" 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 F' 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, MR for a similar offense.) am MR MR �a M" a" 0" P" P" P—" Page 3 of 3 C-GW 03/05 o� Mt 6. Radio-'fOwen�\ ` or �• ( {(fj 96a Ns _Poo (WCOG) ' /�, ' _ /, /,�`' t y • f -`ice 1 � ftl l: \[) 1 t0{Ch6�k1. 3. APPROXIMATE SITE = OUTLINE 1 ti./ At .i `+1 /C/\' i_� '� `�7- t.l enc• B89 `c 1,�6 �G lu/jt,{U��'\ .1�j ♦ /� � ' '• f'• ,b� ,I�- i 73.• Outfall 001 �G •` r ►• s �c. I �. 1 j ♦ 1 . _ o `' • Terra Cot is e77 w'•to1� e 4 —i'Y Ji'.I/Y!/ �fl! o .�_ �"/ ,i"�i•% � � p � �un4cr� . c•.. ARCADIS 80,Corperet2CenterOne, Suite 300 Raleigh. NC 27807 919-8541282 ! Infrastructure buildings, environment communicatlons REV. DRAWING DATE: ACAD FILE: QUADRANGLE LOCATION 1 /9/D6 N SCALE 1:24000 SITE LOCATION MAP 0 2000 4000 CLIENT: PM: JS BRENNTAG SOUTHEAST, INC. LOCATION: 2 HCI BOULEVARD PEIRG: SOURCE: TOPOGRAPHY TAKEN FROM USGS 7.5 MINUTE QUADRANGLE GREENSBORO, NC GUILFORD AND GREENSBORO, NC MAPS DESIGNED: DETAILED: PROJECT NO: FIGURE: 1951 AND PHOTOREVISED W 1994 CJK NC102030.0010 1 LU F m -4 AREA I OF CONCERN I I - ----------------------------- .. ....... . �`:.:.tliVtf.;::::: S W M U #3 t #..... , ,�;.;::.::::,.::::::: spill . r...:•:.•.. .....Containment I I ,•:.::::;:::;:::::.;fir �f'•::::•::•::•::::.�:.: Basin I �� .......... ' `:-: ` : Diked AST .............. Area , Coverreed�Dock ........./ f l Closed Surface GFE / = / / Impoundment Speedy �: f Groundwater Spread, ` Treatment Treatment nc. System System c Bulk N �� NPDES Stop a Bldg. ` ` / ` `` Discharge Point � Office )3 `1koutfa11 001) / Bldg. RAS 1 \ 0 ARCADIS Jnfrastrudure, environment facilities #=ADIS 0tM of North Carolina, Ina Rsal aleigh276 0Cenbr Nve. Suns Too Tel: 919-954-1252 Fine 919-554-5448 wwr.aeeadh '.M PRJT MANAGER- CHECKED BY- J. SHILLIDAY I D. TVANLEY DRAFTERi I PROJECT NUMBERS NC102030.0015 NOTES: 1. Building Locations 8. Well Locations are based on site nap provided by Duncklee 6 Dunham P.C. May 2002. Greensboro Auto Auction Shop BRENNTAG MID -SOUTH, INC. GREENSBORO, NORTH CAROLINA r LEGEND BUILDINGS/STRUCTURES RAILROAD TRACKS FENCE — - - — PROPERTY LINE — — — CREEK CULVERTED SECTION OF CREEK r i AREA OF CONCERN SWMU LOCATION — — _ CLOSED SURFACE. IMPOUNDMENT SCALE IN FEET 0 100 200 SITE MAP FIGURE: 2 •, t ARCADIS Infrastructufe, environment, facilities r• ATTN: Central Files + North Carolina Department of Environmental Quality Division of Water Resources 1617 Mail Service Center Raleigh, North Carolina 27699-1617 Subject: Discharge Monitoring Report for October 2015, Brenntag Mid -South Facility 2 HCl Boulevard, Greensboro, North Carolina NPDES Permit No. NCO078000 + Guilford County Dear Sir or Madam: ARCADIS is pleased to submit the attached Discharge Monitoring Report (DMR) for the month of October 2015 on behalf of Brenmag Mid -South, Inc. for the facility located at 2 HCl Boulevard in Greensboro, North Carolina. Also attached is the laboratory analytical data report for the parameters shown on the DMR and a copy of the Effluent Aquatic Toxicity Report Form (Form AT-1). + During October 2015, the groundwater remediation system operated throughout the month with approximately 7 days of "downtime" due to maintenance