HomeMy WebLinkAbout02_Stormwater Management PlanGreensboro
City of Greensboro
Stormwater Management Plan
(NCS000248)
March 3, 2022
PREPARED FOR
PREPARED BY
City of Greensboro Tetra Tech Engineering, P.C.
Water Resources Department 4000 Park Drive, Suite 200
Stormwater Management Division Durham, NC 27709
2602 South Elm -Eugene Street Tel 919-485-8278
Greensboro, NC 27402 Fax 919-485-8280
tetratech.com
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City of Greensboro Stormwater Management Plan (Final) March 3, 2022
TABLE OF CONTENTS
1.0 INTRODUCTION..................................................................................................................................... 5
2.0 CERTIFICATION.................................................................................................................................... 6
3.0 MS4 INFORMATION..............................................................................................................................7
3.1 Permitted MS4 Area.........................................................................................................................
7
3.2 Existing MS4 Mapping......................................................................................................................8
3.3 Receiving Waters...........................................................................................................................
10
3.4 MS4 Interconnection.......................................................................................................................
12
3.5 Total Maximum Daily Loads (TMDLs)............................................................................................
12
3.6 Endangered and Threatened Species and Critical Habitat............................................................
12
3.7 Industrial Facility Discharges..........................................................................................................
12
3.8 Non-Stormwater Discharges..........................................................................................................
12
3.9 Target Pollutants and Sources.......................................................................................................
13
4.0 STORMWATER MANAGEMENT PROGRAM IMPLEMENTATION...................................................
15
4.1 Legal Authority................................................................................................................................
15
4.2 Organizational Structure.................................................................................................................
15
4.3 Program Funding and Budget........................................................................................................
19
4.4 Shared Responsibility.....................................................................................................................20
4.5 Co-Permittees.................................................................................................................................20
4.6 Measurable Goals for Program Implementation.............................................................................
20
5.0 PUBLIC EDUCATION AND OUTREACH............................................................................................23
6.0 PUBLIC INVOLVEMENT AND PARTICIPATION................................................................................
26
7.0 ILLICIT DISCHARGE DETECTION AND ELIMINATION....................................................................28
8.0 CONSTRUCTION SITE RUNOFF CONTROLS...................................................................................
30
9.0 POST -CONSTRUCTION SITE RUNOFF CONTROLS........................................................................32
10.0 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS .....
35
11.0 PROGRAM TO MONITOR AND CONTROL POLLUTANTS IN STORMWATER DISCHARGES TO
MUNICIPALSYSTEMS..............................................................................................................................40
12.0 WATER QUALITY ASSESSMENT AND MONITORING...................................................................42
13.0 TOTAL MAXIMUM DAILY LOADS....................................................................................................43
14.0 PROGRAM ASSESSMENT, REPORTING, AND RECORDKEEPING.............................................47
14.1 Program Assessment...................................................................................................................
47
14.2 Reporting and Recordkeeping......................................................................................................47
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
LIST OF TABLES
Table 1: Summary of Current MS4 Mapping (2022)....................................................................................8
Table 2: Summary of Primary MS4 Receiving Waters (Alphabetical)........................................................11
Table 3: Summary of Approved TMDL(s)...................................................................................................12
Table 4: Allowable Non-Stormwater Discharges........................................................................................13
Table 5: Summary of Target Pollutants and Sources................................................................................14
Table 6: Summary of Responsible Positions..............................................................................................17
Table 7: Shared Responsibilities................................................................................................................20
Table 8: Program Implementation BMPs...................................................................................................21
Table 9: Public Education and Outreach BMPs.........................................................................................23
Table 10: Public Involvement and Participation BMPs...............................................................................26
Table 11: Illicit Discharge Detection and Elimination BMPs.......................................................................28
Table 12: Construction Site Runoff Control BMPs.....................................................................................
30
Table 13: Post -Construction Site Runoff Control BMPs.............................................................................32
Table 14: Pollution Prevention and Good Housekeeping BMPs................................................................35
Table 15: Program to Monitor and Control Pollutants BMPs.....................................................................40
Table 16: Water Quality Assessment and Monitoring BMPs.....................................................................42
Table 17: Total Maximum Daily Loads (TMDLs) BMPs.............................................................................43
LIST OF FIGURES
Figure 1: City of Greensboro Corporate Limits............................................................................................ 7
Figure 2. City of Greensboro NPDES MS4 Outfall Mapping 2022...............................................................9
Figure 3: City of Greensboro MS4 Permit Implementation Organizational Chart......................................18
Figure 4: City of Greensboro Stormwater Fiscal Year 2020-2021 Budget Expenses...............................19
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
ACRONYMS/ABBREVIATIONS
BMP Best Management Practice
CA
DEMLR
Critical Area
Division of Energy, Mineral, and Land Resources
E&SC
Erosion and Sediment Control
ERU
Equivalent Residential Unit
FEMA
Federal Emergency Management Agency
FOG
Fats, Oils, and Grease
GHP
Good Housekeeping Program
GIS
Geographic Information System
HAZMAT
HAZardous MATerials
I&M
Inspection and Maintenance
IDDE
Illicit Discharge Detection and Elimination
IIP
Industrial Inspection Program
MEP
Maximum Extent Practicable
Municipal Separate Storm Sewer System
North Carolina Department of Environmental Quality
MS4
NCDEQ
NFIP
National Flood Insurance Program
NOV
Notice of Violation
NPDES
National Pollutant Discharge Elimination System
NSW
Nutrient Sensitive Waters
PE&O
Public Education and Outreach
POC
Pollutant of Concern
Pollution Prevention and Good Housekeeping
Superfund Amendments and Reauthorization Act of 1986
PP/GH
SARA
SCM
Stormwater Control Measure
SMART
Specific, Measurable, Attainable, Relevant, and Time -oriented
SOP
Standard Operating Procedure
SPCA
Sediment Pollution Control Act
SSO
Sanitary Sewer Overflow
SWMP
Stormwater Management Plan
Site Pollution Prevention Plan
Total Maximum Daily Load
SPPP
TMDL
TRC
Technical Review Committee
1A/1 A
Wne+a I nnrl AIlnr nfinn
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
REVISION LOG
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
1.0 INTRODUCTION
The purpose of this Stormwater Management Plan (SWMP) is to establish and define the means by
which the City of Greensboro 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 Greensboro 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 NCS000248, 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 Greensboro and located
within the corporate limits of the City of Greensboro.
In preparing this SWMP, the City of Greensboro 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 into the permit. Any major changes to the
approved SWMP will require resubmittal, review, and approval by NCDEQ.
5
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
2.0 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.
am aware that there are significant penalties for submitting false information, including the possibility of
fines and imprisonment for knowing violations.
am also aware that the contents of this document shall become an enforceable part of the NPDES MS4
Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit
compliance and enforcement authority.
Signature: �
Print Name: Taiwo (Tai) Jaiyeoba
Title: City Manager
Signed this da of 20 2Z .
a
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
3.0 MS4 INFORMATION
The City of Greensboro's initial NPDES MS4 Discharge Permit (Permit Number NCS000248) became
effective on December 30, 1994. NCDEQ issued the City of Greensboro's current permit on October 10,
2018, for a period of five years with an effective expiration date of October 9, 2023.
The City's NPDES stormwater permit, and associated SWMP, are designed to control the discharge of
pollutants from the MS4 to the Maximum Extent Practicable (MEP).
3.1 Permitted MS4 Area
This SWMP applies throughout the corporate limits of the City of Greensboro, including all regulated
activities associated with the discharge of stormwater from the MS4. The map below shows the corporate
limits of the City of Greensboro (green polygon).
Figure 1: City of Greensboro Corporate Limits
7
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
3.2 Existing MS4 Mapping
The City of Greensboro's current MS4 mapping includes NPDES MS4 major outfalls* as well as additional
pertinent MS4 assets including manholes, pipe inlets/outlets, open conveyance channels, culverts, storm
inlets, spillways, and pipes, as well as flow connectivity and waterbodies. A numerical summary of the
City's mapped stormwater assets is provided below, and an accompanying map is provided in Figure 2.
Table 1: Summary of Current MS4 Mapping (2022)
NPDES MS4 Assets
Percent of MS4 Area Mapped
No. of Major Outfalls* Mapped
NPDES Industrial Outfalls (>_12")
NPDES Non -Industrial Outfalls (>_36")
Other Stormwater Assets
Manholes
Pipe IOs (Inlets/Outlets)
Open Conveyance
Culverts
Inlets
Spillways
Pipes
Flow Connectivity
Waterbodies
100%
2,070
817
1,233
13,647
16,688
13,239
1,410
57,734
1,822
78,087
5,523
1,778
*The City's NPDES MS4 permit defines a "major MS4 outfall" as a municipal separate storm sewer outfall
that discharges from a single pipe with an inside diameter of 36 inches or more or its equivalent
(discharge from a single conveyance other than circular pipe which is associated with a drainage area of
more than 50 acres); or for municipal separate storm sewers that receive Stormwater from lands zoned for
industrial activity (based on comprehensive zoning plans or the equivalent), an outfall that discharges
from a single pipe with an inside diameter of 12 inches or more or from its equivalent (discharge from
other than a circular pipe associated with a drainage area of 2 acres or more).
0
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
KI
Mir
i,'611 j�
for
2022
Now
Lenend
s
,'YYnot..
N—Ihd��bnaINPDESO.kfh
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.
