NCS000436_Thomasville 2020 Annual Report Narrative_20201026

NPDES Phase II Stormwater
Annual Report
City of Thomasville
Fiscal Year
2019 – 2020
Prepared by:
Josh Johnson, P.E.

And

Phil Ross
Stormwater Program
Coordinator

alley, williams, carmen & king, inc.
engineers and architects
740 chapel hill road - post office box 1179
burlington, north carolina 27216-1179
Phone: [phone]
Fax: [phone]

City of Thomasville Stormwater Annual Report
2019 - 2020
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Report Outline
• Introduction
• NPDES Phase II
o Minimum Control Measures
 Public Education and Outreach
 Public Involvement and Participation
 Illicit Discharge Detection and Elimination
 Construction Site Runoff Controls
 Post Construction Stormwater Management
 Pollution Prevention and Good Housekeeping
• Impaired Waters and TMDL Waters
o Listing of Impaired Waters
 Impairment Type
 Timeline for Improvements
 Current Status
• High Rock Lake
• Stormwater Funding
• Future Issues
• Program Contacts
City of Thomasville Stormwater Annual Report
2019 - 2020
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Introduction

On July 1, 2005, The North Carolina Division of Water Quality (DWQ) in the Department of
Environmental Quality (DEQ), formerly DENR, began issuing Phase II stormwater permits to
municipalities in North Carolina under the National Pollutant Discharge Elimination System Program
(NPDES). At the time, the NPDES Phase II Program was the latest stormwater program stemming from
the Federal Clean Water Act of 1972. Prior to the Phase II program, EPA and NC DEQ had issued NPDES
Phase I Stormwater Permits to Cities larger than 100,000 persons. In North Carolina these cities were
Raleigh, Charlotte, Fayetteville, Durham, Greensboro, and Winston Salem. The Phase II Program
included distribution of Phase II permits to municipalities less than 100,000 residents and began with
municipalities within Municipal Spheres of Influence (MSI) that were greater than 50,000 citizens. The
City of Thomasville is included with the City of High Point and City of Greensboro as a Municipal Sphere
of Influence.

The Phase II stormwater program was created with the intention of improving the quality of the nation’s
waterways by reducing the quantity of pollutants that stormwater transports into stormwater systems
and discharges to surface water bodies. The permit require permittees at a minimum to develop,
implement, and enforce a stormwater program designed to reduce the discharge of pollutants from the
municipal separate storm sewer system (MS4) to the maximum extent practicable.
City of Thomasville Stormwater Annual Report
2019 - 2020
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The stormwater program is composed of the following six management measures:
1. Public Education and Outreach
2. Public Involvement and Participation
3. Illicit Discharge Detection and Elimination
4. Construction Site Runoff Controls
5. Post-Construction Site Runoff Controls
6. Pollution Prevention and Good Housekeeping for Municipal
Operations
Each of these measures consists of required Best Management Practices (BMPs), measurable goals for
each BMP and an implementation schedule for the 5 year permit cycle. Additionally, the City of
Thomasville has a Comprehensive Stormwater Management Program and completes annual reporting
about the NPDES Phase II Program. Because the NPDES Program concentrates on water quality it has
limited provisions concerning water quantity and flooding controls.
In early 2017, NC DWQ issued a renewal of the City’s NPDES Phase II Permit. This renewed permit is
similar to the previous permit with a few minor changes. A copy of the permit is available either through
Josh Johnson, P.E. or through NC Division of Energy, Mineral and Land Resources (NC DEMLR – which as
of fall of 2013 now houses Stormwater Permitting).
This Report is intended to complete the Annual Report specifying the City’s progression in implementing
the NPDES Permit and Comprehensive Stormwater Management Plan (CSWMP). It is also intended to
give readers a comprehensive idea of the City’s full Stormwater Program.
NPDES Phase II Minimum Control Measures
Each of the 6 Minimum Control Measures (MCM’s) has a set of best management practices (BMP’s) that
are intended to foster compliance with both the City’s Permit and CSWMP. These specific BMP’s can be
found in both the Permit and the CSWMP but highlights and specific actions will be noted in the report.
Public Education and Outreach
The City operates a Public Education and Outreach program that is designed to educate the general
public about the need to improve water quality in stormwater. The general objectives are to distribute
education materials to the community and/or to conduct equivalent outreach activities about the
impacts of storm water discharges on surface waters and the steps the public can take to reduce
pollutants in stormwater runoff. These objectives have been further refined to target residents, school
children, local businesses (specifically gas station owners and landscaping companies) and industry
because these groups have the most impact on stormwater pollution prevention.
The education program targets total suspended solids (TSS and Sediment) and nutrient loading because
turbidity, sedimentation, and nutrients are the pollutants of concern in downstream waters.
City of Thomasville Stormwater Annual Report
2019 - 2020
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The City partners with Stormwater SMART, an education and outreach organization hosted by the
Piedmont Triad Regional Council (PTRC). Stormwater SMART is a cooperative group that is funded by
several Piedmont municipalities. It was created in 2005 to provide education and outreach for MS4
Permittees (like Thomasville) and concentrates on direct education of school children and residents.
Danica Heflin is the Stormwater Smart Outreach and Education Coordinator and a copy of Stormwater
SMART’s Annual Report is available at http://www.ptrc.org/services/regional-planning/planning-
documents It provides a comprehensive outlook for the Fiscal Year 2019 - 2020 period. Pages 106 –
107 of the annual report provides specific details of outreach efforts within the City of Thomasville.
Danica Heflin can be contacted at [e-mail] or at [phone].
Due to the unprecedented COVID-19 pandemic, causing statewide shutdowns of public events,
programs and events that were being planned and that are typically held in the spring were cancelled.
Thomasville 2019 - 20
Location/ Event Date Program #Participants/Contacts

