NCS000136_Fact sheet binder_20240403

DEQ / DEMLR
FACT SHEET FOR NPDES INDUSTRIAL INDIVIDUAL
STORMWATER PERMIT DEVELOPMENT
Basic Information for Permit Issuance and Renewals:
Permit Writer/Date Brianna Young 3/25/2024
Permit Number NCS000136
Owner/Facility Name SpecGx,LLC/Mallinckrodt—Raleigh
Pharmaceutical Plant
SIC(NAICS)Code/Category 2833 /Industrial-Manufactures specialty
pharmaceutical products
Basin Name/Sub-basin number Neuse/03-04-02
Receiving Stream/I UC SW001 and SWO02: UT to Perry Creek/
030202010704
SW003B: UT to Neuse River/030202010704
Stream Classification/Stream Segment SW001 and SWO02: C;NSW/27-25-3-(2)
SW00313: WS-IV;NSW, CA/27-(22)
Is the stream impaired on 303 d list]? No
Any TMDLs? See Section 2 below
Any threatened and/or endangered species? See Section 2 below
Any compliance concerns? See Section 2 below
Any permit mods since lastpermit? See Section 1 below
New expiration date 4/30/2029
Comments on Draft Permit? See Section 6 below
Section 1. Facility Activities and Process:
The Mallinckrodt—Raleigh Pharmaceutical Plant is a bulk pharmaceutical manufacturer producing
Acetaminophen(APAP),para-Aminophenol (PAP), aniline, ammonium sulfate (MASL), and acetic
acid. The facility is a large quantity generator of hazardous waste. Per information provided 1/27/2023,
the SIC and NAICS for current processes are:
Process NAICS Code SIC Code
Acetaminophen(APAP) 325411 —Medical and botanical 2388—Medical chemicals and
manufacturing botanical products
325194—Cyclic crude, intermediate, 2865 —Cyclic organic crudes
para-Aminophenol (PAP) and gum and wood chemical and intermediates, and organic
manufacturing des and pigments
Aniline 325199—All other basic organic 2869—Industrial organic
chemical manufacturing chemicals,NEC
Ammonium Sulfate 325311 —Nitrogenous fertilizer 2873 —Nitrogenous fertilizers
MASL manufacturing
Acetic Acid(22%) 325199—All other basic organic 2869—Industrial organic
chemical manufacturing chemicals,NEC
There is an onsite wastewater treatment plant that functions as a pre-treatment plant before the effluent
is piped to the City of Raleigh WWTP. The site also contains an approximately 23 acre stormwater
retention pond, which collects runoff from drainage zone 313.
Page 1 of 9

Documentation from October 2011 in the permit file states there were 5 outfalls/drainage areas: 3 are
land application fields (003, 004, 005; no longer require monitoring) and 2 have stormwater discharge
(001 and 002). Drainage area 3B does not directly discharge but is a retention pond maintained such that
if a catastrophic release occurs on site, the retention pond would capture the release and emergency
responders would recover the release from the pond. Normal maintenance involves maintaining
sufficient freeboard by periodically pumping water out of the pond and into a UT to the Neuse River.
Since the last permit renewal, the following significant changes have occurred:
• Upgraded existing Bulk Acetic Acid/APAP wastewater tank
• Moved storage of hydrogen peroxide and aqua ammonia(stored in totes) from an uncovered area
to the covered/diked Hazardous Waste Storage Pad
• Added new Utilities Building transformer(Substation#8)
• Converted former Tar Loading/Unloading Truck Station to PAP Rework/temporary storage
• Began using Fire Training Area for storing non-routine wastes and high-strength wastewater in
tankers and/or totes
• Added cartridge filters on exhausts of dust collectors
• Added new tank farm/containment system for several replacement vessels used in the production
of APAP
• Added new replacement sulfuric acid tank farm
• Added new K083 waste-combusting boiler in diked area
• Added new stormwater trench drain between Buildings 910 and 903
• Valves remain open in oil-filled transformer containment areas
• Installed additional vessels for the APAP production process
• Moved spent catalyst residues from outdoors to the covered/diked Hazardous Waste Storage Pad
• Removed Unloading Area behind Building 101 and moved caustic unloading
• Removed Washing Area/Catalyst Storage Area
• Renamed Aniline Storage Tanks to "201 Storage Tanks" and added ammonium bisulfate tank
information
• Added area Transformer#9
• Added area Duke Energy Transformer#4 near Firewater Tank
• Added new Firewater Pump House
• Added area Diesel Unloading-Fire Pump
• Updated W-17 for new structural BMP (move tote under roof)
• Added back old oil-filled transformer at former Substation#3 at the Fire Training Field
• Moved empty transformer and associated oil tote at former Substation#4 to Fire Training Field
• Added nitrobenzene isotainer/tanker truck storage at Fire Training Field
• Added L-23 (Zone 2), W-18 (Zone 2), and W-19 (Zone 3) for Non-Routine/temporary
Hazardous Waste/Wastewater Tanker/Tote storage and/or unloading
• Removed old transformers 5-44, 5-45, and 5-46
• Added WWTP Bleach Storage in Drainage Zone 3
Outfall SW001: Drainage Zone 1
Drainage area consists of Duke Energy transformer#4, firewater pumphouse, a parking area, a
warehouse, warehouse loading and unloading, and diesel unloading area for fire pump, and trash cans.
Page 2 of 9

Outfall SW002: Drainage Zone 2
Drainage area consists of the warehouses, fire training area, boiler house, air products hydrogen, APAP
drying tower, vehicle fuel loading/unloading, warehouse loading/unloading, tank farm, fuel storage area,
hazardous waste tanker/tote storage and unloading areas, isotainer tanker and storage/staging, diesel
tanks, a transformer substation, rock salt storage, propane AST, maintenance building wash pit, and
trash cans.
Outfall SW003B: Drainage Zone 3B
Drainage area consists of the WWTP and tank farm, sludge application fields, flush water pond, two (2)
QC labs, shot pond, hydrogen tanks, liquid hydrogen tanks, lubricant storage, ammonium sulfate storage
area, raw waste surge tank, injection pond, propane ASTs, anhydrous ammonia loading/unloading,
nitrobenzene/caustic unloading area, diesel generator, boiler house, manufacturing areas and warehouses
with loading/unloading docks, scrubber system, seven(7) transformer substations, three (3) tank farms,
#2 fuel oil storage tank and unloading, sulfuric acid tank farm and unloading area, acetic acid tank farm
and loading station, ammonia tanks, three (3) aniline tar storage tanks and truck loading, four(4) MASL
ASTs and loading/unloading,used equipment storage areas, oil storage and loading/unloading, empty
drum storage area, hazardous waste tanker/tote unloading area, hazardous waste storage pads, PAP tote
storage pad and loading/unloading, 1 hazardous waste storage pad, washing area/catalyst storage area,
PAP plant compressor,bleach tote storage, loading/unloading areas for railcars, and trash and recycling
bins. Outfall 3 is located at the manual siphon at Lake Burkott and drainage discharges to the onsite
stormwater retention pond.
Additional outfalls:
Stormwater outfalls SW003A(Zone 3A), SW004 (Zone 4), and SW005 (Zone 5) do not have industrial
activity. These zones are land application fields for industrial residuals from the onsite wastewater
treatment plant(managed under permit WQ0005537) and are used for harvesting rye grass or coastal
bermuda.
Why Industrial Sites with Stormwater are Subject to a Permit: Federal NPDES regulations define
stormwater discharge associated with industrial activity in 40 CFR §122.26 (b)(14) as: "the discharge
from any conveyance that is used for collecting and conveying storm water and that is directly related to
manufacturing,processing or raw materials storage areas at an industrial plant. The term does not
include discharges from facilities or activities excluded from the NPDES program under this part 122.
For the categories of industries identified in this section, the term includes, but is not limited to, storm
water [sic] discharges from industrial plant yards; immediate access roads and rail lines used or traveled
by carriers of raw materials, manufactured products, waste material, or byproducts used or created by
the facility; material handling sites; refuse sites; sites used for the application or disposal of process
waste waters (as defined at part 401 of this chapter); sites used for the storage and maintenance of
material handling equipment; sites used for residual treatment, storage, or disposal; shipping and
receiving areas; manufacturing buildings; storage areas (including tank farms) for raw materials, and
intermediate and final products; and areas where industrial activity has taken place in the past and
significant materials remain and are exposed to storm water. For the purposes of this paragraph, material
handling activities include storage, loading and unloading, transportation, or conveyance of any raw
material, intermediate product, final product, byproduct or waste product. The term excludes areas
located on plant lands separate from the plant's industrial activities, such as office buildings and
accompanying parking lots as long as the drainage from the excluded areas is not mixed with storm
water [sic] drained from the above described areas."
Page 3 of 9

Section 2. Monitoring Information and Compliance History:
• December 2012 to February 2022, benchmarks exceeded for:
o SW001: pH min not reached Ix,
o SW002: pH min not reached Ix, TSS 2x, COD 2x
o SW003: Ammonium Sulfate I
TMDL:
A TMDL exists for Perry Creek in the Neuse River Basin, which includes discharge points for the
Mallinckrodt Pharmaceutical Plant. Per the 2010 TMDL: The Unnamed Tributary (UT) Perry Creek at
SR 3514 is considered impaired for biological integrity but is not listed on the 303(d) list due to the Not
Rated bioclassification. A bioclassification of Not Rated can be assigned to streams which have a
drainage area size less than three square miles and would have received a Fair or Poor bioclassification
using the benthic macroinvertebrate criteria derived for larger streams.
Threatened/Endangered Species:
There are no threatened/endangered species at the point of discharge, however the Regal Darner
(Coryphaeschna ingens; NC status: SR) is in the discharge area. Additional species of concern in the
nearby vicinity include Triangle Floater(Alasmidonta undulata; NC status: T), Eastern Lampmussel
(Lampsilis radiata; NC status: T),Neuse River Waterdog (Necturus lewisi;NC status: SC; Federal
status: T), Veined Skullcap (Scutellaria nervosa; NC status: E), Bald Eagle (Haliaeetus leucocephalus;
NC status: T), Creeping Spotflower(Acmella repens;NC status: SR-D), Slender Glass Lizard
(Ophisaurus attenuatus;NC status: SR), Septima's Clubtail (Gomphurus septima; NC status: SR), and
Roanoke Slabshell (Elliptio roanokensis;NC status: SC).
Section 3. Proposed Monitoring for Stormwater Discharges:
The Division considered potential pollutants from past and present industrial activities and data was
submitted for December 2012 to February 2022. Quantitative sampling included pH, TSS, conductivity,
COD, TKN,Nitrate+Nitrite, ammonia nitrogen, sulfate, ammonium sulfate, and total nitrogen.
Parameters are based on potential pollutants in the drainage area, sampling results, and in some cases,
dependent upon future activities (e.g., ash removal through the drainage area). Below is a table of the
proposed monitoring for each outfall at the Mallinckrodt—Raleigh Pharmaceutical Plant site.
Page 4 of 9

Outfalls SW001, SW002, and SWO03B
Quarterly monitoring
Total Suspended Solids BASIS: Potential pollutant from drainage area and BMP effectiveness
(TSS) indicator.
Quarterly monitoring
pH BASIS: Pollutant indicator
Quarterly monitoring
Total Rainfall BASIS: Discharge potential indicator
Quarterly monitoring
Non-Polar Oil &Grease BASIS: Potential pollutant from lubricants; Method 1664 SGT-HEM
targets petroleum-based O&G
Quarterly monitoring
Monthly Oil Usage BASIS: Potential pollutant from drainage area
Quarterly monitoring
BOD BASIS: Discharge potential indicator
Quarterly monitoring
COD BASIS: Discharge potential indicator
Quarterly monitoring
Conductivity BASIS: Pollutant indicator
Quarterly monitoring
Total Nitrogen BASIS: Discharge potential indicator
Quarterly monitoring
Ammonia Nitrogen BASIS: Potential pollutant from drainage area
Quarterly monitoring
Total Sulfate BASIS: Potential pollutant from drainage area
Quarterly monitoring
BASIS: Potential pollutant from drainage area; primary byproduct of
Ammonium Sulfate sulfuric acid used at the facility and has a 1/2 FAV more stringent than
sulfate
Stormwater Benchmarks and Tiered Response: Rather than limits,North Carolina NPDES
Stormwater permits contain benchmark concentrations. Stormwater benchmarks are numerical action
levels for stormwater monitoring. Benchmarks are not effluent limits, and benchmark exceedances are
not permit violations. Benchmarks provide facilities a tool for assessing the significance of pollutants in
stormwater discharges and the effectiveness of best management practices (BMPs). Benchmark
Page 5 of 9

concentrations are intended as guidelines for the facility's development and implementation of the
Stormwater Pollution Prevention Plan(SWPPP).
Benchmark exceedances require the permittee to increase monitoring, increase management actions,
increase record keeping, and/or install stormwater BMPs in a tiered program. The permit establishes a
tiered approach to specify actions the permittee must take in response to analytical results above
benchmark concentrations. The tiered structure of the permit provides the permittee and DEMLR wide
flexibility to address issues that may arise with one or more parameters and/or outfalls.
Metals benchmarks are calculated to mimic acute water quality standards and with the guidance of
DWR. NC DWR follows established federal procedures for calculating acute standards when developing
the benchmarks. Just like the acute standards, metals benchmarks normally reflect one half of the
calculated Final Acute Value (the "1/2 FAV"). In most cases, translation into total recoverable values is
based on an assumed hardness of 25 mg/L and a total suspended solids (TSS) concentration of 10 mg/L.
Acute standards protect aquatic life from negative impacts of short-term exposure to higher levels of
chemicals where the discharge enters a waterbody. The Stormwater Permitting Program applies this
approach because of the ephemeral nature of rainfall events.
The Division may evaluate results to determine if a smaller suite of parameters for some outfalls is
adequate to characterize potential pollution or BMP effectiveness. For example, one or more metals or
other parameters may serve as an adequate tracer for the presence of ash pollution during disturbance or
ash removal in specific drainage areas at this site. For parameters that do not have a stormwater
benchmark, the Division may develop a benchmark value if appropriate toxicity data become available
or if rising trends in concentrations suggest a persistent source.
A summary of the benchmarks in the draft permit, and their basis, is below:
Parameter Benchmark Basis
Total Suspended 100 mg/L National Urban Runoff Program(NURP) Study, 1983
Solids TSS
H 6 s.u. —9 s.u. NC Water Quality Standard(Range)
Non-Polar Oil & Review of other state's daily maximum benchmark
Grease 15 mg/L concentration for this more targeted O&G;NC WQS that
EPA Method 1664 does not allow oil sheen in waters
SGT-HEM
BOD 30 mg/L BPJ; Based on Secondary Treatment Regulation(40 CFR
g 133.03
COD 120 mg/L BPJ; Generally found at levels 4x BOD5 in domestic
wastewaters
Total Nitrogen 30 mg/L TKN+Nitrate+Nitrite Benchmarks (Expressed in mg/L of
N
Ammonia Nitrogen At 7.5 s.u. pH and summer(26°C) temperature from
(summer)
5.6 mg/L Wasteload Allocation document for the coastal plain region
worst-case scenario
Ammonia Nitrogen At 7.5 s.u. pH and winter(14°C) temperature from Wasteload
(winter)
15 mg/L Allocation document for the coastal plain region(worst-case
scenario
Total Sulfate 3,500 mg/L '/2 FAV acute toxicity
Ammonium Sulfate 19 mg/L '/2 FAV
Page 6 of 9

Stormwater Pollution Prevention Plan: The proposed permit conditions reflect the EPA and NC's
pollution prevention approach to stormwater permitting. The Division's maintains that implementation
of Best Management Practices (BMPs) and traditional stormwater management practices that control the
source of pollutants meets the definition of Best Available Technology (BAT) and Best Conventional
Pollutant Control Technology(BCT). The permit conditions are not numeric effluent limitations but are
designed to be flexible requirements for implementing site-specific plans to minimize and control
pollutants in stormwater discharges associated with the industrial activity. Title 40 Code of Federal
Regulations (CFR) §122.44(k)(2) authorizes the use of BMPs in lieu of numeric effluent limitations in
NPDES permits when the agency finds numeric effluent limitations to be infeasible. The agency may
also impose BMP requirements which are "reasonably necessary" to carry out the purposes of the Act
under the authority of 40 CFR 122.44(k)(3). The conditions proposed in this draft permit are included
under the authority of both of these regulatory provisions. In essence, the pollution prevention and BMP
requirements operate as limitations on effluent discharges that reflect the application of BAT/BCT.
Flexibility in Tier Responses: Tier Two actions provide an opportunity for the permittee to propose an
alternative monitoring plan for approval by the Region:
• Alternatively, in lieu of steps 2 and 3, the permittee may, after two consecutive exceedances,
exercise the option of contacting the DEMLR Regional Engineer as provided below in Tier
Three. The Regional Engineer may direct the response actions on the part of the permittee as
provided in Tier Three, including reduced or additional sampling parameters or frequency.
• If pursuing the alternative above after two consecutive exceedances, the permittee may propose
an alternative monitoring plan for approval by the Regional Engineer.
The permit therefore allows the permittee to petition the Regional Office for monitoring changes sooner
than Tier Three (upon any four benchmark exceedances) and gives guidance on one option to take. For
example, the permittee may request that mercury only be monitored semi-annually under the tiers, or
that only parameters over the benchmark be monitored more frequently. In this way, changes to the
monitoring scheme for any outfall could be handled outside of a permit modification.
Other Proposed Requirements:
• It is standard for Stormwater Pollution Prevention Plan(SWPPP)requirements to include an
annual certification that stormwater outfalls have been evaluated for the presence of non-
stormwater discharges, and if any are identified, how those discharges are permitted or otherwise
authorized.
• Requirement to submit a request for permit modification if the facility identifies or creates any
new outfalls, removes outfalls, or alters any drainage area that changes potential pollutants.
• The Division expects the permittee to apply best professional judgment and consider the safety
of its personnel in fulfilling sampling obligations under the permit.
• Federal regulations require electronic submittal of all discharge monitoring reports (DMRs). If a
state does not establish a system to receive such submittals, then permittees must submit DMRs
electronically to the EPA.
• Quarterly QualitativeNisual Monitoring to assure regular observation of outfalls throughout
year.
Page 7 of 9

Section 4. Changes from previous permit to draft:
• Regulatory citations added
• Monitoring increased from semi-annually to quarterly for all parameters (qualitative and
quantitative)
• "No discharge" clarifications made
• eDMR requirement added
• Feasibility study removed
• Outfall specific monitoring implemented
• Boilerplate language moved into body of the permit; boilerplate no longer attached
• Updated facility name to match that on the original name/ownership change request form
• Monitoring for Nitrate+Nitrite removed as monitoring for total nitrogen already required
• Monitoring for BOD added based on presence of materials onsite (pallets, recycling materials)
• Benchmarks updated for parameters per guidance from DWR Standards group on stormwater
benchmarks
Section 5. Changes from draft to final:
• None
Section 6. Discussions with the Facility and Regional Office:
• Initial contact with facility: 9/7/2022
• Initial contact with Regional Office: 9/7/2022
• Draft sent to CO peer review: N/A
• Draft sent to Regional Office: 11/1/2023
• Final permit sent for supervisor signature:
Section 7. Comments received on draft permit:
• Tim Roberts (Mallinckrodt Pharmaceuticals; via email l l/l/2023): What specific materials
present on our site are driving the addition of BOD to the analyses?
o DEMLR response: Monitoring for BOD was included in the draft permit as the site has
pallets and recycling materials stored outside that have the potential to come into contact
with stormwater.
• Shawn Guyer (PWS; via email 11/27/23): We concur with the issuance of this permit provided
the facility is operated and maintained properly, the stated effluent limits are met prior to
discharge, and the discharge does not contravene the designated water quality standards.
• Tim Roberts (Mallinckrodt Pharmaceuticals; via email 12/l/23): Our comments address: (1)the
proposed expanded requirements for Monitoring for Non-Polar Oil and Grease (Vehicle
Maintenance Activities) and(2)the new BOD monitoring requirement:
o Monitoring for Non-Polar Oil & Grease (Vehicle Maintenance Activities): Mallinckrodt
requests that clarifying language be added to ensure that monitoring of non-polar oil &
grease is only required for"Vehicle Maintenance Activity"(defined on Page 39 of the
Page 8 of 9

draft permit). Accordingly, Mallinckrodt recommends the following revisions to the draft
permit:
■ Condition D-I(b) (p. 14) should read"In addition to the grab samples, the average
monthly usage of new motor and hydraulic oil associated with on-site vehicle
maintenance activities for the facility shall be tracked, recorded, and reported to
the Division if it exceeds an average of 55 gallons per month over the previous
twelve (12) months."
■ Add Footnote No. 4 to Table I (p. 15) attached to Parameter Codes 00552 and
NCOIL in the fourth and fifth rows of this table stating: "These parameters are
only required for areas using> 55 gallons per month of oil for on-site vehicle
maintenance activities."
■ These changes are intended to ensure that monitoring regarding oil and grease use
is confined to uses of oil and grease and excludes, for example, indoor use of oil
which does not impact stormwater.
■ DEMLR response: Monitoring for oil and grease and new motor oil are no
longer required for only vehicle maintenance areas. This change is meant to
encompass oil usage for vehicle maintenance as well as any equipment or other
maintenance that utilizes oil onsite. Therefore, the permit shall remain as is.
o Monitoring for BOD: Mallinckrodt believes that the addition of BOD monitoring (item
10 in the November 1, 2023 Draft NPDES Stormwater Permit cover letter) is
inappropriate for this facility for the following reasons: All Mallinckrodt stormwater
outfalls are separated from active operations by heavily wooded areas that include much
wildlife.
■ Nothing significant in our operations justifies adding BOD monitoring in our
Stormwater Permit and Mallinckrodt believes the continued monitoring for COD,
TSS, and other parameters are adequate for monitoring stormwater runoff.
■ Monitoring for BOD in our stormwater outfalls will require additional resources
to react to something that is likely not related to operational activities. We believe
that any future potential BOD benchmark exceedances would most likely be false
positives due to naturally occurring conditions rather than active operations
(Reason 1 above).
■ Because it does not address any actual operational impact concerns, the addition
of BOD sampling adds no real value in terms of improved stormwater
management. Accordingly, the site does not want to accept this unneeded
parameter for a minimum of 5 years and possibly longer(our current permit has
been in effect for over 12 years).
■ Most laboratories cannot analyze for BOD when samples are received on Friday,
Saturday, or Sunday, unless given prior early notice. The nature of stormwater
sampling makes providing early notice very difficult, if not impossible.
■ Mallinckrodt's stormwater sampling costs will nearly double solely because of the
increased sampling frequency for all parameters (quarterly rather than semi-
annual), and with the addition of BOD, those costs will even be higher.
Mallinckrodt respectfully submits that requiring Mallinckrodt to sample a non-
value added parameter which would not directly improve stormwater
management is not an appropriate use of NCDEQ's permitting authority.
■ DEMLR response: As wooden pallets and boxes are stored outdoors (per the
permit renewal application), monitoring for BOD shall remain in the permit. If
benchmark exceedances occur, SpecGX, LLC may contact the Raleigh Regional
Office for guidance and/or assistance.
Page 9 of 9

The Beaufort Gazette Durham I The Herald-Sun The Modesto Bee
The Belleville\eN s-Democrat Fort!North Star-Telegram The Sun Nuys-N1vr tie Beach
Bellingham Het.dd The Fresno Bee Raleigh\ews&Ol+.sener
ClCentre Daily Times The Island Packet Rock Hill I The Herald
Mcatchy un Herald The Kansas City Star The Sacramento Bee
Idalso Statesman Lexington Herald-Leader San Luis Obispo Tribune
Bradenton Herald The Telegraph-Macon Tacoma I The News Tribune
The Charlotte Observer Merced Stuff-Star Tri-City Herald
37te State NIlami Herald. TheWid—dta Eagle
Ledger-Enquirer El Nuevo Herald The Olympian
AFFIDAVIT OF PUBLICATION
Acimunt# Order Number IdeWcaffon Order PO Amount Cols Depth
W06 522115 Print Legal Ad-IPLO160WO-I1PL016069 $47236 1 41 L
Attention: Joyce Sanford Clark STATE OF NORTH CAROLINA
NC DENR ENGERGY MINERAL&LAND RESOURCES COUNTY OF WAKE,COUNTY OF DURHAM
1612 MAIL SERVICE CENTER Before the undersigned,a Notary Public of Dallas
RALEIGH.NC 276991612 County,Texas,duly commissioned and authorized to
administer oaths,affirmations,etc.,personally
[e-mail] appeared Tara Pennington,who being duly sworn or
----------------------------------------------------------------------------
affirmed,according to law,doth depose and say that he
NORTH CAROLINA ENYIRON- ; or she is Accounts Receivable Specialist of the News&
MENTAL MANAGEMENT COM- Observer Publishing Company,a corporation organized
MISSION INTENT TO ISSUE
NPDES STORMWATERand doingbusiness under the Laws of the State of North
DDESS--
CHARGE PERMITS Carolina,and publishing a newspaper known as The
The North Carolina Environmental
Management Commission proposes News&Observer,Wake and State aforesaid,the said
Ma �
to issue NPDES stormwater discharge newspaper in which such notice,paper,document,or
permit(s)to the person(s)listed below.Public comment or objection to the legal advertisement was published was,at the time of
draft permits Is invited.Written com- each and every such publication,a newspaper meeting
menu regarding the proposed permit will be accepted until 30 days after the all of the requirements and qualifications of Section t-
,
publish date of this notice and oonsid- ; 597 of the General Statutes of North Carolina and was a
in the final determination regard-
ing permit issuance and permit provi- qualified newspaper within the meaning of Section 1-597
regard-
ing ,
lions.The Director of the NC Dtvtsion of the General Statutes of North Carolina,and that as
of Energy,Mineral,and Land such he or she makes this affidavit,and is familiar with
hearing
Resourc-
es(DEMLR)may hold a publicc hearingg
should there be a significant degree of the books,files and business of said corporation and by
public interest Please matt reference to the files of said publication the attached
to DEMLR ments
and/or Information requests to DE
at 1612 Mail Service Center.Raleigh, advertisement for NC DENR ENGERGY MINERAL&LAND
NC 27699-1612.
specGx, LLc tss01 Capital RESOURCES was inserted in the aforesaid newspaper on
•
Blvd, Raleigh, NC 276161 has dates as follows:
requested renewal of permit
NCS000136 for the Mallinck- 1 insertion(s)published on:
rodt - Raleigh Pharmaceutics ;
Plant in Wake County.This fa-
cility discharges to an unnamed ;
tributary to Perry Creek in the
Neuse River Basin.
Interested persons may visit DEMLR '
at 512 N. Salisbury Street,Raleigh,
NC 27604 to review information on ;
file. Additional information on NP-
DES permits and this notice may be ;
found on our website: httpsJ/deq.nc.go ; F
eral-a/about-reso i cs/stormwate- ; ,�•-•
era!-and-sand-resources/stormwater/ t1�r
stormwater-program/stormwater--purr (�
?_ ty
lic-notices,or by contacting Brianna ;
Young at brianna.young Odeq.nc.gov I certify or declare)under penalty of perjury that the
or 919-707-3647.
IPLO160657 foregoing is true and correct.
Feb 212024
Notary Public in and or t e-Ta-te—oT Texas.residing in
Dallas County
�'`'�`r•'=9�`' STEPtLAI'+iIE HATCHER
My Notaq ID#13353M
''-*ram• �~" Expires January 14,202$
Extra charge for lost or duplicate affidavits.
legal document please do not destroy!

Young, Brianna A
From: Roberts, Tim <[e-mail]>
Sent: Friday, December 1, 2023 2:14 PM
To: Young, Brianna A
Cc: Phillips, David; Kalar, Michael; Hawk, Ireland
Subject: [External] RE: Draft NPDES stormwater permit NCS000136-Comments
Importance: High
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.
Ms. Young,
Thank you for the opportunity to provide comments on the attached draft permit. Our comments address: (1)the
proposed expanded requirements for Monitoring for Non-Polar Oil and Grease (Vehicle Maintenance Activities) and (2)
the new BOD monitoring requirement:
Monitoring for Non-Polar Oil &Grease(Vehicle Maintenance Activities).
Mallinckrodt requests that clarifying language be added to ensure that monitoring of non-polar oil &grease is only
required for"Vehicle Maintenance Activity"(defined on Page 39 of the draft permit). Accordingly, Mallinckrodt
recommends the following revisions (shaded in yellow below)to the draft permit:
Condition D-1(b) (p. 14)should read "In addition to the grab samples, the average monthly usage of new motor
and hydraulic oil associated with on-site vehicle maintenance activities for the facility shall be tracked,
recorded, and reported to the Division if it exceeds an average of 55 gallons per month over the previous twelve
(12)months."
Add Footnote No. 4 to Table 1 (p. 15) attached to Parameter Codes 00552 and NCOIL in the fourth and fifth rows
of this table stating: "These parameters are only required for areas using>55 gallons per month of oil for on-site
vehicle maintenance activities."
These changes are intended to ensure that monitoring regarding oil and grease use is confined to uses of oil and grease
and excludes,for example, indoor use of oil which does not impact stormwater.
Monitoring for BOD
Mallinckrodt believes that the addition of BOD monitoring (item 10 in the November 1, 2023 Draft NPDES Stormwater
Permit cover letter) is inappropriate for this facility for the following reasons:
All Mallinckrodt stormwater outfalls are separated from active operations by heavily wooded areas that include much
wildlife.
1. Nothing significant in our operations justifies adding BOD monitoring in our Stormwater Permit and Mallinckrodt
believes the continued monitoring for COD,TSS, and other parameters are adequate for monitoring stormwater
runoff.
i

2. Monitoring for BOD in our stormwater outfalls will require additional resources to react to something that is
likely not related to operational activities. We believe that any future potential BOD benchmark exceedances
would most likely be false positives due to naturally occurring conditions rather than active operations (Reason
1 above).
3. Because it does not address any actual operational impact concerns, the addition of BOD sampling adds no real
value in terms of improved stormwater management. Accordingly,the site does not want to accept this
unneeded parameter for a minimum of 5 years and possibly longer(our current permit has been in effect for
over 12 years).
4. Most laboratories cannot analyze for BOD when samples are received on Friday,Saturday, or Sunday, unless
given prior early notice. The nature of stormwater sampling makes providing early notice very difficult, if not
impossible.
5. Mallinckrodt's stormwater sampling costs will nearly double solely because of the increased sampling frequency
for all parameters (quarterly rather than semi-annual), and with the addition of BOD,those costs will even be
higher. Mallinckrodt respectfully submits that requiring Mallinckrodt to sample a non-value added parameter
which would not directly improve stormwater management is not an appropriate use of NCDEQ's permitting
authority.
Mallinckrodt would appreciate the opportunity to have a meeting to discuss our comments with the agency prior to final
issuance of the permit.
Regards,
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(cDmnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, November 1, 2023 4:08 PM
To: Phillips, David <[e-mail]>
Cc: Roberts,Tim <[e-mail]>
Subject: [EXTERNAL] Draft NPDES stormwater permit NCS000136
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon,
Please find attached a copy of the draft stormwater permit for SpecGx, LC Mallinckrodt—Raleigh Pharmaceutical Plant
(NCS000136).A hard copy of this permit will be placed in the mail to David Phillips. Please provide any comments on the
draft permit by December 1, 2023.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
2

NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
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.
3

Young, Brianna A
From: Young, Brianna A
Sent: Thursday, November 2, 2023 8:25 AM
To: Roberts, Tim
Cc: Kalar, Michael; Hawk, Ireland
Subject: RE: [External] RE: Draft NPDES stormwater permit NCS000136
Good morning Tim,
Monitoring for BOD was included in the draft permit as the site has pallets and recycling materials stored outside that
have the potential to come into contact with stormwater. Please let me know if you have any other questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Roberts,Tim <[e-mail]>
Sent: Wednesday, November 1, 2023 4:40 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Hawk, Ireland <[e-mail]>
Subject: [External] RE: Draft NPDES stormwater permit NCS000136
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.
Hi Brianna!
We will review and provide comments by 12/1/2023.
Also, what specific materials present on our site are driving the addition of BOD to the analyses?
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals

8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(c�mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From:Young, Brianna A<[e-mail]>
Sent: Wednesday, November 1, 2023 4:08 PM
To: Phillips, David <[e-mail]>
Cc: Roberts,Tim <Tim.Robe [e-mail]>
Subject: [EXTERNAL] Draft NPDES stormwater permit NCS000136
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon,
Please find attached a copy of the draft stormwater permit for SpecGx, LC Mallinckrodt—Raleigh Pharmaceutical Plant
(NCS000136).A hard copy of this permit will be placed in the mail to David Phillips. Please provide any comments on the
draft permit by December 1, 2023.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address:512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
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.
2

Young, Brianna A
From: Guyer, Shawn
Sent: Monday, November 27, 2023 11:41 AM
To: Young, Brianna A
Subject: NCS000136 FW: Draft stormwater permits
Attachments: Draft NPDES Permit NCS000294.pdf; Draft NPDES Permit NCS000136.pdf
We concur with the issuance of this permit provided the facility is operated and maintained properly, the
stated effluent limits are met prior to discharge, and the discharge does not contravene the designated water
quality standards.
Shawn F. Guyer, P.E.
Deputy Section Chief- Technical Services Branch Head
Division of Water Resources, Public Water Supply Section
North Carolina Department of Environmental Quality
Office: [phone] 1 Mobile: [phone]
[e-mail]
D 0
z-��� - E-
t4 ;
NORTH CAROLINA
Department of Environmental Quality
Email correspondence to and from this address is subject to the North
Carolina Public Records Law and may be disclosed to third parties.
From:Young, Brianna A<[e-mail]>
Sent: Wednesday, November 1, 2023 4:07 PM
To: Guyer, Shawn <[e-mail]>
Subject: Draft stormwater permits
Good afternoon,
Please find attached the draft stormwater permits for Southern Sates Cooperative, Inc. (NCS000294) and SpecGx, LLC
(NCS000136), which have been submitted for public notice.These facilities discharge to class WS-IV; NSW and WS-IV;
NSW, CA waters. Please provide any comments by December 1, 2023.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
1

[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address:512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
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.
2

Compliance Inspection Report
Permit:NCS000136 Effective: 12/01/11 Expiration: 11/30/16 Owner: Specgx LLC
SOC: Effective: Expiration: Facility: Mallinckrodt-Raleigh Pharmaceutical Plant
County: Wake 8801 Capital Blvd
Region: Raleigh
Raleigh NC 276163116
Contact Person:Tim Roberts Title: Phone: [phone]
Directions to Facility:
System Classifications: SWNC,
Primary ORC: Certification: Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 12/08/2022 Entry Time 01:OOPM Exit Time: 03:OOPM
Primary Inspector:Lauren Garcia Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, Individual
Facility Status: Compliant ❑ Not Compliant
Question Areas:
Storm Water
(See attachment summary)
Page 1 of 3

Permit: NCS000136 Owner-Facility:Specgx LLC
Inspection Date: 12/08/2022 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Inspeciton was in response to permit renewal. Facility manufactures Acetaminophen (APAP)and PAP. Acetic acid and
ammonia sulfate are generated during the processing. The facility currently has three outfalls.
Outfalls 1 and 2 receive stormwater at the southern sides of the facility. Outfall 1 receives water from a shipping and
receiving bay as well an emergency equipment shed and fire water tower. Outfall 2 receives water from a fire training area
and the dry storage warehouse. The APAP product is stored in the onsite warehouse and is shipped out from the bay.
The remainder of the site, including the majority of the industrial operations, drains to outfall 3. Outfall 3 is located at the
manual siphon at Lake Burkott. The lake was designed as a fail safe where in the event of a major spill, any spilled material
would be contained in the lake or be contained before reaching the lake. The lake does not have an outfall or emergency
spillway and water levels are controlled manually as needed. Stormwater discharging through zone 3 of the facility travels
approximately'/4 mile through spray fields and under a railroad track to reach the pond. Stormwater travels to the pond
through open swales and stormwater pipes to reach the pond.
There is an onsite wastewater treatment plant that functions as a pre-treatment plant before the effluent is piped to the City
of Raleigh WWTP. Several tanker trucks were parked onsite in the fire training area and contained wastewater. The fire
training area is bermed. There are diesel tanks located in Zone 2 (draining to outfall 2), and are stored in proper secondary
containment. There were empty totes stored in several areas onsite, but were reported to have been emptied and cleaned
and were waiting to be sold.
All chemical tanks used in the processing were observed to be stored in concrete bermed areas/secondary containment.A
moderate amount of pallets were also observed stored onsite. The pallets were not stored under cover.
A hazardous waste pad is located in Zone 3. The facility is a large quantity generator. The hazardous waste pad is within a
storm-resistant shelter. All containers were labelled.
There is a used oil storage building in zone 3. Containers were stored in proper secondary containment.
All necessary paperwork was available onsite.The SWPPP is updated annually and all components were present.
Page 2 of 3

Permit: NCS000136 Owner-Facility:Specgx LLC
Inspection Date: 12/08/2022 Inspection Type:Compliance Evaluation Reason for Visit: Routine
Stormwater Pollution Prevention Plan Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan? ❑ ❑ ❑
#Does the Plan include a General Location (USGS) map? ❑ ❑ ❑
#Does the Plan include a"Narrative Description of Practices"? ❑ ❑ ❑
#Does the Plan include a detailed site map including outfall locations and drainage areas? ❑ ❑ ❑
#Does the Plan include a list of significant spills occurring during the past 3 years? ❑ ❑ ❑
#Has the facility evaluated feasible alternatives to current practices? ❑ ❑ ❑
#Does the facility provide all necessary secondary containment? ❑ ❑ ❑
#Does the Plan include a BMP summary? ❑ ❑ ❑
#Does the Plan include a Spill Prevention and Response Plan (SPRP)? ❑ ❑ ❑
#Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ❑ ❑ ❑
#Does the facility provide and document Employee Training? 0 ❑ ❑ ❑
#Does the Plan include a list of Responsible Party(s)? 0 ❑ ❑ ❑
# Is the Plan reviewed and updated annually? 0 ❑ ❑ ❑
#Does the Plan include a Stormwater Facility Inspection Program? 0 ❑ ❑ ❑
Has the Stormwater Pollution Prevention Plan been implemented? 0 ❑ ❑ ❑
Comment:
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring? ❑ ❑ ❑ ❑
Comment:
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? 0 ❑ ❑ ❑
#Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? 0 ❑ ❑ ❑
Comment:
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? 0 ❑ ❑ ❑
#Were all outfalls observed during the inspection? ❑ ❑ ❑
# If the facility has representative outfall status, is it properly documented by the Division? ❑ ❑ ❑
#Has the facility evaluated all illicit(non stormwater)discharges? 0 ❑ ❑ ❑
Comment:
Page 3 of 3

Young, Brianna A
From: Yuncu, Bilgen <[e-mail]>
Sent: Tuesday, November 15, 2022 4:42 PM
To: Roberts, Tim
Subject: RE: [EXTERNAL] Outfall Discharge Info-Request by Stormwater Permitting Unit
EXTERNAL EMAIL: Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon Tim,
I reviewed the information, and it all looks good to me. I don't believe there is any change in the current information.
Best Regards,
Bilgen
Bilgen Yuncu, PhD, PE, PMP
Environmental Engineer/Project Manager
114 Edinburgh South, Suite: 200 Cary, North Carolina, 27511
TRIC T 919.582.7267 1 C 919.649.9275 1 [e-mail]
Linkedln I Twitter I TRCcompanies.com
From: Roberts,Tim <[e-mail]>
Sent:Tuesday, November 15, 2022 12:05 PM
To:Yuncu, Bilgen <[e-mail]>
Subject: [EXTERNAL] Outfall Discharge Info-Request by Stormwater Permitting Unit
contentThis is an EXTERNAL email. Do not click links or open attachments unless you validate the sender and know
the
ALWAYS hover over the link to preview the actual URL/site and confirm its legitimacy.
I am working on getting Brianna Young the info. she requested a few months ago. Can you review the attached and
provide
• Confirmation of the receiving stream for each outfall
Also we need to confirm:
• Stormwater outfall information: (if changes we need to Email Bethany Geor og ulias)
Send your responses to me and I'll forward to the agency as needed.
1

Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(c�mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
2

Young, Brianna A
From: Roberts, Tim <[e-mail]>
Sent: Friday, January 27, 2023 4:25 PM
To: Young, Brianna A
Cc: Kalar, Michael; Bilgen Yuncu
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136) - Response 1
Attachments: RE: [EXTERNAL] Outfall Discharge Info-Request by Stormwater Permitting Unit
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Here is the attached email referenced below.
-Tim
From: Roberts,Tim
Sent: Friday,January 27, 2023 4:24 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)- Response 1
Importance: High
Here's Part 1 of my responses below(responses in BLUE). I will work on Part 2 (info needs in RED) and get to you by
the end of next week. If you have questions about anything I am sending here, please feel free to ask.
I have some other regulatory reports/plan updates due early next week that I have to complete first. I really appreciate
your patience and understanding.
-Tim
• Provide SIC (NAICS) code; (See table below)
i

Process New NAICS Code(s) Old SIC Code(s)
325411---%.'Iedical and Botanical 2833---Medical Chemicals and
Acetaminophen ( PAP
-Manufacturing (pt) Botanical Products
325194-C,Yclic Crude_
Para-Aminophenol Intermediate, and Cr>.un and 2865-Cyclic Organic Crudes
(PAP) ��'ood Chemical and Intermediates, and Organic
_\-1anufacturin * Dyes. and Pigments
325199-All Other Basic
Aniline Organic Chemical 2869-Industrial Organic
-Manufacturing (pt) Chemicals, NEC
Ammonium Sulfate 325311- Nitrogenous FerthZer
2873-Nitrogenous Fertilizers
(MASL) --Manufacturing
325199-All Other Basic
Acetic Acid (220.a) Organic Chemical 2869-Industrial Organic
'Ianufacturing (pt) Chemicals- NEC
• Confirmation of the facility's name (this will be used in the permit and our database); (Mallinckrodt—
Raleigh Pharmaceutical Plant as noted in the NPDES Stormwater Permit Summary Report;
SpecGx LLC is the legal owner; the "G" is capitalized and not lower case as shown in the NPDES
Stormwater Permit Summary Report)
• Description of industrial activities that occur in each drainage area; (PENDING)
• Confirmation of the receiving stream for each outfall; (Confirmed-see attached email)
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit; (submitted to you on 9-19-22)
• Verification that the information in the renewal application is still complete and correct; (PENDING)
and
• An explanation of any operational changes since the renewal application was submitted. (PENDING)
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(a)mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From: Young, Brianna A<[e-mail]>
Sent: Friday,January 27, 2023 2:11 PM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
2

EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon,
I am following up on our previous correspondence.To date I have not received the requested information.This
information is required in order to proceed with reviewing the permit renewal application. Please let me know if you
have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent:Tuesday, November 15, 2022 11:41 AM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
I will begin working on this info. this week with a goal of having all to you next week before the Thanksgiving holiday.
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(cDmnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
3

