NCS000441_MS4 AUDIT REPORT_20210630

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000441
THE UNIVERSITY OF NORTH CAROLINA AT CHAPEL HILL
Audit Date: June 16, 2021
Report Date: June 28, 2021
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 9th floor
1612 Mail Service Center
Raleigh, NC 27699-1612

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NCS000441 UNC-CH MS4 Audit 20210616

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................4
Program Implementation, Documentation & Assessment...........................................................................5
Illicit Discharge Detection and Elimination (IDDE)........................................................................................7
Post -Construction Site Runoff Controls......................................................................................................10
Pollution Prevention and Good Housekeeping for Municipal Operations..................................................13
Site Visit Evaluation: Municipal Facility No. 1.............................................................................................17
Site Visit Evaluation: MS4 Outfall No. 1......................................................................................................19
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................21
Appendix A: Supporting Documents
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000441 UNC-CH MS4 Audit 20210616 ii

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NCS000441 UNC-CH MS4 Audit 20210616 iii

Audit Details
Audit ID Number:
Audit Date(s):
NCS000441—UNC-CH MS4 Audit_20210616
June 16, 2021
Minimum Control Measures Evaluated:
© Program Implementation, Documentation & Assessment
❑ Public Education & Outreach
❑ Public Involvement & Participation
® Illicit Discharge Detection & Elimination
❑ Construction Site Runoff Controls — No delegated Sediment and Erosion Control Program
❑ Construction Site Runoff Controls — Delegated Sediment and Erosion Control Program
® Post -Construction Site Runoff Controls
® Pollution Prevention and Good Housekeeping for Municipal Operations
❑ Total Maximum Daily Loads (TMDLs)
Field Site Visits:
® Municipal Facilities. Number visited: 1
® MS4 Outfalls. Number visited: 1
❑ Construction Sites. Number visited: Choose are Item.
® Post -Construction Stormwater Runoff Controls. Number visited: 1
❑ Other: Number visited: Choose an item.
❑ Other: Number visited: Choose are item.
Inspector(s) Conducting Audit
Name, Title
Organization
Alaina Marman, Environmental Specialist
NC DEQ
Audit Report Author:
Date:
rt
Signature V 16(y (J-
NCS000441_UNC-CH MS4 Audit_20210616 Page 1 of 23

Permittee Information
MS4 Permittee Name:
The University of North Carolina at Chapel Hill
Permit Effective Date:
October 10, 2018
Permit Expiration Date:
October 9, 2023
Mailing Address:
305 South Building, Campus Box 1000
Date of Last MS4 Inspection/Audit:
April 25, 2018
Co-permittee(s), if applicable:
N/A
Permit Owner of Record:
George Battle, III, Vice Chancellor
Primary MS4 Representatives Participating in Audit
Name
Title, Organization
Catherine Brennan
UNC-CH Executive Director — EHS
Sally Hoyt
UNC-CH Stormwater Utility Manager
Jamie Smedsmo
UNC-CH Water Resources Engineer
Sharon Myers
UNC-CH Environmental Compliance Officer
Janet Clarke
UNC-CH Stormwater Specialist
Robert Bradley
UNC-CH Stormwater Supervisor — Grounds Services
MS4 Receiving Waters
Waterbody
Classification
Impairments
Morgan Creek
WS-II; WS-IV; WS-V; HQW;
NSW; CA
(depending on segment)
Total Nitrogen; Total Phosphorus;
Chlorophyll a
Phils Creek
WS-II; HOW; NSW; CA
N/A
Price Creek
WS-11; HQW; NSW; CA
N/A
Pritchards Mill Creek
WS-II; HQW; NSW; CA
N/A
Chapel Creek
WS-IV; NSW
N/A
Meeting of the Waters
WS- IV; NSW
N/A
Bolin Creek
WS-IV; WS-V; NSW
N/A
Booker Creek
WS-IV; WS-V, B; NSW
N/A
Crow Branch
B; NSW
N/A
NCS000441—UNC-CH MS4 Audit20210616 Page 2 of 23

