NCGNE0821_COMPLETE FILE - HISTORICAL_20120210

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
NCGNE
DOC TYPE
❑HISTORICAL FILE
DOC DATE
❑ aa a �U
YYYYMMDD

4
AjRi
NC®ENR
North Carolina Department of Environment and
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
February 10, 2012
Mr. Mike Estep, Loss Prevention & Safety Manager
Institution Food House, Inc.
P.O. Drawer 2947
Hickory, North Carolina 28603-2947
Dear Mr. Estep:
Natural Resources
Dee Freeman
Secretary
Subject: Denial of No -Exposure Certification NCGNE0821
Institution Food House, Inc.
543 12th Street Drive NW, Hickory, NC
Catawba County
The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES
Stormwater Permitting form, which we received on November 30, 2011. The Division is unable to concur
with your certification of No -Exposure.
Based on an inspection of your facility on January 18, 2012, Mooresville Regional Office staff found that
industrial activities or materials on your site either are exposed, or have the potential to be exposed as
detailed in the attached inspection report. DWQ cannot grant your requested exemption from permit
coverage when industrial activities or materials are exposed or have the potential to be exposed. Please
apply for coverage under General Permit NCG060000 developed for owners or operators of stormwater
point source discharges associated with activities classified as establishments primarily engaged in Public
Warehousing and Storage (SIC 4221-4225) using the enclosed Notice of Intent.
If you have any questions or need further information, please contact Marcia Allocco at [phone], or at
marcia.alloccoCc7ncdenr.gov.
Sincerely,
for Charles Wakild, P.E_,
cc: Stormwater Permitting Unit Files (B. Lowther)
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone; [phone] L Fax: [phone] Customer Service: 1-877-623-6748
Internet: www.nwaterquality.org
Division Director
NorthCarotina
NIMUrally
An Equal Opportunity 4 Affirmative Action Employer - 30% Recycled110% Post Consumer paper

Compliance Inspection Report
Permit: NCGNE0821 Effective: Expiration: Owner: Institution Food House Inc
SOC: Effective: Expiration: Facility: Institution Food House Incorporated
County: Catawba 543 12th St Dr Nw
Region: Mooresville
Hickory NC 28603
Contact Person: Greg Willis Title: Phone: [phone]
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Inspection Date: 01/1812012 �Entry Time: 10:17 AM Exit Time: 12:50 PM
Primary Inspector: Marcia Allocco Phone: [phone]
Secondary Inspector(s):
Ext.2204
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: 5tormwater Discharge, No Exposure Certificate
Facility Status: Q Compliant ■ Not Compliant
Question Areas:
Miscellaneous Questions
(See attachment summary)
Page: 1

Permit: NCGNE0821 Owner - Facility: Institution Food House Inc
Inspection Date: 01/18/2012 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
The facility was visited through a new No -Exposure Certification request
All stormwater at the site drains to Frye Creek, Class WS-IV waters located in the Catawba River Basin located
immediately to the north of the site (verified on USGS Hickory Quadrangle). There was flow in some of the drop inlets on
site most likely due to the rain event in the 24 hours preceding the site visit.
The following sources of stormwater exposure were noted during the inspection:
• The kitchen grease container's lid was properly affixed and there exposed to stormwater. Container should be closed
at all times except during filling. All areas on the outside of the container exposed to stormwater should be free from any
petroleum contamination.
• There was a crate of brake pads just outside the maintenance building was. uncovered and exposed to stormwater.
• There was a scrap metal dumpster located near the maintenance building, which was exposed to stormwater.
• The empty totes next to the maintenance building can be staged outside as long as the outside of the totes do not have
residual product that can become exposed to stormwater and create a source of exposure.
• All dumpsters need to covered at all times (except during addition of refuge) and drain plugs need to be installed to
qualify for no -exposure.
• IFH conducts mobile fueling operations to facilitate faster turn -around for the company's tractor -trailers. This is
accomplished by having a fueling truck fill up at one of the two fueling stations on site and then deliver fuel to the
tractor -trailers as they are filled at the bays in the warehouses. This is exposure unless the mobile fueling area is covered
as well the dispensing station above the two underground storage tanks (USTs).
Page: 2

