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Home My WebLink AboutNCS000421_High Point Draft SWMP v2_20210301Public Services Department Stormwater Services Division February 22, 2021 VIA FEDERAL EXPRESS DEQ-DEMLR Stormwater Program Attn: Jeanette Powell 1612 Mail Service Center Raleigh, NC 27699-1612 NORTH CAROLINN S INTERNATIONAL CITY- REGF-IVED MAR 012021 DENR•L.AM) QUA1,1TY RE: Draft SWMP v2 (NOD-2019-PC-0205) City of High Point NPDES MS4 Permit No. NCS000421 Guilford, Randolph, Davidson & Forsyth Counties Dear Jeanette: Enclosed please find the City of High Point's second draft submission of the Stormwater Management Plan as required by your Comment Letter dated January 27, 2021. If you have any questions, please feel free to contact me. Respectfully, Anita Simpson Storm water Operations Analyst Enclosure cc: Randy McCaslin, Interim City Manager Robby Stone, PE, Deputy Public Services Director Trevor Spencer, PE, Engineering Services Director City of High Point, P.O. Box 230, 211 South Hamilton Street, High Point, NC 27261 USA Fax:336.883.8561 Phone:336.883.3455 TDD:336.883.8517 Draft Stormwater Management Plan v2 City of High Point NCS000421 February 22, 2021 RECEIVED MAR 01 7021 L)St4R•L.AN-1) 01 AUTT ' STORmWAT R PERMiT I ING DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Table of Contents PART 1: INTRODUCTION.......................................................................................................... 1 PART2: 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.......................................................................................... 9 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 .................................... 29 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ......................... 32 PART10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ......... 37 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 List of Tables Table 1: Summary of MS4 Mapping Table 2: Sununaiy 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 Programs) 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 v2 The City of High Point February 22, 2021 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 v2 The City of High Point February 22, 2021 Page 1 PART 2: CERTIFICATION By my signature below I hereby certify, under penalty of law, that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4 Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit compliance and enforcement authority. ❑ I am a ranking elected official. ❑ I am a principal executive officer for the permitted MS4. ❑ I am a duly authorized representative for the permitted MS4 and have attached the authorization made in writing by a principal executive officer or ranking elected official which specifies me as (check one): ❑ A specific individual having overall responsibility for stormwater matters. ❑ A specific position having overall responsibility for stormwater matters. Signature: Z p .At - Print Name: Randy McCaslin Title: Interim City Manager Signed this 1 day of February, 2021. DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 2 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. ZI 41-J s�? DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 3 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 i er 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 EcoBiological Integrity Fish Com EcoBiolo icalIntegrity Benthos Long Branch 17-2-1- 2 WS-IV CA EcoBiological Integrity Fish Com Eco/Biolo ical Integrity Benthos DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 4 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 Couniy 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 Federal Listing County Group Status Fusconaia masoni Atlantic pigtoe Clams Proposed Guilford Threatened Randolph Notropis Cape Fear Shiner Fish Endangered Guilford mekistocholas Randolph Percina rex Roanoke logperch Fish Endangered Guilford Isotria medeoloides Small whorled Flowering 'Threatened 0 onia Plants Guilford Helianthus Schweinitz's Flowering Endangered Davidson schweinitzii sunflower Plants Guilford Randolph Perimyotis subflavus Tricolored bat Mammals Under Review Davidson, Forsyth Clemmys Bog Turtle Reptiles Threatened muhlenber ii 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 v2 The City of High Point February 22, 2021 Page 6 NCG030517 Mickey Truck Body Inc - High Point NCG050370 Innocor Foam Technologies - ACP, Inc. NCCT060003 Kao Specialties Americas LL,C NCG060041 Piedmont ChemicalInd 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 NCGO80702 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 v2 The City of High Point February 22, 2021 Page 7 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 SyntecSeating Solutions LLC NCGNE1022 High Point Furniture Industries NCGNE1131 Fastenal Company l NCGNE1144 V&E Components, Inc. NCGNE1208 Thomas Clyde Lamar ARC NCO28 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 v2 The City of High Point February 22, 2021 Page 8 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-Stormwatcr 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 crawls ace 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 v2 The City of High Point February 22, 2021 Page 9 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 Likely Source(s)/Target SWMP Program Addressing Target Pollutants Audiences Pollutant s /Audience s Litter General Public, Businesses, Public Education & Outreach, Public Schools Participation Pet Waste General Public, Schools, Parks, Public Education & Outreach, Illicit Greenwa s Discharge Detection & Elimination Sediment Construction Erosion, Stream Construction Site Runoff Control Bank Erosion Illicit Discharges General Public, Businesses, Public Education & Outreach, Illicit Municipal