NCS000515_China Grove Draft SWMP v2 DEQ Comment Letter_20210615

June 15, 2021

VIA EMAIL ONLY
RETURN RECEIPT REQUESTED

Town of China Grove
Attn: Ken Deal, Town Manager
[e-mail]
333 N. Main Street
China Grove, NC 28023

Subject: COMMENTS ON DRAFT SWMP v2 (NOV-2020-PC-0443)
Town of China Grove
NPDES MS4 Permit No. NCS000515
Rowan County

Dear Mr. Deal:

On October 6, 2020, the North Carolina Department of Environmental Quality (DEQ) audited the Town
of China Grove (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Violation (NOV) was issued to the Town on October 14, 2020. The NOV defined specific document
submittals and deadlines. The required Draft SWMP submittal (version 2) was received on March 29,
2021 in response to the DEQ staff comments provided on February 19, 2021.

Staff have reviewed the submitted Draft SWMP v2 and are providing the following specific comments.
Please address all comments and submit a signed Draft Final SWMP and permit renewal
application form within thirty (30) calendar days of receipt of this letter. Upon receipt, if the
comments have been adequately addressed, the Draft Final SWMP will be sent to notice for public
comments and subsequent permit issuance.

Comments:

1. Incorporate the standard SWMP template updates, available on the MS4 web page and attached
for your convenience. These updates should be cut/pasted into the Draft Final SWMP and are
generally denoted in the attached document by green highlighting.
2. Add document date in footer.
3. BMP 3.C.4: Implement Permit Years 2-5.
4. Table 12: Change pubic to public. Add sediment and waste management for the construction
sector.
5. BMP 4.A: Add “Include hotline contact information.”
6. BMP 4.B.2 - 3: Include more specific language to address all pollutants of concern and all
audiences over the term of the permit. For example:

a. B.2: Develop a brochure for each target audience which includes the specific target
pollutants/sources listed in Table 12 and one general stormwater awareness brochure for
all audiences.
b. B.3: Distribute targeted brochures to one specific audience each year. Report the target
audience and numbers distributed.
c. B.3: Distribute general stormwater awareness brochures. Report number distributed.
7. BMP 5.D.5: Delete “document changes made”. Changes should be documented for the
compliance audit, but do not need to be reported annually.
8. BMP 6.D.2: Change to Yes/No/Status
9. BMP 6.D.4: Change to Yes/No/Status and number trained.
10. BMP 6.5: If this is the same as BMP 6.D.3, then this item can be deleted.
11. BMP 7: Change annual reporting metrics to Yes/No/Status and number of events/posts. Delete
number 3 (website) as there is a separate BMP for that, or simply cross-reference BMP 5 rather
than repeating tasks.
12. BMP 8: It is recommended that the town establish a single stormwater hotline number and email,
and replace these measurable goals with “See BMP 6”.
13. BMP 11: Report number of events, number of participants and number of drains marked.
14. BMP 12 - 13: Report Yes/No/Status and number of participants or reports. DEQ will review
documentation during the compliance audit and/or request additional information for the annual
review if needed.
15. BMP 14.D.2 – 3: Report Yes/No/Status.
16. BMP 15: Report Yes/No/Status and number of new outfalls added.
17. BMP 17: Add implementation Permit Years 2-5. Report Yes/No/Status and number of violations
issued. Add a measurable goal for staff training if needed, or clarify number 2.
18. BMP 18: Report date submitted to DEQ instead of policy reviewed and revised. Add a
measurable goal to implement the written IDDE Program in Years 2-5 and report Yes/No/Status.
Clarify item 4 to perform routine dry weather major outfall inspections.
19. BMP 19: The illicit discharge SOP must be part of the submitted IDDE Program Plan. Include
appropriate illicit discharge investigation measurable goals such as:
a. Investigate reported illicit discharges, Permit Years 2-5, Report the number
found/reported, investigated, confirmed as an illicit discharge and resolved/eliminated.
20. BMP 20: Outfall inspections and illicit discharge investigations begin in Permit Year 2, so there
will not be any data to evaluate in Permit Year 1. Evaluate the IDDE Program annually in Permit
Years 2-5 and report Yes/No/Status.
21. BMP 21: Change annual reporting to just Yes/No/Status.
22. BMP 22: Also reference BMP 18. Train all field staff who may encounter an illicit discharge
during their routine duties, not just staff responsible for IDDE.
23. BMP 23: Reference BMPs 8 – 10 rather than repeating tasks.
24. BMP 28: Include a measurable goal(s) to implement and enforce the ordinance in Permit Years
2-5, Report number of violations documented.
25. BMP 29.C.3: Change to Continuously, Permit Years 2-5.

