03_Annual Reports FY17-FY21

CITY OF GREENSBORO
NPDES MS4 STORMWATER DISCHARGE PERMIT
Permit # NCS000248
STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
2020/2021 Annual Report
Prepared for:
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Prepared by:
City of Greensboro
Water Resources Department - Stormwater Management Division
P.O. Box 3136
Greensboro, NC 27402-3136
FAF'"-
,IL-9-n
GREENSBORO
October 31, 2021

TABLE OF CONTENTS
Page
Executive Summary ------------------- 1
Significant Receiving Waters and Watersheds -------------------------------------------------------------------------- 1
Organizational Structure------ 3
Legal Authority---------- 4
5
Stormwater Quality Management Program Plan ----------------------------------------------------------------------------------- 6
Public Education and Outreach Program ----------------------------------------------------------------------------------- 6
BMPSummary Table ----------------------------------------------------------------------------------------------------- 6
TargetAudience -------------------------------------------------------------------------------------------------------------- 9
Identifying Pollutants and Target Sources -------------------------------------------------------------------- 10
Public Outreach Narrative Program ------------------------------------------------------------------------------- 10
Public Involvement and Participation ---------------------------------------------------------------------------------------- I I
BMP Summary Table 11
TargetAudience -------------------------------------------------------------------------------------------------------------- 12
Participation Program Narrative ------------------------------------------------------------------------------------ 12
Illicit Discharge Detection and Elimination ------------------------------------------------------------------------------
13
BMPSummary Table -----------------------------------------------------------------------------------------------------
13
Detection and Elimination ----------------------------------------------------------------------------------------------
14
Locating Priority Areas------------------------------------------------------------------
14
Removing Sources of Illicit Discharges ------------------------------------------------------------------------
15
Construction Site Stormwater Runoff Control 16
BMPSummary Table ----------------------------------------------------------------------------------------------------- 16
E&SC Plan Review 16
E&SC Program Implementation and Enforcement---------------------------------------- 16
Construction Site Inspections------------------------------------------------------------------------- 17
Post -Construction Stormwater in New and Redevelopment---------------------------------------------------- 18
BMPSummary Table ----------------------------------------------------------------------------------------------------- 18
Local Permit Issuance 20
-----------------------------------------------------------------------------------------------------
Structural SCM Operation and Maintenance ---------------------------------------------------------------- 21
Pollution Prevention/Good Housekeeping for Municipal Operations----------------- ----22
BMPSummary Table ----------------------------------------------------------------------------------------------------- 22
AffectedOperations------------------------------------------------------------------------------------------------------ 23
Training-------------------------------------------------------------------------------------------------------------------------- 23

Site Inspection and Evaluation of Facilities____ _________________________________________ 24
Maintenance and Inspections___________________________________________________________________25
Vehicular Operations-----------------------------------------------------------------------25
WasteDisposal-------------------------------------------------------------------------------------------------------------- 25
Program to Monitor and Evaluate Stormwater Discharges to the Municipal System ............ 26
BMP Summary Table---------------------------------------26
Water Quality Assessment and Monitoring Program --------------------------------------------------------------- 27
BMP Summary Table___-----------------------------27
Total Maximum Daily Load (TMDL)........................................................................................
28
BMPSummary Table -----------------------------------------------------------------------------------------------------
28
BMP Narratives
31
Identify, Describe and Map Watershed, Outfalls, and Streams ...................................
31
ExistingMeasures -----------------------------------------------------------------------------------------------------------
33
Additional Measures -------------------------------------------------------------------------------------------------------
34
Threatened or Endangered Species Protection Program ........................................................... 35

Stormwater Quality Management Program Plan (Stormwater Plan)
for
Greensboro's NPDES MS4 Discharge Permit
EXECUTIVE SUMMARY
The City of Greensboro's initial National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Discharge Permit (Permit Number NCS000248) became effective on
December 30, 1994. The North Carolina Department of Environmental Quality (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. This document includes a summary of NPDES stormwater quality management
programs and activities implemented, scheduled to be implemented, or completed during the July 1, 2020 -
June 30, 2021 permit term.
The City's NPDES Stormwater permit, and associated Stormwater Quality Management Program Plan
(Stormwater Plan), is designed to control the discharge of pollutants from the MS4 to the Maximum Extent
Practicable (MEP).
Significant Receiving Waters and Watersheds
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 towards
the Haw River, while a smaller portion of the City area drains south towards the Deep River. The North and
South Buffalo Creek Watersheds drain the majority of the City's central urbanized area eastward towards
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 131.94 square miles, represents just over 1% of the 9,322 square mile Cape Fear Basin.
Existing land uses within Greensboro are broadly classified in Table 1.
Table 1— Land Uses in the City of Greensboro
Land Use Classification
Approximate % within Corporate Limits
Residential
39%
Commercial
13%
Industrial
7%
Open Space/Wooded/Undeveloped
41%
Total (land use does not include public streets and water bodies)
100%
Table 2 shows a listing of the primary streams located within the City of Greensboro MS4 service area.
Water quality classifications of receiving streams are provided, along with their use support ratings and
key water quality challenges.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 1 of 35

Table 2 - Primary Receiving Streams within Greensboro Service Area (Upper Cape Fear River
Basin)
Receiving
Stream
Water Quality
Use
Support
Water Quality Issues
303(d) List
Stream Name
Segment
Classification*
Rating
Impaired biological
yes
Reedy Fork
Within
WS-III;NSW,
Impaired
integrity, Chlorophyll a,
Creek
corporate limits
WS-III;NSW CA
Turbidity
Brush Creek
Within
WS-III;NSW
Impaired
Impaired biological
Yes
corporate limits
integrity, Chlorophyll a
Horsepen
Within
WS-III;NSW,
Impaired biological
Yes
Creek
corporate limits
WS-III;NSW CA
Impaired
integrity
Fecal coliform,
Yes
North Buffalo
Within
WS-V;NSW
Impaired
Impaired biological
Creek
corporate limits
integrity, Zinc, Cooper,
NO2+NO3-N
South Buffalo
Within
Turbidity, Impaired
Yes
Creek
corporate limits
WS-V;NSW
Impaired
biological integrity,
Zinc
Yes
East Fork
Within
WS-IV, WS-
Impaired biological
Deep River
corporate limits
IV;CA
Impaired
integrity, Turbidity,
Fecal coliform
Water Quality Classifications:
NSW = Nutrient Sensitive Waters
WS = Water Supply classification (degree of protective measures).
C = Class C waters — general use category (maintain aquatic life and biological integrity, wildlife, secondary
recreation, etc.)
CA = Critical Area
** Use Support Rating (the degree to which the water body supports its designated uses):
FS = Fully Supporting
PS = Partially Supporting
NS = Not Supporting
NR = Not Rated
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 2 of 35

Organizational Structure
The Stormwater Management Utility is one of seven divisions of the City's Water Resources Department
(also including 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.
The following bullet points briefly document the overall organizational structure and functional
responsibilities of the City's Stormwater Plan. 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 substantive ways.
• 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 of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 3 of 35

• 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
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
(http://online.encodeplus.com/regs/greensboro-nc/doc-viewer.aspx#secid-144). 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 -storm water 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;
• 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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 4 of 35

Funding
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, along with the desire 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 non-structural 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 eleven 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
$14,0351803.00 Operations
Administration Management
6%1 3% Water Quality &
Monitoring
Planning & 7%
Engineering
Construction 3%
38%
Public Education &
Maintenance Awareness
24% 1%
Street
Cleaning
18%
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 5 of 35

STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
The following information is the City's stormwater quality management program plan (Stormwater Plan)
identifying programmatic measures to comply with the City's NPDES permit to the maximum extent
practicable. BMP summary tables for each of the regulatory areas are provided, along with narrative for
key programs and updates or accomplishments completed during the last permit year (July 1, 2020 - June
30, 2021).
Public Education and Outreach
BMP Summary
BMPs for Public Education and Outreach Program
BMP
Measurable Goals
Comments
Pollution
Distribute brochures through event
Stormwater SMART target pollution
Prevention
displays, billing inserts, volunteer
brochures (Litter and Trash, Pet Waste,
Brochures
participants, informational displays, field
Yard Waste, Pesticides, Household
representatives and direct mailings to
Chemicals, Vehicle Maintenance) were
target groups. Various issues addressed
displayed at 16 events to
include proper disposal of oil and other
approximately 492 individuals at
toxic materials, sediment and erosion
organized events attended by the City.
control issues, proper application and
Stormwater SMART brochures were
handling of fertilizers and pesticides, litter
also placed in the Water Resources
prevention, pollution reporting and
customer service area and replenished
awareness, etc. for different age groups.
as need thought out the year.
Website
Maintain the Stormwater Management
Throughout the year updates were
Website. Contains information about
made as needed.
pollution prevention, stormwater
http://www.greensboro-
technology and practices. Provides
nc.gov/stonnwater
contacts and forms for pollution reporting
and information requests.
Stormwater
Several videos have been created to
Stormwater SMART PSA's (30
Videos
educate residents and schoolchildren about
seconds each; Litter and Trash, Pet
various pollution prevention measures and
Waste, Yard Waste, Pesticides,
volunteer opportunities. Videos air
Household Chemicals, Vehicle
periodically on Greensboro Television
Maintenance) were adapted to meet
Network (GTN) that appears on the local
Greensboro's needs. They ran 29 times
cable affiliate, are located on the City's
during the Greensboro Grasshoppers
YouTube. These videos are aired on local
home games along with a "Don't Flush
stations 2, 8, 12 and audio versions aired
Wipes" animation" and our
on 98.7, 97.1, 93.1 and 101.1 and Twitter
"Grease Blob" video. In May,—56,193
ads as part of SMART's mass media
patrons attended and in June, —50,744
campaign. Videos were aired on My48 as
attended.
part of the Greensboro SWARM's
broadcasting asset and at Greensboro
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 6 of 35

71v1r J
1 QL1G - l.Urlllrt"Cu
Media
Campaign
Grasshopper home games.
Advertise on TV, cable, Facebook, and
Instagram about different Stormwater
related topics. In addition, advertise
pollution issues in the local Hispanic
newspaper La Noticia and in the City of
Greensboro resident newsletter "At Your
Service".
Videos played 9 times on My 48
during 4 Greensboro SWARM
basketball games reaching —20,000
households.
SMART's mass media campaign
(Litter and Trash and Pet Waste; 15
second and 30 second) outcomes
within Greensboro include TV/Cable
impressions (733,913), Radio
impressions (425,934) and Online
Display impressions (1,314,285) and
Twitter paid placement (71,785).
On the City's NextDoor, site 21 post
were stormwater information. Topics
included sanitary sewer report/sewer
overflow (1 post, —2,625 impressions),
waste reduction, litter prevention &
Adopt -a -Stream (6 posts, — 26,240
impressions), Pet Waste (2 posts,
—17,444 impressions),
Resources/Guilford Creek Week (3
post, — 18,317 impressions),
Salts/Fertilizer (2 posts, — 6992
impressions), FOG (3 posts, —12269
impressions ) and Flooding (2 posts,
—60,205 impressions) leaves (2 posts,
—20,737 impressions).
SMART's social media campaign
included:
59 Facebook posts, 1.9K posts clicks
and 368 fans; 41 Instagram posts, 345
engagements and 528 fans; in
Greensboro (6,666 Facebook activity,
4,633 Instagram activity, 10,117
Website activity).
La Noticia distributed 85,000
newspapers throughout the year with
stormwater education information
included. Topics included sanitary
sewer report/sewer overflow (3 ads),
Motor Oil (5 ads), litter prevention (4
ads), Adopt -a -Stream (7 ads), Pet
Waste (1 ad), Guilford Creek Week (1
ad), Fertilizer (2 ads), FOG (9 ads) and
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 7 of 35

BMP Summary Table — Continued
Flooding (11 ads). These ads are also
available online in the Newspaper.
Water bill inserts were sent to 85,000
households 16 times throughout the year
with stormwater education information
included. Topics included sanitary
sewer overflow prevention (1), loose-
leaf collection (3), waste reduction/litter
prevention (4), Adopt -a -Stream (1), Pet
Waste (2), Guilford Creek Week (1),
Fertilizer (1), FOG (3) and Flooding (2)
These newsletters are also available
online.
Helpline
Established a helpline for citizens to
21 Water Pollution Spills and Concerns
report pollution, address water quality
were reported via the city helpline. 14
and drainage concerns, as well as
Water Pollution events reported via
volunteer opportunities.
online form
270 visits to the Report Water Pollution
webpag_e
42 Drainage Concerns reported via
online form
365 visits to the Report Drainage
Concerns web a e
School and
Develop and present educational talks
Approximately 579 individuals were
Civic Group
and activities for schools and civic
reached by the City's Stormwater
Presentations
groups, including our Enviroscape
program at 22 in person and online
Model, stormwater drain model, and
events in addition to approximately 53
other educational tools.
individuals attending 2 programs.
Stormwater SMART delivered 167
educational nature notebooks to
Greensboro residents via direct mail,
teacher, and library distribution.
Targeted
Develop flyer /brochures to inform
Ongoing effort by the Stormwater
Commercial
businesses that have a potential of illicit
Program; program initiated in Mid -
Education
discharges or improper disposals to the
2003. See page 13 for details.
Initiative
stormwater conveyance system.
Watershed
Road signs have been installed at stream
Ongoing effort by the Stormwater
Signs
crossings identifying the watershed and
Program.
stream name.
Cooperative
The City of Greensboro seeks reasonable
Maintained partnerships, however serval
Efforts
opportunities to collaborate with
County positions have been vacant and
neighboring communities for joint
educational opportunities have been
educational programs. Previously the
limited due to COVID. Greensboro
partnership was with the Piedmont Triad
Public Library held a successful
Water Quality Partnership PTWQP
ecoEx lore outdoor program with —90
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 8 of 35

31vir auliuliary 1 dulc — l UMIrrueu
however; the city is now a member of
Stormwater SMART and receives direct
education and mass media services
through the partnership. The North
Carolina Cooperative Extension Services
and Guilford County Soil and Water
Conservation District are also partners in
Stormwater education
participants. During Guilford Creek
Week, we collaborated with SMART,
City of High Point & Guilford County
Soil and Water to facilitate 2 DIY rain
barrel workshops with 35 participants.
SMART facilitated (virtual) "Backyard
Habitats" a training for teachers to 7
individuals. Presented at the EENC and
Wilderness Education Association
conferences to 71 individuals and held
virtual summer readings (July & Aug)
for 84 individuals in conjunction with
Greensboro Public Libraries.
Distributed 245 NC Native wildflower
seed packets to Greensboro residents
with rain garden instruction cards.
During Guilford Creek week, SMART
coordinated Geocaching and engaged
37 Greensboro residents and 29
residents at a community cleanup in
Apache Park.
https://www.ptrc.org/services/regional-
planning/storrnwater-smart
https://www.ces.ncsu.edu/
https://www.guilfordcoun . nc. ovg /our-
county/planning-development/soil-and-
water-conservation
Target Audience
Current and future target audiences for stormwater education include:
1. General Public, especially homeowners — applies lawn care products, uses chemicals for home and
auto maintenance, makes decisions about drainage issues on their properties and participates in
volunteer opportunities.
2. Structural SCM Owners — maintenance issues and education about proper SCM maintenance and
responsibilities.
3. Industries — potential of water quality impacts due to improper material handling, improper
housekeeping practices and illicit discharges.
4. Commercial landscapers, restaurants, mobile washers, concrete companies, painters, drywall
installers, masons, automotive repair facilities and kennels — potential water quality impacts due to
illegal dumping of wastewater into storm drains and improper chemical handling and application.
5. Through the City's Education and Outreach programs, over 579 individuals were reached through
school programming, summer camps, library programs, and more. A new partnership with the
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 9 of 35

Greensboro's Waste Reduction and Recycling program on the social media platforms Facebook,
Twitter, & Instagram (@GSOGoesGreen) reached over 41,025 impressions (views). Stormwater
topics included Adopt -a -Stream and litter prevention programs/events and Household Hazardous
proper disposal information/events.
6. Through our partnership with Stormwater SMART, approximately 693 individuals were reached
through school programming, educational notebooks, seed packets, Geocaching, library programs,
and more. A robust social (Facebook & Instagram) media campaign landed 11,299 engagements
for 100 posts (all 28-member communities) with 10,117 visits to the Stormwater.org website and
the Fall and Spring mass media (video on TV/cable, radio, online display and paid Twitter)
campaign had 2,545,917 impressions. The June 2021 Geocaching event (an outdoor individually
paced option) for Creek Week reached 37 participants in Guilford County.
Identifying Target Pollutants and Sources
Target pollution sources for stormwater education include:
1. Illicit Connections — The discharge of non-stormwater into the stormwater conveyance system can
result in biological mortality in receiving streams due to discharges.
2. Improper Disposal — The discharge of used motor oil, oil & grease, organic materials (grass and
leaves), and various other pollutants into storm drains can be a problem on construction sites,
commercial and residential areas, etc.
3. Water Quality Monitoring — Routine water quality monitoring data will be evaluated to identify target
pollutants which impact water quality.
4. Pet Waste — Greensboro has developed a TMDL for fecal coliform for the portion of North Buffalo
Creek located within the jurisdictional limits. As a management measure, the City will generate
educational literature targeting pet owners on the need to pick up after their pet in order to protect
water quality. Additionally, staff has observed that a number of public parks and homeowner's
associations have installed pet waste bag dispensers and or signage to encourage proper disposal of
pet waste. As a part of the At Your Service newsletter, information was sent out to residents
regarding the proper way to dispose of pet waste.
Lawns and Gardens — Lawn care chemicals may enter storm drains due to improper application. Yard
waste may also be improperly placed into storm drains. These can create blockages in the stormwater
conveyance system and cause decreased dissolved oxygen in streams. The Clean Streams Program
educates commercial landscape professionals on the proper application of fertilizer and pesticides, as
well as aquatic pesticides. Commercial landscape professionals have an opportunity to receive
pesticide credit for successful completion.
6. Auto Repair Shops — Many auto repair shops have interior drains that have the potential to be
illicit connections (such as older buildings or sites that were previously a different business type).
As these locations are identified and dye -testing is conducted, owners and staff are made aware of
proper house -keeping practices, including awareness of interior drains and their resulting
destinations (i.e., either storm or sanitary sewers).
7. Mobile Auto Washers — car washing activities can generate potentially harmful wash water. An
educational and inspection program targeting mobile auto washers on containment, collection, and
disposal of wash water has been developed.
8. Restaurants — Many restaurants have Good Housekeeping issues related to disposal of cooking oil,
process wastewater generated by cleaning activities, and outdoor storage areas such as trash
dumpsters and grease containers that can adversely impact water quality. An educational and
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 10 of 35

inspection program targeting restaurants has been developed and implemented during this
reporting period.
Public Outreach Program Narrative
Outreach mechanisms are described in the BMP summary table above. Over the permit period,
Greensboro expects to reach the majority of the approximately 300,000 individuals in its MS4 service
area, as well as individuals in surrounding service areas. Everyone who receives a water/sewer bill will
occasionally receive stormwater education messages in the City's citizen newsletter, for example, the "At
Your Service" newsletter. Individuals are also periodically exposed to various stormwater related
messages that are shown on our local governmental broadcast station. For those who do not receive a bill
or do not read the newsletter, various media campaigns featured on TV, radio, and newspaper as well as
post on social media platforms (NextDoor, Facebook, Instagram, and Twitter). Combined together, the
media outlets are designed to reach the citizens of Greensboro. For citizens who speak Spanish, some
materials will be printed in English and Spanish. The City also utilizes a local Spanish radio station and
newspaper to deliver various educational messages.
Public Involvement and Participation
BMP Summary Table
BMPs for Public Involvement and Participation Program
BMP
Measurable Goals
Comments
Adopt -a -Stream
Developed an Adopt -a -Stream Program.
35 cleanups
Volunteers must pick up trash from their adopted
562 volunteers
segment of stream twice per year.
Drain Marker
Developed a Drain Marker Program. Volunteers
1 event
Program
have attached signs to Greensboro's storm drains.
20 drain markers installed
Adopt -a -Street
Developed an Adopt -a -Street Program.
42 cleanups
Volunteers must pick up trash from their adopted
301 volunteers
segment four times per year.
872 hours
Stormwater
Board established to help guide Stormwater
Stormwater Advisory Board
Advisory Board
program on important community issues.
reconvenes as needed to
address community issues.
Annual Clean-up
Promote the Great American Clean-up, NC Big
Cleanups promoted for the
Events
Sweep, and Guilford Creek Week.
Big Sweep (9/20/20-9/26/20),
the Winter Wipe Out
(2/13/21-2/28/21), Great
American Clean-up (4/17/21-
5/2/21), and Guilford Creek
Week (6/5/21-6/12/21) in
addition to GBI's events.
Poster Contest
Water quality, water conservation and soil
Due to Covid and the resulting
conservation poster contest available for
virtual learning format, the
elementary students in the Guilford County
contest was not held during
School System.
this reporting cycle.
Neighbor Woods
Developed a Neighbor Woods Program, which
Due to Covid, this program
Program
encourages community wide tree planting and re-
was canceled during this
vegetation efforts.
cycle.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 11 of 35

BMP Summary Table — Continued
Educational
Power of Wetlands (POW), Wonders of Wetlands
1 Project WET occurred in
Workshops
(WOW) and Project Water Education for
2/10/2021 and 13 attended.
Teachers (WET) workshops offered as a resource
This was a virtual workshop.
for educators.
Household
Promote proper disposal of harmful chemicals
2,059,962 lbs. of chemicals
Hazardous Waste
through the Household Hazardous Waste
were collected for Guilford
Collection
Collection Center.
County. Approximately 75%
is from City residents.
Fats, Oils, and
Program designed to prevent the excessive
Over 14,000 door hangers
Grease Inspection
introduction of oil, grease, and fats into the
were distributed and several
Program
sanitary sewer system and the wastewater
messages were posted to
collection system, which helps prevent sanitary
Nextdoor, and other social
sewer over flows.
media sites.
Target Audience
Target audiences for the public involvement program include representative age, ethnic, and economic
groups in Greensboro, from individuals to businesses. For local citizens who speak Spanish, some materials
to promote volunteer programs are printed in both English and Spanish. A local Spanish radio station and
newspaper will also be used for advertising on select campaigns.
Participation Program Narrative
The public is involved in the City's Stormwater Management Program. The following are ongoing
programs that are available in the community.
Public Hearings
Public hearings are held to address key programs, such as, stream corridor concerns in the
community including restoration projects. Additionally, City Council meetings serve as
public hearing opportunities.
Working with Citizen Volunteers Willing to Educate Others About the Program
As part of the drain marker program, for example, volunteers hang an information piece on
the mailboxes of neighborhood residents where drain markers are installed.
Volunteer Monitoring or Stream Clean-up Activities
As part of our Adopt -a -Stream Program, volunteers are asked to note stream conditions on
their reporting form. The volunteers are required to clean the stream twice per year. Many
also participate in the NC Big Sweep, along with many others who have not formally
adopted a stream.
Flood Advisory Committee
As part of the National Flood Insurance Program (NFIP) Community Rating System
(CRS), communities are challenged with reducing the impact of flooding on private and
public structures. The flood advisory committee was formed through a partnership with
Guilford County Planning Department to communicate important messages. Topics
covered include discussions about flood hazards, flood safety, flood insurance and vital
ways to protect property, and natural floodplain benefits.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 12 of 35

Illicit Discharge Detection and Elimination
The City of Greensboro maintains a program to identify and eliminate illicit discharges and improper
disposals from its MS4 service area.
BMP Summary Table
Ps for Illicit Discharge Detection and Elimination (IDDE Program
LBM
Measurable Goals
Comments
Implementation and
Enforce current Stormwater Management
Ongoing program
enforcement of
Ordinance (Chapter 30 of the Greensboro
(Water Quality Section)
Stormwater Management
Land Development Ordinance) requirements
Ordinance
pertaining to the illicit discharge and improper
dis osal ofpollutants and waste.
Stream water quality
Conduct routine chemical and physical water
Ongoing program
monitoring
quality sampling of major streams. Analyze
(Water Quality Section)
data, detect potential illicit discharges, and
prioritize locations for follow-up investigation.
Response and
Maintain dedicated helpline and field calls
Ongoing program
investigation of citizens'
related to pollution concerns and
(Water Quality Section,
concerns
environmental questions from citizens.
Public Education and
Provide staff response to pollution concerns.
Awareness Section, City
Contact Center
Develop and maintain
Create map and inventory procedures for the
Ongoing program
storm sewer system
collection of major outfalls that discharge to
(Operations Management
inventory base map of
waters of the State.
Section)
major outfalls
Maintain an inventory of
Maintain an inventory of major outfalls that
Inventory complete;
major outfalls that
discharges to waters of the State.
ongoing collection for
discharges to waters of
annexations and new
the State
developments
(Operations Management
Section
Establish procedures to
Establish and maintain procedures to identify
Ongoing program
identify and eliminate
and report failed septic systems or sanitary
(Water Quality Section)
failed septic systems and
sewer overflows to the appropriate agency
sanitary sewer overflows.
(County health department or local utility
department).
Maintain
Maintain procedures for detecting and tracing
Ongoing program
Inspection/detection
the sources of illicit discharges to the MS4 and
(Water Quality &
program to detect dry
for removing the sources.
Operations Management
weather flows at MS4
Sections)
outfalls
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 13 of 35

BMP Summary Table — Continued
Inter -departmental spill
Maintain cooperative agreement and improve
Ongoing program
response team
relationship with spill response team partners.
(City Fire & Police --
City Fire and Police are primary responders,
primary responders;
while Stormwater is a secondary responder to
Stormwater Management
assist in tracking spills and assessing
Division secondary
environmental damage as a result of
responders)
environmental emergencies.
Commercial/Business
Develop and implement education and
Ongoing program
education and inspection
inspection program to inform local businesses
(Water Quality Section)
program
of stormwater regulations, hazards of unlawful
discharges, and penalties for violations.
Education and outreach
Continue ongoing programs and develop new
Ongoing program
programs
programs to inform municipal employees,
(Water Quality Section,
local businesses, and the general public of the
Public Education and
hazards associated with illicit discharges and
Awareness Section)
improper disposal of pollutants and waste.
Detection and Elimination
Greensboro continues to implement a comprehensive program of stormwater ordinance enforcement,
water quality monitoring, education and outreach, spill and citizen complaint response, and formal
inspections in order to prevent, detect, address, and eliminate illicit discharges and improper disposals to
the storm sewer system and receiving waters. The ongoing detection and elimination program currently
includes the following specific tasks:
1. Conducting stream water quality monitoring activity and conducting immediate follow up
when the data suggests a water quality issue.
2. Maintaining venues for public reporting, including helpline via the Contact Center, website
reporting forms, app reporting form, etc.
3. Providing professional staff response to citizen reports and complaints.
4. Participating in cooperative spill response team with inter -governmental partners.
5. Implementing a formal commercial and business education and inspection program.
6. Conducting stormwater investigations at NPDES permitted industrial facilities.
7. Conducting field screening of NPDES MS4 outfalls to detect dry weather flows.
8. Educating and training municipal employees and public.
LocatingPriority Areas
To locate priority areas for illicit discharge investigations, Greensboro will continue to rely on a
combination of water quality monitoring, inspections, complaints or notifications from citizens and city
staff, and historical knowledge to locate and verify priority areas. Permanent sampling stations will
continue to be located within Greensboro's major watershed sub -basins, and field and laboratory water
quality parameters will be analyzed to detect potential illicit discharges and prioritize locations for follow-
up investigation.
Removing Sources of Illicit Discharges
Greensboro's Land Development Ordinance (Chapter 30) specifically prohibits the illicit discharge or
improper disposal of pollutants and waste to Greensboro's stormwater conveyance system and subsequent
receiving surface waters. This ordinance authorizes City staff to utilize enforcement action, when
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 14 of 35

necessary, to stop an illicit discharge, remove the source, and require cleanup of the impacted area.
According to Stormwater's Administrative Procedures for Completing an Enforcement Action, the source
of an illicit discharge may be removed through a series of educational efforts, written Notices of
Violations (NOV), or progressing to civil penalty, if necessary. Once the source and responsible party of
an illicit discharge or improper disposal is identified, an appropriate educational letter or NOV is mailed.
Discontinuation of the discharge is required by the NOV, and the responsible party is required to reply in
writing to Stormwater staff detailing efforts taken to discontinue the unlawful activity and prevent the
activity from occurring in the future. Staff then conducts a follow-up investigation to ensure compliance.
During the July 1, 2020, to June 30, 2021, reporting period, 116 illicit discharges, improper disposals,
spills, or other pollution concerns were reported and investigated, 23 of which resulted in an issuance of a
Notice of Violation (enforcement action). In addition, high fecal coliform results from routine sampling
resulted in follow-up sampling at ten sites. Two of these led staff to the resolution of sanitary sewer
overflows (SSOs).
In addition to the standard citizen reporting procedure such as the City Call Center, City Stormwater
program has an inspection and education program that proactively addresses small commercial businesses
that are identified as having the potential to impact water quality. During the July 1, 2020, to June 30,
2021, reporting period, educational material for horizontal directional drillers was finalized, and more
than 30 drillers have received this information. Staff is working with other divisions in Water Resources
to identify businesses contracted for this type of work in order to educate the companies and inspect their
on -site best management practices.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 15 of 35

Construction Site Stormwater Runoff Control
The City of Greensboro has a locally delegated Erosion and Sediment Control (E&SC) Program
implemented by the Erosion and Sediment Control Section of the Engineering and Inspections Department.
The E&SC Section is responsible for erosion control plan review, grading permits, erosion control
inspections, enforcement, and review of permanent stabilization of commercial development. A Chief E&SC
Inspector and two field inspector(s) comprise the section.
BMP Summary Table
BMPs for Construction Site Stormwater Runoff Control
BMP
Measurable Goals
Comments
Plan Review, Enforce current
Ongoing program
Water Resources Dept,
E&SC ordinances.
implementation and
Stormwater Management
enforcement. The locally
Division, E&SC Section.
delegated program is regulated
by the NCDEQ, Division of
Energy, Mineral and Land
Resources
E&SC Plan Review
In the City of Greensboro, any proposed land disturbance of one or more acre, including common plans of
development that add up to a total of one or more acre, requires a grading permit prior to any land
disturbance. For sites requiring a grading permit, a plan submittal consisting of a grading permit
application, financial responsibility ownership forms, erosion and sediment control plans, and calculations
are required. Plan approval is also required either through the City's Technical Review Committee, or
through a grading only process that consists of limited reviewers from the Technical Review Committee
prior to grading permit issuance. Once plans are reviewed and approved, a pre -construction meeting is
scheduled and a letter of approval is provided to the financially responsible party. As of April 1, 2019,
information is provided to the permittee on the requirement to obtain a NC DEQ issued certificate of
coverage for the NPDES NCGO1 permit.
During the onsite pre -construction meeting, the representative from the erosion and sediment control
section reviews local, state and federal requirements with the permittee prior to issuing the grading
permit. The City then requires and verifies that the certificate of coverage for the NPDES NCGO1 permit
is attached to the grading permit located in the permit box. The City also ensures that temporary erosion
and sediment control measures are installed, inspected, and accepted prior to mass grading of the site.
The City of Greensboro also stipulates that any development resulting in less than one acre of land
disturbance indicate proper erosion and sediment control measures on the site plan. These plans are
reviewed and approved by the erosion and sediment control section during the technical review process.
Therefore, all sites developed that go through the City's Technical Review Committee are reviewed for
compliance with erosion and sediment control regulations.
E&SC Program Implementation and Enforcement
The City of Greensboro employs a variety of mechanisms to ensure compliance with the provisions of the
Soil Erosion and Sedimentation Control ordinance. First, no site will be issued a grading permit until the
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 16 of 35

plan reviewer is certain that necessary sediment and erosion control measures are adequately detailed on the
construction documents. Prior to issuing a grading permit for any site disturbing one acre or more, the City
Code requires that the owner/contractor post a bond. Prior to issuing a grading permit for any site disturbing
one acre or more, City Code requires that the owner/contractor post a bond. If a contractor begins land
disturbance without the required permits, appropriate City staff will issue a stop work order.
Should the field inspector identify deviations from the approved plan during construction, the inspector
may provide an inspection report to the owner and contractor indicating required measures and allowable
timeframe to bring the site into compliance. If the required items are not addressed within the appropriate
time, the inspector may issue a notice of violation (NOV) to the owner. A monetary fine may accompany
the NOV. If the required measures are still not addressed as indicated in the NOV, the inspector may
issue a stop work order. Additionally, the City of Greensboro reserves the right to deny the issuance of a
certificate of occupancy for sites that continue to remain in nonconformance with the erosion and
sediment control regulations.
Construction Site Inspections
Site inspections to ensure that proper erosion control measures are provided on construction sites are
conducted by qualified field inspectors. Each inspector represents a specific area of the City and inspects
sites within this area. Sites may be inspected more often depending on specific site conditions, the
progress of construction, citizen complaints and/or previously identified problems.
As site inspections may occur more frequently based on several factors, these same factors apply to the
prioritization of site inspections. Specific site conditions, contractor experience, citizen complaints,
previous inspections and the progress of construction all impact which site is given priority for inspection
on a more frequent basis. During the site inspection, the field inspector ensures that erosion and sediment
control measures are implemented according to the approved plan and that no significant offsite
sedimentation is occurring. If the inspector recognizes a problem in the field, the inspector may require
that additional erosion control measures be installed and maintained in accordance with established
enforcement procedures.
Included in the chart below is the data on the number of inspections and enforcement actions carried out by
the E&SC Section during the period of July 1, 2020 to June 30, 2021.
INSPECTIONS
Reporting Period: July 1, 2020, to June 30, 2021
Universe of active construction
sites
278
Number of active construction
sites ins ected
278
Number of construction sites
found to be non -compliant after
the initial inspection
7
Number of follow-up
inspections
7
ENFORCEMENT
Reporting Period: July 1, 2020 to June 30, 2021
Number of informal enforcement actions noncompliance
7
Number of formal enforcement actions without penalty
2
Number of formal enforcement actions with penalty
5
Number of stop work order issued
5
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 17 of 35

Post -Construction Stormwater Management for New Development and
Redevelopment
The City of Greensboro enforces local stormwater management and riparian buffer regulations in addition to
State approved water -supply watershed protection regulations. Throughout the NPDES permit compliance
period, the City of Greensboro will review existing ordinances and, if necessary, develop and implement
revised ordinances in order to implement the post -construction stormwater management program with the
goal of further minimizing impacts to surface water quality. 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.
BMP Summary Table
BMPs for Post -Construction Site Stormwater Runoff Controls
BMP
Measurable Goals
Comments
Post -Construction
Develop and adopt by ordinance a
The ordinance was adopted by
Stormwater Management
program to address stormwater
City Council on April 7, 2009 and
Program
runoff from new development and
became effective June 1, 2009.
redevelopment within 24 months
of the permit issue date.
Strategies which include
Developed strategies that include a
City of Greensboro Stormwater
BMPs appropriate for the
combination of structural and/or
Management Manual requires any
MS4
non-structural SCMs implemented
proposed structural SCM be
in concurrence with (a) above.
accompanied by an operation and
Provide a mechanism to require
maintenance plan and agreement
long-term operation and
concurrent to development plan
maintenance of structural SCMs.
approval. The city has an
Require annual inspection reports
extensive inspection program to
of permitted structural SCMs
ensure SCM's are maintained to
performed by a qualified
protect water quality.
professional.
Establish nutrient sensitive
Develop, adopt, and implement an
The Greensboro Land
waters (NSW) protection
ordinance to ensure that the best
Development Ordinance was
measures (for programs
management practices reduce
reviewed and modified to ensure
with development or
nutrient loading to the maximum
structural and non-structural
redevelopment draining to
extent practicable. In areas where
SCMs reduce nutrient loading to
NSW waters)
the Environmental Management
the maximum extent practicable.
Commission has approved a
Nutrient Sensitive Water Urban
Stormwater Management Program,
the provisions of that program
fulfill the nutrient loading
reduction requirement.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 18 of 35

BMP Summary Table — Continued
Deed Restrictions and
Protective Covenants
Impose or require recorded deed
restrictions, plats, and/or
protective covenants that ensure
development activities will
maintain the project consistent
with approved plans.
Current City of Greensboro Land
Development Ordinance requires
a maintenance note and recorded
maintenance agreement to be
placed on final plats stating the
maintenance responsibilities,
consistent with approved plans,
for the project SCM.
Establish a program under the
Coordinate with County health
Stormwater Division coordinates
Post -Construction minimum
department to control the known
with Guilford County Health
measure to control the sources
sources of fecal coliform from
Department to control the known
of fecal coliform to the
septic systems to the maximum
sources of fecal coliform from
maximum extent practicable.
extent practicable.
septic systems within the City's
jurisdictional limits to the
maximum extent practicable.
Additionally, the City's Water
Resources Department funds and
performs an ongoing sewer
rehabilitation program to
minimize and eliminate cross
connections between the storm
and sanitary sewer systems.
Operation and Maintenance
Require an operation and
City of Greensboro Stormwater
Plan
maintenance plan that ensures the
Division's development plan
adequate long-term operation of
review process requires a
the structural SCMs required by
stormwater management plan
the program. The operation and
and separate SCM operation and
maintenance plan may require the
maintenance plan (consistent
owner of each structural SCM to
with the provisions outlined in
submit a maintenance inspection
the State stormwater design
report on each structural SCM
manual) be submitted prior to
annually to the local program, or
receiving development plan
the maintenance inspections may
approval. Currently, the City of
be conducted annually by the
Greensboro Stormwater Division
Permittee.
conducts maintenance
inspections on SCMs within the
City's jurisdiction.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 19 of 35

