NCS000467_Wake Forest Courtesy SWMP Review_20201207

From:Powell, Jeanette
To:Sarna, Monica
Cc:Snyder, Allison; Annette Lucas ([e-mail])
Subject:RE: [External] Town of Wake Forest SWMP Complimentary Review
Date:Monday, December 7, 2020 10:20:00 AM
Hi Monica,

Below are preliminary comments based upon the 1-hour courtesy review. In general, you are on the
right track and the comments are related to more 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.

Preliminary Comments:

BMP 7- report number of publications
BMP 9 – report number of calls and Y/N for evaluate/update/assess
BMP 11.D.1 – presented? Y/N
BMP 2.D.2 – report # (no comments)
BMP 16 – report Y/N
BMP 18, etc – Report # trained (and keep training material and logs on site for audit)
BMP 19.C.1, etc – Permit year 1-5 implies annually, please include frequency such as “annually” for
clarity
BMP 21.B.3 – clarify what “inspect a point along…” means
BMP 22.D.1 – include Y/N/Partial since this task spans 2 years
Table 16 – Typically, an MS4 implements either a delegated program or DEQ implements the
program for the MS4, not both.
Table 18 – If the MS4 is implementing the Universal Stormwater Management Program
requirements, then those requirements replace WS and HQW requirements [Ref. 15A NCAC 02H
.1020(b)]. So, the WS and HQW programs do not have to be listed.
BMP 39 - Ref. BMP 31.D.5.
BMP 47 – it is recommended that each MS4 evaluate all municipal facilities for exposure at least
once per permit cycle, and then inspect those with high potential annually.
Permit Ref. 3.7.3 – Address specific frequencies, schedules, etc. If this is part of the SOP, reference a
specific document title.
BMP 53 – please report # of inspections, # SCMs maintained and # of trained/certified inspectors
It is also recommended that an MS4 maintain a prioritized capital improvement project list for
collection system repair/replacement and periodic refurbishment of SCMs.
BMP 54 – DEQ prefers that the MS4 ensure that staff maintain their professional development hours
and state certification by either checking the status online or including it as part of the employees
annual performance review. Download and maintain the certified personnel list for future audit
documentation.
BMP 58.D.2 – report miles swept and/or solids collected.
BMP 59 – report quantity collected.

If you have any questions, please let me know.

Thanks,
J
Jeanette Powell, CPSWQ, CPESC
MS4 Program Coordinator
919-707-3620
[e-mail]

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: Sarna, Monica <[e-mail]>
Sent: Thursday, December 3, 2020 4:42 PM
To: Powell, Jeanette <[e-mail]>
Cc: Snyder, Allison <[e-mail]>
Subject: [External] Town of Wake Forest SWMP Complimentary Review

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Hi Jeanette-

The Town of Wake Forest has been developing our updated SWMP for our new permit cycle
beginning in 2021. I believe you had mentioned during the last Wow Webinar offering a one-time
review of new SWMPs. Our draft SWMP is in it’s final stages, and we are hoping to present to our
Board in January for approval. Please see attached our draft SWMP ready for your review. Please
note, we tried to incorporate the new Neuse Management Strategy requirements that will be
effective 2022. Is this review done via email? Or will you sent up a call to discuss comments?

Please let me know if you have any questions, or if you need any additional information. We
appreciate the feedback!

Thank you,
Monica Sarna, PE
Stormwater Engineer
Town of Wake Forest
234 Friendship Chapel Rd
Wake Forest, NC 27587-2901
[phone]
[phone]

Correspondence to and from this E-mail address may be subject to the North Carolina Public Records Law (NCGS Chapter 132) and may
be disclosed to third parties.