NCS000483_Kernersville Draft SWMP v1 DEQ Comment Letter_20210616

ROY COOPER
Governor
JOHN NICHOLSON
Interim Secretary
BRIAN WRENN
Director
VIA EMAIL ONLY
RETURN RECEIPT REQUESTED
Town of Kernersville
Attn: Wendi Hartup, Stormwater Manager
townmana__ eerrkchinagrovenc. _ oovv
509 Michael Street
Kernersville, NC 28284
NORTH CAROLINA
Environmental Quality
June 16, 2021
Subject: COMMENTS ON DRAFT SWMP v1 (NOD-2020-PC-0479)
Town of Kernersville
NPDES MS4 Permit No. NCS000483
Forsyth County
Dear Ms. Hartup:
On September 23, 2020, the North Carolina Department of Environmental Quality (DEQ) audited the
Town of Kernersville (Town) for compliance with the subject NPDES MS4 permit. As a result, a Notice
of Deficiency (NOD) was issued to the Town on October 23, 2020. The NOD defined specific document
submittals and deadlines, including the required Draft SWMP submittal (version 1) received on February
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. Incorporate the standard SWMP template updates, available on the MS4 web page and attached
mark-up of the Draft SWMP. These updates are generally denoted in the attached document by
green highlighting, which should be unhighlighted prior to submittal.
2. Add "DRAFT FINAL SWMP" watermark.
3. Update document date on cover page and in footer.
4. Following Table 12: Add a brief narrative description of the existing relationship with PTRC to
serve as the introductory foundation for "continue to..." in the BMP table.
5. BMP 4.D.1: Change reporting metric to Yes/No/Status.
6. BMP 8.D.1: Change reporting metric to Yes/No/Status.
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
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7. BMP 8.D.2: Include number trained in reporting metrics.
8. BMP 13: Include flow direction. If current mapping does not already incorporate flow direction,
then include measurable goals to add it to the mapping.
9. BMP 16.B.2: Include annual inspection of 20% of outfalls.
10. BMP 19, measurable goals 2 - 4: Simply report number trained.
11. BMP 19.C.2: Train staff with potential to discover an illicit discharge annually so they do not
forget in subsequent years. You may want to split this measurable goal into two. IDDE staff
only need one training, but other field staff will need an annual reminder/refresher.
12. BMP 24: The MS4 permit requirement is for the local government to develop and implement an
ordinance for construction site waste management. Relying upon the NCGO10000 permit is no
longer allowable. Please include appropriate BMP(s) and measurable goals to establish and
implement the required local ordinance.
13. Table 19: Add "Permit Year 2" to low density inspections and pet waste ordinance.
14. BMP 29: Add a measurable goal to distribute materials.
15. BMP 30: Add a measurable goal to submit the plan to DEQ for review and approval. Change
"O&M" to "PPGH". Include minimum requirement to inspect high potential facilities annually
and low potential facilities at least once per permit term in permit years 2 — 5. Include
measurable goal to maintain a prioritized facility inventory.
16. BMP 31: Provide annual PPGH training for PPGH staff and staff that work at municipal
industrial facilities. Report number trained.
17. BMP 33.A: Focus the description only on the relevant BMP to provide clarity.
18. BMP 34.A: Focus the description only on the relevant BMP to provide clarity.
19. BMP 34: Add measurable goals to develop and maintain an inventory of municipal SCMs.
20. BMP 37: Clarify that a NCG080000 permit will be obtained if the facility fails to maintain no
exposure status. Report the permit or no exposure number maintained.
21. Permit Reference 3.7.6: Add BUT No. 39 for staff training and renumber following BMP.
22. BMP 39 (40): Focus the description only on the relevant BMP to provide clarity. Add
measurable goals for tracking mechanism, staff training, and pavement management plan
implementation.
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
jeanette.powellknicdenr.gov
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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Thank you for your prompt attention to this matter. Should you have any questions, please contact me at
Jeanette.Powellkncdenr. gov.
Sincerely,
WW4
Jeanette Powell
MS4 Program Coordinator
Cc via email:
DMaltba&toknc.com
Annette Lucas, DEMLR Stormwater Program Supervisor
Tamera Eplin, Winston Salem Regional Office
DEMLR NPDES MS4 Permit Laserfiche File
D North Carolina Department of Environmental Quality Division of Energy, Mineral and Land Resources
512 North Salisbury Street 1 1612 Mail Service Center I Raleigh, North Carolina 27699-1612
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NORTH CAROLINA
Oepartmeru of Environmerrtal Quad /`� 919.707.9200