NCS000248_Greensboro 2020 Annual Report_20201023

CITY OF GREENSBORO
NPDES MS4 STORMWATER DISCHARGE PERMIT

Permit # NCS000248

STORMWATER QUALITY MANAGEMENT PROGRAM PLAN
2019/2020 Annual Report

Prepared for:

North Carolina Department of Environmental Quality
Division of Energy, Mineral & Land Resources
Stormwater Permitting Unit
1617 Mail Service Center
Raleigh, North Carolina 27699-1617

Prepared by:

City of Greensboro
Water Resources Department - Stormwater Management Division
P.O. Box 3136
Greensboro, NC 27402-3136

October 31, 2020

TABLE OF CONTENTS

Page
Executive Summary 1

Significant Receiving Waters and Watersheds 1

Organizational Structure 3

Legal Authority 4

Funding 5

Stormwater Quality Management Program Plan 6

Public Education and Outreach Program 6
BMP Summary Table 6
Target Audience 8
Identifying Pollutants and Target Sources 9
Public Outreach Narrative Program 9

Public Involvement and Participation 10
BMP Summary Table 10
Target Audience 11
Participation Program Narrative 11

Illicit Discharge Detection and Elimination 12
BMP Summary Table 12
Detection and Elimination 13
Locating Priority Areas 13
Removing Sources of Illicit Discharges 14

Construction Site Stormwater Runoff Control 15
BMP Summary Table 15
E&SC Plan Review 15
E&SC Program Implementation and Enforcement 15
Construction Site Inspections 16

Post-Construction Stormwater in New and Redevelopment 17
BMP Summary Table 17
Local Permit Issuance 19
Structural SCM Operation and Maintenance 20

Pollution Prevention/Good Housekeeping for Municipal Operations 21
BMP Summary Table 21
Affected Operations 22
Training 22

Site Inspection and Evaluation of Facilities 25
Maintenance and Inspections 24
Vehicular Operations 24
Waste Disposal 24

Program to Monitor and Evaluate Stormwater Discharges to the Municipal System 25
BMP Summary Table 25

Water Quality Assessment and Monitoring Program 26
BMP Summary Table 26

Total Maximum Daily Load (TMDL) 27
BMP Summary Table 27
BMP Narratives 30
Identify, Describe and Map Watershed, Outfalls, and Streams 30
Existing Measures 32
Additional Measures 33

Threatened or Endangered Species Protection Program 34

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 1 of 34

Stormwater Quality Management Program Plan (Stormwater Plan)
for
Greensboro’s NPDES MS4 Discharge Permit

EXECUTIVE SUMMARY

The City of Greensboro’s initial National Pollutant Discharge Elimination System (NPDES) Municipal
Separate Storm Sewer System (MS4) Discharge Permit (Permit Number NCS000248) became effective on
December 30, 1994. The North Carolina Department of Environmental Quality (NCDEQ) issued the City of
Greensboro’s current permit on October 10, 2018, for a period of five years with an effective expiration date
of October 9, 2023. This document includes a summary of NPDES stormwater quality management
programs and activities implemented, scheduled to be implemented, or completed during the July 1, 2019 -
June 30, 2020 permit term.

The City’s NPDES stormwater permit, and associated Stormwater Quality Management Program Plan
(Stormwater Plan), is designed to control the discharge of pollutants from the MS4 to the Maximum Extent
Practicable (MEP).

Significant Receiving Waters and Watersheds
Greensboro is located near the headwaters of the Cape Fear River Basin in the Piedmont physiographic
region of North Carolina, with a majority of the City’s jurisdictional watersheds draining eastward towards
the Haw River, while a smaller portion of the City area drains south towards the Deep River. The North and
South Buffalo Creek Watersheds drain the majority of the City’s central urbanized area eastward towards
Buffalo Creek. Beyond the eastern City limits, Buffalo Creek drains generally northeastward into the Reedy
Fork Creek and the Haw River, a tributary of the Jordan Lake watershed. The City of Greensboro, with a
total area of about 131.94 square miles, represents just over 1% of the 9,322 square mile Cape Fear Basin.
Existing land uses within Greensboro are broadly classified in Table 1.

Table 1 – Land Uses in the City of Greensboro

Land Use Classification Approximate % within Corporate Limits
Residential 39%
Commercial 13%
Industrial 7%
Open Space/Wooded/Undeveloped 41%
Total (land use does not include public streets and water bodies) 100%

Table 2 shows a listing of the primary streams located within the City of Greensboro MS4 service area.
Water quality classifications of receiving streams are provided, along with their use support ratings and
key water quality challenges.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 2 of 34

Table 2 - Primary Receiving Streams within Greensboro Service Area (Upper Cape Fear River
Basin)

Receiving
Stream Name
Stream
Segment
Water Quality
Classification*
Use
Support
Rating
Water Quality Issues

303(d) List
Reedy Fork
Creek
Within
corporate limits
WS-III;NSW,
WS-III;NSW CA Impaired
Impaired biological
integrity, Chlorophyll a,
Turbidity
yes
Brush Creek Within
corporate limits WS-III;NSW Impaired Impaired biological
integrity, Chlorophyll a
Yes
Horsepen
Creek
Within
corporate limits
WS-III;NSW,
WS-III;NSW CA Impaired Impaired biological
integrity
Yes
North Buffalo
Creek
Within
corporate limits WS-V;NSW Impaired
Fecal coliform,
Impaired biological
integrity, Zinc, Cooper,
NO2+NO3-N
Yes
South Buffalo
Creek
Within
corporate limits WS-V;NSW Impaired
Turbidity, Impaired
biological integrity,
Zinc
Yes
East Fork
Deep River
Within
corporate limits
WS-IV, WS-
IV;CA Impaired
Impaired biological
integrity, Turbidity,
Fecal coliform
Yes

* Water Quality Classifications:
NSW = Nutrient Sensitive Waters
WS = Water Supply classification (degree of protective measures).
C = Class C waters – general use category (maintain aquatic life and biological integrity, wildlife, secondary
recreation, etc.)
CA = Critical Area

** Use Support Rating (the degree to which the water body supports its designated uses):
FS = Fully Supporting
PS = Partially Supporting
NS = Not Supporting
NR = Not Rated

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 3 of 34
Organizational Structure
The Stormwater Management Utility is one of seven divisions of the City’s Water Resources Department
(also including water supply, water reclamation, customer service, business, engineering, and operations and
maintenance). This organizational arrangement facilitates protecting and improving surface water quality
while best managing local water resources.

The following bullet points briefly document the overall organizational structure and functional
responsibilities of the City’s Stormwater Plan. Although the Stormwater Management Division resides
within the Water Resources Department, the program itself is much broader and encompasses and/or extends
well beyond the boundaries of the Water Resources Department. Several other departments in the City of
Greensboro, as well as those in Guilford County, contribute to stormwater quality management and NPDES-
related programs in substantive ways.

• City Stormwater Management Division: NPDES MS4 Discharge Permit administration for
Greensboro; stormwater utility administration; surface water quality monitoring and operations
management; computerized infrastructure management systems; stormwater and surface water quality
related complaint response; stormwater conveyance system inventory and detailed MS4 outfall
mapping; public education and awareness; stormwater and watershed master planning; site
development plan reviews for stormwater management; general stormwater-related technical support
and mapping; local Federal Emergency Management Agency (FEMA) National Flood Insurance
Program (NFIP) floodplain administration; local water supply watershed protection program
administration; stormwater control measures (SCM) evaluations and SCM crediting; SCM inspections
and monitoring; field screening and follow-up monitoring activities; industrial monitoring and related
activities; industrial inspections and educational efforts; system inspection; special stormwater
inspection and enforcement programs; water quality inspections and monitoring programs; overall
authority (as delegated from City Manager’s Office) over the municipal stormwater quality
management programs

• City Field Operations Department: Litter (including floatables) and loose-leaf collection programs;
street cleaning and sweeping programs; closed drainage infrastructure system routine and remedial
maintenance activities; open channel maintenance; new storm sewer construction

• City Engineering and Inspections Department: Project design, construction contract bidding,
construction contract administration, and inspections of new development and redevelopment;
stormwater capital improvement projects and property acquisition; local construction erosion and
sedimentation control program administration

• City Parks and Recreation Department: City of Greensboro parks, greenway and utility easement
maintenance coordination and programs; partner in volunteer programs such as Adopt-a-Park

• City Planning Department: Overall City planning including management of plan review process;
comprehensive planning; management of City’s Technical Review Committee (TRC) for design
engineers and developers; zoning management and ordinance development and revisions

• City Water Resources Department (beyond Stormwater Division): Enhancements to the municipal
stormwater system and receiving waters by controlling sanitary sewer overflows (SSOs) and industrial
spills; pretreatment programs for major industry; water supply and wastewater treatment programs,
including planning and management; water distribution system and sanitary sewer system
maintenance programs

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 4 of 34
• City Fire Department: Spill response program - HAZMAT (HAZardous MATerials) Team,
containment of spills; industrial site inspections

• City Management Information Systems Department: Data management including city Geographic
Information Systems (GIS) and city database administration; city computer systems management;
aerial photography and related city mapping programs

• City Legal Department: Permit-related legal, enforcement and ordinance assistance; other legal
services including contract and agreement reviews

• (Guilford County) Emergency Management / Health Department: County emergency
management programs, chemical control; county spill response, coordinate cleanup & reporting

Legal Authority
The required legal authorities for Greensboro’s NPDES municipal stormwater program were developed
and adopted during the first permit period in a new ordinance to the Greensboro Land Development
Ordinance: Chapter 30 – City of Greensboro Stormwater Management Ordinance
(http://online.encodeplus.com/regs/greensboro-nc/doc-viewer.aspx#secid-144). The stormwater
management ordinance became effective on July 1, 1994.

