HomeMy WebLinkAboutNCS000436_Draft SWMP_20231019 Draft Stormwater Management Plan
City of Thomasville
NCS000436
October 19, 2023
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Table of Contents
PART1: INTRODUCTION........................................................................................................................ 1
PART 2: CERTIFICATION........................................................................................................................2
PART3: MS4 INFORMATION..................................................................................................................3
3.1 Permitted MS4 Area .....................................................................................................................3
3.2 Existing MS4 Mapping.................................................................................................................3
3.3 Receiving Waters..........................................................................................................................4
3.4 MS4 Interconnection.....................................................................................................................4
3.5 Total Maximum Daily Loads (TMDLs) .......................................................................................5
3.6 Endangered and Threatened Species and Critical Habitat............................................................5
3.7 Industrial Facility Discharges.......................................................................................................5
3.8 Non-Stormwater Discharges.........................................................................................................6
3.9 Target Pollutants and Sources.......................................................................................................7
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION.....................................8
4.1 Organizational Structure...............................................................................................................8
4.2 Program Funding and Budget..................................................................................................... 11
4.3 Shared Responsibility/Contracted Services................................................................................ 11
4.4 Co-Permittees.............................................................................................................................. 11
4.5 Measurable Goals for Program Administration.......................................................................... 11
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM......................................................... 14
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM........................................... 17
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM.............................. 18
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM .......................................19
PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM........................................22
PART 10: POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS................27
List of Tables
Table 1: Summary of MS4 Mapping
Table 2: Summary of MS4 Receiving Waters
Table 3: Summary of Approved TMDLs
Table 4: Summary of Federally Listed Species/Habitat Impacted by Surface Water Quality
Table 5: NPDES Stormwater Permitted Industrial Facilities
Table 6: Non-Stormwater Discharges
Table 7: Summary of Target Pollutants and Sources
Table 8: Summary of Responsible Parties
Table 9: Shared Responsibilities (N/A)
Table 10: Co-Permittee Contact Information (N/A)
Table 11: Program Administration BMPs
Table 12: Summary of Target Pollutants &Audiences
Table 13: Public Education and Outreach BMPs
Table 14: Public Involvement and Participation BMPs
Table 15: Illicit Discharge Detection and Elimination BMPs
Table 16: Qualifying Alternative Program Components for Construction Site Runoff Control Program
(N/A)
Table 17: Construction Site Runoff Control BMPs
Table 18: Qualifying Alternative Program(s) for Post-Construction Site Runoff Control Program (N/A)
Table 19: Summary of Existing Post-Construction Program Elements (N/A)
Table 20: Post Construction Site Runoff Control BMPs
Table 21: Pollution Prevention and Good Housekeeping BMPs
PART 1: INTRODUCTION
The purpose of this Stormwater Management Plan(SWMP)is to establish and define the means by which
the City of Thomasville 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 SWMP identifies the specific elements and minimum measures that the City of Thomasville will
develop, implement, enforce, evaluate and report to the North Carolina Department of Environmental
Quality(NCDEQ)Division of Energy,Minerals and Land Resources(DEMLR) in order to comply with
the MS4 Permit number NCS000436 as issued by NCDEQ. This permit covers activities associated with
the discharge of stormwater from the MS4 as owned and operated by the City of Thomasville and located
within the corporate limits of the City of Thomasville.
In preparing this current SWMP,the City of Thomasville has evaluated its MS4,the permit requirements
of it's MS4, and previous Comprehensive Stormwater Management Plans 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
annually to ensure that the elements and minimum measures it contains continue to adequately provide
for permit compliance and the community's needs.
Once the SWMP is approved by NCDEQ, all provisions contained and referenced in this SWMP, along
with any approved modifications of the SWMP, are incorporated by reference into the permit and become
enforceable parts of the permit. Any major changes to the approved SWMP will require resubmittal,
review and approval by NCDEQ, and may require a new public comment period depending on the nature
of the changes.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 1
PART 2: 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.
❑ I am a ranking elected official.
® 1 am a principal executive officer for the permitted MS4.
❑ I am a duly authorized representative for the permitted MS4 and have attached the authorization made
in writing by a principal executive officer or ranking elected official which specifies me as(check one):
❑ A specific individual having overall responsibility for stormwater matters.
❑ A specific position having overall responsibility for stormwater matters.
Signature: DRAFT—NOT SIGNED
Print Michael Brandt
Name:
Title: City Manager
Signed this day October of 2023
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 2
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Table 1: Summary of Current MS4 Mapping
Percent of MS4 Area 100 %
Mapped**
No. of Major Outfalls* Mapped 22 total
*An outfall is a point where the MS4 discharges from a pipe or other conveyance (e.g. a ditch)directly
into surface waters. Major outfalls are required to be mapped to meet permit requirements. A major
outfall is a 36-inch diameter pipe or discharge from a drainage area> 50-acres; and for industrial zoned
areas a 12-inch diameter pipe or a drainage area> 2-acres.
