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HomeMy WebLinkAboutNCS000421_High Point APPROVED SWMP_20211220NCS000421 SWMP City of High Point November 15th, 2021 Stormwater Management Plan City of High Point NCS000421 November 15th, 2021 NCS000421 SWMP City of High Point November 15th, 2021 Page ii Table of Contents PART 1: INTRODUCTION ........................................................................................................................ 1 PART 2: CERTIFICATION ........................................................................................................................ 2 PART 3: MS4 INFORMATION .................................................................................................................. 3 3.1 Permitted MS4 Area ..................................................................................................................... 3 3.2 Existing MS4 Mapping ................................................................................................................. 4 3.3 Receiving Waters .......................................................................................................................... 4 3.4 MS4 Interconnection ..................................................................................................................... 5 3.5 Total Maximum Daily Loads (TMDLs) ....................................................................................... 5 3.6 Endangered and Threatened Species and Critical Habitat ............................................................ 6 3.7 Industrial Facility Discharges ....................................................................................................... 6 3.8 Non-Stormwater Discharges ......................................................................................................... 8 3.9 Target Pollutants and Sources ....................................................................................................... 9 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION ................................... 10 4.1 Organizational Structure ............................................................................................................. 10 4.2 Program Funding and Budget ..................................................................................................... 11 4.3 Shared Responsibility ................................................................................................................. 12 4.4 Co-Permittees .............................................................................................................................. 12 4.5 Measurable Goals for Program Administration .......................................................................... 12 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM ......................................................... 14 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM ........................................... 19 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM .............................. 21 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ................................................... 25 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM ........................................ 27 PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS ...................... 32 NCS000421 SWMP City of High Point November 15th, 2021 Page iii 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 NCS000421 SWMP City of High Point November 15th, 2021 Page 1 PART 1: INTRODUCTION The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by which the City of High Point will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. This SWMP identifies the specific elements and minimum measures that the City of High Point will develop, implement, enforce, evaluate, and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) in order to comply with the MS4 Permit number NCS000421, as issued by NCDEQ. This permit covers activities associated with the discharge of stormwater from the MS4 as owned and operated by the City of High Point and located within the corporate limits of the City of High Point. In preparing this SWMP, the City of High Point has evaluated its MS4 and the permit requirements to develop a comprehensive 5-year SWMP that will meet the community’s needs, address local water quality issues, and provide the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated annually to ensure that the elements and minimum measures it contains continue to adequately provide for permit compliance and the community’s needs. Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along with any approved modifications of the SWMP, are incorporated by reference into the permit and become enforceable parts of the permit. Any major changes to the approved SWMP will require resubmittal, review, and approval by NCDEQ, and may require a new public comment period depending on the nature of the changes. NCS000421 SWMP City of High Point November 15th, 2021 Page 2 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 enforceab le 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: Tasha Logan Ford Title: City Manager Signed this day of November, 2021. NCS000421 SWMP City of High Point November 15th, 2021 Page 3 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits of the City of High Point, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits of City of High Point as of the date of this document. As of January 2020, the jurisdictional and MS4 service area for the City of High Point is 57.8 square miles. The source of this information is the City of High Point, Public Services Department and Planning & Development Department, which updates jurisdictional and geographical boundaries as changes occur. NCS000421 SWMP City of High Point November 15th, 2021 Page 4 3.2 Existing MS4 Mapping The current MS4 mapping includes pipes, flow direction, ditches, inlets, catch basins, manholes, outfalls, sizes, condition, etc., and is contained in our GIS mapping program and in a secure layer of ThePoint, an interactive map which allows searches for property information as well as many other types of information related to areas of High Point. The City of High Point does not provide access to stormwater structural layers to the general public, however. Go to https://gisweb10.highpointnc.gov/JS/ThePoint/ to access the Interactive GIS Data Viewer. Table 1: Summary of Current MS4 Mapping Percent of MS4 Area Mapped 99% No. of Major Outfalls* Mapped 1,203 as of 7-14-2021 *An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g., a ditch) directly into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major outfall is a 36-inch diameter pipe or discharge from a drainage area > 50-acres; and for industrial zoned areas a 12-inch diameter pipe or a drainage area > 2-acres. 