NCG030164_COMPLETE FILE - HISTORICAL_20121204 (2)

STORMWATER DIVISION CODING SHEET
NCG PERMITS
PERMIT NO.
/v
DOC TYPE
HISTORICAL FILE
❑ MONITORING REPORTS
DOC DATE
❑ a /D
YYYYMMDD

4
NCDENR
North Carolina Department of Environment and Natural Resources
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P. E.
Governor Director
December 4, 2012
Mark Stenger
Hickory Springs Manufacturing Company
PO Box 128
Hickory, NC 28603
Dear Permittee:
Dee Freeman
Secretary
Subject: NPDES Stormwater Permit Coverage Renewal
Hickory Springs Metals Complex
COC Number NCG030164
Catawba County
In response to your renewal application for continued coverage under Stormwater General Permit NCG030000
the Division of Water Quality (DWQ) is forwarding herewith the reissued General Permit. This permit is
reissued pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of
Agreement between the state of North Carolina and the U.S. Environmental Protection Agency, dated October
15, 2007 (or as subsequently amended).
The following information is included with your permit package:
• A new Certificate of Coverage (COQ
• A copy of General Permit NCG030000
• A copy of the Technical Bulletin for the General Permit
• Two copies of the Discharge Monitoring Report (DMR) Form
• Two copies of the Qualitative Monitoring Report Form
The General Permit authorizes discharges of Stormwater, and it specifies your obligations for discharge
controls, management, monitoring, and record keeping. Please review the new permit to familiarize yourself
with all the changes in the reissued permit. Your facility has six (6) months from the time of receipt of the
permit to update your current SPPP to reflect all new permit requirements.
The first sample period of your permit begins January 1, 2013. Your facility must sample a "measureable
storm event" beginning during the periods beginning January 1 and July 1 of every year (or, if applicable,
report "No Flow," as outlined in Part III, Section E). Also, please note that Tier 3 Actions in Part 11 of your
permit are triggered by benchmark exceedances on four occasions beginning on the effective date of this
permit and do not count prior exceedances.
The more significant changes in the General Permit since your last COC was issued are noted either in the
Draft Permit Fact Sheet that accompanied the public notice (http://Portal.ncdenr.org/web/wq/ws/su/current-
notices), or in the Response to Comments / Summary of Changes and Technical Bulletin documents that are
posted on the Stormwater Permitting Unit's website with the new General Permit. Please visit
http://Portal.ncdenr.org/web/wci/ws/su/ng)dessw (click on 'General Permits' tab) to review that information
for your specific General Permit carefully.
1617 Mail Service Center, Raleigh, North Carolina 27699-1617
Location: 512 N. Salisbury St. Raleigh, North Carolina 27604
Phone [phone] FAX. [phone]
lotemet: www.ncwatermuallty y.00r
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Nortl t Carolina
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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030164
STORMWATER
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful
standards and regulations promulgated and adopted by the North Carolina Environmental
Management Commission, and the Federal Water Pollution Control Act, as amended,
Hickory Springs Manufacturing Company
is hereby authorized to discharge stormwater from a facility located at:
Hickory Springs Metals Complex
2200 Main Ave SE
Hickory
Catawba County
to receiving waters designated as Miller Branch (Bolicks Dry Branch), a class C waterbody in
the Catawba River Basin in accordance with the effluent limitations, monitoring requirements,
and other conditions set forth in Parts 1, II, III, and IV of General Permit No. NCG030000 as
attached,
This certificate of coverage shall become effective December 4, 2012,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this 41h day of December, 2012.
for Charles Wakild, P.E,, Director
Division of Water Quality
By Authority of the Environmental Management Commission

NCDENR
North Carolina Department of Environment and Natural
Division of Water Quality
Beverly Eaves Perdue Charles Wakild, P.E.
Governor Director
August 29, 2012
Mr. Chris Bagley
Hickory Springs Manufacturing Company
Po Box 128
Hickory, North Carolina 28603
FiLE
Resources
Subject: Notice of Deficiency - NOD-2012-PC-0196
Compliance Evaluation Inspection
Hickory Springs Metals Complex
NPDES Stormwater Permit NCG030000
Certificate of Coverage — N00030164
Catawba County
Dear Mr. Bagley:
Dee Freeman
Secretary
On August 27, 2012, Ms. Marcia Allocco from the Mooresville Regional Office of the Division of Water Quality
(DWQ) conducted a site inspection of the Hickory Springs Metals Complex facility. The site drains to Miller
Branch, Class C waters located in the Catawba River Basin. The site visit and file review revealed that the
subject facility is covered by NPDES General Stormwater Permit — NCG030000.
Accordingly, the following observations were noted during the DWQ inspection (please see the attached
addendum for information about your permit):
1) Stormwater Pollution Prevention Plan (SPPP)
A Stormwater Pollution Prevention Plan (SPPP) has been developed, recorded, and properly implemented.
Yes ❑ No
The SPPP was missing a feasibility study, annual employee training had not been conducted, and semi-annual
facility inspections had not been completed.
2) Qualitative Monitoring
Qualitative monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No'
Although the permittee has commenced qualitative monitoring in 2012 you have not performed semi-annually
for the life of the permit.
3) Analytical Monitoring
Analytical monitoring has been conducted and recorded in accordance with permit requirements.
Yes ❑ No ® NA ❑
Although the permittee has commenced analytical monitoring in 2012 you have not performed semi-annually
for the life of the permit.
Mooresville Regional Office
Location: 610 East Center Ave., Suite 301 Mooresville. NC 25115
Phone: [phone] l Fax: [phone] Customer Service: 1-877-623-6748
Internet: http:llportal,rodenr.org/webtwq
NorthCarolina
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r Mr. Chris Bagley, Hickory Springs Manufacturing Company
NOD-2012-PC-0196, Page 3
August 29, 2012
ADDENDUM
The National Pollutant Discharge Elimination System (NPDES) program was established under the federal
Clean Water Act and then delegated to the Division of Water Quality for implementation in North Carolina. The
NPDES permitting program for stormwater discharges was established in 1990. Phase I focuses on site and
operations planning to reduce pollutant sources.
Through the NPDES permitting program industrial facilities that fall into one of the subject ten categories are
required to obtain permit coverage under a general permit or an individual permit, depending upon the
facilities SIC code and the industrial activity occurring at the facility. There are currently 19 active general
stormwater permits in North Carolina. One condition that is applicable to both the general permits and
individual stormwater permits is the requirement to develop and implement site -specific comprehensive
Stormwater Pollution Prevention plans (SPPP). These plans are required to include a comprehensive
evaluation of the site and operations to reduce pollutant sources and prevent pollutant discharge.
Copies of the general permits and accompanying documents can be accessed from the following webpage:
http:l/portal.ncdenr.org/web/wq/ws/sulnpdessw#General_Permits_NPDES. Permit text, technical bulletins,
discharge monitoring forms, and a Notice of Intent [which is the application for coverage under a NPDES
General Stormwater Permit] can be found on this website.
The following items are a subset of permit requirements and are listed to assist you and help bring your
attention to certain permitting issues, process and condition requirements of your permit. Please see the
above mentioned website to obtain a copy of the permit so you may fully comply with all the conditions therein.
Failure to properly comply with conditions of the permit, like those bulleted below, is a violation(s) of
the permit and subject to civil penalty assessment(s) of up to $25,000.00 per day.
• Industrial facilities that fall into one of the subject ten categories are required to obtain permit coverage
under a general NPDES stormwater permit or an individual NPDES stormwater permit
• All persons desiring to have facilities covered by a General Permit must register with the Division of
Water Quality (DWQ) by filing of a Notice of Intent (NOI) and Applicable Fees.
• This Notice of Intent (NOI) must be submitted and a Certificate of Coverage issued prior to any
discharge of stormwater associated with the industrial activity, process wastewater, and/or mine
dewatering.
• Once the Notice of Intent is received, DWQ will review and determine whether a Certificate of Coverage
(COC) may be issued. If this Certificate of Coverage is issued the facility is covered by the General
Permit. That is, the permittee is authorized to discharge stormwater, process wastewater, and/or mine
dewatering pursuant to the type of General Permit until the permit expires or is modified or revoked.
• Any other point -source discharge to surface waters of the state is prohibited unless it is an allowable
non-stormwater discharge or is covered by another permit, authorization, or approval.
• There are currently 19 active general permits. Permit conditions vary accordingly, however, most of the
permits have the following condition requirements (you must read your entire permit to ensure full
compliance):
o Development and compliance with the Stormwater Pollution Prevention Plan
c Collection, reporting, and recording of Analytical Monitoring
o Collection, reporting, and recording of Qualitative Monitoring
Mooresville Regional office
Location: 610 East Center Ave., Suite 301 Mooresville, NC 28115
Phone: [phone] Fax: [phone] Customer Service: 1-877-623-6748
lntemet: http 11p0rtal.ncdenr.org1weblwq
NorthCalrolina
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Compliance Inspection Report
Permit: NCG030164 Effective: 11/01/07 Expiration: 10/31112 Qwner: Hickory Springs Manufacturing'Company "
SOC: Effective: Expiration: Facility: Hickory Springs Metals Complex
County: Catawba 2200 Main Ave SE
Region: Mooresville
Hickory NC 28603
Contact Person: Chris Bagley Title: Phone: [phone]
Ext.3280
Directions to Facility:
System Classifications:
Primary ORC: Certification: Phone:
Secondary ORC(s):
On -Site Re pros entative(s):
Related Permits:
Inspection Date: 0812712012 Entry Time: 09:36 AM Exit Time: 12:20 PM
Primary Inspector: Marcia Allocc ' Phone: [phone]
Ext.2204
Secondary Inspector(s):
Reason for Inspection: Routine Inspection Type: Compliance Evaluation
Permit Inspection Type: Metal Fabrication Stormwater Discharge COC
Facility Status: ❑ Compliant ■ Not Compliant
Question Areas:
E Storm Water
(See attachment summary)
Page: 1

