NCS000488_Valdese SWMP Inquiry Email_20200529

From:Jack Cline
To:Powell, Jeanette
Cc:John Wear
Subject:Re: [External] Town of Hudson SWMP modifications
Date:Friday, May 29, 2020 2:38:34 PM
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Hello Ms. Powell,
I believe the Caldwell SWMPs are ready to be resubmitted, but I wanted to make sure they are
being submitted correctly. From the current NOV:
"The required revised Draft SWMP v4 submittal must also include an electronic Word document
in Track
Changes format, 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
City’s current MS4 Permit. The revised Draft SWMP v4 shall be submitted to..."
We have tracked all changed made to the SWMPs and will submit them digitally along with
mailing the 'wet signed' physical copies, but I wanted to verify with you if the 'certifying
statement' is intended to be this certification from the SWMP (pasted below), or is the certified
statement supposed to be its own separate document written by each manager?
Thank you,
Sincerely,
Jack Cline
Stormwater Administrator
Western Piedmont Council of Governments
Community & Regional Planning/Data Service
From: Powell, Jeanette <[e-mail]>
Sent: Monday, May 18, 2020 1:26 PM
To: Jack Cline <[e-mail]>
Subject: RE: [External] Town of Hudson SWMP modifications

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Hi Jack,

Their SWMPs should include what they already have/will continue doing, but should also define the
new components that will address the deficiencies identified in the audit reports.

J
Jeanette Powell, CPSWQ
MS4 Program Coordinator
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
512 N. Salisbury Street, Office 640M, Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC 27699-1612
919-707-3620
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental
Quality has adjusted operations to protect the health and safety of the staff and public. Many
employees are working remotely or are on staggered shifts. To accommodate these staffing changes,
all DEQ office locations are limiting public access to appointments only. Please check with the
appropriate staff before visiting our offices, as we may be able to handle your requests by phone or
email. We appreciate your patience as we continue to serve the public during this challenging time.

From: Jack Cline <[e-mail]>
Sent: Monday, May 18, 2020 11:35 AM
To: Powell, Jeanette <[e-mail]>
Cc: John Wear <[e-mail]>; Lucas, Annette <[e-mail]>
Subject: Re: [External] Town of Hudson SWMP modifications

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Hello Ms. Powell,

Thank you for answering my questions, it definitely makes me feel more confident in the edits
i've made to the caldwell SWMPs.

I did have one last question regarding how I should handle the Valdese, Conover, and Rutherford
College SWMPs. Since their audits were all in different conditions compared to the Caldwell
audit (where it was essentially developing the program as a whole), should their SWMPs focus on
newly addressing just the audited shortcomings and maintaining what works (based off what
passed for each of their audit) or should it be written as a whole program being 'revamped'
similar to the caldwell SWMPs?

Thank you,
Jack Cline
Stormwater Administrator
Western Piedmont Council of Governments
Community & Regional Planning/Data Service
From: Powell, Jeanette <[e-mail]>
Sent: Tuesday, May 12, 2020 3:45 PM
To: Jack Cline <[e-mail]>
Cc: John Wear <[e-mail]>; Lucas, Annette <[e-mail]>
Subject: RE: [External] Town of Hudson SWMP modifications

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have questions about this email, please contact a WPCOG IT Staff Member.
Hi Jack,

Sorry for the delayed response, please see bold comments below.

Thanks,
J
Jeanette Powell, CPSWQ
MS4 Program Coordinator
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
512 N. Salisbury Street, Office 640M, Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC 27699-1612
919-707-3620
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental
Quality has adjusted operations to protect the health and safety of the staff and public. Many
employees are working remotely or are on staggered shifts. To accommodate these staffing changes,
all DEQ office locations are limiting public access to appointments only. Please check with the
appropriate staff before visiting our offices, as we may be able to handle your requests by phone or
email. We appreciate your patience as we continue to serve the public during this challenging time.

From: Jack Cline <[e-mail]>
Sent: Wednesday, May 6, 2020 3:20 PM
To: Powell, Jeanette <[e-mail]>
Cc: John Wear <[e-mail]>; Lucas, Annette <[e-mail]>
Subject: Re: [External] Town of Hudson SWMP modifications

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attachment to [e-mail]

Thank you again for looking over our SWMP and getting back so quickly, me and Johnny both
greatly appreciate it! Im glad that most of my edits were acceptable as well.

