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HomeMy WebLinkAboutNCGNE0981_COMPLETE FILE - HISTORICAL_20140218A C4,w 11Z�d STORMWATER DIVISION CODING SHEET NCG PERMITS PERMIT NO. DOC TYPE HISTORICAL FILE ❑ MONITORING REPORTS DOC DATE ❑ YYYYMMDD r NC®ENR North Carolina Department of Environment and Natural Resources Division of Energy, Mineral and Land Resources Land Quality Section Pat McCrory, Governor Tracy E. Davis, PE, CPM John E. Skvada, III, Secretary Director February 18, 2014 Mr. Dana Norvell Nomaco, Inc. 3006 Anacondo Road Tarboro, NC 27886 Subject: Approval of No -Exposure Certification Nomaco, Inc. NCGNE0981 Edgecombe County Dear Mr. Norvell: The Division of Energy, Mineral and Land Resources (DEMLR) has reviewed your submittal of the No - Exposure Certification for Exclusion from the NPDES Stormwater Permitting form and made a site visit to assess the potential for stormwater pollution. Based on our observations and your submittal and signed certification of no exposure at the above referenced facility, the Division is granting your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is incorporated by reference in North Carolina regulations. Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no - exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no -exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge (subject to civil penalties of up to $25,000 per day). Your conditional no -exposure exclusion does not expire. However, you must self re -certify annually, or obtain NPDES permit coverage for any stormwater discharges from your facility. Please retain the completed re -certification forms to have them available during future inspections by DEMLR. 1628 Mail Service Center, Ralegh, North Carolina 27699-1628 Location: 3800 Barrett Drive, Raleigh, North Carolina 27609 �rOne 1 Phone: 919-791-42001 FAX: 919-571-4718 No rtl L, l C aro l 1 na Internet: http:portal. Affirr orActionE dVaturally An Equal Opportunity 1 AtilrtnaGve Action Employer Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. If you have any questions or need further information, please contact Dave Parnell at (919) 791-4200 or at david.parnellCtncdenngov. Sincerely, L. Holley, Jr., RE, CPESC final Engineer gh Regional Office cc: Stormwater Permitting Program Files - with attachment Raleigh Regional Office DEMLR No Exposure Files - with attachment 1628 Mail service Center, Raleigh, Nonh Carolina 27699-1628 Location: 3800 Barrett Drive, Ralegh, North Carolina 27609 One Phone: 919-791.42001 FAX: 919-571-4718 North C�lrOhna Internet: http:pnity\AcrmauteAcmlE Aawa��f An Equal Opportunity A;armative Ac',ion Employer b! { ` Compliance Inspection Report Permit: NCGNE0981 Effective: Expiration: Owner: Nomaco Inc SOC: Effective: Expiration: Facility: Nomaco Inc. County: Edgecombe 3006 Anaconda Rd Region: Raleigh Tarboro NC 27886 Contact Person: Peyton Stamper Title: Phone: 252-563-1763 Directions to Facility: System Classifications: Primary ORC: Certification: Phone: Secondary ORC(s): On -Site Representative(s): Related Permits: NCG050364 Nomaco Inc - Nomaco Inc / Spongex, LLC Inspection Date: 02/05/2014 Entry Time: 10:30 AM Exit Time: 12:00 PM Primary Inspector: David R Parnell Phone: 919-791-4260 Secondary Inspector(s): ' Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, No Exposure Certificate ` Facility Status: ■ Compliant ❑ Not Compliant Question Areas: ® Miscellaneous Questions E Misc (See attachment summary) Page:1 Permit: NCG050364 Owner -Facility: Nomaco Inc Inspection Date: 02/05/2014 .Inspection Type: Compliance Evaluation Reason for Visit: Routine Inspection Summary: Page:2 Permit: NCGO50364 Owner - Fa cilityr Nomaco Inc - - - •Inspection Date: 02/05/2014 Inspection Type: Compliance Evaluation . _Reason for Visit: Routine _ - F Stormwater'Pollution Prevention Plan ' Yes No NA NE . ' Does.the site have'a Stormwater Pollution Prevention Plans ■ ,Q ❑ El - n # Does the Plan include a General Location (USGS) map? ■ .Q' ❑ Q # Does the Plan include a Narrative Description of Practices"? - `' ■ ❑ ❑ Q , - -= # Does; the Plan include a detailedsite map including outfall locations and drainage areas?' '.■ Q ❑ ❑ ' # Does the Plan include a list of significant spills occurring during' the 3.years? - ■, Q Q Q past At Has theJacility: evaluated feasible alternatives to current practices? _ . ■ Q ❑ Q'. _ - #Does the facility provide all necessary seconoary containment? - - '. ', ■ -,❑- Q Q # Does'the'Plan include a BMP summary? ' ", - '� ❑. Q . ❑ -. - `I f - # Does the Plan include a Spill Prevention-and,Response Plan.(SPRP)? _ - ■ Q Q Q - - # Does thePlan iriclude a Preventative Maintenance and Good Housekeeping Plan? - Q ❑ Q - . # Doe.s the'facility provide end, document Employee Training? .. Is ■. Cl ❑_ Q # Does the Plan include a list of,Responsible Party(s)?: - - '❑:.