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Home My WebLink AboutNCS000489_Hendersonville Courtesy SWMP Review_20201207From: Powell, Jeanette Sent: Monday, December 7, 2020 11:30 AM To: Huffman, Mike <mhuffman@hvlnc.gov> Cc: Annette Lucas (annette.lucas@ncdenr.gov) <annette.lucas@ncdenr.gov> Subject: RE: [External] RE: MS4 TMDL Requirements Hi Mike, Below are preliminary comments based upon the 1-hour courtesy review. In general, you are on the right track and the comments are primarily related to more appropriate/brief reporting metrics. They need to be very brief (Y/N, #, etc.). An annual assessment report in an excel format that corresponds to the approved SWMP will be required to be submitted once a new permit is issued. This streamlined reporting will not have the capability to include logs or reports. The annual assessments will be utilized to ensure that the MS4 is on track with the SWMP, and will be a component of the compliance audit prior to permit renewal. Associated logs, etc. should be maintained on site for the periodic compliance audit, which typically occurs the year prior to permit renewal. The excel format is being implemented in order to support electronic reporting once DEQ has an EPA-compliant system in place. It is also recommended that you review the Draft SWMP against the guidance provided on the MS4 web page to ensure that measurable goals, implementation schedules and annual reporting metrics are appropriately located and worded. Preliminary Comments: • You can also include the map in an appendix. • You only need to document current endangered and threatened species within the permitted MS4 area. • The evaluation should include how many car washes you typically have and whether they would have the potential to discharge to a receiving stream. Or, you can just ID it as an issue and address it through the public education and illicit discharge programs. Generally, these activities should occur on grassed areas where the water can infiltrate and not enter the collection system. • Delete instructional text (red italics) prior to submittal. • BMP 3 – it is unclear if materials are being provided to others or whether the MS4 is presenting. • Column C should always include a frequency and permit year(s) [e.g. Annually, Permit Year 1-5]. • Column D - Delete verbs such as “record”, “track”, ”document” etc. This column contains what you will report to DEQ, not the task of recording, tracking, etc. Report quantities, Y/N, etc. Permit language 12>D.1is very literal. See the guidance on the DEQ MS4 web page for additional instruction. • BMP 7 – report Y/N on whether the wrap was installed. • BMP 10 – report number of calls received. • BMP 12.D.1 – Report either monthly meetings held? Y/N or # of meetings held annually. • BMP 14.C – This narrative should be in column A. The measurable goal is 2 events/year and the schedule for implementation is Annually, Permit Years 1-5.The annual reporting metric is 2 events held? Y/N. • For educational events, maintain documentation of the topics, materials, agenda and participants, but only report the number of participants. • BMP 18 is not clear. It looks like the MS4 will be field inventorying 20% of the MS4’s receiving waters/outfalls annually and inventorying newly constructed outfalls as they occur. Please clarify. • BMP 21 – Provide which permit year this is scheduled for. There is no penalty for completing the task early. • BMP 22 is very confusing. Please review guidance and instructions on DEQ MS4 web page. • BMP 35 – the MS4 is required to implement construction waste management requirements in addition to erosion and sediment control requirements. • Please be aware that numbers provided to the MS4 by the county for reporting purposes must be only applicable to the permitted jurisdictional area, not county-wide. This should be a component of the formal agreement between the city and the county and, if it isn’t, a measurable goal to establish an appropriate legal agreement between the two parties should be in the SWMP. • BMP 41 – the MS4 must work with the county to address on-site domestic wastewater treatment systems, if there are any within the city’s jurisdictional area. This could include dissemination of educational materials, performing inspections, etc. • BMP 42 – DEQ would prefer a brief reporting metric such as number of fecal coliform sources identified, etc. • BMP 45 – should be split into two BMPs and located under Permit Ref. 3.7.3. Include specific inspection frequency. • BMP 50 – include SCM maintenance measurable goals. If you have any questions, please let me know. Thanks, J Jeanette Powell, CPSWQ, CPESC MS4 Program Coordinator 919-707-3620 Jeanette.Powell@ncdenr.gov North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 6th Floor 1612 Mail Service Center Raleigh, NC 27699-1612 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. https://deq.nc.gov/sw From: Huffman, Mike <mhuffman@hvlnc.gov> Sent: Thursday, November 12, 2020 3:49 PM To: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Subject: RE: [External] RE: MS4 TMDL Requirements CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Thanks for the updated Jeanette. The City of Hendersonville’s updated SWMP is attached. Have a great afternoon! Mike H. From: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Sent: Thursday, November 12, 2020 3:46 PM To: Huffman, Mike <mhuffman@hvlnc.gov> Subject: RE: [External] RE: MS4 TMDL Requirements Be Advised: This email originated from outside of the Hendersonville network. Do not click links or open attachments unless you recognize the sender and know the content is safe. Mike, DEQ is currently limiting cursory reviews to a 1-hour review. I cannot guarantee when it will be done, but if you want to send it we will review it. J Jeanette Powell, CPSWQ, CPESC MS4 Program Coordinator 919-707-3620 Jeanette.Powell@ncdenr.gov North Carolina Department of Environmental Quality Division of Energy, Mineral & Land Resources Stormwater Program 512 N. Salisbury Street, 6th Floor 1612 Mail Service Center Raleigh, NC 27699-1612 Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed to third parties. https://deq.nc.gov/sw From: Huffman, Mike <mhuffman@hvlnc.gov> Sent: Thursday, October 29, 2020 1:51 PM To: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Subject: RE: [External] RE: MS4 TMDL Requirements CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Certainly! On another note, I’ve converted our SWMP to the new template provided by the State MS4 Program and would like to request a cursory review at your earliest convenience. I’m going through it now to add my specific comments/questions and make sure I’ve not left out any pertinent information. Can I forward it to you once I’ve completed that? Thanks! Mike H.