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HomeMy WebLinkAboutNCS000431_Conover SWMP Inquiry Email_20200529From:Jack Cline To:Powell, Jeanette Cc:John Wear Subject:Re: [External] Town of Hudson SWMP modifications Date:Friday, May 29, 2020 2:38:34 PM CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Hello Ms. Powell, I believe the Caldwell SWMPs are ready to be resubmitted, but I wanted to make sure they are being submitted correctly. From the current NOV: "The required revised Draft SWMP v4 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 City’s ranking elected official or designated City staff member in compliance with Part IV, paragraph G of the City’s current MS4 Permit. The revised Draft SWMP v4 shall be submitted to..." We have tracked all changed made to the SWMPs and will submit them digitally along with mailing the 'wet signed' physical copies, but I wanted to verify with you if the 'certifying statement' is intended to be this certification from the SWMP (pasted below), or is the certified statement supposed to be its own separate document written by each manager? Thank you, Sincerely, Jack Cline Stormwater Administrator Western Piedmont Council of Governments Community & Regional Planning/Data Service From: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Sent: Monday, May 18, 2020 1:26 PM To: Jack Cline <jack.cline@wpcog.org> Subject: RE: [External] Town of Hudson SWMP modifications This is an external email. Please be cautious before clicking any links or attachments. If you have questions about this email, please contact a WPCOG IT Staff Member. Hi Jack, Their SWMPs should include what they already have/will continue doing, but should also define the new components that will address the deficiencies identified in the audit reports. J Jeanette Powell, CPSWQ MS4 Program Coordinator Division of Energy, Mineral and Land Resources Department of Environmental Quality 512 N. Salisbury Street, Office 640M, Raleigh, NC 27604 1612 Mail Service Center, Raleigh, NC 27699-1612 919-707-3620 Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Jack Cline <jack.cline@wpcog.org> Sent: Monday, May 18, 2020 11:35 AM To: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Cc: John Wear <John.Wear@wpcog.org>; Lucas, Annette <annette.lucas@ncdenr.gov> Subject: Re: [External] Town of Hudson SWMP modifications CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Hello Ms. Powell, Thank you for answering my questions, it definitely makes me feel more confident in the edits i've made to the caldwell SWMPs. I did have one last question regarding how I should handle the Valdese, Conover, and Rutherford College SWMPs. Since their audits were all in different conditions compared to the Caldwell audit (where it was essentially developing the program as a whole), should their SWMPs focus on newly addressing just the audited shortcomings and maintaining what works (based off what passed for each of their audit) or should it be written as a whole program being 'revamped' similar to the caldwell SWMPs? Thank you, Jack Cline Stormwater Administrator Western Piedmont Council of Governments Community & Regional Planning/Data Service From: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Sent: Tuesday, May 12, 2020 3:45 PM To: Jack Cline <jack.cline@wpcog.org> Cc: John Wear <John.Wear@wpcog.org>; Lucas, Annette <annette.lucas@ncdenr.gov> Subject: RE: [External] Town of Hudson SWMP modifications This is an external email. Please be cautious before clicking any links or attachments. If you have questions about this email, please contact a WPCOG IT Staff Member. Hi Jack, Sorry for the delayed response, please see bold comments below. Thanks, J Jeanette Powell, CPSWQ MS4 Program Coordinator Division of Energy, Mineral and Land Resources Department of Environmental Quality 512 N. Salisbury Street, Office 640M, Raleigh, NC 27604 1612 Mail Service Center, Raleigh, NC 27699-1612 919-707-3620 Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Jack Cline <jack.cline@wpcog.org> Sent: Wednesday, May 6, 2020 3:20 PM To: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Cc: John Wear <John.Wear@wpcog.org>; Lucas, Annette <annette.lucas@ncdenr.gov> Subject: Re: [External] Town of Hudson SWMP modifications CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Thank you again for looking over our SWMP and getting back so quickly, me and Johnny both greatly appreciate it! Im glad that most of my edits were acceptable as well. I did have a few questions I want to make sure im addressing correctly: Two of our towns (Cajahs Mountain and Gamewell) are very small and dont have some of the components being addressed in the SWMP, and I want to make sure im doing the 'town specifics' part correctly – Yes, this is acceptable Neither of these towns has: a municipal