NCG02 Comments from Hedrick Industries

HEDRICK Jason Conner
VP—Land Management
INDUSTRIES
June 1, 2021
Annette Lucas
DEMLR Stormwater Program
1612 MSC
Raleigh,NC 27699-1612
Dear Annette:
Hedrick Industries objects to the change from semi-annual to quarterly stormwater sampling.
The quarterly stormwater sampling requirement in the proposed permit is not consistent with the permit
requirements for several neighboring states-four of those states also being in EPA's Region 4. None of these
states require quarterly sampling for the entire permit,as North Carolina does. For example:
• Virginia— Annual stormwater sampling.
• Maryland-Quarterly,but only until you have 4 consecutive samples with an average TSS< 100.
• Tennessee-Annual stormwater sampling,with an option to not sample the final year if the average of the
first 4-years is below the benchmark.
• Kentucky—Only wastewater must be sampled.
• Georgia Stormwater sampled quarterly,but with 4-consecutive compliant quarters,the permittee can
reduce to annual sampling. Only requires quarterly stormwater sampling to impaired(303)waters.
• South Carolina Stormwater sampled quarterly,but once 4-consecutive compliant quarters,then
stormwater sampling stops for the remaining permit period.
We do not believe there is data to support the need for more frequent sampling. Since most of the industry's
erosion control BMP's are designed for the 25-year storm, it is common for outfalls to not discharge in response
to many storm events. So,the new quarterly sampling requirement will make an already challenging semi-annual
sampling requirement even more difficult.
Hedrick Industries believes that semi-annual stormwater sampling is still appropriate and more consistent with
our neighboring states and oppose changing to quarterly stormwater sampling.
Hedrick proposes the following revisions to the draft permit.
• Page 6 - B-11 (a)
n Second sentence.. "Inspections shall occur at a minimum on a quarterly schedule. A minimum
of thirty(30)days must separate each inspection."
■ If 30 days must separate each inspection,that would restrict the frequency to a maximum
of monthly. NCAA suggests either removing this second sentence or making it clear that
the minimum of 30 days separation is only required if the inspections are not more than
quarterly.
Office:828.686.3844
Cell:828.712.9009
icannerOhedriekind.com
www.hedrickind.com

• Page 28 -H-5 (b) i and ii
v It appears this language was copied from Section F.5 and therefore references"same storm event"
and"next measurable storm event." For this wastewater section, it should read"sample event"or
"next sample event."
• Page 33--Part J Table 12
Hedrick has concerns over the 24-hour notification for"Visible sediment deposition" and the
fact that there may be a need for an expert opinion from someone who is not onsite to make that
determination. We would suggest either removing the 24-hour notification, or the addition of
"significant" sediment deposition. That would allow for a determination to be made by an expert
from photographic evidence, rather than potentially causing someone to travel to a site to make
the determination of whether or not the"visible sediment deposition" is in fact from the
operation and not naturally occurring.
Sincerely,
Jason Conner
Vice President of Land Management
office:828.686.3844
Cell:828.712.9009
iconnerftedrickind.com
www.hedrickind.com