Employees Discharge Detection & Elimination, Public Involvement Illegal Dumping General Public, Businesses, Public Education & Outreach, Illicit Municipal Employees Discharge Detection & Elimination, Pollution Prevention & Good Housekeeping DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 10 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 Deputy Public Robby Stone Public Services Administration Services Director SWMP Management Public Services Manager VACANT Public Services — Stormwater Division Operations Analyst Anita Simpson Public Education Stormwater Robbie Baker Public Services — & Outreach Specialists Kelsie Burgess Stormwater Division Abigail Rosendale Public Involvement & Stormwater Robbie Baker Public Services — Participation Specialists Kelsie Burgess Stormwater Division Abigail Rosendale Illicit Discharge Stormwater Robbie Baker Public Services — Detection & Specialists Kelsie Burgess Stormwater Division Elimination Abigail Rosendale Construction Site Engineering Services Trevor Spencer Engineering Services Runoff Control Director Erosion Control Scott Ford Inspectors Kathy Blake Post -Construction Operations Analyst Anita Simpson Public Services — Stormwater Stormwater Division Management DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 11 Pollution Prevention Stormwater Specialists Robbie Baker Public Services — Good Housekeeping for Kelsie Burgess Stormwater Division Municipal Operations Abigail Rosendale Municipal Facilities Stormwater Specialists Robbie Baker Public Services — Operation & Kelsie Burgess Stormwater Division Maintenance Program Abigail Rosendale Spill Response All Stormwater All Stormwater Public Services — Program Division Staff Division Staff Stormwater Division MS4 Operation & Public Services Terry Houk Public Services Maintenance Program Director Deputy Public Robby Stone Services Director Municipal SCM Public Services VACANT Public Services — Operation & Manager Stormwater Division Maintenance Program Pesticide, Herbicide & Safety Officer Jim Gwynn Public Services Fertilizer Management Program Vehicle & Equipment Public Services VACANT Public Services — Cleaning Program Manager Stormwater Division Pavement Management Public Services Manager VACANT Public Services — Program Streets and Stormwater Street Maintenance Divisions Superintendent Ken Sult Total Maximum Daily Operations Analyst Anita Simpson Public Services — Load (TMDL) Stormwater Division Requirements Stormwater Specialists Robbie Baker Kelsie Burgess Abigail Rosendale DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 12 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 service 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 Implementing Entity & Program Name Legal Agreement (Y/N) Permit Requirement N/A DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 13 4.4 Co-Permittees The are no other entities applying for co-permittee status under the NPDES MS4 permit member NCS000471 for the City of High Point. Table 10: Co-Permittee Contact Information Co-Permittee MS4 Contact Person Phone & E-Mail Interlocal Agreement Name (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 2.1.2 and Part 4: Annual Self -Assessment Ref. 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 ear Jul 1— June 30 . BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Implementation Reporting Metric 1. Annual Self -Assessment Perform an annual evaluation 1. Prepare, certify, and 1. Annually 1. Annual Self - of SWMP implementation, submit the Annual Self- Permit Years 1-5 Assessment suitability of SWMP Assessment to NCDEQ FY21/22 received by commitments and any prior to August 31st FY22/23 NCDEQ no later proposed changes to the each year. FY23/24 than August 31st SWMP utilizing the NCDEQ FY24/25 each year. Annual Self- Assessment FY25/26 Template. DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 14 Permit 1.6 Permit Renewal Application Ref. Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4 permit. BMP A B C D No. Description of Measurable Schedule for Annual Reporting BMP Goal(s) Implementation Metric 2. Permit Renewal Application Audit stormwater 1. Participate in an 1. TBD — Typically 1. N/A program implementation NPDES MS4 Permit Permit Year 4 for compliance with the Compliance Audit, as FY24/25 permit and approved scheduled and SWMP and utilize the performed by EPA or results to prepare and NCDEQ. submit a permit renewal 2. Self -audit and 2. Permit Year 5 2. Submit Self -Audit application package. document any FY25/26 to DEMLR (required stormwater program component of permit components not renewal application audited by EPA or package). NCDEQ utilizing the DEQ Audit Template. 3. Certify and submit 3. Permit Year 5 3. Permit renewal the stormwater permit FY25/26 application package renewal application received by DEQ at (NOI, Self -Audit, and least 180 days prior Draft SWMP for the to permit expiration. next 5-year permit cycle). DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 15 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 v2 The City of High Point February 22, 2021 Page 16 Table 13: Public Education and Outreach BMPs Permit 3.2.2 and 3.2.4: Outreach to Targeted Audiences Ref. 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 provideeducational information to identified target audiences on pollutants/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 A B I C D No. Description Measurable Goal(s) Schedule for Annual Reporting of BMP Implementation' Metric 3. School Outreach Develop age -specific 1. Provide age -specific 1. Continuously 1. Number of students, educational information stormwater presentations. Permit Years 1-5 date of Event for use in schools and FY21/22 for presentations to FY22/23 school age children. FY23/24 Will present FY24/25 information in FY25/26 appropriate format. 