SCM, a facility with spill potential, municipal vehicles, a vehicle maintenance facility, a facility that would require an O&M, or a SPCC facility. I wanted to make sure that its acceptable to write those similar to BMP 53 on Hudsons swmp (municipal scms) where I added "However, at the time of developing this SWMP the Town of Hudson does not currently have a municipally owned SCM. Should the Town need to install one following expansion, these procedures will be followed" For example I would add the following to the vehicle and Equipment Cleaning BMP: "The Town of Cajahs Mountain does not own any municipal vehicles that would require washing. Should one be purchased the procedures in this BMP will be followed" with a continuous schedule for implementation BMP 18 Stream cleanups – I concur. The reporting metrics can be “Was the event publicized? Y/N/Status” and number of participants. If you have low turnout (and the weather is good), then you could surmise that the publicizing method was a factor. For the publicizing part I made the reporting metric 'number of social media tags and shares' since that would be a trackable metric for this. I will add "The event will be posted on the WPCOG website, The Town Website, and flyers will be distributed at town hall", however tracking the results of that might be difficult to put into a metric outside of flyers distributed. Would doing something like "At stream cleanup events, participants will be asked how they heard about the event" and make the metric "number of participant responses" in addition to social media shares? Or I could add that MG to the BMP as a way to define how it will be publicized, but it would lose the reporting metric. I would just put "Number of Stream Cleanup participants" since that's the ultimate result of it being shared, but I think that would be a redundant metric within the same BMP BMP 19 When you say that the 33.3% part should be in #4, do you mean replacing the "Add new infrastructure as new construction occurs" part with the 33.3% part entirely, or adding it to #4? No, my mistake. My intention was the 33.3% is defining how much of the town we will be mapping each year to reach 100% and #4 was for adding new infrastructure as new construction occurs within the town vs. mapping the existing. Basically would moving that part into the BMP and adding the "Was at least 33.3% of the MS4 area mapped" as the metric be acceptable for this change? This is acceptable BMP 35 Standard reporting Just to make sure, this just needs to be replaced with what's written in the template and that will be acceptable? Yes BMP 45 Municipal Facilities O&M The facilities that would require an O&M plan would be things like water treatment plants, vehicle maintenance facilities, fire departments, public works facilities (basically anything with pollutant sources present). A municipally owned park or public parking lot wouldn't need their own O&M, is this correct? Correct Reason being Cajahs and gamewell each only own a parking lot, a park, and town hall - so if I wrote "Currently the Town of Cajahs Mountain does not have any facilities that would require an O&M plan......" I want to make sure it's accurate to what's expected from DEQ Similar question applies for spill response (although I believe that is more of a 'this facility stores potential pollutants, thus spill plan is required' if im correct) Correct BMP 47 Spill response – requirements for reporting spills can be found at: https://www.ncleg.net/enactedlegislation/statutes/pdf/bysection/chapter_143/gs_143- 215.85.pdf [ncleg.net] Your comment mentions denoting large (reportable) spills and small spills. Is there a quantifiable metric/criteria that would necessitate reporting a large spill to DEQ? BMP 58 Street and Parking lot Sweeping Cajahs only has one municipally owned road, would it be acceptable to put "The Town only owns one municipal road, said road will be swept annually. To supplement this, the Town will take an outreach approach and will prioritize inspecting right-of- way conveyances to prevent blockages"? You could skip the sweeping and rely on inspection, O&M, and public education to prevent issues Gamewell has no municipally owned roads and they only have two parking lots, so would "The Town of Gamewell does not own any municipal roads. The parking lots found at town hall and the park will be kept free of debris. To supplement this an outreach approach will be taken along with prioritization of inspecting Right-of-way conveyances" be acceptable? Yes BMP 60 Leaf Collection For the schedule I put it at continuously since its annually but within a certain range instead of year round. Would "Annually November to January" suffice for the schedule of implementation? or would just "Annually" be prefered? Yes, annually on a seasonal basis