NCS000248_Greensboro Audit Report_20220810

MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
PHASE I PROGRAM AUDIT REPORT
NPDES PERMIT NO. NCS000248
CITY OF GREENSBORO, NORTH CAROLINA
Po Box 3136
Greensboro, NC 27402
Audit Date: June 7, 2022
Report Date: August 10, 2022
North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources Stormwater Program
512 N. Salisbury Street, 6th floor
1612 Mail Service Center
Raleigh, NC 27699-1622

TABLE OF CONTENTS
AuditDetails..................................................................................................................................................1
PermitteeInformation..................................................................................................................................2
Listof Supporting Documents.......................................................................................................................3
Program Implementation, Documentation & Assessment...........................................................................5
Public Education and Outreach................................................................................
Public Involvement and Participation......................................................................
Illicit Discharge Detection and Elimination(IDDE)...................................................
Construction Site Runoff Controls............................................................................
Post -Construction Site Runoff Controls...................................................................
Pollution Prevention and Good Housekeeping for Municipal Operations ...............
Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems..
Water Quality Assessment and Monitoring.............................................................
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1.........
Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2.........
Appendix A: Supporting Documents
F
...............................10
...............................11
...............................13
...............................14
...............................19
...............................22
...............................23
............................... 24
...............................26
DISCLAIMER
This audit consists of an evaluation of program compliance with the issued permit and implementation of
the approved Stormwater Management Plan. This audit report does not include a review of all program
components, and program deficiencies in addition to those noted may be present. The permittee is
required to assess program progress and permit compliance, and to implement the approved Stormwater
Management Plan in accordance with the issued permit.
NCS000248 Greensboro 2022 MS4 Audit ii

Audit Details
Audit ID Number:
Audit Date(s):
NCS000248—Greensboro 2022 MS4 Self -Audit and Audit
Self -Audit 4/5/2022-5/13/2022,
Self -Audit Report — 5/13/2022
Audit — 6/7/2022
Audit Report — 8/10/2022
Minimum Control Measures Evaluated:
© Program Implementation, Documentation & Assessment (evaluated during self -audit)
® Public Education & Outreach (evaluated during self -audit)
® Public Involvement & Participation (evaluated during self -audit)
® Illicit Discharge Detection & Elimination (evaluated during self -audit)
® Construction Site Runoff Controls (evaluated during self -audit)
® Post -Construction Site Runoff Controls (evaluated during self -audit and onsite audit)
® Pollution Prevention and Good Housekeeping for Municipal Operations (evaluated during self -audit)
® Program to Monitor and Control Pollutants (evaluated during self -audit)
® Water Quality Assessment & Monitoring (evaluated during self -audit)
Field Site Visits:
❑ Municipal Facilities. Number visited: (moose an it—i+.
❑ MS4 Outfalls. Number visited: . . ';° � - . `' em.
❑ Construction Sites. Number visited: a . w° . - ; n item.
® Post -Construction Stormwater Runoff Controls. Number visited: 2
❑ Other: Number visited: Cho se an item.
❑ Other: Number visited: Choose fart irem.
Auditors
Note: MS4 Phase I Program Self -Audit Report-NCS000248 has additional information
Name
Title
Paul Clark
NCDEQ, DEMLR, Stormwater
Audit Report Author
Paul Clark
August 10, 2022
Name
Date/
Water Supply Watershed Protection Coordinator
Signature
Title
NCS000248—Greensboro 2022 MS4 Self -Audit
Page 1 of 27

Permittee Information
MS4 Permittee Name:
Greensboro
Permit Effective Date:
10/10/2018
Permit Expiration Date:
10/9/2023
Mailing Address: Date of Last MS4 Inspection/Audit:
PO Box 3136, Greensboro, NC 27402-3136 September 11-13, 2007
Permit Owner of Record:
City of Greensboro
Name
Primary MS4 Representatives Participating in Audit
Title
David Phlegar
Stormwater Management Division Manager
Laine Roberts
Public Education Coordinator
Debbie Shoff ner
Water Quality Analyst
Ray Johnson
Stormwater Operations Supervisor
Cass Heaton
Chief of Sediment and Erosion Control
Johnnie Hill
Engineering Supervisor for Plan Review
Virginia Spillman
Assistant Director, Water Resources
Elea Reyna Ocampo
Water Quality Specialist
Blake Strumbel
Water Quality Analyst
Toni Branson
Water Quality Supervisor
Terri Aprile
Watershed Plan Reviewer
Marina Rincon Bermudez
Watershed Plan Reviewer
NCS000248_Greensboro 2022 MS4 Self -Audit Page 2 of 27

List of Supporting Documents
Item Number
Document Title
Document Format
(web link, e- file, etc.)
01
02
Ordinance Section 30-12-7 (Stormwater Management)
Stormwater Management Plan
Stormwater Quality Management Program Plan Annual Reports (five most
recent fiscal years)
DEMLR Stormwater ePayments verification (screenshot)
pdf
pdf
03
pdf
04
pdf
05
Spills and Concerns (SAC) Database Instruction Manual
pdf
pdf
06
Example of recent correspondence with regional DEQ office regarding a fish kill
Small Polluters Program: Standard Operating Procedures
07
pdf
08
Stormwater Program webpage and "Get Involved" (Public Education and
Outreach) webpage (screenshots)
pdf
09
Examples of Public Education and Outreach materials (general Stormwater
educational material)
pdf
10
City Contact Center webpage, "Report Water Pollution" web form, and "GSO
Collects" smartphone app webpage (screenshots)
pdf
11
Examples of public outreach approaches designed to reach the target audiences
pdf
12
Memorandum of Understanding (MOU) between Stormwater SMART
(Piedmont Triad Regional Council and example extent of exposure for public
Examples of volunteer opportunities designed to promote ongoing citizen
participation
pdf
13
pdf
14
Examples of opportunities for public input on stormwater issues and the
stormwater program
pdf
15
City of Greensboro webpage providing information on MS4 permit and how
public may request copy of SWMP
pdf
16
City of Greensboro Land Development Ordinance Section 30-12-7.3 (Illicit
Discharges and Improper Disposal)
pdf
17
City of Greensboro Land Development Ordinance Section 30-12-7.6
(Enforcement)
pdf
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 3 of 27