❑ ❑ -- - # Is the Plan reviewed and updated annually?... - - -; ■ Q Q ❑ ; ' ` # Does the Plan include. a•Stormwatw Facility Inspection Program? .■ ❑ ('i ❑ - - Hasthe�Stormwater• Pollution Prevention Plan�been implemented? - ■ ❑ -Q.. ❑ Comment. The•current SPPP covers Nomaco in addition to the adjacent Spongex- - site. New SPPP.-- specific- for.each:.facilitymust be _created within 6 months. Spongex . must send in an NOYsince the two'are no longer financially aligned. Plan reviewd, but suggested to client.that the two have theirown.SPPP.F: - Qualitative Monit6rin9 - - - - Yes No NA NE - , Has the facilityconducte-dits Qualitative Monitoring "semi-annually?. - . ■ Q Q Q _ . Comment SDO will change due to splitting off of Spongex Permit and Outfalls .. ; Yes No Na NE l # Is a copy of the Permit and the. Certificate of Coverage availabe.at the site?. - ■. ❑,` ❑ ❑'. - ' - # Were all outfalls observed during the inspection? ■ Q Q 0 - # If the facility -has representative outfall-status, is it properly documented by the Division? - ❑ 91.0 Q # Has the facility evaluated all illicit (non slormivater) discharges?'' • . - - ■ Q, 0 Q Comment' All.SDO were observed for facility (taking`Spongex out of the site plan). Compliant. No Exposure was granted -this inspspection. Annual Certificat ion must be ' done..,' ` Page: 3 - ,. 4 rJc(,uE t % wa(W'A- P"I, a ; 1&v-)-je ab.. Ce Scisiiw+ 0� NCG6S03G4 t.h letler. ®�E Division of Water Quality / Surface Water Protection NC®ENR National Pollutant Discharge Elimination System s NO EXPOSURE CERTIFICATION for Exclusion NCGNE0000 FOR AGENCY USE ONLY D=R= m Year Mono Da) 11 1 Cmifi= of Covers NO EXPOSURE CERTIFICATION National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based on NO EXPOSURE: Submission of this No Exposure Certification constitutes notification that your facility does not require a permit for 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, snowmelf, and/or runoff. For permitted facilities in North Carolina, DWI] 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 acffv/tles, 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 !or your area. (See page 6) (Please print or type) 1) Mailing address of ownerloperator (address to which all certification correspondence will be mailed): Name Contact Street Address City Telephone No. Email Page 1 of 7 ECE k 01V 1 2 2M SWU-NE-12Aug=0 NCGNE0000 No Exposure Certification Exposure Checklists (12. - 14.) 12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? (Please check either "Yes" or "No.") if you answer "Yes" to any of these items, you are no eligible for the no exposure exclusion. a. Using, storing, or cleaning industrial machinery or equipment, and areas where O Yes fi1'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 spillslleaks ❑ Yes &No c. Materials or products from past industrial activity ❑ Yes YNo d. Material handling equipment (except adequately maintained vehicles) ❑ Yes RNo e. Materials or products during loading/unloading or transporting activities ❑ Yes gf'No I. Materials or products stored outdoors (except final products intended for outside ❑ Yes g'No use [e.g., new cars] where exposure to stormwater does not result in the discharge of pollutants) g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, 0 Yes V No and similar containers `� h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes 2/No the discharger I. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes C"No .j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes Ao k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes Aci otherwise regulated (i.e., under an air quality control permit) and evident in the stormwater outflow I. Empty containers that previously contained materials that are not properly stored — ❑ Yes 2�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 dNo stored outside, has the facility had any releases in the past three (3) years? 13) Above Ground Storage Tanks (ASTS): If you answer "No" to any of the following items, you are not eligible for the no exposure exclusion. a. Are exterior ASTs and piping free of rust, damaged or weathered coaling, pits, or ❑ Yes ❑ No G?N/A deterioration, or evidence of leaks? b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No RrN/A cracks, holes, or evidence of leaks, and are drain valves maintained locked shut? Page 3 of 7 SW U-NE-12AU92010 NCGNE0000 No Exposure Certification 14) Secondary Containment: If you answer "No" to any of the following Items, you are not eligible for the no exposure exclusion. a. Is secondary containment provided for all single above ground storage ❑ Yes 0 No e'N/A containers (including drums, barrels, etc.) with a capacity of more than 660- gallons? b. Is secondary containment provided for above ground storage containers stored ❑ Yes ❑ No O N/A In close proximity to each other with a combined capacity of