NCGNE0232_COMPLETE FILE - HISTORICAL_20160223

- - - STORMWATER DIVISION CODING SHEET• - - -
RESCISSIONS .
PERMIT NO. .
DOC TYPE El COMPLETE FILE - HISTORICAL
DATE OF ❑ �V) �Ua (h>
RESCISSION YYYYMMDD

PAT MCCRORY
Governor
, DONALD R. VAN DER VAART
Secrefary _
Energy,Mineral
and Land Resources T R A C Y DAVIS
ENVIRONMENTAL.QUALITY
Direcor
February 23, 2016
Charles E. Powell,Jr.
Sr.EHS Specialist
Pfizer PGS—Wyeth, LLC Sanford
4300 Oak Park
Sanford,NC 27330
Subject: No Exposure Certification#NCGNE0232
Pfizer PGS—Wyeth, LLC Sanford Plant
Lee County
Dear Mr. Powell:
The Division received your letter dated February 19, 2016,notifying us of the delay in funding for the
permanent excess wood chip storage facility construction. This delay means the structure cannot be
completed by December 2016 as outlined in our letter to you late last year.
Given that outdoor storage will persist indefinitely, the company should apply for an NPDES stormwater
discharge permit (and rescind the No Exposure Certification). Because of the nature of the exposed
storage and activity in this drainage area,the DEMLR Stormwater Permitting Program is recommending
that your facility apply for coverage under General Permit NCG210000(Lumber and Wood Products),
rather than under NCG060000, which captures pharmaceutical-related activities(SIC 283-). A Notice of
Intent (NOI) application is enclosed.
As the wood chip area is the only exposed industrial activity at this site,we also recommend that you
apply for Representative Outfall Status(ROS)for the associated outfall. The ROS application form is
enclosed as well. We realize the form is designed to document information about outfall similarities.
Please use question 4. on the form to explain why this outfall is appropriate for ROS(i.e., it is the only
one exposed to industrial activities at the site and characteristic of activities under the General Permit).
Until a Certificate of Coverage(COC)is issued, DEMLR asks you to continue quarterly monitoring for
COD and TSS at the discharge draining from the chip storage area, as stipulated in our December 21,
2015, letter. Please submit the results on the DMR form to the Central Office as we advised(may be
included with your NOI application for the NCG21 General Permit). Note that monitoring requirements
will change upon issuance of the COC. Please refer to the General Permit to understand future
monitoring obligations and conditions.
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
1612 Mail Service Center 1 512 N.Salisbury St. I Raleigh,NC 27699
919 707 9200 T

We appreciate your efforts to keep us apprised of your situation and actively work towards a solution. If
you have any questions or concerns regarding this correspondence, the NOI application, or representative
outfall status (ROS),please contact me at(919)807-6372 or at bethany.geor o� ulias cPncdenr.gov.
{'L
Sincerely,
C
Bethany A. Georgoulias,
Environmental Engineer
DEMLR Stormwater Permitting Program
cc: Stormwater Permitting Program Permit File
Raleigh-R_egional Office/John Holley,.DEMLR Regional Engineer
Central Files
enclosure
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
1612 Mail service tenter� 512 N.Salisbury St Raleigh,NC 27699
919 707 9200 T

Charles E. Powell, Jr.
ONWD Sr. EHS Specialist I
Pfizer PGS
Sanford
4300 Oak Park
Sanford, NC 27330
Via FedEx;Return Receipt Requested
February 19,2016
Ms. Bethany Georgoulias
Environmental Engineer
NC Department of Environmental Quality
Division of Energy, Mineral,and Land Resources
Stormwater Permitting Program
512 North Salisbury Street
Raleigh,North Carolina 27604
Subject: Chip Storage Building Capital Project-Status Update
Current No Exposure Certification No.NCGNE0232
Wyeth, LLC; Sanford, Lee County,North Carolina
Dear Ms. Georgoulias:
In follow up to our February 18, 2016 telephone conversation, Wyeth, LLC,(Wyeth) is informing the
Department of Environmental Quality; Division of Ener4_ . Mineral and Land Resources, (DEQ-DEMLR)
of a delay in the capital funding of a project to construct a permanent storage facility for wood chip
quantities that exceed our Biomass Boiler Storage Silo.
Wyeth understands that the Division has requested that we complete a Stormwater General Permit
application with respect to the Industrial Activity(occasional storage of excess Wood Chip outside).
Wyeth requests guidance and concurrence from DEQ-DEMLR with respect to the possibility of a
Stormwater"General Permit" with a single outfall that is associated with the Industrial Activity of the
occasional storage of excess wood chip, and consideration be given to the fact that the remaining
stormwater pathways and outfalls remain unchanged from previously certified No Exposure Industrial
Activity status_
We look forward to hearing back from you soon and are available to discuss the application further at your
convenience.
If you should have any questions, please contact me at(919)566-4018.
Best Regards
Charles'E. Powell, Jr., RE
Sr. EFTS Specialist I

Geor oulias, Bethan
from: Powell, Charles <[e-mail]>
Sent: Tuesday, December 22, 2015 8:26 AM
To: Georgoulias, Bethany
Subject: RE: No Exposure Response
Bethany
9:30AM sounds good. We can call you at your office number below. Thank You!
Chuck
I �I U
cv-VV-P, 69( Vvi9- C4.c,1.c� Pie�l
Chuck Powell, REM
Sr. EHS Specialist I
Pfizer Vaccines VI S I J
Environmental Health & Safety �('_ ` ` / �L 4300 Oak Park Road 1
Sanford, NC 27330
(919) -4018- Desk 708
[phone]-Fax
[phone]-Mobile y ;I rck do Cy 01-1- 41.9-
[e-mail]
From: Georgoulias, Bethany [mailto:bethany,[e-mail]]
Sent: Tuesday, December 22, 2015 8:24 AM
To: Powell, Charles
Cc: Pickle, Ken
Subject: RE: No Exposure Response
Hi Chuck,
What about 9:30 AM? Should I call you, or will you call me?
Bethany Georgoutias
Environmental Engineer
Stormwater Permitting Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany,georgoulias@ncdenr. ov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: httn:Hportal.ncdenr.org/web/lr/stormwater
f

PC- %'Nothing Compares.,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Powell, Charles mailto:Charles.Powell fizer.com]
Sent: Monday, December 21, 2015 9:47 AM
To:Georgoulias, Bethany<bethanv-Reorgouliasi2ncdenr.gov>
Subject: RE: No Exposure Response
I
Hello Bethany
Can you be available for a phone conference on this memo tomorrow morning Dec 22? We have a couple of questions
that we would like some clarity on.
Chuck
Biobech
Powell, REM
Sr. EHS Specialist I
Pfizer Vaccines
Environmental Health & Safety
4300 Oak Park Road
Sanford, NC 27330
[phone]- Desk
[phone]-Fax
[phone]-Mobile
Charles.Powell(d)Pfizer.com
From: Georgoulias, Bethany fmai Ito:bethanyaeoraouIias ncdenr.aov]
Sent: Monday, December 21, 2015 9:31 AM
To: Powell, Charles
Cc: Pickle, Ken; Holley, John; Bennett, Bradley
Subject: No Exposure Response
Chuck,
Please seethe attached response and follow-up from DEMLR regarding Pfizer—Wyeth, LLC's request regarding No
Exposure status. The hard copy will go out in the mail today with the attachments (monitoring forms). I have copied
John Holley with the Raleigh Regional Office on this correspondence as well.
I'll be in the office briefly tomorrow morning before I'm out again for the holidays, returning Monday,January 4th. The
forms will be attached to the letter, but you may also find them here: http://portal.ncdenr.or�webf Ir npdes-
stormwater(NCG21 General Permit SDO DMR Form)
2

PAT MCCRORY
Governor
..s
DONALD R. VAN DER VAART
., Secs elan'
Energy,Mineral
and Land Resources TRACY DAVIS
ENVIRONMENTAL QUALITY
Db eclor
December 21, 2015
Charles E. Powell,Jr.
Sr. EHS Specialist
Pfizer PGS—Wyeth, LLC Sanford
4300 Oak Park
Sanford,NC 27330
Subject: No Exposure Certification#NCGNE0232
Pfizer PGS—Wyeth, LLC Sanford Plant
Lee County
Dear Mr. Powell:
The Division received your letter dated September 16, 2015, following up on our site visit and discussion
with you at Wyeth,LLC's Sanford Plant on July 22, 2015. The purpose of that visit was to discuss the
plant's need to temporarily store wood chips for the Biomass Boiler outside when quantities exceed the
Storage Silo capacity, and the implications for the plant's current No Exposure Certification. We
understand the company is moving forward with a capital engineering project to construct a permanent
storage building to eliminate stormwater exposure of the excess chips when needed.
For the interim period,the company is seeking concurrence from DEMLR on maintaining No Exposure
status for this plant site while implementing good housekeeping and other best management measures to
minimize exposure and runoff from chips stored outside until permanent shelter construction is
completed. The shelter would bring the site back into compliance with its No Exposure Certification.
DEMLR Staff agree that this storage situation constitutes exposure and does not satisfy No Exposure
Certification conditions, which triggers the requirement for an NPDES stormwater discharge permit.
However, if Wyeth, LLC elects to maintain the NCGNE during this period and works towards regaining
full compliance with No Exposure conditions, DEMLR will consider favorably its progress toward
achieving compliance as long as the company:
• Confirms to us continuing progress toward completing the capital project,and the current
completion date for the shelter is no later than December 2016; and
• Begins sampling discharges draining from the temporary chip storage area on a quarterly basis
in accordance with the analytical monitoring suite in General Permit NCG210000 (Lumber and
Wood Products, i.e., Chemical Oxygen Demand (COD)and Total Suspended Solids (TSS)).
State o£North Carolina I Environmental Quality�Energy,Mineral and Land Resources
1612 Mail Service Center 1 512 N.Salisbury St. I Raleigh,NC 27699
919 707 9200 T

