NCGNE1347_Application_20190319

NCCTJr-; 12,247
Environmental
Quulity
Division of Energy, Mineral and Land Resources
Land Quality Section
National Pollutant Discharge Elimination System
NO EXPOSURE CERTIFICATION for Exclusion
NCGNE0000
FOR AGENCY USE ONLY
Date Received
Year
Month
Day
%j
Certificate of Coverage
NC NE
MAR 19 2013
r�� ®�gE� QLwimit based
National Pollutant Discharge Elimination System application for exclusion fro
on NO EXPOSURE: R PERM i l'ING
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter (with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certification before this exclusion is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed" means
banded or otherwise secured and with locked or non -operational taps or valves; adequately maintained
vehicles used in material handling; and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility -wide basis only —not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
If approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST BE self re -certified at least annually.
Please look for information about re -certification under the NQ EXDQSurs section on this page:
httDs://dea.nc.aov/about/divisions/enerav-mineral-land-resources/energv-mineral-land-Dermits/stormwater-
perm its/npdes-industrial-sw
For questions, please contact the DEMLR 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 Caro O vet,. pk iG uiL{ LL.0
Contact
Street Address
City
Telephone No.
Brenda Wells
4328 Federal [Dr., Suite 105
Greensboro
336 668-0871
State NC ZIP Code 27410
Fax: [phone]
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SWU-NCGNE Last revised 9/28/2016

("KL INFH. L DER
Bright People, Right Solutions.
October 26, 2018
Kleinfelder Project No. 20190687.001A
DEMLR-Stormwater Program
Department of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27669-1612
Subject: Stormwater No Exposure Certification
DS Smith Packaging - Greensboro
Greensboro, North Carolina
Dear Mr. Sir or Madam:
RF0'E11y/r')
MAR 19 2013
DENR-LAND QUALIT(
aTORMWATER f Ers A'l i INQ
On behalf of DS Smith Packaging - Greensboro, Kleinfelder is submitting the enclosed NDPES
Stormwater No Exposure Certification and site location map.
Should you require any additional information, please contact Ms. Kimberly Bostic of DS Smith at
Kimberly. bostic(a)dssmith.com or Christine Brenk at cbrenk(c)kleinfelder.com.
Sincerely,
KLEINFELDER, INC.
Thomas Sipe
Staff Professional II
Christine K. Brenk, CHMM
Principal Professional
TS/CB:cas
Attachments: Facility Location Map
No Exposure Certification Form
Cc: Ron Holman, North America Environmental & Safety Engineer, DS Smith
Kimberly Bostic, DS Smith Packaging - Greensboro
20190687.001A I CLT18R79961 October 26, 2018
© 2018 Kleinfelder www.kleinfelder.com

NCGNE0000 No Exposure Certification
2) Location of facility producing discharge:
Facility Name
IDS Smith Packaging - Greensboro
Facility Contact
Kimberly Bostic
Street Address
4328 Federal Dr., Suite 105
City
Greensboro
County
Guilford
Telephone No.
336 391-6365
3) Physical location information:
State NC ZIP Code 27410
Fax: [phone]
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). From 140, take exit 211 Gallmore Dairy Rd and drive south on Gaiiimore
Dairy Road. Turn left onto Green Point Drive. Turn left onto Federal Drive.
(A copy of a rnap with the facility clearly located on it should be included with the certification application.)
A) Is the facility located on Native American I ands? El Yes ® No
5) Is this a Federal facility? M Yes M No
6) Latitude 31'03.40" Longitude -079°57'07" (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
0 New or Proposed Facility Date operation is to begin
19 Existing Date operation began Under ownership by DS Smith beginning 2017
r3 Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? E3 Yes 0 No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 7 5 2
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Printing operations
11) Does this facility have any Non -Discharge permits (ex: recycle permits)?
M No
0 Yes
If yes, list the permit numbers for all current Non -Discharge permits for this facility:
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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 not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where E3 Yes 13 No 0 N/A
residuals from using, storing or cleaning industrial machinery or equipment
remain and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks
a Yes 0 No in N/A
c. Materials or products from past industrial activity
G Yes p No E3 N/A
d. Material handling equipment (except adequately maintained vehicles)
0 Yes IJ No D N/A
e. Materials or products dur'Irig loading/unluadiny or transporting activllies
0 Yes FJ No C-i N/A
f. Materials or products stored outdoors (except final products intended for outside
0 Yes El No 13 N/A
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,
m Yes El No 13 N/A
tanks, and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained
0 Yes V-1 No 0 N/A
by the discharger
i. Waste material (except waste in covered, non -leaking containers [e.g., 13 Yes 19 No 0 N/A
dumpsters])
j. Application or disposal of process wastewater (unless otherwise permitted) 0 Yes CI No D N/A
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents 13 Yes M No 1711 N/A
not 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 E3 Yes p No p N/A
(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 0 Yes 13 No IS N/A
stored outside, has the facility had any releases in the past three (3) years`?
13) Above Ground Storage Tanks (ASTs): If you answer "No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or 13 Yes 0 No M 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 19 N/A
cracks, holes, or evidence of leaks, and are drain valves maintained locked
shut?
14) Secondary Containment: If you answer "No" to any of the following items, you are not eligible for the
no exposure exclusion.
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NCGNE0000 No Exposure Certification
a. Is secondary containment provided for single above ground storage containers 0 Yes O No M N/A
(including drums, barrels, etc.) with a capacity of more than 660-gallons?
b. Is secondary containment provided for above ground storage containers stored 13 Yes B No [E 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 Section 313 Superfund
Amendments and Reauthorization Act (SARA) water priority chemicals*?
d. Is secondary containment provided for hazardous substances** designated in
40 CFR §116?
e. Are release valves on all secondary containment structures locked?
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility?
b. Is this facility a Small Quantity Generator (less than 1000 kg. of hazardous
waste generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator (1000 kg. or more of hazardous waste
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information:
waste:
Type(s) of
How is material stored:
Where is material stored:
How many disposal shipments per year:
Name of transport / disposal
vendor:
Vendor address:
Footnotes to Questions 14) c. & d.
p Yes in No 01 N/A
Yes [3 No El N/A
12 Yes 0 No p N/A
MYes 0 No p N/A
M Yes 19 No p N/A
M Yes 19 No U N/A
*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.
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.
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NCGNE0000 No Exposure Certification
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: The facility has printing operations using inks and cleaners.
e. If you answered yes to d., are those emissions permitted by an Air Quality
Permit? Please specify: The facility is exempt from air permitting as emissions are less than 5 tons per year.
f. Please list any other environmental program permits (federal, Mate, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: Not Applicable Program: Not Applicable
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
0 Yes El No 13 N/A
[3Yes 03No ON/A
M Yes 0 No 13 N/A
M Yes 0 No 13 N/A
E3 Yes 13 No El N/A
Page 5 of 7
SW U-NCGNE Last revised 9/28/2016

NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of "no
exposure" and obtaining an exclusion from NPDES stormwater permitting.
I cortiry under penally ur law prat preps are riu discharges of sturrnwater currtarnhated by expusure to Industrial adlvlties 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 maintain no exposure conditions and complete a Self -Recertification form at least once
each year, and if requested, provide this certification to the operator of the local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of
Energy, Mineral, and Land Resources, 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. I understand I
must keep a copy of annual re -certifications on file at the facility.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDFS permit prier to any point source discharge of stormwater from the facility Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the Information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Signing: Rre-r,A n_ W Gl`S
of Applicant)
(Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the NCDEQ
Regional Office prior to issuance. The Regional Office may inspect your facility for compliance
with no exposure conditions prior to that approval. The Regional Office may also inspect your
facility at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-215.6 B(i) provides that:
Any person who knowingly makes any false statement, representation, or certification in any application, record, report, plan, or other
document filed or required to be maintained under this Article or a rule implementing this Article; or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article; or who falsifies, tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management] Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars ($10,000).
There is currently no fee for a No Exposure Exclusion.
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NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
DEMLR - Stormwater Program
Dept. of Environmental Quality
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions, please contact the DEMLR Regional Office for your area.
DEMLR Regional Office Contact Information:
Asheville Office ...... [phone]
Fayetteville Office ... [phone]
Mooresville Office ... [phone]
Raleigh Office ........ [phone]
Washington Office ... [phone]
Wilmington Office ... [phone]
Winston-Salem ...... [phone]
Central Office ......... [phone]
Page 7 of 7
SWU-NCGNE Last revised 9/28/2016

