NCG060112_Representative Outfall Status Initial Request_20240220

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93
2055 Sugarloaf Circle I Suite 175 T 770.628.2846
Duluth, Georgia 30097 T 770.285.9007
www.woodardcurran.com
Via Electronic Mail
January 17, 2024
North Carolina Department of Environmental Quality
Woodard Winston-Salem Regional Office
& Curran 450 West Hanes Mill Road, Suite 300
Winston-Salem, North Carolina 27105
Re: ROS Request Form —Certificate of Coverage: NCG060112
NPDES NCG060000 Permit Coverage
Nestle Purina PetCare Company
The Nestle Purina PetCare Company(NPPC) Eden Plant requests that Outfall 002 be considered
representative of Outfall 003. The industrial activities conducted within the drainage area
associated with Outfall 003 are also conducted within the drainage area associated with Outfall
002. Additionally, the materials handled within the drainage area associated with Outfall 003
are also handled within the drainage area for Outfall 002.Therefore, any stormwater discharges
from these drainage areas would be deemed substantially identical.
On behalf of the permittee, NPPC, please find attached the completed Representative Outfall
Status (ROS) Request Form as well as two copies of the 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. As noted on the ROS Request Form,
analytical monitoring data is not available at this time because the Eden Plant is in the final
stages of construction and has not begun operations.
If you have any questions concerning this request and/or supporting documents,please contact
Cherjuana Crawford at 770-628-2846 or Alex Hill at 770-285-9007. Thank you for your time in
reviewing this material.
Sincerely,
WOODARD &CURRAN INC.
a , 4 ca0146.eat
ALEX HILL, CPESC, EIT CHERJUANA CRAWFORD, CHMM, CPEA
Environmental Engineer Project Manager

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93
ATTACHMENT A: REPRESENTATIVE OUTFALL STATUS REQUEST FORM
Woodard
& Curran
Nestle Purina PetCare Company(0233208.09) 2 Woodard &Curran, Inc.
ROS Request January 17, 2024

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93
FOR AGENCY USE ONLY
Division of Energy, Mineral & Land Resources Date Received
;,.. Year Month Day
Stormwater Program
, National Pollutant Discharge Elimination System
Environmental REPRESENTATIVE OUTFALL STATUS (ROS)
Quality REQUEST FORM
If a facility is required to sample multiple discharge locations with very similar storm water discharges, the
permittee may petition the Director for Representative Outfall Status(ROS). DEQ may grant Representative
Outfall Status if storm water 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 DEQ
approval. The approval letter from DEQ must be kept on site with the facility's Stormwater Pollution
Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status.
For questions, please contact the DEQ 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) Certificate of Coverage
N C S N C G 0 6 0 1 1 2
2) Facility Information:
Owner/Facility Name Nestle Purina PetCare Company
Facility Contact William Steiner
Street Address 863 E Meadow Rd
City Eden State NC ZIP Code 27288-3636
County Rockingham E-mail Address [e-mail]
Telephone No. 816 676-8003 Fax:
3) List the representative outfall(s) information (attach additional sheets if necessary):
Outfall(s) 002 is representative of Outfall(s) 003
Outfalls' drainage areas have the same or similar activities? o Yes co No
Outfalls' drainage areas contain the same or similar materials? o Yes a No
Outfalls have similar monitoring results? o Yes a No ©No data*
Outfall(s) is representative of Outfall(s)
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) is representative of Outfall(s)
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.
Page 1 of 3
SWU-ROS-2009 Last revised 12/30/2009