Jolly Branch
NSW
N/A
t&'f�Y(S-.V;
c\�[
S-jlVyjyS(V[`.7�k,�JY
-j,�
3 anbark Branch
Tanbark
\L`jY
V S-V; fY..JYV
N/A
N/A
Wilson Creels
WS-IV; NSW
N/A
Collins Creek
WS-V; NSW
benthos (Nar, AL, FW)
BCigUe Sound
SA; HC �+V
Some areas have restrictions or
prohibitions from shellfish grooving
NCS000441_UNC-CH MS4 Audit_20210616 Page 3 of 23

List of Supporting Documents
Item
Number
Docu ment Ti#le
When Provided
(Prior to/During/After)
01
2021 Draft Stormwater Management Plan
Prier
02
IDDE Standard Operating Procedure (5/4/2021)
Prior
03
IDDE Policy (3/18/2021)
Prior
04
EHS Hazmat Spill Response Map
Prior
05
Stormwater Infrastructure Inspection and Maintenance Manual (5/3/2021)
Prior
06
Stormwater Performance Criteria, Design Standards, and Procedures
(8/20/2010)
Prior
07
Fee Payment History
Prior
08
Fd€iration and Outrpach Plan
During
09
Stormwater Plan Review and Construction Tracking SCUP
During
10
instructions for Looking Up Information on Illicit Discharges in ArcMap
During
11
Instructions for Entering Cutlet and Inlet Inspections into ArcMap
During
12
Hazardous Incident report
During
13
Outdoor Incidents & Spills Response SOP
During
14
Public Pesticide Operator License (staff example)
During
15
Industrial Facility Inspection Report
During
16
Catch Basin Inspection List
During
17
List of Inspected Facilities
During
18
Post -Construction SCM Approval Letter
During
19
Internal Post -Construction Plan Review Checklist
During
20
SCM Inventory as of 2021-06-11
During
NCS000441_UNC-CH MS4 Audit_20210616 Page 4 of 23

Program Implementation, Documentation & Assessment
Staff Interviewed:
Catherine Brennan, Sally Hoyt, Jamie Smedsmo, Sharon Myers, Janet Clarke
Permit Citation
Program Requirement Status supporting
Doc No.
VII
The permittee is current on payment of invoiced administering and compliance
Annual Permit Fee
monitoring fees. Yes 0
Comments
111.2
The permittee reviewed and updated the SWMP as necessary but at least on an
SWMP Evaluation
annual basis.
Partial
---
Comments
The SWMP was updated in 2018 as part of the permit renewal process, and the version submitted in response to the MS4 audit
request is dated March 25, 2021. There is nothing in the SWMP verifying that it was reviewed annually.
II.A.8 and 111.3
Stormwater Plan
Did the permittee submit proposed modifications to DEMLR for approval?
No
---
Modifications
If yes, did the permittee complete the modifications in accordance with the
Not
established deadline?
Applicable
Comments
II.A.9
Sharing
Are any control measures implemented by an entity other than the permittee?
Yes
---
Responsibility
If yes, is there a written agreement in place?
Not
---
Applicable
Comments
The state Sediment program is responsible for E&SC permitting for anything over an acre of disturbance. However, all E&SC plans
are reviewed and approved by EHS (Janet) before they are allowed to be submitted to the state for the final Letter of Approval. The
permittee also has a smaller threshold that triggers an internal process. All the information for the E&SC program can be found
here: https://ehs.unc.edu/stormwater/design-requirements/. A particularly helpful resource is the Requirements Flowchart.
II.A.10
The permittee maintained written procedures for implementing the six minimum
03, 05,
Written
control measures.
Yes
08,09
Procedures
Written procedures identified specific action steps, schedules, resources and
responsibilities for implementing the six minimum measures.
Partial
---
NCS000441_UNC-CH MS4 Audit_20210616 Page 5 of 23