OKWA
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NCDENR
vim.. e.�o.... cer•:..,�c+r �
FMNgWi� W) Ncvw. WY0.1�A
Division of Water Quality / Surface Water Protection
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNEOOQO
FOR AGENCY USE ONLY
D=c Remived
Year Month
pay
Cotificam ofcov=ge
DIVISION CIF AATER Ql1ALITY
NOV 3 0 2G11
NO EXPOSURE CERTIFICATION gyve
0.�trsnor=^tn• c o-r�.�,.��• OFFICE
National Pollutant Discharge Elimination System application for exclusion from a Stonnwater Permit based
on NO EXPOSURE:
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, 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 leaf "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).
re
For questions, please contact the DWQ Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of ownerloperator (address to which all certification correspondence will be maned?:
Name
` Institution Food House, Inc.
Contact
Street Address 543 12 t h s t r a a t nrrup N. W
City Hickory State NIC ZIPCode -2R603_2947_
Telephone No. Fax: 228
Email _ I E Her om
Page 1 of 7 t] 12� 2 U
swu-NE-12At,4201 o NOV 1 8 2011
DENR - WATER QUALITY
WETL*'IDS AND STORMWATER BRANCH

NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name Institution Food House, Inc.
Facility Contact
Facility Street Address 543�L2tb Street Drive N.W. _
City State Nr, ZIP Code 9 8 6 n 3- 9 9 a 7
County Catawba
Telephone No. Fax: [phone]
Email
3) Physical location information:
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction f rom a roadway intersection). N on US 321 `from I - 4 0 t o rictht on 7 t h AveNW
Q traffic liaht:.then right on 12th St_ ag NWjaQtth to__-943 12th St Dr NW
(A copy of a map with the facility clearly located on it should be included with the certification application.) on right
4) Is the facility located on Native American Lands? ❑ Yes ICI No
5) Is this a Federal facility? ❑ Yes ND No
6) Latitude 3 5° 4 4 ' 2 2 . 7 " Longitude_ ' (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
IV Existing Date operation began
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes ❑ No
If yes; what is the NPDES Permit Number? have not been able to locate
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: 514 (
una#le--te- ]_ovate
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Receiving and distribution r_enhPL
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
Q No
❑ Yes
If yes, list the pt_oi,it numbers for all current Non -Discharge permits for this facility:
Page 2 of 7
5WU-NE-12Aug2010

NCGNE0000 No (Exposure Certificatlon
Exposure gAg fsts jT 2. - 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 enmer "Yes" to any of these items, you are no
egg-IbW for the nn axposure exclusion.
a. Using, storm, or cleaning industrial machinery or equipment, and areas were 13 Yes 7,No
residuals from using, storing or cleaning Industrial machinery or equipment remain
and are eased to sWaiwater
b. Materials or residuals on the ground or in stormwater inlets from spilfsliaaks ❑ Yes A No
c. Materials or products from past industrial activity ❑ Yes No
d. Material handling equipment (except adequately maintained vehicles) ❑ Yes No
$. Materials or products during loading/unloading or transporting activities ❑ Yes jKNo
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes 34 No
use [e.g., new cars] where exposure to stormwater does not result in the discharge
of pollutants)
g. Materiels caftifnsd in open, deteriorated or leaking Storage drttr m, barrels, tanks, ❑ Yes V(No
and similar containers
h. Materials or products handled/stored on roads or raliways owned or maintained by ❑ Yes ANo
the discharger
I. Waste material (except waste in covered, non -leaking containers (e.g., dumpsters)) ❑ Yes 19 No
j. Appltration or disposal of process wastewater (unless otherwise permitted) a Yes K No
k. PM ficulate matter or vlWe Visits of residuals from root stacks andforverits trot 0 Yes � -No
otherwise regulated (i.e., under an air quatiity control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes q No
(i.e., not closed and stored upside dorm to prevent precipitation accumulatian)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar ountainers 13 Yes M 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 no
efig Ibis for the no exposure exclusion.
a. Are exterior ASTs and piping tree of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No b(N/A
deterioration, or evidence of leaks?
I- Is secardary =tainment provided for aft exterior ASTs? it so, is it free of any 13 Yes ❑ No X NIA
cracks, holes, or evidence of leaks, and are drain valves maintained lacked shut?
Page 3 of 7
5W U-NE-12Aug2010

