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Home My WebLink AboutNCS000421_High Point Draft SWMP_20200924DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Draft Stormwater Management Plan City of High Point NCS000421 September 24, 2020 DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Table of Contents PART 1:INTRODUCTION .......................................................................................................1 PART 2:CERTIFICATION .......................................................................................................2 PART 3:MS4 INFORMATION ................................................................................................3 3.1 Permitted MS4 Area ....................................................................................................3 3.2 Existing MS4 Mapping ................................................................................................4 3.3 Receiving Waters ........................................................................................................4 3.4 MS4 Interconnection ...................................................................................................5 3.5 Total Maximum Daily Loads (TMDLs) .......................................................................5 3.6 Endangered and Threatened Species and Critical Habitat .............................................6 3.7 Industrial Facility Discharges ......................................................................................6 3.8 Non-Stormwater Discharges ........................................................................................8 3.9 Target Pollutants and Sources .................................................................................... 10 PART 4:STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ..................... 11 4.1 Organizational Structure ............................................................................................ 11 4.2 Program Funding and Budget .................................................................................... 13 4.3 Shared Responsibility ................................................................................................ 13 4.4 Co-Permittees ........................................................................................................... 14 4.5 Measurable Goals for Program Administration........................................................... 14 PART 5:PUBLIC EDUCATION AND OUTREACH PROGRAM ........................................... 16 PART 6:PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ............................. 22 PART 7:ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM ................. 24 PART 8:CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ..................................... 30 PART 9:POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM........................... 36 PART 10:POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ......... 41 DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Table 1: Summary of MS4 Mapping List of Tables Table 2: Summary of MS4 Receiving Waters Table 3: Summary of Approved TMDLs Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality Table 5: NPDES Stormwater Permitted Industrial Facilities Table 6: Non-Stormwater Discharges Table 7: Summary of Target Pollutants and Sources Table 8: Summary of Responsible Parties Table 9: Shared Responsibilities Table 10: Co-Permittee Contact Information Table 11: Program Administration BMPs Table 12: Summary of Target Pollutants & Audiences Table 13: Public Education and Outreach BMPs Table 14: Public Involvement and Participation BMPs Table 15: Illicit Discharge Detection and Elimination BMPs Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Table 17: Construction Site Runoff Control BMPs Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program Table 19: Summary of Existing Post-Construction Program Elements Table 20: Post Construction Site Runoff Control BMPs Table 21: Pollution Prevention and Good Housekeeping BMPs DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 1 PART 1: INTRODUCTION The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the City of High Point will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. This SWMP identifies the specific elements and minimum measures that the City of High Point will develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with the MS4 Permit number NCS000421, as issued by NCDEQ. This permit covers activities associated with the discharge of stormwater from the MS4 as owned and operated by the City of High Point and located within the corporate limits of the City of High Point. In preparing this SWMP, the City of High Point has evaluated its MS4 and the permit requirements to develop a comprehensive 5-year SWMP that will meet the community’s needs, address local water quality issues and provide the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for permit compliance and the community’s needs. Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along with any approved modifications of the SWMP, are incorporated by reference into the permit and become enforceable parts of the permit. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 3 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits of the City of High Point, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits of City of High Point as of the date of this document. As of January 2020, the jurisdictional and MS4 service area for the City of High Point is 57.8 square miles. The source of this information is the City of High Point, Public Services Department and Planning & Development Department, which updates jurisdictional and geographical boundaries as changes occur. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 4 3.2 Existing MS4 Mapping The current MS4 mapping includes pipes, flow direction, ditches, inlets, catch basins, manholes, outfalls, sizes, condition, etc., and is contained in our GIS mapping program and in a secure layer of thePoint. The City of High Point does not provide access to stormwater structural layers to the general public. Table 1: Summary of MS4 Mapping Percent of MS4 Area Mapped 99% No. of Major Outfalls* Mapped 1203 as of 9-15-2020 *An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch) directly into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned areas a 12-inch diameter pipe or a drainage area > 2-acres. 3.3 Receiving Waters The City of High Point MS4 is located within the Cape Fear and Yadkin River Basins and discharges directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below are compiled from the following NCDEQ sources: o Waterbody Classification Map o Impaired Waters and TMDL Map o Most recent NCDEQ Final 303(d) List Table 2: Summary of MS4 Receiving Waters Cape Fear River Basin East Fork of Deep River Receiving Stream Name Index # Water Quality Classification 303 (d) List East Fork of Deep River 17-2-(0.3) WS-IV Fecal Coliform; Turbidity East Fork of Deep River 17-2-(0.7) WS-IV CA Fecal Coliform; Turbidity Long Branch Long Branch 17-2-1-(1) WS-IV Eco/Biological Integrity Fish Com Eco/Biological Integrity Benthos Long Branch 17-2-1-(2) WS-IV CA Eco/Biological Integrity Fish Com Eco/Biological Integrity Benthos DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 5 Boulding Branch Boulding Branch 17-3-2 WS-IV N/A West Fork of Deep River West Fork of Deep River 17-3-(0.3) WS-IV Eco/Biological Integrity Fish Com West Fork of Deep River 17-3-(0.7) WS-IV CA Eco/Biological Integrity Fish Com Richland Creek Richland Creek 17-7-(0.5) WS-IV Fecal Coliform Richland Creek 17-7-(4) WS-IV;CA Fecal Coliform Yadkin River Basin Rich Fork Creek Rich Fork Creek 12-119-7 C Fecal Coliform 3.4 MS4 Interconnection The City of High Point MS4 is not interconnected with another regulated MS4 and directly discharges to the receiving waters as listed in Table 2 above. 3.5 Total Maximum Daily Loads (TMDLs) The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program has been implemented to address the WLA. Table 3: Summary of Approved TMDLs Water Body Name TMDL Pollutant(s) of Concern Stormwate r Waste Load Allocation (Y/N) Water Quality Recover y Program (Y/N) E. Fork Deep River Fecal Coliform Y Y1 Richland Creek Fecal Coliform Y Y2 Rich Fork Creek Fecal Coliform Y Y1 Y1 : Outfall monitoring program only Y2 : TMDL water quality monitoring plan (2015) DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 6 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or critical habitat are identified within the regulated MS4 urbanized area, as determined by a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service. Of those species listed, Table 4 summarizes the species that may be significantly impacted by the quality of surface waters within their habitat. Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality Scientific Name Common name Species Group Federal Listing Status County Fusconaia masoni Atlantic pigtoe Clams Proposed Threatened Guilford Randolph Notropis mekistocholas Cape Fear Shiner Fish Endangered Guilford Randolph Percina rex Roanoke logperch Fish Endangered Guilford Isotria medeoloides Small whorled pogonia Flowering Plants Threatened Guilford Helianthus schweinitzii Schweinitz's sunflower Flowering Plants Endangered Davidson Guilford Randolph Perimyotis subflavus Tricolored bat Mammals Under Review Davidson, Forsyth Clemmys muhlenbergii Bog Turtle Reptiles Threatened Forsyth 3.7 Industrial Facility Discharges The City of High Point MS4 jurisdictional area includes the following industrial facilities which hold NPDES Industrial Stormwater Permits, as determined from the NCDEQ Active NPDES Stormwater Permit List and/or Active Stormwater Permits Map. Table 5: NPDES Stormwater Permitted Industrial Facilities Permit Number Facility Name NCG030009 Thomas Built Buses Inc - High Point NCG030010 Thomas Built Buses Incorporated (Cape Fear River Basin) NCG030010 Thomas Built Buses Incorporated (Yadkin River Basin) DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 7 NCG030517 Mickey Truck Body Inc - High Point NCG050370 Innocor Foam Technologies - ACP, Inc. NCG060003 Kao Specialties Americas LLC NCG060041 Piedmont Chemical Ind I LLC NCG060205 Custom Finishers Incorporated NCG060244 Hunter Farms Dairy NCG060359 Innospec Performance Chemicals NCG060381 Cambrex High Point, Inc. NCG070029 Glass Unlimited-High Point Inc NCG080683 High Point City-Fleet Maintenance Facility NCG080702 High Point City Transit NCG090020 Axalta Coating Systems U.S.A., LLC (High Point) NCG090021 Akzo Nobel Coatings Incorporated NCG120105 Kersey Valley MSW Landfill NCG140003 Childers Concrete NCG140215 ARGOS USA - High Point Concrete Facility (previously Ready Mixed Concrete Plant 75) NCG160041 Larco Construction Co - High Point NCG170388 Chambers Fabrics Incorporated NCG180036 Haworth Inc-Wood Seating Plant NCG180220 High Point Furniture Industries NCG180254 Marsh Furniture Co NCG240007 City of High Point Ingleside Compost Facility NCGNE0048 Premiere Cushion-Hickory Springs Mfg. Co. NCGNE0104 Leggett & Platt Inc-Guilford NCGNE0118 Patheon Softgels Inc. NCGNE0134 Environmental Air Systems Inc NCGNE0150 Patrician Furniture Co NCGNE0166 Poly Pride, Inc. NCGNE0241 Ultra -Flex NCGNE0264 Carpenter Co - High Point NCGNE0281 Henredon Furniture-Guilford DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 8 NCGNE0284 Carson's Hospitality NCGNE0291 Novamelt Americas LLC NCGNE0313 Sunrise Medical DC NCGNE0325 Suiza Dairy Group, LLC (dba Dairy Fresh, LLC)-High Point NCGNE0482 V & E Components Inc NCGNE0497 Triad Fabco Industries NCGNE0498 Triad Fabco Industries-High Point NCGNE0517 Leggett & Platt, Inc. NCGNE0615 General Elastic Corp-Randolph NCGNE0751 Baltek, Inc NCGNE0758 Axalta Coating Systems U.S.A., LLC NCGNE0766 Harriss & Covington Hosiery NCGNE0791 Mannington Wood Floors NCGNE0839 Gotico Furniture and Accents NCGNE0863 NC National Guard High Point Armory & FMS #8 NCGNE0951 Hancock & Moore, LLC NCGNE0970 Baker Interiors Furniture Company - High Point NCGNE0991 Syntec Seating Solutions LLC NCGNE1022 High Point Furniture Industries NCGNE1131 Fastenal Company NCGNE1144 V&E Components, Inc. NCGNE1208 Thomas Clyde Lamar ARC NC028 NCGNE1227 Fortis Solutions Group NCGNE1255 Ornamental Products LLC NCGNE1323 Waste Industries LLC NCGNE1384 Freud America - High Point - 218 Feld NCGNE1385 Freud America - High Point - 220 Feld NCS000421 High Point city - Small MS4 NCS000582 Ennis Flint DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 9 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the City of High Point as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The City of High Point has evaluated residential and charity car washing and street washing for possible significant water quality impacts. Street washing discharges are addressed under the Pavement Management Program in Part 10 of this SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the City of High Point. Wash water associated with car washing that does not contain detergents or does not discharge directly into the MS4 is considered incidental. However, these types of non-stormwater discharges that do contain detergents have not been evaluated by the City of High Point to determine whether they may significantly impact water quality. However, the City of High Point will continue to educate the general public on the hazards associated with car washing. Measures to address these target pollutants are provided in Parts 5 of this SWMP. Table 6: Non-Stormwater Discharges Non-Stormwater Discharge Water Quality Impacts Water line and fire hydrant flushing Incidental Landscape irrigation Incidental Diverted stream flows Incidental Rising groundwater Incidental Uncontaminated groundwater infiltration Incidental Uncontaminated pumped groundwater Incidental Uncontaminated potable water sources Incidental Foundation drains Incidental Air conditioning condensate Incidental Irrigation waters Incidental Springs Incidental Water from crawl space pumps Incidental Footing drains Incidental Lawn watering Incidental Residential and charity car washing Possible Flows from riparian habitats and wetlands Incidental Dechlorinated swimming pool discharges Incidental Street wash water Possible Flows from firefighting activities Incidental DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 10 3.9 Target Pollutants and Sources In addition to those target pollutants identified above, the City of High Point is aware of other significant water quality issues within the permitted MS4 area. Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the likely activities/sources/targeted audiences attributed to each pollutant and identifies the associated SWMP program(s) that address each. In addition, the City of High Point has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing Target Pollutant(s)/Audience(s) Litter General Public, Businesses, Schools Public Education & Outreach, Public Participation Pet Waste General Public, Schools, Parks, Greenways Public Education & Outreach, Illicit Discharge Detection & Elimination Sediment Construction Erosion, Stream Bank Erosion Construction Site Runoff Control Illicit Discharges General Public, Businesses, Municipal Employees Public Education & Outreach, Illicit Discharge Detection & Elimination, Public Involvement Illegal Dumping General Public, Businesses, Municipal Employees Public Education & Outreach, Illicit Discharge Detection & Elimination, Pollution Prevention & Good Housekeeping DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 11 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure The Stormwater Division is responsible for compliance of the City of High Point’s NPDES Permit. All related activities/requirements/etc. for compliance are the responsibility of the Stormwater Division, with the exception of Engineering Services, which oversees the Construction Runoff portion of the Permit. See Appendix A for Organizational Chart. Table 8: Summary of Responsible Parties SWMP Component Responsible Position Staff Name Department Stormwater Program Administration Public Services Assistant Director Robby Stone Public Services SWMP Management Public Services Manager Operations Analyst Trevor Spencer Anita Simpson Public Services – Stormwater Division Public Education & Outreach Stormwater Specialists Robbie Baker, Kelsie Burgess, Abigail Rosendale Public Services – Stormwater Division Public Involvement & Participation Stormwater Specialists Robbie Baker, Kelsie Burgess, Abigail Rosendale Public Services – Stormwater Division Illicit Discharge Detection & Elimination Stormwater Specialists Robbie Baker, Kelsie Burgess, Abigail Rosendale Public Services – Stormwater Division Construction Site Runoff Control Erosion Control Inspectors Scott Ford, Kathy Blake Engineering Services Post-Construction Stormwater Management Operations Analyst Anita Simpson Public Services – Stormwater Division DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 12 Pollution Prevention Good Housekeeping for Municipal Operations Stormwater Specialists Robbie Baker, Kelsie Burgess, Abigail Rosendale Public Services – Stormwater Division Municipal Facilities Operation & Maintenance Program Stormwater Specialists Robbie Baker, Kelsie Burgess, Abigail Rosendale Public Services – Stormwater