NCS000584_Lexington 2019 Annual Report_20191029

NPDES Phase II Stormwater
Annual Report
City of Lexington
Fiscal Year
2018 - 2019

Prepared by:
Josh Johnson, P.E.
And

Phil Ross
Stormwater Program
Coordinator

alley, williams, carmen & king, inc.
engineers and architects
740 chapel hill road - post office box 1179
burlington, north carolina 27216-1179
Phone: [phone]
Fax: [phone]

City of Lexington Stormwater Annual Report
2018
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Report Outline
• Introduction
• NPDES Phase II
o Minimum Control Measures
 Public Education and Outreach
 Public Involvement and Participation
 Illicit Discharge Detection and Elimination
 Construction Site Runoff Controls
 Post Construction Stormwater Management
 Pollution Prevention and Good Housekeeping
• Impaired Waters and TMDL Waters
o Listing of Impaired Waters
 Impairment Type
 Timeline for Improvements
 Current Status
• High Rock Lake
• Stormwater Funding
• Future Issues
• Program Contacts
City of Lexington Stormwater Annual Report
2018
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Introduction

On July 1, 2005, The North Carolina Division of Water Quality (DWQ) in the Department of
Environmental Quality (DEQ), formerly DENR, began issuing Phase II stormwater permits to
municipalities in North Carolina under the National Pollutant Discharge Elimination System Program
(NPDES). At the time, the NPDES Phase II Program was the latest stormwater program stemming from
the Federal Clean Water Act of 1972. Prior to the Phase II program, EPA and NC DEQ had issued NPDES
Phase I Stormwater Permits to Cities larger than 100,000 persons. In North Carolina these cities were
Raleigh, Charlotte, Fayetteville, Durham, Greensboro, and Winston Salem. The Phase II Program
included distribution of Phase II permits to municipalities less than 100,000 residents and began with
municipalities within Municipal Spheres of Influence (MSI) that were greater than 50,000 citizens.
The City of Lexington was notified on May 8, 2014 that it was subject to NPDES MS4 Permitting
requirements under Phase II because it was now located in an urbanized area (UA) according to the
2010 census. EPA now requires local governments with populations over 10,000 that own or operate an
MS4 with an urbanized area to submit an application for a Phase II Stormwater Discharge Permit.

The Phase II stormwater program was created with the intention of improving the quality of the nation’s
waterways by reducing the quantity of pollutants that stormwater transports into stormwater systems
and discharges to surface water bodies. The permit require permittees at a minimum to develop,
City of Lexington Stormwater Annual Report
2018
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implement, and enforce a stormwater program designed to reduce the discharge of pollutants from the
municipal separate storm sewer system (MS4) to the maximum extent practicable. The stormwater
program is composed of the following six management measures:
1. Public Education and Outreach
2. Public Involvement and Participation
3. Illicit Discharge Detection and Elimination
4. Construction Site Runoff Controls
5. Post-Construction Site Runoff Controls
6. Pollution Prevention and Good Housekeeping for Municipal
Operations
Each of these measures consists of required Best Management Practices (BMPs), measurable goals for
each BMP and an implementation schedule for the 5 year permit cycle. Additionally, the City of
Lexington has a Comprehensive Stormwater Management Program and completes annual reporting
about the NPDES Phase II Program. Because the NPDES Program concentrates on water quality it has
limited provisions concerning water quantity and flooding controls.
On November 11, 2016, NC DWQ issued the City of Lexington a NPDES Phase II Permit. A copy of the
permit is available either through the cities Stormwater Administrator or through the NC Division of
Energy, Mineral and Land Resources.
This Report is intended to complete the Annual Report specifying the City’s progression in implementing
the NPDES Permit and Comprehensive Stormwater Management Plan (CSWMP). It is also intended to
give readers a comprehensive idea of the City’s full Stormwater Program.
NPDES Phase II Minimum Control Measures
Each of the 6 Minimum Control Measures (MCM’s) has a set of best management practices (BMP’s) that
are intended to foster compliance with both the City’s Permit and CSWMP. These specific BMP’s can be
found in both the Permit and the CSWMP but highlights and specific actions will be noted in the report.
Public Education and Outreach
The City operates a Public Education and Outreach program that is designed to educate the general
public about the need to improve water quality in stormwater. The general objectives are to distribute
education materials to the community and/or to conduct equivalent outreach activities about the
impacts of stormwater discharges on surface waters and the steps the public can take to reduce
pollutants in stormwater runoff. These objectives have been further refined to target residents, school
children, local businesses (specifically gas station owners and landscaping companies) and industry
because these groups have the most impact on stormwater pollution prevention.
The education program targets total suspended solids (TSS and Sediment) and nutrient loading because
turbidity, sedimentation, and nutrients are the pollutants of concern in downstream waters.
City of Lexington Stormwater Annual Report
2018
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The City partners with Stormwater SMART, an education and outreach organization hosted by the
Piedmont Triad Regional Council (PTRC). Stormwater SMART is a cooperative group that is funded by
several Piedmont municipalities. It was created in 2005 to provide education and outreach for the new
MS4 Permittees (like Lexington) and concentrates on direct education of school children and residents.
Danica Heflin is the Stormwater Smart Outreach and Education Coordinator and a copy of Stormwater
SMART’s Annual Report is available at http://www.ptrc.org/services/regional-planning/stormwater-
smart/documents-resources and provides a comprehensive outlook for the Fiscal Year 2018 period.
Appendix A of the annual report provides specific details of outreach efforts within the City of Lexington.
Danica Heflin can be contacted at [e-mail] or at [phone].
Lexington, NC
Event Date Event Type # attending
Multicultural Fest 5/4/2019 Festival Outreach 289