3.3 Receiving Waters The City of High Point MS4 is located within the Cape Fear and Yadkin River Basins and discharges directly into receiving waters as listed in Table 2 below. Applicable water quality standards listed below are compiled from the following NCDEQ sources: o Waterbody Classification Map o Impaired Waters and TMDL Map o Most recent NCDEQ Final 303(d) List Table 2: Summary of MS4 Receiving Waters Receiving Water Name Stream Index / AU Number Water Quality Classification 303(d) Listed Parameter(s) of Interest Cape Fear River Basin Boulding Branch 17-3-2 WS-IV:* Deep River (including High Point Lake at normal pool elevation) 17-(1) WS-IV;CA:* 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 Hiatt Branch 17-3-1-(1) WS-IV:* High Point City Lake 17-(1) WS-IV;CA:* Long Branch 17-2-1-(1) WS-IV Eco/Biological Integrity Fish Com Eco/Biological Integrity Benthos NCS000421 SWMP City of High Point November 15th, 2021 Page 5 Long Branch 17-2-1-(2) WS-IV;CA:* Eco/Biological Integrity Fish Com Eco/Biological Integrity Benthos Mile Branch (Two Mile Branch / Jackson Lake) 17-7-3 WS-IV:* Oak Hollow Lake 17-3-(0.7) WS-IV;CA:* West Fork of Deep River 17-3-(0.3) WS-IV:* Eco/Biological Integrity Fish Com West Fork of Deep River 17-3-(0.7) WS-IV;CA:* Eco/Biological Integrity Fish Com Richland Creek 17-7-(0.5) WS-IV:* Fecal Coliform Richland Creek 17-7-(4) WS-IV;CA:* Fecal Coliform Unnamed tributaries within the Cape Fear River Basin Yadkin River Basin Rich Fork Creek 12-119-7 C Fecal Coliform Payne Creek 12-119-7 C Kennedy Mill Creek 12-119-7 C Unnamed tributaries within the Yadkin River Basin 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. The MS4 does not interconnect with the statewide NCDOT MS4 and includes: a. The interconnection is not receiving stormwater from the NCDOT MS4. The number of interconnections is known/estimated/unknown. (N/A) b. The interconnection is not discharging stormwater into the NCDOT MS4. The number of interconnections is known/estimated/unknown. (N/A) c. The City of High Point MS4 mapping does not identify interconnections with the NCDOT MS4. d. The City of High Point MS4 mapping does not include NCDOT MS4 outfalls. 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. NCS000421 SWMP City of High Point November 15th, 2021 Page 6 Table 3: Summary of Approved TMDLs Water Body Name TMDL Pollutant(s) of Concern Stormwater Waste Load Allocation (Y/N) Water Quality Recovery Program (Y/N) E. Fork Deep River Fecal Coliform Y Y1 Richland Creek Fecal Coliform Y Y2 Rich Fork Creek Fecal Coliform Y Y1 Y1 : Outfall monitoring program only Y2 : TMDL water quality monitoring plan (2015) 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or critical habitat are identified within the regulated MS4 urbanized area. Based upon a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service, the species listed in Table 4 have the potential to occur within the regulated MS4 urbanized 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: Potential Federally Listed Species/Habitat Impacted by Surface Water Quality Scientific Name Common name Species Group Federal Listing Status Fusconaia masoni Atlantic pigtoe Clams Proposed Threatened Notropis mekistocholas Cape Fear Shiner Fish Endangered Percina rex Roanoke logperch Fish Endangered Isotria medeoloides Small whorled pogonia Flowering Plants Threatened Helianthus schweinitzii Schweinitz's sunflower Flowering Plants Endangered Perimyotis subflavus Tricolored bat Mammals Under Review Clemmys muhlenbergii Bog Turtle Reptiles Threatened Fusconaia masoni Atlantic pigtoe Clams Proposed Threatened 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 Maps & Permit Data web page. 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) NCG030517 Mickey Truck Body Inc - High Point NCS000421 SWMP City of High Point November 15th, 2021 Page 7 NCG050370 Innocor Foam Technologies - ACP, Inc. NCG060003 Kao Specialties Americas LLC NCG060041 Piedmont Chemical Ind I LLC NCG060205 Custom Finishers Incorporated NCG060244 Hunter Farms Dairy NCG060359 Innospec Performance Chemicals NCG060381 Cambrex High Point, Inc. NCG070029 Glass Unlimited-High Point Inc NCG080683 High Point City-Fleet Maintenance Facility NCG080702 High Point City Transit NCG090020 Axalta Coating Systems U.S.A., LLC (High Point) NCG090021 Akzo Nobel Coatings Incorporated NCG120105 Kersey Valley MSW Landfill NCG140003 Childers Concrete NCG140215 ARGOS USA - High Point Concrete Facility (previously Ready Mixed Concrete Plant 75) NCG160041 Larco Construction Co - High Point NCG170388 Chambers Fabrics Incorporated NCG180036 Haworth Inc-Wood Seating Plant NCG180220 High Point Furniture Industries NCG180254 Marsh Furniture Co NCG240007 City of High Point Ingleside Compost Facility NCGNE0048 Premiere Cushion-Hickory Springs Mfg. Co. NCGNE0104 Leggett & Platt Inc-Guilford NCGNE0118 Patheon Softgels Inc. NCGNE0134 Environmental Air Systems Inc NCGNE0150 Patrician Furniture Co NCGNE0166 Poly Pride, Inc. NCGNE0241 Ultra -Flex NCGNE0264 Carpenter Co - High Point NCGNE0281 Henredon Furniture-Guilford 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 NCS000421 SWMP City of High Point November 15th, 2021 Page 8 NCGNE0970 Baker Interiors Furniture Company - High Point NCGNE0991 Syntec Seating Solutions LLC NCGNE1022 High Point Furniture Industries NCGNE1131 Fastenal Company NCGNE1144 V&E Components, Inc. NCGNE1208 Thomas Clyde Lamar ARC NC028 NCGNE1227 Fortis Solutions Group NCGNE1255 Ornamental Products LLC NCGNE1323 Waste Industries LLC NCGNE1384 Freud America - High Point - 218 Feld NCGNE1385 Freud America - High Point - 220 Feld NCS000421 High Point city - Small MS4 NCS000582 Ennis Flint 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 Part 5 of this SWMP. Table 6: Non-Stormwater Discharges Non-Stormwater Discharge Water Quality Impacts Water line and fire hydrant flushing Incidental Landscape irrigation Incidental Diverted stream flows Incidental Rising groundwater Incidental Uncontaminated groundwater infiltration Incidental Uncontaminated pumped groundwater Incidental Uncontaminated potable water sources Incidental Foundation drains Incidental Air conditioning condensate Incidental Irrigation waters Incidental Springs Incidental Water from crawl space pumps Incidental Footing drains Incidental NCS000421 SWMP City of High Point November 15th, 2021 Page 9 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 3.9 Target Pollutants and Sources In addition to those target pollutants identified above, the City of High Point is aware of other significant water quality issues within the permitted MS4 area. Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP, the likely activities/sources/targeted audiences attributed to each pollutant and identifies the associated SWMP program(s) that address each. In addition, the City of High Point has evaluated schools, homeowners and businesses as target audiences that are likely to have significant stormwater impacts. Table 7: Summary of Target Pollutants and Sources Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing Target Pollutant(s)/Audience(s) Litter General Public, Businesses, Schools Public Education & Outreach, Public Participation Pet Waste/Fecal Coliform General Public, Parks, Greenways, Sewer Overflows, Failing Septic Systems Public Education & Outreach, Illicit Discharge Detection & Elimination Sediment Construction Erosion, Stream Bank Erosion Construction Site Runoff Control Illicit Discharges General Public, Businesses, Municipal Employees Public Education & Outreach, Illicit Discharge Detection & Elimination, Public Involvement Illegal Dumping General Public, Businesses, Municipal Employees Public Education & Outreach, Illicit Discharge Detection & Elimination, Pollution Prevention & Good Housekeeping NCS000421 SWMP City of High Point November 15th, 2021 Page 10 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure The Stormwater Division is responsible for compliance of the City of High Point’s NPDES Permit. All related activities/requirements/etc. for compliance are the responsibility of the Stormwater Division, with the exception of Engineering Services, which oversees the Construction Runoff portion of the Permit. See Appendix A for Organizational Chart. Table 8: Summary of Responsible Parties SWMP Component Responsible Position Staff Name Department Stormwater Program Administration Dep. Public Services Director Robby Stone Public Services Administration SWMP Management Public Services Manager Operations Analyst Justin Gray Vacant Public Services Stormwater Division Public Education & Outreach Stormwater Specialists Robbie Baker Kelsie Burgess Abigail Rosendale Public Services Stormwater Division Public Involvement & Participation Stormwater Specialists Robbie Baker Kelsie Burgess Abigail Rosendale Public Services Stormwater Division Illicit Discharge Detection & Elimination Stormwater Specialists Robbie Baker Kelsie Burgess Abigail Rosendale Public Services Stormwater Division Construction Site Runoff Control Engineering Services Director Civil Engineer II Erosion Control Inspectors Trevor Spencer Aspasia Vlachou Scott Ford Kathy Blake Engineering Services Division Post-Construction Stormwater Management Operations Analyst Vacant Public Services Stormwater Division Pollution Prevention / Good Housekeeping for Municipal Operations Stormwater Specialists Robbie Baker Kelsie Burgess Abigail Rosendale Public Services Stormwater Division NCS000421 SWMP City of High Point November 15th, 2021 Page 11 Municipal Facilities Operation & Maintenance Program Stormwater Specialists Robbie Baker Kelsie Burgess Abigail Rosendale Public Services Stormwater Division Spill Response Program All Stormwater Division Staff All Stormwater Division Staff Public Services Stormwater Division MS4 Operation & Maintenance Program Public Services Manager Street Maint. Superintendent Justin Gray Ken Sult Public Services Stormwater Division Municipal SCM Operation & Maintenance Program Public Services Manager Justin Gray Public Services Stormwater Division Pesticide, Herbicide & Fertilizer Management Program Safety Officer Jim Gwynn Public Services Administration Vehicle & Equipment Cleaning Program Public Services Manager Justin Gray Public Services Stormwater Division Pavement Management Program Public Services Manager Street Maint. Superintendent Justin Gray Ken Sult Public Services Stormwater Division (Streets Department) Total Maximum Daily Load (TMDL) Requirements Operations Analyst Stormwater Specialists Vacant Robbie Baker Kelsie Burgess Abigail Rosendale Public Services Stormwater Division 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. NCS000421 SWMP City of High Point November 15th, 2021 Page 12 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 4.4 Co-Permittees The are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000421 for the City of High Point. Table 10: Co-Permittee Contact Information Co-Permittee MS4 Name Contact Person Phone & E-Mail Interlocal Agreement (Y/N) N/A 4.5 Measurable Goals for Program Administration The City of High Point will manage and report the following Best Management Practices (BMPs) for the administration of the Stormwater Management Program. Table 11: Program Administration BMPs Permit Ref. 2.1.2 and Part 4: Annual Self-Assessment Measures to evaluate the performance and effectiveness of the SWMP program components at least annually. Results shall be used by the permittee to modify the program components as necessary to accomplish the intent of the Stormwater Program. The self-assessment reporting period is the fiscal year (July 1 – June 30). SWMP BMP or Permit Requirement Implementing Entity & Program Name Legal Agreement (Y/N) N/A NCS000421 SWMP City of High Point November 15th, 2021 Page 13 BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 1. Annual Self-Assessment Perform an annual evaluation of SWMP implementation, suitability of SWMP commitments and any proposed changes to the SWMP utilizing the NCDEQ Annual Self- Assessment Template. 1. Prepare, certify, and submit the Annual Self- Assessment to NCDEQ prior to August 31 each year. 1. Annually Permit Years 1 – 4 FY21/22 FY22/23 FY23/24 FY24/25 1. Yes/No Permit Ref. 1.6: Permit Renewal Application Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the NPDES MS4 permit. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 2. Permit Renewal Application Audit stormwater program implementation for compliance with the permit and approved SWMP and utilize the results to prepare and submit a permit renewal application package. 1. Participate in an NPDES MS4 Permit Compliance Audit, as scheduled and performed by EPA or NCDEQ. 1. TBD – Typically Permit Year 4 FY24/25 1. Yes/No 2. Self-audit and document any stormwater program components not audited by EPA or NCDEQ utilizing the DEQ Audit Template. Submit Self- Audit to DEMLR (required component of permit renewal application package). 2. Permit Year 5 FY25/26 2. Yes/No/Partial 3. Certify the stormwater permit renewal application (Permit renewal application form, Self-Audit, and Draft SWMP for the next 5-year permit cycle) and submit to NCDEQ at least 180 days prior to permit expiration. 3. Permit Year 5 FY25/26 3. Date of permit renewal application submittal NCS000421 SWMP City of High Point November 15th, 2021 Page 14 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The City of High Point will 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(s) Litter/Household Waste General Public Pet Waste/Fecal Colifor m General Public, Public/Private Sanitary Sewer Infrastructure Sediment Developers, Contractors, Homeowners, Landscapers Fats, Oils & Grease General Public, Commercial, Industrial, Food Industries Nutrients (Phosphorus/Nitrogen) General Public, Commerci al, Landscaping Illicit Discharges General Public, Businesses, Municipal Employees Illegal Dumping General Public, Businesses, Municipal Employees Improper Disposal of Waste General Public, Businesses, Municipal Employees The City of High Point will manage, implement, and report the following public education and outreach BMPs. Table 13: Public Education and Outreach BMPs Permit Ref. 3.2.2 and 3.2.4: Outreach to Targeted Audiences Measures to identify the specific elements and implementation of a Public Education and Outreach Program to share educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The permittee shall provide educational information to identified target audiences on 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. NCS000421 SWMP City of High Point November 15th, 2021 Page 15 BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 3. School Outreach Develop age-specific educational information for use in schools and for presentations to school age children. Will present information in appropriate format. 1. Provide age-specific stormwater presentations upon request. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of students reached 2. Reach out to Guilford County Schools and Private schools to remind them of the programs offered. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status 3. Organize stream habitat events for schools and/or summer camps as requested 3. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Number of participants 4. Public Event Tabling Set up public education table at a variety of public events and locations in order to reach diverse groups, minorities ,and underserved populations. Educational topics will vary and may include general stormwater awareness and the pollutants/sources listed in Table 12 above for the general public target audience (litter, pet waste, septic tank systems, FOG, nutrients, illicit discharges, illegal dumping). 1. Monthly Library Table 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of interactions at the table 2. Monthly Farmer’s Market Table 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of interactions at the table 3. Attend at least 3 other City of High Point Public events. 3. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Number of events held and number of interactions NCS000421 SWMP City of High Point November 15th, 2021 Page 16 4. Coordinate and attend the annual Public Services Day event. 4. Annually Permit years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 4. Number of attendees 5. Coordinate and attend one event in High Point for Guilford Creek Week. 5. Annually Permit years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 5. Number of attendees 5. Utility Bill Inserts Stormwater bill inserts will continue to be inserted into combined utility bill statements and distributed to all City residents and businesses receiving a utility bill on at least a semi- annual schedule. 1. Develop and distribute a stormwater flyer for general stormwater information/pet waste/ septic tank systems. 1. Semi-Annually Permit Year 1 FY21/22 1. Number of flyers mailed 2. Develop and distribute a stormwater flyer for illicit discharges/illegal dumping and general stormwater information 2. Semi-Annually Permit Year 2 FY22/23 2. Number of flyers mailed 3. Develop and distribute a stormwater flyer for litter/household wastes/automotive care and leaf pick 3. Semi-Annually Permit Year 3 FY23/24 3. Number of flyers mailed 4. Develop and distribute a stormwater flyer for general stormwater information and fats, oils, and grease (FOG) 4. Semi-Annually Permit Year 4 FY24/25 4. Number of flyers mailed 5. Develop and distribute a stormwater flyer for illicit discharge/illegal dumping and yard waste/leaf pickup. 5. Semi-Annually Permit Year 5 FY25/26 5. Number of flyers mailed 6. Stormwater Information Documents Informational pamphlets, brochures, and giveaways with specific stormwater topics, as well as general information to be handed out to targeted groups and be available at all tabling events. 1. Develop a list of target audiences, groups, and/or businesses for each informational document. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status NCS000421 SWMP City of High Point November 15th, 2021 Page 17 2. Develop a schedule for inventory of all informational documents and giveaways. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of documents of each topic distributed 7. Information Kiosks Multiple stormwater documents will be displayed at locations throughout the City including City Hall (Customer Service), Public Services Department, the City of High Point Visitors Center, Public Library, Piedmont Environmental Center, and other city-maintained recreational facilities. 1. Develop a location list and schedule to regularly check kiosks 1. Annually Permit Year 1 FY21/22 1. Yes/No/Status 2. Check kiosks to ensure documents are available and replenished 2. Quarterly Permit Years 2-5 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of documents of each topic distributed 8. Social Media Work with the City of High Point’s Public Information Office to promote information about upcoming events and other stormwater- related educational information using multiple social media outlets (Facebook, Next Door, Twitter, Instagram) 1. Post at least three stormwater specific informational social media posts per year. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of views per post and topic 9. Advertisements, Media, Etc. Utilize additional physical or digital advertising spaces to increase visibility of the stormwater message. 1. At least once per year, use non-municipal website or outdoor advertisement space (e.g., La Noticia print and website, using ad space inside and outside of High Point Transit Buses, billboards, shopping carts, etc.) to display an informational stormwater message. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status, and topic(s) displayed NCS000421 SWMP City of High Point November 15th, 2021 Page 18 Permit Ref. 2.1.7, 3.2.3 and 3.6.5(c): Web Site Measures to provide a web site designed to convey the program’s message(s) and provide online materials including ordinances, or other regulatory mechanisms, or a list identifying the ordinances or other regulatory mechanisms, providing the legal authority necessary to implement and enforce the requirements of the permit and SWMP. The web page shall also provide developers with all relevant post-construction requirements, design standards, checklists and/or other materials. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 10. Informational Web Site The Stormwater Services Division will maintain an internet web site that contains detailed information regarding all aspects of the stormwater permit requirements, services offered, educational brochures/fliers, and reporting/contact information. 1. Maintain the stormwater web page and update any changes as needed. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 2. Add a link on the Stormwater webpage to the NCDEQ Stormwater webpage 2. Permit Year 1 FY21/22 2. Yes/No/Status Permit Ref. 3.2.5: Stormwater Hotline Measures for a stormwater hotline/helpline for the purpose of public education and outreach. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 11. Stormwater Hotline Dedicated Customer Service number for all Public Services has been established where citizens can call to report stormwater pollution violations. This number is publicized on the website, stormwater flyers and give-away items (pens, pencils, magnates, etc.) 1. Respond to calls and inquiries within one business day (for non- emergencies), and immediately to an IDDE. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of calls received and number of resolutions 2. Advertise hotline/helpline in all ads, printed materials, social media, and website. 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status NCS000421 SWMP City of High Point November 15th, 2021 Page 19 PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal and local public notice requirements. The City of High Point will manage, implement, and report the following public involvement and participation BMPs. Table 14: Public Involvement and Participation BMPs Permit Ref. 3.3.1: Public Input Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 12. Stormwater Hotline Dedicated Customer Service number for all Public Services has been established where citizens can call to report stormwater pollution violations (See BMP 11). 