associated with + the blower unit for the groundwater remediation system's air stripper tower. A total of 1,066,610 gallons of water were extracted and treated by the groundwater remediation system from September 30, 2015 through October 30, 2015. As of October 30, 2015, approximately 371,273,870 gallons of water had been extracted and treated by the groundwater remediation system since activation of the system in October 1992. r The pH of the effluent from the groundwater remediation system was analyzed on October 16, 2015. The measurement indicated an effluent pH of 7.87 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 27, 2015, 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 27 and 29, 2015. 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 Ceriodaphnia Part of a bigger picture ARCADIS G&M of North Carolina, Inc. 801 Corporate Center Drive Suite 300 Raleigh, North Carolina 27607-5073 Tel 919 854 1282 Fax 919 854 5448 v .arcadis-us.com ENVIRONMENTAL Date: November 24, 2015 Contact: Jim Sbilliday Phone: Ext.52302 Ennall: jshflhday@arcadis.com Our ref: NC102030.0015 ARCADIS Chronic Effluent Toxicity Procedure (revised February 1998). The effluent samples Oft passed the chronic toxicity test. As required by the NPDES permit, the remediation system effluent will be sampled OR again for VOCs and chronic toxicity testing during the next quarterly sampling event in January 2016. 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, Staff Scientist 1 I es E. Shilliday, III, G. ✓PrincipL al Scientist/ _.—i Project Manager Copies: Bruce Biehl — Brenntag Mid -South (Durham) Bill Mesar — Brenntag Mid -South (Greensboro) Project File .e - Page: G:TW%A'Gn C ical%Grx Wro FndhyWC10203p0015`NPI)MQO I S-IOG oh DMR=dC rcpwn 2015 D"lmu.doc 2/2 EFFLUENT NPDES PERMIT NO. NCO078000 DISCHARGE NO. 001 MONTH October YEAR 2015 — FACILITY NAME Brenntag Mid -South, Inc CLASS PC-1 COUNTY Guilford CERTIFIED LABORATORY (1) Test America, Inc. CERTIFICATIONNO. 269 (list additional laboratories on the backside/page 2 of this form) — OPERATOR IN RESPONSIBLE CHARGE (ORC) William Mesar GRADE PC-1 CERTIFICATION NO.985455 PERSON(S) COLLECTING SAMPLES Dave Twamley (ARCADIS G & M) ORC PHONE (336) 292-5166 CHECK BOX IF ORC HAS CHANGED * 0 NO FLOW / DISCHARGE FROM SITE *Q ••r Mail ORIGINAL and ONE COPY to: _ ATTN: CENTRAL FILES DIVISION OF WATER QUALITY — 1617 MAIL SERVICE CENTER RALEIGH NC 27699-1617 - - - BY TRIS SIGNATURE, I CERTIFY THAT THIS REPORT IS ACCURATE AND COMPLETE TO THE BEST OF MY KNOWLEDGE. D W Q Form MR- I.1 (11 /04) Facility Status: (Please check one of the following) All monitoring data and sampling frequencies meet permit requirements X �+ (including weekly averages, if applicable) Compliant All monitoring data and sampling frequencies do NOT meet permit requirements 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. "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 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." William Mesar Permittee (Please print or type) Signature of P rmittee*** V Date (Required unless submitted electronically) �► Brenntag Mid -South, Inc. 2000 East Pettigrew Street, Durham, NC 27703 (919) 596-0681 May 31, 2016 Permittee Address Phone Number e-mail address