The URL can be used to link to this page

Home My WebLink AboutCoWS MS4 Self-Audit Report sent to DEQ_5.5.22 without site visit evaluationsMUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4) PHASE I PROGRAM SELF -AUDIT REPORT NPDES PERMIT NO. NCS000247 CITY OF WINSTON-SALEM, NORTH CAROLINA 101 North Main Street City Hall, Suite 53 Winston-Salem, N.C. 27101 Self -Audit Timeframe: April 7, 2022 to May 4, 2022 Report Date: May 5, 2022 I ( I NCS000247 Winston-Salem 2022 MS4 Self -Audit Self -Audit Certification By my signature below, I certify, under penalty of law, that I am a Duly Authorized Representative* and this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. Name: Mr. Lee Garrity Title: City Manager Signature: 0 / Date: � �/y145 vl * A Duly Authorized Representative can be the Mayor, City Manager, or an authorized person or position. To be authorized, a Delegation of Signature Authority Form signed by the Mayor or City Manager must be on file with the Department. NC5000247 Winston-Salem 2022 MS4 Self -Audit TABLE OF CONTENTS Self -Audit Details, I I I I I I I I I I I I 1 0 1 1 11 1 1 1 1 1 1 1 1 1 1 1 0 1 0 0 a 0 1 0 1 1 1 4 11 0 1 0 6 1 0 4 a * A 0 0 *a 0 0 1 0 0 1 A . 0 h 0 1 1 0 1 , 0 1 0 4 0 . . . 0 0 P 0 4 4 0 4 0 0 0 1 . . I . 1 0 1 0 . . I I . 0 1 . I I . I I . I I . I . . . . I . 0 , 4 0 0 1 1 PermitteeInformation.....................6..0411..111111141111111.........1001.0.16111111116111411.0111..11011111111111111611.I..I..I.I.01......1011012 List of Supporting Documents. I I I I I I I I I I I I I I I I I . I I I . I . I 1 64 ......... 0 .... 3 Program Implementation, Documentation & Assessment...........................................................................5 Public Education and Outreach, I I I I I I I I I I I I a I I I I I I I I 1 6 1 1 1 1 1 1 9 6 N too I I a 1 4 6 a 4 1 1 a I a 0 0 1 4 t 0 N 0 0 4 1 1 1 1 1 1 t 0 1 a 0 1 6 t 0 4 N 4 0 1 1 1 1 1 1 1 1 1 4 0 0 V a I 1 0 4 0 0 4 a a 1 0 4 0 1 . . . . I . . I.68 Public Involvement and Participation.....................................................................................0...................11 Illicit Discharge Detection and Elimination(IDDE)......................................................................................15 Construction Site Runoff Controls..."..,,.,.." . I I 40W40,4 . I . . I a I I I I V 1 0 1 1 1 1 4 V I I I o I a V I a V a I I 1 4 4 6 1 0 6 1 1 too I 1 0 1 a 6 1 0 1 1 1 1 a a 6 1 d 6 a I I 1 4 1 a I I a I I I I I o 1 1 4 1 1 1 8 Post -Construction Site Runoff Controls.....................................................................................................120 Pollution Prevention and Good Housekeeping for Municipal Operations....,..,..,...... 11 11 1 110404427 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems....................................132 WaterQuality Assessment and Monitoring................................................................................................35 Site Visit Evaluation: Municipal Facility No. 1.............................................................................................38 Site Visit Evaluation: Municipal Facility No. 2.............................................................................................40 Site Visit Evaluation: MS4 0utfaII No. 1......................................................................................................42 Site Visit Evaluation: MS4 Outfall No. 2........................................................................................11140000400...44 Site Visit Evaluation: Construction Site No. 1...................................................:..........................:.............I.46 Site Visit Evaluation: Construction Site No. 2..............................................................................................48 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 1............................................50 Site Visit Evaluation: Post -Construction Stormwater Control Measure No. 2...........................................152 DISCLAIMER This audit consists of an evaluation of program compliance with the issued permit and implementation of the approved Stormwater Management Plan. This audit report does not include a review of all program components, and program deficiencies in addition to those noted may be present. The permittee is required to assess program progress and permit compliance, and to implement the approved Stormwater Management Plan in accordance with the issued permit. NCS000247 Winston-Salem 2022 MS4 Self -Audit iii Self -Audit Details Audit ID Number: Self -Audit Date(s): NCS000247_Winston-Salem 2022 MS4 Self -Audit April 7, 2022 to May 4, 2022 Minimum Control Measures Evaluated: ® Program Implementation, Documentation & Assessment X Public Education & Outreach ® Public Involvement & Participation ® Illicit Discharge Detection & Elimination ® Construction Site Runoff Controls ® Post -Construction Site Runoff Controls • Pollution Prevention and Good Housekeeping for Municipal Operations ® Program to Monitor and Control Pollutants M Water quality Assessment & Monitoring Field Site Visits: ❑ Municipal Facilities. Number visited: Choose an item. ❑ MS4 Outfalls. Number visited: Choose an item. ❑ Construction Sites. Number visited: Choose an item. ❑ Post -Construction Stormwater Runoff Controls. Number visited: Choose an item. ❑ Other: . Number visited: Choose an item. ❑ Other: . Number visited: Choose an item. Auditors Name Title Andrew Allen Assistant Stormwater Director Keith Huff Stormwater Director Audit Report Author Andrew K. Allen May 5, 2022 Name Date Assistant Stormwater Director �� ace, ago, Title Signature Audit Report Author Keith D. Huff May 5, 2022 Name Date Stormwater Director Title Signature NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 1 of 54 Audit Report Author Name Date Title Signature Audit Report Author Name Date Title Signature Permittee Information MS4 Permittee Name: City of Winston Salem Permit Effective Date: Permit Expiration Date: October 10, 2018 October 9, 2023 Mailing Address: P.O. Box 2511 Winston-Salem, N.C. 27102 Date of Last MS4 Inspection/Audit: June 2011 by SAIC (EPA -contracted auditors) Permit Owner of Record: City of Winston Salem Primary MS4 Representatives Participating in Audit Name Title Vicki Pigg Stormwater Operations Analyst Ladonta'Jamal' Clark Stormwater Operations Supervisor Joseph Fogarty Stormwater Engineer Matthew Osborne Erosion Control/Floodplain Manager NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 2 of 54 List of Supporting Documents Item Number Document Title Document Format (web link, a - file, etc.) 1 City of Winston-Salem's FY 2021-2022 Stormwater Management Plan PDF 2 Stormwater Division's IDDE SOP Manual PDF 3 An Example of the Stormwater Division's Notice of Violation and Supporting Documentation of Successful Completion PDF 4 BMPs for Public Educational Goals and Objectives PDF 5 Public Educational Outreach Counts Excel 6 Municipal NEW Employee Training Counts Excel 7 Municipal Employee PP&GH and IDDE Training Video Confirmation Excel 8 Stormwater Smart FY 2020-2021 Summary Report PDF 9 Stormwater Smart 2022 Invoice PDF 10 Municipal ALL (other than new) Employees Stormwater Training Video Excel 11 Chapter 75, Article I —the City of Winston Salem's IDDE Ordinance PDF 12 FY 2021-2022 Dry Weather Outfall Screening SOPS and Schedule PDF 13 The Stormwater Division's IDDE Discharge Master Spreadsheet for FY 2021-2022 Excel 14 DEMLR's Review Results Letter of the Winston-Salem/Forsyth County Erosion Control Program, Dated November 20, 2017 PDF 15 Erosion Control Division's Webpage Screen Shot of Pollution Hotline for Reporting Violations PDF 16 Screen Shot of Erosion Control's Flow -Process for Redirecting Project that use any Public Funds to DEMLR, Winston-Salem Regional Office PDF 17 The City of Winston-Salem's Post -construction Stormwater Ordinance PDF 18 The City of Winston-Salem's SCM Operation and Maintenance Agreement Templates for Homeowner Associations and Single Owners PDF 19 Escrow Agreement Template for Homeowner Associations PDF 20 The Stormwater Division's Inspection Master List of Municipal Facilities and Operations PDF NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 3 of 54 21 Municipally -owned Stormwater Control Measures (SCMs) Inventory List PDF 22 The Stormwater Division's FY -2020 to 2022 Inspected Municipal and Industrial Facilities and FY 2022-2023 Proposed Facilities to Inspect PDF 23 The Stormwater Division's Industrial and Municipal Inspection Form Template PDF 24 An Example of a Municipally -owned Stormwater Pollution Prevention Plan (SPPP) of Fleet Services (Template) PDF 25 An Example of a Municipally -owned Spill Response Plan of Fleet Services (Template) PDF 26 Field Operations' MS4 Inspection and Maintenance Program SOPS PDF 27 Street Sweeping Log of Municipally -owned Facilities/Parking Lots for FY 2021- 2022 Excel 28 Reference Lists of Small and Large Quantity Generators (SARA Title III) and Toxic Release Inventory (Hazardous Waste, Disposal, and Recovery Facilities) PDF 29 Master List of General and Individual Permitted Industrial Facilities within the Municipal Boundaries of Winston-Salem PDF 30 The Stormwater Division's Industrial Inspection SOP Manual PDF 31 Priority 1 and 2 Industrial and Municipal Facilities List, FY 2020-2023 PDF 32 The Stormwater Division's Water Quality Assessment and Monitoring Plan PDF NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 4 of 54 Program Implementation, Documentation & Assessment Staff Interviewed: Andrew Allen, Assistant Stormwater Director. Mr. Allen creates and discusses Stormwater Management Plan (Name, Title, Role) (SWMP) requirements to pertinent team members for the upcoming permit year. In addition, Mr. Allen is responsible for conducting an annual program evaluation, gap analysis, and as a result, generation of the next year's SWMP. Permit Citation Program Requirement Status supporting Doc No, ILA. The permittee maintained adequate legal mechanisms, such as regulations, Program ordinances, policies and procedures to implement all provisions of the Stormwater Yes 1 Implementation Management Plan (SWMP). The permlttee implemented provisions of the Stormwater Management Plan and evaluated the performance and effectiveness of the program components annually. Yes The permittee maintained written procedures for implementing the six minimum control measures, which identify specific action steps, schedules, resources and Yes responsibilities. The permittee is current on payment of invoiced administering and compliance monitoring fees (see storm water e-payments on https://deq.nc.gov/sw). Yes --- Comments The FY 2021-2022 SWMP contains the elements denoted in Section ILA. As a component of evaluating program effectiveness, the responsible party completes their section of the annual report and the Assistant Stormwater Director performs a gap analysis. The results of the gap analysis are discussed with the responsible party with accepted action items infused into the SWMP and programmatic implementation. III. The permittee-maintained documentation of all program components including, but Program not limited to, inspections, maintenance activities, educational programs, monitoring Documentation and sampling, implementation of BMPs, enforcement actions and other stormwater Yes activities. Documentation is kept on -file by the permittee for a period of five (5) years. Yes The permittee's Stormwater Management Plan is reviewed and updated as necessary, but at least on an annual basis. Yes Comments No major programmatic changes occurred in the City's Stormwater Management Plan from PY 2016 to 2019, thus the annual report did not change, other than the number of completed permit compliance measures. Multiple gap analyses were performed, but only a portion of recommended actions were implemented. Reasons for non -implementation include, but not limited to, resource limitations, staffing factor and