NCS000611_Fact sheet binder_20240111

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 12/21/2023
Permit Number NCS000611
Owner/Facility Name Brennta Mid-South,Inc./Charlotte Facility
SIC AICS Code/Category 4226 (493190)/Other warehousing and storage
Basin Name/Sub-basin number Catawba/03-08-34
Receiving Stream/HUC UT to Steele Creek/030501030108
Stream Classification/Stream Segment C/ 11-137-10
Is the stream impaired on 303 d list]? No
Any TMDLs? No
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any perinit mods since lastpermit? N/A
New expiration date 1/31/2029
Comments on Draft Permit? See Section 6(below)
Section 1. Facility Activities and Process:
The Brenntag Mid-South, Inc. Charlotte Facility is a wet and dry chemical distribution center, and
includes petroleum-based solvents, acids, and bases. The facility receives bulk deliveries via rail car or
tanker truck and dilutes and/or repackages the chemicals for redistribution in tanker trucks, totes, or
drums.
Per the permit application, all high risk storage or material transfer areas have drainage controlled by
closed drainage valves and are only opened after inspection and sometimes pH testing. Any stormwater
outside of pH limits will be transferred to the onsite treatment plant for eventual discharge to the POTW.
A diked tank farm stores liquid chemicals. Tank farm chemicals are not exposed to precipitation, the
valve closed, and discharged is only after inspection and testing for pH. The loading dock drainage areas
are valved closed and only opened after inspection. Additional non-diked outdoor storage of IBCs drain
into a valved retention pond only opened after inspection and pH testing.
Stormwater flows through the facility via sheet flow to three earthen basins that discharge from five
outfalls. The basins have outlet structures equipped with manually activated valves that remain closed
until accumulated stormwater is evaluated qualitatively and for pH. The facility has approximately 20
outdoor ASTs of acids, caustics, Diesel Emission Fluid(DEF), and solvents. Capacity volumes of the
ASTs range from 20,000 to 30,000 gallons, and secondary containment structures are separated based on
reactivity.
Materials in the tank farm currently include toluene, hydrochloric acid, phosphoric acid, sulfuric acid,
sodium bisulfate, caustic soda, ethylene acetate,bleach, DEF, alkest CS360, sodium thiosulfate,NP9,
citric acid, acetone, blend tanks, IPA 99%USP, spirdane D-40, xylene, methyl ethyl ketone, and glycol
ether EB.
Page 1 of 8

Outfall SW001:
Drainage area consists of the main building, truck scale, tanker parking, car parking, empty tanker
parking, and grassy area.
Outfall SW002:
Drainage area consists of the main building, truck loading docks, and grassy areas.
Outfall SW003:
Drainage area consists of the main building, tank farm, and outdoor IBC storage.
Outfall SW004:
Drainage area consists of the main building, tank farm, outdoor IBC storage, and a retention pond.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Section 2. Monitoring Information and Compliance History:
• As this is an application for a new permit, only one sample per outfall was taken and submitted
with the application. Benchmarks exceeded for:
o SW001: TSS
o SW002: TSS
o SW003: TKN, TN
o SW004: BOD, COD, TKN, TN
• Per an inspection performed by the Charlotte-Mecklenburg Stormwater Services in October
2021, there was evidence of a recent diesel emission fluid(DEF) spill and evidence of old spills
of unknown materials.
Page 2 of 8

Threatened/Endangered Species:
Threatened species in the vicinity of the discharge location include: Tall Larkspur(Delphinium
exaltatum;NC status: T).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for one sample in October 2022. Quantitative sampling included O&G, BOD, COD, TSS, TP,
TKN, and TN.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Brenntag Mid-South, Inc. Charlotte Facility site.
Outfalls SW001, SW002, SW003, and SWO04
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
Conductivity BASIS: Discharge potential indicator; Can be considered for removal at
permit renewal
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Total Phosphorus BASIS: Discharge potential indicator
Page 3 of 8

Outfalls SW001, SW002, SW003, and SWO04 (cont.)
Quarterly monitoring
Total Chromium BASIS: Potential pollutant from drainage area(per sampling performed
by Charlotte-Mecklenburg stormwater staff in February 2022)
Quarterly monitoring
Total Copper BASIS: Potential pollutant from drainage area(per sampling performed
by Charlotte-Mecklenburg stormwater staff in February 2022)
Quarterly monitoring
Total Lead BASIS: Potential pollutant from drainage area(per sampling performed
by Charlotte-Mecklenburg stormwater staff in February 2022)
Quarterly monitoring
Total Zinc BASIS: Potential pollutant from drainage area(per sampling performed
by Charlotte-Mecklenburg stormwater staff in February 2022)
Quarterly monitoring
Total Hardness BASIS: Monitoring for hardness dependent metal present
EPA Method 624 (Total Quarterly monitoring
Purgeable Organics) BASIS: Large volume of chemicals and other pollutants onsite
EPA Method 625 (Base Quarterly monitoring
Neutrals and Acids) BASIS: Large volume of chemicals and other pollutants onsite
Quarterly monitoring
1,4-dioxane BASIS: Large volume of chemicals and other pollutants onsite
Quarterly monitoring
Acetone BASIS: Large volume of chemicals and other pollutants onsite
Quarterly monitoring
Ethanol BASIS: Large volume of chemicals and other pollutants onsite
Quarterly monitoring
Toluene BASIS: Large volume of chemicals and other pollutants onsite
Quarterly monitoring
BASIS: Due to the volume of chemicals stored onsite and site conditions
Aquatic Toxicity based on past site inspections, aquatic toxicity testing will be required.
Monitoring may be considered for removal at the next renewal.
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
Page 4 of 8

concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Page 5 of 8

Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
g 133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Total Nitrogen 30 mg/L TKN+Nitrate+Nitrite Benchmarks (Expressed in mg/L of
N
Total Phosphorus 2 mg/L BPJ; Based on wastewater permit limits for NSW waters
1/2 FAV; Based on(Cr III+Cr VI) acute thresholds and
Chromium(Total) 905 µg/L assumption that industrial activities here are not a source of
hexavalent chromium
Copper Total 10 /L Acute Aquatic Criterion, 1/2 FAV
Lead Total 75 /L Acute A uatic Criterion, 1/2 FAV
Zinc Total 126 /L Acute Aquatic Criterion, 1/2 FAV
1,4-dioxane 0.73 mg/L In-stream standards for general human health exposures,
Class C waters
Acetone 17 mg/L 1/2 FAV
Ethanol 3,900 mg/L 1/2 FAV
Toluene 55 mg/L From NC 02B Std. (11 µg/1), based on April 1986 DWQ
Internal Report
90% acute North Carolina Procedure Document entitled"Pass/Fail
Acute Toxicity mortality Methodology For Determining Acute Toxicity In A Single
Effluent Concentration"
Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
Page 6 of 8

• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Section 4. Changes from previous permit to draft:
• N/A
Section 5. Changes from draft to final:
• Regulatory citations have been added
• Online SWPPP certification requirement ahs been removed per updated stormwater program
requirements
• Monitoring for acetone, ethanol, toluene, and 1,4-dioxane have been added based on a review of
information provided during the permit renewal
• Reopener clause has been added based on a review of information provided during the permit
renewal
Page 7 of 8

Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 2/l/2023
• Initial contact with Regional Office: 2/13/2023
• Draft sent to CO peer review: 3/2/2023
• Draft sent to Regional Office: 9/29/2023
• Final permit sent for supervisor signature: 1/4/2024
Section 7. Comments received on draft permit:
• Jerry Eplin (MRO; via email 10/5/2023): Looks good to me. We'll have no comments from our
end.
• Andrew DeCristofaro (Charlotte-Mecklenburg Storm Water Services; via email 10/27/2023):
o Regarding Secondary Containment: Currently, the facility uses a retention pond as
secondary containment for the IBC storage area, which may not be suited for secondary
containment in structure or volume for that purpose.
■ DEMLR response: Per discussions with the Mooresville Regional Office, a
retention pond with a locked valve that is only discharged after proper monitoring
could meet the secondary containment requirement, but the pond must be properly
sized(25-year 24-hour storm event), and the facility's secondary containment
plan will have to address the issue.
o Regarding Stormwater Outfalls/Discharge/Monitoring: There is a low-lying area of the
property that floods during heavy rain events and does not discharge into the stormwater
infrastructure,but sheet flows off the property. The area would either need to be sampled
during rain events or connected to the stormwater infrastructure.
■ DEMLR response: Per information provided by the DEMLR Mooresville
Regional Office, sheet flow off any property is not regulated by stormwater, even
if it comes from a low-lying area; therefore, the Mooresville Regional Office do
not feel the area represents an outfall that must e monitored. Per the regional
office, the facility does have the obligation to implement BMPs and should
consider this area in their BMP program as they develop their SWPPP.
Page 8 of 8

DailyBeaufoFt Gazette The HeFald-Pock Hill el Nuevo Herald-Miami Sun News-Myrtle Beach
Belleville Slemp-DemccFat Herald Sun-Durham Modesto Bee The News Tribu rpe Tacoma
Bell ingharn Heirald Idaho Stab2sman Paleigh News&Observer The Telegraph-Macon
Bradenton Herald Island Packet The Olympian San Luis Obispo Tiribure
A&,MC,-CLATCHY Centre
Charlotte Obserwer Lexington Heirald-Leader Fort VlAyth Star-Telegram Wichita Ead3le
Fresno Bee Miami Herald Sun Herald-Biloxi
AFFIDAVIT OF PUBLICATION
Account# Order Number Identification Order PO Amount Cols Depth
38106 474193 Print Legal Ad-IPL01421310-IPLO142131 $644.38 2 26 L
Attention: Joyce Sanford Clark North Carolina } SS
NC DENR ENGERGY MINERAL&LAND RESOURCES Mecklenburg County }
1612 MAIL SERVICE CENTER Before the undersigned,a Notary Public of said
RALEIGH,NC Z76991612 County and State,duly authorized to administer
[e-mail] oaths affirmations,etc.,personally appeared,
being duly sworn or affirmed according to law,
----------------------------------------- clothdepose an sa
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION Y that he/s eisa
INTENT TO ISSUE representative of The Charlotte Observer
NPDES STORMWATER DISCHARGE PERMITS
The North Carolina Environmental Management Commission proposes to issue Publishing Company,a corporation organized and
NPDES stormwater discharge permit(s) to the person(s) listed below. Public doing business under the laws of the State of
comment or objection to the draft permits is invited.Written comments regarding
the proposed permit will be accepted until 30 days after the publish date of this Delaware,and publishing a newspaper known as
notice and considered in the final determination regarding permit issuance and
permit provisions.The Director of the NC Division of Energy,Mineral,and Land The Charlotte Observer in the city of Charlotte,
Resources (DEMLR) may hold a public hearing should there be a significant County of Mecklenburg,and State of North
degree of public interest. Please mail comments and/or information requests to y
DEMLR at 1612 Mail Service Center,Raleigh,NC 27699-1612. Carolina and that as such he/she Is familiar with
• Brenntag Mid-South, Inc. [11750 Fruehauf Drive, Charlotte, INC 28273] the books,records,files,and business of said
has requested new permit NCS000611 for the Brenntag Mid-South,Inc. Corporation and by reference to the files of said
Charlotte Facility in Mecklenburg County.This facility discharges to an
unnamed tributary to Steele Creek in the Catawba River Basin. publication,the attached advertisement was
Interested persons may visit DEMLR at 512 N. Salisbury Street, Raleigh, INC inserted.The following is correctly copied from
27604 to review information on file.Additional information on NPDES permits the books and files of the aforesaid Corporation
and this notice may be found on our website: https://deq.nc.gov/about/divi-
sions/energy-mineral-and-land-resources/stormwater/stormwater-program/ and Publication.
stormwater-public-notices,or by contacting Brianna Young at brianna.young @
deq.nc.gov or 919-707-3647.
IPL0142131 1 insertion(s)published on:
Oct 4 2023 10/04/23
f
In Testimony Whereof I have hereunto set my hand
and affixed my seal on the 4th day of October,2023
Notary Public in and for the state of Texas,residing in
Dallas County
�'`' "'• STEPHANIE:HATCHER
x: •- My Notary 10#1335WN
Wires J'anuary 14,2026
Extra charge for lost or duplicate affidavits.
Legal document please do not destroy!

Young, Brianna A
From: Eplin,Jerry W
Sent: Thursday, December 21, 2023 12:44 PM
To: Young, Brianna A
Subject: RE: NCS000611 questions
Brianna: Let me address the issues in reverse order:
Regarding a low area that floods during heavy rain events and runs off via sheet flow, 1) we have no requirement that all
flow from a facility must go to a storm drainage system or to a basin, and 2) sheet flow locations are specifically noted as
not being stormwater outfall locations. I do not believe that such an area represents an outfall that must be
monitored. The facility does have the obligation to implement BMPs, and should consider this area in their BMP
program as they develop their SWPPP,to make sure that this area is maintained in a way that does not contaminate
stormwater.
Regarding storage of totes outside,the permit defines secondary containment as follows:
Secondary Contaiiunent
Spill containment for the contents of the single largest tank within the containment st uchure plus
sufficient freeboard to contain the 25-year, 24-hour stone event.
A retention pond with a locked valve that is only discharged after proper monitoring could meet this
requirement. However,the 25-yr, 24-hr storm event may make some retention ponds too small to be considered
secondary containment.
The facility is required to implement a secondary containment plan within 12 months of receiving new coverage. Their
secondary containment plan will have to address this issue and they will either need to provide additional containment,
or they will need to document that the retention pond meets this requirement.
I see no reason to hold up the permit for either of these issues.
Let me know if you need more information from me regarding this site.
Regards,
Jerry W. Eplin, PE
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone]
Email:[e-mail]
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115

- - -7
D,_ E Qft,A-
Doppelnirid of Enwo mrn dal{Wahlry
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From:Young, Brianna A<[e-mail]>
Sent:Thursday, December 21, 2023 8:18 AM
To: Eplin,Jerry W<[e-mail]>
Subject: RE: NCS000611 questions
Hello Jerry,
Just following up again on the previous emails. Could you provide some guidance on how these items should be
handled?The final permit issuance is being held pending answers to these questions.
Thanks,
Brianna
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent: Monday, December 4, 2023 11:21 AM
To: Eplin,Jerry W<[e-mail]>
Subject: RE: NCS000611 questions
Hello Jerry,
I'm following up on my last email. Do you have any thoughts/guidance on the two items below?
Thanks,
Brianna
Brianna Young, MS(she/her)
2

Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brian na.Young@d eq.nc.goy(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From:Young, Brianna A
Sent: Wednesday, November 15, 2023 11:36 AM
To: Eplin,Jerry W<[e-mail]>
Subject: RE: NCS000611 questions
Sorry for the delayed response. In drainage area SWO04 there is a retention pond. Per my fact sheet, "Per the permit
application, all high risk storage or material transfer areas have drainage controlled by closed drainage valves and are
only opened after inspection and sometimes pH testing.Any stormwater outside of pH limits will be transferred to the
onsite treatment plant for eventual discharge to the POTW. A diked tank farm stores liquid chemicals.Tank farm
chemicals are not exposed to precipitation,the valve closed, and discharged is only after inspection and testing for pH.
The loading dock drainage areas are valved closed and only opened after inspection. Additional non-diked outdoor
storage of IBCs drain into a valved retention pond only opened after inspection and pH testing." Is this an accurate
representation of the site?This may be what the Charlotte folks are referring to.
Regarding sheet flow,there is guidance on SharePoint about point source discharges. Based on this guidance, do you
think the low-lying area referenced by Charlotte should be sampled, or does it truly sheet flow?
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Eplin,Jerry W<[e-mail]>
Sent: Wednesday, November 8, 2023 3:44 PM
To:Young, Brianna A<[e-mail]>
Subject: RE: NCS000611 questions
3

1) 1 was under the impression that the IBC Storage Area had a true secondary containment system. I don't
remember it flowing into a retention pond. I recommend that we ask the facility this question. 1 agree with
their comment that a retention pond would not be an acceptable secondary containment system in this
case. Either way, does this impact the issuance of the permit? I would think the permit could be issued, and
the secondary containment issue be addressed later, since the SWPPP will not have to be finalized 12 month.
2) Regarding the low-lying area that flood during heavy rain events I would disagree with their comment. Sheet
flow off any property is not regulated by stormwater, eve if it comes from a low-lying area.
Jerry W. Eplin, PE
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone]
Email: lerry.eplin(a�deq.nc.gov
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
P4QMii CAT-0i.:%
ago-Orn.oc a r-n-+r
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From:Young, Brianna A<[e-mail]>
Sent: Wednesday, November 8, 2023 11:46 AM
To: Eplin,Jerry W<[e-mail]>
Subject: NCS000611 questions
Hey Jerry,
I received the attached comments from Charlotte/Mecklenburg on the Brenntag draft permit NCS000611. Does MRO
have any input on how to respond to these 2 items?As you have been to the site, I thought you would have a better
grasp on their concerns.
Thanks,
Brianna
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
4

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
5

Young, Brianna A
From: Eplin,Jerry W
Sent: Wednesday, November 8, 2023 3:44 PM
To: Young, Brianna A
Subject: RE: NCS000611 questions
1) 1 was under the impression that the IBC Storage Area had a true secondary containment system. I don't
remember it flowing into a retention pond. I recommend that we ask the facility this question. I agree with
their comment that a retention pond would not be an acceptable secondary containment system in this
case. Either way, does this impact the issuance of the permit? I would think the permit could be issued, and
the secondary containment issue be addressed later, since the SWPPP will not have to be finalized 12 month.
2) Regarding the low-lying area that flood during heavy rain events I would disagree with their comment. Sheet
flow off any property is not regulated by stormwater, eve if it comes from a low-lying area.
Jerry W. Eplin, PE
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone]
Email:[e-mail]
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
D_ J
...... ... .. .,
EQ A)
66l,'el riii'ol'E T% runrflQflUI(Wallly
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, November 8, 2023 11:46 AM
To: Eplin,Jerry W<[e-mail]>
Subject: NCS000611 questions
Hey Jerry,
I received the attached comments from Charlotte/Mecklenburg on the Brenntag draft permit NCS000611. Does MRO
have any input on how to respond to these 2 items?As you have been to the site, I thought you would have a better
grasp on their concerns.
Thanks,
Brianna
1

Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Young, Brianna A
From: Eplin,Jerry W
Sent: Thursday, October 5, 2023 8:38 AM
To: Young, Brianna A
Subject: RE: NCS000611 to public notice
Looks good to me. We'll have no comments from our end.
Jerry W. Eplin, PE
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone] x2147
Email:[e-mail]
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
D�._.E
{}01},illi}�Fili{!F fv ir8fl i51`II1J I{hi.l IIRY
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From:Young, Brianna A<[e-mail]>
Sent: Friday, September 29, 2023 8:29 AM
To: Eplin,Jerry W<[e-mail]>
Subject: NCS000611 to public notice
Good morning,
The draft permit NCS000611 for Brenntag's Charlotte facility has been submitted for public notice. Please provide any
comments by October 30, 2023.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647(office)
1

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
2

Young, Brianna A
From: Eplin,Jerry W
Sent: Monday, May 8, 2023 8:42 AM
To: Young, Brianna A
Subject: NCS000611
Attachments: Brenntag Charlotte Inspection Report 4-21-23.pdf
Hi Brianna:
I want to make sure that you saw this. This is the inspection report for the inspection that I completed for the Brenntag
Charlotte facility. Overall, it was a pretty clean facility. They store a lot of chemicals, but they are all within secondary
containment. They haven't yet finalized their SWPPP but they are ready to, as soon as the permit is issued. I think they
are trying to have a compliant facility. They need to do a little housekeeping, but I pointed that out to them.
Let me know if you have any questions.
Jerry W. Eplin, PE
Assistant Regional Engineer
North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources
Office: [phone] x2147
Email: ierry.eplin(a�ncdenr.gov
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
D- Q
E
{} �j,,ei7iri1 n!F nv oniwiiij I quality�r
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
i

Compliance Inspection Report
Permit:NCS000611 Effective: Expiration: Owner: Brenntag Mid-South Inc
SOC: Effective: Expiration: Facility: Brenntag Charlotte
County: Mecklenburg 11750 Fruehauf Dr
Region: Mooresville
Charlotte NC 28273
Contact Person:David Grenoble Title: District SRQ Manager Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 04/21/2023 Entry Time 10:OOAM Exit Time: 11:22AM
Primary Inspector:Jerry W Eplin Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Other Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: ❑ Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 4

Permit: NCS000611 Owner-Facility:Brenntag Mid-South Inc
Inspection Date: 04/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Other
Inspection Summary:
On April 21, 2023, this facility was inspected in relation to their recent application for an individual stormwater discharge
permit. David Grenoble, Tre' L. Hinchen, and Sylvia Walker were the main Brenntag facility personnel who participated in the
inspection. During the inspection, the following items were noted:
1) The facility does not yet have a Stormwater Pollution Prevention Plan (SWPPP). SWPPP is currently under
development and will not be finalized until the new discharge permit is issued.
2) Facility personnel indicated that they are exempt from having a Spill Prevention, Control, and Countermeasures (SPCC)
Plan, but indicated that they do have a Spill Prevention Plan.
3) Facility stored chemicals both inside and outside the building. Exterior storage included storage in totes and tanks.
Tanks are located within secondary containment.
4) Facility collects most stormwater and inspects it, including internal laboratory analyses, prior to discharing. Facility has
the ability to treat stormwater and discharge to the City of Charlotte sanitary sewer system, when needed.
5) The main process-related stormwater discharges are restrained with valves until the water is deemed suitable to
discharge.
6) Outfall#4 could not be located. The facility needs to locate Outfall#1 and clear a path to the outfall so that samples and
observations can be collected when required. A manhole upgradient of Outfall#4 was observed to have flowing water even
though it has not rained for several days. The facility needs to evaluate this location for potential illicit discharge.
7) On the facility drainage area map, Outfall#1 appears to be located in flowing creek. No pipe was observed. Facility
should evaluate moving Outfall #1 to a location more representative of facility stormwater discharge, i.e. closer to the facility.
8) It was recommended to the facility that they update their drainage area map. Facility drainage appears to have been
slightly modified since the map was prepared. A berm now exists in what was previously Drainage Area#4 that is not
shown on the map.
9) Significant sediment building was observed near Outfall #3. This sediment should be cleaned up and a good
housekeeping program developed to maintain an acceptable conditions.
10) The rail unloading area was also observed to need improved housekeeping.
Page 2 of 4

Permit: NCS000611 Owner-Facility:Brenntag Mid-South Inc
Inspection Date: 04/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Other
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? ❑ ❑ ❑
# Is the Plan reviewed and updated annually? ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? ❑ ❑ 0 ❑
Comment: Facility has applied for an individual stormwater discharge permit but it has not vet been
finalized. Facility is developing their Stormwater Pollution Prevention Plan but it will not be
finalized until after the permit has been issued.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ ❑ 0 ❑
Comment: Facility routinely observes stormwater samples prior to discharge, however, they have not vet
completed the official Qualitative Monitoring required by a stormwater discharge permit.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ 0 ❑
Comment: Facility routinely collects samples of stormwater for internal analysis prior to discharging
stormwater, however, they will not conduct official required analytical monitoring until after the
new permit goes into effect.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? ❑ ❑ 0 ❑
Comment: Three of the four outfalls were observed during the inspection. Outfall number 4 could not be
located. Facility needs to locate and clear a path to outfall number 4. Facility also needs to
consider moving Outfall number 1 closer to the facility.
Page 3 of 4

Permit: NCS000611 Owner-Facility:Brenntag Mid-South Inc
Inspection Date: 04/21/2023 Inspection Type:Compliance Evaluation Reason for Visit: Other
Page 4 of 4

Young, Brianna A
From: DeCristofaro, Andrew <[e-mail]>
Sent: Friday, October 27, 2023 11:25 AM
To: Young, Brianna A
Cc: Miller, Craig
Subject: [External] Attn: DEMLR Stormwater Program - Re: NCS000611
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna,
On behalf of the City of Charlotte I would like to provide the following comments for Draft NPDES Stormwater
Permit NCS000611:
Regarding Secondary Containment:
• Currently, the facility uses a retention pond as secondary containment for the IBC storage area, which
may not be suited for secondary containment in structure or volume for that purpose.
Regarding Stormwater Outfalls/Discharge/Monitoring:
• There is a low-lying area of the property that floods during heavy rain evens and does not discharge
into the stormwater infrastructure, but sheet flows off the property. The area would either need to be
sampled during rain events or connected to the stormwater infrastructure.
We appreciate your time and consideration of these comments.
Please reach out if you have any questions or concerns.
Thank you,
Andrew DeCristofaro
Water Quality Program Specialist
Charlotte-Mecklenburg Storm Water Services
[phone] 1 Andrew.DeCristofaro@ Charlotte NC.gov I CharlofFeNC.gov
srwrc�r�wc.wa �
STORM
-- WATER
i

Young, Brianna A
From: David Grenoble/Mid-South/Brenntag <[e-mail]>
Sent: Wednesday, March 1, 2023 10:48 AM
To: Young, Brianna A
Cc: Bryon Mason/Mid-South/Brenntag; Hinchen, Tre'/Mid-South/Brenntag
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application
NCS000611
Attachments: Brenntag Charlotte Storage Tanks.pdf
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning Brianna,
Please see attached.
If you need any further please let us know.
Thanks,
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
BBRENNTAG
+1 270.869.5806
From: Young, Brianna A<[e-mail]>
Sent: Monday, February 27, 2023 3:31 PM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
This Message Is From an External Sender
This message came from outside your organization.
Hello David,
I have an additional follow-up question. Can you please confirm what is held in the tank farm? If chemicals, please
provide a description of the types of chemicals held.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program

NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Friday, February 3, 2023 9:56 AM
To:Young, Brianna A<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
My apologies, I was unclear on what exactly you needed. I added a few labels to the map that I sent but they were not
as detailed as your info below.
• Outfall SW001: Drainage area consists of the main building,truck scale,tanker parking, car parking, empty
tanker parking, and grassy area.
• Outfall SWO02: Drainage area consists of the main building,truck loading docks, and grassy areas.
• Outfall SWO03: Drainage area consists of the main building,tank farm, and outdoor IBC storage.
• Outfall SWO04: Drainage area consists of the main building,tank farm, outdoor IBC storage, and a retention
pond.
All of this is correct, I don't see anything that needs to be added or amended.
David Grenoble
Regional Safety, Regulatory,and Quality Manager
BBRENNTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Friday, February 3, 2023 9:41 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
2

This Message Is From an External Sender
This message came from outside your organization.
Good morning,
This is the map that was submitted with the application. I was hoping to get a written list to ensure I wasn't missing
anything. What I was able to determine from the map is below. Please let me know if any corrections are needed.
• Outfall SW001: Drainage area consists of the main building,truck scale,tanker parking, car parking, empty
tanker parking, and grassy area.
• Outfall SW002: Drainage area consists of the main building,truck loading docks, and grassy areas.
• Outfall SW003: Drainage area consists of the main building,tank farm, and outdoor IBC storage.
• Outfall SW004: Drainage area consists of the main building,tank farm, outdoor IBC storage, and a retention
pond.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Friday, February 3, 2023 9:27 AM
To:Young, Brianna A<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
Does the attached PDF with the areas labeled meet the needs? If not, please let me know and I will gladly get you the
information.
3

Thanks!
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
13 E TG
+1 270.869.5806
From: Young, Brianna A<[e-mail]>
Sent: Wednesday, February 1, 2023 10:54 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Subject: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
This Message Is From an External Sender
This message came from outside your organization. mjmff�
Good morning,
I am working on reviewing the individual stormwater permit application for new coverage for the Brenntag
Mid-South, Inc. Charlotte Facility. This permit application has been assigned permit number NCS000611.
Please reference this permit number in all future correspondence.
After reviewing the information submitted, I need additional information in order to make sure the permit
adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity in each drainage area;
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
INC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, INC 27604
4

4 � E
oe"rlmeN of En%Nrwrxmal 4ua10
Email correspondence to and from this address rs subject to the North
Carolina Public Records Law and may be disclosed to third parties_
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any
attachments, is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended
recipient, any use, review, dissemination, or copying of any such communication by you is strictly prohibited. If
you believe you have received this or any other electronic communication in error, please do not read, copy, use
or disclose it to others; also please notify the sender by replying to the communication, and then delete it and all
accompanying files from your system. Please verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.
5

Brenntag Charlotte Storage Tanks
Tank# Product
Construction Material Capacity(Gallons) Diameter(feet)
TK 1 Toluene Carbon Steel 30,000 12
TK 11 Hydrochloric Acid Tank Fiberglass (FRP) 24,000 12
w
TK 12 Phos Acid 75% Stainless Steel 12,000 11
(Reclaimed)
TK 13 Sulfuric Acid 93% Carbon Steel 20,000 12
w
TK 14 Sulfuric Acid 50% Poly 20,000 11.2
w
TK 15 Empty Stainless Steel 8,000 7.5
TK 16 Sodium Bisulfite Stainless Steel 30,000 12.5
TK 17 Caustic Soda 25% Carbon Steel 30,000 12
DIAPHRAGM,
MEMBRANE
TK 18 Caustic Soda 50% Carbon Steel 24,000 11.7
TK 19 Empty/Not Usable Carbon Steel 1
TK 2 Ethyl Acetate Carbon Steel 30,000 12
TK 20 Caustic Soda 25% Carbon Steel 30,000 12
TK 21 Bleach Fiberglass (FRP) 13,400 12
TK 23 DEF Stainless Steel 30,000 12
w
TK 24 DEF Stainless Steel 30,000 12
w
TK 25 Alkest CS 360 Stainless Steel 5,500 8
w
TK 26 Empty Stainless Steel 5,500 8
TK 27 Sodium Thiosulfate 30% Stainless Steel 5,500 8
TK 28 NP9 Stainless Steel 5,500 8
TK 29 Citric Acid 50% Stainless Steel 6,500 8

TK 3 Acetone Carbon Steel 30,000 12
TK 30 Citric Acid 50% Stainless Steel 5,500 8
T,
TK 31 Blend Tank Stainless Steel 6,000
TK 32 Blend Tank Stainless Steel 4,000 8.5
TK 33 Blend Tank Stainless Steel 750 5.4
w
TK 34 Clean(Last contained Carbon Steel 8,000 8
Hexylene Glycol)
TK 35 Clean (Last contained Carbon Steel 8,000 8
Hexylene Glycol)
TK 4 IPA 99%USP Stainless Steel - 304 30,000 12
w
TK 5 Spirdane D-40 Carbon Steel 30,000 12
TK 6 Xylene Carbon Steel 30,000 12
TK 7 METHYL ETHYL Carbon Steel 30,000 12
KETONE
TK 8 Glycol Ether EB Carbon Steel 30,000 12
T,
TK 9 Sulfuric Acid 40% Poly 6,250 8.5
w
TK10 Blend Tank Sulfuric Poly 6,500 9

Young, Brianna A
From: David Grenoble/Mid-South/Brenntag <[e-mail]>
Sent: Friday, February 3, 2023 9:56 AM
To: Young, Brianna A
Cc: Bryon Mason/Mid-South/Brenntag
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application
NCS000611
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
My apologies, I was unclear on what exactly you needed. I added a few labels to the map that I sent but they were not
as detailed as your info below.
• Outfall SW001: Drainage area consists of the main building,truck scale,tanker parking, car parking, empty
tanker parking, and grassy area.
• Outfall SWO02: Drainage area consists of the main building,truck loading docks, and grassy areas.
• Outfall SWO03: Drainage area consists of the main building,tank farm, and outdoor IBC storage.
• Outfall SWO04: Drainage area consists of the main building,tank farm, outdoor IBC storage, and a retention
pond.
All of this is correct, I don't see anything that needs to be added or amended.
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Friday, February 3, 2023 9:41 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
This Message Is From an External Sender
This message came from outside your organization.
Good morning,
This is the map that was submitted with the application. I was hoping to get a written list to ensure I wasn't missing
anything. What I was able to determine from the map is below. Please let me know if any corrections are needed.
• Outfall SWO01: Drainage area consists of the main building,truck scale,tanker parking, car parking, empty
tanker parking, and grassy area.

• Outfall SWO02: Drainage area consists of the main building,truck loading docks, and grassy areas.
• Outfall SWO03: Drainage area consists of the main building,tank farm, and outdoor IBC storage.
• Outfall SWO04: Drainage area consists of the main building,tank farm, outdoor IBC storage, and a retention
pond.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Friday, February 3, 2023 9:27 AM
To:Young, Brianna A<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
Does the attached PDF with the areas labeled meet the needs? If not, please let me know and I will gladly get you the
information.
Thanks!
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Wednesday, February 1, 2023 10:54 AM
2

To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Subject: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
This Message Is From an External Sender
This message came from outside your organization.
Good morning,
I am working on reviewing the individual stormwater permit application for new coverage for the Brenntag
Mid-South, Inc. Charlotte Facility. This permit application has been assigned permit number NCS000611.
Please reference this permit number in all future correspondence.
After reviewing the information submitted, I need additional information in order to make sure the permit
adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity in each drainage area;
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,�: D_ E '�&'�
ti ;
NORTH CAROLINA
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
3

as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any attachments,
is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended recipient, any use, review,
dissemination, or copying of any such communication by you is strictly prohibited. If you believe you have received this
or any other electronic communication in error, please do not read, copy, use or disclose it to others; also please notify
the sender by replying to the communication, and then delete it and all accompanying files from your system. Please
verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.
4

Young, Brianna A
From: David Grenoble/Mid-South/Brenntag <[e-mail]>
Sent: Friday, February 3, 2023 9:56 AM
To: Young, Brianna A
Cc: Bryon Mason/Mid-South/Brenntag
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application
NCS000611
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
My apologies, I was unclear on what exactly you needed. I added a few labels to the map that I sent but they were not
as detailed as your info below.
• Outfall SW001: Drainage area consists of the main building,truck scale,tanker parking, car parking, empty
tanker parking, and grassy area.
• Outfall SWO02: Drainage area consists of the main building,truck loading docks, and grassy areas.
• Outfall SWO03: Drainage area consists of the main building,tank farm, and outdoor IBC storage.
• Outfall SWO04: Drainage area consists of the main building,tank farm, outdoor IBC storage, and a retention
pond.
All of this is correct, I don't see anything that needs to be added or amended.
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Friday, February 3, 2023 9:41 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
This Message Is From an External Sender
This message came from outside your organization.
Good morning,
This is the map that was submitted with the application. I was hoping to get a written list to ensure I wasn't missing
anything. What I was able to determine from the map is below. Please let me know if any corrections are needed.
• Outfall SWO01: Drainage area consists of the main building,truck scale,tanker parking, car parking, empty
tanker parking, and grassy area.