Permit Expiration Date ADDITIONAL CERTIFIED LABORATORIES Certified Laboratory (2) R&A Laboratories Certification No. 34 Certified Laboratory (3) Certification No. Certified Laboratory (4) Certification No. +�• Certified Laboratory (5) Certification No. PARAMETER CODES Parameter Code assistance may be obtained by calling the NPDES Unit at (919) 733-5083 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. ate► 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 Client Sample Resuita Client: ARCADIS U.S., Inc. TestAmerica Job ID: 680-118349-1 Project/Site: Brenntag/FWC/Greensboro (Effluent) client Sample ID: thiuent Lab sample !D: 68-0-11834-6-1 Date Collected: 10/27/15 13:00 Matrix: Water Date Received: 10128115 10:00 Method: 8260B Volatile Organic Compounds (GC/MS) Analyte Result Qualifier RL MDL Unit D Prepared Analyzed Dill Fac Benzene 1.0 U 1.0 ug/L 11/03/1517:24 1 Toluene 1.0 U 1.0 ug/L 11103/1517:24 1 trans-1,2-Dichlorcethene 1.0 U 1.0 ug/L 11/03/1617:24 1 Trichloroelhene 1.2 1.0 ug/L 11/03/1517:24 1 Surrogate %Recovery Qualifier Limits prepared Analyzed Dil Fac Toluene d8 (Burr) 97 70- 130 11103115 17:24 1 1,2-Dichloroethane-d4 (Surr) 86 70- 130 11103115 17:24 1 Dibromo8uoromethane (Sun) 92 70-130 11ION15 17:24 1 4-Bromotluorobenzene (Surr) 98 70- 130 11103115 17:24 1 r r Page 8 of 15 TestAmerica Savannah 11 /10/2015 FAW Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 11/05/15 Facility: BRENNTAG MIDSOUTH NPDES#: NCO078000 Pipe#: 001 County: GUILFORD Laboratory Per i Test: R & A LABORATORIES, INC. X Comments: Final Effluent An a+n Sign re erbLtor In Responsible Charge Arcadis Project MIN atory supervisor Mork Order: 10844/10942 MAIL ORIGINAL TO: FM lorth Carolina Ceriodaphnia Chronic Pass/Fail Reproduction Toxicity Test MR 'ONTROL ORGANISMS # Young Produced * PASSED: 2.54t Reduction * Environmental Sciences Branch Div. of Environmental Management N.C. Dept. of EHNR 1621 Mail Service Ctr Raleigh, North Carolina 27699-1621 Chronic Test Results Calculated t = 9.888 Tabular t = 2.508 1 2 3 4 5 6 7 8 9 10 it 12 $ Reduction = 2.54 Mortality Avg.Reprod. 25 22 21 23 23 21 25 21 22 24 24 25 0.00 23.00 Control Control Adult (L) ive (D) ead L L L L L L L L L L L IL 0.00 22.42 FM effluent %,: 90%- Treatment 2 Treatment 2 *'REATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV 6.937%- PASS FAIL # Young Produced 24121122 23 25 21 22 25 21 20 22 23 t control orgs X producing 3rd brood Check One Adult (L) ive (D) ead L IL IL L L L L L L L L L 100� 1st sample 1st sample 2nd sample Complete This For Either Test pH Test Start Date: 10/28/25 Control 6.94 6.99 6.91 7.00 6.96 7.04 Collection (Start) Date Sample 1: 10/27/15 Sample 2: 10/29/15 reatment 2 7.81 7.88 6.96 7.04 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 1 X hrs L A A r d r d r d U M M t t t Sample 2 X hrs T P P 1st sample 1st sample 2nd sample �'0' Control 8.6 8.4 8.6 8.3 8.6 8.4 Hardness (mg/1) 47 .......... ...••••... :068...... :::::::::: Creatment 2 8.5 8.3 8.5 8.2 8.5 8.3 Spec. Cond.