2. Reach out to Guilford 2. Annually 2. Yes/No/Status County Schools and Permit Years 1-5 Private schools to remind FY21/22 them of the programs FY22/23 offered. FY23/24 FY24/25 FY25/26 3. Organize stream 3. Continuously 3. Number of students, habitat events for schools Permit Years 1-5 date of Event and/or summer camps as FY21/22 requested FY22/23 FY23/24 FY24/25 FY25/26 *Scheduling is currently impacted due to COVID-19 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 17 4. Public Event Tabling Set up public education table 1. Monthly Library 1. Continuously 1. Number of interactions at at a variety of public events Table Permit Years 1-5 the table, date of event and locations in order to FY21/22 reach diverse groups, FY22/23 minorities ,and underserved FY23/24 populations FY24/25 FY25/26 2. Monthly Farmer's 2. Continuously 2. Number of interactions at Market Table Permit Years 1-5 the table, date of event FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Attend at least 3 3. Continuously 3. Number of interactions at other City of High Permit Years 1-5 the table, date of event Point Public events. FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 4. Coordinate and 4. Annually 4. Number of attendees, date attend the annual Permit years 1-5 of event Public Services Day FY21/22 event. FY22/23 FY23/24 FY24/25 FY25/26 5. Coordinate and attend 5. Annually 5. Number of attendees, date one event in High Point Permit years 1-5 of event for Guilford Creek FY21/22 Week. FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 18 5. Utility Bill Inserts Stormwater bill inserts will 1. Develop and 1. Semi -Annually 1. Number of flyers continue to be inserted into distribute a stormwater Permit Year 1 mailed, date and topic combined utility bill statements flyer for general FY21/22 and distributed to all City residents stormwater concepts. and businesses receiving a utility bill on at least a semi- annual 2• Develop and 2. Semi -Annually 2. Number of flyers schedule. distribute a stormwater Permit Year 2 mailed, date and topic flyer for illicit FY22/23 discharges/illegal dumping and general stormwater information 3. Develop and 3. Semi -Annually 3: Number of flyers distribute a stormwater Permit Year 3 mailed, date and topic flyer for household FY23/24 wastes/automotive care and leaf pick up/yard waste. 4. Develop and 4. Semi -Annually 4. Number of flyers distribute a stormwater Permit Year 4 mailed, date and topic flyer for general FY24/25 stormwater information and leaf pickup/yard waste. 5. Develop and 5. Semi -Annually 5. Number of flyers distribute a stormwater Permit Year 5 mailed, date and topic flyer for illicit FY25/26 discharge/illegal dumping and yard waste/leaf pickup. 6. Stormwater Information Documents Informational pamphlets, 1. Develop a list of 1. Annually 1. Yes/No/Status brochures, and giveaways with target audiences, Permit Years 1-5 specific stormwater topics, as groups, and/or FY21/22 well as general information to be businesses for each FY22/23 handed out to targeted groups and informational FY23/24 be available at all tabling events. document. FY24/25 FY25/26 2. Develop a schedule 2. Annually 2. Number of for inventory of all Permit Years 1-5 documents of each informational FY21/22 topic distributed and documents and FY22/23 update inventory giveaways. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 19 7. Information Kiosks Multiple stormwater documents 1. Develop a location 1. Annually 1. Yes/No/Status will be displayed at locations list and schedule to Permit Year 1 throughout the City including City regularly check kiosks FY21/22 Hall (Customer Service), Public Services Department, the City of High Point Visitors Center, Public Library, Piedmont Environmental 2. Check kiosks to 2. Quarterly 2. Number of Center, and other city -maintained recreational facilities. ensure documents are Permit Years 2-5 documents of each available and FY22/23 topic distributed replenished FY23/24 FY24/25 FY25/26 8. Social Media Work with the City of High Point's 1. Schedule at least 1. Continuously 1. Number of views Public Information Office to three stormwater Permit Years 1-5 per post, date, and promote information about specific informational FY21/22 topic upcoming events and other posts per year. FY22/23 stuiinwatei- related educational FY23/24 information using multiple social FY24/25 media outlets (Facebook, Next FY25/26 Door, Twitter, Instagram) 9. Advertisements, Media, Etc. Utilize additional physical or 1. At least once per 1. Continuously 1. Yes/No/Status, digital advertising spaces to year, use non- Permit Years 1-5 date, and topic increase visibility of the municipal website or FY21/22 stormwater message. outdoor advertisement FY22/23 space (e.g. La Noticia FY23/24 print/website, using ad FY24/25 space inside and FY25/26 outside of High Point Transit Buses, billboards, shopping carts. DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 20 Permit 2.1.7, 3.2.3 and 3.6.5(c): Web Site Ref. 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 A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 10. Informational Web Site The Stormwater Services Division 1. Maintain the 1. Continuously 1. Yes/No NA, will maintain an internet web site stormwater web page Permit Years 1-5 date updated if that contains detailed information and update any FY21/22 applicable regarding all aspects of the changes as needed. FY22/23 stormwater permit requirements, FY23/24 services offered and contact FY24/25 information. FY25/26 2. Add a link on the 2. Permit Year 1 2. Yes/No/Status Stormwater webpage FY21/22 to the NCDEQ Stormwater webpage Permit 32.5: Stormwater Hotline Ref. Measures for a stormwater hotline/helpline for the purpose of public education and outreach. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual' Reporting Implementation Metric 11. Stormwater Hotline Dedicated Customer Service 1. Respond to calls 1. Continuously 1. Number of calls number for all Public Services has and inquiries within Permit Years 1-5 received and been established where citizens can one business day (for FY21/22 number of call to report stormwater pollution non- emergencies), FY22/23 resolutions violations. This number is and immediately to FY23/24 publicized on the website, an IDDE. FY24/25 stormwater flyers and give-away FY25/26 items (pens, pencils, magnates, etc.) 2. Advertise 2. Continuously 2. Yes/No/Status hotline/helpline in all Permit Years 1-5 ads, printed FY21/22 materials, social FY22/23 media, and website. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 21 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 3.3.1: Public Input Ref: Mechanisms for publicinvolvement that provide for input on stormwater issues and the stormwater program. BMP A'' B C D No Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 12. Stormwater Hotline Dedicated Customer Service 1. Respond to calls and 1. Continuously 1. Number of calls number for all Public inquiries within one Permit Years 1-5 received and number Services has been business day (for non- FY21/22 of resolutions established where citizens emergencies), and FY22/23 can call to report stormwater immediately to an IDDE. FY23/24 pollution violations. FY24/25 FY25/26 2. Advertise 2. Continuously 2. Number of views hotline/helpline in all ads, Permit Years 1-5 per post, date, and printed materials, social FY21/22 topic media, and website. FY22/23 FY23/24 FY24/25 FY25/26 13. Social Media Work with the City of High 1. Schedule at least 3 1. Continuously 1. Number of views Point's Public Information stormwater specific Permit Years 1-5 per post Office to promote information informational posts per FY21/22 about upcoming events and year. FY22/23 other stormwater-related FY23/24 educational information using FY24/25 multiple social media outlets FY25/26 (Facebook, Next Door, Twitter, Instagram) DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 22 14. 15. 16. Adopt -a -Street Program A partnership with Keep High Point Beautiful for volunteers to participate in picking up litter from their adopted street. Adopt -a -Stream Program Provide public and private organizations the opportunity for volunteers to participate in cleaning up local streams. Storm Drain Marking Program Volunteers place drain markers on storm drains to assist in stormwater and watershed education within neighborhoods and public streets. 1. Check in with Keep High Point Beautiful President for Adopt -a -Street results 1. Partner and coordinate with organizations in efforts to clean up adopted stream. 2. Recruit at least one new group per year. 1. Recruit at least one new group per year. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Pounds of trash and recycling collected, date and number of participants 1. Pounds of trash and recycling collected, date and number of participants 2. Number of new groups and date of adoption, update number of total groups 1. Number of storm drains marked, number of participants DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 23 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 3.4.1: MS4 Map Ref. 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. A B C D BMP No. Description of BMP ' Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 17. Stormwater System Inventory Provide dedicated field staff to 1. Add pertinent 1. Continuously 1. Yes/No/Status collect and update Stormwater data for new Permit Years 1-5 infrastructure data. stormwater FY21/22 infrastructure (pipes, FY22/23 junctions, structures, outfalls) to our FY23/24 Stormwater GIS FY24/25 system for new FY25/26 construction 18. Stormwater Web Map All SCMs within the City of High 1. Add new SCMs to 1. Continuously 1. Yes/No/Status Point are identified and added to mapping database once Permit Years 1-5 the current SCM Stormwater Web construction and/or FY21/22 Map. conversion from FY22/23 erosion control basin FY23/24 FY24/25 FY25/26 19. Camera Crew In-house staff collects 1. Maintain process 1. Continuously 1. Yes/No/Status stormwater infrastructure data for collecting data Permit Years 1-5 for existing systems using pipe and incorporating FY21/22 camera. pertinent information FY22/23 into GIS database FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 24 Permit 3.4.2: Regulatory Mechanism Ref. Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminateillicit connections and discharges, illegal dumping, and spills into the MS4 inc tiding enforcement procedures and actions. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 20. Enforcement The Illicit Discharge Control 1. Maintain illicit 1. Continuously 1. Yes/No/Status Ordinance will charge the discharge ordinance, Permit Years 1-5 Public Services Director or administration, and FY21/22 designee with implementing enforcement FY22/23 the Illicit Discharge Detection procedures. FY23/24 and Elimination program. The FY24/25 ordinance does specify legal FY25/26 penalties to be implemented in cases of non-compliance. (Code of Ordinances, Title 12, Chapter 3 - Public Nuisances). Permit 3.4.3: IDDE Plan Ref. 