• Outfall SWO02: Drainage area consists of the main building,truck loading docks, and grassy areas.
• Outfall SWO03: Drainage area consists of the main building,tank farm, and outdoor IBC storage.
• Outfall SWO04: Drainage area consists of the main building,tank farm, outdoor IBC storage, and a retention
pond.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Friday, February 3, 2023 9:27 AM
To:Young, Brianna A<[e-mail]>
Cc: Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: [External] RE: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
Does the attached PDF with the areas labeled meet the needs? If not, please let me know and I will gladly get you the
information.
Thanks!
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Wednesday, February 1, 2023 10:54 AM
2

To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Subject: Brenntag Mid-South, Inc. Charlotte Facility stormwater application NCS000611
This Message Is From an External Sender
This message came from outside your organization.
Good morning,
I am working on reviewing the individual stormwater permit application for new coverage for the Brenntag
Mid-South, Inc. Charlotte Facility. This permit application has been assigned permit number NCS000611.
Please reference this permit number in all future correspondence.
After reviewing the information submitted, I need additional information in order to make sure the permit
adequately serves the needs of the facility. Please provide the following:
• Description of industrial activity in each drainage area;
Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
,�: D_ E '�&'�
ti ;
NORTH CAROLINA
Department of Environmental Duality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
3

as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any attachments,
is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended recipient, any use, review,
dissemination, or copying of any such communication by you is strictly prohibited. If you believe you have received this
or any other electronic communication in error, please do not read, copy, use or disclose it to others; also please notify
the sender by replying to the communication, and then delete it and all accompanying files from your system. Please
verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.
4

2/1/23, 10:54 AM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
Add Entity to My Email Notification List • View Filings • Print a Pre-Populated Annual Report form • Print
an Amended a Annual Report form
Business Corporation
Legal Name
Brenntag Mid-South, Inc.
Information
Sosld: 0604990
Status: Current-Active O
Date Formed: 9/21/2001
Citizenship: Foreign
State of Incorporation: KY
Fiscal Month: December
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: CT Corporation System
Addresses
Mailing Principal Office Reg Office
1405 Highway 136 West 1405 Highway 136 West 160 Mine Lake Ct Ste 200
Henderson, KY 42420 Henderson, KY 42420 Raleigh, NC 27615-6417
Reg Mailing
160 Mine Lake Ct Ste 200
Raleigh, NC 27615-6417
Off icers
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

2/1/23, 10:54 AM North Carolina Secretary of State Search Results
Secretary President Tax Officer Treasurer
Reeve, Leslie Gil Steadman Robert Winslow Robert Winslow
1405 Highway 136 West 1405 Highway 136 West 5083 Pottsville Pike 5083 Pottsville Pike
Henderson KY 42420 Henderson KY 42420 Reading PA 19605 Reading PA 19605
Stock
https://www.sosnc.gov/online services/search/Business_Registration_ResuIts 2/2

Young, Brianna A
From: Young, Brianna A
Sent: Thursday,January 26, 2023 10:59 AM
To: David Grenoble/Mid-South/Brenntag; Chandler, Jeffrey A; Khan, Zahid; Eplin, Jerry W
Cc: Dennis Martin/Mid-South/Brenntag;John Warner/Mid-South/Brenntag; Bryon
Mason/Mid-South/Brenntag; Willie Harshaw
Subject: RE: [External] RE: Permit Application - Brenntag Charlotte
Good morning,
The Division of Energy, Mineral, and Land Resources (DEMLR) Stormwater Permitting Program
acknowledges receipt of your application for new coverage under NPDES Permit Number NCS000611 on
January 25, 2023.
No additional information is required at this time, but we may contact you in the future. Please notify us if any
significant changes have taken place at this facility since you submitted the application package. If you have
any questions about this matter,please contact me at [e-mail] or 919-707-3647.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Thursday,January 19, 2023 5:08 PM
To:Young, Brianna A<[e-mail]>; Chandler,Jeffrey A<[e-mail]>; Khan, Zahid
<[e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: RE: [External] RE: Permit Application - Brenntag Charlotte
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
1

Not a problem. I will get the documents in the mail ASAP.
Thanks again,
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent:Thursday,January 19, 2023 4:04 PM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Chandler,Jeffrey A
<[e-mail]>; Khan, Zahid<za [e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: RE: [External] RE: Permit Application - Brenntag Charlotte
This Message Is From an External Sender
This message came from outside your organization.
Unfortunately we cannot accept electronic signatures. We will need hard copies with original signatures.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Thursday,January 19, 2023 2:30 PM
To:Young, Brianna A<[e-mail]>; Chandler,Jeffrey A<[e-mail]>; Khan, Zahid
2

<[e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: RE: [External] RE: Permit Application - Brenntag Charlotte
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hey Brianna,
My apologies. Can you accept emailed (signed in Acrobat) copies or do we need to mail them?
Thanks,
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent:Thursday,January 19, 2023 11:15 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Chandler,Jeffrey A
<[e-mail]>; Khan, Zahid <za [e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: RE: [External] RE: Permit Application - Brenntag Charlotte
This Message Is From an External Sender
This message came from outside your organization.
Good morning David,
We received the permit application and check for the Brenntag Charlotte facility on January 18, 2023. However, the
application was incomplete.A signature is required on Form 2F under item 5.1 (Non stormwater discharges) and item
10.2 (Certification statement). In addition, EPA Form 1 was missing. In order for the application to be received as
complete and processed, we require EPA Form 1 to be completed, signed, and submitted, and EPA Form 2F to be signed
in all appropriate locations and resubmitted. Please let me know if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
3

[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Friday,January 13, 2023 3:22 PM
To:Young, Brianna A<[e-mail]>; Chandler,Jeffrey A<[e-mail]>; Khan, Zahid
<[e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: RE: [External] RE: Permit Application - Brenntag Charlotte
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good afternoon,
The storm water permit application packet and payment has been mailed out certified mail and should be delivered to
your offices Tuesday or Wednesday next week. USPS tracking number is 7014 0150 00010865 9762.
Please let us know if you need anything further.
Thanks all,
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Wednesday,January 11, 2023 11:21 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Chandler,Jeffrey A
<[e-mail]>; Khan, Zahid <za [e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: RE: [External] RE: Permit Application - Brenntag Charlotte
4

This Message Is From an External Sender
This message came from outside your organization.
Hello David,
Thank you for the update.Yes,that is the correct mailing address, however, please address it to my attention so it gets
to the right office.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Please check with the appropriate staff before visiting our offices,
as we may be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the public
during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Wednesday,January 11, 2023 11:11 AM
To: Chandler,Jeffrey A<[e-mail]>;Young, Brianna A<[e-mail]>; Khan, Zahid
<[e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: [External] RE: Permit Application - Brenntag Charlotte
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning everyone,
Just a quick update, we received the paper check today from our corporate AP. I will get the application and check in the
mail first thing in the morning.
Can someone kindly confirm that the correct mailing address is:
NCDEQ
1612 Mail Service Center
Raleigh, NC 27699-1612
5

Thanks in advance!
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
B BRE N NTAG
+1 270.869.5806
From: David Grenoble/Mid-South/Brenntag
Sent: Friday, December 2, 2022 12:55 PM
To: Chandler,Jeffrey A<[e-mail]>;Young, Brianna A<[e-mail]>; Khan, Zahid
<[e-mail]>; Eplin,Jerry W<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>;John Warner/Mid-South/Brenntag
<[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>; Willie Harshaw
<[e-mail]>
Subject: RE: Permit Application - Brenntag Charlotte
Good afternoon all,
Jeffrey—Thank you for the phone call.
As discussed,this application for our Charlotte individual permit was just finalized this morning. I am attaching the
signed electronic copy here for reference along with the technical drawings.
I will get a request to our corporate AP for any applicable fee(s) and get the hard copy in the mail ASAP.
Thank you all,
- David
David Grenoble
Regional Safety, Regulatory,and Quality Manager
Brenntag Essentials
B BRE N NTAG
Brenntag Mid-South, Inc.
2000 East Pettigrew Street
Durham, North Carolina, USA
+1 270.869.5806
From: Chandler,Jeffrey A<[e-mail]>
Sent: Friday, December 2, 2022 12:46 PM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Young, Brianna A<[e-mail]>;
Khan, Zahid <[e-mail]>; Eplin,Jerry W<[e-mail]>
Subject: RE: [External] RE: Permit Application
This Message Is From an External Sender
6

This message came from outside your organization.
David,
As discussed over the phone today you will be providing all the necessary paperwork and checks for an individual permit
for the Brenntag Mid-South Facility located in Charlotte NC.
Please follow up with this email to confirm that is the case and attach all necessary electronic documents.You must also
submit hard copies to our Raleigh office for review with a check included to cover any fees.
Thank you,
Let me know if you have any questions.
Jeffrey A. Chandler
Environmental Specialist II
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Cell: (704)-677-0025
Office: [phone] x2148
Fax: [phone]
Email: Jeffrey.Chandler(&ncdenr.gov
Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115
D.- E i�77.�_
Q_
DeW rtw i%t of i a a u✓rnrc 1ri.,I ..cq
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Wednesday,July 20, 2022 2:45 PM
To:Young, Brianna A<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,Jeffrey A
<ieffrey.chandler@ncdenr.�ov>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Carson, Brittany<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good afternoon all,

We believe we FINALLY have all the paperwork in order for the permit application/N01.There will be a hard copy with
the applicable check payment placed in the mail today but I wanted to get everything in your hands ASAP so I am
attaching soft copies of everything here. Please review it as/if you are able and don't hesitate to let us know if there is
anything further needed to get this process where it needs to be.
Again, thank you all for your assistance in this case and we look forward to continuing to work together.
Be safe,
- David
David M.Grenoble
M:270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Friday,July 8, 2022 10:27 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Carson, Brittany<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
Good morning David,
Sorry to hear that! Thank you for the update. Please note that if you are applying for coverage under the NCG080000,
Brittany Carson will be the permit application reviewer. Brittany is the Industrial General Permits Coordinator and I have
copied her on this email.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
8

From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Friday,July 8, 2022 10:17 AM
To:Young, Brianna A<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,Jeffrey A
<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning all,
Just a quick update. I apologize for the time lapse, my whole family was hit with COVID over the last couple weeks.
Today is my fist day off quarantine and I am trying to get my feet back under me.We have a intent letter drafted for
coverage under General Stormwater Permit NCDEQ NCG08 but are waiting on CAD drawings for the facility layout. I
have been informed by our consultant that the drawings should be done within the next few business days at which
time we will add them to the documentation and submit everything at once.
Thank you all as always for your support and assistance in this project!
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
BRENNT
From:Young, Brianna A<[e-mail]>
Sent: Monday,April 18, 2022 10:43 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
David,
I should be the primary point of contact for the questions related to the permit application.
9

Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:34 AM
To: Kay, Lily C<[e-mail]>; Chandler,Jeffrey A<[e-mail]>; Young, Brianna A
<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
I understand! Arcadis and I have been in contact and they have reached out to some of the facilities outside of my
region to see how their program/permit is written. Would it be better to work directly with Brianna (now copied)? I am
having some turmoil about how long Arcadis is taking to get us what we need.
Thanks!
- David
David M.Grenoble
M:270.869.5806
From: Kay, Lily C<[e-mail]>
Sent: Monday,April 18, 2022 10:31 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Chandler,Jeffrey A
<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
10

Brianna is the permit writer and should be able to help, but if you need something from me or Jeffrey,just let us
know. We were about to issue an NOV because we had not heard anything. With all of the different liquids you have, it
may take us a minute to evaluate which permit conditions are relevant to this facility.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:26 AM
To: Kay, Lily C<[e-mail]>; Chandler,Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Not a problem at all Lily.
Given that this is new to us,we are hitting a few bumps in the road (hence why we are working with Arcadis). Is there
anyone with the State or with Mecklenburg County that we can reach out to in order to seek guidance on the process in
the event we need any further? I feel like this shouldn't be a difficult or drawn out process but without much experience
in the arena, it is proving to be.
Thanks again!
- David
David M.Grenoble
M:270.869.5806
From: Kay, Lily C<[e-mail]>
Sent: Monday,April 18, 2022 10:21 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Young, Brianna A<[e-mail]>;
Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>; Chandler,Jeffrey A<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Khan,
Zahid <[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
David,
Please keep Jeffrey Chandler and I informed on the status of this application.
Thanks,
Lily
Z4 5Z�"
Environmental Specialist

Land Quality Division
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Physical and Mailing Address: 610 E. Center Ave. Suite 301
Mooresville, NC 28115
`Nothing Compares
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:12 AM
To:Young, Brianna A<[e-mail]>; Dennis Martin/Mid-South/Brenntag<[e-mail]>;
Bradley, Lauren M. <Lauren.Brad [e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Kay,
Lily C<[e-mail]>; Khan,Zahid <[e-mail]>; Bryon Mason/Mid-South/Brenntag
<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning all,
I just wanted to provide an update from Brenntag on the progress of the permit application. We are currently working
with Arcadis and their engineers to get the individual permit set up as well as likely draft and implement a SWPPP for
our Charlotte facility.
I do not believe anyone has requested status updates; however, if there is anyone on this email chain or otherwise that
would like to keep up-to-date of where we are in the process please let me know and I will be happy to send out status
reports as applicable.
Again, thank you all for your assistance in this matter.
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
12

Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
BRENNTAGAMi
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 17, 2022 8:58 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Dennis Martin/Mid-South/Brenntag
<[e-mail]>; Bradley, Lauren M. <[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Kay,
Lily C<[e-mail]>; Khan,Zahid <[e-mail]>
Subject: [EXTERNAL]RE: [External] RE: Permit Application Contact Information
Good afternoon,
I apologize for the delay in addressing this question. Per representatives from Brenntag Charlotte,the SIC code for the
site is 5169. Although NPDES regulations do not automatically permit coverage for facilities with this SIC code, 40 CFR
122.26 allows for NC DEQ's authority to designate discharges and require permits for sites that have the potential to
impact surface water quality because of pollutant contribution.After consultation with both DEQ Mooresville Regional
Office and Charlotte-Mecklenburg Stormwater Services staff, DEQ is requiring that Brenntag Charlotte apply for
stormwater permit coverage. Please review our Industrial Permitting website here for both general and individual
permits to decide which permit coverage best fits your facility/site operations.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your
patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:48 AM
13

To: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<Richard.Farmer@mecklenbu rgcountync.gov>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
It seems like this question keeps circling around and we have yet to be able to collectively bring it to a close.As we have
previously communicated, we will be more than happy to apply for/obtain a storm water permit if indicated. As of our
most recent conversations with Mecklenburg County representatives and Mrs. Young, it is still unclear if this
requirement is applicable to our Charlotte facility or not. We obviously want to do the right thing and maintain full
compliance and cooperation. Can anyone advise definitively if we need a permit and, if so,what the process is to apply
for and obtain one?
Thank you all,
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
BRENNTAGAN
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:26 AM
To: Bradley, Lauren M. <[e-mail]>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<Richard.Farmer@ mecklenburgcountync.gov>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: RE: Permit Application Contact Information
Including our previous correspondence. Please let me know what other information is needed.
Dennis Martin
Operations Manager
BRENNTA
14

Brenntag Mid-South -Charlotte
11750 Fruehauf Dr
Charlotte, NC 28273
980-500-3857(desk)
270-577-4893(cell)
Email:dmartin(a)brenntao.com
www.brenntag.com/Mid-South
Con nectingl Chi a ran T S#ry
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Wednesday, February 23, 2022 2:56 PM
To: Bradley, Lauren M. <Lauren.Bradley@mecklen burgcountync.gov>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<Richard.Farmer@ mecklenburgcountync.gov>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: Re: Permit Application Contact Information
Including David Grenoble, our SRQ.
Get Outlook for iOS
From: Bradley, Lauren M. <[e-mail]>
Sent: Wednesday, February 23, 2022 2:49:38 PM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [EXTERNAL]Permit Application Contact Information
Good evening Dennis,
Please contact Brianna Young, Industrial Individual Permits Coordinator, with NC DEQ/ Division of Energy,
Mineral, and Land Resources (DEMLR) to apply for your permit. She is CC'ed on this email.
[e-mail]
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Thank you for your cooperation during todays sampling event. If you have any questions please feel free to
reach out.
Best,
Lauren Bradley
Environmental Specialist II
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
,.,MATER
.��gso_�_ (D
15

We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
This communication and any documents accompanying this email transmission may be subject to the attorney-client
privilege or be considered attorney work product.
If you believe that you received this email in error, please do not read, copy, use or disclose this communication to
others; also please notify the sender by replying to this message, and then delete it from your system. Please verify that
you will delete the e-mail in your reply.Thank you.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any attachments,
is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended recipient, any use, review,
dissemination, or copying of any such communication by you is strictly prohibited. If you believe you have received this
or any other electronic communication in error, please do not read, copy, use or disclose it to others; also please notify
the sender by replying to the communication, and then delete it and all accompanying files from your system. Please
verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.
16

United States Office of Water EPA Form 3510-1
Environmental Protection Agency Washington. D.C. Revised March 2019
Water Permits Division
. EPA Application Form 1
General Information
NPDES Permitting Program
JAN 2 5 2023
Note: All applicants to the National Pollutant Discharge Elimination System (NPDES) permits
program, with the exception of publicly owned treatment works and other treatment works treating
domestic sewage, must complete Form 1. Additionally, all applicants must complete one or more of the
following forms: 2B,2C, 2D, 2E, or 2F. To determine the specific forms you must complete, consult the
"General Instructions" for this form.

Paperwork Reduction Act Notice
The U.S. Environmental Protection Agency estimates the average burden to collect information
and complete Form 1 to be 2.9 hours for new applicants and 0.9 hours for applicants renewing
existing permits. This estimate includes time to review instructions, search existing data sources,
gather and maintain the needed data, and complete and review the collection of information.
New respondents must also prepare a topographic map. Send comments about the burden
estimate or any other aspect of this collection of information to the Chief, Information Policy
Branch(PM-223), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue,NW,
Washington, DC 20460, and to the Office of Information and Regulatory Affairs, Office of
Management and Budget, 725 17a'Street,NW, Washington, DC 20503, marked "Attention:
Desk Officer for EPA."

DESCRIPTION OF NPDES PERMIT APPLICATION FORMS CONTENTS OF FORM 1 PACKAGE
The application fortes for individual National Pollutant Discharge Form 1—General Instructions
Elimination System(NPDES)permits include the following: Form 1—Line-by-Line Instructions
Form 1—General Information(included in this package), Form 1—Activities That Do Not Require Permits
Form 2—Forms Based on Facility or Activity Type (not included Form 1—Glossary
in this package): Form 1—Application
2A. New and Existing Publicly Owned Treatment Works
2B. Concentrated Animal Feeding Operations and
Concentrated Aquatic Animal Production Facilities
2C. Existing Manufacturing,Commercial,Mining,and
Silvicultural Operations
2D. New Manufacturing,Commercial, Mining,and Silvicultural
Operations That Have Not Yet Commenced Discharge of
Process Wastewater
2E. Manufacturing,Commercial,Mining,and Silvicultural
Facilities Which Discharge Only Nonprocess Wastewater
2F, Stormwater Discharges Associated with Industrial Activity
2S. New and Existing Treatment Works Treating Domestic
Sewage _
FORM 1—GENERAL INSTRUCTIONS
Who Must Apply for an NPDES Permit? Upon your request,and based on information supplied by you,
With the exceptions described in"Form 1—Activities That Do Not EPA or the authorized NPDES state will determine whether you
Require Permits,"the federal Clean Water Act(33 U.S.C. 1251 et are required to obtain a permit for a particular facility or activity.
seq.) prohibits any person from discharging pollutants into waters Be sure to contact EPA or your state if you have a question,
of the United States without first having been issued a permit Form 1 collects general information only.You must also complete
under the NPDES program. a more detailed application based on your proposed discharge
Who Must Complete Form 1? activity, as follows:
All applicants,other than publicly owned treatment works • If your facility is a concentrated animal feeding operation
(POTWs)and treatment works treating domestic sewage or a concentrated aquatic animal production facility,you
(TWTDS), must submit Form 1. If you operate one of the must also complete Form 2B.
following facilities,you must submit form 1:concentrated animal • If your facility is an existing manufacturing,commercial,
feeding operations and aquatic animal production facilities; mining,or Silvicultural facility that currently discharges
manufacturing,commercial,mining,and silvicultural operations; process wastewater,you must also complete Form 2C.
or other industrial facilities. a If your facility is a new manufacturing,commercial,mining,
At the state level,either the U.S. Environmental Protection or Silvicultural facility that has yet to commence discharge of
Agency(EPA)or an approved state agency administers the process wastewater,you must also complete Form 2D,
NPDES permit program. If you are located in a jurisdiction in • If your facility is a new or existing facility(including
which an EPA regional office administers the NPDES permit manufacturing,commercial, mining,and silvicultural
program,you should use Form 1 and all other applicable forms facilities)that discharges only nonprocess wastewater,
described in these instructions. If you are located in a jurisdiction you must also complete Form 2E.
where a state administers the NPDES permit program,contact , If your facility is a new or existing facility whose discharge
the state to determine the forms you should complete. States is composed entirely of stormwater associated with industrial
often develop their own application forms rather than use the activity--excluding discharges from construction activity
federal forms.See http:llwww.epa.gov/npdes/npdes-state- under 122,26(b)(14)(x)or(b)(15�—you must also complete
program-information for a list of states that have approved Form 2F. If the discharge is composed of stormwater and
NPDES permit programs and those that do not. non-stormwater,you must complete Form 2F and you must
Exhibit 1-1 (see end of this section)provides contact information also complete Forms 2C,2D,and/or 2E,as appropriate.See
for each of EPA's 10 regional offices.Since the exhibit's content is Form 2F's instructions for further details.
subject to change,consult EPA's website for the latest information:
http:llwww.epa.gov/aboutepa#regional.
1-1

FORM 1—GENERAL INSTRUCTIONS CONTINUED
Where to File Your Completed Form Completion of Forms
• If you are in a jurisdiction with an approved state NPDES Print or type in the specified areas only.If you do not have enough
permit program,file according to the instructions on the state space on the form to answer a question,you may continue on
forms. additional sheets,as necessary,using a format consistent with the
• If you are in a jurisdiction where EPA is the NPDES form.
permitting authority(i.e.,the state is not an NPDES- The NPDES permitting authority could consider your application
authorized state),mail the completed application forms to the incomplete if you do not provide an answer(or indicate"NA"for
EPA regional office that covers the state in which your facility "not applicable")for all questions on Form 1 and the applicable
is located(see Exhibit 1-1). Form 2.
When to File Your Completed Form Provide your EPA Identification Number from the Facility Registry
Because of statutory and regulatory requirements,the deadlines Service,NPDES permit number,and facility name at the top of
for filing applications vary according to your facility or activity type each page of Form 1 and any attachments.If your facility is new
and the type of permit you need.The various permit application (i.e.,not yet constructed),write or type"New Facility"in the space
deadlines are listed in Exhibit 1-2 at the end of this section. provided for the EPA Identification Number and NPDES number.
If you do not know your EPA Identification Number,contact your
Fees NPDES permitting authority.See Exhibit 1-1 for contact
EPA does not require applicants to pay a fee for applying for information.
NPDES permits.However,states that administer the NPDES Do not leave any response areas blank unless the form directs
permit program may charge fees.Consult with state officials for you to skip them.If the form directs you to respond to an item that
further information. does not apply to your facility or activity,enter"NA"for"not
Public Availability of Submitted Information applicable"to show that you considered the item and determined
a response was not necessary for your facility.
EPA will make information from NPDES permit application forms The NPDES permitting authority will consider your application
available to the public for inspection and copying upon request. complete when it and any supplementary material are received
You may not claim any information on Form 1 (or related and completed according to the authority's satisfaction.The
attachments)as confidential. NPDES permitting authority will judge the completeness of any
You may make a claim of confidentiality for any information that application independently of the status of any other permit
you submit to EPA that goes beyond the information required by application or permit for the same facility or activity.
Form 1.If you do not assert a claim of confidentiality at the time
you submit your information to the NPDES permitting authority,
EPA may make the information available to the public without
further notice to you.EPA will handle claims of confidentiality in
accordance with the Agency's business confidentiality regulations
at Part 2 of Title 4 of the Code of Federal Regulations(CFR).
1-2

FORM 1—GENERAL INSTRUCTIONS CONTINUED
Exhibit 1-1.Addresses of EPA Regional Contacts and Covered States
REGION 1 REGION 6
U.S.Environmental Protection Agency,Region 1 U.S.Environmental Protection Agency,Region 6
5 Post Office Square,Suite 100,Boston,MA 02109-3912 1445 Ross Avenue,Suite 1200,Dallas,TX 75202.2733
Phone:[phone];toll free:[phone] Phone:[phone]G;tot!free:[phone]
Fax:[phone] Fax:[phone]
Website:http:llwww.epa_aovlahoutepaleoa-region-i-new-england Website:hup hvww.epa.govlaboutepafepa-region-6-south-central
Covered states:Connecticut,Maine,Massachusetts,New Hampshire,Rhode Covered states:Arkansas,Louisiana,New Mexico,Oklahoma,and Texas
Island,and Vermont
REGION 2 REGION 7
U.S.Environmental Protection Agency,Region 2 U.S.Environmental Protection Agency,Region 7
290 Broadway,New York,NY 10007-1866 11201 Renner Boulevard,Lenexa,KS 66219
Phone:[phone];toll free:[phone] Phone:[phone]G03;tali free:[phone]
Fax:[phone] Website:hoJMrww.epa.govlaboutepalepa-region-7-midwest
Website:hit2:llwww.epa-govlaboutepalepa-region-2 Covered states:Icava,Kansas,Missouri,and Nebraska
Covered states:New Jersey,New York,Virgin Islands,and Puerto Rico
REGION 3 REGION 8
U.S.Environmental Protection Agency,Region 3 U.S.Environmental Protection Agency,Region 8
1650 Arch Street,Philadelphia,PA 19103-2029 1595 Wynkoop Street,Denver,CO 80202-1129
Phone:[phone];toll free:[phone] Phone:[phone];toll free:[phone]
Fax:[phone] Fax:[phone]
Website;http:liwww.epa.govlaboutei) lepa4egion-3-mid-atlantic Website:httpJW".epa.govlaboultpaiepa-re ion-8-mountains-and- Ip ains
Covered states:Delaware,District of Columbia,Maryland,Pennsylvaria,Virginia, Covered states:Colorado,Montana,North Dakota,South Dakota,Utah,and
and West Virginia Wyoming
REGION 4 REGION 9
U.S.Environmental Protection Agency,Region 4 U.S.Environmental Protection Agency,Region 9
Sam Nunn Atlanta Federal Center 75 Hawthome Street,San Francisco,CA 94105
61 Forsyth Street,SW,Atlanta,GA 30303-8960 Phone:[phone];toll free:(866)EPA-WEST
Phone'.[phone];toll free:[phone] Fax:[phone]
Fax:[phone] Website:http:llwww.epa.00vlabaulepalepa-region-9-pacific-southwest
Website:ht -;www.e a. ovlaboute alabout-e a-r ion-4-southeast Covered states:Arizona,California,Hawaii,Nevada,Guam,American Samoa,
Covered states:Alabama,Florida,Georgia,Kentucky,Mississippi,North Carolina, and Trust Territories
South Carolina,and Tennessee
REGION 5 REGION 10
U.S.Environmental Protection Agency,Region 5 U.S.Environmental Protection Agency,Region 10
77 West Jackson Boulevard,Chicago,IL 60604-3507 1200 Sixth Avenue,Suite 900,Seattle,WA 98101
Phone:[phone];toll tree:[phone] Phone:[phone]:toll free:(800)4244372
Fax:[phone] Fax:[phone]
Website:ht Jlwww,e a. ovlaboute ale a-re ion-5 Website:linp:l*m.epa.govlaboutepaiepa-region-10-pacific-northwest
Covered stales:Illinds,Indiana,Michigan,Minnesota,Ohio,and Wisconsin Covered states:Alaska,Idaho,Oregon,and Washington
Exhibit 1-2.Filing Dates for NPDES Permit Applications
Permit Application When to File i 1
180 days before your present NPDES permit expires or,if you are a
2A new discharger,180 days before the date on which the discharge is
to commence unless the NPDES permitting authority has granted
permission for a later date.
2B 180 days before your present NPDES pennit expires or 180 days
prior to startup if you are a new facility.
2C 180 days before your present NPDES permit expires.
2D 180 days prior to startup.
2E 180 days before your present NPDES permit expires,or 180 days
prior to startup if you are a new faciilty.
Construction:90 days prior to date oomstruction is to commence.
2F Nonconstruction:180 days before your present NPDES permit
expires or 180 days prior to startup if you are a new facility.
25 180 days before your present NPDES pen-nit expires or 180 days
prior to startup if you are a new faciMy.
1-3

FORM 1—LINE-BY-LINE INSTRUCTIONS
Section 1.Activities Requiring an NPDES Permit You can find SIC code numbers and descriptions in the
Item 1.1.Review the questions in Item 1.1 to determine if you are 1987 Standard Industrial Classification Manual, prepared by the
required to submit Form 1.Be sure to check the Form 1— Executive Office of the President,Office of Management and
Glossary for the legal definitions of any key terms. Budget.This document is available from the Government Printing
Office,Washington, D.C.An online version of the manual is also
If you answer"Yes"to a question in Item 1,1,then you do not available courtesy of the Occupational Safety and Health
need to complete Form 1,but you must comply with the Administration at http:liwww.osha.gov/pWimis/sic manual.html.
application requirements specified.
You can find NAICS code numbers and descriptions in the North
Item 1.2.Respond to the questions in Items 1.2.1 to 1.2.5. If you American Industrial Classification System Manual prepared by the
answer"Yes"to any question,you must complete Form 1 and the Executive Office of the President, Office of Management and
Form 2 application specified. See Exhibit 1-2 for filing deadlines, Budget,This document is available from the National Technical
If you answer"No"to every question in items 1.1 and 1.2,then Information Service(NTIS)in Alexandria,Virginia.It is also
you do not need an NPDES pennit,and you do not need to available online at http:liwww.censua.-ovleosiwwwinaicsi.
complete and return any of the NPDES application forms. Use the latest edition of the manuals. If you have any questions
Section 2.Name,Mailing Address,and Location about the appropriate SIC or NAILS codes for your facility,
Item 2.1.Enter the facility's official or legal name. Do not use a contact your NPDES permitting authority.
colloquial name. Section 4.Operator Information
Item 2.2.Provide your EPA Identification Number from the Item 4.1.Give the legal name of the person,firm,public
Facility Registry Service if you have an existing facility. If you do organization,or other entity that operates the facility described in
not know your EPA Identification Number,contact your NPDES this application.This may or may not be the same as the facility's
permitting authority, If your facility is new(i.e.,not yet name.The operator of the facility is the legal entity that controls
constructed),write or type"New Facility." the facility's operation rather than the plant or site manager. Do
not use a colloquial name.
Item 2.3.Give the name(first and last),title,work telephone
number,and email address of the person who is thoroughly Item 4.2.Indicate whether the entity listed in response to Item 4.1
familiar with the operation of the facility and with the facts also owns the facility by marking the appropriate box,
reported in this application.The NPDES permitting authority will Item 4.3. Indicate the ownership status of the operator of the
contact the person listed if they have questions on the material facility by marking the appropriate box. If the facility is a federal
submitted, facility(i.e.,owned by the U.S,government),check the box for
Item 2.4. Give the complete mailing address of the office to which "Public--federal,"If the facility is owned by a state government,
the NPDES permitting authority should send correspondence, check the box for"Public--state."If the facility is owned by a
This often is not the address used to designate the location of the county government,municipal(e.g.,city or town)government,
facility or activity. tribal government,school district,water district,or other local
government entity,check the box for"Other public"and specify
Item 2.5.Give the address or location of the facility identified the type of government entity.If the facility is owned by a
under Item 2.1. If the facility lacks a street name or route number, corporation or other private entity,check the box for"Private."If
give the most accurate,alternative geographic information(e,g., the facility has mixed ownership(e,g., publiciprivate)or is not
section number or quarter section number from county records or owned by an entity of the types previously listed,check the box
"at intersection of Routes 425 and 22").Also provide the county for"Other"and specify the type of entity.
name,county code(if known),city or town,state,and zip code.
Items 4.4 to 4.6.Enter the telephone number,address,and email
For concentrated aquatic animal production facilities,provide the address of the operator identified in Item 4.1.
address or location of the production area(i.e„the location where
the animals are contained,grown,or held). Section 5.Indian Land
Section 3.SIC and NAICS Codes Item 5.1.Indicate whether the facility is located on Indian Land.
Items 3.1 and 3.2.List,in descending order of significance, up to section 6,Existing Environmental Permits
four 4-digit standard industrial classification(SIC)codes and Item 6.1.Check the appropriate boxes and provide the permit
North American Industrial Classification System(NAILS)codes numbers for all relevant federal,state,and local environmental
that best describe your facility in terms of the principal products or permits or construction approvals received or applied for under
services it produces or provides.If the SIC or NAICS codes do any of the programs listed below. If you have more than one
not adequately describe your facility's products or services,you currently effective permit under a particular permit program for
have the option to provide additional descriptive information. your facility,list the additional permit numbers on the application
form or on a separate sheet of paper.
1-4

FORM 1—LINE•BY•LINE INSTRUCTIONS CONTINUED
• Hazardous waste management program under the Resource (e.g.,residential,commercial).An example of an acceptable
Conservation and Recovery Act(RCRA). location map is shown as Exhibit 1-3 at the end of these
• Underground Injection Control(UIC)program under the Safe instructions.Note:Exhibit 1-3 is provided for illustration only;it
Drinking Water Act(SDWA). does not show an actual facility.
• NPDES program under the Clean Water Act(CWA). If the facility is a concentrated animal feeding operation,you are
• Prevention of Significant Deterioration(PSD)program under not required to provide the topographic map required by this
the Clean Air Act(CAA). section of Form 1.Instead,you are required to provide a
topographic map as specified in Section 4 of Form 2B.
• Nonattainment program under the CAA.
Item 7.1.Note that you have completed your topographic map
• National Emission Standards for Hazardous Pollutants(NESHAPs)preconstruciion approval under the CAA. and attached it to the application.
Section ti.Nature of Business
• Ocean dumping permits underthe Marine Protection
Research and Sanctuaries Act(MPRSA). Briefly describe the nature of your business(e.g.,products
produced or services provided).See Examples 1 and 2.
• Dredge or fill permits under Section 404 of the CWA.
Other federal,state,or local environmental permits. Example 1
• Facilities Subject to 40 CFR 426,Subparts F and G
Section 7.Map Industry A is an auto tempered and auto laminated glass
Unless the facility is a concentrated animal feeding operation, manufacturing facility subject to effluent limitation guidelines
provide a topographic map(s)of the area extending at least one (ELGs)for the"Automotive Glass Tempering"and"Automotive
mile beyond the property boundaries of the facility that clearly Glass Laminating"subcategories of the"Glass Manufacturing"
shows the following, point source category at 40 CFR 426,subparts F and G.At the
• The legal boundaries of the facility. facility,glass is cut and then passed through a series of
processes that grind and polish the edges,bend the glass,and
• The location and serial number of each of your existing and then temper the glass to produce side and back windows for
proposed intake and discharge structures. automobiles.Tempering involves heating the glass near the
• All hazardous waste management,storage,and disposal melting point,then rapidly cooling it to increase its mechanical
facilities. and thermal endurance.The facility also produces automobile
• Each well where you inject fluids underground. windshields and undertakes processes that laminate a plastic
sheet between two layers of glass and that prepare the glass for
• All wells,springs,surface water bodies,and drinking water lamination(e.g., cutting,bending, and washing).
wells that are in the public record or otherwise known to you
and that are located in the map area. Example 2
If the facility has associated water intakes,discharge structures, Facility Not Subject to ELGs
hazardous waste disposal sites,or injection wells and these items Industry B undertakes batch-type resin manufacturing operations,
are located more than one mile from the facility,include them on It has aboveground storage tanks for raw materials and finished
the map if possible.If you cannot,attach additional sheets goods,resin loading operations,and warehouses for 55-gallon
describing the location of the structures,disposal site(s),or well(s) drums of finished product. Industry B manufactures alkyd,
and identify the U.S. Geological Survey(USGS)or other map saturated and unsaturated polyester resins in batches using
corresponding to the location(s). reactor vessels and mix tanks. Most of the feedstock liquids are
pumped from storage tanks to the kettles and mixers via a closed
On each map,include the map scale,a meridian arrow showing piping system.Additional feedstocks are added manually as
north,and latitude and longitude to the nearest second. Latitude solids from bags and sacks via manways,which are located on
and longitude coordinates may be obtained in a variety of ways, top of the kettles.The resin is then chemically reacted in the
including use of hand held devices(e.g.,a GPS enabled kettles.After the reaction step finishes,the resin is transferred
smartphone),internet mapping tools(e.g., from the kettles to the mix tanks,where solvents are added to
httos:/Imynasadata.larc.nasa,gov/latitudelongitude-finder/), thin it.The primary byproduct of the reaction is water vapor
geographic information systems(e.g.,ArcView),or paper maps containing condensed soluble organics.The byproduct flows to
from trusted sources(e.g.,USGS). an isolation tank where the vapors are directed to an onsite
On all maps of rivers,show the direction of the current.In tidal thermal oxidizer.The finished resin is then pumped through one
waters,show the directions of ebb and flow tides. of three types of filtration systems into finished goods storage
tanks,55-gallon drums,350-gallon intermediate bulk container
You may develop your map by going to USGS's National 10ap totes,or directly into tanker trucks.A typical batch takes about 30
website at httpvi/nationalmap.covl.(For a map from this site,use hours to complete.
the traditional 7.5-minute quadrangle format.If none is available,
use a USGS 15-minute series map.)You may also use a plat or
other appropriate map.Briefly describe land uses in the map area
1-5