I did have a few questions I want to make sure im addressing correctly:
Two of our towns (Cajahs Mountain and Gamewell) are very small and dont have some of
the components being addressed in the SWMP, and I want to make sure im doing the
'town specifics' part correctly – Yes, this is acceptable
Neither of these towns has: a municipal SCM, a facility with spill potential, municipal
vehicles, a vehicle maintenance facility, a facility that would require an O&M, or a
SPCC facility.
I wanted to make sure that its acceptable to write those similar to BMP 53 on
Hudsons swmp (municipal scms) where I added "However, at the time of developing
this SWMP the Town of Hudson does not currently have a municipally owned SCM.
Should the Town need to install one following expansion, these procedures will be
followed"
For example I would add the following to the vehicle and Equipment Cleaning BMP:
"The Town of Cajahs Mountain does not own any municipal vehicles that
would require washing. Should one be purchased the procedures in this BMP
will be followed" with a continuous schedule for implementation
BMP 18 Stream cleanups – I concur. The reporting metrics can be “Was the event
publicized? Y/N/Status” and number of participants. If you have low turnout (and the
weather is good), then you could surmise that the publicizing method was a factor.
For the publicizing part I made the reporting metric 'number of social media tags
and shares' since that would be a trackable metric for this. I will add "The event will
be posted on the WPCOG website, The Town Website, and flyers will be distributed
at town hall", however tracking the results of that might be difficult to put into a
metric outside of flyers distributed.
Would doing something like "At stream cleanup events, participants will be asked
how they heard about the event" and make the metric "number of participant
responses" in addition to social media shares?
Or I could add that MG to the BMP as a way to define how it will be publicized, but it
would lose the reporting metric. I would just put "Number of Stream Cleanup
participants" since that's the ultimate result of it being shared, but I think that would
be a redundant metric within the same BMP
BMP 19
When you say that the 33.3% part should be in #4, do you mean replacing the "Add
new infrastructure as new construction occurs" part with the 33.3% part entirely, or
adding it to #4? No, my mistake.
My intention was the 33.3% is defining how much of the town we will be mapping
each year to reach 100% and #4 was for adding new infrastructure as new
construction occurs within the town vs. mapping the existing. Basically would
moving that part into the BMP and adding the "Was at least 33.3% of the MS4 area
mapped" as the metric be acceptable for this change? This is acceptable
BMP 35 Standard reporting
Just to make sure, this just needs to be replaced with what's written in the template
and that will be acceptable? Yes
BMP 45 Municipal Facilities O&M
The facilities that would require an O&M plan would be things like water treatment
plants, vehicle maintenance facilities, fire departments, public works facilities
(basically anything with pollutant sources present). A municipally owned park or
public parking lot wouldn't need their own O&M, is this correct? Correct
Reason being Cajahs and gamewell each only own a parking lot, a park, and
town hall - so if I wrote "Currently the Town of Cajahs Mountain does not
have any facilities that would require an O&M plan......" I want to make sure
it's accurate to what's expected from DEQ
Similar question applies for spill response (although I believe that is more of a 'this
facility stores potential pollutants, thus spill plan is required' if im correct) Correct
BMP 47 Spill response – requirements for reporting spills can be found at:
https://www.ncleg.net/enactedlegislation/statutes/pdf/bysection/chapter_143/gs_143-
215.85.pdf [ncleg.net]

Your comment mentions denoting large (reportable) spills and small spills. Is there a
quantifiable metric/criteria that would necessitate reporting a large spill to DEQ?
BMP 58 Street and Parking lot Sweeping
Cajahs only has one municipally owned road, would it be acceptable to put "The
Town only owns one municipal road, said road will be swept annually. To supplement
this, the Town will take an outreach approach and will prioritize inspecting right-of-
way conveyances to prevent blockages"? You could skip the sweeping and rely on
inspection, O&M, and public education to prevent issues
Gamewell has no municipally owned roads and they only have two parking lots, so
would "The Town of Gamewell does not own any municipal roads. The parking lots
found at town hall and the park will be kept free of debris. To supplement this an
outreach approach will be taken along with prioritization of inspecting Right-of-way
conveyances" be acceptable? Yes
BMP 60 Leaf Collection
For the schedule I put it at continuously since its annually but within a certain range
instead of year round. Would "Annually November to January" suffice for the
schedule of implementation? or would just "Annually" be prefered? Yes, annually
on a seasonal basis is appropriate
Similarly, Cajahs and Gamewell do not have a leaf collection service, would an
outreach approach and focus on cleaning leaves off of municipal properties be
sufficient or would they be required to contract out a leaf collection service during
the fall? They could rely on inspection, O&M, and public education to prevent
issues, but develop more measures if issues are noted

