The URL can be used to link to this page

Home My WebLink AboutNCS000421_High Point Draft SWMP v2 Comments Mark-Up_20210621Draft Stormwater Management Plan City of High Point NCS000421 February 22, 2021 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Table of Contents PART 1: INTRODUCTION...................................................................................................... I 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....................................................................................................... 6 3.5 Total Maximum Daily Loads (TMDLs)........................................................................... 6 3.6 Endangered and Threatened Species and Critical Habitat................................................7 3.7 Industrial Facility Discharges.........................................................................................8 3.8 Non-Stormwater Discharges.........................................................................................11 3.9 Target Pollutants and Sources.......................................................................................12 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ...................13 4.1 Organizational Structure...............................................................................................13 4.2 Program Funding and Budget.......................................................................................15 4.3 Shared Responsibility...................................................................................................15 4.4 Co-Permittees...............................................................................................................16 4.5 Measurable Goals for Program Administration.............................................................16 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM.........................................17 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ...........................26 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM...............29 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM...................................35 PART 9: POST -CONSTRUCTION SITE RUNOFF CONTROL PROGRAM .........................38 PART10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ......... 37 Y , DRAFT NCS000421 SWMP The City of High Point February 22, 2021 List of Tables Table 1: Summary of MS4 Mapping 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 February 22, 2021 DRAFT NCS000421 SWMP 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. Any major changes to the approved SWMP will requil resubmittal, review and approval by NCDEQ, and may require a new public comment period depending on the nature of the changes. L-1 DRAFT NCS000421 SWMP 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: Print Name: - Randy McCaslin Title: Interim City Manager Signed this 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. za DRAFT 1114 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 the Point. 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 1,203 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 Man 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 303 (d) List Classification 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 Branc February 22, 2021 Page 4 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 Boulding Branch Boulding Branch 17-3-2 WS-IV N/A im West Fork of Deep Riv 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) Richland Creek 17-7-(0.5) WS-IV CA Richland Creek WS-IV Eco/Biological Integrity Fish Com Fecal Coliform Richland Creek 17-7-(4) WS-IV;CA Fecal Coliform Yadkin River Basin Rich Fork Creek h1k j Rich Fork Creek 12-119-7 C —:Iff 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. —does/does not i e Mull T TS4 and includes: jWe interconnection is/is not receiving stormwater from the NCDOT TS4. The number of interconnections is known/estimated/unknown. Quantity: ## or N/A b. The interconnection is/is not discharging stormwater into the NCDOT TS4. The n}� interconnections is known/estimated/unknown. Quantity: ## or N/A c. The MS4name MS4 mapping does/does not identify interc d. The MS4name MS4 mapping does/does not include NCDOT TS4 outfaZ 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 February 22, 2021 Page 6 Water Body Name TMDL Pollutant(s) of Concern Stormwate Water r Waste Quality Load Recover Allocation y (Y/N) Program E. Fork Deep River Fecal Coliform Y Yi Richland Creek Fecal Coliform Y Y2 Rich Fork Creek Fecal Coliform Y ' Y Y': Outfall monitoring program only Y2 : TMDL water quality monitoring plan (2015) DRAFT NCS000421 SWMP The City of High Point 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endan ered species and/or critical habitat are identified within the regulated MS4 urbanized area. a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Man and Listed species believe to or known to occur in North Carolina mqp as provided by the U.S. Fish and Wildlife ServicePWe species listed in Table ave ial the regulated Murbanized area . 