NCGNEOODD No Exposure Certification
14) Secmtdw y 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
❑ Yes © No xl WA
containers (including drums, barrels, etc.) with a rapacity of more than 660-
galions?
b. Is secondary containment provided for above ground storage containers stored
❑ Yes ❑ No 13 NIA
in dose proximity to each other with a combined capacity of more than 1.320-
gal Ions?
c. is secondary containment provided for Tide III Section 313 Superfund
o Yes ❑ No M NIA
Amendments and Reauthorization Act (SARA) watergdo ' _chemicals'?
d- Is secondary containment provided for hazardous substances'" designated in 40
❑ Yes ❑ No M NIA
CFR §116?
e. Are release valves on all secondary containment structures locked?
❑ Yes ❑ No IC NIA
16) Hazardous Waste:
a. Is this faciltty a Hazardous waste Treatment, Storage, or Disposal Faculty? ❑ Yes Xj No
b. Is this facility a Small Quantity Generator (less than 1000 kg- of hazardous waste ❑ Yes r No
generated per month) of hazardous waste?
C. Is this factity a Large Quantity Generator (1000 kg. or more of hazardous waste t7 Yes 3P No
generated per month) of hazardous waste?
If you answered yes to questions b. arc-, pleasa provide the following information:
Type(s) of waste:
Horn is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport I disposal vendor:
Vendor address:
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 minlmis 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 6117.3_
Page 4 of 7
Swu-N E-12At,C2010

I k
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? ❑ Yes 10 No
b. Does your facility have coal piles on site?
❑ Yes j7 No
c. Does your facility store other fuel sources outside in piles, such as wood chips,
❑ Yes j7 No
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g..
❑ Yes jo 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 )] NIA
Please s pecity:
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit. Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
sW U-N E-i 2Aug2010
Page 5 of 7

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)).
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 (M$4) 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: a f (L WL C
Title: T)tntiv S Jna 4p p r —
(�Ar
(Signature of Applicant) (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 knowingty 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.
Page 6 of 7
SW a-N E-12Aug2010

NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
DQ This completed application and all supporting documentation.
p 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 DWQ 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]
Page 7 of 7
5WU-NE-12AU92010