Please use the Data Monitoring Report (DMR) forms available on our website for the NCG210000
General Permit to record results. Instead of the address on the form(DWQ Central Files), we ask that
you submit the results of the analytical monitoring within 30 days of receipt from the laboratory directly
to the following address:
Attention: DEMLR Stormwater Permitting Program—Central Office
1617 Mail Service Center
Raleigh,NC 27699-1617
Four copies of this form are enclosed. While this DMR form is set up for semi-annual or monthly
reporting,please use the form for quarterly monitoring results and include revision notes as needed. The
form also includes benchmark values for COD and TSS that pertain to specific Tier Response actions in
the General Permit and do not apply in this case;however,personnel reviewing the data should still use
these benchmark levels as a guide for investigating problems or revising shelter construction schedule. If
monitoring demonstrates that these conditions are causing or contributing to water quality standard
impacts,the Division may pursue more immediate action.
We appreciate your efforts to discuss your situation with our agency and actively work towards a
solution. We have reviewed the Job-Aid submitted with your letter and find the document helpful for
meeting your goal. DEMLR did note that the Job-Aid document could do more to help the employee
understand why these actions are important—i.e., adding documentation or training that informs the
employee that the purpose of these actions are to prevent stormwater pollution. If you have any questions
or concerns regarding this correspondence,please contact me at(919) 807-6372 or at
bethany, eorgoulias@ncdenr, og_v.
SincerelyV. Georgoulias',�'�
Be an
Environmental Engineer
DEMLR Stormwater Permitting Program
cc: Stormwater Permitting Program Permit File
Raleigh Regional Office/John Holly,DEMLR Regional Engineer
enclosure
State of North Carolina I Environmental Quality I Energy,Mineral and Land Resources
1612 Mail Service Center 1 512 N.Salisbury St I Raleigh,NC 27699
919 707 9200 T

4 � PAT MCCRORY
er�ror-
lt �L � DONALD R. VAN DER VAART
Secrernn-
Energy,Mineral
and Land Resources �? ro `
T R A C Y DAVIS
ENVIRONMENTALpUALITY
ZS r� _ f zlv� ! — �n 1-7• DirecrorDecember 21,2015
-16 C,� c,,-s z
S-�y}�` "f'6-
ll,Jr.Charles E. Powe /
Sr. EHS Specialist V�4o S t r VJ w1 N
Pfizer PGS—Wyeth, LLC Sanford
4300 Oak Park
Sanford,NC 27330
A4
Subject: No Exposure Certification#NCGNE0232
Pfizer PGS—Wyeth, LLC Sanford Plant
Lee County
Dear Mr. Powell:
The Division received your letter dated September 16, 2015, following up on our site visit and discussion
with you at Wyeth, LLC's Sanford Plant on July 22, 2015, The purpose of that visit was to discuss the
plant's need to temporarily store wood chips for the Biomass Boiler outside when quantities exceed the
Storage Silo capacity, and the implications for the plant's current No Exposure Certification. We
understand the company is moving forward with a capital engineering project to construct a permanent
storage building to eliminate stormwater exposure of the excess chips when needed.
For the interim period, the company is seeking concurrence from DEMLR on maintaining No Exposure
status for this plant site while implementing good housekeeping and other best management measures to
minimize exposure and runoff from chips stored outside until permanent shelter construction is
completed. The shelter would bring the site back into compliance with its No Exposure Certification.
DEMLR Staff agree that this storage situation constitutes exposure and does not satisfy No Exposure
Certification conditions, which triggers the requirement for an NPDES stormwater discharge permit.
However, if Wyeth, LLC elects to maintain the NCGNE during this period and works towards regaining
full compliance with No Exposure conditions,DEMLR will consider favorably its progress toward
achieving compliance as long as the company:
• Confirms to us continuing progress toward completing the capital project,and the current
completion date for the shelter is no later than December 2016; and
• Begins sampling discharges draining from the temporary chip storage area on a quarterly basis
in accordance with the analytical monitoring suite in General Permit NCG210000 (Lumber and
Wood Products, i.e., Chemical Oxygen Demand (COD) and Total Suspended Solids (TSS)).
State ol'North Carolina I Envirorunernal Quality I Energy,Mineral and Land Resources
1612 Mail Service Center 1 512 N.Salisbury St. I Raleigh,NC 27699
919 707 9200 T
.;x V

l
Please use the Data Monitoring Report(DMR)forms available on our website fortheNCG210000
General Permit to record results. Instead of the address on the form(DWQ Cent al-Files),we-ask-thdt
you submit the results of the analytical monitoring within 30 days of receipt from the laboratory directly
to the following address:
Attention: DEMLR Stormwater Permitting Program—Central Office
1617 Mail Service Center
Raleigh,NC, 27699-1617
Four copies of this form are enclosed. While this DMR form is set up for semi-annual or monthly
reporting,please use the form for quarterly monitoring results and include revision notes as needed. The
form also includes benchmark values for COD and TSS that pertain to specific Tier Response actions in
the General Permit and do not apply in this case; however,personnel reviewing the data should still use
these benchmark levels as a guide for investigating problems or revising shelter construction schedule. If
monitoring demonstrates that these conditions are causing or contributing to water quality standard
impacts, the Division may pursue more immediate action.
We appreciate your efforts to discuss your situation with our agency and actively work towards a
solution. We have reviewed the Job-Aid submitted with your letter and find the document helpful for
meeting your goal. DEMLR did note that the Job-Aid document could do more to help the employee
understand why these actions are important—i.e.,adding documentation or training that informs the
employee that the purpose of these actions are to prevent stormwater pollution. If you have any questions
or concerns regarding this correspondence, please contact me at(919) 807-6372 or at
betliaiiy.Lycor.L�oul i asP,ncdenr.t:ov.
Sincerely,
Original signed by Bethany Gerogoalias
Bethany A. Georgoulias,
Environmental Engineer
DEMLR Stormwater Permitting Program
cc: Stormwater Permitting Program Permit File
Raleigh Regional Office 1 John Holly, DEMLR Regional Engineer
Central Files
enclosure
State of North Carolina I Ern•vonntental Quality I Energy,Mineral and Land Resources
1612 Mail Service Center 1 512 N.Salisbury St. { Raleigh,NC 27699
919 707 9200 T
s.

Georgoulias, Bethany
From: Pickle, Ken
Sent: Monday, December 14, 2015 1:04 PM
To: Georgoulias, Bethany
Cc: Bennett, Bradley
Subject: FW: Pfizer No Exposure?
Bethany,
Bradley raised the question to me of whether the stormwater monitoring suite in NCG21 would also be appropriate,
rather than my initial suggestion of NCG24 less feca Is. Comparing the two:
NCG 24 Compost: quarterly for TSS, COD,TN, TP, Cu, Pb,Zn, pH.
NCG21 Timber: twice/yr for TSS, COD.
• Given that we anticipate a short duration (-1 year) exposure, then I think the NCG21 suite is ok, i.e. with the
reduced parameter selection in NCG21, but maybe at the increased frequency of NCG24 (quarterly).
• Intuitively, with the relatively small area of exposure of the chips pile and the relatively inconsistent presence of
the pile, I doubt that there will be significant mass of Cu, Pb, Zn,TN, TP contributed to the receiving water. I
think it's OK to drop them from the suite.
• Arguably, the stockpiling of boiler fuel chips is closer to the normal site conditions targeted under NCG21 rather
than NCG24 .
All this assumes we are willing to enter into a sort of trade off of allowing them to continue under NCGNE, in exchange
for a minimal check on the character of the discharge while they work toward regaining no exposure status.
Ken
Ken Pickle
Stormwater Program Specialist
DEMLR Stormwater Permitting Program
Department of Environmental Quality
919 807 6376 office
ken.pickIe(d-)ncdenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
nothing Compares--.,
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Monday, December 07, 2015 2:20 PM
To: Georgoulias, Bethany<[e-mail]>; Riddle, Rick L<[e-mail]>
Cc: Bennett, Bradley<[e-mail]>
Subject: RE: Pfizer No Exposure?
1

