NCG060175_Tier 2 Sampling Exceedances_20230912

Chandler, Jeffrey A
From:Eplin, Jerry W
Sent:Tuesday, September 12, 2023 1:36 PM
To:Hughes, Megan {PEP}
Cc:Denison, Samantha {PEP}; Canty, Pamela {PEP}; Rose, Tim G {PEP}; Khan, Zahid;
Chandler, Jeffrey A
Subject:RE: \[External\] Tier 2 Sampling Exceedances - NCG060175
Understood. We will place in the file.

Jerry W. Eplin, PE
Assistant Regional Engineer

North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources

Office: [phone] x2147
Email: [e-mail]

Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

From: Hughes, Megan {PEP} <[e-mail]>
Sent: Thursday, September 7, 2023 2:14 PM
To: Eplin, Jerry W <[e-mail]>
Cc: Denison, Samantha {PEP} <[e-mail]>; Canty, Pamela {PEP} <[e-mail]>;
Rose, Tim G {PEP} <[e-mail]>; Khan, Zahid <[e-mail]>; Chandler, Jeffrey A
<[e-mail]>
Subject: RE: \[External\] Tier 2 Sampling Exceedances - NCG060175

CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
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Hi Jerry,

There was a miscommunication on the COD levels listed below for Outfall 3. The actual COD level for Outfall 3 from this
sampling date was 112 mg/L instead of 123 mg/L, so it is actually under the benchmark of 120 mg/L. Since there was not
actually a sampling exceedance at Outfall 3, it would still be under Tier I status and needs only two more samples under
the benchmark to remove the Tier I status.
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Apologies for the incorrect data. Let me know if there is any more information you need on this.

Thank you,

Megan Hughes

“Be smart hydrate from the start”
- Jerome Barber 2023

Environmental Health & Safety SCL
Frito Lay | PepsiCo, Inc.
2911 Nevada Blvd. Charlotte, NC 28273
Cell: 317-459-7955
[e-mail]

From: Eplin, Jerry W <[e-mail]>
Sent: Thursday, August 17, 2023 4:14 PM
To: Hughes, Megan {PEP} <[e-mail]>
Cc: Denison, Samantha {PEP} <[e-mail]>; Canty, Pamela {PEP} <[e-mail]>;
Rose, Tim G {PEP} <[e-mail]>; Khan, Zahid <[e-mail]>; Chandler, Jeffrey A
<[e-mail]>
Subject: RE: \[External\] Tier 2 Sampling Exceedances - NCG060175

WARNING: Email originated outside of PepsiCo.
Thank you for your response. We will place this information in your file. Please let us know if you require our
assistance.

Jerry W. Eplin, PE
Assistant Regional Engineer

North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources

stth
DEQ is upading its email addresses to @deq.nc.gov in phases from May 1 to June 9, 2023.
Employee email addresses may look different, but email performance will not be impacted.

Office: [phone] x2147
Email: [e-mail]

Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115

2

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

From: Hughes, Megan {PEP} <[e-mail]>
Sent: Thursday, August 17, 2023 4:11 PM
To: Eplin, Jerry W <[e-mail]>
Cc: Denison, Samantha {PEP} <[e-mail]>; Canty, Pamela {PEP} <[e-mail]>;
Rose, Tim G {PEP} <[e-mail]>; Khan, Zahid <[e-mail]>
Subject: RE: \[External\] Tier 2 Sampling Exceedances

CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.

Good afternoon,

Yes, the correct COC is NCG060175 and we are of the same understanding on the Tier 1 and 2 information.

We did identify and document potential causes of the exceedances and feasible actions have been implemented for the
Tier 1 response for COD and TSS. Our team is also currently working what’s listed in Table 4 for Tier 2 exceedances.

