NCS000414_2016 Permit Application_20161216

TOWN OF CHAPEL HILL

NPDES PERMIT
RENEWAL
APPLICATION

December 16, 2016

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Table of Contents

1 Population and Estimated Growth Rate ............................................................................................... 6
1.1 Population ..................................................................................................................................... 6
1.2 Growth Rate .................................................................................................................................. 6
2 Jurisdictional Area ................................................................................................................................. 6
3 Stormwater Conveyance System Description ....................................................................................... 6
4 Estimated Land Use............................................................................................................................... 7
5 Receiving Streams ................................................................................................................................. 8
6 TMDLs ................................................................................................................................................... 9
7 Impaired Streams and Existing Programs to Address ........................................................................... 9
8 Existing Water Quality Programs ........................................................................................................ 10
8.1 Town Land Use, Development, and Stormwater Standards and Plans ...................................... 10
8.1.1 Chapel Hill 2020 Comprehensive Plan ................................................................................ 10
8.1.2 Town of Chapel Hill Design Manual .................................................................................... 10
8.1.3 Stormwater Management Master Plan .............................................................................. 11
8.2 Town Code of Ordinances ........................................................................................................... 11
8.2.1 Flood Damage Prevention Ordinance ................................................................................. 11
8.2.2 Erosion and Sediment Control ............................................................................................ 11
8.2.3 Illicit Discharge Detection and Elimination (IDDE) .............................................................. 11
8.2.4 Land Use Management Ordinance (LUMO) ........................................................................ 12
9 Partnerships and Inter-local Agreements ........................................................................................... 14
9.1 Orange County ............................................................................................................................ 14
9.2 Carrboro ...................................................................................................................................... 14
9.3 University of North Carolina at Chapel Hill (UNC) ...................................................................... 14
9.4 Orange Water and Sewer Authority (OWASA) ........................................................................... 14
9.5 North Carolina Department of Transportation (NCDOT) ............................................................ 15
9.6 North Carolina Watershed Stewardship Network ...................................................................... 15
9.7 Clean Water Education Partnership (CWEP) ............................................................................... 15
9.8 Nutrient Scientific Advisory Board (NSAB) .................................................................................. 15
10 State Programs ................................................................................................................................ 16
11 Reliance on Other Government Entity ............................................................................................ 16
12 Points of Contact ............................................................................................................................. 16
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13 Public Education and Outreach Program ........................................................................................ 17
13.1 Target Pollutant Sources ............................................................................................................. 17
13.2 Target Audiences ........................................................................................................................ 17
13.3 Mechanisms Used to Reach Target Audiences ........................................................................... 18
13.4 BMPs for the Public Education and Outreach Program .............................................................. 19
14 Public Involvement and Participation Program .............................................................................. 19
14.1 Stormwater Management Utility Advisory Board ...................................................................... 19
14.2 Volunteer Opportunities ............................................................................................................. 20
14.3 Public Involvement in Subwatershed Studies ............................................................................. 20
14.4 Public Engagement of Specific Groups ....................................................................................... 21
14.5 BMPs for the Public Involvement and Participation Program .................................................... 21
15 Illicit Discharge Detection and Elimination (IDDE) .......................................................................... 21
15.1 Storm Sewer System Map ........................................................................................................... 22
15.2 Regulatory Mechanism ............................................................................................................... 23
15.3 Enforcement ............................................................................................................................... 23
15.4 Detection and Elimination .......................................................................................................... 23
15.5 Non-Stormwater Discharges With Potential to Significantly Contribute Pollutants .................. 24
15.6 Outreach ..................................................................................................................................... 25
15.7 Staff Training ............................................................................................................................... 25
15.8 Evaluation ................................................................................................................................... 26
15.9 BMPs for Illicit Discharge Detection and Elimination (IDDE) ...................................................... 27
16 Post-Construction Stormwater Program ........................................................................................ 28
16.1 Regulatory Mechanism ............................................................................................................... 28
16.2 Operation and Maintenance ....................................................................................................... 28
16.3 BMPs for the Post-Construction Stormwater Program .............................................................. 29
17 Practices to Inspect and Maintain Municipally-Owned Facilities and Structural Stormwater
Control Devices ............................................................................................................................... 30
17.1 Municipally-Owned Facilities ...................................................................................................... 31
17.2 BMPs for Pollution Prevention and Good Housekeeping for Municipal Operations.................. 32
17.3 Structural Stormwater Control Devices ...................................................................................... 33
18 Practices to Reduce Polluted Stormwater Runoff .......................................................................... 33
19 Training Programs for Municipal Staff ............................................................................................ 34
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20 Spill Response Procedures for Municipally Owned and/or Operated Facilities and Public Rights-
of-Way ............................................................................................................................................. 35
21 References ...................................................................................................................................... 36
22 ATTACHMENT 1 ............................................................................................................................... 37
23 ATTACHMENT 2 ............................................................................................................................... 38
24 ATTACHMENT 3 ............................................................................................................................... 39
25 ATTACHMENT 4 ............................................................................................................................... 40

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1 POPULATION AND ESTIMATED GROWTH RATE
1.1 POPULATION
There are 59,569 permanent residents within the Town of Chapel Hill’s municipal limits (including
University of North Carolina students), based on July 1, 2015 Estimates with July 1, 2015 Municipal
Boundaries (NCOSBM 2016). In 2016, 8,190 students lived on campus and would be included under
stormwater permit requirements for the University (UNC Housing Office). As of 2009, University of North
Carolina (UNC) students represented approximately 23% of the Town’s population, based on the
approximately 13,000 students (46%) enrolled that year that gave Chapel Hill as their address (Town of
Chapel Hill 2010).
1.2 GROWTH RATE
The Town of Chapel Hill experienced total growth 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). Between April 1, 2010 and July 1, 2015, the total growth rate was 4.08%, or .08%
per year (NCOSBM 2016). Forty-two percent of the Town’s population growth between 2000 and 2009
was due to the annexation of urbanized areas, and approximately 13% of the total growth between 2010
and 2015 was due to annexation (Town of Chapel Hill 2010; NCOSBM 2016).

TOWN OF CHAPEL HILL POPULATION AND GROWTH STATISTICS
April 2010-July 2015
July
2015
April
2010
Total Growth
2010-2015
Population
Annexed
Growth in
Annexed Areas
Urban
Growth
59,569 57,233 2,336 (4.08%) 301 10 2,025
Data Source: NC Office of State Budget and Management
https://www.osbm.nc.gov/demog/municipal-estimates)
2 JURISDICTIONAL AREA
The current municipal corporate limits (MS4 limits) of the Town of Chapel Hill is 21.5 square miles; the
Town’s jurisdictional area, which includes the Town’s extraterritorial jurisdiction (ETJ), is 27.5 square
miles.
3 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.

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It is estimated that there are over 100 miles of streams and open channels, 63 miles of culverts and
pipelines, and approximately 5600 storm drain inlets within the Town’s corporate limits (Jewell
Engineering Consultants, PC, 2014).

