NCS000450_Carrboro Draft SWMP v2 DEQ Comment Letter_20210629

ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
BRIAN WRENN
Acting Director
VIA EMAIL ONLY
RETURN RECEIPT REQUESTED
Town of Carrboro
Attn: David Andrews, Town Manager
dandrewsPtownofcarrboro.org
301 W Main Street
Carrboro, NC 27510
NORTH CAROLINA
Environmental Quality
June 29, 2021
Subject: COMMENTS ON DRAFT SWMP v2 (NOV-2020-PC-0457)
Town of Carrboro
NPDES MS4 Permit No. NCS000450
Orange County
Dear Mr. Andrews:
On August 12, 2020, the North Carolina Department of Environmental Quality (DEQ) audited the Town
of Carrboro (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Violation (NOV) was issued to the Town on October 29, 2020. The NOV defined specific document
submittals and deadlines. The required Draft SWMP submittal (version 2) and permit renewal application
were received on March 17, 2021.
Staff have reviewed the submitted Draft SWMP v2 and are providing the following specific comments,
which are also incorporated into the attached mark-up version of the Draft SWMP (in track changes
format). Please address all comments and submit a signed Draft Final SWMP 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. Add "DRAFT FINAL SWMP" watermark and/or footer title.
2. Update document date on cover page and in footer.
3. Paragraph 3.2, Table 1: Pull the Carrboro footnote out into the body of the text. The standard
provided footnote is for the regulatory definitions for outfalls. The Carrboro footnote provides
important contextual information and should be included in the text preceding Table 1.
4. Paragraph 3.4: Change NCDOT MS4 to NCDOT TS4 and remove "Quantity: N/A" since the
values are applicable, but unknown.
5. Paragraph 3.8: Update text that DEMLR has not required that other non-stormwater flows be
controlled and delete instructions in red italics.
6. BMP 6.D.2: Change reporting metric to Number of students reached.
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7. BMP 18.D: Change reporting metrics to Yes/No/Status and add a measurable goal to update the
ordinance in permit year 1. Upon review of the ordinance, if an update is determined not to be
needed, the status can be entered in the annual assessment template comment box for this
measurable goal.
8. BMP 19.B.2: Add "...plan to DEQ for review and approval" and change the reporting metric to
"Date submitted".
9. BMP 19.13 3: Change measurable goal to "Implement written IDDE Plan" and schedule for
implementation to "Continuously, Permit Years 2 - 5".
10. BMP 20.A: Change "TOC" to "The Town".
11. BMP 22.B.2: Change "remove" to "remedy". Remove implies that the Town will remove the
illicit discharge, whereas the ordinance provides incentives for the responsible party to remedy.
12. BMP 23.D.1: Change reporting metric to Yes/No/Status.
13. BMP 25.B.2: Add "...identify and report potential illicit discharges."
14. BMP 25.C.3: Add "Annually" to the schedule for implementation.
15. BMP 29.13 and D: Add "... permitted development/construction sites."
16. BMP 38.B.2: Add "...review of facilities for stormwater pollution potential and..."
17. BMP 46.B.3: Change the minimum 10% to 20% annually so that the entire system is inspected
over the permit term.
The required revised Draft Final SWAP 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 to:
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
ieanette.powe11 ,ncdenr.gov
Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
Jeanette.Powell&ncdenr. gov.
Sincerely,
Jeanette Powell
MS4 Program Coordinator

Cc via email:
Randy Dodd, Stormwater Utility Manager rdodd&townofcarrboro.org
Annette Lucas, DEMLR Stormwater Program Supervisor
Bill Denton, Raleigh Regional Office
Thad Valentine, Raleigh Regional Office
DEMLR NPDES MS4 Permit Laserfiche File