NCS000414_Chapel Hill 2021 Permit Application Attachment_20211108

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TOWN OF CHAPEL HILL

Stormwater
Management Plan
(SWMP)

NPDES MS4 Permit #NCS000414

February 2021

Town of Chapel Hill Stormwater Management Plan
NPDES MS4 Permit #NCS0000414
February 2021

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Table of Contents

List of Abbreviations ................................................................................................................................. 6
1 Introduction .......................................................................................................................................... 8
2 Jurisdictional Area ................................................................................................................................. 9
3 Population and Estimated Growth Rate ............................................................................................. 10
3.1 Population ................................................................................................................................... 10
3.2 Growth Rate ................................................................................................................................ 10
4 Stormwater Conveyance System Description ..................................................................................... 10
5 Estimated Land Use............................................................................................................................. 11
6 Receiving Streams ............................................................................................................................... 12
7 Impaired Streams and Existing Programs to Address ......................................................................... 13
8 Total Maximum Daily Loads (TMDLs) ................................................................................................. 14
9 Existing Water Quality Programs ........................................................................................................ 15
9.1 Town Land Use, Development, and Stormwater Standards and Plans ...................................... 15
9.1.1 Chapel Hill 2020 Comprehensive Plan ................................................................................ 15
9.1.2 Town of Chapel Hill Public Works Engineering Design Manual .......................................... 15
9.1.3 Stormwater Management Master Plan .............................................................................. 16
9.1.4 Booker Creek Subwatershed Studies .................................................................................. 16
9.2 Town Code of Ordinances ........................................................................................................... 16
9.2.1 Flood Damage Prevention Ordinance ................................................................................. 16
9.2.2 Erosion and Sediment Control ............................................................................................ 17
9.2.3 Illicit Discharge Detection and Elimination (IDDE) .............................................................. 17
9.2.4 Land Use Management Ordinance (LUMO) ........................................................................ 18
10 Partnerships and Inter-local Agreements ........................................................................................... 22
10.1 Orange County Erosion Control .................................................................................................. 23
10.2 Town of Carrboro ........................................................................................................................ 23
10.3 University of North Carolina at Chapel Hill (UNC) ...................................................................... 23
10.4 Orange Water and Sewer Authority (OWASA) ........................................................................... 23
10.5 North Carolina Department of Transportation (NCDOT) ............................................................ 24
10.6 North Carolina Watershed Stewardship Network (NCWSN) ...................................................... 24
10.7 Clean Water Education Partnership (CWEP) ............................................................................... 24

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10.8 Nutrient Scientific Advisory Board (NSAB) .................................................................................. 24
10.9 Jordan Lake One Water (JLOW) .................................................................................................. 25
10.10 Orange County Hazard Mitigation Plan ...................................................................................... 25
11 State Programs ..................................................................................................................................... 25
12 Reliance on other Government Entity ................................................................................................. 26
12 Points of Contact & Organizational Charts ........................................................................................... 26
13 Public Education and Outreach Program ............................................................................................. 30
13.1 Target Pollutants and Audiences .................................................................................................. 30
13.2 Methods for Education and Outreach .......................................................................................... 31
13.3 Best Management Practices for the Public Education and Outreach Program ............................ 33
14 Public Involvement and Participation Program ................................................................................... 35
14.1 Stormwater Management Utility Advisory Board ......................................................................... 35
14.2 Outreach and Volunteer Opportunities ........................................................................................ 35
14.3 Public Involvement in Subwatershed Studies ............................................................................... 36
14.4 Best Management Practices for the Public Involvement and Participation Program .................. 36
15 Illicit Discharge Detection and Elimination (IDDE) ............................................................................... 37
15.1 Storm Sewer System Map ............................................................................................................. 37
15.2 Regulatory Mechanism ................................................................................................................. 40
15.3 Detection and Elimination ............................................................................................................. 40
15.4 Enforcement Procedures .............................................................................................................. 41
15.5 Non-Stormwater Discharges With Potential to Significantly Contribute Pollutants .................... 41
15.5.1 Pool Discharge & Backwash ................................................................................................ 42
15.5.2 Commercial Air Conditioning Condensate .......................................................................... 42
15.5.3 Water Line Flushing............................................................................................................. 43
15.5.4 Other Prohibited Discharges ............................................................................................... 43
15.6 Outreach & Education ................................................................................................................... 43
15.7 Staff Training ................................................................................................................................. 43
15.8 Evaluation ...................................................................................................................................... 44
15.9 Best Management Practices for Illicit Discharge Detection and Elimination ................................ 44
16 Construction Site Runoff ..................................................................................................................... 47
17 Post-Construction Stormwater Program ............................................................................................ 47
17.1 Regulatory Mechanism ............................................................................................................... 48

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17.2 Operation and Maintenance ....................................................................................................... 48
17.3 Best Management Practices for the Post-Construction Stormwater Program .......................... 48
18 Pollution Prevention and Good Housekeeping ................................................................................... 51
18.1 Municipal Facilities Operation and Maintenance Program ........................................................ 52
18.2 Spill Response Program ............................................................................................................... 52
18.3 Municipal Storm Sewer System (MS4) Operation and Maintenance Program .......................... 53
18.4 Municipal Stormwater Control Measure (SCM) Operation and Maintenance (O&M) Program 53
18.5 Pesticide, Herbicide and Fertilizer Management Program ......................................................... 54
18.6 Vehicle and Equipment Maintenance Program .......................................................................... 54
18.7 Pavement Management Program ............................................................................................... 54
18.8 Employee Training Program ........................................................................................................ 54
18.9 Best Management Practices for Pollution Prevention and Good Housekeeping for Municipal
Operations .............................................................................................................................................. 55
19 References .......................................................................................................................................... 59

List of Tables

Table 1. Town of Chapel Hill Population and Growth Statistics, April 1, 2010-July 1, 2019. ...................... 10
Table 2: Land use types by percent area within the Town of Chapel Hill’s zoning jurisdiction. ................. 12
Table 3. Water quality classifications, use support ratings, and 303(d) list parameters of interest for
receiving streams within the Town of Chapel Hill's zoning jurisdiction (NCDWR 2018). ........................... 12
Table 4. Minimum tree canopy coverage standards by land use type. ...................................................... 22
Table 5. Primary points of contact for the Town of Chapel Hill's MS4 Permit. .......................................... 26
Table 6. Responsible positions and staff per SWMP component. .............................................................. 29
Table 7. Summary of target pollutants and sources, target audiences, and program(s) to address target
pollutants. ................................................................................................................................................... 30
Table 8. BMPs for the Public Education & Outreach program. .................................................................. 33
Table 9. BMPs for the Public Involvement & Participation program. ......................................................... 37
Table 10. BMPs for the IDDE Program. ....................................................................................................... 44
Table 11. BMPs for the Post-Construction Stormwater program. .............................................................. 48
Table 12. BMPs for Pollution Prevention & Good Housekeeping for Municipal Operations. .................... 55

List of Figures

Figure 1. Town of Chapel Hill Corporate (MS4) Limits and Zoning Limits as of November 2020. ................ 9
Figure 2. Map of Jordan Lake Watershed Protection District (blue shading) ............................................. 20
Figure 3. Town of Chapel Hill Organizational Chart Overview. ................................................................... 27

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Figure 4. Organizational chart for the Town of Chapel Hill Public Works Department (December 2020). 28
Figure 5. Stormwater outfalls and receiving streams within the Town of Chapel Hill's zoning jurisdiction.
.................................................................................................................................................................... 39

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LIST OF ABBREVIATIONS
Acronym Meaning
BMP Best Management Practices
CHFD Chapel Hill Fire Department
CO Certificate of Occupancy
COVID-19 Coronavirus Disease 2019
CWEP Clean Water Education Partnership
DO Dissolved oxygen
E&SC Erosion and Sediment Control
ETJ Extraterritorial Jurisdiction
FEMA Federal Emergency Management Agency
FLUM Future Land Use Map
FY19 Fiscal Year 2019
FY21 Fiscal Year 2021
GIS Global Information System
HRD Human Resource Development
HVAC Heating, ventilation, and air conditioning
IDDE Illicit Discharge Detection and Elimination
IPM Integrated Pest Management
JLOW Jordan Lake One Water
IR Integrated Report
LUMO Land Use Management Ordinance
MEP Maximum Extent Practicable
mg/l Milligrams per liter
MS4 Municipal Storm Sewer System
NCAC North Carolina Administrative Code
NCDEMLR North Carolina Division of Energy, Mineral, and Land Resources
NCDEQ or DEQ North Carolina Department of Environmental Quality
NCDOT North Carolina Department of Transportation
NCDWR or DWR North Carolina Division of Water Resources, formerly Division of Water Quality
NCWSN North Carolina Watershed Network
NFIP National Flood Insurance Program
NPDES National Pollutant Discharge Elimination System
NSAB Nutrient Scientific Advisory Board
O&M Operations and Maintenance
OWASA Orange Water and Sewer Authority
PPGH Pollution Prevention and Good Housekeeping
RCD Resource Conservation District
SCM Stormwater Control Measure
SOP Standard operating procedure
SWMP Stormwater Management Plan
SWMUAB Stormwater Management Utility Advisory Board
SWPPP Stormwater Pollution Prevention Plan
TJCOG Triangle J Council of Governments

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Acronym Meaning
TMDL Total Maximum Daily Load
TN Total Nitrogen
TOC Town Operations Center
TP Total Phosphorus
TSS Total Suspended Solids
UNC-CH or UNC University of North Carolina at Chapel Hill
USEPA or EPA United States Environmental Protection Agency
USGS United States Geologic Survey
UT Unnamed tributary
Water Quality Classifications
B Primary recreation, fresh water
C Aquatic life, secondary recreation, fresh water
NSW Nutrient Sensitive Waters
WS-IV Water Supply IV - highly developed
WS-V Water Supply V - upstream

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1 INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to provide information for how the Town
of Chapel Hill is complying with the requirements with its National Pollutant Discharge Elimination System
(NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean
Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum
extent practicable.

This SWMP identifies the specific elements and minimum measures that the Town of Chapel Hill will
develop, implement, enforce, evaluate, and report to the North Carolina Department of Environmental
Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with the
MS4 Permit number NCS000414, as issued by NCDEQ. This permit covers activities associated with the
discharge of stormwater from the MS4 as owned and operated by the Town of Chapel Hill and located
within the corporate limits of the Town of Chapel Hill.

In preparing this SWMP, the Town of Chapel Hill has evaluated its MS4 and the permit requirements to
develop a SWMP that will meet the community’s needs, address local water quality issues, and provide
the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated
annually to ensure that the elements and minimum measures it contains continue to adequately provide
for permit compliance and the community’s needs.

The six minimum measures the Town is required to address are:
• Public Education and Outreach
• Public Participation and Involvement
• Illicit Discharge Detection and Elimination
• Construction Site Runoff Control
• Post-Construction Runoff Control
• Pollution Prevention and Good Housekeeping for Municipal Operations

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2 JURISDICTIONAL AREA
This SWMP and the MS4 permit applies throughout the corporate limits of the Town of Chapel Hill, and
includes all regulated activities associated with the discharge of stormwater from the MS4.

The current corporate area of the Town of Chapel Hill is 21.5 square miles; the Town’s total zoning
jurisdictional area, which includes the Town’s extraterritorial jurisdiction (ETJ), is 27.5 square miles. The
majority of the Town’s jurisdiction is within Orange County, with a small portion in Durham County.

The map below (Figure 1) shows the corporate and zoning (ETJ) jurisdictional limits of Town of Chapel Hill
as of November 2020. This information can also be viewed on the Town’s Interactive Map online.

Figure 1. Town of Chapel Hill Corporate (MS4) Limits and Zoning Limits as of November 2020.

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3 POPULATION AND ESTIMATED GROWTH RATE
3.1 POPULATION
There are 63,639 permanent residents within the Town of Chapel Hill’s municipal limits (including
University of North Carolina students), based on July 1, 2019 Certified Estimates with July 1, 2020
Municipal Boundaries (NCOSBM 2019). In addition, during the 2019-2020 school year, 8,183 students
lived on campus of University of North Carolina-Chapel Hill (UNC-CH) and are considered a seasonal
population. As of September 18, 2020, there were only 1,020 students assigned to live on UNC-CH campus
(UNC Housing Office – Carolina Together Dashboard). This change is due to UNC’s effort to de-densify
campus in response to the COVID-19 pandemic.
3.2 GROWTH RATE
The Town of Chapel Hill experienced a total growth rate of 4.8% between 1990 and 2010 (Town of Chapel
Hill 2010); the growth rate was 2.6% per year between 1990 and 2000, and 1.7% per year between 2000
and 2010 (NCOSBN 2016). Forty-two percent of the Town’s population growth between 2000 and 2009
was due to the annexation of urbanized areas (Town of Chapel Hill 2010).

Between 2010 and 2019, the population in Chapel Hill grew by 6,401; the total growth rate during this
time was 11.2%, with 5% of the total growth due to annexation (NCOSBM 2019). See Table 1 for the most
recent population and growth statistics.

Table 1. Town of Chapel Hill Population and Growth Statistics, April 1, 2010-July 1, 2019.
TOWN OF CHAPEL HILL POPULATION AND GROWTH STATISTICS
April 1, 2010-July 1, 2019
Base
Population Population Change
Estimated
Population
April 2010
Population
Annexed
Change in
Annexed Areas
Change in
2010 Limits
Total
Change
Percent
Change July 2019
57233 325 22 6054 6401 11.2 63639
Data Source: NC Office of State Budget and Management, State Demographer
https://www.osbm.nc.gov/demog/municipal-population-estimates
4 STORMWATER CONVEYANCE SYSTEM DESCRIPTION
The Chapel Hill storm sewer system is a combination of open channel and closed channel conveyances.
Stormwater is conveyed to receiving streams by a combination of overland flow, swales and open
channels, curbs, gutters, catch basins, pipes, culverts, ditches, outfalls, and bridges.

As of November 2020, the Town’s Geographic Information System (GIS) includes approximately 120 miles
of streams and open channels, 20 miles of culverts, and 5 miles of ditches within the Town’s corporate
limits. Within the Town’s zoning jurisdiction, there are approximately 155 miles of streams and open
channels, 21 miles of culverts, and 6 miles of ditches mapped.

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The major receiving streams to which stormwater discharges are conveyed from the Town’s MS4 include
Bolin Creek, Booker Creek, Little Creek, Morgan Creek, and their tributaries within the Cape Fear River
Basin (see Section 6 below). Based on a 2018 update, the Federal Emergency Management Agency
(FEMA)-mapped 1% annual chance floodplains cover approximately 2.3 square miles within the Town’s
zoning jurisdiction. University Place and Eastgate Shopping Center, as well as a number of residences and
other businesses, are within the FEMA-mapped floodplains.

