NCS000446_Apex Draft SWMP v1 DEQ Comment Letter_20210622

ROY COOPER
Governor
JOHN NICHOLSON
Interim Secretary
BRIAN WRENN
Director
VIA EMAIL ONLY
RETURN RECEIPT REQUESTED
Town of Apex
Attn: Jessica Bolin
[e-mail]
105 Upchurch Street
Apex, NC 27502
NORTH CAROLINA
Environmental Quality
June 21, 2021
Subject: COMMENTS ON DRAFT SWMP v1 (NOC-2021-PC-0127)
Town of Apex
NPDES MS4 Permit No. NCS000446
Wake County
Dear Ms. Bolin:
On September 25, 2020, the North Carolina Department of Environmental Quality (DEQ) audited the
Town of Apex (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice of
Compliance (NOC) was issued to the Town on January 27, 2021. The NOC defined specific document
submittals and deadlines, including the required Draft SWMP submittal (version 1) received on May 25,
2021.
Staff have reviewed the submitted Draft SWMP vl and are providing the following specific comments,
which are also incorporated into the attached mark-up version of the Draft SWMP (in track changes
format). Please address all comments and submit a signed Draft Final SWMP and permit renewal
application form within thirty (30) calendar days of receipt of this letter. Upon receipt, if the
comments have been adequately addressed, the Draft Final SWMP will be sent to notice for public
comments and subsequent permit issuance.
Comments:
1. Add "DRAFT FINAL SWMP" watermark and/or footer title.
2. Update document date on cover page and in footer.
3. Paragraph 3.4: Change NCDOT MS4 to NCDOT TS4
4. Table 4: Change "Summary of to Potential
5. Throughout: Add frequencies to Column C Schedule for Implementation. Appropriate
frequencies are noted in the DEQ Comment Mark -Up.
6. BMP 5.13.1: Add litter.
7. BMP 6.D.1: Add number of hotline calls received.
E Q�� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
_ 512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
NORTH CAROLINA
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8. BMP 7.A.1: Change "can be" to are.
9. BMP 7.D.1: Add number of submissions.
10. BMP 8.1).1: Add total number of drains marked.
11. BMP 9.D.1: Add total number of participants.
12. BMP 10:
a. Column A: Add surface waters, conveyances and flow direction.
b. Column B: Change to "Maintain a the current MS4 map showing major outfalls and
str
c. Add Measurable Goal (MG) 2: Add new infrastructure as it is accepted by the town,
Continuously Permit Years 1- 5, report Yes/No/Partial and number of new outfalls added.
13. BMP 12:
a. Column A: Replace "a" with "the".
b. Column B: Change to "Maintain an and implement the..."
14. BMP 13: Change to "Maintain and implement a the program..."
15. BMP 14.D.1: Change to "Number of illicit discharge reports, confirmed illicit discharges, resolved
illicit discharges and enforcement actions issued."
16. BMP 15.13.1: Change "Document" to "Implement".
17. BMP 16: Reference BMPs 6 and 7 rather than repeating tasks.
18. BMP 21.13.1: Delete monthly.
19. BMP 23: Change "a" to "the" and "require" to "requiring".
20. BMP 24.D.1: Change to "Number of annual inspections received and enforcement actions issued."
21. BMP 27:
a. Column B: Change to "Maintain an updated inventory of municipal facilities with the
potential for generating polluted stormwater runoff."
b. Column D: Add number of facilities.
c. Add MG 2: Inspect municipal facilities with the potential for generating polluted stormwater
runoff annually and report Yes/No and number of facility inspections.
22. BMP 28: Change "building" to "facility" and add number of new facilities to reporting metrics.
23. BMP 29: Replace "document" with "implement".
24. BMP 30: Replace "should" with "will".
25. BMP 3 LA: Change to, "Update and implement the current storm drain operation and maintenance
plan."
26. BMP 31.13.1: Change to "Update the Storm Drain Inspections Plan to inspect 20% annually" in
Permit Year 1 so that the system will be inspected once per permit term rather than the current 10%
/ 10 year plan.
27. BMP 31: Add MG2 to implement the plan and report Yes/No, number of inspections completed,
and number of maintenance work orders.
28. BMP 31: Add MG3 to train staff on pollution prevention and illicit discharge identification.
Reference BMPs 6 and 7.
DE Q�� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center 1 Raleigh, North Carolina 27699-1612
NORTH CAROUNA
Oepanm... Environmmrtal Uua11 /`� 919.707.9200

29. BMP 32.13.1: Change to "Continue to maintain an inventory of Town -owned SCMs, maintain on a
monthly basis, and inspect annually" and add Yes/No to reporting metrics.
30. BMP 33: Change to "Relevant municipal employees shall be trained and certified" and add number
of certified staff to reporting metrics.
31. BMP 34: Add MG 2 and reference BMPs 37 — 29. Add MG 3 to obtain / maintain industrial
stormwater permit coverage for subject municipal facilities.
32. BMP 35:
a. Column A: Change "a" to "the" and correct spelling of publicly.
b. Column B: Change "maintain a" to "implement the" and add MG2 to Continue to collect
yard waste.
33. BMP 36: Add a new BMP 36 for litter management and reference BMPs 3, 5, 9, 31. Move BMP
35.13.3 here. Add a MG to address litter, such as evaluate litter loading in public areas and install
receptacles as appropriate to provide for proper disposal.
The required revised Draft Final SWMP and permit application submittal must include both a hard copy
and a pdf electronic copy. The hard copies must include an original "wet" signature by the Town's
ranking elected official or designated staff member in compliance with Part IV, Paragraph G of the
current MS4 Permit. Please also submit a Microsoft Word Track Changes version identifying all changes
made to the Draft SWMP v2 to address these comments.
Please submit the required signed Draft Final SWMP and permit renewal application to:
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
1612 Mail Service Center
Raleigh, NC 27699-1612
ieanette. powe11kncdenr.gov
Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
Jeanette.Powell&ncdenr. gov.
Sincerely,
Jeanette Powell
MS4 Program Coordinator
Cc via email:
James. Misciagno Rapexnc.org
Annette Lucas, DEMLR Stormwater Program Supervisor
Bill Denton, Raleigh Regional Office
Thad Valentine, Raleigh Regional Office
D North Carolina Department of Environmental Quality Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center 1 Raleigh, North Carolina 27699-1612
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NORTH CAROLINA
Oepartmeru of Environmerrtal Quad /`� 919.707.9200

Lauren Garcia, Raleigh Regional Office
DEMLR NPDES MS4 Permit Laserfiche File
D EQ �� North Carolina Department of Environmental Quality I Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
NORTH CAROLINA
oePenmam of enm onmemai aueiN /� 919.707.9200