Figure 2. City of Greensboro NPDES MS4 Outfall Mapping 2022
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
3.3 Receiving Waters
Greensboro is located near the headwaters of the Cape Fear River Basin in the Piedmont physiographic
region of North Carolina, with a majority of the City's jurisdictional watersheds draining eastward toward
the Haw River, while a smaller portion of the City area drains south toward the Deep River. The North and
South Buffalo Creek Watersheds drain the majority of the City's central urbanized area eastward toward
Buffalo Creek. Beyond the eastern City limits, Buffalo Creek drains generally northeastward into the
Reedy Fork Creek and the Haw River, a tributary of the Jordan Lake watershed. The City of Greensboro,
with a total area of about 132 square miles, represents just over 1 % of the 9,322 square mile Cape Fear
River Basin.
Table 2 summarizes primary MS4 receiving waters within the City's jurisdictional area. The following
NCDEQ sources were referenced to verify applicable water quality classifications and water quality
parameters of interest:
• Waterbody Classification Map
• Most recent NCDEQ Final 303(d) List
10
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Table 2: Summary of Primary MS4 Receiving Waters (Alphabetical)
Brush Creek Within corporate limits WS-III;NSW Benthos, Fish Community
Bull Run Within corporate limits WS-IV:*, WS-IV;CA:* N/A
East Fork Deep River Within corporate limits WS-IV:*, WS-IV;CA:* Benthos
Hickory Creek Within corporate limits WS-IV:*, WS-IV;CA:*
Horsepen Creek Within corporate limits WS-III;NSW, WS-III;NSW,CA
Little Alamance Creek Within corporate limits WS-IV;NSW, WS-IV;NSW,CA
North Buffalo Creek Within corporate limits WS-V;NSW
Reedy Fork Within corporate limits WS-III;NSW, WS-III;NSW,CA,
WS-V;NSW
South Buffalo Creek Within corporate limits WS-V;NSW
Benthos
Benthos
N/A
Benthos, Fish Community, Copper, Zinc, Fecal Coliform
Benthos, Fish Community
Benthos, Fish Community, Fecal Coliform
CA: Critical Area
NSW: Nutrient Sensitive Waters
WS-III: Water Supply III — Moderately Developed
WS-IV: Water Supply IV — Highly Developed
WS-V: Water Supply V — Upstream
*Identifies waters that are within a designated Critical Supply Watershed and are subject to a special management strategy specified in 15A NCAC 213 .0248
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
3.4 MS4 Interconnection
The City of Greensboro MS4 is not interconnected with another regulated MS4 and directly discharges to
the receiving waters as listed in Table 2 above.
3.5 Total Maximum Daily Loads (TMDLs)
The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the
map and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates
whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed
directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program
has been implemented to address the WLA. Best management practices (BMPs) for addressing MS4
permit requirements as they pertain to TMDLs are described in Part 13 of this SWMP.
Table 3: Summary of Approved TMDL(s)
North Buffalo Creek Fecal Coliform Y Y
3.6 Endangered and Threatened Species and Critical Habitat
Significant populations of threatened or endangered species and/or critical habitat are not identified within
the City of Greensboro regulated MS4 urbanized area. This determination was made based upon a
review of the Endanaered 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.
3.7 Industrial Facility Discharges
The City of Greensboro jurisdictional area includes multiple industrial facilities that hold NPDES Industrial
Stormwater Permits as determined from the NCDEQ Maps & Permit Data web page. The list of permitted
industrial facilities within the City of Greensboro is updated annually as required by Part II Section H.2(a).
The City will provide program results in the City's annual reporting, as documented in Part 10 of the
SWMP.
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of Greensboro
as summarized in Table 4 below. The City's Stormwater Management Ordinance prohibits the discharge
of any non-stormwater flow to any stormwater conveyance with the exception of those discharges listed in
Table 4.
The City of Greensboro has evaluated residential and charity car washing and street washing for possible
significant water quality impacts. Street washing discharges are addressed under the Pavement
12
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
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 Greensboro. Washwater 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 been evaluated by
the City of Greensboro to determine whether they may significantly impact water quality. These
discharges are primarily addressed by the City through the Public Education and Outreach program and
the Illicit Discharge Detection and Elimination program as addressed in Parts 5 and 7 of this SWMP.
Table 4: Allowable Non-Stormwater Discharges
Water line flushing
Diverted stream flows
Rising groundwater
Uncontaminated groundwater infiltration
Uncontaminated pumped groundwater
Foundation drains
Air conditioning condensation
Irrigation water
Springs
3.9 Target Pollutants and Sources
Water from crawl space pumps
Footing drains
Lawn watering
Residential car washing
Flows from riparian habitats and wetlands
Dechlorinated swimming pool discharges
Street washwater
Discharges from firefighting
The Stormwater Management Division has identified common water quality pollutants and potential
sources and activities contributing to these pollutants. Target audiences have been identified allowing for
proactive measures to be implemented. Table 5 summarizes this information, including the associated
SWMP programs that address each pollutant. Target pollutants are addressed throughout the permit term
in accordance with the goals and schedule described within this SWMP for each respective program
area.
13
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
Table 5: Summary of Target Pollutants and Sources
Residents,
Miscellaneous Illicit Connections, Businesses/Industries, IDDE,
Improper Disposal PP/GH, IIP
Institutions
Bacteria (e.g., Fecal
Pet/Animal Waste, SSOs Residents, Kennels
Coliform, E. coli)
Pesticides, Fertilizers, Residential Lawns and
Yard Waste, Loose Leaf Gardens, Landscaping Residents, Landscapers
Petroleum Products, Residents, Auto Shops,
Vehicle Maintenance/Auto
Automotive Fluids, Mobile Auto Washers,
Heavy Metals Repair, Pressure Washing Permitted Facilities
Detergents, Cleaning Vehicle/Equipment Mobile Auto Washers,
Agents
Washing, Mop Water, Floor Businesses, Permitted
Cleaning Facilities
Fats, Oils, Grease
Paint, Drywall,
Construction Waste
Sediment/Turbidity,
Slurry
Litter, Household
Hazardous Waste
(HHW)
Cooking Oil/Grease, Food Residents, Restaurants,
Waste Food Trucks
Construction, Structural
Repair/Maintenance
Construction/Building,
Structural
Repair/Maintenance,
Concrete/Cement
Residents,
Businesses/Industries,
Institutions
Residents, Painters,
Structural Contractors,
Builders
Builders, Contractors
(Concrete/Ready-Mix,
Construction),
Drillers/Borers
Residents,
Businesses/Industries,
Institutions
PE&O, IDDE
PE&O, IDDE,
PP/GH, IIP
PE&O, IDDE,
IIP
IDDE,
PP/GH, IIP
PE&O, IDDE,
FOG
IDDE
IDDE, E&SC
PE&O,
PP/GH
*PE&O: Public Education and Outreach (SWMP Section 5.0)
IDDE: Illicit Discharge Detection and Elimination (SWMP Section 7.0)
E&SC—Erosion and Sediment Control: Construction Site Runoff Controls (SWMP Section 8.0)
PP/GH: Pollution Prevention and Good Housekeeping for Municipal Operations (SWMP Section 10.0)
IIP—Industrial Inspection Program: Program to Monitor and Control Pollutants in Stormwater Discharges to Municipal
Systems (SWMP Section 11.0)
FOG: Fats, Oils, and Grease (Program through Wastewater Permit(s)—Water Resources, Operations Division)
*May include partnership with Stormwater SMART.
14
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
4.0 STORMWATER MANAGEMENT PROGRAM IMPLEMENTATION
4.1 Legal Authority
The required legal authorities for Greensboro's NPDES municipal stormwater program were developed
and adopted during the first permit period in a new ordinance to the Greensboro Land Development
Ordinance: Chapter 30 (City of Greensboro Stormwater Management Ordinance). The Stormwater
Management Ordinance became effective on July 1, 1994. The Chapter 30 ordinance includes the
following objectives:
• To provide for the establishment and enforcement of the City's Stormwater Management
Program;
• To reduce the discharge of pollutants to the storm sewer system to the maximum extent
practicable by requiring, where appropriate, the use of best management practices, structural
and/or nonstructural stormwater quantity and quality control measures and other provisions;
• To provide for the inspection and proper maintenance of structural and nonstructural stormwater
controls and the municipal separate storm sewer;
• To prohibit non-stormwater discharges to the City storm sewer and require the removal of illicit
connections to the City storm sewer;
• To prevent improper disposal of materials that degrade water quality;
• To permit sampling and monitoring for pollutants such as those associated with illicit discharges,
improper disposal, industrial and construction activities, and the application of pesticides,
herbicides, and fertilizers; and,
• To reduce erosion associated with stormwater runoff; and
• To provide legal definitions for user fee rate calculations.
To date, no significant changes have been required or considered for the City's legal authority related to
NPDES stormwater program implementation. Stormwater Management, working with City Management,
Council, and Stakeholders, has incorporated runoff quantity control and citywide stream buffer
requirements into the Code of Ordinance in recent years, but these have not been specific NPDES MS4
discharge permit requirements. Many of these additional requirements along with historic stormwater
related regulations are located throughout the Code of Ordinance with a large portion appearing in
Chapter 30 which serves as the City's Unified Development Ordinance. Additional ordinance language
specific to the Phase II rules, specifically with regard to post -construction runoff, was adopted by City
Council on April 7, 2009, and became effective June 1, 2009.
