HomeMy WebLinkAboutNCS000246_SWMP_20220920City of Fayetteville
NPDES Permit Program
Stormwater Quality
Management Program
Plan
FAY E T T E V I L 6
STORMWATER
Permit Number NCS000246
July 2021
Table of Contents
Section1: Introduction...........................................................................................................I
Section 2: Background Information.....................................................................................3
2.1 Population Served...............................................................................................................3
2.2 Growth Rate........................................................................................................................3
2.3 Jurisdictional and MS4 Service Areas................................................................................3
2.4 MS4 Conveyance System...................................................................................................5
2.5 Land Use Composition Estimates.......................................................................................5
2.6 Estimate Methodology........................................................................................................5
Section 3: Public Education and Outreach..........................................................................7
3.1
BMP Summary Table..........................................................................................................7
3.2
Target Pollutants and Sources.............................................................................................7
3.3
Target Audiences................................................................................................................8
3.4
Informational Website........................................................................................................9
3.5
Public Education Materials.................................................................................................9
3.6
Hotline / Help Line.............................................................................................................9
3.7
Public Education and Outreach Program..........................................................................10
3.7.1 Newspaper Articles / Inserts.....................................................................................10
3.7.2 Utility Bill Inserts......................................................................................................10
3.7.3 Community Events....................................................................................................10
3.7.4 Public Educational Presentations..............................................................................10
3.7.5 Classroom Outreach..................................................................................................10
3.7.6 Promotional Items.....................................................................................................10
3.8
Measurable Goals..............................................................................................................11
3.9
Program Assessment.........................................................................................................14
Section 4: Public Involvement and Participation..............................................................14
4.1
BMP Summary Table........................................................................................................14
4.2
Volunteer Involvement Program.......................................................................................14
4.3
Public Involvement Mechanism.......................................................................................15
4.4
Hotline / Help Line...........................................................................................................15
4.5
Public Review and Comment............................................................................................15
4.6
Public Notice.....................................................................................................................16
4.7
Measurable Goals..............................................................................................................16
4.8
Program Assessment.........................................................................................................18
Section 5: Illicit Discharge Detection and Elimination(IDDE)........................................18
5.1 BMP Summary Table........................................................................................................18
5.2 Ordinance Administration and Enforcement....................................................................19
5.3 Stormwater System Inventory...........................................................................................19
The City of Fayetteville page -i-
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
5.4
Inspection / Detection Program.........................................................................................20
5.5
Employee Training............................................................................................................21
5.6
Public Education and Outreach.........................................................................................22
5.7
Public Reporting Mechanism............................................................................................22
5.8
Measurable Goals..............................................................................................................22
5.9
Program Assessment.........................................................................................................25
Section 6: Construction Site Runoff Controls....................................................................25
6.1 Locally Delegated Program...............................................................................................25
Section 7: Post -Construction Site Runoff Controls...........................................................25
7.1 BMP Summary Table........................................................................................................26
7.2 Post -Construction Stormwater Management Program......................................................27
7.3 Post -Construction BMP Strategies....................................................................................27
7.4 Deed Restrictions and Protective Covenants....................................................................28
7.5 Operation and Maintenance Plan......................................................................................28
7.6 Setbacks for Built -Upon Areas.........................................................................................28
7.7 Education and Training Program......................................................................................29
7.8 Measurable Goals..............................................................................................................29
7.9 Program Assessment.........................................................................................................33
Section 8: Pollution Prevention and Good Housekeeping for Municipal Operations .... 33
8.1
BMP Summary Table........................................................................................................33
8.2
Operation and Maintenance Program...............................................................................35
8.3
Facility Site Pollution Prevention Plans............................................................................36
8.4
Facility Inventory and Site Inspections.............................................................................36
8.5
Municipal Spill Response Procedures..............................................................................37
8.6
Vehicle and Equipment Cleaning Operations...................................................................38
8.7
BMP Selection for Streets, Roads, and Public Parking Lots Maintenance .......................38
8.8
BMP Implementation for Streets, Roads, and Public Parking Lots Maintenance ............39
8.9
Operation and Maintenance for Municipally Owned or Maintained Structural Stormwater
BMPs and Storm Sewer System.......................................................................................41
8.10
Employee / Staff Training................................................................................................43
8.11
Measurable Goals.............................................................................................................43
8.12
Program Assessment........................................................................................................49
Section 9: Industrial Facilities Evaluation and Monitoring.............................................49
9.1 BMP Summary Table........................................................................................................49
9.2 Industrial Facility Inventory..............................................................................................50
9.3 Industrial Facilities Inspection Program...........................................................................50
9.4 Evaluation Measures.........................................................................................................51
9.5 Measurable Goals..............................................................................................................52
9.6 Program Assessment.........................................................................................................55
The City of Fayetteville page -ii-
NPDES Permit No. NCS000246 - Stormwater Plan July 2021
Section 10: Water Quality Assessment and Monitoring......................................................55
10.1 BMP Summary Table.......................................................................................................55
10.2 Water Quality Assessment and Monitoring Plan.............................................................55
10.3 Water Quality Monitoring Implementation......................................................................59
10.4 Measurable Goals.............................................................................................................59
10.5 Program Assessment........................................................................................................61
Section 11: Total Maximum Daily Loads(TMDLs).............................................................61
11.1 Impaired Streams Program...............................................................................................55
List of Tables
Table 2-1 Population and Growth Rate for the City of Fayetteville.........................................3
Table 2-2 Percentage of Land Uses in the City of Fayetteville................................................5
Table 3-1 BMP Summary Table for the Public Education and Outreach Program..................7
Table 3-2 Targeted Pollution Sources for the Public Education and Outreach Program .........7
Table 3-3 BMP Measurable Goals for the Public Education and Outreach Program ............12
Table 4-1 BMP Summary Table for the Public Involvement and Participation Program ...... 14
Table 4-2 BMP Measurable Goals for the Public Involvement and Participation Program ..17
Table 5-1 BMP Summary for the Illicit Discharge Detection and Elimination Program ....... 18
Table 5-2 BMP Measurable Goals for the Illicit Discharge Detection and Elimination
Program..................................................................................................................23
Table 7-1 BMP Summary Table for the Post -Construction Site Runoff Controls Program ..26
Table 7-2 BMP Measurable Goals for the Post -Construction Site Runoff Controls
Program.................................................................................................................. 30
Table 8-1 BMP Summary Table for Pollution Prevention and Good Housekeeping for
Municipal Operations Program..............................................................................33
Table 8-2 Municipal Sites included in the Pollution Prevention and Good Housekeeping for
Municipal Operations Program..............................................................................36
Table 8-3 BMP Measurable Goals for the Pollution Prevention and Good Housekeeping for
Municipal Operations Program..............................................................................44
Table 9-1 BMP Summary Table for the Industrial Facilities Evaluation and Monitoring
Program..................................................................................................................49
Table 9-2 BMP Measurable Goals for the Industrial Facilities Evaluation and Monitoring
Program..................................................................................................................53
Table 10-1 BMP Summary Table for the Water Quality Assessment and Monitoring
Program..................................................................................................................55
Table 10-2 Water Quality Monitoring Parameters...................................................................56
Table 10-3 Description of City of Fayetteville Water Quality Monitoring Sites .....................57
Table 10-4 BMP Measurable Goals for the Water Quality Assessment and Monitoring
Program..................................................................................................................60
List of Figures
Figure 2-1 Fayetteville Jurisdiction and Drainage Basins.........................................................4
Figure 2-2 Fayetteville Land Uses.............................................................................................6
Figure 10-1 Fayetteville Water Quality Monitoring Sites.........................................................58
The City of Fayetteville page -iii-
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Section 1: Introduction
On December 30, 1994, the City of Fayetteville began operating under Municipal Separate Storm
Sewer System (MS4) National Pollutant Discharge Elimination System (NPDES) Permit Number
NCS000246 as issued by the North Carolina Department of Environmental Quality_(NCDEQ).
This permit is currently renewed for a third term effective October 10, 2018 through October 9,
2023.
This document provides the Stormwater Quality Management Program, herein referred to as the
Stormwater Plan, required by Part I, paragraphs 1, 7, and 11 of the NPDES permit. The overall
objective of the Stormwater Plan is to protect receiving stream water quality by reducing the
discharge of pollutants from the City's MS4 to the maximum extent practicable through the
implementation of the permit programs and Stormwater Plan elements described within this plan.
The Fayetteville Stormwater Division is the primary agency responsible for managing the City's
NPDES stormwater permit, its MS4, and the Stormwater Plan.
Included in this Stormwater Plan are the individual best management practices (BMPs) that will
be used to fulfill program requirements along with the corresponding frequency of each BMP,
measurable program goals, implementation schedule, and funding sources. Staff of the Fayetteville
Stormwater Division, under the direction of the City's Stormwater Manager, is responsible for the
fulfillment of most of the activities discussed in this Stormwater Plan. The City's Street
Maintenance Division and the Environmental Services Department have responsibility for
maintenance of portions of the MS4, in coordination with the Fayetteville Stormwater Division.
The one exception is the Construction Site Runoff Control program where the local office of
NCDEQ is the primary responsible agency.
The development of this Stormwater Plan will be completed within one year and implementation
completed within five years from the effective date of the currently issued permit renewal. The
City's Stormwater Plan includes the following core Phase I permit programs:
1) Public Education and Outreach — This program provides the general public as well as
business and industry with valuable information on general water quality, pollution
prevention, and reporting problems, as well as specialized information on various activities
that have the potential to cause pollution and harm water quality. This information is
provided using a wide range of media including print, radio, and television.
2) Public Involvement and Participation — This program provides the general public as well
as business and industry the opportunity to participate in various programs within the City's
Stormwater Plan. Fayetteville maintains a Stormwater Advisory Board (SWAB), which is
an appointed citizen panel to review and comment on the City's stormwater programs. In
addition, public volunteer opportunities are available with City programs such as Storm
Drain Marking, Adopt -A -Site, Adopt -A -Street, Keep Fayetteville Beautiful, etc.
3) Illicit Discharge Detection and Elimination — This program is designed to protect water
quality by detecting and eliminating pollution sources from illicit connections such as
The City of Fayetteville page - 1 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
improper sewage or wastewater connections; illegal discharges such as chemical, paint, or
oil dumping; and spills such as sewer overflows or vehicle accidents involving discharges
of fuel, oil, and other chemicals. As part of this program, the City enforces the "City of
Fayetteville — Illicit Connections and Improper Disposal Ordinance", which prohibits the
discharge of pollutants to the storm drain system and streams. The City relies on reports
from the public, various monitoring programs, and a wide range of other activities to assist
in identifying and eliminating these sources of pollution.
4) Construction Site Runoff Control — This program has been and is currently provided by the
local office of the NCDEQ Land Quality Section. Even though the City's existing
Construction Site Runoff program is handled by the local office of the NCDEQ Land
Quality Section, the City continues to aggressively inspect construction sites that are
brought to their attention through complaints or other sources. These efforts are fully
coordinated with NCDEQ. Additionally, the City focuses on sites that are smaller than one
acre that are not permitted by NCDEQ.
5) Post -Construction Site Runoff Controls — The City has recently developed a program to
control the discharge of pollutants in stormwater runoff from new development and
redevelopment projects. As part of this program, the City enforces the "City of Fayetteville
— Stormwater Control Ordinance", which requires stormwater treatment practices for
development that meets various size and density thresholds. The program involves review
and approval of project plans as well as site inspections to ensure that treatment practices
are properly operated and maintained.
6) Pollution Prevention and Good Housekeeping for Municipal Operations — This program
focuses on ensuring that City owned and operated facilities are properly operated and
maintained to reduce stormwater pollutant discharges from these facilities. Stormwater
Pollution Prevention Plans and Spill Response Plans are prepared for applicable facilities
that conduct activities with the potential for stormwater pollutant discharges. The City
conducts annual inspections and training sessions at these facilities to ensure that
requirements are being met.
7) Industrial Facilities Evaluation and Monitoring — This program focuses on industrial
facilities that are permitted to discharge stormwater to the City's MS4 and receiving
streams. Inspections are conducted at these facilities to review site operations and materials
handling practices. In addition, the facility site permit is reviewed to ensure that permit
conditions are adhered to.
8) Water Quality Assessment and Monitoring — The City maintains a water quality monitoring
program designed to monitor major streams to determine water quality conditions and
gauge the effectiveness of various stormwater management programs. The program also
is used to assist in locating illicit discharges and connections.
9) Total Maximum Daily Loads (TMDLs) — The Fayetteville Stormwater Division has
determined that a Total Maximum Daily Load (TMDL) has not yet been developed and
approved or established by NCDEQ (as delegated through EPA) for the receiving
The City of Fayetteville page - 2 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
waters of the City of Fayetteville's MS4 NPDES stormwater discharge. Therefore, this
Permit section is currently not applicable in the City of Fayetteville.
Section 2: Background Information
2.1 Population Served
The Stormwater Plan covers the incorporated area of the City of Fayetteville, as applicable and
defined by the NPDES permit. As indicated in the City's NPDES permit, those portions of the
incorporated area that are within the boundaries of Fort Bragg are excluded from the City's NPDES
permit and are thus not intended to be part of this Stormwater Plan. Fort Bragg has a separate
NPDES permit that regulates those stormwater discharges to the Waters of the State. Data reported
in this section was obtained from the City's Planning Department. Table 2-1 provides the
population and estimated average annual growth rate for the City. The source of this population
data is the 2000 and 2010 Decennial Census information.
Table 2-1: Population and Growth Rate for the City of Fayetteville
2010 Population
2000 Population
Estimated Annual Percent Change
200,564
121,015
6.57%
As a point of clarification and as of the 2010 Census, the population of the City of Fayetteville
minus Fort Bragg was 183,367.
2.2 Growth Rate
Table 2-1 shows the population growth rate represented as an "Estimated Annual Percent Change"
for the incorporated area of the City. This growth rate was calculated using the percent change
between the 2000 and 2010 population totals from the Decennial Census, annualized by dividing
this percent change by ten.
