NC0086827_More Information (Received)_20210302

RECEIVED
0 .2 2021 ARCADIS
NCDEQ/DWR/NPDES
Ms.Wren Thedford Arcadis G&M of North
Carolina, Inc. _
NC DEQ—Division of Water Resources Wade I
NPDES Unit 5420 Wade Park
1617 Mail Service Center Boulevard
Suite 350
Raleigh, NC 27699-1617
Raleigh
North Carolina 27607
Date: February 25, 2021 Phone: [phone]
Subject: NPDES Permit Renewal Application(NPDES Permit NC0086827), Fax: [phone]
Groundwater Remediation System, Brenntag Mid-South, Inc. www.arcadis.com •
Durham, North Carolina
NC Engineering License#C-1869
NC Surveying License#C-1869
Dear Ms. Thedford,
On behalf of Brenntag Mid-South, Inc. (Brenntag), Arcadis G&M of North Carolina, Inc. (Arcadis) is submitting the
attached 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 Southchem facility)
in Durham, North Carolina(NPDES Permit NC0086827).Treated groundwater from the remediation system is
discharged to an on-site storm sewer that, in turn, discharges to a drainage ditch located along the southern
boundary of the site. This drainage ditch conveys surface water to an unnamed tributary of Third Fork Creek. No
changes have been implemented to the groundwater remediation system since issuance of the previous NPDES
Permit on November 1, 2016.
We have one requested revision to the NPDES Permit.We would like to remove bis(2-ethylhexyl)phthalate from
the required parameter list. This compound is problematic for a variety of reasons.as noted below. We reviewed
the effluent results all the way back to when we first started collecting NPDES samples in 2002, and it does not
appear that we have ever detected this compound above the current discharge limit of 1.2 micrograms per liter
(pg/L). We have included with this submittal Table 1 which provides a summary of the treatment system effluent
results for the period of November 2016 through December 2020 (the effective period of the existing NPDES
Permit).As can be seen on Table 1, bis(2-ethylhexyl)phthalate has been detected twice during this 4 year period,
and both detections were estimated values (0.68J and 0.11J pg/L)occurring below the discharge limit of 1.2 pg/L.
In addition, the laboratory that performs all the analyses for our NPDES samples (Eurofins-TestAmerica) has
detected bis(2-ethylhexyl)phthalate in the method blanks for samples collected in the past. In communications
with.Eurofins TestAmerica, they have confirmedthat bis(2-ethylhexyl)phthalate is a problematic analyte. They
provided several references documenting that bis(2-ethylhexyl)phthalate can be an artifact resulting from both
sample collection and/or analysis procedures due to its ubiquitous presence in plastics and a variety of other
consumer and industrial products. Our concern is that any future detection of bis(2-ethylhexyl)phthalate would most likely be an artifact of sample collection or sample analysis procedures, and yet this is often very •
difficult to prove. So for the reasons noted above,we would like to request the elimination of bis(2-
ethylhexyl)phthalate)from future permit monitoring requirements.
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(e.g. silt, iron and manganese
precipitate)generated during the groundwater extraction and/or treatment processes are filtered from the
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Ms. Wren Thedford
February 25, 2021
treatment stream using bag filters and granular activated carbon units. The treated effluent is sampled on a
monthly basis for total suspended solids in accordance with the monitoring requirements for the site.
Other items enclosed with this letter in support of the NPDES permit renewal application include the
following:
• Table 1 —summary of the effluent sampling results for a 4 year period between January 2017 through
December 2020 supporting the requested reduction of sampling parameters discussed in this letter;
• Figure 1 - USGS topographic map of the project area that depicts the location of the system outfall;
• Figure -site map that depicts the route of the treated water to the discharge point.
If you have any questions regarding the information presented in the NPDES permit application or any of the
supporting material, please call me at(919)415-2302.
Sincerely, -
Arcadis G&M of North Carolina, Inc.
James E. Shilliday, Ill, L.G.
Principal Scientist, Project Manager
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Copies:
Mr. David Grenoble(Brenntag Mid-South) -
www.arcadis.com
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