The major receiving streams to which stormwater discharges are conveyed include Bolin Creek, Booker
Creek, Little Creek, and Morgan Creek. The Federal Emergency Management Agency (FEMA)-mapped 1%
annual chance floodplains cover almost two square miles within the Town. University Mall 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. During large
storm events, culverts and streams in the lower segments of the Town’s watersheds periodically flood as
a result of high volumes of runoff in conjunction with low flow velocity (gradient) in these areas of Town.

Maintenance and improvements to the MS4 system are funded by stormwater utility fees collected within
the Town. Maintenance of the stormwater system located within the Town’s rights-of-way and on Town-
owned property 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. 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, as well as channel stabilization, stream restoration, 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
addition, the Town has developed an inspection monitoring program for additional culvert crossings to
assess structural conditions, and follows the inspection prioritization plan described in the Town’s
Stormwater Management Master Plan (Jewell Engineering Consultants PC, 2014). Bridges and road
crossings are inspected biennially and after significant storm events, and residents’ reports and
complaints play an important role in identifying stormwater problems.
4 ESTIMATED LAND USE
The estimated percentage of the Town of Chapel Hill’s jurisdictional area (including the Town’s municipal
limits and ETJ) that is under residential, commercial, industrial, and open space land use types is shown in
the table 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.

Land Use Type
Estimated Area of
Town’s Jurisdiction
(2012)
Residential 64%
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Land Use Type
Estimated Area of
Town’s Jurisdiction
(2012)
Commercial 4%
Industrial 1%
Open Space 10%
Institutional 16%
Rights-of-Way 5%
Data Source: Chapel Hill 2020 Land Use Plan Map (adopted 2012).
5 RECEIVING STREAMS
All receiving streams within the Town of Chapel Hill’s jurisdiction are within the Cape Fear River Basin and
drain to both 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 known water quality issues are noted (NCDWR 2014).

Receiving Stream
Name
Stream Index
Number
Water Quality
Classification
Use Support
Rating
Water Quality
Issues
303(d)
List?
Little Creek 16-41-1-15-(0.5) WS-IV; NSW Impaired Poor
Bioclassification Y
Bolin Creek
(Hogan Lake)
16-41-1-15-1-
(0.5)b WS-V; NSW Impaired Fair
Bioclassification Y
Bolin Creek 16-41-1-15-1-(4) WS-IV; NSW Impaired
Fair
Bioclassification,
Habitat
Degradation
Y
Tanbark
(Tanyard) Branch 16-41-1-15-1-3 WS-V; NSW Not Rated Poor
Bioclassification N
Booker Creek
(Eastwood Lake) 16-41-1-15-2-(1) WS-V, B; NSW Impaired
Fair
Bioclassification,
Low Dissolved
Oxygen
Y
Booker Creek 16-41-1-15-2-(4) WS-V; NSW Impaired Fair
Bioclassification Y
Booker Creek 16-41-1-15-2-(5) WS-IV; NSW Impaired Fair
Bioclassification Y
Crow Branch 16-41-1-15-2-2 B; NSW Not Rated Urbanization N
Cedar Fork Creek 16-41-1-15-2-3 WS-V, B; NSW Not Rated Fair
Bioclassification N
Old Field Creek 16-41-1-7 WS-V; NSW Not Rated Urbanization N
Morgan Creek 16-41-2-(5.5)a WS-IV; NSW Supporting Fair
Bioclassification N
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Receiving Stream
Name
Stream Index
Number
Water Quality
Classification
Use Support
Rating
Water Quality
Issues
303(d)
List?
Morgan Creek 16-41-2-(5.5)b WS-IV; NSW Impaired Fair
Bioclassification Y
Wilson Creek 16-41-2-6 C, WS-IV; NSW Not Rated Urbanization N
Fan Branch Creek 16-41-2-6-1 WS-IV; NSW Not Rated Urbanization N
Meeting of the
Waters 16-41-2-7 WS-IV; NSW Not Rated Poor
Bioclassification N
Battle Branch Source to Bolin
Creek C; NSW Not Rated Urbanization N
Data Source: https://deq.nc.gov/about/divisions/water-resources/planning/classification-standards
6 TMDLS
All of Chapel Hill, including the Town’s municipal corporate limits and ETJ, are tributary to the Upper New
Hope Arm of the Jordan Lake, which is subject to a Total Maximum Daily Load (TMDL).
7 IMPAIRED STREAMS AND EXISTING PROGRAMS TO ADDRESS
The following streams are listed as impaired in the most recent (NCDWR 2014) final overall Integrated
Report approved by the USEPA (United States Environmental Protection Agency):

Receiving Stream
Name
Stream Index
Number
Water Quality
Classification
Use Support
Rating
Water Quality
Issues
303(d)
List?
Little Creek 16-41-1-15-(0.5) WS-IV; NSW Impaired Poor
Bioclassification Y
Bolin Creek
(Hogan Lake)
16-41-1-15-1-
(0.5)b WS-V; NSW Impaired Fair
Bioclassification Y
Bolin Creek 16-41-1-15-1-(4) WS-IV; NSW Impaired
Fair
Bioclassification,
Habitat
Degradation
Y
Booker Creek
(Eastwood Lake) 16-41-1-15-2-(1) WS-V, B; NSW Impaired
Fair
Bioclassification,
Low Dissolved
Oxygen
Y
Booker Creek 16-41-1-15-2-(4) WS-V; NSW Impaired Fair
Bioclassification Y
Booker Creek 16-41-1-15-2-(5) WS-IV; NSW Impaired Fair
Bioclassification Y
Morgan Creek 16-41-2-(5.5)b WS-IV; NSW Impaired Fair
Bioclassification Y
Data Source: https://deq.nc.gov/about/divisions/water-resources/planning/classification-standards/303d/303d-files

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Of the seven receiving stream segments considered to be impaired, all but one is impaired for biological
integrity; Booker Creek (Eastwood Lake) is impaired due to low dissolved oxygen.

Chapel Hill addresses impaired waters by implementing the Town’s existing local and state water quality
programs, public education and outreach program, public involvement and participation program, illicit
discharge detection and elimination program, and the post-construction stormwater program (see
Sections 8, 10, 13-16 below).