more than 1,320- gallons? c. Is secondary containment provided for Title III Sectian 313 Superfund ❑ Yes ❑ No Q-N/A Amendments and Reauthorization Act (SARA) water prioritychemicals'? d. Is secondary containment provided for hazardous substances" designated in 40 ❑ Yes ❑ No taUA CFR §116? e. Are release valves on all secondary containment structures locked? ❑ Yes ❑ No C;,N/A 15) Hazardous Waste: a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes GMo b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste orYes ❑ No generated per month) of hazardous waste? c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste ❑ Yes B No 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 st( Where is material How many disposal shipments per year: Name of transport / disposal vendor: L Vendor address: el-*2-0 Al Footnotes to Questions 14) c. & d. 'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for de minimis amounts of certain substances, and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR §372.38. "Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR §117.3. Page 4 of 7 S W U-NE-12Aug2010 NCGNEO000 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? 0 Yes CAO b. Does your facility have coal piles on site? c. Does your facility store other fuel sources outside in piles, such as wood chips, sawdust, etc.? d. Does your facility have air emissions associated with its industrial activity (e.g., degreasing operations, plating, painting and metal finishing)? If so, describe the r l .ftd a-)k4ew�, o�q� industrial activity: e. If you answered yes to d., argthose emissions permitted by an Air Quality Permit? Please specify: f -1 «+r if $ O OS.S 4 ! /(f I. 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: ❑ Yes afCo ❑ Yes "o e*Yes ❑ No Yes ❑ No ❑ WA Page 5 of 7 S W U-NE-12AU92010 NCGNE0000 No Exposure Certification 17) Certification: I certity 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 stornwater 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 recertification to DWO 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 ogint 5gurce di charae of stormwater from the facility Additionally, 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 submitted is to the ldest 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. ,, 4 Printed Name of Person Signing: SoT T Title: of Applicant) It d (Da a Stgned) 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 lncnect vour 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 arty 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, lampers 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 SWU-NE-12Au92010 35-53.000' N j ((J IiM11 VI I 3 1 N r 5 10' N N X,-Su.uuu N gg 0 J \ 2 � o It Lit / y :. =rill i Y� s 1�2Y� \. J,. A 10' N 35-56.000' N 3o�, h 14011le H NOMACQ Wa Can $r UW !u¢albar Nomaco Inc. Sot NMC Drive Zebulon, N: 275)7 Te: gt9.269.5Sno 80u.i45./2!Y Fax: 919.269.7936 wowv.nomacacon NC Department of Energy, Minerals and Land Resources Stormwater Permitting Unit Attn: Mr. Bradley Bennett 512 N. Salisbury Street 9'" Floor Raleigh, North Carolina 27604 October 14, 2013 RE: Request for No Exposure Certification for Exclusion from NPDES Storm Water Permitting Nomaco Incorporated —Tarboro Facility Tarboro, NC Mr. Bennett: Nomaco, Incorporated (Nomaco) owns and operates a foam manufacturing facility in Tarboro, North Carolina. The site currently has two operations that fall under the requirements for a common site. These operations are the Nomaco foam extrusion/production operations and the Spongex, LLC (Spongex) foamed thermoplastic operations. The facilities have one General Permit No. NCG 050000 and Certificate of Coverage No. NP-CIL5064, N( Co So 3 4 4 The Spongex operations are being sold to SwimWays Corp. Upon review of the SW permitting forms, Nomaco feels that the Nomaco operations can meet the No Exposure Certification similar to their Zebulon. NC facility since the Spongex operations are no longer under the same permit. Nomaco is submitting this request for a NOE for Exclusion from NPDES Storm Water Permitting. Federal law at 40 CFR Part 122.26 prohibits point source discharges of storm water associated with industrial activity to discharge to the waters of the U.S. without a NPDES permit. However, NPDES permit coverage is not required for discharges of storm water associated with industrial activities identified at 40 CIF 122.26(b)(14)(i)-(ix) and (xi) if the discharger can certify that a condition of "no exposure" exists at the industrial facility or site. Nomaco certifies that a condition of no exposure exists at the facility. All industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Nomaco will, if approved, maintain a condition of no exposure at the facility so that the no exposure exclusion remains applicable. If conditions change resulting in the exposure of materials and