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 A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 21. Written IDDE Plan Maintain and implement a written 1. Continue to update 1. Continuously 1. Yes/No/Status IDDE Plan. the IDDE Plan as Permit Years 1-5 required by any FY21/22 change in ordinance, FY22/23 state statute or other federal regulation than FY23/24 is specific to IDDE FY24/25 incidents FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 25 22. Outfall Inspections Perform regular dry weather (no 1. Inspect 25% of all 1. Continuously 1. Yes/No/Status rain in previous 72 hours) outfall major outfalls within Permit Years 1-5 inspections to proactively identify the City limits every FY21/22 illicit discharges and illicit year. FY22/23 connections. FY23/24 FY24/25 FY25/26 23. Detection and Elimination Detect and identify illicit 1. Continue to 1. Continuously 1. Yes/No/Status discharges and connections; respond to IDDEs, Permit Years 1-5 conduct dry -weather outfall train employees, and FY21/22 monitoring; respond to citizen conduct outfall FY22/23 concerns made via the Customer monitoring Service line; train City personnel FY23/24 on recognizing and reporting FY24/25 illicit discharges or connections. FY25/26 2. Maintain equipment 2. Continuously 2. Yes/No/Status and materials to detect Permit Years 1-5 IDDEs and analyze FY21/22 stormwater samples. FY22/23 FY23/24 FY24/25 FY25/26 Permit 3.4.4: IDDE Tracking Ref. 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 A B C D No Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 24. Notice of Violation (NOV) Letters NOVs with a detailed 1. Continue to update 1. Continuously 1. Yes/No/Status description of the incident along system processing of Permit Years 1-5 with date/time stamped photos IDDE records and FY21/22 are sent certified mail to the implement procedures FY22/23 violator or representative. that may increase Follow-up occurs when the time efficiency of handling FY23/24 allotted for compliance has these incidents FY24/25 expired. FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 26 2. Store illicit discharge 2. Continuously 2. Yes/No/Number of information in database permit Years 1-5 enforcement actions and Excel spreadsheet; FY21/22 issued maintain hard copies of FY22/23 NOV letters, photos, and other pertinent FY23/24 information in physical FY24/25 files FY25/26 Permit 3.4.5: Staff IDDE Training Ref. 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, illicit connections, illegal dumping, and spills. Each staff training event shall be documented, including the agenda/materials, date, and number of staff participating. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 25. Staff Training Provide stormwater training to 1. Maintain an 1. Annually 1. Yes/No/Status, all groups of municipal staff employee training Permit Years 1-5 dates, topics, and number trained and/or contractors each year. program on g ro detecting FY21/22 Training shall include how and reporting illicit FY22/23 to identify and report illicit discharges, illicit FY23/24 discharges, illicit connections, connections, illegal FY24/25dumping, illegal dumping, and spills. and spills. FY25/26 Permit 3.4.6: IDDE Reporting Ref. 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 A B C D No; Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 26. Stormwater Hotline Dedicated Customer Service 1. Promote and 1. Continuously 1. Number of IDDEs number for all Public Services publicize phone Permit Years 1-5 reported each year. has been established where number to receive FY21/22 citizens can call to report reports related to FY22/23 stormwater pollution violations. illicit discharges. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 27 27. On -Call Duty Officer On -Call duty officer to be 1. Promote and 1. Continuously 1. Number of IDDEs available after normal business publicize phone Permit Years 1-5 reported each year. hours to investigate illicit number to receive FY21/22 discharges, illegal dumping reports related to FY22/23 and spills if reported. illicit discharges. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 28 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 and the NCGO10000 permit for construction activities 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 and any construction activity that is part of a larger common plan of development that would disturb one acre or more. Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Permit Implementing Meets Whole Reference State or Local Legal Authority 'Entity or Part of Program Name Requirement 3.5.1 - City of High Point 15A NCAC City of High Point Whole 3.5.4 Delegated SPCA Program* Chapter 04 * The local delegated SPCA Program ordinance(s)/regulatory mechanism(s) can be found in the City of High Point Development Ordinance, Chapter 6, Section 6.3 - Soil Erosion and Sedimentation; and Chapter 9, Sections 9.5. — Enforcement, 9.6. - Enforcement Procedure , 9.7. — Remedies, and 9.9. - Assessment of Civil Penalties. The City of High Point also implements the following BMPs to meet NPDES MS4 Permit requirements. Table 17: Construction Site Runoff Control BMPs Permit ' 3.5.6: ; Public Input Ref. Measures to provide and promote 'a means for the public to notify the appropriate authorities of observed erosion and sedimentation ``problems. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 28. Municipal Staff Training Train municipal staff who receive 1. Train municipal staff 1. Continuously 1. Yes/No/Status, calls from the public on the (new employees and/or Permit Years 1-5 training date, protocols for referral and tracking employees new to the FY21/22 topic(s) and of construction site runoff control Erosion Control FY22/23 number trained complaints. Inspector position) on FY23/24 proper handling of construction site runoff FY24/25 control complaints. FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 29 29. Stormwater Hotline Dedicated Customer Service 1. Respond to calls 1. Continuously 1. Number of calls number for all Public Services has and inquiries within Permit Years 1-5 received and been established where citizens one business day (for Fy21/22 number of can call to report stonnwater non -emergencies), and FY22/23 resolutions pollution violations. This number immediately to an is publicized on the website, IDDE FY23/24 stormwater flyers and give-away FY24/25 items (pens, pencils, magnates, FY25/26 etc.) 2. Advertise 2. Continuously 2. Yes/No/Status hotline/helpline in all Permit Years 1-5 ads, printed materials, FY21/22 social media, and FY22/23 website. FY23/24 FY24/25 FY25/26 Permit 3.5.5:Waste Management Ref. 