NCG060069_ROS Request Letter to WSRO_20181210

KL E/NFEL L ER
Bright People. Right Solutions.
December 4, 2018
File: 20183812.001A I CLT18L
NCDEQ — Winston-Salem Regional Office
Department of Energy, Mineral and Land Resources
Stormwater Program
585 Waughtown Street
Winston-Salem, NC 27107
Reference: Request for Representative Outfall Status
Procter & Gamble Manufacturing - Browns Summit
NPDES General Permit COC NCG060069
Dear Sir or Madam:
On behalf of The Procter & Gamble Manufacturing Company (P&G), Kleinfelder, Inc. (Kleinfelder)
is submitting this request to obtain approval for Representative Outfall Status (ROS) for Outfall
Nos. 02 and 03 at the P&G facility located at 6200 Bryan Park Road in Browns Summit, NC.
These outfalls have similar drainage and stormwater discharge characteristics. Supporting
information for granting ROS status is provided below. Attachments to this letter include: the
completed ROS Form; two copies of the site map; and analytical results from stormwater
monitoring at both outfalls.
Outfall Descriptions
Outfall 03 is associated with Drainage Area 3 and covers a recently constructed expansion of the
facility at the southeast portion of the property. Stormwater drainage from the impervious areas
at this side of the property are conveyed to a detention basin located on the southern portion of
the property. The outlet pipe for the detention basin (Outfall 03) discharges stormwater when
water levels are high enough due to significant rainfall.
Outfall 02 is associated with Drainage Areas 2 and 2A, located at the north side of the property.
Stormwater flows to two engineered wetlands and a detention basin prior to discharge at Outfall
02.
The drainage areas for Outfalls 02 and 03 both consist of buildings, paved areas, grassy
landscaped areas, loading docks, roadways with vehicle/truck movement, and parking areas.
Both drainage areas each have one emergency generator with associated double -walled diesel
fuel tanks built into the frame of the generator which serves as tertiary containment. Drainage
Area 2 (associated with Outfall 02) also has a fueling station with a 2,000-gallon double -walled
diesel storage tank with a tertiary concrete containment area and a fire pump house that contains
a 460-gallon double -walled fuel tank.
There are no outdoor processing equipment or raw material chemical tanks at the drainage areas
associated with Outfalls 02 and 03. The raw material storage and loading areas are located at the
west side of the plant in Drainage Area 1 and discharge to Outfall 01. The attached site map
depicts the drainage areas, outfall locations, and oil storage locations.
KLEINFELDER 9009 Perimeter Woods Drive, Suite H, Charlotte, NC 28216 p 1704.598.1049 f 1704.598.1050

Analytical Sampling Results
Results for sampling for Outfalls 02 and 03 both indicate pollutant levels below benchmarks as
provided in the attached DMR and laboratory analysis. A summary that compares sampling
results is provided below.
Parameter
Benchmark
Outfall02
collected 10-10-18
Outfall03
collected on 10-15-18
COD
120 m /I
25 m /l
<5 m /l
Hydrocarbon Oil & Grease
30 m /I
<5 mg/1
<5 mg/1
Total Suspended Solids
100 m /I
6.53 m /L
5.4 m /L
Thank you in advance for your expeditious response to this request for approving the ROS for
Outfalls 02 and 03. If you have any questions or require additional information, please contact
Ms. Christine Brenk with Kleinfelder at 704.378.9175 or Ms. April Haley of Procter & Gamble at
336.207.5348.
Respectfully submitted,
KLEINFELDER, INC.
Thomas Sipe Christine K. Brenk, CHMM
Staff Professional II Principal Professional
Cc: Ms. April Haley, Procter & Gamble Site Environmental Leader
Attachments:
ROS Form
Stormwater Analytical Results for Outfalls 02 and 03
Site Drainage map
20183812.001A I CLT18L Page 2 of 2 December 4, 2018
Copyright 2018 Kleinfelder

