NCG210444_COMPLETE FILE - HISTORICAL_20160610

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/v C� a � U7'"I7
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ j 0) (.0 O Ic I O
YYYYMMDD

y PAT MCCRORY
Gorernur
DONALD R. VAN DER VAAR1'
r Secrelmy
Energy, Mineral �g �
and Land Resources RECOVEDP V I S
ENVIRONMENTAL QUALIFY June 10, 2016
JUN 14 2016 Director
Ms. Lynn A. Bottone
Wyeth, LLC CENTRAL FILES
4300 Oak Park Road DWR SECTION
Sanford, NC 27330
Subject: General Permit No. NCG210000
Wyeth, LLC — Sanford Plant
COC No. NCG210444
Rescission of NCGNE0232
Lee County
Dear Ms. Bottone:
In accordance with your application for a discharge permit received on May 9, 2016, we are
forwarding herewith the subject certificate of coverage (COC) to discharge under the subject state —
NPDES general permit. This permit is issued pursuant to the requirements of North Carolina General
Statute 143-215.1 and the Memorandum of Agreement between North Carolina and the US
Environmental Protection Agency dated October 15, 2007 (or as subsequently amended). In
conjunction, the No Exposure Certification No. NCGNE0232 for this facility is hereby rescinded.
The company also requested that stormwater discharge outfall 005 be granted representative
outfall status (ROS) because it discharges stormwater from the area where woodchips are stored at
this facility. The Division hereby approves your request based on the circumstances of exposure at
this site and the information provided during and after our site visit on July 22, 2015, In accordance
with 40 CFR § 122.21(g)(7), you are authorized to sample outfall 005 as a representative outfall. This
approval is effective with the initial sampling event under this permit. However, the permit still
requires Qualitative Monitoring be performed at all SDOs, regardless of representative status.
Please append this letter to your Stormwater Pollution Prevention Plan (SPPP) or permit to document
that ROS has been approved. If changes in drainage areas, structures, processes, storage practices, or
other activities occur that significantly alter the basis of this approval, ROS may no longer be valid.
You would either resume sampling all SDOs, or reapply to this office for representative outfall status
based on updated information.
Please take notice that this certificate of coverage is not transferable except upon approval of the
Division of Energy, Mineral and Land Resources. The Division of Energy, Mineral and Land
Resources may require modification or revocation and reissuancc of the certificate of coverage.
Seale of North Carolina I Environmental Quality I Energy, Mincnl and [and Rcsources
1612 Mail Service Center 1 512 N. Salisbury St. I Raleigh, NC 27699
919 707 9200 T

This permit does not affect the legal requirements to obtain other permits which may be required by
the Division of Energy, Mineral and Land Resources, the Coastal Area Management Act, or any other
federal or local government permit that may be required.
If you have any questions concerning this permit, please contact Bethany Georgoulias at telephone
number [phone] or by email bet hany`geor og uIias a,ncdenr.gov.
Sincerely,
" � /' j d" ?" � ,
for Tracy E. Davis, P.E., CPM, Director
Division of Energy, Mineral and Land Resources
cc: Charles E Powell, Jr., Sr. EHS Specialist/Wyeth, LLC via e-mail
Raleigh Regional Office, John Holley
Central Files
Stormwater Program Files
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

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF ENERGY, MINERAL AND LAND RESOURCES
GENERAL PERMIT NO. NCG210000
CERTIFICATE OF COVERAGE No. NCG210444
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Wyeth, LLC
is hereby authorized to discharge stormwater from a facility located at
Wyeth, LLC
4300 Oak Park Road
Sanford
Lee County
to receiving waters designated as Little Buffalo Creek, a class C water in the Cape Fear River
Basin, in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts I,11, III, and IV of General Permit No. NCG210000 as attached.
This certificate of coverage shall become effective June 10, 2016.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day June 10, 2016.
pl!
for Tracy E. Davis, P.E., CPM
Director, Division of Energy, Mineral and Land Resources
By the Authority of the Environmental Management Commission