The Town also conducts annual biological monitoring at several sites located along the impaired stream
segments and other receiving waters listed above. Since 2011, the Town of Chapel Hill has contracted
biological monitoring services with professional benthic macroinvertebrate scientists (Dave Lenat and
Larry Eaton, both previously with the NCDWR) to conduct annual water quality monitoring at sites
throughout the Town’s jurisdiction. Town stormwater staff use the results of annual monitoring to target
watersheds with poor water quality for improvements and to investigate possible sources of pollution,
including illicit discharges. All annual reports are provided on the Town’s biological monitoring webpage.
8 EXISTING WATER QUALITY PROGRAMS
The Town of Chapel Hill implements a number of water quality programs 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).
8.1 TOWN LAND USE, DEVELOPMENT, AND STORMWATER STANDARDS AND PLANS
8.1.1 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 following Land Use
Management Ordinance (LUMO), design guidelines, and stormwater regulations (see below for
summaries that include these efforts).
8.1.2 Town of Chapel Hill Design Manual
The Town of Chapel Hill 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 guidelines for submission of stormwater
management plans and reports for development, and refers specifically to the North Carolina
Stormwater Design Manual. The Town of Chapel Hill also provides Standard Details for Storm
Drainage and Erosion Control as concrete examples which conform to Town standards. The
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Town’s Design Manual is currently being updated, and the update is anticipated to be published
in January 2017.
8.1.3 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 took into consideration the need to involve
local and regional stakeholders in development of the plan, meet the Town’s stormwater related
regulatory requirements, provide fair, effective and efficient stormwater management services to
residents and property owners in Chapel Hill, provide baseline data and summaries of current
stormwater related conditions, infrastructures and services, and recommend and prioritize action
plans to mitigate flooding and improve water quality and stream integrity in the years ahead.
Phase I was completed in October 2008, and Phase II was completed and adopted by the Town
Council on September 29, 2014.
8.2 TOWN CODE OF ORDINANCES
8.2.1 Flood Damage Prevention Ordinance
The Town of Chapel Hill’s Flood Damage Prevention Ordinance (Chapter 5, Article IV) 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.
8.2.2 Erosion and Sediment Control
The Town’s Soil Erosion and Sedimentation Control (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 contributes to
meeting the Town's NPDES minimum requirements for Construction Site Stormwater Runoff
Control, and it meets or exceeds state erosion control requirements. For example, an erosion and
sediment control permit is required for land development projects disturbing 20,000 square feet
or more of land. The program is administered by the Orange County Erosion Control Division and
enforced by Orange County and the Town of Chapel Hill Inspections staff; 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.
8.2.3 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) to regulate the contribution of pollutants to the
stormwater drainage system, prohibit illicit discharges and connections to the stormwater
drainage system, prevent improper disposal of materials that degrade water quality, and to
establish legal authority to carry out all inspection, detection, monitoring procedures and
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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.
8.2.4 Land Use Management Ordinance (LUMO)
Development regulations and standards are documented in the Chapel Hill LUMO (Appendix A of
the 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. The following
summaries provide an overview of the relevant LUMO sections with respect to water quality and
the Town’s NPDES MS4 permit.
8.2.4.1 Resource Conservation District (RCD)
Section 3.6.3 of the Chapel Hill LUMO 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
in order to preserve the water quality of the Town's actual or potential water supply
sources; to 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; to retain open spaces and greenways
and to protect their environmentally-sensitive character; to preserve urban wildlife and
plant life habitats from the intrusions of urbanization; to provide air and noise buffers
to ameliorate the effects of development; and to preserve and maintain the aesthetic
qualities and appearance of the Town. The RCD buffer currently applied to perennial
streams has a width of 150’ total, consisting of three 50’ zones; the buffer applied to
intermittent streams and perennial waterbodies has a width of 50’, consisting of one
zone. All streams subject to the RCD are field classified by Town staff, and RCD buffers
are measured from the top of bank and must be surveyed. Buffers required on perennial
waterbodies are measured from the mean high water mark.
8.2.4.2 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. Section 3.6.4 of the Chapel Hill LUMO establishes the Watershed Protection
District, and includes requirements for high density development, stream buffer
requirements, restrictions on use of toxic materials, construction standards, and other
performance standards. 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.
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8.2.4.3 Jordan Watershed Riparian Buffer Protection Ordinance
In 2010, the Town incorporated the minimum requirements of the Jordan Nutrient
Strategy Rule (15A North Carolina Administrative Code 02B.0267, as amended by
Session Law 2009-484) for riparian buffer protection into a Jordan Watershed Riparian
Buffer Protection Ordinance, adopted as Section 5.18 of the LUMO. This ordinance
applies to uses in or activities conducted within, or outside of with hydrological impacts
in violation of the diffuse flow requirements set out in subsection 5.18.6(c) upon, fifty -
foot-wide riparian buffers directly adjacent to intermittent streams, perennial streams
and perennial waterbodies, excluding wetlands. 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 (U.S.G.S.).
8.2.4.4 Steep Slopes
Section 5.3, Critical Areas and Environmental Performance Standards, of the Chapel Hill
LUMO 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.
8.2.4.5 Stormwater Management
Section 5.4 of the Chapel Hill LUMO specifies stormwater management requirements,
including a water quality regulation, for all development that adds impervious area. This
section 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 was approved on October 24, 2012, adding Section 5.19 - Jordan
Watershed Stormwater Management for New Development - to the Chapel Hill
LUMO. The effective date was December 1, 2012.

Section 3.11 of the LUMO was adopted on May 12, 2014, and establishes a specific
Ephesus-Fordham Form District in which minimum stormwater management standards
specific to this district for all new development and redevelopment are established. As
a result, the following regulations specific to water quality in other areas of the Town’s
jurisdiction do not apply: Section 3.6.3, Resource Conservation District, Section 5.3.2,
Steep Slopes, Section 5.4, Stormwater Management, and Section 5.19, Jordan
Watershed Stormwater Management for New Development.
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8.2.4.6 Tree Protection
Section 5.7 of the Chapel Hill LUMO regulates the protection, installation, removal, and
long-term management of trees, shrubs and soils within the Town’s jurisdiction.
9 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
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. Below are a few
examples of the partnerships Town staff are actively involved with that relate to our NPDES MS4 permit.
9.1 ORANGE COUNTY
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 and several other
municipalities within the county. In 2016, Orange County added one additional erosion control officer to
their Erosion Control Division to assist with enforcement.
9.2 CARRBORO
The Town of Chapel Hill’s Stormwater Management staff coordinate with the Town of Carrboro’s
Environmental Planner on projects of mutual interest, including annual biological monitoring in Bolin
Creek and Morgan Creek watersheds, stream restoration efforts in the Bolin Creek watershed,
maintenance of the USGS stream gage on Bolin Creek at Village Drive, and stream determinations for
properties located in the vicinity of both jurisdictions.
9.3 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 IDDE efforts,
and co-review UNC development plans. Recently, Town and UNC staff have been sharing information on
training municipal/university staff on stormwater awareness and our respective IDDE programs. A
member of the UNC staff also currently serves on the Town’s Stormwater Management Utility Advisory
Board. In addition, educational and student research projects have been developed in collaboration with
UNC’s Institute for the Environment and environmental classes.
9.4 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 also regarding
Capital Improvement Projects. The Town’s staff are also coordinating with OWASA Operations and
Maintenance staff and UNC Stormwater Management staff on water quality issues and IDDE efforts in our
shared jurisdictions.
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9.5 NORTH CAROLINA DEPARTMENT OF TRANSPORTATION (NCDOT)
The Town of Chapel Hill’s Stormwater Management staff regularly interact with NCDOT staff on review of
development projects (via the Town’s Technical Review Team), long-range transportation planning, and
coordinating 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.
9.6 NORTH CAROLINA WATERSHED STEWARDSHIP NETWORK
The Town of Chapel Hill is an active 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. A member
of the Town Stormwater Management staff serves on the network’s Web Tools Committee, which is
responsible for NCWSN website design, web-mapping tools, and the database that drives them. The
committee is also responsible for the look and feel of end content deliverables from other committees.
9.7 CLEAN WATER EDUCATION PARTNERSHIP (CWEP)
For more than a decade, the Town of Chapel Hill has been and continues to be 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. 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.
9.8 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 STATE PROGRAMS
As described in Section 8 (Existing Water Quality Programs) above, the Town of Chapel Hill is a delegated
local government authority for stormwater and 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 9, Partnerships and Local
Agreements, and Section 11, Reliance on Other Government Entity).
11 RELIANCE ON OTHER GOVERNMENT ENTITY
The Town of Chapel Hill has a legal agreement with Orange County for enforcement of the Town’s Soil
Erosion and Sedimentation Control regulations, which were originally adopted by the Chapel Hill Town
Council on September 22, 1986. The legal agreement between the Town and County was signed on
November 3, 1986. See Section 12 below for contact information for both Orange County and the Town
regarding Soil Erosion and Sedimentation Control (Construction Site Stormwater Runoff Control).
12 POINTS OF CONTACT
The following is the Point of Contact List for the Town of Chapel Hill’s NPDES MS4 Permit:
MEASURE POINTS OF CONTACT
Public Education and Outreach Lance Norris
Public Works Director
[e-mail]
Phone: [phone]
FAX: [phone]