Under average conditions, the Town’s stormwater management systems perform adequately in
containing and conveying stormwater runoff. Localized drainage problems periodically occur in some
locations under certain conditions due to inadequate or deteriorated conveyance facilities and poor
infiltrating soils. During large storm events, culverts and streams in the downstream segments of the
Town’s watersheds periodically flood because of high volumes of runoff in conjunction with low flow
velocity (gradient) in these areas of Town.

The Town’s Stormwater Master Plan (approved by Town Council in 2014) identified as a priority the
continued development of individual subwatershed studies to identify and assess flooding and water
quality issues and develop integrated plans for improvements to the Town’s stormwater conveyance
system. Those studies (and the resulting projects) are ongoing and described further in Section 9 below.

Maintenance and improvements to the MS4 system are funded by stormwater utility fees collected within
the Town corporate limits. The Town’s Stormwater Management Utility was enacted in 2004 and set an
equivalent rate unit fee for impervious surface area. Maintenance of the stormwater system located
within the Town’s rights-of-way and on Town-owned property is performed by seven full-time staff in the
Stormwater Management Division, and includes regular cleanouts of drainage inlets, removal of
blockages, and ongoing repair and upkeep of system components. Maintenance is performed in response
to functional problems using a combination of hand-tools and small power equipment, pressure-flushing,
and/or jet-vacuuming, as appropriate. Street sweeping is also a regular stormwater maintenance activity,
as is seasonal leaf collection. Improvements to the MS4 system include resolving flooding problems
associated with stormwater generated from public streets, stream channel stabilization, stream
restoration, structural Best Management Practices (BMP) installation, and other water quality projects.

The Town contracts with the North Carolina Department of Transportation (NCDOT) for biannual
inspections of some of the bridges/major culvert crossings on Town-maintained streets in Chapel Hill. In
2020, NCDOT was contracted to inspect 19 bridges/major culvert crossings. In addition, Town staff inspect
bridges and road crossings before and after significant storm events, and residents’ reports and
complaints play an important role in identifying stormwater problems.
5 ESTIMATED LAND USE
The estimated percentage of the Town of Chapel Hill’s zoning jurisdiction (including the Town’s municipal
limits and ETJ) that is under residential, commercial, industrial, and open space land use types is shown in
Table 2 below. The percentages for rights-of-way and institutional land uses are also shown. Land use
estimates are derived from 2012 land use data developed by the Chapel Hill Planning Department.

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Table 2: Land use types by percent area within the Town of Chapel Hill’s zoning jurisdiction.

Land Use Type
Estimated Area of
Town’s Jurisdiction
(2012)
Residential 64%
Commercial 4%
Industrial 1%
Open Space 10%
Institutional 16%
Rights-of-Way 5%
Data Source: Chapel Hill 2020 Land Use Plan Map (adopted 2012).

The Town is currently undergoing an update to the Chapel Hill 2020 Land Use Plan Map (adopted in 2012),
as part of a “Charting Our Future” project, which has two phases. The first phase refines the Future Land
Use Map (FLUM), which was originally developed as the Land Use Plan in Chapel Hill 2020, the Town's
Comprehensive Plan. The Town Council adopted the FLUM on December 9, 2020. In 2021, the Town will
proceed with the second phase of the project to rewrite the Town's Land Use Management Ordinance
(LUMO).
6 RECEIVING STREAMS
All receiving streams within the Town of Chapel Hill’s zoning jurisdiction are within the Cape Fear River
Basin and drain to the Morgan Creek and New Hope arms of Jordan Lake. Below is a list of receiving
streams, identified and arranged by stream segment (stream index number). For each stream segment,
the water quality classification, use support rating, and 303(d) list parameters of interest are noted
(NCDWR 2018). For more information on impaired waters and the 303(d) list, including parameters of
interest, see Section 7 below.

Table 3. Water quality classifications, use support ratings, and 303(d) list parameters of interest for receiving streams within the
Town of Chapel Hill's zoning jurisdiction (NCDWR 2018).
Receiving Stream
Name
Stream Index
Number
Water Quality
Classification*
Use Support
Rating*
303(d) List
Parameter of
Interest*
Little Creek 16-41-1-15-(0.5) WS-IV; NSW Impaired Benthos
Bolin Creek
(Hogan Lake)
16-41-1-15-1-
(0.5)b WS-V, C; NSW Impaired Benthos
Bolin Creek 16-41-1-15-1-(4) WS-IV; NSW Impaired Benthos
Jolly Branch 16-41-1-15-1-2 WS-V; NSW Not Rated n/a
Tanbark (Tanyard)
Branch 16-41-1-15-1-3 WS-V; NSW Not Rated n/a
Booker Creek
(Eastwood Lake) 16-41-1-15-2-(1) WS-V,
B; NSW Impaired Dissolved Oxygen
Booker Creek 16-41-1-15-2-(4) WS-V, C; NSW Impaired Benthos
Booker Creek 16-41-1-15-2-(5) WS-IV; NSW Impaired Benthos

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Receiving Stream
Name
Stream Index
Number
Water Quality
Classification*
Use Support
Rating*
303(d) List
Parameter of
Interest*
Crow Branch 16-41-1-15-2-2 B; NSW Not Rated n/a
Cedar Fork Creek 16-41-1-15-2-3 WS-V, B; NSW Not Rated n/a
UT at Wright Mobile
Homes
16-41-1-15-2-3-
1 WS-V, B; NSW Not Rated n/a
Old Field Creek 16-41-1-7 WS-V; NSW Not Rated n/a
Morgan Creek 16-41-2-(5.5)a WS-IV; NSW Supporting n/a
Morgan Creek 16-41-2-(5.5)b WS-IV; NSW Impaired Benthos
Fish Community
Wilson Creek 16-41-2-6 WS-IV; NSW Not Rated n/a
Fan Branch Creek 16-41-2-6-1 WS-IV; NSW Not Rated n/a
Meeting of the Waters 16-41-2-7 WS-IV; NSW Not Rated n/a
Chapel Creek 16-41-2-8 WS-IV; NSW Not Rated n/a
Buck Branch 16-41-2-9 WS-IV; NSW Not Rated n/a
Battle Branch Source to Bolin
Creek C; NSW Not Rated n/a
*Data Sources: https://deq.nc.gov/about/divisions/water-resources/planning/classification-standards
https://deq.nc.gov/about/divisions/water-resources/planning/modeling-assessment/water-quality-data-assessment
7 IMPAIRED STREAMS AND EXISTING PROGRAMS TO ADDRESS
The assessment of water quality in North Carolina is required under Sections 303(d) and 305(b) of the
Clean Water Act and is to be reported on every two years. This assessment is also known as the Integrated
Report (IR). Impaired waters are a subset of the assessments made where water quality samples for a
particular parameter of a waterbody exceed water quality standards and the assessment methodology
have determined that the waterbody is indeed impaired for the particular parameter. Impaired waters
are grouped into two categories:
• Category 4 assessments are those that do not need a TMDL (Total Maximum Daily Load). These
are not included in the 303(d) list.
• Category 5 assessments are those that require a TMDL or TMDL alternative. These Category 5
waters are assembled in a single document (the 303(d) list) and sent to the USEPA (United States
Environmental Protection Agency) on April 1st of every even-numbered year, per 40 CFR 130.7.
EPA must approve, disapprove, or partially approve each 303(d) list.

Table 3 (above) lists all receiving streams within the Town’s zoning jurisdiction, including information on
streams listed as impaired in the final overall Integrated Report approved by the USEPA (NCDWR 2018).

Of the seven receiving stream segments considered to be impaired, six are impaired for biological
integrity. Biological integrity means the ability of an aquatic ecosystem to support and maintain a balanced
and indigenous community of organisms having species composition, diversity, population densities and
functional organization similar to that of reference conditions (15A NCAC 02B .0202). NCDWR uses a
biological rating method to assess benthic and fish communities for biological integrity.

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Booker Creek (Eastwood Lake) is impaired due to low dissolved oxygen (DO). The DO criterion for non-
trout waters is not less than 4.0 mg/l with a daily average of not less than 5.0 mg/l.

Note that though stream segments within the Town’s zoning jurisdiction are designated as impaired
(Category 5), there are currently no TMDL requirements (see Section 8 below).

Chapel Hill addresses impaired waters by implementing the Town’s existing local and state water quality
programs (see Sections 9 & 11 below), interlocal partnerships (Section 10 below), and through activities
associated with the best management practices (BMPs) required in the Town’s MS4 program (see Sections
13-18 below).

The Town also conducts its own annual biological monitoring at several sites located along impaired
stream segments and other receiving waters listed in Table 3. Since 2011, the Town of Chapel Hill has
contracted biological monitoring services with professional benthic macroinvertebrate scientists to
conduct annual water quality monitoring at sites throughout the Town’s jurisdiction. These scientists
include Dave Lenat and Larry Eaton, both of whom previously worked for the NCDWR Biological
Assessment Unit. Town stormwater staff participate in the annual monitoring field work and reporting
and use the results to better understand water quality issues and trends over time within the Town’s
watersheds. All annual reports are provided on the Town’s biological monitoring webpage. As of
monitoring year 2020, the Town is actively monitoring 28 benthic sites annually throughout the Town’s
zoning jurisdiction.
8 TOTAL MAXIMUM DAILY LOADS (TMDLS)
There are no current Total Maximum Daily Load (TMDL) requirements to address water quality
impairments within the Town’s jurisdiction as of the date of this document. However, all of Chapel Hill,
including the Town’s municipal corporate limits and extraterritorial jurisdiction (ETJ), are tributary to the
Upper New Hope Arm of the Jordan Lake (which includes the New Hope Creek and Morgan Creek
tributaries to Jordan Lake).

The North Carolina Division of Water Quality (DWQ, now Division of Water Resources) developed a TMDL
for the B. Everett Jordan Reservoir (Jordan Lake) to address chlorophyll-a impairments, and the EPA
Region 4 approved the TMDL on September 20, 2007. Nutrient controls are the most common focus of
management schemes for reducing excessive algal growth and chlorophyll-a concentrations. Therefore,
the Jordan Lake TMDL was written to address total nitrogen (TN) and total phosphorus (TP) loads to the
lake. North Carolina adopted mandatory Jordan Lake Rules in 2009 to reduce the amount of nutrient
pollution entering Jordan Lake. Implementation of the nutrient reduction regulations has been delayed
by the State Legislature. However, the Town has been complying annually with the Jordan Lake Stage
One Adaptive Management Program for Existing Development Requirements. The Town identifies a
retrofit opportunity for an existing development within the MS4 each year and submits an annual report
to NCDWR.

Two addendums to the Jordan Lake TMDL were later developed and approved: one in 2010 to address
chlorophyll-a impairments in the Haw River (Back Creek and Cane Creek) and Upper New Hope (Morgan
Creek (University Lake) arms; and another in 2014 to address turbidity impairments within the Upper New

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Hope arm (New Hope and Morgan Creek tributaries), and high pH impairments in the Haw River and Upper
New Hope (Morgan Creek) arms of the lake.

For more information on draft and approved TMDLs within the Cape Fear River Basin, see
https://deq.nc.gov/about/divisions/water-resources/planning/modeling-assessment/tmdls/draft-and-
approved-tmdls#CapeFear.
9 EXISTING WATER QUALITY PROGRAMS
The Town of Chapel Hill implements ordinances, plans, and programs to improve water quality at the local
level, some of which implement state water quality programs. Below are brief descriptions of these
programs, with those that are state programs noted (see also Section 10).
9.1 TOWN LAND USE, DEVELOPMENT, AND STORMWATER STANDARDS AND PLANS
9.1.1 Chapel Hill 2020 Comprehensive Plan
The Town of Chapel Hill adopted the Chapel Hill 2020 Comprehensive Plan on June 25, 2012. The
Chapel Hill 2020 Plan promotes protecting the Town’s natural resources, including stream
corridors, steep slopes, tree canopies, habitat areas, and air and water quality. The 2020 Plan
includes a significant section (Theme 5: Nurturing Our Community) on the protection of natural
resources, particularly calling out protection and improvement of streams and waterbodies, and
management of stormwater. During development of the 2020 Plan, the Town Council endorsed
the initiation of a process for Town staff to review and update the Land Use Management
Ordinance (LUMO), design guidelines, and stormwater regulations (see below for summaries that
include these efforts).

The Town has recently completed an update to the Chapel Hill 2020 Land Use Plan Map (adopted
in 2012), as part of a “Charting Our Future” project, which has two phases. The first phase refines
the Future Land Use Map (FLUM), which was originally developed as the Land Use Plan in Chapel
Hill 2020, the Town's Comprehensive Plan. On December 9, 2020, the Town Council adopted the
Future Land Use Map – Update to Chapel Hill 2020. The second phase of the project will rewrite
the LUMO. For more information, see visit the Charting Our Future website:
https://chartingourfuture.info.
9.1.2 Town of Chapel Hill Public Works Engineering Design Manual
The Town of Chapel Hill Engineering Design Manual provides standards for land development that
are intended to complement and supplement the general Design Guidelines included in the
Town’s 2020 Comprehensive Plan. Specific design criteria set forth within the Design Manual
provide a ready reference of those practices and techniques acceptable to the Town and provides
information on the design and acceptable means and measures to comply with the requirements
of the Town’s Land Use Management Ordinance (LUMO). For example, the Design Manual
provides performance criteria, design standards and details, and guidelines for submission of
stormwater management plans and reports for development and refers specifically to the North
Carolina Stormwater Design Manual. The Town’s Design Manual has been updated, and the draft
is anticipated to be approved by Town Council in 2021.

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9.1.3 Stormwater Management Master Plan
The Town of Chapel Hill Stormwater Management Master Plan (Phase I and Phase II) was
developed over a multi-year planning process that established the following key strategic
measures:

• Improve physical, chemical, and biological stream conditions;
• Reduce export of nutrients to Jordan Lake;
• Fewer violations of environmental regulations related to water sources;
• Reduced flooding risk for roads and structures;
• Reduced reactive maintenance activities and repairs;
• More residents, businesses, and staff adopting positive stormwater practices; and
• Benchmarking against best practices among municipal stormwater programs.

Phase I was completed in October 2008, and Phase II was adopted by the Town Council on
September 29, 2014.
9.1.4 Booker Creek Subwatershed Studies
As noted in the Town’s Stormwater Master Plan adopted in September 2014, the development of
subwatershed plans is a strategic initiative as part of the following goals of the Town’s Stormwater
Management Program:
• Address stormwater quantity (flooding) as an integral component within the program;
• Address stormwater quality as an integral function within the program; and
• Protect and restore natural stream corridors.

In 2009, the Town began a pilot subwatershed study, the Booker Creek Headwaters Subwatershed
Study, to assess stream conditions and identify potential stormwater project sites; this study was
included in the Town’s Stormwater Master Plan – Phase II (Jewell Engineering Consultants, PC,
2014).

The Booker Creek Watershed is approximately 6.3 square miles and includes five subwatersheds.
In 2015, the Town contracted with W.K. Dickson to complete individual studies of the four
remaining subwatersheds within the Booker Creek basin: Lower Booker Creek, Eastwood Lake,
Crow Branch, and Cedar Fork.