26. BMP 31: The self-audit indicates that the Town has compliant legal authority in place. Where
existing legal authority fully addresses the requirements, please enter “This permit requirement is
fully met by the existing post-construction program, see references provided in Table 19.”
27. BMP 35.B.2: Ref. BMP no. 30.5 rather than 31.5.
28. BMP 36.2: Change to “Implement inspection tracking, Continuously Permit Years 3-5”.
29. BMP 37: Recommend utilizing language such as “permitted post-construction SCMs and low-
density projects” just in case there SCMs or low density projects that were developed prior to the
permitting requirements being implemented.
30. BMP 37: Add development of a low-density inspection and enforcement SOP to standardize and
consistently manage the process. It is recommended that this precede performing any inspections
or notifying any owners. Report Yes/No/Status.
31. BMP 38: Documentation indicates that a pet waste ordinance is already in place. Chang item 1
to review ordinance and update if needed. Item 3 is incomplete, should say maintain current
town-owned pet waste stations.
32. Add a BMP to provide operation & maintenance educational brochures to town residents who
have septic systems. Disregard this comment if there are no septic systems located in the town’s
corporate limits. Update BMP numbering following addition of this BMP.
33. BMP 39.B.4: Update BMP reference to No. 49 rather than 48. Note that BMP and reference
numbers from here onward may change if a BMP is added per comment 32 above.
34. BMP 42: Change BMP reference to BMP No. 39 rather than 38.2. You could simplify and list
“See BMP No. 39” in columns B – D.
35. BMP 45.C.2: Change this item to “Continuously Permit Years 3 – 5” since Column B establishes
that the inspections will be performed per the SOP schedule.
36. BMP 47.A: Enter narrative description of BMP.
37. BMP 47.B.4 – 5: Inspection forms should be specific to the type of device, so multiple forms or a
fully comprehensive form may be needed. To address this issue, have item 4 says “form(s)” and
item 5 say “…using the appropriate SCM inspection form”.
38. BMP 47.B.7: Update reference from BMP No. 45 to BMP No. 45.B.4.
39. BMP 48.D.1: Report Yes/No/Status and number of certified staff.
40. BMP 49.A: Enter narrative description of BMP.
41. BMP 49.B.1: Change to “require an NPDES industrial stormwater permit.”
42. BMP 51: Add a measurable goal to identify hot spots for more frequent sweeping.
43. BMP 52: Specify a minimum number of events. For example, “Provide seasonal collection of
leaves at a minimum of twice per year on residential streets and public areas” and add measurable
goals to evaluate hot spots for more frequent collection and implement.
44. Add a BMP for weekly litter collection in public spaces.

The required revised Draft Final SWMP and permit application submittal must include both a hard copy
and a pdf electronic copy. The hard copies must include an 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 also submit a Microsoft Word Track Changes version identifying all changes
made to the Draft SWMP v2 to address these comments.

Please submit the required signed Draft Final SWMP and permit renewal application 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
[e-mail].

Sincerely,

Jeanette Powell
MS4 Program Coordinator

Cc via email:
Franklin Gover, Stormwater Program Administrator [e-mail]
Annette Lucas, DEMLR Stormwater Program Supervisor
Zahid Khan, Mooresville Regional Office
DEMLR NPDES MS4 Permit Laserfiche File