2.3 Jurisdictional and MS4 Service Areas
The incorporated area of the City of Fayetteville is approximately 148 square miles. However,
approximately 54 square miles of the City consist of land within Fort Bragg. Since the area of Fort
Bragg is excluded from the City's NPDES permit, the jurisdictional and MS4 service area for the
City is the remaining area of approximately 94 square miles. The location of this area within
Cumberland County and corresponding drainage basins are provided in Figure 2-1. The source of
this information is the City of Fayetteville Planning Department which updates jurisdictional and
geographical boundaries as annexations occur.
The City of Fayetteville page - 3 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
N
CARVERS CREEK
FGRTBRAGG
yBEAVER CREEK-1 CR055 CREEK CAPE FEAR 1
LITTLE CROSS CREEKki
iJ
r
f
+ BONESCREEK +
LITTLE ROCKFISH CREEK 1
B EAVE R.0 R E E K-2 v
L BLOUNTSCREEK
BUCKHEAa CREEK -
BEAVER CREEK-3 r
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STEWARTS,CREEK
LITTLE ROCKFISH -CREEK 2 } ��
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ROC KFISH CREEK
w
Legend
-'Haters afth a State
Drainage Basin
City of Fayetteville
Not in C ity
Tom of Hope Mills
�Tovm of Spring Lake 12,666 24,aa0
Feet
Figure 2-1: Fayetteville Jurisdiction and Drainage Basins
The City of Fayetteville page - 4 -
NPDES Permit No. NCS000246 - Stormwater Plan July 2021
2.4 MS4 Conveyance System
The existing MS4 serving the City is composed of curbs, gutters, catch basins, culverts, pipes, and
ditches that collect and convey stormwater for discharge to receiving streams. There are an
estimated 576 miles of storm drain pipe and 22,115 catch basins and drop inlets within the City's
MS4. At a minimum, pipe systems are typically 15 inches in diameter and are designed for the ten-
year storm event. Outlet energy is commonly dissipated through the use of end -walls or flared end
sections with riprap aprons. Although the natural alignment of many receiving streams has been
altered over the past century, many of the stream banks remain mostly vegetated. Stream banks
that were armored with riprap as a result of previous stream bank stabilization efforts are currently
allowed to re -vegetate naturally.
Maintenance and improvements to the MS4 system are funded by stormwater utility fees collected
within the City. Maintenance activities include cleaning inlets of debris and sediment, maintaining
channels to reduce erosion and maximize pollution reduction capabilities, and the removal of
blockages. Improvements to the MS4 system include solving watershed scale infrastructure
problems, channel stabilization, safety improvements, stream habitat enhancement, water quality
enhancement, and resolving flooding problems associated with stormwater generated from public
streets.
2.5 Land Use Composition Estimates
The number of square miles and percentage of the MS4 service area under residential, commercial,
industrial, public / institutional, vacant, and transportation land use categories are provided in
Table 2-2. Please note that Table 2-2 also provides data for those parcels that have not yet been
assigned a land use category. These percentages are for the incorporated area of the City minus the
area of Fort Bragg. Figure 2-2 provides a map of these land use areas.
Table 2-2: Percentage of Land Uses in the Citv of Favetteville
Land Use Category
Number of Square Miles
% of Land Use
Residential
39
41 %
Commercial
6
6%
Industrial
2
2%
Public / Institutional
9
10%
Vacant
16
17%
Transportation
13
14%
Not Yet Assigned
9
10%
2.6 Estimate Methodoloiy
Land use estimates were derived from City of Fayetteville Unified Development Ordinance
(UDO) Use Classifications.
The City of Fayetteville page - 5 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Fort Bragg Part of the City of Fayetteville !z
(Existing Land Use Data Not Available for jf`;1
This Part of the City)
�? vw
q
Fayetteville City Limits
Existing Land Use
(Based on UDO Use Classification)
Residential
,Commercial
Industrial
Public and Institutional
.Vacant
Not yet assigned
<Null>
County Boundary
Figure 2-2: Fayetteville Land Uses
The City of Fayetteville page - 6 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Section 3: Public Education and Outreach
The City has developed and implemented a Public Education and Outreach Program to distribute
educational materials to the community and conduct outreach activities focused on the impacts of
stormwater discharges on water bodies. The program also provides information on the steps that
the public can take to reduce these impacts and protect water quality conditions. The following
subsections explain the BMPs implemented to meet these requirements, target audience and
pollution sources, outreach strategy, and measures of success.
3.1 BMP Summary Table
Table 3-1 provides information concerning the BMPs implemented to fulfill the Public Education
and Outreach Program requirements. Funding for the BMPs in this section is covered by local
stormwater utility fees.
Table 3-1: BMP Summary Table for the Public Education and Outreach Program
BMP
BMP Description
(a) Describe target
Describe the target pollutants and target pollutant sources the public
pollutants and target
education program is designed to address and why they are an issue.
pollutant sources
(b) Describe target
Describe the target audiences likely to have significant stormwater impacts
audiences
and why they were selected.
(c) Informational website
Promote and maintain an internet website designed to convey the
program's message.
(d) Distribute public
Distribute general stormwater educational material to appropriate target
education materials to
groups as likely to have a significant stormwater impact.
identified user groups
(e) Promote and maintain
Promote and maintain a stormwater hotline / helpline.
Hotline / Help Line
(f) Implement a Public
Promote and maintain a Public Education and Outreach program designed
Education and
to address target pollutant sources and to provide information and education
Outreach Program
to the general public as well as target audiences. For each
media event or activity, including those elements implemented locally or
through a cooperative agreement, estimate and record the extent of exposure.
3.2 Target Pollutants and Sources
Table 3-2 provides the specific pollution sources targeted for the public education program as well
as a description as to why the sources are important for protecting water quality in the City.
The City of Fayetteville page - 7 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 3-2: Targeted Pollution Sources for the Public Education and Outreach Program
Pollution Source
Issue
Lawn Care Activities
Improper application, handling, and storage of lawn care products can result
in the discharge of pollutants to the storm drain system including fertilizers
and herbicides. Improper disposal of grass clippings and leaves
can negatively impact water quality by producing increased BOD and
decreased DO levels in streams. Significant residential development
exists in the City of Fayetteville with the potential for negative water quality
impacts associated with improper lawn care activities.
Improper Disposal
Improper disposal can result in the discharge of a variety of pollutants to
the storm drainage system. This can be a problem at construction sites
where paint and other construction wastes are generated and in established
commercial and residential areas where used oil, grease, animal waste,
carpet cleaning wastes, and a variety of other pollutants can be a problem.
Poor Housekeeping
Poor housekeeping can result in the discharge of petroleum products,
miscellaneous chemicals, and other wastes to the storm drain system and
surface waters. This is usually a problem at commercial and industrial
facilities.
Erosion
Poor erosion control at construction sites results in sediment discharges to
the storm drainage system. Also, excessive volumes of stormwater runoff
cause scouring of the creek banks resulting in sedimentation of the streams.
3.3 Target Audiences
The target audiences for the public education program include those entities that will have
significant positive and / or negative impacts on water quality conditions. The audiences selected
are listed below along with an explanation as to why they are being targeted for educational
outreach.
3.3.1 General Public: Homeowners between the ages of 25 and 55 have been selected as a
primary target for the educational program due to the significant positive and negative impacts
they can have on water quality conditions. This age group represents a significant portion of the
residents of the City. This is also the age group that would potentially engage in activities such as
dumping oil and other wastes into storm drains, improperly disposing of yard wastes along creek
banks, and improperly applying pesticides and herbicides on lawns. This also represents the target
group that would be more inclined to report pollution problems observed in streams and lakes and
participate in volunteer water quality initiatives. The City receives an average of 1,000 telephone
calls annually from the general public to the City's Stormwater Hotline. One of the goals of the
outreach program is to increase public awareness regarding water quality problems / concerns and
provide information regarding proper reporting requirements for observed pollution problems.
Some citizen groups have a greater potential for impacting water quality and will be specifically
targeted as described below:
The City of Fayetteville page - 8 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Civic / Environmental Groups — Targeted to become aware of general water quality issues, report
pollution problems and participate in a variety of volunteer activities.
Neighborhood /Homeowners Associations — Targeted to become aware of general water quality issues,
report pollution problems, and participate in a variety of volunteer activities.
Hispanic Outreach — Targeted for multi -language campaigns to become aware of general water quality
issues and proper disposal activities.
Do -It -Yourself Yard Care — Targeted to reduce pesticide and fertilizer use and properly dispose of yard
waste.
School Aged Children — Targeted to become aware of general water quality issues, collaborate with
public school curriculum, and reach out to parents as well.
3.3.2 Commercial: Commercial facilities have been targeted for the educational program
due to the significant negative impacts they can have on water quality by potentially improperly
handling and disposing of wastes, making illicit connections to the storm drain system, and
practicing poor housekeeping at their facilities. Some commercial facilities have a history of water
quality problems and will be specifically targeted through mailings, brochures, or presentations
including:
Concrete Companies — Targeted for potential illegal dumping of wash water into storm drains.
Lawn Care Companies and Golf Courses — Targeted for potential improper application of
fertilizers and herbicides resulting in discharges to surface waters.
Painting / Home Renovation Companies — Targeted for potential improper handling of paints and
other waste materials resulting in discharges to storm drains.
Restaurants — Targeted for potential improper handling of grease and other cooking byproducts
resulting in discharges to storm drains.
Carpet Cleaning Companies — Targeted for potential illegal dumping of wastewater into storm
drains.
Automotive Repair Facilities — Targeted for potential improper handling of used oil and other
waste automotive fluids resulting in discharges to storm drains.
3.4 Informational Website
A website will continue to be developed and directed at all the target audiences discussed in sub-
section 3.3 including the general public and commercial and industrial entities. Specific
information will be provided on these web pages directed at the pollution sources discussed in
Table 3-2 above.
3.5 Public Education Materials
This outreach mechanism will be used to target specific pollution sources associated with the
general public, industrial / commercial facilities, and institutions including lawn care practices,
handling of used oil and other automotive wastes, housekeeping techniques, etc. as well as to
increase public reporting of pollution problems. Brochures will be distributed during responses to
citizen requests for service, presentations, and at event displays.
The City of Fayetteville page - 9 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
3.6 Hotline / Help Line
The Stormwater Hotline, initiated in 1995 as an integral part of the Stormwater program, is a source
of information and direction, and continues to be the primary means for the public to communicate
incidents, complaints and suggestions on a 24/7 basis.
3.7 Public Education and Outreach Program
Rather than use a "one size fits all" mentality, the public education and outreach program presents
clear messages through a kaleidoscope of media. The multi -faceted program helps citizens of
Fayetteville choose behaviors that protect our water quality.
3.7.1 Newspaper Articles / Inserts
Press releases often result in newspaper articles. Press releases will be issued regularly throughout
the Permit period to trigger newspaper articles about topics such as public events, workshops,
proper yard waste, animal waste and grease disposal, project completion, and other topics.
3.7.2 Coordination with PWC
Periodically throughout the Permit period, the Stormwater Program will coordinate advertising
with PWC addressing water quality and stormwater runoff in various publications produced by the
Public Works Commission and is 70,000 customers. Advertising may take the form of an
advertisement placed in the Storm Prep Guide, guest appearances on various PWC radio and TV
programs, and podcasts, and monthly billing newsletters.
3.7.3 Community Events
Each year throughout the Permit period, staff will regularly participate in community events such
as the Fayetteville Dogwood Festival and community awareness events by having booth space and
distributing information and promotional items.
3.7.4 Public Educational Presentations
Educational presentations will be given beginning in the first year of the permit targeted at the
general public, interest groups, businesses and industrial facilities. These presentations will be
made regularly throughout each of the permit years. The presentations will focus on the efforts
necessary to protect water quality and the promotion of volunteer activities.
3.7.5 Classroom Outreach
Each year throughout the Permit period, classroom presentations will be made to all grades from
prekindergarten through high school utilizing educational outreach materials. Presentations will
also be made at the local colleges (Fayetteville State University and Methodist University) on
certain occasions.
The City of Fayetteville page - 10 —
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
3.7.6 Promotional Items
Promotional items will be designed and distributed to complement outreach activities such as
group presentations, workshops, and public events. Promotional items will include, but are not
limited to, messages with the hotline number to report pollution and the Stormwater Division
internet address.
3.7.7 Partnership with Clean Water Education Partnership
The City will maintain a partnership with the Clean Water Education Partnership which provides
various direct education and mass media services to aid in the implementation of stormwater
outreach and education. The Clean Water Education Partnership is a state wide cooperative that
assists communities large and small with educational efforts through providing direct education
opportunities, mass media services such as television and radio ads, social media and website
content, as well as print publications for both English and Spanish speaking audiences.
3.7.8 Social Media
Social media has become an important way to provide information and engage with audiences in
a variety of subjects. The City uses a variety of social media platforms to educate citizens and
provide program information.
3.8 Measurable Goals
Table 3-3 describes the various Public Education and Outreach Program BMPs and the
Measurable Goals for each BMP by permit term year.
The City of Fayetteville page - 11—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 3-3: BMP Measurable Goals for the Public Education and Outreach Program
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(a) Describe
Describe the target
Review and
Review and
Review and
Review and
Review and
target pollutants
pollutants and target
update target
update target
update target
update target
update target
and target
pollutant sources the
pollution sources
pollution sources
pollution sources
pollution sources
pollution sources
pollutant sources
public education
as necessary
as necessary
as necessary
as necessary
as necessary
program is designed to
address and why they are
an issue.
(b) Describe
Describe the target
Review and
Review and
Review and
Review and
Review and
target audiences
audiences likely to have
update target
update target
update target
update target
update target
significant stormwater
audiences as
audiences as
audiences as
audiences as
audiences as
impacts and why they
necessary
necessary
necessary
necessary
necessary
were selected.