Systematic mapping of stormwater infrastructure is a large part of each subwatershed study. The
results of these subwatershed studies are used to prioritize projects that will help control existing
flooding, stabilize streams, and improve overall water quality in the Town’s watersheds.
Completion of the studies within the Booker Creek watershed has been a multi-year planning
process. For more information, see http://bookercreekplan.org/.
9.2 TOWN CODE OF ORDINANCES
9.2.1 Flood Damage Prevention Ordinance
The Town of Chapel Hill’s Flood Damage Prevention Ordinance (Chapter 5, Article IV)

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• restricts or prohibits uses that are dangerous to health, safety, and property due to water
or erosion hazards or that result in damaging increases in erosion, flood heights or
velocities;
• requires that uses vulnerable to floods, including facilities that serve such uses, be
protected against flood damage at the time of initial construction;
• controls the alteration of natural floodplains, stream channels, and natural protective
barriers, which are involved in the accommodation of floodwaters;
• controls filling, grading, dredging, and all other development that may increase erosion
or flood damage; and
• prevents or regulates the construction of flood barriers that will unnaturally
divert floodwaters or which may increase flood hazards to other lands.

This ordinance meets or exceeds the minimum National Flood Insurance Program (NFIP)
standards and authorizes the Town to implement the federal and state requirements at the local
level.
9.2.2 Erosion and Sediment Control
The Town’s Soil Erosion and Sedimentation Control Ordinance (Chapter 5, Article V), was originally
adopted in 1986 to address soil erosion and sedimentation control and prevent degradation of
area waterways, and was last updated in 2001. This ordinance and its enforcement contribute to
meeting the Town's National Pollutant Discharge Elimination System (NPDES) minimum
requirements for Construction Site Stormwater Runoff Control, and it meets or exceeds state
erosion control requirements.

For land development projects disturbing at least 20,000 square feet of land, an erosion and
sediment control permit is required. Single family development projects that that do not have to
install stormwater control measures on site or apply for erosion control permits but exceed 1,500
square feet of land disturbance are still reviewed and approved by the Town of Chapel Hill to
ensure that no sediment is being transported from the site or that drainage improvements have
no adverse impact on neighboring properties.

The Town’s erosion control program is administered by the Orange County Erosion Control
Division and enforced by Orange County. Both the Town and the County are local delegated
authorities to implement and enforce state erosion and sediment control requirements and have
had an inter-local agreement in place since 1986. The Town and County are currently reviewing
the 1986 agreement to consider updates that would more clearly define the services that will be
provided for MS4 compliance, a requirement to notify the Town if the county’s delegated program
is put on probation by NC Division of Energy, Mineral, Land Resources (NCDEMLR), and provide a
provision that reimbursement of any resulting legal defense and/or penalties may be required for
failure to implement the agreed upon program components.
9.2.3 Illicit Discharge Detection and Elimination (IDDE)
The Town of Chapel Hill adopted an IDDE Ordinance on November 14, 2016, as a new Article V of
Chapter 23 (Water, Sewers and Drainage) of the Town’s Code of Ordinances. The purpose of the
ordinance is to:
• regulate the contribution of pollutants to the stormwater drainage system,

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• prohibit illicit discharges and connections to the stormwater drainage system,
• prevent improper disposal of materials that degrade water quality, and
• establish legal authority to carry out all inspection, detection, monitoring procedures and
enforcement necessary to ensure compliance with the ordinance.

The IDDE Ordinance also provides criteria for assessing civil penalties. Prior to the adoption of
the IDDE Ordinance, the Town’s authority for IDDE enforcement and penalties was limited to
Sections 8-34 and 8-44 of the Code of Ordinances.
9.2.4 Land Use Management Ordinance (LUMO)
Development regulations and standards are documented in the Chapel Hill LUMO (Appendix A of
the Town’s Code of Ordinances). The LUMO was adopted in 2003 as a companion document to
the 2000 Comprehensive Plan. In 2015, a series of text amendment updates were proposed as a
result of the completion of the 2020 Comprehensive Plan, including a text amendment that
increased clarity in the regulations to improve enforcement and water quality protection. In June
2019, a text amendment was approved for Section 3.11 of the LUMO (Blue Hill District) to address
Session Law 2018-145, which affected local government authority over stormwater treatment
requirements for redevelopment projects.

The following summaries provide an overview of the relevant LUMO sections with respect to
water quality and the Town’s NPDES MS4 permit.
9.2.4.1 Resource Conservation District (RCD)
LUMO Section 3.6.3 establishes a Resource Conservation District (RCD) overlay zoning
designation that requires stream buffers along all perennial streams, intermittent
streams, and perennial waterbodies within the Town’s planning jurisdiction. The
purpose of the RCD is to:
• preserve the water quality of the Town's actual or potential water supply sources;
• minimize danger to lives and properties from flooding in and near the
watercourses to preserve the water-carrying capacity of the watercourses, and
to protect them from erosion and sedimentation;
• retain open spaces and greenways and to protect their environmentally-sensitive
character;
• preserve urban wildlife and plant life habitats from the intrusions of urbanization;
• provide air and noise buffers to ameliorate the effects of development; and
• preserve and maintain the aesthetic qualities and appearance of the Town.

The RCD Ordinance was incorporated into the LUMO in 2003 but was originally
established in 1984.

Streams subject to the RCD rules include those shown on the Town's Geographic
Information System (GIS) coverage, the most recent version of the U.S. Geological
Survey 1:24,000 scale (7.5 minute) topographic map, or the soils map in the U.S.
Department of Agriculture Orange County Soil Survey. All streams subject to the RCD
are field classified by Town staff using NC Division of Water Resources (NCDWR)
methodology, and RCD buffers are measured from the top of bank and must be

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surveyed. Buffers required on perennial waterbodies are measured from the mean
high-water mark.
9.2.4.2 Water Supply Watershed Protection Program
The North Carolina Water Supply Watershed Protection Rules adopted in 1992 required
that all local governments having land use jurisdiction within water supply watersheds
adopt and implement water supply watershed protection ordinances, maps, and
management plans. As a result, the Town of Chapel Hill established a Watershed
Protection District overlay zoning designation intended to be applied to a portion of the
New Hope Watershed draining to Jordan Lake in order to ensure long-term water quality
of the Jordan Lake Reservoir, to protect possible future sources of drinking water for the
Town and surrounding localities, and to control pollution sources affecting water
quality.

LUMO Section 3.6.4 establishes the Watershed Protection District, and includes
requirements for high density development, restrictions on use of toxic materials,
construction standards, and other performance standards. In 2015, a text amendment
was made to the Watershed Protection District to reflect changes that resulted from
adoption of the 2020 Comprehensive Plan update. Specifically related to water quality,
the changes in the 2015 text amendment were designed to (1) align local Watershed
Protection District regulations to match State requirements and exemptions, (2) remove
redundant stream buffer text, (3) clarify development options, (4) modify the
dimensional matrix to reflect Town-wide standards based on 2013 Council action, and
(5) make the steep slopes ordinance easier to read and use.

The area of the Watershed Protection District extends five miles from the normal pool
elevation of Jordan Lake Reservoir or the ridgeline of the watershed, whichever is less
(see Figure 2 below).

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Figure 2. Map of Jordan Lake Watershed Protection District (blue shading)
within the Town of Chapel Hill's zoning jurisdiction (green outline).

9.2.4.3 Jordan Watershed Riparian Buffer Protection Ordinance
In 2010, the Town incorporated the minimum requirements of the Jordan Nutrient
Strategy Rule (15A NCAC 02B.0267, as amended by Session Law 2009-484) for riparian
buffer protection into a Jordan Watershed Riparian Buffer Protection Ordinance,
adopted as LUMO Section 5.18. The riparian buffer is 50 feet wide directly adjacent to
intermittent streams, perennial streams, and perennial waterbodies, excluding
wetlands. This ordinance applies to uses or activities conducted within or outside of the
riparian buffer with hydrological impacts in violation of the diffuse flow requirements
set out in subsection 5.18.6(c).

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Streams subject to this ordinance are those shown on the most recent hard copy
paperbound version of the soil survey map prepared by the Natural Resources
Conservation Service of the United States Department of Agriculture, or the most recent
version of the 1:24,000 scale (seven and one-half (7.5) minutes) quadrangle topographic
maps prepared by the United States Geologic Survey (USGS). Town staff field verify all
stream classifications for streams subject to Jordan Watershed Riparian Buffers using
NCDWR methodology.
9.2.4.4 Steep Slopes
LUMO Section 5.3, Critical Areas and Environmental Performance Standards, cross
references the Town’s Erosion and Sediment Control Ordinance and establishes
limitations on the development of steep slope areas. The purpose of this section is to
minimize the grading and site disturbance of steep slopes by restricting land disturbance
on steep slopes and by requiring special construction techniques for development on
steep slopes. These provisions are intended to protect water bodies (streams and lakes)
and wetlands from the effects of erosion on water quality and water body integrity,
protect the plant and animal habitat of steep slopes from the effects of land
disturbance, and preserve the natural beauty and economic value of the town's wooded
hillsides.

A "steep slope" in Section 5.3 is defined as a slope that is equal to or steeper than fifteen
(15) percent and includes those areas of size four hundred (400) square feet or greater.
There are separate requirements for slopes 15% or greater and those 25% or greater.
9.2.4.5 Stormwater Management
LUMO Section 5.4 specifies stormwater management requirements for all development
projects that propose more than 20,000 square feet of land disturbance. The section
includes peak flow rate, volume, and water quality requirements for specified design
storms or precipitation depths. The water quality requirement states that “stormwater
treatment shall be designed to achieve average annual eighty-five (85) per cent total
suspended solids (TSS) removal and must apply to the volume of post-development
runoff resulting from the first one-inch of precipitation.”

A text amendment to the LUMO was approved on October 24, 2012, adding Section
5.19 - Jordan Watershed Stormwater Management for New Development, as required
by the NC General Assembly. The effective date was December 1, 2012. Development
of this new development rule was required to be completed and submitted to the NC
Environmental Management Commission by September 10, 2011. However, the NC
General Assembly then delayed this rule with Session Law 2012-200, and local
governments were barred from implementing this new development stormwater rule.

In addition, LUMO Section 3.11 was adopted on May 12, 2014, and established a specific
Blue Hill District (formerly the Ephesus-Fordham Form District) that included minimum
stormwater management standards specific to this district only for all new development
and redevelopment - new development or redevelopment in the Blue Hill District
received exemptions from Resource Conservation District (RCD), steep slope, and other
regulations, in exchange for treating at least 50% of existing impervious areas.

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In December 2018, the NC General Assembly restricted the ability of local governments
to require new or increased stormwater management controls for (i) preexisting
development or (ii) redevelopment activities that do not remove or decrease existing
stormwater controls (Session Law 2018-145). When a preexisting development is
redeveloped, either in whole or in part, increased stormwater controls shall only be
required for the amount of impervious surface being created that exceeds the amount
of impervious surface that existed before the redevelopment. This session law required
all local governments to adopt this change and update their stormwater ordinances,
regardless of the source of their regulatory authority.

As a result, the Town updated Section 3.11 on June 26, 2019, to provide two stormwater
management options in the Blue Hill District: conventional or enhanced
development. Under the conventional option, streams are subject to Resource
Conservation District (RCD) regulations and other LUMO regulations previously
exempted in this district, and only the net increase in impervious surface requires
stormwater management treatment. Under the enhanced stormwater option, the RCD,
steep slopes, and other previously exempt regulations in this district remain exempt,
and in exchange there is a requirement to treat 50% of total post-construction
impervious surfaces. Since the change in 2019, most development has chosen to
proceed voluntarily with the enhanced development option.
9.2.4.6 Tree Protection
LUMO Section 5.7 regulates the protection, installation, removal, and long-term
management of trees, shrubs, and soils within the Town’s jurisdiction. The following
tree canopy coverage standards are required for applications proposing tree removal
that require council approval, including special use permits, major special use permit
modifications, and conditional zoning district rezonings.

Table 4. Minimum tree canopy coverage standards by land use type.

Land Use Type
Minimum Canopy
Coverage
Multi-Family Residential 30%
Commercial (Use Group C and Business, Office;
Clinic; Funeral Home; and Hotel/Motel)
30%
Institutional (Use Group B) 40%
Mixed Use, Other 40%
All Uses in Innovative, Light Industrial
Conditional Zoning District (LI-CZD)
20%
10 PARTNERSHIPS AND INTER-LOCAL AGREEMENTS
The Town works on a local and regional basis in cooperation with other local government agencies, state
and federal agencies, the University of North Carolina (UNC), and other organizations on a wide variety of

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water resources-related issues. The Town will continue to work together with these partners to meet the
challenges and regulations facing all of us within the Upper Cape Fear River watershed.
10.1 ORANGE COUNTY EROSION CONTROL
Through an inter-local agreement, Orange County’s Erosion Control Division administers, implements, and
enforces the Erosion and Sediment Control (E&SC) program for Chapel Hill, as well as other municipalities
within the county (Carrboro, Hillsborough). The Orange County Sediment and Erosion Control Program
effectively meets the maximum extent practicable (MEP) standard for Construction Site Runoff Controls
by permitting and controlling development activities disturbing one or more acres of land surface and
those activities less than one acre that are part of a larger common plan of development. Town and
Orange County staff work together regularly on enforcement of the Town’s erosion control requirements.
10.2 TOWN OF CARRBORO
The Town of Chapel Hill’s Stormwater Management staff coordinate with the Town of Carrboro’s
Stormwater program and staff regularly on projects of mutual interest. These projects include public
education and outreach, volunteer stream cleanup events, annual biological monitoring in the Bolin Creek
and Morgan Creek watersheds, stream restoration efforts in the Bolin Creek watershed, and stream
determinations for properties located in the vicinity of both jurisdictions. As of 2020, Chapel Hill is now
monitoring two long-term (reference) monitoring sites located in Carrboro (Morgan Creek at NC54 and
Bolin Creek at Waterside Drive). Town of Chapel Hill and Carrboro stormwater staff also work closely on
IDDE efforts across jurisdictions. In addition, the Town of Chapel Hill and Town of Carrboro have an inter-
local agreement to fund annual maintenance of a United States Geologic Survey (USGS) stream gage on
Bolin Creek at Village Drive.
10.3 UNIVERSITY OF NORTH CAROLINA AT CHAPEL HILL (UNC)
The Town of Chapel Hill’s Stormwater Management staff communicate regularly with UNC Stormwater
Management and UNC Energy Services staff to discuss items of mutual interest, coordinate public
education and IDDE efforts, and co-review UNC development plans. A member of the UNC staff serves
on the Town’s Stormwater Management Utility Advisory Board, and Town staff are involved in educational
and student research projects have been developed in collaboration with UNC’s Institute for the
Environment, and courses taught through the UNC Department of City and Regional Planning. Town
Stormwater staff also serve as collaborators on stormwater and water quality grants obtained by UNC and
other academic partners.
10.4 ORANGE WATER AND SEWER AUTHORITY (OWASA)
The Town of Chapel Hill’s Stormwater Management staff meet with OWASA engineering staff regularly
regarding development projects via the Town’s Technical Review Team meetings and regarding Capital
Improvement Projects. The Town’s staff also coordinate with OWASA Operations and Maintenance staff,
UNC Stormwater Management staff, and Town of Carrboro stormwater staff on water quality and illicit
discharge issues in our shared jurisdictions.

