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Home My WebLink AboutNCS000551_Historical File_20110531Pickle, Ken From: Hall, Mandy Sent: Tuesday, June 14, 2011 2:57 PM To: Pickle, Ken Cc: Bennett, Bradley; Smith, Danny; Higgins, Karen Subject: RE: Brenntag stormwater permit application submittal Hi Ken, Thanks for looking over this so quick! The Progress Report is an extra copy and you are welcome to keep it. The history and analytical data may be helpful when you guys are writing the permit. The Permit App. is an extra, too. Call me with questions! Mandy Tingen Hall WWTP Consultant NCDENR-DWQ-SWP 919-791-4254 P 919-788-7159 F 3800 Barrett Drive Raleigh NC 27609 www.ncwaterguality.org Fine Print: E-mail correspondence to and frorn this address may be subject to the North Carolina Public Records Law and may be disclosed to third pail ies. From: Pickle, Ken Sent: Tuesday, June 14, 2011 2:53 PM To: Hall, Mandy Cc: Bennett, Bradley; Smith, Danny; Higgins, Karen Subject: Brenntag stormwater permit application submittal Mandy, Looks like the Brenntag stormwater permit application is sufficiently complete for us to process it, and the Final Report seems compliant with the SOC as far as my cursory review can tell. Attached written screening review summary was an exercise for me to be sure I remembered all that had happened before on Brenntag, and a sort of record for whoever in our unit winds up with this application. Are all these documents for us, or do you want some of them back? • Permit Application, 5/31/2011 • Final Report and Progress Account, 5/31/2011 1 Page 1 of 3 Brenntag stormwater permit application screening review 6/14/2011, kbp Tasks: review submittal for compliance with SOC requirements; screening review for complete permit application submittal. Task results: communication to BB and Mandy Hall review results. Background file review • 11/30/94 - As authorized by 40CFR122.26(a)(1)(v), the Director of the Division of Environmental Management designates SouthChem for a stormwater permit based on RRO determination that the site contributes pollutants to Jordan Lake. Subsequent correspondence in 1998 suggests the facility may never have been permitted, and raises the question of whether the several rectangular concrete basins constitute a treatment system and how that may play into the determination of a ww or sw discharge. • Sept 2004 - Internal DWQ correspondence suggests the facility should get an NPDES ww permit based on the operation of a treatment works. • June 2005 - Internal DWQ determination that the Brenntag site should seek a ww permit, not a stormwater permit. June 2008 RRO NOV. Meeting with Brenntag and DWQ August 2008. EAA submitted to DWQ November 2008. Meeting with Brenntag January 2009. Feb 2, 2009 RRO directs Brenntag to seek an SOC with enforcement schedule. March 2009 SOC application received. • October 18, 2010 - A revised version of the SOC, labeled Ad 1, is signed by B, and in effect. SOC review • SOC requires B to segregate sw and ww; evaluate the feasibility of sending the ww to Durham's POTW; to implement a SPPP; sample the basin outfalls; sample the process waters under pump and haul disposal; submit quarterly monitoring results; • And, by 11/30/10 reroute roof drains, extend canopy, eliminate deep shear gate system, and reroute truck loading area away from the deep shear gate system. • NLT 5/31/2011 B must submit stormwater permit application and final report and progress account. • B must submit quarterly progress reports of the work and activities under the SOC to RRO and to the NPDES unit. • B may continue to Pump and Haul wastewater up until June 30, 2011. If beyond, B must reapply (I guess there is no assurance City of Durham POTW will accept.) • Attachment A: SPPP due to RRO and to SPU NLT April 18, 2011. KBP review of SPPP in October 2010 indicated minor quibbles, but generally ok. • Attachment B Monitoring Schedule; o Stormwater • 2/mo for TSS, O&G, pH, conductivity, COD, BOD5, NH3, TKN. Monthly for: EPA 624, EPA 625, 13 heavy metals Page 2 of 3 ■ 10/10 thru 2/11 and four consecutive months after facility retrofits (Nov 2010, Dec, Jan, Feb, Mar 2011) o Wastewater: ■ Same parameters as stormwater, but different frequencies. • Samples collected from the 20,000 g holding tank; ■ No discharges allowed; • Sample period is for 6 consecutive weeks after facility retrofits are accomplished, presumably NLT 11/30/2010. Final Report and Progress Account review • May 31, 2011 publication • Chapter 2, Facility retrofits: cursory review, no comments. Did not check to see if the retrofits were consistent in details with the SOC retrofit requirements, presume they're close enough. • Chapter 3, p. 6. Note that B has been monitoring on the basis of a representative storm event, defined in part as 0.1" or greater. The new permit will likely include the revised requirement of a `measurable discharge', as the qualifying rain event. • Ch. 4 Stormwater Monitoring activities. o Note that the monitoring data included for stormwater in Table 2 DOES NOT capture the runoff from the very significant area of the facility roof, which bypasses the sampling point. While the monitoring location used for the SOC may have captured the flows suspected of having the greatest risk of contamination, that suspicion is unconfirmed by testing, since the other flows weren't tested. Any future stormwater permit will require the sampling of all stormwater discharge points. o 4.1: note that the final report claims that the samples were analyzed by EPA Methods - however, the EPA method for pH has a 15 minute hold time - overnight shipping to the lab in Savannah, Georgia most certainly did not comply with the hold time requirement of the EPA method. Too bad that while they were field testing for turbidity, they didn't think to also do a field test for pH. o Table 2 - results of the sampling of stormwater and 'non-stormwater'. Note that the table highlights the sample values that exceed water quality standards. This information is helpful, but a better comparison would have been with the likely stormwater permit benchmarks. Note that zinc and copper values routinely exceeded the stormwater benchmarks, and that B did not test to the appropriate MDL for mercury and silver. • Ch 5 Process water monitoring. No comments. Limited relevance to stormwater. • Ch 6 Durham City water. SPU to evaluate the proposition that city water might be influencing stormwater content for heavy metals and organics. My initial suspicion is that the volume of stormwater so far outweighs that of city water that it's unlikely that city water is affecting stormwater concentrations to any significant extent. Page 3 of 3 • Ch 7 Possibility of discharging process water to Durham POTW. No comments. • Ch 8 Summary and Conclusions. All conclusions as to the source and significance of organics, metals, BOD/COD in stormwater will be reviewed subject to re -interpretation as we process the permit application. No further comment now. Application screening review • Check: check. • EPA 1: Acceptable signature • EPA 2F: Sufficient, even if incomplete in minor ways. Summary & indicated action • Appears compliant with the SOC • Application sufficiently complete to process • OK to process the application. END Pickle, Ken From: Hall, Mandy Sent: Monday, June 13, 2011 1:22 PM To: Pickle, Ken Subject: RE: Brenntag SP3 No problemo Mandy Hall DWQ-RRO WWTP Consultant 919-7914254 email is public record & may be viewed by third parties.... Pardon any errors ... sent from my phone! From: Pickle, Ken <ken.pickle@ncdenr.gov> Sent: Monday, June 13, 2011 1:21 PM To: Hall, Mandy <mandy.hall@ncdenr.gov> Cc: Bennett, Bradley <bradley.bennett@ncdenr.gov> Subject: RE: Brenntag SP3 Thanks, Mandy. That helps me know.that I don't need to look at the SPPP, again. It's obviously lost in my office somewhere. I'll find it. Ken From: Hall, Mandy Sent: Monday, June 13, 2011 1:15 PM To: Pickle, Ken Subject: FW: Brenntag SP3 Maybe this will help..... Mandy Tingen Hall WWTP Consultant NCDENR-DWQ-SWP 919-791-4254 P 919-788-7159 F 3800 Barrett Drive Raleigh NC 27609 www.ncwaterguality.org Dine Print: Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties. 1 From: Pickle, Ken Sent: Wednesday, October 13, 2010 12:35 PM To: Pickle, Ken; Hall, Mandy Cc: Bennett, Bradley; Sullivan, Shelton; Smith, Danny Subject: RE: Brenntag SP3 I've performed a cursory review, and I have the following comments. I have an unsigned copy of the SOC, and I note that item 2.(6) requires them to submit an application for an individual stormwater permit by September 30, 2010. We don't have their application as of today. I don't have a copy of the signed SOC, so the final form may be different from my copy. Here are my comments on the SPPP. Transmittal letter and SPPP signature page — signed by the consultants; but I don't see anywhere that Brenntag has signed this document. 1.1—Site Description — generally ok. But, a. As noted above there will be a stormwater discharge from this facility. Unless conditions of the SOC were revised differently from my copy, I would expect this facility to apply for a stormwater discharge permit from SPU. b. Just a caution - - See p.3, 'Since the first two components of the facility's stormwater collection and conveyance system do not come into contact with processing areas, product loading/unloading areas, and/or outdoor storage areas; they are not considered a source of potential contamination of the surface water.' Granted, these flows may no longer qualify as wastewaters. But, we want to be careful about 'they are not considered a source of potential contamination of the surface water.' A gratuitous statement that might be interpreted as indicating that this discharge should not be, what?Regulated? Permitted? Should not be worth further consideration? - - These are exactly and specifically the kinds of flows from an industrial activity site that the NPDES stormwater program is intended to address. Manufacturing facilities, and this one in particular, are notoriously sloppy and routinely unsuccessful in preventing their manufacturing materials from 'accidentally' getting into stormwater. From inspection of SPPP Figure 5, 1 note that all three collection systems could have flows that qualify as from areas with the potential for stormwater pollution. It worries me that apparently the consultants/owner don't get this basic premise of the stormwater program. The key 'conversion of the heart' intended in the stormwater program is to get site managers to appreciate their responsibility to control potential sources of stormwater pollution. That's hard to do, if in your 'stormwater system operating manual' — the SPPP, you just blow off as inconsequential the flows from a third of your site. c. p. 4 & 5-both the lubricant tank farm and lubricant packaging areas have containment area drains that drain to an o/w separator, and from there to the stormwater outfall. We have here two open -sided but roofed and contained process areas with sumps for petroleum spills that drain through the o/w to the stormwater discharge. While it is common for the AST farm (covered and contained as per other AST provisions in our program), it is a bit unusual for the other straight -up, under roof, industrial processing area to have a floor drain to the stormwater system, (even if through an o/w.) Especially when you note that the immediately adjacent tank truck transfer area is uncovered and provided with dry sumps that are manually pumped out, i.e. not connected to the nearby o/w separator. Not sure that we can insist on any remedial action here, but it strikes me as a risky arrangement. Ken From: Pickle, Ken Sent: Tuesday, October 12, 2010 1:48 PM To: Hall, Mandy Cc: Bennett, Bradley Subject: RE: Brenntag SP3 Thanks, Mandy. I'll give it a cursory scan, and then file it in our SPU files. Ken From: Hall, Mandy Sent: Tuesday, October 12, 2010 1:05 PM To: Pickle, Ken Subject: Brenntag SP3 Hi Ken, I put a copy of the SP3 from Brenntag in Interoffice Mail.... Thanks Mandy Tingen Hall WWTP Consultant NCDENR-DWQ-SWP Raleigh Regional Office 1628 Mail Service Center Raleigh, NC 27699-1628 919-791-4254 Ph 929-788-7159 Fax www. ncwaterguality.org _ ARCADIS Infrastructure, environment, buildings Am Final Report and Progress Account, Stormwater Evaluation (April 2010 through March 2011) Brenntag Southeast Facility 2000 Fast Pettigrew Street Durham, North Carolina Special Order by Consent SOC No. S09-006 May 31, 2011 Imagine the result ARCADIS Final Report and Progress Account, Stormwater Evaluation (April 2010 through March 2011) Brenntag Southeast Facility 2000 East Pettigrew Street, Dave Twamley, L.G. Durham, North Carolina Staff Scientist Special Order by Consent SOC No. S09-006 Preparedfor James E. Shilliday, III, L.G. Brenntag Southeast, Inc. Principal Scientist/Project Manager Prepared by: ARCADIS G&M of North Carolina, Inc. 801 Corporate Center Drive Suite 300 Raleigh North Carolina 27607 Tel 919.854.1282 Fax 919.854.5448 Our Ref.: _. NC105024.0007 Date: May 31, 2011 This document is intended only for the use of the individual or entity for which it was prepared and may contain information that is privileged, confidential and exempt from disclosure under applicable law. Any dissemination, distribution or copying of this document is strictly prohibited. ARCADIS 1. Introduction 2. Facility Retrofits 2.1 Re -Routing of Roof Drains 2.2 Elimination of the Deep Sheer Gate System 2.3 Reconfiguration of Conveyance for Outside Storage Area Drainage 2.4 Extension of Canopy at Acid/Base Containment Area 3. Rainfall, Detention Basin Freeboard, and Discharge Monitoring Activities 4. Stormwater Outfall Monitoring Activities 4.1 Sampling Procedures and Analyses 4.2 Stormwater and Non-Stormwater Sample Analytical Results 5. Industrial Process Water Monitoring Activities 5A Sampling Procedures and Analyses 5.2 Industrial Process Water Sample Analytical Results 6. Durham City Water Sampling Activities 6.1 Durham City Water Sample Analytical Results 7. Feasibility of Routing industrial Process Water to City of Durham Sanitary Sewer 8. Summary and Conclusions 8.1 VOCs and SVOCs in Stormwater/Non-Stormwater Samples 8.2 Metals in Stormwater/Non-Stormwater Samples 8.3 BOD and COD in Stormwater/Non-Stormwater Samples 8.4 Potential Source of Elevated Metals and BODICOD for Stormwater/Non- Stormwater Samples 9. Recommendations 10. References 1 3 3 4 4 5 6 7 7 8 10 10 11 12 12 14 15 15 16 16 17 19 20 Table of Contents ARCADIS Tables Table 1 Summary of Daily Rainfall Totals, Detention Basin Freeboard Measurements, Stormwater 1 Nan-Stormwater Sampling Activities, and Discharge Record Table 2 Summary of Stormwater 1 Non-Stormwater Sample Analytical T_ Results from Detention Basin 94 Table 3 Summary of Industrial Process Water Accumulation, Sampling, and Disposal Information Table 4 Summary of Industrial Process Water Sample Analytical Results from Above Ground Storage Tank Table 5 Summary of Durham City Water Sample Analytical Results Figures Figure 1 Stormwater Site Plan (Pre-existing Conditions Prior to Facility Retrofits) Figure 2 Stormwater Site Plan (Facility Retrofits Completed March 2010 through October 2010) Figure 3 Stormwater Site Plan (Existing Conditions — March 2011) Figure 4 Stormwater Site Plan (Sample Collection Locations) Appendices A Facility Retrofit Photo Log Table of Contents ARCADIS 1. Introduction Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) ARCADIS is pleased to submit this Final Report and Progress Account on behalf of Brenntag Southeast, Inc. (Brenntag), in accordance with the provisions of the Special Order by Consent (SOC), SOC No. S09-006 Section 2.b executed by the North Carolina Department of Environment and Natural Resources (NCDENR), Division of Water Quality (DWQ) on April 8, 2010 (NCDENR, 2010). This report summarizes the activities that were completed during the duration of the SOC from April 2010 through March 2011. Quarterly Progress Reports summarizing the activities that were completed during the periods of April through June 2010, July through September 2010, October through December 2010, and January through March 2011, were previously submitted to the DWQ (ARCADIS, 2010a; ARCADIS, 2010b; ARCADIS, 2011 a, and ARCADIS, 2011b). In addition to this introduction, this report consists of the following sections: • Section 2, Facility Retrofits — this section provides a detailed description of the modifications and upgrades to the facility's stormwater conveyance system. • Section 3, Rainfall and Freeboard Monitoring Activities — this section documents the procedures and results of rainfall and stormwater detention/containment basin freeboard monitoring conducted from April 2010 through March 2011. • Section 4, Stormwater Monitoring Activities — this section discusses the procedures and results of the stormwater and non-stormwater sampling activities conducted from April 2010 through March 2011. • Section 5, Industrial Process Water Monitoring Activities —this section discusses the procedures and results of the industrial process water sampling activities conducted in November 2010 and December 2010. • Section 6, Durham City Water Sampling Activities —this section provides a discussion of the results of the Durham city water sampling activities conducted in January 2011. • Section 7, Feasibility of Routing Industrial Process Water to City of Durham Sanitary Sewer— this section discusses the feasibility of utilizing the City of Durham sanitary sewer system as a means to dispose of process/industrial wastewater generated at the site. ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) • Section 8, Summary and Conclusion -- this section summarizes the analytical results for the various sampling activities completed in accordance with the SOC from April 2010 through March 2011, and provides conclusions drawn from those analytical results. • Section 9, Recommendations — this section presents recommendations for specific revised facility operational procedures to address impacts to stormwater. • Section 10, References —provides citations for reference materials used in the preparation of this report. 2 ARCADLS 2. Facility Retrofits Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) As established in the SOC, Brenntag agreed to complete upgrades to the facility's stormwater conveyance system in order to substantially eliminate process water inputs to the system and to reduce the volume of stormwater that discharges into the detention/containment basins. The majority of the facility retrofits were completed in March 2010 including: re-routing of roof drains, elimination of the deep shear gate system and its components, and reconfiguration of the conveyance lines in the truck loading area. The final facility retrofit, which involved extending the canopy in the Acid/Base Containment Area over a section of the processing and handling area, was completed in October 2010. A site plan showing the components of the pre-existing stormwater conveyance system (i.e. prior to the facility retrofits) is presented on Figure 1. The completed facility retrofits are illustrated on Figure 2, and a stormwater site plan that depicts the current site conditions as of March 2011 is presented in Figure 3. Photos of the completed facility retrofits are included in Appendix A. 2.1 Re -Routing of Roof Drains Previously, the majority of the main building roof drain system collected stormwater in a conveyance pipe that was suspended from the ceiling inside the building. The overhead conveyance pipe then discharged to an underground line which conveyed the roof drain water to the deep sheer gate system and then into the stormwater detention basins as depicted in Figure 1. If the detention/containment basins were at full capacity, then roof drainage would back up into the area surrounding the former deep sheer gate and have the potential to comingle with process water and other non- stormwater sources onsite. In March 2010 Brenntag completed modifications to the roof drain conveyance system so that it now discharges into the stormwater conveyance line located along the southern perimeter of the facility (Figure 2), outside of the processinglstorage areas. This modification consisted of the following: • Abandoning the existing underground drainage line that connected the roof drains to the Deep Shear Gate by filling the line with grout. • Installing new overhead PVC piping for the roof drains, connecting the overhead piping to the existing roof drains, and tying the new roof drain line into the stormwater conveyance line near MH #5 immediately north of the rail line tracks (see Figure 2 and photos in Appendix A). ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) The modifications were successful in re-routing rooftop stormwater sheet flow into the perimeter stormwater conveyance line, thus bypassing the abandoned Deep Shear Gate and onsite stormwater detention basins, and then discharging directly into the unnamed creek. 2.2 Elimination of the Deep Sheer Gate System A stormwater evaluation, completed as part of an Engineers Alternatives Analysis (ARCADIS, 2008) of the facility, identified the deep shear gate system as a contributor of non-stormwater inputs to the stormwater system. The evaluation concluded that impacted groundwater was infiltrating the sub -surface conveyance line of the deep sheer gate system. Furthermore, the evaluation determined that during heavy rain events the system would surcharge and overflow from the deep shear gate system's upstream catch basin (SW-3), and into the stormwater system at catch basin SW-4 (Figure 1). Thus, potentially impacted water from the deep shear gate system would overflow and discharge into the detention basins. In March 2010, the conveyance piping and catch basins associated with the deep sheer gate system were abandoned in place. The abandoned catch basins, the deep sheer gate, and approximately 720 linear feet of conveyance line piping were filled with aggregate and permanently grouted as part of this retrofit (see Figure 2 and photos in Appendix A). In addition, a pumping system was installed in an existing vault inside the facility (a former component of the deep sheer gate system beneath the main building) to s facilitate the collection and removal of groundwater that may potentially accumulate in that area (see Figure 2 and photos in Appendix A). The collected groundwater is now pumped into an above grade conveyance line to the equalization basin, via the overhead caustic conveyance line (designated OHC), where it is subsequently handled as process water (Figure 2). Installation of the caustic area sump -pump system and modifications to the OHC line were completed in March 2010. 2.3 Reconfiguration of Conveyance for Outside Storage Area Drainage Part of the abandonment activities for the deep sheer gate conveyance system included disconnecting the catch basin designated as SW-8. The catch basin is now utilized as a sump for collection of runoff originating in the outside storage area south ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) of the main building. Two sump pumps were installed inside the catch basin and approximately 170 linear feet of a new subsurface conveyance line was installed to route water which accumulates in the sump to the existing on -site stormwater conveyance line that discharges to the detention basins (see Figure 2 and photos in Appendix A), Modifications to the catch basin/sump and the outside storage area conveyance system were completed in March 2010. 2.4 Extension of Canopy at Acid/Base Containment Area The trench drain collection system located in the acid tank area was designed to contain any releases in this area by conveying water directly to the facility's equalization basin. Liquid that accumulates in the equalization basin is neutralized and then pumped to a 20,000 gallon wastewater AST, and the process water in the AST is periodically hauled off by a contractor for offsite treatment and disposal. Prior to retrofitting, a portion of the acid area trench drain system was exposed to the elements, allowing stormwater to enter the facility's waste stream (see Figure 1). During heavy rain events the trench drain system would surcharge and overflow into the stormwater collection and conveyance line directly north of the trench drain (catch basins designated SW-4, SW-7, and SW 9). Thus, potentially impacted water would overflow and discharge into the stormwater detention basins. In October 2010, the roof canopy in the Acid/Base Containment Area was extended in order to cover the trench drains located in the processing and handling portion of the Acid/Base Containment Area that had previously been exposed (Figure 2). This retrofit successfully reduced the volume of rainwater entering the acid area trench drains and equalization basin and minimized the potential for impacted process related water from entering the stormwater system. ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) 3. Rainfall, Detention Basin Freeboard, and Discharge Monitoring Activities In order to monitor the rainfall at the facility, a rain gauge was installed on April 23, 2010. Rainfall measurements, detention basin freeboard levels, and an account of outfall releases from the basins are documented on a daily basis (excluding weekends and holidays) by Brenntag personnel. In addition to the rainfall data collected from the on -site rain gauge, daily rainfall data is also retrieved from the North Durham Water Reclamation Facility (DURH), which is located approximately 3.5 miles north of the Brenntag facility. The DURH gauging station is one of several North Carolina Environment and Climate Observing Network (ECONet) stations, which collect and record hourly weather and environmental conditions using automated sensors. The T data is uploaded to a database and tracked through the State Climate Office of North Carolina's website (http:/Awm.nc-climate.ncsu.edu/cronos/?station=DURH). The results of the rainfall, detention basin freeboard, and outfall monitoring activities conducted from April 2010 through March 2011 are presented on Table 1. Daily rainfall data retrieved from the DURH station is used to determine if a representative storm event has occurred in the area. Prior to sampling, data from the on -site rain gauge is used to confirm that the criteria for a representative storm event have been met at the facility. A representative storm event is defined in Attachment B of the SOC as a storm event that measures greater than 0.1 inches of rainfall and is preceded by at feast 72 hours in which no rainfall event measuring greater than 0.1 inches has occurred (NCDENR, 2010). The details of the stormwater outfall monitoring and sampling program are discussed in the following section. ARCADIS 4. Stormwater Outfall Monitoring Activities Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) Stormwater outfall monitoring activities were conducted at the facility in accordance with the requirements outlined in Attachment B of the SOC. As per the SOC, 4 months of stormwater and non-stormwater sampling was conducted prior to completion of the facility retrofits (April through July 2010). The facility retrofits were completed in October 2010 and the second required 4 month period of stormwater and non- stormwater sampling was initiated in November 2010 and completed in March 2011. A summary of the analytical results for the 16 stormwater and 6 non-Stormwater sample collection events conducted under the SOC between April 2010 and March 2011 is provided in Table 2. Stormwater sampling was conducted within a 24 hour period following a representative storm event at the facility. Nan-stormwater discharge samples were also collected prior to any discharge of water that had accumulated in the basins that was not coincident to and representative of a storm event as defined in the SOC. The stormwater and non-stormwater sampling activities completed between April 2010 and March 2011 fulfill all the requirements for stormwater outfall sampling as presented in Attachment B of the SOC. This includes the requirement to conduct two separate non- stormwater sampling events greater than, or equal to, 7 days following a representative storm event (non-stormwater samples from November 15, 2010 and March 23, 2011 met that requirement). The sampling procedures, analyses performed, and analytical results from the monitoring activities are discussed below. 