No Exposure Certification

California State Water Resources Control Board (SWRCB) industrial dischargers wishing to maintain their existing or to obtain a new No Exposure Certification (NEC) conditional exclusion for their facility’s storm water general permit must submit an application for new coverage or an annual re-certification prior to the beginning of the wet season, October 1, 2015.  Dischargers that obtain NEC coverage are exempt from the Storm Water Pollution Prevention Plan (SWPPP), sampling, and visual observation requirements of the Industrial Storm Water General Permit.

What is “No Exposure”?

Boiler MACTNo Exposure means that all industrial activities and materials are protected by a storm resistant shelter from all storm water (rain, snow and/or runoff).  “Industrial activities and materials” include industrial machinery and material handing (i.e., storage, loading, unloading, or onsite transfer) of raw materials, intermediate products, finished products, byproducts and waste.  Shelters are considered “storm resistant” if they are completely roofed and walled.  Completely roofed shelters lacking side coverings are only considered “storm resistant” if the material housed underneath is not prone to wind dispersion or track-out and no runoff comes into contact with the material.  Final products designed for use outside (such as vehicles) or product storage and transportation products (i.e. racks, wooden pallets, containers, etc.) that are 100% pollutant free are exempt from storm resistant shelter requirements.

Who is eligible for NEC coverage? 

All industrial dischargers presently utilizing the SWRCB’s Storm Water Multi-Application and Report Tracking System (SMARTS) to electronically certify and submit reports are eligible.  According to SWRCB, all construction, demolition or land disturbance (i.e. grading and earthwork) activities are ineligible for NEC coverage.  Since NEC must be applied to a facility as a whole and because of this other types dischargers such as construction, may be ineligible for coverage.

How to obtain NEC coverage?

First a facility must register in SMARTS to obtain a Waste Discharge Identification number (WDID).  When facility obtains their WDID, only then can they submit NEC Permit Registration Documents via SMARTS.  They must also pay an annual fee which is dependent upon the facility’s threat to water quality complexity and type of discharge.  After a facility obtains NEC coverage they must re-certify every year confirming that the no exposure conditions are still being maintained.  If a facility does not complete their annual recertification or it becomes possible that industrial activities or materials could be exposed to storm water, they must apply for Notice of Intent (NOI) coverage within seven (7) days.

To learn more about No Exposure Certification, or how Davenport Engineering can help your facility obtain NEC, please contact us today.