activities to storm water, the facility will obtain coverage under a NPDES storm water permit. Nomaco has enclosed the required NOE form in Attachment 1. Thank you for DWQ's consideration of our request for the No Exposure Certification. If you have any questions regarding the information in this letter, please feel free to contact Peyton Stamper at 252-563-1763. ,in rely, 7 Scott Edwards President Nomaco Inc 3800 Barrett Dr, Raleigh, NC 27609 to 1405 Martin Luther King Jr Dr, Tarboro, NC 278... Page 1 of 2 Directions to 1405 Martin Luther King Jr Dr, Oogle Tarboro, NC 27886 74.4 mi - about 1 hour 14 mins 3800 Barrett Dr, Raleigh, NC 27609 1. Head west on Barrett Dr toward Haworth Dr go 0.1 mi total 0.1 mi 2. Turn right onto Six Forks Rd go 0.4 mi About 47 secs total 0.5 mi 3. Slight right to merge onto 1-440 E/Cliff Benson Beltline go 4.9 mi About 5 mins total 5.4 mi 4. Take exit 14 toward US-64 E/US-264 E/Wilson/Rocky Mt go 0.8 mi About 47 secs total 6.1 mi 5. Merge onto Interstate 495/US-264 E/US-64 E go 3.2 mi About 3 mins total 9.3 mi 64 6. Continue onto US-264 E/US-64 E go 13.6 mi About 11 mins total 22.9 mi 64 7. Keep left to stay on US-64 E, follow signs for Rocky Mont Tarboro go 39.9 mi About 33 mins total 62.9 mi 8. Take exit 478 for Kingsboro Rd go 0.4 mi total 63.3 mi (� _ 1 9. Turn left onto Kingsboro Rd go 0.6 mi About 47 secs total 63.9 mi 10. Turn right onto US-64 Alt E/US-64 BUS E go 4.2 mi About 5 mins total 68.0 mi 11. Turn right onto McNair Rd go 1.1 mi About 2 mins total 69.1 mi 12. Take the 2nd left onto Anaconda Rd go 0.3 mi Destination will be on the left total 69.4 mi Total: 69.4 mi - about 1 hour -3mins lel3006 Anaconda Rd, Tarboro, NC 27886 total 0.0 mi 13. Head east on Anaconda Rd go 1.2 mi About 2 mins total 1.2 mi 1 14. Turn right toward Sunset Ave Exd go 0.2 mi total 1.3 mi 15. Take the 1 st left onto Sunset Ave Exd go 0.3 mi total 1.6 mi 16. Take the 1st right onto Western Blvd go 1.2 mi About 3 mins total 2.9 mi 17. Turn left onto W Wilson St go 1.0 mi About 2 mins total 3.8 mi 18. Turn left onto N Main St go 0.2 mi total 4.0 mi 19. Take the 2nd right onto E Baker St go 0.3 mi About 1 min total 4.3 mi https:Hinaps.g000le.con-/maps?mod&source=s_d&saddr=3800+Barrett+Drive.+Raleigh.+N... 2/4/?m a NCGNE0000 No Exposure Certification 2) Location of facility producing discharge: Facility Name /Vovrtdf6 Iv`c Facility Contact _ Facility Street Address City _ County Telephone No. _ Email 3) Physical location Information: State _ N_ _G ZIP Code Fax: Please provide a narrative description of how to get to the facility (use street names, state road numbers, and distance and direction from a roadway intersection). Fx; )` PtY H (4 -L m,-I-a no, ovt t1fe Nail1ZJ,^ R` a, 6t aa+,2 A dnrasdo kd--/S00 4 +' "f/owile'a-E..�►nn"to�[rl°F (A copy of a map with the�facllity arly located on it should be included with the certification application.) 4) Is the facility located on Native American Lands? ❑ Yes O1Vo 5) Is this a Federal facility? ❑ Yes emo 6) Latitude 3S °SP �if/ Longitude 77".PS 20 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 M'� Existing Date operation began /Z-2 ❑ Renewal of existing No Exposure Certification Certification No.: NCGNE 8) Was this facility or site ever covered under an NPDES Stormwater Permit? 01'es ❑ No If yes, what is the NPDES Permit Number? /fz c Os 03 6 f- 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: - 0 &_ 10 10) Provide a brief description of the types of industrial activities and products produced at this facility: it j f. q—=L4 can ..�tf;i i.. •� &&pa"da j*a/-Ll 11) Does this facility have any Non -Discharge permits (ex: recycle permits)? 0170 ❑ Yes If yes, list the permit numbers for all current Non -Discharge permits for this facility: Page 2 of 7 SWU-NE-12Aug2010 {r NC®ENR North Carolina Department of Environment and Natural Division of Energy, Mineral and Land Resources Land Quality Section Tracy E. Davis, PE, CPM Director February 18, 2014 Mr. Dana Norvell Nomaco, Inc. 3006 Anacondo Road Tarboro, NC 27886 Subject: Approval of No -Exposure Certification Nomaco, Inc. NCGNE0981 Edgecombe County Dear Mr. Norvell: Resources Pat McCrory, Governor John E. Skvarla, III, Secretary The Division of Energy, Mineral and Land Resources (DEMLR) has reviewed your submittal of the No - Exposure Certification for Exclusion from the NPDES Stormwater Permitting form and made a site visit to assess the potential for stormwater pollution. Based on our observations and your submittal and signed certification of no exposure at the above referenced facility, the Division is granting your conditional exclusion from permitting as provided for under 40 CFR 126.22(g), which is incorporated by reference in North Carolina regulations. Please note that by our acceptance of your no -exposure certification, you are obligated to maintain no - exposure conditions at your facility. If conditions change such that your facility can no longer qualify for a no -exposure exclusion, you are obligated to immediately obtain NPDES permit coverage for your stormwater discharge. Otherwise, the discharge becomes subject to enforcement as an un-permitted discharge (subject to civil penalties of up to $25,000 per day). Your conditional no -exposure exclusion does not expire. However, you must self re -certify annually, or obtain NPDES permit coverage for any stormwater discharges from your facility. Please retain the completed re -certification forms to have them available during future inspections by DEMLR. 