(Pmhos) 186 443 439 Chlorine(mg/1) 0.02 0.02 .IC50/Acute Toxicity Test Sample temp. at receipt(°C) 2.0 3.0 (Mortality expressed as W, combininq replicates) 1-7 ,C50 = $ -954; Con i ence Limits -- %- Note: Please Concentration Complete This Section Also Mortality start/end start/end Method of Determination Control Moving Average Probit Spearman Karber = Other - High Conc. pH D.O. Organism Tested: Ceriodaphnia dubia Duration(hrs): opied from DEM form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.32) ,C50 = $ -954; Con i ence Limits -- %- Note: Please Concentration Complete This Section Also Mortality start/end start/end Method of Determination Control Moving Average Probit Spearman Karber = Other - High Conc. pH D.O. Organism Tested: Ceriodaphnia dubia Duration(hrs): opied from DEM form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.32) L ARCADIS Infrastructure, environment, factlittes �I North Carolina Department of Environmental Quality .., Division of Water Resources Aquatic Toxicology Branch 1623 Mail Service Center Raleigh, North Carolina 27699-1623 Subject: Chronic Toxicity Testing Report for October 2015, Brenntag Mid -South Facility, 2 HCl Boulevard, Greensboro, North Carolina NPDES Permit No. NCO078000 Guilford County M Dear Sir or Madam: ARCADIS is pleased to submit the attached Division of Environmental Management (DEM) form AT-1 for the month of October 2015 on behalf of Brenntag Mid -South, Inc. for the facility located at 2 HCl Boulevard in Greensboro, North Carolina. Also attached is the laboratory analytical data report for the analytical parameters required by the NPDES permit. During October 2015, the groundwater remediation system operated throughout the month with approximately 7 days of "downtime" due to maintenance associated with the blower unit for the groundwater remediation system's air stripper tower. A total of 1,066,610 gallons of water were extracted and treated by the groundwater remediation system from September 30, 2015 through October 30, 2015. As of .. October 30, 2015, approximately 371,273,870 gallons of water had 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 16, 2015. The measurement indicated an effluent pH of 7.87 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 27, 2015, 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 27 and 29, 2015. The grab samples were transported on ice to Research & Analytical Laboratories, Inc. in Kernersville, North Carolina. The samples were analyzed in r. accordance with the test procedures outlined in the North Carolina Ceriodaphnia Patt of a bigger picture ARCADIS G&M of North Carolina, Inc. 801 Corporate Center Drive Suite 300 Raleigh, North Carolina 276075073 Tel 919 854 1282 Fax 919 854 5448 w .arcaois-us.com ENVIRONMENTAL Date: November 24, 2015 Contact: Jim Shilbday Phone: Ext. 2302 Email: jshilliday@arcadis.com Our ref. NC102030.0015 ARCADIS Chronic Effluent Toxicity Procedure (revised February 1998). The effluent samples �. passed the chronic toxicity test. 