NC0078000_Permit Issuance_20110914

XX
MDEENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Govemor
Coleen H. Sullins
Director
September 14, 2011
Bruce Biehl, Director of Regulatory Affairs
Brenntag Southeast, Inc.
2000 East Pettigrew Street
Durham, North Carolina 27703
Subject:
Dear Mr. Biehl:
Dee Freeman
Secretary
Issuance of NPDES Permit NCO078000
Brenntag Greensboro GW REM, Class 1
2 HCI Boulevard
Guilford County
The Division of Water Quality (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. .
We understand that you have made no significant changes to your existing treatment facilities. Therefore,
except for toxicity testing (see below), the Division has made only minor changes to your permit to include
upgrading your facility description and facility map. We have also added parameter codes to the permit
effluent page for your convenience [see Section A. (1.)]. Finally, please note that since last renewal, your
discharge receiving stream, an unnamed tributary (UT) of Buffalo Creek, has been reclassified from C;
NSW to WS-V; NSW, Water Supply; Nutrient Sensitive Waters.
Change in the Receiving -Stream Minimum Flow — Historically, the minimum summer flow rate in the
unnamed tributary (UT) to Buffalo Creek approximated 1.2 cubic feet per second (s7Q 10 =1.2 cfs). This
flow rate was used to establish previous permit limits and monitoring conditions. However, more recent
stream -flow data, including extended drought conditions, have caused the USGS to reduce this minimum
flow to 0.0 cfs, designating this UT a "zero -flow" stream (s7Q 10 = 0.0 cfs).
Changes to Your Permit Draft / Whole Effluent Toxicity (WET) Testing — Following recent discussions
during the draft review process with your authorized consultant, Jim Shilliday (ARCADIS), the Division
has updated the permit requirements for WET testing. Previous permits (since 1996) required WET testing
at 22% effluent concentration, however based on statewide policy for discharges to zero -flow streams, all
future WET tests must be conducted at 90% effluent concentration.
While compliance to this change begins with the permit effective date, the Division has included a
compliance grace period of approximately 180 days. The Division will not assess civil penalties for WET
'test failures until after February 29, 2012 [see footnote, permit Section A. (1.)]. If you have questions
about WET Testing, please contact Cindy Moore (919-743-8442) at the Division's Aquatic Toxicology
Unit.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service:1-877-623-6748
Internet: www.ncwaterquality+.org
Noe Carolina
A74(raliff
An Equal Opportunity % Affirmative Action Employer

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 Quality. 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 Quality, 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 assistyou, please contact Joe Corporon at
fioe.corooronC&ncdenr.govl or call [phone].
R ly,
Coleen H. Sullins
pFWATF9
D'Og
Enclosure: NPDES Permit NC0078000 (FINAL) o i
hc: Central Files
NPDES Program Files
ARO/SWPS, Attn: Corey Basinger
ec: CG&L Attn: Kim Colson
Aquatic Toxicology Unit, Attn: Susan Meadows / Cindy Moore

Permit NCO078000
STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
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 Southeast, Inc.
is hereby authorized to discharge wastewater from a facility located at
Groundwater Remediation WWTP
Greensboro Site, 2 HCI Boulevard
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 October 1, 2011.
This permit and the authorization to discharge shall expire at midnight on May 31, 2016.
Signed this day September 14, 2011.
Cole . Sullins, Director v
Di 'sion of Water Quality
By the Authority of the Environmental Management Commission

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 Southeast, 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 of the Cape Fear River
Basin.

