NC0086827_Compliance Evaluation Inspection_20210423

ROY COOPER
Governor
DIONNE DELLFGATTI
Secretary
S. DANIEL SMITH
Director
David Grenoble
Brenntag Mid -South, Inc.
2000 E. Pettigrew St.
Durham, NC 27703
NORTH CAROLINA
Environmental Quality
April 23, 2021
Subject: Compliance Evaluation Inspection
NPDES Permit NCO086827
Facility Name: Brenntag / Durham remediation
Durham County
Dear Mr. Grenoble:
On April 15, 2020, Josh Brigham of the Raleigh Regional Office conducted a compliance evaluation
inspection of the treatment facilities located at the Brenntag / Durham groundwater remediation site. The
purpose of this inspection was to ensure compliance with the subject NPDES permit. During the
inspection, the guidance of yourself, Robert Walston, Robert Prigge, and Brent Herb were greatly
appreciated.
The Brenntag / Durham groundwater remediation system is located at 2000 E. Pettigrew St. in Durham,
North Carolina. The subject facility is covered under NPDES Permit NC0086827. The subject facility is
permitted to discharge remediated groundwater to Third Fork Creek, which is classified as a Water
Supply-V Nutrient Sensitive Water in the Cape Fear Basin.
This NPDES compliance evaluation inspection consisted of the following:
• Review of the NPDES permit;
• Review of the owner/facility information;
• On -site review of records and logs;
• On -site inspection of the wastewater treatment units; and
• Inspection of the discharge outfall.
Findings during the pre -inspection file review were as follows:
1. The current NPDES permit was issued effective November 1, 2016, and expires April 30, 2021. The
Division received the permit renewal application on February 19, 2021.
2. A review of Division records revealed that there are no overdue annual permit fees.
3. A review of the facility's DMR violation report starting in January 2018 indicated the facility had a
limit violation for monthly average exceedance of acetone on July 31, 2020 and a monitoring
violation for oil and grease on March 31, 2020. These proceeded to a NOV and NOD respectively.
Findings during the inspection were as follows:
4. Arcadis maintains the treatment units and collects samples. All parameters are analyzed by Test
America Inc. except Chronic Toxicity, which is tested by Pace. Arcadis keeps digital chain of custody
forms, in addition to visitations logs. Further record review indicated that lab results and DMRs were
D Q
�� North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
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complete and organized. A cursory review of lab results for October and November 2020 revealed no
discrepancies with submitted eDMRs.
5. Division records indicate that Scott Alan Dirl is the designated Operator in Responsible Charge
(ORC) and is certified as PC-1. There is no designated backup ORC in the Division's records.
During the inspection, the inspector was informed that Jennifer Hanolt completed her PC-1
certification on April 14, 2021, and will serve as the backup ORC (this was later verified by an e-mail
from Brenntag staff) for the treatment system. Within 30-days of receiving this letter, please
complete the attached ORC designation form and submit it to the address on the form to
designate Ms. Hanolt as the bORC. Please also send a copy to this office. Since Arcadis
maintains the treatment units and collects samples, it was not clear to the inspector how the ORC and
bORC are involved with the subject treatment system. North Carolina Administrative Code Title 15A
subchapter 08G Section .0204(3) requires operators to maintain the system and attempt to ensure the
compliance of the system with any permits issued for the system as well as any other applicable local,
State, and federal environmental permitting and regulatory requirements. Within 30-days of
receiving this letter, please indicate how the designated operators are involved with the
compliance of the subject permit.
6. The permit lists the following treatment units (comments are provided for some units):
a. Influent Flow Meter — Staff stated the meter is replaced annually.
b. Bag Filter (2)
c. Air stripper unit with collection sump and blower
d. Transfer Pump
e. Two (2) each GAC disposable filters
f. Two (2) each cation disposable filters - Removed, Arcadis representative stated that
they were not aiding in meeting permit requirements.
g. Effluent flow meter with totalizer — Staff stated the meter is replaced annually. Flow
is measured
h. Effluent sample location — Sampling is collected from a valve on the piping located
after treatment units. Sampling is also done on the influent.
i. Discharging pipe and outfall — Discharges in same location as stormwater that is
routed through the property.
7. The right of way to the outfall was properly maintained. The outfall was not discharging on the day of
the inspection.
Within 30 days of receiving this letter, please respond in writing describing the actions that Brenntag
will take or have taken to resolve issues noted in item S above.
If you have questions concerning this report please contact Josh Brigham at 919-791-4251 or
joshua.bri ham(a,ncdenr.gov.
Sincerely,
DocuSigned by:
VAAA ,SSA, It. k.oi ln, ALL
a6 WfffeYl, Assistant Regional Supervisor
Water Quality Regional Operations Section
Raleigh Regional Office
Division of Water Resources, NCDEQ
ATTACHMENTS: EPA Water Compliance Inspection Report
ORC Designation Form
Cc: RRO Files
Laserfiche
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North Carolina Department of Environmental Quality I Division of Water Resources
Raleigh Regional Office 13800 Barrett Drive I Raleigh, North Carolina 27609
919.791,4200

