NCS000517_Sandy Point Memo_20191111

Quible
Quible & Associates, P.C.
ENGINEERING • ENVIRONMENTAL SCIENCES • PLANNING • SURVEYING
SINCE 1959
MEMO
TO: Jeanette Powell, MS4 Program Coordinator, NCDEQ
FROM: Brian Rubino, P.G., Quible4t/V—
CC: Sam Young
SUBJECT: NPDES MS4 Permit No. NCS000517
The Fund for Sandy Point North Carolina, LLC
Modification and Renewal
DATE: November 11, 2019
P.O. Drawer 870
Kdty Hawk NC 27949
Phone: [phone]
Fax: [phone]
web: quible.com
We appreciated you and Annette Lucas taking the time to meet with Sam Young and me to
discuss the Sandy Point permit on October 31, 2019.
The purpose of this memo is to provide some possible permit modification triggers that will allow
Sandy Point to be in compliance with the NPDES Six Minimum Control Measures, since the
development activities requiring NPDES MS4 Permitting have not yet commenced. As
discussed, it is integral to the enabling legislation for Sandy Point's development (Session Law
2004-117) and associated State and Federal Permits that the NPDES Permit be in place and
maintained prior to development activities.
Please consider the following permit modification proposals:
• Cover Page of Permit:
You have informed us that the expiration date has a typographical error and that with
renewal/modification of the permit, we understand the permit expiration will be re -set for
a period of five years.
■ Part II, Final Limitations and Controls for Permitted Discharges:
➢ Section B, Public Education and Outreach
Suggested Trigger: "Upon receiving a certificate of occupancy for the 100'
unit (inclusive of dwelling units and commercial premises such as retail,
food service, general service, office and hotel/motel structures)"
➢ Section C, Public Involvement and Participation
Suggested Trigger: "Upon receiving a certificate of occupancy for the 100tn
unit (inclusive of dwelling units and commercial premises such as retail,
food service, general service, office and hotel/motel structures)"

Notes for NPDES Permit Modification and Renewal @ November 3, 2019
➢ Section D, Illicit Discharge Detection and Elimination
There is currently a trigger in the permit: "within 6 months of occupancy of any
residence and/or commercial building"
Suggested Trigger: "Within 24 months of occupancy of any newly
constructed residence and/or commercial building at Sandy Point"
➢ Section E, Construction Site Runoff Controls
Suggested Trigger: "Upon receiving a certificate of occupancy for the 100tn
unit (inclusive of dwelling units and commercial premises such as retail,
food service, general service, office and hotel/motel structures)"
➢ Section F, Post -Construction Site Runoff Controls
Suggested Trigger: "Upon receiving a certificate of occupancy for the 100tn
unit (inclusive of dwelling units and commercial premises such as retail,
food service, general service, office and hotel/motel structures)"
➢ Section G, Pollution Prevention and Good Housekeeping for FSP Activities and
Operations
There is currently a trigger in the permit, into which we would insert the words
"newly constructed": "Within 24 months of occupancy of any newly constructed
residence and/or commercial building at Sandy Point..."
■ Part III, Program Assessment
Our Suggested Trigger for Program Assessment (A, B, C and D) is: "Within 24 months
of occupancy of any newly constructed residence and/or commercial building at
Sandy Point"
■ Part IV, Reporting and Record Keeping:
➢ F, Annual Reporting
Suggested Trigger: "Within 24 months of occupancy of any newly
constructed residence and/or commercial building at Sandy Point"
(consistent with Part III)
Please review and consider our suggestions, which we believe are appropriate. By example,
until there are at least 100 residential dwelling units, everyone will know everyone and be in
touch with everyone, and hence, a formal notification procedure should not be necessary and
probably would not be utilized. Of course, public participation makes sense only once there are
one hundred dwelling units, that is, once there are enough households that three to five percent
participation is meaningful.
I look forward to discussing these issues with you and will be available by email and/or
telephone at your convenience.
Again, Sam and I appreciate the opportunity to work through this with you and your staff.