WQ0034603_Correspondence_20220729

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Plummer,Lauren
From:[e-mail]
Sent:Friday, July 29, 2022 2:26 PM
To:Plummer,Lauren
Cc:[e-mail]; [e-mail]
Subject:RE: [External] Questions on the reclaimed permit draft
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Great, thanks Laura! I appreciate you responding so quickly to our questions and comments. Please remove Site 2 from
the permit.

Have a wonderful weekend!

Anne Marie
Anne Marie C. Baese
EHS Specialist
Environmental Health & Safety
Seqirus – A CSL Company
475 Green Oaks Parkway, Holly Springs, NC 27540, USA
Mobile [phone]

From: Plummer,Lauren <[e-mail]>
Sent: Friday, July 29, 2022 2:22 PM
To: Baese, Anne Marie US/HSP <[e-mail]>
Cc: Lorusso, Ellen US/KOP <[e-mail]>; Rezek, Robert US/HSP <[e-mail]>
Subject: [EXT] RE: [External] Questions on the reclaimed permit draft

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unless you trust the sender and know the content is safe.

Anne Marie,

As I mentioned in the voicemail I left this afternoon, the ORC comment is a standard comment for all non-discharge
facilities. At present, WPCSOCC does not require conjunctive utilization permits to designate an ORC; however, this
condition is included should the regulations change during the next permit cycle. The operator requirements are
handled by a different unit (WPCSOCC). Regarding your second question, we will remove the reference to the NDAR-1
form from Condition IV.4. The monthly NDAR-1 form will not need to be submitted.

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Lastly, Site 2 (the cooling tower and boiler washdown) can be removed from this permit using the above email as your
formal request. Please note, the Non-Discharge Branch will require a major modification application submittal to add
Site 2 back to the permit if required at a future date.

Please let me know if you have any further questions or if you wish for Site 2 to remain in the permit. I am hoping to get
this permit in the queue for final review and issuance as soon as possible.

Thank you,

Lauren Raup-Plummer, PE
Environmental Engineer III
Non-Discharge Branch
Department of Environmental Quality

919-707-3660 office
[e-mail]

512 N. Salisbury St
1617 Mail Service Center
Raleigh, NC 27699-1617

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North Carolina Public Records Law and may be disclosed to third parties.

Effective May 11, 2022, the Non-Discharge Branch is at half-staff. As a result, our response and review times will be
slower than normal. Thank you in advance for your patience.

From: [e-mail] <[e-mail]>
Sent: Thursday, July 28, 2022 2:44 PM
To: Plummer,Lauren <[e-mail]>
Cc: [e-mail]; [e-mail]
Subject: [External] Questions on the reclaimed permit draft

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Report Spam.

Hi Lauren,

Upon reviewing the permit draft, we have a few questions on some text.
1. Can you explain what is meant by “certified operator in responsible charge”? See below from the permit draft:

3. Upon the Water Pollution Control System Operators Certification Commission’s (WPCSOCC) classification of the
subject non-discharge facilities, the Permittee shall designate and employ a certified operator in responsible charge
(ORC), and one or more certified operators as back-up ORCs. The ORC or their back-up shall operate and visit the
facilities as required by the WPCSOCC. [15A NCAC 02T .0117]

We have previously designated our EHS Director as the ORC; however, he does not have a formal training/certificate in
water pollution control systems. When we viewed the certification information previously, it appeared to only apply to
operators of POTWs. We only use the reclaimed water for irrigation. Please provide clarification on what is needed for
the ORC.

2. Under section IV.4 it states the following:

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Three copies of all monitoring data (as specified in Condition IV.3.) on Form NDMR for each PPI and three copies of all
operation and disposal records (as specified in Condition IV.3) on Form NDAR-1 for every site in Attachment B shall be
submitted on or before the last day of the following month. If no activities occurred during the monitoring month,
monitoring reports are still required documenting the absence of the activity. All information shall be submitted to the
following address:

However, on Attachment B, the footnote states:

“1. Utilization records for these sites are not required to be reported on Form NDAR-1. “

Can you please clarify if we need to submit the NDAR-1 form every month? The section and footnote I referenced seem
to contradict each other.

3. For the use of reclaimed water in cooling tower and boiler washdown, we are no longer using reclaimed water for
this purpose due to unacceptable levels of biological growth that required excessive chemical treatments. Also,
the reclaimed water line to the cooling tower was cut and capped so it can no longer be used. Do we need to keep
the cooling tower and boiler washdown in the permit or can these two areas of use be removed from the permit?

Thank you for your time.

Regards,
Anne Marie
Anne Marie C. Baese
EHS Specialist
Environmental Health & Safety
Seqirus – A CSL Company
475 Green Oaks Parkway, Holly Springs, NC 27540, USA
Mobile [phone]

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