The Chapter 30 ordinance includes the following objectives:
• To provide for the establishment and enforcement of the City's Stormwater Management Program;
• To reduce the discharge of pollutants to the storm sewer system to the maximum extent
practicable by requiring, where appropriate, the use of best management practices, structural
and/or nonstructural stormwater quantity and quality control measures and other provisions;
• To provide for the inspection and proper maintenance of structural and nonstructural stormwater
controls and the municipal separate storm sewer;
• To prohibit non-storm water discharges to the City storm sewer and require the removal of illicit
connections to the City storm sewer;
• To prevent improper disposal of materials that degrade water quality;
• To permit sampling and monitoring for pollutants such as those associated with illicit discharges,
improper disposal, industrial and construction activities, and the application of pesticides,
herbicides, and fertilizers; and,
• To reduce erosion associated with stormwater runoff;
• To provide legal definitions for user fee rate calculations.

To date, no significant changes have been required or considered for the City’s legal authority related to
NPDES stormwater program implementation. Stormwater Management, working with City Management,
Council, and Stakeholders has incorporated runoff quantity control and citywide stream buffer requirements
into the Code of Ordinance in recent years, but these have not been specific NPDES MS4 discharge permit
requirements. Many of these additional requirements along with historic stormwater related regulations are
located throughout the Code of Ordinance with a large portion appearing in Chapter 30 which serves as the
City’s Unified Development Ordinance. Additional ordinance language specific to the Phase II rules,
specifically with regard to post-construction runoff, was adopted by City Council on April 7, 2009, and
became effective June 1, 2009.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 5 of 34
Funding
The City established a stormwater utility funding mechanism partially in response to the initial and ongoing
requirements of the NPDES municipal stormwater permit, but also to help ensure a dedicated funding source
for stormwater-related programs and activities, along with the desire to manage municipal stormwater issues
in a more proactive and comprehensive manner. As impervious area is generally in direct correlation with
the volume and quality of surface stormwater runoff, establishing the stormwater billing system based on
total impervious area is equitable to all of the City’s utility customers. As of January 1, 2004, single-family
residences are charged one of three tiers with an average rate of $2.70 per month. Non-single-family
properties are billed based upon the number of equivalent residential units (ERUs), which is computed by
dividing the total impervious area by the size of the ERU (2,543 square feet), on the given property.

Additionally, as a financial incentive for non-structural and structural best management practice
implementation at non-single-family residential sites throughout the City, Greensboro provides a fee
crediting mechanism within the stormwater utility. The City also provides technical support and educational
assistance for innovative stormwater practices.

The Stormwater Utility is a dedicated balanced enterprise fund with budgeted revenues and expenditures of
just over eleven million dollars in the coming fiscal year. This budget represents a slightly higher than
normal budget due to an extra investment in capital projects this fiscal year. The chart illustrates the
allocation of Stormwater Utility funds by operational category.

Administration
6%
Operations
Management
4%Water Quality &
Monitoring
6%Planning &
Engineering
3%
Public Education &
Awareness
1%
Maintenance
23%
Street
Cleaning
16%
Construction
41%
Stormwater FY 2019-2020 Budget Expenses
$14,289,696

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 6 of 34
STORMWATER QUALITY MANAGEMENT PROGRAM PLAN

The following information is the City’s stormwater quality management program plan (Stormwater Plan)
identifying programmatic measures to comply with the City’s NPDES permit to the maximum extent
practicable. BMP summary tables for each of the regulatory areas are provided, along with narrative for
key programs and updates or accomplishments completed during the last permit year (July 1, 2019 - June
30, 2020).

Public Education and Outreach

BMP Summary Table

BMPs for Public Education and Outreach Program
BMP Measurable Goals Comments
Pollution
Prevention
Brochures
Distribute brochures through event displays, billing
inserts, volunteer participants, new customer packets
at Customer Service counter, informational displays,
field representatives and direct mailings to target
groups. Various issues addressed include proper
disposal of oil and other toxic materials, sediment and
erosion control issues, proper application and handling
of fertilizers and pesticides, litter prevention, pollution
reporting and awareness, etc. for different age groups.
Brochures were
distributed to
approximately 1,000
individuals at organized
events attended by the
City in addition to 55
individuals attended by
organized events attended
by Stormwater SMART.
Bill inserts were sent to
85,000 households with
FOG and Flooding
information three times.
Website Maintain the Stormwater Management Website.
Contains information about pollution prevention,
stormwater technology and practices. Provides
contacts and forms for pollution reporting and
information requests.
Throughout the year
updates were made as
needed.
http://www.greensboro-
nc.gov/stormwater
Stormwater
Videos
Several videos have been created to educate residents
and school children about various pollution prevention
measures and volunteer opportunities. Videos air
periodically on Greensboro Television Network
(GTN) that appears on the local cable affiliate, while
others air on local stations 2, 8, 12, and Spectrum
Cable as part of an advertising campaign.
Stormwater SMART
PSA’s were adapted to
meet Greensboro’s needs
and they were promoted
at the No Straw
November Kick-Off
event, on the City’s
YouTube as well as in
Ads via Media Placement
Services (MPS).

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 7 of 34
BMP Summary Table – Continued

Media
Campaign
Advertise on TV, cable, Facebook, and Instagram
about different Stormwater related topics. In addition,
advertise pollution issues in the local Hispanic
newspaper La Noticia and in the City of Greensboro
resident newsletter “At Your Service”.
MPS Ads – Yard Waste
(196 ads with 6,444,173
impressions across TV,
Cable, Facebook,
Instagram and Google
Display), Fats, Oil and
Grease 103 ads with
4,000,707 impressions
across TV, Cable,
Facebook, Instagram and
Google Display) and
Hazardous Waste (186
ads with 5,446,884
impressions across TV,
Cable, Facebook,
Instagram and Google
Display)
Helpline Established a helpline for citizens to report pollution,
address water quality and drainage concerns, as well
as volunteer opportunities.
114 Water Pollution
Spills and Concerns were
reported with 22 via the
city helpline
138 visits to the Report
Water Pollution webpage
349 Drainage Concerns
reported
285 visits to the Report
Drainage Concerns
webpage
School and Civic
Group
Presentations
Develop and present educational talks and activities
for schools and civic groups, including our
Enviroscape Model.
Approximately 1,000
individuals were reached
by the City’s Stormwater
program in addition to
approximately 1,342
from the Stormwater
SMART program.
Targeted
Commercial
Education
Initiative
Develop flyer /brochures to inform businesses that
have a potential of illicit discharges or improper
disposals to the stormwater conveyance system.
Ongoing effort by the
Stormwater Program;
program initiated in Mid-
2003. See page 13 for
details.
Watershed Signs Road signs have been installed at stream crossings
identifying the watershed and stream name.
Ongoing effort by the
Stormwater Program.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 8 of 34
BMP Summary Table – Continued

Cooperative
Efforts
The City of Greensboro seeks reasonable
opportunities to collaborate with
neighboring communities for joint
educational programs. Previously the
partnership was with the Piedmont Triad
Water Quality Partnership (PTWQP)
however; the city is now a member of
Stormwater SMART and receives direct
education and mass media services through
the partnership. The North Carolina
Cooperative Extension Services and
Guilford County Soil and Water
Conservation District are also partners in
Stormwater education.
Maintained partnerships and scheduled
events/programs that were later
canceled due to COVID.

https://www.ptrc.org/services/regional-
planning/stormwater-smart
https://www.ces.ncsu.edu/
https://www.guilfordcountync.gov/our-
county/planning-development/soil-and-
water-conservation

