NCGNE0352_COMPLETE FILE - HISTORICAL_20070919

STORMWATER DIVISION CODING SHEET RESCISSIONS.
PERMIT NO.
DOC TYPE
l COMPLETE FILE'- HISTORICAL
DATE OF
RESCISSION
❑ � �
YYYYMMDD

Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen H. Sullins, Director
Division of Water Quality
September 19, 2007
Mr. Robert J. Waldrop
Full Circle Solutions Inc.
665 Molly Lane, Suite 100
Woodstock, Georgia 30189-3699
Subject: Denial of No Exposure Certification NCGNE0352
Return #1156
Full Circle Solutions Inc.
136 Full Circle, Battleboro, NC
Edgecombe County
Dear Mr. Waldrop:
The Division has reviewed your submittal of the No Exposure Certification for Exclusion from
NPDES Stormwater Permitting form, which we received on March 19, 2007. The Division is unable
to concur with your certification of no exposure.
During a recent inspection of your facility, staff from DWQ's Raleigh Regional Office 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.
Further, it appears that the site is discharging stormwater without a permit, and may be subject
to enforcement action and to a civil penalty assessment of up to $25,000.00 per day for each
violation. Please make application for an NPDES individual stormwater permit using EPA Forms
1 and 2F, available on the DWQ Stormwater Permitting Unit website at:
http://h2o.enr.state.nc.us/su/Forms—Documents.htm.
If you have any questions about applying for coverage under an NPDES individual stormwater
permit please contact Ken Pickle [phone], ext. 584, or through email at
[e-mail].
4ij /
for Coleen H. Sullins
C ix( -Nleo
cc: Ron Boone, aleigh Regional Office
Stormwater Permitting Unit Files
Shelton Sullivan, NPS Assistance & Compliance Oversight Unit
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, North Carolina 27699-1617 [phone]
�p l�
DENFt
Customer Service
1-877-623-6748

Re: NEC ?
Subject: Re: NEC ?
From: Bethany Georgoulias<[e-mail]>
Date: Mon, 10 Sep 2007 16:14:38 -0400
To: Ken Pickle <[e-mail]>
CC: Ron Boone <[e-mail]>, Bradley Bennett <[e-mail]>
Ken,
I agree with your assessment of this situation. I'm not sure how the two sites would
compare, but I am reminded about. the PCS facility located at the NC Port Authority's
Morehead City Port we visited with Linda Willis., Fertilizer material was stored
inside a huge warehouse, but the tracking in and out of dust from loading vehicles
was enough for that facility to cause real problems in NCPA's stormdrains for that
area. (In fact, they required PCS apply as a separate permittee so the company is
directly responsible for it's impact on the Port's stormwater discharge, even though
PCS is a tenant at its facility.) on top of that, Rocky Mount is in a Nutrient
Sensitive Water basin. I don't think we can say No Exposure applies here.
-BG
Ken Pickle wrote:
Hi Ron,
See my comments inserted in your note.
Ken
Ron Boone wrote:
Hi Ken,
Thanks for returning my call. I tried to call you today but you weren't
there so I thought I'd just try sending you an email. Need your opinion
again:
I have a permittee, Full Circle Solutions, that has applied for a NEC.
Is that on Sarah's desk now?
This
company takes the waste by product of the air scrubber systems in the stacks
at the Cogentrix power generation plant in Battleboro, NC, and stores it in
a large warehouse facility in Rocky Mount. They then process it and
distribute it as a fertilizer to farmers.
Sounds like the activity typically would be captured under SIC 28, and therefore
would require an NPDES permit. No NCG fits, so we would normally require a
individual stormwater discharge permit, an NCS permit. Presuming that there was
exposure.
The whole facility is enclosed and
a very small amount of stuff is outside.
If this small amount of stuff is in a designated and exposed staging area, or
storage area, or holding area, then it is part of the process and clearly it
constitutes exposure that disqualifies the site from the no exposure exclusion.
But, even more constraining is the wording we use on our No Exposure Exclusion
form at item 12b., "Materials or residuals on the ground or in stormwater inlets
from spills/leaks." Your description of the site makes me think that this second
characterization is most accurate. 'So, if it is accurate, then they are still not
eligible for the no exposure exclusion. Further, I think that your assessment
that incidental spillage could not be stopped at this site further suggests that
there may not be a realistic way for these folks to qualify for no exposure.
I 1 of 3 9/12/2007 9:51 AM

Re: NEC ?
Further, they make fertilizer. That probably means that their product/raw
material has some soluble nitrogen and/or phosphorus in it. .So, even the capture
of the visible solids might not indicate that the discharge was free from
dissolved nutrients.
I think they would definitely
qualify for NEC if it wasn't for a couple of items that I wanted to ask you
about as follows:
1. It looks like the process is losing a small amount of the raw material
and finished product to the ground via several sources such as:
a. Incidental spillage during the transfer process
b. Transfer of spilled material from the floor/ground inside the
facility,
to the ground outside the facility, both from the truck tires and from
the product dust being blown around while the truck is moving - even though
the truck beds -are covered with tarps
C. Product dust being washed off the truck's windshields only (yeah
right)
onto the ground
I identified quite a few areas around the building where the incidental
losses had accumulated to a point to contrast very well with the surrounding
natural soil color - making it unmistakably clear that it was the product
and not just the natural soil.
However, the entire site has been graded to drain into a pond that then
discharges to a earthen level spreader. I saw some evidence that product had
made its way to the pond, but not out of it. The facility has been in
operation since April '06. Don't know what kind of pond it's supposed to be
as the inlet is at nearly the same invert elevation as the
outlet... according to prints the outlet is less than a foot lower than the
inlet ... so the pond provides;no settleability value at all that I can tell.
Here's where I'm concerned about the product they make. Even if solids were
retained in this basin (and I think you are saying that they aren't), I'm
concerned that the soluble nutrients could be expected in the discharge from the
basin. If so, this would contradict the intent of a no exposure exclusion.
So, other than the incidental spillage and the windshield washing (which can
be stopped), there is no exposure. However, the incidental spillage cannot
be controlled any better. Although the incidental spillage represents a
negligible amount, it may be enough, once it builds up sufficiently, to
present a water quality issue ... but I doubt it. The pond should have been
built better to provide some sedimentation of stuff washed into it.
I feel like telling them to stop washing the windshields and put an overflow
pipe in the pond to provide sedimentation and we'll give them the NEC.
I know it's difficult when you haven't seen things with your own eyes, but
what do you think?
Ron, my comments are listed above. This sort of decision as to at what point we
-can declare no exposure is a live issue in our group now, most recently at a small
composting site in ARO. I've copied Bethany and Bradley to solicit other helpful
comments.
Thanks in advance!
2 of 3 9/12/2007 9:51 AM

