NC0086827_Permit Issuance_20051114

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Mr. Bruce Biebl
Director of Engineering/RegulatoryAffairs
Brenntag Southeast, Inc.
2000 E. Pettygrew St.
Durham, North Carolina 27703
Dear Mr. BiehL•
Michael F. Easley
Governor
William G. Ross, Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
November 14, 2005
Subject: Issuance of NPDES Permit NCM86827
Breantag Southeast, Inc.
Durham County
Division personnel have reviewed and approved your application for renewal of the subject permit.
Accordingly, we are forwarding the attached NPDES discharge permit. This permit is issued pursuant to the
requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement between North
Carolina and the US. Environmental Protection Agency dated May 9,1994 (or as subsequently amended).
This final permit includes no major changes from the draft permit sent to you on September 28, 2005.
If anyparts, measurement frequencies or sampling requirements contained in this permit are unacceptable to
you, you have the right to an adjudicatory hearing upon written request within thirty (30) days following receipt of
this letter. This request must be in the form of a written petition, conforming to Chapter 150B of the North Carolina
General Statutes, and fled with the Office of Administrative Hearings (6714 Md Cr Service Center, Raleigh, North
Carolina 27699-6714). Unless such demand is made, this decision shall be final and binding.
Please note that this permit is not transferable except after notice to the Division. The Division may require
modification or revocation and reissuance of the permit. This permit does not affect the legal requirements to obtain
other permits which may be required bythe Division of Water Quality or pemnts required bythe Division of Land
Resources, the Coastal Area Management Act or any other Federal or Local governmental permit that may be
required. If )on have any questions concerning this permit, please contact Sergei Chernikov at telephone number
[phone],extension 594.
cc: Central FSes
NPDESPermitFle ,-I
Raleigh Regional Office/Surface Water Protection
Aquatic Toxicology Unit
Mr. James E. Shilliday, III, L.G.
Arcadis G&M of North Carolina, Inc.
801 Corporate Center Dr.. Suite 300
Raleigh, NC 27607-5073
N. C. Division of Water Quality I NPDES Unit
1617 Mail Service Center, Raleigh, NC 27699-1617
Internet: h2o.enr.state.nc.us
Sincerely,
N— Alan W. Klimek, P.E.
Phone: [phone]
fax. [phone]
DENR Customer Service Center..1 800 623-7748

Permit Number: NCO086827 `
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
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Brenntag Southeast, Inc.
is hereby authorized to discharge wastewater from a facility located at
Brenntag Southeast, Inc.Groundwater Remediation System
2000 East Pettigrew Street
Durham County
to receiving waters designated as Unnamed Tributary to Third Fork Creek in the Cape Fear River
Basin in accordance with effluent limitations, monitoring requirements, and other conditions set
forth in Parts I, II, III and IV hereof.
This permit shall become effective December 1, 2005.
This permit and authorization to discharge shall expire at midnight on October 30, 2010.
Signed this day November 14, 2005.
F4, Alan Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

•
r
Permit Number: NCO086827
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. Discharge treated groundwater from said treatment works at the location specified on the
attached map through outfall(s) 0012 into an unnamed tributary to Third Fork Creek,
which is classified C-NSW waters in the Cape Fear River Basin.

Permit Number: NCO086827
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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 groundwater from outfall(s) 001. Such discharges
shall be limited and monitored by the Permittee as specified below:
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Flow
0.0144
Continuous
Recording
E or I
MGD
Total Suspended Solids
30.0
Monthly
Grab
E
Oil and Grease
Monthly
Grab
E
Iron
Monthly
Grab
E
Manganese
Monthly
Grab
E
enzene
erly
Grab
E
is 2-eth lhexyl) hthalate
rB
Quarterl
Grab
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,1 Dichloroethene
Quarterly
Grab
E
Tetrachloroethene
Quarterly
Grab
E
Trichloroethene
Quarterly
Grab
E
Toluene
Quarterly
Grab
E
Chloride
erly
Grab
E
IVinyl
'Xylenes (Total)
Quarterly
Grab
E
EPA Method 624/625 (Full
Annually
Grab
E
Suite
Total Nitrogen.
Monthly
Grab
E
Chronic ToxiciW
I Quarterl
Grab
E
Footnotes:
1. Sample Location: E — Effluent, I — influent
2. The grab sample for oil and grease should be skimmed from the surface in a quiescent zone,
such as a holding tank, if possible.
3. Chronic P/F (Ceriodaphnia) @ 90%, January, April, July, and October.
The discharge shall contain no floating solids or foam visible in other than trace amounts.

