Module I

   
 
Lesson Two: NPDES Stormwater Permit Program
 
 
             

Exposure Checklist for No Exposure Certification

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 rain, 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

  • Adequately maintained vehicles used in material handling

  • Final products, other than products that would be mobilized in storm water 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.

Answer the following questions with “Yes” or “No” to check whether you are eligible for No Exposure Certification.

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.
  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                                          Yes No
  2.  Materials or residuals on the ground or in storm water inlets from spills/leaks                                                      Yes No
  3.  Materials or products from past industrial activity                                                                                              Yes No
  4.  Material handling equipment (except adequately maintained vehicles)                                                                 Yes No
  5.  Materials or products during loading/unloading or transporting activities                                                               Yes No
  6.  Materials or products stored outdoors (except final products intended for outside use [e.g., new cars] where                  exposure to storm water does not result in the discharge of pollutants)                                                                Yes No
  7.  Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, and similar containers             Yes No
  8.  Materials or products handled/stored on roads or railways owned or maintained by the discharger                         Yes No
  9.  Waste material (except waste in covered, non-leaking containers [e.g., dumpsters])                                            Yes No
  10.  Application or disposal of process wastewater (unless otherwise permitted)                                                         Yes No
  11.  Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated (i.e.,                        under an air quality control permit) and evident in the storm water outflow                                                             Yes No

 
 
 
 

 

Copyright @ January,2005 Prepared by Transportation Environmental Resource Center (TERC)