NCS000501_Waynesville 2020 Annual Report Letter_20201204

16 South Main Street · P.O. Box 100 · Waynesville, NC 28786 Phone [phone] Fax [phone]
Web Address: www.waynesvillenc.gov
Gary Caldwell, Mayor Robert W. Hites, Jr. Town Manager
Julia Freeman, Mayor Pro Tem William Cannon, Town Attorney
Jon Feichter, Alderman
Anthony Sutton, Alderman
Chuck Dickson, Alderman
12/04/2020

DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699- 1612

RE: 2020 Annual Report (NCS000501); Reporting period July 1, 2019 to June 30, 2020.

Dear Jeanette,

We are submitting this letter in response to the email we received from you on November 13,
2020 regarding our Annual Report for the period from July 1, 2019 to June 30, 2020. Because
we were audited during the current reporting period, please consider this letter as our annual
report.

On July 24 and 25, 2019, DEQ conducted a Compliance Stormwater Evaluation Inspection of
Waynesville’s Phase II Municipal Separate Storm Sewer System Program. The following
minimum control measures were evaluated:
 Public Education and Outreach
 Public Involvement and Participation
 Illicit Discharge Detection & Elimination;
 Post-Construction Site Runoff Controls; and
 Pollution Prevention and Good Housekeeping for Municipal Operations.

Based on the audit results, on August 2, 2019, DEQ issued a Notice of Violation (NOV-2019-PC-
0553) to the town outlining the following required actions:

1. Respond in writing within 30 calendar days from the date of receipt of the NOV to
acknowledge these requirements and the intent to comply.
Results: The response letter was received by DEQ on August 30, 2019.

2. Adopt a Council Resolution within sixty calendar days from the date of receipt of the
NOV. The resolution must declare support for a compliant stormwater management
program. An original signed document must be submitted to DEQ.
Results: The Waynesville Board of Alderpersons adopted the resolution on September
10, 2019. The signed document was submitted to DEQ via email on September 10,
2019.
16 South Main Street · P.O. Box 100 · Waynesville, NC 28786 Phone [phone] Fax [phone]
Web Address: www.waynesvillenc.gov

3. Within 120 calendar days from the date of receipt of the NOV:
a) Conduct a self-audit, which includes, at a minimum, an evaluation of compliance with
the permit conditions found in Part II Section B: for Public Education & Outreach;
Section C: Public Involvement & Participation; Section D: Illicit Discharge Detection and
Elimination; Section F: Post-Construction Site Runoff Controls, and Section G: Pollution
Prevention and Good Housekeeping. The self-audit must be documented utilizing the
DEQ standard MS4 Permit Compliance A udit Report Template.
Results: The town contracted with Haywood Waterways Association to complete the
self-audit, which was performed on January 14 and 15, 2020 using the standard
template. The report was submitted to DEQ via email on February 6, 2020.

b) Develop a Draft Stormwater Management Plan (SWMP) which details specific actions,
measurable goals, and implementation timelines to bring the stormwater management
program into compliance with NPDES MS4 requirements over the new 5-year permit
term. The SWMP must be documented utilizing the DEQ Phase II MS4 SWMP Template.
The SWMP must address all known compliance deficiencies including, at a minimum,
the items detailed in the DEQ MS4 Program Audit Report.
Results: The draft SWMP was submitted to DEQ via email on December 2, 2019.

4. Submit an NPDES MS4 permit application within 30 days of receiving written DEQ
concurrence that the submitted draft SWMP documents a compliant stormwater
management program. A new 5-year NPDES MS$ permit will be public noticed along
with the submitted SWMP.
Results: No action, the town is waiting for the draft SWMP to be approved by DEQ.

5. Respond to public comments on the draft SWMP and submit a final SWMP for DEQ
approval and final permit issuance.
Results: No action, the town is waiting for the draft SWMP to be approved by DEQ
before posting for public comments.

In a letter dated May 1, 2020, DEQ requested additional information in the draft SWMP and
outlined the following actions to address deficiencies .
1. The Town of Waynesville’s Draft SWMP is insufficient because it contains many
Measurable Goals that are not clear, specific and measurable and/or are simply
repeating permit conditions. Providing a compliant SWMP within the timeframes stated
in this letter is required to resolve the subject NOV.
2. The Draft SWMP does not address key deficiencies from the (DEQ’s) July 24-25, 2019
compliance audit. … Key deficiencies include, but are not limited to: Written IDDE Plan,
MS4 map, Dry weather screening of outfalls, Post-construction SCM Inventory, Post-
construction SCM O&M Plans , Post-construction SCM inspections, O&M for municipal
facilities, Written spill response procedures, MS4 O&M, and Standardized
documentation and tracking.
16 South Main Street · P.O. Box 100 · Waynesville, NC 28786 Phone [phone] Fax [phone]
Web Address: www.waynesvillenc.gov
3. The required revised Draft SWMP v2 submittal must also include an electronic Word
document in Track Changes format, and a hard copy with a certifying statement and
original “wet” signature by the Town’s ranking elected official or designated Town staff
member in compliance with Part IV, paragraph G of the Town’s current MS4 Permit.
Results: The revised draft SWMP was submitted to DEQ via email on August 10, 2020. It was
submitted in Word format using Track Changes and addressed the deficiencies noted in the
May 1 letter. The signed hard copy was sent to DEQ on August 10, 2020. A cover letter was
also included that outlined other activities completed, these include:
 Updating the town’s outfall (based on dry weather screening) and MS4 inventory map:
https://www.waynesvillenc.gov/sites/default/files/inline -
files/Outfall_compressed%20%281%29.pdf
 Implementing a monitoring and documentation system for post-construction stormwater
BMPs; they’ve asked for engineering verification for several sites, and planned a mass
mailing for others in September;
 Establishing a dedicated webpage and hotline:
https://www.waynesvillenc.gov/departments/development-services/stormwater-
management;
 Completing an educational poster:
https://www.waynesvillenc.gov/sites/default/files/inline -
files/MS4%20Permit%20Poster.pdf, and
 Renewing their contract with Haywood Waterways to implement the Public Education &
Outreach and Public Involvement & Participation minimum measures.

Please let me know if I can provide any information. You may reach me at 828-550-5238.

Sincerely,

Robert W. Hites Jr.
Town Manager