�10 � BOOK I a 9 i PAGEo i 4 5
�� •
FILED
EDGECOMBE COUNTY Nip
05123r'2007 9,25 AM
ROBIN W. CARPENTER
Resister Of Deeds
a(!-,
Register/Dew.
NORTH CAROLINA STORM WATER FACILITY OPERATION
EDGECOMBE COUNTY AND MAINTENANCE AGREEMENT
ISrAGREEAAENT=made a d entered into this 071" day of 2007 by and between
(Full Circle Solutions. Inc. 1 and the City of Rocky Mount, a North Carolina municipal
corporal eco be Counties (the "City");
WITNESSETH:
WHEREAS, the City has adopted certain storm water management regulations applicable to the
property of Permittee located in the City of Rocky Mount, Edgecombe County, North Carolina, and more
particularly described In PC 9 Slide 17 Edgecombe. County Registry (the
"Property); and
WHEREAS, such regulations require the Permittee to operate and maintain an engineered stone water
control facility as part of the development of the Property; and
WHEREAS, Permittee has constructed a private on -site engineered storm water control facility (the
"Facility") to satisfy the requirements of such regulations, the boundaries of such Facility being described in
Appendix 1 attached hereto and incorporated herein by reference; and
WHEREAS, a separate deed vesting title to the real estate on which the Facility is located in Permittee
has been recorded in the Edgecombe County Registry; and ,
WHEREAS, as a condition of the development of the Property, Permittee is required to enter into an
operation and maintenance agreement providing for the continued operation and maintenance of the Facility.
NOW, THEREFORE, for and in consideration of the premises and the approval by the City of the
development activities on the Property, the Permittee does hereby covenant and agree with the City that the
Facility shall be held, operated, maintained, and encumbered pursuant to the covenants and conditions
hereinafter set forth;
1. No conveyance of Facility without New Aareement. Permittee covenants and agrees that it will not convey,
transfer, assign, lease, or otherwise release or relinquish ownership or control of the Facility, in whole or in
pad, unless and until the proposed new owner of the Facility, or any interest therein, has entered into a
Stone Water Facility Operation and Maintenance Agreement with the City containing substantially the same
teens and conditions as this Agreement, and a copy thereof has been recorded in the
County Register of Deed's Office.
2. Operation and Maintenance Plan. Permittee has prepared and submitted to the City an Operation and
Maintenance Plan for the Facility which has been approved by the City. Permittee shall operate, maintain,
repair, and, if necessary, reconstruct the Facility in accordance with the Operation and Maintenance Plan.
3. Inspection and Maintenance of Facility. In addition to the maintenance provided for in the Operation and
Maintenance Plan, Permittee shall undertake and provide the following inspection, repair, and maintenance
of the Facility:

BBBK 14 9 I PANG 7 4 60
a. Grassing around the Facility shall be maintained to prevent the erosion of these areas. The areas shall be
periodically mowed to maintain the aesthetic quality of the site and to prevent a reduction in capacity of the
stormwater system. Grass should to exceed a height of 15 inches. All eroded areas shall be repaired.
b. Open ditches shall be kept free of undesirable growth and mowed or maintained to the design cross-section
and area as shown on the construction plans approved by the City Engineer and on file in the office of the
City Engineer. Growth on the slopes and bottom should not exceed a height of 8 inches.
c. Landscaping of the area around the Facility shall not reduce the capacity or hinder operation and
maintenance of the Facility. Landscaping shall be maintained to ensure that landscape materials live and
prosper. Re -vegetation of areas may be required by the City Engineer.
d. The Facility shall be routinely checked as directed by the City Engineer for, and Geared of, all accumulation
of debris and the Facility's outlet structure Geared of any blockage that is present.
e. Storm drainage pipes and culverts shall be periodically inspected on a schedule established by the City
Engineer for debris and sand build-up. T hey shall be cleaned as necessary to provide for the free
conveyance of stormwater as designed.
f. The Facility shall be maintained at the design depth as shown on the construction plans approved by the
City Engineer and on file in the office of the City Engineer. The pond shall be inspected and maintained by
the Permittee on a regular basis. Debris and sedimentation shall be removed by the Permittee when:
1. The primary outlet capacity is impaired and/or,
2. The depth of the Facility has been reduced by more than one foot from the original depth or the Facility
volume is reduced by 20% of the design impoundment volume. Sediment bays and forebays shall be kept
clean of any sediment.
g. The Facility shall be maintained in a manner to control insects, odors and algae as determined necessary by
the City Engineer.
h. Any fencing or other security measures shall be maintained in good condition. If no fencing or security
measures are included with the original construction, they shall be added at the Permittee's expense at such
time as the City Engineer determines that unauthorized persons are disturbing the Facility and that security
measures will help prevent such unauthorized activity.
4. Right of Inspection by City. The Permittee hereby grants the City the right, privilege and easement over and
cross the Property lying between any public street or right of way and the Facility for the purpose of
inspecting, correcting, repairing, replacing or maintaining the Facility as provided in this Agreement. This
right, privilege and easement is appurtenant to and shall run with the Property.
5. Remedies for Violations of this Agreement.
a. If the Permittee shall fail to maintain or repair the Facility as set forth herein, or otherwise violates this
Agreement, the city may order the Permittee to undertake the necessary repair or maintenance or to correct
such violation. If the Permittee shall fail to comply with such order within thirty (30) days from the date
thereof, the permltee shall be considered in violation of this agreement and Chapter 8 of the LDC and will be
subject to penalties as provided in section 1205 of the LDC and pursuant to the authority contained in Article
19 of Chapter 160A, Planning and Development and 15A NCAC 2B.0258. Should the permitee fail to make
the required corrections within 30 days of the issuance of the civil penalty, the City may enter the Property
and perform all necessary work to place the Facility in proper working condition. The full cost of performing
the work including administrative costs and penalties shall be assessed as a lien on the property.
b. The City shall have the right to bring an action and recover sums due, damages, seek injunctive relief,
and/or such other and further relief as may be just and appropriate.
c. The remedies provided by this paragraph are cumulative; and are in addition to any other remedies provided
by law.
6. No Waiver of Breach. In the event of a breach of any term of this Agreement, any delay or failure on the
part of the City to exercise any rights, powers, or remedies herein provided shall not be construed as a
waiver thereof or acquiescence of such breach or any future breach.
7. Amendments. This Agreement may be amended, revised or modified only by a written document signed by
the parties.