FORM 1—LINE-BY-LINE INSTRUCTIONS CONTINUED
Section 9.Cooling Water Intake Structures FEDERAL REGULATIONS AT 40 CFR 122.22 REQUIRE THIS
Item 9.1.Indicate whether the facility uses cooling water.If yes, APPLICATION TO BE SIGNED AS FOLLOWS:
continue to Item 9.2.If no,skip to Item 10.1. A. For a corporation,by a responsible corporate officer.For the
Item 9.2.Identify the source of the cooling water.For example, purpose of this section,a responsible corporate officer
indicate whether the cooling water is from a surface water, means:(1)a president,secretary,treasurer,or vice-president
groundwater well,public water system,or treated effluent that of the corporation in charge of a principal business function,
would otherwise be discharged to a water of the U.S. or any other person who performs similar policy-or decision-
making functions for the corporation,or(2)the manager of
If the facility uses a cooling water intake structure as described in one or more manufacturing,production,or operating facilities,
40 CFR 125,Subparts I and J,the facility may have additional provided the manager is authorized to make management
application requirements under 40 CFR 122.21(r).Note that the decisions which govern the operation of the regulated facility
information required by 40 CFR 122.21(r)is not requested as part including having the explicit or implicit duty of making major
of Form 1.Contact your NPDES permitting authority to determine capital investment recommendations,and initiating and
the specifics of what you should provide and when. directing other comprehensive measures to assure long term
Section 10.Variance Requests environmental compliance with environmental laws and
An applicant(other than a POTW)may request a variance from regulations;the manager can ensure that the necessary
otherwise applicable effluent limitations under certain conditions systems are established or actions taken to gather complete
described at 40 CFR 122.21(m). and accurate information for permit application requirements;
and where authority to sign documents has been assigned or
Item 10.1.If known at the time of application,check all of the delegated to the manager in accordance with corporate
authorized variances that you plan to request or renew.Note that procedures.
you are not being asked to submit any other information at this B. For a partnership or sole proprietorship,by a general partner
time.Contact your NPDES permitting authority to determine the or the proprietor,respectively.
specifics of what you should provide and when.The ability to
request a variance is not limited to the time of application,and an C. For a municipality,state,federal,or other public facility,by
applicant may request a variance consistent with statutory and either a principal executive officer or ranking elected official.
regulatory requirements. For purposes of this section,a principal executive officer of a
federal agency includes:(1)The chief executive officer of the
Section 11.Checklist and Certification agency,or(2)a senior executive officer having responsibility
Item 11.1.Review the checklist provided.In Column 1,mark the for the overall operations of a principal geographic unit of the
sections of Form 1 that you have completed and are submitting agency(e.g.,Regional Administrators of EPA).
with your application.In Column 2,indicate for each section
whether you are submitting attachments.
Item 11.2.The Clean Water Act provides for severe penalties for
submitting false information on this application form.CWA Section
309(c)(2)provides that,"Any person who knowingly makes any
false statement,representation,or certification in any application,
...shall upon conviction,be punished by a fine of no more than
$10,000 or by imprisonment for not more than six months,or
both."
1-6

Exhibit 1-3.Example Topographic Map
V.4.M>'M7M(>rt d•1MC la1(bQq
u.s,ua«xu tiuM r :U5 Topo
CENTRAL PROCESSING CO.
001\
- Intake \. -
Wage Ales
CENTRAL Crr( mjeLa�^
wd
Hwm■ _ _
Waeme Area -- �-
t _
Loeal*n Map
Conn,Proocaa:np Ca
Central Cty Otl�
1-7

FORM 1—ACTIVITIES THAT DO NOT REQUIRE PERMITS
You are not required to obtain an NPDES permit if your discharge • Any discharge in compliance with the instructions of an On-
is in one of the following categories,as provided by the CWA and Scene Coordinator pursuant to 40 CFR 300(The National Oil
NPDES regulations at 40 CFR 122 to 125.(However,under CWA and Hazardous Substances Pollution Contingency Plan)or
Sections 510 and 312,some discharges exempted from the 33 CFR 153.10(e)(Pollution by Oil and Hazardous
federal NPDES requirements may still be regulated by a state Substances).
permitting authority.) Any introduction of pollutants from non point-source
• Any discharge of sewage from vessels and any effluent from agricultural and silvicultural activities,including stormwater
properly functioning marine engines,laundry,shower,and runoff from orchards,cultivated crops,pastures,range lands,
galley sink wastes,or any other discharge incidental to the and forest lands,but not discharges from concentrated
normal operation of a vessel,including vessels of the Armed animal feeding operations as defined in 40 CFR 122,23,
Forces within the meaning of section 312 of the CWA and discharges from concentrated aquatic animal production
recreational vessels within the meaning of section 502(25)of facilities as defined in 40 CFR 122.23,discharges from
the CWA.None of these exclusions apply to rubbish,trash, concentrated aquatic animal production facilities as defined
garbage,or other such materials discharged overboard;nor in 40 CFR 122.24,discharges to aquaculture projects as
to other discharges when the vessel is operating in a defined in 40 CFR 122.25,and discharges from silvicultural
capacity other than as a means of transportation such as point sources as defined in 40 CFR 122.27.Note:Per 40
when used as an energy or mining facility,a storage facility CFR 122.26(b)(14)(ii),facilities classified within SIC 24,
or a seafood processing facility,or when secured to a Industry Group 241,that are rock crushing,gravel washing,
storage facility or a seafood processing facility,or when log sorting,or log storage facilities operated in connection
secured to the bed of the ocean,contiguous zone or waters with silvicultural activities defined in 40 CFR 122.27(b)(2H3)
of the United States for the purpose of mineral or oil and Industry Groups 242 through 249;26(except 265 and
exploration or development. 267),28(except 283),29,311,32(except 323),33,3441,
• Discharges of dredged or fill material into waters of the and 373(not included are all other types of silviculture
United States that are regulated under CWA Section 404. facilities)are considered stormwater discharges associated
with industrial activity,and are required to obtain an NPDES
• The introduction of sewage,industrial wastes,or other permit.
pollutants into publicly owned treatment works by indirect . Return flows from irrigated agriculture.
dischargers.Plans or agreements to switch to this method of
disposal in the future do not relieve dischargers of the • Discharges into a privately owned treatment works,except as
obligation to have and comply with permits until all the NPDES permitting authority may otherwise require under
discharges of pollutants to waters of the United States are 40 CFR 122.44(m).
eliminated.(See also 40 CFR 122.47(b).)This exclusion . Discharges from a water transfer."Water transfer"means an
does not apply to the introduction of pollutants to privately activity that conveys or connects waters of the United States
owned treatment works or to other discharges through pipes, without subjecting the transferred water to intervening
sewers,or other conveyances owned by a state,municipality, industrial,municipal,or commercial use.This exclusion does
or other party not leading to treatment works. not apply to pollutants introduced by the water transfer
activity itself to the water being transferred.
1-8

FORM 1—GLOSSARY
Note:This glossary includes terms used in the various NPDES application forms,including Form 1.The definitions are from the NPDES
regulations at 40 CFR 122.2 unless otherwise specified.If you have any questions concerning the meaning of any of these terms,contact
your NPDES permitting authority.
ANIMAL FEEDING OPERATION(defined at§122.23)means a lot or facility(other than an aquatic animal production facility)where the
following conditions are met;
• Animals(other than aquatic animals)have been,are,or will be stabled or confined and fed or maintained for a total of 45 days or
more in any 12-month period;and
• Crops,vegetation,forage growth,or post-harvest residues are not sustained in the normal growing season over any portion of the lot
or facility.
APPLICATION means the EPA standard national forms for applying for a permit,including any additions,revisions,or modifications to the
forms;or forms approved by EPA for use in approved states,including any approved modifications or revisions.
APPROVED PROGRAM or APPROVED STATE means a State or interstate program which has been approved or authorized by EPA
under part 123.
AQUACULTURE PROJECT(defined at§122.25)means a defined managed water area which uses discharges of pollutants into that
designated area for the maintenance or production of harvestable freshwater,estuarine,or marine plants or animals.DESIGNATED
PROJECT AREA means the portions of the waters of the United States within which the perrnittee or permit applicant plans to confine the
cultivated species,using a method or plan or operation(including,but not limited to,physical confinement)which,on the basis of reliable
scientific evidence,is expected to ensure that specific individual organisms comprising an aquaculture crop will enjoy increased growth
attributable to the discharge of pollutants,and be harvested within a defined geographic area.
AVERAGE MONTHLY DISCHARGE LIMITATION means the highest allowable average of daily discharges over a calendar month,
calculated as the sum of all daily discharges measured during that month divided by the number of daily discharges measured during that
month.
AVERAGE WEEKLY DISCHARGE LIMITATION means the highest allowable average of daily discharges over a calendar week,
calculated as the sum of all daily discharges measured during a calendar week divided by the number of daily discharges measured during
that week.
BEST MANAGEMENT PRACTICES(BMPs)means schedules of activities,prohibitions of practices,maintenance procedures,and other
management practices to prevent or reduce the pollution of waters of the United States.BMPs include treatment requirements,operation
procedures,and practices to control plant site runoff,spillage or leaks,sludge or waste disposal,or drainage from raw material storage.
BIOSOLIDS(see sewage sludge).
BYPASS(defined at§122.41(m))means the intentional diversion of waste streams from any portion of a treatment facility.
COMBINED SEWER OVERFLOW(CSO)means a discharge from a combined sewer system(CSS)at a point prior to the Publicly Owned
Treatment Works(POTW)Treatment Plant(defined at§403.3(r)).
COMBINED SEWER SYSTEM(CSS)means a wastewater collection system owned by a State or municipality(as defined by section
502(4)of the CWA)which conveys sanitary wastewaters(domestic,commercial and industrial wastewaters)and storm water through a
single-pipe system to a Publicly Owned Treatment Works(POTW)Treatment Plant(as defined at§403.3(r)).
CONCENTRATED ANIMAL FEEDING OPERATION(defined at§122.23)means an animal feeding operation that is defined as a Large
CAFO or as a Medium CAFO by the terms of(A)or(B)below,or that is designated as a CAFO in accordance with 40 CFR 122.23(c).Two
or more AFOs under common ownership are considered to be a single AFO for the purposes of determining the number of animals at an
operation,if they adjoin each other or if they use a common area or system for the disposal of wastes.
A. LARGE CONCENTRATED ANIMAL FEEDING OPERATION(LARGE CAFO)means an AFO that stables or confines as many as or
more than the numbers of animals specified in any of the following categories:
1. 700 mature dairy cows,whether milked or dry;
2. 1,000 veal calves;
3. 1,000 cattle other than mature dairy cows or veal calves.Cattle includes but is not limited to heifers,steers,bulls and cow/calf
pairs;
4. 2,500 swine each weighing 55 pounds or more;
5. 10,000 swine each weighing less than 55 pounds;
1-9

FORM 1—GLOSSARY CONTINUED
6. 500 horses;
7. 10,000 sheep or lambs;
8. 55,000 turkeys;
9. 30,000 laying hens or broilers,if the AFO uses a liquid manure handling system;
10. 125,000 chickens(other than laying hens),if the AFO uses other than a liquid manure handling system;
11. 82,000 laying hens,if the AFO uses other than a liquid manure handling system;
12. 30,000 ducks(if the AFO uses other than a liquid manure handling system);or
13. 5,000 ducks(if the AFO uses a liquid manure handling system).
B. MEDIUM CONCENTRATED ANIMAL FEEDING OPERATION(MEDIUM CAFO)means any AFO with the type and number of
animals that fall within any of the ranges listed below and which has been defined or designated as a CAFO.An AFO is defined as a
Medium CAFO if:
1. The type and number of animals that it stables and confines falls within any of the following ranges:
a. 200 to 699 mature dairy cows,whether milked or dry;
b. 300 to 999 veal calves;
c. 300 to 999 cattle other than mature dairy cows or veal calves.Cattle includes but is not limited to heifers,steers,bulls and
cow/calf pairs;
d. 750 to 2,499 swine each weighing 55 pounds or more;
e. 3,000 to 9,999 swine each weighing less than 55 pounds;
f. 150 to 499 horses;
g. 3,000 to 9,999 sheep or lambs;
h. 16,500 to 54,999 turkeys;
i. 9,000 to 29,999 laying hens or broilers,if the AFO uses a liquid manure handling system;
j. 37,500 to 124,999 chickens(other than laying hens),if the AFO uses other than a liquid manure handling system;
k. 25,000 to 81,999 laying hens,if the AFO uses other than a liquid manure handling system;
I. 10,000 to 29,999 ducks(if the AFO uses other than a liquid manure handling system);ore
m. 1,500 to 4,999 ducks(if the AFO uses a liquid manure handling system);and
2. Either one of the following conditions are met:
a. Pollutants are discharged into waters of the United States through a man-made ditch,flushing system,or other similar man-
made device;or
b. Pollutants are discharged directly into waters of the United States which originate outside of and pass over,across,or
through the facility or otherwise come into direct contact with animals confined in the operation.
CONCENTRATED AQUATIC ANIMAL PRODUCTION FACILITY(defined at§122.24)means a hatchery,fish farm,or other facility which
contains,grows,or holds aquatic animals in either of the following categories,or which the Director designates as such on a case-by-case
basis:
A. Cold water fish species or other cold water aquatic animals including,but not limited to,the Salmonidae family of fish(e.g.,trout and
salmon)in ponds,raceways,or other similar structures which discharge at least 30 days per year but does not include:
1. Facilities which produce less than 9,090 harvest weight kilograms(approximately 20,000 pounds)of aquatic animals per year,
and
2. Facilities which feed less than 2,272 kilograms(approximately 5,000 pounds)of food during the calendar month of maximum
feeding.
B. Warm water fish species or other warm water aquatic animals including,but not limited to,the Ameiuridae,Cetrarchiclae,and
Cyprfnidae families of fish(e.g.,respectively,catfish,sunfish,and minnows)in ponds,raceways,or other similar structures which
discharge at least 30 days per year,but does not include;
1. Closed ponds which discharge only during periods of excess runoff;or
2. Facilities which produce less than 45,454 harvest weight kilograms(approximately 100,000 pounds)of aquatic animals per year.
1-10

FORM 1—GLOSSARY CONTINUED
CWA means the Clean Water Act(formerly referred to as the Federal Water Pollution Control Act or Federal Water Pollution Control Act
Amendments of 1972)Public Law 92-500,as amended by Public Law 95-217,Public Law 95-576,Public Law 96483 and Public Law
97-117,33 U.S.C. 1251 et seq.
CWA AND REGULATIONS means the Clean Water Act(CWA)and applicable regulations promulgated thereunder.In the case of an
approved State program,it includes State program requirements.
DAILY DISCHARGE means the"discharge of a pollutant"measured during a calendar day or any 24-hour period that reasonably
represents the calendar day for purposes of sampling.For pollutants with limitations expressed in units of mass,the"daily discharge"is
calculated as the total mass of the pollutant discharged over the day.For pollutants with limitations expressed in other units of
measurement,the"daily discharge"is calculated as the average measurement of the pollutant over the day.
DIRECT DISCHARGE means the"discharge of a pollutant."
DIRECTOR means the Regional Administrator or the State Director,as the context requires,or an authorized representative.When there
is no"approved State program,"and there is an EPA administered program,"Director"means the Regional Administrator.When there is
an approved State program,"Director"normally means the State Director.In some circumstances,however,EPA retains the authority to
take certain actions even when there is an approved State program.(For example,when EPA has issued an NPDES permit prior to the
approval of a State program,EPA may retain jurisdiction over that permit after program approval,see§123.1.)In such cases,the term
"Director"means the Regional Administrator and not the State Director.
DISCHARGE(OF A POLLUTANT)means:
• Any addition of any pollutant or combination of pollutants to waters of the United States from any point source;or
• Any addition of any pollutant or combination of pollutants to the waters of the contiguous zone or the ocean from any point source
other than a vessel or other floating craft which is being used as a means of transportation.
This definition includes discharges into waters of the United States from:surface runoff which is collected or channelled by man;
discharges through pipes,sewers,or other conveyances owned by a State,municipality,or other person which do not lead to a treatment
works;and discharges through pipes,sewers,or other conveyances,leading into privately owned treatment works.This term does not
include an addition of pollutants by any"indirect discharger".
DISCHARGE MONITORING REPORT means the EPA uniform national form,including any subsequent additions,revisions,or
modifications for the reporting of self-monitoring results by permittees.DMRs must be used by"approved States"as well as by EPA.EPA
will supply DMRs to any approved State upon request.The EPA national forms may be modified to substitute the state agency name,
address,logo,and other similar information,as appropriate,in place of EPA's.
DRAFT PERMIT means a document prepared under§124.6 indicating the Director's tentative decision to issue or deny,modify,revoke
and reissue,terminate,or reissue a"permit."A notice of intent to terminate a permit,and a notice of intent to deny a permit,as discussed
in§124.5,are types of"draft permits."A denial of a request for modification,revocation and reissuance,or termination,as discussed in
§124.5,is not a"draft permit."A"proposed permit"is not a"draft permit."
EFFLUENT LIMITATION means any restriction imposed by the Director on quantities,discharge rates,and concentrations of"pollutants"
which are"discharged"from"point sources"into"waters of the United States,"the waters of the"contiguous zone,"or the ocean.
EFFLUENT LIMITATIONS GUIDELINES means a regulation published by the Administrator under section 304(b)of the CWA to adopt or
revise"effluent limitations."
ENVIRONMENTAL PROTECTION AGENCY(EPA)means the United States Environmental Protection Agency.
FACILITY or ACTIVITY means any NPDES"point source"or any other facility or activity(including land or appurtenances thereto)that is
subject to regulation under the NPDES program.
GENERAL PERMIT means an NPDES"permit"issued under§122.28 authorizing a category of discharges under the CWA within a
geographical area.
HAZARDOUS SUBSTANCE means any substance designated under 40 CFR part 116 pursuant to section 311 of the CWA.
INDIAN COUNTRY(or INDAN LANDS)means:
• All land within the limits of any Indian reservation under the jurisdiction of the United States Government,notwithstanding the
issuance of any patent,and,including rights-of-way running through the reservation;
• All dependent Indian communities with the borders of the United States whether within the originally or subsequently acquired territory
thereof,and whether within or without the limits of a state;and
• All Indian allotments,the Indian titles to which have not been extinguished,including rights-of-way running through the same.
1-11

FORM 1—GLOSSARY CONTINUED
INDIAN TRIBE means any Indian Tribe,band,group,or community recognized by the Secretary of the Interior and exercising
governmental authority over a Federal Indian reservation.
INDIRECT DISCHARGE means a nondomestic discharger introducing"pollutants"to a"publicly owned treatment works.'
LARGE MUNICIPAL SEPARATE STORM SEWER SYSTEM(defined at§122.26(b)(4))means all municipal separate storm sewers that
are either:
(i)Located in an incorporated place with a population of 250,000 or more as determined by the 1990 Decennial Census by the Bureau of
the Census(Appendix F of 40 CFR 122);or
(ii)Located in the counties listed in appendix H of 40 CFR 122,except municipal separate storm sewers that are located in the
incorporated places,townships or towns within such counties;or
(iii)Owned or operated by a municipality other than those described in paragraphs(i)or(ii)and that are designated by the Director as part
of the large or medium municipal separate storm sewer system due to the interrelationship between the discharges of the designated
stone sewer and the discharges from municipal separate storm sewers described under paragraphs(i)or(ii).In making this determination
the Director may consider the following factors:
(A)Physical interconnections between the municipal separate storm sewers;
(B)The location of discharges from the designated municipal separate storm sewer relative to discharges from municipal separate storm
sewers described in paragraph(i);
(C)The quantity and nature of pollutants discharged to waters of the United States;
(D)The nature of the receiving waters;and
(E)Other relevant factors;or
(iv)The Director may,upon petition,designate as a large municipal separate storm sewer system,municipal separate storm sewers
located within the boundaries of a region defined by a storm water management regional authority based on a jurisdictional,watershed,or
other appropriate basis that includes one or more of the systems described in paragraphs(i),(ii),(iii).
LOG SORTING AND LOG STORAGE FACILITIES(defined at§122.27)means facilities whose discharges result from the holding of
unprocessed wood,for example,logs or roundwood with bark or after removal of bark held in self-contained bodies of water(mill ponds or
log ponds)or stored on land where water is applied intentionally on the logs(wet decking).(See 40 CFR 429,subpart I,including the
effluent limitations guidelines.)
MAJOR FACILITY means any NPDES"facility or activity"classified as such by the Regional Administrator,or,in the case of"approved
State programs,"the Regional Administrator in conjunction with the State Director.
MAXIMUM DAILY DISCHARGE LIMITATION means the highest allowable"daily discharge."
MEDIUM MUNICIPAL SEPARATE STORM SEWER SYSTEM(defined at§122.26(b)(7))means all municipal separate storm sewers that
are either:
(i)Located in an incorporated place with a population of 100,000 or more but less than 250,000,as determined by the 1990 Decennial
Census by the Bureau of the Census(appendix G of 40 CFR 122);or
(ii)Located in the counties listed in appendix I of 40 CFR 122,except municipal separate storm sewers that are located in the incorporated
places,townships or towns within such counties;or
(iii)Owned or operated by a municipality other than those described in paragraph(i)or(ii)and that are designated by the Director as part
of the large or medium municipal separate storm sewer system due to the interrelationship between the discharges of the designated
storm sewer and the discharges from municipal separate storm sewers described under paragraph(i)or(ii).In making this determination
the Director may consider the following factors:
(A)Physical interconnections between the municipal separate storm sewers;
(B)The location of discharges from the designated municipal separate storm sewer relative to discharges from municipal separate storm
sewers described in paragraph(i);
(C)The quantity and nature of pollutants discharged to waters of the United States;
(D)The nature of the receiving waters;or
(E)Other relevant factors;or
1-12

FORM 1—GLOSSARY CONTINUED
(iv)The Director may,upon petition,designate as a medium municipal separate storm sewer system,municipal separate storm sewers
located within the boundaries of a region defined by a storm water management regional authority based on a jurisdictional,watershed,or
other appropriate basis that includes one or more of the systems described in paragraphs(i),(ii),(iii)of this section.
MUNICIPALITY means a city,town,borough,county,parish,district,association,or other public body created by or under State law and
having jurisdiction over disposal of sewage,industrial wastes,or other wastes,or an Indian tribe or an authorized Indian tribal organization,
or a designated and approved management agency under section 208 of the CWA.
MUNICIPAL SEPARATE STORM SEWER(defined at§122.26(b)(8))means a conveyance or system of conveyances(including roads
with drainage systems,municipal streets,catch basins,curbs,gutters,ditches,man-made channels,or storm drains):
• Owned or operated by a State,city,town,borough,county,parish,district,association,or other public body(created by or pursuant to
State law)having jurisdiction over disposal of sewage,industrial wastes,stormwater,or other wastes,including special districts under
State law such as a sewer district,flood control district or drainage district,or similar entity,or an Indian tribe or an authorized Indian
tribal organization,or a designated and approved management agency under section 208 of the CWA that discharges to waters of the
United States.
• Designed or used for collecting or conveying stormwater.
• Which is not a combined sewer,and
• Which is not part of a POTW as defined at 40 CFR 122.2.
MUNICIPAL SLUDGE(see sewage sludge)
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM(NPDES)means the national program for issuing,modifying,revoking
and reissuing,terminating,monitoring and enforcing permits,and imposing and enforcing pretreatment requirements,under sections 307,
402,318,and 405 of the CWA.The term includes an"approved program."
NEW DISCHARGER means any building,structure,facility,or installation:
• From which there is or may be a"discharge of pollutants;"
• That did not commence the"discharge of pollutants"at a particular"site"prior to August 13, 1979;
• Which is not a"new source;"and
• Which has never received a finally effective NPDES permit for discharges at that"site."
This definition includes an"indirect discharger"which commences discharging into"waters of the United States"after August 13, 1979.It
also means any existing mobile point source(other than an offshore or coastal oil and gas exploratory drilling rig or a coastal oil and gas
developmental drilling rig)such as a seafood processing rig,seafood processing vessel,or aggregate plant,that begins discharging at a
"site"for which it does not have a permit;and any offshore or coastal mobile oil and gas exploratory drilling rig or coastal mobile oil and gas
developmental drilling rig that commences the discharge of pollutants after August 13, 1979,at a"site"under EPA's permitting jurisdiction
for which it is not covered by an individual or general permit and which is located in an area determined by the Regional Administrator in
the issuance of a final permit to be an area of biological concern.In determining whether an area is an area of biological concem,the
Regional Administrator shall consider the factors specified in 40 CFR 125.122(a)(1)through(10).
An offshore or coastal mobile exploratory drilling rig or coastal mobile developmental drilling rig will be considered a"new discharger"only
for the duration of its discharge in an area of biological concern.
NEW SOURCE means any building,structure,facility,or installation from which there is or may be a"discharge of pollutants,"the
construction of which commenced:
• After promulgation of standards of performance under section 306 of the CWA which are applicable to such source,or
• After proposal of standards of performance in accordance with section 306 of the CWA which are applicable to such source,but only
if the standards are promulgated in accordance with section 306 within 120 days of their proposal.
OWNER OR OPERATOR means the owner or operator of any"facility or activity"subject to regulation under the NPDES program.
PERMIT means an authorization,license,or equivalent control document issued by EPA or an"approved State"to implement the
requirements of this part and parts 123 and 124."Permit includes an NPDES"general permit"(§122.28).Permit does not include any
permit which has not yet been the subject of final agency action,such as a"draft permit"or a`proposed permit."
PESTICIDE DISCHARGES TO WATERS OF THE UNITED STATES FROM PESTICIDE APPLICATION means the application of
biological pesticides,and the application of chemical pesticides that leave a residue,from point sources to waters of the United States.In
the context of this definition of pesticide discharges to waters of the United States from pesticide application,this does not include
1-13

FORM 1—GLOSSARY CONTINUED
agricultural storm water discharges and return flows from irrigated agriculture,which are excluded by law(33 U.S.C. 1342(I);33 U.S.C.
1362(14)).
PESTICIDE RESIDUE for the purpose of determining whether a NPDES permit is needed for discharges to waters of the United States
from pesticide application,means that portion of a pesticide application that is discharged from a point source to waters of the United
States and no longer provides pesticidal benefits.It also includes any degradates of the pesticide.
POINT SOURCE means any discernible,confined,and discrete conveyance,including but not limited to,any pipe,ditch,channel,tunnel,
conduit,well,discrete fissure,container,rolling stock,concentrated animal feeding operation,landfill leachate collection system,vessel or
other floating craft from which pollutants are or may be discharged.This term does not include return flows from irrigated agriculture or
agricultural stormwater runoff.(See§122.3).
POLLUTANT means dredged spoil,solid waste,incinerator residue,filter backwash,sewage,garbage,sewage sludge,munitions,
chemical wastes,biological materials,radioactive materials(except those regulated under the Atomic Energy Act of 1954,as amended(42
U.S.C.2011 of seq.)),heat,wrecked or discarded equipment,rock,sand,cellar dirt and industrial,municipal,and agricultural waste
discharged into water.It does not mean:
• Sewage from vessels;or
• Water,gas,or other material which is injected into a well to facilitate production of oil or gas,or water derived in association with oil
and gas production and disposed of in a well,if the well used either to facilitate production or for disposal purposes is approved by
authority of the State in which the well is located,and if the State determines that the injection or disposal will not result in the
degradation of ground or surface water resources.Note:Radioactive materials covered by the Atomic Energy Act are those
encompassed in its definition of source,byproduct,or special nuclear materials.Examples of materials not covered include radium
and accelerator-produced isotopes.See Train v.Colorado Public Interest Research Group,Inc.,426 U.S. 1(1976).
PRIMARY INDUSTRY CATEGORY means any industry category listed in the NRDC settlement agreement(Natural Resources Defense
Council et al.v. Train,8 E.R.C.2120(D.D.C.1976),modified 12 E.R.C.1833(D.D.C. 1979));also listed in appendix A of part 122.
PRIVATELY OWNED TREATMENT WORKS means any device or system which is(1)used to treat wastes from any facility whose
operator is not the operator of the treatment works and(2)not a'POTW."
PROCESS WASTEWATER means any water which,during manufacturing or processing,comes into direct contact with or results from the
production or use of any raw material,intermediate product,finished product,byproduct,or waste product.
PROPOSED PERMIT means a state NPDES"permit'prepared after the close of the public comment period(and,when applicable,any
public hearing and administrative appeals)which is sent to EPA for review before final issuance by the State.A'proposed permit°is not a
"draft permit."
PUBLICLY OWNED TREATMENT WORKS or POTW(defined at§403.3)means a treatment works as defined by CWA Section 212,
which is owned by a state or municipality(as defined by CWA Section 502(4)).This definition includes any devices or systems used in the
storage,treatment,recycling,and reclamation)of municipal sewage or industrial wastes of a liquid nature.This definition also includes
sewers,pipes,and other conveyances only if they convey wastewater to a POTW.The term also means the municipality as defined in
CWA Section 502(4),which has jurisdiction over the indirect discharges to and the discharges from such a treatment works.
REGIONAL ADMINISTRATOR means the Regional Administrator of the appropriate Regional Office of the Environmental Protection
Agency or the authorized representative of the Regional Administrator,
ROCK CRUSHING AND GRAVEL WASHING FACILITIES(defined at§122.27)means facilities which process crushed and broken
stone,gravel,and riprap(See 40 CFR 436,subpart B,including the effluent limitations guidelines).
SCHEDULE OF COMPLIANCE means a schedule of remedial measures included in a"permit",including an enforceable sequence of
interim requirements(for example,actions,operations,or milestone events)leading to compliance with the CWA and regulations.
SECONDARY INDUSTRY CATEGORY means any industry category which is not a primary industry category.
SEWAGE FROM VESSELS means human body wastes and the wastes from toilets and other receptacles intended to receive or retain
body wastes that are discharged from vessels and regulated under section 312 of the CWA,except that with respect to commercial
vessels on the Great Lakes this term includes graywater.For the purposes of this definition,°graywater"means galley,bath,and shower
water.
SEWAGE SLUDGE means any solid,semi-solid,or liquid residue removed during the treatment of municipal waste water or domestic
sewage.Sewage sludge includes,but is not limited to,solids removed during primary,secondary,or advanced waste water treatment,
scum,septage,portable toilet pumpings,type III marine sanitation device pumpings(33 CFR 159),and sewage sludge products.Sewage
sludge does not include grit or screenings,or ash generated during the incineration of sewage sludge.
1-14

FORM 1—GLOSSARY CONTINUED
SILVICULTURAL POINT SOURCE(defined at§122.27)means any discernible,confined,and discrete conveyance related to rock
crashing,gravel washing,log sorting,or log storage facilities which are operated in connection with silvicultural activities and from which
pollutants are discharged into waters of the United States.This term does not include non-point source silvicultural activities such as
nursery operations,site preparation,reforestation and subsequent cultural treatment,thinning,prescribed burning,pest and fire control,
harvesting operations,surface drainage,or road construction and maintenance from which there is natural runoff.However,some of these
activities(such as stream crossing for roads)may involve point source discharges of dredged or fill material which may require a CWA
Section 404 permit(see 33 CFR 209.120 and part 233).
SITE means the land or water area where any"facility or activity"is physically located or conducted,including adjacent land used in
connection with the facility or activity.
SLUDGE-ONLY FACILITY means any"treatment works treating domestic sewage"whose methods of sewage sludge use or disposal are
subject to regulations promulgated pursuant to section 405(d)of the CWA and is required to obtain a permit under§122.1(b)(2).
STANDARDS FOR SEWAGE SLUDGE USE OR DISPOSAL means the regulations promulgated pursuant to section 405(d)of the CWA
which govem minimum requirements for sludge quality,management practices,and monitoring and reporting applicable to sewage sludge
or the use or disposal of sewage sludge by any person.
STATE means any of the 50 States,the District of Columbia,Guam,the Commonwealth of Puerto Rico,the Virgin Islands,American
Samoa,the Commonwealth of the Northern Mariana Islands,the Trust Territory of the Pacific Islands,or an Indian Tribe as defined in
these regulations which meets the requirements of§123.31 of this chapter.
STATE DIRECTOR means the chief administrative officer of any State or interstate agency operating an"approved program,"or the
delegated representative of the State Director.If responsibility is divided among two or more State or interstate agencies,"State Director"
means the chief administrative officer of the State or interstate agency authorized to perform the particular procedure or function to which
reference is made.
STORMWATER(or STORM WATER)(defined at§122.26(b)(13))means stormwater runoff,snow melt runoff,and surface runoff and
drainage.
STORMWATER DISCHARGE ASSOCIATED WITH INDUSTRIAL ACTIVITY(defined at§122.26(b)(14))means the discharge from any
conveyance that is used for collecting and conveying stormwater and that is directly related to manufacturing,processing or raw materials
storage areas at an industrial plant.The term does not include discharges from facilities or activities excluded from the NPDES program
under this part 122.For the categories of industries identified in this section,the term includes,but is not limited to,stormwater discharges
from industrial plant yards;immediate access roads and rail lines used or traveled by carriers of raw materials,manufactured products,
waste material,or by-products used or created by the facility;material handling sites;refuse sites;sites used for the application or disposal
of process waste waters(as defined at 40 CFR 401);sites used for the storage and maintenance of material handling equipment;sites
used for residual treatment,storage,or disposal;shipping and receiving areas;manufacturing buildings;storage areas(including tank
farms)for raw materials,and intermediate and final products;and areas where industrial activity has taken place in the past and significant
materials remain and are exposed to stormwater.For the purposes of this paragraph,material handling activities include storage,loading
and unloading,transportation,or conveyance of any raw material,intermediate product,final product,by-product or waste product.The
term excludes areas located on plant lands separate from the plants industrial activities,such as office buildings and accompanying
parking lots as long as the drainage from the excluded areas is not mixed with stormwater drained from the above described areas.
Industrial facilities(including industrial facilities that are federally,State,or municipally owned or operated that meet the description of the
facilities listed in paragraphs 1 through 14 below)include those facilities designated under the provisions of 40 CFR 122.26(a)(1)(v).The
following categories of facilities are considered to be engaging in"industrial activity"for purposes of 40 CFR 122.26(b)(14):
1. Facilities subject to stormwater effluent limitations guidelines,new source performance standards,or toxic pollutant effluent standards
under 40 CFR Subchapter N(except facilities with toxic pollutant effluent standards which are exempted under paragraph 11 below);
2. Facilities classified as Standard Industrial Classification 24,Industry Group 241 that are rock crushing,gravel washing,log sorting,or
log storage facilities operated in connection with silvicultural activities defined in 40 CFR 122.27(b)(2H3)and Industry Groups 242
through 249;26(except 265 and 267),28(except 283),29,311,32(except 323),33,3441,373;(not included are all other types of
silvicultural facilities);
3. Facilities classified as Standard Industrial Classifications 10 through 14(mineral industry)including active or inactive mining
operations(except for areas of coal mining operations no longer meeting the definition of a reclamation area under 40 CFR 434.11(1)
because the performance bond issued to the facility by the appropriate SMCRA authority has been released,or except for areas of
non—coal mining operations which have been released from applicable State or Federal reclamation requirements after
December 17,1990)and oil and gas exploration,production,processing,or treatment operations,or transmission facilities that
discharge stormwater contaminated by contact with or that has come into contact with,any overburden,raw material,intermediate
products,finished products,byproducts or waste products located on the site of such operations;(inactive mining operations are
mining sites that are not being actively mined,but which have an identifiable owner/operator;inactive mining sites do not include sites
1-15

