NCS000245_Raleigh 2020 Annual Report_20201028

NPDES Stormwater
MS4 Permit Annual
Report

October 1, 2019 – September 30, 2020

Permit No. NCS000245
To discharge stormwater under the National Pollutant Discharge Elimination System
Prepared by S. Wayne Miles, PE, Stormwater Program Manager

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Table of Contents

Summary ............................................................................................................................... 3

Section A: Annual Expenditures .............................................................................................. 4

Section B: Public Involvement and Participation ..................................................................... 5
B.1 Program Narrative .................................................................................................. 5
B.2 Best Management Practices .................................................................................. 5

Section C: Illicit Discharge Detection and Elimination ............................................................. 7
C.1 Program Narrative .................................................................................................. 7
C.2 Best Management Practices .................................................................................. 7

Section D: Construction Site Runoff Controls ........................................................................ 11
D.1 Program Narrative ................................................................................................ 11
D.2 Best Management Practices ................................................................................ 11

Section E: Post-construction Site Runoff Controls ................................................................ 14
E.1 Program Narrative ................................................................................................ 14
E.2 Post-construction Stormwater Management Program Measures ........................ 14
E.3 Best Management Practices ................................................................................ 14

Section F: Pollution Prevention and Good Housekeeping for Municipal Operations ............ 15
F.1 Program Narrative ................................................................................................ 15
F.2 Best Management Practices ................................................................................ 15

Section G: Public Education and Outreach ........................................................................... 17
G.1 Program Narrative ................................................................................................ 17
G.2 Best Management Practices ................................................................................ 17

Section H: Program to Monitor/Evaluate Stormwater Discharges to Municipal Systems ..... 20
H.1 Program Narrative ................................................................................................ 20
H.2 Best Management Practices ................................................................................ 20

Section I: Water Quality Assessment and Monitoring .......................................................... 21
I.1 Program Narrative ................................................................................................ 21
I.2 Best Management Practices ................................................................................ 21

_______________________________

S. Wayne Miles, PE
Stormwater Program Manager
City of Raleigh

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Summary
This report describes programs and activities undertaken during the period of October 1, 2019 through
September 30, 2020 as required by the City of Raleigh’s permit to discharge stormwater under the
National Pollutant Discharge Elimination System (NPDES), NPDES Stormwater MS4 Permit no.
NCS000245.

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Section A: Annual Expenditures
Expenditures for the City’s Stormwater Program for this reporting period were $15,644,757, funded by the
City’s stormwater utility fee. The adopted Capital Improvement Program budget for the City’s Stormwater
Program for FY2021 (fiscal year July 1, 2020 through June 30, 2021) is $6,500,000.

Table A.1: FY2021 Stormwater Program Capital Improvement Program Budget

Stormwater Program Category FY2021 CIP Budget
General Drainage Infrastructure $2,400,000
Neighborhood Drainage System Improvements $2,150,000
Lake Preservation $350,000
Stream Restoration $500,000
Water Quality $300,000
City SCMs and Dams Program $125,000
Street Drainage System Improvements $675,000
Total $6,500,000

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Section B: Public Involvement and Participation

B.1 Program Narrative
The City provides several opportunities for public involvement and participation. The City’s Stormwater
Management Plan is noticed and presented at a public hearing for comment by the public once per permit
cycle. As-needed changes to City stormwater regulations also are noticed and presented at public
hearings for comment by the public. The annual budget for the Stormwater Management Division is
noticed and presented for public comment prior to adoption. As a means of obtaining more regular public
input on policy and project related matters, Raleigh City Council established the Stormwater Management
Advisory Commission that reviews stormwater management issues and provides guidance and
recommendations to City Council.

B.2 Best Management Practices

B.2.1 Administer a Public Involvement Program
The City provides several public involvement opportunities annually and at the time of revising the
Stormwater Management Plan. These opportunities are described below.

B.2.2 Allow the public an opportunity to comment on the Stormwater Management Plan
The City’s Stormwater Management Plan is revised with each permit cycle and is presented to City
Council for public hearing. The current Stormwater Management Plan, which was updated May 2015 and
available for public comment June 2015, is available upon request to the public at raleighnc.gov.
Stormwater staff is revising and updating the Stormwater Management Plan, to be completed within the
next reporting period.

