NCS000248_Greensboro Audit NOC_20220810

COOPERROY
Governvr
I RETV S. BISM
BRIANWRENN
August 10, 2022
CERTIFIED MAIL 7019 1120 0002 0066 3330
RETURN RECEIPT REQUESTED
City of Greensboro
Attn: David Phlegar, Stormwater Manager
Department of Water Resources
PO Box 3136
Greensboro, NC 27402-3136
Subject: NOTICE OF COMPLIANCE
City of Greensboro
NPDES MS4 Permit No. NCS000248
Guilford County
Dear Mr. Phlegar:
On June 7, 2022, staff from the North Carolina Department of Environmental Quality (DEQ) conducted a
compliance audit of subject National Pollutant Discharge Elimination System (NPDES) Municipal Separate
Storm Sewer System (MS4) Permit. For your reference, a copy of the MS4 Program Audit Report issued by
DEQ is enclosed with this notice.
In accordance with Part VI of the permit and DEQ policy, a new 5-year MS4 permit will be issued in response
to the audit. As such, the Town is required to complete the following actions:
(1) Respond in writing within thirty (30) calendar days from the date of receipt of this notice to
acknowledge these requirements and the intent to comply.
(2) Submit documentation for review and comment within one hundred twenty (120) calendar days
from the date of receipt of this letter:
a. Develop a Draft Stormwater Management Plan (SWMP) which details specific actions,
measurable goals, and implementation timelines to bring the stormwater management
program into compliance with NPDES MS4 requirements over the new 5-year permit term.
The SWMP must address all known compliance deficiencies including, at a minimum, any
items detailed in the DEQ MS4 Program Audit Report and the City self -audit.
(3) Submit an NPDES MS4 permit application within thirty (30) days of receiving written DEQ
concurrence that the submitted Draft SWMP documents a compliant stormwater management
program. A new 5-year NPDES MS4 permit will be public noticed along with the submitted SWMP.
(4) Respond to public comments on the Draft SWMP and submit a Final SWMP for DEQ approval and
final permit issuance. The final DEQ-approved SWMP shall become an enforceable component of
the NPDES MS4 permit.
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Required documentation shall be submitted via e-mail to Vaul.clark(a ncdenr.g-ov, or to:
DEQ-DEMLR Stormwater Program
Attn: Paul Clark
1612 Mail Service Center
Raleigh, NC 27699-1612
If the City fails to meet the aforementioned requirements and/or submits a significantly noncompliant Draft
SWMP, DEQ may proceed with enforcement. As is stated in Part V, Section A.1(c) of the permit:
Understate law, a daily civil penalty of not more than twenty-five thousand dollars ($25,000) per
violation may be assessed against any person who violates orfails to act in accordance with the terms,
conditions, or requirements of a permit [North Carolina General Statute 143-215.6A]. Please note that
compliance with the requirements of this NOD and/or issuance of civil or criminal penalties levied by
DEQ does not preclude the EPA from carrying out its own enforcement case against the permittee.
Thank you for your attention to this matter. Should you have any questions, please contact me at (919) 707-
3642 or, paul.clark6tricderingov.
Sincerely, L�_�'
�X/
Paul Clark
Water Supply Watershed Protection Coordinator
Division of Energy, Mineral and Land Resources
Enclosures: DEQ MS4 Permit Compliance Audit Report
CC:
Virginia Spillman, Assistant Director, Water Resources
[e-mail], DEMLR Interim MS4 Program Coordinator
DEMLR NPDES MS4 Permit Laserfiche File