HomeMy WebLinkAboutNCG060105_Emails RE ROS with 2014 ROS Request_20210727Georgoulias, Bethany
From: Georgoulias, Bethany
Sent: Tuesday, July 27, 2021 10:16 AM
To: David Schaefer
Cc: McCoy, Suzanne
Subject: RE: [External] FW: GSK Zebulon Certificate NCG060105 - Representative Outfall Status
David,
I'm sorry the response has been delayed. We just lost our General Permit coordinator who was handling general permit
inquiries, but another one should be hired soon. Suzanne McCoy who handles ROS requests is out until Thursday. I
would recommend making a formal request to renew the ROS status and sending that to Suzanne, who has a procedure
to route it through the Regional Office. This would be the best way to cover your bases in the meantime.
Best,
Bethany Georgoulias
Environmental Engineer
Stormwater Program, Division of Energy, Mineral, and Land Resources
N.C. Department of Environmental Quality
919 707 3641 office
bethany.georgoulias@ncdenngov
512 N. Salisbury Street, Raleigh, NC 27604 (location)
1612 Mail Service Center, Raleigh, NC 27699-1612 (mailing)
Website: http://deq.nc.gov/about/divisions/energy-mineral-land-resources/stormwater
D, E�
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From: David Schaefer [mailto:david.x.schaefer@gsk.com]
Sent: Tuesday, July 27, 2021 8:55 AM
To: Georgoulias, Bethany <bethany.georgoulias@ncdenr.gov>
Subject: [External] FW: GSK Zebulon Certificate NCG060105 - Representative Outfall Status
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Hi Bethany,
Sorry to bother you, but I had not yet received a response to the email below. Can you comment on whether we would
be able to retain our representative outfall status? Our first sampling of the quarter I may have to complete very soon
so I was hoping to clear this up.
I'm assuming if we can, I should also send this request in writing.
Thanks,
Dave Schaefer
GSK Zebulon
From: David Schaefer
Sent: Monday, July 19, 2021 3:58 PM
To: Lucas, Annette <annette.lucas@ncdenr.gov>
Cc: McCoy, Suzanne <suzanne.mccov@ncdenr.gov>
Subject: GSK Zebulon Certificate NCG060105 - Representative Outfall Status
Hello,
I was reading the overview slides for the updated stormwater permits including NCG060000 Food and Kindred. I noticed
that the slides mentioned confirming with NCDEQ that representative outfall status was renewed with the new permits
and certificates.
I had not yet made any formal requests to this point to extend our representative outfall status, but I did mention it in
my email to sign up for eDMRs.
Can you confirm if our ROS status can be renewed for the duration of the next certificate (or beyond)?
I have attached the initial request for ROS status granted in 2014 by David Parnell. This was confirmed via phone or
email with NCDEQ to be renewed as an ROS for the previous two Certificates as well (most recently in 2018). While I
have updated the current state of total outfalls to correct what was submitted then, I can confirm that our outfall
number 5 includes all possibilities of activity that would make it a representative outfall.
Also, I noticed in the slides that an ROS could also be granted for qualitative monitoring as well in wake of the new
quarterly analytical requirements. While I do not see a form to be used to make this request, I'd be very interested in
making this change also.
I can also submit this request in writing to NCDEQ, however I was awaiting your guidance as to any official forms that
must be submitted if needed or if only a written request to renew was sufficient.
Thanks for your assistance,
David Schaefer, CHMM
EHS Engineer
Safety
Manufacturing
GSK
1011 N Arendell Ave
Zebulon, NC 27597
Email david.x.schaefera-gsk.com
Tel +1 919 269 1966
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IMA
NCDENR
NORTH CAROLINA DFFARTMENT OF
ENVIRONMENT AND NATURAL RESOURCES
Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
REPRESENTATIVE OUTFALL STATUS (ROS)
REQUEST FORM
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall 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 Storm water 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)
N C S
2) Facility Information:
Owner/Facility Name: GlaxoSmithl<line - Zebulon
Certificate of Coverage
N C G 0 6 0 1 0 5
Facility Contact John Bolla, Site Director
Street Address 1011 N Arendell Ave
City Zebulon State NC ZIP Code 27597
County WAKE E-mail Address Melanie.x.szvdlik-hawkes@gsk.com
Telephone No. (919)269-5000 Fax:
3) List the representative outfall(s) information (attach additional sheets if necessary):
Outfall(s)
5
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s) 5 is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s)
❑ Yes
❑ No
❑ Yes
❑ No
❑ Yes
❑ No ❑ No data*
1A
❑ Yes
❑ No
❑ Yes
❑ No
❑ Yes
❑ No ❑ No data*
is representative of Outfall(s) 2
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No ❑ No data*
Page 1 of 4
SWU-ROS-2009 Last revised 12/30/2009
Representative Outfall Status Request
Outfall(s) 5 is representative of Outfall(s) 3
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) 5 is representative of Outfall(s) 4
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) 5 is representative of Outfall(s) 6
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) 5 is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
7
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No ❑ No data*
Outfall(s) 5 is representative of Outfall(s) 8
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) 5 is representative of Outfall(s) 9
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
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.
