NC0086827_Review of Engineers Alternatives Analysis_20090202

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director Dee Freeman
Secretary
February 2, 2009
Mr. Bruce Biehl
Brenntag Southeast Inc.
2300 East Pettigrew Street
Durham, NC 27702
Subject: Review of Engineers Alternatives Analysis
Brenntag Southeast, Inc.
Discharge to Unnamed Tributary to Third Ford'Creek
Durham County
Dear Mr. Biehl,
This letter concerns issues discussed with you and your representatives in our meeting on January 30, 2009
concerning the Engineers Alternatives Analysis submitted by ARCADIS on the behalf of Brenntag Southeast,
Inc dated November 5, 2008. The submittal was submitted in response to the Notice of Violation from this
office dated June 23, 2008 and a subsequent meeting with your representatives on August 19, 2008.
As we discussed in the meeting, there are still concerns/constraints with: 1) co-mingling of process water and
stormwater, 2) volume(s) of stormwater that is conveyed to the treatment units, 3) sample data from the facility
indicates that the discharge would not consistently meet the requirements of a stormwater permit without
treatment, and 4) there are regulatory constraints with respect to using stormwater permitting mechanism to
address wastewater and process control/wastewater treatment units (e.g. pH adjustment and aeration).
It is the Raleigh Regional Office position that the facility has an existing illegal (unpermitted) treatment unit,
and wastewater discharge. This facility, a bulk chemical re-distribution facility, is required to have an
Individual Stormwater permit. Currently, the aeration basins are installed in series and do not appear to be
properly engineered for the flow volumes that these units episodically receive.
You indicated in the meeting, your intention to separate out the process water and other contaminated water
from the stormwater and possibly pursue connection to the City of Durham of the process wastewater that is
currently being pumped and hauled. Accordingly, it is the RRO recommendation that you seek out a Special
Order by Consent (SOC) to allow the facility to pursue compliance with requirements for permitting activities
on site while an enforceable compliance schedule is in place. This tool (SOC) will allow Brenntag to develop
and implement an organized approach to affecting full compliance.
•
One
Npr Carolina
,Naturally
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone[phone] Customer Service
Internet: www.ncwaterquality.org 1628 Mail Service Center Raleigh,NC 27699-1628 FAX [phone] 1-877-623-6748
An Equal Opportunity/Affirmative Action Employer—50%Recycled/10%Post Consumer Paper

Mr. Biehl
Page 2
Components of this SOC would minimally include the following:
-Planning/Investigation
-Stormwater Pollution Prevention Plan(SP3)
-Stormwater monitoring to include minimally, pH, BOD, metals and organics
-Process Water monitoring to include minimally,pH, BOD, metals and organics
-Treatment unit monitoring to include minimally,pH, BOD, metals and organics
-Discharging treatment unit monitoring
-Documentation of Pump and Haul Activities: to include storage control status, storage volume records,pump
and hauling records, and destination.
-Construction with specific dates to complete portions of the project
Attached is an application with directions for submittal. Please respond to this correspondence within February
23, 2009 with your SOC application. Thank you for your attention to this matter. Also, we will be glad to meet
with you and your representatives to discuss requirements that will be placed in the SOC.
Should you have any questions regarding these matters,please contact Mandy Hall or myself at(919) 791-4200.
Sincerely
5T, /Jo( GCG-7/92
S. Daniel Smith
Water Quality Regional Supervisor
cc: DWQ Raleigh Regional Office File Copy
Matt Mathews—NPDES Permitting Branch
Gil Vinzani-NPDES Permitting
Representative Paul Luebke, Sate Legislative Blg.,
300 N. Salsisbury ST. Room 529, Raleigh NC 27603-5925
Patrick Butler—RRO Air Quality
John Cox, City of Durham Stormwater
Bradley Bennett- Wetlands and Stormwater Branch