BOOK 14 91 PAGEo'7 40
8. Bindina Effect. The conditions and restrictions set forth herein with regard to the Facility shall run with the
land and shall bind the Permittee and its successors and assigns and all parties claiming by, through, or
under them shall be taken to hold, agree, and covenant with the City, with its successors and assigns, and
with each of them to conform to and observe said conditions and restrictions. The City shall be deemed a
beneficiary of the conditions and restrictions set forth herein and such conditions and restrictions shall run
with the land in favor of the City.
9. Warranties of Title. The Permittee covenants and warrants that it is lawfully seized and possess of the
Facility and real estate described in Appendix 1, that it has good right and lawful authority to enter into this
Agreement for the purposes herein expressed, and that no consent or waiver by the holder of any mortgage,
deed of trust, or other security instrument, or any other person, fine, or corporation is required prior to
entering into this Agreement.
10. Interpretation. Use of the masculine gender.herein includes the feminine and neuter, and the singular
number used herein shall equally include the plural. The captions preceding the various provisions of this
Agreement are for the convenience of reference only, and shall not be used as an aid in interpretation or
construction of this Agreement.
11. Severabilily. Invalidation of any one of these covenants or conditions by judgement or order of any court
shall in no way affect any of the other provisions, which shall remain in full force and effect.
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals this the day and year first
above written.
Full Cia;le Solutions. Inc
M I :W •�,�
Shane Flynn, Site'Manager
136 Full Circle
Rocky Mou 27804
City of Rocky Mount
Director of Engineering
STATE OF NORTH CAROLINA
COUNTY OF 1�1 ox�lh
I, I rn a notary public in and for said county and state, certify that
F personally appeared before me d»s date, stated that he or she is
rjt ae✓ of r ti IA Il�.4+1�iiOn<_ 71rr. ,andacknowledged
the execution of the foreg6ing instrument with the City of Rocky Mount on behalf of said
Pt I iI C1AC (a SOL1io„c
This the of 5 day of t VA A 20101
tn„ -�4
Notary Public
My Commission Expires: ", a _ t� O I 1
(SEAL)
' OFFICIAL SEAL'
�j ,� . Notary PulNic, North Carolina
`� �� County of Nash
�? Kim Hear
M issi nE 'rea

Bog 14 91 PAGE 014 8 •
STATE OF NORTH CAROLINA
COUNTY OF II t�l GS
I, \0- r,e C YO` a notary public in and for said county and state, certify
that I ni - \ �' �> - kz -c personally appeared before me this day, stated that he or
she is the Director of Engineering of the City of Rocky Mount, a municipal corporation, and that by authority
duly given and as the act of the City, foregoing contract was signed in its corporate name by its
i re c-- o- o �— n ze ' no
This the ')- . day of h , 20 07
Notary Public
My Commission Expires:
Elaine C. Pate
(SEAL) Notary Publio
Nash County, NC

BOOK 1491 PAOJ6749
NORTH CAROLINA STORM WATER FACILITY OPERATION
EDGECOMBE COUNTY AND MAINTENANCE AGREEMENT
Appendix 1
Legal Description of the Facility for Full Circle Solutions, Inc. Detention Pond:
See PC 9, Slide 17 recorded in Edgecombe County Registry for description of the stormwater
easement.

