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HomeMy Public PortalAboutCity of Ballwin July 13, 2016 Mr. Gary Kramer, P.E., City Engineer/Public Works Director City of Ballwin 200 Park Dr. Ballwin, MO 63011 RE: No Exposure Certification regarding Industrial Operations Dear Mr. Kramer: On June 24, 2016, Birhanu Kinfe, a representative of the Missouri Department of Natural Resources, conducted an inspection in response to the October 02, 2012 (enclosed) request for a renewal of No Exposure Certification MONX00044 that was issued on November 17, 2008. Your application for a No Exposure determination under EPA NPDES Form 3510-11 has been reviewed. It was determined that the Public Works Facility located at 200 Park Dr., Ballwin, MO to have no exposure to storm water or storm water runoff and operated in accordance with 10 CSR 20-6.200(1)B(16). Your renewed No Exposure Certification number, which is issued on the above date, is MONX00044. This letter serves as notice of exemption from the applicable storm water permit number MO-R80CXXX. At any time, the Department of Natural Resources may review the eligibility of this exemption. It is incumbent upon the Public Works Facility, to understand and comply with Regulation 10 CSR 20- 6.200(1) (B) (16) at all times or this exemption shall be void. The Public Works Facility, is required to notify the Department of Natural Resources in writing within 30 days of any actual or imminent violation of 10 CSR 20-6.200(1)(B)(16). This exemption will expire on July 12, 2021. Please reapply for exemption of the applicable storm water permit 60 days prior to this date. If you have any questions or comments, please direct them to Birhanu Kinfe of the St. Louis Regional Office by mail at the Missouri Department of Natural Resources, St. Louis Regional Office, 7545 S. Lindbergh Blvd., Suite 210, St. Louis, MO 63125; by phone at (314) 416-2960; or by email at birhanu.kinfe@dnr.mo.gov. Sincerely, ST. LOUIS REGIONAL OFFICE Dorothy E. Franklin Regional Director DEF/BK/hw Enclosure 1 No Exposure Inspection Checklist The purpose of the checklist is to help determine whether exposure of industrial activities, materials, and equipment to storm water has been eliminated at the facility. Please include comments referring to how the facility may correct any issue or why a No Exposure Certification should not be allowed. General No Exposure Questions Facility Name: Public Works Facility, City of Ballwin NPDES Permit # (if applicable): MONX00044 Person(s) Representing the facility during inspection: Jim Link 1 Are industrial materials and activities exposed to stormwater? (Industrial materials include, but are not limited to material handling equipment, industrial machinery, raw materials, intermediate products, by products, final products that are not intended for outdoor use, waste products, which include storing and cleaning of industrial material or equipment, areas were residuals remain.) Yes No (If yes, does not qualify.) Comments: Drums, Barrels, Tanks, or Similar Containers 2 Are drums, barrels, tanks, and similar containers that are exposed to stormwater tightly sealed and in good condition? (banded or otherwise secure without operational taps or valves, not leaking, or deteriorated) Yes No (If no, does not qualify.) Comments: 3 Are there any Aboveground Storage Tanks (ASTs) onsite ? Yes No (If no, disregard questions 4-7) Comments: No AST Is the capacity of the AST(s) greater than 20,000 gallons of petroleum product? (including pre/post- consumer products, ethanol or biodiesel) Yes No (If yes, does not qualify.) Comments (note- may qualify if connected to sanitary sewer.) No AST at the site 5 Are the ASTs associated with vehicle maintenance (EPA states ASTs must be physically separated and not associated with vehicle maintenance operations)? Vehicle maintenance is defined as: the rehabilitation, mechanical repairing, painting, fueling, and/or lubricating of a motor-driven conveyance that transports people or freight, such as an automobile, truck, train, or airplane. Yes No (If yes, does not qualify.) Comments: No AST 6 Are the ASTs pipes, pumps, or other equipment exposed to stormwater in good condition? Yes No (If no, does not qualify.) Comments: No AST at the site 7 Are the liquid materials within the secondary containment properly disposed? Yes No (If no, does not qualify.) Comments: No AST 2 Housekeeping and Maintenance 8 Are vehicles that are exposed to stormwater adequately maintained? Yes No (If no, does not qualify.) Comments: 9 Are materials or equipment cleaned outdoors? (e.g. vehicle and industrial equipment washing that is not otherwise regulated in the MOG76 permit) Yes No If yes, please describe what is being washed, if detergents are used, and if residuals are left on the ground. Comments: 10 Are good housekeeping practices being used in areas subject to exposure