From:Young, Brianna A<[e-mail]>
Sent:Tuesday, November 15, 2022 11:01 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good morning,
I am following up on our previous correspondence.To date I have not received the requested information.This
information is required in order to proceed with the permit renewal. Do you have an estimate on when the information
will be provided? Please let me know if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent: Wednesday, October 19, 2022 1:29 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Not yet. We are in the midst of a plant shutdown. I will try to have by the end of the month.
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
4

T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(c�mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, October 19, 2022 10:08 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good morning,
I am following up on our previous correspondence. Have you had a chance to work on this information request?The
permit renewal review is on hold pending the additional information.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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:Young, Brianna A
Sent:Tuesday, September 20, 2022 8:47 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
Thank you for providing this information. Please let me know if you have any questions as you work through the rest of
the request next month.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
5

Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent: Monday, September 19, 2022 4:41 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Attached is the summary data you requested below that I had our consultant (TRC) pull together the you. Again, I'll start
working on the other information next month after I return from vacation.
Regards,
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(cDmnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From: Roberts,Tim
Sent:Thursday,September 8, 2022 11:04 AM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>
Subject: RE: Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
Hi Brianna! As we just discussed on the phone, I will try to get you the monitoring summary from my consultant and
forward to you as soon as possible this month. I'll start working on the other information next month after I return from
vacation.
Thanks!
6

Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(d_)mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error,please inform the sender and remove any record of this message.
From: Young, Brianna A<[e-mail]>
Sent: Wednesday, September 7, 2022 3:44 PM
To: Phillips, David <[e-mail]>; Roberts,Tim <[e-mail]>
Subject: [EXTERNAL] Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon,
I am working on renewing the individual stormwater permit for the Mallinckrodt Raleigh Pharmaceutical Plant
(NCS000136). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Provide SIC (NAICS) code;
• Confirmation of the facility's name (this will be used in the permit and our database);
• Description of industrial activities that occur in each drainage area;
• Confirmation of the receiving stream for each outfall;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany oulias
• Stormwater outfall information: Email Bethany Geor og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePUment website

Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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.
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.
8

Young, Brianna A
From: Roberts, Tim <[e-mail]>
Sent: Monday, February 13, 2023 10:36 AM
To: Young, Brianna A
Cc: Kalar, Michael; Bilgen Yuncu
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136) - Response 1
Attachments: SWPPP Plan-Sec 2-Description of Activities by Zone.pdf, Revised Figs 5 6 and 9-Dec
2022.pdf, Attachment IV-Current BMPs-Dec 2022.pdf,Attachment V-Summary of
Significant Changes in Industrial Activities-Rev 1-Feb 2023.pdf
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Here is the remaining information I needed to provide you:
• Description of industrial activities that occur in each drainage area; See attached Section 2 from the
site's SWPP Plan.
• Verification that the information in the renewal application is still complete and correct; You already
have the info. on the change in company name, etc. See attached revised Figures 5, 6, and 9 and
current BMPs-Attachment IV of the Application.
and
• An explanation of any operational changes since the renewal application was submitted. See attached
revised List of Changes-Attachment V of the Application.
Let me know if you need anything else.
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 I USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(c�mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From:Young, Brianna A<[e-mail]>
Sent:Thursday, February 2, 2023 4:06 PM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)- Response 1
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
1

Thank you for submitting this information. I will reach out with any additional questions one I've had a chance to review
everything.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent: Friday,January 27, 2023 4:25 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)- Response 1
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Here is the attached email referenced below.
-Tim
From: Roberts,Tim
Sent: Friday,January 27, 2023 4:24 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)- Response 1
Importance: High
Here's Part 1 of my responses below(responses in BLUE). I will work on Part 2 (info needs in RED) and get to you by
the end of next week. If you have questions about anything I am sending here, please feel free to ask.
I have some other regulatory reports/plan updates due early next week that I have to complete first. I really appreciate
your patience and understanding.
-Tim
• Provide SIC (NAICS) code; (See table below)
2

Process New NAICS Code(s) Old SIC Code(s)
325411---%.'Iedical and Botanical 2833---Medical Chemicals and
Acetaminophen ( PAP
-Manufacturing (pt) Botanical Products
325194-C,Yclic Crude_
Para-Aminophenol Intermediate, and Cr>.un and 2865-Cyclic Organic Crudes
(PAP) ��'ood Chemical and Intermediates, and Organic
_\-1anufacturin * Dyes. and Pigments
325199-All Other Basic
Aniline Organic Chemical 2869-Industrial Organic
-Manufacturing (pt) Chemicals, NEC
Ammonium Sulfate 325311- Nitrogenous FerthZer
2873-Nitrogenous Fertilizers
(MASL) --Manufacturing
325199-All Other Basic
Acetic Acid (220.a) Organic Chemical 2869-Industrial Organic
'Ianufacturing (pt) Chemicals- NEC
• Confirmation of the facility's name (this will be used in the permit and our database); (Mallinckrodt—
Raleigh Pharmaceutical Plant as noted in the NPDES Stormwater Permit Summary Report;
SpecGx LLC is the legal owner; the "G" is capitalized and not lower case as shown in the NPDES
Stormwater Permit Summary Report)
• Description of industrial activities that occur in each drainage area; (PENDING)
• Confirmation of the receiving stream for each outfall; (Confirmed-see attached email)
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit; (submitted to you on 9-19-22)
• Verification that the information in the renewal application is still complete and correct; (PENDING)
and
• An explanation of any operational changes since the renewal application was submitted. (PENDING)
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(a)mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From: Young, Brianna A<[e-mail]>
Sent: Friday,January 27, 2023 2:11 PM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
3

EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon,
I am following up on our previous correspondence.To date I have not received the requested information.This
information is required in order to proceed with reviewing the permit renewal application. Please let me know if you
have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent:Tuesday, November 15, 2022 11:41 AM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
I will begin working on this info. this week with a goal of having all to you next week before the Thanksgiving holiday.
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(cDmnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
4

From:Young, Brianna A<[e-mail]>
Sent:Tuesday, November 15, 2022 11:01 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good morning,
I am following up on our previous correspondence.To date I have not received the requested information.This
information is required in order to proceed with the permit renewal. Do you have an estimate on when the information
will be provided? Please let me know if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent: Wednesday, October 19, 2022 1:29 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Not yet. We are in the midst of a plant shutdown. I will try to have by the end of the month.
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
5

T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(c�mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, October 19, 2022 10:08 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good morning,
I am following up on our previous correspondence. Have you had a chance to work on this information request?The
permit renewal review is on hold pending the additional information.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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:Young, Brianna A
Sent:Tuesday, September 20, 2022 8:47 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
Thank you for providing this information. Please let me know if you have any questions as you work through the rest of
the request next month.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
6

Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent: Monday, September 19, 2022 4:41 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Attached is the summary data you requested below that I had our consultant (TRC) pull together the you. Again, I'll start
working on the other information next month after I return from vacation.
Regards,
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(cDmnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From: Roberts,Tim
Sent:Thursday,September 8, 2022 11:04 AM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>
Subject: RE: Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
Hi Brianna! As we just discussed on the phone, I will try to get you the monitoring summary from my consultant and
forward to you as soon as possible this month. I'll start working on the other information next month after I return from
vacation.
Thanks!
7

Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(d_)mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error,please inform the sender and remove any record of this message.
From: Young, Brianna A<[e-mail]>
Sent: Wednesday, September 7, 2022 3:44 PM
To: Phillips, David <[e-mail]>; Roberts,Tim <[e-mail]>
Subject: [EXTERNAL] Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon,
I am working on renewing the individual stormwater permit for the Mallinckrodt Raleigh Pharmaceutical Plant
(NCS000136). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Provide SIC (NAICS) code;
• Confirmation of the facility's name (this will be used in the permit and our database);
• Description of industrial activities that occur in each drainage area;
• Confirmation of the receiving stream for each outfall;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany oulias
• Stormwater outfall information: Email Bethany Geor og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePUment website
8

Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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.
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.
9

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to slormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BWs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"+"near
the Structural 13MP.
Location: South of the building 51A warehouse in Drainage
Zones 1 and 2
Materials: Granular APAP(in cardboard drums),APAP powder
(in cardboard drums and boxes),dust control material,
Building 51 Warehouse ice melt,lime,cleaning solution,paint,paint thinner,
(S-1)* self-shrinking bottle closures,cardboard packaging,
glass jars,and wooden pallets.
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: North ofthe building,51 warehouse and south of
building 100 in Drainage Zone 2
Building 51A Warehouse Materials: This storage area APAP which is stored in cardboard
drums and supersacks.
(S-2)* Structural BMPs: None related to stormwater.
Procrd u ral BMPs: None related to stormwater.
Location: Southwest of building 901(boiler house)in Drainage
Zone 3B
Materials: #2 fuel oil(50,000 gallon tank)
Structural BMPs*: This aboveground storage tank is located within a
concrete secondary containment dike(80 x 60 x 5')that
can contain the contents of the tank plus accumulated
No.2 Fuel Oil Storage Tank rainwater from a 25-year 24 hour storm event.
(S-3) Procedural BMPs: Stormwater that collects in the bermed area is inspected
by the Mallinckrodt Utilities Department, if the
stormwater is found to be clean,it is pumped out from
the sump located in the corner of the dike to the
stormwater ditch located north of the dike. A lock has
been placed on the sump pumpin this area.
Location: Northwest of building 901 in Drainage Zone 3B
Materials: K083 aniline tar
Structural BMPs*: This aboveground storage tank is built with secondary
containment in the form of a concrete dike equipped
with a sump.The containment structure(34.5`x 14.5'x
3')will hold the 10,000»gallon capacity of the tank and
approximately 3.5"ofaccumulation ofrainfWl. This
tank is covered by a canopy which diverts rainwater
from accumulating in the containment area.
K083 Aniline Tar Feed Tank at Boiler House Procedural BMPs: The tank area is inspected daily and the concrete dike
(S-5) and sump in this storage area are inspected after each
shift for stormwater accumulation. Stormwater
accumulation in the sump or diked area is manually
pumped out to the hazardous wastewater tanker. Filling
the tank is limited to 8,400 gallons or less to allow for
the containment of the contents of the tank plus allow
for freeboard(see Table 1,S-19,Table 2,and Table 5,
W-17).
Page 1 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
thoirlevel of potential impact to stormwater,including frequency
or movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Structural BMP.
Location: West of building 101 in Drainage Zone 3B
Materials: The following materials are stored on the east side of
the building:compressed gas cylinders;surplus motors
and metal parts;wooden pallets;piping;and the piping
rack storage within a metal fence. The following
materials are stored on the north side of the building:
miscellaneous equipment and parts from the production
Maintenance Building(Building 903) lines;APAP hoppers;and empty synthetic lubricant
(S-6)* drums.The following materials are stored on the west
side of the building;a parts washing system;wooden
boxes;and miscellaneous equipment and parts from the
production lines. The following materials are stored on
the south side of the building:miscellaneous equipment
and parts from the production lines;cardboard boxes;
and scrap metal.
Structural BMPs: None related to stormwater.
Procedural BMPs: None Related to stormwater.
Location: Northwest of Building 903,north of Building 903,and
west of Building 201 near power transmission line
Used Equipment Storage Areas (south of Hill Tank Farm)in Drainage Zone 3B
Materials: New and used surplus equipment
(S 7)
Structural BMPs: None related to stormwater
Procedural BMPs: All equipment,parts and scrap material must not
contain,or must be cleaned to remove,significant
material residues,including draining of oils or hydraulic
fluids,prior to being stored in this area. Insulation must
be removed prior to being stored in this area.
Location: 'Northwest of building 903 in Drainage Zone 3B
Materials: Four hydrogen tanks:two containing gaseous hydrogen
and two containing liquid hydrogen
Structural BMPs: None related to stormwater
Hydrogen Tank Farm Procedural BMPs: None related to stormwater,as this area is not a
(S-8)* stormwater concern due to the fact that at normal vapor
pressure hydrogen is in the ps phase.
Location: North of building 903 in Drainage Zone 3B
Materials: Empty totes and empty drums which once contained
raw materials
Structural BMPs: None relating to stormwater
Procedural BMPs: Returnable totes are not rinsed prior to returning to the
vendor but valves are shut prior to placing in the storage
area. Most empty used drums are rinsed and/or drained
and crushed prior to placing in dumpsters for off-site
Empty Container Storage Area recycled or disposal and generally are not stored or
staged in this area. However,prior to being placed in
(S-9) this storage area,non-returnable and general returnable
drums must be thoroughly rinsed prior to being
returned. Returnable totes in good condition including
hydrogen peroxide,ethomeen,and aqua ammonia are
not rinsed but are stored here and returned to the vendor
for reuse. There is also an Empty Container Standard
Operating Procedure that personnel follow for the
handling ofempty containers.
Page 2 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stermivater,including frequency
of movement of materials,volume of ninterials,location 0 facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BNIPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Strocuu-al BMP.
Location: Southwest of the ammonia tanks and northwest of the
empty drum storage area in Drainage Zone 3B
Materials: Acetic acid 20%,nitrobenzene,hydrogen peroxide,
acetic anhydride,and aniline.
Structural BMPs*: This storage area has a divided concrete dike which
allows for segregation of incompatible materials should
a spill occur. There is a sump located in each of the
diked areas. The tanks in this area arc:also equipped
with overflow detection devices.The containment dike
for tank T-8 and the containment dike for Tanks T-1,2,
Hill Tank Farm 6 and 7 have a notch in the top of the containment wall
(S-10) dividing them so the dikes act as one larger containment
area for all 5 tanks. The containment area for Tanks 1,
2,6 and 7 is 124.5'x 49'x 3.6'. The containment area
for T-8 is 34'x 50.5'x 3'. This containment area can
hold the volume of the largest tank(135,0000 gallons)
and rainwater accumulation.
Procedural BMPs: Stormwater is allowed to accumulate in the locked
sumps and inspected for visual signs of impact.
Stormwater is typically pumped to the process sewer
(WWTP). Excessive rainfall may require discharge
onto the ground;however,the slonnwater is sampled
prior to ground discharge.
Location: Southwest of buildings 201-205,northeast of the tank
farm on the hill in Drainage Zone 3B
Materials: Anhydrous ammonia(gaseous)
Structural BMPs: The tanks are surrounded by an earthen berm.
Ammonia Tanks Procedural BMPs: Stormwater that collects in the earthen bean is
(S-12) inspected by the Mallinckrodt PAP Department. If the
stormwater is found to be clean,it is pumped out from
the comer drain and is discharged into the stormwater
ditch system. A lock has been placed on the sump
pump in this area.
Location: Northeast of building 51A and southwest of building
101 in Drainage Zone 3B
Materials: APAP(granular and powder),PAP,bottles with caps,
Building 100 cardboard packaging,filter paper,filter cloth,safety
(S-13)* absorbent,dense soda ash,20 gal drums citric acid,rock
salt,cleaner,and urea.
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: On the southwestem side of building 101 in Drainage
Zone 3B
Materials: Potassium hydroxide,second crop mother liquors,
APAP mother liquors and crude mother liquors.
Largest tank in this area is approximately 11,000
Tank Farm West of Building 101 gallons)
(S-14) Structural BMPs*: The tanks in this area are contained by a dike. The dike
drains into a sump that drains to the process sewer
system. The dike is approximately 49.5'x 20.5'x 2'.A
locked sump is located in the diked area and can release
accumulated materials to the process sewer.
Procedural BMPs: None related to storm water
Page 3 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Rest Management Practices(8MPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations tat c into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the 5lructural BMP.
Location: North of building 101 and south of building 201 in
Drainage Zone 3B
Materials: Acetic acid(Largest tank is 29,000 gallons),APAP
process wastewaters with acetic acid(Largest tank is
8,500 gallons).
Structural BMPs*: This storage area contains two concrete diked areas
North of Building 101 separating four acetic acid tanks(65'x 33'x 2.5')and
Acetic Acid Tanks- two process tanks(33'x 33'x 2.5'). Each diked area
(SNo
has a drainage trench equipped with a sump. This dike
provides sufficient containment for the volume of the
largest tank in the dike and rainwater accumulation
from a 25 year-24 hour storm event.
Procedural BMPs: The Sump in the diked area is operated in the locked
closed position. Stormwater is pumped to the process
sewers stem.
Location: Northeast of building 101 and east of Tank Farm(S-15)
in Drainage Zone 3B
Materials: Dried PAP in tote bins and bulk bags,along with
miscellaneous equipment
Structural BMPs: Curbed areas divert rainwater to the site process sewer
PAP Storage system.
(S-16) Procedural BMPs: The valves on the bottoms of the tote bins are closed
and the bins are rinsed with water to remove excess
PAP from the outside of the bins before placing the bins
outside,
Location: North of building 201 in Drainage Zone 3B
Materials: Raw materials including:cardboard,catalyst,empty 55-
Building 200/204 PAP Warehouse gal metal drums,PAP in supersacks and drums,sodium
(5-18)* hydrosulfite drums,sodium metabisulfrte drums,
ethomeen,and defoaming agent.
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: On the northeastern comer of building 205 in Drainage
Zone 3B
Materials: K083 aniline still bottoms
Structural BMPs*: The tanks(T-384 and T-385)in this storage area are
covered by a canopy and built with secondary
containment in the form of a concrete dike(45'x 20.5'
K083 Aniline Tar Storage Tanks at 205 x 2')that provides sufficient containment for the largest
(S-19) tank and the minimal amount of rainwater that could be
accumulated. Additional needed secondary
containment is provided by the process sewer in this
area.
Procedural BMPs: Filling Tanks 384 and 385 is controlled by a level
gauge. Any accumulated stormwater is pumped to the
hazardous wastewater tanker(Table 6,W-17).
Page 4 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BNTs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Structural BMP_
Location: East of building 205 in Drainage Zone 3B
Materials: Hazardous waste,solid wastes,drums of spent catalyst
for recovery,empty drums,boxes of methanol,plastic
totes of aqua ammonia,plastic totes of hydrogen
peroxide,and fuel for fire-training purposes
Structural BMPs: The hazardous waste storage pad has a full roof and
walls on the north,east,and south sides. There are 4
separate bays segregated by a short knee wall. This
area also has a concrete pad that has epoxy coating and
is sealed with"Waterstop". The base is sloped to 4
separate collection trenches in the rear of the storage
area. There is also a speed bump on the western side
that is open for roadway access and prevents rainwater
from running onto the pad.
Hazardous Waste Storage Pad Procedural BMPs: Incompatible wastes/materials are segregated and not
(S-20) placed within the same storage bay. Hazardous and
solid wastes materials are generally stored in
appropriate new containers depending on the nature of
the hazardous waste or hazardous material to ensure no
incompatible materials stored in the same bay. When
using 55-gallon drums,the drums that are sealed are
then placed four to a pallet(maximum)with all drums
touching to prevent tipping. Provisions are made to
stack drums at safe heights and adequate aisle space is
maintained between the pallets. Stormwater
accumulation in the drainage trenches at the base of the
pad is typically evaporates. Should excess stormwater
accumulate in this trench,a vac truck collects the
stormwater and trans ort$to the WWTP for disposal.
Location: Southeast of the WWTP in Drainage Zone 3B
Materials: Urea 46%N,hydrated lime,PAP,APAP,pumps and
Building 10 Warehouse miscellaneous equipment.
(S-22)* Structural BMPs: None related to stormwater.
Procedural BMPs: None related to Slormwatcr.
Location: Northeast of the WWTP in Drainage Zone 3B
Materials: Acetic acid,phosphoric acid,and a mixture of calcium
and magnesium hydroxide.
Structural BMPs*: The three storage tanks are located in a segregated
concrete dike. The Magnesium hydroxide tank(10,000
gallons)is located in an area 23.5'27.5'x 3.5'. The
acetic acid(6,000 gallon)and the phosphoric acid
Tank Farm at WWTP (5,000 gallon)tanks are located in an adjacent
(5-23) containment dike measuring 22.25'x 27.5'x 3.5'.
Each diked area has a drainage valve that is maintained
in the locked closed position. There is sufficient
containment for the volume of the largest tank and
rainwater accumulation in each of the dikes.
Procedural BMPs: The stormwater that collects in the diked area is
checked visually for signs of contamination and for
odor prior to being manually pumped back to the
WWTP
Page 5 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"s"near
the Structural BMP.
Location: Northwest of the PAP Plant in Drainage Zone 3B
Materials: Ammonium sulfate. (Largest tank volume of five tanks
in this area is 4 million gallons.)
Structural BMPs*: The MASL tanks are field-erected tanks equipped with
MASL Aboveground Storage Tanks synthetic liners and leak detection systems. In addition,
(S-25)* secondary containment for the N4ASL storage tank area
is provided by the onsite retention pond which has a
containment volume of approximately 15 million
gallons).
Procedural BMPs: None related to stormwater
Location: Northeast ofbuilding 101 in Drainage Zone 3B
Materials: PAP(in drums,super sacks and bins)and lime.
Warehouse in Building 105 Structural BMPs: None related to storm water.
(S-26)* Procedural BMPs: None related to stormwater.
Location: Southeast of the boiler house(Building 901)and west
of the building 51 warehouse in Drainage Zone 2
Materials: Fuel(unleaded gasoline and diesel). Total volume is
1,280 gallons)
Structural BMPs: The above ground storage tanks are housed in a
recessed concrete containment area. A 14'x 29'x 6"
high,sloped concrete berm for truck unloading was
added to an existing 10'x 29'x 14"area(8"of this area
being recesses)where the tanks are located. This
Vehicle Fuel Storage Area containment provides sufficient containment for the
(S-27) tanks and rainwater accumulation.
Procedural BMPs: There are no drains from this area.Stormwater that
accumulates in the dike and in the bermed pad is
visually inspected by the Mallinckrodt Warehouse
Department For signs of contamination and odor. If no
impacts arc identified,the water is manually pumped to
the stormwater ditch located east of the fuel storage
area. A lock has been placed on the sump pump in this
area.
Location: On the northeastern comer of building 201 in Drainage
Zone 3B
Materials: Aniline,ammonium bisulfite(Largest tank is 8,100
gallons)in West Dike;aniline(10,000-gallon tank)in
East Dike.
Structural BMPs*: These storage tanks are located in concrete dikes(East
201 Storage Tanks Dike:35'x 18'x 4.5';West Dike: 18'x18'x5')that have
(S-30) sumps which are pumped to the above-ground process
sewer. Sufficient containment for the largest tank and
rainwater accumulation is provided in these concrete
dikes.
Procedural BMPs: Stormwater that accumulates in the diked area is
manually released to the process sewer.
Location: East side of Building 901(boiler house)in Drainage
Zone 2
Storage Materials: Plastic bags of rock salt
Rock Salt Structural BMPs: None related to stormwater
(S-3
Procedural BMPs: Provisions are made to store materials in original
containers and stack containers on wooden pallels.
Page 6 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area, Areas requiring containment is noted with an"x"near
the Structural BNT.
Location: North of building 2 adjacent to the drainage ditch in
Drainage Zone 3B
Propane Aboveground Storage Tank Materials: Propane
(S-35)* Structural BMPs: None related to stormwater
Procedural BMPs: None related to stormwater.
Location: North of fuel storage area in Drainage Zone 2
Propane Aboveground Storage Tank Materials: Propane
(S-38)* Structural BMPs: None related to stormwater
Procedural BMPs: None related to stormwater.
Location: Building 901(Boiler House)in Drainage Zone 2
Materials: Corrosion inhibitor,potassium hydroxide,sodium
bisulfite,sodium hydroxide,sodium tripolyphosphate,
Building 901,Boiler Treatment Chemicals and Distilled resin cleaner,fuel oil additive,synthetic compressor
Water Chemical Storage Area lubricant,rock salt,and boiler treatment chemicals.
(S-39)* Structural BMPs: This storage area is inside of a fully enclosed building
with concrete flooring and no floor drains.
Procedural BMPs: Provisions are made to stack drums at safe heights and
lase drums on pallets.
Location: North of Building 903(Maintenance Building)in
Drainage Zone 3B
Materials: Three electrical infrastructure transformers are located
in this area. The volume of transformer oil in each one
is 487,392,and 478 gallons.
Structural BMPs: A 2-inch high,crush-and-run gravel dike surrounds this
transformer station that is owned,operated and
maintained by Duke-Energy. Accumulated rainwater
Duke-Energy Substation percolates through gravel or evaporates. Should a spill
(S-41) leave this area,a series of storm water conveyances
with control valves throughout the site would contain
the release.
Procedural BMPs: The substation is periodically inspected by Mallinckrodt
personnel for indicators of contamination(color,foam,
sheens,stains and odor).Duke-Energy will be contacted
immediately if physical indicators of contamination are
observed.
Location: North of Building 2(Administration Building)in
Drainage Zone 3B
Materials: Approximately 134 gallons of transformer oils are
contained in electrical equipment at this substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
substation if found to be leaking. Any materials leaving
Transformer Substation No. 1,Near Building 2 the dike area will be collected in a series of stormwater
conveyances with control valves located throughout the
(S-42) site.The dike is located within a locked fenced area.
Procedural BMPs: The substation is periodically inspected by Mallinckrodt
personnel for indicators of contamination and who have
been trained to close the dike valve if oil leaks are
observed. The substation is also inspected semi-
annually as a part of the stormwater inspection
ono
Page 7 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"s"near
the Struc[ural UMP_
Location: North of Building 903(Maintenance Building)in
Drainage Zone 3B
Materials: Approximately 131 gallons of transformer oils are
contained in electrical equipment at this substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
substation. Any materials leaving the dike area will be
Transformer Substation No.2,Near Building 903 collected in a series of storm water conveyances with
(S-43) control valves located throughout the site. The dike is
located within a locked fenced area.
Procedural BMPs: The substation is periodically inspected by
Mallinckrodt personnel for indicators of contamination
and who have been trained to close the dike valve if oil
leaks are observed.The substation is also inspected
semi-annually as a part of the stormwater inspection
rp,Oran.
Location: East of Big Mac(raw waste surge tank)in Drainage
Zone 3B
Materials: Approximately 300 gallons of transformer mineral oil is
contained in electrical equipment.
Structural BMPs: Transformer is contained in weatherproof enclosure on
Duke-Energy Transformer Substation No. 1,Near Big Mac concrete pad.
Procedural BMPs: The substation is periodically inspected by Mallinckrodt
(S-47) personnel for indicators of contamination.Duke-
Energy will be contacted immediately if physical
indicators of contamination are observed. The
substation is also inspected semi-annually as a part of
the stormwater inspection program.
Location: West of Building 10 in Drainage Zone 3B
Materials: Approximately 145 gallons of transformer mineral oil is
contained in electrical equipment.
Structural BMPs: Transformer is contained in weatherproof enclosure on
Duke-Energy Transformer Substation No.2,West of Building concrete pad.
10 Procedural BMPs: The substation is periodically inspected by Mallinckrodt
personnel for indicators of contamination or release.
(S-48) Duke-Energy will be contacted immediately if physical
indicators of contamination are observed. The
substation is also inspected semi-annually as a part of
the stormwater inspection program.
Location: North of the Wastewater Treatment Plant in Drainage
Zone 3B
Materials: Approximately 380 gallons of transformer mineral oil is
contained in electrical equipment
Structural BMPs: Transformer is contained in weatherproof enclosure on
Duke-Energy Transformer Substation No.3,Near Wastewater concrete pad.
Treatment Plant Procedural BMPs: The substation is periodically inspected by Mallinckrodt
(S-49) personnel for indicators of contamination or release.
Duke-Energy will be contacted immediately if physical
indicators of contamination are observed. The
substation is also inspected semi-annually as a part of
the stormwater inspection pro ram.
Page 8 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Mpaagement Practices(BMPS)
NOTE:Assooiated Required Secondary Conlainment is described under structural
Storage Area SNTs. All containment calculations take into cfl'ccl the displacement ortbe tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Structural BW-
Location: Building 907 in Drainage Zone 3B
Materials: Lubricant and waste oil drums and a 500-gallon waste
oil tank.
Structural BMPs: Tanks and drums are housed in a 46'by 51'6"fully-
enclosed building with a concrete floor and no floor
drains. A 1,100 gallon containment pan is provided
for the 500 gallon used oil tank. Any materials leaving
Building 907 Oil Storage the building will be collected in a series of storm water
(S-50)* conveyances with control valves located throughout the
site.
Procedural BMPs: Provisions are made to place drums and materials on
pallets and stack pallets at safe heights. Spill control
materials are readily available.
Location: West of the fire training area in Drainage Zone 2
Materials: Paint,fuel,piping,compressed gas.
Structural BMPs: Trailers prevent contact with stormwater for most
Contractor Trailer Area chemicals.
(S-51) Procedural BMPs: Most chemicals are not stored outside the trailers.
Portable containment usually provided for chemicals
stored outside or at least chemicals stored n pallets so
not standing in water.
Location: West of Building 201 near catalyst wash area in
} Drainage Zone 3B
Ethomeen Building Materials: 3 totes containing Ethomeen C-12 and 1 tote of
(S-52)* defoaming agent.
Structural BMPs: Building prevents contact with stormwater.
Procedural BMPs: Chemicals are not stored outside the building.
Location: Off south end of Building 901(Boiler House)in
Drainage Zone 3B
Materials: Approximately 421 gallons of silicone-based dielectric
fluid are contained in electrical equipment at this
substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
Transformer Substation No.8,Near Building 901 substation. Any materials leaving the dike area will be
(S-53) collected in a series of storm water conveyances with
control valves located throughout the site. The dike is
located within a locked fenced area.
Procedural BMPs: Applicable personnel are trained to close the dike valve
if oil leaks are observed.The substation is also
inspected semi-annually as a part of the stormwater
inspection
Location: North of building 205 in Drainage Zone 3B
Materials: Dried PAP in bulk bags,off-spec process liquors,
miscellaneous equipment
PAP Rework and Temporary Chemical Storage Structural BMPs: Area is covered by a canopy to minimize contact with
(S-54)(formerly L-5) rain,plus area is curbed with a sump so accumulated
rainwater can be sent to the site process sewer system.
Prcccdural BMPs: The materials are stored on pallets or in tote bins.
Page 9 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to storm«ater,including frequency
of movement of materials,volume of materials,location al facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"""near
tho Structural BMP.
Location: North end of building 101 in Drainage Zone 3B
Materials: Northwestern Dike-Recovered Acetic Acid and
Hydrogen Peroxide(Largest Tank is 1,500 gallons);
Northcentral Dike-Process Liquors containing Acetic
Acid(Largest Tank is 2,000 gallons);Northeastern
Dikes A/13-Process Liquors containing Acetic Acid
(Dike A:Largest tank is<3,000 gallons;Dike B:
Largest tank is 6,000 gallons)
Tank Farm North of 101(S-55) Structural BMPs: The tanks in this area are contained by four separate
dikes. Each dike drains into a sump that pumps into the
process sewer system. North=tcrn Dike A is
approximately 37'x 13'x 2',Northeastern dike B is
approximately 36'x 2 P x 3',Northcentral Dike is
approximately 19'x 13'x 2',and Northwestern Dike is
approximately 36'x 18'x 2'.A sump is located in each
diked area and can release accumulated stormwater to
the process sewer.
Procedural BMPs: Stormwater is not discharged to the ground in this area.
Location: Southwest of the ammonia tanks and northwest of the
empty drum storage area in Drainage Zone 3B
Materials: Sulfuric acid. (Largest Tank is 28,000 gallons)
Structural BMPs*: This storage area has a concrete dike(27'x 73'x 3.5').
There is a sump located in the diked area. The
Sulfuric Acid Tank Farm(5-56) containment area(capacity of 42,000 gallons)is
sufficient for the volume of the largest tank and
rainwater accumulation.The tanks in this area are also
equipped with overflow detection devices.
Procedural BMPs: Stormwater is allowed to accumulate in the sump and
inspected for visual signs of impact.Stormwater is
typica!!y. pumped to the proms sewer(WWTP).
Location: Wastewater Treatment Plant Area in Drainage Zone 3B
Materials: Approximately 82 gallons of diesel is contained is
contained in generator.
Structural BMPs: The generator is located in a roofed area with a
WWTP Back-up Diesel Generator(S-57) secondary containment area capable of containing a
release of the oil in the generator and any rainwater that
may be accumulated in the dike under the canopy.
Procedural BMPs: The generator is periodically inspected by Mallinckrodt
personnel for indicators of contamination or release.
Location: Wastewater Treatment Plant Area in Drainage Zone 3B
Materials: Anti-Foam Agent in two totes.
Anti-Foam Dike area in WWTP(5-58) Structural BMPs: This area is contained in concrete curbed shed south of
the tank farm at WWTP.
Procedural BMPs: The area is periodically inspected by Mallinckrodt
personnel for indicators of contamination or release.
Location: South of building 903 in Drainage Zone 3B
Materials:
Structural BMPs: The Boiler and ancillary piping are located in a concrete
dike that has a drainage trench equipped with a sump.
Boiler No.7(S-59) This equipment is located in the same dike as the Cloud
[Co-located with Scrubber System(P-5)] Chamber Scrubber(see Table 4,P-5).
Procedural BMPs: Stormwater is allowed to accumulate in the sump and
inspected by Elie Mallinckrodt Utilities Department for
visual signs of impact. Based on prior approval by the
City of Raleigh POTW,stormwater is pumped to the
condensate sewers stem.
Page 10 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Structural BMP.
Location: East of Building 200
Materials: Compressor Oil
PAP Plant Compressor(S-60) Structural BMPs: Sloped areas divert rainwater to the site process sewer
system.
Procedural BMPs: None related to stormwater.
Location: East of Building 101(APAP Plant)in Drainage Zone
313
Materials: Approximately 421 gallons of silicone-based dielectric
fluid are contained in electrical equipment at this
substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
Transformer Substation No.9,East of Building 108 substation. Any materials leaving the dike area will be
(S-61) collected in a series of storm water conveyances with
control valves located throughout the site. The dike is
located within a locked fenced area.
Procedural BMPs: Applicable personnel are trained to close the dike valve
if oil leaks are observed.The substation is also
inspected semi-annually as a part of the stormwater
inspection ETgaM.
Location: Southeast of the Firewater'f ani in Drainage Zone 1
Materials: Approximately 312 gallons of transformer mineral oil is
contained in electrical equipment
Structural BMPs: Transformer is contained in weatherproof enclosure on
Duke Energy Transformer Substation No.4, concrete pad.
Procedural BMPs: The substation is periodically inspected by Mallinckrodt
Near Firewater Tank personnel for indicators of contamination or release.
(S-62) Duke-Energy will be Contacted immediately if'physical
indicators of contamination are observed. The
substation is also inspected semi-annually as a part of
the stormwater inspection program.
Location: East of Building 51 in Drainage Zone 1
Building 913-Fire Pump House Materials: Diesel in firewater water.
(S-63)* Structural BMPs: None related to storm water.
Procedural BMPs: None related to starm►yater.
Location: Fire Training Area in Drainage Zone 2
Materials: Nitrobenzene,Sulfuric Acid
Structural BMPs: The fire training area is located on a concrete diked pad
approximately 113'x 99'x 1.5'that slopes to a sump
on the southern end ofthe pad, The sump is operated in
a locked and closed position.
Bulk Chemical Isotainer/Tanker Truck Storage/Staging,Fire Procedural BMPs: Collected rainwater in the sump is inspected by the
Training Area Mallinckrodt Utilities Department and then manually
(S-64) pumped to the stormwater conveyance ditch located
east of the training area. A lock has been placed on the
sump pump in this area. In addition,Mallinckrodt EHS
personnel inspect the containment system
approximately weekly. The EHS Department ensures
that onlv com atible materials aze stored in this area.
Page 11 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for material storage areas were chasm based on
their level of patential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Structural Blv1P.
Location: Southwest Corner of the Wastewater Tr7pan
Materials: Sodium Hypochlorite
Structural BMPs: Single tote is stored on a secondary contthat can hold the entire contents of the cCollected rainwater is tested for pH prio
Bleach Tote Storage at WWTP into Al Basin.
(S-65) Procedural BMPs: Collected rainwater in the sump is inspected by the
Mallinckrodt Utilities Department and then manually
pumped to Al Basin if not contaminated.
Contaminated rainwater is evaluated for potential off-
site disposal.
Notes:
• (S-4) Former No.6 Fuel Oil Tank has been completely removed from the site.
• (S-11) Former Bulk Acetic Acid Bladder Tank has been completely removed from the site(in 1996).
• (S-17) Former Spent Catalyst Storage Area is not in use;moved to Hazardous Waste Pad(S-20)in 2016.
• (S-21) Former Storage Area West of Shot Pond has been completely removed from the site.
■ (S-24) Former Washing Area/Catalyst Storage Area was demolished and operations incorporated into
Building 201 as part of the Mott Filter Project in 2017.
• (S-28) Former Flammable Liquids Storage Area has been completely removed from the site.
• (S-29) Former Storage Pad northwest of Environmental Lab(WWTP area)
• (S-32) Former Waste Toluene Storage Tank Area has been completely removed from the site(in 2000).
• (S-33) Former Day Tanks at Building 201 have been completely removed from the site(in 1996).
• (S-34) Former Day Tanks at Building 205 have been completely removed from the site(in 1996).
■ (S-36) Former Corrective Action Roll-off Storage is a practice no longer utilized at the site.
• (S-37) Wastewater Filter Solids Accumulation Area is no longer utilized at the site.
• (S-40) Hydrogen Peroxide Tote location moved to the Hill Tank Farm(S-10)in 2009.
• (S-44) Former Substation 3 being held for potential re-use was removed from the Fire Training Field in
2021.
• (S-45) Former Substation 4 being held for potential re-use and associated tote of transformer oil was
removed from the Fire Training Field in 2021.
• (S-46) Substation 5B was removed from east of Building 200 and replaced with a dry-type transformer in
2021.
* Denotes areas not inspected because no significant exposure to stormwater
Page 12 of 12

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised December 2021
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and tv a of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: On the east and south sides of the building 51 warehouse,in
Building 51 Warehouse Loading/Unloading Drainage Zones 1 and 2
Materials: APAP(granular and powder)
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: On the eastern and western sides of the building 51A warehouse
in Drainage Zones 2 and 3B
Building 51A Warehouse Loading/Unloading Materials: Raw materials(see Table 1,S-2)
(L-2)* Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: North of building 101 and south of building 201,in Drainage
Zone 3B
Materials: Acetic acid.
Structural BMPs: A trench drain leading to a manually controlled sump that
discharges into the process sewer system collects run-off from
this material transfer area. An asphalt berm diverts run-off in
Acetic Acid Loading Stations this area to the process sewer.
North of Building 101 Procedural BMPs: Before loading/unloading procedures begin,operators make
(L-3) sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators are also present during loading and unloading
operations,and monitor the levels of materials in the tanks to
prevent overflow ands ill,and to observe for leaks.
Location: West of buildings 101 and 205 in Drainage Zone 3B
Materials: Nitrobenzene,sulfuric acid,and acetic anhydride are received
in this area;aniline,ammonium sulfate,and acetic acid are
shipped from this area.
Structural BMPs: The nitrobenzene railcar transfer areas are equipped with
collection pans that drain to a 1,000-gallon sump. The aniline
rail car transfer area is equipped with a collection pan that
drains to a 500-gallon sump. The sump is equipped with a
pump so that the contents can be collected and used or
discharged to the site process sewer system. Sulfuric acid
Railcar Area Loading/Unloading railcar transfer areas consist of lime to neutralize any spilled
(L-4) material. Additional secondary containment would be
provided by the series of valve-controlled ditches located
onsite.
Procedural BMPs: Before loading/unloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators also present during unloading and monitor the levels
of materials in the tanks to prevent overflow and spill and to
observe for leaks.
Page 1 of 7

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised December 2021
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and type of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: North of the WWTP and cast of the flushwater pond in
Drainage Zone 3B
Materials: Acetic acid,phosphoric acid,and liquid magnesium hydroxide
Structural BMPs: Wastewater treatment chemical loading/unloading occurs on a
concrete pad with a 5"sloped concrete berm.The sloped berm
allows vehicle access,but provides containment.The pad is
approximately 47'by 14'and is constructed in a roadway,and
is sloped toward a sump. The capacity of the loading area is
approximately 1,900 gallons. The sump has a level switch and
accumulated water in the loading area is pumped into the dike
around the liquid magnesium hydroxide tank,which has a
Tank Farm at WWTP Unloading capacity of approximately 13,000 gallons. A lock has been
(L-6) placed on the sump pump in this area.
Procedural BMPs: Before loading/unloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators also monitor the levels of materials in the tanks and
the transfer operations to prevent overflow and minimize the
impact of any spill. Water accumulated in the dike is checked
visually by the Mallinckrodt Utilities Department for signs of
contamination and odor prior to being manually pumped to the
WWTP(see Table 2,S-23).
Location: Southeast ofthe WWTP in Drainage Zone 3B
Materials: APAP and PAP
Structural BMPs: This loading/unloading area has two loading docks with bumper
pads which provide a tight seal between the building and trucks,
a canopy and a driveway which is sloped towards the building.
The area is paved and contains a catch basin at each loading
Building 10 Warehouse Loading/Unloading dock that drains to the storm water system.The majority of the
(L-7) materials handling operations are contained inside the trailer
and warehouse. Secondary containment for this area would be
provided by the onsite retention pond.
Procedural BMPs: Provisions are made to place materials on pallets and stack
pallets at safe heights. Absorbent materials are also readily
available in this area. The catch basins are cleared of leaves
and debris as needed.
Page 2 of 7

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised December 2021
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and tv a of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: On the north side of the 42 fuel oil aboveground storage tank
(S-3)in Drainage Zone 3B
Materials: No.#2 fuel oil
Structural BMPs: Top loading/unloading operations are conducted at this truck
loading/unloading station. The station,consisting of concrete
dike walls on the east and west sides,concrete ramps on the
north and south sides(68'x 13'),and a trench drain and sump
at the low point has sufficient capacity to contain the volume of
one compartment of a 7,500 gallon tanker truck plus freeboard
for rain accumulation. An operator is present at all times during
No.2 Fuel Oil/Caustic Unloading Area unloading operations and any leaks or failures in the hoses,etc.
(L-9) would be corrected immediately.
Procedural BMPs: Before unloading procedures begin,Utility operators make sure
that wheels are chocked,that the vessel is in good condition,the
vessel is vented(if it is pressurized),and that the hoses,pumps,
and lines do not have leaks in accordance with area-specific
fuel unloading procedure in the site's Oil SPCC Plan(see Table
1,S-3).Operators also monitor the levels of materials in the
tanks to prevent overflow and spill.The sump is pumped to the
stormwater ditch located west across the roadway. A lock has
been placed on the sump p mp in this area.
Location: On the eastern side of building 100 in Drainage Zone 3B
Loading/Unloading Dock at Building 100 Materials: New,empty fiber pack drums and chemicals in drums and bags.
Structural BMPs: None related to stormwater.
(L-10)* Procedural BMPs: None related to stormwater.
Location: South of the MASL Storage Tanks in Drainage Zone 3B
Materials: Ammonium sulfate(MASL)
Structural BMPs: Each of the two-loading/unloading areas has a sloped concrete
pad,berms around the concrete pad,and a sump with a total
capacity of approximately 3,500 gal. The sumps have pumps
with float switches that pump collected materials to MASL
Tank#1. This provides enough containment for the volume of
one compartment of a tanker truck plus rainwater accumulation.
Procedural BMPs: Truck drivers are responsible for implementing procedures to
minimize the likelihood of a release from the truck loading
MASL Loading operation. Before loading/unloading procedures begin,drivers
(L-11) make sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks. A
metered loading system automates the loading process and
minimizes the possibility of overfill.Drivers are responsible for
checking the truck valve to ensure it is secure before leaving the
site. Failure to comply will ban the driver from receiving any
future loads of MASL. Accumulated water is generally
pumped to MASL Tank#1.
Page 3 of 7