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 A B C D No, Description of BMP Measurable Goal(s) Schedule 'for Implementation Annual Reporting Metric 30. Establish and Maintain Legal Authority Provide ordinance language to 1. Develop, adopt 1. Permit Year 1 1. Yes/No/Status, require construction site operators and/or update the FY21/22 date of adoption to control waste ordinance 2. Maintain Legal 2. Continuously 2. Yes/No/Summary Authority Permit Years 2-5 FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 30 31. Pre -Construction Conference Conduct project conferences 1. Conduct Pre- 1. Continuously 1. Document and report with contractors, engineers, Construction Permit Years 1-5 number of plan reviewers and site Meetings FY21/22 preconstruction construction inspectors for all FY22/23 conferences projects with land disturbing FY23/24 activities requiring an E&SC FY24/25 plan FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 31 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 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 (Ord. No. 7266/17-08 , § 2, 1- Ordinance Chapter 2.2 17-2017; Ord. No. 7476/18-105, § 2.13, 12-3- 2018); 3.6.3(a) & 15A NCAC City of High Point Development (Ord. No. 7266/17-08 , § 27, 02H.0153(c) Federal, State & Ordinance Chapter 6.2 1-17-2017; Ord. No. Local Projects 7287/17-29, § 12, 4-3-2017) DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 32 3.6.3(b) Plan Review City of High Point Development (Ord. No. 7266/17-08 , § 2, Ordinance Chapter 2.2 1-17-2017; Ord. No. 7476/18-105, § 2.13, 12-3- 2018); 3.6.3(c) O&M Agreement City of High Point Development Ord. No. 7266/17-08 , § 27, Ordinance Chapter 6.2.11 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 Ord. No. 7266/17-08 , § 27, Ordinance Chapter 6.2.11 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 City of High Point Development Ord. No. 7266/17-08 , § 27, Restrictions/Covenants Ordinance Chapter 6.2.11 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 Ord. No. 7266/17-08 , § 27, Ordinance Chapter 6.2.11 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 Ord. No. 7266/17-08 , § 27, Ordinance Chapter 6.2.11 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 Ord. No. 7266/17-08 , § 27, Ordinance Chapter 6.2.11 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 Ord. No. 7266/17-08 , § 27, Ordinance Chapter 6.2.11 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 v2 The City of High Point February 22, 2021 Page 33 3.6.4(b) Compliance with City of High Point Development Ord. No. 7266/17-08 , § 27, Plans Ordinance Chapter 6.2.11 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(c) Annual SCM City of High Point Development Ord. No. 7266/17-08 , § 27, Inspections Ordinance Chapter 6.2.11 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 City of High Point Development Ord. No. 7266/17-08 , § 27, Inspections Ordinance Chapter 6.2.11 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 City of High Point Development Ord. No. 7266/17-08 , § 27, Professional Ordinance Chapter 6.2.11 1-17-2017; Ord. No. 72.87/17-2.9, §§ 12, 13, 4-3- 2017; Ord. No. 7365/17- 108, § 1, 11-20-2017) Permit Requirements for Municipal Ordinance/Code Date Adopted Fecal Coliform Reduction Reference(s) and/or Document Title(s) 3.6.6(a) Pet Waste City of High Point Code of (Ord. No. 6168/04-65, § 1, Ordinances, Title 12, Chapter 3, 9-7-04; Ord. No. 6541/08- Sec. 12-3-1 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 v2 The City of High Point February 22, 2021 Page 34 Table 20: Post Construction Site Runoff Control BMPs Permit 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post -Construction Reporting Requirements Ref. 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 tillpost-construction pro rains and QAPs. Do not edit this BMP. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 32. Standard Reporting Implement standardized tracking, 1. Track number of 1. Continuously 1. Number of reviews documentation, inspections, and low density and high Permit Years 1-5 reporting mechanisms to compile density plan reviews FY21/22 appropriate data for the annual performed. FY22/23 self -assessment process. Data shall be provided for each Post- FY23/24 Construction/ Qualifying FY24/25 Alternative Program being FY25/26 implemented as listed in Tables 2. Track number of 2. Continuously 2. Number of 18 and 19. and �i low density ` hi Permit Years 1-5 approvals density plans FY21/22 approved. FY22/23 FY23/24 FY24/25 FY25/26 3. Maintain a current 3. Continuously 3. Number and type of inventory of low Permit Years 1-5 SCMs constructed density projects and FY21/22 constructed SCMs FY22/23 including SCM type or low density acreage, FY23/24 location, and last FY24/25 inspection date. FY25/26 4. Track number of 4. Continuously 4. Number of SCM SCM inspections Permit Years 1-5 inspections performed. FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 35 5. Track number of low density inspections performed. 6. Track number and type of enforcement actions taken. 5. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 6. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 5. Number of low density inspections 6. Number and type of enforcement actions taken. Permit 3.6.3: Plan Review and Approval Ref. 