BMP Summary Table — Continued
Educational materials and
Provide educational materials
Water Resources Stormwater and
training for developers
and training for developers. New
Engineering Divisions notify
materials may be developed by
developers and engineers of
the permittee, or the permittee
ordinance changes via direct
may use materials adopted from
phone and e-mail, face-to-face
other programs and adapted to
meetings upon request regarding
the permittees new development
proposed site projects, Triad
and redevelopment program.
Real Estate and Building
Industry Coalition, televised City
Council meetings, providing
opportunity for public comment,
as well as posting the changes on
the City website.
Setbacks for Built -upon Areas
Require built -upon areas to be
The Greensboro Land
located at least 50 feet landward
Development Ordinance was
of all perennial and intermittent
reviewed and modified to require
surface waters except as provided
a 50 foot stream buffer in
for in the Permittees Post-
accordance with NPDES phase II
Construction Stormwater
requirements.
Ordinance. For purposes of this
In addition, the City of
section, a surface water shall be
Greensboro has updated the
present if the feature is shown on
riparian buffer requirements
either the most recent printed
according to the Jordan and
version of the soil survey map
Randleman Lake Rules. The
prepared by the Natural
"Table of Activities and
Resources Conservation Service
Structures in Stream Buffers
of the United States Department
(Zone 1 & Zone 2)" located in
of Agriculture or the most recent
Chapter 30 of the Greensboro
version of the 1:24,000 scale (7.5
Land Development Ordinance
minute) quadrangle topographic
determines the allowable uses
maps prepared by the United
within the 50' riparian buffer.
States Geologic Survey (USGS).
Relief from this requirement may
be allowed when surface waters
are not present in accordance
with the provisions of 15A
NCAC 02B .0233(3) (a).
Local Permit Issuance
Currently, Group, Site and Subdivision plans within Greensboro's jurisdiction are reviewed by the City's
Technical Review Committee (TRC) for compliance with applicable development regulations. TRC is an
interdepartmental team charged with enforcing development standards as they relate to Watershed
Protection, Stormwater Management, Water -Supply, Water Reclamation, Zoning, Transportation, Parks
and Recreation, Tree Preservation, etc. Approval by members of TRC is a prerequisite to the issuance of
a grading permit or building permit. The City has reviewed and modified the Greensboro Land
Development Ordinance in order to ensure that plans meet post -construction stormwater management
requirements as defined by 15A NCAC 2H.0126 (10). The final 15A NCAC 211.0126 (10)(h) rules define
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 20 of 35

low and high density development thresholds and as such these thresholds and any associated permanent
structural control and riparian buffer requirements will be applied to applicable new development or re-
development within the City's jurisdictional area. These requirements have now been incorporated in the
Greensboro Land Development Ordinance to allow for enforcement by City staff prior to issuance of the
applicable construction permit. The post -construction stormwater requirements were adopted by City
Council on April 7, 2009 and became effective June 1, 2009. Additionally, the City amended the Land
Development Ordinance and adopted Jordan Lake Riparian Buffer requirements on November 9, 2010.
These rules became effective on December 1, 2010.
Structural SCM Operation and Maintenance
Greensboro mandates that all required structural stormwater control measures (SCMs) be placed in a
drainage maintenance and utility easement (DMUE) connected to the public right-of-way by a 20 foot
wide access easement. The DMUE and access easement for each SCM must be platted before any
certificate of occupancy is issued for the site. TRC-approved development plans for structural SCMs
include an operation and maintenance plan (consistent with the provisions outlined in the State minimum
design criteria) be submitted prior to receiving development plan approval. Furthermore, notes are
recorded on the plat indicating that the City has the right to access the site for SCM inspections and that
the owner will maintain the SCM per the approved maintenance plan or as directed by the City.
During the reporting period (July 1, 2020 to June 30, 2021), 319 privately owned SCMs were inspected
by City staff for performance and maintenance compliance. Four owners were issued a Notice of
Violation (NOV) for failing to complete the required maintenance items. Of the four sites with NOVs,
two have completed the required SCM maintenance. The city is working with the property owners,
through enforcement procedures, to complete maintenance items on the two remaining SCMs.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 21 of 35

Pollution Prevention/Good Housekeeping for Municipal Operations
Pollution Prevention and Good Housekeeping Programs are an important factor in the improvement of
stormwater runoff quality. Municipal departments that utilize various facilities currently implement good
housekeeping and pollution prevention programs. Additionally, the City Water Resources Department
works to ensure that pollution prevention and good housekeeping measures are being implemented at
other municipal facilities to the maximum extent practicable with the intent of improving stormwater
runoff quality discharged into receiving streams by those municipal facilities and their operations.
BMP Summary
BMPs for Pollution Prevention/Good Housekeeping Program
MP
Measurable Goals
Comments
Street Sweeping
Continue ongoing program with periodic
Ongoing program:
review.
Stormwater Management
and Field Operations
Department.
Loose Leaf Collection for
Continue ongoing program with periodic
Ongoing program:
Composting
review.
Stormwater Management
and Field Operations
Department.
Erosion and
City owned or otherwise public
Ongoing program:
Sedimentation Control
construction sites are regulated by NCDEQ,
City owned and other
Division of Energy, Mineral and Land
publicly funded projects
Resources for proper erosion and sediment
obtain appropriate state
control.
permits.
Staff Training/Site
The Stormwater Management Division of
Ongoing cooperative effort
Operator Education
Water Resources distributes education
by the City's departments
material for training employees on various
municipal operations.
Site Planning/Pollution
Develop and implement pollution
Ongoing effort by the City
Prevention Plan for
prevention plans that have been determined
of Greensboro.
Municipal Facilities
to have the potential to impact Water
Quality.
Site inspection and
The City maintains mapping programs that
The City's Stormwater
evaluation of facilities,
consist of all municipal facilities, as well as
Management Division has
operations including the
any related structural SCMs. City
identified a list of specific
MS4 system and
Stormwater Management maintains an
city facilities and ranked
associated structural
ongoing inspection program to monitor,
each of them according to
SCMs.
document and enforce stormwater
their potential to pollute.
discharges to the MS4 system.
Inspections of the high and
medium ranking facilities
have been conducted,
including documenting
areas where improvements
can be made to reduce the
potential of generating
polluted runoff.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 22 of 35

Affected Operations
The facilities listed in the following table are municipal operations that have been issued NPDES
Stormwater Discharge permits. These facilities have developed Municipal Pollution Prevention/Good
Housekeeping techniques in addition with the education and training material sent out.
Municipal Operation
Permit Number
City of Greensboro White St. Landfill
NCG 120013
TZ Osborne WWTP
NCG110005
Patton Avenue Service Center
NCGO80799
Greensboro Transit Authority (Bus Garage)
NCGO80893
Traininiz
The City's Stormwater Management Division of Water Resources provides educational and technical
assistance for City facilities pertaining to pollution prevention plans and/or BMPs for the improvement of
overall environmental quality. In addition, the Stormwater Management Division also provides assistance
for City facilities pertaining to structural and non-structural stormwater BMPs for the improvement of
stormwater quality and/or quantity and BMP design and implementation.
The City has identified nine Departments that have a greater potential to contribute pollution to
stormwater runoff. The Departments involved in this program are as follows:
1. Coliseum
2. Engineering and Inspections
3. Field Operations
4. Finance (Equipment Services)
5. Fire
6. Parks and Recreation
7. Police
8. Transportation
9. Water Resources
During the July 1, 2020 to June 30, 2021 reporting period, approximately 804 City of Greensboro
employees received training on municipal pollution prevention. This number includes our in house
stormwater pollution prevention DVD, Water Resources employee's training videos and the Fire
Department's in-depth annual training of personnel on spill response and pollution prevention.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 23 of 35

City of Greensboro: Municipal Pollution Prevention
Good Housekeeping Employee Training Participation
■ Water Resources
■ Coliseum
■ Finance(Equipment Services)
■ Parks & Recreation
■ Field Operations*
Total: 804 Employees Trained
Collectively, it is the responsibility of the entire City of Greensboro to maintain the NPDES citywide
permit and enforce programs collaboratively. The objective is for all municipal departments that engage
in various operations to implement good housekeeping and pollution prevention methods in everyday
activities and to set a good example for the community to follow.
Site Inspection and Evaluation of Facilities
Stormwater personnel focused on site inspection and evaluation of city owned and operated facilities. A
complete list of all City owned and operated facilities was obtained from a GIS layer file. To prioritize
each facility, the history of spills/concerns, the proximity to a stream or stormwater conveyance system,
and the activities at a particular location were considered when ranking each facility as High, Medium or
Low. This ranking is further defined below.
High: Facilities in this category would have a large amount of outdoor processing activities, close
proximity to a stream and/or material storage on -site or obvious poor housekeeping issues.
Examples of these facilities would be golf courses, satellite fueling stations, facilities that
store salt for deicing roadways or the Coliseum that has many vendors using this property
at all times.
Medium: This category includes facilities that have some outdoor storage or processing, that may
not be in close proximity to a stream. Examples of these type facilities would be larger
parks, the science center, water treatment plants and the fire training center.
Low: A facility in low level ranking would have limited or no outdoor processing areas.
Examples of these facilities would be libraries, parking decks, rec centers and fire stations.
During the July 1, 2020 to June 30, 2021, reporting period, the stormwater management division
continued to inspect the high or medium risk ranked city owned facilities (listed below). All
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 24 of 35

recommendations and improvements made at these facilities were documented in the respective facility
files.
Municipal Operation
Rank
Fire Station #1
H
Carolyn Allen Park
M
Greensboro Cultural Center
M
Greensboro Curb Market
M
Lake Townsend Water Treatment Plant
M
Maintenance and Inspections
The City of Greensboro Stormwater Maintenance Section, within the City's Field Operations Department,
maintains open and closed stormwater infrastructure and drainage conveyance systems that carry public
runoff within the MS4 service area. This section also performs stream maintenance activities and
preventative maintenance on most public stormwater infrastructure.
The City's Stormwater Management Division identifies and inspects industrial and related facilities that
may discharge stormwater into either the MS4 or receiving streams in Greensboro, and assists the local
industrial community in the development and implementation of appropriate stormwater runoff controls.
In addition, the City has an ongoing litter pick-up program to clear trash and other floatables from
roadways, which helps keep them out of the storm drainage system and surface waters.
Vehicular Operations
The City of Greensboro's vehicular operation centers utilize the City's hazardous waste program to
recycle or dispose used oil, antifreeze, batteries, and spare parts and used chemicals. A new salt storage
barn was constructed in fall 2002 as a BMP to prevent salt stormwater runoff from entering receiving
streams.
Waste Disposal
Waste materials generated from the City's day-to-day activities are managed according to local and state
regulations and vendors utilized by Greensboro are audited to ensure environmental compliance. With
the ongoing public education and awareness programs, the City will continue to facilitate staff meetings to
inform staff of all new and related regulations/programs corresponding with the Municipal Pollution
Prevention and Good Housekeeping Program.
Examples of Waste Disposal Programs include:
• Hazardous Waste Program
• Solid Waste Recycling
• Lead Disposal Program
• Oil Disposal Program
• Water Treatment Chemicals Disposal Program
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 25 of 35

Program to Monitor and Evaluate Storm Water Discharges to the Municipal System
The City of Greensboro has developed and implemented an industrial facilities inspection program during
the first two permit terms. During the current permit term, the inspection program will be reviewed and
revised to reflect current permit conditions. Industrial facilities subject to Section 313 of Title III of the
Superfund Amendments and Reauthorization Act of 1985 (SARA), and industrial facilities that the City
determines to be contributing or have the potential to contribute a substantial pollutant loading to the
municipal separate storm sewer system will be inventoried and evaluated.
BMP Summary Table
BMPs for Monitoring and Evaluating Storm Water Discharges to the MS4
BMP
Measurable Goals
Comments
Maintain Inventory of Industrial Sites
The City maintains an
The City will update and
inventory of all NPDES
revise list annually.
permitted industrial facilities.
The City will add additional
facilities to list that meet the
SARA Title III (Section 313)
criteria or that contribute
substantial pollutant loading
to the MS4 system.
Inspection Program
The City has developed a
The City has an ongoing
formal inspection program
industrial inspection program
for evaluating industrial
with a goal of visiting all
facilities. This inspection
listed industrial facilities once
program will be expanded to
per permit cycle. Annual
include any facility on the
training is conducted for City
above stated list.
staff on specific inspection
procedures and staff
coordinates with NCDEQ on
a regular basis to be trained
on any issues or permit
updates.
Establish and Implement Measures to
The City has developed the
The City has a strong working
Evaluate Commercial and Industrial
industrial facilities inspection
relationship with the NCDEQ
Facilities discharging stormwater to
program to evaluate those
regional office and county
the City's MS4
facilities on the above list
officials. The City's
and ensure all permit
enforcement procedures are
conditions are being met and
utilized when water quality
discharges to the MS4 are
violations are encountered and
not considered substantive.
follow up actions are deemed
necessary. NPDES permit
deficiencies are addressed in
written notification and are
also forwarded to NCDEQ
(agency with permitting
authority).
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 26 of 35

During the reporting period (July 1, 2020 to June 30, 2021), a total of 13 NPDES permitted facilities were
inspected by City staff. Of these 13 inspections, three were also listed in the Toxic Release Inventory.
Additionally, one facility without a permit was inspected because it is listed in the Toxics Release
Inventory. No enforcement action was warranted from these inspections. The number of facility
inspections varies from year to year, with some years having more inspections than others. This variation
in facility inspections is due to a previous scheduling agreement between the City of Greensboro and
NCDEQ to avoid overlapping inspections of NPDES permitted facilities.
Water Quality Assessment and Monitoring
The City of Greensboro has developed and implemented a comprehensive water quality monitoring and
assessment program to evaluate the impacts on water quality.
BMP Summary Table
BMPs for Water Quality Assessment and Monitoring
LZBM:P
Measurable Goals
Comments
Water Quality Assessment and
A DRAFT City of Greensboro
Draft document was submitted
Monitoring Plan
Water Quality Assessment and
to NCDEQ for comment and
Monitoring Plan was submitted
approval within 12 months of
within 12 months of permit
permit issuance as required.
issuance as required by the
NPDES permit.
Water Quality Monitoring
The City will implement the
The City implemented the
water quality assessment and
submitted water quality
monitoring plan in accordance
monitoring plan January 1,
with NCDEQ and the permit
2009.
schedule.
Revisions to the Water Quality
The City will conduct an annual
The City will review and revise
Assessment and Monitoring Plan
review, revise as appropriate,
annually and coordinate with
and submit any revisions to
NCDEQ any proposed changes.
NCDEQ for approval.
The most recent revision
occurred in the 2019-20
reporting cycle. This revised
plan was submitted with the
2019-2020 annual report.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 27 of 35

Total Maximum Daily Load (TMDL)
The City of Greensboro has an EPA and NCDEQ approved TMDL for Fecal Coliform bacteria for North
Buffalo Creek. The permittee will utilize BMPs within the six minimum measures to address the
permittee's assigned NPDES regulated stormwater waste load allocation (WLA) identified in the
approved TMDL to the maximum extent practicable and to the extent authorized by law. Resolute efforts
are being made to determine the most efficient best management practices that address the MS4 NPDES
regulated Waste Load Allocation identified in the TMDL. Current efforts are continually re-evaluated and
adapted as needed. More importantly, new ideas are continuously shared and assessed, with the ultimate
goal of improving and protecting water quality.
An assessment of available data, BMP strategies, and TMDL Watershed Plan effectiveness will be
conducted and utilized to define the appropriate progress and schedule of the watershed plan within the
context of the Maximum Extent Practical (MEP) standard. Activities conducted throughout the program
implementation schedule to address the MS4 NPDES regulated waste load allocation (WLA) identified in
the TMDL will be evaluated and defined as to the collective contribution to the watershed plan. The
results of the analysis will be utilized to prioritize local funding aimed at elimination of the most
significant portion of the MS4 waste load allocation for the least resources.
BMP Summary Table
BMPs for Total Maximum Daily Load
A6
Measurable Goals
Comments
(A) Identify, describe and
Within 12 months the permittee shall
Description, maps, and
map watershed, outfalls, and
prepare a plan that:
outfall information is
streams
• Identifies the watershed(s) subject to an
noted in BMP Narratives
approved TMDL with an approved
following this table.
Waste Load Allocation (WLAs)
assigned to the permittee; and
• Includes a description of the
watershed(s); and
• Includes a map of the 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
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 28 of 35

BMP Summary Table — Continued
tributaries within the watershed contributing
to the impaired segments.
(B) Evaluate existing
Within 12 months the Permittee's plan:
Measures include
measures
• Shall describe existing measures being
education, sampling,
implemented by the Permittee designed
investigating pollution
to achieve the MS4's NPDES WLA and
concerns, industrial
to reduce the TMDL pollutant of
inspections, etc. See
concern to the MEP within the
information in BMP
watershed to which the TMDL applies;
Narratives following this
and
table for a more complete
• Provide an explanation as to how those
list and descriptions.
measures are designed to reduce the
TMDL pollutant of concern.
• The Permittee shall continue to
implement the existing measures until
notified by NCDEQ.
C) Assessment of available
Within 24 months the permittee's plan shall
An assessment of the
monitoring data
include an assessment of available
programmatic
monitoring data. Where long-term data is
management measures,
available, this assessment should include an
existing TMDL data,
analysis of the data to show trends.
relevant watershed data,
monitoring data, etc., is
performed periodically.
An assessment of
activities conducted under
the TMDL plan will be
performed to evaluate the
overall effectiveness of
the watershed plan and
make any adjustments
deemed necessary. The
assessment will be used,
where possible, to
evaluate the performance
of existing BMPs and
identify additional BMP
strategies as necessary.
(D) Monitoring Plan
Within 24 months the permittee shall
The monitoring plan for
develop a Monitoring Plan for the
the TMDL Watershed
permittee's assigned NPDES regulated
Plan includes current
WLA as specified in the TMDL. The
monitoring programs and
permittee shall maintain and implement the
procedures that will be
Monitoring Plan as additional outfalls are
updated as necessary to
identified and as accumulating data may
achieve the City's waste
suggest. Following any review and
load allocation (WLA)
comment by the Division the permittee shall
and reduce the pollutant of
incorporate any necessary changes to
concern (POC) to the
monitoring plan and initiate the plan within
maximum extent possible.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 29 of 35

BMP Summary Table — Continued
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.
(E) Additional Measures
Within 24 months the permittee's plan
Measures include the
shall:
FOG Program, sanitary
• Describe additional measures to
sewer rehabilitation, pet
be implemented by the permittee
waste stations, and the use
designed to achieve the
of new technology, and
permittee's MS4's NPDES
the SSO Reduction
WLA and to reduce the TMDL
Committee. See
pollutant of concern to the MEP
information in BMP
within the watershed to which
Narratives following this
the TMDL applies; and
table.
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.
(F) Implementation Plan
Within 48 months the permittee's plan
Current BMPs will
shall:
continue to be
• Describe the measures to be
implemented to achieve
implemented within the remainder of
the Waste Load
the permit term designed to achieve
Allocation to reduce the
the MS4's NPDES WLA and to
pollutant of concern to the
reduce the TMDL pollutant of
MEP. This includes
concern to the MEP; and
existing BMPs and the
• Identify a schedule, subject to
exploration of additional
Division approval, for completing
opportunities.
the activities.
• Implement the permittee's TMDL
plan
(G) Incremental Success
The permittee's plan must outline ways
The TMDL plan describes
to track progress and report successes
ways to track and report
designed to achieve the MS4's NPDES
successes based on the
regulated WLA and to reduce the
TMDL BMPs and goals
TMDL pollutant of concern to MEP
designed to achieve the
within the watershed to which the
Waste Load Allocation to
TMDL applies.
reduce the pollutant of
concern to the MEP.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 30 of 35

BMP Summary Table — Continued
(H) Reporting
The permittee shall conduct and
Following the schedule per the
submit to the Division an annual
permit, the TMDL watershed
assessment of the program
plan addresses and reports on the
designed to achieve the MS4's
TMDL program.
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 Narratives
1) Identify, Describe and Map Watershed, Outfalls, and Streams (A)
Watershed Description
The North Buffalo Creek watershed is located in Greensboro, North Carolina (Guilford County), and is in
the headwaters of the Cape Fear River Basin. The eastern flowing stream eventually feeds into the Haw
River. The watershed is represented by small floodplain streams that have some bedrock outcroppings and
are surrounded by gently sloping uplands. North Buffalo Creek's headwaters lie entirely within urbanized
areas (commercial, industrial, and residential with high impervious area) in the city of Greensboro
(population—300,000).
As outlined in the City's TMDL Watershed Plan, the compliance point for Upper North Buffalo Creek
TMDL is located where Summit Avenue crosses over North Buffalo Creek. The drainage area from the
headwaters to this compliance point is 21.8 mil and incorporates 8.7 miles of stream. The area is generally
deemed as built out, in that no major future land use changes are predicted. The area is 38% residential,
15% right-of-ways, and 20% forest. Impervious surface constitutes >26% of the watershed. In January of
2009, the City started collecting water quality samples at the compliance point on a monthly basis.
Samples are analyzed for both physical and analytical parameters.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 31 of 35

Drainage Area: Headwaters to TMDL Compliance Point
Upper North Buffalo Creek Watershed
TMDL for Fecal Coliform
4 i
i.�. Comp€aincePoint
i L
• r-! h I
[ /x r.
Outfall Locations
MS4 outfalls have been determined through GIS and the City's ongoing stormwater inventory process.
See map below for outfall locations within the TMDL watershed.
Schedule for Locating New Outfalls
Unknown major NPDES outfalls will be identified utilizing the ongoing stormwater inventory procedures
through subsequent QAQC checks of various sub basins, ongoing collection efforts involved with new
development, and updates due to drainage system repairs and maintenance. Any new outfalls and/or
newly identified outfalls will be recorded and mapped on a routine basis.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 32 of 35

NPDES Outfalls in TMDL Drainage Area
Outfalls in Upper North Buffalo Creek Watershed
2) Existing Measures (B)
Outfall Screening
NPDES outfalls are investigated/screened on a routine basis to determine illicit discharges or improper
disposals. Locations are determined based on random selection and areas that have not been done before.
Any noted concerns are investigated further, which may include tracking, obtaining readings for physical
parameters, and/or taking samples to be analyzed in the field or by the contracted lab.
Education
The following are examples of TMDL/pollution education and outreach:
• Engaging citizens with the Drain Marker and Adopt -a -Stream programs, pet waste stations, etc., to
encourage personal involvement
• Assisting local universities with stream clean-up events
• Partnering with communities and organizations to use media for a broad -scale approach to
pollution education and prevention
• Educating citizens about TMDLs via the City's website
• Creating and updating education/outreach materials, such as new drain markers reminding dog
owners to "scoop the poop."
Small -Quantity Polluters Program
As well as general education, specific business types in the community are identified and educated
regarding housekeeping practices and proper waste disposal. This Pollution Prevention Program entails
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 33 of 35

water quality staff to educate businesses that are common polluters, such as painters, landscapers, ready -
mix concrete companies, auto repair shops, mobile washers, restaurants, horizontal drillers, etc. This
ongoing prevention program is highly regarded and has been determined to be a worthwhile endeavor in
keeping pollution from streams and other water sources.
Fixed Interval Sampling
Monthly sampling and assessments are performed, including the analysis of results and the need for
outfall follow-ups; this includes a sampling site at the compliance point in additional to three other
monitoring sites in the TMDL watershed. When data suggests an elevated level of fecal coliform,
increased follow-up sampling and investigations take place to determine the potential source.
Sanitary Sewer Overflow (SSO) Prevention
Ongoing evaluation of citywide SSOs is being used to direct resources for maintenance and rehabilitation
of sanitary sewer lines in the TMDL watershed in an effort to prevent overflows and exfiltration.
Field Observations
Issues discovered by staff through inventory collections, outfall screenings, etc., and water quality staff
address potential issues.
Public Concerns/Reports
Reports are followed up by investigating, tracking, resolving, and enforcing violations when applicable.
Over the past reporting year, 116 calls were investigated throughout the city. Of those calls, 3 1 % were in
the TMDL watershed. This high percentage may be a result of additional outreach efforts in that area.
Industrial Inspection Program
NPDES permitted facilities and TRI facilities are inspected, focusing on a review of the Stormwater
Prevention Pollution Plan, spill prevention and response procedures, employee training, housekeeping
practices, and outfall monitoring.
3) Additional Measures Q
Fats, Oils, and Grease (FOG) Program
This ongoing program seeks to reduce the number of SSOs due to issues caused by oil and grease. New
approaches and technology, such as SwiftComply software, are continuously evaluated and implemented
where applicable. In addition, two full-time staff positions have been recently added to support this
program, increasing staff in this section from one to three.
North Buffalo Basin Modeling
A consultant has been hired for watershed modeling. The main goal of this modeling is to address
flooding issues, but there is a water quality element as well. As flooding can result in sanitary sewer
issues, investigating drainage solutions can have a direct effect on reducing fecal coliform entering
surface waters.
Sanitary Sewer Rehabilitation
During the reporting year, over 15,000 linear feet of sewer underwent rehabilitation in the North Buffalo
watershed up to the compliance point.
Pet Waste Stations
Pet waste stations in the TMDL watershed have been mapped, including both private stations and those
maintained by the City of Greensboro. Within this watershed, there are approximately 113 documented
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 34 of 35

pet waste stations (84 private, 29 city maintained).
New Technology
New technology is always being assessed in an effort to be proactive regarding the City's wastewater
collection system. Acoustical testing and assessment tools (such as SL-RAT—Sewer Line Rapid
Assessment Tool), could help reduce the number of SSOs, therefore reducing the WLA for the POC. The
Operations Division continually explores new and updated equipment to prevent SSOs and to investigate
or repair sewer lines. In addition, inflatable plugs are being used when applicable, helping prevent
overflows from entering surface waters.
SSO Reduction Committee
This committee is compiled of representatives from multiple divisions within the Water Resources
Department. The goal of the committee is to take a holistic approach to preventing SSOs by analyzing
past overflows using GIS, the work order management system, and staffs institutional knowledge to
implement enhanced reduction strategies.
Threatened or Endangered Species Protection Program
The City of Greensboro currently does not have any federally listed aquatic animal species that are listed
as threatened or endangered by the U.S. Fish and Wildlife Service or the National Marine Fisheries
Service under the provisions of the Endangered Species Act.
For more information on the City of Greensboro's NPDES MS4 Discharge Permit and associated
Stormwater Quality Management Program Plan, please visit the Stormwater website at:
www.greensboro-nc.gov/stormwater
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2021
NPDES Permit No. NCS000248 Page 35 of 35

CITY OF GREENSBORO
NPDES MS4 STORMWATER DISCHARGE PERMIT
Permit # NCS000248
STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
2019/2020 Annual Report
Prepared for:
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Prepared by:
City of Greensboro
Water Resources Department - Stormwater Management Division
P.O. Box 3136
Greensboro, NC 27402-3136
FAF-;Tg
L"N
GREENSBORO
October 31, 2020

TABLE OF CONTENTS
Page
ExecutiveSummary --------------------------------------------------------------------------------------------------------------------------------- I
Significant Receiving Waters and Watersheds -------------------------------------------------------------------------- 1
OrganizationalStructure ------------------------------------------------------------------------------------------------------------- 3
LegalAuthority-------------------------------------------------------------------------------------------------------------------------- 4
Funding---------------------------------------------------------------------------------------------------------------------------------------- 5
Stormwater Quality Management Program Plan-------- 6
Public Education and Outreach Program ----------------------------------------------------------------------------------- 6
BMPSummary Table ----------------------------------------------------------------------------------------------------- 6
TargetAudience -------------------------------------------------------------------------------------------------------------- 8
Identifying Pollutants and Target Sources----------------------------------------------- 9
Public Outreach Narrative Program ------------------------------------------------------------------------------- 9
Public Involvement and Participation ---------------------------------------------------------------------------------------- 10
BMPSummary Table ----------------------------------------------------------------------------------------------------- 10
Target Audience------------------------------- 11
Participation Program Narrative----------------- 1 1
Illicit Discharge Detection and Elimination ------------------------------------------------------------------------------
12
BMPSummary Table --------------------------------------------------------------- -------------------------------------12
Detection and Elimination
13
Locating Priority Areas --------------------------------------------------------------------------------------------------
13
Removing Sources of Illicit Discharges ------------------------------------------------------------------------
14
Construction Site Stormwater Runoff Control 15
--------------------------------------------------------------------------
BMPSummary Table ----------------------------------------------------------------------------------------------------- 15
E&SC Plan Review 15
---------------------------------------------------------------------------------------------------------
E&SC Program Implementation and Enforcement ------------------------------------------------------- 15
Construction Site Inspections ----------------------------------------------------------------------------------------- 16
Post -Construction Stormwater in New and Redevelopment 17
BMPSummary Table ----------------------------------------------------------------------------------------------------- 17
Local Permit Issuance 19
-----------------------------------------------------------------------------------------------------
Structural SCM Operation and Maintenance ---------------------------------------------------------------- 20
Pollution Prevention/Good Housekeeping for Municipal Operations ------------------------------------- 21
BMPSummary Table ----------------------------------------------------------------------------------------------------- 21
AffectedOperations -------------------------------------------------------------------------------------------------------- 22
Trainine 22

Site Inspection and Evaluation of Facilities___________________________ 25
Maintenance and Inspections____ 24
VehicularOperations ------------------------------------------------------------------------------------------------------ 24
WasteDisposal---------------------------------------------------------------------------------------------------- 24
Program to Monitor and Evaluate Stormwater Discharges to the Municipal System ------------
25
BMPSummary Table ----------------------------------------------------------------------------------------------------- 25
Water Quality Assessment and Monitoring Program______________________________________________________________ 26
BMPSummary Table ----------------------------------------------------------------------------------------------------- 26
Total Maximum Daily Load(TMDL)----------------------------------------------------------------------------------------
27
BMPSummary Table -----------------------------------------------------------------------------------------------------
27
BMP Narratives
30
Identify, Describe and Map Watershed, Outfalls, and Streams -----------------------------------
30
ExistingMeasures -----------------------------------------------------------------------------------------------------------
32
Additional Measures
33
Threatened or Endangered Species Protection Program ----------------------------------------------------------- 34

Stormwater Quality Management Program Plan (Stormwater Plan)
for
Greensboro's NPDES MS4 Discharge Permit
EXECUTIVE SUMMARY
The City of Greensboro's initial National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Discharge Permit (Permit Number NCS000248) became effective on
December 30, 1994. The North Carolina Department of Environmental Quality (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. This document includes a summary of NPDES stormwater quality management
programs and activities implemented, scheduled to be implemented, or completed during the July 1, 2019 -
June 30, 2020 permit term.
The City's NPDES stormwater permit, and associated Stormwater Quality Management Program Plan
(Stormwater Plan), is designed to control the discharge of pollutants from the MS4 to the Maximum Extent
Practicable (MEP).
Significant Receiving Waters and Watersheds
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 towards
the Haw River, while a smaller portion of the City area drains south towards the Deep River. The North and
South Buffalo Creek Watersheds drain the majority of the City's central urbanized area eastward towards
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 131.94 square miles, represents just over 1 % of the 9,322 square mile Cape Fear Basin.
Existing land uses within Greensboro are broadly classified in Table 1.
Table 1 — Land Uses in the City of Greensboro
Land Use Classification
Approximate % within Corporate Limits
Residential
39%
Commercial
13%
Industrial
7%
Open Space/Wooded/Undeveloped
41 %
Total (land use does not include public streets and water bodies)
100%
Table 2 shows a listing of the primary streams located within the City of Greensboro MS4 service area.
Water quality classifications of receiving streams are provided, along with their use support ratings and
key water quality challenges.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 1 of 34

Table 2 - Primary Receiving Streams within Greensboro Service Area (Upper Cape Fear River
Basin)
Receiving
Stream
Water Quality
Use
Support
Water Quality Issues
303(d) List
Stream Name
Segment
Classification*
Rating
Impaired biological
yes
Reedy Fork
Within
WS-III;NSW,
Impaired
integrity, Chlorophyll a,
Creek
corporate limits
WS-III;NSW CA
Turbidity
Brush Creek
Within
WS-III;NSW
Impaired
Impaired biological
Yes
corporate limits
integrity, Chlorophyll a
Horsepen
Within
WS-III;NSW,
Impaired biological
Yes
Creek
corporate limits
WS-III;NSW CA
Impaired
integrity
Fecal coliform,
Yes
North Buffalo
Within
WS-V;NSW
Impaired
Impaired biological
Creek
corporate limits
integrity, Zinc, Cooper,
NO2+NO3-N
South Buffalo
Within
Turbidity, Impaired
Yes
Creek
corporate limits
WS-V;NSW
Impaired
biological integrity,
Zinc
Yes
East Fork
Within
WS-IV, WS-
Impaired biological
Deep River
corporate limits
IV;CA
Impaired
integrity, Turbidity,
Fecal coliform
Water Quality Classifications:
NSW = Nutrient Sensitive Waters
WS = Water Supply classification (degree of protective measures).
C = Class C waters — general use category (maintain aquatic life and biological integrity, wildlife, secondary
recreation, etc.)
CA = Critical Area
** Use Support Rating (the degree to which the water body supports its designated uses):
FS = Fully Supporting
PS = Partially Supporting
NS = Not Supporting
NR = Not Rated
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 2 of 34

Organizational Structure
The Stormwater Management Utility is one of seven divisions of the City's Water Resources Department
(also including 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.
The following bullet points briefly document the overall organizational structure and functional
responsibilities of the City's Stormwater Plan. 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 substantive ways.
• 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 of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 3 of 34

• 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
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
(htlp:Honline.encodeplus.com/regs/greensboro-nc/doc-viewer.aspx#secid-144). 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 -storm water 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,
• 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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 4 of 34

Funding
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, along with the desire 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 non-structural 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 eleven 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 2019-2020 Budget Expenses
$14,289,696 Operations
Administration Management
6% 1 4% Water Quality &
Monitoring
Planning & 6%
Engineering
Construction 3%
41%
Public Education &
Maintenance Awareness
23% 1%
Street
Cleaning
16%
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 5 of 34

STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
The following information is the City's stormwater quality management program plan (Stormwater Plan)
identifying programmatic measures to comply with the City's NPDES permit to the maximum extent
practicable. BMP summary tables for each of the regulatory areas are provided, along with narrative for
key programs and updates or accomplishments completed during the last permit year (July 1, 2019 - June
30, 2020).
Public Education and Outreach
BMP Summary Table
BMPs for Public Education and Outreach Program
BMP
Measurable Goals
Comments
Pollution
Distribute brochures through event displays, billing
Brochures were
Prevention
inserts, volunteer participants, new customer packets
distributed to
Brochures
at Customer Service counter, informational displays,
approximately 1,000
field representatives and direct mailings to target
individuals at organized
groups. Various issues addressed include proper
events attended by the
disposal of oil and other toxic materials, sediment and
City in addition to 55
erosion control issues, proper application and handling
individuals attended by
of fertilizers and pesticides, litter prevention, pollution
organized events attended
reporting and awareness, etc. for different age groups.
by Stormwater SMART.
Bill inserts were sent to
85,000 households with
FOG and Flooding
information three times.
Website
Maintain the Stormwater Management Website.
Throughout the year
Contains information about pollution prevention,
updates were made as
stormwater technology and practices. Provides
needed.
contacts and forms for pollution reporting and
http://www.greensboro-
nc.gov/stormwater
information requests.
Stormwater
Several videos have been created to educate residents
Stormwater SMART
Videos
and school children about various pollution prevention
PSA's were adapted to
measures and volunteer opportunities. Videos air
meet Greensboro's needs
periodically on Greensboro Television Network
and they were promoted
(GTN) that appears on the local cable affiliate, while
at the No Straw
others air on local stations 2, 8, 12, and Spectrum
November Kick -Off
Cable as part of an advertising campaign.
event, on the City's
YouTube as well as in
Ads via Media Placement
Services (MPS).
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 6 of 34

BMP Summary Table — Continued
Media
Advertise on TV, cable, Facebook, and Instagram
MPS Ads — Yard Waste
Campaign
about different Stormwater related topics. In addition,
(196 ads with 6,444,173
advertise pollution issues in the local Hispanic
impressions across TV,
newspaper La Noticia and in the City of Greensboro
Cable, Facebook,
resident newsletter "At Your Service".
Instagram and Google
Display), Fats, Oil and
Grease 103 ads with
4,000,707 impressions
across TV, Cable,
Facebook, Instagram and
Google Display) and
Hazardous Waste (186
ads with 5,446,884
impressions across TV,
Cable, Facebook,
Instagram and Google
Display)
Helpline
Established a helpline for citizens to report pollution,
114 Water Pollution
address water quality and drainage concerns, as well
Spills and Concerns were
as volunteer opportunities.
reported with 22 via the
city helpline
138 visits to the Report
Water Pollution webpage
349 Drainage Concerns
reported
285 visits to the Report
Drainage Concerns
web a e
School and Civic
Develop and present educational talks and activities
Approximately 1,000
Group
for schools and civic groups, including our
individuals were reached
Presentations
Enviroscape Model.
by the City's Stormwater
program in addition to
approximately 1,342
from the Stormwater
SMART prog am.
Targeted
Develop flyer /brochures to inform businesses that
Ongoing effort by the
Commercial
have a potential of illicit discharges or improper
Stormwater Program;
Education
disposals to the stormwater conveyance system.
program initiated in Mid -
Initiative
2003. See page 13 for
details.
Watershed Signs
Road signs have been installed at stream crossings
Ongoing effort by the
identifying the watershed and stream name.
Stormwater Program.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 7 of 34

