NCS000480_Rutherford College Draft SWMP v2 DEQ Comment Letter_20201210

December 10, 2020

CERTIFIED MAIL 7019 1120 0000 5077 1742
RETURN RECEIPT REQUESTED

Town of Rutherford College
Attn: Kenneth Geathers, Town Manager
980 Malcolm Boulevard
Rutherford College, NC 28612

Subject: COMMENTS ON DRAFT SWMP (NOV-2019-PC-0452)
Town of Rutherford College
NPDES MS4 Permit No. NCS000480
Burke County

Dear Mr. Geathers:

On July 16, 2020, the North Carolina Department of Environmental Quality (DEQ) audited the Town of
Rutherford College (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Violation (NOV) was issued to the Town on May 30, 2019. 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), version 2, submittal on July 16,
2020. Staff have reviewed the submitted Draft SWMP v2 and request that the following comments
be addressed in a final Draft SWMP. The revised Draft SWMP is required to be submitted, along
with a permit renewal application, to DEQ within thirty (30) calendar days of receipt of this letter.

Comments

1. BMP 3.D.2: Change to number of fliers distributed at Town hall. The number of fliers left there
would not be meaningful metric as there is no indication that they were displayed or
disseminated.
2. BMPs 19, 20, 36, 37, 38, 48, 56, Table 19: Resolve sticky notes in document.
3. BMP 25.B and C.1: “Monitor” implies analytic or qualitative monitoring and continuously
would imply non-stop. Please update language to “screen” and “annually”. For example, BMP
26 is continuous because investigation and tracking occurs for each event.
4. BMP 45.C.3: Implement in permit years 2-5 since plans are developed in Year 1.
5. BMP 53.D.3: Add total number of municipal SCMs as a reporting metric.
6. BMP 60: Provide a metric for quantifying leaf collection such as number of bags, pounds
collected, etc.

The required revised Draft SWMP v3 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 Draft SWMP v3 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 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]
Annette Lucas, DEMLR Stormwater Program Supervisor
Stan Aiken, Asheville Regional Office
Isaiah Reed, Asheville Regional Office
DEMLR NPDES MS4 Permit Laserfiche File