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: 7671777117ederally 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 Guilford pogonia Plants Helianthus Schweinitz's Flowering Endangered Davidson schweinitzii sunflower Plants Guilford Randolph Perimyotis subflavus Tricolored bat Mammals Under Review Davidson, Forsyth February 22, 2021 Page 7 Clemmys Bog Turtle Reptiles Threatened muhlenbergii 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 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 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 NCG080683 Glass Unlimited -High Point Inc 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) Larco Construction Co - High Point NCG160041 NCG170388 Chambers Fabrics Incorporated NCGI80036 Haworth Inc -Wood Seating Plant February 22, 2021 Page 8 NCG180220 High Point Furniture Industries NCG 180254 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 Carpenter Co - High Point NCGNE0264 NCGNE0281 Henredon Furniture -Guilford DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 9 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 NCGNE 1022 High Point Furniture Industries NCGNE 1131 Fastenal Company NCGNE 1144 V&E Components, Inc. NCGNE 1208 Thomas Clyde Lamar ARC NCO28 NCGNE1227 Fortis Solutions Group NCGNE1255 Ornamental Products LLC NCGNE 1323 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 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-Stormwater Discharges 11 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 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 Pollutant(s) Audience(s) Pollutant(s)/Audience(s) Litter General Public, Businesses, Public Education & Outreach, Public Schools Participation Pet Waste General Public, Schools, Parks, Public Education & Outreach, Illicit Greenways be Discharge Detection & Elimination Sediment Construction Erosion, Stream Construction Site Runoff Control Bank Erosion Illicit Discharges General Public, OTusinesses, 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, Le Pollution Prevention & Good Housekeeping 21 SWMP Page 10 DRAFT NCS0004 The City of High Point February 22, 2021 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 Or 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 Engineering Services Abigail Rosendale Construction Site Trevor Spencer Engineering Services Runoff Control Director Erosion Control Scott Ford N $000, Inspectors Kathy Blake Post -Construction Operations Analyst Anita Simpson Public Services — Stormwater Stormwater Division Management DRAFT NCS0004 The City of High Point February 22, 2021 21 SWMP 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 Program All Stormwater All Stormwater Public Services — 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 Manager VACANT IK Public Services — Operation & 4 Stormwater Division Maintenance Program 009W Pesticide, Herbicide & Safety Officer Jim Gwynn Public Services Fertilizer Management , Program \ Vehicle & Equipment Public Servic s Manager VACANT Public Services — Cleaning Program N Stormwater Division Pavement Management Public Services Manager VACANT Public Services — Streets Program 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 21 SWMP DRAFT NCS0004 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. t 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 Permit Requirement Implementing Entity & Program Name Legal Agreement (Y/N) N/A 21 SWMP DRAFT NCS0004 The City of High Point February 22, 2021 Page 15 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 -Pee MS4 Contact Person Phone & E-Mail Interlocal Agreement Name ( ) 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 year (July 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. _ of SWMP implementation, submit the Annual Self- Permit Years 1-4 suitability of SWMP Assessment to NCDEQ FY21/22 commitments and any prior to August 31st FY22/23 proposed changes to the each year. FY23/24 SWMP utilizing the NCDEQ FY24/25 Annual Self- Assessment Template. Page 16 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 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. A B C D BMP No. Description of Measurable Goal(s) Schedule for Annual Reporting BMP Implementation Metric 2. Permit Renewal Application I Audit stormwater program 1. Participate in an 1. TBD — Typically 1. _ implementation for NPDES MS4 Permit Permit Year 4 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. Permit Year 5 application package. 