(c) Informational
Promote and maintain an
Continue to
Continue to
Continue to
Continue to
Continue to
website
internet website
maintain an
maintain an
maintain an
maintain an
maintain an
designed to convey the
informational
informational
informational
informational
informational
program's message.
website to provide
website to provide
website to provide
website to provide
website to provide
program
program
program
program
program
information to the
information to the
information to the
information to the
information to the
public
public
public
public
public
(d) Distribute
Distribute general
Distribute
Distribute
Distribute
Distribute
Distribute
public education
stormwater educational
educational
educational
educational
educational
educational
materials to
material to appropriate
materials at public
materials at public
materials at public
materials at public
materials at public
identified user
target groups as likely to
events,
events,
events,
events,
events,
groups
have a significant
workshops, and
workshops, and
workshops, and
workshops, and
workshops, and
stormwater impact.
presentations
presentations
presentations
presentations
presentations
(e) Promote and
Promote and maintain a
Maintain a hotline
Maintain a hotline
Maintain a hotline
Maintain a hotline
Maintain a hotline
maintain -Hotline /
stormwater hotline /
that receives
that receives
that receives
that receives
that receives
Help Line
helpline.
information from
information from
information from
information from
information from
the public 24
the public 24
the public 24
the public 24
the public 24
hours a day
hours a day
hours a day
hours a day
hours a day
The City of Fayetteville page -12 -
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(f) Implement a
Promote and maintain a
Continue
Continue
Continue
Continue
Continue
Public Education
Public Education and
education and
education and
education and
education and
education and
and Outreach
Outreach program
outreach activities
outreach activities
outreach activities
outreach activities
outreach activities
Program
designed to address
per the plan
per the plan
per the plan
per the plan
per the plan
target pollutant sources
and to provide
information and
education to the general
public as well as target
audiences.
The City of Fayetteville page —13-
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
3.9 Program Assessment
The overall success of the Public Education and Outreach Program will be measured through the
successful implementation of the components of the program. Program assessment will be reported
with each Annual NPDES Permit Report discussing the activities completed in this section for the
previous program year.
In addition, success may also be measured specifically by the following:
➢ Number of Hotline inquires
➢ Number of Citizen Requests for Service Received
➢ Number of Water Quality Presentations Conducted
➢ Survey Results
Section 4: Public Involvement and Participation
The City has developed and implemented a Public Involvement and Participation Program to
provide opportunities for the public to participate in program development and implementation.
The following Sections explain the BMPs to be implemented to meet this requirement, explanation
of the public participation program, and measures of success.
4.1 BMP Summary Table
Table 4-1 provides information concerning the BMPs to be implemented to fulfill the Public
Involvement and Participation Program requirements. Funding for the BMPs in this section is
covered by local stormwater utility fees.
Table 4-1: BMP Summary Table for the Public Involvement and Participation Program
BMP
BMP Description
(a) Volunteer community
Develop and promote volunteer opportunities designed to promote
involvement program
ongoing citizen participation.
(b) Establish a mechanism
Provide and promote a mechanism for public involvement that provides
for public involvement
for input on stormwater issues and the stormwater program.
(c) Establish Hotline /
Promote and maintain a Hotline / Helpline for the purpose of public
Help Line
involvement and participation.
(d) Public review and
Make copies of the most recent Stormwater Plan available for public
comment
review and comment.
(e) Public notice
Comply with State, Tribal, and local public notice requirements when
implementing a Public Involvement and Participation Program.
4.2 Volunteer Involvement Program
The City of Fayetteville through the Parks and Recreation Department coordinates two programs,
Adopt -A -Street and Adopt -A -Site, to provide trash and litter pickup along streets and sites that have
been adopted by volunteer groups. The groups volunteer to clean these areas several times a year.
The City provides trash bags along with a list of safety procedures to be followed during the cleanup.
The City of Fayetteville page -14—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
The groups report their activities back to the City, and the City picks up the full trash bags for proper
disposal. These groups provide a valuable service toward the improvement of water quality by
picking up and properly disposing of trash and litter that could otherwise be discharged to the
City's storm drainage system during the next rain event.
The Stormwater Division partners with Fayetteville Beautiful, a local affiliation of Keep America
Beautiful. Fayetteville Beautiful is responsible for citywide clean ups to include, but not limited
to, litter and debris removal, stream cleanup, etc. Fayetteville Beautiful strives to keep the City
clean, and to educate the public about the importance of putting litter in its proper place, thus
keeping it out of local rivers and streams.
4.3 Public Involvement Mechanism
The City has an active Stormwater Advisory Board (SWAB) that meets regularly. The SWAB was
established via ordinance in July 2009 as the City formed its own Stormwater Utility and Program
continuing under the same general format as the Joint Stormwater Advisory Board as established
with Cumberland County in 1995.
The City SWAB consisting of Fayetteville citizens provides guidance and advice to the City
Council pertaining to the Stormwater Management Program. Additionally, the SWAB has the
powers and duty in matters relating to the administrative review of any orders or decisions made
by the Stormwater Manager. In the past year, the SWAB has meet to discuss several issues
important to the Stormwater Program, such as amending the Stormwater Ordinance, reviewing
Capital Improvement Needs, reviewing the Stormwater Budget, and recommending a Stormwater
Utility fee increase. The SWAB has also heard presentations regarding the City's BMP inspections
process, outfall inspections process, as well as periodic project updates given by City Staff. The
SWAB provides useful feedback and is an important asset to the Stormwater Program.
4.4 Hotline / Help Line
The Stormwater Hotline, initiated in 1995 as an integral part of the Stormwater program, is a source
of information and direction, and continues to be the primary means for the public to communicate
incidents, complaints and suggestions on a 24/7 basis.
4.5 Public Review and Comment
Following the development of a Stormwater Plan, copies will be made available to the public for
review and comment. Hard copies will be available for public review at City Hall as well as a
digital copy will be posted on the Stormwater Division website. The SWAB will also review the
Stormwater Plan. Additionally, presentations and updates will be made to the SWAB as needed to
update and involve the public in the ongoing development and implementation of the program.
The City of Fayetteville page -15—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
4.6 Public Notice
All regular meetings, special meetings, and hearings of the Stormwater Advisory Board are filed
in accordance with the North Carolina Open Meetings Law. Notices of meetings are posted in a
central location in City Hall, as well as posted on the City's website. All records, files, and accounts
are considered public records as provided in the North Carolina General Statutes.
4.7 Measurable Goals
Table 4-2 describes the various Public Involvement and Participation Program BMPs and the
Measurable Goals for each BMP by permit term year.
The City of Fayetteville page -16—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 4-2: BMP Measurable Goals for the Public Involvement and Participation Program
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(a) Volunteer
Develop and promote
Continue to
Continue to
Continue to
Continue to
Continue to
community
volunteer opportunities
support Adopt -A-
support Adopt -A-
support Adopt -A-
support Adopt -A-
support Adopt -A -
involvement
designed to promote
Street, Adopt -A-
Street, Adopt -A-
Street, Adopt -A-
Street, Adopt -A-
Street, Adopt -A -
program
ongoing citizen
Site, and
Site, and
Site, and
Site, and
Site, and
participation.
Fayetteville
Fayetteville
Fayetteville
Fayetteville
Fayetteville
Beautiful
Beautiful
Beautiful
Beautiful
Beautiful
programs
programs
programs
programs
programs
(b) Establish a
Provide and promote a
Maintain the
Maintain the
Maintain the
Maintain the
Maintain the
mechanism for
mechanism for public
Stormwater
Stormwater
Stormwater
Stormwater
Stormwater
public involvement
involvement that
Advisory Board
Advisory Board
Advisory Board
Advisory Board
Advisory Board
provides for input on
stormwater issues and
the stormwater program.
(c) Establish
Promote and maintain a
Maintain a hotline
Maintain a hotline
Maintain a hotline
Maintain a hotline
Maintain a hotline
Hotline / Help Line
Hotline / Helpline for
that receives
that receives
that receives
that receives
that receives
the purpose of public
information from
information from
information from
information from
information from
involvement and
the public 24
the public 24
the public 24
the public 24
the public 24
participation.
hours a day
hours a day
hours a day
hours a day
hours a day
(d) Public review
Make copies of the most
Provide copies of
Advise the
Advise the
Advise the
Advise the
and comment
recent Stormwater Plan
draft Stormwater
SWAB on
SWAB on
SWAB on
SWAB on
available for public
Plan for public
program issues as
program issues as
program issues as
program issues as
review and comment.
review and
necessary
necessary
necessary
necessary
comment
(e) Public notice
Comply with State,
Provide public
Provide public
Provide public
Provide public
Provide public
Tribal, and local public
notices for all
notices for all
notices for all
notices for all
notices for all
notice requirements
SWAB meetings
SWAB meetings
SWAB meetings
SWAB meetings
SWAB meetings
when implementing a
as well as other
as well as other
as well as other
as well as other
as well as other
Public Involvement and
meetings as
meetings as
meetings as
meetings as
meetings as
Participation Program.
necessary
necessary
necessary
necessary
necessary
The City of Fayetteville page -17—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
4.8 Program Assessment
The overall success of the Public Involvement and Participation Program will be measured through
the successful implementation of the components of the program. Program assessment will be
reported with each Annual NPDES Permit Report discussing the activities completed in this
section for the previous program year.
In addition, success may also be measured specifically by the following:
➢ Number of Streets and Sites adopted by Volunteers
➢ Number of Citizen Requests for Service Received
➢ Number of Pollution Problems detected
➢ Survey Results
Section 5: Illicit Discharge Detection and Elimination (IDDE)
The City maintains a proactive Illicit Discharge Detection and Elimination Program that has
developed out of the implementation of the NPDES stormwater permit program. The program
centers on the identification of water quality problem areas and the initiation of standardized
follow-up field screening activities designed to identify and eliminate pollution sources and restore
water quality conditions. Some of the integral components of this program are as follows:
➢ Responding to citizen requests for service concerning water quality problems
➢ Administration and enforcement of the City's stormwater pollution control ordinance
➢ Identification and mapping of stormwater outfalls that discharge to Waters of the State
➢ Creek Cleaning and Dry Weather Flow screening
➢ Train employees about illicit discharges and how to prevent and report them
➢ Maintain a public reporting mechanism
➢ Coordination with other local government agencies to identify and eliminate failed septic
systems and sanitary sewer overflows
The following Sections explain the BMPs to be implemented to meet this requirement, explanation
of the program, and measures of success.
5.1 BMP Summary Table
Table 5-1 provides information concerning the BMPs to be implemented to fulfill the Illicit
Discharge Detection and Elimination Program requirements. Funding for the BMPs in this section
is covered by local stormwater utility fees.
Table 5-1: BMP Summary Table for the Illicit Discharge Detection and Elimination Program
BMP
BMP Description
(a) Maintain appropriate
legal authorities
Maintain adequate ordinances or other legal authorities to prohibit illicit
connections and discharges and enforce the approved IDDE Program.
The City of Fayetteville page -18—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
(b) Maintain a Storm
Maintain a current map showing major outfalls and receiving streams.
Sewer System Base
Map
(c) Inspection / detection
Maintain written procedures and / or Standard Operating Procedures
program to detect dry
(SOPS) for detecting and tracing the sources of illicit discharges and for
weather flows at MS4
removing the sources or reporting the sources to the State to be properly
outfalls
permitted. Written procedures and / or SOPS shall specify a timeframe for
monitoring and how many outfalls and the areas that are to be targeted for
inspections.
(d) Employee training
Conduct training for appropriate municipal staff on detecting and
reporting illicit connections and discharges.
(e) Maintain a public
Establish and publicize reporting mechanism for the public to report illicit
reporting mechanism
connections and discharges. Establish citizen request response
procedures.
(f) Documentation
Document the date of Investigations, any enforcement action(s) or
remediation that occurred.
5.2 Ordinance Administration and Enforcement
Article H. Illicit Connections and Improper Disposal of Chapter 23 Stormwater Management became
effective in the City in July 2009. Prior to that, the City had been covered via an interlocal agreement
under Cumberland County's Ordinance as part of the previous joint Permit with the County. The
City's Ordinance contains the exact same provisions as the previous County Ordinance. The
Ordinance makes it illegal to place, deposit, or discharge anything except for stormwater runoff
into the storm drainage system. There are some "DENR approved" exceptions but overall the
Ordinance is very inclusive. The Ordinance provides City staff with a right -of- entry to private
property including buildings for enforcement actions when required. There is also a Schedule of
Civil Penalties, reviewed and approved annually by City Council on the City's Fee Schedule, that
details the fines and penalties associated with ordinance violations. The Ordinance is available to
the public online through the City's Stormwater website, or through
http://online.encodeplus.com/regs/fayetteville-nc/.
5.3 Stormwater System Inven!M
The City has previously inventoried the stormwater system that is considered part of the public
system. Thus, the inventory contains all stormwater structures and conveyances within the public
right-of-way and follows the system to its outfalls into Waters of the State. The parts of the
stormwater system that originate on private property are not part of the inventory. The inventory is
updated with new structures and conveyances as they are constructed through as-builts that are
submitted to the City at project completion.
During the inventory, lists of water quality concerns, sediment, and maintenance needs for each of
the watersheds were generated identifying the locations where problems and other maintenance
The City of Fayetteville page -19—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
needs exist. These lists were used by the City to detect and eliminate illicit connections and improper
disposal. Also, this information is being used to schedule maintenance by the City of Fayetteville
along with NCDOT. The stormwater system inventory was instrumental in identifying outfalls to
Waters of the State that need to be monitored as part of the field screening process.
5.4 Inspection / Detection Program
An effective Inspection / Detection Program is essential to the success of the Stormwater Plan.
Such a program has been in place in the City of Fayetteville since the beginning of the NPDES
permit program in 1995. To establish a solid approach for identifying and eliminating illicit
discharges, the City will rely on techniques proven to be successful through prior implementation
of the IDDE Program. These techniques are summarized below.
Out all Inspections / Inventory — During the stormwater system inventory, the City located and
identified all outfalls to Waters of the State regardless of their size. As the City has completed the
stormwater inventory, that data has been used to identify all major outfalls to Waters of the State
that are 36 inches and greater. The City has currently identified approximately 279 major outfalls
to Waters of the State. In order to create a baseline, the City completed an initial dry weather
screening of all the major outfalls once their location was established. Each year, the City aims to
screen 100% of the identified outfalls for dry weather flows and evidence to detect and eliminate
illicit connections or improper disposal. Since many of the outfalls have dry weather flows due to
the infiltration of groundwater, the Stormwater Inspector routinely evaluates the dry weather flow
for any abnormal color, odor, or sheen. Results of the screenings are recorded in a database and
are considered a permanent record.
The City will continue to monitor dry weather flows at the major outfalls and at other locations
throughout the stormwater system as they are identified. If dry weather flows are observed,
samples will be collected to determine if the flow is a pollution source and immediate follow-up
field screening activities will be initiated when needed to identify and eliminate pollution sources.