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised December 2021
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and type of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: Southeast of the boiler house(Building 901)and west of the
building 51 warehouse in Drainage Zone 2
Materials: Gasoline and diesel fuel
Structural BMPs: An additional,bermed 14 feet was added to the length and
another 6"added to the height of the existing recessed 10'x
29'x14"fuel tank containment area. The sloped berm allows
vehicle access,but provides containment(see Table 1,5-27).
Sufficient containment is provided for a 2,500 gallon tanker
truck and 1,400 gallons of rainwater accumulation from a 25
year-24 hour storm event. Containment for the additional 1,300
gallons of possible accumulated rainwater would be provided
by the adjacent valve-control storm water ditch. An operator is
Vehicle Fuel Loading/Unloading present during all unloading operations and a failure or rupture
(L-12) would be addressed immediately.
Procedural BMPs: Before unloading procedures begin,Utility operators make sure
that wheels are chocked,that the vessel is in good condition,the
vessel is vented(if it is pressurized),the vessel is grounded(if it
contains flammable material),and that the hoses,pumps,and
lines do not have leaks in accordance with specific fuel
unloading procedures in the site's Oil SPCC Plan. Operators
also monitor the levels of materials in the tanks to prevent
overflow and spill. There are no drains from this area.
Stormwater that accumulates in the dike and in the bermed pad
is manually pumped to the stormwater ditch just east of this
area. A lock has been placed on the sump pumpin this area.
Location: Northeastern comer of building 201,in Drainage Zone 3B
Materials: Aniline,ammonium bisulfite
Structural BMPs: This loading/unloading area has a sloped concrete pad,a sump
and dike along the western end of the pad,dikes on the northern
and southern sides of the pad,and a berm on the eastern end of
the pad(this berm was moved approximately 20 ft.to the west
in 2004 to facilitate drainage). Stormwater accumulated in the
sump is pumped to the process sewer system. Drainage will
Aniline Truck Loading/Ammonium Bisulfite allow all stormwater to flow by gravity to the process sewer.
Truck Unloading The existing loading/unloading area has a capacity of
(L-13) approximately 2,000 gallons.
Procedural BMPs: Before loading/unloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators also monitor the levels of materials in the tanks as
well as the transfer operations to prevent overflow and spill.
Location: West Side of Building 200 in Drainage Zone 3B
Materials: PAP
Structural BMPs: This loading/unloading area has a driveway that slopes south to
three catch basins that drain to the condensate sewer system via
West Side PAP Loading/Unloading industrial discharge agreement. There is also roof over the
(L-14) loading and unloading platform.
Procedural BMPs: Provisions are made to place materials on pallets and stack
pallets at safe heights. Absorbent materials are also readily
available in this area. Materials are moved inside as soon as
possible and not stored on the loading platform.
Page 4 of 7

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt Pharmaceuticals[SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised December 2021
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and type of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: Northeast of building 903 in Drainage Zone 3B
Materials: Anhydrous ammonia
Structural BMPs: This concrete diked loading/unloading area slopes and drains to
a sump. Rainwater collected in the sump is manually pumped
by the Mallinckrodt Warehouse Department to the stormwater
Anhydrous Ammonia Unloading Area conveyance ditch. A lock has been placed on the sump pump in
this area.
(L-17) Procedural BMPs: Before loading/unloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,and that the hoses,pumps,and lines do not have
leaks. Operators also monitor the levels of materials in the
tanks to prevent overflow and spill.
Location: Northeast of building 903 in Drainage Zone 3B
Materials: Sulfuric acid
Structural BMPs: This concrete diked unloading area slopes and drains to a sump.
Material collected in the sump is manually pumped to the
process sewer system. Operators are present during the
Sulfuric Acid Unloading Area unloading operations and can manually discharge to process
(L-18) sewer.
Procedural BMPs: Before unloading procedures begin,operators make sure that
wheels are chocked,that the vessel is in good condition,and
that the hoses,pumps,and lines do not have leaks. Operators
also monitor the levels of materials in the tanks to prevent
overflow ands ill.
Location: Northeast of building 903 in Drainage Zone 3B
Materials: Nitrobenzene or Caustic(Sodium hydroxide or Potassium
hydroxide).
Structural BMPs: This loading/unloading area has a concrete containment berm
with a capacity of 6,000 gallons. This concrete diked
Nitrobenzene/Caustic Unloading Area unloading area slopes and drains to a sump. Materials collected
(L-19) in the sump is manually pumped to the process sewer system.
Procedural BMPs: Before unloading procedures begin,operators make sure that
wheels are chocked,that the vessel is in good condition,and
that the hoses,pumps,and lines do not have leaks. Operators
also monitor the levels of materials in the tanks to prevent
overflow ands ill,
Location: Adjacent to Building 907 in Drainage Zone 3B
Materials: Used Oil
Structural BMPs: This concrete loading area slopes to a stormwater conveyance
ditch that contains a gate valve that is operated in the locked
position. This storm water conveyance provides secondary
containment for this area.
Procedural BMPs: Only Environmental Staff are able to oversee the loading of
used oil and signing of the manifest. Before unloading
Used Oil Loading Area(L-20) procedures begin,Environmental personnel make sure that
wheels are chocked,that the vessel is in good condition,and
that the hoses,pumps,and lines do not have leaks plus verifies
that the valve in the stormwater drainage ditch located north of
the Hydrogen Plant is locked in accordance with area-specific
fuel loading procedure in the site's Oil SPCC Plan. The person
also monitors the levels of materials in the tanks to prevent
overflow and spill. Spill response materials are located at this
area and are placed around the loading operation area and a spill
boom is placed between the loading❑ erations and the ditch.
Page 5 of 7

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised December 2021
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
andtype of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: In WWTP Area on the east side and adjacent to the dieseI
emergency backup generator in Drainage Zone 3B
Materials: Diesel
Structural BMPs: This unloading area slopes to a stormwater conveyance ditch
that drains to the onsite retention pond,which provides
secondary containment.
WWTP Emergency Generator(L-21) Procedural BMPs: Before unloading procedures begin,Utility operators make sure
that wheels are chocked,that there is sufficient room in the fuel
tank,and that the hoses and pumps do not have leaks in
accordance with area-specific fuel unloading procedure in the
site's Oil SPCC Plan. Operators also monitor the level of
material in the generator to prevent overflow and spill.Spill
equipment is available in this area and spill booms are placed
around the loading operations.
Location: On the south side of Building 913(Firewater Pump House)in
Drainage Zone 1
Materials: Diesel fuel
Structural BMPs: Top unloading operations are conducted at this truck unloading
station. The station consists of concrete dike walls on the north,
east,and south sides,a concrete ramp on the east side(-25'x
42'x 2.5'at deep end),and a trench drain and drain pipe
equipped with a manual valve at the low point and has
sufficient capacity to contain the volume of one compartment of
a 7,500 gallon tanker truck plus freeboard for rain
accumulation. The drain valve is closed during unloading
Diesel Unloading for Firewater Pump operations plus an operator is present at all times during
(L_22) unloading so any leaks or failures in the hoses,etc.would be
corrected immediately.
Procedural BMPs: Before unloading procedures begin,Utility operators make sure
that wheels are chocked,that the vessel is in good condition,the
vessel is vented(if it is pressurized),and that the hoses,pumps,
and lines do not have leaks in accordance with area-specific
fuel unloading procedure in the site's Oil SPCC Plan.Operators
also monitor the levels of materials in the pump to prevent
overflow and spill.The sump drain valve on the containment
area remains open when fuel unloading is not being conducted.
Location: Fire Training Area in Drainage Zone 2
Materials: Corrosive or Otherwise Hazardous Waste for off-site disposal;
Corrosive or Otherwise Hazardous Wastewaters for off-site or
on-site treatment.
Structural BMPs: The fire training area is located on a concrete diked pad
approximately 40'x 20'x 1.5'that slopes to a sump on the
southern end of the pad. The sump is operated in a locked and
Hazardous Waste Tanker/Tote Unloading[Non- closed position.
Routine](L-23) Procedural BMPs: Collected rainwater in the sump is inspected by the
Mallinckrodt Utilities Department and then manually pumped
to the stormwater conveyance ditch located east ofthe training
area. A lock has been placed on the sump pump in this area.
The EHS Department ensures that only compatible materials
are stored in this area. EHS is present whenever hazardous
waste from tankers or totes are loaded into tankers for off-site
dis osal since EHS signs all manifests.
Notes:
■ (L-5) Former K083 Tar Loading and Unloading area is no longer in use. Also see Table 6,W-17.
■ (L-8)Former Loading/Unloading Area Behind Building 100 is no longer in use. Caustic unloading
operations moved to L-19(shared with Nitrobenzene truck unloading).
Page 6 of 7

■ (L-15)Former Waste Toluene Loading area is no longer in use;toluene is no longer used in plant
processes.
• (L-16)Former Thionyl Chloride and DMF Unloading area is no longer in use;these chemicals are no
longer used in plant processes.
* Denotes areas not inspected because no significant exposure to stormwater
Page 7 of 7

Table 4
Outdoor Process Areas—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for outdoor process activities were chosen
based on their level of potential impact to storm water,
including frequency of movement of materials,volume of
materials,location at facility,and type of materials.
Outdoor Process Area Location and Implemented Best Management Practices(BMPs)
Location: West of the building 51 warehouse and southwest of the
Fire Training Area gasoline storage and loadinglunloading area in Drainage
(P-1) Zone 2
Materials: #2 fuel oil,gasoline,various hazardous materials(see S-
64)or hazardous/solid wastes
Structural BMPs: The fire training area is located on a concrete diked pad
approximately 113'x 99'x 1.5'that slopes to a sump on
the southern end of the pad. The sump is operated in a
locked and closed position.
Procedural BMPs: Fire training is rarely conducted live at the facility. If
live fire training is conducted,an environmental
contractor manually pumps liquids in the sump into a
vacuum truck for disposal upon completion of fire
training.Residual liquids contained in the sump are
typically a mixture of rainwater,#2 fuel oil,and
firefighting foam.The sump is then power-washed and
emptied into the vacuum truck.During the rest of the
year,when no potential contamination sources are
present in the sump,collected rainwater in the sump is
inspected by the Mallinckrodt Utilities Department and
then manually pumped to the stormwater conveyance
ditch located east of the training area. A lock has been
placed on the sump pump in this area. Mallinckrodt
personnel inspect the containment system at least once
each six months. When hazardous wastes are
temporarily stored in this area(<90-day storage),a
minimum of weekly inspections are performed. The
Environmental Department ensures that only compatible
materials are stored in this area.
Location: On the southeastern end of the maintenance building
Maintenance Wash Pit (building 903)in Drainage Zone 2
(P-2)* Materials: Infrequent use for rinsing maintenance equipment/tools.
Structural BMPs: The concrete wash pit is sloped towards a sanitary sewer
drain located on the northern end of the pit. There are
berms located on the southern,eastern,and western
sides of the pit.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of stormwater contamination.
Location: North of the PAP process area in Drainage Zone 3B
Wastewater Treatment Plant Materials: Process wastewater
(P-4)* Structural BMPs: The tanks in the WWTP are equipped with high level
alarms,flow controls,and liners with the steel tanks
themselves as secondary containment.The 4,000,000-
gallon capacity wastewater holding tank is equipped
with a water leachate system under the tank that collects
and redirects minor spills to the WWTP.
Procedural BMPs: None related to stormwater.
Page 1 of 2

Table 4
Outdoor Process Areas—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2022
Note:The BMPs for outdoor process activities were chosen
based on their level of potential impact to storm water,
including frequency of movement of materials,volume of
materials,location at facility,and type of materials.
Outdoor Process Area Location and Implemented Best Management Practices(BMPs)
Location: South of Building 910 and west of Building 912 in
Scrubber System Drainage Zone 3B
(P-5) Materials: 25%Sodium hydroxide
[Co-located with Boiler No.7(S-59)] Structural BMPs: The scrubber system and associated tanks are contained
by a dike. This equipment is located in the same dike as
Boiler No.7(see Table 2,S-59).This dike provides
sufficient containment for the volume of the largest tank
in the dike and rainwater accumulation from a 25 year-
24 hour storm event. The dike drains into a trench and
sump.
Procedural BMPs: Stormwater is allowed to accumulate in the sump and
inspected by the Mallinckrodt Utilities Department for
visual signs of impact. Based on prior approval by the
City of Raleigh POTW,stormwater is pumped to the
condensate sewers stem..
* Denotes areas not inspected because no significant exposure to stormwater
Page 2 of 2

Table 5—BMP Summary
Dust/Particulate Generating/Control Areas
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2018
Note:The BMPs for dust/particulate generating/control
activities were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,and type
of materials.
Dust/Particulate Generating/Control Areas Location and Implemented Best Management Practices(BMPs)
Location: In Buildings 201 and205 in Drainage Zone 3B
PAP Bag Filters for Vacuum Dryers and Product Bin Materials: PAP(powder)
Packaging Structural BMPs: The bag filters are equipped with a control device to
(D-1)* , prevent emissions of particulates. The roof drains in this
area are directed to the WWTP.
Procedural BMPs: None related to stormwater. Not identified as a
9 igii ilicaut source of storm water contamination.
Location: In Buildings 101,102,103,and 104 in Drainage Zones 2
APAP Bag Filters on Drop Hoppers,Sizing Operating and 3B
Equipment,and Multi-level Clean Room Operations Materials: APAP(powder,granular)
(D-2)* Structural BMPs: The bag filters are equipped with a control device to
prevent emissions of particulates and the roof drains in
this area are directed to the W WTP.
Procedural BMPs: None related to stormwater. Not identified as a
sign ificant.source of stormwater contamination.
Location: South of Building L02 in Drainage Zone 2
APAP Drying Tower Courtyard Materials: APAP from bag filter transportation
(D-3) Structural BMPs: Drainage from the courtyard area,through which bag
filters are cleaned and transported,was redirected to the
process sewer system in 2004.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of stormwater contamination.
Incidental releases of APAP dust is swept up on a
re Iar basis.
Location: West of Building 5IA in Drainage Zones 2 and 3B
Boiler House Materials: Particulates from the burning of fuels in site boilers
(D-4)* Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of stormwater contamination.
* Denotes areas not inspected because no significant exposure to stormwater
Page 1 of 1

Table 6
Waste Disposal Areas—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised: December 2021
Note:The BMPs for waste disposal activities were chosen
based on their level of potential impact to storm water,
including volume of materials,location at facility,and type
of materials.
Waste Disposal Area Location and Implemented Best Management Practices(BMPs)
Location: NW Comer of Building 101 in Drainage Zone 3
Dumpster and Trash Compactor Northwest of Building Materials: Crushed empty fiber drums and trash from Building 101
101 and administrative offices and carbon.
(W-2)* Structural BMPs: The trash compactor is self-enclosed and is contained by
walls on the south and east sides,and a berm on the west
side.The dumpster is contained by walls on the south
and east sides,and a berm on the west side. Run off
from this area flows to an asphalt diversion berm,then
drains to a sump leading to the site process sewer
system.
Procedural BMPs: Employees are trained about appropriate placement of
waste in dumpsters.
Location: SE and SW of Building 201 in Drainage Zone 3
Materials: Trash from building 200 and 201,packaging for raw
Dumpster Southeast of Building 201 materials,drums/totes of potassium hydroxide,and non-
Waste Pallet Dumpster East of the Maintenance Shop recyclable pallets.
(W-3)* Structural BMPs: Trash dumpster is self-enclosed. These dumpsters are
not covered or within a dike due to low risk of exposure
to Stormwater.
Procedural BMPs: Employees are trained about appropriate placement of
wastes and pallets in dumpsters.
Location: NW of Building 10 in Drainage Zone 3
Dumpster Northwest of Building 10 Materials: Trash from Building 10 and WWTP
Dumpster near Building 10 Loading Docks Structural BMPs: The common trash dumpster is self-enclosed and the
(W-4)* cardboard dumpster is open-topped.
Procedural BMPs: Employees are trained about placement of waste in
dumpsters.
Location: NW of Building 101 in Drainage Zone 3
Cardboard Recycling Container Materials: Cardboard
(W-7)* Structural BMPs: None related to stormwater
Procedural BMPs: Employees are trained about placement of cardboard for
recycling in dumpsters.
Location: North of Building 205 in former K083 Tar load/unload
Dumpster North of Building 205 area(L-5)in Drainage Zone 3
(W-9). Materials: Trash from buildings 204 and 205 and packaging for raw
materials.
Structural BMPs: The dumpster is self-enclosed and is located on concrete
pad,surrounded by a berm,sloped toward a sump
located inside the loading area.
Procedural BMPs: Accumulated storm water is inspected and,if clean,is
manually pumped to the process sewer.Employees are
trained about placement of waste in dum sters.
Location: NW of the Maintenance Building in Drainage Zone 3
Recycling Bins Northwest of Maintenance Materials: Segregated metal equipment,parts,and miscellaneous
(W-10)* construction debris.
Structural BMPs: None related to stormwater
Procedural BMPs: Employees arc trained about placement of n:cyclab[es in
bins/dumpsters.All oils are drained and piping is wiped
dm6n prior to P1acement in metal rea cl i niz bins.
Misc.Trash Cans Location: Throughout plant site
(W-13)* Materials: Misc.garbage(e.g.,paper,beverage containers,etc.)
Structural BMPs: The common trash can with lid or open top trash hopper
Procedural BMPs: Employees are trained about placement of waste in
dumpsters.
Hazardous Waste Storage Area
(W-14) See Table 1,S-20
Page 1 of 3

i
Table 6
Waste Disposal Areas—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised:December 2021
Note:The BMPs for waste disposal activities were chosen
based on their level of potential impact to storm water,
including volume of materials,location at facility,and type
of materials.
Waste Disposal Area Location and Implemented Best Management Practices(BMPs)
Location: East of Building IOOA in Drainage Zone 3
Trash Compactor East of Building 1OOA Materials: Crushed empty fiber drums and trash from building 100,
(W-16)* IOOA and warehouse
Structural BMPs: The trash compactor is covered by a roof.
Procedural BMPs: Employees are trained about placement of waste in
dum sters.
Location: Northwest of building 901 in Drainage Zone 3
K083 Rainwater Storage—west of Building 905 Materials: Rainwater/precipitation that has been in contact with
(W-17) K083 aniline tar tanks and/or the secondary containment
for those tanks.
Structural BMPs: Rainwater is pumped or manually transferred to totes
from the dikes containment areas of S-5 and S-19.
These totes are stored in a covered diked concrete
secondary containment located adjacent to the Aniline
Tar Tank containment area(S-5). This area is 10'x 13'
x 0.5'.
Procedural BMPs: Stormwater accumulation from the sumps or diked areas
of S-5 and S-19 is manually pumped out directly into
totes(or other containers). These totes are stored
temporarily in this diked area until being transferred to
the Hazardous Waste Storage Building(S-20),at
intervals of less than 90 days for each tote. Filling the
tote is limited to a few inches below the top of the tote to
allow for freeboard. The totes are stored at the
} Hazardous Waste Storage Pad prior to ultimately being
sent off-site for disposal as a hazardous waste.
Accumulated water in this area is inspected prior to
discharge.
Location: Fire Training Area in Drainage Zone 2
Materials: Corrosive or Otherwise Hazardous Waste for off-site
disposal;Corrosive or Otherwise Hazardous
Wastewaters for either on-site or off-site or on-site
treatment.
Structural BMPs: The fire training area is located on a concrete diked pad
approximately 40'x 20'x 1.5'that slopes to a sump on
the southern end of the pad. The sump is operated in a
Hazardous Waste Tanker/Tote Storage[Non-Routine] locked and closed position.
(W-18) Procedural BMPs: Collected rainwater in the sump is inspected by the
Mallinckrodt Utilities Department and then manually
pumped to the stormwater conveyance ditch located east
of the training area. A lock has been placed on the sump
pump in this area. The EHS Department ensures that
only compatible materials are stored in this area EHS
Department or designee conducts weekly inspections of
tankers/totes if stored in this area.
Location: PAP Building 205 Dike at PAP Wastewater Pit in
Drainage Zone 3
Materials: Corrosive or Otherwise Hazardous Wastes for off-site
disposal or Wastewaters waters for on-site treatment.
Structural BMPs: This production area is fully contained in a concrete
Hazardous Waste Tanker Storage[Non-Routine] diked area that slopes to a large wastewater sump. The
(W-19) sump is manually activated as needed for wastewater
removal.
Procedural BMPs: Operations personnel ensure the tanker is not leaking
while operating the wastewater sump under normal
operations. For wastewaters that can be treated on-site,
the slowk released into the sump for transfer to the on-
Page 2 of 3

Table 6
Waste Disposal Areas—BMP Summary
Mallinckrodt Pharmaceuticals [SpecGx LLC]
Raleigh Pharmaceutical Plant
Revised:December 2021
Note:The BMPs for waste disposal activities were chosen
based on their level of potential impact to storm water,
including volume of materials,location at facility,and type
of materials.
Waste Disposal Area Location and Implemented Best Management Practices(BMPs)
site wastewater treatment plant. The EHS Department
works with the PAP Department to ensure that only
compatible materials are stored in this area when a
waste/wastewater tanker is temporarily being stored in
this dike. EHS Department or designee conducts weekly
inspections of tankers/totes if stored in this area.
Notes:
■ (W-1)Carbon dumpster now part of W-2.
• (W-5,W-6, and W-11)All trash cans and open top hoppers identified as W-13.
• (W-8)Dumpsters at Driveway Tank Farm are no longer used.
• (W-12)Former Open Top Roll-off Storage(same as S-36)is a practice that is no longer used at this facility.
• Denotes areas not inspected because no significant exposure to stormwater
Page 3 of 3

Summary of Significant Changes in Industrial Activities
SpecGx LLC, (Mallinckrodt Pharmaceuticals) —Raleigh Plant
2011 to 2016
Year Description
2011 • Upgraded existing Bulk Acetic Acid/APAP Wastewater Tank Farm
including better materials of construction for the acetic acid tanks and
an improved containment design (S-15),
• Moved storage of 2 raw materials stored in totes, hydrogen peroxide
and aqua ammonia,from an uncovered area (S-17)to the
covered/diked Hazardous Waste Storage Pad (S-20)
• Added new Utilities Building transformer, Substation#8 (S-53)
• Converted former Tar Loading/Unloading Truck Station (S-40)to PAP
Rework/temporary storage (S-54)
• Switched management of K083-contaminated rainwater from a tanker
trailer to totes (L-5)
• Began using Fire Training Area (P-1)for storing non-routine wastes and
high-strength wastewater in tankers and/or totes
• Added cartridge filters on exhausts of dust collectors to ensure broken
bags do not emit particulate onto the roofs (D-2)
2012 • Added new tank farm/containment system for several replacement
vessels used in the production of APAP including an improved
containment design (S-55)
• Added new replacement sulfuric acid tank farm including better
materials of construction for the tanks and an improved containment
design (S-56)
2013 • Added new K083 waste-combusting boiler in diked area (S-59)
• Added new stormwater trench drain between Buildings 910
and 903
• Added new procedures for collection of HVAC and chiller
cleaning water
2014 • Updated protocol for addressing potential stormwater
contamination for dumpsters and open-topped buckets
2015 • Modified protocol for valves in oil-filled transformer containment areas
to have valves remain open due to safety concerns with ponding water
under energized equipment and closing valves upon discovery of oil
leaks
• Installed additional vessels for the APAP production process, including
new containment systems including an improved containment design
(S-55)
2016 • Moved spent catalyst residues (S-17)from outdoors to the
covered/diked Hazardous Waste Storage Pad (S-20)

Summary of Significant Changes in Industrial Activities
SpecGx LLC, (Mallinckrodt Pharmaceuticals) —Raleigh Plant
2017 to Present
Year Description
2017 • Removed L-8 (Unloading Area behind Building 101) and moved caustic
unloading to (L-19) in Zone 3B
• Removed S-24 (Washing Area/Catalyst Storage Area) in Drainage Zone
3B since equipment is in Building 201
• Renamed S-30 (Aniline Storage Tanks) "201 Storage Tanks" and add
ammonium bisulfite tank information
• Added area S-61 (Transformer#9) in Zone 3B
• Added area S-62 (Duke Energy Transformer#4 near Firewater Tank) in
Zone 1
• Added area S-63 (new Firewater Pump House) in Zone 1
• Added area L-22 (Diesel Unloading-Fire Pump) in Zone 1
2018 • Updated W-17 for new structural BMP (move tote under roof)
2019 • Added back S-44 (old oil-filled transformer at former Substation#3) at
the Fire Training Field in Table 2
• Moved S-45 (old empty transformer and associated tote of oil at former
Substation #4)to Fire Training Field
• Added S-64 (Nitrobenzene isotainer/tanker truck storage) at Fire
Training Field
• Revised P-1 (Fire Training Area) to reflect current practices
2020 • Changed name of S-64 to Bulk Chemical Isotainer/Tanker
Storage/Staging at Fire Training Field
• Revised P-1 (Fire Training Area) to reflect current practices
2021 • Added L-23 (Zone 2), W-18 (Zone 2), and W-19 (Zone 3)for Non-
Routine/temporary Hazardous Waste/Wastewater Tanker/Tote storage
and/or unloading
• Removed old transformers S-44, S-45, and S-46
2022 • Added WWTP Bleach Storage (S-65) in Drainage Zone 3.

Young, Brianna A
From: Yuncu, Bilgen <[e-mail]>
Sent: Tuesday, November 15, 2022 4:42 PM
To: Roberts, Tim
Subject: RE: [EXTERNAL] Outfall Discharge Info-Request by Stormwater Permitting Unit
EXTERNAL EMAIL: Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon Tim,
I reviewed the information, and it all looks good to me. I don't believe there is any change in the current information.
Best Regards,
Bilgen
Bilgen Yuncu, PhD, PE, PMP
Environmental Engineer/Project Manager
114 Edinburgh South, Suite: 200 Cary, North Carolina, 27511
TRIC T 919.582.7267 1 C 919.649.9275 1 [e-mail]
Linkedln I Twitter I TRCcompanies.com
From: Roberts,Tim <[e-mail]>
Sent:Tuesday, November 15, 2022 12:05 PM
To:Yuncu, Bilgen <[e-mail]>
Subject: [EXTERNAL] Outfall Discharge Info-Request by Stormwater Permitting Unit
contentThis is an EXTERNAL email. Do not click links or open attachments unless you validate the sender and know
the
ALWAYS hover over the link to preview the actual URL/site and confirm its legitimacy.
I am working on getting Brianna Young the info. she requested a few months ago. Can you review the attached and
provide
• Confirmation of the receiving stream for each outfall
Also we need to confirm:
• Stormwater outfall information: (if changes we need to Email Bethany Geor og ulias)
Send your responses to me and I'll forward to the agency as needed.
1

Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(c�mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
2

Young, Brianna A
From: Roberts, Tim <[e-mail]>
Sent: Friday, January 27, 2023 4:25 PM
To: Young, Brianna A
Cc: Kalar, Michael; Bilgen Yuncu
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136) - Response 1
Attachments: RE: [EXTERNAL] Outfall Discharge Info-Request by Stormwater Permitting Unit
Importance: High
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Here is the attached email referenced below.
-Tim
From: Roberts,Tim
Sent: Friday,January 27, 2023 4:24 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)- Response 1
Importance: High
Here's Part 1 of my responses below(responses in BLUE). I will work on Part 2 (info needs in RED) and get to you by
the end of next week. If you have questions about anything I am sending here, please feel free to ask.
I have some other regulatory reports/plan updates due early next week that I have to complete first. I really appreciate
your patience and understanding.
-Tim
• Provide SIC (NAICS) code; (See table below)
i

Process New NAICS Code(s) Old SIC Code(s)
325411---%.'Iedical and Botanical 2833---Medical Chemicals and
Acetaminophen ( PAP
-Manufacturing (pt) Botanical Products
325194-C,Yclic Crude_
Para-Aminophenol Intermediate, and Cr>.un and 2865-Cyclic Organic Crudes
(PAP) ��'ood Chemical and Intermediates, and Organic
_\-1anufacturin * Dyes. and Pigments
325199-All Other Basic
Aniline Organic Chemical 2869-Industrial Organic
-Manufacturing (pt) Chemicals, NEC
Ammonium Sulfate 325311- Nitrogenous FerthZer
2873-Nitrogenous Fertilizers
(MASL) --Manufacturing
325199-All Other Basic
Acetic Acid (220.a) Organic Chemical 2869-Industrial Organic
'Ianufacturing (pt) Chemicals- NEC
• Confirmation of the facility's name (this will be used in the permit and our database); (Mallinckrodt—
Raleigh Pharmaceutical Plant as noted in the NPDES Stormwater Permit Summary Report;
SpecGx LLC is the legal owner; the "G" is capitalized and not lower case as shown in the NPDES
Stormwater Permit Summary Report)
• Description of industrial activities that occur in each drainage area; (PENDING)
• Confirmation of the receiving stream for each outfall; (Confirmed-see attached email)
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit; (submitted to you on 9-19-22)
• Verification that the information in the renewal application is still complete and correct; (PENDING)
and
• An explanation of any operational changes since the renewal application was submitted. (PENDING)
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(a)mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From: Young, Brianna A<[e-mail]>
Sent: Friday,January 27, 2023 2:11 PM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
2

EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good afternoon,
I am following up on our previous correspondence.To date I have not received the requested information.This
information is required in order to proceed with reviewing the permit renewal application. Please let me know if you
have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent:Tuesday, November 15, 2022 11:41 AM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
I will begin working on this info. this week with a goal of having all to you next week before the Thanksgiving holiday.
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(cDmnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
3

From:Young, Brianna A<[e-mail]>
Sent:Tuesday, November 15, 2022 11:01 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good morning,
I am following up on our previous correspondence.To date I have not received the requested information.This
information is required in order to proceed with the permit renewal. Do you have an estimate on when the information
will be provided? Please let me know if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent: Wednesday, October 19, 2022 1:29 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Not yet. We are in the midst of a plant shutdown. I will try to have by the end of the month.
Thanks!
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
4

T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(c�mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, October 19, 2022 10:08 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
EXTERNAL EMAIL:Do not click on links or attachments unless you are confident they are safe.Click the"Suspicious Email"
button on the menu bar to have the message reviewed by Cybersecurity.
Good morning,
I am following up on our previous correspondence. Have you had a chance to work on this information request?The
permit renewal review is on hold pending the additional information.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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:Young, Brianna A
Sent:Tuesday, September 20, 2022 8:47 AM
To: Roberts,Tim <[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: RE: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
Thank you for providing this information. Please let me know if you have any questions as you work through the rest of
the request next month.
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
5

Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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. 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: Roberts,Tim <Tim.Robe [e-mail]>
Sent: Monday, September 19, 2022 4:41 PM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>; Bilgen Yuncu <[e-mail]>
Subject: [External] RE: Mallinckrodt Raleigh Pharmaceutical Plant (NCS000136)
CAUTION: External email. Do not click links or open attachments unless you verify.Send all suspicious email as an attachment to
Report Spam.
Attached is the summary data you requested below that I had our consultant (TRC) pull together the you. Again, I'll start
working on the other information next month after I return from vacation.
Regards,
Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(cDmnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
this in error, please inform the sender and remove any record of this message.
From: Roberts,Tim
Sent:Thursday,September 8, 2022 11:04 AM
To:Young, Brianna A<[e-mail]>
Cc: Kalar, Michael <[e-mail]>
Subject: RE: Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
Hi Brianna! As we just discussed on the phone, I will try to get you the monitoring summary from my consultant and
forward to you as soon as possible this month. I'll start working on the other information next month after I return from
vacation.
Thanks!
6

Tim Roberts I Principal Environmental Engineer
Mallinckrodt Pharmaceuticals
8801 Capital Boulevard I Raleigh, NC 27616 1 USA
T: 919.878.2895 1 M: 919.369.1721 1 F: 919.878.2823
tim.roberts(d_)mnk.com I www.mallinckrodt.com
This information may be confidential and/or privileged. Use of this information by anyone other than the intended recipient is prohibited. If you receive
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From: Young, Brianna A<[e-mail]>
Sent: Wednesday, September 7, 2022 3:44 PM
To: Phillips, David <[e-mail]>; Roberts,Tim <[e-mail]>
Subject: [EXTERNAL] Mallinckrodt Raleigh Pharmaceutical Plant(NCS000136)
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Good afternoon,
I am working on renewing the individual stormwater permit for the Mallinckrodt Raleigh Pharmaceutical Plant
(NCS000136). I need additional information in order to 1) confirm that the information I have is correct and 2)
make sure the permit adequately serves the needs of the facility. Please provide the following:
• Provide SIC (NAICS) code;
• Confirmation of the facility's name (this will be used in the permit and our database);
• Description of industrial activities that occur in each drainage area;
• Confirmation of the receiving stream for each outfall;
• An electronic spreadsheet summarizing all of the monitoring data that has been collected since the
effective date of the current permit;
• Verification that the information in the renewal application is still complete and correct; and
• An explanation of any operational changes since the renewal application was submitted.
Enter your stormwater permit number into the Stormwater Permit Summary Report and you will see a form that
includes the address of the facility, contact information for the permit, and the regulated stormwater outfall(s)
for the facility. Please review the facility information to make sure it is correct. Information can be updated
using the links provided below, where applicable:
• Facility/Company name or ownership: Name/Ownership Change Form
• Owner Affiliation(Legally responsible person; i.e., someone with the company who is designated to
represent the company per signatory requirements or another authorized representative): Permit Contact
Update Request Form
• Delegation of Signature Authority (DOSA): Permit Contact Update Request Form
• Billing contact: Permit Contact Update Request Form
• Permit contact: Permit Contact Update Request Form
• Facility contact: Permit Contact Update Request Form
• Facility address only: Email Bethany oulias
• Stormwater outfall information: Email Bethany Geor og ulias
• Visit the eDMR Six Steps website and complete Steps 1 and 2.
• Pay outstanding permit fees: Stormwater ePUment website