COVID-19. IV'B' The permittee submitted annual reports to the Department by October 31st of each Annual Reporting calendar yearfor the previous fiscal year's activities (from July 1"tojune 301h). Yes --- The Annual Reports included appropriate information to accurately describe the progress, status, and results of the permittee's Stormwater Management Plan, including, but not limited the following: NCS000247_Winston-Salem 2022 M54 Self -Audit Page 5 of 54 Program Implementation, Documentation & Assessment a. A detailed description of the status of implementation of the Stormwater Management Plan. This includes information on development and implementation of each major component of the Stormwater Management Plan Yes for the past year and schedules and plans for the year following each report. b. A description and justification of any proposed changes to the Stormwater Management Plan. This includes descriptions and supporting Information for the proposed changes and how these changes will impact the Stormwater No Management Plan (results, effectiveness, implementation schedule, etc.). c. Documentation of any necessary changes to programs or practices for assessment of management measures implemented through the Stormwater Yes — Management Plan. d. A summary of data accumulated as part of the Stormwater Management Plan throughout the year along with an assessment of what the data indicates. Yes — e. An assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement actions. Yes f. Discussion of program funding. Yes -- Comments: Admittingly, the Stormwater Division did not include and implement all proposed changes from multiple gap analysis from PY 2016 — 2019 in the Stormwater Management Plan. Gap analyses results were denoted and submitted to the corresponding responsible party for implementation. Reasons for non -implementation include, but not limited to, resource limitations, staffing factor and COVID-19. IVD. The Permittee maintained a record of any illicit discharge that reaches waters of the Other Information state and may cause or contribute to a violation of the water quality standards or Yes 2,3 constitute an imminent threat to health or the environment. The record includes dates, identification of possible responsible parties, causes, and any action taken by the permittee or the responsible party. Yes Discharges that constitute an imminent threat to health or the environment were reported within 24 hours by phone or e-mail to the Division Regional Office during business hours, or to the NC Division of Emergency Management State Operations Yes --- Center hotline outside of business hours. Comments The Stormwater Division issues a Notice of Violation (NOV) to the responsible entity for illicit discharges or dumping that reach (or have the potential) the City's MS4 system or waters of the state. Each NOV states the required compliance items, due date, and potential fines, if action items are not completed. The Winston-Salem/Forsyth County Emergency Management and /or Stormwater Division staff notifies WSRO Regional Office, if imminent danger to public health is determined or if the National Response Center is notified. Please reference the attached example of an issued NOV and supporting compliance documentation that demonstrates the Stormwater Division's IDDE process for successfully eliminating pollutants to the MS4 and receiving waters. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 6 of 54 Program Implementation, Documentation & Assessment Additional 1) The Stormwater Division has uploaded the latest version of its Stormwater Management Plan for PY Comments: 2020-2021 for DEC's reference. Stormwater staff performed a comprehensive overhaul of its Plan with respective work outcomes to be reported to DEQ this upcoming annual report. 2) The Stormwater Division has uploaded its IDDE SOP Plan for DEQ's reference. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 7 of 54 Public Education and Outreach Staff Interviewed: Vicki Pigg, Stormwater Operations Analyst, supervised the Senior Community Educator from November 2021- (Name, Title, Role) April 2022. As of April 19, 2022, the job position of Senior Community Educator is vacant. Permit Citation Program Requirement Status supporting Doc No. 11.B.2.a. The permittee described the target pollutants and target pollutant sources that the Target Pollutants Yes 4 public education program is designed to address and why they are an issue. & Sources Comments The Senior Community Educator maintains a master document regarding best management practices for Public Education and Outreach and Public Involvement and Participation activities for the Stormwater Division. This document includes programmatic objectives, materials and programs developed, and goals for the Stormwater Division related to Public Education, Outreach and Public Involvement. This document is living and updated, as needed. Further and complete details regarding the selected BMPs for Public Ed/Outreach/Public Involvement. is available in the attached FY 2021-2022 Stormwater Management Plan and FY 2020-2021 Annual Report. This document is called "BMP for Pub Ed Intro Goals Objectives.docx" and resides here: (G:\Stormwater Educator- Education Outreach Public Involvement\SOPS\WordDocs of SOPS). Please reference the attached BMP document for DEQ's review. 11.B.2.b. The permittee described the target audiences likely to have significant stormwater Target Audiences impacts and why they were selected. ves 4 Comments The Senior Community Educator evaluates and shifts educational outreach focus, as needed, to address the needs and requests of the community. Method behind making these changes is documented in the "BMP for Pub Ed Intro Goals Objectives.docx" and this document lives here: (G:\Stormwater Educator - Education Outreach Public Involvement\SOPS\WordDocs of SOPS) Examples of minor shifting education focus: If we get more automotive related complaints, we address them with targeted education in the form of handouts or mailers (completed targeted mailer in 2020 to automotive businesses in the Salem Creek Watershed with English and Spanish information). We have gotten several more pet waste related complaints in 2020 and 2021 and targeted those neighborhoods with pet waste related door hangers and information. We also did several social media posts to NextDoor and Facebook to reach other homeowners and residents concerned about pet waste and worked with Stormwater SMART (and the committee) to choose pet waste as one of the mass media outreach topics for the region. Handouts available upon request. II.B.2.c. The permittee promoted and maintained an Internet web site designed to convey the Informational Yes S Web Site program's message. NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 8 of 54 Public Education and Outreach Comments The Stormwater Division's webpage is located at www.City ofws.org/stormwater. The main topics on Stormwater's website are (and corresponding, supporting minimum measure): 1) Main page— buttons to pay stormwater bill, post construction stormwater, help keep our waterways clean, storm drainage maintenance, info inside bar how to contact City Link 2) Do your part —volunteering information (public involvement and participation information) 3) For businesses — stormwater runoff information for businesses (industrial/commercial BMPs-targeted audience) 4) For residents —stormwater runoff information for residents (public involvement) 5) Fun stuff— kid's activities for educational awareness and growth (targeted audience for public outreach) 6) Capital improvement projects— information about current capital improvement projects (public involvement) 7) Report polluters— how to report polluters (IDDE program component) 8) Staff —staff listing (IDDE and public involvement) 9) Stormwater management — information about stormwater management program (public involvement and participation) 10) Stormwater runoff— information about stormwater runoff (public education and outreach) 11) Stormwater survey (public involvement and participation) 12) Stormwater billing and utility rate— information about stormwater utility fees (public education and outreach) 13) Erosion Control Information: https://www.City ofws.org/733/Erosion-Control (Construction Site Runoff Controls) 14) Drainage Maintenance Related Information: https://www.City ofws.org/1325/Drainage-Maintenance (Municipal Good housekeeping and Pollution Prevention) 11.B.2.d. The permittee distributed general stormwater educational material to appropriate Public Education Yes 5 target groups as likely to have a significant stormwater impact. Materials Comments Please reference the attached spreadsheet from November 2018 to the current for the number of distributed educational materials. This spreadsheet resides at: G:\Stormwater Educator - Education Outreach Public Involvement\Ed & Outreach Programs Spreadsheet title is "Ed_Outreach—Counts.xlsx" For workload data collected prior to November 2018, staff consults the spreadsheets saved at this location: G:\Stormwater Educator -Education Outreach Publiclnvolvement\Ed & Outreach Programs\Ed & Outreach Counts from Roseann 2010-2018- 11•B•2•e• The permittee promoted and maintained a stormwater hotline(s) or helpline(s) for Stormwater the public to request information about stormwater, public involvement & Yes Hotline participation, and to report illicit connections & discharges, etc. Comments In 2005, City Council commissioned the creation and implementation of a centralized telephone call center/web-based complaint hotline for the citizens of the City of Winston-Salem. Known to the public as City Link, this communication center receives citizen - generated a -mails or telephone calls regarding stormwater-related items illicit within the City. The public can access City Link from the City of Winston-Salem's homepage of https://www.City ofws.org/; the City Link button appears at the top portion of the City's homepage and the City Link contact information appears at the bottom of all City webpages. On the Stormwater Division's homepage on the City website, the City Link contact information is provided at the top of the page. The City Link contact information is shared on every public brochure made available by the Stormwater Division, On May 14, 2021, The City of Winston- Salem added a Chat feature to our City website which enable citizens to communicate via chat with our City Link staff. The Chat icon is in the bottom right hand of the City webpage. The Senior Community Educator receives electronic notifications for presentation requests from City Link or directly from website requests. Illicit discharges are received through the Stormwater Pollution Hotline (336-727-8000). which is operated by City Link, City Link refers all illicit discharge complaints to Stormwater staff, who will investigate these reports within 24 hours. NCS000247_Winston-Salem 2022 M54 Self -Audit Page 9 of 54 Public Education and Outreach 11.6.2.f. The permittee's outreach program, including those elements implemented locally or Public Education through a cooperative agreement, include a combination of approaches designed to Yes 5,6,7,8,9, & Outreach reach the target audiences. 