FORM 1-GLOSSARY CONTINUED
where mining claims are being maintained prior to disturbances associated with the extraction,beneficiation,or processing of mined
materials,nor sites where minimal activities are undertaken for the sole purpose of maintaining a mining claim);
4. Hazardous waste treatment,storage,or disposal facilities,including those that are operating under interim status or a permit under
subtitle C of RCRA;
5. Landfills,land application sites,and open dumps that receive or have received any industrial wastes(waste that is received from any
of the facilities described under this subsection)including those that are subject to regulation under subtitle D of RCRA;
6. Facilities involved in the recycling of materials,including metal scrapyards,battery reclaimers,salvage yards,and automobile
junkyards,including but limited to those classified as Standard Industrial Classification 5016 and 5093;
7. Steam electric power generating facilities,including coal handling sites;
8. Transportation facilities classified as Standard Industrial Classifications 40,41,42(except 4221-25),43,44,45,and 5171 which have
vehicle maintenance shops,equipment cleaning operations,or airport deicing operations.Only those portions of the facility that are
either involved in vehicle maintenance(including vehicle rehabilitation,mechanical repairs,painting,fueling,and lubrication),
equipment cleaning operations,airport deicing operations,or which are otherwise identified under paragraphs 1-7 or 9-11 are
associated with industrial activity;
9. Treatment works treating domestic sewage or any other sewage sludge or wastewater treatment device or system,used in the
storage treatment,recycling,and reclamation of municipal or domestic sewage,including land dedicated to the disposal of sewage
sludge that are located within the confines of the facility,with a design flow of 1.0 mgd or more,or required to have an approved
pretreatment program under 40 CFR 403.Not included are farm lands,domestic gardens or lands used for sludge management
where sludge is beneficially reused and which are not physically located in the confines of the facility,or areas that are in compliance
with section 405 of the CWA;
10. Construction activity including clearing,grading and excavation,except operations that result in the disturbance of less than five acres
of total land area.Construction activity also includes the disturbance of less than five acres of total land area that is a part of a larger
common plan of development or sale if the larger common plan will ultimately disturb five acres or more;
11. Facilities under Standard Industrial Classifications 20,21,22,23,2434,25,265,267,27,283,285,30,31 (except 311),323,34
(except 3441),35,36,37(except 373),38,39,and 4221-25.
TOXIC POLLUTANT means any pollutant listed as toxic under section 307(a)(1)or,in the case of"sludge use or disposal practices,"any
pollutant identified in regulations implementing section 405(d)of the CWA.
TREATMENT WORKS TREATING DOMESTIC SEWAGE(TWTDS)means a POTW or any other sewage sludge or waste water
treatment devices or systems,regardless of ownership(including federal facilities),used in the storage,treatment,recycling,and
reclamation of municipal or domestic sewage,including land dedicated for the disposal of sewage sludge.This definition does not include
septic tanks or similar devices.For purposes of this definition,"domestic sewage"includes waste and waste water from humans or
household operations that are discharged to or otherwise enter a treatment works.In States where there is no approved State sludge
management program under section 405(f)of the CWA,the Regional Administrator may designate any person subject to the standards for
sewage sludge use and disposal in 40 CFR 503 as a"treatment works treating domestic sewage,"where he or she finds that there is a
potential for adverse effects on public health and the environment from poor sludge quality or poor sludge handling,use or disposal
practices,or where he or she finds that such designation is necessary to ensure that such person is in compliance with 40 CFR 503.
UPSET(defined at§122.41(n))means an exceptional incident in which there is unintentional and temporary noncompliance with
technology based permit effluent limitations because of factors beyond the reasonable control of the permittee.An upset does not include
noncompliance to the extent caused by operational error,improperly designed treatment facilities,inadequate treatment facilities,lack of
preventive maintenance,or careless or improper operation.
VARIANCE means any mechanism or provision under section 301 or 316 of the CWA or under 40 CFR 125,or in the applicable"effluent
limitations guidelines"which allows modification to or waiver of the generally applicable effluent limitation requirements or time deadlines of
the CWA.This includes provisions which allow the establishment of alternative limitations based on fundamentally different factors or on
sections 301(c),301(g),301(h),301(i),or 316(a)of the CWA.
WATERS OF THE UNITED STATES as defined at§122.2.
WHOLE EFFLUENT TOXICITY(WET)means the aggregate toxic effect of an effluent measured directly by a toxicity test.
1-16

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
OMB No.2040.0004
Form U.S.Environmental Protection Agency
1 \8/EPA Application for NPDES Permit to Discharge Wastewater
NPQES GENERAL INFORMATION
SECTIONe •D
1.1 Applicants Not Required to Submit Form 1
Is the facility a new or existing publicly owned Is the facility a new or existing treatment works
1.1.1 treatment works? 1.1.2
treating domestic sewage?
If yes, STOP. Do NOT complete El No If yes.STOP.Do NOT 0 No
Form 1.Complete Form 2A. complete Form 1.Complete
Form 2S.
1.2 Applicants Required to Submit Form 1
ft 1.2.1 Is the facility a concentrated animal feeding 1.2.2 Is the facility an existing manufacturing,
operation or a concentrated aquatic animal commercial, mining,or silvicultural facility that is
o- production facility? currently discharging process wastewater?
QYes 4 Complete Form 1 0 No Yes 3 Complete Form No
z and Form 2B. 1 and Form 2C,
R 1.2.3 Is the facility a new manufacturing,commercial, 1.2.4 Is the facility a new or existing manufacturing,
I mining,or silvicultural facility that has not yet commercial,mining,or silvicultural facility that
commenced to discharge? discharges only nonprocess wastewater?
Yes 4 Complete Form 1 No Yes 4 Complete Form No
and Form 2D. 1 and Form 2E.
U)du
1.2.5 Is the facility a new or existing facility whose
'— discharge is composed entirely of stormwater
associated with industrial activity or whose
discharge is composed of both stormwater and
non-stormwater?
0 Yes 4 Complete Farm 1 No
and Form 2F
unless exempted by
40 CFR
122.26(b)(14)(x)or
SECTION
DE- LOCATION
2.1 Facility Name
Brenntag Mid-South Inc.,Charlotte Facility
0 2.2 EPA Identification Number
a None for CWA programs
J
2.3 Facility Contact
Name(first and last) Title Phone number
Dennis Martin Operations Manager [phone]
a
c Email address
dmartin@ Brenntag.cnm
2A Facility Mailing Address
Street or P.O.box
11750 Fruehauf Drive
City or town State ZIP code
Durham NC 28273
EPA Form 3510-1(revised 3.19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
OMB No.2040.0004
2.5 Facility Location
Street, route number,or other specific identifier
Q U 11750 Fruehauf Drive
g County name County code(if known)
Mecklenburg
0
E City or town State ZIP code
a cc Charlotte NC 28273
SECTiONfA 1
3.1 SIC Code(s) Description(optional)
4226 Special Warehousing and Storage
m
m
a
0
U
U
z 3.2 NAICS Codes) Description(optional)
a
c
16 493190 Other Warehousing and Storage
U
SPCTION 4.OPERATOR INFORMATION
4.1 Name of 0 stator
Brenntag Mid-South Inc.,Charlotte
0 4.2 Is the name you listed in Item 4.1 also the owner?
I
9 0Yes ElNo
L 4.3 Operator Status
0
❑ Public—federal ❑ Public—state ❑ Other public(specify)
o ❑✓ Private ElOther(specify)
4.4 Phone Number of Operator
[phone]
4.5 Operator Address
w Street or P.O. Box
ro
Same as Owner
City or town State ZIP code
0 0
� V
Email address of operator
0
SECTION 5.INDIAN LAND 4
5.1 Is the facility located on Indian Land?
❑ Yes ❑✓ No
EPA Form 3510-1(revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
OMB No.2040-0004
ENVIRONMENTALI
6A Existing Environmental Permits(check all that apply and print or type the corresponding permit number for each)
❑ NPDES(discharges to surface m RCRA(hazardous wastes) ❑ UIC(underground injection of
water) fluids)
Lu ❑ PSD(air emissions) ❑ Nonattainment program(CAA) ❑ NESHAPs(CAA)
a>
i
❑ Ocean dumping(MPRSA) ❑ Dredge or fill(CWA Section 404) ❑ Other(specify)
SECTION1
7.1 Have you attached a topographic map containing all required information to this application?(See instructions for
b specific requirements.)
✓❑ Yes ❑ No ❑ CAFO—Not Applicable(See requirements in Form 213.)
S.LCTION 8.NATURE OF }
8.1 Describe the nature of your business.
Wet and Dry Chemical Distribution,Includes Petroleum based solvents,Acids and Bases.
m
C
.Cn
O
7
tO
z
ECTION 9.COOLINGI
9.1 Does your facility use cooling water?
❑ Yes ❑✓ No + SKIP to Item 10.1.
S 9.2 Identify the source of cooling water.(Note that facilities that use a cooling water intake structure as described at
�,y 40 CFR 125, Subparts I and J may have additional application requirements at 40 CFR 122.21(r).Consult with your
NPDES permitting authority to determine what specific information needs to be submitted and when,)
o
U �
SECTION
1 1 I
10A Do you intend to request or renew one or more of the variances authorized at 40 CFR 122.21(m)?(Check all that
apply.Consult with your NPDES permitting authority to determine what information needs to be submitted and
when.)
w ❑ Fundamentally different factors(CWA ❑ Water quality related effluent limitations(CWA Section
Section 301(n)) 302(b)(2))
❑ Non-conventional pollutants(CWA ❑ Thermal discharges(CWA Section 316(a))
Section 301(c)and(g))
Not applicable
EPA Form 3510-1(revised 3-19) Page 3

EPA IdentifiicaGan Number NPDES Permit Number Facility Name Form Approved 03/05119
OMB No.2040-OOC4
'�CTIONKC ECKLIST AND CERTIFICATION1
11.1 In Column 1 below, mark the sections of Form 1 that you have completed and are submitting with your application.
For each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority. Note
that not all applicants are re uired to provide attachments.
Column 1 Column 2
❑ Section 1:Activities Requiring an NPDES Permit ❑ wl attachments
❑✓ Section 2:Name, Mailing Address,and Location ❑ wl attachments
❑✓ Section 3: SIC Codes ❑ wl attachments
0 Section 4:Operator Information ❑ wl attachments
❑� Section 5: Indian Land ❑ wl attachments
❑✓ Section 6: Existing Environmental Permits ❑ wl attachments
d
d ❑ Section 7:Map ❑ matopographic ❑ wl additional attachments
0 0 Section 8:Nature of Business ❑ w/attachments
Z Section 9:Cooling Water Intake Structures ❑ w/attachments
m
t' Section 10:Variance Requests ❑ wl attachments
❑✓ Section 11:Checklist and Certification Statement ❑ w!attachments
11.2 Certification Statement
I certify under penalty of law that this document and all atfachments were prepared under my direction or supervision
in accordance with a system designed to assure that qualified personnel properly gather and evaluate the
information submitted. Based on my inquiry of the person or persons who manage the system,or those persons
directly responsible for gathering the information, the information submitted is,to the best of my knowledge and
belief, true, accurate,and complete.!am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name(print or type first and last name) Official title
David Grenoble Regional SRQ Manager
Signature C _Date signed
01/23/2023
EPA Form 3510.1(revised 3-19) Page 4

United States Office of Water EPA Form 3510-2F
Environmental Protection Agency Washington, D.C. Revised March 2019
Water Permits Division
EPA Application Form 2F
stormwater Discharges
Associated with industrial
Activity
NPDES Permitting Program
Note: Complete this form and Form I if you are a new or existing facility whose discharge is composed
entirely of stormwater associated with industrial activity, excluding discharges from construction
activity under 40 CFR 122.26(b)(14)(x) or(b)(15). 1f your discharge is composed of stormwater and
non-stormwater, you must complete Forms I and 2F, and you must complete Form 2C, 21), or 2E, as
appropriate. See the "Instructions" inside for further details.

Paperwork Reduction Act Notice
The U.S. Environmental Protection Agency estimates the average burden to collect and complete
Form 2F to be 28.1 hours. The estimate includes time for reviewing instructions, searching existing data
sources, gathering and maintaining the needed data, and completing and reviewing the collection of
information. Send comments about the burden estimate or any other aspect of this collection of
information, including suggestions for reducing the burden,to the Chief, Information Policy Branch
(PM-223), U.S. Environmental Protection Agency, 1200 Pennsylvania Avenue,NW,Washington, DC
20460, and to the Office of Information and Regulatory Affairs, Office of Management and Budget,
725 17t' Street,NW, Washington, DC 20503, marked "Attention: Desk Officer for EPA."

FORM 2F—INSTRUCTIONS
General Instructions Where to File Your Completed Form
Who Must Complete Form 2F? Submit your completed application package(Forms 1 and 2F plus
You must complete Form 2F if you answered"Yes"to Item 1.2.5 on any other applicable forms)to your NPDES permitting authority.
Form 1—that is,you are a new or existing facility and your Consult Exhibit 1-1 of Form 1 s General Instructions"to identify
discharge is composed entirely of stormwater associated with your NPDES permitting authority.
industrial activity(excluding discharges from construction activity Public Availability of Submitted Information
under40 CFR 122.26(b)(14)(x)or(b)(15))or composed of The U.S.Environmental Protection Agency(EPA)will make
stormwater and non-stormwater and are seeking coverage under information from NPDES permit application farms available to the
an individual National Pollutant Discharge Elimination System public for inspection and copying upon request.You may not claim
(NPDES)permit.Note that applicants in the latter category must any information on Form 2F(or related attachments)as confidential.
also complete Forms 2C,2D,or 2E,as applicable.See inset
below. You may make a claim of confidentiality for any information that you
submit to EPA that goes beyond the information required by Form
Notes 2F.Note that NPDES permitting authorities will deny claims for
• Form 2F must be completed by any operator of treating any effluent data(estimated or actual)as confidential.If you
a facility that discharges stormwater associated do not assert a claim of confidentiality at the time you submit your
with industrial activity or the operator of any information to the NPDES permitting authority,EPA may make the
stormwater discharger that EPA is evaluating for information available to the public without further notice to you.EPA
designation as a significant contributor of will handle claims of confidentiality in accordance with the Agency's
pollutants to waters of the United States,or as business confidentiality regulations in Part 2 of Title 40 of the Code
contributing to a violation of a water quality of Federal Regulations(CFR).
standard. Completion of Forms
• For discharges composed entirely of Print or type in the specified areas only.If you do not have enough
stormwater,the operator must complete space on the form to answer a question,you may continue on
Form 2F in conjunction with Form 1. additional sheets,as necessary,using a format consistent with the
• For discharges of stormwater combined with form.
process wastewater,the operator must Provide your EPA Identification Number from the Facility Registry
complete and submit Form 2F,Form 1,and
is water that Service,NPDES permit number,and facility name at the top of each
Form 2C.Process wastewater page of Form 2F and any attachments.If your facility is new(i.e.,
comes into direct contact with is results from
the production direct
use of any raw material, not yet constructed),write or type"New Facility"in the space
intermediate product,finished product, provided for the EPA Identification Number an NPDES permit
byproduct,waste product,or wastewater. number.If you do not know your EPA Identification Number,contact
• For discharges of stormwater combined with Your NPDES permitting authority.See Exhibit 1-1 of Form 1's
"General Instructions"for contact information.Additionally,for
nonprocess wastewater,the operator must Tables A through D,provide the applicable outfall number at the top
complete Form 2F,Form 1,and Form 2E. of each page.
Nonprocess wastewater includes noncontact
cooling water and sanitary wastes that are not Do not leave any response areas blank unless the form directs you
regulated by effluent guidelines,except to skip them.If the form directs you to respond to an item that does
discharges by educational,medical,or not apply to your facility or activity,enter"NA"for"not applicable"to
commercial chemical laboratories. show that you considered the item and determined a response was
• For new discharges of stormwater associated not necessary for your facility.
with industrial activity that will be combined with The NPDES permitting authority will consider your application
other new non-stormwater discharges,the complete when it and any supplementary material are received and
operator must submit Form 2F,Form 1,and completed according to the authority's satisfaction.The NPDES
Form 2D. permitting authority will judge the completeness of any application
independently of the status of any other permit application or permit
for the same facility or activity.
Definitions
The legal definitions of all key terms used in these instructions and
Form 2F are in the"Glossary"at the end of the"General
Instructions"in Form 1.
2F-1

FORM 2F—INSTRUCTIONS CONTINUED
Line-by-Line Instructions Section 3.Site Drainage Map
Section 1.Outfall Location Item 3.1 Attach a site drainage map showing the topography of the
Item 1.1.Identify each of the facility's outfalls by number. For each facility.If a topographic map is unavailable,you may provide an
outfall,specify the latitude and longitude to the nearest 15 seconds outline of drainage areas served by the outfall(s)covered in the
and name of the receiving water.Latitude and longitude application.The site map must include the following information:
coordinates may be obtained in a variety of ways, including use of Each of its drainage and discharge structures.
hand held devices(e.g.,a GPS enabled smartphone),internet The drainage area of each stormwater outfall.
mapping foals(e.g„
hUps:llmynasadata.[arc.nasa.00v/latitudelongitude-finder!), Paved areas and buildings within the drainage area of each
geographic information systems(e,g.,ArcView),or paper maps stormwater outfall;each past or present area used for outdoor
from trusted sources(e.g.,U.S. Geological Survey or USGS).The storage or disposal of significant materials;each existing
location of each outfall(i.e.,where the coordinates are collected) structural control measure to reduce pollutants in stormwater
shall be the location where collected and concentrated stormwater runoff;materials loading and access areas;and areas where
flows are discharged from the facility such that the first receiving pesticides,herbicides,soil conditioners,and fertilizers are
water body into which the discharge flows,either directly or applied.
through a separate storm sewer system,is a water of the United • Each hazardous waste treatment,storage,or disposal facility
States.If you need further guidance in responding to Item 1.1,refer (including each area not required to have a Resource
to hqp:liwww.epa.gov/qeospatial/latitudelongitude-data-standard. Conservation and Recovery Act permit and is used for
Note:In EPA's stormwater permits,'outfalls"are referred to as accumulating hazardous waste for less than 90 days under
"discharge points." 40 CFR 262.34).
• Each well where fluids from the facility are injected
Note that space has been provided on the form for six outfalls. If underground.
you have more than this number,type your information on a
separate sheet of paper in a format similar to that of the form. Springs and other surface water bodies that receive stormwater
discharges from the facility.
Make sure you note the EPA Identification Number, NPDES permit
number,and facility name at the top of the page and indicate the When you have completed and attached your site map to Form 2F,
specific item of the form to which you are responding—Item 1.1 in answer"Yes"to Item 3.1.
this case. In other sections of the form,you will be asked to provide Section 4.Pollutant Sources
information by outfall number(Sections 2,4,5,and 7).
Item 4.1.List all outfalls discharging stormwater.Provide an
Section 2.Improvements estimate of the impervious surface area drained by the outfall.
Item 2.1.Indicate if you are required by any federal,state,or local Specify units of measure.(Impervious surfaces are surfaces where
authority to meet an implementation schedule for constructing, stormwater runs off at rates significantly higher than background
upgrading,or operating wastewater treatment equipment or rates—e.g.,predevelopment levels.They include paved areas,
practices or any other environmental programs that could affect the building roofs, parking lots,and roadways.)
discharges described in this application.The requirements include, Provide an estimate of the total surface area(impervious and
but are not limited to,permit conditions,administrative enforcement pervious areas)drained by each outfall(within a mile radius of the
orders,enforcement compliance schedule letters,stipulations, facility).You may use the site map developed under Item 3.1 to
court orders,and grant or loan conditions. If yes,continue to Item estimate the total area drained by each outfall.For areas under
2.2.If no,skip to Section 3, 5 acres,consult your NPDES permitting authority to determine
Item 2.2.Briefly identify and describe each applicable project(e.g., whether the area should be reported to the nearest tenth of an acre
consent decree,enforcement order,or permit condition).For each or nearest quarter of an acre.
condition,specify the affected outfall number(s),the source(s)of Item 4.2, Provide a narrative description of the following:
the discharge,the required final compliance date,and the
projected final compliance dale. Significant materials that in three years prior to the submittal of
this application have been treated,stored,or disposed of in a
Item 2.3.OPTIONAL ITEM. Indicate if you have attached any manner to allow exposure to stormwater.
sheets describing any additional water pollution control programs
(or other environmental projects that could affect your discharges) ' Method of treatment,storage,or disposal of such materials.
that you may now have underway or planned. If you attach • Materials management practices employed,in the three years
additional sheets,indicate in the attachment whether each program prior to the submittal of this application,to minimize contact by
is actually underway or is planned,and indicate your actual or these materials with stormwater runoff.
planned schedule for construction. Be sure to note your EPA • Materials loading and access areas.
Identification Number, NPDES permit number, and facility name at 0 The location,manner,and frequency in which pesticides,
the top of any attached pages. herbicides,soil conditioners,and fertilizers are applied.
You should identify your significant materials by chemical name,
2 F-2

FORM 2F—INSTRUCTIONS CONTINUED
form(e.g.,powder,liquid,etc.),and type of container or treatment Tables A,B,C,and D
unit.Indicate any materials treated,stored,or disposed of Items 7.2 to 7.17.These items require you to collect and report data
together.The term"significant materials"includes,but is not in Tables A through D,at the end of Form 2F,for the parameters and
limited to:raw materials;fuels;materials such as solvents, pollutants listed in Exhibits 2F-2,2F-3,and 21`4(at the end of the
detergents,and plastic pellets;finished materials such as metallic instructions).The instructions for completing Tables A through D are
products;raw materials used in food processing or production; table-specific,as are the criteria for determining who should
hazardous substances designated under Section 101(14)of the complete them.
Comprehensive Environmental Response,Compensation,and
Liability Act;any chemical the facility is required to report pursuant Important note:Read the"General Instructions for Reporting,
to Section 313 of Titre III of the Superfund Amendments and Sampling,and Analysis"below before completing items 7.2 to 7.17.
Reauthorization Act;and fertilizers;pesticides;and waste products Item 7.2 and Table A.All applicants must complete Table A.If the
such as ashes,slag,and sludge that have the potential to be discharge is an existing discharge and your discharge is composed
released with stormwater discharges. exclusively of stormwater(i.e.,no process or nonprocess
Item 4.3.For each outfall,list the location and type of existing wastewater)then you only need to provide monitoring data for oil and
structural and non-structural control measure(s)to reduce grease,total phosphorus,total Kjeldahl nitrogen,and total nitrogen.
pollutants in stormwater runoff.Structural controls include Indicate"NA"for"not applicable"in the columns for all other
structures that enclose materials handling or storage areas; parameters.Answer"Yes"to Item 7.2 once you have completed this
structures that cover materials;and berms,dikes,or diversion task.
ditches around manufacturing,production,storage,or treatment item 7.3 and Table B.indicate whether the facility is subject to an
units and retention ponds.Spill prevention plans,employee effluent limitations guideline(ELG)(see 40 CFR Subchapter N to
training,visual inspections,preventive maintenance,and determine which pollutants are limited in ELGs)or if the facility is
housekeeping measures are examples of non-structural controls. subject to effluent limitations in an NPDES permit for its process
wastewater or stormwater(if the facility is operating under an existing
Describe the treatment,including the schedule and type of maintenance activities performed,and the ultimate disposal of any NPDES permit).If yes,continue to Item 7.4.If no,skip to Item 7.5.
solid or fluid wastes other than by discharge.For each structural Note:Stormwater discharges from certain industrial sources or
control identified,indicate the type of treatment the stormwater activities have specific ELGs for which they must comply.These
receives using the codes in Exhibit 2F-1,at the end of the stormwater-specific ELGs include:
instructions.For each non-structural control identified,indicate Regulated Discharge 40 CFR Section
"Not Applicable"in the"Codes from Exhibit 2F-1"column. Discharges resulting from spraydown or Intentional Part 429,Subpart
Section 5.Non-Stormwater Discharges wetting of logs at wet deck storage areas
Item 5.1.Provide a certification that all outfalls that should contain Runoff from phosphate fertilizer manufacturing fadlitles Part 418,Subpart A
that comes into contact with any raw materials,finished
stormwater discharges associated with industrial activity have product,byproducts or waste products(SIC 2874)
been tested or evaluated for the presence of non-stormwater Runoff from asphalt emulsion facilities Part443,SubpartA
discharges.Tests for such non-stormwater discharges can include Runoff from material storage piles at cement Part411,Subpart C
smoke tests,fluorometric dye tests,analysis of accurate manufacturing facilities
schematics,and others. Mine dewatering discharges at crushed stone, Part 436,Subparts B,
tion of the method used,the date of an construction sand and gravel,or industrial sand mining c,and o
Item 5.2.Include a description Y facilities
testing,and the onsite drainage points that were directly observed Runoff from hazardous waste and non-hazardous waste Pan445,Subparts A
during a test used to support the certification in Item 5.1.All non- landfills and B
stormwater discharges must be identified in a Form 2C,2D,or 2E. Runoff from coal storage piles at steam electric Part 423
See"Who Must Complete Form 2F?"above for more information. generating fadlifies
Section 6.Significant Leaks or Spills Runoff containing urea from airfield pavement deicing at Part 449
erasting and new primary airports with 1,000 or more
Item 6.1.Describe any significant leaks or spills of toxic or annual non-propeller aircraft departures
hazardous pollutants at the facility within the three years prior to Item 7.4.In Table B,list all pollutants that are limited in an ELG to
the submittal of this application.Include the approximate date and which the facility is subject and all pollutants listed in the facility's
location of the spill or leak and the type and amount of material NPDES permit for its process wastewater(if the facility is operating
released. under an existing NPDES permit)and provide quantitative data for
Section 7.Discharge Information each pollutant(provide actual data for existing dischargers and
Item 7.1.Answer whether you are a new source or new discharge. estimated data for new sources and new dischargers).If a pollutant
Contact your NPDES permitting authority to determine if you are a in Exhibits 2F-2 or 2F-3 is indirectly limited by an ELG through an
new source or new discharge. indicator(e.g.,use of total suspended solids as an indicator to
control the discharge of iron and aluminum),you must provide data
for the pollutant in Table B.Complete one table for each outfall.
Answer"Yes'to Item 7.4 once you have completed this task.
2F-3

FORM 2F--INSTRUCTIONS CONTINUED
Item 7.5 and Table C.Table C requires you to address the Item 7.11. Provide quantitative data in Table C for those pollutants
pollutants in Exhibits 2F-2,2F-3,and 2F-4 for each outfall, in Exhibit 2F-3 that you expect to be discharged in concentrations
Pollutants in each of these exhibits are addressed differently. of 10 ppb or greater(provide actual data for existing dischargers
Indicate whether you know or have reason to believe any pollutants and estimated data for new sources and new dischargers).Answer
in Exhibit 2F-2 are present in the discharge. If yes,continue to Item "Yes"to Item 7.11 once you have completed this task,
7.6,If no,skip to Item 7.7. Item 7.12.Indicate whether you expect acrolein,acrylonitrile,2,4-
Item 7,6.For each outfall,list all pollutants in Exhibit 2F--2 that you dinitrophenol,or 2-methyl-4,6-dinitrophenol to be discharged in
know or have reason to believe are present in the discharge in concentrations of 100 ppb or greater. If yes,continue to Item 7.13.
Table C(except pollutants previously listed in Table 8 that are If no,skip to item 7.14.
limited directly or indirectly by an ELG)and either report quantitative Item 7.13.Provide quantitative data in Table C for the pollutants
data or briefly describe the reasons the pollutant is expected to be identified in Item 7.12 that you expect to be discharged in
discharged.Answer"Yes"to Item 7.6 once you have completed this concentrations of 100 ppb or greater(provide actual data for
task. existing dischargers and estimated data for new sources and new
Item 7.7.This item asks if you qualify as a"small business."If so, dischargers).Answer"Yes"to Item 7.13 once you have completedthis task.
you are exempt from the reporting requirements for the organic toxic
pollutants listed in Exhibit 2F-3. Item 7.14.For any pollutants you expect to be present in the
You can qualify as a small business in two ways; (1)If your facility is discharge at concentrations less than 10 ppb(or less than 100 ppb
a coal mine and if your probable total annual production is less than for the above four pollutants),either submit quantitative data or
100,000 tons per year,you may submit past production data or briefly describe the reasons the pollutant is expected to be
estimated future production(such as a schedule of estimated total discharged in Table C.Answer"Yes to Item 7.14 once you have
production under 30 CFR 795.14(c))instead of conducting analyses completed this task.
for the organic toxic pollutants;(2)If your facility is not a coal mine Item 7.15.Indicate whether you know or have reason to believe
and if your gross total annual sales for the most recent three years any pollutants in Exhibit 2F4 are present in the discharge, If yes,
average less than$100,000 per year(in second quarter 1980 continue to Item 7.16. If no,skip to Item 7.17.
dollars),you may submit sales data for those years instead of Item 7.16.For each outfall,list any pollutant in Exhibit 2F4 that
conducting analyses for the organic toxic pollutants.The production you know or believe to be present in the discharge in Table C and
or sales data must be for the facility that is the source of the explain why you believe it to be present, No analysis is required,
discharge.The data should not be limited to production or sales for but if you have analytical data,you must report it.Answer"Yes"to
the process or processes that contribute to the discharge, unless Item 7.16 once you have completed this task.
those are the only processes at your facility.For sales data,in
situations involving intra-corporate transfer of goods and services, Note:Under 40 CFR 117,12(a)(2),certain discharges of hazardous
the transfer price per unit should approximate market prices for substances(listed in Exhibit 2F5)may be exempted from the requirements of
those goods and services as closely as possible. Sales figures for CWA Section 311,which establishes reporting requirements,civil penalties,
years after 1980 should be indexed to the second quarter of 1980 by and liability for cleanup costs for spills of oil and hazardous substances.A
using the gross national product price deflator(second quarter of discharge of a particular substance can be exempted if the origin,source,and
amount of the discharged substances are identified in the NPDES permit
1980= 100),This index is available online from the U.S. Department application or in the permit,if the permit contains a requirement for treatment
of Commerce, Bureau of Economic Analysis at of the discharge,and if the treatment is in place.If you would like to apply for
httl7:Nwww,bee.goylnatlonalINUSNTables. an exemption from the requirements of CWA Section 311,attach additional
sheets of paper to your application,setting forth the following information:
If you qualify as a small business according to the criteria above, 1. The substance and the amount of each substance that might be
answer"Yes"to Item 7.7 and skip to Item 7.18.Otherwise,answer discharged.
"No"and Continue to Item 7.8. 2. The origin and source of the discharge of the substance.
Item 7.8.Indicate whether you know or have reason to believe any 3. The treatment to be provided for the discharge by:
pollutants in Exhibit 217-3 are present in the discharge.If yes, a. An onsile treatment system separate from any treatment system
treating your normal discharge;
continue to Item 7.9. If no,skip to Item 7.10. b. A treatment system designed to treat your normal discharge and that
Item 7.9.For each outfall,list all pollutants in Exhibit 2F-3 that you is additionally capable of treating the amount of the substance
know or have reason to believe are present in the discharge in identified under paragraph 1 above;or
Table C(except pollutants previously listed in Table B).Answer c. Any combination of the above.
"Yes"to Item 7.9 once you have completed this task, See 40 CFR 117.12(a)(2)and(c)or contact your NPDES permitting authority
for further infonnation on exclusions from CWA Section 311.
Item 7.10.Indicate whether you expect any of the pollutants from
Exhibit 2F--3 to be discharged in concentrations of 10 parts per Item 7.17 and Table D.Provide data for the storm event(s)that
billion(ppb)or greater. If yes,continue to Item 7.11. If no,skip to resulted in the maximum daily discharges for the Flow weighted
Item 7.12. composite sample in Table D. If sampling is conducted during more
than one storm event,you only need to report the information
2F-4

FORM 21F—INSTRUCTIONS CONTINUED
requested on Table D for the storm event(s)that resulted in any Section 10.Checklist and Certification Statement
maximum pollutant concentration reported on Tables A through C. Item 10.1.Review the checklist provided on the application.In
Provide flow measurements or estimates of the flow rate,as well as Column 1,mark the sections of Form 2F that you have completed
the total amount of discharge for the storm event(s)sampled,the and are submitting with your application.For each section in
method of flow measurement,or estimation.Provide the data and Column 2,indicate whether you are submitting attachments.
duration of the storm event(s)sampled,rainfall measurements,or Item 10.2.The Clean Water Act(CWA)provides for severe
estimates of the storm event that generated the sampled runoff and penalties for submitting false information on this application form.
the duration between the storm event sampled and the end of the Section 309(c)(2)of the CWA provides that,"Any person who
previous measurable(greater than 0.1 inch rainfall)storm event. knowingly makes any false material statement,representation,or
Answer"Yes"to Item 7.17 once you have completed this task. certification in any application,...shall upon conviction be punished
Used or Manufactured Toxics by a fine of not more than$10,000 or by imprisonment for not more
Item 7.18.Review Exhibits 2F-2 through 2F4 and determine if you than six months or both."
currently use or manufacture any of the pollutants listed as FEDERAL REGULATIONS AT 40 CFR 122.22 REQUIRE THIS
intermediate or final products or byproducts.If so,answer"Yes." APPLICATION TO BE SIGNED AS FOLLOWS:
You should also answer"Yes"if you know or have reason to
believe that 2,3,7,8-tetrachloro-dibenzo-p-dioxin(TCDD)is A. For a corporation,by a responsible corporate officer.For the
discharged or if you use or manufacture 2,4,5-Mchlorphenoxy purpose of this section,a responsible corporate officer means:
acetic acid(2,4,5-T);2-(2,4,5-tdchlorophenoxy)propanoic acid (1)a president,secretary,treasurer,or vice-president of the
(Silvex,2,4,5-TP);2-(2,4,5-Mchlorophenoxy)ethyl,2,2- corporation in charge of a principal business function,or any
dichloropropionate(Erbon);0,0-dimethyl 0-(2,4,5-tdchlorphenyl) other person who performs similar policy-or decision-making
phosphorothioate(Ronnel);2,4,5-tdchlorophenol(TCP);or functions for the corporation,or(2)the manager of one or
hexachlorophene(HCP).If your answer to Item 7.18 is"No,"skip to more manufacturing,production,or operating facilities,
Section 8. provided the manager is authorized to make management
decisions which govern the operation of the regulated facility
Item 7.19.List all of the toxic pollutants identified under Item 7.18, including having the explicit or implicit duty of making major
including TCDD.Note that the NPDES permitting authority may capital investment recommendations,and initiating and
waive or modify the requirement if you demonstrate that it would be directing other comprehensive measures to assure long term
unduly burdensome to identify each toxic pollutant and the NPDES environmental compliance with environmental laws and
permitting authority has adequate information to issue your permit. regulations;the manager can ensure that the necessary
You may not claim any information submitted in response to Item systems are established or actions taken to gather complete
7.18 as confidential;however,you do not have to distinguish and accurate information for permit application requirements;
between use or production of the pollutants or list the amounts. and where authority to sign documents has been assigned or
Section 8.Biological Toxicity Testing Data delegated to the manager in accordance with corporate
Item 8.1.Answer whether you know of or have reason to believe procedures.
that biological toxicity testing has been conducted of your B. For a partnership or sole proprietorship,by a general partner
wastewater treatment,including engineering reports or pilot plant or the proprietor,respectively.
studies.If no,skip to Section 9.Otherwise,continue. C. For a municipality,state,federal,or other public facility,by
Item 8.2.List any tests of which you are aware and their purposes. either a principal executive officer or ranking elected official.
For purposes of this section,a principal executive officer of a
Section 9.Contract Analysis Information federal agency includes:(1)The chief executive officer of the
Item 9.1.Indicate if any of the analyses performed in Section 7 agency,or(2)a senior executive officer having responsibility
were performed by a contract laboratory or consulting firm.If no, for the overall operations of a principal geographic unit of the
skip to Section 10.If yes,continue to Item 9.2. agency(e.g.,Regional Administrators of EPA).
Item 9.2.Provide the name,address,phone number,and pollutants END
analyzed by the laboratory or consulting firm(s)in the spaces Submit your completed Form 1,Form 2F,and
provided. all associated attachments
(and any other required NPDES application forms)
to your NPDES permitting authority.
2F-5

