SwSG Comments on NCG070000

SwSGStormwater Services Group, LLC
8916 Oregon Inlet Court
Raleigh, North Carolina 27603
Phone: [phone]
Fax: [phone]
April 26, 2023
Brittany Cook
Stormwater Program
NC Division of Energy, Mineral, and Land Resources
1612 Mail Service Center
Raleigh,NC 27699-1612
RE: Comments regarding Draft General Permit NCG070000
Dear Ms. Cook:
Please accept the following comments into the record for the subject permit.
B-7. Facility Inspections
BMPs shall be inspected by or under the direction of the permittee at a minimum of semi-
annually.
The term BMP should be replaced with SCM as you are referring to constructed stormwater
control measures — the latest terminology referring to bio-retention cells, wet ponds, dry basins,
etc. The term SCM is used correctly elsewhere in the permit.
We agree that a semi-annual inspection schedule is sufficient for SCMs.
B-11. Preventative Maintenance and Good Housekeeping Program
B-11. (a) ... Inspections shall occur at a minimum on a quarterly schedule (January-
March, April-June, July-September, October-December).
With over 3000 site inspections of permitted facilities since 1993, this consultant can confidently
state that quarterly inspections are overkill. Facilities do not change that much in three months
much less year to year. Prior to 2021,NCDEQ allowed for a semi-annual inspection frequency.
A semi-annual inspection will determine if the permittee needs to increase the in-house
frequency of BMP implementation. The annual SWPPP review will document the need for
additional BMPs or physical changes to the facility.
Can the NCDEQ show that Quarterly inspections - a cost incurred by permittees — have any
documented record of improving the quality of stormwater runoff?
1 This consultant uses the term BMP to indicate any action— structural or programmatic - that reduces pollution in
stormwater runoff.

NCDEQ/DEMLR SWSG
NCG070000 Comments
Page 2
I recommend that NCDEQ keep the semi-annual inspections that are in the current NCG070000
permit that was issued 06/01/18. Refer to Part II Section A.4-4 in the current permit.
E-1(d). Required Baseline Monitoring
Samples shall be collected from four separate monitoring periods per year.
With over 4000 stormwater discharge samples collected at permitted municipalities and facilities
since 1991, this consultant can confidently state that quarterly samples are overkill.
Prior to 2021, NCDEQ allowed for semi-annual outfall monitoring. In the late 1990's, a
permittee was allowed to forego monitoring in the 3rd and 4th years of the permit term if certain
criteria was met. Quarterly monitoring—a cost incurred by permittees—does nothing to improve
the quality of stormwater runoff. This expense would be better spent on implementing BMPs
such as shelters and pavement sweeping that actually do reduce pollution.
The permittee has limited control on the runoff quality. External factors such as atmospheric
deposition, length of dry period prior to sample collection, and intensity of rainfall affect runoff
quality and which cannot be controlled by the permittee.
I recommend that NCDEQ keep the semi-annual monitoring schedule that is in the current
NCG070000 permit that was issued 06/01/18. Refer to Part II Section B Table 1 and Section C
Table 4 in the current permit.
E-4.(f)c. Submit the DMR within 30 days after the end of the monitoring period.
Can NCDEQ explain the reasoning for this requirement? If the sample is collected in the first
week of the monitoring period and the lab report is received by the permittee in the second week,
why must the submittal of the DMR be delayed 8 to 10 weeks?
Allow the permittee to submit the DMR within 30 days of receiving the lab analysis report
regardless of when it was received within the monitoring period.
This concludes my comments regarding the draft General Permit NCG070000. You may call me
to discuss my recommendations.
Hy ,ogically,
or ate ervices Group, LLC
es Frei
Senior Project Manager
cc: File
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