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93
Representative Outfall Status Request
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.
In the development of the SWPPP,the facility has identified four outfalls(Outfalls 001,002,003,and 004)that discharge stormwater
associated with industrial activities.In accordance with the facility's NPDES General Permit(NCG060000),sampling for analytical monitoring
would be required at all four outfalls.This form is to request that Outfalls 002 and 003 be granted representative outfall status(ROS),where
Outfall 002 would be considered representative of Outfall 003.Therefore,samples collected at Outfall 002 would be considered
representative of samples collected at Outfall 003.The following industrial activities are conducted in the drainage area that discharges to
Outfall 002:Loading and Unloading—Slurry Receiving;Slurry Waste Tank Unloading;Grain/Meal Silo Unloading;Loading and Unloading—
Liquid Receiving;Dye Waste Tank Unloading;Salt Brine Saturated Tank Loading and Unloading;Loading and Unloading—
Trash/Pallet/Recycling;Transformers;Loading and Unloading—Dry Ingredients/Finished Goods/Maintenance;Outdoor Material Storage,
and Outdoor Roll-off Storage.The following industrial activities are conducted in the drainage area that discharges to Outfall 003:Loading
and Unloading—Trash/Pallet/Recycling and Loading and Unloading—Dry Ingredients/Finished Goods/Maintenance.Thus,all the industrial
activities and outdoor material handling that is conducted within the drainage area for Outfall 003 are also conducted within the drainage
area that discharges to Outfall 002.
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 DEQ 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 N
ame of Person Signing: William Steiner
ALUM Sk i. 2/19/2024
37CA9DF83DAC45B...
(Signature of Applicant) (Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ 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.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30/2009

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93
Representative Outfall Status Request
Mail the entire package to:
NCDEQ DEMLR 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 DEQ. 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.
For questions, please contact the DEQ Regional Office for your area.
Win • Sale 1�
s/L „ r \
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Wil , ngton
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa, NC 28778 Washington Regional Office
943 Washington Square Mall
Phone [phone] Washington, NC 27889
FAX [phone]
Phone [phone]
Fayetteville Regional Office FAX [phone]
Systel Building,
225 Green St., Suite 714 Wilmington Regional Office
Fayetteville, NC 28301-5094 127 Cardinal Drive Extension
Wilmington, NC 28405
Phone [phone]
FAX [phone] Phone [phone]
FAX [phone]
Mooresville Regional Office
610 East Center Ave. Winston-Salem Regional Office
Mooresville, NC 28115 585 Waughtown Street
Winston-Salem, NC 27107
Phone [phone] Phone [phone]
FAX [phone] Water Quality Main FAX [phone]
Raleigh Regional Office Central Office
1628 Mail Service Center 1612 Mail Service Center
Raleigh, NC 27699-1628 Raleigh, NC 27699-1612
Phone [phone] Phone [phone]
FAX [phone] FAX [phone]
Page 3 of 3
SWU-ROS-2009 Last revised 12/30/2009

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93
ATTACHMENT B: SITE MAPS
Woodard
& Curran
Nestle Purina PetCare Company(0233208.09) 3 Woodard &Curran, Inc.
ROS Request January 17, 2024