Program Implementation, Documentation & Assessment
Comments
The Public Education and Outreach and Public Involvement and Participation MCMs have plans instead of SOPS. The SOPS and plans
contain a good amount of detail, but there are places where specifics would be helpful, especially for anyone stepping into a role
for the first time. For example: what is the timeframe for entering illicit discharges in the EHS HASMIS database and in GIS? Another
example: PP&GH training for staff is provided on a recurring basis, but how frequent is "recurring?" During the audit it was noted
that some portions of Staff training are provided only when new staff have joined the group. This should be noted in the written
procedure for the particular MCM under which the training is covered.
1111
The permittee maintained documentation of all program components including, but
ProProgram
g
not limited to, inspections, maintenance activities, educational programs,
yes
1S'
Documentation
implementation of BMPs, enforcement actions etc., on file for a period of five years.
16
Comments
111.2
The Annual Reports included appropriate information to accurately describe the progress, status, and results
Annual Report
of the permittee's Stormwater Plan, including, but not limited the following:
Submissions
a) A detailed description of the status of implementation of the Stormwater Plan
as a whole. This will include information on development and implementation
of each major component of the Stormwater Plan for the past year and
Yes
---
schedules and plans for the year following each report.
b) An adequate description and justification of any proposed changes to the
Stormwater Plan. This will include descriptions and supporting information for
the proposed changes and how these changes will impact the Stormwater
Yes
--
Plan (results, effectiveness, implementation schedule, etc.).
c) Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater
yes
---
Plan.
d) A summary of data accumulated as part of the Stormwater Plan throughout
the year along with an assessment of what the data indicates in light of the
yes
---
Stormwater Plan.
e) Information on the annual expenditures and budget anticipated for the year
following each report, along with an assessment of the continued financial
yes
---
support for the overall SWMP.
f) A summary of activities undertaken as part of the SWMP throughout the year.
This will include project assessments, inspections, continued inventory and
review of the storm sewer system, education, training, and IDDE program
Yes
---
results.
Comments
The permittee submitted annual BIMS SWMPAs during the permit term. SWMPAs can be viewed at:
https://edocs.deq.nc.gov/WaterResiiu rues/Browse.aspx?d bid=O&startid=715819.
Additional
Comments:
NCS000441_UNC-CH MS4 Audit_20210616 Page 6 of 23

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed:
Sally Hoyt, Jamie Smedsmo, Sharon Myers, Janet Clarke
Permit Citation
Program Requirement Status
supporting
DOc No.
II.D.2.a
The permittee maintained an IDDE Policy that includes illicit detection, right of entry,
IDDE Program
and prohibition of illicit discharges. yes
02,03
If yes, the policy includes procedures for routine inspection, sampling, and
maintenance of outfalls; detection and elimination of illicit discharges, spills, and
Yes
illegal dumping; reporting and recordkeeping; training and development; and
03
implementation of BMPs.
Comments
II.D.2.b
The permittee maintained fact sheets for public education on illicit connections and
Educational
spill management.
yes
08
Information
If yes, the fact sheets were distributed to University and Hospital maintenance
personnel and contractors.
'yes
0
The permittee maintained written guidelines and/or fact sheets that include
information on what constitutes an illicit discharge, University contacts, and how to
Yes
0
report suspect activities.
If yes, the guidelines/fact sheets were distributed to the campus population as
part of the education and outreach program.
Yes
0
Comments
Informational fact sheets are available here. https://ehs.unc.edu/stormwater/pollution-prevention/..
General IDDE information is available here: https:Hehs.unc.edu/stormwater/program/illicit-discharge-detection-and-elimination/.
There is an approval process that anyone wanting to use any outdoor space for any activity must go through, and part of that
approval process is coordination with EHS staff (Janet) to eliminate potential illicit discharges.
II.D.2.c
The permittee trained employees on how to inspect for illicit connections and
03, 04,
Training
established a tracking system for managing reported problem areas.
yes
08,10
NCS000441_UNC-CH MS4 Audit_20210616 Page 7 of 23

