NC0086827_Contaminated Groundwater Emails_20080228

[Fwci:Contaminated groundwater at Brenntag SE in Durham]
Subject: [Fwd: Contaminated groundwater at Brenntag SE in Durham]
From: Matt Matthews<[e-mail]>
Date: Thu, 28 Feb 2008 16:39:58 -0500
To: Gil Vinzani <[e-mail]>
FYI
Original Message
Subject:Contaminated groundwater at Brenntag SE in Durham
Date:Thu, 28 Feb 2008 16:21:33 -0500
From:Cox,John <[e-mail]>
To:Charlotte Jesnick<[e-mail]>
CC:Matt Matthews <[e-mail]>, Bradley Bennett<[e-mail]>,
Mack Wiggins<[e-mail]>, Danny Smith <[e-mail]>,Tom
Reeder<[e-mail]>, <[e-mail]>, Dexter Matthews
<[e-mail]>,Woolfolk, Michelle<[e-mail]>
Charlotte,
I have been advised that the Superfund Inactive Sites Branch address issues that may be related to groundwater
contamination from prior use.
This is to request the participation of your branch regarding a complex set of issues regarding the Brenntag
Southeast facility located at 2000 East Pettigrew Street, Durham, NC. The Pettigrew Street facility receives acids,
caustics,and organic chemicals by railcar for storage, repackaging and shipment elsewhere. The City of Durham
Stormwater Service Division has been working with Brenntag and its consultants for several years on multiple
issues. One of the most intractable issues has been contaminated groundwater that has been seeping into
underground stormwater piping at the facility. This groundwater-together with any associated stormwater-is
collection in a series of containment basins at the site. Attached sampling by Brenntag's consultants indicates that
the water in the containment basins had a BOD of 180 mg/I,which is nearly that of raw sewage. Discharge of this
water has been contaminating the channel downstream.
For the last several months Brenntag has been hauling the containment water offsite for treatment and disposal.
A contractor has been installing chemical resistant liner in the stormwater piping system to limit the entry of
contaminated groundwater into the underground stormwater piping. With the completion of the lining,
contaminated groundwater may no longer be leaving the site via the stormwater system.
We have continued to receive complaints about odors from the stream for several months after Brenntag ceased
discharging from the containment system and began hauling the contaminated water off-site. I am concerned that
the contaminated groundwater is following the topography and seeping into the stream from shallow groundwater.
The contamination may be from prior use of the site as the Durham Cotton Mill. Samples the City of Durham
collected from with the stormwater system at the site resembled landfill leachate,and may have derived from
wastes buried on the western portion of the site. Facility managers have indicated that in building the foundation
for one of the shed roof structures,the contractor encountered a soupy muck that required a specialized caisson
in order to build the foundation. An alternative explanation for the BOD (greater than 10,000 mg/I)and metals we
found is acetate that may have leaked from underground process piping at the site,together with leaked caustic
and acid solutions etching metals from the pipe and leaching metals from the soils.
The facility did some limited sampling of monitoring wells at our request but did not sample all of the wells nor did
they measure BOD.
The residential community downstream has been severely impacted by the odor, and this has become an
Environmental Justice issue. The North Carolina Department of Environment and Natural Resources must take a
more active role in addressing the issues at this site, including the contaminated groundwater.
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[Fwd:Contaminated groundwater at Brenntag SE in Durham]
I am forwarding some previous correspondence to provide you with additional background on the range of issues,
together with attachments including the results of groundwater and containment basin monitoring.
John Cox
Stormwater Services Division
(919)560- 1328 x 251
From: Cox,John
Sent: Saturday, October 27, 2007 3:19 PM
To: Matt Matthews
Cc: Mack Wiggins; Bradley Bennett; Danny Smith;Azarelo,James; Gil Vinzani; Baker, Jonathan; Hailey, Bill
Subject: Brenntag Meeting Notes&review of recent data
Importance: High
Further below is the transmittal of the summary of our latest meeting with Brenntag. The meeting summary is
attached,together with meeting handouts.
I am also attaching a pdf file containing the results of monitoring performed by Brenntag's consultants,Arcadis,
after our meeting.The Arcadis file includes the transmittal letter,two tables of results, and a map of the locations
sampled.
The transmittal further below discusses our concerns and initial impressions regarding BOD, ammonia and TKN.
On further reflection,we have the following additional comments:
• The containment structure(SW-1)exceeded the water quality standard for pH at 9.27 based on the field
measurement,which is more representative than the lab measurement(e.g.changes in carbon dioxide
concentration in the sample.)
• Metals concentrations are much lower than in prior sampling, but zinc exceed the NC Action Limit,and
nickel exceeds NC WQS
• Specific conductivity is extremely high (2,972 umhos)
• Immediately outside the containment structure (SW-13) pH was 8.67 and conductivity 819 umhos,still
relatively high numbers.
One of our staff recommended that Brenntag should monitor the 3 pipes that convey flow to containment basins.
He noticed that there is a pipe labeled UGA(Underground Acid) going from SW-2 to SW-1, and that SW-3 and
SW-2 are in line with the UGC (Underground Caustic). We understood that part of the$900,000 work that
Brenntag undertook over the last two years has been to replace the underground pipes with above ground pipes in
carrier pipes, but wonder whether the old pipes were ever disconnected from the stormwater pipes?
It is still not clear to us where the BOD and TKN are coming from. (1) It may be generated by breakdown of
buried wastes—see prior messages and meeting summary discussions of organic muck. (2) It may also be from
spilled acetate or from acetate that leaked into the groundwater from prior leaks. The use of ammonium
hydroxide to adjust pH may also be contributing to the TKN.