Target Audience
Current and future target audiences for stormwater education include:
1. General Public, especially homeowners – applies lawn care products, uses chemicals for home and
auto maintenance, makes decisions about drainage issues on their properties and participates in
volunteer opportunities.
2. Structural SCM Owners – maintenance issues and education about proper SCM maintenance and
responsibilities.
3. Industries – potential of water quality impacts due to improper material handling, improper
housekeeping practices and illicit discharges.
4. Commercial landscapers, restaurants, mobile washers, concrete companies, painters, drywall
installers, masons, automotive repair facilities and kennels – potential water quality impacts due to
illegal dumping of wastewater into storm drains and improper chemical handling and application.
5. School age children are educated about the importance of protecting water quality through the
distribution of elementary school homework folders and outreach opportunities in our local school
system. Our sponsorship ad in this school year provided an opportunity for us to reach over 2,100
students, their families and caregivers. In partnership with Guilford County Soil and Water
Conservation District over 141 middle and high school students studied and registered for the NC
Area III Envirothon. The Envirothon was canceled due to COVID-19.
6. Through the City’s Education and Outreach programs, over 1,104 individuals were reached
through school programming, summer camps, library programs, and more. A robust social
(Facebook, Twitter, & Instagram) media campaign landed over 9,316,964 impressions (views),
and a five-month mass media (video on local cable channels) campaign had 4,286,000
impressions.
7. Through our partnership with Stormwater SMART, over 1,372 individuals were reached through
school programming, summer camps, library programs, and more. Over 66 hours of direct public
education was provided through this partnership. A robust social (Facebook, Twitter, &
Instagram) media campaign landed over 5,000 engagements for 445 posts, and a five-month mass
media (video on local cable channels) campaign had 159,446 impressions. In the 2020 Spring
BioThon (May 13 – June 19, 2020) an online alternative to Creek Week, 143 observations were
submitted by individuals or families in Guilford County.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 9 of 34

Identifying Target Pollutants and Sources
Target pollution sources for stormwater education include:
1. Illicit Connections – The discharge of non-stormwater into the stormwater conveyance system can
result in biological mortality in receiving streams due to discharges.
2. Improper Disposal – The discharge of used motor oil, oil & grease, organic materials (grass and
leaves), and various other pollutants into storm drains can be a problem on construction sites,
commercial and residential areas, etc.
3. Water Quality Monitoring – Routine water quality monitoring data will be evaluated to identify target
pollutants which impact water quality.
4. Pet Waste – Greensboro has developed a TMDL for fecal coliform for the portion of North Buffalo
Creek located within the jurisdictional limits. As a management measure, the City will generate
educational literature targeting pet owners on the need to pick up after their pet in order to protect
water quality. Additionally, staff has observed that a number of public parks and homeowner’s
associations have installed pet waste bag dispensers and or signage to encourage proper disposal of
pet waste. As a part of the At Your Service program, information was sent out to residents regarding
the proper way to dispose of pet waste.
5. Lawns and Gardens – Lawn care chemicals may enter storm drains due to improper application. Yard
waste may also be improperly placed into storm drains. These can create blockages in the stormwater
conveyance system and cause decreased dissolved oxygen in streams. The Clean Streams Program
educates commercial landscape professionals on the proper application of fertilizer and pesticides, as
well as aquatic pesticides. Commercial landscape professionals have an opportunity to receive
pesticide credit for successful completion.
6. Auto Repair Shops – Many auto repair shops have interior drains that have the potential to be
illicit connections (such as older buildings or sites that were previously a different business type).
As these locations are identified and dye-testing is conducted, owners and staff are made aware of
proper house-keeping practices, including awareness of interior drains and their resulting
destinations (i.e., either storm or sanitary sewers).
7. Mobile Auto Washers – car washing activities can generate potentially harmful wash water. An
educational and inspection program targeting mobile auto washers on containment, collection, and
disposal of wash water has been developed.
8. Restaurants – Many restaurants have Good Housekeeping issues related to disposal of cooking oil,
process wastewater generated by cleaning activities, and outdoor storage areas such as trash
dumpsters and grease containers that can adversely impact water quality. An educational and
inspection program targeting restaurants has been developed and implemented during this
reporting period.

Public Outreach Program Narrative
Outreach mechanisms are described in the BMP summary table above. Over the permit period,
Greensboro expects to reach the majority of the approximately 287,000 individuals in its MS4 service
area, as well as individuals in surrounding service areas. Everyone who receives a water/sewer bill will
occasionally receive stormwater education messages in the City’s citizen newsletter, for example, the “At
Your Service” newsletter. Individuals are also periodically exposed to various stormwater related
messages that are shown on our local governmental broadcast station. For those who do not receive a bill
or do not read the newsletter, various media campaigns are featured on TV, radio, and newspaper.
Combined together, the media outlets are designed to reach the citizens of Greensboro. For citizens who

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 10 of 34
speak Spanish, some materials will be printed in English and Spanish. The City also utilizes a local
Spanish radio station and newspaper to deliver various educational messages.

Public Involvement and Participation

BMP Summary Table

BMPs for Public Involvement and Participation Program
BMP Measurable Goals Comments
Adopt-a-Stream Developed an Adopt-a-Stream Program.
Volunteers must pick up trash from their adopted
segment of stream twice per year.
26 cleanups
830 volunteers
Drain Marker
Program
Developed a Drain Marker Program. Volunteers
have attached signs to Greensboro’s storm drains.
1 event
20 drain markers installed
Adopt-a-Street Developed an Adopt-a-Street Program.
Volunteers must pick up trash from their adopted
segment four times per year.
65 cleanups
594 volunteers

Stormwater
Advisory Board
Board established to help guide Stormwater
program on important community issues.
Stormwater Advisory Board
reconvenes as needed to
address community issues.
Annual Clean-up
Events
Promote the Great American Clean-up, NC Big
Sweep, and Guilford Creek Week.
The Great American Clean-up
and Guildford Creek Week
were canceled due to COVID
but The Big Sweep was
promoted at a few events and
did occur with over 30 clean
ups.
Poster Contest

Water quality, water conservation and soil
conservation poster contest available for
elementary students in the Guilford County
School System.
Staff vacancies prevented the
participation of the contest
this year.
Neighbor Woods
Program
Developed a Neighbor Woods Program, which
encourages community wide tree planting and re-
vegetation efforts.
166 trees planted
Educational
Workshops
Power of Wetlands (POW), Wonders of Wetlands
(WOW) and Project Water Education for
Teachers (WET) workshops offered as a resource
for educators.
All planned workshops were
scheduled for the 2nd half of
reporting year and were
canceled because of COVID-
19.
Household
Hazardous Waste
Collection
Promote proper disposal of harmful chemicals
through the Household Hazardous Waste
Collection Center.
1,900,314 lbs. of chemicals
were collected for Guilford
County. Approximately 75%
is from City residents.
Fats, Oils, and
Grease Inspection
Program
Program designed to prevent the excessive
introduction of oil, grease, and fats into the
sanitary sewer system and the wastewater
collection system, which helps prevent sanitary
sewer over flows.
Over 10,000 door hangers
were distributed as well as ads
with MPS contract, SWARM
games and other events
throughout the year.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 11 of 34
Target Audience
Target audiences for the public involvement program include representative age, ethnic, and economic
groups in Greensboro, from individuals to businesses. For local citizens who speak Spanish, some materials
to promote volunteer programs are printed in both English and Spanish. A local Spanish radio station and
newspaper will also be used for advertising on select campaigns.

Participation Program Narrative
The public is involved in the City’s Stormwater Management Program. The following are ongoing
programs that are available in the community.

• Public Hearings
Public hearings are held to address key programs, such as, stream corridor concerns in the
community including restoration projects. Additionally, City Council meetings serve as
public hearing opportunities.

• Working with Citizen Volunteers Willing to Educate Others About the Program
As part of the drain marker program, for example, volunteers hang an information piece on
the mailboxes of neighborhood residents where drain markers are installed.

• Volunteer Monitoring or Stream Clean-up Activities
As part of our Adopt-a-Stream Program, volunteers are asked to note stream conditions on
their reporting form. The volunteers are required to clean the stream twice per year. Many
also participate in the NC Big Sweep, along with many others who have not formally
adopted a stream.

• Flood Advisory Committee
As part of the National Flood Insurance Program (NFIP) Community Rating System
(CRS), communities are challenged with reducing the impact of flooding on private and
public structures. The flood advisory committee was formed through a partnership with
Guilford County Planning Department to communicate important messages. Topics
covered include discussions about flood hazards, flood safety, flood insurance and vital
ways to protect property, and natural floodplain benefits.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 12 of 34
Illicit Discharge Detection and Elimination
The City of Greensboro maintains a program to identify and eliminate illicit discharges and improper
disposals from its MS4 service area.