Illicit Discharge Detection and Elimination (IDDE)
Comments
EHS (Janet) provides general Stormwater Awareness Training (45 minutes and there is an online version)
0 Approximately every 3 years for target groups (facilities, restaurants...)
EHS (Sharon) provides annual SWPPP training for the Hazardous Materials Facility (HMF) staff responsible for that individual
industrial Stormwater permit. Annual training is also provided for service station staff and for medical air operations staff at RDU.
HASMIS also has a training database which records training completed by campus employees. For private, off -campus groups there
is a sign -in sheet that Janet then keeps in the Stormwater notebook.
The permittee's Preventative Maintenance Program also has an IDDE training component for grounds staff because they do the
annual inspections of outfalls and SCMs.
HASMIS is the incident tracking system. Additionally, there is an illicit discharge layer in ArcGIS that EHS updates periodically and is
used by the Emergency response Team to trace the path of an illicit discharge.
II.D.2.d
The permittee conducted dry weather flow field observations for at least 1/5 of the
Detection and
jurisdictional area per year.
yes
01,03
Elimination
The permittee maintained a database of outfalls, inspection date, tests conducted,
findings, and actions taken.
yes
11
The permittee maintained a standard reporting format and contact for all complaints
and reports of illicit discharges.
Yes
12
Comments
Grounds Services conducts visual screenings of outfalls as part of annual preventative maintenance. Additionally, EHS (Janet) does
dry weather field flow inspections. If Grounds Services staff see a flow or anything odd, they immediately call it in and it becomes a
spill response.
II.D.2.e
The permittee maintained a storm sewer system map showing outfalls and receiving
Storm Sewer
waterbody.
yes
---
System Mapping
The permittee conducted visual inspections of the storm sewer system including
outfalls and existing components of the drainage system in an effort to maintain an
Yes
CAS, 16
inventory of drainage structures and storm sewer system maps.
The permittee categorized outfalls by the receiving water to which the outfall
discharges.
Yes
___
Outfall information maintained included location, reference number, size and
type of structure, apparent condition of structure, and dry -weather flow.
Yes
---
Comments
The storm sewer system map is in ArcGIS and was viewed during the audit. Location, reference number, size, type, and condition of
Structure and the existence of dry -weather flow are recorded for each outfall. An example of the information contained in ArcGIS
can be seen in supporting document 11. More information about the storm sewer system mapping can be found at:
https:Hehs. u nc. edu/stormwater/program/stormwater-system-mapping/.
II.D.2.f
The permittee used the EHS hotline set up under the Public Involvement
Hotline
Program for public reporting of illicit connections.
yes
02
NCS000441_UNC-CH MS4 Audit_20210616 Page 8 of 23

Illicit Discharge Detection and Elimination (IDDE)
The permittee maintained a log of hotline calls and actions taken.
Yes
02,1€I
Comments
EFIS has a hotline, email address, and electronic reporting form for reporting illicit discharges (or anything stormwater related),
which can be found here: https:Hehs.unc.edu/stormwater/report-a-problem/. Anyone can also call 911 and those calls get routed
through campus police who then contact EHS staff.
II.13.2.
The permittee maintained a written spill/dumping response procedure and a flow
Spill Response
chart or phone tree, or similar list for internal use, that shows the procedures for
Procedure
responding to public reports of illicit discharges, the various responsible agencies and
Yes
02' 1
their contacts, and who would be involved in illicit discharge incidence response.
Comments
Additional
Comments:
NCS000441_UNC-CH MS4 Audit_20210616 Page 9 of 23

Post -Construction Site Runoff Controls
Staff Interviewed:
Sally Hoyt, Jamie Smedsmo, Sharon Myers, Janet Clarke
Implementation (check all that apply):
© The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure:
❑ The permittee implements the following deemed -compliant program(s), which meet NPDES MS4 post -construction
requirements for the areas where implemented and in compliance with the specific program requirements as provided in 15A
NCAC and noted below (Complete Session Law 2006-246 section below):
❑ Water Supply Watershed I (WS-1) — 15A NCAC 26 .0212
❑ Water Supply Watershed II (WS-II) — 15A NCAC 213.0214
❑ Water Supply Watershed III (WS-III) — 15A NCAC 213.0215
❑ Water Supply Watershed IV (WS-IV) —15A NCAC 26 .0216
❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 213.0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258
❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy — 15A NCAC 213 .0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Ordinance(s) (check all that apply):
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements throughout the MS4 permitted area (check all that apply):
❑ DEQ model ordinance
❑X MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000.
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved ordinance for a deemed -compliant Program (see list above)
Permit Citation Program Requirement Status Supporting
Doc No.
The permittee maintained standards and policies for post -construction SCMs for
Yes 0£
development or the redevelopment of University properties.
NCS000441—UNC-CH MS4 Audit_20210616 Page 10 of 23