BMP Summary Table — Continued
Cooperative
The City of Greensboro seeks reasonable
Maintained partnerships and scheduled
Efforts
opportunities to collaborate with
events/programs that were later
neighboring communities for joint
canceled due to COVID.
educational programs. Previously the
partnership was with the Piedmont Triad
https://www.ptrc.org/services/re_io�nal-
planning/stormwater-smart
Water Quality Partnership (PTWQP)
however; the city is now a member of
https://www.ces.ncsu.edu/
Stormwater SMART and receives direct
https://www.guilfordcountync.gov/our-
county/planning-development/soil-and-
education and mass media services through
water -conservation
the partnership. The North Carolina
Cooperative Extension Services and
Guilford County Soil and Water
Conservation District are also partners in
Stormwater education.
Target Audience
Current and future target audiences for stormwater education include:
1. General Public, especially homeowners — applies lawn care products, uses chemicals for home and
auto maintenance, makes decisions about drainage issues on their properties and participates in
volunteer opportunities.
2. Structural SCM Owners — maintenance issues and education about proper SCM maintenance and
responsibilities.
3. Industries — potential of water quality impacts due to improper material handling, improper
housekeeping practices and illicit discharges.
4. Commercial landscapers, restaurants, mobile washers, concrete companies, painters, drywall
installers, masons, automotive repair facilities and kennels — potential water quality impacts due to
illegal dumping of wastewater into storm drains and improper chemical handling and application.
5. School age children are educated about the importance of protecting water quality through the
distribution of elementary school homework folders and outreach opportunities in our local school
system. Our sponsorship ad in this school year provided an opportunity for us to reach over 2,100
students, their families and caregivers. In partnership with Guilford County Soil and Water
Conservation District over 141 middle and high school students studied and registered for the NC
Area III Envirothon. The Envirothon was canceled due to COVID-19.
6. Through the City's Education and Outreach programs, over 1,104 individuals were reached
through school programming, summer camps, library programs, and more. A robust social
(Facebook, Twitter, & Instagram) media campaign landed over 9,316,964 impressions (views),
and a five -month mass media (video on local cable channels) campaign had 4,286,000
impressions.
7. Through our partnership with Stormwater SMART, over 1,372 individuals were reached through
school programming, summer camps, library programs, and more. Over 66 hours of direct public
education was provided through this partnership. A robust social (Facebook, Twitter, &
Instagram) media campaign landed over 5,000 engagements for 445 posts, and a five -month mass
media (video on local cable channels) campaign had 159,446 impressions. In the 2020 Spring
BioThon (May 13 — June 19, 2020) an online alternative to Creek Week, 143 observations were
submitted by individuals or families in Guilford County.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 8 of 34

Identifying Target Pollutants and Sources
Target pollution sources for stormwater education include:
1. Illicit Connections — The discharge of non-stormwater into the stormwater conveyance system can
result in biological mortality in receiving streams due to discharges.
2. Improper Disposal — The discharge of used motor oil, oil & grease, organic materials (grass and
leaves), and various other pollutants into storm drains can be a problem on construction sites,
commercial and residential areas, etc.
3. Water Quality Monitoring — Routine water quality monitoring data will be evaluated to identify target
pollutants which impact water quality.
4. Pet Waste — Greensboro has developed a TMDL for fecal coliform for the portion of North Buffalo
Creek located within the jurisdictional limits. As a management measure, the City will generate
educational literature targeting pet owners on the need to pick up after their pet in order to protect
water quality. Additionally, staff has observed that a number of public parks and homeowner's
associations have installed pet waste bag dispensers and or signage to encourage proper disposal of
pet waste. As a part of the At Your Service program, information was sent out to residents regarding
the proper way to dispose of pet waste.
5. Lawns and Gardens — Lawn care chemicals may enter storm drains due to improper application. Yard
waste may also be improperly placed into storm drains. These can create blockages in the stormwater
conveyance system and cause decreased dissolved oxygen in streams. The Clean Streams Program
educates commercial landscape professionals on the proper application of fertilizer and pesticides, as
well as aquatic pesticides. Commercial landscape professionals have an opportunity to receive
pesticide credit for successful completion.
6. Auto Repair Shops — Many auto repair shops have interior drains that have the potential to be
illicit connections (such as older buildings or sites that were previously a different business type).
As these locations are identified and dye -testing is conducted, owners and staff are made aware of
proper house -keeping practices, including awareness of interior drains and their resulting
destinations (i.e., either storm or sanitary sewers).
7. Mobile Auto Washers — car washing activities can generate potentially harmful wash water. An
educational and inspection program targeting mobile auto washers on containment, collection, and
disposal of wash water has been developed.
8. Restaurants — Many restaurants have Good Housekeeping issues related to disposal of cooking oil,
process wastewater generated by cleaning activities, and outdoor storage areas such as trash
dumpsters and grease containers that can adversely impact water quality. An educational and
inspection program targeting restaurants has been developed and implemented during this
reporting period.
Public Outreach Program Narrative
Outreach mechanisms are described in the BMP summary table above. Over the permit period,
Greensboro expects to reach the majority of the approximately 287,000 individuals in its MS4 service
area, as well as individuals in surrounding service areas. Everyone who receives a water/sewer bill will
occasionally receive stormwater education messages in the City's citizen newsletter, for example, the "At
Your Service" newsletter. Individuals are also periodically exposed to various stormwater related
messages that are shown on our local governmental broadcast station. For those who do not receive a bill
or do not read the newsletter, various media campaigns are featured on TV, radio, and newspaper.
Combined together, the media outlets are designed to reach the citizens of Greensboro. For citizens who
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 9 of 34

speak Spanish, some materials will be printed in English and Spanish. The City also utilizes a local
Spanish radio station and newspaper to deliver various educational messages.
Public Involvement and Participation
BMP Summary Table
BMPs for Public Involvement and Participation Program
BMP
Measurable Goals
Comments
Adopt -a -Stream
Developed an Adopt -a -Stream Program.
26 cleanups
Volunteers must pick up trash from their adopted
830 volunteers
segment of stream twice per year.
Drain Marker
Developed a Drain Marker Program. Volunteers
I event
Program
have attached signs to Greensboro's storm drains.
20 drain markers installed
Adopt -a -Street
Developed an Adopt -a -Street Program.
65 cleanups
Volunteers must pick up trash from their adopted
594 volunteers
segment four times per year.
Stormwater
Board established to help guide Stormwater
Stormwater Advisory Board
Advisory Board
program on important community issues.
reconvenes as needed to
address community issues.
Annual Clean-up
Promote the Great American Clean-up, NC Big
The Great American Clean-up
Events
Sweep, and Guilford Creek Week.
and Guildford Creek Week
were canceled due to COVID
but The Big Sweep was
promoted at a few events and
did occur with over 30 clean
UPS.
Poster Contest
Water quality, water conservation and soil
Staff vacancies prevented the
conservation poster contest available for
participation of the contest
elementary students in the Guilford County
this year.
School System.
Neighbor Woods
Developed a Neighbor Woods Program, which
166 trees planted
Program
encourages community wide tree planting and re -
vegetation efforts.
Educational
Power of Wetlands (POW), Wonders of Wetlands
All planned workshops were
Workshops
(WOW) and Project Water Education for
scheduled for the 2nd half of
Teachers (WET) workshops offered as a resource
reporting year and were
for educators.
canceled because of COVID-
19.
Household
Promote proper disposal of harmful chemicals
1,900,314 lbs. of chemicals
Hazardous Waste
through the Household Hazardous Waste
were collected for Guilford
Collection
Collection Center.
County. Approximately 75%
is from City residents.
Fats, Oils, and
Program designed to prevent the excessive
Over 10,000 door hangers
Grease Inspection
introduction of oil, grease, and fats into the
were distributed as well as ads
Program
sanitary sewer system and the wastewater
with MPS contract, SWARM
collection system, which helps prevent sanitary
games and other events
sewer over flows.
throughout the year.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 10 of 34

Target Audience
Target audiences for the public involvement program include representative age, ethnic, and economic
groups in Greensboro, from individuals to businesses. For local citizens who speak Spanish, some materials
to promote volunteer programs are printed in both English and Spanish. A local Spanish radio station and
newspaper will also be used for advertising on select campaigns.
Participation Program Narrative
The public is involved in the City's Stormwater Management Program. The following are ongoing
programs that are available in the community.
• Public Hearings
Public hearings are held to address key programs, such as, stream corridor concerns in the
community including restoration projects. Additionally, City Council meetings serve as
public hearing opportunities.
Working with Citizen Volunteers Willing to Educate Others About the Program
As part of the drain marker program, for example, volunteers hang an information piece on
the mailboxes of neighborhood residents where drain markers are installed.
Volunteer Monitoring or Stream Clean-up Activities
As part of our Adopt -a -Stream Program, volunteers are asked to note stream conditions on
their reporting form. The volunteers are required to clean the stream twice per year. Many
also participate in the NC Big Sweep, along with many others who have not formally
adopted a stream.
Flood Advisory Committee
As part of the National Flood Insurance Program (NFIP) Community Rating System
(CRS), communities are challenged with reducing the impact of flooding on private and
public structures. The flood advisory committee was formed through a partnership with
Guilford County Planning Department to communicate important messages. Topics
covered include discussions about flood hazards, flood safety, flood insurance and vital
ways to protect property, and natural floodplain benefits.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 11 of 34

Illicit Discharge Detection and Elimination
The City of Greensboro maintains a program to identify and eliminate illicit discharges and improper
disposals from its MS4 service area.
BMP Summary Table
BMPs for Illicit Discharge Detection and Elimination (IDDE) Program
BMP
Measurable Goals
Comments
Implementation and
Enforce current Stormwater Management
Ongoing program by the
enforcement of
Ordinance (Chapter 30 of the Greensboro
Water Quality Section;
Stormwater Management
Land Development Ordinance) requirements
Ordinance
pertaining to the illicit discharge and improper
dis osal ofpollutants and waste.
Stream water quality
Conduct routine chemical and physical water
Ongoing program by the
monitoring
quality sampling of major streams. Analyze
Water Quality Section
data, detect potential illicit discharges, and
prioritize locations for follow-up investigation.
Response and
Maintain dedicated helpline and field calls
Ongoing program by the
investigation of citizens'
related to pollution concerns and
Water Quality Section;
concerns
environmental questions from citizens.
Public Education and
Provide staff response to pollution concerns.
Awareness Section; City
Contact Center
Develop and maintain
Create map and inventory procedures for the
Ongoing program by the
storm sewer system
collection of major outfalls that discharge to
Stormwater Management
inventory base map of
waters of the State.
Division, Field
major outfalls
Operations Section
Maintain an inventory of
Maintain an inventory of major outfalls that
Inventory complete;
major outfalls that
discharges to waters of the State.
ongoing collection for
discharges to waters of
annexations and new
the State
developments:
Stormwater Management
Division.
Establish procedures to
Establish and maintain procedures to identify
Ongoing program by the
identify and eliminate
and report failed septic systems or sanitary
Water Quality Section
failed septic systems and
sewer overflows to the appropriate agency
sanitary sewer overflows.
(County health department or local utility
de artment).
Maintain
Maintain procedures for detecting and tracing
Ongoing program by the
Inspection/detection
the sources of illicit discharges to the MS4 and
Water Quality Section
program to detect dry
for removing the sources.
weather flows at MS4
outfalls
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 12 of 34

BMP Summary Table — Continued
Inter -departmental spill
Maintain cooperative agreement and improve
Ongoing program by the
response team
relationship with spill response team partners.
City's Fire & Police as
City Fire and Police are primary responders,
primary responder. City's
while Stormwater is a secondary responder to
Stormwater Division as
assist in tracking spills and assessing
secondary.
environmental damage as a result of
environmental emergencies.
Commercial/Business
Develop and implement education and
Ongoing program by the
education and inspection
inspection program to inform local businesses
Water Quality Section.
program
of stormwater regulations, hazards of unlawful
During the reporting
discharges, and penalties for violations.
period, preparations were
made to begin educating
the next business group:
directional drillers.
Education and outreach
Continue ongoing programs and develop new
Ongoing program by the
programs
programs to inform municipal employees,
Water Quality Section;
local businesses, and the general public of the
Public Education and
hazards associated with illicit discharges and
Awareness Section
improper disposal of pollutants and waste.
Detection and Elimination
Greensboro continues to implement a comprehensive program of stormwater ordinance enforcement,
water quality monitoring, education and outreach, spill and citizen complaint response, and formal
inspections in order to prevent, detect, address, and eliminate illicit discharges and improper disposals to
the storm sewer system and receiving waters. The ongoing detection and elimination program currently
includes the following specific tasks:
1. Conducting stream water quality monitoring activity and conducting immediate follow up
when the data suggests a water quality issue.
2. Maintaining a helpline for citizen complaint reporting.
3. Providing professional staff response to citizen reports and complaints.
4. Secondary participation in cooperative spill response team with inter -governmental partners.
5. Development of a formal commercial and business education and inspection program.
6. Conducting stormwater investigations at industrial facilities.
7. Conducting field screening of NPDES MS4 outfalls to detect dry weather flows.
8. Continuation of ongoing educational efforts for municipal employees and general public.
LocatingPriority riority Areas
To locate priority areas for illicit discharge investigations, Greensboro will continue to rely on a
combination of water quality monitoring, inspections, complaints or notifications from citizens and city
staff, and historical knowledge to locate and verify priority areas. Permanent sampling stations will
continue to be located within Greensboro's major watershed sub -basins, and field and laboratory water
quality parameters will be analyzed to detect potential illicit discharges and prioritize locations for follow-
up investigation.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 13 of 34

Removing Sources of Illicit Discharges
Greensboro's Land Development Ordinance (Chapter 30) specifically prohibits the illicit discharge or
improper disposal of pollutants and waste to Greensboro's stormwater conveyance system and subsequent
receiving surface waters. This ordinance authorizes City staff to utilize enforcement action, when
necessary, to stop an illicit discharge, remove the source, and require cleanup of the impacted area.
According to Stormwater's Administrative Procedures for Completing an Enforcement Action, the source
of an illicit discharge may be removed through a series of educational efforts, written Notices of
Violations (NOV), or progressing to civil penalty, if necessary. Once the source and responsible party of
an illicit discharge or improper disposal is identified, an appropriate educational letter or NOV is mailed.
Discontinuation of the discharge is required by the NOV, and the responsible party is required to reply in
writing to Stormwater staff detailing efforts taken to discontinue the unlawful activity and prevent the
activity from occurring in the future. Staff then conducts a follow-up investigation to ensure compliance.
During the July 1, 2019 to June 30, 2020 reporting period, 114 illicit discharges, spills, or concerns were
reported, investigated or educated. Of the 114, 61 required further investigation and were ultimately
eliminated. Fifteen (15) of those investigated illicit discharges resulted in an issuance of a Notice of
Violation (enforcement action). One Notice of Violation resulted in the issuance of a civil penalty for
$1,625.
In addition to the standard citizen reporting procedure such as the City Call Center, City Stormwater
program has an inspection and education program that during routine operations proactively addresses
small commercial businesses that are identified as having the potential to impact water quality. During the
July 1, 2019 to June 30, 2020 reporting period, preparations were made to educate horizontal directional
drillers. These preparations included creating educational material, working with other divisions in Water
Resources to identify businesses contracted for this type of work, talking with major fiber optic
companies regarding improper disposals, drafting a plan for field education, etc. Implementation is set to
take place within the next few months.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 14 of 34

Construction Site Stormwater Runoff Control
The City of Greensboro has a locally delegated Erosion and Sediment Control (E&SC) Program
implemented by the Erosion and Sediment Control Section of the Engineering and Inspections Department.
The E&SC Section is responsible for erosion control plan review, grading permits, erosion control
inspections, enforcement, and review of permanent stabilization of commercial development. A Chief E&SC
Inspector and two field inspector(s) comprise the section.
BMP Summary Table
BMPs for Construction Site Stormwater Runoff Control
BMP
Measurable Goals
Comments
Plan Review, Enforce current
Ongoing program
Water Resources Dept,
E&SC ordinances.
implementation and
Stormwater Management
enforcement. The locally
Division, E&SC Section.
delegated program is regulated
by the NCDEQ, Division of
Energy, Mineral and Land
Resources
E&SC Plan Review
In the City of Greensboro, any proposed land disturbance of one or more acre, including common plans of
development that add up to a total of one or more acre, requires a grading permit prior to any land
disturbance. For sites requiring a grading permit, a plan submittal consisting of a grading permit
application, financial responsibility ownership forms, erosion and sediment control plans, and calculations
are required. Plan approval is also required either through the City's Technical Review Committee, or
through a grading only process that consists of limited reviewers from the Technical Review Committee
prior to grading permit issuance. Once plans are reviewed and approved, a pre -construction meeting is
scheduled and a letter of approval is provided to the financially responsible party. As of April 1, 2019,
information is provided to the permittee on the requirement to obtain a NC DEQ issued certificate of
coverage for the NPDES NCGO1 permit.
During the onsite pre -construction meeting, the representative from the erosion and sediment control
section reviews local, state and federal requirements with the permittee prior to issuing the grading
permit. The City then requires and verifies that the certificate of coverage for the NPDES NCGO1 permit
is attached to the grading permit located in the permit box. The City also ensures that temporary erosion
and sediment control measures are installed, inspected, and accepted prior to mass grading of the site.
The City of Greensboro also stipulates that any development resulting in less than one acre of land
disturbance indicate proper erosion and sediment control measures on the site plan. These plans are
reviewed and approved by the erosion and sediment control section during the technical review process.
Therefore, all sites developed that go through the City's Technical Review Committee are reviewed for
compliance with erosion and sediment control regulations.
E&SC Program Implementation and Enforcement
The City of Greensboro employs a variety of mechanisms to ensure compliance with the provisions of the
Soil Erosion and Sedimentation Control ordinance. First, no site will be issued a grading permit until the
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 15 of 34

plan reviewer is certain that necessary sediment and erosion control measures are adequately detailed on the
construction documents. Prior to issuing a grading permit for any site disturbing one acre or more, the City
Code requires that the owner/contractor post a bond. Prior to issuing a grading permit for any site disturbing
one acre or more, City Code requires that the owner/contractor post a bond. If a contractor begins land
disturbance without the required permits, appropriate City staff will issue a stop work order.
Should the field inspector identify deviations from the approved plan during construction, the inspector
may provide an inspection report to the owner and contractor indicating required measures and allowable
timeframe to bring the site into compliance. If the required items are not addressed within the appropriate
time, the inspector may issue a notice of violation (NOV) to the owner. A monetary fine may accompany
the NOV. If the required measures are still not addressed as indicated in the NOV, the inspector may
issue a stop work order. Additionally, the City of Greensboro reserves the right to deny the issuance of a
certificate of occupancy for sites that continue to remain in nonconformance with the erosion and
sediment control regulations.
Construction Site Inspections
Site inspections to ensure that proper erosion control measures are provided on construction sites are
conducted by qualified field inspectors. Each inspector represents a specific area of the City and inspects
sites within this area. Sites may be inspected more often depending on specific site conditions, the
progress of construction, citizen complaints and/or previously identified problems.
As site inspections may occur more frequently based on several factors, these same factors apply to the
prioritization of site inspections. Specific site conditions, contractor experience, citizen complaints,
previous inspections and the progress of construction all impact which site is given priority for inspection
on a more frequent basis. During the site inspection, the field inspector ensures that erosion and sediment
control measures are implemented according to the approved plan and that no significant offsite
sedimentation is occurring. If the inspector recognizes a problem in the field, the inspector may require
that additional erosion control measures be installed and maintained in accordance with established
enforcement procedures.
Included in the chart below is the data on the number of inspections and enforcement actions carried out by
the E&SC Section during the period of July 1, 2019 to June 30, 2020.
INSPECTIONS
Reporting Period: July 1, 2019, to June 30, 2020
Universe of active construction
sites
278
Number of active construction
sites ins ected
278
Number of construction sites
found to be non -compliant after
the initial inspection
7
Number of follow-up
inspections
7
ENFORCEMENT
Reporting Period: July 1, 2019 to June 30, 2020
Number of informal enforcement actions noncompliance
7
Number of formal enforcement actions without penalty
2
Number of formal enforcement actions with penalty
5
Number of stop work order issued
5
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 16 of 34

Post -Construction Stormwater Management for New Development and
Redevelopment
The City of Greensboro enforces local stormwater management and riparian buffer regulations in addition to
State approved water -supply watershed protection regulations. Throughout the NPDES permit compliance
period, the City of Greensboro will review existing ordinances and, if necessary, develop and implement
revised ordinances in order to implement the post -construction stormwater management program with the
goal of further minimizing impacts to surface water quality. Ordinance language specific to the Phase H
rules, specifically with regard to post -construction runoff, was adopted by City council on April 7, 2009, and
became effective June 1, 2009.
BMP Summary Table
BMPs for Post -Construction Site Stormwater Runoff Controls
jFBMP
Measurable Goals
Comments
Post -Construction
Develop and adopt by ordinance a
The ordinance was adopted by
Stormwater Management
program to address stormwater
City Council on April 7, 2009 and
Program
runoff from new development and
became effective June 1, 2009.
redevelopment within 24 months
of the permit issue date.
Strategies which include
Developed strategies that include a
City of Greensboro Stormwater
BMPs appropriate for the
combination of structural and/or
Management Manual requires any
MS4
non-structural SCMs implemented
proposed structural SCM be
in concurrence with (a) above.
accompanied by an operation and
Provide a mechanism to require
maintenance plan and agreement
long-term operation and
concurrent to development plan
maintenance of structural SCMs.
approval. The city has an
Require annual inspection reports
extensive inspection program to
of permitted structural SCMs
ensure SCM's are maintained to
performed by a qualified
protect water quality.
professional.
Establish nutrient sensitive
Develop, adopt, and implement an
The Greensboro Land
waters (NSW) protection
ordinance to ensure that the best
Development Ordinance was
measures (for programs
management practices reduce
reviewed and modified to ensure
with development or
nutrient loading to the maximum
structural and non-structural
redevelopment draining to
extent practicable. In areas where
SCMs reduce nutrient loading to
NSW waters)
the Environmental Management
the maximum extent practicable.
Commission has approved a
Nutrient Sensitive Water Urban
Stormwater Management Program,
the provisions of that program
fulfill the nutrient loading
reduction requirement.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 17 of 34

BMP Summary Table — Continued
Deed Restrictions and
Protective Covenants
Impose or require recorded deed
restrictions, plats, and/or
protective covenants that ensure
development activities will
maintain the project consistent
with approved plans.
Current City of Greensboro Land
Development Ordinance requires
a maintenance note and recorded
maintenance agreement to be
placed on final plats stating the
maintenance responsibilities,
consistent with approved plans,
for the project SCM.
Establish a program under the
Coordinate with County health
Stormwater Division coordinates
Post -Construction minimum
department to control the known
with Guilford County Health
measure to control the sources
sources of fecal coliform from
Department to control the known
of fecal coliform to the
septic systems to the maximum
sources of fecal coliform from
maximum extent practicable.
extent practicable.
septic systems within the City's
jurisdictional limits to the
maximum extent practicable.
Additionally, the City's Water
Resources Department funds and
performs an ongoing sewer
rehabilitation program to
minimize and eliminate cross
connections between the storm
and sanitary sewer systems.
Operation and Maintenance
Require an operation and
City of Greensboro Stormwater
Plan
maintenance plan that ensures the
Division's development plan
adequate long-term operation of
review process requires a
the structural SCMs required by
stormwater management plan
the program. The operation and
and separate SCM operation and
maintenance plan may require the
maintenance plan (consistent
owner of each structural SCM to
with the provisions outlined in
submit a maintenance inspection
the State stormwater design
report on each structural SCM
manual) be submitted prior to
annually to the local program, or
receiving development plan
the maintenance inspections may
approval. Currently, the City of
be conducted annually by the
Greensboro Stormwater Division
Permittee.
conducts maintenance
inspections on SCMs within the
City's jurisdiction.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 18 of 34

BMP Summary Table — Continued
Educational materials and
Provide educational materials
Water Resources Stormwater and
training for developers
and training for developers. New
Engineering Divisions notify
materials may be developed by
developers and engineers of
the permittee, or the permittee
ordinance changes via direct
may use materials adopted from
phone and e-mail, face-to-face
other programs and adapted to
meetings upon request regarding
the permittees new development
proposed site projects, Triad
and redevelopment program.
Real Estate and Building
Industry Coalition, televised City
Council meetings, providing
opportunity for public comment,
as well as posting the changes on
the City website.
Setbacks for Built -upon Areas
Require built -upon areas to be
The Greensboro Land
located at least 50 feet landward
Development Ordinance was
of all perennial and intermittent
reviewed and modified to require
surface waters except as provided
a 50 foot stream buffer in
for in the Permittees Post-
accordance with NPDES phase II
Construction Stormwater
requirements.
Ordinance. For purposes of this
In addition, the City of
section, a surface water shall be
Greensboro has updated the
present if the feature is shown on
riparian buffer requirements
either the most recent printed
according to the Jordan and
version of the soil survey map
Randleman Lake Rules. The
prepared by the Natural
"Table of Activities and
Resources Conservation Service
Structures in Stream Buffers
of the United States Department
(Zone I & Zone 2)" located in
of Agriculture or the most recent
Chapter 30 of the Greensboro
version of the 1:24,000 scale (7.5
Land Development Ordinance
minute) quadrangle topographic
determines the allowable uses
maps prepared by the United
within the 50' riparian buffer.
States Geologic Survey (USGS).
Relief from this requirement may
be allowed when surface waters
are not present in accordance
with the provisions of 15A
NCAC 02B .0233(3) (a).
Local Permit Issuance
Currently, Group, Site and Subdivision plans within Greensboro's jurisdiction are reviewed by the City's
Technical Review Committee (TRC) for compliance with applicable development regulations. TRC is an
interdepartmental team charged with enforcing development standards as they relate to Watershed
Protection, Stormwater Management, Water -Supply, Water Reclamation, Zoning, Transportation, Parks
and Recreation, Tree Preservation, etc. Approval by members of TRC is a prerequisite to the issuance of
a grading permit or building permit. The City has reviewed and modified the Greensboro Land
Development Ordinance in order to ensure that plans meet post -construction stormwater management
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 19 of 34

requirements as defined by 15A NCAC 2H.0126 (10). The final 15A NCAC 2H.0126 (10)(h) rules define
low and high density development thresholds and as such these thresholds and any associated permanent
structural control and riparian buffer requirements will be applied to applicable new development or re-
development within the City's jurisdictional area. These requirements have now been incorporated in the
Greensboro Land Development Ordinance to allow for enforcement by City staff prior to issuance of the
applicable construction permit. The post -construction stormwater requirements were adopted by City
Council on April 7, 2009 and became effective June 1, 2009. Additionally, the City amended the Land
Development Ordinance and adopted Jordan Lake Riparian Buffer requirements on November 9, 2010.
These rules became effective on December 1, 2010.
Structural SCM Operation and Maintenance
Greensboro mandates that all required structural stormwater control measures (SCMs) be placed in a
drainage maintenance and utility easement (DMUE) connected to the public right-of-way by a 20 foot
wide access easement. The DMUE and access easement for each SCM must be platted before any
certificate of occupancy is issued for the site. TRC-approved development plans for structural SCMs
include an operation and maintenance plan (consistent with the provisions outlined in the State minimum
design criteria) be submitted prior to receiving development plan approval. Furthermore, notes are
recorded on the plat indicating that the City has the right to access the site for SCM inspections and that
the owner will maintain the SCM per the approved maintenance plan or as directed by the City.
During the reporting period (July 1, 2019 to June 30, 2020), 445 privately owned SCMs were inspected
by City staff for performance and maintenance compliance. Fifteen owners were issued a Notice of
Violation (NOV) for failing to complete the required maintenance items with two of the fifteen receiving
an additional second NOV. Of the fifteen sites with NOVs, nine have completed the required SCM
maintenance. The city is working with the property owners, through enforcement procedures, to complete
maintenance items on the six remaining SCMs.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 20 of 34

Pollution Prevention/Good Housekeeping for Municipal Operations
Pollution Prevention and Good Housekeeping Programs are an important factor in the improvement of
stormwater runoff quality. Municipal departments that utilize various facilities currently implement good
housekeeping and pollution prevention programs. Additionally, the City Water Resources Department
works to ensure that pollution prevention and good housekeeping measures are being implemented at
other municipal facilities to the maximum extent practicable with the intent of improving stormwater
runoff quality discharged into receiving streams by those municipal facilities and their operations.
BMP Summary Table
BMPs for Pollution Prevention/Good Housekeeping Program
ism&==
Measurable Goals
Comments
Street Sweeping
Continue ongoing program with periodic
Ongoing program:
review.
Stormwater Management
and Field Operations
Department.
Loose Leaf Collection for
Continue ongoing program with periodic
Ongoing program:
Composting
review.
Stormwater Management
and Field Operations
Department.
Erosion and
City owned or otherwise public
Ongoing program:
Sedimentation Control
construction sites are regulated by NCDEQ,
City owned and other
Division of Energy, Mineral and Land
publicly funded projects
Resources for proper erosion and sediment
obtain appropriate state
control.
permits.
Staff Training/Site
The Stormwater Management Division of
Ongoing cooperative effort
Operator Education
Water Resources distributes education
by the City's departments
material for training employees on various
municipal operations.
Site Planning/Pollution
Develop and implement pollution
Ongoing effort by the City
Prevention Plan for
prevention plans that have been determined
of Greensboro.
Municipal Facilities
to have the potential to impact Water
Quality.
Site inspection and
The City maintains mapping programs that
The City's Stormwater
evaluation of facilities,
consist of all municipal facilities, as well as
Management Division has
operations including the
any related structural SCMs. City
identified a list of specific
MS4 system and
Stormwater Management maintains an
city facilities and ranked
associated structural
ongoing inspection program to monitor,
each of them according to
SCMs.
document and enforce stormwater
their potential to pollute.
discharges to the MS4 system.
Inspections of the high and
medium ranking facilities
have been conducted,
including documenting
areas where improvements
can be made to reduce the
potential of generating
polluted runoff.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 21 of 34

Affected Operations
The facilities listed in the following table are municipal operations that have been issued NPDES
Stormwater Discharge permits. These facilities have developed Municipal Pollution Prevention/Good
Housekeeping techniques in addition with the education and training material sent out.
Municipal Operation
Permit Number
City of Greensboro White St. Landfill
NCG120013
TZ Osborne WWTP
NCG110005
North Buffalo WWTP
NCG110004
Patton Avenue Service Center
NCGO80799
Greensboro Transit Authority (Bus Garage)
NCGO80893
Training
The City's Stormwater Management Division of Water Resources provides educational and technical
assistance for City facilities pertaining to pollution prevention plans and/or BMPs for the improvement of
overall environmental quality. In addition, the Stormwater Management Division also provides assistance
for City facilities pertaining to structural and non-structural stormwater BMPs for the improvement of
stormwater quality and/or quantity and BMP design and implementation.
The City has identified nine Departments that have a greater potential to contribute pollution to
stormwater runoff. The Departments involved in this program are as follows:
1. Coliseum
2. Engineering and Inspections
3. Field Operations
4. Finance (Equipment Services)
5. Fire
6. Parks and Recreation
7. Police
8. Transportation
9. Water Resources
During the July 1, 2019 to June 30, 2020 reporting period, approximately 395 City of Greensboro
employees received training on municipal pollution prevention. This number includes our in house
stormwater pollution prevention DVD, Water Resources employee's training videos and the Fire
Department's in-depth annual training of personnel on spill response and pollution prevention.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 22 of 34

City of Greensboro: Municipal PolIutionPrevention
Good Housekeeping Employee Training
Participation
14
395 Employees Trained
o Water Resources o Fire o Field Ops
Collectively, it is the responsibility of the entire City of Greensboro to maintain the NPDES citywide
permit and enforce programs collaboratively. The objective is for all municipal departments that engage
in various operations to implement good housekeeping and pollution prevention methods in everyday
activities and to set a good example for the community to follow.
Site Inspection and Evaluation of Facilities
Stormwater personnel focused on site inspection and evaluation of city owned and operated facilities. A
complete list of all City owned and operated facilities was obtained from a GIS layer file. To prioritize
each facility, the history of spills/concerns, the proximity to a stream or stormwater conveyance system,
and the activities at a particular location were considered when ranking each facility as High, Medium or
Low. This ranking is further defined below.
Hijah: Facilities in this category would have a large amount of outdoor processing activities, close
proximity to a stream and/or material storage on -site or obvious poor housekeeping issues.
Examples of these facilities would be golf courses, satellite fueling stations, facilities that
store salt for deicing roadways or the Coliseum that has many vendors using this property
at all times.
Medium: This category includes facilities that have some outdoor storage or processing, that may
not be in close proximity to a stream. Examples of these type facilities would be larger
parks, the science center, water treatment plants and the fire training center.
Low: A facility in low level ranking would have limited or no outdoor processing areas.
Examples of these facilities would be libraries, parking decks, rec centers and fire stations.
During the July 1, 2019 to June 30, 2020, reporting period, the stormwater management division
continued to inspect the high or medium risk ranked city owned facilities (listed below). In addition, the
Stormwater Management Division followed up with three medium risk facilities that were previously
inspected. All improvements made at these three facilities were documented in the respective facility files.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 23 of 34

Municipal Operation
Rank
Solid Waste Transfer Station
M
Barber Park
M
Oka T. Hester Park
M
Forest Lawn Cemetery
M
Mitchell Water Treatment Plant
M
Maintenance and Inspections
The City of Greensboro Stormwater Maintenance Section, within the City's Field Operations Department,
maintains open and closed stormwater infrastructure and drainage conveyance systems that carry public
runoff within the MS4 service area. This section also performs stream maintenance activities and
preventative maintenance on most public stormwater infrastructure.
The City's Stormwater Management Division identifies and inspects industrial and related facilities that
may discharge stormwater into either the MS4 or receiving streams in Greensboro, and also assists the
local industrial community in the development and implementation of appropriate stormwater runoff
controls. In addition, the City has an ongoing litter pick-up program to clear trash and other floatables
from roadways, which helps keep them out of the storm drainage system and surface waters.
Vehicular Operations
The City of Greensboro's vehicular operation centers utilize the City's hazardous waste program to
recycle or dispose used oil, antifreeze, batteries, and spare parts and used chemicals. A new salt storage
barn was constructed in fall 2002 as a BMP to prevent salt stormwater runoff from entering receiving
streams.
Waste Disposal
Waste materials generated from the City's day-to-day activities are managed according to local and state
regulations and vendors utilized by Greensboro are audited to ensure environmental compliance. With
the ongoing public education and awareness programs, the City will continue to facilitate staff meetings to
inform staff of all new and related regulations/programs corresponding with the Municipal Pollution
Prevention and Good Housekeeping Program.
Examples of Waste Disposal Programs include:
• Hazardous Waste Program
• Solid Waste Recycling
• Lead Disposal Program
• Oil Disposal Program
• Water Treatment Chemicals Disposal Program
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 24 of 34

Program to Monitor and Evaluate Storm Water Discharges to the Municipal System
The City of Greensboro has developed and implemented an industrial facilities inspection program during
the first two permit terms. During the current permit term, the inspection program will be reviewed and
revised to reflect current permit conditions. Industrial facilities subject to Section 313 of Title III of the
Superfund Amendments and Reauthorization Act of 1985 (SARA), and industrial facilities that the City
determines to be contributing or have the potential to contribute a substantial pollutant loading to the
municipal separate storm sewer system will be inventoried and evaluated.
BMP Summary Table
BMPs for Monitoring and Evaluating Storm Water Discharges to the MS4
BMP
Measurable Goals
Comments
Maintain Inventory of Industrial Sites
The City maintains an
The City will update and
inventory of all NPDES
revise list annually.
permitted industrial facilities.
The City will add additional
facilities to list that meet the
SARA Title III (Section 313)
criteria or that contribute
substantial pollutant loading
to the MS4 system.
Inspection Program
The City has developed a
The City has an ongoing
formal inspection program
industrial inspection program
for evaluating industrial
with a goal of visiting all
facilities. This inspection
listed industrial facilities once
program will be expanded to
per permit cycle. Annual
include any facility on the
training is conducted for City
above stated list.
staff on specific inspection
procedures and staff
coordinates with NCDEQ on
a regular basis to be trained
on any issues or permit
updates.
Establish and Implement Measures to
The City has developed the
The City has a strong working
Evaluate Commercial and Industrial
industrial facilities inspection
relationship with the NCDEQ
Facilities discharging stormwater to
program to evaluate those
regional office and county
the City's MS4
facilities on the above list
officials. The City's
and ensure all permit
enforcement procedures are
conditions are being met and
utilized when water quality
discharges to the MS4 are
violations are encountered and
not considered substantive.
follow up actions are deemed
necessary. NPDES permit
deficiencies are addressed in
written notification and are
also forwarded to NCDEQ
(agency with permitting
authority).
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 25 of 34