4.2 Organizational Structure
The City of Greensboro's Stormwater Management utility is one of seven divisions of the City's Water
Resources Department (which includes water supply, water reclamation, customer service, business,
engineering, and operations and maintenance). This organizational arrangement facilitates protecting and
improving surface water quality while best managing local water resources.
Although the Stormwater Management Division resides within the Water Resources Department, the
program itself is much broader and encompasses and/or extends well beyond the boundaries of the
Water Resources Department. Several other departments in the City of Greensboro, as well as those in
Guilford County, contribute to stormwater quality management and NPDES-related programs in
15
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
substantive ways. The following bullet points and Table 6 identify the overall organizational structure and
functional responsibilities of the City's Stormwater Management Program.
City Stormwater Management Division: NPDES MS4 Discharge Permit administration for
Greensboro; stormwater utility administration; surface water quality monitoring and operations
management; computerized infrastructure management systems; stormwater and surface water
quality related complaint response; stormwater conveyance system inventory and detailed MS4
outfall mapping; public education and awareness; stormwater and watershed master planning; site
development plan reviews for stormwater management; general stormwater-related technical support
and mapping; local Federal Emergency Management Agency (FEMA) National Flood Insurance
Program (NFIP) floodplain administration; local water supply watershed protection program
administration; stormwater control measures (SCM) evaluations and SCM crediting; SCM inspections
and monitoring; field screening and follow-up monitoring activities; industrial monitoring and related
activities; industrial inspections and educational efforts; system inspection; special stormwater
inspection and enforcement programs; water quality inspections and monitoring programs; overall
authority (as delegated from City Manager's Office) over the municipal stormwater quality
management programs
• City Field Operations Department: Litter (including floatables) and loose-leaf collection programs;
street cleaning and sweeping programs; closed drainage infrastructure system routine and remedial
maintenance activities; open channel maintenance; new storm sewer construction
• City Engineering and Inspections Department: Project design, construction contract bidding,
construction contract administration, and inspections of new development and redevelopment;
stormwater capital improvement projects and property acquisition; local construction erosion and
sedimentation control program administration
• City Parks and Recreation Department: City of Greensboro parks, greenway and utility easement
maintenance coordination and programs; partner in volunteer programs such as Adopt -a -Park
• City Planning Department: Overall City planning including management of plan review process;
comprehensive planning; management of City's Technical Review Committee (TRC) for design
engineers and developers; zoning management and ordinance development and revisions
• City Water Resources Department (beyond Stormwater Division): Enhancements to the
municipal stormwater system and receiving waters by controlling sanitary sewer overflows (SSOs)
and industrial spills; pretreatment programs for major industry; water supply and wastewater
treatment programs, including planning and management; water distribution system and sanitary
sewer system maintenance programs
• City Fire Department: Spill response program — HAZMAT (HAZardous MATerials) Team,
containment of spills; industrial site inspections
• City Management Information Systems Department: Data management including city Geographic
Information Systems (GIS) and city database administration; city computer systems management;
aerial photography and related city mapping programs
• City Legal Department: Permit -related legal, enforcement and ordinance assistance; other legal
services including contract and agreement reviews
• (Guilford County) Emergency Management/Health Department: County emergency management
programs, chemical control; county spill response, coordinate cleanup & reporting
16
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Table 6: Summary of Responsible Positions
Stormwater Program Stormwater Management Water Resources —
Administration Division Manager David Phlegar Stormwater Management
SWMP Management Water Quality Section
Supervisor
Public Education &
Outreach
Public Involvement &
Pnrtirinatinn
Illicit Discharge Detection
& Elimination
Public Education
Coordinator
Water Quality Analyst
Public Education
Coordinator
Water Quality Analyst
Operations Management
Section Supervisor
TBD Water Resources—
Stormwater Management
Laine Roberts Water Resources —
Business
Debbie Shoffner Water Resources—
Stormwater Management
Laine Roberts Water Resources —
Business
Debbie Shoffner Water Resources—
Stormwater Management
Ray Johnson Water Resources—
Stormwater Management
Construction Site Runoff Erosion and Sediment Cass Heaton
Controls Control Chief
Post -Construction Site Stormwater Engineering Johnnie Hill
Runoff Controls Section Supervisor
Municipal SCM Operation Operations Management Ray Johnson
& Maintenance Program Section Supervisor
Pollution Prevention &
Good Housekeeping for
Municipal Operations
Water Quality Specialist
Water Quality Analyst
Public Education
Coordinator
Elea Reyna
Ocampo
Blake Strumbel
Laine Roberts
Water Resources—
Stormwater Management
Water Resources —
Engineering
Water Resources—
Stormwater Management
Water Resources—
Stormwater Management
Water Resources—
Stormwater Management
Water Resources—
RiiSinPS
For additional information on specific program responsibilities, refer to the
City's most recent MS4 Operation & Maintenance Plan.
Program to Monitor &
Control Pollutants in Water Quality Analyst
Stormwater Discharges
Water Quality Section
Water Quality Assessment Supervisor
& Monitoring
Water Quality Analyst
Total Maximum Daily Water Quality Section
Loads Supervisor
Blake Strumbel Water Resources—
Stormwater Management
TBD Water Resources—
Stormwater Management
Debbie Shoffner Water Resources—
Stormwater Management
TBD Water Resources—
Stormwater Management
17
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
CITY OF G'REENSBORO
Organizational Chart
NPaES MS4 Programs
March2022
Vacant
A5515TANTCITY
MANAGER
Taiwo Jaiyeoba u Chris Wilson
CITY MANAGER Ill DEPUTY CITY
MANAGER
Michelle Kenney McDowell Mike Borchers
Sue Schwartz
Kennedy EN
PLANNING GINEERING WATER
NEIGHBORHOOQ &INSPECTIONS RESOURCES
DEVELOPMENT DIRECTOR DIRECTOR DIRECTOR
DIRECTOR
............:............
Redevelolxnm[
Michael Lewis gulch Shumate
DEVELOPMENT rACILITIES
SERVICES MANAGER
MANAGER
City EacrliNSCM••
Kenny Carroll SUM. —
Kristine Williams
ASSISTANT
DIRECTOR
Aimee Walker
BUSINESS
MANAGER
Laine Roberts
Daniel
WATER
EliRESOURCE5
FINANCIAL
u - • u
EDUCATION
COORDINATOR
—" ...........
•Puwrestr.mwarer
Educatbn &
o.—h
- PuMi[ inv t— nt&
Panrnpauon
ANALYST
Aarmwatet UttlRy
FlmrrdalOwersight
David Phlegar
STORMWATER
MANAGEMENT
MANAGER
Larry Davis Nathaniel"Trey"
ASSISTANT CITY Davis
MANAGER ASSISTANTCITY
MANAGER
lull. Delgado
FIELD
OPERATIONS
DIRECTOR
Chris Marriott
James Sieber
FIELD
RIGHT-OF-WAY
OPERATIONS
MAINTENANCE
DEPUTY
MANAGER
DIRECTOR
Vacant
Richard Lovett
RIGHT -Or -WAY
ENVIRONMENTAL
MAINTENANCE
SERVICES
SUPERVISOR
MANAGER
..........:.............
.................
• now Maintenarwe
SWPPPs&
Imowiiy, utcl
Imdemenraaon
.Tree news
(landfill, GTA, MMfprd}
Household Hazar<kms
warn
X',�TREET
Virginia Spillman
•Street Sweepersl
ASSISTANT
cleaners
DIRECTOR
Imse lcat[allecdm
Ednasha M[Cray
DIRECTOP
LRARKS&S&RECREATIpN
Management
OpenSpa[eand Pack
SCMs
Nathaniel Moore
...........:...........
•spm Responsea
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Randall Cox
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..... ....:...........
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David Munoz
STREET
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........................
Jana Stewart
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Mario Edouard
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Cass Heaton
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IG Chukwu
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Debbie Shaffner
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Devin Lawimoro
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Huw Wheeler
Mark Cain
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Elea Reyna
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Figure 3: City of Greensboro MS4 Permit Implementation
Organizational Chart
18
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
4.3 Program Funding and Budget
In accordance with the issued permit, the City of Greensboro 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 City established a stormwater utility funding mechanism partially in response to the initial and
ongoing requirements of the NPDES municipal stormwater permit, but also to help ensure a dedicated
funding source for stormwater-related programs and activities and to manage municipal stormwater
issues in a more proactive and comprehensive manner. As impervious area is generally in direct
correlation with the volume and quality of surface stormwater runoff, establishing the stormwater billing
system based on total impervious area is equitable to all of the City's utility customers. As of January 1,
2004, single-family residences are charged one of three tiers with an average rate of $2.70 per month.
Non -single-family properties are billed based upon the number of equivalent residential units (ERUs),
which is computed by dividing the total impervious area by the size of the ERU (2,543 square feet), on the
given property.
Additionally, as a financial incentive for nonstructural and structural best management practice
implementation at non -single-family residential sites throughout the City, Greensboro provides a fee
crediting mechanism within the stormwater utility. The City also provides technical support and
educational assistance for innovative stormwater practices.
The stormwater utility is a dedicated balanced enterprise fund with budgeted revenues and expenditures
of just over fourteen million dollars in the coming fiscal year. This budget represents a slightly higher than
normal budget due to an extra investment in capital projects this fiscal year. The chart illustrates the
allocation of Stormwater Utility funds by operational category.