General Instructions for Reporting,Sampling,and Analysis
Important note:Read these instructions before completing Tables byproducts,and any previous analyses known to you of your
A through C and Section 7 of Form 2F. effluent or similar effluent.
General Items Sampling
Complete the applicable tables for each outfall at your facility.Be The collection of the samples for the reported analyses should be
sure to note the EPA Identification Number,NPDES permit supervised by a person experienced in performing sampling of
number,facility name,and applicable outfall number at the top of industrial wastewater or stormwater discharges.You may contact
each table page and any associated attachments. your NPDES permitting authority for detailed guidance on sampling
You may report some or all of the required data by attaching techniques and for answers to specific questions.See Exhibit 1-1 of
separate sheets of paper instead of completing Tables A through C Form 1 for contact information.Any specific requirements in the
for each of your outfalls so long as the sheets contain all of the analytical methods—for example,sample containers,sample
required information and are similar in format to Tables A through preservation,holding times,and the collection of duplicate
C.For example,you may be able to print a report in a compatible samples—must be followed.
format from the data system used in your gas chromatography/ The time when you sample should be representative of your normal
mass spectrometry(GC/MS)analysis completed under Table B. operation,to the extent feasible,with all processes that contribute
If you are an existing discharger,you are required to report actual wastewater in normal operation,and with your treatment system
quantitative data.See"Use of Historic Data"below for use of operating properly with no system upsets.Collect samples from the
historic data.If you are a new source or discharge,you may supply center of the flow channel,where turbulence is at a maximum,at a
site specified
estimated data along with the source of each estimate.If you have
specified in your present NPDES permit,or at any site adequate
quantitative data available,however,you must provide it.Base for the collection of a representative sample.
estimates on available,in-house or contractor engineering reports, Grab samples must be taken in the first 30 minutes of discharge(or
or any other studies performed on the proposed facility.Use the as soon thereafter as practicable)for pH,temperature,cyanide,total
following codes to report your source information in the"Source of phenols,residual chlorine,oil and grease,fecal coliform(including
Information"column: E.colt)and enterocood(previously known as fecal streptococcus at
Data Source Code 40 CFR 122.26(d)(2)(iii)(A)(3)),and volatile organic compounds.
Engineering reports 1 You are not required to analyze a flow-weighted composite for these
Actual data from pilot plants 1 parameters.
Estimates from other engineering 2 For all other pollutants,both a grab sample collected during the first
reports 30 minutes(or as soon thereafter as practicable)of the discharge
Data from other similar plants 3 and a flow-weighted composite sample must be analyzed.However,
Best professional estimates 4 a minimum of one grab sample may be taken for effluents from
Others 5 and specify on holding ponds or other impoundments with a retention period of
the table greater than 24 hours.
No later than 24 months after your facility commences to
discharge,you must complete and submit sampling and analysis All samples must be collected from the discharge resulting from a
data for the pollutants and parameters in Tables A through C. storm event that is greater than 0.1 inches and at least 72 hours
However,you need not report results for tests you have already from the previously measurable(greater than 0.1 inch rainfall)storm
performed and reported under the discharge monitoring event Where feasible,the variance in the duration of the event and
requirements of your NPDES permit. the total rainfall of the event should not exceed 50 percent from the
Table A requires you to report at least one analysis for each average or median rainfall event in that area.
pollutant listed.Tables B and C require you to report analytical data A grab sample must be taken during the first 30 minutes of the
in two ways.For some pollutants addressed in Tables B and C,if discharge(or as soon thereafter as practicable),and a flow-
you know or have reason to know that the pollutant is present in weighted composite must be taken for the entire event or for the first
your discharge,you may be required to list the pollutant and test three hours of the event.
(sample and analyze)and report the levels of the pollutants in your Grab and composite samples are defined as follows:
discharge.For all other pollutants addressed in Tables B and C,
you must list the pollutant if you know or have reason to know that Grab sample:An individual sample of at least 100 milliliters
the pollutant is present in the discharge,and either report collected during the first 30 minutes(or as soon thereafter as
quantitative data for the pollutant or briefly describe the reasons practicable)of the discharge.This sample is to be analyzed
the pollutant is expected to be discharged.(See Items 7.2 through separately from the composite sample.
7.17 of the instructions for completing Tables A through C.).Base Flow-weighted composite sample:A flow-weighted composite
your determination that a pollutant is/will be present in your sample may be taken with a continuous sampler that proportions the
discharge on your knowledge of the facility's raw materials, amount of sample collected with the flow rate or as a combination of
material management practices,maintenance chemicals,history of a minimum of three sample aliquots taken in each hour of discharge
spills and releases,intermediate and final products and
2F-6

General Instructions for Reporting,Sampling,and Analysis Continued
for the entire event or for the first three hours of the event,with All reporting of values for metals must be in terms of"total
each aliquot being at least 100 milliliters and collected with a recoverable metal"unless:
minimum period of 15 minutes between aliquot collections.The An applicable,promulgated ELG specifies the limitation for the
composite must be flow proportional;the time interval between
either each aliquot or the volume of each aliquot must be metal in dissolved,valent,or total form;
proportional to either the stream(effluent)flow at the time of • All approved analytical methods for the metal inherently
sampling or the total stream(effluent)flow since the collection of measure only its dissolved form(e.g.,hexavalent chromium);
the previous aliquot.Aliquots may be collected manually or or
automatically.Where GC1MS volatile organic analysis is required, . The NPDES permitting authority has determined that in
aliquots must be combined in the laboratory immediately before establishing case-by-case limitations it is necessary to express
analysis.Only one analysis for the composite sample is required. the limitations of the metal in dissolved,valent,or total form to
Use of Historical Data carry out the provisions of the CWA.
Existing data may be used,if available,in lieu of sampling If you measure only one grab sample and one flow-weighted
conducted solely for the purposes of this application,provided it is composite sample for a given outfall,complete only the"Maximum
representative of the present discharge and was collected within Daily Discharge"columns in the tables and enter"1"in the"Number
3 years of the application due date.If you sample for a listed of Storm Events Sampled"column.The NPDES permitting authority
pollutant on a monthly or more frequent basis,summarize the data may require you to conduct additional analyses to further
collected within one year of the application for the pollutant(s)at characterize your discharges.
issue. If you measure more than one value for a grab sample or a flow-
Among the factors that would cause the data to be weighted composite sample for a given outfall and those values are
unrepresentative are significant changes in production level; representative of your discharge,you must report them.You must
changes in raw materials,processes,or final products;and describe your method of testing and analysis.
changes in stormwater treatment.The NPDES permitting authority may request additional information,including current quantitative The"Average Daily Discharge' column on Tables A to C is not
compulsory but should be
data,if they determine it to be necessary to assess your filled out if data are available.To
complete the"Average Daily Discharge
discharges.The NPDES permitting authority may allow or establish column,determine the
appropriate site-specific sampling procedures or requirements average of all values within the last year and report the
i concentration and mass.Report the total number of storm events
including sampling locations,the season in which the sampling
takes place,the minimum duration between the previous sampled under the"Number of Storm Events Sampled"column.
measurable storm event and the storm event sampled,the Substantially Identical Outfalls
minimum or maximum level of precipitation required for an If you have two or more substantially identical outfalls,you may
appropriate storm event,the form of precipitation sampled(snow request permission from your NPDES permitting authority to sample
melt or rainfall),protocols for collecting samples under 40 CFR 1361 and analyze only one eutfall and submit the results of the analysis
and additional time for submitting data on a case-by-case basis. for all substantially identical outfalls.If your request is granted,
Reporting submit the following information on a separate sheet attached to the
Report sampling results for all pollutants in Tables A through C as application form:the identity of the outfall you did test and an
concentration and mass,with the exception of flow,temperature, explanation of how it is substantially identical to the outfall(s)that
pH,color,and fecal coliform organisms. you did not test.
Flow,temperature,pH,color,and fecal coliform organisms must Analysis
be reported as million gallons per day(mgd),degrees Celsius Except as specified below,all required quantitative data shall be
(°C),standard units,color units,and most probable number per collected in accordance with sufficiently sensitive analytical methods
100 milliliters(MPN1100 mQ,respectively.Use the following approved under 40 CFR 136 or required under 40 CFR chapter I,
abbreviations in the columns requiring"units"in Tables A through subchapter N or 0.A method is"sufficiently sensitive"when:
C.
• The method minimum level(ML)is at or below the level of the
Concentration Mass applicable water quality criterion for the measured pollutant or
m=parts per million Ibs=pounds pollutant parameter.
m L=milligrams per liter ton=tons(English tons The method MIL is above the water quality criterion,but the
b=parts per billion mg=milligrams amount of the pollutant or pollutant parameter in the facility's
=microqrams per liter g=grams discharge is high enough that the method detects and
IVIPN=most probable number per kg=kilograms quantifies the level of the pollutant or pollutant parameter in the
100 milliliters T=tonnes metric tons discharge.
2F-7

General Instructions for Reporting,Sampling,and Analysis Continued
• The method has the lowest ML of the analytical methods select a different method from the remaining EPA-approved
approved under 40 CFR 136 or required under 40 CFR methods that is sufficiently sensitive consistent with 40 CFR
chapter I,subchapter N or 0,for the measured pollutant or 122.21(e)(3)(i).Where no other EPA-approved methods exist,you
pollutant parameter. must select a method consistent with 40 CFR 122.21(e)(3)(ii).
Consistent with 40 CFR 136,you may provide matrix-or sample- When there is no analytical method that has been approved under
specific MLs rather than the published levels.Further,where you 40 CFR 136;required under 40 CFR chapter I,subchapter N or 0,
can demonstrate that,despite a good faith effort to use a method and is not otherwise required by the NPDES permitting authority,
that would otherwise meet the definition of"sufficiently sensitive," you may use any suitable method but shall provide a description of
the analytical results are not consistent with the quality assurance the method.When selecting a suitable method,other factors such
(QA)Iquality control(QC)specifications for that method,then the as a method's precision,accuracy,or resolution,may be considered
NPDES permitting authority may determine that the method is not when assessing the performance of the method,
performing adequately and the NPDES permitting authority should
2F-8

Exhibit 2F-1.Codes for Treatment Units and Disposal of Wastes Not Discharged
1. PHYSICAL TREATMENT PROCESSES
1—A.................Ammonia stripping 1—M................Grit removal
1-13.................Dialysis 1—N................Microstraining
1—C................Diatomaceous earth filtration 1-0................Mixing
1—D................Distillation 1—P................Moving bed filters
1—E.................Electrodialysis 1—Q................Multimedia filtration
1—F.................Evaporation 1—R................Rapid sand filtration
1—G................Flocculation 1—S................Reverse osmosis(hyperfiltration)
1—H................Flotation 1—T................Screening
1-1..................Foam fractionation 1—U................Sedimentation(settling)
1—J.................Freezing 1—V................Slow sand filtration
1—K.................Gas-phase separation 1—W...............Solvent extraction
1—L.................Grinding(comminutors) 1—X................Sorption
2. CHEMICAL TREATMENT PROCESSES
2 A.................Carbon adsorption 2—G................Disinfection(ozone)
2-13.................Chemical oxidation 2—H................Disinfection(other)
2—C................Chemical precipitation 2—I..................Electrochemical treatment
2-1)................Coagulation 2—J.................Ion exchange
2—E.................Dechlorination 2—K................Neutralization
2—F.................Disinfection(chlorine) 2—L.................Reduction
3. BIOLOGICAL TREATMENT PROCESSES
3—A.................Activated sludge 3—E................Pre-aeration
3—B.................Aerated lagoons 3—F................Spray irrigation/land application
3—C................Anaerobic treatment 3—G................Stabilization ponds
3—D................Nitrification—denitrification 3—H................Trickling filtration
4. WASTEWATER DISPOSAL PROCESSES
4—A.................Discharge to surface Water 4—C................Reuselrecycle of treated effluent
4-13.................Ocean discharge through outfall 4—D................Underground injection
5. SLUDGE TREATMENT AND DISPOSAL PROCESSES
5—A.................Aerobic digestion 5—M................Heat drying
5-13.................Anaerobic digestion 5—N................Heat treatment
5—C................Belt filtration 5-0................Incineration
5—D................Centrifugation 5—P................Land application
5—E.................Chemical conditioning 5—Q................Landfill
5—F.................Chlorine treatment 5—R................Pressure filtration
5—G................Composting 5—S................Pyrolysis
5—H................Drying beds 5—T................Sludge lagoons
5-1..................Elutriation 5—U................Vacuum filtration
5—J.................Flotation thickening 5—V................Vibration
5—K.................Freezing 5—W...............Wet oxidation
5-1..................Gravity thickening
2F-9

Exhibit 2F-2.Conventional and Nonconventional Pollutants(40 CFR 122.21,Appendix D,Table IV)
Bromide
Chlorine,total residual
Color
Fecal colifonn
Fluoride
Nitrate-nitrite
Nitrogen,total organic(as N)
Oil and grease
Phosphorus(as P),total
Radioactivity(as alpha,total;beta,total;radium,total;and radium 226,total)
Sulfate(as SO4)
Sulfide(as S)
Sulfite(as S03)
Surfactants
Aluminum,total
Barium,total
Boron,total
Cobalt,total
Iron,total
Magnesium,total
Molybdenum,total
Manganese,total
Tin,total
Titanium,total
2F-10

Exhibit 2F-3.Toxic Pollutants(40 CFR 122.21,Appendix D,Tables II and III)
Toxic Pollutants and Total Phenol
Antimony,total Copper,total Silver,total
Arsenic,total Lead,total Thallium,total
Beryllium,total Mercury,total Zinc,total
Cadmium,total Nickel,total Cyanide,total
Chromium,total Selenium,total Phenols,total
GCIMS Fraction—Volatile Compounds
Acrolein Dichlorobromomethane 1,1,2,2-tetrachloroethane
Acrylonitrile 1,1-dichloroethane Tetrachlorcethylene
Benzene 1,2-dichloroethane Toluene
Bromoform 1,14chloroethylene 1,2-trans-dichloroethylene
Carbon tetrachloride 1,2-dichloropropane 1,1,1-trichloroethane
Chlorobenzene 1,3-dichloropropylene 1,1,2-tdchloroethane
Chlorodibromomethane Ethylbenzene Trichloroethylene
Chloroethane Methyl bromide Vinyl chloride
2-Chloroethylvinyl ether Methyl chloride
Chloroform Methylene chloride
GCIMS Fraction—Acid Compounds
2-chlorophenol 2,4-dinitrophenol Pentachlorophenol
2,4-dichlorophenol 2-nitrophenol Phenol
2,4-dimethylphenol 4-nitrophenol 2,4,6-tdchlorophenol
4,6-dinitro-o-cresol P-chloro-m-cresol
GCIMS Fraction—Base/Neutral Compounds
Acenaphthene 4-chlorophenyl phenyl ether Hexachlorobenzene
Acenaphthylene Chrysene Hexachlorobutadiene
Anthracene Dibenzo(a,h)anthracene Hexachlorocyclopentadiene
Benzidine 1,2-dichlorobenzene Hexachloroethane
Benzo(a)anthracene 1,3-dichlorobenzene Indeno(1,2,3-cd)pyrene
Benzo(a)pyrene 1,4-dichlorobenzene Isophorone
3,4-benzofluoranthene 3,3-dichlorobenzidine Naphthalene
Benzo(ghi)perylene Diethyl phthalate Nitrobenzene
Benzo(k)fluoranthene Dimethyl phthalate N-nitrosodimethylamine
Bis(2-chloroethoxy)methane Di-n-butyl phthalate N-nitrosodi-n-propylamine
Bis(2-chloroethyl)ether 2,4-dinitrotoluene N-nitrosodiphenylamine
Bis(2-chioroisopropyi)ether 2,6-dinitrotoluene Phenanthrene
Bis(2-ethylhexyl)phthalate Di-n-octyl phthalate Pyrene
4-bromophenyl phenyl ether 1,2-diphenylhydrazine(as azobenzene) 1,2,4-bichlorobenzene
Butyl benzyl phthalate Fluoranthene
2-chloron2phthalene Fluorene
GCIMS Fraction—Pesticides
Aldrin Dieldrin PCB-1254
a-BHC a-endosulfan PCB-1221
f-BHC O endosulfan PCB-1232
y-BHC Endosulfan sulfate PCB-1248
b-BHC Endrin PCB-1260
Chlordane Endrin aldehyde PCB-1016
4,4'-DDT Heptachlor Toxaphene
4,4'-DDE Heptachlor epoxide
4,4'-DDD PCB-1242
2F-11

Exhibit 2F4.Certain Hazardous Substances and Asbestos(40 CFR 122.21,Appendix D,Table V)
Toxic Pollutant
Asbestos
Hazardous Substances
Acetaldehyde Dintrobenzene Naphthenic acid
Allyl alcohol Diquat Nitrotoluene
Allyl chloride Disulfoton Parathion
Amyl acetate Diuron Phenolsulfonate
Aniline Epichlorohydrin Phosgene
Benzonitrile Ethion . Propargite
Benzyl chloride Ethylene diamine Propylene oxide
Butyl acetate Ethylene dibromide Pyrethrins
Butylamine Formaldehyde 4uinoline
Caplan Furfural Resorcinol
Carbaryl Guthion Strontium
Carbofuran Isoprene Strychnine
Carbon disulfide Isopropanolamine Styrene
Chlorpyrifos Kelthane 2,4,5-T(2,4,5-tdchlorophenoxyacetic
acid)
Coumaphos Kepone TDE(tetrachlorodiphenyi ethane)
Cresol Malathion 2,4,5-TP[2-(2,4,5-trichlorophenoxy)
propanoic acid]
Crotonaldehyde Mercaptodimethur Tdchlorofon
Cyclohexane Methoxychlor Triethanolamine
2,4-D(2,4-dichlorophenoxyacefic acid) Methyl mercaptan Triethylamine
Diazinon Methyl methacrylate Trimethylamine
Dicamba Methyl parathion Uranium
Dichlobenil Mevinphos Vanadium
Dichlone Mexacarbate Vinyl acetate
2,2-dichloropropionic acid Monoethyl amine Xylene
Dichlorvos Monomethyl amine Xylenol
Diethyl amine Naled Zirconium
Dimethyl amine
2F-12

Exhibit 2F-5.Hazardous Substances
1.Acetaldehyde 73.Captan 144.Ferrous sulfate
2.Acetic add 74.Carbaryl 145.Formaldehyde
3.Acetic anhydride 75.Carbofuran 146.Formic add
4.Acetone cyanohydrin 76.Carbon disulfide 147.Fumaric acid
5.Acetyl bromide 77.Carbon tetrachloride 148.Furfural
6.Acetyl chloride 78.Chlordane 149.Guthlon
7.Akxolein 79.Chlorine 150.Heptachlor
8.Acrydonitrfle 80,Chlorobenzene 151.Hexachlorocydopentadiene
9.Adipic add 81.Chloroform 152.Hydrochloric acid
10.Alddn 82,Chloropyrifos 153.Hydrofluoric add
11.Allyl alcohol 83.Chlorosulfonic add 154.Hydrogen cyanide
12.Ago chloride 84.Chromic acetate 155.Hydrogen sulfide
13.Aluminum sulfate 85.Chromic add 156.Isoprene
14.Ammonia 86.Chromic sulfate 157.Isopropanolamine dodecylbenzenesulfonate
15.Ammonium acetate 87.Chromous chloride 158.Kelthane
16.Ammonium benzoate 88.Cobaltous bromide 159.Kepone
17,Ammonium bicarbonate 89.Cobaltous formate 160.Lead acetate
18.Ammonium bichromate 90.Cobaltous sulfamate 161.Lead arsenate
19.Ammonium bifluoride 91.Coumaphos 162.Lead chloride
20.Ammonium bLsuffite 92.Cresol 163,Lead fluoborate
21.Ammonium carbamate 93.Crotonaldehyde 164.Lead fluorite
22.Ammonium carbonate 94.Cupric acetate 165.Lead iodide
23.Ammonium chloride 95.Cupric aoetoarsenite 166.Lead nitrate
24.Ammonium chromate 96.Cupric chloride 167.Lead stearate
25.Ammonium citrate 97.Cupric nitrate 168.Lead sulfate
26.Ammonium fluoroborate 98.Cupric oxalate 169.Lead sulfide
27.Ammonium fluoride 99.Cupric sulfate 170.Lead thfocyanate
28.Ammonium hydroxide 100.Cupric sulfate ammoniated 171.Undane
29.Ammonium oxalate 101.Cupric tartrate 172.Lithium chromate
30.Ammonium silicofluoride 102.Cyanogen chloride 173.Marathion
31.Ammonium sulfamate 103.Cydohexane 174,Maleic add
32.Ammonium sulfide 104.2,4-D add(2,4-dichlorophenoxyacetc add) 175.Maleic anhydride
33.Ammonium sulfite 105.2,4-D esters(2,4-dlchlorophenoxyacedc add esters) 176.Mercaptodimethur
34.Ammonium tartrate 106.DDT 177.Mercuric cyanide
35.Ammonium thiocyanate 107.Diadnon 178.Mercuric nitrate
36.Ammonium thiosulfate 108.Dicamba 179.Mercuric sulfate
37.Amyl acetate 109.Dichlobenil 180,Mercuric thlocyanate
38.Aniline 110.Dichlone 181.Mercurous nitrate
39.Antimony pentachloride 111.Dichlorobenzene 182.Methoxychlor
40.Antimony potassium tartrate 112.Dichloroprcpane 183.Methyl mercaptan
41.Antimony tribromide 113.Dichloropropene 184.Methyl methacrylate
42.Antimony trichlodde 114,Dichloropropenedichloproropane mix 185.Methyl parathion
43.Antimony tdfluodde 115.2,2dichloropropionic add 186.Mevinphos
44.Antimony trioxide 116.Dichlonros 187.Mexacarbate
45.Arsenic disulfide 117.Dieldrin 188.Monoethylamine
46,Arsenic pentoxide 118.Diethylamine 189,Monomethylamine
47.Arsenic trichloride 119.Dimethylamine 190.Naled
48.Arsenic trioxide 120.Dinitrobenzene 191.Naphthalene
49.Arsenic trisuifide 121.Dinitrophenol 192.Naphthenic add
50.Barium cyanide 122.Dinitrotoluene 193.Nickel ammonium sulfate
51.Benzene 123.Dfquat 194.Nickel chloride
52.Benzolc add 124.Disuifaton 195.Nickel hydroxide
53.Benzonitrile 125.Duren 196.Nickel nitrate
54.Benzoyi chloride 126.Dodecyibenzesulfonlc add 197.Nickel sulfate
55.Benzyl chloride 127.Endosulfan 198.Nitric add
56.Beryilfum chloride 128,Endrin M.Nitrobenzene
57.Beryilfum fluoride 129.Epidrlorohydrin 200.Nitrogen dioxide
58.B#Rum nitrate 130.Ethion 201.Nitrophenol
59.Butylaoetate 131.Ethylbenzene 202.Nitrotoluene
60.n-butylphthalate 132.Ethylenediamine 203.Parafornaldehyde
61.Butylamine 133.Ethylene dibromide 204.Parathlon
62.Butyric add 134.Ethylene dichloride 205.Pentachlorophenol
63.Cadmium acetate 135.Ethylene diaminetetracetic add(EDTA) 206.Phenol
64.Cadmium bromide 136.Ferric ammonium citrate 207.Phosgene
65.Cadmium chloride 137.Ferric ammonium oxalate 208.Phosphoric add
66.Calcium arsenate 138.Fertfc chloride 209.Phosphorus
67.Calcium arsenite 139.Ferric fluoride 210.Phosphorus oxychloride
68.Calcium carbide 140.Ferric nitrate 211.Phosphorus pentasulfide
69.Calcium chromate 141.Ferric sulfate 212.Phosphorus trichlodde
70.Calcium cyanide 142.Ferrous ammonium sulfate 213.Polychlorinated biphenyls(PCB)
71.Calcium dodecylbenzenesulfonate 143.Ferrous chloride 214.Potassium arsenate
72.Calcium hypochlorfte 215.Potassium arsenite
2F-13

Exhibit2F-5.Hazardous Substances
216.Potassium bichromate 245.Sodium phosphate(dibasic) 271.Uranyl acetate
217.Potassium chromate 246.Sodium phosphate(tribasic) 272.Uranyl nitrate
218.Potassium cyanide 247.Sodium selenite 273.Vanadium penoxide
219.Potassium hydroxide 248.Strontium chromate 274.Vanadyl sulfate
220.Potassium permanganate 249.Strychnine 275.Vinyl acetate
221.Propargde 250.Styrene 276.Vinyiidene chloride
222.Propionicacid 251,Sulfuric add 277.Xylene
223.Propionic anhydride 252.Sulfur monochloride 278.Xylenol
224.Propylene oxide 253.2,4,5-T add(2,4,5-trichlorophenoxyacetic add) 279.Zinc acetate
225.Pyrethrins 254.2,4,5-T amines(2,4,5-trichlorophenoxy acetic add 280.Zinc ammonium chloride
226.Quinoline amines) 281.Zinc borate
227,Resorcinol 255.2,4,5-T esters(2,4,5-tdchlorophenoxy acetic add 282.Zinc bromide
228.Selenium oxide esters) 283.Zinc carbonate
229.Silver nitrate 256.2,4,5-T salts(2,4,5-tridhlorophenoxy acetic add 284.Zinc chloride
230.Sodium salts) 285.Zinc cyanide
231.Sodium arsenate 257.2,4,5-TP add(2,4,5-trichlorophenoxy propanoic 286.Zinc fluoride
232.Sodium arsenhe add) 287.Zinc formate
233.Sodium bichromate 258.2,4,5-TP add esters(2,4,5-tdchlorophenoxy 288.Zlnc hydrosulfrte
234.Sodium b1fluodde propanoic add esters) 289.Zinc nitrate
235.Sodium bisulfite 259.TIDE(tetrachlorodiphenyi ethane) 290.Zinc phenolsuHonate
236.Sodium chromate 260.Tetraethyl lead 291.Zinc phosphide
237.Sodium cyanide 261.Tetraethyl pyrophosphate 292,Zinc silicofluoride
238.Sodium dodecylbenzenesulfonate 262.Thallium sulfate 293.Zinc sulfate
239,Sodium fluoride 263,Toluene 294.Zirconium nitrate
240.Sodium hydrosulfide 264.Toxaphene 295.Zirconium potassium fluoride
241.Sodium hydroxide 265.Tdchlorofon 296.Zirconium sulfate
242.Sodium hypos hlorite 266.Trichloroethylene 297.Zirconium tetrachloride
243.Sodium methylate 267.Tdchlorophenol
244.Sodium nitrite 268,Triethanolamine dodecylbenzenesulfonate
269.Triethylamine
270.Trimethylamine
2F-14

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
None Brenntag Charlotte OMB No.2040-0004
Form U.S Environmental Protection Agency
2F 1W. Application for NPDES Permit to Discharge Wastewater
NPDES STORMWATER DISCHARGES ASSOCIATED WITH INDUSTRIAL ACTIVITY
• i
1.1 Provide information on each of the facili 's outfalls in the table below
Outfall Receiving Water Name Latitude Longitude
Number
001 Unamed Trib of Steele 35' 7' 33.66' N -80° 57' 28.5JJ' W
c
0
002 Unamed Trib of Steele 35` 7' 33.1j' N -80' 57' 33.99" W
0
003 Unamed Trib of Steele 35° 7' 32.86 N -80' 57' 37.01d' W
Q 004 Unamed Trib of Steele 35° 7' 32.6d' N -80' 57' 39.16' W
'• 1
2.1 Are you presently required by any federal,state,or local authority to meet an implementation schedule for constructing,
upgrading,or operating wastewater treatment equipment or practices or any other environmental programs that could
affect the discharges described in this application?
❑ Yes ❑ No 4 SKIP to Section 3.
Z2 Briefly identify each applicable project in the table below.
Brief Identification and Affected Outfalls
Description of Project (listoutfall numbers) Source(s)of Discharge Final Compliance Dates
Required Projected
U)
c
m
E
'a
n.
E
2.3 Have you attached sheets describing any additional water pollution control programs(or other environmental projects
that may affect your discharges)that you now have underway or planned?(Optional Item)
❑ Yes ❑ No
EPA Form 3510-2F(Revised 3-19) Page 1

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
None Brenntag Charlotte OMB No.2040-0004
• ti' � 1
a� 3.1 Have you attached a site drainage map containing all required information to this application?(See instructions for
r' _ C specific guidance.)
�n •L �
o ® Yes ❑ No
SECTIONPOLLUTANT SOURCES
4.1 Provide information on the facility's pollutant sources in the table below.
Outfall Impervious Surface Area Total Surface Area Drained
Number (within a mile radius of the facility) (within a mile radius of the facility)
specify units specify units
001 80 % 80,800 sq ft
specify units specify units
002 80 % 73,600 sf ft
specify units specify units
003 90 % 74,300 sq ft
specify units specify units
004 70 % 56,400 sq ft
specify units specify units
specify units specify units
4,2 Provide a narrative description of the facility's significant material in the space below.(See instructions for content
requirements.)
All high risk storage or material transfer areas have drainage controlled by closed drainage valves. These are opened
only after inspection and in some instances pH testing. Any storm-water outside of pH limits will be transfered to the
0 on-site treatment plant for eventual discharge to the POTW.
A diked tank farm stores liquid chemicals. The Tank farm is valved closed and precipitation is discharged only after
inspection and testing for pH. Tank farm chemicals are not exposed to precipitation. Loading Dock Drainage areas are
a valved closed and only opened after inspection. Additional non-diked outdoor storage of IBCs drain into a valved
retention pond only opened after inspection and pH testing.
4.3 Provide the location and a description of existing structural and non-structural control measures to reduce pollutants in
stormwater runoff. (See instructions forspecificguidance.)
Stormwater Treatment
Codes
Outfall from
Number Control Measures and Treatment Exhibit
2F—i
list
001 Drainage from Truck Scale is valved closed and only opened after inspection
002 Truck Loading Docks are valved closed and only opened after inspection
003 Tank Farm is valved closed and only opened after inspection and pH testing. Outfall is also v 2-K
004 Retention Pond is valved closed and only opened after inspection and pH testing. 2-K
EPA Form 3510-2F(Revised 3-19) Page 2

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03105119
None Brenntai3 Charlotte OMB No.2040.0004
SECTION !N STORMWATER L I
5.1 1 certify under penalty of law that the outfall(s) covered by this application have been tested or evaluated for the
presence of non-stormwater discharges. Moreover, 1 certify that the outfalls identified as having non-stormwater
discharges are described in either an accompanying NPDES Form 2C, 2D, or 2E application.
Name(print o type first and last name) Official title
Sign Date signed
u !
a> Provide the testing information requested in the table below.
Outfall Onsite Drainage Points
An Number Description of Testing Method Used Date(s)of Testing Directly Observed
During Test
m
r
m
001 Visual Inspection during dry weather 05/25/2022 001
0
c 002 Visual Inspection during dry weather 05/25/2022 002
0
z
003 Visual Inspection during dry weather 05/22/2022 003
004 Visual Inspection during dry weather 05/22/2022 004
SECTIONOR 1 . L
6.1 Describe any significant leaks or spills of toxic or hazardous pollutants in the last three years.
None that left containment areas.a
`o
N
Y
!E
J
C
19
C7
C
O]
V1
IECTI
• 7.DISCHARGE •' • I CFR 1121�6(c)(11)(i)(E))
See the instructions to determine the pollutants and parameters you are required to monitor and,in turn,the tables you must
o com fete.Not all applicants need to complete each table.
ca 7.1 Is this a new source or new discharge?
o ❑ Yes-* See instructions regarding submission of ❑ No 4 See instructions regarding submission of
estimated data. actual data.
Tables A,D,C,and D
y 7.2 Have you completed Table A for each outfali?
a ✓❑ Yes ❑ No
EPA Form 3510.2F(Revised 3-19) Page 3

EPA Identification Number NPDES Permit Number Facility Name Form Approved 03/05119
None Brenntag Charlotte OMB No.2040-0004
7.3 Is the facility subject to an effluent limitation guideline(ELG)or effluent limitations in an NPDES permit for its process
wastewater?
❑ Yes ✓❑ No 4 SKIP to Item 7.5.
7.4 Have you completed Table B by providing quantitative data for those pollutants that are(1)limited either directly or
indirectly in an ELG and/or(2)subject to effluent limitations in an NPDES permit for the facility's process wastewater?
❑ Yes ❑ No
7.5 Do you know or have reason to believe any pollutants in Exhibit 2F-2 are present in the discharge?
❑ Yes ❑ No 4 SKIP to Item 7.7.
7.6 Have you listed all pollutants in Exhibit 2F-2 that you know or have reason to believe are present in the discharge and
provided quantitative data or an explanation for those pollutants in Table C?
❑ Yes ❑ No
7.7 Do you qualify for a small business exemption under the criteria specified in the Instructions?
❑ Yes 4SKIP to Item 7.18. ✓❑ No
7.8 Do you know or have reason to believe any pollutants in Exhibit 217-3 are present in the discharge?
❑ Yes ❑✓ No+SKIP to Item 7.10.
-� 7.9 Have you listed all pollutants in Exhibit 2F-3 that you know or have reason to believe are present in the discharge in
Table C?
❑ Yes ❑ No
0 7.10 Do you expect any of the pollutants in Exhibit 217-3 to be discharged in concentrations of 10 ppb or greater?
j_ ❑ Yes No 4 SKIP to Item 7.12.
0
5 7.11 Have you provided quantitative data in Table C for those pollutants in Exhibit 2F-3 that you expect to be discharged in
L° concentrations of 10 ppb or greater?
w ❑ Yes ❑ No
7.12 Do you expect acrolein,acrylonitrile,2,4-dinitrophenol,or 2-methyl-4,6-dinitrophenol to be discharged in concentrations
of 100 ppb or greater?
❑ Yes ❑✓ No 4 SKIP to Item 7.14.
7.13 Have you provided quantitative data in Table C for the pollutants identified in Item 7.12 that you expect to be
discharged in concentrations of 100 ppb or greater?
❑ Yes ❑ No
7.14 Have you provided quantitative data or an explanation in Table C for pollutants you expect to be present in the
discharge at concentrations less than 10 ppb(or less than 100 ppb for the pollutants identified in Item 7.12)?
❑ Yes 0 No
7.15 Do you know or have reason to believe any pollutants in Exhibit 2F4 are present in the discharge?
❑ Yes 0 No 4 SKIP to Item 7.17.
7.16 Have you listed pollutants in Exhibit 2F4 that you know or believe to be present in the discharge and provided an
explanation in Table C?
❑ Yes ❑ No
7.17 Have you provided information for the storm event(s)sampled in Table D?
❑✓ Yes ❑ No
EPA Form 3510-2F(Revised 3-19) Page 4

EPA Identification Number NPOES Permit Number Fadlo Name Form Approved 03105/19
None Brenntag Charlotte OMB No.2040.0004
M Used or Manufactured Toxics
7.18 Is any pollutant listed on Exhibits 2F-2 through 2F-4 a substance or a component of a substance used or
manufactured as an intermediate or final product or byproduct?
0
r' ❑ Yes ❑✓ No 4 SKIP to Section 8.
0
E 7.19 List the pollutants below,including TCDD if applicable.
E
i. 4, 7.
d
2, 5. 8.
s
u
3. 6. 9.
SECTION 8.BIOLOGICAL TOXICITY TESTING DATA(40 CFR 122.21(g)(11 1))
8.1 Do you have any knowledge or reason to believe that any biological test for acute or chronic toxicity has been made on
any of your discharges or on a receiving water in relation to your discharge within the last three years?
ca
❑ Yes 0 No 4 SKIP to Section 9.
w.
8.2 Identify the tests and their purposes below.
Z Test(s) Purpose of Test(s) Submitted to NPDES Date Submitted
x Permitting Authori 7
0
❑ Yes ❑ No
�a
V
a
`n ❑ Yes ❑ NO
a�
❑ Yes ❑ No
SECTION • •- • i
9.1 Were any of the analyses reported in Section 7(on Tables A through C)performed by a contract laboratory or
consulting firm?
✓❑ Yes ❑ No 4 SKIP to Section 10.
9.2 Provide information for each contract laboratory or consulting firm below.
Laboratory Number I Laboratory Number 2 Laboratory Number 3
Name of laboratory/firm
Pace Charlotte Pace Asheville
c
0
A
H Laboratory address
y 9800 Kincey Ave Suite 100 225 Riverside Drive
y' Huntersville,NC 28078 Asheville NC 28804
ro
c
a
o Phone number
Q [phone] [phone]
Pollutant(s)analyzed TSS,BOD5,Total N,TKN, Oil and Grease
Nitrogen NO2+NO3,
Phoisphorus,COD
EPA Form 3510-2F(Revised 3-19) Page 5

EPA ldentification Number NPDES Permit Number Facility Name Form Approved 03/05119
None Brenntag Charlotte OMB No.2040-0004
S�ECTION 10.CHECKLIST AND CERTIFICATION1 + .
10.1 In Column 1 below,mark the sections of Form 2F that you have completed and are submitting with your application.For
each section,specify in Column 2 any attachments that you are enclosing to alert the permitting authority.Note that not
all applicants are required to complete all sections or provide attachments.
Column 1 Column 2
0 Section 1 ❑ wl attachments(e.g.,responses for additional outfalIs)
• Section 2 ❑ wl attachments
0 Section 3 ❑ wl site drainage map
Section 4 ❑ wl attachments
Section 5 ❑ wl attachments
✓❑ Section 6 ❑ wl attachments
v Section 7 0 Table A ❑ wl small business exemption request
N
`o ElTable B ✓❑ w/analytical results as an attachment
❑ Table C El Table D
a
❑ Section 8 ❑ w/attachments
c
❑ Section 9 ❑ wlattachments(e.g.,responses for additional contact laboratories or firms)
❑ Section 10 ❑
cs 10.2
Certification Statement
1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system or those persons directly responsible
for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and
complete. I am aware that there are significant penalties for submitting false information, including the possibility of tine
and imprisonment for knowing violations.
Name(print or
U C.`]e first and last name) Official title
Cr �i'F�C �� fticxf 7/��E /ZfC r7cr^
Si nature / Date signed
a 12
EPA Form 3510-2F(Revised 3-19) Page 6

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03105119
None Brenntag Charlotte 001 OMB No.2040-0004
TABLE A.CONVENTIONAL AND NON CONVENTIONALr
You must provile the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (speciy units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new soumelnew
During First Flow-Weightedsit During First Flo Composite
Events Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease ND 1
2. Biochemical oxygen demand(BODs) ND 1
3, Chemical oxygen demand(COD) 42.3 mg/L 1
4. Total suspended solids(TSS) 524 mg/L 1
5. Total phosphorus 0.17 mg/L 1
6. Total Kjeldahl nitrogen(TKN) 2.0 mg/L 1
7. Total nitrogen(as N) 2.1 mg/L 1
pH(minimum)
8,
rpH(maximum)
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 7

This page intentionally left blank.