4.1 Sampling Procedures and Analyses Stormwater and non-stormwater grab samples were collected directly from the last of four stormwater detention basins from the sample location designated as "outfall", as depicted on Figure 4. All water samples were collected into appropriately labeled containers, packed on ice in a cooler, and shipped to the analytical laboratory. Samples collected in the field remained in the presence of a project representative until delivery to the laboratory. Each cooler containing water samples included a completed chain -of -custody form to maintain a record of personnel that had contact with the samples. Samples were shipped for overnight delivery to Test America, Inc. in f ' Savannah, Georgia, via Federal Express. Samples were submitted for the full suite of laboratory analyses as required by the SOC including: total suspended solids (TSS) by Standard Method 2540D, oil and grease by United States Environmental Protection Agency (USEPA) Method 1664A, ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) pH by USEPA Method 150.1, conductivity by USEPA Method 120.1, total and dissolved chemical oxygen demand (COD) by USEPA Method 410.4, total and dissolved biochemical oxygen demand (BOD) by USEPA Method 405.1, total and dissolved organic carbon (TOC and DOC) by USEPA Method 415.1, ammonia by USEPA Method 350.1, total kjeldahl nitrogen (TKN) by USEPA Method 351.2, volatile organic compounds (VOCs) by USEPA Method 624, semi -volatile organic compounds (SVOCs) by USEPA Method 625, total priority pollutant metals (antimony, arsenic, beryllium, cadmium, copper, chromium, lead, mercury, nickel, selenium, silver, thallium, and zinc) by USEPA Method 200.8, and mercury by USEPA Method 245.1. In addition, an aliquot of water was collected and field tested for turbidity by USEPA Method 180.1 using a portable turbidimeter. 4.2 Stormwater and Non-Stormwater Sample Analytical Results The analytical results for stormwater and non-stormwater samples collected in April 2010 through March 2011 (Table 2), indicate that several VOCs were detected in the samples at relatively low concentrations including: acetone, bromodichloromethane, chloroethane, chloroform, 1,1-dichloroethane, toluene, 1,1,1-trichloroethane, trichloroethene, and vinyl chloride. Three VOCs (bromodichloromethane, chloroform, and vinyl chloride) were detected in the stormwater samples at concentrations that exceeded surface water standards, and five VOCs (chloroethane, chloroform, toluene, trichloroethene, and vinyl chloride) were detected in the non-stormwater samples at ^• concentrations that exceeded surface water standards (see Table 2). No SVOCs were detected in any of the stormwater or non-stormwater samples collected between April 2010 and March 2011. Total nitrogen and ammonia were detected at low concentrations in a majority of the samples collected in April 2010 through March 2011. In general, the SOD and COD results for the samples collected between April 2010 and March 2011 were relatively low. The BOD results for the 22 samples collected between April 2010 and March 2011 ranged from 2.1 milligrams per liter (mg/L) to 170 mg1L (see Table 2), with an average concentration of 22.1 mg/L. The COD results for the 22 samples collected between April 2010 and March 2011 ranged from 20 mg/L to 340 mg/L (see Table 2), with an average concentration of 70.4 mg/L. Elevated concentrations of two metals (zinc and copper) were also detected in the stormwater and non-stormwater samples at concentrations that exceeded the surface water standards for those two compounds; however, these concentrations are very consistent with the concentrations of zinc and copper detected in the facility's potable water supplied by the City of Durham. ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) Overall, the stormwater and non-stormwater sample analytical data continue to indicate that the water that is accumulating in the detention basins is primarily not impacted with VOCs or SVOCs that could be associated with chemicals that are handled or stored at the site. This applies to water accumulating during rain events and water accumulating during periods without rain. The low concentrations of VOCs that have been detected in the stormwater and non-stormwater samples may however be associated with some degree of groundwater and/or Durham city water infiltration into the stormwater system. VOCs that were detected in the stormwater and non- stormwater samples also have been detected in the groundwater at the site, and two of the VOCs (bromodichloromethane and chloroform) have been detected in the Durham city water samples collected from the site. In addition, elevated concentrations of zinc and copper detected in the stormwater and non-stormwater samples would appear to be associated with infiltration of Durham city water into the stormwater system as these two metals have been detected at similar concentrations in Durham city water samples collected from the site. 9 ARCADIS 5. Industrial Process Water Monitoring Activities Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) y. Industrial process water monitoring activities were conducted at the facility in November and December 2010 in accordance with the requirements outlined in Attachment B of the SOC. As per the SOC, 6 weeks of process water sampling was conducted following completion of the facility retrofits. The facility retrofits were completed in October 2010 and the required 6 week period for process water sampling occurred from November 1 through December 12, 2010. A total of six process water samples were collected during this time period. A summary of the industrial process water accumulation, sampling, and disposal information for the period of November 2010 through March 2011 is provided in Table 3. A summary of the analytical results for the process water sample collection events conducted in November through December 2010 is provided in Table 4. The sampling procedures, analyses performed, and analytical results from the industrial process water monitoring activities are discussed below. 5.1 Sampling Procedures and Analyses Industrial process water sampling activities were conducted on November 4, 12, 19, 23, and December 1 and 8, 2010. The sampling events consisted of collection of grab samples directly from a spigot located on the 20,000 gallon AST from the sample location designated as "Process Water", as depicted on Figure 4. The AST is used to 4 store the facility's process water prior to the water being shipped offsite for disposal. All water samples were collected into appropriately labeled containers, packed on ice in a cooler, and shipped to the analytical laboratory. Samples collected in the field remained in the presence of a project representative until delivery to the laboratory. Each cooler containing water samples included a completed chain -of -custody form to maintain a record of personnel that had contact with the samples. Samples were shipped for overnight delivery to Test America, Inc. in Savannah, Georgia, via Federal Express. Samples were submitted for a range of laboratory analyses as prescribed in the SOC including: total suspended solids (TSS) by Standard Method 2540D, oil and grease by United States Environmental Protection Agency (USEPA) Method 1664A, pH by USEPA Method 150.1, conductivity by USEPA Method 120.1, total and dissolved chemical oxygen demand (COD) by USEPA Method 410.4, total and dissolved biochemical oxygen demand (BOD) by USEPA Method 405.1, total and dissolved organic carbon (TOC and DOC) by USEPA Method 415.1, ammonia by USEPA Method 350.1, total kjeldahl nitrogen (TKN) by USEPA Method 351.2, volatile organic 10 ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) compounds (VOCs) by USEPA Method 624, semi -volatile organic compounds (SVOCs) by USEPA Method 625, total priority pollutant metals (antimony, arsenic, beryllium, cadmium, copper, chromium, lead, mercury, nickel, selenium, silver, thallium, and zinc) by USEPA Method 200.8, and mercury by USEPA Method 245.1. In addition, an aliquot of water was collected and field tested for turbidity by USEPA Method 180.1 using a portable turbidimeter. 5.2 Industrial Process Water Sample Analytical Results The analytical results for the industrial process water samples collected in November and December 2010 (Table 4), indicate that several VOCs and SVOCs were detected in the samples at low to moderate concentrations including: acetone, bromomethane, chloroform, chloromethane, tetrachloroethene, phenol, and bis(2-ethylhexyl)phthalate. As seen in Table 4, total nitrogen and ammonia were detected at very high concentrations in three of the four samples that were analyzed for those compounds. The BOD results for the four samples that were analyzed for BOD were all consistently very high ranging from 3,100 mg/L to 9,600 mg/L. The COD results for the four samples that were analyzed for COD also were all consistently very high ranging from 10,000 mg/L to 12,000 mg/L. Highly elevated concentrations of several metals were detected in the process water samples including: chromium, zinc, copper, and nickel. 11 ARCADIS 6, Durham City Water Sampling Activities Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) Durham city water sampling activities were conducted at the facility in January 2011. While not required by the SOC, samples of the Durham city water supply at the facility were collected to assist in the evaluation of the quality of the city water that is utilized onsite at the facility. A total of four city water samples were collected on January 7, 2011. The samples were collected from spigots at four locations across the facility (Figure 4). Three of the four city water samples were analyzed for metals only, and one of the city water samples was analyzed for the full suite of analytical parameters to match the suite of analytical parameters used for the stormwater and non-stormwater samples. A summary of the analytical results for the Durham city water samples collected on January 7, 2011 is provided in Table 5. 6.1 Durham City Water Sample Analytical Results The analytical results for the city water samples collected on January 7, 2011 indicate that the city water contains several compounds that are also being detected in the stormwater and non-stormwater samples, and the concentrations of these compounds are very similar to those detected in the stormwater and non-stormwater samples. Two VOCs (bro mod i chloro methane and chloroform) were detected in the city water sample which was submitted for the full suite of analyses. The VOCs were detected at concentrations exceeding surface water standards (see Table 5). These same two VOCs have been detected in stormwater and non-stormwater samples at similar concentrations (see Table 2). In addition, the city water sample which was submitted for the full suite of analyses contained concentrations of ammonia and total nitrogen similar to those detected in the stormwater and non-stormwater samples (see Table 2 and Table 5). Elevated concentrations of metals (zinc and/or copper) were detected in all four of the city water samples. The concentrations of copper detected in the city water samples exceeded the surface water standard for copper in two of the four city water samples, and the concentrations of zinc detected in the city water samples exceeded the surface water standard for zinc in all four city water samples. In addition, the zinc and copper concentrations detected in the city water samples were generally higher than the concentrations of the zinc and copper detected in the stormwater and non-stormwater samples. It should also be noted that SOD and COD were not detected in the city water sample which was submitted for the full suite of analyses. 12 ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) Based on the analytical results from the four city water samples, it appears that at least some of the compounds that are being detected in the stormwater and non-stormwater samples could be originating from city water infiltrating into the stormwater system. In particular the detections of zinc and copper in the stormwater and non-stormwater samples may be directly related to infiltration of city water. 13 ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) 7. Feasibility of Routing Industrial Process Water to City of Durham Sanitary Sewer Currently, process water associated with site activities is temporarily containerized within a 20,000 gallon AST located within the vicinity of the equalization basin. Process water originating from the overhead caustic line and the acid/base containment area trench drain system is discharged into the equalization basin, where it is neutralized prior to being pumped into the AST. The AST is equipped with a float - type sight gage that indicates the storage capacity remaining in the tank. The AST is also equipped with an automated high level alarm. The site's process water is disposed of by periodically pumping and hauling the waste water to an off -site facility properly permitted for disposal. The wastewater is hauled by Hilco Transport (Greensboro, North Carolina), and treated and disposed at the HOH Corporation located in Winston Salem, North Carolina (EPA ID# NCR000012260). In accordance with the SOC, Brenntag has been evaluating the feasibility of routing the discharge of process water to the City of Durham's sanitary sewer system. As such, Brenntag submitted an Industrial User Wastewater Survey and Permit Application (Appendix B) to the City of Durham Department of Water Management (DWM) on April 28, 2009. The DWM subsequently issued a letter indicating that they wanted to wait until Brenntag completed their facility retrofits and process water sampling activities under the requirements of the SOC prior to further evaluating Brenntag's Permit Application. The results of the process water sampling activities conducted in November and December 2010 were recently submitted to the City of Durham DWO. Brenntag is re-establishing correspondence with the DWM to determine the pretreatment requirements (if any) for the proposed discharge. Once the pretreatment standards are established, an evaluation of the technical and economic feasibility of discharging to the DWM sanitary sewer system will be initiated. 14 ARCADIS 8. Summary and Conclusions Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) Based on the analytical data from the stormwater/non-stormwater samples, process water samples, and Durham city water samples collected over the period of April 2010 through March 2011, several general conclusions were developed. A summary of the stormwater/non-stormwater sample analytical results along with associated conclusions are presented below. 8.1 VOCs and SVOCs in StormwaterlNon-Stormwater Samples The analytical results for stormwater and non-stormwater samples collected in April 2010 through March 2011 indicate that several VOCs were detected in the samples at relatively low concentrations including: acetone, bromodichloromethane, chloroethane, chloroform, 1,1-dichloroethane, toluene, 1,1,1-trichloroethane, trichloroethene, and vinyl chloride. Three VOCs (bromodichloromethane, chloroform, and vinyl chloride) were detected in the stormwater samples at concentrations that exceeded surface water standards, and five VOCs (chloroethane, chloroform, toluene, trichloroethene, and vinyl chloride) were detected in the non-stormwater samples at concentrations that exceeded surface water standards. No SVOCs were detected in any of the stormwater or non-stormwater samples collected between April 2010 and March 2011. The stormwater and non-stormwater analytical data collected in April 2010 through March 2011 indicate that the water that is accumulating in the detention basins is not impacted with significant concentrations of VOCs that would be associated with chemicals that are handled or stored at the site. In addition, no SVOCs have been detected in the stormwater and non-stormwater samples. This would indicate that Brenntag has implemented successful handling and storage practices for facility chemicals that could introduce VOCs and/or SVOCs into the stormwater management system at the site. The low concentrations of VOCs that have been sporadically detected in stormwaterinon-stormwater samples may originate from several potential sources including: normal runoff from paved areas at the facility, limited infiltration of groundwater into the facility stormwater system, and/or introduction of Durham city water into the stormwater system (housekeeping sources). Several of the VOCs that have been sporadically detected at low concentrations in the stormwater and non- stormwater samples also have been detected in the groundwater at the site; however, groundwater infiltration should be very limited because the existing stormwater management structures have been lined and epoxy coated. The introduction of Durham city water into the stormwater system (e.g. washdown water) could account for two of the VOCs detected in the stormwater and non-stormwater samples (chloroform 15 ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) and bromodichloromethane), as these two compounds also have been detected in the Durham city water. See Section 8.4 for a more detailed discussion on how the city water is suspected to be entering the stormwater management system. 8.2 Metals in Stormwater/Non-Stormwater Samples Elevated concentrations of two metals (zinc and copper) have been detected in the stormwater and non-stormwater samples at concentrations that exceeded the surface water standards for those two compounds. The zinc results for the 22 samples collected between April 2010 and March 2011 ranged from 120 micrograms per liter (µg/L) to 500 µg/L. The copper results for the 22 samples collected between April 2010 and March 2011 ranged from 7.4 µg/L µg/L to 14 µglL. The concentrations of zinc and copper detected in the stormwater and non-stormwater samples are very consistent with the concentrations of zinc and copper detected in the facility's water supplied by the City of Durham. The zinc and copper concentrations detected above reporting limits in the four city water samples ranged from 420 pg/L to 1,200 pg/L and 17 pg/L to 30 pg/L, respectively. This provides a line of evidence that the zinc and copper detections in the stormwater and non-stormwater samples could be associated with the introduction of Durham city water into the stormwater management system. See Section 8.4 for a more detailed discussion on how the city water is suspected to be entering the stormwater management system. 8.3 BOD and COD in StormwaterlNon-Stormwater Samples In general, the BOD and COD results for the stormwater and non-stormwater samples collected between April 2010 and March 2011 were relatively low. The BOD results for the 22 samples collected between April 2010 and March 2011 ranged from 2.1 milligrams per liter (mglL) to 170 mg/L, with an average concentration of 22.1 mg/L. The COD results for the 22 samples collected between April 2010 and March 2011 ranged from 20 mglL to 340 mg/L, with an average concentration of 70.4 mg/L. Although the majority of the detections of BOD and COD were relatively low, there was enough variability in the detections to indicate that a non-stormwater source was potentially entering the stormwater system and impacting the BOD and COD concentrations. As a comparison to the stormwater and non-stormwater BOD and COD results, the BOD results for the four process water samples were all consistently very high, ranging from 3,100 mg/L to 9,600 mg/L. The COD results for the four process water samples that were analyzed for COD also were all consistently very high, ranging from 10,000 lire ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) mg/L to 12,000 mg/L. The BOD and COD results for the process water samples demonstrate that even a small amount of process water entering the stormwater system could likely have a significant impact on the BOD and COD concentrations in the stormwater/non-stormwater samples. Because our analytical data primarily eliminated VOCs and SVOCs as constituents of concern that might be creating elevated BOD and COD in the stormwater/non- stormwater samples, we focused on other chemicals that are handled and stored at the facility to determine what might be causing the elevated, and somewhat variable, BOD and COD results for stormwater/non-stormwater samples. It was determined that acetic acid is one of the primary chemicals stored and handled in the Acid/Base Containment Area (see Figure 3), and that relatively small quantities of acetic acid can yield elevated BOD and COD in stormwater (1.0 mg/L of acetic acid/acetate will yield up to 0.9 mg/L of BOD). Therefore, the product handling and storage activities conducted in the Acid/Base Containment Area were further reviewed to determine if a pathway exists for acetic acid to enter the stormwater system in that area. The following section discusses how acetic acid may be entering the stormwater management system. 8.4 Potential Source of Elevated Metals and BODICOD for Stormwaterinon-Stormwater Samples T, The process water that is generated in the Acid/Base Containment Area is expected to contain considerable concentrations of acetic acid. This process water is routed to the equalization basin via the acid area trench drain system (see Figure 3). Based on site observations, it appears that process water from the acid area trench drain may intermittently have the potential to enter the stormwater system. Prior to retrofitting, a portion of the acid area trench drain system was exposed to the elements, allowing stormwater to enter the trench drain system. During heavy rain events the trench drain system would surcharge and overflow into the stormwater collection and conveyance line directly north of the trench drain (catch basins designated SW-4, SW-7, and SW-9). Thus, potentially impacted water would overflow and discharge into the stormwater detention basins. In October 2010, the roof canopy in the Acid/Base Containment Area was extended in order to cover the trench drains located in the processing and handling portion of the Acid/Base Containment Area that had previously been exposed (Figure 2). This retrofit successfully reduced the volume of rainwater entering the acid area trench drains and equalization basin and minimized the potential for impacted process related 17 ARCADIS Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) water from entering the stormwater system. However, city water used to wash down drums and the floor in the Acid/Base Containment Area still has the potential to accumulate in the trench drain, and if the trench drain system is not emptied into the equalization basin, the city water which accumulates in the trench drain can still overflow the trench drain and enter the same stormwater catch basins listed above. This wash down water would have elevated zinc and copper concentrations as it originates from city water, and it could have significant concentrations of acetic acid depending on the amount of acetic acid that was being processed on any given day. It appears that the surcharging of the trench drain system in the Acid/Base Containment Area is the most likely explanation for the elevated zinc, copper, BOD and COD concentrations which have been detected in the stormwater/non-stormwater samples collected in the period of April 2010 through March 2011. 18 ARCADIS 9. Recommendations Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) This section provides recommendations for specific revised facility operational procedures to address elevated metals, BOD and COD concentrations detected in stormwater/non-stormwater samples. • The valve that drains process water from the trench drain system in the Acid/Base Containment Area should remain normally open so that process water does not accumulate in the trench drain and this should eliminate the potential for surcharging the trench drain and subsequent overflows into the stormwater collection and conveyance system. • A high level alarm should be installed for the equalization basin to avoid overfilling. • A schedule for epoxy coating of the trench drain system should be established that would be effective at maintaining an adequate epoxy coating on the trench drain system components. • The sloping of the concrete floor in the Acid/Base Containment Area should be evaluated to determine if modifications would improve separation of process water from stormwater catch basins and restriction of stormwater from entering the trench drain system. • Additional training should be provided to the Brenntag personnel that work in the Acid/Base Containment Area to ensure they are aware of the importance of keeping process water from accumulating in the trench drain system, and particularly to avoid any scenario that allows process water to enter the nearby stormwater catch basins. 19 ARCADIS 10. References Final Report and Progress Account, Stormwater Evaluation, (April 2010 through March 2011) ARCADIS, 2008. Engineers Alternatives Analysis, Response to NOV-2008-CV-0008, Brenntag Southeast, Discharge to Unnamed Tributary to Third Fork Creek. Letter submitted to NCDENR Surface Water Protection — Department of Water Quality. November 5. ARCADIS, 2010a. Quarterly Progress Report, Stormwater Evaluation. Brenntag Southeast Facility, 2000 East Pettigrew Street, Durham North Carolina. Special Order by Consent. SOC No. S09-006, July 29. ARCADIS, 2010b. Quarterly Progress Report, Stormwater Evaluation (July through September 2010). Brenntag Southeast Facility, 2000 East Pettigrew Street, Durham North Carolina. Special Order by Consent. SOC No. S09-006. October 28. ARCADIS, 2011 a. Quarterly Progress Report, Stormwater Evaluation (October through December 2010). Brenntag Southeast Facility, 2000 East Pettigrew Street, Durham North Carolina. Special Order by Consent. SOC No. S09-006. January 28. ARCADIS, 2011b. Quarterly Progress Report, Stormwater Evaluation (January through March 2011). Brenntag Southeast Facility, 2000 East Pettigrew Street, Durham North Carolina. Special Order by Consent. SOC No. S09-006. April 29. North Carolina Department of Environment and Natural Resources (NCDENR), 2010. Division of Water Quality. Special Order by Consent. SOC No. S09-006. April 8. 