I'm available to discuss M after 2:30, T except 1:00—2:00, W except 11:00-- 1:00, H, and F. Also next week M &T.
For your consideration in advance, here's my December summary, updated today from Jul_
1. Still today Pfizer fails the test for No Exposure based on the chip boiler operating practice constituting exposure,
and potentially on the basis of construction site exposure.
2. IIRC, years ago they previously had qualified for NCGNE, but changes to the operation of the boiler changed site
conditions, and so jeopardize the No Exposure exclusion.
3. But, as with most permittees in violation of NPDES permits or rules, we would want them to work to come into
compliance. Pfizer is doing that now: wrt wood chips they have developed the printed Job Aid since our visit;
and they continue to work toward a capital project for a shelter. (The only defect!saw in the lob Aid was that
the employee was not specifically informed that certain steps of the Job Aid were intended to control
storm water pollution. They didn't tell the employee why.) Continuing, and wrt on-site construction, I'm not
sure the construction areas meet the 1 acre threshold. Do you recall? If not, no problem? Even if so, consider
that their construction projects are presumably moving toward completed projects, i.e. moving toward no
exposure.
4. At the time of our visit, we did not observe indications of an egregious impact on water quality: we didn't
analyze samples, or look in the creek, etc., but the intuitive evaluation of what we saw was not worrisome. I
was more interested in the trail of sediment from the construction site to the storm drain inlet than I was with
the stained parking lot down gradient from the chips piles.
5. Proposed approach: Tell Pfizer that they fail the test for NCGNE, but that the NCGNE can remain the vehicle for
their compliance with NPDES rules if:
a. They confirm to us the continuing progress toward the capital project, and the current completion date
is Dec. 2016 or earlier.
b. They confirm to us the continuing progress of the construction activities on site and report a completion
date for them on or before Dec. 2016 (?).
c. They begin taking quarterly samples in January in accordance with the monitoring suite in NCG24, less_
fecals. We (SPP)will review the results real time, and advise if we see any reason to change the
approach outlined here. This extra sampling is intended to provide a basis to rebut any contention that
the site is causing harm because it's under NCGNE inappropriately, and should instead be under an
individual stormwater permit with analytical monitoring, benchmarks, and potentially monthly
sampling.
d. As we considered before, this approach allows us to conserve our very valuable time in order to put our
time toward more impactful activities.
kbp
From: Georgoulias, Bethany
Sent: Monday, December 07, 2015 9:45 AM
To: Pickle, Ken <[e-mail]>; Riddle, Rick L<[e-mail]>
Cc: Bennett, Bradley<bradley.ben [e-mail]>
Subject: RE: Pfizer No Exposure?
Ken/Rick,
We received this response from Pfizer back in September, and l have not yet responded to it. There has just been too
much on SPP's plate. We owe them a response, and it would be helpful to me to sit down with one or both of you and
discuss so I am confident on what direction we should be headed on this. We were undecided at the time, and this
follow-up from you back in July was leaning away from approval, but we are now half a year beyond that(and
presumably closer to when they'll build permanent shelter).
2

f'
Do you have some time on Friday, or maybe early next week, so I can get back to Chuck before the holidays on this?
Thanks,
Bethany
Bethany Georgoulias
Environmental Engineer
Stormwater Permitting Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany.georgoul ias(gnedenr.gov
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh,NC 27604 (location)
Website: http://portal.nedenr.org/web/lr/storrnwater
KID. ''Nothing Compares,..
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Pickle, Ken
Sent: Friday,July 24, 2015 12:22 PM
To: Georgoulias, Bethany<bethanv.eeorgouliasgncdenr.,gov>; Riddle, Rick L<[e-mail]>
Subject: Pfizer No Exposure?
Bethany,
For your use as you deem appropriate, here are my notes and analysis on Pfizer. Please correct my observations or
conclusions where I'm off the mark.
The beginning standard is found at 40 CFR 122.26(g):
(g) Conditional exclusion for"no exposure"of industrial activities and materials to storm water. Discharges composed
entirely of storm water are not storm water discharges associated with industrial activity if there is "no exposure" of
industrial materials and activities to rain, snow, snowmelt and/or runoff, and the discharger satisfies the conditions in
paragraphs (g)(1) through (g)(4) of this section. "No exposure" means that all industrial materials and activities are
protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Industrial materials or
activities include, but are not limited to, material handling equipment or activities, industrial machinery, raw materials,
intermediate products, by-products, final products, or waste products. Material handling activities include the storage,
loading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste
product.
Pfizer fails this test. Specifically, all industrial activities and materials are not protected by a storm resistant
shelter to prevent exposure to rainfall. Bark chips for fuel are sporadically exposed to rainfall, i.e. they are not
protected by a storm resistant shelter. The duration of the exposure is on the order of 3—4 days maximum
recurring monthly during approximately 6— 8 months per year(?), and the maximum amount of material exposed
at any one time is typically four to six(?) dump truck loads.
3

Federal rule qualifiers and exceptions to the beginning standard test in 40 CFR 122.26
• Tightly sealed containers not leaking and not operational do not require a storm resistant shelter, and would not
disqualify from No Exposure. Not relevant at Pfizer.
• Adequately maintained vehicles used in material handling. Not relevant at Pfizer.
• Final products not mobilized by stormwater. Not relevant at Pfizer.
Federal rule clarifications/limitations/explanations of exposure and no exposure
• Industrial material and activities that must be protected/sheltered include: material handling activities, raw
materials, loading and unloading of any raw material. Would seem to apply at Pfizer.
• Stormwater discharges from construction activity are not eligible for the No Exposure exclusion from
permitting. Combined with the specific rules provision that No Exposure is available only on a facility wide
basis this presents us with an interesting consideration at Pfizer.
• The original certification (and presumably North Carolina's special annual recertification) must indicate that
there will be no exposure of"(B) Materials or residuals on the ground...(E) Materials or products during
loading/unloading...(F) Materials or products stored outdoors...(H) Materials or products handled/stored on
roads..." If circumstances change such that the business can no longer certify to no exposure, the discharge
becomes subject to enforcement for unpermitted discharge, and the discharger should apply for and obtain
permit authorization. So for Pfizer's in a tough situation with the federal rule definition and clarifying
descriptions o}"no exposure':
Federal and other guidance, as I understand it material from our SP_P Guidance folder and from EPA's June
2000 No Exposure guidance manual)
• Temporary laydown areas for construction and maintenance activities may be allowed under some (?)
circumstances.
• We have allowed the granite slab folks to store rock slabs outside unprotected and still grant No Exposure.
• Our experience is that tarps are only suitable for very small areas (e.g., 8'x8'), and that it is not realistic to think
that tarps can be deployed reliably for large areas or piles.
• It's all a matter of degree of exposure, ultimately. This question tests us as to how large an exposure is ok to still
be considered No Exposure.
• We can allow the exposure of products intended to see outdoor service (like automobiles), and still grant No
Exposure.
• Pfizer has a fairly clean site with two exceptions
o On-going construction: sediment travelling to stormwater inlets(even though protected somewhat by
hay bales); contractor lay down yards with scrap and presumably demolition dumpsters (pretty well
disconnected from discrete drainage ways) -- UAJL& 0 > t ?tAre, c ✓Ld
o Chips exposed sporadically(but as a deliberate, recurring feature of the boiler operation.) Clear
evidence of pollutant transport off site (staining across the parking lot entering a vegetated ditch.) The
flow enters either Buffalo Creek, or the Lee Brick ponds. Perhaps unlikely that there is a significant
impact from either of the discharges from the chips area at Pfizer. But, certainly uncertain as to
whether years of discharges of wood bits and wood powder might be exerting a measureable COD in the
receiving water, or resulting in a deposit of organic material. In retrospect, it might have been helpful for
us to cross the fence line and eyeball the ditch and clay pits. Although, we may not have been able to
discern much that would be relevant.
Ameliorating site circumstances
• Apart from the two conditions noted immediately above the site is otherwise relatively clean.
• There is a possibility that the existing discharges have no measureable impact on the receiving water due to
travel distance and/or retention time vs small absolute mass of pollutants potentially mobilized by runoff.
• Although recurring, the exposure of chips is relatively infrequent and of short duration, occurring only when the
chip silo is at capacity.
Hay bales for(some) solids capture are available, and reportedly Pfizer deploys them when excess chips are
dumped.
4

