NCS000426_Hickory Draft SWMP v2 DEQ Comment Letter_20201211

December 11, 2020

VIA EMAIL ONLY
RETURN RECEIPT REQUESTED

City of Hickory
Attn: Warren Wood, City Manager
76 North Center Street
Hickory, NC 28601

Subject: COMMENTS ON DRAFT SWMP v2 (NOV-2019-PC-0283)
City of Hickory
NPDES MS4 Permit No. NCS000426
Catawba County

Dear Mr. Wood:

On December 12, 2018, the Environmental Protection Agency audited the City of Hickory (City) for
compliance with the subject NPDES MS4 permit. As a result, a Notice of Violation (NOV) was issued to
the City on April 24, 2019. The NOV defined specific document submittals and deadlines, which have
been provided in a timely manner.

DEQ received the required Draft Stormwater Management Plan (SWMP), version 2, submittal on July 7,
2020. Staff have reviewed the submitted Draft SWMP and request that the following comments be
addressed in a final Draft SWMP. The revised final Draft SWMP is required to be signed and
submitted, along with a permit renewal application, to DEQ within thirty (30) calendar days of
receipt of this letter.

Comments

1. BMP 18.B: Format cell margins so text is not cut off.
2. BMP 18.D.2: Add a reporting metric such as number of reports received.
3. BMP 20.D.3: Recommend changing reporting metric to Y/N.
4. BMP 21.D.2 - 4: Recommend changing reporting metric to Y/N.
5. BMP 24.D.2: Fix numbering from #1 to #2 and change reporting metric to date submitted to
DEQ.
6. BMP 25.B.2: Clarify that 20% of outfalls will be inspected each year.
7. BMP 26.D.2: Recommend changing reporting metric to Y/N.
8. BMP 27.C.1 - 2: It appears that the GIS application update for tracking would eb a one time
event in Year 1 with Y/N reporting; then item 2 would become a continuous update in Years 2-5.
Please clarify.
9. BMP 27.D.3: Change reporting metric to number of IDDEs resolved.
10. BMP 39.D.2: Report number of violations,
11. BMP 41.B.3: Change/add a goal to develop SPCC plans for identified facilities. Determining
facilities that need one should be part of the inspection process.
12. BMP 41.D.4: Recommend changing reporting metric to number of facilities added or closed.

13. BMP 42: Add a goal for implementing the SOP in Years 3-5. Report the number of inspections
performed.
14. BMP 50.B.1: Please change to “…maintain and verify…”. FYI, verification is typically
accomplished by either downloading the certification list each year and keeping it on file, or
confirming that each employee’s certification is current during their annual review.
15. BMP 54: Please change reporting metric to miles swept or amount of solids removed.
16.

The required revised Draft SWMP v3 submittal must include an electronic Word document in Track
Changes format, and a hard copy with a certifying statement and original “wet” signature by the City’s
ranking elected official or designated staff member in compliance with Part IV, Paragraph G of the
current MS4 Permit.

Please submit the required signed Draft SWMP v3 and permit renewal application to:

DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
[e-mail]

Upon receipt, a Draft Permit and the submitted Draft SWMP will be published for a required 30-day
public notice which includes an EPA and public comment period. The permit will be issued following
resolution of any comments received, and will become effective on July 1, 2021.

Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
[phone] or [e-mail].

Sincerely,

Jeanette Powell
MS4 Program Coordinator

Cc via email:
[e-mail]
[e-mail]
[e-mail]
Annette Lucas, DEMLR Stormwater Program Supervisor
Zahid Khan, Mooresville Regional Office
DEMLR NPDES MS4 Permit Laserfiche File