NCS000408_02_Graham-CSWMP-Report 2017rev. August 2021_20210917

COMPREHENSIVE STORMWATER
MANAGEMENT PLAN
FOR
THE CITY OF GRAHAM
JUNE 2017
CONTACT INFORMATION UPDATED
AUGUST 2021

TABLE OF CONTENTS
Tableof Contents.............................................................................................................ii
Definitions....................................................................................................................... v
1 Storm Sewer System Information............................................................................. 6
1.1 MS4 Conveyance System.................................................................................... 6
1.2 Land Use Composition Estimates: ........................................................................ 6
1.3 Estimate Methodology: ......................................................................................... 6
1.4 TMDL Identification............................................................................................... 6
2 Receiving Streams.................................................................................................... 8
3 Existing Water Quality Programs.............................................................................. 9
3.1 Local Programs: ................................................................................................... 9
3.2 State Programs: .................................................................................................... 9
4 Permitting Information............................................................................................. 10
5 Co -Permitting Information....................................................................................... 12
6 Reliance on other government entity to satisfy one or more permit obligations...... 13
7 Stormwater Management Program......................................................................... 14
7.1 Public Education and Outreach on Storm Water Impacts ................................... 14
7.1.1 BMP Summary Table....................................................................................... 14
7.1.2 Target Audience.............................................................................................. 15
7.1.3 Target Pollutant Sources................................................................................. 15
7.1.4 Outreach Program........................................................................................... 15
7.1.5 Decision Process............................................................................................. 15
7.1.6 Evaluation........................................................................................................ 15
7.2 Public Involvement and Participation.................................................................. 16
7.2.1 BMP Summary Table....................................................................................... 16
7.2.2 Target Audience.............................................................................................. 17
7.2.3 Participation Program...................................................................................... 17

7.2.4 Decision Process............................................................................................. 17
7.2.5 Evaluation........................................................................................................ 17
7.3 Illicit Discharge Detection and Elimination.......................................................... 18
7.3.1 BMP Summary Table....................................................................................... 18
7.3.2 Storm Sewer System Map............................................................................... 19
7.3.3 Regulatory Mechanism.................................................................................... 19
7.3.4 Enforcement: ................................................................................................... 19
7.3.5 Detection and Elimination................................................................................ 19
7.3.6 Non Stormwater Discharges............................................................................ 20
7.3.7 Outreach.......................................................................................................... 20
7.3.8 Decision Process............................................................................................. 20
7.3.9 Evaluation........................................................................................................ 20
7.4 Construction Site Stormwater Runoff Control ..................................................... 20
7.5 Post -Construction Storm Water Management in New Development and
Redevelopment.................................................................................................. 21
7.5.1
BMP Summary Table.......................................................................................
21
7.5.2
Stormwater Management Options...................................................................
22
7.5.3
Non -Structural BMP's......................................................................................
22
7.5.4
Structural BMPs...............................................................................................
22
7.5.5
Regulatory Mechanism....................................................................................
22
7.5.6 Operation and Maintenance............................................................................. 22
7.5.7 Education.........................................................................................................22
7.5.8 Decision Process............................................................................................. 23
7.5.9 Evaluation........................................................................................................ 23
7.6 Pollution Prevention/Good Housekeeping for Municipal Operations .................. 24
7.6.1 BMP Summary Table....................................................................................... 24
7.6.2 Affected Operations......................................................................................... 25
7.6.3 Training............................................................................................................25
7.6.4 Maintenance and Inspections.......................................................................... 25
7.6.5 Vehicular Operations....................................................................................... 26
7.6.6 Waste Disposal................................................................................................ 26
7.6.7 Flood Management Projects............................................................................ 26

7.6.8 Decision Process............................................................................................. 26
7.6.9 Evaluation........................................................................................................ 26
7.7 Total Maximum Daily Loads (TMDL).................................................................. 27
7.7.1 BMP Summary Table....................................................................................... 27
7.7.2 Determination of TMDL's................................................................................. 28
7.7.3 Establishing a Water Quality Recovery Plan .................................................... 28
7.7.4 Decision Process............................................................................................. 28
7.7.5 Evaluation........................................................................................................ 28
IV

