HomeMy WebLinkAboutNCS000489_Hendersonville Courtesy SWMP Review_20201207From: Powell, Jeanette
Sent: Monday, December 7, 2020 11:30 AM
To: Huffman, Mike <mhuffman@hvlnc.gov>
Cc: Annette Lucas (annette.lucas@ncdenr.gov) <annette.lucas@ncdenr.gov>
Subject: RE: [External] RE: MS4 TMDL Requirements
Hi Mike,
Below are preliminary comments based upon the 1-hour courtesy review. In general, you are on the
right track and the comments are primarily related to more appropriate/brief reporting metrics. They
need to be very brief (Y/N, #, etc.). An annual assessment report in an excel format that corresponds to
the approved SWMP will be required to be submitted once a new permit is issued. This streamlined
reporting will not have the capability to include logs or reports. The annual assessments will be utilized
to ensure that the MS4 is on track with the SWMP, and will be a component of the compliance audit
prior to permit renewal. Associated logs, etc. should be maintained on site for the periodic compliance
audit, which typically occurs the year prior to permit renewal. The excel format is being implemented in
order to support electronic reporting once DEQ has an EPA-compliant system in place.
It is also recommended that you review the Draft SWMP against the guidance provided on the MS4 web
page to ensure that measurable goals, implementation schedules and annual reporting metrics are
appropriately located and worded.
Preliminary Comments:
• You can also include the map in an appendix.
• You only need to document current endangered and threatened species within the permitted
MS4 area.
• The evaluation should include how many car washes you typically have and whether they would
have the potential to discharge to a receiving stream. Or, you can just ID it as an issue and
address it through the public education and illicit discharge programs. Generally, these activities
should occur on grassed areas where the water can infiltrate and not enter the collection
system.
• Delete instructional text (red italics) prior to submittal.
• BMP 3 – it is unclear if materials are being provided to others or whether the MS4 is presenting.
• Column C should always include a frequency and permit year(s) [e.g. Annually, Permit Year 1-5].
• Column D - Delete verbs such as “record”, “track”, ”document” etc. This column contains what
you will report to DEQ, not the task of recording, tracking, etc. Report quantities, Y/N,
etc. Permit language 12>D.1is very literal. See the guidance on the DEQ MS4 web page for
additional instruction.
• BMP 7 – report Y/N on whether the wrap was installed.
• BMP 10 – report number of calls received.
• BMP 12.D.1 – Report either monthly meetings held? Y/N or # of meetings held annually.
• BMP 14.C – This narrative should be in column A. The measurable goal is 2 events/year and the
schedule for implementation is Annually, Permit Years 1-5.The annual reporting metric is 2
events held? Y/N.
• For educational events, maintain documentation of the topics, materials, agenda and
participants, but only report the number of participants.
• BMP 18 is not clear. It looks like the MS4 will be field inventorying 20% of the MS4’s receiving
waters/outfalls annually and inventorying newly constructed outfalls as they occur. Please
clarify.
• BMP 21 – Provide which permit year this is scheduled for. There is no penalty for completing
the task early.
• BMP 22 is very confusing. Please review guidance and instructions on DEQ MS4 web page.
• BMP 35 – the MS4 is required to implement construction waste management requirements in
addition to erosion and sediment control requirements.
• Please be aware that numbers provided to the MS4 by the county for reporting purposes must
be only applicable to the permitted jurisdictional area, not county-wide. This should be a
component of the formal agreement between the city and the county and, if it isn’t, a
measurable goal to establish an appropriate legal agreement between the two parties should be
in the SWMP.
• BMP 41 – the MS4 must work with the county to address on-site domestic wastewater
treatment systems, if there are any within the city’s jurisdictional area. This could include
dissemination of educational materials, performing inspections, etc.
• BMP 42 – DEQ would prefer a brief reporting metric such as number of fecal coliform sources
identified, etc.
• BMP 45 – should be split into two BMPs and located under Permit Ref. 3.7.3. Include specific
inspection frequency.
• BMP 50 – include SCM maintenance measurable goals.
If you have any questions, please let me know.
Thanks,
J
Jeanette Powell, CPSWQ, CPESC
MS4 Program Coordinator
919-707-3620
Jeanette.Powell@ncdenr.gov
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 6th Floor
1612 Mail Service Center
Raleigh, NC 27699-1612
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.
https://deq.nc.gov/sw
From: Huffman, Mike <mhuffman@hvlnc.gov>
Sent: Thursday, November 12, 2020 3:49 PM
To: Powell, Jeanette <Jeanette.Powell@ncdenr.gov>
Subject: RE: [External] RE: MS4 TMDL Requirements
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
Thanks for the updated Jeanette. The City of Hendersonville’s updated SWMP is attached. Have a great
afternoon!
Mike H.
From: Powell, Jeanette <Jeanette.Powell@ncdenr.gov>
Sent: Thursday, November 12, 2020 3:46 PM
To: Huffman, Mike <mhuffman@hvlnc.gov>
Subject: RE: [External] RE: MS4 TMDL Requirements
Be Advised: This email originated from outside of the Hendersonville network. Do not click links or open
attachments unless you recognize the sender and know the content is safe.
Mike,
DEQ is currently limiting cursory reviews to a 1-hour review. I cannot guarantee when it will be done,
but if you want to send it we will review it.
J
Jeanette Powell, CPSWQ, CPESC
MS4 Program Coordinator
919-707-3620
Jeanette.Powell@ncdenr.gov
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 6th Floor
1612 Mail Service Center
Raleigh, NC 27699-1612
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be
disclosed to third parties.
https://deq.nc.gov/sw
From: Huffman, Mike <mhuffman@hvlnc.gov>
Sent: Thursday, October 29, 2020 1:51 PM
To: Powell, Jeanette <Jeanette.Powell@ncdenr.gov>
Subject: RE: [External] RE: MS4 TMDL Requirements
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
Certainly!
On another note, I’ve converted our SWMP to the new template provided by the State MS4 Program
and would like to request a cursory review at your earliest convenience. I’m going through it now to add
my specific comments/questions and make sure I’ve not left out any pertinent information. Can I
forward it to you once I’ve completed that?
Thanks!
Mike H.