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Map Scale 1. 24, 000
Wyeth, LLC
Wyeth, LLC - Sanford Facility
Latitude: 350 32' 29" N
Longitude: 790 10'36" W
GDunty: Lee
Receiving Stream: Little Buffalo Creek
Stream (lass: C
Sub -basin: 03-06-11 (Cape Fear River Basin)
Facility Location

NCG210000 N.O.I.
15) Does this facility have exposed accumulations of sawdust, bark, mulch, wood chips, or similar size
woody material on -site for longer than seven (7) days? (Exposed directly to rainfall or to run-on from
other areas of the facility.)
❑ No 0 Yes
16) Are vehicle maintenance activities occurring at this facility?
0 No ❑ Yes
17) Hazardous Waste:
a) Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
0 No ❑ Yes
b) Is this facility a Small Quantity Generator (less than 1000 kg, of hazardous waste generated per month)
of hazardous waste?
0 No ❑ Yes
c) Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste generated per month) of
hazardous waste?
❑ No 0 Yes
d) If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste: D001, D002, D003, D005, D008, D009 D011, D022, D035, F002, F003, F005. P030.
P069, P098, P105, 0002, 0003, U108, U123, U135, U144, U154, U197,_U201. U220, U404
How is material stored: Hazardous wastes are stored inside locked for 90 days or less
Where is material stored: Hazardous wastes are stored inside
How many disposal shipments per year: Approximately 10
Name of transport 1 disposal vendor: Veolia Environmental Services
Vendor address: 2176 Will Suitt Road, Creedmoor, NC 27522
18) Certification:
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).
I hereby request coverage under the referenced General Permit. I understand that coverage under this
permit will constitute the permit requirements for the discharge(s) and is enforceable in the same manner as
an individual permit.
certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing: _Lynn A. Bottone _
Title: Site Leader
Page 3 of 4
SWU-236-080113 Last revised 712114

NCG210000 N.O.k. j
Axm
(Signature ofApplica t) (Datb Signed)
Notice of Intent must be accompanied by a check or money order for $100.00 made payable to:
NCDENR
Final Checklist
This application will be returned as incomplete unless all of the following items have been included:
9 Check for $100 made payable to NC DENR
This completed application and all supporting documents
0 Copy of county map or USGS quad sheet with location of facility clearly marked on map
Mail the entire package to:
Stormwater Permitting Program
Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of an NPDES permit.
For questions, please contact the DEMLR Central Office or Regional Office for your area.
To visit our website, go to http✓/aortal.ncdenr.ora/web/!r/stormwater
DEMLR Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........
[phone]
Page 4 of 4
SWU-236-080113 Last revised 712114

Charles E. Powell, Jr.
Sr. EHS Specialist I
Pfizer PGS
Sanford
4300 Oak Park
Sanford, NC 27330
Via FedEx; Return Receipt Requested
May 6, 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: Stormwater Permit Application
Wyeth, LLC; Sanford, Lee County, North Carolina
Dear Ms. Georgoulias:
In follow up to our May 5, 2016 telephone conversation, Wyeth, LLC (Wyeth) is submitting the attached
National Pollutant Discharge Elimination System (NPDES) Notice of intent (NO[) for coverage under
General Permit NCG210000 (Lumber and Wood Products) due to our need for intermittent storage of
exposed woodchip associated with our biomass boiler operation.
In addition to the NOI, Wyeth is also submitting the attached NPDES Representative Outfall Status (ROS)
Request Form pertaining to Outfall 005 that discharges stormwater from the area where woodchips are
periodically stored. Wyeth understands that if Representative Outfall Status is granted for Outfall 005, the
remaining site outfalls would be subject only to Qualitative Monitoring Requirements.
Until a Certificate of Coverage (COC) is issued, Wyeth will continue quarterly monitoring for Chemical
Oxygen Demand (COD) and Total Suspended Solids (TSS) at the discharge draining from the chip storage
area, as stipulated in your December 21, 2015 letter. -
We appreciate the assistance from the Division relative to this NOI and ROS request. If you should have
any questions regarding this submittal, please contact me at (919) 566-401$.
Best Regards,
harles E. Powdil, Jr., RE1JE
Sr. EFIS Specialist I