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10.5 NORTH CAROLINA DEPARTMENT OF TRANSPORTATION (NCDOT)
The Town of Chapel Hill’s Stormwater Management staff regularly interacts with NCDOT staff on review
of development projects via the Town’s Technical Review Team, long-range transportation planning, and
coordinate specifically with NCDOT District staff regarding operation and maintenance of stormwater
infrastructure (i.e., culvert blockages, drainage problems) within NCDOT’s rights-of-ways. The Town also
contracts with NCDOT for biannual inspections of some of the bridges/major culvert crossings on Town-
maintained streets in Chapel Hill.
10.6 NORTH CAROLINA WATERSHED STEWARDSHIP NETWORK (NCWSN)
The Town of Chapel Hill is a local government partner in the NC Watershed Stewardship Network
(NCWSN), a cooperative partnership of watershed stakeholders across North Carolina connected by our
shared work to increase communication and collaboration for healthy streams and clean water.
10.7 CLEAN WATER EDUCATION PARTNERSHIP (CWEP)
For more than a decade, the Town of Chapel Hill has been an active local government partner in the Clean
Water Education Partnership (CWEP), a cooperative effort between local governments, state agencies,
and nonprofit organizations to protect water quality in the Tar-Pamlico, Neuse, and Cape Fear River
Basins. Led by the Triangle J Council of Governments (TJCOG), CWEP helps the Town and other local
governments develop educational and outreach materials to cooperatively achieve more than they could
individually and conducts mass media stormwater outreach on behalf of local governments subject to
state and federal stormwater outreach requirements. The objective is to improve the public's
understanding of where stormwater pollution comes from, its impact on water quality, and what people
can do to reduce the problem. The Town is currently working on and intends to enter into a Memorandum
of Agreement with CWEP in Fiscal Year 2021 (FY21) that specifically outlines the role that CWEP plays in
helping meet the Town’s MS4 requirements for Public Education and Outreach and Public Involvement
and Participation.
10.8 NUTRIENT SCIENTIFIC ADVISORY BOARD (NSAB)
A member of the Town of Chapel Hill’s stormwater staff has actively participated in the Nutrient Scientific
Advisory Board (NSAB) as a local government board representative since the board’s formation in 2010.
As required by Session Law 2009-216, the NSAB comprises six local government representatives, a
professional or academic representative, a professional engineer, an NCDOT representative, and a
conservation organization representative. Session Law 2009-216, in addition to setting requirements for
stormwater from existing development in the Jordan Lake Watershed, required the formation of the NSAB
to improve on the tools needed to address nutrient loading from existing development in any watershed,
statewide, where nutrients are of concern.

The primary role of the NSAB is to provide advice and recommendations to the NC Division of Water
Resources (NCDWR) and local governments on ways to effectively meet existing development
requirements of nutrient strategies in general, and to meet the Jordan Stage 2 requirements specifically.
The NSAB is tasked to develop methods for estimating jurisdiction-scale loadings; project-scale load
reductions; load-reducing strategies; feasibility, costs, benefits, and credit-accounting of the identified
management strategies; and identify the need to refine water quality modeling and other analytical tools
used to evaluate water quality.

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10.9 JORDAN LAKE ONE WATER (JLOW)
The Town has been an active participant in the Jordan Lake One Water initiative, coordinated by the
Triangle J Council of Governments (TJCOG), since its inception. Town Stormwater staff have served on
the Integrated Watershed Management workgroup, and the Town’s Mayor is a member of the Jordan
Lake One Water Local Elected Officials Group.

The JLOW is comprised of local governments, conservation groups, universities, water utilities,
agriculture, and state agencies, with efforts underway to incorporate private industry stakeholders.
Supported by diverse stakeholders throughout the watershed, JLOW seeks to develop and implement an
integrated watershed management “One Water” framework for the Jordan Lake watershed by facilitating
collaboration among the many interested parties, and providing an avenue whereby policy, operational,
and financial recommendations can be developed. JLOW has developed a Work Plan to guide and explain
this effort, which seeks to include all those interested in realizing watershed-wide social, economic, and
environmental benefits, while sharing the costs of water quality and quantity improvements.

The purpose of the JLOW management framework is intended to be sufficiently broad in scope to cover
most if not all water-related management collaborative opportunities. One of the key areas it will address
is the upcoming Jordan Lake Watershed nutrient rules re-adoption. The nutrient rules re-adoption process
required by the NC Department of Environmental Quality (DEQ) began in January 2020, upon receipt of
the UNC Nutrient Management Study from the NC Policy Collaboratory.
10.10 ORANGE COUNTY HAZARD MITIGATION PLAN
Pursuant to the Federal Disaster Mitigation Act of 2000 and North Carolina Senate Bill 300, which was
passed in 2001, Orange County prepared and adopted a multi-jurisdictional Hazard Mitigation Plan with
the Town of Carrboro and Town of Hillsborough. In accordance with federal regulations which requires
plans to be updated every five years, an updated plan was later adopted by the participating jurisdictions.
The Orange County Hazard Mitigation Plan Update received final Federal Emergency Management Agency
(FEMA) approval July 14, 2010.

The Town assisted in creating the Eno-Haw Regional Hazard Mitigation Plan. The jurisdictions of Carrboro,
Elon, Graham, Haw River, Hillsborough, Mebane, Roxboro, Alamance County, Orange County, and Person
County coordinated the plan effective September 22, 2020 to September 21, 2025. This entailed an
update to the 2015 Eno-Haw Regional Mitigation Plan. The plan includes the top prioritized projects from
the Lower Booker Creek Subwatershed Study.
11 STATE PROGRAMS
As described in Section 9 (Existing Water Quality Programs) above, the Town of Chapel Hill is a delegated
local government authority for stormwater, water supply watershed, and Jordan Lake riparian buffer rules
required by the State.
In addition, the Town of Chapel Hill maintains an inter-local agreement for enforcement of the Town’s
Erosion and Sediment Control Ordinance with Orange County, which is a delegated local authority for
enforcement of state erosion and sediment control rules (see Section 10, Partnerships and Local
Agreements, and Section 12, Reliance on Other Government Entity).

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12 RELIANCE ON OTHER GOVERNMENT ENTITY
The Town of Chapel Hill has a legal agreement with Orange County for implementation and enforcement
of the Town’s Soil Erosion and Sedimentation Control regulations to meet the MS4 requirements for the
minimum measure of Construction Site Stormwater Runoff Control. See Section 10.1 above for more
information. See Section 12 below for contact information for Orange County Erosion Control staff.
12 POINTS OF CONTACT & ORGANIZATIONAL CHARTS
The Primary Points of Contact for each minimum measure of the Town of Chapel Hill’s NPDES MS4 Permit
are shown in Table 5 below. An overview of the Town of Chapel Hill’s organization is shown in Figure 3,
and the organizational chart for the Public Works Department is shown in Figure 4. The Town positions
and staff currently responsible for each specific Stormwater Management Plan (SWMP) component are
shown in Table 6. The Town Manager is ultimately responsible for the administration, implementation,
and enforcement of the Town’s MS4 permit.

Table 5. Primary points of contact for the Town of Chapel Hill's MS4 Permit.
MINIMUM MEASURE PRIMARY POINT OF CONTACT
Program Implementation
Chris Roberts, Manager of Engineering & Infrastructure
Town of Chapel Hill Public Works
[e-mail]
[phone]
Public Education and Outreach Sammy Bauer, Community Education Coordinator
Town of Chapel Hill Stormwater Management Division
[e-mail]
[phone]
Public Involvement
and Participation
Illicit Discharge Detection
and Elimination
Allison (Schwarz) Weakley, Stormwater Analyst
Town of Chapel Hill Stormwater Management Division
[e-mail]
[phone]
Post-Construction Stormwater Management
Alisha Goldstein, Engineer III
Town of Chapel Hill Stormwater Management Division
[e-mail]
[phone]
Construction Site Stormwater Runoff Control
Patrick R. Mallett, Erosion Control & Stormwater Supervisor
Orange County Planning and Inspections
[e-mail]
[phone]
Pollution Prevention/Good Housekeeping for
Municipal Operations
Ernest Odei-Larbi, Senior Engineer
Town of Chapel Hill Stormwater Management Division
[e-mail]
[phone]

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Figure 3. Town of Chapel Hill Organizational Chart Overview.

Citizens of
Chapel Hill
Mayor and
Town Council
Town Manager
Deputy Town Manager
Assistant Town Manager
Town Attorney
Departments
Business Management
Communications and Public Affairs
Fire
Housing and Community
Human Resource Development
Library
Parks and Recreation
Planning
Police
Public Works
Technology Solutions
Transit
Boards and Commissions
Board of Adjustment
Chapel Hill Downtown Partnership
Chapel Hill Library Advisory Commission
Community Design Commission
Community Policing Advisory Committee
Cultural Arts Commission
Environmental Stewardship Advisory Board
Grievance Hearing Board
Historic District Commission
Housing Advisory Board
Human Services Advisory Board
Justice in Action Committee
Orange Water and Sewer Authority Board of Directors
Parks, Greenways, and Recreation Commission
Planning Commission
Stormwater Management Utility Advisory Board
Transportation and Connectivity Advisory Board
TOWN OF CHAPEL HILL ORGANIZATION CHART

Figure 4. Organizational chart for the Town of Chapel Hill Public Works Department (December 2020).

Table 6. Responsible positions and staff per SWMP component.
SWMP Component Responsible Position(s) Staff Name(s) Department
Stormwater Program
Administration

Manager of Engineering & Infrastructure

Chris Roberts Public Works Department
SWMP Management Stormwater Analyst Allison Weakley Public Works - Stormwater
Management Division
Public Education &
Outreach Community Education Coordinator
Stormwater Analyst
Stormwater Specialist
Senior Engineer
Samantha Bauer
Allison Weakley
Jason Salat
Sue Burke
Public Works – Stormwater
Management Division
Public Involvement &
Participation
Illicit Discharge Detection
& Elimination
Stormwater Analyst
Stormwater Specialist
Allison Weakley
Jason Salat
Public Works – Stormwater
Management Division
Construction Site Runoff
Control
Orange County Erosion Control &
Stormwater Supervisor Patrick R. Mallett Orange County Planning &
Inspections Department
Post-Construction
Stormwater Management
Senior Engineer
Engineer III
Engineer III
Ernest Odei-Larbi
Mary Beth Meumann
Alisha Goldstein
Public Works – Stormwater
Management Division
Pollution Prevention/Good
Housekeeping for
Municipal Operations
Senior Engineer
Community Education Coordinator
Stormwater Specialist
Ernest Odei-Larbi
Samantha Bauer
Jason Salat
Public Works – Stormwater
Management Division
Municipal Facilities
Operation & Maintenance
Program

Facilities Manager

Mack Howell Public Works – Facilities
Management
Spill Response Program Manager of Engineering & Infrastructure
Assistant Chief Administration
Chris Roberts
Stacy Graves
Public Works Department
Fire Department
MS4 Operation &
Maintenance Program
Senior Engineer
Drainage Maintenance Supervisor
Sue Burke
Robert Sykes
Public Works – Stormwater
Management Division
Municipal Stormwater
Control Measure (SCM)
Operation & Maintenance
Program
Senior Engineer
Engineer III
Engineer III
Ernest Odei-Larbi
Mary Beth Meumann
Alisha Goldstein
Public Works – Stormwater
Management Division
Pesticide, Herbicide &
Fertilizer Management
Program
Park Maintenance Superintendent
Park Maintenance Supervisor
Kevin Robinson
Tanner Thompson
Parks & Recreation
Department
Vehicle Equipment
Maintenance & Cleaning
Program
Assistant Chief Administration Stacy Graves
Fire Department
(Fleet and Transit under
industrial NPDES permit
outside municipal limits)
Pavement Management
Program
Streets & Construction Services
Superintendent
Streets Supervisor
Drainage Maintenance Supervisor
Mike Wright

Greg Ling
Robert Sykes

Public Works Department

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SWMP Component Responsible Position(s) Staff Name(s) Department
Total Maximum Daily Load
(TMDL) Requirements

Manager of Engineering & Infrastructure

Chris Roberts

Public Works Department
13 PUBLIC EDUCATION AND OUTREACH PROGRAM
The Town of Chapel Hill has an active public education and outreach program that distributes educational
materials to the community and conducts outreach activities about the impacts of stormwater discharges
on water bodies and the steps that the public can take to reduce pollutants in storm water runoff. Below
is a description of pollutant sources the Town has identified as targets for our outreach efforts, a summary
of target audiences for education and outreach, mechanisms used to reach those audiences, and a table
showing the Best Management Practices (BMPs) the Town is implementing to meet the Public Education
and Outreach Program component of our MS4 permit. BMPs such as the informational web site, public
education materials, volunteer programs, etc., are all coordinated under an integrated public education,
outreach, and involvement program.
13.1 TARGET POLLUTANTS AND AUDIENCES
The target audiences for the public education program are listed below with an explanation as to why
they are being targeted for educational outreach.

Table 7. Summary of target pollutants and sources, target audiences, and program(s) to address target pollutants.
Target Pollutant(s) Likely Source(s)/Target
Audience(s)
SWMP Program(s) Addressing
Target Pollutant(s)/Audience(s)
Sediment Construction/Contractors,
Residents, Public School
Students, Municipal Employees
Construction Site Runoff, Illicit
Discharge Detection and Elimination
(IDDE), Good Housekeeping
Oil & Grease Residents, Businesses
(Restaurants, Auto Repair & Gas
Stations), Municipal Employees
Public Education & Outreach, IDDE,
Good Housekeeping
Litter Residents, Public School
Students, Businesses, Municipal
Employees
Public Education & Outreach, Public
Involvement & Participation, IDDE,
Good Housekeeping
Yard Waste Residents, Businesses
(Landscaping), Municipal
Employees
Public Education & Outreach, IDDE,
Good Housekeeping
Pet Waste Residents, Public School
Students, Dog Parks
Public Education & Outreach, IDDE
Proper Waste Disposal Residents, Public School
Students, Businesses, Municipal
Employees
Public Education & Outreach, IDDE,
Good Housekeeping

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Public School Students (Grades 2-12): This target audience has the greatest potential for growing up to
be good watershed stewards and influencing the behavior of adults. The Town maintains an active youth
education program and partners with local schools to deliver information and hands-on experiences that
are aligned with the North Carolina Course of Study. In FY21, the Town produced a YouTube video on
water quality parameters for 8th grade students. The Town also sponsors high school interns upon request
and provides opportunities for the community to serve. More information on the public education
program is available on the Town’s Public Education and Participation website.

