NCGNE0523_COMPLETE FILE - HISTORICAL_20090220

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNED5a3
DOC TYPE
EX HISTORICAL FILE
DOC DATE
❑ Do � v
YYYYMMDD

Affl'_K;W�
Na
NCDENR
North Carolina Department of Environment an RtnI
esources�
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins - � Vee:Freewan
Governor Director Secretary
February 20, 2009 F E B 2 4 2008
Mr. William Lefler I���l
Pratt industries Dl�l�-Surface Water Rofe 1,'�n
185 Deer Ridge Drive
Statesville, NC 28625
Subject: Denial of No -Exposure Certification NCGNE0523
Pratt Industries
185 Deer Ridge Dr., Statesville, NC 28625
Iredell County
Dear Mr. Lefler:
The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES Stormwater
Permitting form, which we received on April 30, 2008. The Division is unable to concur with your certification of no
exposure.
Based on an inspection of your facility, Mooresville Regional Office staff found that materials on your site either are
exposed, or have the potential to be exposed. DWQ cannot grant your requested exemption from permit coverage
when materials are exposed or have the potential to be exposed. Please continue to operate under the General Permit
NCG050000,
If you have any questions or need further information, please contact Robert Patterson at [phone], or through
email at [e-mail].
Sincerely,
for Coleen H. Sullins
cc: Mooresville Regional Office -Michael Parker
Stormwater Permitting Unit — No Exposure Files
NCGO50361 Permit File
Wetlands and Stormwater Branch
1617 Mail Service Center, Ralegh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone: [phone] FAX: [phone] Customer Service: 1-877-623-6748
Intemei: www.ncwaterquality.org
An Equal Opportunity L Affirmative Action Employer
NoirthCarolina
Naturally

LLL—
Ath
NC®ENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Quality
Coleen H. Sullins
Director
February 16, 2009
Mr. Terry Devine, Process Improvement Manager
Pratt Industries --- Corrugating, Division
185 Deer Ridge Drive 4
Statesville, North Carolina 28625
Subject: No -Exposure Compliance Evaluation Inspection
Pratt Industries
No -Exposure No. NCGNE0523
Iredell County, NC
Dear h1r. Devine:
Dee Freeman
Secretary
Enclosed is a copy of the No -Exposure Compliance Evaluation Inspection report for the inspection
conducted at the subject facility on February 10, 2009, by lt-lr. Michael L. Parker with this Office. Thank
you for your assistance and cooperation during the inspection.
The summary portion of the inspection should be self-explanatory. Your company has a No -
Exposure Certification request currently under review by the Division, however, observations by Mr.
Parker during his visit indicate that there are still areas of your site where exposure exist. Such being the
case, this Office will recommend to our Central Office that the request for a No -Exposure exemption not
be approved at this time and that you continue to comply with the terms and conditions of your existing
storm water permit (NCG030361). which remain in effect.
If you have any questions, comments, or need assistance with understanding any aspect of your
permit, please do not hesitate to contact Mr. Parker at [phone].
Sincerely,
Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Enclosure
cc: Shelton Sullivan — NPS/ACO Unit
Mooresville Regional office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 One
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 NorthCat-olina
Internet: wvrw.ncwaterquality.org Naturally
An Equal Opportunity 1Affirmative Acfon Employer — 50% Recycied110% Post consumer paper