Division of Energy, Mineral & Land Resources
Stormwater Program
National Pollutant Discharge Elimination System
Environmental REPRESENTATIVE OUTFALL STATUS (ROS)
nr rnlifii
xLOULN 1 MJKM
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
If a facility is required to sample multiple discharge locations with very similar stormwater discharges, the
permittee may petition the Director for Representative Outfall Status (ROS). DEQ may grant Representative
Outfall Status if stormwater discharges from a single outfall are representative of discharges from multiple
outfalls. Approved ROS will reduce the number of outfalls where analytical sampling requirements apply.
If Representative Outfall Status is granted, ALL outfalls are still subject to the qualitative monitoring
requirements of the facility's permit —unless otherwise allowed by the permit (such as NCG020000) and DEQ
approval. The approval letter from DEQ must be kept on site with the facility's Stormwater Pollution
Prevention Plan. The facility must notify DEQ in writing if any changes affect representative status.
For questions, please contact the DEQ Regional Office for your area (see page 3).
(Please print or type)
1) Enter the permit number to which this ROS request applies:
Individual Permit (or) Certificate of Coverage
N I C I S I N I c G 0 6 0 0 6 19
2) Facility Information:
Owner/Facility Name
Facility Contact
Street Address
City State ZIP Code
County E-mail Address
Telephone No. Fax:
3) List the representative outfall(s) information (attach additional sheets if necessary):
Outfall(s)
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s)
is representative of Outfall(s)
Outfalls' drainage areas have the same or similar activities?
Outfalls' drainage areas contain the same or similar materials?
Outfalls have similar monitoring results?
Outfall(s)
is representative of Outfall(s)
X Yes ❑ No
XYes ❑ No
XYes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ Yes ❑ No
❑ No data*
❑ No data*
Outfalls' drainage areas have the same or similar activities? ❑ Yes ❑ No
Outfalls' drainage areas contain the same or similar materials? ❑ Yes ❑ No
Outfalls have similar monitoring results? ❑ Yes ❑ No ❑ No data*
*Non-compliance with analytical monitoring prior to this request may prevent ROS approval. Specific
circumstances will be considered by the Regional Office responsible for review.
Page 1 of 3
SWU-ROS-2009 Last revised 12/30/2009

Representative Outfall Status Request
4) Detailed explanation about why the outfalls above should be granted Representative Status:
(Or, attach a letter or narrative to discuss this information.) For example, describe how activities and/or
materials are similar.
5) Certification:
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record,
report, plan, or other document filed or required to be maintained under this Article or a rule implementing this
Article; or who knowingly makes a false statement of a material fact in a rulemaking proceeding or contested case
under this Article; or who falsifies, tampers with, or knowingly renders inaccurate any recording or monitoring device
or method required to be operated or maintained under this Article or rules of the [Environmental Management]
Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed
ten thousand dollars ($10,000).
hereby request Representative Outfall Status for my NPDES Permit. I understand that ALL outfalls are still
subject to the qualitative monitoring requirements of the permit, unless otherwise allowed by the permit
and regional office approval. I must notify DEQ in writing if any changes to the facility or its operations
take place after ROS is granted that may affect this status. If ROS no longer applies, I understand I must
resume monitoring of all outfalls as specified in my NPDES permit.
certify that I am familiar with the information contained in this application and that to the best of my
knowledge and belief such information is true, complete, and accurate.
Printed Name of Person Signing:
Title:
(Signature of Applicant)
(Date Signed)
Please note: This application for Representative Outfall Status is subject to
approval by the NCDEQ Regional Office. The Regional Office may inspect your
facility for compliance with the conditions of the permit prior to that approval.
Final Checklist for ROS Request
This application should include the following items:
❑ This completed form.
❑ Letter or narrative elaborating on the reasons why specified outfalls should be granted representative
status, unless all information can be included in Question 4.
❑ Two (2) copies of a site map of the facility with the location of all outfalls clearly marked, including the
drainage areas, industrial activities, and raw materials/finished products within each drainage area.
❑ Summary of results from monitoring conducted at the outfalls listed in Question 3.
❑ Any other supporting documentation.
Page 2 of 3
SWU-ROS-2009 Last revised 12/30/2009

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Brown Summit, NC 27214
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Client Sample ID: North Pond
Lab Sample ICE. 67526-01
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Collection Date: 10/1012018 8.00
Parameter
Method
Result
Units
Rep Limit Ana€ s Analysis Date/Time
COD
EPR410.4
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EPA 1664 Revision Mika Gel
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EE 10/11/2018
Total Suspended Solids (TSS)
8M 2540 D-1997
6.53
mg1L
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AW 10/1612018
r:l€ent Sample 10: South pond
Lab Sample ID:
67526-02
Proctor & Gamble
Collection Date:
10/10/2018 9:00
Parameter
Method
Result
Units
Rep Limit Analyst Analysis DaterTime
COD
EPA 410.4
<5
mg/L
5
HW 10/11/2018
Hydrocarbon O&G
EPA 1664 Revision B/S€l€ca Gel
<6
mg/L
5
EE 10/12/2018
Total Suspended Solids (TSS)
SM 2540 D-1997
<5.0
mg/L
5
AW 10/1512018
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P.O. Box 473 106 Short Street Kernersvllle, North Carolina 27284 Tel: [phone] Fax; 336-996.0326 www.randatabs.com Page 1