EPA Identification Number NPDES Permit Number Fadiity Name Ouffall Number Form Approved 03Y05119
None Brenntag Charlotte 001 OMB No.2040-0004
• • 1 • • • •• = F
List each pollutant that is limited in an effluent limitation guideline(ELG)that the facility is subject to or any pollutant listed in the facility's NPDES permit for its process wastewater(if the
facility is operating under an existing NPDES permit).Complete one table for each outfall.See the instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
(spec; units) (speci units) Number of Storm Information
Pollutant and CAS Number(if available) Grab Sample Taken hted Events Samp
led pted Grab Sample Taken Flow-Weighted {new sourcehrew
During First During First dischargers only,use
30 Minutes Composite 30 Minutes Composite codes in instructions)
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 9

This page intentionally left blank.

EPA Identification Number NPDES Pennfl Number Facility Name OuM Number Form Approved 03f05I19 '
None Brenntag Charlotte 001 OMB No.20404M
TABLE C.TOXiC POLLUTANTS,CERTAIN HAZARDOUS SUBSTANCES,AND ASBESTOS(40 CFR 122.26(c)(1)(i)(E)(4)and 40 CFR 122.21(g)(7)(vi)(B)and(vii))'
List each pollutant shown in Exhibits 2F-2,217-3,and 2F-4 that you know or have reason to believe is present.Complete one table for each outfa►I.See the instructions fior additional
details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
units units Number of Storm Information
Pollutant and CAS Number(d ) Grab Sample Taken Grab Sample Taken (new sourcetnew
During First Flo Composite
Flow-Weighted During First Flo Composite
Events Sampled dischargers onty,use
30 Minutes Composite 30 Minutes Composite codes in instructions)
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-21'(Revised 3-19) Page 11

lank.
TIusPage intentionally left b

EPA Identification Number NPOES Permit Number Facility name Outfall Number Form Approved 0105f19
None Brenntag Charlotte 001 OMB No.2040-0004
TABLE D.STORM EVENT INFORMATION(40 CFR 122.26(c)(1)(i)(E)(6))
Provide data for the storm event(s)that resulted in the maximum daily discharges for the How-weighted composite sample.
Number of Flours Between
Total Rainfall During Maximum Flow Rate
Duration of Storm Event (in inches) Beginning of Storm Measured and {in gpm or specify units) Total Flow from Rain Event
Date of Storm Event (in hours) Storm Event End of Previous Measurable Rain During Rain Event (in gallons or specify units)
Event
10/06/2022
2 hrs 0.1 inch >72 hrs MGD 0.262 all 4 outfails Unknown
Provide a description of the method of flow measurement or estimate.
Depth of Flow in Circular Pipe,Pipe Slope,Pipe Diameter,Manning Equation. All outfalis were flowing half full and are 6"smooth PVC pipe on 1%slope. 0.262 MGD x 4 oufalis=1.05
MGD
EPA Form 3510-2F(Revised 3-19) Page 13

EPA Identification Number NPOES Permit Number Facility Name Outtall Number Form Approved 0310511E
Brenntag Charlotte 003 OM8 No.204U044
COTABLE A. •NAL AND NON CONVENTIONALI
You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details and re uirements.
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new source/new
During First Flo Composite
ed During First Flow-Weighted Composite
Invents Sampled dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease ND 1
2. Biochemical oxygen demand(BODs) 13.9 mg/L 1
3. Chemical oxygen demand(COD) 117 mg/L 1
4. Total suspended solids(TSS) 30.2 mg/L 1
5. Total phosphorus 0.35 mg/L 1
6. Total K(eldahl nitrogen(TKN) 84.1 mg/L 1
7. Total nitrogen(as N) 114 mg/L 1
pH(minimum)
8.
rpH(ma;7imum)
Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or O.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3.19) Page 7

EPA Iden5 icabon Number NPOES Perm4 Number Facility Name Outfall Number Form Approved 03105119
Brenntag Charlotte 004 OMB No.2040-0004
TABLE A.CONVENTIONAL AND NON • •
You must provide the results of at least one anal sis for every pollutant in this table.Complete one table for each outfall.See instructions for additional details and requirements.
Maximum Daily Discharge Average Daily Discharge Source of
fspeafyunits) (specify units) Number of Storm Information
Pollutant or Parameter Grab Sample Taken Grab Sample Taken (new sourcefnew
During First Flo Composite During During First Flo Composite
Events Sampled dischargers only,,use
30 Minutes DOmp°S 30 Minutes Composite odes in instructions)
1. Oil and grease ND 1
2. Biochemical oxygen demand(BODs) 43.6 mg/L i
3. Chemical oxygen demand(COD) 124 mg/L 1
4. Total suspended solids(TSS) 97.4 mg/L 1
5. Total phosphorus 0.81 mg/L 1
6. Total Kjeldahl nitrogen(TKN) 91.5 mg/L 1
7. Total nitrogen(as N) 119 mg/L 1
pH(minimum)
8.
pH(maximum)
3 Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510-2F(Revised 3-19) Page 7

EPA Identification Number NPDES Permit Number Facility Name Outfall Number Form Approved 03105/19
Brenntag Charlotte 002 OMB No.2040.OW
TABLE • 1 NON CONVENTIONALi
You must provige the results of at least one anal sis for eve pollutant in this table.Complete one table for each outfall,See instructions for additional details and requirements,
Maximum Daily Discharge Average Daily Discharge Source of
(specify units) (specify units) (dumber of Storm Information
Pollutant or Parameter Grab Sample Taken FlWihtd Grab Sample Taken Flow-Weighted Events Sampled (new source/new
During First ow- ege During First p dischargers only;use
30 Minutes Composite 30 Minutes Composite codes in instructions)
1. Oil and grease ND 1
2. Biochemical oxygen demand(BODs) ND x
3. Chemical oxygen demand(COD) 74 mg/L 1
4. Total suspended solids(TSS) 700 mg/L
5. Total phosphorus 0.16 mg/L 1
6. Total Kjeldahl nitrogen(TKN) 3.2 mg/L 1
7. Total nitrogen(as N) 3.2 mg/L
pH(minimum)
8.
pH(maximum)
I Sampling shall be conducted according to sufficiently sensitive test procedures(i.e.,methods)approved under 40 CFR 136 for the analysis of pollutants or pollutant parameters or
required under 40 CFR chapter I,subchapter N or 0.See instructions and 40 CFR 122.21(e)(3).
EPA Form 3510.2F(Revised 3-19) Page 7

Young, Brianna A
From: David Grenoble/Mid-South/Brenntag <[e-mail]>
Sent: Monday, May 9, 2022 10:10 AM
To: Young, Brianna A; Kay, Lily C; Chandler, Jeffrey A
Cc: Dennis Martin/Mid-South/Brenntag
Subject: RE: [External] Brenntag Charlotte
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
We are finally making headway! We are now working with Linebach Funkhouser Inc. to get permitted and a SWPPP in
place. We have signed off on their proposal and they are drafting a Notice of Intent to use a general permit that we
believe is applicable to our operations at Brenntag Mid-South, Inc.—Charlotte (NCG080000).They will be conducting
further assessment of the facility in the near future to gather a layout and identify our outfalls, etc. Once this is
complete,the NOI will be drafted and contain all the relevant information including a diagram map showing the outfalls
and discharge points.This will be followed shortly after with drafting and implementation of the SWPPP.
I will keep everyone updated as information becomes available.
Thank you all,
- David
David M.Grenoble
M:270.869.5806
From:Young, Brianna A<[e-mail]>
Sent:Thursday, May 5, 2022 11:38 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] Brenntag Charlotte
This Message Is From an External Sender
This message came from outside your organization.
Thank you for this update. Please continue to let us know as you get more information.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
1

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Tuesday, May 3, 2022 10:49 AM
To:Young, Brianna A<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,Jeffrey A
<leffrey.chandler@ncdenr.�ov>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: [External] Brenntag Charlotte
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning all,
I want to keep communication open and let everyone know what the current status is. As of right now, we are looking in
a new direction for consultants. We have reached out to a firm that some of our other regions use (I believe they are
called Funkhouser or some iteration thereof) and have given them a description of what is needed including drafting and
submittal of the individual permit application and development and implementation of a SWPPP from scratch; among
other things. We currently anticipate them taking on the project and they have advised us that they will have a work
agreement drawn up this week.
I will work diligently to get concrete timelines from them on when we should expect each step to occur and we have
explained and verified that they understand the urgency behind this.
I hope to be able to share the anticipated timeline with this group this week or early next week and that we can all begin
to see tangible progress.
Thank you all again for your help and support in this matter.
Be safe,
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
2

D EIY T
From:Young, Brianna A<[e-mail]>
Sent: Monday,April 18, 2022 10:43 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
David,
I should be the primary point of contact for the questions related to the permit application.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:34 AM
To: Kay, Lily C<[e-mail]>; Chandler,Jeffrey A<[e-mail]>; Young, Brianna A
<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
3

I understand! Arcadis and I have been in contact and they have reached out to some of the facilities outside of my
region to see how their program/permit is written. Would it be better to work directly with Brianna (now copied)? I am
having some turmoil about how long Arcadis is taking to get us what we need.
Thanks!
- David
David M.Grenoble
M:270.869.5806
From: Kay, Lily C<[e-mail]>
Sent: Monday,April 18, 2022 10:31 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Chandler,Jeffrey A
<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
Brianna is the permit writer and should be able to help, but if you need something from me or Jeffrey,just let us
know. We were about to issue an NOV because we had not heard anything. With all of the different liquids you have, it
may take us a minute to evaluate which permit conditions are relevant to this facility.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:26 AM
To: Kay, Lily C<[e-mail]>; Chandler,Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Not a problem at all Lily.
Given that this is new to us,we are hitting a few bumps in the road (hence why we are working with Arcadis). Is there
anyone with the State or with Mecklenburg County that we can reach out to in order to seek guidance on the process in
the event we need any further? I feel like this shouldn't be a difficult or drawn out process but without much experience
in the arena, it is proving to be.
Thanks again!
- David
David M.Grenoble
M:270.869.5806
From: Kay, Lily C<[e-mail]>
Sent: Monday,April 18, 2022 10:21 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Young, Brianna A<[e-mail]>;
4

Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>; Chandler,Jeffrey A<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Khan,
Zahid <[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
David,
Please keep Jeffrey Chandler and I informed on the status of this application.
Thanks,
Lily
Z4 lacy
Environmental Specialist
Land Quality Division
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Physical and Mailing Address: 610 E. Center Ave. Suite 301
Mooresville, NC 28115
Nothtng Compares.—,-,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:12 AM
To:Young, Brianna A<[e-mail]>; Dennis Martin/Mid-South/Brenntag<[e-mail]>;
Bradley, Lauren M. <Lauren.Brad [e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Kay,
Lily C<[e-mail]>; Khan,Zahid <[e-mail]>; Bryon Mason/Mid-South/Brenntag
<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
5

CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning all,
I just wanted to provide an update from Brenntag on the progress of the permit application. We are currently working
with Arcadis and their engineers to get the individual permit set up as well as likely draft and implement a SWPPP for
our Charlotte facility.
I do not believe anyone has requested status updates; however, if there is anyone on this email chain or otherwise that
would like to keep up-to-date of where we are in the process please let me know and I will be happy to send out status
reports as applicable.
Again, thank you all for your assistance in this matter.
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
BRENNTAGM
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 17, 2022 8:58 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Dennis Martin/Mid-South/Brenntag
<[e-mail]>; Bradley, Lauren M. <[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Kay,
Lily C<[e-mail]>; Khan,Zahid <[e-mail]>
Subject: [EXTERNAL]RE: [External] RE: Permit Application Contact Information
Good afternoon,
I apologize for the delay in addressing this question. Per representatives from Brenntag Charlotte,the SIC code for the
site is 5169. Although NPDES regulations do not automatically permit coverage for facilities with this SIC code, 40 CFR
122.26 allows for NC DEQ's authority to designate discharges and require permits for sites that have the potential to
impact surface water quality because of pollutant contribution.After consultation with both DEQ Mooresville Regional
Office and Charlotte-Mecklenburg Stormwater Services staff, DEQ is requiring that Brenntag Charlotte apply for
stormwater permit coverage. Please review our Industrial Permitting website here for both general and individual
permits to decide which permit coverage best fits your facility/site operations.
Thank you,
6

Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your
patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:48 AM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
It seems like this question keeps circling around and we have yet to be able to collectively bring it to a close.As we have
previously communicated, we will be more than happy to apply for/obtain a storm water permit if indicated. As of our
most recent conversations with Mecklenburg County representatives and Mrs. Young, it is still unclear if this
requirement is applicable to our Charlotte facility or not. We obviously want to do the right thing and maintain full
compliance and cooperation. Can anyone advise definitively if we need a permit and, if so,what the process is to apply
for and obtain one?
Thank you all,
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
7

DEIYTM
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:26 AM
To: Bradley, Lauren M. <[e-mail]>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: RE: Permit Application Contact Information
Including our previous correspondence. Please let me know what other information is needed.
Dennis Martin
Operations Manager
V F1�NTA M
Brenntag Mid-South -Charlotte
11750 Fruehauf Dr
Charlotte, NC 28273
980-500-3857(desk)
270-577-4893(cell)
Email:dmartin(@brenntaq.com
www.brenntag.com/Mid-South
CanneCtfn-gChiamTStrry
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Wednesday, February 23, 2022 2:56 PM
To: Bradley, Lauren M. <Lauren.Bradley@ mecklen burgcountync.gov>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<Richard.Farmer@ mecklenburecountync.gov>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: Re: Permit Application Contact Information
Including David Grenoble, our SRQ.
Get Outlook for iOS
From: Bradley, Lauren M. <Lauren.Brad ley@ mecklenburgcountync.gov>
Sent: Wednesday, February 23, 2022 2:49:38 PM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [EXTERNAL]Permit Application Contact Information
8

Good evening Dennis,
Please contact Brianna Young, Industrial Individual Permits Coordinator, with NC DEQ/ Division of Energy,
Mineral, and Land Resources (DEMLR) to apply for your permit. She is CC'ed on this email.
[e-mail]
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Thank you for your cooperation during todays sampling event. If you have any questions please feel free to
reach out.
Best,
Lauren Bradley
Environmental Specialist 11
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
WATER
SWAM gam�
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
This communication and any documents accompanying this email transmission may be subject to the attorney-client
privilege or be considered attorney work product.
If you believe that you received this email in error,please do not read, copy, use or disclose this communication
to others; also please notify the sender by replying to this message, and then delete it from your system. Please
verify that you will delete the e-mail in your reply. Thank you.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any
attachments, is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended
recipient, any use, review, dissemination, or copying of any such communication by you is strictly prohibited. If
you believe you have received this or any other electronic communication in error,please do not read, copy, use
or disclose it to others; also please notify the sender by replying to the communication, and then delete it and all
accompanying files from your system. Please verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.
9

Young, Brianna A
From: David Grenoble/Mid-South/Brenntag <[e-mail]>
Sent: Thursday, May 5, 2022 10:43 AM
To: Young, Brianna A; Kay, Lily C; Chandler, Jeffrey A
Cc: Dennis Martin/Mid-South/Brenntag
Subject: RE: [External] RE: Permit Application Contact Information
Attachments: Proposal for SWPPP, SPCC, Stormwater Permit Application (5-3-22).pdf
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
Arcadis finally provided me with a scope of work proposal (this was requested on March 17t" after Brianna confirmed
that we needed to proceed). We are still awaiting information from our secondary consultant as well.
I wanted to provide you all with this information in hopes that it shows a good faith effort on our part to get this permit
and program in place for our Charlotte facility. Depending on what our secondary consultant option presents, we will
proceed with one or the other. I have also forwarded this proposal up my chain of command to make sure everyone is
on the same page and is aware of the forthcoming expenditure for the project.
Thank you all again,
- David
David M.Grenoble
M:270.869.5806
From:Young, Brianna A<[e-mail]>
Sent: Monday,April 18, 2022 10:43 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Kay, Lily C<[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
David,
I should be the primary point of contact for the questions related to the permit application.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
1

[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
Please check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.We
appreciate your patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:34 AM
To: Kay, Lily C<[e-mail]>; Chandler,Jeffrey A<[e-mail]>; Young, Brianna A
<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
I understand! Arcadis and I have been in contact and they have reached out to some of the facilities outside of my
region to see how their program/permit is written. Would it be better to work directly with Brianna (now copied)? I am
having some turmoil about how long Arcadis is taking to get us what we need.
Thanks!
- David
David M.Grenoble
M:270.869.5806
From: Kay, Lily C<[e-mail]>
Sent: Monday,April 18, 2022 10:31 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Chandler,Jeffrey A
<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
Brianna is the permit writer and should be able to help, but if you need something from me or Jeffrey,just let us
know. We were about to issue an NOV because we had not heard anything. With all of the different liquids you have, it
may take us a minute to evaluate which permit conditions are relevant to this facility.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:26 AM
2

To: Kay, Lily C<Ii [e-mail]>; Chandler,Jeffrey A<[e-mail]>
Cc: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Not a problem at all Lily.
Given that this is new to us,we are hitting a few bumps in the road (hence why we are working with Arcadis). Is there
anyone with the State or with Mecklenburg County that we can reach out to in order to seek guidance on the process in
the event we need any further? I feel like this shouldn't be a difficult or drawn out process but without much experience
in the arena, it is proving to be.
Thanks again!
- David
David M.Grenoble
M:270.869.5806
From: Kay, Lily C<[e-mail]>
Sent: Monday,April 18, 2022 10:21 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Young, Brianna A<[e-mail]>;
Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>; Chandler,Jeffrey A<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Khan,
Zahid <[e-mail]>; Bryon Mason/Mid-South/Brenntag<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
This Message Is From an External Sender
This message came from outside your organization.
David,
Please keep Jeffrey Chandler and I informed on the status of this application.
Thanks,
Lily
Z4 5Z�"
Environmental Specialist
Land Quality Division
Division of Energy, Mineral, and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Fax: [phone]
Email: [e-mail]
3

Physical and Mailing Address: 610 E. Center Ave. Suite 301
Mooresville, NC 28115
-"--^ lathing Compares ..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent: Monday,April 18, 2022 10:12 AM
To:Young, Brianna A<[e-mail]>; Dennis Martin/Mid-South/Brenntag<[e-mail]>;
Bradley, Lauren M. <Lauren.Brad [e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Kay,
Lily C<[e-mail]>; Khan,Zahid <[e-mail]>; Bryon Mason/Mid-South/Brenntag
<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning all,
I just wanted to provide an update from Brenntag on the progress of the permit application. We are currently working
with Arcadis and their engineers to get the individual permit set up as well as likely draft and implement a SWPPP for
our Charlotte facility.
I do not believe anyone has requested status updates; however, if there is anyone on this email chain or otherwise that
would like to keep up-to-date of where we are in the process please let me know and I will be happy to send out status
reports as applicable.
Again, thank you all for your assistance in this matter.
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
4

B ElY T
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 17, 2022 8:58 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Dennis Martin/Mid-South/Brenntag
<[e-mail]>; Bradley, Lauren M. <[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Kay,
Lily C<[e-mail]>; Khan,Zahid <[e-mail]>
Subject: [EXTERNAL]RE: [External] RE: Permit Application Contact Information
Good afternoon,
I apologize for the delay in addressing this question. Per representatives from Brenntag Charlotte,the SIC code for the
site is 5169. Although NPDES regulations do not automatically permit coverage for facilities with this SIC code, 40 CFR
122.26 allows for NC DEQ's authority to designate discharges and require permits for sites that have the potential to
impact surface water quality because of pollutant contribution. After consultation with both DEQ Mooresville Regional
Office and Charlotte-Mecklenburg Stormwater Services staff, DEQ is requiring that Brenntag Charlotte apply for
stormwater permit coverage. Please review our Industrial Permitting website here for both general and individual
permits to decide which permit coverage best fits your facility/site operations.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your
patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:48 AM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<Richard.Farmer@ mecklenburgcountync.gov>;
5

Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
It seems like this question keeps circling around and we have yet to be able to collectively bring it to a close.As we have
previously communicated, we will be more than happy to apply for/obtain a storm water permit if indicated. As of our
most recent conversations with Mecklenburg County representatives and Mrs. Young, it is still unclear if this
requirement is applicable to our Charlotte facility or not. We obviously want to do the right thing and maintain full
compliance and cooperation. Can anyone advise definitively if we need a permit and, if so,what the process is to apply
for and obtain one?
Thank you all,
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
BRENNTAGAS
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:26 AM
To: Bradley, Lauren M. <[e-mail]>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: RE: Permit Application Contact Information
Including our previous correspondence. Please let me know what other information is needed.
Dennis Martin
Operations Manager
V RE IY NT "
Brenntag Mid-South -Charlotte
11750 Fruehauf Dr
Charlotte, NC 28273
980-500-3857(desk)
6

270-577-4893(cell)
Email:dmartin(ftrenntao.com
www.brenntag.com/Mid-South
Co n ne ct rngl Ch e m f star
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent: Wednesday, February 23, 2022 2:56 PM
To: Bradley, Lauren M. <[e-mail]>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: Re: Permit Application Contact Information
Including David Grenoble, our SRQ.
Get Outlook for iOS
From: Bradley, Lauren M. <Lauren.Brad [e-mail]>
Sent: Wednesday, February 23, 2022 2:49:38 PM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<Richard.Farmer@ mecklenbu rgcountync.gov>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<Michael.Schley@ mecklenburgcountync.gov>
Subject: [EXTERNAL]Permit Application Contact Information
Good evening Dennis,
Please contact Brianna Young, Industrial Individual Permits Coordinator, with NC DEQ/ Division of Energy,
Mineral, and Land Resources (DEMLR) to apply for your permit. She is CC'ed on this email.
[e-mail]
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Thank you for your cooperation during todays sampling event. If you have any questions please feel free to
reach out.
Best,
Lauren Bradley
Environmental Specialist II
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
WATER
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
7

This communication and any documents accompanying this email transmission may be subject to the attorney-client
privilege or be considered attorney work product.
If you believe that you received this email in error,please do not read, copy, use or disclose this communication
to others; also please notify the sender by replying to this message, and then delete it from your system. Please
verify that you will delete the e-mail in your reply. Thank you.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any
attachments, is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended
recipient, any use, review, dissemination, or copying of any such communication by you is strictly prohibited. If
you believe you have received this or any other electronic communication in error,please do not read, copy, use
or disclose it to others; also please notify the sender by replying to the communication, and then delete it and all
accompanying files from your system. Please verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.
8

Young, Brianna A
From: Bradley, Lauren G. <Lauren.Bradley@mecklen burg countync.gov>
Sent: Tuesday, March 22, 2022 12:24 PM
To: Morman, Alaina; Kay, Lily C
Cc: Santiago, Matthew J.; Farmer, Richard L; Young, Brianna A; Miller, Craig
Subject: FW: [External] RE: Permit Application Contact Information
Attachments: Brenntag.docx; Brenntag Mid-South Inspection Report.pdf; Brentagg Pond
SummaryTable of Results Form.docx; Brentagg Outfall SummaryTable of Results
Form.docx
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good afternoon Alaina,
Your name was given to me by Brianna Young, please see correspondence below. There is a chemical
repackaging facility located here in Charlotte, Brenntag Mid-South, that has had numerous discharges and
spills over the last several years. Please see the attached brief history of their incidents. They have been told a
number of times in the past to apply for a permit, which they have not yet done. Our concern is that they are
discharging unpermitted and contaminated stormwater from this location. Please see the attached results
from analytical sampling we conducted at this facility on 2/23/22. 1 have also attached the report from our
10/19/21 industrial inspection.
Are there any enforcement procedures for facilities that are discharging unpermitted and contaminated
stormwater? We often inspect permitted facilities which are not operating within their permit requirements
(i.e. no SWPPP and/or no monitoring) and we inspect facilities which probably need a permit but don't have
one, but this facility's housekeeping practices and stormwater discharge are very concerning.
Any help or assistance you can provide in this matter would be greatly appreciated.
Thank you,
Lauren Bradley
Environmental Specialist 11
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 Lauren.Bradley@MeckNC.g_ov I StormWater.CharMeck.org
1,4STORM
SffVhM gam� a
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, March 22, 2022 10:52 AM
To: Bradley, Lauren G. <[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
1

<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Lauren,
Thank you for this additional information. In regards to which permit they need to apply for: I used standard language in
my response—in the Central Office,we tell them they need to figure out which permit they think fits best and apply for
that one. If they think they qualify for a general permit,they are welcome to try applying for one. If they choose to apply
for a general permit and that gets denied,they lose the application fee and have to apply for an individual permit. Some
applicants choose to apply for the quicker review and less expense of a general permit and understand they may lose
the application fee (it's only$100 versus$860 for individual application).
Your question about an NOV is outside my scope of knowledge. That is an enforcement question that should be directed
back to Lily, or here in the Central Office Alaina Morman would be the contact for that. I only handle permits, not
compliance.
If they don't apply for a permit,that is something we would have to have internal discussion on what to do next.
Please let me know if you have any other questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your
patience as we continue to serve the public during this challenging time.
From: Bradley, Lauren G. <Lauren.Brad [e-mail]>
Sent:Tuesday, March 22, 2022 10:40 AM
To:Young, Brianna A<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
2

CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning Brianna,
I apologize for the delay in response to your last email. When I conducted an inspection of this facility on
10/19/2021, Lily Kay accompanied us and she informed the facility manager that an individual permit would
be required as their facility would not fall under a general permit; has that changed? Lily had also mentioned
to the facility manager during that inspection that if they don't apply for a permit within 30 days they would
be issued an NOV, is that still the case? If they don't apply for a permit, what would be done? Especially since
they've been told a number of times before that a permit is necessary.
Also, I have attached the results from our sampling event at this facility on 2/23/22. We took samples from
two locations at the facility: the pond that's currently being used as a secondary containment for the bulk
storage of hazardous materials and near an outfall what is supposed to hold stormwater in a vault but does
not function properly so it sheet flows off of the property. This facility's stormwater discharge is very
concerning.
Please let me know if you have any questions or if there is anything we can assist with. Also, if you could
please keep me posted on the progress in issuing their permit, that would be greatly appreciated.
Thank you,
Lauren Bradley
Environmental Specialist 11
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
CATER
.— s. (&.
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
From:Young, Brianna A<[e-mail]>
Sent:Thursday, March 17, 2022 8:58 AM
To: David Grenoble/Mid-South/Brenntag<[e-mail]>; Dennis Martin/Mid-South/Brenntag
<[e-mail]>; Bradley, Lauren G. <[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael <[e-mail]>; Kay,
Lily C<[e-mail]>; Khan,Zahid <[e-mail]>
Subject: RE: [External] RE: Permit Application Contact Information
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Good afternoon,
I apologize for the delay in addressing this question. Per representatives from Brenntag Charlotte,the SIC code for the
site is 5169. Although NPDES regulations do not automatically permit coverage for facilities with this SIC code, 40 CFR
3

122.26 allows for NC DEQ's authority to designate discharges and require permits for sites that have the potential to
impact surface water quality because of pollutant contribution.After consultation with both DEQ Mooresville Regional
Office and Charlotte-Mecklenburg Stormwater Services staff, DEQ is requiring that Brenntag Charlotte apply for
stormwater permit coverage. Please review our Industrial Permitting website here for both general and individual
permits to decide which permit coverage best fits your facility/site operations.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your
patience as we continue to serve the public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:48 AM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good morning,
It seems like this question keeps circling around and we have yet to be able to collectively bring it to a close.As we have
previously communicated, we will be more than happy to apply for/obtain a storm water permit if indicated. As of our
most recent conversations with Mecklenburg County representatives and Mrs. Young, it is still unclear if this
requirement is applicable to our Charlotte facility or not. We obviously want to do the right thing and maintain full
compliance and cooperation. Can anyone advise definitively if we need a permit and, if so,what the process is to apply
for and obtain one?
Thank you all,
- David
David M.Grenoble
4

Regional Safety,Regulatory,and Quality Manager
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
BRENNTAGM
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:26 AM
To: Bradley, Lauren M. <[e-mail]>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: RE: Permit Application Contact Information
Including our previous correspondence. Please let me know what other information is needed.
Dennis Martin
Operations Manager
B ENNTAG M
Brenntag Mid-South -Charlotte
11750 Fruehauf Dr
Charlotte, NC 28273
980-500-3857(desk)
270-577-4893(cell)
Email:dmartin(a)brenntaa.com
www.brenntag.com/Mid-South
CorinectingChernfstr
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent: Wednesday, February 23, 2022 2:56 PM
To: Bradley, Lauren M. <Lauren.Bradley@ mecklen burgcountync.gov>; David Grenoble/Mid-South/Brenntag
<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: Re: Permit Application Contact Information
Including David Grenoble, our SRQ.
Get Outlook for iOS
From: Bradley, Lauren M. <Lauren.Brad ley@ mecklenburgcountync.gov>
Sent: Wednesday, February 23, 2022 2:49:38 PM
5

To: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L<[e-mail]>;
Santiago, Matthew J. <[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [EXTERNAL]Permit Application Contact Information
Good evening Dennis,
Please contact Brianna Young, Industrial Individual Permits Coordinator, with NC DEQ/ Division of Energy,
Mineral, and Land Resources (DEMLR) to apply for your permit. She is CC'ed on this email.
[e-mail]
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Thank you for your cooperation during todays sampling event. If you have any questions please feel free to
reach out.
Best,
Lauren Bradley
Environmental Specialist II
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
-
WATT
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
This communication and any documents accompanying this email transmission may be subject to the attorney-client
privilege or be considered attorney work product.
If you believe that you received this email in error, please do not read, copy, use or disclose this communication to
others; also please notify the sender by replying to this message, and then delete it from your system. Please verify that
you will delete the e-mail in your reply.Thank you.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any attachments,
is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended recipient, any use, review,
dissemination, or copying of any such communication by you is strictly prohibited. If you believe you have received this
or any other electronic communication in error, please do not read, copy, use or disclose it to others; also please notify
6

the sender by replying to the communication, and then delete it and all accompanying files from your system. Please
verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.