NCDENR
ErmMOH.s — Nu NCIaACLS
NOTICE OF INTENT
Division of Energy, Mineral and Land Resources
Stormwater Permitting Program
National Pollutant Discharge Elimination System
NCG210000 4 IL'0
FOR AGENCY USF. ONLY
Date Received
Ycar
Month
Dav
Certificate of Cove
NOqU I
i ck fi oun
pennil Assi ed to
Qk I I it .3
National Pollutant Discharge Elimination System application for coverage under General Permit
NCG210000:
For STORMWATER DISCHARGES associated with activities classified as:
L~
},, r u"kw
'Iv 2�'r�J?a 2
Oct `+C�
SIC' 24 Timber Products (except as specified below), including Wood Chip Mills;
And, Like activities deemed by DEMLR to be similar in the process and/or the exposure of raw
materials, products, by-products, or waste materials.
The following activities are specifically excluded from coverage under this General Permit:
Wood Kitchen Cabinets (SIC 2434)
Wood Preserving (SIC 2491)
Logging (SIC 2411)
. Standard Industrial Classification Code
(Please print or type)
1) Mailing address of owner/operator (address to which official permit correspondence will be mailed):
Name Wyeth, LLC
Owner Contact (a person) Charles E Powell Jr, Sr EHS Specialist
Street Address 4300 Oak Park Road
City Sanford State NC ZIP Code 27330
Telephone No. 919-566-4018 Fax: [phone]
E-mail Address Charles. owell fizer.com
2) Location of facility producing discharge:
Facility Name Wyeth, LLC
Facility Contact (a person) Charles E Powell Jr. Sr EHS Specialist
Contact E-mail Charles. powell(EDpfizer.com
Street Address 4300 Oak Park Road
City Sanford State NC ZIP Code 27330
County Lee
Telephone No. 919-566-4018 Fax: [phone]
3) Permit Contact
Permit Contact (a person) Charles E Powell Jr, Sr EHS Specialist I
Contact E-mail Char les.powelleofizer.com
Contact phone number 919-566-4018
4) Physical Location Information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). From US 1_South, turn right onto NC-87 N/US-15 N/US
501 N. In approximately 0.7 miles turn right onto Oak Park Road.
(A copy of a county map or USGS quad sheet with facility clearly located on the map is required to be submitted with this application)
Page 1 of 4
SWU-236-080113 Last revised 712114

NCG210000 N.O.I. 3 5-
5) Latitude 351, 32'. 29" Longitude -79", 10'. 36" (degrees, minutes, seconds)
6) This NPDES Permit Application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
0 Existing
7) Standard Industrial Classification (SIC):
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2836
8) Provide a brief narrative description of the types of industrial activities and products manufactured at
this facility: The facility manufactures intermediates and active drug substances used to produce vaccines
which prevent disease.
9) Discharge points I Receiving waters:
How many discharge points (ditches, pipes, channels, etc.) convey stormwater from the property? 12
10) Receiving waters:
What is the name of the body or bodies of water (creek, stream, river, lake, etc.) that the facility stormwater
discharges end up in? Little Buffalo Creek and unnamed tributaries to Little Buffalo Creek
If the site stormwater discharges to a separate storm sewer system, name the operator of the separate storm
sewer system (e.g. City of Raleigh municipal storm sewer). NIA
11) Does this facility have any other water quality permits?
❑ No
Yes
If yes, list the permit numbers for all current water quality permits for this facility: IUP #000022, NCG551038 _
12) Does this facility have any Non -Discharge permits (ex: recycle permits)?
x❑ No
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
13) Does this facility employ any best management practices for stormwater control?
❑ No
19 Yes
If yes, please briefly describe: Secondary containment is provided for above Around storage containers
release valves for all secondary containment remain locked. In addition, good housekeeping measures are
employed to minimize exposure during periodic storage of wood chips_
14) Does this facility have a Stormwater Pollution Prevention Plan?
19 No
❑ Yes
If yes, when was it implemented?
Page 2 of 4
SWU-236-080113 Last revised 712114