Metals are much lower than in prior sampling, possibly because the underground pipes that were leaking acids
and caustics have been abandoned and replaced with above ground pipes. Additional sampling would be
required to evaluate the variability of metals concentrations, and to add monitoring of CN. NCDWQ had previously
found low concentrations of acetone and other organic compounds, and a second round of such monitoring is
needed.
In the absence of information on toxic organics and metals,we are primarily concerned about(1) 180 mg/I BOD,
(2) 13 mg/I ammonia, (3)total nitrogen, (4) high salinity in the containment structures. Our biologists are finding
blood-red midges in the channel downstream that are characteristic of heavy organic loading. Modeling is needed
to establish allowable BOD concentration and load. Ammonia toxicity is likely under a wide range of
temperatures,given the high pH. Any effluent limits need to consider that the facility discharges to a tributary of
the Upper New Hope Arm of Jordan Lake,which is subject to nitrogen and phosphorous limits.
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[Fw4:Contaminated groundwater at Brenntag SE in Durham]
Earlier you were sent a graph of monitoring data at TF6.5RCUT that demonstrates the impact that periodic
discharge of high BOD water has had. It appears that Brenntag cut back on aeration this past summer because
the water in the containment basins was clearer.
Other issues include contamination of groundwater by pollutants other than chlorinated organics and gasoline
(currently being addressed on the eastern end of the site), and air quality/public health impacts from venting of
tank headspace when transferring organic chemicals from rail cars, including acetone,toluene, methyl ethyl
ketone, ethanol, isopropyl alcohol, isopropyl acetate, ethyl acetate, and N-propyl acetate(other organic chemicals
such as xylene, are handled in drums that have much less headspace.)
John
John Cox
Stormwater Services Division
From: Cox,John
Sent: Wednesday, October 24, 2007 5:31 PM
To: '[e-mail]'
Cc: Bruce Biehl; Hailey, Bill; Azarelo, James; [e-mail]; Baker, Jonathan; Wiebke, Paul;
[e-mail]; Westbrook, Vicki; Dodson, Robert; Hicks, Reginald
Subject: Brenntag Meeting Notes and preliminary data review
Importance: High
David,
Attached please find the final meeting summary and attachments from our meeting of November 1,2007.
This afternoon we received the report from your consultant(Jim Shilliday of Arcadis). It will take us several days
to thoroughly review the data. However,you should anticipate another meeting involving representatives from
NCDWQ to discuss Next Steps to address the BOD and nitrogen that you are discharging. It would be helpful if
you could provide the summary of recent work so that folks new to the issue can get up to speed. In the interim, I
wanted to give you my initial reaction to the monitoring data.
Sample results from the facility's four stormwater retention/aeration basins [as monitored at SW-1]
indicate the water has a BOD of 180 mg/I. Ammonia-nitrogen and TKN-nitrogen are 13 mg/I and 19 mg/I,
respectively. These numbers are extremely high,and are comparable to wastewater. Dissolved oxygen
in this basin was reported as 2.2 mg/I,which suggests that there was at least some aeration being
applied. The BOD is close to that of dilute domestic wastewater,and it seems clear that the BOD alone
explains the stinky creek. It appears that most of the TKN is in the form of ammonia,which is highly toxic
to aquatic life and also has a high oxygen demand.
Regarding assertions of progress made in reducing impacts to water quality, we agree that heavy metals
have declined significantly at SW-1. However, the City of Durham measured TKN on June 21,2004 at
SW-1 as 15.5 mg/I, compared to 19 mg/I in the recent sampling. The data does not demonstrate any
improvement in BOD,TKN-nitrogen or ammonia-nitrogen resulting from the extensive work undertaken
over the last two years. At concentrations of 13 mg/I, ammonia is likely to be at least as toxic to aquatic
life as the heavy metals. You will need to come up with a plan to address the BOD and nitrogen. You
may wish to contact the City's Water Management Department to explore whether the reduction in metals
has been sufficient to meet the City's pretreatment limits.
Samples should also be collected from the stormwater system upstream of the four stormwater
retentions/aeration basins, (e.g. SW-2, CB downstream of SW-2, SW-9,etc.)
The groundwater data collected thus far does not indicate that it is also a contributor, but the groundwater
monitoring did not cover a large enough area. To simplify this I suggest a two step process: monitor for
pH,conductivity, DO,temperature and turbidity at the following wells: MW-15d, MW-34, MW-36, MW-37,
MW-42, MW-45, MW-44, MW-50D. The results can be acquired and reported fairly quickly, and can be
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[Fwd:Contaminated groundwater at Brenntag SE in Durham]
used as indicators or triggers to limit the need for lab sampling. We will suggest triggers after we have
completed our data review.
I have modified the draft Meeting Summary to reflect that Brenntag has responded to each request for update that
the City has made. However, I would like to reiterate that the City has had to request progress reports,and that
the Meeting Summary for our meeting of November 22, 2005 included the following:
After the proposed plan has been approved by headquarters, construction is likely to take three
(3) months. When construction has been completed and the improvements have all been
placed in service, Brenntag will contact the John Cox and Shannon Langley so that the
City of Durham and the Division of Water Quality can assess what issues, if any, remain to be
addressed.
Please note that Shannon Langley is no longer working for the NC Division of Water Quality.
Brenntag has yet to notify us that all improvements have been made per our meeting of November 22,2005.
However,this may be because the Brenntag did not begin the work of sealing of the underground pipes until
2007. This work was included in the Plan of Action that Brenntage presented on November 22,2005. In
responding to a letter from Jim Azarelo, Bruce Biehl notified us on May 18, 2007 that Tri-State Utilities had been
contracted to install liners to prevent infiltration of contaminated groundwater into the underground stormwater
system. On September 25, 2007, Mr. Biehl indicated to Mr.Azarelo that the City would receive a letter
summarizing the work completed on lining the storm drains.