Once I have the above listed information, I can continue my review. You will receive a draft permit for a 30-day
comment period. During this time we will be able to address any comments or concerns you have. During the
same 30-day period, the draft will be sent to a Regional Office staff member for review as well as out to public
notice. Once all comments and concerns are addressed, you may be issued a final permit.
Please contact me if you have any questions.
Thank you,
Brianna Young, MS(she/her/hers)
Industrial Individual Permits Coordinator
Stormwater Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
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.
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.
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Stormwater Pollution Prevention Plan Section 2
Mallinckrodt Pharmaceuticals [SpecGx LLC]
2.0 GENERAL SITE DESCRIPTION AND SITE PLANS
This section first presents a general site description for the facility,followed by a detailed description of the
industrial activities conducted within each of the drainage zones onsite. Supporting the general site
description and drainage zone descriptions,this section also contains a site location map and site plan
depicting the drainage zones and the locations of the industrial activities conducted within the zones.
Within each of the drainage zones,the following industrial activities are addressed:
• Location of the drainage zones within the facility
• Facility materials storage practices
• Loading/unloading activities
• Outdoor process areas
• Dust or particulate generating or control processes
• Waste disposal practices
• Significant spills or leaks within the past three years
• Evaluation for non-stormwater discharges
2.1 GENERAL SITE DESCRIPTION
2.1.1 Facility Operations
Mallinckrodt began operation at the site in 1966. Operating under SIC code 2833,this facility manufactures
bulk pharmaceuticals. The industrial area site plan is presented in Figure 3.
The facility conducts its operations under the provisions of several environmental permits. Included in the
permits are:.
• Permit to Discharge Pretreated Wastewater to City of Raleigh-Neuse River WWTP
#CHEM, issued through the City of Raleigh.
• Wastewater Residual Land Application Permit#WQ00005537 for on-site land application,
issued through the NCDEQ-Division of Water Resources.
• Individual NPDES Stormwater Permit#NCS000136,issued through the NCDEQ-DEMLR.
• RCRA Hazardous Waste Permit#NCD042091975R2(or most recent version)issued
through the NCDEQ-Division of Waste Management(DWM),Hazardous Waste Section.
• Title V Air Quality Permit#AQ1479T61 (or most recent version),for construction and
operation of air emission sources or cleaning devices and appurtenances,issued through the
NCDEQ-Division of Air Quality(DAQ).
Water is supplied to facility through a municipal water supply system. In addition, some fairly clean
wastewater generated by the adjacent Mallinckrodt Imaging Plant(located south of this facility)is used for
utility make-up water. Wastewater at the facility is collected in the sanitary sewer system,condensate sewer
system,or process sewer system. Stormwater collected within certain areas of the facility is also routed to
the process,sanitary or condensate sewers for treatment and/or discharge;these areas are shown on Figure
4. The remaining stormwater at the facility is drained through a stormwater conveyance system that either
discharges to a tributary of Perry Creek, a class Ws-IV,NSW and C water,and considered impaired due to
biological integrity and Neuse River,both nutrient sensitive waters(NSW)in the Neuse River Basin. Both
waterways are also included under a statewide Total Maximum Daily Load(TMDL)for mercury.
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The on-site WWTP receives process wastewater and contaminated groundwater from the on-site
,groundwater collection systems. The WWTP uses an activated sludge system that employs nitrification and
denitrification to reduce pollutant concentrations. Then using sludge flocculation generation and settling,
the sludge is separated from the liquids. Thickened sludge is used for on-site land application.The
separated liquids from the process water along with the sanitary and condensate(non-contact process water)
waters are discharged to the City of Raleigh Publicly-Owned Treatment Works(POTW). Mallinckrodt
personnel operate the WWTP.
Non-hazardous,dry solid waste is placed in designated dumpsters and compactors located throughout the
facility,and transported off-site to a sanitary landfill. The typical composition of the solid waste includes
the following:crushed empty fiber drums,packaging for raw materials,non-recyclable pallets,non-
recyclable cardboard,floor sweepings,and administrative/office wastes. Several dumpsters are also
designated for materials to be recycled at off-site facilities. These materials include cardboard,aluminum
cans,pallets,scrap metal,newspaper,magazines,paper,and plastic bottles.
Hazardous waste is accumulated at the facility at several hazardous waste satellite accumulation areas and
moved to the permitted hazardous waste storage pad. Hazardous waste is then transported off-site to a
permitted treatment, storage,and disposal(TSD)facility by a permitted hazardous waste transporter.
Several of the most common hazardous waste streams transported off-site each year include the following:
aniline still bottoms(K083),debris or sampling materials and personal protective equipment(PPE)such as
impacted by nitrobenzene(D036 or U 169)in the event of a spill/leak,debris or sampling materials and PPE
impacted by aniline(U220) in the event of a spilUleak,and lab packs of waste chemicals generated in the
quality control laboratory. Several non-regulated wastes, including pipe and insulation debris,oil residuals,
PAP,and APAP,are also accumulated at the hazardous waste storage pad prior to being transported off-site
to appropriate TSD facilities.
Air emission sources,air cleaning devices and appurtenances at the facility are located in the following
areas:
• PAP process line in Building 201,
• PAP process line in Building 205,
• APAP process line in Building 101,
• APAP drying/packaging operations in Buildings 102, 103,and 104, and
• Support facilities including boilers,K083 storage tank, stand-by diesel generator at the
WWTP.
Emission limitations reporting and testing requirements for specific equipment and processes are provided
in the site's air quality permit. Additional emission limitations for the combustion of K083 aniline tar in
Boilers#1 and#2 are provided within the Boiler and Industrial Furnaces(BIF)emission standards.
2.1.2 Facility Location
Mallinckrodt is located at 8801 Capital Boulevard(US Route 1)in Raleigh,Wake County,North Carolina.
The center of the plant has the coordinates 35°54'03"North latitude and 78°33'39" West longitude(Figure
1).
As shown in Figure 2,the area surrounding the facility is comprised of a combination of industrial-zoned
and residential-zoned properties,and primarily vacant forestland. The facility is bounded by:
• Neuse River to the north,
• Guerbet Medical Imaging Plant and Durant Road to the south,
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• Capital Boulevard(US Route 1)to the east,and
• North Wake County Sanitary Landfill and the Falls River Subdivision to the west.
2.1.3 Facility Layout
The Mallinckrodt facility is zoned industrial. As shown in the industrial area site plan(Figure 3),the
administrative buildings(Buildings 1,2,and 10)are located along Capital Boulevard(US Route 1)on the
eastern side of site. The main manufacturing areas are located to the west of the administrative buildings
within the Building 200-205 complex and the Building 100-108 complex. Prior to shipment off-site,the
majority of the finished product is stored within the Building 51 warehouse, located south of the
manufacturing area. Additional finished product storage is located in Building 10 warehouse.
The northern and western sides of the industrial area contain the support areas for the pharmaceutical
manufacturing processes. The northern end of the industrial area houses the Facilities WWTP. The western
side of the pharmaceutical manufacturing area contains the following structures or areas:
• Bulk aboveground storage tanks(ASTs)to the west of Buildings 201-205 for raw materials
and products;
• Maintenance Building(Building 903);
• Boiler House(Building 901)and its associated fuel storage ASTs;
• Warehouse for finished products(Building 51);
• Gasoline and diesel storage area to the west of Building 51;and
• Fire training area.
In previous years this Plan addressed five stormwater discharge outfalls(Outfalls 001 through 005);
however,after reviewing drainage routes and operations of stormwater conveyance structures in 2011, it
was concluded that only two of the drainage outfalls(Outfalls 001 and 002)and the onsite stormwater
retention pond are associated with stormwater runoff from the industrial portion of the facility. Outfalls
003, 004 and 005 receive Stormwater runoff solely from the agricultural operators for harvesting rye grass or
coastal bermuda. The agricultural operations involve land application fields(Drainage Zones 3A,4 and 5)
and as a part of the wastewater treatment plant operations,Mallinckrodt is permitted by NCDEQ DWR
Permit No. WQ0005537 to apply industrial residuals to the land application fields located north and west
of the manufacturing area. Surface water runoff from the land application fields is currently monitored
under Permit No. WQ0005537 at several designated stream locations on site. These three outfalls
(Outfalls 003, 004 and 005)receive discharge from the land application fields and not industrial
processes.
Based on the above,Mallinckrodt has revised this Stormwater Pollution Prevention Plan to exclude
outfalls 003, 004, and 005 and their associated sampling. A Notification in Change of Stormwater
Discharge Outfall Locations was submitted to NCDENR in October 2011. This notification stated that
since Mallinckrodt Outfalls 003, 004 and 005 mainly receive Stormwater runoff from the land application
fields(Drainage Zones 3A,4 and 5)and not the industrial areas and that the land application process is
permitted under a NCDENR DWQ permit,Mallinckrodt was going to eliminate conducting the quantitative
and qualitative monitoring requirements for these outfalls. Mallinckrodt continues to sample Outfall 003B,
which is the discharge from the onsite retention pond near the outfall, after a representative storm event.
Data from this Outfall will be reported.
Presently,there are two permitted stormwater drainage zones(Zone 1 and Zone 2)that discharge to Outfalls
001 and 002,respectively,and one unpermitted drainage zone(Zone 3B)that discharges to the onsite
stormwater retention pond at the facility as shown on Figure 2. The stormwater retention pond has a
surface area of approximately 23 acres and an estimated capacity of approximately 15 million gallons.
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Mallinckrodt Pharmaceuticals[SpecGx LLC]
The embankment at the retention pond acts as a hydraulic barrier,collecting stormwater runoff associated
with manufacturing areas and agricultural operations located within Drainage Zone 3B (approximately
173 acres). Mallinckrodt monitors water quality in the pond and periodically pumps water directly to the
Neuse River. A throttling device is installed in the dam wall of the stormwater retention pond and it is
maintained in the closed position. Therefore,the pond has no direct discharge of stormwater.
Mallinckrodt believes this outfall should not be identified as a stormwater discharge outfall in the site's
permit. However,the water from this pond is periodically pumped out. An agreement of understanding
between Division of Water Quality(DWQ)and Mallinckrodt was made so that water being pumped out
of the pond is sampled as an outfall twice a year during a non-storm event. Figure 2 also presents the
total area of each drainage zone,the area of impervious surfaces calculated for each drainage zone,the
percent impervious area,and the location of each outfall(including the latitude and longitude of each
outfall). A description of each drainage zone is provided in the following sections including descriptions
and locations of:
• Each drainage zone with respect to surface water bodies(Figure 2);
• Materials storage practices(Figure 5);
• Loading and unloading activities(Figure 6);
• Outdoor process areas(Figure 7);
• Dust/particulate generating areas(Figure 8); and
• Waste handling areas(Figure 9).
A discussion on non-stormwater discharges is also presented for each drainage zone in the sections below.
The annual update will contain a list of significant spills and leaks of pollutants for each area for the last three
years,or the notation that no spills have occurred. The annual update will also include a documented re-
certification of that stormwater outfalls have been evaluated for the presence of non-stormwater discharges
(Appendix E).
Allowable Non-Stormwater Discharges per the Permit(Section W.2)include other discharges that are
authorized by a non-stormwater NPDES permit(currently does not apply to this facility); uncontaminated
groundwater, foundation drains, air-conditioner condensate without chemicals, springs,discharge of
uncontaminated potable water,waterline or fire hydrant flushings,water from footing drains,flows from
riparian habitats and wetlands; and discharges resulting from fire-fighting or fire-fighting training.
At this facility there is a series of stormwater conveyance ditches that are used as onsite BMPs. In some
of these ditches there are valves that are operated in the locked and closed position so that they are acting
as secondary or tertiary containment. The water in these ditches is inspected,just as a concrete
containment around a tank would be inspected,for the accumulation of stormwater. The facility produces
product that can act as a dye,therefore fugitive dust on the roads in Zone 3B may add color to stormwater
runoff. However,the series of ditches in Zone 3B ultimately drain into the onsite retention pond located
north of the industrial portion of the facility.This drainage is depicted in Figures 4 through 9. This pond
also serves as secondary and or tertiary containment in some cases, since the pond discharge is in a locked
and closed position. In addition, because this pond serves as secondary containment it is visually
observed for color,foam, outfall staining, and visible sheens before discharge to the Neuse River plus it is
sampled semi-annually during or after a qualifying storm event.
In some of the process areas onsite there is a process sewer system that acts as a BMP for surface water
discharge in the process area.
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2.2 Drainage Zone 1 (Zone 1)
2.2.1 Zone 1 Location
Drainage Zone 1 collects stormwater runoff from the southeastern corner of the industrial area,from the
south and east sides of Building 51 (the finished products warehouse). This drainage zone,comprised of
approximately 9 acres,discharges stormwater through Outfall#1 located at latitude N35153' 49.82"
longitude W780 33'37.19". From Outfall 1,the stormwater flows to the adjacent Medical Imaging facility
property,from which runoff is discharged to the Durant Road drainage system. The Durant Road drainage
system drains to the southeast and discharges into an unnamed tributary of Perry Creek(Figure 1). There
are no potential stormwater contaminants in this zone.
2.2.2 Zone 1 Materials Storage Practices
As shown in Figure 5,materials storage areas located within Zone 1 include:
• Building 51 Warehouse(S-1)-East Side
• Duke-Energy Transformer 44(S-62)
• Firewater Pump House—Building 913 (S-63)
Descriptions of material storage practices for these areas are included in Table 2.
2.2.3 Zone 1 Loading/Unloading Activities
As shown in Figure 6, loading/unloading activities located within or directly affecting Zone 1 include:
• Building 51 Warehouse Loading/Unloading(L-1)
• Diesel Unloading for Firewater Pump(L-22)
Descriptions of the loading/unloading activities are provided in Table 3.
2.2.4 Zone 1 Outdoor Process Areas
There are no outdoor process areas located within Zone 1. Therefore,a potential does not exist for
contaminants from production operations to contribute to stormwater discharges at Outfall 1 (see Figure 7).
2.2.5 Zone 1 Dust/Particulate Generating Control Processes
There are no dust or particulate generating or control processes located within Zone 1. Therefore,a
potential does not exist for dust or particulate contaminants to contribute to storrnwater discharges at Outfall
1 (see Figure 8).
2.2.6 Zone 1 Waste Handling Areas
As shown on Figure 9,the only waste handling area located within Zone 1 are the trash cans(W-13)south
of Building 51 located by the gazebo. These trash cans are not identified as a significant source of
stormwater contamination.
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2.2.7 Significant Spills/Leaks Within Past Three Years Within Zone 1
Significant spills are defined in Part VI of the Permit to include releases of oil or hazardous substances in
excess of reportable quantities tinder Section 311 of the Clean Water Act(40 CFR 110.10 and CFR 117.21)
or Section 102 of CERCLA(40 CFR 302.4). There has not been a significant spill or leak within Zone 1
within the past three years.
2.2.8 Evaluation for Non-Stormwater Discharges within Zone 1
Initial evaluations for non-stormwater discharges were conducted by O'Brien&Gere on several dates
between July 1994 and October 1995. Solutions-IES,Inc. (Solutions-IFS)conducted an updated evaluation
for non-stormwater discharges on September 6-7,2001. S&ME conducted an updated evaluation for non-
stormwater discharges on April 14,2014. A copy of this latest evaluation and certification is included in
Appendix E.
2.3 Drainage Zone 2 (Zone 2)
2.3.1 Zone 2 Location
Zone 2 collects stormwater runoff from the southwestern corner of the industrial area,from the north and
west sides of Building 51 and from areas to the south and east of the Boiler House(Building 901).There
are a number of industrial activities located within Drainage Zone2 that could contribute potential pollutants
to stormwater discharges from Outfall 2. This drainage zone,comprised of approximately 42 acres,
primarily discharges stormwater through Outfall 2 located at latitude N350 53' 51.22"and longitude W78°
33' 41.64". There is also a small drainage swale on the western side of Drainage Zone 2 which also
discharges to the Durant Road drainage system(described in 2.2.1). From Outfall 2,water flows to the
adjacent Medical Imaging facility property, from which runoff is discharged to the Durant Road drainage
system. A new valve was installed in 2003 upstream of Outfall 2. This valve is locked and closed. In
Drainage Zone 2,stormwater that falls on certain rooftop areas and tank secondary containment areas
within the manufacturing area is collected, sent directly to the plant WWTP,and does not enter the
stormwater collection system.
Potential stormwater contaminants from site activities in Zone 2 include transferring of diesel and gas
fuel,transformer oils, products stored in tanks in tank farm west of 101, small containers of petroleum
products in contractor yard, and materials stored in fire training containment.
2.3.2 Zone 2 Materials Storage Practices
As shown in Figure 5,material storage areas located within or directly affecting Zone 2 area include:
• Building 51 Warehouse(S-1)-west side
• Building 5 1 A Warehouse(S-2)Vehicle Fuel Storage Area(S-27)
• Rock Salt Storage(S-31)
• Propane AST(S-38)
• Building 901,Boiler Treatment Chemicals and DI H2O Chemical Storage(S-39)
• Contractor Trailer Area(S-51)
• Transformer Substation No. 8(south of Building 901)(S-53)
• Bulk Chemical Isotainer/Tanker Truck Storage/Staging(S-64)—presently stored/staged in
Fire Training Area(P-1)
Descriptions of the material storage practices are included in Table 2.
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Mallinckrodt Pharmaceuticals [SpecGx LLC]
2.3.3 Zone 2 Loading/Unloading Activities
As shown in Figure 6,loading/unloading activities located within or directly affecting Zone 2 include:
• Building 51 Warehouse Loading/Unloading, west end of building(L-1)
• Building 51A Warehouse Loading/Unloading(L-2)
• Vehicle Fuel Loading/Unloading(L-12)
• Hazardous Waste Tanker/Tote Unloading [Non-Routine] (L-23)
Descriptions of the loading/unloading activities are provided in Table 3.
2.3.4 Zone 2 Outdoor Process Areas
Although the main production operations are conducted within the manufacturing buildings,ancillary
outdoor process and control equipment associated with the production activities have the potential to
contribute contaminants to stormwater runoff. As shown in Figure 7,the outdoor process areas located
within Zone 2 include:
• Fire Training Area(P-1)
• Wash Pit at Maintenance Building(P-2)
Descriptions of the outdoor process areas are provided in Table 4.
2.3.5 Zone 2 Dust/Particulate Generating Control Processes
As shown on Figure 8,dust or particulate generating or control processes present within Zone 2 include:
• APAP Drying Tower Courtyard(D-3)
• Boiler House(D-4)
Descriptions of these processes are provided in Table 5.
2.3.6 Zone 2 Waste Handling Areas
As shown on Figure 9,waste handling areas located within Zone 2 include:
• Trash Cans(W-13)
• Hazardous Waste Tanker/Tote Storage [Non-Routine] (W-18).
Descriptions of these areas are provided in Table 6.
2.3.7 Significant Spills[Leaks within Past Three Years Within Zone 2
Significant spills are defined in Part VI of the Permit to include releases of oil or hazardous substances in
excess of reportable quantities under Section 311 of the Clean Water Act(40 CFR 110.10 and CFR
117.21)or Section 102 of CERCLA(40 CFR 302.4). There has not been a significant spill or leak within
Zone 2 within the past three years.
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2.3.8 Evaluation for Non-Stormwater Discharges With in Zone 2
Initial evaluations for non-stormwater discharges were conducted by O'Brien&Gere on several dates
between July 1994 and October 1995. Solutions-IES conducted an updated evaluation for non-stormwater
discharges on September 6- 7,2001. S&ME conducted an updated evaluation for non-stormwater
discharges on April 14,2014. Mallinckrodt has been conducted the annual evaluation for non-stormwater
discharges beginning in 2015 and a copy of the most recent evaluation and certification is included in
Appendix E.
2.4 Drainage Zone 3B(Zone 3B)
2.4.1 Zone 3B Location
Zone 3B collects stormwater runoff from the majority of the manufacturing areas.
In January 1997,Mallinckrodt constructed an earthen fill embankment through an existing stormwater
retention pond under the approval of Nationwide General Permit Number 3 8 issued by the USACOE,
Wilmington District. The embankment acts as a hydraulic barrier,collecting stormwater run-off associated
with the manufacturing areas and fields located within Zone 313(approximately 173 acres)and separating it
from stormwater runoff associated with the land application fields located north of Zone 3B.Mallinckrodt
monitors water quality in the pond and periodically pumps water to a tributary stream that flows into the
Neuse River.
Mallinckrodt also operates control valves within each of the Zone 3B swales in the chemical manufacturing
area. In addition, Stormwater that falls on certain rooftop areas and tank secondary containment areas
within the manufacturing area of Zone 313 is collected,sent directly to the plant WWTP, and does not
enter the stormwater collection system. A throttling device is installed in the dam wall of the stormwater
retention pond and it is maintained in the closed position. Therefore,the pond,which collects stormwater
runoff from drainage Zone 313,has no direct discharge of stormwater. The stormwater retention pond has
a surface area of approximately 23 acres and an estimated capacity of approximately 15 million gallons.
The headwall and valve in the west stormwater ditch,northwest of the liquid hydrogen storage tanks,were
improved in 2003 by replacing the old valve with a smaller pipe and valve, and adding safe personnel access
down the face of the headwall so that the valve can be easily cleaned, improving operational reliability. The
manually activated valve controlling release of stormwater from this stormwater ditch is secured with a
locking mechanism. The valve and headwall in the northern stormwater ditch near Mallinckrodt Ammonia
Sulfate Liquor(MASL)Tank 3 has also been similarly improved by adding personnel access down the face
of the headwall so that the valve can be easily cleaned and operational reliability improved,and by
reinforcing the structure of the headwall. The manually activated valve controlling release of stormwater
from the MASL area is secured with a locking mechanism. Water collected from the MASL areas is
typically pumped to the process sewer. If there is a major storm event(i.e., greater than 1-inch),the
stormwater is analyzed for ammonia and inspected prior to release to the retention pond.
Stormwater runoff collection was improved in 2003 in the area between Buildings 101 and 201,west of
Building 2. An asphalt curb has been built along the eastern side of the pavement between the acetic acid
tank farm and the 201/205 bin staging area so that sheet flow is captured and routed into the trench drain
that flows north from the 201/205 bin staging area to the process sewer. Asphalt curbs have also been built
west of the acetic acid tank farm, isolating the flow west from this area and directing it to a sump,which is
manually pumped to the process sewer.
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Condition 4 of Nationwide General Permit required Mallinckrodt to remove this temporary diversion
measure no later than July 16,2001. However,correspondence from the NC Division of Water Quality
(DWQ;June 10,2001)approved retaining the temporary structure as a permanent structure(Appendix G).
A trench drain was installed in 2012 in between Buildings 910 and 906,when the new adjacent boiler
system was constructed. This drain collects stormwater starting at the east side of buildings 903 and the
Boiler House building and discharges it into the ditch located on the east side of Building 907.
Potential stormwater contaminants from site activities in Zone 3B include No.2 fuel oil,aniline,
nitrobenzene,PAP,aniline tar,acetic acid,used oil,new oils,compressor oil,transformer oils, sulfuric acid
and diesel.
2.4.2 Zone 3B Materials Storage Practices
There are a number of industrial activities located within Zone 3B that could contribute potential pollutants
to stormwater discharges.As shown on Figure 5,materials storage areas located within Zone 3B area
include:
• No.2 Fuel Oil Storage Tank(S-3)
• K083 Aniline Tar Tank at Boiler House(S-5)
• Maintenance Building(S-6)
0 Used Equipment Storage Areas(S-7)
• Hydrogen Tanks(S-8)
• Empty Container Storage Area(S-9)
+ Tank Farm on Hill(S-10)
• Ammonia Tanks(S-12)
• Building 100(S-13)
• Tank Farm West of Building 101 (S-14)
• Acetic Acid Tank Farm(S-15)
PAP Tote Storage(S-16)
• Building 200/204 PAP Warehouse(S-18)
• K083 Aniline Tar Storage Tanks(S-19)
• Hazardous Waste Storage Pad(S-20)
• Building 10 Warehouse(S-22)
• Tank Farm at WWTP(S-23)
• MASL Aboveground Storage Tanks(S-25)
• Warehouse Northeast of Building 101 (S-26)
• 201 Storage Tanks(S-30)
• Propane Aboveground Storage Tank(S-35)
• Progress Energy Substation(S-41)
• Transformer Substation No. 1,near Building 2 (S-42)
• Transformer Substation No. 2,near Building 903 (S-43)
• P-E Transformer Substation 41,near Big Mac(S-47)
• P-E Transformer Substation#2,near Building 10 (S-48)
• P-E Transformer Substation#3,near Wastewater Treatment Plant(S-49)
• Building 907 Used Oil and Oil Storage(S-50)
• Ethomeen Building(S-52)
• PAP Rework and Temporary Chemical Storage(S-54)
• Tank Farm North of Building 101 (S-55)
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• Sulfuric Acid Tank Farm(S-56)
• Back-up Diesel Generator at WWTP(S-57)
• Anti-Foam Tank Area at WWTP(S-58)
• Boiler west of Building 901 (S-59)
• PAP Plant Compressor(S-60)
• Transformer Substation No. 9,near Building 108 (S-61)
Two additional transformers, Substations 5A and 6 are located on the property,but do not contain any
coolant oil. The stormwater pollution prevention compliance status of the transformers owned by Progress
Energy and located on Mallinckrodt property is included in Appendix F.
2.4.3 Zone 3B Loading/Unloading Activities
As shown in Figure 6,loading/unloading activities located within Zone 3B include:
• Acetic Acid Loading Station North of Building 101 (L-3)
• Railcar Area Loading/Unloading(L-4)
• Tank Farm at WWTP Loading/Unloading(L-6)
• Building 10 Warehouse Loading/Unloading(L-7)
• No. 2 Fuel Oil Unloading Area(L-9)
• Loading/Unloading Dock at Building 100 (L-10)
• MASL Loading/Unloading(L-11)
• Aniline Truck Loading(L-13)
• West Side PAP Loading/Unloading(L-14)
• Anhydrous Ammonia(L-17)
• Sulfuric Acid Unloading Area(L-18)
• Nitrobenzene/Caustic Unloading Area(L-19)
• Used Oil Truck Loading Area at Bldg 907 (L-20)
• WWTP Generator Truck Unloading Area(L-21)
Descriptions of the loading activities are provided in Table 3.
2.4.4 Zone 3B Outdoor Process Areas
Although the main production operations are conducted within the manufacturing buildings,a sprinkler
system deluge within a production building and several ancillary processes have the potential to contribute
contaminants to stormwater runoff. As shown in Figure 7,the outdoor process areas located within Zone
3B include:
• Waste Water Treatment Plant(P-4)
• Scrubber System(P-5)
Descriptions of the outdoor process areas are provided in Table 4.
2.4.5 Zone 3B Dust/Particulate Generating Control Processes
As shown on Figure 8,dust or particulate generating or control processes present within Zone 3B include:
• PAP Bag Filters for Vacuum Dryers and Product Bin Packaging(D-1)
Revised December 2022
13

Stormwater Pollution Prevention Plan Section 2
Mallinckrodt Pharmaceuticals [SpecGx LLC]
• APAP Bag Filters on Drop Hoppers, Sizing Operating Equipment, and Multilevel Clean
Room Operations(D-2)
• Boiler House(D-4)
Descriptions of these processes are provided in Table 5.
2.4.6 Zone 3B Waste Handling Areas
As shown in Figure 9,the waste handling areas located within Zone 3B include:
• Dumpster and Trash Compactor Northwest of Building 101 (W-2)
• Dumpster Southwest of Building 201 and Waste Pallet Dumpster East of Maintenance
(W-3)
• Dumpsters Northwest of Building 10 (W-4)
• Cardboard and Metal Recycling Dumpsters(W-7)
• Dumpster North of Building 205 (W-9)
• Recycling Bins Northwest of Maintenance(W-10)
• Miscellaneous Trash Cans (W-13)
• Hazardous Waste Storage Pad(W-14)
• Sludge(Wastewater Residuals)Application Fields(W-15)
• Trash Compactor East of Building 100A(W-16)
• K083 Rainwater Storage(W-17)
Hazardous Waste Tanker Storage [Non-Routine] (W-19)
Descriptions of these areas are provided in Table 6.
2.4.7 Significant Spills/Leaks Within Past Three Years Within Zone 3B
Significant spills are defined in Part VI of the Permit to include releases of oil or hazardous substances in
excess of reportable quantities under Section 311 of the Clean Water Act(40 CFR 110.10 and CFR 117.21)
or Section 102 of CERCLA(40 CFR 302.4). ). There have been no significant spill events that have
occurred in the past 3 years.
2.4.8 Evaluation for Non-Stormwater Discharges Within Zone 3B
O'Brien&Gere conducted initial evaluations for non-stormwater discharges on several dates between July
1994 and October 1995. Solutions-IES conducted an updated evaluation for non-Stormwater discharges on
September 6-7,2001. S&ME conducted an updated evaluation for non-stormwater discharges on
April 14, 2014. Mallinckrodt has been conducted the annual evaluation for non-stormwater
discharges beginning in 2015 and a copy of the most recent evaluation and certification is included in
Appendix E.
Revised December 2022
14

_ LEGEND
7 r, ��`... " _• is.•• i ,� ❑ MATERIAL STORAGE AREA,
• ]>]7] OPEN SLOPED DITCH&
• ,• .� � r� >�.�. �.�. DIRECTION OF STORM FLOW
*. +•_ s. _ ~•*' ' * % RED INDICATES LOCATION SUBJECT
_-' •� TO SEMI-ANNUAL INSPECTION.
Y +,",{, y , - •, :� BLACK INDICATES LOCATION WITH
NO EXPOSURE.
1 • L Ti�1
re. ,, s � � q• � S-1 BUILDING 51 WAREHOUSE
•+ ') S-2 BUILDING S1A WAREHOUSE
. i-
' S-3 NO.2 FUEL OIL STORAGE TANK
'S-5 K083 ANILINE TAR TANK AT BOILER HOUSE
S-6 MAINTENANCE
r r r _ ' •y. BUILDING S-7 USED EQUIPMENT STORAGE AREA
. • S-8 HYDROGEN TANKS
r
S-9 EMPTY DRUM STORAGE AREA 1 S-10 TANK FARM ON HILL
t
S-12 AMMONIATANKS
s S-13 BUILDING 100
~ z S Y s x' 777yy r S-14-TANK FARM WEST OF BUILDING 101
'*L
yya ?� r S-15 ACETIC ACID TANK FARM NORTH OF BUILDING 101
S-16 PAPTOTESTORAGE
i -�• j77 7 F;ua S-17 STORAGE PAD SOUTH OF BUILDING 201
? J y1 ��� :[� }y}}y,�77_jy77]77 -e J S-18 BUILDING 200 WAREHOUSE
i !} `� s_ A-S-7 5-19 K083 ANILINE TAR STORAGE TANKS
_ t I►j /` S-20 HAZARDOUS WASTE STORAGE PAD
S-22 BUILDING 10 WAREHOUSE
91 r •' rrM1 50 07 f f`Tf Q , �� rrr r �/R. , S-23 TANK FARM AT W WTP
n Ilff U R ''� r�r Eli h+`, �� S-24 WASHING AREAICATALVST STORAGE AREA
20N 38 R�0]� - S-25 BUILDINOOGROUNDSTORAGETANKS
n nF
S-27 FUEL STORAGE AREA
7 h S-30 ANALINE STORAGE TANK
- .I() ----- x _ 1 01•1420 BUILDIN
- -" In 903 �' y I r�7A' ry h S-35 PROPANE ABOVEGROUND STORAGE TANK
s�r BQ❑ 9�. 912 -4 I r � :%r} rr' S-3B PROPANE ABOVE GROUND STORAGE TANK
J 4 +t• rrr S r 1 '� S-39 BUILDING901,80 LER TREATMENT CHEMICALS
� g4. 7T77 ] S-41 P-ETRANSFORMER
31 a S42 TRANSFORMER SUBSTATION 01 AT BUILDING 42
1 -yj ❑) �,• a",.�• I � ��_ � �� 5-43 TRANSFORMER SUBSTATION#2 EAST OF BUILDING 903 _ �/•�
a f _ .`3�.• � _ JC
f rat 53tT❑ r1 T'02 ]a]]a]yai]iyy�] y ►a, S - i711INc�20E I 11'
tOD '.�j $�! ]»7assaa77»>7i]]»ya]
S-47 P-E TRANSFORMER SUBSTATION#1 AT MASL
S ,. a --j `yy_. •� , S-48 P-E TRANSFORMER SUBSTATION#2 AT BUILDING 10
v 4'TiiY7 S •- i 2f11 TRANSFORMER
.•- _ -] _ =��J]7]7aF{-- �,,,, _ - n`r SSO BUILDING9070MLSTORAGEnON#3ATWWTP
y. •"•nr .,. v ,I rteC{{�� ' lA� -
5-51 CONTRACTOR TRAILER AREA
-fj� -� `� $ e } S-5 EN BUILDING
S-53 TRANSFORMER SUBSTATION#8 SOUTH OF BUILDING 901
S-54 PAP REWORK 6 TEMP CHEMICAL STORAGE
r m Q S-55 TANK FARM NORTH OF BUILDING 101(FUTURE)
5-56 SULFURIC ACID TANK FARM
7 e• S-57 1ANYfP BACK-UP GENERATOR
S-58 ANTI-FOAM DIKE AREA OF WWTP
S-59 BOILER 7-WEST OF BUILDING 901
S-60 PAP PLANT COMPRESSOR
;^� S-61 TRANSFORMER SUBSTATION#9 EAST OF BLDGA0B
+Y _ --77]7]» ''`E S62 DUKE ENERGY TRANSFORMER#4 NEAR FIREWATER TANK
r:rr u, .57 �y7]a s�j�a3 I S-63 FIREWNPER PUMPHOUSE .— r
1J` S•AH•- O ,y]�y]] 'y'r sy s-G"- lI FEISOTA[NERrfANHERSTORAGE,I_5
-221_ 711b --[77$}� IMAGE SOURCE NC ONEMAP,D SOURCE:WAKE ATEIS D 2013
1 ' •, �' „_' >?S} ',Nov ® 1 7.�777 7777 i ✓�'^ G ,DATED
BUUIMG SOURCE 2 WAKE COUNTY GIB,DATE 010H2O12
IU]
• 7 }
- - - - a?a'l' •. s ■ >77777 �'�� �� /(��� [. PARKING LOT SOURCE WAKE COUNTY GIS,DATED 2010
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- CAPITAL BLVD (US-1) 141%1 WE am
— �--- �SiC 1...+ � a - :c.- .. *.:' �_ �• - } i i � rr+�r m oaixec efvmorc
= � ' �'µ ,:'° �•� _ _ . . i� �� as PIN4•
Mallinckmc t
Pharmaceuticals
i
MATERIAL STORAGE
II r ..� _ �• �` _ .'I PRACTICES
s,•„� y � r _ ..��._ •r• -..' ' '�`; r FIG.5
_ ftlhT au11 RM
SCALE. o
GRAPHIC SCALE user E' .
30o a 150 300
5100-210-087
TM atom Is IK( IN FEET ) + IS IMT 0'�OR M
M a �*I"w w
RE 1304705

r -_ LEGEND
y,p ❑ LOADING 1 UNLOADING AREA
OPEN SLOPED DITCH&
;, " _ t1 + ��`-„r1;'•r' � � ">" DIRECTION OF STORM FLOW
•:ti. , � '
. �.� :� �_'•' �--'�" RED INDICATES LOCATION SUBJECT
TO SEMI-ANNUAL INSPECTION.
BLACK INDICATES LOCATION WITH
NO EXPOSURE.
7.
:. s_ - f.' ' ❑` L-1 BUILDING 51 WAREHOUSE
LOADING/UNLOADING
L-2 BUILDING 51A WAREHOUSE
a; ;':. 'S " ';. .�:. !�. . �44.,w_ r•.. LOADING/UNLOADING
L-3 ACETIC ACID LOADING STATION
r , �,-2.` �'j' 'F"Y•' '^ 1: _ s '. .. �_ ��?''.�'�aa''`'s»�� } �'� NORTH OF BUILDING 101
,'"aj L-4 RAILCAR AREA LOADING/UNLOADING
►�`v L-6 TANK FARM AT WWTP
- ''`g' .t'�,1- . G �f" ~1 �• �3 � A �il 1 . ?��?�7]7�]7 _
LOADING/UNLOADING
y3+� yr r� L-7 BUILDING 10 WAREHOUSE
907 .� �+ �:.,�!G�; K � ,r LOADING/UNLOADING
13
a
A r�F L-9 NO.2 FUEL OIL UNLOADING AREA
goo I'm7{ - ' ! ^'Tr- ' s �r L-10 LOADING/UNLOADING DOCK AT
n 903 - '- 'y `�` 7 7 '� +� r.rr '•.►• BUILDING 100
_�_3;• +" Li
" -i��i C�J s1z 77r �` .�� L-11 MASL LOADING/UNLOADING
-�— � -17 IF Ls _ -' - - 2 VEHICLE FUEL LOADING/UNLOADING
�[ SCCCCCCCiCSCCt{{S{C — _ �� Trr ❑L ,,�j $ � } n�
- {«�• _; l__ •�, I- �,z L-13 ANILINE TRUCK LOADING
L-14 WEST SIDE PAP
51 5IN& 106 �J�--_ �•� E �]3Y]]iYi]�]]] II a�]]�a7A>a7Yaa]]ay]]> >s� •`�__ - _ LOADING/UNLOADING
,4 i - _ L-17 ANHYDROUS AMMONIA UNLOADING
y ©L-1 n io ❑ L-1 j.� lull, zoi " ' 14
}���a� s;' u �•-1`--f L-18 SULFURIC ACID UNLOADING AREA
2
L-19 NITROBENZENE/CAUSTIC UNLOADING AREA
105 t}:'ti"'i iR o J
a w�4. + � • . =� � 1 I ��—R` f •• ,,I _, ,� �N _ ' 3 L-20 USED OIL LOADING AREA
0 _ w�' L-21 WWTP GENERATOR UNLOADING AREA
{{tttt{{ �+ {�' `� �--=� r��' L-22 FIRE PUMP UNLOADING AREA
24 �� � �3 PA LAkb�:
IMAGE SOURCE:NC ONEMAP,DA ED 2�1
lop
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DATED MARCH 2O12
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y 777.. t
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it
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FIG.6
reD
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GRAPHIC SCALE
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7H6 Dw"611@ PnFf {f DF mKmwwl! OR M
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. _ - NLE 1 W4706

LEGEND
p WASTE HANDLING AREAS
- — OPEN SLOPED DITCH&
DIRECTION OF STORM FLOW
:: .
RED INDICATES LOCATION SUBJECT
TO SEMI-ANNUAL INSPECTION.
�. � BLACK INDICATES LOCATION WITH
ti { NO EXPOSURE.
W-2 TRASH COMPACTOR AND
DUMPSTER WEST OF BUILDING 101
W-3 DUMPSTER IN VICINITY OF
i �h,�.. '• - 0� �L BUILDING 201
W-4 DUMPSTERS IN VICINITY OF
Sri BUILDING 10
W-7 CARDBOARD RECYCLING CONTAINER
' Q W43
W-9 DUMPSTER NORTH OF BUILDING 205
y . 777�77a}ss}]}s}} W-10 RECYCLING BINS NORTHWEST OF
_ t ۥ _ MAINTENANCE
`� ' ! �,* R �� �� '� a�• y�,7i7»>�� 'b� W-13 MISC.TRASH CANS
W-14 HAZARDOUS WASTE STORAGE AREA
_. - = - # r `�_ ,1 TOE W-15 LAND APPLICATION FIELDS
a�,., (NOT SHOWN)
cor e4k � W-16 TRASH COMPACTOR EAST OF
3B fit BUILDING 100A
_ �,, .• ��
` W-17 K083 RAINWATER 7TORAGE903
_
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.- �P Ih = I DATED 2010
s PARKING LOT SOURCE:WAKE COUNTY
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GRAPHIC SCALE
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� ��_ r1 Q ,• �i as�
k W� _naaa+a• ��ya7�+' IN FEET
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Date Conductivity(Ns/cm) Date pH (SU) [Benchmark Value = 6 - 9] Date Total Suspendid Solids (mg/1) [Benchmark Value = 100]
MC001 MC002 MC003B MC004US MC004DS MC005 MC001 MC002 MC003B MC004US MC004DS MC005 MC001 MC002 MC003B MC004US MC004DS MC005
NS NS NS NS NS NS
1/29/2003 387 190 725 NS 169 197 1/29/2003 NS NS NS NS NS NS 1/29/2003 NS NS NS NS NS NS
4/25/2003 80 170 560 190 230 260 4/25/2003 NS NS NS NS NS NS 4/25/2003 NS NS NS NS NS NS
9/4/2003 30 20 510 30 30 160 9/4/2003 NS NS NS NS NS NS 9/4/2003 NS NS NS NS NS NS
11/19/2003 40 20 290 40 90 420 11/19/2003 NS NS NS NS NS NS 11/19/2003 NS NS NS NS NS NS
3/15/2004 55.8 43.8 271 124.3 119.8 186.0 3/15/2004 NS NS NS NS NS NS 3/15/2004 NS NS NS NS NS NS
6/23/2006 60 30 200 70 60 120 6/23/2006 8.2 8.5 8.2 8.5 8.7 8.4 6/23/2006 6 10 140 510 510 1700
11/7/2006 0.0914 0.3376 1.5718 0.1526 0.1526 0.2964 11/7/2006 5.66 6.64 7.21 7.22 7.09 7.16 11/7/2006 1.7 55 18 46 22 60
3/16/2007 51.3 57.7 484 109.6 106.7 160.9 3/16/2007 5.2 5.34 6.24 6.07 5.95 6.2 3/16/2007 48 74 52 240 110 120
7/11/2007 30 90 690 120 NS NS 7/11/2007 7.3 6.7 6.9 7.1 NS NS 7/11/2007 17 25 200 22 NS NS
10/24/2007 22 26 570 34 60 NS 10/24/2007 5.31 5.6 5.51 6.25 6.3 NS 10/24/2007 11.9 18.7 7.2 89 121 NS
5/28/2008 51 98 350 121 147 201 5/28/2008 6.32 7.38 7.86 7.25 7.50 7.67 5/28/2008 11.0 178 794 2.3 3.1 40.0
11/4/2008 40 60 670 140 190 160 11/4/2008 7.6 6.2 5.3 5.6 5.30 4.9 11/4/2008 7.2 47.7 10 5.7 11.8 618
4/6/2009 91.4 105.9 345 138 160 146 4/6/2009 5.53 6.48 6.79 7.42 7.54 7.45 4/6/2009 24.4 45.6 35.2 50.1 50.5 58.6
9/17/2009 123 154 741 138 152 100 9/17/2009 5.54 6.09 7.03 7.34 7.51 6.84 9/17/2009 6.9 6 9.1 11.3 3.7 50.3
7/27/2010 30 50 610 60 90 NS 7/27/2010 5.76 6.34 7.46 7.33 7.41 NS 7/27/2010 29.0 93 58 280 420 NS
9/27/2010 124 80 591 191 129 239 9/27/2010 5.22 5.4 6.14 6.3 6.23 6.72 9/27/2010 36.0 25 8 61 24 55.0
4/26/2011 80 30 610 120 200 170 4/26/2011 7.63 7.49 7.33 7.77 7.54 7.81 4/26/2011 14 29 28 1.6 3.1 12
10/11/2011 10 120 670 120 170 190 10/11/2011 8.28 6.75 6.78 7.22 7.21 7.29 10/11/2011 45.0 22 1.0 1.2 1.2 7.5
5/9/2012 0 0.01 0.39 5/9/2012 7.67 6.85 7.78 5/9/2012 2.8 15 10
9/18/2013 28 30 304 9/18/2013 7.0 6.8 7.6 9/18/2013 7.1 54 5.2
4/19/2013 180 220 503 4/19/2013 6.12 6.14 8.3 4/19/2013 4.8 64 2.6
11/1/2013 24 61 377 11/1/2013 6.1 6.0 6.82 11/1/2013 3.5 85 13
4/25/2014 57 48 346 4/25/2014 6.3 6.7 8.6 4/25/2014 80 7.7 4.1
9/24/2014 31 99 330 9/24/2014 8.7 7.1 6.9 9/24/2014 37 29 9.3
5/21/2015 77 198 448 5/21/2015 6.4 6.5 7.9 5/21/2015 26 46 29
10/27/2015 101 191 1175 10/27/2015 7.2 6.6 6.8 10/27/2015 53.5 15.1 4.4
3/4/2016 107 54 317 3/4/2016 4.0 4.0 6.4 3/4/2016 35.8 12.0 3.20
10/7/2016 123 79 351 10/7/2016 6.51 6.57 7.18 10/7/2016 5.15 119 4.92
3/14/2017 135 118 306 3/14/2017 6.71 6.6 7.09 3/14/2017 8.9 7.73 1.58
10/16/2017 335 162 363 10/16/2017 6.83 6.28 7.59 10/16/2017 10.1 13.8 21
3/1/2018 142 129 387 3/1/2018 6.27 6.62 6.89 3/1/2018 17.6 22.7 4.56
9/17/2018 130 155 421 9/17/2018 6.48 6.39 6.83 9/17/2018 1.52 3.79 3.60
2/18/2019 148 140 362 2/18/2019 6.80 6.31 7.40 2/18/2019 14.1 7.55 1.46
8/14/2019 162 176 391 8/14/2019 6.51 6.21 7.26 8/14/2019 14.7 36.5 8.20
2/6/2020 162 158 381 2/6/2020 6.51 6.72 7.35 2/6/2020 10.3 30.0 1.27
8/4/2020 156 142 290 8/4/2020 6.81 6.72 7.02 8/4/2020 3.47 1.73 10.40
3/16/2021 121 147 286 3/16/2021 6.63 6.81 7.01 3/16/2021 35.2 34.40 7.27
7/8/2021 162 182 304 7/8/2021 6.82 6.49 7.11 7/8/2021 6.2 25.6 15.6
2/4/2022 189 197 289 2/4/2022 6.71 6.62 7.06 2/4/2022 95.0 154 7.365
Enter rows above this line
Notes: Non-detects entered as 1/2 times the detection limit(values in italics). Notes: Non-detects entered as 1/2 times the detection limit(values in italics). Notes: Non-detects entered as 1/2 times the detection limit(values in italics).
Not sampled/analyzed entered as "NS." Not sampled/analyzed entered as "NS." Not sampled/analyzed entered as "NS."
Yellow higlights indicate exceedence of Benchmark Value. Yellow higlights indicate exceedence of Benchmark Value. Yellow higlights indicate exceedence of Benchmark Value.

Date COD (mg/1) [Benchmark Value = 120] Date TKN (mg/1) [Benchmark Value = 30] Date Nitrate + Nitrite as N (mg/1) [Benchmark Value = 10]
MC001 MC002 MC003B MC004US MC004DS MC005 MC001 MC002 MC003B MC004US MC004DS MC005 MC001 MC002 MC003B MC004US MC004DS MC005
1/29/2003 170 79 72.5 72.5 72.5 72.5 1/29/2003 60 3.0 0.45 0.34 0.57 0.56 1/29/2003 0.828 1.581 14 0.37 1.5 0.72
4/25/2003 68 160 72.5 NS 72.5 35 4/25/2003 NS NS NS NS NS NS 4/25/2003 0.75 1.5 22 NS 2.1 0.46
9/4/2003 58 81 47 69 88 60 9/4/2003 NS NS NS NS NS NS 9/4/2003 0.56 0.58 15 0.37 0.55 0.52
11/19/2003 56 44 81 NS 100 140 11/19/2003 NS NS NS NS NS NS 11/19/2003 0.28 0.13 8.6 NS 0.48 0.31
3/15/2004 72.5 47 72 NS 72 14 3/15/2004 NS NS NS NS NS NS 3/15/2004 1.2 0.72 4 NS 1.1 1.2
6/23/2006 63 44 120 86 32 76 6/23/2006 1 1.2 1.7 0.66 0.75 1.6 6/23/2006 1.4 0.71 2.2 0.61 0.62 0.87
11/7/2006 39 81 62 27 72.5 39 11/7/2006 0.71 0.95 1.1 0.59 0.25 1.1 11/7/2006 0.25 0.34 17 0.24 0.44 0.12
3/16/2007 NS NS NS NS NS NS 3/16/2007 NS NS NS NS NS NS 3/16/2007 NS NS NS NS NS NS
7/11/2007 72.5 72.5 72.5 72.5 NS NS 7/11/2007 0.25 1.4 2.3 0.25 NS NS 7/11/2007 0.36 4.5 2.5 0.41 NS NS
10/24/2007 72.5 72.5 36 31 36 NS 10/24/2007 1 1.4 0.99 0.98 1.1 NS 10/24/2007 0.39 0.49 0.05 0.28 0.29 NS
5/28/2008 39.8 91.1 1720 72.5 72.5 72.5 5/28/2008 1.2 2.7 43.7 0.25 0.25 0.72 5/28/2008 0.7 2.2 0.05 0.34 1.2 0.2
11/4/2008 72.5 72.5 72.5 72.5 72.5 108 11/4/2008 0.79 2.6 1.1 0.25 0.25 4.8 11/4/2008 0.42 0.94 14.8 0.05 1.7 0.05
4/6/2009 47.6 79.6 54.7 37.8 29.4 38.8 4/6/2009 1.6 2.8 1.8 1.2 1.1 1.4 4/6/2009 0.29 0.41 5.4 0.44 0.65 0.34
9/17/2009 72.5 72.5 72.5 72.5 72.5 31.0 9/17/2009 0.69 7.5 1.1 0.25 0.25 0.25 9/17/2009 0.8 0.86 8.9 0.12 0.42 0.13
7/27/2010 25 70 25 93 110 NS 7/27/2010 0.94 7.2 2 3.7 7.7 NS 7/27/2010 0.37 0.74 8.4 0.55 0.7 NS
9/27/2010 19.7 14.3 37.8 39.4 29.2 41.0 9/27/2010 0.25 0.25 0.37 0.47 0.25 0.42 9/27/2010 0.1 0.3 3.48 0.06 0.22 0.05
4/26/2011 43 27 30 5 5 22 4/26/2011 1.4 0.6 0.84 0.05 0.05 0.36 4/26/2011 0.86 0.05 8.4 0.24 2.2 0.31
10/11/2011 19 100 38 76 79 28 10/11/2011 1.0 7.5 1.3 0.3 0.27 0.65 10/11/2011 0.59 1.30 5.20 0.27 1.10 0.45
5/9/2012 16 5 56 5/9/2012 0.78 0.83 1.9 5/9/2012 0.32 0.35 0.05
9/18/2013 38 23 59 9/18/2013 0.89 0.8 1.5 9/18/2013 0.14 0.32 0.05
4/19/2013 35 370 46 4/19/2013 1.2 17 1.0 4/19/2013 0.59 0.69 0.05
11/1/2013 17 56 48 11/1/2013 0.98 3.2 2.3 11/1/2013 0.31 0.9 0.16
4/25/2014 90 100 25 4/25/2014 1.9 1.8 1.3 4/25/2014 0.68 1.5 0.3
9/24/2014 21 26 40 9/24/2014 0.59 1.3 1.4 9/24/2014 0.05 2.3 0.05
5/21/2015 35 53 30 5/21/2015 2 4.1 2.1 5/21/2015 1.1 1.7 0.05
10/27/2015 61.5 26.6 29.2 10/27/2015 0.942 2.31 6.3 10/27/2015 1.03 1.86 0.05
3/4/2016 19.1 17.0 30.1 3/4/2016 0.532 0.459 0.920 3/4/2016 0.826 0.657 1.90
10/7/2016 34.9 28.5 32.3 10/7/2016 0.192 0.449 0.696 10/7/2016 0.223 0.259 0.035
3/14/2017 19.1 21.4 24 3/14/2017 0.558 0.767 0.774 3/14/2017 1.78 1.05 0.053
10/16/2017 24.2 15.5 60.5 10/16/2017 0.652 0.956 3.31 10/16/2017 0.471 0.783 0.07
3/1/2018 74.8 28.1 39.0 3/1/2018 0.990 0.520 4.73 3/1/2018 1.32 0.413 0.848
9/17/2018 25.7 26.5 32.0 9/17/2018 0.939 0.626 1.31 9/17/2018 0.865 0.626 1.31
2/18/2019 13.9 8.09 35.8 2/18/2019 0.337 0.866 0.988 2/18/2019 0.702 0.616 2.04
8/14/2019 45.0 5.68 41.0 8/14/2019 0.704 0.569 1.71 8/14/2019 0.895 0.27 0.00985
2/6/2020 17.2 12.0 21.2 2/6/2020 0.513 0.338 0.283 2/6/2020 0.372 0.060 1.58
8/4/2020 14.1 12.0 37.6 8/4/2020 0.559 0.169 1.85 8/4/2020 0.507 0.111 0.025
3/16/2021 5.9 5.9 5.9 3/16/2021 0.670 1.90 0.837 3/16/2021 0.83 0.629 0.880
7/8/2021 22.6 44.1 41.6 7/8/2021 0.578 1.19 1.48 7/8/2021 1.14 0.471 0.025
2/4/2022 77.6 144 5.85 2/4/2022 2.51 7.11 1.52 2/4/2022 0.956 0.822 1.96
Enter rows above this line
Notes: Non-detects entered as 1/2 times the detection limit(values in italics). Notes: Non-detects entered as 1/2 times the detection limit(values in italics). Notes: Non-detects entered as 1/2 times the detection limit(values in italics).
Not sampled/analyzed entered as "NS." Not sampled/analyzed entered as "NS." Not sampled/analyzed entered as "NS."
Yellow higlights indicate exceedence of Benchmark Value. Yellow higlights indicate exceedence of Benchmark Value. Yellow higlights indicate exceedence of Benchmark Value.
Green highlights means parameter analyzed/used for Total Nitrogen Calculation.