Chris Jensen
Senior Engineer
(Stormwater – Technical Services)
[e-mail]
Phone: [phone]
FAX: [phone]

Public Involvement and
Participation
Illicit Discharge Detection and
Elimination
Post-Construction Stormwater
Management
Construction Site Stormwater
Runoff Control
Howard Fleming, Jr.
Orange County Erosion Control
Supervisor
[e-mail]
Phone: [phone]
FAX: [phone]
Chris Jensen
Senior Engineer
(Stormwater – Technical Services)
[e-mail]
Phone: [phone]
FAX: [phone]
Pollution Prevention/Good
Housekeeping for Municipal
Operations
Lance Norris
Public Works Director
[e-mail]
Phone: [phone]
FAX: [phone]

Brian Litchfield
Transit Director
[e-mail]
Phone: [phone]
FAX: [phone]
Chris Jensen
Senior Engineer
(Stormwater – Technical Services)
[e-mail]
Phone: [phone]
FAX: [phone]

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See Attachments 1, 2, and 3 for Organizational Charts for the Town of Chapel Hill, Public Works
Department, and Stormwater Management program, respectively.

The Town Manager is ultimately responsible for the administration, implementation, and enforcement of
the Town’s Stormwater Management program. Through reorganization, the Public Works Director now
supervises Stormwater Management staff.

Roger L. Stancil, Town Manager, was duly authorized by the Town Council at its December 5, 2016 meeting
to sign this NPDES permit renewal application and future renewal application on behalf of the Town of
Chapel Hill (see Attachment 4 for Resolution to Authorize the Town Manager to Sign the NPDES Permit
Renewal Application).
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 storm water 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 BMPs the Town is implementing to meet the Public Education and Outreach Program
component of our NPDES 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 POLLUTANT SOURCES
The Town’s target pollutant sources for public education and outreach include sediment, fertilizers and
other nutrients, litter, pet waste, and other illicit discharges.
13.2 TARGET 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.

Public School Students (Grades 2-12): This target audience has the greatest potential for growing up to
be good watershed stewards, and also 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. The Town also sponsors high school interns 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.

Homeowners: This subgroup of the general 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 are likely to care for a home and property, and have the
greatest potential for engaging in target activities such as yard care, disposal practices, pet ownership, car
maintenance, and pollution reporting.

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Multi-Family Residential Communities: This target audience has been selected because the Town has a
significant population of university students who live in apartments, and affordable housing options are
increasing. Educating residents of these complexes about pet waste, litter, and proper waste disposal in
particular can be beneficial to water quality.

Construction Industry: This target audience has been selected because it 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 paint, concrete, and other waste. The Town provides a link to a Construction BMP
website maintained by the CWEP.

Local Businesses: This target audience includes restaurants, landscapers, and other local businesses that
can benefit from knowledge of BMPs to prevent pollution that are specific to their business activities. The
Town maintains a Stormwater Management at your Business website to provide information to prevent
water pollution in the workplace, and has developed award-winning materials for restaurants in particular
that are regularly distributed.

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. In addition to working with homeowners
and multi-family residential communities, the Town continues to provide pet waste materials and
pollution prevention information to the Orange County Animal Shelter to distribute for dog adoptions.
13.3 MECHANISMS USED TO REACH TARGET AUDIENCES
The Town continues to widely distribute printed brochures at the local library, at festivals and exhibits,
and hangs door hangers in neighborhoods. The Town also continues to publish regular newsletters,
maintain a Facebook group, contribute articles to the Town’s e-news, and provide workshops and training
opportunities for public schools and UNC students, local businesses, and citizens. The Stormwater
Management staff also maintains and regularly updates a Stormwater Management Program website,
participates in the Town’s e-notification service for Town updates, frequently includes information in a
weekly TOWNweek ad in the Chapel Hill News, and maintains a stormwater hotline/helpline (919 -969-
RAIN). Stormwater videos are shown daily on Local Government cable TV Channel 18. 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.

In addition, in partnership with other local governments in the region, the Town is an active member of
CWEP 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 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, and maintains a website the Town links to help citizens
understand what they can do to help reduce stormwater pollution in their community. For more
information about CWEP outreach activities, refer to the annual reports posted on their webpage; see
also Section 9 above.

Chapel Hill has also partnered with stormwater educators in Durham and Raleigh to run ads and articles
in Spanish language news media distributed in the Triangle. Since many Hispanic and Latino workers cross
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jurisdictional boundaries in construction, housekeeping and restaurant jobs, pooling resources for more
frequent advertising allows stormwater educators to increase the number of impressions of clean water
messages and thus increase the probability of behavior change.
13.4 BMPS FOR THE PUBLIC EDUCATION AND OUTREACH PROGRAM
Below are Best Management Practices (BMPs) the Town implements to meet the Public Education and
Outreach component of our NPDES MS4 permit. Funding for the BMPs in this section is covered by local
stormwater utility fees.

BMP Measurable Goals
a. Identify 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

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

c. Develop and distribute public
education materials to
identified target audiences and
user groups.
Distribute stormwater educational material to appropriate
target groups using locally appropriate strategies.

Measure and record the extent of exposure for each strategy.

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

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 homeowners 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
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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.
14.2 VOLUNTEER OPPORTUNITIES
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, gardens, families, and businesses.

One of the Town’s volunteer opportunities involves the storm drain labeling program. 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.

The Town also 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.

In 2013, The Town of Chapel Hill began a volunteer water quality monitoring program (The Stream Team)
to connect citizen scientists and residents with their watersheds and local government, to encourage
residents to report illicit discharges and sources of pollution, and to train volunteers to conduct visual
assessments and measure basic water quality parameters, primarily at sites nearby the established
annual biological monitoring sites described above. Three levels of volunteer commitment and training
are offered: (1) Stream Walkers, (2) Stream Team Monitors, and (3) Watershed Stream Team Leaders.

