Step 2: Consider certifying for No Exposure

Can I qualify for No Exposure?
Facilities that shelter all significant materials and activities indoors or within a storm-resistant shelter can apply for No Exposure. Efforts to minimize your operational exposure to stormwater can help you save money and time, and protect our surface and groundwater resources.

Review the benefits of certifying for No Exposure

What are the benefits of certifying for No Exposure?

  • Exclusion from the requirements of the industrial stormwater permit
  • No Stormwater Pollution Prevention Plan to create
  • No application fee or no annual fee to pay
  • No annual reports to fill out
  • No monitoring to conduct

Determine whether your activities and materials are within a storm-resistant shelter

No exposure means all significant activities and materials are protected by a storm-resistant shelter 100% of the time.

What is a storm-resistant shelter?

Storm-resistant shelters include completely roofed and walled buildings or structures, as well as structures with only a top cover but no side coverings, provided the material under the structure is not otherwise subject to any run-on and subsequent runoff of stormwater, such as berming the area or sloping the land inward to prevent spills from running out of the area.

Do you have any outdoor significant materials

No Exposure means that rain, snow, and runoff never contact "significant materials" or industrial activities. These significant materials and activities can be found in raw materials, intermediate products, byproducts, final products, waste prod­ucts, material-handling operations, and manufacturing equipment. Pollutants of concern can include metals, oil and grease, organics, sediments, nutrients, and other chemicals. Materials are considered significant if they contain pollutants that could be transferred to stormwater.

Significant materials

  • Fuels, solvents, coolants, lubricants and cleaners
  • Raw, intermediate, and final products
  • Metallic materials
  • Chemicals
  • Wastes and scrap materials
  • Hazardous materials/wastes
  • Processing or production operations
  • Machining fluids
  • Dust or residuals
  • Fueling stations
  • Above-ground tanks for liquid storage

Industrial activities

  • Outdoor storage activities
  • Outside manufacturing areas
  • Vehicle & equipment washing, maintenance and storage areas
  • Loading and unloading operations
  • Substance Transfer areas
  • Fueling of vehicles, equipment
  • Outdoor manufacturing or processing activities
  • Significant dust or particulate generating activities
  • Onsite waste disposal practices
  • Outside storage areas for raw materials, by-products, and finished products
  • Grinding, cutting, degreasing, buffing, and brazing
  • Industrial waste management areas (landfills, waste piles, treatment plants, disposal areas)

Prevent exposure to stormwater

The following Stormwater Control Measures can help you prevent exposing pollutants to stormwater. See Step 4 for more information about Stormwater Control Measures:

  • Move significant materials and activities under cover
  • Increase waste pickup frequency
  • Optimize maintenance practices
  • Control spills and leaks
  • Manage wastes
  • Optimize operations

Review the common violations at No Exposure facilities

Not all facilities who certify for No Exposure can qualify. Here are common sources of exposure at facilities attempting to certify for No Exposure:

  • Open/unplugged dumpsters: can leak when stormwater gets in.
  • Storing significant materials outdoors: corrodible metals, used appliances, etc.
  • Industrial activities being conducted outdoors: mixing of wastes, loading/unloading of products, etc.
  • Fueling of vehicles/equipment: land, air, water transportation sector facilities or other facilities with outdoor vehicle fueling,
  • Dust/particulates: facilities operating under an air permit but having particulate matter or visible deposits of residuals on the ground.
  • Pollutants potentially mobilized by wind: windblown raw materials cause a condition of exposure. Materials sheltered from precipitation can still be deemed exposed if the materials can be mobilized by wind.
  • Metal processing facilities: large bins outside that are uncovered and contain scrap metal in them
  • Trash compactors: exposure occurs from hydraulic leaks, contents falling out of seams in equipment, or during loading or unloading
  • “Bag houses” or other particulate matter collection devices: particulate matter exposure frequently occurs

Go to Step 3