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NCGNE0972_COMPLETE FILE - HISTORICAL_20141014
STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. NCGNE DOC TYPE ❑HISTORICAL FILE DOC DATE ❑ �,D�u I o 14 YYYYMMDD A177ko-IlwA -o � NCDENR North Carolina Department of Environment and Natural Resources Division of Energy, Mineral and Land Resources Land Quality Section Tracy E. Davis, PE, GPM Director October 14, 2014 Mr. Jonathan Gobble GNK Driveline Newton LLC GAP 2 Facility 2900 US 321 South Ne"rton. NC 28658 Dear Mr. Gobble: Pat McCrory, Governor John E. Skvarla, III, Secretary Subject: Denial of No -Exposure Certification NCGNE0972 GKN Driveline Newton LLC 1848 GKN Way Newton, NC 28658 Catawba County The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES Stormwater Permitting form, which we received on October 10, 2013. The Division is unable to concur with your certification of No -Exposure. Based on an inspection of your facility on October 11, 2013 Mooresville Regional Office staff found that industrial activities or materials on your site either are exposed, or have the potential to be exposed. DEMLR cannot grant your requested exemption from permit coverage when industrial activities or materials are exposed or have the potential to be exposed. Please see attached inspection report. If you have any questions or need further information, please contact Mr. Samar Bou-Ghazale at (704) 663-1699, or at Samar.Bou-Ghazale@ncdenr.gov. cc Stormwater P-ermitting_Unit_Files NCGNE0972 Permit File Sincerely, Zahid S. Khan Land Quality Section Regional Engineer Mooresville Regional Office 610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 Telephone 704-663-16991 FAX: 704-663-6040 • Intemet: http://portal.nedenr.org/web/ir/land-guali An Equal Opportunity 1 Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper Permit: NCGNE0972 SOC: County: Catawba Region: Mooresville Compliance Inspection Report Effective: Expiration: Owner: Gkn Driveline Newton LLC Effective: Expiration: Facility: GKN Driveline Newton LLC GAp 2 Facility 2900 US 321 S Contact Person: Jonathan Gobble Directions to Facility: System Classifications: Primary ORC: Secondary ORC(s): On -Site Representative(s): Related Permits: Title: Inspection Date: 10/11/2013 Entry Time: 02:10 PM Primary Inspector: Samar E Bou Ghazale Secondary Inspector(s): Newton NC 28658 Phone: 828-428-6472 Certification: Exit Time: 03:50 PM Phone: Phone: 704-663-1699 Ext.2199 Reason for Inspection: Other Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, No Exposure Certificate Facility Status: 0 Compliant ■ Not Compliant Question Areas: ■ Miscellaneous Questions ■ Misc (See attachment summary) Page: 1 !y; Permit: NCGNED972 Owner - Facility: Gkn Driveline Newton LLC Inspection bate: 10/11/2013 Inspection Type: Compliance Evaluation Reason for Visit: Other Inspection Summary: A site investigation was conducted on October 11, 2013 for no exposure certification. Refer to inspection report for items that need to be corrected prior the issuance of the no exposure certification. Please note that you need to apply for a stormwater permit if the facility was not able to obtain a no exposure certification in the very near future. Misc Is the facility compliant? Comment: There are 5 items that need to be addressed prior to obtaining a no exposure certification. 1=The dumpster needs to be watertight and should have a lid. 2-Pallets need to be kept under roof. 3-A Barrel with un-know content was filled with stormwater. 