ri
Permit: NCG030164 Owner - Facility: Hickory Springs Manufacturing Company
Inspection' Date: 08/27/2012' " 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? ■ I I n n
# Does the Plan include a "Narrative Description of Practices"? ■ n n Cl
# 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
■
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)?
■
n
n
n
# Is the Plan reviewed and updated annually?
■
n
n
n
# Does the Plan include a Stormwater Facility Inspection Program?
■
n
n
n
Has the Stormwater Pollution Prevention Plan been implemented?
n
■
n
n
Comment: The SPPP contains a site map with outfalls and drainage areas.
Walk-through noted discrepancies with actual conditions. See Permit and Outfalls
section for more information. The SPPP did not contain a feasibility study but did
contain a very extensive BMP summary. There are no aboveground storage tanks
(ASTs) at the facility. The permittee has not conducted annual employee training since
2007. Training is planned for employees before the end of 2012. Facility inspection
completed in May 2012 and another has been added to the compliance calendar for
completion before the end of 2012.
Qualitative Monitoring
Yes No
NA
NE
Has the facility conducted its Qualitative Monitoring semi-annually?
n ■
n
n
Comment: Qualitative monitoring was conducted in May of 2012. Semi-annual
monitoring was not completed previous to this date.
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
■
n
Page: 3

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SPR GS.
September 27, 2012
Marcia Allocco
Surface Water Protection Section
610 East Center Avenue, Suite 301
Mooresville, NC 28115
RE: Notice of Deficiency -- NOD-2012-PC-0196
Hickory Springs Metals Complex
NPDES Stormwater Permit NCG030000
Certificate of Coverage — NCGO30164
Catawba County
Dear Ms. Allocco:
Chris Bagley, CHMM, PE, QEP
Corporate Environmental Engineer
Hickory Springs Manufacturing Company
235 2' Avenue NW
P.O. Box 128
Hickory, North Carolina 28603
828.328.2213 Office
828,328.5502 Fax
[e-mail]
This letter is in response to the referenced Notice of Deficiency (NOD), which was issued to the
Hickory Springs Metals Complex on August 29, 2012 after your site inspection conducted on
August 27, 2012. Below are each of the four deficiencies documented in the NOD followed by
our response.
1. The SPPP was missing a feasibility study, annual employee training had not been
conducted, and semi-annual facility inspections had not been completed.
Part 11 Section A.2.(a) of the Metals Complex stormwater permit requires that a feasibility
study, as described in the permit, is part of the SPPP. Hickory Springs will revise its
SPPP to incorporate this required element by December 31, 2012. Annual employee
training will be completed by December 31, 2012 and will be scheduled annually
thereafter. A semi-annual inspection was conducted on May 8, 2012. Hickory Springs
initiated an environmental monitoring and reporting calendar for the Metal Complex in
2012 which includes due dates for semi-annual inspections to ensure they are conducted
as required.
2. Although the permittee has commenced qualitative monitoring in 2012 you have
not performed semi-annually for the life of the permit.
Qualitative monitoring was conducted on May 18, 2012. Hickory Springs initiated an
environmental monitoring and reporting calendar for the Hickory Metal Complex in 2012
which includes due dates for qualitative monitoring to ensure monitoring is conducted as
required. Qualitative monitoring is conducted and documented in conjunction with
stormwater discharge sampling for analytical monitoring.
3. Although the permittee has commenced analytical monitoring in 2012 you have not
performed semi-annually for the life of the permit.
Hickory Springs submitted Discharge Monitoring Reports (DMRs) to the Division of Water
Quality for samples obtained May 8, 2009, May 21, 2010, and May 8, 2012. Hickory
Springs initiated an environmental monitoring and reporting calendar for the Hickory

