NCGNE1232_COMPLETE FILE - HISTORICAL_20170928

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO. /V
DOC TYPE .0' HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE ❑ UI� � 9��_
YYYYMMDD

ROY COOPER
Governor
MICHAEL S, REGAN
Secrelary
µ TRACY E. DAVIS
Energy,-Mineral Director
and Land Resources
ENVIRONMENTAL OUAUTY
September 28, 2017
Hickory Printing Solutions, LLC
Attention: Mr, Stephen Patton
725 Reese Drive SW
Hickory, North Carolina 28613
Subject: No-Exposure rtific tion NCGNE1232
Hickory Printing o trh ,
725 Reese Drive SW
Hickory,North Carolina 28613
Catawba County
Dear Mr. Patton:
The Division has reviewed your submittal of the No Exposure Certification for Exclusion from NPDES Stormwater
Permitting form, which we received on August 24, 2017. The Division is unable to concur with your certification of
No-Exposure.
Based on an inspection of your facility on August 29, 2017 Mooresville Regional Office staff found that industrial
activities or materials on your site either are exposed, or have the potential to be exposed. DEMLR cannot grant
your requested exemption from permit coverage when industrial activities or materials are exposed or have the
potential to be exposed. Please see attached inspection report.
If you have any questions or need further information, please contact Holliday Keen at [phone], or at
[e-mail].
Sincerely,
S, !
Zahid S. Khan, CPM, CPESC, CPSWQ
Regional Engineer
Land Quality Section
Enclosure: Inspection Report
cc: Mr. Bradley Bennett, Stormwater Permitting Program, No- Exposure Files NCGNE1232
State of North Carolina I Environmental Quality J Energy,Mineral and Land Rcsour=
Mooresville Regional Office 1 610 East Center Ave Ste 301 1 Mooresville,NC 28115
704 663 1699 T

a
Compliance Inspection Report
Permit: NCGNE1232 Effective: Expiration: Owner: Hickory Printing Solutions LLC
SOC: Effective: Expiration: Facility: Hickory Printing Solutions,LLC-Conover-an R.R.I
County: Catawba 725 Reese Dr Sw
Region: Mooresville
Conover NC 28613
Contact Person: Jeff Hale Title: Phone: 82BA65-7683
Directions to Facility:
from old us 70 take exit 130,turn left onto 1st st w then right onto 41h ave sw,turn left onto 2nd st sw tehn right onto 3rd ave sw,turn
right onto 4th street place sw,then left onto reece drive sw,facility is on left.
System Classifications:
Primary ORC: Cortificatiow Phone:
Secondary ORC(s):
On-Site Representative(s):
Related Permits:
Inspection Date: 08/29/2017 Entry Time: 11:00AM Exit Time: 11:30AM
Primary Inspector: Holliday Keen Phone:
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Technical Assistance
Permit Inspection Type: Stormwater Discharge, No Exposure Certificate
Facility Status: Compliant Not Compliant
Question Areas.
Miscellaneous Questions
(See attachment summary)
Page: 1

Permit: NCGNE1232 Owner-Facility:Hickory Printing SolutionsLLC
Inspection Date: 01312912017 Inspection Type:Technical Assistance Reason for Visit: Routine
Inspection Summary.
This inspection was conducted per request for a No Exposure Certification from Hickory Printing Solutions, LLC received by
this office on August 24,2017. During my inspection I found materiais and pallets located outside,exposed to stormwater.
Due to these issues, I recommend denial of the No Exposure certification at this time. Please remove any materials or
pallets stored outside or place them under complete and permanent cover and contact our office to complete a follow up
inspection.Alternatively, please seek coverage under the NPDES general permit relating to the SIC code for this business. If
you have any questions, please contact our office at 704-663-1699 or by email at Holliday.Keen@NCDENR,gov.
Page'. 2

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on NO EXPOSURE:
Submission of this No Exposure Certification constitutes notification that your facility does not require a
permit for stormwater discharges associated with industrial activity in the State of North Carolina because
it qualifies for a no exposure exclusion. A condition of no exposure at an industrial facility means all
industrial materials and activities are protected by a storm resistant shelter(with some exceptions) to
prevent exposure to rain, snow, snowmelt, and/or runoff.
For permitted facilities in North Carolina, DEMLR must approve your application for No
Exposure Certif?cation before this exr hision is effective. Until you are issued a No
Exposure Certification and your NPDES permit is rescinded, your facility must continue
to abide by the terms and conditions of the current permit.