2. Self -audit and 2. Yes/No/Partial document any FY25/26 stormwater program components not audited by EPA or NCDEQ utilizing the DEQ Audit Template. mrt Self -Audi to WMLR (require] Omponent of pen' Wewal applicatiol package) 3.. Certify the stormwatj 3. Permit Year 5 3. Date of peml permit renewal FY25/26 renewal applicatid application (Permit submittal renewal application = Self -Audit, and Draft SWMP for the next permit cycle) and sub m to NCDEQ at least 1$� days prior to permit expiration. PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 17 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 r General Public, Businesses Pet waste/Fecal Coliform General Public, Public/Private Ranitary Sewer Infrastructure Sediment Developers, Contractors, Homeowners, Landscapers Fats, Oils & Grease Ahhm� 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 Raw The City of High Point will manage, implement, and report the following public education and outreach BMPs. Y DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 16 Page 19 Table 13: Public Education and Outreach BMPs 3.2.2 and 3.2.4: Outreach to Targeted Audiences Permit 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 provide educational 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 C D No. Description of Measurable Goal(s) Schedule for Annual Reporting BMP Implementation Metric - - A 3. School Outreach Develop age -specific 1. Provide age -specific 1. Continuously 1. Number of students educational information stormwater presentations Permit Years 1-5 for use in schools and for upon request. FY21/22 presentations to school FY22/23 age children. Will FY23/24 present information in FY24/25 appropriate format. FY25/26 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 habitat 3. Continuously 3. Number of participants events for schools and/or Permit Years 1-5 summer camps as FY21/22 requested FY22/23 FY23/24 FY24/25 FY25/26 *Scheduling is currently impacted due to COV11)49 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 20 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 and locations in order to FY21/22 reach diverse groups, FY22/23 minorities, and underserved FY23/24 populations. Educational FY24/25 topics will vary and may FY25/26 include general stormwater 2. Monthly Farmer's 2. Continuously 2. Number of interactions at awareness and the Market Table Permit Years 1-5 the table pollutants/sources listed in FY21/22 Table 12 above for the FY22/23 general public target audience FY23/24 (litter, pet waste, FOG, FY24/25 nutrients, illicit discharges, FY25/26 illegal dumping). 3. Attend at least 3 other 3. Continuously 3. Number of events held and City of High Permit Years 1-5 number of interactions at the Point Public events. FY21/22 table FY22/23 FY23/24 FY24/25 FY25/26 4. Coordinate and 4. Annually 4. Number of attendees attend the annual Public Permit years 1-5 Services Day event. FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 ■ DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 21 5. Utility Bill Inserts r/ Stormwater bill inserts will 1. Develop and 1. Semi -Annually continue to be inserted into distribute a stormwater Permit Year 1 1. Number of flyers combined utility bill statements and flyer for general FY21/22 mailed distributed to all City residents and stormwater information businesses receiving a utility bill on and pet waste at least a semi- annual schedule. 2. Develop and 2. Semi -Annually 2. Number of flyers distribute a stormwater Permit Year 2 mailed 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 flyer for FY23/24 l� litter/household 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 flyer for general FY24/25 stormwater information and fats, oil and grease (FOG). DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 22 5. Develop and 5. Semi -Annually 5. Number of flyers distribute a stormwater Permit Year 5 mailed 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 well groups, and/or FY21/22 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 documents and FY22/23 giveaways. FY23/24 FY24/25 FY25/26 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 OW, FY24/25 FY25/26 8. Social Media DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 23 Work with the City of High Point's 1. Post at least three 1. Annually 1. Number of views Public Information Office to stormwater specific Permit Years 1-5 per postand topic promote information about informational social FY21/22 upcoming events and other media posts per year. FY22/23 stormwater- 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. Annually 1. Yes/No/Status, an digital advertising spaces to year, use nonmunicipal Permit Years 1-5 topic(s) displayed increase visibility of the website or outdoor FY21/22 stormwater message. advertisement space FY22/23 (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, etc.) to display a informational stormwater message. 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. Schedule for Annual Reporting Description of BMP Measurable Goal(s) Implementation Metric i 10. Informational Web Site DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 24 The Stormwater Services 1. Maintain the 1. Continuously 1. Yes/No/Status, Division will maintain an internet stormwater web page Permit Years 1-5 web site that contains detailed and update any FY21/22 information regarding all aspects changes as needed. FY22/23 of the stormwater permit FY23/24 requirements, services offered, FY24/25 educational brochures/fliers and FY25/26 reporting/contact information. 