The information included on this graphic representation has been compiled from a
variety of sources and is subject to change without notice. Kleinfelder makes no
representations or warranties. express or implied, as to accuracy, completeness,
timeliness, or rights to the use of such information. This document is not intended for
use as a land survey product nor is it designed or intended as a construction design This map is from the U S G S 7.5-minute map for
document. The u of the information contained on this graphic
representation is at the sole risk of the party using or misusing the information. Guilford County 2016.
PROJECT NO.
DRAWN BY:
KLE//VFEL DER CHECKED BY: JA
Bright People. Right Solutions. DATE: 8/14/2018
REVISED:
LOCATION MAP
DS Smith Packaging Greensboro
4328 Federal Dr., Suite 105
Greensboro, NC 27409
FIGURE
1
KLEINFELDER - 9009 Perimeter Woods Dr., Suite H I Charlotte, NC 28216 1 PH: 704.598.1049 1 FAX: [phone] www.kleinfelder.com

McCoy, Suzanne
From: Bostic Kimberly <[e-mail]>
Sent: Wednesday, March 27, 2019 10:25 AM
To: McCoy, Suzanne; [e-mail]
Cc: Holman Ron
Subject: [Fxte.rnall RF: DS Smith Packaging - Greensboro Stormwater NCGNF Application
Good morning Ms. McCoy,
I am the HSE Manager for Greensboro and understand that the location's Information was not found under
IDS Smith. IDS Smith purchased several companies in the US over the last couple of years, including the
Holly Springs location you found. I just searched; the Greensboro location is still listed as Carolina Graphic
1 cervices, l l (- can the Sec'y of State's site The site manager has changed since the last update (now it is
Brenda Wells), but James Morgan is the President of IDS Smith's US operations. Let me know if you need
any other information to validate the company name/ownership, and 111 reach out to others in the company
who can help.
Mailing
4328 Federal Drive, Suite 105
Greensboro, NC 2741
Principal Office
4328 Federal Drive, Suite 10
Greensboro, NC 27410
Company Officials
All Ll-Cs are managed by their managers pursuant to K... 7J-3-2.
14 c alter
Keith Ledbetter
4328 Federal Drive, Suite 10
Greensboro NC 27 ,1
Mai alter
Jamga_Morgan
4323 Federal Drive, Suite 105
Greensboro NC 271

Secretary of State
Home C Want To.- k Divisions + Topics Online Service. 10
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Carolina Gravhic Services LLC
Kimberly Bostic
Regional Health, Safety and Environmental Manager
DS Smith, North America Packaging and Paper Division, United States
MI [phone] F [phone]
ki [e-mail]
From: McCoy, Suzanne <[e-mail]>
Sent: Wednesday, March 27, 2019 9:29 AM
To: Bostic Kimberly <[e-mail]>; [e-mail]
Subject: DS Smith Packaging - Greensboro Stormwater NCGNE Application
Good morning,
I am in receipt of the Stormwater No Exposure Certification Application for DS Smith Packaging — Greensboro facility.
2

Ore of the first things I must do for the application is to verify the owner entity is registered with the North Carolina
Secretary of State.
DS Smith Packaging does return any results. I have tried variations and only came up with DS Smith Packaging — Holly
Springs as an Assumed Name.
Is there a "Parent" owner entity?
Please advise.
Suzanne McCoy
Stormwater Program Administrative Specialist V
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
512 N. Salisbury Street, Office 640K, Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC 27699-1612
919-707-3640
Website: t.t . jf igc�.,-!.c.�,uv ,ci_��tfclivisi_u� sjelioi. y.::Eni.nera(.::Iarid.:resources/sormwater
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