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 entity 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. 10 17 and the qualifying alternative programs that apply within your jurisdiction, (c) Ensure that each project has an Operation and Maintenance Agreement that complies with 15A 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 exlslit?g post-collstrucllon pl•ograrn, see references nrovided in Table 19. Permit 3.6.4: Inspections and Enforcement Ref. 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 host -construction program, see references provided in Table 19. Permit 3.6.6: Fecal Coliform Reduction Ref. 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 provided in Table 19. DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 36 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 Preventionand Good Housekeeping BMPs Permit 3.7.1: 'Municipal Facilities Operation and Maintenance Program Ref. 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 in establish specific frequencies, schedules, and standard documentation; provide staff training' on general stormwater awareness and implementing pollution prevention and goodihousekeeping practices. BMP A B C D No: Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 33. Operation and Maintenance Plan Maintain and update a written 1. Implement all 1. Continuously 1. Yes/No/Status Operation and Maintenance Plan. aspects of the O&M Permit Years 1-5 Summary Plan FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 37 2. Update plan on 2. Annually 2. Yes/No/Status an annual basis. Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 34. Inventory of Municipal Facilities Update and maintain inventory of 1. Review and update 1. Annually 1. Yes/No/Date municipal facilities that have the list of municipal Permit Years 1-5 updated potential to generate polluted facilities. FY21/22 stormwater runoff. FY22/23 FY23/24 FY24/25 FY25/26 35. Municipal Facility Inspections Inspect municipal facilities 1. Review and update 1. Annually 2. Yes/No/Status deemed to have the potential to municipal inspection Permit Years 1-5 generate polluted stormwater forms. FY21/22 runoff. FY22/23 FY23/24 FY24/25 FY25/26 2. Perform municipal 2. Annually 2. Yes/No/Status, facility inspections on Permit Years 1-5 number of inspections those facilities that FY21/22 have the potential to FY22/23 pollute stormwater. FY23/24 FY24/25 FY25/26 36. Municipal Employee Training Conduct annual stormwater 1. Perform employee 1. Annually 1. Yes/No/Status, training that covers general training at Facilities Permit Years 1-5 training dates, topics stormwater awareness, pollution that have been FY21/22 and number trained prevention and spill response, and identified as having FY22/23 IDDE reporting the possibility to have a negative impact on FY23/24 stormwater. FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 3 8 Permit 3.7.2: Spill Response Program Ref. 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 s ill res use procedures. BMP A B C D No. Description of BMP Measurable+Goal(s) Schedule for Annual Reporting Implementation Metric 37. Spill Response Plan A written spill response plan has 1. Review and update 1. Annually 1. Yes/No/Status been developed for municipal Spill Response Plan Permit Years 1-5 facilities that store or use annually to ensure plan FY21/22 materials that could contaminate is effective. FY22/23 stormwater runoff. Municipal facilities with industrial permits FY23/24 have a spill response plan as part FY24/25 of their Stormwater Pollution FY25/26 2. Perform spill 2. Annually 1. Yes/No/Status, Prevention Plan or SPCC Plan. response training for Permit Years 1-5 training date, topics, municipal employees FY21/22 and number trained annually. FY22/23 FY23/24 FY24/25 FY25/26_ 3. Evaluate municipal 3. Annually 3. Yes/No/Status facilities to determine Permit Years 1-5 if any need to be added FY21/22 or removed from those FY22/23 requiring a Spill Response Plan. FY23/24 FY24/25 FY25/26 38. Maintain Inventory of Facilities with a Spill Response Plan Maintain a list of city facilities 1. Update list of city 1. Annually 1. Yes/No/Status that have a SPCC Plan, SWPPP, facilities with the Permit Years 1-5 or Spill Response Plan. potential to pollute FY21/22 stormwater. FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 39 Permit 3.7.3: MS4 Operation and Maintenance Program Ref: Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff trainingon 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 Description of BMP Measurable Goal(s) Schedule for Annual Reporting No :Implementation Metric 39. Inspections and Maintenance of Stormwater Conveyances Inspection and Maintenance Plan 1. Develop an SOP 1. Permit Year 1 1. Yes/No/Status for stormwater infrastructure that identifies FY21/22 inspections. frequencies and documentation for maintenance. 2.Perform inspections 2. Annually 2. Yes/No/Status in accordance with Permit Years 1-5 SOP FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3.Maintenance is 3. Continuously 3. Yes/No/Status prioritized by citizen Permit Years 1-5 reports or inspections. FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 40. Employee Training Continue stormwater training to 1. Provide training to 1. Annually 1. Yes/No/Status, employees within the Public employees. Permit Years 1-5 training date, topic, and Services Department. FY21/22 number trained FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 40 Permit 3.7.4: Municipal SCM Operation and Maintenance Program` Ref. 