A4�
I

Permit NCO078000
A. (1.) EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
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 and monitored by the Permittee as specified below:
EFFLUENT sue=s7
�S
S
, IYlonthIY
�'�'
s eeklx,
%�.
{Daly }
`k ��Hbi�"T�8-
1 Ieasurement
,Sample.
r r? Sample =,
CHARACT' RI�STICS ��
C'14Y....
a,.t
[Palarimet:,Co es]'
µ► AveraQQp°�, <r
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t�Fre :uenc Y
at a
TYP
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Flow
Influent or
0.216 MGD
Continuous
Recording
50050
Effluent
PH
Not < 6.0 nor > 9.0 standard Units
Monthly
Grab
Effluent
00400
Toluene
Quarterly
Grab
Effluent
34010
Benzene
Quarterly
Grab
Effluent
34030
Trans 1,2 Dichloroethene
Quarterly
Grab
Effluent
34546
Trichloroethene
Quarterly
Grab
Effluent
78391
Chronic Toxicity
Quarterly
Grab
Effluent
TB?3B
Footnotes:
1. Sampling shall be concurrent, collected in conjunction with toxicity sampling.
2. Chronic Toxicity (Ceriodaphnia dubia) P/F at 90%; samples to be collected during
January, April, July, and October [see Special Condition A. (2)]. Compliance with
Pass/Fail at 90% to commence after February 29, 2012.
Condition: The Permittee shall discharge no floating solids or foam.

Permit NCO078000
A. (2.) CHRONIC TOXICITY - PERMIT LIMIT (QUARTERLY)
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, guarteLly monitoring using test procedures outlined in the "North
Carolina Ceriodaphnia Chronic Effluent Bioassay Procedure," Revised February 1998, or subsequent versions or
"North Carolina Phase II 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.
t�

D.
1
ron, Joe
�F: EK 1 6,1". 5h, (/iJ ,
From: Shilliday, Jim [[e-mail]]
Sent: Wednesday, September 07, 2011 11:46 AM
To: Corporon, Joe
Cc: Hennessy, John
Subject: RE: NPDES Permit Final for Brenntag / Greensboro NCO078000
Attachments: Initial USGS response concerning... Re: 7Q10 flow estimate for unnamed tributary to South
Buffalo Creek, Greensboro, NC
Joe,
Based on the information provided by the USGS in the attached e-mail dated 8/22/11, it appears that a zero flow 7Q10
designation for the stream that receives our discharge is a default designation. However, I don't see that further
evaluation would likely change that designation. It appears that the proposed increase in effluent concentration for
WET tests is consistent with a zero flow designation for our stream.
Thanks,
Jim
From: Corporon, Joe [mailto:[e-mail]]
Sent: Tuesday, September 06, 2011 12:33 PM
To: Shilliday, Jim
Cc: Hennessy, John
Subject: FW: NPDES Permit Final for Brenntag / Greensboro NCO078000
Mr. Shilliday — We have not heard from you since 12Aug, nor received documentation from the USGS altering the
published receiving -stream low -flow designation (s7Q10 = 0.0 cfs). The Division has no alternative but to correct the
draft permit as previously noted. We will therefore proceed with issuance of the permit final.
Please note that all Whole Effluent Toxicity (WET) tests conducted after the permit effective date shall be tested at 90%
effluent concentration in accord with state and federal regulations. We regret any inconvenience this may cause your
client or your organization.
Thanks for your continued cooperation.
Respectfully,
JoeR. Corporon, L.G.
Environmental Specialist
NPDES Program
NCDENR/Division of Water Quality (DWQ)
Surface Water Protection Section
919-807-6394; FAX [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.

