NCS000584_SWMP Approval_20230214

ROY COOPER s
Governor C
MICHAELS.REGAN ,o=
Secretary
BRIAN WRENN NORTH CAROLINA
Acting Director Environmental Quality
February 14,2023
CERTIFIED MAII.7021 2720 0000 1254 8043
RETURN RECEIPT REQUESTED
City of Statesville
Attn: Randal Moore, Stormwater Program Manager
Post Office Box 1111
Statesville,North Carolina 28687
Subject: Letter of NCDEQ Concurrence
City of Statesville Draft SWAM
NPDES MS4 Permit No.NCS000584
Iredell County
Dear Mr. Moore:
NCDEQ staff have reviewed the Draft SWMP submittal and concur with the outlined program,
provided that the following comments be addressed in a final Draft SWMP submittal,to be
provided to DEQ within thirty(30)calendar days of receipt of this letter to continue with the
permit renewal process.
Specific Comments
1. Table 3 on page 5 is incomplete.
2. Update looter date.
3. A BMP for permit requirement 2.1.1 is not present in the SWAP.
a. Consider a documented analysis to confirm that the program is adequately funded and
staffed to take place permit year 1. With an annual reporting metric of
adequate/inadequate.
4. Relocate BMP 5.6 to the Program Administration portion of the SWMP.
5. A BMP for permit requirement 2.2.2 is not present in the SWMP.
a. Consider a measurable goal to create all required written procedures for permit year 1
with a reporting metric of yes/no.
b. Consider a measurable goal to review all written programs and update as need for permit
years 2-5 with an annual reporting metric of yes/no.
6. BMP 5.1 should be elaborated on to include that the agreements will be reviewed to ensure
compliance with all requirements outlined in 3.2 of the permit.
7. BMP 6.1 schedule for implementation should be"quarterly".
8. In BMP 6.4, Consider adding examples of what events may be provided.
9. BMP 7.2 annual reporting metric should include Yes/No. You will need an answer for that BMP
even if no revisions were made.
10. A BMP for permit requirement 3.4.3-(e shall be provided.
a. Consider an annual evaluation of the IDDE program with reporting metric Yes/No.
D_EQ�� North Carolina Department of Environmental Quality I Division of Energy,Mineral and Land Resources
512 North Salisbury Street 11612 Mail Service Center I Raleigh,North Carolina 2 76 9 9-1612
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Page 2 of 2
Letter of Concurrence
City of Statesville
February 14, 2023
11. BMP 9.4 is currently a repeat of BMP 9.3 and does not demonstrate compliance with 3.6.3 of the
permit.
a. Consider review and maintenance of the permittee's ordinance to determine if it
accomplishes the purpose outlined in 3.6.3 with a reporting metric of Yes/No.
12. Consider making the reporting metric for all trainings outlined in the SWMP"number of staff
trained"or"participation".
13. The reporting Metric for BMP 10.9.5 can be changed to Yes/No.
14. The reporting metric for BMP 10.9.4 can be reduced to the number of SCMs inspected.
15. The reporting metric for BMP 10.11.1 should be a number rather than Yes/No.
16. Reformat cells for BMPs 10.13, 10.14 and 10.15 to reduce confusion.
For final approval,the revised Draft SWMP submittal must include a scanned pdf sent to the below listed
email, and a hard copy with 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 revised SWMP to:
DEQ-DEMLR Stormwater Program
Attn: Isaiah Reed
1612 Mail Service Center
Raleigh,NC 27699-1612
And electronically to:
Isaiah.reedgncdenr.gov
Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
[phone] or at Isaiah.reed2ncderingov.
Sincerely
Isaiah Reed, PE, CPSWQ,MS4CECI
MS4 Program Coordinator
North Carolina Department of Environmental Quality
ec: DEMLR NPDES MS4 Permit Laserfiche File
Randal Moore, Stormwater Program Manager rmooregstatesvillene.net
Isaiah Reed, MS4 Program Coordinator Isaiah.reed(2ncdenr.gov