NCS000403_Audit Response Letter_20220812

alley, Williams, carmen & king, Inc.
ENGINEERING • ARCHITECTURE • SURVEYING
August 10, 2022
Mr. Rich Roedner, Town Manager
Town of Elon
P.O. Box 595
Elon, North Carolina 27244
Subject: MS4 Stormwater
Program Audit Report
Response to Audit
Dear Mr. Roedner,
As you are aware, NC DEQ's Division of Energy, Mineral, and Land Resources (DEMLR)
conducted an audit of the Town's Municipal Separate Storm Sewer System (MS4) on June
29t" 2022. The audit was conducted by Isaiah Reed — Environmental Engineer DEMLR staff
from the Asheville Regional Office. The meeting included an in -person audit review of
program implementation in the morning and afternoon field visits to Elon MS4 sites in order
to determine the Town's compliance with its NPDES Phase 2 MS4 stormwater permit and
comprehensive stormwater management plan (CSWMP).
The Town received its audit report from DEMLR on July 15, 2022. The audit report included a
Notice of Deficiency (NOD) based upon minor deficiencies identified in the audit report.
After a review of the audit report and NOD, we concur that there are improvements that can
be made to the Town of Elon's stormwater program. However, the deficiencies noted
appear very minor and it appears that a Notice of Compliance would have been a more
appropriate determination.
We recommend implementing the findings from the Audit within the below response actions
but as noted, do not believe that the identified actions rise to the level of a deficient
stormwater program. As such, the upcoming changes will be minor in scope.
Response Actions:
1. Respond to DEMLR noting these concerns and that the Town plans to comply with the
audit findings.
2. Conduct a self -audit of the Town's Public Education and Outreach and Public
Involvement programs.
3. Develop a draft Stormwater Management Plan (updated CSWMP).
4. Submit a new permit application after approval of the draft SWMP (above).
5. Improvements to the Annual Report addressing program effectiveness issues and
evaluation of the SWMP itself as noted.
740 Chapel Hill Road, Burlington, North Carolina P.O. Box 1179 (27216)
Tel. [phone] Fax [phone] awck.com

6. Implementing additional outreach for IDDE issues and tracking documentation.
In reviewing the audit report and the audit process, the auditor had several worthy suggestions
to make the Town's stormwater program better. A better program will benefit the citizens of
the Town by improving water quality, but I believe after reviewing the audit report that the
report is overly hard in its assessment of the program and that there were several items that
were overstated or misstated.
As always, it is our pleasure to work with the Town of Elon and if you would like to discuss any
of the above items, please let me know.
Sincerely,
Josh Johnson, P.E.
Town Engineer (contracted)
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