From: Corporon, Joe
Sent: Friday, August 12, 20113:14 PM
To: Shilliday, Jim
Cc: Hennessy, John
Subject: RE: NPDES Permit Final for Brenntag / Greensboro NC0078000
Jim -WET testing is bound by rule to the 7Q10 [the lowest consecutive 7-day flow in any 10-year period]. What may
resolve this issue immediately is written confirmation of change from J. Curtis Weaver (USGS). In the past the Division
relied on his official stream -flow data, but the State can no longer afforded this service. However, you may contact Mr.
Weaver directly and ask him to verify jfor a small fee, I understand] — perhaps the stream designation has changed.
Secondly, a question: Are you sure you cannot pass TOX @ 90%?
Permit final issuance on hold pending further discussion.
Thanks.
From: Shilliday, Jim [mailto:[e-mail]]
Sent: Friday, August 12, 20118:06 AM
To: Corporon, Joe
Cc: Hennessy, John; Moore, Cindy; Pinnix, Alan; [e-mail]
Subject: RE: NPDES Permit Final for Brenntag / Greensboro NC0078000
Mr. Corporon,
We reviewed the USGS topographic map for this site (see attached map) and determined that the stream that receives
discharge from our groundwater treatment system is a perennial stream which receives water from a fairly sizable
drainage basin. Based on the information on the topographic map, it appears that the drainage basin that feeds into this
steam extends upgradient from the site approximately 1.5 miles and is approximately 0.5 miles wide. We have been
sampling at this site since 2002 and have always observed flow in the stream. At times the flow is quite significant.
don't think that this stream should be considered a zero -flow stream under the s7Q10 designation, but I cannot say with
absolute certainty that zero flow at s7Q10 doesn't occur. Can you tell me how you arrived at that designation? I think
the original sample dilution requirements of 22% effluent was established because of the amount of flow that is
occurring in this stream.
It may be beneficial to have a call to discuss.
Thanks,
Jim
From: Corporon, Joe[mailto:][e-mail]]
Sent: Tuesday, August 09, 20112:56 PM
To: [e-mail]
Cc: Shilliday, Jim; Hennessy, John; Moore, Cindy
Subject: NPDES Permit Final for Brenntag / Greensboro NC0078000
Mr. Biehl —
DWQ has discovered an error in your draft NPDES permit related to chronic Whole Effluent Toxicity (WET) testing. We
wish to correct this error.

It appears, for these past many years (since 1991), your permit has required you to WET test at an effluent
concentration of 22%. However, under zero -flow receiving -stream conditions (s7Ct10 = 0.0 cfs), your summer discharge
constitutes the bulk of the receiving stream, thereby offering no dilution [Instream Waste Concentration (IWC) =100 90].
Typically these receiving -stream conditions mandate a WET test at 90% effluent concentration.
It is our intent therefore, to correct this error before issuing the permit final. In future you will be required to test for
toxicity quarterly at 90% concentration consistent with similar NPDES permits statewide. We regret any inconvenience
this may cause your ongoing groundwater remediation project.
We will hold final issuance of the subject permit pending your acknowledgement of this correspondence. Thanks for
your patience and consideration.
Respectfully,
Joe R. Corporon, L. G.
Environmental Specialist
16) NPDES Program
NCDENR/Division of Water Quality (DWQ)
Surface Water Protection Section
919-807-6394; FAX [phone]
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to
third parties.
NOTICE: This e-mail and any files transmitted with it are the property of ARCADIS U.S., Inc. and its affiliates. All rights,
including without limitation copyright, are reserved. The proprietary information contained in this e-mail message, and any
files transmitted with it, is intended for the use of the recipient(s) named above. If the reader of this e-mail is not the
intended recipient, you are hereby notified that you have received this e-mail in error and that any review, distribution or
copying of this e-mail or any files transmitted with it is strictly prohibited. If you have received this e-mail in error, please
notify the sender immediately and delete the original message and any files transmitted. The unauthorized use of this e-
mail or any files transmitted with it is prohibited and disclaimed by ARCADIS U.S., Inc. and its affiliates. Nothing herein is
intended to constitute the offering or performance of services where otherwise restricted by law.

A, *A
' ! MCDE NR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Govemor Director Secretary
-----------------------------------------------------------------------------------------------------------------------------
May 24, 2011
MEMORANDUM
To:
Lisa Edwards, W-SRO/ DEH
Winston-Salem Regional Office
From:
Joe R. Corporon, L.G.
DWQ/NPDES
Subject:
Review of Discharge to Waters Classified WS-V; NSW
Brenntag Southeast, Inc.
Groundwater Remediation (GW REM)
Greensboro WWTP (0.216 MGD—Class 1)
NPDES Permit NCO078000
2 HCI Boulevard, Greensboro
Guilford County
Please review and provide your comments [email OK].
RESPONSE:
I have reviewed the draft permit and determined that.the proposed discharge is not located
sufficiently close to any existing or known proposed public water supply intake so as to create an
adverse effect on water quality. The DEH concurs with the issuance of this permit provided the
Permittee properly operates and maintains the facility; the Permittee meets the stated effluent limits
i
i
prior to discharge; and the discharge does not contravene the designated water quality standards.
I concur with issuance of the above permit provided the following conditions are met:
I oppose the issuance of the above permit based on reasons stated below, or attached:
Signed:
Date.
cc: file
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St Raleigh, North Carolina 27604 One
Phone: 919 W-63001 FAX: 9IM07-64921 Customer Service:1-877.623.6748 Noi-thCarohna
Internet tNwuv.nawaterquality.org Adwrally
An Equal Opportunity % Affirmative Action Employer