B.2.3 Organize a volunteer community involvement program
The City’s Stormwater Management Division sponsors four volunteer programs that encourage adopting
streams, stream cleanups, storm drain marking, and stream monitoring. These volunteer programs
normally are maintained throughout the year with ongoing volunteer activities, including one stream
cleanup event organized by City staff and one stream monitoring workshop. During this reporting period,
both those events were canceled due to COVID-19. Staff are exploring virtual options for future stream
monitoring workshops if meeting in person is not possible. Information is provided at raleighnc.gov.

B.2.4 Establish a Mechanism for Public Involvement
The Stormwater Management Advisory Commission was established in 2003 by a resolution adopted by
City Council. It is the official citizen advisory board to City Council on issues pertaining to stormwater
program policies. This commission advises City Council and staff on matters pertaining to policy changes
and stormwater services and reviews the annual stormwater budget and capital improvement plan. It
consists of 10 members residing within the Raleigh City limits appointed by City Council to overlapping
two-year terms. The commission’s monthly meetings are open to the public, and public input is invited.
The commission’s mission statement is: “The Stormwater Management Advisory Commission will
manage resources sufficiently to protect the public infrastructure, quality of life, environment, and propert y
of the citizens of Raleigh through fair and equitable cost-effective means”. Information is provided at
raleighnc.gov.

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B.2.5 Establish Hotline/Helpline
The City uses the Stormwater Management Division’s main telephone line, [phone], as a
hotline/helpline. A dedicated email address, [e-mail], is another option for the
public and City employees to report spills and illicit discharges.

These helplines are maintained during working business hours. After hours and on weekends, calls
regarding spills and other illicit discharges are:
• Received by the City’s 911 center and routed to the Fire Department or other appropriate
departments, and
• Depending on the nature and urgency of the spill or discharge inquiries are routed to
[e-mail].

During this reporting period, 103 water quality-related calls were received from the public, with 53 of these
calls received through the water quality helpline and dedicated email address and 50 calls directly to staff
phones and emails.

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Section C: Illicit Discharge Detection and Elimination

C.1 Program Narrative
The City’s illicit discharge program began in 1995. This program is based on a City ordinance that defines
what constitutes an illicit discharge and an illicit connection and provides enforcement protocols.

Illicit discharges and illicit connections are identified through reports from the public, reports from City staff
across all departments, dry weather screening observations, and outfall inspections. A team of three staff
is assigned to Illicit Discharge Detection and Elimination (IDDE). IDDE preventive measures include
educating City staff and the public through various means and direct mailings to businesses, such as
landscapers and restaurants, that have a history of illicit discharges. Outreach efforts also include regular
updates to website content, social media, utility billing and newsletter inserts , and coordination with Wake
County and professional associations to distribute illicit discharge prevention information to wide
audiences.

C.2 Best Management Practices

C.2.1 Develop/Implement Illicit Discharge Detection and Elimination Program
During this reporting period the IDDE Program achieved the results shown in Table C-1.

Table C-1. Illicit Discharge and Elimination Program Achievements
Achievement Count
Water quality complaints investigated 103
Illicit discharges confirmed and eliminated* 76
Illicit connections confirmed and eliminated 2
NOVs issued 18
Civil penalties issued 0
Total amount of civil penalties issued $0

The City’s goals for IDDE also include responding to water quality complaints within one business day
and inspecting high-priority stormwater outfalls each year for dry weather flows. The City has
implemented a GIS-based application for prioritizing, tracking, and documenting outfall inspections and
improve record-keeping.

C.2.2 Modify, as necessary, and maintain appropriate legal authorities
The City’s Illicit Discharge Ordinance was adopted in 1995 by City Council and was amended in February
2011. This ordinance has been maintained and was not modified during this reporting period.