'Permit Number: NCO086827 '
A. (2.) CHRONIC TOXICITY PERMIT LIMIT (QRTRIM
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, guaLtgly 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 II 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 TBP3B 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 Branch 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 Branch 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.

imap:[e-mail]:143/f...
Subject: Draft Permit Reviews (2)
From: John Giorgino <[e-mail]>
Date: Thu, 13 Oct 2005 14:15:40 -0400
To: sergei chernikov <[e-mail]>
Sergei, I have reviewed the following:
NCO086827 Brentag Southeast - No Comments
NCO086088 Girmes Site Remediation - sample is listed as a composite, this facility has
been taking a grab sample.
Thanks for forwarding the drafts.
-John
John Giorgino
Environmental Biologist
North Carolina Division of Water Quality
Environmental Sciences Section
Aquatic Toxicology Unit
Mailing Address:
1621 MSC
Raleigh, NC 27699-1621
Office: 919 733-2136
Fax: [phone]
Email: [e-mail]
Web Page: http://www.esb.enr.state.nc.us
1 of 1 10/ 14/2005 8:19 AM

09/28/2005 16:37 FAX [phone] HERALD SUN CLASSIFIEDS
0001
Name (Primary) N C D I N R
Start Date 10/3/2005
Stop Date 10/3/2005
publication HE - Hera.d Sun
Ad # 42132
Ad Sales Rep. 02 - Doina Minor
PUBLIC NOTICE
STATE OF NORTH CAROL.INA
ENVIRONMENTAL COMMISSION/NPQ UNIT
1617ALEIIGH. NC 2769 -1817
R
NOTIFICATION OF INTENT TO ISSUE
A NPOES WASTEWATER PERMIT
On the basis of thorough staff review and applica-
tion of NO General Statue 143.21. Public law 92-
boo and other lawful standards end
regulations.
regulations.
Nonhopotlno esIsusCnmIstproposes o Issue Environmental ManagementPollu-
tant Discharge Elimination System (NPOES)
wastewater dlschsrppee per
mit to the pereon(s) Rat-
ed below etfecthre a5 days from the publish date
of this notice.
written Comments r+cgwding the proposed permit
will be accepted until 30 days after the publish
date of this notice. All comments received poor to
that date are considered in the final determi-
nations regarding she propose0 par**+R The Drcc-
tor of the F C OM -nor+ of Water Ckoky r+rtay decide
to hold a public meeting for the proposed permit
should the Division receive a s+gntll ant degree of
oublie interest.
Copies of the draft permit end other %uppoMRgin-
formatlon on file used to determine eatdklons
present In the draft permit arc avauable upon re.
Quest and payment of the coots of reproduction.
Meg comment_- analor regueets for information to
the NC DlvWcn of Water Qu81lry Pt the above ad-
dress or cast the Point Source ursfwn at (918)733-
5083, extension 520. Please include the NPOES
permit number (attached) In any eommunreatlon.
lntefelted persons may Also visit the OMBion of
Water oualmy at 512 N. Ssrsbury Street. Raleigh,
NO 27604-1/48 between the hours of 8:00 a.m.
and 5-.00 p.m. to reviser information on fle.
The 9renntag Southeast Inc. (2000 East Pet&
grew St., Durham, NO 2jJ031 has spptred for rc-
newal of NPOSS permit NCOCS8827 for the Brcn-
ntag facility in Durham County. This permitted fa-
cilrty d isenarges treated roundwater to the un-
named tributary to Tnlyd-FFork Crack in the Cape
Fear RIvice Sash. Currently TSS are water auPGly
limited. This dechargiF may affect future alloca-
tions in tnlB portion of the Cane Fear River Basin.
H-S; October 3, 2005
-.�, �' t CaA
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q,p,, kOm, 'Yv�lv%-�
lot, 91q-q1q-6993