We would like to know whether the work by Tri-State in sealing the pipes completes the Plan of Action work
outlined in the Meeting Summary for the meeting of November 22, 2005. Secondly, please provide us with the
date of completion for the work by Tri-State Utilities to line the stormwater piping. Finally, please let us know when
we can expect to receive the summary of recent work-presumably the information on lining the stormwater pipes
will be included in this summary together with a description of the other work completed since November 2005.
John
John Cox
Stormwater Services Division
From: [e-mail] [mailto:[e-mail]
Sent: Friday, October 19, 2007 2:49 PM
To: Cox, John
Cc: Bruce Biehl; Hailey, Bill; Azarelo,James; [e-mail]; Baker, Jonathan; Wiebke, Paul;
[e-mail]
Subject: Re: Brenntag Meeting Notes
John,
I had not had a chance to reply until now as I have been out of town.We had a meeting today with Arcadis to
review the test results form the samples taken and were very pleased with the results.The sample taken form the •
creek leaving the property was in compliance with stream standards.We have also identified some areas that we
can further improve on and have a contractor coming in to give us an estimate and time frame to make the
improvements.Jim Shilliday is going to put together a report for you and said that he could have it completed by
Tuesday 10/23/2007. The only comments that I have on your meeting notes are that as I had mentioned in the
meeting,your perception of our communication is that we have done a poor job.We feel as though that we have
responded to every request for information in a timely manor. We have provided you with update reports every
time we were asked. As far as communicating with the public until notified by you we have not received any
complaints nor had person to contact, a note went out to Ms.Wisdom Pharaoh that day.
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[Fwc]:Contaminated groundwater at Brenntag SE in Durham]
We are hopeful that you will be pleased with the good progress we have made and to the extent that we can , we
will continue to work together for the best possible solution to resolve the odor issues in the creek.
David Robertson
Vice President of Operations
Brenntag Southeast, Inc.
[phone]
[phone] Fax
[e-mail]
"Cox,John"<John.Cox@durhamnc.00v> To<dsrobertsonabrenntae.com>,"Bruce Biehl"<[e-mail]>,
<Jim.Shillidav@ arcadis-us.com>
1W15/2007 01:20 PM cc'Azarelo,James'<[e-mail]>,'Halley,Bill'
<[e-mail]>,"Baker,Jonathan'
<[e-mail]>,'Wiebke,Paul'
<Paul.W iebke @ durhamnc.eov>
Subject Brenntag Meeting Notes
Attached is a draft summary of our meeting together with four handouts from the meeting. Please review and
provide comments or corrections by noon,Thursday October 18,2007.
Also attached is a graph showing the combined impact of dissolved oxygen (DO)and biochemical oxygen
demand (BOD) at TF6.5 RCUT. The graph shows violations of the state's water quality standard for dissolved
oxygen, but it also demonstrates the potential for oxygen to become further depleted as the BOD removes the
remaining oxygen. Resulting anaerobic conditions generated hydrogen sulfide and other noxious odors.
We have received a current map of the existing monitoring wells. And e-mail from Mr. Shilliday indicated that only
three monitoring wells were sampled; it did not indicate the locations of the other samples. I expect we will want to
meet with you and to recommend sampling at additional locations after we have reviewed the results of these
samples.
John
John Cox
Stormwater Services Division
From: Cox, John
Sent:Thursday, September 27, 2007 3:51 PM
To: David Robertson ([e-mail]); Bruce Biehl; Glenn Dunn
Cc: Azarelo, James; Gil Steadman; '[e-mail]'; Judy Garrett
Subject: RE: MacDougal Terrace Resident Complaints
Importance: High
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[Fwd:Contaminated groundwater at Brenntag SE in Durham]
. While I recognize the efforts and expense undertaken by Brenntag to date,the work to date has not been
successful in mitigating the impacts to water quality. In our meeting with Brenntag and NC Division of Water
Quality staff on November 22,2005, we indicated our concern that the planned$1 million work would not address
the source of this contamination. If the source were leaking underground pipes, one would expect that the amount
of the discharge would have declined once the pipes were replaced. Our meeting notes indicate:
City of Durham Stormwater Services staff and Division of Water Quality staff expressed concern that, if some of
the contamination is being generated from wastes buried on site, leachate would find another route to enter the
creek.
Because the work cited above did not significantly address contaminated water infiltrating into the stormwater
system, I understand that Brenntag hired a contractor to seal the pipe using trenchless pipe rehabilitation
technology. I remain concerned that the contaminated water will find another route to enter the creek. As was
indicated in our meeting in 2005,the bottom line is whether pollutants are still leaving the site by whatever means
or path. If the pipe sealing project is not successful in keeping pollutants from entering the creek,additional work
will be needed.
While I certainly recognize the efforts undertaken by Brenntag, it is not the City's job to impart that information to
the public. The impacts to the stream and to water quality are unacceptable. The high BOD being discharged to
the creek makes the creek stink and causes water quality violations. Because we are currently in a drought,the
lack of any diluting water may have magnified the impacts. I am surprised that your consultants have not come up
with some short-term measures to mitigate these impacts, but perhaps you have not directed them to do so.
While the City has previously agreed to a phased approach to addressing this issue, our patience with this
approach is wearing thin given both the lack of progress and the horrible job of communicating with the public.
This has remained unresolved for far too long. It is not going to go away.
Brenntag has done an extremely poor job of communicating with the public. The company has failed to
acknowledge citizen's concerns, and has also failed to take credit for the efforts it has undertaken. Stonewalling is
interpreted as lack of concern. If you do not change how you have approached this,you should expect public
attention and public scrutiny to continue to increase. I have had staff from Duke University and from NC Central
University request monitoring data. I have recently had a similar request from a political activist.