Post -Construction Site Runoff Controls
I I. F.2.a
Standards and
Policies on SCMs for
The permittee's SCM requirements are at least as stringent as the minimum
Post -Construction
requirements in 15A NCAC 02H .1000.
Yes
06
Controls
Comments
The state's Stormwater Design Manual is cited, but the permittee also has some standards that are more stringent.
II.F.2.b
Plan Reviews
The permittee conducts site plan reviews of new development and redevelopment
06, 0,
projects to ensure compliance with University standards.
yes
19
Comments
Energy Services reviews plans for compliance with UNC-CH standards and Chapel Hill standards.
Marine Institute has two SCMs permitted through the state. If any development takes place, Energy Services would review the
plans to the standards outlined in the Coastal stormwater rules, or whatever rules apply specifically to that area.
II.F.2.c
The permittee conducted post -construction inspections before closing out
Field Inspections
construction projects to verify that the performance standards have been met.
yes
06,18
Comments
Energy Services (Jamie and Sally) observes the SCM throughout the construction process and take pictures as needed.
New practices being implemented on all new projects: 1) design engineers must submit SCM certifications, and 2) Energy Services is
issuing close -taut letters.
II.F.2.d
Maintenance and
The permittee developed and implemented a maintenance and inspection program
Inspection Program
for post -construction structural controls.
Yes
05
Comments
II.F.2.e
Inventory
The permittee developed and maintained an inventory of all University post-
yes
20
construction SCMs.
Comments
When looking at the inventory, the Storm ID is the unique identifier.
11.F.3
The permittee implemented the Jordan Lake Nutrient Strategy for projects within
Jordan Lake Nutrient
yes
00
the Jordan Lake watershed in accordance with 15A NCAC 02B .0271.
Strategy
NCS000441_UNC-CH MS4 Audit_20210616 Page 11 of 23

Post -Construction Site Runoff Controls
Comments
II.F.4
The permittee ensured that the water quality design volumes of SCMs take into
Design Volume
account the runoff at build out from all surfaces draining to the system.
Yes
€i
Comments
This is a requirement in the states Design Manual --Chapter C-0. Minimum Design Criteria for all SCMs. This requirement is also in
the contractual language of the designers.
Additional
Comments:
NCS000441_UNC-CH MS4 Audit_20210616 Page 12 of 23

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Sally Hoyt, Jamie Smedsmo, Sharon Myers, Janet Clarke, Robert Bradley
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.G.2.a
The permittee maintained material storage procedures that include provision of
Spill Prevention and
secondary containment; development of spill prevention, containment, and control
Response
plans and/or safety plans; and preferred sheltering of all chemicals and other
Yes
---
hazardous substances.
The permittee provided recurring spill training to employees.
Yes
08,13
If yes, the training covered proper handling procedures and emergency actions.
Yes
08,13
Comments
Most of the secondary containment is at the HMi- site and then there is secondary containment associated with diesel storage for
generators throughout Campus. The Generator Shop inspects secondary containment for diesel storage. They receive
spill/stormwater training through the SPCC training which is an online training recorded through HASMIS.
The permittee's Spill Prevention Control and Countermeasure Plan is accessible here: https://ehs.unc.edu/environmental/spcc/.
II.G.2.b
The permittee provided recurring training to all employees (University and
Employee Training
Hospital) who maintain the drainage system.
Yes
0
If yes, the training focused on floatable, grit, sediment, and disposal of
pollutants removed from the drainage system.
Yes
08
The permittee provided recurring training to all employees (University and
Hospital) who manage and apply chemicals.
es
08
If yes, the training addressed safe storage, application, and disposal of residue
chemicals.
Yes
08
The permittee provided information on reducing the frequency and amount of
nutrient application.
Yes
08
Comments
The hospital has its own 6HS department that does its own hazardous waste and chemical training.
General training/educational materials can be found here: https:Hehs.unc.edu/stormwater/pollution-prevention/landscape-
maintenance/.
II.G.2.c
The permittee performed visual inspections of the University's storm sewer system
OS, 6,
Visual Inspections
including drains, inlets, and outfalls.
Yes
11
NCS000441_UNC-CH MS4 Audit_20210616 Page 13 of 23