DEFINITIONS
BMP — Best Management Practice also known as a Stormwater Control Measure
Category 4b Plan — An EPA approved plan that is an alternative to a TMDL
DEMLR — Division of Energy, Mining, and Land Resources
DEQ — Department of Environmental Quality (formerly DENR)
EPA — Environmental Protection Agency
Illicit Discharge — Any discharge to an MS4 that is not entirely composed of stormwater.
Exceptions include discharges from NPDES-Permitted industrial sources and
discharges from fire -fighting activities
MS4 — Municipal Separate Storm Sewer System. A conveyance or system of
conveyances (including roads with drainage systems, municipal streets, catch basins
curbs, gutters, ditches, manmade channels, or storm drains)
NPDES — National Pollutant Discharge Elimination System
SCM — Stormwater Control Measure
TMDL — Total Maximum Daily Load
v

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
1 STORM SEWER SYSTEM INFORMATION
Population Served: 14,812 (2016 Estimate from the NC Office of Budget & Management)
Annual Growth Rate: 4.7%
Jurisdictional and MS4 Service Areas: Jurisdictional area: 9.39 square miles,
MS4: 9.39 square miles
1.1 MS4 CONVEYANCE SYSTEM
The City of Graham MS4 consists of a combination of storm drain piping, roadside ditches, and sheet flow. New developments are
required by City ordinance to have curb and gutter drainage systems and high density developments are required to treat the first 1"
of runoff from the developed property. City streets are maintained by the City's Street Department, which is housed in the Public
Works Department. State roads are maintained and managed by NCDOT.
1.2 LAND USE COMPOSITION ESTIMATES;
Residential:
50.04%
Commercial:
23.20%
Industrial:
6.52%
Open Space:
20.24%
1.3 ESTIMATE METHODOLOGY.
The land use estimate was based on the zoning within the jurisdictional area as of June 2009. The Piedmont Triad Council of
Government's GIS system provided the zoning data, and includes the right-of-way areas.
1.4 TMDL IDENTIFICATION
Town Branch has a TMDL for fecal coli form. The TMDL lists the following non -point sources in the watershed: urban runoff
(stormwater), sewer line systems (leaky sewer lines and sewer system overflows), wildlife, failing septic systems, and probably illicit
Page 6

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
connections in unknown locations. The TMDL does not include an implementation plan. The City of Graham has begun addressing
sanitary sewer overflows through sewer system infrastructure upgrading.
Page 7

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
2 RECEIVING STREAMS
Table 1. Cape Fear River Basin
Receiving Stream Name
Stream
Segment
Water Quality
Classification
Use
Support
Rating
Water
Quality
Issues
Haw River
16-(10.5)
WS-V; NSW
1, 2, 3
Benthos
Town Branch
16-17
WS-V; NSW
Fecal
Coliform
County Home Branch (Still House Branch)
16-17-1
WS-V; NSW
NR
N/A
Big Alamance Creek
16-19-(4.5)
WS-V; NSW
NR
N/A
Back Creek (Little Creek)
16-19-5
WS-V; NSW
NR
N/A
Little Alamance Creek
16-19-11
WS-V; NSW
1,2
Urban
Stormwater
Bowden Branch (Boyd Creek)
16-19-11-2
WS-V; NSW
NR
N/A
Aquatic life and secondary recreation
2 Fish consumption
3 On 303(d) list
Page 8

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
3 EXISTING WATER QUALITY PROGRAMS
3.1 LOCAL PROGRAMS:
Additionally the City operates a Stage 1 Adaptive Management Program for Existing Development in the Jordan Lake Basin. The
Stage 1 Adaptive Management Program is very similar to the NPDES Phase II Program and is part of a Jordan Lake Watershed
Nutrient Sensitive Waters Strategy.
3.2 STATE PROGRAMS:
NCDEQ implements the NC Erosion and Sediment Control Program within the City of Graham.
Page 9

