NCS000414_Chapel Hill 2021 Annual Report Letter_20210823

PUBLIC WORKS DEPARTMENT
STORMWATER MANAGEMENT DIVISION
405 Martin Luther King, Jr. Blvd.
Chapel Hill, NC 27514-5705
Telephone [phone]
Fax [phone]
www.townofchapelhill.org
August 23, 2021

NCDEQ-DEMLR Stormwater Program
Attn: Jeanette Powell
512 N. Salisbury Street
1612 Mail Service Center
Raleigh, NC 27699- 1612

RE: 2021 Annual Report (NCS000414)

Dear Ms. Powell,

We are submitting this letter in response to the emails we received from you on June 16, 2021, and August
2, 2021, regarding 2021 Annual Reporting guidance for the reporting period July 1, 2020 - June 30, 2021. On
June 8, 2021, the NCDEQ conducted an audit of the Town of Chapel Hill’s Phase II Municipal Separate Storm
Sewer System (MS4) Program. The following minimum control measures were evaluated:

• Program Implementation, Documentation & Assessment;
• Illicit Discharge Detection & Elimination;
• Construction Site Runoff Controls; and
• Pollution Prevention and Good Housekeeping for Municipal Operations.

On July 22, 2021, the NCDEQ issued a Notice of Deficiency (NOD-2021-PC-0397) to the Town of Chapel Hill.
Town Stormwater staff received an email copy of the NOD on July 29, 2021, and the Town Manager received
a hard copy of the NOD via certified mail on August 6, 2021.

The following is a summary of the actions required by the NOD, and the current status of the Town’s
compliance with those requirements.

1. Within 30 calendar days from the date of receipt of the NOD, the Town shall respond in writing to
acknowledge the requirements and the intent to comply.

STATUS: This response letter was submitted to NCDEQ on August 23, 2021, via email, and sent via
certified mail the same day.

2. Within 120 calendar days from the date of receipt of the letter and utilizing the NCDEQ standard
template for each, the Town shall:
a. Conduct a self-audit that includes, at minimum, an evaluation of compliance with the permit
conditions for Public Education & Outreach; Public Involvement & Participation; Post -
Construction Site Runoff Controls, and Total Maximum Daily Loads.

(NOTE: The NOD letter stated that all permit conditions found in Part II of the Town’s MS4
permit be evaluated during the self-audit, but NCDEQ confirmed by email to me on August
2, 2021, that the Town only needs to self-audit the minimum control measures that NCDEQ
did not audit on June 8, 2021.)

Town of Chapel Hill 2021 Annual Report (NCS000414)
August 23, 2021

b. 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 the MS4 requirements over the new 5-year permit term. The
SWMP must address all known compliance deficiencies including, at minimum, the items
detailed in the NCDEQ MS4 Program Audit Report and the Town self-audit.

STATUS: The Town is currently conducting a self-audit of the required minimum control measures
listed in 2(a) above and developing a new draft SWMP utilizing the templates required by NCDEQ.
The self-audit and draft SWMP will be submitted to NCDEQ via email no later than December 6, 2021.

3. Within 30 days of receiving written NCDEQ concurrence that the submitted Draft SWMP documents
a compliant stormwater management program, submit an NPDES MS4 permit application.

STATUS: The Town will submit a new NPDES MS4 permit application within 30 days of receiving
written NCDEQ concurrence the submitted SWMP documents a compliant MS4 program.

4. Respond to public comments on the Draft SWMP and submit a Final SWMP for NCDEQ approval and
final permit issuance.

STATUS: The Town will respond to public comments on the Draft SWMP and submit a Final SWMP
for NCDEQ approval and final permit issuance.

Should you have any questions, please contact me at 919-969-7202 or [e-mail].

Sincerely,

Allison Schwarz Weakley
Stormwater Analyst

cc: Maurice Jones, Town Manager
Chris Roberts, Manager of Engineering & Infrastructure
Ernest Odei-Larbi, Senior Engineer