HomeMy Public PortalAboutCity of Manchester STATE OF MISSC)L!RI Jeremiah W(fay)Nixon,Governor • Harr D.Bozoian,Director
DEPARTMENT OF NATURAL RESOURCES
dnr.mo.gov
October 18,2016
Mr. Robert Ruck,Director of Public Works
Public Works Facility—City of Manchester
800 Second Street
Manchester, MO 63011
RE: No Exposure Certification regarding Industrial Operations
Dear Mr. Ruck:
On August 30,2016,a representative of the Missouri Department of Natural Resources, Birhanu
Kinfe,conducted an inspection in response to the November 27,2012(enclosed)request for a
renewal of No Exposure Certification, MONX00046. 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 800 Second Street, Manchester, Missouri 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 No Exposure Certification that was issued on the above date,October 18,2016 is
MONX00046. This letter serves as notice of exemption from the applicable storm water permit
number MO-R8OCXXX.
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 October 17,2021. 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 Martha Cruse of the St.Louis
Regional Office at(314)416-2960 or by mail to 7545 South Lindbergh Blvd., Suite 210, St.
Louis,MO 63125.
Sincerely,
ST. LOUIS REGIONAL OFFICE
Dorothy�kl in
Regional Director
DEF/BK/jdk
ME MISSOURI
DEPARTMENT OF
® NATURAL RESOURCES •
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 Manchester
NPDES Permit#(if applicable):MONX00046
Person(s)Representing the facility during inspection: Bob Ruck
Are industrial materials and activities exposed to Yes ❑No® (If yes,does not qualify.)
stormwater?(Industrial materials include,but are not Comments:
limited to material handling equipment,industrial
machinery,raw materials,intermediate products,by
1 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.)
Drums,Barrels,Tanks,or Similar Containers
Are drums,barrels,tanks,and similar containers that are Yes❑ No® (If no,does not qualify.)
exposed to stormwater tightly sealed and in good Comments:
2 condition?(banded or otherwise secure without
operational taps or valves,not leaking,or deteriorated)
Are there any Aboveground Storage Tanks(ASTs)onsite? Yes®No❑(If no,disregard questions 4-7)
Comments:
3 It contains 2,000 gallon petroleum products
Is the capacity of the AST(s)greater than 20,000 gallons of Yes❑No® (If yes,does not qualify.)
petroleum product?(including pre/post-consumer Comments(note-may qualify if connected to sanitary sewer.)
products,ethanol or biodiesel)
It contains 2,000 gallon
Are the ASTs associated with vehicle maintenance(EPA Yes❑No❑ (If yes,does not qualify.)
states ASTs must be physically separated and not Comments:
associated with vehicle maintenance operations)?
Vehicle maintenance is defined as:the rehabilitation, The AST is physically separated and not associated with vehicle
5 mechanical repairing,painting,fueling,and/or lubricating maintenance
of a motor-driven conveyance that transports people or
freight,such as an automobile,truck,train,or airplane.
Are the ASTs pipes,pumps,or other equipment exposed Yes®No❑ (If no,does not qualify.)
6 to stormwater in good condition? Comment
Are the liquid materials within the secondary containment Yes®No❑ (If no,does not qualify.)
properly disposed? Comments:
7 No liquid material in secondary container
1
�^ Housekeeping and Maintenance
Are vehicles that are exposed to stormwater adequately Yes®No❑ (If no,does not qualify.)
8 maintained? Comments:
Are materials or equipment cleaned outdoors? (e.g. Yes❑ No
vehicle and industrial equipment washing that is not If yes,please describe what is being washed,if detergents are used,and if
9 otherwise regulated in the MOG76 permit) residuals are left on the ground.
Comments:
Are good housekeeping practices being used in areas Yes®No❑ (If no,does not qualify.)
subject to exposure to stormwater,including spills/leaks Comments:
(e.g.materials or residuals exposed to stormwater or Clean parking lot observed
10 within the collection system that can become mobilized)?