BOOK 14 91 PAOE 015 0
City of Rocky Mount
BMP Maintenance Plan (for Commercial Sites)
This document must be filled out completely and recorded as an Addendum to the Operation &
Maintenance Agreement
Project Name: Full Circle Solutions, Inc
PIN: 382650338100
Project Location: 136 Full Circle
Date ofProject Construction: March 2007
a) Date that BMP(s) will begin operating as designed: April 2007
b) Description of BMP(s):
(Attach additional
sheets as necessary)
Detention basin
c) Attach Plan and Profile views of BMP(s) on A r/z x I 1 inch paper at a reasonable scale. These plans
should clearly show all areas of the BMP(s) including as -built (and accepted) elevations and contours as
well as all details of the control structure(s) and outfall(s). Additionally any easements pertaining to the
operation and/or maintenance of the BMP(s) must be shown.
d) Attach a narrative outlining the method of operation of the BMP(s), including normal operating
procedures or minimum standards required for the BMP(s) to produce the required results.
e) Provide a definition and description of the maintenance activities and schedule that are required for the
continued successfi l operation of the BMP(s). The following documents are provided by the NC State
University BAE Department, and provide detailed guidance as to the required maintenance of wet ponds
and wetlands (htt)://www.bae.ncsu.edu/stormwater/PublicatioiiFiles/WetlwidMaintenance2OO6.I)dl) and
bioretention cells (htto://www.bae.ncsu.edu/stormwater/PubticationFilesBioretcndon2006.vdf1.
f) Provide a simple annual budget for maintenance and inspection and include the source of funding (i.e.
POA, Owner, Trust, etc.). Some typical expenses might be Inspection by a Registered Professional
Engineer, Invasive Plant Removal, Sediment Removal, Routine Maintenance and Repair, etc.
g) To be signed by land owner responsible for operation and maintenance of the BMP(s):
I, - ..n e certify and acknowledge that I am
(individually / a corporate officer, managing member, or otherwise authorized to sign for and on behalf
of rvli C rcl z a North Carolina
CO2Qoftpftc:!J which is) responsible for the maintenance and operation of the
Stormwater BMP(s) described herein (BMP(s)). I understand that the Operation & Maintenance
Agreement, of which this document is an addendum, legally binds me/the corporation to perform the
maintenance activities set forth in this addendum, and by signing below I agree to same. I understand
that as a part of carrying out iry responsibility of the continued maintenance of the BMP(s), I am/the
corporation is required to submit to the City of Rocky Mount Engineering Department an annual BMP
Inspection Report certified by a North Carolina registered professional engineer prior to the end of each
Page 1 of 2

BGBK 14 9 1 PAGE 04 1
calendar year. Furthermore, I understand and agree that I am/the corporation is responsible for correcting
any problems found that result in the improper operation of the BMP(s) at any time.
SignedJ. K�-Z `%� � Dated: 7 / 7 —0
STATE OF NORTH CAROUNA COUNTY OF OOLSh
1, —K M IJ par n , a notary public in and for said county and
state, certify that Shan e. M F u n r personally appeared before
my this day, stated that he/she is S i 4e Mcizna PY of
Full Ci✓C.le. SOlrii:OnS r Mir and acknowledged the execution of the
foregoing
/� instrument with the City of Rocky Mount on behalf of said
Flt l U .1 -de <10 I uk-A i QVI S
This is the I I day of_apby_ 20 0.7 V;n `W f-�
Notary Public (Sign)
My Commission Expires �oti_t t } 2011
rAFFICIAL SEAL • Notary Public (Print)
No ��a"ry"""i�'ublic, NoM CaroFna
i y . County of Nash
M Comrrnsswn Ex H eer
h) To be certified by the Professional Engineer preparing this document:
I Peter W. Sokalski, PE
a registered professional
engineer in the State of North Carolina, hereby certify that the foregoing BMP Maintenance Plan was
prepared under my responsible charge and that it is of sufficient detail and accuracy to ensure, to the extent
reasonably possible, the continued successful operation of the BMP(s) described herein if followed.
C ARl/y/i
(Seal) \�� �C ... , C� ✓i✓
02295:.'
i A•:Ci` rLQ; ••�
��✓✓iWit lISO\\�`\
I-'-'R.vW. II/1l06
Dated:- �
Page 2 of 2

BMBOOK 14 9 1 PAfj�15 2P Maintenance Plan - AttaLents Page 1
ITEM d) Narrative of BMP Operation:
The Detention Basin operates by collecting stormwater from the runoff area and temporarily storing the
water and releasing the water at an engineered rate through an outlet pipe. The basin stores the water
and should be dry within 2 to 3 days after a stone event. No permanent water storage is designed for
the system.
ITEM e) Maintenance Activities and Schedule:
Maintenance activities shall be performed as follows:
Description
Method
Frequency
Time of Year
Inspect the dry detention basin system for sediment
Visual
After every significant
All year
accumulation, erosion, trash accumulation, vegetated
runoff producing rainfall
cover, and general condition.
event or monthly
Check and clear the orifice of any obstructions.
Visual
After every significant
All year
runoff producing rainfall
event or month)
Repair eroded areas immediately, re -seed as necessary
Visual
After every significant
All year
to maintain good vegetative cover
runoff producing rainfall
event or month)
Mow vegetative cover
Mechanical
As needed to maintain
All year
maximum grass height of
6..
Inspect and repair the collection system (i.e. catch
Visual
Quarterly,
All year
basins, piping, swales, riprap, etc.) to maintain proper
functioning.
Remove accumulated sediment from the dry detention
Mechanical
Semi-annually or when
All year
basin system. Removed sediment shall be disposed of
or by hand
sediment accumulation is
in an appropriate manner and shall be handled in a
noticed.
manner that will not adversely impact water quality (i.e.
stockpiling near a stream etc.).
Level spreaders or other structures that provide diffuse
Mechanical
Semi-annually
All year
Flow. All accumulated sediment and debris shall be
or by hand
removed from the structure, and a level elevation shall
be maintained across the entire Flow spreading structure.
Any down gradient erosion must be repaired and/or
replanted as necessary.
BASIN DIAGRAM (rill in the blanks)
MAIN POND
The basin is to be a "dry detention basin", in which there is no permanent pool of water designed. If there appears
to be standing water over a long period of time, the system is not in good working order and the problem should be
corrected immediately.
Full Circle Solutions, Inc. April 16, 2007