Division Spill Response Program All Stormwater Division Staff All Stormwater Division Staff Public Services – Stormwater Division MS4 Operation & Maintenance Program Public Services Director Public Services Assistant Director Terry Houk Robby Stone Public Services Municipal SCM Operation & Maintenance Program Public Services Manager Trevor Spencer Public Services – Stormwater Division Pesticide, Herbicide & Fertilizer Management Program Safety Officer Jim Gwynn Public Services Vehicle & Equipment Cleaning Program Public Services Manager Trevor Spencer Public Services – Stormwater Division Pavement Management Program Public Services Manager Superintendent of Street Maintenance Trevor Spencer Ken Sult Public Services – Streets and Stormwater Divisions Total Maximum Daily Load (TMDL) Requirements Operations Analyst Stormwater Specialists Anita Simpson Robbie Baker, Kelsie Burgess, Abigail Rosendale Public Services – Stormwater Division DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 13 4.2 Program Funding and Budget In accordance with the issued permit, the City of High Point shall maintain adequate funding and staffing to implement and manage the provisions of the SWMP and comply with the requirements of the NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is billed by the Division annually. The stormwater program is funded through a stormwater utility fee charged to property owners within city limits. Residential customers are charged 1 Equivalent Residential Unit (ERU) of $4 per month. All commercial and industrial properties are charged based on the total amount of impervious area on a property divided by the ERU (Equivalent Residential Unit) of 2,588 square feet multiplied by $4 per month. Example: 100,000 sq. ft. / 2588 sq. ft. = 38.64 ERU, 38.64 ERU X $4 per month = $154.56 per month for the stormwater utility fee. The stormwater utility fee sufficiently funds program needs and services, and a staff of 26 employees. The staff consists of 1 Public Services Manager, 1 Operations Analyst, 1 GIS Analyst, 2 Administrative Associates, 3 Stormwater Specialists, 2 Stormwater Supervisors for field service crews, 1 Stormwater Technician (camera truck operator), and 15 Motor Equipment Operators for field serv ice crews. The stormwater utility fee collects revenue in excess of $5.45 million annually, while the Stormwater Division has a total operating budget of approximately $2.9 million. 4.3 Shared Responsibility The City of High Point does not share the responsibility to implement any of the six minimum control measures. Table 9: Shared Responsibilities SWMP BMP or Permit Requirement Implementing Entity & Program Name Legal Agreemen t (Y/N) N/A DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 14 4.4 Co-Permittees The are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000421 for the City of High Point. Table 10: Co-Permittee Contact Information Co-Permittee MS4 Name Contact Person Phone & E-Mail Interlocal Agreemen t (Y/N) N/A 4.5 Measurable Goals for Program Administration The City of High Point will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. Table 11: Program Administration BMPs Permit Ref. 2.1.2 and Part 4: Annual Self -Assessment Measures to evaluate the performance and effectiveness of the SWMP program components at least annually. Results shall be used by the permittee to modify the program components as necessary to accomplish the intent of the Stormwater Program. The self-assessment reporting period is the fiscal year (July 1 – June 30). BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Annual Self-Assessment Perform an annual evaluation of SWMP implementation, suitability of SWMP commitments and any proposed changes to the SWMP utilizing the NCDEQ Annual Self- Assessment Template. 1. Prepare, certify and submit the Annual Self-Assessment to NCDEQ prior to October 31st each year. 1. Annually Permit Years 1-4 1. Annual Self- Assessment received by NCDEQ no later than October 31st each year. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 15 Permit Ref. 1.6: Permit Renewal Application Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4 permit. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 2. Permit Renewal Application Audit stormwater program implementation for compliance with the permit and approved SWMP and utilize the results to prepare and submit a permit renewal application package. 1. Participate in an NPDES MS4 Permit Compliance Audit, as scheduled and performed by EPA or NCDEQ. 1. TBD – Typically Permit Year 4 1. N/A 2. Self-audit and document any stormwater program components not audited by EPA or NCDEQ utilizing the DEQ Audit Template. 2. Permit Year 5 2. Submit Self-Audit to DEMLR (required component of permit renewal application package). 3. Certify and submit the stormwater permit renewal application (NOI, Self-Audit, and Draft SWMP for the next 5 -year permit cycle). 3. Permit Year 5 3. Permit renewal application package received by DEQ at least 180 days prior to permit expiration. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 16 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The City of High Point will continue to implement a Public Education and Outreach Program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of storm water discharges on water bodies and steps the public can take to reduce pollutants in storm water runoff. The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by the Public Education and Outreach Program, are summarized in Table 12 below. In addition, the City of High Point is required to inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping and improper disposal of waste. Table 12: Summary of Target Pollutants & Audiences Target Pollutants/Sources Target Audience Litter/Household Waste General Public, Businesses Pet waste/Fecal Coliform General Public, Public/Private Sanitary Sewer Infrastructure Sediment Developers, Contractors, Homeowners, Landscapers Fats, Oils & Grease General Public, Commercial, Industrial, Food Industries Nutrients (Phosphorus/Nitrogen) General Public, Commercial, Landscaping Illicit Discharges General Public, Restaurants, Industrial, Municipal Employees Illegal Dumping General Public, Businesses, Municipal Employees The City of High Point will manage, implement and report the following public education and outreach BMPs. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 17 Table 13: Public Education and Outreach BMPs Permit Ref. 3.2.2 and 3.2.4: Outreach to Targeted Audiences Measures to identify the specific elements and implementation of a Public Education and Outreach Program to share educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The permittee shall provide educational information to identified target audiences on pollutant s/sources identified in table 12 above and shall document the extent of exposure of each media, event or activity, including those elements implemented locally or through a cooperative agreement. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. School Outreach Develop age -specific educational information for use in schools and for presentations to school age children. Will present information in appropriate format. 1. Provide age-specific presentations. 1. Permit Years 1-5 During the school year for elementary and middle school students. 1. Count number of students in attendance 2. Reach out to Guilford County Schools and Private schools Semi-Annually to remind them of the programs offered. 2. Permit Years 1-5 Once in the summer and once in January after Christmas break. 2. Document emails sent 3. Organize stream habitat events for schools and/or summer camps as requested 3. Permit Years 1-5 During the school year for elementary, middle school students, summer for camp groups. 3. Count number of students in attendance 4. *Scheduling is currently impacted due to COVID-19 4. 5. 5. 2. Public Event Tabling Set up public education table at a variety of public events and locations in order to reach diverse groups, minorities and underserved populations 1. Monthly Library Table. 1. Already in place. Permit Years 1-5. Will need to work with library for new procedures with COVID-19. 1. Track the number of interactions had at the table. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 18 2. Monthly Farmer’s Market Table 2. Already in place. Permit Years 1-5. Will need to work with library for new procedures with COVID-19. 2.Track the number of interactions had at the table using counter. 3. Attend at least 3 other City of High Point Public events. 3. Continue to work with other City divisions to remain on their list of people to contact for event tabling 3. Track the number of interactions had at the table using a counter 4. Coordinate and attend the annual Public Services Day event. 