1. See BMP 11 1. See BMP 11 1. See BMP 11 Permit Ref. 3.3.2: Volunteer Opportunities Measures to provide volunteer opportunities designed to promote ongoing citizen participation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 13. Adopt-a-Street Program Provide public and private organizations the opportunity for volunteers to participate in cleaning up local streams. 1. Check in with Keep High Point Beautiful President for Adopt-a- Street results 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Pounds of trash and recycling collected, date and number of participants 14. Adopt-a-Stream Program Provide public and private organizations the opportunity for volunteers to participate in cleaning up local streams. 1. Partner and coordinate with organizations in efforts to clean up adopted stream. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Pounds of trash and recycling collected, date and number of participants NCS000421 SWMP City of High Point November 15th, 2021 Page 20 Table 14: Public Involvement and Participation BMPs 2. Recruit at least one new Adopt-A-Stream group per year. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of new groups 15. Storm Drain Marking Program Volunteers place drain markers on storm drains to assist in stormwater and watershed education within neighborhoods and public streets. 1. Recruit at least one new storm drain marking volunteer group per year. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 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 NCS000421 SWMP City of High Point November 15th, 2021 Page 21 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The City of High Point will develop, manage, implement, document, report and enforce an Illicit Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. Table 15: Illicit Discharge Detection and Elimination BMPs Permit Ref. 3.4.1: MS4 Map Measures to develop, update and maintain a municipal storm sewer system map including stormwater conveyances, flow direction, major outfalls and waters of the United States receiving stormwater discharges. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 16. Storm Sewer System Inventory Provide dedicated field staff to collect and update stormwater infrastructure data. 1. Add pertinent data for new stormwater infrastructure (pipes, junctions, structures, outfalls) to our Stormwater GIS system for new construction 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 2. Maintain storm sewer system map including stormwater conveyances, flow direction, major outfalls, and surface waters. 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status Total number of mapped outfalls 17. Stormwater Web Map All SCMs within the City of High Point are identified and added to the current SCM Stormwater Web Map. 1. Add new SCMs to mapping database once construction and/or conversion from erosion control basin 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 18. Camera Crew In-house staff collects stormwater infrastructure data for existing systems using pipe camera. 1. Maintain process for collecting data and incorporating pertinent information into GIS database 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status NCS000421 SWMP City of High Point November 15th, 2021 Page 22 Table 15: Illicit Discharge Detection and Elimination BMPs Permit Ref. 3.4.2: Regulatory Mechanism Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to prohibit, detect, and eliminate illicit connections and discharges, illegal dumping, and spills into the MS4, including enforcement procedures and actions. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 19. Enforcement The Illicit Discharge Control Ordinance will charge the Public Services Director or designee with implementing the Illicit Discharge Detection and Elimination program. The ordinance does specify legal penalties to be implemented in cases of non-compliance. (Code of Ordinances, Title 12, Chapter 3 - Public Nuisances). 1. Maintain illicit discharge ordinance, administration, and enforcement procedures. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status Permit Ref. 3.4.3: IDDE Plan Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges, illegal dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4. The plan shall provide standard procedures and documentation to: a) Locate priority areas likely to have illicit discharges, b) Conduct routine dry weather outfall inspections, c) Identify illicit discharges and trace sources, d) Eliminate the source(s) of an illicit discharge, and e) Evaluate and assess the IDDE Program. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 20. Written IDDE Plan Maintain and implement a written IDDE Plan. 1. Continue to update the IDDE Plan as required by any change in ordinance, state statute or other federal regulation than is specific to IDDE incidents 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 21. Outfall Inspections NCS000421 SWMP City of High Point November 15th, 2021 Page 23 Table 15: Illicit Discharge Detection and Elimination BMPs Perform regular dry weather (no rain in previous 72 hours) outfall inspections to proactively identify illicit discharges and illicit connections. 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 1. Yes/No/Status 22. Detection and Elimination Detect and identify illicit discharges and connections; conduct dry- weather outfall monitoring; respond to citizen concerns made via the Customer Service line; train City personnel on recognizing and reporting illicit discharges or connections. 1. Continue to respond to IDDEs, train employees, and conduct outfall monitoring 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 2. Maintain equipment and materials to detect IDDEs and analyze stormwater samples. 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status Permit Ref. 3.4.4: IDDE Tracking Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping was observed, the results of the investigation, any follow-up of the investigation, the date the investigation was closed, the issuance of enforcement actions, and the ability to identify chronic violators. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 23. Notice of Violation (NOV) Letters NOVs with a detailed description of the incident along with date/time stamped photos are sent certified mail to the violator or representative. Follow-up occurs when the time allotted for compliance has expired. 1. Continue to update system processing of IDDE records and implement procedures that may increase efficiency of handling these incidents 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 2. Store illicit discharge information in database and Excel spreadsheet; maintain hard copies of NOV letters, photos, and other pertinent information in physical files 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Number of enforcement actions issued NCS000421 SWMP City of High Point November 15th, 2021 Page 24 Table 15: Illicit Discharge Detection and Elimination BMPs Permit Ref. 3.4.5: Staff IDDE Training Measures to provide training for municipal staff and contractors who, as part of their normal job responsibilities, may observe an illicit discharge, illicit connection, illegal dumping, or spills. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping, and spills. Each staff training event shall be documented, including the agenda/materials, date, and number of staff participating. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 24. Staff Training Provide stormwater training to all groups of municipal staff and/or contractors each year. Training shall include how to identify and report illicit discharges, illicit connections, illegal dumping, and spills. 1. Maintain an employee training program on detecting and reporting illicit discharges, illicit connections, illegal dumping, and spills. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status, Number trained Permit Ref. 3.4.6: IDDE Reporting Measures for the public and staff to report illicit discharges, illegal dumping, and spills. The mechanism shall be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained personnel. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 25. Stormwater Hotline Dedicated Customer Service number for all Public Services has been established where citizens can call to report stormwater pollution violations. 1. Promote and publicize phone number to receive reports related to illicit discharges. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of IDDEs reported each year. 26. On-Call Duty Officer On-Call duty officer to be available after normal business hours to investigate illicit discharges, illegal dumping and spills if reported. 1. Promote and publicize phone number to receive reports related to illicit discharges. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of IDDEs reported each year. NCS000421 SWMP City of High Point November 15th, 2021 Page 25 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153, the City of High Point relies upon the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 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 Reference State or Local Program Name Legal Authority Implementing Entity 3.5.1 - 3.5.4 City of High Point Delegated SPCA Program* 15A NCAC Chapter 04 NCDEQ Approved Delegation City of High Point 2 * 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 Ref. 3.5.6: Public Input Measures to provide and promote a means for the public to notify the appropriate authorities of observed erosion and sedimentation problems. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 27. Municipal Staff Training Train municipal staff who receive calls from the public on the protocols for referral and tracking of construction site runoff control complaints. 1. Train municipal staff on proper handling of construction site runoff control complaints. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of staff trained NCS000421 SWMP City of High Point November 15th, 2021 Page 26 28. Stormwater Hotline Dedicated Customer Service number for all Public Services has been established where citizens can call to report stormwater pollution violations. This number is publicized on the website, stormwater flyers and give-away items (pens, pencils, magnates, etc.) (See BMP 11). 1. See BMP 11 1. See BMP 11 1. See BMP 11 Permit Ref. 3.5.5: Waste Management Measures to require construction site operators to control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impact to water quality BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 29. Establish and Maintain Legal Authority Provide ordinance to require construction site operators to control waste 1. Develop, adopt and/or update the ordinance 1. Permit Year 1 FY21/22 1. Yes/No/Status, date of adoption 2. Maintain Legal Authority 2. Continuously Permit Years 2-5 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Summary 30. Pre-Construction Conference Conduct project conferences with contractors, engineers, plan reviewers and site construction inspectors for all projects with land disturbing activities requiring an E&SC plan 1. Conduct Pre- Construction Meetings 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Document and report number of preconstruction conferences 2. Develop and distribute informational Fact Sheet at pre- construction conferences 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status Number of Fact Sheets distributed NCS000421 SWMP City of High Point November 15th, 2021 Page 27 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM This SWMP identifies the minimum elements to develop, implement and enforce a program to address stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that are located within the City of High Point and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of structural Stormwater Control Measures (SCMs) and/or non-structural BMPs appropriate for the community and ensure adequate long- term operation and maintenance of SCMs. In accordance with 15A NCAC 02H .0153 and .1017, the City of High Point implements the following State post-construction program requirements, which satisfy the NPDES Phase II MS4 post-construction site runoff control requirements as Qualifying Alternative Programs (QAPs) in the MS4 area(s) where they are implemented. Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program State QAP Name State Requirements Local Ordinance / Regulatory Mechanism Reference None N/A N/A 2 The City of High Point has existing requirements other than Qualifying Alternative Program(s) for implementation of the NPDES Phase II MS4 post-construction program requirements. These existing requirements are codified in local ordinance(s), and implementation is further defined in guidance, manuals and/or standard operating procedure(s) as summarized in Table 19 below. Table 19: Summary of Existing Post-Construction Program Elements Permit Requirements for Plan Review and Approval Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.2(a) Authority City of High Point Development Ordinance Chapter 2-2 Ord. No. 7266/17-08, § 2, 1-17- 2017; Ord. No. 7476/18-105, § 2.B, 12-3- 2018 3.6.3(a) & 15A NCAC 02H.0153(c) Federal, State & Local Projects City of High Point Development Ordinance Chapter 6-2 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, § 12, 4-3-2017 3.6.3(b) Plan Review City of High Point Development Ordinance Chapter 2-2 Ord. No. 7266/17-08, § 2, 1-17- 2017; Ord. No. 7476/18-105, § 2.B, 12-3-2018 NCS000421 SWMP City of High Point November 15th, 2021 Page 28 3.6.3(c) O&M Agreement City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17-108, § 1, 11-20-2017 3.6.3(d) O&M Plan City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17-108, § 1, 11-20-2017 3.6.3(e) Deed Restrictions/Covenants City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17-108, § 1, 11-20-2017 3.6.3(f) Access Easements City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108, § 1, 11-20-2017 Permit Requirements for Inspections and Enforcement Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.2(b) Documentation City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108, § 1, 11-20-2017 3.6.2(c) Right of Entry City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108 § 1, 11-20-2017 3.6.4(a) Pre-CO Inspections City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108 § 1, 11-20-2017 3.6.4(b) Compliance with Plans City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108 § 1, 11-20-2017 3.6.4(c) Annual SCM Inspections City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108 § 1, 11-20-2017 3.6.4(d) Low Density Inspections City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108 § 1, 11-20-2017 3.6.4(e) Qualified Professional City of High Point Development Ordinance Chapter 6-2-11 Ord. No. 