NCGNE1025_COMPLETE FILE - HISTORICAL_20140904 (2)

- STORMWATER DIVISION CODING -SHEET-
RESCISSIONS.
PERMIT NO.
NC CjN Ei Ua�)
DOC TYPE
CJ COMPLETE -FILE -HISTORICAL
DATE OF
RESCISSION
❑
YYYYMMDD

I��
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral and Land Resources
Land Quality Section Pat McCrory, Governor
Tracy E. Davis, PE, CPM John E. Skvarla, III, Secretary
Director
September 4, 2014
Mr. Shawn Lafferty
Environmental Protection Agency
109 T. W. Alexander Drive
Research Triangle Park, NC 27711
Subject: Approval of No -Exposure Certification
RTP Durham
NCGNE1025
Durham County
Dear Mr. Lafferty:
The Division of Energy, Mineral and Land Resources (DEMLR) has reviewed your submittal of the No -
Exposure Certification for Exclusion from the NPDES Stormwater Permitting form and made a site visit to
assess the potential for stormwater pollution. Based on our observations and your submittal and signed
certification of no exposure at the above referenced facility, the Division is granting your conditional
exclusion from permitting as provided for under 40 CFR 12E.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 (subject to civil penalties of up to $25,000 per day). Your conditional no -exposure exclusion
does not expire. However, you must self re -certify annually, or obtain NPDES permit coverage for any
stormwater discharges from your facility. Please retain the completed re -certification forms to have
them available during future inspections by DEMLR.
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Ralegh, North Carolina 27609 One
Phone: [phone]DO 1 FAX: [phone] North C arol i n a
Internet: http:portal.ncdenr.orghxebllr! �fttiN�`!J/
An Equai Opportunity 1 Affirmative Action Employer i�L `K L j

14i
Your conditional exclusion from permitting 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 Dave Parnell at [phone] or at
[e-mail].
Sincerely,
John L. Holley, Jr., PE, CPESC
Regional Engineer
Raleigh Regional Office
cc: Stormwater Permitting Program Files - with attachment
Raleigh Regional Office DEMLR No Exposure Files - with attachment
1628 Mail Service Center, Ralegh, North Carolina 27699.1628
Location: 3800 Barrett Drive, Ralegh, North Carolina 27609 One
Phone: 919-791A200 t FAX: 919-571A718 NorthCaroiina
kntemei: http:portal.nodenr.orglweWlr! x//
An Equal Opportunity 1 Affirmalive Action Employer Na`utallI ,

.�
NC®ENR
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral and Land Resources
Land Quality Section Pat McCrory, Governor
Tracy E. Davis, PE, CPM John E. Skvarla, III, Secretary
Director
September 4, 2014
MAIL'ED
Mr. Shawn Lafferty
Environmental Protection Agency
109 T. W. Alexander Drive
Research Triangle Park, NC 27711
Subject: Approval of No -Exposure Certification
RTP Durham RECEiVEDIDENRIDWR
NCGNE1025
Durham County SEP 2 6 M4
Water warty
Permitting Section
Dear Mr. Lafferty:
The Division of Energy, Mineral and Land Resources (DEMLR) has reviewed your submittal of the No -
Exposure Certification for Exclusion from the NPDES Stormwater Permitting form and made a site visit to
assess the potential for stormwater pollution. Based on our observations and your submittal and signed
certification of no exposure at the above referenced facility, the Division is granting your conditional
exclusion from permitting 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 (subject to civil penalties of up to $25,000 per day.). Your conditional no -exposure exclusion
does not expire. However, you must self re -certify annually, or obtain NPDES permit coverage for any
stormwater discharges from your facility. Please retain the completed re -certification forms to have
them available during future inspections by DEMLR.
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Raleigh, North Carolina 27609 One
Phone: [phone] FAX: [phone] NorthCat'olina
Internet: http:portal,ncdenr,orglwebllrl �aturalC� An Equal Opportunity 1 Affirmative Action Employer

EDTro IUI-117
"' ' '~ ,'|'

:r
Your conditional exclusion from permitting 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 Dave Parnell at [phone] or at
david.parnellftcdenngov.
Sincerely,
ohn . Holley, Jr., PE, CPESC
onal Engineer
Raleigh Regional Office
cc: Stormwater Permitting Program Files - with attachment
Raleigh Regional Office DEMLR No Exposure Files - with attachment
1628 Mail Service Center, Raleigh, North Carolina 27699-1628
Location: 3800 Barrett Drive, Raleigh, Noah Carolina 27609
Phone: [phone] FAX: [phone]
Intemet: http:portal, ncdenr.orglwebllrt
An Equal Opportunity 1 Affirmative Action Employer
None
rthCarolina
Naturally

r
Compliance Inspection Report
Permit: NCGNE1025 Effective: Expiration: Owner: Environmental Protection Agency
SOC: Effective: Expiration: Facility: Environmental Protection Agency
County: Durham 109 TW Alexander Dr
Region: Raleigh
RTP NC 27711
Contact Person: Shawn Lafferty Title: Phone: [phone]
Directions to Facility:
Facility is bordered by TW Alexander Drive (SR-2028) to the west, NC-147 to the east, Hopson Road (SR-1978) to the south, and an
abandoned former spur of NC-147 to the north.
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date:' 08/26/2014 Entry Time: 01:OOPM Exit Time: 02:OOPM
Primary Inspector: David R Parnell Phone: [phone]
Secondary lnspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: Compliant Not Compliant
Question Areas:
Miscellaneous Questions Misc
(See attachment summary)
Page: 1

Permit: NCGNE1025 Owner - Facility: Environmental Protection Agency
inspection Data: 0812612014 Inspection Type: Compliance Evaluation Reason for Visit Routine
Inspection Summary:
Page: 2

1
permit; NCGNE1025 owner- Facility: Environmental Protection Agency
Inspection Data: 0812612014 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Misc
Yes No NA NE
Is the facility compliant? 0 ❑ ❑ ❑
Comment: This Compliance Evaluation Inspection was to evaluate this facility's compliance with the No
Exposure Certification that they have submitted. A prior evaluation had revealed coal
T roductsldust that were exposed to weather as well as pallets and other items that needed
shelter. These issues have been resolved. It was pointed out that pallets may, not be stored
without being covered, even for short periods of time, while waltinMffor pickup. The No Exposure
Certification is approved for this site.
Page: 3

