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HomeMy WebLinkAboutNCS000248_Draft SWMP_20221208Greensboro Proposed City of Greensboro Stormwater Management Plan (NCS000248) December 8, 2022 PREPARED FOR City of Greensboro Water Resources Department Stormwater Management Division 2602 South Elm -Eugene Street Greensboro, NC 27402 PREPARED BY Tetra Tech Engineering, P.C. 4000 Park Drive, Suite 200 Durham, NC 27709 Tel 919-485-8278 Fax 919-485-8280 tetratech.com (This page was intentionally left blank.) City of Greensboro Stormwater Management Plan (Draft) TABLE OF CONTENTS 1.0 INTRODUCTION..................................................................................................................................... 5 2.0 CERTIFICATION.................................................................................................................................... 6 3.0 MS4 INFORMATION.............................................................................................................................. 7 3.1 Permitted MS4 Area......................................................................................................................... 7 3.2 Existing MS4 Mapping......................................................................................................................8 3.3 Receiving Waters........................................................................................................................... 10 3.4 MS4 Interconnection....................................................................................................................... 12 3.5 Total Maximum Daily Loads(TMDLs)............................................................................................ 12 3.6 Endangered and Threatened Species and Critical Habitat............................................................ 12 3.7 Industrial Facility Discharges.......................................................................................................... 12 3.8 Non-Stormwater Discharges.......................................................................................................... 12 3.9 Target Pollutants and Sources....................................................................................................... 13 4.0 STORMWATER MANAGEMENT PROGRAM IMPLEMENTATION................................................... 15 4.1 Legal Authority................................................................................................................................ 15 4.2 Organizational Structure................................................................................................................. 15 4.3 Program Funding and Budget........................................................................................................ 19 4.4 Shared Responsibility..................................................................................................................... 20 4.5 Co-Permittees................................................................................................................................. 20 4.6 Measurable Goals for Program Implementation............................................................................. 20 5.0 PUBLIC EDUCATION AND OUTREACH............................................................................................23 6.0 PUBLIC INVOLVEMENT AND PARTICIPATION................................................................................26 7.0 ILLICIT DISCHARGE DETECTION AND ELIMINATION....................................................................28 8.0 CONSTRUCTION SITE RUNOFF CONTROLS...................................................................................30 9.0 POST -CONSTRUCTION SITE RUNOFF CONTROLS........................................................................32 10.0 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS ..... 35 11.0 PROGRAM TO MONITOR AND CONTROL POLLUTANTS IN STORMWATER DISCHARGES TO MUNICIPAL SYSTEMS..............................................................................................................................40 12.0 WATER QUALITY ASSESSMENT AND MONITORING...................................................................42 13.0 TOTAL MAXIMUM DAILY LOADS....................................................................................................43 14.0 PROGRAM ASSESSMENT, REPORTING, AND RECORDKEEPING.............................................47 14.1 Program Assessment................................................................................................................... 47 14.2 Reporting and Recordkeeping......................................................................................................47 City of Greensboro Stormwater Management Plan (Draft) LIST OF TABLES Table 1: Summary of Current MS4 Mapping (2022) .......................... Table 2: Summary of Primary MS4 Receiving Waters (Alphabetical) Table 3: Summary of Approved TMDL(s)........................................... Table 4: Allowable Non-Stormwater Discharges ................................ Table 5: Summary of Target Pollutants and Sources ........................ Table 6: Summary of Responsible Positions ...................................... Table 7: Shared Responsibilities........................................................ Table 8: Program Implementation BMPs........................................... Table 9: Public Education and Outreach BMPs................................. Table 10: Public Involvement and Participation BMPs....................... Table 11: Illicit Discharge Detection and Elimination BMPs............... Table 12: Construction Site Runoff Control BMPs ............................. Table 13: Post -Construction Site Runoff Control BMPs..................... Table 14: Pollution Prevention and Good Housekeeping BMPs........ Table 15: Program to Monitor and Control Pollutants BMPs ............. Table 16: Water Quality Assessment and Monitoring BMPs ............. Table 17: Total Maximum Daily Loads (TMDLs) BMPs ..................... LIST OF FIGURES .. 8 11 12 13 14 17 20 21 23 26 28 30 32 35 40 42 43 Figure 1: City of Greensboro Corporate Limits............................................................................................ 7 Figure 2. City of Greensboro NPDES MS4 Outfall Mapping 2022...............................................................9 Figure 3: City of Greensboro MS4 Permit Implementation Organizational Chart......................................18 Figure 4: City of Greensboro Stormwater Fiscal Year 2020-2021 Budget Expenses...............................19 City of Greensboro Stormwater Management Plan (Draft) ACRONYMS/ABBREVIATION S BMP Best Manaaement Practice CA DEMLR Critical Area Division of Energy, Mineral, and Land Resources E&SC Erosion and Sediment Control ERU Equivalent Residential Unit FEMA Federal Emergency Management Agency Fats, Oils, and Grease Good Housekeeping Program FOG GHP GIS Geographic Information System HAZMAT HAZardous MATerials I&M Inspection and Maintenance IDDE Illicit Discharge Detection and Elimination IIP Industrial Inspection Program MEP Maximum Extent Practicable Municipal Separate Storm Sewer System North Carolina Department of Environmental Quality MS4 NCDEQ NFIP National Flood Insurance Program NOV Notice of Violation NPDES National Pollutant Discharge Elimination System NSW Nutrient Sensitive Waters PE&O Public Education and Outreach POC Pollutant of Concern Pollution Prevention and Good Housekeeping Superfund Amendments and Reauthorization Act of 1986 PP/GH SARA SCM Stormwater Control Measure SMART Specific, Measurable, Attainable, Relevant, and Time -oriented SOP Standard Operating Procedure SPCA Sediment Pollution Control Act SSO Sanitary Sewer Overflow SWMP Stormwater Management Plan Site Pollution Prevention Plan Total Maximum Daily Load SPPP TMDL TRC Technical Review Committee WLA Waste Load Allocation City of Greensboro Stormwater Management Plan (Draft) REVISION LOG City of Greensboro Stormwater Management Plan (Draft) 1.0 INTRODUCTION The purpose of this proposed "Draft" Stormwater Management Plan (SWMP) for the upcoming permit cycle, 2023-2028, is to establish and define the means by which the City of Greensboro will comply with its National Pollutant Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) Permit and the applicable provisions of the Clean Water Act to meet the federal standard of reducing pollutants in stormwater runoff to the maximum extent practicable. This "Draft" SWMP identifies minimum measures that the City of Greensboro will develop, implement, enforce, evaluate, and report to the North Carolina Department of Environmental Quality (NCDEQ) Division of Energy, Minerals and Land Resources (DEMLR) to comply with the MS4 Permit number NCS000248. Since the "proposed" permit covering years 2023-2028 has not been drafted nor reviewed yet, this "Draft" SWMP covers currently known activities associated with the discharge of stormwater from the MS4 as owned and operated by the City of Greensboro and located within the corporate limits of the City of Greensboro. In preparing this "Draft" SWMP, the City of Greensboro evaluated its MS4 permit requirements to develop a comprehensive 5-year SWMP that will meet the community's needs, address local water quality issues, and provide the minimum measures necessary to comply with the permit. The SWMP will be evaluated and updated once the new permit has been issued to ensure that the elements and minimum measures it contains continue to meet the community's needs and adequately provide for permit compliance. Any major changes to the approved SWMP will require resubmittal, review, and approval by NCDEQ. 5 City of Greensboro Stormwater Management Plan (Draft) 2.0 CERTIFICATION By my signature below I hereby certify, under penalty of law, that 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. I am also aware that the contents of this document shall become an enforceable part of the NPDES MS4 Permit, and that both the Division and the Environmental Protection Agency have NPDES MS4 Permit compliance and enforcement authority. Signature: Print Name: Michael Borchers Title: Director of Water Resources Department On Signed this day of 20 1 City of Greensboro Stormwater Management Plan (Draft) 3.0 MS4 INFORMATION The City of Greensboro's initial NPDES MS4 Discharge Permit (Permit Number NCS000248) became effective on December 30, 1994. NCDEQ issued the City of Greensboro's current permit on October 10, 2018, for a period of five years with an effective expiration date of October 9, 2023. The City's NPDES stormwater permit, and associated SWMP, are designed to control the discharge of pollutants from the MS4 to the Maximum Extent Practicable (MEP). 