! OF wA"r
r
o �
Mr. Curtis Daniels
Hickory Springs Manufacturing Company
2230 Main Avenue, S.E.
Hickory, NC 28603
Dear Mr. Daniels:
Michael F. Easley, Governor kc� _
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
Coleen 1-1. Sullins, Director
Division of Water Quality
October 29, 2007
Subject: Compliance Evaluation Inspection
NPDES Permit No. NCG030164
Catawba County, North Carolina
Enclosed please find a copy of the Compliance Evaluation Inspection Report for the inspection conducted at
the subject facility on October 5, 2007, by Ms. Polly Lespinasse of this Office.
It is requested that a written response be submitted to this Office by November 29, 2007,
addressing the deficiencies noted in the Inspection Summary/Stormwater Pollution Prevention
Plan of the report. In responding, please address your comments to the attention of Ms. Marcia
Allocco.
The report should be self-explanatory, however, should you have any questions concerning this report, please
do not hesitate to contact Ms. Lespinasse or me at [phone].
Sincerely,
'T2t r,
K---
Robert B. Krebs
Regional Supervisor
Surface Water Protection Section
Enclosure
cc: Shelton Sullivan, DWQ, NPS-ACO Unit
North Carolina Division of Water Quality 610 East Center Avenue, Suite 301
intemet: h2o-enr.state.nc.us Mooresville, NC 28115
Phone [phone]
Fax [phone]
None hCarolina
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j.,
Permit: NCG030164 Owner - Facility: Hickory Springs Manufacturing Company
Inspection Date: 10/05/2007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Inspection Summary:
Stormwater Pollution Prevention Plan:
The facility needs to update the written portion of the SWPPP to accurately identify the number of outfalls (3 are depicted
on the site map). The SWPPP includes an evaluation of significant spills, however, it just indicates "none to date".
Advised facility staff to note the appropriate dates since the plan is older than 3 years. The facility has implemented many
BMPs to reduce stormwater exposure to materials/chemicals, however, these actions had not been documented. In
addition, other opportunities (feasible alternatives) were identified during the inspection. The facility provided training on
the SWPPP on 10/02/07. However, prior to this training, no specific stormwater training had been provided. Training
must be conducted on an annual basis and documented. The facility is not documenting the required semi-annual facility
inspections. DWQ discussed with facility staff the need for documented inspections and what items would be appropriate
to include on the inspection form.
Analytical Monitoring:
The facility has had coverage under a general permit since 2000. They conducted one round of analytical sampling in
2001 (under the previous permit) and included TTO sampling. They obtained clarification that, based on their processes,
TTO sampling is not required. Coverage was obtained again under the Current permit and one sampling event was
conducted in October 2006. Two outfalls were sampled and the results were under the cutoff concentration limits. Due
to drought conditions, they have been unable to conduct any additional sampling. DWQ staff discussed the appropriate
sampling times (within the first year of the effective date of the permit and if the results don't exceed the cutoff
concentrations, during the last year of the permit). Based on this, DWQ staff advised that no additional analytical
sampling should be conducted this year since the permit is expired and due to the drought conditions. Advised that once
the permit is re -issued, sampling must be conducted again as required by the permit.
Page: 2

40
Permit: NCG030164 Owner - Facility: Hickory Springs Manufacturing Company
Inspection Date: 10/0512007 Inspection Type: Compliance Evaluation Reason for Visit: Routine
Comment: Some solid waste was observed at Outfall #3 and proper disposal was
discussed with facility staff.
Page: 4

NCS Stormwater Questions for Facilities in BIMS
Stormwater Management Plan
Yes
No
NA
NE
1. Has the facility evaluated feasible alternatives to current practices?
❑
❑
❑
❑
• Provide a review of the technical and economic feasibility of changing the methods of operations and/or
storage practices to eliminate or reduce exposure of materials and processes to Stormwater.
• In areas where elimination of exposure is not practical, the stormwater management plan shall document the
feasibility of diverting the Stormwater runoff away from areas of potential contamination.
2. Does the facility provide all necessary secondary containment?
❑
❑
❑
❑
• Applies to liquid raw materials, manufactured products, waste materials, or by-products
• Single AST capacity > 660 gallons
• Multiple AS containers in close proximity to each other with a total combined capacity of > 1,320
• If connected to SW conveyance; controlled by manually activated valves or other similar devices? (Closed?)
• Collected water observed for color, foam, outfall staining, visible sheens, and dry weather flow prior to release
• Document individual making observation, description of water, date, and time of release (RR=5 yrs)
3. Does the Plan include a 3MP summary?
❑
1 ❑
I ❑
1 ❑
Narrative description of BMPs to be considered including oil and grease separation, debris control, vegetative filter
strips, infiltration and stormwater detention or retention, where necessary.
• The need for structural BMPs shall be based on the assessment of potential sources to contribute significant
quantities of pollutants to stormwater discharges and data collected through monitoring of stormwater
discharges.
4. Does the Plan include a Spill Prevention and Response Plan (SPRP)?
❑
❑
❑
❑
• Assessment of potential pollutant sources based on materials inventory of the facility
• Facility personnel responsible for implementing the SPRP shall be identified
• Responsible person shall be on -site at all times during facility operations that have the potential to
contaminate stormwater runoff through spills or exposure of materials associated with the facility operations.
5. Does the Plan include a Preventative Maintenance and Good Housekeeping
❑
ElEl
❑
Plan?
• Document schedules of inspections and maintenance activities of stormwater control systems, plant
equipment and systems
• Inspect material handling areas
• Regular cleaning schedules of these areas
6. Does the facility provide and document Employee Training?
❑
I ❑
I ❑
❑
• Provide at a minimum, annual training for all personnel including. proper spill response, cleanup procedures,
preventative maintenance activities for all personnel involved in any of the facility's operations that have
the potential to contaminate stormwater runoff
Develop training schedule and identify facility personnel responsible for implementing the training

NCS Stormwater Questions for Facilities in BIMS
Yes
No NA
NE
7. Does the Plan include a list of Responsible Parties?
❑
❑ ❑
❑
Identify position responsible for the overall coordination, development, implementation, and revision of the SPPP
8. Is the Plan reviewed and updated annually?
❑
❑
I ❑
1 ❑
Have there been any changes to the design, construction, operation, or maintenance of the facility, which would have
a significant effect on the potential for the discharge of pollutants to surface waters? Does plan include changes?
9. Does the Plan include a Stormwater Facility Inspection Program?
I ❑
I ❑
I ❑
I ❑
• Inspect at a minimum semiannually once in Fall (Sept. -Nov) and once in Spring (Apr -June)
• Inspection and subsequent maintenance activities performed shall be documented
o Record date and time
o Individual performing inspection
o Narrative description of the stormwater outfall and plant equipment and systems
• Records should be incorporated into the SPPP
10. Has the Stormwater Pollution Prevention Plan been implemented?
❑ ❑
❑
❑
Have they done what they said they were going to do and have they documented it. Examples include:
• Monitoring and measurements including sampling data
• Inspections
• Maintenance activities
• Training provided to employees
• Activities to implement BMPs associated with industrial activities including vehicle maintenance. (RR=S yrs)
Comments:
Qualitative Monitoring
Yes
No
NA
NE
1. Has the facility conducted its Qualitative Monitoring semi-annually?
❑
❑
❑
❑
Sampling in Spring (April -June) and Fall (September -November)
Color Odor Clarity Floating Solids
Suspended solids Foam Oil Sheen Other indicators
Comment:

NCS Stormwater Questions for Facilities in BIMS
Analytical Monitoring
Yes
No
NA
NE
1. Has the facility conducted its Analytical monitoring?
❑
❑
❑
❑
2. Has the facility conducted its Analytical monitoring from Vehicle Maintenance
El❑
El
Elareas?
Comment:
Permit and Outfalls
Yes
No
NA
NE
1. Is a copy of the Permit and the Certificate of Coverage available at the site?
❑
❑
❑
❑
2. Were all outfails observed during the inspection?
❑
❑
❑
❑
3. If the facility has representative outfall status; has it been documented by the
Division?
❑
❑
❑
❑
4. Has the facility evaluated all illicit (non stormwater) discharges?
❑
❑
❑
❑
Comment:

4W
HICKQRY SPRiN%t..CA. . ����.,fe��MANUFACTURING COMP
November 9, 2007
VIA 0VEgYGH.T MAIL
j cUt
Ms. Marcia Allocco NC DENR MRO
NCDENR— Division of Water Quality 610 East Center Avenue, Suite 301 M-Surface Writopf Protection
Mooresville, NC 28115
RE: Hickory Springs Manufacturing Company
Compliance Evaluation Inspection — Responses to Identified Deficiencies
NPDES Permit No. NCG030164
Dear Ms. Allocco:
The purpose of this correspondence is to respond to your letter to Hickory Springs, dated
October 29, 2007 concerning deficiencies identified as a result of a compliance inspection at our
Hickory Metals Complex in Hickory, NC on October 5, 2007.
As requested, we have prepared the following written responses to each of the items specifically
listed as deficiencies in the "Inspection Summary/Storm Water Pollution Prevention Plan" of the
report.
Item No. 1
"The facility needs to update the written portion of the SWPPP to accurately identify the number
of outfalls (3 are depicted on the site map).
Response to Item No. 1
Th;. SWPPP has been updated to correct this oversight. See Attachment A for relevant sections
of the facility's SWPPP that have been revised.
Item No. 2
"The SWPPP includes an evaluation of significant spills, however, it just indicated none to date.
Advised facility .staff to note the appropriate dates since the plan is older than 3 years. "
Response to Item No. 2
Based on the permit language contained in the General Permit, Hickory Springs is to provide "a
list of significant, spills or leaks of pollutants that have occurred at the facility during the 3
previous years and anv corrective actions taken to mitigate spill impacts." Hickory Springs has
changed this section of the SWPPP from "To date, there have been no Significant Spills or Leaks
at the Metals Complex" to actually listing each of the previous three years. See Attachment B
for our demonstration of permit compliance.
Hickory Springs Manufacturing Company
235 2nd Avenue, N.W. • P.O. Box 128 9 Hickory, North Carolina 28603-0128 • Telephone: [phone]

Ms. Marcia Allocco
NCDENR — Division of Water Quality
November 9, 2007
Page 2 of 3
Item No. 3
"The facility has implemented many BMPs to reduce stormwater exposure to
materials/chemicals, however these actions had not been documented. In addition, other
opportunities (feasible alternatives) were identified during the inspection. "
Response to Item No. 3
The existing Table 4-2 in the facility's SWPPP identifies many currently implemented structural
and non-structural BMPs at the Hickory Metals Complex. See Attachment C for a copy of this
Table. Additional internal correspondence, including emails, notes, and memos relative to
evaluations, recommendations, decisions, etc. are also maintained independently from the
SWPPP.
It is our understanding that the requirement of Section A.2.(c) of the permit is to provide a
narrative description of BMPs to be considered, where necessary. The need for structural or non-
structural BMPs will (as required) be based on our assessment of the potential of sources to
contribute significant quantities of pollutants to storm water discharges from the facility and data
collected through monitoring of storm water discharges. Based on the collection and analysis of
storm water discharges from the facility in accordance with permit requirements, analytical
results have demonstrated concentrations of Total Suspended Solids, Oil & Grease, and Lead to
be well below the established "Cut-off Concentrations" identified in the permit. pH testing has
also shown samples to be within the acceptable range as specified in the permit. Therefore,
although additional opportunities can almost always be identified for storm water pollution
prevention at industrial facilities, the basis for identifying additional BMPs to meet permit
conditions at the Hickory Metals Complex is not believed to be currently necessary. This is not
to say that Hickory Springs will not continue to implement proactive measures to reduce its
impacts on discharges of storm water to surface waters of the State.
Item No. 4
"The facility provided training on the SWPPP on 10102107. However, prior to this training, no
specific stormwater training had been provided. Training must be conducted on an annual basis
and documented.
Response to Item No. 4
Hickory Springs has previously provided training related to various aspects of storm water
pollution prevention to employees on a one-on-one basis (job related), as well as discussions
during regularly scheduled safety meetings. Specific documentation of this training, however,
has not been developed in the past to demonstrate compliance. In recognition of this lack of
formal documentation of training records, a specific storm water pollution prevention training
program has been developed and was provided to over 60 employees on October 2, 2007.
Records of employees who participated in this additional training were documented and will
continue to do so. Training related to storm water pollution prevention will continue to be
provided on an annual basis for all applicable employees.
W\Metals Complex\DENR Storm Water Inspection 2007\Response Letter_NO 2007,doe

Ms. Marcia Allocco
NCDENR -- Division of Water Quality
November 9, 2007
Page 3 of 3
Item No. 5
"The facility is not documenting the required semi-annual facility inspections. DWQ discussed
with facility staff the need for documented inspections and what items would be appropriate to
include on the inspection form. "
_Response to Item No. 5
Hickory Springs understands the permit requirements for semi-annual inspections, which is
outlined in detail within the facility's SWPPP (see Attachment D). As the permit does not
specifically explain that the completion of a form is required, the facility has assumed that email
and memo correspondence would satisfy the record keeping requirements for the semi-annual
inspections. It is now recognized and understood that the permit requires Hickory Springs to
incorporate these inspection records into the facility's SWPPP. As such, we have developed
Appendix C of the SWPPP to maintain all inspection records to demonstrate compliance (sec
Attachment E).
Should you require additional information or have any questions concerning our responses,
please feel free to contact me at [phone], Ext. 3244 or [e-mail].
Sincerely,
HICKORY SPRINGS MANUFACTURING COMPANY
Randy S. Waibel, CHMM
Corporate Environmental Compliance Manager
Enc. Attachments A — E
cc: C. Angi (633)
B. Bush (Corp)
C. Daniels (603)
J. Tate (603)
N:\Metals Complea\OENR Storm Water Inspecton 2007\Response Letter_Nov 2007.doc

Hickory Springs — Hickory Metals Complex SWPPP
2.4. STORM WATER DISCHARGES FROM FACILITY
Currently, the facility's storm water drainage and conveyance system collects storm water runoff from
on -site roads, driveways, parking lots, buildings, and various vegetated i.e.,grass/wooded) areas before
discharging into the Miller Branch via hrec separate discharge locations "outfalls" Outfall 001, 002,
and 003 . Although most storm water runoff is collected by the facility's drainage system, there are
various portions of storm water "run-on" that contributes to the overall discharge at Outfall 001.
As previously described in Section 1.2, the Hickory Springs currently has a NPDES permit to discharge
storm water runoff to the Miller Branch. Figure 2 — Drainage Plan presents the current storm water
drainage features at the Hickory Springs facility, delineation of drainage areas, and the locations of storm
water discharge outfalls. The embedded table within Figure 2 presents an overview of the current storm
water outfalls, including approximate size of drainage areas, and characteristics of each contributing sub -
drainage area.
2.5. EXISTING FACILITY PROCEDURES
The following procedures have been established by Hickory Springs to comply with requirements of
various USEPA and NCDENR spill prevention, response and control regulations:
• Hazardous Waste Management: EC-HW1-1
• Spill Response and Reporting: EC-SRI-I
+ Oil Spill Prevention, Control and Management: EC-SPCC1-1
• Tank System Installations and Management: EC-TK1-1
• Drainage of Secondary Containment Systems: EC -DC I-1
2.6. PERSONNEL TRAINING
The employee training programs at Hickory Springs are established to teach employees about storm
water management, potential sources of contaminants, pollution prevention, and the use of non-structural
BMPs, such as good housekeeping and spill prevention. Employee training programs instill appropriate
Hickory Springs personnel with a thorough understanding of this SWPPP, including BMPs, processes
and materials they are working with, safety hazards, practices for preventing discharges, and Hickory
Springs procedures for responding quickly and properly to chemical or otherwise potentially harmful
incidents.
At a minimum, appropriate employees are trained on proper spill response and preventative maintenance
activities to prevent the potential for the contamination of storm water due to facility operations.
Employee training is provided by the Safety and Environmental Manager and/or the Corporate
Environmental Compliance Manager. Appendix A is used to document employee training.
Specific training for incident response is limited to the Facility's Emergency Response Team and their
Supervisors. Training records are maintained by the Safety & Environmental Manager and/or the Human
Resource Manager.
EC 603,633,623 -- Page 13 of 32
Updated: November 7, 2007