4-Rusted metals were noted on site exposed to stormwater- 5-Waste oil was noted on the ground. Please clean the spill of any oil quantity_ Yes Nn NA NF Page: 2 MAO ,A� NCDENR or F..YmvMFVT .rn MnLTy, {>F_9C1..xF3 Division of Water Quality I Surface Water Protection s National Pollutant Discharge Elimination Syste'm�,>pi- FOR AGENCY USE ONLY Date Received•-n.,` Year Month Day Certificate of Coverage NICIGINIFIT NO EXPOSURE CERTIFICATION Ibr ExclusiotlJ per, NCGNE0000 NOEXPOSUAECERTIFICATION� '�D 0 QG National Pollutant Discharge Elimination System application for exclusiop fro a StormWater Permit based on NO EXPOSURE: V_ V 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 Sfate 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, DWO 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). For questions, please contact the DWO Regional Office for your area. (See page 6) (Please print or type) 1) Mailing address of owner/operator (address to which all certification corresngndence will be mailed): Name Contact Street Address City Telephone No. Email GKN Driveline Newton LLC Jonathan Gobble 1848 GKN Wa Newton State NC ZIP Code 28658 828 428-6472 Fax: 828-428-3770 ionathan.gobble@gkndriveline.com � @�u V � Page 1 of 7 OCT _ a 1013 SW U-NE-12Aug2010 ti c NCGNE0000 No Exposure Certification r 2) Location of facility producing discharge: Facility Name GKN Driveline Newton LLC GAP 2 Facilit Facility Contact Jonathan Gobble Facility Street Address 2900 US 321 Sauth City Newton State NC ZIP Code 28658 County Catawba Telephone No. 828 428-6472 Fax: 828-428-3770 Email ionathan.gobble@gkndriveline.com 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 from a roadway intersection). Take US 321 Business south from Newton approximately 5 miles. GKN facility will be on the left (Axle Plant 2). (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 x No 5) Is this a Federal facility? ❑ Yes X No 3 5: 3 (v* Iy 6) Latitude 35°36'15.61"N_ Longitude - 81°12'47.72"W_(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 X 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 X No 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: 3714 10) Provide a brief description of the types of industrial activities and products produced at this facility: Assembly of drive train components for the automotive industry into gear and axle sets. 11) Does this facility have any Non -Discharge permits (ex: recycle permits)? X No ❑ 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 Exl2osure 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 eligible for the no exposure exclusion. a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes X 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 Cl Yes X No c. Materials or products from past industrial activity ❑ Yes X No d. Material handling equipment (except adequately maintained vehicles) ❑ Yes X No e. Materials or products during loading/unloading or transporting activities ❑ Yes X No f. Materials or products stored outdoors (except final products intended for outside ❑Yes X No use (e.g., now 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 X No and similar containers h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes X No the discharger i. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes X No j. Application or disposal of process wastewater (unless otherwise permitted) © Yes X No k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes X No 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 X No (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 X 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 DQJ eligible for the no exposure exclusion. a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No X NIA deterioration, or evidence of leaks? b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No X N/A cracks, holes, or evidence of leaks, and are drain valves maintained locked shut? Page 3 of 7 SW U-NE-12Aug2010 NCGNE0000 No Exposure Certification 14) Secondary Containment: If you answer "No" to any of the following items, you are n2l 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? 'See additional information attached. 