Parnell, David
From: Kenny, James T [e-mail]]
Sent: Thursday, October 04, 2012 9:26 PM
To: Parnell, David
Cc: West, Sandy
Subject: RE: Merck Technical Assistance Visit - No Exposure
Attachments: Nalco2_USA_English.pdf; ATT00001.c; ATT00002.htm
Dave -
Thanks for coming out on Wednesday - we certainly appreciated your help. I have attached the MSDS for
the Nalco-2 as promised.
We are working with our Plant Engineering group regarding the empty drums you saw. Leaving the
drums where we saw them is not an acceptable practice at our facility and we will ensure folks realize
that. I will also send you an update on the removal of the pipe rack once I get some solid dates around
that activity.
From my notes, the site was meeting the No Exposure criteria with regard to the gas and diesel loading
and storage areas as well as the areas where we transfer water treatment chemical (the empty drums
referenced above excluded). The configuration of the loading docks, the dumpsters and the compactors
were also in alignment with the NE program and there was no condensate flow that required separate
permitting.
As mentioned above, we will be in contact and will call you for another visit shortly. In the mean time,
should you have any questions or suggestions for us - please don't hesitate to contact me. Once again,
thank you for your help.
Jim Kenny
Durham - VMF
919-884-4267
http:llwww.meTckmanufacturing-dur.ham.com/
From: Parnell, David [mailto:[e-mail]]
Sent: Thursday, October 04, 2012 10:29 AM
To: Kenny, -James T
Cc: Lowther, Brian
Subject: Merck Technical Assistance Visit - No Exposure
Jim,
Enclosed is the site visit record from my visit to Merck on October 3. Please keep me updated on the
progress of the alterations at the Water Reclamation Process area. Also please send me a MSDS for the
NALGO-2.
Thanks,
Dave Parnell
Environmental Specialist

Division of Water Quality
Surface Water Protection Section
3800 Barrett Drive
Raleigh, NC 27609
david.pai-nell(@ncdenr.gov
919-791-4260
919-788-7159 Fax
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties.

��NALCO
HUMAN HEALTH HAZARDS - ACUTE
SAFETY DATA SHEET
PRODUCT
NALCO® 2
EMERGENCY TELEPHONE NUMBER(S)
[phone] (24 Hours) CHEMTREC
EYE CONTACT :
Corrosive. Will cause eye burns and permanent tissue damage.
SKIN CONTACT
Corrosive; causes permanent skin damage.
INGESTION:
Corrosive; causes chemical burns to the mouth, throat and stomach.
INHALATION:
Elevated temperatures or mechanical action may form vapors, mists or fumes which may be irritating to the eyes,
nose, throat and lungs.
AGGRAVATION OF EXISTING CONDITIONS :
A review of available data does not identify any worsening of existing conditions.
4. J FIRST AID MEASURES
EYE CONTACT :
Immediately flush eye with water for at least 15 minutes while holding eyelids open. PROMPT ACTION IS
ESSENTIAL IN CASE OF CONTACT. Get immediate medical attention.
SKIN CONTACT:
Immediately flush with plenty of water for at least 15 minutes. Use a mild soap if available. For a large splash, flood
body under a shower. Get immediate medical attention. Contaminated clothing, shoes, and leather goods must be
discarded or cleaned before re -use.
INGESTION:
Get immediate medical attention. DO NOT INDUCE VOMITING. If conscious, washout mouth and give water to drink.
INHALATION:
Remove to fresh air, treat symptomatically. Get immediate medical attention.
NOTE TO PHYSICIAN:
Probable mucosal damage may contraindicate the use of gastric lavage. Based on the individual reactions of the
patient, the physician's judgement should be used to control symptoms and clinical condition.
5. FIRE FIGHTING MEASURES
FLASH POINT: None
EXTINGUISHING MEDIA:
Not expected to burn. Use extinguishing media appropriate for surrounding fire.
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www.nalco.com and request access.
2111

A41'NALCO
SAFETY DATA SHEET
PRODUCT
NALCOO 2
EMERGENCY TELEPHONE NUMBER(S)
[phone] (24 Hours) CHEMTREC
FIRE AND EXPLOSION HAZARD
Not flammable or combustible. Contact with reactive metals (e.g. aluminum) may result in the generation of flammable
hydrogen gas.
SPECIAL PROTECTIVE EQUIPMENT FOR FIRE FIGHTING :
In case of fire, wear a full face positive -pressure self contained breathing apparatus and protective suit.
6. JMCCIIDENTA03EEEASEWEASURES7
PERSONAL PRECAUTIONS:
Restrict access to area as appropriate until clean-up operations are complete. Use personal protective equipment
recommended in Section 8 (Exposure Controls/Personal Protection). Stop or reduce any leaks if it is safe to do so.
Keep people away from and upwind of spill/leak. Ventilate spill area if possible. Ensure clean-up is conducted by
trained personnel only. Do not touch spilled material. Have emergency equipment (for fires, spills, leaks, etc.) readily
available. Notify appropriate government, occupational health and safety and environmental authorities.
METHODS FOR CLEANING UP:
SMALL SPILLS: Soak up spill with absorbent material. Place residues in a suitable, covered, properly labeled
container. Wash affected area. LARGE SPILLS: Contain liquid using absorbent material, by digging trenches or by
diking. Reclaim into recovery or salvage drums or tank truck for proper disposal. Clean contaminated surfaces with
water or aqueous cleaning agents. Contact an approved waste hauler for disposal of contaminated recovered
material. Dispose of material in compliance with regulations indicated in Section 13 (Disposal Considerations).
ENVIRONMENTAL PRECAUTIONS :
Do•not-contaminate-surface'water.,.,
7. 1 HANDLING AND STORAGE
HANDLING:
Do not get in eyes, on skin, on clothing. Do not take internally. Use with adequate ventilation. Avoid generating
aerosols and mists. Keep the containers closed when not in use. Have emergency equipment (for fires, spills, leaks,
etc.) readily available.
STORAGE CONDITIONS:
Store the containers tightly closed. Store separately from acids. Store in suitable labeled containers.
SUITABLE CONSTRUCTION MATERIAL:
Compatibility with Plastic Materials can vary; we therefore recommend that compatibility is tested prior to use.
8. 1 EXPOSURE CONTROLS/PERSONAL PROTECTION
OCCUPATIONAL EXPOSURE LIMITS:
Exposure guidelines have not been established for this product. Available exposure limits for the substance(s) are
shown below.
Substance(s) Category: ppm mg1m3 Non -Standard
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www.nalco.com and request access.
3/11

��NALCO
Sodium Hydroxide
SAFETY DATA SHEET
PRODUCT
NALGO@ 2
EMERGENCY TELEPHONE NUMBER(S)
[phone] (24 Hours) CHENiTREC
ACGIHICeiling
OSHA Z1/PEL
Unit
ENGINEERING MEASURES:
General ventilation is recommended. Use local exhaust ventilation if necessary to control airborne mist and vapor.
RESPIRATORY PROTECTION:
Where concentrations in air may exceed the limits given in this section or when significant mists, vapors, aerosols, or
dusts are generated, an approved air purifying respirator equipped with suitable filter cartridges is recommended.
Consult the respirator 1 cartridge manufacturer data to verify the suitability of specific devices. In event of emergency
or planned entry into unknown concentrations a positive pressure, full-facepiece SCBA should be used. If respiratory
protection is required, institute a complete respiratory protection program including selection, fit testing, training,
maintenance and inspection.
HAND PROTECTION:
When handling this product, the use of chemical gauntlets is recommended. The choice of work glove depends on
work conditions and what chemicals are handled. Please contact the PPE manufacturer for advice on what type of
glove material may be suitable. Gloves should be replaced immediately if signs of degradation are observed.
SKIN PROTECTION:
Wear chemical resistant apron, chemical splash goggles, impervious gloves and boots. A full slicker suit is
recommended if gross exposure is possible.
EYE PROTECTION. -
Wear a face shield with chemical splash goggles.
HYGIENE RECOMMENDATIONS:
Use good work and personal hygiene practices to avoid exposure. Eye wash station and safety shower are necessary.
If clothing is contaminated, remove clothing and thoroughly wash the affected area. Launder contaminated clothing
before reuse. Always wash thoroughly after handling chemicals. When handling this product never eat, drink or
smoke.
HUMAN EXPOSURE CHARACTERIZATION
Based on our recommended product application and personal protective equipment, the potential human exposure is:
Low
9. 1 PHYSICAL AND CHEMICAL PROPERTIES
PHYSICAL STATE Liquid
APPEARANCE Clear White
ODOR None
SPECIFIC GRAVITY 1.44 - 1.52 @ 77 °F 125 °C
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www.nalco.com and request access.
4111