Stormwater FY 2020-2021 Budget Expenses
$14,035,803.00 Operations
Administration Management
6, 3% Water Quality &
Monitoring
Planning & 7%
Engineering
Construction 3%
38%IL
Public Education &
Maintenance Awareness
24% 1%
Street
Cleaning
18%
Figure 4: City of Greensboro Stormwater Fiscal Year 2020-2021 Budget Expenses
19
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
4.4 Shared Responsibility
The City of Greensboro will share the responsibility to implement the following minimum control
measure(s), which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The
City of Greensboro remains responsible for compliance if the other entity fails to perform the permit
obligation, and may be subject to enforcement action if neither the City of Greensboro nor the other entity
fully performs the permit obligation. Table 7 below summarizes any shared responsibilities.
Table 7: Shared Responsibilities
Public Education & Outreach Stormwater SMART* (Piedmont Triad Regional Council) N (Contractual)
*Stormwater SMART: https://www.ptrc.org/services/regional-planninq/stormwater-smart
4.5 Co-Permittees
The are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000248 for the City of Greensboro.
4.6 Measurable Goals for Program Implementation
The City of Greensboro will manage and report the following BMPs for the administration of the
Stormwater Management Program.
20
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Table 8: Program Implementation BMPs
Program-
Permit
II.AA: "The permittee will maintain adequate legal mechanism, such as regulations,
Ref.
ordinances, policies and procedures to implement all provisions of the Stormwater
Management Plan. If major modifications are proposed in the timeline for development of
these authorities, the Division must be notified of the changes, the reasons for the changes,
and justifications for the changes. The Division may comment on the modifications and
require changes as allowed by Federal and State and as deemed necessary to assure
appropriate implementation of the Stormwater Management Plan. The Permittee shall obtain
prior approval of changes to the Stormwater Management Plan that eliminate or reduce any
program or measure in an approved Stormwater Management Plan."
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual
Implementation
Reporting Metric
1.
Maintain regulations, ordinances,
policies, and procedures.
Maintain adequate legal
Review regulations�nnually, Permit Report any
mechanism, such as
ordinances, policies, Years 1-5 updates and
regulations, ordinances,
and procedures and modifications.
policies, and procedures to
update if necessary.
implement all provisions of
the Stormwater
Management Plan.
Permit
II.A.2: "The permittee will implement provisions of the Stormwater Management Plan and
Ref.
evaluate the performance and effectiveness of the program components."
A B C D
BMP
No.
�
Description of BMP Measurable Goals) Schedule for Annual
Implementation I Reporting Metric
2.
Implement the Stormwater
Management Plan.
Evaluate program Annually, Permit Described in
Implement the City's
SWMP and evaluate
effectiveness as Years 1-5 Section 14
performance and
described in Section (Program
effectiveness.
14 (Program Assessment,
Assessment, Reporting, and
Reporting, and Recordkeeping)
Recordkeeping)
Permit
II.A.3: "The permittee is required to keep the Stormwater Management Plan up to date with
Ref.
annual updates if any changes are warranted. The permittee is required to make available its
Stormwater Management Plan to the Division upon request. At a minimum, the permittee
shall include 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. The Division may review reports submitted by the
permittee to assure that the Stormwater Management Plan is implemented appropriately to
address the requirements of the permit. The Division may require modifications to any part of
the permittee's Stormwater Management Plan where deficiencies are found. If modifications
to the Stormwater Management Plan are necessary, then the Division will notify the permittee
of the need to modify the Stormwater Management Plan to be consistent with the permit and
will establish a deadline to finalize such changes to the program."
A
B
C
D
21
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Program
BMP
Description of BMP
Measurable Goal(s)
Schedule for
Annual
No.
Implementation
Reporting Metric
3.
Keep the Stormwater Management Plan up to date.
Maintain SWMP with
1. Update the SWMP
1. Permit Year 1
1. Report any
annual updates if any
to incorporate current
updates and
changes are warranted.
permit requirements
modifications.
and program
components.
2. Review the SWMP
2. Annually,
2. Report any
and update if
Permit Years 2-5
updates and
necessary.
modifications.
4.
Maintain appropriate legal mechanisms.
I
Include ordinances or other
Review regulations,
Annually, Permit
Report any
regulatory mechanisms
ordinances, policies,
Years 1-5
updates and
providing legal authority to
and procedures and
modifications.
implement and enforce the
update if necessary.
requirements of the permit.
Permit
II.AA: "The permittee shall maintain,
and make available to the Division upon request, written
Ref.
procedures for implementing
the six minimum control
measures. Written
procedures shall
identify specific action steps,
schedules, resources and responsibilities for implementing the
six minimum measures."
BMP
A
B
C
D
No.
Description of BMP
Measurable Goal(s)
Schedule for
Annual
Implementation
Reporting Metric
5.
Maintain written procedures.
Maintain written procedures
1. Maintain written
1. Ongoing,
1. N/A
for implementing the six
procedures as
Permit Years 1-5
minimum control measures
documented in this
and make available to the
SWMP.
Division upon request.
2. Review and
2. Annually,
2. N/A
update written
Permit Years 1-5
procedures as
necessary and as
documented in this
SWMP.
22
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
5.0 PUBLIC EDUCATION AND OUTREACH
The City of Greensboro will implement a Public Education and Outreach Program to distribute
educational materials to the community or conduct equivalent outreach activities about the impacts of
stormwater discharges on water bodies and steps the public can take to reduce pollutants in stormwater
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 5. In addition, the City of
Greensboro is required to inform businesses and the general public of the hazards associated with illicit
discharges, illegal dumping, and improper disposal of waste.
The City of Greensboro will manage, implement, and report the following public education and outreach
BMPs.
Table 9: Public Education and Outreach BMPs
Permit II.B.2.a: Describe target pollutants and target pollutant sources
Ref. "Describe the target pollutants and target pollutant sources the permittee's public education
program is designed to address and why they are an issue."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
6. Describe target pollutants and target pollutant sources.
Describe the target
pollutants and target
pollutant sources the
permittee's public education
program is designed to
address and why they are
an issue.
1. Re-evaluate
target pollutant
sources.
2. Review and
update target
pollutant sources,
if needed, based
on previous year.
1. Permit Year 1
2. Annually, Permit
Years 2-5
1. Target
pollutants,
sources, and why
they are an issue
2. Target
pollutants,
sources, and why
they are an issue
Permit II.B.2.b: Describe target audiences
Ref. "Describe the target audiences likely to have significant storm water impacts and why they
were selected."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
7. Describe target audiences.
Describe the target
audiences likely to have
significant stormwater
impacts and why they were
selected.
1. Re-evaluate
target audiences
as needed to
address current
target pollutants.
1. Permit Year 1
1. Target
audience(s) for
each target
pollutant and why
they were selected
23
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Public• and Outreach
2. Review and 2. Annually, Permit
2. Target
update target Years 2-5
audience(s) for
audiences, if
each target
needed, based on
pollutant and why
previous year.
they were selected
Permit
II.B.2.c: Information Web Site
Ref.
"The permittee shall promote and maintain, an internet web site designed
to convey the
program's message."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
8.
Maintain Website with program information.
I
Promote and maintain an Maintain and Ongoing, Permit
Website analytics
internet website designed to promote the Years 1-5
convey the program's Stormwater
message. Program
webpages.
Permit
II.B.2.d: Distribute public education materials to identified user groups
Ref.
"Distribute general stormwater educational material to appropriate target groups as likely to
have a significant stormwater impact. Instead of developing its own materials, the permittee
may rely on state -supplied Public Education and Outreach materials, as available, when
implementing its own program."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
9.
Distribute public education materials.
Distribute general 1. Distribute 1. Ongoing, Permit
1. Number of
stormwater educational materials through Years 1-5
events for which
material to appropriate a variety of
materials were
target groups as likely to avenues such as
distributed and
have a significant public events,
approximate
stormwater impact. social media, and
number of
other virtual
participants or
platforms.
individuals
reached
2. Review 2. Annually, Permit
2. Note which
educational Years 2-5
material(s) were
materials and
updated or created
update or generate
new materials as
needed.
Permit
II.B.2.e: Promote and maintain Hotline(s) or Helpline(s)
Ref.
"Promote and maintain a stormwater hotline(s) or helpline(s) for the public to request
information about stormwater, public involvement & participation, and to report illicit
connections & discharges, etc."
24
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
OutreachPublic Education and
BMP
A B C
D
No.
Description of BMP Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
10.
Inform public of City Contact Center.
Inform public of City Contact Display 373-CITY Ongoing, Permit
Number of water
Center (336-373-CITY) as on relevant City Years 1-5
quality or pollution
an avenue to report issues webpages in
calls received by
and request information. prominent
City Contact
locations and on
Center
printed materials.
Permit
II.B.2.f: Implement a Public Education and Outreach Program
Ref.
"The permittee's outreach program, including those elements implemented locally or through
a cooperative agreement, shall include a combination of approaches designed
to reach the
target audiences. For each media, event or activity, including those elements
implemented
locally or through a cooperative agreement the permittee shall estimate and record the extent
of exposure."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
11.
Implement a public education and outreach program.
Implement a public Implement the Ongoing, Permit
Number of events
education and outreach public education Years 1-5
or activities and
program to reach the target and outreach
number of
audiences. For each activity program.
participants for
estimate and record the
each
extent of exposure.
25
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
6.0 PUBLIC INVOLVEMENT AND PARTICIPATION
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 Greensboro will manage, implement, and report the following public involvement and
participation BMPs.