10 Program Implementation For each media, event or activity, including those elements implemented locally or through a cooperative agreement, the permittee estimated and recorded the extent Yes of exposure. Comments All public participation and public education and outreach activities are documented in the Stormwater Division's Annual Report every year and submitted to NC DEQ. A spreadsheet is also maintained with the relevant workload information (list of programs, p of attendees, etc.). See attached spreadsheets (for November 2018 onward - G:\Stormwater Educator- Education Outreach Public Involvement\Ed & Outreach Programs, Spreadsheet title is "Ed_Outreach Counts.xlsx". For data prior to November 2018, please see spreadsheets saved in this folder: G:\Stormwater Educator - Education Outreach Public Involvement\Ed & Outreach Programs\Ed & Outreach Counts from Roseann 2010-2018). The Stormwater Division is a participating member of Stormwater SMART, a regional consortium of NC Piedmont communities that provides stormwater public education services for participating members. In addition, the Stormwater Division contributes financially each year to Stormwater SMART for the generation of educational materials and media outreach. Stormwater SMART submits its annual report to consortium members to document their activities/outreach efforts (see attached annual reports from Stormwater SMART). Media campaigns completed by the Stormwater Division are documented in a report from the vendor with the engagement results and other mass media outreach efforts done by the Stormwater Division are all saved here: G:\Stormwater Educator - Education Outreach Public Involvement\Mass Media. Additional None Comments: NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 10 of 54 Public Involvement and Participation Staff Interviewed: Vicki Pigg, Stormwater Operations Analyst, supervised the Senior Community Educator from November 2021- (Name, Title, Role) April 2022. As of April 19, the job position of Senior Community Educator is vacant. Permit Citation Program Requirement Status supporting Doc No. II.C.2.a. Volunteer The permittee included and promoted volunteer opportunities designed to promote Community Yes 3 Involvement ongoing citizen participation. Program NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 11 of 54 Public Involvement and Participation The City of Winston-Salem has implemented the following programs to various degrees inor er to promote volunteer opportunities and ongoing citizen participation: • Creek Week is a week-long series of events geared to engage the public and support water quality awareness. Events usually include Creek Crawls, photo contest, guided paddles and nature walks, lunch and learn presentations, a community read and book discussion, professional development workshops, homeowner and resident workshops, special children and teen's programs at the public libraries, community clean-ups, water centered recreational activities, and other interactive programs. Creek Week occurs in March and is organized by a committee of municipal, county, and non-profit organizations. • Creek Crawls are held with local school classes where the students visit a nearby creek to examine the water quality of the stream using water quality test kits and visual observations. Benthic macroinvertebrates are collected, examined, and discussed as to form an overall assessment of the water quality of the selected stream. Students are taught to collect water samples and to identify the macrolnvertebrates collected based on provided keys as part ofthis 'hands on' approach. • The Stormwater Division co -coordinates the Adopt -A -Stream program with Keep Winston-Salem Beautiful to reduce litter, debris, and floatables in our waterways. Homeowner associations, companies, special interest groups, families or other interested parties can request to Adopt -A -Stream in their area of interest. Interested parties will commit to conducting three clean-ups per year and the City will provide signage and debris removal after each cleanup. Keep Winston-Salem Beautiful also coordinates Adopt -A -Street and Adopt -A -Park programs to reduce litter, debris, and floatables in our community. • Big Sweep is conducted every year in October to remove trash and debris from local waterways. • The Great American Clean -Up in Winston-Salem is conducted every year in April to remove trash and debris from local streets, parks, and waterways. • The Stormwater Division coordinates the Storm Drain Marking program where volunteer groups place adhesive 'No Dumping, Drains to Creekmarkers or use a provided storm drain marking stencil and spray paint on catch basins and other drainage structures within the community. Volunteer groups also distribute door hangers that contain Stormwater education material informing citizens about fertilizer use, pet waste and illegal dumping within targeted neighborhoods due to the number of reoccurring complaints. • The Stream Watch in Winston-Salem program encourages volunteers to visit local Winston-Salem waterways to make various visual observations about the habitat and water quality. Observations are shared through a paper survey emailed back to the stormwater division. Volunteers are provided with Winston-Salem specific stormwater and stream educational information to help guide them through their visual observations. Volunteers are encouraged to report any illicit discharges they observe while participating in Stream Watch in Winston-Salem. Please reference the attached spreadsheet for Stormwater volunteer participation (for November 2018 onward - G:\Stormwater Educator -Education Outreach Public Involvement\Ed &Outreach Programs, Spreadsheet title is "Ed_Outreach_Counts.xlsx". For data prior to November 2018, please see spreadsheets saved in this folder: G:\Stormwater Educator- Education Outreach Public Involvement\Ed & Outreach Programs\Ed & Outreach Counts from Roseann 2010-2018). KWSB maintains records of KWSB sponsored clean-ups and shares these with the Stormwater Division for reporting purposes. These programs are all advertised on the Stormwater Website (https://www.City ofws.org/718/Do-Your-Part) or KWSB website (https://www.City ofws.org/405/Keep-Winston-Salem-Beautiful) or through advertising completed by the Marketing and Communications Department (via the City's own social media or other paid advertising). NC5000247_Winston-Salem 2022 M54 Self -Audit Page 12 of 54 Public Involvement and Participation II.C.2.b. Mechanism for The permittee provided and promoted a mechanism for public involvement that Public provides for input on stormwater Issues and the stormwater program. Yes --- Involvement Comments The City of Winston-Salem has three main mechanisms for public input on stormwater issues as well as soliciting feedback regarding Stormwater's Management Plan; these three mechanisms include City Council Committee meetings, Stormwater Appeals Board, and City Link's'suggestion and comment' service. The City Council (and Public Works Committee) have established open public meetings that citizens are invited to attend to discuss any stormwater-related topic. Public Works Committee meetings are advertised on the City's website and are held the second Tuesday of every month. City Council convenes twice a month - every meeting has an open floor segment, where citizens may voice their stormwater-related concerns. The Stormwater Appeals Board has been created to hear appeals if an owner, developer, engineer or other party disagrees with the decision of Stormwater staff. As of late, the Public Works Committee of the City Council has heard any appeals and carried them to resolution. City Link has instituted a citizen 'suggestion and comment' service request that allows any citizen to submit suggestions or comments, which relates to the Stormwater Management Program. These suggestions or comments are forwarded to the Department Head for review and implementation, if approved. The permittee promoted and maintained a hotline/helpline for the public to request II.C.2.c. information about stormwater, public involvement & participation, and to report Yes --- Hotline/Help Line illicit connections & discharges, etc. Comments In 2005, City Council commissioned the creation and implementation of a centralized telephone call center/web-based complaint hotline for the citizens of the City of Winston-Salem. Known to the public as City Link, this communication center receives citizen - generated a -mails or telephone calls regarding stormwater-related items illicit within the City. The public can access City Link from the City of Winston-Salem's homepage of https://www.City ofws.org/ or by the chat feature on the City of Winston-Salem's webpage; the City Link button appears at the top portion of the City's homepage and the City Link contact information appears at the bottom of all City webpages. On the stormwater Division's homepage on the City website, the City Link contact information is provided at the top of the page. The Senior Community Educator receives electronic notifications for presentation requests from City Link or directly from website requests. Illicit discharges are received through the Stormwater Pollution Hotline (33&727-8000), which is operated by City Link. City Link refers all illicit discharge complaints to Stormwater staff, who will investigate these reports within 24 hours. II.C.2.d. The permittee made the most recent Stormwater Management Plan available for Public Comment public review and comment. Yes --- Comments The current Stormwater Management Plan was posted to the Stormwater Division's webpage in November 2021. One can locate the Stormwater Management Plan at https://www.City ofws.org/DocumentCenter/View/22898/Stormwater-Management-Plan-FY- 2021-2022-pdf The permittee complied with State, Tribal and local public notice requirements when II.C.2.e. Public Notice implementing the public involvement / participation program. Yes NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 13 of 54 Public Involvement and Participation Comments The City of Winston-Salem complies with applicable public notice requirements, when implementing its public involvement and participation program. Compliance with 40 CFR 122.34 is achieved by working with the City Secretary's Office, Marketing and Communications and the Community Assistance Specialist for scheduling, advertising, and posting public meetings. Additional None Comments: NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 14 of 54 Illicit Discharge Detection and Elimination (IDDE) Staff Interviewed: Ladonta 'Jamal' Clark, Stormwater Operations Supervisor, oversees, manages, and enforces the Stormwater (Name, Title, Division's IDDE program for permit compliance. Role) Permit Citation Program Requirement Status supporting Doc No. II.D.2.a. The permittee maintained adequate ordinances or other legal authorities to prohibit Legal Authorities illicit connections and discharges and enforce the approved IDDE Program. Yes 11 Comments: City Council adopted the City's Illicit Discharge Ordinance in September 2005, Currently, the City of Winston Salem's IDDE ordinance is contained within Municode, Chapter 75, Article I. Stormwater staff uses the City's IDDE ordinance for regulatory compliance to cease illicit discharges and connections from entering the MS4/receiving waters. The program involves identifying and eliminating illicit substances and materials; staff issues Notices of Violations (NOVs) to the offending entity for permanent resolution of illicit activity. The base file address is: G: JTechn Pro%ects_Files JIDDE- Complaints and NOVs. The file address for the Chapter 75 ordnance Is: G: jTechnProjects Files)IDDE -Complaints and NOVsiChapter 75 Article 1002.1b. The permittee maintained a current map showing major outfalls and receiving M$4 Mapping Yes --- streams. Comments The City's GIS database is comprehensive; the Stormwater Division contracts a professional engineering firm, HDR, to collect stormwater inventory (e.g., pipes, structures, major SDOs, etc.) and the corresponding attribute data on a regular basis. A NC licensed surveying firm, MLA, performs in -field data collection and assessment services with HDR integrating the GIS data into the appropriate geodatabase layer (as well as performing proper QA/QC data checks). MLA and HDR (and Stormwater staff) ensure that all inventory is collected to the applicable major stormwater discharge diameter (36 inches for residential zoned land use areas or drainage areas greater (or equal) than 50 acres OR 12" in industrial zoned land areas or drainage areas greater (or equal) to two acres. In addition, all stormwater infrastructure within the City's right-of-way Is mapped and enters the geodatabase layer, as well, since the City owns and operates this system. The City's GIS data is housed in its SDE database and operates in the ArcMap program. The stormwater inventory map can be used to track the connectivity of pipes to locate illicit discharges. For FY 2021-2022, HDR has concentrated inventory reconnaissance activities in Lower and Middle Creek Subwatersheds, Upper and Lower Muddy Creek Subwatersheds, portion of Lower Silas Creek Watershed, and a section of Upper Peters Creek Watershed. These areas were selected due to prioritized impaired segments of TMDLs watersheds and routine watershed masterplan updates. Approximately 2,300 major SDOs were inventoried, and 14 miles of streams were assessed. Also, identified inventory that needed updating due to various capital improvement projects, were surveyed and corrected. II.D.2.c. The permittee maintained written procedures and/or Standard Operating Procedures Dry Weather Flow (SOPS) for detecting and tracing the sources of Illicit discharges. Yes 2 Program The permittee maintained written procedures and/or Standard Operating Procedures (SOPS) for removing the sources or reporting the sources to the State to be properly Yes permitted. The permittee maintained written procedures and/or SOPS that specify a timeframe for monitoring and how many outfalls and the areas that are to be targeted for Yes 12 inspections. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 15 of 54 Illicit Discharge Detection and Elimination (IDDE) Comments Please reference the attached Item #2, IDDE SOP Manual, for documentation of these above -mentioned BMPs. In addition, please reference the attached document, Item #4— FY 2021-2022 Dry Weather Outfall Screening SOPs and Schedule that shows this year's timeframe and targeted stream segments for dry weather screening activities. Item #4 is a standalone document from the IDDE SOP Manual but bolsters the City's IDDE program. For this upcoming permit year, Stormwater staff will evaluate FY 2021-2022 water quality data to determine the most impaired stream segments, then create a prioritization list for SDO and stream -walking reconnaissance activities. II.D.2.d. The permittee conducted training for appropriate municipal staff on detecting and Employee Training reporting illicit connections and discharges. Yes 10 Comments During FY 2021-2022, the Sr. Community Educator, Stormwater Operations Analyst, and the City's Marketing and Communications Department created a new training video that highlights proper pollution prevention & municipal goodhousekeeping practices for key City operations to eliminate pollutant exposure to the environment. A main topic in this video pertains to recognizing and reporting illicit discharges/dumping activities to Stormwater staff, so more incidents can successfully resolve by Stormwater staff, thanks to 'rank and file' City team members. From November 2021 to March 2022, 2,127 out of 2,354 City employees (90.3%) viewed and passed a confirmation test of Stormwater's new PP & MGH and IDDE training video. II.D.2.e. The permittee maintained and publicized reporting mechanism(s) for the public to Public Reporting report illicit connections and discharges. Yes --- Comments City Link, the City's centralized citizen reporting center, receives phone calls, emails, social media apps, and Internet inquiries for a myriad of City resource requests. As an option of reporting, citizens can file illicit discharge/dumping claims to City Link. Once a City Link Customer Service Representative intake the complaint, an automated email message (with all pertinent case information) is sent to the Stormwater Operations Supervisor (SOS), Stormwater Operations Analyst, and Assistant Stormwater Director (ASD). Next, the SOS or ASD assigns the service request to a Stormwater Technician (or responds themselves, if staff is busy with their current workload. The City publicizes City Link by using communicative means of the internet, radio, and television - please reference the embedded link below. City Link's contact number is (336) 727-8000. In addition, Stormwater Division maintains a reporting illicit discharges option on-line at https://www.City ofws.org/817/Report- Polluters. This webpage contains City Link's contact number and general questions to collect illicit discharge information. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 16 of 54 Illicit Discharge Detection and Elimination (IDDE) I I. D.2.f. Documentation The permittee documented the date of investigations, any enforcement action(s) or Yes 3, 13 remediation that occurred. Comments Stormwater staff tracks and documents every IDDE complaint and investigation by various means. Rock Solid is the service request database that the City uses to intake, track, and manage all IDDE complaints. If Stormwater staff receives IDDE complaints directly, these complaints are entered into Rock Solid. Each cataloged service request is date and time stamps by the responsible person; all information cannot be erased, once entered. Rock Solid displays the status of the service request — staff manually needs to change the status, once compliance items have been successfully completed. Apart from Rock Solid, every IDDE investigation has its own electronic folder on the G: drive and the responding staff member completes an investigation report, which documents the date, address, location, parcel identification number, finding of facts, and resulting compliance actions to be taken (if warranted). All enforcement actions are documented in the form of a Notice of Violation (NOV) -this enforcement mechanism explicitly states what corrective actions are required by the offering party, due date, and potential fines, if corrective actions are not completed. As a component of the NOV, the offending party must submit remedial documentation (if applicable) to the Stormwater Division, or a staff member must perform a site inspection to confirm successful completion of all required measures. The responding Stormwater staff member(s) documents all successful measures via photographs, information documentation in Rock Solid, email, and inspection reports, once all measures are confirmed by Stormwater staff, a successful completion letter is issued to the responsible party. Lastly, a master Excel spreadsheet tracks all pertinent information of each IDDE investigation, which includes resolution date, POCs, inspector, etc. —the incident location is mapped on a master GIS layer for a geographical reference. The City has attached this master Excel spreadsheet for DEC's reference. Additional Comments: NC5000247_Winston-Salem 2022 MS4 Self -Audit Page.17 of 54 Construction Site Runoff Controls Staff Interviewed: Matthew Osborne, Erosion Control/Floodplain Program Manager (Name, Title, Role) Program Delegation Status: The permittee has a delegated Sediment and Erosion Control Program to implement the North Carolina Sedimentation Pollution Control Act (SPCA) of 1973 and Chapter 4 of Title 1SA of the North Carolina Administrative Code. The delegated or authorized Sediment and Erosion Control Program effectively meets the NPDES MS4 MEP standard for Construction Site Runoff Controls by permitting and controlling development activities disturbing one or more acres of land surface and those activities less than one acre that are part of a larger common plan of development as authorized under the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. Permit Citation Program Requirement Status Supporting Doc Na. II.E.2.a. Delegated SPCA The permittee implements a delegated program in compliance with the Program Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the Yes JA North Carolina Administrative Code within the City's jurisdictional area. Comments (Note date of last SPCA delegated program review by NCDEQ-DEMLR staff and result) The most recent delegated program review by NCDEQ-DEMLR staff was July 25, 2017. The result of the delegated program review was a recommendation by NCDEQ-DEMLR staff to continue delegation of the program. II.E.2.c. The permittee provided and promoted a means for the public to notify the Reporting appropriate authorities of observed erosion and sedimentation problems. re: 15 Mechanism Comments Yes, through information provided on our Erosion Control website (https://www.City ofws.org/733/Erosion-Control). The public can call the City of Winston-Salem's Pollution Hotline at (336) 727-8000 or 311 to report sedimentation discharge claims. Citizens can email City Link at City link@City ofws.org to report these claims as well. II.E.2.d. The permittee coordinated the approval of the construction site runoff control with Coordination with DEMUR for new development and redevelopment projects to be built within the Yes 16 DEMUR permittee's planning jurisdiction by entities with eminent domain authority. Comments Projects with eminent domain authority are referred/forwarded to NCDEQ-DEMLR staff at the Winston-Salem Regional Office by providing a standard comment of referral on plan reviews where Erosion Control staff determine it to be applicable. All projects that receive public funding (from governmental agencies, full or partially funded) are referred/forwarded to NCDEQ-DEMLR staff at the Winston-Salem Regional Office for review and approval. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 18 of 54 Construction Site Runoff Controls Additional None Comments: NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 19 of 54 Post -Construction Site Runoff Controls Staff Interviewed: Joe Fogarty, Stormwater Engineer. Reviews and approves submitted plans for compliance with City's post - (Name, Title, Role) construction ordinance. Ensures all operation and maintenance agreements for SCMs are properly executed and recorded. Oversees Stormwater staff (or performs) concerning SCM inspections (private and public) and ensures appropriate correspondence to transmitted to responsible parties. Program Implementation (check all that apply): ® The permittee implements the components of this minimum measure. ❑ The permittee relies upon another entity to implement the components of this minimum measure: list name of entity ❑ The permittee implements the following Qualifying Alternative Program(s), which meet NPDES M54 post -construction requirements in the areas where they are implemented and in compliance with the specific program requirements as provided in 15A NCAC and noted below: ❑ Water Supply Watershed I (WS-1) —15A NCAC 213.0212 (Eff. March 1, 2019 15A NCAC 02B .0620-.0624) ❑ Water Supply Watershed II (WS-11) —1SA NCAC 28 .0214 (Eff. March 1, 2019 15A NCAC 026 .0620-.0624) ❑ Water Supply Watershed III (WS-III) —15A NCAC 2B .0215 (Eff. March 1, 2019 15A NCAC 02B .0620 - .0624) ❑ Water Supply Watershed IV (WS-IV) —15A NCAC 213.0216 (Eff. March 1, 2019 15A NCAC 02B .0620-.0624) ❑ Freshwater High Quality Waters (HOW) —15A NCAC 2H .1006 ❑ Freshwater Outstanding Resource Waters (ORW) —15A NCAC 2H .1007 ❑ Neuse River Basin Nutrient Sensitive (NSW) Management Strategy-15A NCAC 2B ,0235 ❑ Tar -Pamlico River Basin Nutrient Sensitive (NSW) Management Strategy —15A NCAC 2B .0258 ❑ Randleman Lake Water Supply Watershed Nutrient Management Strategy-15A NCAC 2B .0251 ❑ Universal Stormwater Management Program —15A NCAC 2H .1020 Regulatory Authority: The permittee utilizes the following ordinances and/or regulatory authority to fulfill post construction minimum measure program requirements (check all that apply): ❑ DEQ model ordinance ® MS4 designed post -construction practices that meet or exceed 15A NCAC 02H :1000 ❑ DEQ approved comprehensive watershed plan ❑ DEQ approved Qualifying Alternative Program listed above Program Requirement Status supporting Doc No. The permittee implements the Qualifying Alternative Program requirements No checked above in accordance with the applicable 15A NCAC rules. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 20 of 54 Post -Construction Site Runoff Controls 02H .1017 The permittee cumulatively implements the Qualifying Alternative Program Qualifying No requirements checked above throughout the entire MS4 permitted area. Alternative Program(s) If response is no or partial, the permittee implements MS4 post - construction requirements in accordance with 15A NCAC 02H .1017(3) — Yes 17 (14) throughout the balance of the MS4 permitted area. Comments Permit Citation Program Requirement Status supporting Doc No, II.F.2.a. The permittee maintained an ordinance or similar regulatory mechanism that Legal Authority authorizes a program to address stormwater runoff from new development and Yes 17 redevelopment to the extent allowable under State law. Comments The Stormwater Division oversees and enforces the City's post -construction stormwater management program. The City of Winston-Salem has supplemented previous water supply watershed regulations with current post -construction regulations for Class 'C' waters in order to address stormwater runoff from new and redeveloped sites. The current Post Construction Stormwater Management ordinance was adopted by the City Council on September 19, 2008, and this ordinance applies to all development within our jurisdictional area (municipal boundary). The City's Post -construction Ordinance can be located at https://I ibra ry. m un icod e.com/nc/wi nston-salem/codes/code—of—ordinances?nodel d=PTI I ICOO R—CH75STMA_ARTI V POCOST, II.F.2.b. The permittee maintains strategies that include a combination of structural and/or Stormwater Control non-structural SCMs in concurrence with the legal authorities above (II.F.2.a.). Yes Measures (SCMs) The permittee provides a mechanism to require long-term operation and maintenance of structural SCMs. Yes --- The permittee requires annual inspection reports of permitted structural SCMs Yes performed by a qualified professional. The permittee implements SCM requirements that are at least as stringent as the Yes 17 minimum requirements in 15A NCAC 02H .1000. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 21 of 54 Post -Construction Site Runoff Controls The City ofWinston-Salem's Post Construction Stormwater Management ordinance provides sizing and performance criteria for water quality and quantity SCMs. The City of Winston-Salem has also adopted the State's Stormwater Design and NCDOT Linear Transportation Toolbox as technical guides for designing structural SCMs within Its jurisdictional area and thus for use in also providing sizing and performance criteria, in combination with the ordinance provisions. The ordinance addresses both low density and high -density development scenarios as regards water quality attenuation. Low density developments (less than 24 percent built upon area, or less than two dwelling units per an acre) must meet all the Minimum Design Criteria (MDC) of the NC DWR Stormwater Design Manual —Low Density Chapter, to the maximum extent practicable. Such items include but are not limited to recording of stream buffers where applicable and using vegetative conveyances to the maximum extent practicable. High density developments (greater than 24 percent built upon area and more than two dwelling units per acre) in addition to meeting all the low density non-structural SCM requirements, to the maximum extent practicable, must also provide structural SCMs. Any SCM or combination of SCMs that are considered 'Primary' SCMs per the Stormwater Design Manual and that can be effectively constructed in the Piedmont physiographic region may be approved by the Stormwater Engineer or Stormwater Director. In addition, the Post Construction Stormwater Management ordinance also includes a local requirement for water quantity standards if a development creates more than 20,000 square feet of new impervious area. If that is the case a development must either, (a) design structural SCMs in order to mitigate detrimental downstream effects of flooding and erosion in various design storm events, or in lieu of management provide a "no adverse impact downstream study" if indeed a no adverse impact situation can be proven. Stormwater staff inspect approved water quantity SCMs (pre-2008 post -construction ordinance adoption) as well as the Salem Lake Watershed (Water Supply IV Classification) SCMs on an annual basis. Next, Stormwater staff informs the owners of record of any deficiencies noted so that they may be addressed. Operation and Maintenance Agreements are required to be approved, recorded and Implemented for all the developments located within the Salem Lake Watershed area that require SCM(s) and the owners of such SCMs are bound to the terms of that agreement. SCMs, within the City limits jurisdiction and approved after the adoption of the post -construction ordinance, must have an Operation and Maintenance Agreement recorded as part of the post construction permit process that is binding on the SCM owner. The responsibility of SCM inspection and maintenance is placed on the designated SCM owner, or Homeowners Association/Property Owners Association, as applicable, who has signed the recorded Operation and Maintenance Agreement. The requirements for such inspections and maintenance are outlined in an Operation and Maintenance Manual that forms part of the overall Operation and Maintenance Agreement. Beginning after the certification of the as -built drawings for a permitted stormwater management system, the system must be inspected per the frequency described in this agreement by a suitably qualified professional on behalf of the owner. The owner must keep all records of these inspections and any maintenance activities that may have been necessary and submit these records to the Stormwater Director for review on an annual basis. The Stormwater Director or his designee may carry out his own inspection to validate such submitted records. II.F.2.c. Deed Restrictions The permittee provides mechanisms such as recorded deed restrictions, plats, and Protective and/or protective covenants so that development activities maintain the project Yes 18 Covenants I consistent with approved plans. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 22 of 54 Post -Construction Site Runoff Controls Comments The City of Winston-Salem created, adopted, and implemented its post -construction ordinance on September 19, 2008. This ordinance includes comprehensive regulatory procedures in order to ensure compliance. Right of entry drainage and access easements must be granted to the City to inspect, monitor, maintain, repair, or to reconstruct the stormwater management system as necessary and these easements are referenced in the recorded Operation and Maintenance Agreements, Notice of Violations, remedies, and monetary penalties are examples of regulatory tools contained within the post -construction ordinance that the Stormwater Division utilizes as enforcement mechanisms. For further reference, the City's Post -construction Stormwater Control Ordinance (Chapter 75, Article IV) can be located at this link: https:Hlibrary,municode.com/nc/winston- salem/codes/code_of_ord ina nces7nodeld=PTI I ICOOR_CH75STMA_ARTI VPOCOST II.F.2.d. The developer provides the permittee with an operation and maintenance plan for Operation and the stormwater system, indicating the operation and maintenance actions that Maintenance Plans shall be taken, specific quantitative criteria used for determining when those Yes 18,19 actions shall be taken, and who is responsible for those actions. The plans clearly indicate the steps that shall be taken and who shall be responsible for restoring a Stormwater system to design specifications if a failure occurs. No 18 The plans include a legally enforceable acknowledgment by the responsible party. No 18 Development is maintained consistent with the requirements in the approved plans. yes 18 Modifications to those plans must be / are approved by the Permittee, yes 18 NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 23 of 54 Post -Construction Site Runoff Controls SCM5, within the City limitslurs on and approved after the adoption of the 2008 Post -construction Ordinance, must have an Operation and Maintenance Agreement recorded as part of the post construction permit process that is binding on the SCM owner. The responsibility of SCM inspection and maintenance is placed on the designated SCM owner, or Homeowners Association/Property Owners Association, as applicable, who has signed the recorded Operation and Maintenance Agreement. The requirements for such inspections and maintenance are outlined in an Operation and Maintenance Manual that forms part of the overall Operation and Maintenance Agreement. Beginning after the certification of the as -built drawings for a permitted stormwater management system, the system must be inspected per the frequency described in this agreement by a suitably qualified professional on behalf of the owner. The owner must keep all records of these inspections and any maintenance activities that may have been necessary and submit these records to the stormwater Director for review on an annual basis. The Stormwater Director or his designee may carry out his own inspection to validate such submitted records. All structural SCMs approved in accordance with the Post -Construction stormwater Management ordinance must have a financial surety that meets the requirements of the ordinance provisions, in force prior to permit issuance. For a developer who wants to remain the party responsible In perpetuity for the long-term Operation and Maintenance of the system, a payment into the City's Catastrophic Failure Fund shall equal four percent of the estimated construction cost of the stormwater management system, verified by submittal of a sealed engineers estimate. This payment is maintained a City account and is non-refundable. The developer may apply for a loan from this account if needed to address system deficiencies. For SCMs that are to be owned and operated by a HOA or POA, then the surety that is required is in the form of an escrow account and escrow agreement. The developer establishes an escrow account at the time of permitting and deposits 15 percent of the estimated construction cost of the stormwater management system into this account, with the HOA/POA to add further funds in the future. An escrow agreement must be approved and recorded during the permit process, which allows the City access to this escrow account, and its funds if needed should a SCM owner fail to comply with maintaining the system. II.F.2.e. Educational Materials and The permittee provided educational materials and training for developers. Yes Training NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 24 of 54 Post -Construction Site Runoff Controls Comments Multiple training and information sessions were provided by Stormwater Division staff prior to and after the ordinance implementation in 2008. Educational materials provided include a permit application flowchart, example of design calculations and other supplementary information such as Operation and Maintenance Manual templates. These are available on the Stormwater Division's website. The Stormwater Engineer, and if needed, the Stormwater Director, also make themselves regularly available to meet with developers at their request on an individual basis if they need guidance on permit policies and procedures before applying for a permit. The Stormwater Engineer is also a member of the City's Technical Review Committee (TRC) and attends in person meetings held on a weekly and monthly basis to explain the post -construction stormwater management permitting process to applicants looking to develop or redevelop property within the City limits and Salem Lake Watershed, The Stormwater Engineer has on average three such meetings (individual plus TRC combined) on a weekly basis. The Stormwater Engineer fulfills multiple meetings and information requests from developers, owners, and citizens either by phone or e-mail on a weekly basis outside of the