RV NA 0
DENSITY
SOLUBILITY IN WATER
pH (100 %)
VISCOSITY
VOC CONTENT
SAFETY DATA -SHEET
PRODUCT
NALCO@ 2
EMERGENCY TFLFPHONF Ni1MRFRISI
[phone] (24 Hours) CHEMTREC
12.0 - 12.7 IblgaI
Complete
14
280 cps @ 40 °F 14.4 °C
0.00 % EPA Method 24
Note: These physical properties are typical values for this product and are subject to change.
10. 1 STABILITY AND REACTIVITY
STABILITY:
Stable under normal conditions.
HAZARDOUS POLYMERIZATION!
Hazardous polymerization will not occur.
CONDITIONS TO AVOID:
Freezing temperatures.
MATERIALS TO AVOID:
Contact with strong acids (e.g. sulfuric, phosphoric, nitric, hydrochloric, chromic, sulfonic) may generate heat,
splattering or boiling and toxic vapors.
HAZARDOUS DECOMPOSITION PRODUCTS:
Under fire conditions: None known
11. 1 TOXICOLOGICAL INFORMATION
No toxicity studies have been conducted on this product.
SENSITIZATION:
This product is not expected to be a sensitizer.
CARCINOGENICITY:
None of the substances in this product are listed as carcinogens by the International Agency for Research on Cancer
(IARC), the National Toxicology Program (NTP) or the American Conference of Governmental Industrial Hygienists
(ACGIH).
HUMAN HAZARD CHARACTERIZATION:
Based on our hazard characterization, the potential human hazard is: High
12. 1 ECOLOGICAL INFORMATION
ECOTOXICOLOGICAL EFFECTS:
The following results are for the product.
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www, nalco.com and request access.
5111

A40NALCO
Acute Fish Results :
SAFETY DATA SHEET
PRODUCT
NALCO® 2
EMERGENCY TELEPHONE NUMBER(S)
[phone] (24 Hours) CHEMTREC
Species
Ex osure
I Test Type
I Value
I Test Descriptor
Rainbow Trout
96 hrs
LC50
172 mg/1
Product
Fathead Minnow.
96 hrs
LC50
534 m /I
Product
ACUTE INVERTEBRATE RESULTS:
Species I Exposure Test Type Value Test Descriptor
Daphnia magna 148 hrs LC50 64 mq/1 Product
ENVIRONMENTAL HAZARD AND EXPOSURE CHARACTERIZATION
Based on our hazard characterization, the potential environmental hazard is: Low
Based on our recommended product application and the product's characteristics, the potential environmental
exposure is: High
If released into the environment, see CERCLA/SUPERFUND in Section 15,
13. DISPOSAL CONSIDERATIONS
If this product becomes a waste, it could meet the criteria of a hazardous waste as defined by the Resource
Conservation and Recovery Act (RCRA) 40 CFR 261. Before disposal, it should be determined if the waste meets the
criteria of a hazardous waste.
Hazardous Waste: D002
Hazardous wastes must be transported by a licensed hazardous waste transporter and disposed of or treated in a
properly licensed hazardous waste treatment, storage, disposal or recycling facility. Consult local, state, and federal
regulations for specific requirements.
1 14. 1 TRANSPORT INFORMATION I
The information in this section is for reference only and should not take the place of a shipping paper (bill of lading)
specific to an order. Please note that the proper Shipping Name / Hazard Class may vary by packaging, properties,
and mode of transportation. Typical Proper Shipping Names for this product are as follows.
The presence of an RQ component (Reportable Quantity for U.S. EPA and DOT) in this product causes it to be
regulated with an additional description of RQ for road, or as a class 9 for road and air, ONLY when the net weight in
the package exceeds the calculated RQ for the product.
LAND TRANSPORT
Proper Shipping Name ; SODIUM ALUMINATE SOLUTION
Technical Names):
UN/ID No: ' UN 1819
Hazard Class - Primary : 8
Packing Group : 11
Nalco Company 1601 W, Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www.naloo.com and request access.
6/11

��NALCO
SAFETY DATA SHEET
PRODUCT
NALCO® 2
EMERGENCY TELEPHONE NUMBER(S)
[phone] (24 Hours) CHEMTREC
Flash Point : None
Reportable Quantity (per package) : 14,650 Ibs
RQ Component : SODIUM HYDROXIDE
AIR TRANSPORT (ICAO/IATA) :
The presence of an RQ component (Reportable Quantity for U.S. EPA and DOT) in this product causes it to be
regulated with an additional description of RQ for road, or as a class 9 for road and air, ONLY when the net weight in
the package exceeds the calculated RQ for the product.
Proper Shipping Name
Technical Name(s)
UN/ID No. -
Hazard Class - Primary:
Packing Group :
Reportable Quantity (per package)
RQ Component :
MARINE TRANSPORT (IMDG/IMO) :
Proper Shipping Name
Technical Name(s) :
UN/ID No :
Hazard Class - Primary:
Packing Group :
15. 1 REGULATORY INFORMATION
SODIUM ALUMINATE SOLUTION
UN 1819
8
11
14,650 Ibs
SODIUM HYDROXIDE
SODIUM ALUMINATE SOLUTION
UN 1819
8
11
This section contains additional information that may have relevance to regulatory compliance. The information in this
section is for reference only. It is not exhaustive, and should not be relied upon to take the place of an individualized
compliance or hazard assessment. Nalco accepts no liability for the use of this information.
NATIONAL REGULATIONS, USA:
OSHA HAZARD COMMUNICATION RULE, 29 CFR 1910.1200 :
Based on our hazard evaluation, the following substance(s) in this product is/are hazardous and the reason(s) is/are
shown below.
Sodium Aluminate : Corrosive
Sodium Hydroxide : Corrosive
CERCLA/SUPERFUND, 40 CFR 302 :
This product contains the following Reportable Quantity (RQ) Substance. Also listed is the RQ for the product. If a
reportable quantity of product is released, it requires notification to the NATIONAL RESPONSE CENTER,
WASHINGTON, D.C. (1-800-424-8802).
RQ Substance
RQ
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www.nalco.com and request access.
7/11