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FULL CIRCLE SOLUTIONS-
STORMWATER RIWP POND
ADA AND LEGAL DISCLAIMER
This document Is not represented to comply with all requlremeols contained In the ADA o,
other laws. Engineers are not licensed to interpret laws or give advice concerning laws, the
owner should have this document reviewed by his attorney to determine legal compliance.
DATE: I CONSULTING ENGINEERS, P.A. "
REV. 4-18-07 CIVIL, MUNICIPAL III ENGINEERS 11/
SHEET AI COMPREHENSIVE ENVIRONMENTAL SERVICES O Q O O
1 OF 1 P.O. Boll 7966 / RaekT Mpunl, N.C. 27804
phone: [phone] www.applanenginvers.com ���;��
SCALE 1n=40• Fax: (252) ) 972-77 E-Nall: od www.applanonginun.com
a.N. 06-084 BOUNDARY DESCRIPTION SHOWN IS NOT FOR RECORDATION
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, a Itlq,l.0.
111 tY, t
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FULL CIRCLE SOLUTIONS-
STORMWATER RIWP POND
ADA AND LEGAL DISCLAIMER
This document Is not represented to comply with all requlremeols contained In the ADA o,
other laws. Engineers are not licensed to interpret laws or give advice concerning laws, the
owner should have this document reviewed by his attorney to determine legal compliance.
DATE: I CONSULTING ENGINEERS, P.A. "
REV. 4-18-07 CIVIL, MUNICIPAL III ENGINEERS 11/
SHEET AI COMPREHENSIVE ENVIRONMENTAL SERVICES O Q O O
1 OF 1 P.O. Boll 7966 / RaekT Mpunl, N.C. 27804
phone: [phone] www.applanenginvers.com ���;��
SCALE 1n=40• Fax: (252) ) 972-77 E-Nall: od www.applanonginun.com
a.N. 06-084 BOUNDARY DESCRIPTION SHOWN IS NOT FOR RECORDATION

NG&I)to35Z
EPA Form 3510-11 (10-80)
❑r1
United Stales EnviroForm Approvednmental Protection Agency OMB No. 2040-0211
NPOES A ^ Washington, DC 20460
FORM NS
3570-17 Lsr dd����'�� EPA NO EXPOSURE CERTIFICATION for Exclusion from
NPDES Storm Water Permitting
Submission of this No Exposure Cenification constitutes notice that the entity identified in Section A does not require permit canonization for its storm water
discharges assoc-laled with industrial activity in the Stale identified In Section B under CPA"s Storm Water MunlSector Geneml f!'mhd due retire existence
of a condition of no exposure.
A condition of no exposure exists at an industrial facility when all industrial materials and activities are protected by a storm resistant shelter to prevent
exposure to min. snow, snowmelt, andlor touch, Industrial materials or activities include, but are not limped to, material handling equipment or activities,
industrial machinery, raw materials. intermediate products, by-pmducs, final products, or waste products. Material handling activities include the storage,
leading and unloading, transportation, or conveyance of any raw material, intermediate product, final product or waste pmducl. 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 du not teak, "Sealed"
means banded Or otherwise seolred and without operational laps or valves;
- adequately maintained vehicles used in material handling; and
- final products, other than products that would be mobilized in storm water discharges (e.g., rock sah).
A No Exposure Certification must be provided for earb taclllty qualifying for the no exposure exclusion, in addition, the exclusion from NPDES permlttng is
available on a focilM-wide basis only, not for individual outfalls. it any industrial activities or materials are or will be exposed to precipitation, the facility is
not eligible for the no exposure exclusion.
13Y signing and submitting this No Exposure Certification form, lye entity in Section A is certifying that a condition of no exposure exists at its facility or site.
and is obligated to comply with the terms and conditions of 40 CFR 122.26(g).
ALL INFORMATION MUST BE PROVIDED ON THIS FORM
D.tail.d instructions for compluling this form and obtaining the no expo.... exclusion .ra p seriA.d an pag.4 3 and 4
A. Facility Operator Information
I. N.me: FILI It_$L.I la I%IRIG t-tq--l 1411(VL-IVrC7 k ICYNISI 111AJI P1 I I IJ 2. Phone: 17171 n151 i 1%171QI11-71
3. Mailing Address: a. Street: Iloilo 1.51 Ire OIL I L I y I ILIAIIJIEj 1JIJd I TI iA II1010 1 1 1 1 1 1 1 1
b. City: 1, JNo in 101`::t :I MP Iiu I 1 1 1 , I I I I I I I I c.State: �I d. Zip Code: I.310ii, I'd' A i-t3iloi9 ll
B. FacilityfSite Location
-IInforrm'a'tion
1. Fa6lity Name: IE it A L L1
2. a. Street Address: l t_T.LSL`ol7
b. City: ILL, 1TI TI L—I�—J `
d. Slate: k1 J e, Zip Code) gE-LLS'101 �I -' ICJ
1. Is the facility located on Indian Lands? Yes No [N
4. Is this a Federal facility? Yes No
5. a. Latitude: (yb I " L of 91.1 b. Longitude: Iola i -7 ` LgL..W ?o i I� I
6. a. Was the facility ce site previously omered under an NPDES storm water permit? Yes f_ No j3
b. If yes, enter NPOES permit ouni
7. SIC/Activity Codes'. Primary: r-i " I Secondary (if appiirabin)'. I I I I
B. Total size of site associated with industrial aclivily:
acres
9. a. Have you paved or roofed over a formerly exposed, pervious area in order to qualify for the no exposure exclusion? YeS
In. If yes, please indicale approximately how much area was paved or moled over Completing this question does not disqualify you for the no exposure
exclusion. However. your permitting authority may use this information in considering whether storm water discharges from your site are likely to have
an adverse impact on water quality, in which case you could be required to obtain permit coverage.
Less than one ace D One to five was n More than we acres 7
i n
/Page t of 4 tlxl
�O I-