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Note- Outfall 005 is the only outfall �' ✓
that discharges stormwater
from an area with exposed 2 :=
i activity,
industrial a rty, and the only area
that is characteristic of the activities ,..
ce�Esri, Di
under NCG210000. J DA, u5cs t
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° Outfall Drainage Area 0 150 30EEEEEEEzzzz=IFeet Dewberry
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A
ACDENR
Nptm, (awOuru ov�r.cNT OF
EM'MKr+MFI+r u,o NaVRLL �S�CES
Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
REPRESENTATIVE OUTFALL STATUS (ROS)
REQUEST FORM
FOR AGFNCY USE ONLY
Date Received
Year
Month
Da
If a facility is required to sample multiple discharge locations with very similar stormwa ter discharges, the
permittee may petition the Director for Representative Outfoll Status (ROS). DWQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DWQ
approval. The approval letter from DWQ must be kept on site with the facility's Stormwater Pollution
Prevention Plan. The facility must notify DWQ in writing if any changes affect representative status.
For questions, please contact the DWQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
N I C I S N C I G 1 2 1 1
2) Facility Information:
Owner/Facility Name Wyeth, LLC
Facility Contact Charles E Powell Jr, Sr EHS Specialist I
Street Address 4300 Oak Park Road
City Sanford State NC ZIP Code 27330
County Lee E-mail Address [e-mail]_
Telephone No. 919-566-4018 Fax: [phone]
3) List the representative outfall(s) information (attach additional sheets if necessary):
Outfall(s) 005 is representative of Outfall(s) 001, 004, 006, 007, 008, 009, 011, 012
Outfalls' drainage areas have the same or similar activities?
9 Yes
❑ No
Outfalls' drainage areas contain the same or similar materials?
❑x Yes
❑ No
Outfalls have similar monitoring results?
❑ Yes
❑ No ❑9 No data*
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
❑ Yes
❑ No
Outfalls' drainage areas contain the same or similar materials?
❑ Yes
❑ No
Outfalls have similar monitoring results?
❑ Yes
❑ No ❑ No data*
Outfall(s) is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
❑ Yes
❑ No
Outfalls' drainage areas contain the same or similar materials?
❑ Yes
❑ No
Outfalls have similar monitoring results?
❑ Yes
❑ No ❑ No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
Page 1 of 4
SWU-ROS-2009 Last revised 1213012OG9

1 •1
Representative Outfall Status Request
circumstances will be considered by the Regional Office responsible for review.
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or
materials are similar.
Wyeth LLC is requesting_ Representative Outfall Status for Outfall 005 that discharges stormwater from the
area where woodchips_are periodically stored. As discussed during our March 1, 2016 telephone
conversation with Bethany Georgoulias, Environmental Engineer with DEQ-DEMLR, and in keeping with the
DEQ-DEMLR letter to Wyeth, LLC, dated February 23, 2016, the wood chip area is the only exposed industrial
activity at the site, and the only one that is characteristic of activities under General Permit NCG210000
(Lumber and Wood Products). Wyeth understands that if Representative Outfall Status is granted for Outfall
005, the remaining site outfalls associated with industrial activity would be subject only to Qualitative
Monitoring Requirements.
5) Certification:
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).
1 hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DWQ in writing if any changes to the facility or its operations take
place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must resume
monitoring of all outfalls as specified in my NPDES permit.
I certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing: Lynn A. Bottone
Title: Site Leader
+ r
(Signature of App icont) (Date Signe )
Please note: This application for Representative Outfall Status is subject to approval by the
NCDENR Regional Office. The Regional Office may inspect your facility for compliance with the
conditions of the permit prior to that approval.
Final Checklist for ROS Request
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
Page 2 of 4
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
❑ Any other supporting documentation.
Mail the entire package to:
NC DENR Division of Water Quality
Surface Water Protection Section
at the appropriate Regional Office (See map and addresses below)
Notes
The submission of this document does not guarantee Representative Outfall Status (ROS) will be granted as
requested. Analytical monitoring as per your current permit must be continued, at all outfalls, until written
approval of this request is granted by DWQ. Non-compliance with analytical monitoring prior to this request
may prevent ROS approval. Specific circumstances will be considered by the Regional Office responsible for
review.
For questions, please contact the DWQ Regional Office for your area.
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778
Phone [phone]
FAX [phone]
Fayetteville Regional Office
Systel Building,
225 Green St., Suite 714
Fayetteville, NC 28301-5094
Phone [phone]
FAX [phone]
Mooresville Regional Office
610 East Center Ave.
Mooresville, NC 28115
Phone [phone]
FAX [phone]
Raleigh Regional Office
1628 Mail Service Center
Raleigh, NC 27699-1628
FAX [phone]
Washington Regional Office
943 Washington Square Mall
Washington, NC 27889
Phone [phone]
FAX [phone]
Wilmington Regional Office
127 Cardinal Drive Extension
Wilmington, NC 28405
Phone [phone]
FAX [phone]
Winston-Salem Regional Office
585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone]
Water Quality Main FAX [phone]
Page 3 of 4
SWU-ROS-2009 Last revised 12/30/2009