Pollution Prevention and Good Housekeeping for Municipal Operations
The permittee conducted inspections to identify areas where exposures have the
potential to introduce hazardous pollutants to the storm sewer system.
Yes
05
Comments
II.G.2.e
The permittee performed inlet and catch basin cleaning, pipe cleaning, curbside
Storm Sewer System
leaf removal, parking lot and road sweeping, and planting and mulching of erosion
Yes
05,16
Maintenance
prone areas.
Comments
n supporting document 1.6, each line item is an inlet that's been inspected and cleaned. More information about storm sewer
system maintenance can be round here: https://ehs.unc.edu/stormwater/program/stormwater-maintenance/.
II.G.2.f
The permittee maintained an inventory of all facilities and operations owned and
Inspection and
operated by the University with the potential for generating polluted stormwater
yes
17,20
Evaluation of
runoff.
Facilities and
Operations
The permittee conducted recurring inspections of the facilities and operations.
'yes
15
If yes, the inspections include sources of polluted runoff, stormwater controls,
and conveyance systems.
yes
15
The permittee documented deficiencies and planned, implemented, and
documented corrective actions.
Yes
15
Comments
II.G.2.g
The permittee evaluated the non-structural BMPs within each department and
BMP Inspection and
organization on an annual basis and implemented more stringent BMPs as needed.
Yes
___
Maintenance
The permittee maintained and implemented a program for inspection, operation,
and maintenance of post -construction SCMs.
Yes
05
If yes, the program included written procedures detailing: inspection and
maintenance requirements for the proper operation of the various types of SCM
devices, frequency of inspections, "how-to" instructions for maintenance, and an
fifes
05
inspection and maintenance tracking mechanism.
Comments
Grounds Services supervisors and crew leaders all receive the Stormwater SCM Inspection and Maintenance Certification through
C State University.
NCS000441_UNC-CH MS4 Audit_20210616 Page 14 of 23

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.h
The permittee maintained an inventory of University facilities covered under an
Industrial NPDES
NPDES industrial stormwater permit.
yes
17
Facilities
The permittee annually inspected University facilities covered under an NPDES
industrial stormwater permit.
Yes
1a
Comments
II.G.2.i
The permittee evaluated the materials used and activities performed on parks, golf
Pesticide, Herbicide
courses, easements, right of ways, and other open spaces for pollution prevention
yes
---
and Fertilizer
opportunities.
Application
The permittee ensured employees are properly trained in pesticide, herbicide and
Management
fertilizer application management.
Partial
14
The permittee ensured contractors are properly trained in pesticide, herbicide and
fertilizer application management.
Partial
__
The permittee ensured all permits, certifications, and other measures for
applicators are followed.
Partial
Comments
The stormwater supervisor of Grounds Services explained that the university's overarching goal is to always use the most effective,
lowest risk product. One way they do this is by having an Integrated Pest Management Plan. Before any product is chosen, Grounds
Services identifies the pest, researches the pest, and looks at what the acceptable infestation level is for the particular location.
hey also consult the NC Agricultural Chemicals Manual. Once a product is chosen; Grounds Services staff follow the guidance on
the product label and any industry standards. When working with fertilizers, Grounds Services looks at the turf type and location
and visibility of the area they are considering treating. They implement industry accepted practices and regularly consult the NC
Skate Extension TurfFiles.
Grounds Services maintains most property, but the Athletics Department maintains some as well. Currently, the Athletics
Department is not included in the stormwater training.
The Carolina Inn, the hospital, the Rizzo Center, and the SECU Family House use private contractors. Currently, the permittee is not
verifying if private contractors and their employees are certified.
More information on pollution prevention for landscape maintenance can be -found here:
https://ehs.unc.edu/stormwater/pollution-prevention/landscape-maintenance/.
II.G.2.i
The permittee described and implemented measures that prevent or minimize
Vehicle and
contamination of stormwater runoff from all areas used for vehicle and equipment
Yes
---
Equipment Cleaning
cleaning.
Comments
There is a vehicle wash bay at the service station which is where university vehicles are supposed to be cleaned. Public Safety
Officers are included in the stormwater awareness training.
More information on pollution prevention for vehicles can be found here: https:Hehs.unc.edu/stormwater/pollution-
prevention/vehicles/.
NCS000441_UNC-CH MS4 Audit_20210616 Page 15 of 23