Lexington BBQ Festival 10/27/18 Outreach 549

Community Litter Cleanups

Lexington Appearance
Commission

5/18/19 Litter Collection 50+/ 30+ bags

Councilor Lanier-Ward 5

5/17/2019 Litter Collection 8 +/ 5+ bags

Councilor Holt-Ward 1

5/18/19 Litter Collection 15+/ 10 + bags

Jennifer Leonard (LAC member)

5/1/19 Litter Collection 15+/ 15+ bags
Total 926

Stormwater Outreach Efforts in Lexington
The City also has handouts on display at the Lexington City Hall and the Lexington Library. The City’s
Stormwater website can be found under Public Services / Water Resources at:
https://www.lexingtonnc.gov/city-services/public-utilities/water-resources/lexington-stormwater. It
also includes a link to Stormwater SMARTs website under the “Stormwater Education Section” page.
City of Lexington Stormwater Annual Report
2018
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The placement of 3 Healthy watershed Signs (see picture)
help to educate the public of the need to protect
watersheds within the City. These signs are located at
Finch Park, Washington Park and Jaycee Park.
To help decrease the buildup of Fats, Oils and Grease in the
sewer lines 179 food service Brochures with Stormwater
Pollution Prevention information were mailed out to local
City restaurants on November 11, 2018.
Also 250 Flyers were distributed to Residents on October 9,
2018 at the Utility Customer Appreciation Day Event.

Public Participation and Involvement
The City has a responsibility to solicit and consider public opinion on all matters, including stormwater
management. The City currently has a Helpline through Public Services to report Stormwater or stream
issues Monday – Friday – 8am to 5pm – Ph. 336-248-3930. Stormwater SMART activities help to
promote public involvement and educate the public especially at the school age levels. They have also
set up a booth to distribute stormwater materials at the annual Barbeque Festival held in the fall and
the Multicultural Festival held each spring. Events that attracts over 100, 000 people to Uptown
Lexington. The City will plan to hold a Stormwater Public Meeting as needs arise. Public meetings seek
the citizens input on the stormwater program and will provide a platform for the City to further educate
its citizens as well.

