NC0086827_NOV-2021-LV-0388 Response_20210630

ARCADIS
Design & Consultancy
for natural and
built assets
Mr. Scott Vinson
North Carolina Department of Environmental Quality
Division of Water Resources
3800 Barrett Drive,
Raleigh, North Carolina 27609
Subject:
Response to Notice of Violation, Brenntag Mid -South Facility, 2000 East Pettigrew
Street, Durham, North Carolina
NPDES Permit No. NC0086827
Durham County
Dear Mr. Vinson:
Arcadis G&M of North Carolina, Inc. (Arcadis), on behalf of Brenntag Mid -South,
Inc. (Brenntag) is submitting the following additional information in response to the
Notice of Violation (NOV) dated May 26, 2021. We apologize for the delay in
submitting this response, but the NOV letter was only recently found.
As indicated in the NOV, the acetone concentration reported for the effluent sample
collected on March 30, 2021, was 12.0 parts per million (ppm) which exceeded the
permit limit of 2.0 ppm. We think that this discharge limit exceedance resulted from
high influent concentrations of acetone due to the system being shut down for 3
months, and from a malfunction of the air stripper. As soon as we learned of the
discharge limit exceedance, we inspected the system to determine if all components
were operating correctly. It was determined that the wire mesh demister pad in the
air exhaust stack was no longer working properly and limiting air flow through the
air stripper. We replaced the wire mesh demister pad to improve air flow through the
air stripper.
Subsequent NPDES sampling events conducted on April 29, 2021, and May 26,
2021, indicated that the air stripper was effectively stripping the acetone from the
extracted groundwater. The acetone concentrations in the effluent samples for those
two NPDES sampling events were .30 ppm and .56 ppm, respectively.
We have implemented monthly inspections of the wire mesh demister pad to limit the
potential for this situation to occur again.
Arcadis G&M of North Carolina,
Inc.
5420 Wade Park Boulevard
Suite 350
Raleigh,
North Carolina 27607
www.arcadis-us.com
ENVIRONMENTAL
Date:
June 30, 2021
Contact:
Jim Shilliday
Phone:
919-415-2302
Email:
[e-mail]
Our ref:
30065852.03

AARCADIS
If you have any questions regarding the information in this letter, please contact me
at your next convenience.
Sincerely,
Arcadis G&M of North Carolina, Inc.
Jim Shilliday, L.G.
Project Manager
Copies:
David Grenoble (Brenntag)
Rob Walston (Brenntag)
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