J
Representative Outfall Status Request
Central Office Phone [phone]
1617 Mail Service Center FAX [phone]
Raleigh, NC 27699-1617
Page 4 of 4
SWLJ-ROS-2009 Last revised 12/30/2009

Energy, Mineral
and Land Resources
ENVIRONMENTAL OUALITV
February 23, 2016
Charles E. Powell, Jr.
Sr. EHS Specialist
Pfizer PGS — Wyeth, LLC Sanford
4300 Oak Park
Sanford, NC 27330
PAT MCCRORY
Goremor
DONALD R. VAN DER VAART
Sccrelm y
TRACY DAVIS
Viremor
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.
6A0
o c fat
Swe of Nonh 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
Y'.°C�c t":�r.�. ��';�` ,S�r --� ...4� �, ''3• tip,- ^ C1M 'r

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 [phone] or at [e-mail].
Sincerely,
U �
Bethany A. 6eorgoulias,
Environmental Engineer
DEMLR Stormwater Permitting Program
cc: Stormwater Permitting Program Permit File
Raleigh Regional 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 Center 1 512 N. Salisbury St. I Raleigh. NC 27699
919 707 9200 T

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Energy. Mineral
and Land Resources
ENVIRONMENTAL pUALITV
February 23, 2016
Charles E. Powell, Jr.
Sr. EHS Specialist
Pfizer PGS — Wyeth, LLC Sanford
4300 Oak Park
Sanford, NC 27330
PA1' MCCRORY
corernor
DONALD R. VAN DER VAART
secretan,
TRACY DAVIS
Director
cap 0'r
C�r1��s�rn�
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 NO[ 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 band Resources
1612 Mail Service Center t 512 N. Salisbury St. t Raleigh, NC 27699
9 t 9 707 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 NO] application, or representative
outfall status (ROS), please contact me at [phone] or at bethany.georgoulias i ncdenr.gov.
Sincerely,
Original sighed by Belllrnty Gerugoidias
Bethany A. Georgoulias,
Environmental Engineer
DEMLR Stormwater Permitting Program
cc: Stormwater Permitting Program Permit File
Raleigh Regional Office / John Holley, DEMLR Regional Engineer
Central Files
enclosure
Slate of North Carolina I Fnviron[nental Quality i Energy, Mineral and land Resources
1612 Mail Service Center 1 512 N, Salisbury St. J Raleigh, NC 27699
919 707 9200 T

Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Monday, February 22, 2016 10:14 AM
To: 'Powell, Charles'
Subject: RE: Letter
Hi Chuck,
I received your letter today. We will respond with a letter advising you of your next steps. We agree that NCG21 GP
coverage in this case will be the most appropriate.
By the way, take a look at the NCG21 permit on our website (that's all changed recently, so here's a direct
link: https.//ncdenr.s3.amazonaws.com/s3fs-
public/Energy%20Minera 1%20a nd%20La nd%20Resources/Stormwater/N PDE5%20General%2OPermits/NCG21-Permit-
20130731-DEMLR-SW.pdf)
You'll see the language I was referring to last week in Part 11, Section B. Analytical Monitoring is required only when piles
of wood chips are stored for seven days or longer.
We will follow up soon.
Best regards,
Bethany
Bethany Georgoulias
Environmental Engineer
Stonnwater Permitting Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 807 6372 office
bethany_geor oug liasP,,nedenr._og_v
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
512 N. Salisbury Street, Raleigh, NC 27604 (location)
Website: http://portal.ncdenr.org/web/Ir/stormwater
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:[e-mail]]
Sent: Friday, February 19, 2016 12:56 PM
To: Georgoulias, Bethany<[e-mail]>
Subject: Letter

Hello Bethany
I put the letter we discussed on the telephone yesterday regarding our capital project status update, in our Fed Ex box
today. You should receive it on Monday. Thanks for your assistance and have a great weekend.
Regards,
Chuck Powell
Chuck 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(cbPfizer.com

Charles E. Powell. Jr.
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 Energy, 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 Boiier 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.[phone].
Best Regards
Charles'E. Powell. Jr., RE
Sr. EHS Specialist I

Energy. Mineral
and Land Resources
ENVIRONMENTAL QUALITY
December 21, 2015
Charles E. Powell, Jr.
Sr. EHS Specialist
Pfizer PGS — Wyeth, LLC Sanford
4300 Oak Park
Sanford, NC 27330
PAT MCCRORY
Govemor
DONALD R. VAN DER VAART
secremol,
TRACY DAVIS
Director
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 of North Carolina I Environmental Quality I Energy, Mineral and land Resources
1612 Mail Service Center 1 5 t 2 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 [phone] or at
bethan .�reor roulias ncdenr. ov.
Sincerely,
Original sighed by Belhaiiy Gerogotdiets
Bethany A. Georgoulias,
Environmental Engineer
DEMLR Stormwater Permitting Program
cc: Stormwater Permitting Program Permit File
Raleigh Regional Office / John Holly, DEMLR Regional Engineer
Central Files
enclosure
Slate of North Carolina I Environmental Quality j Enero, Mineral and Land Resources
1612 Mail Service Center [ 512 N. Salishury St. I Raleigk NC 27699
919 707 9200 T

r
Fze]r
Via FedEx• ReWrn Receipt Recluested
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:
Charles E. Powell, Jr.
Sr. EHS Specialist 1
Pfizer PGS
Sanford
4300 Oak Park
Sanford, NC 27330,
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 managemenrthe 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 willmensure 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.
WI .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) 566-401 S.
Best Regards,
�Larleb. Powell. Jr., REII
Sr. EHS Specialist I

�$ 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 ► ith the standard document requirements for
each document: Font type is Times Ne1U Roman: font size is 12 points. spacing should be
1.3, margins must be I inch on all sides, and page number must be listed on each page
and right -aligned. Refer to JAGPM4205-01 far 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, JASPM1100-11., Figure 7 Drawing
Documents
Q• WARNING: 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.
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 itmay be impossible to receive chips into the.reclaimer. In those cases
l(
this procedure begins at section 4.
Page 1 of 7

Actions:
Do this:
Pictures & Illustrations
Section 1.0:
1.1 Receive notification from Security truck has arrived
1 ❑ Doors & sa__fery chain
1.2 Open doors at reclaimer IEl
Receivin g
Preparation
1.3 Remove safety chain at reclaimer I ❑
1.4 Back truck up against reclaimer 20
1.5 Chock truck wheels 3❑
.i !�'`€
r ,
NOTE: Truck wheels must remained chocked when unloading into
4'J
reclaimer
1.6 Open truck doors
- T
1.7 Close doors on reclaimer against side of trailer-
20 Truck against reclaimer
r l r!
Fioel
y
•41jli 1
Section 2:0:
2.1 Instruct1driver to start trailer conveyer
30 Chocked truck wheel
Unload Trailer
2.2 When chips start moving, push reclaimer start button 40
2.3 Go inside to Wellons control system, set fuel speed.
into Reclairner
NOTE: Fuel speed is dependent on chip quality
2.4 Monitor unload'progress from top of reclaimer & adjust fuel
-
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
j `^
NOTE: Check for oil leaks,under truck. NotiA, truck driver &
place oil catch pan under leak."
40 Reclaimer start
tEk- 11W K'
50 View from top of
Reclaimer
r ,: • .« -
Ir n
Page 2 of 7

