NCS000444_Lowell 2020 Annual Report Letter_20201030

City of Lowell
101 W. First Street
Lowell, North Carolina 28098
October 29, 2020
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699-1612
SUBJECT: Annual Report (NCS000444)
Dear Jeanette:
Lowell
North Carolina
Phone: [phone]
Fax: [phone]
www.lowellnc.com
We are submitting this letter in response to the email we received from you on October 26, 2020
regarding Annual Reporting guidance.
The City of Lowell (NCS000444) received an audit on October 30, 2019. The following control measures
were evaluated:
- Public Education and Outreach
- Public Involvement
- Illicit Discharge Detection and Elimination
- Construction Site Runoff Controls
- Post Construction Runoff Controls
- Pollution Prevention & Good Housekeeping
On February 18, 2020 DEQ issued a Notice of Violation (NOV-2020-PC-0093) to the City of Lowell. The
following actions were required:
1) Respond in writing within thirty (30) calendar days from the date of the receipt of this notice to
acknowledge these requirements and the intent to comply.
Responded to Zahid Kahn with intent to comply on February 28, 2020.
2) Adopt a Council Resolution within sixty (60) calendar days from the date of the receipt of this
notice. The resolution must declare support for a compliant stormwater management program.
Adopted Resolution on March 10, 2020.

3) Submit documentation for review and comment within one hundred twenty (120) calendar days
from the receipt of this letter:
a. Conduct a self -audit which includes, at a minimum, an evaluation of compliance with
the permit conditions found in Part II Section B: Public Education and Outreach; Section
C, Public Involvement and Participation; Section D: Illicit Discharge Detection and
Elimination; Section E: Construction Site Runoff Controls; Section F: Post -Construction
Site Runoff Controls; Section G: Pollution Prevention and Good Housekeeping; Section
H: Total Maximum Daily Loads. The self -audit must be documented utilizing the DEQ
standard MS4 Permit Compliance Audit Report Template.
I received email correspondence from you on October 15, 2020 that guided the City on
what was necessary to self -audit. After speaking with Zahid Kahn, James Moore and
yourself a letter of explanation for only submitting the TMDL self -audit was sent on
October 16, 2020.
b. Develop a Draft Stormwater Management Plan (SWMP) which details specific actions,
measurable goals, and implementation timelines to bring the stormwater management
program into compliance with NPDES MS4 Program Audit Report and the City of Lowell
self -audit.
The City submitted a Draft SWMP on October 16, 2020.
4) Submit an NPDES MS4 permit application within thirty (30) days of receiving written DEQ
concurrence that the submitted Draft SWMP documents a compliant stormwater management
program. A new 5-year NPDES MS4 permit will be public noticed along with the submitted
SWMP.
The City will submit a new NPDES MS4 permit application within 30 days of receiving written
DEQ concurrence that the submitted SWMP documents a compliant stormwater management
program.
5) Respond to public comments on the Draft SWMP and submit a Final SWMP for DEQ approval
and final permit issuance. The final DEQ-approved SWMP shall become an enforceable
component of the NPDES MS4 permit.
The City will respond with a Final SWMP.
Scott Attaway
City Manager
704-824-3518