News & Record
North Carolina, Guilford County
Published by
News & Record, Inc.
Greensboro, North Carolina
AFFIDAVIT OF
Before the undersigned, a Notary Public of said County and State, duly commissioned, qualified and authorized by law to
administer oaths, personally appeared the Publisher's Representative who being first duly sworn, deposed and says:
1. That he/she is the Publisher's Representative of the Greensboro News & Record, Inc. a corporation, engaged in the
publication of newspapers known as "News & Record", published, issued and entered as second class mail in the City of
Greensboro in said County and State.
2. That he/she is authorized to make this affidavit and sworn statement; that the notice or other legal advertisement,
a copy of which is attached hereto, was published in the News & Record on the dates listed below.
3. That the said newspaper (or newspapers) in which such notice, paper, document, or legal advertisement was published
was, at the time of each and every such publication, a newspaper meeting all of the requirements and qualifications of
Section 1-597 of the General Statutes of North Carolina and was a qualienewspaper i hin the meaning of Section 1-59;
of the General Statutes of North Carolina. \\\�tltll I I I II///// '
Publisher's Representative `\`��P PNNE
Z �pTARy
Sworn to and subscribed before me, this day o , 2011 _ My Comm. Exp.
6H5/20114 U—
PUBOG
Notary Public-/'//o/II Dco
Name Ad # Date Edition Class PO Ad Cow
NCDENR DWQ NPDES 34257299 (05127/1& Record 400 2 CHI Blvd Public NoticeNorth Carolina Environmenta

Ad ID 134257299 Date 05/25/2011 Time 3:48 PM
Public Notice
North Carolina Fnvimnnental
Managenerrt CormonrNPDES
Unit
1617 Mail 5er%ke Center
flak' %NC 27699-1617
Notts of I nt to Issue a NPDB
Wasteseter Perm[
The North Camlina ErMmnmenbl
Management Co.... on proposes
to issue a NPDESwastevvater
disdsange pernfttotfe person(s)
listed below
Written mmrens regaidingthe
proposed permit wit be a¢epted
until 30 days after the publsh date of
this wtine. The Director of the NC
Divkon of Wafer Quality (D\P4) Trey
hold a pubk hearing should there be
a signif lant degree of pubk interest
Please rrei mmrerRs andor
infonrsat , , mmss to DWQ at the
information on NPDE5 pemits and
this notice rYW be found on our
websb:
fmpf/portaLnadenrorglve wp/p
s/npdeskalerdir, or b7 calling 19)
B 6304
Bwntaq Southeast Inc, Durham
apple to renew permit NQ707B000,
m dischaated gmundwaer
fmm2 Cr,NBF4 Greensbom Guifford
County, to a UT of South Buffalo
Creek, Cape Fear Rher Basin.
Ad shown is not actual print size