��NALCO
Sodium Hydroxide
SAFETY DATA SHEET
PRODUCT
NALCO® 2
EMERGENCY TELEPHONE NUMBER(S)
[phone] (24 Hours) CHEMTREC
14,650 Ibs
SARA/SUPERFUND AMENDMENTS AND REAUTHORIZATION ACT OF 1986 (TITLE III) - SECTIONS 302, 311,
312, AND 313 :
SECTION 302 - EXTREMELY HAZARDOUS SUBSTANCES (40 CFR 355) :
This product does not contain substances listed in Appendix A and B as an Extremely Hazardous Substance.
SECTIONS 311 AND 312 - MATERIAL SAFETY DATA SHEET REQUIREMENTS (40 CFR 370) :
Our hazard evaluation has found this product to be hazardous. The product should be reported under the following
indicated EPA hazard categories:
X Immediate (Acute) Health Hazard
- Delayed (Chronic) Health Hazard
- Fire Hazard
- Sudden Release of Pressure Hazard
- Reactive Hazard
Under SARA 311 and 312, the EPA has established threshold quantities for the reporting of hazardous chemicals.
The current thresholds are: 500 pounds or the threshold planning quantity (TPQ), whichever is lower, for extremely
hazardous substances and 10,000 pounds for all other hazardous chemicals.
SECTION 313 - LIST OF TOXIC CHEMICALS (40 CFR 372) :
This product does not contain substances on the List of Toxic Chemicals.
TOXIC SUBSTANCES CONTROL ACT (TSCA) :
The substances in this preparation are included on or exempted from the TSCA 8(b) Inventory (40 CFR 710)
FOOD AND DRUG ADMINISTRATION (FDA) Federal Food, Drug and Cosmetic Act :
When use situations necessitate compliance with FDA regulations, this product is acceptable under : 21 CFR 173.310
Boiler Water Additives, 21 CFR 176.170 Components of paper and paperboard in contact with aqueous and fatty foods
and 21 CFR 176.180 Components of paper and paperboard in contact with dry foods.
Limitations: no more than required to produce intended technical effect. Steam produced may be used in contact with
any food type, defined under 21 CFR 170, 3, which includes milk or milk products.
NSF NON-FOOD COMPOUNDS REGISTRATION PROGRAM (former USDA List of Proprietary Substances &
Non -Food Compounds) :
NSF Registration number for this product is : 062373
This product is acceptable for treating boilers or steam lines where steam produced may contact edible products
and/or cooling systems where the treated water may not contact edible products in and around food processing areas
(G6).
This product has been certified as KOSHER/PAREVE for year-round use INCLUDING THE PASSOVER SEASON by
the CHICAGO RABBINICAL COUNCIL.
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www.nalco.com and request access.
8/11

AV NA 0
SAFETY DATA SHEET
PRODUCT
NALCO® 2
EMERGENCY TELEPHONE NUMBER(S)
[phone] (24 Hours) CHEIUITREC
NSF INTERNATIONAL:
This product has received NSF/International certification under NSF/ANSI Standard 60 in the coagulation and
flocculation category. The official name is "Sodium Aluminate". Maximum product application dosage is: 100 mgll.
FEDERAL WATER POLLUTION CONTROL ACT, CLEAN WATER ACT, 40 CFR 401.151 formerly Sec. 307,40 CFR
116.4 1 formerly Sec. 311 :
This product contains the following substances listed in the regulation. Additional components may be unintentionally
present at trace levels.
Substances
Citations
• Sodium Hydroxide
Sec. 311
CLEAN AIR ACT, Sec. 112 (Hazardous Air Pollutants, as amended by 40 CFR 63), Sec. 602 (40 CFR 82, Class I and
II Ozone Depleting Substances) :
Substances listed under this regulation are not intentionally added or expected to be present in this product. Listed
components may be present at trace levels.
CALIFORNIA PROPOSITION 65 :
Substances listed under California Proposition 65 are not intentionally added or expected to be present in this product.
MICHIGAN CRITICAL MATERIALS:
Substances listed under this regulation are not intentionally added or expected to be present in this product. Listed
components may be present at trace levels.
STATE RIGHT TO KNOW LAWS:
The following substances are disclosed for compliance with State Right to Know Laws:
Sodium Aluminate 1302-42-7
Sodium Hydroxide 1310-73-2
Water 7732-18-5
INTERNATIONAL CHEMICAL CONTROL LAWS:
CANADIAN ENVIRONMENTAL PROTECTION ACT (CEPA) :
The substance(s) in this preparation are included in or exempted from the Domestic Substance List (DSL).
16. 1 OTHER INFORMATION
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www.nalco.com and request access.
9111

��NALCO
SAFETY DATA SHEET
PRODUCT
NALCO® 2
EMERGENCY TELEPHONE NUMRFR(SI
[phone] (24 Hours) CHEMTREC
Due to our commitment to Product Stewardship, we have evaluated the human and environmental hazards and
exposures of this product. Based on our recommended use of this product, we have characterized the product's
general risk. This information should provide assistance for your own risk management practices. We have evaluated
our product's risk as follows:
* The human risk is: Low
* The environmental risk is: Low
Any use inconsistent with our recommendations may affect the risk characterization. Our sales representative will
assist you to determine if your product application is consistent with our recommendations. Together we can
implement an appropriate risk management process.
This product material safety data sheet provides health and safety information. The product is to be used in
applications consistent with our product literature. Individuals handling this product should be informed of the
recommended safety precautions and should have access to this information. For any other uses, exposures should
be evaluated so that appropriate handling practices and training programs can be established to insure safe workplace
operations. Please consult your local sales representative for any further information.
REFERENCES
Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices, American
Conference of Governmental Industrial Hygienists, OH., (Ariel InsightT"' CD-ROM Version), Ariel Research Corp.,
Bethesda, MD.
Hazardous Substances Data Bank, National Library of Medicine, Bethesda, Maryland (TOMES CPSTM CD-ROM
Version), Micromedex, Inc., Englewood, CO.
IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Man, Geneva: World Health
Organization, International Agency for Research on Cancer.
Integrated Risk Information System, U.S. Environmental Protection Agency, Washington, D.C. (TOMES CPST"'
CD-ROM Version),
Micromedex, Inc., Englewood, CO.
Annual Report on Carcinogens, National Toxicology Program, U.S. Department of Health and Human Services, Public
Health Service.
Title 29 Code of Federal Regulations, Part 1910, Subpart Z, Toxic and Hazardous Substances, Occupational Safety
and Health Administration (OSHA), (Ariel InsightT"' CD-ROM Version), Ariel Research Corp., Bethesda, MD.
Registry of Toxic Effects of Chemical Substances, National Institute for Occupational Safety and Health, Cincinnati,
OH,
(TOMES CPST"' CD-ROM Version), Micromedex, Inc., Englewood, CO.
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 - [phone]
For additional copies of an MSDS visit www. nalco.com and request access.
10111

A41"NaLco
SAFETY DATA SHEET
PRODUCT
NALCOO 2
EMERGENCY TELEPHONE NUMBER(5)
[phone] (24 Hours) CHEMTREC
Ariel InsightTM (An integrated guide to industrial chemicals covered under major regulatory and advisory programs),
North American Module, Western European Module, Chemical Inventories Module and the Generics Module (Ariel
lnsightTM CD-ROM Version), Ariel Research Corp., Bethesda, MD.
The Teratogen Information System, University of Washington, Seattle, WA (TOMES CPSTM CD-ROM Version),
Micromedex, Inc., Englewood, CO.
Prepared By: Product Safety Department
Date issued : 06/27/2012
Version Number : 1.21
Nalco Company 1601 W. Diehl Road • Naperville, Illinois 60563-1198 • [phone]
For additional copies of an MSDS visit www. nalco.com and request access.
11 1 11