DENR/DWQ
FACT SHEET FOR NPDES PERMIT DEVELOPMENT
NPDES No. Na086827
Facility Information
A licant/FaciliName:
Brenatag Southeast, Inc.
Applicant Address:
2000 East Pettigrew Street, Durham, NC 27702
Facility Address:
2000 East Pettigrew Street, Durham, NC
Permitted Flow
0.0144 MGD
Type of Waste:
Remediated Groundwater
Facility/Permit Status:
Renewal
Count3r
Durham
Miscellaneous
to Third Fork I Regional
E.iiIly
Area mil : m.1 mil
10 cfs 0.0
210 (cfs): 0.0
'low cfs : m.1
100%
SUMMARY
Brenntag Southeast, Inc. has applied for renewal of NPDES permit to discharge remediated groundwater
into a storm drain located in Durham County. The only viable option, other than discharge to surface water,
is to discharge to the City of Durham However, the City of Durbam is unwilling to accept the remediated
groundwater. Leaving the only other economically viable option as discharge to surface water.
The facility is requesting a permitted flow of 0.0144MGD. Groundwater sampling events from 1996 to
present have detected the following compounds including chlorinated solvents:
Isopropyl ether#
Benzene
Carbon disulfide
Chloroethane#
Chloroform#
1,1-Dichloroethane
1,1-Dichloroethene
1,2-Dichloroethane(total)
1,3,5-Tritneth34benzene#
tert-butylbenzene#
1,2,4-Trimethlybenzene#
sec-butylbenzene#
ethylbenzene#
Methlyene chloride#
Tetrachloroethene
Toluene
1,1,1-Trichlorethane#
Trichloroethene
Vinyl chloride
Xylenes(total)
Bis(2ethylhexyl) phthalate
Naphthalene#
Fact Sheet
NPDES Renewal
Page 1

Phenol
Methyl isobutyl ketone#
# - Major Modification for the permit was issued on 03/19/2004 and monitoring for these parameters was
removed based on the fact that these constituents were not found at detectable levels in the effluent for at
least past 12 months.
In addition to solvent contamination groundwater samples indicate contamination from petroleum sources,
therefore the conditions of the general permit for groundwater remediation systems have been incorporated
into this permit. The general permit assumes zero dilution in developing the permit limits and monitoring
requirements. Assuming zero dilution is appropriate for this site since discharge is to a zero flow stream..
A vacuum -enhanced recovery system will be used to pump groundwater from 10 extraction wells at - a
maximum rate of 10 gpm per well. This equates to 0.0144 MGD.
The discharge will be to an. unnamed tributary to Third Fork Creek Though the unnamed tributary is not
listed as impaired, according to the state's 303(d) list, Third Fork Creek is listed as impaired. The cause of
impairment is uncertain but urbanization is suspected.
TOXICITY TESTING: '.
Current Requirement: Chronic Toxicity (Ceriodaphnia) P/F at 90%
Recommended Requirement: Chronic Toxicity (Ceriodaphnia) P/F at 90%
This facility has failed three chronic toxicity tests during the previous 4.5 years. The subsequent tests have
passed.
INSTREAM MONITORING•
None.
COMPLIANCE SUMMARY:
DMRs have been reviewed for the period January 2001 through August 2005. The facility has a mixed
compliance record. The following Notices of Violation were issued: 12/06/02 - tox, 11/25/02 tox,
9/ 16/02 - tox, 9/23/02 - tox, 9/04/02 - tox, 06/20/02 - tox, 12/21/01 - tox, 11/06/01 - TSS,
tetrachloethene,1,1 dichloroethene.
PROPOSED CHANGES:
• MortitoringFmqum . The monitoring for carbon disulfide and phenol have been eliminated based on
DMRs review (non -detect for 20 months). The monitoring frequency for vinyl chloride and xylenes has
been reduced to quarterly based on DMRs review (non -detect for 20 months).
• Lirr t . Based on DMRs review (non -detect for 20 months) limits for benzene, bis (2-ethy1exyl)
phtalaet, 1,1 - dichloroethene, tetrachloroethene, trichloroethene, and toluene have been eliminated.
Monitoring frequency for these parameters have been reduced to quarterly due to the elimination of the
limits.
PROPOSED SCHEDULE FOR PERMIT ISSUANCE:
Draft Permit to Public Notice: September 28, 2005
Permit Scheduled to Issue: November 14, 2005
STATE CONTACT:
If you have any questions on any of the above information or on the attached permit, please contact Sergei
Chernikov at [phone] ext. 594.
Fact Sheet
NPDES Renewal
Page 2

