NCS000484_Salisbury Draft SWMP v1 DEQ Comment Letter_20210127

January 27, 2021

VIA EMAIL ONLY
RETURN RECEIPT REQUESTED

City of Salisbury
Attn: W. Lane Bailey, City Manager
132 North Main Street
Salisbury, NC 28144

Subject: COMMENTS ON DRAFT SWMP v1 (NOV-2020-PC-0057)
City of Salisbury
NPDES MS4 Permit No. NCS000484
Rowan County

Dear Mr. Bailey:

On October 14, 2019, staff from the North Carolina Department of Environmental Quality (DEQ) audited
the City of Salisbury (City) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Violation (NOV) was issued to the City on February 21, 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 October 22, 2020.
Staff have reviewed the submitted Draft SWMP and request that the following comments be
addressed in a final Draft SWMP. The 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. The short version of the permit renewal application form can be found on DEQ MS4 Forms &
Resources web page.

Comments

1. Section 3.4: Please include the following items regarding inter-connection with the NCDOT
MS4, as appropriate.
The MS4 interconnects with the NCDOT MS4. The interconnection(s) with the NCDOT
MS4 include:
o Receiving stormwater from the NCDOT MS4. The number of interconnections is
known / estimated / unknown. Quantity:
o Discharging stormwater into the NCDOT MS4. The number of interconnections is
known / estimated / unknown. Quantity:
The MS4 mapping does / does not identify interconnections with the NCDOT MS4.
The MS4 mapping does / does not include NCDOT MS4 outfalls.

2. Table 12: Mercury is a statewide air quality TMDL and does not have to be included as a target
water quality pollutant in the SWMP.
3. BMP 6.B.3: Please break into two measurable goals – one to establish the tracking mechanism
and one to perform the tracking.
4. BMP 7.D.1: The listed reporting metric does not correspond to the city council task/measurable
goal.
5. BMP 10.D.1: Please include a volume of trash collected rather than a general description of trash
collected.
6. BMP 11.D.1: Please include total number of catch basins marked.
7. BMP 14:C & D: Include BMP reference number.
8. BMP 14: At least one full year of outfall inspections will be required to be performed prior to the
permit year 4 compliance audit. Please adjust schedules accordingly.
9. Reinsert Permit Ref. 3.5.5 and include appropriate measurable goals. Each MS4 is required to
implement local waste management requirements.
10. Table 19: Include table heading. Enter date adopted for 3.6.6(b), or appropriate BMPs to address
the requirements.
11. BMP 24: Most MS4s review and update ordinances, but it is not clear if this was the intent of
this BMP. Please clarify what task(s) will be performed to “maintain” and the reporting metric.
12. Permit Ref. 3.6.6: Change the reference from Table 18 to Table 19. See also comment 10 above.
If there is no requirements for septic operation and maintenance currently in place, then include
appropriate BMPs to address.
13. BMP 35: Please clarify what an “active SPCC form” is.
14. BMP 37: There are insufficient BMPs to establish that the MS4 is being inspected and
maintained. Clarify what will be inspected weekly. Include BMPs that quantify and report
ongoing collection system maintenance. Most MS4s report the number of catch basins and
collection system miles cleaned/maintained or work orders executed annually.
15. BMP 38.B.3: It is not clear how this BMP relates to the SCM inventory. Please clarify.
16. BMP41: Please also include the number of industrial permits. This provides context for the
number of inspections performed.

The required revised Final Draft SWMP 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 City’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 Final Draft SWMP and permit renewal application to:

DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell

1612 Mail Service Center
Raleigh, NC 27699-1612
[e-mail]

Upon receipt, a Draft Permit and the submitted Final 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]
Annette Lucas, DEMLR Stormwater Program Supervisor
Zahid Khan, Mooresville Regional Office
DEMLR NPDES MS4 Permit Laserfiche File