1628 Mail service Center, Raleigh, North Carolina 27699-1628 Location: 38008arred Drive, Raleigh, North Carolina 27609 t�rOne t, 1 Phone: 919-791-42001 FAX: 919-571471E NorthCarolina Ila Internet: hfp:pMal.ncdenr.org/webgr/ /itLrrLilly An Equal Opportunity1 Affirmative Action Employer Your conditional exclusion from permitting does not affect your facility's legal requirements to obtain environmental permits that may be required under other federal, state, or local regulations or ordinances. If you have any questions or need further information, please contact Dave Parnell at (919) 791-4200 or at david.parnellPncdenr.gov. Sincerely, L. Holley, Jr., RE, CPESC onal Engineer igh Regional Office cc: Stormwater Permitting Program Files - with attachment Raleigh Regional Office DEMLR No Exposure Files - with attachment 1628 Mail service Center, Raleigh, North Carolina 27699-1628 Location: 3800 Barrett Drive, Raleigh, North Carolina 27609 One Phone: 919-791-42001 FAX: 919-571-4718 North Carolina Internet hltp:portaLncrmativ ActionlE dVaturally An Equal Opponunity 1 Affirmative Action Employer Permit: NCGNE0981 Effective: SOC: Effective: County: Edgecombe Region: Raleigh Compliance Inspection Report Expiration: Owner: Nomaco Inc Expiration: Facility: Nomaco Inc. 3006 Anaconda Rd Contact Person: Peyton Stamper Title: Directions to Facility: System Classifications: Primary ORC: Certification: Secondary ORC(s): On -Site Representative(s): Related Permits: NCG050364 Nomaco Inc - Nomaco Inc / Spongex, LLC Tarboro INC 27886 Phone: 252-563-1763 Phone: Inspection Date: 02/05/2014 Entry Time: 10:30 AM Exit Time: 12:00 PM Primary Inspector: David R Parnell Phone: 919-791-4260 Secondary Inspector(s): Reason for Inspection: Routine Inspection Type: Compliance Evaluation Permit Inspection Type: Stormwater Discharge, No Exposure Certificate Facility Status: S Compliant Cl Not Compliant Question Areas: Miscellaneous Questions E Misc (See attachment summary) Page:t Permit: NCG050364 Owner -Facility: Nomaco Inc Inspection Date: 02/05/2014 .Inspection Type: Compliance. Evaluation Reason for Visit: Routine Inspection Summary: Page:2 Permit: NCGO50364 Owner -Facility: Nomaco Inc Inspection Date: 02105/2014 Inspection Type: Compliance Evaluation Reason for Visit: Routine Stormwater Pollution Prevention Plan Yes No NA NE Does the site have a Stormwater Pollution Prevention Plan? ■ ❑ ❑ ❑ It Does the Plan include a General Location (USGS) map? ■ ❑ ❑ ❑ # Does the Plan include a "Narrative Description of Practices'? ® ❑ ❑ ❑ # Does the Plan include a detailed site map including outfall locations and drainage areas? ■ ❑ ❑ ❑ At Does the Plan include a list of significant spills occurring during the past 3 years? ■ ❑ ❑ ❑ # Has the facility evaluated feasible alternatives to current practices? ■ Cl ❑ ❑ At Does the facility provide all necessary secondary containment? ■ ❑ ❑ ❑ At Does the Plan include a BMP summary? ■ ❑ ❑ ❑ # Does the Plan include a Spill Prevention and Response Plan (SPRP)? ■ ❑ ❑ ❑ # Does the Plan include a Preventative Maintenance and Good Housekeeping Plan? ■ ❑ ❑ ❑ # Does the facility provide and document Employee Training? ■ ❑ ❑ ❑ # Does the Plan include a list of Responsible Party(s)? ■ ❑ ❑ ❑ # Is the Plan reviewed and updated annually? ■ ❑ ❑ n It Does the Plan include a Stormwater Facility Inspection Program? ■ ❑ Cl ❑ Has the Stormwater Pollution Prevention Plan been implemented? ■ ❑ ❑ ❑ Comment: The current SPPP covers Nomaco in addition to the adjacent Spongex site. New SPPP - specific - for each facility must be created within 6 months. Spongex must send in an NOI since the two are no longer financially aligned. Plan reviewd, but suggested to client that the two have their own SPPP. Qualitative Monitoring Yes No NA NE Has the facility conducted its Qualitative Monitoring semi-annually? ■ ❑ ❑ ❑ Comment: SDO will change due to splitting off of Spongex. Permit and Outfalls Yes No NA NE # Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ ❑ ❑ # Were all outfalls observed during the inspection? ■ ❑ ❑ ❑ # If the facility has representative outfall status, is it properly documented by the Division? ❑ ■ ❑ ❑ # Has the facility evaluated