During an audit of the program, documentation could not be found granting Representative Outfall
Status. Melissa Seguin, EHS Contractor for GlaxoSmithl<line contacted David Parnell with the NCDENR
/DEMLR to request a copy of the approved ROS. Mr. Parnell indicated that he could not find a copy of the
original approval but did see documentation from a 2012 NCDENR DWQ Compliance Evaluation Inspection
indicating that GlaxoSmithKline was granted Representative Outfall Status for the permit (See attached).
Mr. Parnell agreed that GlaxoSmithl<line should make another request for ROS based on the fact that
neither office has an actual ROS on file or a copy of an approved ROS. Additional sampling will not be
needed unless this ROS is not approved and granted prior to the 2014 —Year 2, Period 2 Sampling Period
which ends on 31 December 2014. During an upcoming visit, Mr. Parnell has agreed to help us reassess our
outfalls to determine if another outfall should be added to our ROS sampling strategy.
Page 2 of 4
SWU-ROS-2009 Last revised 12/30/2009
Representative Outfall Status Request
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).
I 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: JOHN J. BOLLA kA/-l/LLB iV/6_ c721F- &/J`
Title: SITE DIRECTOR, GLAXOSMITHI<UNE ZEBULON EaiGM/�i cJ/_�E �4vTpf 3�2C
(Signature of Applicant)
(Date Signed)
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.
❑ 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.
Page 3 of 4
SWU-ROS-2009 Last revised 12/30/2009
Representative Outfall Status Request
For questions, please contact the DWQ Regional Office for your area.
Asheville Regional Office
2090 U.S. Highway 70
Washington Regional Office
Swannanoa, NC 28778
943 Washington Square Mall
Washington, NC 27889
Phone (828) 296-4500
FAX (828) 299-7043
Phone (252) 946-6481
FAX (252) 975-3716
Fayetteville Regional Office
Systel Building,
Wilmington Regional Office
225 Green St., Suite 714
127 Cardinal Drive Extension
Fayetteville, NC 28301-5094
Wilmington, NC 28405
Phone (910) 433-3300 Phone (910) 796-7215
FAX 910/ 486-0707 FAX (910) 350-2004
Mooresville Regional Office
Winston-Salem Regional Office
610 East Center Ave.
585 Waughtown Street
Mooresville, NC 28115
Winston-Salem, NC 27107
Phone (336) 771-5000
Phone (704) 663-1699
Water Quality Main FAX (336) 771-4630
FAX (704) 663-6040
Central Office
Raleigh Regional Office
1617 Mail Service Center
1628 Mail Service Center
Raleigh, NC 27699-1617
Raleigh, NC 27699-1628
Phone (919) 807-6300
Phone (919) 791-4200
FAX (919) 807-6494
FAX (919) 571-4718
Page 4 of 4
SWU-ROS-2009 Last revised 12/30/2009
TFM00185
VERSION 1
Page 1 of 1
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Responsible Individual: (Print Name):
Title:
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Delegate: (Print Name):
Title:
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Date responsibility Starts:
Date responsibility Ends:
4
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Note: Temporary signature authority should not exceed 30 business days.
The responsible individual, by signature below, hereby delegates the authority to execute, review,
amend, authorize, or approve on behalf of GSK any documents relevant to each specific area of
responsibility as noted in the following table. The delegate may not re -delegate this temporary
authority.
Activity/Job Function.
Che all that apply
Policy -related categories, long term only
GMP documents, five business days
SAP approvals, five business days
Other, describe:
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Responsible Individual's Signature:
Initials:
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Assigned Delegate's Signature:
Initials:
Date: