NCG060286_COMPLETE FILE - HISTORICAL_20141121

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/V CcO(a Oa K
DOC TYPE
�. HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ cpO)v IIa'
YYYYMMDD

I CDENR
North Carolina Department of Environment and Natural Resources
Pat McCrory
Governor
Mr. Tim Yost
Engineering and Facilities Manager
Kellogg Company
One Quality Lane
Cary, North Carolina 27513
Dear Mr. Yost:
John E. Skvada, III
. Secretary
November 21, 2014
Subject: Kellogg's — Austin Quality Foods
NPDES STORMWATER PERMIT NCG060286
Wake County
On November 18, 2014, Dave Parnell, of the Raleigh Regional Office of the North Carolina
Division of Energy, Mineral and Land Resources (DEMLR), conducted a compliance evaluation
inspection (CEI) at the above referenced facility. The site lies in the watershed of an unnamed
tributary (UT) to Crabtree Creek, Class C, NSW waters, which lies in the Neuse River Basin.
The following observations were noted during the NCG060286 DEMLR inspection:
This facility is a mass produced cracker baking and packaging facility, which does not conduct
vehicle maintenance on site. Thank you for your assistance, as well as the assistance of Stacy
Hardy and Joseph Atkinson, during the inspection. It was appreciated. The inspection began
in a conference room, where a thorough review of the Stormwater Pollution Prevention Plan;
as well as, the qualitative and analytical monitoring results, was conducted. All aspects of the
Stormwater Pollution Prevention Plan are being implemented. Employee training was well
documented, as were significant spills (0) which occurred during the last three years.
Analytical and Qualitative monitoring data were reviewed and found to be in order and
compliant with the NPDES Stormwater Permit. The SPPP is reviewed and updated annually.
Following the monitoring data review, the Stormwater Discharge Outfalls (SDO) were
observed. You and your staff are knowledgeable, with respect to the sample sites at all of the
four SDO. It was noted that sampling is conducted by your consultant, who was not present
during this CEI.
Division of Energy, Mineral, and land Resources
Energy Section • Geological Survey Section - Land Quality Section
1612 Mail Service Center, Raleigh, North Carolina 27699-1612.919-707-92001 FAX: [phone]
512 North Salisbury Street, Raleigh, North Carolina 27604 - Internet: http://Dortal.ncdenr.org/webAr/
An Equal Opportunity 1 Affirmative Action Employer — 50% Recycled 110% Post Consumer Paper

Thank you for your diligence in carrying out the requirements of your NPDES Stormwater
Permit Should you have questions regarding these matters, please contact Dave Parnell at
[phone] or [e-mail].
Sincerely,
Holley, Jr., PE, CPESC
Regional Office
cc: Stormwater Permitting Program Files - with attachment
DEMLR Raleigh Regional Office Files - with attachment

Compliance Inspection Re art
Penult: NGG060286 Effective: 12/01/12 Expiration: 10/31/17 Owner: Austin Quality Foods, Inc.
SOC: Effective: Expiration: Facility: Austin Quality Foods, Inc. (Keebler Company)
County: Wake One Quality Ln
Region: Raleigh
Cary NC 27513
Contact Person: Anthony Depletro Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Represbntative(s):
Related Permits:
Inspection Date: 11/18/2014
Primary Inspector: David R Parnell
Secondary Inspector(s):
Certification:
Phone:
Entry Time: 10:30AM Exit Time: 12:30PM
Phone: [phone]
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Food/Tobacco/SoapsJCosmeticatPublic Warehousing Stormwater Discharge COC
Facility Status: Compliant Not Compliant
Question Anus:
Storm Water
(See attachment summary)
Page: 1

permit NCG060286 Owner • Facilfly:Austin Duality Foods, Inc.
Imp Wflon Dana: 11/1812014 Inspection Type: Compliance Evaluation Reason for Visit Routine
Inspection Summary:
Page: 2

permit: NCG080288 Owner - Facility: Austin Quality Foods, Inc.
Inspection Date: 11/1812014 Inspection Type: Compliance Evaluation Reason for Vlsit: Routine
5torrnwater Pollution Prevention Plan
Yes No NA NE
Does the site have a Stormwater Pollution Prevention Plan?
0 ❑ ❑ ❑
# Does the Plan include a General Location (USGS) map?
E ❑ ❑ ❑
# Does the Plan include a "Narrative Description of Practices?
■ ❑ ❑ ❑
# Does the Plan include a detailed site map including outfall locations and drainage areas?
N ❑ ❑ ❑
# Does the Plan include a list of significant spills occurring during the past 3 years?
❑ ❑ ❑
# Has the facility evaluated feasible altematives to current practices?
N ❑ ❑ ❑
# 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)?
❑ ❑ ❑
# Is the Plan reviewed and updated annually?
❑ ❑ ❑
# Does the Plan include a Stormwater Facility Inspection Program?
E ❑ ❑ ❑
Has the Stomawater Pollution Prevention Plan been implemented?
E ❑ ❑ ❑
Comment: Updated SPPP met all requirements of the NPDES Permit.
Qualitative Monitoring
Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? N Cl 1111
Comment:
Anahrtical Monitoring Yes No NA WE
Has the facility conducted its Analytical monitoring? ❑ ❑ ❑
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? ❑ ❑ ❑
Comment: Compliant with permit.
Permit and Outfails
Yes No NA HE
# Is a copy of the Permit and the Certificate of Coverage available at the site? E ❑ ❑ ❑
# Were all outfalls observed during the inspection? 0 ❑ ❑ ❑
# if the facility has representative outfail status, is it properly documented by the Division? ❑ ❑ E ❑
# Has the facility evaluated all illicit (non stomlwater) discharges? 0 ❑ 1111
Comment: Discussed past exceedences of COD - possible reason - pollen. Has not had reason to
advance to Tier 2.
Page: 3

4
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Steve Surovec
Austin Quality Foods, Inc.
One Quality Lane
Cary, NC 27513
Dear Permittee:
Division of Water Quality
Charles Wakild, P. E.
Director
December 4, 2012
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Austin Quality Foods, Inc. (Keebler Company)
COC Number NCGO60286
Wake County
In response to your renewal application for continued coverage under stormwater General Permit NCG060000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COC)
• A copy of General Permit NCGO60000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E} Also, please note that Tier 3 Actions in Part II of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://portal.ncdenr.org/web/wq/ws/su/npdessw (click an 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Servioe Center. Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Ralegh, North Carolina 27604
Pho ,e: 919 807-63001 FAX: 9 = 9-1307-6492
Intemet: www.ncwate uali .orq
An • ;rai uppo::unity 1 AfiianaGve A. lion Emplo er
NorthC'aj-olina
;Vatl4rall.,

Steve Surovec
December 4, 2012
Page 2of2
Some of the changes include:
Part II:
• Section A: The Stormwater Pollution Prevention Plan (SPPP) section, if applicable, has been updated
to the most current language of our permits. Additional conditions for specific industry sectors have
been added to the SPPP requirements in some cases.
• Sections 8, C: Failure to perform analytical stormwater monitoring may result in the Division requiring
that the permittee begin a monthly sampling scheme.
• Sections 6, C: A lower TSS benchmark of 50 mg/1 for HQW, ORW, PNA and Tr Waters applies to these
more sensitive waters.
• Sections B, C. The monitoring parameter Oil & Grease (O&G) has been replaced.by the parameter
Total Petroleum Hydrocarbons (TPH) for vehicle maintenance areas, and in some cases, other
analytical monitoring requirements.
• Sections 8, C, D: Inability to sample due to adverse weather must be recorded in the SPPP, or in
separate on -site records if your General Permit does not require an SPPP. Adverse weather is defined
in the "Definitions" section of the permit.
• Sections 8, C. The term "Representative Storm Event" has been replaced by "Measurable Storm
Event." A measurable storm event is defined in the permit.
• Section D: If the permittee fails to respond effectively to problems identified by qualitative
monitoring, DWQ may require the permittee to perform corrective action.
Please review Parts III and IV to understand the Standard Conditions of your new NPDES General Permit,
including Compliance and Liability, Reporting, Monitoring and Records requirements; Operation and
Maintenance obligations; and Definitions. Please note that all samples analyzed in accordance with the terms
of this permit must be submitted to the Division on Discharge Monitoring Report (DMR) forms available on
the Stormwater Permitting Unit's website above. DMR forms must be delivered to the Division no later than
30 days from the date the facility receives the sampling results from the laboratory. Also note that existing
permittees do not need to submit a renewal request prior to expiration unless directed by the Division.
Your coverage under the General Permit is transferable only through the specific action of DWQ. This permit
does not affect the legal requirements to obtain other permits which may be required by DENR, nor does it
relieve the permittee from responsibility for compliance with any other applicable federal, state, or local law,
rule, standard, ordinance, order, judgment, or decree. If you have any questions regarding this permit
package, please contact the Division's Stormwater Permitting Unit at [phone].
Sincerely,
for Charles Wakild, P.E.
cc: DWQ Central Files
Stormwater Permitting Unit Files
Raleigh Regional Office