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits of the City of Greensboro, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits of the City of Greensboro (green polygon). Figure 1: City of Greensboro Corporate Limits 7 City of Greensboro Stormwater Management Plan (Draft) 3.2 Existing MS4 Mapping The City of Greensboro's current MS4 mapping includes NPDES MS4 major outfalls* as well as additional pertinent MS4 assets including manholes, pipe inlets/outlets, open conveyance channels, culverts, storm inlets, spillways, and pipes, as well as flow connectivity and waterbodies. A numerical summary of the City's mapped stormwater assets is provided below, and an accompanying map is provided in Figure 2. Table 1: Summary of Current MS4 Mapping (2022) NPDES MS4 Assets Percent of MS4 Area Mapped No. of Major Outfalls* Mapped NPDES Industrial Outfalls (>_12") NPDES Non -Industrial Outfalls (>_36") Other Stormwater Assets Manholes Pipe IOs (Inlets/Outlets) Open Conveyance Culverts Inlets Spillways Pipes Flow Connectivity Waterbodies 100% 2,070 817 1,233 13,647 16,688 13,239 1,410 57,734 1,822 78,087 5,523 1,778 *The City's NPDES MS4 permit defines a "major MS4 outfall" as a municipal separate storm sewer outfall that discharges from a single pipe with an inside diameter of 36 inches or more or its equivalent (discharge from a single conveyance other than circular pipe which is associated with a drainage area of more than 50 acres); or for municipal separate storm sewers that receive stormwater from lands zoned for industrial activity (based on comprehensive zoning plans or the equivalent), an outfall that discharges from a single pipe with an inside diameter of 12 inches or more or from its equivalent (discharge from other than a circular pipe associated with a drainage area of 2 acres or more). 0 City of Greensboro Stormwater Management Plan (Draft) 3.3 Receiving Waters Greensboro is located near the headwaters of the Cape Fear River Basin in the Piedmont physiographic region of North Carolina, with a majority of the City's jurisdictional watersheds draining eastward toward the Haw River, while a smaller portion of the City area drains south toward the Deep River. The North and South Buffalo Creek Watersheds drain the majority of the City's central urbanized area eastward toward Buffalo Creek. Beyond the eastern City limits, Buffalo Creek drains generally northeastward into the Reedy Fork Creek and the Haw River, a tributary of the Jordan Lake watershed. The City of Greensboro, with a total area of about 132 square miles, represents just over 1 % of the 9,322 square mile Cape Fear River Basin. Table 2 summarizes primary MS4 receiving waters within the City's jurisdictional area. The following NCDEQ sources were referenced to verify applicable water quality classifications and water quality parameters of interest: • Waterbody Classification Map • Most recent NCDEQ Final 303(d) List 10 City of Greensboro Stormwater Management Plan (Draft) Table 2: Summary of Primary MS4 Receiving Waters (Alphabetical) Brush Creek Within corporate limits WS-III;NSW Bull Run Within corporate limits WS-IV:*, WS-IV;CA:* East Fork Deep River Within corporate limits WS-IV:*, WS-IV;CA:* Hickory Creek Within corporate limits WS-IV:*, WS-IV;CA:* Horsepen Creek Within corporate limits WS-III;NSW, WS-III;NSW,CA Little Alamance Creek Within corporate limits WS-IV;NSW, WS-IV;NSW,CA North Buffalo Creek Within corporate limits WS-V;NSW Reedy Fork Within corporate limits WS-III;NSW, WS-III;NSW,CA, WS-V; NSW South Buffalo Creek Within corporate limits WS-V;NSW Benthos, Fish Community N/A Benthos Benthos Benthos N/A Benthos, Fish Community, Copper, Zinc, Fecal Coliform Benthos, Fish Community Benthos, Fish Community, Fecal Coliform CA: Critical Area NSW: Nutrient Sensitive Waters WS-III: Water Supply III — Moderately Developed WS-IV: Water Supply IV — Highly Developed WS-V: Water Supply V — Upstream *Identifies waters that are within a designated Critical Supply Watershed and are subject to a special management strategy specified in 15A NCAC 213 .0248 City of Greensboro Stormwater Management Plan (Draft) 3.4 MS4 Interconnection The City of Greensboro MS4 is not interconnected with another regulated MS4 and directly discharges to the receiving waters as listed in Table 2 above. 3.5 Total Maximum Daily Loads (TMDLs) The TMDL(s) listed in Table 3 below have been approved within the MS4 area, as determined by the map and list provided on the NCDEQ Modeling & Assessment Unit web page. The table also indicates whether the approved TMDL has a specific stormwater Waste Load Allocation (WLA) for any watershed directly receiving discharges from the permitted MS4, and whether a Water Quality Recovery Program has been implemented to address the WLA. Best management practices (BMPs) for addressing MS4 permit requirements as they pertain to TMDLs are described in Part 13 of this SWMP. Table 3: Summary of Approved TMDL(s) North Buffalo Creek Fecal Coliform Y Y 3.6 Endangered and Threatened Species and Critical Habitat Significant populations of threatened or endangered species and/or critical habitat are not identified within the City of Greensboro regulated MS4 urbanized area. This determination was made based upon a review of the Endangered and Threatened Species and Species of Concern by County for North Carolina Map and Listed species believe to or known to occur in North Carolina map as provided by the U.S. Fish and Wildlife Service. 3.7 Industrial Facility Discharges The City of Greensboro jurisdictional area includes multiple industrial facilities that hold NPDES Industrial Stormwater Permits as determined from the NCDEQ Maps & Permit Data web page. The list of permitted industrial facilities within the City of Greensboro is updated annually as required by Part II Section H.2(a). The City will provide program results in the City's annual reporting, as documented in Part 10 of the SWMP. 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the City of Greensboro as summarized in Table 4 below. The City's Stormwater Management Ordinance prohibits the discharge of any non-stormwater flow to any stormwater conveyance with the exception of those discharges listed in Table 4. The City of Greensboro has evaluated residential and charity car washing and street washing for possible significant water quality impacts. Street washing discharges are addressed under the Pavement 12 City of Greensboro Stormwater Management Plan (Draft) Management Program in Part 10 of this SWMP. The Division has not required that other non-stormwater flows be specifically controlled by the City of Greensboro. Washwater associated with car washing that does not contain detergents or does not discharge directly into the MS4 is considered incidental. However, these types of non-stormwater discharges that do contain detergents have been evaluated by the City of Greensboro to determine whether they may significantly impact water quality. These discharges are primarily addressed by the City through the Public Education and Outreach program and the Illicit Discharge Detection and Elimination program as addressed in Parts 5 and 7 of this SWMP. Table 4: Allowable Non-Stormwater Discharges Water line flushing Diverted stream flows Rising groundwater Uncontaminated groundwater infiltration Uncontaminated pumped groundwater Foundation drains Air conditioning condensation Irrigation water Springs 3.9 Target Pollutants and Sources Water from crawl space pumps Footing drains Lawn watering Residential car washing Flows from riparian habitats and wetlands Dechlorinated swimming pool discharges Street wash -water Discharges from firefighting The Stormwater Management Division has identified common water quality pollutants and potential sources and activities contributing to these pollutants. Target audiences have been identified allowing for proactive measures to be implemented. Table 5 summarizes this information, including the associated SWMP programs that address each pollutant. Target pollutants are addressed throughout the permit term in accordance with the goals and schedule described within this SWMP for each respective program area. 13 City of Greensboro Stormwater Management Plan (Draft) Table 5: Summary of Target Pollutants and Sources Residents, Miscellaneous Illicit Connections, Businesses/Industries, IDDE, Improper Disposal PP/GH, IIP Institutions Bacteria (e.g., Fecal Pet/Animal Waste, SSOs Coliform, E. coli) Pesticides, Fertilizers, Residential Lawns and Yard Waste, Loose Leaf Gardens, Landscaping Residents, Kennels Residents, Landscapers PE&O, IDDE PE&O, IDDE, PP/GH, IIP Petroleum Products, Residents, Auto Shops, Vehicle Maintenance/Auto PE&O, IDDE, Automotive Fluids, Mobile Auto Washers, Repair, Pressure Washing IIP Heavy Metals Permitted Facilities Vehicle/Equipment Mobile Auto Washers, Detergents, Cleaning IDDE, Agents Washing, Mop Water, Floor Businesses, Permitted PP/GH, IIP Cleaning Facilities Fats, Oils, Grease Cooking Oil/Grease, Food Residents, Restaurants, PE&O, IDDE, Waste Food Trucks FOG Paint, Drywall, Construction, Structural Residents, Painters, Construction Waste Repair/Maintenance Structural Contractors, IDDE Builders Construction/Building, Builders, Contractors Sediment/Turbidity, Structural (Concrete/Ready-Mix, IDDE, E&SC Slurry Repair/Maintenance, Construction), Concrete/Cement Drillers/Borers Litter, Household Residents, Residents, PE&O, Hazardous Waste Businesses/Industries, Businesses/Industries, PP/GH (HHW) Institutions Institutions *PE&O: Public Education and Outreach (SWMP Section 5.0) IDDE: Illicit Discharge Detection and Elimination (SWMP Section 7.0) E&SC—Erosion and Sediment Control: Construction Site Runoff Controls (SWMP Section 8.0) PP/GH: Pollution Prevention and Good Housekeeping for Municipal Operations (SWMP Section 10.0) IIP—Industrial Inspection Program: Program to Monitor and Control Pollutants in Stormwater Discharges to Municipal Systems (SWMP Section 11.0) FOG: Fats, Oils, and Grease (Program through Wastewater Permit(s)—Water Resources, Operations Division) *May include partnership with Stormwater SMART. 