Follow up
Subject: Follow up
From: Shannon Langley <[e-mail]>
Date: Mon, 12 Sep 2005 16:44:22 -0400
To: Gil Vinzani <[e-mail]>
Just a note for you. I left a message for Bruce Biehl at Brenntag this morning. I
told him we were still expecting a permit application from him and that he could call
me if he had any questions about that. I told him he could call you if I was out of
the office.
An interesting side note....I received a message from John Cox today who manages the
City of Durham SW services group. John said that recently Brenntag had approached
the City of Durham about taking this water into the sewer through the pretreatment
program. It seems there were some concerns about Cyanide levels expressed by the
City. John is going to get that data for us. John indicated there was to be a
meeting set up between the City pretreatment folks, Brenntag folks and Durham SW
folks in the very near future to discuss.
Shannon
1 of 1 9/27/2005 12:37 PM

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
<[e-mail]>
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
1 of 1 7/4/2005 9:21 AM

Q ARCADIS
Infrastructure, buildings, environment, communications
ARCADIS G&M of North Carolina,
.. -„
Inc.
801 Corporate Center Drive
Suite 300
r
Raleigh,
Mr. Charles H. Weaver, Jr.
LLSS
U ss
North Carolina 27607-5073
NC DENR
i I
Tel [phone]
Division of Water Quality
tiPA 2 8
ZOOS %
Fax [phone]
NPDES Unit
v .arcadis-us.com
1617 Mail Service Center
_ J
Raleigh, NC 27699-1617
"R - WATU
ouaLITY
FOINT SDUr.11 t R,=VH
ENVIRONMENTAL
Subject:
NPDES Permit Renewal Application, Groundwater Remediation System, Brenntag
Southeast, Inc. (former Southchem facility), Durham, North Carolina.
Dear Mr. Weaver:
On behalf of Brenntag 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 Southchem) in Durham, North
Carolina. Treated groundwater from the remediation system is discharged to an on -
site storm sewer that, in turn, discharges to a drainage ditch located along the
southern boundary of the site. This drainage ditch conveys surface water to an
unnamed tributary of Third Fork Creek. Other items enclosed with this letter in
support of the NPDES permit renewal application include: a copy of the March 2005
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 and/or treatment process are filtered from the treatment
stream using bag filters and granular activated carbon units. The treated effluent is
sampled on a monthly basis for total suspended solids in compliance with the
monitoring requirements for the site (see Attachment A).
Date:
26 April 2005
Contact:
Jim Shilliday
Extension:
246
E-mail:
jshilliday@arcadis-
us.com
Our ref.
NC000368.0015
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.
ChristopherJ. Kalmowski, E.I.
Staff Engineer
E. Shilliday, III,
Scientist/Prolec
Copies:
Mr. Bruce Biehl, Brenntag Southeast, Inc.
File
e:\EW�NC0900.019NPDES Pe Rene hCavw Wterlor NPDES Pw ROMW.O
Page:
2/2