in -person meetings. Currently, the Stormwater Director and Stormwater Engineer regularly attend a Developer Forum and Planning Board meeting to inform interested parties regarding the post -construction permitting, potential communal negative impacts, and other pertinent post -construction stormwater management topics. The City maintains a website on the Stormwater Divisions webpage that addresses the City's post -construction permitting process as well as development requirements within the regulated Salem Lake Watershed area. This website is used as an educational tool available to all developers and SCM owners. The website contains items such as, a link to the Post Construction Stormwater Management ordinance, a link to the NC DWR Stormwater Design Manual website, the permit flow chart, a link to the permit application and checklists for submittal, templates for Operation and Maintenance Agreements and Manuals, design examples or SCMs, templates for inspections and annual compliance reports, a link to the electronic review submittal system and also a detailed FAQ section that attempts to address most, if not all of the questions that developers and SCM owners typically have. This website may be found at https://www.City ofws.org/794/Post-Construction-Stormwater-Management. ll'F'4' The permittee applies additional requirements to projects draining to SA waters by Sensitive Receiving requiring SCMs that result in the highest degree of fecal coliform die -off and Not Waters controls sources of fecal coliform to the maximum extent practicable in accordance Applicable with 15A NCAC 02H .1017(9) The permittee applies additional requirements to projects draining to Trout waters by requiring SCMs that avoid a sustained increase In receiving water temperature Not Applicable in accordance with 15A NCAC 02H .1017(9) The permittee implements an approved locally implemented Nutrient Management Strategy that addresses post -construction runoff and the provisions Not Applicable of that Strategy fulfill the MS4 post -construction requirement. Comments None Permittee Projects The permittee meets the requirements of the post -construction program for Yes 17 construction projects that are performed by, or under contract for, the permittee. NCS000247_Winston-Salem 2022 M545e1f-Audit Page 25 of 54 Post -Construction Site Runoff Controls Comments The City's Engineering Department manages and oversees construction projects for the City of Winston-Salem. SCMs, associated with these construction projects, adhere to Chapter 75 of the City Code. Operation and Maintenance Agreements are held by the responsible municipal entity, which the SCM's location is physically constructed. For example, if a new fire station is constructed that warrants post -construction measures (e.g., water quality/quantity SCMs, riparian buffers, etc.), then the Winston-Salem Fire Department is responsible for maintenance activities. I L F.6. The permittee requires that the water quality design volume of SCMs account for SCM Design Volume the runoff at build out from all surfaces draining to the system. yes F717 Comments SCM water quality designed volumes are required in the ordinance and implemented at review stage for developments by provision of drainage delineation plans/maps, as a part of the design documents. II.F.7. The permittee fulfills the post -construction minimum control measure Linear requirements for non-NCDOT linear transportation projects if they are designed, Transportation constructed, and conveyed as set forth in 15A NCAC 02H .1001(1)(c): Projects (i) Constructed to NCDOT standards and in accordance with the NCDOT BMP Toolbox; Yes 17 (11) Conveyed to NCDOT or other public entity and regulated in accordance with that entity's NPDES MS4 Permit; and (III) The project is not part of a common plan of development. Comments The City of Winston-Salem utilizes the NCDOT Linear Transportation BMP Toolbox for roads, strollways, greenways and other linear projects. These may include vegetated conveyances and plunge pools to the MEP. Additional None Comments: NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 26 of 54 Pollution Prevention and Good Housekeeping for Municipal Operations Staff Interviewed: Name: Ladonta Clark "Jamal" (Name, Title, Role) Title: Stormwater Operations Supervisor Role: (Supervisor) Supervising Two Stormwater Technicians and One Stormwater Inspector. Oversees the Pollution Prevention and Good Housekeeping for Municipal Operations/Facilities program. Permit Citation Program Requirement Status supporting Doc No, II.G.2.a. The permittee maintained an inventory of municipal facilities and operations Municipal Facility owned and operated by the permittee that have been determined by the Yes 20 Inventory permittee to have significant potential or generating polluted stormwater runoff. The permittee maintained an inventory of municipally -owned structural SCMs. Yes 21 Comments The Stormwater Inspector and/or the Stormwater Operations Supervisor maintains a comprehensive inventory of municipal facilities and operations. This inventory is very detailed and encompasses pertinent facility/operation Information, such as facility contact, last date of inspection, priority ranking, located within a TMDL watershed, etc. The Stormwater Engineer maintains an inventory of structural SCMs that are City -owned. This inventory includes basic information, which encompasses date of installation, location, type of SCM, pollutants treated, possesses an 0&M Plan, etc. The link to the exact spreadsheet is here G:\Industrial Inspection & Municipal Good housekeeping\MGH&PP Program\Municipal Facilities\Master Municipal\Master Municipal.xlsx Last Updated Date: 10/11/2021 of the Master Municipal Facilities/Operations List. Last Updated Date: 1/3/2022 of inventory of City -owned SCMs ILG.2.b. The permittee implemented an inspection and maintenance program for facilities Inspection and and operations owned and operated by the permittee for potential sources of Yes 22 Maintenance for polluted runoff, including stormwater controls and conveyance systems. Municipal Facilities The inspection program evaluates pollutant sources, documents deficiencies, plans corrective actions, implements appropriate controls, and documents the Yes 23 accomplishment of corrective actions. The maintenance program includes maintenance activities and procedures aimed at preventing or reducing pollutants generated from municipal facilities and Yes 23 operations. NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 27 of 54 Pollution Prevention and Good Housekeeping for Municipal Operations Comments The Stormwater Division inspects and ensures proper maintenance activities of City -owned facilities or operations by means of the creation and implementation of a Stormwater pollution prevention plan (SPPP) by the responsible City entity. The Stormwater Inspector conducts inspections based on the priority level of the facility or operation; higher prioritized sites or operations are inspected on an increased frequency and/or order. As municipal facilities or operations are inspected, the inspection results (e.g., Required Actions to be Completed by the Facility) are incorporated into the Stormwater Division's master tracking list. Inspections are conducted, recorded, documented, and sent to the responsible municipal entity with required corrective actions that need to be completed. Each site pollution prevention plan has a maintenance schedule of BMPs, and the Stormwater Inspector monitors BMP completion by means of site reinspections and/or submitted documentation. The Stormwater Inspector tracks the completion of all required BMP actions and schedules site reinspections, if the responsible municipal entity does not respond within the specified due date. Inspection form folder is hyperlinked here: G:\Industrial Inspection & Municipal Goodhousekeeping\Inspection Forms\Industrial Inspection Forms II.G.2.c. The permittee maintained and implemented Site Pollution Prevention Plans for Site Pollution municipal facilities owned and operated by the permittee that have been Prevention Plans for determined b the permittee to have significant potential for generating y p g p g g polluted Yes 21, 24 Municipal Facilities stormwater runoff that has the goal of preventing or reducing pollutant runoff. Comments If a municipal facility has an NCG permit or possess the size and magnitude of a state -permitted facility, then the created stormwater pollution prevention plan (SPPP) will follow the outline and contain contents of a general stormwater permit. This ensures that larger and/or more complex municipal operations/facilities possess a SPPP that is compliant with permit requirements as well as eliminating pollutant exposure to stormwater. If City -owned facility/operation has the potential to generate pollutants, but not large or complex, the facility is Issued an abbreviated SPPP. An abbreviated plan consists of numerous aspects of a permitted -facility SPPP, (e.g., spill response measures, basic facility maps with Stormwater discharge outfalis, good housekeeping and preventative maintenance schedule, employee training, etc.), but not all SPPP components (e.g., feasibility study, risk assessment, site maps with topography, etc.). It is the municipal entity's responsibility to implement all provisions of their assigned SPPP, including updating all pertinent information, as site or personnel changes occur. General SPPP templates and inspection -generated material are stored digitally on the Stormwater Division's shared G: drive by Stormwater Inspector or Stormwater Operations Supervisor. The Stormwater Inspector conducts a site inspection to track and monitor the progression of SPPP compliance. When an inspection is completed, the Stormwater Inspector denotes any required actions that facility will need to perform to maintain SPPP compliance; the Stormwater Inspector sends an electronic inspection report to the facility for corrections. As the Stormwater Inspector performs their site inspection, they have access to the facility's current SPPP for comparing site conditions to the Stormwater Division's Inspection form. After reviewing the master municipal facilities/operations spreadsheet, Stormwater staff have determined the following breakdown for SPPPs: The number of municipally -owned facilities/operations that possess SPPPs (full or abbreviated) = 58 The number of municipally -owned facilities/operations to be evaluated for potential pollutants and SPPP creation = 25 The number of municipally -owned facilities that possess a spill prevention, control, and countermeasure plan = 3 Stormwater staff have digitalized all inspection forms, which are stored at the following hyperlink locations: G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Completed NIGH SWPPPs G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Municipal Facilities NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 28 of 54 Pollution Prevention and Good Housekeeping for Municipal Operations " The permittee maintained spill response procedures for municipal facilities and Spill Response operations owned and operated by the permittee that have been determined by Procedures for Yes 25 the permittee to have significant potential for generating polluted stormwater Municipal Facilities runoff, Comments All spill response procedures (SRP) for municipal facilities are included in every site pollution prevention plan (SPPP). In the event of a spill, the municipal facility will be able to use their SRPs for mitigating the effects of said spill. In addition, the responsible entity must keep their SPPP current, which includes SRPs and the spill response team contact information. As the Stormwater Inspector inspects the facility, he or she denotes if the responsible entity must make any needed changes. Employee awareness is the key to an effective spill prevention and response program. Spill prevention training is a component of the general