18
City of Greensboro Illicit Discharge Detection and Elimination (IDDE) Program
Plan (Standard Operating Procedures)
pdf
19
City of Greensboro Administrative Procedures for Completing an Enforcement
Action ("Enforcement SOP")
pdf
20
City of Greensboro NPDES Outfall Screening Program Standard Operating
Procedures
pdf
pdf
21
22
Example City staff attendance logs for IDDE and small polluter training
Example call summaries for IDDE investigation, follow up, and enforcement
pdf
23
Official letter from NCDEQ-DEMLR delegating continued administration of SPCA
1973 to City of Greensboro Erosion and Sediment Control Program
pdf
24
Erosion and Sediment Control Plan submittal procedure — public funding or
power of eminent domain (screenshot)
pdf
25
City of Greensboro Land Development Ordinance Section 30-12-3 (Water Supply
Watersheds and Other Watershed Districts)
pdf
26
City of Greensboro Land Development Ordinance Section 30-13-5 (Engineered
Stormwater Controls)
pdf
27
Example approved design plans with inspection and maintenance requirements
specified
pdf
28
Private SCM Inspection Program — Standard Operating Procedures
Example SCM inspection reports by qualified professionals
pdf
29
pdf
30
Example final plat indicating maintenance responsibility
pdf
31
Example meeting agenda for Triad Real Estate and Building Industry Coalition
(TREBIC)
pdf
32
NCDEQ Stormwater Design Manual (table of contents)
pdf
33
Standard Operating Procedures: Pollution Prevention and Good Housekeeping—
Municipal Facilities Inspection and Maintenance Program
pdf
34
City Owned SCM Inspection Program Standard Operating Procedures
pdf
35
City of Greensboro Municipal Separate Storm Sewer System Operation and
Maintenance Plan
pdf
36
37
Pollution Prevention Plan: City of Greensboro Transfer Station SPPP
Pollution Prevention Plan: City of Greensboro Parks & Recreation Maintenance
Facility
pdf
pdf
38
City of Greensboro — Municipal Vehicle/Equipment Washing Standard Operating
Procedures
pdf
39
Standard Operating Procedures: Pollution Prevention and Good Housekeeping—
Education and Outreach Program
pdf
NCS000248—Greensboro 2022 MS4 Self -Audit Page 4 of 27

40
Staff Training Tracking Information for Pollution Prevention and Good
Housekeeping
xISx
41
Training Video Views for Pollution Prevention and Good Housekeeping
pdf
42
Industrial Facility Inventory
xlsm
43
Stormwater Industrial Facilities Inspection Program —Standard Operating
Procedures
pdf
44
Example compliance letter and correspondence with DEMLR for industrial
facility
pdf
45
City of Greensboro NPDES Permit Program Water Quality Assessment and
Monitoring Plan
pdf
46
Fixed Interval Monitoring Program: Standard Operating Procedures
pdf
47
Description of Water Quality Index (WQI) Database and Data Warehouse
pdf
Program Implementation, Documentation & Assessment (Information taken from self -audit)
Staff Interviewed:
David Phlegar, Stormwater Management Division Manager
(Name, Title, Role)
Permit Citation
Program Requirement
Status
Supporting
Doc No.
IL.A.
01:
Program
The permittee maintained adequate legal mechanisms, such as regulations,
List of
supporting
Implementation
ordinances, policies and procedures to implement all provisions of the Stormwater
Yes
Documents
Management Plan (SWMP).
(pages3&4
of this
document)
The permittee implemented provisions of the Stormwater Management Plan and
evaluated the performance and effectiveness of the program components annually.
Yes
02,03
The permittee maintained written procedures for implementing the six minimum
control measures, which identify specific action steps, schedules, resources and
Yes
02
responsibilities.
The permittee is current on payment of invoiced administering and compliance
monitoring fees (see Stormwater e-payments on https:11deq.nc.g0v1sw).
Yes
04
Comments
The legal authorities for the City to implement and enforce its Stormwater Program are established through Section 30-12-7
(Stormwater Management) of the City's Land Development Ordinance. The resources provided in the List of Supporting Documents
consist of policies and procedures established by the City to implement and enforce its stormwater management program in
accordance with and under the legal authority of the City's Stormwater Management Ordinance.
The City's Stormwater Management Plan describes written procedures for implementing the minimum control measures as
required by the City's Phase I MS4 permit, and the City's Annual Reporting is the primary means by which the City evaluates the
performance and effectiveness of the program components.
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 5 of 27

Program Implementation, Documentation & Assessment (Information taken from self -audit)
III. A. List of
Program The permittee maintained documentation of all program components including, but Supporting
Documentation not limited to, inspections, maintenance activities, educational programs, Yes Documents
(pages 3&4
implementation of BMPs, enforcement actions and other stormwater activities. of this
Documentation is kept on -file by the permittee for a period of five (5) years. I Yes 1 02
The permittee's Stormwater Management Plan is reviewed and updated as
Yes 02
necessary, but at least on an annual basis.
Comments
Documentation of all program components is described in the individual minimum measures within this audit report. Please refer
to those sections for detailed information as well as the List of Supporting Documents.
W.B. The permittee submitted annual reports to the Department by October 31st of each yes 03 and
Annual Reporting calendar year for the previous fiscal year's activities (from July Vt to June 30th)
LR
records
The Annual Reports included appropriate information to accurately describe the progress, status, and results
of the permittee's Stormwater Management Plan, including, but not limited the following:
a. A detailed description of the status of implementation of the Stormwater Plan as j
a whole. This includes information on development and implementation of each
Yes 02,03
major component of the Stormwater Management Plan for the past year and
schedules and plans for the year following each report.
b. A description and justification of any proposed changes to the Stormwater
Management Plan. This includes descriptions and supporting information for the Yes 02,03
proposed changes and how these changes will impact the Stormwater Plan
(results, effectiveness, implementation schedule, etc.).
c. Documentation of any necessary changes to programs or practices for
assessment of management measures implemented through the Stormwater Yes 02,03
Management Plan.
d. A summary of data accumulated as part of the Stormwater Management Plan Yes 02,03
throughout the year along with an assessment of what the data indicates.
e. An assessment of compliance with the permit, information on the establishment Yes 02,03
of appropriate legal authorities, inspections, and enforcement actions.
f. Discussion of program funding. Yes 02,03
Comments
All information is on file and submitted annually.
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 6 of 27

Program Implementation, Documentation & Assessment (Information taken from self -audit)
IV.D. The Permittee maintained a record of any illicit discharge that reaches waters of the
Other Information state and may cause or contribute to a violation of the water quality standards or Yes os
constitute an imminent threat to health or the environment
The record includes dates, identification of possible responsible parties, causes, and
Yes OS
any action taken by the permittee or the responsible party.
Discharges that constitute an imminent threat to health or the environment were
reported within 24 hours by phone or e-mail to the Division Regional Office during Yes 06
business hours, or to the NC Division of Emergency Management State Operations
Center hotline outside of business hours.
Comments
Records of illicit discharges are maintained in the Spills and Concerns (SAC) database. The City's SAC Database Instruction Manual
describes the function of the database and includes numerous screenshots illustrating the types of information that is recorded and
how information is input.
The Stormwater Program is in regular contact with the NCDEQ regional office on spills/discharges and other water quality related
concerns. The referenced supporting document includes an example of recent correspondence with the regional office regarding a
fish kill.
Additional I Program documentation is complete.
Comments:
NCS000248_Greensboro 2022 MS4 Self -Audit Page 7 of 27

