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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� Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. 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 CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to Report Spam. 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 sg k.com I Twitter I YouTube I Facebook I Flickr GSK monitors email communications sent to and from GSK in order to protect GSK, our employees, customers, suppliers and business partners, from cyber threats and loss of GSK Information. GSK monitoring is conducted with appropriate confidentiality controls and in accordance with local laws and after appropriate consultation. 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 Ygmlpaml°y L�MslJ@ofley Responsible Individual: (Print Name): Title: ; 5rtC_ r-CP-1 Delegate: (Print Name): Title: L - 16F4- ,U G S`MU-9Z) A4,01 Date responsibility Starts: Date responsibility Ends: 4 '217 0G7- I q 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: ------------------------------------------------------------------------------------- ------------------------------m------------------ e--o-------------e---------------e--__--e---------e-e--------_---------_-_----_------e--_--------------------_--o---e--------_--------- ---------a__e---e--------------e--------_---------_---------_--------e-_-------------_--_---_----------------_-__-_------e---_--e------ --------------------------------------------------------------------------------------------------------------------------------------- --------------------------------------------------------------------------------------------------------------------------------------- - ---------------ee----e--_--------_----e-_--e-----__---_a----_e--e--------_----_---o_-_-----_-----_---_-e-----.------e-----------e-------------------------------------------------------------------------------------------------------------------------------------------- --------------------------------------------------------------------------------------------------------------------------------------- Responsible Individual's Signature: Initials: Datle- im Z® O C I j 1__"' Assigned Delegate's Signature: Initials: Date: