NCGNE0796_COMPLETE FILE - HISTORICAL_20180911

STORM WATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNE O � L)
DOC TYPE
El HISTORICAL FILE
DOC DATE
❑ �V) �O I �I
YYYYMMDD

RECEIVED
SEP 11 2018
Environmental
Quality
C'
DrNR-LAND QUALITY
T
Division of Energy,cMiHW.iRarid,.il�?!ig ,Resources
Land Quality Section
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
FOR AGENCY USE ONLY
Dale Received
Year Month Day
LNIl:!(;IIC1VT `I-t" .i,.
National Pollutant Discharge Elimination System application for exclusion from a Ttor
on NO EXPOSURE:
SEP.112013
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are lightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 1 22.26(g).
If approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST BE self re -certified at least annually.
Please look for information about re -certification under the No Exposure section on this page:
httpsaHdea. nc.gov/about/divisions/energy-mineral-land-resources/energy-mineral-land-perm itslstormwater-
For questions, please contact the DEMLR Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed):
Name Reagents Holdings, LLC
Contact
Street Address
City
Telephone No.
Michael Watson
4710 Sweden Road
Charlotte
704 805-4151
State NC ZIP Code 28273
Fax:
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NCGNEQ000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Reagents Holdings, LLC
Facility Contact Michael Watson
Street Address 4710 Sweden Road
City
County
Telephone No.
Charlotte
Mecklenburg
704 805-4151
3) Physical location information:
State NC ZIP Code 28273
Fax:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). From lnlarsta,e77, south on Arrowood Rd, then south on Ergand si,
then south on Sweden Rd. located approx. 800 ft. from intersection.
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes ETNo
5) Is this a Federal facility? 0 Yes E3 No
6) Latitude 35.,7.,47 Longitude -80•,52•,52 (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
a New or Proposed Facility Date operation is to begin
O Existing Date operation began acquired assests 10-31-2015
0 Renewal of existing No Exposure Certification Certification No.: NCGN
8) Was this facility or site ever covered under an NPDES Stormwater Permit? CI Yes 0No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 8 9 9
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Labortory products distribution and solution manufacturer
11) Doers this facility have any Non -Discharge permits (ex: recycle permits)?
e'No
p Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
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NCGNE0000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
0 Yes 0 No NIA
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
residuals from using, storing or cleaning industrial machinery or equipment
remain and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
c. Materials or products from past industrial activity
d. Material handling equipment (except adequately maintained vehicles)
e. Materials or products during loading/unloading or transporting activities
f. Materials or products stored outdoors (except final products intended for outside
use [e.g., new cars] where exposure to stormwater does not result in the
discharge of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels,
tanks, and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained
by the discharger
0 Yes 13 No B'N/A
p Yes
p No
IA .
❑ Yes
0 No
NIA
0 Yes
0 No
M-N//P
D Yes
© No
IA
0 Yes 0 No 1311NIA
0 Yes ❑ Na IA
i. Waste material (except waste in covered, non -leaking containers [e.g., 0 Yes
0 No Q NIA
dumpsters])
j. Application or disposal of process wastewater (unless otherwise permitted) 0 Yes
0 No W<A
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents 0 Yes
0 No IA
not otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored 0 Yes
0 No /A
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers E3 Yes 0 No OINIA
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or 0 Yes 0 No NIA .
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No M NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked
shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
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5WU-NCGNE Last revised 9/28/2016

NCGNE0000 No Exposure Certification
a. Is secondary containment provided for single above ground storage containers
❑ Yes D No
p'N/A
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored
❑ Yes d No
NIA
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund
❑Yes G No
NIA
Amendments and Reauthorization Act (SARA) waterpriority chemicals*?
d. Is secondary containment provided for hazardous substances" designated in
❑ Yes p No
a /A
40 CFR §116?
e. Are release valves on all secondary containment structures locked?
0 Yes G No
eXNIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑Yes oo O NIA
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous G Yes "0 p NIA
waste generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste OYes 0 No p NIA
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of
waste: Flammable, Toxic, Universal
How Is material stored: 55 gal drum until shipped offisite for disposal
Where is material stored: satilite stroage and central storage areas
How many disposal shipments per year: monthly (12)
Name of transport 1 disposal
vendor: Ecoflo
Vendor address: 2750 Patterson street, Greensboro, NC 27407
Footnotes to Questions 14) c. & d.
'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16) Other information: If you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
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NCGNE0000 No Exposure Certification
a. Does your facili y store used, recycled, or otherwise reclaimed pallets outside?
Yes G No 0 NIA
Store Gln{/ --s�oostc/ -off
�
b. Does your facility have coal piles on site?
p Yes 0 No M'NIA
c. Does your facility store other fuel sources outside in piles, such as wood chips,
El Yes G No e16A
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g.,
i❑ Yes 0 No OTIIA
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air Quality
��
0 Yes 0 No of NIA
Permit? Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: Hazardous Waste generator, Program: Federal EPA
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Page 5 of 7
5WU-NCGNE Last revised 9/28/2016

NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that i have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to maintain no exposure conditions and complete a Self -Recertification form at least once
each year, and if requested, provide this certification to the operator of the local municipal separate stomp sewer system
(MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of
Energy, Mineral, and Land Resources, or MS4 operator where the discharge is into the local MS4, to perform inspections
to confirm the condition of no exposure and to make such inspection reports publicly available upon request. I understand I
must keep a copy of annual re -certifications on file at the facility.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Signing: Michael J. Watson Jr.
Title: Director of Regulatory Compliance
of
(Dfie Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the NCDEQ
Regional Office prior to issuance. The Regional Office may inspect your facility for compliance
with no exposure conditions prior to that approval. The Regional Office may also inspect your
facility at any time in the future for compliance with the No Exposure Exclusion.
North Carofina 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).
There is currently no fee for a No Exposure Exclusion.
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NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
This completed application and all supporting documentation.
�A map with the location of the facility clearly marked.
❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
DEMLR - Stormwater Program
Dept. of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DEMLR Regional Office for your area.
DEMLR Regional Office Contact Information:
Asheville Office ...... [phone]
Fayetteville Office
... [phone]
Mooresville Office
. _. [phone]
Raleigh Office ........
[phone]
Washington Office
...[phone]
Wilmington Office
... [phone]
Winston-Salem ......
[phone]
Central Office .........(919)
707-9220
Page 7 of 7
SWU-NCGNE Last revised 9/28/2016

9/4/2018
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AT'
Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
Division of Energy, Mineral and Land Resources
Land Quality Section — Stormwater Permitting
National Pollutant Discharge Elimination System
ANNUAL NO EXPOSURE EXCLUSION SELF RE -CERTIFICATION
NCCNE0000
Do not submit this form to DEMLR unless requested.
For questions, please contact the DEMLR Regional Office for your area or the Central Office.
(Please print or type)
Facility's No Exposure Exclusion No. Date Completed (MM/DD/YYYY)
N I c I s I N I E 10 7 9 16 1 10 19/ 0 14/ 12 10 1 18
1) Has the facility name or owner changed? ❑✓ Yes ❑ No
(if yes, please submit a separate Name/Ownership Change Form to DEMLR located at:
http://deg.nc gov/about/divisions/energy-mineral-land-resources/energy-mineral_-land-permits/stormwater-permits/npdes-
industrial-sw )
2) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible to maintain your no exposure exclusion, and must immediately apply for a permit from DEMLR.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes Q No
residuals from using, storing or cleaning industrial machinery or equipment
remain and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
❑ Yes
0 No
c. Materials or products from past industrial activity
❑ Yes
✓❑ No
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes
❑✓ No
e. Materials or products during loading/unloading or transporting activities
❑ Yes
✓❑ No
f. Materials or products stored outdoors (except final products intended for outside
❑ Yes
❑✓ No
use [e.g., new cars] where exposure to stormwater does not result in the
discharge of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels,
❑ Yes
✓❑ No
tanks, and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained
❑ Yes
❑✓ No
by the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g.,
❑ Yes
❑✓ No
dumpsters])
j. Application or disposal of process wastewater (unless otherwise permitted)
❑ Yes
❑✓ No
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents
❑ Yes
❑✓ No
not otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored
❑ Yes
0 No
(i.e., not closed and stored upside down to prevent precipitation accumulation)
Page 1 of 3
5WU-NESR-Way2016

NCGNE0000 No Exposure Self Re -Certification
rn. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers Yes ✓D No
stored outside, has the facility had any releases in the past three (3) years?
3) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible to maintain your no exposure exclusion, and must immediately apply for a permit from DEMLR.
a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, ✓❑Yes❑ No ❑
or deterioration, or evidence of leaks? NIA
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ✓❑Yes❑ No ❑
cracks, holes, or evidence of leaks, and are drain valves maintained locked NIA
shut?
4) Secondary Containment: If you answer "No" to any of the following items, you are not eligible to
maintain your no exposure exclusion, and must immediately apply for a permit from DEMLR.
a. Is secondary containment provided for all single above ground storage ✓❑Yes❑ No ❑
containers (including drums, barrels, etc.) with a capacity of more than 660- NIA
gallons?
b. Is secondary containment provided for above ground storage containers stored ✓❑Yes❑ No ❑
in close proximity to each other with a combined capacity of more than 1,320- NIA
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund ✓❑Yes❑ No ❑
Amendments and Reauthorization Act (SARA) water priority chemicals"? NIA
d. Is secondary containment provided for hazardous substances" designated in Eyes[] No ❑
40 CFR §116? NIA
e. Are release valves on all secondary containment structures locked? ✓❑Yes❑ No ❑
NIA
Footnotes to Questions 4) c. & d.
'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment.
However, some exceptions may be made for de minimis amounts of certain substances, and/or other qualifiers, as described in the exemptions
from reporting requirements of Title Ill SARA 313 in 40 CFR §372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment.
However, some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR
§117.3.
5) Other information: If you answer "Yes" to any bf the following items, and the answer if different from
how it was answered when originally applying, you might not be eligible to maintain your no exposure
exclusion. Please contact the Division if this is the case.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ✓❑ Yes 11 No
b. Does your facility have coal piles on site? ❑ Yes Z No
c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes ✓❑No
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g., Yes ❑✓ No
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity_
e. If you answered yes to d., are those emissions permitted by an Air Quality ❑✓ Yes❑ No❑
Permit? Please specify: NIA
Page 2 of 3
SWU-NESR-3May2016