Water Quality Monitoring — Water quality monitoring is conducted for the purpose of identifying
illicit connections and discharges, determining general water quality conditions, and targeting
water quality problem areas for additional follow-up actions. IDDE monitoring includes ambient
and fixed interval stream monitoring activities aimed at improving capabilities for identifying and
eliminating pollution problems and tracking long and short-term water quality trends. These data
will continue to be carefully reviewed in order to identify priority areas for follow-up field
screening, with an overall goal of identifying and eliminating pollution sources.
Industrial / Commercial Facilities — Industrial / commercial facilities are identified as a potential
source of illicit connections and discharges to City streams. An inspection program for industrial
/commercial facilities was implemented as a component of the initial NPDES permit program to
identify and eliminate pollution sources. These activities continue as part of the NPDES permit
program and the Stormwater Plan.
The City of Fayetteville page - 20—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Public Outreach / Involvement — Reporting by the general public is one of the best tools for
detecting illicit connections and discharges. The City will focus its public outreach campaign, in
part, on informing the public of what to look for in the detection of illicit connections and
discharges and the proper reporting process for suspected pollution problems. All reported
pollution problems will be recorded as a "citizen request for service" and immediately assigned to
staff for initiation of necessary follow-up actions to identify and eliminate pollution sources.
Illicit Connections and Improper Disposal Ordinance — The City's Illicit Connections and
Improper Disposal Ordinance is the main document that defines prohibited discharges and
describes enforcement measures that may be applied when violations are determined. Once an
illicit discharge or other pollution source is identified, the ordinance will be utilized to ensure the
elimination of pollution problems and the restoration of water quality conditions.
The City investigates possible illicit connections or improper disposal activities to detect and
eliminate them. The City acts as the enforcement agent and has authority to issue fines. Additionally,
during any enforcement action, the Inspector will educate the violator on stormwater quality and how
similar situations can be avoided in the future.
Coordination with Fayetteville Public Works Commission (PWC — The Stormwater Division and
PWC will continue to work jointly on promoting water quality issues through their public relations
programs. Additionally, the Stormwater Division forwards potential sanitary sewer leaks to PWC
upon discovery. Likewise, PWC alerts the Stormwater Division anytime there is a sanitary sewer
overflow that would potentially impact the water quality of the City's stormwater drainage system
and, more importantly, local streams. In cases of sanitary sewer overflows, Fayetteville PWC sends
email messages to both the Stormwater Manager and the Stormwater Inspections Supervisor
detailing the specifics of the occurrence. Responses by the Stormwater Division will vary
depending on the nature of the problem and the threat to water quality. Therefore, there is open
communication and continuous dialogue between these two agencies.
Coordination with County Health Department — Stormwater will continue to forward discoveries
of failing and potentially failing septic tanks to the Cumberland County Health Department and
works with their personnel as needed to resolve the matter. Additionally, the Stormwater Division
will coordinate with the County Health Department to resolve issues of stagnant water and
mosquito problems.
Sanitary Sewer Extension — In addition to the above coordination with the County Health
Department, properties in Cumberland County that are primarily on septic tank will continue to be
annexed into the City of Fayetteville. As a result, these properties will be converted over time to
the sanitary sewer. Thus, the proliferation of septic tanks in the urbanized area will continue to be
reduced. Accordingly, this will reduce the circumstances where septic tanks fail and in turn impact
the local water quality.
5.5 Employee Training
Target City employee groups will be educated about common illicit discharges, associated
environmental and health hazards, pollution prevention practices, problem reporting methods
The City of Fayetteville page - 21—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
and the requirements of the Illicit Connections and Improper Disposal Ordinance. Employee groups
will be prioritized and education programs will be delivered based on the established priorities.
Various education methods will be used as appropriate for the target groups, including online
training tools, distribution of written literature, participation in employee events, articles in
employee newsletters, and referrals to information on the Stormwater website, group presentations,
field visits, and facility inspections.
5.6 Public Education and Outreach
The City will continue to maintain a public education and outreach program to inform businesses,
industries, and the general public about illicit discharges and improper waste disposal and how
they impact the environment. This education and outreach program will include instructions
regarding the proper method for reporting illicit discharges. A media campaign, website, utility
bill inserts and handouts / brochures will be the primary education and outreach mechanisms.
Handouts and brochures will be reviewed and revised as necessary and will be distributed during
the performance of facility inspections, when responding to citizen requests for service, and at
event displays. These public education and outreach items for the IDDE Program are included as
a component of the Public Education and Outreach Program described in Section 3 of this
Stormwater Plan.
5.7 Public Reporting Mechanism
The Stormwater Hotline, initiated in 1995 as an integral part of the Stormwater program, is a source
of information and direction, and continues to be the primary means for the public to communicate
incidents, complaints and suggestions on a 24/7 basis.
5.8 Documentation
The City maintains electronic and hard copy files as necessary to document activities conducted under the
Illicit Discharge Detection and Elimination Program, including service requests, investigations and
enforcement actions.
5.9 Measurable Goals
Table 5-2 describes the various Illicit Discharge Detection and Elimination Program BMPs and
the Measurable Goals for each BMP by permit term year.
The City of Fayetteville page - 22—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 5-2: BMP Measurable Goals for the Illicit Discharge Detection and Elimination Program
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(a) Maintain
Maintain adequate
Continue
Continue
Continue
Continue
Continue
appropriate legal
ordinances or other legal
administration
administration
administration
administration
administration
authorities
authorities to prohibit
and enforcement
and enforcement
and enforcement
and enforcement
and enforcement
illicit connections and
of the Illicit
of the Illicit
of the Illicit
of the Illicit
of the Illicit
discharges and enforce
Connections and
Connections and
Connections and
Connections and
Connections and
the approved IDDE
Improper Disposal
Improper Disposal
Improper Disposal
Improper Disposal
Improper Disposal
Program.
Ordinance.
Ordinance
Ordinance
Ordinance
Ordinance
Review ordinance
and propose
updates as
necessary.
(b) Maintain a
Maintain a current map
Continue to
Continue to
Continue to
Continue to
Continue to
Storm Sewer
showing major outfalls
maintain storm
maintain storm
maintain storm
maintain storm
maintain storm
System Base Map
and receiving streams.
sewer map in GIS
sewer map in GIS
sewer map in GIS
sewer map in GIS
sewer map in GIS
and update as
and update as
and update as
and update as
and update as
necessary to show
necessary to show
necessary to show
necessary to show
necessary to show
additional outfalls
additional outfalls
additional outfalls
additional outfalls
additional outfalls
(c) Inspection /
Maintain written
Implement the
Continue
Continue
Continue
Continue
detection program
procedures and / or
established IDDE
implementation of
implementation of
implementation of
implementation of
to detect dry
Standard Operating
program.
the established
the established
the established
the established
weather flows at
Procedures (SOPS) for
IDDE program
IDDE program
IDDE program
IDDE program
MS4 outfalls
detecting and tracing the
sources of illicit
discharges and for
removing the sources or
reporting the sources to
the State to be properly
permitted. Written
procedures and / or
SOPs shall specify a
timeframe for
monitoring and how
many outfalls and the
areas that are to be
targeted for inspections.
The City of Fayetteville page - 24—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(d) Employee
Conduct training for
Update training
Update training
Update training
Update training
Update training
training
appropriate municipal
procedures as
procedures as
procedures as
procedures as
procedures as
staff on detecting and
necessary and
necessary and
necessary and
necessary and
necessary and
reporting illicit
conduct employee
refresher training
conduct employee
conduct employee
conduct employee
conduct employee
connections and
refresher training
refresher training
refresher training
refresher training
discharges.
(e) Maintain a
Establish and publicize
Maintain a hotline
Maintain a hotline
Maintain a hotline
Maintain a hotline
Maintain a hotline
public reporting
reporting mechanism for
that receives
that receives
that receives
that receives
that receives
mechanism
the public to report
information from
information from
information from
information from
information from
illicit connections and
the public 24
the public 24
the public 24
the public 24
the public 24
discharges. Establish
hours a day.
hours a day
hours a day
hours a day
hours a day
citizen request response
procedures.
(f)
The City shall document
Maintain IDDE
Maintain IDDE
Maintain IDDE
Maintain IDDE
Maintain IDDE
Documentation
the date of
program records
program records
program records
program records
program records
investigations, any
and databases to
and databases to
and databases to
and databases to
and databases to
enforcement action(s) or
accurately
accurately
accurately
accurately
accurately
remediation that
document the
document the
document the
document the
document the
occurred.
activities in the
activities in the
activities in the
activities in the
activities in the
program.
program.
program.
program.
program.
The City of Fayetteville page - 24—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
5.9 Program Assessment
The overall success of the Illicit Discharge Detection and Elimination Program will be measured
through the successful implementation of the components of the program. Program assessment
will be reported with each Annual NPDES Permit Report discussing the activities completed in
this section for the previous program year.
In addition, success may also be measured specifically by the following:
➢ Number of Citizen Requests for Service Addressed
➢ Number of Inspections Conducted
➢ Number of Problems Discovered
➢ Number of Notice of Violations (NOVs) Issued
➢ Number and Amount of Penalties Issued
Section 6: Construction Site Runoff Controls
6.1 Locally Delegated Program
The City does not currently have a locally delegated erosion control program for administrating a
Construction Site Runoff Controls Program. This program has been and is currently provided by
the local office of the NCDEQ Land Quality Section. Even though the City's existing Construction
Site Runoff program is handled by the local office of the NCDEQ Land Quality Section, the City
continues to aggressively inspect construction sites that are brought to their attention through
complaints or other sources. The City developed a standard operating procedure (SOP) that
provides a step by step outline as to how perform the inspection and any needed follow-up. These
activities are fully coordinated with NCDEQ Land Quality Section. There continues to be an
excellent working relationship between the City and NCDEQ to address all problems associated
with construction sites.
Additionally, the above referenced program by NCDEQ's Land Quality Section regulates
construction sites that are one (1) acre and larger. The City considers smaller sites as potentially
discharging sediment and performs inspections and pursues enforcement measures through our
local Ordinance or referral to NCDEQ when needed.
Section 7: Post -Construction Site Runoff Controls
The City has worked to develop and implement a program to manage post -construction stormwater
discharges to the MS4 in accordance with the NPDES requirements contained in 15A NCAC 2H
.0126(9). The goal of this program is to address water quality impacts from post -construction
stormwater discharges through the use of a combination of structural and non- structural
stormwater control measures (SCMs) as appropriate. The program has included the development,
implementation, and enforcement of an ordinance to address stormwater runoff from new
development and re -development projects that disturb one acre or more, including projects less
than one acre that are part of a larger common plan of development or sale that discharge to the
MS4. The ordinance assigns responsibility for the development and implementation of long-term
The City of Fayetteville page - 25—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
operation and maintenance practices for required SCMs. The following sections explain the BMPs
to be implemented to meet this requirement.
7.1 BMP Summary Table
Table 7-1 provides information concerning the BMPs to be implemented to fulfill the Post -
Construction Site Runoff Controls Program requirements. Funding for the BMPs in this section is
covered by local stormwater utility fees.
Table 7-1: BMP Summary Table for the Post -Construction Site Runoff Controls Program
BMP
BMP Description
(a) Post -Construction
Maintain an ordinance (or similar regulatory mechanism) for program to
Stormwater
address stormwater runoff from new development and redevelopment.
Management Program
(b) Strategies which
Maintain strategies that include a combination of structural and / or non -
include Stormwater
structural SCMs implemented in concurrence with (a) above. Provide a
Control Measures
mechanism to require long-term operation and maintenance of structural
(SCMs) appropriate
SCMs. Require annual inspection reports of permitted structural SCMs
for the MS4
performed by a qualified professional.
(c) Deed restrictions and
Provide mechanisms such as recorded deed restrictions, plats, and / or
protective covenants
protective covenants so that development activities maintain the project
consistent with approved plans.
(d) Operation and
The developer shall provide the City with an operation and maintenance
maintenance plan
plan for the stormwater system, indicating the operation and maintenance
actions that shall be taken, specific quantitative criteria used for
determining when those actions shall be taken, and who is responsible for
those actions. The plan must clearly indicate the steps that shall be taken
and who shall be responsible for restoring a stormwater system to design
specifications if a failure occurs and must include an acknowledgment by
the responsible party. Development must be maintained consistent with
the requirements in the approved plans and any modifications to those
plans must be approved by the City.
(f) Educational materials
Provide educational materials and training for developers. New materials
and training for
may be developed by the City, or the City may use materials adopted from
developers
other programs and adapted to the City's new development and
redevelopment program.
7.2 Post -Construction Stormwater Management Program
In October 2008, the Fayetteville City Council approved a Stormwater Control Ordinance that
contained provisions to address stormwater runoff from new development and redevelopment. The
ordinance became effective on January 1, 2009. Article III, Stormwater Control, of the City's
Stormwater Management Ordinance, Chapter 23 of the City of Fayetteville's Code of Ordinances,
requires SCMs to control peak discharge on new development as well as redevelopment so that the
post -development peak discharge rate will be no greater than the predevelopment peak discharge rate.
This provision minimizes the downstream flooding impacts arising from new development. Once
The City of Fayetteville page - 26—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
approved by the City Council, the ordinance was forwarded to NCDEQ for their review and approval.
The State requested several revisions so that the ordinance would be fully compliant with NPDES
permit requirements. In February 2012, the City adopted the proposed revisions to Article III to make
the ordinance compliant with Phase II post- construction requirements. The Article was subsequently
approved by NCDEQ. Based on the State's approval, the City of Fayetteville was delegated the
authority to administer the post- construction program on a local level. Therefore, the ordinance
contains both stormwater quantity and quality provisions. Last of all and to address the concern
regarding the ongoing maintenance of stormwater facilities in single-family subdivisions, the City
decided to accept the functional maintenance responsibility for these facilities, if the developer
requests such.
The above ordinance and Post -Construction Stormwater Management Program were designed to
meet the requirements for post -construction runoff from new development and redevelopment
projects specified by 15A NCAC 2H .0126 and the NPDES stormwater permit program. The
ordinance covers the entire jurisdictional area of the City minus those portions located on Fort
Bragg. As part of the program, an Administrative Manual was developed to ensure successful
implementation of the program.