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PRJT MANAGER, CHECKED BY- DRAFTER, PROJECT NUMBER NC 000368,0014,00004 FIGURE:
ARCADIS NOTES:J. SHILLIDAY A. WARREN
DRAWINGi
ARCA015 G&M of North Carolina, Inc. BRENNTAG SOUTHEAST FACILITY SITE
801 Corporate Center Drive, Suite 300 2004-SITE-MAP (FORMER SOUTHCHEM FACILITY) MAP
Raleigh, NC 27607 DURHAM, NORTH CAROLINA
Tel: [phone] Fax: [phone] DATE-
www.arcadis—us.com 21APRO5

FACT SHEET FOR EXPEDITED RENEWAL
Permit Number
6C 008(p 9,)-
Facility Name
Reviewer
Basin/Sub-basin
Receiving Stream
Stream Classification in permit
Stream Classification in BIMS
Is the stream impaired (listed on 303(d))?
Is stream monitoring required?
Do they need NH3 limit(s)?
Do they need TRC limit(s)?
Do they have whole -effluent toxicity testing?
Are there special conditions?
Existing Expiration Date
Proposed Expiration Date
Miscellaneous Comments:
Ell
0
If expedited, is this a simpler permit or a more difficult one?

Michael F. Easley, Governor
William G. Ross, Jr., Secretary
North Carulina Department of Environment and Natural Resources
Alan W. Klimek, P.E., Director
Division of Water Quality
February 21, 2005
Memorandum
To: Dave Goodrich, Supervisor
Point Source Branch
From: Ken Schuster, Supervisor
Surface Water Protection
Raleigh Regional Office
Subject: Brenntag Chemical Distributor
Durham County
Recently, staff of the Raleigh Regional Office have received several complaints related to conditions in an
unnamed tributary to Third Fork creek in the general area of Sima Avenue. Our staff, along with that of
Durham Stormwater Services, have documented widely varying instream pH conditions in that particular
stretch of stream below the subject facility.
A review of our agency's files reveals that several years ago Brenntag (formerly Southchem Inc.) was
informed by letter that the stormwater from their site was a contributor of pollutants to the waters of the
B.E. Jordan Watershed and must be covered under an NPDES permit (copy attached). Specifically,
runoff from the site is captured and held in a series of concrete vaults. Air is injected into the contained
stormwater through permanent piping structures. Readings for pH are taken from the last vault structure
and pH is adjusted (typically by adding sulfuric acid per Brenntag representatives comments during an
August 10, 2004 site visit by DWQ) before the water is released to the UT to third fork creek. -
It is the opinion of the Raleigh Regional Office that this method of capture, aeration and pH
adjustment constitutes the operation of a "treatment works" within the meaning of North
Carolina General Statute 143-215.1. In accordance with this statute, the operation of the
treatment works must be covered under a valid permit. Continued operation of the treatment
works without a valid permit subjects them to civil penalties as authorized by NCGS 143-
215.6A.
Further, It is the opinion of the RRO that the runoff from this site meets the definition of "other
waste" as defined in NCGS 143-213 (18)c.
Attached for reference are copies of previous letters sent to the facility, lab results from different
sampling events and pictures of the facility. Please review the attached letter and advise if you
have questions. Historically, we have attempted to resolve this issue intemally, with no success.
Unless you have any significant concerns we plan to send out the attached letter in mid -March
North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone [phone]
service
Internet h2o.enr.stale.nc.us 1628 Mail Service Center Raleigh, NC 27699-1628 FAX [phone]
Customer
Nor Carouna
,Naturally
1.877-623-6748
An Equal Opportunity/Affirmative Acdon Employer-50% Recycledl10% Post Consumer Paper