During the reporting period (July 1, 2019, to June 30, 2020), a total of 13 NPDES permitted facilities
were inspected by City staff. Of these 13 inspections, three were also listed in the Toxic Release
Inventory. Additionally, one facility without a permit was inspected because it is listed in the Toxics
Release Inventory. No enforcement action was warranted from these inspections. The number of facility
inspections varies from year to year, with some years having more inspections than others. This variation
in facility inspections is due to a previous scheduling agreement between the City of Greensboro and
NCDEQ to avoid overlapping inspections of NPDES permitted facilities.
Water Quality Assessment and Monitoring
The City of Greensboro has developed and implemented a comprehensive water quality monitoring and
assessment program to evaluate the impacts on water quality.
BMP Summary Table
BMPs for Water Quality Assessment and Monitoring
BMP
Measurable Goals
Comments
Water Quality Assessment and
A DRAFT City of Greensboro
Draft document was submitted
Monitoring Plan
Water Quality Assessment and
to NCDEQ for comment and
Monitoring Plan was submitted
approval within 12 months of
within 12 months of permit
permit issuance as required.
issuance as required by the
NPDES permit.
Water Quality Monitoring
The City will implement the
The City implemented the
water quality assessment and
submitted water quality
monitoring plan in accordance
monitoring plan January 1,
with NCDEQ and the permit
2009.
schedule.
Revisions to the Water Quality
The City will conduct an annual
The City will review and revise
Assessment and Monitoring Plan
review, revise as appropriate,
annually and coordinate with
and submit any revisions to
NCDEQ any proposed changes.
NCDEQ for approval.
The most recent revision
occurred in the 2019-20
reporting cycle. The revised
plan along with the annual
report is going to be submitted
to NCDEQ on October 31,
2020.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 26 of 34

Total Maximum Daily Load (TMDL)
The City of Greensboro has an EPA and NCDEQ approved TMDL for Fecal Coliform bacteria for North
Buffalo Creek. The permittee will utilize BMPs within the six minimum measures to address the
permittee's assigned NPDES regulated stormwater waste load allocation (WLA) identified in the
approved TMDL to the maximum extent practicable and to the extent authorized by law. Resolute efforts
are being made to determine the most efficient best management practices that address the MS4 NPDES
regulated Waste Load Allocation identified in the TMDL. Current efforts are continually re-evaluated and
adapted as needed. More importantly, new ideas are continuously shared and assessed, with the ultimate
goal of improving and protecting water quality.
An assessment of available data, BMP strategies, and TMDL Watershed Plan effectiveness will be
conducted and utilized to define the appropriate progress and schedule of the watershed plan within the
context of the Maximum Extent Practical (MEP) standard. Activities conducted throughout the program
implementation schedule to address the MS4 NPDES regulated waste load allocation (WLA) identified in
the TMDL will be evaluated and defined as to the collective contribution to the watershed plan. The
results of the analysis will be utilized to prioritize local funding aimed at elimination of the most
significant portion of the MS4 waste load allocation for the least resources.
BMP Summary Table
BMPs for Total Maximum Daily Load
Measurable Goals
Comments
(A) Identify, describe and
Within 12 months the permittee shall
Description, maps, and
map watershed, outfalls, and
prepare a plan that:
outfall information is
streams
• Identifies the watershed(s) subject to an
noted in BMP Narratives
approved TMDL with an approved
following this table.
Waste Load Allocation (WLAs)
assigned to the permittee; and
• Includes a description of the
watershed(s); and
• Includes a map of the 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
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 27 of 34

BMP Summary Table — Continued
tributaries within the watershed contributing
to the impaired segments.
(B) Evaluate existing
Within 12 months the Permittee's plan:
Measures include
measures
• Shall describe existing measures being
education, sampling,
implemented by the Permittee designed
investigating pollution
to achieve the MS4's NPDES WLA and
concerns, industrial
to reduce the TMDL pollutant of
inspections, etc. See
concern to the MEP within the
information in BMP
watershed to which the TMDL applies;
Narratives following this
and
table for a more complete
• Provide an explanation as to how those
list and descriptions.
measures are designed to reduce the
TMDL pollutant of concern.
• The Permittee shall continue to
implement the existing measures until
notified by NCDEQ.
C) Assessment of available
Within 24 months the permittee's plan shall
An assessment of the
monitoring data
include an assessment of available
programmatic
monitoring data. Where long-term data is
management measures,
available, this assessment should include an
existing TMDL data,
analysis of the data to show trends.
relevant watershed data,
monitoring data, etc., is
performed periodically.
An assessment of
activities conducted under
the TMDL plan will be
performed to evaluate the
overall effectiveness of
the watershed plan and
make any adjustments
deemed necessary. The
assessment will be used,
where possible, to
evaluate the performance
of existing BMPs and
identify additional BMP
strategies as necessary.
(D) Monitoring Plan
Within 24 months the permittee shall
The monitoring plan for
develop a Monitoring Plan for the
the TMDL Watershed
permittee's assigned NPDES regulated
Plan includes current
WLA as specified in the TMDL. The
monitoring programs and
permittee shall maintain and implement the
procedures that will be
Monitoring Plan as additional outfalls are
updated as necessary to
identified and as accumulating data may
achieve the City's waste
suggest. Following any review and
load allocation (WLA)
comment by the Division the permittee shall
and reduce the pollutant of
incorporate any necessary changes to
concern (POC) to the
monitoring plan and initiate the plan within
maximum extent possible.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 28 of 34

BMP Summary Table — Continued
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.
(E) Additional Measures
Within 24 months the permittee's plan
Measures include the
shall:
FOG Program, sanitary
• Describe additional measures to
sewer rehabilitation, pet
be implemented by the permittee
waste stations, and the use
designed to achieve the
of new technology, and
permittee's MS4's NPDES
the SSO Reduction
WLA and to reduce the TMDL
Committee. See
pollutant of concern to the MEP
information in BMP
within the watershed to which
Narratives following this
the TMDL applies; and
table.
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.
(F) Implementation Plan
Within 48 months the permittee's plan
Current BMPs will
shall:
continue to be
• Describe the measures to be
implemented to achieve
implemented within the remainder of
the Waste Load
the permit term designed to achieve
Allocation to reduce the
the MS4's NPDES WLA and to
pollutant of concern to the
reduce the TMDL pollutant of
MEP. This includes
concern to the MEP; and
existing BMPs and the
• Identify a schedule, subject to
exploration of additional
Division approval, for completing
opportunities.
the activities.
• Implement the permittee's TMDL
plan
(G) Incremental Success
The permittee's plan must outline ways
The TMDL plan describes
to track progress and report successes
ways to track and report
designed to achieve the MS4's NPDES
successes based on the
regulated WLA and to reduce the
TMDL BMPs and goals
TMDL pollutant of concern to MEP
designed to achieve the
within the watershed to which the
Waste Load Allocation to
TMDL applies.
reduce the pollutant of
concern to the MEP.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 29 of 34

BMP Summary Table — Continued
(H) Reporting
The permittee shall conduct and
Following the schedule per the
submit to the Division an annual
permit, the TMDL watershed
assessment of the program
plan addresses and reports on the
designed to achieve the MS4's
TMDL program.
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 Narratives
1) Identify, Describe and Map Watershed, Outfalls, and Streams (A)
Watershed Description
The North Buffalo Creek watershed is located in Greensboro, North Carolina (Guilford County), and is in
the headwaters of the Cape Fear River Basin. The eastern flowing stream eventually feeds into the Haw
River. The watershed is represented by small floodplain streams that have some bedrock outcroppings and
are surrounded by gently sloping uplands. North Buffalo Creek's headwaters lie entirely within urbanized
areas (commercial, industrial, and residential with high impervious area) in the city of Greensboro
(population —287,000).
As outlined in the City's TMDL Watershed Plan, the compliance point for Upper North Buffalo Creek
TMDL is located where Summit Avenue crosses over North Buffalo Creek. The drainage area from the
headwaters to this compliance point is 21.8 mil and incorporates 8.7 miles of stream. The area is generally
deemed as built out, in that no major future land use changes are predicted. The area is 38% residential,
15% right-of-ways, and 20% forest. Impervious surface constitutes >26% of the watershed. In January of
2009, the City started collecting water quality samples at the compliance point on a monthly basis.
Samples are analyzed for both physical and analytical parameters.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 30 of 34

Drainage Area: Headwaters to TMDL Compliance Point
Upper North Buffalo Creek Watershed \IY
,
TMDL for Fecal Coliform f4�
f �r
Complaince Point
A
j 1 ,
t i
f
Outfall Locations
MS4 outfalls have been determined through GIS and the City's ongoing stonnwater inventory process.
See map below for outfall locations within the TMDL watershed.
Schedule for Locating New Outfalls
Unknown major NPDES outfalls will be identified utilizing the ongoing stormwater inventory procedures
through subsequent QAQC checks of various sub basins, ongoing collection efforts involved with new
development, and updates due to drainage system repairs and maintenance. Any new outfalls and/or
newly identified outfalls will be recorded and mapped on a routine basis.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 31 of 34

NPDES Outfalls in TMDL Drainage Area
©utfalls in Upper North Buffalo Creek Watershed
2) Existing Measures (B)
Outfall Screening
NPDES outfalls are investigated/screened on a routine basis to determine illicit discharges or improper
disposals. Locations are determined based on random selection and areas that have not been done before.
Any noted concerns are investigated further, which may include tracking, obtaining readings for physical
parameters, and/or taking samples to be analyzed in the field or by the contracted lab.
Education
The following are examples of TMDL/pollution education and outreach:
• Engaging citizens with the Drain Marker and Adopt -a -Stream programs, pet waste stations, etc., to
encourage personal involvement
• Assisting local universities with stream clean-up events
• Partnering with communities and organizations to use media for a broad -scale approach to
pollution education and prevention
• Educating citizens about TMDLs via the City's website
Small -Quantity Polluters Program
As well as general education, specific business types in the community are identified and educated
regarding housekeeping practices and proper waste disposal. This Pollution Prevention Program entails
water quality staff to educate businesses that are common polluters, such as painters, landscapers, ready -
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 32 of 34

mix concrete companies, auto repair shops, mobile washers, restaurants, etc. This ongoing prevention
program is highly regarded and has been determined to be a worthwhile endeavor in keeping pollution
from streams and other water sources.
Fixed Interval Sampling
Monthly sampling and assessments are performed, including the analysis of results and the need for
outfall follow-ups; this includes a sampling site at the compliance point in additional to three other
monitoring sites in the TMDL watershed. When data suggests an elevated level of fecal coliform,
increased follow-up sampling and investigations take place to determine the potential source.
Sanitary Sewer Overflow (SSO) Prevention
Ongoing evaluation of citywide SSOs is being used to direct resources for maintenance and rehabilitation
of sanitary sewer lines in the TMDL watershed in an effort to prevent overflows and exfiltration.
Field Observations
Issues discovered by staff through inventory collections, outfall screenings, etc., and water quality staff
address potential issues.
Public Concerns/Reports
Reports are followed up by investigating, tracking, resolving, and enforcing violations when applicable.
Over the past reporting year, illicit connections have been identified and eliminated throughout the city.
Industrial Inspection Program
NPDES permitted facilities and TRI facilities are inspected, focusing on a review of the Stormwater
Prevention Pollution Plan, spill prevention and response procedures, employee training, housekeeping
practices, and outfall monitoring.
3) Additional Measures Q
Fats, Oils, and Grease (FOG) Program
This ongoing program seeks to reduce the number of SSOs due to issues caused by oil and grease. New
approaches and technology, such as SwiftComply software, are continuously evaluated and implemented
where applicable. In addition, two staff positions have been recently added to support this program,
increasing staff in this section from one to three in the near future.
Sanitary Sewer Rehabilitation
During the reporting year, over 33,000 linear feet of sewer underwent rehabilitation in the North Buffalo
watershed up to the compliance point.
Pet Waste Stations
Pet waste stations in the TMDL watershed have been mapped, including both private stations and those
maintained by the City of Greensboro. Within this watershed, there are approximately 113 documented
pet waste stations (84 private, 29 city maintained).
New Technology
New technology is always being assessed in an effort to be proactive regarding the City's wastewater
collection system. Acoustical testing and assessment tools (such as SL-RAT—Sewer Line Rapid
Assessment Tool), could help reduce the number of SSOs, therefore reducing the WLA for the POC. The
Operations Division continually explores new and updated equipment to prevent SSOs and to investigate
or repair sewer lines. In addition, inflatable plugs are being used when applicable, helping prevent
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 33 of 34

overflows from entering surface waters.
SSO Reduction Committee
This committee is compiled of representatives from multiple divisions within the Water Resources
Department. The goal of the committee is to take a holistic approach to preventing SSOs by analyzing
past overflows using GIS, the work order management system, and staffs institutional knowledge to
implement enhanced reduction strategies.
Threatened or Endangered Species Protection Program
The City of Greensboro currently does not have any federally listed aquatic animal species that are listed
as threatened or endangered by the U.S. Fish and Wildlife Service or the National Marine Fisheries
Service under the provisions of the Endangered Species Act.
For more information on the City of Greensboro's NPDES MS4 Discharge Permit and associated
Stormwater Quality Management Program Plan, please visit the Stormwater website at:
www.;areensboro-nc.2ov/stormwater
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 34 of 34

CITY OF GREENSBORO
NPDES MS4 STORMWATER DISCHARGE PERMIT
Permit # NCS000248
STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
2018/2019 Annual Report
Prepared for:
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Prepared by:
City of Greensboro
Water Resources Department - Stormwater Management Division
P.O. Box 3136
Greensboro, NC 27402-3136
kl-g&
GREENSBORO
October 31, 2019

TABLE OF CONTENTS
Page
ExecutiveSummary --------------------------------------------------------------------------------------------------------------------------------- I
Significant Receiving Waters and Watersheds -------------------------------------------------------------------------- 1
OrganizationalStructure ------------------------------------------------------------------------------------------------------------- 3
Legal Authority --------------------
Funding---------------------------------------------------------------------------------------------------------------5
Stormwater Quality Management Program Plan -
Public Education and Outreach Program ...............
BMP Summary Table ---------------------------------
Target Audience ------------------------------------------
Identifying Pollutants and Target Sources
Public Outreach Narrative Program ----------.
Public Involvement and Participation____
BMP Summary Table -----------------
Target Audience__________________________
Participation Program Narrative
Illicit Discharge Detection and Elimination
no
---- 6
----------------------------------- 6
7
------------------------------------
------------------------------------8
9
9
9
10
BMPSummary Table ----------------------------------------------------------------------------------------------------- 11
Detection and Elimination 12
----------------------------------------------------------------------------------------------
LocatingPriority Areas --------------------------------------------------------------------------------------------------- 12
Removing Sources of Illicit Discharges ------------------------------------------------------------------------ 13
Construction Site Stormwater Runoff Control 14
--------------------------------------------------------------------------
BMPSummary Table ----------------------------------------------------------------------------------------------------- 14
E&SC Plan Review 14
---------------------------------------------------------------------------------------------------------
E&SC Program Implementation and Enforcement ------------------------------------------------------- 14
Construction Site Inspections ----------------------------------------------------------------------------------------- 15
Post -Construction Stormwater in New and Redevelopment 16
BMPSummary Table ----------------------------------------------------------------------------------------------------- 16
Local Permit Issuance 18
-----------------------------------------------------------------------------------------------------
Structural SCM Operation and Maintenance ---------------------------------------------------------------- 19
Pollution Prevention/Good Housekeeping for Municipal Operations ------------------------------------- 20
BMPSummary Table ----------------------------------------------------------------------------------------------------- 20
AffectedOperations -------------------------------------------------------------------------------------------------------- 21
Trainine 21

Site Inspection and Evaluation of Facilities--------------------------------- 22
Maintenance and Inspections---- 23
VehicularOperations ------------------------------------------------------------------------------------------------------ 23
WasteDisposal---------------------------------------------------------------------------------------------------- 23
Program to Monitor and Evaluate Stormwater Discharges to the Municipal System ------------
24
BMPSummary Table ----------------------------------------------------------------------------------------------------- 24
Water Quality Assessment and Monitoring Program --------------------------------------------------- -----------26
BMPSummary Table ----------------------------------------------------------------------------------------------------- 26
Total Maximum Daily Load(TMDL)--------------------------------------
26
BMPSummary Table -----------------------------------------------------------------------------------------------------
27
BMP Narratives
30
Identify, Describe and Map Watershed, Outfalls, and Streams -----------------------------------
30
ExistingMeasures -----------------------------------------------------------------------------------------------------------
31
Additional Measures
32
Threatened or Endangered Species Protection Program ----------------------------------------------------------- 33

Stormwater Quality Management Program Plan (Stormwater Plan)
for
Greensboro's NPDES MS4 Discharge Permit
EXECUTIVE SUMMARY
The City of Greensboro's initial National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Discharge Permit (Permit Number NCS000248) became effective on
December 30, 1994. The North Carolina Department of Environmental Quality (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. This document includes a summary of NPDES stormwater quality management
programs and activities implemented, scheduled to be implemented, or completed during the July 1, 2018 -
June 30, 2019 permit term.
The City's NPDES stormwater permit, and associated Stormwater Quality Management Program Plan
(Stormwater Plan), is designed to control the discharge ofpollutants from the MS4 to the Maximum Extent
Practicable (MEP).
Significant Receiving Waters and Watersheds
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 towards
the Haw River, while a smaller portion of the City area drains south towards the Deep River. The North and
South Buffalo Creek Watersheds drain the majority of the City's central urbanized area eastward towards
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 131.94 square miles, represents just over 1 % of the 9,322 square mile Cape Fear Basin.
Existing land uses within Greensboro are broadly classified in Table 1.
Table 1 — Land Uses in the City of Greensboro
Land Use Classification
Approximate % within Corporate Limits
Residential
39%
Commercial
13%
Industrial
7%
Open Space/Wooded/Undeveloped
41 %
Total (land use does not include public streets and water bodies)
100%
Table 2 shows a listing of the primary streams located within the City of Greensboro MS4 service area.
Water quality classifications of receiving streams are provided, along with their use support ratings and
key water quality challenges.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 1 of 33

Table 2 - Primary Receiving Streams within Greensboro Service Area (Upper Cape Fear River
Basin)
Receiving
Stream
Water Quality
Use
Support
Water Quality Issues
303(d) List
Stream Name
Segment
Classification*
Rating
Impaired biological
yes
Reedy Fork
Within
WS-III;NSW,
Impaired
integrity, Chlorophyll a,
Creek
corporate limits
WS-III;NSW CA
Turbidity
Brush Creek
Within
WS-III;NSW
Impaired
Impaired biological
Yes
corporate limits
integrity, Chlorophyll a
Horsepen
Within
WS-III;NSW,
Impaired biological
Yes
Creek
corporate limits
WS-III;NSW CA
Impaired
integrity
Fecal coliform,
Yes
North Buffalo
Within
WS-V;NSW
Impaired
Impaired biological
Creek
corporate limits
integrity, Zinc, Cooper,
NO2+NO3-N
South Buffalo
Within
Turbidity, Impaired
Yes
Creek
corporate limits
WS-V;NSW
Impaired
biological integrity,
Zinc
Yes
East Fork
Within
WS-IV, WS-
Impaired biological
Deep River
corporate limits
IV;CA
Impaired
integrity, Turbidity,
Fecal coliform
Water Quality Classifications:
NSW = Nutrient Sensitive Waters
WS = Water Supply classification (degree of protective measures).
C = Class C waters — general use category (maintain aquatic life and biological integrity, wildlife, secondary
recreation, etc.)
CA = Critical Area
** Use Support Rating (the degree to which the water body supports its designated uses):
FS = Fully Supporting
PS = Partially Supporting
NS = Not Supporting
NR = Not Rated
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 2 of 33

Organizational Structure
The Stormwater Management Utility is one of seven divisions of the City's Water Resources Department
(also including 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.
The following bullet points briefly document the overall organizational structure and functional
responsibilities of the City's Stormwater Plan. 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 substantive ways.
• 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 of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 3 of 33

• 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
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
(http://online.encodeplus.com/reps/greensboro-nc/doc-viewer.aspx#secid-144). 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 -storm water 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,
• 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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 4 of 33

.. A -
Constru i
41%
Funding
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, along with the desire 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 non-structural 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 eleven 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 F'Y 01 -2019 Budget Expenses
.14,051,616 Operations
Adim'n'strat"cn Management
6
S% Water Quality
Monitoring
Planning& 6%
Engineering
3%
Public Educat-on &
na Awareness
229E 1'}
5tre't
Cleaning
16%
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 5 of 33

STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
The following information is the City's stormwater quality management program plan (Stormwater Plan)
identifying programmatic measures to comply with the City's NPDES permit to the maximum extent
practicable. BMP summary tables for each of the regulatory areas are provided, along with narrative for
key programs and updates or accomplishments completed during the last permit year (July 1, 2018 - June
30, 2019).
Public Education and Outreach
BMP Summary Table
BMPs for Public Education and Outreach Program
BMP
Measurable Goals
Comments
Pollution
Distribute brochures through event displays, billing
Ongoing effort by the
Prevention
inserts, volunteer participants, new customer packets
Stormwater Program.
Brochures
at Customer Service counter, informational displays,
field representatives and direct mailings to target
groups. Various issues addressed include proper
disposal of oil and other toxic materials, sediment and
erosion control issues, proper application and handling
of fertilizers and pesticides, litter prevention, pollution
reporting and awareness, etc. for different age groups.
Website
Maintain the Stormwater Management Website.
Ongoing effort by the
Contains information about pollution prevention,
Stormwater Program.
stormwater technology and practices. Provides
contacts and forms for pollution reporting and
http://www.greensboro-
nc. gov/stormwater
information requests.
Stormwater
Several videos have been created to educate residents
Ongoing effort by the
Videos
and school children about various pollution prevention
Stormwater Program.
measures and volunteer opportunities. Videos air
Additional videos may be
periodically on Greensboro Television Network
created as issues arise.
(GTN) that appears on the local cable affiliate, while
others air on local stations 2, 8, 12, and Spectrum
Cable as part of an advertising campaign.
Media
Advertise on TV, cable, Facebook, and Instagram
Ongoing effort by the
Campaign
about different Stormwater related topics. In addition,
Stormwater Program.
advertise pollution issues in the local Hispanic
newspaper La Noticia and in the City of Greensboro
resident newsletter "At Your Service".
Helpline
Established a helpline for citizens to report pollution,
Ongoing effort by the
address water quality and drainage concerns, as well
Stormwater Program and
as volunteer opportunities.
City Contact Center.
School and Civic
Develop and present educational talks and activities
Ongoing effort by the
Group
for schools and civic groups, including our
Stormwater Program.
Presentations
Enviroscape Model.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 6 of 33

BMP Summary Table — Continued
Targeted
Develop flyer /brochures to inform
Ongoing effort by the Stormwater
Commercial
businesses that have a potential of illicit
Program; site visits initiated in Mid -
Education
discharges or improper disposals to the
2003.
Initiative
stormwater conveyance system.
Cooperative
The City of Greensboro seeks reasonable
Ongoing effort by the Stormwater
Efforts
opportunities to collaborate with
Program.
neighboring communities for joint
https://www.piedmontcleanstreams.org/
educational programs. Previously the
partnership was with the Piedmont Triad
https://www.ptrc.org/services/re_io�nal-
planning/stormwater-smart
Water Quality Partnership (PTWQP)
however; the city is now a member of
Stormwater SMART and receives direct
education and mass media services through
the partnership. The North Carolina
Cooperative Extension Services and
Guilford County Soil and Water
Conservation District are also partners in
Stormwater education.
Watershed
Road signs have been installed at stream
Ongoing effort by the Stormwater
Signs
crossings identifying the watershed and
Program.
stream name.
Target Audience
Current and future target audiences for stormwater education include:
1. General Public, especially homeowners — applies lawn care products, uses chemicals for home and
auto maintenance, makes decisions about drainage issues on their properties and participates in
volunteer opportunities.
2. Structural SCM Owners — maintenance issues and education about proper SCM maintenance and
responsibilities.
3. Industries — potential of water quality impacts due to improper material handling, improper
housekeeping practices and illicit discharges.
4. Commercial landscapers, restaurants, mobile washers, concrete companies, painters, drywall
installers, masons, automotive repair facilities and kennels — potential water quality impacts due to
illegal dumping of wastewater into storm drains and improper chemical handling and application.
5. School age children are educated about the importance of protecting water quality through the
distribution of elementary school homework folders and outreach opportunities in our local school
system. Our sponsorship ad provided an opportunity for us to reach over 7,600 students and their
families. In partnership with Guilford County Soil and Water Conservation District over 140
middle and high school students have competed in the NC Area III Envirothon. During the event,
students train and complete in areas of soils, aquatics, wildlife, forestry, and current environmental
issues.
6. Through the partnership with Stormwater SMART, over 3,167 individuals were reached through
school programming, summer camps, library programs, creek week events, and more. Over 189.5
hours of direct public education was provided through this partnership. A robust social (Facebook,
Twitter, & Instagram) media campaign landed over 111,482 impressions (views) for 2018-2019
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 7 of 33

and then a three-month mass media (video on local cable channel) campaign reached 196,924
impressions.
Identifying Target Pollutants and Sources
Target pollution sources for stormwater education include:
1. Illicit Connections — The discharge of non-stormwater into the stormwater conveyance system can
result in biological mortality in receiving streams due to discharges.
2. Improper Disposal — The discharge of used motor oil, oil & grease, organic materials (grass and
leaves), and various other pollutants into storm drains can be a problem on construction sites,
commercial and residential areas, etc.
3. Water Quality Monitoring — Routine water quality monitoring data will be evaluated to identify target
pollutants which impact water quality.
4. Pet Waste — Greensboro has developed a TMDL for fecal coliform for the portion of North Buffalo
Creek located within the jurisdictional limits. As a management measure, the City will generate
educational literature targeting pet owners on the need to pick up after their pet in order to protect
water quality. Additionally, staff has observed that a number of public parks and homeowner's
associations have installed pet waste bag dispensers and or signage to encourage proper disposal of
pet waste. As a part of the At Your Service program, information was sent out to residents regarding
the proper way to dispose of pet waste.
5. Lawns and Gardens — Lawn care chemicals may enter storm drains due to improper application. Yard
waste may also be improperly placed into storm drains. These can create blockages in the stormwater
conveyance system and cause decreased dissolved oxygen in streams. The Clean Streams Program
educates commercial landscape professionals on the proper application of fertilizer and pesticides, as
well as aquatic pesticides. Commercial landscape professionals have an opportunity to receive
pesticide credit for successful completion.
6. Auto Repair Shops — Many auto repair shops have interior drains that have the potential to be
illicit connections (such as older buildings or sites that were previously a different business type).
As these locations are identified and dye -testing is conducted, owners and staff are made aware of
proper house -keeping practices, including awareness of interior drains and their resulting
destinations (i.e., either storm or sanitary sewers).
7. Mobile Auto Washers — car washing activities can generate potentially harmful wash water. An
educational and inspection program targeting mobile auto washers on containment, collection, and
disposal of wash water has been developed.
8. Restaurants — Many restaurants have Good Housekeeping issues related to disposal of cooking oil,
process wastewater generated by cleaning activities, and outdoor storage areas such as trash
dumpsters and grease containers that can adversely impact water quality. An educational and
inspection program targeting restaurants has been developed and implemented during this
reporting period.
Public Outreach Program Narrative
Outreach mechanisms are described in the BMP summary table above. Over the permit period,
Greensboro expects to reach the majority of the approximately 287,000 individuals in its MS4 service
area, as well as individuals in surrounding service areas. Everyone who receives a water/sewer bill will
occasionally receive stormwater education messages in the City's citizen newsletter, for example, the "At
Your Service" newsletter. Individuals are also periodically exposed to various stormwater related
messages that are shown on our local governmental broadcast station. For those who do not receive a bill
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 8 of 33

or do not read the newsletter, various media campaigns are featured on TV, radio, and newspaper.
Combined together, the media outlets are designed to reach the citizens of Greensboro. For citizens who
speak Spanish, some materials will be printed in English and Spanish. The City also utilizes a local
Spanish radio station and newspaper to deliver various educational messages.
Public Involvement and Participation
BMP Summary Table
BMPs for Public Involvement and Participation Program
BMP
Measurable Goals
Comments
Adopt -a -Stream
Developed an Adopt -a -Stream Program.
Ongoing effort by the
Volunteers must pick up trash from their adopted
Stormwater Program.
segment of stream twice per year.
Drain Marker
Developed a Drain Marker Program. Volunteers
Ongoing effort by the
Program
have attached signs to Greensboro's storm drains.
Stormwater Program.
Adopt -a -Street
Developed an Adopt -a -Street Program.
Ongoing effort administered
Volunteers must pick up trash from their adopted
by the City's Field Operations
segment four times per year.
Department.
Stormwater
Board established to help guide Stormwater
Stormwater Advisory Board
Advisory Board
program on important community issues.
reconvenes as needed to
address community issues.
Annual Clean-up
Promote the Great American Clean-up, NC Big
Ongoing effort by the City's
Events
Sweep, and Guilford Creek Week.
Parks and Recreation
Department.
Poster Contest
Water quality, water conservation and soil
Ongoing effort administered
conservation poster contest available for
by the Guilford County Soil
elementary students in the Guilford County
and Water Conservation
School System.
District and Stormwater
Program.
Neighbor Woods
Developed a Neighbor Woods Program, which
Ongoing effort administered
Program
encourages community wide tree planting and re-
by the City's Planning
vegetation efforts.
Department.
Educational
Power of Wetlands (POW), Wonders of Wetlands
Ongoing effort administered
Workshops
(WOW) and Project Water Education for
by the Greensboro Public
Teachers (WET) workshops offered as a resource
Library, Guilford County Soil
for educators.
and Water Conservation
District, and the Parks and
Recreation Department.
Household
Promote proper disposal of harmful chemicals
Ongoing effort by the City's
Hazardous Waste
through the Household Hazardous Waste
Field Operations Department.
Collection
Collection Center.
Fats, Oils, and
Program designed to prevent the excessive
Ongoing effort by the
Grease Inspection
introduction of oil, grease, and fats into the
Stormwater Program and the
Program
sanitary sewer system and the wastewater
Industrial Pretreatment
collection system, which helps prevent sanitary
Division.
sewer over flows.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 9 of 33

Target Audience
Target audiences for the public involvement program include representative age, ethnic, and economic
groups in Greensboro, from individuals to businesses. For local citizens who speak Spanish, some materials
to promote volunteer programs are printed in both English and Spanish. A local Spanish radio station and
newspaper will also be used for advertising on select campaigns.
Participation Program Narrative
The public is involved in the City's Stormwater Management Program. The following are ongoing
programs that are available in the community.
• Public Hearings
Public hearings are held to address key programs, such as, stream corridor concerns in the
community including restoration projects. Additionally, City Council meetings serve as
public hearing opportunities.
Working with Citizen Volunteers Willing to Educate Others About the Program
As part of the drain marker program, for example, volunteers hang an information piece on
the mailboxes of neighborhood residents where drain markers are installed.
Volunteer Monitoring or Stream Clean-up Activities
As part of our Adopt -a -Stream Program, volunteers are asked to note stream conditions on
their reporting form. The volunteers are required to clean the stream twice per year. Many
also participate in the NC Big Sweep, along with many others who have not formally
adopted a stream.
Flood Advisory Committee
As part of the National Flood Insurance Program (NFIP) Community Rating System
(CRS), communities are challenged with reducing the impact of flooding on private and
public structures. The flood advisory committee was formed through a partnership with
Guilford County Planning Department to communicate important messages. Topics
covered include discussions about flood hazards, flood safety, flood insurance and vital
ways to protect property, and natural floodplain benefits.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 10 of 33

Illicit Discharge Detection and Elimination
The City of Greensboro maintains a program to identify and eliminate illicit discharges and improper
disposals from its MS4 service area.
BMP Summary Table
BMPs for Illicit Discharge Detection and Elimination (IDDE) Program
BMP
Measurable Goals
Comments
Implementation and
Enforce current Stormwater Management
Ongoing program by the
enforcement of
Ordinance (Chapter 30 of the Greensboro
Water Quality Section;
Stormwater Management
Land Development Ordinance) requirements
Ordinance
pertaining to the illicit discharge and improper
dis osal ofpollutants and waste.
Stream water quality
Conduct routine chemical and physical water
Ongoing program by the
monitoring
quality sampling of major streams. Analyze
Water Quality Section
data, detect potential illicit discharges, and
prioritize locations for follow-up investigation.
Response and
Maintain dedicated helpline and field calls
Ongoing program by the
investigation of citizens'
related to pollution concerns and
Water Quality Section;
concerns
environmental questions from citizens.
Public Education and
Provide staff response to pollution concerns.
Awareness Section; City
Contact Center
Develop and maintain
Create map and inventory procedures for the
Ongoing program by the
storm sewer system
collection of major outfalls that discharge to
Stormwater Management
inventory base map of
waters of the State.
Division, Field
major outfalls
Operations Section
Maintain an inventory of
Maintain an inventory of major outfalls that
Inventory complete;
major outfalls that
discharges to waters of the State.
ongoing collection for
discharges to waters of
annexations and new
the State
developments:
Stormwater Management
Division.
Establish procedures to
Establish and maintain procedures to identify
Ongoing program by the
identify and eliminate
and report failed septic systems or sanitary
Water Quality Section
failed septic systems and
sewer overflows to the appropriate agency
sanitary sewer overflows.
(County health department or local utility
de artment).
Maintain
Maintain procedures for detecting and tracing
Ongoing program by the
Inspection/detection
the sources of illicit discharges to the MS4 and
Water Quality Section
program to detect dry
for removing the sources.
weather flows at MS4
outfalls
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 11 of 33

BMP Summary Table — Continued
Inter -departmental spill
Maintain cooperative agreement and improve
Ongoing program by the
response team
relationship with spill response team partners.
City's Fire & Police as
City Fire and Police are primary responders,
primary responder. City's
while Stormwater is a secondary responder to
Stormwater Division as
assist in tracking spills and assessing
secondary.
environmental damage as a result of
environmental emergencies.
Commercial/Business
Develop and implement education and
Ongoing program by the
education and inspection
inspection program to inform local businesses
Water Quality Section.
program
of stormwater regulations, hazards of unlawful
During the reporting
discharges, and penalties for violations.
period, approximately
110 businesses (concrete
finishers, landscapers,
painters, etc.) were
educated and/or
inspected.
Education and outreach
Continue ongoing programs and develop new
Ongoing program by the
programs
programs to inform municipal employees,
Water Quality Section;
local businesses, and the general public of the
Public Education and
hazards associated with illicit discharges and
Awareness Section
improper disposal of pollutants and waste.
Detection and Elimination
Greensboro continues to implement a comprehensive program of stormwater ordinance enforcement,
water quality monitoring, education and outreach, spill and citizen complaint response, and formal
inspections in order to prevent, detect, address, and eliminate illicit discharges and improper disposals to
the storm sewer system and receiving waters. The ongoing detection and elimination program currently
includes the following specific tasks:
1. Conducting stream water quality monitoring activity and conducting immediate follow up
when the data suggests a water quality issue.
2. Maintaining a helpline for citizen complaint reporting.
3. Providing professional staff response to citizen reports and complaints.
4. Secondary participation in cooperative spill response team with inter -governmental partners.
5. Development of a formal commercial and business education and inspection program.
6. Conducting stormwater investigations at industrial facilities.
7. Conducting field screening of NPDES MS4 outfalls to detect dry weather flows.
8. Continuation of ongoing educational efforts for municipal employees and general public.
LocatingPriority riority Areas
To locate priority areas for illicit discharge investigations, Greensboro will continue to rely on a
combination of water quality monitoring, inspections, complaints or notifications from citizens and city
staff, and historical knowledge to locate and verify priority areas. Permanent sampling stations will
continue to be located within Greensboro's major watershed sub -basins, and field and laboratory water
quality parameters will be analyzed to detect potential illicit discharges and prioritize locations for follow-
up investigation.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 12 of 33

Removing Sources of Illicit Discharges
Greensboro's Land Development Ordinance (Chapter 30) specifically prohibits the illicit discharge or
improper disposal of pollutants and waste to Greensboro's stormwater conveyance system and subsequent
receiving surface waters. This ordinance authorizes City staff to utilize enforcement action, when
necessary, to stop an illicit discharge, remove the source, and require cleanup of the impacted area.
According to Stormwater's Administrative Procedures for Completing an Enforcement Action, the source
of an illicit discharge may be removed through a series of educational efforts, written Notices of
Violations (NOV), or progressing to civil penalty, if necessary. Once the source and responsible party of
an illicit discharge or improper disposal is identified, an appropriate educational letter or NOV is mailed.
Discontinuation of the discharge is required by the NOV, and the responsible party is required to reply in
writing to Stormwater staff detailing efforts taken to discontinue the unlawful activity and prevent the
activity from occurring in the future. Staff then conducts a follow-up investigation to ensure compliance.
During the July 1, 2018 to June 30, 2019 reporting period, 114 illicit discharges, spills, or concerns were
reported, investigated or educated. Of the 114, 61 required further investigation and were ultimately
eliminated. Fifteen (15) of those investigated illicit discharges resulted in an issuance of a Notice of
Violation (enforcement action). One Notice of Violation resulted in the issuance of a civil penalty for
$1,625.
In addition to the standard citizen reporting procedure such as the City Call Center, City Stormwater
program has an inspection and education program that during routine operations proactively addresses
small commercial businesses that are identified as having the potential to impact water quality. During the
July 1, 2018, to June 30, 2019, reporting period, approximately 110 businesses were educated and
inspected. This included educating 21 auto shops, 6 concrete finishers, 71 landscapers, 1 mobile washer,
and 11 painters/construction contractors.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 13 of 33