Public Education and Outreach
Staff Interviewed: Laine Roberts, Public Education Coordinator
(Name, Title, Role)
Permit Citation Program Requirement Status Supporting
Doc No.
II.B.2.a. The permittee described the target pollutants and target pollutant sources that the
Target Pollutants Yes 02
public education program is designed to address and why they are an issue.
& Sources
Comments
Target pollutants and sources are addressed in the City's Stormwater Management Plan and through the City's Public Education
and Outreach Program.
II.B.2.b. The permittee described the target audiences likely to have significant stormwater
Yes j 02,07
Target Audiences impacts and why they were selected.
Comments
Target audiences are described in the City's Stormwater Management Plan and are addressed through the City's Public Education
and Outreach Program. In addition, the City's Small Polluters Program SOP identifies small polluters (e.g., auto shops, landscapers,
painters, restaurants, etc.) that are targeted as part of the City's IDDE program.
ILB.2.c.
promoted and maintained an internet web site designed to convey the
Thegpermittee
Informational Yes 08
ram's message.
Web Site
Comments
Public information on the City's Education and Outreach program is provided at cr. There is a
webpage dedicated to the City's Public Education and Outreach program where anyone can submit a public education request at
www.E,reci-Sboro-nc.gov/dep? irtments/wate,,-r,.'s urCeSfgE,.t-invoived.
II.B.2.d. The permittee distributed general stormwater educational material to appropriate
Public Education Yes 09
target groups as likely to have a significant stormwater impact.
Materials
Comments
The City has distributed many educational materials in multiple languages through its Education and Outreach program and reports
metrics on audiences reached/number of participants in its annual reporting. The referenced supporting document provides select
examples of general stormwater educational materials and is not exhaustive.
11.B.2.e.
The permittee promoted and maintained a stormwater hotline(s) or helpline(s) for
Stormwater
the public to request information about stormwater, public involvement &
Yes
10
Hotline
participation, and to report illicit connections & discharges, etc.
Comments
There are multiple avenues for the public to request information and report stormwater issues, including the City's online "Report
Water Pollution" form (r:. •.=bot^-e."/ oar W,;u `^:) and the City's Contact Center which receives input and inquiries
via phone (336-373-CITY), email (see Contact Center webpage), and live chat cc'7�C.,::t-
t :..:ck:I In 2018 the City launched the "GSO Collects" smartphone app to provide the public direct access to Field Operations staff
for trash, recycling, proper disposal of household hazardous waste, and general issues and inquires.
11.B.2.f.
The permittee's outreach program, including those elements implemented locally or
Public Education
through a cooperative agreement, include a combination of approaches designed to
Yes
& Outreach
reach the target audiences.
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 8 of 27

Public Education and Outreach
Program For each media, event or activity, including those elements implemented locally or
Implementation through a cooperative agreement, the permittee estimated and recorded the extent Yes 12
of exposure.
Comments
The City's Public Education and Outreach Program includes a wide variety of approaches to reach target audiences. Examples
include social media posts, partnerships with Stormwater SMART, seasonal tabling events throughout the year, radio and television
ads, newspapers, bill inserts, activities with local schools and libraries, and more. The referenced supporting document provides
select examples illustrating a combination of approaches and is not exhaustive. In addition, the City's annual reporting provides
information on BMPs for public education and outreach including activities and analytics (e.g., number of events, number of
individuals reached, etc.)
The City has an agreement with Stormwater SMART for outreach/education support and a Memorandum of Understanding (MOU)
is provided in the supporting documents. The partnership continues and an updated MOU is currently being routed through the
City for signatures. In addition, an example summary of public education and outreach activities documenting the extent of
exposure is also provided for 2021-2022 (to date); please note that this list is not exhaustive.
Additional The City's annual stormwater management program report cites statistics from the educational program,
Comments: website analytics, hotline calls, etc.
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 9 of 27

Public Involvement and Participation
Staff interviewed: Laine Roberts, Public Education Coordinator
(Name, Title, Role)
Permit Citation Program Requirement Status Supporting
Doc No.
II.C.2.a.
Volunteer
The permittee included and promoted volunteer opportunities designed to promote
Community Yes 13
ongoing citizen participation.
Involvement
Program
Comments
In addition to the Adopt -a -Stream program (, ,kvw.greet�sb(,,ro-n4,gov/;ado ta—stream), the City promotes public engagement via
NextDoor, Facebook, Instagram, and Twitter. Also, bill inserts, newsletters, local newspaper advertisements (including in Spanish),
plus special events and community programs. The referenced supporting document provides select examples of volunteer
opportunities and is not exhaustive.
II.C.2.b.
Mechanism for
The permittee provided and promoted a mechanism for public involvement that
Public
provides for input on stormwater issues and the stormwater program.
Yes
13,14
Involvement
Comments
Opportunities for public input and involvement are provided every two weeks at City Council meetings; input and opportunities for
public engagement are also received via social media, NextDoor, during the permit renewal process, at public events, from the
website, and via emails to City officials that are routed to the Stormwater Program. The referenced supporting document provides
select examples of general public involvement opportunities and is not exhaustive.
II.C.2.c.
The permittee promoted and maintained a hotline/helpline for the public to request
Hotline/Help Line
information about stormwater, public involvement & participation, and to report
Yes
10
illicit connections &discharges, etc.
Comments
See'II.B.2.e. Stormwater Hotline' in Public Education and Outreach minimum measure for more information.
II.C.2.d.
The permittee made the most recent Stormwater Management Plan available for
Public Comment
public review and comment.
Yes
15
Comments
Information on the City's SWMP, including how to request the most recent version, is provided via the Stormwater Program
webpageat�:��;E�.�;�cr.�wF��c.;c�,Js
II.C.2.e.
The permittee complied with State, Tribal and local public notice requirements when
Public Notice
implementing the public involvement / participation program.
Yes
13
Comments
The referenced supporting document provides select examples of means through which the City issues public notices and is not
exhaustive.
Additional
Program is continually seeking new opportunities to increase public involvement and engagement in the
Comments:
stormwater program and improve water quality.
NCS000248_Greensboro 2022 MS4 Self -Audit Page 10 of 27

