NCS000500_Ayden DEQ SWMP v1 Comment Letter_20200723

July 23, 2020

CERTIFIED MAIL 7013 2630 0001 8990 3682
RETURN RECEIPT REQUESTED

Town of Ayden
Attn: Steven Harrell, Town Manager
P.O. Box 219
Ayden, NC 28513

Subject: COMMENTS ON DRAFT SWMP (NOV-2019-PC-0539)
Town of Ayden
NPDES MS4 Permit No. NCS000500
Pitt County

Dear Mr. Harrell:

On July 23, 2019, the North Carolina Department of Environmental Quality (DEQ) audited the Town of
Ayden (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of Violation
(NOV) was issued to the Town on July 26, 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) submittal on October 29, 2019.
Staff have reviewed the submitted Draft SWMP dated October 24, 2019 and request that the
following comments be addressed in a final Draft SWMP. The revised Draft SWMP is required to
be submitted to DEQ within thirty (30) calendar days of receipt of this letter.

General Comments
1. Refer to the General SWMP Guidance, which has been posted in the Phase II MS4 Toolbox on
the DEQ MS4 web page. A copy is also attached for your convenience. This guidance was
developed after the Town’s Draft SWMP was submitted. It provides detail on what is required
for BMPs, appropriate measurable goals, and reportable metrics. This guidance should be used to
establish clear, specific and measurable goals throughout the Town’s Draft SWMP document.
There is a general lack of specificity throughout the document.
2. Delete all embedded instructions throughout the document (red italicized text).
3. Consecutively number each BMP under “BMP No.” throughout the document. Do not restart
numbering in each table. This provides for quick and accurate referencing (e.g. BMP 24.B.3
would reference BMP number 24, measurable goal number 3).
4. Delete all blank rows/numbers in tables.
5. Each Measurable Goal (MG) is required to have a schedule for implementation. Appropriate
schedules include a frequency and the permit years in which the MG activity will occur. Please
see General SWMP Guidance on the DEQ MS4 web page. “To be determined” is not acceptable
for any measurable goal.

6. Cross-reference BMPs that are used under more than one permit conditions to streamline the
reporting and compliance process. It is only necessary to report an activity one time. Rather than
repeat the wording, provide cross-references if the same BMP or MG is used to meet other permit
conditions.

Specific Comments

1. Section 3.3: Receiving waters map does not clearly show receiving waters or stream names.
2. Section 3.7: Change “Town of Farmville” to Ayden.
3. Section 3.8: Describe how discharges were evaluated, what the resulting determination was and
why.
4. Section 3.9/Table 7: Add car washing and street wash water unless section 3.8 provides support
for not including them.
5. Section 4.2: Include description of current fees, revenue and what funds are used for.
6. Table 9: It appears that the Town has a contract with McDaniel & Associates to implement the
post-construction program. If so, please include in the table.
7. Table 12: Add car washing and street wash water unless section 3.8 provides support for not
including them.
8. Table 14, BMP 6 Annual Review and Input: Describe what “plan” will be reviewed.
9. Table 15, BMP 9 Storm Sewer System Map: It appears that only 60% of the MS4 is mapped.
Provide specific steps/measurable goals to complete the remaining 40%.
10. Table 15, BMP 10 Regulatory Mechanism: The Town already has an ordinance. Describe the
specific purpose of the review.
11. Table 15, BMP 19: The Town is not required to do general stream sampling/monitoring under
the NPDES MS4 Phase II program, but must do so if it is a commitment in the SWMP. If the
intent of this measurable goal was to provide monitoring to identify illicit discharges, this is
unclear. The procedures for identifying illicit discharges should be a component of the required
written IDDE Plan.
12. Table 16: The Town of Ayden does not have a delegated SPCA Program, but Pitt County does. If
the county implements the erosion and sediment control program within the town limits, then the
county must be listed as the local program name and a legal agreement between the town and the
county is required. If NCDEQ implements the program within the town limits, then the program
name is state implemented SPCA program with DEQ as the implementing entity.
13. Table 17, Permit Reference 3.5.5 Waste Management: Measures to require and enforce
compliance are needed (ordinance(s), etc.).
14. Table 18: Delete the “None” row since the Town is subject to Neuse NSW.
15. Table 21, BMP 28 & 32: Training for handling construction site runoff control complaints is not
a measure for municipal pollution prevention and good housekeeping. Operation and
maintenance staff are required to be trained on stormwater awareness and pollution prevention.
16. Table 21, BMP 33: There are two requirements lumped together (perform inspections of the
storm sewer collection system, and maintain the collection system), and the measurable goals are
not sufficient for either. Separate and provide appropriate measurable goals for each (see
guidance document and section 3.7.3 of the draft permit template).
17. Table 21, Permit Reference 3.7.4: Since the Town does not currently have any SCMs but could
in the future, include a measurable goal to develop and implement an operation and maintenance
program if /when a municipal stormwater control measure is installed.

18. Table 21, Permit Reference 3.7.5 requires compliance with permits and applicator certifications.
The Town should include a BMP to ensure that applicator certifications are current for all
relevant staff. Other MS4s have handled this by including the certification as part of the
employee annual review process, or downloading the information once a year to verify that staff
are current on requirements.
19. BMP 35: It is unclear whether the connected vehicle wash area exists, or will be developed. The
description says “utilize”, but the BMP says “establish”. Please resolve the discrepancy. Also,
establish is a one-time activity, not continuous.

The required revised Draft SWMP v2 submittal must include a certifying statement and original “wet”
signature by the City’s ranking elected official or designated City staff member in compliance with Part
IV, Paragraph G of the current MS4 Permit. Please submit the required Draft SWMP to:

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

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, CPSWQ
MS4 Program Coordinator

Cc via email:
Mike Mitchell, EPA Stormwater Enforcement
Annette Lucas, DEMLR Stormwater Program Supervisor
Alaina Morman, DEMLR Stormwater Compliance & Enforcement
DEMLR NPDES MS4 Permit Laserfiche File