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Allocco, Marcia
From:
Allocco, Marcia
Sent:
Friday, January 27, 2012 2:27 PM
To:
[e-mail]'
Cc:
Georgoulias, Bethany
Subject:
IFH Inspection of 1/18/12
Hi Mike,
I hope you are well and I am sorry I could not get the below list (from the site visit on 1/18/12) to you earlier but
I was pulled to some other issues this last week. The list includes issues that would need to be resolved to
issue No -Exposure Certification (NEC) and well as some issues that Michael Burkhard and I suggested
needed attention.
Issues needing resolution for NEC
• IFH would need to ensure the cover to the kitchen grease container stays closed at all times except
during filling. All areas exposed to stormwater should be free from any petroleum contamination.
• IFH needs to move the crate of brake pads inside or cover them while outside to prevent stormwater
exposure to the brake pads.
• IFH needs to cover the scrap metal dumpster to prevent stormwater exposure to the scrap metal.
• IFH needs to label the empty tote of Def (spelling?). There were no signs of residual material on the
outside of the tote so it was not a source of stormwater exposure during the inspection. IFH can stage
empty totes in this area as long as the outside of the totes do not have residual product that can
become exposed to stormwater and create a source of exposure.
• The trash compactor near the Yum warehouse was not reconnected correctly and some of the contents
had escaped and made their way to the drain located within 10 feet of the compactor. During the
inspection it was thought the drain lead to the stormwater system. However, post inspection you
contacted me and noted the drain was connected to the oil/water separator used for the interior truck
washing station near the maintenance building and ultimately lead to the sanitary system.
• All dumpsters need to covered at all times (except during addition of refuge) and drain plugs need to be
installed to qualify for no -exposure.
• IFH conducts mobile fueling operations to facilitate faster turn -around for the company's tractor -trailers.
This is accomplished by having a fueling truck fill up at one of the two fueling stations on site and then
deliver fuel to the tractor -trailers as they are filled at the bays in the warehouses.
I chatted with our permitting folks and discussed the option of covering any storm drains during the
fueling operation and whether that would qualify you for No -Exposure. Permitting staff noted that the
issue of mobile fueling had come across the stormwater listsery used by the different state and EPA
stormwater permitting groups and multiple people noted that they treat mobile fueling as exposure.
This is in line with what we discussed on the 181h regarding the USPS offices in Charlotte where we
treated mobile fueling operations as "exposure" and made them get permit coverage. The only way to
get No -Exposure for this issue would be to cover all areas where mobile fueling occurs including the
fueling tank areas (two USTs) so there is no stormwater exposure. Since you do not qualify for No -
Exposure Certification at this time I would direct you to get coverage under our General permit that
covers general warehousing (NCG060000). The Notice of Intent to be covered under this General
Permit is located at http://I?ortal.ncdenr.org/web/wq/ws/su/npdessw#tab-3.
Other Issues
• IFH does not control the "Old Meat House" warehouse but the outside was reviewed during the NEC
inspection. The roof drain downspouts on the rear of the warehouse have caused significant erosion
into the earthen berm. This is causing sediment additions to the stormwater discharged from the site.
Since sediment is the #1 pollutant in NC streams we would like to see some "rock" or other stabilizing
material added to the area below the downspouts. The material that is added would dissipate some of

e -�
the energy from the roof drain discharge and hopefully significantly reduce the amount of sediment .
leaving the site. You will have to size the material so it would not be carried away in the stormwater
discharge. Another measure that could be implemented is to stabilize the entire area with vegetative
cover such as grass in addition to energy dissipation measures.
We conducted an illicit discharge evaluation while at IFH. We did this by looking in all drop inlets and
determining if there were any dry weather flows since there was no precipitation during our site visit of
1/18/12. Several of the drop inlets on the stormwater conveyance line between the frozen warehouse
and the refrigerated/Yum warehouse appeared to be entirely clogged with sediment. This could cause
flooding of the parking areas that drain to this stormwater line in the future. We suggested that you
contract with a jet truck to vacuum out any residual material to enable "free flow" of stormwater in the
discharge line.
Once the lines (noted above) are clean we also suggested you investigate whether you could find drain
inserts that would fit your inlets and collect any accumulated sediment without discharging it. This
would provide a preventative measure to avoid an expensive clean -out in the future. This New Pig
website shows an example of a drain insert and is not meant as an endorsement of any product.
The frozen warehouse has an emergency generator staged outside that includes a skid mounted
aboveground storage tank (AST) with a capacity of — 500 gallons. While there was no sign of
petroleum contamination from the AST we suggested that you purchase some drain covers for the two
stormwater drains in the area near the emergency generator. The idea of the drain covers was to use
them to -prevent any additions of petroleum to the stormwater system in case there was a failure of the
tank or a spill during refueling. This was thought prudent since there is only a short distance between
your stormwater collection point and where it discharges into a stream at the front edge of the IFH
property. Petroleum spills to surface waters can become expensive endeavors. This New Pig website
shows an example of a stormwater drain cover.
If you have any questions please feel free to give a call. I'll be out of the office next week on training and back
on 2/7/11. 1 won't issue the letter denying No -Exposure until after I get back in case you wanted to discuss any
of the items I noted in this e-mail.
Regards,
Marcia
Marcia Allocco, MS - Environmental Chemist
NC Dept. of Env. & Natural Resources (NCDENR)
Division of Water Quality - Surface Water Protection Group
610 East Center Ave., Suite 301, Mooresville, INC 28115
Phone: [phone] Fax: [phone]
[e-mail]
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 unless the content is exempt by statute or other regulation.