K- 12 Program at
Schools and Libraries
Fall 2019 Outreach

52

Lexington BBQ Festival
Visitors from
Thomasville
September 28, 2019

Outreach 49

iNaturalist.org
Biothon
April –June 2020 Virtual Outreach 22/206

TOTAL 307

Stormwater Smart Outreach Efforts in Thomasville
The City also has handouts on display at Thomasville City Hall and Thomasville Library. A possible future
improvement would be to include stormwater information and a link to Stormwater SMARTs website in
a more obvious and easy to find place on the City website.
Public Participation and Involvement
The City has a responsibility to solicit and consider public opinion on all matters, including stormwater
management. The City originally involved the public with a public hearing in 2006 and tried to create a
citizen’s committee during the first permit cycle but little interest was shown from the public. The City
has been receptive to any questions from citizens, maintains a Helpline - (City Hall at [phone] as
well as a Sanitary Sewer Overflow reporting form on the website) and has worked with Stormwater
SMART to educate the public but continues to struggle to establish effective Public Participation and
Involvement. The City held a Stormwater Public Meeting in October 2017 and was planning for a Spring
Meeting in 2020 but all efforts were cancelled due to COVID-19 restrictions. Future meetings will be
City of Thomasville Stormwater Annual Report
2019 - 2020
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planned when safe for the public. This meeting will seek the citizens input on the stormwater program
and will provide a platform for the City to educate its citizens as well.
Illicit Discharge Detection and Elimination
The City of Thomasville has a full Illicit Discharge Detection and Elimination (IDDE) Program. The IDDE
Program is intended to reduce discharges to the stormwater system that are not entirely composed of
stormwater. There are a few permitted discharges and firefighting related discharges that are allowed.
An illicit discharge is typically dirt, soap, pet waste, litter, oil, fertilizer, pesticides, or raw sewage and
often times comes from “generating sites.” Generating sites are points of pollution that continue over a
period and are recurring at regular or irregular intervals.
The backbone of the IDDE program is the IDDE Ordinance that the City passed in 2006. The IDDE
ordinance provides permits specific discharges into the MS4 as legal, provides legal authority to restrict
illegal discharges, prohibits illicit connections, provides conditions for cleaning up and preventing
polluted spills, provides for right of entry into property to investigate prohibited activities, and provides
the City with options for enforcing the Ordinance. The IDDE Ordinance is based on the NC DWQ’s Model
Ordinance.
The second basis for the IDDE program is the City’s MS4 Map. The mapping program was completed in
the first permit cycle by GPS mapping and is now usable in an AutoCAD format. The map includes the
entire MS4 system and provides for easy access to aid in the investigation of illicit discharges. An
investigator with the map could find an illicit discharge and then easily follow the flow of the discharge
upstream until finding a source of the discharge.