® Division of Water Quality
❑ Division of Soil and Water Conservation
❑ Other Agency
Facility Number : Facility Status: wive Permit: N GN 0523 ❑ Denied Access
Inspection Type: Stormwatgr _ Inactive or Closed Date:
Reason for Visit: Routine _ County: Ire QII _ _ Region: MgoresvWe _
Date of Visit: 024012009 Entry Time:01 00 PM Exit Time: 02 15 PM Incident #:
Farm Name: Pratt Industries Owner Email:
Owner: Pratt Industries w _ Phone: [phone]
Mailing Address: 1903 Weiniq St State5villg NC 28677
Physical Address: 1 5 Deer Ridge Ln StatesvilleNC28625
Facility Status: ❑ Compliant E Not Compliant Integrator:
Location of Farm: Latitude: Longitude:
140 exit 148-go North on Highway 90 for 2 miles -Right on Deer Ridge Lane.
Question Areas:
Certified Operator: Operator Certification Number:
Secondary OIC(s):
On -Site Representative(s): Name Title Phone
24 hour contact name Terry Devine Phone: [phone]
On -site representative William Lefler Phone:
Primary Inspector:
Inspector Signature
Michael L Parker
� (` G'�e
���
� -Z�
Phone: [phone]
Ext.2194 ,
Date: 2-
Secondary Inspector(s):
Inspection Summary:
Facility has requested a no -exposure exemption, Observations made during the site visit revealed that there are still areas where
exposure exist. These areas include a pallet storage area and two dumpsters, which accept waste other than office waste. Facility was
advised to continue to maintain their current SW permit (NCG050361) until such time as all exposure can be eliminated. This Office
will recommend that the no -exposure request not be approved at this time
Page: 1

A�� Division of Water Quality 1 Surface Water Protection
NC®ENR National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
E.^nnonnu+i u+o Naviw fiEsouRc[]
NCGNEOOOO
NO EXPOSURE CERTIFICATION
FOR AGENCY USE ONLY
Dale Received
Year
Monlh ❑ay
d
O
Certificatc of Coverage
N1 c IGINLE-10Z
National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit
based on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notice that your facility does not require permit
authorization for its 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.
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 reaui
For
for the No Exoosure Exclusion once every five
contact the DWO Regional Office for your area.
(Please print or type)
1) Mailing address of owner/operator
will
Name L1,Wja m
Street Address / X� _J) Qa
City 6AL12 s u I I 1p State ZIP Code a3?L AS
Telephone No. -704 S rf V- yo6/_!�Fax: _-'7o 4 S 78'- Cll rlla
2) Location of facility producing discharge:
Facility Name
Facility Contact
Street Address
City
County
Telephone No.
'?P,n4i TnciuSlemS
.Sfa�o.�vrlle. " StateL ZIP Code
"704 S 0 Y-/_6J .S_ Fax: r7014 1
Page 1 of 5
C
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SWU-NE-110607 Last revised 11l06107

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NCGNE0000 No Exposure Certification
3) Physical location information:
4)
5)
6)
7)
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). --raoW - exr'j 14 - k/UsA nn _ 4. ,L_9_E�
(A copy of a map with the facility clearly located on it should'be included with the certification application.)
is the facility located on Native American Lands? ❑ Yes R No
Is this a Federal facility? ❑ Yes N(No
Latitude35' 49t oZ_ Longitude SO S17! 31" (deg, min, sec)
This NPDES Permit Application applies to which of the following:
❑ New or Proposed Facility Date operation is to begin
V Existing Date operation began
8) Was this facility or site ever covered under an NPDES St o mwater Permit? P Yes ❑ No
If yes, what is the NPDES Permit Number? N
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:
10) Provide a brief description of the types of industrial activities and products produced at this facility:
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
VN o
❑ Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
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..
a. Using, storing, or cleaning industrial machinery or equipment, and areas where
❑ Yes ®'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 VNo
c. Materials or products from past industrial activity
❑ Yes VNo
d. Material handling equipment (except adequately maintained vehicles)
❑ Yes VNo
e. Materials or products during loading/unloading or transporting activities
❑ Yes VIN0
f. Materials or products stored outdoors (except final products intended for outside
❑ Yes VNo
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
Page 2 of 5
5WU-NE-110607 Last revised 11/06/07

NCGNE0000 No Exposure Certification
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks,
❑ Yes VNo
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by
❑ Yes VNo
the discharger
1. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters))
❑ Yes 10, No
j. Application or disposal of process wastewater (unless otherwise permitted)
❑ Yes VNo
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not
❑ Yes VNo
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
1. Empty containers that previously contained materials that are not properly stored ❑ Yes VNo
(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 VNo
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 ei Yes ❑ No
deterioration, or evidence of leaks?
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 shut?
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 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 any amount of Title Ill Section 313
Superfund Amendments and Reauthorization Act (SARA) water priority
chemicals?
d. Is secondary containment provided for any amount of hazardous substances?
e. Are release valves on all secondary containment structures locked?
VYes ❑ No
VYes ❑ No
la'Yes ❑ No
'Yes ❑ No
&KYes ❑ No
Page 3 of 5
5WU-NE•110607 Last revised 11/06/07