No Benchmark Value for this parameter beginning in 2012.

Date Ammonia as N (mg/1) [Benchmark Value = 7.2] Date Sulfate (mg/I) [Benchmark Value = 500] Date Ammonium Sulfate (mg/I) [Benchmark Value = 19]
MC001 MC002 MC003B MC004US MC004DS MC005 MC001 MC002 MC003B MC004US MC004DS MC005 MC001 MC002 MC003B MC004US MC004DS MC005
1/29/2003 NS NS NS NS NS NS 1/29/2003 11 16 160 4.4 9.8 25 1/29/2003
4/25/2003 NS NS NS NS NS NS 4/25/2003 6.1 16 140 NS 12 20 4/25/2003
9/4/2003 NS NS NS NS NS NS 9/4/2003 2.5 2.5 65 2.5 2.5 16 9/4/2003
11/19/2003 NS NS NS NS NS NS 11/19/2003 2.5 2.5 100 NS 9.2 150 11/19/2003
3/15/2004 NS NS NS NS NS NS 3/15/2004 2.5 6.4 42 NS 16 64 3/15/2004
6/23/2006 0.13 0.54 0.17 0.1 0.1 0.05 6/23/2006 8.5 2.5 46 19 14 24 6/23/2006 0.61 0 0.8 0.47 0.47 0
11/7/2006 0.39 0.79 0.23 0.15 0.05 0.63 11/7/2006 2.5 2.5 160 2.5 2.5 6.7 11/7/2006 0.25 0.25 1.08 0.25 0.25 2.97
3/16/2007 NS NS NS NS NS NS 3/16/2007 NS NS NS NS NS NS 3/16/2007 NS NS NS NS NS NS
7/11/2007 0.05 0.62 0.37 0.12 NS NS 7/11/2007 2.5 12 150 2.5 NS NS 7/11/2007 0.25 2.92 1.75 0 NS NS
10/24/2007 0.05 0.25 0.11 0.05 0.05 NS 10/24/2007 2.5 2.5 281 2.5 2.5 NS 10/24/2007 0.25 1.18 0.52 0.25 0.25 NS
5/28/2008 0.05 0.31 0.27 0.05 0.05 0.05 5/28/2008 5.3 23 46.8 2.5 8.5 22.4 5/28/2008 0.25 1.46 1.27 0.25 0.25 0.25
11/4/2008 0.35 0.84 0.05 0.05 0.05 0.05 11/4/2008 2.5 6.3 173 2.5 13.9 53.5 11/4/2008 0.25 3.96 0.25 0.25 0.25 0.25
4/6/2009 0.05 0.35 0.05 0.05 0.05 0.05 4/6/2009 2.5 5.2 67.6 2.5 6.8 19.1 4/6/2009 0.25 1.65 0.25 0.25 0.25 0.25
9/17/2009 0.05 0.69 0.05 0.05 0.05 0.05 9/17/2009 5.5 12.8 155 2.5 2.5 11.8 9/17/2009 0.25 3.25 0.25 0.25 0.25 0.25
7/27/2010 0.27 0.59 0.29 0.26 0.22 NS 7/27/2010 5.5 3.8 110 2.5 2.7 NS 7/27/2010 1.27 2.78 1.37 1.23 1.04 NS
9/27/2010 0.02 0.11 0.02 0.02 0.02 0.02 9/27/2010 5 5 169 5 5 5 9/27/2010 0 0 0 0 0 0
4/26/2011 0.53 0.05 0.10 0.05 0.05 0.05 4/26/2011 2.5 2.5 130 2.5 21 15 4/26/2011 0.05 0.05 0.47 0.05 0.05 0.05
10/11/2011 0.53 3.20 0.12 10/11/2011 2.5 30 160 2.5 15 41 10/11/2011 0.05 15.09 0.57 0.05 0.05 0.05
5/9/2012 0.14 0.41 0.12 5/9/2012 2.5 2.5 38 5/9/2012 0.05 0.05 0.566
9/18/2013 0.05 0.4 0.14 9/18/2013 2.5 2.5 28 9/18/2013 0.05 0.05 0.66038
4/19/2013 0.52 2.1 0.54 4/19/2013 2.5 7.8 72 4/19/2013 0.05 9.91 2.55
11/1/2013 0.27 1.1 0.6 11/1/2013 2.5 6.8 69 11/1/2013 0.05 5.19 2.83
4/25/2014 0.62 0.42 0.725 4/25/2014 2.5 2.5 74 4/25/2014 0.05 0.05 0.05
9/24/2014 0.725 0.42 0.725 9/24/2014 2.5 5 29 9/24/2014 0.05 1.98 0.05
5/21/2015 0.58 2 0.725 5/21/2015 2.5 13 64 5/21/2015 0.25 9.43 0.725
10/27/2015 0.334 1.36 5.09 10/27/2015 5.66 22.9 469 10/27/2015 0.58 6.42 24.01
3/4/2016 0.141 0.120 0.097 3/4/2016 5.57 5.86 115 3/4/2016 0.67 0.57 0.46
10/7/2016 0.088 0.205 0.105 10/7/2016 3.00 3.15 77.3 10/7/2016 0.42 0.97 0.50
3/14/2017 0.122 0.039 0.076 3/14/2017 2.24 2.73 96.1 3/14/2017 0.58 0.18 0.15
10/16/2017 0.075 0.385 0.541 10/16/2017 3.60 5.89 49.1 10/16/2017 0.35 1.82 2.55
3/1/2018 0.151 0.145 3.70 3/1/2018 6.95 3.53 244 3/1/2018 0.71 0.68 17.45
9/17/2018 0.07585 0.07585 0.099 9/17/2018 6.01 1.18 29.6 9/17/2018 0.15 0.15 0.47
2/18/2019 0.143 0.736 0.319 2/18/2019 33.6 4.24 82.6 2/18/2019 0.67 3.47 1.50
8/14/2019 0.135 0.233 0.323 8/14/2019 3.93 2.70 23.4 8/14/2019 0.64 1.10 1.52
2/6/2020 0.07585 0.053 0.203 2/6/2020 0.923 2.07 111 2/6/2020 0.15 0.25 0.958
8/4/2020 0.0585 0.0585 0.489 8/4/2020 6.71 0.758 25.8 8/4/2020 0.276 0.276 2.31
3/16/2021 0.138 0.515 0.059 3/16/2021 3.41 3.79 71.1 3/16/2021 0.651 2.429 0.552
7/8/2021 0.0585 0.224 0.0585 7/8/2021 4.15 2.74 60.8 7/8/2021 0.276 1.057 0.276
2/4/2022 0.474 1.84 0.222 2/4/2022 25.6 33.1 126 2/4/2022 2.236 8.679 1.047
Enter rows above this line
Notes: Non-detects entered as 1/2 times the detection limit(values in italics). Notes: Non-detects entered as 1/2 times the detection limit(values in italics). Notes: Non-detects entered as 1/2 times the detection limit(values in italics).
Not sampled/analyzed entered as "NS." Not sampled/analyzed entered as "NS." Not sampled/analyzed entered as "NS."
Yellow higlights indicate exceedence of Benchmark Value. Yellow higlights indicate exceedence of Benchmark Value. Yellow higlights indicate exceedence of Benchmark Value.
Before 2012 Benchmark Value was 19.9 Before 2012 Benchmark Value was 250 Before 2012 Benchmark Value was 13.75

Date Total Nitrogen (mg/1) [Benchmark Value = 30]
MC001 MC002 MC003B MC004US MC004DS MC005
1/29/2003
4/25/2003
9/4/2003
11/19/2003
3/15/2004
6/23/2006
11/7/2006
3/16/2007
7/11/2007
10/24/2007
5/28/2008
11/4/2008
4/6/2009
9/17/2009
7/27/2010
9/27/2010
4/26/2011
10/11/2011
5/9/2012 1.1 1.2 1.9
9/18/2013 1 1.1 1.5
4/19/2013 1.8 18 1
11/1/2013 1.3 4.1 2.5
4/25/2014 2.6 3.3 1.6
9/24/2014 0.59 1.3 1.4
5/21/2015 3.1 5.8 2.4
10/27/2015 1.97 3.99 6.3
3/4/2016 1.36 1.12 2.82
10/7/2016 0.415 0.708 0.731
3/14/2017 2.34 1.82 0.827
10/16/2017 1.12 1.74 3.31
3/1/2018 2.31 0.933 5.58
9/17/2018 1.8 0.724 1.67
2/18/2019 1.04 1.48 3.03
8/14/2019 1.60 0.839 1.71
2/6/2020 0.89 0.398 1.86
8/4/2020 1.07 0.280 1.85
3/16/2021 1.50 2.530 1.72
7/8/2021 1.72 1.66 1.48
2/4/2022 3.47 7.93 3.48
Notes: Non-detects entered as 1/2 times the detection limit(values in italics).
Not sampled/analyzed entered as "NS."
Yellow higlights indicate exceedence of Benchmark Value.

Date Conductivity (Ns/cm) Date
MC001 MC002 MC003B MC004US MC004DS MC005
5/9/2012 0 0.01 0.39 5/9/2012
9/18/2013 28 30 304 9/18/2013
4/19/2013 180 220 503 4/19/2013
11/1/2013 24 61 377 11/1/2013
4/25/2014 57 48 346 4/25/2014
9/24/2014 31 99 330 9/24/2014
5/21/2015 77 198 448 5/21/2015
10/27/2015 101 191 1175 10/27/2015
3/4/2016 107 54 317 3/4/2016
10/7/2016 123 79 351 10/7/2016
3/14/2017 135 118 306 3/14/2017
10/16/2017 335 162 363 10/16/2017
3/1/2018 142 129 387 3/1/2018
9/17/2018 130 155 421 9/17/2018
2/18/2019 148 140 362 2/18/2019
8/14/2019 162 176 391 8/14/2019
2/6/2020 162 158 381 2/6/2020
8/4/2020 156 142 290 8/4/2020
3/16/2021 121 147 286 3/16/2021
7/8/2021 162 182 304 7/8/2021
2/4/2022 189 197 289 2/4/2022
Enter rows above this line
Notes: Non-detects entered as 1/2 times the detection limit (values in italics). Notes: Non-
Not sampled/analyzed entered as "NS." Not s;
Yellow higlights indicate exceedence of Benchmark Value. Yellov
Date COD (mg/1) [Benchmark Value = 120] Date
MC001 MC002 MC003B MC004US MC004DS MC005
5/9/2012 16 5 56 5/9/2012
9/18/2013 38 23 59 9/18/2013
4/19/2013 35 370 46 4/19/2013
11/1/2013 17 56 48 11/1/2013
4/25/2014 90 100 25 4/25/2014
9/24/2014 21 26 40 9/24/2014
5/21/2015 35 53 30 5/21/2015
10/27/2015 61.5 26.6 29.2 10/27/2015
3/4/2016 19.1 17.0 30.1 3/4/2016
10/7/2016 34.9 28.5 32.3 10/7/2016
3/14/2017 19.1 21.4 24 3/14/2017
10/16/2017 24.2 15.5 60.5 10/16/2017
3/1/2018 74.8 28.1 39.0 3/1/2018
9/17/2018 25.7 26.5 32.0 9/17/2018

2/18/2019 13.9 8.09 35.8 2/18/2019
8/14/2019 45.0 5.68 41.0 8/14/2019
2/6/2020 17.2 12.0 21.2 2/6/2020
8/4/2020 14.1 12.0 37.6 8/4/2020
3/16/2021 5.9 5.9 5.9 3/16/2021
7/8/2021 22.6 44.1 41.6 7/8/2021
2/4/2022 77.6 144 5.85 2/4/2022
Enter rows above this line
Notes: Non-detects entered as 1/2 times the detection limit (values in italics). Notes: Non-
Not sampled/analyzed entered as "NS." Not s;
Yellow higlights indicate exceedence of Benchmark Value. Yellov
Green
No Bei
Date Ammonia as N (mg/1) [Benchmark Value = 7.2] Date
MC001 MC002 MC003B MC004US MC004DS MC005
5/9/2012 0.14 0.41 0.12 5/9/2012
9/18/2013 0.05 0.4 0.14 9/18/2013
4/19/2013 0.52 2.1 0.54 4/19/2013
11/1/2013 0.27 1.1 0.6 11/1/2013
4/25/2014 0.62 0.42 0.125 4/25/2014
9/24/2014 0.725 0.42 0.725 9/24/2014
5/21/2015 0.58 2 0.725 5/21/2015
10/27/2015 0.334 1.36 5.09 10/27/2015
3/4/2016 0.141 0.120 0.097 3/4/2016
10/7/2016 0.088 0.205 0.105 10/7/2016
3/14/2017 0.122 0.039 0.076 3/14/2017
10/16/2017 0.075 0.385 0.541 10/16/2017
3/1/2018 0.151 0.145 3.70 3/1/2018
9/17/2018 0.07585 0.07585 0.099 9/17/2018
2/18/2019 0.143 0.736 0.319 2/18/2019
8/14/2019 0.135 0.233 0.323 8/14/2019
2/6/2020 0.07585 0.053 0.203 2/6/2020
8/4/2020 0.0585 0.0585 0.489 8/4/2020
3/16/2021 0.138 0.515 0.059 3/16/2021
7/8/2021 0.0585 0.224 0.0585 7/8/2021
2/4/2022 0.474 1.84 0.222 2/4/2022
Enter rows above this line
Notes: Non-detects entered as 1/2 times the detection limit (values in italics). Notes: Non-
Not sampled/analyzed entered as "NS." Not s;
Yellow higlights indicate exceedence of Benchmark Value. Yellov
Before 2012 Benchmark Value was 19.9 Befor(
Date Total Nitrogen (mg/1) [Benchmark Value = 30]
MC001 MC002 MC003B MC004US MC004DS MC005

5/9/2012 1.1 1.2 1.9
9/18/2013 1 1.1 1.5
4/19/2013 1.8 18 1
11/1/2013 1.3 4.1 2.5
4/25/2014 2.6 3.3 1.6
9/24/2014 0.59 1.3 1.4
5/21/2015 3.1 5.8 2.4
10/27/2015 1.97 3.99 6.3
3/4/2016 1.36 1.12 2.82
10/7/2016 0.415 0.708 0.731
3/14/2017 2.34 1.82 0.827
10/16/2017 1.12 1.74 3.31
3/1/2018 2.31 0.933 5.58
9/17/2018 1.8 0.724 1.67
2/18/2019 1.04 1.48 3.03
8/14/2019 1.60 0.839 1.71
2/6/2020 0.89 0.398 1.86
8/4/2020 1.07 0.280 1.85
3/16/2021 1.50 2.530 1.72
7/8/2021 1.72 1.66 1.48
2/4/2022 3.47 7.93 3.48
Notes: Non-detects entered as 1/2 times the detection limit (values in italics).
Not sampled/analyzed entered as "NS."
Yellow higlights indicate exceedence of Benchmark Value.

pH (SU) [Benchmark Value = 6 - 9] Date Total St
MC001 MC002 MC003B MC004US MC004DS MC005 MC001
NS NS NS NS NS NS
7.67 6.85 7.78 5/9/2012 2.8
7.0 6.8 7.6 9/18/2013 7.1
6.12 6.14 8.3 4/19/2013 4.8
6.1 6.0 6.82 11/1/2013 3.5
6.3 6.7 8.6 4/25/2014 80
8.7 7.1 6.9 9/24/2014 37
6.4 6.5 7.9 5/21/2015 26
7.2 6.6 6.8 10/27/2015 53.5
4.0 4.0 6.4 3/4/2016 35.8
6.51 6.57 7.18 10/7/2016 5.15
6.71 6.6 7.09 3/14/2017 8.9
6.83 6.28 7.59 10/16/2017 10.1
6.27 6.62 6.89 3/1/2018 17.6
6.48 6.39 6.83 9/17/2018 1.52
6.80 6.31 7.40 2/18/2019 14.1
6.51 6.21 7.26 8/14/2019 14.7
6.51 6.72 7.35 2/6/2020 10.3
6.81 6.72 7.02 8/4/2020 3.47
6.63 6.81 7.01 3/16/2021 35.2
6.82 6.49 7.11 7/8/2021 6.2
6.71 6.62 7.06 2/4/2022 95.0
detects entered as 1/2 times the detection limit (values in italics). Notes: Non-detects entered
ampled/analyzed entered as "NS." Not sampled/analyze,
v higlights indicate exceedence of Benchmark Value. Yellow higlights indic�
TKN (mg/1) [Benchmark Value = 30] Date Nitrate
MC001 MC002 MC003B MC004US MC004DS MC005 MC001
0.78 0.83 1.9 5/9/2012 0.32
0.89 0.8 1.5 9/18/2013 0.14
1.2 17 1.0 4/19/2013 0.59
0.98 3.2 2.3 11/1/2013 0.31
1.9 1.8 1.3 4/25/2014 0.68
0.59 1.3 1.4 9/24/2014 0.05
2 4.1 2.1 5/21/2015 1.1
0.942 2.31 6.3 10/27/2015 1.03
0.532 0.459 0.920 3/4/2016 0.826
0.192 0.449 0.696 10/7/2016 0.223
0.558 0.767 0.774 3/14/2017 1.78
0.652 0.956 3.31 10/16/2017 0.471
0.990 0.520 4.73 3/1/2018 1.32
0.939 0.626 1.31 9/17/2018 0.865

0.337 0.866 0.988 2/18/2019 0.702
0.704 0.569 1.71 8/14/2019 0.895
0.513 0.338 0.283 2/6/2020 0.372
0.559 0.169 1.85 8/4/2020 0.507
0.670 1.90 0.837 3/16/2021 0.83
0.578 1.19 1.48 7/8/2021 1.14
2.51 7.11 1.52 2/4/2022 0.956
detects entered as 1/2 times the detection limit (values in italics). Notes: Non-detects entered
ampled/analyzed entered as "NS." Not sampled/analyze,
v higlights indicate exceedence of Benchmark Value. Yellow higlights indic
i highlights means parameter analyzed/used for Total Nitrogen Calculation.
nchmark Value for this parameter beginning in 2012.
Sulfate (mg/1) [Benchmark Value = 500] Date Amm
MC001 MC002 MC003B MC004US MC004DS MC005 MC001
2.5 2.5 38 5/9/2012 0.05
2.5 2.5 28 9/18/2013 0.05
2.5 7.8 72 4/19/2013 0.05
2.5 6.8 69 11/1/2013 0.05
2.5 2.5 74 4/25/2014 0.05
2.5 5 29 9/24/2014 0.05
2.5 13 64 5/21/2015 0.25
5.66 22.9 469 10/27/2015 0.58
5.57 5.86 115 3/4/2016 0.67
3.00 3.15 77.3 10/7/2016 0.42
2.24 2.73 96.1 3/14/2017 0.58
3.60 5.89 49.1 10/16/2017 0.35
6.95 3.53 244 3/1/2018 0.71
6.01 1.18 29.6 9/17/2018 0.15
33.6 4.24 82.6 2/18/2019 0.67
3.93 2.70 23.4 8/14/2019 0.64
0.923 2.07 111 2/6/2020 0.15
6.71 0.758 25.8 8/4/2020 0.276
3.41 3.79 71.1 3/16/2021 0.651
4.15 2.74 60.8 7/8/2021 0.276
25.6 33.1 126 2/4/2022 2.236
detects entered as 1/2 times the detection limit (values in italics). Notes: Non-detects entered
ampled/analyzed entered as "NS." Not sampled/analyze,
v higlights indicate exceedence of Benchmark Value. Yellow higlights india
2012 Benchmark Value was 250 Before 2012 Benchmz

ispendid Solids (mg/1) [Benchmark Value = 100]
MC002 MC003B MC004US MC004DS MC005
15 10
54 5.2
64 2.6
85 13
7.7 4.1
29 9.3
46 29
15.1 4.4
12.0 3.20
119 4.92
7.73 1.58
13.8 21
22.7 4.56
3.79 3.60
7.55 1.46
36.5 8.20
30.0 1.27
1.73 10.40
34.40 7.27
25.6 15.6
154 1.365
as 1/2 times the detection limit (values in italics).
d entered as "NS."
ate exceedence of Benchmark Value.
e + Nitrite as N (mg/1) [Benchmark Value = 10]
MC002 MC003B MC004US MC004DS MC005
0.35 0.05
0.32 0.05
0.69 0.05
0.9 0.16
1.5 0.3
2.3 0.05
1.7 0.05
1.86 0.05
0.657 1.90
0.259 0.035
1.05 0.053
0.783 0.07
0.413 0.848
0.626 1.31

0.616 2.04
0.27 0.00985
0.060 1.58
0.111 0.025
0.629 0.880
0.471 0.025
0.822 1.96
as 1/2 times the detection limit (values in italics).
d entered as "NS."
ate exceedence of Benchmark Value.
ionium Sulfate (mg/1) [Benchmark Value = 19]
MC002 MC003B MC004US MC004DS MC005
0.05 0.566
0.05 0.66038
9.91 2.55
5.19 2.83
0.05 0.05
1.98 0.05
9.43 0.725
6.42 24.01
0.57 0.46
0.97 0.50
0.18 0.15
1.82 2.55
0.68 17.45
0.15 0.47
3.47 1.50
1.10 1.52
0.25 0.958
0.276 2.31
2.429 0.552
1.057 0.276
8.679 1.047
as 1/2 times the detection limit (values in italics).
d entered as "NS."
ate exceedence of Benchmark Value.
irk Value was 13.75

Total Maximum Daily Load to Address
Impaired Biological Integrity
in the Perry Creek Watershed, Neuse River Basin
April 2010
EPA Approval on May 13, 2010
North Carolina Department of Environment and Natural Resources
Division of Water Quality

Table of Contents
SUMMARY.................................................................................................................... 3
IMPLEMENTATION SUMMARY............................................................................... 3
INTRODUCTION .......................................................................................................... 3
APPLICABLE SURFACE WATER QUALITY STANDARDS AND RULES........... 5
WATERSHED DESCRIPTION..................................................................................... 6
POLLUTANT SOURCE ASSESSMENT...................................................................... 8
STRESSOR IDENTIFICATION.................................................................................... 8
WATER QUALITY TARGET..................................................................................... 10
SEASONAL VARIATION AND CRITICAL CONDITIONS.................................... 11
WASTELOAD ALLOCATION (WLA) AND LOAD ALLOCATION (LA)............. 12
TMDL IMPLEMENTATION ...................................................................................... 13
IMPLEMENTATION RESOURCES........................................................................... 14
REFERENCES ............................................................................................................. 16
Appendix 1 Summary data from all benthos sites in the Perry Creek
Watershed, from 1995 to present.
Perry Creek TMDL Page 2

SUMMARY
Based on a weight of evidence analysis for the Perry Creek watershed, the two most
important factors contributing to impairment are scour and habitat degradation. These
stressors and other indicator parameters are associated with the high levels of
development(impervious areas) in the Perry Creek watershed.
A TMDL must address stressors believed to be contributing to the impairment. Where
the major cause of impairment is stormwater runoff, the use of surrogate indicators
expressed as quantitative targets is appropriate in TMDL development. Because of
stormwater-associated pollutants and the effects on the system's hydrology, these targets
are used as surrogates to estimate stormwater pollutant load reductions needed to meet
water quality standards.
IMPLEMENTATION SUMMARY
The goal of this TMDL is to achieve water quality standards, in this case, a benthic
macroinvertebrate community bioclassification of Not Impaired, Good-Fair, or better.
Achievement of this water quality standard may be met by plementing management
practices designed to mitigate the effects of stormwater runoff. Eliminating impervious
cover(IC) is not necessary to reach the TMDL target reductions. Aquatic life (biological
community)will be the measure of TMDL success.
When the TMDL is implemented, stressors (scour and habitat degradation, for example)
will be reduced.
INTRODUCTION
Section 303(d)(1)(C) of the federal Clean Water Act(CWA) and the U.S. Environmental
Protection Agency's (EPA) implementing regulations direct each State to develop a Total
Maximum Daily Load (TMDL) for each impaired segment on the Section 303(d) list,
taking into account seasonal variations and a protective margin of safety(MOS)to
account for uncertainty. Traditionally, a TMDL reflects the total pollutant loading of the
impairing substance a waterbody can receive and still meet water quality standards.
The purpose of this report is to establish a TMDL to address the aquatic life impairments
in the Perry Creek watershed. The goal is to provide the basis for improving the
watershed ecosystem through implementation of stormwater best management practices
such that the beneficial uses of the waterbodies are restored. Upon approval by EPA, this
TMDL becomes part of the NC Division of Water Quality(DWQ)Neuse River
Basinwide Water Quality Plan.
In 2002, EPA provided clarifications of existing regulatory requirements for establishing
wasteload allocations (WLAs) for stormwater discharges in TMDLs (EPA Memorandum
2002). Specific key points of the memorandum include:
• EPA expects that most Water Quality Based-Effluent Limits (WQBELs) for
NPDES-regulated municipal and small construction stormwater discharges will
Perry Creek TMDL Page 3

be in the form of Best Management Practices, and that numeric limits will be
used only in rare instances.
When a non-numeric WQBEL is imposed, the permit's administrative record,
including the fact sheet when one is required, needs to support that the BMPs are
expected to be sufficient to implement WLA in the TMDL.
It may be reasonable to express allocations for NPDES-regulated stormwater
discharges from multiple point sources as a single categorical wasteload
allocation when data and information are insufficient to assign each source or
outfall individual WLAs.
EPA expects TMDL authorities to make separate allocations to NPDES-regulated
stormwater discharges (in the form of WLAs) and unregulated stormwater(in the
form of load allocations). EPA recognizes that these allocations might be fairly
rudimentary because of data limitations and variability in the system.
This TMDL applies to the entire Perry Creek watershed, which includes the assessment
units listed in Table 1.
Table 1. Perry Creek Watershed Assessment Units and Descriptions
Assessment Sampling Current
Stream Name Unit Number Location Description Bioclassification
A *
Perry Cr 27-25-(2) SR 2006 From dam at Greshams Fair 2005
Lake to Neuse River.
Perry Cr 27-25-(1) Hunters From source to dam at Not Rated 2004
Way Greshams Lake
Unnamed From dam at Camp
Tributary Perry 27-25-3-(2) SR 3514 Durant to Perry Creek Not Rated 2004
Cr
Unnamed
Tributary Perry 27-25-3-(1) N/A From source to dam at N/A
Cr Camp Durant
* See Figure 1 for spatial reference.
Perry Creek at SR 2006 has been on the NC 303(d) list of impaired waters since 1998.
Perry Creek at Hunters Way was sampled approximately 500 meters downstream of an
impoundment. Because of the sampling site's close proximity to an impoundment, a
bioclassification of Not Rated was given for this location. This segment [AU#27-25-(1)]
will be moved to Category 4c in a subsequent Integrated Report because of the impact of
the impoundment. EPA's 4c category is defined as the non-attainment of any applicable
water quality standard which is the result of pollution and is not caused by a pollutant.
The Unnamed Tributary(UT) Perry Creek at SR 3514 is considered impaired for
biological integrity but is not listed on the 303(d) list due to the Not Rated
bioclassification. A bioclassification of Not Rated can be assigned to streams which have
a drainage area size less than three square miles and would have received a Fair or Poor
Perry Creek TMDL Page 4

bioclassification using the benthic macroinvertebrate criteria derived for larger streams
(NCDWQ 2003). The UT Perry Creek(AU#27-25-3-(1))benthic macroinvertebrate
community has not been assessed.
APPLICABLE SURFACE WATER QUALITY STANDARDS AND RULES
TMDLs are established to achieve and maintain water quality standards. A water quality
standard is the combination of a designated use for a particular body of water and the
water quality criteria designed to protect that use. Examples of designated uses include
aquatic life survival and propagation, swimming, drinking water supply, and shellfish
harvesting. Water quality criteria consist of narrative statements and numeric values
designed to protect the designated uses. Criteria may differ among waters with different
designated uses.
The surface water classifications for the Perry Creek watershed include Class C and Class
B uses. All waters in North Carolina have the base classification of"C." Class C waters
are protected for aquatic life propagation and biological integrity(including fishing and
fish),wildlife, secondary recreation, agriculture and other uses suitable for Class C.
There are no restrictions on watershed development or types of discharges associated
with Class C (15A NCAC 0213.0211, 2007).
In addition, the Perry Creek segment AU#27-25-(1) from source to Greshams Lake dam
and the UT Perry Creek segment AU#27-25-3-(1), from source to dam at Camp Durant
are protected as Class B for primary recreation. Class B uses are primary recreational
activities that include swimming, skin diving, water skiing, and similar uses involving
human body contact with water where such activities take place in an organized manner
or on a frequent basis.
Since the Perry Creek watershed is in the Neuse River Basin, waters have the
supplemental water quality classification of Nutrient Sensitive Waters (NSW). This
supplemental classification is intended for waters needing additional nutrient
management due to their experiencing or being subject to excessive growth of
microscopic or macroscopic vegetation. In general, management strategies for point and
nonpoint source pollution control require control of nutrients (nitrogen and/or phosphorus
usually) (15A NCAC 02B.0233, 2007). The Neuse River Basin-Nutrient Sensitive
Waters Management Strategy: Basinwide Stormwater Requirements are designed for
local governments to implement their own stormwater management plan (15A NCAC
0213.0235, 2007). This requirement has been in effect since August 1, 1998.
This TMDL addresses Perry Creek watershed, which has impaired biological integrity.
Impairment for biological integrity is based on a narrative standard that pertains to the
aquatic life use designation. Biological integrity means "the ability of an aquatic
ecosystem to support and maintain a balanced and indigenous community of organisms
having species composition, diversity,population densities and functional organization
similar to that of reference conditions" (15A NCAC 02B.0202, 2007).
DWQ's criterion for assessing aquatic life as impaired is a biological community at a
benthic macroinvertebrate or fish sampling site with a bioclassification of Poor, Fair or
Severe Stress. The criterion for assessing aquatic life as supporting is a bioclassification
Perry Creek TMDL Page 5

of Good-Fair, Good, Excellent,Not Impaired,Natural or Moderate Stress at a biological
community sampling site.
Biological impairments to the Perry Creek watershed were identified using bioassessment
protocols outlined in the North Carolina's Standard Operating Procedure for Benthic
Macroinvertebrates (NCDWQ 2006). Perry Creek at SR 2006 has carried a benthic
macroinvertebrate bioclassification of Fair since 1995. The supporting data analysis that
resulted in the listing for impaired biological integrity is located in Appendix 1.
Habitat evaluation is not currently linked to the North Carolina Piedmont
bioclassification ratings so there are no habitat thresholds or breakpoints distinguishing
"condition groups" (e.g., Excellent, Good, Good-Fair, Fair, or Poor); higher overall
scores simply represent better aquatic habitat than lower overall scores. To reduce the
subjectivity of visual interpretations of the habitat components, the DWQ assessment
form provides definitions of various conditions and the associated score (NCDWQ 2006).
The DWQ methodology(2006) for evaluating instream aquatic habitat focuses on eight
key components that affect the availability and suitability of habitat. The components are
rated individually and the summation of the scores ranges from 0 to 100, with 100
reflecting the highest quality habitat. Habitat scores for the sites in the Perry Creek
watershed are provided in Appendix 1. The eight components and their relative weight to
the overall score are:
• Channel modification(5)
• Instream habitat types (20)
• Bottom substrate (15)
• Pool variety 0 0)
• Riffle habitats (16)
• Bank stability and vegetation (14)
• Light penetration(10)
• Riparian vegetative zone width(10)
WATERSHED DESCRIPTION
The Perry Creek watershed is located in northeast Raleigh, Wake County, in the Neuse
River Basin. The mainstem of Perry Creek flows generally east toward its confluence
with the Neuse River. This watershed is within the USGS 12-digit hydrologic unit(HU)
030202010704, which is approximately 31.6 square miles in area. For purposes of this
TMDL, the Perry Creek watershed was extracted from the 12-digit HU. It comprises a
smaller drainage area of I I square miles (Figure 1). The TMDL watershed is defined as
Perry Creek from source to SR 2006 (Perry Creek Road) and all tributaries draining to
this portion of Perry Creek(Figure 1).
The TMDL watershed lies within the City of Raleigh's jurisdiction. Two major
highways (US I and I-540) transect this TMDL watershed. The predominant land cover
is developed with extensive residential subdivisions and urban office parks/commercial
areas. Impervious surfaces (areas such as roof tops, roads and parking lots that prevent
infiltration of precipitation into the soil) cover approximately 17% of this watershed.
Significant impacts to stream biota can generally be expected with this degree of
unmitigated impervious cover(Schueler, 1994).
Perry Creek TMDL Page 6

The watershed is located in the Northern Outer Piedmont ecoregion (45f; Griffith et al.
2002). Upland soils of the watershed consist of a variety of soil associations (Cawthorn,
1970), corresponding to two major geologic belts running in a north-south direction
through the study area. The western portion of the study area(encompassing the
headwaters of Perry Creek to U.S. 1)has predominant soils of the Cecil-Appling
associations, derived primarily from crystalline materials (mostly granite, gneiss and
shist) and mudstone. Soils along the eastern portion of the study area(from U.S. 1 to the
confluence of the Neuse River). are largely of the Wehadkee series. These are nearly
level poorly drained soils formed in sandy alluvium and are common along streams in
Wake County.
Impoundments in the watershed include Greshams Lake on Perry Creek and a lake at
Camp Durant on an unnamed tributary(UT) to Perry Creek. Smaller impoundments are
also present: two above Greshams Lake on Perry Creek, one above the Lake at Camp
Durant, and two in the upper watershed of an unnamed tributary originating near U.S. 1.
Figure 1. Perry Creek TMDL watershed
N
1-540 •
Unn ed Tributary Per r
-25-341) • �
1-549 27-25-3 2)
U51
err ree r
2 25r(1} j Perry Creek
2T-2S(2
U 51 1-540
N
Legend
Perry Creek Watershed
Raleigh City Limits
�r Benthic Monitoring Compliance Site
Perry Creek TMDL Page 7

POLLUTANT SOURCE ASSESSMENT
This TMDL report largely draws its information from two stressor studies conducted by
DWQ in 2004 for the Perry Creek watershed. These efforts analyzed the causes of
impairment by measuring various water chemistry, sediment toxicity,physical and
biological parameters (NCDWQ 2004a,NCDWQ 2004b).
The NCDWQ Environmental Sciences Section conducted two stressor studies in 2004.
(NCDWQ 2004a,NCDWQ 2004b). Stressor studies are specialized studies that attempt
to identify specific factors leading to degraded water quality conditions. The assessment
included field measurements and water chemistry data identifying potential causes of
impairment. Major watershed activities and sources of pollution contributing to those
causes such as stream bank erosion and stormwater runoff from urban areas were
identified.
In addition, DWQ's Biological Assessment unit conducted a stressor study in May 2004.
This effort assessed benthic macroinvertebrates, habitat characteristics, chemical and
physical data to analyze specific stressors identified as causes of impairment to the
aquatic community. This study confirmed potential sources of stressors for TMDL
development and determined the current status of the impairment. The supporting data
analysis that resulted in the listing for impaired biological integrity is located in
Appendix 1.
Conclusions of the studies show aquatic organisms in the Perry Creek watershed are
heavily impacted by multiple stressors associated with high levels of development
(impervious areas).
The relative contribution of these stressors cannot be clearly differentiated based on the
available data. For example, increases in stream flow associated with development
during storm events result in bank erosion and scour. The stream bank erosion and
sedimentation associated with these events contributes to habitat degradation that would
be associated with biological impairment. Additionally, nutrient enrichment associated
with the residential and commercial development around Greshams Lake, possible
leaking sewer lines, and the golf course and residential areas present in the watershed
may also contribute to biological impairment by causing algal activity and lowered
dissolved oxygen levels. A number of impoundments in the watershed were identified as
hindering downstream macroinvertebrate recolonization. No single pollutant or group of
specific pollutants has been identified as the cause of impairment in the watershed.
Significant contributors to impairment of Perry Creek and UT Perry Creek include the
following NPDES Stormwater Phase I permit holders: City of Raleigh (NCS000245) and
NC Department of Transportation (NCDOT) (NCS000250).
STRESSOR IDENTIFICATION
Studies conducted by the Environmental Sciences Section of DWQ in the Perry Creek
watershed in 2004 included a detailed evaluation of the causes of impairment. The
following paragraphs summarize the findings of that analysis. These studies included the
following primary tasks:
• Identification of potential "candidate" causes of impairment in the watershed
Perry Creek TMDL Page 8

• Collection of additional data
• Characterization of the causes of impairment using a"strength of evidence" approach
The strength of evidence evaluation included analysis of whether candidate stressors
were primary causes of impairment, secondary causes of impairment,part of the
cumulative cause of impairment, a contributing stressor, a potential cause or contributor,
or an unlikely cause or contributor. Other sources of evidence evaluated included benthic
macroinvertebrate community data, habitat and riparian area assessment, chemistry,
toxicity data, current watershed activities, land uses, and pollutant sources.
The following candidate causes were not determined to be significant or primary causes
of impairment in Perry Creek and therefore are not addressed by this TMDL:
Toxicity(resulting from residential and commercial development). Water chemistry
data, sediment chemistry and bioassay data, watershed characteristics, and benthic
community data were utilized in the evaluation of toxicity as a cause of impairment.
Although toxic impacts are very episodic and difficult to identify, data from benthic
mentum deformity tests did not show toxic conditions. Water column samples indicated
elevated values for aluminum, iron, and manganese but this is not unusual due to the
presence of these metals in local soil types. Sediment metals samples found no values
above the hazardous waste site screening values used by the USEPA (NCDWQ 2004a).
Hydromodification—Low Dissolved Oxygen.
Although there are areas with poor habitat (including deep uniform stream channels, little
habitat diversity, rip-rap, minimal stream bottom diversity, and very low or no flow
velocities), dissolved oxygen levels are not viewed as a primary limiting factor for
benthos. The watershed is not impaired for dissolved oxygen.
Organic and nutrient enrichment. Benthic community data and water quality monitoring
data were utilized to evaluate organic and nutrient enrichment as a potential cause of
stress on the biological community. The watershed is not impaired for chlorophyll-a or
dissolved oxygen. Although it was difficult to distinguish between the impacts of organic
and nutrient enrichment, based on algal activity there is some enrichment associated with
urbanization such as commercial and residential development,possible leaking sewer
lines and the golf course (NCDWQ 2004a). The control of untreated stormwater runoff
to this watershed should provide benefits to the aquatic community. The nutrient rules
for the Neuse River Basin are applied in the Perry Creek watershed.
The following candidate causes were determined to be significant causes of impairment
in Perry Creek:
Hydromodification and associated scour due to storm flows (resultingfro
rom
development). The Neuse River Basinwide Water Quality Plan (NCDWQ 2009) listed
habitat degradation from urban runoff as a potential cause for impairment based on
biological data. Available data(benthic macroinvertebrate, habitat and riparian area
assessments, stream observations and watershed characteristics)were reviewed to assess
stormflow scour as a cause of impairment in the watershed. Scour associated with rapid
Perry Creek TMDL Page 9

and significant increases in stream flow was found to be the most pervasive stressor in
the watershed. The stream bank erosion and sedimentation associated with these events
contribute to habitat degradation associated with biological impairment. The benthic
macroinvertebrate data lacked specific indicator taxa but rather exhibited highly tolerant
benthic communities, suggesting considerable impacts from urban/suburban pressures.
Hydromodification (resulting from dams). Impacts from dams include the following:
• Prevention of downstream colonization of aquatic populations
• Lower water levels below dams
• Change in temperature and dissolved oxygen
• Change in food type
Although it is difficult to isolate these impacts from those of lower baseflows associated
with urbanization, there is evidence that the lowered water levels below dams are an
important stressor to the biological communities in the Perry Creek watershed. For this
reason, Perry Creek at Hunters Way will be moved to Category 4c, impairment due to
hydromodification. This TMDL does not address this stressor.
Based on a weight of evidence analysis, the two most important factors are scour and
hydromodification (dams); the impacts of nutrient enrichment and habitat degradation are
more localized. Although toxicity was not viewed as a primary cause of impairment,
combined with other causes of impairment, it may contribute to the cumulative effect.
All of the stressors and indicator parameters discussed above are associated with the high
levels of development in the Perry Creek watershed.
WATER QUALITY TARGET
Extensive national and state level research shows strong correlations between impairment
and watershed development. Stormwater runoff from impervious surfaces can carry a
complex array of potential pollutants that can impact the aquatic community. Because of
the uncertainty in identifying specific pollutants in urbanized stormwater runoff,
difficulties arise in quantifying the real target (biological integrity) in a TMDL.
A TMDL must address stressors believed to be contributing to the impairment. Where
the major cause of impairment is stormwater runoff, the use of surrogate indicators
expressed as quantitative targets is appropriate in TMDL development. Because of
stormwater-associated pollutants and the effects on the system's hydrology, these targets
are used as surrogates to estimate stormwater pollutant load reductions needed to meet
water quality standards.
Research conducted by The Center for Watershed Protection(CWP) indicated that
variability in stream quality indicator data is usually dampened when impervious cover
(IC) exceeds 10%, which presumably reflects the stronger influence of stormwater runoff
on stream quality indicators. In particular, the chance that a stream quality indicator will
attain a high quality score is sharply diminished at higher IC levels. This trend becomes
pronounced within the 10 to 25% IC range and almost inevitable when watershed IC
exceeds 25%. This pattern suggests that IC is a more robust and reliable indicator of
overall stream quality beyond the 10% IC threshold(CWP 2003).
Perry Creek TMDL Page 10