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93 PLOT SCALE:10::
� POTENTIAL POLLUTANT SOURCES
1 / Ilr ir NO. ACTIVITY
1 LOADING AND UNLOADING-SLURRY RECEIVING
_ SURFACE SURFACE 2 SLURRY WASTE TANK UNLOADING
/ IMPOUNDMENT IMPOUNDMENT 3 GRAIN/MEAL SILO UNLOADING
/, 1 2 4 LOADING AND UNLOADING-LIQUID RECEIVING
/✓ 07 5 DYE WASTE TANK UNLOADING® �+ Woodard
0
6 SALT BRINE SATURATED TANK LOADING AND UNLOADING
k.,
le
/ -- 7 RAIL CAR UNLOADING-DRY INGREDIENTS
8 RAIL CAR UNLOADING-LIQUID INGREDIENTS
9 RAIL CAR STAGING-DRY AND LIQUID INGREDIENTS
J 10 LOADING AND UNLOADING-TRASH/PALLET/RECYCLING 2055 Sugarloaf Circle,Suite 175
11 FIRE PUMP DIESEL TANK LOADING Duluth,Georgia 30097
12 OPERATION OF DOUBLE CELLED COOLING TOWERS 770.622.6766 www.woodardcurran.com
13 DUKE ENERGY SUBSTATION
WATERSHED 6 14 OPERATION OF THE WWPT FACILITY
15 OPERATION OF THE WWPT FACILITY CHEMICAL STORAGE ROOM & Curran
— , 16 DIESEL GENERATOR THIS DOCUMENT IS THE PROPERTY
17 OUTDOOR REFRIGERATED TRAILER PARKING OF WOODARD&CURRAN AND ITS
19 ' , 18 LOADING AND UNLOADING-DIESEL TANK
�� r 19 TRANSFORMER CLIENT. ON WITHOUT
IT
MODIFICATION WITHOUT WRITTEN
OUTFALL 004 20 LOADING AND UNLOADING-DRY INGREDIENTS/FINISHED GOODS/MAINTENANCE PERMISSION IS PROHIBITED.
21 OUTDOOR MATERIAL STORAGE
BASIN 4 v / �� 22 OUTDOOR ROLL-OFF STORAGE
RAVEL Ro.o 7 j/ o I 23 TRUCK AND TRAILER PARKING PE SEAL:
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I L o EDEN PLANT
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a i , WATER HOUSE sK � /p JOB NO: 0233208.09
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/i� DATE NOVEMBE
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v m"`"s SURFACE I•:•�� Mt 1 MI /
Q IMPOUNDMENT ••� � Y 0 :
c 3 /:.. ,�7 m I DESIGNED BY: ARH
4,1412*
-- -i--____ a DRAWN BY: ARH
m I RAIDLCAR `� CHECKED BY: CCC
rn / \' UNLOADING =
N - 11 FILENAME:0233208.09_SITE MAP.dwg
o AVEL ROAD
ILROA..f, TRACKS /4/`� \ ` I WATERSHED 5
v \ 1R LEGEND DRAWING TITLE:
# POTENTIAL POLLUTANT SOURCES
L ' WATERSHED 3 j SITE MAP
v RAVEL ROAD
SK SPILL KIT
0 rES y 1 j O
-C DRAINAGE AREA
-. 1
c c� STORMWATER RETENTION POND
c ��
So— STORMWATER SEWER SYSTEM
V _ BASIN 3 .-- OUTFALL 001 J
APPROXIMATE DIRECTION OF FLOW12 o DRAWING NO:
o \ NHD STREAM
EMEADOWROAD FIGURE 2
DITCH LINE
SHEET: 1 OF 01
SOURCES:DRAWING(.DWG)FILE TITLED"GARDENKEEPER 23-0517",GOOGLE EARTH AERIAL IMAGERY,AND USGS NATIONAL HYDROGRAPHY DATASET L I PAVED SURFACE