Brochures and Flyers
City of Lexington Stormwater Annual Report
2018
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Illicit Discharge Detection and Elimination
The City of Lexington has a full Illicit Discharge Detection and Elimination (IDDE) Program. The IDDE
Program is intended to reduce discharges to the stormwater system that are not entirely composed of
stormwater. There are a few permitted discharges and firefighting related discharges that are allowed.
An illicit discharge is typically dirt, soap, pet waste, litter, oil, fertilizer, pesticides, or raw sewage and
often times comes from “generating sites.” Generating sites are points of pollution that continue over a
period and are recurring at regular or irregular intervals.
The backbone of the IDDE program is the IDDE Ordinance that the City passed in 2017. The IDDE
ordinance provides permits specific discharges into the MS4 as legal, provides legal authority to restrict
illegal discharges, prohibits illicit connections, provides conditions for cleaning up and preventing
polluted spills, provides for right of entry into property to investigate prohibited activities, and provides
the City with options for enforcing the Ordinance. The IDDE Ordinance is based on the NC DWQ’s Model
Ordinance.
The second basis for the IDDE program is the City’s MS4 GIS Map. The GIS program was completed in
the past by a City Surveyor and digitized from Mylar maps. The maps includes the entire MS4 system
and provides for easy access to aid in the investigation of illicit discharges. An investigator with the GIS
map could find an illicit discharge and then easily follow the flow of the discharge upstream until finding
a source of the discharge.

Lexington GIS Map
City of Lexington Stormwater Annual Report
2018
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The Lexington GIS Map has a drainage layer that shows piping location and size, basins and direction of
flow. Other useful layers include creeks and ponds, FEMA flood information, USGS, Lot ownership lines,
property information, aerials and topographic layers. The city receives updates to the program nightly
from the county and the city updates the information as needed. The GIS Information can be accessed
through The City of Lexington’s Engineering and Development Services.
The IDDE program includes smoke testing storm drainage lines, in 2018 approximately 800 linear feet
was done. Outfalls that have dry weather flows are reported and investigated. To date, most dry
weather flow testing has been done in conjunction with complaints or City staff investigations.
The City had three sanitary sewer overflows (SSO’s) during 2018 reported by city staff and citizens and
the causes included debris in lines, grease, roots, pipe failures, inflow and infiltration, and severe natural
conditions. All 3 were repaired. In 2018 approximately 13, 000 Linear feet of the system was video
inspected for problems and blockages.
The City had no Capital Improvement Projects planned for stormwater or sanitary sewer Improvements
in 2018.
The City received 834 complaints of illegal dumping in 2018. Cases were investigated and were typically
issues of junk and general debris. 833 cases were resolved.
There were no illicit connections and no rerouted connections identified by the City during 2018.

City of Lexington Stormwater Annual Report
2018
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Lexington Watershed Map
Construction Site Runoff Controls
The City of Lexington delegates the Construction Site Runoff Controls to NC DEQ. The City of Lexington
does not have a delegated erosion control program but does make sure that plans it approves that will
disturb greater than 1.0 acres of land apply for, and receive, an erosion control plan. The City of
Lexington also has the ability to call NC DEQ to report known sedimentation issues.
Post Construction Site Runoff Controls
The City of Lexington has a typical NPDES Phase II Post Construction Program. This includes a Post
Construction Ordinance, administrative forms that support it, and a review process. The Post
Construction Program applies to projects that exceed 1 acre of disturbance or have a common plan of
development that will cumulatively exceed 1.0 acres of disturbance. Projects that exceed 24% built-
upon area are considered high density projects, projects that are less than 24% BUA are low density
projects. High Density Projects are then required to meet the following requirements:
• Treat runoff from the first 1” of rain (the first flush).
• Treated Runoff is to be for 85% TSS removal.

City of Lexington Stormwater Annual Report
2018
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• Discharge treated water at a rate less than or equal to the Predevelopment rate for the 1 year
24 hour storm.
• Discharge treated water between 48-120 hours.
• Stormwater Control Measures must be in easements and must have a recorded operation and
maintenance agreement.
• Compliance with 30’ vegetated buffers on perennial and intermittent streams.
Stormwater Control Measures, as well as runoff calculations, are prepared based upon the NC DEQ BMP
Manual and then reviewed by Josh Johnson, P.E.