20 ARCADIS Tables Page 1 of9 Table 1. Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non-Stomwater Sampling Activities, and Discharge Record for the Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina. Date Precipitation' Rain Gouge' Discharge Basin Freeboard Depths (feet)' (inches) (inches) Basin Basin Basin Basin Sampling / Activities Conducted Comments (gam-) 91 02 93 #4 4/82010 0.02 NA - 4/92010 0.04 NA 4/102010 0.00 NA I 4/112010 0.00 NA_- -�NA f 4/122010 4/132010 0.00 0.03 NA 4/14/2010 _.._ 0.00 NA- T- - 4/152010 0.00 j NA -. 4/162010 0.00 - NA - t � -!..__-- 4/17/2010 0.00 NA 4/182010 0.00 NA 4/192010 0.00 NA 4202010 0.00 NA 421/2010 0.49 NA 0 4 1 4 4 4.5_- 4222010 0.00 NA 45,000 2 2 0.5 0 B. White on -site to collect stomwater discharge sample. Sampling conducted in association with the 421/10 rainfall event. Brenntag released stomwater discharge after sampling was completed - 4232010 0.00 0.00 0 NR NR NR i NR I B. White on -site to install rain gauge. ` 4242010 - 0.13 _-... NR __.-- 0 NR _ NR_ NR NR _..._ .--- -.-------...__._.._..._.____ _ -� ..-._..._.__._______.... -.--_-.-_.---__........ .._.. 425/2010 0.22 NR 0 a NR NR NR NR� 4262010 0.00 i 0.34 _ 30,000 i 2 2 <0.5 '; 0 B. White on -site to collect stormwater discharge sample. Sampling conducted in association with 424/10 and 425/10 rainfall event. j I ! Brenntag released stomwater discharge after sampling was completed - 4272010 _ 428/2010 0 00 i 0.00 0.00 .._ - _._ 1 0.00 0 L.. 0-..± 3 3 1 >6 a__... >6 1 >6 >6 >6 >G -.._ 4292o10 0.00 0.00 L 0 3 >6 I >6 >6 4/302010 0.00 0.00 0 >3 >6 >5 4 _ 5/12010 0.00 0.00 0 NR NR NR NR 522010 0.00 0.00 _ 0 NR NR NR NR -_ 5/32010 0.00 0.00 0 3 4 2 2 5/42010 0.00 0.00 0 3 4 2 2 5/52010 0.00 0.00 0 3 >3 2 2 5/62010 0.10 0.00 0 >3 3 1.5 1.5 _ - 5/72010 0.00 0.00 30,000 3 3 1 I D. Twamley on -site to collect non-stomwater discharge sample. Water accumulated in basins over an 11 day period (427/10 through 5/7/IO) with no qualifying nun events occurring, thus the sample is determined to be non-stomwater. Brenntag released non-stomwater discharge after sampling was completed 5182010 0.00 NR 0 NR NR NR NR 5/92010 0.00 NR 0 NR j NR 1 NR ! NR j 5/102010 0.00 0 3 1 >6 >6 !_.>6 _5/11/2010 0.00 -� _0.00 0.00 - 0 3� -3 >6 r >6 5l12/2010 0.00 0.00 ; >6 >6 6 5_/132010 0.00 0.00 _0� - 0 + - 3 1--_6_[ 6 5 5 ---5 -- - -- 5/142010 - 0.00_ _ 0.00 0 3 5 --- - --- .. ... 5/152010 0.47 NR 0 NR NR NR ; NR ^5/162010 0.46 - NR 0� NR NR NR NR - _ - 5/172010 4.60 1.00 90,000 2.0 2,0 0.5 0.0 D. Twam!ey on -site to collect stomwater discharge sample. Sampling conducted in association with 5115110 thnr 5/17/10 rain event. Brenntag released stormwater discharge after sampling was completed. 5/182010 0.25 3,05 45,000 2.0 2.0 0.5 0.0 Samples not collected because <72 hours had passed since the 5115110 Brenntag released stomwater discharge. through 5/17110 rainfall event. Page 2 of 9 Table 1. Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non-Stormwater Sampling Activities, and Discharge Record for the Brenntag Southeast Facility (Fortner Southchem Facility), Durham, North Carolina. Date precipitation' x Discharge Basin Froeboard Depths (feet)' heson Rein Gauge Volume (inches) (inches) Basin Basin Basin Basin Sampling /Activities Conducted Comments (gall-) 91 N 2 93 44 5/192010 0.17 0.24 45,000 2.0 2.0 0.5 1 0.0 ISamples not collected because <72 hours had passed since the 5118110 Brenntag released stormwater discharge. -+ �0 - 0 _ I 1_W_;_-..__ rainfall event. 1 _-�. 5202010 0.00 0.11 8f j 8.0 F 7.0 7.0 JA&D on -site to clean and remove sediment from detention basins. A significant amount ofsediment had accumulated in the bottoms ofthe four 1 t basins primarily due to road construction work that was being performed on i Pettigrew Street adjacent to the facili s northern property boon } ry' P perry dory. -5n1i2010 ._.'___..0.00 0.00 0 6.5 1 7.5 6.5 1 6.0 5/222010 Oil) T NR - 0 j NR NR NR NR 5232010 0.80 ; NR �- 0 --y _NR I NR tj NR N_ R- 5/24/2010 0. is 2.00 35,000 ; 1.5 2.0 0.5 0.0 D. Twamley on -site to celled stormwater discharge sample. Sampling conducted in association with 52v10 through 524/10 rainfall I i event. Brenntag released stormwater discharge after sampling was completed. 5252010 0.07 _._--_.-- 0.15 --._-- 0 3.5 4.0 _._ 3.0 3.0 _ _ 5262010 0.01 0.00 0 3.5 3.0 1.5 1.5 _......._...._......_--.-._.-.... -. .......... 5272010 0.00 0.00 28,000 3.0 2.5 1.0 0.5 Samples not collected because the May 2010 storm -water sampling - - Brenntag released stormwater discharge. ants have been fulfilled. 5282010 1.12 0.00 0 3.5 7.0 5.5 5.5 5292010 0.03 0 NR NR NR NR 5/302010 0.00 _NR NR 0 NR NR _ NR NR 5/312010 0.00 NR 0 NR NR NR NR Freeboard depths not recorded due to Holiday. -- 6/12010 0.43 2.5 45,000 i 1.5 0.5 0.0 0.0 Samples not collected because <72 hours had passed since the 528/10 Brenntag released stormwater discharge. E and 529/10 rainfall event. 622010 _ 0.06 _1 0.05 1 0 ! 3.5 5.0 j 3.0 3.0 0.00 0 3.5 3. 0 1.5 _6/32010 6/42010 �0.00 6.00 _0.02 0.00 I - 0 3.0 2.0 1.0 ! 1.0 6/5/2010 6/62010 6/72010 0.06 0.00 NR NR 0.14 0 - 0 0 NR NR 2.5 NR NR 2.0 NR NR NR NR 0.0 ! 0.0 6/82010 0.00 0.00 35,000 2.5 2.0 0.0 0.0 B. White on -site to collect non-stormwater discharge sample. Water accumulated in basins over a 7 day period (62/10 through 6/8110) with no qualifying rainfall events occurring, thus the sample is determined to be non-stormwater. Brenntag released non-stormwater discharge after W - sampling was completed. 6/92010 0.00 0.00 _ 0 3.0 7.0 5.5 5.5 ----- - 6/102010 0.00 0.00 1 0 3.0 J 7.0 5.5 5.5 6/112010 0.00 0.00 1 0 1 3.5 1 6.0 4.0 4.0 6/122010 0.31 NR 0 NR NR NR NR _-- 6/13/2010 6/142010 0.71 0.01 NR 0NR NR NR j 0.44 35,000 i 2.0 1.5 1 0.0 ' 0.0 D. Twamley on -site to collect stormwater discharge sample. -- Sampling conducted in association with 6/12/10 through 6/14/10 rainfall event. Brenntag released stormwater discharge after sampling was 6/152010 0.00 0.02 0 i 3.5 ! 7.0 ( 5.5 5.5 -� -- --- ---- v 6/162010 0.43 0.00 0 3.5 I 7.0 9.5- 5.5 ! 6/17/2010 b 0.01 0.90 30,000 i 2.0 IT! 0.0 i 0.0 iSamples not collected because <72 hours had passed since the 6/12110 Brenntag released stormwater discharge. 6/18/2010 0.00 ' Jllirou 6/14/10 rainfall event. :. 0.00 0 1 3.57.0 S.5 r 5.5 I _ 6/192010 - 0.00 .00 .__ _ NR i 0 NR NR `` NR + NR 6202010 0.00 j NR 0 ; NR ! NR NR r NR 6212010 0.00 0.00 --0 3.5 4.5 ! 3.5 ! 3.5 ' 622/2010 0.00 0.00 0 3.5 4.5 3.0 j 3.0 Page 3 of 9 Table 1. Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non-Stonnwater Sampling Activities, and Discharge Record for the Brermtag Southeast Facility (Former Southchem Facility), Durham, North Carolina. Date Precipitation' 2 Discharge Basin Freeboard Depths (feet) Rain Gauge Volume Basin Basin Basin Basin Sampling / Activities Conducted4 Comments (inches) (inches) (gall-) # 1 # 2 # 3 94 6/23/2010 0.16 0.35 35,000 2.0 1.5 0.0 0.0 D. Twamley on -site to tolled stormwater discharge sample. Sampling conducted in association with 623110 rainfall event that produced 1 0.35" of precipitation over a I hour period at the facility. Brenntag released stormwater discharge after sampling was completed 6r"10 0.01 0.00 0 3.5 7.5 6.0 5.5 6/25/2010 0.00 0.02 0 3.5 7.5 6.0 5.5 _ 626/2010 0.00 NR 0 NR NR NR NR 6/27/2010 0.00 NR 0 NR NR 1 NR j NR 6n812010 0.02 0.20 35,000 2.5 1.5 0.5 0.0 Samples not collected because the June 2010 storm -water sampling requirements irements have been fulfilled. Brenntag released stormwater discharge. G/29n010 OAl 0.00 0 3.5._F Ili 5.5�. 5.5 0 7.0 _ 6/30/2010 0.00 0.00 3s 7nnol0 - 0.00 0.00 0 3.5 1 7.0 5.5 t -5.5 7=010 0.00 0.00 0 3.5 5.0 4.0 4.0 ' 7/32010 0.00 NR 0 NR NR NR NR '-"""`-'_-`"_..__._.-. --- _.�__.__--•--_�..r-_�_... ___ 7/4n010 0.00 NR 0 NR NR NR NR 7/5n010 0.00 NR 0 NR NR NR NR Freeboard depths not recorded due to Holida . w 7/612010 0.00 0.00 30,000 3.5 3.5 2.3 2.0 D. Twamley on -site to collect non-stormwater discharge sample. Water accumulated in basins over an 8 day period (6/29/10 through 716/10) with no qualifying rainfall events occurring, thus the sample is determined to be non-stormwater. Brenntag released non-stormwater discharge after sampling was completed. 7512010 0.00 0.00 0 3.5 7.5 6.0 6.0 -i M'2010 0.00 0.00 0 NR NR NR i N_R -0.5 j 719/2010 0.14 0.24 35,000 3.3 2.5 1,0 i D. Twamley on -site to collect stormwater discharge sample. Sampling conducted in association with 7/9110 rainM event that produced I i i ! ' 0.24" of precipitation over a 2 hour period at the facility. Brenntag released stormwater discharge after sampling was completed. _ .- 7/1On010 0.00 j NR 0 NR NR NR NR m 7/1 In010 m 0.00 NR -j _ _i - - 0 --- _ :.- NR ' NR i NR NR - 7/12/2010 ------------ _ 0.07 _ � 0003 .._ t 0 _ i-3.5 3.0� 6.0 j 5.0 r 4.3 7/13/2010 1.06 0.17 35,000 2.5 1 1.0.5D. Twamlay on -site to collect stormwater discharge sample. Sampling conducted in association with 7112110 rainfall event that produced 0.17" of precipitation at the facility. Brenntag released stormwater discharge i i after sampling was completed. 7/1412010 0.15 0.32 35,000 2.0 1.5 ° 0.0 ( 0.0 Samples not collected because 42 hours had passed since the 7/13/10 Brenntag released stormwater discharge. - i rain event. Additionally, the July 2010 stormwater sampling requirements have already been fulfilled 7/1512010 0.00 0.00 0 3.5 7.0 5.5 5.5 -- 7/16010 0.02 0.00 0 3.3-- 7/17n010 0.84 NR 0 NR I NR NR NR 7/18/2010 0.90 NR 0 NR I NR NR NR 7/19/2010 0.01 0.45 35.000 - 1.5 1.5 0.0 0.0 Samples not collected because the July 2010 stone -water sampling requirements have been fulfilled Brenntag released stormwater discharge. 7/2012010 0.13 0.00 1 0 3.5 f 6.5 5.5 5 5 7n 1/2010 .._ 0 01 0.06 i .._......_.__.-._.__...-. 0 i 3 5 5.5 € 4_3 4 5 _ . __._.-_ 7/22/2010 7n3n010 0.00 t 0 00 0.00 o.00 0 0 I 3 5 3 5 4.5 } 4.5 3.5 - 3.5 3 0 3.0 1 - 1 �� -i -NR 7n4/2010 i 0.00 NR- 0 NR NR 712Sn010 0.48 NR 0 r NR NR NR NR �- 7/26(2010 0.01 } 0.17 30.000 ! 1.5 1.5 0.0 0.0 Samples not collected because the July 2010 storm -water sampling Brenntag released stormwater discharge. 1 (requirements have been fu1011od. 7127/2010 0.26 0.00 0 3.5 7.0 5.5 5.5 Page 4 of 9 Table I- Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non-Stormwater Sampling Activities, and Discharge Record for the Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina. Date Precipitation' ( Inches) Rain Gauge' (inches ) Discharge VS f¢allons) Basin Freeboard Depths (feet)' Basin Basin Basin Basin Sampling! Activities Conducted' Comments it l a? tea R d 7282010 0.00 0.45 35,000 1.5 1.5 0.0 0.0 Samples not collected because the July 2010 storm -water sampling Brenntag released stormwater discharge. requirements have been fulfilled 7292010 0.00 0.00 0 3.5 7.5 6.0 6.0 7/302010 0.00 0.15 0 3.5 3.3 1.5 { 1.5 7/312010 0.09 j NR 0 k NR NR NR NR , 8/12010 0.17 i NR 0 NR k NR i NR NR 822010 0.01 ' 0.26 t 30,000 1.5 1.0 0.0 0.0 !Samples not collected in August through October 2010 as facility retrofit Brenntag released stormwater discharge. - T - lactivities were not complete. 8/3/2010 0,00 i 0.00 0 3.5 7 0 5.5 8/42010 0 37 0.00 0 3 5 -5.5 ! 7.0 5.5 5.5 052010 0.66 0.52 1 30,000 2.3 j 2.7 0.5 0.0 'Samples not collected in August through October 2010 as facility retrofit Brenntag released stormwater discharge. 8!6/2010 0.00 j 0.41 ! 30,000 2.0 j 2.3 1 0.0 ; 0.0 !activities were not wmPlete ---�� Samples not collected in August through October 2010 as facility retrofit Brenniag released stormwater discharge. - __. 8/72010 8/t1/2010 0.00 0.00 1 NR NR j ...__ 0 NR 0 NR I_ _ I NR NR I NR- NR j NR i NR activities were not complete. 8/92010 0.00 om 1 0 3.3 5.8 4.3 4.0 9/102010 0.00 0.00 0 3.3 4.3 3.8 3.5 -_ 9/112010 0.06 0.00 0 3.3 4.3 3.3 3.0 - 8/122010 0.01 0.00 0 3.0 3.0 2.0 2.0 8/132010 0.00 0.10 0 2.5 2.0 1.0 1.0 8/142010 0.00 NR 0 NR NR NR I NR 0.00 NR 0 NR NR NR NR _81152010 9/162010 _ 0.00 _ 0.00 35,000 1.5 - 1.5 - 0.0 0.0 Samples not collected in August through October 2010 as facility retrofit Breantag released stormwater discharge. 8/17/2010 8/182010 8/ 192010 0.00 0.00 0 i 3.5 0.02 0.00 f 0 13 5 k 1.11 0.54 30,000 15 k activities were not com lets . ! 7.0 i 5.5 i 5.5 r 7.0 5.5 5.5 1.5 0.0 0.0 Samples not collected in August through October 2010 as facility retrofit I tnntag released stormwater discharge. i -- ---?-__-: ---- activities were not complete.- -__ 8202010 8212010 0 0.01 0.50 0 15 ; 0.00 NR 0 NR l 5 0.0 0.0 - 1 NR i NR NR i __ -- - ....- -- - - ----- - -...- - - - - - ---- - ---- ---- 82220:0 ----- Y..-------- --- 0.48 I NR 0 NR -_+ .� , -- NR i NR i NR 1.5 ( 0.0 0.0 iSamples l _-- _ - - -__ not collected in August through October 2010 as facility retrofit activities were not complete. --_� `- _- -- - -- Brenntag released stormwater discharge. 823200 -8242010 0.01 -0.24 1.20 _-�- 30,000 I,5 _ i 0.03 0 3.5 I S.5 4.5 r 4.0 8252010 0.10 0.06 0 3.5 4.0 1 3.0 i 3.0 0.00 0.00 0 1 3.5 4.0 3.0 k 3.0 -- _8262010 8272010 0.00 0.00 0 3.5 3.0 1.5 1.5 8282010 0.00 NR - NR NR--NR ! NR --- 8292010 81302010 8/31/2010 9lI2010 -0 T_ _ _.-- 0.00 NR 0 I NR NR NR NR 0.00 0.00 30,000 "Ti- LS j 0.0 0.0 !Samples not collected in August through October 2010 as facility retrofit activities were not com lete 0.00 _ 0.00 _ 0 3.5 7.2 6.0 6.0--- 0.00 000 0 35 i 70 60 60 - Brenntag released stormwater discharge. 9l22010 _ 9/32010 __.. _ ._ ...._ _ ....._ -._ _ 0.00 0 00 0_ 3 5 7 0 6 0 6 0 -- -_--i - _..- _ __---•-- . _ _..._ ___ .___...- ____ ___ 0.00 0.00 0 3 5 7.0 6.0 6.0 _.---. _ __ ... _. __. _._..._._._ ... _..__._ _....._.._.._ _ ........... ____.i._._-.__ 9/42010 9152010 9/Gl2010 __._I_- .. 0.00 NR _� 0 i NRNR I NR- 0.00 ! NR j 0 NR NR ( N NR 0.00 NR -NR 0 _ NR NR 1 NR NR _ Freeboard depths not recorded due to Holiday. 9172010 0.00 0.00 0 3.5 4.5 3.0 1 3.0 page 5 or9 Table 1. Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non•Stormwater Sampling Activities, and Discharge Record for the BrenntaA Southeast Facility (Former Southchem Facility), Durham, North Carolina. Date Precipitation' Rain Gauge' Discharge Basin Freeboard Depths (feet) (inches) (inches) Basin Basin Basin Basin Sampling / Activities Conducted` Comments (gallons) y 1 92 # 3 94 9/8/2010 0.00 0.00 0 3.5 4.0 3.0 1 2.5 9/9/2010 0.00 0.00 0 3.5 4.0 2.5 1 2.0 9/10/2010 0.00 0.00 0 3.0 3.5 2.0 1.5 9/112010 0.07 NR 0 NR NR NR NR 9/12/2010 0.04 NR 0 NR NR NR NR- 9/13/2010 0.00 0.04 30,000 3.0 3.0 1.5 1.0 Samples not collected in August through October 2010 as facility retrofit Brenntag released stormwater discharge. activities were not complete. 9/142010 0.00 0.00 0 3.5 7.0 6.0 6.0 9/15/2010 0.00 .... _ 0 00 _ 0 3 5 6.5 5.5 T 5 0 1 - -- --- _ ---.-.._. _ .,.. ._........... -- --_ 9/162010 ( 0 00 0 3.5 6.3 5_0 1 4.5 1 9/1T2010 _0.00 0.00 0.00 0 3.5 -- 5.7 1 4.5 4.2 9/182010 _._..- - ! 0.00 NR _...-.._. 0 NR NR _. -. NR NR- ___-12010 9/192010 _. 0.00 ! NR ! 0 NR r NR i NR NR i 3.5 i 3.5 3.2 1 3.0 3.0 2.6 i 2.7 2.5 i - - =T..--_ 9/20/2010 9/21/2010 _ �___.__._....._M....__ 0.00 0.00 0.00 0.00 { 0 ; 3.5 5.0 0 3.5 4.7 - 9/222010 0.00 0.00 0.00 0.00 --__1-_ -a- 0 3.5 0 3.5 4.3 1 4.0 ---_-- _ _ - - 923/2010 9242010 0.00 0.00 9252010 0.00 NR 0 NR NR NR NR 926/2010 1.30 NR 0 NR NR NR NR - ----_-_--- - -- --_ - -- 9272010 1.07 2.50 35,000 ' 2.3 2.0 0.0 0.0 Samples not collected in August through October 2010 as facility retrofit Bramteg released stormwater discharge. -- - activities were not complete. 92812010 0.23 0.00 0 3.5 6.0 6.0 6.0 - - 9292010 1.56 0.50 30,000 2.3 2.0 0.0 0.0 Samples not collected in August through October 2010 as facility retrofit _ Brenntag released stormwater discharge _ a_cnnnes were not complete. 9/302010 1.53 3.00 { 35,000 2.3 2.0 ! 0.0 i 0.0 1Samples not collected in August through October 2010 as facility retrofit Brenntag released stormwater discharge. ! (activities were not complete. - -----__ - 10l12010 - 0.00 ; 0.02 0 i 3.5 ! 4.5 3.5 i 3.5-- 10R12010 0.00 i NR j- 0 NR ! NR !-NR I NR 10/32010 0.01 NR 0 NR NR ! NR NR _... _ _- 10/42010 _.--- 0.08 0.00 - ---_..---r-�..- 0 2.3 r 2.5 -- 1 1.0 , __NR 1.0 --- ---- 10/52010 --_ (- 0.01 ----0 0.06 j - 0 2.3 2.0 0.0 ! 0.0 ' -- _ __-._.- -- ---- -- --- -- --------- Accumulation in basins pumped out for offsite disposad due to high pH. 10/62010 i 0.00 I 0.00 0 ! I_- >6 t >6 >6 1 >6 10/72010 0.00 J 0.00 0 >6->6 >6 i >6 ----- -- - -_ - -- -- --- 10/8/2010 0.00 0.00 0 >6 >6 >6 1 >6 10/92010 0.00 NR 0 NR NR NR NR 10/102010 0.00 NR 0 NR NR NR NR 10/112010 0.00 0.00 0 3.5 >6 5.0 5.0 �- 10/122010 0.00 0.00 0 3.3 6.0 4.7 4.5 10/132010 0.00 0.00 0 3.5 5.3 4.0 3.7 10/142010 1.27 1.10 30,000 2.3 2.0 0.0 0.0 Samples not collected in August through October 2010 as facility retrofit Bren dag released stormwater discharge. activities were not complete. 10/152010 0,01 0.02 0 3.5 6.0 4.8 4.5 10/162010 0.00 NR 0 NR NR NR 1 NR- 10/172010 _ 1 NR 0 NR NR NR NR i 10/182010 000 0.00 0 3.5 1 4.3 33 ! r 2.5� _-_ 10/I92010 10202010 _ _..-. .. 0.00 0.06 - 0.01 -_ 0.00 --�-- _ 0.043�.5 0.03 ! 0 1 -- O y 3.5 !_4.0 3.S f j 3.5 3.3 1.0 2.5 1.0 -..__ _.. _..--------...-- - -- - - ---- - - ---- - - -- - ----- --- - 10212010 ! Page 6 of 9 Table 1. Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non-Stamwater Sampling Activities, and Discharge Record for the Brenntag Southeast Facility (Fortner Southchem Facility), Durham, North Carolina. Date Precipitation' Rain Gaugw Discharge Basin Freeboard Depths (fat)' (inches) (inches) Basin Basin Basin Basin Sampling / Activities Conducted' Continents (gallons) # I q 2 03 04 10222010 M0.00 1--6--00 30,000 3.5 I 2.5 Wj 1.0 I.0 Samples not collected in August through October 2010 as facility retrofit Bremung released stormwater discharge. _ activities were not complete. _ - 10232010 0.00 NR OW NR NR NR NR 10242010 0.00 NR T 0 NR NR NR NR 10252010 0.15 0.14 0 3.5 >6 3.0 4.0 10262010 0.38 0.45 35,000 2.5 2.0 0.0 I 0.0 Samples not collected in August through October 2010 as facility retrofit Brcuntag released stomwater discharge. activities were not complete. 10272010 0.37 1 0.00 0 3.5 7.0 5.5 5.3 10282010 0.00 0.24 35,000 2.5 2.0 0.0 0.0 Samples not collected in August through October 2010 as facility retrofit Bmntag released stomwater discharge. activities were not complete. 10292010 10/302010 0.00 i 000 0 01 1 - NR 0 0 3.5 NR >6 NR 1 >6 >6 NR N 10/312010 0 00 NR .... i .. 0 .... .... _ NR .. NR # NR 1- NR ...._.....3.. _.. - . .. ... .. ..... _ .............. .. .....-......_. ... __..._... _ - _ _........... _........._.-..._.. .. ...-................._ ..... _. -... .._. _.... __ "- ... 1ll12010 000 1 0.00 0 ; 35 9540 ; 3.7 11/2/2010 0.00 0.00 0 3.5 ! 5.0 ; 3.5 3.3 _ 11/ Moll) 0.04 1 0.00 F 0 L 3.5 4.5 3.0 ` 3.0� Accumulation in basins pumped out for offshe disposal due to low PH. 11/42010 }- 0.69 0.70 _ 1 30,000 2.5 1 2.0 j 0.0 0.0 ; D. Tweml on -site to collect stomwater discharge sample. Breirn released stomwater discharge after sampling was completed, 11/52010 0.00 I 0.10 1 0 ! 3.3 6.0 4.5 j 4.0 11/62010 0.07 NR 0 NR NR NR i NR 11/72010 0.0 NR 0 NR NR NR NR I1/8/2010 0.00 0.07 0 3.0 3.0 1.0 1.0 _ 11/92010 0.00 0.02 30,000 3.0 2.3 0.8 0.5 Samples not collected because basin accumulation was associated with Brenntag released stomwater discharge. 11/6/10 and 11/8/10 non -qualifying rain events that produced 0.07" and 0.02" of rainfall at the facility, respectively. 11/102010 0.00 0.00 0 3.5 7.3 6.0 5.8 11/112010 0.00 0.00 0 3.5 7.0 5.3 5.0 11/122010 0.00 0.00 0 3.5 6.5 5.0 4.5 _ 11/132010 0.00 NR 0 NR NR NR NR _ ---- ._..__...-_-. -------- _._ 11/142010 -11/152010 ----- 0.00 _ i -- NR _._.._.. 0 - _NR_ -- NRZ _ _ ..- NR _NR _..__.--_ -..--- -----------...-_.-_.- ------------------- - 0.00 0.00 30,000 ` 3.3 # 4.3 3.0 t- 2.7 D. Twamley on -site recollect non-stomwater discharge sample. Brenntag released nan stomwater discharge after sampling was completed 11/162010 ! 0.21 0.11 0 3.5 -- i 6_0! 5.0 5.0 11/172010 i _ 0.03 0.10 _ - 0_ 3.5 3.5 2.5 2.0 ; D Twamley on -site to collect stomwater dischar a sample. -� 11/18/20103.5 0.00 0.01 : 30,000 3.5 i 3 5 2.5 2.0 ! Brenntag released stomwater discharge on 11/18/10 after sampling was completed on 11/17/10. - - ----.. -_-_ 11119/2010 _0.00 0.00 0 3 5 >7 r--- I1/202010�R- 0.00 NR 0 NRL_NR=L NR ; NR ;--- 11212010 0.00 I NR 0 NR 1 -NR ' NR NR 11/22/2010 0.00 0.00 0 3.5 5.0 ! 4.0 3.5 - v 11/232010 0.00 0.00 ! 0 3.5 5.0 3.0 3.0 _ -- - - -- 11242010 0.00 0.00 0 5.0 3.0 3.0 11252010 11262010 0.00 _ -- NR - 0.10 NR 0 -._NR 0 !NR JNR NR � NR I NR 1 NR Freeboard depths not recorded due to Hod _ Freeboard d s not recorded due to Holiday_11272010 0.00 NR 0 NR NR NR , 11282010 0.00 NR 0 NR NR NR NR -- - -- - 11292010 0.00 0.08 0 2.5 2.5 1.0 ! 1.0 r 11/302010 _ - 0.01 _ i 0.00 35,000 2.5 2.0 i 0.0 0.0 !Samples not collected because basin accumulation was associated with _ Brenntag released stomwaterdischarge. j ? i 1126/10 non -qualifying rain event that produced 0.08" ofminftil at the i ! ! facility. Additionally, the November stomwater sampling requirements have already been fulfilled. i i i i i i i 1 i i l i i i i i i i Page 7 of 9 Table I. Summary of Daily Rainfall Totals, Basin Freeboard Ivteasurements, Stonnwater / NonStommwater Sampling Activities, and Discharge Record for the Brenntag Southeast Facility (Forcer Southchem Facility), Durham, North Carolina Precipitation' Rain Gauger Discharge rge Basin Freeboard Depths (feet)r Date Volume Basin Basin Basin Basin Sampling / Activities Conducted' Comments (inches) (inches) (eallons) a i a 1) a •t a e 12/1/2010 0.38 0 60 35,000 1 2.5 2.0 0.0 i 0.0 D. Twaml on -site to collect stormwater discharge sample. Brennmg released stonnwater discharge after samplin& was completed. 12/22010 0.25 0 3.5 6.7 5.3 1 5.0 _ 12/3/2010 _0.00 0.00 --1 0.00 0 3.5 6.0 5.3 4.3 I 12/42010 _ 0.03 NR 0 NR NR NR NR 12152010 -0.24 - NR 0 NR NR NR _ NR ---�T-- ^�-- - 12/6/2010 0.00 0.00 30.000 2.5 2.5 0.0 0.0 D. Twamley on -site to collect stormwater discharge sample. Brenn released stormwater discharge after sampling was completed. 12172010 0.00 0.00 0 6.3 6.0 5.0 5.0 ~_ 12182010 0.00 0.00 0 3.5 5.3 3.9 ; 3.5 12/9/2010 0.00 0.00 0 5.5 5.3 3.8 3.5 _ 12/102010 0.00 0.00 0 5.0 5.0 4.0 3.5 { A_ 12/112010 0.11 NR 0 NR NR NR NR { 12/122010 0.28 NR 0 NR NR NR NR - 12/132010 _ 0.00 _-•. 0.44 . - _ - - 30,000 _ 2.5 i 1.8 0.0 - -i- 1.0 ISamples not collected because two stormwater sampling events had 'already been completed in December 2010. Brenntag released stormwater discharge. - 2/14/2010 1 0.00._ .i 0.00 I- � _. _>6 i 5.0 5.0 4.0 12/152010 12/16/2010 12/1720I0 12/18/2010 12/192010 12202010_ 12212010 I 0 00 0.00 1 0.70 0.55 0.04 0.24 -- _ _.._ 0.00 NR --- - _- 0.00 _ - �- NR 0_r01 --� 0`04-�- 0.00 0.00 0 >6 5.0 5.0 4,0 30,01 2 5 1.8 r 0.0 0.0 30,000 2.5 T 1.8 1 0 0 0.0 __- 0 NR NR NR NR T_.. _---_- --- - -. _- 0 _^ NR NR ; NR NR 0 4.3.5 - 4.0. _ 2.8 2 0 3.5 3.3 2.0 1.8 _- - --- - - ,Samples not collected because two stomwater sampling events had already been completed in December 2010: ;Samples not collected because two stormwater sampling events had already been completed in December 2010. -- -- Brenntag released stormwater discharge, Brenntag released stormwater discharge. ' _ 12222010 0.00 0.00 0 3.5 3.3 2.0 1.8 -_ 12232010 0.00 NR 0 NR NR NR NR Freeboard depths not recorded due to Holi 12242010 0.00 NR 0 NR NR NR NR Freeboard depths not recorded due to Holiday. _ 12252010 0.04 NR 0 NR NR NR NR -- 12262010 0.13 NR 0 NR NR NR NR _ 12272010 12282010 12292010 12/302010 12l3120I0 flI/2011 + 122011 _ 0.42 0.25 30,000 1.0 0 01 I 0.00 � 0 3.5 0 00 _ 0.50- 0 3.5 0 00 0.00 0 3 5 0 00 NR 0 NR 0 20 NR 0 NR ; 0.11 NR 0 NR 7 0.0 --I 4.5 4.3 0.0 0.0 - F 3,5 i 3.3 2.8 2.3 � -1_5 1.5 NR NR , NR NR NR NR Samples not collected because two stormwater sampling events had already been completed in December 2010. - i Bremang released stormwater discharge. -- --� 2.7 I NR ' NR Nit Freeboard depths not recorded due to Hole _ - 113201 I il4201 l 1/5/2011 _0.01 0,40 . �0.00 0.03 -y- 0.00 i 0.00 30,000 `. 2.5 I 0 ; 3.8� -0 -1-3.5 2.0 i 5.5 1 3.8 ' 0.0 0.0 {D 4.3 4.0 j 2.8 2.0 Twamley on site to collect stormwater discharge sample. �- - Brenning released stormwater discharge after sampling was feted _ �m�- - 1/62011 0.09 0.09 { 0 3.0 2.5 1.0 1.0 1/7201 l 0.00 0.00 30,000 2.5 2.0 0.0 0.0 Samples not collected because basin accumulation was associated with 1/6/1 I non -qualifying rain event that produced 0,09" of rainfall at the facility. Brenntag released stormweter discharge. _ 1lg12011 - 0.00 NR 0 NR NR NR NR 1/92011 1/IO/ZOII 0.00 0.01 NR 0.00 0 0 NR 3.5 NR 7.0 NR NR >5 i >6 1/112011 0,09 0'"0 3.5 I/12201! 0.17 1 O.IS 0 2.5 2.5 0.0 , 0.0 1 /132011 _ 0.00 - 0.00 i 30,000 2.0 2.0 { 0.0 0.0 ';D. Twamley on -site to collect stormwater discharge sam le. Brenntag released stormwater discharge after sampl!2& was completed. Page 9 of 9 Table 1. Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non-Stormwater Sampling Activities, and Discharge Record for the Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina. i a Discharge Basin Freeboard Depths (feet)' Date Precipitation Rain Gauge Volume Basin Basin Basin Basin Sampling / Activities Conducted' Comments (inches) (inches) (dons) # I # 2 # 3 # 4 1/14/2011 mm1/15/2011 0.00 f 0.02 0 4.4 ` 8.0 666.8 0.00 NR 0 NR i NR t NR NR R � _- 1/16/2011 0.00 NR 0 NR E NR N 1/1712011 0_09 0.00.._ 0_.._._:. 3.5 5.0 } 3.5 3 3.8 1/18/2011 'i/19/2011 0.00 - _ 0.06 0.00 _.._ 0 ? 3.5 _... ; 0_ 3.0 L5 l.3 __. 2.5 i 13 l.0 i -•- ----___.___. _ _._ 50/2011 M0.000� 0.00 , 0.00 _2.5 35,000 2.0 2.0 0.0 ! 0.0 = ' Samples not collected because two stormwater sampling events had already been completed in Lan 2011- P_ "etY Brenntag released stormwater discharge. __ 1/21/2011 0.00 0.00 0 3.5 _.__ .._ 3,0 _r>6 >6 _ 1/22/2011 0.00 NR 0 NR NR t- 1/23/2011 0.00 NR 0 NR NR NR NR 1/24/2011 0.00 0.00 0 3.3 3.7 2.3 2.0 _~M 1/25/2011 0.14 0.00 0 2.8 2.4 1.0 0.8 1/26/2011 0.35 0.60 35,000 2.0 2.0 0.0 0.0 Samples not collected because two stormwater sampling events had Brertntag released stormwater discharge, - { _ j jalready been completed in January 2011, 1/27/2011 0.00 0.05 J 0 3A 4.3 t 2.8 1 216 126/2011 _.. _ O.OD _r 0.00 I 0 i 2.9 __.-- NR 1 2.5 1.4 NR NR NR _I/29/2011 _ _^0.00_i._......._HR...._._.,z__..._-0 ? ^NR 1/3012011 0.00 NR i 0 NR ` NR NR 0.5 I/3112011 0.00 0.00 0 ; 2.2 1.8 0.0 '$amples 2/IR011 0.00 j 0.00 i 35,000 i 2.0 2.0 0.0 0.0 not collected because basin accumulation was associated with Brenntag released stormwater discharge. 1126/11 non -qualifying rain event that produced 0.05" of rainfall at the .............._.........._...-....._ 2220I 1 __.__-._..._..._._._...._...._...._ ......-......_._........_.............. 0.15 ... _....__._._............_._.....1........................_......:...._............_ 0.15 .........._.. 30,000 ;` 3.3 t __..............-.._........__._._....... ._..._.___:.._.._..-_...._.I..........._.._.�......, 2.8 1.5 1 1.2 _.._._.._..._......_..__..._........__...._......... fac' i� I u=?•_.._-............. _._..._.._.................... ....... _..__..�._------ _---- _�.._�_._._._..._._...__•__._._ D. Twamley on -site to collect stormwater discharge sample. -- - --._........_........ ... _._...--•---.._..-. _ - - _ _ _..._........_...__.... Dead cat floating in 4th detention basin at time of sample collection. Brenn released stotmwater disch a after sampling was com leted. ra8 _ _.._. _ _.__..... �B__- _P _-P__.E _.,..-....._....... 2fJ2011 0.00 0.00 0 2.5 2.2 0.8 0.5 2/4/2011 0.37 0.28 35,000 2.0 2.0 0.0 1 0.0 Samples not collected because <72 hours had passed since the 2/7JI l Breantag released stormwater discharge. r { rein event. 2/5/2011 OJ9 NNRR� 0� -( NR _ l NR NR NR 2162011 0.00 NR _ I 0 1 NR NR I NR �0.0 2l72011 0.00 1.00 35,000 i 2.0 ! 2.0 0.0 Basin accumulation was associated with 215/11 min event that produced Bmnnmg released stormwater discharge. j ? 1 1.0" of rainfall at the facility. Samples not collected because <72 hours had passed since the 214111 rain event. -_-T/8 2/8/2011 2/9/2011 _.. .6 _0.1 0.00 - _1 0.01 W 0.00 0 4.5 0 » 4.0 5.8 + 4,4 4.3 i 5.2 ! 3.5 i 3.4Y' 2/102011 _ _ 0.00 _ _ _.. 0.01 _ 0 3.4 3.2 ? 2.2 1.3 2/I I/2011 ( 0.00 0.00 i 0 2.4 2.0 0.8 0.5 'D. Twamley on -site to collect non-stormwater discharge sample. 2/122011 I 0.00 NR 0 NR NR NR NR _� 2/132011 2l142011 000 NR 0 00 0 00 0 NR NR NR NR 0 2 0 ; 2 0 _0.0 0 0 -- ... __ _ .»..... .......... .._ .. No disch a due to hi H. - 21152011 0,00 I 0.00 2.0 1 2.0 t 0.0 0.0 No discharge due to _ 2/16/2011 0.00 0.00 -!� _0 _ 35,000 1 2.0 2.0 0.0 ; 6.0 ? ry - v y H within tolerance. Bronntag released non-stormwatedischarge. 2/17/2011 0.00 0.00 0 3.5 6.5 5.5 ' 5.5 2/18/2011 0.00 0.00 0 3.5 5.5 4.5 4.5 _ 2/19/2011 0.00 NR 0 NR NR NR NR i _ 2202011 0.00 NR 0 NR NR NR NR 2212011 0.00 0.00 0 3.5 4.0 2.7 2.3 222/2011 0.00 0.00 0 1 3.5 4.0 2.7 2 2232011 0.00 0.00 30,0000 3.0 2.5 1.1 0.9 2242011 0.06 0.00 _ _� 0 3_5 j 5.2 j 3.8 , 3.0 Page 900 Table 1. Summary of Daily Rainfall Totals, Basin Freeboard Measurements, Stormwater / Non-Storrwater Sampling Activities, and Discharge Record for the Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina Precipitation' 2 Discharge Basin Freeboard Depths (feet)' Date nchesRain Orange Volume Basin Basin Basin Basin Sampling / Activities Conducted` Comments (inches) (inches) (gallons) ft t 8 2 !! 3 8 a 21252011 0.06 j 0.07 0 3.0 5.0 3.5 3.5 2/26/2011 0.00 NR 0 NR NR NR NR 2/272011 0.00 N- 229/2011 0.79 NR 0 NR i NR NR NR Freeboard depths not recorded. Brenntag released stormwater discharge after samples were collected 301 I 0.00 0.88 30,000 2.2 /12 i I.S ± 0,0 0.0 D. Twamley on -site to collect stormwater discharge sample Basin ;accumulation was associated with 228/11 rain event rain event that !produced 0-.9-1" o-f-ra-in-fall-athe-fi- 3220-0 00 -0-.0-0--....... .0.0-0, 0 3 5 _. -- -- ! >6 - ---------- --- 3/3201 I 0.00 0_Ol 0 3 2 j 5.8 4.3 i 4.1 ' __- -. _ _ . _._. 3/4201 t 0.00 0.00 i 0 3.0 _ 5,5 4.0 ? 5- - 3/5/2011 0.00 - NR 0 - -NR NR NR NR_- -- -- -- 3/62011 0.47 _ NR 0 NR NR NR NR- 3/72011 0.00 0.32 30,000 1.0 0.0 0.0 0.0 Brenntagreleased stormwater discharge. 3AU2011 0.00 0.01 0 3.3 6.2 5.1 4.8 _ 3/92011 0.24 NR 0 NR NR NR NR 3/102011 O.SO 0.40 30,000 1.0 - 0.0 j 0.0 0.0 _ -----_---- Breantag released stormwater discharge. -- i 3/112011 0,00 0.42 30,000 1.0 0.0� i 0.0 j 0.0 Brennta- g released stormwater discharge._ 3/122011 _ 0.00 _ I NR i 0 NR NR ? NR NR 3/132011 0.00 -- NR - 0_ NR NR NR NR 3/142011 0.00 NR ..I..--.--- - -L - 0 4 5 5.5 ,+ 4.5 4.0 -- _ . _-. - - --- - ---- ----- -_- _ _. .- - -- ---- - - _ 3/1520114 0.20 1 NR 0 I 4.0 S 0 3.5. 3.0 31162011 0.03 0.24 30 000 1 0 + 0 0 0.0 0.0 3/172011 0.01 1 .02 i 0 4.1} 6.0 i 5.2 3/182011 ! 0.00 0.00 0 3.8 5.5 4.4 n-4.0 -- 3/192011 0.00 ; NR 0 NR� -��- _...-._._i; 3202011 - 0.00 - �- NR --- j 0 - NR i_NR i NR NR -i 3212011 0.00 0.00 0 2.0 2.0 + 2.5 1 3.5 3222011 -j 0.00 j--0 00 0 2.0 2.0 0.8� 3232011 0.85 i 0.00 30,000 2.0 1.9 0.0 0.0 D. Twanfley on -site to collect non-stormwater discharge sample prior to Brenntag released non-stormwater discharge after samples were collected - 3242011 0.07 0.60 30,000 _ 2.0 0.0 0,0 0.0 rain event. impending - Brenntag released stormwater discharge associated with 323/1 I rain event. 3252011 0.00 0.02 0 3.3 7.0 5.7 1 5.3 3262011 0.39 NR 0 NR NR NR + NR 327/2011 0.06 NR + 0 NR NR NR NR 3/28/2011 0.05 0.46 0 2.2 1.8 0.0 0.0 - - 329/2011 3/30/201 I 0.01- 0.93 _ NR 0.92 j 0 35,000 �NR I.0 NR NR I_ NR 0.0 0.0 0.1 Brenntagreleased discharge. �__. - - _ --- stormwater - 3/31/2011 0.01 _ 0.04 0 L 3.3_ 3.1 ; 1.8_-.-_.-_- Notes: 1 Data retrieval from DURH station - North Durham Water Reclamation Facility (approximately 3.5 miles north of Bmmtag Facility), httpd/www nr climate.ncsu.edu/cronosl7station=DURH 2 Data retrieved from on -site min gauge and recorded by Brenntag personnel. The reported value represents the total rainfall accumulation since the last reading. Data from DURH station is fast used to determine if representative rainfall event criteria was met. Data from on -site rain gauge is used to confirm that a representative rainfall event has occurred at the site. 3 Basin freeboard depths are measured in feet from top of grate to water level. 4 The stormwater / non-stormwater sampling activities were conducted during specific time periods as per the requirements of the SOC. The first 4 month sampling period extended from April through July 20I0, followed by a 3 month period of no sampling while facility retrofits were completed, followed by the second 4 month period which extends from November 2010 through Febnuuy 2011. NA Not Available NR Not Recorded. Pave 1 of 3 Table 2. Summary of Stormwater / Non-Stormwater Sample Analytical Results from Detention Basin #4, Brenntag Southeast Facility (Former Southchem Facility); Durham; North Carolina. Sample ID-: SW(04-22-10) SW(04-26-10) Non-SW(05-07-10) SW(05-17-10) SW(05-24-10) Non-SW(06-08-10) SW(06-14-10) SW(06-23-10) Non-SW(07-06-10) SW(07-09-10) SW(07-13-10) SW(II-4-10) Non-SW(II-15-10) SW(II-17-10) SW(12-1-10) SW(12-6-10) SW(1-3-11) SW(I-13-11) SW(2-2-11) Non-SW(2-11-11) SW(3-1-11) Non-SW(3-23-11' Lab ID: 680-57005-1 680-57058-1 680-57465-1 680-57717-1 680-57936-1 680-58369-1 680-58546-1 680-58837-1 680-59153-1 680-59290-1 680-59368-1 680-62851-1 680-63190-1 680-63272-1 680-63623-1 680-63777-1 680-64502-1 680-64767-1 680-65305-1 680-65610-1 680-66071-1 680-66705-1 Date Sampled 04/22/10 04/26/10 05/07/10 05/17/10 05/24/10 06/08/10 06/14/10 06/23/10 7/6/2010 7/9/2010 7/13/2010 11/4/2010 11/15/2010 11/17/2010 12/1/2010 12/6/2010 1/3/2011 1/13/2011 2/2/2011 2/11/2011 3/1/2011 3/23/2011 Constituents NCAC 2B Standard' Metals (ua/L) (USEPA Method 200.8/245.1) Cadmium • O C 2 N s <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 Arsenic 3 <a 10 <2.5 <2.5 <2.5 2.8 2.5 3.5 2.8 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 2.9 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 Beryllium , 0 6.52 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 <0.50 Chromium ( 502 <5.0 <5.0 <5.0 5.6 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 5.1 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 Lead . 0 3 25 N s 3.8 3.6 2.7 6.1 3.6 2.6 <1.5 6.3 <1.5 2.2 1.9 4.5 1.5 9.4 5.5 4.4 5.4 9.0 4.2 4.5 4.3 1.6 Antimony , aq 5.6 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 5.9 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 6.2 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 Selenium , O166 52 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 <2.5 Thallium 0.24 <1.0 <1.0 <I.0 <I.0 <I.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <L0 <I.0 <1.0 <I.0 <1.0 Zinc � � 240 370 350 Copper�O0i 7AL s Ill 7.4 991 7?6 144 15 0 946 805 110 ?5 0 12 13 110 130 5.3 12 8 11 7.� Silver . DOI 0.06 AL' <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <L0 <I.0 <1.0 <1.0 <1.0 <1.0 <I.0 <1.0 <1.0 <I.0 <1.0 <1.0 <I.0 Nickel -7-4 88N2 \5.0k 8.2 13 5.5 <5.0 16 9.8 15 22 29 22 8.6 42 34 7.2 12 6.8 6.3 15 71 8.4 19 Mercury 12 rttY/L-, 0.012 2 <0.20 <0.20 <0.20 <020 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 <0.20 Turbidity (NTU) 50 N 2 S5 NA NA 27.4 37.4 23.9 7.4 22.8 9.9 12.6 7.71 81 9.44 1.68 63.5 0.39 0.50 0.21 NA 0.39 NA NA (USEPA 180.1) PH (SU) 6.0-9.0 N 2 6.93 HF 7.23 HF 7.83 HF 6.84 HF 7.17 HF 7.15 HF 6.61 HF 7.52 HF 7.91 HF 7.69 HF 7.76 HF 6.99 HF 7.77 HF 7.53 HF 7.20 HF 7.51 HF 8.65 HF 7.15 HF 8.21 HF 9.01 HF 7.00 HF 8.25 (USEPA Method 150.1) Conductivity (urnhos/cm) NE 200 300 570 45 66 470 260 490 570 400 380 120 550 380 110 280 1,500 690 630 820 <5.0 510 (USEPA 120.1) Ammonia (me/L) NE 0.068 0.20 <0.050 0.66 0.28 0.20 1.0 0.35 0.14 0.52 0.53 0.15 0.66 0.43 0.26 0.31 0.70 1.2 0.82 0.52 0.24 1.1 (USEPA Method 350.1) , Nitroeen (mQ/L) (USEPA Methods 351.2) Total Kjeldahl Nitrogen NE 1.7 1.5 1.0 0.98 1.2 1.3 1.5 1.7 IS 2.2 1.3 0.60 2.2 2.1 0.90 1.0 2.6 1.7 2.7 1.7 1.5 3.4 Biochemical Oxwen Demand (me/L) (USEPA Method 405.1) Total BOD R NE 170 H 61 19 12 2.9 6.0 3.8 8.0 9.3 13 5.0 24 • 2.1 7.7 11 3.2 24 17 38 19 25 4.3 Dissolved BOD NE NA NA NA 9.5 2.0 3.2 2.2 7.6 5.4 9.1 2.0 22 <2.0 5.8 10 <2.0 24 14 38 17 18 3.3 Chemical Oxvaen Demand (mg/L) (USEPA Method 410.4) Total COD i NE 340 130 73 30 26 48 30 71 69 39 64 59 43 45 25 20 98 70 110 82 51 26 Dissolved COD `' NE NA NA NA 21 <20 42 23 62 64 11 30 50 <20 31 5.7 <20 58 68 79 58 <20 30 Oganic Carbon (me/L) (USEPA Method 415.1) Total Organic Carbon NE NA NA NA NA 4.4 9.8 8.9 12 11 14 12 14 4.4 9.8 7.3 4.0 15 NA 25 15 11 NA Dissolved Organic Carbon NE NA NA NA NA 3.5 7.3 8.0 8.6 9.9 11 12 16 4.4 9.8 5.7 5.5 15 NA 23 15 11 NA HEM Oil and Grease (me/L) ?Q NE <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 9.4 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 (USEPA Method 1664A) J 30 Total Suspended Solids (ma/L) NE 24 14 9.5 62 27 26 <5.0 29 7.5 53 12 28 12 19 66 7.5 16 <5.0 14 16 45 9.5 (Standard Method 2540D) Footnotes appear on last page. Page 2 of 3 1~ _, 1 Table 2. Summary of Stormwater / Non-Stormwater Sample Analytical Results from Detention Basin 44, Brenwag Southeast Facility (Former Southchem Facility), Durham, North Carolina. ('_-- Sample ID A: SW(04-22-10) SW(04-26-10) Non-SW(05-07-10) SW(05-17-10) SW(05-24-10) Non-SW(06.08-10) SW(06-14-10) SW(06-23-10) Non-SW(07-06-10) SW(07-09-10) SW(07-13-10) SW(II-4-10) Non-SW(I1-15-10) SW(11-17-10) SW(12-1-10) SW(12-6-10) SW(I-3-11) SW(1-13-11) SW(2-2-11) Non-SW(2-11-11) SW(3-1-11) Non-SW(3-23-11) Lab ID: 680-57005-1 680-57058-1 680-57465-1 680-57717-1 680-57936-1 680-58369-1 680-58546-1 680-58837-1 680-59153-1 680-59290-1 680-59368-1 680-62851-1 680-63190-1 680-63272-1 680-63623-1 680-63777-1 680-64502-1 680-64767-1 680-65305-1 680-65610-1 680-66071-1 680-66705-1 1-- Date Sampled 04/22/10 04/26/10 05/07/10 05/17/10 05/24/10 06/08/10 06/14/10 06/23/10 07/06/10 7/9/2010 7/13/2010 11/4/2010 11/15/2010 11/17/2010 12/1/2010 12/6/2010 1/3/2011 1/13/2011 2/2/2011 2/11/2011 3/1/2011 3/23/2011 Constituents NCAC2B { Standard ? Volatile Orsanics (ue/L) (USEPA Method 624) Acetone 2,0002 120 <25 32 39 42 53 <25 59 <25 <25 <25 29 43 73 <25 <25 380 100 180 1,400 190 78 Benzene 1.19 <1.0 <1.0 <1.0 <I.0 <1.0 <1.0 <1.0 <1.0 <1-0 <1.0 <1.0 <I.0 <I.0 <1-0 <1.0 <1.0 <7-0 <I.0 <1.0 <5.0 <1.0 <1.0 Bromadichloromethane 0.55 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 2.9_ <1.0 <10 <1-0 <1.0 <1.0 <1.0 <1.0 <1.0 C- , 17 _ - 1.4 = i <5.0 <1.0 <1.0 Bromofo n 4.3 <1.0 <I.0 <1.0 <1.0 <1.0 <1.0 <1-0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1-0 <I-0 <1-0 <1-0 <5.0 <1.0 <1.0 Bromomethane 47 <1.0 <I.0 <1.0 <1.0 <1.0 <I0 <1-0 <1.0 <1,0 <1.0 <1.0 <1.0 <1.0 <1.0 <I-0 <1-0 <1.0 <1-0 <I-0 <5.0 <1.0 <1.0 Carbon tetrachloride 0.254 <1.0 <1.0 <I.0 <1.0 <1.0 <1.0 <1-0 <1.0 <I-0 <1-0 <1.0 <1.0 <1.0 <1.0 <LO <1-0 <1.0 <10 <10 <5-0 <1.0 <1.0 Chlorobenzene 130 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <I-0 <10 <1.0 <1.0 <1.0 <1.0 <1.0 <1-0 <1.0 <1.0 <1.0 <5-0 <1.0 <1.0 Chloroethane 12 <1.0 <1.0 <I.0 <1.0 <LO <I.0 <1.0 <1.0 <1.0 <1-0 <1.0 <1-0 <1.0 <1.0 <1.0 <1-0 1.5 <1.0 <1.0 14 <1.0 <1.0 Chloroform 5.6 3.4 5.2 5.5 <1.0 <1.0 4.1 2.1 27 - <1.0 1.1 1.1 <I.0 4.7 4.0 <1.0 3.0 22 21 29 41 1.1 4.4 Chlommethane 2.6 <1.0 <1.0 <1.0 <1.0 <1.0 <l0 <I.0 <1.0 <1.0 <1-0 <1-0 <I.0 <I-0 <1.0 <I.0 <1.0 <1.0 <L0 <1.0 <5.0 <1.0 <I.0 Dibromochloromethane 0.4 <1.0 <I.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <I-0 <1-0 <1.0 <I.0 <10 <I.0 <1.0 <1.0 <I.0 <1.0 <1.0 <5.0 <1.0 <1.0 1.1-Dichloroethane 6,700 1.4 3.3 <I.0 <1.0 <1.0 1.5 1.5 <I.0 <10 <1.0 <1.0 3.2 <1-0 1.6 1.0 1.5 4.7 <LO 3.9 21 2.4 1.6 112-Dichloroethane 0.38 <1.0 <1.0 <1.0 <I.0 <1.0 <1.0 <1.0 <1-0 <I-0 <I.0 <1.0 <1.0 <I-0 <1-0 <1.0 <1.0 <1-0 <1.0 <10 <5.0 <1.0 <I.0 1, 1 -Dichloroethene 330 <LO <1.0 <1.0 <1.0 <1.0 <1.0 <I.0 <1-0 <1.0 <10 <1.0 <1,0 <1-0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <5.0 <1.0 <1.0 1,2-Dichloropropane 0.5 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <I.0 <1.0 <10 <I.0 <10 <I-0 <1-0 <1.0 <I-0 <1.0 <1.0 <1.0 <5.0 <1.0 <1.0 { 1,3-Dichloropropane (total) NE <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2.0 <2-0 <1.0 <2.0 Q-0 <2.0 <2.0 <2-0 <2.0 <2.0 <2.0 <10 <2.0 <2.0 Ethylbenzene 972 <1,0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1,0 <1.0 <1.0 <1.0 <1.0 <I.0 <1.0 <1.0 <50 <1.0 <1.0 Methylene Chloride 4.6 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <5.0 <50 <5.0 <5.0 <5.0 <5.0 <5-0 <5.0 <5-0 <50 <5.0 <5-0 <25 <5.0 <5.0 1,1,2,2-Tetrachloroethane 0.17 <1.0 <1.0 <1.0 <1.0 <1.0 <I.0 <1.0 <1.0 <I-0 <1.0 <1.0 <10 <1.0 <1-0 <I.0 <I-0 <I.0 <1,0 <I-0 <5-0 <1.0 <1.0 Tetrachloroethene 0.7 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <I.0 <I-0 <1.0 <I0 <1.0 <LO <LO <I-0 <1-0 <1.0 <1-0 <5.0 <1.0 <1.0 Toluene 17 2 <L0 <L0 <Lp <1 0 <1 0 <1.0 <1.0 a1.0 <Lp <l-0 <1.0 3.8 q0 <1.0 <l-0 <1-0 4.9 <1.0 2.8 ( 1 . ' 2.5 <1.0 trans-1,2-Dichloroethene 140 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <LO <1.0 <1.0 <1.0 <LO <1.0 <1-0 <1.0 <I.0 <1-0 <50 <I.0 <1.0 1,1,1-Trichloroethane 2,500- <1.0 1.1 <I.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <I.0 4.4 <1.0 1.4 <10 <1-0 11 <1.0 6.1 45 3.8 1.8 1 1,1,2-Trichloroethane 0.59 <1.0 <1.0 <I.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <10 <I.0 Q-0 <1.0 <1.0 <1.0 <1-0 <1.0 <1.0 <1.0 <5.0 <1-0 <1.0 Trichloroethene 2.5 <1.0 <1.0 <1.0 <1.0 <1.0 <I.0 <1.0 <1,0 <1.0 <1.0 <1.0 <10 <I.0 4.0 <1.0 <1.0 <1.0 <1.0 <LO 52 - <1-0 <1.0 Vinyl Chloride 0.025 <L0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <1.0 <I-0 <1.0 l.6 _ <1-0 <1.0 <1.0 <1-0 <1.0 <1.0 <1.0 11 j <1-0 <1.0 I' Semi-Volatiles (ue/L) (USEPA Method 625) 2,4,6-Trichlorophenol 1 N <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <10 <10 1( 2,4-Dichlorophenol I N <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <10 <10 2,4-Dimethylphenol 320N2 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <iO <10* <10* <9.8 H* <10* <10* 2,4-Dinitrophenol 26 N 2 <50 <50 <49 <50 <48 <48 <48 <49 <50 <48 <50 <47 <49 <48 <48 <50 <50 <50* <50 <49 H <52 <50* 2-Nitrophenol 8,000 N 2 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 [ 4,6-Dinitro-2-methylphenol 12 N 2 <50 <50 <49 <50 <48 <48 <48 <49 <50 <48 <50 <47 <49 <48 <48 <50 <50 <50 <50 <49 H <52 <50 4-Chloro-3-methylphenol 7 N <10 <10 <9.8 <10 <9,5 <9.5 <9.5 <9.7 <10 <9-5 QO <9.4 <9.8 <9.5 <95 <10 <10 <10 <10 <9.8 H <10 <10 4-Nitrophenol 270' <150 <150 <49 <50 <48 <48 <48 <49 <50 <48 <50 <47 <49 <48 <48 <50 <50 <50 <50 <49 H <52 <50 Pentachlorophenol 0.27 <50 <50 <49 <50 <48 <48 <48 <49 <50 <48 <50 <47 <49 <48 <48 <50 <50 <50 <50 <49 H <52 <50 r Phenol 300 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9-7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 2-Chlorophenol IN <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9-7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 1,2,4-Trichlorobenzene 35 , <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9-7 <10 <9-5 <10 <9A <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 1,2-Dichlorobenzene 420, <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <93 <10 <9.5 <10 <9-4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 1,2-Diphenylhydrazine 0.036 <10 <10 <9.8 <10 <9.5 <95 <9.5 <93 <10 <9-5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 t 1,3-Dichlorobenzene 320 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9J <10 <9-5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 1,4-Dichlorobenzene 63, <10 <10 <%8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 2-Chloronaphthalene 1,000 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <95 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 2,6-Dinitrotoluene ' 0.048 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9-7 <10 <9.5 <10 <9.4 <9-8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 E 2,4-Dinitrotoluene : ' 0.11 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <95 <10 <9.4 <9-8 <9-5 <95 <10 <10 <10 <10 <9.8 H <10 <10 3,3'-Dichlorobenzidine 0.'021 <60 <60 <59 <60 <57 <57 <57 <58 <60 <57 <60 <57 <59 <57 <57 <60 <60 <60 <60 <59 H <62 <60 4-Bromophenyl phenyl ether NE , ,; <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9-8 <95 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 4-Chlomphenyl phenyl ether NE' <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9-8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Acenaphthene 20 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <94 4.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Acenaphthylene NE.." <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9-4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Anthracene 0.05,2 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9-8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Benzidine 0.000086 ` <80 <80 <78 <80 <76 <76 <76 <78 <80 <76 <80 <75 <78 <76 <76 <80 <80 <80 <80 <78 H <83 <80 Benzo[a]anthracene U028 <-10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9-5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 ' Benzo[a]pyrene 0.0028 . <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <%7 <10 <9.5 <10 <9-4 <9-8 <9-5 <9.5 <10 <10 <10 <10 <%8 H <10 <10 Benzo[b]fluoranthene 0.0028 <10 Up <9.8 <10 <9.5 <9.5 <9.5 <%7 <10 <9.5 <10 <9-4 <9-8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 t - Benzo[g,h,i]perylene NE <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9A <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Benzo[k]fluoranthene 0.0028 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Footnotes appear on last page. Page 3 of 3 Table 2. Summary of Stormwater / Non-Stormwater Sample Analytical Results from Detention Basin 44, Brenmag Southeast Facility (Former Southchem Facility), Durham, North Carolina Sample ID": Lab ID: Date Sampled SW(04-22-10) 680-57005-1 04/22/10 SW(04-26-10) Non-SW(05-07-10) SW(05-17-10) 680-57058-1 680-57465-1 680-57717-1 04/26/10 05/07/10 05/17/10 SW(05-24-10) Non-SW(06-08-10) SW(06-14-10) 690-57936-1 680-58369-1 680-58546-1 05/24/10 06/08/10 06/14/10 SW(06-23-10) Non-SW(074)6-10) SW(07-09-10) 680-58837-1 680-59153-1 680-59290-1 06/23/10 07/06/10 7/9/2010 SW(07-13-10) 680-59368-1 7/13/2010 SW(11-4-10) 680-62851-1 11/4/2010 Non-SW(11-15-10) SW(H-17-10) 680-63190-1 680-63272-1 11/15/2010 11/17/2010 SW(12-1-10) 680-63623-1 12/1/2010 SW(12-6-10) 680-63777-1 12/6/2010 SW(I-3-11) 680-64502-1 1/3/2011 SW(I-13-11) 680-64767-1 1/13/2011 SW(2-2-11) 680-65305-1 2/2/2011 Non-SW(2-11-11) 680-65610-1 2/11/2011 SW(3-1-11) 680-66071-1 3/1/2011 Non-SW(3-23-11) 680-66705-1 3/23/2011 Semi-Volatiles(ue/L) NCAC2B (USEPA Method 625) Standard t Bis(2-chloroethoxy)methane 100 <10 <10 <9.8 <10 <9.5 <9-5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Bis(2-chloroethyl)ether „0.03 <10 <10 <9.8 <10 <9.5 <9-5 <9.5 <9.7 <10 <95 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <10 <10 Bis(2-ethylhexyl) phthalate 1.2 <10 <10 <9.8 <10 <9.5 <9-5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Butyl benzyl phthalate 19Z, <10 QO <9.8 <10 <9.5 <9.5 <9.5 <9.7 <IO <9.5 <IO <9.4 <9.8 <9-5 <9.5 <IO <10 <10 <10 <9.8 H <10 QO Chrysene 0.0028 <10 <10 <9.8 <10 <9.5 <9-5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Di-n-butyl phthalate 9.5 2 <10 <10 <9.8 <10 <9.5 <9-5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9-5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Di-n-octyl phthalate 900 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <9-5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Dibenz(a,h)anthracene 0.6028 ' <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <95 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Diethyl phthalate 1,200 21 <10 <10 <9.8 <10 <9.5 <9.5 <9-5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9-5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Dimethyl phthalate 3,400 2 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Fluoranthene 0.112 ' <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <%7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Fluorene 462, <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8H <10 <10 Hexachlorobenzene 0.0028 <10 <IO <9.8 q0 <9.5 <9.5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <10 <10 Hexachlorobutadiene 0.44' <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <10 <10 Hexachlorocyclopentadiene 1"" <20 QO <20 <20 <19 <19 <19 <19 <20 <19 <20 <19 <20 <19 <19 <20 <20 <20 <20 <20 H <21 <20 Hexachloroethane 1.4 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9-5 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <10 <10 Indeno[1,2,3-cd]pyrene 0.0028 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Isophorone 35 ` <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <10 <10 N-Nitrosodi-n-propylamine 0.005 <I0 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <I0 <9-5 <10 <9.4 <9.8 <9.5 <9-5 <10 <10 <10 <10 <9.8 H <I0 <10 N-Nitrosodimethylamine 0.00069 <20 <20 <20 <20 <19 <19 <19 <19 <20 <19 <20 <9.4 <20 <19 <19 <20 <20 <20 <20 <20 H <21 <20 N-Nitrosodiphenylamine 3.3 <10 <10 <9.8 <10 <9 5 <9 5 <9 5 <9.7 <10 <9-5 -'10 <9A <9-8 <9-5 <9,5 <10 <10 <10 <10* <9.8 H <10 <10 Naphthalene 3302 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <95 <9.5 <10 <10 <10 <10 <9.8H <10 <10 Nitrobenzene 17 ,' <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9-5 <9.5 <10 <0 <10 <10 <9.8 H <10 <10 Phenanthrene NE <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <95 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 Pyrene 830' <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9A <9.8 <95 <9.5 <10 <10 <10 <10 <9.8 H <10 <10 2,4-Dimethylphenol 320N2 <10 <10 <9.8 <10 <%5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <9.5 <9.5 <10 <10 <10 <10 <9.8H <10 <10 bis(chloroisopropyl) ether 0.0001 <10 <10 <9.8 <10 <9.5 <9.5 <9.5 <9.7 <10 <9.5 <10 <9.4 <9.8 <95 <9-5 <10 <10 <10 <10 <9.8 H <I0 <10 Notes: A Samples are collected from the 4th of four 10,000 gallon stonnwater detention basins. I 15A NCAC 2B surface water quality standards for water supply classifications as adopted per 15A NCAC 2B or National Criteria per USEPA (Redbook standards effective May 1, 2007 and updated February 5, 2010). 2 15A NCAC 2B surface water quality standards for freshwater aquatic life classifications as adopted per 15A NCAC 2B or National Criteria per USEPA (Redbook standards effective May 1, 2007 and updated February 5, 2010). µg/L Micrograms per liter. mg/L Milligrams per liter. µmhos/cm Micromhos per centimeter 31 Constituent was detected above the quantitation limit. Concentration exceeded NCAC 2B Standard. NE NCAC 2B or National Criteria per USEPA Standard Not Established. NA Not Analyzed. AL Action Level Standard - see 2B.0211 for additional information. N Narrative Standard See 2B.0211. HF Field Parameter with holding time of 15 minutes. H Sample was prepped or analyzed beyond the specified holding time. * Laboratory Control Spike (LCS) or LCS-Duplicate exceeded the control limits. Page 1 of 3 M" tM a� arm Mft rja low rq am Ina use MM Table 3. Summary of industrial Process Water Accumulation, Sampling, and Disposal Information, Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina. Date AST Volume (gallons) Sampling / Activities Conducted' Comments 1 I/l/2010 8,000 I 11/3/2010 12,000- 11/4/2010 <1,000 D. Twam!ey on -site to collect process water sample. _ Process water hauled off -site for disposal after samples were collected. 11/5/2010 <1,000 i 11/612010 NR 11/7/2010 NR- 11/8/2010 12,000 11/9/2010 <1,000 - - -------- Process water. hauled offsite for 11/10/2010 <1,000 11/11/2010 <1,000 _ 11/12/2010 <1,000 D. Twaml on -site to collect process water sample, - -- 11/13/2010 NR ---- --__ _ 11/14/2010 NR--__-�- 11/15/2010 6,000 ! 11/16/2010 15,000 _ 11/17/2010 <1,000 !Process water hauled ofT site for disposal. 11/18/2010 <1000 �- 11/19/2010 12,000 D. Twamle on -site to collect process water sample.-_- 11/20/2010 NR 11/21/2010 NR- 1 1/22/2010 10,000 l 1/23/2010 6,600 D. Twand on -site to collect process water sample.- 11/24/2010 13,500 11/25/2010 NR _ Volume not recorded due to Holiday. 11126/2010 NR - Volume not recorded due to Holiday. 1U27/2010 NR .____.. -._ 11/28/2010 NR I - 11/29/2010 13,500 11/3012010 15,000 12/1/2010 <1,000 D. Twam!ey on -site to collect process water sample. !Process water hauled off -site for disposal after samples were collected. - 12/2/2010 16,000 -1-�- _ _ _ _ _ _ y u _^Process - water hauled off -site for vsal. 12/3/2010 16,000 12/4/2010 NR 12/5/2010 NR 12/6/2010 5,000 -^- { 12/7/2010 6,600 12/8/2010 13,500 D. Twaml on -site to collect process water sample. _ Process water hauled off -site for disposal after samples were collected. 12/9/2010 5,000 i 12/10/2010 13,500 12/11/2010 NR ! 12/12/2010 NR T 12/13/2010 6,600 12/14/2010 6,600 12115/2010 6,600 12/16/2010 ...._-- _-- 12/17/2010 _- 13,300 13,300 -- - ___.-.__._.._.__ - ... ----- -- ----_ ._ _. Process water hauled off site for disposal_ -- --�� 12/1912010 NR 12/19/2010 NR 12/20n010 to 00o.12/21/2010 6,600 12/22/2010 1 6.600 i 12/25/2010 NR 12/26/2010 _ NR 12/27/2010 <1 0t 12/29/2010 <10( 12/29/2010 18,0C 12/30/2010 <1,0( 12/31/2010 NR 1/l/2011 NR -~1/2/2011 NR 1/3/2011- -- 6,60 1/4/2011 16,0( ne not recorded due to Hot ne not recorded due to Hot ss water hauled off -site for ss water hauled off -site for ss water hauled off -site for ne not recorded due to Hot MR on ftp2orl Table 3. Summary of Industrial Process Water Accumulation, Sampling, and Disposal Information, Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina. Date AST Volume Sampling / Activities Conducted' Comments ® (ttallons) P 8 am FAR 1/5/2011 <1,000 _— -__ Process water hauled off site for disposal. - 1/62011 10 000 1172011 16,000 ---^ 1182011 NR _ 1/92011 NR - 11102011 13300 -�-'~ ---•--•-•--.-._._.....__-_._____. _ _u.._.- 1/112011 15,000_-- 1/122011 <1000 Process water hauled off -site for disposal. - 1/132011 1/142011 4,000 8,000 —• - 1/152011 1/16/2011 NR NR - __ _..._ _ _ _ 1/172011 --10000 1/12011 10000 -1/192011 10,000 -1202011 13,300 1212011 NR_- 1/232011 NR — /2011 6,600 - 1/242011 ,600 1/262011 13,300 -1272011 16 000 _ —` Process water hauled ofi site for disposal -_ -�- - -- 1282011 10 000 1/29/2011 NR - NR -1130/2011 2011 _ 2/12011 12,000 Process water hauled off -site for disposal. 222011 4,000 /32 2011 8,000 - 2/42011 _ 10,000 _._..- -^ -� Process water hauled off -site for disposal.-----�____ 2/52011 NR _ - �...._... __.._........ _._ ____.._.,.._ _.... ___ _ __....__-.__.,.......... _... 2i62o1 l 2/72011 -- NR 6,600 2/8/2011 2/9201 i _... _ 2/102011 j 8,000 1Q000 _ _ 12,000 . . _.....__ _. ..__..__.,._,__. _ - 2/112011 16 000 - Process water hauled off -site for disposal. � 2/122011 _.. 