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060286
STORM WATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Austin Quality Foods, Inc.
is hereby authorized to discharge stormwater from a facility located at:
Austin Quality Foods, Inc. (Keebler Company)
One Quality Ln
Cary
Wake County
to receiving waters designated as Crabtree Creek, a class C;NSW waterbody in the Neuse River
Basin in accordance with the effluent limitations, monitoring requirements, and other
conditions set forth in Parts 1, I1, Ill, and IV of General Permit No. NCG060000 as attached.
This certificate of coverage shall become effective December 4, 2012.
This Certificate of Coverage shall remain in effect for the duration of the General Permit
Signed this 4th day of December, 2012.
for Charles Wakild, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

of w 7-
GO
r_
O `C
June 10, 2005
Mr. Matt Elshenawy
Austin Quality Foods, Incorporated
One Quality Lane
Cary, NC 27513
Michael F. Easley, Governor
William G_ Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Alan W_ Klimek, P.E. Director
Division of Water Quality
Subject: General Permit No. NCG060000
Austin Quality Foods Inc. (Keebler
Company)
COC No. NCG060286
Wake County
Dear Mr. Elshenawy:
In accordance -with your application for a discharge permit received on March 24, 2005,
we are forwarding herewith the subject certificate of coverage to discharge under the subject
state --- NPDES general permit. This permit is issued pursuant to the requirements of North
Carolina General Statute 143-215.1 and the Memorandum of Agreement between North Carolina
and the US Environmental Protection Agency dated May 9, 1994 (or as subsequently amended).
Please take notice that this certificate of coverage is not transferable except after notice to
the Division of Water Quality. The Division of Water Quality may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be
required by the Division of Water Quality or permits required by the Division of Land
Resources, Coastal Area Management Act or any other federal or local governmental permit that
may be required.
If you have any questions concerning this permit, please contact Bethany Georgoulias at
telephone number [phone] ext. 529.
Sincerely,
ORIGINAL SIGNED By
BRADLEY BENNET'T
Alan W. Klimek, P.E..'
cc: Raleigh Regional Office
Central Files
Stormwater-Permitting-UUnit�Files
ro ` Carolina
Aatura!!y
North Carolina Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 Phone [phone] Customer Service
Internet h2o.enr.state.nc.us 512 N. Salisbury St. Raleigh, NC 27604 FAX [phone]
An Equal OpportunilylAffirmat ve Action Employer — 50% Recycle&10% Post Consumer Paper

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG060000
CERTIFICATE OF COVERAGE No. NCG060286
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Austin Quality Foods, Incorporated
is hereby authorized to discharge stormwater from a facility located at
Austin Quality Foods, Inc. (Keebler Company)
One Quality Lane
Cary, NC
Wake County
to receiving waters designated as an unnamed tributary (UT) to Crabtree Creek, a class C-NSW
water in the Neuse River Basin in accordance with the effluent limitations, monitoring
requirements, and other conditions set forth in Parts 1, II, III, IV, V, and VI of General Permit
No. NCG060000 as attached.
This certificate of coverage shall become effective June 10, 2005.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day June 10, 2005. r-
rt
ORIGINAL SIGNED BY;,"
BRADLEY BENNETT ►'
for Alan W. Klimek, P.E., Director
Division of Water Quality
By the Authority of the Environmental Management Commission

i
LOCATION MAP:
Latitude: 35°49'3" NCG060286
Longitude: 78'48'35"
County: Wake, NC Austin Qualify Foods,
Stream Class: C-NSW Inc. (Keebler Company)
Receiving Stream: UT to Crabtree Creek
Subbasin: 03-04-02 (Neuse River Basin)
Cffotth fI MALE ABOVE