Industrial materials or activities include, but are not limited to: material handling equipment or activities,
industrial machinery, raw materials, intermediate products, by-products, final products, or waste products.
Material handling activities include the storage, loading and unloading, transportation, or conveyance of
any raw material, intermediate product, final product or waste product. A storm resistant shelter is not
required for the following industrial materials and activities: drums, barrels, tanks, and similar containers
that are tightly sealed, provided those containers are not deteriorated and do not leak. "Sealed"means
banded or otherwise secured and with locked or non-operational taps or valves; adequately maintained
vehicles used in material handling;and final products, other than products that would be mobilized in
stormwater discharges (e.g., rock salt).
A No Exposure Certification must be provided for each facility qualifying for the no exposure exclusion. In
addition, the exclusion from NPDES permitting is available on a facility-wide basis only—not for individual
outfalls. If any industrial activities or materials are, or will be, exposed to precipitation, the facility is not
eligible for the no exposure exclusion. By signing and submitting this No Exposure Certification form, you
certify that a condition of no exposure exists at this facility or site and are obligated to comply with the
terms and conditions of 40 CFR 122.26(g).
If approved, your conditional No Exposure Exclusion has no expiration date
BUT MUST BE self re-certified at least annually.
Please look for information about re-certification under the No Exposure section on this page:
https://deg.nc.gDv/about/divisions/energy-mineral-land-resources/energV-mineral-land-permitslstormwater-
permitslnpdes-industriaksw
For questions, please contact the DEMLR Regional Office for your area. (See page 6)
(Please print or type)
1) Mailing address of ownerloperator(address to which all certification correspondence will be mailed?:
Name Hickory Printing Solutions, LLC -Conover: an R. R. Donnelley Company
Contact Stephen Patton
Street Address 725 Reese Drive SW
City Conover State NC T ZIP Code 28613
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NCGNE0000 No Exposure Certification
Telephone No. 828 465-3431 Fax: [phone]
2) Location of facility producing discharge:
Facility Name Hickory Printing Solutions, LLC —Conover: an R. R. Donnelley Company
Facility Contact Jeff Hale
Street Address 725 Reese Drive SW
City Conover State NC ZIP Code 28613
County Catawba
Telephone No. 828 465-7683 Fax: [phone]
3) Physical location information: 3,5 . 709 3 f F'' C)3 7 FED
v
Please provide a narrative description of how to get to the facility (use street names, state road numbers, and
distance and direction from a roadway intersection). From Old US 70 take Exit 130. Turn left onto 151 St. W
then turn right onto 41h Ave SW. Turn left onto 2"d St SW then turn right onto 3rd Ave SW. Turn right onto 4th St
Place SW then tarn left onto Reese Drive SW. Facilitv on left.
(A copy of a map with the facility clearly located on it should be included with the certification application.)
4) Is the facility located on Native American Lands?0 Yes ❑x No
5) Is this a Federal facility? ❑ Yes ❑X No
6) Latitude 35 42' 31.0514"N Longitude -81 14' 16.3766"W (deg., min., seconds)
7) This NPDES No Exposure Exclusion application applies to which of the following:
o New or Proposed Facility Date operation is to begin
❑x Existing Date operation began 611110
❑ Renewal of existing No Exposure Certification Certification No.: NCGNE
8) Was this facility or site ever covered under an NPDES Stormwater Permit? ❑ Yes ❑x No
If yes, what is the NPDES Permit Number?
9) Standard Industrial Classification:
Provide the 4-digit Standard Industrial Classification Code (SIC Code) that describes the primary industrial
activity at this facility
SIC Code: 2 7 5 2
10) Provide a brief description of the types of industrial activities and products produced at this facility:
Site produces various printed products including catalogs and brochures.
11) Does this facility have any Non-Discharge permits (ex: recycle permits)?
❑x No
❑ Yes
If yes, list the permit numbers for all current Non-Discharge permits for this facility:
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CIArl I INY1(2NIC

NCGNEO000 No Exposure Certification
Exposure Checklists (12. - 14.)