• Pfizer reportedly sweeps the dump area immediately after the pile of chips has been fully depleted.
• Pfizer demonstrated commitment to a capital project to remove the exposure of wood chips, potentially
complete in 4Q 2016.
• The relatively short exposed storage duration suggests limited degradation in place, and consequently limited
transport and discharge of wood chip degradation pollutants.
Regulatory and administrative considerations
• Pfizer has an NCGNE now. It seems excessively bureaucratic to transition Pfizer into a NPDES stormwater permit
based on the chips exposure, and then back out again to NCGNE once the demolition and reconstruction is
completed (this year?) and the capital project for a storm resistant shelter is completed (4Q 2016).
• Given the demands on our time, it seems to be responsible to preferentially allocate our time for other issues
and actions that may more effectively protect surface waters from the impacts of runoff pollution. The Pfizer
site appears to be small potatoes from the perspective of impact on Buffalo Creek. It conserves our time to
allow the continuation of NCGNE, rather than require short duration coverage under an NCG or NCS.
• We have asked Pfizer to provide written arguments in support of the request for a favorable agency
determination and the continuation of No Exposure, despite the agreement that there are recurring
exposures. It may be that arguments they present will further help us decide what to do at Pfizer.
• On the other hand, it is legitimate to consider that we do not want to set a precedent that weakens our
requirements for granting or continuing the No Exposure Exclusion from Permitting. No Exposure is a valuable
regulatory tool for protecting surface waters.
• One potential resolutionRath: We receive and evaluate Pfizer's written arguments. Assuming the arguments
are solid, propose that Pfizer may continue under NCGNE until December 2016 (?)for the several reasons
stated, but that Pfizer must take quarterly samples analyzed for the constituents contained in the NCG24
Composting General Permit, less fecal coiiform. No other features of the NCG24 General Permit
pertains. Sampling to continue quarterly for 2 quarters after the completion of the storm resistant shelter or
December 2016, whichever is later. At the end of this time Pfizer shall re-certify to SPP the condition of No
Exposure. SPP or RRO may or may not conduct a confirming inspection.
SPP or RRO to receive the quarterly results, and to respond to them as they may indicate. Meaning, if there are
no hits,then the NCGNE can remain in effect. If there are hits above the NCG24 benchmarks, RRO or SPP to
evaluate the significance of them and direct Pfizer to: apply for a NCS or NCG permit in the case of egregious
exceedances; propose increased housekeeping measures for exceedances judged less worrisome by SPP or RRO;
or other response actions that Pfizer and SPP might agree to.
o Our summary explanation to Pfizer is: Strictly speaking, you fail the test for no exposure. However,
DEMLR has determined that the otherwise good site housekeeping, the reasonable exercise of our
authority to protect water quality, and our responsibility to make the best use of our limited staff
resources, will allow us to continue Pfizer under the NCGNE if Pfizer will provide quarterly performance
monitoring to establish that no uncontemplated egregious impacts are occurring. SPP/RRO will review
the quarterly reports in real time to assure that any significant exceedances are addressed together with
Pfizer.
5

Ken Pickle
Stormwater Program Specialist
NCDENR I DEMLR t Stormwater Permitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury St, Raleigh, NC 27604
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Website: http://portal.ncdenr.org/we11r/stormwater
** Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties unless the content is exempt by statute or other regulations.**
6

Charles E. Powell, Jr.
Sr. EHS Specialist I
Pfizer PGS
Sanford
4300 Oak Park
Sanford, NC 2733Q
Via FedEx; Return Receipt Requested
September 16, 2015
Ms:Bethany Georgoulias
Environmental Engineer
NC Department of Environment&Natural Resources
Division of Energy, Mineral, and Land Resources
Stormwater Permitting Program
512 North Salisbury Street
Raleigh;North Carolina 27604
Subject: BMP's for Wyeth, LLC
Sanford, Lee County,North Carolina
Dear Ms. Georgoulias:
As a follow up to your recent visit to our facility and per your request, we are forwarding you a"Job-Aid"
that we have developed around receipt and intermittent storage of wood chip on the pavement area behind
our Central Utility Building(CUB), Biomass!Boiler operations area. As we mentioned during your visit,
we have implemented procedures and practices to improve the management the wood chip storage pile
during rain events. Specifically we have implemented Best Management Practices(BMP's)to achieve
good housekeeping measures and to minimize runoff. We have developed a Job-Aid(Attached)that will
be used by the CUB personnel that we feel will ensure we have minimized runoff during rain events. In the
Job Aid we cover procedures for our management practices if we have to store chip on the ground beyond 7
days due to an unplanned shutdown. In addition, we have developed a drawing showing our woodchip
storage area and size along with the flow path for rainwater runoff.
Wyeth, LLC, is in the process of moving forward with a capital engineering project to construct a
permanent storage building to provide cover and protection from stormwater exposure. For the interim
period, we are requesting your concurrence on these measures to allow us to maintain our Stormwater No
Exposure Certification status.
If you should have any questions,please contact me at(919) 566-4018.
Best Regards,
arIes E. Powell Jr. REI
Sr. EHS Specialist I SEP A ~�D
z015 .
401 8V _aU
ER A�RMrU N1:S
G

NOTE: Please read carefully and adhere to the blue and red instructions (all
�-! instructional information must be removed prior to routing your document for
reviewlapproval). Remember to comply with the standard document reguiremen for
each document: Font type is Times New Roman,font size is 12 points, spacing A Auld be
1.3, margins must be 1 inch on all sides, and page number must be listed on each page
and right-aligned Refer to JAGPM4205-01 for additional information regarding
document authoring. ,
Classification/ This document provides instructions for receiving biomass wood chips for use in the
Use Biomass Boiler.
Purpose Receive wood chip deliveries & transfer to storage system
When When biomass wood chips are delivered
Materials Work gloves; safety glasses,'safety shoes
Reference SPM-1100. JASPMI 100-11, Figure 7 Drawing .
Documents
QWARNING: Weather conditions must be considered when performing these tasks. If dangerous
• weather is present or occurs during transfer, process must be secured & all personnel must move to a
shelter location. Transfer must be delayed until weather clears.
CAUi10N PPE REQUIRED: Safety glasses, safety shoes, gloves are required when unloading trucks where
personnel may come in contact with equipment or wood chip materials.
{ NOTE. In certain circumstances it may be impossible to receive chips into the reclaimer. In those cases
this procedure begins at section 4.
a
Page 1 of 7

Actions: Do this: Pictures & Illustrations
1.1 Receive notification from Security truck has arrived 1❑ Doors& safe chain
Section 1.0: -
1.2 Open doors at reclaimer 1❑ 17-.j�
1.3 Remove safety chain at reclaimer 1❑
Receiving 1.4 Back truck up against reclaimer 20 t
Preparation 1.5 Chock truck wheels 30 �
NOTE: Truck wheels must remained chocked when unloading into ,: -
reclaimer .�
1.6 Open truck doors
1.7 Close doors on reclaimer against side of trailer -
20 Truck against reclaimer
Ell :}
err ,+�!!�� �■ '+
Section 2.0:
2.1 Instruct driver to start trailer conveyer 30 Chocked truck wheel
2.2 When chips start moving, push reclaimer start button 40
Unload Trailer 2.3 Go inside to Wellons control system, set fuel speed.
into Reclaimer NOTE: Fuel speed is dependent on chip quality
2.4 Monitor unload progress from top of reclaimer&adjust fuel t
speed as required 50 '
NOTE: If unloading entire trailer into reclaimer proceed to section
3. If unloading partial or full load on ground proceed to section 4
NOTE: Check for oil leaks under truck. Notify truck driver&
place oil catch pan under leak.
413 Reclaimer start
50 View from top of
Reclaimer
k
Page 2 of 7

, t
Section 3.0- 3.1 Open doors on reclaimer : 60 Spilled material after
3.2 Remove wheel'ch6cks' unloading
Completing 3.3 Instruct driver to move forward approximately '
8 �F�K ti• '�
Delivery into 3.4 Brush off residua] chips, debris from rear of trailer 6❑ g :r;^:�+c; •_�;;.�-F�;�
Reclaimer 3.5 Close trailerdoors
3.6 Receive drivers paperwork ,. wt• zy
31.7 Instruct driver to leave site {' :?Rsall.
3l8 Clean chip residuals off of concrete&place in reclaimer ' -r
Section 4.0: 4.1 Instruct driver to move to designated temporary storage location 70 Designated temporary
42 When'driver is in position, stand on drivers`side of trailer storage area
Unloading maintaining visual contact with driver in mirror
Partial or Full 4.3 Instruct driver to start trailer conveyer
Load in 4.4 Instruct driver to pull forward approximately 5' when chip pile
Temporary reaches back of trailer ,+w
Storage 4.5 Repeat step 4.4 until contents of trailer are on ground 70 i
I
Section 5.0:
5.1 Instruct driver to move forward approximately 8' 80 Picture of tractor sweeper
5.2 Brush off residual chips,debris from rear of trailer
Completing 5.3 Close trailer doors '
Delivery to 5.4 Receive drivers paperwork +..
Temporary 5.5 Instruct driver to leave site
Storage 5.6 Tidy up loose chips around chip pile 80
.�xkti
Section 6.0- 6.1 Place,straw bales around chip pile as shown in the picture 713
6.2.Use tractor sweeper to actively sweep up any stray chip&any
Securing Chip other fines on pavement area 813
Pile in
Temporary
Storage
Section 7.0- 7.1 Conduct daily inspection of temporary storage area 913 Picture of flow path
7.2 Log status of temporary storage area
Managing 7.3 If chips are being stored in temporary storage area, inspect:
Storm Water storm water flow path for chip fines 90
Runoff from 7.4 Contact EHS if chips have been stored in temporary storage
Temporary area for four consecutive days
Storage 7.5 Contact EHS if fines are found outside of temporary storage —
pile containment straw bales to evaluate containment setup
7.6 Repair or modify temporary storage pile containment straw
bales as directed by EHS
'Page 3 of 7