2011 2/13 NR -.- NR .__----_-._..-.-, ...._ . .. ..........-------- _ _M- 2/IS2011 — NR 2/1612011 NR NR _2/172011 2/182011 NR 2/192011 NR _—_- NR .......................__..._..__.._..____.___...._---.--..._.__._._..... -- ... _... _._._.... _...-..._......_.. 2t2 2011 6,600 _ 2/222011 6,600 2232011 10,000 __...._-- 2_242011 13,300 2252011 12,000 -_ —� Process water hauled off -site for dispo sal. _ 2262011 NR _ 2272011 3/112011 3/22011 _...-__ 6,600 6,600 __ _ _ _ .._ _......_ _ ._.-. - -____......... ...................... ... _ --...... _ ....... 3/32011 3/42011 3/5l2011 _.,___._- 3/92011 3/92011 _ 3/10/2011 10,000 10,900 NR NR - - - 9,000 NR 12 000 VIM Page 3 of 3 FM Table 3. Summary of Industrial Process Water Accumulation, Sampling, and Disposal Information, Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina. Date AST Volume Sampling / Activities Conducted' Comments (gallons) p 8 am "M r. awn ar am oft MON WI-71 3/11/2011 15,000 _ J� —, ,Process water hauled off -site for disposal. 3/12/2011 NR- 3/13/2011 NR 3/15/2011 4 OOD_� 3/16/2011 4 ,000 3/1/2011 ,000 3/18/2011 8 000 _ Trocess water hauled off -site for disposal. _ 3/19/2011 NR _ 3/20/2011 NR 3/21/2011 6 600 _ 3/23/2011 12.000 3/24/2011 _ 16,000 — - _ ]Process water hauled off -site for disposal. —� 3/25/2011 8,000 _ _- 3/26/2011 NR I 3l27/2011 _ NR 3/28/2011 6 600 3/29/2011 6,600 3/30/2011 8,000 3/31/2011 10,000 � 4/1/2011 12 000 Notes: 1 The process water sampling activities were conducted during a specified 6 week time period as per the requirements of the SOC. The sampling period was initiated following completion of facility retrofits which extended from November 1 through December 12, 2010. NR Not Recorded. Page I of 3 Table 4. Summary of Industrial Process Water Sample Analytical Results from Above Ground Storage Tank, Brenntag Southeast Facility (Former Southchcm Facility), Durham, North Carolina. Sample ID': PW (11-4-10) PW (11-12-10) PW (H-19-10) PW (11-23-10) PW (12-1-10) PW (12-8-10) Lab ID: 680-62854-1 680-63147-1 680-63377-1 680-63470-1 680-6329-1 680-63883-1 Date Sampleds: 111041€ 0 1 1 / 121l0 l 1119/ 10 11/23/10 12/01 / l0 12/08/10 Constituents NCAC 2B Standard' Metals(uQ/L) (USEPA Method 200.8/245.1) Cadmium 2 N 2 NA <1.0 NA NA 0.99 NA Arsenic 10 NA <5,0 NA NA 12 NA Beryllium 6.5 z NA <1.0 NA NA <0.50 NA Chromium 502 NA 78 NA NA 2,100 NA Lead 25 N 2 NA 13 NA NA 23 NA Antimony 5.6 NA <10 NA NA 16 NA s.. Selenium 5 2 NA <5.0 NA NA 3.3 NA Thallium 0.24 NA <2.0 NA NA <1.0 NA Zinc 50 AL 2 NA 11800 NA NA 3,700 NA Copper 7 AL 2 NA 210 NA NA 380 NA Silver 0.06 AL' NA <2.0 NA NA 3.5 NA Nickel 88 N 2 NA 150 NA NA ,40 10 NA Mercury 0.012, NA <020 NA NA 0.21 NA Turi)idity (NT11) SON' NA 50 NA NA 1G8 NA (USEPA Method 180.1) Fp l (SU) 6.040 N 2 7.29 HF 6.60 HF 6.80 HF 7.73 HF 6.47 HF 8.05 HF (USEPA Method 150.1) Conductivity (umhoslcm) NE 24,000 20,000 20,000 420 21,000 44,000 (US EPA Method 120.1) Ammonia (me/1..) NE 160 260 NA NA 470 0.84 (USEPA Method 350 1) Total Kieldahl Nitrogen (me/L) NE 400 490 NA NA 210 <0.20 (USEPA Method 351.2) Biochemical Oxyeen Demand (mtt[L) NL'• 6,700 9,600 NA NA 3,100 7,700 (USEPA Method 405.1) Chemical Oxyeen Demand (me/L) NE 101000 " 12,000 NA NA 10,000 12,000 (USEPA Method 410.4) HEM oil and Grease (me/L) NEE NA <5.0 NA NA 21 NA (USEPA Method 1664A) Total Suspended Solids fm__ e%L) NE 180 63 NA NA 280 760 (Standard Method 2540D) Footnotes appear on last page. w^ GAENV55outhchemlNC 105024.0007NQaanerly Progress ReponsiN l J January - MarchlTables\Excel Files\Table 4 Summary of Process Water Analytical Results xlsx Page 2 of 3 Table 4. Summary of Industrial Process Water Sample Analytical Results from Above Ground Storage Tank, Brenntag Southeast Facility (Former Smirch= Facility), Durham, Noah Carolina. Sample ID ,. PW (11-4-10) PW (11-12-10) PW (I1-19-10) PW (11-23-10) PW (12-1-10) PW (12-8-10) Lab ID; 680-62854-1 680-63147-1 680-63377-1 680.63470-1 680-6329-1 680.63883-1 Date Sampled n: 11/04/10 11/12/10 11/19/10 11/23/10 12/01/10 12/08/10 Constituents NCAC 2B Standard Volatile 4reanics Ine/L (USEPA Method 624) Acetone 2,0002 NA 1,100 NA NA 720 NA Benzene 1.19 NA <5.0 NA NA <5.0 NA Bromodichloromethane 0.55 NA <5.0 NA NA <5.0 NA Bromoform 4.3 NA <5.0 NA NA <5.0 NA Bromomethane 47 NA 52 NA NA <5.0 NA Carbon tetrachloride 0.254 NA <5.0 NA NA <5.0 NA Chlorobenzene 130 NA <5.0 NA NA <5.0 NA Chloroethane 12 NA <5.0 NA NA <5.0 NA Chloroform 5.6 NA 39 NA NA 130 NA Chloromethane 2.6 NA 270 NA NA 22 NA Dibromochloromethane 0,4 NA <5.0 NA NA <5.0 NA I,l-Dichloroethane 6,700 NA <5.0 NA NA <5.0 NA 1,2-Dichlaroethane 0.38 NA <5.0 NA NA <5.0 NA 1,1-Dichloroethene 330 NA <5.0 NA NA <5.0 NA 1,2-Dichloropropane 0.5 NA <5.0 NA NA <5.0 NA 1,3-Dichloropropane (total) NE NA <10 NA NA <10 NA Ethylbenzene 971 NA <5.0 NA NA <5.0 NA Methylene Chloride 4.6 NA <25 NA NA <25 NA 1,1,2,2-Teirachloroethatre 0.17 NA <5,0 NA NA <5.0 NA Tetrachloroethene 0,7 NA 7.7 NA NA <5.0 NA Toluene III NA <5.0 NA NA <5.0 NA trans-1,2-Dichloroethene 140 NA <5.0 NA NA <5.0 NA 1,1,1-Trichloroethane 2,500z NA <5,0 NA NA <5.0 NA 1,1,2-Trichloroethane 0.59 NA <5,0 NA NA <5.0 NA Trichloroethene 2.5 NA <5,0 NA NA <5.0 NA Vinyl Chloride 0.025 NA <5.0 NA NA <5.0 NA Semi-Volatiles (uelL) (11SEPA Method 625) 2,4,6-Trichloroplrenol i N NA <9.7 NA NA <9.9 NA 2,4-Dichlorophenol I N NA <9.7 NA NA <9.9 NA 2,4-Dimethylphenol 320 N' NA <9.7 NA NA <9.9 NA 2,4-Dinitrophenol 26 N z NA <49 NA NA <50 NA 2-Nitropbenol 8,000 N' NA <9.7 NA NA <9.9 NA 4,6-Dinitro-2-methytphenol 12 N' NA <49 NA NA <50 NA 4-Chloro-3-me1hylphenol I N NA <9.7 NA NA <9.9 NA 4-Nitrophenol 270 NA <49 NA NA <50 NA Pentachlorophenol 0.27 NA <49 NA NA <50 NA Phenol 300 NA <9.7 NA NA 190 NA 2-Chloroplrenol 1 N NA <9.7 NA NA <9.9 NA 1,2,4-Trichlorobenzene 35 NA <9.7 NA NA <9.9 NA 1,2-Dichlorobenzene 420 NA <9.7 NA NA <9.9 NA 1,2-Diphenylhydrazine 0.036 NA <9.7 NA NA <9,9 NA 1,3-Dichlorobenzene 320 NA <9.7 NA NA <9.9 NA 1,4-Dichlorobenzene 63 NA <9.7 NA NA <9.9 NA 2-Chloronaphthalene 1,000 NA <9.7 NA NA <9.9 NA 2,6-Dinitrotoluene 0.048 NA <9,7 NA NA <9,9 NA 2,4-Dinitrotoluene 0.11 NA <9.7 NA NA <9.9 NA 3,Y-Dichlorobenzidine 0,021 NA <58 NA NA <59 NA Footnotes appear on last page Page 3 of 3 Table 4. Summay of Industrial Process Water Sample Analytical Results from Above Ground Storage Tank, Brenntag Southeast Facility (Former Soulhchem Facility), Durham, North t.arolina, Sample [D": PW (11-4-10) PW (11-12-10) PW (11-19-10) PW (11-23-10) PW (12-1-10) PW (12-8-10) Lab ID: 680-62854-1 680-63147-1 680-63377-1 680-63470-1 680.6329-1 680-63883.1 Date Sampled';: 11/04/10 11/12/10 11/19/10 11/23/10 12/01110 12/08/10 4-Bromophenyl phenyl ether NE NA <9.7 NA NA <9.9 NA 4-Chlorophenyl phenyl ether NE NA <9.7 NA NA <9.9 NA Acenaphthene 20 NA <9.7 NA NA <9.9 NA Acenaphthylene NE NA <9.7 NA NA <9.9 NA Anthracene 0.052 NA <9.7 NA NA <9.9 NA Benzidine 0.000086 NA <79 NA NA <79 NA Benzo[a]anthracene 0.0028 NA <9.7 NA NA <9.9 NA Benzo[a]pyrene 0.0028 NA <9.7 NA NA <9.9 NA Benzo[b]tluormthene 0.0028 NA <9.7 NA NA <99 NA Benzo[gjijjpetylene NE NA <9.7 NA NA <9.9 NA Benzo[k](luoranihene 0.0028 NA <9.7 NA NA <9.9 NA Bis(2-chloroethoxy)methane 100 NA <9.7 NA NA <9.9 NA Bis(2-cliloroethyl)ether 0.03 NA <9.7 NA NA <9.9 NA Bis(2-ethylhexyl) phthalate 1.2 NA <9.7 NA NA 39 NA Butyl benzyl phthalate 192 NA <9.7 NA NA <9.9 NA Chrysene 0.0028 NA <9.7 NA NA <9.9 NA Di-n-butyl phthalate 9.5 2 NA <9.7 NA NA <9.9 NA Di-n-octy) phthalate 900 NA <9.7 NA NA <9.9 NA Dibenz(a,h)anthracene 0.0028 NA <9.7 NA NA <9.9 NA Diethyl phthalate 1,200 r NA <9.7 NA NA <9.9 NA Dimethyl phthalate 3,4002 NA <9.7 NA NA <9.9 NA Fluoranthene 0.117 NA <9.7 NA NA <9.9 NA Fluorene 46 z NA <9.7 NA NA <9.9 NA Hexachlorobenzene 0.0028 NA <9.7 NA NA <9.9 NA Hexachlorobutadiene 0.44 NA <9.7 NA NA <9.9 NA Hexachlorocyclopentadiene I NA <19 NA NA QO NA Hexacltloroethanc IA NA <9.7 NA NA <9.9 NA lndeno[1,2,3-cd]pyrene 0.0028 NA <9.7 NA NA <9.9 NA Isophorone 35 NA <9.7 NA NA <9.9 NA N-Nitrosodi-n-propylamine 0.005 NA <9.7 NA NA <9.9 NA N-Nitrosodimethylamine 0.00069 NA <19 NA NA <20 NA N-Nitrosodiphenylamine 3.3 NA 19.7 NA NA <9.9 NA Naphthalene 330 NA <9.7 NA NA <9.9 NA Nitrobenzene 17 NA <9 7 NA NA <9.9 NA Phenanthrene NE NA <9.7 NA NA <9,9 NA Pyrene 830 NA <9.7 NA NA <9.9 NA 2,4-Dimethylphenol 320 N'- NA <9.7 NA NA <9.9 NA bis(chloroisopropyl) ether ODOM NA <9.7 NA NA <9.9 NA Notes: A Samples are collected directly from the 20,000 gallon above ground storage lank used to store process water at the Facility. B The process water sampling activities were conducted during a specified 6 week time period as per the requirements of the SOC The sampling period was initiated following completion of facility retrofits which extended from November 1 through December 12, 2010. i 15A NCAC 2B surface water quality standards for water supply classifications as adopted per 15A NCAC 2B or National Criteria per USEPA (Redbook standards effective May 1, 2007 and updated February 5, 2010). 2 I5A North Carolina Administrative Code 2B surface water quality standards for freshwater aquatic life classifications as adopted per 15A NCAC 2B or National Criteria per USEPA (Redbook standards elective May 1, 2007 and updated February 5, 2010). µg/L Micrograms per liter. mg(L Milligrams per liter. pmhosrcm Micromhosper centimeter 31 Constituent was detected above the quantization limit. Concentration exceeded NCAC 2B Standard. NE NCAC 2B or National Criteria per USEPA Standard Not Established. NA Not Analyzed. AL Action Level Standard - see 2B.02I1 for additional information, N Narrative Standard See 2B.021 I. HF Field Parameter with holding time of 15 minutes. Laboratory Control Spike (I -CS) or LCS-Duplicate exceeded the control limits. Page I of 3 Table 5. Summary of Durham City Water Sample Analytical Results, Brenntag Southeast Facility (Former Southchem Facility), Durham, North Carolina, Sample ID: Durham City Water Durham City Water Durham City Water Durham City Water BFV Acid Area Caustic Area Hydrant Lab113: 680-64651-1 680-64651-2 690-64651-3 680-646514 Date Sampled; I/712011 1/7/201 1 1/7/2011 117/201 l Constituents NCAC 2B Standard' Metals (uelL) (USEPA Method 200.8/245.1) Cadmium 2 N 2 <0.50 <0.50 <0.50 <0.50 Arsenic 10 <2.5 <2.5 <2.5 <2.5 _ Beryllium 6.5 2 <0.50 <0.50 <0.50 <0.50 Chromium 502 <5.0 <5.0 <5.0 <5.0 Lead 25 N 2 2.0 <1.5 <1.5 9.0 Antimony 5.6 <5.0 <5.0 <5.0 <5.0 Selenium 5 2 <2.5 <2.5 <2.5 <2.5 Thallium 0.24 <1.0 <1.0 <1.0 <1.0 Zinc 50 AL z 750 1,200 1,100 420 Copper 7 AL 2 17 <5.0 <5.0 30 Silver 0.06AL2 <1-0 <1.0 <1.0 <1.0 Nickel 88 N 2 <5.0 <5.0 <5.0 27 Mercury 0.012 2 <0.20 <0.20 <0.20 <0.20 Turbidih- (NTU) 50 N 2 NA NA NA NA (USEPA 180.1) [a I (SU) 6.0-9.0 N 2 7.52 HF NA NA NA (USEPA Method 150.1) Conductivitv (umhos/cm) NE 200 NA NA NA (USEPA 120.1) Ammonia (mWL) NE 0.81 NA NA NA (USEPA Method 350.1) Nitrogen (melL) (USEPA Methods 351.2) ... Total Kjeldahl Nitrogen NE 0.95 NA NA NA Biochemical Oxyeen Demand (mg/L) (USEPA Method 405. I ) ,�. Total BOD NE <2.0 NA NA NA Chemical Oxveen Demand (melL) (USEPA Method 410.4) Total COD \E <20 NA NA NA HEM Oil and Grease (tne/L) NI: <5.0 NA NA NA (USEPA Method 1664A) a. Total Suspended Solids (me/L) NL <5.0 NA NA NA (Standard Method 2540D) Footnotes appear on last page. Page 2 of 3 Table 5. Suunmary of Durham City Water Sample Analytical Results, Brenntag Southeast Fact lily (Former Southchem Facility), Sample ID: Durham City Water Durham City Water Durham City Water Dunham City Water BFV Acid Area Caustic Area Hydrant Lab ID: 680-64651-1 680-64651-2 680-64651-3 680.646514 Date Sampled: 1I7/2011 117/2011 1/7/2011 117/2011 Constituents NCAG 2B Standard[ Volatile O1EanieS (ItEIL) (USEPA Method 624) Acetone 2,0002 <25 NA NA NA .., Benzene 1.19 <1.0 NA NA NA Bromodichloromethame 0.55 33 NA NA NA Bromoform 4.3 <1.0 NA NA NA Bromomethane 47 <1.0 NA NA NA Carbon tetrachloride 0,254 <1.0 NA NA NA Chlorobenzeme 130 <1.0 NA NA NA Chlnraethane 12 <1.0 NA NA NA Chloroform 5.6 IS NA NA NA Chloromethane 2.6 <1.0 NA NA NA Dibromochloromethane 0.4 <1.0 NA NA NA I,1-Dichloroethane 6,700 <10 NA NA NA 1,2-Dich€oroethane 0.38 <1.0 NA NA NA 1,1-Dichloroethene 330 <1.0 NA NA NA 1,2-Dichloropropane 0.5 <I.0 NA NA NA 1,3-Dichloropropane (total) NE <2.0 NA NA NA Ethylbenzene 97 z <1.0 NA NA NA Methylene Chloride 4.6 <5.0 NA NA NA 1,1,2,2-Telrachloroelhane 0.17 <1.0 NA NA NA Teirachloroethene 0.7 <1.0 NA NA NA Toluene 112 <1,0 NA NA NA trans-1,2-Dichloroethene 140 <1,0 NA NA NA I,1,1-Trichloroethane 2,500r <1,0 NA NA NA 1,1,2-Trieliloroethane 0.59 <1,0 NA NA NA Trichloroethene 2.5 <1.0 NA NA NA Vinyl Chloride 0.025 <1.0 NA NA NA Semi-Volatiles (MgJt.l (USEPA Method 625) 2,4,6-Trichlorophenol l N <10 NA NA NA 2,4-Dichlorophenol I N <10 NA NA NA 2,4-Dimeihylphenol 320 N x <10 NA NA NA 2,4-Dinitrophenot 26 N 2 <50 NA NA NA 2-Nitrophenol 8,000 N = <10 NA NA NA 4,6-Dinitro-2-methylphenol 12 N x <50 NA NA NA 4-Chloro-3-methylphenol I N <10 NA NA NA 4-Nitrophenol 270 <50 NA NA NA Pentachtorephenol 0.27 <50 NA NA NA Phenol 300 <10 NA NA NA 2-Chlorophenol 1 N <10 NA NA NA 1,24-Trichlorohenzene 35 <10 NA NA NA 1,2-Dichlorobenzene 420 <10 NA NA NA 1,2-Diphenylhydrazine 0,036 <10 NA NA NA 1,3.Dichlorobenzene 320 <10 NA NA NA 1,4-Dichlorobenzene 63 <10 NA NA NA 2-Chloronaphthalene 1,000 <10 NA NA NA 2,6-Dinitrotoluene 0.048 <10 NA NA NA 2,4-anitrotoluene 0.11 <10 NA NA NA 3,3'-Dichlorobenzidine 0.021 <60 NA NA NA Footnotes appear on last page Page 3 of 3 Table 5. Summary of Durham City Water Sample Analytical Results, Brenntag Southeast Facility (Former Southchem Facility) Durham, North Carolina. Sample 1D: Durham City Water Durham City Water Durham City Water Durham City Water BFV Acid Area Caustic Area Hydrant Lab ID: 680-64651.i 680-64651-2 680-64651-3 680-64651.4 Date Sampled: 1/7/2011 117l2011 U712011 1/7/2011 4-Bromophenyl phenyl ether KE <10 NA NA NA 4-Chlorophenyl phenyl ether NE <10 NA NA NA Acenaphthenc 20 <10 NA NA NA Acenaphthylene NE <10 NA NA NA Amhracene 0.051 <10 NA NA NA Benzidine 0.000086 <80 NA NA NA Benzola]anthracene 0.0028 <10 NA NA NA Benzoja]pyrene 0.0028 <10 NA NA NA Benzo]b]fluoranthene 0.0028 <10 NA NA NA Benzojg,h,i]perylene NE <10 NA NA NA Benzolklfiuoranthene 0.0028 <10 NA NA NA 13*2-chloroethoxy)methane 100 <10 NA NA NA Bis(2-chloroethyl)ether 0,03 <10 NA NA NA Bis(2-ethylheKyl) piuhalate 1.2 <10 NA NA NA Butyl benzyl phthalate 19, <10 NA NA NA Chrysenc 0.0028 <10 NA NA NA Di-n-butyl phthalate 9.5 2 <10 NA NA NA Di-n-octyl phthalate 900 <10 NA NA NA Dibenz(a,lr)anthracene 0.0028 <10 NA NA NA Diethyl phthalate 1,200 = <10 NA NA NA Dimethyl phthalate 3,400 = <10 NA NA NA Fluoranthcne 0.111 <10 NA NA NA Fluorene 46: <10 NA NA NA Hexachlorobenzerte 0.0028 <10 NA NA NA Hexacl:lorobutad-acne 0.44 <10 NA NA NA Hexachlorocyclopentadiene 1 <20 NA NA NA Hexachloroethane 1-4 <10 NA NA NA Indenoll,2,3-cdjpyrene 0.0028 <10 NA NA NA lsophorone 35 <10 NA NA NA N-Nitrosodi-n-pmpylamme 0.005 <10 NA NA NA N-Nitrosodimethylarnme 0.00069 <20 NA NA NA N-Nitrosodiphenylamine 3.3 <10 NA NA NA Naphthalene 330 <10 NA NA NA Nitrobenzene 17 <10 NA NA NA Phenanthrene NE <10 NA NA NA Pyrene 930 <10 NA NA NA 2,4-Dimethylphenol 320 N a <10 NA NA NA b*chloroisopropyl) ether 0.0001 <10 NA NA NA Notes: I 15A NCAC 2B surface water quality standards for water supply classifications as adopted per 15A NCAC 2B or National Critena per USEPA (Redbook standards effective May 1, 2007 and updated February 5, 2010). 2 15A North Carolina Administrative Code 2B surface water quality standards for freshwater aquatic life classifications as adopted per 15A NCP 2B or National Criteria per USEPA (Redbook standards effective May 1, 2007 and updated February 5, 2010). pg/L Micrograms per liter. mg/L Milligrams per liter. ptnhos/crr Micromhos per centimeter IS Constituent was detected above the quantitation limit. =Concentration exceeded NCAC 2B Standard NE NCAC 2B or National Criteria per USEPA Standard Not Established. NA Not Analyzed. AL Action Level Standard - see 21]10211 for additional information. N Narrative Standard See 213.0211. HF Field Parameter with holding time of 15 minutes. H Sample was prepped or analyzed beyond the specified holding time. ARCADIS Figures Appendix A FaclIfty Retrofit Photo Log A. Re -Route Roof Drains to "off -Site" Stormwater Line B. Installation of Sump and Conveyance Line to Detention Basin Rooftop rainwater is routed to perimeter "off -site" stormwater conveyance line. Runoff from the outside storage area accumulates in the catch basin/sump pictured above. The accumulated runoff is then pumped to the stormwater detention basins. Photo A: View of roof drain connection to new sub -surface conveyance line. Photo B: View of double pump system installed at the outside storage area sump. Retrofits completed in March 2010. 1 A. Re -Route Roof Drains to "Off -Site" Stormwater Line B. Installation of Sump and Conveyance Line to Detention Basin Photo A: View of outside storage area showing the location of new subsurface conveyance lines connecting rooftop runoff to "off -site" Stormwater line (flow depicted by blue arrow). Photo B: Close up view of double pump system inside catch basin/sump. Runoff originating from the outside storage area accumulates in the sump where it is subsequently pumped to the Stormwater detention basins via the smaller diameter PVC conveyance line (flow depicted by yellow arrow in Photo A). Retrofits completed in March 2010. 2 I i ] A. Re -Route Roof Drains to "Off -Site" Stormwater Line B. Installation of Sump and Conveyance Line to Detention Basin (A) The blue arrow indicates flow direction of new subsurface conveyance line routing rooftop runoff to "off -site" stormwater line. (B) The yellow arrow indicates flow direction of new subsurface conveyance line that transfers sump accumulation (i.e. stormwater originating from outside storage area) to existing stormwater detention basin conveyance line located on far side of tracks. Retrofits completed in March 2010. 3 Deep Shear Gate Elimination Photo A: View of former deep shear gate after it was abandoned in place by grouting with cement. Photo B: Close up view of abandoned deep shear gate. This retrofit was completed in March 2010. 4 Deep Shear Gate Elimination (Pumping System) Groundwater from the abandoned underground caustic conveyance line accumulates inside the sump pictured above. The water is then pumped to the equalization basin through the overhead caustic conveyance line for treatment as process water. Photo A: View of caustic area sump and new overhead conveyance line piping. 5 Photo B: Close up view of sump location (beneath manhole). This retrofit was completed in March 2010. Canopy Extension Over Acid/Base Containment Area View of extended roof canopy covering the trench drain system in Acid/Base Containment Area. Completed in October 2010. NCDENR Norm Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director OCT 2 2 2010 Mr. David Robertson Brenntag Southeast, Inc. 2000 East Petigrew Street Durham, North Carolina 27703 Subject: SPECIAL ORDER BY CONSENT SOC No. S09-006 Ad I Brenntag Southeast, Inc. Durham County Dear Mr. Robertson: Dee Freeman Secretary Attached for your records is a copy of the signed Special Order by Consent amendment approved by the Environmental Management Commission. The terms and conditions of the Order are in full effect, including those requiring submittal of written notice of compliance or non-compliance with any schedule date. Pursuant to North Carolina General Statute 143-215.31), water quality fees have been revised to include an annual fee for activities covered under a Special Order by Consent. Brenntag Southeast, Inc. will be subject to a fee of $250.00 on a yearly basis while under the Order. The initial fee payment will be invoiced. at a later date, with future fee invoicing done on an annual basis. If you have any questions concerning this matter, please contact staff in the Raleigh Regional Office at (919) 796-7215 or Bob Sledge at (919) 807-6398. Sincerely, V"Y Coleen H. Sullins Attachment cc: Jeanne Phillips, ETU Central Files NPDES Unit — SOC File Raleigh Regional Office, Surface Water Protection 1617 Mail Service Center, Raleigh, North Carolina 27699-1617 One Location: 512 N. Salisbury St. Raleigh, North Carolina 27604 Phone: 919-807.63001 FAX: 919-807-64921 Customer Service:1-877-623-6748 NorthCarohna Internet: www.ncwaterquality.org �aturallr� e.. e....el n......d..�ll., I Ae1.. 14'. Ami, n 9-1— • NORTH CAROLINA • ENVIRONMENTAL MANAGEMENT COMMISSION COUNTY OF DURHAM IN THE MATTER OF - NORTH CAROLINA BRENNTAG SOUTHEAST, INC. SPECIAL ORDER BY CONSENT EMC SOC WQ NO. S09-006 Ad I Pursuant to provisions of North Carolina General Statutes (G.S.) 143-215.2, this Special Order by Consent is entered into by Brenntag Southeast, Inc., hereinafter referred to as Brenntag, and the North Carolina Environmental Management Commission, an agency of the State of North Carolina created by G.S. 143B-282, and hereinafter referred to as the Commission: 1. Brenntag and the Commission hereby stipulate the following: a. Brenntag owns and operates a bulk chemical re -distribution facility and is required to have an individual stormwater permit. b. Brenntag operates a facility that houses holding basins, treatment units, and periodically discharges stormwater that requires a permit pursuant to G.S. 143.215.1(a) to an unnamed tributary to Third Fork Creek, class C-NSW waters, in the Cape Fear River Basin. In addition to efforts already made by Brenntag, this Special Order by Consent shall affect future compliance by requiring the separation of process/industrial wastewater and other contaminated waters from the stormwater and developing and implementing a Stormwater Pollution Prevention Plan. c. Discharging untreated process/industrial wastewater commingled with stormwater from the above -described holding basins without the required stormwater permit constitutes causing and contributing to pollution of the above named waters of the State, and Brenntag "is within the jurisdiction of the Commission as set forth 'in G.S. Chapter 143, Article 21. d. Brenntag has implemented measures to stop stormwater from contacting areas where chemicals are packaged or otherwise handled, and has taken measures to stop groundwater from infiltrating underground stormwater conduits, including retro-fitting the conduits with liners. Brenntag proposes to implement additional measures to further insure that industrial products do not commingle with stormwater at the site. e. Brenntag submitted an Engineering Alternatives Analysis (EAA) evaluating four management options for the stormwater and co -mingled wastewater discharges. Brenntag intends to separate the process/industrial wastewater and other contaminated waters from the stormwater discharge. f. Brenntag has secured financing to implement the needed facility retrofits and other necessary actions as called for in this Order. g. Since this Special Order is by consent, neither party will file a petition for a contested case or for judicial review concerning its terms. 2. Brenntag hereby agrees to do the following: • a. Undertake the following activities in accordance with the indicated time schedule: 1) On or before thirty (30) days from the date of this Order, submit the following in writing to DWQ: Describe the permanent method(s) Brenntag will employ to eliminate the discharge of process/industrial wastewater and other contaminated water from the stormwater discharge(s). In addition, indicate the feasibility of routing the discharge of process/industrial wastewater to the City of Durham's sanitary sewer system. The description should include interim dates for accomplishment. MET 2) Develop and implement a Stormwater Pollution Prevention Plan (SP3) within 180 days of the date of this Order, herein after referred to as SP3. The Plan must be implemented and include, at a minimum, the items listed in Attachment A of this Order. 3) Monitoring is to be conducted from the effective date of this Order through time period as described in 3.a-c below and as depicted in Attachment B of this Order. a. At a minimum, sample the wastewater/stormwater basin outfall(s) (in series basin/tanks outlet) for the stormwater outfall for parameters and frequencies identified in Attachment B of this Order. b. At a minimum, sample the process wastewater (pump and haul location) for the following parameters and frequencies identified in Attachment B of this Order. c. Provide bench sheets and monitoring results in both hardcopy written and in Excel (electronic) spreadsheet formats. Submit this data with each quarterly progress report. (See paragraph 2b below) 4) On or before November 30, 2010, complete the following facility retrofits: a. Re-route roof drains b. Extend Canopy at Acid/Base Containment Area c. Eliminate Deep Shear Gate System d. Re-route truck loading area conveyance and disconnect from Deep Shear Gate conveyance 5) On or before May 31, 2011, Brenntag must apply for a NPDES individual stormwater permit (Brenntag must include a copy of the below -mentioned Final Report and Progress Account with this application). 6) On or before May 31, 2011, submit the following in writing to DWQ: Final Report and Progress Account: Provide a written report specifically including supporting sample analysis data (see Attachment B), of the on -site changes, additions, and repairs to the infrastructure or process control methods that demonstrate the elimination of the contaminated groundwater and process/industrial wastewater from the stormwater. b. Brenntag will submit quarterly progress reports detailing the work and activities undertaken and completed with regards to schedules and activities included in this SOC. The reports are to be submitted as follows: one copy must be mailed to the Raleigh Regional Supervisor, Division of Water Quality / Surface Water Protection Section,1628 Mail Service Center, Raleigh, NC 27699-1628, and two copies must be mailed to the 2 Brenntag Southeast, Inc. EMC SOC WQ No. S09-006 Ad I Point Source Branch, Division of Water Quality, 1617 Mail Service Center, Raleigh, NC 27699-1617. The quarterly reports are due in each respective office no later than the thirtieth (30t') day of 3anuary, April, 3uly, and October for the duration of this Order. c. No later than fourteen (14) calendar days after any date identified for accomplishment of any activity listed in paragraph 2 a above, submit to the Raleigh Regional Office of DWQ written- notice of compliance (including the date compliance was achieved along with supporting documentation if applicable) or noncompliance therewith. In the case of noncompliance, the notice shall include a statement of the reason(s) for noncompliance, remedial action(s) taken, and a statement identifying the extent to which subsequent dates or times for accomplishment of listed activities may be affected. d. Brenntag will continue to operate its facility as best as possible to prevent/minimize any adverse impacts to the surface waters. 