BMP Summary Table

BMPs for Illicit Discharge Detection and Elimination (IDDE) Program
BMP Measurable Goals Comments
Implementation and
enforcement of
Stormwater Management
Ordinance
Enforce current Stormwater Management
Ordinance (Chapter 30 of the Greensboro
Land Development Ordinance) requirements
pertaining to the illicit discharge and improper
disposal of pollutants and waste.
Ongoing program by the
Water Quality Section;
Stream water quality
monitoring
Conduct routine chemical and physical water
quality sampling of major streams. Analyze
data, detect potential illicit discharges, and
prioritize locations for follow-up investigation.
Ongoing program by the
Water Quality Section
Response and
investigation of citizens’
concerns
Maintain dedicated helpline and field calls
related to pollution concerns and
environmental questions from citizens.
Provide staff response to pollution concerns.
Ongoing program by the
Water Quality Section;
Public Education and
Awareness Section; City
Contact Center
Develop and maintain
storm sewer system
inventory base map of
major outfalls
Create map and inventory procedures for the
collection of major outfalls that discharge to
waters of the State.
Ongoing program by the
Stormwater Management
Division, Field
Operations Section
Maintain an inventory of
major outfalls that
discharges to waters of
the State
Maintain an inventory of major outfalls that
discharges to waters of the State.
Inventory complete;
ongoing collection for
annexations and new
developments:
Stormwater Management
Division.
Establish procedures to
identify and eliminate
failed septic systems and
sanitary sewer overflows.
Establish and maintain procedures to identify
and report failed septic systems or sanitary
sewer overflows to the appropriate agency
(County health department or local utility
department).
Ongoing program by the
Water Quality Section

Maintain
Inspection/detection
program to detect dry
weather flows at MS4
outfalls
Maintain procedures for detecting and tracing
the sources of illicit discharges to the MS4 and
for removing the sources.
Ongoing program by the
Water Quality Section

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NPDES Permit No. NCS000248 Page 13 of 34
BMP Summary Table – Continued

Inter-departmental spill
response team
Maintain cooperative agreement and improve
relationship with spill response team partners.
City Fire and Police are primary responders,
while Stormwater is a secondary responder to
assist in tracking spills and assessing
environmental damage as a result of
environmental emergencies.
Ongoing program by the
City’s Fire & Police as
primary responder. City’s
Stormwater Division as
secondary.
Commercial/Business
education and inspection
program
Develop and implement education and
inspection program to inform local businesses
of stormwater regulations, hazards of unlawful
discharges, and penalties for violations.
Ongoing program by the
Water Quality Section.
During the reporting
period, preparations were
made to begin educating
the next business group:
directional drillers.
Education and outreach
programs
Continue ongoing programs and develop new
programs to inform municipal employees,
local businesses, and the general public of the
hazards associated with illicit discharges and
improper disposal of pollutants and waste.
Ongoing program by the
Water Quality Section;
Public Education and
Awareness Section

Detection and Elimination
Greensboro continues to implement a comprehensive program of stormwater ordinance enforcement,
water quality monitoring, education and outreach, spill and citizen complaint response, and formal
inspections in order to prevent, detect, address, and eliminate illicit discharges and improper disposals to
the storm sewer system and receiving waters. The ongoing detection and elimination program currently
includes the following specific tasks:
1. Conducting stream water quality monitoring activity and conducting immediate follow up
when the data suggests a water quality issue.
2. Maintaining a helpline for citizen complaint reporting.
3. Providing professional staff response to citizen reports and complaints.
4. Secondary participation in cooperative spill response team with inter-governmental partners.
5. Development of a formal commercial and business education and inspection program.
6. Conducting stormwater investigations at industrial facilities.
7. Conducting field screening of NPDES MS4 outfalls to detect dry weather flows.
8. Continuation of ongoing educational efforts for municipal employees and general public.

Locating Priority Areas
To locate priority areas for illicit discharge investigations, Greensboro will continue to rely on a
combination of water quality monitoring, inspections, complaints or notifications from citizens and city
staff, and historical knowledge to locate and verify priority areas. Permanent sampling stations will
continue to be located within Greensboro’s major watershed sub-basins, and field and laboratory water
quality parameters will be analyzed to detect potential illicit discharges and prioritize locations for follow-
up investigation.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 14 of 34
Removing Sources of Illicit Discharges
Greensboro’s Land Development Ordinance (Chapter 30) specifically prohibits the illicit discharge or
improper disposal of pollutants and waste to Greensboro’s stormwater conveyance system and subsequent
receiving surface waters. This ordinance authorizes City staff to utilize enforcement action, when
necessary, to stop an illicit discharge, remove the source, and require cleanup of the impacted area.

According to Stormwater’s Administrative Procedures for Completing an Enforcement Action, the source
of an illicit discharge may be removed through a series of educational efforts, written Notices of
Violations (NOV), or progressing to civil penalty, if necessary . Once the source and responsible party of
an illicit discharge or improper disposal is identified, an appropriate educational letter or NOV is mailed.
Discontinuation of the discharge is required by the NOV, and the responsible party is required to reply in
writing to Stormwater staff detailing efforts taken to discontinue the unlawful activity and prevent the
activity from occurring in the future. Staff then conducts a follow-up investigation to ensure compliance.

During the July 1, 2019 to June 30, 2020 reporting period, 114 illicit discharges, spills, or concerns were
reported, investigated or educated. Of the 114, 61 required further investigation and were ultimately
eliminated. Fifteen (15) of those investigated illicit discharges resulted in an issuance of a Notice of
Violation (enforcement action). One Notice of Violation resulted in the issuance of a civil penalty for
$1,625.

In addition to the standard citizen reporting procedure such as the City Call Center, City Stormwater
program has an inspection and education program that during routine operations proactively addresses
small commercial businesses that are identified as having the potential to impact water quality. During the
July 1, 2019 to June 30, 2020 reporting period, preparations were made to educate horizontal directional
drillers. These preparations included creating educational material, working with other divisions in Water
Resources to identify businesses contracted for this type of work, talking with major fiber optic
companies regarding improper disposals, drafting a plan for field education, etc. Implementation is set to
take place within the next few months.

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NPDES Permit No. NCS000248 Page 15 of 34
Construction Site Stormwater Runoff Control
The City of Greensboro has a locally delegated Erosion and Sediment Control (E&SC) Program
implemented by the Erosion and Sediment Control Section of the Engineering and Inspections Department.
The E&SC Section is responsible for erosion control plan review, grading permits, erosion control
inspections, enforcement, and review of permanent stabilization of commercial development. A Chief E&SC
Inspector and two field inspector(s) comprise the section.

BMP Summary Table

BMPs for Construction Site Stormwater Runoff Control
BMP Measurable Goals Comments
Plan Review, Enforce current
E&SC ordinances.
Ongoing program
implementation and
enforcement. The locally
delegated program is regulated
by the NCDEQ, Division of
Energy, Mineral and Land
Resources
Water Resources Dept,
Stormwater Management
Division, E&SC Section.

E&SC Plan Review
In the City of Greensboro, any proposed land disturbance of one or more acre, including common plans of
development that add up to a total of one or more acre, requires a grading permit prior to any land
disturbance. For sites requiring a grading permit, a plan submittal consisting of a grading permit
application, financial responsibility ownership forms, erosion and sediment control plans, and calculations
are required. Plan approval is also required either through the City’s Technical Review Committee, or
through a grading only process that consists of limited reviewers from the Technical Review Committee
prior to grading permit issuance. Once plans are reviewed and approved, a pre-construction meeting is
scheduled and a letter of approval is provided to the financially responsible party. As of April 1, 2019,
information is provided to the permittee on the requirement to obtain a NC DEQ issued certificate of
coverage for the NPDES NCG01 permit.

During the onsite pre-construction meeting, the representative from the erosion and sediment control
section reviews local, state and federal requirements with the permittee prior to issuing the grading
permit. The City then requires and verifies that the certificate of coverage for the NPDES NCG01 permit
is attached to the grading permit located in the permit box. The City also ensures that temporary erosion
and sediment control measures are installed, inspected, and accepted prior to mass grading of the site.
The City of Greensboro also stipulates that any development resulting in less than one acre of land
disturbance indicate proper erosion and sediment control measures on the site plan. These plans are
reviewed and approved by the erosion and sediment control section during the technical review process.
Therefore, all sites developed that go through the City’s Technical Review Committee are reviewed for
compliance with erosion and sediment control regulations.

