NC0086827_Draft Permit_20210607

dt,s STA7E°
ROY COOPER
er:--,j
Governor
DIONNE DELLI-GATTI `
Secretary ;fti,c. .'
S.DANIEL SMITH NORTH CAROLINA
Director Environmental Quality
June 07, 2021
Mr. David Grenoble
Brenntag Mid-South Inc
2000 E Petigrew St
Durham, N.C. 27703-4049
Subject: DRAFT NPDES PERMIT NC0086827
Brenntag/Durham Remediation
Grade I Phys. Chem.WPCS
[15A NCAC 08G.0306]
Durham County
Dear Mr. Grenoble:
Enclosed with this letter is a copy of the draft permit for your facility. Please review the draft very
carefully to ensure thorough understanding of the conditions and requirements it contains. Your
permit is among several in the Cape Fear River Basin that the Division has targeted for expedited
renewal.
This draft contains the following changes from the existing permit:
➢ Supplement to Cover Page—A DWR compliance inspection in April 2021 noted that
the two cation disposable filters were removed, as they did not aid in meeting permit
requirements. These components have been removed from the treatment components list
on the supplement to cover page.
> Facility Classification-The facility's classification was added above the effluent table.
> Tocicity Testing—Section A.(2.)was updated to include information for electronic
submittal of results.
> Electronic Reporting-The language in section A.(3.)has been updated to be consistent
with the finalization of federal requirements for electronic reporting.
> Bis(2-ethylhexyl)phthalate-The Division has reviewed your request to have bis(2-
ethylhexyl)phthalate removed from this permit. This parameter of concern was detected
twice during the last permit cycle. Bis(2-ethylhexyl)phthalate is known to be a
problematic analyte. Eurofins TestAmerica,the lab which analyzes this facilities samples,
flagged the results in both instances of detection for this compound to indicate that 1)the
detected result was less than the reporting limit but greater than the MDL, so the value
had to be approximated and 2)the compound was also present in the lab blank. All
"detections"have been low values,and may have also been false detections. This facility
has never exceeded the permit limit of 1.2 ug/L. The Division agrees with the removal of
the reporting requirement for bis(2-ethylhexyl)phthalate from this permit. The parameter
has been removed from the Effluent Limitations and Monitoring Requirements(A. (1.)).
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
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current permit. The latest version is available at https://bit.ly/2BZ4xxx 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 Durham County area, per EPA
requirements. Please provide your comments, if any, to me no later than 30 days after
receiving this draft permit.
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 via email at[[e-mail]] or call 919-707-9125.
Sincerely,
Lae_
Emily DelDuco Richards
Environmental Specialist II
NPDES Program
ec: NPDES files
Wilmington Regional Office
Page 2 of 2

Permit NC0086827
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 Environmental Management
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 Mid-South, Inc. Groundwater Remediation System
2000 East Pettigrew Street, Durham
Durham County
to receiving waters designated as Unnamed Tributary to Third Fork Creek in the Cape Fear River Basin
in accordance with effluent limitations,monitoring requirements,and other conditions set forth in Parts I,
II,III and IV hereof.
This permit shall become effective
This permit and authorization to discharge shall expire at midnight on April 30, 2026.
Signed this day
S. Daniel Smith
Director,Division of Water Resources
By Authority of the Environmental Management Commission
Page 1 of 7

Permit NC0086827
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:
I. continue to operate a groundwater remediation treatment system consisting of:
o influent flow meter
o bag filter
o air stripper unit with collection sump and blower
o transfer pump
o two(2)each GAC disposable filters
o effluent flow meter with totalizer
o effluent sample location
o discharge piping and outfall
this facility located at Brenntag Mid-South, Inc.groundwater remediation system(GW-REM),
2000 East Pettigrew Street, Durham, Durham County, and
2. discharge from said treatment works via Outfall 001, a location specified on the attached map,
into an unnamed tributary(UT)to Third Fork Creek [16-41-1-12-(1)], a waterbody currently
classified WS-V;NSW within subbasin 03-06-05 [HUC: 03030002] of the Cape Fear River
Basin.
Page 2 of 7

Permit NC0086827
Part I
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
[NCAC 02B.0400 et seq., 02B.0500 et seq.]
Grade 1 Physical Chemical Water Pollution Control System [15A NCAC 08G .0306]
Beginning on the effective date of this permit and lasting until expiration, the Permittee is authorized to
discharge treated groundwater from Outfall 001. Such discharges shall be limited, monitored, and
reported by the Permittee as specified below:
PERMIT LIMITS MONITORING REQUIREMENTS
EFFLUENT CHARACTERISTICS
[PARAMETER CODE] Monthly Daily Measurement Sample Sample
Average Maximum Frequency Type Location
Flow(MGD) 50050 0.0144 Instantaneous Recorder Effluent
Total Suspended Solids(TSS) 00530 30.0 mg/L 30.0 mg/L Monthly Grab Effluent
pH 00400 Not<6.0 or>9.0 s.u. Monthly Grab Effluent
Acetone 81552 2.0 mg/L Monthly Grab Effluent
Benzene 34030 Quarterly Grab Effluent
1,1 Dichloroethylene(1,1 DCE) 34501 Quarterly Grab Effluent
Tetrachloroethylene(PCE) 78389 Quarterly Grab Effluent
Toluene 34010 Quarterly Grab Effluent
Trichloroethylene(TCE) 39180 Quarterly Grab Effluent
Vinyl chloride 39175 Quarterly Grab Effluent
Total xylenes 81551 Quarterly Grab Effluent
Oil&Grease EPA 1664 00556 Quarterly Grab Effluent
[STG-HEM]
WET Testing 2 TGP3B Quarterly Grab Effluent
See
EPA Method 624/625 76028/ Annually Method Effluent
Table A.(1.)Footnotes:
1. The Permittee shall submit Monthly Discharge Monitoring Reports(DMRs)electronically using DWR's
eDMR electronic submittal system[See Section A. (3.)].
2. Whole Effluent Toxicity(WET)testing-Chronic Toxicity(Ceriodaphnia),P/F at 90%,January,April,
July,and October[See A.(2.)].Toxicity sampling shall be conducted concurrently with other parameter
sampling.
Condition:The Permittee shall discharge no floating solids or foam visible in other than trace amounts.
Page 3 of 7

Permit NC0086827
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 monitor at a minimum, quarterly 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 electronically using the
Divisions eDMR system 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:
Attention: North Carolina Division of Water Resources
Water Sciences Section/Aquatic Toxicology Branch
1623 Mail Service Center
Raleigh, NC 27699-1623
Or,results can be sent to the email, [e-mail].
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 based on the toxicity
Page 4 of 7

Permit NC0086827
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)l
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
1617 Mail Service Center
Page 5 of 7

Permit NC0086827
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-po l lutant-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. 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
Page 6 of 7

Permit NC0086827
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. Si2natory Requirements [Supplements Section B. (11.) (b) and Supersedes Section B. (11.) (d)I
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

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Brenntag Mid-South, Inc. Facility : *1111F)
BrenntagMid-South GW-REM, Durham Location
(not to scale)
State Grid/USGS Quad: D23NW/SW Durham,NC
Receiving Stream: UT to Third Fork Creek[segment 16-41-1-12-(1)]
Latitude: N 35°58'35" HUC: 03030002 NPDES Permit NC0086827
Longitude: W 78°52'58" Drainage Basin: Cape Fear River
Sub-Basin: 03-06-05 Stream Class: WS-V;NSW North Durham County
1