2. Add a link on the 2. Permit Year 1 2. Yes/No/Status Stormwater FY21/22 webpage to the NCDEQ Stormwater webpage Permit 3.2.5: 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 and inquiries within Permit Years 1-5 received and number has been established where one business day (for FY21/22 of resolutions citizens can call to report non- emergencies), FY22/23 stormwater pollution violations. and immediately to an FY23/24 This number is publicized on the IDDE. FY24/25 website, stormwater flyers and FY25/26 give-away 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 .0A media, and website. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 25 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 public involvement that provide for input on stormwater issues and the stormwater program. BMP A B C D No. Annual Reporting Description of BMP Measurable Goal(s) Schedule for Implementation Metric 12. Stormwater Hotline Dedicated Customer Service See BMP 11 See BMP 11 See BMP 11 number for all Public Services has been established where citizens can call to report stormwater pollution violations. See BMP 11 13. DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 26 Permit 3.3.2: Volunteer Opportunities Ref. Measures to provide volunteer opportunities designed to promote ongoing citizen participation. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Metric Implementation 14. Adopt -a -Street Program ' A partnership with Keep High 1. Check in with 1. Annually 1. Pounds of trash Point Beautiful for volunteers to Keep High Point Permit Years 1-5 and recycling participate in picking up litter Beautiful President FY21/22 collected, date and from their adopted street. for Adopt -a -Street FY22/23 number of results FY23/24 participants FY24/25 FY25/26 15. Adopt -a -Stream Program Provide public and private 1. Partner and 1. Annually 1. Pounds of trash and organizations the opportunity coordinate with Permit Years 1-5 recycling collected, for volunteers to participate in organizations in FY21/22 date and number of cleaning up local streams. efforts to clean up FY22/23 participants adopted stream. FY23/24 , FY24/25 FY25/26 2. Recruit at least one 2. Annually 2. Number of new groups new Adopt -a -Stream Permit Years 1-5 group per year. FY21/22 FY22/23 FY23/24 FY24/25 01 FY25/26 16. Storm Drain Marking rogram Volunteers place drain markers 1. Recruit at least one 1. Annually 1. Yes/No/Status on storm drains to assist in new storm drain Permit Years 1-5 stormwater and watershed marking volunteer FY21/22 education within group per year. FY22/23 neighborhoods and public FY23/24 streets. FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 27 2. Coordinate storm drain marking and track marked drains 2. Annually Permit Years 1-5 FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of storm drains marked, number of participants DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 28 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 A outfalls and waters of the B United States receiving stormwater C discharges. D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 17. Storm Sewer System Inventory Provide dedicated field staff to 1. Add pertinent data 1. Continuously 1. Yes/No/Status collect and update stormwater for new stormwater Permit Years 1-5 infrastructure data. infrastructure (pipes, FY21/22 junctions, structures, FY22/23 outfalls) to our FY23/24 Stormwater GIS , FY24/25 system for new FY25/26 construction 2. Maintain storm 2. Continuously 2. Yes/No/Status sewer system map Permit Years 1-5 Total number of including FY21/22 mapped outfalls stormwater FY22/23 conveyances, flow FY23/24 direction, major FY24/25 outfalls and surface FY25/26 waters. 18. Stormwater Web Map DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 29 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 L In-house staff collects stormwater 1. Maintain process for 1. Continuously 1. Yes/No/Status infrastructure data for existing collecting data and Permit Years 1-5 systems using pipe camera. incorporating pertinent FY21/22 information into GIS FY22/23 database FY23/24 FY24/25 FY25/26 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 eliminate illicit connections and discharges, illegal dumping, and spills into the MS4, including enforcement procedures and actions. A B C D BMP Description of BMP Measurable Goal(s) Schedule for No. Annual Reporting Implementation Metric 20. Enforcement The Illicit Discharge Control 1. Maintain illicit 1. Continuously 1. Yes/No/Status Ordinance will charge the Public discharge ordinance, Permit Years 1-5 Services Director or designee administration, and FY21/22 with implementing the Illicit enforcement FY22/23 Discharge Detection and procedures. FY23/24 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 impleme it 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. DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 30 The plan shall provide standard pro ;edures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit lischarges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and a ;sess the IDDE Program. A BMP No. Description of BMP 21. 1 Written IDDE Plan Maintain and implement a IDDE Plan. 22. I Outfall Inspections Perform regular dry weather (no rain in previous 72 hours) outfall inspections to proactively identify illicit discharges and illicit connections. 