Pollution Prevention and Good Housekeeping for Municipal Operations
Additional
Comments:
Items to address:
1) Stormwater training needs to be provided to the Athletics Department staff.
2) The credentials of private contractors applying pesticides and herbicides need to be verified, or the
per ittee needs to come up with an alternative way to ensure contractors are properly trained in pesticide,
herbicide and fertilizer application management.
NCS000441_UNC-CH MS4 Audit_20210616 Page 16 of 23

Site Visit Evaluation: Municipal Facility No. 1
Facility Name:
UNC-CH Hazardous Materials Facility
Date and Time of Site Visit:
June 16, 2021 at'-2.45 PM
Facility Address:
1120 Estes Drive
Facility Type (Vehicle Maintenance, Landscaping, etc.):
facility that receives and stores hazardous waste
Name of MS4 inspector(s) evaluated:
Sharon Myers
Most Recent MS4 Inspection (List date and name of inspector):
December 18, 2020 by Sharon Myers
Name(s) and Title(s) of Facility Representative(s) Present During the Site Visit:
Name
Title
Sally Hoyt
UNC-CH Stormwater Utility Manager
Janet Clarke
UNC-CH Stormwater Specialist
ramie Smedsmo
UNC-CH Water Resources Engineer
Observations
Facility Documentation/Training
Does the facility have a Stormwater Pollution Prevention Plan (SWPPP) or similar document? Is it facility -specific?
Yes. The SWPPP is specific to the HMF.
What type of stormwater training do facility employees receive? How often?
The employees receive annual SWPPP training.
Inspector Training/Knowledge
What type of stormwater training does the M54 inspector receive? How often?
The inspector is the environmental compliance officer for UNC-CH and has worked in the stormwater field since 1998.
Did the MS4 inspector appear knowledgeable about Permit requirements for pollution prevention and good housekeeping?
Yes.
Did the MS4 inspector appear knowledgeable about stormwater pollution prevention and good housekeeping?
Yes.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form?
No checklist or standardized form was used. The inspector walks the same route each inspection and carries a notepad to record
any issues.
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Site Visit Evaluation: Municipal Facility No. 1
Does the MS4 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the facility's SWPPP (or similar document)?
Yes.
Does the MS4 inspector's process include walking the entire facility and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious areas of concern? If so, explain:
No obvious areas of concern were missed. There were some metal pipes being stores outside that ideally should be covered, but
there were not many of them.
Does the MS4 inspector's process include presenting the inspection findings to the facility contact?
Yes. See supporting document 15.
Inspection Results
Did the facility inspection result in any corrective actions to be Implemented? If so, for what Issue(s)?
No.
If compliance corrective actions were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
i he HIVIF is the facility covered under the individual industrial stormwater permit, but Sharon extends her "facility inspection" to
include the surrounding buildings and activities (see supporting document 15 for all areas inspected). This is above and beyond
what is required and DEQ applauds the standard she has set. Her efforts have paid off because each area we inspected was well
maintained and orderly.
NCS000441_UNC-CH MS4 Audit_20210616 Page 18 of 23

