AQ_F_1400166_20221103_CMPL_NOV-Resp

SealedAlr 4a,
10/27/2022 RECEIVED
'North Carolina Department of Environmental Quality NOV 3 2022
Asheville Regional Office
Division of Air Quality
�iv'sionofAirQuatity
Asheville Regional office
2090 U.S. Highway 70
Swannanoa, North Carolina 28778
Attention: Brendan Davey, P.E —Regional Supervisor
RE: Notice of Violation
Dear Mr. Davey
This letter is the response to the RMP audit conducted on 9/27/22 and corresponding NOV letter dated
10/17/22.
NOV (1):
Operating Procedures —The owner operator must certify annually that operating procedures are current
and accurate. According to records at the time of the inspection on September 27, 2022, the most recent
certifications were conducted by the facility on January 6, 2017. Therefore, it appears that Sealed Air's
Hudson facility failed to certify operating procedures annually during the calendar years of 2018, 2019,
2021 and 2022.
Response:
Sealed Air has implemented a plan to certify all operating procedures for 2022 and annually thereafter.
We anticipate the process for 2022 will be completed by 11/4/2022.
NOV (2):
Compliance Audits—The owner/operator must conduct a compliance audit certifying the evaluation of the
design and effectiveness of the entire prevention program at least once every three years. According to
documentation reviewed during the inspection, the most recent compliance audit was certified on May 16,
2016. Therefore, Sealed Air's Hudson Facility failed to complete a compliance audit at least once every
three years.
Response:
Sealed Air completed regulatory audits of the Hudson facility on 5/21/2018 and 9/11/2019 which did
involve the RMP covered process. Sealed Air has developed a RMP specific audit protocol to document
the elements required by the RMP regulation. The most recent RMP audit was completed on 10/20/2022.

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NOV (3):
Emergency Response Coordination —Beginning September 21, 2018, coordination with local emergency
planning and response organizations must occur at least annually. This is intended to address changes
in the regulated process, or potential changes to the owner/operator's emergency response and/or the
community emergency response plan. The owner or the operator of the regulated process shall document
coordination with local authorities. At the time of the inspection, it was stated that there were no
coordination activities between the Sealed Air facility and local emergency response organizations during
2019. Although there were records documenting coordination activities in 2020, 2021 and 2022, it
appears the facility failed to complete and document the required emergency response coordination in
2019.
Response:
The 2019 emergency response coordination activity was conducted on January 30, 2019. The attached
letter is the required evidence documenting the activity from the Hudson Fire department. Please accept
this as proof the activity occurred.
Should you have any questions or require further assistance, please contact BJ Mortez at 828-
726-2033.
Sincerely,
Seth Bradshaw
Plant Manager

r 0
2019 Emergency Response Planning Activity Letter
HUDSON RRE DEPAP f MENT
Hudson fire Department
122 Mt,Herman Road
Hudson,K 28638
January 30,201Iq
Vince White
Mant Manager
Sealed Air Corporation
2{101 Intfmationat Blvd,
Hudson.,NC 28,6538
Dear.Mr.Whit e,
On behalf Of the Hu0son.Fire Department,I want to thank you for taking t1inie to CdULate.as or,your
u,perations.Everyone greatly enjoyed the tour and the information provided about your facility an
Wednesday,January 3Q,20,t9,
Sealed Air Cot pur kit ions rommitment to our corrinijinity.is ob(vivus,and we thank you.it is reas."writig to
know that your facility takes a part,in making our town suer-essful.I know yourschedule is very busy and
we 9feadY aPPreciate the time you shared with us,
Hudson Fire Department look-,forward to staying in tauch with you,and please don"t hesitate to call if I
can be of any assistance,
At,
c) -rty E,Courtney,Chief