NCGNE0000 No Exposure Self Re -Certification
6) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining/maintaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
understand that I am obligated to annually self re -certify No Exposure and, if requested, submit this re -certification to
DEMLR or the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where
applicable). I understand that I must allow the North Carolina Division of Water Quality, or MS4 operator where the
discharge is into the local MS4, to perform inspections to confirm the condition of no exposure and to make such inspection
reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information provided. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information provided is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for providing false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this document and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Signing: Michael J. Watson
Title: ,_ /I Grt
9l412018
(Date Signed)
Please note: The Regional Office may inspect your facility at any time in the future for compliance
with the No Exposure Exclusion.
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).
This completed form must be kept on file at the facility for at least 5 years. Do not submit this
form to DEMLR unless requested.
Page 3 of 3
SWU-NESR-3May2016

North Carolina
Beverly Eaves Perdue
Governor
Mr. Loren Lowy
Ricca Chemical Company, LLC
308 West Fork Drive
Arlington, Texas 76012
Dear Mr. Lowy:
:=��gg
NCDENR
Department of Environment and
Division of Water Quality
Coleen H. Sullins
Director
Natural Resources
September 27, 2011
Subject: r No -Exposure Certification NCGNE07961'
Reagents Holdings, LLC
4746 Sweden Road, Charlotte, NC
Mecklenburg County
Dee Freeman
Secretar<j
The Division has reviewed your submittal of the No -Exposure Certification form for exclusion from NPDES
Stormwater Permitting. Based on your submittal and signed certification of no exposure at the above referenced
facility and the site visit on September 2, 2011, the Division is granting your conditional exclusion from permitting
as provided for under 40 CFR 122.26(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no -
exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a No -
Exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater
discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Please
refer to the information provided in the attached inspection report (last two bulleted items) highlighting two
areas at the site where exposure could occur and nullify your No -Exposure Certification.
You must self re -certify your No -Exposure status annually using the enclosed form or obtain NPDES permit
coverage for any stormwater discharges from your facility. The annual self re -certification does not need to
be submitted to DWQ unless requested.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain
environmental permits that may be required under other federal, state, or local regulations or ordinances. If
you have any questions or need further information, please contact Ms. Marcia Allocco at [phone], or
[e-mail].
Sincerely,
_�� 0 (C-,
for Coleen H. Sullins
Enclosure; No -Exposure Self Re -certification Information sheet
Annual No -Exposure Self Re -certification form
Site inspection report
RECEIVED
OCT 10 2011
information Processing Unit
DWQIBOG
Mooresville Regional office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 2.8115
Phone: [phone] ! Fax: [phone] Customer Service: 1-877-623-6748
Internet: www.ncwaterquality.org
An Fnu.l l A, inn - InRi. Rervrinri W1% P—t (nncumpr niwr
None
rthCarolina
;Vaturallil

Mr. Loren Lowy, Ricca Chenicai Company, LLC
Reagents Holdings. LLC — UCGNE0796
September 27, 2011
cc: Stormwater Permitting Unit No- Exposure Files (Brian Lowther)
Mecklenburg County Water Quality Program (R. Rozzelle) .

I
Compliance Inspection Report
Permit: NCGNE0796 Effective: Expiration: Owner: Ricca Chemical Company LLC
SOC: Effective: Expiration: Facility: Reagents Holdings LLC
County: Mecklenburg PO Box 240746
Region: Mooresville
Charlotte NC 28224
Contact Person: Kristy Bierschbach Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection pate: 09102I2011 . Enemy Time: 09:54 AM Exit Time: 10:20 AM
Primary Inspector: Marcia Allocco. Phone: [phone]
Secondary Inspector(s): Ext.2204
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: ® Compliant n Not Compliant
Question Areas:
M Miscellaneous Questions
(See attachment summary)
Page: 1