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
4 PERMITTING INFORMATION.
Table 2. Responsible Contacts
CITY OF GRAHAM
Position
Name
Phone No.
Fax No.
Email
City Manager / Vacant
Fran Lie n4a., e s s
2 70-6799
f.. aR GSS@G'tyefg ra ha
Interim / Asst. City
Manager
Aaron Holland
336/570/6700
336/570-6703
[e-mail]
City Clerk
Darcy Sperry
336/570-6500
336/570-6703
[e-mail]
Stormwater Engineer
Alley, Williams,
Carmen, & King, Inc.
Josh Johnson
336/226-5534
336/226-3034
[e-mail]
City Public Works
Director
Burke Robertson
336/570-6709
336/570-6703
[e-mail]
City Attorneys
Robert (Bob) Ward
J. Bryan Coleman
336/228-1433
336/570-6703
City Planning Director
Justin Snyder
336/570-6700
336/570-6703
[e-mail]
Utilities Director
Tonya Mann
336/578-3264
336/570-6703
[e-mail]
Page 10

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
City Of Graham
Organizational Chart
City Council
City Attorney
City Manager
Fire Chief
Public Works Director
Police Chief
City Clerk
Signing Official: City Manager — Frankie Maness -
Duly Authorized Representative: NA
City Engineer
Tax Collector
Finance Director
Water Billing & Collection Administrator
Planning Director
Interim City Manager - Aaron Holland
Page 11

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
5 CO -PERMITTING INFORMATION
Not applicable
Page 12
CITY OF GRAHAM

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
6 RELIANCE ON OTHER GOVERNMENT ENTITY TO SATISFY ONE OR MORE PERMIT OBLIGATIONS
The City of Graham will rely on the State Erosion and Sediment Control Program and the
Department of Water Quality's general stormwater permit program for construction
activities to meet the construction site stormwater runoff control requirement. There are
no legal agreements in place to establish responsibilities.
The City also contracts with the Piedmont Triad Regional Council's Stormwater Smart
program. The program handles most of the City's educational responsibilities.
Contact Information:
NC Sedimentation and Erosion Control Program
Winston-Salem Regional Office
Tamera Eplin, P.E.
450 West Hanes Mill Road, Suite 300,
Winston Salem, NC 27105-7407
336/776-9800
Piedmont Triad Regional Council
Stormwater Smart
Dancia Heflin
1398 Carrollton Crossing Drive,
Kernersville, NC 27284
[phone] ext. 3008
Page 13

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7 STORMWATER MANAGEMENT PROGRAM
7.1 PUBLIC EDUCATION AND OUTREACH ON STORM WATER IMPACTS
7.1.1 BMP Summary Table
BMP
Measurable Goals
YIR
Y2R
Y3R
Y4R
Y5R
Responsible Position/Party
Maintain an education plan
Maintain education plan. Include in Plan the BMPs, schedule,
X
X
X
X
X
City Planner
targeted audiences, and measurable goals. Summarize plan
Stormwater Engineer
and implementation progress in each annual report.
School Programs
Maintain school children education program. Focus on basic
X
X
X
X
X
City Planner
messages regarding clean water and the things they can do at
Stormwater Engineer
home to help. Track the number of children reached and the
subject covered and report annually.
Mailers, brochures, posters
Distribute bilingual mailer for insert in utility bills. Distribute
X
X
X
X
City Planner
bilingual brochures and posters for distribution at City Hall.
Stormwater Engineer
Target homeowners and businesses with messages about how
they can reduce pollution picked up by stormwater. Track
number of homes and businesses reached by mailer and report
annually.
City's web page
Link to other stormwater websites. Give tips on reducing
X
X
X
X
X
City Planner
pollution. Report annually.
Stormwater Engineer
Festivals, parades, local
Participate in local festivals annually by providing a stormwater
X
X
X
X
X
City Planner
fairs
information booth starting. Provide bilingual messages on the
Stormwater Engineer
importance of clean water and on specific activities that can be
carried out to help keep stormwater clean.
Business and Industry
Maintain program for educating business and industry using
X
X
City Planner
education and outreach
brochures or pamphlets and report annually on number of
Stormwater Engineer
businesses reached and number of employees educated. Focus
on workplace issues to reduce pollutant loading. Target hot spot
businesses.
Helpline / Hotline
All stormwater related calls will be forwarded to the Public Works
X
X
X
X
X
Public Works Director
Dir. who will then distribute the information to other employees.
Page 14