I recommend in the strongest possible terms that you take steps to communicate with residents through the
Residents Council—as discussed below-or by some other means. Given the company's prior failure to
communicate,your initial efforts may be received with some skepticism and mistrust on the part of citizens- it will
take some time to build trust.
Finally, I wanted to make sure you are aware that in November 2006 Durham City Council adopted a revised illicit
discharge ordinance that provides for substantially increased penalties for violations.
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[Fwc]:Contaminated groundwater at Brenntag SE in Durham]
I understand that you will be sending Jim Azarelo reports on the pipe rehabilitation and on the subsequent
sampling to assess the effectiveness of that work. You should also provide Jim with a schedule and keep him
informed of other steps that you contemplate.
John Cox
Stormwater Services Division
From:Azarelo, James
Sent:Thursday, September 27, 2007 11:01 AM
To: [e-mail]
Cc: Cox,John
Subject: MacDougal Terrace Resident Complaints
Bruce,
I just got off the phone with Ms.Wisdom Pharaoh. She's on the Resident Council over at MacDougal Terrace.
The residents there are concerned about the foul odors emanating from Third Fork Creek. Without getting into
too much detail, I told her that the City is investigating area industries to determine the source(s)of the
contaminants and is working toward solutions. I also told her that a considerable amount of money has been
spent to reduce or otherwise eliminate the impact that some industries may have on the environment.
I think it would be best if Ms. Pharaoh and her residents heard about this work from businesses themselves. I am
providing you with her contact information should you choose to discuss these items with her.
Wisdom Pharaoh
[phone](Office-no answering machine)
Wisdom [e-mail] (Personal email)
[e-mail] (Resident council email)
Thanks,
Jim Azarelo
Industrial Stormwater Inspector
Department of Public Works
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[Fwd:Contaminated groundwater at Brenntag SE in Durham]
•
. Stormwater Services-Water Quality Section
101 City Hall Plaza
Durham, NC 27701
Office: [phone]x226
Cell: [phone]
Fax: [phone]
[attachment "Meeting Summary(10-01-07)-Review copy.doc" deleted by David S
Robertson/Southeast/Brenntag] [attachment "03-07 Dissolved Oxygen Sag at
TF6.5RCUT2003-3rdQ2007-expanded.pdf' deleted by David S Robertson/Southeast/Brenntag]
[attachment "SpCond 04-06.pdf' deleted by David S Robertson/Southeast/Brenntag] [attachment "03-07
Conductivity at TF6.5RCUT2003-3rdQ2007.pdf' deleted by David S Robertson/Southeast/Brenntag]
[attachment "Compliance summary 2006 nutrient&FC sites.pdf' deleted by David S
Robertson/Southeast/Brenntag] [attachment "Q_Brenntag-07-3rdq.pdf' deleted by David S
Robertson/Southeast/Brenntag]
Matt Matthews v-(919) 733-5083, ext. 517
NC DENR/Division of Water Quality f-(919) 733-0719
Point Source Branch [e-mail]
1617 Mail Service Center http://h2o.enr.state.nc.us/swps/
Raleigh, North Carolina 27699-1617
Content-Type: application/octet-stream
Meeting Summary_10-01-07-Final.pdf
Content-Encoding: base64
03-07 Conductivity at TF6.5RCUT2003-3rdQ2007.pdf Content-Type: application/octet-stream
Content-Encoding: base64
Content-Type: application/octet-stream
Compliance summary 2006 nutrient&FC sites.pdf
Content-Encoding: base64
Content-Type: application/octet-stream
Q_Brenntag-07-3rdq.pdf
Content-Encoding: base64
8 of 9 2/29/2008 4:48 PM

•
• Meeting with Brenntag
City of Durham
Stormwater Services Water Quality Group
October 1, 2007 Meeting Summary
Final Oct. 24, 2007
A meeting was held at 10:00 AM on October 1, 2007 at the facilities of Brenntag Southeast on
Pettigrew Street in the City of Durham. The meeting provided an opportunity for:
• The City of Durham to present findings regarding impacts of discharges from the Brenntag
site on water quality in Rock Creek, a tributary of Third Fork Creek;
• Brenntag staff and their consultants to present progress made and current plan of action to
provide additional controls to eliminate sources of illicit discharge at the site.
Attendees of this meeting are listed below:
Name Organization Telephone
David Robertson Brenntag Southeast 919-281-2968
Bruce Biehl Brenntag Southeast 919-281-2932
T. Inmane Brenntag Southeast 919-281-2932
S. Hill Brenntag Southeast 919-281-2932
James Shilliday Arcadis/ Brenntag 919-854-1282
A. Pinnix Arcadis/ Brenntag 919-854-1282
Paul Wiebke City of Durham, Stormwater Services 919-560-4326
John Cox City of Durham, Stormwater Services, Water Quality 919-560-1230x224
Bill Hailey City of Durham, Stormwater Services, Water Quality 919-560-1230x221
Jon Baker City of Durham, Stormwater Services, Water Quality 919-560-1230x225
Jim Azarelo City of Durham, Stormwater Services, Water Quality 919-560-1230x226
After introductions, John Cox provided copies of the meeting notes (and attachments)from the
previous meeting held on November 22, 2005 to the representatives from Arcadis because
these individuals had not attended the previous meeting, which included representatives from
the NC Department of Environment and Natural Resources - Division of Water Quality (NC
DENR/DWQ), City of Durham staff from Stormwater Services and Water Management, and
Brenntag and its consultants. Copies of the meeting notes from the November 2005 meeting
were previously distributed in an e-mail to attendees on December 5, 2005.
Water Quality Impacted Downstream of Brenntag
John Cox briefly summarized water quality monitoring results attached to the meeting notes
from the previous meeting and presented updated monitoring results at the City's monitoring
site (TF6.5RCUT) 2,500 feet downstream of the Brenntag facility (handouts are attached).