to stormwater, including spills/leaks (e.g. materials or residuals exposed to stormwater or within the collection system that can become mobilized)? Yes No (If no, does not qualify.) Comments: Clean parking lot observed 11 Do dumpsters have a lid, are they completely covered and materials not allowed to drain from any holes in the bottom, or be lost in loading onto a garbage truck? (Industrial refuse and trash that is stored uncovered is considered exposed.) Yes No (If no, does not qualify.) Comments: No Dumpsters 12 Are containers, racks, and other transport platforms (e.g. wooden pallets) for storage or conveyance of final products pollutant free? Yes No (If no, does not qualify.) Comments: No exposed containers or Pallets MS4 13 Are only stormwater discharges entering the storm drain system? Yes No (If no, does not qualify.) Comments: 14 Is the facility causing an adverse impact on water quality due to major changes at the site to achieve no exposure, such as constructing new building/shelters or constructing structures to prevent run-on in a formerly vegetated area? (An increase in impervious area often leads to an increase in volume and velocity of runoff, which, in turn, can result in a higher concentration of pollutants in the discharge, since fewer pollutants are naturally filtered out.) Yes No If yes, please explain what was constructed and address the concern for pollutants. Comments: Loading and Unloading or transporting 15 Are materials or products during loading/unloading exposed to stormwater? Yes No (If yes, does not qualify.) Comments: Residuals and other activities 16 Is there any particulate matter or visible deposits of residuals from roof stacks and/or vents that can be mobilized by wind (including industrial activities with stack emissions or process dusts that settle on surfaces.)? Yes No (If yes, does not qualify.) Comments: 3 Residuals and other activities (continued) 17 Are there any materials or products from past industrial activity exposed to stormwater? (e.g. a site that is superfund, or major spills occurred at this site causing long term environmental effects) Yes No (If yes, does not qualify.) Comments: Process Wastewaters 18 Is there now or in the foreseeable future any application or disposal of process wastewater exposed to stormwater (unless otherwise permitted)? Yes No (If yes, does not qualify.) Comments: 19 Are any materials stored or disposed in outdoor ponds or impoundments? Yes No (If yes, does not qualify.) Comments: Storm Resistant Shelters 20 If the storm resistant shelter is only top cover and no side covers, is the material stored under the cover subject to any run-on and subsequent runoff? (e.g., a pile of sawdust that is protected by a roof but not four walls that is placed into a large roll off container) Yes No (If yes, does not qualify.) Comments: No Storm Resistant shelter. All storage is under a roof. 21 Is the company using any type of temporary covered storage (i.e. tarps)? How long? ( EPA recommends temporary sheltering of industrial materials and activities only allowed during facility renovation or construction but provides the NPDES permitting authority to address the issue on a case by case basis) Yes No Comments: Final Products 22 Are the final products intended for outdoor use deteriorated or otherwise be a potential source for pollutants in stormwater? Yes No (If yes, does not qualify.) Comments: 23 Are there any leakage/spills around the buildings where product is being stored? Yes No (If yes, does not qualify.) Comments: No Exposure Determination 24 Does the facility meet the "no exposure" certification requirements? Yes No Comments: 25 If yes, did you terminate their previous permit if needed? Yes No Comments: 4 Photo: #1 Date Taken: 6/24/2016 By: Birhanu Kinfe Facility: Public Works Facility, City of Ballwin No Exposure Certification: MONX00044 Description :Main Office of the Facility Photo: #2 Date Taken: 6/24/2016 By: Birhanu Kinfe Facility: Public Works Facility, City of Ballwin No Exposure Certification: MONX00044 Description : Vehicles Maintenance building 5 Photo: #3 Date Taken: 6/24/2016 By: Birhanu Kinfe Facility: Public Works Facility, City of Ballwin No Exposure Certification: MONX00044 Description : Well-maintained vehicles at the parking lot Photo: #4 Date Taken: 6/24/2016 By: Birhanu Kinfe Facility: Public Works Facility, City of Ballwin No Exposure Certification: MONX00044 Description : Dome for Salt Storage NPDES FORM 3510-11 i\1to1'3X000`f+ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC 20460 NO EXPOSURE CERTIFICATION FOR EXCLUSION FROM NPDES STORMWATER PERMITTING Form Approved OMB No. 2040-0211 Submission of this No Exposure Certification constitutes notice that the entity identified in Section A does not require permit authorization for its stormwater discharges associated with industrial activity in the State