Illicit Discharge Detection and Elimination (IDDE)
Staff Interviewed: Debbie Shoffner, Water Quality Analyst
(Name, Title, Ray Johnson, Stormwater Operations Supervisor
Role)
Permit Citation
Program Requirement Status
Supporting
Doc No.
II.D.2.a.
The permittee maintained adequate ordinances or other legal authorities to prohibit 16, 17, 18,
Legal Authorities
illicit connections and discharges and enforce the approved IDDE Program. Yes 19
Comments
Prohibition and enforcement of illicit connections and discharges and the City's IDDE Program are made possible through Section
30-12-7.3 (Illicit Discharges and Improper Disposal) and Section 30-12-7.6 (Enforcement) of the City's Land Development Ordinance
as well as the City's IDDE Program Plan (SOP) and Enforcement SOP.
II.D.2.b. The permittee maintained a current map showing major outfalls and receiving
MS4 Mapping streams. Yes 02,20
Comments
The City updates the map of major outfalls and receiving streams annually, if needed, in the SWMP. There is also a screenshot of
the dashboard in the City's NPDES Outfall Screening SOP.
II.D.2.c.
The permittee maintained written procedures and/or Standard Operating Procedures
Dry Weather Flow
(SOPs) for detecting and tracing the sources of illicit discharges.
Yes
18,20
Program
The permittee maintained written procedures and/or Standard Operating Procedures
(SOPs) for removing the sources or reporting the sources to the State to be properly
Yes
18,20
permitted.
The permittee maintained written procedures and/or SOPS that specify a timeframe
for monitoring and how many outfalls and the areas that are to be targeted for
Yes
20
inspections.
Comments
The City maintains an IDDE Program Plan (SOP) and NPDES Outfall Screening SOP which provide written procedures for detecting,
tracing, removing, and reporting the sources of illicit discharges. The Outfall Screening SOP specifies that all major outfalls should
be inspected at least once per permit cycle, and that specific outfalls may be prioritized based on citizen reports and concerns.
Further, the Inspection Dashboard (illustrated in the Outfall Screening SOP) notifies the inspector of the current status of each
outfall to help them identify and prioritize outfalls for inspection.
*Major outfalls are discharges from > 36" diameter pipes or drainage areas of > 5€1 acres. in areas zoned for industrial activity, major outfalls
are > 12" or drainage area > 2 acres.
II.D.2.d. The permittee conducted training for appropriate municipal staff on detecting and
Employee Training reporting illicit connections and discharges. Yes 18,21
Comments
The City's IDDE Program Plan (SOP) describes municipal staff training for illicit connection and discharge detection and reporting.
The example training attendance logs included in the supporting documents provide an example of staff participation in training for
IDDE and small polluters.
II.D..2.e. The permittee maintained and publicized reporting mechanism(s) for the public to
Yes 10
Public Reporting report illicit connections and discharges.
NCS000248_Greensboro 2022 MS4 Self -Audit Page 11 of 27

Illicit Discharge Detection and Elimination (IDDE)
Comments
There are multiple avenues for the public to report potential illicit connections and discharges, including the City's online "Report
Water Pollution" form and the City's Contact Center which can be reached via phone
(336-373-CITY), email (see Contact Center webpage), or live chat In 2018,
the City launched the "GSO Collects" smartphone app to provide the public direct access to Field Operations staff for trash,
recycling, and general issues and inquiries —the "Report an Issue" feature can be used to direct requests to the relevant supervisor.
II.D.2.f.
Documentation The permittee documented the date of investigations, any enforcement action(s) or
Yes os, 19, 22
remediation that occurred.
Comments
The City maintains a Spills and Concerns (SAC) database to track reports/complaints including the manner in which the report was
received, initial investigations, observations including photos, and follow-up actions including enforcement. The City's SAC
Database Instruction Manual provides detailed instructions on how to use the database including numerous screenshots of the
database. The City's IDDE Program Plan (SOP) also outlines investigation and reporting procedures including referencing the
Enforcement article of the City's Land Development Ordinance (30-12-7.6 Enforcement) and the City's Enforcement SOP.
Two examples of call reports are provided in the Supporting documents to demonstrate how the City documents investigations,
remediation, and enforcement for spills.
Additional
The Small Polluters Program (supporting document 07) meets the objective of identifying and targeting
Comments:
specific pollution sources and audiences that may have the potential to contribute to impaired water quality.
NCS000248—Greensboro 2022 MS4 Self -Audit
Page 12 of 27

Construction Site Runoff Controls
Staff Interviewed:
Cass Heaton, Chief of Sediment and Erosion Control
(Name, Title, Role)
Program Delegation Status:
The permittee has a delegated Sediment and Erosion Control Program and implements the North Carolina Sedimentation
Pollution Control Act (SPCA) of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code.
The delegated or authorized Sediment and Erosion Control Program effectively meets the NPDES MS4 MEP standard for
Construction Site Runoff Controls by permitting and controlling development activities disturbing one or more acres of land surface
and those activities less than one acre that are part of a larger common plan of development as authorized under the Sediment
Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code.
Permit Citation Program Requirement Status
Supporting
Doc No.
II.E.2.a.
Delegated SPCA The permittee implements a delegated program in compliance with the Sediment
Program Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Yes
23
Administrative Code within the city's jurisdictional area.
Comments (Note date of last SPCA delegated program review by NCDEQ-DEMLR staff and result)
The City's Erosion and Sediment Control Program was reviewed by NCDEQ-DEMLR on December 14, 2021. On February 22, 2022,
the Sedimentation Control Commission voted to continue delegation of the SPCA of 1973 to the City of Greensboro. A letter
announcing DEMLR's decision is provided in the supporting documents and is dated February 24, 2022.
II.E.2.c.
The permittee provided and promoted a means for the public to notify the
Reporting Yes so
Mechanism appropriate authorities of observed erosion and sedimentation problems.
Comments
The primary means for the public to report erosion and sedimentation concerns is the City Contact Center (336-373-CITY). From
there, calls are directed to the appropriate program and staff. Input on erosion and sedimentation issues is also received from
numerous avenues including reports from internal City staff (phone calls, emails), the GSO Collects app, and social media.
II.E.2.d.
The permittee coordinated the approval of the construction site runoff control with
Coordination with
DEMLR for new development and redevelopment projects to be built within the
Yes
24
DEMLR
permittee's planning jurisdiction by entities with eminent domain authority.
Comments
The City's Erosion and Sediment Control Plan submittal system incorporates a prompt: "Is this site using any public funding, or does
the applicant have the power of eminent domain?" If "yes" is selected, the applicant is directed to submit the plan to NCDEQ for
review and approval.
I.D.
Implementation in Construction Site Runoff Control requirements are applied in the Permittee's Extra Not
ETI Territorial Jurisdictional (ETJ) to the extent allowable under State and local law. Applicable
Comments
Additional
Comments:
NCS000248_Greensboro 2022 MS4 Self -Audit Page 13 of 27