According to `Estimating and Projecting Impervious Cover in the Southeastern United
States' (USEPA 2005), degraded benthic community sites are evident as impervious area
increases. Specifically, among sites in North Carolina with a total impervious area
greater than 10%, 62%were degraded. In contrast, 90% of sites with less than 10% IC
were not degraded.
Based on the above findings, the surrogate TMDL target for Perry Creek is 9% IC. This
target incorporates a 1% IC margin of safety. North Carolina data in the USEPA study
(2005) indicate that 10% of sites with<10% impervious cover could remain degraded.
The Perry Creek TMDL target is expected to protect all waters, however, because the
measure of TMDL success is based upon water quality standards for benthic
macroinvertebrate data and not upon a quantified actual reduction in IC. Specifically, the
goal of this target is to achieve a benthic macroinvertebrate community bioclassification
of Good-Fair,Not Impaired or better. Achievement of this water quality standard may be
met by plementing management practices designed to mitigate the effects of
stormwater runoff. Because IC is a surrogate measure, eliminating IC is not necessary in
reaching the TMDL target reductions. Measuring the aquatic life (biological community)
directly will be the method for assessing attainment of the TMDL goal. "TMDLs may be
established using a pollutant-by-pollutant or biomonitoring approach." (40 CFR
130.7(c)(1)(i)) This approach was first used in North Carolina for the Swift Creek
TMDL(NCDWQ 2009), approved by USEPA in 2009.
SEASONAL VARIATION AND CRITICAL CONDITIONS
Regulations require that a TMDL be established with consideration of seasonal
variations. Stormwater flows occur throughout the year, with different environmental
effects at both low and high flows. Critical conditions for aquatic life protection are not
limited to flow conditions or time of year. Benefits realized from impervious cover
mitigation occur in all seasons because stormwater management will be implemented to
meet the IC target and will reduce adverse impacts (pollutant loading and damaging
flows) for the full spectrum of storms throughout the year.
MARGIN OF SAFETY
A Margin of Safety(MOS) is required as part of a TMDL in recognition of many
uncertainties in the understanding and simulation of water quality in natural systems. For
example, knowledge is incomplete regarding the exact nature and magnitude of pollutant
loads from various sources and the specific impacts of those pollutants on the chemical
and biological quality of complex, natural water bodies. The MOS is intended to account
for such uncertainties in a manner that is conservative from the standpoint of
environmental protection.
A 1% IC Margin of Safety(MOS) was subtracted from the surrogate TMDL target to
account for uncertainty in the analysis, resulting in a combined WLA and LA target of
9%. The goal of the TMDL is to reduce impacts from stormwater on the aquatic life in
the Perry Creek watershed.
Perry Creek TMDL Page 11

WASTELOAD ALLOCATION (WLA)AND LOAD ALLOCATION (LA)
In the Perry Creek watershed there are no continuous NPDES wastewater discharges,
individual industrial stormwater discharges, or permitted animal operations. There are
two intermittent NPDES permitted dischargers in the Perry Creek watershed. The City of
Raleigh (NCS000245) and the NC Department of Transportation (NCS000250) are
regulated under Phase I NPDES Stormwater permits. The WLA portion of this TMDL
applies to these Phase I NPDES permits. This TMDL applies to designated and future
MS4 permits that are subject to the NPDES program.
Stormwater discharges are highly variable in frequency and duration. It is reasonable to
express allocations for NPDES-regulated stormwater discharges from multiple point
sources as a single categorical wasteload allocation when data and information are
insufficient to assign each source or outfall individual WLAs (EPA Memorandum 2002).
This TMDL applies the surrogate 9% IC target to the stormwater drainage area affecting
both regulated and non-regulated sources in this watershed.
To calculate the equivalent of% IC reductions required to achieve the TMDL target:
Equivalent of percent IC reduction= [(IC Current Condition—surrogate IC Target)/IC
Current Condition)] x 100
where surrogate IC Target= 9%
The equivalent of percent IC reduction (Table 2)was calculated for the Perry Creek
TMDL watershed(Figure 1). The equivalent IC reduction is 47% for the TMDL
watershed(Table 2). This TMDL watershed was extracted from the USGS 12-digit
hydrologic unit(HU) 030202010704 and is approximately eleven square miles in area.
The current condition(Table 2)was calculated from analysis of existing percent
imperviousness using the National Land Cover Dataset(2001), supplemented by the
Watershed Assessment Model for North Carolina (Pate 2009). The current condition for
the Perry Creek TMDL watershed is 17% impervious.
Table 2. TMDL Targets, Surrogate Targets, and Equivalent Percent Reductions for
Perry Creek TMDL Watershed
Percent Impervious Cover
TMDL Target TMDL WLA Current Equivalent%Reduction
Bioclassification Surrogate and MOS
T Condition
Target LA
Good-Fair or o 0 1% 0 47%Equivalent of%IC reduction
better 10/0 9/0 17/o accomplished by improved stormwater
management.
*Equivalent of%IC reduction means actions that mitigate the adverse impacts of stormwater,including
but not limited to reducing pollutant loading and reducing the volume of storm runoff. Such actions could
include disconnecting IC,installing infiltration basins,eliminating illicit discharges,etc.
Achieving the equivalent%IC reduction will require mitigation of the adverse impacts of
stormwater, including but not limited to reducing pollutant loading and reducing the
volume of storm runoff. Such actions could include disconnecting IC, installing
Perry Creek TMDL Page 12

infiltration basins, eliminating illicit discharges, etc. The TMDL target bioclassification
of Good-Fair or better will be measured at the benthic compliance points (Figure 1).
TMDL IMPLEMENTATION
EPA is not required to, and does not, approve TMDL implementation plans. This section
is intended to provide some initial assistance for implementing this TMDL.
This TMDL applies to designated and future MS4 permits that are subject to the NPDES
program. The linkage of the TMDL with the NPDES Stormwater Phase I permits will
constitute a significant portion of the implementation. The goal of this TMDL is to
reduce the effects of stormwater impacts to the receiving streams so that water quality
standards for biological integrity are met. Attainment of such a standard is achieved
when a benthic macroinvertebrate community sample receives a bioclassification of Not
Impaired, Good-Fair or better. Compliance will be measured at the benthic sampling
sites at Perry Cr at SR 2006 and UT Perry Cr at SR 3514 (Figure 1).
Implementation for this TMDL will best be accomplished through incorporating an
adaptive management strategy for stormwater runoff. Such a strategy should include one
or more of the following for new and existing development:
• Installing engineering BMPs to reduce the impacts of stormwater runoff from
impervious areas.
• Minimizing additional disturbance to maintain existing natural buffering capacity
• Disconnecting impervious cover from the surface waterbodies to reduce peak
flows and volumes of stormwater runoff.
• Reducing impervious cover.
• Adopting land use ordinances that require or allow Low Impact Development
(LID)techniques or other non-structural best management practices.
• Detecting and eliminating illicit discharges.
• Developing an educational component and outreach program.
Affected entities may propose alternative measures that meet the intent of the TMDL.
Stormwater impacts include erosion and damage to instream aquatic habitat, a complex
mix of pollutant loading, and lack of infiltration to provide stable base flow to streams.
When the TMDL is implemented, stressors affecting aquatic life will be reduced or not
delivered to the waterbody in the first place.
The waterbodies draining this watershed are located in urbanized areas that are subject to
the requirements of North Carolina's NPDES Phase I Stormwater permit. Several efforts
for addressing stormwater runoff are currently in place for the City of Raleigh under their
permit. The city must develop, implement and enforce a Stormwater Management Plan
and ordinances approved by the NC Department of Environment and Natural Resources
(NCDENR). The plan includes educational and regulatory initiatives to ensure sound
development. Ordinances approved by NCDENR and adopted by Raleigh address
requirements for new development, illicit discharges detection and elimination,
watershed protection, and sediment and erosion control. The City of Raleigh was issued
a NPDES Stormwater Permit, effective June 1, 2007. Under the NPDES permit,
stormwater runoff from new development that disturbs greater than or equal to one acre,
including projects less than one acre that are part of a larger common plan of
Perry Creek TMDL Page 13

development or sale, must be controlled and treated in accordance with the conditions of
the permit and the Stormwater Management Plan. The permit and Stormwater
Management Plan mandate:
1. A public education and outreach program on the impacts of stormwater
discharges and how to reduce pollutants in stormwater runoff.
2. A public involvement and participation program.
3. A program to detect and eliminate illicit discharges within the jurisdictional
area.
4. A program to reduce pollutants in any stormwater runoff from construction
activities resulting from a land disturbance of greater than or equal to one
acre.
5. A program to address post-construction stormwater runoff from new
development that cumulatively disturb greater than or equal to one acre,
including projects less than one acre that are part of a larger common plan of
development or sale; and
6. A pollution prevention/good housekeeping program for municipal operations
that addresses operation and maintenance, including a training component, to
prevent or reduce pollutant runoff from those operations.
Raleigh and Wake County are subject to the Neuse River Basin—Nutrient Sensitive
Waters Management Strategy: Basinwide Stormwater Requirements (15A NCAC
02B.0235).
Since implementation is expected to meet TMDL requirements at the compliance points
(Figure 1,benthic macroinvertebrate sampling sites), an ongoing biological monitoring
program is critical in assessing the effectiveness of the implementation efforts. DWQ
will continue monitoring the biological communities in this watershed to track TMDL
implementation and attainment of water quality standards. This will be an iterative
process to meet TMDL targets for attaining a bioclassification of Good-Fair or better at
the compliance points. This process is recognized as lengthy, possibly spanning multiple
permit cycles.
IMPLEMENTATION RESOURCES
Resources are available to assist in the implementation of this TMDL.
The Center for Watershed Protection has produced a series of Urban Subwatershed
Restoration Manuals. The manuals provide comprehensive information on watershed
restoration techniques by introducing an integrated framework for restoration and
techniques for assessing urban watersheds. The manual series can be located here:
http://www.cLwp.or,zIPublicationStorelUSRM.htm
A report prepared for The United States Environmental Protection Agency, Stormwater
TMDL Implementation Support Manual, March 2006(Project No: 10598-001-500)
shows the impervious cover method used in developing TMDL targets. The report can
be located here: http://www.epa.gov/ne/eco/tmdl/assets/pdfs/Stormwater-TMDL-
Implementation-Support-Manual.pdf
Perry Creek TMDL Page 14

The North Carolina Division of Water Quality 2007 Stormwater BMP Manual provides
guidance for meeting stormwater regulations and designing stormwater BMPs that meet
water quality objectives. The manual can be located here:
http://h2o.enr.state.nc.us/su/bmp_updates.htm
The North Carolina State University developed a NC Low Impact Development
Technique document. The project documented changes in runoff and pollutant export
resulting from the construction of a low impact development residential subdivision.
This is located here: http://www.bae.ncsu.edu/programs/extension/wqg/.
Perry Creek TMDL Page 15

REFERENCES
Cawthorn, J.W. 1970. Soil Survey of Wake County North Carolina. USDA Soil
Conservation Service.
Center for Watershed Protection. 2003. Impacts of Impervious Cover on Aquatic Systems.
Griffith, G.E., Omernik, J.M., Comstock, J.A., Schafale, M.P., McNab, W.H., Lenat,
D.R., and MacPherson, T.F., 2002, Ecoregions of North Carolina,U.S. Environmental
Protection Agency, Corvallis, OR
North Carolina Division of Water Quality. 2006. Standard Operating Procedures For
Benthic Macroinvertebrates.
North Carolina Division of Water Quality. 2007. Fresh Surface Water Quality Standards
for Class C Waters, 15A NCAC 02B.0211.
North Carolina Division of Water Quality. 2007. Fresh Surface Water Quality Standards
for Class WS-III Waters, 15A NCAC 02B.0215.
North Carolina Division of Water Quality. 2007. Neuse River Basin Nutrient Sensitive
Waters Management Strategy: Basinwide Stormwater Requirements, 15A NCAC
02B.0235.
North Carolina Division of Water Quality. 2009. Neuse River Basinwide Water Quality
Plan.
North Carolina Division of Water Quality. 2009. Total Maximum Daily Load for
Addressing Impaired Biological Integrity in the Headwaters of Swift Creek Watershed,
Neuse River Basin.
North Carolina Division of Water Quality, Environmental Sciences Section. 2004a.
TMDL Stressor Study Memorandums. October 15 &27
North Carolina Division of Water Quality, Environmental Sciences Section. 2004b.
TMDL Stressor Study Memorandums. November 9
North Carolina Division of Water Quality. 2007. Stormwater Best Management Practices
Manual.
North Carolina Division of Water Quality. 2006. Draft TMDL Water Quality Recovery
Program Guidance Document.
Pate, Travis. 2009. Watershed Assessment Model for North Carolina. Master's Project-
University of North Carolina-Chapel Hill.
Schueler, T.R. 1994. The Importance of Imperviousness. Watershed Protection
Techniques1, 100-111.
Perry Creek TMDL Page 16

United States Environmental Protection Agency. 2005. Estimating and Projecting
Impervious Cover in the Southeastern United States. EPA/600/R-05/061.
United States Environmental Protection Agency, Memorandum. 2002. Establishing
TMDL Wasteload Allocations (WLAs)for Stormwater Sources and NPDES Permit
Requirements Based on Those WLAs.
Perry Creek TMDL Page 17

Appendix 1. Summary data for all benthos sites in the Perry Creek Watershed,
from 1995 to present.
Perry Cr Perry Cr Perry Cr Perry Cr Perry Cr UT Perry Cr
Hunters Way SR 2006 SR 2006 SR 2006 SR 2006 SR 3514
5/11/2004 7/25/1995 12/9/1996 7/6/2000 5/10/2004 5/10/2004
COMMUNITY
Ephemeroptera 2 5 6 6 5 6
Plecoptera 0 0 3 0 0 0
Trichoptera 3 3 2 2 4 4
Coleoptera 4 0 0 0 8 4
Odonata 5 0 0 0 7 8
Megaloptera 0 0 0 0 1 1
Diptera:Chironomidae 13 0 1 0 0 26 31
Misc. Diptera 5 0 0 0 4 4
Oligochaeta 4 0 0 0 3 5
Crustacea 1 0 0 0 2 1
Mollusca 3 0 0 0 2 4
Other 4 0 0 0 1 1
Total Taxa Richness 44 8 11 8 63 70
EPT Richness 5 8 11 8 9 10
Seasonal Corr 5 8 8 8 9 10
out of season s
EPT Abundance 34 30 51 50 67 77
Biotic Index 6.97 - - - 6.88 6.92
Seasonal Correction 7.17 7.08 1 7.12
EPT BI 6.97 5.87 5.57 1 5.23 1 6.26 1 5.84
Bioclassification Not Rated Fair Fair Fair Fair Not Rated
HABITAT
Stream Width 3 9 5 7 5 4
Average Depth 0.1 0.2 0.2 0.2 0.2 0.2
Flow/Current Moderate Moderate Moderate Moderate Moderate Moderate
Bank Height 1.5 1.5 0.5
Bank Angle(1) 60 90 90
Bank Erosion None Severe Severe Moderate Moderate None
Canopy(%) 98 90 50 80 70 90
Canopy Type Deciduous Deciduous Deciduous Deciduous Deciduous Deciduous
Aufwuchs None None- Moderate Abundant None None
Moderate
Pedostemum None None None None None None
Tribs Present? No No No No Yes No
Substrate %
Boulder 20 0 0 0 0 0
Rubble 30 0 0 0 0 0
Gravel 30 10 35 20 0 10
Sand 20 80 60 80 70 90
Silt 0 1 10 5 1 0 1 30 0
Other 0 1 0 0 1 0 1 0 0
Habitat Score 71 1 60 1 70 1 56 1 54 56
CHEMISTRY
Temp°C 22 27 6 25 22 21.2
DO m /I 6.3 6.9 8.2 7.1 1 7.7
Cond S/cm 116 110 66 150 148 115
pH 6.7 7 7.2 6.6 6.7
LOCATION/GENERAL
Basin subbasin Neuse 02 Neuse 02 Neuse 02 Neuse 02 Neuse 02 Neuse 02
County Wake Wake Wake Wake Wake Wake
Latitude 355230 355250 355250 355250 355247 355249
Longitude 783556 783250 783250 783250 783253 783309
Collection Card 9376 6887 7232 8141 9375 9374
Sample Type Full Scale EPT EPT EPT Full Scale Full Scale
Drainage Area 3.5 9.5 9.5 9.5 9.5 I 2
approx sq mi
Shaded columns denote samples collected for the 2004 Stressor Study.
Perry Creek TMDL Page 18

ATTACHMENT A
Public Notice
A public notice was posted to the DWQ TMDL website and notice was sent to a mailing
list of interested parties.
Notice was also posted in the Raleigh NC News and Observer newspaper. The Affidavit
of Publication is provided below.

ATTACHMENT B
Public Comment
The public comment period extended from October 24, 2009 through November 27,
2009. Comments were received from four entities:
City of Raleigh
Wake County
City of Charlotte
NC Department of Transportation
These comments with NC Division of Water Quality responses are provided in the
Responsiveness Summary(below).
Meetings
In addition, the following meetings were held with the affected MS4s:
• City of Raleigh on September 22, 2009
• NC Department of Transportation on October 5, 2009
Another meeting was held with an interested party:
• Wake County on October 30, 2009
2

Perry Creek TMDL Responsiveness Summary
April 2010
One commenter suggested that other surrogate measures be used to draft a TMDL for
addressing biological integrity. The Center for Watershed Protection study does not
indicate that mitigating high IC levels enough to create a net IC level of approximately
10%will necessarily return high stream quality indicator scores.
Response: There are several citations in the Federal Regulations that support the use of
surrogate measures for TMDL Development. For example, 40 CFR§130.2-(i)states that
"TMDLs can be expressed in terms of either mass per time, toxicity, or other appropriate
measure." In addition 40 CFR§130.7(c)(1)(i) "states that TMDLs may be established
using a pollutant-by-pollutant or biomonitoring approach." We would be willing to
consider other targets, surrogate targets and non-TMDL approaches for impaired
biological integrity streams in Charlotte. The commenter did not suggest an alternative
surrogate.
One commenter suggested that local data be collected to determine conditions that result
in high stream quality indicator scores which lead to a more appropriate surrogate.
Response: The TMDL is not so prescriptive to limit local government's collection of
additional data to develop the most effective management strategy. The goal of this
TMDL is to achieve a bioclassification of Good-Fair or better, not necessarily to achieve
the surrogate target. Percent impervious cover serves as a surrogate measure of the
complex mixture of pollutants transported by stormwater. Since the impairment cannot
be attributed to a specific pollutant, impervious cover (IC) was used as a surrogate
measure of the complex array of stressors associated with stormwater that impact
aquatic life. We would be willing to consider other targets, surrogate targets and non-
TMDL approaches.
One commenter stated that using a 9% IC target is inconsistent with minimum Post-
Construction Controls Ordinance (PCCO)rules. The State's minimum PCCO regulations
require controls when IC meets 24%. Although not part of the TMDL, and if an IC
surrogate is ultimately used, we recommend that this discrepancy be addressed to avoid
the resulting burden that will be placed on regulated municipalities to make up the
difference through TMDL implementation.
Response: The PCCO Rules were not aimed at restoring impaired biological integrity
and do not address existing development. Local governments have the option of adopting
more restrictive ordinances.
One commenter stated that to address degraded habitat and scour, stream bank restoration
is a necessary precursor to begin biological restoration and will address other related
impairments such as turbidity. Therefore, we believe that stream stabilization and
restoration, not IC removal, is a more appropriate first step and a partial (and likely
significant) success toward biological recovery.
3

Response: The TMDL is not requiring IC removal nor does it propose to be the only
solution in restoring the biological community. In addition, stabilization and restoration
without mitigation of stormwater impacts would not provide a permanent solution. We
recognize that any approach at water quality improvement that requires management
changes in existing areas creates implementation challenges. That is why the TMDL
document notes the need for an iterative process that may take a long period of time for
implementation. The Division's approach in this process will be to allow entities to
develop a recovery plan that is effective and that is also reasonable. Over time we
anticipate that management alternatives in these areas will increase/improve and we
anticipate that implementing agencies will effectively adapt their management strategies
to utilize the most effective approaches. While the TMDL confers no additional authority
to local entities for implementation, we do feel that there are authorities available that
allow local entities to select and prioritize stormwater management practices today that
can begin this process. This could include identifying public lands for stormwater
controls, looking at stormwater provisions for redevelopment or utilizing innovative
approaches to reuse or otherwise reduce stormwater runoff.
One commenter stated that on page 6, the TMDL watershed area is reported to be 11
square miles (or 306,662,400 square feet). Our understanding of the TMDL is that if the
impervious cover in the watershed is reduced to 306,662,240 square feet or less, then
water quality standards will be achieved as measured by a Not Impaired, Good-Fair or
better benthic macroinvertebrate bioclassification. It is our further understanding that the
maximum allowable impervious cover in the watershed allocated to point and nonpoint
sources (WLA+LA) is equal to 27,599,616 square feet (9% of 306,662,400 s.£) Is our
understanding of the draft Perry Creek TMDL correct and are our calculations correct? If
not,please provide clarification and corrections to our calculations.
Response: The current imperious cover is 17%and the mitigation is aimed at achieving
the equivalent of 9% through stormwater management.
One commenter suggested that more specific stressors be identified.
Response: There is a list of stressors in the TMDL since the impairment cannot be
attributed to a specific pollutant, impervious cover (IQ was used as a surrogate measure
of the complex array of stressors associated with stormwater. The TMDL report does
contain site-specific information referenced from two stressor studies conducted by DWQ
in 2004.
One commenter stated that more research is needed to determine a proven, definitive
course of action that will restore the biological integrity of streams in North Carolina
prior to TMDL implementation.
Response: The implementation plan is not a required component of the TMDL. The
TMDL language and permitting approach attempt to recognize that there may be
multiple ways for entities to meet the intent of the TMDL, not just one single approach.
Through the development of your plan in your stormwater permit,you will have the
opportunity to work with the Division to target the most appropriate approach for your
jurisdictional area.
4

Two commenters stated that it is not clear from the draft report which MS4 permittees
have been assigned a WLA?
Response: The WLA portion of the TMDL applies to the Phase I NPDES stormwater
permits. EPA recommends expressing the wasteload allocation in the TMDL as either a
single number for all NPDES-regulated storm water discharges, or when information allows,
as different WLAs for different identifiable categories. In this case, information was not
available to establish separate WLA numbers.
One commenter stated that Wake County has no land use regulatory authority in the
Perry Creek watershed, the TMDL is not applicable to Wake County. It is requested that
all references to unincorporated Wake County be removed from the TMDL.
Response:A TMDL must include a load allocation for all nonpoint sources. Not all of
this TMDL watershed is covered by a NPDES permit.
Two commenter asked if future permit applications for new construction will be denied
by DWQ if a proposed project increases impervious cover in the watershed? If the
answer is No, then what requirements related to this TMDL will be a condition of permit
application approval for future construction projects in the watershed that add new
impervious cover?
Response: The DWQ Stormwater Permitting Unit will work with permiees to access the
need for any potential modifications or clarifications in the permit language.
One commenter asked if in the future,will either DWQ or EPA a 9% impervious cover
limitation in the Perry Creek watershed?
Response: The goal of the TMDL is to mitigate for the effects of stormwater runoff
through stormwater management, not documenting the current or future extent of
impervious cover. The studies done in this particular watershed clearly indicate that
stormwater runoff from impervious areas is having an adverse impact on the biological
community.
One comment stated that NCDOT-owned impervious cover in this watershed is
approximately 3.2%. Assuming the accuracy of this figure, is NCDOT currently in
compliance with the draft TMDL? At what percent impervious cover would NCDOT be
out of compliance with the draft TMDL?
Response:It is not clear what the 3.2%refers to from the commenter. All MS4 permits
include a requirement to implement an approved TMDL and strongly encourage
adjoining jurisdictions to work together in this process. We also realize that individual
entities will be interested in their specific compliance and the Division anticipates that
for each permitee adherence to their final recovery plan will establish their compliance.
One commenter stated that under the "SUMMARY"heading(pg 3) -the document
summary specifies hydromodification (impoundments), nutrient and organic loading, and
low DO as primary stressors. In order to avoid distraction from the primary focus of
stormwater(and the surrogate IC) as the stressor, I would suggest removing the nutrient
and organic loading from the summary.
Response: The text has been changed for clarification.
5

One commenter requests that the classification of impairment and application of the
TMDL be limited to the lower portion of the watershed from US 1 to the Neuse until
additional sampling establishes an accurate and objective assessment of the remainder of
the watershed.
Response:Percent impervious cover appears to be uniform across this watershed
regardless of the type of development. The DWQ study indicated strong pressures from
suburban and urban development. In implementing the TMDL and developing the Water
Quality Recovery Program through the NPDES Stormwater permit local governments t
will be able to target the areas they believe will result in meeting the narrative water
quality standard of a Good-Fair bioclassification.
One commenter stated that under the "WATERSHED DESCRIPTION"heading (pg 6) -
reference is made to the Perry Creek watershed(study area) which appears to be an 11
square mile subset of the entire 31.6 square mile watershed. Does the TMDL apply to the
entire Perry Creek watershed or just the "study area"?
Response: The TMDL applies to the entire 11 square mile watershed. The text has been
revised for clarification.
One commenter stated that under the "POLLUTANT SOURCE ASSESMENT"heading
(pg 8) - in the 5ch paragraph the document indicates low DO may be a stressor due to
nutrient enrichment and algal activity. Since there is no evidence presented to support
this hypothesis and local staff have traditionally not found low DO to be a problem in
urban streams, we would request that this assumption be removed.
Response: The text has been clarified.
One commenter stated that the document fails to discuss Load Allocation (LA) for those
portions of the watershed not subject to NPDES permits such as discharges to waters of
the state from systems not owned or operated by an NPDES permit holder(direct
discharges from private land into waters of the state)which qualify as non-point sources.
Response: This TMDL includes a Load Allocation of 9% impervious cover.
6

8/26/22, 11:30 AM North Carolina Secretary of State Search Results
• File an Annual Report/Amend an Annual Report • Upload a PDF Filing • Order a Document Online -
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an Amended a Annual Report form
Limited Liability Company
Legal Name
SpecGx LLC
Information
Sosld: 1593443
Status: Current-Active O
Date Formed: 5/8/2017
Citizenship: Foreign
State of Incorporation: DE
Annual Report Due Date: April 15th
Currentgnnual Report Status:
Registered Agent: CT Corporation System
Addresses
Reg Office Reg Mailing Mailing
160 Mine Lake Ct Ste 200 160 Mine Lake Ct Ste 200 385 Marshall Ave
Raleigh, NC 27615 Raleigh, NC 27615 Webster Groves, MO 63119
Principal Office
385 Marshall Ave
Webster Groves, MO 63119
Company Officials
All LLCs are managed by their managers pursuant to N.C.G.S. 57D-3-20.
Manager Manager Vice President
Beilinson, Marc Casey, Mark Cathi M. Ponciroli
385 Marshall Ave 385 Marshall Ave 385 Marshall Ave
Webster Groves MO 63119 Webster Groves MO 63119 Webster Groves MO 63119
https://www.sosnc.gov/online_services/search/Business_Registration_ResuIts 1/2

8/26/22, 11:31 AM North Carolina Secretary of State Search Results
Manager
Edmiston, Sherman
385 Marshall Ave
Webster Groves MO 63119
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NPDES STORMWATER PERMIT COVERAGE
RENEWAL APPLICATION
PERMIT NO. NCS000136
June 2016
Mallinckrodt LLC
8801 Capital Boulevard
Raleigh, North Carolina 27616
Mallinckrodt

Ift Mallinckrodt
Pharmaceuticals
June 2, 2016
Bradley Bennett, Manager
Stormwater Permitting Program
Division of Energy, Minerals, and Land Resources
North Carolina Department of Environmental Quality
512 N. Salisbury Street
Raleigh,NC 27604
Re: NPDES Stormwater Permit Coverage Renewal Application
Mallinckrodt LLC, 8801 Capital Boulevard, Raleigh, Wake County,NC 27616
NPDES Individual Stormwater Permit No. NCSOOOi36
Dear Mr. Bennett:
Mallinckrodt LLC (Mallinckrodt) is submitting two (2) copies of the attached NPDES
Stormwater Permit Coverage Renewal Application for the above-referenced site for your
review and approval. Mallinckrodt is currently permitted to discharge stormwater consistent
with NPDES Permit No. NCS000136, effective December 1, 2011, and expiring November
30, 2016 and we currently monitor three (3) stormwater discharge outfalls following the
requirements of the Permit.
If you have any questions or require additional information, please contact me at
919-878-2895.
Sincerely,
Mallinckrodt LLC
Tim Roberts
Environmental Manager
Attachments (2)
Srrbinitted via Federal Express Tracking# 776419549199
cc: Julie Summers- Mallinckrodt, w/o Attachments
8801 Capital Boulevard•Raleigh,NC 27616-919.878.2800 T•919.878.2823 F•www.mallinckrodt.com

Permit Coverage
AMARenewal Avolication Form NPDES Permit Number
NCDENR National Pollutant Discharge Elimination System NCS000136
Stormwater Individual Permit dl�
se provide your permit number in box in the upper right hand corner, complete the information in the space provided
w and return the completed renewal form along with the required supplemental information to the address indicated.
Owner Information * Address to which permit correspondence will be mailed
Owner/Organization Name: Mallinckrodt LLC
Owner Contact: Timothy M. Goodman
Mailing Address: 8801 Capital Boulevard
Phone Number: 919-878-2822
Fax Number: 919-878-2823
E-mail address: [e-mail] Vrr)
Facility Information 1UAI 0 201_
Facility Name: Mallinckrodt Pharmaceuticals 'D ,
Facility Physical Address: 8801 Capital Boulevard ie,r,_N OQUAt1?�,
Facility Contact: Tim Raleigh
�RM RPERNj4ING
Mailing Address: 8801 Capital Boulevard
Raleigh, NC 27616
Phone Number: 919-878-2895
Fax Number: 919-878-2823
E-mail address: [e-mail]
Permit Information
Permit Contact: Tim Roberts
Mailing Address: 8801 Capital Boulevard
Raleigh, NC 27616
ie Number: 919-878-2895
dumber: 919-878-2823
E-mail address: [e-mail]
Discharge Information
Receiving Stream: Neuse River and Unnamed Tributary to Perry Creek
Stream Class: 27-(22) and 27-25-3-(2)
Basin: Neuse River Basin
Sub-Basin: 03-04-02
Number of Outfalls: 3
Facility/Activity Changes Please describe below any changes to your facility or activities since issuance of your permit. Attached a
separate sheet if necessary.
See Section V of Attachments.
CERTIFICATION
I certify that I am familiar with the Information contained in the application and that to the best of my knowledge and belief
such information is true, complete and accurate.
Signature Date OG ILG I— 2
Tlmotby M. l�nr r Ln Site Director
F Print or type name of person signing above Title
SW Individual Permit Coverage Renewal
Please return this completed application form Stormwater Permitting Program
and requested supplemental information to: 1612 Mail Service Center
Raleigh, North Carolina 27699-1612

SUPPLEMENTAL INFORMATION REQUIRED FOR RENEWAL OF INDIVIDUAL
.� NPDES STORMWATER PERMIT
Two copies of each of the following shall accompany this submittal in order for the application
to be considered complete:
(Do not submit the site Stormwater Pollution Prevention Plan)
Initials
1. A current Site Map from the Stormwater Pollution Prevention Plan. The location of
industrial activities (including storage of materials, disposal areas, process areas and
loading and unloading areas), drainage structures, drainage areas for each outfall,
building locations and impervious surfaces should be clearly noted.
2. A summary of Analytical Monitoring results during the term of the existing permit
(if your permit required analytical sampling). Do not submit individual lab reports.
The summary can consist of a table including such items as outfall number,
parameters sampled, lab results, date sampled, and storm event data.
3. A summary of the Visual Monitoring results. Do not submit individual monitoring
reports. The summary can consist of a table including such items as outfall number,
parameters surveyed, observations, and date monitoring conducted.
4. A summary of the Best Management Practices utilized at the permitted facility.
Summary should consist of a short narrative description of each BMP's in place at
the facility. If the implementation of any BMP's is planned, please include
information on these BMP's.
J� 5. A short narrative describing any significant changes in industrial activities at the
permitted facility. Significant changes could include the addition or deletion of
work processes, changes in material handling practices, changes in material storage
practices, and/or changes in the raw materials used by the facility.
b. Certification of the development and implementation of a Stormwater Pollution
Prevention Plan for the permitted facility (Sign and return attached form).
If the final year analytical monitoring of the existing permit term has not been completed
prior to filing the renewal submittal, then the last years monitoring results should be submitted
within 30 days of receipt of the laboratory reports. (i.e. do not withhold renewal submittal
waiting on lab results)

TABLE OF ATTACHMENTS
I. SITE MAPS FROM SWPPP
II. SUMMARY OF ANALYTICAL MONITORING DATA
III. SUMMARY OF VISUAL MONITORING DATA
IV. SUMMARY OF BMP'S FROM SWPPP
V. NARRATIVE OF SIGNIFICANT CHANGES
VI. SWPPP CERTIFICATION

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WAKE FOREST, DATED 2002 1000 0 500 1000 2000
CONTOUR INTERVAL 10 FEET THIS DRAWING IS THE PROPERTY OF MALLINCKRODT LLC OR AN
IN FEET AFFILIATE ("MALLINCKRODT'} AND IS NOT TO BE REPRODUCED, COPIED OR USED
FOR MINI
EXCEPT AS SPECIFIED IN WRITING BY MALLINCKROOT.
Malfirrokrod[the'M'brand mark and Ure Mahadvadt Phalmamdczfs logo are trademarks of a Matincpiodt company,
®2013 Maldnckradt
VIDNITY Ift Mallinckrodf
FIG. 1 Pharmaceuticals
RALEIGH PHARMACEUTICAL PLANT
SITE RALEIGH PLANT BLDG. BBOI Capital Blvd. Raleigh, NC 27616
SCALE AS NOTED GATE 5 31 16 FLOOR 51 0 0 _ 2 1 0 — 0 Q(�3
DR. BY: Er�GR. CHK'0 I
PROJECT N0. DRAWING
REVISION H
DATE JENGR. DESCRIPTION
FILE # 304701

_ LOCATION AREA(SQ FT) AREA
.r - ' P"�' rir` _ •� •T- ':�'4, 7 31:{ _.. 1 399,583 9.17
i gir
2 2,084,328 47.85
3A 11,300,902 259.43
.e' _ •�.',- .'t S. "`ya%( �, r ^- ,.�r 313 7,576,640 173.94
4 1,144,582 26.28
1,949,46
� � ,'° _ k� •�• ;;- gam-' ,
# �✓
1,.. ' . . --"a;•�'a'."P,�i.'!` - ,-r WATER
A ER FEATURES
LOCATION AREA(SQFAREA(ACRE)
A 1,030,492 23.6 ft
D 13,972 0.3
E 53,876 1.2
- F 4,072 0.1
F -
,_ - O 31,4 0.80 6
' I 9,703 0.2
J 18,043 0.4
ZONE 4 K 1 0.3
L 5,026,026 0.1
M 5,026 0.1
4
jJ 70HE 3A ZONE 5
'.` ,••. '' l _ 't; _ IMPERVIOUS SURFACES
AREA AREA
LOCATION S( Q FT) (ACRE) %IMP.)
Zone 1 76,243 1.8 19.6
Zone 2 227,156 5.2 12
Zone 3A 105,974 2.4 0.9
- tY Zone3B 855,641 19.6 19.3
e Zone 4 6,516 0.2 0.8
G Zone 5 15,363 0.4 0.9
Q ._ Downstream 32,706 0.8 --
Iv W _h,�. �,, ., TOTAL 1,503,075 34.5 --
�, cj�
ZONE V
NORTHWEST
1
<St RETENTION p i
PERRY GR — __. POND
LEGEND
RETENTION DRAINAGE ZONE
k o POND
�_ �F. BOUNDARY
• ' —t..- MZY
� � E�B= - ----- -- t 0 11 OUTFALL LOCATION
E OR OPEN TOP\
POND
R s RETENTION
. � t :' _. sue , �' -4 '" M
NEUS '
5 , � E
VoG
A
TANK AREA
• r—••, R`i I - TDML TOTAL
UM
DAILY LEADIM
l {
. "h.t 6 � 's f :.y` t f� `iw L L,„ �A 1 •'1 �! - `\
t ' - TMDL FOR MERCURY
1 15/25/161 T3 1 CHANGED PROPERTY LINE
--FY`FF V
4 F
NO. DATE ENGR. DESCRIPTION
.'�., /j.�Y �_. -\�a►P.? \�I. ' ��%•-.., '. _. -_� I .-_.- )RAWING REVISIONS
: ' rya• '?' I. � j�I�M' ws . _. . .' � r- PROJECT NO.
•; • F� ! P � ,✓a�..�i -.:•� 'rr'•__` ;Y r - - _ , ��T +•.�� PSM/RMP PLAN: ECP PLAN:
Maliinckrodt
Pharmaceuticals
� . OVERALL
SITE PLAN
._1 LZ
IMAGE SOURCE: NC ONEMAP, DATED 2013 GRAPHIC SCALE FIO.2
800 0 400 800 SITE RALEIGH PLANT BLDG. FLOOR
PARCEL SOURCE:WAKE COUNTY GIS, DATED MARCH 2O12 SCALE AS NOTED DATE
DR.B'T ENGR.
TOPO SOURCE:WAKE COUNTY GIS, DATED MARCH 2O09
HYDRO SOURCE:WAKE COUNTY GIS, DATED NOV.2011 ( IN FEET ) DRAWING NO. R v.
5100210084
THIS DRAWING IS THE PROPERTY OF MALLINCKRODT LLC OR AN
AFFILIATE("MALLINCKRODT")AND IS NOT TO BE REPRODUCED,COPIED OR USED
FOR ANY PURPOSE EXCEPT AS SPECIFIED IN WRITING BY MALLINCKRODT.
M'II"k,o A 'M'bard m*aM Ihv MA ,Wt Pharmaceuicah logo era ha'Jamarks ofa MaNnckmtltwmpmy
C.MekMdv
FILE 1 304702

~-4�
wit
LIQUID H2` -
TANK
LUBRICANT STORA E
AIR PRODUCTS HYDROGEN HYDROGEN
a.
as s > r TANKS
907
' WASTE LO
RAW NA -
a � IV 3B
* ± m = 90fi �j ❑ HILL SURGE
TANK
G
�rylll U
E'4 910 TANK AMMONIUM (BIG MAC)FARM INJ.
:' - M, •"� i ,: _..LF.!-i902 - �'.
— 903 SULFATE POND
' � :(SOUTH) AMMONIUM �t.• TRAININO - 809 �� 912 - AMhAONIA (CLOSED) SULFATE- � _ -
FIRE
`.:. Y AREA .9 LBOLERIJOUSE��F ❑ °. TANKS r�. SL#d MA
20C a v MASL#2
�.• Y ""' 51 51A/QT 100 1 207 202 MASL#4. �\
_ .... WAREHOUSE
104102
(7 300 GRAPHIC SCALE�� 300
�__ v_ _, ['201 2D 2oa
ism -0�1 L_ zos
210 _
'-105 r--- I_—' -SHOT
B.Q.POND r.:'�. _
�206 � 'POND (CLOSE[)} M �,•.
`�. IN FEET
0/ FLUSH WATER POND_ Q BASIN#1 \
IMAGE SOURCE:NC ONEMAP, DATED 2013
EMERGENCY, (CLOSED)
\
.t. PM ENT BLDG; �? SP1LL_.... WAKE COUNTY GI
BASIN#2
�xI �
' RESPONSE
PARCEL SOURCE WA S
QC LAB I HAZARDOUS
TEPAD % SHED _ (CLOSED)
DATED MARCH 2O12
rvoR7 wnsTEWATEa B_a BUILDING SOURCE:WAKE COUNTY GIS,
O g H EMERGENCY TREATMENT PLANT B G DATED 201
1 EQUIPMENT BLDG r G B-a
PARKING LOT SOURCE:WAKE COUNTY
GIS, DATED 2010
1 15/26/161 T.R.1 CHANGED PROPERTY LINE
z CAPITAL BLVD (US-1)
• .,- NO. DATE DESCRIPTION
j+ ENGR
`•� J DRAWING REwslons
PROJECT NO.
PSM/RMP PLAN: ECP PLAN:
Mallinckrod
1
�-, I
Pharmaceuticals
"� INDUSTRIAL AREA
_._
SITE PLAN
6. FIG.
SITE RALEIGH PLANT BLDG. FLOOR
SCALE i DATE
DR.BY: ENGR.
CHECKED
DRAWING NO. 5100-210-085 R,
THIS DRAWING IS THE PROPERTY OF MALLINCKRODT LLC OR AN
AFFlLIATE("MALLINCKRODT')AND IS NOT TO BE REPRODUCED,COPIED OR USED
FOR ANY PURPOSE EXCEPT AS SPECIFIED IN WRITING BY MALLINCKRODT.
MaNladvodl,the•M•bond mxkard fw MsXxkf IXPMmw3dI bN a,e tndam Uda MaN}mdtro 'Y
02013 MaWKkmdl
FILE 1 304703