Construction Site Stormwater Runoff Control
The City of Greensboro has a locally delegated Erosion and Sediment Control (E&SC) Program
implemented by the Erosion and Sediment Control Section of the Engineering and Inspections Department.
The E&SC Section is responsible for erosion control plan review, grading permits, erosion control
inspections, enforcement, and review of permanent stabilization of commercial development. A Chief E&SC
Inspector and two field inspector(s) comprise the section.
BMP Summary Table
BMPs for Construction Site Stormwater Runoff Control
BMP
Measurable Goals
Comments
Plan Review, Enforce current
Ongoing program
Engineering and Inspections
E&SC ordinances.
implementation and
Dept, Development Services
enforcement. The locally
Division, E&SC Section.
delegated program is regulated
by the NCDEQ, Division of
Energy, Mineral and Land
Resources
E&SC Plan Review
In the City of Greensboro, any proposed development resulting in land disturbance of equal to or greater than
one acre requires a grading permit prior to any land disturbance activity. An NPDES Stormwater Discharge
Permit for Construction Activities is issued in conjunction with the grading permit for sites one acre or
greater. For sites requiring a grading permit, development plans and a grading application are submitted to
the E&SC Section, which reviews the plans to ensure that proper erosion and sediment control practices are
designed. Once the E&SC Section approves the plan, a grading permit is issued and land disturbance may
begin. The City of Greensboro also requires that any development resulting in less than one acre of land
disturbance indicate proper erosion and sediment control measures on the site plan. These plans are reviewed
and approved by the E&SC Section through the TRC process. Therefore, all sites developed through the
City's TRC process are reviewed for compliance with E&SC regulations.
E&SC Program Implementation and Enforcement
The City of Greensboro employs a variety of mechanisms to ensure compliance with the provisions of the
Soil Erosion and Sedimentation Control ordinance. First, no site will be issued a grading permit until the
plan reviewer is certain that necessary sediment and erosion control measures are adequately detailed on the
construction documents. Prior to issuing a grading permit for any site disturbing one acre or more, the City
Code requires that the owner/contractor post a bond. Prior to issuing a grading permit for any site disturbing
one acre or more, City Code requires that the owner/contractor post a bond. If a contractor begins land
disturbance without the required permits, appropriate City staff will issue a stop work order.
Should the field inspector identify deviations from the approved plan during construction, the inspector
may provide an inspection report to the owner and contractor indicating required measures and allowable
timeframe to bring the site into compliance. If the required items are not addressed within the appropriate
time, the inspector may issue a notice of violation (NOV) to the owner. A monetary fine may accompany
the NOV. If the required measures are still not addressed as indicated in the NOV, the inspector may
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 14 of 33

issue a stop work order. Additionally, the City of Greensboro reserves the right to deny the issuance of a
certificate of occupancy for sites that continue to remain in nonconformance with the erosion and
sediment control regulations.
Construction Site Inspections
Site inspections to ensure that proper erosion control measures are provided on construction sites are
conducted by qualified field inspectors. Each inspector represents a specific area of the City and inspects
sites within this area. Sites may be inspected more often depending on specific site conditions, the
progress of construction, citizen complaints and/or previously identified problems.
As site inspections may occur more frequently based on several factors, these same factors apply to the
prioritization of site inspections. Specific site conditions, contractor experience, citizen complaints,
previous inspections and the progress of construction all impact which site is given priority for inspection
on a more frequent basis. During the site inspection, the field inspector ensures that erosion and sediment
control measures are implemented according to the approved plan and that no significant offsite
sedimentation is occurring. If the inspector recognizes a problem in the field, the inspector may require
that additional erosion control measures be installed and maintained in accordance with established
enforcement procedures.
Included in the chart below is the data on the number of inspections and enforcement actions carried out by
the E&SC Section during the time period of July 1, 2018 to June 30, 2019.
INSPECTIONS
Reporting Period: July 1, 2018, to June 30, 2019
Universe of active construction
sites
241
Number of active construction
sites ins ected
241
Number of construction sites
found to be non -compliant after
the initial inspection
11
Number of follow-up
inspections
11
ENFORCEMENT
Reporting Period: July 1, 2018 to June 30, 2019
Number of informal enforcement actions noncompliance
0
Number of formal enforcement actions without penalty
11
Number of formal enforcement actions with penalty
0
Number of stop work order issued
0
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 15 of 33

Post -Construction Stormwater Management for New Development and
Redevelopment
The City of Greensboro enforces local stormwater management and riparian buffer regulations in addition to
State approved water -supply watershed protection regulations. Throughout the NPDES permit compliance
period, the City of Greensboro will review existing ordinances and, if necessary, develop and implement
revised ordinances in order to implement the post -construction stormwater management program with the
goal of further minimizing impacts to surface water quality. 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.
BMP Summary Table
BMPs for Post -Construction Site Stormwater Runoff Controls
jFBMP
Measurable Goals
Comments
Post -Construction
Develop and adopt by ordinance a
The ordinance was adopted by
Stormwater Management
program to address stormwater
City Council on April 7, 2009 and
Program
runoff from new development and
became effective June 1, 2009.
redevelopment within 24 months
of the permit issue date.
Strategies which include
Developed strategies that include a
City of Greensboro Stormwater
BMPs appropriate for the
combination of structural and/or
Management Manual requires any
MS4
non-structural SCMs implemented
proposed structural SCM be
in concurrence with (a) above.
accompanied by an operation and
Provide a mechanism to require
maintenance plan and agreement
long-term operation and
concurrent to development plan
maintenance of structural SCMs.
approval. The city has an
Require annual inspection reports
extensive inspection program to
of permitted structural SCMs
ensure SCM's are maintained to
performed by a qualified
protect water quality.
professional.
Establish nutrient sensitive
Develop, adopt, and implement an
The Greensboro Land
waters (NSW) protection
ordinance to ensure that the best
Development Ordinance was
measures (for programs
management practices reduce
reviewed and modified to ensure
with development or
nutrient loading to the maximum
structural and non-structural
redevelopment draining to
extent practicable. In areas where
SCMs reduce nutrient loading to
NSW waters)
the Environmental Management
the maximum extent practicable.
Commission has approved a
Nutrient Sensitive Water Urban
Stormwater Management Program,
the provisions of that program
fulfill the nutrient loading
reduction requirement.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 16 of 33

BMP Summary Table — Continued
Deed Restrictions and
Protective Covenants
Impose or require recorded deed
restrictions, plats, and/or
protective covenants that ensure
development activities will
maintain the project consistent
with approved plans.
Current City of Greensboro Land
Development Ordinance requires
a maintenance note and recorded
maintenance agreement to be
placed on final plats stating the
maintenance responsibilities,
consistent with approved plans,
for the project SCM.
Establish a program under the
Coordinate with County health
Stormwater Division coordinates
Post -Construction minimum
department to control the known
with Guilford County Health
measure to control the sources
sources of fecal coliform from
Department to control the known
of fecal coliform to the
septic systems to the maximum
sources of fecal coliform from
maximum extent practicable.
extent practicable.
septic systems within the City's
jurisdictional limits to the
maximum extent practicable.
Additionally, the City's Water
Resources Department funds and
performs an ongoing sewer
rehabilitation program to
minimize and eliminate cross
connections between the storm
and sanitary sewer systems.
Operation and Maintenance
Require an operation and
City of Greensboro Stormwater
Plan
maintenance plan that ensures the
Division's development plan
adequate long-term operation of
review process requires a
the structural SCMs required by
stormwater management plan
the program. The operation and
and separate SCM operation and
maintenance plan may require the
maintenance plan (consistent
owner of each structural SCM to
with the provisions outlined in
submit a maintenance inspection
the State stormwater design
report on each structural SCM
manual) be submitted prior to
annually to the local program, or
receiving development plan
the maintenance inspections may
approval. Currently, the City of
be conducted annually by the
Greensboro Stormwater Division
Permittee.
conducts maintenance
inspections on SCMs within the
City's jurisdiction.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 17 of 33

BMP Summary Table — Continued
Educational materials and
Provide educational materials
Stormwater Division's Planning
training for developers
and training for developers. New
and Engineering Section notify
materials may be developed by
developers and engineers of
the permittee, or the permittee
ordinance changes via direct
may use materials adopted from
phone and e-mail, face-to-face
other programs and adapted to
meetings upon request regarding
the permittees new development
proposed site projects, Triad
and redevelopment program.
Real Estate and Building
Industry Coalition, televised City
Council meetings, providing
opportunity for public comment,
as well as posting the changes on
the City website.
Setbacks for Built -upon Areas
Require built -upon areas to be
The Greensboro Land
located at least 50 feet landward
Development Ordinance was
of all perennial and intermittent
reviewed and modified to require
surface waters except as provided
a 50 foot stream buffer in
for in the Permittees Post-
accordance with NPDES phase II
Construction Stormwater
requirements.
Ordinance. For purposes of this
In addition, the City of
section, a surface water shall be
Greensboro has updated the
present if the feature is shown on
riparian buffer requirements
either the most recent printed
according to the Jordan and
version of the soil survey map
Randleman Lake Rules. The
prepared by the Natural
"Table of Activities and
Resources Conservation Service
Structures in Stream Buffers
of the United States Department
(Zone 1 & Zone 2)" located in
of Agriculture or the most recent
Chapter 30 of the Greensboro
version of the 1:24,000 scale (7.5
Land Development Ordinance
minute) quadrangle topographic
determines the allowable uses
maps prepared by the United
within the 50' riparian buffer.
States Geologic Survey (USGS).
Relief from this requirement may
be allowed when surface waters
are not present in accordance
with the provisions of 15A
NCAC 02B .0233(3) (a).
Local Permit Issuance
Currently, Group, Site and Subdivision plans within Greensboro's jurisdiction are reviewed by the City's
Technical Review Committee (TRC) for compliance with applicable development regulations. TRC is an
interdepartmental team charged with enforcing development standards as they relate to Watershed
Protection, Stormwater Management, Water -Supply, Water Reclamation, Zoning, Transportation, Parks
and Recreation, Tree Preservation, etc. Approval by members of TRC is a prerequisite to the issuance of
a grading permit or building permit. The City has reviewed and modified the Greensboro Land
Development Ordinance in order to ensure that plans meet post -construction stormwater management
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 18 of 33

requirements as defined by 15A NCAC 2H.0126 (10). The final 15A NCAC 2H.0126 (10)(h) rules define
low and high density development thresholds and as such these thresholds and any associated permanent
structural control and riparian buffer requirements will be applied to applicable new development or re-
development within the City's jurisdictional area. These requirements have now been incorporated in the
Greensboro Land Development Ordinance to allow for enforcement by City staff prior to issuance of the
applicable construction permit. The post -construction stormwater requirements were adopted by City
Council on April 7, 2009 and became effective June 1, 2009. Additionally, the City amended the Land
Development Ordinance and adopted Jordan Lake Riparian Buffer requirements on November 9, 2010.
These rules became effective on December 1, 2010.
Structural SCM Operation and Maintenance
Greensboro mandates that all required structural stormwater control measures (SCMs) be placed in a
drainage maintenance and utility easement (DMUE) connected to the public right-of-way by a 20 foot
wide access easement. The DMUE and access easement for each SCM must be platted before any
certificate of occupancy is issued for the site. TRC-approved development plans for structural SCMs
include an operation and maintenance plan (consistent with the provisions outlined in the State minimum
design criteria) be submitted prior to receiving development plan approval. Furthermore, notes are
recorded on the plat indicating that the City has the right to access the site for SCM inspections and that
the owner will maintain the SCM per the approved maintenance plan or as directed by the City.
During the reporting period (July 1, 2018 to June 30, 2019), 468 privately owned stormwater SCMs were
inspected by City staff for performance and maintenance compliance. Twenty-one owners were issued a
Notice of Violation (NOV) for failing to complete the required maintenance items with one of the twenty-
one receiving an additional second NOV. Of the twenty-one sites with NOVs, seven have completed the
required SCM maintenance. The city is working with the property owners, through enforcement
procedures, to complete maintenance items on the fourteen remaining SCMs.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 19 of 33

Pollution Prevention/Good Housekeeping for Municipal Operations
Pollution Prevention and Good Housekeeping Programs are an important factor in the improvement of
stormwater runoff quality. Municipal departments that utilize various facilities currently implement good
housekeeping and pollution prevention programs. Additionally, the City Water Resources Department
works to ensure that pollution prevention and good housekeeping measures are being implemented at
other municipal facilities to the maximum extent practicable with the intent of improving stormwater
runoff quality discharged into receiving streams by those municipal facilities and their operations.
BMP Summary Table
BMPs for Pollution Prevention/Good Housekeeping Program
ism&==
Measurable Goals
Comments
Street Sweeping
Continue ongoing program with periodic
Ongoing program:
review.
Stormwater Management
and Field Operations
Department.
Loose Leaf Collection for
Continue ongoing program with periodic
Ongoing program:
Composting
review.
Stormwater Management
and Field Operations
Department.
Erosion and
City owned or otherwise public
Ongoing program:
Sedimentation Control
construction sites are regulated by NCDEQ,
City owned and other
Division of Energy, Mineral and Land
publicly funded projects
Resources for proper erosion and sediment
obtain appropriate state
control.
permits.
Staff Training/Site
The Stormwater Management Division of
Ongoing cooperative effort
Operator Education
Water Resources distributes education
by the City's departments
material for training employees on various
municipal operations.
Site Planning/Pollution
Develop and implement pollution
Ongoing effort by the City
Prevention Plan for
prevention plans that have been determined
of Greensboro.
Municipal Facilities
to have the potential to impact Water
Quality.
Site inspection and
The City maintains mapping programs that
The City's Stormwater
evaluation of facilities,
consist of all municipal facilities, as well as
Management Division has
operations including the
any related structural SCMs. City
identified a list of specific
MS4 system and
Stormwater Management maintains an
city facilities and ranked
associated structural
ongoing inspection program to monitor,
each of them according to
SCMs.
document and enforce stormwater
their potential to pollute.
discharges to the MS4 system.
Inspections of the high and
medium ranking facilities
have been conducted,
including documenting
areas where improvements
can be made to reduce the
potential of generating
polluted runoff.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 20 of 33

Affected Operations
The facilities listed in the following table are municipal operations that have been issued NPDES
Stormwater Discharge permits. These facilities have developed Municipal Pollution Prevention/Good
Housekeeping techniques in addition with the education and training material sent out.
Municipal Operation
Permit Number
City of Greensboro White St. Landfill
NCG120013
TZ Osborne WWTP
NCG110005
North Buffalo WWTP
NCG110004
Patton Avenue Service Center
NCGO80799
Greensboro Transit Authority (Bus Garage)
NCGO80893
Training
The City's Stormwater Management Division of Water Resources provides educational and technical
assistance for City facilities pertaining to pollution prevention plans and/or BMPs for the improvement of
overall environmental quality. In addition, the Stormwater Management Division also provides assistance
for City facilities pertaining to structural and non-structural stormwater BMPs for the improvement of
stormwater quality and/or quantity and BMP design and implementation.
The City has identified nine Departments that have a greater potential to contribute pollution to
stormwater runoff. The Departments involved in this program are as follows:
1. Coliseum
2. Engineering and Inspections
3. Field Operations
4. Finance (Equipment Services)
5.
Fire
6.
Parks and Recreation
7.
Police
8.
Transportation
9.
Water Resources
During the July 1, 2018 to June 30, 2019 reporting period, approximately 568 City of Greensboro
employees received training on municipal pollution prevention. This number includes our in house
pollution prevention DVD, Water Resources employee's training Videos and the Fire Department's in-
depth annual training of personnel on spill response and pollution prevention.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 21 of 33

City of Greensboro: Municipal PolIutionPrevention
Good Housekeeping Employee Training
Participation
10 �10
568 Employees Trained
o Water Resources ■ Fire V Parks & Recreation 0 Coliseum
The stormwater management division contacted representatives in the nine City departments listed above
to determine what they would like to see in new employee training materials. Once those needs were
identified, contact was made with municipalities throughout North Carolina. These municipalities shared
the materials they use as well as the strategies to achieve the Municipal Pollution Prevention Good
Housekeeping employee training goals. The City purchased the materials commonly used by other
municipalities and devised a distribution plan for FY 18-19 that best meets the employee training goals
utilizing the available resources. The materials (video/DVD) was placed on the online employee training
application and distributed to applicable departments.
Collectively, it is the responsibility of the entire City of Greensboro to maintain the NPDES city-wide
permit and enforce programs collaboratively. The objective is for all municipal departments that engage
in various operations to implement good housekeeping and pollution prevention methods in everyday
activities and to set a good example for the community to follow.
Site Inspection and Evaluation of Facilities
Stormwater personnel focused on site inspection and evaluation of city owned and operated facilities. A
complete list of all City owned and operated facilities was obtained from a GIS layer file. To prioritize
each facility, the history of spills/concerns, the proximity to a stream or stormwater conveyance system,
and the activities at a particular location were considered when ranking each facility as High, Medium or
Low. This ranking is further defined below.
High: Facilities in this category would have a large amount of outdoor processing activities, close
proximity to a stream and/or material storage on -site or obvious poor housekeeping issues.
Examples of these facilities would be golf courses, satellite fueling stations, facilities that
store salt for deicing roadways or the Coliseum that has many vendors using this property
at all times.
Medium: This category includes facilities that have some outdoor storage or processing, that may
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 22 of 33

not be in close proximity to a stream. Examples of these type facilities would be larger
parks, the science center, water treatment plants and the fire training center.
Low: A facility in low level ranking would have limited or no outdoor processing areas.
Examples of these facilities would be libraries, parking decks, rec centers and fire stations.
During the July 1, 2018 to June 30, 2019 reporting period, the Stormwater Management Division
finalized the SOP, ranked all 126 facilities that do not have a NPDES permit. The stormwater
management division ranked 23 facilities as having a high or medium risk of generating polluted runoff.
The six high-ranking facilities were completed during the FYI 6-17. The stormwater management division
began conducting inspections of the 17 municipal facilities with a medium ranking during this reporting
cycle and completed 1-facility inspection. In addition, the Stormwater Management Division documented
improvements made at high -risk facilities that were inspected during FY 16-17.
W-0" Municipal Operation
Solid Waste Transfer Station M
Maintenance and Inspections
The City of Greensboro Stormwater Maintenance Section, within the City's Field Operations Department,
maintains open and closed stormwater infrastructure and drainage conveyance systems that carry public
runoff within the MS4 service area. This section also performs stream maintenance activities and
preventative maintenance on most public stormwater infrastructure.
The City's Stormwater Management Division identifies and inspects industrial and related facilities that
may discharge stormwater into either the MS4 or receiving streams in Greensboro, and also assists the
local industrial community in the development and implementation of appropriate stormwater runoff
controls. In addition, the City has an ongoing litter pick-up program to clear trash and other floatables
from roadways, which helps keep them out of the storm drainage system and surface waters.
Vehicular Operations
The City of Greensboro's vehicular operation centers utilize the City's hazardous waste program to
recycle or dispose used oil, antifreeze, batteries, and spare parts and used chemicals. A new salt storage
barn was constructed in fall 2002 as a BMP to prevent salt stormwater runoff from entering receiving
streams.
Waste Disposal
Waste materials generated from the City's day-to-day activities are managed according to local and state
regulations and vendors utilized by Greensboro are audited to ensure environmental compliance. With
the ongoing public education and awareness programs, the City will continue to facilitate staff meetings to
inform staff of all new and related regulations/programs corresponding with the Municipal Pollution
Prevention and Good Housekeeping Program.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 23 of 33

Examples of Waste Disposal Programs include:
• Hazardous Waste Program
• Solid Waste Recycling
• Lead Disposal Program
• Oil Disposal Program
• Water Treatment Chemicals Disposal Program
Program to Monitor and Evaluate Storm Water Discharges to the Municipal System
The City of Greensboro has developed and implemented an industrial facilities inspection program during
the first two permit terms. During the current permit term, the inspection program will be reviewed and
revised to reflect current permit conditions. Industrial facilities subject to Section 313 of Title III of the
Superfund Amendments and Reauthorization Act of 1985 (SARA), and industrial facilities that the City
determines to be contributing or have the potential to contribute a substantial pollutant loading to the
municipal separate storm sewer system will be inventoried and evaluated.
BMP Summary Table
BMPs for Monitoring and Evaluating Storm Water Discharges to the MS4
BMP
Measurable Goals
Comments
Maintain Inventory of Industrial Sites
The City maintains an
The City will update and
inventory of all NPDES
revise list annually.
permitted industrial facilities.
The City will add additional
facilities to list that meet the
SARA Title III (Section 313)
criteria or that contribute
substantial pollutant loading
to the MS4 system.
Inspection Program
The City has developed a
The City has an ongoing
formal inspection program
industrial inspection program
for evaluating industrial
with a goal of visiting all
facilities. This inspection
listed industrial facilities
program will be expanded to
once per permit cycle.
include any facility on the
Annual training is conducted
above stated list.
for City staff on specific
inspection procedures and
staff coordinates with
NCDEQ on a regular basis to
be trained on any issues or
permit updates.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 24 of 33

BMP Summary Table — Continued
Establish and Implement Measures to
The City has developed the
The City has a strong
Evaluate Commercial and Industrial
industrial facilities inspection
working relationship with the
Facilities discharging stormwater to
program to evaluate those
NCDEQ regional office and
the City's MS4
facilities on the above list
county officials. The City's
and ensure all permit
enforcement procedures are
conditions are being met and
utilized when water quality
discharges to the MS4 are not
violations are encountered
considered substantive.
and follow up actions are
deemed necessary. NPDES
permit deficiencies are
addressed in written
notification and are also
forwarded to NCDEQ
(agency with permitting
authority).
During the reporting period (July 1, 2018, to June 30, 2019), a total of 12 NPDES permitted facilities
were inspected by City staff. Of these 12 inspections, one was also listed in the Toxics Release Inventory.
No enforcement action was warranted from these inspections. The number of facility inspections varies
from year to year, with some years having more inspections than others. This variation in facility
inspections is due to a previous scheduling agreement between the City of Greensboro and NCDEQ to
avoid overlapping inspections of NPDES permitted facilities.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 25 of 33

Water Quality Assessment and Monitoring
The City of Greensboro has developed and implemented a comprehensive water quality monitoring and
assessment program to evaluate the impacts on water quality.
BMP Summary Table
BMPs for Water Quality Assessment and Monitoring
BMP
Ir
Measurable Goals
Comments
Water Quality Assessment and
A DRAFT City of Greensboro
Draft document was submitted
Monitoring Plan
Water Quality Assessment and
to NCDEQ for comment and
Monitoring Plan was submitted
approval within 12 months of
within 12 months of permit
permit issuance as required.
issuance as required by the
NPDES permit.
Water Quality Monitoring
The City will implement the
The City implemented the
water quality assessment and
submitted water quality
monitoring plan in accordance
monitoring plan January 1,
with NCDEQ and the permit
2009.
schedule.
Revisions to the Water Quality
The City will conduct an annual
The City will review and revise
Assessment and Monitoring Plan
review, revise as appropriate,
annually and coordinate with
and submit any revisions to
NCDEQ any proposed changes.
NCDEQ for approval.
The most recent revision
occurred in 2017 and was sent
to NCDEQ on 8/15/2017.
Total Maximum Daily Load (TMDL)
The City of Greensboro has an EPA and NCDEQ approved TMDL for Fecal Coliform bacteria for North
Buffalo Creek. The permittee will utilize BMPs within the six minimum measures to address the
permittee's assigned NPDES regulated stormwater waste load allocation (WLA) identified in the
approved TMDL to the maximum extent practicable and to the extent authorized by law. Resolute efforts
are being made to determine the most efficient best management practices that address the MS4 NPDES
regulated Waste Load Allocation identified in the TMDL. Current efforts are continually re-evaluated and
adapted as needed. More importantly, new ideas are continuously shared and assessed, with the ultimate
goal of improving and protecting water quality.
An assessment of available data, BMP strategies, and TMDL Watershed Plan effectiveness will be
conducted and utilized to define the appropriate progress and schedule of the watershed plan within the
context of the Maximum Extent Practical (MEP) standard. Activities conducted throughout the program
implementation schedule to address the MS4 NPDES regulated waste load allocation (WLA) identified in
the TMDL will be evaluated and defined as to the collective contribution to the watershed plan. The
results of the analysis will be utilized to prioritize local funding aimed at elimination of the most
significant portion of the MS4 waste load allocation for the least resources.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 26 of 33

BMP Summary Table
BMPs for Total Maximum Daily Load
BMP
Measurable Goals
Comments
(A) Identify, describe and
Within 24 months the permittee shall
Description, maps, and
map watershed, outfalls, and
prepare a plan that:
outfall information is
streams
• Identifies the watershed(s) subject to an
noted in BMP Narratives
approved TMDL with an approved
following this table.
Waste Load Allocation (WLAs)
assigned to the permittee,
• Includes a description of the
watershed(s),
• Includes a map of watershed(s) showing
streams & outfalls
• 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 to discover and
locate other 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.
(B) Existing measures
Within 24 months the Permittee's plan:
Measures include
• Shall describe existing measures being
education, sampling,
implemented by the Permittee designed
citizen concerns,
to achieve the MS4's NPDES WLA and
industrial inspections, etc.
to reduce the TMDL pollutant of
See information in BMP
concern to the MEP within the
Narratives following this
watershed to which the TMDL applies;
table for a more complete
and
list and descriptions.
• 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 NCDEQ.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 27 of 33

BMP Summary Table — Continued
C) Assessment of Available
Within 24 months the permittee's plan shall
An assessment of the
Monitoring Data
include an assessment of available
programmatic
monitoring data. Where long-term data is
management measures,
available, this assessment should include an
existing TMDL data,
analysis of the data to show trends.
relevant watershed data,
monitoring data, etc., is
performed periodically.
An assessment of
activities conducted under
the TMDL plan will be
performed to evaluate the
overall effectiveness of
the watershed plan and
make any adjustments
deemed necessary. The
assessment will be used,
where possible, to
evaluate the performance
of existing BMPs and
identify additional BMP
strategies as necessary.
(D) Monitoring Plan
Within 36 months the permittee shall
The monitoring plan for
develop and submit to the Division a
the TMDL Watershed
Monitoring Plan for the permittee's
Plan includes current
assigned NPDES regulated WLA as
monitoring programs and
specified in the TMDL. The permittee shall
procedures that will be
maintain and implement the Monitoring
updated as necessary to
Plan as additional outfalls are identified and
achieve the City's waste
as accumulating data may suggest.
load allocation (WLA)
Following any review and comment by the
and reduce the pollutant of
Division the permittee shall incorporate any
concern (POC) to the
necessary changes to monitoring plan and
maximum extent possible.
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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 28 of 33

BMP Summary Table — Continued
(E) Additional Measures
Within 36 months the permittee's plan
Measures include the
shall:
FOG Program, sanitary
• Describe additional measures to be
sewer rehabilitation, pet
implemented by the permittee
waste stations, and the use
designed to achieve the permittee's
of new technology, and
MS4's NPDES WLA and to reduce
the SSO Reduction
the TMDL pollutant of concern to
Committee. See
• the MEP within the watershed to
which the TMDL applies; and
information in BMP
Narratives following this
Provide an explanation as to how those
table.
measures are designed to achieve the
permittee's MS4's NPDES regulated WLA
to the MEP within the watershed to which
the TMDL applies.
(F) Implementation Plan
Within 48 months the permittee's plan
Current BMPs will
shall:
continue to be
• Describe the measures to be
implemented to achieve
implemented within the remainder of
the Waste Load
the permit term designed to achieve
Allocation to reduce the
the MS4's NPDES WLA and to
pollutant of concern to the
reduce the TMDL pollutant of
MEP. This includes
concern to the MEP and
existing BMPs and the
Identify a schedule, subject to NCDEQ
exploration of additional
approval, for completing the activities.
opportunities.
(G) Incremental Success
The permittee's plan must outline ways to
The TMDL plan describes
track and report successes designed to
ways to track and report
achieve the MS4's NPDES regulated WLA
successes based on the
and to reduce the TMDL pollutant of
TMDL BMPs and goals
concern to MEP within the watershed to
designed to achieve the
which the TMDL applies.
Waste Load Allocation to
reduce the pollutant of
concern to the MEP.
(H) Reporting
The permittee shall conduct and submit to
Following the schedule
the Division an annual assessment of the
per the permit, the TMDL
program designed to achieve the MS4's
watershed plan addresses
NPDES WLA and to reduce the TMDL
and reports on the TMDL
pollutant of concern to the MEP within the
program.
watershed to which the TMDL applies. Any
monitoring data and information generated
from the previous year are to be submitted
with each annual report.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 29 of 33

BMP Narratives
1) Identify, Describe and Map Watershed, Outfalls, and Streams (A)
Watershed Description
The North Buffalo Creek watershed is located in Greensboro, North Carolina (Guilford County), and is in
the headwaters of the Cape Fear River Basin. The eastern flowing stream eventually feeds into the Haw
River. The watershed is represented by small floodplain streams that have some bedrock outcroppings and
are surrounded by gently sloping uplands. North Buffalo Creek's headwaters lie entirely within urbanized
areas (commercial, industrial, and residential with high [>28%] impervious area) in the city of
Greensboro (population >287,000).
As outlined in the City's TMDL Watershed Plan, the compliance point for Upper North Buffalo Creek
TMDL is located where Summit Avenue crosses over North Buffalo Creek. The drainage area from the
headwaters to this compliance point is 21.8 miz and incorporates 8.7 miles of stream. The area is generally
deemed as built out, in that no major future land use changes are predicted. The area is 38% residential,
15% right-of-ways, and 20% forest. Impervious surface constitutes approximately 26% of the watershed.
In January of 2009 the City started collecting water quality samples at the compliance point on a monthly
basis. Samples are analyzed for both physical and analytical parameters.
Map of Drainage area from Headwaters to Fecal Coliform TMDL Compliance Point:
Upper North Buffalo Creek Watershed
TMDL for Fecal Coliform
v
� Jai
V M
I r ;
J ,
' Complaince Point
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 30 of 33

Outfall Locations
MS4 outfalls have been determined through GIS and the City's ongoing stormwater inventory process.
See map below for outfall locations within the TMDL watershed.
Schedule for Locating New Outfalls
Unknown major NPDES outfalls will be identified utilizing the ongoing stormwater inventory procedures
through subsequent QAQC checks of various sub basins, ongoing collection efforts involved with new
development, and updates due to drainage system repairs and maintenance. Any new outfalls and/or
newly identified outfalls will be recorded and mapped on a routine basis.
Map of NPDES Outfalls located within the Fecal Coliform TMDL Compliance Area
Outfalls in Upper North Buffalo Creek Watershed
2) Existing Measures (B)
Outfall Screening
NPDES outfalls are investigated/screened on a routine basis to determine illicit discharges or improper
disposals. Locations are determined based on random selection and areas that have not been done before.
Any noted concerns are investigated further, which may include tracking, obtaining readings for physical
parameters, and/or taking samples to be analyzed in the field or by the contracted lab.
Education
The following are examples of TMDL/pollution education and outreach:
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 31 of 33

• Citizen participation with the Drain Marker program, Adopt -a -Stream program, pet waste stations,
etc., to encourage citizens to have personal involvement
• Partnering with communities and organizations and using the media for a broad -scale approach to
pollution education and prevention
• Educating citizens about TMDLs via the City's website
Small -Quantity Polluters Program
As well as general education, specific potential polluters in the community are targeted and educated
regarding housekeeping practices and proper waste disposal. This Pollution Prevention Program entails
water quality staff to inspect and educate businesses that are common polluters, such as painters,
landscapers, ready -mix concrete companies, auto repair shops, mobile washers, restaurants, etc. This
ongoing prevention program is highly regarded and has been determined to be a worthwhile endeavor in
keeping pollution from streams and other water sources.
Fixed Interval Sampling
Monthly sampling and assessments are performed, including the analysis of results and the need for
outfall follow-ups; this includes a sampling site at the compliance point in additional to three other
monitoring sites in the TMDL watershed. When data suggests an elevated level of fecal coliform,
increased follow-up sampling and investigations take place to determine the potential source.
Sanitary Sewer Overflow (SSO) Prevention
Ongoing evaluation of citywide SSOs is being used to direct resources for maintenance and rehabilitation
of sanitary sewer lines in the TMDL watershed in an effort to prevent overflows and exfiltration.
Field Observations
Issues discovered by staff through inventory collections, outfall screenings, etc., and water quality staff
address potential issues.
Public Concerns/Reports
Reports are followed up by investigating, tracking, resolving, and enforcing violations when applicable.
Over the past reporting year, illicit connections have been identified and eliminated throughout the city.
Industrial Inspection Program
NPDES permitted facilities and TRI facilities are inspected, focusing on a review of the Stormwater
Prevention Pollution Plan, spill prevention and response procedures, employee training, housekeeping
practices, and outfall monitoring.
3) Additional Measures (E)
Fats, Oils, and Grease (FOG) Program
This ongoing program seeks to reduce the number of SSOs due to issues caused by oil and grease.
Sanitary Sewer Rehabilitation
During the reporting year, over 21,000 linear feet of sewer underwent rehabilitation in the North Buffalo
watershed up to the compliance point.
Pet Waste Stations
Pet waste stations in the TMDL watershed have been mapped, including both private stations and those
maintained by the City of Greensboro. Within this watershed, there are approximately 113 documented
pet waste stations (84 private, 29 city maintained).
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 32 of 33

New Technology
New technology is always being assessed in an effort to be proactive regarding the City's wastewater
collection system. Acoustical testing and assessment tools (such as SL-RAT—Sewer Line Rapid
Assessment Tool), could help reduce the number of SSOs, therefore reducing the WLA for the POC. The
Operations Division continually explores new and updated equipment to prevent SSOs and to investigate
or repair sewer lines. In addition, inflatable plugs are being used when applicable, preventing overflows
from entering surface waters.
SSO Reduction Committee
This committee is compiled of representatives from multiple divisions within the Water Resources
Department. The goal of the committee is to take a holistic approach to preventing SSOs by analyzing
past overflows using GIS, the work order management system, and staffs institutional knowledge to
implement enhanced reduction strategies.
Threatened or Endangered Species Protection Program
The City of Greensboro currently does not have any federally listed aquatic animal species that are listed
as threatened or endangered by the U.S. Fish and Wildlife Service or the National Marine Fisheries
Service under the provisions of the Endangered Species Act.
For more information on the City of Greensboro's NPDES MS4 Discharge Permit and associated
Stormwater Quality Management Program Plan, please visit the Stormwater website at:
www.greensboro-ne.gov/stormwater
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) October 31, 2019
NPDES Permit No. NCS000248 Page 33 of 33

CITY OF GREENSBORO
NPDES MS4 STORMWATER DISCHARGE PERMIT
Permit # NCS000248
STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
2017/2018 Annual Report
Prepared for:
North Carolina Department of Environment & Natural Resources
North Carolina Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Prepared by:
City of Greensboro
Water Resources Department - Stormwater Management Division
P.O. Box 3136
Greensboro, NC 27402-3136
GREENSBORO
September 2018

TABLE OF CONTENTS
Page
ExecutiveSummary --------------------------------------------------------------------------------------------------------------------------------- I
Significant Receiving Waters and Watersheds -------------------------------------------------------------------------- 1
OrganizationalStructure ------------------------------------------------------------------------------------------------------------- 3
Legal Authority --------------------
Funding---------------------------------------------------------------------------------------------------------------5
Stormwater Quality Management Program Plan -
Public Education and Outreach Program ...............
BMP Summary Table ---------------------------------
Target Audience ------------------------------------------
Identifying Pollutants and Target Sources
Public Outreach Narrative Program ----------.
Public Involvement and Participation____
BMP Summary Table -----------------
Target Audience__________________________
Participation Program Narrative
Illicit Discharge Detection and Elimination
no
---- 6
----------------------------------- 6
7
------------------------------------
------------------------------------8
9
9
9
10
BMPSummary Table ----------------------------------------------------------------------------------------------------- 11
Detection and Elimination 12
----------------------------------------------------------------------------------------------
LocatingPriority Areas --------------------------------------------------------------------------------------------------- 12
Removing Sources of Illicit Discharges ------------------------------------------------------------------------ 13
Construction Site Stormwater Runoff Control 14
--------------------------------------------------------------------------
BMPSummary Table ----------------------------------------------------------------------------------------------------- 14
E&SC Plan Review 14
---------------------------------------------------------------------------------------------------------
E&SC Program Implementation and Enforcement ------------------------------------------------------- 14
Construction Site Inspections ----------------------------------------------------------------------------------------- 15
Post -Construction Stormwater in New and Redevelopment.
BMP Summary Table ..................................................
Local Permit Issuance
-------------------------------------------------
Structural SCM Operation and Maintenance ------------.
Pollution Prevention/Good Housekeeping for Municipal Operations
BMPSummary Table ----------------------------------------------------------------
Affected Operations -------------------------------------------------------------------
Site Inspection and Evaluation of Facilities
16
16
18
19
20
20
21
21
22

Maintenance and Inspections ----------------------------------------------------------------------------------------- 23
VehicularOperations-----------------------------------------------------------------------------------23
WasteDisposal--------------------------------------------------------------------------------------------------- 23
Program to Monitor and Evaluate Stormwater Discharges to the Municipal System ------------
24
BMPSummary Table ----------------------------------------------------------------------------------------------------- 24
Water Quality Assessment and Monitoring Program ---------------------------------------------------------------- 26
BMPSummary Table ----------------------------------------------------------------------------------------------------- 26
Total Maximum Daily Load(TMDL)----------------------------------------------------------------------------------------
26
BMPSummary Table -----------------------------------------------------------------------------------------------------
27
BMP Narratives
30
Identify, Describe and Map Watershed, Outfalls, and Streams -----------------------------------
30
ExistingMeasures-------------------------------------------------------------------------------31
Additional Measures
32
Threatened or Endangered Species Protection Program ----------------------------------------------------------- 33