Routine monitoring at this site has included pH, dissolved oxygen, and conductivity; beginning
in 2005, monitoring at this site was enhanced to include BOD, nutrients, and selected metals.
The stream monitoring data indicated improvement in some water quality parameters
downstream of the Brenntag facility since the meeting in November of 2005, but either no
change or worsening in other parameters. The pH level has stabilized and conductivity appears
to have decreased slightly. However, dissolved oxygen (DO) and biochemical oxygen demand
(BOD) have become more problematic. While water quality is generally poor in urban streams
draining the older developed areas along the railroad lines running through Durham,
p.1

Brenntag October 1, 2007 Meeting Summary
TF6.5RCUT is worse than other impacted sites in Third Fork Creek and nearby Northeast Creek,
with higher levels of conductivity, BOD, total phosphorus, and total nitrogen, and lower levels of
DO.
Mr. Cox also discussed the downstream water resources that are impacted by discharges from
the Brenntag site, including Rock Creek, Third Fork Creek, New Hope Creek, and the Upper New
Hope Arm of Jordan Lake. Mr. Cox also stated that the combination of high BOD being
discharged to the creek and low DO together contribute to making the creek stink and cause
water quality violations. Mr. Cox speculated that the drought and lack of diluting water may
have magnified the impacts. Mr. Cox stated that the impacts to the stream and to water quality
have been, and continue to be, unacceptable.
Mr. Cox indicated that there may be other contributing sources, but it is difficult to identify or
confirm those sources in the presence of contamination from upstream. In such complex
situations, the City's approach to finding and eliminating illicit discharges is to start upstream
with control efforts. The Brenntag site is located near the ridgeline that separates the Neuse
and Cape Fear River Basins, and prior investigation had shown that contaminated water was
not present in the storm drain system entering the Brenntag site from Pettigrew Street. Based
on the very high BOD found in prior sampling at Brenntag, it is clear that discharges from the
site have been a significant contributor to BOD, DO and other concerns downstream.
Brenntag's response and Current plan of action
Dave Robertson stated that Brenntag spent about $900,000 developing and implementing the
corrective action plan presented at the previous meeting. Corrective actions focused on existing
processes at the facility and included:
• Replacing the underground piping that carries process wastewater to the collection pit
with overhead (above ground) piping, which facilitates future leak detection and repair.
• Sealing concrete surfaces that are subject to spills with a chemical resistant coating.
• Re-coating stormwater containment basins with a chemical resistant coating to prevent
leakage.
• Abandoning underground transfer line from the Emergency Neutralization Unit to the
storage tank and piping it above ground.
Mr. Robertson stated that after the above work had been completed, Brenntag contracted to
line the underground stormwater piping on-site to prevent contaminants from entering the
stormwater system at a cost of approximately $70,000.
Mr. Robertson stated that he thought Brenntag had corrected the problems discussed in the
previous meeting and was unaware of continuing issues until being notified recently by Mr. Cox.
Mr. Robertson also stated that Brenntag is dealing with legacy issues created by industries that
occupied the site prior to Brenntag's occupation. Mr. Robertson stated that when Brenntag
started construction on the canopies for the chemical transfer areas, they drilled into bedrock at
a depth of 17 -22 feet and found organic black muck. Mr. Robertson also stated that they had
found purple dye during another ground excavation project onsite and suspected the area
uncovered as being an old treatment pit although he did not specify as to the location on the
property. Mr. Robertson also stated that when Brenntag re-routed the storm drainage system
on-site, they found multiple pipes coming from different directions. Some of these pipes
appeared to contain sewage. They were unable to determine the source of these pipes; some
p.2

• Brenntag October 1, 2007 Meeting Summary
were re-connected but many were capped off. Mr. Robertson posed the theory of the source of
the contamination being under the pavement(ie. contaminated groundwater) due to his
observation of seasonal water levels correlating with the water quality problem.
James Shilliday of Arcadis confirmed that recovery wells at the Brenntag site are located
primarily on the Eastern part of the property, where plumes of chlorinated solvent exist in the
groundwater, but that there are monitoring wells on the western part of the site. Mr. Shilliday
also stated that the recovery wells are 40 feet deep and pump to a depth of 35 feet. Mr. Cox
requested that Brenntag provide Stormwater with a current map showing the locations of the
recovery and monitoring wells located on the Brenntag site. Mr. Shilliday also stated that
currently the groundwater table is substantially lower due to the drought.
City Concerns about Brenntag's Current Plan of Action
When asked by Mr. Cox if Brenntag had been aerating the stormwater containment basins over
the past 6 months, Mr. Robertson and Bruce Biehl stated that they have not operated the
aerators. John Cox observed that any reduction in operation of the aerators may have
contributed to the low dissolved oxygen downstream. Mr. Biehl indicated they could operate
the aerators in the containment basins to improve dissolved oxygen and reduce oxygen demand
in the water they discharge.
Mr. Cox acknowledged the prior efforts and expense undertaken by Brenntag in re-routing
stormwater, constructing secondary containment, construction of roofing over storage areas,
and implementation of the recent corrective actions to eliminate illicit discharges from their
existing processes to the stormwater collection system. However, Mr. Cox emphasized that it
did not appear that the work had been successful in fully addressing the impacts to water
quality. Mr. Cox explained that if the source of contamination had been the leaking
underground pipes that the amount of the discharge would have declined once the above-
ground process pipes had been placed in service. Mr. Cox read the following from the meeting
notes from the November 22, 2005 meeting:
"The proposed sealing of the pipes may prevent contamination from entering at one
location, but the flow could travel in the pipe bedding and either enter the piping system
at another location or seep into the stream channel. In short, there is concern that the
proposed plan does not address a possible continuing source of contamination below the
ground.