Hickory Springs — Hickory Metals Complex SWPPP
Definition of "representative storm event"
As defined by the General Permit, a representative storm event is one that measures greater than 0.1 inches of
rainfall and that is preceded by at least 72 hours in which no storm event measuring greater than 0.1 inches has
occurred. A single storm event may contain up to 10 consecutive hours of no precipitation. For example, if it rains
for 2 hours without producing any collectable discharge, and then stops, a sample may be collected if a rain
producing a discharge begins again within the next 10 hours,
Hickory Springs performs the required monitoring of storm water runoff from each outfall,
including Outfalls 001, 002 and 003. (see Figure 2 for locations).
Additionally, and in accordance with Part 11. Section C of the General Permit (Qualitative Monitoring
Requirements) Hickory Springs must fulfill qualitative monitoring requirements which require a visual
inspection of each storm water outfall regardless of representative outfall status and shall be performed
as specified below in Table 6-2. This monitoring is performed in order to evaluate the effectiveness of
the SWPPP and to assess potential new sources of storm water pollution. No analytical tests are required
and the monitoring need not be performed during a representative storm event.
Table 6-2.
Discharge Characteristics ! . '
. { - -9a¢a'
I
;Frequency C €
'�f s,
IA;,�-sr r��
Morntor�ng Location ,
-Mira rr 4'-
Color
Semi -Annual
SDO
Odor
Semi -Annual
SDO
Clarity
Semi -Annual
SDO
Floating Solids
Semi -Annual
SDO
Suspended Solids
Semi -Annual
SDO
Foam
Semi -Annual
SDO
Oil Sheen
Semi -Annual
SDO
Other obvious indicators of storm water pollution
Semi -Annual
SDO
Note:
1. Monitoring location: Qualitative monitoring shall be performed at each storm water discharge outfall (SDO) regardless of
representative outfall status.
This first qualitative monitoring event for the term must occur at the same time as the initial analytical
monitoring event. All other qualitative monitoring will be performed two times a year, once from April
to June and the second from September to November.
Part II., Section D of the General Permit (On -site Vehicle Maintenance Monitoring Requirements)
applies to facilities that perform vehicle maintenance on site. As the Hickory Springs facility does not
currently perform vehicle maintenance activities, this section does not apply to the facility.
EC 603.633.623 — Page 27 of 32
Updated: November 7, 2007

Hickory Springs — Hickory Metals Complex
SWPPP
4.3. ASSESSMENT OF PAST SPILLS, LEAKS AND RELEASES
The following table presents a summary of past "significant spills or leaks" of pollutants that have
occurred at the facility during the 3 previous years and any corrective actions taken to mitigate spill
impacts.
Table 4-1.
.Hickor. Spnngs`� ,, � al s �, �,, � ¢
Sum'rna of'Past Sign if! 6ant*' Sills and leaks to- Storm Water;l7atns
Spill Year
Description of Incident
2004
No Significant Spills or Leaks
2005
No Significant Spills or Leaks
2006
No Significant Spills or Leaks
2007
To date, No Significant Spills or Leaks
* "Significant Spills/Leaks' is defined as 'releases of oil or hazardous substances in excess of reportable quantities under Section 311 of the
Clean Water Act (40 CFR Part 110.10 and 117.21) or Section 102 of CERCLA (40 CFR 302.4)."
4.4. ASSESSMENT OF EXISTING STORM WATER SAMPLING DATA
As previously described in Section 1.2, the Hickory Springs facility currently has NPDES permit
coverage from the NCDENR to discharge storm water runoff into the Miller Branch. Scheduled
samplings of storm water drainage areas are performed by Hickory Springs to meet the permit water
quality monitoring requirements (Part IL, Sections B and C of the Permit). The current permit specifies
the constituents to sample and sampling frequency for each storm water discharge location. Analysis is
conducted in accordance with USEPA analytical laboratory test methods and the procedures outlined in
Section D.4. of the Permit. Sampling and analysis undergo quality control and quality assurance
(QA/QC) review to ensure validity of analytical results. The SWPP Team Coordinator also reviews the
analytical data and compares against the "Cut -Off Concentrations" identified in Part 11, Section B of the
Permit.
Based on the review of the most recent sampling, conducted on October 17, 2006, discharges of storm
water runoff were below the "Cut -Off Concentrations." A copy of this data is maintained with the SWPP
Team Coordinator.
Analytical results from sampling during the final year of the permit term must be reported by Hickory
Springs to NCDENR with the permit renewal application.
In addition to the analytical monitoring requirements, semi-annual qualitative monitoring is also
performed to confirm the presence or absence of certain discharge characteristics, such as color, odor,
clarity, and oil sheen.
4.5. EXISTING STRUCTURAL AND NON-STRUCTURAL BMPS TO REDUCE
POLLUTANTS IN STORM WATER DISCHARGES
A variety of non-structual and structural practices are employed at the Hickory Springs facility to reduce
the potential of pollutant sources from coming into contact with precipitation and entering the storm
water drainage system.
EC 603.633.623 — Page 18 of 32
Updated: November 7, 2007

Hickory Springs — Hickory Metals Complex
SWPPP
4.5.1. Non -Structural Controls
Examples of non-structural practices that are currently implemented at the Hickory Springs facility
include the following:
• Housekeeping activities — A variety of housekeeping activities are conducted, including the
following:
o Sweeping and disposal of debris inside facility buildings: Housekeeping practices inside the
buildings at the site include daily sweeping of work areas and shipping/receiving areas.
Spilled liquids are cleaned up with appropriate absorbent materials prior to sweeping. Daily
housekeeping reduces the amount of debris at the facility that can be tracked out to surfaces
exposed to storm water.
o Regular cleaning of outdoor areas and catch basins: The outdoor drainage areas at the
facility are cleaned on an as -needed basis to remove debris, trash, and accumulated
sediments. The removed debris and trash is disposed into on -site dumpsters. Regular
cleaning allows catch basins to operate efficiently in removing storm water runoff, thus
preventing localized flooding, and reduces the amount of debris, trash and sediment that may
be flushed into the storm water system by a storm event.
• Signage and labeling far containers — Most areas and also containers of chemical/petroleum products
(or wastes) are identified with signs that provide pertinent information including: hazardous or non-
hazardous, ignitable, flammable, corrosive, and reactive. These signs and labels assist in providing
that proper handling and disposal practices are followed and in reducing potential improper disposal
incidents at the facility.
• Inspections — Routine informal inspections of truck loading/unloading docks, bulk unloading/loading
areas for chemicals/petroleum products, and other outdoor areas are conducted by a variety of
Hickory Springs personnel.
The following table summarizes and presents BMPs currently being implemented at the Hickory Springs
facility. A status of "C" refers to the implementation status of currently being implemented.
Table 4-2.
BMPs
[ail i !d , W
Descr�pUon of activities . i , 1 'r t{
i +� "& §
Status
FW €, -
.'.Schedule"
f
�
33
Good housekeeping
Garbage, waste materials, and used parts/equipment are regularly
C
picked up from around outdoor areas and properly disposed.
Outdoor solid waste containers (dumpsters) are maintained in an
C
orderly condition (i.e., containers are not overfilled).
The areas surrounding solid waste containers are maintained
C
clean.
Oil (petroleum or non -petroleum) products used on -site are stored
in appropriate (covered) containers and are maintained indoors
C
and/or within secondary containment.
The facility outdoor areas, especially within loading dock areas,
are kept clean and free of accumulated debris (i.e., trash, shipping
C
materials).
EC 603.633.623 — Page 19 of 32
Updated: November 7, 2007