- NCG060286
Austin Quality Foods, Inc.
rev. 6/9/05
April 25, 2005
B. Georgoulias
Summary
This facility submitted a Notice of Intent to be covered under General Permit NCG060000
(Food and Kindred Products). This facility manufactures bread and baked products for
wholesale. The stormwater discharge drains to a UT to Crabtree Creek, a Class C-NSW
water in the Neuse River Basin. This facility is located in Wake County, handled by the
Raleigh Regional Office.
Application review
a) The permit application has been signed and sufficiently completed. Yes.
b) The SIC code accurately describes this facility's activities and is covered by this
general permit. Yes. SIC: 2052 (Bakery Products: Cookies & Crackers)
c) Does this facility have other permits? No.
d) Hazardous Waste Activities? Yes. Per facility contact M. Elshenawry
Facility is a Small Quantity Generator (<1000 kg/mo.) and stores materials
such as obsolete or empty ink cartridges (used to spray packaging with labels,
barcodes, etc.) and chemicals used in the facility's lab for testing products and
packages. These materials are stored in a locked haz mat building with three
compartments, each of which have containment in the bottom of the room.
Stored until enough waste accumulated for a disposal shipment, which is only
about once a year.
e) Regional Office input requested: 4/25/2005 (via e-mail to RRO DWQ.)
RG Approval received: 06/09/2005 (via e-mail from J. Garrett)
g) Application approved? Yes.

R : [F,�'NOI for Austin Quality Foods (Keebler), Cary, NCI
Subject: Re: [Fwd: NOI for Austin Quality Foods (Keebler), Cary, NC]
From: Judy Garrett <[e-mail]>
Date: Thu, 09 Jun 2005 13:26:29 -0400
To: Bethany Georgoulias <bethany. georgoulias@ncmail. net>
No. We have no objections to issuance of a COC to Austin Foods.
Judy
Bethany Georgoulias wrote:
Hi Judy,
Just wanted to check on the status of this one; does the region have any concerns
with issuing a COC for this site? Thanks,
Bethany Georgoulias
Environmental Engineer
NC DENR DWQ
Stormwater Permitting Unit
[phone], ext. 529
[e-mail]
Ken Schuster wrote:
Judy can you contact Bethany concerning this site. thks.
Bethany Georgoulias wrote:
Hi Ken,
Just wanted to check if there was a contact in the RRO for this site/NOI
approval. I got a call back from the contact, and I don't think there are
any issues with the hazardous waste materials (ink for spraying packages,
chemicals for testing products) --all are stored in areas with secondary
containment.
Thanks,
BG
-------- Original Message --------
Subject: NOI for Austin Quality Foods (Keebler), Cary, NC
Date: Mon, 25 Apr 2005 13:38:00 -0400
From: Bethany Georgoulias <[e-mail]>
To: Ken Schuster <[e-mail]>
Hi Ken,
One more NOI for NCG060000 in your region (and just down the road). We have
an application from Austin Quality Foods (Keebler Company) in Cary for
coverage and wanted to get input from the Raleigh Office; please forward to
the appropriate staff member. Here's the info. on this facility:
NOI for COC #NCG060266
Austin Quality Foods--Keebler Company (Wake Co.)
One Quality Lane
Cary, NC 27513
contact: Matt Elshenawy
1 of 2 6/9/2005 1:33 PM

Re: [Fwd: NOI for Austin Quality Foods (Keebler), Cary, NC]
tei. (local) 677-3222
Main activity: Manufactures cookies and crackers from raw ingredients.
Discharge is to: UT to Crabtree Creek (Class C-NSW) in the Neuse Basin
Other permits: None listed
Hazardous waste: This facility is a small quantity hazardous waste generator
and lists toxic and flammable liquids, which are stored in a hazardous waste
storage building. Only one shipment per year.
I phoned the contact to follow up on the types of haz. waste stored, etc. and
am waiting for a return call.
Does the Regional Office have any concerns with issuing a COC for this
facility?
Also, I plan on attending the meeting with Paul tomorrow afternoon, so I will
see you and Myrl then!
2 of 2 6/9/2005 l :33 PM

r + I
�� 1■ 1 1
V 1 1 1
1 5 i
.-......�.....�1r.-...-�.�.� • i.+.Wr , _ _ �._t�����. _1 �. __.�{____- 1 ��s. �.� __ � ..T-A. - -i- •_.•_ice_ _I .... i-i_ r_ _ ��-._ til. _ _
�• r y �i t i �• r E � �k t � y 1 { � f

f �
�
k
+ 1
1
f i
t .