identified in Section B under EPA's Stormwater 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 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. "Sealed" means banded or otherwise secured and without 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, 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 instructions for completing this form and obtaining the no exposure exclusion are provided on pages 3 and 4. A. Facility Operator Information Name: ICI I ITIYI OIF BIAILILW I NI 1 1 1 1 1 1 1 1 2. Phone: 3. Email: Iqdk l r a `nle l r Eab la 1 1 {NI I In I. H10 1.1u 1s I I I 1 1 1 1 1 4. Mailing Address: a Street 200 PIA * D RI I IVI EI I I I I 1 1 I b. City: BEAILIL/ I IN II I I I I c. State 1MC d. Zip Cod 16 1 16 316 21217 -191010101 I I I 31011111-I 1 1 1 1 B. Facility/Site Locafon Information Facility Name: 2, a. Street Address: b. City: d. Stale: BIA MO L RILBIL IId 1210101 IPA LW 11N e. Zip Code: R wdRIKIsI IFIAICI IILIIITIYI 1)1 AJ KI IDIRI I vIE 1 11 1 1 1 1 1 1 1 1 1 1 1 1 1 1 3. Is the facility located on Indian Lands? 4. Is this a Federal facility? 5. a. Latitude: 1318 "13 5 613 011 1 1I ❑ YES NO In YES NO b. Longitude: 0 c. County ISIT1 • 910 312 6. a. Was the facility or site previously covered under an NPDES stormwater permit'? © YES ❑ NO b. If yes, enter NPDES permit number or tracking number: MO -R040005 7. SIC/Activity Codes: Primary: 8. Total size of site associated with industrial activity Secondary (if applicable) 2 acres 1 1 I 9. a. Have you paved or roofed over a formerly exposed, pervious area in order to qualify for the no exposure exclusion? IT YES © NO 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 stormwater 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 0 EPA Form 3510-11 (09-08) Page 1 of 4 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. 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 stormwater 2. Materials or residuals on the ground or in stormwater inlets from spills/leaks 3. Materials or products from past industrial activity 4. Material handling equipment (except adequately maintained vehicles) 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 cars] where exposure to stormwater does not result in the discharge of pollutants) 7. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, and similar containers 8. Materials or products handled/stored on roads or railways owned or maintained by the discharger 9. Waste material (except waste in covered, non leaking containers [e.g., dumpsters]) 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 permit) and evident in the stormwater outflow Yes No ❑ n 121 ❑ 0 CO 0 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 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 submit a no exposure certification form once every five years to 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 MS4, 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 an NPDES permit prior to any point source discharge of stormwater from the facility. Additionally, I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fine and imprisonment fo knowing v'olations. Print Name: Print Title: CIA RIYI d II1jY Signature: —"Aidlattr-1 Date: Email: KRIA MEIRI I I I I II I I I IO2IEJR/ID I RI IdFI IPIu I110/02/12101121 Mo Day Year g�k dal-deka:13k 1 1 I w�ilnl. juts II BILI IICI 1 1 1 1 1 1 AtO RIKISI 1 1 1 1 1 1 1 EPA Form 3510-11 (09-08) Page 2 of 4 Water Peimitting Permit Basic - MoDNR Page 1 of 2 Missouri Department of Natural Resource Permitting and Compliance,:' Search I Applications I Permit Add MGP I DMRS I SE Data Entry I CSO I Archive I Comp Mon I Reports I Facility I Public Notice I Basic Info I SE Data Entry I Journal I DMR ater information System j- ENF I ANCR Activity • Home • Help • Logout Permit Basic Information Expired Permit ID: MONX00044 Facility ID: 16353 Facility: PUBLIC WORKS FACILITY, Ballwin Owner Name: BALLNAN, CITY OF County: St. Louis Region: SLR Permit Type: Non-NPDES Non-NPDES Type: NO EXPOSUR Construction Type: Initial Date: 11/17/2008 Indicates a Required Field + Indicates field is required at time of issuance. Basic Permit Comments: Application ID: AP Permit NO LIMITS; NO EXPOSURE CERTIF FOR EXLUSION FROM NPDES PMTS Archive Ind/Box No Primary SIC: Additional SIC Codes: Primary NAICS: Additional NAICS Codes: Comments: Continuing Authority Issuing Authority 'Name: pro -7;i `Permit Writer: L Codes 4213 in -1 7 Other Information Ecological Drainage Unit: I Renew Permit) Date Information +Issue 111/17/2008 Date: + Effective Date: 11/17/2008 Expiration 11/16/2013 Date: Termination Date. Termination Comments: Terminate Major/Minor Status Compliance Tracking Status File Name: PUBLIC WORKS FACILITY Permit Category: No Exposure Fee Category: NPDES Components Select the NPDES Component(s) required: (Check to add Components.) https://www.dnr.mo.gov/cwis/peiinit/permitBasic.do?permitInsta... 6/27/2016