14 City of Greensboro Stormwater Management Plan (Draft) 4.0 STORMWATER MANAGEMENT PROGRAM IMPLEMENTATION 4.1 Legal Authority The required legal authorities for Greensboro's NPDES municipal stormwater program were developed and adopted during the first permit period in a new ordinance to the Greensboro Land Development Ordinance: Chapter 30 (City of Greensboro Stormwater Management Ordinance). The Stormwater Management Ordinance became effective on July 1, 1994. The Chapter 30 ordinance includes the following objectives: • To provide for the establishment and enforcement of the City's Stormwater Management Program; • To reduce the discharge of pollutants to the storm sewer system to the maximum extent practicable by requiring, where appropriate, the use of best management practices, structural and/or nonstructural stormwater quantity and quality control measures and other provisions; • To provide for the inspection and proper maintenance of structural and nonstructural stormwater controls and the municipal separate storm sewer; • To prohibit non-stormwater discharges to the City storm sewer and require the removal of illicit connections to the City storm sewer; • To prevent improper disposal of materials that degrade water quality; • To permit sampling and monitoring for pollutants such as those associated with illicit discharges, improper disposal, industrial and construction activities, and the application of pesticides, herbicides, and fertilizers; and, • To reduce erosion associated with stormwater runoff; and • To provide legal definitions for user fee rate calculations. To date, no significant changes have been required or considered for the City's legal authority related to NPDES stormwater program implementation. Stormwater Management, working with City Management, Council, and Stakeholders, has incorporated runoff quantity control and citywide stream buffer requirements into the Code of Ordinance in recent years, but these have not been specific NPDES MS4 discharge permit requirements. Many of these additional requirements along with historic stormwater related regulations are located throughout the Code of Ordinance with a large portion appearing in Chapter 30 which serves as the City's Unified Development Ordinance. Additional ordinance language specific to the Phase II rules, specifically with regard to post -construction runoff, was adopted by City Council on April 7, 2009, and became effective June 1, 2009. 4.2 Organizational Structure The City of Greensboro's Stormwater Management utility is one of seven divisions of the City's Water Resources Department (which includes water supply, water reclamation, customer service, business, engineering, and operations and maintenance). This organizational arrangement facilitates protecting and improving surface water quality while best managing local water resources. Although the Stormwater Management Division resides within the Water Resources Department, the program itself is much broader and encompasses and/or extends well beyond the boundaries of the Water Resources Department. Several other departments in the City of Greensboro, as well as those in Guilford County, contribute to stormwater quality management and NPDES-related programs in 15 City of Greensboro Stormwater Management Plan (Draft) substantive ways. The following bullet points and Table 6 identify the overall organizational structure and functional responsibilities of the City's Stormwater Management Program. City Stormwater Management Division: NPDES MS4 Discharge Permit administration for Greensboro; stormwater utility administration; surface water quality monitoring and operations management; computerized infrastructure management systems; stormwater and surface water quality related complaint response; stormwater conveyance system inventory and detailed MS4 outfall mapping; public education and awareness; stormwater and watershed master planning; site development plan reviews for stormwater management; general stormwater-related technical support and mapping; local Federal Emergency Management Agency (FEMA) National Flood Insurance Program (NFIP) floodplain administration; local water supply watershed protection program administration; stormwater control measures (SCM) evaluations and SCM crediting; SCM inspections and monitoring; field screening and follow-up monitoring activities; industrial monitoring and related activities; industrial inspections and educational efforts; system inspection; special stormwater inspection and enforcement programs; water quality inspections and monitoring programs; overall authority (as delegated from City Manager's Office) over the municipal stormwater quality management programs • City Field Operations Department: Litter (including floatables) and loose-leaf collection programs; street cleaning and sweeping programs; closed drainage infrastructure system routine and remedial maintenance activities; open channel maintenance; new storm sewer construction • City Engineering and Inspections Department: Project design, construction contract bidding, construction contract administration, and inspections of new development and redevelopment; stormwater capital improvement projects and property acquisition; local construction erosion and sedimentation control program administration • City Parks and Recreation Department: City of Greensboro parks, greenway and utility easement maintenance coordination and programs; partner in volunteer programs such as Adopt -a -Park • City Planning Department: Overall City planning including management of plan review process; comprehensive planning; management of City's Technical Review Committee (TRC) for design engineers and developers; zoning management and ordinance development and revisions • City Water Resources Department (beyond Stormwater Division): Enhancements to the municipal stormwater system and receiving waters by controlling sanitary sewer overflows (SSOs) and industrial spills; pretreatment programs for major industry; water supply and wastewater treatment programs, including planning and management; water distribution system and sanitary sewer system maintenance programs • City Fire Department: Spill response program — HAZMAT (HAZardous MATerials) Team, containment of spills; industrial site inspections • City Management Information Systems Department: Data management including city Geographic Information Systems (GIS) and city database administration; city computer systems management; aerial photography and related city mapping programs • City Legal Department: Permit -related legal, enforcement and ordinance assistance; other legal services including contract and agreement reviews • (Guilford County) Emergency Management/Health Department: County emergency management programs, chemical control; county spill response, coordinate cleanup & reporting its City of Greensboro Stormwater Management Plan (Draft) Table 6: Summary of Responsible Positions Stormwater Program Stormwater Management David Phlegar Water Resources — Administration Division Manager Stormwater Management SWMP Management Water Quality Section Toni Branson Water Resources — Supervisor Stormwater Management Public Education Laine Roberts Water Resources — Public Education & Coordinator Business Outreach Water Quality Analyst Shameka Water Resources — Williams Stormwater Management Public Involvement & Public Education Laine Roberts Water Resources — Participation Coordinator Business Water Quality Analyst TBD Water Resources — Illicit Discharge Detection Stormwater Management & Elimination Operations Management Ray Johnson Water Resources — Section Supervisor Stormwater Management Construction Site Runoff Erosion and Sediment Cass Heaton Water Resources — Controls Control Chief Stormwater Management Post -Construction Site Stormwater Engineering Johnnie Hill Water Resources — Runoff Controls Section Supervisor Engineering Municipal SCM Operation Operations Management Ray Johnson Water Resources— & Maintenance Program Section Supervisor Stormwater Management Environmental Elea Reyna Water Resources — Compliance Specialist Ocampo Stormwater Management Water Quality Analyst Shameka Water Resources — Pollution Prevention & Williams Stormwater Management Good Housekeeping for Municipal Operations Public Education Laine Roberts Water Resources — Coordinator Business For additional information on specific program responsibilities, refer to the City's most recent MS4 Operation & Maintenance Plan. Program to Monitor & Water Resources— Control Pollutants in Water Quality Analyst TBD Stormwater Management Stormwater Discharges Water Quality Section Toni Branson Water Resources — Water Quality Assessment Supervisor Stormwater Management & Monitoring Water Resources — Water Quality Analyst TBD Stormwater Management Total Maximum Daily Water Quality Analyst TBD Water Resources — Loads Stormwater Management 17 City of Greensboro Stormwater Management Plan (Draft) MYOF OREEN560RO Organim7ional Cher1 D—.b-2M I h-LFe— tff,—.I* 'lYY' Mw} r�r� MshaJl YY �� ali G4io A� GOJ¢il�1�G1! 115 R1GIu ®�. hi3�i�n rltW .eA {ALllil6 �xwQ amcrc MnV NLSOWS w n�ea YWItl �rW�LLIf Qi bran iIFGMiYI YYViaiR w�YY�r C_ muWa .en rpan �� mxawcc ommxo�ou wet ah�- wum n� {LYI OF441GYE RYR#WY f116E� GLRRf p16'9! YIXYOI IY�Q C C lyY� �a Lp1� arm LlaliQY AMypQhGlA �O�Wr [tl�ML W 6 w�i amid we a¢�usi YrYr�rurrt cnrrxev� Figure 3: City of Greensboro MS4 Permit Implementation Organizational Chart 18 City of Greensboro Stormwater Management Plan (Draft) 4.3 Program Funding and Budget In accordance with the issued permit, the City of Greensboro shall maintain adequate funding and staffing to implement and manage the provisions of the SWMP and comply with the requirements of the NPDES MS4 Permit. The budget includes the permit administering and compliance fee, which is billed by the Division annually. The City established a stormwater utility funding mechanism partially in response to the initial and ongoing requirements of the NPDES municipal stormwater permit, but also to help ensure a dedicated funding source for stormwater-related programs and activities and to manage municipal stormwater issues in a more proactive and comprehensive manner. As impervious area is generally in direct correlation with the volume and quality of surface stormwater runoff, establishing the stormwater billing system based on total impervious area is equitable to all of the City's utility customers. As of January 1, 2004, single-family residences are charged one of three tiers with an average rate of $2.70 per month. Non -single-family properties are billed based upon the number of equivalent residential units (ERUs), which is computed by dividing the total impervious area by the size of the ERU (2,543 square feet), on the given property. Additionally, as a financial incentive for nonstructural and structural best management practice implementation at non -single-family residential sites throughout the City, Greensboro provides a fee crediting mechanism within the stormwater utility. The City also provides technical support and educational assistance for innovative stormwater practices. The stormwater utility is a dedicated balanced enterprise fund with budgeted revenues and expenditures of just over fourteen million dollars in the coming fiscal year. This budget represents a slightly higher than normal budget due to an extra investment in capital projects this fiscal year. The chart illustrates the allocation of Stormwater Utility funds by operational category. Stormwater FY 2021-2022 Budget Expenses $1059695268.00 Administration 8%\ Construction 20% Street Cleaning 24% Operations Management 4% Water Quality & Monitoring Planning & 8% Engineering 4% Public Education & Maintenance Awareness 31% 1% Figure 4: City of Greensboro Stormwater Fiscal Year 2021-2022 Budget Expenses 19 City of Greensboro Stormwater Management Plan (Draft) 4.4 Shared Responsibility The City of Greensboro will share the responsibility to implement the following minimum control measure(s), which are at least as stringent as the corresponding NPDES MS4 Permit requirement. The City of Greensboro remains responsible for compliance if the other entity fails to perform the permit obligation, and may be subject to enforcement action if neither the City of Greensboro nor the other entity fully performs the permit obligation. Table 7 below summarizes any shared responsibilities. Table 7: Shared Responsibilities Public Education & Outreach Stormwater SMART* (Piedmont Triad Regional Council) N (Contractual) *Stormwater SMART: https://www.ptrc.org/services/regional-planning/stormwater-smart 4.5 Co-Permittees The are no other entities applying for co-permittee status under the NPDES MS4 permit number NCS000248 for the City of Greensboro. 