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: How is material stored: Where is material stored: How many disposal shipments per year: Name of transport / disposal vendor: Vendor address: Footnotes to Questions 14) c. & d. X Yes ❑ No ❑ NIA X Yes ❑ No ❑ NIA ❑ Yes ❑ No X NIA ❑ Yes ❑ No X N/A ❑ Yes ❑ No X N/A ❑ Yes X No ❑ Yes X No ❑ Yes X No "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, Page 4 of 7 SW U-NE-12Aug2010 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? X Yes ❑ No 'See additional information attached. b. Does your facility Have coal piles on site? []Yes X No c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes X No sawdust, etc.? d. Does your facility have air emissions associated with its industrial activity (e.g., ❑ Yes X 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 X NIA 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: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Permit: Program: Page 5 of 7 SW U-N E-12Aug2010 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: Michael Erdt Title: Plant Director _ _ .. (Signature -of Appli U- (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. Page 6 of 7 SW U-NE-12Aug2010 NCGNE0000 No Exposure Certification This application should include the following items: X This completed application and all supporting documentation. X A map with the location of the facility clearly marked. n/a 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 iY�Iti 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. Asheville Office ...... (828) 296-4500 Fayetteville Office ... (910) 433-3300 Mooresville Office ... (704) 663-1699 Raleigh Office ........ (919) 791-4200 Washington Office ...(252) 946-6481 Wilmington Office ... (910) 796-7215 Winston-Salem ...... (336) 771-5000 Central Office .........(919) 807-6300 Page 7of7 SWU-NE-12Aug2010 � V � j r •gip �` �, � 1 .,,�, ,,r�'j. � 4{1 fl y� I P..sor,� >. - }� SITE LOCATION lh - � . r o =� ,,ice -_ - \`` •.. . wl . � � � •• }'- .- i r 1, .t�f ���` . Source http Hgoto arcgisonline.comlmaps/USA_Topo_Maps QSite Location N 0 1,000 2,000 4,000 6,000 8,000 Feet SITE LOCATION ameca G GAP 2 FACILITY 2900 00 HWY 321 SOUTH NEWTON, NORTH CAROLINA PREPARED 7EATE CHECKED DATE JOB NUMBER FIGURE BY SJM 8/1/13 BY HH 8/1/13 625213-0083 1 ADM> GKN DRNElJNE September 17, 2013 Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 GKN Driveline Newton 1848 GKN Way Newton NC 28658 USA T +1 (0)828 428 3711 F +1 (0)828 428 3770 RE: Additional Information Referenced on No Exposure Certification Exclusion Application GKN Driveline LLC GAP 2 Facility 15b. This facility was previously listed as a Small Quantity Generator. It is now listed as a Conditionally Exempt Small Quantity Generator. 16a. When new machinery is received at this facility it is usually shipped inside wood crates on wood skids that we consider to be the same as pallets. These skids and crates are non -pressure treated raw wood of pine or oak species and are placed in a temporary dumpster for removal offsite to a facility for recycling or disposal. i i 4� nth" S obble EHS Specialist GKN Driveline Newton LLC 1848 GKN Way Newton, NC 28658 Office: (828) 428-6472 Cell: (828) 508-1239 jonathan.gobble@gkndriveline.com 4� > GKN DPJVEUNE October 3, 2013 Stormwater Permitting Unit Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 GKN Driveline Newton 1848 GKN Way Newton NC 28658 USA T +1 (0)828 428 3711 F +1 (0)828 428 3770 RE: GKN Driveline Newton LLC — Stormwater NCGNE0000 No Exposure Certification To Whom It May Concern, Please find enclosed the above referenced certification. If you have any questions please do not hesitate to contact me. Thank y u fqr your time. onat n- . Go ble EHS Specialist GKN Driveline Newton LLC 1848 GKN Way Newton, NC 28658 Office: (828) 428-6472 Celt: (828) 508-1239 Jonathan.gobble@gkndriveline.com Enclosures: NCGNE0000 Permit Application OCT 7 2013 NCDENR North Carolina Department of Environment and Natural Resources Division of Water Quality Pat McCrory Governor Mr. Jonathan Gobble GNK Driveline Newton LLC GAP 2 Facility 2900 US 321 South Newton, NC 28658 Dear Mr. Gobble: Tracy Davis Director October 14, 201J John E. Skvarla, III Secretary Subject: Denial of No -Exposure Certification NCGNE0972 GKN Driveline Newton LLC 1848 GKN Way Newton, NC 28658 Catawba County The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES Stormwater Permitting form, which we received on October 10, 2013. The Division is unable to concur with your certification of No - Exposure. Based on an inspection of your facility on October 11, 2013 Mooresville Regional Office staff found that industrial activities or materials on your site either are exposed, or have the potential to be exposed. DWQ cannot grant your requested exemption from permit coverage when industrial activities or materials are exposed or have the potential to be exposed. Please see attached inspection report. If you have any questions or need further information, please contact Mr. Samar Bou-Ghazale at (704) 663-1699, or at Samar. Bou-Ghazale@ncden r. gov. Sincerely, Zahid Khan Regional Engineer cc: Stormwater Permitting Unit Files NCGNE0972 Permit File Mooresville Regional Office Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115 Phone: (704) 663-16991 Fax: (704) 663-6040 4 Customer Service: 1-877-623-6748 Intemet: www.ncwaterquality.org NorthCarolina Naturally An Equal Opportunity 1 ATrmative Action Employer - 30% Recycled110% Post Consumer paper iA 7� NCDENR North Carolina Department of Environment and Natural Resources Division of Energy, Mineral and Land Resources Land Quality Section Tracy E. Davis, PE, CPM Director October 14, 2014 Mr. Jonathan Gobble GNK Driveline Newton LLC GAP 2 Facility 2900 US 321 South Newton, NC 28658 Dear Mr. Gobble: Pat McCrory, Governor o D . Skvarla, Ill, Secretary o� 0���o5t Subject: Denial of No -Exposure Certification NCGNE0972 GKN Driveline Newton LLC 1848 GKN Way Newton, NC 28658 Catawba County The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES Stormwater Permitting form, which we received on October 10, 2013. The Division is unable to concur with your certification of No -Exposure. Based on an inspection of your facility on October 11, 2013 Mooresville Regional Office staff found that industrial activities or materials on your site either are exposed, or have the potential to be exposed. DEMLR cannot grant your requested exemption from permit coverage when industrial activities or materials are exposed or have the potential to be exposed. Please see attached inspection report. If you have any questions or need further information, please contact Mr. Samar Bou-Ghazale at (704) 663-1699, or at Samar.Bou-Ghazale@ncdenr.gov. Sincerely, J-1-1 -S Zahid S. Khan Land Quality Section Regional Engineer cc: Stormwater Permitting Unit Files NCGNE0972 Permit File Mooresville Regional Office 610 East Center Avenue, Suite 301, Mooresville, North Carolina 28115 Telephone 704-663-16991 FAX: 704-663-6040 • Internet: hitp://portal.nedenr.org/web/Ir/land-quality An Equal Opportunity 1 Affirmative Action Employer— 50% recycled 110% Post Consumer Paper Compliance Inspection Report Permit: NCGNE0972 Effective: Expiration: Owner: Gkn Driveiine Newton LLC SOC: Effective: Expiration: Facility: GKN Driveline Newton LLC GAp 2 Facility County: Catawba 2900 US 321 S Region: Mooresville Newton NC 28658 Contact Person: Jonathan Gobble Title: Phone: 828-428-6472 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: Inspection Date: 10/11/2013 Entry Time: 02:10 PM Exit Time: 03:50 PM Primary Inspector: Samar E Sou Ghazale Phone: 704-663-1699 Secondary Inspector(s): Ext.2199 Reason for Inspection: Other Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, No Exposure Certificate Facility Status: 0 Compliant ■ Not Compliant Question Areas: E Miscellaneous Questions 0 Misc (See attachment summary) Page: 1 Permit: NCGN E0972 Owner - Facility: Gkn priveline Newton LLC Inspection pate: 10/11/2013 Inspection Type: Compliance Evaluation Reason for Visit: Other Inspection Summary: A site investigation was conducted on October 11, 2013 for no exposure certification. Refer to inspection report for items that need to be corrected prior the issuance of the no exposure certification. Please note that you need to apply for a stormwater permit if the facility was not able to obtain a no exposure certification in the very near future. Misc Is the facility compliant? Comment: There are 5 items that need to be addressed prior to obtaining a no exposure certification. 1-The dumpster needs to be water tight and should have a lid. 2-Pallets need to be kept under roof. 3-A Barrel with un-know content was filled with stormwater. 4-Rusted metals were noted on site exposed to stormwater. 5-Waste oil -was noted on the ground. Please clean the spill of any oil quantity. Yes No NA NE Page: 2