HomeMy WebLinkAboutNCS000441_UNC-Ch Audit Report_20180425Energy, Mineral
and Land Resources
ENVIRONMENTAL QUALITY
April 25, 2018
Sharon Myers
UNC at Chapel Hill EH&S
1120 Estes Dr. Ext.
CB 1650
Chapel Hill, NC 27599-1650
Subject: MS4 Compliance Inspection
Permit No. NCS000441
Dear Ms. Myers:
ROY COOPER
Governor
MICHAEL S. REGAN
Secretary
WILLIAM E. TOBY VINSON, JR.
Interim Director
The North Carolina Department of Environment Quality (NCDEQ), Division of Energy, Mineral
and Land Resources (DEMLR), conducted a Municipal Separate Storm Sewer System (MS4) Compliance
Inspection of the subject permit on April 25, 2018. The compliance evaluation is conducted to evaluate
the University's compliance with the requirements of Section 402(p) of the Clean Water Act (CWA), 33
U.S.C. § 1342(p), the regulations promulgated there under at 40 Code of Federal Regulations Part
122.26, and the subject North Carolina National Pollutant Discharge Elimination System (NPDES) Permit.
We appreciate the staff willingness to work with DEQ during the compliance inspection.
Attached is the inspection report.
If you have any questions concerning this matter please feel free to contact me at (919) 807-
6369 or robert.patterson@ncdenr.gov.
ec: NCS000441 File
Sally Hoyt — UNC EH&S
Janet Clark— UNC EH&S
Jamie Smedsmo — UNC EH&S
Robert Bradley — UNC EH&S
Thad Valentine — DEMLR RRO
Rachel Hart — EPA Region 4
Sincerely,
X��P-
Robert D. Patterson, PE
Environmental Engineer
Stormwater Program
State of North Carolina I Environmental Quality I Energy, Mineral and Land Resources
1612 Mail Service Center 1 512 N. Salisbury St. I Raleigh, NC 27699
919 707 9200 T
MS4 COMPLIANCE INSPECTION/AUDIT
GENERAL INFORMATION
Audit Date: 4/25/2018
Permit No: NCS000441 permittee: UNC at Chapel Hill
NCDEQ Staff Present:
Robert Patterson, Thad Valentine
Municipal Staff Present:
Sally Hoyt, Sharon Myers, Janet Clark, Jamie Smedsmo, Robert Bradley
CONTRACT OPERATIONS/PARTNERSHIPS
n/a
PROGRAMS & DOCUMENTS REVIEWED
O✓ Interagency agreements or partnerships UNC is a member of the Town of Chapel Hill's SW committee
O✓ Legal authorities/ordinances
O✓ Stormwater Management Plan
F/ Annual Report
O✓ Stormwater Staff Org. Chart & Budget
O✓ MS4 & SCM Inventory on GIS
O✓ Pesticide, Herbicide, and Fertilizer (PHF) Controls
O✓ Other inspection forms, SOPs, training slides
Public Education & Outreach
Satisfactory OUnsatisfactory ON/A ONot Reviewed
conscious that the target audience is unique to the univ. compared to typical municipal
MS4
Public Involvement & Participation
( Satisfactory ®Unsatisfactory ON/A ONot Reviewed
hire students to help with drain marking, etc.
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Rev. 201 ghn7
MS4 COMPLIANCE INSPECTION/AUDIT
IDDE
e Satisfactory Q Unsatisfactory 0 N/A
sw and ww inventory in gis for tabelts in field
O Not Reviewed
Post -construction SW
e Satisfactory ® Unsatisfactory O N/A ® Not Reviewed
Implementing Jordan New -D regs themselves as a state entity; proactive with the State
Construction Office wrt projects that need stormwater permits
Construction SW
QSatisfactory
®Unsatisfactory ®N/A 0Not Reviewed
DEQ RRO implements; but UNC staff inspect also at least monthly.
Need to update web link & effective date (item #3) to the NCG01 permit in the document
titled UNC EHS Erosion and Sedimentation Control Guidelines for Construction Projects.
PPGH for Municipal Operations
e Satisfactory 0 Unsatisfactory ® N/A O Not Reviewed
Well implemented. also have req'd NPDES industrial sw permit for subject facilities
TMDLs
e Satisfactory
Unsatisfactory ®N/A 0Not Reviewed
implementing the Jordan Lake Nutrient Strategy for new -development
Evaluation & Monitoring of Industrial SW Discharges to MS4
OSatisfactory QUnsatisfactory eN/A ®Not Reviewed
Water Quality Assessment & Monitoring
O Satisfactory ® Unsatisfactory e N/A ® Not Reviewed
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Rev. 201 ghn7
MS4 COMPLIANCE INSPECTION/AUDIT
ADDITIONAL INFO/COMMENTS
All-round a very well implemented stormwater program.
The NCDEQ— Stormwater Program will review this audit information, and will provide the permittee
with a draft and/or final MS4 Audit Report that may include the following compliance items:
• Notice of Violation. Any permit noncompliance constitutes a violation of the Clean Water Act
and is grounds for enforcement action; for permit termination, revocation and reissuance, or
modification; or denial of permit coverage upon renewal application.
• Notice of non-compliance: A finding that could result in a Notice of Violation, a fine or other
enforcement action if corrective action is not taken.
• Discrepancies: A finding that would not likely cause a Notice of Violation, a fine, or other
enforcement action. Discrepancies are normally a result of poor management practices,
failure to follow installation Standard Operating Procedures, minor differences of
interpretation or administration oversights. Discrepancies can also be findings where
compliance could not be determined
• Identify any repeat deficiencies
• Recommendations represent practices that should be considered to improve the overall
effectiveness to improve stormwater management
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Rev. 2018Jan7