Lexington Stormwater Management Permit Application

Low Density projects are required to comply with the stream buffer regulations. Both Low and High
Density Projects are required to comply with the City’s Storm Sewer Design Manual which governs
storm drainage design as well as peak runoff rates.
When a project is submitted to the City it goes through the Water/ Waste Water Administration. The
Stormwater Administrator then determines if the project is subject to the Stormwater Ordinance and
High Density or Low Density. If the project exceeds 1.0 acres then a copy of the plan is sent to Josh
Johnson, P.E. with Alley, Williams, Carmen, and King, Inc. At that point review comments are made
about the project and addressed. After approval of the project, the owner is required to complete an
Operation and Maintenance Agreement for the stormwater control measures. This O&M agreement is
then recorded with the register of deeds so that it can reviewed at a later point in time.
City of Lexington Stormwater Annual Report
2018
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The City of Lexington reviewed 71 projects in 2018, 1 of which triggered the stormwater ordinance. The
City reviewed an additional 70 projects that did not cross the disturbance threshold including remodels
and additions.
The City of Lexington requires as-builts and annual inspection reports from new stormwater control
measures (SCM). In the coming year the City will inspect the existing stormwater control measures and
then provide the property owners with the inspection report and the needed improvements. This letter
will also contain information requiring SCM owners to provide future inspection reports to the City or
face fines and/or assessments.
Pollution Prevention and Good Housekeeping
Pollution Prevention is an overall goal of the City’s stormwater management plan and Good
Housekeeping is a key to that goal. Municipalities, in general, conduct many activities that can pose a
threat to water quality. Municipal facilities are the primary potential source of contamination but with
good housekeeping habits this potential can be reduced or eliminated. The City attempts to minimize
stormwater pollution from municipal operations by complying with best management plans for each
City facility. The BMP’s are written into a City Facilities O&M Plan that is intended to reduce or eliminate
stormwater exposure of oil, grease, pesticides, herbicides, fertilizers, sediment, and other materials
used by the City. Currently the City is inspecting operational facilities which pose the greatest potential
for stormwater concerns. Annual Inspections are planned for the coming year for each of the City
facilities. Any issues will be noted, written into the Facility O&M Plan, and discussed with the facility
supervisor.
The City operates many different facilities including the following:
Name of Facility Address
Waste Water Treatment Plant 500 Glendale Rd.
Water Treatment Plant 2979 Greensboro St. Ext.
Water Resources Dept. 711 S. Talbert Blvd.
Street/Sanitation/Public Grounds 310 S. Talbert Blvd.
Lexington Utilities 425 Carolina Avenue
Lexington Garage 507 Carolina Avenue
Lexington Aquatic Park 207 Forest Rose Drive
Finch Park & Ball Fields 15 Paul Beck Rd
Washington Park and Splash Park 100 Brookington Rd
Lexington Golf Club 200 Country Club Blvd.

City of Lexington Stormwater Annual Report
2018
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City staff with the greatest exposure to stormwater will be trained in the coming year on PPGH once
annually. The training is combined with illicit discharge detection and elimination training. The PPGH
portion of the training concentrates on good housekeeping functions. This often includes identification
of bad habits that can take place and how to fix the situation to reduce the risk of pollution to
stormwater.
The City of Lexington sweeps streets annually through the City’s street department. In 2018 it swept a
total of 1,198 miles (18 miles uptown every Friday and 20 miles in one of 4 zones on the same day)
collecting a total of 823 Cuyds of debris. The debris typically is approx. 75% inorganic and 25% organic.
The City is also in year one of a four year Brown Cart Recycling Program. This pilot program collects yard
waste i.e., grass leaves, hedge trimmings and small sticks weekly from residents. This program is in
addition to the larger leaf collection efforts in held from October through December.
The City of Lexington put out 100 tons of road salt in 2018. It also recycled 1650 gallons of oil through
Clean Green and the fleet started to using recycled oil for heating.
The City cleans culvert pipes and drainage ditches on an as requested basis and cleans storm drains
ahead of predicted large precipitation. Culvert pipes are cleaned by jet truck, ditches by backhoe and
hand and inlets by hand as needed and during the fall leaf season.
The City has one pet waste station at Meyers Park.
Impaired Waters and Total Maximum Daily Loads (TMDL)
Lexington is in the Yadkin- Pee- Dee River Basin
Swearing Creek and Abbots Creek pass within or in the edge of Lexington’s jurisdiction and are listed on
the “2014 Category 5 Water Quality Assessments 303(d) List”. However, no TMDLs for these streams
have been established at this time.