"Stormwater Services and Division of Water Quality staff agreed that a phased approach
to control was warranted due to the complex history and nature of the site, and further
agreed that the proposed plan was a reasonable next phase. However, City staff
indicated that the bottom line was whether pollutants were still leaving the site, and that
additional work would be needed if contaminants from the site found other means of
entering the creek."
At the previous meeting there had been discussion that an alternate explanation for the high
BOD contamination entering Brenntag's stormwater system was leakage from underground
pipes carrying acetate which the project would address, but that given the City's concerns about
legacy buried wastes from cotton mill operations, Brenntag had an obligation to demonstrate
that the work it had done was successful. Mr. Cox pointed out that Brenntag did not have any
monitoring data demonstrating the work had been successful either in eliminating contaminated
p.3

Brenntag October 1, 2007 Meeting Summary
water from entering the stormwater collection system and containment basins, or in seeping
into the stream.
In response to a question by Mr. Cox, Mr. Biehl indicated that the water in the containment
basins was much clearer after completion of the work, that the black floc was no longer
present, and that they had not been extensively aerating the water prior to discharge.
Mr. Cox expressed disappointment that Brenntag had not conducted its own monitoring, that
they and their consultants had not come up with short-term measures to mitigate impacts, and
that Brenntag has not been more forthcoming in routinely informing the City of its progress
either on a regular basis or at critical milestones.
Mr. Cox acknowledged that Brenntag has responded to every request for information from the
City, and has provided updates when the City has requested them. However, he indicated that
company responses were reactive, rather than proactive, and he expressed disappointment that
the company had not routinely provided updates at critical milestones in the construction
process. The meeting summary for the November 22, 2005 meeting indicates that Brenntag
will notify Mr. Cox when it has completed the work in the Work Plan it present at that meeting,
which notice the City has not received.
Mr. Cox further expressed disappointment that Brenntag had not proactively communicated
with the public nor conducted outreach to citizens in the Burton Park-McDougald Terrace area.
Brenntag and its predecessor have completed a number of construction projects over the years
to improve environmental protection, but the company has not effectively taken credit for the
effort and expense it has under taken nor acknowledged that it will continue to identify and
implement projects until it has addressed all of the sources at its site. Mr. Cox indicated that
citizens have continued to complain about odor from the creek, and to request data from the
City. Mr. Cox suggested that Brenntag take active steps to communicate with residents in the
vicinity of their site, including but not limited to the Residents Council of McDougald Terrace.
Mr. Robertson indicated he would contact Ms. Wisdom Pharaoh immediately.
Mr. Cox stated that while the City had previously agreed to a phased approach in addressing
impacts due to the complex history and nature of the site, the City's patience was not unlimited,
and that he was disappointed not only in Brenntag's lack of progress, but also in their passive
approach to communication and demonstrating compliance. Mr. Cox stated Brenntag should
not consider remediation to be complete until it can show that pollutants are no longer leaving
the Brenntag site in either surface water or groundwater.
Mr. Robertson indicated that Brenntag had rehabilitated the sewer service line and the brick
junction box out to the edge of Brenntag's property. Mr. Cox indicated that Brenntag had
responsibility for the sewer line until it reach the street right-of-way.
Next Steps
Mr. Cox stated that he expects to receive two reports from Brenntag; one on the recent work
completed, and the second on the results of sampling to test the effectiveness of this work and
to assess the possibility of other subsurface sources of contamination. Mr. Cox indicated that
samples should be collected from the containment structures, from stormwater piping draining
to the containment basins, from the area outside the stormwater discharge point, and from
p.4

• Brenntag October 1, 2007 Meeting Summary
monitoring wells, including those on the western portion of the site. Mr. Cox discussed
procedures for collecting samples in the stormwater system when only minimal flows are
present, and discussed water quality parameters needed to assess conditions and demonstrate
compliance, including field measurements of conductivity, pH, and dissolved oxygen, and
laboratory measurements of biochemical oxygen demand (five day total without suppression of
nitrogen demand, i.e. not CBOD), nitrite+nitrate, total Kjeldahl nitrogen, and a number of
metals (later confirmed to include cadmium, arsenic, beryllium, chromium, lead, antimony,
selenium, thallium, zinc. copper, silver, nickel, and mercury)
Mr. Shilliday mentioned that Arcadis will include the parameters mentioned by Mr. Cox in the
sampling scheduled for the week of October 1s`2007 and will sample at the following locations:
• Inside stormwater containment basins
• Monitoring wells on the western side of the site including the ones located near the
stormwater containment basins
• Creek downstream of the stormwater containment basins
Mr. Shilliday also mentioned that Brenntag may need some type of treatment system
downstream of the stormwater containment basins if sampling results do not show that the
recent work performed is effective. Mr. Shilliday also mentioned that he would provide Mr. Cox
with a map of the recovery and monitoring wells.
Mr. Biehl offered that Brenntag will resume using aeration in the stormwater containment
basins and will monitor them frequently for dissolved oxygen.
Mr. Robertson stated that he would like to be the point of contact for any requests and
complaints from outside groups and that he will respond to them promptly, and that he will
contact the Residents Council of McDougald Terrace. Mr. Robertson also reaffirmed that he will
provide Stormwater with a report of the recent remedial work completed along with a report
including analytical results of the latest sampling and findings based upon the analytical results.
Mr. Cox stated to Mr. Robertson that Stormwater will discuss further remedial actions and other
steps with Brenntag after the City has reviewed the results of sampling from the wells, basins
and creek.
The meeting ended at 11:20 AM.