23. Detection and Elimination B Measurable Goal(s) C Schedule for Implementation 1. Continue to update 1. Continuously the IDDE Plan as Permit Years 1-5 required by any change FY21 /22 in ordinance, state FY22/23 statute or other federal FY23/24 regulation than is FY24/25 specific to IDDE FY25/26 incidents 1. Inspect 25% of all major outfalls within the City limits every year. 1. Continuously Permit Years 1-5 FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 01 Annual Reporting Metric 1. Yes/No/Status 1. Yes/No/Status DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 31 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 FY23/24 Service line; train City personnel FY24/25 on recognizing and reporting illicit FY25/26 discharges or connections. 2. Maintain equipment 2. Continuously and materials to detect Permit Years 1-5 2. Yes/No/Status 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. A B C D BMP No. Annual Reporting Metric Description of BMP Measurable Goal(s) Schedule for Implementation 24. Notice of Violation (NOV) Letters NOVs with a detailed description 1. Continue to update 1. Continuously 1. Yes/No/Status of the incident along with system processing of Permit Years 1-5 date/time stamped photos are 0 IDDE records and FY21/22 sent certified mail to the violator implement procedures FY22/23 or representative. Follow-up that may increase FY23/24 occurs when the time allotted for efficiency of handling FY24/25 compliance has expired. these incidents FY25/26 2. Continuously 2. Yes/No/Number o Store illicit discharge Permit Years 1-5 enforcement actions i nformation in database FY21/22 issued and Excel spreadsheet; maintain hard copies of FY22/23 NOV letters, photos, FY23/24 and other pertinent FY24/25 information in physical FY25/26 files DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 32 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 Number trained and/or contractors each year. program on detecting FY21/22 Training shall include how to and reporting illicit FY22/23 identify and report illicit discharges, illicit FY23/24 discharges, illicit connections, connections, illegal FY24/25 illegal dumping, and spills. dumping, 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. Measurable Goal(s) Schedule for Annual Reporting Description of BMP Implementation Metric 26. Stormwater Hotline DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 33 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 Mft� FY25/26 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 and reports related to FY22/23 spills if reported. illicit discharges. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 34 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the MS4name relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 as a qualifying alternative program to meet a portion of the NPDES MS4 Permit requirements for construction site runoff control measures. The SPCA requirements include reducing pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre, and includes any construction activity that is part of a larger common plan of development that would disturb one acre or more. The state SPCA Program is either delegated to a city/town, delegated to a county, or implemented by NCDEQ in non -delegated areas Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program Permit State or Local Legal Implementing Reference Program Name Authority Entity 3.5.1 - City of High Point 15A NCAC City of High Point 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. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 28. Municipal Staff Training AV DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 35 Train municipal staff who 1. Train municipal 1. Nualll 1. receive calls from the public on staff (new employees Permit Years 1-5 the protocols for referral and and/or employees new FY21/22 tracking of construction site to the Erosion Control FY22/23 runoff control complaints. Inspector position) on FY23/24 proper handling of FY24/25 construction site runoff FY25/26 control complaints. 29. Stormwater Hotline Dedicated Customer Service 1. See BMP 11 1. Continuously 1. See BMP 11 number for all Public Services has Permit Years 1-5 been established where citizens can FY21/22 call to report stormwater pollution FY22/23 violations. This number is publicized on the website, See FY23/24 BMP 11 FY24/25 FY25/26 2. See BMP 11 2. See BMP 11 2. See BMP 11 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 Annual Reporting Implementation Metric 30. Establish and Maintain Legal Authority Provide ordinance to require 1. Develop, adopt 1. Permit Year 1 1. Y/N/Status, date construction site operators to and/or update the FY21/22 of control waste ordinance adoption DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 36 31. Pre -Construction Conference Conduct project conferences 1. Conduct 1. Continuously 1. Document and report with contractors, engineers, Pre -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 2. Develop and 2. Continuously 2. Yes/No/Status distribute Permit Years 1-5 Number of Fact Sheets informational Fact FY21/22 distributed