Parnell, David
From: Kenny, James f [e-mail]]
Sent: Thursday, October 04, 2012 9:26 PM
To: Parnell, David
Cc: West, Sandy
Subject: RE: Merck Technical Assistance Visit - No Exposure
Attachments: Nalco2_USA_English.pdf; ATT00001.c; ATT00002.htm
Dave -
Thanks for coming out on Wednesday - we certainly appreciated your help. I have attached the MSDS for
the Nalco-2 as promised.
We are working with our Plant Engineering group regarding the empty drums you saw. Leaving the
drums where we saw them is not an acceptable practice at our facility and we will ensure folks realize
that. I will also send you an update on the removal of the pipe rack once I get some solid dates around
that activity.
From my notes, the site was meeting the No Exposure criteria with regard to the gas and diesel loading
and storage areas as well as the areas where we transfer water treatment chemical (the empty drums
referenced above excluded). The configuration of the loading docks, the dumpsters and the compactors
were also in alignment with the NE program and there was no condensate Flow that required separate
permitting.
As mentioned above, we will be in contact and will call you for another visit shortly. In the mean time,
should you have any questions or suggestions for us - please don't hesitate to contact me. Once again,
thank you for your help.
Jim Kenny
Durham - VMF
919-884-4267
http://wwvv.mecckmanufacturing-durham.com/
From: Parnell, David[mailto:[e-mail]]
Sent: Thursday, October 04, 2012 10:29 AM
To: Kenny, James T
Cc: Lowther, Brian
Subject: Merck Technical Assistance Visit - No Exposure
Jim,
Enclosed is the site visit record from my visit to Merck on October 3. Please keep me updated on the
progress of the alterations at the Water Reclamation Process area. Also please send me a MSDS for the
NALCO-2.
Thanks,
Dave Parnell
Environmental Specialist

Division of Water Quality
Surface Water Protection Section
3800 Barrett Drive
Raleigh, NC 27609
david.narnell @ncdenr.Rov
919-791-4260
919-788-7159 Fax
E-mail correspondence to and from this address may be subject to the North Carolina Public Records Law
and may be disclosed to third parties.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Research Triangle Park; NC 27711
OFFICE OF
ADMINISTRATION
AND RESOURCES
MANAGEMCNT
July 22, 2014
North Carolina Department of Environment and Natural Resources
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, NC 27699-1617
To whom it may concern:
Please find the attached Division of Water Quality/Surface Water Protection, National
Pollution Discharge Elimination System, NO EXPOSURE CERTIFICATION for
Exclusion.
The Environmental Protection Agency, located at Research Triangle Park (EPA RTP) is
submitting the No Exposure Certification form and supporting attachments based on the
interpretation received through email from Ken Pickle, Environmental Engineer:,
NCDENR/ DEMLR/ Stormwater Permitting Program, dated March 28, 2014. The
enclosed email, which discussed the EPA's shared hazardous waste permit with NLEHS,
clarified EPA-RTP's applicability to the stormwater No Exposure Certification.,
Therefore, EPA-RTP is enclosing the completed form for your review and dete=' Ination.
If you have any questions please feel free to contact me at 919-541-5449.
Sincerely,
Shawn L erty
Safety & Occupational Health Manager
Enclosed: No Exposure Certification application
Durham county Tax parcel site location
Description of EPA-RTPs Hazardous Waste Storage Facility at EPA-RTP
Email dated March 28, 2014, EPA stormwater permitting at RTP
Internet Address (URL) • http://www.epa,gov
FtecycledlRecyclable • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30 % Postconsumer)

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AMM
Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
' NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
NO EXPOSURE CERTIFICATION
FOR AGENCY.USE ONLY
Date Received
Year
Month
Da
Certificate of Coverage
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater-.discharges associated with industrial activity in the State of North Carolina because
it qualifies for a•no exposure exclusion. A condition of no exposure at an industrial facility means all
indusfriah materials andyactivifies are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DWQ must approv your application for No
Exposure Certification before this exclusion -is effective. Until -you are issued ,a No
Exposure Certification and your NPDES permit is. rescinded„your facility must continue
to abide by the terms; and conditions of the current permit.
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 with locked or non -operational taps or valves; adequately maintained .
vehicles used in materla_ Ghandling;.and final products, other than products that -would be! mobilized in
stormwater 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 wlde Basis ohly­�7ot for individual
outfalls. If any industrial activities or materials are, or will be, exposed toprecipitation, tiie facility is not
eligible for the no exposure, exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
For questions, please contact the DWQ, Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed?:
Name Environmental Protectiort Agency. Research Triangle Park
Contact Peter Johnson
Street Address
Cjty
Telephone No.
Email
109 T.W. Alexander Drive
Research Triangle Park State NC ZIP Code 27526
[phone] Fax: [phone]
[e-mail]
Page 1 of 7
S W U-N E-12Aug2010

Ni
NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Environmental Protection Agency, Research Triangle Park
Facility Contact
Shawn Lafferty
Facility Street Address 109 TW Alexander Drive
City
Research Triangle Park
County
Durham
Telephone No.
[phone]
Email
[e-mail]
State NC ZIP Code 27711
Fax: [phone]
3) Physical location information:
Please provide a. narrative description of how to get to the,facility,(usestreet.names;.state;road numbers, and
distance and';direction from a roadway Intersection). Facility is bgrdered,by TW Alexander Ddve.(SR 2028) to the.west, NC-14'7 to
the east, Hopson Rd. (SR-1978) to the south, and an abandoned former spur of NC-147 to the north.
(A copy of a map with the facility clearly located on ii.should be included with the certification -application.)
4) Is the facility. located on Native American Lands? ❑ Yes • • p=NoY
5) Is this a Federal facility? p Yes ❑ No
6) Latitude 35. 52, 56.8668 Longitude 78,52, 21.5364 (deg., min., seconds)
7) This NPDES� No Exposure Exclusion application applies to -which. of.th&f6Ilowing:
❑ New or Proposed Facility Date operation is.to begin
Existing ! Date operation began 20131
❑ Renewallof existing No Exposure Certification Certification No.: NCGNE: .
i
8) Was this facility or site ever covered under an NODES Stormwater Permit? ❑Yes, p No°
If yes, what is the NPDES Permit !Number?
i
9) .Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary ihdustrial
activity at this facility
SIC Code: 81 7 3 3
10) Provide a brief description of the types of industrial activities and .products. produced at this facility:
EPA- RTP is a research laboratory, with associated facility andadministrative support. No products are produced at this_fac lity:
11) Does this facility have any Non -Discharge permits (ez': recycle permits)?
❑ No
O Yes
If yes, list thepermit numbers for all current Non -Discharge permits for this facility:
Hazardous Waste Management Permit, (shared with NIEHS) NC2750890004-R2
Underground Storage Tank Permits, 20130652401, 20130652901, 20120753601
Ind ustrial'UserjPermit, County of Durham, DCL-034
' Air Permit (shared with NIEHS), No. 04226R29
Page 2of7
SWU-NE-12Aug2010