Residents: This subgroup of the public has been selected because residential land use in the Town is
approximately 64% of the Town’s jurisdiction, and thus they have the greatest potential for affecting
stormwater quality.

Homeowners: Homeowners are likely to care for a home and property and have the greatest
potential for engaging in target activities such as yard care, trash disposal practices, pet
ownership, car maintenance, and reporting pollution. Homeowners can also make stormwater-
friendly changes to their property, such as disconnecting downspouts and installing rain gardens.

Single-Family Home Renters: Like the homeowners, renters in single-family homes also engage in
target activities such as yard care, disposal practices, pet ownership, car maintenance, and
reporting pollution.

Multi-Family Residential Communities: This target audience has been selected because the Town
has a significant population of university students who live in apartments. Educating residents of
these complexes about pet waste, litter, and proper waste disposal in particular can be beneficial
to water quality. The Town works with property managers to help reach this audience.

Pet Owners: Residents who own pets are a target audience because pet waste is easily
preventable when the public is informed about the threat it causes to water quality. According
to Orange County Animal Services, 4,818 pets were registered in Chapel Hill in FY19, which is
about one-third of the total pets registered in Orange County.

Construction Industry: This target audience has the greatest potential for affecting erosion and
sedimentation control at construction sites, which can be a significant contributor of sediment to the
Town’s waterways. This industry also has the greatest potential for improper disposal of materials such
as trash, paint, concrete, and other waste.

Local Businesses: This target audience includes restaurants, landscapers, pet stores, paint stores/paint
contractors, mobile/power washing companies and other local businesses that can benefit from
knowledge of BMPs to prevent pollution that are specific to their business activities. The Town maintains
an "On the Job" section on the Prevent Water Pollution webpage to provide information to prevent water
pollution in the workplace, and has developed award-winning materials for restaurants in particular that
are regularly distributed.
13.2 METHODS FOR EDUCATION AND OUTREACH
Educational Materials: Stormwater staff create and distribute educational materials about common
pollutants, best practices, drainage issues, stream buffers, watersheds, and other topics as needed.

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Informational Website: The Stormwater Management staff maintains and regularly updates a
Stormwater Management Program website. The Town maintains webpages dedicated to illicit
discharges, preventing water pollution, and a Stormwater program overview. The pages include
information about the Town’s MS4 permit as well as the Illicit Discharge Ordinance.

Other Digital Tools: The Town maintains a Facebook group, participates in the Town’s e-
notification service for Town updates, and contributes to the Tar Heel Citizen Times off-campus
newsletter. Stormwater/clean water messages are also included in Parks & Recreation outreach
(signage, catalogs, and webpages), Orange County Solid Waste and Recycling e-news, and through
local watershed organizations.

Printed Materials: Staff maintain and distribute brochures specific to businesses and the general
public in various locations around Town. The Town provides materials to homeowners who apply
for permits that involve pool permits and riparian buffers. The Town often provides pet waste
materials and pollution prevention information to the Orange County Animal Shelter to distribute
for dog adoptions. Distribution of printed brochures has been on pause due to the COVID-19
pandemic, but Town staff continue to offer electronic versions of these materials.

Events: Events educate the public on illicit discharge identification and reporting, stormwater drainage
and flooding issues, the biological monitoring program, and the connection between stormwater drainage
and local waterways. The Town distributes educational materials at the local library, festivals, and
exhibits. Large events are on hold in FY21 due to the COVID-19 pandemic.

Workshops: Stormwater management staff also provide workshops and training opportunities upon
request for public schools and UNC students, local businesses, and residents.

Stormwater Hotline: Community members can report pollution and drainage issues at 919-969-RAIN
(7246). In addition to using the hotline, water quality and quantity concerns may be reported through
SeeClickFix/Chapel Hill Connect, social media accounts, and email ([e-mail] and
[e-mail]). The hotline as well as the Town’s stormwater management website is
advertised on printed and digital materials.

Industry-specific outreach has included the production of videos demonstrating proper disposal of kitchen
mop water and grease, and post cards that can be handed to landscapers showing proper disposal of yard
waste. The Town maintains a program developed in partnership with UNC-Chapel Hill’s Institute for the
Environment that provides pollution prevention training materials for restaurant staff, including food
service managers and supervisors. The Town also partnered with Sherwin Williams and the Cities of
Durham and Raleigh to survey local painting contractors and place hazardous household waste collection
center information at local Sherwin Williams stores. The results of the survey informed the development
of industry-specific IDDE education strategies in a brochure on How to Clean Up Paint & Stain.

Partnerships: In partnership with other local governments in the region, the Town is an active member of
the Clean Water Education Partnership (CWEP), which is a cooperative effort that aims to protect North
Carolina’s waterways from stormwater pollution through public education and outreach. CWEP leverages
resources to assist local government outreach efforts with coordinated media campaigns that reach wide

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audiences through cinema ads, online videos, social media, and radio campaigns. CWEP also produces
topical brochures and newspaper ads for use by the Town and other local governments in English and
Spanish, maintains a website the Town links to help citizens understand what they can do to help reduce
stormwater pollution in their community, and assists with direct education events. For more information
about CWEP outreach activities, refer to the annual reports posted on their webpage; see also Section 10
above.
13.3 BEST MANAGEMENT PRACTICES FOR THE PUBLIC EDUCATION AND OUTREACH PROGRAM
Below are the Best Management Practices (BMPs) the Town implements to meet the Public Education
and Outreach component of our MS4 permit. Funding for the BMPs in this section is covered by local
stormwater utility fees.

Table 8. BMPs for the Public Education & Outreach program.
BMP Measurable Goals Schedule for
Implementation
Annual Reporting
Metric
a. Describe targeted
residential and
commercial sources
and activities
Identify targeted residential
and commercial sources and
activities including:

• A description of the
target pollutants
and/or stressors and
likely sources and
impacts on
stormwater runoff
and water quality.
• Target audiences
likely to have
significant storm
water impacts and
why they were
selected.

Continuously. Evaluate
and update annually.
Targeted audiences
matrix is evaluated
annually and
updated as needed.
(Yes/No/Status)

b. Informational Web
Site
Promote and maintain an
internet web site.

Continuously. Evaluate
and update annually.

Track reach and
engagement on
website quarterly.

Evaluated annually
and updated as
needed.
(Yes/No/Status)

Number of unique
and total page visits
per quarter.

c. Develop and
distribute public
education materials
Distribute, assess, and
update as necessary
stormwater educational
Continuously. Evaluate
and update annually.
The number of
educational
materials that were

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BMP Measurable Goals Schedule for
Implementation
Annual Reporting
Metric
to identified target
audiences and user
groups.
material to appropriate
target groups using locally
appropriate strategies.

Measure and record the
extent of exposure for each
strategy.

distributed to
targeted audiences,
including:
• business
owners and
operators.
• residents.
• pet owners.

The number of
promotional items
given out at events.

The number of
partnerships for
promotions (radio,
TV, Businesses).

The number of
stormwater related
articles published.

d. Maintain
Hotline/Help line
Promote and maintain a
stormwater hotline/helpline.

Continuously. Evaluate
annually and update,
as necessary.
Number of calls to
hotline to report
water quality issues.

Number of
mechanisms utilized
to share hotline
(e.g., brochures,
promotional items).

e. Evaluate program
effectiveness
Assess the stormwater
education/outreach program
and update, as necessary.
Evaluate annually and
update, as necessary.
See metrics
provided for a-d
above.

Evaluated annually
and updated as
needed?
(Yes/No/Status)

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14 PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
The Town of Chapel Hill has an active Public Involvement and Participation program to provide
opportunities for the public to participate in program development and implementation. Below is a
description of the program and a table of BMPs the Town implements. The primary target audiences for
this program are residents and homeowners’ associations, real estate agents, local businesses,
environmental groups, civic groups, UNC students, public schools, and youth organizations.
14.1 STORMWATER MANAGEMENT UTILITY ADVISORY BOARD
The Town’s Stormwater Management Utility Advisory Board (SWMUAB) was formed in 2004 by ordinance
(Chapter 23, Article I), and meets monthly. The Board is charged with the following responsibilities:
• Provide recommendations regarding the identification and implementation of new stormwater
management program activities;
• review and provide recommendations on the Stormwater Management Program Master Plan;
• provide recommendations concerning gaps or inconsistencies in Town stormwater management
services, facilities, programs, policies, and regulations and recommend improvement alternatives;
• provide recommendations for priorities and scheduling of watershed master planning and
development of drainage basin plans;
• assist Town staff in working with stakeholder groups to implement program objectives and
activities;
• assist Town staff with public education and outreach activities that promote the Town’s
Stormwater Management Program;
• assist Town staff in meeting the mission and achieving the identified goals and objectives of the
Town’s Stormwater Management Program;
• provide recommendations for internal program evaluation and reporting mechanisms; and
• assist Town staff in periodically reporting (Quarterly Report) to the Town Council on program
effectiveness.

The Town’s Stormwater Management Division provide staff support for the SWMUAB.
14.2 OUTREACH AND VOLUNTEER OPPORTUNITIES
Volunteer Programs: The Town values volunteers who help educate their community about
stormwater. Groups that commonly participate in volunteer activities include Boy/Girl Scout troops,
environmental interest groups, homeowners’ associations, schools, civic groups, families, and businesses.
The Town updates and maintain a webpage focused on public education and participation, which provides
information on volunteer opportunities.

Storm Drain Marking: This program provides storm drain decals, adhesive, safety vests and
information forms for completion by the groups for volunteers to adhere vinyl printed markers to
storm drains in older storm drains in neighborhoods, at parks, and at schools. Volunteers also help
distribute door hangers which provides tips for keeping waterways clean. This program has been
on hiatus since 2018 due to staff turnover and limitations and will resume in FY21.

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Litter Cleanups: The Town provides opportunities for participation in stream litter cleanups every
spring and fall, as well as during other times of the year upon request. Supplies, maps, and data
sheets are provided to volunteers by the Town, and the Town maintains a webpage that provides
additional information on cleanup events and resources available. Town-sponsored cleanup
events have been on hold during the COVID-19 pandemic due to safety concerns. Staff continue
to support community-planned cleanup events by providing supplies and coordinating trash
pickup.

Water Quality Monitoring: In 2013, The Town of Chapel Hill began a volunteer water quality
monitoring program called The Stream Team. The goals of this program are to:
o connect citizen scientists and residents with their watersheds and local government,
o encourage residents to report illicit discharges and sources of pollution, and
o train volunteers to conduct visual assessments and measure basic water quality
parameters. Sites are chosen based on volunteer interest with emphasis on sites nearby
the established annual biological monitoring sites described above.

This program has been on hiatus since 2018 due to staff turnover and limitations and will resume
in FY21.

Service Projects: Town staff work with UNC students and high school students upon request to provide
service projects that engage students in stormwater management activities and water quality
monitoring. There are no projects currently.

Public School Program: The Town’s public schools program fits the NC Standard Course of Study, and helps
students learn ways to reduce pollution and protect our natural resources. For example, Town staff work
with elementary and middle school students on IDDE and stormwater awareness using an Enviroscape
watershed model to demonstrate the fate of stormwater runoff. Due to the COVID-19 pandemic,
traditional in-school presentations are on hold. The Town is providing virtual engagement opportunities
and working with local Academic Support Circles to provide stormwater education to students. Academic
Support Circles were set up in the community to support working parents during the COVID-19 pandemic.
14.3 PUBLIC INVOLVEMENT IN SUBWATERSHED STUDIES
Through the recent development of the Lower Booker Creek Subwatershed Study, Eastwood Lake
Subwatershed Study, and Cedar Fork Subwatershed Study, many opportunities have been provided to
ensure residents, businesses, visitors and property owners stay engaged and provide feedback on water
quality issues and flooding. The project's Public Involvement Plan included use of direct mail
questionnaires, web‐based applications, road sign notices, email notices, Town news, flyers, information
cards distributed by businesses in the subwatershed, information tables at local businesses, paid ads in
the local newspaper, and a number of public meetings and presentations.
14.4 BEST MANAGEMENT PRACTICES FOR THE PUBLIC INVOLVEMENT AND PARTICIPATION
PROGRAM
Below are Best Management Practices (BMPs) the Town implements to meet the Public Involvement and
Participation component of our MS4 permit.

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Table 9. BMPs for the Public Involvement & Participation program.
BMP Measurable Goals Schedule for
Implementation
Annual Reporting
Metric
a. Volunteer
community
involvement
program
Include and promote
volunteer opportunities
as part of its stormwater
management program
designed to promote
ongoing citizen
participation.

Reinstate storm drain
marking program in
FY21.

Hold biannual
community-wide
cleanup events.
Number of storm
drains marked,
number of volunteers.

Number of clean up
events, number of
volunteers, weight of
debris removed in
tons, number of
stream miles cleaned.

b. Mechanism for
public involvement
Continue staff support to
Storm Water Advisory
Board.
Continuously. Number of meetings
and number of
participants.
15 ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE)
The overall goals of the illicit discharge detection and elimination (IDDE) program include program
administration and documentation, outfall assessment, preventing illicit discharges, and finding and fixing
illicit discharges. The Town of Chapel Hill maintains an IDDE program that includes a stormwater
conveyance system map (infrastructure and receiving streams), a regulatory mechanism (IDDE
Ordinance), and procedures for detection and elimination as well as enforcement. The Town actively
provides education and outreach to the Town’s residents and businesses, including targeted audiences,
and has been further developing a sustainable staff training program. A tracking and reporting system is
in place, and IDDE efforts are coordinated and communicated with other affected agencies, including
adjacent MS4 communities. Key staff responsible for this program are identified in Table 6 above.
15.1 STORM SEWER SYSTEM MAP
The Town’s stormwater infrastructure geodatabase includes data for inlets, manholes, junction boxes,
pipes, pipe junctions, outfalls, channels, ditches, and bridges, pond structures, as well as difficult access
structures. Maintenance of the Town’s stormwater infrastructure data is based on the incorporation of
as-built surveys from new development projects, and field verification and mapping of existing
infrastructure. Field-verified data relies on a site visit and inspection of existing storm sewer
infrastructure, as well as discovery of previously unmapped storm sewer structures.

In 2008 and 2009, stream conditions and potential stormwater project sites were assessed as part of two
pilot studies: the Ephesus Subwatershed Study and Booker Creek Headwaters Subwatershed Study,
respectively; both studies were included in the Town’s Stormwater Management Master Plan – Phase II
(Jewell Engineering Consultants, PC, 2014). These pilot studies involved mapping culverts and outlets and
noting their condition, as well as identifying potential pollution sources in these subwatersheds.

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In 2015, engineering firm W.K. Dickson and Town Stormwater Management staff conducted field work to
map, catalog and assess the drainage system, stream stability, and water quality in the Lower Booker
Creek subwatershed as part of the Lower Booker Creek Subwatershed Study. Since then, systematic
drainage system mapping has continued in the Eastwood Lake and Cedar Fork subwatersheds of Booker
Creek. The final Booker Creek subwatershed to be mapped is Crow Branch. For more information on
Booker Creek subwatershed studies, including reports, see http://bookercreekplan.org/.