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 2016. _ If you have any questions regarding the information presented in this letter or on the attached effluent toxicity report form (form AT-1), please call one of the individuals listed below. Sincerely, ARCADIS G&M of North Carolina, Inc. David Twamley, L.G. James E. Shilliday, III, �G. ., Staff Scientist Principal Scientist/ Project Manager Copies: Bruce Biehl — Brenntag Mid -South (Durham) Bill Mesar— Brenmag Mid -South (Greensboro) Project File Page: G1EWWodh ChemicaOGreensboro FaClitMC102030.0015WPDE512015-10 Wober DMR and CT reporROO 2015 T0166ty LettecCoc 2/2 M Effluent Toxicity Report Form - Chronic Pass/Fail and Acute LC50 Date: 11/05/15 Facility: BRENNTAG MIDSOUTH NPDES#: NCO078000 Pipe#: 001 County: GUILFORD Laboratory Per i Test: R & A LABORATORIES, INC. X Comments: Final Effluent An �.., Sign re pe for n Response e Charge Arcades Project X �/1 1 � or/Laboratory Supervisor I * PASSED: 2.54t Reduction * Mork Order: 10844/10942 MAIL ORIGINAL TO: FM _north Carolina Ceriodaphnia Chronic Pass/Fail Reproduction Toxicity Test :ONTROL ORGANISMS Environmental Sciences Branch Div. of Environmental Management N.C. Dept. of EHNR 1621 Mail Service Ctr Raleigh, North Carolina 27699-1621 Chronic Test Results Calculated t = 0.888 Tabular t = 2.508 1 2 3 4 5 6 7 8 9 10 11 12 $ Reduction = 2.54 # Young Produced 25 22 21 23 23 21 25 21 22 24124125 t Mortality Avg.Reprod. 0.00 23.00 Adult (L}eve (D)ead ii L L L L L L L L L L L L Control Control 0.00 22.42 affluent %-: 90%- Treatment 2 Treatment 2 =REATMENT 2 ORGANISMS 1 2 3 4 5 6 7 8 9 10 11 12 Control CV 6.937%- PASS FAIL # Young Produced 11 24 21 22 23125121 22 25 21 20 22 23 W control orgs X producing 3rd �_.Adult Wive (D)ead L LIL L L L L L brood 100%; Check One 1st sample 1st sample 2nd sample Complete This For Either Test pH Test Start Date: 10/28/15 am Control 6.94 6.99 6.91 7.00 6.96 7.04 Collection (Start) Date Sample 1: 10/27/15 Sample 2: 10/29/15 reatment 2 7.81 7.88 6.96 7.04 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 1 X hrs L A A -- r d r d r d U M M t t t Sample 2 X hrs T P P ftm 1st sample 1st sample 2nd sample Hardness (mg/1) 47 .•••...... .••....... .......... .......... Control 8.6 8.4 8.6 8.3 8.6 8.4 .......... .......... Spec. Cond.(pmhos) 186 443 439 Preatment 2 8.5 8.3 8.5 8.2 8.5 8.3 Chlorine(mg/1) 0.02 0.02 _jC50/Acute Toxicity Test Sample temp. at receipt (0C) :ccssssc:: 2.0 3.0 Mortality expressed as %, combining replicates) ,C5 0 = $ 95W Con i ence Limits Note: Please Concentration Complete This Section Also Mortality start/end start/end Method of Determination Control Moving Average Probit Spearman Karber - Other - High Conc. pH D.O. wwOrganism Tested: Ceriodaphnia dubia Duration(hrs): 'opied from DEM form AT-1 (3/87) rev. 11/95 (DUBIA ver. 4.32) MR Client Sample Results Client: ARCADIS U.S., Inc. Project/Site: Brenntag/FWC/Greensboro (Effluent) �Cael�t Saalv�Ce C�: �%�Ct'�es�fr - Date Collected: 10/27/15 13:00 Bate Received: 10128/15 10:00 Method: 82608 Volatile Organic Compounds (GC/MS) Analyte Result Qualifier RL Benzene 1.o U 1.0 Toluene 1.0 U 1.0 trans-1,2-Dichloroethene 1.0 U 1.0 Trichloroethene 1.2 1.0 Surrogate %Recovery Qualifier Limits Talue -(Sum) 97 70- 330 1,2-Dichloroethane44(Suff) 88 70-130 Dibmmofluoromethane (Sure) 92 70-130 4-Broma0uombenzene (Suff) 98 70- 130 TestAmerica Job ID: 680-11834E-1 Lab Same a 16: 68-0-1 Ueus 'G Matrix: Water MDL Unit D Prepared Analyzed oil Fac ug/L 11/03/15 17:24 1 ug/L 11/03/15 17:24 1 ug/L 11103/15 17:24 1 ug/L 11/03/15 17:24 1 Prepared Analyzed Dll Fac 11103115 17:24 1 11103115 17:24 1 11/03/15 17:24 1 11/03/15 17:24 1 TestAmerica Savannah Page 8 of 15 11/10/2015