all illicit (non stormwater) discharges? ■ ❑ ❑ ❑ Comment: All SDO were observed for facility (taking Spongex out of the site plan). Compliant. No Exposure was granted this inspspection. Annual Certification must be done. Page: 3 S MC61JE s % alpfW- 6 PL-u ajol- 1"-- a abw{- fe ScissioA o� NCG6S03Gtf i K leVer. © r Division of Water Quality I Surface Water Protection .M NCDENR National Pollutant Discharge Elimination System NO EXPOSURE CERTIFICATION for Exclusion NCGNE0000 FOR AGENCY USE ONLY mm Rid Ys� Maa1b NIC 11 1 Cm we NO EXPOSURE CERTIFICATION National Pollutant Discharge Elimination System application for exclusion from a Stormwater Permit based on NO EXPOSURE: Submission of this No Exposure Certification constitutes notification that your facility does not require a permit for 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, snowme/t, and/or runoff. For permitted facilities in North Carolina, DWQ must approve your application for No Exposure Certification before this exclusion is effective. Unfit 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, bamals, tanks, and similar containers that are tightly sealed, provided those containers are not deteriorated and do not leak. "Seated" 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 on"ot for Individual outfalls. If any industrial activities or materials are, or will be, exposed to predpltation, the faci►l y is not eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification forth, 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 correspondence will be mailed): Name Contact Street Address City Telephone No. Email Pagel of 7 4,ov 1 3 20113 SWU-NE-12Aug2010 F a r NCGNE0000 No Exposure Certification Exposure Checklists (12. - 14.) 12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable future? (Please check either "Yes" or "No.") If you answer "Yes" to any of these items, you are eligible for the no exposure exclusion. a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes ANo 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 spillsAeaks ❑ Yes PrNo c. Materials or products from past industrial activity ❑ Yes YNo d. Material handling equipment (except adequately maintained vehicles) ❑ Yes g'No e. Materials or products during loading/unloading or transporting activities ❑ Yes Ao I. Materials or products stored outdoors (except final products intended for outside ❑ Yes IR No use (e.g., new cars] where exposure to stormwater does not result in the discharge of pollutants) g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes LAO and similar containers h. Materials or products handled/stored on roads or railways owned or maintained by tt� ❑ Yes LNo the discharger I. Waste material (except waste in covered, non -leaking containers [e.g., dumpsters]) ❑ Yes L/No j. Application or disposal of process wastewater (unless otherwise permitted) ❑ Yes r/No k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not ❑ Yes E(No otherwise regulated (i.e., under an air quality control permit) and evident in the stormwater outflow I. Empty containers that previously contained materials that are not property stored ❑ Yes 2iNo (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 12(No stored outside, has the facility had any releases in the past three (3) years? 13) Above Ground Storage Tanks (ASTs): it you answer "No" to any of the following items, you are not eligible for the no exposure exclusion. a. Are exterior ASTs and piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No M"A deterioration, or evidence of leaks? b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes ❑ No 2rN/A cracks, holes, or evidence of leaks, and are drain valves maintained locked shut? Page 3 of 7 SWU-NE-12Aug2010 i NCGNE0000 No Exposure Certification 14) Secondary Containment: If you answer "No" to any of the following Items, you are jol eligible for the no exposure exclusion. a. Is secondary containment provided for all single above ground storage ❑ Yes ❑ No OWA containers (including drums, barrels, etc.) with a capacity of more than 660- gallons? b. Is secondary containment provided for above ground storage containers stored ❑ Yes ❑ No &WA 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 0 Yes O No GI -N/A Amendments and Reauthorization Act (SARA) water priority chemicals'? d. Is secondary containment provided for hazardous substances" designated in 40 ❑ Yes ❑ No IRVA CFR §116? e. Are release valves on all secondary containment structures locked? ❑ Yes ❑ No I2M/A 15) Hazardous Waste: a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes 21No b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous waste eoVes ❑ No generated per month) of hazardous waste? c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste O Yes IN No 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 st Where is material How many