The above referenced Stormwater Management Ordinance is available on the City's website as
well as through the Internet at http://online.encodeplus.com/regs/fayetteville-nc/.
7.3 Post -Construction BMP Strategies
The above referenced Article III utilizes the "Stormwater Design Manual" as developed by NCDEQ.
Therefore, local engineers and developers are able to utilize any of the SCMs in the Manual to address
their post -construction site runoff control requirements. On April 12, 2012, the Stormwater Division
submitted an updated "Certification of Local BMP Manual or Stormwater Engineering Guidance"
form to NCDEQ to attest that the local Water Supply Watershed and Phase II Stormwater Programs
are meeting requirements as outlined in the State's BMP Manual. Previously, the City's BMP Manual
certification was for Water Supply Watershed regulations only, but the update to add the Phase II
Stormwater component was necessary due to local program delegation by the State that resulted
from revisions to the City's Stormwater Management Ordinance adopted on February 13, 2012.
Article III requires the long term operation and maintenance of structural SCMs by the property
owner. This is accomplished by requiring that the structural SCM be inspected on an annual basis
and the inspection report submitted to the City of Fayetteville. The inspection and report are
designed to determine any maintenance needs and how they are to be repaired. Article III requires
that the inspection be performed and the report signed by a qualified professional.
The exception to the above is in single-family subdivisions where the developer requests that the
City provide the functional maintenance responsibility for the structural SCM. In these cases, the
City performs the annual inspection and determines any functional maintenance needs. If
necessary, City forces provide the needed repairs. The property owners in the subdivision are still
responsible for the routine maintenance such as grass cutting, trash removal, and landscaping.
The Stormwater Program has developed a Standard Operating Procedure (SOP) for Post
Construction SCM Inspections. The stormwater inspectors will follow the SOP while conducting
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
SCM inspections, maintain all inspection reports, and keeping all records in a central location.
7.4 Deed Restrictions and Protective Covenants
Section 23-32 Minimum Stormwater Quality Control Requirements of Article III of the
Stormwater Management Ordinance contains provisions that require deed restrictions and
protective covenants to ensure that development projects remain consistent with approved plans.
7.5 Operation and Maintenance Plan
Section 23-27 Plan Requirements of Article III of the Stormwater Management Ordinance contains
provisions that require the execution of an operation and maintenance agreement between the City
and the responsible party (owner) of each SCM. The provisions also stipulate that the owner must
conduct annual inspections of SCMs, maintain proper records documenting operation and
maintenance activities, and submit inspection reports to the City. In the case of single family
residential projects only, the City will assume the responsibility for operating, maintaining, and
inspecting required structural SCMs.
Please note that Article III of the ordinance requires that the above Operation and Maintenance
Plan be submitted to the City for review and approval prior to the issuance of a permit for the
construction of the improvements.
7.6 Setbacks for Built -Upon Areas
Section 23-32 Minimum Stormwater Quality Control Requirements of Article III of the
Stormwater Management Ordinance contains provisions that require a minimum of 30-foot buffers
on all perennial and intermittent streams draining less than or equal to 640 acres. Buffer widths of
75-feet are required on all perennial and intermittent streams draining greater than 640 acres. These
buffers are recorded on record plats.
7.7 Education and Training Program
The Stormwater Division developed an Administrative Manual that details how stormwater plans are
to be prepared, submitted, and reviewed by the City. The Manual outlines the entire process from
approval of the construction plans to the inspection and approval of the stormwater control measures
(SCMs). The Manual was specifically prepared to educate and train the local engineers and
developers on the new requirements for Post -Construction Site Runoff Controls. As a matter of fact,
the City engaged a Stakeholder Committee consisting of local engineers and developers to assist
in the development of the Administrative Manual.
Since the Administrative Manual became effective in February 2012, local engineers and developers
have used it for the preparation and submittal of plans to the City. In particular, the Appendices
contain numerous forms that are required during the design, construction, and closeout phases of the
SCMs. Additionally, City staff uses the Manual to review and approve the design, construction, and
closeout of all stormwater projects. In particular, the Appendices contain numerous form letters that
the City utilizes to approve, disapprove, or issue notices of violation for all phases of a stormwater
project. The Stormwater Division also plans to review and update the Administrative Manual on an
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
as needed basis to ensure that it reflects any updates to Article III of the ordinance (Stormwater
Control) or other procedural modifications. The Administrative Manual is available to the public on
the City of Fayetteville Stormwater website(www.fayettvillenc.Rov/stormwater).
During the current Permit cycle, the Administrative Manual and ordinance will be evaluated for
potential amendments and reconciling proposed changes with the Administrative Manual.
7.8 Measurable Goals
Table 7-2 describes the various Post -Construction Site Runoff Controls Program BMPs and the
Measurable Goals for each BMP by permit term year.
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 7-2: BMP Measurable Goals for the Post -Construction Site Runoff Controls Program
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(a) Post-
Maintain an ordinance
Continue
Continue
Continue
Continue
Continue
Construction
(or similar regulatory
administration
administration
administration
administration
administration
Stormwater
mechanism) for program
and enforcement
and enforcement
and enforcement
and enforcement
and enforcement
Management
to address stormwater
of the Stormwater
of the Stormwater
of the Stormwater
of the Stormwater
of the Stormwater
Program
runoff from new
Control Ordinance
Control Ordinance
Control Ordinance
Control Ordinance
Control Ordinance
development and
redevelopment.
(b) Strategies
Maintain strategies that
Continue Post-
Continue Post-
Continue Post-
Continue Post-
Continue Post -
which include
include a combination of
Construction Site
Construction Site
Construction Site
Construction Site
Construction Site
SCMs appropriate
structural and / or non-
Runoff Controls
Runoff Controls
Runoff Controls
Runoff Controls
Runoff Controls
for the MS4
structural SCMs
program by
program by
program by
program by
program by
implemented in
requiring SCMs,
requiring SCMs,
requiring SCMs,
requiring SCMs,
requiring SCMs,
concurrence with (a)
ensuring proper
ensuring proper
ensuring proper
ensuring proper
ensuring proper
above. Provide a
SCM operation
SCM operation
SCM operation
SCM operation
SCM operation
mechanism to require
and maintenance,
and maintenance,
and maintenance,
and maintenance,
and maintenance,
long-term operation and
and annual
and annual
and annual
and annual
and annual
maintenance of
inspections
inspections
inspections
inspections
inspections
structural SCMs.
Require annual
inspection reports of
permitted structural
SCMs performed by a
qualified professional.
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(c) Deed
Provide mechanisms
Continue to
Continue to
Continue to
Continue to
Continue to
restrictions and
such as recorded deed
implement Deed
implement Deed
implement Deed
implement Deed
implement Deed
protective
restrictions, plats, and /
Restrictions and
Restrictions and
Restrictions and
Restrictions and
Restrictions and
covenants
or protective covenants
Protective
Protective
Protective
Protective
Protective
so that development
Covenants
Covenants
Covenants
Covenants
Covenants
activities maintain the
through
through
through
through
through
project consistent with
administration of
administration of
administration of
administration of
administration of
approved plans.
the Stormwater
the Stormwater
the Stormwater
the Stormwater
the Stormwater
Control
Control
Control
Control
Control
Ordinance
Ordinance
Ordinance
Ordinance
Ordinance
(d) Operation and
The developer shall
Continue to
Continue to
Continue to
Continue to
Continue to
maintenance plan
provide the City with an
implement
implement
implement
implement
implement
operation and
Operation and
Operation and
Operation and
Operation and
Operation and
maintenance plan for the
Maintenance Plan
Maintenance Plan
Maintenance Plan
Maintenance Plan
Maintenance Plan
stormwater system,
requirements
requirements
requirements
requirements
requirements
indicating the operation
through
through
through
through
through
and maintenance actions
administration of
administration of
administration of
administration of
administration of
that shall be taken,
the Stormwater
the Stormwater
the Stormwater
the Stormwater
the Stormwater
specific quantitative
Control
Control
Control
Control
Control
criteria used for
Ordinance
Ordinance
Ordinance
Ordinance
Ordinance
determining when those
actions shall be taken,
and who is responsible
for those actions.
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(f) Educational
Provide educational
Continue to
Continue to
Continue to
Continue to
Continue to
materials and
materials and training
provide
provide
provide
provide
provide
training for
for developers. New
Administrative
Administrative
Administrative
Administrative
Administrative
developers
materials may be
Manual to educate
Manual to educate
Manual to educate
Manual to educate
Manual to educate
developed by the City,
and train local
and train local
and train local
and train local
and train local
or the City may use
engineers and
engineers and
engineers and
engineers and
engineers and
materials adopted from
developers
developers.
developers
developers
developers
other programs and
Review Manual
adapted to the City's
and propose
new development and
updates as
redevelopment program.
necessary.
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
7.9 Program Assessment
The overall success of the Post -Construction Site Runoff Controls Program will be measured
through the successful implementation of the components of the program. Program assessment
will be reported with each Annual NPDES Permit Report discussing the activities completed in
this section for the previous program year.
In addition, success may also be measured specifically by the following:
➢ Number of Plans Reviewed
➢ Number of SCMs Installed
➢ Number of Inspections Conducted
Section 8: Pollution Prevention and Good Housekeeping for Municipal Operations
The City maintains a comprehensive Pollution Prevention and Good Housekeeping for Municipal
Operations Program for applicable City owned and operated facilities. This includes inspection
and training programs to reduce stormwater pollutant runoff from these municipal operations to
the maximum extent practicable. Training materials developed locally and those available through
EPA have been used in training programs, which are targeted to operations with the highest
potential for impacting stormwater quality. The following Sections explain the BMPs to be
implemented to meet this requirement.
8.1 BMP Summary Table
Table 8-1 provides information concerning the BMPs to be implemented to fulfill the Pollution
Prevention and Good Housekeeping for Municipal Operations Program requirements. Funding for
the BMPs in this section is covered by local stormwater utility fees.
Table 8-1: BMP Summary Table for the Pollution Prevention and Good Housekeeping for
Municipal Operations Program
BMP
BMP Description
(a) Inventory of municipal
Maintain an inventory of municipal facilities and operations that have been
facilities and
determined to have significant potential for generating polluted stormwater
operations
runoff. Also maintain an inventory of municipally -owned structural SCMs.
(b) Inspection and
Implement an inspection and maintenance program for facilities and
evaluation of municipal
operations owned and operated by the City for potential sources of
facilities and operations
polluted runoff, including stormwater controls and conveyance systems.
The inspection program shall evaluate pollutant sources, document
deficiencies, plan corrective actions, implement appropriate controls, and
document the accomplishment of corrective actions. The maintenance
program shall include maintenance activities and procedures aimed at
preventing or reducing pollutants generated from municipal facilities and
operations.
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
(c) Site Pollution
Maintain and implement Site Pollution Prevention Plans for municipal
Prevention Plans for
facilities owned and operated by the City that have been determined by the
municipal facilities and
City to have significant potential for generating polluted stormwater runoff
operations
that has the ultimate goal of preventing or reducing pollutant runoff.
(d) Spill Response
Maintain and implement spill response procedures for municipal facilities
Procedures for
and operations owned and operated by the City that have been determined
municipal facilities and
by the City to have significant potential for generating polluted stormwater
operations
runoff.
(e) Prevent or minimize
Describe measures that prevent or minimize contamination of the
contamination of
stormwater runoff from all areas used for vehicle and equipment cleaning,
stormwater runoff from
including fire stations that have more than three fire trucks and
all areas used for
ambulances. Perform all cleaning operations indoors, cover the cleaning
vehicle and equipment
operations, ensure wash water drains to the sanitary sewer system, collect
cleaning
stormwater runoff from the cleaning area and provide treatment or recycle,
or other equivalent measures. If sanitary sewer is not available to the
facility and cleaning operations take place outdoors, the cleaning
operations shall take place on grassed or graveled areas to prevent point
source discharges of the wash water into the storm drains or surface
waters.
Where cleaning operations cannot be performed as described above and
when operations are performed in the vicinity of a storm drainage
collection system, the drain is to be covered with a portable drain cover
during cleaning activities. Any excess standing water shall be removed
and properly handled prior to removing the drain cover.
Facilities that serve three or fewer fire trucks and ambulances and that
cannot comply with these requirements shall incorporate structural
measures during facility renovation.
(f) Streets, roads, and
The City shall implement BMP's to reduce polluted stormwater runoff
public parking lots
from municipally owned streets, roads, and public parking lots within the
maintenance
corporate limits.
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
(g) Inspection and
The City shall maintain and implement an inspection and maintenance
Maintenance (I&M) for
program for stormwater control measures (SCMs) owned and operated by
municipally -owned or
the municipality and the municipal storm sewer system (including catch
maintained structural
basins, the conveyance system, and structural stormwater controls).
stormwater (SCMs) and
the storm sewer system
(h) Staff training
Maintain and implement a training plan that indicates when, how often,
who is required to be trained, and what they are to be trained on.
8.2 Facility Inventory and Site Inspections
All parcels of land owned or operated by the City will be examined to determine whether they will
be included in the inventory of sites for inclusion in the Pollution Prevention and Good
Housekeeping for Municipal Operations Program. To be included in the final inventory means that
those facilities will be inspected regularly, have SPPPs prepared and implemented, and their
employees will be trained on a regular basis (among other activities). Facilities on the final
inventory will have two or more buildings, stormwater drainage to the MS4, and a potential to
generate polluted stormwater runoff. Table 8-2 shows the current inventory based on known
operations. The list will be expanded if additional operations are identified through the inventory
process.
Table 8-2: Municipal Sites included in the Pollution Prevention and Good Housekeeping for
Municipal Operations Program
Facility
Industrial
Permit
Physical Address
PWC Wastewater Treatment Plant
Yes
601 South Eastern Boulevard
PWC Water Treatment Plant
502 Hoffer Drive
PWC Electrical Storage Yard
1035 Old Wilmington Road
PWC Fleet Maintenance Facility
1035 Old Wilmington Road
Fayetteville Regional Airport
Yes
400 Airport Road
Fayetteville Area System of Transit Bus Garage
Yes
455 Grove Street
Environmental Services Facility
Yes
455 Grove Street
Building Maintenance Facility & Fueling Station
325 Grove Street
Street Division Facility
335 Alexander Street
Milan Street Storage Yard
400 Milan Road
Marsh Street Storage Facility and Truck Wash
704 Marsh Street
Parks and Recreation Maintenance Facility
602 Ann Street
Parks and Recreation Maintenance / Storage
Facility
214 Gray Street
Waste Management Transfer Station
583 Winslow Street
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Facilities on the final inventory list will be evaluated through inspections on a priority basis.