Section 8.0 8.1 Chip deliveries will be halted for a planned shutdown of 100 Fuel Silo
biomass boiler '
Managing Chip 8.2 For shutdowns of <30 days silo may remain filled with chips
Deliveries 8.3 For semiannual shutdowns of >30 days chips will be ,
'.
During consumed to empty silo prior to boiler shutdown 100
Planned
Biomass Boiler .
Shutdowns
Section 9.0 9.1 Chip deliveries will be halted as soon as possible for a
unplanned shutdown of biomass boiler
Managing Chip 9.2 Chips that will not fit into silo will be placed in chip temporary
Deliveries storage area per sections 4.0—6.0
During
Unplanned
Biomass Boiler
Shutdown
Section 10.0- 10.1 If chips will need to be stored in chip temporary storage area
for more than four days contact EHS 70
Managing 10.2 If chips cannot be used in Biomass process in<7 days. SEM
Temporary & EHS team will develop plan for removal of chips from site
Storage Area
for Chip
Storage Longer
than Four Days
Page 4 of 7

HAZSTOR II NOTES:
1, CROSS
BUILDINGS 6 II G-D0001-01FERENCE(GOOD0101:dwg)
WHEN MAKING MODIFICATIONS
3 ,� TO ANY WASTE STORAGE
9 4 2 Imo! 43Y l -'
AREAS.
II
10-7
-� W E
Tin
0U0 -� p
BOILER
ROOM
GENERATOR
3�vaols diH�
LLUJILLILL I 1 1 11111111 11 ILL
ILL
LLLLI-I--LLLIJ-LLLLLLLLJ-LLLLLLLLU-LU-L I L-
I
DRAWING TITLE
"2 DRAWND
L C341 L`YOUTEY
MAN umuT
11 ULL111--tU Ill IJ 1111 Ill Ll DRAWING NUMBER
FIGURE 7
ca we w raw 7D%

p Charles E. Powell, Jr.
Sr. EHS Specialist f
Pfizer PGS
Sanford
4300 Oak Park
Sanford, NC 27330
Via FedEx; Return Receipt Requested
May 27, 2015
Ms. Bethany Georgoulias
Environmental Engineer RECEIVED
NC Department of Environment& Natural Resources
Division of Energy, Mineral, and Land Resources MAY 2 9 2015
Stormwater Permitting Program
512 North Salisbury Street DENR-LAND QUALITY
Raleigh, North Carolina 27604 STQRMWATER PERMITTING
Subject: BMP's for Wyeth, LLC
Sanford, Lee County, North Carolina
Dear Ms. Georgoulias:
As a follow up to our telephone conversation and email on May 6, 2015, this letter
describes the Stormwater Best Management Practices (BMP's) that we are implementing
at our facility. As we discussed Wyeth, LLC, a subsidiary of Pfizer, operates a 29.4
million Btu per hour Biomass Boiler that uses wet-wood chip as its fuel source. Wood
chip deliveries occur Monday—Friday and are loaded into our Wood Chip storage silo
located behind the Central Utilities Building next to our Biomass Boiler. Our supplier
sources our wood chip from local logging operations. These operations that can
sometimes be affected by weather conditions that prevent them from delivering
consistently to meet our boiler operating needs. As a result we need to periodically store
wood chip in piles on the paved area adjacent to the Storage Silo. The wood chip pile is
typically moved into our storage silo within 4-6 days of receiving the load.
Wyeth, LLC maintains a Stormwater "No Exposure" Certification. We are in the process
of moving forward with a capital engineering project to construct a permanent storage
building to provide cover and protection from stormwater exposure. The project is in the
scoping stage, and a project timeline has not yet been established. We estimate 2°d or 3rd
quarter of 2016 for completion. In the meantime, the following BMP's are being
implement in order to minimize stormwater runoff potential:
1). Good Housekeeping Measures: Our Central Utilities personnel will utilize manual
and equipment assisted mobile sweepers daily to minimize any stray wood chip and

wood chip fines. Wood Chip and fines will be swept up, removed, and placed into the
reclaimer for loading into the storage silo. We will document cleaning activities in our
daily field log book used by Central Utilities personnel.
2). Management of Runoff: We will install silt fencing and hay bales to filter and
control sediment from leaving the storage area during rain events. Any sediment
captured will be disposed of and the area will be inspected daily to ensure the integrity of
the silt fencing and hay bales.
3). Minimize Exposure: We will manage our wood chip delivery volume by working
with our supplier to best determine optimal weekly shipment volumes, considering
weather and operating conditions with the goal of minimizing the amount of loads that
will need to be stored on the paved area near the storage silo.
We are completing our annual stormwater no exposure certification and ask for your
guidance and concurrence of our temporary BM P's to minimize our stormwater exposure
until a permanent covered structure can be put into place at our facility.
If you should have any questions, please contact me at [phone].
Best Regards,
harles E. Powell, Jr., RE
Sr. EFIS Specialist I

Geor oulias, Bethany
From: Georgoulias, Bethany
Sent: Friday, June 12, 2015 1:58 PM
To: 'Powell, Charles'
Cc: Pickle, Ken; Riddle, Rick L; Bennett, Bradley
Subject: FW: Stormwater No Exposure Certification
Attachments: NCGNE WyethLLC_Temporary-BMPs_Letter-20150527.pdf
Hi Chuck,
As I mentioned earlier this week, we received your letter and request for guidance and concurrence on temporary BMPs
to minimize stormwater exposure until a permanent covered structure can be put into place at your facility. We'd like
to arrange a site visit with 2-3 members of our Central Office in July, possibly accompanied by some staff members from
the Raleigh Regional Office. The visit will allow us to give you the best guidance on the company's request regarding No
Exposure. CO staff will include Ken Pickle, me, and possibly Rick Riddle, another Engineer in our group.
The weeks of July 61h or July 201"are best for me to join this visit. Can we set up a time in the morning (maybe around
10 AM?)on one day of those weeks?
I'm heading out of the office for vacation for most of the next two weeks, but I'll be back on Monday,June 291h. While
I'm out, feel free to coordinate a time with Ken Pickle—I'll check in as I'm able via e-mail and will try to confirm a
potential date.
Thank you,
Bethany
Bethanry Gc-orgoidias, Eivironrmenntcil Engineer
NCDENR/Division of Energy,Mineral,and Land Resources
Stonnwater Pennitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh,NC 27604
919 1 807-6372 (phone);919/807-6494 (fax)
Website: http://pgrtal.ncdenr.orp/web/lr/stormwater
E-mail correspondence io aad front liiis address rnav,he srrhjecr to Me A'orih Carolina POlic Retards law and rnav he disclosed!o Mini pa7ies.
1

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Friday,June 12, 2015 1:44 PM
To: Holley, John
Cc: Pickle, Ken; Bennett, Bradley
Subject: FW: Stormwater No Exposure Certification
Attachments: NCGNE_WyethLLC_Temporary-BMPs_Letter-20150527.pdf; NCGNE_SelfRecert_Form.pdf
Hi John,
This facility in Sanford is covered under No Exposure Certfication No. NCGNE0232. Chuck Powell from Wyeth (subsidiary
of Pfizer)called us last month while working through the No Exposure Self-Certification Self-Recertification form. He
called us because, as his letter explains, they receive wood chips for their biomass boiler and sometimes have to
stockpile a volume larger than their silo—which is then moved into the silo within 4-6 days of receiving the load. After
speaking with him about it,we concluded that this is exposure and that the company would need to implement a
permanent solution (shelter cover for example) to maintain No Exposure conditions, or apply for a stormwater permit.
They are moving forward to build a permanent shelter. Because of the planning and capital investment involved, it
won't happen right away. Wyeth would rather do what they need to do without having to apply for a general permit
(NCG06 applies here, and did for a time before they obtained an NCGNE) for a very short period, and then turn around
to rescind it. I advised the company to write us a letter with their proposed solution so we could further guide them on
what to do.
Raleigh Central Office intends to arrange a site visit because this is an unusual circumstance, and we'd like to check our
understanding of the situation as described against ground conditions. It's an educational and program application
opportunity for us—particularly because we run into all sorts of"gray areas" when it comes to No Exposure, and we
make every attempt to solve challenging circumstances in a practical but appropriate way. We are sensitive to the
demands on your time right now without a primary Stormwater Permitting Program staff member. However, once we
set the date,we will let you know in case RRO staff would like to participate.
The visit probably won't happen until July at the earliest; I'm away from the office for the next two weeks. If you have
any questions or concerns about it in the meantime, please let Ken Pickle know in my absence.
Thanks,
Bethany
Beihany Geotgoidias, Environmental Engineer
NCDENR/Division of Energy, Mineral,and 1-and Resources
Stonnwater Pennitting Program
1612 Mail Service Center, Raleigh.NC 27699-1612
512 N. Salisbury Street, Raleigh,NC 27604
919/807-6372 (phone); 919/807-6494 (fax)
Website: http://portal.ncdenr.oryjweb/lr/stormwater
E-mail correspondence to rind from this address man,be subiect to the North Carolina Public Records last,and may be disclosed to third pmvies.
1