United States Environmental Protection Agency
Form Approved.
EPA Washington, D.C. 20460
OMB No. 2040-0057
Water Compliance Inspection Report
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 IN I 2 15 I 3 I NCO086827 I11 12 21/04/15 17 18 L l 191 ! I 201
21111111111111111111111111111111111111111111 I66
Inspection Work Days Facility Self -Monitoring Evaluation Rating 61 QA ---------------------- Reserved ------ ------------
I 72 I n, I 73I ( IL_I74 71 1 1 I I I I 180
67 70I I 71ItyL
IJ J L_
Section B: FacilityData
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)
09:30AM 21J04/15
16/11/01
Brenntag / Durham remediation
2000 E Petigrew St
Exit Time/Date
Permit Expiration Date
Durham NC 277034049
10:45AM 21/04/15
21/04/30
Name(s) of Onsite Representative(s)Mtles(s)/Phone and Fax Number(s)
Other Facility Data
Name, Address of Responsible Official/Title/Phone and Fax Number
Jeffrey Best,2000 E Petigrew St Durham NC 277034049//919-281-2993/ Contacted
No
Section C: Areas Evaluated During Inspection (Check only those areas evaluated)
Permit 0 Flow Measurement Operations & Maintenar 0 Records/Reports
Effluent/Receiving Wate 0 Laboratory
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
Joshua S Brigham DWR/RRO WQ/919-791-4200/
Signature of Management Q A Reviewer ncy/Office/Phone and Fax Numbers Date
D 'J
rs
EPA Form 3560-3 (Rev 9-94) Previous editions a e obsolete.
Page#

NPDES yr/mo/day Inspection Type (Cont.)
31 NCO086827 I11 12I 21/04/15 117 18 IC I
Section D: Summary of Finding/Comments (Attach additional sheets of narrative and checklists as necessary)
1. Arcadis maintains the treatment units and collects samples. All parameters are analyzed by
TestAmerica Inc. except Chronic Toxicity, which is tested by Pace. Arcadis keeps digital chain of
custody forms, in addition to visitations logs. Further record review indicated that lab results and DMRs
were complete and organized. A cursory review of lab results for October and November 2020
revealed no discrepancies with submitted eDMRs.
2. Division records indicate that Scott Alan Dirl is the Operator in Responsible Charge (ORC) and is
certified as PC-1. During the inspection, the inspector was informed that Jennifer Hanolt had
completed her PC-1 certification on 4/14 to serve as backup ORC (this was later verified by an e-mail
from Brenntag staff). Please complete the attached ORC designation form and submit it to the address
on the form. Please also send a copy to this office. Since Arcadis maintains the treatment units and
collects samples, it was not clear to the inspector how the ORC and bORC are involved with the
subject permit. North Carolina Administrative Code Title 15A subchapter 08G Section .0204(3) requires
operators to maintain the system and attempt to ensure the compliance of the system with any permits
issued for the system as well as any other applicable local, State, and federal environmental permitting
and regulatory requirements. Please indicate how the operators are involved with the compliance of the
subject permit.
3. The permit lists the following treatment units (comments are provided for some units):
a. Influent Flow Meter — Staff stated the meter is replaced annually.
b. Bag Filter (2)
c. Air stripper unit with collection sump and blower
d. Transfer Pump
e. Two (2) each GAC disposable filters
f. Two (2) each cation disposable filters - Removed, Arcadis representative stated that they were not
aiding in meeting permit requirements.
g. Effluent flow meter with totalizer — Staff stated the meter is replaced annually. Flow is measured
h. Effluent sample location — Sampling is collected from a valve on the piping located after treatment
units. Sampling is also done on the influent.
i. Discharging piping and outfall — Discharges in same location as stormwater that is routed through
the property.
4. The right of way to the outfall was properly maintained. The outfall was not discharging on the day
of the inspection.
Page#