NCGNE0000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) 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 for the no exposureexclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
❑Yes O No
residuals from, using, storing- or. cleanino. industrial machinery or equipment remain
i
and are exposed to stormwater
s
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
❑ Yes O No
c. Materials or products from past industrial activity
❑ Yes ONo
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes ONo
{
e. Materials or products during loadinglunloading or transporting activities
❑Yes ONo
f. Materials or products stored outdoors (except final products intended for outside
❑ Yes O No
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
—
k
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
❑ Yes ONo
and similar container`s
t
h. Materials or products handled/stored on roads or railways owned or. maintained by
El Yes ONo
the discharger
i. Waste material (except waste,in covered, non -leaking containers [e.g., dumpsters])
❑Yes ONo
j. Application or disposal of process wastewater (unless otherwise permitted)
❑ Yes 0 No
k. Particulate matter or visible deposits of residuals from roof;stkks and/or vents not
❑Yes El 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 p No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers
❑ Yes O No
stored outside, has the facility had any releases in the past,three (3). years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a.. Are exterior ASTs and.piping•free of rust, damaged or weathered coating, pits, or pYes ❑ 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?
Page 3of7
$ W U—N£-12Aug2010

NCGNE0000 No Exposure Certification
14) Secondary Containment: If you answer." `No" to.anyof the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for all single above ground storage
DYes [--]No O 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
DYes ❑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 4&
[-]Yes ❑ No ❑✓ NIA
CFR §116?
e. Are release valves on all secondary containment structures locked?
✓]Yes ❑No ❑NIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
I
❑✓ Yes `nNo
A. .
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste, [] Yes.. P/1 No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste DYes. []No
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information-
Type(s) of waste: solvents, toxic, and corrosive materials from research operations
How Is material stored: Indoors, in containers less than or equal to 55 gal., in secondarycontainment
I
Where is material stored: Research cabs and two waste handling locations, all indoors
How many disposal shipments.per year<,, Aprx.4 shipments per year
Name of transport / disposal vendor: Veoila Es Teclir icai Solui;oris
Vendor address: 2176 will suitt Road, Creedmoor, NC 27522
Footnotes to Questions 14) 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)-bvlk storage minimums require
secondary containment. However, some exceptions maybe made for amounts`less thah'the Reportable'Quantities
of the hazardous 'substances listed in 40 CFR §117.3.
Page 4 of 7
SwU-NE-12Au92010

NCGNE0000 No Exposure Certification
16) Other information: If you answer "Yes" to any of the following items, you might not be. eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may beirequired.
a. Does your facility store used, recycled, or.otherwise reclaimed pallets outside? .❑ Yes ❑ No
b. Does your facility have coal piles on site? ❑Yes E]No
c. Does your facility store other fuel sources outside in piles, such as wood chips, []Yes ID No
sawdust, etc.?
d Does your facility have air emissions assocrated with its industrial.activity (e.g„ ❑Yes No
i
d�greasng operations, plating, pairiting.and`metal #finishing}? Ef so,.describe the I
i nd'ustrial. acfi�ity:
e. It you answered,yes to d., are those emissions permitted by an Air Quality Permit? ❑Yes ❑No 0 NIA
Pleasev6dif :
f Please Irst any other environmental program permits,(federal, state, etc.} not
specitied'earlier in.this application (§uch as Hazardous Waste Permits, etc.):
Permit: Program:
Permit: Prog ram :
Permit: Program:
Permit: Program: `
Permit: Program:
Permit: Program:
Permit: Program:
Notes: See attached supporting documentation.
Page 5 of 7
S W U-N E-12Aug2410

I
NCGNE0000 No Exposure Certification
17) 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 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 12226(g)(2)).
I understand that I am obligated to annually self re -certify No Exposure and, if requested, submit the re -certification to
DWQ or.the operator of the local municipal separate storm sewer system (NV24) into which the facility discharges (where
applicable). I understand that I must allow the hlorth Carolina Division of Water'Quaiity, or MS4: oper•ator,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 discharde,of stormwater from the facility. Additionally, 1 certify uhdar penalty of
law that this document and all attachments were prepared under my direction'or.supervision in accordance=wth.a system i
designed to assure that qualified: personnel properly gathered and evaliiated.tfie information submitted: Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible forgathering 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.
i
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: Peter Johnson
Title: Director, Office of Admirtistrabon and Resource Management
5-&Applicant)
�lt4/
(Date Signed)
I
Please note: This application for the No Exposure Exc{usiori is` s rtijecf to appidval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
i
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 file&or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a rnaterial 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).
There is currently no fee for a No Exposure Exclusion.
Page•6 of 7
SWU-NE-12Aug2010

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Quick Information
PIN Number:0737-04-66-4416, Parcel ID: 178490
Acreage: 500.23500000 Land Use: IND/ ENVIRONMENTAL SCI
Deed Book: 000336 Deed Page: 000300
Plat Book: 000057 P[at Page: 000092,
Subdivision: N/A-iNO•SUBDIVISION Site'Addeess: 109 T W ALEXANDER DR
Owner Name: UNITED STATES OF Owner Address: ATTN US ARMY CORP OF
AMERICA ENGINEERS
11405 FALLS OF THE NEUSE RD
WAKE FOREST, NC, 27587

Hazardous Waste Storage Facility at EPA-RTP
The EPA shares a hazardous waste storage permit (NC2750890004-R2) with NIEHS as we both reside on
one tract of federally owned land. Under this permit, we have two rooms in the EPA Administration and
Research Building that are permitted storage areas. These 2 rooms are completely enclosed, climate
controlled and are not exposed to any weather. The only activities conducted in these rooms are
consolidation of wastes (primarily solvents and aqueous wastes) from small containers (4;diter or less) to
55-gallon drums, and short-term storage of these drums.
Once these drums are filled, they are loaded directly onto an enclosed box truck and transferred to the
main Hazardous Waste Storage Facility on the NEIHS side of the campus. This storage facility is covered
under an individual Stormwater Permit (NCS000360). These transfers occur roughly every 45 days.
At no time are any wastes left outdoors where they would be exposed to any stormwater!

