Applying for the VT Multi-Sector General Permit
Step 3. Claiming No Exposure
No Exposure is one of two ways to comply with the MSGP.
It is the quickest and easiest way to obtain coverage under the MSGP, and is intended for facilities whose industrial materials and activities are sheltered or located indoors.
What is No Exposure?
No Exposure means that all industrial materials and activities are protected by a storm resistant shelter to prevent exposure to precipitation.
What is No Exposure?
Industrial materials and activities include but are not limited to material handling equipment, industrial machinery, waste materials, raw materials, intermediate products, by-products, and final products.
Storm resistant shelters include completely roofed and walled buildings, or structures with only a top cover but no side coverings, provided that the material underneath is not subject to run-on and run-off.
What is No Exposure?
Roofed areas are acceptable storm resistant shelters.
The No Exposure Checklist
1. Industrial machinery or equipment (storage, use, or cleaning)
2. Past spills and leaks3. Industrial materials or waste from previous or
current use (includes loading/unloading)4. Inadequately maintained material handling
equipment(continued on next slide)
To claim No Exposure materials and activities must be sheltered from rain, snow, snowmelt, and runoff at your facility. The items on this checklist can not be exposed to stormwater.
5. Materials contained in open, deteriorating, or leaking storage drums, barrels, tanks, and similar containers
6. Application or disposal of process wastewater
7. Particulate matter from roof stacks 8. Waste Material9. Raw, intermediate, and final products (with
some exceptions)
The No Exposure Checklist
The items on this checklist can not be exposed to stormwater.
Materials That Can Be Stored OutdoorsThe following industrial materials can be stored outdoors and do not need to be protected by a storm resistant shelter:
(continued on next slide)
Drums, barrels, tanks, and other similar containers that are sealed and without operational taps and valves. Such containers must be in good condition and can not leak. They must also comply with other DEC regulations.
Containers may only be stored outdoors. You can not claim No Exposure if you are adding or withdrawing materials from unsheltered containers stored outdoors.
Materials That Can Be Stored Outdoors
Adequately maintained, non-leaking vehicles.
Final products built and intended for use outdoors.
Lidded and plugged dumpsters.
Above ground storage tanks that are not associated with vehicle maintenance and are not leaking.
The Benefits of No Exposure
Obtaining No Exposure for your facility is an excellent way to prevent stormwater pollution.
There is no permit fee.
You only need to reapply for No Exposure once every five years.
Incorporating good housekeeping practices and moving materials and activities indoors may help your facility obtain No Exposure.
If you construct shelters or additional buildings to cover materials or add paving (increase impervious area) on your site, you may trigger other stormwater permits.
Check with the stormwater section before undertaking these projects.
Achieving No Exposure
Understanding No Exposure
Properly maintained vehicles can be stored outdoors. This vehicle is not properly maintained and is leaking oil.
You can not claim No Exposure if you have junk piles at your
facility. Junk piles are a source of stormwater pollution.
Understanding No Exposure
Finished products built and intended for outdoor use (like guard
rails and culverts) can be stored outside if they will not deteriorate.
Understanding No Exposure
Materials are contained within a storm resistant shelter, however, they are spilling out onto the walkway where they come into contact with stormwater. A permittee can only claim No Exposure
if best management practices (BMPs), like sweeping, are implemented.
Understanding No Exposure
Dumpsters must be plugged and closed at all times (except when adding trash).
Understanding No Exposure
No ExposureExposure
Understanding No Exposure
The fueling pump and point of dispensing must be covered. Sand spread during winter months should be swept in spring.
Applying for No ExposureIf all of the materials and activities on the “No Exposure Checklist” are sheltered or protected from stormwater and precipitation, then your facility can apply for No Exposure.
You must obtain and file a “No Exposure Certification Form”.
For some facilities, it will be very difficult or impossible to claim No Exposure.
If conditions at your facility change and materials and activities are exposed to stormwater, then the facility no longer qualifies for No Exposure.
These facilities must prepare a Stormwater Pollution Prevention Plan (SWPPP) and submit a Notice of Intent (NOI) form. See the next presentation, Step 4, for more information.
What to Do If You Can Not Claim No Exposure
Summary
No Exposure is one of two ways to comply with the MSGP.
If your facility’s activities take place indoors and any outdoor activities (such as loading and unloading) are protected from precipitation, then the facility is a likely candidate for No Exposure.
SummaryClaiming No Exposure requires you to certify that all industrial materials and activities are protected from rain, snow, snowmelt, and runoff.
The No Exposure Certification is a legally binding agreement and the facility must maintain its No Exposure status.
Thank You For Your Time
We welcome your questions.
Stormwater Section (802) [email protected]
Please continue with our presentations.