Though infrastructure has also been mapped in the Bolin Creek and Morgan Creek subwatersheds, to date
there has not been systematic, survey-grade mapping in these subwatersheds as there has been in Booker
Creek.

As of December 2020, there are 1,767 outfalls mapped within the Town’s zoning jurisdiction, including
culvert outlets, as reflected in the Town’s stormwater infrastructure data set; of these outfalls,
approximately 240 have been documented to have a diameter of 36” or greater and are either not culverts
or are culverts with other stormwater infrastructure draining to them (see Figure 5). The Town will
continue to systematically map subwatersheds throughout the Town’s jurisdiction and refine the
stormwater infrastructure data, so the numbers reported here are dynamic.

Receiving waters are determined from the Town’s geodatabase for streams and waterbodies and NC
Division of Water Resource (NCDWR)’s stream classifications data. The Town’s stream and waterbody
geodatabase originates from inputs of data from topo and soils maps, staff input, as well as LIDAR data.
Streams and waterbodies are field verified by Town staff through the Town’s on-going stream
determination program, and these data are updated frequently based on site visits. This program is in
place to meet the Town’s requirements as a delegated authority to implement and enforce Jordan Lake
buffer rules as well as the Town’s Resource Conservation District (RCD) regulations.

The Town of Chapel Hill also has a pollution sources geodatabase which includes mapped locations of
industrial NPDES-permitted discharges and residential, commercial, and industrial sites that are known to
or have the potential to generate illicit discharges, such as commercial dumpsters, dry cleaners, landfills,
underground storage tanks, and various businesses such as automotive service stations.

In addition, OWASA regularly shares GIS data with the Town for their water and sewer infrastructure, and
the Town coordinates regularly with the Town of Carrboro and UNC stormwater staff to share data and
information.

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Figure 5. Stormwater outfalls and receiving streams within the Town of Chapel Hill's zoning jurisdiction.

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15.2 REGULATORY MECHANISM
The Chapel Hill Town Council adopted an Illicit Discharge Detection and Elimination (IDDE) Ordinance
(Chapter 23, Article V of the Town Code of Ordinances) on November 14, 2016, that effectively prohibits
discharge of non-stormwater to the Town’s storm sewer network. The IDDE Ordinance details the Town’s
authority, spill response notification requirements, violation and enforcement procedures, and a schedule
of associated civil penalties and other remedies for violations of the ordinance.
15.3 DETECTION AND ELIMINATION
The Town uses a variety of tools to help detect and then eliminate illicit discharges, including a pollution
reporting hotline, on-site inspections, storm drain network or drainage area investigations, and ultimately
correction and enforcement.

Reports of illicit discharges to the Town’s storm sewer system are often initiated by reports from residents
and Town staff and are particularly effective at identifying obvious illicit discharges. Residents of Chapel
Hill tend to be well-informed and proactive regarding water quality issues - in FY19, staff received 39
complaints, of which 28 were reports from the general public. Stormwater Management staff, other Town
staff, as well as coordinating agencies (e.g., UNC, Orange County Health Department) who are regularly in
the field make reports and/or initiate an investigation as part of their daily work when they notice a
potential illicit discharge.

The Stormwater Management program maintains a hotline for complaints during business hours. The
Town’s Emergency Management unit is available for after-hours concerns and has a long history of
working with Stormwater Management to respond to illicit discharge incidents. Procedures for reporting
illicit discharges and spills are included in the IDDE ordinance, and are also available on the Town’s
Stormwater Management website.

In addition to reports of potential illicit discharges, Town staff conduct stream determinations and
examine outfalls during site visits – if an illicit discharge is suspected, an investigation is initiated. Because
conducting stream determinations requires that a site visit not take place within 48 hours of a rainfall
event, discharge from outfalls during dry weather is more noticeable. In addition, while systematically
mapping the Town’s storm sewer infrastructure, any water quality issues observed at outfalls is
documented in the Town’s GIS database for follow-up investigation. Known hot spots for high potential
for illicit discharges within the Town include commercial development in downtown and in shopping
centers with restaurants and communal dumpsters; these areas are patrolled as staff workload allows.

Illicit discharges with unknown origins are traced by working up or down the storm sewer network to
narrow the source of the discharge - from the initial point of investigation, following visual, physical and/or
chemical indicators, through the network to the source. Moving up the network when a discharge is
detected at an outfall, Town staff use a storm sewer map and/or following pipe and drain connections.
When a discharge is observed draining to a storm drain inlet, it is followed down the storm sewer network,
and may involve accessing manholes and catch basins before ending at an outfall.

To identify an illicit discharge, or trace it through the stormwater conveyance system, investigators make
and document visual observations, and may also use a water quality meter to measure temperature,
specific conductivity, dissolved oxygen (DO), and pH. Staff have additional test kits for ammonia and

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chlorine, and the Town has a contract with Pace Analytical when a water quality sample may need to be
analyzed in a laboratory. Dye testing or using clean water to identify flow paths may be utilized if the
path of the network is not entirely known.

Illicit discharge investigations have also been initiated by Stormwater Management staff by focusing on
indicators from annual benthic macro invertebrate monitoring results in subwatersheds with poor or
declining water quality. Since 2011, the Town has established 36 benthic macroinvertebrate monitoring
sites, of which 28 sites are currently monitored annually. For example, in 2015, toxicity was identified at
one newly established benthic monitoring site that prompted an investigation by Town staff that led to
the resolution of a long-running discharge of swimming pool backwash from an apartment complex.
Stormwater Management staff issued a NOV, and then worked with the property owner to remedy the
illicit discharge.

Once the source of an illicit discharge has been identified, steps are taken to fix or eliminate the discharge.
The responsible party is identified (if possible), and education/compliance assistance and/or enforcement
actions are taken to address the discharge. An escalating enforcement approach is usually undertaken,
working toward voluntary compliance for first-time offenders. More serious violations or continued non-
compliance may warrant a more aggressive enforcement-oriented approach. See also Section 15.4 below.
15.4 ENFORCEMENT PROCEDURES
The Town’s IDDE Ordinance outlines enforcement procedures and actions that may be taken as a result
of a violation. Enforcement action is undertaken by Stormwater Management staff acting as the Town
Manager’s designee. Upon a report or detection of a suspected illicit discharge or connection, staff
investigate and gather evidence, including photos. A database is populated with information pertinent to
the investigation and enforcement actions taken, including date(s) the illicit discharge was observed, the
results of the investigation, any follow-up of the investigation, and the date the investigation was closed,
and is updated as the investigation progresses. All relevant documentation, including photos and
correspondence, is saved in an investigation folder specific to the incident.

When the Town finds that there is a violation of the IDDE Ordinance, the party(ies) responsible are issued
a Notice of Violation (NOV) in writing by certified mail, personal service, or posting of the notice at the
facility where the violation occurred. Often, Town staff also issue the NOV via email (in addition to
certified mail) to expedite receipt more quickly. The NOV cites the Town’s authority, describes the illicit
discharge, outlines remedies, specifies a timeline for compliance, and states potential penalties. Work by
the responsible party to resolve/remediate the illicit discharge must follow a reasonable timeline and is
monitored with follow up investigations by Town staff to ensure compliance.
15.5 NON-STORMWATER DISCHARGES WITH POTENTIAL TO SIGNIFICANTLY CONTRIBUTE
POLLUTANTS
Town staff periodically review non-stormwater discharges that are considered “allowed” in the IDDE
Ordinance to assess whether they have potential to significantly impact water quality or cause or
contribute to a violation of applicable water quality standards. If so, they are regulated as an illicit
discharge.

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The Orange Water and Sewer Authority (OWASA) updated their Sewer Use Ordinance on January 9, 2020,
to allow for discharge from dumpster pads, elevator sumps, pool filter backwash, and condensate from
commercial HVAC systems into the sanitary sewer system if the discharge meets the requirements of the
ordinance (i.e., does not damage the collection system or interfere with treatment). Formal review and
approval by OWASA is required before these discharges may be conveyed to the sanitary sewer system.
15.5.1 Pool Discharge & Backwash
Discharges from swimming pool back-washing, pool discharges that have not been dechlorinated, and
saltwater pool discharges are all non-stormwater discharges with the potential to significantly contribute
pollutants to the Town’s MS4 and waters of the State.

As noted above, a report of toxicity at one of the Town’s newly established benthic monitoring sites in
2015 prompted an investigation into the source of the toxicity, and it was discovered that an outdoor
swimming pool at an apartment complex was directly discharging chlorinated pool water and backwash
directly into a stream. In 2016, specific conductivity readings obtained by Town Stormwater Management
staff at several different outfalls that receive swimming pool filter backwash far exceeded 1000uS/cm,
indicating that pool backwash was causing potentially significant water quality issues. As a result, the
Town’s IDDE Ordinance was drafted and approved to allow discharges from dechlorinated swimming
pools only, and to specifically prohibit pool filter backwash discharge or saltwater pool discharge.

The Town has a working relationship with OWASA regarding pool discharge allowances. Additionally, pool
permits are reviewed by Town staff to ensure that pool discharges do not significantly impact water
quality standards. New pool owners receive a Pool Maintenance brochure that provides information on
the IDDE Ordinance and best practices.

Stormwater staff use GIS data for swimming pool locations to track the potential for illicit discharges.
These data are maintained regularly based on reports from the Town’s Inspections staff who send monthly
reports of newly permitted pools.

Previously permitted pool discharges are also occasionally discovered during field work for stream
determinations. If direct discharge to streams is observed, property owners are notified and required to
redirect pool backwash discharge to sanitary sewer if possible; if not possible, the Town works with the
property owner on alternatives, such as installing a non-discharge cartridge system.
15.5.2 Commercial Air Conditioning Condensate
Scientific research has identified wastewater discharges produced from air conditioning cleaning
operations to have high concentration of heavy metals and other pollutant of concern to water quality.
Heating, Ventilation, and Air Conditioning (HVAC) companies clean the metal condensation coils and fins
of air conditioning units for maintenance and efficiency purposes.

Though the Town’s IDDE Ordinance lists commercial AC condensate as an allowed activity, the Town of
Chapel Hill prohibits the discharge of HVAC condensate from commercial operations into the Town’s MS4
due to its potential to significantly impact water quality. To comply with this requirement, proposed new
commercial developments are required to plumb the HVAC unit to sanitary sewer after a plumbing plan
has been reviewed and approved by OWASA. Existing commercial buildings with the potential to
discharge HVAC condensate into Town’s MS4 are provided education about the impact of the HVAC
condensate on surface water quality and given some time to plumb the unit to sanitary sewer. Commercial

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cleaning companies are also required to contain, collect, and properly dispose of their waste into the
sanitary sewer system.
15.5.3 Water Line Flushing
To maintain drinking water distribution systems and fire hydrants and to ensure the quality of drinking
water being distributed, many activities are conducted that result in the discharge of chlorinated and
super-chlorinated water. Activities such as fire hydrant flushing, water line pressure testing and
maintenance, water line flushing, and other distribution system discharges release super-chlorinated
water into surface water. Super-chlorinated water (i.e., water with chlorine concentrations above 4 mg/l)
discharge into surface water is toxic to aquatic life.

The Town has worked with OWASA to prevent the discharge of super-chlorinated water during water line
and fire hydrant flushing. Using dichlorination tablets, the super-chlorinated/chlorinated water is
dechlorinated to 0.1 mg/l total residue chlorine or less prior to discharge to surface water or Town’s MS4.
15.5.4 Other Prohibited Discharges
Stormwater Management staff have also identified area drains in covered parking lots and elevator sump
pumps that drain to the storm sewer system as sources of pollution and have prohibited installation of
these types of drains on new and redevelopment projects. OWASA’s Sewer Use Ordinance allows this
discharge into sanitary sewer after plumbing plan has been reviewed and approved.
15.6 OUTREACH & EDUCATION
Outreach and education are essential to pollution prevention as well as illicit discharge detection and
elimination. The Town has several staff that provide outreach, including a Community Outreach position,
who primarily works on public education, outreach and participation, and as well as the Stormwater
Analyst and Stormwater Specialist positions who are responsible for the IDDE program and frequently
provide education to the business community. These staff also coordinate training for Town staff.

Outreach for IDDE is addressed in the following sections above:
• Section 13.1 Target Pollutants and Audiences,
• Section 13.2 Methods for Education and Outreach, and
• Section 14.2 Outreach and Volunteer Opportunities.
15.7 STAFF TRAINING
Employee training is important to prevent pollution on properties owned or operated by the Town and
can also help with the Town’s detection and elimination of illicit discharges on private property.

Town Stormwater Management staff provided several presentations on stormwater awareness and IDDE
to upper and middle level management, the Town Council, and advisory board members, as part of the
process of IDDE Ordinance review and adoption in 2016.

In 2013, site assessments were conducted by Town Stormwater Management staff and an engineering
firm at individual facilities owned and operated by the Town to:
• evaluate existing conditions and to determine whether or not the facilities are impacted by the
NPDES MS4 permit;

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• identify stormwater “hot spots” where a significant potential for stormwater runoff
contamination may exist; and
• provide recommendations to the Town.

Town personnel familiar with the operations at the individual facilities also participated in the
assessments. During the site visits, the assessment team interviewed facility personnel and observed
various industrial operations.

As a follow-up to the site assessments, the Town hired an engineering firm in FY21 to develop and assist
the Town in implementing a more comprehensive and sustainable training program for all Town
employees and all municipal facility staff. Target employee groups will be educated about common illicit
discharges, pollution prevention practices, reporting protocols, and the requirements of the IDDE
Ordinance. Various methods will be used as appropriate to reach the target groups, including classroom
presentations and outdoor field-based training sessions. Town stormwater staff will work with the
consultant to develop an employee training plan to set goals, direct the actions of the training program,
and to develop training sessions specific to both facility employees and facility managers/department
supervisors.

In addition, Town Stormwater Management staff will work with the Human Resources Development
(HRD) Department to incorporate stormwater awareness training into the Town’s new employee
orientation training and existing employee training programs.
15.8 EVALUATION
The effectiveness of the Town’s IDDE program can be evaluated by reviewing the program and progress
made toward meeting the program’s measurable goals on a regular basis (see Table 10 below). The Town
has developed a comprehensive IDDE tracking database and filing system which is used to help identify
hot spots, chronic violators, and common pollution sources, and to provide information for annual
reporting. This information can also be used to recommend program revisions and staff work plans, as
well as identify staff and funding needs. In addition, the Town maintains a comprehensive GIS database
of stormwater infrastructure and receiving streams, as well as water quality monitoring data, and
evaluation of these data help identify gaps in mapping that should be addressed as well as identifying
major outfalls that should be prioritized for dry weather screening.
15.9 BEST MANAGEMENT PRACTICES FOR ILLICIT DISCHARGE DETECTION AND ELIMINATION
Below are Best Management Practices (BMPs) the Town implements to meet the Illicit Discharge
Detection and Elimination (IDDE) component of our MS4 permit.