The map was originally published as a map book but generally is used on a watershed basis or through
AutoCAD and the City’s Engineering Department. If a specific area is needed it can be printed by either
Stormwater or City Staff. The map is intended to be updated on a regular basis as new development
City of Thomasville Stormwater Annual Report
2019 - 2020
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happens but updates since the completion of the map have been sporadic. A future improvement to the
MS4 map would be a conversion to GIS and the use of GIS by the City of Thomasville.
The IDDE program also includes dry weather testing of outfalls into the stream system. In the first
permit cycle this was conducted in coordination with the mapping. Outfalls that had dry weather flows
were reported and investigated. Since the first permit cycle, most dry weather flow testing has been
done in conjunction with complaints or City staff investigations.
The City has ongoing issues with its collection system that have resulted in multiple sanitary sewer
overflows annually. The City had 31 SSO’s during 2019- 20 reported by city staff and citizens and the
causes included debris in lines, grease, roots, pipe failures, inflow and infiltration, and severe natural
conditions. Only 3 necessitated repairs to pipe and equipment. The City is working hard on improving
the collection system and reducing SSO’s but improving the collection system will take several years to
reach compliance.
The City did not have an additional capital improvement budget in 2019. The 2018 budget included
funding for three planned capital improvements projects, Hanks Branch Outfall Phase I and Phase II
Upgrades and North Hamby Creek Phase III project oversight. The goals of these projects are to reduce
Sanitary Sewer Overflows which are also Illicit Discharges.
In 2019, the City also worked with Alley, Williams, Carmen, and King to conduct video inspection of over
100,000 linear feet of the sanitary sewer system.
There was no illegal dumping reported in 2019, there were no illicit connections and no rerouted
connections identified by the City during 2019. Two Illicit discharges were reported by citizens.
City Staff are trained on an annual basis to identify illicit discharges and the reporting process for these
discharges. 2020 training was being planned but was cancelled due to Statewide COVID-19 restrictions.
Typically the training is combined with the Pollution Prevention and Good Housekeeping training of
public works, utilities, recreation, planning, and administrative staff as well as some fire and police
personnel. Training of new hires in the future will be a way to improve education toward stormwater
IDDE problems.

City of Thomasville Stormwater Annual Report
2019 - 2020
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Thomasville Collection System Watershed Map
Construction Site Runoff Controls
The City of Thomasville delegates the Construction Site Runoff Controls to NC DEQ. The City of
Thomasville does not have a delegated erosion control program but does make sure that plans it
approves that will disturb greater than 1.0 acres of land apply for, and receive, and erosion control plan.
The City of Thomasville also has the ability to call NC DEQ to report known sedimentation issues. A
possible improvement could be NC DEQ’s responsiveness to City generated complaints, which has been
less than effective in the past.
Post Construction Site Runoff Controls
The City of Thomasville has a typical NPDES Phase II Post Construction Program. This includes a Post
Construction Ordinance, administrative forms that support it, and a review process. The Post
Construction Program applies to projects that exceed 1 acre of disturbance or have a common plan of
development that will cumulatively exceed 1.0 acres of disturbance. Projects that exceed 24% built-
upon area are considered high density projects, projects that are less than 24% BUA are low density
projects.

City of Thomasville Stormwater Annual Report
2019 - 2020
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High Density Projects are then required to meet the following requirements:
• Treat runoff from the first 1” of rain (the first flush).
• Treated Runoff is to be for 85% TSS removal.
• Discharge treated water at a rate less than or equal to the Predevelopment rate for the 1 year
24 hour storm.
• Discharge treated water between 48-120 hours.
• Stormwater Control Measures must be in easements and must have a recorded operation and
maintenance agreement.
• Compliance with 30’ vegetated buffers on perennial and intermittent streams.
Stormwater Control Measures, as well as runoff calculations, are prepared based upon the NC DEQ BMP
Manual and then reviewed by Josh Johnson, P.E.