Thank you,

Megan Hughes

“Be smart hydrate from the start”
- Jerome Barber 2023

Environmental Health & Safety SCL
Frito Lay | PepsiCo, Inc.
2911 Nevada Blvd. Charlotte, NC 28273
Cell: 317-459-7955
[e-mail]

From: Eplin, Jerry W <[e-mail]>
Sent: Wednesday, August 16, 2023 8:15 AM
To: Hughes, Megan {PEP} <[e-mail]>
Cc: Denison, Samantha {PEP} <[e-mail]>; Canty, Pamela {PEP} <[e-mail]>;
Rose, Tim G {PEP} <[e-mail]>; Khan, Zahid <[e-mail]>
Subject: RE: \[External\] Tier 2 Sampling Exceedances

WARNING: Email originated outside of PepsiCo.
Ms. Hughes:

NC DEQ has received the Tier Notification as submitted below. I would like to clarify a couple of issues:

1) You did not provide a permit or COC number for the facility. Based upon file review, I believe the correct COC
number is NCG060175. Is that correct?
2) Assuming that I have the correct COC number, based upon review of your submitted DMRs and the email below,
your facility should be Tier 1 for pH and TSS at Outfall #1, and Tier 2 for COD at Outfalls 1, 2, and 3. Do you have
the same understanding?

3

Did your Tier 1 “Required Responses” for COD and TSS, implemented sometime between March and August, identify any
potential causes of the exceedances, and have any “feasible actions” been implemented?

Likewise, I would like to point you to Table 4 in Section E6 of the NCG060000 permit, which lists the required responses
for Tier Two exceedances, including:
 Conducting a stormwater management inspection
 Identifying and evaluating possible causes
 Selecting and implementing a feasible course of action, and
 Beginning monthly monitoring at all outfalls for all parameters until three consecutive samples are
below the benchmarks (or in range) for all parameters.

Please reply related to my questions above and let me know if you have any other questions or require our assistance.

Regards,

Jerry W. Eplin, PE
Assistant Regional Engineer

North Carolina Department of Environmental Quality
Division of Energy, Mineral, and Land Resources

stth
DEQ is upading its email addresses to @deq.nc.gov in phases from May 1 to June 9, 2023.
Employee email addresses may look different, but email performance will not be impacted.

Office: [phone] x2147
Email: [e-mail]

Physical and Mailing Address:
610 E. Center Ave. Suite 301
Mooresville, NC 28115

Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties

From: Khan, Zahid <[e-mail]>
Sent: Tuesday, August 15, 2023 5:57 PM
To: Hughes, Megan {PEP} <[e-mail]>; Eplin, Jerry W <[e-mail]>
Cc: Denison, Samantha {PEP} <[e-mail]>; Canty, Pamela {PEP} <[e-mail]>;
Rose, Tim G {PEP} <[e-mail]>
Subject: RE: \[External\] Tier 2 Sampling Exceedances

Jerry,
Please response. Thanks

4

From: Hughes, Megan {PEP} <[e-mail]>
Sent: Tuesday, August 15, 2023 2:14 PM
To: Khan, Zahid <[e-mail]>
Cc: Denison, Samantha {PEP} <[e-mail]>; Canty, Pamela {PEP} <[e-mail]>;
Rose, Tim G {PEP} <[e-mail]>
Subject: \[External\] Tier 2 Sampling Exceedances

CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.

Good afternoon Zahid,

I had reached out back in March for a Tier 1 response related to some outfall sampling exceedances at our Charlotte
Frito Lay facility. Our second consecutive sampling results came August 14 also showing some exceedances, so I am
reaching out now for our Tier 2 Response in accordance with our permit.

The results from the samples taken 8/3/2023 reported exceedance values for COD of 599 mg/L, 823 mg/L, and 123
mg/L at Outfalls 001, 002, and 003 and a 5.66 pH at Outfall 001.

Please let me know if there is anything else you need from me for these Tier 2 responses.

Thank you,

Megan Hughes

“Be smart hydrate from the start”
- Jerome Barber 2023

Environmental Health & Safety SCL
Frito Lay | PepsiCo, Inc.
2911 Nevada Blvd. Charlotte, NC 28273
Cell: 317-459-7955
[e-mail]

Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third parties by an authorized
state official.
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