Do dumpsters have a lid,are they completely covered and Yes®No❑ (If no,does not qualify.)
materials not allowed to drain from any holes in the Comments:
11 bottom,or be lost in loading onto a garbage truck?
(Industrial refuse and trash that is stored uncovered is
considered exposed.)
Are containers,racks,and other transport platforms(e.g. Yes No❑ (If no,does not qualify.)
wooden pallets)for storage or conveyance of final Comments:
12 products pollutant free? No exposed containers or Pallets
MS4
Are only stormwater discharges entering the storm drain Yes® No❑ (If no,does not qualify.)
system? Comments:
13
Is the facility causing an adverse impact on water quality Yes❑No® If yes,please explain what was constructed and address the
14 due to major changes at the site to achieve no exposure, concern for pollutants.
such as constructing new building/shelters or constructing Comments:
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.)
Loading and Unloading or transporting
Are materials or products during loading/unloading Yes❑No® (If yes,does not qualify.)
exposed to stormwater? Comments:
15
Residuals and other activities
Is there any particulate matter or visible deposits of Yes❑ No® (If yes,does not qualify.)
residuals from roof stacks and/or vents that can be Comments:
mobilized by wind(including industrial activities with stack
16 emissions or process dusts that settle on surfaces.)?
2
ti
Residuals and other activities(continued)
Are there any materials or products from past industrial Yes❑No® (If yes,does not qualify.)
activity exposed to stormwater?(e.g.a site that is Comments:
superfund,or major spills occurred at this site causing long
17 term environmental effects)
Process Wastewaters
Is there now or in the foreseeable future any application Yes❑No® (If yes,does not qualify.)
or disposal of process wastewater exposed to stormwater Comments:
18
(unless otherwise permitted)?
Are any materials stored or disposed in outdoor ponds or Yes❑No® (If yes,does not qualify.)
impoundments? Comments:
19
Storm Resistant Shelters
If the storm resistant shelter is only top cover and no side Yes❑ No® (If yes,does not qualify.)
covers,is the material stored under the cover subject to Comments:
any run-on and subsequent runoff?(e.g.,a pile of sawdust
20 that is protected by a roof but not four walls that is placed No Storm Resistant shelter.All storage is under a roof.
into a large roll off container)
Is the company using any type of temporary covered Yes❑No
storage(i.e.tarps)? How long?(EPA recommends Comments:
temporary sheltering of industrial materials and activities
21 only allowed during facility renovation or construction but
provides the NPDES permitting authority to address the
issue on a case by case basis)
Final Products
Are the final products intended for outdoor use Yes❑ No® (If yes,does not qualify.)
deteriorated or otherwise be a potential source for Comments:
22 pollutants in stormwater?
Are there any leakage/spills around the buildings where Yes❑No® (If yes,does not qualify.)
product is being stored? Comments:
23
No Exposure Determination
Does the facility meet the"no exposure"certification Yes®No❑
requirements? Comments:
24 This is a renewal of No Exposure Certification
If yes,did you terminate their previous permit if needed? Yes❑No❑
25 Comments:
3
"Insert Picture Here" Photo: #1
Date Taken: 8/30/2016
�, By: Birhanu Kinfe
Facility: Public Works Facility, Cityof Manchester
��,•
160 , No Exposure Certification: MONX00046
-1a:ny * �-- } Description : Facility Truck
r
.a,
"Insert Picture Here" Photo: #2
Date Taken: 8/30/2016
By: Birhanu Kinfe
Facility: Public Works Facility, City of Manchester
MM. No Exposure Certification: MONX00046
Description : Vehicles Maintenance building
—
Tr
4
"Insert Picture Here" Photo:#3
Date Taken: 8/30/2016
By: Birhanu Kinfe
Facility: Public Works Facility, City of Manchester
No Exposure Certification: MONX00044
Description : Dome for salt storage
_ iret-
Photo:#4
Date Taken:8/30/2016
By: Birhanu Kinfe
Facility: Public Works Facility, City of Manchester
No Exposure Certification: MONX00046
Description : Dome for Salt Storage
5
2-
/IA b iU • Li- •
NPDES UNITED STATES ENVIRONMENTAL PROTECTION AGENCY Form Approved
FORM 4EPA WASHINGTON,DC 20460 OMB No.2040-0211
3510-11 No EXPOSURE CERTIFICATION FOR EXCLUSION FROM NPDES STORMWATFR
PERMITTING
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 8 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
I - final products;other than products that would be mobilized In stormwater discharges(e.g.,rock salt).
