Loading...
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. Page 1 of 3 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 Page 2 of 3 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 Page 3 of 3 Rev. 2018Jan7