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.1.2 Target Audience
Graham residents, school children, local businesses (including gas station owners
and landscaping companies) and industry, will be targeted because these groups
have the most impact on stormwater pollution prevention.
7.1.3 Target Pollutant Sources
The education program will target total suspended solids and nutrient loading
because turbidity, sedimentation, and nutrients are the pollutants of concern in
downstream waters. In addition, floatables, trash, and debris will also be targeted.
The education program will also address the proper use and disposal of typical
household chemicals, garden chemicals, and used motor oil.
7.1.4 Outreach Program
School programs, printed materials to be distributed via mail and public events,
and participation in state cleanup programs will be used to reach the target
audience. By using these methods, the education program will be expected to
reach all residents of Graham, as well as those that do business here, over the
course of the five year permit period. As a result of this outreach program, the
target audience will be informed of the importance of reducing storm water
pollution and ways they can incorporate pollution reduction in their daily lives.
Direct Education was chosen over mass media due to availability of the
cooperative stormwater education program, Stormwater SMART, and due to
studies showing the effectiveness of direct education over mass media.
7.1.5 Decision Process
The formation of the storm water public education and outreach program was
based on the mechanisms currently in place, and their means and effectiveness
of communicating and educating the public about the issues of stormwater
pollution prevention. Each of the BMP's selected was judged to be an effective and
economical tool for educating the general public and/or specific groups within the
community, with a specific measurable goal with which to gauge its effectiveness.
7.1.6 Evaluation
The education and outreach program will be evaluated based on how each
individual BMP is meeting its measurable goal at the end of each reporting period.
Changes will be considered for any BMPs that are not meeting the measurable
goals.
Page 15

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.2 PUBLIC INVOLVEMENT AND PARTICIPATION
7.2.1 BMP Summary Table
BMP
Measurable Goals
YIR
Y2R
Y3R
Y4R
Y5R
Responsible Position/Panty
Public Meeting
A public meeting will be held annually to discuss the
X
X
X
X
X
City Planner
implementation of the permit. This meeting will provide
City Clerk
the public with the opportunity to be involved with the
stormwater program and will serve as a better conduit
Stormwater Engineer
for public input than the stormwater committee used
previously. More meetings may be held if public
Asst City Manager
involvement is substantial.
Volunteer Stormwater Program
The City will promote various volunteer stormwater
X
X
X
X
X
City Planner
programs annually. These will include Big Sweep,
Stormwater Engineer
Adopt -A -Stream programs, and Storm Drain Stenciling.
The number of participants will be reported annually.
Helpline / Hotline
All stormwater related calls will be forwarded to the
X
X
X
X
X
Public Works Director
Public Works Director who will then distribute the
information to other employees.
Page 16

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.2.2 Target Audience
The City's stormwater committee will be discarded in favor of an annual public
meeting. The public meetings will allow the public an opportunity to review the
stormwater management program and will target all interested and affected
members of the Graham community. Additional meetings may be held if public
involvement is substantial.
The City's committee was ineffective in soliciting widespread public input.
7.2.3 Participation Program
The public was originally involved in the development of the stormwater permit and
management program through a public hearing in 2005. Public participation
opportunities will be implemented throughout the life of the permit through the
Volunteer Stormwater Programs and the Annual Public Meeting.
7.2.4 Decision Process
A public meeting is necessary for public participation and input. The other BMPs
were selected to give the public a choice of both active and passive participation
roles.
7.2.5 Evaluation
The Public Involvement and Participation program will be evaluated based on how
each individual BMP is meeting its measurable goal at the end of each reporting
period. Changes will be considered for any BMPs that are not meeting the
measurable goals.
Page 17