Table 10: Public Involvement and Participation BMPs
Permit II.C.2.a: Volunteer community involvement program
Ref.
"The permittee shall include and promote volunteer opportunities designed
to promote
ongoing citizen participation."
BMP
A B
C
D
No.
Description of BMP Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
12.
Include and promote volunteer opportunities.
Include and promote Implement the
Ongoing, Permit
Number of
volunteer opportunities to City's volunteer
Years 1-5
volunteer
promote ongoing citizen community
opportunities and
participation. involvement
number of
program.
participants in
each
Permit
II.C.2.b: Establish a Mechanism for Public Involvement
Ref.
"The permittee shall provide and promote a mechanism
for public involvement that provides
for input on stormwater issues and the stormwater
program."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
13.
Provide a mechanism for public involvement.
Provide and promote a 1. Offer public
1. Ongoing, Permit
1. Y/N
mechanism for the public to comment period
Years 1-5
provide input on stormwater during bi-monthly
issues and the City's City Council
stormwater program. meetings.
2. Offer project
2. As needed
2. Y/N
specific public
Permit Years 1-5
meetings.
3. Offer
3. Within 6 months
3. Y/N
opportunity for
prior to permit
public review and
reissuance
comment during
permit reissuance
period.
it!
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Public Involvement and Participation
Permit
II.C.2.c: Establish a Hotline(s) or Helpline(s)
Ref.
"The permittee shall promote and maintain a hotline(s) or helpline(s) for the public to request
information about stormwater, public involvement participation, and to report illicit
connections & discharges, etc."
BMP
A
B
C D I
No.
Description of BMP
Measurable
Schedule for Annual Reporting
I
Goal(s)
Implementation Metric
14. Promote and maintain a stormwater hotline or helpline.
Inform public of City Contact Display 373-CITY Ongoing, Permit Number of water
Center (336-373-CITY) as on relevant City Years 1-5 quality or pollution
an avenue to report issues webpages in calls received by
and request information. prominent City Contact
locations and on Center
printed materials.
Permit
II.C.2.d: Public Review and Comment
Ref.
"The permittee shall make their most recent Stormwater Management Plans available for
public review and comment."
BMP
A
B
C D I
No.
Description of BMP
Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
15. Reference SWMP on City webpage.
Reference most recent Reference most Ongoing, Permit Website analytics
Stormwater Management recent SWMP on Years 1-5 (e.g., number of
Plan on City Stormwater Stormwater views)
webpage. webpage.
Permit
II.C.2.e: Public Notice
Ref.
"Pursuant to 40 CFR 122.34 the permittee must, at a minimum, comply with State, Tribal and
local public notice requirements when implementing a public involve ment/participatio n
program."
BMP
A
B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
16. Comply with applicable State, Tribal, and local public notice requirements.
Comply with State and City Provide Ongoing, Permit Y/N
public notice requirements opportunities for Years 1-5
when advertising public public input on
review and comment stormwater
opportunities or when program.
notifying public of other
opportunities to participate.
27
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
7.0 ILLICIT DISCHARGE DETECTION AND ELIMINATION
The City of Greensboro will develop, manage, implement, document, report, and enforce an IDDE
Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs.
Table 11: Illicit Discharge Detection and Elimination BMPs
DischargeIllicit Detection
Permit
II.D.2.a: Maintain appropriate legal authorities
Ref.
"Maintain adequate ordinances or other legal authorities to prohibit illicit connections and
discharges and enforce the approved IDDE Program."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
17. Maintain appropriate IDDE legal authorities.
Maintain ordinance to 1. Review and 1. Once per permit 1. Report any
prohibit and enforce illicit update ordinances cycle updates and
connections and as necessary. modifications.
discharges. 2. Review and 2. Once per permit 2. Report any
revise cycle updates and
enforcement of modifications.
standard operating
procedure (SOP)
as necessary.
Permit
II.D.2.b: Maintain a Storm Sewer System Base Map of Major MS4 Outfalls
Ref.
"The permittee shall maintain a current map showing major outfalls and receiving streams."
BMP
A
B
C
D
No.
Description of BMP Measurable Schedule for Annual Reporting
do
Goal(s) Implementation Metric
18.
Maintain MS4 base map of major MS4 outfalls. I
Maintain current map Review and Ongoing, Permit Report any
showing major MS4 outfalls update as needed Years 1-5 updates and
and receiving streams. modifications.
Permit
II.D.2.c: Inspection/detection program to detect dry weather flows at MS4 outfalls
Ref.
"Maintain written procedures and/or Standard Operating Procedures (SOPs) for detecting
and tracing the sources of illicit discharges and for removing the sources or reporting the
sources to the State to be properly permitted. Written procedures and/or SOPs shall specify a
timeframe for monitoring and how many outfalls and the areas that are to be targeted for
inspections."
BMP
A
B
C
D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
119. Maintain SOPS for finding and addressing illicit discharges.
28
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Illicit Discharge Detection and Elimination
Maintain and update IDDE Review and revise Once per permit Y/N
SOP. IDDE SOP as cycle
needed.
Permit II.D.2.d: Employee Training
Ref. "Conduct training for appropriate municipal staff on detecting and reporting illicit connections
and discharges."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
20. Provide training for IDDE staff.
Conduct municipal staff Staff training for Ongoing, Permit Training date(s),
training for IDDE program. IDDE Years 1-5 topics, and staff
names
Permit II.D.2.e: Maintain a public reporting mechanism(s)
Ref. "Maintain and publicize reporting mechanism(s) for the public to report illicit connections and
discharges."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
21.
Maintain IDDE reporting mechanism for the public.
Maintain and publicize Ensure reporting Ongoing, Permit Y/N
reporting mechanisms (e.g., mechanisms are Years 1-5
website, app, City Contact maintained,
Center 336-373-CITY) publicized, and
updated.
II.D.2.f: Documentation
Permit
Ref.
"The permittee shall document the date of investigations, any enforcement action(s) or
remediation that occurred."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
22.
Document IDDE program.
Document illicit connections
Document IDDE Ongoing, Permit Number of
and discharge inspections,
program activities. Years 1-5 investigations and
investigations, and
results.
resolution.
29
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
8.0 CONSTRUCTION SITE RUNOFF CONTROLS
The City of Greensboro's MS4 permit requirements pertaining to Construction Site Runoff Controls are
managed through the City's locally delegated Erosion and Sediment Control (E&SC) Program. The E&SC
program meets the standard for Construction Site Runoff Controls through permitting and controlling
development activities as authorized under the Sediment Pollution Control Act (SPCA) of 1973 and
Chapter 4 of Title 15A of the North Carolina Administrative Code. 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 City of Greensboro implements the following BMPs to meet NPDES MS4 Permit requirements for
Construction Site Runoff Controls.
Table 12: Construction Site Runoff Control BMPs
Permit II.E.2.a: "The permittee has a delegated or authorized Sediment and Erosion Control
Ref. Program. As such, to the extent authorized by law, the permittee is responsible for
compliance with the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the
North Carolina Administrative Code. The delegated or authorized Sediment and Erosion
Control Program effectively meets the MEP standard for Construction Site Runoff Controls by
permitting and controlling development activities disturbing one or more acres of land surface
and those activities less than one acre that are part of a larger common plan of development
as authorized under the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of
the North Carolina Administrative Code."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual
Goal(s) Implementation Reporting Metric
23. Conduct erosion and sediment control inspections. I
Conduct erosion and 1. Inspect 100% of 1. Annually, Permit 1. Number of
sediment control active sites. Years 1-5 inspections
inspections for all permitted completed
sites. 2. Issue Notice of 2. As needed, 2. Number of
Violation (NOV) if Permit Years 1-5 NOVs, number of
not in compliance. NOVs corrected
3. Issue stop work 3. As needed, 3. Number of stop
orders if not Permit Years 1-5 work orders
remedied.
4. Escalate 4. As needed, 4. Number of
enforcement Permit Years 1-5 enforcements,
process if NOV number of
not corrected. corrected actions
Permit II.E.2.b: "The NCGO10000 permit establishes requirements for construction site operators to
Ref. control waste such as discarded building materials, concrete truck washout, chemicals, litter,
and sanitary waste at the construction site that may cause adverse impacts to water quality."
A B C D
all
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Construction Site Runoff
Controls
11
Description of BMP Measurable
Schedule for Annual
Goal(s)
Implementation Reporting Metric
24.
Ensure NCG01 requirements are being implemented.
Ensure NCG01 Ensure 100% of
Ongoing, Permit Number of plans
requirements are added to plans are
Years 1-5 reviewed
construction site plans compliant.
including ground
stabilization and materials
handling worksheet,
seeding table with
timelines, self -inspection
requirements, and details.
Permit
II.E.2.c: "The permittee shall provide and promote a means for the public to notify the
Ref.
appropriate authorities of observed erosion and sedimentation problems. The permittee may
implement a plan promoting the existence of the NCDEQ "Stop Mud" hotline (1-866-
STOPMUD) to meet the requirements of this paragraph."
BMP
A
B
C
D
No.
Schedule for
Measurable
Description of BMP
Annual
Goal(s)
Implementation
Reporting Metric
25.
Maintain City Contact Center and E&SC webpage that links to Stormwater.