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Wednesday, May 06, 2015 11:14 AM
To: 'Powell, Charles'
Cc: Pickle, Ken
Subject: RE: Stormwater No Exposure Certification
Hi Chuck,
Thanks for your question regarding storage of wood chips for the biomass boiler at your site and your No Exposure
annual self re-certification.
I've discussed your situation with my colleagues, and we agree that what you described (an exposed area with excess
wood chips outside maybe 3-4 days until moved into the storage silo, on a somewhat periodic basis) is not considered
No Exposure. If this scenario happened rarely, say once every six months or so, and not typically in wet weather(if
management practices could reduce that likelihood somehow), we might view it differently. I think we have to
acknowledge here that this is an exposure condition. If the company wants to continue to operate under the No
Exposure exclusion, it should implement a solution to cover the wood chips.
We don't always know what peculiar circumstances No Exposure applications will present to us—we've met our
share. Occasionally we encounter circumstances that challenge how we implement the federal rule requirements. So,
in the application and re-certification forms, we've left that "room to wiggle" in a general way—not necessarily because
we know of a specific case where a sawdust or wood chip storage pile has been outside and still allowed an NCGNE
exclusion. There might have been these instances, but I personally can't recall them. I can think of a time where a small
area in a different industry was kept debris-free most of the time, but was occupied at times by material for a compost
vessel. During those periods, the material was covered by a tarp. This is not the strictest interpretation of No Exposure,
but we allowed an NCGNE approval based on the specific case, the limited size of the area, BMPs at the site, and other
observations of the regional inspector and/or central office staff. These kinds of calls are very case-by-case.
I hope that helps. If you have any other questions, please let me know.
Bethany
Bethany Georgoulias, E vironniental L-ngineer-
NCDENR 1 Division of Energy, Mineral; and band Resources
Stomiwater Perniitting Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 N. Salisbury Street, Raleigh; NC 27604
919/807-6372 (phone): 919/807-6494 (fax)
Website: http://portal.nedenr.org/web/lr/stortnwater
E-mail cvrnupondence to and fivm this address nunv be srrlrjeci to the North Corolina Public Records law and maY 6e disclosed io third parties.
From: Powell, Charles [mailto:Charles.Powell(&pfizer.com]
Sent: Tuesday, May 05, 2015 9:42 AM
To: Georgoulias, Bethany
Subject: Stormwater No Exposure Certification
Hi Bethany
1

Thanks for talking with me about the No Exposure Certification for our facility. I am sending you my contact information
so you'll have my email address as well. I look forward to hearing back from you.
Regards,
Chuck Powell
P ierBiotech
Chuck Powell, REM
Sr. EHS Specialist I
Pfizer Specialty Care/Biotechnology
Environmental Health & Safety
4300 Oak Park Road
Sanford, NC 27330
[phone]- Desk
[phone]-Fax
[phone]-Mobile
Charles.Powell((IPfizer.com
2

WAT� Michael F.Easley.Governor
`" `Oa0 RnG William G.Ross Jr..Secretary
w North Carolina Department of Environment and Natural Resources
G] Alan W.Klimek,P.E.Director
Division of Water Quality
0 Coleen H.Sullins.Deputy Director
Division of Water Quality
August 5, 2005
Mr. J. Bruce Kaylos
Wyeth Holdings Corporation
Five Giralda Farms
Madison, NJ 07940
Subject: No Exposure Certification NCGNE0232
Wyeth Vaccines
4300 Oak Park Drive, Sanford, NC
Lee County
Dear Mr. Kaylos:
The Division has reviewed your submittal of the No-Exposure Certification for Exclusion from NPDES
Stormwater Permitting form, which we received on May 3, 2005. Based on your submittal and signed
certification of no exposure at the above referenced facility, the Division is granting your certification as
provided for under 40 CFR 126.22(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your no exposure certification, you are obligated to maintain no
exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no-
exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater
discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Your
conditional no-exposure exclusion expires in five years (July 31, 2010). At that time you must re-certify with
the Division, or obtain NPDES permit coverage for any stormwater discharges from your facility.
Your certification of no exposure does not affect your facility's legal requirements to obtain environmental
permits that may be required under other federal, state, or local regulations or ordinances.
If you have any questions or need further information, please contact Sarah Young at [phone], ext.
502, or at [e-mail].
Sincerely,
r_y jas,�
for Alan W. Klimek, P.E.
cc: Raleigh Regional Office - Central Files —wlattachments
Stormwater Permitting Unit Files
NCDENR
N.C.Division of Water Qua lily 1617 Mail Service Center Raleigh,North Carolina 27699-1617 [phone] Customer Service
1-877-623-0748

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United States Environmental Protection Agency Form Approved
9 Y OMB No.2040-0211
NODES ®ri�EPA Washington, DC 20460
FORM �' NO EXPOSURE CERTIFICATION for Exclusion from
351 D-11
NPDES Storm Water Permitting
Submission of this No Exposure Certification constitutes notice that the entity identified in Section A does not require permit authorization for its storm water
discharges associated with industrial activity in the State identified in Section B under EPA's Storm Water Multi-Sector General Permit due to the existence
of a condition of no exposure.
A condition of no exposure exists at an industrial facility when all industrial materials and activities are protected by a storm resistant shelter to prevent
exposure to rain, snow,snowmelt,and/or runoff. Industrial materials or activities include,but are not limited to,material handling equipment or activities,
industrial machinery,raw materials,intermediate products,by-products,final products,or waste products. Material handling activities include the storage,
loading and unloading,transportation,or conveyance of any raw material,intermediate product,final product or waste product. A storm resistant shelter is
not required for the following industrial materials and activities:
— drums, barrels,tanks,and similar containers that are tightly sealed,provided those containers are not deteriorated and do not leak. "Sealed"
means banded or otherwise secured and without operational taps or valves;
— adequately maintained vehicles used in material handling;and
— final products,other than products that would be mobilized in storm water discharges(e.g.,rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In addition,the exclusion from NPDES permitting is
available on a facility-wide basis only,not for individual outfalls. If any industrial activities or materials are or will be exposed to precipitation,the facility is
not eligible for the no exposure exclusion.
By signing and submitting this No Exposure Certification form,the entity in Section A is certifying that a condition of no exposure exists at its facility or site,
and is obligated to comply with the terms and conditions of 40 CFR 122.26(g),
ALL INFORMATION MUST BE PROVIDED ON THIS FORM.
Detailed instructions for completing this form and obtaining the no exposure exclusion are provided on pages 3 and 4.
A. Facility Operator Information /n� f}
1. Name: I'J11`i I I�I'I}1 11}101LLD1 i miGISI II.I�IR I�I DiRl l I 101�1 I I 12. Phone: [phone]&I 61CISLDIO>OJ
3, Mailing Address: a.Street: IF111VI+i iGillkIAILIVIAI iFIAIRIM1Sl I I I I I I I I I Ira I I I
b.City: IMI h JDt I I S I O I M I I I I I I I I I I I I I I I I c.Staie: NO—i d.Zip Code: 1 Q 171 9 i L4i 01—1 1 1 I I
B. Facility/Site Location Information A
1.Facility Name: �`iIrE1710 I IVI hi qe_,� I IAVI E4 I I I I I I I I I I I I I I I I I
2.a.Street Address: 1+�1 f6A i0 k I�Ilt AIXI I I I 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
b. City: ISA A Fi QI nIDi 1--I I I I i I I I I I I I I I I c.County: I Li FI EI I I I I 1 I �
d.State: 141 r_I e.Zip Code: I a171313 101—1 -1 L_) Il
3.Is the facility located on Indian Lands? Yes ❑ No 1U
4.is this a Federal facility?� Yes ❑ No ® MAY 0 3 ?nn5
5.a. Latitude: aLs-1 LJL 6A b.Longitude: I L!'.�oj Z5,
6.a.Was the facilityor site previously covered under an NODES storm water permit? Yes No DENR-WATER QUALITY
p y p ❑ WETWVDS AND STORMWATER BRANCH
b. If yes,enter NPDES permit number: _lY L,17_o(Q0hoc)
7.SIC/Activity Codes: Primary: 21 1 14St�] Secondary(it applicable): I I I I
8.Total size of site associated with industrial activity: :z 2 acres
9.a.Have you paved or roofed over a formerly exposed,pervious area in order to quality for the no exposure exclusion? Yes ❑ No
b. If yes,please indicate approximately how much area was paved or roofed over. Completing this question does not disqualify you for the no exposure
exclusion. However,your permitting authority may use this information in considering whether storm water discharges from your site are likely to have
an adverse impact on water quality,in which case you could be required to obtain permit coverage.
Less than one acre One to five acres ❑ More than five acres
EPA Form 3510-11 (10-99) Page 1 of 4