3. Brenntag agrees that unless excused under paragraph four (4), Brenntag will pay the Director of DWQ, by check payable to the North Carolina Department of Environment and Natural Resources, stipulated penalties according to the following schedule for failure to meet the deadlines set out in paragraphs 2a, 2b, and 2c. Failure to meet a schedule date listed in paragraph 2a; Failure to monitor as stipulated in Attachment B; Failure to submit progress reports as required by paragraph 2b or 2c; Failure to develop and/or implement the Plan as required in Attachment A; Failure to demonstrate the substantial elimination of the process/industrial wastewater from the stormwater discharge on or before May 31, 2011; $500 per day. $100 per omitted value per parameter. $500 for the first violation; penalty doubles with each subsequent assessment for late reports. $500 per day. $5,000 (single penalty). 4. Brenntag and the Commission agree that the stipulated penalties are not due if Brenntag satisfies DWQ that noncompliance was caused solely by: a. An act of God; b. An act of war; c. An intentional act or omission of a third party, but this defense shall not be available if the act or omission is that of an employee or agent of the defendant or if the act or omission occurs in connection with a contractual' relationship with Brenntag; d. An extraordinary event beyond Brenntag's control. Contractor delays or failure to obtain funding will not be considered as events beyond Brenntag's control; or e. Any combination of the above causes. 3 Brenntag Southeast, Inc. EMC SOC WQ No. S09-006 Ad I Failure within thirty (30) days of receipt of written demand to pay the penalties, or challenge them by a contested case petition pursuant to G.S. 1506-23, will be grounds for a collection action, which the Attorney General is hereby authorized to initiate. The only issue in such an action will be whether the thirty (30) days has elapsed. 5. Noncompliance with the terms of this Special Order by Consent is subject to enforcement action in addition to the above stipulations, including injunctive relief pursuant to G.S. 143- 215.6.C., provided that during the term of this SOC no additional penalty shall be assessed for any non-compliance for which a stipulated penalty has been assessed hereunder. 6. Not to exceed the expiration date of this Order, the Commission allows Brenntag to Pump and Haul industrial wastewater for off -site disposal until such time that Brenntag may implement a feasible solution to the wastewater discharge. If Brenntag has not implemented a solution to the wastewater discharge by the expiration date of this Order, Brenntag must obtain approval to pump -and -haul the industrial wastewater in compliance with applicable regulatory requirements and shall continue to make its best effort to obtain permission to discharge wastewater to the City of Durham's municipal sanitary wastewater system. 7. This Special Order by Consent (including Attachments A and B) and any terms or conditions contained herein, hereby supersede any and all previous Special Orders, enforcement compliance schedule letters, terms, and conditions contained therein. 8. Full compliance with this Special Order by Consent will resolve previous issues cited in correspondence dated June 23, 2008 from the Raleigh Regional Office of the Surface Water Protection Section of the Division of Water Quality. 9. This Special Order by Consent may be amended provided Brenntag has made good faith efforts to secure funding, complete all scheduled activities and achieve compliance within the dates specified. 10. Brenntag, upon signature of this Special Order by Consent, will be expected to comply with all schedule dates, terms, and conditions of this document. This Special Order by Consent shall expire on .tune 30, 2011. For Brenntag Southeast, Inc.: Gil D. Steadman Print Name of Signing Official Signature President Title October 18, 2010 Date For the North Carolina Environmental Management Commission: Chair of the Commission Date 4 Brenntag Southeast, Inc. EMC SOC WQ No. S09-006 Ad I Attachment A EMC SOC WQ No. S09-006 Ad I Stormwater Pollution Prevention Plan (SP3) 1, Site Plan. The site plan shall provide a description of the physical facility and the potential pollutant sources which may be expected to contribute to contamination of stormwater discharges. The site plan shall contain the following: (a) A general location map (USGS quadrangle map or appropriately drafted equivalent map), showing the facility's location in relation to transportation routes and surface waters, the name of the receiving water(s) to which the stormwater outfall(s) discharges, or if the discharge is to a municipal separate storm sewer system, the name of the municipality and the ultimate receiving waters, and accurate latitude and longitude of the point(s) of discharge. The map should identify whether each receiving water is impaired (on the state's 303(d) list of impaired waters) or is located in a watershed for which a TMDL has been established, and what the parameter(s) of concern are. North Carolina's 303(d) list can be found at www.ncwaterquality.org. (b) A narrative description of storage practices, loading and unloading activities, outdoor process areas, dust or particulate generating or control processes, and waste disposal practices. A narrative description of the potential pollutants which could be expected to be present in the stormwater discharge from each outfall. (c) A site map drawn to scale (including a distance legend) showing: the site property boundary, the stormwater discharge points, all on -site and adjacent surface waters and wetlands, industrial activity areas (including storage of materials, disposal areas, process areas, loading and unloading areas, and haul roads), site topography, all drainage features and structures, drainage areas for each outfall, industrial activities occurring in each drainage area, buildings, existing BMPs, and impervious surfaces. The site map must indicate the percentage of each drainage area that is impervious and include flow direction. (d) A list of significant spills or leaks of pollutants that have occurred at the facility during the three (3) previous years and any corrective actions taken to mitigate spill impacts. (e) Certification that the stormwater outfalis have been evaluated for the presence of non- stormwater discharges. Z. Stormwater Management Plan. The stormwater management plan shall contain a narrative description of the materials management practices employed which control or minimize the exposure of significant materials to stormwater, including structural and nonstructural measures. The stormwater management plan, at a minimum, shall incorporate the following: (a) Feasibility Study. A review of the technical and economic feasibility of changing the methods of operations and/or storage practices to eliminate or reduce exposure of materials and processes to stormwater. Wherever practical, Brenntag shall prevent exposure of all storage areas, material handling operations, and manufacturing or fueling operations. In areas where elimination of exposure is not practical, the stormwater management plan shall document the feasibility of diverting the stormwater runoff away from areas of potential contamination. (b) Secondary Containment Requirements and Records. Secondary containment is required for: bulk storage of liquid materials; storage in any amount of Section 313 of Title III of Srenntag Southeast, Inc. Page 1 of 3 Attachment A,, EMC SOC WQ No. S09-006 Ad I Stormwater Pollution Prevention Plan (SP3) the Superfund Amendments and Reauthorization Act (SARA) water priority chemicals; and storage in any amount of hazardous substances, in order to prevent leaks and spills from contaminating stormwater runoff. A table or summary of all such tanks and stored materials and their associated secondary containment areas shall be maintained. If the secondary containment devices are connected directly to stormwater conveyance systems, the connection shall be controlled by manually activated valves or other similar devices (which shall be secured closed with a locking mechanism), and any stormwater that accumulates in the containment area shall be at a minimum visually observed for color, foam, outfall staining, visible sheens and dry weather flow, prior to release of the accumulated stormwater. Accumulated stormwater shall be released if found to be uncontaminated by the material stored within the containment area. Records documenting the individual making the observation, the description of the accumulated stormwater, and the date and time of the release shall be kept for a period of five years. (c) BMP Summary. A listing of site structural and non-structural Best Management Practices (BMP) shall be provided. The installation and implementation of BMPs shall be based on the assessment of the potential for sources to contribute significant quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater discharges. The BMP Summary shall include a written record of the specific rationale for installation and implementation of the selected site BMPs. The BMP Summary shall be reviewed and updated annually 3. Spill Prevention and Response Plan. The Spill Prevention and Response Plan (SPRP) shall incorporate an assessment of potential pollutant sources based on a materials inventory of the facility. Facility personnel (or team) responsible for implementing the SPRP shall be identified in a written list incorporated into the SPRP and signed and dated by each individual acknowledging their responsibilities for the plan. An employee trained in chemical hazard identification and Brenntag's spill notification protocol shall be on -site at all times during facility operations that have the potential to contaminate stormwater runoff through spills or exposure of materials associated with the .facility operations. The SPRP must be site stormwater specific. Therefore, an oil Spill Prevention and Containment Control (SPCC) plan may be a component of the SPRP but may not be sufficient to completely address the stormwater aspects of the SPRP. The common elements of the SPCC with the SPRP may be incorporated by reference into the SPRP. Based on the materials inventory for the facility, provide a detailed plan for cleaning up any chemical in the event of a spill or chemical release. 4. Preventative Maintenance and Good Housekeeping Program. A preventative maintenance program shall be developed. The program shall list all stormwater control systems, stormwater discharge outfalls, all on -site and adjacent surface waters and wetlands, industrial activity areas (including material storage areas, material handling areas, disposal areas, process areas, loading and unloading areas, and haul roads), all drainage features and structures and existing structural BMPs. The program shall establish schedules of inspections, maintenance, and housekeeping activities of stormwater control systems, as well as facility, equipment, facility areas, and facility systems that present a potential for stormwater exposure or stormwater pollution. Inspection of material handling areas and regular cleaning schedules of these areas shall be incorporated into the program. Timely compliance with the established schedules for inspections, maintenance, and housekeeping shall be recorded in writing and maintained in the SPPP. Brenntag Southeast, Inc. Page 2 of 3 Attachment A , EMC SOC WQ No. S09-006 Ad I -Stormwoter Pollution Prevention Plan (SP3) 5. Employee Training Training schedules shall be developed and training provided at a minimum on an annual basis for facility personnel with responsibilities for: spill response and cleanup, preventative -maintenance activities, and for any of the facility's operations that have the potential to contaminate stormwater runoff. Facility personnel (or team) responsible for implementing the training shall be identified, and their annual training shall be documented by the signature of each employee trained. 6. Responsible Panfv. The SP3 shall identify a specific position(s) responsible for the overall coordination, development, implementation, and revision to the Plan. Responsibilities for all components of the Plan shall be documented and position assignments provided. 7. Plan Amendment. Brenntag shall amend the SP3 whenever there is a change in design, construction, operation, or maintenance which has a significant effect on the potential for the discharge of pollutants to surface waters. All aspects of the SP3 shall be reviewed and updated on an annual basis. The annual update shall include an updated list of significant spills or leaks of pollutants for the previous three years, or the notation that no spills have occurred. The annual update shall include re -certification that the stormwater outfalls have been evaluated for the presence of non-stormwater discharges. Each annual update shall include a re-evaluation of the effectiveness of the BMPs listed in the BMP.Summary of the Stormwater Management Plan. The Division may notify Brenntag when the SP3 does not meet one or more of the minimum requirements of the Order. Within 30 days of such notice, Brenntag shall submit a time schedule to the Division of Water Quality for modifying the Plan to meet minimum requirements. Brenntag shall provide certification in writing to the Raleigh Regional Office that the changes have been made. 8. ,Facility Inspections Inspections of the facility and all stormwater systems shall occur as part of the Preventative Maintenance and Good Housekeeping Program at a minimum on a semi- annual schedule, once during the first half of the year (January to June) and once during the second half (July to December), with at least 60-days separating inspection dates (unless performed more frequently than semi-annually). These facility inspections are different from, and in addition to; the stormwater discharge characteristic monitoring required in the SOC. 9. Implementation. Brenntag shall implement the SP3. Brenntag shall document all monitoring, measurements, inspections, maintenance activities, and training provided to employees, including the log of the sampling data and of actions taken to implement BMPs associated with the industrial activities, including vehicle maintenance activities. Such documentation shall be kept on -site for a period of five years and made available to the Director or the Director's authorized representative immediately upon request. A copy of the SP3 must be maintained on -site at all times and available for review by staff of the Division of Water Quality. Complete and submit as follows: one copy must be mailed to the Raleigh Regional Supervisor, Division of Water Quality/Surface Water Protection Section, 1628 Mail Service Center, Raleigh, NC 27699-1628 and one copy must be mailed to the Stormwater Permitting Unit, Division of Water Quality, 1617 Mail Service Center, Raleigh, NC 27699-1617. This SP3 is due in each respective office no later than 180 days from the effective date of this SOC. Brenntag Southeast, Inc. Page 3 of 3 Attachment B EMC SOC WQ No. S09-006 Ad I Monitoring Schedule Stormwater Outfalis The stormwater contained in the detention basins will be grab -sampled a minimum of the frequency and duration listed below. Each sample will be collected during a representative storm event (provided a stormwater discharge occurs). If discharges of water occur and are not coincident to and representative of a storm event (e.g. groundwater is seeping into the stormwater collection system), sampling must occur at the frequency described below. A representative storm event definition is provided. A representative storm event is a storm event that measures greater than 0.1 inches of rainfall and that is preceded by at least 72 hours in which no storm event measuring greater than 0.1 inches has occurred. A single storm event may contain up to 10 consecutive hours of no precipitation. For example, if it rains for 2 hours without producing any collectable discharge, and then stops, a sample may be collected if a rain producing a discharge begins again within the next 10 hours. Parameter or Condition Frequency Stormwater Outfalls Duration Method Total Suspended Solids 2 per month * SM 2540D Oil & Grease Monthly * EPA 1664A H 2 per month EPA 150.1 Conductivity 2 per month * "EPA ApprovedMethod" Chemical Oxygen Demand COD 2 per month EPA 410.4 Biochemical Oxygen Demand BODs 2 per month 4 "EPA Approved Method" Ammonia -Nitrogen 2 per month EPA 350.1 Total K•eldahl Nitrogen 2 per month EPA 351.2 Pur eable Organics Monthly * EPA 624 Base -Neutral and Acid -Extractable Organics Monthly * EPA 625 Metals- Monthly EPA 200.8/245.1 Rainfall Daily (excluding Weekends and Holidays) Length of SOC Documented Log Freeboard (Basin Levels) & Release Account Daily (excluding Weekends and Holidays) Length of SOC Documented Log * Stormwater - 4 consecutive months from effective date of SOC and 4 consecutive months from completion date of facility retrofits, described in Section 2.a (4) of this Order. *Discharges (other than storm events) - 4 consecutive months from effective date of SOC and 4 consecutive months from completion date of facility retrofits, described in Section 2.a (4) of this Order. Note: following the first four (4) consecutive months of data and after reviewing the discharge monitoring results, DWQ- RRO-SWP may agree for Brenntag to decrease the frequency of non-stormwater discharge sampling to once (1) per month. Antimony, Arsenic, Beryllium; Cadmium, Copper, Chromium, Lead, Mercury, Nickel, Selehium, Silver, Thallium, Zinc 4 After facility retrofits are complete, a minimum of two separate sampling events must be conducted >t 7 days following a representative storm event. Samples will be collected from the final stormwater basin. Brenntag Southeast, Inc. Page 1 Attachment $ EMC SOC WQ No. S09-006 Ad I Monitoring Schedule Industrial Process Wastewater (pH Adiustment Unit - Pump and Haul Location) At no time will any Surface Water Discharge be permitted or allowed from this unit. Grab samples will be collected directly from the 20,000 gallon storage tank. Parameter or Condition Frequency Duration Method Total Suspended Solids 2 per month SM 2540D Oil & Grease Monthly EPA 1664A H Weekly EPA 150.1 Conductivity Weekly "EPA Approved Method' Chemical Oxygen Demand COD 2 per month EPA 410.4 Biochemical Oxygen Demand BODs 2 per month "EPA Approved Method' Ammonia -Nitrogen 2 per month EPA 350.1 Total K'eldahl Nitrogen 2 per month EPA 351.2 Pur eable Organics Monthly EPA 624 Base -Neutral and Acid -Extractable Organics Monthly EPA 625 Metals- Monthly EPA 200.8/245.1 Total Unit Volume Daily (excluding Weekends and Holidays) Documented Log 6 consecutive weeks following completion date of facility retrofits, described Section 2.a (4) Antimony, Arsenic, Beryllium, Cadmium, Copper, Chromium, Lead, Mercury, Nickel, Selenium, Silver, Thallium, Zinc Brenntag Southeast, Inc. Page 2 ARCADISy Infrastructure, environment, buildings S. Daniel Smith Water Quality Regional Supervisor Surface Water Protection — Department of Water Quality Raleigh Regional Office 1628 Mail Service Center Raleigh, North Carolina 27699-1628 subject: Response to February 2, 2009 letter from NCDENR-DWQ with Special Order by Consent (SOC) Application Brenntag Southeast Discharge to Unnamed Tributary to Third Ford Creek Durham County Dear Mr. Smith: ARCADIS is responding on behalf of Brenntag Southeast, Inc. (Brenntag) to the February 2, 2009 letter from the North Carolina Department of Environment and Natural Resources (NCDENR), Division of Water Quality (DWQ) recommending that Brenntag pursue a Special Order by Consent (SOC) to address the Notice of Violation (NOV-2008-CV-0008) dated June 23, 2008. Brenntag has completed revisions to the SOC Application template to eliminate references to wastewater treatment since the detention/containment basins are not process wastewater treatment units. As described in the Engineers Alternatives Analysis (EAA) dated November 5, 2008, the primary purpose of these four detention basins is to provide 110 percent containment in the event of a spill from the loading/unloading areas at the facility. These four detention basins, misidentified as _ "treatment units" in the February 2, 2009 NCDENR-DWQ letter, collect stormwater sheet flow from loading/unloading areas, uncovered outdoor storage areas, and covered processing areas. The aeration and pH adjustment operations formerly performed in the four detention basins to correct the effects of co -mingling of non- stormwater (identified as impacted groundwater) and stormwater were permanently discontinued in August of 2008 after measures were taken that mitigated the non- stormwater inputs. These measures included slip lining of the stormwater conveyance lines associated with the deep sheer gate system, increased frequency of pump -and -haul activities associated with the deep sheer gate, and repairs to the acid trench drain system. Further, Brenntag has elected to take the deep sheer gate ARCADIS 801 Corporate Center Drive Suite 300 Raleigh North Carolina 27607 Tel 919.854.1282 Fax 919.854,5448 www.arcadis-us.com Environmental Date: 18 March 2009 contara: James E. Shilliiday, III Phone: 919.854.5448 Email- jshilliday@ arcadis- us.com Our ref: N C 105024.0004 G:%EN%AS uthchMm NC1C5924.DD 41SOC Appl-l- -- ARCADIS S. Daniel Smith March 18, 2009 system out of service as a permanent solution. Additional proposed retrofits associated with the facility's storm water system are included in the SOC Application. In order to provide a better understanding of the complexity of the stormwater issues associated with the Brenntag facility, a brief explanation of the primary sources of non-stormwater (identified as impacted groundwater) that have created water quality issues in the four detention basins is provided below. (1) Deep Sheer Gate System. The deep sheer gate system has been identified as the primary source of non-stormwater (impacted groundwater) which has historically been discharging to the four detention basins. Impacted groundwater has been infiltrating into the underground piping associated with the deep sheer gate system from the subsurface in the area of the main facility building. Based on a camera survey, the piping under the main facility rt building was determined to be cracked and have offset joints which allowed impacted groundwater from beneath the facility to enter the piping and subsequently discharge into the deep sheer gate. The water that accumulated in the deep sheer gate periodically overflowed into catch basins connected to the detention basins thus causing impacted groundwater to co - mingle with stormwater, resulting in pH excursions. The source of the impacted groundwater is believed to be caused by exfiltration of stormwater from the roof drains that discharge to the deep sheer gate subsurface conveyance piping. For example, during rain events, the conveyance piping associated with the deep sheer gate fills with stormwater which is then forced out of the piping through cracks/offsets and into the pipe bedding and into contact with impacted soils. After the rain event, the head pressure in the pipe is reduced and impacted groundwater infiltrates back into the piping subsequently discharging to the deep sheer gate. Once it was determined that infiltration of impacted groundwater to the deep sheer gate system was occurring, the piping associated with the deep sheer gate system was slip lined in an attempt to eliminate the influx of impacted groundwater. However, it was determined that the slip lining did not completely eliminate the influx of impacted groundwater into the piping and impacted groundwater continued to co -mingle with storm water in the deep sheer gate. An alternate method was then employed to address this issue. The contents of the deep sheer gate were pumped out on a more frequent basis to prevent overfilling of the deep sheer gate, thus preventing the subsequent overland flow of impacted stormwater to stormwater catch Page: 2/4 G_tF SWOK *TrNCIOM240OW90C Appb� ARCADIS S. Daniel Smith March 18, 2009 -° basins connected to the four detention basins. The pump and haul activities associated with the deep sheer gate have generally been effective at stopping the deep sheer gate from providing impacted water to the four detention basins. However, in the event that the deep sheer gate is overfilled during a significant rain event, the comingled stormwater and impacted groundwater continue to back up into the deep sheer gate piping network and flow out of one of the catch basins associated with the deep sheer gate system and into a catch basin associated with the four containment basins. It has been determined that the best way to stop this from occurring is to redirect the roof drain water so that it is no longer entering the deep sheer gate system and then completely abandon the deep sheer gate system. (2) Acid Area Trench Drain System. The trench drain system in the acid area is also considered a potential source for non-stormwater (impacted groundwater) that may be entering catch basins connected to the four detention basins. The trench drain system in the acid area is designed to collect rinse water and convey it to the equalization basin where the process water is subsequently treated (pH neutralization) and then pumped to a 20,000 gallon above -ground storage tank. The process water in the above- ground storage tank is periodically pumped off and hauled offsite for disposal. -- Based on water quality monitoring data from catch basins located north of the acid trench drain, it appears that some process water may have leaked from the trench drains into the subsurface and subsequently migrated to the catch basins. The acidic water which accumulated in the catch basins located north of the acid containment area then discharged to the four detention basins. Brenntag has implemented a practice of periodically coating the trench drains to eliminate the leaking of process water. In addition, the proposed extension of the canopy over the trench drains will eliminate the surcharging of the trench drains that currently occurs during rain events. It is ARCADIS's professional judgment that the activities presented in the SOC Application Attachment included with this letter should be sufficient to fully separate the facility's stormwater from any facility process water or impacted groundwater. Thus, the Brenntag facility's stormwater discharge would be eligible for an Individual Page: 3/4 ARCADIS S. Daniel Smith March 18, 2009 Stormwater Permit under the National Pollutant Discharge Elimination System (NPDES) program. Further, Brenntag concurs that directly discharging its process water from the equalization basin to the sanitary sewer system for treatment at the City of Durham publicly owned treatment works (POTW) would be preferred to off -site pump and haul disposal provided that: ■ Pretreatment limits do not require installation of a treatment system that is more expensive to install and operate than the pump and haul program that is currently being followed; ■ The pretreatment system, if any, does not require a full-time operator; and • Sewer usage and POTW fees are not cost -prohibitive. On behalf of Brenntag, ARCADIS requests concurrence with the proposed retrofits and schedule included with the SOC Application. Thank you for your consideration of this SOC Application. We have attempted to provide the appropriate information given that the applicable circumstances are different from those of the usual SOC Application. If you have any questions or comments concerning this document, please contact us. Sincerely, ARCADIS G&M of North Carolina, Inc. Ja es E. Shilliday, III, L.G. Project Manager Jon Forbort, Principal Engineer -- Copies: Bruce Biehl (Brenntag) Dave Robertson (Brenntag) Peter Ramaley (Brenntag) Glenn Dunn (Poyner & Spruill) Page: 414 c�EWSW wC105024.00XWcAPpD w SOC Application 1' r S'1'A`r;4, OF Nt}R'IT C:AROLINA �I�,^i 1)KPAlt`1'11i ENT 01? ENV1WN�r� , Mr ANU NATURAL Rl<SOUlt(TI; DIVISION 01" WATER QUALITY i APPLICATION EE`C)R A SPi,t:1 L ORDER [IV CONSENT (SOC) 11 PERMIT RJill) ATE)) iiN1;OR1i~'1A"1'ION; 1. Applicant (Corporation, #EldiVidUld, (il' Ofll `): l;ictlflt:. it.