E&SC Program Implementation and Enforcement
The City of Greensboro employs a variety of mechanisms to ensure compliance with the provisions of the
Soil Erosion and Sedimentation Control ordinance. First, no site will be issued a grading permit until the

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 16 of 34
plan reviewer is certain that necessary sediment and erosion control measures are adequately detailed on the
construction documents. Prior to issuing a grading permit for any site disturbing one acre or more, the City
Code requires that the owner/contractor post a bond. Prior to issuing a grading permit for any site disturbing
one acre or more, City Code requires that the owner/contractor post a bond. If a contractor begins land
disturbance without the required permits, appropriate City staff will issue a stop work order.

Should the field inspector identify deviations from the approved plan during construction, the inspector
may provide an inspection report to the owner and contractor indicating required measures and allowable
timeframe to bring the site into compliance. If the required items are not addressed within the appropriate
time, the inspector may issue a notice of violation (NOV) to the owner. A monetary fine may accompany
the NOV. If the required measures are still not addressed as indicated in the NOV, the inspector may
issue a stop work order. Additionally, the City of Greensboro reserves the right to deny the issuance of a
certificate of occupancy for sites that continue to remain in nonconformance with the erosion and
sediment control regulations.

Construction Site Inspections
Site inspections to ensure that proper erosion control measures are provided on construction sites are
conducted by qualified field inspectors. Each inspector represents a specific area of the City and inspects
sites within this area. Sites may be inspected more often depending on specific site conditions, the
progress of construction, citizen complaints and/or previously identified problems.

As site inspections may occur more frequently based on several factors, these same factors apply to the
prioritization of site inspections. Specific site conditions, contractor experience, citizen complaints,
previous inspections and the progress of construction all impact which site is given priority for inspection
on a more frequent basis. During the site inspection, the field inspector ensures that erosion and sediment
control measures are implemented according to the approved plan and that no significant offsite
sedimentation is occurring. If the inspector recognizes a problem in the field, the inspector may require
that additional erosion control measures be installed and maintained in accordance with established
enforcement procedures.

Included in the chart below is the data on the number of inspections and enforcement actions carried out by
the E&SC Section during the period of July 1, 2019 to June 30, 2020.

INSPECTIONS
Reporting Period: July 1, 2019, to June 30, 2020
Universe of active construction
sites
278 Number of active construction
sites inspected
278
Number of construction sites
found to be non-compliant after
the initial inspection

7
Number of follow-up
inspections
7
ENFORCEMENT
Reporting Period: July 1, 2019 to June 30, 2020
Number of informal enforcement actions noncompliance 7
Number of formal enforcement actions without penalty 2
Number of formal enforcement actions with penalty 5
Number of stop work order issued 5

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NPDES Permit No. NCS000248 Page 17 of 34
Post-Construction Stormwater Management for New Development and
Redevelopment
The City of Greensboro enforces local stormwater management and riparian buffer regulations in addition to
State approved water-supply watershed protection regulations. Throughout the NPDES permit compliance
period, the City of Greensboro will review existing ordinances and, if necessary, develop and implement
revised ordinances in order to implement the post-construction stormwater management program with the
goal of further minimizing impacts to surface water quality. Ordinance language specific to the Phase II
rules, specifically with regard to post-construction runoff, was adopted by City council on April 7, 2009, and
became effective June 1, 2009.

BMP Summary Table

BMPs for Post-Construction Site Stormwater Runoff Controls
BMP Measurable Goals Comments
Post-Construction
Stormwater Management
Program
Develop and adopt by ordinance a
program to address stormwater
runoff from new development and
redevelopment within 24 months
of the permit issue date.
The ordinance was adopted by
City Council on April 7, 2009 and
became effective June 1, 2009.
Strategies which include
BMPs appropriate for the
MS4
Developed strategies that include a
combination of structural and/or
non-structural SCMs implemented
in concurrence with (a) above.
Provide a mechanism to require
long-term operation and
maintenance of structural SCMs.
Require annual inspection reports
of permitted structural SCMs
performed by a qualified
professional.
City of Greensboro Stormwater
Management Manual requires any
proposed structural SCM be
accompanied by an operation and
maintenance plan and agreement
concurrent to development plan
approval. The city has an
extensive inspection program to
ensure SCM’s are maintained to
protect water quality.

Establish nutrient sensitive
waters (NSW) protection
measures (for programs
with development or
redevelopment draining to
NSW waters)
Develop, adopt, and implement an
ordinance to ensure that the best
management practices reduce
nutrient loading to the maximum
extent practicable. In areas where
the Environmental Management
Commission has approved a
Nutrient Sensitive Water Urban
Stormwater Management Program,
the provisions of that program
fulfill the nutrient loading
reduction requirement.
The Greensboro Land
Development Ordinance was
reviewed and modified to ensure
structural and non-structural
SCMs reduce nutrient loading to
the maximum extent practicable.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 18 of 34
BMP Summary Table – Continued

Deed Restrictions and
Protective Covenants
Impose or require recorded deed
restrictions, plats, and/or
protective covenants that ensure
development activities will
maintain the project consistent
with approved plans.
Current City of Greensboro Land
Development Ordinance requires
a maintenance note and recorded
maintenance agreement to be
placed on final plats stating the
maintenance responsibilities,
consistent with approved plans,
for the project SCM.
Establish a program under the
Post-Construction minimum
measure to control the sources
of fecal coliform to the
maximum extent practicable.
Coordinate with County health
department to control the known
sources of fecal coliform from
septic systems to the maximum
extent practicable.

Stormwater Division coordinates
with Guilford County Health
Department to control the known
sources of fecal coliform from
septic systems within the City’s
jurisdictional limits to the
maximum extent practicable.
Additionally, the City’s Water
Resources Department funds and
performs an ongoing sewer
rehabilitation program to
minimize and eliminate cross
connections between the storm
and sanitary sewer systems.
Operation and Maintenance
Plan
Require an operation and
maintenance plan that ensures the
adequate long-term operation of
the structural SCMs required by
the program. The operation and
maintenance plan may require the
owner of each structural SCM to
submit a maintenance inspection
report on each structural SCM
annually to the local program, or
the maintenance inspections may
be conducted annually by the
Permittee.
City of Greensboro Stormwater
Division’s development plan
review process requires a
stormwater management plan
and separate SCM operation and
maintenance plan (consistent
with the provisions outlined in
the State stormwater design
manual) be submitted prior to
receiving development plan
approval. Currently, the City of
Greensboro Stormwater Division
conducts maintenance
inspections on SCMs within the
City’s jurisdiction.

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NPDES Permit No. NCS000248 Page 19 of 34
BMP Summary Table – Continued

Educational materials and
training for developers
Provide educational materials
and training for developers. New
materials may be developed by
the permittee, or the permittee
may use materials adopted from
other programs and adapted to
the permittees new development
and redevelopment program.
Water Resources Stormwater and
Engineering Divisions notify
developers and engineers of
ordinance changes via direct
phone and e-mail, face-to-face
meetings upon request regarding
proposed site projects, Triad
Real Estate and Building
Industry Coalition, televised City
Council meetings, providing
opportunity for public comment,
as well as posting the changes on
the City website.
Setbacks for Built-upon Areas Require built-upon areas to be
located at least 50 feet landward
of all perennial and intermittent
surface waters except as provided
for in the Permittees Post-
Construction Stormwater
Ordinance. For purposes of this
section, a surface water shall be
present if the feature is shown on
either the most recent printed
version of the soil survey map
prepared by the Natural
Resources Conservation Service
of the United States Department
of Agriculture or the most recent
version of the 1:24,000 scale (7.5
minute) quadrangle topographic
maps prepared by the United
States Geologic Survey (USGS).
Relief from this requirement may
be allowed when surface waters
are not present in accordance
with the provisions of 15A
NCAC 02B .0233(3) (a).
The Greensboro Land
Development Ordinance was
reviewed and modified to require
a 50 foot stream buffer in
accordance with NPDES phase II
requirements.
In addition, the City of
Greensboro has updated the
riparian buffer requirements
according to the Jordan and
Randleman Lake Rules. The
“Table of Activities and
Structures in Stream Buffers
(Zone 1 & Zone 2)” located in
Chapter 30 of the Greensboro
Land Development Ordinance
determines the allowable uses
within the 50’ riparian buffer.