Inspections will include the following:
• Thorough assessment of facility operations, maintenance activities, maintenance
schedules, and long-term inspection procedures.
• Evaluation of waste disposal methods and documentation to ensure compliance with
existing regulations and elimination of all potential pollution sources.
• Evaluation of the stormwater drainage system, including catch basin inlets, structural best
management practices and outfalls.
• Evaluation of water quality conditions downstream of the facility and identification and
elimination of pollution sources if discovered.
• Review of spill response and clean up procedures with recommended revisions as
appropriate.
• Evaluation of housekeeping practices with recommended revisions as necessary to
eliminate potential pollution sources.
• Evaluation of outdoor storage facilities and recommendations for elimination of potential
pollution sources.
• Identification and elimination of dry weather discharges.
• Review of Stormwater Pollution Prevention Plans where applicable including effluent
monitoring (if required by permit).
• Completion of a written report documenting findings and recommendations.
Follow-up inspections and meetings with appropriate personnel will be conducted as necessary to
ensure the elimination of all potential pollution sources. The supervisor and other management
personnel of each facility will be contacted and provided with a copy of the written report.
8.3 Facility Site Pollution Prevention Plans
Site Pollution Prevention Plans (SPPPs) will be developed for all facilities listed in Table 8.2
below. For facilities with their own Phase I NPDES Stormwater Permit, a detailed SPPP will be
developed in accordance with their permits. All other facilities will be covered under the City of
Fayetteville's Phase I MS4 permit, and shorter, more user-friendly versions of SPPPs will be
developed for them. In all cases, the SPPP will be used as an implementation guide for maintaining
good housekeeping and reducing stormwater pollution. All appropriate topics will be covered
including best management practices, monitoring, training, inspections, spill prevention / response,
vehicle / equipment cleaning, and preventative maintenance. All documentation will be kept in the
SPPPs, including descriptions of deficiencies found and corrective actions taken. A site map will
also be included in all SPPPs.
8.4 Municipal Spill Response Procedures
Numerous activities conducted by City employees, both in the field and at facilities, have the
potential to generate spills that may enter the MS4 and contaminate surface waters. Because of
that risk, Spill Prevention and Response Procedures will be developed for all facilities (and
associated field operations) listed in Table 8.2. For those facilities / operations that already have
procedures in place, they will be reviewed and updated as necessary. To make the effort as
seamless as possible, Spill Prevention and Response Procedures will be incorporated into SPPPs.
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
To that end, spill prevention and response evaluations will often be conducted in conjunction with
evaluations to develop SPPPs. Once the procedures are developed, proper implementation will be
evaluated as part of annual inspections.
Items that will be evaluated and incorporated into Spill Prevention and Response Plans include
the following:
• Product storage tanks / containers, exposure, and secondary containment
• Flow path and potential for entry into the MS4
• Spill history, response to those spills, and documentation
• Activities that may generate spills
• Operating procedures to prevent spills
• Spill response procedures
• Spill response equipment and other countermeasures
• Employee training
8.5 Vehicle and Equipment Cleaning_ Operations
The City recognizes the negative impacts that vehicle and equipment wash water runoff can have
on stormwater and, ultimately, surface waters. Municipal employees wash the majority of vehicles
and equipment at commercial or municipal vehicle wash facilities that drain to the sanitary sewer.
Vehicle and equipment washing at municipal facilities will be assessed during annual inspections
at all facilities listed in Table 8-2. A section regarding vehicle and equipment washing will then
be included in the SPPP of each facility that conducts washing activities. Where washing is found
to not be in accordance with the City's NPDES Permit, corrective actions will be implemented as
appropriate to the conditions at each facility. Once the SPPPs are developed, washing activities
will continue to be evaluated during facility inspections.
8.6 BMP Selection for Streets, Roads, and Public Parking Lots Maintenance
Streets, roads, and parking lots can be a significant source of stormwater pollution. In previous
years, the City of Fayetteville has implemented various BMPs to address these pollutants within
the MS4 by cleaning catch basins and other MS4 maintenance activities. As required by the City's
current NPDES Municipal Stormwater Discharge Permit, the City has evaluated additional types
of BMPs that, in the City's opinion, would best address polluted stormwater runoff from
municipally -owned streets, roads, and public parking lots prior to these pollutants entering the
MS4.
The City's `BMP Evaluation for Municipally -Owned Streets, Roads, and Public Parking Lots"
summarizes the City's evaluation of BMPs to reduce polluted stormwater runoff from municipally -
owned streets, roads, and public parking lots within the corporate limits. The City's evaluation
focused on the following BMPs:
Street Sweeping
Yard Waste Containerization
Loose Leaf Collection
Spill Response (HAZMAT)
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Person Street "Greenstreet" Streetscape
Public Parking Lots
Animal Control
Dog Park
Coordination with NCDOT
Therefore and based on its evaluation, the City has selected the above BMPs to reduce polluted
stormwater runoff from its municipally -owned streets, roads, and public parking lots. All of the
above BMPs are outlined in the next section.
8.7 BMP Implementation for Streets, Roads, and Public Parking Lots Maintenance
The following are BMPs that the City is either currently implementing or will implement to reduce
polluted stormwater runoff from its municipally -owned streets, roads, and public parking lots.
Street Swe0in— The Stormwater Division currently funds the City's entire Street Sweeping
operations. The City Street Maintenance Division performs this service on City streets as well as on
some NCDOT roads, including selected thoroughfares, through a maintenance agreement. In regards
to the street sweeping schedule, the thoroughfares are typically swept at night due to less traffic.
These streets are swept ten (10) times during the year or about once per month except during the
heart of winter. The sweeping process requires a water spray that does not work well in cold weather.
The thoroughfare schedule includes NCDOT streets through the agreement previously referenced.
Residential / subdivision streets are swept four (4) times per year plus shortly behind the leaf
collection as close as possible. Thus, most of the residential / subdivision streets are swept five (5) or
six (6) times peryear.
Yard Waste Containerization — The City's Environmental Services Department collects
containerized yard waste once per week throughout the year. Citizens have the choice to purchase
a brown yard waste container through Environmental Services, or may use clear plastic yard waste
bags to containerize debris. Containerization of yard waste and debris helps the City to continue to
look appealing, as well as to prevent this material from flowing into the storm drainage system.
Details regarding the pickup of yard waste are outlined in Article I, Chapter 22 of the Solid Waste
Ordinance. Stormwater promotes yard waste containerization through its educational program to
help prevent stormwater pollution.
Loose Leaf Collection — The Stormwater Division promotes the City of Fayetteville's loose leaf
collection. During the fall leaf season, City residents can place their loose leaves and pine straw at
the curb for pick-up during specific collection periods. This program provides for the timely
removal of the leaves prior to them being washed into the storm drainage system. Stormwater
coordinates with Environmental Services to educate citizens on proper placement of their loose
yard waste to ensure that it does not reach the drainage system. At other times throughout the year,
Chapter 22, Article I of the City's Solid Waste Ordinance requires containerization of all leaves
for efficient and effective pick-up. Again, the containerization requirement keeps the leaves from
being washed down streets and other conveyances, and into the storm drainage system.
Spill Response — The City of Fayetteville's Hazardous Materials (HAZMAT) Team provides
regional emergency spill response. The members of the HAZMAT unit are certified in hazardous
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NPDES Permit No. NCS000246 — Stormwater Plan July 2021
materials by the State of North Carolina. Firemen who are part of the HAZMAT team also receive
a wide variety of training to handle different types of hazardous materials and situations once they
are assigned. The HAZMAT team is also contracted by the State of North Carolina as one of seven
Regional Response teams. The team is in charge of responding to incidents that cover a twelve
county area. It is through these response teams that counties in the region receive the necessary
help and materials to handle large HAZMAT calls.
The Stormwater Division takes an active role in any HAZMAT spill response where material could
potentially enter the drainage system and eventually Waters of the State. To participate in this
process, Stormwater Division personnel have received general HAZMAT training. Stormwater
Division personnel will plug any drainage lines in the vicinity of a spill where the spill might enter
a portion of the drainage system. If necessary, Stormwater Division personnel will contact an
environmental firm who is licensed and permitted to clean materials out of the storm drainage
system. Stormwater Division personnel coordinate the efforts to ensure that hazardous materials
do not reach the Waters of the State.
Person Street "Greenstreet" Streetscape — The Person Street Green Street project is complete and
monitoring of the project finished in the spring of 2020. The final report was turned over to the
City in the winter of 2020.
The Person Street "Greenstreet" project encompasses two blocks of Person Street (which is a major
corridor for Downtown Fayetteville). Person Street is located upstream and discharges its runoff
to Blounts Creek. The design for this project incorporates innovative Low Impact Development
(LID) devices which aids in runoff reduction and pollution reduction. Devices such as linear bio-
filtration bump -outs, Silva Cells, and an experimental undersized permeable pavement design are
used in this project. These devices meet LID volume reduction and quality improvement goals for
this project. Blounts Creek is a biologically impaired stream upstream of the Greenstreet project
and benefits from improved water quality from the proposed devices.
Public Parking Lots — The Filterra systems that were installed in the Amtrak parking lots were
removed during construction of the Segra Baseball Stadium. Two Filterra units were installed on
Person Street for use in the Person Street Green Street.
City -owned parking lots are swept by street maintenance on an as needed basis and when requested
by City staff.
Animal Control — On June 24, 2013, the Fayetteville City Council adopted amendments to the
Animal Control Ordinance which requires owners of animals to immediately dispose of animal
waste from any public or private property, properly. Violators of the Ordinance can face violation
notices, fines, leading up to loss of animal (until fees are paid) for habitual offenders. This
ordinance will not only help the community to look better, but it will also have a positive impact
on water quality.
Dog ark — The City of Fayetteville operates the Riverside Dog Park, located near the Cape Fear
Botanical Gardens. There are two designated areas, one for dogs smaller than twenty-five pounds and
the other for any dog larger. All dogs in the park are to be on a leash and have license and tags on
their collars. Additionally, dog owners are educated and encouraged to properly dispose of their dog's
The City of Fayetteville page - 40—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
waste. The proper disposal of dog waste makes for a better park but it also improves the quality of
the stormwater runoff leaving the park.
Coordination with NCDOT — The Stormwater Division coordinates with the local NCDOT on
various stormwater activities such as street sweeping and ditch maintenance programs as well as
issues related to their NPDES permit implementation. As indicated previously, the City is reimbursed
for street sweeping various NCDOT roads through an existing maintenance agreement.
8.8 Inspection and Maintenance for Municipally Owned or Maintained Stormwater Control
Measures (SCMs) and Storm Sewer System
The City provides several municipal operations designed to keep its storm sewer system
functioning properly. All of these operations impact the storm sewer system. Thus, it is important
to develop operation and maintenance programs that take impacts to the storm sewer system into
consideration. Initially it will be important to meet with appropriate personnel within these
operations. Such meetings will provide a forum to gather information about field activities and
potential impacts, review operation and maintenance procedures, and discuss cooperative roles for
updating good housekeeping programs and making improvements. Observations of field activities
that impact the storm sewer system will also be a key part of developing operation and maintenance
programs. Seeing activities take place first-hand and obtaining input from field employees will
provide important information that may not be obtained during an office meeting.
Some of these municipal operations already have well -established operation and maintenance
programs. These programs will be reviewed in terms of how well they address impacts to the storm
sewer system and subsequently updated if necessary. Where programs are lacking or deficient, the
City will work with appropriate personnel to develop programs and procedures as well as to
conduct training of field employees on how to properly implement the programs and procedures.
Based on previous experience with its old permit, the City has and is currently implementing
operation and maintenance programs and procedures as outlined below. As part of the development
process, the programs and procedures as outlined below will be reviewed and modified as
necessary to better protect the storm sewer system.
Drainage Inspection — The Stormwater Division makes routine inspections of the drainage system
based on drainage complaints. Stormwater Division personnel inspect the problem area, assess the
source of the problem, then report the problem to the appropriate agency (City Street Maintenance
Division, City or County Engineering, NCDOT, etc.). The Stonmwater Division maintains a
computerized database of open Work Orders until the problem is resolved. This complaint driven
process was greatly enhanced based on the results from the stormwater inventory. Therefore, based
on data from the inventory, the inspection and maintenance of the storm drainage system has become
more efficient, effective, and systematic.
Additionally, all members of the City's Street Maintenance Crews including the Leaf Cleaning Crews
have been instructed to inspect the storm drainage system as they carry out their daily responsibilities
in the field. Based on their field observations, they report any potential maintenance needs through
the proper channels. Also, the Inspectors in the Construction Management Division look for any
drainage system maintenance needs as they inspect construction projects involving new and
The City of Fayetteville page - 41—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
replacement / upgraded infrastructure throughout the City.
DrainagSystem Maintenance — The City Street Maintenance Division routinely cleans the piped
portions of the storm sewer system using a Jet -Vac process. This maintenance practice provides
benefits by removing sediments and other pollutants that might otherwise be washed downstream
during a heavy rain. The Stormwater Division has also purchased a camera system (RovverX Long -
Range Pipe Inspection Crawler) to assist in inspecting storm drainage pipe. The City uses the camera
to videotape various pipes looking for damaged pipes, problems with pipe joints, and potential illegal
connections to the storm drain system. The camera system has the capability to take video and still
images during inspections. The camera has greatly expanded system maintenance and upkeep, while
allowing for a more timely resolution to problems that are detected.
Limited Creek Cleaning Program — The Stormwater Division has a Limited Creek Cleaning Program
which essentially removes trash, debris and undergrowth from the existing ditches, channels and creek
banks in order to proactively remove potential threats to the public right of way or city -owned
infrastructure. Crews may perform limited vegetation maintenance to ensure that the character of the
channel is maintained, however the program is not intended to increase the capacity or improve any
conveyance characteristics of the channel by excavation or filling; thus, the name Limited Creek
Cleaning Program.