`iout,.11ua st'_f �i1C . (1��L?ll€1( ate) 2. Print or "t _ypt: Owncr's car Signing Official's Name amd Titic: Ah 3. Fnc:ili(y N-im a (as sllomi oj) Peniiii): r+k�t as r! ic,,xtl��-, r;c:r cxe Yfri t;. 11 . F�111111CA41L111 t)iltl:; - - — 5. NPOV,"S i'crmit No. (i't`r pplif:a0k). NOL amAi.cabLe,- no t.-rinit — 6. Nan1c, oi'Ilic spccil-ic wastewaWX 11'eatilluilt racility (if rliffcrefl(fi'ain I.3. ethove); -- - Neat rjixA..i.c;ab_t.e,_ i 1ldividiVIl ; LO.IALTWat.t�r_ txj]_rtliL rjt)fAj_i _TtiOl1 Wi-1 1 be subid t twd , _ _ — _ _- I L !t't,1O-AI'1'I,1['XJ`.1ON NUETiNC,` Prior to submittitlg this completed aplliicatloll 1br111, applicamis must Inca with thu appropriate Ve;ional offitt:l. akicc to divums %vh6lwv ov. Sx)C S1i1 S)OC; is l pproprialc for 1111s Situation, Please. ilol(: [Ilk, data this 1llectilig occUlTud: 0 anua_ry -3.Q� ?.� p 9.. - - _--_-. `A 1-11,_ A1)1)I'i IONA1, F1,OW OR;t LOW HYA1,1,0C:1+►TION: Not, aP111..icablc,. In m:coiE1;muc. with NCCTS 1,13-21 5.67(b), only racilitics owned by 21 tillit of govc i'ilrllcil rc:ddit yucst aiuil,iI -fl w. .i, - - Additional flow may he aliu,,ve t under all SOC only in _slut flit: clyctU115ttElll cs. 1'ht 5u cirourllstances may include clim1illadAg errs,niit cowfAiant luith an NPOHIS or Noll-disclim-ge permit. Thcsc t irclii7lst=tiles- trot include failure io perform proper m aii3lenance ou lre:1Cnizat $,ystcros, ccii3M dingo -A syMrm. When rcclmestillf; additional flow, [lie facility #nwt inlilil(: ]ls j##stilictltiiicl :imtl stipl�ortinf; documlc:lltatioil. 11 I11C requeskg(I-Si,ZlAi011al (low i5 11oll-dolncstic, the I'acility nlilst tic Attic to dc#rromstratc, the ability it, A*ciivcly lycat the t' astc. and disimu 01` residuals. The 4Ippliumll must 11rovidc it •� .citst liled ar1Hlysis of'th(3 calls(ituCtlts ill thc: ))r-Ulxlscd 11011-dollic:slic Was LC water. .0 .r .. The total domestic estic additional flow mclucst[:d: Hic total itoil cit)lit4sfiC ar,Iclitioilal (low re(uested. The tidal additional lloli' {,str/11 f7f ilrc 14h,"ve): gal lolls-p;I-day, gallons per clay, j;illlolis per day. M- Please attach a cictalilcd &wls -kltioit c)t• f)rojccl Iistiiit, q)f the; proposed arllocaltioil ibc additional floxv, with all a pkiotfitili of how flow quantilius ►verc usWi.:riud- Please he a dviscd that ally il(1[liklCrlii?:f AjcL)' -Allowed by fbis rc41musiod SOC tl'Jff Ix. (lctCI-mined by ii ar<.i "11Act.c' atralysi s c)f' ally .� � i),iCcted adverse impact to waislewater (reatrllcilt lacllitics mid slti'filec %valor.. .,,r IAl. NIC"C'E'SSITY rINAUR,i'[ M : s,�..� 'a)i:' 111case altlic:h a naurative providing a dwaliled explatlatioll or die l h-cunlstatices rugarditiv, [iic necessity of the proposed SOC, 11161(It: tho IN lowing issl)cs: 4ft � xiyttrrr; zrcrz r trrinvoidabIC ANU-17C Vi0 iitiuirs(s) t)i'permit s;ontiti€ion rat' tltilits{tij, 'l'lie ekisting4real ment process-und any nioditicaltions-that have ticun maldc [o da€cj- Collection system rellabilitatlon work ccil)ll)lctc[I of seller [heel (inClucfiilg (IateS), ® Ct)f;Ptslfl?ailli)il-5i'ltla leli�-if:Stf'iiil-:l�Sifi:i�dy :#i�idi�iF1'�*- tI'.Ftdi'zI1i;L;11i1�rh3T;i i3I' �ld'i„�i`�:3t13bi:d]I. }•'.�,L'll3ttf.,'�.' - fdetltify uny [loll-collllplialall signif tcaillt i 1dustriaf -users and lilcaslirc(5) proposvd-Cri'- to kvu-- to bVilig tI1C l)r44'Cuttiletlt flGilitic5 back into C:[]mpliallewc—I17.a1y Ii.i.IsS tl'lirl t�6Ui�llf4t ir3'i c:[ll`(:ntla [13lili:i' [:a33lwalt i1��+�:L,aliEr{1:�, �}Icasf� t,ta[;+l tll. Si, V. (�tf.l,Cl'lFICA.•.t'tONt See% iCY: cipplic:atAorl ilt:tachillurit_- 'ffiv �ipplicant nmA suhmii ai repoil prepared by an indepundellt processional with uxpurtisx ilt . wasid%vater.Qt atnient. Tfiis report must address the Following: a All c.v-,% l mi'dii -of* i%W,6iig trea[Sill:ilt kmits, o1wratilomil })l'k)l iAl)res and rt;tmmi'Ilundittions ,is to how the cfticicovicti of, 111 ac 1140litics can bu rnaxillrii.ca. 0 A cur(ifiCaitioIl tfral: these hkifitic; Could not- f)e oticralted ill a mailnet. dial would acllicvc rr compliance With final pert•ilil Ililtits. v Thu uffluunt lintits lbul [tic J'auili[y ixllikl hu -t_vcl led to reel if' Operated al 11101. 111m. iilium cfficii-`ncy ituring lho tcril-I of tlic rcou(.Mcii SOC (llc sln-C. to Consider interim Cilil �tl'lli:ii()ll I1llil;iL'8). c; Any nkliai` a.tiukis taliien Lo cmm-ct protik%w, lltio W i'CC1twmiltg tilt, "SM". 2 MO ' : ip;Ac•ulritrl Persian 200G.1u125 •• VI. PREDICTED C OMPLIANC:E' SCH1 13Y.It,14:: 5cc Six -IDID .cat5.o►7 M.tachmeni:. The applicant must submit a detailed listing ofactivities along; with time frames thin arc necessary to bring the htcility into compliance. This schedule should include milestone dates for -- bug;inilinft conslructioii, ending.c.<)nst►_uction, laid aellicving Illial coil) pliatice. In determining tllc: milestone dates, the following should be considered: r c Time for stibmitting plebs, S;}ti l itlCiitiUtlS iind iippyopriaatc engineering; reports to DWQ tirr review and approval. v OccutTencc oftuajor construction activifics that arc likely to aMct facility pertiormanec aw (-antis-out-oj'sOt=victa;Ai%tif-si oil of 11a�vs; etc:}: Infiltration/Inflow work, if accessary. a �ifltltittE'1i21-ilSt:!•t; act;ic�ri:�g; contpliatac;c>,a�ftY�thcli• g�rctr::itt.ncut-licri�:ils id'api�Iic:flrlc.- Mae To.m-iuity Reduction i.valtill tions ('1 RE), if necessar),: .� VI1. FUNOIN(:; S(1r1RC,' S 10,ir;Iil'f'i"Vt(:EiMN: Sec srX: applic;al.A.ou at tachlitent. The applicant must list the sources of funds utilized to complete. the work needed to bring the facility into compliance. Possible funding; sources include but are not limited to loan -� comnlitilicnts, bonds, letters of credit, block grants and cash reserves. '!'he. applicant must show that the funds are availablu, or cite be secured in time to elect the seliedule outlitied as part oi'this application. THJS A11VIA C:ATION PACKAGJ; W11,1, NOT 111; AC.: METED 1)Y TI II1 1)1VISION OF WATUR QUALITY UNLESS A1,1. Ul- `1.1.1f? A1)11LI("A13t.1? ITFMS AIt1i 1NCIA J1)i"D WITII FAft n-iu, SU13ivtI'I VAL. Ilcrjan !(ents. a, nac original and two copies of the completed and appropriately executed application low Will, along; with all required attacliments. G If the SC)C is f m, v Cily / Town, the person .sigai► g the SOC' must tic it ranking ,,,a elected A lciul or other duly authorized crllployce. If the Sot: is fur ii Corporation f Company I industry I Other, the person signing; the SOC must be it principal executive officer of at least file lad of vice - as llfcSideili, or his rhtly authorized rcprcscnfativc. If the SOC is for a School District, (lie person signing; (lie SOC' must be the Superintendent of Schools or olhcr duly authorized employee. .r 'Nate: Rvfw-encc In slgnala?y requirvinvals in SOCs may lic hjund in the North Carolina Administrative Code I`t'15A NCAC; 2i1 .1206i(a)(3)1. b. The non-relimdable Special Order by Consent (SOC) processing; lcc of $1100,00. A check must be ►l adc .payable to The Department of HAivironmem and Natural Resources. C. Ail--t;Vttlliilia)i1--1't3f}Ci'.--{}Ei3tliii'ti,4--hy---►eti- it�tt;l3tist�#:sr►�-�:��ti:~><+4tat�i viidli.--er:;av►•.;i;,�c--ir, 3 a. .SOC Applicalio)) Version 7. 006Al2S .r APPLICANT'S CERTIFICATION: 11 -tbv-►a Y.co'b.-mks bn , attest this application for a Special Order by Consent (SOC) has been reviewed by me and is accurate and complete to the best of my knowledge. I understand if all required parts of this application are not completed and if all required supporting information and attachments are not included, this application package may be returned as incomplete. Furthermore, I attest by my signature that I fully understand that an upfront penalty, which may satisfy as a full settlement for past violations, may be imposed. (Note: Reference to upfront penalties in Special Orders by Consent may be found in the North Carolina Administrative Code [T15A NCAC 211.1206(c)(3)].} Date Signature of Signing Official a ►Ci 6/'% Printed Name of Signing Official 3 I2z16-7 THE COMPLETED APPLICATION PACKAGE, INCLUDING THE ORIGINAL AND TWO COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, SHOULD BE SENT TO THE FOLLOWING ADDRESS: NORTH CAROLINA DIVISION OF WATER QUALITY POINT SOURCE BRANCH 1617 MAIL SERVICE CENTER RALEIGH, NORTH CAROLINA 27699-1617 IF THIS APPLCIATION IS FOR A NON -DISCHARGE SYSTEM, THEN SEND TO: NORTH CAROLINA DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION 1636 MAIL SERVICE CENTER RALEIGH, NORTH CAROLINA 27699-1636 RECEIVED DENR - WATER QUALITY POINT SOURCE BRANCH 4 SOC Application Version 2006Jul25 APPLICANT'S CERTIFICATION: 1, .. v % f-'- T:S N attest this applicat Consent (SOC) has been revioNved by me and is accurate and knowledge. I understand if all regUired parts of this application required supporting information and attachinews arc not included, 11)h be returned as incomplete. ion for a Special Order by complete to the best of my are not completed and if all ote: Reference to upfront penalties in Special Orders by the Not -Ili Carolina Administrative lode [T15A NCAC 2H .12i16s(c)(3)1.1 DatcI Signature of Signing Official i /G,: t Printed Name of Signing Official THE COMPLETE.1) APPLICATION PACKAGE, INCLUDING TI-IC ORIGINAL AND'I WO COPIES OF ALL SUPPORTING INFORMATION AND MATERIALS, Si-IOULD Bra SEN'r TO THE FOLLOWING ADDRESS; NORTH CAROLINA DIVISION OF WATER QUALITY POINT SOURCE BRANCH 1617 MAIL SERVICE CENTER RALEIGH, NORTH CAROLINA 27699-1617 IF THIS APPLCIATION IS FOR A NON -DISCHARGE SYSTEM, TI-MN SEND TO: NORTH CAROLINA DIVISION OF WATER QUALITY AQUIFER PROTECTION SECTION 1636 MAIL, SERVICE CENTER RALEIGH, NORTH CAROLINA 27699-1636 4 �-- SIaC A,Upfr�c�alion Versimi 2006.l WS SOC Application Attachment ARCAMS IV. Necessity Narrative The circumstances at the Brenntag facility necessitating this SOC include the following: A. Responding to a Notice of Violation (NOV-2008-CV-0008) dated June 23, 2008; B. Improving stormwater management by voluntary evaluation of the stormwater system to identify non-stormwater inputs; C. Improving process water management; and D. Facility management's desire to cooperate with the NCDENR and ensure e compliance of site activities. The circumstances noted above are described in greater detail below. A. Responding to NOV-2008-CV-0008 The Notice of Violation (NOV) issued on June 23, 2008 identified potential permitting issues for the Brenntag facility. Brenntag responded to the NOV by evaluating the facility for non -storm water (defined as impacted groundwater) and process -related impacts to stormwater conveyance and discharge. Brenntag responded to the NCDENR in a letter dated August 29, 2008 which provided for an intermediate step in addressing the permitting issues. The intermediate step involved preparation of an Engineers Alternatives Analysis (EAA) to evaluate storm water issues at the facility. The EAA was completed on November 5, 2008 and submitted to the NCDENR. The EAA provided an evaluation of the following four stormwater and process -related water management options: 1. Identifying and implementing stormwater best management practices (BMPs) for the facility to eliminate impacted groundwater and/or process related inputs to the stormwater system and application for an Individual Stormwater Permit. 2. Retrofitting the facility to remove specific stormwater inputs (e.g. roof drains, y sheet flow from off -site sources, etc.) from discharging into the deep sheer gate system and subsequently the detention basins, and a recommendation for eventual abandonment of the deep sheer gate system. SOC Application Attachment Brenntag Southeast BECdUse we care 100% recycled paper produced by wine p , +.e: H)OR3v g.4e L5oalhehe~05024.00Wsw eppkaUonu - so application allachmenl.dw ARCADES 3. Conveying process -related water from the equalization basin to the City of Durham publicly owned treatment works (POTW) under an Industrial User Wastewater Permit. 4. Continued use of the existing deep sheer gate system to contain stormwater along with implementation of upgrades to the four stormwater detention basins to facilitate removal of BOD and discharge of the treated stormwater to the unnamed tributary of Third Fork Creek under an NPDES Industrial Wastewater Permit, The EAA provided reasons for not pursuing option four and a more detailed evaluation of options one, two, and three was utilized to develop some of the proposed activities presented in this SOC Application. As described in the EAA and the cover letter associated with this SOC Application, periodic surcharge of the deep sheer gate system (i.e. overfilling of the deep sheer gate system due to rain events) caused some co -mingling of non-stormwater (impacted groundwater that leaches into the piping associated with the deep sheer gate) with stormwater, which ultimately reached the four detention basins. The aeration and pH adjustment operations in the detention basins to correct the effects of co -mingling of non-stormwater and stormwater were permanently discontinued in August of 2008 after measures were taken that generally eliminated the introduction of non -storm water into the four detention basins. These measures included slip lining of the storm water conveyance lines associated with the deep sheer gate system, increased frequency of pump and haul activities associated with the deep sheer gate system, and repairs to the trench drain system in the acid containment area. Brenntag has elected to take the deep sheer gate system out of service as a permanent solution. B. Improving Sformwater Management Brenntag aims to improve stormwater management at the facility by continuing ongoing monitoring of stormwater discharged from the facility, separating conveyance and discharge of non-stormwater and stormwater, planning and completing facility retrofits, and applying for an Individual Stormwater Permit. Since August 6, 2008, Brenntag has implemented daily sampling of the influent to the stormwater detention basins for chemical oxygen demand (COD). A sample was also collected weekly and submitted for laboratory analysis of biochemical oxygen demand SOC Application Attachment Brenntag Southeast irivr !(�. p)MdLlcai; hq VVI:ld (rawer enerClY g.renvlsouihtlrem�nclOW24,UM4\5oc applicallon'A - sac application aha hmem dx ARCADIS (BOD). In addition, conductivity and pH measurements were collected daily from each of the basins. Results from these sampling efforts were provided in the EAA. As a result of the facility evaluation and storm water sampling activities conducted in 2008, the deep sheer gate system was identified as contributing to stormwater impacts at the facility. The stormwater evaluation indicated that impacted groundwater is infiltrating the conveyance line to the deep sheer gate through cracks and offsetjoints in the conveyance line. Further, the evaluations indicated that during rain events, T stormwater from roof drains discharged to the deep sheer gate sub -surface conveyance line, causing periodic hydraulic loading of the subsurface conveyance line which resulted in exfiltration of stormwater into subsurface soils under the facility's main building. In some areas beneath the main building the subsurface soils are impacted and the exfiltrated stormwater that comes in contact with those soils also becomes impacted. Following the rain event, the water leaches back into the subsurface conveyance line exacerbating the groundwater impacts detected at the deep sheer gate. .. In addition, periodic surcharging of the Deep Sheer Gate conveyance line (overfilling of the conveyance line during rain events) resulted in water overflowing from catch basin SW-3 to the pavement. The overflow then discharges into stormwater collection catch basin SWA which subsequently drains to the detention basins. Since this was identified in August 2008, the facility has increased the frequency at which water is pumped out of the deep sheer gate basin to prevent surcharging as an intermediate measure. The BOD results collected from August 2008 through December 2008 have generally been lower than 5 milligrams per liter (mg/L), without any "treatment" (it should be noted that pH adjustment and aeration was permanently discontinued in August 2008 after measures were taken that generally eliminated the introduction of non -storm water into the four detention basins). Despite these improvements, occasional increased BOD concentrations to levels slightly above 5 mg/L have been detected in the detention basins, which influenced Brenntag's decision to take the deep sheer gate system out of service (as discussed above). The proposed retrofits associated with this modification are discussed in Section VI of the SOC Application. Brenntag plans to utilize the formal structure provided by the Individual Stormwater Permit to better manage facility stormwater through a Pollution Prevention Plan and best management practices. SOC Application Attachment Brenntag Southeast 9ecause we care I DO%a recycled Paper prodLfced by wind power energy g:kmlsautlKhemMct05024.00g415ae8pplieali W- sacapplk*ion avacmeet doc ARCADIS C. Improving Process Water Management Brenntag aims to improve process water management at the facility by implementing measures to further ensure that process water generated in the acid containment area is conveyed to the equalization basin in a manner that doesn't allow the process water to leach into the subsurface (i.e. routinely sealing the acid area trench drain system). The trench drain system in the acid area was identified as a potential source for non - storm water (impacted groundwater) that may be entering catch basins associated with the storm water system and subsequently discharging to the four detention basins. The trench drain system in the acid area is utilized to convey acidic process water from the acid containment area to the equalization basin where the process water is subsequently treated and then pumped to a 20,000 gallon above -ground storage tank. The process water in the above -ground storage tank is periodically pumped off and hauled offsite for disposal. Based on water quality monitoring data from catch basins located north of the acid trench drain, it appears that some process water may have leaked from the trench drains into the subsurface and subsequently migrated to the catch basins. The acidic water which accumulates in the catch basins located north of the acid containment -- area then discharges to the four detention basins. Brenntag has implemented a practice of periodically coating the trench drains to eliminate the leaking of process water. In addition, the proposed extension of the canopy over the trench drains will eliminate the surcharging of the trench drains that currently occurs during rain events. 0" In addition, Brenntag will be evaluating the feasibility of discharging process water from the equalization basin to the City of Durham POTW. Brenntag is moving forward with collecting samples from the equalization basin to assist with characterizing the water quality associated with the process water generated at the acid containment area. This water quality data will be reviewed along with daily flow estimates for process water as part of the feasibility evaluation for discharge to the City of Durham POTW. D. Facility Management's Desire to Cooperate with Agency and Ensure Compliance of Site Activities It has been Brenntag's desire to ensure continued compliance with state and federal regulations and to cooperate with the agencies administrating those regulations. Brenntag has already completed some facility modifications since the NOV was issued in June 2008. The stormwater evaluation that took place following the NOV identified SOC Application Attachment Brenntag Southeast Because we care 100 recycled paler plodirced bye-v,Ild 7, AL1 caerriv 0:*rrv15oufthem)m105024.00041soe aPaUtmar 4 - s application attachmerN.do ARCADIS - the impacted groundwater and process water related inputs to the stormwater collection and conveyance system. The following sections list the identified groundwater and process water related inputs along with a detailed explanation of the facility improvements that Brenntag has implemented to date. 1. Groundwater Infiltration - It was determined that impacted groundwater was infiltrating into the underground pipeline associated with the deep sheer gate system. In order to prevent groundwater infiltration, Brenntag slip -lined the conveyance line and associated catch basins designated SW-3 and SW-8. This modification helped reduce groundwater infiltration, but it did not eliminate it. 2. Tank Containment Area - Pitting was observed on the galvanized steel structures adjacent to the tank containment area in the southwest area of the property (designated as "Phase III Ex Tanks" on Figure 2). The pitting indicated that metal constituents such as zinc could be mobilized and potentially enter the stormwater system. Once identified, Brenntag applied a chemical resistant coating to the galvanized steel equipment exposed to stormwater as a corrective measure. 3. Acid Containment Area -The trench drain collection system located in the acid containment area (labeled AATD on Figure 2) is used to collect and convey process water from the acid containment area to the equalization basin. Improvements were implemented to the trench drain collection system through - the application of a chemical resistant coating. This improvement was implemented as a routine maintenance measure to prevent process water from leaching out of the trench drain into the subsurface and then potentially leaching -T into the stormwater conveyance line associated with catch basins designated SW-4, SW-7 and SW-9. Storm water catch basins SW-4, SW-7, and SW-9 discharge to the four detention basins; therefore, improvements to the trench drain system should facilitate improvement of the quality of water entering the detention basins. V. Certification This section, as written in the original SOC application provided by NCDENR-DWQ, is not applicable to this facility's circumstances for entering into an SOC. Brenntag does not currently operate the detention basins as treatment units, nor will they in the future. Therefore, this document does not include an evaluation of water treatment processes. SOC Application Attachment Brenntag Southeast Because we care M 100% recycled paper produced by wind power coy irgy g'.�enVmuthchamYul05024.0004Lsm apgkaeanu- sac application Wachm fl.da ARCADIS VI. Predicted Compliance Schedule Brenntag proposes to implement the facility modifications presented in this SOC Application within 10 months following the NCDENR's concurrence with the Application. A proposed schedule for performing the tasks necessary to implement the facility improvements is presented as Figure 1. For the purposes of a timeline, it was assumed that obtaining the NCDENR's concurrence on the proposed facility improvements may take up to 6 weeks. Therefore, the timeline shown in Figure 1 begins May 1, 2009. Included within this schedule are the following, facility retrofit design and construction, preparation and submittal of an NPDES Individual Stormwater Permit Application, and evaluation of directly connecting the facility's process effluent T to the City of Durham POTW. The following retrofits to the system are proposed to remove non-stormwater inputs to the stormwater collection conveyance system as well as reduce the volume of stormwater discharging to the detention basins. A. Re -Route Roof Drains Currently the majority of the main building roof drain system collects stormwater in a conveyance pipe that is suspended from the ceiling inside the building. The overhead conveyance pipe discharges to the underground deep sheer gate conveyance line. Brenntag proposes to modify the indoor overhead conveyance pipe to discharge to the stormwater conveyance line located east of the facility, outside of the processing/storage areas. The line will be connected to this stormwater conveyance line at MH #4 (see Figure 2). B. Reconfigure Conveyance of Truck Loading Area Drainage The catch basin located in the truck loading area will be disconnected from the deep sheer gate conveyance system by abandoning the connection at the catch basin designated as SW-8. A new subsurface conveyance line will be routed to connect the catch basin to the existing stormwater conveyance line that discharges to the stormwater detention basins (see Figure 3). C. Eliminate Deep Sheer Gate System The conveyance piping and catch basins associated with the deep sheer gate will be abandoned in place downstream of the catch basin adjacent to the southwest side of the main building (upstream of the catch basin designated SW-3). Abandoned catch basins and the deep sheer gate will be filled with aggregate and permanently grouted. A pumping system to be installed in the .. SOC Application Attachment Brenntag Southeast Because we care w 100% recycled paper produced by wine power energy gi&WSalgh O*C1OSM 00041soceppkationN•sacappAcatlan ettachm rrt do ARCADIS existing vault (a component of the deep sheer gate conveyance line beneath the main building) is proposed to facilitate the collection and removal of groundwater that may accumulate in the underground conveyance line located beneath the main building. The collected groundwater will be pumped into an above grade conveyance line to the overhead caustic line (designated OHC) to be handled as process water at the equalization basin (see Figure 3). D. Extend Canopy at Acid Containment Area The roof canopy will be extended over a section of the processing/handling area associated with the acid containment area to reduce the potential for rain water to enter the acid area trench drains (see Figure 2). Included in the schedule is the required approval of a building permit from the City of Durham for this construction activity, which alone may take up to a month. Upon completion of the above listed facility retrofits, Brenntag will be in a position to operate under a NPDES Individual Stormwater Permit. The Individual Stormwater Permit will include selection of facility best management practices (BMPs), as well as a Stormwater Pollution Prevention Plan. Preparation of the application will be concurrent with design and construction of facility retrofit activities with the goal of submitting the permit before the end of the 10 month timeline. The process water monitoring programs in place will be reviewed and updated as necessary to include, at minimum, pH, BOD, metals, and organics and sufficient monitoring frequency. The documentation procedures for the pump and haul activities will be reviewed and updated as necessary to include, at minimum, storage control status, storage volume records, pump and hauling records, and destination. Brenntag would like to conduct a feasibility evaluation for pretreating facility process water that is contained in the equalization basin and directly routing the process water to the City of Durham POTW in lieu of the present pump and haul activities. It is proposed that this evaluation will take approximately 3 months. The evaluation would include a conclusion regarding the feasibility of this option, as well as an approximate timeline and estimated costs for design and construction. aaa{ SOC Application Attachment Brenntag Southeast Because we care ON )00% recycled paper produced by wind power energy g.Amw%oArcbwnNc105M4ADD41socaPPk2 M.m appna[lonanaduTn l.do ARCADiS VII. Funding Sources Identification Brenntag will fund this project using funds from the Durham facility's operating budget for 2009. SOC Application Attachment Brenntag Southeast Because we care MM 1 Da / recycled paper produced by wind power energy y:WMsaihdia IOW4.0004isoc appG"mW •Soc application MWdvnentdoc Figure 1: Predicted Compliance Schedule for Special Order of Consent Actvities Brenntag Southeast, Inc. Durham, NC ID Task Name Calendar Days Working i Days Start Finish Qtr 2 2009 Qtr 3 2009 Qtr 4 2009 Qtr 1 2010 Apr I May Jun Jul Au Se Oct Nov Dec Jan Feb Mar 1 Overall Predicted Compliance Schedule Receive concurrence from NCDENR-DWQ to begin SOC activities Construction Achieve Compliance Retrofits Engineering, Drawings, and Specifications Project Bidding Review Bids Project Award Contracting Construction Re -Route Roof Drains Reconfigure Conveyance of Truck Loading Area Drainage Eliminate Deep Sheer Gate System Extend Canopy at Acid Containment Area !NPDES Individual Stormwater Permit Prepare Application and Part I of Permit Stormwater Pollution Prevention Plan Brenntag Permit Review and Comment Submit Permit Application to NCDENR-DWQ Feasibility Evaluation for Routing Process Effluent to City of Durham POTW Review, Evaluate, and Revise Process Water Monitoring Program Assess Pretreatment Requirements Evaluate Options for Compliance with Pretreatment Requirements Assess Conveyance System and Connection to City Sewer System Develop Timeline to Connect to City Sewer System Cost Estimate !Review and Revise Documentation Procedures for Pump and Haul Activities 302 days 1 days 194 days 1 days 285 days 40 days 12 days 11 days 1 days 19 days 194 days 40 days 54 days 12 days 82 days 89 days 5 days 54 days 12 days 1 days 89 days 26 days 12 days 19 days 19 days 12 days 12 days 19 days 216 days 1 day 140 days 1 day 205 days 30 days 10 days 9 days 1 day 15 days 140 days 30 days 40 days 10 days 60 days 65 days 5 days 40 days 10 days 1 day 65 days 20 days 10 days 15 days 15 days 10 days 10 days 15 days Fri 5l1/09 Fri 5/1/09 Mon 8/3/09 Fri 2/26/10 Mon 5/4/09 Mon 5/4/09 Mon 6/15109 Mon 6/29/09 Fri 7/10/09 Mon 7/13/09 Mon 8/3109 Mon 8/3/09 Mon 9/14/09 Mon 11/9/09 Mon 11/23/09 Mon 5/4/09 Mon 5/4/09 Mon 5/11/09 Mon 7/6/09 Fri 7131/09 Mon 6/15109 Mon 6/15/09 Mon 7/13/09 Mon 7/27/09 Mon 7/27/09 Mon 8/17l09 Mon 8/31/09 Mon 9128/09 Fri 2/26/10 Fri 5/1l09 Fri 2/12/10 Fri 2/26/10 Fri 2/12/10 Fri 6/12/09 Fri 6126/09 Thu 7/9/09 Fri 7/10/09 Fri 7/31/09 Fri 2/12/10 Fri 9/11/091 Fri 11/6/09 Fri 11/20/09 Fri 2/12/10 Fri 7/31/09� Fri 5/8/09� Fri 713/09 Fri 7/17/09 Fri 7/31109 Fri 9/11109 Fri 7/10/09 Fri 7/24/09 Fri 8/14/091 Fri 8/14/09' Fri 8/28/09 Fri 9/11/09 Fri 10/16/09 ;- _ _ _ _ _ _ _ _ _ _ _ - �i - - - �O C== _` - - ♦I 1 , ' 2 3 4 5 (Facility 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Project: Schedule Date: Mon 3/16/09 Task E= Progress Split , , , Milestone O Summary Project Summary External Tasks ; . Split External MileTask , z 0 c 0 0 m NOTES: 1. INFORMATION SHOWN WAS PROVIDED BY THE OWNER AND SUPPLEMENTED BY A FIELD VISIT BY ARCADIS. 