COVID/Current turn in date
Do you currently have an expected date for when the 6 Caldwell SWMPs will need to
be submitted by given the current timeline with the Stay at home order? I want to
ensure they will be ready and submitted by that time given the current phased
approach the state is taking. See 05/11/20 email
Apologies for the wall of text, I just want to be as clear as possible and cover everything I can
(and im a bit long winded). Again, thank you so much for taking the time with us to make sure we
get this right

Sincerely
Jack Cline
Stormwater Administrator
Western Piedmont Council of Governments
Community & Regional Planning/Data Service
From: Powell, Jeanette <[e-mail]>
Sent: Wednesday, May 6, 2020 12:35 PM
To: Jack Cline <[e-mail]>
Cc: John Wear <[e-mail]>; Lucas, Annette <[e-mail]>
Subject: RE: [External] Town of Hudson SWMP modifications

This is an external email. Please be cautious before clicking any links or attachments. If you
have questions about this email, please contact a WPCOG IT Staff Member.
Great job, Jack! Attached are a few comments. I look forward to getting all your SWMP submittals in.

Thanks,
J
Jeanette Powell, CPSWQ
MS4 Program Coordinator
Division of Energy, Mineral and Land Resources
Department of Environmental Quality
512 N. Salisbury Street, Office 640M, Raleigh, NC 27604
1612 Mail Service Center, Raleigh, NC 27699-1612
919-707-3620
Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental
Quality has adjusted operations to protect the health and safety of the staff and public. Many
employees are working remotely or are on staggered shifts. To accommodate these staffing changes,
all DEQ office locations are limiting public access to appointments only. Please check with the
appropriate staff before visiting our offices, as we may be able to handle your requests by phone or
email. We appreciate your patience as we continue to serve the public during this challenging time.

From: Jack Cline <[e-mail]>
Sent: Monday, May 4, 2020 3:46 PM
To: Powell, Jeanette <[e-mail]>
Cc: John Wear <[e-mail]>
Subject: [External] Town of Hudson SWMP modifications

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attachment to [e-mail]

Ms. Powell,

Thank you again for taking the time last week to talk to me and Mr. Wear about our SWMP, I
believe it really helped me focus on the corrections I needed to make. I hope the changes I have
made put us in the right spot for approval. Thank you again for offering to look over our SWMP
before our next official submittal, it will be very helpful for us to ensure the most recent changes
are correct and to reassure we are on the right path. I have attached the Town of Hudson SWMP
that I have made the edits from our call to.

In regards to what changes were made (broadly):
Track changes was left on to view exactly what changed in this current version
Modification/revisions from the previous comments provided (as discussed during our call.
These changes were done before our call last week, so this would be the version we
looked at together but it's where the bulk of the BMP specific changes came from)
Added more town specific details (where possible) to the Town of Hudson for this SWMP
Ex: Specified their large festival for outreach events, specified a targeted stream for
cleanups, specified the school targeted for outreach activities, etc.
Modified the reporting metrics to your recommendations (numerical focus, moved 'extra
details' to the MGs with a note on what should be recorded for the audit vs. in each
annual report as originally written)
Modified the specific BMPs we looked at during our call from your recommendations
Corrected several of the 'Schedule for implementation' issues found during our call and to
better match their reporting metrics/BMPs
All other modifications were from specific BMPs we looked at, previous revisions, cross
referencing BMPs/reporting metrics, and overall clean up of the SWMP and are probably
best shown on the document itself.

Again, thank you for helping us so much with our SWMPs. My hope is that these revisions will
put us in the right spot for approval. If this version is satisfactory I will make similar edits
(within reason to maintain municipal specific variation) for our other SWMPs that are
requiring resubmittal.

Sincerely,
Jack Cline
Stormwater Administrator
Western Piedmont Council of Governments
Community & Regional Planning/Data Service