NCS000422_Black Mtn Draft SWMP v1 Comment Letter_20201130

ROY COOPER 4;.,
Governor
' 1V
MICHAEL S.REGAN
Secretary
BRIAN WRENN NORTH CAROLINA
Director Environmental Quality
November 30, 2020
CERTIFIED MAIL 7019 1 120 0000 5077 1759
RETURN RECEIPT REQUESTED
Town of Black Mountain
Attn: Don Collins,Mayor
160 Midland Avenue
Black Mountain,NC 28711
Subject: COMMENTS ON DRAFT SWMP (NOV-2020-PC-0116)
Town of Black Mountain
NPDES MS4 Permit No.NCS000422
Buncombe County
Dear Mr. Collins:
On February 12, 2020,the North Carolina Department of Environmental Quality(DEQ)audited the Town
of Black Mountain(Town)for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Violation(NOV)was issued to the Town on February 27, 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 May 4, 2020.
Staff have reviewed the submitted Draft SWMP and request that the following comments be
addressed in a final Draft SWMP. The revised Draft SWMP is required to be submitted to DEQ
within thirty(30) calendar days of receipt of this letter.
General Comments
1. Refer to the General SWMP Guidance, which has been posted in the Phase II MS4 Toolbox on
the DEQ MS4 web page. It provides detail on what is required for BMPs, appropriate measurable
goals, and reportable metrics. This guidance should be used to establish clear, specific and
measurable goals throughout the Town's Draft SWMP document. There is a general lack of
specificity throughout the document.
2. Delete all embedded instructions throughout the document(red italicized text).
3. Consecutively number each BMP under"BMP No."throughout the document. Do not restart
numbering in each table. This provides for quick and accurate referencing(e.g. BMP 24.B.3
would reference BMP 24, Measurable Goal 3).
4. Delete all blank rows/numbers in tables.
5. Every BMP in the tables must be a named and a clear description must be provided. These BMPs
will be used to determine compliance with the MS4 program, so they must be clear, measurable,
and specific.
6. Each Measurable Goal (MG)must be clear, measurable, and specific.
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7. Each MG is required to have a schedule for implementation. The schedule for MGs should
according to permit year(Permit Year 1 or Permit Years 2-5, for example),not according to the
month and year when you expect to complete the task. In addition, include a frequency(quarterly
or annually,for example). This will be important during the annual reporting process going
forward.
8. Cross-reference BMPs that are used under more than one permit conditions to streamline the
reporting and compliance process. It is only necessary to report an activity one time. Rather than
repeat the wording,provide cross-references if the same BMP or MG is used to meet other permit
conditions.
Specific Comments
1. All pages: Show correct date for the SWMP in the footer.
2. Section 3.3: Complete this table. Unnamed tributaries will either have their own stream index
number/classification or will take on the index number/classification of the water to which they
drain.
3. Section 3.9/Table 7: Add car washing unless section 3.8 provides support for not including it.
Complete the table to provide the SWMP Program addressing each target pollutant/audience.
4. Section 4.3/Table 9: Include specifically which BMP/Permit Requirement that each entity assists
with.
5. Table 12: Add car washing unless section 3.8 provides support for not including it.
6. Table 13: "Implement a Public Education and Outreach Program" is too vague for a BMP
name/description. It will be difficult for the Town to demonstrate compliance with this BMP.
7. Tables 14: "Volunteer Community Involvement Program"and"Mechanisms for Public
Involvement"are too vague for BMP names/descriptions. It will be difficult for the Town to
demonstrate compliance with these BMPs.
8. Table 15: Since the Town does not have a current storm sewer system map,a BMP for creating a
compliant map with MGs and a schedule must be provided.
9. Table 16: Delete the second two rows of this table.
10. Part 8: Provide references to the local construction site program ordinances.
11. Table 17: The stormwater hotline should be cross-referenced. Check the Town's construction site
ordinance to ensure that it requires construction site operators to control waste(if not,obtaining
the authority for this will need to be included in the SWMP). Also,consider providing contractor
education about waste management as a BMP.
12. Table 18: Delete the last five rows from this table since the Town does not have any Qualifying
Alternative Programs for Post-Construction. Describe any customizations that the Town has
made to the MS4 program in the paragraph(s)under Table 18.
13. Table 19: Nice job.
14. Table 20:
a. The level of specificity under"Standard Reporting"is what is needed elsewhere in the
SWMP. Under the"Schedule for Implementation,"be sure to add Permit Years 1-5.
b. If the Town does not currently have a mechanism for tracking post-construction SCMs
and low-density projects,provide a BMP to develop an inventory.

c. The Town's current fecal coliform ordinance does not sufficiently address current MS4
permit requirements,add a BMP here to establish the needed authority.
15. Table 21:
a. Add a BMP for facility inspections on a regular basis throughout the permit term under
3.7.1.
b. Add a BMP for inventorying facilities with spill potential.
c. More specific BMP titles and descriptions need to be used for items such as"Standard
operating procedures review and improvements"and"General stormwater training."
16. Note that this list of specific comments is in addition to the General Comments above. Nearly
every BMP provided in every table failed to meet at least one of the items listed in General
Comments. It is the Town's responsibility to apply every one of the General Comments to every
BMP in the draft SWMP.
The required revised Draft SWMP v2 submittal must include a certifying statement and original"wet"
signature by the City's ranking elected official or designated City staff member in compliance with Part
IV,Paragraph G of the current MS4 Permit.
Please submit the required Draft SWMP within thirty(30)calendar days via both mail and email to:
DEQ-DEMLR Stormwater Program
Attn: Annette Lucas
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
[phone] or Annette.Lucasc ncdenr.gov.
Sincerely,
annagte, m . 4)C-a-e'-
Annette Lucas,PE
Stormwater Program Supervisor
Cc via email:
Mike Mitchell,EPA Stormwater Enforcement
Jeanette Powell,DEMLR MS4 Coordinator
Alaina Morman,DEMLR Stormwater Compliance&Enforcement
Jessica Trotman, Town of Black Mountain
DEMLR NPDES MS4 Permit Laserfiche File