Permit: NCGNE0796 Owner -Facility: Ricca Chemical Company LLC
inspection date: 09/02/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility was visited through a new No -Exposure Certification request. Industrial activities at the facility include
laboratory product distribution and solution manufacturing.
From the Mecklenburg County GIS system it was determined that.the facility discharges stormwater to an unnamed
tributary to Kings Branch along the northern and western sides of the facility (manufacturing building).
The facility had the following industrial materials outside and exposed to stormwater:
• Two general waste dumpsters equipped with lids and drain plugs
• Two cardboard dumpsters equipped with lids
• Multiple empty 55-gallon drums that were sealed and did not show signs of leakage. However, there were signs of
historical leakage on the asphalt near the "empty" drum storage area on the northwest side of the facility (behind
manufacturing building). The staining was attributed to unauthorized cutting of drums on site by a drum recycler. The
staining did not appear to be affecting stormwater discharges from the facility. This area drains to a vegetated area
before reaching the unnamed tributary. Pictures of the staining were taken during the inspection and will be kept on file.
The following requirements were conveyed to the facility contact during the inspection:
• To obtain/maintain No -Exposure there shall be no cutting, opening, draining, or other manipulation of the "empty" drums
while stored outside the facility. Any manipulation will nullify No -Exposure and the permittee would need to apply for
coverage under an industrial stormwater permit.
• The general waste dumpster near the main storm drain inlet should be replaced since there was a gap in the metal at
the bottom weld seam. There was no liquid in the dumpster on the day of the inspection. If liquids were introduced into
the dumpster they could exit the dumpster and cause exposure. This would nullify No -Exposure Certification.
Page: 2

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins Dee Freeman
Governor Director Secretary
September 27, 2011
Mr. Loren Lowy
Ricca Chemical Company, LLC
308 West Fork Drive
Arlington, Texas 76012
Subject: No -Exposure Certification NCGNE0796
Reagents Holdings, LLC
4746 Sweden Road, Charlotte, NC
Mecklenburg County
Dear Mr. Lowy:
The Division has reviewed your submittal of the No -Exposure Certification form for exclusion from NPDES
Stormwater Permitting. Based on your submittal and signed certification of no exposure at the above referenced
facility and the site visit on September 2, 2011, the Division is granting your conditional exclusion from permitting
as provided for under 40 CFR 122.26(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no -
exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a No -
Exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater
discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Please
refer to the information provided in the attached inspection report (last two bulleted items) highlighting two
areas at the site where exposure could occur and nullify your No -Exposure Certification.
You must self re -certify your No -Exposure status annually using the enclosed form or obtain NPDES permit
coverage for any stormwater discharges from your facility. The annual self re -certification does not need to
be submitted to DWQ unless requested.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain
environmental permits that may be required under other federal, state, or local regulations or ordinances. If
you have any questions or need further information, please contact Ms. Marcia Allocco at [phone], or
at marcia.allocco(o)ncdenr.gov.
Sincerely,
for Coleen H. Sullins
Enclosure: No -Exposure Self Re -certification Information sheet
Annual No -Exposure Self Re -certification form
Site inspection report
Mooresville Rogional office One
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 North Carol Lila
Phone: [phone] Fax: [phone] Customer Service: 1.877-623-6748 I
Internet: www.nctivaterquality.org ��atla(a ly

sMr_'Lo en Lowy,,' -Ricca Chemical Company; LLC
ReUe is iold�r�gs, LLC — NCGNE0796
SS' HHS7, 201 1 `'
cc: Stormwater Permitting Unit No- Exposure Files (Brian Lowther)
Mecklenburg County Water Quality Program (R. Rozzelle)

Compliance Inspection Report
Permit: NCGNE0796 Effective: Expiration: Owner: Ricca Chemical Company LLC
SOC: Effective: Expiration: Facility: Reagents Holdings LLC
County: Mecklenburg PO Box 240746
Region: Mooresville
Charlotte NC 28224
Contact Person: Kristy Sierschbach Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09102/2011 '.Ent Time: 09:54 AM Exit Time: 10:20 AM
Primary Inspector: Marcia Alloccd Phone: [phone]
Secondary Inspector(s): Ext.2204
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: E3 Compliant rl Not Compliant
Question Areas:
0 Miscellaneous Questions
(See attachment summary)
1
Page: 1

Permit: NCGNE0796 Owner - Facility: Ricca Chemical Company LLC
Inspection Date: 09/02/2011 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility was visited through a new No -Exposure Certification request. Industrial activities at the facility include
laboratory product distribution and solution manufacturing.
From the Mecklenburg County GIS system it was determined that the facility discharges stormwater to an unnamed
tributary to icings Branch along the northern and western sides of the facility (manufacturing building).
The facility had the following industrial materials outside and exposed to stormwater:
• Two general waste dumpsters equipped with lids and drain plugs
• Two cardboard dumpsters equipped with lids
• Multiple empty 55-gallon drums that were sealed and did not show signs of leakage. However, there were signs of
historical leakage on the asphalt near the "empty" drum storage area on the northwest side of the facility (behind
manufacturing building). The staining was attributed to unauthorized cutting of drums on site by a drum recycler. The
staining did not appear to be affecting stormwater discharges from the facility. This area drains to a vegetated area
before reaching the unnamed tributary. Pictures of the staining were taken during the inspection and will be kept on file
The following requirements were conveyed to the facility contact during the inspection:
• To obtain/maintain No -Exposure there shall be no cutting, opening, draining, or other manipulation of the "empty" drums
while stored outside the facility. Any manipulation will nullify No -Exposure and the permittee would need to apply for
coverage under an industrial stormwater permit.
• The general waste dumpster near the main storm drain inlet should be replaced since there was a gap in the metal at
the bottom weld seam. There was no liquid in the dumpster on the day of the inspection. If liquids were introduced into
the dumpster they could exit the dumpster and cause exposure. This would nullify No -Exposure Certification,
Page: 2

