TITLE: Title
Planned NPDES Stormwater Permit Audit
PURPOSE: The purpose of this agenda item is to inform the Council of the planned audit for the Town’s NPDES stormwater permit.
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DEPARTMENT: Public Works
CONTACT INFORMATION: Randy Dodd, Stormwater Utility Manager, (919) 918-7341; Heather Holley, Stormwater Specialist, (919) 918-7426
INFORMATION: Staff received notification that an audit is planned for May 19th for the Town’s NPDES Phase II stormwater permit. This will be the first permit audit since the permit was originally issued in 2005. As included in recent monthly stormwater reports, the EPA began a statewide compliance initiative in North Carolina, with administration from the NC Division of Environmental Quality (NCDEQ). In 2019, compliance audits were incorporated into the NPDES program as a component of the permit renewal process, and an audit schedule was instituted for renewal of 20% of the permits (109 are active in NC) each year. NPDES permits require the implementation of a comprehensive stormwater management program to reduce pollutants in stormwater runoff to the Maximum Extent Practicable (MEP). The MEP is based upon implementation of six Minimum Control Measures (MCMs) throughout the jurisdictional area:
Public Education & Outreach
Public Involvement & Participation
Illicit Discharge Detection & Elimination
Construction Site Runoff Controls (Carrboro has delegated to Orange County)
Post-Construction Site Runoff Controls
Pollution Prevention & Good Housekeeping for Municipal Operations
NCDEQ staff have informed permittees over the past year about the new audits and compliance expectations (see attachment). 90% of the 30 permittees that have already received an audit have either received a Notice of Violation (24 permittees) or Notice of Deficiency (3 permittees). NOVs require an elected official resolution committing to improved performance as part of preparing for and implementing a reissued permit. Stormwater staff have been preparing for the audit in recent months, will turn additional attention to preparation over the next month, and provide a report after the audit.
FISCAL & STAFF IMPACT: There is no fiscal impact associated with accepting this report. There will be a staff impact in preparing for and following up on the audit regardless of the outcome, especially over the next roughly 6 months in preparation for permit reissuance.
RECOMMENDATION:r The staff recommends that the Town Council receive the staff report.