DocuSign Envelope ID:2E0EB6CD-55DC-44C6-ABDB-FD63C7793C93 PLOT SCALE:10::
� POTENTIAL POLLUTANT SOURCES
1 / Ilr ir NO. ACTIVITY
1 LOADING AND UNLOADING-SLURRY RECEIVING
_ SURFACE SURFACE 2 SLURRY WASTE TANK UNLOADING
/ IMPOUNDMENT IMPOUNDMENT 3 GRAIN/MEAL SILO UNLOADING
/, 1 2 4 LOADING AND UNLOADING-LIQUID RECEIVING
/✓ 07 5 DYE WASTE TANK UNLOADING® �+ Woodard
0
6 SALT BRINE SATURATED TANK LOADING AND UNLOADING
k.,
le
/ -- 7 RAIL CAR UNLOADING-DRY INGREDIENTS
8 RAIL CAR UNLOADING-LIQUID INGREDIENTS
9 RAIL CAR STAGING-DRY AND LIQUID INGREDIENTS
J 10 LOADING AND UNLOADING-TRASH/PALLET/RECYCLING 2055 Sugarloaf Circle,Suite 175
11 FIRE PUMP DIESEL TANK LOADING Duluth,Georgia 30097
12 OPERATION OF DOUBLE CELLED COOLING TOWERS 770.622.6766 www.woodardcurran.com
13 DUKE ENERGY SUBSTATION
WATERSHED 6 14 OPERATION OF THE WWPT FACILITY
15 OPERATION OF THE WWPT FACILITY CHEMICAL STORAGE ROOM & Curran
— , 16 DIESEL GENERATOR THIS DOCUMENT IS THE PROPERTY
17 OUTDOOR REFRIGERATED TRAILER PARKING OF WOODARD&CURRAN AND ITS
19 ' , 18 LOADING AND UNLOADING-DIESEL TANK
�� r 19 TRANSFORMER CLIENT. ON WITHOUT
IT
MODIFICATION WITHOUT WRITTEN
OUTFALL 004 20 LOADING AND UNLOADING-DRY INGREDIENTS/FINISHED GOODS/MAINTENANCE PERMISSION IS PROHIBITED.
21 OUTDOOR MATERIAL STORAGE
BASIN 4 v / �� 22 OUTDOOR ROLL-OFF STORAGE
RAVEL Ro.o 7 j/ o I 23 TRUCK AND TRAILER PARKING PE SEAL:
GUARDHOUSE
_is
_____
_I
1 1 1 1 - '4
.DRA.L -� — SK SK� ;_. . _. .:\._ ------- —
® �m�. —
lift
2, �Iion
WATERSHED 2
I za 04- 03-1!(
CIWAREHOUSE PACKAGING
NORTH -, — 70
WAREHOUSE
Ammr j ._, BASIN 2
Q o, ' OUTFALL 003
E •
j � sK� � m----
•'i BASIN 5 - m STORMWATER POLLUTION
o .��/ PREVENTION PLAN (SWPPP)
c — I
oI 1 = .�sl o2-OFFICE Ym I '� CLIENT INFO:
fV I I _ �r "� _�
o I m I I El ,s ' ❑ 01 NESTLE PURINA PETCARE COMPANY
O RAW PROCESSING BASIN 1 OUTFACE 002
I L o EDEN PLANT
3 �� I sK e! �,�` m m 863 EAST MEADOW ROAD
„ _ �} ' ° " -- 0 EDEN, NORTH CAROLINA
' ■� .-9�0 0� ,o =' GRAIN1 Ie WATERSHED 1
f SILOS :
I 12-DOMESTIC•r %
✓ S,
a i , WATER HOUSE sK � /p JOB NO: 0233208.09
'ir l J �.. 1// o .1 — -sas �M I R 2023
/i� DATE NOVEMBE
RAI.o. - ® , aiiirfi �T SCALE: 1" = 375'
v m"`"s SURFACE I•:•�� Mt 1 MI /
Q IMPOUNDMENT ••� � Y 0 :
c 3 /:.. ,�7 m I DESIGNED BY: ARH
4,1412*
-- -i--____ a DRAWN BY: ARH
m I RAIDLCAR `� CHECKED BY: CCC
rn / \' UNLOADING =
N - 11 FILENAME:0233208.09_SITE MAP.dwg
o AVEL ROAD
ILROA..f, TRACKS /4/`� \ ` I WATERSHED 5
v \ 1R LEGEND DRAWING TITLE:
# POTENTIAL POLLUTANT SOURCES
L ' WATERSHED 3 j SITE MAP
v RAVEL ROAD
SK SPILL KIT
0 rES y 1 j O
-C DRAINAGE AREA
-. 1
c c� STORMWATER RETENTION POND
c ��
So— STORMWATER SEWER SYSTEM
V _ BASIN 3 .-- OUTFALL 001 J
APPROXIMATE DIRECTION OF FLOW12 o DRAWING NO:
o \ NHD STREAM
EMEADOWROAD FIGURE 2
DITCH LINE
SHEET: 1 OF 01
SOURCES:DRAWING(.DWG)FILE TITLED"GARDENKEEPER 23-0517",GOOGLE EARTH AERIAL IMAGERY,AND USGS NATIONAL HYDROGRAPHY DATASET L I PAVED SURFACE