DENR/DWQ
COMPLEX -EXPIDITED FACT SHEET
FOR NPDES PERMIT DEVELOPMENT
NPDES NCO078000
Facility Information
Applicant/Facility Name:
Brenntag Southeast, Inc. GW Remediation Site
Applicant Address:
2000 East Pettigrew Street; Durham, NC 27703
Facility Address:
2 HCI Boulevard; Greensboro, NC 27409
Permitted Flow
0.216 MGD
Type of Waste:
Treated groundwater (GW remediation of chlorinated and non -
chlorinated organic solvents — DCE, TCE)
Facility Class/Permit Status:
Class 1 / 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 Corporon
Subbasin:
03-06-02
Date:
13May2011
Drainage Area (mi'):
1.34
Lat. N 360 03' 52" Long. W79° 52' 37"
Summer 7 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 located at its Greensboro
site. This is the former Worth Chemical Corporation site, which became known as Brenntag following a
merger of the two companies in 2001. GW contamination resulted from spills to the former Worth Chemical's
containment pond (the pond has been cleaned and filled for many years). GW contaminants include chlorinated
and non -chlorinated organic solvents. This Groundwater Remediation System (GW REM) ran continuously
during the previous permit cycle (2006-2011) except for 29 consecutive days during March and April of 2006.
Annual average flow rates are presented herein (Table 2), disregarding assumed reporting error "0.4047 MGD"
[likely 0.04047 MGD], reported on November 15, 2007.
Receiving Stream — This UT to South Buffalo Creek has been reclassified since the last renewal from C-NSW
to Water Supply (WS-V; NSW). The defining waterbody — the upper portion of South Buffalo Creek (from the
headwaters to McConnell Road) is not impaired. The lower portion of this stream segment however is impaired
(303d listed), but the stream -impairment begins on South Buffalo Creek some 12 or more river miles
downstream of the subject outfall [for details on impairment, see portion of 303d list, 2010 (draft), attached].
Fact Sheet
NPDES NCO078000
Renewa12011
Page 1

FILE REVIEW / COMPLIANCE SUMMARY
Reasonable Potential Analyses (RPA) - Flow history, averages, and maximums, are summarized in
Table 2. DMR data were reviewed from January 2006 through March 2011. Throughout this period, the
Permittee reported no parameter limit exceedances - no parameter detected above its method -detection limit.
Table 2. Flow Summary Jan2006 thru March2011
YEAR
Samples
(n)
AVERAGE
FLOW (MGD)
MAXIMUM
FLOW (MGD)
2006
363
0.044
0.057
2007
365
0.045
0.055
2008
365
0.043
0.084
2009
365
0.044
0.0595
2010
365
0.046
0.061
2011
59
0.045
0.0497
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 @ 22% (Jan., Apr., July, Oct.).
This facility has not failed a toxicity test during the
past two permit cycles — ne-ehm eiaended
9EE
Table 3. DMR Review Summary — Jan2006 thru March 2011
Parameter
Samples
n
Hits
n
Comments / Action
Benzene
18
0
Not detected; no change to permit
Toluene
36
0
Not detected; no change to permit
DCE Trans 1, 2 Dichloroethenel
19
0
Not detected; no change to pennit
TCE [Trichloroethenel
21
0
Not detected; no change to permit
Chronic Toxicity
21
0
Not detected; no change to permit
pH
64
MAX = 8.27 s.u.; Min = 6.7 s.u.
no change to permit
SUMMARY OF PROPOSED CHANGES
Updated facility description (see Supplement to Cover Sheet) and facility map; stream classification;
added parameter codes to effluent page.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE
Draft Permit to Public Notice: May 25, 2011
Permit Scheduled to Issue: July 5, 2011
If you have qu tions eg in any of the above information or on the attached permit, please contact
Joe Corporo 919- 7- 94.
NAME: 1 DATE:
6/�
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All Waters in NC are in Category
AU —Number AU —Name
Parameter
5-303(d Li or Mercury due to statewide fish consumption advice for several fish species
AU_Description LengthArea AU_Units Classification
Reason for Rating Use Category Collection Year 3030hcar
QQ 16-11-14-1a2 North Buffalo Creek From Philadelphia Lake to North Buffalo
Creek WWTP
5 Ecological/biological Integrity Benthos Poor Bioclassification Aquatic Life
QQ 16-11-14-1b North Buffalo Creek
5 Copper
5 Zinc
16-11-(1)b
Reedy Fork
5 EcologicaVbiological Integrity FishCom
Q 16-11-(9)b Reedy Fork(Hardys
L Mill Pond)
�( e\1Fecal Coliform (recreation)
ZWe
1.6 FW Miles C;NSW
1998 2008
From North Buffalo Creek WWTP to Buffalo 8.1 FW Miles C;NSW
Creek
Standard Violation Aquatic Life 2008 2008
Standard Violation Aquatic Life 2008 2008
From SR 2128 to a point 0.4 mile 4.2 FW Miles WS-III;NSW
downstream of Moores Creek
Fair Bioclassification Aquatic Life 2004 2006
From Buffalo Creek to Haw River 8.6 FW Miles QNSW
Standard Violation
Recreation
2008
2004
Standard Violat on
Aq tic Life
2008
2008
b South Buffalo C ek
from McConnell d to US 70
4.7 Miles
C;NSW
,16-11-14-
W 5 Ecologi Ubiological Integrity FishCo
Poor Bioclassification Aquatic 'fe
2003
1998
Q
16-11-14-2c South Buffalo Creek
From US 70 to Buffalo C ek
4.8 FW Mile
C;NSW
5 Copper
andard Violation Aquatic Life
2008
O8
5 Zinc
Standard Violation Aquatic Life
2008
2008
Q
16-11-5-1-(2) Unnamed Tributary
From dam at Guilford College bathing lake
1.3 FW Miles
WS-III;NSW
at Guilford College
to Horsepen Creek
5 Ecological/biological Integrity Benthos
Poor Bioclassification Aquatic Life
2001
2006
Cape Fear River Basin
Headwaters Haw River
Watershed 0303000202
16-(1)a HAW RIVER
From source to SR 2109
7.8 FW Miles
C;NSW
5 EcologlcaVbiological Integrity Benthos
Fair Bioclassification Aquatic Life
1998
2000
Q
16-(1)b HAW RIVER
From SIR 2109toSR2426
12.5 FW Miles
C;NSW
5 Copper
Standard Violation Aquatic Life
2008
2008
Q
16-7a Little Troublesome
From source to Reidsville WWTP
3.5 FW Miles
C;NSW
Creek
5 EcologicaVbiological Integrity Benthos
Fair Bioclassification Aquatic Life
1994
2000
Q.
16-6-(3) Troublesome Creek
From dam at Lake Reidsville to Haw River
1.8 FW Miles
QNSW
5 Lon Dissolved Oxygen
Standard Violation Aquatic Li fie
2008
2010
Cape Fear River Basin
Creek
Watershed 0303000203
�j yf]�BigAllamance
kcir �lgbCl
NC
2010 Integrated Report Category 5-303(d) List EPA 5ubrn
tal 20100329 Monday, March 29, 2010
Page 4 of 115