4. Speak to all division heads 2-3 months in advance to commit to a date. 4. Track number of people that come to the event and to the stormwater table. 5. Coordinate and attend one event in High Point for Guilford Creek Week. 5. Permit Years 1-5. GCW coordination begins in August of each year and events are held in March. 5. Track the number of people that come to the event and to the stormwater table. 3. Utility Bill Inserts Stormwater bill inserts will continue to be inserted into combined utility bill statements and distributed to all City residents and businesses receiving a utility bill on at least a semi - annual schedule. 1. Develop and distribute a stormwater flyer for general stormwater concepts. 1. Semi-Annually Permit Year 1 1. Document and report the topic and number of utility bill inserts distributed. 2. Develop and distribute a stormwater flyer for illicit discharges/illegal dumping and general stormwater information 2. Semi-Annually Permit Year 2 3. Develop and distribute a stormwater flyer for household wastes/automotive care and leaf pick up/yard waste. 3. Semi-Annually Permit Year 3 DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 19 4. Develop and distribute a stormwater flyer for general stormwater information and leaf pickup/yard waste. 4. Semi-Annually Permit Year 4 5. Develop and distribute a stormwater flyer for illicit discharge/illegal dumping and yard waste/leaf pickup. 5. Semi-Annually Permit Year 5 4. Stormwater Information Documents Informational pamphlets/brochures and giveaways with specific stormwater topics, as well as general information to be handed out to targeted groups and be available at all tabling events. 1. Develop a list of target audiences/groups/ businesses for each informational document. 1. Permit Years 1 -5 1. Record number of documents and give- away items distributed at each event. 2. Record the number of documents delivered to groups/businesses. 2. Develop a schedule for inventory of all informational documents and giveaways. 1. Permit Years 1 - 5 1 Document remaining totals. 5. Information Kiosks Multiple stormwater documents will be displayed at locations throughout the City including City Hall (Customer Service), Public Services Department, the City of High Point Visitors Center, Public Library, Piedmont Environmental Center and other city-maintained recreational facilities. 1. Develop a location list and schedule to regularly check kiosks to ensure brochures are available and replenished as necessary 1. Permit Year 1 1. Record the document topic and amount distributed at each location. 2. Check kiosks to ensure documents are available and replenished as necessary 2. Quarterly during Permit Year 2 3. Quarterly during Permit Year 3 DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 20 4. Quarterly during Permit Year 4 5. Quarterly during Permit Year 5 6. Social Media Work with the City of High Point’s Public Information Office to promote information about upcoming events and other stormwater- related educational information using multiple social media outlets (Facebook, Next Door, Twitter, Instagram) 1. Schedule at least 3 stormwater specific informational posts per year. 1. Continuously during Permit Years 1 -5 1. Document and report date of posts and number of views. 7. Advertisements, Media, Etc. Utilize additional physical or digital advertising spaces to increase visibility of the stormwater message. 1. At least once per year, use non-municipal website or outdoor advertisement space (e.g. La Noticia print/website, using ad space inside and outside of High Point Transit Buses, billboards, shopping carts. 1. Continuously during Permit Years 1 -5 1. Documenting and tracking will be dependent on the type of media used and their methods for tracking. Permit Ref. 2.1.7, 3.2.3 and 3.6.5(c): Web Site Measures to provide a web site designed to convey the program’s message(s) and provide online materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit and SWMP. The web page shall also provide developers with all relevant post -construction requirements, design standards, checklists and/or other materials. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 8. Informational Web Site The Stormwater Services Division will maintain an internet web site that contains detailed 1. Maintain the stormwater web page and update any changes as needed. 1. Continuously during Permit Years 1 -5 1. Document and report the number of webpage views. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 21 information regarding all aspects of the stormwater permit requirements, services offered and contact information. 2. Add a link on the Stormwater webpage to the NCDEQ Stormwater webpage 2. Permit Year 1 2. Document and report the date information was added Permit Ref. 3.2.5: Stormwater Hotline Measures for a stormwater hotline/helpline for the purpose of public education and outreach. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 9. Stormwater Hotline Dedicated Customer Service number for all Public Services has been established where citizens can call to report stormwater pollution violations. This number is publicized on the website, stormwater flyers and give-away items (pens, pencils, magnates, etc.) 1. Respond to calls and inquiries within one business day (for non - emergencies), and immediately to IDDE. 1. Continuously from the date of initial hotline going live. Permit Years 1 - 5 1. Document and report a summary of the number of inquiries received, the general type of inquiry (education, outreach, complaint), and the contact mechanism (phone, email, web page, walk -in) 2. Advertise hotline/helpline in all ads, printed materials, social media and website. 2. Permit Years 1 -5 2. Yes/No status DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 22 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal and local public notice requirements. The City of High Point will manage, implement and report the following public involvement and participation BMPs. Table 14: Public Involvement and Participation BMPs Permit Ref. 3.3.1: Public Input Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Stormwater Hotline Dedicated Customer Service number for all Public Services has been established where citizens can call to report stormwater pollution violations. 1. Respond to calls and inquiries within one business day (for non-emergencies), and immediately to IDDE. 1. Continuously from the date of initial hotline going live. Permit Years 1 - 5 1. Document and report a summary of the number of inquiries received, the general type of inquiry (education, outreach, complaint), and the contact mechanism (phone, email, web page, walk -in) 2. Advertise hotline/helpline in all ads, printed materials, social media and website. 2. Permit Years 1-5 2. Yes/No status 2. Social Media Work with the City of High Point’s Public Information Office to promote information about upcoming events and other stormwater-related educational information using multiple social media outlets (Facebook, Next Door, Twitter, Instagram) 1. Schedule at least 3 stormwater specific informational posts per year. 1. Continuously during Permit Years 1-5 1. Document and report date of posts and number of views. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 23 Permit Ref. 3.3.2: Volunteer Opportunities Measures to provide volunteer opportunities designed to promote ongoing citizen participation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 3. Adopt -a-Street Program A partnership with Keep High Point Beautiful for volunteers to participate in picking up litter from their adopted street. 1. Check in with Keep High Point Beautiful President twice a year to receive Adopt -a -Street numbers. 1. Permit Years 1 -5 1. Document and report the number of new streets adopted and the total number of adopted streets. 2. Document number of cleanups, cleanup participants, and amount of trash/recycling picked up. 4. Adopt -a-Stream Program Provide public and private organizations the opportunity for volunteers to participate in cleaning up local streams. 1. Partner and coordinate with organizations in efforts to clean up adopted stream. 1. Permit Years 1 -5 1. Document and report the number of new streams adopted and the total of adopted streams. 2. Target goal is to recruit at least one new group per year. 2. Permit Years 1 -5 2. New group information will be recorded in Adopt -a- Stream documentation and annual reporting. 5. Storm Drain Marking Program Volunteers place drain markers on storm drains to assist in stormwater and watershed education within neighborhoods and public streets. 