Post -Construction Site Runoff Controls
Staff Interviewed: Virginia Spillman, Assistant Director, Water Resources
(Name, Title, Role) Johnnie Hill, Engineering Supervisor
Ray Johnson, Stormwater Operations Supervisor
Terry April, Watershed Plan Reviewer
Elea Reyna Ocampo, Water Quality Specialist
Blake Strumbel, Water Quality Analyst
Program Implementation (check all that apply):
Z The permittee implements the components of this minimum measure.
❑ The permittee relies upon another entity to implement the components of this minimum measure: name of entity
® The permittee implements the following Qualifying Alternative Program(s), which meet NPDES MS4 post -construction
requirements in the areas where they are implemented and in compliance with the specific program requirements as provided in
15A NCAC and noted below:
❑ Water Supply Watershed I (WS-1) —15A NCAC 213.0212 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
❑ Water Supply Watershed II (WS-11) —15A NCAC 26 .0214 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
® Water Supply Watershed III (WS-III) —15A NCAC 213.0215 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624)
® Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 (Eff. March 1, 2019 15A NCAC 026 .0620 - .0624)
❑ Freshwater High Quality Waters (HQW) —15A NCAC 2H .1006
❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007
❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 213.0235
❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy — 15A NCAC 2B .0258
® Randleman Lake Water Supply Watershed Nutrient Management Strategy— 15A NCAC 213.0251
❑ Universal Stormwater Management Program —15A NCAC 2H .1020
Regulatory Authority:
The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program
requirements (check all that apply):
❑ DEQ model ordinance
® MS4 designed post -construction practices that meet or exceed 15A NCAC 02H .1000
❑ DEQ approved comprehensive watershed plan
❑ DEQ approved Qualifying Alternative Program listed above
Program Requirement Status Supporting
Doc No.
O2H .1017 The permittee implements the Qualifying Alternative Program requirements
Qualifying checked above in accordance with the applicable 15A NCAC rules. Yes 01
Alternative
Program(s) The permittee cumulatively implements the Qualifying Alternative Program Yes 01(see 30-
requirements checked above throughout the entire MS4 permitted area. 12-7.1B)
NCS000248—Greensboro 2022 MS4 Self -Audit Page 14 of 27

Post -Construction Site Runoff Controls
If response is no or partial, the permittee implements MS4 post-
construction requirements in accordance with 15A NCAC 02H .1017(3) —
Not
Applicable
---
(14) throughout the balance of the MS4 permitted area.
Comments
Storrnwater Mana."Ternent Plan (SWM) required for all new clevelopment/redevelopment in corporate limits and ETJ of City. NPIDES
MS4 Phase I requirements are implemented in WSWP areas, Inaddition, SWMs for projects w4hin Water Supply Watershed
Protection (WSWP) areas ni ust meet add itionai requi rernents. To enforce WSWP regulations, City requires that before any new
development/re-development activities begin on a site located within WSWP, a Watershed Development Plan (WDP) Must be
submitted to City for approval. WDP,vd-ien required, should be incorporated into SWM. Please see Ordinance Section 30-12-7.
The Ordinance can be accessed online
Permit Citation Program Requirement Status Supporting
I Doc No.
I.D. Post -Construction Site Runoff Control requirements are applied in the Permittee's
Implementation in Extra Territorial Jurisdictional (ETJ) to the extent allowable under State and local Not ---
ETJ law. Applicable
Comments
Stormwater Management Plan (SWM) required for all new development/redevelopment in corporate limits and ETJ of City.
II.F.2.a. The permittee maintained an ordinance or similar regulatory mechanism that 01 (see 30-
Legal Authority authorizes a program to address stormwater runoff from new development and Yes 12-7.213);
redevelopment to the extent allowable under State law. 12-3.4)
Comments
Provisions in Ordinance Section 30-12-3.4 address the applicability ofthe Stormwater Program
Stormwater Control The permittee maintains strategies that include a combination of structural and/or Yes 12-3.6); 26
non-structural SCMs in concurrence with the legal authorities above (II.F.2.a.). (see 30-13-
The permittee provides a mechanism to require long-term operation and
12-
maintenance of structural SCMs.
26 (see 30-
The permittee requires annual inspection reports of permitted structural SCMs
25 (see 30-
performed by a qualified professional.
28,29
The permittee implements SCM requirements that are at least as stringent as the
Yes
25
Comments
Inspection of SCMs is a requirement that is implemented through multiple avenues including City ordinances (see specific
references above), specification of inspection and maintenance requirements on approved design plans (see example in supporting
documents), and through the City's Private SCM Inspection SOP. The Stormwater Management Division performs inspections for
public and privately owned SCMs within the City limits. Inspections are tracked using RAIN database (see Private SCM Inspection
SOP for RAIN screenshots). The supporting documents include several examples of SCM inspection reports performed by qualified
NCS0OUZ48_Greensboru2OZZyW54Self-Audit Page 1Sof27

Post -Construction Site Runoff Controls
I I. F.2.c.
Deed Restrictions
The permittee provides mechanisms such as recorded deed restrictions, plats,
and Protective
and/or protective covenants so that development activities maintain the project
Yes
26 (see 30-
13-5.4); 30
Covenants
consistent with approved plans.
Comments
The plat recordation requirements associated with SCMs is detailed in Ordinance Section 30-13-5.4. The recorded plat includes
applicable items such as the owner's maintenance statement, engineer's certification of quality control, access and maintenance
easements, and built upon area limits. Plat references the Operation and Maintenance Agreement, O&M schedule./plan and
protective. covenant,
11.F.2.d.
Operation and
Maintenance Plans
Comments
The developer provides the permittee with an operation and maintenance plan for
the stormwater system, indicating the operation and maintenance actions that
shall be taken, specific quantitative criteria used for determining when those
actions shall be taken, and who is responsible for those actions.
Yes
The plans clearly indicate the steps that shall be taken and who shall be responsible
Yes
for restoring a stormwater system to design specifications if a failure occurs.
The plans include a legally enforceable acknowledgment by the responsible party. I Yes
Development is maintained consistent with the requirements in the approved
Yes
plans.
Modifications to those plans must be / are approved by the Permittee.
Yes
30; 26 (see
30-13-5.1,
30-13-5.2,
30-13-5.3);
25 (see 30-
12-3.7C2,
30-12-3.7D,
and 30-12-
3.6D; 27
26 (see 30-
13-5.5); 25
(see 30-12-
3.6D, 30-
12-3.7C2,
and 30-12-
3.7D); 27
26 (see Ord
30-13-5.4
and 30-13-
5.3 ); 27, 30
26 (see 30-
13-5.2); 25
(see
30-12-3.7E
and 30-12-
3.6)
25 (see
30-12-3.6
and 30-12-
3.7C3)
Operation and maintenance requirements are detailed in multiple sections of the Ordinance as noted above. The Ordinance
requires that SCM be designed per the State's SCM Manual which includes an 0&M schedule. The 0&M schedule specific to the
SCM is included on the approved Technical Review Committee (TRC) plan. Additionally, the 0&M requirements are documented on
the final plat and recorded at the Register of Deeds. Further Ordinance sections as noted above include requirements to submit
plans for approval for any new development, which includes changes or additions to previously approved plans. This process is led
by the TRC Committee of which Water Resources is a member.
II.F.2.e.
Educational
Materials and The permittee provided educational materials and training for developers. Yes 31
Training
NCS000248_Greensboro 2022 MS4 Self -Audit Page 16 of 27