Permit: NCO086827 Owner -Facility: Brenntag / Durham remediation
Inspection Date: 04/15/2021 Inspection Type: Compliance Evaluation
Laboratory
Yes
No
NA NE
Are field parameters performed by certified personnel or laboratory?
0
❑
❑
❑
Are all other parameters(excluding field parameters) performed by a certified lab?
0
❑
❑
❑
# Is the facility using a contract lab?
0
❑
❑
❑
# Is proper temperature set for sample storage (kept at less than or equal to 6.0 degrees
❑
❑
M
❑
Celsius)?
Incubator (Fecal Coliform) set to 44.5 degrees Celsius+/- 0.2 degrees?
❑
❑
0
❑
Incubator (BOD) set to 20.0 degrees Celsius +/- 1.0 degrees?
❑
❑
0
❑
Comment
Record Keeping
Yes
No
NA
NE
Are records kept and maintained as required by the permit?
0
❑
❑
❑
Is all required information readily available, complete and current?
M
❑
❑
❑
Are all records maintained for 3 years (lab. reg. required 5 years)?
0
❑
❑
❑
Are analytical results consistent with data reported on DMRs?
0
❑
❑
❑
Is the chain -of -custody complete?
0
❑
❑
❑
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?
❑
❑
❑
Has the facility submitted its annual compliance report to users and DWQ?
❑
❑
0
❑
(If the facility is = or > 5 MGD permitted flow) Do they operate 24/7 with a certified operatc
❑
❑
0
❑
on each shift?
Is the ORC visitation log available and current?
❑
❑
0
❑
Is the ORC certified at grade equal to or higher than the facility classification?
0
❑
❑
❑
Is the backup operator certified at one grade less or greater than the facility classification'
0
❑
❑
❑
Is a copy of the current NPDES permit available on site?
M
❑
❑
❑
Facility has copy of previous year's Annual Report on file for review?
❑
❑
0
❑
Comment: Arcadis keeps digital log of visits and COC forms
Flow Measurement - Influent Yes No NA NE
# Is flow meter used for reporting? 0 ❑ ❑ ❑
Page# 3

Permit: NCO086827
Inspection Date: 04/15/2021
Flow Measurement - Influent
Owner -Facility: Brenntag / Durham remediation
Inspection Type: Compliance Evaluation
Is flow meter calibrated annually?
Is the flow meter operational?
(If units are separated) Does the chart recorder match the flow meter?
Comment: Replaced annually
Flow Measurement - Effluent
# 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: Replaced annually
Effluent Pipe
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:
Yes No NA NE
❑ ■ ❑ ❑
❑ ❑ ❑
❑ ❑ ■ ❑
Yes No NA NE
❑ ❑ ❑
❑ M ❑ ❑
❑ ❑ ❑
❑ ❑ M ❑
Yes No NA NE
■ ❑ ❑ ❑
® ❑ ❑ ❑
❑ ❑ ❑ M
Operations & Maintenance Yes No NA NE
Is the plant generally clean with acceptable housekeeping? 0 ❑ ❑ ❑
Does the facility analyze process control parameters, for ex: MLSS, MCRT, Settleable ❑ ■ ❑ ❑
Solids, pH, DO, Sludge Judge, and other that are applicable?
Comment: Samples collected by Arcadis and sent to TestAmerica and Pace
Permit
Yes
No
NA
NE
(If the present permit expires in 6 months or less). Has the permittee submitted a new
0
❑
❑
❑
application?
Is the facility as described in the permit?
0
❑
❑
❑
# Are there any special conditions for the permit?
❑
❑
❑
Is access to the plant site restricted to the general public?
M
❑
❑
❑
Is the inspector granted access to all areas for inspection?
0
❑
❑
❑
Comment:
Page# 4