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION
7.3.1 BMP Summary Table
BMP
Measurable Goals
YIR
Y2R
Y3R
Y4R
Y5R
Responsible Position/Party
Review Illicit Discharge Ordinance
Review Illicit Discharge Ordinance and make any
X
X
X
X
X
City Attorney
necessary revisions.
Stormwater Engineer
City Planner
Review Illicit Discharge Program
Review Illicit Discharge Program and make any
X
X
X
X
X
Public Works Director
necessary revisions.
Stormwater Engineer
City Planner
Maintain storm sewer system map
Maintain system map in support of inspection program.
X
X
X
X
X
Stormwater Engineer
showing outfalls and the receiving
The map will note outfalls and receiving body of water
City Planner
body of water.
for each outfall. Report annually on progress.
Public Works Director
Maintain an inspection and
Investigate and track any sources of Illicit discharges.
X
X
X
X
X
Public Works Director
elimination program within the
document date, discharge observed, results and the
Stormwater Engineer
community.
date problem was corrected.
Coordinate with local health
Provide a fact sheet on septic system management,
X
X
Public Works Director
department on failing septic systems,
Record date of distribution and number of copies
Stormwater Engineer
locating problem areas in the system
placed.
map. Provide public information on
City Planner
septic system management.
Train employees on how to inspect
Provide materials through HR to all public employees
X
X
X
X
X
Public Works Director
for illicit connections and establish a
in illicit connections and how to recognize one.
Stormwater Engineer
tracking system for managing
Summarize in annual report.
reported problem areas.
City Planner
Dry Weather Flow Detection
Dry Weather testing will be done at least bi-annually in
X
X
X
X
X
Stormwater Engineer
accordance with the IDDE program, dependent upon
Public Works Director
other IDDE investigations.
Page 18

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.3.2 Storm Sewer System Map
Storm sewer system has been mapped and will be inspected during the course of
normal maintenance operations by the public service department. The route of the
system, locations of pipes, drainage ditches, and outfalls will be maintained on a
paper map and/or electronic map. The map will be updated as needed during
subsequent maintenance operations.
7.3.3 Regulatory Mechanism
The City has an Illicit Discharge Ordinance which allows for inspection,
maintenance, and prohibits illicit discharges.
7.3.4 Enforcement:
There are provisions in the amended ordinance for enforcement actions and
penalties for dumping, spills, and willful illicit connection.
7.3.5 Detection and Elimination
After the field screening is complete, the City will take measures to identify and
remove illegal discharges. Identifying illegal discharges may require a combination
of office and field work. After the field screening, staff will consult the jurisdiction -
wide information they have compiled to obtain information about the land uses,
infrastructure, industries, potential sources and types of pollution that may exist in
the drainage area of the outfall.
After priority areas have been identified in the office, a systematic field
investigation will be planned that minimizes the amount of resources required to
identify the source. The following field methods may be used to identify and trace
the source of illegal discharges:
• Site Investigation
• Dry weather flow observations
• Smoke Testing/Dye Testing
• Television Inspection
The right of entry established in the ordinance will provide access for inspection if
the origin of the discharge is in doubt. Once an illegal discharge is located and
confirmed through field screening, staff will notify the responsible party verbally if
possible and follow-up with written notification. If the responsible party does not
comply with the removal schedule provided by the City, or receive approval for a
revised schedule, the City will take enforcement action and the connection will be
removed at the responsible party's expense.
Page 19

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.3.6 Non Stormwater Discharges
Currently there are no known non-stormwater discharges that are a significant
contributor to the MS4. If any are identified in the future, they will be addressed at
that time.
7.3.7 Outreach
City employees will be informed of the hazards associated with illegal discharges
and improper disposal of waste as part of their general training requirements.
These will be addressed in the Pollution Prevention/Good Housekeeping section
of this plan, and will include training in hazardous material handling and disposal,
as well as notices and signs posted in the appropriate areas.
The general public will be educated through the BMP's listed in the Public
Education section of this plan. These educational BMP's will include brochures,
public service announcements, and business education and outreach programs.
7.3.8 Decision Process
The formation of the storm water Illicit Discharge Detection and Elimination
program was based primarily on regulatory mechanisms. The regulatory,
educational, procedural BMP's selected were judged to be an effective means of
detecting and eliminating illicit discharges.
7.3.9 Evaluation
The effectiveness of the program will be gauged by the total number of illicit
connections detected and removed each year and with public complaints. If the
total number remains constant, or increases, changes will be made to the public
education program and/or the City ordinance to allow for greater enforcement and
penalties.
7.4 CONSTRUCTION SITE STORMWATER RUNOFF CONTROL
The City of Graham will rely on the North Carolina State Erosion and Sediment Control
Program and the Department of Water Quality's general stormwater permit program for
construction activities to meet the construction site stormwater runoff control
requirement.
Page 20