3800 Barrett Dr, Raleigh C 27609 to 1 Quality Ln, Cary, NC 27513 - Google Maps Page I of 1
-r�bu ® -
Directio t Quality Ln, Cary, NC 27513
Gooslel 9 7 -7, 3 Z v�
P3800 Barrett Dr, Raleigh, NC 27609
1- Head west on Barrett Dr toward Haworth Dr go 0-1 mi
total 0.1 mi
2. Turn right onto Six Forks Rd go 0.7 mi
About 2 mins total 0.8 mi
3. Turn left to merge onto 1-440 W go 4.2 mi
® About 5 mins total 5.0 mi
4. Take exit 4B toward 1-40 WIRDU International Airport/Durham go 0.4 mi
total 5.4 mi
5. Merge onto Wade Avenue
About 3 mins
""" 6. Merge onto 1-40 W
-. About 1 min
7. Take exit 287 for Harrison Ave toward Cary
8..Tum left onto N Harrison Ave (signs for Weston)
About 1 min
�f 9. Slight right toward Weston Pkwy
10. Slight right onto Weston Pkwy
_--- About 4mins-
11. Turn left onto Sheldon Dr
i2. Turn left onto Quality Ln
Partial restricted usage road '
Destination will be on the right
About 54 secs
B� 1 Quality Ln, Cary, NC 27513
go 2.8 mi
total 8.1 mi L
go 1.2 mi
total 9.3 mi
- - --- - - - go0.2mi
total 9.5 mi
go 0.5 mi
total 10.1 mi
go 387 ft
total 10.1 mi
go 3.0 mi
L� total 13.1 mi
- go 0.1 mi
total 13.2 mi
J go 0.2 mi
total 13.4 mi
These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause
conditions to differ from the map results, and you should plan your route accordingly. You must obey all signs or notices regarding your
route.
Map data 02014 Google
I Directions weren't right? Please find your route on maps.google.com and click "Report a problem". at the bottom left. I
httpsalmaps.google.com/maps?"&source=s-d&saddr=3800+Barrett+Drive,+Raleigh,+... 11 / 13/2014

Valentine, Thad
From: Valentine, Thad
Sent: Thursday, October 19, 2017 1:29 PM
To: 'Greg Kanellis'
Subject: RE: [External] Kellogg's Cary, NC Storm Water Tier 3 Response Notification (NCG060286)
Greg
Thanks for the benchmark exceedance notification which prompted your Tier 3 response and your assessment of the
bench mark exceedance issue at your facility located at One Quality Lane in Cary, NC. Your assessment of the issue
seems sound and I agree with your course of action. Please contact me once the November sample has been taken and
results are back so we can discuss the results and further actions, if any, to take going forward. Your notification is
documented and I will include it in the file for your NCG060286 permit.
From: Greg Kanellis[mailto:[e-mail]]
Sent: Thursday, October 19, 2017 12:02 PM
To: Valentine, Thad <[e-mail]>
Cc: Depietro, Anthony ([e-mail]) <[e-mail]>; Matt Bramblett
<M [e-mail]>
Subject: [External] Kellogg's Cary, NC Storm Water Tier 3 Response Notification (NCG060286)
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you verify that the
attachment and content are safe. Send all suspicious email as an attachment to [e-mail].
Thad,
Per our phone conversation, an exceedance of the benchmark value for COD was detected in a sample from one of the
outfalls (SW01) during our recent semi-annual sampling event on October 9, 2017. The benchmark value for COD has
been exceeded four times at this outfall throughout the permit term prompting a Tier 3 response. This email serves as
completing the notification requirement for the Tier 3 response. As discussed, we believe we have identified the source
of the COD benchmark value exceedance as HVAC condensate drains that vent production operations at the
facility. Recently, these drains have been hard -piped to the sanitary sewer. The COD exceedance appears to be
attributed to residual biological growth in the flow path to the outfall that is attributed to the HVAC condensate
formerly discharged to this outfall. Kellogg's proposes to clean the outfall and flow path of residual biological growth
and resample the outfall for COD in November 2017. You will be copied on the DMR submittal with the November 2017
results. If the COD result is below the benchmark value, we propose to resume semi-annual monitoring. Please respond
with receipt of this email and approval of the proposed approach. Please contact me with any questions.
Best regards,
Greg
Gregory Kanellis, PE Senior Project Engineer
Hart & Hickman, PC 13334 Hillsborough Street i Raleigh, NC 27607
Direct 919-723-2512 1 Mobile [phone] Main 919-847-4241
www.harthickman.com
hart hickman
SMARM UNWiDNME►TAL SOLUTKM