Local Permit Issuance
Currently, Group, Site and Subdivision plans within Greensboro’s jurisdiction are reviewed by the City’s
Technical Review Committee (TRC) for compliance with applicable development regulations. TRC is an
interdepartmental team charged with enforcing development standards as they relate to Watershed
Protection, Stormwater Management, Water-Supply, Water Reclamation, Zoning, Transportation, Parks
and Recreation, Tree Preservation, etc. Approval by members of TRC is a prerequisite to the issuance of
a grading permit or building permit. The City has reviewed and modified the Greensboro Land
Development Ordinance in order to ensure that plans meet post-construction stormwater management

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NPDES Permit No. NCS000248 Page 20 of 34
requirements as defined by 15A NCAC 2H.0126 (10). The final 15A NCAC 2H.0126 (10)(h) rules define
low and high density development thresholds and as such these thresholds and any associated permanent
structural control and riparian buffer requirements will be applied to applicable new development or re-
development within the City’s jurisdictional area. These requirements have now been incorporated in the
Greensboro Land Development Ordinance to allow for enforcement by City staff prior to issuance of the
applicable construction permit. The post-construction stormwater requirements were adopted by City
Council on April 7, 2009 and became effective June 1, 2009. Additionally, the City amended the Land
Development Ordinance and adopted Jordan Lake Riparian Buffer requirements on November 9, 2010.
These rules became effective on December 1, 2010.

Structural SCM Operation and Maintenance
Greensboro mandates that all required structural stormwater control measures (SCMs) be placed in a
drainage maintenance and utility easement (DMUE) connected to the public right-of-way by a 20 foot
wide access easement. The DMUE and access easement for each SCM must be platted before any
certificate of occupancy is issued for the site. TRC-approved development plans for structural SCMs
include an operation and maintenance plan (consistent with the provisions outlined in the State minimum
design criteria) be submitted prior to receiving development plan approval. Furthermore, notes are
recorded on the plat indicating that the City has the right to access the site for SCM inspections and that
the owner will maintain the SCM per the approved maintenance plan or as directed by the City.

During the reporting period (July 1, 2019 to June 30, 2020), 445 privately owned SCMs were inspected
by City staff for performance and maintenance compliance. Fifteen owners were issued a Notice of
Violation (NOV) for failing to complete the required maintenance items with two of the fifteen receiving
an additional second NOV. Of the fifteen sites with NOVs, nine have completed the required SCM
maintenance. The city is working with the property owners, through enforcement procedures, to complete
maintenance items on the six remaining SCMs.

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NPDES Permit No. NCS000248 Page 21 of 34
Pollution Prevention/Good Housekeeping for Municipal Operations
Pollution Prevention and Good Housekeeping Programs are an important factor in the improvement of
stormwater runoff quality. Municipal departments that utilize various facilities currently implement good
housekeeping and pollution prevention programs. Additionally, the City Water Resources Department
works to ensure that pollution prevention and good housekeeping measures are being implemented at
other municipal facilities to the maximum extent practicable with the intent of improving stormwater
runoff quality discharged into receiving streams by those municipal facilities and their operations.

BMP Summary Table

BMPs for Pollution Prevention/Good Housekeeping Program
BMP Measurable Goals Comments
Street Sweeping Continue ongoing program with periodic
review.
Ongoing program:
Stormwater Management
and Field Operations
Department.
Loose Leaf Collection for
Composting
Continue ongoing program with periodic
review.
Ongoing program:
Stormwater Management
and Field Operations
Department.
Erosion and
Sedimentation Control
City owned or otherwise public
construction sites are regulated by NCDEQ,
Division of Energy, Mineral and Land
Resources for proper erosion and sediment
control.
Ongoing program:
City owned and other
publicly funded projects
obtain appropriate state
permits.
Staff Training/Site
Operator Education
The Stormwater Management Division of
Water Resources distributes education
material for training employees on various
municipal operations.
Ongoing cooperative effort
by the City’s departments

Site Planning/Pollution
Prevention Plan for
Municipal Facilities
Develop and implement pollution
prevention plans that have been determined
to have the potential to impact Water
Quality.
Ongoing effort by the City
of Greensboro.
Site inspection and
evaluation of facilities,
operations including the
MS4 system and
associated structural
SCMs.
The City maintains mapping programs that
consist of all municipal facilities, as well as
any related structural SCMs. City
Stormwater Management maintains an
ongoing inspection program to monitor,
document and enforce stormwater
discharges to the MS4 system.
The City’s Stormwater
Management Division has
identified a list of specific
city facilities and ranked
each of them according to
their potential to pollute.
Inspections of the high and
medium ranking facilities
have been conducted,
including documenting
areas where improvements
can be made to reduce the
potential of generating
polluted runoff.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 22 of 34
Affected Operations
The facilities listed in the following table are municipal operations that have been issued NPDES
Stormwater Discharge permits. These facilities have developed Municipal Pollution Prevention/Good
Housekeeping techniques in addition with the education and training material sent out.

Municipal Operation Permit Number
City of Greensboro White St. Landfill NCG120013
TZ Osborne WWTP NCG110005
North Buffalo WWTP NCG110004
Patton Avenue Service Center NCG080799
Greensboro Transit Authority (Bus Garage) NCG080893

Training
The City’s Stormwater Management Division of Water Resources provides educational and technical
assistance for City facilities pertaining to pollution prevention plans and/or BMPs for the improvement of
overall environmental quality. In addition, the Stormwater Management Division also provides assistance
for City facilities pertaining to structural and non-structural stormwater BMPs for the improvement of
stormwater quality and/or quantity and BMP design and implementation.

The City has identified nine Departments that have a greater potential to contribute pollution to
stormwater runoff. The Departments involved in this program are as follows:
1. Coliseum
2. Engineering and Inspections
3. Field Operations
4. Finance (Equipment Services)
5. Fire
6. Parks and Recreation
7. Police
8. Transportation
9. Water Resources

During the July 1, 2019 to June 30, 2020 reporting period, approximately 395 City of Greensboro
employees received training on municipal pollution prevention. This number includes our in house
stormwater pollution prevention DVD, Water Resources employee’s training videos and the Fire
Department’s in-depth annual training of personnel on spill response and pollution prevention.

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NPDES Permit No. NCS000248 Page 23 of 34

Collectively, it is the responsibility of the entire City of Greensboro to maintain the NPDES citywide
permit and enforce programs collaboratively. The objective is for all municipal departments that engage
in various operations to implement good housekeeping and pollution prevention methods in everyday
activities and to set a good example for the community to follow.

Site Inspection and Evaluation of Facilities

Stormwater personnel focused on site inspection and evaluation of city owned and operated facilities. A
complete list of all City owned and operated facilities was obtained from a GIS layer file. To prioritize
each facility, the history of spills/concerns, the proximity to a stream or stormwater conveyance system,
and the activities at a particular location were considered when ranking each facility as High, Medium or
Low. This ranking is further defined below.

High: Facilities in this category would have a large amount of outdoor processing activities, close
proximity to a stream and/or material storage on-site or obvious poor housekeeping issues.
Examples of these facilities would be golf courses, satellite fueling stations, facilities that
store salt for deicing roadways or the Coliseum that has many vendors using this property
at all times.

Medium: This category includes facilities that have some outdoor storage or processing, that may
not be in close proximity to a stream. Examples of these type facilities would be larger
parks, the science center, water treatment plants and the fire training center.

Low: A facility in low level ranking would have limited or no outdoor processing areas.
Examples of these facilities would be libraries, parking decks, rec centers and fire stations.

During the July 1, 2019 to June 30, 2020, reporting period, the stormwater management division
continued to inspect the high or medium risk ranked city owned facilities (listed below). In addition, the
Stormwater Management Division followed up with three medium risk facilities that were previously
inspected. All improvements made at these three facilities were documented in the respective facility files.
14
279
102
City of Greensboro: Municipal PollutionPrevention
Good Housekeeping Employee Training
Participation
Water Resources Fire Field Ops
395 Employees Trained

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 24 of 34

Municipal Operation Rank
Solid Waste Transfer Station M
Barber Park M
Oka T. Hester Park M
Forest Lawn Cemetery M
Mitchell Water Treatment Plant M

Maintenance and Inspections
The City of Greensboro Stormwater Maintenance Section, within the City’s Field Operations Department,
maintains open and closed stormwater infrastructure and drainage conveyance systems that carry public
runoff within the MS4 service area. This section also performs stream maintenance activities and
preventative maintenance on most public stormwater infrastructure.

The City’s Stormwater Management Division identifies and inspects industrial and related facilities that
may discharge stormwater into either the MS4 or receiving streams in Greensboro, and also assists the
local industrial community in the development and implementation of appropriate stormwater runoff
controls. In addition, the City has an ongoing litter pick-up program to clear trash and other floatables
from roadways, which helps keep them out of the storm drainage system and surface waters.

