NCS000438_Spring Lake Courtesy SWMP Review Comments_20210118

From:Powell, Jeanette
To:[e-mail]; [e-mail]
Cc:Annette Lucas ([e-mail])
Subject:NCS000438: Spring Lake Courtesy SWMP Review Comments
Date:Monday, January 18, 2021 8:06:00 AM
Hi Deanna,

My apologies that this courtesy preliminary SWMP review took so long. Below are preliminary
comments. You are on the right track, just need to refine some things. I love Adopt-A-Drain, first
time I’ve seen that one.

Comments:
1. Replace “as needed” with “Continuously”.
2. BMP has been changed to SCM in the table headings. BMP is the correct federal term. SCM is
a state term for post-construction Stormwater Control Measures (stormwater management
devices).
3. Include frequency and permit year(s) in column C (schedule for implementation).
4. BMP 12: Stream Watch accepts surveys and general observations, but monitoring data
cannot be utilized by the state since it cannot be verified that it meets state requirements.
Recommend changing “monitoring” to “surveys”.
5. BMP 13 & 14: MS4 map is for the collection system (pipes, swales, outfalls, etc). SCMs are
addressed under the pollution prevention section.
6. Permit Ref. 3.4.3: A written IDDE plan and proactive IDDE program is required to be
established within the first year. The provided measurable goals are reactive.
7. Part 8: Reinsert Table 16 and 17 from template. All MS4s will be required to train staff and
locally control construction site waste.
8. BMP 24: Separate into multiple measurable goals. Create/maintain an inventory, inspect
annually, train staff, etc.
9. BMP 25 & 26: Recommend staff SOP and training so reporting becomes an automatic
process.
10. BMP 27: This section is for the collection system (pipes, catch basins, etc.), not constructed
stormwater control measures (SCMs).
11. BMP 28: Inspect municipal SCMs annually and perform required maintenance in accordance
with the SCM O&M requirements. Develop/use a standard inspection form. Report number
of inspections and maintenance activities performed.
12. BMP 29 & 30: Train staff on use, handling , storage and pollution prevention. If the town has
any certified applicators, ensued certifications are current annually.
13. BMP 31: MS4s sometimes need industrial stormwater permits for facilities such as vehicle
maintenance, wastewater treatment > 1 MGD, etc. The DEQ Regional Office can assist you in
assessing whether these permits are needed. If so, inspect permitted facilities annually to
ensure they are in compliance with the industrial permit. Measurable goals for non-permitted
vehicle maintenance would be pollution prevention training and SOP measures on site.
14. BMP 32: Be more specific on measurable goals, schedule, annual reporting metric (e.g.
Sweep streets in accordance with xx plan/schedule, Annually Permit Years 1-5, street miles
swept). Establish standard tracking and reporting for street sweeping staff so you have the
numbers you need at the end of the year.
15. BMP 33: I will be looking for more specific information such as number of catch basins
cleaned. Also, this should be under the MS4 section, and you could cross-reference here.

Thanks,
J
Jeanette Powell, CPSWQ, CPESC
MS4 Program Coordinator
919-707-3620
[e-mail]

North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 6th Floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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https://deq.nc.gov/sw