rlci l �J FEW tti�F
IWC Calculations �J
9-Aug-11 rv-
Brentag GW-REM
ac
NC0078000d�
Prepared By: Joe Corporon, NPDES Program
Enter Design Flow (MGD): 0.044 [actual flow - 5-year average - 2006-2011]
Enter s7Q10(cfs): 0
Enter w7Q10 (cfs): 0.09
Residual Chlorine Ammonia (NH3 as N)
(summer)
7Q10 (cfs) 0 7Q10 (CFS) 0
DESIGN FLOW (MGD) 0.044 DESIGN FLOW (MGD) 0.044
DESIGN FLOW (cfs) 0.0682 DESIGN FLOW (cfs) 0.0682
STREAM STD (ug/L) 17.0 STREAM STD (mg/1-) 1.0
UPS BACKGROUND LEVEL (I 0 UPS BACKGROUND LEVEL (mg/L) 0.22
IWC (%) 100.00 IWC (%) 100.00
Allowable Conc. (ug/1) 17 Allowable Conc. (mg/1) 1.0
Ammonia (NH3 as N)
(winter)
7Q10 (CFS) 0.09
Fecal Limit 200/100ml DESIGN FLOW (MGD) 0.044
(If DF >331; Monitor) DESIGN FLOW (cfs) 0.0682
(If DF <331; Limit) STREAM STD (mg/L) 1.8
Dilution Factor (DF) 1.00 UPS BACKGROUND LEVEL (mg/L) 0.22
IWC (%) 43.11
Allowable Conc. (mg/1) 3.9
Servor/Current Versions/IWC
8/9/2011