4.6 Measurable Goals for Program Implementation The City of Greensboro will manage and report the following BMPs for the administration of the Stormwater Management Program. 20 City of Greensboro Stormwater Management Plan (Draft) Table 8: Program Implementation BMPs Program Permit II.AA: "The permittee will maintain adequate legal mechanism, such as regulations, Ref. ordinances, policies and procedures to implement all provisions of the Stormwater Management Plan. If major modifications are proposed in the timeline for development of these authorities, the Division must be notified of the changes, the reasons for the changes, and justifications for the changes. The Division may comment on the modifications and require changes as allowed by Federal and State and as deemed necessary to assure appropriate implementation of the Stormwater Management Plan. The Permittee shall obtain prior approval of changes to the Stormwater Management Plan that eliminate or reduce any program or measure in an approved Stormwater Management Plan." BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Implementation Reporting Metric 1. Maintain regulations, ordinances, policies, and procedures. Maintain adequate legal Review regulations, Annually, Permit Report any mechanism, such as ordinances, policies, Years 1-5 updates and regulations, ordinances, and procedures and modifications. policies, and procedures to update if necessary. implement all provisions of the Stormwater Management Plan. Permit F. II.A.2: "The permittee will implement provisions of the Stormwater Management Plan and Ref. evaluate the performance and effectiveness of the program components." BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Implementation Reporting Metric 2. Implement the Stormwater Management Plan. Implement the City's Evaluate program Annually, Permit Described in SWMP and evaluate effectiveness as Years 1-5 Section 14 performance and described in Section (Program effectiveness. 14 (Program Assessment, Assessment, Reporting, and Reporting, and Recordkeeping) Recordkeeping) Permit II.A.3: "The permittee is required to keep the Stormwater Management Plan up to date with Ref. annual updates if any changes are warranted. The permittee is required to make available its Stormwater Management Plan to the Division upon request. At a minimum, the permittee shall include ordinances, or other regulatory mechanisms or a list identifying the ordinances, or other regulatory mechanisms providing the legal authority necessary to implement and enforce the requirements of the permit. The Division may review reports submitted by the permittee to assure that the Stormwater Management Plan is implemented appropriately to address the requirements of the permit. The Division may require modifications to any part of the permittee's Stormwater Management Plan where deficiencies are found. If modifications to the Stormwater Management Plan are necessary, then the Division will notify the permittee of the need to modify the Stormwater Management Plan to be consistent with the permit and will establish a deadline to finalize such changes to the program." A B C D 21 City of Greensboro Stormwater Management Plan (Draft) Description of BMP Measurable Goal(s) Schedule for Annual No. Implementation Reporting Metric 3. Keep the Stormwater Management Plan up to date. Maintain SWMP with 1. Update the SWMP 1. Permit Year 1 1. Report any annual updates if any to incorporate current updates and changes are warranted. permit requirements modifications. and program components. 2. Review the SWMP 2. Annually, 2. Report any and update if Permit Years 2-5 updates and necessary. modifications. 4. Maintain appropriate legal mechanisms. Include ordinances or other Review regulations, Annually, Permit Report any regulatory mechanisms ordinances, policies, Years 1-5 updates and providing legal authority to and procedures and modifications. implement and enforce the update if necessary. requirements of the permit. II.AA: "The permittee shall maintain, and make available to the Division upon request, written Permit Ref. procedures for implementing the six minimum control measures. Written procedures shall identify specific action steps, schedules, resources and responsibilities for implementing the six minimum measures." A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Implementation Reporting Metric 5. Maintain written procedures. Maintain written procedures 1. Maintain written 1. Ongoing, 1. N/A for implementing the six procedures as Permit Years 1-5 minimum control measures documented in this and make available to the SWMP. Division upon request. 2. Review and 2. Annually, 2. N/A update written Permit Years 1-5 procedures as necessary and as documented in this SWMP. 22 City of Greensboro Stormwater Management Plan (Draft) 5.0 PUBLIC EDUCATION AND OUTREACH The City of Greensboro will implement a Public Education and Outreach Program to distribute educational materials to the community or conduct equivalent outreach activities about the impacts of stormwater discharges on water bodies and steps the public can take to reduce pollutants in stormwater runoff. The target audiences and identified pollutants listed in Part 3.9 of this SWMP, which will be addressed by the Public Education and Outreach Program, are summarized in Table 5. In addition, the City of Greensboro is required to inform businesses and the general public of the hazards associated with illicit discharges, illegal dumping, and improper disposal of waste. The City of Greensboro will manage, implement, and report the following public education and outreach BMPs. Table 9: Public Education and Outreach BMPs OutreachPublic Education and Permit II.113.2.a: Describe target pollutants and target pollutant sources Ref. "Describe the target pollutants and target pollutant sources the permittee's public education program is designed to address and why they are an issue." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 6. Describe target pollutants and target pollutant sources. Describe the target 1. Re-evaluate 1. Permit Year 1 1. Target pollutants and target target pollutant pollutants, pollutant sources the sources. sources, and why permittee's public education they are an issue program is designed to 2. Review and 2. Annually, Permit 2. Target address and why they are update target Years 2-5 pollutants, an issue. pollutant sources, sources, and why if needed, based they are an issue on previous year. Permit II.113.2.b: Describe target audiences Ref. "Describe the target audiences likely to have significant storm water impacts and why they were selected." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 7. Describe target audiences. Describe the target 1. Re-evaluate 1. Permit Year 1 1. Target audiences likely to have target audiences audience(s) for significant stormwater as needed to each target impacts and why they were address current pollutant and why selected. target pollutants. they were selected 23 City of Greensboro Stormwater Management Plan (Draft) Public Education . Outreach 2. Review and 2. Annually, Permit 2. Target update target Years 2-5 audience(s) for audiences, if each target needed, based on pollutant and why previous year. they were selected Permit II.B.2.c: Information Web Site Ref. "The permittee shall promote and maintain, an internet web site designed to convey the program's message." BMP A B C D No. Description of BMP easurable Schedule for Annual Reporting Implementation Metric 8. Maintain Website with program information. Promote and maintain an Maintain and Ongoing, Permit Website analytics internet website designed to promote the Years 1-5 convey the program's Stormwater message. Program webpages. Permit II.B.2.d: Distribute public education materials to identified user groups Ref. "Distribute general stormwater educational material to appropriate target groups as likely to have a significant stormwater impact. Instead of developing its own materials, the permittee may rely on state -supplied Public Education and Outreach materials, as available, when implementing its own program." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 9. Distribute public education materials. Distribute general 1. Distribute 1. Ongoing, Permit 1. Number of stormwater educational materials through Years 1-5 events for which material to appropriate a variety of materials were target groups as likely to avenues such as distributed and have a significant public events, approximate stormwater impact. social media, and number of other virtual participants or platforms. individuals reached 2. Review 2. Annually, Permit 2. Note which educational Years 2-5 material(s) were materials and updated or created update or generate new materials as needed. Permit II.B.2.e: Promote and maintain Hotline(s) or Helpline(s) Ref. "Promote and maintain a stormwater hotline(s) or helpline(s) for the public to request information about stormwater, public involvement & participation, and to report illicit connections & discharges, etc." 24 City of Greensboro Stormwater Management Plan (Draft) . sutreaCh BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 10. Inform public of City Contact Center. Inform public of City Contact Display 373-CITY Ongoing, Permit Number of water Center (336-373-CITY) as on relevant City Years 1-5 quality or pollution an avenue to report issues webpages in calls received by and request information. prominent City Contact locations and on Center printed materials. Permit II.B.2.f: Implement a Public Education and Outreach Program Ref. "The permittee's outreach program, including those elements implemented locally or through a cooperative agreement, shall include a combination of approaches designed to reach the target audiences. For each media, event or activity, including those elements implemented locally or through a cooperative agreement the permittee shall estimate and record the extent of exposure." A B C D BMP No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 11. Implement a public education and outreach program. Implement a public Implement the Ongoing, Permit Number of events education and outreach public education Years 1-5 or activities and program to reach the target and outreach number of audiences. For each activity program. participants for estimate and record the each extent of exposure. 