LEGEND
OUTDOOR PROCESS AREA
WHERE WATER IS ISOLATED
&CAPTURED FOR ONSITE
TREATMENT
DOWNSPOUT THAT DRAINS
r' TO GROUND
DOWNSPOUT THAT DRAINS
TO PROCESS SEWER
UNDERGROUND STORM AND
OPEN DITCH FEATURES
INDUSTRIAL AREAS
�» #
- 001 OUTFACE LOCATION
ATE VANE
OPEN GATE VALVE
.
1. CAUSTIC UNLOADING AREA
2. BUILDING 103 ROOF AND APAP
COURTYARD
3. BUILDING 101 ROOF AND
R 4
^ �' ^�r nn AkF OUTDOOR PROCESS EQUIPMENT
<,
- s, �, - r JN 313 4. PROCESS SEWER
n^ -} !� , kOTT\` STORAGE TANKS R
»»>
^ <<<< AP ROADWAY IS ISOLATED BY
LOCKED...-_ n
._
> >
AP
AP
GRADING AND RAISED"DAM"
' \ LOCKED GATE VALVE )
'�'`n� •' � . • � , ~_ 6. HILL BULK TANK FARM
7. PAP ROADWAY(IS ISOLATED BY
«««t211< c« <—— V � RAISED"DAM")
GRADING AND RA M"
- _}' c+•�.., tz �;:'. 8. 201 DUMPSTER
9. BUILDING 201 ROOF AND
OUTDOOR PROCESS EQUIPMENT
v � J
»»» 10. BUILDING 205 ROOF AND
OUTDOOR PROCESS EQUIPMENT
ov
11. WWTP BULK TANKS AND TRUCK
v/ [` CLOSED GATE VALVE UNLOADING STATION
4 •. —�«««« e`
OPEN GATE VALVE O; 12 BULK MASL TANKS
• r
_
IMAGE SOURCE: NC ONEMAP, DATED 2013
PARCEL SOURCE:WAKE COUNTY GIS,
»»»»» , , DATED MARCH 2012
LOCKED GATE VALVE ,7>'» ''��, BUILDING SOURCE:WAKE COUNTY GIS,
f4;`a u »»»»»»»»7� DATED 2010
PARKING LOT SOURCE:WAKE COUNTY
+;w •_s .. +d v I` GIS, DATED 2010
_J
- Y
RTY LINE
"-»»»»»»_»»»>�»»»»»»»»»»»»»»»»777>>>»»»> 1 5/26/161 TR I CHANGED =
CAPITAL BLVD
--.- N0. DATE ENGR. DESCRIPTION
�`I ''���) �— - DRAWING REVISIONS
PROJECT N0.
# � "t �.. •_• .- -_ _ \\\\ PSIA/RMP PLAN: ECP FLAN:-
} "•� W ..--� � � •��
•— -
f
Patl'nc krod tharmaceuticals It
' ,•� f`
MFG MASL & WWTP AREAS
THAT DRAIN DIRECTLY TO PROCESS SEWER
... -..... .. ...:..-.- -........ _..._. _.. _.. ......:. .._.,._.-.. e��b'_i �a ...�..®._.:�r. .A.: - �•.•.::. SIE RALEIGH PLANT BLDG. FLOOR
SCALE 1 DATE
DP,.BY: 'NON.
GRAPHIC SCALE CHECKED
300 0 150 300
DRAWING NO. 5100-210 086
� � �
THIS DRAWING IS THE PROPERTY OF MALUNCKRODT LLC OR AN
AFFILIATE("MALLINCKRODT")AND IS NOT TO BE REPRODUCED,COPIED DR USED
FOR ANY PURPOSE EXCEPT AS SPECIFIED IN WRITING BY( MALUNCKRODT.IN FEET MMlukrotll,tn."M a�IA—k��ftb flld mPhi-16 1ih�llvaae��k�aa aau�wal y.
©2D13M0,k,mi
FILE;{ 304704

LEGENDAMATERIAL STORAGE AREA
r � -
_ OPEN SLOPED DITCH&
DIRECTION OF STORM FLOW
RED INDICATES LOCATION SUBJECT
TO SEMI-ANNUAL INSPECTION.
' J
BLACK INDICATES LOCATION WITH
/ NO EXPOSURE.
S-1 BUILDING 51 WAREHOUSE
S-2 BUILDING 5 A WAREHOUSE
S-3 NO.2 FUEL OIL STORAGE TANK
S-5 K083 ANILINE TAR TANKAT BOILER HOUSE
1 } + LDING
S-7 USED TEQUIPMENT ENANCE ISTORAGE AREA
4 +� S-8 HYDROGEN TANKS
S-9 EMPTY DRUM STORAGE AREA
t_ S-10 TANK FARM ON HILL
S-12 AMMONIATANKS
I!►:- `. - S-13 BUILDING100
y '. \'` �»»»»»>»> S-15 ACETIC ACID TANK FARM NORTH OF BUILDING 101
516 PAP TOTE STORAGE
�'• ~` •- -`+ ', . BUILDING 101
S-17 STORAGE PAD SOUTH OF BUILDING 201
r�
S-18 BUILDING 200 WAREHOUSE
S'� L�S _ -- E PAD
H J S-19 K083 ANILINE TAR STORAGE TANKS
5-20 HAZARDOUS WASTES O
50T� S 22 BUILDING 10 WAREHOUS�G�+nI� "Pt 17� rr� rh .. ?: > S-23 TANK FARM AT WWTP
»»» n kFeUR S 24 WASHING AREPJCATALYST STORAGE AREA
y `
r .! _ S-25 MASL ABOVEGROUND STORAGE TANKS
^ _ �� r k�� S-26 BUILDING 105
r
N 3B
S-27 FUEL STORAGE AREA
n 903
"--.• .. 2 I S-5js„ << .'! �hn \\ - - 5-30 ANALINE STORAGE TANK
T
4 p ,4 �:'a> 0'4v'-1 v A'> ,' �'' ��>j - S-31 DI H2O BUILDING
v S-35 PROPANE ABOVEGROUND STORAGE TANK
^ 912 -41-i,� v 5�7�� >�>� )E \ S-38 PROPANE ABOVE GROUND STORAGE TANK
TREATMENT CHEMICALS
S 3 -3 F
• ' >t r
= S 9
} 7-�7+'A77 0 BUILDING
S «< 1 0 S-{k »»>?� ti > 2 TRANSFORMER SUBSTATION#1 AT BUILDING#2
�w• .--- «Z r S-43 TRANSFORMER SUBSTATION#2 EAST OF BUILDING 903
01
51 S TD 100 — ❑' �.., ._.� »»> .4»»»»»»»»»»»>
.:•. - •�I-- ` »> >�� � ' -- S-46 TRANNSFORMER SUBSTATION#SB EASTF BUILDSFORMER SUBSTATION#4 WEST OF ING NGNG 1200
>�j, -� \�--T's --- i S-47 P-E TRANSFORMER SUBSTATION#1 AT MASL
S- 4 -.✓� S-48 P-E TRANSFORMER SUBSTATION#2 AT BUILDING 10
»»►}— ION#3 AT WWTP
n »
yi >�� S-09 P-E TRANSFORMER SUBSTATION
ariali n S50 BUILDING 907 OIL STORAGE
v / 'r - - P - - AREA
Z1�Q� > �`! j S-51 CONTRACTOR TRAILER
' S-2
V/ _ $-16 S"1 7 � i20 - SQ. , _ ., - - S-52 ETHOMEEN BUILDING
a
y
ti•_ � < „ _ BUILDING 901
REWORK&TEMP-
X* S-5 TANK FARM NORTH OF BUILDING 1D1O(FUTURE)
S-54
<a
.., ,r•. �- - -- �. 5-56 SULFURIC ACID TANK FARM
_ - JY;, ' a, a _� ti 2 _ C .. S-57 WWTP BACK-UP GENERATOR
'(
` 5 58 ANTI-FOAM DIKE AREA OF WWTP
a�� �_ t� � ,�-, s �; �"t� �, '" a; - o. - ?�� n�•`'� '�'s - S-59 BOILER 7-WEST OF BUILDING 901
S-60 PAP PLANT COMPRESSOR
ap > ` .�»»»> $-49 r IMAGE SOURCE: NC ONEMAP, DATED 2013
PARCEL SOURCE:WAKE COUNTY GIS,
S-48 ��S 5
• � _, ,, �':�'L:'�+.��s � DATED MARCH 2O12
BUILDING SOURCE:WAKE COUNTY GIS,
c 10 2-22 - DATED 2010
' �• PARKING LOT SOURCE:WAKE COUNTY
� �.•:w: �� _t'�"`'�",�:�, }'%-.'> GIS, DATED 2010
_.-
' `�»»»»»»_»»»>�»»»»y»»»»»»»»»jjj7i?), > 1 5 27 16 T.R. CHANGED PROPERTY LINES
t - CAPITAL BLVD (US-1) r%T`y` MD. DATE ENGR. DESCRIPTION
_ }
-� „•�� � f' DRAWING AEV510NG
r } 3 sue.' PROJECT N0.
PSM/RMP oU ECP PLAN:
Mallinckroct
Pharmaceuticals
• t .�,yl• -
i► a ,.; Y •$s MATERIAL
RACTICG SAG
-- FIG 5
-. - SIZE PUN! BLDG. FLOOR
SCALE DATE
GRAPHIC SCALE OR BY: ENGR.
CHECKED 300 0 150 300 DRAwD+G NO. R
5100-210-087 /1\
THIS DRAWING IS THE PROPERTY OF MAWNCKRODT LLC OR AN
( IN FEET ) AFFILIATE('MAWNCKRODT)AND IS NOT TO BE REPRODUCED.COPIED OR USED
FOR ANY PURPOSE EXCEPT AS SPECIFIED IN WRTONG BY MAWNCKRODT.
MMNema.lr va c.w mn.m u.MintivaW Pnv.nauDak ew..e.a.wts a,Mm 4io0I onwM
OA77MMYrAmO
FILE 1 304705

/ LEGEND
I�
'�_`: ❑ LOADING/UNLOADING AREA
• ' y-' OPEN SLOPED DITCH &
DIRECTION OF STORM FLOW
f
;• �\ /' RED INDICATES LOCATION SUBJECT
TO SEMI-ANNUAL INSPECTION.
Y `e ~'�► BLACK INDICATES LOCATION WITH
r. NO EXPOSURE.
L-1 BUILDING 51 WAREHOUSE
LOADING/UNLOADING
'
L-2 BUILDING 51A WAREHOUSE
y >„»>»>,,,,����� LOADING/UNLOADING 7
L 3 ACETIC I STATIONADING
y ac ,Q^t NORTH OFBUILODING01
s
- LOADING/UNLOADING
---—
1t t ra
- •;, _, Q •-� -': � �� _.7n r�r L-6 TANK FARM AT WWTP
a -+,�, a, •.#r soy � � � LOADING/UNLOADING
t >»> n^ ��' nrr rrr p L-7 BUILDING 10 WAREHOUSE
• n f,' �'� r N E3B �.. __ LOADING/UNLOADING
'AIVII
y a+ ^
•' .- ^
-: ^ r L-8 LOADING/UNLOADING AREA BEHIND
s,o r
A i02 „ ^ �,b V `5<<. t '(�+.•` ? ��'� � •�
- ' —I" , > r BUILDING 101
sos Ia3 v ' ~`\ L-9 NO.2 FUEL OIL UNLOADING AREA
- * I _1 912 I, `y v ?�j'' 'I \ L-10 LOADING/UNLOADING DOCK AT
t ❑ '1 -17 BUILDING 100
v Lr ; > ❑ ?PP ` ' lbw
«<t«c<ccrt<zc««<<—— __. - g . ❑L $ R ,'>,� L-11 MASL LOADING/UNLOADING
krw� .�: « 8.. - y 20 Q L-12 VEHICLE FUEL LOADING/UNLOADING
207 d�—. »»»» `\
100 a" ,�~ " /, n^
51 51A/QT »»>»
L-13 ANILINE TRUCK LOADING
/ L 1 »»»»»»»»»»>»»»»
_ - - _ »'� >—�, �- -- L-14 WEST SIDE PAP
1 ,10 •$i n �� » ��-—_ LOADING/UNLOADING
r" ❑L-1 ❑ L-1 v `� 2 , ''�� - ``-- ` L-17 ANHYDROUS AMMONIA UNLOADING
w may,
i
vv
1 .;��� G AREA
L 18 SULFURIC ACID UNLOADING
<"<`�"�<E = _ CJ►t L-20 USED OIL LOADING AOREAN
c. <'. .. OT ;►, P R: l °` �` L-21 WWTP GENERATOR UNLOADING
- z-
-��
2 , AREA
ij
IMAGE
SOURCE:z»>»»»>, ��` PARCEL E SOURC WAKE COUNTY GIS,
a3 , DATED MARCH 2O12
" -
> rr ' BUILDING SOURCE:WAKE COUNTY GIS,
T DATED 2010
10 PARKING LOT SOURCE:WAKE COUNTY
• v
GIS, DATED 2010
-1-»»»»»»—>>»»»»»»»»»»»»»»»»»»»>>,7 >>»»»»— 7 5'27 16 T.R. CHANGED PROPERTY LINE
7>
• - ..- CA ,A �� D U — 1 �� N0. DATE ENCR. DESCR'.PTIDN
PIT V S /
.:. - Imo, DRAWING REVISIONS
Y .y
t nc� krodt
- Malli,v Pharmaceuticals
LOADING/UNLOADING
ACTIVITIES
FIG 6
- - -- - --- SITE RALEIGH PIANr BLDG. FLOOR
SCALE DATE
GRAPHIC SCALE CH BY: NGR.
CHECKED
300 D ,So 300 DRAWING NO
5100-210088
THIS DRAWING IS THE PROPERTY OF MALUNCKRODT LLC OR AN
AFFILIATE(-WAWNCKRODT')AND IS NOT TO BE REPRODUCED,COPIED OR USED
( IN FEET ) FOR ANY PURPOSE EXCEPT AS SPECIFIED IN WRITING BY NLALLINCKRODT.
MoW44v'L M•M•daa maxaq er M I—ft Pxamxw bp-�—a:Idt% l r
02013A101d O!
FILE y 304706

7 r• LEGEND
• PROCESS AREAS
r OPEN SLOPED DITCH&
DIRECTION OF STORM FLOW
RED INDICATES LOCATION SUBJECT
TO SEMI-ANNUAL INSPECTION.
4: BLACK INDICATES LOCATION WITH
1; NO EXPOSURE.
Ira<_• -
air
P-1 FIRE TRAINING AREA
P-2 WASH PIT AT MAINTENANCE BUILDING
�:- •� :f : P
P-4 WASTE WATER TREATMENT PLANT
w - P-5 SCRUBBER SYSTEM
• �
-j,co If >,
n > sT
73
nn
1A __7-
~ ^
y 910
-i,
02903 1��>
I
►" h
12 v 77�
LL'!PA 1 "_ , ,>z? \ IMAGE SOURCE: NC ONEMAP, DATED 2013
WAKE COUNTY GI
»»>>>?:.:• - PARCEL SOURCE WA ,S
r y
DATED MARCH 2O12
-- - _ - w. n _ BUILDING SOURCE:WAKE COUNTY GIS,
_. too �a f »t • »»»»»»»»»»>»»» DATED 2010
� -' „ + f � - �-.-;, - - - — .•.-;�'��. - - � .� PARKING LOT SOURCE:WAKE COUNTY
k..
.t 6
t._.-. •.ram f is i..af. V 10 °dd"" ..i-. a, J �, - _
o - t.. 2 ' :f `', , GIS, DATED 2010
««< "'� fa `..r 21 205'
II
t o5
s«««——c««< a
I
2 � EDi
i' _ . GRAPHIC SCALE
- y
_ �. ?»»»»» _... 300 0 150 300
>` .v . . . .
�..
-
• •"" LIN
41
IN FEET
L M.�..
Is
rr-
v a v 10
tt V 1 5 27 16 T.R. CHANGED PROPERTY LINE
vr
y ND. 0.47E ENGR. DRAWING REVISIONS
' DESCRIPTION
'` t •"Y•j-••�• 18AK a. _ ... »»»»»»_�»»»»»»»»»»»»»»»»»»»»>�� PROJECT NO.
CAPITAL BLVD (US-1) r— j PSN/PoAP PUN: ECP PAN:
Mallinckrodt
LI ' Pharmaceuticals
OUTDOOR
F � ,_ . 'R• r 1 _3 '_ *-i PROCESS AREA
FIG.7
't } L• ..I �! - 1 ,) Y _ .:,� :1!� y SITE RALEIGH PUNT BLDG. FLOOR
o t '.e yDOTE
Y —t
- - . L.. _ _- .... -.... ._.:. _.___. •_.. _..-_ .:'$ CHECKED
DRAWING NO. 5100-210-089
THIS DRAWING IS THE PROPERTY OF MALUNCKRODT TC OR AN
AFFILIATE('MALUNCKRODT�AND IS NOT TO RE REPRODUCED,COPIED OR USED
FOR ANY PURPOSE EXCEPT AS SPECIFIED IN W'RDING BY MAWNCKROOT.
MiirxtmtlL u,.•M•Inrtl mw.rm n»MfMdrodl I'bmuceu4als k+m><•Iaa«w�a.wWMNmlwwm
B T113 Ma�ntluotll
FILE/ 304707

LEGEND
DUST/PARTICLE GENERATING
'� •
f
�' `'a "• CONTROL AREA
411
\- OPEN SLOPED DITCH&
w -
DIRECTION OF STORM FLOW
j �` -
Z� - RED INDICATES LOCATION SUBJECT
/ •' � ,•' � ,' v - TO SEMI-ANNUAL INSPECTION.
BLACK INDICATES LOCATION WITH
\� NO EXPOSURE.
2.
D-1 PAP BAGFILTERS FOR VACUUM
DRYERS&PRODUCT BIN PACKAGING
t.; _ D-2 APAP BAGFILTERS ON DROP
.. HOPPERS,SIZING OPERATING
,7»"'»»»>,, EQUIPMENT,AND MULTILEVEL CLEAN
ROOM OPERATIONS
_
A > D-3 APAP DRYING TOW
ER COURTYARD
� C
> > ►i���
. A
An BOILER HOUSE
r�
-7 err nn
907 n rr fr TO�
y^ F
+ Y
-
o10 .,, , - 1 ' '"�• << � ;' �� � IMAGE SOURCE: NC ONEMAP, DATED 2013
02 +� n t'a'ry 'P` < �''>' ':'n .r - PARCEL SOURCE:WAKE COUNTY GIS,
sos V ; �_>,»> DATED MARCH 2012
s SOURCE:WAKE COUNTY ,
r ,�
CE
1 T
-} b _-»»>>�?7:.' - DATED 2010 0
--\.} II Y S
��� `. PARKING LOT SOURCE:WAKE COUNTY
r n
�20 - n GI DATED 2010
»»»»»>> 7Fill
n ''»»»►�---... ._ _ \ -
_. - , a.,1:err •.'S� t •i V sa e �jj . -'Z t n: 0 g 20
y
0 1
tC
' .r s .v 21 - 'J.Y
.�?� 1: �"�' .fit` - `-•'cE«— --�,- c� \
ems-- ;` ,� rt«�',r�' < a a �-r••— �� v ��� T� y�,
'� C -- __- Q �• GRAPHIC SCALE
.• »»»»» -�.- 300 0 150 300
a k tt
'. • 1 F 1'[tfa'. , '+-3�•„�,
4
..1�. .. r l ,: t „ > - • c ` :»»s»»»»>i�7� t '� r. IN FEET
>h V 1015/27/161 T.R.1 CHANGED PROPERTY LINE
.•+• -• _. - - »»»»»»_ »»»»»»»»»»»»»»»»77'>>' PROJECT N0. ISIONS RIPT>,,,• ENGR. ION
»»> DRAWING REY
CAPITAL BLVD ,�"� """' ' M RMP PUN: ECP PLAN,
( - Mallinckrodt
_ � � ' ,�-1 = ., - _,w. r- .S � •• _ -. _ _ Pharmaceuticals
DUST/PARTICLE GEN PATI G
FIG.8
-, {.t'• SITE RALEIGH PLANT SLOG. FLOOR
z t•
�• - -- scuE
DR.BY:
��a[ F' �♦ ra�I j CHECKED
• � j� �;'S ENGR.
0A _ .._.. _ !- _ �•?f•. u._ i!_ ..tat.. i
. •� : E1 DRAWING NO. 5100-210-090
THIS DRAWING IS THE PROPERTY OF MALUNCKRODT LLC OR AN
AFFILIATE(•MALLINCKRODT�AND IS NOT TO BE REPRODUCED,COPIED OR USED
FOR ANY PURPOSE EXCEPT AS SPECIFIED IN WRIPNG BY MALLINCKRODT.
OX13 md,lha lT dad nrrk W tla MaEckmtll PNamayutlras h9a an hahmaM1s da Ma�xJvodwnpant
DX13 A1airk-!
FILE 1 304708

LEGEND
O WASTE HANDLING AREAS
OPEN SLOPED DITCH&
»»>
DIRECTION OF STORM FLOW
/ k , RED INDICATES LOCATION SUBJECT
,Ty / TO SEMI-ANNUAL INSPECTION.
BLACK INDICATES LOCATION WITH
f j
NO EXPOSURE.
W 2 TRASH COMPACTOR AND
DUMPSTER WEST OF BUILDING 101
W-3 DUMPSTER BUILDING 20N VICINITY OF
BUILDING
F ....,N -4.. (:•+�-Y A`{tom{, -
ZY�,,,,,���, ,* W-4 DUMPSTERS IN VICINITY OF
BUILDING 10
' 3" r W-7 CARDBOARD RECYCLING CONTAINER
"' �' ', €, ' ; _ _ ' �•x - W-9 DUMPSTER NORTH OF BUILDING 205
�; t Sw• *,i� f.r"r` ": - >?>>»»>,,,»»»> W-10 RECYCLING BINS NORTHWEST OF
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Summary of Analytical Stormwater Monitoring Results
Mallinckrodt LLC
Raleigh Pharmaceutical Plant
March 2012 - Present
Outfall 001
Parameter Units
Total -Chemical Ammonium
Suspended Oxygen Total Nitrate- Ammonia Sulfate-
Total Rainfall Solids pH Conductivity Demand Nitrogen Nitrite Nitrogen Sulfate Calculated
(inches) (m !L) (S.U.) (US/cm) (mglL) (mg/L) (mg/L) (mglL) (mg/L) (m IL)
Benchmark N/A 100 6- 9 N/A 120 30 10 7.2 500 19
Date
519/12 0.45 2.8 7.67 0 16 1.1 0.32 0.14 <5.0 <0.1
9/18/12 3.66 7.1 7.0 28 38 1.0 0.14 <0.10 <5.0 <0.1
4/19/13 0.57 4.8 6.12 180 35 1.8 0.59 0.52 <5.0 <0.1
11/1113 1.23 3.5 6.1 24 17 1.3 0.31 0.27 <5.0 <0.1
4125/14 0.47 80 6.3 57 90 2.6 0.68 0.62 <5.0 <0.1
9/24/14 0.57 37 8.7 31 21 0.6 0.05 <0.25 <5.0 <0.1
5/21/15 0.24 26 6.4 77 35 3.1 1.1 0.58 <5.0 <5.0
10/27/15 0.11 53.5 7.2 101 61.5 1.97 1.03 0.334 5.66 0.58
314116 0.11 35.8 4.0 107 19.1 1.4 0.826 0.141 5.57 0.67
Notes:
Benchmark Exceedances noted in Bold font.

Summary of Analytical Stormwater Monitoring Results
Mallinckrodt LLC
Raleigh Pharmaceutical Plant
March 2012 - Present
Outfall 002
Parameter(Units
Total Chemical Ammonium
Suspended Oxygen Total Nitrate- Ammonia Sulfate-
Total Rainfall Solids pH Conductivity Demand Nitrogen Nitrite Nitrogen :Sulfate Calculated
inches (mg/L) (S.U.) (uSlcm) (mglL) (mg/L) (m IL) (m 1L) lL (m 1L)
Benchmark N/A 100 6-9 N/A 120 30 10 T2 500 19
Date
519112 0.45 15 6.85 0.01 5 1.2 0.35 0.41 <5.0 <0.1
9/18/12 3.66 54 6.8 30 23 1.1 0.32 0.4 <5.0 <0.1
4/19/13 0.57 64 6.14 220 370 18 0.69 2.1 7.8 9.91
1111113 1.23 85 6.0 61 56 4.1 0.9 1.1 6.8 5.19
4/25114 0.47 7.7 6.7 48 100 3.3 1.5 0.42 <5.0 <0.1
9/24/14 0.57 29 7.1 99 26 1.3 2.3 0.42 5 1.98
5/21/15 0.24 46 6.5 198 53 5.8 1.7 2 13 9.43
10/27/15 0.11 15.1 6.6 191 26.6 3.99 1.86 1.36 22.9 6.42
314116 0.11 12.0 4.0 54 17.0 1.12 0.657 0.120 5.86 0.57
Notes:
Benchmark Exceedances noted in Bold font.

Summary of Analytical Stormwater Monitoring Results
Mallinckrodt LLC
Raleigh Pharmaceutical Plant
March 2012 - Present
Outfall 003B
Parameter Units
Total Chemical Ammonium
Suspended Oxygen Total Nitrate- Ammonia Sulfate-
Total Rainfall Solids pH Conductivity Demand Nitrogen Nitrite Nitrogen Sulfate Calculated
inches (mgIL) (S.U.) (uSlcm) (mg/L) m IL) m IL) (m IL) (m 1L) (m 1L)
Benchmark N/A 100 6- 9 NIA 120 30 10 7.2 500 19
Date
519112 0.45 10 7.78 0.39 56 1.9 <0.10 0.12 38 0.566
9I18I12 3.66 5.2 7.6 304 59 1.5 <0.10 0.14 28 0.66038
4/19/13 0.57 2.6 8.3 503 46 1.0 <0.10 0.54 72 2.55
1111/13 1.23 13 6.82 377 48 2.5 0.16 0.6 69 2.83
4I25114 0.47 4.1 8.6 346 25 1.6 0.3 <0.25 74 <0.1
9/24/14 0.57 9.3 6.9 330 40 1.4 <0.10 <0.25 29 <0.1
5/21/15 0.24 29 7.9 448 30 2.4 <0.10 <0.25 64 <2.5
10/27/15 0.11 4.4 6.8 1175 29.2 6.3 <0.10 5.09 469 24.01
314116 0.11 3.20 6A 317 30.1 2.82 1.90 0.097 115 0.46
Notes:
Benchmark Exceedances noted in Bold font.

h
Summary of Visual Stormwater Monitoring Results
Mallinckrodt LLC
Raleigh Pharmaceutical Plant
March 2012 - Present
Outfall 001
Other Obvious
Floating Suspended Indications of
Characteristic Color Odor Clarity Solids Solids Foam Oil Sheen Pollution
Date
519/12 Clear None 1-Clear 1-None 2-Slight No No None
Very Light
9/18/12 Brown None 1-Clear 1-None 2-Slight No No None
4119/13 Clear None 1-Clear 1-None 1-None No No None
2-Slight
(Grass/
1111/13 Light Brown None 1-Clear Leaves) 1-None No No None
2-Slightly
4/25/14 Light Brown None Turbid 1-None 1-None No No None
2-Slightly
9/24/14 Light Clear Tan None Turbid 1-None 2-Slight No No None
Very Light
5/21/15 Brown-Gray None 2 2 1-None No No None
10/27/15 Light Tan None 2 2 1-None No No None
Light Brown- 2-Slightly 2-Slight
3/4/16 Mostly Clear None Turbid (Leaves) 2-Slight (Soil) No No None

Summary of Visual Stormwater Monitoring Results
Mallinckrodt LLC
Raleigh Pharmaceutical Plant
March 2012 - Present
Outfall 002
Other Obvious
Floating Suspended Indications of
Characteristic Color Odor Clarity I Solids Solids Foam Oil Sheen Pollution
Date
2-Slightly
519112 Light Tan None Turbid 1-None 2-Slight No No None
9/18/12 Grayish Brown None 4-Cloud 2-Slight 3-Some No No None
2-Slightly 2-Slight
4/19/13 Light Brown None Turbid (Pollen) 2-Slight No No None
2-Slightly 3-Some
1111/13 Light Brown None Turbid (Organics) 1-None No No None
Very Light 2-Slightly
4/25/14 Brown None Turbid 2-Slight 1-None No No None
Clear Medium 3-Some
9/24114 Tan-Gray Unknown' 3-Turbid (Grass) 3-Some Yes2 No None
Very Light
Brown to 2-Slightly
5121/15 Mediun Brown None Turbid 3-Some 2-Slight No No None
Meduiurn 3-Some
10/27/15 Brown None 3-Turbid (Grass) 2-Slight No No None
Light Brown- 2-Slightly 2-Slight
314116 Mostly Clear None Turbid (Leaves) 2-Slight Soil No No None
Footnotes:
1- Could not smell sample due to background odors at the site.
2 - Not much foam but some due to high flow through headwall valve in ditch.

Summary of Visual Stormwater Monitoring Results
Mallinckrodt LLC
Raleigh Pharmaceutical Plant
March 2012 -Present
Outfall 003B
Other Obvious
Floating Suspended Oil Indications of
Characteristic Color Odor Clarity Solids Solids Foam Sheen Pollution
Date
Light Brown,
5/10/12 Tonic Color None 1-Clear 1-None 1-None Yes' No None
9/18/12 Light Brown None 3-Turbid 3-Some 2-Light No No None
Light Brown/ 2-Slightly
4/22/13 Biege None Turbid 1-None 1-None No No None
2-Slightly
1114113 Light Tan None Turbid 2-Slight 2-Light No No None
Dark, Clear
4/28/14 Brown None 1-Clear 3-Some 2-Light No No None
Clear Dark 2-S[ightly
9124/14 Tan None Turbid 3-Some 2-Li ht No No None
2-Slightly 4-Mostly
5/21115 Light Brown None Turbid Covered 3-Some No No None
10/27/15 Light Tan None 3-Turbid 2-Slight 2-Light No No None
Light Brown, 1-Mostly
314I16 Mostly Clear None Clear 1-None 1-None No No None
Footnotes:
1 - Foam caused by high flow rate/agitation; observations made during pumping within 30 minutes of starting pump.