Table 10. BMPs for the IDDE Program.
BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
a. Maintain
adequate legal
authorities
Conduct annual review of
legal authorities and
revise, as necessary.
Evaluate annually and
update as needed.

Evaluated annually for any
needed updates?
(Yes/No/Status)

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BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric

b. Maintain a Storm
Sewer System
Base Map of
Major Outfalls
Complete and maintain a
map identifying major
outfalls and receiving
streams.

Complete outfall map in
Booker Creek subwatershed
by FY22.
(See schedule for
subwatershed studies)

Develop plan for completing
outfall mapping in Bolin
Creek & Morgan Creek
subwatersheds in FY22.

Continuously maintain map
of major outfalls and
receiving streams.

Number of major outfalls
added to map per fiscal
year.

Plan for completing outfall
mapping is developed?
(Yes/No/Status)

All major outfalls in new
developments are mapped
using as-built data?
(Yes/No/Status)

c. Detect dry
weather flows
Develop and implement a
program for conducting
regular dry weather flow
field observations in
accordance with written
field screening procedure
for detecting sources of
illicit discharges.

Develop Standard Operating
Procedures (SOP) and
implementation plan in
FY21.

Establish priority outfall
inspection areas in FY21.

Inspect a minimum of 10%
major outfalls/year
beginning in FY21.

SOP completed and
approved?
(Yes/No/Status)

Priority inspection areas
identified?
(Yes/No/Status)

The number of dry
weather inspections
completed.
d. Investigations
into the source of
all identified illicit
discharges
Maintain, assess
annually, and update as
necessary written
procedures for
conducting investigations
into the source of
identified illicit
discharges, including
approaches to requiring
such discharges to be
eliminated or reported to
the State to be properly
permitted.

Complete and implement
SOP in FY21.

SOP completed and
approved?
(Yes/No/Status)

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BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
e. Track
investigations
and document
illicit discharges
Track all investigations
and document the
date(s) the illicit
discharge was observed;
the results of the
investigation; any follow-
up of the investigation;
and the date the
investigation was closed.

Continuously track
investigations as they occur.
Evaluate tracking records
and report annually.

Number of
• investigations
• verified illicit
discharges.
• remedied illicit
discharges.
• enforcement
actions taken.

Record for each
investigation tracked
includes date(s) observed,
results, follow-up and date
closed? (Yes/No/Status)

f. Town Employee
Training
Implement and
document a training
program for appropriate
municipal staff, who, as
part of their normal job
responsibilities, may
come into contact with
or otherwise observe an
illicit discharge or illicit
connection to the storm
sewer system.
Develop IDDE training
program in FY21 for all
• new employees
• current employees
• municipal facility
employees

Train all
• new employees
within one (1) year
of start date

• current employees
annually

• municipal facility
employees annually
Training program
developed for all new
employees, current
employees, and municipal
facility staff?
(Yes/No/Status)

All new employees trained
within one (1) year of start
date? (Yes/No/Status)

All current employees
participate in annual
refresher training?
(Yes/No/Status)

All municipal facility staff
participate in annual
refresher training?
(Yes/No/Status)

g. Provide Public
Education
Inform public employees,
businesses, and the
general public of hazards
associated with illegal
discharges and improper
disposal of waste.

Continuously track
educational materials
provided and report
annually.

The number of
educational materials that
were distributed to public
employees, businesses,
and the general public.

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BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
(See also BMPs above for
Public Education (website,
events, target audiences,
etc.) & IDDE BMP (f) Town
Employee Training)

h. Reporting hotline Promote and maintain
hotline for public and
town staff to report illicit
discharges and
connections.
Continuously. Review and
report.

The number of calls
received by a hotline(s).

The number of
problems/incidents
remedied as a result of
hotline calls.

(See also IDDE BMP (d)
above – IDDE
investigations)

i. Enforcement Track the issuance of
notices of violation and
enforcement actions.
This mechanism shall
include the ability to
identify chronic violators
for initiation of actions to
reduce noncompliance.

Continuously. Review and
report annually.

All NOV and enforcement
actions tracked in
database? (Yes/No/Status)

Number of notices of
violation and enforcement
actions.

(see also IDDE BMP (e)
above – IDDE Investigation
tracking)
16 CONSTRUCTION SITE RUNOFF
The Town of Chapel Hill relies on the Orange County Erosion Control program for compliance with
construction site runoff requirements. See Section 11 above.
17 POST-CONSTRUCTION STORMWATER PROGRAM
The Town of Chapel Hill implements and enforces a stormwater program to address storm water runoff
from new development and redevelopment projects, and implements various strategies, including a
combination of structural and/or non-structural BMPs, appropriate for the Town to accomplish
implementation and enforcement. The mechanisms through which the Town implements this program
are summarized below.

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17.1 REGULATORY MECHANISM
Land Use Management Ordinance (LUMO) Section 5.4 outlines general performance criteria for post-
development stormwater management. The requirements for post-construction site runoff control
pertain to projects with over 20,000 square feet of land disturbance. The performance criteria meet
NCDEQ water quality requirements and exceeds requirements for peak rate and volume control. The
Town’s Public Works Engineering Design Manual references specifications and guidelines pertinent to
Stormwater Control Measures (SCMs), which must be designed according to the NCDEQ Stormwater
Design Manual. These criteria must be reflected in development plans prior to approval.
17.2 OPERATION AND MAINTENANCE
LUMO Sections 5.4.8 and 5.4.9 include requirements for Operations & Maintenance (O&M) of SCMs. The
following items are required prior to the release of a Certificate of Occupancy (CO):
• The design engineer for a SCM must provide a North Carolina Professional Engineer’s certification
with an as-built survey certifying that the SCM has been constructed as approved by the Town of
Chapel Hill.
• The stormwater facility easement plat and a notarized O&M agreement signed by the owner must
be recorded at the Orange County Register of Deeds. This agreement binds the owner and other
future owners to regular inspection and maintenance of the SCMs on the site.
• Town Stormwater Management staff inspect and approve all installed SCMs. In some cases, if
reasonable justification is provided, the CO may be released prior to completion of the SCMs but
a bond will be required and held until SCMs are completed and approved.

The Town requires owners to submit an Annual Inspection and Maintenance Report for all SCMs.
Inspections must be performed by a registered North Carolina Professional Engineer or Landscape
Architect with qualified professional SCM Inspection and Maintenance training. If a report is not received
by its annual deadline, Town staff send the SCM owner a letter reminding them of inspection report
requirements. Additionally, Town staff inspect all SCMs at least once every five years. LUMO Section
5.4.8(e) includes requirements for addressing sites that fail to maintain SCMs.

Guidance and requirements for SCM inspections and maintenance, including templates for O&M
agreements, inspection and maintenance plans, inspection logs, and annual inspection reports can be
found at the Town’s Stormwater Control Measures webpage.
17.3 BEST MANAGEMENT PRACTICES FOR THE POST-CONSTRUCTION STORMWATER PROGRAM
Below are Best Management Practices (BMPs) the Town implements to meet the Post-Construction
Stormwater Program component of our NPDES MS4 permit.

Table 11. BMPs for the Post-Construction Stormwater program.
BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
a. Maintain
adequate legal
authorities
Review and revise
ordinances or other legal
authorities, and
revise/update as
Evaluate and update
annually as needed.

Evaluated annually for any
needed updates?
(Yes/No/Status)

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BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
necessary, or adopt any
new ordinances or other
legal authorities designed
to meet the objectives of
the Post-Construction
Stormwater Management
Program.

b. Strategies which
include
Stormwater
Control Measures
(SCMs)
appropriate for
the MS4
Compliance with 15A
NCAC 02H Section 1000
effectively meets the Post-
Construction Stormwater
Runoff control
requirements.
Evaluate annually and
update as needed to
ensure requirements are
met.
Evaluated annually for any
needed updates?
(Yes/No/Status)

c. Plan reviews Conduct site plan reviews
of all new development
and redeveloped sites.

Continuously.

The number of
development and
redevelopment projects
with greater than one acre
of land disturbance
reviewed.
d. Inventory of
projects with
post-construction
structural
stormwater
control measures
Develop and maintain an
inventory of projects with
post-construction
structural stormwater
control measures installed
and implemented at new
development and
redeveloped sites,
including both public and
private sector sites
located within the
permittee’s jurisdiction
area that are covered by
its post-construction
ordinance requirements.

Inventory has been
completed and is updated
continuously. Evaluate
annually.
Number of new SCMs
associated with a project
that have received a
Certificate of Occupancy.

e. Deed Restrictions
and Protective
Covenants
Provide mechanisms such
as recorded deed
restrictions and protective
covenants so that
development activities
maintain the project
Mechanism is complete.
Evaluate and update
annually as needed.

Continuously ensure that
deed restrictions and
Evaluated annually for any
needed updates?
(Yes/No/Status)

All new SCMs installed and
implemented have
recorded deed restrictions

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BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
consistent with approved
plans.

protective covenants are
recorded.

and protective covenants
as required?
(Yes/No/Status)
f. Long-term
operation and
maintenance of
structural
Stormwater
Control Measures
(SCMs)
Require an operation and
maintenance plan for the
long-term operation
SCMs.
O&M requirements in
place through ordinance.
Evaluate and update
annually as needed.

Continuously ensure that
O&M plans are required
and recorded. Evaluate
annually.

Continuously ensure that
annual inspections are
performed by a qualified
professional. Evaluation
annually.

Evaluate annually.

Evaluated annually for any
needed updates?
(Yes/No/Status)

All new SCMs installed and
implemented have O&M
plans are recorded?
(Yes/No/Status)

All SCMs inspected are
performed by a qualified
professional?
(Yes/No/Status)

Percent (%) of sites in the
Town’s inventory that
have completed and
submitted an annual
inspection report.

g. Inspections Conduct and document
inspections of each
project site covered under
performance standards, at
least one time during the
permit term.

Annually inspect at least
20% of all project sites in
inventory.
At least 20% of project
sites inspected by Town
staff annually?
(Yes/No/Status)
h. Educational
materials and
training for
developers
Make available through
paper or electronic
means, ordinances, post-
construction
requirements, design
standards checklist, and
other materials
appropriate for
developers. New
materials may be
developed by the
Complete. Evaluate
annually and update as
needed.

Evaluated annually for any
needed updates?
(Yes/No/Status)

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BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
permittee, or the
permittee may use
materials adopted from
other programs and
adapted to the
permittee’s new
development and
redevelopment program.

i. Enforcement Track the issuance of
notices of violation and
enforcement actions as
administered by the
permittee. This
mechanism shall include
the ability to identify
chronic violators for
initiation of actions to
reduce noncompliance.

Continuously. Evaluate
annually.

Continuously track non-
compliance and evaluate
annually.

Mechanism in place to
initiate actions to reduce
non-compliance. Evaluate
and update as needed.
Number of notices of
violation and enforcement
actions issued.

Evaluated annually for any
needed updates?
(Yes/No/Status)
18 POLLUTION PREVENTION AND GOOD HOUSEKEEPING
Pollution prevention and good housekeeping (PPGH) for municipal facilities and operations is
accomplished through the implementation of seven required programs, which collectively address the
ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and open
space maintenance, fleet and building maintenance, new construction and land disturbances, and
municipal storm sewer system maintenance.

Pollution prevention and good housekeeping for municipal operations includes the following programs:

• Municipal Facilities Operation and Maintenance Program
• Spill Response Program
• MS4 Operation and Maintenance Program
• Municipal Stormwater Control Measure (SCM) Operation and Maintenance Program
• Pesticide, Herbicide and Fertilizer Management Program
• Vehicle and Equipment Maintenance Program
• Pavement Management Program
• Employee Training Program

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18.1 MUNICIPAL FACILITIES OPERATION AND MAINTENANCE PROGRAM
Municipally-owned or operated facilities in Chapel Hill include the Town Operations Center, Town Fire
Department, Town Police Department, Town Parks and Recreation Facilities, Town Hall, Town Housing
Facilities, the Public Library, and Town-owned or operated parking lots.
The Town’s Operations Center (TOC) – Public Works Complex and Transit Facility – is located outside the
MS4 permit jurisdiction (corporate limits) and maintains a Spill Prevention Control and Countermeasure
Plan (Town of Chapel Hill 2011a) and Stormwater Pollution Prevention Plan (Town of Chapel Hill 2011b)
in compliance with a separate industrial NPDES permit (General Permit No. NCG080000 to Discharge
Stormwater Associated with Industrial Activity). The Town conducts annual inspections and training
sessions at the TOC for facility staff to ensure that requirements are being met. Field operations are
evaluated for impacts on stormwater quality and best management practices are developed and
implemented to minimize those impacts.

Site assessments for other municipally owned and operated facilities (not covered by the TOC’s industrial
NPDES permit) were conducted in July 2013 by Town Stormwater Management staff and a consultant to:
• evaluate existing conditions;
• determine whether or not the facilities are impacted by the NPDES MS4 permit;
• identify stormwater “hot spots” where a significant potential for stormwater runoff
contamination may exist; and
• provide recommendations to the Town (Town of Chapel Hill 2013).

Facility-level BMPs (which include programmatic, operational, and structural BMPs) were identified to:
• improve stormwater runoff quality;
• improve pollution prevention and good housekeeping practices at the facilities; and
• bring the facilities closer into compliance with NPDES permit requirements and Town goals.

The BMP recommendations that resulted from the site assessments were organized by site and prioritized
by a pollution potential rating (high, medium, low) and a cost type rating (high, medium, low).

In 2020, the Town hired an engineering firm to update the 2013 pollution prevent good housekeeping
assessment for all Town facilities. To date, site inspections have been conducted at all facilities. The
contractor is tasked with developing a regular inspection plan that can be used to determine maintenance
and training needs.
18.2 SPILL RESPONSE PROGRAM
The Town’s Operation Center – Public Works Complex and Transit Facility - maintains a Spill Prevention
Control and Countermeasure Plan (Town of Chapel Hill 2011a) and Stormwater Pollution Prevention Plan
(Town of Chapel Hill 2011b) in compliance with North Carolina NPDES General Permit No. NCG080000 to
Discharge Stormwater Associated with Industrial Activity. The Town conducts annual inspections and
training sessions at these facilities to ensure that requirements are being met. Field operations are
evaluated for impacts on stormwater quality and best management practices are developed and
implemented to minimize those impacts. This facility is outside the municipal limits and not subject to
the MS4 requirements.

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Town Stormwater Management staff work with Emergency Management personnel on spill response and
other emergencies for municipally owned/operated facilities and public rights-of-ways. As documented
during the 2013 site assessments, Chapel Hill Fire Department (CHFD) personnel have and maintain spill
response procedures, are trained in material handling and spill response, and have equipment to respond
to and contain oil or hazardous chemical spills. Staff at the Town’s community centers and aquatic center
are also trained in material handling and spill response procedures.