Section 3.0:
3.1 Open doors on reclaimer
60 Spilled material'after
Completing
Delivery into
3.2 Remove wheel chocks
3.3 Instruct driver to move forward approximately 8'
3.4 Brush off residual chips, debris from rear of trailer 611ffii,�r:
unloading
F
Reclaimer
3:5 Close trailer doors
3.6 Receive drivers paperwork#=1.;'
,ram
3.7 instruct driver to leave site
3.8 Clean chip residuals -off of concrete & place in reclaimer
�;'µfr
}[;;;fLv►S;
Section 4.0:
4.1 lnstruct driver to move to designated temporary storage location
70 Designated temporary
Unloading
4.2 When driver is in position, stand on drivers side of trailer
storage area
Partial or Full
maintaining visual contact with driver in mirror
4.3 Instructdriver to start trailer conveyer
Load in
4.4 Instruct driver to pull forward approximately 5' when chip pile
�-
Temporary
reaches back of trailer
Storage
4.5 Repeat step 4.4 until contents of trailer, are on ground 70
Section 5.0:
5.1 Instruct driver to move forward approximately 8'
80 Picture of tractor sweeper
Completing
5.2 Brush off residual chips, debris from rear of trailer
-----
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 813
Section 6.0:
6.1 Place straw bales around chip pile as shown in the picture 70
Securing Chip
6.2.Use tractor sweeper to actively sweep up -any stray chip & any
other fines on pavement area 80
Pile in
Temporary
Storage
Section 7.0-
7 1 Conduct daily inspection of temporary storage area
.9❑ Picture of flow path
Managing
7.2 Lou. status of temporary storage area
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
_ l;
Temporary
area for four consecutive days
y
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 shutc1ms-n of
1013 Fuel Silo
Managing Chip
biomass boiler-r-
3.2 For shutdowns of < 30 days silo may remain filled with chips
Deliveries
8.3 For semiannual shutdowns of > 30 days chips will be
Duringconsumed
to empty silo prior to boiler shutdown 10❑
i
Planned`
Biomass Boiler
Shutdowns
Section 9.0
9.I Chip deliveries will be halted as soon as possible for a
Managing Chip
unplanned shutdown of biomass boiler
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
Managing
for more than four days contact EHS 70
10.2 If chips cannot be used in Biomass process in :5 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

NOTES:
1, CROSS REFERENCE
C-00001-OY (G0000101:Gwg)
WREN MAKING M004FICATIONS
1O ANY WASTE STORAGE
AREAS.
1011
111 �a�rni I
ewa MM1 IIFMw
DRAVING TITLE
W 2 DRUM
E74 91 9RMT
ARAM lAym
DRAVING NUMBER
FIGURE 7

Via FcdEx; Return Receipt Requested
May 27, 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:
Charles E. Powell, Jr.
Sr. EHS Specialist I
Pfizer PGS
Sanford
4300 Oak Park
Sanford. NC 27330
RECEIVED
CLAY 2 9 2015-
DENR-LAND QUALITY
STORIVIVVATER PERMITTING
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 3Td
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). Manap_ement of Runuff: 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 BMP'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,
6
q-1arles >✓. Powell, Jr., RE
Sr. EHS Specialist I

Legend
7 8 `
Outfall—Locations.
Drainage Area
12 ,
I _ �. .ON
Wood Chip Storage
r
Biomass Boiler
OF
4
Note: Outfall 005 is the only outfall
that discharges stormwater -3
from an area with exposed 2
industrial activity, and the only area
that is characteristic of the activities r
rce Esri b�
under NCG210000. ' QA USGa. r v
ser Comrr
Stormwater Drainage Area 0 150 300 N _
Concepts 4fp Outfall Feet Dewberry
p Base Map 1 in = 300 ft A