Town staff also continue to work with UNC students to provide service projects that engage students in
stormwater management activities and water quality monitoring. Current UNC student service projects
include a sociology student intern conducting an anti-litter campaign in public housing, students from a
UNC Restoration Ecology class (ENEC 304) monitoring water quality at Homestead Park in the Booker
Creek headwaters, and the Epsilon Eta fraternity which is monitoring water quality for bacterial
pollution at various locations in Chapel Hill and Carrboro.
14.3 PUBLIC INVOLVEMENT IN SUBWATERSHED STUDIES
Through the recent development of the Lower Booker Creek Subwatershed Study, many opportunities
have been provided to ensure residents, businesses, visitors and property owners stay engaged. 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. In October 2015, the Town began distribution of questionnaires to
property owners in the entire Booker Creek watershed requesting feedback on erosion and flooding. The
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Town provided several other avenues for obtaining citizen input including setting up an online website
specifically for the project, targeted outreach to local groups and events, and stakeholder interviews. The
Town intends on conducting future subwatershed studies throughout the Booker Creek watershed. The
next study is scheduled to begin in 2017 and will focus on the Eastwood Lake subwatershed.
14.4 PUBLIC ENGAGEMENT OF SPECIFIC GROUPS
The Town engages a diverse citizenry, by working in schools and public housing communities, and with
local businesses and community groups to participate in the stormwater management program.

The Town maintains an active 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. An effort is also underway to address discharges from the washing of
paint equipment. The Town has 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. From this survey, industry-specific IDDE education strategies will be
developed. A new IDDE awareness effort is also currently being fostered through partnerships with the
Town’s Office of Housing and Community Development; this work includes community cleanups, learning
fairs and beautification projects.

Town staff also provide presentations and volunteer opportunities for religious organizations and civic
groups, such as the Chamber of Commerce.
14.5 BMPS 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 NPDES MS4 permit.

BMP Measurable Goals
a. Provide opportunities for public
involvement in program
activities
Provide opportunities for ongoing citizen participation through:

 Storm drain identification project
 NC Big Sweep

b. Mechanism for public
involvement in program
development
Continue staff support to Storm Water Advisory Board.

15 ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE)
The Town of Chapel Hill maintains an illicit discharge detection and elimination program that is responsive
to citizen reports, and also one that is proactive, with a primary component being the use of surface water
quality monitoring data, including chemical, physical and biological data, to detect water quality problem
areas and to initiate field screening activities designed to identify and eliminate pollution sources and
restore water quality conditions. Some of the integral components of the IDDE program are as follows:

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 Maintaining a water quality monitoring program to accurately assess existing water quality
conditions and identify trends.
 Using short-term monitoring activities to identify specific pollution sources as a component of the
follow-up field-screening program.
 Responding to citizen requests for service concerning water quality problems.
 Administering and enforcing the Town’s stormwater IDDE ordinance.
 Using public participation efforts such as the storm drain labeling program, clean water
ambassadors, and citizen stream monitoring.
 Identifying and mapping of stormwater outfalls that discharge to waters of the State.
 Stream walking and dry weather flow screening.
 Training employees about illicit discharges and how to prevent and report them.
 Maintaining a public reporting mechanism.
 Coordinating with other local government agencies to identify and eliminate failed septic systems
and sanitary sewer overflows.

Below are summaries of the Town’s storm sewer mapping efforts, regulatory mechanism for the IDDE
program, enforcement procedures, and detection and elimination procedures. Also below are summaries
of how the Town addresses particular non-stormwater discharges which may significantly contribute to
pollution, the Town’s IDDE outreach and training efforts, how the Town currently evaluates program
effectiveness, and a table of the BMPs the Town implements for this program.
15.1 STORM SEWER SYSTEM MAP
Maintenance of the Town’s storm sewer map is based on review of as-built field surveys and field
verification of pre-2006 relic storm sewer data. Storm sewer data from digital as-built surveys reflects
recently added or modified infrastructure. Field-verified data relies on a site visit and thorough inspection
of existing storm sewer infrastructure, and field verification frequently results in corrections of existing
relic data, as well as discovery of previously unmapped storm sewer structures. During field inspections,
condition assessment data are also collected for system components, and structures are photographed.

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 2
(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. In 2015,
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. Future subwatershed studies within the Booker Creek
watershed are planned as follows: Eastwood Lake (2017), Crow Branch (2018), and Cedar Fork (2019).

Currently, there are approximately 1600 outfalls, including culvert outlets, reflected in the Town’s
stormwater infrastructure data set. Of these, 626 have been verified by field visits or as-built plans. Field
verification is a year round, ongoing endeavor. At the current pace of field inventory work, site visits verify
and/or find approximately 17 outfalls per month. A provisional definition for major outfalls is based on
outfall pipe diameters of 36 inches or greater. Of 626 field verified outfalls, approximately 10% have a
diameter of 36” or greater.

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Receiving waters are determined from the Town’s GIS feature dataset for streams and NCDWR’s stream
classifications data. The Town’s stream dataset originates from inputs of data from topo and soils maps,
staff input, as well as LIDAR data. More than 70% of the approximately 3000 stream features in the Town’s
stream dataset have been field verified through the Town’s on-going stream determination program. This
program is in place to meet the Town’s requirements as a delegated authority to enforce Jordan Lake
buffer rules and the Town’s Resource Conservation District (RCD) regulations.

The Town of Chapel Hill also has developed a pollution sources geodatabase which includes mapped
locations of 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.
15.2 REGULATORY MECHANISM
The Chapel Hill Town Council recently adopted a new 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, enforcement procedures,
and a schedule of associated civil penalties for illicit discharges.

In addition, the Town’s Design Manual references specifications and guidelines pertinent to IDDE, and is
currently being updated to include standards for design of dumpster pads and elevator drains plumbed
to sanitary sewer, among others. These criteria must be reflected in development plans prior to approval.
15.3 ENFORCEMENT
As mentioned above, the Town of Chapel Hill now has a comprehensive IDDE Ordinance that outlines
enforcement procedures and actions. Enforcement action is typically undertaken by Stormwater
Management staff acting as the Town Manager’s designee. Upon detection of a suspected discharge,
staff gather evidence including photos and field test results. A database is populated with information
pertinent to investigation, enforcement, and NCDWR recommendations for Phase II communities. The
database is updated as the investigation progresses. Parties responsible for illicit discharges are issued a
Notice of Violation (NOV). The NOV cites Town authority, describes the illicit discharge, outlines remedies,
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.
15.4 DETECTION AND ELIMINATION
Reports of illicit discharges to the Town’s storm sewer system are typically initiated by complaints from
citizens and Town staff, and are detected via random field tests of receiving streams for selected water
quality parameters. Illicit discharge investigations are also initiated by Stormwater Management staff by
focusing on indicators from annual benthic macro invertebrate monitoring results in subwatersheds with
poor or declining water quality.

