NCS000400_Email RE Jamestown MS4 Permit Public Comments_20240608 (2)

Georgoulias, Bethany
From: Katie Gumerson <[e-mail]>
Sent: Saturday, June 8, 2024 7:19 PM
To: Reed, Isaiah L
Cc: [e-mail]; [e-mail]
Subject: [External] DEMLR Stormwater Program, Jamestown NC NPDES MS4 past-due permit
renewal NCS000400 - PUBLIC COMMENT
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Mr. Reed,
In the Town of Jamestown's Self Audit Permit Report (8/1/2023 - 10/20/2023), page four, Public
Education and Outreach, the first program requirement is: Permittee defined goals and objectives
of the Local Public Education and Outreach Program based on Community Wide Issues.
This is what Matthew Johnson, town manager,reported: "Goals and objectives were defined in the
Stormwater Management Plan (SWMP); goals and objectives are revisited annually with Stormwater
SMART. Determinations are based on water quality reports, permit requirements and industry best
practices."
This is reality: The Town of Jamestown has completely failed to provide any kind of useful, relevant
public education. The Town of Jamestown does not "outreach" nor communicate with local residents
on critical stormwater, wastewater, water quality, flooding, and contaminated spill information - this
community's top priority items of concern.
In Jamestown's June 2023 stormwater audit report (the onsite audit by NCDEQ personnel), the
NCDEQ auditors made several references to "STORMWATER SMART" to which Jamestown pays
annual membership dues of $5,605 for "stormwater management surface water quality and
watershed protection public education." Stormwater Smart, according to the audit report, is operated
by the Piedmont Triad Water Quality Partnership, also known as the Upper Cape Fear River Basin
Association (UCFRBA).
The members of UCFRBA are towns that lie all along Deep River and discharge to waterways
emptying into Jordan Lake and Randleman Lake. In addition to Jamestown, member towns include
Asheboro, Reidsville, Burlington, Durham, Greensboro and Sanford - towns with the highest levels of
1 ,4 Dioxane and PFAS discharges in the state and country.
1

UCFRBA member facilities' membership dues buy them SHORTCUTS around permitting
requirements: like canned public education brochures, and the right to add a town's name (like
Jamestown) to a list of "participants" in educational events that happen in OTHER member
locations so far away from Jamestown that they are not promoted anywhere near Jamestown, nor do
they have anything to do with the streams in Jamestown.
More information on UCFRBA is here: https://themamestowner9.com/permit-violations-mamestown-
nc/uppper-cape-fear-river-basin-is-not-good-for-Jamestown/
As a result, Jamestown's town manager and utilities staff are freed from any responsibility to provide
any kind of badly needed education and outreach to the local community - so they don't. Jamestown
does not participate in Guilford Creek Week. Jamestown does not promote any kind of clean up of
our waterways, streams, tributaries or creeks.
In fact, public access to the sludgy, dark, smelly Deep River, which runs through Jamestown and is
polluted by industrial discharge from dozens of private and municipal facilities, landfills, dumps,
superfund sites, chemical companies and manufacturers, is BLOCKED in Jamestown.
All public access roads and pathways to Deep River are blocked by gates, "no trespassing signage"
and thick overgrown weeds, fallen trees or dilapidated structures. The only exception is a small
access path below the walking bridge at Dillon Road and Deep River which once had a parking space
but no longer does. Danger signs warn visitors to stay away from a large visible wooden mill several
hundred feet away, on the river, that is falling down.
The town hosts NO litter clean-ups targeting the network of streams and waterways in our town,
National Night Out has NOTHING to do with our waterways and water quality, there are no water-
focused wine & design classes or family fishing days in Jamestown, there is no storm drain
ANYTHING (in fact, the storm drains on Main Street between Town Hall and GTCC stay perpetually
clogged with sticks, cans, trash, leaves and debris), and the only kind of stormwater education that
takes place at the Jamestown Library might be the existence of a Stormwater SMART brochure in a
kiosk somewhere.
Stormwater SMART members are also somehow exempted from the water sampling and monitoring
that stopped years ago yet is so DESPERATELY NEEDED all along DEEP RIVER, BULL RUN,
COPPER BRANCH, LONG BRANCH, RICHLAND CREEK and the other water supply waterways
that merge within Jamestown's boundaries. In a March 28, 2023 letter to Robby Stone (High Point
public works director), Michael Montebello (North Carolina NPDES Program Chief) wrote that due to
some "uncertainties" and missing specifications, "... if a permit is eventually issued (to Eastside
Wastewater Treatment Plant in JAMESTOWN) for a 32 MGD discharge (into DEEP
RIVER/RANDLEMAN LAKE), then reservoir monitoring requirements below[the point of discharge]
for Dissolved Oxygen and chlorophyll CANNOT BE WAIVED BY PARTICIPATING IN THE UPPER
CAPE FEAR RIVER BASIN ASSOCIATION" - thus implying that under other circumstances, these
reservoir monitoring requirements ARE being waived.
2