K�
NCDENR
North Carolina Department of Environment and Natural Resources
D vision of Water Quality
Beverly Eaves Perdue Coleen H.-Sullins
Governor Director
September 27, 2011
Mr. Loren Lowy
Ricca Chemical Company, LLC
308 West Fork Drive
Arlington, Texas 76012
Subject: No -Exposure Certification NCGNE0796
Reagents Holdings, LLC
4746 Sweden Road, Charlotte, NC
Mecklenburg County
Dear Mr. Lowy:
Dee Freeman
Secretary
The Division has reviewed your submittal of the No -Exposure Certification form for exclusion from NPDES
Stormwater Permitting. Based on your submittal and signed certification of no exposure at the above referenced
facility and the site visit on September 2, 2011, the Division is granting your conditional exclusion from permitting
as provided for under 40 CFR 122.26(g), which is incorporated by reference in North Carolina regulations.
Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no -
exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a No -
Exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater
discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge. Please
refer to the information provided in the attached inspection report (last two bulleted items) highlighting two
areas at the site where exposure could occur and nullify your No -Exposure Certification.
You must self re -certify your No -Exposure status annually using the enclosed form or obtain NPDES permit
coverage for any stormwater discharges from your facility. The annual self re -certification does not need to
be submitted to DWQ unless requested.
Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain
environmental permits that may be required under other federal, state, or local regulations or ordinances. If
you have any questions or need further information, please contact Ms. Marcia Allocco at [phone], or
at marcia.allocco(cDncdenr.gov.
Sincerely,
for Coleen H. Sullins
Enclosure: No -Exposure Self Re -certification Information sheet
Annual No -Exposure Self Re -certification form
Site inspection report
Mooresville Regional office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Costomer Service: 1-877-623-6748
internet: wm.nmaterquallty.org
One
NorthCarolina

Mr. Loren Lowy, Ricca Chemical Company, LLC
Reagents Holdings, LLC - NCGNE0796
September 27, 2011
cc: Stormwater Permitting Unit No- Exposure Files (Brian Lowther)
Mecklenburg County Water Quality Program (R. Rozzelle)
r

Compliance Inspection Report
Permit: NCGNE0796 Effective: Expiration: Owner: Ricca Chemical Company LLC
SOC: Effective: Expiration: Facility: Reagents Holdings LLC
County: Mecklenburg
PO Box 240746
Region: Mooresville
Charlotte NC 28224
Contact Person: Kristy Bierschbach Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 09102/2011 Entry Time: 09:54 AM Exit Time: 10,20 AM
Primary Inspector: Marcia Allocco. Phone: [phone]
Secondary Inspector(s): Ext.2204
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: 13 Compliant U Not Compliant
Question Areas:
S2 Miscellaneous Questions
(See attachment summary)
Page: 1

Permit: NCGNE0796 Owner - Facility: Ricca Chemical Company LLC
Inspection Date: 09102/2011 inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility was visited through a new No -Exposure Certification request. Industrial activities at the facility include
laboratory product distribution and solution manufacturing.
From the Mecklenburg County GIS system it was determined that the facility discharges stormwater to an unnamed
tributary to Kings Branch along the northern and western sides of the facility (manufacturing building).
The facility had the following industrial materials outside and exposed to stormwater.-
Two general waste dumpsters equipped with lids and drain plugs
• Two cardboard dumpsters equipped with lids
• Multiple empty 55-gallon drums that were sealed and did not show signs of leakage. However, there were signs of
historical leakage on the asphalt near the "empty" drum storage area on the northwest side of the facility (behind
manufacturing building). The staining was attributed to unauthorized cutting of drums on site by a drum recycler. The
staining did not appear to be affecting stormwater discharges from the facility. This area drains to a vegetated area
before reaching the unnamed tributary. Pictures of the staining were taken during the inspection and will be kept on file.
The following requirements were conveyed to the facility contact during the inspection:
• To obtain/maintain No -Exposure there shall be no cutting, opening, draining, or other manipulation of the "empty" drums
while stored outside the facility. Any manipulation will nullify No -Exposure and the permittee would need to apply for .
coverage under an industrial stormwater permit.
• The general waste dumpster near the main storm drain inlet should be replaced since there was a gap in the metal at
the bottom weld seam. There was no liquid in the dumpster on the day of the inspection. If liquids were introduced into
the dumpster they could exit the dumpster and cause exposure. This would nullify No -Exposure Certification.
Page 2