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RESEARCh & ANALyTICAI
LABORATORIES, INC.
For: Proctor & Gamble
6200 Bryan Park Road
Brown Summit, NC 27214
Attn: April Haley
Report of Analysis
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Parameter Method Result Units Rep Limit Analyst Analysis Date/jime
COD EPA 410.4 <5 mg/L 5 HW 10117/2018
Hydrocarbon O&G EPA 1664 Revision B/Silica Gel <5 mg/L 5 EE 10116/2018
Total Suspended Solids (TSS) SM 2540 D-1997 5.4 mg/L 5 AW 10/15/2018
NA = not analyzed
P.O. Box 473 106 Short Street Kernersville. North Carolina 27284 Tel: [phone] Fax: [phone] www.randalabs.com Page 1
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NOTES:
1. SITE PLAN PROVIDED BY PROCTOR
& GAMBLE CO.
The information included on this graphic representation has been compiled from a variety of sources and is
subject to change without notice. Kleinfelder makes no representations or warranties, express or implied,
as to accuracy, completeness, timeliness, or rights to the use of such information. This document is not
intended for use as a land survey product nor is it designed or intended as a construction design document.
The use or misuse of the information contained on this graphic representation is at the sole risk of the party
using or misusing the information.
Tml Ills 111 Ili
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COMPACTOR/RECYCLE
DUMPSTER
BOILER ROOM
EMERGENCY
GENERATOR
DUMPSTER
TWO (2) GANTREZ
TWO
GENERATORS REEDY FORK RANCH
5,000-GALLON MINERAL
OIL TANK (APDO) 500-GALLON MINERAL
OIL TANK (APDO)
DIESEL STORAGE AND
FUELING STATION
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PROJECT NO. 20191457
\ DRAWN BY NCD/NL
KL E/NFEL DER CHECKED BY CB
Bright People. Right Solutions. DATE: 12-03-2018
REVISED:
WETLANDS--
ETLANDS
LEGEND
PROPERTY BOUNDARY
DRAINAGE AREA 1
DRAINAGE AREA 1A
DRAINAGE AREA 2
DRAINAGE AREA 2A
DRAINAGE AREA 3
O OUTFALLS
-i STORMWATER FLOW DIRECTION
FIGURE
SITE DRAINAGE MAP
PROCTOR & GAMBLE CO. 2
6200 BRYAN PARK ROAD
BROWNS SUMMIT, NC

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(SKIN CARE DISPENSING) ---
SKIN CARE
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12, 60-GALLON OIL DISPENSING
(WAREHOUSE #1)
NOTES:
1. SITE PLAN PROVIDED BY PROCTOR
& GAMBLE CO.
The information included on this graphic representation has been compiled from a variety of sources and is
subject to change without notice. Kleinfelder makes no representations or warranties, express or implied,
as to accuracy, completeness, timeliness, or rights to the use of such information. This document is not
intended for use as a land survey product nor is it designed or intended as a construction design document.
The use or misuse of the information contained on this graphic representation is at the sole risk of the party
using or misusing the information.
Tml Ills 111 Ili
n
COMPACTOR/RECYCLE
DUMPSTER
BOILER ROOM
EMERGENCY
GENERATOR
DUMPSTER
TWO (2) GANTREZ
TWO
GENERATORS REEDY FORK RANCH
5,000-GALLON MINERAL
OIL TANK (APDO) 500-GALLON MINERAL
OIL TANK (APDO)
DIESEL STORAGE AND
FUELING STATION
0 450 900
SCALE: 1" = 450' SCALE IN FEET
t
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TOTAL AREA = 288.132 ACRES
OUTFACE 2 wErLAN
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I
- —
A S — a_
__—WE 11 roc
�� HARDY'S MILL POND
FIRE PUMP
WAREHOUSE
EMERGENCY
GENERATOR
PROJECT NO. 20191457
\ DRAWN BY NCD/NL
KL E/NFEL DER CHECKED BY CB
Bright People. Right Solutions. DATE: 12-03-2018
REVISED:
WETLANDS--
ETLANDS
LEGEND
PROPERTY BOUNDARY
DRAINAGE AREA 1
DRAINAGE AREA 1A
DRAINAGE AREA 2
DRAINAGE AREA 2A
DRAINAGE AREA 3
O OUTFALLS
-i STORMWATER FLOW DIRECTION
FIGURE
SITE DRAINAGE MAP
PROCTOR & GAMBLE CO. 2
6200 BRYAN PARK ROAD
BROWNS SUMMIT, NC