Citizens of Chapel Hill tend to be well-informed and proactive regarding water quality issues. During 2016,
Stormwater Management staff responded to 57 complaints, 24 of which were received from the general
public. With implementation of a new IDDE Ordinance giving staff stronger investigative and enforcement
powers, the number of future investigations is anticipated to be higher. The Stormwater Management
program maintains a hotline for complaints during business hours. The Town’s Emergency Management
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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 new IDDE ordinance, and also available on the Town’s Stormwater Management website.

Since 2011, the Town has established 36 benthic macroinvertebrate monitoring sites; these monitoring
sites are priority areas for regular screening for illicit discharges. In 2015, a report of toxicity at one newly
established benthic monitoring site prompted an investigation 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. Program
effectiveness can also be quantified using benthic, ambient, and NCDWR water quality monitoring data
from prior years.

Illicit discharges with unknown origins are traced using maps of storm sewer infrastructure. Working up
the storm sewer network from the initial point of investigation, investigators make regular observations
of temperature, specific conductivity, dissolved oxygen (DO), and pH; staff anticipate the future use of
field tests for ammonia and chlorine to augment the use of these water quality parameters. Subsequently,
the investigator follows indicators of poor water quality, ultimately arriving at the initial point of the illicit
discharge.

In 2016, stormwater staff acquired VPN (virtual private network) capability, which allows for direct access
from the field to Town Geographic Information System (GIS) data, including storm sewer network, sanitary
sewer infrastructure, and stream data. VPN access also connects the field investigator to emails and
server files remotely, including prior investigations and technical references that reside on the Town’s
server.

Outfall screening is also included in field work for storm sewer infrastructure inventory. Outfall condition
assessment tables linked to the GIS outfall feature class capture data on flow and the description of any
observed discharge from outfalls.
15.5 NON-STORMWATER DISCHARGES WITH POTENTIAL TO SIGNIFICANTLY CONTRIBUTE POLLUTANTS
Discharges from swimming pool back-flushing and pool discharges that have not been dechlorinated are
two types of non-stormwater discharge with the potential to significantly contribute pollutants to the
Town’s MS4 and waters of the State. In 2016, specific conductivity readings obtained by Town Stormwater
Management staff at several different outfalls that receive swimming pool backwash from filter cleaning
far exceeded 1000uS/cm, indicating that filter backwash was causing potentially significant water quality
issues. As a result, the Town’s new IDDE Ordinance allows discharges from dechlorinated swimming pools,
but specifically prohibits discharges that include pool filter backwash discharge or saltwater pool
discharge, or from pools that have not been dechlorinated. 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 a swimming pool was directly discharging chlorinated pool water
and backwash directly into a stream.

Stormwater staff will use GIS data for swimming pool locations to identify those within close proximity to
streams. Stream water quality parameters will be regularly monitored near these locations. If benthic
data or field meter data indicate declining water quality, nearby pool owners will be asked to plumb
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discharge lines directly to sanitary sewer. In the event of non-compliance, the Town may choose to follow
up with enforcement action as provided in our new IDDE Ordinance.

In addition, 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.
15.6 OUTREACH
The Town maintains a website dedicated to illicit discharges, which was recently updated to reflect the
new IDDE Ordinance. The Town also continues to update and maintain a webpage focused on public
education and participation, which provides information on and promotes opportunities to participate in
the Town’s ongoing public school program, stream cleanups, and volunteer stream monitoring and storm
drain labeling. 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 middle school students on IDDE and stormwater awareness through the use of an Enviroscape
watershed model to demonstrate the fate of stormwater runoff. Town staff also work with UNC college
students to conduct service projects related to water quality, which provides an opportunity to engage
young adults in IDDE awareness and pollution prevention.

The Town continues to maintain an active role in the development and distribution of media that
promotes awareness about IDDE, and is an active partner in the Clean Water Education Partnership
(CWEP). The Town links CWEP media productions and other information on best management practices
and pollution prevention on its website, including a webpage dedicated specifically to businesses and
specific industries.

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 an active 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. An effort is also underway to address discharges from the
washing of paint equipment. The Town has 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. From this survey, industry-specific IDDE education strategies
will be developed.

The Town continues to provide pet waste materials and pollution prevention information to the Orange
County Animal Shelter to distribute for dog adoptions, and continues to maintain and distribute a number
of brochures specific to businesses and the general public in various locations around Town. A new IDDE
awareness effort is also currently being fostered through partnerships with the Town’s Office of Housing
and Community; this work includes community cleanups and beautification projects.
15.7 STAFF TRAINING
Town Stormwater Management staff have recently 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. Stormwater staff will continue
to work toward active participation of upper and middle level management in ensuring that training for
NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 26
2016 NPDES MS4 Permit Renewal Application

Town employees is implemented and maintained, and that management staff understand the
mechanisms in place for detection and enforcement.

In 2013, site assessments were conducted by Town Stormwater Management staff and a consultant 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; to identify stormwater “hot spots”
where a significant potential for stormwater runoff contamination may exist; and to 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. The municipally-operated facilities identified and
involved in the site assessments included the Town Operations Center (Public Works and Transit
Departments), Town Fire Department (including five fire stations and the Fire Rescue Training Center),
Town Police Department (including the Police Station and other substations), Town Parks and Recreation
Facilities (including two community centers, the aquatic center, and the Parks and Recreation
Administrative Office and Community Clay Studio), Town Hall, the Public Library, and downtown
properties with solid waste compactors.

As a follow-up to the site assessments, the Town intends to implement a more comprehensive training
program for all 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 a 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 existing new employee
orientation training.
15.8 EVALUATION
Changes in the health of macroinvertebrate communities is an excellent measure of prolonged changes
to water quality. The effectiveness of the Town’s IDDE program can be measured when weighed against
habitat changes and other impacts to species diversity and abundance.

Enforcement effectiveness can be measured by the number illicit discharges investigated vs. length of
time to resolution. The ongoing success of enforcement action can be determined with post-year follow
ups.

Other quantitative goals will be set when possible. Given current staffing resources, 4 days per month
dedicated to storm sewer inventory is a reasonable goal for continued progress for system mapping and
outfall assessments. Complaint response can measure staff responsiveness to illicit discharge complaints.
By estimating flow rates of illicit discharges and using USGS gauge data, estimates of nutrient loads from
illicit discharges can be calculated. Comparing the contribution of the Town’s IDDE program to broader
goals for nutrient reduction will show the comparative effectiveness of the program.
NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 27
2016 NPDES MS4 Permit Renewal Application

15.9 BMPS FOR ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE)
Below are Best Management Practices (BMPs) the Town implements to meet the Illicit Discharge
Detection and Elimination (IDDE) component of our NPDES MS4 permit.

BMP Measurable Goals
a. Maintain adequate legal
authorities
Maintain through ordinance, or other regulatory mechanism,
adequate legal authorities to prohibit non-stormwater
discharges.

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

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.

d. Investigations into the source of all
identified illicit discharges
Develop and implement written procedures for conducting
investigations into the source of all identified illicit
discharges, including approaches to requiring such discharges
to be eliminated or reported to the State to be properly
permitted.