Linebach ■ Funkhouser, Inc.
ENVIRONMENTAL COMPLIANCE&CONSULTING
May 6, 2022
Bryon Mason
Brenntag Mid-South
1405 KY-136 W
Henderson, KY 42420
[e-mail]
Re: Proposal for Storm-Water Permitting Services
11750 Fruehauf Drive
Charlotte,NC 28273
Linebach Funkhouser Proposal No. 133-22
Dear Mr. Mason:
Linebach Funkhouser, Inc. (LFI) is pleased to provide Brenntag Mid-South with this proposal to
assist the referenced facility with storm-water permitting services in accordance with North
Carolina's National Pollutant Discharge Elimination System (NPDES) requirements and
development of a Storm-water Pollution Prevention Plan (SWPPP). The proposal includes
background information, our proposed scope of services, anticipated schedule and cost
information.
BACKGROUND
We understand that Brenntag Mid-South has a property at 11750 Fruehauf Drive Charlotte,NC .
The site has been directed by the North Carolina Department of Environmental Quality (DEQ) to
prepare an application for coverage under an NPDES permit and an appropriate SWPPP.
Currently, the plant does not have a NPDES permit for storm-water discharges or no exposure
certificate. The applicable requirements for a NPDES permit are summarized below. The amount
of material Brenntag Mid-South stores outside currently likely makes the facility ineligible for a
no exposure certificate.
North Carolina has 21 General Industrial Permits. Industries that are eligible for one of the
General Industrial Permits are issued a Certificate of Coverage (COC). Each facility's COC
contains the same requirements as for all other facilities covered under the same General Permit.
General permits are renewed on a five-year cycle. General Permits are generally preferable to
individual permits.
114 Fairfax Avenue 0 Louisville,KY 40207 ■ [phone] 0 linebachfimkhouser.com

Proposal for Storm-water Permitting Services May 6, 2022
Linebach Funkhouser Proposal Number 133-22
LFI believes that Brenntag Charlotte can be granted coverage under General Permit
NCG080000, Transit and Transportation. Coverage under this General Permit is applicable to:
• All owners or operators of stormwater point source discharges associated with
establishments primarily engaged in activities classified as Vehicle Maintenance Areas
(including vehicle rehabilitation, mechanical repairs, painting, fueling, lubrication, and
equipment cleaning areas), Rail Transportation [Standard Industrial Classification (SIC)
40], Local and Suburban Transit and Interurban Highway Passenger Transportation (SIC
41), Motor Freight Transportation and Warehousing (SIC 42), Postal Service (SIC 43),
and Petroleum Bulk Stations and Terminals (SIC 5171) with total petroleum storage
capacity of less than 1 million zallons;
• Stormwater point source discharges from like industrial activities deemed by The
Division of Energy, Mineral, and Land Resources (DEMLR) to be similar to the above
operations in their processes; discharges; and/or exposure of raw materials, intermediate
products, byproducts, or waste products. Other activities may include stormwater
discharges from oil water separators, secondary containment structures and petroleum
storage facilities, and/or vehicle maintenance areas at any facilities other than those
listed.
SCOPE OF SERVICES
TASK 1 - Site Evaluation and Records Review
LFI will visit the Brenntag Mid-South facility to conduct a site evaluation and review
facility records. Some of the following information has already been provided to LFI and
will be evaluated prior to our site visit. The visit will include:
• Identifying key personnel responsible for implementing Brenntag Mid-
South's SWPPP (including a responsible company official with signatory
authority);
• Inspecting the site to verify the locations, drainage patterns, and sizes of
storm-water outfall areas;
• Reviewing existing site plans (e.g., plant layout drawing, topographic
map,etc.);
• Contacting the local sewer authority for the plans of stormwater sewers
that may connect to Steele Creek. LFI will request copies of the storm
sewers and sanitary sewers that will need to be included in the
application for the permit.
• Conducting a facility-specific raw material and waste inventory;
• Identifying current storm-water management practices;
• Documenting past significant spills and leaks in potential storm-water
contact areas; and,
• Identifying non-storm-water discharges.
2

Proposal for Storm-water Permitting Services May 6, 2022
Linebach Funkhouser Proposal Number 133-22
During the site evaluation, LFI may also review Brenntag Mid-South's inventory and
material records, and supplement as necessary to produce an inventory of exposed
materials. Each inventory will identify significant materials that include, but are not
limited to:
• Raw materials;
• Fuels and oils;
• Hazardous substances designated under Section 101(14) of the
Comprehensive Environmental Response, Compensation, and Liability
Act(CERCLA);
• Chemicals the facility utilizes and is required to report pursuant to
Section 313 of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA Title III);
• Fertilizers and pesticides; and,
• Waste products that have the potential to release contaminants to the
storm-water discharges.
Site Plan
During the site evaluation, a base map for the facility will be used to illustrate locations
for the following:
• An outline of the drainage area(s) of the existing storm-water outfall(s);
• Locations of any existing structural control measures used to reduce
pollutants in storm-water runoff,
• Locations where significant materials are exposed to precipitation;
• Locations where major spills or leaks have occurred; and,
• Locations of surface water bodies, fueling stations, loading/unloading
areas, waste handling/disposal areas, liquid storage tanks, processing
areas, and storage areas.
A general site layout of the facility (if available) can be used as a base map that can be
modified for use in the SWPPP and for the completion of the NPDES application.
Identification of Non-Storm-Water Discharges
The SWPPP will include a certification indicating that storm-water outfalls have been
tested or evaluated for the presence of non-storm-water discharges. The certification will
include the identification of potential non-storm-water discharges and a description of the
results of any test and/or evaluation for the presence of non-storm-water discharges. The
certification will be performed during a dry weather period and will involve a visual
inspection of each outfall. If flow is observed in any of the evaluated outfalls during the
certification, Brenntag Mid-South will be notified, and an investigation to determine the
source of the non-storm-water flow will be recommended.
Best Management Practices (BMPs)
Based upon the conditions observed during the site evaluation, LFI will recommend
BMPs to reduce pollutant levels in storm-water runoff and will assist in establishing time
3

Proposal for Storm-water Permitting Services May 6, 2022
Linebach Funkhouser Proposal Number 133-22
frames to implement the selected BMPs as required by NCDEQ. Typical BMPs will
incorporate good housekeeping, preventative maintenance, visual inspections, spill
prevention and response, sediment and erosion control, management of runoff, employee
training, and record keeping.
TASK 2 - Complete NPDES Notice of Intent(NOI)
A Notice of Intent (NOI) for coverage under the General Storm-water Discharge Permit for Transit
and Transportation (NCG080000) will be completed for Brenntag Mid-South. Copies of the
submittal(s)will be forwarded to Brenntag Mid-South.
The NOI will require the identification and location of the site outfalls and where they discharge or
connect with the storm-water system, which will drain to a water of the state. A site diagram map
of the outfalls and discharge points will be attached to this NOI.
TASK 3—SWPPP Preparation
The SWPPP is an internal document required by the NPDES permit that if followed should
prevent violations of the NPDES permit terms and conditions. The SWPPP is generally not
submitted to the state but can be requested by a state inspector to determine if Brenntag Mid-
South is following its own internal plan.
SWPPP Plan Draft and Final
The SWPPP will reflect the findings of the site evaluation and will identify activities and
significant materials that may potentially be sources of, or contribute to, storm-water
pollution at the site. In addition, the SWPPP will recommend BMPs to reduce pollutant
levels in storm-water runoff. Additionally, the SWPPP will include storm-water sampling
requirements and spill prevention, response, and notification procedures.
Upon completion, a draft copy SWPPP will be provided to Brenntag Mid-South for
review. Upon receipt of Brenntag Mid-South's comments, and once the modifications, if
any, are incorporated by LFI into the SWPPP, two copies of the final SWPPP will then be
forwarded to Brenntag Mid-South.
COST
Based on our experience with similar industrial facilities and our understanding of the project
requirements, LFI will perform the services outlined above for the estimated prices listed below:
TASK TASK DESCRIPTION ESTIMATED COST
I Site Visit
2 NPDES NOI for Coverage under the general permit
3 SWPPP
TOTAL
4

Proposal for Storm-water Permitting Services May 6, 2022
Linebach Funkhouser Proposal Number 133-22
If conditions exist that may cause an exceedance of the aforementioned budgetary estimate, LFI
will discuss these potential changes prior to completing the remainder of the work. These costs are
based on readily available records, access to the facility as necessary and an Brenntag Mid-South
representative knowledgeable about facility operations, available to assist LFI staff as necessary.
SCHEDULE
LFI will initiate Task 1 and 2 of the scope of work described herein within two weeks of receipt of
written authorization-to-proceed. LFI estimates that both tasks will be completed within 3-4 weeks
of initiation.
AUTHORIZATION
If you are in agreement with the scope of work set forth in this proposal and the attached terms
and conditions, please sign in the space below and return one copy to us as your authorization to
proceed. We appreciate the opportunity to provide Brenntag Mid-South with this proposal and
look forward to working with you on this project. Please feel free to contact us if you have any
questions or comments regarding this information.
Sincerely,
William P Harshaw, PE Charles D. Linebach, CHMM
Senior Engineer Principal
Accepted by: t ` t
Signature:
Acknowledging attached terms and conditions
Date: May 6,2022
Attachment
5

Linebach m Funkhouser,Inc.
environmental compliance&consulting
TERMS AND CONDITIONS
DEFINITIONS.When used herein,the terms"we","us""Linebach Funkhouser, Inc."or"our'refer to Linebach Funkhouser, Inc.,and the terms"you",
"your',"he","his","it"and"its"refer to Client.
SCOPE OF WORK. Client has requested that Linebach Funkhouser, Inc. perform the Work as specified in and for the charges set forth in our
Proposal'(incorporated by reference in its entirety herein)and as authorized by Client's representative.
COMPENSATION. Invoices for services provided are due and payable upon receipt. Balances outstanding more than thirty(30)days after invoice
date shall be deemed delinquent and shall be subject to a monthly finance charge of 1 1/2 percent,court costs,attorney's fees and any other cost of
collection incurred by Linebach Funkhouser,Inc.
RIGHT OF ENTRY AND RIGHT TO PROCEED. Client grants a right of entry from time to time to Linebach Funkhouser, Inc., its agents, staff,
consultants, and contractors or subcontractors,for the purpose of performing and with the right to perform all acts,studies, and research including
without limitation,the making of tests and evaluations,pursuant to the Work. Client represents that it possesses all permits and licenses required to
comply fully with all laws,ordinances and regulations governing the performance of its activities at the site. To the extent that any of the Work requires
access to property owned or controlled by a third party,Client represents that it has obtained all licenses,permits,and rights-of-way necessary to grant
Linebach Funkhouser,Inc.access to such property.
STANDARD OF CARE. Linebach Funkhouser, Inc. will perform its services using that degree of skill and care ordinarily exercised under similar
conditions by reputable members of Linebach Funkhouser, Inc.'s profession practicing in the same or similar locality at the time the services are
performed. NO OTHER WARRANTY,EXPRESS OR IMPLIED,IS MADE OR INTENDED.
INSURANCE.Linebach Funkhouser, Inc.maintains workers'compensation and employer's liability insurance for our employees as required by state
laws. In addition,we maintain comprehensive general liability and auto liability insurance. A Certificate of insurance can be supplied evidencing such
coverage. We will not be liable or responsible for any loss,damage,or liability beyond the amounts,limits,coverage,or conditions of such insurance
specified above.
PROFESSIONAL LIABILITY. Client acknowledges and agrees that our total aggregate liability to Client or any third party arising from negligent
professional acts,errors,omissions or breach of the above described standard of care and warranty,shall not exceed our fee or the amounts,limits,
coverage or conditions of our professional liability insurance.
HAZARDOUS SUBSTANCES AND CONSTITUENTS.Client shall advise us upon execution of this Agreement of any hazardous substances or any
condition existing in,on,or near the site presenting a potential danger to human health,the environment,or equipment. Client shall provide continuing
information as it comes available to the attention of Client in the future. By virtue of entering into this Agreement or of performing the Work hereunder,
we do not assume control of or responsibility for the site or the person in charge of the site or for communicating with any federal,state or local public
agencies regarding the Work or the site or undertake responsibility for reporting to any federal,state or local public agencies any conditions at the site
that may present a potential danger to public health,safety or the environment,including but not limited to spills,releases,or leaks. Client shall bear
the sole responsibility for communicating with any federal,state or local public agencies regarding the Work or the site,and for notifying the appropriate
federal, state or local public agencies as required by law, or otherwise to disclose, in a timely manner, any information that may be necessary to
present any danger to health,safety, or the environment, including but not limited to spills, releases and leaks. Client shall indemnify and hold us
harmless for the consequences of any communication or reporting by us or by Client to any such public agency. Client shall have sole responsibility
for compliance with any and all federal,state or local laws,regulations,guidance or other requirements relating to the handling,treatment,storage or
disposal of hazardous substances or constituents,and shall have sole responsibility for any and all changed conditions at,or hazardous substances or
constituents introduced to the site by Client or any third party before,during or after the completion of the Work described herein. Client shall have
sole responsibility for compliance with all applicable laws relating to the handling,removal,transportation,treatment,storage or disposal of hazardous
substances or constituents from,to or at the site,and shall indemnify and hold harmless Linebach Funkhouser,Inc.for any and all liability arising from
such action, including but not limited to any allegation that Linebach Funkhouser, Inc. is an owner, handler, generator, operator, treater, storer,
transporter, or disposer under the Resource Conservation and Recovery Act of 1976 as amended, the Comprehensive Environmental Response,
Compensation,and Liability Act as amended,or any other similar federal,state or local regulation or law.
UNFORESEEN OCCURRENCES.If,during the performance of the Work,any unforeseen hazardous substances or constituents or other unforeseen
conditions or occurrences are encountered which,in our sole discretion affect or may affect the Work,the risk involved in performing the Work,or the
recommended scope of the Work,we will promptly notify Client thereof. Subsequent to that notification,Linebach Funkhouser,Inc.in its sole discretion
may:
(a) If practicable,complete the original Scope of Services in accordance with the procedures originally intended in the Proposal:

(b) Agree with Client to modify the Scope of Services and the estimate of charges to include work on the previously unforeseen conditions or
occurrences:
(C) Terminate the Work as provided herein effective on the date specified by us.
CLAIMS.In the event any third party or employee of Client brings suit or claim for damages against us alleging exposure to or damage from material,
elements or constituents at or from Client's facility before,during,or after the Work performed under this Agreement,which is alleged to have resulted
in or caused disease or any adverse health condition or resulting in cost for remedial action, uninhabitabilitv of property,or other personal injury or
property damage,then:Client shall be liable for,hold harmless and indemnify us in any such suit or claim of any kind or of any nature whatsoever and
pay on our behalf,to the maximum extent permitted by law, any and all damages,losses, liabilities,obligations, penalties,claims,judgments,costs,
disbursements or expenses,including but not limited to attorneys'and experts'fees and other costs,expenses or disbursements,and personnel costs
incurred by us as a result of such suit or claim,including any interest thereon. In the event that Client makes a claim against us of any kind or nature
whatsoever for any alleged error, omission, or act arising out of the performance of the Work that cannot be mutually resolved without resort to
litigation,and Client fails to prove such claim,then Client shall pay all costs incurred by us in defending ourselves against the claim,including,but not
limited to attorneys' and experts'fees and other costs, expenses or disbursements, and personnel costs incurred by us as a result of such claim,
including any interest thereon. Client agrees that for the purposes of this Agreement it has failed to prove its claim when the monetary amount
awarded to or recovered by it is less than the highest sum offered by us in writing to resolve the matter prior to resolution of the claim.
DOCUMENTS.Client will furnish or cause to be furnished such reports,data,studies,plans,specifications,documents and other information deemed
necessary by us for proper performance of our services and Client warrants and represents that any such information provided shall not infringe on any
United States or foreign patent,copyright,trade secret or other proprietary right of any third party,and shall hold Linebach Funkhouser,Inc.harmless
and indemnify us for any such infringement. We may rely upon Client-provided documents in performing the services required under this Agreement;
however,we assume no responsibility or liability for their accuracy. Client-provided documents will remain property of Client. All documents,including,
but not limited to drawings, specifications, reports, boring logs, field notes, laboratory test data, calculations and estimates, prepared by us as
instruments of service pursuant to this Agreement, shall be our sole property. Client agrees and acknowledges that all documents of any nature
furnished to Client or Client's agents or designees by Linebach Funkhouser, Inc.shall be treated as confidential,and shall be disseminated only to
those employees or agents whose duties justify their need to know such information, unless prior written authorization is obtained from Linebach
Funkhouser,Inc.or disclosure is compelled by a court of competent jurisdiction. Client further agrees that any documents not paid for will be returned
to us upon demand and will not be used by Client for any purpose whatsoever. Client further agrees that under no circumstances shall any documents
produced by us pursuant to this Agreement be used at any location,for any project or by any person not expressly provided for in this Agreement
without our prior written permission. If Client uses all or any of our documents for another project or disseminates our documents in violation of this
paragraph,client shall to the maximum extent permitted by law indemnify and hold us harmless from any all claims arising from such unauthorized use.
Further,no part of any document we deliver to Client shall be reproduced or distributed,whether for advertising or any other purpose,without our prior
written consent. Any such reproduction or distribution shall be at Client's sole risk and without liability or legal exposure to Linebach Funkhouser,Inc.,
and Client shall indemnify and hold us harmless,to the maximum extent permitted by law,from any and all claims arising from such unauthorized
reproduction or distribution.
TERMINATION.This Agreement may be terminated by either party for any reason upon 10 days'written notice. Upon termination of this Agreement,
Linebach Funkhouser,Inc.shall be entitled to payment for Work performed up to and including the date the notice of termination is received as well as
all reasonable costs of demobilization and closeout of the Work.
DUTY TO COOPERATE.The parties agree to provide reasonable access to information regarding the site or the Work performed and to responsible
personnel as may be required to address any claim made regarding the Work performed or this Agreements. The parties further agree to provide
copies to each other of any claims,demands or notices from any federal,state or local public agency regarding the Work performed or this Agreement.
SEVERABILITY.In the event that any provision herein shall be deemed invalid or unenforceable,the other provisions hereof shall remain in full force
and effect,and binding upon the parties hereto.
SURVIVAL.All obligations arising prior to the termination of this Agreement and all provisions of this Agreement allocating responsibility or liability
between Client and Linebach Funkhouser,Inc.shall survive the completion of the services and the termination of this Agreement.
INTEGRATION.This Agreement and the documents attached hereto and which are incorporated herein constitute the entire Agreement between the
parties and cannot be changed except by written instrument signed by both the parties.
GOVERNING LAW,VENUE AND JURISDICTION.This Agreement is and shall be deemed to be a contract entered into and made pursuant to the
laws of the State of Kentucky and shall in all respects be governed,construed,applied and enforced in accordance with the laws of such State.

Linebach ■ Funkhouser, Inc.
ENVIRONMENTAL COMPLIANCE&CONSULTING
2022 FEE SCHEDULE
For Unit Rate/Time & Materials Projects
A. Professional
➢ Field
Geologist, Scientist, Engineer,per hour $85
➢ Staff
Geologist, Scientist, Engineer,per hour $100
➢ Project
Geologist, Scientist, Engineer,per hour $115
➢ Senior
Geologist, Scientist, Engineer,per hour $135
➢ Principal
Geologist, Scientist, Engineer,per hour $160
B. Support Personnel
➢ Word Processor/Administrative Assistant,per hour $55
➢ Drafting,per hour $80
C. Subcontractors
➢ Drilling,Laboratory,Etc. Cost+20%
D. Travel Expenses
➢ Vehicle Rental, Overnight,Meals, Etc. Cost+20%
E. Other Expenses
➢ Overnight Courier(Fed Ex,UPS) Cost+20%
➢ General Administrative Expenses(Copies, Office Phone,Fax) No Charge
-Report production expenses requiring excessive
documentation or report copies(more than 2), or outside
printing/copying services,will be passed along at Cost+ 15%
F. Equipment
➢ Disposable Bailers,each $20.00
➢ Photo-Ionization Detector,per day $95.00
➢ Water Level Indicator,per day $30.00
➢ Interface Probe,per day $65.00
➢ Peristaltic Pump,per day $50.00
➢ Survey Equipment,per day $65.00
➢ Hand Auger,per day $35.00
➢ Hammer Drill,per day $30.00
➢ Drone,per day $150.00

94ARCAD IS Oesi assets sultancy
fornaturaland
built assets
Mr. David Grenoble Arcadis G&M of North Carolina,Inc.
District SRQ Manager Wade I
Brenntag Mid-South, Inc. 5420 Wade Park Boulevard
2000 East Pettigrew Street Suite 350
Durham, NC 27703 Raleigh
North Carolina 27607
Tel [phone]
Fax [phone]
Subject:
Proposal to Conduct a Site Inspection, Prepare SWPPP, Prepare SPCC Plan, ENVIRONMENT
Collect Stormwater Samples for Stormwater Permit, and Prepare an Application
for an Individual Industrial NPDES Stormwater Permit, 11750 Fruehauf Drive,
Date:
Charlotte, North Carolina. May 3, 2022
Contact:
Jim Shilliday
Dear Mr. Grenoble:
Phone:
Arcadis G&M of North Carolina, Inc. (Arcadis) is pleased to submit this proposal 919-415-2302
to Brenntag Mid-South, Inc., (Brenntag)to assist with stormwater work for the
above-referenced site. The work tasks will include the following: conduct a site Email:
inspection, preparation of a Stormwater Pollution Prevention Plan (SWPPP), [e-mail]
preparation of a Spill Control and Countermeasure (SPCC) Plan, collection of Our ref:
stormwater samples for an Individual Industrial NPDES Stormwater Permit
Application, and preparation of an Individual Industrial NPDES Stormwater
Permit Application. ARCADIS G&M of North Carolina,Inc.
The following text discusses the scope of services and costs associated with the NC Engineering License#C-1869
above-mentioned activities. NC Surveying License#C-1869
SCOPE OF SERVICES
Task 1. Site Inspection
An Arcadis representative will conduct an inspection of the Brenntag facility
located 11750 Fruehauf Drive, Charlotte, NC. The purpose of the site inspection
will be to identify chemical storage areas at the facility, types of chemicals stored
at the facility, surficial drainage patterns at the facility, and locations of
stormwater capture and conveyance structures.
https://arcadiso365-my.sharepoint.com/personal/jim_shilliday_arcadis-us_com/Documents/Documents/Brenntag-Fruehauf-Charlotte/Proposal for 2022 SWPPP,SPCC Plan, Page:
Stormwater NPDES Permit Application(4-20-22)/SWPPP,SPCC,Stormwater Permit Application Proposal(5-3-22).docx 1/3

Mr. David Grenoble
May 3, 2022
Task 2. Preparation of SWPPP
Based on discussions with Brenntag a SWPPP has not previously been prepared for this Brenntag
facility. Arcadis will use the SWPPP prepared for the Brenntag facility in Durham as a template and
complete a site-specific SWPPP for the Charlotte facility using information gathered during the site
inspection.
Task 3. Preparation of SPCC Plan
Based on discussions with Brenntag a SPCC Plan has not previously been prepared for this Brenntag
facility. Arcadis will use the SPCC Plan prepared for the Brenntag facility in Durham as a template and
complete a site-specific SPCC Plan for the Charlotte facility using information gathered during the site
inspection.
Task 4. Collection of Stormwater Samples for Individual Industrial NPDES Stormwater Permit
Application
Arcadis staff will sample the facilities designated stormwater outfall for a facility specific parameter list. At
a minimum, the required parameter list will include oil &grease, total phosphorus, total Kjeldahl nitrogen
(TKN), and total nitrogen. There are several parameter lists included in the application that have to be
reviewed for potential disclosure, so we may have to analyze stormwater samples for other parameters
based on materials stored at the site.
Task 5. Preparation of an Individual Industrial NPDES Stormwater Permit Application
Following completion of the baseline stormwater sampling event, an Individual Industrial NPDES
Stormwater Permit Application will be prepared and submitted to the NCDEQ. The permit application will
require a non-refundable application fee of$860.00.
Task 6. Project Management
Project management will include scheduling all fieldwork activities with Arcadis personnel and with
subcontractors, preparation of subcontractor agreements, budget tracking, monthly accounting activities,
preparation of monthly project budget/activities reports and client interaction.
PROJECT TEAM
The overall execution of the project will be managed by Jim Shilliday out of our office in Raleigh, North
Carolina. All civil engineering activities will be performed by Ryan Gerber also out of our Raleigh office.
PROJECT COST
This project will be conducted on a time and materials basis with a not-to-exceed-budget in accordance
with the hourly rates, terms, and conditions in our contract with Brenntag. A task-specific listing of the
project costs for the scope of services presented in this proposal is provided as Attachment A. Project
expenses will be invoiced on a monthly basis according to our contract with Brenntag. The total cost
associated with performing the scope of work presented in this proposal is estimated at$33,992. Should
arcadis.com
https://arcadiso365-my.sharepoint.com/personal/jim_shilliday_arcadis-us_com/Documents/Documents/Brenntag-Fruehauf-Charlotte/Proposal for 2022 SWPPP,SPCC Plan, Page:
Stormwater NPDES Permit Application(4-20-22)/SWPPP,SPCC,Stormwater Permit Application Proposal(5-3-22).docx 2/3

Mr. David Grenoble
May 3, 2022
additional effort be required that is not specifically described in the above scope of services, then these
efforts will be billed on a time-and-materials basis, following the contract fee schedule.
CLOSING REMARKS
Arcadis appreciates the opportunity to be of continued service to Brenntag. If you have any questions or
comments concerning this proposal, please contact me at your earliest convenience at(919)415-2302. If
this proposal is acceptable, please sign the attached Scope of Work Authorization included as
Attachment B and send a copy to Arcadis.
Sincerely,
Arcadis G&M of North Carolina, Inc.
James E. Shilliday, III, L.G.
Principal Scientist/Project Manager
Enclosures:
Attachment A Cost Estimate
Attachment B Work Authorization
arcadis.com
https://arcadiso365-my.sharepoint.com/personal/jim_shilliday_arcadis-us_com/Documents/Documents/Brenntag-Fruehauf-Charlotte/Proposal for 2022 SWPPP,SPCC Plan, Page:
Stormwater NPDES Permit Application(4-20-22)/SWPPP,SPCC,Stormwater Permit Application Proposal(5-3-22).docx 3/3

Attachment A
Estimated Costs to Inspect Site, Prepare SWPPP, Prepare SPCC Plan, Collect Stormwater Samples for Individual
Industrial NPDES Stormwater Permit Application,and Prepare Individual Industrial NPDES Stormwater Permit Application
Brenntag Charlotte Facility, 11750 Fruehauf Drive, Charlotte, North Carolina.
Task(s) Description Hours Rate Totals
1. Site Inspection
Labor
Sr Project Staff 1 12 $ 159.86 /hr $ 1,918.32
Expenses $ 200.00
Subtotal: $ 2,118.32
2. SWPPP Preparation
Labor
Sr Project Staff 1 40 $ 159.86 /hr $ 6,394.40
Sr. Drafting 10 $ 86.00 /hr $ 860.00
Sr Project Manager 8 $ 192.94 /hr $ 1,543.52
Project Assistant 8 $ 86.00 /hr $ 688.00
$ 9,485.92
3. SPCC Plan Preparation
Labor
Sr Project Staff 1 24 $ 159.86 /hr $ 3,836.64
Sr. Drafting 4 $ 86.00 /hr $ 344.00
Sr Project Manager 4 $ 192.94 /hr $ 771.76
Project Assistant 4 $ 86.00 /hr $ 344.00
$ 5,296.40
4. Collection of Stormwater Samples for Individual Industrial NPDES Stormwater Permit Application
Labor
Sr Project Staff 1 4 $ 159.86 /hr $ 639.44
Staff Scientist 1 12 $ 86.00 /hr $ 1,032.00
Sr Project Manager 2 $ 192.94 /hr $ 385.88
Laboratory Subcontractor(Test America) $ 1,200.00
Equipment/Expenses $ 1,400.00
$ 4,657.32
5. Preparation of Individual Industrial NPDES Stormwater Permit Application
Labor
Sr Project Staff 1 30 $ 159.86 /hr $ 4,795.80
Sr Project Manager 8 $ 192.94 /hr $ 1,543.52
Project Assistant 8 $ 86.00 /hr $ 688.00
Expenses(Permit Fee) $ 860.00
$ 7,887.32
6. Project Management
Labor
Sr Project Manager 20 $ 192.94 /hr $ 3,858.80
Project Assistant 8 $ 86.00 /hr $ 688.00
$ 4,546.80
TOTAL PROJECT COST $ 33,992
Pagel of 1

Attachment B
SCOPE OF WORK AUTHORIZATION
Pursuant to
Agreement
Dated March 30, 2005
between
Arcadis U.S.,Inc.
and
Brenntag North America,Inc.
Proposal Date: May 3, 2022
Proposal Description: Site Inspection, SWPPP, SPCC, Stormwater Permit Application
Site: Brenntag/Fruehauf/Charlotte,North Carolina
Arcadis Office: Raleigh,NC
Authorized Budget: $33,992
Pursuant to the terms and conditions of the Agreement dated March 30, 2005, between
Arcadis U.S., Inc., and Brenntag North America, Inc., including all Exhibits, which are
incorporated herein by reference, Arcadis U.S., Inc., shall perform the Services described in
the proposal identified above and attached to this Scope of Work Authorization.
Brenntag Mid-South, Inc. Arcadis U.S.,Inc.
-C/)W"-�F _=7
By: B James E. Shillidgy III
Title: Title: Account Leader
Date: Date: 5/3/22

Young, Brianna A
From: Kay, Lily C
Sent: Thursday, March 17, 2022 9:32 AM
To: Young, Brianna A
Subject: Re: [External] RE: Permit Application Contact Information
Brianna,
With the amount solvents and caustics they have on site, I feel they need an individual permit. Just my thoughts.
Lily
Sent from my iPhone
On Mar 17, 2022, at 8:57 AM,Young, Brianna A<[e-mail]>wrote:
Good afternoon,
I apologize for the delay in addressing this question. Per representatives from Brenntag Charlotte,the
SIC code for the site is 5169.Although NPDES regulations do not automatically permit coverage for
facilities with this SIC code,40 CFR 122.26 allows for NC DEQ's authority to designate discharges and
require permits for sites that have the potential to impact surface water quality because of pollutant
contribution.After consultation with both DEQ Mooresville Regional Office and Charlotte-Mecklenburg
Stormwater Services staff, DEQ is requiring that Brenntag Charlotte apply for stormwater permit
coverage. Please review our Industrial Permitting website here for both general and individual permits
to decide which permit coverage best fits your facility/site operations.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has
adjusted operations to protect the health and safety of the staff and public. Many employees are working
remotely or are on staggered shifts.To accommodate these staffing changes,all DEQ office locations are limiting
public access to appointments only. Please check with the appropriate staff before visiting our offices,as we may
1

be able to handle your requests by phone or email.We appreciate your patience as we continue to serve the
public during this challenging time.
From: David Grenoble/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:48 AM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>; Bradley, Lauren M.
<Lauren.Brad [e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L
<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [External] RE: Permit Application Contact Information
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an
attachment to Report Spam.
Good morning,
It seems like this question keeps circling around and we have yet to be able to collectively bring it to a
close.As we have previously communicated,we will be more than happy to apply for/obtain a storm
water permit if indicated. As of our most recent conversations with Mecklenburg County
representatives and Mrs.Young, it is still unclear if this requirement is applicable to our Charlotte facility
or not. We obviously want to do the right thing and maintain full compliance and cooperation. Can
anyone advise definitively if we need a permit and, if so, what the process is to apply for and obtain
one?
Thank you all,
- David
David M.Grenoble
Regional Safety,Regulatory,and Quality Manager
<image001.jpg>
Brenntag Mid-South,Inc.
M:270.869.5806
www.brenntag.com
<image002.gif>
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Thursday, February 24, 2022 8:26 AM
To: Bradley, Lauren M. <[e-mail]>; David Grenoble/Mid-
South/Brenntag<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L
<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael
<[e-mail]>
Subject: RE: Permit Application Contact Information
Including our previous correspondence. Please let me know what other information is needed.
Dennis Martin
Operations Manager
<image003.png>
2

Brenntag Mid-South -Charlotte
11750 Fruehauf Dr
Charlotte, NC 28273
980-500-3857(desk)
270-577-4893(cell)
Email:dmartin(a)brenntao.com
www.brenntag.com/Mid-South
<image004.gif>
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent:Wednesday, February 23, 2022 2:56 PM
To: Bradley, Lauren M. <Lauren.Bradley@ mecklen burgcountync.gov>; David Grenoble/Mid-
South/Brenntag<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L
<[e-mail]>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael
<[e-mail]>
Subject: Re: Permit Application Contact Information
Including David Grenoble, our SRQ.
Get Outlook for iOS
From: Bradley, Lauren M. <Lauren.Bradley@ mecklenburgcountync.gov>
Sent:Wednesday, February 23, 2022 2:49:38 PM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Cc:Young, Brianna A<[e-mail]>; Farmer, Richard L
<Richard.Farmer@meck lenburgcountync.gov>; Santiago, Matthew J.
<[e-mail]>; Schley, Michael
<[e-mail]>
Subject: [EXTERNAL]Permit Application Contact Information
Good evening Dennis,
Please contact Brianna Young, Industrial Individual Permits Coordinator, with NC DEQ/ Division
of Energy, Mineral, and Land Resources (DEMLR) to apply for your permit. She is CC'ed on this
email.
[e-mail]
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Thank you for your cooperation during todays sampling event. If you have any questions please
feel free to reach out.
Best,
Lauren Bradley
Environmental Specialist 11
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
<image005.png>
3

We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
This communication and any documents accompanying this email transmission may be subject to the
attorney-client privilege or be considered attorney work product.
If you believe that you received this email in error, please do not read, copy, use or disclose this
communication to others; also please notify the sender by replying to this message, and then delete it
from your system. Please verify that you will delete the e-mail in your reply.Thank you.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic
communication relating to this matter, including any attachments, constitute an "electronic
communication"within the meaning of the Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or
any similar law of any other jurisdiction. In addition,this and any subsequent electronic communication,
and any attachments, may be subject to the attorney-client privilege or be considered attorney work
product.
This communication, and any subsequent electronic communication relating to this matter, including
any attachments, is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an
intended recipient, any use, review, dissemination, or copying of any such communication by you is
strictly prohibited. If you believe you have received this or any other electronic communication in error,
please do not read, copy, use or disclose it to others; also please notify the sender by replying to the
communication, and then delete it and all accompanying files from your system. Please verify that you
will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent
communication, including any attachments, are solely those of the author or sender and do not
necessarily represent those of Brenntag or its affiliated companies. Neither Brenntag nor any of its
affiliated companies accepts any liability for any damage caused by any virus transmitted by any email
or its attachments.
4

Charlotte-Mecklenburg
STORM
-WATER 2145 Suttle Avenue
Charlotte, NC 28208
Services-
May 9, 2022
Brenntag
Attn: Dennis Martin, Operations Manager
11750 Fruehauf Drive
Charlotte,NC
Subject: Stormwater Monitoring
Brenntag
Dear Mr. Martin,
On February 23, 2022, Lauren Bradley of Charlotte-Mecklenburg Storm Water Services
(CMSWS) sampled stormwater runoff from the subject facility located at 11750 Fruehauf
Drive in Charlotte,North Carolina. The monitoring was conducted under authority
granted by Charlotte City Code Chapter 18, Section 18-82.
The monitoring was also conducted as part of a cooperative working agreement between
Mecklenburg County and the North Carolina Department of Environmental Quality
(NCDEQ) — Division of Energy, Mineral and Land Resources (DEMLR). NCDEQ —
DEMLR has been copied on this report and made aware of monitoring results regarding
the facility's NPDES permit.
Total rainfall during the rain event in which samples were collected at your facility was
0.39". Rainfall data was reported by the United States Geologic Survey(USGS)real-time
station CRN-21 (Rain Gauge at Kennedy Jr. High). CMSWS sampled stormwater runoff
from Outfall #1 and the onsite pond. A summary table of results is attached to this report.
Please see the attached table for more information on your monitoring results. CMSWS
analyzed the monitoring results from your facility by comparing them to Storm Water
Permit benchmark parameters as well as to local and state stream standards (CMSWS
Action Levels and North Carolina Water Quality Standards). The results indicate highly
elevated levels of Biochemical Oxygen Demand (BOD) in your facility's stormwater
runoff. Since the stormwater sample was not collected from a stream, the local and state
surface water quality standards do not apply; however,they indicate the potential of
polluted runoff from the facility to negatively impact the receiving stream.
Based on this analysis, and under authority of the City of Charlotte Storm Water
Pollution Control Ordinance, CMSWS is requiring Brenntag to evaluate current outdoor
processes, material storage practices and overall housekeeping at your facility. Within 30
days of receiving this letter, submit a written response to CMSWS
obTo report pollution or drainage problems call: 311 � '
CHARiATIF_ http://stormwater.charmeek.org

Dennis Martin, Operations Manager
Page 2
May 9, 2022
(matthew.santiagogmecklenbur countync.gov) which includes both short term and long
term actions to be taken in an effort to reduce these elevated pollutant concentrations.
Please contact me at(980) 240-3337 if you have any questions or need additional
information. For questions specifically regarding NPDES stormwater permitting,please
contact Lily Kay with NCDEQ—DEMLR at(704) 663-1699.
Sincerely,
Matt Santiago
Environmental Specialist II
Charlotte-Mecklenburg Storm Water Services
Attachment
cc: Andrew DeCristofaro, City of Charlotte
Lily Kay,NCDEQ - DEMLR
Zahid Khan,NCDEQ—DEMLR
Jeffrey Chandler,NCDEQ - DEMLR
2

kv::= Charlotte-Mecklenburg
STORM 2145 Suttle Ave
WATER Charlotte, NC 28202
Services v
Summary of Stormwater Monitoring and Analysis
Facility: Brenntag Outfall
Sample Date: 2/23/22
Rain Event Total: 0.39" inches (CRN-21)
Industrial CMSWS NC Water
Parameter Units Outfall 001 Stormwater Permit Action Level Quality
Discharge Standard
Benchmarks/Limits (In-stream) (In-stream)
Temperature (°C) 16.3 32 -
Dissolved
(mg/L) 8.09 - 4.0
Oxygen
Conductivity (umho/cm) 206.0 550 -
pH 9.34 6.0—9.0 - 6.0 to 9.0
Fecal Coliform 1 OmL <100 1000 3000 200
E-Coli Bacteria 1 mpn/ <100 - - -
Total Suspended (mg/P 227 100 - -
Solids
Turbidity (NTU) 260 - - 50.0
Copper* (mg/L) 0.039 0.010 - 0.0036
Zinc* (mg/L) 0.270 0.126 - 0.036
Chromium (mg/L) 0.030 0.905 - 0.016
Lead* (mg/L) 0.008 0.075 - 0.014
Oil and Grease, (mg/L) <5 15 - -
and TPH
BOD (mg/L) 338 - 6.0 -
COD (mg/L) 880 120 - -
Yellow indicates exceedance of Permit Benchmark Value or a CMSWS Action Level.NC Water Quality
In Stream Standards are also shown as a reference.
*Monitoring data collected during this event is based on total recoverable metals.
The values for the Industrial Stormwater Permits Discharge Benchmarks and CMSWS Action Levels are
also based on total recoverable metals.The NC Water Quality Standard for in-stream is based on dissolved
metals with an assumed in-stream hardness value of 25 mg/L.
•
o' To report pollution or drainage problems, call: 311
http://stormwater.charmeek.org y`
CHAIROTTE

kv::= Charlotte-Mecklenburg
STORM 2145 Suttle Ave
WATER Charlotte, NC 28202
Services v
Summary of Stormwater Monitoring and Analysis
Facility: Brenntag Pond
Sample Date: 2/23/22
Rain Event Total: 0.39" inches (CRN-21)
Industrial CMSWS NC Water
Parameter Units Outfall 001 Stormwater Permit Action Level Quality
Discharge Standard
Benchmarks/Limits (In-stream) (In-stream)
Temperature (°C) 16.5 32 -
Dissolved
(mg/L) 7.41 - 4.0
Oxygen
Conductivity (umho/cm) 27.5 550 -
pH 9.12 6.0-9.0 - 6.0to9.0
Fecal Coliform 1 OmL <100 1000 3000 200
E-Coli Bacteria 1 mpn/ 100 - - -
Total Suspended (mg/-) 46.4 100 - -
Solids
Turbidity (NTU) 60 - - 50.0
Copper* (mg/L) 0.034 0.010 - 0.0036
Zinc* (mg/L) 0.450 0.126 - 0.036
Chromium (mg/L) 0.007 0.905 - 0.016
Lead* (mg/L) <0.005 0.075 - 0.014
Oil and Grease, (mg/-) <5.0 15 - -
and TPH
BOD (mg/L) 171 - 6.0 -
COD (mg/L) 370 120 -
Yellow indicates exceedance of Permit Benchmark Value or a CMSWS Action Level.NC Water Quality
In Stream Standards are also shown as a reference.
*Monitoring data collected during this event is based on total recoverable metals.
The values for the Industrial Stormwater Permits Discharge Benchmarks and CMSWS Action Levels are
also based on total recoverable metals.The NC Water Quality Standard for in-stream is based on dissolved
metals with an assumed in-stream hardness value of 25 mg/L.
•
o' To report pollution or drainage problems, call: 311
http://stormwater.charmeek.org y'
CHAIROTTE

Brenntag Charlotte overview
• Chemical packaging and distribution processing, storage
• Process water is collected and secure and discharge to the sewer system
• SIC code: S169
• On the south side of Charlotte
• Open to a site visit
• They unload tankers
• Their question: Do they need a permit?
Dennis Martin—[e-mail]
My review
• DEQ DEMLER MRO and Charlotte/Mecklenburg both feel they need a permit
• SIC code they provided does not seem to require a permit
• Can we make them apply for a permit using Director discretion?