12) Are any of the following materials or activities exposed to precipitation, now or in the foreseeable
future? (Please check either"Yes" or"No.") If you answer"Yes" to any of these items, you are not
eligible for the no exposure exclusion.
a. Using, storing, or cleaning industrial machinery or equipment, and areas where ❑ Yes ONo ❑ NIA
residuals from using, storing or cleaning industrial machinery or equipment remain
and are exposed to stormwater
b. Materials or residuals on the ground or in stormwater inlets from spills/leaks ❑ Yes ONo ❑ NIA
c. Materials or products from past industrial activity ❑ Yes ONo ❑ NIA
d. Material handling equipment(except adequately maintained vehicles) ❑ Yes ONo ❑ NIA
e. Materials or products during loading/unloading or transporting activities ❑ Yes ONo ❑ NIA
f. Materials or products stored outdoors (except final products intended for outside ❑ Yes ONo ❑ NIA
use (e.g., new cars]where exposure to stormwater does not result in the discharge
of pollutants)
g. Materials contained in open, deteriorated or leaking storage drums, barrels, tanks, ❑ Yes ONo © NIA
and similar containers
h. Materials or products handled/stored on roads or railways owned or maintained by ❑ Yes ONo ❑ NIA
the discharger
i. Waste material (except waste in covered, non-leaking containers [e.g., dumpsters]) ❑ Yes ONo ❑ N1A
j. Application or disposal of process wastewater(unless otherwise permitted) ❑ Yes ONo ❑ NIA
k. Particulate matter or visible deposits of residuals from roof stacks and/or vents not C1 Yes ONo ❑ NIA
otherwise regulated (i.e., under an air quality control permit) and evident in the
stormwater outflow
I. Empty containers that previously contained materials that are not properly stored ❑ Yes ONo ❑ NIA
(i.e., not closed and stored upside down to prevent precipitation accumulation)
m. For any exterior ASTs, as well as drums, barrels, tanks, and similar containers ❑ Yes O No ❑ NIA
stored outside, has the facility had any releases in the past three (3) years?
13) Above Ground Storage Tanks (ASTs): If you answer"No" to any of the following items, you are not
eligible for the no exposure exclusion.
a. Are exterior ASTs or piping free of rust, damaged or weathered coating, pits, or ❑ Yes ❑ No O NIA
deterioration, or evidence of leaks?
b. Is secondary containment provided for all exterior ASTs? If so, is it free of any ❑ Yes 0 No O NIA
cracks, holes, or evidence of leaks, and are drain valves maintained locked shut?
14) Secondary Containment: If you answer"No" to any of the following items, you are not eligible for the
no exposure exclusion.
a. Is secondary containment provided for single above ground storage containers ❑ Yes ❑ No O NIA
(including drums, barrels, etc.)with a capacity of more than 660-gallons?
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NCGNE0000 No Exposure Certification
b. Is secondary containment provided for above ground storage containers stored ❑ Yes ❑ No ❑x NIA
in close proximity to each other with a combined capacity of more than 1,320-
gallons?
c. Is secondary containment provided for Title III Section 313 Superfund ❑ Yes ❑ No NIA
Amendments and Reauthorization Act (SARA) water priority chemicals,*?
d. is secondary containment provided for hazardous substances" designated in 40 ❑ Yes ❑ No ON/A
CFR §116?
e. Are release valves on all secondary containment structures locked? ❑ Yes ❑ No 0 NIA
15) Hazardous Waste:
a. Is this facility a Hazardous Waste Treatment, Storage, or Disposal Facility? ❑ Yes ❑x No ❑ NIA
b. Is this facility a Small Quantity Generator(less than 1000 kg, of hazardous waste 0 Yes ❑ No ❑ NIA
generated per month) of hazardous waste?
c. Is this facility a Large Quantity Generator(1000 kg. or more of hazardous waste ❑ Yes 0 No ❑ NIA
generated per month) of hazardous waste?
If you answered yes to questions b. or c., please provide the following information
Type(s) of waste: Used blanket wash, used oil, used ink
How is material stored: 55 gallon drums
Where is material stored: Chemical Storage Room
How many disposal shipments per year: 18
Name of transport/disposal vendor. Nexeo Solutions, LLC
Vendor address: 5200 Blazer Parkway, Dublin, Ohio 43017 USA
Footnotes to Questions 14) c. & d.
*Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for de minimis amounts of certain substances,
and/or other qualifiers, as described in the exemptions from reporting requirements of Title III SARA 313 in 40 CFR
§372.38.
"Note that amounts below the 660-gallon (single) and 1,320-gallon (combined) bulk storage minimums require
secondary containment. However, some exceptions may be made for amounts less than the Reportable
Quantities of the hazardous substances listed in 40 CFR §117.3.