C.2.3 Complete the Development of a Storm Sewer Base Map and Inventory of Major MS4 Outfalls
During the 2014-2015 reporting period, the City completed an inventory of Raleigh’s MS4 and associated
stormwater drainage infrastructure within the Raleigh corporate area and Raleigh’s extra-territorial
jurisdiction. A GIS-based map of the stormwater infrastructure is available to the public at
https://maps.raleighnc.gov/iMAPS/. The City continually updates and upgrades this inventory by

incorporating as-built data (as new infrastructure is added and existing infrastructure is replaced) and
identifying and correcting errors. Citywide updates have been made to the database from as-builts
records for completed City projects that include changes to the stormwater infrastructure.

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The City developed its initial inventory of MS4 outfalls in 2016 and 2017 based on outfall pipe size and
land use within the contributing drainage area. During the reporting period for this annual report, the City
became aware that NC DEMLR had posted its definition for a major outfall, originating with U.S. EPA,
based on criteria different from the criteria the City had previously developed. Work is ongoing to update
the existing major outfall dataset to conform to the EPA definition.

C.2.4 Maintain an inventory of Major MS4 Outfalls that discharge to waters of the State
The City continually maintains its stormwater infrastructure inventory and major MS4 outfalls inventory by
incorporating as-built data and verifying past-collected data.

C.2.5 Inspection/detection program to detect dry weather flows at MS4 outfalls
Dry weather flow inspections are conducted per the procedures outlined in the Engineering Services
Department, Stormwater Management Division Standard Procedure SW-100 Illicit Discharge Detection
and Elimination. A GIS-based application was used during this reporting period for tracking and
documenting dry weather outfall inspections. Priority outfalls were identified to target for inspection during
this reporting period. The outfalls were prioritized based on:

• Impairment status of downstream water bodies,
• Proximity to sanitary sewer lines and manholes,
• Land use,
• Outfall pipe size, and
• Location within the Neuse Riparian Buffer.

This prioritization strategy targeted outfalls susceptible to industrial and commercial illicit discharges,
potential connection to sanitary sewer lines through pipe failures, dense residential development, and
potential for a discharge to reach surface waters.

Figure C-1 shows priority outfalls for the City to inspect annually. Using the GIS-based application, 200
outfalls were inspected during this reporting period. In addition to updating the existing major outfall
dataset to conform to the EPA definition (section C.2.3), ongoing work includes inspecting the major
outfalls as identified in this updated dataset.

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Figure C-1. Priority MS4 Outfalls

C.2.6 Employee Training
During this reporting period, 916 City employees received formal training on illicit discharge detection.
The City continued to transition from face-to-face training to online training to improve coverage of
training among City departments, to facilitate tracking and recordkeeping of training activities, and to
adjust for social distancing needed because of COVID-19. In addition, 216 City employees received
formal training on pollution prevention and good housekeeping during this reporting period.

C.2.7 Provide Public Education
Through the public education and outreach, the City provides general stormwater awareness education
and an introduction to problems caused by illicit discharges.

The City distributes educational postcards that are targeted to specific businesses, including automobile
services, food services, landscaping services, food truck services, carpet cleaning services, and general
illicit discharge prevention. These postcards are provided to businesses when first-time violations of the
illicit discharge ordinance are observed by staff. Information for preventing illicit discharges and reporting
illicit discharges also is provided on the City’s website.

C.2.8 Modify, if necessary, and maintain public reporting mechanism
During this reporting period the City maintained and did not modify its main telephone line as a helpline
nor its dedicated email address, [e-mail], as another helpline. During this

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reporting period, 53 helpline calls and/or emails from the community were received to report possible illicit
discharges.

C.2.9 Establish procedures to identify and eliminate failed septic system and sanitary sewer overflows
When a sanitary sewer overflow or sewer leak is identified, and when a failed septic system is l ocated
within the Raleigh city limits, procedures outlined in the Engineering Services Department, Stormwater
Management Division Standard Procedure SW-100 Illicit Discharge Detection and Elimination are
followed.