25 City of Greensboro Stormwater Management Plan (Draft) 6.0 PUBLIC INVOLVEMENT AND PARTICIPATION This SWMP identifies the minimum elements and implementation of a Public Involvement and Participation Program that complies with applicable State, Tribal, and local public notice requirements. The City of Greensboro will manage, implement, and report the following public involvement and participation BMPs. Table 10: Public Involvement and Participation BMPs Permit II.C.2.a: Volunteer community involvement program Ref. "The permittee shall include and promote volunteer opportunities designed to promote ongoing citizen participation." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 12. Include and promote volunteer opportunities. Include and promote Implement the volunteer opportunities to City's volunteer promote ongoing citizen community participation. involvement program. Ongoing, Permit Number of Years 1-5 volunteer opportunities and number of participants in each Permit II.C.2.b: Establish a Mechanism for Public Involvement Ref. "The permittee shall provide and promote a mechanism for public involvement that provides for input on stormwater issues and the stormwater program." BMP A B C No. Description of BMP Measurable Schedule for Goal(s) Implementation 13. Provide a mechanism for public involvement. Provide and promote a mechanism for the public to provide input on stormwater issues and the City's stormwater program. 1. Offer public comment period during bi-monthly City Council meetings. 2. Offer project specific public maatinn-q ,5. urrer opportunity for public review and comment during permit reissuance period. a Annual Reporting Metric 1. Ongoing, Permit 1. Y/N Years 1-5 2. As needed 2. Y/N Permit Years 1-5 3. Within 6 months 3. Y/N prior to permit reissuance 26 City of Greensboro Stormwater Management Plan (Draft) Public• Participation Permit II.C.2.c: Establish a Hotline(s) or Helpline(s) Ref. "The permittee shall promote and maintain a hotline(s) or helpline(s) for the public to request information about stormwater, public involvement participation, and to report illicit connections & discharges, etc." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 14. Promote and maintain a stormwater hotline or helpline. Inform public of City Contact Display 373-CITY Ongoing, Permit Number of water Center (336-373-CITY) as on relevant City Years 1-5 quality or pollution an avenue to report issues webpages in calls received by and request information. prominent City Contact locations and on Center printed materials. Permit II.C.2.d: Public Review and Comment Ref. "The permittee shall make their most recent Stormwater Management Plans available for public review and comment." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric Reference SWMP on City webpage. 15. Reference most recent Reference most Ongoing, Permit Website analytics Stormwater Management recent SWMP on Years 1-5 (e.g., number of Plan on City Stormwater Stormwater views) webpage. webpage. Permit II.C.2.e: Public Notice Ref. "Pursuant to 40 CFR 122.34 the permittee must, at a minimum, comply with State, Tribal and local public notice requirements when implementing a public involvement/participation program." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting jkL dh Goal(s) Implementation Metric 16. Comply with applicable State, Tribal, and local public notice requirements. Comply with State and City Provide Ongoing, Permit Y/N public notice requirements opportunities for Years 1-5 when advertising public public input on review and comment stormwater opportunities or when program. notifying public of other opportunities to participate. 27 City of Greensboro Stormwater Management Plan (Draft) 7.0 ILLICIT DISCHARGE DETECTION AND ELIMINATION The City of Greensboro will develop, manage, implement, document, report, and enforce an IDDE Program which shall, at a minimum, include the following illicit discharge detection and elimination BMPs. Table 11: Illicit Discharge Detection and Elimination BMPs DischargeIllicit Detection Permit II.D.2.a: Maintain appropriate legal authorities Ref. "Maintain adequate ordinances or other legal authorities to prohibit illicit connections and discharges and enforce the approved IDDE Program." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 17. Maintain appropriate IDDE legal authorities. Maintain ordinance to 1. Review and 1. Once per permit 1. Report any prohibit and enforce illicit update ordinances cycle updates and connections and as necessary. modifications. discharges. 2. Review and 2. Once per permit 2. Report any revise cycle updates and enforcement of modifications. standard operating procedure (SOP) as necessary. Permit II.D.2.b: Maintain a Storm Sewer System Base Map of Major MS4 Outfalls Ref. "The permittee shall maintain a current map showing major outfalls and receiving streams." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 18. Maintain MS4 base map of major MS4 outfalls. Maintain current map Review and Ongoing, Permit Report any showing major MS4 outfalls update as needed Years 1-5 updates and and receiving streams. modifications. Permit II.D.2.c: Inspection/detection program to detect dry weather flows at MS4 outfalls Ref. "Maintain written procedures and/or Standard Operating Procedures (SOPs) for detecting and tracing the sources of illicit discharges and for removing the sources or reporting the sources to the State to be properly permitted. Written procedures and/or SOPs shall specify a timeframe for monitoring and how many outfalls and the areas that are to be targeted for inspections." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 19. Maintain SOPs for finding and addressing illicit discharges. 28 City of Greensboro Stormwater Management Plan (Draft) DischargeIllicit Detection and Elimination and update IDDE Review and revise Once per permit Y/N SOP. IDDE SOP as cycle needed. Permit II.D.2.d: Employee Training Ref. "Conduct training for appropriate municipal staff on detecting and reporting illicit connections and discharges." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 20. Provide training for IDDE staff. Conduct municipal staff Staff training for Ongoing, Permit Training date(s), training for IDDE program. IDDE Years 1-5 topics, and staff names Permit II.D.2.e: Maintain a public reporting mechanism(s) Ref. "Maintain and publicize reporting mechanism(s) for the public to report illicit connections and discharges." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 21. Maintain IDDE reporting mechanism for the public. Maintain and publicize Ensure reporting Ongoing, Permit Y/N reporting mechanisms (e.g., mechanisms are Years 1-5 website, app, City Contact maintained, Center 336-373-CITY) publicized, and updated. Permit II.D.2.f: Documentation Ref. 'The permittee shall document the date of investigations, any enforcement action(s) or remediation that occurred." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 22. Document IDDE program. Document illicit connections Document IDDE Ongoing, Permit Number of and discharge inspections, program activities. Years 1-5 investigations and investigations, and results. resolution. 29 City of Greensboro Stormwater Management Plan (Draft) 8.0 CONSTRUCTION SITE RUNOFF CONTROLS The City of Greensboro's MS4 permit requirements pertaining to Construction Site Runoff Controls are managed through the City's locally delegated Erosion and Sediment Control (E&SC) Program. The E&SC program meets the standard for Construction Site Runoff Controls through permitting and controlling development activities as authorized under the Sediment Pollution Control Act (SPCA) of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. The SPCA requirements include reducing pollutants in stormwater runoff from construction activities that result in land disturbance of greater than or equal to one acre, and includes any construction activity that is part of a larger common plan of development that would disturb one acre or more. The City of Greensboro implements the following BMPs to meet NPDES MS4 Permit requirements for Construction Site Runoff Controls. Table 12: Construction Site Runoff Control BMPs Permit II.E.2.a: "The permittee has a delegated or authorized Sediment and Erosion Control Ref. Program. As such, to the extent authorized by law, the permittee is responsible for compliance with the Sediment Pollution Control Act of 1973 and Chapter 4 of Title 15A of the North Carolina Administrative Code. The delegated or authorized Sediment and Erosion Control Program effectively meets the 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." BMP A B C D No. Description of BMP Measurable Schedule for Annual Goal(s) Implementation Reporting Metric 23. Conduct erosion and sediment control inspections. Conduct erosion and 1. Inspect 100% of 1. Annually, Permit 1. Number of sediment control active sites. Years 1-5 inspections inspections for all permitted completed sites. 2. Issue Notice of 2. As needed, 2. Number of Violation (NOV) if Permit Years 1-5 NOVs, number of not in compliance. NOVs corrected 3. Issue stop work 3. As needed, 3. Number of stop orders if not Permit Years 1-5 work orders remedied. 4. Escalate 4. As needed, 4. Number of enforcement Permit Years 1-5 enforcements, process if NOV number of not corrected. corrected actions Permit II.E.2.b: "The NCGO10000 permit establishes requirements for construction site operators to Ref. control waste such as discarded building materials, concrete truck washout, chemicals, litter, and sanitary waste at the construction site that may cause adverse impacts to water quality." A B C D all City of Greensboro Stormwater Management Plan (Draft) Construction Site Runoff Controls BMP Description of BMP Measurable Schedule for Annual Goal(s) Implementation Reporting Metric 24. Ensure NCG01 requirements are being implemented. Ensure NCG01 Ensure 100% of Ongoing, Permit Number of plans requirements are added to plans are Years 1-5 reviewed construction site plans compliant. including ground stabilization and materials handling worksheet, seeding table with timelines, self -inspection requirements, and details. Permit II.E.2.c: "The permittee shall provide and promote a means for the public to notify the Ref. appropriate authorities of observed erosion and sedimentation problems. The permittee may implement a plan promoting the existence of the NCDEQ "Stop Mud" hotline (1-866- STOPMUD) to meet the requirements of this paragraph." BMP A B C D No. Description of BMP Measurable Schedule for Annual Goal(s) Implementation Reporting Metric 25. Maintain City Contact Center and E&SC webpage that links to Stormwater. Maintain City of 1. Maintain 1. Ongoing, Permit 1. Y/N Greensboro construction webpage for Years 1-5 site runoff/erosion/land E&SC disturbance/grading webpage and Contact 2. Maintain City 2. Ongoing, Permit 2. Y/N Center (336-373-CITY) reporting hotline Years 1-5 (373-CITY) Permit II.E.2.d: "For new development and redevelopment projects to be built within the permittee's Ref. planning jurisdiction by entities with eminent domain authority, the permittee shall, to the maximum extent practicable, coordinate the approval of the construction site runoff control with the DEMLR." BMP A B C D No. Description of BMP Measurable Schedule for Annual Goal(s) Implementation Reporting Metric 26. Provide a mechanism to direct permittee to DEMLR. Coordinate approval of Maintain process I Ongoing, Permit Report any construction site runoff for to direct applicant Years 1-5 changes. entities with eminent to another domain authority. jurisdiction where appropriate. 