Stormwater Quality Management Program Plan (Stormwater Plan)
for
Greensboro's NPDES MS4 Discharge Permit
EXECUTIVE SUMMARY
The City of Greensboro's initial National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Discharge Permit (Permit Number NCS000248) became effective on
December 30, 1994. The North Carolina Department of Environmental Quality (NCDEQ) issued the City of
Greensboro's current permit on March 1, 2013, for a period of five years with an effective expiration date of
February 28, 2018. This document includes a summary of NPDES stormwater quality management
programs and activities implemented, scheduled to be implemented, or completed during the July 1, 2017 -
June 30, 2018 permit term.
The City's NPDES stormwater permit, and associated Stormwater Quality Management Program Plan
(Stormwater Plan), is designed to control the discharge of pollutants from the MS4 to the Maximum Extent
Practicable (MEP).
Significant Receiving Waters and Watersheds
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 towards
the Haw River, while a smaller portion of the City area drains south towards the Deep River. The North and
South Buffalo Creek Watersheds drain the majority of the City's central urbanized area eastward towards
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 131.94 square miles, represents just over 1 % of the 9,322 square mile Cape Fear Basin.
Existing land uses within Greensboro are broadly classified in Table 1.
Table 1— Land Uses in the City of Greensboro
Land Use Classification
Approximate % within Corporate Limits
Residential
39%
Commercial
13%
Industrial
7%
Open Space/Wooded/Undeveloped
41 %
Total (land use does not include public streets and water bodies)
100%
Table 2 shows a listing of the primary streams located within the City of Greensboro MS4 service area.
Water quality classifications of receiving streams are provided, along with their use support ratings and
key water quality challenges.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 1 of 33

Table 2 - Primary Receiving Streams within Greensboro Service Area (Upper Cape Fear River
Basin)
Receiving
Stream
Water Quality
Use
Support
Water Quality Issues
303(d) List
Stream Name
Segment
Classification*
Rating
Impaired biological
yes
Reedy Fork
Within
WS-III;NSW,
Impaired
integrity, Chlorophyll a,
Creek
corporate limits
WS-III;NSW CA
Turbidity
Brush Creek
Within
WS-III;NSW
Impaired
Impaired biological
Yes
corporate limits
integrity, Chlorophyll a
Horsepen
Within
WS-III;NSW,
Impaired biological
Yes
Creek
corporate limits
WS-III;NSW CA
Impaired
integrity
Fecal coliform,
Yes
North Buffalo
Within
WS-V;NSW
Impaired
Impaired biological
Creek
corporate limits
integrity, Zinc, Cooper,
NO2+NO3-N
South Buffalo
Within
Turbidity, Impaired
Yes
Creek
corporate limits
WS-V;NSW
Impaired
biological integrity,
Zinc
Yes
East Fork
Within
WS-IV, WS-
Impaired biological
Deep River
corporate limits
IV;CA
Impaired
integrity, Turbidity,
Fecal coliform
Water Quality Classifications:
NSW = Nutrient Sensitive Waters
WS = Water Supply classification (degree of protective measures).
C = Class C waters — general use category (maintain aquatic life and biological integrity, wildlife, secondary
recreation, etc.)
CA = Critical Area
** Use Support Rating (the degree to which the water body supports its designated uses):
FS = Fully Supporting
PS = Partially Supporting
NS = Not Supporting
NR = Not Rated
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 2 of 33

Organizational Structure
The Stormwater Management Utility is one of seven divisions of the City's Water Resources Department
(also including 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.
The following bullet points briefly document the overall organizational structure and functional
responsibilities of the City's Stormwater Plan. 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 substantive ways.
• 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; best management practice (BMP) evaluations and BMP crediting; BMP 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 of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 3 of 33

• 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
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 -storm water 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;
• 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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 4 of 33

Funding
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, along with the desire 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 non-structural 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 eleven 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 2017-2018 Budget Expenses
$11,952,214 Operations
Administration Management
6%� 3% Water Quality &
Monitoring
Planning & 6%
Engineering
Construction 4%
39% F/Z
�PUbIIC Education &
490
Maintenance Awareness
23% 1%
Street
Cleaning
18%
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 5 of 33

STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
The following information is the City's stormwater quality management program plan (Stormwater Plan)
identifying programmatic measures to comply with the City's NPDES permit to the maximum extent
practicable. BMP summary tables for each of the regulatory areas are provided, along with narrative for
key programs and updates or accomplishments completed during the last permit year (July 1, 2017 - June
30, 2018).
Public Education and Outreach
BMP Summary Table
BMPs for Public Education and Outreach Program
BMP
Measurable Goals
Comments
Pollution
Distribute brochures through event displays, billing
Ongoing effort by the
Prevention
inserts, volunteer participants, new customer packets
Stormwater Program.
Brochures
at Customer Service counter, informational displays,
field representatives and direct mailings to target
groups. Various issues addressed include proper
disposal of oil and other toxic materials, sediment and
erosion control issues, proper application and handling
of fertilizers and pesticides, litter prevention, pollution
reporting and awareness, etc. for different age groups.
Website
Maintain the Stormwater Management Website.
Ongoing effort by the
Contains information about pollution prevention,
Stormwater Program.
stormwater technology and practices. Provides
contacts and forms for pollution reporting and
http://www.greensboro-
nc. gov/stormwater
information requests.
Stormwater
Several videos have been created to educate residents
Ongoing effort by the
Videos
and school children about various pollution prevention
Stormwater Program.
measures and volunteer opportunities. Videos air
Additional videos may be
periodically on Greensboro Television Network
created as issues arise.
(GTN) that appears on the local cable affiliate, while
others air on local stations 2, 8, 12, and Spectrum
Cable as part of an advertising campaign.
Media
Advertise on TV, radio, newspaper, GTN, web
Ongoing effort by the
Campaign
banners, and in city newsletters to the extent
Stormwater Program.
practicable.
Helpline
Established a helpline for citizens to report pollution,
Ongoing effort by the
address water quality and drainage concerns, as well
Stormwater Program and
as volunteer opportunities.
City Contact Center.
School and Civic
Develop and present educational talks and activities
Ongoing effort by the
Group
for schools and civic groups, including our
Stormwater Program.
Presentations
Enviroscape Model.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 6 of 33

BMP Summary Table — Continued
Targeted
Develop flyer /brochures to inform
Ongoing effort by the Stormwater
Commercial
businesses that have a potential of illicit
Program; site visits initiated in Mid -
Education
discharges or improper disposals to the
2003.
Initiative
stormwater conveyance system.
Cooperative
The City of Greensboro seeks reasonable
Ongoing effort by the Stormwater
Efforts
opportunities to partner with neighboring
Program.
communities for joint educational programs.
http://www.piedmontwaterqualit.
Example: "Piedmont Triad Water Quality
Partnership (PTWQP) " and also the North
Carolina Cooperative Extension Services and
Guilford County Soil and Water
Conservation District.
Watershed
Road signs have been installed at stream
Ongoing effort by the Stormwater
Signs
crossings identifying the watershed and
Program.
stream name.
Target Audience
Current and future target audiences for stormwater education include:
I. General Public, especially homeowners — applies lawn care products, uses chemicals for home and
auto maintenance, makes decisions about drainage issues on their properties and participates in
volunteer opportunities.
2. Structural SCM Owners — maintenance issues and education about proper BMP maintenance and
responsibilities.
3. Industries — potential of water quality impacts due to improper material handling, improper
housekeeping practices and illicit discharges.
4. Commercial landscapers, restaurants, mobile washers, concrete companies, painters, drywall
installers, masons, automotive repair facilities and kennels — potential water quality impacts due to
illegal dumping of wastewater into storm drains and improper chemical handling and application.
5. School age children are educated about the importance of protecting water quality through the
distribution of elementary school homework folders in our local school system. Our sponsorship
ad provided an opportunity for us to reach over 7,600 students and their families. In partnership
with Guilford County Soil and Water Conservation District over 250 middle and high school
students have completed in the NC Area III Envirothon. During the event, students train and
complete in areas of soils, aquatics, wildlife, forestry, and current environmental issues.
Identifying Target Pollutants and Sources
Target pollution sources for stormwater education include:
1. Illicit Connections — The discharge of non-stormwater into the stormwater conveyance system can
result in biological mortality in receiving streams due to discharges.
2. Improper Disposal — The discharge of used motor oil, oil & grease, organic materials (grass and
leaves), and various other pollutants into storm drains can be a problem on construction sites,
commercial and residential areas, etc.
3. Water Quality Monitoring — Routine water quality monitoring data will be evaluated to identify target
pollutants which impact water quality.
4. Pet Waste — Greensboro has developed a TMDL for fecal coliform for the portion of North Buffalo
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 7 of 33

Creek located within the jurisdictional limits. As a management measure, the City will generate
educational literature targeting pet owners on the need to pick up after their pet in order to protect
water quality. Additionally, staff has observed that a number of public parks and homeowner's
associations have installed pet waste bag dispensers and or signage to encourage proper disposal of
pet waste. As a part of the At Your Service program, information was sent out to residents regarding
the proper way to dispose of pet waste.
5. Lawns and Gardens — Lawn care chemicals may enter storm drains due to improper application. Yard
waste may also be improperly placed into storm drains. These can create blockages in the stormwater
conveyance system and cause decreased dissolved oxygen in streams. The Clean Streams Program
educates commercial landscape professionals on the proper application of fertilizer and pesticides, as
well as aquatic pesticides. Commercial landscape professionals have an opportunity to receive
pesticide credit for successful completion.
6. Auto Repair Shops — Many auto repair shops have interior drains that have the potential to be
illicit connections (such as older buildings or sites that were previously a different business type).
As these locations are identified and dye -testing is conducted, owners and staff are made aware of
proper house -keeping practices, including awareness of interior drains and their resulting
destinations (i.e., either storm or sanitary sewers).
7. Mobile Auto Washers — car washing activities can generate potentially harmful wash water. An
educational and inspection program targeting mobile auto washers on containment, collection, and
disposal of wash water has been developed.
8. Restaurants — Many restaurants have Good Housekeeping issues related to disposal of cooking oil,
process wastewater generated by cleaning activities, and outdoor storage areas such as trash
dumpsters and grease containers that can adversely impact water quality. An educational and
inspection program targeting restaurants has been developed and implemented during this
reporting period.
Public Outreach Program Narrative
Outreach mechanisms are described in the BMP summary table above. Over the permit period,
Greensboro expects to reach the majority of the approximately 287,000 individuals in its MS4 service
area, as well as individuals in surrounding service areas. Everyone who receives a water/sewer bill will
occasionally receive stormwater education messages in the City's citizen newsletter, for example, the "At
Your Service" newsletter. Individuals are also periodically exposed to various stormwater related
messages that are shown on our local governmental broadcast station. For those who do not receive a bill
or do not read the newsletter, various media campaigns are featured on TV, radio, and newspaper.
Combined together, the media outlets are designed to reach the citizens of Greensboro. For citizens who
speak Spanish, some materials will be printed in English and Spanish. The City also utilizes a local
Spanish radio station and newspaper to deliver various educational messages.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 8 of 33

Public Involvement and Participation
BMP Summary Table
BMPs for Public Involvement and Participation Program
BMP
Measurable Goals
Comments
Adopt -a -Stream
Developed an Adopt -a -Stream Program.
Ongoing effort by the
Volunteers must pick up trash from their adopted
Stormwater Program.
segment of stream twice per year.
Drain Marker
Developed a Drain Marker Program. Volunteers
Ongoing effort by the
Program
have attached signs to Greensboro's storm drains.
Stormwater Program.
Adopt -a -Street
Developed an Adopt -a -Street Program.
Ongoing effort administered
Volunteers must pick up trash from their adopted
by the City's Field Operations
segment four times per year.
Department.
Stormwater
Board established to help guide Stormwater
Stormwater Advisory Board
Advisory Board
program on important community issues.
reconvenes as needed to
address community issues.
Annual Clean-up
Promote the Great American Clean-up, NC Big
Ongoing effort by the City's
Events
Sweep, and Guilford Creek Week.
Parks and Recreation
Department.
Poster Contest
Water quality, water conservation and soil
Ongoing effort administered
conservation poster contest available for
by the Guilford County Soil
elementary students in the Guilford County
and Water Conservation
School System.
District and Stormwater
Program.
Neighbor Woods
Developed a Neighbor Woods Program, which
Ongoing effort administered
Program
encourages community wide tree planting and re-
by the City's Planning
vegetation efforts.
Department.
Educational
Power of Wetlands (POW), Wonders of Wetlands
Ongoing effort administered
Workshops
(WOW) and Project Water Education for
by the Greensboro Public
Teachers (WET) workshops offered as a resource
Library, Guilford County Soil
for educators.
and Water Conservation
District, and the Parks and
Recreation Department.
Household
Promote proper disposal of harmful chemicals
Ongoing effort by the City's
Hazardous Waste
through the Household Hazardous Waste
Field Operations Department.
Collection
Collection Center.
Fats, Oils, and
Program designed to prevent the excessive
Ongoing effort by the
Grease Inspection
introduction of oil, grease, and fats into the
Stormwater Program and the
Program
sanitary sewer system and the wastewater
Industrial Pretreatment
collection system, which helps prevent sanitary
Division.
sewer over flows.
Target Audience
Target audiences for the public involvement program include representative age, ethnic, and economic
groups in Greensboro, from individuals to businesses. For local citizens who speak Spanish, some materials
to promote volunteer programs are printed in both English and Spanish. A local Spanish radio station and
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 9 of 33

newspaper will also be used for advertising on select campaigns.
Participation Program Narrative
The public is involved in the City's Stormwater Management Program. The following are ongoing
programs that are available in the community.
• Public Hearings
Public hearings are held to address key programs, such as, stream corridor concerns in the
community including restoration projects. Additionally, City Council meetings serve as
public hearing opportunities.
Working with Citizen Volunteers Willing to Educate Others About the Program
As part of the drain marker program, for example, volunteers hang an information piece on
the mailboxes of neighborhood residents where drain markers are installed.
Volunteer Monitoring or Stream Clean-up Activities
As part of our Adopt -a -Stream Program, volunteers are asked to note stream conditions on
their reporting form. The volunteers are required to clean the stream twice per year. Many
also participate in the NC Big Sweep, along with many others who have not formally
adopted a stream.
• Flood Advisory Committee
As part of the National Flood Insurance Program (NFIP) Community Rating System
(CRS), communities are challenged with reducing the impact of flooding on private and
public structures. The flood advisory committee was formed through a partnership with
Guilford County Planning Department to communicate important messages. Topics
covered include discussions about flood hazards, flood safety, flood insurance and vital
ways to protect property, and natural floodplain benefits.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 10 of 33

Illicit Discharge Detection and Elimination
The City of Greensboro maintains a program to identify and eliminate illicit discharges and improper
disposals from its MS4 service area.
BMP Summary Table
BMPs for Illicit Discharge Detection and Elimination (IDDE) Program
BMP
Measurable Goals
Comments
Implementation and
Enforce current Stormwater Management
Ongoing program by the
enforcement of
Ordinance (Chapter 30 of the Greensboro
Water Quality Section;
Stormwater Management
Land Development Ordinance) requirements
Ordinance
pertaining to the illicit discharge and improper
dis osal ofpollutants and waste.
Stream water quality
Conduct routine chemical and physical water
Ongoing program by the
monitoring
quality sampling of major streams. Analyze
Water Quality Section
data, detect potential illicit discharges, and
prioritize locations for follow-up investigation.
Response and
Maintain dedicated helpline and field calls
Ongoing program by the
investigation of citizens'
related to pollution concerns and
Water Quality Section;
concerns
environmental questions from citizens.
Public Education and
Provide staff response to pollution concerns.
Awareness Section; City
Contact Center
Develop and maintain
Create map and inventory procedures for the
Ongoing program by the
storm sewer system
collection of major outfalls that discharge to
Stormwater Management
inventory base map of
waters of the State.
Division, Field
major outfalls
Operations Section
Maintain an inventory of
Maintain an inventory of major outfalls that
Inventory complete;
major outfalls that
discharges to waters of the State.
ongoing collection for
discharges to waters of
annexations and new
the State
developments:
Stormwater Management
Division.
Establish procedures to
Establish and maintain procedures to identify
Ongoing program by the
identify and eliminate
and report failed septic systems or sanitary
Water Quality Section
failed septic systems and
sewer overflows to the appropriate agency
sanitary sewer overflows.
(County health department or local utility
de artment).
Maintain
Maintain procedures for detecting and tracing
Ongoing program by the
Inspection/detection
the sources of illicit discharges to the MS4 and
Water Quality Section
program to detect dry
for removing the sources.
weather flows at MS4
outfalls
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 11 of 33

BMP Summary Table — Continued
Inter -departmental spill
Maintain cooperative agreement and improve
Ongoing program by the
response team
relationship with spill response team partners.
City's Fire & Police as
City Fire and Police are primary responders,
primary responder. City's
while Stormwater is a secondary responder to
Stormwater Division as
assist in tracking spills and assessing
secondary.
environmental damage as a result of
environmental emergencies.
Commercial/Business
Develop and implement education and
Ongoing program by the
education and inspection
inspection program to inform local businesses
Water Quality Section.
program
of stormwater regulations, hazards of unlawful
During the reporting
discharges, and penalties for violations.
period, approximately 45
restaurants and 6 grease
hauling companies were
educated and/or
inspected.
Education and outreach
Continue ongoing programs and develop new
Ongoing program by the
programs
programs to inform municipal employees,
Water Quality Section;
local businesses, and the general public of the
Public Education and
hazards associated with illicit discharges and
Awareness Section
improper disposal of pollutants and waste.
Detection and Elimination
Greensboro continues to implement a comprehensive program of stormwater ordinance enforcement,
water quality monitoring, education and outreach, spill and citizen complaint response, and formal
inspections in order to prevent, detect, address, and eliminate illicit discharges and improper disposals to
the storm sewer system and receiving waters. The ongoing detection and elimination program currently
includes the following specific tasks:
1. Conducting stream water quality monitoring activity and conducting immediate follow up
when the data suggests a water quality issue.
2. Maintaining a helpline for citizen complaint reporting.
3. Providing professional staff response to citizen reports and complaints.
4. Secondary participation in cooperative spill response team with inter -governmental partners.
5. Development of a formal commercial and business education and inspection program.
6. Conducting stormwater investigations at industrial facilities.
7. Conducting field screening of NPDES MS4 outfalls to detect dry weather flows.
LocatingPriority riority Areas
To locate priority areas for illicit discharge investigations, Greensboro will continue to rely on a
combination of water quality monitoring, inspections, complaints or notifications from citizens and city
staff, and historical knowledge to locate and verify priority areas. Permanent sampling stations will
continue to be located within Greensboro's major watershed sub -basins, and field and laboratory water
quality parameters will be analyzed to detect potential illicit discharges and prioritize locations for follow-
up investigation.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 12 of 33

Removing Sources of Illicit Discharges
Greensboro's Land Development Ordinance (Chapter 30) specifically prohibits the illicit discharge or
improper disposal of pollutants and waste to Greensboro's stormwater conveyance system and subsequent
receiving surface waters. This ordinance authorizes City staff to utilize enforcement action, when
necessary, to stop an illicit discharge, remove the source, and require cleanup of the impacted area.
According to Stormwater's Administrative Procedures for Completing an Enforcement Action, the source
of an illicit discharge may be removed through a series of educational efforts, written Notices of
Violations (NOV), or progressing to civil penalty, if necessary. Once the source and responsible party of
an illicit discharge or improper disposal is identified, an appropriate educational letter or NOV is mailed.
Discontinuation of the discharge is required by the NOV, and the responsible party is required to reply in
writing to Stormwater staff detailing efforts taken to discontinue the unlawful activity and prevent the
activity from occurring in the future. Staff then conducts a follow-up investigation to ensure compliance.
During the July 1, 2017 to June 30, 2018 reporting period, 67 illicit discharges were reported, 80 were
investigated, and 45 were eliminated. Twenty-two (22) of the investigated illicit discharges resulted in an
issuance of a Notice of Violation (enforcement action); and of these 22, one included a civil penalty. The
higher number of investigations as compared to the number reported is a result of when in-house
Stormwater staff recognizes potential polluters while in the field, and they stop to inspect and/or educate
the potential polluter.
In addition to the standard citizen reporting procedure such as the City Call Center, City Stormwater
program has an inspection and education program that during routine operations proactively addresses
small commercial businesses that are identified as having the potential to impact water quality. During the
July 1, 2017, to June 30, 2018, reporting period, approximately 45 restaurants were educated and
inspected. In addition, six grease haulers that service the area were educated.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 13 of 33

Construction Site Stormwater Runoff Control
The City of Greensboro has a locally delegated Erosion and Sediment Control (E&SC) Program
implemented by the Erosion and Sediment Control Section of the Engineering and Inspections Department.
The E&SC Section is responsible for erosion control plan review, grading permits, erosion control
inspections, enforcement, and review of permanent stabilization of commercial development. A Chief E&SC
Inspector and field inspector(s) comprise the section.
BMP Summary Table
BMPs for Construction Site Stormwater Runoff Control
EJBMP
Measurable Goals
Comments
Plan Review, Enforce current
Ongoing program
Engineering and Inspections
E&SC ordinances.
implementation and
Dept, Development Services
enforcement. The locally
Division, E&SC Section.
delegated program is regulated
by the NCDEQ, Division of
Energy, Mineral and Land
Resources
E&SC Plan Review
In the City of Greensboro, any proposed development resulting in land disturbance of equal to or greater than
one acre requires a grading permit prior to any land disturbance activity. An NPDES Stormwater Discharge
Permit for Construction Activities is issued in conjunction with the grading permit for sites one acre or
greater. For sites requiring a grading permit, development plans and a grading application are submitted to
the E&SC Section, which reviews the plans to ensure that proper erosion and sediment control practices are
designed. Once the E&SC Section approves the plan, a grading permit is issued and land disturbance may
begin. The City of Greensboro also requires that any development resulting in less than one acre of land
disturbance indicate proper erosion and sediment control measures on the site plan. These plans are reviewed
and approved by the E&SC Section through the TRC process. Therefore, all sites developed through the
City's TRC process are reviewed for compliance with E&SC regulations.
E&SC Program Implementation and Enforcement
The City of Greensboro employs a variety of mechanisms to ensure compliance with the provisions of the
Soil Erosion and Sedimentation Control ordinance. First, no site will be issued a grading permit until the
plan reviewer is certain that necessary sediment and erosion control measures are adequately detailed on the
construction documents. Prior to issuing a grading permit for any site disturbing one acre or more, the City
Code requires that the owner/contractor post a bond. Prior to issuing a grading permit for any site disturbing
one acre or more, City Code requires that the owner/contractor post a bond. If a contractor begins land
disturbance without the required permits, appropriate City staff will issue a stop work order.
Should the field inspector identify deviations from the approved plan during construction, the inspector
may provide an inspection report to the owner and contractor indicating required measures and allowable
timeframe to bring the site into compliance. If the required items are not addressed within the appropriate
time, the inspector may issue a notice of violation (NOV) to the owner. A monetary fine may accompany
the NOV. If the required measures are still not addressed as indicated in the NOV, the inspector may
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 14 of 33

issue a stop work order. Additionally, the City of Greensboro reserves the right to deny the issuance of a
certificate of occupancy for sites that continue to remain in nonconformance with the erosion and
sediment control regulations.
Construction Site Inspections
Site inspections to ensure that proper erosion control measures are provided on construction sites are
conducted by qualified field inspectors. Each inspector represents a specific area of the City and inspects
sites within this area. Sites may be inspected more often depending on specific site conditions, the
progress of construction, citizen complaints and/or previously identified problems.
As site inspections may occur more frequently based on several factors, these same factors apply to the
prioritization of site inspections. Specific site conditions, contractor experience, citizen complaints,
previous inspections and the progress of construction all impact which site is given priority for inspection
on a more frequent basis. During the site inspection, the field inspector ensures that erosion and sediment
control measures are implemented according to the approved plan and that no significant offsite
sedimentation is occurring. If the inspector recognizes a problem in the field, the inspector may require
that additional erosion control measures be installed and maintained in accordance with established
enforcement procedures.
Included in the chart below is the data on the number of inspections and enforcement actions carried out by
the E&SC Section during the time period of July 1, 2017 to June 30, 2018.
INSPECTIONS
Reporting Period: July 1, 2017, to June 30, 2018
Universe of active construction
sites
290
Number of active construction
sites ins ected
290
Number of construction sites
found to be non -compliant after
the initial inspection
4
Number of follow-up
inspections
4
ENFORCEMENT
Reporting Period: July 1, 2017 to June 30, 2018
Number of informal enforcement actions noncompliance
0
Number of formal enforcement actions without penalty
4
Number of formal enforcement actions with penalty
0
Number of stop work order issued
0
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 15 of 33

Post -Construction Stormwater Management for New Development and
Redevelopment
The City of Greensboro enforces local stormwater management and riparian buffer regulations in addition to
State approved water -supply watershed protection regulations. Throughout the NPDES permit compliance
period, the City of Greensboro will review existing ordinances and, if necessary, develop and implement
revised ordinances in order to implement the post -construction stormwater management program with the
goal of further minimizing impacts to surface water quality. 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.
BMP Summary Table
BMPs for Post -Construction Site Stormwater Runoff Controls
jFBMP
Measurable Goals
Comments
Post -Construction
Develop and adopt by ordinance a
The ordinance was adopted by
Stormwater Management
program to address stormwater
City Council on April 7, 2009 and
Program
runoff from new development and
became effective June 1, 2009.
redevelopment within 24 months
of the permit issue date.
Strategies which include
Developed strategies that include a
City of Greensboro Stormwater
BMPs appropriate for the
combination of structural and/or
Management Manual requires any
MS4
non-structural SCMs implemented
proposed structural SCM be
in concurrence with (a) above.
accompanied by an operation and
Provide a mechanism to require
maintenance plan and agreement
long-term operation and
concurrent to development plan
maintenance of structural SCMs.
approval. It is also required that
Require annual inspection reports
City inspectors have access to
of permitted structural SCMs
perform required inspections.
performed by a qualified
professional.
Establish nutrient sensitive
Develop, adopt, and implement an
The Greensboro Land
waters (NSW) protection
ordinance to ensure that the best
Development Ordinance was
measures (for programs
management practices reduce
reviewed and modified to ensure
with development or
nutrient loading to the maximum
structural and non-structural
redevelopment draining to
extent practicable. In areas where
SCMs reduce nutrient loading to
NSW waters)
the Environmental Management
the maximum extent practicable.
Commission has approved a
Nutrient Sensitive Water Urban
Stormwater Management Program,
the provisions of that program
fulfill the nutrient loading
reduction requirement.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 16 of 33

BMP Summary Table — Continued
Deed Restrictions and
Protective Covenants
Impose or require recorded deed
restrictions, plats, and/or
protective covenants that ensure
development activities will
maintain the project consistent
with approved plans.
Current City of Greensboro Land
Development Ordinance requires
a maintenance note and recorded
maintenance agreement to be
placed on final plats stating the
maintenance responsibilities,
consistent with approved plans,
for the project SCM.
Establish a program under the
Coordinate with County health
Stormwater Division coordinates
Post -Construction minimum
department to control the known
with Guilford County Health
measure to control the sources
sources of fecal coliform from
Department to control the known
of fecal coliform to the
septic systems to the maximum
sources of fecal coliform from
maximum extent practicable.
extent practicable.
septic systems within the City's
jurisdictional limits to the
maximum extent practicable.
Additionally, the City's Water
Resources Department funds and
performs an ongoing sewer
rehabilitation program to
minimize and eliminate cross
connections between the storm
and sanitary sewer systems.
Operation and Maintenance
Require an operation and
City of Greensboro Stormwater
Plan
maintenance plan that ensures the
Division's development plan
adequate long-term operation of
review process requires a
the structural SCMs required by
stormwater management plan
the program. The operation and
and separate SCM operation and
maintenance plan may require the
maintenance plan (consistent
owner of each structural SCM to
with the provisions outlined in
submit a maintenance inspection
the State stormwater design
report on each structural SCM
manual) be submitted prior to
annually to the local program, or
receiving development plan
the maintenance inspections may
approval.
be conducted annually by the
Currently, the City of
Permittee.
Greensboro Stormwater Division
conducts maintenance
inspections on SCMs within the
City's jurisdiction.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 17 of 33

BMP Summary Table — Continued
Educational materials and
Provide educational materials
Stormwater Division's Planning
training for developers
and training for developers. New
and Engineering Section notify
materials may be developed by
developers and engineers of
the permittee, or the permittee
ordinance changes via direct e-
may use materials adopted from
mail, face-to-face meetings upon
other programs and adapted to
request regarding proposed site
the permittees new development
projects, Triad Real Estate and
and redevelopment program.
Building Industry Coalition,
televised City Council meetings,
providing opportunity for public
comment, as well as posting the
changes on the City website.
Setbacks for Built -upon Areas
Require built -upon areas to be
The Greensboro Land
located at least 50 feet landward
Development Ordinance was
of all perennial and intermittent
reviewed and modified to require
surface waters except as provided
a 50 foot stream buffer in
for in the Permittees Post-
accordance with NPDES phase II
Construction Stormwater
requirements.
Ordinance. For purposes of this
In addition, the City of
section, a surface water shall be
Greensboro has updated the
present if the feature is shown on
riparian buffer requirements
either the most recent printed
according to the Jordan and
version of the soil survey map
Randleman Lake Rules. The
prepared by the Natural
"Table of Activities and
Resources Conservation Service
Structures in Stream Buffers
of the United States Department
(Zone 1 & Zone 2)" located in
of Agriculture or the most recent
Chapter 30 of the Greensboro
version of the 1:24,000 scale (7.5
Land Development Ordinance
minute) quadrangle topographic
determines the allowable uses
maps prepared by the United
within the 50' riparian buffer.
States Geologic Survey (USGS).
Relief from this requirement may
be allowed when surface waters
are not present in accordance
with the provisions of 15A
NCAC 02B .0233(3) (a).
Local Permit Issuance
Currently, Group, Site and Subdivision plans within Greensboro's jurisdiction are reviewed by the City's
Technical Review Committee (TRC) for compliance with applicable development regulations. TRC is an
interdepartmental team charged with enforcing development standards as they relate to Watershed
Protection, Stormwater Management, Water -Supply, Water Reclamation, Zoning, Transportation, Parks
and Recreation, Tree Preservation, etc. Approval by members of TRC is a prerequisite to the issuance of
a grading permit or building permit. The City has reviewed and modified the Greensboro Land
Development Ordinance in order to ensure that plans meet post -construction stormwater management
requirements as defined by 15A NCAC 2H.0126 (10). The final 15A NCAC 2H.0126 (10)(h) rules define
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 18 of 33

low and high density development thresholds and as such these thresholds and any associated permanent
structural control and riparian buffer requirements will be applied to applicable new development or re-
development within the City's jurisdictional area. These requirements have now been incorporated in the
Greensboro Land Development Ordinance to allow for enforcement by City staff prior to issuance of the
applicable construction permit. The post -construction stormwater requirements were adopted by City
Council on April 7, 2009 and became effective June 1, 2009. Additionally, the City amended the Land
Development Ordinance and adopted Jordan Lake Riparian Buffer requirements on November 9, 2010.
These rules became effective on December 1, 2010.
Structural SCM Operation and Maintenance
Greensboro mandates that all required structural stormwater control measures (SCMs) be placed in a
drainage maintenance and utility easement (DMUE) connected to the public right-of-way by a 20 foot
wide access easement. The DMUE and access easement for each SCM must be platted before any
certificate of occupancy is issued for the site. TRC-approved development plans for structural SCMs
include an operation and maintenance plan (consistent with the provisions outlined in the State minimum
design criteria) be submitted prior to receiving development plan approval. Furthermore, notes are
recorded on the plat indicating that the City has the right to access the site for SCM inspections and that
the owner will maintain the SCM per the approved maintenance plan or as directed by the City.
During the reporting period (July 1, 2017 to June 30, 2018), a total of 420 privately owned stormwater
SCMs were inspected by City staff for performance and maintenance compliance. Ten owners were
issued a Notice of Violation (NOV) for failing to complete the required maintenance items with two of
the ten receiving an additional second NOV. Of the ten sites with NOVs, seven have completed the
required SCM maintenance. The city is working with the property owners, through enforcement
procedures, to complete maintenance items on the three remaining SCMs.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 19 of 33

Pollution Prevention/Good Housekeeping for Municipal Operations
Pollution Prevention and Good Housekeeping Programs are an important factor in the improvement of
stormwater runoff quality. Municipal departments that utilize various facilities currently implement good
housekeeping and pollution prevention programs. Additionally, the City Water Resources Department
works to ensure that pollution prevention and good housekeeping measures are being implemented at
other municipal facilities to the maximum extent practicable with the intent of improving stormwater
runoff quality discharged into receiving streams by those municipal facilities and their operations.
BMP Summary Table
BMPs for Pollution Prevention/Good Housekeeping Program
ism&==
Measurable Goals
Comments
Street Sweeping
Continue ongoing program with periodic
Ongoing program:
review.
Stormwater Management
and Field Operations
Department.
Loose Leaf Collection for
Continue ongoing program with periodic
Ongoing program:
Composting
review.
Stormwater Management
and Field Operations
Department.
Erosion and
City owned or otherwise public
Ongoing program:
Sedimentation Control
construction sites are regulated by NCDEQ,
City owned and other
Division of Energy, Mineral and Land
publicly funded projects
Resources for proper erosion and sediment
obtain appropriate state
control.
permits.
Staff Training/Site
The Stormwater Management Division of
Ongoing cooperative effort
Operator Education
Water Resources distributes education
by the City's departments
material for training employees on various
municipal operations.
Site Planning/Pollution
Develop and implement pollution
Ongoing effort by the City
Prevention Plan for
prevention plans that have been determined
of Greensboro.
Municipal Facilities
to have the potential to impact Water
Quality.
Site inspection and
The City maintains mapping programs that
The City's Stormwater
evaluation of facilities,
consist of all municipal facilities, as well as
Management Division has
operations including the
any related structural SCMs. City
identified a list of specific
MS4 system and
Stormwater Management maintains an
city facilities and ranked
associated structural
ongoing inspection program to monitor,
each of them according to
SCMs.
document and enforce stormwater
their potential to pollute.
discharges to the MS4 system.
Inspections of the high and
medium ranking facilities
have been conducted,
including documenting
areas where improvements
can be made to reduce the
potential of generating
polluted runoff.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 20 of 33

Affected Operations
The facilities listed in the following table are municipal operations that have been issued NPDES
Stormwater Discharge permits. These facilities have developed Municipal Pollution Prevention/Good
Housekeeping techniques in addition with the education and training material sent out.
Municipal Operation
Permit Number
City of Greensboro White St. Landfill
NCG120013
TZ Osborne WWTP
NCG110005
North Buffalo WWTP
NCG110004
Patton Avenue Service Center
NCGO80799
Greensboro Transit Authority (Bus Garage)
NCGO80893
Training
The City's Stormwater Management Division of Water Resources provides educational and technical
assistance for City facilities pertaining to pollution prevention plans and/or BMPs for the improvement of
overall environmental quality. In addition, the Stormwater Management Division also provides assistance
for City facilities pertaining to structural and non-structural stormwater BMPs for the improvement of
stormwater quality and/or quantity and BMP design and implementation.
The City has identified nine Departments that have a greater potential to contribute pollution to
stormwater runoff. The Departments involved in this program are as follows:
1. Coliseum
2. Engineering and Inspections
3. Field Operations
4. Finance (Equipment Services)
5.
Fire
6.
Parks and Recreation
7.
Police
8.
Transportation
9.
Water Resources
During the July 1, 2017 to June 30, 2018 reporting period, approximately 712 City of Greensboro
employees received training on municipal pollution prevention. This number includes our in house
pollution prevention DVD, Water Resources employee's training Videos and the Fire Department's in-
depth annual training of personnel on spill response and pollution prevention.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 21 of 33

City of Greensboro: Municipal Pollution Prevention
Good Housekeeping Employee Training Participation
10 10
■ Water Resources
■ Fire
■ Parks & Recreation
■ Coliseum
712 Employees Trained
The stormwater management division contacted representatives in the nine City departments listed above
to determine what they would like to see in new employee training materials. Once those needs were
identified, contact was made with municipalities throughout North Carolina. These municipalities shared
the materials they use as well as the strategies to achieve the Municipal Pollution Prevention Good
Housekeeping employee training goals. The City purchased the materials commonly used by other
municipalities and devised a distribution plan for FY 18-19 that best meets the employee training goals
utilizing the available resources.
Collectively, it is the responsibility of the entire City of Greensboro to maintain the NPDES city-wide
permit and enforce programs collaboratively. The objective is for all municipal departments that engage
in various operations to implement good housekeeping and pollution prevention methods in everyday
activities and to set a good example for the community to follow.
Site Inspection and Evaluation of Facilities
Stormwater personnel focused on site inspection and evaluation of city owned and operated facilities. A
complete list of all City owned and operated facilities was obtained from a GIS layer file. To prioritize
each facility, the history of spills/concerns, the proximity to a stream or stormwater conveyance system,
and the activities at a particular location were considered when ranking each facility as High, Medium or
Low. This ranking is further defined below.
High: Facilities in this category would have a large amount of outdoor processing activities, close
proximity to a stream and/or material storage on -site or obvious poor housekeeping issues.
Examples of these facilities would be golf courses, satellite fueling stations, facilities that
store salt for deicing roadways or the Coliseum that has many vendors using this property
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 22 of 33

at all times.
Medium: This category includes facilities that have some outdoor storage or processing, that may
not be in close proximity to a stream. Examples of these type facilities would be larger
parks, the science center, water treatment plants and the fire training center.
Low: A facility in low level ranking would have limited or no outdoor processing areas.
Examples of these facilities would be libraries, parking decks, rec centers and fire stations.
During the July 1, 2017 to June 30, 2018 reporting period, the stormwater management division finalized
the SOP, ranked all 126 facilities that do not have a NPDES permit. The stormwater management division
ranked 22 facilities as having a high or medium risk of generating polluted runoff. The high ranking
facilities were completed 16-17 permit cycle. The stormwater management division began conducting
inspections of the municipal facilities with a medium ranking during this reporting cycle and completed 3
facility inspections. In addition the stormwater management division has documented improvements
made per our recommendations to a high risk facility that was inspected during FY 16-17.
Municipal Operation
Rank
Country Park
M
Jaycee Park
M
Natural Science Center
M
Maintenance and Inspections
The City of Greensboro Stormwater Maintenance Section, within the City's Field Operations Department,
maintains open and closed stormwater infrastructure and drainage conveyance systems that carry public
runoff within the MS4 service area. This section also performs stream maintenance activities and
preventative maintenance on most public stormwater infrastructure.
The City's Stormwater Management Division identifies and inspects industrial and related facilities that
may discharge stormwater into either the MS4 or receiving streams in Greensboro, and also assists the
local industrial community in the development and implementation of appropriate stormwater runoff
controls. In addition, the City has an ongoing litter pick-up program to clear trash and other floatables
from roadways, which helps keep them out of the storm drainage system and surface waters.
Vehicular Operations
The City of Greensboro's vehicular operation centers utilize the City's hazardous waste program to
recycle or dispose used oil, antifreeze, batteries, and spare parts and used chemicals. A new salt storage
barn was constructed in fall 2002 as a BMP to prevent salt stormwater runoff from entering receiving
streams.
Waste Disposal
Waste materials generated from the City's day-to-day activities are managed according to local and state
regulations and vendors utilized by Greensboro are audited to ensure environmental compliance. With
the ongoing public education and awareness programs, the City will continue to facilitate staff meetings to
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 23 of 33

inform staff of all new and related regulations/programs corresponding with the Municipal Pollution
Prevention and Good Housekeeping Program.
Examples of Waste Disposal Programs include:
• Hazardous Waste Program
• Solid Waste Recycling
• Lead Disposal Program
• Oil Disposal Program
• Universal Waste Program
• Water Treatment Chemicals Disposal Program
Program to Monitor and Evaluate Storm Water Discharges to the Municipal System
The City of Greensboro has developed and implemented an industrial facilities inspection program during
the first two permit terms. During the current permit term, the inspection program will be reviewed and
revised to reflect current permit conditions. Industrial facilities subject to Section 313 of Title III of the
Superfund Amendments and Reauthorization Act of 1985 (SARA), and industrial facilities that the City
determines to be contributing or have the potential to contribute a substantial pollutant loading to the
municipal separate storm sewer system will be inventoried and evaluated.
BMP Summary Table
BMPs for Monitoring and Evaluating Storm Water Discharges to the MS4
BMP
Measurable Goals
Comments
Maintain Inventory of Industrial Sites
The City maintains an
The City will update and
inventory of all NPDES
revise list annually.
permitted industrial facilities.
The City will add additional
facilities to list that meet the
SARA Title III (Section 313)
criteria or that contribute
substantial pollutant loading
to the MS4 system.
Inspection Program
The City has developed a
The City has an ongoing
formal inspection program
industrial inspection program
for evaluating industrial
with a goal of visiting all
facilities. This inspection
listed industrial facilities
program will be expanded to
once per permit cycle.
include any facility on the
Annual training is conducted
above stated list.
for City staff on specific
inspection procedures and
staff coordinates with
NCDEQ on a regular basis to
be trained on any issues or
permit updates.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 24 of 33

BMP Summary Table — Continued
Establish and Implement Measures to
The City has developed the
The City has a strong
Evaluate Commercial and Industrial
industrial facilities inspection
working relationship with the
Facilities discharging stormwater to
program to evaluate those
NCDEQ regional office and
the City's MS4
facilities on the above list
county officials. The City's
and ensure all permit
enforcement procedures are
conditions are being met and
utilized when water quality
discharges to the MS4 are not
violations are encountered
considered substantive.
and follow up actions are
deemed necessary. NPDES
permit deficiencies are
addressed in written
notification and are also
forwarded to NCDEQ
(agency with permitting
authority).
During the reporting period (July 1, 2017, to June 30, 2018), a total of I I NPDES permitted facilities
were inspected by City staff. Of these I I inspections, one was also listed in the Toxics Release Inventory.
Four additional unpermitted facilities were inspected that were listed only in the Toxics Release
Inventory. No enforcement action was warranted from these inspections. The number of facility
inspections varies from year to year, with some years having more inspections than others. This variation
in facility inspections is due to a previous scheduling agreement between the City of Greensboro and
NCDEQ to avoid overlapping inspections of NPDES permitted facilities.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 25 of 33

Water Quality Assessment and Monitoring
The City of Greensboro has developed and implemented a comprehensive water quality monitoring and
assessment program to evaluate the impacts on water quality.
BMP Summary Table
BMPs for Water Quality Assessment and Monitoring
BMP
Ir
Measurable Goals
Comments
Water Quality Assessment and
A DRAFT City of Greensboro
Draft document was submitted
Monitoring Plan
Water Quality Assessment and
to NCDEQ for comment and
Monitoring Plan was submitted
approval within 12 months of
within 12 months of permit
permit issuance as required.
issuance as required by the
NPDES permit.
Water Quality Monitoring
The City will implement the
The City implemented the
water quality assessment and
submitted water quality
monitoring plan in accordance
monitoring plan January 1,
with NCDEQ and the permit
2009.
schedule.
Revisions to the Water Quality
The City will conduct an annual
The City will review and revise
Assessment and Monitoring Plan
review, revise as appropriate,
annually and coordinate with
and submit any revisions to
NCDEQ any proposed changes.
NCDEQ for approval.
Total Maximum Daily Load (TMDL)
The City of Greensboro has an EPA and NCDEQ approved TMDL for Fecal Coliform bacteria for North
Buffalo Creek. The permittee will utilize BMPs within the six minimum measures to address the
permittee's assigned NPDES regulated stormwater waste load allocation (WLA) identified in the
approved TMDL to the maximum extent practicable and to the extent authorized by law. Resolute efforts
are being made to determine the most efficient best management practices that address the MS4 NPDES
regulated Waste Load Allocation identified in the TMDL. Current efforts are continually re-evaluated and
adapted as needed. More importantly, new ideas are continuously shared and assessed, with the ultimate
goal of improving and protecting water quality.
An assessment of available data, BMP strategies, and TMDL Watershed Plan effectiveness will be
conducted and utilized to define the appropriate progress and schedule of the watershed plan within the
context of the Maximum Extent Practical (MEP) standard. Activities conducted throughout the program
implementation schedule to address the MS4 NPDES regulated waste load allocation (WLA) identified in
the TMDL will be evaluated and defined as to the collective contribution to the watershed plan. The
results of the analysis will be utilized to prioritize local funding aimed at elimination of the most
significant portion of the MS4 waste load allocation for the least resources.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 26 of 33

BMP Summary Table
BMPs for Total Maximum Daily Load
BMP
Measurable Goals OM
Comments
7(A)dentify, describe and
Within 24 months the permittee shall
Description, maps, and
watershed, outfalls, and
prepare a plan that:
outfall information is
sreams
• Identifies the watershed(s) subject to an
noted in BMP Narratives
approved TMDL with an approved
following this table.
Waste Load Allocation (WLAs)
assigned to the permittee,
• Includes a description of the
watershed(s),
• Includes a map of watershed(s) showing
streams & outfalls
• 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 to discover and
locate other 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.
(B) Existing measures
Within 24 months the Permittee's plan:
Measures include
• Shall describe existing measures being
education, sampling,
implemented by the Permittee designed
citizen concerns,
to achieve the MS4's NPDES WLA and
industrial inspections, etc.
to reduce the TMDL pollutant of
See information in BMP
concern to the MEP within the
Narratives following this
watershed to which the TMDL applies;
table for a more complete
and
list and descriptions.
• 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 NCDEQ.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 27 of 33

BMP Summary Table — Continued
C) Assessment of Available
Within 24 months the permittee's plan shall
An assessment of the
Monitoring Data
include an assessment of available
programmatic
monitoring data. Where long-term data is
management measures,
available, this assessment should include an
existing TMDL data,
analysis of the data to show trends.
relevant watershed data,
monitoring data, etc., is
performed periodically.
An assessment of
activities conducted under
the TMDL plan will be
performed to evaluate the
overall effectiveness of
the watershed plan and
make any adjustments
deemed necessary. The
assessment will be used,
where possible, to
evaluate the performance
of existing BMPs and
identify additional BMP
strategies as necessary.
(D) Monitoring Plan
Within 36 months the permittee shall
The monitoring plan for
develop and submit to the Division a
the TMDL Watershed
Monitoring Plan for the permittee's
Plan includes current
assigned NPDES regulated WLA as
monitoring programs and
specified in the TMDL. The permittee shall
procedures that will be
maintain and implement the Monitoring
updated as necessary to
Plan as additional outfalls are identified and
achieve the City's waste
as accumulating data may suggest.
load allocation (WLA)
Following any review and comment by the
and reduce the pollutant of
Division the permittee shall incorporate any
concern (POC) to the
necessary changes to monitoring plan and
maximum extent possible.
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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 28 of 33

BMP Summary Table — Continued
(E) Additional Measures
Within 36 months the permittee's plan
Measures include the
shall:
FOG Program, sanitary
• Describe additional measures to be
sewer rehabilitation, pet
implemented by the permittee
waste stations, and the use
designed to achieve the permittee's
of new technology, and
MS4's NPDES WLA and to reduce
the SSO Reduction
the TMDL pollutant of concern to
Committee. See
• the MEP within the watershed to
which the TMDL applies; and
information in BMP
Narratives following this
Provide an explanation as to how those
table.
measures are designed to achieve the
permittee's MS4's NPDES regulated WLA
to the MEP within the watershed to which
the TMDL applies.
(F) Implementation Plan
Within 48 months the permittee's plan
Current BMPs will
shall:
continue to be
• Describe the measures to be
implemented to achieve
implemented within the remainder of
the Waste Load
the permit term designed to achieve
Allocation to reduce the
the MS4's NPDES WLA and to
pollutant of concern to the
reduce the TMDL pollutant of
MEP. This includes
concern to the MEP and
existing BMPs and the
Identify a schedule, subject to NCDEQ
exploration of additional
approval, for completing the activities.
opportunities.
(G) Incremental Success
The permittee's plan must outline ways to
The TMDL plan describes
track and report successes designed to
ways to track and report
achieve the MS4's NPDES regulated WLA
successes based on the
and to reduce the TMDL pollutant of
TMDL BMPs and goals
concern to MEP within the watershed to
designed to achieve the
which the TMDL applies.
Waste Load Allocation to
reduce the pollutant of
concern to the MEP.
(H) Reporting
The permittee shall conduct and submit to
Following the schedule
the Division an annual assessment of the
per the permit, the TMDL
program designed to achieve the MS4's
watershed plan addresses
NPDES WLA and to reduce the TMDL
and reports on the TMDL
pollutant of concern to the MEP within the
program.
watershed to which the TMDL applies. Any
monitoring data and information generated
from the previous year are to be submitted
with each annual report.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 29 of 33

BMP Narratives
1) Identify, Describe and Map Watershed, Outfalls, and Streams (A)
Watershed Description
The North Buffalo Creek watershed is located in Greensboro, North Carolina (Guilford County), and is in
the headwaters of the Cape Fear River Basin. The eastern flowing stream eventually feeds into the Haw
River. The watershed is represented by small floodplain streams that have some bedrock outcroppings and
are surrounded by gently sloping uplands. North Buffalo Creek's headwaters lie entirely within urbanized
areas (commercial, industrial, and residential with high [>28%] impervious area) in the city of
Greensboro (population >287,000).
As outlined in the City's TMDL Watershed Plan, the compliance point for Upper North Buffalo Creek
TMDL is located where Summit Avenue crosses over North Buffalo Creek. The drainage area from the
headwaters to this compliance point is 21.8 miz and incorporates 8.7 miles of stream. The area is generally
deemed as built out, in that no major future land use changes are predicted. The area is 38% residential,
15% right-of-ways, and 20% forest. Impervious surface constitutes approximately 26% of the watershed.
In January of 2009 the City started collecting water quality samples at the compliance point on a monthly
basis. Samples are analyzed for both physical and analytical parameters.
Map of Drainage area from Headwaters to Fecal Coliform TMDL Compliance Point:
Upper North Buffalo Creek Watershed
TMDL for Fecal Coliform��
1 ' 4- '
r
i
Comphince Point
� 4
l
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 30 of 33

Outfall Locations
MS4 outfalls have been determined through GIS and the City's ongoing stormwater inventory process.
See map below for outfall locations within the TMDL watershed.
Schedule for Locating New Outfalls
Unknown major NPDES outfalls will be identified utilizing the ongoing stormwater inventory procedures
through subsequent QAQC checks of various sub basins, ongoing collection efforts involved with new
development, and updates due to drainage system repairs and maintenance. Any new outfalls and/or
newly identified outfalls will be recorded and mapped on a routine basis.
Map of NPDES Outfalls located within the Fecal Coliform TMDL Compliance Area:
Outfalls in Upper North Buffalo Creek Watershed
2) Existing Measures (B)
Outfall Screening
NPDES outfalls are investigated/screened on a routine basis to determine illicit discharges or improper
disposals. Locations are determined based on basin, citizen concerns, spill calls, results from various
monitoring data, and/or routine selection of particular basins. Any noted concerns are investigated further,
which may include tracking, obtaining readings for physical parameters, and/or taking samples to be
analyzed in the field or by the contracted lab.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 31 of 33

Education
• Citizen participation with the Drain Marker program, Adopt -a -Stream program, pet waste stations,
etc., to encourage citizens to have personal involvement
• Partnering with communities and organizations and using the media for a broad -scale approach to
pollution education and prevention
• Using At Your Service, the City's monthly newsletter that is distributed with the water bill, to
educate residents about pet waste and fecal coliform
• Educating citizens about TMDLs via the City's website
Small -Quantity Polluters Program
As well as general education, specific potential polluters in the community are targeted and educated
regarding housekeeping practices and proper waste disposal. This Pollution Prevention Program entails
water quality staff to inspect and educate businesses that are common polluters, such as painters,
landscapers, ready -mix concrete companies, auto repair shops, mobile washers, restaurants, etc. This
ongoing prevention program is highly regarded and has been determined to be a worthwhile endeavor in
keeping pollution from streams and other water sources.
Fixed Interval Sampling
Monthly sampling and assessments are performed, including the analysis of results and the need for
outfall follow-ups; this includes a sampling site at the compliance point in additional to three other
monitoring sites in the TMDL watershed.
Sanitary Sewer Overflow (SSO) Prevention
Ongoing evaluation of citywide SSOs is being used to direct resources for maintenance and rehabilitation
of sanitary sewer lines in the TMDL watershed in an effort to prevent overflows and exfiltration.
Field Observations
Issues discovered by staff through inventory collections, outfall screenings, etc., and water quality staff
address potential issues.
Public Concerns/Reports
Reports are followed up by investigating, tracking, resolving, and enforcing violations when applicable.
Over the past reporting year, illicit connections have been identified and eliminated throughout the city.
Among these illicit connections were those discovered at Moses Cone Hospital, which is located in the
TMDL watershed. Stormwater staff has worked with staff at Moses Cone Hospital to eliminate these
discharges into the stormwater system.
Industrial Inspection Program
NPDES permitted facilities and TRI facilities are inspected, focusing on a review of the Stormwater
Prevention Pollution Plan, spill prevention and response procedures, employee training, housekeeping
practices, and outfall monitoring.
3) Additional Measures
Fats, Oils, and Grease (FOG) Program
This ongoing program seeks to reduce the number of SSOs due to issues caused by oil and grease.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 32 of 33

Sanitary Sewer Rehabilitation
During the reporting year, over 56,700 linear feet of sewer underwent rehabilitation in the North Buffalo
watershed up to the compliance point.
Pet Waste Stations
Pet waste stations in the TMDL watershed have been mapped, including both private stations and those
maintained by the City of Greensboro. Within this watershed, there are currently 113 documented pet
waste stations (84 private, 29 city maintained).
New Technology
New technology being used for the City's wastewater collection system, such as SL-RAT (Sewer Line
Rapid Assessment Tool), could help reduce the number of SSOs, therefore reducing the WLA for the
POC. The Operations Division continually explores new and updated equipment to prevent SSOs and to
investigate or repair sewer lines. In addition, inflatable plugs are being used when applicable, preventing
overflows from entering surface waters.
SSO Reduction Committee
This committee is compiled of representatives from multiple divisions within the Water Resources
Department. The goal of the committee is to take a holistic approach to preventing SSOs by analyzing
past overflows using GIS, the work order management system, and staffs institutional knowledge to
implement enhanced reduction strategies.
Threatened or Endangered Species Protection Program
The City of Greensboro currently does not have any federally listed aquatic animal species that are listed
as threatened or endangered by the U.S. Fish and Wildlife Service or the National Marine Fisheries
Service under the provisions of the Endangered Species Act.
For more information on the City of Greensboro's NPDES MS4 Discharge Permit and associated
Stormwater Quality Management Program Plan, please visit the Stormwater website at:
www.greensboro-nc.2ov/stormwater
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2018
NPDES Permit No. NCS000248 Page 33 of 33

CITY OF GREENSBORO
NPDES MS4 STORMWATER DISCHARGE PERMIT
Permit # NCS000248
STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
2016/2017 Annual Report
Prepared for:
North Carolina Department of Environment & Natural Resources
North Carolina Division of Water Quality
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617
Prepared by:
City of Greensboro
Water Resources Department - Stormwater Management Division
P.O. Box 3136
Greensboro, NC 27402-3136
FAF'"-
,IL-9-n
GREENSBORO
September 2017

TABLE OF CONTENTS
Page
Executive Summary________________ 1
Significant Receiving Waters and Watersheds .......................................................................... 1
Organizational Structure_________________________________ 2
LegalAuthority------------------------------------------------------------------------------------------------------------------------- 4
Funding........................................................................................................................................ 5
Stormwater Quality Management Program Plan ----------------------------------------------------------------------------------- 6
Public Education and Outreach Program ................................................................................... 6
BMPSummary Table ----------------------------------------------------------------------------------------------------- 6
TargetAudience -------------------------------------------------------------------------------------------------------------- 7
Identifying Pollutants and Target Sources_________ 7
Public Outreach Narrative Program ............................................................................... 8
Public Involvement and Participation ---------------------------------------------------------------------------------------- 9
BMP Summary Table_______________ 9
TargetAudience -------------------------------------------------------------------------------------------------------------- 9
Participation Program Narrative ------------------------------------------------------------------------------------ 10
Illicit Discharge Detection and Elimination ------------------------------------------------------------------------------
11
BMPSummary Table -----------------------------------------------------------------------------------------------------
I I
Detection and Elimination ----------------------------------------------------------------------------------------------
12
LocatingPriority Areas ---------------------------------------------------------------------------------------------------
12
Removing Sources of Illicit Discharges________________________________________________________________________
13
Construction Site Stormwater Runoff Control 14
BMPSummary Table ----------------------------------------------------------------------------------------------------- 14
E&SC Plan Review 14
E&SC Program Implementation and Enforcement__________________________________ 14
Construction Site Inspections________________________________________________________________ 15
Post -Construction Stormwater in New and Redevelopment____________________________________________________ 16
BMPSummary Table ----------------------------------------------------------------------------------------------------- 16
Local Permit Issuance 18
-----------------------------------------------------------------------------------------------------
Structural SCM Operation and Maintenance_____ 19
Pollution Prevention/Good Housekeeping for Municipal Operations_ 20
BMP Summary Table------------------------------------------------------------------20
AffectedOperations------------------------------------------------------------------------------------------------------ 21
Training-------------------------------------------------------------------------------------------------------------------------- 21
Site Inspection and Evaluation of Facilities_________________________________________________________________ 22

Maintenance and Inspections ----------------------------------------------------------------------------------------- 23
VehicularOperations---------------------------------------------------------------------------------23
WasteDisposal------------------------------------------------------------------------------------------- 23
Program to Monitor and Evaluate Stormwater Discharges to the Municipal System ............ 24
BMPSummary Table----------------------------------------------------------------------------------------------------24
Water Quality Assessment and Monitoring Program_
BMPSummary Table---------------------------------------
26
26
Total Maximum Daily Load(TMDL)----------------------------------------------------------------------------------------
26
BMPSummary Table -----------------------------------------------------------------------------------------------------
27
BMP Narratives
30
Identify, Describe and Map Watershed, Outfalls, and Streams
30
ExistingMeasures -----------------------------------------------------------------------------------------------------------
31
Additional Measures
32
Threatened or Endangered Species Protection Program ----------------------------------------------------------- 33

Stormwater Quality Management Program Plan (Stormwater Plan)
for
Greensboro's NPDES MS4 Discharge Permit
The City of Greensboro's initial National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Discharge Permit (Permit Number NCS000248) became effective on
December 30, 1994. The North Carolina Department of Environmental Quality (NCDEQ) issued the City of
Greensboro's current permit on March 1, 2013, for a period of five years with an effective expiration date of
February 28, 2018. This document includes a summary of NPDES stormwater quality management
programs and activities implemented, scheduled to be implemented, or completed during the July 1, 2016 -
June 30, 2017 permit term.
The City's NPDES Stormwater permit, and associated Stormwater Quality Management Program Plan
(Stormwater Plan), is designed to control the discharge of pollutants from the MS4 to the Maximum Extent
Practicable (MEP).
Significant Receiving Waters and Watersheds
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 towards
the Haw River, while a smaller portion of the City area drains south towards the Deep River. The North and
South Buffalo Creek Watersheds drain the majority of the City's central urbanized area eastward towards
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 131.94 square miles, represents just over 1% of the 9,322 square mile Cape Fear Basin.
Existing land uses within Greensboro are broadly classified in Table 1.
Table 1 — Land Uses in the City of Greensboro
Land Use Classification
Approximate % within Corporate Limits
Residential
39%
Commercial
13%
Industrial
7%
Open Space/Wooded/Undeveloped
41%
Total (land use does not include public streets and water bodies)
100%
Table 2 shows a listing of the primary streams located within the City of Greensboro MS4 service area.
Water quality classifications of receiving streams are provided, along with their use support ratings and
key water quality challenges.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 1 of 33

Table 2 - Primary Receiving Streams within Greensboro Service Area (Upper Cape Fear River
Basin)
Receiving
Stream
Water Quality
Use
Support
Water Quality Issues
303(d) List
Stream Name
Segment
Classification*
Rating
Impaired biological
yes
Reedy Fork
Within
WS-III;NSW,
Impaired
integrity, Chlorophyll a,
Creek
corporate limits
WS-III;NSW CA
Turbidity
Brush Creek
Within
WS-III;NSW
Impaired
Impaired biological
Yes
corporate limits
integrity, Chlorophyll a
Horsepen
Within
WS-III;NSW,
Impaired biological
Yes
Creek
corporate limits
WS-III;NSW CA
Impaired
integrity
Fecal coliform,
Yes
North Buffalo
Within
WS-V;NSW
Impaired
Impaired biological
Creek
corporate limits
integrity, Zinc, Cooper,
NO2+NO3-N
South Buffalo
Within
Turbidity, Impaired
Yes
Creek
corporate limits
WS-V;NSW
Impaired
biological integrity,
Zinc
Yes
East Fork
Within
WS-IV, WS-
Impaired biological
Deep River
corporate limits
IV;CA
Impaired
integrity, Turbidity,
Fecal coliform
Water Quality Classifications:
NSW = Nutrient Sensitive Waters
WS = Water Supply classification (degree of protective measures).
C = Class C waters general use category (maintain aquatic life and biological integrity, wildlife, secondary
recreation, etc.)
CA = Critical Area
** Use Support Rating (the degree to which the water body supports its designated uses):
FS = Fully Supporting
PS = Partially Supporting
NS = Not Supporting
NR = Not Rated
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 2 of 33

Organizational Structure
The Stormwater Management Utility is one of seven divisions of the City's Water Resources Department
(also including 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.
The following bullet points briefly document the overall organizational structure and functional
responsibilities of the City's Stormwater Plan. 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 substantive ways.
• 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; best management practice (BMP) evaluations and BMP crediting; BMP 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 of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 3 of 33

• 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
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 -storm water 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;
• 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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 4 of 33

Funding
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, along with the desire 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 non-structural 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 eleven 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 2016-2017 Budget Expenses
$11,762,315 Operations
Administration Management
o
7o � 4/o Water Quality &
Ago Monitoring
Planning & 7%
Engineering
Construction F�o 3%
34%
Public Education &
Awareness
Street Maintenance 1%
Cleaning 19%
25%
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 5 of 33

STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
The following information is the City's stormwater quality management program plan (Stormwater Plan)
identifying programmatic measures to comply with the City's NPDES permit to the maximum extent
practicable. BMP summary tables for each of the regulatory areas are provided, along with narrative for
key programs and updates or accomplishments completed during the last permit year (July 1, 2016 - June
30, 2017).
Public Education and Outreach
BMP Summary Table
BMPs for Public Education and Outreach Program
BMP
Measurable Goals
Comments
Pollution
Distribute brochures through event displays, billing
Ongoing effort by the
Prevention
inserts, volunteer participants, new customer packets
Stormwater Program.
Brochures
at Customer Service counter, informational displays,
field representatives and direct mailings to target
groups. Various issues addressed include proper
disposal of oil and other toxic materials, sediment and
erosion control issues, proper application and handling
of fertilizers and pesticides, litter prevention, pollution
reporting and awareness, etc. for different age groups.
Website
Maintain the Stormwater Management Website.
Ongoing effort by the
Contains information about pollution prevention,
Stormwater Program.
stormwater technology and practices. Provides
contacts and forms for pollution reporting and
http://www.greensboro-
nc.gov/stormwater
information requests.
Stormwater
Several videos have been created to educate residents
Ongoing effort by the
Videos
and school children about various pollution prevention
Stormwater Program.
measures and volunteer opportunities. Videos air
Additional videos may be
periodically on Greensboro Television Network
created as issues arise.
(GTN) that appears on the local cable affiliate, while
others air on local stations 2, 8, 12, and Spectrum
Cable as part of an advertising campaign.
Media
Advertise on TV, radio, newspaper, GTN, web
Ongoing effort by the
Campaign
banners, and in city newsletters to the extent
Stormwater Program.
practicable.
Helpline
Established a helpline for citizens to report pollution,
Ongoing effort by the
address water quality and drainage concerns, as well
Stormwater Program and
as volunteer opportunities.
City Contact Center.
School and Civic
Develop and present educational talks and activities
Ongoing effort by the
Group
for schools and civic groups, including our
Stormwater Program.
Presentations
Enviroscape Model.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 6 of 33

BMP Summary Table — Continued
Targeted
Develop flyer /brochures to inform
Ongoing effort by the Stormwater
Commercial
businesses that have a potential of illicit
Program; site visits initiated in Mid -
Education
discharges or improper disposals to the
2003.
Initiative
stormwater conveyance system.
Cooperative
The City of Greensboro seeks reasonable
Ongoing effort by the Stormwater
Efforts
opportunities to partner with neighboring
Program.
communities for joint educational programs.
http://www.pledmontwaterquality.org/
Example: "Piedmont Triad Water Quality
Partnership (PTWQP) " and also the North
Carolina Cooperative Extension Services and
Guilford County Soil and Water
Conservation District.
Watershed
Road signs have been installed at stream
Ongoing effort by the Stormwater
Signs
crossings identifying the watershed and
Program.
stream name.
Target Audience
Current and future target audiences for stormwater education include:
1. General Public, especially homeowners — applies lawn care products, uses chemicals for home and
auto maintenance, makes decisions about drainage issues on their properties and participates in
volunteer opportunities. Through a collaborative effort with PTWQP, the City has distributed over
200 stream buffer kits to homeowners in the surrounding communities. Each kit contained 4 different
common stream bank plant species that will provide many essential benefits. Through a collaborative
effort with North Carolina Cooperative Extension agencies in the surrounding communities, the
partnership is able to help homeowners learn valuable landscape techniques. To enhance the annual
advertising campaign, a landscape kit containing a soil probe, measuring spoon, measuring tape, rain
gauge, garden gloves, pet waste bags and educational material was distributed to workshop attendees.
2. Structural SCM Owners — maintenance issues and education about proper BMP maintenance and
responsibilities.
3. Industries — potential of water quality impacts due to improper material handling, improper
housekeeping practices and illicit discharges.
4. Commercial landscapers, restaurants, mobile washers, concrete companies, painters, drywall
installers, masons, automotive repair facilities and kennels — potential water quality impacts due to
illegal dumping of wastewater into storm drains and improper chemical handling and application.
5. School age children are educated about the importance of protecting water quality through the
distribution of elementary school homework folders in our local school system. Our sponsorship
ad provided an opportunity for us to reach over 7,600 students and their families. In partnership
with Guilford County Soil and Water Conservation District over 250 middle and high school
students have completed in the NC Area III Envirothon. During the event, students train and
complete in areas of soils, aquatics, wildlife, forestry, and current environmental issues.
Identifying Target Pollutants and Sources
Target pollution sources for stormwater education include:
1. Illicit Connections — The discharge of non-stormwater into the stormwater conveyance system can
result in biological mortality in receiving streams due to discharges.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 7 of 33

2. Improper Disposal — The discharge of used motor oil, oil & grease, organic materials (grass and
leaves), and various other pollutants into storm drains can be a problem on construction sites,
commercial and residential areas, etc.
3. Water Quality Monitoring — Routine water quality monitoring data will be evaluated to identify target
pollutants which impact water quality.
4. Pet Waste — Greensboro has developed a TMDL for fecal coliform for the portion of North Buffalo
Creek located within the jurisdictional limits. As a management measure, the City will generate
educational literature targeting pet owners on the need to pick up after their pet in order to protect
water quality. Additionally, staff has observed that a number of public parks and homeowner's
associations have installed pet waste bag dispensers and or signage to encourage proper disposal of
pet waste. As a part of the At Your Service program, information was sent out to residents regarding
the proper way to dispose of pet waste.
5. Lawns and Gardens — Lawn care chemicals may enter storm drains due to improper application. Yard
waste may also be improperly placed into storm drains. These can create blockages in the stormwater
conveyance system and cause decreased dissolved oxygen in streams. The Clean Streams Program
educates commercial landscape professionals on the proper application of fertilizer and pesticides, as
well as aquatic pesticides. Commercial landscape professionals have an opportunity to receive
pesticide credit for successful completion.
6. Auto Repair Shops — Many auto repair shops have interior drains that have the potential to be
illicit connections (such as older buildings or sites that were previously a different business type).
As these locations are identified and dye -testing is conducted, owners and staff are made aware of
proper house -keeping practices, including awareness of interior drains and their resulting
destinations (i.e., either storm or sanitary sewers).
7. Mobile Auto Washers — car washing activities can generate potentially harmful wash water. An
educational and inspection program targeting mobile auto washers on containment, collection, and
disposal of wash water has been developed.
8. Restaurants — Many restaurants have Good Housekeeping issues related to disposal of cooking oil,
process wastewater generated by cleaning activities, and outdoor storage areas such as trash
dumpsters and grease containers that can adversely impact water quality. An educational and
inspection program targeting restaurants has been developed and implemented during this
reporting period.
Public Outreach Program Narrative
Outreach mechanisms are described in the BMP summary table above. Over the permit period,
Greensboro expects to reach the majority of the approximately 287,000 individuals in its MS4 service
area, as well as individuals in surrounding service areas. Everyone who receives a water/sewer bill will
occasionally receive stormwater education messages in the City's citizen newsletter, for example, the "At
Your Service" newsletter. Individuals are also periodically exposed to various stormwater related
messages that are shown on our local governmental broadcast station. For those who do not receive a bill
or do not read the newsletter, various media campaigns are featured on TV, radio, and newspaper.
Combined together, the media outlets are designed to reach the citizens of Greensboro. For citizens who
speak Spanish, some materials will be printed in English and Spanish. The City also utilizes a local
Spanish radio station and newspaper to deliver various educational messages.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 8 of 33

Public Involvement and Participation
BMP Summary Table
BMPs for Public Involvement and Participation Program
BMP
Measurable Goals
Comments AM
Adopt -a-Streamm
Developed an Adopt -a -Stream Program.
Ongoing effort by the
Volunteers must pick up trash from their adopted
Stormwater Program.
segment of stream twice per year.
Drain Marker
Developed a Drain Marker Program. Volunteers
Ongoing effort by the
Program
have attached signs to Greensboro's storm drains.
Stormwater Program.
Adopt -a -Street
Developed an Adopt -a -Street Program.
Ongoing effort administered
Volunteers must pick up trash from their adopted
by the City's Field Operations
segment four times per year.
Department.
Stormwater
Board established to help guide Stormwater
Stormwater Advisory Board
Advisory Board
program on important community issues.
reconvenes as needed to
address community issues.
Annual Clean-up
Promote the Great American Clean-up and the
Ongoing effort by the City's
Events
NC Big Sweep.
Parks and Recreation
Department.
Poster Contest
Water quality, water conservation and soil
Ongoing effort administered
conservation poster contest available for
by the Guilford County Soil
elementary students in the Guilford County
and Water Conservation
School System.
District and Stormwater
Program.
Neighbor Woods
Developed a Neighbor Woods Program, which
Ongoing effort administered
Program
encourages community wide tree planting and re-
by the City's Planning
vegetation efforts.
Department.
Educational
Power of Wetlands (POW), Wonders of Wetlands
Ongoing effort administered
Workshops
(WOW) and Project Water Education for
by the Greensboro Public
Teachers (WET) workshops offered as a resource
Library, Guilford County Soil
for educators.
and Water Conservation
District, and the Parks and
Recreation Department.
Household
Promote proper disposal of harmful chemicals
Ongoing effort by the City's
Hazardous Waste
through the Household Hazardous Waste
Field Operations Department.
Collection
Collection Center.
Fats, Oils, and
Program designed to prevent the excessive
Ongoing effort by the
Grease Inspection
introduction of oil, grease, and fats into the
Stormwater Program and the
Program
sanitary sewer system and the wastewater
Industrial Pretreatment
collection system, which helps prevent sanitary
Division.
sewer over flows.
Target Audience
Target audiences for the public involvement program include representative age, ethnic, and economic
groups in Greensboro, from individuals to businesses. For local citizens who speak Spanish, some materials
to promote volunteer programs are printed in both English and Spanish. A local Spanish radio station and
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 9 of 33

newspaper will also be used for advertising on select campaigns.
Participation Program Narrative
The public is involved in the City's Stormwater Management Program. The following are ongoing
programs that are available in the community.
• Public Hearings
Public hearings are held to address key programs, such as, stream corridor concerns in the
community including restoration projects. Additionally, City Council meetings serve as
public hearing opportunities.
Working with Citizen Volunteers Willing to Educate Others About the Program
As part of the drain marker program, for example, volunteers hang an information piece on
the mailboxes of neighborhood residents where drain markers are installed.
Volunteer Monitoring or Stream Clean-up Activities
As part of our Adopt -a -Stream Program, volunteers are asked to note stream conditions on
their reporting form. The volunteers are required to clean the stream twice per year. Many
also participate in the NC Big Sweep, along with many others who have not formally
adopted a stream.
• Flood Advisory Committee
As part of the National Flood Insurance Program (NFIP) Community Rating System
(CRS), communities are challenged with reducing the impact of flooding on private and
public structures. The flood advisory committee was formed through a partnership with
Guilford County Planning Department to communicate important messages. Topics
covered include discussions about flood hazards, flood safety, flood insurance and vital
ways to protect property, and natural floodplain benefits.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 10 of 33

Illicit Discharge Detection and Elimination
The City of Greensboro maintains a program to identify and eliminate illicit discharges and improper
disposals from its MS4 service area.
BMP Summary Table
BMPs for Illicit Discharge Detection and Elimination (IDDE.) Program
BMP IL
Measurable Goals
Comments
Implementation and
Enforce current Stormwater Management
Ongoing program by the
enforcement of
Ordinance (Chapter 30 of the Greensboro
Water Quality Section;
Stormwater Management
Land Development Ordinance) requirements
Ordinance
pertaining to the illicit discharge and improper
dis osal ofpollutants and waste.
Stream water quality
Conduct routine chemical and physical water
Ongoing program by the
monitoring
quality sampling of major streams. Analyze
Water Quality Section
data, detect potential illicit discharges, and
prioritize locations for follow-up investigation.
Response and
Maintain dedicated helpline and field calls
Ongoing program by the
investigation of citizens'
related to pollution concerns and
Water Quality Section;
concerns
environmental questions from citizens.
Public Education and
Provide staff response to pollution concerns.
Awareness Section; City
Contact Center
Develop and maintain
Create map and inventory procedures for the
Ongoing program by the
storm sewer system
collection of major outfalls that discharge to
Stormwater Management
inventory base map of
waters of the State.
Division, Field
major outfalls
Operations Section
Maintain an inventory of
Maintain an inventory of major outfalls that
Inventory complete;
major outfalls that
discharges to waters of the State.
ongoing collection for
discharges to waters of
annexations and new
the State
developments:
Stormwater Management
Division.
Establish procedures to
Establish and maintain procedures to identify
Ongoing program by the
identify and eliminate
and report failed septic systems or sanitary
Water Quality Section
failed septic systems and
sewer overflows to the appropriate agency
sanitary sewer overflows.
(County health department or local utility
department).
Maintain
Maintain procedures for detecting and tracing
Ongoing program by the
Inspection/detection
the sources of illicit discharges to the MS4 and
Water Quality Section
program to detect dry
for removing the sources.
weather flows at MS4
outfalls
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 11 of 33