NCGNEOOOO No Exposure Certification
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes 9No
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste ❑ Yes 21No
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes GKNo
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
Type(s) of waste:
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal vendor:
Vendor address:
16) 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)).
1 understand that I am obligated to submit a no exposure Eertificalion form once every five) years to the North Carolina
Division of Water Quality and, if requested, to 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: � ��_ r� L [_ e
Title: (ZnWl /tl V-- r
of
(Date Signed)
Page 4 of 5
5WU-NE-110607 Last revised 11/06/07

NCGNE0000 No Exposure Certification
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 tact 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.
Final Checklist
This application should include the following items:
❑l is completed application and all supporting documentation.
1-1 A map with the location of the facility clearly marked.
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 ...
Fayetteville Office
Mooresville Office
Raleigh Office .....
Washington Office
Wilmington Office
Winston-Salem ....
Central Office ......
[phone]
[phone]
[phone]
[phone]
...[phone]
[phone]
[phone]
...[phone]
Page 5 of 5
SWU-NE-110607 Last revised 11/06/07

Pratt Grdustrres, GiC. August 2007
MACTEC Project No. 6125-07-0013
Figure 1-2 Pratt Industries, Inc. —183 Deer Ridge Lane, Statesville, NC Street Location
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Pratt L¢dustries, Inc,
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Figure 1-1 Pratt Industries, Inc. —183 Deer Ridge Lane, Statesville, NC Appro2dmate
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Re: NCGNE0523 - Pratt Industries
Subject: Re: NCGNE0523 - Pratt Industries
From: Michael Parker <[e-mail]>
Date: Fri, 20 Feb 2009 15:37:39 -0500
To: Sarah Young <Sarah,Young cr ncmai1.net>
Sarah,
I guess we need to send them something "officially" denying their No -exposure request
even though they have been verbally told that it would not be granted. I spoke to a
company rep on Wednesday who told me that they planned to keep their GP and may try
for NE at a later date.
Mike
Sarah Young wrote:
Michael -
Should we send out a letter denying this request,
confirm? -sarah
0
or do we need to wait for you to
Sarah M. Young
Wetlands and Stormwater Branch 1617 Mail Service Center
Raleigh, NC 27699-1617
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Web site: http://h2o.enr.state.nc.us/ws/home.htm
**E-mail correspondence to and from this address may be subject to the North
Carolina Public Records Law and may be disclosed to third parties.**
Michael Parker wrote:
Sarah,
Visited the subject site last week. Based on what I saw we should not issue
them a NE. More than likely they will end up keeping their SW permit
(NCG050361). I will be.sending out an inspection telling them our
recommendations. If you have any questions, just let me know.
Mike
I
Michael Parker - Michael.Parker@nc_nail.net
Environmental Engineer II
North Carolina Dept. of Environment & Natural Resources
Division of Water Quality
610 East Center Avenue
Suite 301
Mooresville, NC 28115
Ph: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Law and may be disclosed to third parties.
1 of 1. 2/20/2009 3:38 I'M

NCGNE0523 - Pratt Industries
Subject: NCGNE0523 - Pratt industries
From: Michael Parker <michael.parker a ncmail.net>
Date: Mon, 16 Feb 2009 08:24:59 -0500
To: Sarah Young <[e-mail]>
Sarah,
Visited the subject site last week. Based on what I saw we should not issue them a
NE. More than likely they will end up keeping their SW permit (NCG050361). I will be
sending out an inspection telling them our recommendations. If you have any
questions, just let me know.
Mike
Michael Parker - Michael. [e-mail]
Environmental Engineer II
North Carolina Dept. of Environment & Natural Resources
Division of Water Quality
610 East Center Avenue
Suite 301
Mooresville, NC 281.15
Ph: [phone] Fax: [phone]
E-mail correspondence to and from this address may be subject to the North Carolina
Public Records Laos and may be disclosed to third parties.
—iD �" - �,J
r
'
1 0(' 1 2/16/2009 9:34 AM