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 establish specific frequencies, schedules, and documentation. BMP A B C D No. Description of BMP Measurable'Goal(s) Schedule for Annual Reporting Implementation Metric 41. Municipal SCM Inventory Maintain inventory of municipally 1. Maintain Operation 1. Continuously 1. Yes/No/Status owned structural SCMs. and Maintenance plans Permit Years 1-5 for all City -owned FY21/22 SCMs. FY22/23 FY23/24 FY24/25 FY25/26 2. Update inventory of 2. Continuously 1. Yes/No/Date City -owned SCMs. Permit Years 1-5 updated FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Maintain NC SCM 3. Continuously 3. Yes/No/Status Inspection and Permit Years 1-5 Maintenance FY21/22 Certification for FY22/23 approved personnel. FY23/24 FY24/25 FY25/26 42. SCM Inspection and Maintenance Perform regular inspections and 1. NC SCM 1. Continuously 1. Yes/No/Status maintenance of municipal SCMs Certification is Permit Years 1-5 and document on an annual basis maintained by FY21/22 with all related documentation Stormwater Staff FY22/23 stored in a tracking database. conducting SCM inspections. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 41 2. SCM inspections are 2. Continuously 2. Number of conducted per the Permit Years 1-5 inspections performed SCM Inspection SOP. FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Perform needed 3. Continuously 3. Number of maintenance identified permit Years 1-5 enforcement actions during the inspections. FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 4. Update the tracking 4. Continuously 4. Yes/No/Status data base with Permit Years 1-5 inspection status and FY21/22 documents. FY22/23 FY23/24 FY24/25 FY25/26 Permit 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Ref.' 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 training, and shall ensure compliance with permits and applicator certifications. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 43. Applicator Training for Pesticides, Herbicides and Fertilizer Training of city staff who apply 1. Maintain proper 1. Continuously 1. Yes/No/Status chemicals to help prevent licenses or certification Permit Years 1-5 negative water quality impacts for applying FY21/22 from pesticides, herbicides, and pesticides, herbicides, FY22/23 fertilizers. and fertilizers. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 42 2. Provide staff 2. Continuously 2. Yes/No/Status, training in pollution Permit Years 1-5 training date, topic and prevention and FY21/22 number trained applying chemicals FY'ZZ%l3 FY23/24 FY24/25 FY25/26 Permit 3.7.6: Vehicle and Equipment Maintenance Program Ref. 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 A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 44. NPDES Industrial Permit Compliance Ensure that municipal facilities 1. Update municipal 1. Annually 1. Yes/No/Status covered under a NPDES industrial facility inventory with permit Years 1-5 permit are maintaining NPDES permit status. FY21/22 compliance. FY22/23 FY23/24 FY24/25 FY25/26 2. Ensure that all 2. Annually 2. Yes/No/Status NPDES Permits for Permit Years 1-5 municipal facilities are FY21/22 renewed as needed. FY22/23 FY23/24 FY24/25 FY25/26 3. Use industrial 3. Annually 3. Yes/No/Status facility inspection Permit Years 1-5 form when conducting FY21/22 annual inspections at FY22/23 municipal facilities covered under a FY23/24 NPDES permit. FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 43 4. Complete annual 4. Annually 4. Yes/No/Status, training Permit Years 1-5 training dates, topics FY21/22 and number trained FY22/23 FY23/24 FY24/25 FY25/26 45. Vehicle and Equipment Cleaning and Maintenance Facility Inspections Vehicle and equipment cleaning 1. Perform annual 1. Annually 1. Yes/No/Status and maintenance is included as inspections and notify Permit Years 1-5 part of the annual facility responsible person of FY21/22 inspection. any corrective actions FY22/23 required. FY23/24 FY24/25 FY25/26 2. Ensure any 2. Continuously 2. Yes/No/Status corrective actions are Permit Years 1-5 made by conducting a FY21/22 follow-up inspection FY22/23 and/or contacting the responsible person. FY23/24 FY24/25 FY25/26 Permit 3.7.7: Pavement Management Program Ref. 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 A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 46. Street Sweeping Street sweeping following a 1. Develop a standard 1. Permit Year 1 1. Yes/No/Status regular schedule in order to operating procedure, FY21/22 reduce pollutants from City including schedules, owned and maintained streets. zones/locations, and proper disposal of collected wash waters and solids. DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 44 2. Implement SOP 2. Annually 2. Number of street and documentation. Permit Years 1-5 miles swept FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 47. Loose Leaf Collection Provide seasonal loose leaf 1. Publicize/establish 1. Annually 1. Yes/No/Status collection in residential areas and protocols for Permit Years 1-5 compost the collected material at residential brush and FY21/22 the city operated composting bagged leaf center for use by the city and collections. FY22/23 residents. FY23/24 FY24/25 FY25/26 2. Collect brush and 2. Annually 2. Total weight of bagged leaves Permit Years 1-5 brush collected FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 45 APPENDIX A Jay Wagner Mayor City Council Randy McCaslin Interim City Manager Trevor Spencer Terry Houk Bob Martin Engineering Services Director Public Services Director Customer Services Director Robby Stone Deputy Public Services Director Material Recycling Facility Stormwater Management Division Environmental Services Division Melanie Bruton ; (Vacant) Greg Holt MRF Superintendent Public Services Manager Environmental Services Superintendent Street Maintenance Division Ken :Sult Street Maintenance Superintendent R-1/28/2021 DRAFT NCS000421 SWMP v2 The City of High Point February 22, 2021 Page 46