disposal shipments per year: Name of transport / disposal vendor: Vendor address: el-*zU/V Footnotes to Questions 14) c. & d. 'Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for de minimis amounts of certain substances, and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR §372.38. "Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require secondary containment. However, some exceptions may be made for amounts less than the Reportable Quantities of the hazardous substances listed in 40 CFR §117.3. Page 4 of 7 SWU-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? b. Does your facility have coal piles on site? c. Does your facility store other fuel sources outside in piles, such as wood chips, sawdust, etc.? d. Does your facility have air emissions associated with its industrial activity (e.g., degreasing operations, plating, painting and metal finishing)? If so, describe the industrial activity: 22obd-&wr yZed or blew sq o aced e. If you answered yes to d., argg,those emissions permitted by an Air Quality Permit? Please specify: Pr f �� r.. r t $ O PSS 4 % /q I. 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: ❑ Yes cAo ❑ Yes QAo ❑ Yes "o 00Yes 0 No ET Yes ❑ No O WA Page 5 of 7 SWU-NE-12Aug2010 NCGNEO000 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•certity No Emosure and, if requested, submit the re -certification to DWQ or the operator of the local municipal separate stone 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 1 must obtain coverage under an NPDES permit odor to any point source discharge of slomfwater from the facility. Additionally, I certity 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. 1 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. ( /f Printed r� me of Person S>$ning: CoT T Title: rt-fSi d / otApplicanp // E (Da a Signe0 Please note: This application for the No Exposure Exclusion Is subject to approval by the NCDENR Regional Office prior to Issuance. The Regional OHke may inspect your facility for compliance with no exposure conditions prior to that approval. The Regional Office may also Inspect your facility at any time In the future for compliance with the No Exposure Exclusion. North Carolina General Statute 143-215.6 B([) provides that: Any person who knowingly makes any false statement, representation, or certification in any appBplkx% record, report, plan, or other document filed or required to be maintained under this Article or a rule implementing this Article; or who knowngly makes a false statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly random inaccurate any recording or monitoring device or method required to be operated or maintained under Ws Article or rules of the [Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine not to exceed ten thousand dollars ($I0,0DO). There Is currently no fee for a No Exposure Exclusion. Page 6 of 7 S W U-NE-12Aug2010 TOPOI map printed on 10/09/13 from "North Caro!ina.tpo' and'Untlded.tpg' w „-oo.ow v �l_�r 4\ _ ? �` I. •` Site Location f z !� J"',�� .i'• �e �7� fi 77=17 nnn' W 77-36.000' W 77°35.000' W 0 1=FEET 0 '.LO F=KIERl6 PriwM 5r. TO.'0! C_001 N., w GeocrpG H,,ldt-p (avu.,vpa.c—) \`1 1 z C r e Fp.W, WGS84 77-34.000' W 2R0 qov� k, �iollry ffa IN®iYt707Y CO We Can true Iagofher NC Department of Energy, Minerals and Land Resources Stormwater Permitting Unit Attn: Mr. Bradley Bennett 512 N. Salisbury Street gt° Floor Raleigh, North Carolina 27604 October 14, 2013 RE: Request for No Exposure Certification for Exclusion from NPDES Storm Water Permitting Nomaco Incorporated — Tarboro Facility Tarboro, NC Mr. Bennett: Nomaco, Incorporated (Nomaco) owns and operates a foam manufacturing facility in Tarboro, North Carolina. The site currently has two operations that fall under the requirements for a common site. These operations are the Nomaco foam extrusion/production operations and the Spongex, LLC (Spongex) foamed thermoplastic operations. The facilities have one General Permit No. NCG 050000 and Certificate of Coverage No. NCSi05 . N[r oSo3G y The Spongex operations are being sold to SwimWays Corp. Upon review of the SW permitting forms, Nomaco feels that the Nomaco operations can meet the No Exposure Certification similar to their Zebulon, NC facility since the Spongex operations are no longer under the same permit. Nomaco is submitting this request for a NOE for Exclusion from NPDES Storm Water Permitting. Federal law at 40 CFR Part 122.26 prohibits point source discharges of storm water associated with industrial activity to discharge to the waters of the U.S. without a NPDES permit. However, NPDES permit coverage is not required for discharges of storm water associated with industrial activities identified at 40 CIF 122.26(b)(14)(i)-(ix) and (xi) if the discharger can certify that a condition of "no exposure" exists at the industrial facility or site. Nomaco certifies that a condition of no exposure exists at the facility. All industrial materials and activities are protected by a storm resistant shelter to prevent exposure to rain, snow, snowmelt, and/or runoff. Nomaco will, if approved, maintain a condition of no exposure at the facility so that the no exposure exclusion remains applicable. If conditions change resulting in the exposure of materials and activities to storm water, the facility will obtain coverage under a NPDES Nomaco Inc. storm water permit. 