31 City of Greensboro Stormwater Management Plan (Draft) 9.0 POST -CONSTRUCTION SITE RUNOFF CONTROLS This SWMP identifies the minimum elements to develop, implement, and enforce a program to address stormwater runoff from new development and redevelopment projects that disturb greater than or equal to one acre, including projects less than one acre that are part of a larger common plan of development or sale, that are located within the City of Greensboro and discharge into the MS4. These elements are designed to minimize water quality impacts utilizing a combination of structural SCMs and/or non- structural BMPs appropriate for the community, and ensure adequate long-term operation and maintenance of SCMs. The City of Greensboro implements the following BMPs to meet NPDES MS4 Permit requirements for Post -Construction Site Runoff Controls. Table 13: Post -Construction Site Runoff Control BMPs Permit II.F.2.a: Post -Construction Stormwater Management Program Ref. "Maintain an ordinance (or similar regulatory mechanism) that authorizes a program to address stormwater runoff from new development and redevelopment to the extent allowable under State law." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting on Goal(s) ImplementatiMetric 27. Maintain a post -construction Stormwater Management Ordinance. Maintain City's post- Review ordinance Once per permit Report any construction stormwater and revise as cycle updates and management ordinance. necessary. modifications. Permit II.F.2.b: Strategies which include Stormwater Control Measures (SCMs) appropriate for Ref. Tthe MS4 "Maintain strategies that include a combination of structural and/or non-structural SCMs implemented in concurrence with (a) above. Provide a mechanism to require long-term operation and maintenance of structural SCMs. Require annual inspection reports of permitted structural SCMs performed by a qualified professional. A qualified professional means an individual trained and/ or certified in the design, operation, inspection and maintenance aspects of the SCMs being inspected, for example, someone trained and certified by NC State for BMP Inspection & Maintenance. Within 12 months of the effective date of this permit, the permittee shall evaluate, and revise as needed, SCM requirements, to be at least as stringent as the minimum requirements in 15A NCAC 02H .1000." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 28. Ensure stormwater control measures (SCMs) are being implemented. Implement TRC program to Reviewed plans J Ongoing, Permit Y/N review required SCMs. per ordinance. Years 1-5 0 City of Greensboro Stormwater Management Plan (Draft) Post -Construction 29. Ensure long-term SCM 1Obtain executed Ongoing, Permit Y/N maintenance through O&M O&M agreement Years 1-5 agreements. for each new SCM 30. Require routine inspection 1Completed Ongoing, Permit Number of SCM reports. inspections for Years 1-5 inspections SCMs. completed 31. Ensure City inspection staff City staff are Ongoing, Permit List of staff with maintain qualified credentialed (e.g., Years 1-5 active certifications professional status. North Carolina State University SCM Inspection & Maintenance Certification) Review and revise SCM Ensure SCM Ongoing, Permit Report any 32. requirements to be requirements are Years 1-5 updates and consistent with NC rules. consistent. modifications. Permit II.F.2.c: Deed Restrictions and Protective Covenants Ref. "The permittee shall provide mechanisms such as recorded deed restrictions, plats, and/or protective covenants so that development activities maintain the project consistent with approved plans." A B C D BMP No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 33. Ensure Deed Restrictions/Protective Covenants are recorded. Maintain ordinance 1. Review Once per permit 1. Report any provisions which require ordinance andycle updates and TC1. plats and O&M agreements updated as modifications. to ensure projects maintain needed. consistency with approved 2. Implement 2. Ongoing, Permit 2. Report any plans. standard language Years 1-5 updates and on plats which modifications. matches approved plan. Permit II.F.2.d: Operation and Maintenance Plan Ref. "The developer shall provide the permittee with an operation and maintenance plan for the stormwater system, indicating the operation and maintenance actions that shall be taken, specific quantitative criteria used for determining when those actions shall be taken, and who is responsible for those actions. The plan must clearly indicate the steps that shall be taken and who shall be responsible for restoring a stormwater system to design specifications if a failure occurs and must include a legally enforceable acknowledgment by the responsible party. Development must be maintained consistent with the requirements in the approved plans and any modifications to those plans must be approved by the Permittee." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 34. Require O&M plans. 33 City of Greensboro Stormwater Management Plan (Draft) Post -Construction Site Runoff Controls Require O&M plan for Ensure O&M plan Ongoing, Permit Y/N SCMs. and executed Years 1-5 O&M agreement for each approved SCM. Permit II.F.2.e: Educational materials and training for developers Ref. "Provide educational materials and training for developers. New materials may be developed by the permittee, or the permittee may use materials adopted from other programs and adapted to the permittee's new development and redevelopment program." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 35. Provide education and training. Provide educational 1. Maintain City 1. Ongoing, Permit 1. Y/N materials to development website section Years 1-5 community. dedicated to developers and contractors. 2. Conduct 2. Ongoing, Permit 2. Y/N ongoing informal Years 1-5 education through plan review process. 3. Conduct 3. Ongoing, Permit 3. Y/N ongoing informal Years 1-5 education through local industry trade groups (e.g., TREBIC (Triad Real Estate Building Industry Coalition). 34 City of Greensboro Stormwater Management Plan (Draft) 10.0 POLLUTION PREVENTION AND GOOD HOUSEKEEPING FOR MUNICIPAL OPERATIONS This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City of Greensboro's municipal facilities and operations. Pollution prevention and good housekeeping is accomplished through the implementation of programs that address the ultimate goal of preventing or reducing pollutant runoff from municipal operations, such as parks and open space maintenance, fleet and building maintenance, new construction and land disturbances, and municipal storm sewer system maintenance. This is achieved through the application of a suite of BMPs described below and managed in cooperation with multiple City departments and facilities which may include, but is not limited to, the following: • Coliseum • Engineering and Inspections • Field Operations • Finance (Equipment Services) • Fire • Parks and Recreation • Police • Transportation • Water Resources Table 14: Pollution Prevention and Good Housekeeping BMPs Permit II.G.2.a: Inventory of municipal facilities and operations Ref. "Maintain an inventory of municipal facilities and operations owned and operated by the permittee that have been determined by the permittee to have significant potential for generating polluted stormwater runoff. Also maintain an inventory of municipally- owned structural SCMs." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 36. Maintain inventory of municipal facilities and municipally owned SCMs. Review and update list of 1. Review inventory 1. Annually, 1. Number of municipal facilities and and update as Permit Years 1-5 municipal facilities municipally owned SCMs. needed. and municipally owned SCMs 2. Identify and 2. Once per 2. Updated prioritize new and permit cycle prioritized list for existing facilities new and existing according to municipal facilities pollutant runoff potential. 35 City of Greensboro Stormwater Management Plan (Draft) Pollution Prevention and Good Housekeeping Permit II.G.2.b: Inspection and maintenance program for municipal facilities and operations Ref. "Implement an inspection and maintenance program for facilities and operations owned and operated by the permittee for potential sources of polluted runoff, including stormwater controls and conveyance systems. The inspection program shall evaluate pollutant sources, document deficiencies, plan corrective actions, implement appropriate controls, and document the accomplishment of corrective actions. The maintenance program shall include maintenance activities and procedures aimed at preventing or reducing pollutants generated from municipal facilities and operations." A B C D BMP No. Description of BMP Measurable Schedule for Ann al Re ing Goal(s) Implementation e 37. Implement municipal facilities inspection and maintenance program. Inspection and 1. Inspect municipal 1. Once per 1. Number of maintenance of municipal facilities. permit cycle inspections facilities and operations completed 2. Provide 2. Ongoing, as 2. Number of recommendations needed inspections for municipal resulting in facilities resulting recommendations from inspections. 3. Inspect 3. Ongoing to 3. Number of municipally owned ensure inspections stormwater SCMs. maintenance per completed established schedule Permit II.G.2.c: Site Pollution Prevention Plans for municipal facilities Ref. "Maintain and implement Site Pollution Prevention Plans for municipal facilities owned and operated by the permittee that have been determined by the permittee to have significant potential for generating polluted stormwater runoff that has the goal of preventing or reducing pollutant runoff." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 38. Maintain site pollution prevention plans (SPPPs) for municipal facilities with pollution - runoff potential. Maintain/implement SPPPs 1. Review and 1. Once per 1. Y/N for municipal facilities with update list of permit cycle significant runoff potential municipal facilities needing SPPPs. 