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Section D: Construction Site Runoff Controls

D.1 Program Narrative
The City has had active construction site runoff control efforts (sedimentation and erosion control) since
the 1970s. This program is delegated and overseen by the North Carolina Department of Environmental
Quality (DEQ). This program includes ordinances, plan review, permitting, inspection, education, and
enforcement activities. The City receives and responds to calls and concerns from citizens on a regular
basis. All related ordinance changes are noticed and subject to public hearing prior to adoption.

D.2 Best Management Practices

D.2.1 Erosion and Sediment Control
Erosion and sediment control is delegated to the City by DEQ and is evaluated by DEQ annually. The
City has adopted an erosion and sediment control ordinance as part of its land development regulations.
This ordinance meets the DEQ Land Quality Division’s minimum requirements.

For this reporting period, program staffing included one stormwater development supervisor, one
stormwater reviewer supervisor, three senior stormwater engineers, two stormwater engineers, one
stormwater inspections supervisor, three regional stormwater inspection coordinators, and five
stormwater inspectors. Staffing levels varied somewhat during this period as vacancies occurred and
were filled. This group handles all plan review and field inspection responsibilities for the program.

D.2.2 Develop requirements for construction site operations
Requirements for construction are part of the City’s land development regulations. When plan approval
and permits are obtained for any land disturbing activity over 12,000 square feet, construction site
operators must coordinate with a stormwater compliance inspector. The site must be maintained per
these regulations throughout construction. Improper maintenance results in a notice of violation and/or a
civil penalty as outlined in the development regulations.

D.2.3 Educational and training opportunities for construction site operators
The City participates in annual training seminars for designers and contractors in cooperation with the
State and other local municipalities. This training provides construction contractors an overview of each
municipal sediment and erosion control program and associated requirements. There is no charge for
participating in this training seminar. No training was provided this reporting period.

D.2.4 Plan Reviews
Five stormwater engineers manage review and approval of stormwater plans for new development sites.
Stormwater, erosion and sediment control, and floodplain plans for new development are reviewed by
these staff members. Reviews include calculations and details for proposed stormwater devices. Senior
stormwater engineers review larger projects and projects where a stormwater device is shared between
multiple owners. Stormwater engineers review smaller commercial projects and single-owner projects.
Approximately 1,081 development plan reviews were conducted during this reporting period.

D.2.5 Public Information
Reports received concerning active construction sites are logged into a database and assigned to a
stormwater compliance inspector. During this reporting period, 465 calls regarding construction sites were

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received. Responses to callers generally are made within one business day of the received report. The
caller is contacted with the outcome when a resolution is obtained.

D.2.6 Inspection and Enforcement Procedures
Stormwater inspections are implemented by a stormwater inspector supervisor and a group of eight
stormwater compliance inspectors. During this reporting period, the City was divided into two regions
(Figure D-1), and a team of three stormwater compliance inspectors conducts inspections in each region
and coordinates with the regional senior stormwater engineer who reviews and approves erosion and
sediment control plans. In addition, a team of two stormwater compliance inspectors handles all single-
family lot-related inspections.

Figure D-1. Regional Stormwater Inspections Map

Approximately 13,364 construction site inspections were made during this reporting period, and
approximately 33 enforcement actions were initiated, including four fines for continuing violations.

Each team of stormwater compliance inspectors works together to address scheduled inspections,
routine inspections, pre-construction meetings, plan reviews and complaint calls throughout the region.
Inspectors coordinate and rotate through sites so that a “fresh” look is taken at each site and compliance
is consistently enforced. This team approach also allows the inspectors to provide excellent customer
service throughout their region even when a team member may be out on leave.

Regional coordinators serve as the primary point of contact, manage the regional permit database,
manage the routine inspection schedule, perform and document inspections, attend pre -construction

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meetings, perform plan reviews, and answer complaint calls. Stormwater inspectors perform and
document inspections, attend pre-construction meetings, perform plan reviews, answer complaint calls
and serve as a technical resource throughout the city, but primarily within their assigned region.

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Section E: Post-construction Site Runoff Controls

E.1 Program Narrative
The City’s post-construction site runoff controls remain in compliance with The City’s permit through the
Neuse Nutrient Sensitive Waters Management Strategy and Water Supply Watershed programs.