Low Density projects are required to comply with the stream buffer regulations. Both Low and High
Density Projects are required to comply with the City’s Storm Sewer Design Manual which governs
storm drainage design as well as peak runoff rates.
When a project is submitted to the City it goes through the City Planning Department. City Planning staff
determine if the project is more than one acre or not. If the project exceeds 1.0 acres then a copy of the
City of Thomasville Stormwater Annual Report
2019 - 2020
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plan is sent to Josh Johnson, P.E. with Alley, Williams, Carmen, and King, Inc. AWCK then determines if
the project is subject to the Stormwater Ordinance and High Density or Low Density. At that point
review comments are made about the project and addressed. After approval of the project, the owner is
required to complete an Operation and Maintenance Agreement for the stormwater control measures.
This O&M agreement is then recorded with the register of deeds so that it can reviewed at a later point
in time.
The City of Thomasville reviewed 19 projects in 2019 - 20, one of which triggered the stormwater
ordinance. The City reviewed an additional 18 projects that did not cross the disturbance threshold and
one project was completed.
The City of Thomasville requires as-builts and annual inspection reports from new stormwater control
measures (SCM) but has had trouble getting annual inspection reports submitted. In the coming year the
City will inspect the existing stormwater control measures and then provide the property owners with
the inspection report and the needed improvements. This letter will also contain information requiring
SCM owners to provide future inspection reports to the City or face fines and/or assessments.
Pollution Prevention and Good Housekeeping
Pollution Prevention is an overall goal of the City’s stormwater management plan and Good
Housekeeping is a key to that goal. Municipalities, in general, conduct many activities that can pose a
threat to water quality. Municipal facilities are the primary potential source of contamination but with
good housekeeping habits this potential can be reduced or eliminated. The City attempts to minimize
stormwater pollution from municipal operations by complying with best management plans for each
City facility. The BMP’s are written into a City Facilities O&M Plan that is intended to reduce or eliminate
stormwater exposure of oil, grease, pesticides, herbicides, fertilizers, sediment, and other materials
used by the City. Each of the City facilities is inspected annually and any issues are noted, written into
the Facility O&M Plan, and discussed with the facility supervisor.

The City operates many different facilities including the following:
Name of Facility Address
Wastewater Treatment Plant 110 Optimist Park Road
Water Treatment Plant 200 Old Lexington Rd
Public Works Facility 525 Turner Street
Utilities Facility 512 Doak St
City Hall 10 Salem St
Police Station
Police Academy
7 West Guilford St
1285 Jacob St
City of Thomasville Stormwater Annual Report
2019 - 2020
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Fire Station # 21
(Headquarters)
712 East Main St
Fire Station # 22 815 S NC Highway 109
Fire Station # 23 1107 Lexington Ave
Fire Station # 24
Recreation Office
7000 Ballpark Rd
1 East Main St
Finch Field National Highway
City Parks Varies
Winding Creek Golf Course
Golf Course Maintenance
72 Winding Creek Rd
1281 Jacob St
George Cushwa Stadium Stadium Drive
Memorial Park Swimming Pool Stadium Drive
Thomasville Library 14 Randolph Street

Each of these facilities is inspected annually and any new facilities will be added to the inspection list.

Thomasville Memorial Park Swimming Pool

City of Thomasville Stormwater Annual Report
2019 - 2020
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City staff with the greatest exposure to stormwater are trained on PPGH once annually. Planned training
in 2020 was cancelled due to statewide COVID-19 restrictions. Training is combined with illicit discharge
detection and elimination training. The PPGH portion of the training concentrates on good
housekeeping functions. This often includes identification of bad habits that can take place and how to
fix the situation to reduce the risk of pollution to stormwater.