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
_ OFFICE OF SCIENCE INFORMATION MANAGEMENT
W RESEARCH TRIANGLE PARK, NC 27711
c
OFFICE OF
RESEARCH AND DEVELOPMENT
Mr. Ken Pickle
North Carolina Department of Environment and Natural Resources
Division of Energy, Mineral, and Land Resources
1612 Mail rZ eraice Center
Raleigh, NC: 27699-1612
SUBJECT. US Environmental Protection Agency's Research Triangle Park Campus and
Applicabili,y for NPDES Stormwater Permit
Dear Mr. Pxk1e:
On behalf of the US Environmental Protection Agency's (EPA) campus located in Research
Triangle Ptrk, North Carolina, I am requesting a determination from your office regarding the
applicabilil y of a NPDES Stormwater Permit for our site.
EPA's Research Triangle Park (RTP) campus is co -located with the National Institute of
Environmental and Health Sciences OUMS), on a section of federal property in Research
Triangle P;trk. Our two sites jointly share one Resource Conservation and Recovery Act
(RCRA) gmerator identification number. This decision was recommended by NCDENR's
Waste Management Division prior to the construction of EPA's new campus. Our sites also
share a wa ste management storage facility which is permitted as a RCRA Part B storage facility.
As required by regulation for a RCRA storage facility, a NPDES stormwater permit was applied
for and obtained by NIEHS since the storage facility is located near NMHS's central utility
plant. Du ping the last RCRA storage permit renewal, EPA staff questioned the Waste
Managem mrt Division's permit writers whether the RCRA permitted waste bulking moms
located within the EPA main facility would require an additional storm water permit. EPA-RTP
was directed to NCDENR's Office of Water Quality for that determination.
EPA RTP's Senior Management requested a technical site visit by NCDENR stormwater staff,
Mr. Dave Parnell, to review campus activities and operations to recommend any improvements
to our site., conditions in order to achieve a ` ao exposure" certification for stormwater .
management. EPA RTP also has developed and begun implementation of a Stormwater
Managen Lent Plan for the campus.
While our campus continues to improve our management of stormwater, EPA -RI? still seeks a
de;termimadon from your office whether to either continue our work toward "no exposure"
certification or,if we must pursue application for a stormwater permit.

EPA RTP would gladly arrange another site visit from your staff to observe campus
improvements or to further discuss whether a stormwater permit will be required.
If you .have any questions, please feel free to contact our Environmental Compliance Officer,
Cara. Lucas, at (919)541-10$6. ,
Respectfully,
4JeweMorris, Deputy irector
Science and Information.
MaAagement
ORD Designated Safety, Health &
Environmental Management Official

From: Pickle, Ken [mailto:[e-mail]
Sent: Friday, March 28, 207.4,11:43,4M
To: Morris, Jewel
Cc: Parnell, David; Bennett, Bradley; Georgoulias, Bethany; [e-mail]; Randall; Mike
Subject: EPA stormwater permitting at RTP
Hi Jewel,
My apologies for the delay in responding to your questions about NPDES stormwater permitting at your
RTP lab TSD facility. i
. l
in addition to our communications, I have reviewed notes from past -inspection and technical assistance
visits by the Raleigh Regional Office. Based on your verbal descriptions over the phone, and on previous
email correspondence, and on inspection results, we would be receptive to your application and
certification for the No Exposure Exclusion.from Permitting at your RTP lab.
Based on your descriptions of the -site, North Cara i6a`would,apply;:the,federa l NPDES rul ` ;like this:
� ....
* While the RTP Lab activity, is not a captured industrial activity under the federal NPDES program,
youctvirosmaif raomsforwaste labjchernieals"do gualifyasa regulated.facility; based on b6lifying as a
haz wasie!TSD, as you already, knewl er regulati6h'.b North Caraina's Division of Waste Manag'e.ment.
You reported: that materials may be kept in that area for longer than 90 days, while being
aggregated. Periodically -they are re -located to the`NIEHS facility across the lake. The NIEHS facility is
already our stormwater permittee for their TSD operations..
I
f
* We consider that only the immediate area of the haz waste storage rooms is the regulated
facility. Other R&D activities on your campus are not part of the regulated industrial facility. This is
important in light of Cara's report that trial burns of pulverized coal produce ash or other remnants
that may on occasion be exposed. Other exposures may exist on other parts of your campus, as
well. But that exposure is not directly associated -with the regulated industrial facility, the haz waste
TSD.
*
Cara reports that efforts are underway to limit exposures around the campus. That is good, of
course. But as 1 understand the activities at your site, our only regulatory authority is over stormwater
discharges from the TSD facility.
* The TSD rooms are inside the much larger research; building, and I anticipate that the only
industrial materials and activities that might have risk of exposure would be the handling of the haz
waste as it exits the building headed for NIEHS. It seems to me that this is the immediate location where
you need to continue to be vigilant to assure no exposure conditions.
Of course, we commend your continued efforts to reduce exposure on the other parts of your
campus.
Our application form for the No Exposure Exclusion from Permitting is at this location on lour website:
http://portal.ncdenr.org/web/Ir/npdes-stormwater
At the moment our turn -around time on No Exposure applications is pretty quick,.probably less than a
month.

f -�
Please 'contactlme if I can help further. I apologize again for the delayon=rnydesk,
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR E DEMLR I Stormwater Permitting, Program
1612 Mail Service Center, Raleigh, NC 27699-1612
512 U. Salisbury St, Raleigh, NC 27604
k
Phone: (919);80776376
Fax: [phone]
Email: [e-mail]
Website: http: /portal.iicdenr.org/Web/Ir/stormwater
** •Email correspondence to. and:.from�this address issubje6-t,6torthe NortK�Caraina:Public Records Law,-.
an6:may. EbeAiselo_ sed to third parties ur less;the,conientiis ez6mpt by statute<or>pther regulatidns **.:.,.
}

1 &W
f� OV
Division of Water Quality 1 Surface Water Protection
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
. JUL 2• R 201;
NO EXPOSURE CERTIFICATION
J=I R QUALITY
National Pollutant Discharge Elimination System application for exclusion from a Stormy r'fdrdr*M MNIACT_i'—
on NO EXPOSURE:
FOR AGENCY USE ONLY
Date Received
Year
Month
Da
( ". ilkao of Vera ec-t r
I -1 t
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial -materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DWQ must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
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 seated, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater 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, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
You are required to self re -certify your No Exposure Exclusion annually.
For questions, please contact the DWQ Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name Environmental Protection Agency, Research Triangle Park
Contact Peter Johnson
Street Address 109 T.W. Alexander Drive
City ' Research Triangle Park State NC ZIP Code
Telephone No. [phone] Fax: [phone]
Email [e-mail]
em leu0i8e4 g6jW l bN3O ON
Page t of 7
SWU-NE-12Aug2010

NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Environmental Protection Agency, Research Triangle Park
Facility Contact Shawn Lafferty
Facility Street Address 109 TW Alexander Drive
City Research Triangle Park State NC
County Durham
Telephone No. [phone] Fax: (919)
Email [e-mail]
ZIP Code 27711
685-3449
3) 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). Facility is bordered byTW Alexander Drive (SR-2028) to the west, NC-147 to
the east, Hopson Rd. (SR-1978) to the south, and an abandoned former spur of NC-147 to the north.
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) is the facility located on Native American Lands? [-I Yes )] No
5) Is this a Federal facility? 0 Yes ❑ No
6) Latitude 35, 52, 56.8668 Longitude 78.52. 21.5364 (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility
[Z] Existing
Date operation is to begin _
Date operation began 2001
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes p No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 8 7 3 3
10) Provide a brief description of the types of industrial activities and products produced at this facility:
EPA-RTP is a research laboratory, with associated facility and administrative support. No products are produced at this facility.
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
❑ No
El Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Hazardous waste Management Permit, (shared with NIEHS) NC2750890004-R2
" Underground Storage Tank Permits, 20130652401, 20130652901, 20120753601
Industrial User Permit, County of Durham, DCL-034
' Air Permit (shared with NIEHS), No. 04226R29
VI u 3 0 ,c if Page2of7
SWU-NE-12Aug2010
J