Attachments:
The hand outs distributed at the meeting include:
1. "QBrenntag-07-3rdq,"a table of monitoring results at TF6.5 RCUT for 2007 showing
BOD concentrations of 18, 8 and 6 mg/I and dissolved oxygen measurements of 2.9, 3.0
and 4.1 mg/I.
2. "Box&Whisker Plot of Specific Conductivity, 2004-2006,"a graph showing the
distribution of Specific Conductivity data by station for 31 monitoring stations with the
top and bottom of the box at the 75th and 25th percentile, respectively; the graph shows
that conductivity is highly elevated at TF6.5RCUT compared to all other impacted urban
sites.
p.5

•
Brenntag October 1, 2007 Meeting Summary
3. "Conductivity at TF6.5RCUT,"a Scatter Plot of Specific Conductivity at TF6.5RCUT by
date with linear trend line showing slight downward trend; note that the attached
version has been slightly updated from the version distributed at the meeting to include
the available latest.
4. "2006 City Of Durham Ambient Stream Sampling, Summary of Compliance with Water
Quality Standards and Criteria,"a table summarizing water quality monitoring results for
2006 by station for monitoring monthly in the City's ambient monitoring program.
p.6

Q_Brenntag-07-3rdq 10/2/2007
Site ID CollectionDateLata ID ?.r T Cu,>or d4.11?,or 0\TIO.4
I 2+t 3, 441H3 >or TP > I FC CaCO
TF6.5RCUT 1/17/2007 142< 5< 10< 2 0.5 0.9< 0.05 0.1 99 230
TF6.5RCUT 2/14/2007 142 8.9 25 6 0.5 1 0.32 0.1 14000 90
TF6.5RCUT 3/14/2007 142< 5 35< 2< 0.5 j 0.6< 0.05 0.08 350 210
TF6.5RCUT 5/23/2007 142< 5 87 18 2.4 0.5 0.09 0.12 2700 240
TF6.5RCUT 6/20/2007 142 12 158< 2 2.1 j 0.4< 0.05 0.06 ' 32000 120
TF6.5RCUT 7/18/2007 142< 5 66 8 0.5 0.2< 0.05 0.07> 60000 60
TF6.5RCUT 8/15/2007; 142 Y 0 0 0 01 0 0 0 i 0. 0
Page 1

Q_Brenntag-07-3rdq 10/2/2007 .
Gonad '=C ,`u a 3*xt a t 6
10.91 88.4 7.9 2.73 2 0.01 2147117 580
11.98 94.7 7.8 35.1 6 0.66 2147117 250 •
_� 10.43 91.9 7.8 4.25 2 0 2147117 560
3.01 31.8 8.02 5.38 18 0 2147117 980
; 2.87 33.2 8.3 15.9 2 0.25 2147117 650
1 4.081 49.5 7.4 11.3 8 0.69 2147117 250
Stream was dry; 0 01 01 0 0 0 2147117, 0
•
Page 2

. .
ARCAD1S
Infrastructure,buildings,environment,communications ARCADIS G&M of North Carolina,
Inc.
801 Corporate Center Drive
Suite 300
Mr.John Cox Raleigh,
City of Durham,Storm Water Services North Carolina 27807-5073
101 City Hall Plaza Tel [phone]
Durham,North Carolina 27701 Fax [phone]
www.arcadis-us.com
subject:
Results from October 2007 Storm Water and Groundwater Sampling Activities, ENVIRONMENTAL
Brenntag Southeast Facility,2000 East Pettigrew Street, Durham,North Carolina
Dear Mr.Cox:
Date:
This letter report provides information on the storm water and groundwater sampling 23 October 2007
activities performed on October 4 and 5,2007 at the Brenntag Southeast Facility in
Durham,North Carolina. Enclosed with this letter please find the following: (1)field Contact:
parameter data for groundwater and storm water samples,(2)summary of laboratory Jim Shilliday
analytical results for the storm water samples collected at the facility,(3)summary of
laboratory analytical results for the groundwater samples collected at the facility,and Extension:
(4)facility site plan which depicts the facility's storm water management structures, 246
sanitary sewer lines,and storm water and groundwater sample collection locations.
E-mail:
Surface water samples were collected from storm water migrating onto the site in an jshilliday@arcadis-
underground line(SW-14),storm water discharging from that same underground line us.com
at its discharge point(SW-12),storm water migrating off the site at the property line
(SW-13),and storm water contained in the last of the facility's four aeration basins Our r
(SW-1). The field parameter measurements and analytical results indicate that the NC000368.0017
storm water coming onto the site(SW-I4)and leaving the site(SW-12 and SW-13)
was not impacted with regards to the selected field measurements and laboratory
analytical parameters. The storm water contained in the fourth aeration basin(SW-1)
was impacted with levels of zinc and nickel which slightly exceeded the surface
water standards for those compounds and the biochemical oxygen demand associated
with that sample exceeded the background levels detected in SW-14.
Groundwater samples were collected from three monitor wells located in the
southwest portion of the site(MW-2,MWW-38,and MWW-43). The field
parameter measurements for the groundwater samples are representative of non-
impacted background conditions. The analytical results indicate that the groundwater
samples from monitor wells MW-2 and MWW-38 slightly exceeded the groundwater
standards for chromium, lead,and/or nickel. The detection of these compounds at
concentrations slightly above groundwater standards is likely attributable to sample
turbidity.
In general,the analytical results indicate that the improvements to the storm water
management system that have been implemented by Brenntag over the past two years
G:1ENMSeuttocheinWCO368 of 7VStotmwater sen y.Cey or Mature RepodtStorm water Sampling Hewes ac,

Table 1. Groundwater and Storm Water Sample Field Parameter Data for Samples Collected in October 2007,
Brenntag Southeast Facility(Former Southchem Facility),Durham,North Carolina.