Maintain City of
1. Maintain 1. Ongoing, Permit
1. Y/N
Greensboro construction
webpage for Years 1-5
site runoff/erosion/land
E&SC
disturbance/grading
webpage and Contact
2. Y/N
2. Maintain City 2. Ongoing, Permit
Center (336-373-CITY)
reporting hotline Years 1-5
(373-CITY)
Permit
II.E.2.d: "For new development and redevelopment projects to be built within the permittee's
Ref.
planning jurisdiction by entities with eminent domain authority, the permittee shall, to the
maximum extent practicable, coordinate the approval of the construction site runoff control
with the DEMLR."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual
Goal(s)
Implementation
Reporting Metric
26.
Provide a mechanism to direct permittee to DEMLR.
Coordinate approval of Maintain process Ongoing, Permit Report any
construction site runoff for to direct applicant Years 1-5 changes.
entities with eminent to another
domain authority. jurisdiction where
appropriate.
31
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
9.0 POST -CONSTRUCTION SITE RUNOFF CONTROLS
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 Greensboro and discharge into the MS4. These elements are
designed to minimize water quality impacts utilizing a combination of structural SCMs and/or non-
structural BMPs appropriate for the community, and ensure adequate long-term operation and
maintenance of SCMs.
The City of Greensboro implements the following BMPs to meet NPDES MS4 Permit requirements for
Post -Construction Site Runoff Controls.
Table 13: Post -Construction Site Runoff Control BMPs
Post -Construction Site Runoff Controls
Permit
II.F.2.a: Post -Construction Stormwater Management Program
Ref.
"Maintain an ordinance (or similar regulatory mechanism) that authorizes a program to
address stormwater runoff from new development and redevelopment to the extent allowable
under State law."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for Annual Reporting
Goal(s)
Implementation Metric
27.
Maintain a post -construction Stormwater Management Ordinance.
Maintain City's post- Review ordinance Once per permit Report any
construction stormwater and revise as cycle updates and
management ordinance. necessary. modifications.
Permit
II.F.2.b: Strategies which include Stormwater Control Measures (SCMs) appropriate for
Ref.
the MS4
"Maintain strategies that include a combination of structural and/or non-structural SCMs
implemented in concurrence with (a) above. Provide a mechanism to require long-term
operation and maintenance of structural SCMs. Require annual inspection reports of
permitted structural SCMs performed by a qualified professional.
A qualified professional means an individual trained and/ or certified in the design, operation,
inspection and maintenance aspects of the SCMs being inspected, for example, someone
trained and certified by NC State for BMP Inspection & Maintenance.
Within 12 months of the effective date of this permit, the permittee shall evaluate, and revise
as needed, SCM requirements, to be at least as stringent as the minimum requirements in
15A NCAC 02H .1000."
BMP
A
B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
28. Ensure stormwater control measures (SCMs) are being implemented.
Implement TRC program to Reviewed plans Ongoing, Permit Y/N
review required SCMs. per ordinance. Years 1-5
32
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Post -Construction
29. Ensure long-term SCM 1Obtain executed Ongoing, Permit Y/N
maintenance through O&M O&M agreement Years 1-5
agreements. for each new SCM
30. Require routine inspection 1 Completed Ongoing, Permit Number of SCM
reports. inspections for Years 1-5 inspections
SCMs. completed
31.
Ensure City inspection staff City staff are Ongoing, Permit List of staff with
maintain qualified credentialed (e.g., Years 1-5 active certifications
professional status. North Carolina
State University
SCM Inspection &
Maintenance
Certification)
32.
Review and revise SCM Ensure SCM Ongoing, Permit Report any
requirements to be requirements are Years 1-5 updates and
consistent with NC rules. consistent. modifications.
I.F.2.c: Deed Restrictions and Protective Covenants
Permit
Ref.
"The permittee shall provide mechanisms such as recorded deed restrictions, plats, and/or
protective covenants so that development activities maintain the project consistent with
approved plans."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for Annual Reporting
Goal(s)
Implementation Metric
33. Ensure Deed Restrictions/Protective Covenants are recorded.
Maintain ordinance 1. Review 1. Once per permit 1. Report any
provisions which require ordinance and cycle updates and
plats and O&M agreements updated as modifications.
to ensure projects maintain needed.
consistency with approved 2. Implement 2. Ongoing, Permit 2. Report any
plans. standard language Years 1-5 updates and
on plats which modifications.
matches approved
plan.
Permit
II.F.2.d: Operation and Maintenance Plan
Ref.
"The developer shall provide the permittee with an operation and maintenance plan for the
stormwater system, indicating the operation and maintenance actions that shall be taken,
specific quantitative criteria used for determining when those actions shall be taken, and who
is responsible for those actions. The plan must clearly indicate the steps that shall be taken
and who shall be responsible for restoring a stormwater system to design specifications if a
failure occurs and must include a legally enforceable acknowledgment by the responsible
party. Development must be maintained consistent with the requirements in the approved
plans and any modifications to those plans must be approved by the Permittee."
A B C D I
BMP
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
34. Require O&M plans.
33
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Post -Construction
Require O&M plan for Ensure O&M plan
Ongoing, Permit Y/N
SCMs. and executed
Years 1-5
O&M agreement
for each approved
SCM.
Permit
II.F.2.e: Educational materials and training for developers
Ref.
"Provide educational materials and training for developers.
New materials may be developed
by the permittee, or the permittee may use materials adopted from other programs and
adapted to the permittee's new development and redevelopment
program."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for Annual Reporting
Goal(s)
Implementation Metric
35.
Provide education and training.
Provide educational 1. Maintain City
1. Ongoing, Permit 1. Y/N
materials to development website section
Years 1-5
community. dedicated to
developers and
contractors.
22. C Condu cdn uo cd t
2. Ongoing, Permit 2. Y/N
ongoing informal
Years 1-5
education through
plan review
process.
3. Conduct
3. Ongoing, Permit 3. Y/N
ongoing informal
Years 1-5
education through
local industry trade
groups (e.g.,
TREBIC (Triad
Real Estate
Building Industry
Coalition).
34
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
10.0 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR
MUNICIPAL OPERATIONS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City
of Greensboro's municipal facilities and operations. Pollution prevention and good housekeeping is
accomplished through the implementation of programs that 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.
This is achieved through the application of a suite of BMPs described below and managed in cooperation
with multiple City departments and facilities which may include, but is not limited to, the following:
• Coliseum
• Engineering and Inspections
• Field Operations
• Finance (Equipment Services)
• Fire
• Parks and Recreation
• Police
• Transportation
• Water Resources
Table 14: Pollution Prevention and Good Housekeeping BMPs
Permit II.G.2.a: Inventory of municipal facilities and operations
Ref. "Maintain an inventory of municipal facilities and operations owned and operated by the
permittee that have been determined by the permittee to have significant potential for
generating polluted stormwater runoff. Also maintain an inventory of municipally- owned
structural SCMs."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
36. Maintain inventory of municipal facilities and municipally owned SCMs.
Review and update list of 1. Review inventory 1. Annually, 1. Number of
municipal facilities and and update as Permit Years 1-5 municipal facilities
municipally owned SCMs. needed. and municipally
owned SCMs
2. Identify and 2. Once per
2. Updated
prioritize new and permit cycle
prioritized list for
existing facilities
new and existing
according to
municipal facilities
pollutant runoff
potential.
35
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Pollution ... Housekeeping
Permit
II.G.2.b: Inspection and maintenance program for municipal facilities and operations
Ref.
"Implement an inspection and maintenance program for facilities and operations owned and
operated by the permittee for potential sources of polluted runoff, including stormwater
controls and conveyance systems. The inspection program shall evaluate pollutant sources,
document deficiencies, plan corrective actions, implement appropriate controls, and
document the accomplishment of corrective actions. The maintenance program shall include
maintenance activities and procedures aimed at preventing or reducing pollutants generated
from municipal facilities and operations."
BMP
A
B
C D
No.
Description of BMP
Measurable
Schedule for Annual Reporting
Goal(s)
Implementation Metr
37.
Implement municipal facilities inspection and maintenance program.
Inspection and 1. Inspect municipal 1. Once per 1. Number of
maintenance of municipal facilities. permit cycle inspections
facilities and operations completed
2. Provide 2. Ongoing, as 2. Number of
recommendations needed inspections
for municipal resulting in
facilities resulting recommendations
from inspections.
3. Inspect 3. Ongoing to 3. Number of
municipally owned ensure inspections
stormwater SCMs. maintenance per completed
established
schedule
Permit II.G.2.c: Site Pollution Prevention Plans for municipal facilities
Ref. "Maintain and implement Site Pollution Prevention Plans for municipal facilities owned and
operated by the permittee that have been determined by the permittee to have significant
potential for generating polluted stormwater runoff that has the goal of preventing or reducing
pollutant runoff."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
38.
Maintain site pollution prevention
plans (SPPPs) for municipal facilities with pollution -
runoff potential.
Maintain/implement SPPPs
1. Review and 1. Once per 1. Y/N
for municipal facilities with
update list of permit cycle
significant runoff potential
municipal facilities
needing SPPPs.
2. Review, update, 2. Once per 2. List of facilities
and provide SPPPs permit cycle with reviewed or
to municipal updated SPPPs
facilities for
implementation.
WER
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
Pollution Prevention and ... Housekeeping
Permit II.G.2.d: Spill Response Procedures for municipal facilities and operations
Ref. "Maintain spill response procedures for municipal facilities and operations owned and
operated by the permittee that have been determined by the permittee to have significant
potential for generating polluted stormwater runoff."