FNPDES
-,EPA NO EXPOSURE CERTIFICATION for Exclusion from OMBFNo 20400211d
NPDES Storm Water Permitting
C. Exposure Checklist
Are any of the following materials or activities exposed to precipitation,now or in the foreseeable future?
(Please check either"Yes"or"No"in the appropriate box.) If you answer"Yes"to any of these questions
(1)through(11),you are not eligible for the no exposure exclusion.
Yes No
1. Using,storing or cleaning industrial machinery or equipment,and areas where residuals from using,storing
or cleaning industrial machinery or equipment remain and are exposed to storm water
2. Materials or residuals on the ground or in storm water inlets from spills/leaks El IN
3. Materials or products from past industrial activity ❑
4. Material handling equipment(except adequately maintained vehicles) Ln
5. Materials or products during loading/unloading or transporting activities
6. Materials or products stored outdoors(except final products intended for outside use[e.g.,new cars]where El M
exposure to storm water does not result in the discharge of pollutants)
7. Materials contained in open,deteriorated or leaking storage drums,barrels,tanks,and similar containers
8. Materials or products handled/stored on roads or railways owned or maintained by the discharger ❑
9. Waste material(except waste in covered,non-leaking containers[e.g.,dumpsters]) �(
10. Application or disposal of process wastewater(unless otherwise permitted)
11. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated
(i.e.,under an air quality control permit)and evident in the storm water outflow
D. Certification Statement
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of"no exposure"and obtaining an
exclusion from NPDES storm water permitting.
I certify under penalty of law that there are no discharges of storm water contaminated by exposure to industrial activities or materials from the industrial
facility or site identified in this document(except as allowed under 40 CFR 122.26(g)(2)).
I understand that 1 am obligated to submit a no exposure certification form once every five years to the NPDES permitting authority and,if requested,to
the operator of the local municipal separate storm sewer system(MS4)into which the facility discharges(where applicable). I understand that I must
allow the!NPDES permitting authority,or MS4 operator where the discharge is into the local MS4,to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request. I understand that I must obtain coverage under an NPDES permit prior
to any point source discharge of storm water from the facility.
Additionally,1 certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a
system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or
persons who manage the system,or those persons directly responsible for gathering the information,the information submitted is to the best of my
knowledge and belief true,accurate and complete. I am aware that there are significant penalties for submitting false information,including the possibility
of fine and imprisonment for knowing violations.
Print Name: k y L
Print Title: IAt?31P+1Ct4-110& I nISI"I Ll-rl t�•I I I I I �I L_ I I I I I I I I Lj
Signature:
Date: i
EPA Form 3510-11 (10-99) Page 2 of 4

NPDES Instructions for the NO EXPOSURE CERTIFICATION for Form Approved
FORM -,EPA OMB No.2040-0211
3510-11 Exclusion from NPDES Storm Water Permitting
Who May File a No Exposure Certification Section B. Facility/Site Location Information
Federal law at 40 CFR Part 122.26 prohibits point source discharges of 1. Enter the official or legal name of the facility or site.
storm water associated with industrial activity to waters of the U.S.without
a National Pollutant Discharge Elimination System(NPDES)permit. However, 2. Enter the complete street address(if no street address exists,provide
NPDES permit coverage is not required for discharges of storm water a geographic description[e.g., Intersection of Routes 9 and 55]),city,
associated with industrial activities identified at 40 CFR 122.26(b)(14)(i)- county,state,and zip code. Do not use a P.O.Box number,
(ix)and(xi)if the discharger can certify that a condition of"no exposure"
exists at the industrial facility or site. 3. Indicate whether the facility is located on Indian Lands.
Storm water discharges from construction activities identified in 40 CFR 4. Indicate whether the industrial facility is operated by a department or
122.26(b)(14)(x)and(b)(15)are not eligible for the no exposure exclusion. agency of the Federal Government(see also Section 313 of the Clean
Water Act).
Obtaining and Maintaining the No Exposure Exclusion
5. Enter the latitude and longitude of the approximate center of the facility
This form is used to certify that a condition of no exposure exists at the or site in degrees/minutes/seconds. Latitude and longitude can
industrial facility or site described herein.This certification is only applicable be obtained from United States Geological Survey(USGS)quadrangle
in jurisdictions where EPA is the NPDES permitting authority and must be or topographic maps, by Calling 1-(888)ASK-USGS,or by accessing
re-submitted at least once every five years. EPA's web site at http://www.epa.gov/owm/sw/industry/index.htm and
selecting Latitude and Longitude Finders under the Resources/Permit
The industrial facility operator must maintain a condition of no exposure at section.
its facility or site in order for the no exposure exclusion to remain applicable.
It conditions Change resulting in the exposure of materials and activities to Latitude and longitude far a facility in decimal form muss be converted
storm water,the facility operator must obtain coverage under an NPDES to degrees (°), minutes ('), and seconds (") for proper entry on
storm water permit immediately. the certification farm. To convert decimal latitude or longitude to
degrees/minutes/seconds,follow the steps in the following example.
Where to File the No Exposure Certification Form Example: Convert decimal latitude 45.1234567 to degrees(1),minutes
Mail the completed no exposure certification form to: ('),and seconds(').
a) The numbers to the left of the decimal point are the degrees: 45°.
Storm Water No Exposure Certification(4203)
USEPA b) To obtain minutes,multiply the first four numbers to the right of the
401 M Street,SW decimal point by 0.006: 1234 x 0.006=7.404.
Washington,D.C. 20460 c) The numbers to the left of the decimal point in the result obtained
in(b)are the minutes: 7'.
Completing the Form
d) To obtain seconds, multiply the remaining three numbers to the
You must type or print,using uppercase letters,in appropriate areas only. right of the decimal from the result obtained in (b) by 0.06:
Enter only one character per space(i.e.,between the marks). Abbreviate 404 x 0.06=24.24. Since the numbers to the right of the decimal
if necessary to stay within the number of characters allowed for each item. point are not used,the result is 24'.
Use one space for breaks between words. One form must be completed
for each facility or site for which you are seeking to certify a condition of no e) The conversion for 45.1234567=45' 7' 24".
exposure. Additional guidance on completing this form can be accessed
through EPA's web site at www.epa.gov/ownVsw. Please make sure you 6. Indicate whether the facility was previously covered under an NPDES
have addressed all applicable questions and have made a photocopy for storm water permit. If so,include the permit number.
your records before sending the completed form to the above address.
7. Enter the 4-digit SIC code which identifies the facility's primary activity,
and second 4-digit SIC code identifying the facility's secondary activity,
Section A. Facility Operator Information if applicable. SIC codes can be obtained from the Standard Industrial
Classification Manual,1987.
1. Provide the legal name of the person,firm,public organization,or any
other entity that operates the facility or site described in this certification. 8_ Enter the total size of the site associated with industrial activity in acres.
The name of the operator may or may not be the same as the name of Acreage may be determined by dividing square footage by 43,560,as
the facility. The operator is the legal entity that controls the facility's demonstrated in the following example.
operation,rather than the plant or site manager.
2. Provide the telephone number of the facility operator. Example: Convert 54,450 ft2 to acres
Divide 54,450 ft2 by 43,560 square feet per acre:
3. Provide the mailing address of the operator(P.O.Box numbers may be 54,450 ft2=43,560 ft2/acre=1.25 acres.
used). Include the city, state, and zip code. All correspondence will
be sent to this address. 9. Check"Yes"or"No"as appropriate to indicate whether you have paved
or roofed over a formerly exposed,pervious area(i.e.,lawn,meadow,
dirt or gravel road/parking lot)in order to qualify for no exposure. If yes,
also indicate approximately how much area was paved or roofed over
and is now impervious area.
EPA Form 3510-11 (10-99) Page 3 of 4

NPDES Instructions for the NO EXPOSURE CERTIFICATION for Form Approved
FORM -,EPA OMB No.2040 021 i
3510-11 Exclusion from NPDES Storm Water Permitting
Section C. Exposure Checklist authority to sign documents has been assigned or delegated to
the manager in accordance with corporate procedures;
Check"Yes"or"No"as appropriate 10 describe the exposure conditions at
your facility. If you answer"Yes"to ANY of the questions(1)through(11) For a partnership or sole proprietorship: by a general partner or the
in this section,a potential for exposure exists at your site and you cannot proprietor;or
certify to a condition of no exposure. You must obtain (or already have)
coverage under an NPDES storm water permit. After obtaining permit For a municipal, State, Federal, or other public facility: by either a
coverage, you can institute modifications to eliminate the potential for a principal executive or ranking elected official.
discharge of storm water exposed to industrial activity,and then certify to
a condition of no exposure. Paperwork Reduction Act Notice
Section D. Certification Statement Public reporting burden for this certification is estimated to average 1.0 hour
per certification,including time for reviewing instructions,searching existing
Federal statutes provide for severe penalties for submitting false information data sources,gathering and maintaining the data needed,and completing
on this application form. Federal regulations require this application to be and reviewing the collection of information. Burden means the total time,
signed as follows: effort,or financial resources expended by persons to generate,maintain,
retain,or disclose to provide information to or for a Federal agency. This
For a corporation: by a responsible corporate officer,which means: includes the time needed to review instructions;develop,acquire, install,
and utilize technology and systems for the purposes of collecting,validating,
(i) president,secretary,treasurer,or vice-president of the corporation and verifying information, processing and maintaining information, and
in charge of a principal business function,or any other person disclosing and providing information;adjust the existing ways to comply with
who performs similar policy or decision making functions for the any previously applicable instructions and requirements;train personnel to
corporation,or be able to respond to a collection of information;search data sources;
complete and review the collection of information;and transmit or otherwise
(ii) the manager of one or more manufacturing, production, or disclose the information. An agency may not conduct or sponsor,and a
operating facilities,provided the manager is authorized to make person is not required to respond to,a collection of information unless it
management decisions which govern the operation of the displays a currently valid OMB control number. Send comments regarding
regulated facility including having the explicit or implicit duty of the burden estimate,any other aspect of the collection of information,or
making major capital investment recommendations,and initiating suggestions for improving this form,including any suggestions which may
and directing other comprehensive measures to assure long increase or reduce this burden to: Director,OPPE Regulatory Information
term environmental compliance with environmental laws and Division (2137), USEPA, 401 M Street, SW, Washington, D.C. 20460.
regulations; the manager can ensure that the necessary systems Include the OMB control number of this form on any correspondence. Do
are established or actions taken to gather complete and accurate not send the completed No Exposure Certification form to this address.
information for permit application requirements; and where
EPA Form 3510-11 (10-99) Page 4 of 4