Temperature Dissolved pH Specific
Well NoJ Date (Degrees Oxygen (Standard Conductance
SW location Sampled Celsius) (mg/L) Units) (limbos)
MW-2 10/05/07 18.80 5.30 8.36 541
MWW-38 10/04/07 17.92 5.03 8.50 541
MWW-43 10/04/07 17.35 3.57 7.27 555
SW-1 10/05/07 24.09 2.20 9.27 2,972
SW-12 10/04/07 23.70 7.60 8.40 293
SW-13 10/04/07 22.97 7.17 8.67 819
SW-14 10/04/07 25.89 6.79 8.97 212
G:\ENV'Sowhchcn NcO368.0171Stormwater sampling\City of Durham ReporaTable 1 SW&GW Parameters.xls

Table 2. Summary of Analytical Results for Storm Water Samples Collected in October 2007,Brenntag Southeast Facility
(Former Southchem Facility).Durham.North Carolina
Sample ID: SW-1 SW-12 SW-13 SW-14
Lab ID: 680-30867-1 680-30808-3 680-30808-2 680-30808-1
Date Sampled 10/05/07 10/04/07 10/04/07 10/04/07
Constituents NCAC 213
Standardt
Metals(ue/L)
(USEPA Method 200.8)
Cadmium 2 <0.5 <0.5 <0.5 <0.5
Arsenic 50 6.5 3.4 3.5 3.6
Beryllium 6.5 <0.5 <0.5 <0.5 <0.5
Chromium 50 63 <5.0 <5.0 <5.0
Lead 25 N 4.5 <1.5 <1.5 <1.5
Antimony NE <2.5 <2.5 <2.5 <2.5
Selenium 5 <2.5 <2.5 <2.5 <2.5
Thallium NE <1.0 <1.0 <1.0 <1.0
Zinc 50 AL 89 <20 <20 <20
Copper 7 AL <5.0 <5.0 <5.0 <5.0
Silver 0.06 AL <1.0 <1.0 <1.0 <1.0
Nickel 88 130 2.6 29 1.7
Mercury2 0.012 <0.20 <0.20 <0.20 <0.20
pH(SU) 6.0-9.0 8.85 7.42 8.09 7.82
(USEPA Method 150.1)
Ammonia(me/LZ NE 13 0.41 0.44 0.68
(USEPA Method 350.1)
Nitrogen(me/L)
(USEPA Methods 351.2/353.2)
Total Kjeldahl Nitrogen NE 19 0.76 1.7 0.58
Nitrate 10 <0.050 0.14 0.14 <0.050
Nitrite NE <0.050 <0.050 <0.050 <0.050
Biochemical Oxygen Demand(nte/L) NE 180 <2.0 <2.0 <2.0
(USEPA Method 405.1)
I5A North Carolina Administrative Code 2B surface water quality standards for SB and SC water classifications as adopted per
15A NCAC 2B or National Criteria Per USEPA(last updated 10/31/04)
2 USEPA Method 245.1
pg/L Micrograms per liter.
mg/L Milligrams per liter.
< Constituent was not detected above the quantitation limit.
31 Constituent was detected above the quantitation limit.
Concentration exceeded NCAC 2B Standard.
AL Action Level Standard-see 2B.0211 for additional information
N Narrative Standard See 2B.0211
NE NCAC 2B Standard Not Established
G:\ENV\Southchem\NC0368.0I7\Stonnwater sampling\City of Durham Report\Tables 2 and 3.SW&GW analytical results Oct 2007.xls

Table 3. Summary of Analytical Results for Groundwater Samples Collected in October 2007,Brenntag Southeast Facility
(Former Southchem Facility),Durham,North Carolina
Sample ID: MW-2 MWW-38 MWW-43
Lab ID: 680-30808-4 680-30808-6 680-30808-5
Date Sampled 10/04/07 10/04/07 10/04/07
Constituents I! ,C 2L
0 .ard1
Metals(UQ/L)
(USEPA Method 200.8)
Cadmium 1.75 <0.5 <0.5 <0.5
Arsenic 50 13 33 13
Beryllium NE 1.9 0.55 <0.5
Chromium 50 59 190 <5.0
Lead 15 19 4.5 1.7
Antimony NE <2.5 <2.5 <2.5
Selenium 50 <2.5 <2.5 <2.5
Thallium NE <1.0 <1.0 <1.0
Zinc 1,050 100 32 22
Copper 1,000 18 18 <5.0
Silver 17.5 <1.0 <1.0 <1.0
Nickel 100 41 390 4.1
Mercury2 1.05 <0.20 <0.20 <0.20
pHISU) 6.5-8.5 7.60 7.94 7.57
(USEPA Method 150.1)
Ammonia(m2/1.) NE 0.30 0.23 0.27
(USEPA Method 350.1)
J litroaen Ime/L3
(USEPA Methods 351.2/353.2)
Total Kjeldahl Nitrogen NE 0.94 0.52 0.63
Nitrate 10 0.064 0.16 0.44
Nitrite 1 <0.050 <0.050 <0.050
Biochemical Oxveen Demand(me/Ll NE <2.0 <2.0 12
(USEPA Method 405.1)
I5A North Carolina Administrative Code 2L Classifications and Water Quality Standards Applicable to the Groundwaters of
North Carolina(last updated 12/01/05)
7
USEPA Method 245.1
tg/L Micrograms per liter.
mg/L Milligrams per liter.
< Constituent was not detected above the quantitation limit.
31 Constituent was detected above the quantitation limit.
Concentration exceeded NCAC 2L Standard.
NE NCAC 2L Standard Not Established
G:1ENV\So uthchem1NC0368.0171Stormwater sampling\City of Durham Report\Tables 2 and 3,SW&GW analytical results Oct 2007.xls

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