employee training program. New personnel are taught spill prevention practices during the City's new employee orientation. The spill response team gains a sufficient understanding of the objectives of the spill prevention program. Spill prevention training highlights previous spill events, equipment failures, remedies taken, and newly developed prevention measures. The Stormwater Spill Response Team Leader evaluates the spill prevention program at least once each year to keep it current. The location for the file location can be found here in the hvperlinks: G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Completed MGH SWPPPs G:\Industrial Inspection &Municipal Goodhousekeeping\MGH&PP Program\Municipal Facilities II.G.2.e. The permittee described measures that preventor minimize contamination of the Vehicle and stormwater runoff from all areas used for vehicle and equipment cleaning, Yes --- Equipment Cleaning including fire stations that have more than three fire trucks and ambulances. Areas The permittee performs all cleaning operations indoors, covers the cleaning operations, ensures wash water drains to the sanitary sewer system, collects wash yes --- water and stormwater run-on from the cleaning areas and provides treatment or recycling, or other equivalent measures The permittee, if sanitary sewer is not available to the facility and cleaning operations take place outdoors, ensures wash water drains to an SCM for treatment, or else the cleaning operations take place on or drain directly to grassed Yes --- or graveled areas to prevent point source discharges of wash water into the storm drains or surface waters. The permittee, where cleaning operations cannot be performed as described above and when operations are performed in the vicinity of a storm drainage collection system, covers the drain(s) with a portable drain cover during cleaning activities, Yes and any excess standing water is removed and properly handled prior to removing the drain cover. The permittee facilities that have three or fewer fire trucks and ambulances attempt to comply with the above requirements; however, those that cannot yes --- comply with these requirements due to existing limitations incorporate structural measures during facility renovation to the extent practicable. NCS000247_Winston-Salem 2022 M54 Self -Audit Page 29 of 54 Pollution Prevention and Good Housekeeping for Municipal Operations Comments To mitigate any pollutants from being released into the MS4 or receiving waters from vehicle cleaning activities, all vehicle washing is performed at Fleet Services' Lowery Street location. At that facility, the City of Winston Salem has four wash bays that are connected to oil and water separators —these separators discharge to the sanitary sewer system. One bay is an automatic wash bay that fits vehicles 7 foot and lower. Two of the bays wash high clearance vehicles; the other bay is an automatic wash bay for heavy equipment. All City of Winston Salem employees are advised to use this facility as their main source of vehicle and equipment cleaning, unless employees use a private auto -washing facility that is connected to the sanitary sewer. All fire stations have a stormwater pollution prevention plan; Stormwater staff recommended to the Winston-Salem Fire Department to prevent all wash water from entering the MS4 system during vehicle -washing activities. The WSFD SPPP is located at the following location: G:\Industrial Inspection & Municipal Goodhousekeeping\MGH&PP Program\Completed MGH SWPPPs\Fire Stations II.G.2.f. Streets, Roads and The permittee implements BMPs to reduce polluted stormwater runoff from Public Parking Lot municipally -owned streets, roads, and public parking lots within the corporate Yes 26, 27 Maintenance limits. Comments Field Operations at City Yard processes an average of 800 service requests annually resulting in over 1,450 work orders each year. These work orders address a wide variety of maintenance tasks from inlet cleaning to ditch reshaping to structural maintenance. If structures have observable structural damage, the structure is placed on a prioritization list for future repair or replacement. Please reference the City's MS4 Inspection, Operation, and Maintenance Plan (I, O, and M) for more detailed information regarding this permit requirement. Stormwater staff prioritized the top four parking lots/facilities for street sweeping activities, based on potential pollutant exportation. These facilities include Fleet Services, Sanitation/Lowery Street car -washing facility, Streets (Field Operations), and the Winston-Salem Transit Authority (WSTA) Maintenance and Parking Facility. These facilities are swept every other week (on average) by the City's Sanitation Department. II.G.2.g. The permittee maintained and implemented an inspection and maintenance Inspection and program for structural stormwater control measures (SCMs) owned and operated Partial Maintenance for by the municipality. Municipal SCMs and MS4 The permittee maintained and implemented an inspection and maintenance program for the municipal storm sewer system (including catch basins, the Yes 26 conveyance system and SCMs). Comments The Stormwater Engineer, a North Carolina licensed professional engineer, inspected all City -owned stormwater control measures (SCMs) In November 2021. Admittingly, the Stormwater Division has not performed significant maintenance for its SCMs, since being installed, other than trash/debris removal. Reasons for the lack of significant maintenance activities include, but limited to, insufficient resources, staffing factor, and COVID-19. Field Operations at City Yard processes an average of 800 service requests annually resulting In over 1,450 work orders each year. These work orders address a wide variety of maintenance tasks from inlet cleaning to ditch reshaping to structural maintenance. If structures have observable structural damage, the structure is placed on a prioritization list for future repair or replacement. Please reference the City's MS4 Inspection, Operation, and Maintenance Plan (I, 0, and M) for more detailed information regarding this permit requirement. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 30 of 54 Pollution Prevention and Good Housekeeping for Municipal Operations II.G.2.h. The permittee maintained a training plan that indicates when, how often, and who Staff Training Yes 6, 10,23 is required to be trained and what they are to be trained on. The permittee implemented a training plan that indicates when, t and Yes 6110 who is required to be trained and what they are to be trained on. Comments In each site pollution prevention plan, there is a section that requires the responsible entity to perform spill response (SR) training. During the site inspection, the Stormwater Inspector audits the facility's current SR documentation and provides training for staff when needed. The SPPP requires SR training be done at least once a year and anytime that there is a new employee that has joined the work force. This type of training is specific to the operation. Also, on the Stormwater Division's inspection form, there is a question where the Inspector denotes if training has been completed. This question reminds the Inspector to confirm training has been completed and properly documented (within the Stormwater Management Strategy section of the municipal/industrial inspection form). The Senior Community Educator and the Stormwater Inspector collaborate and provide educational DVDs that cover multiple pollution prevention topics to pertinent City employees. During FY 2021-2022, the Senior Community Educator, Stormwater Operations Analyst, and the City`s Marketing and Communications Department created a new training video that highlights proper pollution prevention & municipal good housekeeping practices for key City operations to eliminate pollutant exposure to the environment. A main topic in this video pertains to recognizing and reporting illicit discharges/dumping activities to Stormwater staff, so more incidents can successfully be resolve by Stormwater staff, thanks to 'rank and file' City team members. From November 2021 to March 2022, 2,127 out of 2,354 City employees (90.3%) viewed and passed a confirmation test of Stormwater's new PP & MGH and IDDE training video. This educational video will need to be viewed by all City employees on an annual frequency for maximum memory retention. Additional I None Comments: NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 31 of 54 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems Staff Interviewed: Name: Ladonta Clark "Jamal" (Name, Title, Role) Title: Stormwater Operations Supervisor Role: (Supervisor) Supervising Two Stormwater Technicians and One Stormwater Inspector. Responsible for administering and ensuring permit compliance with the Stormwater Division's Industrial Inspection Program. Permit Citation Program Requirement Status supporting Doc No. II.H.Z.a. The permittee maintained an inventory of permitted hazardous waste treatment, Industrial Facility disposal, and recovery facilities, industrial facilities that are subject to Section 313 Yes 28 Inventory of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA). The permittee maintained an inventory of industrial facilities identified with an industrial activity (as defined in 40 CFR 122.26) permitted to discharge storm water Yes 29 to the permittee's MS4. Comments The Stormwater Division maintains a comprehensive industrial facility inventory. The Stormwater Inspector consults the Environmental Protection Agency's databases (via the Internet) to obtain applicable industries, within the municipal boundaries of Winston-Salem, that are subject to SARA Title III (i.e., RCRA facilities) and permitted hazardous waste facilities (i.e., the toxic release inventory facilities. Then, the Stormwater Inspector obtains active and expired NPDES Stormwater Permittees from North Carolina Department of Environmental quality's website within the City limits. The Stormwater Inspector consults EPA's and DEC's websites annually to maintain a complete and current database. The file location for all databases is located: G:\Industrial Inspection & Municipal Goodhousekeeping\Indust_Inspect\City Industrial Information\TRI (updated 4/11/2022) G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information\RCRA (updated 4/11/2021) G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information\Active CoCs (updated 4/12/2022) Source websites of RCRA, TRI, and state -permitted stormwater facilities: Active & Expired NPDES Stormwater Permits - deq.nc.gov TRI-. Gathered from USEPA TRI Facilities Search RCRA- Using USEPA Envirofacts RCRA Lookup ILH,2.b. I7 nspection Program The permittee identified priorities and inspection procedures. At a minimum, Yes 30,31 priority facilities include those identified above (subsection II.H.2.a). NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 32 of 54 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems Comments When merging RCRA, TRI, active DEQ stormwater permits, and the City's IDDE lists together, the Stormwater Inspector observes the frequency of each facility's name, The Increased frequency of each repeating name shows the scope and magnitude of industrial operations, thus, warranting the heightened priority of the facility to be inspected. As a result, these types of facilities are moved into the top tier for inspection services. After this tiered initial sorting, the Stormwater Inspector uses additional priority -ranking criteria to finalize the industrial inspection list— this criterion includes historical spills, located within a TMDL watershed, analytical monitoring data, and major staff or facility changes. The Stormwater Inspector's goal is to inspect every general or individually stormwater permitted facility once during its permit cycle (every five years) Please note: The Stormwater Inspector performs inspection activities on RCRA or