WATER POLLUTION CONTROL SYSTEM OPERATOR DESIGNATION FORM (WPCSOCC)
NCAC 15A 8G .0201
Press TAB to enter information
Permittee Owner/Officer Name:
Email Address:
Permittee Signature:
Facility Name:
Date:
Permit #
SUBMIT A SEPARATE FORM FOR EACH SYSTEM CLASSIFICATION: SELECT ONE
ORC - OPERATOR IN RESPONSIBLE CHARGE
Print Full Name: Work Phone:
Certificate Type: Select
Email Address:
Signature:
Certificate Grade: Select Certificate #:
Effective Date:
"/ certify that i agree to my designation as the Operator in Responsible Charge for the facility noted. / understand and will abide by the
rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC
Print Full Name: Work Phone:
Certificate Type: Select
Email Address:
Signature:
Certificate Grade: Select Certificate #:
Effective Date:
"1 certify that/ agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so con result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Mail, fax or email
ORIGINAL to:
Mail or Fax a COPY to:
WPCSOCC, 1618 Mail Service Center, Raleigh, NC 27699-1618
Email: [e-mail] Fax: [phone]
Asheville
2090 US Hwy 70
Swannanoa, NC 28778
Fax:[phone]
Phone: [phone]
Washington
943 Washington Sq. Mall
Washington, NC 27889
Fax:[phone]
Phone:2S2-946-6481
Fayetteville
225 Green St., Suite 714
Fayetteville, NC 28301-5043
Fax:[phone]
Phone:[phone]
Wilmington
127 Cardinal Dr.
Wilmington, NC 28405-2845
Fax: [phone]
Phone: [phone]
Mooresville
610 E. Center Ave., Suite 301
Mooresville, NC 28115
Fax:[phone]
Phone:[phone]
Winston-Salem
45 W. Hanes Mill Rd.
Winston-Salem, NC 27105
Fax: [phone] Phone:
336-776-9800
Raleigh
3800 Barrett Dr.
Raleigh, NC 27609
Fax: [phone]
Phone: [phone]
Revised 1112020

Page 2
Facility Name:
BACKUP ORC
Permit #:
Print Full Name: Work Phone:
Certificate Type: Select Certificate Grade: Select Certificate #:
Email Address:
Signature: Effective Date:
"I certify that I agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC
Print Full Name: Work Phone:
Certificate Type: Select Certificate Grade: Select Certificate #:
Email Address:
Signature:
Effective Date:
"I certify that/ agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC
Print Full Name: Work Phone:
Certificate Type: Select
Email Address:
Signature:
Certificate Grade: Select Certificate #:
Effective Date:
"I certify that 1 agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
BACKUP ORC
Print Full Name: Work Phone:
Certificate Type: Select
Email Address:
Certificate Grade: Select Certificate #:
Signature: Effective Date:
"I certify that/ agree to my designation as a Back-up Operator in Responsible Charge for the facility noted. I understand and will abide by
the rules and regulations pertaining to the responsibilities of the ORC as set forth in 15A NCAC 08G .0204 and failing to do so can result in
Disciplinary Actions by the Water Pollution Control System Operators Certification Commission."
Revised 1112020