E.2 Post-construction Stormwater Management Program Measures

The City implements the Neuse Nutrient Sensitive Waters Management Strategy (15A NCAC 2B .0251)
throughout the planning jurisdiction of Raleigh. Water Supply Watershed IV (WS-IV) Programs (15A
NCAC 2H .0216) are implemented within the Falls Lake watershed, Swift Creek watershed, and Richland
Creek watershed.

The City’s post-construction site runoff controls are deemed compliant with the implementation of the
above-mentioned program measures.

The City has set up a private maintenance policy for owners of private properties with stormwater control
measures (SCMs). Every year, the private property owner must have a licensed professional engineer or
landscape architect certify the SCM is still functioning property and must send that certification to the City.
If these inspections are not made, then notification and enforcement actions are undertaken. Fines in the
amount of $40,000 were issued during this reporting period. There were 439 failures to submit annual
inspections during this reporting period; these owners were sent “not in compliance” reports, and the
failures were remedied and confirmed by City staff.

E.3 Best Management Practices

E.3.1 Establish a program under the post-construction minimum measure to control the sources of fecal
coliform to the maximum extent practicable

When a sanitary sewer overflow or sewer leak is identified, and when a failed septic system is located
within the Raleigh city limits, procedures outlined in the Engineering Services Department, Stormwater
Management Division Standard Procedure SW-100 Illicit Discharge Detection and Elimination are
followed.

The following reports of leaks, overflows, or discharges by City staff were investigated during this
reporting period through the Illicit Discharge Detection and Elimination program:
• 33 public agency sanitary sewer leaks or overflows,
• 16 private sanitary sewer leaks or overflows, and
• 1 septic system discharge.

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Section F: Pollution Prevention and Good Housekeeping for
Municipal Operations

F.1 Program Narrative
During this reporting period, the City’s Stormwater Management Division began transitioning from having
delegated responsibility for pollution prevention and good housekeeping to City departments that manage
the various City operations to educating, advising, supporting, and facilitating departments’ procedures
and practices. Stormwater Management staff assists City departments through regular site visits, online
training, educational activities, site assessments, advice, assistance with preparing stormwater pollution
prevention plans, and implementing SCM retrofits to capture and treat runoff.

F.2 Best Management Practices

F.2.1 Develop and Maintain an Inventory and Inspection Program for Municipally Owned Facilities
Stormwater staff has developed an inventory of 184 properties that have been identified as having
potential to impact stormwater. This inventory has been prioritized into categories of no exposure, low
priority, and high priority sites based on activities conducted at each site. This inventory uses GIS-based
software to populate a Cityworks inspections application that tracks inspections, site contacts, photos ,
and identified stormwater concerns. Each department has been responsible for developing and
maintaining individual operation and maintenance plans for its sites, with Stormwater Management staff
regularly assisting with site visits, resources and guidance.

F.2.2 Develop Site Pollution Prevention Plan for Municipal Facilities
Each department previously has been responsible for developing and maintaining stormwater pollution
prevention plans for its operations that could contribute to stormwater pollution, based on a template
prepared by Stormwater Management staff. During this reporting period, Stormwater Management staff
began planning to contract for professional services for preparing plans for the City’s high-priority sites, to
be implemented and maintained by each facility’s department with assistance from Stormwater
Management staff.

F.2.3 Inspection and evaluation of facilities, operations, and the MS4 system and associated
management practices
Stormwater staff used the newly created municipal site inventory to schedule and conduct site
inspections. Each of these 184 sites was inspected during this reporting period and prioritized as one of
the following: no exposure, low priority, or high priority. Stormwater staff provides guidance and
assistance to the City departments regarding best practices for pollution prevention and good
housekeeping during these site visits.

The City inspects and evaluates the physical condition and function of its MS4 through the Transportation
Field Services Division. During this reporting period, field staff responded to reports of MS4 operating
problems, resulting in regularly clearing of obstructions and debris from catch basins and pipes, sweeping
streets and curb lines, and using cameras to investigate and repair damaged infrastructure.