1. Target goal is to recruit at least one new group per year. 1. Permit Years 1 -5 1. Number of storm drains marked and number of participants. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 24 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The City of High Point will develop, manage, implement, document, report and enforce an Illicit Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. Table 15: Illicit Discharge Detection and Elimination BMPs Permit Ref. 3.4.1: MS4 Map Measures to develop, update and maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Stormwater System Inventory Provide dedicated field staff to collect and update sto rmwater infrastructure data. 1. Add new stormwater infrastructure (pipes, junctions, structures, outfalls) to our Stormwater GIS system for new construction 1. As needed 1. To maintain the current map, existing, added and suspected stormwater outfalls will be field located to verify their existence, location and other pertinent information such as size, material and condition. 2. Stormwater Web Map All SCMs within the City of High Point are identified and added to the current SCM Stormwater Web Map. 1. Add new SCMs to mapping database once construction and/or conversion from erosion control basin 1. As needed 1. To maintain the current map, existing and newly constructed SCMs will be field verified and the type of SCM will be included in the description 3. Camera Crew In -house staff collects stormwater infrastructure data for existing systems using pipe camera. 1. Maintain process for collecting data and incorporating into GIS database 1. Continuously Permit Years 1 – 5 1. Document and report updated map showing major outfalls, conveyances, flow direction and receiving streams DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 25 Permit Ref. 3.4.2: Regulatory Mechanism Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4, including enforcement procedures and actions. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 4. Enforcement The Illicit Discharge Control Ordinance will charge the Public Services Director or designee with implementing the Illicit Discharge Detection and Elimination program. The ordinance does specify legal penalties to be implemented in cases of non-compliance. Sec. 12-3-1 - Public Nuisance Sec. 12-3-2 - Enforcement Sec. 12-3-9 - Civil penalties. 1. Review ordinances and update if revision is required to maintain legal authority. 1. Continuously Permit Years 1 – 5 1. Document all aspects of the IDDE with notes, photos, and incident records from authorized First Responders (Fire Department) if necessary; update Accela database, IDDE Excel tracking spreadsheet and Stormwater Web Map; 2. 2. 2. Update IDDE Accela database and upload all pertinent memos, photos, etc. 3. 3. 3. Update Excel tracking spreadsheet with brief description of the IDDE and Y/N if NOV issued and current status of the IDDE 4. 4. 4. Update the Stormwater Web Map showing location and type of IDDE DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 26 5. Educating the Public and Municipal Employees On Reporting Guidelines Along with BMP #8, the City of High Point will incorporate documents to help the public and its municipal employees better understand what constitutes a violation and how to report it. 1. Monitor violation reports as set forth in BMP #8. 1. Continuously 1. Amount of educational material distributed electronically or at events and number of municipal employees trained during annual Stormwater training sessions Permit Ref. 3.4.3 : IDDE Plan Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping and any non -stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall provide standard procedures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit discharges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and assess the IDDE Program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 6. Written IDDE Plan Maintain and implement a written IDDE Plan. 1. Continue to update the IDDE Plan as required by any change in ordinance, state statute or other federal regulation than is specific to IDDE incidents 1. Continuously Permit Years 1 – 5 1. The written plan will be reviewed and updated accordingly on an annual basis. Dates of review/revisions will be included in the front of the IDDE binder. 7. Outfall Inspections Perform regular dry weather (no rain in previous 72 hours) outfall inspections to proactively identify illicit discharges and illicit connections. 1. Inspect one quarter of all major outfalls within the City limits every year. 1. All Stormwater Specialists (or other designated staff) will perform outfall monitoring year around as weather and scheduling permits 1. All information regarding outfall inspections is directly uploaded to the database in the field using Tablets. Number of outfalls monitored during any time frame can be accessed from the database. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 27 8. Detection and Elimination The City of High Point uses multiple methods of detecting and identifying illicit discharges and connections: dry-weather outfall monitoring program conducted on all outfalls, responding to citizen calls and concerns made through our Customer Service line, and training City personnel on how t o recognize illicit discharges/connections and how to report them 1. Continue to inspect, at a minimum, 50% of all recognized outfalls. 1. Depending upon the type of pollutant involved , differing identification techniques may be used such as visual observations, smells, or chemical tests. 1. NOV letter certified mailed to offender 2. 2. Once the source of discharge is determined, the perpetrator will be required to cease discharging. 2. Time/date stamped photos of the IDDE on the property 3. 3. The Illicit Discharge Control Ordinance will charge the Public Services Director or designee with implementing the Illicit Discharge Detection and Elimination program. The ordinance does specify legal penalties to be implemented in cases of non- compliance. 3. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 28 Permit Ref. 3.4.4: IDDE Tracking Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was observed, the results of the investigation, any follow -up of the investigation, the date the investigation was closed, the issuance of enforcement actions, and the ability to identify chronic violators. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 9. Notice of Violation (NOV) Letters Once an NOV has been witnessed and investigated by stormwater staff, documentation of the incident begins approval to the area. An NOV letter with a detailed description of the incident along with dated/time stamped Photos are sent certified mail to the violator or representative. Follow- up of the IDDE occurs once the time limit for compliance is reached. I. Continue to update system processing of IDDE records and implement procedures that may increase efficiency of handling these incidents 1. Immediately 1. Record of all NOV's issued and any follow up associated with them. Permit Ref. 3.4.5: Staff IDDE Training Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall include how to identify and report illicit discharges, i llicit connections, illegal dumping and spills. Each staff training event shall be documented, including the agenda/materials, date, and number of staff participating. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 10. Staff Training Provide stormwater training to all groups of municipal staff and/or contractors each year. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. 1. Maintain an employee training program on detecting and reporting illicit discharges, illicit connections, illegal dumping and spills. 1. Annually Permit Years 1 – 5 1. Document and report the name and number of staff trained, training dates and topics covered. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 29 Permit Ref. 3.4.6: IDDE Reporting Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained personnel. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 11. Stormwater Hotline Dedicated Customer Service number for all Public Services has been established where citizens can call to report stormwater pollution violations. 1. Promote and publicize phone number to receive reports related to illicit discharges. 1. Continuously Permit Years 1 – 5 1. Document and report the number of illicit discharges, connection, or dumping complaints received, detected and addressed each permit year. 12. On-Call Duty Officer On-Call duty officer to be available after normal business hours to investigate illicit discharges, illegal dumping and spills if reported. 