NC0086827_Brenntag Meeting 2005_20050627

Brenntag meeting with RRO
Subject: Brenntag meeting with RRO
From: Ken Pickle<[e-mail]>
Date: Mon, 27 Jun 2005 15:45:52-0400
To: Teresa Rodriguez<[e-mail]>
CC:Bradley Bennett<[e-mail]>,Gil Vinzani <[e-mail]>, Shannon
Langley<[e-mail]>,Ken Schuster<[e-mail]>,Judy Garrett
<Judy.Garrett@ ncmail.net>
Teresa,
Gil wanted me to pass on the results of our meeting this afternoon with RRO about
Brenntag.
ATTENDING: Ken Schuster, Shannon Langley, Judy Garret, Jenny Atkins, Gil Vinzani, and
Ken Pickle
The group reached the following conclusions.
a) The four treatment vaults constitute a treatment works, and Brenntag must apply
for an NPDES wastewater permit for the operation of a treatment works. Or, Brenntag
must cease the discharge. Or Brenntag can capture and haul away the discharge. Or
Brenntag can provide a roof for larger portions of the site, and potentially connect
to the City of Durham's wastewater collection system.
b) Shannon Langley will make minor modifications to a draft letter to Brenntag, and
send it out right away. The letter will inform Brenntag that they must either cease
the discharge, or apply for a permit for the discharge from the four treatment
vaults. RRO expects the facility to object to the requirement for a permit, and that
the ceasing of the discharge is not a viable option for this business.
c) It appears that the facility currently has an NPDES discharge permit for a
groundwater remediation system, and it appears that that permit is currently under
review for renewal.
d) After discussion both ways, RRO felt that there might be some advantage to
permitting the discharge from the four treatment vaults on the same permit as the
already existing groundwater remediation permit. My sense is that this decision is
subject to change, if RRO or if NPDES E unit encounters any good reason to keep the
two discharges on two different permits.
e) The Stormwater Permitting Unit will not try further to resurrect Brenntag's 1996
application for a stormwater permit (we seem to have lost the paperwork, and cannot
find anything about it) , nor will we seek a new submittal for a stormwater permit
from Brenntag. The group consensus was that the operation of a treatment works
argues for an NPDES wastewater permit, not a stormwater permit. The group believes
that the Director's 1994 determination that Brenntag must seek a stormwater permit
may have been reached before the four treatment vaults were installed.
Ken
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