7266/17-08, § 27, 1-17- 2017; Ord. No. 7287/17-29, §§ 12, 13, 4-3-2017; Ord. No. 7365/17- 108 § 1, 11-20-2017 NCS000421 SWMP City of High Point November 15th, 2021 Page 29 Permit Requirements for Fecal Coliform Reduction Municipal Ordinance/Code Reference(s) and/or Document Title(s) Date Adopted 3.6.6(a) Pet Waste City of High Point Code of Ordinances, Title 12, Chapter 3, Sec. 12-3-1 Ord. No. 6168/04-65, § 1, 9-7-04; Ord. No. 6541/08-26, 5-19-08; Ord. No. 6573/08-58, § 2, 8-18- 2008 3.6.6(b) On-Site Domestic Wastewater Treatment City of High Point Code of Ordinances, Title 12, Chapter 3, Sec. 12-3-1 (Ord. No. 6168/04-65, § 1, 9-7-04; Ord. No. 6541/08-26, 5-19-08; Ord. No. 6573/08-58, § 2, 8-18- 2008 The annual reporting metrics for the post construction program are provided in Table 20: Post Construction Site Runoff Control BMPs below. Table 20: Post Construction Site Runoff Control BMPs Permit Ref. 3.6.5(a), 3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements Measures to document activities over the course of the fiscal year (July 1 – June 30) including appropriate information to accurately describe progress, status, and results. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 31. Standard Reporting Implement standardized tracking, documentation, inspections, and reporting mechanisms to compile appropriate data for the annual self- assessment process. Data shall be provided for each Post-Construction/ Qualifying Alternative Program being implemented as listed in Tables 18 and 19. 1. Track number of low density and high density plan reviews performed. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Number of plan reviews performed for low density and high density. 2. Track number of low density and high density plans approved. 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of plan approvals issued for low density and high density. 3. Maintain a current inventory of low density projects and constructed SCMs including SCM type or low density acreage, location, and last inspection date. 3. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Summary of number and type of SCMs added to the inventory; and number and acreage of low density projects constructed. NCS000421 SWMP City of High Point November 15th, 2021 Page 30 Table 20: Post Construction Site Runoff Control BMPs 4. Track number of SCM inspections performed. 4. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 4. Number of SCM inspections. 5. Track number of low density inspections performed. 5. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 5. Number of low density projects inspected. 6. Track number and type of enforcement actions taken. 6. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 6. Number of enforcement actions issued. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric Permit Ref. 3.6.3: Plan Review and Approval Measures to maintain plan review and approval authority, standards and procedures to: (a) Require Federal, State, and local government projects to comply with Post-Construction Program requirements throughout the entire MS4 permitted area, unless the 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. NCS000421 SWMP City of High Point November 15th, 2021 Page 31 BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric Permit Ref. 3.6.4: Inspections and Enforcement Measures to maintain inspection and enforcement authority, standards, and procedures to: (a) Conduct post- construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy. Alternatively, the project owner may provide a surety bond to guarantee compliance with the approved plan(s), (b) Ensure that the project has been constructed in accordance with the approved plan(s), (c) Ensure annual inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance Agreement, (d) Ensure inspection of low density projects at least once during the permit term, and (e) Require that inspections be conducted by a qualified professional. This permit requirement is fully met by the existing post-construction program, see references provided in Table 19. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric Permit Ref. 3.6.6: Fecal Coliform Reduction Measures to control, to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H .1017(7). At a minimum, the program shall include: (a) A pet waste management component, which may be achieved by revising an existing litter ordinance, and (b) An on-site domestic wastewater treatment system component, if applicable, which may be coordinated with local county health department, to ensure proper operation and maintenance of such systems. This permit requirement is fully met by the existing post- construction program, see references provided in Table 19. NCS000421 SWMP City of High Point November 15th, 2021 Page 32 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 Ref. 3.7.1: Municipal Facilities Operation and Maintenance Program Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted stormwater runoff. The permittee shall maintain a current inventory of municipal facilities; perform facility inspections and routine maintenance; establish specific frequencies, schedules, and standard documentation; provide staff training on general stormwater awareness and implementing pollution prevention and good housekeeping practices. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 33. Operation and Maintenance Plan Maintain and update the written Operation and Maintenance Plan. 1. Implement all aspects of the O&M Plan 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status Summary NCS000421 SWMP City of High Point November 15th, 2021 Page 33 2. Update plan on an annual basis. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status Summary 34. Inventory of Municipal Facilities Update and maintain inventory of municipal facilities that have the potential to generate polluted stormwater runoff. 1. Review and update list of municipal facilities. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Date updated 35. Municipal Facility Inspections Inspect municipal facilities deemed to have the potential to generate polluted stormwater runoff. 1. Review and update municipal inspection forms. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status 2. Perform municipal facility inspections on those facilities that have the potential to pollute stormwater. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status, number of inspections 36. Municipal Employee Training Conduct annual stormwater training that covers general stormwater awareness, pollution prevention and spill response, and IDDE reporting 1. Perform employee training at Facilities that have been identified as having the possibility to have a negative impact on stormwater. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status, Number trained NCS000421 SWMP City of High Point November 15th, 2021 Page 34 Permit Ref. 3.7.2: Spill Response Program Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response procedures. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 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. 1. Review and update Spill Response Plan annually to ensure plan is effective. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 2. Perform spill response training for municipal employees annually. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status, Number trained 3. Evaluate municipal facilities to determine if any need to be added or removed from those requiring a Spill Response Plan. 3. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Yes/No/Status 38. 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 1. Yes/No/Status NCS000421 SWMP City of High Point November 15th, 2021 Page 35 Permit Ref. 3.7.3: MS4 Operation and Maintenance Program Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and maintenance staff training on stormwater awareness and pollution prevention, perform MS4 inspections, maintain the collection system including catch basins and conveyances; and establish specific frequencies, schedules, and standard documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 39. Inspections and Maintenance of Stormwater Conveyances Inspection and Maintenance Plan for stormwater infrastructure inspections. 1. Develop an SOP that identifies frequencies and documentation for maintenance. 1. Permit Year 1 FY21/22 1. Yes/No/Status 2.Perform inspections in accordance with SOP 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status Number of MS4 inspections performed 3. Maintain a prioritized Capital Improvement Project (CIP) list. 3. Continuously 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. 40. Employee Training Continue stormwater training to employees within the Public Services Department (See BMP 36). 1. See BMP 36 1. See BMP 36 1. See BMP 36 Permit Ref. 3.7.4: Municipal SCM Operation and Maintenance Program Measures to manage municipally-owned, operated, and/or maintained structural stormwater control measures (SCMs) that are installed for compliance with the permittee’s post-construction program. The permittee shall maintain a current inventory of SCMs, perform SCM inspections and maintenance, and shall establish specific frequencies, schedules, and documentation. A B C D NCS000421 SWMP City of High Point November 15th, 2021 Page 36 BMP No. Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 41. Municipal SCM Inventory Maintain inventory of municipally owned structural SCMs. 1. Maintain Operation and Maintenance plans for all City-owned SCMs. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 2. Update inventory of City-owned SCMs. 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Date updated; total number of SCMs inventoried 42. SCM Inspection and Maintenance Perform regular inspections and maintenance of municipal SCMs and document on an annual basis with all related documentation stored in a tracking database. 1. NC SCM Certification is maintained by Stormwater Staff conducting SCM inspections. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status Number of certified staff 2. Conduct annual SCM inspections per the SCM Inspection SOP. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of inspections performed 3. Perform needed maintenance identified during the inspections. 3. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Number of SCMs maintained 4. Update the tracking data base with inspection status and documents. 4. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 4. Yes/No/Status NCS000421 SWMP City of High Point November 15th, 2021 Page 37 Permit Ref. 3.7.5: Pesticide, Herbicide and Fertilizer Management Program Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine pollution prevention and chemical use, storage, and handling training, and shall ensure compliance with permits and applicator certifications. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 43. Applicator Training for Pesticides, Herbicides and Fertilizer Training of city staff who apply chemicals to help prevent negative water quality impacts from pesticides, herbicides, and fertilizers. 1. Maintain proper licenses or certification for applying pesticides, herbicides, and fertilizers. 1. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status Number of licensed staff 2. Provide staff training in pollution prevention and applying chemicals. 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status, Number trained Permit Ref. 3.7.6: Vehicle and Equipment Maintenance Program Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES industrial permitting comply with those permit requirements, provide routine pollution prevention training to staff, perform routine inspections, and establish specific frequencies, schedules, and documentation. BMP No. A B C D 44. NPDES Industrial Permit Compliance Ensure that municipal facilities covered under an NPDES industrial permit are maintaining compliance. 1. Update municipal facility inventory with NPDES permit status. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status NCS000421 SWMP City of High Point November 15th, 2021 Page 38 2. Ensure that all NPDES Permits for municipal facilities are renewed as needed. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status; number of industrial stormwater permitted facilities 3. Use industrial facility inspection form when conducting annual inspections at municipal facilities covered under a NPDES permit. 3. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 3. Yes/No/Status; number of industrial facility inspections performed 4. See BMP 36 4. See BMP 36 4. See BMP 36 45. Vehicle and Equipment Cleaning and Maintenance Facility Inspections Vehicle and equipment cleaning and maintenance is included as part of the annual facility inspection. 1. Perform annual inspections and notify responsible person of any corrective actions required. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status Number of inspections performed 2. Ensure any corrective actions are made by conducting a follow-up inspection and/or contacting the responsible person. 2. Continuously Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Yes/No/Status Number of follow-up inspections performed Permit Ref. 3.7.7: Pavement Management Program Measures to reduce pollutants in stormwater runoff from municipally-owned streets, roads, and parking lots within the permittee’s corporate limits. The permittee shall implement measures to control litter, leaves, debris, particulate, and fluid pollutants associated with vehicles, and establish specific frequencies, schedules, and documentation. BMP No. A B C D Description of BMP Measurable Goal(s) Schedule for Implementation Annual Reporting Metric 46. Street Sweeping NCS000421 SWMP City of High Point November 15th, 2021 Page 39 Street sweeping following a regular schedule in order to reduce pollutants from City owned and maintained streets. 1. Develop a standard operating procedure, including schedules, zones/locations, and proper disposal of collected wash waters and solids. 1. Permit Year 1 FY21/22 1. Yes/No/Status 2. Implement SOP and documentation. 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Number of street miles swept 47. Loose Leaf Collection Provide seasonal loose leaf collection in residential areas and compost the collected material at the city operated composting center for use by the city and residents. 1. Publicize/establish protocols for residential brush and bagged leaf collections. 1. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 1. Yes/No/Status 2. Collect brush and bagged leaves 2. Annually Permit Years 1-5 FY21/22 FY22/23 FY23/24 FY24/25 FY25/26 2. Total weight of brush collected