I Post -Construction Site Runoff Controls
Training is provided directly to engineers through ongoing plan review feedback. The Stormwater Management Division website
includes a tab for "Developers and Contractors" (vjv,,v.,.1are4i:s o o-€�c.;ovJd ;tr+�nisJE°3� per-iesot,rc s/!et v o,� r� ar,d-
contractors) that includes links to regulations (i.e., Ordinance), standards (i.e., manuals and specifications) and outside resources
(i.e., precipitation data, watershed maps, etc.). The City also regularly participates in local developer organization meetings
(including TREBIC) and provides presentations, training, and program updates. )�4vt ai'r .n :,r u �.� in erew EFe :, reerren , GG;`vl
schedule:/plan are put on the plans to be more visible and usable.
II.F.4. The permittee applies additional requirements to projects draining to SA waters by
Sensitive Receiving requiring SCMs that result in the highest degree of fecal coliform die -off and Not
Waters controls sources of fecal coliform to the maximum extent practicable in accordance Applicable with 15A NCAC 02H .1017(9)
The permittee applies additional requirements to projects draining to Trout waters
Not
by requiring SCMs that avoid a sustained increase in receiving water temperature -
Applicable
in accordance with 15A NCAC 02H .1017(9)
The permittee implements an approved locally implemented Nutrient
Management Strategy that addresses post -construction runoff and the provisions Yes 01(see 30
12-7.2); 32
of that Strategy fulfill the MS4 post -construction requirement.
Comments
The Ordinance requires projects to meet the requirements of the Stormwater Management Manual which references the State
SCM Manual and includes appropriate strategies for nutrient removal.
ILF.S. 25 (see 30-
The permittee meets the requirements of the post -construction program for
Permittee Projects Yes 12-3.4 and
construction projects that are performed by, or under contract for, the permittee. 30-12-3.6)
Comments
As noted in Ordinance Section 30-12-3.4, regulations are applied to all projects in City limits and City owned projects are not
exempted in 30-12-3.46. All City capital project go through construction and/or Technical Review Committee (TRC) plan review
processes conducted by City. 'I'll a,- _ .rv: e .,C.r*f F ­ r:< rn tiers.
II.F.6. 25 (see 30-
SCM Design Volume The permittee requires that the water quality design volume of SCMs account for Yes 12-3.6 and
the runoff at build out from all surfaces draining to the system. 30-12-
33A), 32
Comments
The Ordinance requires all projects to meet the requirements of the Stormwater Management Manual which references the State
SCM Manual and includes requirements for design volume calculations.
II.F.7. The permittee fulfills the post -construction minimum control measure
Linear requirements for non-NCDOT linear transportation projects if they are designed,
Transportation constructed, and conveyed as set forth in 15A NCAC 02H .1001(1)(c):
Projects
(i) Constructed to NCDOT standards and in accordance with the NCDOT BMP
Toolbox;
(ii) Conveyed to NCDOT or other public entity and regulated in accordance with
that entity's NPDES MS4 Permit; and
(iii) The project is not part of a common plan of development.
Yes
25 (see 30-
12-3.4A2)
NCS000248_Greensboro 2022 MS4 Self -Audit Page 17 of 27

Post -Construction Site Runoff Controls
Comments
Linear transportation projects (i.e., sidewalks, roadways, and road widening) are reviewed and stormwater impacts are required to
meet the City's stormwater regulations to the maximum extent practicable. If it is determined that the projects cannot meet the
City's more stringent regulations, the project must still comply with minimum federal and state regulations (i.e., NCDOT standards
and BMP Toolbox).
Additional
Comments: in; o : ANN. .-,;U t : ,', gi.oklp Ll:�Vl £ .E e ; .'lve
(2) groups that are part of the Technical Review i:onnmit:tee (TRC) approve. Apphcatio€ffilan then goes to
construction group. Construction group maintains regular communication with builder/developer and
conducts regular inspections. After construction complete and construction group approves as.-IDLIAS, project
goes to ;.vater quality group (where post construcOen inspections, etc, occur)
NCS000248_Greensboro 2022 MS4 Self -Audit Page 18 of 27

Pollution Prevention and Good Housekeeping for Municipal Operations
Staff Interviewed:
Elea Reyna Ocampo, Water Quality Specialist
(Name, Title, Role)
Laine Roberts, Public Education Coordinator
Blake Strumbel, Water Quality Analyst
Ray Johnson, Stormwater Operations Supervisor
Permit Citation
Program Requirement
Status
supporting
Doe No.
ILG.2,a.
The permittee maintained an inventory of municipal facilities and operations
Municipal Facility
owned and operated by the permittee that have been determined by the
Yes 33
Inventory
permittee to have significant potential or generating polluted stormwater runoff.
The permittee maintained an inventory of municipally -owned structural SCMs. Yes 34
Comments
The City's inventory of municipal facilities, which also assigns a risk rank based on the potential for generating polluted runoff, is
provided in the City's Pollution Prevention and Good Housekeeping SOP and is reviewed at least once every permit cycle and
updated as needed. In addition, the City's inventory of municipally -owned SCMs is included in the City -Owned SCM SOP and is
reviewed at least once every permit cycle and updated as needed.
IL.G.2.b.
The permittee implemented an inspection and maintenance program for facilities
Inspection and
and operations owned and operated by the permittee for potential sources of
Yes
33, 34, 35
Maintenance for
polluted runoff, including stormwater controls and conveyance systems.
Municipal Facilities
The inspection program evaluates pollutant sources, documents deficiencies, plans
corrective actions, implements appropriate controls, and documents the
Yes
33
accomplishment of corrective actions.
The maintenance program includes maintenance activities and procedures aimed
at preventing or reducing pollutants generated from municipal facilities and
Yes
33
operations.
Comments
The City's Pollution Prevention and Good Housekeeping SOP describes the City's inspection and maintenance program for City -
owned facilities. The City -Owned SCM SOP describes inspection and maintenance protocols for municipally -owned SCMs. Inspection
and maintenance of municipal stormwater conveyance systems is described in the City's MS4 Operation and Maintenance Plan.
The City's maintenance program for municipal facilities and operations as documented in the Pollution Prevention and Good
Housekeeping SOP provides clear procedures for inspections, follow-up, corrective actions, and documentation to prevent or
reduce pollution, including a sample inspection form, letter template, sample inspection report, and contact/follow-up log.
II.G.2.c.
The permittee maintained and implemented Site Pollution Prevention Plans for
Site Pollution
municipal facilities owned and operated by the permittee that have been
Prevention Plans for
determined by the permittee to have significant potential for generating polluted
Yes
36,37
Municipal Facilities
stormwater runoff that has the goal of preventing or reducing pollutant runoff.
Comments
The City maintains and implements Site Pollution Prevention Plans for the City of Greensboro Transfer Station and the City of
Greensboro Parks and Recreation Maintenance Facility as required.
NCS000248_Greensboro 2022 MS4 Self -Audit Page 19 of 27