BMP A B C D I
No. I
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
39. Maintain spill response procedures for high -priority municipal facilities. I
Ensure spill response 1. Review and 1. Once per 1. Y/N
procedures are current and update list of permit cycle
implemented. facilities requiring
SRPs.
2. Review, update,
and provide SRPs
to municipal
facilities for
implementation.
3. Train staff on spill
response
procedures.
2. Once per
permit cycle
3. Annually,
Permit Years 1-5
2. Facilities with
reviewed or
updated SRPs
3. List of staff
attending training,
dates of training,
and training topics
Permit II.G.2.e: Prevent or Minimize Contamination of Stormwater Runoff from all areas used
Ref. for Vehicle and Equipment Cleaning
"Describe measures that prevent or minimize contamination of the stormwater runoff from all
areas used for vehicle and equipment cleaning, including fire stations that have more than
three fire trucks and ambulances. Perform all cleaning operations indoors, cover the cleaning
operations, ensure wash water drains to the sanitary sewer system, collect wash water and
stormwater run-on from the cleaning area and provide treatment or recycling, or other
equivalent measures. If sanitary sewer is not available to the facility and cleaning operations
take place outdoors, wash water shall drain to an SCM for treatment, or else the cleaning
operations shall take place on or drain directly to grassed or graveled areas to prevent point
source discharges of the wash water into the storm drains or surface waters.
Where cleaning operations cannot be performed as described above and when operations
are performed in the vicinity of a storm drainage collection system, the drain is to be covered
with a portable drain cover during cleaning activities. Any excess standing water shall be
removed and properly handled prior to removing the drain cover.
Facilities that have three or fewer fire trucks and ambulances should attempt to comply with
the above requirements; however, those that cannot comply with these requirements due to
existing limitations shall incorporate structural measures during facility renovation to the
extent practicable."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
40. Document vehicle and equipment cleaning procedures. I
37
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Permit
Ref.
BMP
No.
41.
Describe measures to 1. Identify facilities 1. Once per 1. List of facilities
prevent or minimize where vehicles and permit cycle where vehicles and
pollution from vehicle and equipment are equipment are
equipment cleaning. cleaned. cleaned
2. Review 2. Once per 2. Report any
procedures for permit cycle updates and
cleaning vehicles modifications.
and equipment and
update as needed.
II.G.2.f: Streets, roads, and public parking lots maintenance
"The permittee shall implement BMPs to reduce polluted stormwater runoff from municipally -
owned streets, roads, and public parking lots within the corporate limits."
A
B
10
Description of BMP Measurable Schedule for
Goal(s) Implementation
Implement BMPs to reduce polluted stormwater runoff.
Reduce pollution from 1. Sweep 1. Ongoing,
streets, roads, and public designated streets, Permit Years 1-5
parking lots to the MEP. roads, and parking according to
lots. priority schedule
For additional information
on specific program
responsibilities, refer to the
City's most recent MS4
Operation & Maintenance
Plan.
2. Conduct
seasonal loose leaf
collection.
2. Ongoing,
Permit Years 1-5
according to
neighborhood
pickup schedule
D
Annual Reporting
Metric
1. Tons of material
collected
2. Tons of leaves
collected
3. Conduct loose
3. Ongoing, as
3. Tons of loose
litter collection.
needed
litter collected
4. Conduct periodic
4. Ongoing, as
4. Volume of water
street flushing
needed
used for flushing
Permit II.G.2.g: Inspection and Maintenance (I&M) for municipally -owned or maintained SCMs
Ref. and the storm sewer system
"The permittee shall maintain and implement an inspection and maintenance program for
stormwater control measures (SCMs) owned and operated by the municipality and the
municipal storm sewer system including catch basins, the conveyance system, and SCMs."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
42. I Inspect and maintain City -owned SCMs and the MS4.
Inspect and maintain 1. Inspect 1. Ongoing, per 1. Number of
municipally -owned SCMs. municipally owned SCM specific inspections
SCMs schedule completed
38
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Pollution
... Housekeeping
2. Provide
2. Ongoing, as
2. Number of
maintenance
needed
inspections
recommendations
requiring
for municipally
maintenance
owned SCMs
43.
Inspect and maintain MS4,
1. Inspect
1. Ongoing, per
1. Number of work
including catch basins and
municipally owned
schedule and
orders initiated
the conveyance system.
stormwater
upon reports of
conveyance
problems
For additional information
system.
on specific program
2. Maintain
2. As needed
2. Number of work
responsibilities, refer to the
municipally owned
based on
orders completed
City's most recent MS4
stormwater
inspection
Operation & Maintenance
conveyance
results
Plan.
system.
Permit
I.G.2.h: Staff training
Ref.
"Maintain and implement a training plan that indicates when, how often,
and who is required
to be trained and what they are
A
to be trained on."
B
C
D I
BMP
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
I
Goal(s)
Implementation
Metric
44.
Maintain and implement a Pollution Prevention and Good Housekeeping (PP/GH)
training plan.
Develop and implement
1. Train new
1. Within first 6
1. Number of new
PP/GH SOP which
employees on
months of hire
staff trained
incorporates staff training
PP/GH
plan.
2. Train current
2. Annually,
2. Number of staff
employees on
Permit Years 1-5
trained
PP/GH
39
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
11.0 PROGRAM TO MONITOR AND CONTROL POLLUTANTS IN
STORMWATER DISCHARGES TO MUNICIPAL SYSTEMS
The City of Greensboro's MS4 permit requires that the City monitor and evaluate stormwater discharges
to its MS4 system which originate from hazardous waste treatment, disposal, and recovery facilities, and
qualifying industrial facilities. The City addresses this requirement through the following BMPs.
Table 15: Program to Monitor and Control Pollutants BMPs
Program. Control Pollutants in Storm Water Discharges
Permit
II.H.2.a: Maintain an Inventory of Industrial Facilities
Ref.
"Maintain an inventory of permitted hazardous waste treatment, disposal, and recovery
facilities, industrial facilities that are subject to Section 313 of Title III of the Superfund
Amendments and Reauthorization Act of 1986 (SARA), and industrial facilities identified with
an industrial activity permitted to discharge storm water to the permittee's MS4.
For the purposes of this permit, industrial activities shall mean all permitted industrial
activities as defined in 40 CFR 122.26."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for Annual Reporting
Goal(s)
Implementation Metric
45. Maintain industrial facilities inventory.
Maintain an inventory of Review and Annually, Permit Y/N
facilities subject to Section maintain facility Years 1-5
313 of SARA Title III; inventory to
NPDES permitted industrial ensure all
facilities; and hazardous applicable facilities
waste treatment, disposal, are included
and recovery facilities.
Permit II.H.2.b: Inspection Program
Ref. "Identify priorities and inspection procedures. At a minimum, priority facilities include those
identified above in subsection II.1-1.2.a."
BMP
A
B
C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
46. Identify priorities and procedures for industrial facilities inspection program.
Identify priorities and Maintain Once per permit Y/N
inspection procedures. inspection SOP, cycle
review and update
as needed.
40
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
ProgramPollutants
Permit
II.H.2.c: Evaluate Industrial Facilities discharging stormwater to the City's MS4
Ref.
"The Permittee is required to evaluate control measures implemented at permitted hazardous
waste treatment, disposal, and recovery facilities, industrial facilities that are subject to
Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986
(SARA), industrial facilities identified with an industrial activity permitted to discharge storm
water to the permittee's MS4, or as identified as an illicit discharge under the IDDE Program.
For permitted facilities, the municipality shall establish procedures for reporting deficiencies
and non-compliance to the permitting agency. Where compliance with an existing industrial
stormwater permit does not result in adequate control of pollutants to the MS4, municipality
will recommend and document the need for permit modifications or additions to the permit
issuing authority.
For the purposes of this permit, industrial activities shall mean all permitted industrial
activities as defined in 40 CFR 122.26. For the purpose of this permit, the Permittee is
authorized to inspect the permitted hazardous waste treatment, disposal, and recovery
facilities as an authorized representative of the Director."
BMP
A
B
C D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
47. Establish procedures for reporting evaluation of industrial facilities.
Evaluate control measures Conduct Ongoing, per SOP Number of
implemented at permitted inspections based inspections
industrial facilities and on established conducted,
establish procedures for procedures number of
reporting deficiencies and documented in permitted facilities
non-compliance. SOP. reported to
NCDEQ
41
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
12.0 WATER QUALITY ASSESSMENT AND MONITORING
Per the City's MS4 permit, the primary objective for Water Quality Assessment and Monitoring is to
"[e]valuate the impacts of MS4 discharges on surface water quality" (11.1.1). To accomplish this objective,
the City implements the following BMPs.
Table 16: Water Quality Assessment and Monitoring BMPs
Permit 11.1.2.a: Water Quality Assessment and Monitoring Plan
Ref. "Maintain a Water Quality Assessment and Monitoring Plan. The Plan shall include a
schedule for implementing the proposed assessment and monitoring activities."
BMP
No.
48.
A
B
C
Description of BMP Measurable Schedule for
Goal(s) Implementation
Maintain a Water Quality Assessment and Monitoring Plan.
Maintain a Water Quality Review and revise Ongoing, Permit
Assessment and Monitoring the Water Quality Years 1-5
Plan including an Assessment and
implementation schedule. Monitoring Plan as
needed.