2. Review, update, 2. Once per 2. List of facilities and provide SPPPs permit cycle with reviewed or to municipal updated SPPPs facilities for implementation. 36 City of Greensboro Stormwater Management Plan (Draft) Pollution Prevention and ..• Housekeeping Permit II.G.2.d: Spill Response Procedures for municipal facilities and operations Ref. "Maintain spill response procedures for municipal facilities and operations owned and operated by the permittee that have been determined by the permittee to have significant potential for generating polluted stormwater runoff." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 39. Maintain spill response procedures for high -priority municipal facilities. Ensure spill response 1. Review and 1. Once per 1. Y/N procedures are current and update list of permit cycle implemented. facilities requiring SRPs. 2. Review, update, 2. Once per 2. Facilities with and provide SRPs permit cycle reviewed or to municipal updated SRPs facilities for implementation. 3. Train staff on spill 3. Annually, 3. List of staff response Permit Years 1-5 attending training, procedures. dates of training, and training topics Permit II.G.2.e: Prevent or Minimize Contamination of Stormwater Runoff from all areas used Ref. for Vehicle and Equipment Cleaning "Describe measures that prevent or minimize contamination of the stormwater runoff from all areas used for vehicle and equipment cleaning, including fire stations that have more than three fire trucks and ambulances. Perform all cleaning operations indoors, cover the cleaning operations, ensure wash water drains to the sanitary sewer system, collect wash water and stormwater run-on from the cleaning area and provide treatment or recycling, or other equivalent measures. If sanitary sewer is not available to the facility and cleaning operations take place outdoors, wash water shall drain to an SCM for treatment, or else the cleaning operations shall take place on or drain directly to grassed or graveled areas to prevent point source discharges of the wash water into the storm drains or surface waters. Where cleaning operations cannot be performed as described above and when operations are performed in the vicinity of a storm drainage collection system, the drain is to be covered with a portable drain cover during cleaning activities. Any excess standing water shall be removed and properly handled prior to removing the drain cover. Facilities that have three or fewer fire trucks and ambulances should attempt to comply with the above requirements; however, those that cannot comply with these requirements due to existing limitations shall incorporate structural measures during facility renovation to the extent practicable." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 40. Document vehicle and equipment cleaning procedures. 37 City of Greensboro Stormwater Management Plan (Draft) Permit Ref. BMP No. 41. Describe measures to 1. Identify facilities 1. Once per 1. List of facilities prevent or minimize where vehicles and permit cycle where vehicles and pollution from vehicle and equipment are equipment are equipment cleaning. cleaned. cleaned 2. Review 2. Once per 2. Report any procedures for permit cycle updates and cleaning vehicles modifications. and equipment and update as needed. II.G.2.f: Streets, roads, and public parking lots maintenance "The permittee shall implement BMPs to reduce polluted stormwater runoff from municipally - owned streets, roads, and public parking lots within the corporate limits." A B C u Don of BMP jkMeasurable Schedule for Annual Reporting oal(s) Implementation Metric Implement BMPs to reduce polluted stormwater runoff. Reduce pollution from streets, roads, and public parking lots to the MEP. For additional information on specific program responsibilities, refer to the City's most recent MS4 Operation & Maintenance Plan. 1. Sweep designated streets, roads, and parking lots. 2. Conduct seasonal loose leaf collection. 1. Ongoing, Permit Years 1-5 according to priority schedule 2. Ongoing, Permit Years 1-5 according to neighborhood pickup schedule 3. Conduct loose 3. Ongoing, as litter collection. needed 1. Tons of material collected 2. Tons of leaves collected 3. Tons of loose litter collected 4. Conduct periodic 4. Ongoing, as 4. Volume of water street flushing needed used for flushing Permit II.G.2.g: Inspection and Maintenance (I&M) for municipally -owned or maintained SCMs Ref. and the storm sewer system "The permittee shall maintain and implement an inspection and maintenance program for stormwater control measures (SCMs) owned and operated by the municipality and the municipal storm sewer system including catch basins, the conveyance system, and SCMs." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 42. Inspect and maintain City -owned SCMs and the MS4. Inspect and maintain 1. Inspect 1. Ongoing, per 1. Number of municipally -owned SCMs. municipally owned SCM specific inspections SCMs schedule completed WE: City of Greensboro Stormwater Management Plan (Draft) Pollution Prevention and Good Housekeeping 2. Provide 2. Ongoing, as 2. Number of maintenance needed inspections recommendations requiring for municipally maintenance owned SCMs 43. Inspect and maintain MS4, 1. Inspect 1. Ongoing, per 1. Number of work including catch basins and municipally owned schedule and orders initiated the conveyance system. stormwater upon reports of conveyance problems For additional information system. on specific program 2. Maintain 2. As needed 2. Number of work responsibilities, refer to the municipally owned based on orders completed City's most recent MS4 stormwater inspection Operation & Maintenance conveyance results Plan. system. Permit II.G.2.h: Staff training Ref. "Maintain and implement a training plan that indicates when, how often, and who is required to be trained and what they are to be trained on." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 44. Maintain and implement a Pollution Prevention and Good Housekeeping (PP/GH) training plan. Develop and implement 1. Train new 1. Within first 6 1. Number of new PP/GH SOP which employees on months of hire staff trained incorporates staff training PP/GH plan. 2. Train current 2. Annually, 2. Number of staff employees on Permit Years 1-5 trained PP/GH 39 City of Greensboro Stormwater Management Plan (Draft) 11.0 PROGRAM TO MONITOR AND CONTROL POLLUTANTS IN STORMWATER DISCHARGES TO MUNICIPAL SYSTEMS The City of Greensboro's MS4 permit requires that the City monitor and evaluate stormwater discharges to its MS4 system which originate from hazardous waste treatment, disposal, and recovery facilities, and qualifying industrial facilities. The City addresses this requirement through the following BMPs. Table 15: Program to Monitor and Control Pollutants BMPs ProgramPollutants in Storm Water Discharges Permit II.H.2.a: Maintain an Inventory of Industrial Facilities Ref. "Maintain an inventory of permitted hazardous waste treatment, disposal, and recovery facilities, industrial facilities that are subject to Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), and industrial facilities identified with an industrial activity permitted to discharge storm water to the permittee's MS4. For the purposes of this permit, industrial activities shall mean all permitted industrial activities as defined in 40 CFR 122.26." A B C D BMP No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 45. Maintain industrial facilities inventory. Maintain an inventory of Review and Annually, Permit Y/N facilities subject to Section maintain facility Years 1-5 313 of SARA Title III; inventory to NPDES permitted industrial ensure all facilities; and hazardous applicable facilities waste treatment, disposal, are included and recovery facilities. Permit II.H.2.b: Inspection Program Ref. "Identify priorities and inspection procedures. At a minimum, priority facilities include those identified above in subsection II.1-1.2.a." A B C D BMP No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 46. Identify priorities and procedures for industrial facilities inspection program. Identify priorities and Maintain Once per permit Y/N inspection procedures. inspection SOP, cycle review and update as needed. City of Greensboro Stormwater Management Plan (Draft) Program• Control Pollutants in Storm Water Discharges Permit II.H.2.c: Evaluate Industrial Facilities discharging stormwater to the City's MS4 Ref. "The Permittee is required to evaluate control measures implemented at permitted hazardous waste treatment, disposal, and recovery facilities, industrial facilities that are subject to Section 313 of Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA), industrial facilities identified with an industrial activity permitted to discharge storm water to the permittee's MS4, or as identified as an illicit discharge under the IDDE Program. For permitted facilities, the municipality shall establish procedures for reporting deficiencies and non-compliance to the permitting agency. Where compliance with an existing industrial stormwater permit does not result in adequate control of pollutants to the MS4, municipality will recommend and document the need for permit modifications or additions to the permit issuing authority. For the purposes of this permit, industrial activities shall mean all permitted industrial activities as defined in 40 CFR 122.26. For the purpose of this permit, the Permittee is authorized to inspect the permitted hazardous waste treatment, disposal, and recovery facilities as an authorized representative of the Director." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 47. Establish procedures for reporting evaluation of industrial facilities. Evaluate control measures Conduct Ongoing, per SOP Number of implemented at permitted inspections based inspections industrial facilities and on established conducted, establish procedures for procedures number of reporting deficiencies and documented in permitted facilities non-compliance. SOP. reported to NCDEQ 41 City of Greensboro Stormwater Management Plan (Draft) 12.0 WATER QUALITY ASSESSMENT AND MONITORING Per the City's MS4 permit, the primary objective for Water Quality Assessment and Monitoring is to "[e]valuate the impacts of MS4 discharges on surface water quality" (11.1.1). To accomplish this objective, the City implements the following BMPs. Table 16: Water Quality Assessment and Monitoring BMPs Permit 11.1.2.a: Water Quality Assessment and Monitoring Plan Ref. "Maintain a Water Quality Assessment and Monitoring Plan. The Plan shall include a schedule for implementing the proposed assessment and monitoring activities." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goals) dkL ML-48. Implementation Metric Maintain a Water Quality Assessment and Monitoring Plan. Maintain a Water Quality Review and revise Ongoing, Permit Report any Assessment and Monitoring the Water Quality Years 1-5 updates and Plan including an Assessment and modifications. implementation schedule. Monitoring Plan as i needed. Permit 11.1.2.b: Water Quality Monitoring Ref. "Maintain and implement the Water Quality Assessment and Monitoring Plan submitted to DEMLR." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 49. Implement the Water Quality Assessment and Monitoring Plan. Implement the monitoring program per the Water Quality Assessment and Monitoring Plan. Conduct water quality monitoring and data evaluation as documented in the Water Quality Assessment and Monitoring Plan. As described in the Water Quality Assessment Plan, Permit Years 1-5 Brief summary of implementation IF City of Greensboro Stormwater Management Plan (Draft) 13.0 TOTAL MAXIMUM DAILY LOADS As documented in Part II Section J of the City of Greensboro's MS4 permit, the City will determine whether the MS4 discharges to receiving waters with a TMDL and identify the pollutants of concern, utilize BMPs within the six minimum control measures and the City's TMDL Watershed Plan to meet the assigned NPDES MS4 regulated stormwater WLA, and address the WLA assigned to the City to the maximum extent practicable. The City is not expected to attain the water quality standards for the subject receiving waters. Table 17: Total Maximum Daily Loads (TMDLs) BMPs Permit II.J.2.a: Identify, describe and map watershed, outfalls, and streams Ref. "Within 12 months the permittee shall prepare a plan that: • Identifies the watershed(s) subject to an approved TMDL with an approved Waste Load Allocation (WLAs) assigned to the permittee; and • Includes a description of the watershed(s); and • Includes a map of watershed(s) showing streams & outfalls; and • Identifies the locations of currently known major outfalls within its corporate limits with the potential of contributing to the cause(s) of the impairment to the impaired segments, to their tributaries, and to segments and tributaries within the watershed contributing to the impaired segments; and • Includes a schedule (not to exceed 6 months) to discover and locate other unknown major outfalls within its corporate limits that may be contributing to the cause of the impairment to the impaired stream segments, to their tributaries, and to segments and tributaries within the watershed contributing to the impaired segments." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 50. Identify, describe, and map TMDL watersheds, outfalls, and streams. Identify, describe, and map 1. Identify, 1. Once per permit 1. Report any TMDL watersheds, outfalls, describe, and map cycle updates and and streams. TMDL watersheds. modifications. 2. Identify major 2. Ongoing, as 2. Number of outfalls that needed major outfalls contribute to within the TMDL TMDL. watershed 3. Review 3. Annually, Permit 3. Number of programs (IDDE, Years 1-5 additional major outfall mapping, outfalls identified etc.) for mapping other unknown major outfalls within the TMDL watersheds as needed. 43 City of Greensboro Stormwater Management Plan (Draft) iotannaximurn saiiy Loaas Permit II.J.2.b: Evaluate existing measures Ref. "Within 12 months the Permittee's plan: • Shall describe existing measures currently being implemented by the Permittee designed to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of concern to the MEP within the watershed to which the TMDL applies; and • Provide an explanation as to how those measures are designed to reduce the TMDL pollutant of concern. • The Permittee shall continue to implement the existing measures until notified by the Division." A B C D BMP No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 51. Evaluate existing TMDL wasteload allocation measures. Evaluate existing TMDL 1. Review and 1. Once per permit 1. List of measures wasteload allocation evaluate existing cycle measures. list of TMDL WLA measures. 2. Describe TMDL 2. Once per permit 2. Description of measures that cycle TMDL measures reduce the POC that reduce the (Pollutant of POC Concern). 3. Continue 3. Ongoing, Permit 3. Document implementation of Years 1-5 which measures TMDL WLA were implemented measures. II.J.2.c: Assessment of available monitoring data Permit Ref. "Within 24 months the permittee's plan shall include an assessment of available monitoring data. Where long-term data is available, this assessment should include an analysis of the data to show trends." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 52. Assess available monitoring data for TMDL watersheds. Assess available TMDL Review and Once per permit Brief summary monitoring data for TMDL assess available cycle report for TMDL watersheds. TMDL watershed POC monitoring data. City of Greensboro Stormwater Management Plan (Draft) Permit II.J.2.d: Monitoring Plan Ref. "Within 24 months the permittee shall develop a Monitoring Plan for the permittee's assigned NPDES regulated WLA as specified in the TMDL. The permittee shall maintain and implement the Monitoring Plan as additional outfalls are identified and as accumulating data may suggest. Following any review and comment by the Division the permittee shall incorporate any necessary changes to monitoring plan and initiate the plan within 6 months. Modifications to the monitoring plan shall be approved by the Division. Upon request, the requirement to develop a Monitoring Plan may be waived by the Division if the existing and proposed measures are determined to be adequate to achieve the MS4's NPDES WLA to MEP within the watershed to which the TMDL applies." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 53. Maintain monitoring plan for TMDL waters. Update monitoring plan for Review monitoring Once per permit Submit TMDL waters if necessary. plan for TMDL cycle modifications to waters and update NCDEQ for review as needed. Permit II.J.2.e: Additional Measures Ref. "Within 24 months the Permittee's plan shall: • Describe additional measures to be implemented by the permittee designed to achieve the permittee's MS4's NPDES WLA and to reduce the TMDL pollutant of concern to the MEP within the watershed to which the TMDL applies; and • Provide an explanation as to how those measures are designed to achieve the permittee's MS4's NPDES regulated WLA to the MEP within the watershed to which the TMDL applies." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 54. Describe and explain additional TMDL WLA measures. Describe and explain any 1. Describe any 1. Annually, Permit 1. Report any additional TMDL wasteload new TMDL WLA Years 1-5 updates and allocation measures. measures. modifications. 2. Explain how any new TMDL measures help to reduce the POC. Permit II.J.2.f: Implementation Plan Ref. "Within 48 months the Permittee's plan shall: 2. Annually, Permit 12. Report any Years 1-5 updates and modifications. • Describe the measures to be implemented within the remainder of the permit term designed to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of concern to the MEP; and • Identify a schedule, subject to Division approval, for completing the activities. • Implement the permittee's TMDL plan." 45 City of Greensboro Stormwater Management Plan (Draft) Total Maximum Daily Loads BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 55. Implement TMDL watershed plan. Implement TMDL watershed Review and Once per permit Report any plan evaluate TMDL cycle updates and watershed plan. modifications. Permit II.J.2.g: Incremental Success Ref. "The permittee's plan must outline ways to track progress and report successes designed to achieve the MS4's NPDES regulated WLA and to reduce the TMDL pollutant of concern to MEP within the watershed to which the TMDL applies." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 56. Document incremental success in reducing POC. Document ways to track Track progress Once per permit Brief summary progress that achieves and report cycle report for TMDL incremental successes in successes POC reducing the POC. designed to reduce POC. II.J.2.h: Reporting Permit Ref. "The permittee shall conduct and submit to the Division an annual assessment of the program designed to achieve the MS4's NPDES WLA and to reduce the TMDL pollutant of concern to the MEP within the watershed to which the TMDL applies. Any monitoring data and information generated from the previous year are to be submitted with each annual report." BMP A B C D No. Description of BMP Measurable Schedule for Annual Reporting Goal(s) Implementation Metric 57. Submit annual TMDL assessment report. Annual TMDL assessment Annual Annually, Permit Brief summary report. assessment and Years 1-5 report for TMDL update of TMDL POC report. we City of Greensboro Stormwater Management Plan (Draft) 14.0 PROGRAM ASSESSMENT, REPORTING, AND RECORDKEEPING 14.1 Program Assessment As required in Part III of the MS4 permit, the City will document implementation of this SWMP. Components of documentation may include inspections, maintenance activities, educational programs, monitoring and sampling, implementation of BMPs, enforcement actions, and other stormwater activities. Documentation will be kept on file for at least five years and made available to NCDEQ upon request. The SWMP will be reviewed on an annual basis and updated if necessary. Responsible divisions and/or departments for each permit element will report to the Water Quality Section Supervisor during the annual review if updates are required to program processes, goals, or metrics. The Water Quality Section Supervisor will be responsible for incorporating these program changes into the SWMP. The City will submit an annual report of the SWMP evaluation and monitoring information to NCDEQ as described below. 14.2 Reporting and Recordkeeping As required in Part IV.A of the MS4 permit, the City will retain records of monitoring information, including all calibration and maintenance records, and copies of reports required by the permit for at least five years from the date of the sample, measurement, report, or application. As required in Part IV.B of the MS4 permit, the City will submit an annual report to NCDEQ that tracks progress in implementing the SWMP. The annual report will include the following sections: • Description of the status of implementation of the SWMP, including the development and implementation of each major component of the SWMP for the past year • Description and justification of any proposed changes to the SWMP • Necessary changes to programs or practices for assessment of management measures implemented through the SWMP • Summary of data accumulated as part of the SWMP with an assessment of what the data indicates • Assessment of compliance with the permit, information on the establishment of appropriate legal authorities, inspections, and enforcement actions • Discussion of program funding 47