NCS000449_Cramerton NOV Response Letter_20220411

TOWN OF
CRAMEi TbN
est. 1915
April 1111, 2022
DEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
512 N Salisbury St
1612 Mail Service Center Drive
Raleigh, NC 27699-1612
SUBJECT: Response to Notice of Violation (NOV-2022-PC-0072)
The Town of Cramerton (NC5000449) participated -inanNPDES M54 program audit on February 23ra
2022. The following control measures were evaluated:
• Program Implementation, Documentation, & Assessment
• Public Education and Outreach
• Public Involvement and Participation
• Illicit Discharge Detection and Elimination
• Pollution Prevention and Good Housekeeping for Municipal Operations
On March 24", 2022 DEQ issued a Notice of Violation (NOV-2022-PC-0072) to the Town of Cramerton.
The Notice of Violation detailed the following corrective actions:
1. Respond in writing within thirty (30) calendar days from the date of receipt of this notice to
acknowledge these requirements and intentAb comply.
This letter shall serve as the Town's acknowledgement of these requirements and intent to
comply.
2. Adopt a Council Resolution within sixty (60),calendar days from the date of receipt of this notice.
The resolution must declare support for a compliant stormwater management program.
A resolution confirming the Town's responsibility and support for implementing the
requirements of the NPDES MS4 permit was adopted by the Board of Commissioners on April
7`", 2022. A copy of the resolution is included as an attachment to this letter.
3. Submit documentation for review and comment within one hundred twenty (120) calendar days
from the date of receipt of this letter:
a. The Illicit Discharge Detection and Elimination Program Plan, as required in Part II,
Section A.7. and Section D.2.a. of the current permit.
155 North Maui Street Cramerton, NC 28032 704.824.4337
www.cramerton.org

TOWN OF
CRAmPkTbN
est. 1915
b. The MS4 Operation and Maintenance Program Plan, as required in Part II, Section A.7.
and Section G.2.f. of the current permit.
c. The Municipal SCM Operation and Maintenance Program Plan, as required in Part II,
Section A.7. and Section G.2.h. of the current permit. The Town does not currently
have any owned or operated SCMs. Please clarify on the expectation of this
requirement at this time.
Self -evaluate the permit components that were not reviewed by DEQ for compliance
and submit the results, within one hundred twenty (120) calendar days from the date of
receipt of this letter. The Part II of the MS4 Phase II Audit Template can be used for this
purpose. The specific sections that should be self -audited include:
i. Section E: Construction Site Runoff Controls;
ii. Section F Post -Construction Site Runoff Controls;
iii. Section Hi Total Maximum Daily Loads'(TMDLs).
d. 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 M54 requirements over the new 5-year permit
term'. The SWMP must be documented utilizing the DEC. 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 and the self -audit.
The Town will submit the Illicit Discharge and Detection Elimination Program Plan, the
MS4 Operations and Maintenance Program Plan, and theMunicipal SCM Operation
and MaintenanceProgram Plan for review and comment. Furthermore, the Town will
conduct a self -audit using Part II of the MS4 Phase IPAudit Template for the
Construction Site Runoff Controls, Post -Construction Site Runoff Controls, and the
Total Maximum Daily Loads (TMDLs) components our program. Finally, the Town will
submit a Draft Stormwater Management Plan and submit to DEQ for review and
comment.
4. Submit an NPDES MS4 Permit application for whichever comes first:
a. At least one hundred eighty days prior to permit expiration, or
b. Within thirty (30) days of receiving written DEQ concurrence that the submitted SWMP
documents a compliant stormwater management program and the MS4 should submit
the application including a signed Final Draft SWMP. A new 5-year NPDES MS4 permit
will be public noticed along with the Draft Final SWMP.
155 North Maas Street Cramerton, NC 28032 704-824.4337
www.cTainciton.org

TO`XN OF
CRAMEkT6N
iiiiiiiiiiiiiiiiiiiiiillillillillillilI est. 1915
The Town will submit a new NPDES MS4 permit application within 30 days of receiving
written DEQ concurrence that the submitted SWMP documents a compliant
stormwater management program.
5. Respond to comments on the Draft Final SWMP and submit a signed Final SWMP for DEQ
approval and final permit issuance. The final DEQ-approved SWMP shall become an enforceable
component of the NPDES MS4 permit and an Annual Self -Assessment Template that
corresponds to the approved SWMP will be provided.
The Town will respond with a final SWMP resolving NCDEQ comments on the draft SWMP.
Respectfully,
David Pugh
Town Manager
155 Nordl Maui Street Cramerton, NC 28032 704.824.4337
www.cramerton.org