NPOES
FORME
3510-11
NO EXPOSURE CERTIFICATION for Exclusion from
PA NPOES Storm Water Permitting
Form Approved
OMB No. 2040.0211
C. Exposure checklist
Are any of the following materials or activities exposed to precipitation, now or in the bese mble future?
(Please check either'Yes' or "No' in the appropriate box.) If you answer"Yes" to any of thew questions
(1) through (11). you ere not eIigiN. for the no expoaure exdusion.
Yes
No
1. Using, storing or clearing industrial machinery or equipment, and areas where residuals from using, storing
❑
3I
or cleaning industrial machinery or equipment remain and are exposed to storm water
2. Materials or residuals on the ground or in storm water inlets from spills/leaks
❑
f
3. Materials or products from past industrial activity
❑
IIJfv
4. Material handling equipment (except adequately maintained vehicles)
❑
,L�,(
�1
5. Materials or products during loading)untoading or transporting activities
❑�/
G. Metoriols oh products statue outdoors (oxcept final products intended for outside use [e.g., new cars] where
El
�V
exposure to storm water does not result in the discharge of pollutants)
7. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, rind similar containers
❑
B. Materials or prmucls hamlled/smen on roads or raihxays owned or maintained by the dimharger
❑
9. Waste material (except .waste in covered, non -leaking containers fe.g., dumpsters])
❑
Q
10, Application or disposal of process wastewater (unless otherwise permitted)
❑
ryi
lJ
11. Pmtic tale matter or visible deposits of residuals from roof stocks and/or vents not otherwise regulated
❑
(i.e., under an air quality control permit) and evident in the storm water outflow
D. certification statement
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a rendition of "no exposure' and obtaining an
exclusion from NPDES storm water permitting.
I certify under penalty of law that there are no discharges ofstorm water 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 certification form once "cry five years to the NPUES permitting authority and, B requested, to
the operator of the local municipal separate storm sewer system (MS4) into which the facility discharges (where applicable). I understand that 1 must
allow the NPOES permitting authority, 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 pubticy available upon request. I understand that 1 must obtain coverage under an NPOES permit prior
to any point source discharge of storm worth trout the facility.
Addy. imally. 1 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 submnted is to the best of cry
knowledge and belief two, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility
of Fine and imprisonment tar knowing violations.
Print Narne'IRIOIgIFIIi'ITI 171 wtAltiDI21018 I I ;I I I I I I I I l I I L—i—J
Print Title: V 1 I CAI ICI A�1Ei/$it�IEINtTi 11 1 1 1 1 1 1 1 1 1 1 1 I I I
Signature:_4fKiVL� --f --- _----------
Date: 10131016101>I
ERA Form 3510-11 (10.99) rage a or 9

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United States Environmental Protection Agency Form Approved
g y OMB No. 2040-0211
NODES ®®�� Washington, Nfo
0460
FORM `�' NO EXPOSURE CERTIFICATION
ON for Exclusion from
3510-11
NODES Storm Water Permitting
Submission of this No Exposure Certification constitutes notice that ([identify identified in Section A does not require permit authorization for ifs storm water
discharges associated with industrial activity in the State Identified In Section B under EPA's Storm Water Multi -Sector General Permit due to the existence
of a condition of no exposure.
A condition of no exposure exists at an industrial facility when all industrial materials and activities are protected by a storm resistant shelter to prevent
exposure to min, 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 Without operational laps or valves;
- adequately maintained vehicles used in material handling; and
- final products, other than products that would be mobitized in storm water discharges (e.g., rock sa10.
A No Exposure Certificatlon must be provided for each facility qualifying for the no exposure exclusion. In addition, the exclusion from NPDES permitting Is
available on a tecility-wide basis only, not for individual outfails. 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, the entity in Section A is certifying that a condition of no exposure exists at its facility or site,
and is obligated to comply with the terms and conditions of 40 CFR 122.26(g).
ALL INFORMATION MUST BE PROVIDED ON THIS FORM
Detailed instruction, for completing this form and obtaining the no exposure exclusion are provided on pagan 3 and 4
A. Facility Operator Information
1. Name: 57 ILt I L I L le t I�kGLIFI 1 S 011_ I ulT1 t I C4 AJ in l Ij:IAJI CI I 1 1 12. Phone: [phone] i 171710I t 1-71
3. Mailing Address: a.Street tOltol.51 JMOILILIyI ILRIWIJ_1 ni&U-1 iI TIM 1110D I I t I I I I 1
b,C1y: I I I I I I I I 1 I I I I c.Slate: LCL� d.ZipCode: 1310111�1�1-1311o1g1�
B. FacilirylSite Location Information
1. Facility Name: 1FIli ILILI ICi IZI01LIIcI I'(ol l It if —\I l l CrfQI ril IVIWIC-j I I I 1 1
2. a. Street Address: lillikoll� IIFIw L14 iC-ItIQIC1LIG1 1 I I i t I I I I I I I I I I
b. City: brii Ti Ti Lia 16r,Ie_ici I I i I i ly_I I I I c,County: Irk 19
1 el CInIIY ble1
d.State: WJ e.Zip Code: aI (IQi101(j1-1 I I I
3. Is the facility located on Indian Lands? Yes ❑ No [A00
Urn
4. is this a Federal facility? Yes ❑ No ® 2, A -:;t:
5. a. Latitude: « . �� I01J b. Longitude: C}171,� OI I� mF
D r
6. a. Was the facility or site prevbusy covered under an NODES storm water permit? Yes ❑ No
A Cc
b. If yes, enter NPDES permit number _ 0 p �,
7. SIC/Activity Codes: Primary: Secondary(if applicable): I I I I i� DC C�)
8. Total size of site associated with industrial activity: ___—___—acres P
9. a. Have you paved or roofed over a formerly exposed, pervious area in order to quality for the no exposure exclusion? Yes ❑
b. If yes, please indicate approximately how much area was paved or roofed over. Completing this question does not disqualify you for the no exposure
exclusion. However. your permitting authority may use this information in considering whether storm water discharges from your site are likely to have
an adverse impact on water quality, in which case you could be required to obtain permit coverage.
Less than one acre ❑ One to five acres ❑ More than five acres ❑
EPA Form 3510-11 (10-99) Page 1 of 4