Receiving Stream Name

Stream
Segment

Water Quality
Classification

Overall
Category
Use
Support
Rating
Swearing Creek 12-113 C 5 Impaired
Rat Spring Branch 12-113-5 C ND -
Tar Creek 12-113-6 C ND -
North Potts Creek
(Michaels Branch)
12-113-3 C ND -
Abbotts Creek 12-119-6b C Impaired Impaired
City of Lexington Stormwater Annual Report
2018
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Abbotts Creek 12-118.5 WS-V,B Impaired Impaired
ND – No Data
High Rock Lake Rules
The City of Lexington is within the High Rock Lake Watershed. High Rock Lake is impaired for elevated
levels of turbidity, chlorophyll a, and pH. The chlorophyll a and pH impairments are primarily associated
with excess algal growth, which is caused by elevated nutrient loading to the lake (primarily nitrogen
and phosphorous). The turbidity impairment is also related to the algal growth within the lake but is
primarily due to upstream sedimentation to the lake. The Lake has a drainage area of 3,974 square
miles, although a portion of that watershed (367 square miles) is within the Kerr Lake watershed. The
dam for High Rock Lake is about _15_ miles from the center of Lexington and Lexington is one of several
urbanized centers within the watershed. The other urbanized areas include Winston-Salem, Salisbury,
High Point, and Thomasville.

High Rock Lake Watershed from Watershed Model - NC
DENR

City of Lexington Stormwater Annual Report
2018
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NC DEQ has been working on potential solutions to improve water quality within High Rock Lake for
several years and expects to develop the Nutrient Management Strategy. High Rock Lake is listed as the
number one priority on the State of North Carolina’s Nutrient Development Criteria Plan but is currently
on hold due to NC DEQ staffing restrictions. The City of Lexington should be heavily involved in the
stakeholder process and should evaluate how it’s improvements to its Collection System may already be
contributing to improving water quality within downstream waters.
Stormwater Funding
The City of Lexington currently funds it’s Stormwater Programs through the City General Fund. The City
uses these funds to pay for its Water Quality Programs including its NPDES Phase II and
Inflow/Infiltration/Exfiltration Program and/or studies. The City’s Stormwater Budget for the 2018-2019
Calendar Year is $10,360 (plus city department’s staff, material and equipment). Additional funding is
expected in 2019-2020. New funding mechanisms will be evaluated for future budget years.
The Future of Stormwater
Stormwater, and Water Quality in particular, is an evolving field of regulation. The City of Lexington is
already involved in NPDES Phase II, Biological Integrity within streams, and will soon be involved in
Nutrient Sensitive Waters with High Rock Lake. Within the next decade the City needs to plan for further
regulation of these issues as well as several other outstanding issues. EPA continues to work on two
potentially large future items that include a Numerical Nutrient Criteria for all surface waters and a
National Stormwater Rule. The Numerical Nutrient Criteria is an EPA supported push towards
establishing nutrient limits for all surface waters. Currently in North Carolina, generally only reservoirs
have nutrient limits and the limits are based upon response indicators.
Stormwater Program Contacts
Name Position Phone # Email
Roger Jones, P.E. Public Services
Manager
[phone] [e-mail]
Josh Johnson, P.E. Consultant Engineer [phone] [e-mail]

Terra A. Greene City Manager [phone] [e-mail]