Wyeth Vaccines
4300.Oak Park J.Kenneth Taft
Sanford,NC 27330 Environmental Manager
Tel [phone] x-6408
Wyeth [e-mail]
April 25, 2005
Bradley Bennett
Supervisor, Stormwater and General Permits Unit
NCDENR Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699 - 1617
Category 11 Exemption For; Wyeth Vaccines
4300 Oak Park
Sanford, NC 27330
Dear Mr. Bennett:
To maintain compliance with the 1999 EPA regulations, the NPDES Form 3510-11 (NO
EXPOSURE CERTIFICATION) has been completed and enclosed with this letter.
Please note that operations have indeed ceased at the previously permitted facility at
4305 Oak Park (Wyeth-Ayerst Lab #NCG060253). That facility has been demolished
and removed from site, so this no exposure request applies for the entire property
(226 +/- acre parcel of USCS, Colon, NC Quadrangle).
Thank-you for adding this update to our Category 11 permit exemption file. Please
contact me if there are questions regarding this record, or if there is any additional
information required.
Sincerely,
I Kenneth Taft
Environmental Manager
0 k�9
MAY 4
DENR-WATER QUAtITy
T1 M65 AND STOftAfyyqi�R BRANCH

No-Exposure Stormwater Certification-Wyeth Vaccines
Subject: No-Exposure Stormwater Certification - Wyeth Vaccines
From: Mike Dare <[e-mail]>
Date: Wed, 29 Jun 2005 11:19:18 -0400
To: [e-mail], Ken Schuster<[e-mail]>
June 29, 2005
Ms. Sarah Young
Subject: No Exposure Certification Request
Wyeth Vaccines
GNE0232
Lee y
Dear Ms. Young,
This writer, of the RRO Surface Water Protection Section, conducted an inspection, on
June 28, 2005, of the Wyeth Vaccines Facility for evaluation of the request for
No-Exposure Certification. Mr. Kenneth Taft (Environmental Manager) and Sean
Rasmussen represented this vaccine production facility during the inspection. The
grounds exterior to material storage, production and mechanical facilities were
evaluated. (On-going construction activities, regulated by the Land Quality Section,
were not included in this inspection. ) Findings during the inspection are as
follows:
There was no evidence of spills, overflows or similar incidents.
Ail chemical and fuel storage tanks have secondary containment. There was no
evidence of leakage from exterior chemical and fuel piping.
Hazardous wastes are stored in buildings with sub-base secondary containment.
Cafeteria waste fags and oils are stored in a double containment tank until picked
up.
8-c facility refuse dumpsters are all in good rating lids.
it is the opinion of this writer that the requested No-Exposure Stormwater
Certification should be granted to Wyeth Vaccines.
Please call (571-4700 ext. 273) if there are questions. J
Thank you,
Mike Dare
Environmental Technician
1 of 1 6/29/2005 11:34 AM

Division of Water Quality/ Surface Water Protection
National Pollutant Discharge Elimination System
NCDEI��'�NR ANNUAL NO EXPOSURE EXCLUSION SELF RE-CERTIFICATION
tkm-C tp QgiaRT w D,
NUU R� NCGNE0000
Do not submit this form to DWQ unless requested.
For questions, please contact the DWQ Regional Office for your area or the Central Office.
(Please print or type)
Facility's No Exposure Exclusion No. Date Completed (MM/DD/YYYY)
N C G N 1~ 1 / 1 1 /
1) Has the facility name or owner changed? ❑ Yes ❑ No
(if yes, please submit a separate Name/Ownership Change Form to DWQ located at
http://portal.ncdenr.org/web/wq/ws/su/npdessw#Application_Forms_NPDES)
2) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either"Yes" or"No.") If you answer"Yes" to any of these items,you are not
eligible to maintain your no exposure exclusion, and must immediately apply for a permit from DWQ.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes [:] No
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes [—] No
c. Materials or products from past industrial activity ❑ Yes ❑ No
d. Material handling equipment (except adequately maintained vehicles) ❑ Yes ❑ No
e. Materials or products during loading/unloading or transporting activities ❑ Yes ❑ No
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes ❑ No
use [e.g., new cars]where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes ❑ No
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes ❑ No
the discharger
L Waste material (except waste in covered, non-leaking containers [e.g., dumpsters]) ❑ Yes ❑ No
j. Application or disposal of process wastewater(unless otherwise permitted) ❑ Yes ❑ No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes ❑ No
otherwise regulated (i.e., under an air quality control permit)and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes [:] No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
Page 1 of 3
SWU-NESR-29Ju1201 0

' Irk
NCGNE0000 No Exposure Self Re-Certification
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes ❑ No
stored outside, has the facility had any releases in the past three(3)years?
3) Above Ground Storage Tanks (ASTs): if you answer"No"to any of the following items, you are not
eligible to maintain your no exposure exclusion, and must immediately apply for a permit from DWQ.
a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or [:]Yes[] No ❑ NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑Yes❑ No ❑ NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
4) Secondary Containment: If you answer"No"to any of the following items,you are not eligible to
maintain your no exposure exclusion, and must immediately apply for a permit from DWQ.
a. is secondary containment provided for all single above ground storage ❑Yes❑ No ❑ NIA
containers (including drums, barrels, etc.)with a capacity of more than 660-
gallons?
b. Is secondary containment provided for above ground storage containers stored ❑Yes❑ No ❑ NIA
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund ❑Yes❑ No ❑ NIA
Amendments and Reauthorization Act (SARA)water priority chemicals"?
d. Is secondary containment provided for hazardous substances**designated in 40 ❑Yes❑ No ❑ NIA
CFR§116?
e. Are release valves on all secondary containment structures locked? ❑Yes❑ No ❑ NIA
Footnotes to Questions 4)c.&d.
'Note that amounts below the 660-gallon(single)and 1,320-gallon(combined)bulk storage minimums require secondary containment.
However,some exceptions may be made for de minimis amounts of certain substances,and/or other qualifiers,as described in the
exemptions from reporting requirements of Title III SARA 313 in 40 CFR§372.38.
"Note that amounts below the 660-gallon(single)and 1,320-gallon(combined)bulk storage minimums require secondary containment.
However,some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR
§117.3.
5) Other information: If you answer"Yes"to any of the following items, and the answer if different from
how it was answered when originally applying, you might not be eligible to maintain your no exposure
exclusion. Please contact the Division if this is the case.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes ❑ No
b. Does your facility have coal piles on site? ❑ Yes ❑ No
c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes ❑No
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity(e.g., [] Yes [] No
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? ❑Yes❑ No❑NIA
Please specify:
Page 2 of 3
SW U-NESR-29Ju12010

NCGNEOOOO No Exposure Self Re-Certification
6) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of"no
exposure"and obtaining/maintaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document(except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to annually self re-certify No Exposure and, if requested, submit this re-certification to
DWQ or the operator of the local municipal separate storm sewer system(MS4)into which the facility discharges(where
applicable). I understand that I must allow the North Carolina Division of Water Quality,or MS4 operator where the
discharge is into the local MS4,to perform inspections to confirm the condition of no exposure and to make such
inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information provided. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information,the information provided is to the best of my knowledge and belief true,accurate and complete. I am aware
that there are significant penalties for providing false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this document and that to the best of my knowledge and belief
such information is true,complete,and accurate.
Printed Name of Person Signing:
Title:
(Signature) (Date Signed)
Please note: The Regional Office may inspect your facility at any time in the future for
compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement,representation,or certification in any application,record,report, plan,or other
document filed or required to be maintained under this Article or a rule implementing this Article;or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article;or who falsifies,tampers with,or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management]Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars($10,000).
This completed form must be kept on file at the facility for at least 5 years. Do not submit this
form to DWQ unless requested.
Page 3 of 3
SWU-NESR-2gJul2010

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