Vehicular Operations
The City of Greensboro’s vehicular operation centers utilize the City’s hazardous waste program to
recycle or dispose used oil, antifreeze, batteries, and spare parts and used chemicals. A new salt storage
barn was constructed in fall 2002 as a BMP to prevent salt stormwater runoff from entering receiving
streams.
Waste Disposal
Waste materials generated from the City’s day-to-day activities are managed according to local and state
regulations and vendors utilized by Greensboro are audited to ensure environmental compliance. With
the ongoing public education and awareness programs, the City will continue to facilitate staff meetings to
inform staff of all new and related regulations/programs corresponding with the Municipal Pollution
Prevention and Good Housekeeping Program.

Examples of Waste Disposal Programs include:
• Hazardous Waste Program
• Solid Waste Recycling
• Lead Disposal Program
• Oil Disposal Program
• Water Treatment Chemicals Disposal Program

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 25 of 34
Program to Monitor and Evaluate Storm Water Discharges to the Municipal System
The City of Greensboro has developed and implemented an industrial facilities inspection program during
the first two permit terms. During the current permit term, the inspection program will be reviewed and
revised to reflect current permit conditions. Industrial facilities subject to Section 313 of Title III of the
Superfund Amendments and Reauthorization Act of 1985 (SARA), and industrial facilities that the City
determines to be contributing or have the potential to contribute a substantial pollutant loading to the
municipal separate storm sewer system will be inventoried and evaluated.

BMP Summary Table

BMPs for Monitoring and Evaluating Storm Water Discharges to the MS4
BMP Measurable Goals Comments
Maintain Inventory of Industrial Sites The City maintains an
inventory of all NPDES
permitted industrial facilities.
The City will add additional
facilities to list that meet the
SARA Title III (Section 313)
criteria or that contribute
substantial pollutant loading
to the MS4 system.
The City will update and
revise list annually.
Inspection Program The City has developed a
formal inspection program
for evaluating industrial
facilities. This inspection
program will be expanded to
include any facility on the
above stated list.
The City has an ongoing
industrial inspection program
with a goal of visiting all
listed industrial facilities once
per permit cycle. Annual
training is conducted for City
staff on specific inspection
procedures and staff
coordinates with NCDEQ on
a regular basis to be trained
on any issues or permit
updates.
Establish and Implement Measures to
Evaluate Commercial and Industrial
Facilities discharging stormwater to
the City’s MS4
The City has developed the
industrial facilities inspection
program to evaluate those
facilities on the above list
and ensure all permit
conditions are being met and
discharges to the MS4 are
not considered substantive.
The City has a strong working
relationship with the NCDEQ
regional office and county
officials. The City’s
enforcement procedures are
utilized when water quality
violations are encountered and
follow up actions are deemed
necessary. NPDES permit
deficiencies are addressed in
written notification and are
also forwarded to NCDEQ
(agency with permitting
authority).

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 26 of 34
During the reporting period (July 1, 2019, to June 30, 2020), a total of 13 NPDES permitted facilities
were inspected by City staff. Of these 13 inspections, three were also listed in the Toxic Release
Inventory. Additionally, one facility without a permit was inspected because it is listed in the Toxics
Release Inventory. No enforcement action was warranted from these inspections. The number of facility
inspections varies from year to year, with some years having more inspections than others. This variation
in facility inspections is due to a previous scheduling agreement between the City of Greensboro and
NCDEQ to avoid overlapping inspections of NPDES permitted facilities.

Water Quality Assessment and Monitoring
The City of Greensboro has developed and implemented a comprehensive water quality monitoring and
assessment program to evaluate the impacts on water quality.

BMP Summary Table

BMPs for Water Quality Assessment and Monitoring
BMP Measurable Goals Comments
Water Quality Assessment and
Monitoring Plan
A DRAFT City of Greensboro
Water Quality Assessment and
Monitoring Plan was submitted
within 12 months of permit
issuance as required by the
NPDES permit.
Draft document was submitted
to NCDEQ for comment and
approval within 12 months of
permit issuance as required.
Water Quality Monitoring The City will implement the
water quality assessment and
monitoring plan in accordance
with NCDEQ and the permit
schedule.
The City implemented the
submitted water quality
monitoring plan January 1,
2009.
Revisions to the Water Quality
Assessment and Monitoring Plan
The City will conduct an annual
review, revise as appropriate,
and submit any revisions to
NCDEQ for approval.
The City will review and revise
annually and coordinate with
NCDEQ any proposed changes.
The most recent revision
occurred in the 2019-20
reporting cycle. The revised
plan along with the annual
report is going to be submitted
to NCDEQ on October 31,
2020.

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NPDES Permit No. NCS000248 Page 27 of 34
Total Maximum Daily Load (TMDL)

The City of Greensboro has an EPA and NCDEQ approved TMDL for Fecal Coliform bacteria for North
Buffalo Creek. The permittee will utilize BMPs within the six minimum measures to address the
permittee’s assigned NPDES regulated stormwater waste load allocation (WLA) identified in the
approved TMDL to the maximum extent practicable and to the extent authorized by law. Resolute efforts
are being made to determine the most efficient best management practices that address the MS4 NPDES
regulated Waste Load Allocation identified in the TMDL. Current efforts are continually re-evaluated and
adapted as needed. More importantly, new ideas are continuously shared and assessed, with the ultimate
goal of improving and protecting water quality.

An assessment of available data, BMP strategies, and TMDL Watershed Plan effectiveness will be
conducted and utilized to define the appropriate progress and schedule of the watershed plan within the
context of the Maximum Extent Practical (MEP) standard. Activities conducted throughout the program
implementation schedule to address the MS4 NPDES regulated waste load allocation (WLA) identified in
the TMDL will be evaluated and defined as to the collective contribution to the watershed plan. The
results of the analysis will be utilized to prioritize local funding aimed at elimination of the most
significant portion of the MS4 waste load allocation for the least resources.

BMP Summary Table

BMPs for Total Maximum Daily Load
BMP Measurable Goals Comments
(A) Identify, describe and
map watershed, outfalls, and
streams

Within 12 months the permittee shall
prepare a plan that:
• Identifies the watershed(s) subject to an
approved TMDL with an approved
Waste Load Allocation (WLAs)
assigned to the permittee; and
• Includes a description of the
watershed(s); and
• Includes a map of the watershed(s)
showing streams & outfalls; and
• Identifies the locations of currently
known major outfalls within its
corporate limits with the potential of
contributing to the cause(s) of the
impairment to the impaired segments, to
their tributaries, and to segments and
tributaries within the watershed
contributing to the impaired segments;
and
• Includes a schedule (not to exceed 6
months) to discover and locate other
unknown major outfalls within its
corporate limits that may be contributing
to the cause of the impairment to the
impaired stream segments, to their
Description, maps, and
outfall information is
noted in BMP Narratives
following this table.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 28 of 34
BMP Summary Table – Continued

tributaries within the watershed contributing
to the impaired segments.

(B) Evaluate existing
measures

Within 12 months the Permittee’s plan:
• Shall describe existing measures being
implemented by the Permittee designed
to achieve the MS4’s NPDES WLA and
to reduce the TMDL pollutant of
concern to the MEP within the
watershed to which the TMDL applies;
and
• Provide an explanation as to how those
measures are designed to reduce the
TMDL pollutant of concern.
• The Permittee shall continue to
implement the existing measures until
notified by NCDEQ.
Measures include
education, sampling,
investigating pollution
concerns, industrial
inspections, etc. See
information in BMP
Narratives following this
table for a more complete
list and descriptions.
C) Assessment of available
monitoring data
Within 24 months the permittee’s plan shall
include an assessment of available
monitoring data. Where long-term data is
available, this assessment should include an
analysis of the data to show trends.

An assessment of the
programmatic
management measures,
existing TMDL data,
relevant watershed data,
monitoring data, etc., is
performed periodically.
An assessment of
activities conducted under
the TMDL plan will be
performed to evaluate the
overall effectiveness of
the watershed plan and
make any adjustments
deemed necessary. The
assessment will be used,
where possible, to
evaluate the performance
of existing BMPs and
identify additional BMP
strategies as necessary.
(D) Monitoring Plan

Within 24 months the permittee shall
develop a Monitoring Plan for the
permittee’s assigned NPDES regulated
WLA as specified in the TMDL. The
permittee shall maintain and implement the
Monitoring Plan as additional outfalls are
identified and as accumulating data may
suggest. Following any review and
comment by the Division the permittee shall
incorporate any necessary changes to
monitoring plan and initiate the plan within
The monitoring plan for
the TMDL Watershed
Plan includes current
monitoring programs and
procedures that will be
updated as necessary to
achieve the City’s waste
load allocation (WLA)
and reduce the pollutant of
concern (POC) to the
maximum extent possible.