Beaver Management Program — The City of Fayetteville partners with USDA to remove debris and
obstructions in local waterways. To accomplish this, the Stormwater Division coordinates with the
local wildlife Beaver Management Assistance Program (BMAP) to provide City residents with these
needed services to reduce or eliminate property damage and threats to human health and safety caused
by beaver activities within the City limits. The beaver population in local urban streams continues
to grow and be problematic for property owners.
8.9 Employee / Staff Training
Training seminars will be conducted for employees at the facilities listed in Table 8-2 based on a
priority schedule. The goal of these training seminars will be to inform employees of the actions
necessary to reduce the discharge of pollutants from their facilities / operations and protect water
quality. The following topics will be included in the seminar:
1) Overview of general water quality conditions in the City of Fayetteville and reasons for
protecting water quality
2) Description of common pollutants, their sources, and water quality impacts
3) Description of the actions that each facility should take to reduce discharges of pollutants,
with an emphasis on good housekeeping
4) Description of effective spill prevention measures that should be employed at each
facility
5) Discussion of typical pollution sources at municipal operations and specific actions that
should be taken to eliminate these sources and protect water quality
6) Review of the Site Pollution Prevention Plan where applicable
7) Explanation of the potential negative consequences of failing to control pollutants at
facilities
8) Overview of IDDE Program and how to report observed water quality problems
The City of Fayetteville page - 42—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
The seminars will include a combination of classroom -style presentations and hands-on outdoor
activities. Written materials including a summary of good housekeeping practices and spill
prevention / control techniques will also be distributed during the seminars.
8.10 Measurable Goals
Table 8-3 describes the various Pollution Prevention and Good Housekeeping for Municipal
Operations Program BMPs and the Measurable Goals for each BMP by permit term year.
The City of Fayetteville page - 43—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 8-3: BMP Measurable Goals for the Pollution Prevention and Good Housekeeping for Municipal Operations Program
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(a) Inventory of
Maintain an inventory
Maintain an
Maintain an
Maintain an
Maintain an
Maintain an
municipal facilities
of municipal facilities
inventory of
inventory of
inventory of
inventory of
inventory of
and operations
and operations that
municipal facilities
municipal facilities
municipal facilities
municipal facilities
municipal facilities
have been determined
and municipally-
and municipally-
and municipally-
and municipally-
and municipally -
to have significant
owned structural
owned structural
owned structural
owned structural
owned structural
potential for generating
SCMs. Review and
SCMs. Review and
SCMs. Review and
SCMs. Review and
SCMs. Review and
polluted stormwater
update as
update as
update as
update as
update as
runoff. Also maintain
an inventory of
necessary.
necessary.
necessary.
necessary.
necessary.
municipally -owned
structural SCMs.
(b) Inspection and
Implement an
Conduct
Conduct
Conduct
Conduct
Conduct
evaluation of
inspection and
inspections of
inspections of
inspections of
inspections of
inspections of
municipal facilities
maintenance program
applicable facilities
applicable facilities
applicable facilities
applicable facilities
applicable facilities
and operations
for facilities and
and make
and make
and make
and make
and make
operations owned and
corrective actions
corrective actions
corrective actions
corrective actions
corrective actions
operated by the City for
where necessary.
where necessary.
where necessary.
where necessary.
where necessary.
potential sources of
polluted runoff,
including stormwater
controls and
conveyance systems.
The City of Fayetteville page - 44—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(c) Site Pollution
Maintain and implement
Review and
Review and
Review and
Review and
Review and
Prevention Plans
Site Pollution
update facility
update facility
update facility
update facility
update facility
for municipal
Prevention Plans for
Site Pollution
Site Pollution
Site Pollution
Site Pollution
Site Pollution
facilities and
municipal facilities
Prevention Plans
Prevention Plans
Prevention Plans
Prevention Plans
Prevention Plans
operations
owned and operated by
as necessary and
as necessary and
as necessary and
as necessary and
as necessary and
the City that have been
continue
continue
continue
continue
continue
determined by the City
implementation of
implementation of
implementation of
implementation of
implementation of
to have significant
Site Pollution
Site Pollution
Site Pollution
Site Pollution
Site Pollution
potential for generating
Prevention Plans
Prevention Plans
Prevention Plans
Prevention Plans
Prevention Plans
polluted stormwater
runoff that has the
ultimate goal of preventing
or reducing pollutant
runoff.
(d) Spill Response
Maintain and implement
Review facility
Review facility
Review facility
Review facility
Review facility
Procedures for
spill response procedures
Spill Response
Spill Response
Spill Response
Spill Response
Spill Response
municipal facilities
for municipal facilities
Procedures and
Procedures and
Procedures and
Procedures and
Procedures and
and operations
and operations owned and
update as
update as
update as
update as
update as
operated by the City that
necessary.
necessary.
necessary.
necessary.
necessary.
have been determined by
Continue
Continue
Continue
Continue
Continue
the City to have
implementation of
implementation of
implementation of
implementation of
implementation of
significant potential for
procedures.
procedures.
procedures.
procedures.
procedures.
generating polluted
stormwater runoff.
(e) Prevent or
Maintain and implement
Review procedures
Review procedures
Review procedures
Review procedures
Review procedures
minimize
measures that prevent or
for vehicle and
for vehicle and
for vehicle and
for vehicle and
for vehicle and
contamination of
minimize contamination
equipment cleaning
equipment cleaning
equipment cleaning
equipment cleaning
equipment cleaning
stormwater runoff
of the stormwater runoff
operations and
operations and
operations and
operations and
operations and
from all areas used
from all areas used for
update as necessary
update as necessary
update as necessary
update as necessary
update as necessary
for vehicle and
vehicle and equipment
equipment cleaning
cleaning, except for
facilities that serve three
or fewer fire trucks and
ambulances.
The City of Fayetteville page - 45—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(f) Streets, roads,
The City shall
Review procedures
Review
Review
Review procedures
Review procedures
and public parking
implement BMPs to
and BMPs for
procedures and
procedures and
and BMPs for
and BMPs for
lots maintenance
reduce polluted
streets, roads, and
BMPs for streets,
BMPs for streets,
streets, roads, and
streets, roads, and
stormwater runoff from
public parking lots
roads, and public
roads, and public
public parking lots
public parking lots
municipally -owned
maintenance and
parking lots
parking lots
maintenance and
maintenance and
streets, roads, and public
update as necessary
maintenance and
maintenance and
update as necessary
update as necessary
parking lots within the
update as
update as
corporate limits.
necessary
necessary
(g) Inspection and
The City shall
Continue
Continue
Continue
Continue
Continue
Maintenance for
implement and maintain
implementation of
implementation
implementation of
implementation of
implementation of
municipally-
an inspection and
the operation and
of the operation
the operation and
the operation and
the operation and
owned or
maintenance program
maintenance
and maintenance
maintenance
maintenance
maintenance
maintained
for stormwater control
program for
program for
program for
program for
program for
stormwater control
measures SCMs, and the
structural
structural
structural
structural
structural
measures (SCMs)
storm sewer system
stormwater SCMs
stormwater
stormwater SCMs
stormwater SCMs
stormwater SCMs
and the storm
(including catch basins,
and the storm
SCMs and the
and the storm
and the storm
and the storm
sewer system
the conveyance system,
sewer system and
storm sewer
sewer system and
sewer system and
sewer system and
(including catch
and structural
review and update
system and
review and update
review and update
review and update
basins, the
stormwater
as necessary
review and
as necessary
as necessary
as necessary
conveyance
controls).
update as
system, and
necessary
structural
stormwater
controls)
The City of Fayetteville page - 46—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(h) Staff training
Implement and Maintain
Conduct annual
Conduct annual
Conduct annual
Conduct annual
Conduct annual
a training plan that
staff training on
staff training on
staff training on
staff training on
staff training on
indicates when, how
Good
Good
Good
Good
Good
often, who is required to
housekeeping, Spill
housekeeping, Spill
housekeeping,
housekeeping,
housekeeping,
be trained, and what
Response, and Site
Response, and Site
Spill Response,
Spill Response,
Spill Response,
they are to be trained on.
Pollution
Pollution
and Site
and Site
and Site
Prevention Plans
Prevention Plans
Pollution
Pollution
Pollution
(where applicable)
(Where applicable)
Prevention Plans
Prevention Plans
Prevention Plans
(where
(where
(where
applicable)
applicable)
applicable)
The City of Fayetteville page - 47—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
8.11 Program Assessment
The overall success of the Pollution Prevention and Good Housekeeping for Municipal Operations
Program will be measured through the successful implementation of the components of the
program. Program assessment will be reported with each Annual NPDES Permit Report discussing
the activities completed in this section for the previous program year.
In addition, success may also be measured specifically by the following:
➢ Number of Inspections Conducted
➢ Number of Problems Discovered and Resolved
Section 9: Industrial Facilities Evaluation and MonitorinL-
The City maintains an Industrial Facilities Evaluation and Monitoring Program to evaluate and
monitor discharges to the City's MS4 from applicable industrial facilities. This includes inspection
and monitoring programs to evaluate facilities that may contribute or have the potential to
contribute substantial pollutant loads to the MS4. The following Sections explain the BMPs to be
implemented to meet this requirement.
9.1 BMP Summary Table
Table 9-1 provides information concerning the BMPs to be implemented to fulfill the Industrial
Facilities Evaluation and Monitoring Program requirements. Funding for the BMPs in this section
is covered by local stormwater utility fees.
Table 9-1: BMP Summary Table for the Industrial Facilities Evaluation and Monitoring Program
BMP
BMP Description
(a) Maintain an Inventory
Maintain an inventory of permitted hazardous waste treatment, disposal,
of Industrial Facilities
and recovery facilities, industrial facilities that are subject to Section 313
of Title III of the Superfund Amendments and Reauthorization Act of
1986 (SARA), industrial facilities identified with an industrial activity
permitted to discharge stormwater to the City's MS4, or as identified as an
illicit discharge under the IDDE Program.
For the purposes of the City's NPDES Permit, industrial activities shall
mean all permitted industrial activities as defined in 40 CFR 122.26.
(b) Inspection Program
Identify priorities and inspection procedures. At a minimum, priority
facilities include those identified above in subsection (a).
(c) Evaluate Industrial
The City is required to evaluate control measures implemented at
Facilities discharging
permitted hazardous waste treatment, disposal, and recovery facilities,
stormwater to the
industrial facilities that are subject to Section 313 of Title III of the
City's MS4
Superfund Amendments and Reauthorization Act of 1986 (SARA),
industrial facilities identified with an industrial activity permitted to
The City of Fayetteville page - 48—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
discharge stormwater to the City's MS4, or as identified as an illicit
discharge under the IDDE Program.
For permitted facilities, the City shall establish procedures for reporting
deficiencies and non-compliance to the permitting agency. Where
compliance with an existing industrial stormwater permit does not result
in adequate control of pollutants to the MS4, the City will recommend and
document the need for permit modifications or additions to the permit
issuing authority.
For the purposes of the City's NPDES Permit, industrial activities shall
mean all permitted industrial activities as defined in 40 CFR 122.26. For
the purpose of the City's NPDES Permit, the City is authorized to inspect
the permitted hazardous waste treatment, disposal, and recovery facilities
as an authorized representative of the Director.
9.2 Industrial Facility Inventory
Facilities included in the inventory will fit into one or more of the following categories: hazardous
waste TSD facility, SARA Title III facility (TRI reporter), NPDES Stormwater permitted facility,
Stormwater No Exposure Certificate facility, and Industrial Wastewater Pre- Treatment permitted
facility. Currently, a list of 33 facilities has been developed showing those facilities that discharge
to the City's MS4 and have the potential to discharge significant pollutant loads.
The list forms the basis of the industrial inspection and monitoring program inventory. The list
was compiled by obtaining information from the Fayetteville Regional Office of NCDEQ, field
findings, Yellow Pages review, and other sources. The inventory will be modified as facilities on
the list start up or shut down. Other facilities that do not fit into the categories described above
may be added to the inventory as well. An example would be a facility discovered during field
activities to have an illicit discharge or pollution issues.
9.3 Industrial Facilities Inspection Program
The purpose of the Industrial Facilities Inspection Program is to evaluate activities at industrial
facilities that may impact stormwater discharges, and then work with problem facilities to reduce
identified stormwater pollution. To effectively accomplish the goals of the program, the City has
developed a standard operating procedure (SOP) that is used by all of its Inspectors as they make
industrial facility inspections. The SOP provides a step-by-step outline as to how the inspection as
well as any needed follow-up actions is to take place.
Additionally, the City has updated a previously developed standard Inspection Form using the EPA
Guidance Manual. The new form is used and filled out by all of the Inspectors conducting
inspections of industrial facilities. The Inspection Form contains an extensive checklist including
the following:
The City of Fayetteville page - 49—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
o Review of the Stormwater Pollution Prevention Plan (SWPPP)
o Review and inspection of all activities both inside and outside of the facility
o Observations at all stormwater outfalls
o BMPs are reviewed and their effectiveness assessed
o History of any spills or leaks are reviewed
o Photographs are taken of the facility and its activities
Industrial inspections are conducted on a priority basis. Those industries with the greatest potential
to cause environmental harm and impact the quality of stormwater runoff are assigned a higher
priority and inspected before others. The City Inspector completes an industrial site inspection
checklist report as described above for each site inspected. The inspection checklist information is
transferred to an Excel spreadsheet as a permanent record. The City is currently inspecting all 33
of the facilities on the above referenced inventory on an annual basis. If problems are noted during
the inspection, the facility is notified of the deficiencies and instructed to make the necessary
improvements in order to achieve compliance. The compliance status of such facilities is indicated
as "pending" in the inventory to note that the facility will need to be re -inspected at a later date to
determine compliance. Once the facility has achieved compliance, the inventory is updated to
indicate that the facility "complied".
As a supplement to the industrial inspections and in a continuing effort to improve local water
quality, the City inspects area restaurants to make sure that they are practicing good housekeeping
in particular in the disposal of their cooking waste byproducts (grease). Similar to the industrial
inspections, the City Inspector completes a site inspection checklist report for each restaurant
inspected. The inspection checklist information is transferred to a database as a permanent record.