The City inspects and evaluates its regulated SCMs through post-construction site runoff controls,
addressed in section E of this annual report. Practices for inspecting and evaluating non-
regulated/voluntary SCMs are similar to those used for regulated SCMs.

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F.2.4 Conduct staff training
A new pollution prevention and good housekeeping training module was purchased and implemented
using the City’s iLearn platform. This platform allows training to be completed remotely and provides
regular reports tracking staff who have completed the training. Approximately 300 City employees
completed the training during this reporting period.

F.2.5 Review of municipality owned or operated regulated industrial activities
The following City facilities hold NPDES Industrial Stormwater Permits and are subject to operational and
reporting requirements separate from the City’s NPDES MS4 Permit requirements: Neuse River
Resource Recovery Facility, Smith Creek Wastewater Treatment Plant, Little Creek Wastewater
Treatment Plant, Solid Waste Service Center, Yard Waste Center, Raleigh Transit Operations Facility,
Raleigh Paratransit Operations Facility, and Downtown Remote Operation Facility. Each facility has a
site-specific stormwater pollution prevention plans and is inspected annually by Stormwater staff. All were
inspected during this reporting period.

F.2.6 Spill response procedures
City and Stormwater staff follow the procedures outlined in the City Standard Operating Procedu re –
Administrative Regulation Handling of Hazardous Materials Emergencies along with the Stormwater
Management Division Standard Procedure SW-101 (C) Managing Spills of Materials Which Threaten to
Enter the Stormwater Conveyance System.

Spill response procedures for municipal operations owned and operated by the City with the potential to
generate polluted stormwater runoff are included in the site-specific stormwater pollution prevention plans
for each individual City facility or operation. Stormwater Management staff has developed and made
available to all City departments SW-102 (B) Interdepartmental SOP for Managing Spills for any facility or
work group that does not have specific spill response procedures.

F.2.7 Prevent or minimize contamination of stormwater runoff from all areas used for vehicle and
equipment cleaning
Actions taken to prevent or minimize pollution of stormwater runoff from areas used for vehicle and
equipment cleaning are included in the site-specific stormwater pollution prevention plans developed for
each individual City operation. As part of the pollution prevention and good housekeeping program,
Stormwater staff have inventoried and completed site visits to all City -owned areas used for vehicle and
equipment cleaning during this reporting period.

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Section G: Public Education and Outreach

G.1 Program Narrative
The City provides a wide assortment of tools for reaching out to and educating the public including utility
bill inserts, newsletters, webpages, articles, presentations at workshops, classroom education, TV and
radio campaigns, and others. Tools and activities used are summarized below.

G.2 Best Management Practices
G.2.1 Identify target pollutants and target pollutant sources
The target pollutants identified for the 2013-2018 NPDES Stormwater MS4 Permit cycle included
nutrients, bacteria, sediment, and copper. Pollutant sources include atmospheric deposition, fertilizers,
sanitary sewer overflows, wild and domestic animal waste, construction project sites, stream bank
erosion, and general stormwater runoff.

G.2.2 Identify target audiences
The target audience included community members, businesses, and construction sites, with emphasis on
erosion and sediment control, and school children, with emphasis on demonstrations about water
pollution and common pollutants and on behavior change to improve the health of streams and lakes.

G.2.3 Informational website
Content on the City’s website, raleighnc.gov, provides information about stormwater, the stormwater
system, flood maps, floodplain mapping, capital improvement projects, water pollution, water quality
monitoring, real-time USGS stream flow data, small and large infrastructure projects, and volunteer
programs. The amount of traffic to the City’s website has increased substantially in recent years, with
more than 25,000 page views during this reporting period, up from 1,600 page views in 2016. The
increase is directly related to amplifying web content on other digital and print material and to the City’s
new website unveiled at the end of 2019.

The City is a partner of the Clean Water Education Partnership (CWEP), facilitated by the Triangle J
Council of Governments. CWEP manages and updates a general stormwater education website at nc-
cleanwater.org that provides information for community members, business owners, students, and
teachers about sources and effects of stormwater pollution and how they can help prevent pollution.
Outreach material includes social media, television public service announcements, radio public service
announcements, movie theater pre-roll public service announcements, and print advertisements.
Outreach to Hispanic community members include newspapers and other news media and direct
education and outreach contact at events using a part-time Spanish-speaking education specialist.