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.5 POST -CONSTRUCTION STORM WATER MANAGEMENT IN NEW DEVELOPMENT AND REDEVELOPMENT
7.5.1 BMP Summary Table
BMP
Measurable Goals
YIR
Y2R
Y3R
Y4R
Y5R
Responsible Position/Party
Review the Post Construction Ordinance
Review the Post Construction Ordinance for
X
City Planner
compliance with NC DWQ guidance and local
City Attorney
effectiveness. Phase II Post -Construction
Ordinance will incorporate Jordan Lake Nutrient
Stormwater Engineer
Strategy Regulations in conjunction with NC
Session Law and DWQ regulations.
Review standards and policies that ensure
Review local standards to remain in compliance
X
X
X
X
X
Stormwater Engineer
structural BMPs will be in conformance with
with the NC DEQ BMP Manual. Additional
City Planner
the state's Stormwater Management
measures and techniques may be added to the
Design Manual
local ordinance as they are investigated.
Review maintenance standards and
Review the maintenance standards and
X
X
Stormwater Engineer
inspection program to ensure that on -site
inspection program for local on -site controls.
City Planner
controls continue to function as designed.
Maintain the education program created for
Maintain the education program created for land
X
X
Stormwater Engineer
land developers and the public.
developers and the public detailed in other
City Public Works Director
BMP's. Report annually on progress made.
City Planner
Coordinate with the county health
Coordinate with county health department. Report
X
X
X
X
Stormwater Engineer
department on developing and
Annually on progress made.
City Planner
implementing an oversight program to
minimize the potential for fecal coliform
City Public Works Director
contamination by ensuring proper operation
and maintenance of on -site wastewater
treatment systems.
Green Infrastructure Practices and
Green Infrastructure Practices and Strategies will
X
Stormwater Engineer
Strategies will be encouraged.
be encouraged and existing standards may be
City Planner
eased to encourage green projects.
Inspections and long-term maintenance of
Maintain an inspection and maintenance plan for
X
X
X
X
X
City Engineer
Stormwater Control Measures (SCMs)
SCM's. Annual SCM Inspections performed by a
City Planner
qualified professional. SCM maintenance and
inspections will be reviewed by the town during
the permit cycle.
Page 21

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.5.2 Stormwater Management Options
The existing land usage ordinance has a post -construction stormwater runoff
management program for new development and redevelopment projects that
disturb greater than, or equal to, one acre. This ordinance may be revised prior to
the end of year 3 of the permit to incorporate Low Impact Development (LID)
provisions and Nutrient Reduction limits as defined in the Jordan Lake Nutrient
Reduction Strategy will be adopted within the timeline established by NC Session
Laws and NC DWQ Regulations.
7.5.3 Non -Structural BMP's
The receiving streams in the City's watershed are classified as Nutrient Sensitive
Waters; therefore the post construction ordinance ensures that best management
practices for reducing nutrient loading are implemented. In addition, a nutrient
application (both inorganic fertilizer and organic nutrients) management program
has been developed and is included in the stormwater management program.
7.5.4 Structural BMPs
The City has certified its BMP manual as equal to the NC DWQ BMP Manual. The
City reviews structural BMP's based on the NC DWQ BMP Manual and will
continue to do so in the future. The City may investigate additional qualified BMP's
in the future. These additional techniques are to be evaluated based upon field
testing and evaluation by the City's Engineer.
7.5.5 Regulatory Mechanism
The City's Post -Construction Ordinance establishes the City's ability to regulate
new development for water quality compliance.
7.5.6 Operation and Maintenance
The City's Post -Construction Ordinance establishes the City's ability to regulate
new development for water quality compliance. The ordinance includes guidelines
for delegating routine and non -routine maintenance responsibilities to ensure
access for inspections, and providing a mechanism for enforcement.
The City will require annual submissions of BMP inspection reports and the City
will inspect each BMP during each permit cycle.
7.5.7 Education
An education process for developers and citizens about new development with
respect to stormwater and water quality has been established and is ongoing.
Page 22