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.

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

h. Reporting hotline Promote and maintain hotline for public and town staff to
report illicit discharges and connections. Conduct reactive
inspections in response to complaints and follow-up
inspections as needed to ensure that corrective measures
have been implemented by the responsible party to achieve
and maintain compliance.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 28
2016 NPDES MS4 Permit Renewal Application

BMP Measurable Goals
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.

16 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. Below are summaries of the Town’s regulatory mechanism for this
program, how the Town ensures the long-term operation and maintenance (O&M) of structural BMPs and
that future O&M responsibilities are clearly identified in an agreement between the Town and another
party as the post-development landowners, and a table of BMPs the Town implements to meet the
requirements of his NPDES MS4 permit requirements.
16.1 REGULATORY MECHANISM
Section 5.4.6 of the Town’s Land Use Management Ordinance (LUMO) outlines general performance
criteria for post-development stormwater management. The Town’s Design Manual references
specifications and guidelines pertinent to Stormwater Control Measures (SCMs), which must be designed
according to the North Carolina Stormwater Design Manual. These criteria must be reflected in
development plans prior to approval.
16.2 OPERATION AND MAINTENANCE
The design engineer for the SCM must provide an Engineer’s certification with an as-built survey certifying
that the SCM has been constructed as approved by the Town of Chapel Hill. The SCMs are required to be
located in an easement dedicated as a “Private Stormwater Facility easement.” 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 prior to issuing the owner with a Certificate of Occupancy (CO).

The Town requires owners to submit annual inspections and O&M reports for all SCMs, and sends SCM
owners annual letters reminding them of upcoming due dates for reports. Due dates are 12 months after
initial inspection of SCMs and approval of COs. Inspections must be performed by a qualified Licensed
Professional Engineer or other qualified professional with North Carolina State University (NCSU)
Stormwater BMP Inspection and Maintenance Certification. For redevelopment and new development
projects, Town Stormwater Management staff must inspect and approve all installed SCMs before
issuance of COs.

Sections 5.4.8 and 5.4.9 of the LUMO include requirements for Operations & Maintenance (O&M) of
SCMs. O&M procedures are included in permit conditions. Written O&M covenants and easements must
be recorded with the County Register of Deeds prior to issuance of COs.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 29
2016 NPDES MS4 Permit Renewal Application

The Town inspects all SCMs at least once every five years, and additional inspections may be conducted
by the Town on any reasonable basis. Inspections may also include reviewing maintenance and repair
records.

If a responsible party fails or refuses to meet the requirements of an O&M covenant, the Town, after
reasonable notice, may correct a violation of the design standards or maintenance needs by performing
all necessary work to place the facility in proper working condition. In the event that the stormwater
management facility becomes a danger to public safety or public health, or is otherwise not functioning
as designed, the Town shall notify the party responsible for maintenance of the stormwater management
facility in writing. After proper notice, the Town may assess the owner(s) of the facility for the cost of
repair work and any penalties; and the cost of the work can be covered by a lien on the property, or may
be placed on the tax bill and collected as ordinary taxes by the county.

A comprehensive database is being developed to aid Town oversight of SCMs. The database includes
delineated SCMs in GIS, and geographic data are linked to tabular data reflecting O&M history. Also
included are in the GIS database are links to SCM as-built surveys and approval documents, as well as links
to photos and any other information pertinent to SCMs.
16.3 BMPS 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.

BMP Measurable Goals
a. Adequate legal authorities Maintain through an ordinance, or other regulatory
mechanism, adequate legal authorities to meet the
objectives of the Post-Construction Site Runoff Controls
program.

b. Strategies which include BMPs
appropriate for the MS4
Adopt the DWQ BMP Design Manual or certify that the local
BMP Design Manual meets or exceeds the requirements in
the DWQ BMP Design Manual.

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

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.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 30
2016 NPDES MS4 Permit Renewal Application

BMP Measurable Goals
e. Deed Restrictions and Protective
Covenants
Provide mechanisms such as recorded deed restrictions and
protective covenants so that development activities
maintain the project consistent with approved plans.

f. Long-term operation and
maintenance of structural BMPs
Require an operation and maintenance plan for the
long-term operation of the structural BMPs. The operation
and maintenance plan shall require the owner of each
structural BMP to perform and maintain a record of annual
inspections of each structural BMP. Annual inspection of
permitted structural BMPs shall be performed by a qualified
professional.

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

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
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.

17 PRACTICES TO INSPECT AND MAINTAIN MUNICIPALLY-OWNED FACILITIES
AND STRUCTURAL STORMWATER CONTROL DEVICES
Below are descriptions of the Town’s practices to inspect and maintain municipally-owned facilities,
including BMPs the Town implements to meet pollution prevention and good housekeeping
requirements, and practices to inspect and maintain structural stormwater control devices.
NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 31
2016 NPDES MS4 Permit Renewal Application

17.1 MUNICIPALLY-OWNED FACILITIES
Municipally-owned facilities in Chapel Hill include the Town Operations Center, Town Fire Department,
Town Police Department, Town Parks and Recreation Facilities, Town Hall, the Public Library, and Town-
owned parking lots.
The Town’s Operation Center (TOC) – 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 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 in order 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; to determine whether or not the facilities are impacted by the NPDES MS4
permit; to identify stormwater “hot spots” where a significant potential for stormwater runoff
contamination may exist; and to 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; to improve pollution prevention and good housekeeping practices at
the facilities; and to 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).

The municipally-operated facilities identified and involved in the individual site assessments included the
Town Fire Department (including five fire stations and the Fire Rescue Training Center), Town Police
Department (including the Police Station and other substations), Town Parks and Recreation Facilities
(including two community centers, the aquatic center, and the Parks and Recreation Administrative Office
and Community Clay Studio), Town Hall, the Public Library, and downtown properties with solid waste
compactors.

As a follow-up to the site assessments conducted in 2013, the Town intends to conduct site assessments
for additional facilities (e.g., other park facilities not previously assessed, Town-owned parking lots),
update the site assessments for each facility previously visited, and contract with a consultant to inspect
facilities and provide site-specific training at individual facilities. The updated site-specific assessments
will provide a basis for developing a regular inspection plan and be used to determine maintenance and
training needs.

In addition, a Stormwater BMP Maintenance Manual was developed specifically 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.
NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 32
2016 NPDES MS4 Permit Renewal Application

17.2 BMPS 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 and Transit Departments; however, some BMPs are performed by
employees in other Town departments (as noted in Section 17.1 above).

BMP Measurable Goals
a. Inventory of municipally
owned or operated facilities
Maintain an inventory of facilities and operations owned and
operated by the permittee with the potential for generating
polluted stormwater runoff.

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 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 an Operation and Maintenance (O&M)
program for municipal owned and operated facilities. The O&M
program shall specify the frequency of inspections and routine
maintenance requirements.