NPOES
FORMEl
3510-11
ZoEPANO EXPOSURE CERTIFICATION for Exclusion from
NPDES Storm Water Permitting
Form Approved
OMB No, 2040-0211
C. Exposure Checklist
Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future?
(Please check either "Yes' or "No' in the appropriate box.) If you answer "Yes" to any of these questions
(1) through (11), you are not eligible for the no exposure exclusion.
Yes
No
1. 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 storm water
2. Materials or residuals on the ground or in storm water inlets from spills/leaks
❑
�{
�J
3, Materials or products from past industrial activity
❑
1[X
4. Material handling equipment (except adequately maintained vehicles)
❑
Rf
5. Materials or products during loading/unloading or transporting activities
❑
6. Materials or products stored outdoors (except final products intended for outside use [e.g,. new canal where
❑
�1❑-/�
u
exposure to storm water does not result in the discharge of pollutants)
7. Materials contained in open, deteriorated or leaking storage drams, barrels, tanks, and similar containers
❑
6. Materials or products handlealstored on roads or railways owned or maintained by the discharger
❑
9. Waste material (except waste in covered, non -leaking containers (e.g., dumpsters))
❑
ld�
u
10. Application or disposal of process wastewater (unless otherwise permitted)
❑
11. Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated
❑
(i.e.. under an air quality control pemlit) and evident in the storm water outflow
D. Certification Statement
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 storm water permitting.
I certify under penalty of law that there are no discharges or storm water 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 submit a no exposure certification form once every five years (o the NPDES permitting authority 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 NPDES permitting authority, or MS4 operator where the discharge is into the local M54, to perform inspections to confirm the condition of no
exposure and to make such inspection reports publicly available upon request. I understand that I must obtain coverage under art NPDES permit prior
to any point source discharge of storm water 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 wigs 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. 1 am aware that there are significant penalties for submitting false information, including the possibility
of fine and imprisonment for knowing violations.
Print Natne: �Pli;lE lli',171 111 11✓IAI�ID IR IRJ PI_I 1 L1_J�
Print Title: IV I! IClrl lit?Ljr 1�_IDI /V7" U I i I I I I I I I I I I I I I I
Signature: 9_ �1'����iJ_
Date: 10t31016 WiX
EPA Form 3510-11 (10-99) Page 2 of 4