The Town has contracted an engineering firm to update the 2013 facilities assessment that will include
development of Stormwater Pollution Prevention Plans (SWPPPs), including spill response procedures, for
all municipal facilities in FY21. For all facilities for which a site assessment has or will be conducted, an
inventory and map of all municipal operations and/or activities and a site plan showing drains, outfalls,
SCMs and receiving waters will be developed and included in the SWPPP. An O&M plan and/or inspection
and maintenance schedule will also be developed and followed, and inspections of individual facilities will
be conducted annually. Staff training at the identified facilities will be conducted (where needed), and a
record of who was trained, what they were trained on, and when they were trained will be maintained.
Spill response procedures will be followed and updated as needed.
18.3 MUNICIPAL STORM SEWER SYSTEM (MS4) OPERATION AND MAINTENANCE PROGRAM
The Town maintains the stormwater system within the Town’s rights-of-way and on Town-owned
property. This program reduces stormwater runoff from municipally-owned streets, roads, piped and
vegetative conveyances, manholes, cleanouts, drop inlets, and other drainage structures. Maintenance
is performed by staff in the Stormwater Management Division, and includes regular cleanouts of drainage
inlets, removal of blockages, and ongoing repair and upkeep of system components. Maintenance is
performed in response to functional problems using a combination of hand-tools and small power
equipment, pressure-flushing, and/or jet-vacuuming, as appropriate.

Street sweeping is also a regular stormwater maintenance activity that focuses on major streets (once per
week), downtown streets (twice per week), and residential streets (once per six weeks). Additionally, the
Town has a seasonal leaf collection program. Sweepers are also deployed after special events involving
street closures, such as Halloween on Franklin Street and the Downtown Christmas Parade. Seven full-
time staff are currently dedicated to maintenance of the MS4.

Improvements to the MS4 system include resolving flooding problems associated with stormwater
generated from public streets, stream channel stabilization, stream restoration, Best Management
Practices (BMP) installation, and other water quality projects.
18.4 MUNICIPAL STORMWATER CONTROL MEASURE (SCM) OPERATION AND MAINTENANCE
(O&M) PROGRAM
A Stormwater BMP Maintenance Manual was developed for the Northern Community (Homestead) Park
in 2009 for the Parks and Recreation Department by Stormwater Management Division staff. The manual
summarizes O&M for the structural BMPs constructed at Homestead Park, and compiles maps and
approved plan designs. Currently the Parks and Recreation staff are responsible for maintaining structural
BMPs on Town property that they maintain.

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An engineering firm was hired in FY21 to develop and implement an O&M program for all SCMs on Town-
owned properties.
18.5 PESTICIDE, HERBICIDE AND FERTILIZER MANAGEMENT PROGRAM
The Town has adopted an Integrated Pest Management Program (IPM) and policy as a comprehensive
approach that gives priority to prevention and management of pests including insects, weeds, and plant
diseases by the least toxic method. The policy reduces the environmental and health risks associated with
pest management and is administered by Town Parks and Recreation staff. Reducing loading of toxics in
stormwater runoff is one of the direct benefits of this program.
18.6 VEHICLE AND EQUIPMENT MAINTENANCE PROGRAM
A program to identify areas that have the potential to generate illicit discharge will be developed in FY21.
The Town has engaged a contractor to develop a spill response plan and stormwater pollution prevention
plan (SWPPP) for Town facilities where vehicle and equipment maintenance take place. An organized
vehicle spill cleanup response to prevent pollutants from vehicular accidents from entering storm drains
system will be part of the spill response plan.
18.7 PAVEMENT MANAGEMENT PROGRAM
The Town has a vacuum sweeper truck for removing sediments and pollutants from street surfaces in the
downtown district and on municipal parking Lots. Residential roads are swept on a rotational schedule
(see Section 18.3 above). The vacuum sweeper is attached with a “wander hose” that allows removal of
debris and sediments from curb inlets and catch basins.
Storage of salt/sand is located at the Town’s Operation Center which is covered under an industrial NPDES
permit and located outside of the Town’s municipal limits. The storage area is contained within concrete
slab/filled concrete block perimeter walls and protected from runoff by a roof structure covering the
storage area.
18.8 EMPLOYEE TRAINING PROGRAM
An engineering firm was retained by the Town in FY21 to help develop a sustainable employee training
program for all municipal employees. The employee training program will provide basic training on
stormwater pollution prevention (“Stormwater 101”), as well as facility-level training for Town operations.
The “Stormwater 101” portion of the training plan will discuss how the stormwater system functions, how
individual facilities can impact downstream water quality, and demonstrate to staff that their role at any
Town facility is important to protecting water resources.

For facility-level training, the Stormwater Pollution Prevention Plan (SWPPP) for the facility will be
reviewed and a demonstration on how to use the SWPPP will be provided. Facility tours at selected
locations will include a detailed discussion on how to use the SWPPP Map, how to use the corresponding
inspection forms, what to look for when performing an inspection, and what to do should an employee
observe an infraction. An emphasis of the training plan will be making sure staff know the documentation

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requirements of the SWPPP and why they are important for permit compliance. This discussion will also
include how to provide feedback to stormwater staff so that SWPPPs can be edited and improved over
time.

Town Stormwater staff will work with the Human Resources Development (HRD) Department to
incorporate stormwater awareness and facility-level training into the Town’s existing new employee
orientation training and provide regular refresher courses for existing employees.

The Town’s Operations Center (TOC) – Public Works Complex and Transit Facility - maintains a separate
industrial NPDES permit (General Permit No. NCG080000 to Discharge Stormwater Associated with
Industrial Activity). As part of that NPDES permit, the Town conducts annual inspections and training
sessions at the TOC to ensure that requirements at that facility complex are being met.
18.9 BEST MANAGEMENT PRACTICES FOR POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR
MUNICIPAL OPERATIONS
Below are Best Management Practices (BMPs) the Town implements to meet the Pollution Prevention
and Good Housekeeping for Municipal Operations component of our NPDES MS4 permit. Most of the
BMPs associated with pollution prevention and good housekeeping for the Town’s municipal facilities are
carried out by the Town’s Public Works staff or contractors; however, some BMPs are performed by
employees in other Town departments (see Table 6 above).

Table 12. BMPs for Pollution Prevention & Good Housekeeping for Municipal Operations.
BMP Measurable Goals Schedule for
Implementation
Annual Reporting Metric
a. Inventory of
municipally
owned or
operated
facilities
Maintain, evaluate annually,
and update as necessary an
inventory of facilities and
operations owned and
operated by the permittee
with the potential for
generating polluted
stormwater runoff.

Inventory initiated and
expected to be completed
in FY21.

Review inventory annually
and update, as necessary.

Changes made to inventory
are documented (2013
comparison with 2021
assessment)?
(Yes/No/Status)

Inventory reviewed
annually and updated as
necessary? (Yes/No/Status)

b. Identify and
map
municipally
owned or
operated
facilities
Identify and map
municipally-owned or
operated facilities. The map
shall identify the
stormwater outfalls
corresponding to each of
the facilities as well as the
receiving waters to which
these facilities discharge.
The map shall be
Inventory and map update
for each facility to be
completed in FY21.

Review inventory annually
and update, as necessary.

All facilities have been
inventoried and mapped?
(Yes/No/Status)

Inventory reviewed
annually and updated as
necessary? (Yes/No/Status)

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Annual Reporting Metric
maintained and updated
regularly and be available
for review by the permitting
authority.

c. Operation and
Maintenance
(O&M) for
municipally
owned or
operated
facilities
Maintain and implement,
evaluate annually, and
update as necessary an
Operation and Maintenance
(O&M) program for
municipal owned and
operated facilities with the
potential for generating
polluted stormwater runoff.
The O&M program shall
specify the frequency of
inspections and routine
maintenance requirements.

O&M program will be
completed and
implemented in FY21.

Document inspections and
maintenance required
annually for each facility.

O&M program for facilities
completed and
implemented?
(Yes/No/Status)

All facilities inspected?
(Yes/No/Status)

Maintenance actions
completed according to
inspection report?
(Yes/No/Status)

d. Spill Response
Procedures
for
municipally
owned or
operated
facilities
Maintain written spill
response procedures for
municipal operations.

Written spill response
procedures will be
completed for each facility
in FY21.

Spill response procedure
completed for each facility?
(Yes/No/Status)

e. Streets, roads,
and public
parking lots
maintenance
Maintain and implement a
program to reduce polluted
stormwater runoff from
municipally-owned streets,
roads, and public parking
lots.

Street sweeping of roads
and streets is ongoing per
MS4 O&M SOP.

Parking lots/decks
inspected per SWPPP.

Continue leaf/yard debris
pickup seasonally per
schedule.

Evaluate and report
annually.

Document and report
number of streets and
roads swept and amount of
debris collected
and recorded in the annual
street sweeping log.

Inspections took place per
SWPPP? (Yes/No/Status)

Weight of debris
collected in tons.

The quantity of salt applied
to roadways (in tons).

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BMP Measurable Goals Schedule for
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f. Storm sewer
system
inspection and
maintenance
program
Maintain an O&M program
for the stormwater sewer
system catch basins and
conveyance systems the
municipality owns and
maintains.

Implementation of
program in place –
evaluate annually and
update as needed.

Develop SOP for inspecting
Town maintained
conveyances in FY21.
O&M program for
stormwater sewer system
evaluated and updated?
(Yes/No/Status)

Document and report any
inspection issues, when
maintenance is performed
and how many inlets on
each street are inspected.
Records to include date of
inspection, inspector, and
linear footage of
inspections/maintenance.

SOP developed for
stormwater sewer system?
(Yes/No/Status)

g. Identify and
map
municipally
owned or
maintained
structural
stormwater
controls
Identify and map
municipally-owned or
operated structural
stormwater controls.
Inventory and mapping of
SCMs at all facilities (within
Town corporate limits)
completed in FY21.

Review inventory annually
and update as needed.

Inventory and mapping of
SCMs completed?
(Yes/No/Status)

Inventory reviewed
annually and as needed?
(Yes/No/Status)

h. O&M for
municipally-
owned or
maintained
structural
stormwater
controls
Maintain and implement,
assess annually and update
as necessary an O&M
program for municipally-
owned or maintained
structural stormwater
controls.

Document inspections and
maintenance of all
municipally-owned or
maintained structural
stormwater controls.

O&M program for
municipal SCMs will be
completed and
implemented in FY21.

Document inspections and
maintenance required
annually for each facility.

O&M program for
municipal SCMs completed
and implemented?
(Yes/No/Status)

All facilities inspected?
(Yes/No/Status)

Document and report
number of inspections and
maintenance actions
needed.

Maintenance actions
completed according to

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BMP Measurable Goals Schedule for
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Annual Reporting Metric
inspection report?
(Yes/No/Status)

Document and report
maintenance actions
performed.

i. Pesticide,
Herbicide and
Fertilizer
Application
Management.
Ensure municipal employees
and contractors are properly
trained and all permits,
certifications, and other
measures for applicators are
followed.

Annually Certification for all
municipal employees and
contractors are
documented?
(Yes/No/Status)

Document number of staff
members with active
certification.

j. Staff training Implement an employee
training program for
employees involved in
implementing pollution
prevention and good
housekeeping practices.

Training program for all
employees developed and
implemented in FY21.

Continuously document
and report annually.

(See also IDDE BMP (f)
above)

Training program
developed and
implemented?
(Yes/No/Status)

Document and report who
is trained, number of staff
trained, training dates, and
topics covered.

k. Prevent or
minimize
contamination
of stormwater
runoff from all
areas used for
vehicle and
equipment
cleaning
Describe measures that
prevent or minimize
contamination of the
stormwater runoff from all
areas used for vehicle and
equipment cleaning.

SWPPP developed in FY21
for all fire stations where
vehicle washing takes
place.

(See also PPGH BMP (j)
above)
SWPPP developed in FY21?
(Yes/No/Status)

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19 REFERENCES
Jewell Engineering Consultants, PC. 2008. Town of Chapel Hill Stormwater Management Program Master
Plan – Phase I Report. Prepared for the Town of Chapel Hill, NC. October 2008. Available online:
https://www.townofchapelhill.org/government/departments-services/public-works/stormwater-
management/stormwater-management-utility
Jewell Engineering Consultants, PC. 2014. Town of Chapel Hill Stormwater Management Program Master
Plan – Phase II Final Report. Prepared for the Town of Chapel Hill, NC. Adopted by Town Council on
September 29, 2014. Available online: https://www.townofchapelhill.org/government/departments-
services/public-works/stormwater-management/stormwater-management-utility
NCDWR. 2018. North Carolina Final Integrated Report & Section 303(d) List. North Carolina Division of
Water Resources (NCDWR), Raleigh, North Carolina. Available online:
https://deq.nc.gov/about/divisions/water-resources/planning/modeling-assessment/water-quality-
data-assessment/integrated-report-files.
NCOSBM. 2019. 2019 Municipal Estimates. North Carolina Office of State Budget and Management,
Raleigh, NC. Available online: https://www.osbm.nc.gov/demog/municipal-estimates)
Town of Chapel Hill. 2007. 2007 Data Book – Land Use and Development Trends. Town of Chapel Hill,
NC. Available online: http://www.townofchapelhill.org/home/showdocument?id=1276.
Town of Chapel Hill. 2010. 2010 Data Book - Demographics. Town of Chapel Hill, NC. Available online:
http://www.townofchapelhill.org/home/showdocument?id=10030.
Town of Chapel Hill. 2011a. Spill Prevention Control and Countermeasure Plan (SPCCP) for the Town of
Chapel Hill Town Operations Center, Public Works Complex and Transit Facility. August 2011.
Town of Chapel Hill. 2011b. Stormwater Pollution Prevention Plan (SPPP) for the Town of Chapel Hill Town
Operations Center, Public Works Complex and Transit Facility. August 2011.
Town of Chapel Hill. 2012. Chapel Hill 2020 Land Use Plan – Land Use Categories Map and Data. Town
of Chapel Hill Planning Department. Adopted by Town Council on June 25, 2012. Available online:
http://www.townofchapelhill.org/home/showdocument?id=1215.
Town of Chapel Hill. 2013. Town of Chapel Hill Site Assessments of Town Facilities. Town of Chapel Hill
Public Works Department, Stormwater Management Division. July 2013.
U.S. Census Bureau. Census 2000 – Town of Chapel Hill Data. Available online:
http://www.townofchapelhill.org/home/showdocument?id=1238.
U.S. Census Bureau. Census 2010 – Town of Chapel Hill Data. Available online:
http://www.census.gov/quickfacts/table/PST045215/3711800

W.K. Dickson. 2018. Town of Chapel Hill Lower Booker Creek Subwatershed Study, September 2018.
Prepared for the Town of Chapel Hill. Available online: http://bookercreekplan.org/.

Town of Chapel Hill Stormwater Management Plan
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February 2021

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W.K. Dickson. 2020. Town of Chapel Hill Eastwood Lake Subwatershed Study, June 2020 draft. Prepared
for the Town of Chapel Hill. Available online: http://bookercreekplan.org/.