Hickory Springs — Hickory Metals Complex
SWPPP
Table 4-2.
BMPs �T:�
rF
D�iscnption of activities .���e
!Y£., .`��.. 7—. %<y. ��' Yf .7 ✓i k e'"d , :?: 1
Status ;
- ;- b 5 }Ss
Schedule"
i•, ,"yi6
Good housekeeping
On an as needed basis, facility storm sewer catch basins and
(continued)
secondary containment areas shall be maintained (i.e., kept clean
C
and no accumulation of rain water).
When possible, building overhead doors are kept closed during
rain events.
C
Loading and unloading docks are kept clean on a daily basis.
C
Roof top areas are routinely inspected and kept clean.
C
Significant materials are stored either indoors or within outdoor
secondary containment to prevent direct exposure and runoff of
C
storm water.
Indoor areas are kept clean from accumulating dust and particles
that may be tracked outdoors.
C
Facility areas are cleaned by manual methods (sweeping) only.
Water is not used to "hose off" indoor or outdoor areas.
C
Collect, handle, and dispose of or recycle residual fluids from
manufacturing/processing equipment,
C
Preventive
Maintenance
Equipment and areas that have the potential for failures or spills
have been identified and are routinely inspected
C
Equipment operated according to manufacturer's
recommendations
C
Preventive maintenance performed on equipment (with potential of
spills/ leaks) to provide for proper operation and detection of
C
potential spills/leaks before they occur.
Berms, including secondary containment structures, and drains
maintained and inspected on a regular basis.
C
Spill prevention and
response
Spill prevention and response procedures for petroleum products
are followed in accordance with the facility's SPCC Plan.
C
Accumulated rainwater within secondary containment areas is
visually inspected for the presence of oil sheen before being
C
manually discharged to an area outside of the containment area.
Leaks of oil and other petroleum products are immediately cleaned
up, as appropriate (dependent upon the size of the spill).
C
No vehicle maintenance is conducted at the facility, including
employee vehicles or trucks.
C
Paints, oils and other maintenance fluids for on -site equipment
maintained indoors within contained areas.
C
Outdoor drum storage is minimized. Drums that are stored
outdoors are inspected prior to storage to verify that bungs are
tight and there is no chemical or petroleum residual on the exterior
C
surfaces of the drum, If residual exists on the exterior surfaces,
the drum is covered to prevent exposure,
Drip pans are used under transfer hose connections during all
petroleum transfers.
C
EC 603.633.623 — Page 20 of 32
Updated'. November 7, 2007

Hickory Springs — Hickory Metals Complex
SWPPP
Table 4-2.
n.av
BMPs , , _ , . '
Description of activities J�?�L } t�J 3t jy Fqb Y S P y� �M�F }�
Y �� P hN , �.•e'�+,� 3)
E Status
.((
ls6hedule"
i 4 . V .
Spill prevention and
response
Outdoor containers (drums) are inspected for signs of leaks or
corrosion on a weekly basis.
C
(continued)
Equipment resulting in a leak or spill of fluids immediately reported
to the SWPPP Coordinator.
C
All drums are completely drained (emptied) before disposing or
storing outdoors.
C
Drums are always maintained closed unless they are in use.
C
Emergency spill equipment maintained in appropriate locations
around the facility.
C
Material Handling and
Materials with the potential to contaminate storm water are
Storage
maintained either indoors or are stored within outdoor areas with
C
secondary containment.
All miscellaneous scrap equipment is stored indoors. If located
outdoors, the materials are covered with appropriately sized and
C
secured tarps to prevent exposure.
Employee Training
Appropriate employees trained regarding the components and
goals of the SWPPP
C
Appropriate employees trained in good housekeeping practices
C
Appropriate employees trained in material handling practices
C
Appropriate employees trained in the proper inspection procedures
C
Appropriate employees trained in spill prevention and response
practices (in accordance with the SPCC Plan).
C
Waste Handling and
Recycling
Solid wastes, including paper, wood, metal, and plastic is placed in
covered outdoor dumpsters.
C
Scrap metals are collected and disposed of into an appropriate
dumpster, which is routinely picked up by a scrap metal recycling
C
company.
Record keeping and
Reporting
All records of inspections, spills, maintenance activities, corrective
actions, visual observations, are retained by the SWPP Team
C
Coordinator.
Training attendance documented
C
Sediment and Erosion
Maintain vegetative cover on ground surfaces.
C
Control
Visual
Inspections
Housekeeping inspections are conducted on a routine basis
C
Routine inspections (as part of daily activities) are performed at
areas where employee vehicles and trucks are parked to observe
C
if there are leaking automotive fluids.
Storm water catch basins, ditches and outdoor areas draining
storm water runoff inspected once/quarter (at a minimum) following
C
a rain event
EC 603.633.623 — Page 21 of 32
Updated: November 7, 2007

Hickory Springs — Hickory Metals Complex
SWPPP
Table 4-2.
Description of activities`.;}� `E�,' { war' `iF?;° g1F;15tatus
:=Schedule"
Visual
Maintenance areas inspected regularly for proper implementation
Inspections
of control measures
C
(continued)
Each of the identified potential pollutant source areas at the facility
are inspected on a regular basis to evaluate the effectiveness of
C
the existing BMPs
Notes: ` As new or modified BMPs are added to this Table, an implementation schedule will be established to ensure compliance
with the General Permit.
4.5.2. Structural and Physical Controls
Existing structural and physical controls employed at the facility are described in the following:
• Extensive overhead coverage — The majority of the facility activities are conducted under roof, which
significantly reduces the number of industrial activities and potential pollutants exposed to storm
water runoff at the Hickory Springs Complex.
• Secondary containment systems for outdoor containers. Each of the existing facility petroleum,
chemical, paint, and other potentially hazardous products are located outdoors and/or are located within
the secondary containment systems. Inspections of secondary containment systems are performed on a
regular basis by the Safety and Environmental Manager. Storm water that may accumulate within
outdoor containment areas is only discharged to the storm water drainage system following the
completion of the "Record of Containment Area Drainage" form (see Appendix B)
4.6. SUMMARY OF POTENTIAL STORM WATER POLLUTANT SOURCE AREAS
The toxicity or hazardousness of chemicals; quantity of chemicals, paints or petroleum products used,
produced or discharged; likelihood of contact with storm water; and the history of leaks or spills are
considered in the evaluation of the potential source areas.
The potential source areas identified at the Hickory Springs Metals Complex include the following:
Roadways and parking lot areas
• Shipping/receiving loading dock areas
• Chemical/paint/petroleum loading/unloading areas
• Paint residue (bake -off) oven area
• On -site waste disposal areas (dumpsters, roll -off containers, compactors)
Each of the areas identified above present a potential for exposure to storm water that discharges to
surface water from the Hickory Springs facility. Storm water contact with the potential source areas of
storm water pollution is generally be limited to only accidents that may occur at the facility. In addition,
there are specific controls established by Hickory Springs to control or limit the discharge of pollutants
off -site in the event of a spill or other accident.
EC 603.633.623 — Page 22 of 32
Updated: November 7, 2007