---------- --
NPDES Instructions for the NO EXPOSURE CERTIFICATION for Form Approved
FORM �riEP/� OMB No. 20400211
a FORM
Exclusion from NPDES Storm Water Permitting
Who May File a No Exposure Certification Section B. Facility/Site Location Information
Federal law at 40 CFR Part 122.26 prohibits point source discharges of
storm water associated with industrial activity to waters of the U.S. without
a National Pollutant Discharge Elimination System (NPDES) pemAt. However,
NPDES permit coverage is not required for discharges of storm water
associated with industrial activities identified at 40 CFR 122.26(b)(14)(i)-
fx) and (xi) if the discharger can certify that a condition of "no exposure'
exists at the industrial facility or site.
Storm water discharges from construction activities identified in 40 CFR
122.26(b)(14)(x) and (b)(15) are not eligible for the no exposure exclusion.
Obtaining and Maintaining the No Exposure Exclusion
This form is used to certify that a condition of no exposure exists at the
industrial facility or site described herein. This certification is only applicable
in jurisdictions where EPA iz the NPDES permitting authority and must be
re -submitted at least once every five years.
The industrial facility operator must maintain a condition of no exposure at
its Facility or site in order for the no exposure exclusion to remain applicable.
If conditions change resulting in the exposure of materials and activities to
storm water, the facility operator must obtain coverage under an NPDES
storm water peril immediately.
Where to File the No Exposure Certification Form
Mail the completed no exposure certification form to:
Storm Walor No Exposure Certification (4203)
USEPA
401 M Street, SW
Washington, D.C. 20460
Completing the Form
You must type or print, using uppercase letters, in appropriate areas only.
Enter only one character per space (i.e., between the marks). Abbreviate
If necessary to stay within me number of characters allowed for each item.
Use one space for breaks between words. One form must be completed
for each facility or site for which you are seeking to certify a condition of no
exposure. Additional guidance on completing this form can be accessed
through EPA's web site at mm.epa.gov/owm/sw. Please make sure you
have addressed all applicable questions and have made a photocopy for
your records before sending the completed form to the above address,
Section A. Facility Operator Information
1. Provide the legal name of the person, firm, public organization, or any
other entity that operates the facility or site described in this certification
The name of the operator may or may not be the same as the name of
the facility. The operator is the legal entity that controls the facility's
operation, rather than the plant or site manager.
2. Provide the telephone, nwober of the facility operator.
3. Provide the mailing address of the operator (P.O. Box numbers may be
used). Include the city, state, and zip code. All correspondence will
be sent to this address.
1. Enter the official or legal name of the facility or site.
2. Enter the complete street address (if no street address exists, provide
a geographic description [e.g.. Intersection of Routes 9 and 551). city,
county, state, and zip code. Do not use a P.O. Box number.
3. Indicate whether the bm ity is located on Indian Lands.
4. Indicate whether the industrial facility is operated by a department or
agency of the Federal Government (see also Section 313 of the Clean
Water Act).
5. Enter the latitude and longitude of the approximate center of the facility
or site in degrees/minutes/seconds. Latitude and longitude can
be obtained from United States Geological Survey (USGS) quadrangle
or topographic maps, by calling 1-(888) ASK-USGS, or by accessing
EPA's web site at http7/www.epa.gov/owrnisw/industry/index.htm and
soldering Latitude and Longitude Finders under the Resources/Permit
section.
Latitude and longitude for a facility in decimal form must be converted
to degrees (1), minutes I'). and seconds (") for proper entry an
the certification form. To convert decimal latitude or longitude to
degmes/minutes/seconds. follow the steps in the following example.
Example: Convert decimal latitude 45.1234567 to degrees (°), minutes
('), and seconds (").
a) The numbers to the left of the decimal point are the degrees: 4Y
b) To obtain minutes, multiply the first four numbers to the right of the
decimal point by 0.006: 1234 x 0.006 = 7.404.
c) The numbers to the left of the decimal point in the result obtained
in (b) are the minutes, 7'.
d) To obtain seconds, multiply the remaining three numbers to the
right of the decimal from the result obtained in to) by 0.06:
404 x 0.06 = 24,24. Since the numbers to the right of the decimal
point are not used, the result is 24".
e) The conversion for 45.1234567 = 45- '1' 24".
6. Indicate whether the facility was previously covered under an NPOES
storm water permit. If so. Include the permit number.
7. Enter the 4-digit SIC code which identifies the facility's primary activity,
and second 4-digit SIC code identifying the facility's secondary activity.
if applicable. SIC codes can be obtained from the Standard Industrial
Classification Manual, 1987.
It. Enter the total size of the site associated with industrial activity in acres,
Acreage may be determined by dividing square footage by 43,560, as
demonstrated in the following example.
Example: Convert 54,49) ftz to acres
Divide 54,450 fit by 43,560 square feet per acre:
54,450 ftz+43,560 ftz/acre = 1.25 acres.
9. Check Nes or'No' as appropriate to indicate whether you have paved
or roofed over a formerly exposed, pervious area (i.e., lawn, meadow,
did or gravel road/parking lot) in order to qualify for no exposure. It yes,
also indicate approximately how much area was paved or roofed over
and is now Impervious area.
EPA Form 3510-11 (10-99) Page 3 of 4

NPDES Instructions for the NO EXPOSURE CERTIFICATION for Form Approved
FORM dG EPA OMB No. 2040-0211
3510-11 Exclusion from NPDES Storm Water Permitting
Section C. Exposure Checklist
Check "Yes' or "No' as appropriate to describe the exposure conditions at
your facility. If you answer "Yes'to ANY of the questions (1) through (11)
In this section, a potential for exposure exists at your site and you cannot
certify to a condition of no exposure. You must obtain (or already have)
coverage under an NPDES storm water permit. Alter obtaining permit
coverage, you can institute modifications to eliminate the potential for a
discharge of storm water exposed to industrial activity, and then certify to
a condition of no exposure.
Section D. Certification Statement
Federal statutes provide for severe penalties for submitting false information
on this application form. Federal regulations require this application to be
signed as follows.
For a corporation! by a responsible corporate officer, which means:
(i) president, secretary, treasurer, or vice-president of the corporation
in charge of a principal business function, or any other person
who performs similar policy or decision making flmctions for the
corporation, or
(h) the manager of one or more manufacturing. production, or
operating facilities, provided the manager is authorized to make
management decisions which govern the operation of the
regulated facility including having the explicit or implicit duty of
making major capital investment recommendations, and initiating
and directing other comprehensive measures to assure long
term environmental compliance with environmental laws and
regulations; the manager can ensure that the necessary systems
are established or actions taken to gather complete and accurate
information for permit application requirements; and where
authority to sign documents has been assigned or delegated to
the manager in accordance with corporate procedures:
For a partnership or sole proprietorship: by a general partner or the
proprietor; or
For a municipal, State, Federal, or other public facility: by either a
principal executive or ranking elected official.
Paperwork Reduction Act Notice
Public reporting burden for this certification is estimated to average 1.0 hour
per certification, including time for reviewing instructions, searching existing
data sources, gathering and maintaining the data needed, and completing
and reviewing the collection of information. Burden means the total time,
effort, or financial resources expended by persons to generate, maintain,
retain, or disclose to provide information to or for a Federal agency. This
includes the time needed to review instructions; develop, acquire, install,
and utilize technology and systems for the purposes of collecting, validating,
and verifying information, processing and maintaining information, and
disdosing and providing information; adjust the existing ways to comply with
any previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources:
complete and review the collection of information; and transmit or otherwise
disclose the information. An agency may not conduct or sponsor. and a
person Is not required to respond to, a collection of information unless it
displays a currently valid OMB central number. Send comments regarding
the burden estimate, any other aspect of the collection of information, or
suggestions for improving this form, including any suggestions which may
increase or reduce this burden to: Director, OPPE Regulatory Information
Division (2137), USEPA, 401 M Street, SW, Washington, D.C. 20460.
Include the OMB control number of this form on any correspondence. Do
not send the completed No Exposure Certification form to this address.
EPA Form 3510-11 (10-99) Page 4 of 4

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