1. Promote and publicize phone number to receive reports related to illicit discharges. 1. Continuously Permit Years 1 – 5 1. Document and report the number of illicit discharges, connection, or dumping complaints re ceived, detected and addressed each permit year. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 30 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the City of High Point relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973, the NCG010000 permit for construction activities, and the Randleman Lake Water Supply Watershed: Protection and Maintenance of Existing Riparian Buffers as qualifying alternative programs to meet the NPDES MS4 Permit requirements for all construction site runoff control measures to reduce pollutants in stormwater runoff from construction activities that: • Result in land disturbance of greater than or equal to one acre; • Is located on highly erodible soils with a “k” Factor greater than .36; • Includes a water quality pond or retention structure in a watershed, or drains into a water quality pond or retention structure in any part of a watershed; • Is located in a Tier 1 or Tier 2 portion of a Watershed Critical Area; • Is located in an existing uncovered area requiring extensive soil erosion control measures; • Requires extensive erosion control measures; • Any construction activity that is part of a larger common plan of development that would disturb one or more acres. Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Permit Reference State or Local Program Name Legal Authority Implementing Entity Meets Whole or Part of Requirement 3.5.1 - 3.5.4 City of High Point Delegated SPCA Program* 15A NCAC Chapter 04 City of High Point Whole 3.5.1 - 3.5.4 State Implemented SPCA Program 15A NCAC Chapter 04 NCDEQ Whole 3.5.1 - 3.5.4 Randleman Lake Water Supply Watershed: Protection and Maintenance of Existing Riparian Buffers 15A NCAC 02B.0724 effective 6- 15-2020 NCDEQ Whole 2 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found at https://library.municode.com/nc/high_point/codes/development_ordinance?nodeId=CH6ENST _6.3SOERSE. The City of High Point also implements the following BMPs to meet NPDES MS4 Permit requirements. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 31 Table 17: Construction Site Runoff Control BMPs Permit Ref. 3.5.6: Public Input Measures to provide and promote a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Municipal Staff Training (NC Sediment Control Commission) As per Memorandum of Agreement between the NC Sedimentation Control Commission (Commission) and City of High Point (CoHP) issued August 3, 2020: The Commission will provide: • Instructional materials for persons involved in the enforcement of the SPCA and erosion and sedimentation control rules,ordinances, regulations, and plans. • Manuals and publications to assist in the design, construction and inspection of erosion and sedimentation control measures. • Technical assistance in review of drafterosion and sedimentation control plans for complex activities. 1. CoHP E&SC Staff shall attend Commission sponsored training on E&SC Practices, proper handling of construction site runoff control complaints. 1. See Memorandum of Agreement 1. Annual Report incorporating Monthly Commission Reports. 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 32 2. Municipal Staff Training (City of High Point) CoHP will train staff who receive calls from the public to: • Enforce the provisions of the SPCA. Administer the SPCA for all land-disturbing activity within its jurisdiction. CoHP E&SC Staff will: • Review plans within 30 days of receipt of a new plan and within 15 days of a revised plan. • Approve; approve with modifications; or disapprove draft plans in conformance with the basic control objectives contained in 15A NCAC 04B .0106. • Notify in writing the person submitting the plan that it has b een approved, approved with modifications, or disapproved within 30 days of receipt of a new plan and within 15 days of a revised plan. • Include in written notifications of plan approval the following: (1) Reference to NPDES General Stormwater Permit NCG 010000 expiration date of the approval, 2) the right of periodic inspection, and (3) condition the approval upon the applicant's compliance with Federal and State water quality laws, regulations and rules. See Memorandum of Agreement Annual Report incorporating Monthly Commission Reports. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 33 3. BMP - Inspections (A) Periodically and regularly inspect sites undergoing land - disturbing activity within its jurisdiction. Periodically and regularly means with sufficient frequency to effectively monitor compliance with the SPCA and rules adopted pursuant to the SPCA and the local erosion and sedimentation control ordinance. CoHP E&SC Staff will: (1) Document all inspections in writing, including electronic documents. (2) Inspection reports shall include, at a minimum, all information in the model sedimentation inspection report developed by the Commission. (3) Maintain inspection records for active projects in accordance with State and local record retention policies. See Memorandum of Agreement Annual Report incorporating Monthly Commission Reports. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 34 B) Issue Notices of Violation (hereinafter, "NOV") for any significant violation of the SPCA, rules adopted pursuant to the SPCA, or the local erosion and sedimentation control ordinance documented in an inspection report. The NOV shall specify the following: describe the violation with reasonable particularity: See Memorandum of Agreement Annual Report incorporating Monthly Commission Reports. a. request that all illegal activity cease b. the actions that need to be taken to comply with the SPCA and the local ordinance c. a date by which the person must comply with the SPCA and the local ordinance d. inform the violator that any person who fails to comply within the time specified is subject to additional civil and criminal penalties for a continuing violation as provided in G.S. 113A-64 and the local ordinance DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 35 Permit Ref. 3.5.5: Waste Management Measures to require construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to water quality. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 4. Approve SWPPP for NCG01 Phasing on Approved SWPPP for NCG01 Part 2 Ground Stabilization and Materials Handling Requirements. 1. Practices identified as being prohibited. 1. Effective April 1, 2019 to March 31, 2024 1. Inspection Report/Notice of Violation 2. 2. 2. 3. 3. 3. 4. 4. 4. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 36 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM This SWMP identifies the minimum elements to develop, implement and enforce a program to address stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that are located within the City of High Point and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of structural Stormwater Control Measures (SCMs) and/or non-structural BMPs appropriate for the community and ensure adequate long -term operation and maintenance of SCMs. In accordance with 15A NCAC 02H .0153 and .1017, the City of High Point implements the following State post-construction program requirements, which satisfy the NPDES Phase II MS4 post-construction site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where they are implemented. Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program State QAP Name State Requirements Local Ordinance / Regulatory Mechanism Reference None N/A N/A 2 The City of High Point has existing requirements other than Qualifying Alternative Program(s) for implementation of the NPDES Phase II MS4 post-construction program requirements. These existing requirements are codified in local ordinance(s), and implementation is further defined in guidance, manuals and/or standard operating procedure(s) as summarized in Table 19 below. Table 19: Summary of Existing Post-Construction Program Elements Permit Requirements for Plan Review and Approval Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.2(a) Authority City of High Point Development Ordinance Chapter 2.2 (Ord. No. 7266/17-08 , § 2, 1-17-2017; Ord. No. 7476/18-105, § 2.B, 12-3- 2018); 3.6.3(a) & 15A NCAC 02H.0153(c) Federal, State & Local Projects City of High Point Development Ordinance Chapter 6.2 (Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, § 12, 4-3- 2017) DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 37 3.6.3(b) Plan Review City of High Point Development Ordinance Chapter 2.2 (Ord. No. 7266/17-08 , § 2, 1-17-2017; Ord. No. 7476/18-105, § 2.B, 12-3- 2018); 3.6.3(c) O&M Agreement City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) 3.6.3(d) O&M Plan City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) 3.6.3(e) Deed Restrictions/Covenants City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) 3.6.3(f) Access Easements City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17-108 § 1, 11-20-2017) 3.6.2(b) Documentation City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) 3.6.2(c) Right of Entry City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17-108 § 1, 11-20-2017) 3.6.4(a) Pre-CO Inspections City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) 3.6.4(b) Compliance with Plans City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 38 3.6.4(c) Annual SCM Inspections City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) 3.6.4(d) Low Density Inspections City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) 3.6.4(e) Qualified Professional City of High Point Development Ordinance Chapter 6.2.11 Ord. No. 7266/17-08 , § 27, 1-17-2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) Permit Requirements for Fecal Coliform Reduction Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.6(a) Pet Waste City of High Point Code of Ordinances, Title 12, Chapter 3, Sec. 12-3-1 (Ord. No. 6168/04-65, § 1, 9-7-04; Ord. No. 6541/08- 26, 5-19-08; Ord. No. 6573/08-58, § 2, 8-18-08) The annual reporting metrics for the post construction program are provided in Table 20: Post- Construction Site Runoff Control BMPs below. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 39 Table 20: Post Construction Site Runoff Control BMPs Permit Ref. 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements Measures to document activities over the course of the fiscal year (July 1 – June 30) including appropriate information to accurately describe progress, status, and results. [These BMPs, measurable goals and annual reporting metrics are required for all post -construction programs and QAPs. Do not edit this BMP.] BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Standard Reporting Implement standardized tracking, documentation, inspections and reporting mechanisms to compile appropriate data for the annual self-assessment process. Data shall be provided for each Post- Construction/ Qualifying Alternative Program being implemented as listed in Tables 18 and 19. 1. Track number of low density and high density plan reviews performed. 1. Continuously 1. Number of plan reviews performed for low density and high density. 2. Track number of low density and high density plans approved. 2. Continuously 2. Number of plan approvals issued for low density and high density. 3. Maintain a current inventory of low density projects and constructed SCMs including SCM type or low density acreage, location and last inspection date. 3. Continuously 3. Summary of number and type of SCMs added to the inventory; and number and acreage of low density projects constructed. 4. Track number of SCM inspections performed. 4. Continuously 4. Number of SCM inspections. 5. Track number of low density inspections performed. 5. Continuously 5. Number of low density inspections. 6. Track number and type of enforcement actions taken. 6. Continuously 6. Number and type of enforcement actions taken. Permit Ref. 3.6.2: Legal Authority Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a) review designs and proposals for new development and redevelopment to determine whether adequate stormwater control measures will be installed , implemented, and maintained, (b) request information such as stormwater plans, inspection reports, monitoring results, and other information deemed necessary to evaluate compliance with the Post-Construction Stormwater Management Program, and (c) enter p rivate property for the purpose of inspecting at reasonable times any facilities, equipment, practices, or operations related to stormwater discharges to determine whether there is compliance with the Post -Construction Stormwater Management Program. This permit requirement is fully met by the existing post -construction program, see references provided in Table 19. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 40 Permit Ref. 3.6.3: Plan Review and Approval Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal, State, and local government projects to comply with Post -Construction Program requirements throughout the entire MS4 permitted area, unless the entit y is subject to its own NPDES MS4 permit or a qualifying alternative program, (b) Conduct site plan reviews of all new development and redeveloped sites that disturb greater than or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that complies with 1 5A NCAC 02H .1050(12), (d) Ensure that each project has an Operation and Maintenance Plan that complies with 15A NCAC 02H .1050(13), (e) Ensure that each project has recorded deed restrictions and protective covenants, that require the project to be maintained consistent with approved plans, and (f) Ensure that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A NCAC 02H 1050 (9) and (10). This permit requirement is fully met by the existing post -construction program, see references provided in Table 19. Permit Ref. 3.6.4: Inspections and Enforcement Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post - construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy. Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s), (b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require that inspections be conducted by a qualified professional. This permit requirement is fully met by the existing post-construction program, see references provided in Table 19. Permit Ref. 3.6.6: Fecal Coliform Reduction Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H .1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be achieved by revising an existing litter ordinance, and (b) An on -site domestic wastewater treatment system component, if applicable, which may be coordinated with local county health department, to ensure proper operation and maintenance of such systems. This permit requirement is fully met by the existing post - construction program, see references pro vided in Table 19. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 41 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City of High Point municipal facilities and operations. Pollution prevention and good housekeeping is accomplished through the implementation of seven required programs, which collectively address the ultimate goal of preventing or reducing pollutant runoff from municipal operations such as parks and open space maintenance, fleet and building maintenance, new construction and land disturbances, and municipal storm sewer system maintenance. Pollution prevention and good housekeeping for municipal operations includes the following programs: 1. Municipal Facilities Operation and Maintenance Program 2. Spill Response Program 3. MS4 Operation and Maintenance Program 4. Municipal SCM Operation and Maintenance Program 5. Pesticide, Herbicide and Fertilizer Management Program 6. Vehicle and Equipment Maintenance Program 7. Pavement Management Program The City of High Point will manage, implement and report the pollution prevention and good housekeeping BMPs as specified in Table 21 below for each required program. Table 21: Pollution Prevention and Good Houseke eping BMPs Permit Ref. 3.7.1: Municipal Facilities Operation and Maintenance Program Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities; perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on general stormwater awareness and implementing pollu tion prevention and good housekeeping practices. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Operation and Maintenance Plan Maintain and update a written Operation and Maintenance Plan. 1. Implement all aspects of the O&M Plan 1. Permit Years 1-5 1. Yes/No/Status Summary 2.Update plan on an annual basis. 2. Annually Permit Years 1-5 2. Document and report updates to O&M Manual 3. 3. 3. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 42 2. Inventory of Municipal Facilities Update and maintain inventory of municipal facilities that have the potential to generate polluted stormwater runoff. 1. Review and update list of municipal facilities. 1. Annually Permit Years 1-5 1.Yes/No/Date Updated Document and report changes made to facility inventory list. 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. 3. Municipal Facility Inspections Inspect municipal facilities deemed to have the potential to generate polluted stormwater runoff. 