BMP Summary Table — Continued
Inter -departmental spill
Maintain cooperative agreement and improve
Ongoing program by the
response team
relationship with spill response team partners.
City's Fire & Police as
City Fire and Police are primary responders,
primary responder. City's
while Stormwater is a secondary responder to
Stormwater Division as
assist in tracking spills and assessing
secondary.
environmental damage as a result of
environmental emergencies.
Commercial/Business
Develop and implement education and
Ongoing program by the
education and inspection
inspection program to inform local businesses
Water Quality Section;
program
of stormwater regulations, hazards of unlawful
currently educating and
discharges, and penalties for violations.
inspecting restaurants.
During the reporting
period, over 400
restaurants have been
educated and inspected.
Education and outreach
Continue ongoing programs and develop new
Ongoing program by the
programs
programs to inform municipal employees,
Water Quality Section;
local businesses, and the general public of the
Public Education and
hazards associated with illicit discharges and
Awareness Section
improper disposal of pollutants and waste.
Detection and Elimination
Greensboro continues to implement a comprehensive program of stormwater ordinance enforcement,
water quality monitoring, education and outreach, spill and citizen complaint response, and formal
inspections in order to prevent, detect, address, and eliminate illicit discharges and improper disposals to
the storm sewer system and receiving waters. The ongoing detection and elimination program currently
includes the following specific tasks:
1. Conducting stream water quality monitoring activity and conducting immediate follow up
when the data suggests a water quality issue.
2. Maintaining a helpline for citizen complaint reporting.
3. Providing professional staff response to citizen reports and complaints.
4. Secondary participation in cooperative spill response team with inter -governmental partners.
5. Development of a formal commercial and business education and inspection program.
6. Conducting stormwater investigations at industrial facilities.
7. Conducting field screening of NPDES MS4 outfalls to detect dry weather flows.
Locating Priority
To locate priority areas for illicit discharge investigations, Greensboro will continue to rely on a
combination of water quality monitoring, inspections, complaints or notifications from citizens and city
staff, and historical knowledge to locate and verify priority areas. Permanent sampling stations will
continue to be located within Greensboro's major watershed sub -basins, and field and laboratory water
quality parameters will be analyzed to detect potential illicit discharges and prioritize locations for follow-
up investigation.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 12 of 33

Removing Sources of Illicit Discharges
Greensboro's Land Development Ordinance (Chapter 30) specifically prohibits the illicit discharge or
improper disposal of pollutants and waste to Greensboro's stormwater conveyance system and subsequent
receiving surface waters. This ordinance authorizes City staff to utilize enforcement action, when
necessary, to stop an illicit discharge, remove the source, and require cleanup of the impacted area.
According to Stormwater's Administrative Procedures for Completing an Enforcement Action, the source
of an illicit discharge may be removed through a series of educational efforts, written Notices of
Violations (NOV), or progressing to civil penalty, if necessary. Once the source and responsible party of
an illicit discharge or improper disposal is identified, an appropriate educational letter or NOV is mailed.
Discontinuation of the discharge is required by the NOV, and the responsible party is required to reply in
writing to Stormwater staff detailing efforts taken to discontinue the unlawful activity and prevent the
activity from occurring in the future. Staff then conducts a follow-up investigation to ensure compliance.
During the July 1, 2016 to June 30, 2017 reporting period, 65 illicit discharges were reported, 74 were
investigated, and 46 were eliminated. Twenty-five (25) of the investigated illicit discharges resulted in an
issuance of a Notice of Violation (enforcement action); and of these 25, two included a civil penalty. The
higher number of investigations as compared to the number reported is a result of when in-house
Stormwater staff recognizes potential polluters while in the field, and they stop to inspect and/or educate
the potential polluter.
In addition to the standard citizen reporting procedure such as the City Call Center, City Stormwater
program has an inspection and education program that during routine operations proactively addresses
small commercial businesses that are identified as having the potential to impact water quality. During the
July 1, 2016 to June 30, 2017, reporting period, approximately 400 restaurants were educated and
inspected. One of these inspections resulted in the issuance of a Notice of Violation (enforcement action).
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 13 of 33

Construction Site Stormwater Runoff Control
The City of Greensboro has a locally delegated Erosion and Sediment Control (E&SC) Program
implemented by the Erosion and Sediment Control Section of the Engineering and Inspections Department.
The E&SC Section is responsible for erosion control plan review, grading permits, erosion control
inspections, enforcement, and review of permanent stabilization of commercial development. A Chief E&SC
Inspector and field inspector(s) comprise the section.
BMP Summary Table
BMPs for Construction Site Stormwater Runoff Control
BMP
Measurable Goals
Comments
Plan Review, Enforce current
Ongoing program
Engineering and Inspections
E&SC ordinances.
implementation and
Dept, Development Services
enforcement. The locally
Division, E&SC Section.
delegated program is regulated
by the NCDEQ, Division of
Energy, Mineral and Land
Resources
E&SC Plan Review
In the City of Greensboro, any proposed development resulting in land disturbance of equal to or greater than
one acre requires a grading permit prior to any land disturbance activity. An NPDES Stormwater Discharge
Permit for Construction Activities is issued in conjunction with the grading permit for sites one acre or
greater. For sites requiring a grading permit, development plans and a grading application are submitted to
the E&SC Section, which reviews the plans to ensure that proper erosion and sediment control practices are
designed. Once the E&SC Section approves the plan, a grading permit is issued and land disturbance may
begin. The City of Greensboro also requires that any development resulting in less than one acre of land
disturbance indicate proper erosion and sediment control measures on the site plan. These plans are reviewed
and approved by the E&SC Section through the TRC process. Therefore, all sites developed through the
City's TRC process are reviewed for compliance with E&SC regulations.
E&SC ProgramImplementation and Enforcement
The City of Greensboro employs a variety of mechanisms to ensure compliance with the provisions of the
Soil Erosion and Sedimentation Control ordinance. First, no site will be issued a grading permit until the
plan reviewer is certain that necessary sediment and erosion control measures are adequately detailed on the
construction documents. Prior to issuing a grading permit for any site disturbing one acre or more, the City
Code requires that the owner/contractor post a bond. Prior to issuing a grading permit for any site disturbing
one acre or more, City Code requires that the owner/contractor post a bond. If a contractor begins land
disturbance without the required permits, appropriate City staff will issue a stop work order.
Should the field inspector identify deviations from the approved plan during construction, the inspector
may provide an inspection report to the owner and contractor indicating required measures and allowable
timeframe to bring the site into compliance. If the required items are not addressed within the appropriate
time, the inspector may issue a notice of violation (NOV) to the owner. A monetary fine may accompany
the NOV. If the required measures are still not addressed as indicated in the NOV, the inspector may
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 14 of 33

issue a stop work order. Additionally, the City of Greensboro reserves the right to deny the issuance of a
certificate of occupancy for sites that continue to remain in nonconformance with the erosion and
sediment control regulations.
Construction Site Inspections
Site inspections to ensure that proper erosion control measures are provided on construction sites are
conducted by qualified field inspectors. Each inspector represents a specific area of the City and inspects
sites within this area. Sites may be inspected more often depending on specific site conditions, the
progress of construction, citizen complaints and/or previously identified problems.
As site inspections may occur more frequently based on several factors, these same factors apply to the
prioritization of site inspections. Specific site conditions, contractor experience, citizen complaints,
previous inspections and the progress of construction all impact which site is given priority for inspection
on a more frequent basis. During the site inspection, the field inspector ensures that erosion and sediment
control measures are implemented according to the approved plan and that no significant offsite
sedimentation is occurring. If the inspector recognizes a problem in the field, the inspector may require
that additional erosion control measures be installed and maintained in accordance with established
enforcement procedures.
Included in the chart below is the data on the number of inspections and enforcement actions carried out by
the E&SC Section during the time period of July 1, 2016 to June 30, 2017.
INSPECTIONS
Reporting Period: July 1, 2016 to June 30, 2017
Universe of active construction
sites
300
Number of active construction
sites inspected
300
Number of construction sites
found to be non -compliant after
the initial inspection
9
Number of follow-up
inspections
9
ENFORCEMENT
Reporting Period: July 1, 2016 to June 30, 2017
Number of informal enforcement actions noncompliance
9
Number of formal enforcement actions without penalty
9
Number of formal enforcement actions with penalty
0
Number of stop work order issued
0
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 15 of 33

Post -Construction Stormwater Management for New Development and
Redevelopment
The City of Greensboro enforces local stormwater management and riparian buffer regulations in addition to
State approved water -supply watershed protection regulations. Throughout the NPDES permit compliance
period, the City of Greensboro will review existing ordinances and, if necessary, develop and implement
revised ordinances in order to implement the post -construction stormwater management program with the
goal of further minimizing impacts to surface water quality. Ordinance language specific to the Phase H
rules, specifically with regard to post -construction runoff, was adopted by City council on April 7, 2009, and
became effective June 1, 2009.
BMP Summary Table
BMPs for Post -Construction Site Stormwater Runoff Controls
BMP
Measurable Goals
Comments
Post -Construction
Develop and adopt by ordinance a
The ordinance was adopted by
Stormwater Management
program to address stormwater
City Council on April 7, 2009 and
Program
runoff from new development and
became effective June 1, 2009.
redevelopment within 24 months
of the permit issue date.
Strategies which include
Developed strategies that include a
City of Greensboro Stormwater
BMPs appropriate for the
combination of structural and/or
Management Manual requires any
MS4
non-structural SCMs implemented
proposed structural SCM be
in concurrence with (a) above.
accompanied by an operation and
Provide a mechanism to require
maintenance plan concurrent to
long-term operation and
development plan approval. It is
maintenance of structural SCMs.
also required that City inspectors
Require annual inspection reports
have access to perform required
of permitted structural SCMs
inspections.
performed by a qualified
professional.
Establish nutrient sensitive
Develop, adopt, and implement an
The Greensboro Land
waters (NSW) protection
ordinance to ensure that the best
Development Ordinance was
measures (for programs
management practices reduce
reviewed and modified to ensure
with development or
nutrient loading to the maximum
structural and non-structural
redevelopment draining to
extent practicable. In areas where
SCMs reduce nutrient loading to
NSW waters)
the Environmental Management
the maximum extent practicable.
Commission has approved a
Nutrient Sensitive Water Urban
Stormwater Management Program,
the provisions of that program
fulfill the nutrient loading
reduction requirement.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 16 of 33

BMP Summary Table — Continued
Deed Restrictions and
Protective Covenants
Impose or require recorded deed
restrictions, plats, and/or
protective covenants that ensure
development activities will
maintain the project consistent
with approved plans.
Current City of Greensboro Land
Development Ordinance requires
a maintenance note be placed on
final plats stating the
maintenance responsibilities,
consistent with approved plans,
for the project SCM.
Establish a program under the
Coordinate with County health
Stormwater Division coordinates
Post -Construction minimum
department to control the known
with Guilford County Health
measure to control the sources
sources of fecal coliform from
Department to control the known
of fecal coliform to the
septic systems to the maximum
sources of fecal coliform from
maximum extent practicable.
extent practicable.
septic systems within the City's
jurisdictional limits to the
maximum extent practicable.
Additionally, the City's Water
Resources Department funds and
performs an ongoing sewer
rehabilitation program to
minimize and eliminate cross
connections between the storm
and sanitary sewer systems.
Operation and Maintenance
Require an operation and
City of Greensboro Stormwater
Plan
maintenance plan that ensures the
Division's development plan
adequate long-term operation of
review process requires a
the structural SCMs required by
stormwater management plan
the program. The operation and
and separate SCM operation and
maintenance plan may require the
maintenance plan (consistent
owner of each structural SCM to
with the provisions outlined in
submit a maintenance inspection
the State stormwater design
report on each structural SCM
manual) be submitted prior to
annually to the local program, or
receiving development plan
the maintenance inspections may
approval.
be conducted annually by the
Currently, the City of
Permittee.
Greensboro Stormwater Division
conducts maintenance
inspections on SCMs within the
City's jurisdiction.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 17 of 33

BMP Summary Table — Continued
Educational materials and
Provide educational materials
Stormwater Division's Planning
training for developers
and training for developers. New
and Engineering Section notify
materials may be developed by
developers and engineers of
the permittee, or the permittee
ordinance changes via direct e-
may use materials adopted from
mail, face-to-face meetings upon
other programs and adapted to
request regarding proposed site
the permittees new development
projects, Triad Real Estate and
and redevelopment program.
Building Industry Coalition,
televised City Council meetings,
providing opportunity for public
comment, as well as posting the
changes on the City website.
Setbacks for Built -upon Areas
Require built -upon areas to be
The Greensboro Land
located at least 50 feet landward
Development Ordinance was
of all perennial and intermittent
reviewed and modified to require
surface waters except as provided
a 50 foot stream buffer in
for in the Permittees Post-
accordance with NPDES phase II
Construction Stormwater
requirements.
Ordinance. For purposes of this
In addition, the City of
section, a surface water shall be
Greensboro has updated the
present if the feature is shown on
riparian buffer requirements
either the most recent printed
according to the Jordan and
version of the soil survey map
Randleman Lake Rules. The
prepared by the Natural
"Table of Activities and
Resources Conservation Service
Structures in Stream Buffers
of the United States Department
(Zone 1 & Zone 2)" located in
of Agriculture or the most recent
Chapter 30 of the Greensboro
version of the 1:24,000 scale (7.5
Land Development Ordinance
minute) quadrangle topographic
determines the allowable uses
maps prepared by the United
within the 50' riparian buffer.
States Geologic Survey (USGS).
Relief from this requirement may
be allowed when surface waters
are not present in accordance
with the provisions of 15A
NCAC 02B .0233(3) (a).
Local Permit Issuance
Currently, Group, Site and Subdivision plans within Greensboro's jurisdiction are reviewed by the City's
Technical Review Committee (TRC) for compliance with applicable development regulations. TRC is an
interdepartmental team charged with enforcing development standards as they relate to Watershed
Protection, Stormwater Management, Water -Supply, Water Reclamation, Zoning, Transportation, Parks
and Recreation, Tree Preservation, etc. Approval by members of TRC is a prerequisite to the issuance of
a grading permit or building permit. The City has reviewed and modified the Greensboro Land
Development Ordinance in order to ensure that plans meet post -construction stormwater management
requirements as defined by 15A NCAC 2H.0126 (10). The final 15A NCAC 2H.0126 (10)(h) rules define
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 18 of 33

low and high density development thresholds and as such these thresholds and any associated permanent
structural control and riparian buffer requirements will be applied to applicable new development or re-
development within the City's jurisdictional area. These requirements have now been incorporated in the
Greensboro Land Development Ordinance to allow for enforcement by City staff prior to issuance of the
applicable construction permit. The post -construction stormwater requirements were adopted by City
Council on April 7, 2009 and became effective June 1, 2009. Additionally, the City amended the Land
Development Ordinance and adopted Jordan Lake Riparian Buffer requirements on November 9, 2010.
These rules became effective on December 1, 2010.
Structural SCM Operation and Maintenance
Greensboro mandates that all required structural stormwater control measures (SCMs) be placed in a
drainage maintenance and utility easement (DMUE) connected to the public right-of-way by a 20 foot
wide access easement. The DMUE and access easement for each SCM must be platted before any
certificate of occupancy is issued for the site. TRC-approved development plans for structural SCMs
include an operation and maintenance plan (consistent with the provisions outlined in the State
stormwater design manual) be submitted prior to receiving development plan approval. Furthermore,
notes are recorded on the plat indicating that the City has the right to access the site for SCM inspections
and that the owner will maintain the SCM per the approved maintenance plan or as directed by the City.
During the reporting period (July 1, 2016 to June 30, 2017), a total of 366 privately owned stormwater
SCMs were inspected by City staff for performance and maintenance compliance. Six owners were issued
a Notice of Violation (NOV) for failing to complete the required maintenance items with two of the six
receiving an additional second NOV. All required SCM maintenance items for the NOV's, including the
sites with the second NOV, except for one, have since (or now) been completed.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 19 of 33

Pollution Prevention/Good Housekeeping for Municipal Operations
Pollution Prevention and Good Housekeeping Programs are an important factor in the improvement of
stormwater runoff quality. Municipal departments that utilize various facilities currently implement good
housekeeping and pollution prevention programs. Additionally, the City Water Resources Department
works to ensure that pollution prevention and good housekeeping measures are being implemented at
other municipal facilities to the maximum extent practicable with the intent of improving stormwater
runoff quality discharged into receiving streams by those municipal facilities and their operations.
BMP Summary Table
F�41 Er BMPs for Pollution Prevention/Good Housekeeping Program
J_BMP
Measurable Goals
Comments
Street Sweeping
Continue ongoing program with periodic
Ongoing program:
review.
Stormwater Management
and Field Operations
Department.
Loose Leaf Collection for
Continue ongoing program with periodic
Ongoing program:
Composting
review.
Stormwater Management
and Field Operations
Department.
Erosion and
City owned or otherwise public
Ongoing program:
Sedimentation Control
construction sites are regulated by NCDEQ,
City owned and other
Division of Energy, Mineral and Land
publicly funded projects
Resources for proper erosion and sediment
obtain appropriate state
control.
permits.
Staff Training/Site
The Stormwater Management Division of
Ongoing cooperative effort
Operator Education
Water Resources distributes education
by the City's departments
material for training employees on various
municipal operations.
Site Planning/Pollution
Develop and implement pollution
Ongoing effort by the City
Prevention Plan for
prevention plans that have been determined
of Greensboro.
Municipal Facilities
to have the potential to impact Water
Quality.
Site inspection and
The City maintains mapping programs that
The City's Stormwater
evaluation of facilities,
consist of all municipal facilities, as well as
Management Division has
operations including the
any related structural SCMs. City
identified a list of specific
MS4 system and
Stormwater Management maintains an
city facilities and ranked
associated structural
ongoing inspection program to monitor,
each of them according to
SCMs.
document and enforce stormwater
their potential to pollute.
discharges to the MS4 system.
Inspections of the high and
medium ranking facilities
have been conducted,
including documenting
areas where improvements
can be made to reduce the
potential of generating
polluted runoff.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 20 of 33

Affected Operations
The facilities listed in the following table are municipal operations that have been issued NPDES
Stormwater Discharge permits. These facilities have developed Municipal Pollution Prevention/Good
Housekeeping techniques in addition with the education and training material sent out.
Municipal Operation
Permit Number
City of Greensboro White St. Landfill
NCG120013
TZ Osborne WWTP
NCG110005
North Buffalo WWTP
NCG110004
Patton Avenue Service Center
NCG080799
Greensboro Transit Authority (Bus Garage)
NCG080893
Training
The City's Stormwater Management Division of Water Resources provides educational and technical
assistance for City facilities pertaining to pollution prevention plans and/or BMPs for the improvement of
overall environmental quality. In addition, the Stormwater Management Division also provides assistance
for City facilities pertaining to structural and non-structural stormwater BMPs for the improvement of
stormwater quality and/or quantity and BMP design and implementation.
The City has identified nine Departments that have a greater potential to contribute pollution to
stormwater runoff. The Departments involved in this program are as follows:
1. Coliseum
2. Engineering and Inspections
3. Field Operations
4. Finance (Equipment Services)
5. Fire
6. Parks and Recreation
7. Police
8. Transportation
9. Water Resources
During the July 1, 2016 to June 30, 2017 reporting period, approximately 852 City of Greensboro
employees received training on municipal pollution prevention. This number includes Water Resources
employee's training DVD's or Videos, the Fire Department's and Field Op's in-depth annual training of
personnel on spill response and pollution prevention.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 21 of 33

FY 16-17 City of Greensboro Municipal Pollution Prevention:
Good Housekeeping Program Departmental Participation
52 Total Employees
■ Fire ■ Field Ops ■ Water Resources
Collectively, it is the responsibility of the entire City of Greensboro to maintain the NPDES city-wide
permit and enforce programs collaboratively. The objective is for all municipal departments that engage
in various operations to implement good housekeeping and pollution prevention methods in everyday
activities and to set a good example for the community to follow.
Site Inspection and Evaluation of Facilities
Stormwater personnel focused on site inspection and evaluation of city owned and operated facilities. A
complete list of all City owned and operated facilities was obtained from a GIS layer file. To prioritize
each facility, the history of spills/concerns, the proximity to a stream or stormwater conveyance system,
and the activities at a particular location were considered when ranking each facility as High, Medium or
Low. This ranking is further defined below.
High: Facilities in this category would have a large amount of outdoor processing activities, close
proximity to a stream and/or material storage on -site or obvious poor housekeeping issues.
Examples of these facilities would be golf courses, satellite fueling stations, facilities that
store salt for deicing roadways or the Coliseum that has many vendors using this property
at all times.
Medium: This category includes facilities that have some outdoor storage or processing, that may
not be in close proximity to a stream. Examples of these type facilities would be larger
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 22 of 33

parks, the science center, water treatment plants and the fire training center.
Low: A facility in low level ranking would have limited or no outdoor processing areas.
Examples of these facilities would be libraries, parking decks, rec centers and fire stations.
During the July 1, 2016 to June 30, 2017 reporting period, the stormwater management division finalized
the SOP, ranked all 126 facilities that do not have a NPDES permit and began conducting inspections of
the municipal facilities with a high or medium ranking. The stormwater management division ranked 22
facilities as having a high or medium risk of generating polluted runoff, and completed 8 facility
inspections (5 high and 3 medium).
Municipal Operation __9W
Parks and Recreation Maintenance
H
City Fueling Station & Salt Barn
H
Bryan Park Complex
H
Tanger Family Bicentennial Gardens
H
Greensboro Coliseum
H
Gillespie Golf Course
Caldwell Park
Greensboro Arboretum
Maintenance and Inspections
The City of Greensboro Stormwater Maintenance Section, within the City's Field Operations Department,
maintains open and closed stormwater infrastructure and drainage conveyance systems that carry public
runoff within the MS4 service area. This section also performs stream maintenance activities and
preventative maintenance on most public stormwater infrastructure.
The City's Stormwater Management Division identifies and inspects industrial and related facilities that
may discharge stormwater into either the MS4 or receiving streams in Greensboro, and also assists the
local industrial community in the development and implementation of appropriate stormwater runoff
controls. In addition, the City has an ongoing litter pick-up program to clear trash and other floatables
from roadways, which helps keep them out of the storm drainage system and surface waters.
Vehicular Operations
The City of Greensboro's vehicular operation centers utilize the City's hazardous waste program to
recycle or dispose used oil, antifreeze, batteries, and spare parts and used chemicals. A new salt storage
barn was constructed in fall 2002 as a BMP to prevent salt stormwater runoff from entering receiving
streams.
Waste Disposal
Waste materials generated from the City's day-to-day activities are managed according to local and state
regulations and vendors utilized by Greensboro are audited to ensure environmental compliance. With
the ongoing public education and awareness programs, the City will continue to facilitate staff meetings to
inform staff of all new and related regulations/programs corresponding with the Municipal Pollution
Prevention and Good Housekeeping Program.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 23 of 33

Examples of Waste Disposal Programs include:
• Hazardous Waste Program
• Solid Waste Recycling
• Lead Disposal Program
• Oil Disposal Program
• Universal Waste Program
• Water Treatment Chemicals Disposal Program
Program to Monitor and Evaluate Storm Water Discharges to the Municipal System
The City of Greensboro has developed and implemented an industrial facilities inspection program during
the first two permit terms. During the current permit term, the inspection program will be reviewed and
revised to reflect current permit conditions. Industrial facilities subject to Section 313 of Title III of the
Superf ind Amendments and Reauthorization Act of 1985 (SARA), and industrial facilities that the City
determines to be contributing or have the potential to contribute a substantial pollutant loading to the
municipal separate storm sewer system will be inventoried and evaluated.
BMP Summary Table
for Monitoring and Evaluating Storm Water Discharges to the MS4
LMPs
BMP
AN Measurable Goals
Comments
Maintain Inventory of Industrial Sites
The City maintains an
The City will update and
inventory of all NPDES
revise list annually.
permitted industrial facilities.
The City will add additional
facilities to list that meet the
SARA Title III (Section 313)
criteria or that contribute
substantial pollutant loading
to the MS4 system.
Inspection Program
The City has developed a
The City has an ongoing
formal inspection program
industrial inspection program
for evaluating industrial
with a goal of visiting all
facilities. This inspection
listed industrial facilities
program will be expanded to
once per permit cycle.
include any facility on the
Annual training is conducted
above stated list.
for City staff on specific
inspection procedures and
staff coordinates with
NCDEQ on a regular basis to
be trained on any issues or
permit updates.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 24 of 33

BMP Summary Table — Continued
Establish and Implement Measures to
The City has developed the
The City has a strong
Evaluate Commercial and Industrial
industrial facilities inspection
working relationship with the
Facilities discharging stormwater to
program to evaluate those
NCDEQ regional office and
the City's MS4
facilities on the above list
county officials. The City's
and ensure all permit
enforcement procedures are
conditions are being met and
utilized when water quality
discharges to the MS4 are not
violations are encountered
considered substantive.
and follow up actions are
deemed necessary. NPDES
permit deficiencies are
addressed in written
notification and are also
forwarded to NCDEQ
(agency with permitting
authority).
During the reporting period (July 1, 2016, to June 30, 2017), a total of 25 NPDES permitted facilities
were inspected by City staff. Of these 25 inspections, 7 were also listed in the Toxics Release Inventory.
One additional unpermitted facility was inspected that was listed only in the Toxics Release Inventory.
No enforcement action was warranted from these inspections. The number of facility inspections varies
from year to year, with some years having more inspections than others. This variation in facility
inspections is due to a previous scheduling agreement between the City of Greensboro and NCDEQ to
avoid overlapping inspections of NPDES permitted facilities.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 25 of 33

Water Quality Assessment and Monitoring
The City of Greensboro has developed and implemented a comprehensive water quality monitoring and
assessment program to evaluate the impacts on water quality.
BMP Summary Table
BMPs for Water Quality Assessment and Monitoring
BMP
Measurable Goals
Comments
Water Quality Assessment and
A DRAFT City of Greensboro
Draft document was submitted
Monitoring Plan
Water Quality Assessment and
to NCDEQ for comment and
Monitoring Plan was submitted
approval within 12 months of
within 12 months of permit
permit issuance as required.
issuance as required by the
NPDES permit.
Water Quality Monitoring
The City will implement the
The City implemented the
water quality assessment and
submitted water quality
monitoring plan in accordance
monitoring plan January 1,
with NCDEQ and the permit
2009.
schedule.
Revisions to the Water Quality
The City will conduct an annual
The City will review and revise
Assessment and Monitoring Plan
review, revise as appropriate,
annually and coordinate with
and submit any revisions to
NCDEQ any proposed changes.
NCDEQ for approval.
Total Maximum Daily Load (TMDL)
The City of Greensboro has an EPA and NCDEQ approved TMDL for Fecal Coliform bacteria for North
Buffalo Creek. The permittee will utilize BMPs within the six minimum measures to address the
permittee's assigned NPDES regulated stormwater waste load allocation (WLA) identified in the
approved TMDL to the maximum extent practicable and to the extent authorized by law. Resolute efforts
are being made to determine the most efficient best management practices that address the MS4 NPDES
regulated Waste Load Allocation identified in the TMDL. Current efforts are continually re-evaluated and
adapted as needed. More importantly, new ideas are continuously shared and assessed, with the ultimate
goal of improving and protecting water quality.
An assessment of available data, BMP strategies, and TMDL Watershed Plan effectiveness will be
conducted and utilized to define the appropriate progress and schedule of the watershed plan within the
context of the Maximum Extent Practical (MEP) standard. Activities conducted throughout the program
implementation schedule to address the MS4 NPDES regulated waste load allocation (WLA) identified in
the TMDL will be evaluated and defined as to the collective contribution to the watershed plan. The
results of the analysis will be utilized to prioritize local funding aimed at elimination of the most
significant portion of the MS4 waste load allocation for the least resources.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 26 of 33

BMP Summary Table
BMPs for Total Maximum Daily Load
BMP
Measurable Goals
Comments
(A) Identify, describe and
Within 24 months the permittee shall
Description, maps, and
map watershed, outfalls, and
prepare a plan that:
outfall information is
streams
• Identifies the watershed(s) subject to an
noted in BMP Narratives
approved TMDL with an approved
following this table.
Waste Load Allocation (WLAs)
assigned to the permittee,
• Includes a description of the
watershed(s),
• Includes a map of watershed(s) showing
streams & outfalls
• 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 to discover and
locate other 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.
(B) Existing measures
Within 24 months the Permittee's plan:
Measures include
• Shall describe existing measures being
education, sampling,
implemented by the Permittee designed
citizen concerns,
to achieve the MS4's NPDES WLA and
industrial inspections, etc.
to reduce the TMDL pollutant of
See information in BMP
concern to the MEP within the
Narratives following this
watershed to which the TMDL applies;
table for a more complete
and
list and descriptions.
• 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 NCDEQ.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 27 of 33

BMP Summary Table — Continued
C) Assessment of Available
Within 24 months the permittee's plan shall
An assessment of the
Monitoring Data
include an assessment of available
programmatic
monitoring data. Where long-term data is
management measures,
available, this assessment should include an
existing TMDL data,
analysis of the data to show trends.
relevant watershed data,
monitoring data, etc., is
performed periodically.
An assessment of
activities conducted under
the TMDL plan will be
performed to evaluate the
overall effectiveness of
the watershed plan and
make any adjustments
deemed necessary. The
assessment will be used,
where possible, to
evaluate the performance
of existing BMPs and
identify additional BMP
strategies as necessary.
(D) Monitoring Plan
Within 36 months the permittee shall
The monitoring plan for
develop and submit to the Division a
the TMDL Watershed
Monitoring Plan for the permittee's
Plan includes current
assigned NPDES regulated WLA as
monitoring programs and
specified in the TMDL. The permittee shall
procedures that will be
maintain and implement the Monitoring
updated as necessary to
Plan as additional outfalls are identified and
achieve the City's waste
as accumulating data may suggest.
load allocation (WLA)
Following any review and comment by the
and reduce the pollutant of
Division the permittee shall incorporate any
concern (POC) to the
necessary changes to monitoring plan and
maximum extent possible.
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.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 28 of 33

BMP Summary Table — Continued
(E) Additional Measures
Within 36 months the permittee's plan
Measures include the
shall:
FOG Program, sanitary
• Describe additional measures to be
sewer rehabilitation, pet
implemented by the permittee
waste stations, and the use
designed to achieve the permittee's
of new technology, and
MS4's NPDES WLA and to reduce
the SSO Reduction
the TMDL pollutant of concern to
Committee. See
• the MEP within the watershed to
information in BMP
which the TMDL applies; and
Narratives following this
Provide an explanation as to how those
table.
measures are designed to achieve the
permittee's MS4's NPDES regulated WLA
to the MEP within the watershed to which
the TMDL applies.
(F) Implementation Plan
Within 48 months the permittee's plan
Current BMPs will
shall:
continue to be
• Describe the measures to be
implemented to achieve
implemented within the remainder of
the Waste Load
the permit term designed to achieve
Allocation to reduce the
the MS4's NPDES WLA and to
pollutant of concern to the
reduce the TMDL pollutant of
MEP. This includes
concern to the MEP and
existing BMPs and the
Identify a schedule, subject to NCDEQ
exploration of additional
approval, for completing the activities.
opportunities.
(G) Incremental Success
The permittee's plan must outline ways to
The TMDL plan describes
track and report successes designed to
ways to track and report
achieve the MS4's NPDES regulated WLA
successes based on the
and to reduce the TMDL pollutant of
TMDL BMPs and goals
concern to MEP within the watershed to
designed to achieve the
which the TMDL applies.
Waste Load Allocation to
reduce the pollutant of
concern to the MEP.
(H) Reporting
The permittee shall conduct and submit to
Following the schedule
the Division an annual assessment of the
per the permit, the TMDL
program designed to achieve the MS4's
watershed plan addresses
NPDES WLA and to reduce the TMDL
and reports on the TMDL
pollutant of concern to the MEP within the
program.
watershed to which the TMDL applies. Any
monitoring data and information generated
from the previous year are to be submitted
with each annual report.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 29 of 33

BMP Narratives
1) Identify, Describe and Map Watershed, Outfalls, and Streams (A)
Watershed Description
The North Buffalo Creek watershed is located in Greensboro, North Carolina (Guilford County), and is in
the headwaters of the Cape Fear River Basin. The eastern flowing stream eventually feeds into the Haw
River. The watershed is represented by small floodplain streams that have some bedrock outcroppings and
are surrounded by gently sloping uplands. North Buffalo Creek's headwaters lie entirely within urbanized
areas (commercial, industrial, and residential with high [>28%] impervious area) in the city of
Greensboro (population >287,000).
As outlined in the City's TMDL Watershed Plan, the compliance point for Upper North Buffalo Creek
TMDL is located where Summit Avenue crosses over North Buffalo Creek. The drainage area from the
headwaters to this compliance point is 21.8 mil and incorporates 8.7 miles of stream. The area is generally
deemed as built out, in that no major future land use changes are predicted. The area is 38% residential,
15% right-of-ways, and 20% forest. Impervious surface constitutes approximately 26% of the watershed.
In January of 2009 the City started collecting water quality samples at the compliance point on a monthly
basis. Samples are analyzed for both physical and analytical parameters.
Map of Drainage area from Headwaters to Fecal Coliform TMDL Compliance Point:
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 30 of 33

Outfall Locations
MS4 outfalls have been determined through GIS and the City's ongoing stormwater inventory process.
See attached map below for outfall locations within the TMDL watershed. Unknown major NPDES
outfalls will be identified utilizing the ongoing stormwater inventory procedures through subsequent
QA/QC checks of various sub -basins, and the ongoing collection and proactive maintenance efforts.
Schedule for Locating New Outfalls
Unknown major NPDES outfalls will be identified utilizing the ongoing stormwater inventory procedures
through subsequent QA/QC checks of various sub -basins, and the ongoing collection and proactive
maintenance efforts. Any new outfalls and/or newly identified outfalls will be recorded and mapped on a
routine basis.
Map of NPDES Outfalls located within the Fecal Coliform TMDL Compliance Area:
Outfalls in Upper North Buffalo Creek Watershed
2) Existing Measures (B)
Outfall Screening
NPDES outfalls are investigated/screened on a routine basis to determine illicit discharges or improper
disposals. Locations are determined based on basin, citizen concerns, spill calls, results from various
monitoring data, and/or routine selection of particular basins. Any noted concerns are investigated further,
which may include tracking, obtaining readings for physical parameters, and/or taking samples to be
analyzed in the field or by the contracted lab.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 31 of 33

Education
• Citizen participation with the Drain Marker program, Adopt -a -Stream program, pet waste stations,
etc., to encourage citizens to have personal involvement
• Partnering with communities and organizations and using the media for a broad -scale approach to
pollution education and prevention
• Using At Your Service, the City's monthly newsletter that is distributed with the water bill, to
educate residents about pet waste and fecal coliform
• Educating citizens about TMDLs via the City's website
Small -Quantity Polluters Program
As well as general education, specific potential polluters in the community are targeted and educated
regarding housekeeping practices and proper waste disposal. This Pollution Prevention Program entails
water quality staff to inspect and educate businesses that are common polluters, such as painters,
landscapers, ready -mix concrete companies, auto repair shops, mobile washers, restaurants, etc. This
ongoing prevention program is highly regarded and has been determined to be a worthwhile endeavor in
keeping pollution from streams and other water sources.
Fixed Interval Sampling
Monthly sampling and assessments are performed, including the analysis of results and the need for
outfall follow-ups; this includes a sampling site at the compliance point in additional to three other
monitoring sites in the TMDL watershed. Monthly sampling and assessments are performed, including
the
Sanitary Sewer Overflow (SSO) Prevention
Ongoing evaluation of citywide SSOs is being used to direct resources for maintenance and rehabilitation
of sanitary sewer lines in the TMDL watershed in an effort to prevent overflows and exfiltration. In this
reporting period, over 24,500 feet of sewer line underwent rehabilitation.
Field Observations
Issues discovered by staff through inventory collections, outfall screenings, etc., and water quality staff
address potential issues.
Public Concerns/Reports
Reports are followed up by investigating, tracking, resolving, and enforcing violations when applicable.
Industrial Inspection Program
NPDES permitted facilities and TRI facilities are inspected, focusing on a review of the Stormwater
Prevention Pollution Plan, spill prevention and response procedures, employee training, housekeeping
practices, and outfall monitoring.
3) Additional Measures
Fats, Oils, and Grease (FOG) Program
This ongoing program seeks to reduce the number of SSOs due to issues caused by oil and grease.
Sanitary Sewer Rehabilitation
During the reporting year, over 34,000 linear feet of sewer underwent rehabilitation in the North Buffalo
watershed up to the compliance point.
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 32 of 33

Pet Waste Stations
Pet waste stations in the TMDL watershed have been mapped, including both private stations and those
maintained by the City of Greensboro. Within this watershed, there are currently 113 pet waste stations
(84 private, 29 city maintained).
New Technology
New technology being used for the City's wastewater collection system, such as SL-RAT (Sewer Line
Rapid Assessment Tool), could help reduce the number of SSOs, therefore reducing the WLA for the
POC. The Operations division continually explores new and updated equipment to prevent SSOs and to
investigate or repair sewer lines.
SSO Reduction Committee
This committee is compiled of representatives from multiple divisions within the Water Resources
Department. The goal of the committee is to take a holistic approach to preventing SSOs by analyzing
past overflows using GIS, the work order management system, and staffs institutional knowledge to
implement enhanced reduction strategies.
Threatened or Endangered Species Protection Program
The City of Greensboro currently does not have any federally listed aquatic animal species that are listed
as threatened or endangered by the U.S. Fish and Wildlife Service or the National Marine Fisheries
Service under the provisions of the Endangered Species Act.
For more information on the City of Greensboro's NPDES MS4 Discharge Permit and associated
Stormwater Quality Management Program Plan, please visit the Stormwater website at:
www.greensboro-nc.gov/stormwater
City of Greensboro's Stormwater Management Program Plan (Stormwater Plan) September 30, 2017
NPDES Permit No. NCS000248 Page 33 of 33