5oi NMC Drive Zebulon, N-- 27597 Nomaco has enclosed the required NOE form in Attachment 1. Tel: 91g.a69.650o Thank you for DWQ's consideration of our request for the No Exposure Certification. If you S19.26 .7916 have any questions regarding the information in this letter, please feel free to contact Peyton Fa.c:919•zGg.�9;G Stamper at252-563-1763. www.110111r1co.co 1 Sin yely, Scott Edwards ICIV Ll— President 20UNomaco Inc •.P 3800 Barrett Dr, Raleigh, NC 27609 to 1405 Martin Luther King Jr Dr, Tarboro, NC 278... Page 1 of 2 Directions to 1405 Martin Luther King Jr Dr, Good a Tarboro, NC 27886 74.4 mi - about 1 hour 14 mins 3800 Barrett Dr, Raleigh, NC 27609 1. Head west on Barrett Dr toward Haworth Dr go 0.1 mi total 0.1 mi 2. Turn right onto Six Forks Rd go 0.4 mi About 47 secs total 0.5 mi ® 3. Slight right to merge onto 1-440 E/Cliff Benson Beltline go 4.9 mi About 5 mins total 5.4 mi 4. Take exit 14 toward US-64 E/US-264 E/Wilson/Rocky Mt go 0.8 mi About 47 secs total 6.1 mi 5. Merge onto Interstate 495/US-264 E/US-64 E go 3.2 mi About 3 mins total 9.3 mi 6. Continue onto US-264 E/US-64 E go 13.6 mi 64 About 11 mins total 22.9 mi 64 7. Keep left to stay on US-64 E, follow signs for Rocky Mont Tarboro go 39.9 mi About 33 mins total 62.9 mi 8. Take exit 478 for Kingsboro Rd go 0.4 mi total 63.3 mi 9. Turn left onto Kingsboro Rd go 0.6 mi About 47 secs total 63.9 mi A 10. Turn right onto US-64 Alt E/US-64 BUS E go 4.2 mi 1 About 5 mins total 68.0 mi 11. Turn right onto McNair Rd go 1.1 mi r About 2 mins total 69.1 mi 12. Take the 2nd left onto Anaconda Rd go 0.3 mi Destination will be on the left total 69.4 mi Total: 69.4 mi - about 1 hour 3 mins 4 3006 Anaconda Rd, Tarboro, NC 27886 total 0.0 mi 13. Head east on Anaconda Rd go 1.2 mi About 2 mins total 1.2 mi 14. Turn right toward Sunset Ave Exd go 0.2 mi total 1.3 mi 15. Take the 1st left onto Sunset Ave Exd go 0.3 mi total 1.6 mi 16. Take the 1st right onto Western Blvd go 1.2 mi About 3 mins total 2.9 mi 17. Turn left onto W Wilson St go 1.0 mi About 2 mins total 3.8 mi 18. Turn left onto N Main St go 0.2 mi total 4.0 mi ri 19. Take the 2nd right onto E Baker St go 0.3 mi 1 About 1 min total 4.3 mi https:Hmaps.google.com/maps?mod&source=s_d&saddr=3800+Barrett+Drive +Raleigh.+N... 2/4/2014 3800 Barrett Dr, Raleigh, NC 27609 to 1405 Martin Luther King Jr Dr, Tarboro, NC 278... Page 2 of 2 20. Continue onto Martin Luther King Jr Dr go 0.7 mi Destination will be on the right total 5.0 mi About 2 mins Total: 5.0 mi — about 12 mins 1405 Martin Luther King Jr Dr, Tarboro, NC 27886 These directions are for planning purposes only. You may find that construction projects, traffic, weather, or other events may cause conditions to differ fromttje map results, and you should plan your route accordingly. You must obey all signs or notices regarding your route. Map data ©2014 Google https:Hmaps.google.comlmaps?f—d&source=s_d&saddr=3800+Barrett+Drive +Raleigh +N... 2/4/2014 NCGNE0000 No Exposure Certification 2) Location of facility producing discharge: Facility Name _ Facility Contact _ Facility Street Address City County Telephone No. 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 from a roadway intersection). �¢�, f�» -Le no. o.r v I — f?..,-4. _._l A_. '_'4_ aJ -/Soo F+F %. A/otif_e/d Crf'(' (A copy of a map with the acility clearly located on it should be included with the certification application.) 4) Is the facility located on Native American Lands? ❑ Yes 0140 5) Is this a Federal facility? ❑ Yes of No 6) Latitude 3S'Sf - I f'9" Longitude 77'-?S 10° 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 e Existing Date operation began ///c17 ❑ Renewal of existing No Exposure Certification Certification No.: NCGNE 8) Was this facility or site ever covered under an NPDES Stormwater Permit? ErYes ❑ No If yes, what is the NPDES Permit Number? 14/ G Gs o3 L f- 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: -3— o & 6 10) Provide a brief description of the types of industrial activities and products produced at this facility: y fru�/ 1 d ce.n u'rS (,d �.. if aeKr1 ��yo (r&gq F"Mjn2 11) Does this facility have any Non -Discharge permits (ex: recycle permits)? 210170 ❑ Yes If yes, list the permit numbers for all current Non -Discharge permits for this facility: Page 2 of 7 SWU-NE-12Aug2010