Hickory Springs — Hickory Metals Complex
SWPPP
6.3. INSPECTIONS
In accordance with the General Permit, Hickory Springs is required to conduct a site compliance
evaluation (evaluation) on a semi-annual basis (once in the fall [September — November] and once in
the spring ]April — Junel). This SWPPP shall be revised, as appropriate, and the revisions implemented
within 30 days of the evaluation. Evaluations are required to include the following components:
a A review of all visual observation records, inspection records, and sampling and analysis results.
A visual inspection of all potential pollutant sources for evidence of, or the potential for, pollutants
entering the drainage system.
• A review and evaluation of all BMPs (both structural and non-structural) to determine whether the
BMPs are adequate, properly implemented and maintained, or whether additional BMPs are
needed. A visual inspection of equipment needed to implement the SWPPP, such as spill response
equipment, shall be included.
• An evaluation report that includes:
• identification of personnel performing the evaluation
• the date(s) of the evaluation
• necessary SWPPP revisions
• schedule for implementing SWPPP revisions
• any incidents of non-compliance and the corrective actions taken.
The evaluation report must be maintained with SWPPP records and retained for at least five years.
This semi-annual inspection is in addition to the Qualitative Monitoring inspections described in Table 6-
2.
All records, including the completed evaluation reports, are maintained in Appendix C of this
document.
EC 603.633.623 — Page 30 of 32
Updated: November 7, 2007

APPENDIX C
Storm Water Discharge Permit
Completed Inspection Records
Routine Inspection Records/Correspondence
Qualitative Monitoring Forms
:) Semi -Annual Inspections

HI CKLO R"IT SPR I NG S
MANUFACTURING COMPANY
L_ s
January 5, 2009 VIA CERTIFIED MAIL
Ms. Marcia Allocco
NCDENR — Division of Water {duality
610 East Center Avenue, Suite 301
Mooresville, NC 28115
RE: Hickory Springs Manufacturing Company
Hickory Metals Complex
NPDES Permit No. NCG030164
Reporting of Noncompliance
Dear Ms. Allocco:
"fhe purpose of this correspondence is to comply with Section E.9. of the above -referenced
NPDES permit. Specifically, Hickory Springs has not performed the following required
monitoring requirements during the 2008 calendar year:
• Semi-annual analytical monitoring requirements, as identified in Table 1 and Table 2 of
Section B; and
• Semi-annual qualitative monitoring requirements, as identified in Table 4 of Section C.
The discovery of these non-compliance conditions were based on my records review following
the recent departure of Mr. Curtis Daniels, the former Safety & Environmental Manager at this
facility.
Until further notice, 1 will be responsible for the compliance with the above -referenced permit
and the implementation of the facility's Storm Water Pollution Prevention Plan. Recognizing the
importance of compliance with the conditions of our permit, I have made the necessary
arrangements with on -site personnel to perform the required storm water monitoring in the
Future.
As no analytical monitoring of storm water discharges was performed during Year 1 (Period I
Period 2), as specified in Table 2, it is not clear, if there should be an attempt to ma1:e up these
sampling;/analytical periods. Unless otberwise instructed, we will proceed with the required
analytical monitoring for the remaining eight periods.
Hickory Springs Manufacturing Company
235 2nd Avenue, N.W. • P.O. Box 128 • Hickory, North Carolina 28603-0128 • Telephone: [phone]

Ms. Marcia Allocco
NCDENR — Division of Water Quality
January 5, 2009
Page 2of2
Should you require additional information or have any questions concerning this matter, please
feel free to contact me at [phone], Ext. 3244 or [e-mail].
Sincerely,
HICKORY SPRINGS MANUFACTURING COMPANY
RC�. "I/w, "
Randy S. Waibel, CHMM
Corporate Environmental Manager
cc: C. Angi (633)
B. Bush (Corp)
J. Tate (603)
B. Trimble (Corp)
H:Wetalg ComplexVENR Non-ComplienceVon-Compliance Letler_Dec 31 2008.doc

(� \NA Michael F. Easley, Governor
�O 9pG William G. Ross Jr., Secretary
0A
North Carolina Department of Environment and Natural Resources
GO 7
Alan W. Klimek, P.E., Director
Division of Water Quality
0 Y ,
August 23, 2002
CURTIS DANIELS
HICKORY SPRINGS MANUFACTURING COMPANY - CATAWBA
PO BOX 128
HICKORY. NC 28603
Subject: NPDES Stormwater Permit Renewal
HICKORY SPRINGS MANUFACTURING COMPANY
- CATAWBA
COC Number NCG030164
Dear Perrnittee:
In response to your renewal application for continued coverage under general permit NCG030000, the Division of
Water Quality (DWQ) is forwarding herewith the reissued Stormwater general permit. This permit is reissued
pursuant to the requirements of North Carolina General Statute 143-215.1 and the Memorandum of Agreement
between the state of North Carolina and the U.S. Environmental Protection Agency, dated December 6, 1983"
The following information is included with your permit package:
* A new Certificate of Coverage
A copy of General Stormwater Permit NCG030000
* A copy of the Analytical Monitoring Form (I)MR)
* A copy of a Technical Bulletin for the general permit
Your coverage under this general permit is not transferable except after notice to DWQ. The Division may require
modification or revocation and reissuance of the Certificate of Coverage. 'Phis permit does not affect the legal
requirements to obtain other permits which may be required by DENR or relieve the permittee from responsibility
for compliance with any other applicable federal, state, or local law, rule, standard, ordinance, order, judgment, or
decree.
If you have any questions regarding this permit package please contact Bill Mills of the Central Office Stormwater
and General Permits Unit at [phone], ext. 548
cc: Central Files
Stormwater & General Permits Unit Files
Mooresville Regional Office
Sincerely,
Bradley Bennett, Supervisor
Stormwater and General Permits Unit
[l (' 2302
e�h
NCDERR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF WATER QUALITY
GENERAL PERMIT NO. NCG030000
CERTIFICATE OF COVERAGE No. NCG030164
STORMWATER DISCHARGES
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provision of North Carolina General Statute I43-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
HICKORY SPRINGS MANUFACTURING COMPANY
is hereby authorized to discharge mormwater from a facility located at
HICKORY SPRINGS MANUFACTURING COMPANY - CATAWBA
2200 MAIN AVE SE
HICKORY
CATAWBA COUNTY
to receiving waters designated as Miller Branch, a class C stream, in the Catawba River Basin in accordance with
the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, I1, I11, IV, V, and V1 of
General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective September 1, 2002,
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day August 23, 2002.
fur Alan W. Klimek, P.E., Director
Division of Water Quality
By Authority of the Environmental Management Commission