IDDE/PPGH Training
Thomasville Fire Station 22
City of Thomasville Stormwater Annual Report
2019 - 2020
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The City of Thomasville sweeps streets annually through the City’s street department and it is estimated
that the total is 529.52 miles are covered annually and that 206 tons of debris was picked up. The debris
is roughly 75% inorganic and 25% organic. Streets are swept March through November, 6.5 miles weekly
and an additional 15.96 miles monthly.
The City of Thomasville normally puts out road salt and alternatives to road salt. In 2019 the city used 2
tons of sand, 1,800 lbs. of salt and 1000 gallons of salt brine solution. The City also recycled 1500 gallons
of oil through the heating of the Fleet Services Facility.
The City cleans culvert pipes and drainage ditches on an as requested basis and cleans storm drains
ahead of predicted large precipitation. Culvert pipes are cleaned by jet truck, ditches by backhoe and
hand and inlets by hand as needed.
Currently the City does not maintain or have any Pet waste stations.
Impaired Waters and Total Maximum Daily Loads (TMDL)
The City of Thomasville has significant issues with impaired waters and the City drains to two different
TMDL protected waters. The impaired streams are Rich Fork Creek, Hamby Creek, North Hamby Creek
and Hunts Fork. The TMDL’s are for Turbidity in High Rock Lake and for Fecal Coliform in Rich Fork Creek
and Hamby Creek. The TMDL for Rich Fork and Hamby Creek’s specifically lists Sanitary Sewer Overflows
as a source of fecal coliform in the streams and the City has dedicated its resources to limiting SSO’s
from the Collection System in order to improve the water quality within these streams (see above
section on IDDE and the future Inflow/Infiltration/Exfiltration Report). Some details about the impaired
streams are included below:
• Rich Fork Creek (12-119-7b) is impaired for Fecal Coliform and for Ecological and Biological
Integrity of the Fish Community. Rich Fork Creek has significant water quality problems as it
drains High Point as well as Thomasville. The City of Thomasville is working to comply with the
TMDL by improving the collection system within Thomasville.
• Hunts Fork (12-119-7-3) is impaired for Ecological and Biological Integrity of the Benthic
Community. Hunts Fork is directly upstream of Rich Fork Creek and the City is working to
improve the collection system within this watershed.
• Hamby Creek (12-119-7-4a) is impaired for Fecal Coliform and for Ecological and Biological
Integrity of the Fish Community. Hamby Creek has significant water quality problems as it drains
High Point as well as Thomasville. The City of Thomasville is working to comply with the TMDL
by improving the collection system within Thomasville.
• North Hamby Creek (12-119-7-4-1) is impaired for Ecological and Biological Integrity of the
Benthic Community. North Hamby Creek is directly upstream of North Hamby Creek and the City
is working to improve the collection system within this watershed.
City of Thomasville Stormwater Annual Report
2019 - 2020
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High Rock Lake Rules
The City of Thomasville is within the High Rock Lake Watershed. High Rock Lake is impaired for elevated
levels of turbidity, chlorophyll a, and pH. The chlorophyll a and pH impairments are primarily associated
with excess algal growth, which is caused by elevated nutrient loading to the lake (primarily nitrogen
and phosphorous). The turbidity impairment is also related to the algal growth within the lake but is
primarily due to upstream sedimentation to the lake. The Lake has a drainage area of 3,974 square
miles, although a portion of that watershed (367 square miles) is within the Kerr Lake watershed. The
dam for High Rock Lake is about 25 miles from the center of Thomasville and Thomasville is one of
several urbanized centers within the watershed. The other urbanized areas include Winston-Salem,
Salisbury, High Point, and Lexington.

High Rock Lake Watershed from Watershed Model - NC DENR
NC DEQ has been working on potential solutions to improve water quality within High Rock Lake for
several years and expects to develop the Nutrient Management Strategy. High Rock Lake is listed as the
number one priority on the State of North Carolina’s Nutrient Development Criteria Plan but is currently
on hold due to NC DEQ staffing restrictions. The City of Thomasville should be heavily involved in the
stakeholder process and should evaluate how it’s improvements to its Collection System may already be
contributing to improving water quality within downstream waters.
City of Thomasville Stormwater Annual Report
2019 - 2020
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Stormwater Funding
The City of Thomasville funds it’s Stormwater Programs through a Stormwater Fee. The City collects a
flat fee of $1/month from utility users. This fee produces $103,380 annually. The City uses this fee to pay
for its Water Quality Programs including its NPDES Phase II and Inflow/Infiltration/Exfiltration Program
and/or studies. The City’s Stormwater Budget for the 2019 Calendar Year is $114,627 and the City plans
to use accrued stormwater balance for future stormwater specific projects.
In the future, the stormwater budget may need to increase to fund additional improvements. These
increases may be offset by converting the current flat fee into an Existing Residential Unit (ERU) style
fee. The ERU is based on an impervious area per property calculation and will be a more equitable
distribution of stormwater costs than the flat fee is. However, the ERU will have a substantially higher
startup and maintenance costs than the current fee has.
The Future of Stormwater
Stormwater, and Water Quality in particular, is an evolving field of regulation. The City of Thomasville is
already involved in NPDES Phase II, Biological Integrity within streams, and will soon be involved in
Nutrient Sensitive Waters with High Rock Lake. Within the next decade the City needs to plan for further
regulation of these issues as well as several other outstanding issues. EPA continues to work on two
potentially large future items that include a Numerical Nutrient Criteria for all surface waters and a
National Stormwater Rule. The Numerical Nutrient Criteria is an EPA supported push towards
establishing nutrient limits for all surface waters. Currently in North Carolina, generally only reservoirs
have nutrient limits and the limits are based upon response indicators.
Stormwater Program Contacts
Name Position Phone # Email
Kelly Craver City Manager [phone] [e-mail]
Daryl Poole Public Works Director [phone] [e-mail]
Josh Johnson Stormwater Engineer [phone] [e-mail]