NCGNE0000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) 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 for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑Yes O 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 O No
c. Materials or products from past industrial activity ❑ Yes ONo
d. Material handling equipment (except adequately maintained vehicles) ❑ Yes O No
e. Materials or products during loading/unloading or transporting activities ❑Yes ONo
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes p 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 O No
and similar containers
h. Materials or products-handled/stored on roads or railways owned or maintained by ❑Yes O No
the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑Yes ONo
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes D No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑Yes O 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 ONo
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes O No
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or OYes ❑ No ❑N/A
deterioration, or evidence of leaks?
b. Is secoridary containment provided for all exterior ASTs? If so, is it free of any [Z]Yes ❑ No ❑NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
Page 3of7
SW U-NE-12Aug2010

NCGNE00O0 No. Exposure Certification
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for all single above ground storage
containers (including drums, barrels, etc.) with a capacity of more than 660-
gallons?
b. Is secondary containment provided for above ground storage containers stored
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title ill Section 313 Superfund
Amendments and Reauthorization Act (SARA) water priority chemicals'?
d. Is secondary containment provided for hazardous substances— designated in 40
CFR §116?
e. Are release valves on all secondary containment structures locked?
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
b. Is this facility a Small Quantity Generator (less than 1000 kg, of hazardous waste
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Tvne(s) of waste: solvents, toxic, and corrosive materials from research operations
How is material stored: Indoors, in containers less than or equal to 55 gal., in secondary containment
Where Is material stored: Research labs and two waste handling locations, alk indoors
How many disposal shipments per year: Aprx.4 shipments per year
Name of transport / disposal vendor: veora Es Technical solutions
Vendor address: 2176 will Suitt Road, Creedmoor, NC 27522
Footnotes to Questions 14) c. & d.
✓❑Yes ❑No ❑NIA
❑Yes ❑No ❑NIA
❑Yes ❑No ✓❑NIA
❑Yes [:]No ✓❑NIA
DYes [:]No ❑NIA
DYes ❑ No
❑ Yes ❑✓ No
❑✓ Yes [:]No
'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,
Page 4 of 7
SWU-NE-12Aug2010

NCGNE0000 No Exposure Certification
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes 0 No
b. Does your facility have coal piles on site?
c. Does your facility store other fuel sources outside in piles, such as wood chips,
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g.,
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?
Please; specify:
l f. Please,list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Notes: See attached supporting documentation.
❑Yes ONO
❑Yes [Z] No
❑ Yes ENO
❑Yes ❑No EIN/A
Page 5of7
SwU-NE-12Au92010

NCGNE0000 No Exposure Certification
17) 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 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, it requested, submit the 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 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.
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: Peter Johnson
Title: Director, Office of Administration and Resource Management
Applicant)
�lt�rl
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
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 tact 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).
There is currently no fee for a No Exposure Exclusion.
Page 6 of 7
S W U-N E-12Aug2010

Bm* Bramh
I
f
Burdc Creek
fr
a
�
n
�
' � r
r
PIN Number:0737-04-66-4416
Acreage:500.23500000
Deed Book:000336
Plat Book: 000057
Subdivision: N/A - NO SUBDIVISION
Owner Name: UNITED STATES OF
AMERICA
Quick Information
Parcel ID: 178490
Land Use: IND/ ENVIRONMENTAL SCI
Deed Page: 000300
Plat Page: 000092
Site Address: 109 T W ALEXANDER DR
Owner Address: ATTN US ARMY CORP OF
ENGINEERS
11405 FALLS OF THE NEUSE RD
WAKE FOREST, NC, 27587

Hazardous Waste Storage Facility at EPA-RTP
The EPA shares a hazardous waste storage permit (NC2750890004-R2) with NIEHS as we both reside on
one tract of'ffederally owned land. Under this permit, we have two rooms in the EPA Administration and
Research Building that are permitted storage areas. These 2 rooms are completely enclosed, climate
controlled and are not exposed to any weather. The only activities conducted in these rooms are
consolidation of wastes (primarily solvents and aqueous wastes) from small containers (4-liter or less) to
55-gallon drums, and short-term storage of these drums.
Once these drums are filled, they are loaded directly onto an enclosed box truck and transferred to the
main Hazardous.Waste Storage Facility on the NE1HS side of the campus. This storage facility is covered
under an Individual Stormwater Permit (NCS000360). These transfers occur roughly every 45 days.
At no time are any wastes left outdoors where they would be exposed to any stormwater.

From: Pickle,, Ken [mailto:[e-mail]]
Sent: Friday, March 28, 2014 11:41 AM
To: Morris, Jewel
Cc: Parnell, David; Bennett, Bradley; Georgoulias, Bethany; [e-mail]; Randall, Mike
Subject: EPA,�stormwater permitting at RTP
Hi Jewel,
My apologieIs for the delay in responding to your questions about NPDES stormwater permitting at your
RTP lab TSD-facility.
I
in addition to our communications, I have reviewed notes from past inspection and technical assistance
visits by the' Raleigh Regional Office. Based on your verbal descriptions over the phone, and on previous
email correspondence, and on inspection results, we would be receptive to your application and
certification for the No Exposure Exclusion -from Permitting at your RTP lab.
Based on your descriptions of the site, North Caraina would apply the federal NPDES rules like this:
* While the RTP Lab activity is not a captured industrial activity under the federal NPDES program,
your two small rooms for waste lab chemicals do qualify as a regulated facility, based on qualifying as a
haz waste TSD, as you already knew per regulation by North Caraina's Division of Waste Management.
You reported that materials may be kept in that area for longer than 90 days, while being
aggregated. Periodically they are re -located to the NIEHS facility across the lake. The NIEHS facility is
already our stormwater permittee for their TSD operations.
* We consider that only the immediate area of the haz waste storage rooms is the regulated
facility. Other R&D activities on your campus are not part of the regulated industrial facility. This is
important yin light of Cara's report that trial burns of pulverized coal produce ash or other remnants
that may on occasion be exposed. Other exposures may exist on other parts of your campus, as
well. But that exposure is not directly associated with the regulated industrial facility, the haz waste
TSD.
* Cara reports that efforts are underway to limit exposures around the campus. That is good, of
course. But as I understand the activities at your site, our only regulatory authority is over stormwater
discharges from the TSD facility.
* The TSD rooms are inside the much larger research building, and 1 anticipate that the only
industrialimaterials and activities that might have risk of exposure would be the handling of the haz
waste as it exits the building headed for NIEHS. It seems to me that this is the immediate location where
you needito continue to be vigilant to assure no exposure conditions.
Of course, we commend your continued efforts to reduce exposure on the other parts of your
campus.
Our application form for the No Exposure Exclusion from Permitting is at this location on our website:
http://portal.ncdenr.org/web/Ir/npdes-stormwater
At the moment our turn -around time on No Exposure applications is pretty quick, probably less than a
month. ,

Please contact me if I can help further. I apologize again for the delay on my desk.
Best Regards,
Ken
Ken Pickle
Environmental Engineer
NCDENR I DEMLR I 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/web/ir/stormwater
** Email correspondence to and from this address is subject to the North Caraina Public Records Law
and may be disclosed to third parties unless the content is exempt by statute or other regulations."