Annual Reporting
Metric
Report any
updates and
modifications
Permit 11.1.2.b: Water Quality Monitoring
Ref. "Maintain and implement the Water Quality Assessment and Monitoring Plan submitted to
DEMLR."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
49. Implement the Water Quality Assessment and Monitoring Plan.
Implement the monitoring
program per the Water
Quality Assessment and
Monitoring Plan.
Conduct water
quality monitoring
and data
evaluation as
documented in the
Water Quality
Assessment and
Monitoring Plan.
As described in
the Water Quality
Assessment Plan,
Permit Years 1-5
Brief summary of
implementation
42
City of Greensboro Stormwater Management Plan (Final) March 3, 2022
13.0 TOTAL MAXIMUM DAILY LOADS
As documented in Part II Section J of the City of Greensboro's MS4 permit, the City will determine
whether the MS4 discharges to receiving waters with a TMDL and identify the pollutants of concern,
utilize BMPs within the six minimum control measures and the City's TMDL Watershed Plan to meet the
assigned NPDES MS4 regulated stormwater WLA, and address the WLA assigned to the City to the
maximum extent practicable. The City is not expected to attain the water quality standards for the subject
receiving waters.
Table 17: Total Maximum Daily Loads (TMDLs) BMPs
Total Maximum Daily Loads
Permit II.J.2.a: Identify, describe and map watershed, outfalls, and streams
Ref. "Within 12 months the permittee shall prepare a plan that:
• Identifies the watershed(s) subject to an approved TMDL with an approved Waste Load
Allocation (WLAs) assigned to the permittee; and
• Includes a description of the watershed(s); and
• Includes a map of watershed(s) showing streams & outfalls; and
• Identifies the locations of currently known major outfalls within its corporate limits with the
potential of contributing to the cause(s) of the impairment to the impaired segments, to
their tributaries, and to segments and tributaries within the watershed contributing to the
impaired segments; and
• Includes a schedule (not to exceed 6 months) to discover and locate other unknown
major outfalls within its corporate limits that may be contributing to the cause of the
impairment to the impaired stream segments, to their tributaries, and to segments and
tributaries within the watershed contributing to the impaired segments."
BMP A B C D I
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
50. Identify, describe, and map TMDL watersheds, outfalls, and streams.
Identify, describe, and map 1. Identify, 1. Once per permit 1. Report any
TMDL watersheds, outfalls, describe, and map cycle updates and
and streams. TMDL watersheds. modifications.
2. Identify major 2. Ongoing, as 2. Number of
outfalls that needed major outfalls
contribute to within the TMDL
TMDL. watershed
3. Review 3. Annually, Permit 3. Number of
programs (IDDE, Years 1-5 additional major
outfall mapping, outfalls identified
etc.) for mapping
other unknown
major outfalls
within the TMDL
watersheds as
needed.
43
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Total Maximum Daily Loads
Permit
II.J.2.b: Evaluate existing measures
Ref.
"Within 12 months the Permittee's plan:
• Shall describe existing measures currently being implemented by the Permittee designed
to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of concern to the
MEP within the watershed to which the TMDL applies; and
• Provide an explanation as to how those measures are designed to reduce the TMDL
pollutant of concern.
• The Permittee shall continue to implement the existing measures until notified by the
Division."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
51. Evaluate existing TMDL wasteload allocation measures.
Evaluate existing TMDL 1. Review and 1. Once per permit 1. List of measures
wasteload allocation evaluate existing cycle
measures. list of TMDL WLA
measures.
2. Describe TMDL 2. Once per permit 2. Description of
measures that cycle TMDL measures
reduce the POC that reduce the
(Pollutant of POC
Concern).
3. Continue 3. Ongoing, Permit 3. Document
implementation of Years 1-5 which measures
TMDL WLA were implemented
measures.
Permit II.J.2.c: Assessment of available monitoring data
Ref. "Within 24 months the permittee's plan shall include an assessment of available monitoring
data. Where long-term data is available, this assessment should include an analysis of the
data to show trends."
BMP A B C D I
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
52.
Assess available monitoring data for TMDL watersheds.
Assess available TMDL
Review and Once per permit Brief summary
monitoring data for TMDL
assess available cycle report for TMDL
watersheds.
TMDL watershed POC
monitoring data.
44
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
Total Maximum Daily Loads
Permit
II.J.2.d: Monitoring Plan
Ref.
"Within 24 months the permittee shall develop a Monitoring Plan for the permittee's assigned
NPDES regulated WLA as specified in the TMDL. The permittee shall maintain and
implement the Monitoring Plan as additional outfalls are identified and as accumulating data
may suggest. Following any review and comment by the Division the permittee shall
incorporate any necessary changes to monitoring plan and initiate the plan within 6 months.
Modifications to the monitoring plan shall be approved by the Division. Upon request, the
requirement to develop a Monitoring Plan may be waived by the Division if the existing and
proposed measures are determined to be adequate to achieve the MS4's NPDES WLA to
MEP within the watershed to which the TMDL applies."
BMP
A
B
C
D
No.
Description of BMP Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
53. Maintain monitoring plan for TMDL waters.
Update monitoring plan for Review monitoring Once per permit Submit
TMDL waters if necessary. plan for TMDL cycle modifications to
waters and update NCDEQ for review
as needed.
Permit II.J.2.e: Additional Measures
Ref. "Within 24 months the Permittee's plan shall:
• Describe additional measures to be implemented by the permittee designed to achieve
the permittee's MS4's NPDES WLA and to reduce the TMDL pollutant of concern to the
MEP within the watershed to which the TMDL applies; and
• Provide an explanation as to how those measures are designed to achieve the
permittee's MS4's NPDES regulated WLA to the MEP within the watershed to which the
TMDL applies."
BMP
A
B
C
D
No.
Description of BMP
Measurable
Schedule for
Annual Reporting
Goal(s)
Implementation
Metric
54. Describe and explain additional TMDL WLA measures.
Describe and explain any 1. Describe any 1. Annually, Permit 1. Report any
additional TMDL wasteload new TMDL WLA Years 1-5 updates and
allocation measures. measures. modifications.
2. Explain how any 2. Annually, Permit 2. Report any
new TMDL Years 1-5 updates and
measures help to modifications.
reduce the POC.
Permit II.J.2.f: Implementation Plan
Ref. "Within 48 months the Permittee's plan shall:
• Describe the measures to be implemented within the remainder of the permit term
designed to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of
concern to the MEP; and
• Identify a schedule, subject to Division approval, for completing the activities.
• Implement the permittee's TMDL plan."
45
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
55. Implement TMDL watershed plan.
Implement TMDL watershed Review and Once per permit Report any
plan evaluate TMDL cycle updates and
watershed plan. modifications.
Permit II.J.2.g: Incremental Success
Ref. "The permittee's plan must outline ways to track progress and report successes designed to
achieve the MS4's NPDES regulated WLA and to reduce the TMDL pollutant of concern to
MEP within the watershed to which the TMDL applies."
BMP A B C D
&L— Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
56. Document incremental success in reducing POC.
Document ways to track Track progress Once per permit Brief summary
progress that achieves and report cycle report for TMDL
incremental successes in successes POC
reducing the POC. designed to
reduce POC.
Permit II.J.2.h: Reporting
Ref. "The permittee shall conduct and submit to the Division an annual assessment of the
program designed to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of
concern to the MEP within the watershed to which the TMDL applies. Any monitoring data
and information generated from the previous year are to be submitted with each annual
report."
BMP A B C D
No.
Description of BMP Measurable Schedule for Annual Reporting
Goal(s) Implementation Metric
57. Submit annual TMDL assessment report.
Annual TMDL assessment Annual Annually, Permit Brief summary
report. assessment and Years 1-5 report for TMDL
update of TMDL POC
report.
11
City of Greensboro Stormwater Management Plan (Final)
March 3, 2022
14.0 PROGRAM ASSESSMENT, REPORTING, AND RECORDKEEPING
14.1 Program Assessment
As required in Part III of the MS4 permit, the City will document implementation of this SWMP.
Components of documentation may include inspections, maintenance activities, educational programs,
monitoring and sampling, implementation of BMPs, enforcement actions, and other stormwater activities.
Documentation will be kept on file for at least five years and made available to NCDEQ upon request.
The SWMP will be reviewed on an annual basis and updated if necessary. Responsible divisions and/or
departments for each permit element will report to the Water Quality Section Supervisor during the annual
review if updates are required to program processes, goals, or metrics. The Water Quality Section
Supervisor will be responsible for incorporating these program changes into the SWMP. The City will
submit an annual report of the SWMP evaluation and monitoring information to NCDEQ as described
below.
14.2 Reporting and Recordkeeping
As required in Part IV.A of the MS4 permit, the City will retain records of monitoring information, including
all calibration and maintenance records, and copies of reports required by the permit for at least five
years from the date of the sample, measurement, report, or application.
As required in Part IV.B of the MS4 permit, the City will submit an annual report to NCDEQ that tracks
progress in implementing the SWMP. The annual report will include the following sections:
• Description of the status of implementation of the SWMP, including the development and
implementation of each major component of the SWMP for the past year
• Description and justification of any proposed changes to the SWMP
• Necessary changes to programs or practices for assessment of management measures
implemented through the SWMP
• Summary of data accumulated as part of the SWMP with an assessment of what the data
indicates
• Assessment of compliance with the permit, information on the establishment of appropriate legal
authorities, inspections, and enforcement actions
• Discussion of program funding
47