Sheet at pre- FY22/23 construction FY23/24 0004, conferences FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 37 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 Municipal Ordinance/Code Date Adopted Plan Review and Approval Reference(s) and/or Document Title(s) 3.6.2(a) Authority City of High Point Development (Ord. No. 7266/17-08 , § 2, 117- Ordinance Chapter 2.2 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, 1-17- 02H.0153(c) Federal, State & Ordinance Chapter 6.2 2017; Ord. No. Local Projects 7287/17-29, § 12, 4-3-2017) DRAFT NCS000421 SWMP 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.B, 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- A 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 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. 7287/17-29, §§ 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 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 A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 32. Standard Reporting x 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 FY23/24 shall be provided for each Post- FY24/25 Construction/ Qualifying FY25/26 Alternative Program being - 2. Track number of low density and high 2. Continuously Permit Years 1-5 2. Number of approvals implemented as listed in Tables 18 and 19. 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 FY23/24 low density acreage, FY24/25 location, and last FY25/26 inspection date. 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 The City of High Point February 22, 2021 Page 42 5. Track number of 5. Continuously 5. Number of low low density Permit Years 1-5 density _ inspections performed. FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 6. Track number and 6. Continuously 6. type of enforcement actions taken. Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 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 .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 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 existing post -construction program, see references provided 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 post -construction program, see references provided in Table 19. DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 43 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 79. 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 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 maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on general stormwater awareness and implementing pollution prevention and good housekeeping practices. BMP A B C D DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 44 No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 33. Operation and Maintenance Plan Maintain and update the written 1. Implement all aspects 1. Continuously 1. Yes/No/Status Operation and Maintenance Plan. of the O&M Permit Years 1-5 Summary Plan FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Update plan on an 2. Annually 2. Yes/No/Status 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 4F FY25/26 35. Municipal Facility Inspection 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 7 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 45 36. I Municipal Employee Training Conduct annual stormwater training that covers general stormwater awareness, pollution prevention and spill response, and IDDE reporting Permit 3.7.2: Spill Response Program Ref. Measures for facilities and operatio stormwater runoff if spilled. The pej spill response procedures. A BMP No. Description of BMP 37. 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. 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 1. Perform employee 1. Annually 1. Yes/No/Status, training at Facilities Permit Years 1-5 Number trained that have been FY21/22 identified as having the FY22/23 possibility to have a FY23/24 negative impact on FY24/25 stormwater. FY25/26 ns that store and/or use materials that have the potential to contaminate -mittee shall maintain written spill response procedures and train staff on B C D Annual Reporting Metric Measurable Goal(s) Schedule for Implementation 1. Review and update 1. Annually 1. Yes/No/Status Spill Response Plan Permit Years 1-5 annually to ensure plan FY21/22 is effective. FY22/23 FY23/24 FY24/25 FY25/26 2. Perform spill 2. Annually 2. Yes/No/Status, response training for Permit Years 1-5 Number trained municipal employees FY21/22 annually. FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 46 3. Evaluate municipal 3. Annually facilities to determine if Permit Years 1-5 any need to be added or FY21122 removed from those FY22/23 requiring a Spill FY23/24 Response Plan. FY24/25 FY25/26 38. 1 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 FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 3. Yes/No/Status 1. YeJFNo/Status 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 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 Schedule for Annual Reporting BMP No. Description of BMP Measurable Goal(s) 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. V DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 47 40. 