G.2.4 Develop and distribute public education material to identified user groups
The City has a general stormwater awareness brochure targeted for homeowners and students that
focuses on sources and causes of stormwater pollution and offers solutions for preventing pollution
around the home. English and Spanish versions are distributed to community members at community
events and at school presentations.

The City has a general illicit discharge prevention educational brochure and postcards targeted to specific

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types of businesses, including automobile services, food services, and landscape services. These
brochures are available to download from the City’s website and are distributed to businesses when first -
time violations of the illicit discharge ordinance are observed by staff.

G.2.5 Media campaign
The City uses its Raleigh Television Network and social media platforms (i.e. Twitter, Facebook, and
YouTube) to distribute stormwater education media campaigns. During this reporting period, the City
focused on creating short informational videos and other content for Facebook and Twitter that provided
information about Raleigh Rainwater Rewards, illegal discharges, stormwater education, stormwater
projects, and volunteer programs. The City also shared CWEP’s informational videos on stormwater
pollution via social media and on the City’s stormwater education webpage. All videos are available on
YouTube and generate traffic to the website. Social media accounts average 130,000 impressions a
month on Twitter (how many people see a post) and reach 200 people a month on Facebook.

In addition to providing videos and website and printed materials, CWEP produces a large multi -media
campaign including television public service announcements, radio public service announcements, and a
stormwater informational website, www.nc-cleanwater.org. The CWEP annual report for this reporting
period is submitted directly to NC DEMLR by the Triangle J Council of Governments on behalf of the City.

G.2.6 Establish hotline/helpline
The City has used the Stormwater Management Division’s main telephone line, [phone], as a
helpline since 1995. In 2016, the City added an email address [e-mail] as another
helpline for community members. These helplines are maintained during working business hours. During
this reporting period, 102 water quality-related helpline calls or emails were received.

G.2.7 Public Education and Outreach Program
Below is a summary of public education and outreach elements that were completed during this reporting
period:
1) Postcard direct mail sent to 500 swimming pool service companies operating in Raleigh,
partnering with Wake County.
2) Direct contact/interaction with 137community members about the Raleigh Rainwater Rewards
Program.
3) Flood and hurricane awareness event held in partnership with the NC Museum of Natural
Sciences and the Carolina Hurricanes for the public education/awareness.
4) Utility bill inserts for the City’s Urban Watersheds newsletter to 145,000 community members,
including flood-precaution information in July and general information about stormwater programs
in February (the newsletter also is distributed digitally on a quarterly basis). The City increased
print distribution from 800-1600 per year at community centers to 145,000 by direct reach to
community members.
5) One public presentation to citizens advisory committees prior to disbanding the CACs.
6) Four stormwater staff attendance at community festivals pre COVID.
7) One stream cleanup.
8) Two stream monitoring workshops.
9) 49 volunteer water quality monitoring events.
10) 40 presentations to school groups, faith communities and professional organizations, including
Earth Day events and Stormwater Management Advisory Commission Meetings.
11) News coverage in ABC 11, CBS17, Raleigh Magazine, Spectrum News, The News & Observer,
US News & World Report, WRAL, and WUNC.
12) Real-time data and flood information pushed out via social media during a storm.
13) 1,871 distribution of educational brochures at City offices and at outreach events .
14) Volunteer activities advertised through email marketing and social media platforms.

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15) Email campaigns focused on education/outreach opportunities in schools and the Capture it!
contest; Raleigh Rainwater Rewards; stormwater pollution awareness; volunteer opportunities;
development requirements for stormwater; flood education; stormwater control measure
inspections; rain barrel resources; and project updates .
16) 300 direct mail loose leaf/landscaper notification letters.
17) Nine public meetings of the Stormwater Management Advisory Commission, composed of 10
volunteer City residents, and 4 meetings of its Green Stormwater Infrastructure Committee .

