NCG050146_MONITORING INFO_20090318

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
Nc c-) o s o) v �/
DOC TYPE
❑ HISTORICAL FILE
L MONITORING REPORTS
DOC DATE
❑ V ly l
YYYYMMDD

NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Coleen H. Sullins
Governor Director
March 18, 2009
CERTIFIED MAIL 7007 1490 0004 4510 3296
RETURN RECEIPT REQUESTED
Mr. Gerald Haigler, Maintenance Manager
Herff Jones
9601 Monroe Road
Charlotte, NC 28270
Subject: Notice of Violation
Tracking Number: NOV-2009-PC-0241
Compliance Evaluation Inspection
Herff Jones Yearbook
Stormwater Permit COC NCG050146
Mecklenburg County, NC
Dear Mr. Haigler:
Dee Freeman
Secretary
Enclosed is a copy of the Compliance Evaluation Inspection (CEI) report for the
inspection conducted at the subject facility on January 12, 2009, by Ms. Aliyah Turner of
Charlotte -Mecklenburg Storm Water Services. This inspection was conducted as part of a
cooperative working agreement between Mecklenburg County and the Division of Water
Quality. In addition, the inspection was conducted on behalf of the City of Charlotte in
compliance with the City's NPDES Permit, NCS000240, Part 11 Section H. Thank you for your
assistance and cooperation during the inspection.
This report is being issued as a Notice of Violation (NOV) due to the permittee's failure
to implement the Stormwater Pollution Prevention Plan in violation of the subject Stormwater
Permit and North Carolina General Statute (G.S.) 143-215.1, as detailed in the Stormwater
Pollution Prevention flan and Qualitative Monitoring sections of the enclosed report.
Pursuant to G.S. 143-215.6A, a civil penalty of not more than twenty-five thousand dollars
($25,000.00) may be assessed against any person who violates or fails to act in accordance with
the terms, conditions, or requirements of any permit issued pursuant to G.S. 143-215.1.
Mooresville Regional Office
Location: 610 East Center Ave.. Suite 301 Mooresville, NC 28115 _ One
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748 NOrth CdT'O �.l l7 it
Internet: w .ncwaterquality.org /ort
An Equal Opporunity\ Affirmative Action Employer -50%Recycleo110% Post Consumerpaper (/ at,11'rrll11

Mr. G. Haigler, Herff Jones
NOV-2009-PC-0247, Page 2
March 18, 2009
It is requested that a written response be submitted to this Office by April 17, 2009,
addressing the above -noted violations in the enclosed report. In addition, it is requested that your
response demonstrate (i.e., drawings, schematics, etc.) that stormwater and not wastewater is
being managed and conveyed through manholes within the building marked "sanitary sewer". In
responding to the violations, please address your comments to the attention of Ms. Marcia
Allocco at the letterhead address.
The subject facility will have 90 days from the date of this letter to come into compliance
with the above -noted violations. A follow-up evaluation will be conducted by CMSWS after
.Tune 16, 2009, to ensure compliance with the facility's Stormwater Permit and/or compliance
with the City of Charlotte Stormwater Ordinance.
The enclosed report should be self-explanatory; however should you have any questions
concerning this report or have any questions regarding your permit, please do not hesitate to
contact Ms. Allocco of this Office at [phone].
Sincerely,
for Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Mooresville Regional Office
Enclosure
cc: Shelton Sullivan, NPS-ACO Unit
Bethany Georgoulias, Stormwater Permitting
Rusty Rozzelle, Mecklenburg County
Craig Miller, City of Charlotte
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-I- r MR GERALD HAIGLER,
ra MAINTENANCE MGR.
f` HER IT JONES
N c i 9601 MONROE ROAD
ciri CHARLOTTE NC 28270
3/18/09

'] y.
Permit: NCG050146
SOC:
County: Mecklenburg
Region: Mooresville
Compliance Inspection Report
Effective: 06/01/08 Expiration: 05/31/13
Effective: Expiration:
Contact Person: Gerald Haigler
Directions to Facility:
System Classifications:
Primary ORC:
Secondary ORC(s):
On -Site Representative(s):
Related Permits:
Title:
Certification:
Owner: Herff Jones Inc
Facility: Herff Jones Incorporated
9601 Monroe Rd -
Charlotte NC 28270
Phone: [phone]
Phone:
Inspection Date: 01/'12/2009 Entry Time: 10:00 AM Exit Time: 11:25 AM
Primary Inspector: Water Quality Program Meckenburg County Phone: [phone]
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Apparel/Printing/Paper/Leather/Rubber Stormwater
Discharge COC
Facility Status: Q Compliant ® Not Compliant
Question Areas:
® Storm Water
(See attachment summary)
Page: 1

