NCS000393_Dallas Draft SWMP v1 DEQ Comment Letter_20201214

December 15, 2020

VIA EMAIL ONLY
RETURN RECEIPT REQUESTED

Town of Dallas
Attn: Rick Coleman, Mayor
210 North Holland Street
Dallas, NC 28034

Subject: COMMENTS ON DRAFT SWMP (NOV-2019-PC-0778)
Town of Dallas
NPDES MS4 Permit No. NCS000393
Gaston County

Dear Mr. Coleman:

On December 4, 2018, the North Carolina Department of Environmental Quality (DEQ) audited the Town
of Dallas (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of Violation
(NOV) was issued to the Town on January 10, 2020. 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 September 10,
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. General comment: Include frequencies in Column C - Schedule for Implementation (Once,
Annually, Continuously, etc.) for measurable goal. See SWMP Template Instructions and
General SWMP Guidance on the DEQ MS4 Forms & Resources web page for additional
information.
2. General comment: Annual Reporting Metrics in Column D should be a reportable quantity,
Y/N/Status, etc. See SWMP Template Instructions and General SWMP Guidance on the DEQ
MS4 Forms & Resources web page for additional information. Record, verify, obtain, maintain,
etc. are not appropriate reporting metrics, but do identify tasks and supporting information that
should be documented and maintained on site for future compliance audits.
3. BMP 3.D.1: Reporting metric should be quantity of materials distributed for each target audience
and topic(s). Records should be maintained on site for future compliance audits.
4. BMP 4.D.1 and 5.D.1: Reporting metric should be Y/N/Status.
5. BMP 5.B.2: Provide more specific Measurable Goals to define that all target audiences and
target pollutant sources in Table 12 will be addressed during the permit term. For example:
Perform outreach to school students on one target pollutant (litter, nutrients, fecal coliform,

general non-point source pollution) per year, Annually Permit Years 2-5, report topic and
quantity of students reached. If this overlaps with another BMP, then please provide cross
references rather than restating the item (e.g. See BMP.3.B.3).
6. BMP 7.D.2: Report number of issues reported.
7. BMP 8.B.1: Separate establish (Once, Year 1) and maintain (Continuously, Years 2-5) into two
separate measurable goals and report Y/N/Status.
8. BMP 8.D.2: Report number trained.
9. BMP 9.B.1 and 10: Cross reference BMPs rather than repeat.
10. BMP 12.D.2 – 4: Report Y/N/Status.
11. BMP 14: This section should include Measurable Goals to: (1) develop a written IDDE Plan, (2)
submit it to DEQ for review and approval (report date submitted) in Permit Year 1, (3) Implement
the approved plan Continuously in Permit Years 2-5 (report Y/N/Status). The written plan must
include the SOPs and standard documentation for Permit Ref. 3.4.3(a) – (e).
12. BMP 15 - 16: Conduct IDDE inspections in accordance with the approved IDDE Plan and report
number of inspections documented, number of confirmed illicit discharges, number of illicit
discharges remedied, and number of illicit discharge enforcement actions.
13. BMP 17, 22, 24: Report number trained.
14. BMP 18: Report number of fact sheets posted.
15. BMP 19 – 20: Duplicate item. Cross reference to prior BMPs.
16. BMP 26: Report Y/N/Status. Delete Measurable Goal 2. The approved SWMP and new permit
will include a required annual assessment template (annual report form) that includes all
measurable goals in the SWMP.
17. BMP 27: Reference BMP 25.
18. BMP 29: Report number of O&M Plans approved and number of annual inspections submitted.
19. BMP 30: Define “periodic” frequency and report number of inspections performed.
20. BMP 32: Make reporting metrics the number facilities, number of inspections, number of high
and low priority facilities, and Y/N/Status for updates.
21. BMP 33: For clarity, please change “program” to “plan”, and “designated” to “high potential”.
Make reporting metrics (1) number of plans developed, (2) number of regular inspections, and (3)
Y/N/Status.
22. BMP 34: Staff at facilities that have a high hazard for spills must also be trained on spill
response procedures, add a measurable goal. Make reporting metrics for listed items (1)
Y/N/Status, (2) Number reviewed, (3) Y/N/Status, and (4) number trained.
23. BMP 35: Make reporting metrics (1) Y/N/Status, (2) number trained, (3) number trained.
24. Permit Ref. 3.7.3: Please include Measurable Goals for MS4 collection system inspections and
maintenance.
25. BMP 36: Make reporting metrics Y/N/Status and number of SCMs in inventory.
26. BMP 37: Report date inventory completed, number of structures inventoried and Y/N/status.
27. BMP 38.D: Report (1) number of certified personnel, (2) number trained, (3) Y/N/Status and (4)
Y/N/Status.
28. BMP 39: Provide inspection frequency. Report Y/N/Status, number of inspections and number
of re-inspections.

29. BMP 40: Report number trained.
30. BMP 41.D.1: This is a measurable goal, move to column B and report Y/N/Status. Report
quantity of regular trash and leaf/yard waste collected.
31. BMP 41: Add two separate measurable goals: (1) implementation of storm drain/catch basin
cleaning and report number of storm drains/catch basins cleaned (this should be listed under
Permit Ref. 3.7.3), and (2) street sweeping and report number of street miles swept or quantity of
solids collected.
32. BMP 42.D.2: Report number trained.

The required revised Draft SWMP v2 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 Town’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 v2 and permit renewal application to:

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

Upon receipt and preliminary approval, 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]
[e-mail]
[e-mail]
Annette Lucas, DEMLR Stormwater Program Supervisor
Zahid Khan, Mooresville Regional Office
DEMLR NPDES MS4 Permit Laserfiche File