:NCDENR ..' .
.North Carolina De�iartrnent.of En'v'ironment ano'Natural Resources
Division of Water Quality
Beverly Eaves Perdue
Colleen H. Sullins . Dee. Freeman
Governor..
Director ::.. -Secretary
September 27, 2011
Mr. Loren Lowy
.'Ricca Chemical _Company, LLC-
308 West Fork Drive'
Arlington, Texas 76012
Subiect: No -Exposure Certification NCGNE0796
-Reagents. Holdings, LLC
4746 Sweden Road, Charlotte, NC.
.'Mecklenburg County
Dear Mr. Lawy:
The' Division-has'revieviied'yoursubmittal-af the No -Exposure Certification ,form.for exclLision:frobi.NPDES. `.
Stormwater Permitting. '.Based on.your submittal and signed certification of no'exposure at the above'refere'nced
facility and the site visit on September 2, 2011, the Division is granting your, conditional exclusion from permitting
as provided for under 40 GFR 122.26(g), which is incorporated by reference in North Carolina .regulations.
Please note, that by our acceptance of your no -exposure certification, you are obligated to. maintain. no-
•;
ex posure`conditions at yourJa ijlty- :If conditions change such ttlat your facility can.no:longer qualify for a No
Exposure exclusion .you are obligated to immediately obtain NPDES permit coverage for your stormwater
discharge Otherwise, theaischarge becomes subject#o enforcement as an un-permitted,'dischard6,! Please.
.':.refer to the information provided in the attaq ',Jnspection report (East two b0l eted iterns) highlighting tv+ro ...'
areas at the site where exposure could occur.and nullify your. No-Exposure.Certification.
You must self re -certify your No -Exposure status annually using the enclosed form or obtain NPDES permit
coverage for any stormwater discharges from your facility. The annual self re-ce0cation does not need to .
be subrhitted to DWQ unless requested.
Your conditional. exclusion from permitting does not affect,'your, facility's legal. requirements to obtain.
environmental permits that may be.required under other federal, state, or.local regulators, or ordinances.
.if
you have any -questions or need further information, please contact Ms. Marcia Allocco at [phone]; or
at marcia.alloccoa-ncdenr.gov.
Sincerely,
for .Coleen H.-Sullins
Enclosure: No-Exposure'Self Re -certification Information sheet
Annual No -Exposure Self.Re-certification form
Site inspection report
Mooresville Regional Office One /� 1
Location: 610 East Center Ave., Su1e 301 Mooresville, NC 28115 NorthCarOlina
Phone: [phone] Fa)c: (704) 66MD401 Customer Service: 1.877-&0-6748 a �}
Internet www•ncwaterqua5ty.org ,/ wmrally

Compliance. Inspection Report
Permit: NCGNE0796 .Effective:
Expiration::' Owner: Rioca'Chemical Compariy LLC
SOC: Effective:
Expiration: Facility. Reagents Holdings LLC
County: Mecklenburg
.... .: . PO. Box 240746 .
Region: Mooresville
. .. :.. Charlotte NC 2$224 : ..
Contact Person: Kristy a3ierschbach :. -
- : Title: Phone: '704-554-7474 ..
Directions to Facility: ,
System Classifications: .
Primary (?RC: :....... ., .
Certification:. 'Phone:
Secondary ORC(s):.
On -Site Representative(s):
Related Permits:
:... .:: .>::..:....:. ...... .. .: :.;.. ,.
Inspection Date:. 0916212011 En
Time: 09:54'AM F-xit Time: 10:20 AM.::
Primary Inspector: Marcia Allaoco
Phone: [phone]
Ext 2204
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type:' Stormwater Discharge, No Exposure Certificate
Facility Status: ■ Compliant , n Not Compliant
Question Areas:
® Miscellaneous Questions
(See attachment summary)
Page: i

Page: 2

No Exposure Certification Questions
NGG
Permit No.:
NCSO
NCGNE NCO
Facility Name:
.J
Permit Effective:
NA
Discharges to:
Inspection Date:
r'( �)
inspection Type
CEI CSI Complaint Other
Inspector(s):
Jk
Agency:
(M.RO MCWQP
Entry Time:
ClA
Contact
Exit Time
Facility (s)
Work Days
Facility Status:
Compliant
Non -Compliant Neither
ee
�•1 C'(��C� 1,
Y
Lj—n �/�'�
Page 1 of 3 Rev. 1, 6109