Due to the severely impaired, contaminated and IGNORED state of Jamestown and southern Guilford
County's waterways, the fact that ANY environmental entity would choose to minimize surface water
monitoring in Jamestown - which is physically set up to be the "outfall" for all of the chemical laden
streams running south from the manufacturing zones of High Point and west Greensboro - is so
incredibly inappropriate that it can only be presumed to be the result of intentional deceit or
dangerous ignorance.
The "community wide issues" that grip this town and the surrounding area - the issues EVERYONE IS
TALKING about, speaking publicly about, researching about, writing about, and submitting public
comments about for the past two years - are:
1 .
2.
3.
4. The
5. rising levels of PFAS contaminants in Jamestown's public water system (see:
6.
7.
8.
https://themamestowner9.com/water-quality-mamestown-nc/pfas-test-results-round-4/
9.
10.
11 .
12.The
13. rising levels of 1 ,4 Dioxane contamination in Jamestown's public water system (see:
14.
15.
16.
https://themamestowner9.com/water-quality-mamestown-nc/1-4-dioxane-i22-years/
3

17.
18.
19.
20.The
21 . lack of oversight and monitoring by the NC DEQ DWR of stormwater permits held by industrial
and chemical facilities that discharge into Jamestown's surface waters (see:
22.
23.
24.
https://themamestowner9.com/water-quality-mamestown-nc/the-worse-it-pets/
25.
26.
27.
28.The
29. lack of communication and response to water and flooding questions and concerns that the
residents and the local community receive from the town of Jamestown (see
30.
31.
32.
https://themamestowner9.com/public-comments-and-citizen-complaints/mamestown-residents-
stormwater-com plaints/
33.
34.
35.
36.The
37. ongoing misinformation campaign by the town manager to DOWNPLAY, and the refusal of the
local Winston Salem Regional Office of the Division of Water Resources to acknowledge, the
contaminated and degraded state of Jamestown's surface waters, contaminated groundwater
38. and aquifers, the increasingly unhealthy state of our drinking water supply
(PTRWA/Randleman Lake - via Greensboro and High Point's connections), and the massive
increases in flooding and damage to our property that is occurring with increasing storm events
39. of higher intensity. (see
40.
41.
4

https://themamestowner9.com/local-government/mamestowns-matthew-mohnson/
AND
https://themamestowner9.com/water-quality-mamestown-nc/l 4-dioxane-levels-increase-
iamestown-nc-water/
The people who live in this community are smart enough to know how to dispose of grease after they
fry bacon. They know what NOT to pour down the drain or commode. And they do NOT pour
chemicals and hazardous materials into the streams and waterways that their pets and the area
wildlife drink from, and that neighborhood kids wade in. We don't need this kind of "education."
We need REAL education - PFAS, VOCs, 1 ,4 DIOXANE, Hazardous METALS measurements and
DATA; how to deal with it in our backyards and streams; why and what buildings in town are
contaminated with intrusive chemical vapors; and a MAP of ALL of the unremedied contaminated
sites, inactive hazardous sites, Brownfields, Superfund sites, inactive landfills, contaminated streams,
and potential vapor-producing sites are located so we can keep our kids, pets, gardens (and
ourselves) away from them. (See https://themamestowner9.com/contaminant-sources-hazardous-
sites/Jamestown-nc-map-contamination/)
This same SELF-AUDIT response states that "Determinations are based on water quality reports,
permit requirements and industry best practices."
Jamestown issues NO WATER QUALITY reports. Today is June 8, 2024. THE MOST CURRENT
WATER QUALITY REPORT Jamestown residents have access to is for the period JANUARY-
DECEMBER 2022: https://storage.googleapis.com/dbc-ocity/files/pdf/Jamestown2022CCRTrifold1-
1689000881 .pdf
Our finished water comes from PTRWA/Randleman Lake. This information is the same as what's in
their Consumer Confidence
Report, HERE (http://ptrwa.org.previewc38.carrierzone.com/2023%20PTRWA%20CCR.pdf) , yet the
Town of Jamestown can't even get it together to drop it in the template and post it on the town
website.
5