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.5.8 Decision Process
The post -construction stormwater management program ensures that controls are
in place that will prevent or minimize water quality impacts from new development
and redevelopment projects. These controls include post -construction ordinance
to address post -construction runoff control from new development and
redevelopment projects and ensure adequate long-term operation and
maintenance of BMPs. Future revisions to this ordinance will be intended to
enhance water quality.
7.5.9 Evaluation
The post -construction site management for new and re -development activities
program will be evaluated based on how each individual BMP is meeting its
measurable goal at the end of each reporting period. Changes will be considered
for any BMPs that are not meeting the measurable goals.
Page 23

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.6 POLLUTION PREVENTION/GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS
7.6.1 BMP Summary Table
BMP
Measurable Goals
YIR
Y2R
Y3R
Y4R
Y5R
Responsible Position/Party
Maintain Inventory and O&M Manual
Maintain, update, inspect annually all Municipal
X
X
X
X
X
Public Works Director
of Municipal Facilities and Operations
Facilities and update as needed Operation and
Stormwater Engineer
Maintenance Manual for every facility and operation.
Spill Response Procedures
Maintain or create Spill Response Procedures
X
X
X
X
X
Public Works Director
Streets, Roads, and Public Parking
Maintain Implementation of BMP's. Evaluate Annually
X
X
X
X
X
Stormwater Engineer
Lots Maintenance Program
for cost and effectiveness.
Public Works Director
O&M for municipally owned or
Continue implementation of O&M Program for the
X
X
X
X
X
Stormwater Engineer
maintained catch basins and
MS4, including catch basins and conveyance systems.
Public Works Director
conveyance systems
Reassess program annually.
O&M for municipally -owned or
Continue to implement/and maintain the O&M Program
X
X
X
X
X
Stormwater Engineer
maintained structural stormwater
for municipally -owned or maintained structural
Public Works Director
controls
stormwater controls. Document inspections and
maintenance
Pesticide, Herbicide and Fertilizer
Ensure municipal employees and contractors are
X
X
X
X
X
Public Works Director
Application Management
properly trained and all permits, certifications, and
other measures for applicators are followed.
Staff Training
Maintain an employee training program for employees
X
X
X
X
X
Stormwater Engineer
involved in pollution prevention and good
Public Works Director
housekeeping practices.
Vehicle Washing
Maintain measures to minimize or prevent
X
X
X
X
X
Stormwater Engineer
contamination of stormwater runoff from all areas used
Public Works Director
for vehicle and equipment cleaning.
Page 24

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.6.2 Affected Operations
The City of Graham operates a municipal building that serves as a City hall and fire station, a police station, a Public Works
vehicle and equipment storage yard, and a maintenance facility for the Parks & Recreation Department. All vehicles,
equipment, and materials at the storage yard and Park maintenance facility are stored in covered buildings. There are no
floor drains in any of the buildings at these two facilities.
7.6.3 Training
Training materials have been developed on pollution prevention for public facilities, using similar materials as will be used
in the public outreach program. All employees will be educated on the need for controls to protect stormwater from exposure
to potential pollutants. This training will also serve as the training requirement for public employees as specified in the
outreach component of the Illicit Discharge section of this program.
All public employees involved in vehicle, open space, or building maintenance operations will be provided training in BMPs,
the processes and materials they are working with, safety hazards, practices for preventing discharges, and procedures
for responding quickly and properly to toxic and hazardous material incidents.
All public employees involved in stormwater drainage system maintenance will be specifically trained in the disposal of
floatables, grit, sediment, and other pollutants removed from the system. Additional training, or certification, will be provided
to employees that manage and apply chemicals for control of dust, pests, vermin, and weeds and/or to enhance the growth
or condition of public urban landscape and recreation facilities. Training will target the safe and effective application, storage
and disposal of chemicals used.
7.6.4 Maintenance and Inspections
A preventive maintenance program has been developed that includes routine inspections of catch basins and other
stormwater systems for the municipal building and vehicle storage yard. The objective of the inspections is to reduce
pollutant loading from municipal sites. Inspections include noting any problems or issues that may have an impact on
stormwater quality, and any corrective actions needed. Schedules, procedures, and a record -keeping system are used to
schedule and document inspections.
Page 25