No Exposure Certification Questions
If you answer "Yes" to any of these questions the facility is not eligible for No Exposure (or for question #10
mi ht not be eligible)
Yes
No
NA
1. Does the facility/site use, store, or clean industrial machinery or equipment and are those areas,
where residuals from using, storing, or cleaning industrial machinery or equipment remain exposed to
❑
❑
stormwater?
2. Is there any evidence of materials or residuals on the ground or in stormwater inlets from spills or
❑
❑
leaks?
3. Is there any evidence of materials, residuals, or products from past industrial activity (past sources of
❑
❑
contamination that have remained on site which could cause a condition of exposure)?
4. Are any materials or final products (including improperly maintained material handling equipment,
transformers, cooling towers, and air compressors) exposed to precipitation during material handling,
loading/unloading, or transporting activities, now or in the foreseeable future? [The containers, racks,
❑
❑
and other transport platforms (e.g., wooden pallets) used for the storage or conveyance of these
final products can also be stored outside, providing the containers, racks, and platforms are
pollutant -free].
5. Are any materials or products contained in open, deteriorated or leaking storage drums, barrels,
❑
❑
tanks, and similar containers exposed to precipitation, now or in the foreseeable future?
6. Are any materials or products exposed to precipitation handled or stored on roads or railways owned
❑
❑
or maintained by the discharger?
7. Is any waste material (except waste in covered, non -leaking containers, e.g., dumpsters)
❑
❑
exposed to precipitation, now or in the foreseeable future?
8. Is there application or disposal of process wastewater (unless otherwise permitted) exposed to
❑
❑
precipitation, now or in the foreseeable future?
OF
9. Is there particulate matter or visible deposits of residuals from roof stacks/vents not otherwise
❑
❑
regulated, i.e., under an air quality control permit, exposed to precipitation?
10. Does the facility have an Emissions permit with the Division of Air Quality? What pollutants does it
❑
❑
cover? Does the facility file a TRI report? What chemicals are released?
Comments:
P,-,- rw L091 �s� c�;r �r�c-tf�cfz u e� its c� c� c ht¢x i fr. s-tr rice '-�-
l- - to 4--o- A t Yl Z c -r�c� fi re t�r►cz�3n �cc� �'-
�r'
�-y�r�c
Ju
l M,_O("L'i L_� IrSio S�or-m urn � .
I
Page 2 of 3 Rev. 1, 6/09

No Exposure Certification Questions
If you answer "No" to any of these questions the facility is not eligible for No Exposure
Yes/1No
NA
11. Are drums, barrels, tanks, and similar containers exposed to precipitation labeled, tightly sealed, in
good condition, free of leaks and any deterioration, and properly stored?
❑
❑
12. Are materials stored in original containers with original labels?
❑
❑
13. Are incompatible materials stored separately?
❑
❑
14. Do drums, barrels, tanks, and similar containers exposed to precipitation meet DOT specifications,
including compatibility?
❑
❑
15. If empty containers that previously contained materials are exposed to precipitation are they
properly stored {i.e., closed and stored upside down to prevent precipitation from accumulating on top of.
the drums around the bung}?
V
❑
❑
16. For facilities or sites with exterior ASTs and drums, barrels, tanks, and similar.containers stored
outside, has the facility been free of any releases in the past 3 years?
V-1:1
El
17. Is the storage area secured to prevent unauthorized entrances?
❑
❑
18. Are exterior ASTs physically separated from and not associated with vehicle maintenance?
❑
❑
19. Are piping, flanges, valves, pumps or other equipment exposed to precipitation free of any evidence
of leaks and spills?
❑
❑
20. Are exterior ASTs and piping exposed to precipitation protected from traffic lanes to minimize
El
Elexposure?
21. Are exterior AST coatings free of signs of bubbled, cracked, damaged, or weathered coating?
❑
❑
22. Are exterior ASTs or piping/supports free of rust, pits or deterioration or evidence of leaks?
❑
❑
NK
23. Are exterior AST leak detection systems operating properly?
❑
❑
24. Are exterior AST capacity indicating equipment operating properly?
❑
❑
25. Is secondary containment provided for all exterior ASTs? Is secondary containment free of any
cracks, holes, or evidence of leaks?
❑
❑
26. Is exterior AST secondary containment enclosure free of accumulated water?
❑
❑
27. Are exterior AST secondary containment drain valves maintained locked shut?
❑
❑
28. Are drain logs being maintained for all exterior AST secondary containment?
❑
❑
29. Are spill kits available and adequate?
4
❑
❑
30. For facilities or sites with exterior ASTs and drums, barrels, tanks, and similar containers stored
outside, has the facility developed and implemented an SPCC plan, an inspection and maintenance
program, material handling procedures, and site specific loading and unloading procedures?
❑
❑
31. For facilities or sites with ASTs and drums, barrels, tanks, and similar containers stored outside, has
the facility developed and implemented an employee training program addressing spill prevention control
and countermeasures, inspection and maintenance, material handling procedures, and site specific
loading and unloading procedures?
❑
❑
Comments:
Page 3 of 3 Rev. 1, 6/09

■
l
4 .-

A, ;Division of Water Quality 1 Surface Water Protection
0NP®ENR National Pollutant Discharge Elimination System
��++.. ._ Nu,�{I
rl.�..».en � NO EXPOSURE CERTIFICATION for Exclusion
Flfvp'7•IMr-VT ylr� q, , Rr,.a:l:rn
NCGNE0000
NO EXPOSURE CERTIFICATION
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
Cenificate of Coverage
NICIGINIE
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based
on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for storm water discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DWQ must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
(outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g)..,:.:-.
You are reauired to self re-certifi your No Exposure Exclusion annuallv.. i
For questions, please contact the DWO Regional Office for your area. (Seepage 6)
(Please print or type)
1) Mailing address of owner/operator (address to which all certification correspondence will be mailed :
Name Ricca Chemical Company LLC
Contact r. a-rex1 x . r. c)W y
Street Address -3-as west Fork Drive
City Arlington State TX ZIPCode 76012
Telephone No. 8 1 7 70 1- 3 305 Fax: 8 1 7 2 7 4- 4 7 5 4
Email [e-mail] rNR
Page 1 of 7
5WU-NE=-12Aug2010 rshwate

NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Reagents Holdings L L C
Facility Contact K r i s t y B i e r s c h b a c h
Facility Street Address 4746 'Sweden 2 Sweden Road Pc> a `-014 la
City Charlotte State ZIPCode 28273 a
County Mecklenburci
Telephone No. 704 554-7474 Fax: [phone]
Email [e-mail]
3) Physical location information:
Please provide a narrative description of how to got to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection)- From Interstate 77, South on A r r o w o o d Rd,
then south on England St, then south on Sweden Rd. located app 800 ft from inte
r s e c ti(Aq t py of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands? ❑ Yes Flo
5) Is this a Federal facility? ❑ Yes KNNo
6) Latitude 3 5. 7. 4 7 Longitude - 8 0, 52, 52 (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
XX Existing Date operation began acquired assets 1 0- 1- 2 0 1 0
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes Flo
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4 digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: ;), ggc)
10) Provide a brief descriptions of the types of industrial activities and products produced at this facility:
Laboratory -products distribution and solution mmxy manufacturer
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
XXNo
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
Page 2of7
SW U-NE-12Aug2010

NCGNE0000 No Exposure Certification
Exposure Checklists (72 - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes ,qNo
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from.spills/leaks ❑ Yes >EY-No
c. Materials or products from past industrial activity ❑ Yes >UNo
d. Material handling equipment (except adequately maintained vehicles) ❑ Yes >allo
e. Materials or products during loading/unloading or transporting activities ❑ Yes �ETNo
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes >allo
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes 31TNo
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes "No
the discharger
L Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes -allo
j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes >IXNo
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes x3cNo
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored o Yes >LjcNo
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes )IT -No
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No �DQN/A
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
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14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for all single above ground storage
containers (including drums, barrels, etc.) with a capacity of more than 660-
gallons?
b. Is secondary containment provided for above ground storage containers stored
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c_ Is secondary containment provided for Title III Section 313 Superfund
Amendments and Reauthorization Act (SARA) water priority chemicals*?
d. Is secondary containment provided for hazardous substances"* designated in 40
CFR §116?
e. Are release valves on all secondary containment structures locked?
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste: Flammable
How is material stored: stored in 55 g a l
Where is material stored: Flammable s t o r a g
How many disposal shipments per year: 2 - 3
Name of transport 1 disposal vendor: US Waste
Vendor address: 4420 Jefferies Hwy,
Footnotes to Questions 14) c. & d.
❑ Yes ❑ No ZWA
❑ Yes ❑ No fal/A
❑ Yes ❑ No F,.O/A
❑ Yes ❑ No ;7xN/A
❑ Yes ❑ No :EM/A
❑ Yes XXNo
>EkYes ❑ No -
❑ Yes )EkNo
drum until shipped offsite for disposal
e room
Industries
Walterboro, SC 29488
*Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title ill SARA 313 in 40 CFR
§372.38.
**Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities
of the hazardous substances listed in 40 CFR §117.3.
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NCGNE0000 No Exposure Certification
16) Other information: if you answer "Yes" to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? RI Yes ❑ No
stored until disposed of.
b. Does your facility have coal piles on site? ❑ Yes Q No
c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes 91 No
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g., ❑ Yes 0 No
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity:
e. If you answered yes to d., are those emissions permitted by an Air Quality Permit? ❑ Yes ❑ No kkNIA
Please specify:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: Hazardous Waste gener$oQg Fam_ federal EPA
Permit:
Program.
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
Permit:
Program:
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NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities
or materials from the industrial facility or site identified in this document (except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to annually self_re-certify No Exposure and, if requested, submit the re -certification to
DWQ or the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where
applicable). I understand that I must allow the North Carolina Division of Water Quality, or MS4 operator where the
discharge is into the local MS4, to perform inspections to confirm the condition of no exposure and to make such
inspection reports publicly available upon request.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate -
Printed Name of Person Signing: Loren K . Lowy
Title: Dir ptor of Regulatory Affairs
(Signature of Applicant)
-772- Jun
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDENR Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
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).
There is -currently no fee for a No Exposure Exclusion.
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NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
This completed application and all supporting documentation.
E' A map with the location of the facility clearly marked.
❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
Stormwater Permitting Unit
Division of Water Quality
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DWO Regional Office for your area.
DWQ Regional Office Contact Information:
Asheville Office ......
[phone]
Fayetteville Office ...
[phone]
Mooresville Office ...
[phone]
Raleigh Office ........
[phone]
Washington Office ...(252)
946-6481
Wilmington Office ...
[phone]
Winston-Salem ......
[phone]
Central Office .........[phone]
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