NCS000331_Fort Bragg MS4 Audit Correspondence_20200819

From:Powell, Jeanette
To:[e-mail]
Subject:MS4 Permit Compliance Audit
Date:Wednesday, August 19, 2020 10:51:00 AM
Attachments:NCS000290_Camp Lejeune MS4 Audit Agenda_20200924.pdf
I received some questions from another base, so am providing you the same information as an FYI:

The MS4 permit compliance audits are scheduled for two consecutive days. The first day is
interviews and documentation review. The second day is field inspection of industrial facilities and
outfalls. I have attached Camp Lejeune’s audit agenda fyi, your audit agenda should be the same.
Do you have an audit date preference for December 9-10 or December 15-16?

DEQ usually takes photographs during site visits, but it is expected that there will be security issues
on base. We can approach this by either (1) obtaining approval for DEQ to take pictures, or (2) base
staff take the pictures under direction of DEQ staff and maintain them on file as required permit
documentation. Under option 2, a photo log would be generated and included in the audit report,
but not the actual photos.

Picking up DEQ staff at the gate and providing escort is acceptable.

DEQ is currently evaluating all of the non-traditional MS4s that have/want to include industrial
facilities in the next permit iteration. We can schedule a meeting to discuss this topic in September
if you would like to.

DEQ is cognizant of fiscal year budgets, and will remain respectful of commitments that cannot be
changed. Under the standard timeline for an audit, the Draft SWMP is required to be submitted 120
days following receipt of the audit notice. For Camp Lejeune, this would likely require Draft SWMP
submittal in April-May 2021 and the new permit would be effective January 1, 2022. However,
please note that the standard audit timeline and permit effective date was developed to work with
the state fiscal year of July 1 - June 30. DEQ is open to basing DOD MS4 permits on the federal fiscal
year of October 1 - September 30, if appropriate. That would make the new permit effective date
either October 1, 2021 or April 1, 2022, with a standard annual reporting period of October 1 -
September 30.

A DOD-relevant Draft SWMP template will be made available this fall. It will be similar to the current
Draft SWMP template posted on the DEQ web page, but will be specific to the DOD MS4 permit
requirements.

Regards,
J

Jeanette Powell
MS4 Program Coordinator

Division of Energy, Mineral and Land Resources
North Carolina Department of Environmental Quality
Phone: [phone]
Email: [e-mail]
Physical Address: 512 North Salisbury Street
Mailing Address: 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