J
Permit: NCGO50146 Owner -Facility: Herff Jones Inc
Inspection Date: 01/12/2009 Inspection Type: Compliance Evaluation I Reason for Visit: Routine
Inspection Summary:
Facility Description.
The Herff Jones facility conducts photographic development activities. The facility operates twenty-four hours a day,
seven days a week and has approximately 90 employees. All industrial activities are conducted indoors and not exposed
to stormwater.
Compliance History:
The permittee/facility does not have any prior compliance issues with the NC Division of Water Quality or
Charlotte -Mecklenburg Storm Water Services (CMSWS).
Industrial Operations/City of Charlotte Stormwater Ordinance Review:
There were no recommendations for Herff Jones facility at this time.
Page: 2

iJ
Permit: NCG050146 Owner - Facility: Hem Jones Inc
Inspection Date: 0111212009 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
Stormwater Pollution Prevention Plan
Yes
No
NA
NE
Does the site have a Stormwater Pollution Prevention Plan?
■
n
n
n
# Does the Plan include a General Location (USGS) map?
■
n
n
n
# Does the Plan include a "Narrative Description of Practices"?
■
n
n
n
# Does the Plan include a detailed site map including outfall locations and drainage areas?
■
n
n
n
# Does the Plan include a list of significant spills occurring during the past 3 years?
■
n
n
n
# Has the facility evaluated feasible alternatives to current practices?
■
n
n
n
# Does the facility provide all necessary secondary containment?
®
n
n
# Does the Plan include a BMP summary?
■
n
n
n
# Does the Plan include a Spill Prevention and Response Plan (SPRP)?
■
n
n
n
# Does the Plan include a Preventative Maintenance and Good Housekeeping Plan?
n
■
n
n
# Does the facility provide and document Employee Training?
n
■
n
n
# Does the Plan include a list of Responsible Party(s)?
in
n
n
n
# Is the Plan reviewed and updated annually?
n
®
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
n
In
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
n
0
0
n
Comment: During the on -site stormwater inspection the permittee provided a
Stormwater Pollution Prevention Plan (SPPP) dated August 1998. Since the inspection,
the permittee updated the SPPP. A copy was sent to CMSWS on February 2, 2009, for
review. However, the permittee has not fully implemented the SPPP. No documentation
could be provided showing updates to employee training, the preventative maintenance
and good housekeeping program, or the stormwater facility inspection program.
Qualitative Monitoring Yes No NA NE
Has the facility conducted its Qualitative Monitoring semi-annually? n ■ n n
Comment: Qualitative Monitoring was last conducted and documented by the
permittee in November 1998.
Analytical Monitoring Yes No NA NE
Has the facility conducted its Analytical monitoring? n n ■ n
# Has the facility conducted its Analytical monitoring from Vehicle Maintenance areas? n n in n
Comment: Analytical monitoring is not required by the NPDES general stormwater
permit because the permittee does not conduct vehicle maintenance onsite.
Permit and Outfalls Yes No NA NE
# Is a copy of the Permit and the Certificate of Coverage available at the site? ■ ❑ n n
Page:3

Permit: NCG050146 Owner - Facility: Herff Jones Inc
Inspection Date: 01/12/2009 Inspection Type: Compliance Evaluation
Reason for Visit: Routine
# Were all outfalls observed during the inspection?
# If the facility has representative outfall status, is it properly documented by the Division?
# Has the facility evaluated all illicit (non stormwater) discharges?
Comment: The permittee documented one stormwater outfall on the facility site map.
However, during the inspection three stormwater outfalls were observed.
Two manholes were observed inside the facility that were marked sanitary sewer.
Although, according to Mr. Gerald Hagler (Maintenance Manager) the manholes are for
stormwater flow and not sanitary sewer. The inspector was told that roof drains are
piped into the building where rainwater is carried through a network of piping and the
two stormwater manholes (due to a facility expansion).
Rainwater is then discharged to a pond that flows to McAlpine Creek. No
non-stormwater discharges were observed in the stormwater outfalls on site during the
inspection.
nn■n
ennn
Page:4

a:
RHERFFJONESO
April 7, 2009
Dear Ms. Marcia Allocco,
Ref NOV-2009-PC-0247
An employee owned company
r
APR - 8 2009
DIA10-S;:rYoco, `Nader Proly—dlon
This letter is regarding the inspection at our facility on January 12, 2009.We do have a Preventative
Maintenance and Good Housekeeping Plan. I have updated the plan as of January 2009. A copy of this
plan is available for review. We have implemented employee training, which is in process now. We will
review and update the plan annually. We have a Stormwater inspection program. It has not been
performed for some time, but will be performed as required from this time forward.
We do only have one outfall, which is designated on our stormwater runoff map. I have included a copy
of this map. The points that I showed Ms. Turner were areas that water moves from the building to
show the direction of water flow to the pond and creek.
Also, please note that our facility has submitted a request for no exposure due to the change in our
manufacturing status. We have changed from the use of film to digital technology and have no silver
generated in our waste stream.
The manhole covers that are marked sanitary sewer have been marked as such for as long as I can
remember. These were installed by the contractor when this construction was done. We are, however,
removing the marking on the covers that reference them as sanitary sewer.
Sincerely, ,A
Gerald Haigler
Maintenance Manager
Herff Jones Yearbook
U
RECOGNITION • EDUCATION • MOTIVATION
Herff Jones, Inc. Charlotte Yearbook 9601 Monroe Road Charlotte, NC 28270 [phone] FAX [phone]

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MR GFRALD IIAIGLER,
MAINTFNANCEMGR.
HERFF JONBS
9601 MONROE ROAD.
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CHARLOTTE NC 28270
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