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

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.

f. Operation and Maintenance
(O&M) for municipally -owned
or maintained catch basins
and conveyance systems
Develop and implement an O&M program for the stormwater
sewer system including municipally -owned or maintained catch
basins and conveyance systems.

g. Identify and map for
municipally owned or
maintained structural
stormwater controls
Identify and map municipally-owned or operated structural
stormwater controls. The map shall identify the stormwater
outfalls corresponding to each structural stormwater control as
well as the receiving waters to which these facilities discharge.
The map shall be maintained and updated regularly and be
available for review by the permitting authority.

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.
NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 33
2016 NPDES MS4 Permit Renewal Application

BMP Measurable Goals

The O&M program shall specify the frequency of inspections and
routine maintenance requirements.

Inspect and maintain if necessary, all municipally-owned or
maintained structural stormwater controls in accordance with the
schedule developed by permittee. The permittee shall document
inspections and maintenance of all municipally-owned or
maintained structural stormwater controls.

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.

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

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.

17.3 STRUCTURAL STORMWATER CONTROL DEVICES
The Town’s practices to inspect and maintain structural stormwater control devices in private
developments are described above in Section 16 – Post-Construction Stormwater Program. The Town’s
practices to inspect and maintain these devices on Town-owned property are described above in Section
17.1.
18 PRACTICES TO REDUCE POLLUTED STORMWATER RUNOFF
To reduce polluted stormwater runoff from municipally-owned streets, roads, piped and vegetative
conveyances, manholes, cleanouts, drop inlets, and other drainage structures, the Town maintains the
stormwater system within the Town’s rights-of way and on Town-owned property. 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. Street sweeping is
also a regular stormwater maintenance activity, and focuses on major streets (once per week), downtown
streets (twice per week), and residential streets (once per 6 weeks). 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

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 34
2016 NPDES MS4 Permit Renewal Application

Other practices to reduce stormwater runoff include public education and outreach, public involvement
and participation, IDDE, construction site and post-construction site stormwater activities, and existing
water quality programs and regulations (see Sections above).
19 TRAINING PROGRAMS FOR MUNICIPAL STAFF
As noted above, 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 and Transit Departments; however,
some BMPs are performed by employees in other Town departments (see Section 17.1 above). The
Town’s Operation 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 are being met.

The Town continues to develop employee training programs that will provide cross-training on NPDES
MS4 stormwater requirements, stormwater pollution prevention, and good housekeeping for Town
operations. Implementation of a Town-wide employee training program will provide regular refresher
courses, and training for new employees. An integrated employee training program can cover several
areas of the NPDES program including IDDE (see Section 15.7), Construction Site and Post-Construction
Runoff, and Pollution Prevention and Good Housekeeping programs.

Staff training for IDDE has recently consisted of several presentations on stormwater awareness and IDDE
regulatory and enforcement mechanisms to upper and middle level management, the Town Council, and
advisory board members, as part of the process of IDDE Ordinance review and adoption. Stormwater
Management staff will continue to work toward active participation of upper and middle level
management in ensuring that training for Town employees is implemented and maintained, and that
management staff understand the mechanisms in place for detection and enforcement.

In 2013, as noted above, Town personnel familiar with the operations at the individual municipally owned
and operated facilities participated in site-specific assessments. During the site assessments, facility
personnel were interviewed and various industrial operations observed. The municipally-operated
facilities identified and involved in the site assessments included the Town Fire Department (including five
fire stations and the Fire Rescue Training Center), Town Police Department (including the Police Station
and other substations), Town Parks and Recreation Facilities (including two community centers, the
aquatic center, and the Parks and Recreation Administrative Office and Community Clay Studio), Town
Hall, the Public Library, and downtown properties with solid waste compactors.

As a follow-up to the site assessments, the Town intends to implement a more comprehensive training
program for all 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 Management staff will work with a 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.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 35
2016 NPDES MS4 Permit Renewal Application

In addition, Town Stormwater staff will work with the Human Resources Development (HRD) Department
to incorporate stormwater awareness training into the Town’s existing new employee orientation
training.
20 SPILL RESPONSE PROCEDURES FOR MUNICIPALLY OWNED AND/OR
OPERATED FACILITIES AND PUBLIC RIGHTS-OF-WAY
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 in order to minimize those impacts.

As noted above, 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 at the following facilities: Town Fire Department (including five fire stations and the Fire
Rescue Training Center), Town Police Department (including the Police Station and other substations),
Town Parks and Recreation Facilities (including two community centers, the aquatic center, and the Parks
and Recreation Administrative Office and Community Clay Studio), Town Hall, the Public Library, and
downtown properties with solid waste compactors. During the site assessments, each facility was
evaluated for existing practices and staff training activities, inspections were made of structural SCMs (if
present), and on-site spill response equipment was inspected and/or recommended.

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, and exchange of
GIS information on the Town’s stormwater conveyance system and stream network is coordinated. 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 need for spill response procedures (and training) at other facilities have been documented as
recommendations in the site assessment document, which will be updated to include additional facilities
not previously considered (e.g., other park facilities).

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 and SCMs will be developed. 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 incidents will be reported and documented, and records of all spills maintained.
Spill response procedures will be followed and updated as needed.
NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 36
2016 NPDES MS4 Permit Renewal Application

21 REFERENCES
Jewell Engineering Consultants, PC. 2008. Town of Chapel Hill Stormwater Management Program Master
Plan – Phase 1 Report. Prepared for the Town of Chapel Hill, NC. October 2008.
Jewell Engineering Consultants, PC. 2014. Town of Chapel Hill Stormwater Management Program Master
Plan – Phase 2 Final Report. Prepared for the Town of Chapel Hill, NC. Adopted by Town Council on
September 29, 2014.
NCDWR. 2014. 2014 Category 5 Water Quality Assessments - Final 303(d) List. Published by the North
Carolina Division of Water Resources (NCDWR), Raleigh, North Carolina. December 19, 2014. Available
online: http://deq.nc.gov/about/divisions/water-resources/planning/classification-
standards/303d/303d-files.
NCOSBM. 2016. 2016 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. 2016. Town of Chapel Hill Lower Booker Creek Subwatershed Study, September 2016 Draft.
Prepared for the Town of Chapel Hill. Available online: http://www.lowerbookercreeksws.org/.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 37
2016 NPDES MS4 Permit Renewal Application

22 ATTACHMENT 1
Organizational chart for the Town of Chapel Hill.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 38
2016 NPDES MS4 Permit Renewal Application

23 ATTACHMENT 2
Organizational chart for the Town of Chapel Hill PUBLIC WORKS DEPARTMENT.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 39
2016 NPDES MS4 Permit Renewal Application

24 ATTACHMENT 3
Organizational chart for the Town of Chapel Hill PUBLIC WORKS DEPARTMENT – STORMWATER
MANAGEMENT PROGRAM.

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 40
2016 NPDES MS4 Permit Renewal Application

25 ATTACHMENT 4

NPDES RPE Stormwater Permit Application
VII. NARRATIVE STORMWATER MANAGEMENT PROGRAM REPORT
Town of Chapel Hill Page 41
2016 NPDES MS4 Permit Renewal Application