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NPDES Permit No. NCS000248 Page 29 of 34
BMP Summary Table – Continued

6 months. Modifications to the monitoring
plan shall be approved by the Division.
Upon request, the requirement to develop a
Monitoring Plan may be waived by the
Division if the existing and proposed
measures are determined to be adequate to
achieve the MS4’s NPDES WLA to MEP
within the watershed to which the TMDL
applies.

(E) Additional Measures Within 24 months the permittee’s plan
shall:
• Describe additional measures to
be implemented by the permittee
designed to achieve the
permittee’s MS4’s NPDES
WLA and to reduce the TMDL
pollutant of concern to the MEP
within the watershed to which
the TMDL applies; and
Provide an explanation as to how those
measures are designed to achieve the
permittee’s MS4’s NPDES regulated WLA
to the MEP within the watershed to which
the TMDL applies.
Measures include the
FOG Program, sanitary
sewer rehabilitation, pet
waste stations, and the use
of new technology, and
the SSO Reduction
Committee. See
information in BMP
Narratives following this
table.
(F) Implementation Plan Within 48 months the permittee’s plan
shall:
• Describe the measures to be
implemented within the remainder of
the permit term designed to achieve
the MS4’s NPDES WLA and to
reduce the TMDL pollutant of
concern to the MEP; and
• Identify a schedule, subject to
Division approval, for completing
the activities.
• Implement the permittee’s TMDL
plan
Current BMPs will
continue to be
implemented to achieve
the Waste Load
Allocation to reduce the
pollutant of concern to the
MEP. This includes
existing BMPs and the
exploration of additional
opportunities.

(G) Incremental Success The permittee’s plan must outline ways
to track progress and report successes
designed to achieve the MS4’s NPDES
regulated WLA and to reduce the
TMDL pollutant of concern to MEP
within the watershed to which the
TMDL applies.
The TMDL plan describes
ways to track and report
successes based on the
TMDL BMPs and goals
designed to achieve the
Waste Load Allocation to
reduce the pollutant of
concern to the MEP.

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 30 of 34
BMP Summary Table – Continued

(H) Reporting The permittee shall conduct and
submit to the Division an annual
assessment of the program
designed to achieve the MS4’s
NPDES WLA and to reduce the
TMDL pollutant of concern to
the MEP within the watershed to
which the TMDL applies. Any
monitoring data and information
generated from the previous year
are to be submitted with each
annual report.
Following the schedule per the
permit, the TMDL watershed
plan addresses and reports on the
TMDL program.

BMP Narratives

1) Identify, Describe and Map Watershed, Outfalls, and Streams (A)
Watershed Description

The North Buffalo Creek watershed is located in Greensboro, North Carolina (Guilford County), and is in
the headwaters of the Cape Fear River Basin. The eastern flowing stream eventually feeds into the Haw
River. The watershed is represented by small floodplain streams that have some bedrock outcroppings and
are surrounded by gently sloping uplands. North Buffalo Creek’s headwaters lie entirely within urbanized
areas (commercial, industrial, and residential with high impervious area) in the city of Greensboro
(population ~287,000).

As outlined in the City’s TMDL Watershed Plan, the compliance point for Upper North Buffalo Creek
TMDL is located where Summit Avenue crosses over North Buffalo Creek. The drainage area from the
headwaters to this compliance point is 21.8 mi² and incorporates 8.7 miles of stream. The area is generally
deemed as built out, in that no major future land use changes are predicted. The area is 38% residential,
15% right-of-ways, and 20% forest. Impervious surface constitutes >26% of the watershed. In January of
2009, the City started collecting water quality samples at the compliance point on a monthly basis.
Samples are analyzed for both physical and analytical parameters.

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NPDES Permit No. NCS000248 Page 31 of 34

Drainage Area: Headwaters to TMDL Compliance Point

Outfall Locations
MS4 outfalls have been determined through GIS and the City’s ongoing stormwater inventory process.
See map below for outfall locations within the TMDL watershed.

Schedule for Locating New Outfalls
Unknown major NPDES outfalls will be identified utilizing the ongoing stormwater inventory procedures
through subsequent QAQC checks of various sub basins, ongoing collection efforts involved with new
development, and updates due to drainage system repairs and maintenance. Any new outfalls and/or
newly identified outfalls will be recorded and mapped on a routine basis.

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NPDES Permit No. NCS000248 Page 32 of 34

NPDES Outfalls in TMDL Drainage Area

2) Existing Measures (B)
Outfall Screening
NPDES outfalls are investigated/screened on a routine basis to determine illicit discharges or improper
disposals. Locations are determined based on random selection and areas that have not been done before.
Any noted concerns are investigated further, which may include tracking, obtaining readings for physical
parameters, and/or taking samples to be analyzed in the field or by the contracted lab.

Education
The following are examples of TMDL/pollution education and outreach:
• Engaging citizens with the Drain Marker and Adopt-a-Stream programs, pet waste stations, etc., to
encourage personal involvement
• Assisting local universities with stream clean-up events
• Partnering with communities and organizations to use media for a broad-scale approach to
pollution education and prevention
• Educating citizens about TMDLs via the City’s website

Small-Quantity Polluters Program
As well as general education, specific business types in the community are identified and educated
regarding housekeeping practices and proper waste disposal. This Pollution Prevention Program entails
water quality staff to educate businesses that are common polluters, such as painters, landscapers, ready-

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 33 of 34
mix concrete companies, auto repair shops, mobile washers, restaurants, etc. This ongoing prevention
program is highly regarded and has been determined to be a worthwhile endeavor in keeping pollution
from streams and other water sources.

Fixed Interval Sampling
Monthly sampling and assessments are performed, including the analysis of results and the need for
outfall follow-ups; this includes a sampling site at the compliance point in additional to three other
monitoring sites in the TMDL watershed. When data suggests an elevated level of fecal coliform,
increased follow-up sampling and investigations take place to determine the potential source.

Sanitary Sewer Overflow (SSO) Prevention
Ongoing evaluation of citywide SSOs is being used to direct resources for maintenance and rehabilitation
of sanitary sewer lines in the TMDL watershed in an effort to prevent overflows and exfiltration.

Field Observations
Issues discovered by staff through inventory collections, outfall screenings, etc., and water quality staff
address potential issues.

Public Concerns/Reports
Reports are followed up by investigating, tracking, resolving, and enforcing violations when applicable.
Over the past reporting year, illicit connections have been identified and eliminated throughout the city.

Industrial Inspection Program
NPDES permitted facilities and TRI facilities are inspected, focusing on a review of the Stormwater
Prevention Pollution Plan, spill prevention and response procedures, employee training, housekeeping
practices, and outfall monitoring.

3) Additional Measures (E)
Fats, Oils, and Grease (FOG) Program
This ongoing program seeks to reduce the number of SSOs due to issues caused by oil and grease. New
approaches and technology, such as SwiftComply software, are continuously evaluated and implemented
where applicable. In addition, two staff positions have been recently added to support this program,
increasing staff in this section from one to three in the near future.

Sanitary Sewer Rehabilitation
During the reporting year, over 33,000 linear feet of sewer underwent rehabilitation in the North Buffalo
watershed up to the compliance point.

Pet Waste Stations
Pet waste stations in the TMDL watershed have been mapped, including both private stations and those
maintained by the City of Greensboro. Within this watershed, there are approximately 113 documented
pet waste stations (84 private, 29 city maintained).

New Technology
New technology is always being assessed in an effort to be proactive regarding the City’s wastewater
collection system. Acoustical testing and assessment tools (such as SL-RAT—Sewer Line Rapid
Assessment Tool), could help reduce the number of SSOs, therefore reducing the WLA for the POC. The
Operations Division continually explores new and updated equipment to prevent SSOs and to investigate
or repair sewer lines. In addition, inflatable plugs are being used when applicable, helping prevent

City of Greensboro’s Stormwater Management Program Plan (Stormwater Plan) October 31, 2020
NPDES Permit No. NCS000248 Page 34 of 34
overflows from entering surface waters.

SSO Reduction Committee
This committee is compiled of representatives from multiple divisions within the Water Resources
Department. The goal of the committee is to take a holistic approach to preventing SSOs by analyzing
past overflows using GIS, the work order management system, and staffs institutional knowledge to
implement enhanced reduction strategies.

Threatened or Endangered Species Protection Program
The City of Greensboro currently does not have any federally listed aquatic animal species that are listed
as threatened or endangered by the U.S. Fish and Wildlife Service or the National Marine Fisheries
Service under the provisions of the Endangered Species Act.
_____________________________________________________________________________________

For more information on the City of Greensboro’s NPDES MS4 Discharge Permit and associated
Stormwater Quality Management Program Plan, please visit the Stormwater website at:
www.greensboro-nc.gov/stormwater