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.6.5 Vehicular Operations
All vehicles, equipment, and associated material at both the Public Works and Parks & Rec. facilities are stored inside
buildings. The Public Works vehicles (pickup and dump trucks) are currently washed outside, with the untreated wash
water discharging into a nearby drainage ditch. Washing of these vehicles at another location has been investigated but
is non -cost effective and pollution runoff is minimized by runoff not going across impervious areas and not going directly
into surface waters. Minor vehicle and equipment maintenance take place at these facilities.
7.6.6 Waste Disposal
Garbage, recyclables, and heavy trash collection are contracted out to private companies.
7.6.7 Flood Management Projects
Future flood management projects will be reviewed from a water quality standpoint.
7.6.8 Decision Process
The most effective and practical BMPs for minimizing stormwater pollution were selected for this program.
7.6.9 Evaluation
The pollution prevention/good housekeeping for municipal operations program will be evaluated based on how each
individual BMP is meeting its measurable goal at the end of each reporting period. Changes will be considered for any
BMPs that are not meeting the measurable goals.
Page 26

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.7 TOTAL MAXIMUM DAILY LOADS (TMDL)
.1 BMP Summary Table
BMP
Measurable Goals
YIR
Y2R
Y3R
Y4R
Y5R
Responsible Position/Party
Establish if a TMDL exists on a
Verify TMDL's annually.
X
X
X
X
X
Stormwater Engineer
receiving water of the MS4
Identify, Describe, and Map
Identify watershed WLA for stormwater, describe
X
Stormwater Engineer
watershed, outfalls, and streams.
watershed, map watershed, identify location of major
outfalls in watershed, identify impaired streams in
watershed, and identify schedule to discover and
locate other possible contributing sources.
Existing Measures
Create Water Quality Recovery Program.
X
Stormwater Engineer
Monitoring Plan
Create and submit to NC DWQ a monitoring program
X
Stormwater Engineer
for each pollutant of concern in the TMDL.
Additional Measures
Additional measures that improve water quality may be
X
X
X
Stormwater Engineer
started as needed.
Implementation Plan
Determine final implementation schedule, including
X
Stormwater Engineer
when in the permit additional items will be
implemented.
Incremental Success
Determine if and/or how incremental success will be
X
Stormwater Engineer
measured.
Annual Assessment
Submit Annual Report on program to DWQ
X
X
X
X
X
Stormwater Engineer
Page 27

COMPREHENSIVE STORMWATER MANAGEMENT PROGRAM REPORT
CITY OF GRAHAM
7.7.2 Determination of TMDL's
A TMDL on a receiving water with a stormwater Waste Load Allocation (WLA)
will trigger the need for compliance with this section of the CSWMP. A TMDL with
no WLA will not require a Water Quality Recovery Plan, but rather the need to
evaluate existing strategies and if any can be tailored or expanded to improve the
water quality in the TMDL watershed.
7.7.3 Establishing a Water Quality Recovery Plan
Based on the above schedule the City of Graham would begin creating a Water
Quality Recovery Plan (WARP) within 12 months of establishment of the TMDL,
would have evaluated existing measures within 24 months, developed a
monitoring plan within 36 months, and would be implementing or have planned for
implementation within 48 months. The WQRP would be submitted and approved
by NC DWQ and EPA.
7.7.4 Decision Process
TMDL planning and implementation will be done in an effort to improve water
quality and with the approval of NC DWQ staff.
7.7.5 Evaluation
Progress toward restoring water quality standards will be difficult to determine and
most evaluation tools will be based upon programs rather than through water
quality monitoring or water quality improvements. While the goal of a WQRP is to
improve water quality standards, the NPDES MS4 permit obligation is to reduce
non -point source pollutant loading to the maximum extent practicable (MEP). The
MS4 is not required to meet water quality standards. Evaluation of successful
techniques will be evaluated over time, probably multiple permit cycles.
Page 28