Pollution Prevention and Good Housekeeping for Municipal Operations
II.G.2.d.
The permittee maintained spill response procedures for municipal facilities and
Spill Response
operations owned and operated by the permittee that have been determined by
Procedures for
the permittee to have significant potential for generating polluted stormwater
Yes
36,37
Municipal Facilities
runoff.
Comments
The Site Pollution Prevention Plans for the City of Greensboro Transfer Station and the City of Greensboro Parks and Recreation
Maintenance Facility clearly document spill response procedures for those facilities as required.
II.G.2.e.
The permittee described measures that prevent or minimize contamination of the
Vehicle and
stormwater runoff from all areas used for vehicle and equipment cleaning,
Yes
38
Equipment Cleaning
including fire stations that have more than three fire trucks and ambulances.
Areas
The permittee performs all cleaning operations indoors, covers the cleaning
operations, ensures wash water drains to the sanitary sewer system, collects wash
Yes
38
water and stormwater run-on from the cleaning areas and provides treatment or
recycling, or other equivalent measures
The permittee, if sanitary sewer is not available to the facility and cleaning
operations take place outdoors, ensures wash water drains to an SCM for
treatment, or else the cleaning operations take place on or drain directly to grassed
Yes
38
or graveled areas to prevent point source discharges of wash water into the storm
drains or surface waters.
The permittee, where cleaning operations cannot be performed as described above
and when operations are performed in the vicinity of a storm drainage collection
system, covers the drain(s) with a portable drain cover during cleaning activities,
Yes
38
and any excess standing water is removed and properly handled prior to removing
the drain cover.
The permittee facilities that have three or fewer fire trucks and ambulances
attempt to comply with the above requirements; however, those that cannot
comply with these requirements due to existing limitations incorporate structural
Yes
38
measures during facility renovation to the extent practicable.
Comments
The City's Municipal Vehicle/Equipment Washing SOP describes procedures for preventing or minimizing polluted runoff from
municipal vehicle and equipment cleaning areas and includes appropriate procedures for indoor and outdoor washing. The
vehicle/equipment washing SOP also references other relevant City documents including the City's MS4 Operation and
Maintenance Plan, PP/GH training video, Hugh Medford SWPPP, Greensboro Transit Agency SWPPP, and White Street Landfill
SWPPP.
ILG.2,f,
Streets, Roads and The permittee implements BMPs to reduce polluted stormwater runoff from
Public Parking Lot municipally -owned streets, roads, and public parking lots within the corporate Yes 35
Maintenance limits.
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 20 of 27

Pollution Prevention and Good Housekeeping for Municipal Operations
Comments
The City's MS4 Operation and Maintenance Plan describes procedures and references relevant SOP documents for reducing or
minimizing polluted stormwater runoff from municipally -owned streets, roads, and parking lots.
II.G.2.e. The permittee maintained and implemented an inspection and maintenance
Inspection and program for structural stormwater control measures (SCMs) owned and operated Yes 34,35
Maintenance for by the municipality.
Municipal SCMs and
MS4 The permittee maintained and implemented an inspection and maintenance
program for the municipal storm sewer system (including catch basins, the Yes 35
conveyance system and SCMs).
Comments
The City -Owned SCM SOP describes the City's inspection and maintenance program for municipally -owned SCMs; this is also
referenced in the City's MS4 Operation and Maintenance Plan. The City's MS4 Operation and Maintenance Plan describes the City's
inspection and maintenance program for the MS4 and references other relevant SOP documents.
II.G.2.h.
The permittee maintained a training plan that indicates when, how often, and who
Staff Training
is required to be trained and what they are to be trained on.
Yes
39, 40, 41
The permittee implemented a training plan that indicates when, how often, and
Yes 39, 40, 41
who is required to be trained and what they are to be trained on.
Comments
The City's Pollution Prevention and Good Housekeeping Education and Outreach SOP describes the City's training plan including
who, when, and how often. Training is provided via a number of methods including online training courses, new employee training
programs, and site -specific training.
The City maintains a Good Housekeeping Program Training Tracking spreadsheet to record number of staff trained on Pollution
Prevention and Good Housekeeping each year by department. In addition, the List of Supporting Documents includes example
summary analytics (i.e., number of video views) for internal good housekeeping and pollution prevention training.
Additional
Comments:
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 21 of 27

Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Staff Interviewed:
Blake Strumbel, Water Quality Analyst
(Name, Title, Role)
Permit Citation
Program Requirement
Status
supporting
Doc No.
II.H.2.a.
The permittee maintained an inventory of permitted hazardous waste treatment,
Industrial Facility
disposal, and recovery facilities, industrial facilities that are subject to Section 313
Yes
42,43
Inventory
of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA).
The permittee maintained an inventory of industrial facilities identified with an
industrial activity (as defined in 40 CFR 122.26) permitted to discharge storm water
Yes
42,43
to the permittee's MS4.
Comments Screenshots of the database can be found in the SOP
The City maintains a comprehensive Industrial Facility Inventory which classifies facilities by type (e.g., NPDES permitted, TRI, No
Exposure, etc.), includes inspection dates and permit numbers, and also identifies facilities which are considered "high risk."
II.H.2.b.
The permittee identified priorities and inspection procedures. At a minimum,
Inspection Program
priority facilities include those identified above (subsection II.H.2.a).
Yes
43
Comments
The City maintains a Stormwater Industrial Facilities Inspection Program SOP which describes priorities and inspection procedures.
The SOP describes inspection methods, frequency, staff training, step-by-step procedures based on facility type, documentation
procedures, enforcement, and records management.
II.H.2.c.
The permittee evaluated control measures implemented at permitted hazardous
Industrial Facility
waste treatment, disposal, and recovery facilities, industrial facilities that are
Evaluation
subject to Section 313 of Title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA).
Yes
43
For the purpose of this permit the Permittee is authorized to inspect the permitted
hazardous waste treatment disposal, and recovery facilities as an authorized representative
of the Director.
The permittee evaluated control measures implemented at industrial facilities
identified with an industrial activity permitted to discharge storm water to the
permittee's MS4.
Yes
43
For the purposes of this permit industrial activities shall mean all permitted industrial
activities as defined in 40 CFR 122.26.
For permitted industrial facilities, the permittee established procedures for
Yes
43
reporting deficiencies and non-compliance to the permitting agency.
Where compliance with an existing industrial stormwater permit does not result
in adequate control of pollutants to the MS4, the permittee recommends and
Yes
44
documents the need for permit modifications or additions to the permit issuing
authority.
The permittee evaluated control measures implemented at industrial facilities
Yes
43,18
identified as an illicit discharge under the IDDE Program.
NCS000248_Greensboro 2022 MS4 Self -Audit Page 22 of 27

Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems
Comments
The City's Stormwater Industrial Facilities Inspection Program SOP includes established procedures to address these permit
requirements. The SOP includes an example inspection form, letter templates (multiple examples depending on severity of
deficiencies), and screenshots describing data entry into the City's database for tracking and follow-up. The Industrial Facilities SOP
also references a number of other relevant guides and SOPs.
An example compliance letter and correspondence with DEMLR is provided to demonstrate the City's actions when compliance
with an existing industrial stormwater permit does not result in adequate control of pollutants to the MS4.
Additional i
Comments:
Water Quality Assessment and Monitoring
Staff Interviewed:
Debbie Shoffner, Water Quality Analyst
(Name, Title, Role)
Blake Strumbel, Water Quality Analyst
Permit Citation
Program Requirement Status supporting
It
Dot No.
11.1.2.a.
Water Quality
The permittee maintained a Water Quality Assessment and Monitoring Plan. Yes 45
Assessment and
Monitoring Plan
The Water Quality Assessment and Monitoring Plan includes a schedule for
Yes 45
implementing the proposed assessment and monitoring activities.
Comments
The City maintains and implements a Water Quality Assessment and Monitoring Plan which is reviewed annually and updated as
needed. The Plan describes monitoring methods, types, parameters, locations, and frequency, as well as analytical methods, quality
assurance and recordkeeping procedures, and data evaluation methods.
11.1.2.b.
The permittee maintained and implemented the Water Quality Assessment and
Water Quality
Monitoring Plan submitted to DEMLR.
Yes
45,03
Monitoring
The Division waived the requirement to maintain a Water Quality Assessment and
Not
Monitoring Plan.
Applicable
Comments
The City maintains and implements a Water Quality Assessment and Monitoring Plan which is reviewed annually and updated as
needed.
Additional
In addition to the Water Quality Assessment and Monitoring Plan, the City maintains an SOP for its fixed
Comments:
interval sampling (FIS) program (supporting document 46). Water quality data are used by the City to develop
a WQI score for the City's streams. A summary of the City's WQI database (supporting document 47) including
screenshots is provided in the Supporting documents.
NCS000248_Greensboro 2022 MS4 Self -Audit Page 23 of 27

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Site Name:
Date and Time of Site Visit:
De-.vonsh're ?ownhomes
6/7/2022
Site Address:
SCM Type:
4307 Lake jeranette ;load
Eloretention cells
Greensboro
Most Recent MS4 Inspection (include Date and Entity):
:'}/7T 2021.
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (Include Date):
Blake Stru nbe!
Site Visit:
Name(s) and Title(s) of Site Representative(s) Present During the
Name
Title
David Phlegar
Stormwater Division Manager
Virginia Spillman
Assistant Director, Water Resources
Ray Johnson
Stormwater {operations Supervisor
Debbie Slictfner
Water QUality Analyst
Elea Reyna-Ocampo
Water G<uality Specialist
Toni Branson
WaterQuality Supervisor
Water QUality Analyst
Make Strumbei
Observations
Site Documentation
Does the site have an operation and maintenance plan?
ye.s
Does the site have records of annual inspections? Are they performed by a qualified individual?
Yes, Yes
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
NC State University/NC Cooperative extension'—Ce, ified
Storn,waller SCM insrection & Maintenance Professional (re netved
even y three years)
---0n-the-j,.,L training, as well as new employee training
Did the MS4 inspector appear knowledgeable about MS4 requirements for post -construction site runoff controls?
Yes
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 24 of 27

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, 0&M
requirements, etc.)?
Yes
Inspection Procedures
Does the M54 inspector's process include the use of a checklist or other standardized form? What format?
Yes. Refer to SOP for privately owned SCMs.
Does the MS4 inspector's process include taking photos?
Yes.
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes, rep;iewcd immediately after inspection
Does the M54 inspector's process include walking the entire site and inspecting all points of discharge?
Yes.
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes,
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
NA
If compliance issues were identified, what timeline for correction/follow-up was provided?
NA
Notes/Comments/Recommendations
Inspectors can use portable computers, cell phones with hot spots, or paper to record inspection results.
NCS000248_Greensboro 2022 MS4 Self -Audit Page 25 of 27

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2
Site Name:
Date and Time of Site Visit:
Bee Safe (New SCM need to get. contact)
6/7/2022
Site Address:
SCM Type:
3007 Martinsville Road
Bloretention cell
Most Recent MS4 Inspection (include Date and Entity):
-1/10/2020
Name of MS4 Inspector(s) evaluated:
Most Recent MS4 Enforcement Activity (include Date):
Name(s) and Title(s) of Site Representative(s) Present During the Site Visit:
Name
Title
Assistant Director, Water Resources
Virginia SpillMan
Stonwvater Operations Superv;sor
Ray Johnson
Debb'e Shoffrier
Water Quality Analyst
Elea Reyna-Ocam.po
Water Quality Specialist
Tcni Branson
Water Quality Superviso;
Blake Strunibel
Water Quality Analyst
Observations
Site Documentation
Does the site have an operation and maintenance plan?
Y es
Does the site have records of annual inspections? Are they performed by a qualified individual?
yes, Yes
Inspector Training/Knowledge
What type of stormwater training does the MS4 inspector receive? How often?
-NC State University/NC Cooperative Extension— Certified Storm.wate., SCM Irirpection & Nlia4itenance Professional (rene�.-(:d
every three years)
--On-the-job training, as,�,Yell as new employee training
Did the MS4 inspector appear knowledgeable about MS4
requirements for post -construction site runoff controls?
Ves
NCSUOO248_GreensboroZUZ2K4S4Self-Audit
Page 26 of 27

Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2
Did the MS4 inspector appear knowledgeable about post -construction BMPs (general purpose/function, components, O&M
requirements, etc.)?
Yes
Inspection Procedures
Does the MS4 inspector's process include the use of a checklist or other standardized form? What format?
Yes
Does the MS4 inspector's process include taking photos?
Yes
Does the MS4 inspector's process include reviewing the site's operation and maintenance plan and records of annual inspections?
Yes, reviewed immediately after inspection
Does the MS4 inspector's process include walking the entire site and inspecting all points of discharge?
Yes
Did the MS4 inspector miss any obvious operation and maintenance deficiencies? If so, explain:
No. Inspector noted gravel in inlet structure will inquire of Permittee about this.
Does the MS4 inspector's process include presenting the inspection findings to the site contact in writing?
Yes. Letter is sent.
Compliance/Enforcement
What, if any, enforcement actions (verbal warnings, NOV, etc.) did the inspection result in?
NA
If compliance issues were identified, what timeline for correction/follow-up was provided?
NA
Notes/Comments/Recommendations
Inspectors can use portable computers, cell phones with hot spots, or paper to record inspection results.
NCS000248_Greensboro 2022 MS4 Self -Audit
Page 27 of 27