TRI facilities ONLY If the facility has an active general or individual stormwater permit or experiences an illicit discharge. This is due to inspection and entry authority reasons; general (and individual) stormwater permits grant access to local stormwater programs under Section 1-13, if connected to the MS4 as well as Chapter 75, the City of Winston-Salem's Illicit Discharge Ordinance. Otherwise, local, state, and federal regulations do not provide legal authority for entry and inspection by Stormwater staff into RCRA and TRI facilities. The Stormwater Division's Industrial Facilities List (of past inspected facilities from FY 2020-2022 and FY 2022-2023 proposed facilities) is located : G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information, The Stormwater Division has created and implemented industrial inspection procedures SOPS - these SOPS are located: G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information\Industrial SOP\Current II.H.2.c. The permittee evaluated control measures implemented at permitted hazardous Industrial Facility waste treatment, disposal, and recovery facilities, industrial facilities that are Evaluation subject to Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA). Yes For the purpose of this permit the Permittee is authorized to inspect the permitted hazardous waste treatment disposal, and recoveryfacilities as an authorized representative of the Director. The permittee evaluated control measures implemented at industrial facilities identified with an industrial activity permitted to discharge storm water to the permittee's MS4. Yes For the purposes of this permit, industrial activities shall mean all permitted industrial activities as defined in 40 CFR 122.26, For permitted industrial facilities, the permittee established procedures for reporting deficiencies and non-compliance to the permitting agency. Yes Where compliance with an existing industrial stormwater permit does not result in adequate control of pollutants to the MS4, the permittee recommends and documents the need for permit modifications or additions to the permit Issuing yes 30 authority. The permittee evaluated control measures implemented at industrial facilities identified as an illicit discharge under the IDDE Program. Yes --- NC5000247_Winston-Salem 2022 MS4 Self -Audit Page 33 of 54 Program to Monitor and Evaluate Stormwater Discharges to Municipal Systems Comments The Stormwater Division evaluates all implemented stormwater control measures (SCMs) or best management practices (BMPs) at TRI, RCRA, and active state -permitted facilities, which have been issued a general or individual Stormwater permit (this includes all facilities that have experienced an illicit discharge). If SCMs or BMPs are deemed inadequate or have failed, the Stormwater Inspector denotes all required action items that the facility will need to correct to become compliant with their Stormwater permit. The Stormwater Inspector determines the specified due date that the facility must implement all corrective measures, based on the amount and severity of action items that are required. The Stormwater Inspector and/or the Stormwater Operations Supervisor creates, establishes, updates, and maintains all procedures for reporting deficiencies and non-compliance to the Winston-Salem Regional Office of DEG, which are listed in our Industrial Inspection SOP Manual. This manual was updated on April 18, 2022 and located at: G:\Industrial Inspection & Municipal Goodhousekeeping\lndust_Inspect\City Industrial Information\Industrial SOP\Current. In addition, the Stormwater Division notifies DEQ WSRO of insufficient measures within existing state stormwater permits via the City's Inspection Form. When a facility (commercial or Industrial) releases an illicit discharge, the Stormwater Inspector performs a comprehensive inspection to permanently eliminate the source or connection of said discharge. The Stormwater Inspector incorporates all inspection documentation into the industrial inspection folder for future reference, as well as into the master industrial spreadsheet as a criterion for assessment prioritization. Additional None Comments: NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 34 of 54 Water Quality Assessment and Monitoring Staff Interviewed: Name: Ladonta Clark "Jamal" (Name, Title, Role) Title: Stormwater Operations Supervisor Role: (Supervisor) Supervising Two Stormwater Technicians and One Stormwater Inspector. Oversees and ensure compliance with the Stormwater Division's Water Quality Assessment and Monitoring Plan. Permit Citation Program Requirement Status supporting Doc No. 11.1.2.a. Water Quality The permittee maintained a Water Quality Assessment and Monitoring Plan. Yes 32 Assessment and Monitoring Plan The Water Quality Assessment and Monitoring Plan includes a schedule for Yes 32 implementing the proposed assessment and monitoring activities. NC5000247_Winston-Salem 2022 M54 Self -Audit Page 35 of 54 Comments The Stormwater Operations Supervisor maintains the City's Water quality Assessment and Monitoring Plan, which was last modified on April 13. 2022. Stormwater staff performs water quality The Plan resides at: G:\Techn_Projects_Files\WQAM Plan_ Stormwater staff has implemented the Water Quality Assessment and Monitoring Plan —the sampling plan schedule is in Section 9: Sampling Monitoring Yearly Schedule. Stormwater staff has summarized the sampling regime contained within the Water quality Assessment and Monitoring Sampling Plan and is stored at the following location: G:\Techn_Projects_Files\WQAM Plan_\Sampling Summaries, Fixed Interval Sampling Fixed Interval sampling is performed quarterly, in all weather conditions, at 13 sites across Winston-Salem's municipal boundaries. Fixed interval will be carried out on the third week of the first month at the beginning of each quarter. The sites are divided between two receiving streams: Salem Creek and Muddy Creek— both are TMDL watersheds. There are six sites on Salem Creek and seven sites on Muddy Creek. The remaining seven sites are in Mill, Silas, Little, Fiddlers, and Lower South Fork Watersheds. Twenty-four sampling parameters are collected at each site. Most water quality samples are analyzed in a North Carolina certified laboratory, while several parameters are analyzed using an instanteous water quality meter. • There are nineteen parameters that are analyzed in a certified laboratory, which includes Biological Oxygen Demand, Total Cadmium, Total Chromium, Dissolved and Total Copper, Total Lead, Total Nickel, Dissolved and Total Zinc, Total Dissolved Solids (TDS), Nitrate, Nitrite, Ammonia, Total Kjeldahl Nitrogen, Dissolved and Total Phosphorous, Total Suspend Solids (TSS), Turbidity (NTU), and Fecal Coliforms. • Field parameters are gathered primarily by a YSI quatro Pro Plus, This device is used to gather the following five parameters: Temperature (C), Dissolved Oxygen (%), Dissolved Oxygen, Conductivity(µS/L), and pH. As events arise or equipment fails, all parameters may be substituted from YSI meters and Pocket Colorimeters and be collected instead by bottle and taken to Pace Analytical for lab analysis. Total Maximum Dailv Load (TMDL) Currently, the City of Winston-Salem has two TMDL watersheds. These two watersheds are Salem Creek and Muddy Creek Watersheds. TMDL sampling is conducted in five of these watersheds for a total of 22 sites: Upper Salem Creek (six sites), Peters Creek (five sites), Middle Salem Creek (two sites), Lower Salem Creek (two sites), and Brushy Fork (seven sites). Sampling is dependent upon ambient weather conditions, so no fixed schedule exists for sampling within the quarter to achieve desired levels of sampling. All sampling is done in either dry or wet weather conditions, with wet weather being defined as a rain event of greater than 0.10" in the last 72 hours and anything less being defined as dry weather. Ten parameters are collected at each site. Some are lab analyzed while most are field gathered. • The four lab analyzed parameters are Fecal Coliforms, Total Suspended Solids (TSS), Ammonia, and Nitrate. These samples are collected in sample bottles and placed on Ice before being taken to Pace Analytical Laboratories. • Field parameters are gathered primarily by a YSI Quatro Pro Plus. This device is used to gather the following six parameters: Temperature (C), Dissolved Oxygen (%), Dissolved Oxygen, Conductivity(µS/L), Total Dissolved Solids (TDS), and pH. As events arise or equipment fails, all parameters may be substituted from YSI meters and Pocket Colorimeters, Water Quality Monitoring Water quality Monitoring (WQM) sampling is performed quarterly at 18 sites in both dry and wet weather conditions across the Winston-Salem municipal boundaries. Because WQM sampling is weather dependent, there is no set time frame for this sampling during the quarter. Fifty percent of WQM samples are expected to be collected during wet weather conditions, which is defined as occurring within 72 hours of a rainfall event amounting to one -tenth of an inch of precipitation or more. Fifty percent of samples are also expected to be collected during dry weather conditions, which is defined as occurring at least 72 hours after a rain event of one -tenth of an inch or more or when there has been less than one -tenth of precipitation. The number of samples collected in dry and wet weather conditions is reversed for the following quarter of the year to balance the appropriate amount of data for all sites. NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 36 of 54 Water Quality Assessment and Monitoring The 18 sites used for WQM sampling represent data for several different watersheds within Winston-Salem municipal boundaries. The percentage of sites representing each watershed from the total 18 sites are as follows: • Eleven percent of the sampling sites (Lower South Fork at Peters Creek Pkwy and Lower South Fork at Old Lexington Road) are collected within the Lower South Fork Muddy Creek Watershed. • Eleven Percent of the sampling sites (Fiddlers Creek at Teague Road and Fiddler's Creek at Willard Road) are collected within the South Fork Muddy Creek Watershed. • Eleven percent of the sampling sites (Monarcas Creek at Linn Station Road and Mill Creek at Reynolda Road) are collected within the Lower Mill Creek Watershed. • 23 percent of the sampling sites (Mill Creek at Patterson Avenue, Mill Creek at Shattalon Drive, Leak Fork at Hines Park Soccer Field, and Leak Fork at Motor Road) are collected within the Middle Mill Creek Watershed. • 29 percent of the sampling sites (Silas Creek at Royall Drive, Silas Creek at Reynolda Village, Silas Creek at Yorkshire Road, Little Creek at Old Vineyard Road, and Silas Creek at Country Road) are collected within the Silas Creek Watershed. • Five percent of the sampling sites (Muddy Creek at Country Club Road) are collected within the Lower Muddy Creek Watershed. • Five percent of the sampling sites (Peters Creek at Hanes Park) are collected within the Peters Creek Watershed. • Five percent of the sampling sites (Muddy Creek at Reynolda Road) are collected within the Upper Muddy Creek Watershed. During WQM sampling, seven pollutant parameters are collected and measured by utilizing either a YSI Water Quality Meter for temperature, pH, dissolved oxygen, total dissolved solids, and conductivity or by grabbing a water sample that is taken in for laboratory analysis for nitrate and ammonia. 11.1.2.b. The permittee maintained and Implemented the Water Quality Assessment and Water Quality Monitoring Plan submitted to DEMUR. Yes 32 Monitoring The Division waived the requirement to maintain a Water Quality Assessment and Not Monitoring Plan. Applicable Comments The City of Winston Salem has maintained and implemented its Water Quality Assessment and Monitoring Plan, which was submitted to Jeanette Powell on May 24, 2021, Additional None Comments: NCS000247_Winston-Salem 2022 MS4 Self -Audit Page 37 of 54