2. AN ACTUAL SURVEY WAS NOT PERFORMED TO LOCATE ALL ITEMS. THEREFORE, THIS FIGURE ONLY REPRESENTS A SCHEMATIC OF CURRENT CONDITIONS AS OBSERVED, AND MAY NOT BE COMPLETELY ACCURATE. 3 .JG' ('-TALI ----fie -" • AL r_� R 4. t. Ef-- i kEIWXR 9 I 99 B9C-K'J .01 i99. 89 8 V49•...' ? _ 4N+(Ws Bs1K 18 _ sc11 ._. � ss�kf A tp+iF3 - `4'f G; 3•S�K MID 12 -{ I Ws'liJ1] Fv I / , 9 s \� br, z I �� w.M.•:,, yXi li 'i iP.,:ii aY _ CW$- f �EO.UAL211'we PAIN.I .� E%itA: AA:i x /...( V 5'0�4"E ♦5 I Q / ,a $N-4 i4Yflf4? ST N .�EXiENO /�°' OFEP SEEER CA swz -• `: T � F$W � _ _ _ _ 1! SN Z I i � [4 ruts y'.+.Fc, DETENTION BtSWS °' '—a:.•rl _ ,w \fit 0�. jN-,t c L—JL—JL 10 aHASc III .I' �e� ��sn cnu�e,t '°�. "�-nJ\ 1 v Y •.i�.V_ f .— - - - --C—__ �\y,L,C7`.t.-i; .. PROPOSED CONNECTION OF ROOF DRANS TO MHj4 -\-'L��.J��./�_/'✓.J•��\.J�_.'�s'_ '�1.�.�,.i,J�.t ,`�Ln�..�J',A�_n.J_A.'`1.� J`:._1�• �J�-emu'-/\_'��-'v � -AS' - VIES` E.:PR'SS4-A" (VARIABLE R.O 'W.) NC flWY NO. 147 (EXISTING PUBLIC) LEGEND ONSNE STORNWATER ----- . OFFSDE STORMWATER/ROOF DRAINS -- SANBARY SEWER -- -. WATER ACID AREA TRENCH DRAIN —• UNDERGROUND ACID -- - OVERHEAD CAUSTIC - UNDERGROUND CAUSTIC 0 40' W. I20' SCALE IN FEET ,:m W -- w.w SCALE HOUSE 1 1 =+ 1 1 V 1 ti 1 _ 1 tC - 1 4-- 1 I NOTES 1. INFORMATION SHOWN WAS PROVIDED BY THE OWNER AND SUPPLEMENTED BY A FIELD VISIT BY ARCADIS. 2. AN ACTUAL SURVEY WAS NOT PERFORMED TO LOCATE ALL ITEMS. THEREFORE, THIS FIGURE ONLY REPRESENTS A SCHEMATIC OF CURRENT CONDIOONS AS OBSERVED, AND MAY NOT BE COMPLETELY ACCURATE. EX. VH 0 C ra UZI, PAR:L IE�". a j "=rrr i L /I _ L II 25,15 N 0 1 • t\ :e � EOUAIuZA t N BASIN � F at y / z .•u..�. J I •: eY.s w 'r 1 rx, Sa .';t i '1r ^` w—;A.B — g }EP 4;— _ 1 o-t —1r--I r 1 'a r f n12 w d w -� _ t ram. `�� _r.I 3 -ram•--��—r �._.�- -�`i = ce -��' '-'«;}_d �"'--_"____ r-, A t "`\. ? i75 CONNECTPROPOSEDTO NE 3'-gib"'W t27.23'�: .T..L. �--� 4. a.?8 P" STORMANCE U <.35' � STORMWATER LINE THAT QISCHARGES TO BASINS a 545; - YrE EXPr.: 5i4Yar a `C HVIY NO. 1417( (EXISTING PUBLIC) LEGEND ONSITE STORMWATER — — - y OFFSITE STORMWATER/RDOF DRAINS --- —_.. p SANOAf7f SEWER c WATER o LL ACID AREA TRENCH DRAIN UNDERGROUND ACID g x OVERHEAD CAUSl1C - UNDERGROUND CAUSTIC n y 0 �0' BIT 120' iE SCALE IN FEET O 1u 'Till. A sa.:.-�a P.., NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Paves Perdue Coleen H. Sullins Governor Director March 26, 2009 David Robertson Brenntag Southeast, Inc. 2000 East Pettigrew Street Durham, NC 27703 Subject: Non -Refundable Processing Fee Special Order by Consent Brenntag Southeast, Inc. Durham County Dear Mr. Robertson: Dee Freeman Secretary This letter is to acknowledge receipt of your application for a Special Order by Consent and receipt of the non-refundable application fee (check number 0 16 188) in the amount of $400.00 received from you on March 19, 20o9. Division staff in our Raleigh Regional Office has a copy of your application and will review and process it accordingly. If you have any questions concerning the SOC, you may contact Danny Smith in our Raleigh Regional Office at 919/571-4700 or me at 919/807-6392. Sincerely, Vanessa E. Manuel Eastern NPDES Program Cc: Danny Smith,'DWQ/SWP-RRO SOC File w/ attachments Ken Pickle, DWQ/SWP/Stormwater Permitting Unit H. Glenn Dunn, Poyner Spruill, LLP, 301 Fayetteville St., Suite 1900, Raleigh, NC 27601 1617 Mail Service Center, Raleigh, North Carolina 27699.1617 Locatlon: 512 N, Salisbury St. Raleigh, North Carolina 27604 One Phone: 919-807-63001 FAX: 919-807-64951 Customer Service: 1-877-623.6748 NorthCarolina Internet: www.ncwaterquality.org Naturally An Equal 0ppgdunity 1 AffirmaM Action Employer �/ Y NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Beverly Eaves Perdue Coleen H. Sullins Governor Director February 2, 2009 Mr. Bruce Biehl Brenntag Southeast Inc. 2300 East Pettigrew Street Durham, NC 27702 Subject: Review of Engineers Alternatives Analysis Brenntag Southeast, Inc. Discharge to Unnamed Tributary to Third Ford Creek Durham County Dear Mr. Biehl, Dee Freeman Secretary This letter concerns issues discussed with you and your representatives in our meeting on January 30, 2009 concerning the Engineers Alternatives Analysis submitted by ARCADIS on the behalf of Brenntag Southeast, Inc dated November 5, 2008. The submittal was submitted in response to the Notice of Violation from this office dated June 23, 2008 and a subsequent meeting with your representatives on August 19, 2008. As we discussed in the meeting, there are still concerns/constraints with: 1) co -mingling of process water and stormwater, 2) volume(s) of stormwater that is conveyed to the treatment units, 3) sample data from the facility indicates that the discharge would not consistently meet the requirements of a stormwater permit without treatment, and 4) there are regulatory constraints with respect to using stormwater permitting mechanism to address wastewater and process control/wastewater treatment units (e.g. pH adjustment and aeration). It is the Raleigh Regional Office position that the facility has an existing illegal (unpermitted) treatment unit, and wastewater discharge. This facility, a bulk chemical re -distribution facility, is required to have an Individual Stormwater permit. Currently, the aeration basins are installed in series and do not appear to be properly engineered for the flow volumes that these units episodically receive. You indicated in the meeting, your intention to separate out the process water and other contaminated water from the stormwater and possibly pursue connection to the City of Durham of the process wastewater that is currently being pumped and hauled. Accordingly, it is the RRO recommendation that you seek out a Special Order by Consent (SOC) to allow the facility to pursue compliance with requirements for permitting activities on site while an enforceable compliance schedule is in place. This tool (SOC) will allow Brenntag to develop and implement an organized approach to affecting full compliance. One NCarolina Xa&r1lli1j/ North Carolina Division of Water Quality Raleigh Regional Office Surface Water Protection Phone (919) 791-4200 Customer Service Internet www.ncwaterquality.org 1628 Mail Service Center Raleigh, NC 27699-1628 FAX (919) 571-4718 1-877-623-6748 An Equal Opportun4lAftirmative Action Employer— 50% Recycled110% Post Consumer Paper Mr. Biehl Page 2 Components of this SOC would minimally include the following: -Planning/Investigation -Stormwater Pollution Prevention Plan (SP3) -Stormwater monitoring to include minimally, pH, BOD, metals and organics -Process Water monitoring to include minimally, pH, BOD, metals and organics -Treatment unit monitoring to include minimally, pH, BOD, metals and organics -Discharging treatment unit monitoring -Documentation of Pump and Haul Activities: to include storage control status, storage volume records, pump and hauling records, and destination. -Construction with specific dates to complete portions of the project Attached is an application with directions for submittal. Please respond to this correspondence within February 23, 2009 with your SOC application. Thank you for your attention to this matter. Also, we will be glad to meet with you and your representatives to discuss requirements that will be placed in the SOC. Should you have any questions regarding these matters, please contact Mandy Hall or myself at (919) 791-4200. Sincerely, •� C�1,2 S. Daniel Smith Water Quality Regional Supervisor cc: DWQ Raleigh Regional Office File Copy Matt Mathews — NPDES Permitting Branch Gil Vinzani- NPDES Permitting Representative Paul Luebke, Sate Legislative Big., 300 N. Salsisbury ST. Room 529, Raleigh NC 27603-5925 Patrick Butler — RRO Air Quality John Cox, City of Durham Stormwater Bradley Bennett - Wetlands and Stormwater Branch [Fwd: Re: Brenntag remissions] 0 Subject: [Fwd: Re: Brenntag remissions] From: Niki Maher <Niki.Maher@ncmail.net> Date: Fri, 18 Jan 2008 12:56:00 -0500 To: Bradley Bennett <bradley.bennett@ncmail.net>, Ken Pickle <ken.pickle@ncmail.net> ------- Original Message-------- Subject:Re: Brenntag remissions Date:Fri, 18 Jan 2008 12:00:11 -0500 From:Marcia Allocco <marcia.allocco(ancmail.net> To:Niki Maher <Niki.Mahernancmail.net> CC:Rob Krebs <Rob.Krebs( 'Dncmail.net>, "Hutchins, Olivia" <Olivia. Hutchins( i,mecklenburgcountyne.gov>, "Moore, Meredith" <Meredith. Moorena,mecklenburgcountync. gov> References: <4790BAB7.7090603 (a7ncmail.net> Hi Nikki, I talked with Bruce Biehl (sp?) yesterday from the Brenntag, Southeast, Inc. Durham facility and he stated that the State was requiring them to get a stormwater permit for their Durham facility even though the SIC code did not require it. He stated that they had originally applied — 7 years ago but that application was lost. He stated they had reapplied — 3years ago but had not hear anything so maybe we could address all Brenntag Southeast, Inc. facilities at once and get them all reviewed and permitted together. As far as the second NOV/NRE is concerned they have identified the source of the discharge and it was legacy to when they bought the facility. Apparently a containment area in the railroad offloading section of the site was piped to the creek. He stated that next week he and the facility manager would be walking the site to identify any other pipes and their origin. Marcia Marcia Allocco - Marci_a.Allocco@ncmail.net Environmental Chemist North Carolina Department of Environment & Natural Resources Division of Water Quality - Surface Water Protection Group 610 East Center Ave., Suite 301 Mooresville, NC 28115 Ph: (704) 663-1699 Fax: (704) 663-6040 1 of 1 2/ 18/2008 7:45 AM [Fwd: Brenntag meeting with RROI Subject: [Fwd: Brenntag meeting with RRO] From: Bradley Bennett <Bradley.Bennett@ncmail.net> Date: Fri, 18 Jan 2008 12:52:31 -0500 To: Niki Maher <niki.maher@ncmail.net> CC: Ken Pickle <ken.pickle@ncmail.net> Niki Here is the last think on the Brenntag Durham facility that I have. As I noted, the group determined that the system should be permitted as a wastewater treatment works and no stormwater permit would be required. I'm not sure how much of this Shannon transmitted in his letter. Judy Garrett may have some info as it appears she was in the meetings. ------- Original Message-------- Subject:Brenntag meeting with RRO Date:Mon, 27 Jun 2005 15:45:52 -0400 From:Ken Pickle <ken.pickle(a,ncmail.net> To:Teresa Rodriguez <teresa.rodriguez(a),ncmail.net> CC:Bradley Bennett <bradley.bennett(cDncmail.net>, Gil Vinzani <Gil.Vinzani(a,ncmail.net>, Shannon Langley <Shannon.Langleypncmail.net>, Ken Schuster <ken.schusterPncmail.net>, Judy Garrett <Judy.GarrettPncmail.net> Teresa, Gil wanted me to pass on the results of our meeting this afternoon with RRO about Brenntag. ATTENDING: Ken Schuster, Shannon Langley, Judy Garret, Jenny Atkins, Gil Vinzani, and Ken Pickle The group reached the following conclusions. a) The four treatment vaults constitute a treatment works, and Brenntag must apply for an NPDES wastewater permit for the operation of a treatment works. Or, Brenntag must cease the discharge. Or Brenntag can capture and haul away the discharge. Or Brenntag can provide a roof for larger portions of the site, and potentially connect to the City of Durham's wastewater collection system. b) Shannon Langley will make minor modifications to a draft letter to Brenntag, and send it out right away. The letter will inform Brenntag that they must either cease the discharge, or apply for a permit for the discharge from the four treatment vaults. RRO expects the facility to object to the requirement for a permit, and that the ceasing of the discharge is not a viable option for this business. c) It appears that the facility currently has an NPDES discharge permit for a groundwater remediation system, and it appears that that permit is currently under review for renewal. d) After discussion both ways, RRO felt that there might be some advantage to permitting the discharge from the four treatment vaults on the same permit as the already existing groundwater remediation permit. 1 of2 2/18/2008 7:31 AM [Fwd: Brenntag meeting with RRO] My sense is that this decision is subject to change, if RRO or if NPDES E unit encounters any good reason to keep the two discharges on two different permits. e) The Stormwater Permitting Unit will not try further to resurrect Brenntag's 1996 application for a stormwater permit (we seem to have lost the paperwork, and cannot find anything about it), nor will we seek a new submittal for a stormwater permit from Brenntag. The group consensus was that the operation of a treatment works argues for an NPDES wastewater permit, not a stormwater permit. The group believes that the Director's 1994 determination that Brenntag must seek a stormwater permit may have been reached before the four treatment vaults were installed. Ken 2 of 2 2/18/2008 7:31 AM imap:Hken.pickle%40dwq.denr. ne mail. net @ c ms.ncmail.net:143/fete_. Subject: [Fwd: Brenntag in Durham] From: Tom Belnick <tom.belnick@ncmail.net> Date: Mon, 13 Sep 2004 14,24:45 -0400 To: Ken Pickle <ken.pickle@ncmail.net> Hi Ken- I just received this email, and its another one of those wastewater/stormwater and who permits discussions. I'd like to talk with you about this also. ------- Original Message-------- Subject:Brenntag in Durham Date:Mon, 13 Sep 2004 09:44:51 -0400 From -Shannon Langley <shannon.langle @ncmai].net> To:Mike Templeton <mike.templeton@ncmail.net>, Tom Belnick <Tom.Belnick@ncmail.net> CC:Dave Goodrich <Dave.Goodrich@ncmail.net>, Vanessa Manuel <vanessa.manuel@nemail.net>, Ken Schuster <Ken.Schuster@nemail.net> Tom and Mike, Dave and Vanessa indicated this email would be best directed to you. I am sending this as an informational item but also looking for some feedback from our HQ permitting staff and recommendations on how to proceed. Brentagg Inc (formerly SouthChem) is a chemical distributor located in Durham. The facility receives and repackages for distribution large volumes of chemicals. Our office has received a significant number of complaints about impacts from the facility to a UT to third fork creek (which is impaired). The facility has a GW remediation permit but also has a series of "vaults" where they collect all the rainwater runoff from their property. These "vaults" are aerated. Further, company staff check and adjust pH of the water collected in these valuts prior to releasing it to the UT. Company staff have indicated they have to add sulfuric acid to the water to adjust pH b/c it usually has a pH of 10 or 11. Sometimes though staff have to adjust the pH upwards b/c it is below 6.0. Durham Stormwater services, a service of Durham public works, have done some more extensive sampling out there. I have attached a spreadsheet they sent to us with some of the results they got from sampling the vaults. Downstream samples of pH have shown values anywhere from 4-11 below the plant (there is no upstream as this plant sits right at the fall line between the Neuse and Cape Fear basins). We have taken ph readings below the facility and gotten reading of 9.2 pH instream. A file review reveals that in 1994, then Section chief Steve Tedder, sent a letter to the facility stating they must obtain an NPDES SW permit. An aplication was submitted and received a permit number (NCS000345). This permit still shows up as "In draft" on BIMS and no permit has been issued. In 1998, a memo from the Raleigh regional office was sent to Coleen stating since the facility was capturing, aerating and performing pH adjustment on this water, that this process constituted the "operation of a treatment works". No further information is available in our files. It seems as if a discussion as to whether the facility should receive a SW or WW permit may have resulted in the facility 1 of 2 9/15/2004 2:04 PM imap://ken.pickle%40dwq.denr.ncmail.net @cros.ncmail. net:143/fetc... receiving no permit at all to this point. The creek below this facility is being impacted. Basic pH conditions, acidic ph conditions, chemical smells in the creek are documented on a routine basis. Smells have been so bad at times Durham police have been called in to look for dead bodies. Our office recommends the facility be required to apply for and obtain an individual NPDES permit because of the nature of "treatment' of this water. Before proceeding we would like to get any comments or suggestions from HQ on this matter. The RRO plans to send the facility a letter detailing our findings and requiring that the facility submit an application for an NPDES permit to your office. If you would like to do a site visit I would be happy to arrange. Thanks. Shannon Langley Mr. E. Shannon Langley Environmental Specialist Raleigh Regional Office NC Division of [later Quality 2 of 2 9/15/2004 2:04 PM DIVISION OF ENVIRONMENTAL MANAGEMENT July 31, 1998 M E M O R A N D U M To: Steve Tedder Coleen Sullins From: Steve Mitchell Subject: Stormwater Discharge Designation Letter SouthChem Incorporated 2000 East Pettigrew St P.O. Box 1491 Durham, N.C. 27702 On November 8, 1994 Messrs. Ted Cashion and Steve Mitchell visited the subject facility. Although the Standard Industrial Classification does not apply for stormwater permitting (there is no actual manufacturing that takes place) this facility repackages chemicals for resale. SouthChem is a regional distributor of industrial chemicals. This facility manages high volumes of chemicals which include caustic soda, soda ash, sodium sulfate, muriatic acid, acetone, trichloroethane, xylene, methyl ethyl ketone, and toluene. This repackaging transpires from railroad car or tanker, to forty pound sack or five gallon carboy, etc. The stormwater generated at this site is collected in two separate aeration basins, mixed and neutralized as necessary, and discharged. There is proper containment around the bulk holding tanks and I am sure that all of the safety procedures are followed. But accidents and spills do occur when transferring from train cars to distribution areas to fifty-five gallon drums and so forth. This facility recently released 200 gallons of water (August 22, 1994) from the containment basin with a pH of 10.2 and at that time the treatment works were determined to be a treatment works. In response, the company indicated that they would remove the aeration and mixing and thereby create a stormwater containment basin and not be in violation of General Statutes for operation of a treatment works without a permit. If this is not sufficient information for designation, please inform me. ArGERAGHTY AAftfC'o 1 .f7T T T`" YXTl1 r2�1 ;__ - Mr. Ted Cashion, Groundwater Raleigh Regional Office Division of Environmental Management Department of Environment, Health and Natural Resources 3800 Barrett Drive Raleigh, NC 27604 Re: NPDES Permit Application for Southchem, Inc., Dear Mr. Cashion: pany 1995 This letter is to confirm our telephone conversation on May 16, 1995, regarding the NPDES permit application submittal for the Southchem, Inc. facility located at 2000 E. Pettigrew Street, Durham, North Carolina. On March 3, 1995, prior to the deadline for submitting the NPDES permit application, we talked with Mr. Steve Ulmer, Division of Environmental Management, regarding the potential delay in submitting the NPDES permit application for the above -referenced facility due to sampling problems associated with the weather. Most of the significant storm events occurred at night or within 72 hours of the previous storm event. As a result we were not able to collect the storm water samples from the facility outfalls. Mr. Ulmer indicated that the 90-day deadline was informal and a formal extension was not required. He also indicated that he would update you on the status of the Southchem permit application based on our conversation. As I informed you on May 16, 1995, we are currently waiting for a significant storm event for sampling. Upon collection/analysis of the storm water samples, a NPDES permit application will be submitted as soon as practicable to the Division of Environmental Management Thank you for your cooperation. If you have any questions please contact myself or Najun Shetty at (919) 571-1662. Sincerely, GE & INC. Christoo ovdahl Project Chemist CWL/smp &Wsets mjunlgoulhcheked-letw5l CrossPointe 11, 2840 Plaza Place, Suite 350 - Raleigh, North Carolina 27612 - (919) 571-1662 - FAX (919) 5717994 t i State of North Car`u„na Department of Environment, Health and Natural Resources 'Division of Environmental Management James B. Hunt, Jr., Governor Jonathan B. Howes, -Secretary A Preston Hovyi�� r`,'`�'1E„ Director 11 G l November 30, 1994 Bruce Biehl 2000 East Pettigrew Street Post Office Box 1491 Durham, N.C. 27702 Subject: NPDES Stormwater Permit Application SouthChem Inc. Durham County Dear Mr. Biehl: Based upon an evaluation made by Mr. Steve Mitchell and Mr. Ted Cashion of the Raleigh Regional Office concerning the stormwater discharge from SouthChem our Water Quality Section has determined that this facility is a contributor of pollutants to the waters of the B.E. Jordan Watershed. I have determined that this discharge of stormwater must be covered by an NPDES Permit to be issued by this Division. Therefore, in accordance with the provisions of Title 40 Code of Federal Regulations (CFR) Part 122,26(a)(1)(v), I am hereby designating this stormwater discharge as subject to permitting under the NPDES program. A NPDES permit application shall be submitted within 90 days of the receipt of this letter. The attached application forms (Form 1 and Form 2F) must be completed and properly signed and the permit application filing fee ($400.00) must accompany the application forms. Please note that these applications require the sampling and analyses of a stormwater sample from a representative storm event and the submission of the data in the Form 2F. If you should have any questions or require additional information, please contact Mr. Mitchell of our Raleigh Regional Office at 919-571-4700. Sincerely, A. Preston Howard, Jr., P.E. v `- cc: Permits and Engineering City of Durham Durham County Health Department RRO attch (Form 1 and Form 2F) P.O, Box 29535, Raleigh, North Carolina 27626-0535 Telephone 919-733-7015 FAX 919-733-2496 An Equal Opportunity Affirmative Acfion Employer f(, re^vcl�)n/ 10% post-cnn;umer paper ho Ethyl Hexanoic Acid C8-1-116-02 140 ug/I 1,1-Dichloroethene C2-H4-Cl2 3.4 ug/I 1,1-Dichloroethane C2-H4-Cl2 0.42ug/I cis-1,2-Dichloroethene C2-H4-Cl2 0.74ug/l GENERAL Toxic by ingestion, inhalation, and through skin absorption. Strong irritant to eyes and skin. Carcinogenic. Flammable, dangerous risk of fire. Explosive in air at 6 to 16%. TLV: 10 ppm in air. Chloroform CHCI3 1.4 ug/I aka Trichloromethane Toxic by inhalation. Prolonged inhalation or ingestion may be fatal. Carcinogenic. TLV: 10 ppm in air. OSHA PEL: 50 ppm for 10 minutes. 1,1,1-Trichloroethane C2-H3-CI3 1.5 ug/l CH3CCI3 aka Methyl Chloroform Irritant to eyes, mucous membranes, and skin. Trichloroethene C2-H3-CI3 1.5 ug/l CHCI:CCI2 Toxic by inhalation. TVL: 50 ppm in air. 1,2-Dichloropropane C3-H6-Cl2 CH3CHCICH2CI aka Propylene Dichloride Flammable, dangerous risk of fire, explosive limitslin air 3.4 to 14.5%. Toxic by ingestion or inhalation. TLV: 75 ppm in air. Has caused liver and kidney necrosis in experimental animals. Tetrachloroethene C2-H2-CI4 4.9 ug/l C12C:CC12 aka Perchloroethylene Irritant to eyes and skin. TLV: 50 ppm in air.