16) Other information: If you answer"Yes"to any of the following items, you might not be eligible for the
no exposure exclusion. A more in-depth evaluation of the site circumstances may be required.
a. Does your facility store used, recycled, or otherwise reclaimed pallets outside? ❑ Yes ONo ❑ N/A
b. Does your facility have coal piles on site? ❑ Yes ONo ❑ N/A
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NCGNE0000 No Exposure Certification
c. Does your facility store other fuel sources outside in piles, such as wood chips, ❑ Yes ❑x No ❑ NIA
sawdust, etc.?
d. Does your facility have air emissions associated with its industrial activity (e.g., E]Yes ❑ No ❑ NIA
degreasing operations, plating, painting and metal finishing)? If so, describe the
industrial activity: Emissions from printing operations
e. if you answered yes to d., are those emissions permitted by an Air Quality EYes ❑ No ❑ NIA
Permit? Please specify: NCDEQ Air Permit 07607R10 (Small)
f. Please list any other environmental program permits (federal, state, etc.) not
specified earlier in this application (such as Hazardous Waste Permits, etc.):
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
Permit: Program:
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NCGNE0000 No Exposure Certification
17) Certification:
I certify under penalty of law that I have read and understand the eligibility requirements for claiming a condition of"no
exposure"and obtaining an exclusion from NPDES stormwater permitting.
I certify under penalty of law that there are no discharges of stormwater contaminated by exposure to industrial activities or
materials from the industrial facility or site identified in this document(except as allowed under 40 CFR 122.26(g)(2)).
I understand that I am obligated to maintain no exposure conditions and complete a Self-Recertification form at least once
each year, and if requested, provide this certification to the operator of the local municipal separate storm sewer system
(MS4) into which the facility discharges (where applicable). I understand that I must allow the North Carolina Division of
Energy, Mineral, and Land Resources, or MS4 operator where the discharge is into the local MS4,to perform inspections
to confirm the condition of no exposure and to make such inspection reports publicly available upon request. I understand
must keep a copy of annual re-certifications on file at the facility.
In the event that the site no longer qualifies for a No Exposure Exclusion, I understand that I must obtain coverage under
an NPDES permit prior to any point source discharge of stormwater from the facility.Additionally, I certify under penalty of
law that this document and all attachments were prepared under my direction or supervision in accordance with a system
designed to assure that qualified personnel properly gathered and evaluated the information submitted. Based on my
inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is to the best of my knowledge and belief true, accurate and complete. I am aware
that there are significant penalties for submitting false information, including the possibility of fine and imprisonment for
knowing violations.
I certify that I am familiar with the information contained in this application and that to the best of my knowledge and belief
such information is true, complete, and accurate.
Printed Name of Person Signing: Stephen Patton
Title: Plant President
(SignatueVbf Applicant) (Date Signed)
Please note: This application for the No Exposure Exclusion is subject to approval by the
NCDEQ Regional Office prior to issuance. The Regional Office may inspect your facility for
compliance with no exposure conditions prior to that approval. The Regional Office may also
inspect your facility at any time in the future for compliance with the No Exposure Exclusion.
North Carolina General Statute 143-216.6 B(i) provides that:
Any person who knowingly makes any false statement, representation,or certification in any application,record,report,plan,or other
document filed or required to be maintained under this Article or a rule implementing this Article;or who knowingly makes a false
statement of a material fact in a rulemaking proceeding or contested case under this Article;or who falsifies,tampers with, or knowingly
renders inaccurate any recording or monitoring device or method required to be operated or maintained under this Article or rules of the
[Environmental Management]Commission implementing this Article shall be guilty of a Class 2 misdemeanor which may include a fine
not to exceed ten thousand dollars($10,000).
There is currently no fee for a No Exposure Exclusion.
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NCGNE0000 No Exposure Certification
Final Checklist
This application should include the following items:
❑ This completed application and all supporting documentation.
❑ A map with the location of the facility clearly marked.
❑ If the site currently has an NPDES Stormwater Permit, be sure to indicate the permit number in Question 8.
Mail the entire package to:
Stormwater Permitting Program
Division of Energy, Mineral and Land Resources
1612 Mail Service Center
Raleigh, North Carolina 27699-1612
Note
The submission of this document does not guarantee the issuance of a No Exposure Exclusion.
For questions,please contact the DEMLR Regional Office for your area.
DEMLR Regional Office Contact Information:
a
Asheville Office ...... [phone] win ro sale
Fayetteville Office ... [phone]
Mooresville Office ... [phone] �
Raleigh Office ........ [phone] car le .�
Washington Office ...[phone]r k "'
Wilmington Office ... [phone]
elf
Winston-Salem ...... [phone] F ill
�'
Central Office .........[phone] �.
wil ngton
Page 7 of 7