�oF W A TF,
Michael F. Easley, Governor
William G. Ross Jr., Secretary
North Carolina Department of Environment and Natural Resources
CALVIN MCGILL
HICKORY SPRINGS MFG CO-CA,rAWB
235 2ND AVE NW PO BOX 128
December 27, 2001
',Gregory J. Thorpe, Ph.D.
Acting Director
(•' Division of Water Quality
APR 1 0 2002
HICKORY, NC 28603
Subject: NPDES Stormwater Permit Renewal.: ,� 1"
..,r:r.. � v�tlrsm� I 1 :�6l� i it..i9
HICKORY SPRINGS MF CO=C�A I-AWB
COC Number NCG030164
Catawba County
Dear Permittee:
Your facility is currently covered for Stormwater discharge under General Permit NCG030000. This Permit expires
on August 31, 2002, The Division staff is currently in the process of rewriting this permit and is scheduled to have
the permit reissued by late summer ol'2002. Once the permit is reissued, your facility would he eligible for
continue(] coverage under the reissued permit.
In order to assure your continued coverage under the general permit, you must apply to the Division of Water
Quality (DWQ) for renewal of your permit coverage. To make this renewal process easier, we are informing you in
advance that your permit will he expiring. Enclosed you will find a General Permit Coverage Renewal
Application Form. The application must be completed and returned by March 4, 2002 in order to assure continued
coverage under the general permit.
Failure to request renewal within this time period may result in a civil assessment of at least $250.00. Larger
penalties may he assessed depending on the delinquency of the request. Discharge of stormwater from your facility
without coverage under a valid stormwater NPDES permit would constitute a violation of NCGS 143-215.1 and
could result in assessments of civil penalties of up to $10,000 per day.
Please note that recent federal legislation has extended the "no exposure exclusion" to all operators of industrial
facilities in any of the l l categories of "storm water discharges associated with industrial activity," (except
construction ac(ivities). If you feel your facility can certify a condition of "no exposure", i.e. the ]acilty industrial
materials and operations are not exposed to stormwater, you can apply for the no exposure exclusion. For additional
information contact the Central Office Stormwater Staff member listed below or check the Stormwater & General
Permits Unit Weh Site at http:llh2o.cnr.state.ne.us/su/storiiiwater.iitinI
If the subject stormwater discharge to waters of the state has been terminated, please complete the enclosed
Rescission Request Form. Mailing instructions are listed on the bottom of the form. You will he notified when the
rescission process has hcen completed.
I1' you have any queslions regarding the permit renewal procedures please contact Miku Parker of the Mooresville
Regional Office at 704-663-1699 or Bill Mills of the Central Office Stormwater Unit at [phone], ext. 548
Sincerely,
Bradley Bennett, Supervisor
Stornwater and General Permits Unit
cc: Central Files
Mooresville Regional Office
®��
NCDENR
N. C. Division of Water Quality 1617 Mail Service Center Raleigh, NC 27699-1617 [phone] Customer Service
1-800-623-7748

State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Water Quality
James B. Hunt, Jr., Governor OEM
Wayne McDevitt, Secretary p E H N F1
A. Preston Howard, Jr., P.E., Director
September 24, 1997
CALVIN MCGILL
HICKORY SPRINGS MFG-CATAWBA
235 2ND AVE NW PO BOX 128
HICKORY, NC 28603
Subject: Reissued Stormwater General Permit for Certificate of Coverage No. NCG030164
Catawba County
Dear Permittee:
In response to your renewal application for continued coverage under the subject permit, the Division
of Water Quality (DWQ) is forwarding herewith the reissued stormwater general permit. This permit
is reissued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency
dated December 6, 1983.
The following information is included with your permit package:
■ A copy of the stormwater general permit.
■ A Stormwater Pollution Prevention Plan Certification Form. This form certifies that you have
developed and implemented the Stormwater Pollution Prevention Plan (SPPP) required in your
permit. This form must be completed and returned to the Division within 30 days of receipt of
this letter. DO NOT send the SPPP with the signed form.
■ Five copies of Analytical Monitoring forms.
■ Five copies of Qualitative Monitoring forms.
■ A copy of a Technical Bulletin on the stormwater program with outlines program components
and addresses frequently asked questions.
rr A corrected Certificate of Coverage if you indicated a name or address change on the Renewal
Form returned to the Division.
Your certificate of coverage is not transferable except after notice to DWQ. The Division of Water
Quality may require modification or revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by
DWQ or permits required by the Division of Land Resources, Division of Air Quality, Coastal Area
Management Act or any other Federal or Local governmental permits that may be required.
If you have any questions concerning this permit or other attached documents, please contact the
Stormwater Group at telephone number [phone]
Sincerely,
for A. Preston Howard, Jr., P. E.
P.O. Box 29535, Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal Opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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' State of North Carolina
Department of Environment,
Health and Natural Resources
Division of Environmental Management
James B. Hunt, Jr., Governor
Jonathan B. Howes, Secretary
A. Preston Howard, Jr., P.E., Director
May 21, 1993
Calvin McGill
Hickory Springs Manufacturing Company
235 2nd Avenue
Hickory, NC 28603
AT4
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Subject: General Permit No. NCG030000
Hickory Springs Manufacturing Company
COC NCG030164
Catawba County
Dear Mr. McGill:
In accordance with your application for discharge permit received on October 6, 1992, we are
forwarding herewith the subject certificate of coverage to discharge under the subject state - NPDES general
permit. This permit is issued pursuant to the requirements of North Carolina General Statute 143-215 .1 and the
Memorandum of Agreement between North Carolina and the US Environmental Protection agency dated
December 6, 1983.
If any parts, measurement frequencies or sampling requirements contained in this permit are
unacceptable to you, you have the right to request an individual permit by submitting an individual permit
application. Unless such demand is made, this certificate of coverage shall be final and binding.
Please take notice that this certificate of coverage is not transferable except after notice to the Division
of Environmental Management. The Division of Environmental Management may require modification or
revocation and reissuance of the certificate of coverage.
This permit does not affect the legal requirements to obtain other permits which may be required by the
Division of Environmental Management or permits required by the Division of Land Resources, Coastal Area
Management Act or any other Federal or Local governmental permit that may be required.
If you have any questions concerning this permit, please contact Mr. Bill Mills at telephone number 9191733-
5083.
cc:
Sincerelyg1,
Qrinal Signed By
Coleen H. Sullins
A. Preston Howard, Jr., P. E.
Mooresville Regional Office
P.O. Box 29535. Raleigh, North Carolina 27626-0535 Telephone [phone] FAX [phone]
An Equal opportunity Affirmative Action Employer 50% recycled/ 10% post -consumer paper

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STATE OF NORTH CAROLINA
DEPARTMENT OF ENVIRONMENT, HEALTH, AND NATURAL RESOURCES
DIVISION OF ENVIRONMENTAL MANAGEMENT
� _ :u ►! ► i Ilil
STORMWATER DISCHARGES
In compliance with the provision of North Carolina General Statute 143-215.1, other lawful standards and
regulations promulgated and adopted by the North Carolina Environmental Management Commission, and the
Federal Water Pollution Control Act, as amended,
Hickory Springs Manufacturing Co.
is hereby authorized to discharge stormwater from a facility located at
Hickory Springs Manufacturing Co.
2200 Main Avenue, SE
Hickory
Catawba County
to receiving waters designated as Miller Branch in the Catawba River Basin
in accordance with the effluent limitations, monitoring requirements, and other conditions set forth in Parts I, Il, III
and IV of General Permit No. NCG030000 as attached.
This certificate of coverage shall become effective May 21, 1993.
This Certificate of Coverage shall remain in effect for the duration of the General Permit.
Signed this day May 21, 1993.
original Signed BY
i,-i-an H. Sullins
A. Preston Howard, Jr., P.E., Director
Division of Environmental Management
By Authority of the Environmental Management Commission

' STATE OF NORTH CAROLINA
DEPARTMENT OF NATURAL AND ECONOMIC RESOURCES
RALEIGH, NORTH CAROLINA
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