A No Exposure Certification must be provided far 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 Information1.
I I I `
Name: _ /elYIit f i�tiii1C1 I I I I ! I I I ! I i I I 2.Phone, = ' (ia -f-I I
3.Email: I rIY1( Q 't � Pt la ` a 'eIYI 01#1,101 p'IJ I I I
4.Mailing Address: a.Street 14131 i ./Yt h' > LI
b.City: �a:• t:Irc' I I/1 I I I I I I i 1 I I I c.State k d.ZlpCode: 1I(41IiI-01 2
B.Facility/Site Location Information f I-
1.Facility Name: Pk)tiI I) r-1 h�f0IvI k5I I I�_I f I+Iy 1LI �i1�1.tft g.1011 ?e-,7
2.a.Street Address: IsJ010I I512 01/ I IeleI III ! I I 1 l 1 1 i I I I I I I I
' b.City: iVG�� IP.side Vll I I HIM I ( I I c,County: 5 tab
C.Slate: ITIO s.Zip Code: 0 -!q-1p 7 2I
3.Is the facility located on Indian Lands? ❑YES LKNO ' ra
4.Is this a Federal facility? ❑YES
5.a.Latitude: 12biI3 5 b.Longitude: I f 9l01 3 1.3I
: 6.a.Was the facility or site previously covered under an NPDES stormwater permit? "S ❑NO
b.If yes,enter NPDES permit number or tracking number. /N\C) Q.o4-7o`
7,SIC/Activity Codes. Primary: 1 i�I?1 (if a Of applicable): Lill
I l I
8.Total size of site associated with industrial activity: acres
9.a.Have you paved or roofed over a formerly exposed,pervious area in order to qualify for the no exposure exclusion? ❑YES NC
• 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 ❑ Moro than five acres ❑
EPA Form 3510-11 (09-08) Page 1 of 4
•
C. Exposure Checklist
Are any of the following materials or acfivlties exposed to precipitation,now or in the foreseeable future?
(Please check either"Yes"or"No"in the appropriate box.)if you answer"Yes"to any of these questions
(1)through(11),you are not eligible for the no exposure exclusion. Yes No
1.Using,storing or cleaning Industrial machinery or equipment,and areas where residuals from using,storing or cleaning 0
industrial machinery or equipment remain and are exposed to stormwater
2.Materials or residuals on the ground or in stormwater inlets from spills/leaks I
3.Materials or products from past industrial activity
4.Material handling equipment(except adequately maintained vehicles) re
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]whore
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})
1 D.Application or disposal of process wastewater(unless otherwise permitted) Q
11.Particulate matter or visible deposits of residuals from roof stacks and/or vents not otherwise regulated
(Le..under an air quality control permit)and evident in the stormwater outflow
D.Certification Statement
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of no exposure"and obtaining
an exclusion from NPDES 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
1 industrial facility or site identified In this document(except as allowed under 40 CFR 122.26(gx2)).
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'•s to
the best of my knowledge and belief true,accurate and complete. I am a•.vare that there are significant penalties for submitting false information,
including the possibility of fine and Imprisonment for knowing violations.
Print Name: Fa s1110,1t1tItVielr I l I i I l I I I f I I
Print Title: I,- i }1 VI 1n I t'a; ell{ 1 i IIIII ( 1 1 1 1 1 1 1
t
Signature:
Date; 'L rt 11 MMM1 k I 71
Mo Day Year
Email: [ Ls I ,I -Ii"1r IzIvi'4► >xlnle.lk[t.51+41rIACti.IioIVI 1 1 I 1 1 1 1
EPA Form 3510-11 (09-08) Page 2 of 4