0 ARCADIS
Infrastructure, buildings, environment. communications
Mrs. Dina Sprinkle
NCDENR
Division of Water Quality
Point Source Branch
1617 Mail Service Center
Raleigh, NC 27699-1617
subject:
NPDES Permit Renewal Application, Groundwater Remediation System, Brenntag
Southeast, Inc., (Former Worth Chemical Facility), Greensboro, North Carolina.
NPDES Permit No. NCO078000
Dear Mrs. Sprinkle:
On behalf of Brerl Southeast, Inc. (Brenntag Southeast), 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 Southeast facility (formerly 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. Other items enclosed with this letter in support of
the NPDES permit renewal application include: a copy of the October 2010
Discharge Monitoring Report (Attachment A) which summarizes the most recent
analytical data for the system effluent; a USGS topographic map of the project area
that depicts the location of the system outfall (Figure 1); and a site map that depicts
the route of the treated water to the discharge point (Figure 2).
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.
ARCADIS G&M of North Carolina,
Inc.
801 Corporate Center Drive
Suite 300
Raleigh,
North Carolina 27607-5073
Tel [phone]
Fax [phone]
v .arcadis-us.com
ENVIRONMENTAL
Date:
November 23, 2010
Corxect:
Jim Shilliday
Extension:
246
E-mail:
jshilliday@arcadis-
us.com
Our ref:
NC102030.0010
Part of a bigger picture

ARCADIS
If you have any questions regarding the information presented in the NPDES permit
application or any of the supporting material, please call us at [phone].
Sincerely,
ARCADIS G&M of North Carolina, Inc.
��Z-
�
E. Shilliday, III, L.G.
>al Scientist/Project Man er
copies:
Mr. Bruce Biehl, Brenntag Southeast, Inc.
Mr. Bill Mesar, Brenntag Southeast, Inc.
File
C:IENNWah CNam reen m Fa ARMC10E0]O.WMPCES Pe l Renewal Appllullon\Cae> LNlttlor NPNES Pem Renewaltl
Page:
2/2

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
Mail the complete application to:
N. C. Department of Environment and Natural Resources
Division of Water Quality / NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
NPDES Permit Number NCO078000
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 Southeast, Inc.
Mailing Address
2000 East Pettigrew Street
City
Durham
State / Zip Code
North Carolina 27703
Telephone Number
[phone]
Fax Number
[phone]
e-mail Address
[e-mail]
2. Location of facility producing discharge:
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 fu7n, consultant or other entity that operates the facility. (Note that this is not referring to the
Operator in Responsible Charge or ORC)
Name ARCADIS
Mailing Address 801 Corporate Center Drive, Suite 300
f i
City Raleigh
State / Zip Code North Carolina 27607
Telephone Number [phone] F, u
Fax Number [phone]
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.
5. Products recovered:
Gasoline ❑ Diesel fuel ❑ Solvents ® Other chlorinated and
nonchlorinated solvents
6. Number of separate discharge points: 1
Outfall Identification number(s) 001
7. Frequency of discharge: Continuous ® Intermittent ❑
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 outfcdl, including
Latitude and longitude):
Unnamed Tributary to South Buffalo Creek
36 03 51.92N
79 52 37.38W
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 reneuxds):
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
v 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.
Page 2 of 3 C-Gw 03105

NPDES PERMIT APPLICATION - SHORT FORM C - GW
For discharges associated with groundwater treatment facilities.
13. Applicant Certification
I certify that I am familiar with the information contained in the application and that to the
best of my knowledge and belief such information is true, complete, and accurate.
Bruce Biehl Director of Regulatory Affairs
Printed name of Person Signing Title
Signature of Applicant
Date
1 l LZ;2
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
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,
for a similar offense.)
Page 3 of 3 C-GW 03105

QUADRANGLE LOCATION N
SCALE 1:24000
0 2000 4000
SOURCE: TOPOGRAPHY TAKEN FROM USGS 7.5 MINUTE QUADRANGLE
GUILFORD AND GREENSBORO, NC MAPS
1951 AND PHOTOREVISED IN 1994
ARCADIS �g� °,2�°��rOrie,
Infrastructure buildings, environment communications
REV. DRAWING DATE: ACAD FILE:
1/9/O6
SITE LOCATION MAP
:NT: BRENNTAG SOUTHEAST, INC. PM: is
:ATION: 2 HCl BOULEVARD PE/RG:
GREENSBORO,NC
IIGNED: DETAILED: PROJECT NO: FIGURI
CJK I I NC102030.0010 1

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