As part of this inspection process, the City Inspectors provide the restaurants with educational
materials and notify the owners of educational and training resources available to them through
the City.
If the restaurant is found to be in non-compliance, the inspector will issue a Notice of Violation
(NOV), and provide guidance on how the problem can be remedied. If the issues are later found
to be unresolved, or not satisfactory, fines can be issued.
9.4 Evaluation Measures
During an industrial inspection, the City Inspector conducts visual monitoring of the receiving
waters at the industrial discharge point. The Inspector checks to see if the discharge has an
abnormal color, any odor, or sheen on the surface. The inspector also collects a sample of the
discharge for visual observation and to determine if any substances are suspended in the water
column. If necessary, photographs are taken of the outfall. If evidence of polluted runoff is
suspected, a sample of the discharge is collected and further analyzed by an approved laboratory
for a number of pollutant parameters. If pollutants are verified in the runoff, the City notifies the
facility and requires actions to be taken to remedy the situation.
Since the City is acting on behalf of NCDEQ in the majority of the industrial inspections and
anytime there is a potential violation or problem on any of the State permitted facilities, the City
The City of Fayetteville page - 50—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
notifies the Fayetteville Regional Office of NCDEQ of the situation. There is an excellent working
relationship between the Stormwater Division and the local NCDEQ office.
As an EPA requirement and supplemental to the major outfall inspections described earlier in
Section 5.4, the City also monitors and inspects outfalls (12 inches and larger) associated with
industrial activities to make sure that they are not discharging any potential pollutants to the City's
storm drainage system or to Waters of the State. Similar to the major outfall inspections, the City
Inspector completes an outfall inspection checklist report for each industrial outfall inspected. The
inspection checklist information is transferred to a database as a permanent record. The City is
currently inspecting 46 industrial outfalls.
9.5 Measurable Goals
Table 9-2 describes the various Industrial Facilities Evaluation and Monitoring Program BMPs
and the Measurable Goals for each BMP by permit term year.
The City of Fayetteville page - 51—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 9-2: BMP Measurable Goals for the Industrial Facilities Evaluation and Monitoring Program
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(a) Maintain an
Maintain an inventory of
Update the
Update the
Update the
Update the
Update the
Inventory of
permitted hazardous
industrial facility
industrial facility
industrial facility
industrial facility
industrial facility
Industrial Facilities
waste treatment,
inventory as
inventory as
inventory as
inventory as
inventory as
disposal, and recovery
needed
needed
needed
needed
needed
facilities, industrial
facilities that are subject
to Section 313 of Title
III of the Superfund
Amendments and
Reauthorization Act of
1986 (SARA), industrial
facilities identified with
an industrial activity
permitted to discharge
stormwater to the City's
MS4, or as identified as
an illicit discharge under
the IDDE Program.
(b) Inspection
Identify priorities and
Review and
Review and
Review and
Review and
Review and
Program
inspection procedures.
update Standard
update Standard
update Standard
update Standard
update Standard
Operating
Operating
Operating
Operating
Operating
Procedures and
Procedures and
Procedures and
Procedures and
Procedures and
Inspection Forms
Inspection Forms
Inspection Forms
Inspection Forms
Inspection Forms
as necessary
as necessary
as necessary
as necessary
as necessary
The City of Fayetteville page - 53—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
BMP
BMP Description
Measurable
Goals (by permit term year)
1
2
3
4
5
(c) Evaluate
The City is required to
Conduct
Conduct
Conduct
Conduct
Conduct
Industrial Facilities
evaluate control
inspection and
inspection and
inspection and
inspection and
inspection and
discharging
measures implemented
monitoring
monitoring
monitoring
monitoring
monitoring
stormwater to the
at permitted hazardous
activities based on
activities based on
activities based on
activities based on
activities based on
City's MS4
waste treatment,
established
established
established
established
established
disposal, and recovery
procedures and
procedures and
procedures and
procedures and
procedures and
facilities, industrial
prioritization
prioritization
prioritization
prioritization
prioritization
facilities that are
strategy at all
strategy at all
strategy at all
strategy at all
strategy at all
subject to Section 313
industrial
industrial
industrial
industrial
industrial
of Title III of the
facilities
facilities
facilities
facilities
facilities
Superfund
Amendments and
Reauthorization Act of
1986 (SARA),
industrial facilities
identified with an
industrial activity
permitted to discharge
stormwater to the
City's MS4, or as
identified as an illicit
discharge under the
IDDE Program.
The City of Fayetteville page - 54—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
9.6 Program Assessment
The overall success of the Industrial Facilities Evaluation and Monitoring Program will be
measured through the successful implementation of the components of the program. Program
assessment will be reported with each Annual NPDES Permit Report discussing the activities
completed in this section for the previous program year.
In addition, success may also be measured specifically by the following:
➢ Number of Inspections Conducted
➢ Number of Problems Discovered and Resolved
Section 10: Water Quality Assessment and Monitoring
The City maintains a Water Quality Assessment and Monitoring Program to monitor and assess
the quality of streams within the City as required by the NPDES stormwater permit. Information
gained from the program can be used to help identify and eliminate sources of pollution and illicit
discharges, track short-term and long-term trends, and, where possible, gauge the effectiveness of
stormwater management efforts and programs conducted by the City. The following Sections
explain the BMPs to be implemented to meet this requirement.
10.1 BMP Summary Table
Table 10-1 provides information concerning the BMPs to be implemented to fulfill the Water
Quality Assessment and Monitoring Program requirements. Funding for the BMPs in this section
is covered by local stormwater utility fees.
Table 10-1: BMP Summary Table for the Water Quality Assessment and Monitoring Program
BMP
BMP Description
(a) Water Quality
Maintain a Water Quality Assessment and Monitoring Plan. The Plan
Assessment and
shall include a schedule for implementing the
Monitoring Plan
proposed assessment and monitoring activities.
(b) Water Quality
The City shall implement and maintain the Water Quality Assessment and
Monitoring
Monitoring
Plan submitted to DEMLR.
10.2 Water Quality Assessment and Monitoring Plan
The City has been conducting water quality monitoring of streams and stormwater discharges since
the inception of its NPDES Stormwater Permit Program in 1995. Initially, the monitoring program
focused mainly on identifying illicit discharges. Data was used to identify and eliminate these
illegal discharges to the MS4 and surface waters and proved to be highly successful. While current
water quality monitoring efforts continue to be used for this purpose, the program has been
expanded over the years to include a wider array of water quality parameters with the additional
goal of identifying short-term and long-term water quality trends and gauging overall program
effectiveness, where possible.
The City of Fayetteville page - 55—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
As part of the new NPDES permit and the Stormwater Plan, the Stormwater Division developed
and submitted a Water Quality Assessment and Monitoring Plan to NCDEQ via a June 12, 2013
email with the Plan as an attachment. The Plan detailed proposed monitoring activities, parameters,
and data assessment required by the Permit. The Plan specified water quality monitoring activities
to be performed on a quarterly basis at a total of 6 stream sites on the major watersheds in the City.
Monitoring will be conducted for chemical and physical parameters on a fixed interval monitoring
basis. Staff at NCDEQ reviewed and approved the Plan later on June 12, 2013.
Table 10-2 provides a list of the water quality parameters sampled at the monitoring sites. Table
10-3 contains a description and location of the 6 monitoring sites in the Monitoring Plan. Figure
10-1 shows a map and location of the 6 monitoring sites within the Monitoring Plan.
Table 10-2: Water Quality Monitoring Parameters
Parameter
Sample Type
Frequency
Temperature
In -situ
Quarterly
Turbidity
In -situ
Quarterly
Dissolved Oxygen
In -situ
Quarterly
pH
In -situ
Quarterly
Conductivity
In -situ
Quarterly
Total Suspended Solids
Grab
Quarterly
Total Nitrogen
Grab
Quarterly
Total Kjeldahl Nitrogen
Grab
Quarterly
Ammonia (NH3)
Grab
Quarterly
NO2 + NO3
Grab
Quarterly
Total Phosphorous
Grab
Quarterly
Chromium (Cr)
Grab
Quarterly
Copper (Cu)
Grab
Quarterly
Lead (Pb)
Grab
Quarterly
Zinc (Zn)
Grab
Quarterly
Fecal Coliform
Grab
Quarterly
The City of Fayetteville page - 56—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 10-3: Description of City of Fayetteville Water Quality Monitoring Sites
Site
Stream
Location
BLT
Blounts Creek
Culvert at Campbell Avenue
XCK
Cross Creek
Culvert at Hillsboro Street
BVR
Beaver Creek
Bridge at Cumberland Road
BCK
Buckhead Creek
Culvert at Coventry Road
LRC
Little Rockfish Creek
Bridge at Lakewood Drive
CCK
Carvers Creek
Culvert at Ramsey Street and 1-295
The City of Fayetteville page - 57—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
FGRTBRAGG
1:1a
ES CREEK
LITTLE ROCKFISH CRE K 1
BEA1,CREEK2
i
Burl
BEAVER CREEK-31
STEWARTS,CREEK•
e
r
I
BLOl1NTS CREEK
r�
CREEK -
1
pCAPE FEL414•2
LITTLE R�CKFISH-CREEK
CREEK
Legend
Drainsge Basin
City of Fayetteville
N at in City
Town of Hope Mills
Town of Spring Lake
'Nat ersafthe State
Monitoring Site Location 0 12,000 24.000
Feet
Figure 10-1: Fayetteville Water Quality Monitoring Sites
The City of Fayetteville page - 58—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
10.3 Water Quality Monitoring Implementation
The City prepared and submitted its Water Quality Assessment and Monitoring Plan to NCDEQ
in June 2013 as described in Section 10-2 above. Upon receiving approval of the plan from
NCDEQ in June 2013, the City began implementation of the plan to conduct quarterly fixed
interval monitoring at the 6 specified monitoring sites. Following completion of monitoring
activities at the end of each fiscal year (June 30), monitoring data will be analyzed to determine
water quality trends and gauge program effectiveness where possible, especially in the areas of
illicit discharge detection and elimination.
10.4 Measurable Goals
Table 10-4 describes the various Water Quality Assessment and Monitoring Program BMPs and
the Measurable Goals for each BMP by permit term year.
The City of Fayetteville page - 59—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
Table 10-4: BMP Measurable Goals for the Water Quality Assessment and Monitoring Program
BMP
BMP Description
Measurable Goals
(by permit term year)
1
2
3
4
5
(a) Water Quality
Maintain a
Continue to
Continue to
Continue to
Continue to
Continue to
Assessment and
Water Quality
maintain the water
maintain the water
maintain the water
maintain the water
maintain the water
Monitoring Plan
Assessment and
quality assessment
quality assessment
quality assessment
quality assessment
quality assessment
Monitoring Plan. The
and monitoring
and monitoring
and monitoring
and monitoring
and monitoring
Plan shall include a
plan.
plan.
plan.
plan.
plan.
schedule for
implementing the
proposed assessment
and monitoring
activities.
(b) Water Quality
The City shall implement
Continue to
Continue to
Continue to
Continue to
Continue to
Monitoring
and maintain the Water
conduct Water
conduct Water
conduct Water
conduct Water
conduct Water
Quality Assessment and
Quality
Quality
Quality
Quality
Quality
Monitoring Plan
Assessment and
Assessment and
Assessment and
Assessment and
Assessment and
submitted to DEMLR.
Monitoring
Monitoring
Monitoring
Monitoring
Monitoring
activities per the
activities per the
activities per the
activities per the
activities per the
approved plan
approved plan
approved plan
approved plan
approved plan
The City of Fayetteville page - 60—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
10.5 Program Assessment
The overall success of the Water Quality Assessment and Monitoring Program will be measured
through the successful implementation of the components of the program. Program assessment
will be reported with each Annual NPDES Permit Report discussing the activities completed in
this section for the previous program year.
In addition, success may also be measured specifically by the following:
➢ Number of Samples Collected
➢ Number of Parameters Analyzed
➢ Data Analysis to Determine Trends
Section 11: Total Maximum Daily Loads (TMDLs)
The Stormwater Division has determined that a Total Maximum Daily Load (TMDL) has not yet
been developed and approved or established by NCDEQ (as delegated through EPA) for the
receiving waters of the City of Fayetteville's MS4 NPDES stormwater discharge. Therefore, this
Permit section is currently not applicable in the City of Fayetteville.
11.1 Impaired Streams Program
The Stormwater Division developed an Impaired Streams Program to monitor streams that have
been classified as impaired within the City limits in 2014. In many cases, it is possible that an
impaired stream could progress negatively overtime, and may have a TMDL assigned to them to
improve their water quality. In order to be proactive, Stormwater has developed this program on a
voluntary basis to monitor impaired streams and make necessary adjustments to improve their
water quality prior to the potential issuance of a TMDL.
This program will allow Stormwater to assess the effect pollutants may have on streams, as well
as determine how the streams are impacted by their surrounding environments. Stormwater uses
several methods to analyze the health of a stream, such as analytical laboratory sampling, field
sampling, and site inspections. The Stormwater Division samples for 20 to 32 parameters at each
sample site depending on what related issues are found during the inspection. These methods allow
staff to assess both the chemical and biological conditions of a stream. Information obtained
through sampling and inspection is then recorded on an Excel Spreadsheet. Using the spreadsheet,
staff will be able to analyze the results over time to determine patterns and possible pollution issues
within a stream.
The Stormwater Division identified the sample sites based on stream segments that the State has
deemed as impaired, along with input from the PWC Watersheds Group, to ensure that there is no
duplication of sample sites. From these efforts, 20 sample sites were identified. This program
allows Stormwater to understand the characteristics of our impaired streams.
Stormwater staff has developed a Standard Operating Procedure (SOP) for inspecting and
collecting sampling data from our designated impaired stream segments. The purpose of the
document outlines the City's efforts to monitor and reduce pollutants in local streams classified as
The City of Fayetteville page - 61—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021
impaired by NCDEQ. The written document is also highly effective in showing procedural
consistency and the process when audited by DENR and EPA. While there are no TMDLs
currently assigned to the City, the collected data and a validated process will be great tools and
provide historical information to hopefully avoid or at least delayfuture TMDLs in the local area.
The City of Fayetteville page - 62—
NPDES Permit No. NCS000246 — Stormwater Plan July 2021