Site Visit Evaluation: MS4 Outfall No. 1
Outfall ID Number:
Date and Time of Site Visit:
221-8-028
.tune 16, 2021 at '-4:00 PM
Outfall Location:
Outfall Description (Pipe Material/Diameter, Culvert, etc.):
behind the Boshamer Parking lot
84" RCP
Receiving Water:
Is Flow Present? If So, Describe (Color, Approximate Flow Rate,
Meeting of the Waters
Sheen, Odor, Floatables/Debris, etc.):
Yes, flow present —most likely groundwater.
Most Recent Outfall Inspection/Screening (Date):
Visual inspection on .tune 4, 2021
Days Since Last Rainfall:
Inches:
June 11, 2.021- S days
0.3"
Name of MS4 Inspector(s) evaluated:
Janet Clarke.
Observations
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
The inspector is the stormwate r specialist in EHS and has 20+ years of environmental compliance experience. She also has the
Stormwater SCM Inspection and Maintenance Certification through NC State University, Her certification number is 1579.
Did the MS4 inspector appear knowledgeable about illicit discharge indicators and investigations?
Yes.
Inspection Procedures
Does the inspector's process include the use of a checklist or other standardized form?
Yes. The GIS form asks all the standard visual duality questions. There are paper forms for interns.
Does the inspector's process include taking photos?
Ye. The first thing the inspector does is take a photo. if there is turbidity present, and active construction activity upstream, the
inspector sends the photo to the construction manager while at the outfall and will call to discuss needed corrections.
Did the MS4 inspector miss any obvious potential illicit discharge indicators or maintenance issues? If so, what were they?
No,
NCS000441_UNC-CH MS4 Audit_20210616 Page 19 of 23

Site Visit Evaluation: MS4 Outfall No. 1
Inspection Results
Did the outfall inspection result in any work orders or maintenance requests? If so, for what issue(s)?
o.
Will a follow-up outfall inspection be conducted? If so, for what reason?
No, a follow-up inspection is not needed.
Notes/Comments/Recommendations
Fart of outf<fll inspections involves sampling the water using a Horiba Water Quality Meter which monitors multiple parameters at
once. The meter's pH readings have been off lately, so a paper pH strip was used to verify the results. I was impressed with Janet's
IDDE knowledge and overall inspection process.
(Thank you, Janet, for showing me how the meter works — very cool')
NCS000441_UNC-CH MS4 Audit_20210616 Page 20 of 23

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
EHS Building
Date and Time of Site Visit:
June 16, 2021 at —2:00 PM
Site Address:
1120 Estes Drive
SCM Type:
Hydrodynamic Separator
Most Recent MS4 Inspection: April 1, 2021
Name of MS4 Inspector(s) evaluated:
Robert Bradley
Most Recent MS4 Enforcement Activity:
N/A
Name(s) and Title(s) of Site Representative(s) Present During the
Site Visit:
Name
Title
Sally Hoyt
UNC-CH Stormwater Utility Manager
Sharon Myers
UNC-CH Environmental Compliance Officer
Janet Clarice
UNC-CH Stormwater Specialist
Ja;-i!e Srned mo
iJNC-CH l Eater P.sources Engineer
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Yes.
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, this SCM is inspected quarterly and there are records of each inspection,
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
1'he inspector is the stormwater supervisor of Grounds Services. He has the Stormwater SCM inspection and Maintenance
Certification through NC State University. His certification number is 1186.
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes.
NCS000441_UNC-CH MS4 Audit_20210616 Page 21 of 23

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes, the inspector is very knowledgeable.
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes.
Does the MS4 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes. The O&M plan, drainage area, engineer specs, manufacturer's maintenance manual, and past inspections can be accessed via
the inspector's iPad,
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes.
Did tl ie MS4 irspector miss any ubviuus operation and rnainteriance deficiencies? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
If the SCM had needed to be cleaned, the inspector is the person who would organize that. if the SCM had pollution issues, the
inspector would have sent the inspection report to EMS stormwater staff (Janet). If the SCM had structural issues, the inspector
would have sent the inspection report to Energy Services (Sally and Jamie).
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
N/A
If compliance issues were identified, what timeline for correction/follow-up was provided?
N/A
Notes/Comments/Recommendations
I was impressed by Robert's knowledge and inspection skills. He came prepared to conduct a complete inspection and took the
time to explain how the SCM works, maintenance concerns to watch out for, and demonstrate the functionality of the tools
(specifically, the depth measurer and the iPad).
NCS000441_UNC-CH MS4 Audit_20210616 Page 22 of 23

APPENDIX A: SUPPORTING DOCUMENTS
All supporting documentation cited in this report can be accessed from the Division of Energy,
Mineral, and Land Resources' online Laserfiche repository at the following link:
httos://edncs.deq.nc erResourrps/Rrovvse.aspx?dbid=Q&startid=176442l
NC5000441_UN[-CHyWS4Audit_20210616 Page 23of23