1 Employee Training Continue stormwater training to employees within the Public Services Department. 2.Perform inspections 2. Annually 2. Yes/No/Status in accordance with Permit Years 1-5 Number of MS4 SOP FY21/22 inspections performed FY22/23 FY23/24 FY24/25 FY25/26 3.Maintain a prioritized Capital Improvement Project (CIP) list. 1. Provide training to employees. 3. Continuously Permit Years 1-5' FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 1. Annually Permit Years 1-5 FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 3. Yes/No/Status Number of CIPs on list. Number of CIPs completed. 1. Yes/No/Status, training date, topic, and number trained Permit 3.7.4: Municipal SCM Operation and Maintenance Program Ref. Measures to manage municipally -owned, operated, and/or maintained structural stormwater control measures (SCNI 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. Schedule for Annual Reporting Description of BMP Measurable Goal(s) Implementation Metric 41. Municipal SCM Inventory DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 48 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 2. Total number of FY22/23 municipal SCMs FY23/24 inventoried FY24/25 FY25/26 3. 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 Number of certified and document on an annual basis maintained by FY21/22 staff with all related documentation Stormwater Staff FY22/23 stored in a tracking database. conducting SCM FY23/24 inspections. FY24/25 FY25/26 2. Conduct annual 2. Annually 2. Number of SCM inspections per Permit Years 1-5 inspections performed the FY21/22 SCM Inspection SOP. FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 49 3. Perform needed 3. Continuously 3. maintenance identified Permit Years 1-5 Number of SCMs during the inspections. FY21/22 maintained 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. A B C D BMP No. Schedule for Annual Reporting Description of BMP Measurable Goal(s) 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 negative licenses or certification Permit Years 1-5 Number of licensed water quality impacts from for applying FY21/22 staff pesticides, herbicides, and pesticides, herbicides, FY22/23 fertilizers. and fertilizers. FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 50 2. Provide staff 2. Continuously 2. Yes/No/Status, training in pollution Permit Years 1-5 Number trained prevention and FY21/22 applying chemicals. FY22/23 FY23/24 FY24/25 FY25/26 3.7.6: Vehicle and Equipment Maintenance Program Permit 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. A B C D BMP 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 Number of industrial municipal facilities are FY21/22 stormwater permitted renewed as needed. FY22/23 facilities FY23/24 FY24/25 FY25/26 3. Use industrial 3. Annually 3. Yes/No/Status facility inspection Permit Years 1-5 Number of industrial form when conducting FY21/22 facility inspections annual inspections at FY22/23 performed municipal facilities FY23/24 covered under a NPDES permit. FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 51 4. Complete annual 4. Annually 4. Yes/No/Status, training Permit Years 1-5 Number trained FY21/22 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 Number of part of the annual facility responsible person of FY21/22 inspections inspection. any corrective actions FY22/23 performed required. FY23/24 FY24/25 FY25/26 2. Ensure any 2. Continuously 2. Yes/No/Status corrective actions are Permit Years 1-5 Number of follow-up made by conducting a FY21/22 inspections follow-up inspection FY22/23 performed and/or contacting the FY23/24 responsible person. 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. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 46. Street Sweeping 1. Develop a standard 1. Permit Year 1 1. Yes/No/Status Street sweeping following a operating procedure, FY21/22 regular schedule in order to reduce including schedules, pollutants from City owned and zones/locations, and maintained streets. proper disposal of collected wash waters and solids. DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 52 2. Implement SOP and 2. Annually 2. Number of street 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. Ye o/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 center bagged leaf FY22/23 for use by the city and residents. collections. FY23/24 FY24/25 FY25/26 2. Collect brush and 2. Annually 2. Total weight of brush bagged leaves Permit Years 1-5 collected/disposed FY21 /22 FY22/23 FY23/24 FY24/25 FY25/26 DRAFT NCS000421 SWMP The City of High Point February 22, 2021 Page 53 /_1»: 1►191cc,1 y y Trevor Spencer Engineering Services Director Material Recycling Facility Melanie Bruton MRFSuperintendent Jay Wagner Mayor City Council Randy McCaslin Interim City Manager Terry Houk Public Services Director Robby Stone Deputy Public Services Director Stormwater Management Division (Vacant) Public Services Manager Street Maintenance Division Ken Sult Street Maintenance Superintendent Bob Martin Customer Services Director Environmental Services Division Greg Holt Environmental Services Superintendent Rev. 1/28/2021