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APPENDIX 2
INSTRUCTIONS FOR NO EXPOSURE CERTIFICATION (NEC)
shall register for NOI coverage under this General tracked out of the facility, and is not a source of
Permit prior to a planned facility change that will pollutants in the industrial storm water discharges.
cause exposure, or within seven (7) calendar days
after unplanned exposure occurs. If an unplanned 4. Industrial Materials/Activities Not Requiring a
exposure occurs due to an emergency response or Storm-Resistant Shelter
one-time event that is unlikely to re-occur, a
Discharger may contact the Regional Water Board The intent of the “No Exposure” exclusion is to maintain
to discuss whether the requirement to obtain NOI a condition of permanent “No Exposure”. A storm-
coverage can be waived. Unless the Discharger resistant shelter is not required for the following
receives a written waiver from the Regional Water industrial materials and activities:
Board, the Discharger shall electronically certify and
submit PRDs to obtain NOI coverage. a. Drums, Barrels, Tanks, and Similar Containers that
are sealed (“sealed” means banded or otherwise
c. Current contamination resulting from historic secured and without operational taps or valves), are
industrial practices at the facility (e.g., soil not exposed provided those containers are not
contamination, groundwater contamination, etc.) deteriorated, do not contain residual materials on
represents a condition of exposure to waters of the the outside surfaces, and do not leak. Drums,
United State; therefore a facility with historic barrels, etc., that are not opened while outdoors, or
contamination is not eligible for NEC coverage. are not deteriorated or leaking, and that do not pose
a risk of contaminating storm water runoff.
3. What is the Definition of No Exposure? Consider the following when making a “No
Exposure” determination:
a. No Exposure means all industrial materials and
activities are protected by a storm-resistant shelter i. Materials shall not be added or withdrawn to/from
to prevent exposure to rain, snow, snowmelt and/or containers while outdoors
runoff.
ii. Simply moving containers while outside does not
b. Industrial materials and activities include, but are create exposure unless exposure occurs when
not limited to, material-handling equipment or pollutants are “tracked out” by the container
activities; industrial machinery; raw materials, handling equipment or vehicles.
intermediate products, by-products, and final
products; or waste products. iii. All outdoor containers shall be inspected to
ensure they are not open, deteriorated, or
c. Material handling activities include storage, loading leaking. When an outdoor container is observed
and unloading, transport, or conveyance of any raw as opened, deteriorated, or leaking, the container
material, intermediate product, by-product, final must immediately be closed, replaced, or
product, or waste product. sheltered. Frequent detection of open,
deteriorated, or leaking containers, or failure to
d. Final products intended to be used outdoors (e.g., immediately close, replace, or shelter opened,
automobiles) typically pose little risk of polluting deteriorated or leaking containers will cause a
storm water since not typically contaminated with condition of exposure.
pollutants that become mobilized by contact with
storm water. Final products are exempt from the iv. Containers, racks, and other transport platforms
requirement for protection by a storm-resistant (e.g., wooden pallets) used with drums, barrels,
shelter to qualify for no exposure. Similarly, etc., can be stored outside providing they are
containers, racks, and other transport platforms contaminant-free and in good repair.
(e.g., wooden pallets) used for the storage or
conveyance of final products may also be stored b. Above Ground Storage Tanks (ASTs) In addition to
outside if pollutant-free or pollutants do not mobilize generally being considered as not exposed, ASTs
via contact with storm water. may also be exempt from the prohibition against
adding or withdrawing material to/from external
e. Storm-resistant shelters include: (1) completely containers. ASTs typically use transfer valves to
roofed and walled buildings or structures, (2) dispense materials that support facility operations
structures with only a top cover (no side coverings) (e.g., heating oil, propane, butane, chemical
supported by permanent supports, provided feedstock) or fuel for delivery vehicles (gasoline,
material within the structure is not subject to wind diesel, compressed natural gas). For operational
dispersion (sawdust, powders, etc.) or being
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Order 2014-0057-DWQ