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an""near
the Structural BMP.
Location: South of the building 51 R warehouse in Drainage
Zones 1 and 2
Materials: Granular APAP(in cardboard drums),APAP powder
(in cardboard drums and boxes),dust control material,
Building 51 Warehouse ice melt,lime,cleaning solution,paint,paint thinner,
(S-1)* self-shrinking bottle closures,cardboard packaging,
glass jars,and wooden pallets.
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: North of the building 51 warehouse and south of
building 100 in Drainage Zone 2
Building 5 1 A Warehouse Materials: This storage area APAP which is stored in cardboard
drums and supersacks.
(S-2)* Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: Southwest of building 901(boiler house)in Drainage
Zone 3B
Materials: #2 fuel oil(50,000 gallon tank)
Structural BMPs*: This aboveground storage tank is located within a
concrete secondary containment dike(80 x 60 x 5')that
can contain the contents of the tank plus accumulated
No.2 Fuel Oil Storage Tank rainwater from a 25-year 24 hour storm event.
(S-3) Procedural BMPs: Stormwater that collects in the bermed area is inspected
by the Mallinckrodt Utilities Department_ If the
stormwater is found to be clean,it is pumped out from
the sump located in the comer of the dike to the
stormwater ditch located north of the dike. A lock has
been placed on the sump pumpin this area.
Location: Northwest of building 901 in Drainage Zone 313
Materials: K083 aniline tar
Structural BMPs*: This aboveground storage tank is built with secondary
containment in the form of a concrete dike equipped
with a sump.The containment structure(34.5`x 14.5'x
3')will hold the 10,000-gallon capacity of the tank and
approximately 3.5"of accumulation of rainfall. This
tank is covered by a canopy which diverts rainwater
K083 Aniline Tar Feed Tank at Boiler House from accumulating in the containment area.
(S-5) Procedural BMPs: The tank area is inspected daily and the concrete dike
and sump in this storage area are inspected after each
shift for stormwater accumulation. Stormwater
accumulation in the sump or diked area is manually
pumped out to the hazardous wastewater tanker. Filling
the tank is limited to 8,400 gallons or less to allow for
the containment of the contents of the tank plus allow
for freeboard(see Table 1,S-19,Table 2,and Table 5,
W-17).
Page 1 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"•"near
the Structural BMP.
Location: West of building 101 in Drainage Zone 3B
Materials: The following materials are stored on the east side of
the building:compressed gas cylinders;surplus motors
and metal parts;wooden pallets;piping;and the piping
rack storage within a metal fence. The following
materials are stored on the north side of the building:
miscellaneous equipment and parts from the production
Maintenance Building(Building 903) lines;APAP hoppers;and empty synthetic lubricant
(S-6)* drums.The following materials are stored on the west
side of the building;a parts washing system;wooden
boxes;and miscellaneous equipment and parts from the
production lines. The following materials are stored on
the south side of the building:miscellaneous equipment
and parts from the production lines;cardboard boxes;
and scrap metal.
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: Northwest of Building 903,north of Building 903,and
west of Building 201 near power transmission line
Used Equipment Storage Areas (south of Hill Tank Farm)in Drainage Zone 3B
(S-7) Materials: New and used surplus equipment
Structural BMPs: None related to stormwater
Procedural BMPs: All equipment,parts and scrap material must not
contain,or must be cleaned to remove,significant
material residues,including draining of oils or hydraulic
fluids,prior to being stored in this area. Insulation must
be removed prior to being stored in this area.
Location: Northwest of building 903 in Drainage Zone 3B
Materials: Four hydrogen tanks:two containing gaseous hydrogen
and two containing liquid hydrogen
Hydrogen Fram Structural BMPs: None related to stormwater
(S-g)* Procedural BMPs: None related to stormwater,as this area is not a
stormwater concern due to the fact that at normal vapor
pressure hydrogen is in the gas phase.
Location: North of building 903 in Drainage Zone 3B
Materials: Empty totes and empty drums which once contained
raw materials
Structural BMPs: None relating to stormwater
Procedural BMPs: Returnable totes are not rinsed prior to returning to the
vendor but valves are shut prior to placing in the storage
area. Most empty used drums are rinsed and/or drained
and crushed prior to placing in dumpsters for off-site
Empty Container Storage Area recycled or disposal and generally are not stored or
(S-9) staged in this area. However,prior to being placed in
this storage area,non-retumable and general returnable
drums must be thoroughly rinsed prior to being
returned. Returnable totes in good condition including
hydrogen peroxide,ethomeen,and aqua ammonia are
not rinsed but are stored here and returned to the vendor
for reuse. There is also an Empty Container Standard
Operating Procedure that personnel follow for the
handling of empty containers.
Page 2 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"'"near
the Structural BMP.
Location: Southwest of the ammonia tanks and northwest of the
empty drum storage area in Drainage Zone 3B
Materials: Acetic acid 20%,nitrobenzene,hydrogen peroxide,
acetic anhydride,and aniline.
Structural BMPs*: This storage area has a divided concrete dike which
allows for segregation of incompatible materials should
a spill occur. There is a sump located in each of the
diked areas. The tanks in this area are also equipped
with overflow detection devices.The containment dike
for tank T-8 and the containment dike for Tanks T-1,2,
Hill Tank Farm 6 and 7 have a notch in the top of the containment wall
(S-10) dividing them so the dikes act as one larger containment
area for all 5 tanks. The containment area for Tanks 1,
2,6 and 7 is 124.5'x 49'x 3.6'. The containment area
for T-8 is 34'x 50.5'x 3'. This containment area can
hold the volume of the largest tank(135,0000 gallons)
and rainwater accumulation.
Procedural BMPs: Stormwater is allowed to accumulate in the locked
sumps and inspected for visual signs of impact.
Stormwater is typically pumped to the process sewer
(WWTP). Excessive rainfall may require discharge
�\ onto the ground;however,the stormwater is sampled
prior to ground discharge.
Location: Southwest of buildings 201-205,northeast of the tank
farm on the hill in Drainage Zone 3B
Materials: Anhydrous ammonia(gaseous)
Structural BMPs: The tanks are surrounded by an earthen berm.
Ammonia Tanks Procedural BMPs: Stormwater that collects in the earthen berm is
(S-12) inspected by the Mall inckrodt PAP Department. If the
stormwater is found to be clean,it is pumped out from
the comer drain and is discharged into the stormwater
ditch system. A lock has been placed on the sump
pump in this area.
Location: Northeast of building 51A and southwest of building
101 in Drainage Zone 3B
Materials: APAP(granular and powder),PAP,bottles with caps,
Building 100 cardboard packaging,filter paper,filter cloth,safety
(S-13)* absorbent,dense soda ash,20 gal drums citric acid,rock
salt,cleaner,and urea.
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: On the southwestern side of building 101 in Drainage
Zone 3B
Materials: Potassium hydroxide,second crop mother liquors,
APAP mother liquors and crude mother liquors.
Largest tank in this area is approximately 11,000
Tank Farm West of Building 101 gallons)
(S-14) Structural BMPs*: The tanks in this area are contained by a dike. The dike
drains into a sump that drains to the process sewer
system. The dike is approximately 49.5'x 20.5'x 2'.A
locked sump is located in the diked area and can release
accumulated materials to the process sewer.
Procedural BMPs: None related to storm water
Page 3 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level or potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an""near
the Structural BMP.
Location: North of building 101 and south of building 201 in
Drainage Zone 3B
Materials: Acetic acid(Largest tank is 29,000 gallons),APAP
process wastewaters with acetic acid(Largest tank is
8,500 gallons).
Structural BMPs*: This storage area contains two concrete diked areas
Acetic Acid Tanks-North of Building 101 separating four acetic acid tanks(65'x 33'x 2.5')and
(S-15) two process tanks(33'x 33'x 2.5'). Each diked area
has a drainage trench equipped with a sump. This dike
provides sufficient containment for the volume of the
largest tank in the dike and rainwater accumulation
from a 25 year-24 hour storm event.
Procedural BMPs: The Sump in the diked area is operated in the locked
closed position. Stormwater is pumped to the process
sewers stem.
Location: Northeast of building 101 and east of Tank Farm(S-15)
in Drainage Zone 3B
Materials: Dried PAP in tote bins and bulk bags,along with
miscellaneous equipment
PAP Storage Structural BMPs: Curbed areas divert rainwater to the site process sewer
(S-16) system.
Procedural BMPs: The valves on the bottoms of the tote bins are closed
and the bins are rinsed with water to remove excess
PAP from the outside of the bins before placing the bins
outside.
Location: North of building 201 in Drainage Zone 3B
Materials: Raw materials including:cardboard,catalyst,empty 55-
Building 200/204 PAP Warehouse gal metal drums,PAP in supersacks and drums,sodium
(S 18)* hydrosulfite drums,sodium metabisulfite drums,
ethomeen,and defoaming agent.
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: On the northeastern comer of building 205 in Drainage
Zone 3B
Materials: K083 aniline still bottoms
Structural BMPs*: The tanks(T-384 and T-385)in this storage area are
covered by a canopy and built with secondary
containment in the form of a concrete dike(45'x 20.5'
K083 Aniline Tar Storage Tanks at 205 x 2')that provides sufficient containment for the largest
(5-19) tank and the minimal amount of rainwater that could be
accumulated. Additional needed secondary
containment is provided by the process sewer in this
area.
Procedural BMPs: Filling Tanks 384 and 385 is controlled by a level
gauge. Any accumulated stormwater is pumped to the
hazardous wastewater tanker(Table 6,W-17).
Page 4 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"•"near
the Structural BMP.
Location: East of building 205 in Drainage Zone 3B
Materials: Hazardous waste,solid wastes,empty drums,boxes of
methanol,plastic totes of aqua ammonia,fuel,and
plastic totes of hydrogen peroxide
Structural BMPs: The hazardous waste storage pad has a full roof and
walls on the north,east,and south sides. There are 4
separate bays segregated by a short knee wall. This
area also has a concrete pad that has epoxy coating and
is sealed with"Waterstop". The base is sloped to 4
separate collection trenches in the rear of the storage
area. There is also a speed bump on the western side
that is open for roadway access and prevents rainwater
from running onto the pad.
Hazardous Waste Storage Pad Procedural BMPs: Incompatible wastes/materials are segregated and not
(S-20) placed within the same storage bay. Hazardous and
solid wastes materials are generally stored in
appropriate new containers depending on the nature of
the hazardous waste or hazardous material to ensure no
incompatible materials stored in the same bay. When
using 55-gallon drums,the drums that are sealed are
then placed four to a pallet(maximum)with all drums
touching to prevent tipping. Provisions are made to
/"mob\ stack drums at safe heights and adequate aisle space is
maintained between the pallets. Stormwater
accumulation in the drainage trenches at the base of the
pad is typically evaporates. Should excess stormwater
accumulate in this trench,a vac truck collects the
stormwater and transports to the WWTP for disposal.
Location: Southeast of the WWTP in Drainage Zone 313
Materials: Urea 46%N,hydrated lime,PAP,APAP,pumps and
Building 10 Warehouse miscellaneous equipment.
(S-22)* Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: Northeast of the WWTP in Drainage Zone 3B
Materials: Acetic acid,phosphoric acid,and a mixture of calcium
and magnesium hydroxide.
Structural BMPs*: The three storage tanks are located in a segregated
concrete dike. The Magnesium hydroxide tank(10,000
gallons)is located in an area 23.5'27.5'x 3.5'. The
acetic acid(6,000 gallon)and the phosphoric acid
Tank Farm at WWTP (5,000 gallon)tanks are located in an adjacent
(5-23) containment dike measuring 22.25'x 27.5'x 3.5'.
Each diked area has a drainage valve that is maintained
in the locked closed position. There is sufficient
containment for the volume of the largest tank and
rainwater accumulation in each of the dikes.
Procedural BMPs: The stormwater that collects in the diked area is
checked visually for signs of contamination and for
odor prior to being manually pumped back to the
WWTP
Page 5 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
�. Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"•"near
the Structural BMP. -
Location: Southwest corner of building 201 in Drainage Zone 3B
Materials: Spent catalyst,defoaming agent,miscellaneous
equipment(Less than 660 gallons located here)
Structural BMPs: This recessed area has a roof,brick floor,walls on the
west and south sides,the raised-slab floor of building
Washing Area/Catalyst Storage Area 201 on the north side,and a concrete pad on the east
(S-24) side.A sump and pump are also located in the
northwest corner. Curbs have been added along with a
sump. Accumulated water is discharged to the process
sewer.
Procedural BMPs: None related to stormwater
Location: Northwest of the PAP Plant in Drainage Zone 3B
Materials: Ammonium sulfate. (Largest tank volume of five tanks
in this area is 4 million gallons.)
Structural BMPs*: The MASL tanks are field-erected tanks equipped with
MASL Aboveground Storage Tanks synthetic liners and leak detection systems. In addition,
(S-25)* secondary containment for the MASL storage tank area
is provided by the onsite retention pond which has a
containment volume of approximately 15 million
gallons).
Procedural BMPs: None related to stormwater
Location: Northeast of building 101 in Drainage Zone 3B
Materials: PAP(in drums,super sacks and bins)and lime.
Warehouse in Building 105 Structural BMPs: None related to storm water.
(S-26)* Procedural BMPs: None related to stormwater.
Location: Southeast of the boiler house(Building 901)and west
of the building 51 warehouse in Drainage Zone 2
Materials: Fuel(unleaded gasoline and diesel). Total volume is
1,280 gallons)
Structural BMPs: The above ground storage tanks are housed in a
recessed concrete containment area. A 14'x 29'x 6"
high,sloped concrete berm for truck unloading was
added to an existing IO'x 29'x 14"area(8"of this area
being recesses)where the tanks are located. This
Vehicle Fuel Storage Area containment provides sufficient containment for the
(S-27) tanks and rainwater accumulation.
Procedural BMPs: There are no drains from this area.Stormwater that
accumulates in the dike and in the bermed pad is
visually inspected by the Mallinckrodt Warehouse
Department for signs of contamination and odor. If no
impacts are identified,the water is manually pumped to
the stormwater ditch located east of the fuel storage
area. A lock has been placed on the sump pump in this
area.
Location: On the northeastern comer of building 201 in Drainage
Zone 3B
Materials: Aniline(Largest tank is 8,500 gallons).
Structural BMPs*: These storage tanks are located in a concrete dike(35'x
Aniline Storage Tanks 18'x 4.5')that has a drainage valve leading to the
(S-30) process sewer. Sufficient containment for the largest
tank and rainwater accumulation is provided in this
concrete dike.
Procedural BMPs: Stormwater that accumulates in the diked area is
manually released to the process sewer.
Page 6 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Structural BMP.
Location: Southeast end of Building 901 (boiler house)in
Drainage Zone 2
Rock Salt Storage Materials: Plastic bags of rock salt
(S-31) Structural BMPs: None related to stormwater
Procedural BMPs: Provisions are made to store materials in original
containers and stack containers on wooden pallets.
Location: North of building 2 adjacent to the drainage ditch in
Drainage Zone 3B
Propane Aboveground Storage Tank Materials: Propane
(S-35)* Structural BMPs: None related to stormwater
Procedural BMPs: None related to stormwater.
Propane Aboveground Storage Tank Location: North of fuel storage area in Drainage Zone 2
Materials: Propane
(S-38)* Structural BMPs: None related to stormwater
Procedural BMPs: None related to stormwater.
Location: Building 901(Boiler House)in Drainage Zone 2
Materials: Corrosion inhibitor,potassium hydroxide,sodium
bisulfite,sodium hydroxide,sodium tripolyphosphate,
Building 901,Boiler Treatment Chemicals and Distilled resin cleaner,fuel oil additive,synthetic compressor
Water Chemical Storage Area lubricant,rock salt,and boiler treatment chemicals.
(S-39)* Structural BMPs: This storage area is inside of a fully enclosed building
with concrete flooring and no floor drains.
Procedural BMPs: Provisions are made to stack drums at safe heights and
lace drums on pallets.
Location: North of Building 903(Maintenance Building)in
Drainage Zone 3B
Materials: Three electrical infrastructure transformers are located
in this area. The volume of transformer oil in each one
is 487,392,and 478 gallons.
Structural BMPs: A 2-inch high,crush-and-run gravel dike surrounds this
transformer station that is owned,operated and
Progress Energy(P-E)Substation maintained by P-E. Accumulated rainwater percolates
(S 41) through gravel or evaporates. Should a spill leave this
area,a series of storm water conveyances with control
valves throughout the site would contain the release.
Procedural BMPs: The substation is periodically inspected by Mallinckrodt
personnel for indicators of contamination(color,foam,
sheens,stains and odor).P-E will be contacted
immediately if physical indicators of contamination are
observed.
Location: North of Building 2(Administration Building)in
Drainage Zone 3B
Materials: Approximately 134 gallons of transformer oils are
contained in electrical equipment at this substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
Transformer Substation No. 1,Near Building 2 substation if found to be leaking. Any materials leaving
(S 42) the dike area will be collected in a series of stormwater
conveyances with control valves located throughout the
site.The dike is located within a locked fenced area.
Procedural BMPs: Applicable personnel are trained to close the dike valve
if oil leaks are observed.The substation is also
inspected semi-annually as a part of the stormwater
inspection program.
Page 7 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an" ',near
the Structural BMP.
Location: North of Building 903(Maintenance Building)in
Drainage Zone 3B
Materials: Approximately 131 gallons of transformer oils are
contained in electrical equipment at this substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
Transformer Substation No.2,Near Building 903 substation. Any materials leaving the dike area will be
(S-43) collected in a series of storm water conveyances with
control valves located throughout the site. The dike is
located within a locked fenced area.
Procedural BlVIPs: Applicable personnel are trained to close the dike valve
if oil leaks are observed.The substation is also
inspected semi-annually as a part of the stormwater
inspection program.
Location: West of building 101 in Drainage Zone 3B
Materials: Approximately 254 gallons of transformer oils are
contained in electrical equipment at this substation
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
substation. Any materials leaving the dike area will be
Transformer Substation No.4,Near Building 101 collected in a series of storm water conveyances with
(S-45) control valves located throughout the site. The
transformer and dike is located within a locked fenced
area.
Procedural BMPs: Applicable personnel are trained to close the dike valve
if oil leaks are observed.The substation is also
inspected semi-annually as a part of the stormwater
inspection program.
Location: East of building 200 in Drainage Zone 3B
Materials: Approximately 168 gallons of transformer oils are
contained in electrical equipment at this substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
contain the oil in the transformer is located around this
Transformer Substation No.5B,Near Building 200 substation. Any materials leaving the dike area will be
collected in a series of storm water conveyances with
(S46) control valves located throughout the site. The dike is
located within a locked fenced area.
Procedural BMPs: Applicable personnel are trained to close the dike valve
if oil leaks are observed.The substation is also
inspected semi-annually as a part of the stormwater
inspection program.
Location: East of Big Mac(raw waste surge tank)in Drainage
Zone 3B
Materials: Approximately 300 gallons of transformer mineral oil is
contained in electrical equipment.
Structural BMPs: Transformer is contained in weatherproof enclosure on
concrete pad. Any materials leaving the transformer
P-E Transformer Substation No. 1,Near Big Mac area will be collected in a series of stormwater
(S47) conveyances with control valves located throughout the
site.
Procedural BMPs: The substation is also inspected semi-annually as a part
of the stormwater inspection program. Progress Energy
will be contacted immediately if physical indicators of
contamination are observed.
Page 8 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"*"near
the Structural BMP.
Location: West of Building 10 in Drainage Zone 3B
Materials: Approximately 145 gallons of transformer mineral oil is
contained in electrical equipment.
Structural BMPs: Transformer is contained in weatherproof enclosure on
concrete pad.Any materials leaving the dike area will
be collected in a series of storm water conveyances with
control valves located throughout the site. The dike is
located within a locked fenced area.
P-E Transformer Substation No.2,West of Building 10 Procedural BMPs: The substation is inspected after rain events by
(S-48) Mallinckrodt personnel for indicators of contamination
(color,foam,sheens,stains and odor)prior to discharge.
Contaminated stormwater would be pumped out and
disposed of properly.The substation is also inspected
semi-annually as a part of the stormwater inspection
program.Progress Energy will be contacted
immediately if physical indicators of contamination are
observed.
Location: North of the Wastewater Treatment Plant in Drainage
Zone 3B
Materials: Approximately 380 gallons of transformer mineral oil is
contained in electrical equipment
Structural BMPs: Transformer is contained in weatherproof enclosure on
P-E Transformer Substation No3,Near Wastewater concrete pad. Any materials leaving the dike area will
Treatment Plant be collected in a series of storm water conveyances with
(S-49) control valves located throughout the site.
Procedural BMPs: The substation is periodically inspected by Mallinckrodt
personnel for indicators of contamination or release.
Progress Energy will be contacted immediately if
physical indicators of contamination are observed.
Location: Building 907 in Drainage Zone 3B
Materials: Lubricant and waste oil drums and a 500-gallon waste
oil tank.
Structural BMPs: Tanks and drums are housed in a 46'by 51'6"fully-
enclosed building with a concrete floor and no floor
drains. A 1,100 gallon containment pan is provided
for the 500 gallon used oil tank. Any materials leaving
Building 907 Oil Storage the building will be collected in a series of storm water
(S-50)* conveyances with control valves located throughout the
site.
Procedural BMPs: Provisions are made to place drums and materials on
pallets and stack pallets at safe heights. Spill control
materials are readily available.
Location: West of the fire training area in Drainage Zone 2
Materials: Paint,fuel,piping,compressed gas.
Structural BMPs: Trailers prevent contact with stormwater for most
Contractor Trailer Area chemicals.
(S-51) Procedural BMPs: Most chemicals are not stored outside the trailers.
Portable containment usually provided for chemicals
stored outside or at least chemicals stored n pallets so
not standing in water.
Location: West of Building 201 near catalyst wash area in
Drainage Zone 3B
Ethomeen Building Materials: 3 totes containing Ethomeen C-12 and 1 tote of
(S-52)* defoaming agent.
Structural BMPs: Building prevents contact with stormwater.
/0001\ Procedural BMPs: Chemicals are not stored outside the building.
Page 9 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
�. Revised: May 2016
Note:The BNIPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"'near
the Structural BMP.
Location: Off south end of Building 901(Boiler House)in
Drainage Zone 3B
Materials: Approximately 421 gallons of silicone-based dielectric
fluid are contained in electrical equipment at this
substation.
Structural BMPs: A concrete dike equipped with a valve is sufficient to
Transformer Substation No.8,Near Building 901 contain the oil in the transformer is located around this
substation. Any materials leaving the dike area will be
(S-53) collected in a series of stone water conveyances with
control valves located throughout the site. The dike is
located within a locked fenced area.
Procedural BMPs: Applicable personnel are trained to close the dike valve
if oil leaks are observed.The substation is also
inspected semi-annually as a part of the stormwater
inspection program.
Location: North of building 205 in Drainage Zone 3B
Materials: Dried PAP in bulk bags,off spec process liquors,
miscellaneous equipment
PAP Rework and Temporary Chemical Storage Structural BMPs: Area is covered by a canopy to minimize contact with
(S-54)(formerly L-5) rain,plus area is curbed with a sump so accumulated
rainwater can be sent to the site process sewer System.
�\ Procedural BMPs: The materials are stored on pallets or in tote bins.
Location: North end of building 101 in Drainage Zone 3B
Materials: Northwestern Dike-Recovered Acetic Acid and
Hydrogen Peroxide(Largest Tank is 1,500 gallons);
Northcentral Dike-Process Liquors containing Acetic
Acid(Largest Tank is 2,000 gallons);Northeastern
Dikes AB-Process Liquors containing Acetic Acid
(Dike A:Largest tank is<3,000 gallons;Dike B:
Largest tank is 6,000 gallons)
Tank Farm North of 101(S-55) Structural BMPs: The tanks in this area are contained by four separate
dikes. Each dike drains into a sump that pumps into the
process sewer system. Northeastern Dike A is
approximately 37'x 13'x 2',Northeastern Dike B is
approximately 36'x 2 P x 3',Northcentral Dike is
approximately 19'x 13'x 2',and Northwestern Dike is
approximately 36'x 18'x 2'.A sump is located in each
diked area and can release accumulated stormwater to
the process sewer.
Procedural BMPs: Stormwater is not discharged to the ground in this area.
Location: Southwest of the ammonia tanks and northwest of the
empty drum storage area in Drainage Zone 3B
Materials: Sulfuric acid. (Largest Tank is 28,000 gallons)
Structural BMPs*: This storage area has a concrete dike(27'x 73'x 3.5').
There is a sump located in the diked area. The
Sulfuric Acid Tank Farm(S-56) containment area(capacity of 42,000 gallons)is
sufficient for the volume of the largest tank and
rainwater accumulation.The tanks in this area are also
equipped with overflow detection devices.
Procedural BMPs: Stormwater is allowed to accumulate in the sump and
inspected for visual signs of impact.Stormwater is
typically pumped to the process sewer(WWTP).
Page 10 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
/doftN Revised: May 2016
Note:The BMPs for material storage areas were chosen based on
their level of potential impact to stormwater,including frequency
Of movement of materials,volume of materials,location at facility,
and type of materials.
Location and Implemented Best Management Practices(BMPs)
NOTE:Associated Required Secondary Containment is described under structural
Storage Area BMPs. All containment calculations take into effect the displacement of the tanks
located in the containment area. Areas requiring containment is noted with an"'"near
the Structural BMP.
Location: Wastewater Treatment Plant Area in Drainage Zone 3B
Materials: Approximately 82 gallons of diesel is contained is
contained in generator.
Structural BMPs: The generator is located in a roofed area with a
WWTP Back-up Diesel Generator(S-57) secondary containment area capable of containing a
release of the oil in the generator and any rainwater that
may be accumulated in the dike under the canopy.
Procedural BMPs: The generator is periodically inspected by Mallinckrodt
ersonnel for indicators of contamination or release.
Location: Wastewater Treatment Plant Area in Drainage Zone 3B
Materials: Anti-Foam Agent in two totes.
Anti-Foam Dike area in WWTP(S-58) Structural BMPs: This area is contained in concrete curbed shed south of
the tank farm at WWTP.
Procedural BMPs: The area is periodically inspected by Mallinckrodt
personnel for indicators of contamination or release.
Location: South of building 903 in Drainage Zone 3B
Materials:
Structural BMPs: The Boiler and ancillary piping are located in a concrete
dike that has a drainage trench equipped with a sump.
Boiler No.7(S-59) This equipment is located in the same dike as the Cloud
[Co-located with Scrubber System(P-5)] Chamber Scrubber(see Table 4,P-5).
Procedural BMPs: Stormwater is allowed to accumulate in the sump and
inspected by the Mallinckrodt Utilities Department for
visual signs of impact. Based on prior approval by the
City of Raleigh POTW,stormwater is pumped to the
condensate sewers stem.
Location: East of Building 200
Materials: Compressor Oil
PAP Plant Compressor(S-60) Structural BMPs: Sloped areas divert rainwater to the site process sewer
system.
Procedural BMPs: None related to stormwater.
Notes:
• (S-4) Former No.6 Fuel Oil Tank has been completely removed from the site.
• (S-11) Former Bulk Acetic Acid Bladder Tank has been completely removed from the site(in 1996).
• (S-17) Former Spent Catalyst Storage Area is not in use;moved to Hazardous Waste Pad(S-20)in 2016.
• (S-21) Former Storage Area West of Shot Pond has been completely removed from the site.
• (S-28) Former Flammable Liquids Storage Area has been completely removed from the site.
• (S-29) Former Storage Pad northwest of Environmental Lab(WWTP area)
• (S-32) Former Waste Toluene Storage Tank Area has been completely removed from the site(in 2000).
• (S-33) Former Day Tanks at Building 201 have been completely removed from the site(in 1996).
• (S-34) Former Day Tanks at Building 205 have been completely removed from the site(in 1996).
• (S-36) Former Corrective Action Roll-off Storage is a practice no longer utilized at the site.
• (S-37) Wastewater Filter Solids Accumulation Area is no longer utilized at the site.
• (S40) Hydrogen Peroxide Tote location moved to the Hill Tank Farm(S-10)in 2009.
,Woft� • (S44) Former Transformer Substation No.3 has been completely removed from the site(in 2015).
Page 11 of 12

Table 2
Materials Storage Practices—BMP Summary
Mallinckrodt LLC
Raleigh AN Plant
Revised: May 2016
* Denotes areas not inspected because no significant exposure to stormwater
Page 12 of 12

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised May 2014
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and tvpe of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: On the east and south sides of the building 51 warehouse,in
Building 51 Warehouse Loading/Unloading Drainage Zones 1 and 2
(L I)• Materials: APAP(granular and powder)
Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: On the eastern and western sides of the building 51A warehouse
in Drainage Zones 2 and 3B
Building 5 1 A Warehouse Loading/Unloading Materials: Raw materials(see Table 1,S-2)
(L-2)' Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: North of building 101 and south of building 201,in Drainage
Zone 3B
Materials: Acetic acid.
Structural BMPs: A trench drain leading to a manually controlled sump that
discharges into the process sewer system collects run-off from
this material transfer area. An asphalt berm diverts run-off in
Acetic Acid Loading Stations this area to the process sewer.
North of Building 101 Procedural BMPs: Before loading/unloading procedures begin,operators make
(L-3) sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators are also present during loading and unloading
operations,and monitor the levels of materials in the tanks to
prevent overflow ands ill,and to observe for leaks.
Location: West of buildings 101 and 205 in Drainage Zone 3B
Materials: Nitrobenzene,sulfuric acid,and acetic anhydride are received
in this area;aniline,ammonium sulfate,and acetic acid are
shipped from this area.
Structural BMPs: The nitrobenzene railcar transfer areas are equipped with
collection pans that drain to a 1,000-gallon sump. The aniline
rail car transfer area is equipped with a collection pan that
drains to a 500-gallon sump. The sump is equipped with a
pump so that the contents can be collected and used or
discharged to the site process sewer system. Sulfuric acid
Railcar Area Loading/Unloading railcar transfer areas consist of lime to neutralize any spilled
(L-4) material. Additional secondary containment would be
provided by the series of valve-controlled ditches located
onsite.
Procedural BMPs: Before loading/unloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators also present during unloading and monitor the levels
of materials in the tanks to prevent overflow and spill and to
observe for leaks.
Page 1 of 6

Table 3
Loading/Unloading Activities—BMP Summary
,.� Mallinckrodt LLC
Raleigh API Plant
Revised May 2014
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and type of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: North of the WWTP and cast of the flushwater pond in
Drainage Zone 3B
Materials: Acetic acid,phosphoric acid,and liquid magnesium hydroxide
Structural BMPs: Wastewater treatment chemical loading/unloading occurs on a
concrete pad with a 5"sloped concrete berm.The sloped berm
allows vehicle access,but provides containment.The pad is
approximately 47'by 14'and is constructed in a roadway,and
is sloped toward a sump. The capacity of the loading area is
approximately 1,400 gallons. The sump has a level switch and
accumulated water in the loading area is pumped into the dike
around the liquid magnesium hydroxide tank,which has a
Tank Farm at WWTP Unloading capacity of approximately 13,000 gallons. A lock has been
(L-6) placed on the sump pump in this area.
Procedural BMPs: Before loading/unloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators also monitor the levels of materials in the tanks and
the transfer operations to prevent overflow and minimize the
impact of any spill. Water accumulated in the dike is checked
visually by the Mallinckrodt Utilities Department for signs of
contamination and odor prior to being manually pumped to the
/dolt" WWTP(see Table 2,5-23).
Location: Southeast of the WWTP in Drainage Zone 3B
Materials: APAP and PAP
Structural BMPs: This loadinglunloading area has two loading docks with bumper
pads which provide a tight seal between the building and trucks,
a canopy and a driveway which is sloped towards the building.
The area is paved and contains a catch basin at each loading
Building 10 Warehouse Loading/Unloading dock that drains to the storm water system.The majority of the
(L-7) materials handling operations are contained inside the trailer
and warehouse. Secondary containment for this area would be
provided by the onsite retention pond.
Procedural BMPs: Provisions are made to place materials on pallets and stack
pallets at safe heights. Absorbent materials are also readily
available in this area. The catch basins are cleared of leaves
and debris as needed.
Location: On the western side of building 100 in Drainage Zone 3B
Materials: Caustic(Sodium hydroxide or Potassium hydroxide).
Structural BMPs: This loading/unloading area has a concrete containment berm
with a capacity of 6,000 gallons. The loading/unloading area
contains a sump that allows accumulated liquids to be pumped
to the site process sewer system.
Loading/Unloading Area Behind Building 100 Procedural BMPs: Before loading/unloading procedures begin,operators make
(L-8) sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators also monitor the levels of materials in the tanks to
prevent overflow ands ill.
Page 2 of 6

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised May 2014
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and type of materials.
Loading/Unloading Area Location and!Implemented Best Management Practices(BMPs)
Location: On the north side of the#2 fuel oil aboveground storage tank
(S-3)in Drainage Zone 3B
Materials: No.#2 fuel oil
Structural BMPs: Top loading/unloading operations are conducted at this truck
loading/unloading station. The station,consisting of concrete
dike walls on the east and west sides,concrete ramps on the
north and south sides(68'x 13'),and a trench drain and sump
at the low point has sufficient capacity to contain the volume of
one compartment of a 7,500 gallon tanker truck plus freeboard
for rain accumulation. An operator is present at all times during
No.2 Fuel Oil/Caustic Unloading Area unloading operations and any leaks or failures in the hoses,etc.
(L-9) would be corrected immediately.
Procedural BMPs: Before unloading procedures begin,Utility operators make sure
that wheels are chocked,that the vessel is in good condition,the
vessel is vented(if it is pressurized),and that the hoses,pumps,
and lines do not have leaks in accordance with area-specific
fuel unloading procedure in the site's Oil SPCC Plan(see Table
1,S-3).Operators also monitor the levels of materials in the
tanks to prevent overflow and spill.The sump is pumped to the
stormwater ditch located west across the roadway. A lock has
been placed on the sump pumpin this area.
Location: On the eastern side of building 100 in Drainage Zone 3B
Loading/Unloading Dock at Building 100 Materials: New,empty fiber pack drums and chemicals in drums and bags.
(L-10)* Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater.
Location: South of the MASL Storage Tanks in Drainage Zone 3B
Materials: Ammonium sulfate(MASL)
Structural BMPs: Each of the two-loading/unloading areas has a sloped concrete
pad,berms around the concrete pad,and a sump with a total
capacity of approximately 3,500 gal. The sumps have pumps
with float switches that pump collected materials to MASL
Tank#l. This provides enough containment for the volume of
one compartment of a tanker truck plus rainwater accumulation.
Procedural BMPs: Truck drivers are responsible for implementing procedures to
minimize the likelihood of a release from the truck loading
MASL Loading operation. Before loading/unloading procedures begin,drivers
(L-11) make sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks. A
metered loading system automates the loading process and
minimizes the possibility ofoverfill.Drivers are responsible for
checking the truck valve to ensure it is secure before leaving the
site. Failure to comply will ban the driver from receiving any
future loads of MASL. Accumulated water is generally
pumped to MASL Tank#1.
Page 3 of 6

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised May 2014
Note:The BMPs for loading/unloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and type of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: Southeast of the boiler house(Building 901)and west of the
building 51 warehouse in Drainage Zone 2
Materials: Gasoline and diesel fuel
Structural BMPs: An additional,bermed 14 feet was added to the length and
another 6"added to the height of the existing recessed 10'x
29'xl4"fuel tank containment area. The sloped berm allows
vehicle access,but provides containment(see Table 1,S-27).
Sufficient containment is provided for a 2,500 gallon tanker
truck and 1,400 gallons of rainwater accumulation from a 25
year-24 hour storm event. Containment for the additional 1,300
gallons of possible accumulated rainwater would be provided
by the adjacent valve-control storm water ditch. An operator is
Vehicle Fuel Loading/Unloading present during all unloading operations and a failure or rupture
(L-12) would be addressed immediately.
Procedural BMPs: Before unloading procedures begin,Utility operators make sure
that wheels are chocked,that the vessel is in good condition,the
vessel is vented(if it is pressurized),the vessel is grounded(if it
contains flammable material),and that the hoses,pumps,and
lines do not have leaks in accordance with specific fuel
unloading procedures in the site's Oil SPCC Plan. Operators
also monitor the levels of materials in the tanks to prevent
overflow and spill. There are no drains from this area.
Stormwater that accumulates in the dike and in the bermed pad
is manually pumped to the stormwater ditch just east ofthis
area. A lock has been placed on the sump pumpin this area.
Location: Northeastern comer of building 201,in Drainage Zone 3B
Materials: Aniline,ammonium bisulfate
Structural BMPs: This loading/unloading area has a sloped concrete pad,a sump
and dike along the western end of the pad,dikes on the northern
and southern sides of the pad,and a berm on the eastern end of
the pad(this berm was moved approximately 20 ft.to the west
in 2004 to facilitate drainage). Stormwater accumulated in the
sump is pumped to the process sewer system. Drainage will
Aniline Truck Loading/Ammonium Bisulfite allow all stormwater to flow by gravity to the process sewer.
Truck Unloading The existing loadinglunloading area has a capacity of
(L-13) approximately 2,000 gallons.
Procedural BMPs: Before loadinglunloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,the vessel is vented(if it is pressurized),the vessel is
grounded(if it contains flammable or combustible material),
and that the hoses,pumps,and lines do not have leaks.
Operators also monitor the levels of materials in the tanks as
well as the transfer operations to prevent overflow ands ill.
Location: West Side of Building 200 in Drainage Zone 3B
Materials: PAP
Structural BMPs: This loading/unloading area has a driveway that slopes south to
three catch basins that drain to the condensate sewer system via
West Side PAP Loading/Unloading industrial discharge agreement. There is also roof over the
(L-14) loading and unloading platform.
Procedural BMPs: Provisions are made to place materials on pallets and stack
pallets at safe heights. Absorbent materials are also readily
available in this area. Materials are moved inside as soon as
possible and not stored on the loadin latform.
Page 4 of 6

Table 3
Loading/Unloading Activities—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised May 2014
Note:The BMPs for loadingfunloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materiaL%location at facility,
and type of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: Northeast of building 903 in Drainage Zone 3B
Materials: Anhydrous ammonia
Structural BMPs: This concrete diked loading/unloading area slopes and drains to
a sump. Rainwater collected in the sump is manually pumped
by the Mallinckrodt Warehouse Department to the stormwater
Anhydrous Ammonia Unloading Area conveyance ditch. A lock has been placed on the sump pump in
this area.
(L-17) Procedural BMPs: Before loading/unloading procedures begin,operators make
sure that wheels are chocked,that the vessel is in good
condition,and that the hoses,pumps,and lines do not have
leaks. Operators also monitor the levels of materials in the
tanks to prevent overflow and spill.
Location: Northeast of building 903 in Drainage Zone 3B
Materials: Sulfuric acid
Structural BMPs: This concrete diked unloading area slopes and drains to a sump.
Material collected in the sump is manually pumped to the
process sewer system. Operators are present during the
Sulfuric Acid Unloading Area unloading operations and can manually discharge to process
(L 18) sewer.
Procedural BMPs: Before unloading procedures begin,operators make sure that
wheels are chocked,that the vessel is in good condition,and
that the hoses,pumps,and lines do not have leaks. Operators
also monitor the levels of materials in the tanks to prevent
overflow ands ill.
Location: Northeast of building 903 in Drainage Zone 3B
Materials: Nitrobenzene
Structural BMPs: This concrete diked unloading area slopes and drains to a sump.
Materials collected in the sump is manually pumped to the
Nitrobenzene Unloading Area process sewer system.
(L-19) Procedural BMPs: Before unloading procedures begin,operators make sure that
wheels are chocked,that the vessel is in good condition,and
that the hoses,pumps,and lines do not have leaks. Operators
also monitor the levels of materials in the tanks to prevent
overflow ands ill.
Location: Adjacent to Building 907 in Drainage Zone 3B
Materials: Used Oil
Structural BMPs: This concrete loading area slopes to a stormwater conveyance
ditch that contains a gate valve that is operated in the locked
position. This storm water conveyance provides secondary
containment for this area.
Procedural BMPs: Only Environmental Staff are able to oversee the loading of
used oil and signing of the manifest. Before unloading
Used Oil Loading Area(L-20) procedures begin,Environmental personnel make sure that
wheels are chocked,that the vessel is in good condition,and
that the hoses,pumps,and lines do not have leaks plus verifies
that the valve in the stormwater drainage ditch located north of
the Hydrogen Plant is locked in accordance with area-specific
fuel loading procedure in the site's Oil SPCC Plan. The person
also monitors the levels of materials in the tanks to prevent
overflow and spill. Spill response materials are located at this
area and are placed around the loading operation area and a spill
boom is placed between the loading operations and the ditch.
Page 5 of 6

Table 3
Loading/Unloading Activities—BMP Summary
�* Mallinckrodt LLC
Raleigh API Plant
Revised May 2014
Note:The BMPs for loadingtunloading activities
were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,
and type of materials.
Loading/Unloading Area Location and Implemented Best Management Practices(BMPs)
Location: In W WTP Area on the east side and adjacent to the diesel
emergency backup generator in Drainage Zone 3B
Materials: Diesel
Structural BMPs: This unloading area slopes to a stormwater conveyance ditch
that drains to the onsite retention pond,which provides
secondary containment.
WWTP Emergency Generator(L-21) Procedural BMPs: Before unloading procedures begin,Utility operators make sure
that wheels are chocked,that there is sufficient room in the fuel
tank,and that the hoses and pumps do not have leaks in
accordance with area-specific fuel unloading procedure in the
site's Oil SPCC Plan. Operators also monitor the level of
material in the generator to prevent overflow and spill.Spill
equipment is available in this area and spill booms are placed
around the loading operations.
Notes:
• (L-5) Former K083 Tar Loading and Unloading area is no longer in use. Also see Table 6,W-17.
• (L-15)Former Waste Toluene Loading area is no longer in use;toluene is no longer used in plant
processes.
• (L-16)Former Thionyl Chloride and DMF Unloading area is no longer in use;these chemicals are no
longer used in plant processes.
* Denotes areas not inspected because no significant exposure to stormwater
Page 6 of 6

Table 4
000,\ Outdoor Process Areas—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2014
Note:The BMPs for outdoor process activities were chosen
based on their level of potential impact to storm water,
including frequency of movement of materials,volume of
materials,location at facility,and type of materials.
Outdoor Process Area Location and Implemented Best Management Practices(BMPs)
Location: West of the building 51 warehouse and southwest of the
Fire Training Area gasoline storage and loadinglunloading area in Drainage
(P-1) Zone 2
Materials: #2 fuel oil,gasoline,various hazardous materials or
hazardous/solid wastes
Structural BMPs: The fire training area is located on a concrete diked pad
approximately 40'x 20'x 1.5'that slopes to a sump on
the southern end of the pad. The sump is operated in a
locked and closed position.
Procedural BMPs: Fire training is conducted annually,typically in October
of each year. Upon completion of fire training,an
environmental contractor manually pumps liquids in the
sump into a vacuum truck for disposal.Residual liquids
contained in the sump are typically a mixture of
rainwater,92 fuel oil,and firefighting foam.The sump is
then power-washed and emptied into the vacuum truck.
During the rest of the year,when no potential
contamination sources are present in the sump,collected
rainwater in the sump is inspected by the Mallinckrodt
Utilities Department and then manually pumped to the
stormwater conveyance ditch located east of the training
area. A lock has been placed on the sump pump in this
area. Mallinckrodt personnel inspect the containment
system at least once each six months. When hazardous
wastes are temporarily stored in this area(<90-day
storage),a minimum of weekly inspections are
performed. The Environmental Department ensures that
only compatible materials are stored in this area.
Location: On the southeastern end of the maintenance building
Maintenance Wash Pit (building 903)in Drainage Zone 2
(P-2)* Materials: Infrequent use for rinsing maintenance equipment/tools.
Structural BMPs: The concrete wash pit is sloped towards a sanitary sewer
drain located on the northern end of the pit. There are
berms located on the southern,eastern,and western
sides ofthe pit.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of stormwater contamination.
Location: North of the PAP process area in Drainage Zone 3B
Wastewater Treatment Plant Materials: Process wastewater
(P-4)` Structural BMPs: The tanks in the WWTP are equipped with high level
alarms,flow controls,and liners with the steel tanks
themselves as secondary containment.The 4,000,000-
gallon capacity wastewater holding tank is equipped
with a water leachate system under the tank that collects
and redirects minor spills to the WWTP.
Procedural BMPs: None related to stormwater.
i,MIN
Page 1 of 2

Table 4
Outdoor Process Areas—BMP Summary
Mallinckrodt LLC
,�►� Raleigh API Plant
Revised: May 2014
Note:The BMPs for outdoor process activities were chosen
based on their level of potential impact to storm water,
including frequency of movement of materials,volume of
materials,location at facility,and type of materials.
Outdoor Process Area Location and Implemented Best Management Practices(BMPs)
Location: South of Building 910 and west of Building 912 in
Scrubber System Drainage Zone 3B
(P-5) Materials: 25%Sodium hydroxide
[Co-located with Boiler No.7(S-59)] Structural BMPs: The scrubber system and associated tanks are contained
by a dike. This equipment is located in the same dike as
Boiler No.7(see Table 2,S-59).This dike provides
sufficient containment for the volume of the largest tank
in the dike and rainwater accumulation from a 25 year-
24 hour storm event. The dike drains into a trench and
sump.
Procedural BMPs: Stormwater is allowed to accumulate in the sump and
inspected by the Mallinckrodt Utilities Department for
visual signs of impact. Based on prior approval by the
City of Raleigh POTW,stormwater is pumped to the
condensate sewer system..
* Denotes areas not inspected because no significant exposure to stormwater
f"IN
%"e\
Page 2 of 2

Table 5—BMP Summary
Dust/Particulate Generating/Control Areas
Mallinckrodt LLC
Raleigh API Plant
Revised: May 2014
Note:The BMPs for dust/particulate generating/control
activities were chosen based on their level of potential impact
to storm water,including frequency of movement of
materials,volume of materials,location at facility,and type
of materials.
Dust/Particulate Generating/Control Areas Location and Implemented Best Management Practices(BMPs)
Location: In Buildings 201 and 205 in Drainage Zone 313
PAP Bag Filters for Vacuum Dryers and Product Bin Materials: PAP(powder)
Packaging Structural BMPs: The bag filters are equipped with a control device to
(D-1)* prevent emissions of particulates. The roofdrains in this
area are directed to the W WTP.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of storm water contamination.
Location: In Buildings 101,102,103,and 104 in Drainage Zones 2
APAP Bag Filters on Drop Hoppers,Sizing Operating and 313
Equipment,and Multi-level Clean Room Operations Materials: APAP(powder,granular)
(D-2)* Structural BMPs: The bag filters are equipped with a control device to
prevent emissions of particulates and the roof drains in
this area are directed to the W WTP.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of stormwater contamination.
Location: South of Building 102 in Drainage Zone 2
APAP Drying Tower Courtyard Materials: APAP from bag filter transportation
(D-3) Structural BMPs: Drainage from the courtyard area,through which bag
filters are cleaned and transported,was redirected to the
process sewer system in 2004.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of stormwater contamination.
Incidental releases of APAP dust is swept up on a
regular basis.
Location: West of Building 51A in Drainage Zones 2 and 3B
Boiler House Materials: Particulates from the burning of fuels in site boilers
(D-4)* Structural BMPs: None related to stormwater.
Procedural BMPs: None related to stormwater. Not identified as a
significant source of stormwater contamination.
* Denotes areas not inspected because no significant exposure to stormwater
Page 1 of 1

Table 6
Waste Disposal Areas—BMP Summary
Mallinckrodt LLC
Raleigh API Plant
Revised:July 2015
Note:The BMPs for waste disposal activities were chosen
based on their level of potential impact to storm water,
including volume of materials,location at facility,and type
of materials.
Waste Disposal Area Location and Implemented Best Management Practices(BMPs)
Location: NW Comer of Building 101 in Drainage Zone 3
Dumpster and Trash Compactor Northwest of Building Materials: Crushed empty fiber drums and trash from Building 101
101 and administrative offices and carbon.
(W-2)* Structural BMPs: The trash compactor is self-enclosed and is contained by
walls on the south and east sides,and a berm on the west
side.The dumpster is contained by walls on the south
and east sides,and a berm on the west side. Run off
from this area flows to an asphalt diversion berm,then
drains to a sump leading to the site process sewer
system.
Procedural BMPs: Employees are trained about appropriate placement of
waste in dumpsters.
Location: SE and SW of Building 201 in Drainage Zone 3
Materials: Trash from building 200 and 201,packaging for raw
Dumpster Southeast of Building 201 materials,drums/totes of potassium hydroxide,and non-
Waste Pallet Dumpster East of the Maintenance Shop recyclable pallets.
(W-3)* Structural BMPs: Trash dumpster is self-enclosed. These dumpsters are
not covered or within a dike due to low risk of exposure
to Stormwater.
Procedural BMPs: Employees are trained about appropriate placement of
wastes and pallets in dumpsters.
Location: NW of Building 10 in Drainage Zone 3
Dumpster Northwest of Building 10 Materials: Trash from Building 10 and WWTP
Dumpster near Building 10 Loading Docks Structural BMPs: The common trash dumpster is self-enclosed and the
(W4)* cardboard dumpster is open-topped.
Procedural BMPs: Employees are trained about placement of waste in
dumpsters.
Location: NW of Building 101 in Drainage Zone 3
Cardboard Recycling Container Materials: Cardboard
(W-7)* Structural BMPs: None related to stormwater
Procedural BMPs: Employees are trained about placement of cardboard for
recycling in dumpsters.
Location: North of Building 205 in former K083 Tar load/unload
Dumpster North of Building 205 area(L-5)in Drainage Zone 3
(W-9)' Materials: Trash from buildings 204 and 205 and packaging for raw
materials.
Structural BMPs: The dumpster is self-enclosed and is located on concrete
pad,surrounded by a berm,sloped toward a sump
located inside the loading area.
Procedural BMPs: Accumulated storm water is inspected and,if clean,is
manually pumped to the process sewer.Employees are
trained about placement of waste in dumpsters.
Location: NW of the Maintenance Building in Drainage Zone 3
Recycling Bins Northwest of Maintenance Materials: Segregated metal equipment,parts,and miscellaneous
(W-10)* construction debris.
Structural BMPs: None related to stormwater
Procedural BMPs: Employees are trained about placement of recyclables in
bins/dumpsters.All oils are drained and piping is wiped
down prior to placement in metal recycling bins.
Misc.Trash Cans Location: Throughout plant site
(W-13)* Materials: Misc.garbage(e.g.,paper,beverage containers,etc.)
Structural BMPs: The common trash can with lid or open top trash hopper
Procedural BMPs: Employees are trained about placement of waste in
dumpsters.
Hazardous Waste Storage Area
(W-14) See Table 1,S 20
Page 1 of 2

Table 6
Waste Disposal Areas—BMP Summary
�..� Mallinckrodt LLC
Raleigh API Plant
Revised:July 2015
Note:The BMPs for waste disposal activities were chosen
based on their level of potential impact to storm water,
including volume of materials,location at facility,and type
of materials.
Waste Disposal Area Location and Implemented Best Management Practices(BMPs)
Location: East of Building 100A in Drainage Zone 3
Trash Compactor East of Building IOOA Materials: Crushed empty fiber drums and trash from building 100,
(W-16)* IOOA and warehouse
Structural BMPs: The trash compactor is covered by a roof.
Procedural BMPs: Employees are trained about placement of waste in
dun stern.
Location: Northwest of building 901 in Drainage Zone 3
K083 Rainwater Storage—west of Building 905 Materials: Rainwater/precipitation that has been in contact with
(W-17) K083 aniline tar tanks and/or the secondary containment
for those tanks.
Structural BMPs: Rainwater is pumped or manually transferred to totes
from the dikes containment areas of S-5 and S-19.
These totes are stored in this diked concrete secondary
containment located adjacent to the Aniline Tar Tank
containment area(S-5). This area is 45'x 13'x 0.5'at
the ends and is sloped towards the middle where the
depth is 0.7'.
Procedural BMPs: Stormwater accumulation from the sumps or diked areas
of S-5 and S-19 is manually pumped out directly into
totes(or other containers). These totes are stored
temporarily in this diked area until being transferred to
the Hazardous Waste Storage Building(S-20),at
intervals of less than 90 days for each tote. Filling the
tote is limited to a few inches below the top of the tote to
�\ allow for freeboard. The totes are stored at the
Hazardous Waste Storage Pad prior to ultimately being
sent off-site for disposal as a hazardous waste.
Accumulated water in this area is inspected prior to
discharge.
Notes:
• (W-1)Carbon dumpster now part of W-2.
• (W-5,W-6,and W-11)All trash cans and open top hoppers identified as W-13.
• (W-8)Dumpsters at Driveway Tank Farm are no longer used.
• (W-12)Former Open Top Roll-off Storage(same as 5-36)is a practice that is no longer used at this facility.
• Denotes areas not inspected because no significant exposure to stormwater
/0016N
Page 2 of 2

Summary of Significant Changes in Industrial Activities
Mallinckrodt LLC, Raleigh Pharmaceuticals Plant
2011 to Present
Year Description
2011 • Upgraded existing Bulk Acetic Acid/APAP Wastewater Tank Farm
including better materials of construction for the acetic acid tanks and
an improved containment design (S-15),
• Moved storage of 2 raw materials stored in totes, hydrogen peroxide
and aqua ammonia,from an uncovered area (S-17)to the
covered/diked Hazardous Waste Storage Pad (S-20)
• Added new Utilities Building transformer,Substation#8(S-53)
• Converted former Tar Loading/Unloading Truck Station (S-40)to PAP
Rework/temporary storage(S-54)
• Switched management of K083-contaminated rainwater from a tanker
trailer to totes(L-5)
• Began using Fire Training Area (P-1)for storing non-routine wastes and
high-strength wastewater in tankers and/or totes
• Added cartridge filters on exhausts of dust collectors to ensure broken
bags do not emit particulate onto the roofs(D-2)
2012 • Added new tank farm/containment system for several replacement
vessels used in the production of APAP including an improved
containment design (S-55)
• Added new replacement sulfuric acid tank farm including better
materials of construction for the tanks and an improved containment
design(S-56)
2013 • Added new K083 waste-combusting boiler in diked area (S-59)
• Added new stormwater trench drain between Buildings 910
and 903
• Added new procedures for collection of HVAC and chiller
cleaning water
2014 • Updated protocol for addressing potential stormwater
contamination for dumpsters and open-topped buckets
2015 . Modified protocol for valves in oil-filled transformer containment areas
to have valves remain open due to safety concerns with ponding water
under energized equipment and closing valves upon discovery of oil
leaks
• Installed additional vessels for the APAP production process, including
new containment systems including an improved containment design
(S-55)
2016 • Moved spent catalyst residues(S-17)from outdoors to the
covered/diked Hazardous Waste Storage Pad (S-20)

STORMWATER POLLUTION PREVENTION PLAN
DEVELOPMENT AND IMPLEMENTATION
CERTIFICATION
North Carolina Division of Energy, Mineral, and Land Resources - Stormwater Permitting
Facility Name: Mallinckrodt LLC
Permit Number: NCS000136
Location Address: 8801 Capital Boulevard
Raleigh, North Carolina 27616
County: USA
"I certify, under penalty of law, that the Stormwater Pollution Prevention Plan (SPPP) document and all attachments were
developed and implemented under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gather and evaluate the information required by the SPPP. Based on my inquiry of the
person or persons who manage the system, or those persons directly responsible for gathering the information, the
information gathered is, to the best of my knowledge and belief, true, accurate and complete."
And
"I certify that the SPPP has been developed, signed and retained at the named facility location, and the SPPP has been
fully implemented at this facility location in accordance with the terms and conditions of the stormwater discharge
permit."
And
"I am aware that there are significant penalties for falsifying information, including the possibility of fines and
imprisonment for knowing violations."
Sign (according to permit signatory requirements) and return this Certification. DO NOT
SEND STORMWATER POLLUTION PREVENTION PLAN WITH THIS CERTIFICATION.
Signature -,x /Am� Date 06 f 0 2,41'4 to
r 0 frlA�(
00
Print or type name of person signing above Title
Awftl
SPPP Certification 10/13