Brenntag — A History
9/21/18: Industrial Facility Inspection by Chad Broadway - The facility has a reverse osmosis
system that treats potable water for use in diluting Diesel Emission Fluid. The system discharges
filter backwash and/or general byproduct discharge from the treatment process to the facility's
stormwater basin, and ultimately to surface waters. This discharge represents an unpermitted
wastewater discharge and is a violation of local ordinance and North Carolina regulations. A
Notice of Violation was issued by NCDEQ-DWR on October 10, 2018.
The illicit discharge of filter backwash and/or process byproduct from the facility's reverse
osmosis system has been ceased. The facility has plumbed the discharge into one of the facility's
chemical secondary containment areas, which discharges to the facility's pretreatment system.
The site was non permitted and was informed that they should contact he NCDEQ Division of
Energy, Mineral, and Land Resources to determine if a National Pollutant Discharge Elimination
System(NPDES) industrial stormwater permit is required for this site.
3/12/20: Emergency Response -Matt Santiago and Hannah Meeler of Charlotte-Mecklenburg
Stormwater Services (CMSWS) responded to an emergency call regarding an accidental release
of sulfuric acid. According to facility personnel, a hose broke while transferring sulfuric acid
from a train car to storage containers at the facility. Approximately 300 to 500 gallons of
sulfuric acid was released onto the trailer parking area which is composed of crushed and rolled
gravel. CMSWS walked the creek on the other side adjacent to the berm. No evidence of the
sulfuric acid was observed migrating through the berm. An excavator was onsite later in the day
to remove and dispose of impacted gravel and re-grade the lot.
4/29/20: Emergency Response -Dave Ferguson responded to a reported spill and was informed
that a rail car carrying hydrochloric acid was being drawn down when a pipe burst, discharging
to the gravel lot at the rear of the property. An estimated 5000 gallons spilled and an unknown
quantity of acid had actually reached the stream resulting in a fish kill.
Ferguson worked with Ken Rhame of the Environmental Protection Agency and Wes Bell of
NCDENR on the spill response. A penalty of$550 was issued to Brenntag by CSWS.
10/19/21: Mr. John Thao, Mrs. Lauren Goyne, and Mr. Matt Santiago conducted a facility
penalty reinspection and industrial inspection of the Brenntag facility located on 11750 Fruehauf
Dr. Ms. Lily Kay and her associate with NC DEQ were also in attendance. No violation of the
storm water ordinance was observed. Ms.Kay instructed Brenntag to obtain a storm water permit
for the facility. Industrial storm water monitoring will be performed.
1/25/22: An administrative penalty in the amount of$16,900 was issued by the NC DEQ
hazardous waste section for improper labeling and product profiling of hazardous waste located
on site. This investigation was initiated on 1/22/2020. They were also fined $2638 for
investigation cost and required to pay a $1680 fee for acting as a hazardous waste storage
facility.

2145 Suttle Avenue
STORMCharlotte, NC 28208
ER Facility Inspection
—� Ser 'vices
Facility Name: Brenntag Mid-South Inspection#: 62995
Contact: Dennis Martin, Operations Manager Permit#:
Inspector: Lauren Goyne Receiving Stream: Steele Creek
Inspection Date: 10/19/2021 Entry Time: 1:00 pm Exit Time: 3:00 pm SIC#:
Facility Description: Brenntag Mid-South is located at 11750 Fruehauf Drive on approximately 12 acres across two
parcels. The facility receives various chemicals including solvents, acids, bases, and diesel emission fluid via rail car or
tanker truck and dilutes or repackages the chemicals for further distribution.
File Review/History: Charlotte-Mecklenburg Storm Water Services (CMSWS)previously inspected Brenntag Mid-South
on September 21, 2018.As a result of this inspection, the facility was issued a Notice of Violation on October 10, 2018
from the North Carolina Department of Environmental Quality- Division of Water Resources for the discharge of filter
backwash and/or process byproduct from the facility's reverse osmosis system.
Inspection Summary:At the time of inspection, Brenntag Mid-South was observed to be compliant with the City of
Charlotte Storm Water Pollution Control Ordinance. Please refer to the report for comments and recommendations from
the inspection.
INSPECTION DETAILS
Site Inspection Deficiency Comments
Stormwater system (catch basins, No Stormwater flows through the facility via sheet flow and to
inlets, outfalls, etc.) three earthen basins which discharge from five outfalls at the
northern perimeter of the facility. See the"Structural
stormwater control measures(SCMs)"section for
recommendations.
Erosion issues No No erosion issues were observed during the inspection.
Structural stormwater control Recommendation The facility has three earthen basins with outlet structures
measures(SCMs) equipped with manually activated valves that remain closed
until accumulated stormwater is qualitatively evaluated and
analyzed for pH. At the time of inspection,the largest basin,
which drains the outdoor tote storage area, had accumulated
water that was observed to be very dark in color. CMSWS
recommends determining the source of the dark water in
order to protect water quality.
Illicit discharges/connections No No illicit discharges or connections were observed during the
inspection.
Aboveground storage tank(s)(ASTs) No The facility has approximately 20 outdoor ASTs of acids,
and any associated venting and/or caustics, Diesel Emission Fluid (DEF), and solvents.
dispenser(s)—list tank size(s)and Capacity volumes of the ASTs range from 20,000 to 30,000
contents gallons, and secondary containment structures are separated
based on reactivity.Accumulated stormwater in containment
structures is analyzed for pH prior to release. No stormwater
pollution issues were observed.
Underground storage tank(s)(USTs) N/A
and any associated fill port area(s)
and dispenser(s)—list tank size(s)
and contents
&— To report pollution or drainage problems call: 311
CttARIATTE_ http://stormwater.charmeck.org
11/2/2021 4:48:47PM Page 1 of 3

Site Inspection Deficiency Comments
Outdoor material storage area(s) Repeat Finding A recent DEF spill, as well as evidence of old spills of
unknown materials,where observed in the tote storage area
at the southern portion of the facility.The facility should
promptly clean spills in an effort prevent stormwater
contamination and protect water quality. Update:on 10/20/21
,facility personnel sent photos to CMSWS showing that the
recent DEF spill had been cleaned.
Outdoor processing area(s) N/A
Loading/unloading area(s) No The facility receives bulk chemicals via rail car and tanker
truck and repackages and/or dilutes the chemicals prior to
subsequent redistribution in tanker trucks,totes, or drums.
No stormwater pollution issues were observed.
Vehicle/equipment area(s)-fueling, No The facility's forklifts are fueled using propane, maintained
maintenance,washing, storage, etc. onsite by a third party contactor, and mainly stored indoors.
According to facility personnel, no vehicle/equipment washing
occurs onsite. No stormwater pollution issues were observed.
Oil/water separator and/or No The facility has a wastewater pretreatment system on site
pretreatment and discharges to the Charlotte Water sanitary sewer system
as a registered Significant Industrial User. No stormwater
pollution issues were observed.
Waste storage/disposal area(s)- Recommendation The facility has one municipal waste dumpster and two large
open tops, waste containers, scrap open-top dumpster.All dumpsters were observed outdoors
metal bins, etc. and uncovered and the waste dumpster was observed without
a drain plug. CMSWS recommends covering all waste
containers to protect water quality.
Food service area(s) N/A
Indoor material storage area(s) No The facility has numerous 55-gallon drums of various
products, such as acids, caustics, DEF, and solvents,which
are stored indoors waiting to be distributed. No stormwater
pollution issues were observed.
Indoor processing area(s) No The facility receives bulk chemicals via rail car and tanker
truck which are then processed into smaller containers. No
stormwater pollution issues were observed.
Floor drains No Drains in the acid area collect spills in a small, in-ground
tank. Wastewater from the tank is pumped out and is taken
to the facility's wastewater pretreatment. Drains in the solvent
loading/unloading area are also pumped out and the
wastewater is collected by a third party for disposal. No
stormwater pollution issues were observed.
Spill response equipment Recommendation Spill kits were not readily observed during the inspection.
CMSWS recommends placing spill kits throughout the facility
in order to promptly address spills and leaks in and effort to
protect water quality.
SWPPP Section Observed Comments
Does the facility have a Stormwater N/A Brenntag is currently non-permitted and is not required to
Pollution Prevention Plan (SWPPP)? have a stormwater pollution prevention plan. Based on the
nature of industrial operations, exposure of pollutants to
stormwater, and presence of outfalls,the facility should
contact the NCDEQ Division of Energy, Mineral, and Land
Resources to determine if a National Pollutant Discharge
Elimination System (NPDES)industrial stormwater permit is
required for this site.
Reviewed and updated annually N/A
To report pollution or drainage problems call: 311
CIIARIATTE_ http://stormwater.charmeck.org ..
11/2/2021 4:48:47PM Page 2 of 3

SWPPP Section Observed Comments
Responsible party N/A
General location (USGS)map N/A
Detailed site map N/A
Narrative description of industrial N/A
processes
Feasibility study N/A
Evaluation of stormwater outfalls(non N/A
-stormwater discharge evaluation)
Stormwater best management N/A
practice(BMP)summary
Secondary containment plan (all N/A
necessary secondary containment
provided and documented)
Records on every release from a N/A
secondary containment system (for
the last 5 years)
Spill prevention and response N/A
procedures(SPRP)
List of significant spills or leaks(for N/A
the last 3 years)
Solvent management plan (SMP) N/A
Preventative maintenance and good N/A
housekeeping program (PMGHP)
Facility inspections conducted as N/A
required
Employee training (provided and N/A
documented)
Qualitative/Analytical Monitoring Observed Comments
Qualitative monitoring conducted as N/A
required
Analytical monitoring conducted as N/A
required
Analytical monitoring for onsite N/A
vehicle and equipment maintenance
as required
Permit and Outfalls Observed Comments
Copy of permit and certificate of N/A
coverage onsite
All outfalls observed No Outfalls were not accessible due to a fence
Number of Outfalls Observed 0
Representative outfall status N/A
documented by DEMLR
ObTo report pollution or drainage problems call: 311
CIIARIATTE_ http://stormwater.charmeck.org
11/2/2021 4:48:47PM Page 3 of 3

Young, Brianna A
From: Goyne, Lauren M. <[e-mail]>
Sent: Tuesday, November 9, 2021 3:49 PM
To: Young, Brianna A; Kay, Lily C
Cc: Farmer, Richard L; Santiago, Matthew J.; Thao, John; Chandler,Jeffrey A
Subject: RE: [External] Thoughts/Questions about the Brenntag Inspection
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hi Brianna,
That is very helpful information.Thank you so much for clarifying this,we really appreciate it.
Best,
Lauren Goyne
Environmental Specialist 11
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
WATER
$n*m i
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, November 9, 2021 1:25 PM
To: Goyne, Lauren M. <[e-mail]>; Kay, Lily C<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>;Thao,John <[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Subject: RE: [External] Thoughts/Questions about the Brenntag Inspection
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Hello Lauren,
I apologize for the delay in responding to you as I wanted to speak with other stormwater permitting staff first. In our
permits, secondary containment is defined as "Spill containment for the contents of the single largest tank within the
containment structure plus sufficient freeboard to contain the 25-year, 24-hour storm event." Double-walled tanks are
considered sufficient because they are not open to the atmosphere and are designed to contain contents of a tank, but
ponds are tricky if used as secondary containment(depends on whether they are lined and prevent material from
getting into groundwater, etc.). Unless a pond can hold a spill and the 25-yr, 24-hr event without overflow,they don't
always qualify.
i

With all that said, if the area is not bermed and might sheetflow off,the permittee does not have what qualifies. Does
this provide everything you need?
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your
patience as we continue to serve the public during this challenging time.
From: Goyne, Lauren M. <[e-mail]>
Sent:Tuesday, November 2, 2021 11:33 AM
To:Young, Brianna A<[e-mail]>; Kay, Lily C<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>;Thao,John <[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Subject: RE: [External] Thoughts/Questions about the Brenntag Inspection
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Good Morning Brianna,
Thank you for the information. I'm not exactly sure that this language would address the concern.There is an
outdoor/uncovered area this facility utilizes to store dozens of 250-g totes of various products.The totes are not being
stored on spill pallets.This area drains to a small pond on the property and is being utilized as a type of secondary
containment.The pond does discharge through a pipe in the ground which is connected to a manual release valve where
facility personnel evaluate the water before releasing it to the stormwater conveyance system.
However,the concern is that the area where the totes are being stored is not contained with berms or walls and storm
water is able to sheet flow from this area.The color of the pond water is also a concern.
Can you provide a more clear definition of what classifies as secondary containment and would the area I've described
qualify?
Thank you for your assistance with this.
Lauren Goyne
2

Environmental Specialist 11
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 1 2145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
TE {
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
From: Young, Brianna A<[e-mail]>
Sent: Monday, November 1, 2021 4:06 PM
To: Kay, Lily C<[e-mail]>; Goyne, Lauren M. <[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>;Thao,John <[e-mail]>; Chandler,
Jeffrey A<][e-mail]>
Subject: RE: [External] Thoughts/Questions about the Brenntag Inspection
CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Good afternoon,
The below condition is standard language in stormwater individual permits currently being issued.Would this language
address the concerns you have if Brenntag were to be issued a permit?
B-9. Secondary Containment Plan
In order to prevent leaks and spills from contaminating stormwater runoff, secondary containment is required
for: bulk storage of liquid materials including petroleum products; storage in any amount of water priority
chemicals listed in Section 313 of Title III of the Superfund Amendments and Reauthorization Act (SARA);
and storage of hazardous substances in any amount.
For facilities subject to the federal Spill Prevention, Control, and Countermeasure (SPCC)regulation, the SPCC
Plan may be used to support compliance with this requirement.
The Secondary Containment Plan shall include:
(a) A table or summary of tanks and stored materials equipped with secondary containment systems;
(b) Manually activated valves or other similar devices that are securely closed with a locking mechanism if
the secondary containment devices are connected to stormwater conveyance system;
(c) A commitment to visually observe any accumulated stormwater prior to release for color, foam, outfall
staining, visible sheens, and dry weather flow. Accumulated stormwater may be released if found to be
uncontaminated by any material. Accumulated stormwater found to be contaminated shall not be released
from the containment area;
(d) Records on every release from a secondary containment system that include: the individual making the
observation, a description of the accumulated stormwater, and the date and time of the release. These
records shall be kept for a period of five (5)years.
Brianna Young, MS (she/her)
Industrial Individual Permits Coordinator
3

Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.We appreciate your
patience as we continue to serve the public during this challenging time.
From: Kay, Lily C<[e-mail]>
Sent: Friday, October 29, 2021 10:46 AM
To: Goyne, Lauren M. <[e-mail]>;Young, Brianna A<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>;Thao,John <[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Subject: RE: [External] Thoughts/Questions about the Brenntag Inspection
Hey Brianna,
Lauren with Charlotte Stormwater Services has some questions below that would probably be best answered by the
permit writer. Can you help with this please?
Thanks,
Lily
From: Goyne, Lauren M. <[e-mail]>
Sent:Tuesday, October 26, 2021 12:35 PM
To: Kay, Lily C<[e-mail]>
Cc: Farmer, Richard L<[e-mail]>; Santiago, Matthew J.
<[e-mail]>;Thao,John <[e-mail]>; Chandler,
Jeffrey A<[e-mail]>
Subject: [External] Thoughts/Questions about the Brenntag Inspection
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Hello Lily,
I'm working on my inspection report for Brenntag and I have some questions. Really, I'm concerned about the dark
brown color of the pond and the evidence of spills/stains that we observed in the outdoor tote storage area on the
south side of the facility which drains to said pond.
Will the lack of secondary containment for the tote area (will they even be required to have secondary containment for
the totes?) be addressed in their permit or will they be allowed to use the pond as secondary containment for the tote
4

area and if so,what procedures will they need to follow before they are allowed to discharge that water to the
stormwater system?
My concern is that they are using that pond as pretreatment for spills and leaks from the tote area but they are only
testing the water for pH and doing a qualitative assessment before it's released. We don't know exactly what's in that
pond water or why it's so dark and we don't know if pond was installed for that purpose.
Any assistance or clarity you can provide would be greatly appreciated.
Thank you,
Lauren Goyne
Environmental Specialist 11
Charlotte-Mecklenburg Storm Water Services Water Quality Program
Mecklenburg County 12145 Suttle Avenue I Charlotte, NC 28208
[phone] 1 [e-mail] I StormWater.CharMeck.org
STORM
ATER
We are passionate about making our environment safe and healthy
by reducing flood losses and improving water quality for all.
5

Young, Brianna A
From: Young, Brianna A
Sent: Wednesday, October 27, 2021 3:22 PM
To: Dennis Martin/Mid-South/Brenntag; David Grenoble/Mid-South/Brenntag
Subject: RE: [External] Brenntag Charlotte Site Map
Thank you, Dennis. I will review and let you know if I need any further information.
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred during State of Emergency)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
Based on the current guidance to minimize the spread of COVID-19,the Department of Environmental Quality has adjusted
operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts.
To accommodate these staffing changes,all DEQ office locations are limiting public access to appointments only. Please check with
the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your
patience as we continue to serve the public during this challenging time.
From: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Sent: Monday, October 25, 2021 9:52 AM
To:Young, Brianna A<[e-mail]>; David Grenoble/Mid-South/Brenntag<[e-mail]>
Subject: [External] Brenntag Charlotte Site Map
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Get Outlook for iOS
From: [e-mail] <CharlotteMail Room @brenntag.com>
Sent: Monday, October 25, 2021 10:58:19 AM
To: Dennis Martin/Mid-South/Brenntag<[e-mail]>
Subject: Message from KM_287
SCAN FROM BRENNTAG CHARLOTTE
This communication and any documents accompanying this email transmission may be subject to the attorney-client
privilege or be considered attorney work product.
i

If you believe that you received this email in error, please do not read, copy, use or disclose this communication to
others; also please notify the sender by replying to this message, and then delete it from your system. Please verify that
you will delete the e-mail in your reply.Thank you.
NOTICE OF CONFIDENTIAL COMMUNICATION This communication and any subsequent electronic communication
relating to this matter, including any attachments, constitute an "electronic communication"within the meaning of the
Electronic Communications Privacy Act, 18 U.S.C.A. §2510 or any similar law of any other jurisdiction. In addition,this
and any subsequent electronic communication, and any attachments, may be subject to the attorney-client privilege or
be considered attorney work product.
This communication, and any subsequent electronic communication relating to this matter, including any attachments,
is CONFIDENTIAL and is intended solely for the addressee(s). If you are not an intended recipient, any use, review,
dissemination, or copying of any such communication by you is strictly prohibited. If you believe you have received this
or any other electronic communication in error, please do not read, copy, use or disclose it to others; also please notify
the sender by replying to the communication, and then delete it and all accompanying files from your system. Please
verify that you will delete the communication in your reply.
Please note that any views or opinions presented in this communication or any subsequent communication, including
any attachments, are solely those of the author or sender and do not necessarily represent those of Brenntag or its
affiliated companies. Neither Brenntag nor any of its affiliated companies accepts any liability for any damage caused by
any virus transmitted by any email or its attachments.
2

' I
_ 4
k
�1
�1 t
1
1 f i
1 R
Leaend }
cc
Storm Water Flow Direction
0
® Catch Basin _ -
a
m Culvert
m
o i ------- Buried Pipe
J 00
O
j O
f6 o Curb
d b _
a Trench
MT BRENNTAG SOUTHEAST,INC.
>2 N 11750 FRUEHAUF DRIVE
w a o — — — Ditch - = r CHARLOTTE, NORTH CAROLINA
z SPCC PLAN
N g _...—..._... Creek
o N Parcel Boundary SURFACE DRAINAGE
C¢Q' FIGURE
a 0 40 80 160 a N
j w 1 Sea:e in Feet -
U�C3

Brenntag — A History
9/21/18: Industrial Facility Inspection by Chad Broadway - The facility has a reverse osmosis
system that treats potable water for use in diluting Diesel Emission Fluid. The system discharges
filter backwash and/or general byproduct discharge from the treatment process to the facility's
stormwater basin, and ultimately to surface waters. This discharge represents an unpermitted
wastewater discharge and is a violation of local ordinance and North Carolina regulations. A
Notice of Violation was issued by NCDEQ-DWR on October 10, 2018.
The illicit discharge of filter backwash and/or process byproduct from the facility's reverse
osmosis system has been ceased. The facility has plumbed the discharge into one of the facility's
chemical secondary containment areas, which discharges to the facility's pretreatment system.
The site was non permitted and was informed that they should contact he NCDEQ Division of
Energy, Mineral, and Land Resources to determine if a National Pollutant Discharge Elimination
System(NPDES) industrial stormwater permit is required for this site.
3/12/20: Emergency Response -Matt Santiago and Hannah Meeler of Charlotte-Mecklenburg
Stormwater Services (CMSWS) responded to an emergency call regarding an accidental release
of sulfuric acid. According to facility personnel, a hose broke while transferring sulfuric acid
from a train car to storage containers at the facility. Approximately 300 to 500 gallons of
sulfuric acid was released onto the trailer parking area which is composed of crushed and rolled
gravel. CMSWS walked the creek on the other side adjacent to the berm. No evidence of the
sulfuric acid was observed migrating through the berm. An excavator was onsite later in the day
to remove and dispose of impacted gravel and re-grade the lot.
4/29/20: Emergency Response -Dave Ferguson responded to a reported spill and was informed
that a rail car carrying hydrochloric acid was being drawn down when a pipe burst, discharging
to the gravel lot at the rear of the property. An estimated 5000 gallons spilled and an unknown
quantity of acid had actually reached the stream resulting in a fish kill.
Ferguson worked with Ken Rhame of the Environmental Protection Agency and Wes Bell of
NCDENR on the spill response. A penalty of$550 was issued to Brenntag by CSWS.
10/19/21: Mr. John Thao, Mrs. Lauren Goyne, and Mr. Matt Santiago conducted a facility
penalty reinspection and industrial inspection of the Brenntag facility located on 11750 Fruehauf
Dr. Ms. Lily Kay and her associate with NC DEQ were also in attendance. No violation of the
storm water ordinance was observed. Ms.Kay instructed Brenntag to obtain a storm water permit
for the facility. Industrial storm water monitoring will be performed.
1/25/22: An administrative penalty in the amount of$16,900 was issued by the NC DEQ
hazardous waste section for improper labeling and product profiling of hazardous waste located
on site. This investigation was initiated on 1/22/2020. They were also fined $2638 for
investigation cost and required to pay a $1680 fee for acting as a hazardous waste storage
facility.

kv::= Charlotte-Mecklenburg
STORM 2145 Suttle Ave
WATER Charlotte, NC 28202
Services v
Summary of Stormwater Monitoring and Analysis
Facility: Brenntag Outfall
Sample Date: 2/23/22
Rain Event Total: 0.39" inches (CRN-21)
Industrial CMSWS NC Water
Parameter Units Outfall 001 Stormwater Permit Action Level Quality
Discharge Standard
Benchmarks/Limits (In-stream) (In-stream)
Temperature (°C) 16.3 32 -
Dissolved
(mg/L) 8.09 - 4.0
Oxygen
Conductivity (umho/cm) 206.0 550 -
pH 9.34 6.0—9.0 - 6.0 to 9.0
Fecal Coliform 1 OmL <100 1000 3000 200
E-Coli Bacteria 1 mpn/ <100 - - -
Total Suspended (mg/P 227 100 - -
Solids
Turbidity (NTU) 260 - - 50.0
Copper* (mg/L) 0.039 0.010 - 0.0036
Zinc* (mg/L) 0.270 0.126 - 0.036
Chromium (mg/L) 0.030 0.905 - 0.016
Lead* (mg/L) 0.008 0.075 - 0.014
Oil and Grease, (mg/L) <5 15 - -
and TPH
BOD (mg/L) 338 - 6.0 -
COD (mg/L) 880 120 - -
Yellow indicates exceedance of Permit Benchmark Value or a CMSWS Action Level.NC Water Quality
In Stream Standards are also shown as a reference.
*Monitoring data collected during this event is based on total recoverable metals.
The values for the Industrial Stormwater Permits Discharge Benchmarks and CMSWS Action Levels are
also based on total recoverable metals.The NC Water Quality Standard for in-stream is based on dissolved
metals with an assumed in-stream hardness value of 25 mg/L.
•
o' To report pollution or drainage problems, call: 311
http://stormwater.charmeek.org y`
CHAIROTTE

Charlotte-Mecklenburg
STORM 2145 Suttle Ave
WATER Charlotte, NC 28202
Services
Summary of Stormwater Monitoring and Analysis
Facility: Brenntag Outfall
Sample Date: 2/23/22
Rain Event Total: 0.39" inches (CRN-4521)
Industrial
Stormwater Permit NC Water
Discharge CMSWS Quality
Parameter Units Outfall 001 Benchmarks/Limits Action Level Standard
(NCGxx0000 (In-stream) (In-stream)
benchmarks/limits in
bold)
Temperature (°C) 16.3 32 -
Dissolved
(mg/I) 8.09 - 4.0
Oxygen
Conductivity (umho/cm) 206.0 550 -
pH 9.34 6.0-9.0 - 6.0to9.0
Fecal Coliform 1 OmL <100 1000 3000 200
E-Coli Bacteria 100 <100 - - -
Total Suspended (mg/L) 227 100 - -
Solids
Turbidity (NTU) 260 - - 50.0
Copper* (mg/L) 0.039 0.010 - 0.0036
Zinc* (mg/L) 0.270 0.126 - 0.036
Chromium (mg/L) 0.030 0.905 - 0.016
Lead* (mg/L) 0.008 0.075 - 0.014
Oil and Grease, (mg/L) <5 15 - -
and TPH
BOD (mg/L) 338 - 6.0 -
COD (mg/L) 880 120 - -
Yellow indicates exceedance of Permit Benchmark Value or a CMSWS Action Level.NC Water Quality
In Stream Standards are also shown as a reference.
*Monitoring data collected during this event is based on total recoverable metals.
The values for the Industrial Stormwater Permits Discharge Benchmarks and CMSWS Action Levels are
also based on total recoverable metals.The NC Water Quality Standard for in-stream is based on dissolved
metals with an assumed in-stream hardness value of 25 mg/L.
•
ohTo report pollution or drainage problems, call: 311
http://stormwater.charmeck.org : .'
C IARIATTF.-

kv::= Charlotte-Mecklenburg
STORM 2145 Suttle Ave
WATER Charlotte, NC 28202
Services v
Summary of Stormwater Monitoring and Analysis
Facility: Brenntag Pond
Sample Date: 2/23/22
Rain Event Total: 0.39" inches (CRN-21)
Industrial CMSWS NC Water
Parameter Units Outfall 001 Stormwater Permit Action Level Quality
Discharge Standard
Benchmarks/Limits (In-stream) (In-stream)
Temperature (°C) 16.5 32 -
Dissolved
(mg/L) 7.41 - 4.0
Oxygen
Conductivity (umho/cm) 27.5 550 -
pH 9.12 6.0-9.0 - 6.0to9.0
Fecal Coliform 1 OmL <100 1000 3000 200
E-Coli Bacteria 1 mpn/ 100 - - -
Total Suspended (mg/-) 46.4 100 - -
Solids
Turbidity (NTU) 60 - - 50.0
Copper* (mg/L) 0.034 0.010 - 0.0036
Zinc* (mg/L) 0.450 0.126 - 0.036
Chromium (mg/L) 0.007 0.905 - 0.016
Lead* (mg/L) <0.005 0.075 - 0.014
Oil and Grease, (mg/-) <5.0 15 - -
and TPH
BOD (mg/L) 171 - 6.0 -
COD (mg/L) 370 120 -
Yellow indicates exceedance of Permit Benchmark Value or a CMSWS Action Level.NC Water Quality
In Stream Standards are also shown as a reference.
*Monitoring data collected during this event is based on total recoverable metals.
The values for the Industrial Stormwater Permits Discharge Benchmarks and CMSWS Action Levels are
also based on total recoverable metals.The NC Water Quality Standard for in-stream is based on dissolved
metals with an assumed in-stream hardness value of 25 mg/L.
•
o' To report pollution or drainage problems, call: 311
http://stormwater.charmeek.org y'
CHAIROTTE

Charlotte-Mecklenburg
STORM 2145 Suttle Ave
WATER Charlotte, NC 28202
Services
Summary of Stormwater Monitoring and Analysis
Facility: Brenntag Pond
Sample Date: 2/23/22
Rain Event Total: 0.39" inches (CRN-4521)
Industrial
Stormwater Permit NC Water
Discharge CMSWS Quality
Parameter Units Outfall 001 Benchmarks/Limits Action Level Standard
(NCGxx0000 (In-stream) (In-stream)
benchmarks/limits in
bold)
Temperature (°C) 16.5 32 -
Dissolved
(mg/I) 7.41 - 4.0
Oxygen
Conductivity (umho/cm) 27.5 550 -
pH 9.12 6.0—9.0 - 6.0 to 9.0
Fecal Coliform 1 OmL <100 1000 3000 200
E-Coli Bacteria 100 100 - - -
Total Suspended
Solids (mg/L) 46.4 100 - -
Turbidity (NTU) 60 - - 50.0
Copper* (mg/L) 0.034 0.010 - 0.0036
Zinc* (mg/L) 0.450 0.126 - 0.036
Chromium (mg/L) 0.007 0.905 - 0.016
Lead* (mg/L) <0.005 0.075 - 0.014
Oil and Grease, (mg/-) <5.0 15 - -
and TPH
BOD (mg/L) 171 - 6.0 -
COD (mg/L) 370 120 - -
Yellow indicates exceedance of Permit Benchmark Value or a CMSWS Action Level.NC Water Quality
In Stream Standards are also shown as a reference.
*Monitoring data collected during this event is based on total recoverable metals.
The values for the Industrial Stormwater Permits Discharge Benchmarks and CMSWS Action Levels are
also based on total recoverable metals.The NC Water Quality Standard for in-stream is based on dissolved
metals with an assumed in-stream hardness value of 25 mg/L.
•
ohTo report pollution or drainage problems, call: 311
http://stormwater.charmeck.org : .'
CtIARIATTF.-

Nz STh7E'c.
ROY COOPER ,
Governor
ELIZABETH S.BISER ` w n
Secretary
BRIAN WRENN NORTH CAROLINA
Director Environmenta/Quality
August 15,2022
Brenntag Mid-South Inc.
Attn: Dennis Martin
11750 Fruehauf Drive
Charlotte, NC 28273
Subject: NOI Application NCGO81026
Brenntag Charlotte
Return#1336
Mecklenburg County
Dear Dennis Martin:
We received your application for an NPDES discharge permit on July 25, 2022. OnAugust 2, 2022,
Jeffrey Chandler with the Mooresville Regional Office conducted a site visit to determine whether
the facility was compliant with coverage under Stormwater General Permit NCG080000.
The industrial activities occurring onsite include diluting or repackaging various chemicals
(solvents,acids,bases) and for further distribution.The site also has diesel emission fluid via rail
car or tanker truck.A previous inspection conducted on October 19w,2021,ended with a
recommendation that this site is best suited for an individual permit.Therefore,it has been .
concluded that the industrial activity of this facility does not qualify for coverage under General
Permit NCG080000:Transit and Transportation.
With this letter,your application is being returned to you.To properly secure adequate stormwater
permit coverage,your next permitting step is for you to apply for an Individual Industrial
Stormwater Permit. This type of permit coverage can best be tailored to an industrial operation
such as Brenntag Charlotte.
Please visit our website at deq.nc.gov/SW-industrial for more information on the application for an
Individual Industrial Stormwater Permit,guidance,and related documents. Please respond to this
correspondence by submitting an individual stormwater permit application to this office within 90
days for the date of this letter.
Please contact Brianna Young,the Stormwater Individual Permit Coordinator, at 919-707-3647 or
via email at Brianna.Young(@ncdenr.gov for further guidance concerning individual permits.
Qom,- North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
'PI
512 North Salisbury Street 11612 Mail Service Center I Raleigh,North Carolina2 76 9 9-1612
3icsNc aa.D' !�
919.707,9200

Sincerely,
for Brian Wrenn, Director
Division of Energy, Mineral,and Land Resources
cc: Mooresville Regional Office/Z. Khan
Q;v North Carolina Department oFEnvironmental Quality I Division of Energy,Mineral and land Resources
r� 4'�yn 512 North Salisbury street 1 1612 Mail Service Center I Raleigh.North Carolina 27699-1612
479.797.9200