is appropriate Similarly, Cajahs and Gamewell do not have a leaf collection service, would an outreach approach and focus on cleaning leaves off of municipal properties be sufficient or would they be required to contract out a leaf collection service during the fall? They could rely on inspection, O&M, and public education to prevent issues, but develop more measures if issues are noted COVID/Current turn in date Do you currently have an expected date for when the 6 Caldwell SWMPs will need to be submitted by given the current timeline with the Stay at home order? I want to ensure they will be ready and submitted by that time given the current phased approach the state is taking. See 05/11/20 email Apologies for the wall of text, I just want to be as clear as possible and cover everything I can (and im a bit long winded). Again, thank you so much for taking the time with us to make sure we get this right Sincerely Jack Cline Stormwater Administrator Western Piedmont Council of Governments Community & Regional Planning/Data Service From: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Sent: Wednesday, May 6, 2020 12:35 PM To: Jack Cline <jack.cline@wpcog.org> Cc: John Wear <John.Wear@wpcog.org>; Lucas, Annette <annette.lucas@ncdenr.gov> Subject: RE: [External] Town of Hudson SWMP modifications This is an external email. Please be cautious before clicking any links or attachments. If you have questions about this email, please contact a WPCOG IT Staff Member. Great job, Jack! Attached are a few comments. I look forward to getting all your SWMP submittals in. Thanks, J Jeanette Powell, CPSWQ MS4 Program Coordinator Division of Energy, Mineral and Land Resources Department of Environmental Quality 512 N. Salisbury Street, Office 640M, Raleigh, NC 27604 1612 Mail Service Center, Raleigh, NC 27699-1612 919-707-3620 Based on the current guidance to minimize the spread of COVID-19, the Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Many employees are working remotely or are on staggered shifts. To accommodate these staffing changes, all DEQ office locations are limiting public access to appointments only. Please check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email. We appreciate your patience as we continue to serve the public during this challenging time. From: Jack Cline <jack.cline@wpcog.org> Sent: Monday, May 4, 2020 3:46 PM To: Powell, Jeanette <Jeanette.Powell@ncdenr.gov> Cc: John Wear <John.Wear@wpcog.org> Subject: [External] Town of Hudson SWMP modifications CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an attachment to report.spam@nc.gov Ms. Powell, Thank you again for taking the time last week to talk to me and Mr. Wear about our SWMP, I believe it really helped me focus on the corrections I needed to make. I hope the changes I have made put us in the right spot for approval. Thank you again for offering to look over our SWMP before our next official submittal, it will be very helpful for us to ensure the most recent changes are correct and to reassure we are on the right path. I have attached the Town of Hudson SWMP that I have made the edits from our call to. In regards to what changes were made (broadly): Track changes was left on to view exactly what changed in this current version Modification/revisions from the previous comments provided (as discussed during our call. These changes were done before our call last week, so this would be the version we looked at together but it's where the bulk of the BMP specific changes came from) Added more town specific details (where possible) to the Town of Hudson for this SWMP Ex: Specified their large festival for outreach events, specified a targeted stream for cleanups, specified the school targeted for outreach activities, etc. Modified the reporting metrics to your recommendations (numerical focus, moved 'extra details' to the MGs with a note on what should be recorded for the audit vs. in each annual report as originally written) Modified the specific BMPs we looked at during our call from your recommendations Corrected several of the 'Schedule for implementation' issues found during our call and to better match their reporting metrics/BMPs All other modifications were from specific BMPs we looked at, previous revisions, cross referencing BMPs/reporting metrics, and overall clean up of the SWMP and are probably best shown on the document itself. Again, thank you for helping us so much with our SWMPs. My hope is that these revisions will put us in the right spot for approval. If this version is satisfactory I will make similar edits (within reason to maintain municipal specific variation) for our other SWMPs that are requiring resubmittal. Sincerely, Jack Cline Stormwater Administrator Western Piedmont Council of Governments Community & Regional Planning/Data Service