Jamestown residents received NOTHING from the town - NO NOTICE - about the high levels of
PFAS found in our drinking water systemduring the EPA's first round of UCMR5 test sampling that
took place at three Jamestown water connections on FEBRUARY 14, 2023.
The EPA states that ALL residents are to be given notice that the test results are available for
review within TWELVE MONTHS after they are provided to the town. The Town of Jamestown
provides NO water quality information to residents except what is found on the 2022 water report
listed above - only the basics from the pipes (lead, copper, asbestos). So not only is the town's
NPDES MS4 permit three years expired, its UCMR5 reporting is past due.
The EPA defines "OUTREACH" as including Public Notice to residents about SPILLS. NO NOTICE
WHATSOEVER was given to this community and surrounding communities regarding the October
2022 spill of industrial wastewater from a chemical manufacturer into BULL RUN STREAM, another
major drinking water supply stream that runs through Jamestown backyards and neighborhoods
before emptying into Deep River. The Winston Salem Regional Office of the NCDEQ did not cite nor
fine the discharger (Alberdingk Boley) for failing to notify residents of this 6-day, 16,000-gallon
MINIMUM spill, even though Alberdingk Boley's pretreated wastewater contains high amounts of 1,4
DIOXANE. (see https://themamestowner9.com/permit-violations-mamestown-nc/alberdingk-boley-spill-
iamestownnc/)
When a second spill occurred in November, 2023, a small one-paragraph notice was posted on the
Town of Jamestown's Facebook page with NO SPECIFICS. Jamestown residents are STILL
AWAITING specific data on these spills that were requested via FOIA submittals last fall. Despite
numerous inquiries, they remain UNANSWERED, so we still do not know what soaked into BULL
RUN's stream banks where our backyard gardens are currently producing tomatoes, squash and
peppers. (see https://themamestowner9.com/contaminant-sources-hazardous-sites/alberdinqk-boley-
spills/eastside-wwtp-omitted-spill-info/AND https://themamestowner9.com/public-records/foia-public-
records-requests-ignored/)
The Town of Jamestown, INSTEAD of providing much needed stormwater/wastewater/water quality
information to its residents has only ignored, mocked, dismissed and ridiculed its citizens for
requesting such information. (see https://themamestowner9.com/water-quality-mamestown-nc/blogger-
responds-to-m islead ing-press-release-from-town-of-iamestown/)
Jamestown sits at a vitally crucial nexus of a number of impaired waterways that suddenly become
"UNIMPAIRED" when they cross the town boundaries into Jamestown. New factories, manufacturers
and massive residential developments with history-making tree clearing and soil disturbance is
currently taking place as part of this area's weirdly chaotic, aggressive "Carolina CORE" push for
frenzied development.
Permits are sloppy and nonstop parades of dump trucks roll through town every day from 1-85/1-40 to
the giant landfills on Deep River with NO LICENSE PLATES.
6

The cost of damages that will come from allowing the Town of Jamestown to continue "NON-
overseeing" of matters related to stormwater, wastewater, water quality, residential density, erosion,
sedimentation and construction controls will cost taxpayers and the U.S. Government BILLIONS of
dollars to repair.
The NC DEQ's Winston Salem Regional Office has demonstrated that it does not have the resources
to monitor Jamestown's deteriorated and contaminated waterways. Guilford County, the City of High
Point, and the City of Greensboro have only contributed to the problem with nonsensical spot-zoning
and conflicting address/authority mapping. (see https://themamestowner9.com/contaminant-sources-
hazardous-sites/brownfields-hazardous-sites/one-metals-drive-greensboro/)
The Environmental Protection Agency needs to step in NOW and take over all stormwater,
wastewater and water quality matters in Jamestown and Southern Guilford County.
Sincerely,
Katie Gumerson