1. Review and update municipal inspection forms. 1. Annually Permit Years 1-5 1. Document any changes made to municipal inspection forms. 2. Perform municipal facility inspections on those facilities that have the potential to pollute stormwater. 2. Annually Permit Years 1-5 2. Document the number of inspections performed and note any enforcement actions required. 3. 3. 3. 4. 4. 4. 5. 5. 5. 4. Municipal Employee Training Conduct annual stormwater training that covers general stormwater awareness, pollution prevention and spill response, and IDDE reporting 1. Perform employee training at Facilities that have been identified as having the possibility to have a negative impact on stormwater. 1. Annually Permit Years 1-5 1. Document and report the number of staff trained, training date(s), and topics covered. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 43 Permit Ref. 3.7.2: Spill Response Program Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response procedures. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 5. Spill Response Plan A written spill response plan has been developed for municipal facilities that store or use materials that could contaminate stormwater runoff. Municipal facilities with industrial permits have a spill response plan as part of their Stormwater Pollution Prevention Plan or SPCC Plan. 1. Review and update Spill Response Plan annually to ensure plan is effective. 1. Annually Permit Years 1-5 1. Yes/No/Status and documents any changes needed to the Spill Response Plan. 2. Perform spill response training for municipal employees annually. 2. Annually Permit Years 1-5 2. Document and report training records of staff members trained, and the date training occurred. 3. Evaluate municipal facilities to determine if any need to be added or removed from those requiring a Spill Response Plan. 3. Annually Permit Years 1-5 3. Number of additions or revisions. 4. 4. 4. 5. 5. 5. 6. Maintain Inventory of Facilities with a Spill Response Plan Maintain a list of city facilities that have a SPCC Plan, SWPPP, or Spill Response Plan. 1. Update list of city facilities with the potential to pollute stormwater. 1. Annually Permit Years 1-5 1. Yes/No/ Date updated. 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 44 Permit Ref. 3.7.3: MS4 Operation and Maintenance Program Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard documentation. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 7. Inspections and Maintenance of Stormwater Conveyances Inspection and Maintenance Plan for stormwater infrastructure inspections. 1. Develop an SOP that identifies frequencies and documentation for maintenance. 1. Permit Year 1 1. Yes/No/Status 2.Perform inspections in accordance with SOP 2.Follow schedule established in SOP. 2.Number of inspections performed and document any deficiencies. 3.Maintenance is prioritized by citizen reports or inspections. 3.Countinuously Permit Year 1-5 3.Number of maintenance activities performed. 4. 4. 4. 5. 5. 5. 8. Employee Training Continue stormwater training to employees within the Public Services Department. 1. Provide training to employees. 1. Annually Permit Year 1-5 1. Yes/No/Status 2. 2. 2. 3. 3. 3. 4. 4. 4. 5. 5. 5. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 45 Permit Ref. 3.7.4: Municipal SCM Operation and Maintenance Program Measures to manage municipally-owned, operated, and/or maintained structural SCMs that are installed for compliance with the permittee’s post -construction program. The permittee shall maintain a current inventory of SCMs, perform SCM inspections and maintenance, and shall es tablish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 9. Municipal SCM Inventory Maintain inventory of municipally owned structural SCMs. 1. Maintain Operation and Maintenance plans for all City-owned SCMs. 1. Continuously Permit year 1 -5 1. Report number of SCMs 2. Update inventory of City-owned SCMs. 2. Continuously Permit year 1 -5 2. Note when SCMs are added to the inventory. 3. Maintain NC SCM Inspection and Maintenance Certification for approved personnel. 3. Continuously Permit Years 1-5 3.Report stormwater staff members certification status. 4. 4. 4. 5. 5. 5. 10. SCM Inspection and Maintenance Perform regular inspections and maintenance of municipal SCMs and document on an annual basis with all related documentation stored in a tracking database. 1. NC SCM Certification is maintained by Stormwater Staff conducting SCM inspections. 1. Continuously Permit year 1 -5 1. Number of staff with certification. 2. SCM inspections are conducted per the SCM Inspection SOP. 2. Continuously Permit year 1 -5 2.Number of SCM inspections conducted along with inspection status. 3. Perform needed maintenance identified during the inspections. 3. Continuously Permit year 1 -5 3.Yes/no/status 4. Update the tracking data base with inspection status and documents. 4. Continuously Permit year 1 -5 4.Yes/no/status 5. 5. 5. DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 46 Permit Ref. 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine pollution prevention and chemical use, storage and handling train ing, and shall ensure compliance with permits and applicator certifications. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 11. Applicator Training for Pesticides, Herbicides and Fertilizer Training of city staff who apply chemicals to help prevent negative water quality impacts from pesticides, herbicides and fertilizers. 1. Maintain proper licenses or certification for applying pesticides, herbicides and fertilizers. 1. Continuously Permit Year 1-5 1. Yes/No/Status 2. Provide staff training in pollution prevention and applying chemicals. 2.Annually Permit Year 1-5 2.Yes/No/Status 3. 3. 3. 4. 4. 4. 5. 5. 5. Permit Ref. 3.7.6: Vehicle and Equipment Maintenance Program Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 12. NPDES Industrial Permit Compliance Ensure that municipal facilities covered under a NPDES industrial permit are maintaining compliance. 1. Update municipal facility inventory with NPDES permit status. 1. Annually Permit Year 1-5 1. Yes/No/Dated Updated 2. Ensure that all NPDES Permits for municipal facilities are renewed as needed. 2. Annually Permit Year 1-5 2.Yes/No/Status 3. Use industrial facility inspection form when conducting annual inspections at municipal facilities covered under a NPDES permit. 3. Annually Permit Year 1-5 3.Number of Inspections conducted. Note any significant violations. Yes/No/Status DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 47 4. Complete annual training 4.Annually Permit Year 1-5 4. Document and report the number of staff trained, training date(s), and topics covered. 5. 5. 5. 13. Vehicle and Equipment Cleaning and Maintenance Facility Inspections Vehicle and Equipment Cleaning and Maintenance is included as part of the annual facility inspection. 1. Perform annual inspections and notify responsible person of any corrective actions required. 1. Annually Permit Year 1-5 1. Number of inspections performed and document any corrective actions. 2. Ensure any corrective actions are made by conducting a follow-up inspection and/or contacting the responsible person. 2. Follow-up inspections will be conducted as needed. Permit Year 1-5 2.Number of corrective actions required and resolutions. 3. 3. 3. 4. 4. 4. 5. 5. 5. Permit Ref. 3.7.7: Pavement Management Program Measures to reduce pollutants in stormwater runoff from municipally -owned streets, roads, and parking lots within the permittee’s corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 14. Street Sweeping Street sweeping following a regular schedule in order to reduce pollutants from City owned and maintained streets. 1. Develop a standard operating procedure, including schedules, zones/locations and proper disposal of collected wash waters and solids. 1. Permit Years 1 1. Yes/No Status Summary DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 48 2. Implement SOP and documentation. 2. Annually Permit Years 1-5 2. Document and report total number of street miles swept. 3. 3. 3. 4. 4. 4. 5. 5. 5. 15. Loose Leaf Collection Provide seasonal loose leaf collection in residential areas and compost the collected material at the city operated composting center for use by the city and residents. 1. Publicize/establish protocols for residential brush and bagged leaf collections. 1. Permit Years 1 -5 1. Yes/No Status Summary 2. Collect brush and bagged leaves 2. Weekly per resident. Permit Years 1 -5 2. Document and report the total amount of brush collected /disposed of annually (pounds). DRAFT NCS000421 SWMP The City of High Point September 24, 2020 Page 49 APPENDIX A