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Section H: Program to Monitor and Evaluate Stormwater
Discharges to Municipal Systems

H.1 Program Narrative
A program to monitor stormwater management and housekeeping at facilities that hold Stormwater
NPDES Industrial Permits was added to the City’s NPDES Stormwater MS4 Permit with its renewal in
July 2007 and remains in the permits that were renewed in 2013 and 2018. This new program was
included in the City’s July 2008 Stormwater Management Plan and remains in the plan updated in May
2015. The City maintains a list of approximately 53 industrial facilities and 16 no exposure sites provided
by the North Carolina Department of Environmental Quality (DEQ). The City’s program provides for
inspecting facilities with Stormwater NPDES Industrial Permits at least every three years.

H.2 Best Management Practices
H.2.1 Maintain an inventory of industrial sites
The City maintains and updates a list of industrial facilities, as described in Section H.1. During this
reporting period, the City received no notifications from DEQ of changes in Stormwater NPDES Industrial
Permits within the area of the City’s NPDES Stormwater MS4 Permit. Annually, Stormwater staff contacts
DEQ at the beginning of each reporting year to reconcile the City inventory with DEQ’s list of industrial
facilities within the City.

H.2.2 Inspection program
The City maintains protocols for reporting to DEQ issues of noncompliance with Stormwater NPDES
Industrial Permits. Illicit discharge staff and stormwater inventory staff are trained in how to conduct
inspections and follow the procedures outlined in the Engineering Services Department, Stormwater
Management Division Standard Procedure SW-111 City of Raleigh Industrial Site Inspection. In addition,
the City uses information from drainage system inventory inspections, observation by stormwater
inspectors, and follow up to citizen complaints to identify and address problem facilities. The City
inspected 45 active industrial sites and 16 no exposure sites during this reporting period; of these, no
permitted industrial facilities were found to be out of c ompliance.

H.2.3 Establish and implement evaluation measures
The City evaluates compliance of facilities with Stormwater NPDES Industrial Permits in accordance with
conditions in each facility’s permit. A GIS inspection application is used to assess the facility, identify
areas of non-compliance and document observations and needed corrective actions.

21
Stormwater MS4 Permit Annual Report
Permit No. NCS000245

Section I: Water Quality Assessment and Monitoring

I.1 Program Narrative
The original monitoring required as part of the NPDES Stormwater MS4 Permit application included end-
of-pipe sampling for various land uses. More recent monitoring has moved away from end -of-pipe
monitoring and is focused primarily on ambient stream sampling. The City’s goal is to assess the status
and changes in water quality of water bodies in Raleigh. This is achieved through the application of the
practices detailed below.

I.2 Best Management Practices
I.2.1 Water Quality Assessment and Monitoring Plan
The City maintains a Water Quality Assessment and Monitoring Plan, dated 2010. This plan includes
monitoring locations, monitoring schedule, monitoring parameters, laboratory analytical methods, data
evaluation and assessment methods, and reporting protocols. The resulting data establish baseline levels
of water quality in each stream and provide an indication of the presence of pollutants in stormwater
originating in each watershed.

I.2.2 Water quality monitoring
Monitoring data were collected at the 18 monitoring sites identified in the Water Quality Assessment and
Monitoring Plan to characterize water quality conditions within major watersheds in the City’s jurisdiction.
Samples are collected four times per year. The September 2020 sampling was postponed to October due
to delays in contract routing with a new laboratory and, during this reporting period samples were
collected on December 10, 2019, March 10, 2020, and June 16, 2020. As a result, the City anticipates
collecting samples on five dates during the next (2020-2021) reporting period. Samples were analyzed for
E. coli, total phosphorus, turbidity, total suspended solids, total hardness, total Kjeldahl nitrogen, nitrate +
nitrite, ammonia nitrogen, copper, calcium, magnesium, and zinc by an NC DEQ certified laboratory. At
each site, City staff recorded pH, conductivity, salinity, dissolved oxygen, and temperature.

I.2.3 Revisions to Water Quality Assessment and Monitoring Plan
The Water Quality Assessment and Monitoring Plan is dated 2010. No changes have been made to this
plan since then.