NCS000564_Wendell Draft SWMP Courtesy Review Comments_20210118

From:Powell, Jeanette
To:[e-mail]
Cc:Annette Lucas ([e-mail])
Subject:NCS000564: Wendell Draft SWMP Courtesy Review Comments
Date:Monday, January 18, 2021 9:01:00 AM
Hi Marc,

Please see below for preliminary comments on Wendell’s Draft SWMP courtesy review of the
01/08/21 document provided to DEQ. Please note that Wendell would be subject to an automatic
Notice of Violation when audited in 2021 since many basic current permit requirements are not
developed/ implemented (written plans, etc.); and these items cannot be delayed until permit years
4 and 5 since Wendell has had an MS4 permit since 2012.

Comments:
1. Include frequency and applicable permit year(s) in column C.
2. The Draft SWMP only commits to perform activities in Permit Years 4 and 5. The MS4 must
commit to implement the compliant program throughout the permit term (all five years) and
cannot focus implementation on only years 4 and 5 as this would effectively delay permit
implementation for sixteen years.
3. BMP 1: The annual self-assessment (annual report) is required in all permit years 1-5. It is not
acceptale to submit in only years 3 and 4.
4. Written IDDE Plan is required under the current permit and to be completed prior to audit in
2022.
5. Table 19: Complete date adopted column.
6. BMP 35: FYI, most MS4s require the SCM owner to submit an annual inspection in addition to
the proposed requirements. This puts the burden and liability on the SCM owner. It is
recommended that Wendell consider implementing the same approach.
7. BMP 37: Recommend coordinating an outreach and education effort with the county that is
targeted at proper operation and maintenance.
8. BMP 47: If the town employes certified applicators, include annual verification of
certification(s).
9. BMP 48: Please note that some municipal facilities may be subject to industrial stormwater
permitting (vehicle maintenance, wastewater treatment, etc.). The NCDEQ regional office can
assist with identifying wher ethese permits are required. Industrial permits should be
obtained prior to the MS4 audit in 2021.

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
th
512 N. Salisbury Street, 6 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