** Thomasville's entire stormwater system is mapped currently but due to rapid growth this is an
ongoing task
3.3 Receiving Waters
The City of Thomasville MS4 drains into several impaired waters which in turn drain into the Rich Fork
Creek and Hamby Creek Watersheds in the Yadkin River Basin. The Rich Fork Creek and Hamby Creek
Watersheds have an active TMDL for Fecal Coliform. The city receiving waters as listed in Table 2
below. Applicable water quality standards listed below are compiled from the following NCDEQ
sources:
o Waterbody Classification Map
o Impaired Waters and TMDL Map
o Most recent NCDEQ Final 303(d)List
Table 2: Summary of MS4 Receiving Waters
Receiving Water Name Stream Index Water 303(d)Listed Parameter(s)
/AU Number Quality of Interest
Classification
Hamby Creek 12-119-7-4a C Fecal Coliform
Hanks Branch 12-119-7-3-1 C N/A
Hunts Fork 12-119-7-3 C Benthic
Jimmys Creek 12-119-7-4-2 C N/A
Kennedy Mill Creek 12-119-7-2 C N/A
North Hamby Creek 12-119-7-4-1 C Benthic
3.4 MS4 Interconnection
The City of Thomasville's MS4 is interconnected with the NCDOT MS4 within NCDOT owned right of
ways.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 4
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.
Table 3: Summary of Approved TMDLs
Water Body Name TMDL Pollutant(s) of Concern Stormwater Water
Waste Quality
Load Recovery
Allocation Program
Y/N Y/N
Hamby Creek Fecal Coliform N N
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 regulated MS4 urbanized area. 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,the species listed in
Table 4 have the potential to occur within the regulated MS4 urbanized area. Of those species listed,
Table 4 summarizes the species that may be significantly impacted by the quality of surface waters within
their habitat.
Table 4: Potential Federally Listed Species/Habitat Impacted by Surface Water Quality
Scientific Name Common name Species Group Federal Listing
Status
Helianthus schweinitzii Schweinitz's Endangered
Sunflower
Plantago cordata Heart-leaf Endangered
Plantain
Pseudognaphalium helleri Heller's Rabbit- Endangered
Tobacco
Perim otis subflavus Tricolored Bat Endangered
Rhus michauxii Michaux's sumac Endangered
3.7 Industrial Facility Discharges
The City of Thomasville MS4 jurisdictional area includes the following industrial facilities which hold
NPDES Industrial Stormwater Permits, as determined from the NCDEQ Maps&Permit Data web page.
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City of Thomasville Page 5
Table 5: NPDES Stormwater Permitted Industrial Facilities
Permit Number Facility Name
NCGI 100194 City of Thomasville—Small MS4
3.8 Non-Stormwater Discharges
The water quality impacts of non-stormwater discharges have been evaluated by the City of Thomasville
as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not
significantly impact water quality. The City of Thomasville has evaluated residential and charity car
washing and street washing for possible significant water quality impacts.
Street washing discharges are addressed under the Pavement 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 Thomasville.
Wash water 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 Thomasville to determine whether they may
significantly impact water quality. Currently runoff from car washing in The City of Thomasville
would be considered incidental.
Table 6: Non-Stormwater Discharges
Non-Stormwater Discharge Water Quality Impacts
Water line and fire hydrant flushing Incidental
Landscape irrigation Incidental
Diverted stream flows Incidental
Rising groundwater Incidental
Uncontaminated groundwater infiltration Incidental
Uncontaminated pumped groundwater Incidental
Uncontaminated potable water sources Incidental
Foundation drains Incidental
Air conditioning condensate Incidental
Irrigation waters Incidental
Springs Incidental
Water from crawls ace pumps Incidental
Footing drains Incidental
Lawn watering Incidental
Residential and charity car washing Possible
Flows from riparian habitats and wetlands Incidental
Dechlorinated swimming pool discharges Incidental
Street wash water Possible
Flows from firefighting activities Incidental
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 6
3.9 Target Pollutants and Sources
In addition to those target pollutants identified below,the City of Thomasville is not aware of other
significant water quality issues within the permitted MS4 area.
The education program will target total suspended solids and nutrient loading because turbidity,
sedimentation, and nutrients are the pollutants of concern in downstream waters. In addition, floatables,
trash,and debris will also be targeted. The education program will also address the proper use and disposal
of typical household chemicals,garden chemicals, and used motor oil.
Table 7 below summarizes the water quality pollutants identified throughout Part 3 of this SWMP,the
likely activities/sources/targeted audiences attributed to each pollutant and identifies the associated
SWMP program(s)that address each. In addition,the City of Thomasville has evaluated schools,
homeowners and businesses as target audiences that are likely to have significant stormwater impacts.
Table 7: Summary of Target Pollutants and Sources
Target Pollutant(s) Likely Source(s)/Target Audience(s) SWMP Program Addressing
Target Pollutant s /Audience s
Litter Residents, Businesses, Schools Public Education&Outreach
Sediment Residents, Businesses Public Education&Outreach
Nitrogen and Phosphorous Fertilizer/Residents Public Education&Outreach
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City of Thomasville Page 7
PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION
4.1 Organizational Structure
City of Thomasville
Organizational Chat
City Council
City Attorney Boards and Commissions
City Attorney _F
City Manager
Finance Director
Fire Chief Police Chief
City Clerk Planning Director
Recreation Director Public Services Director
HR Director City Engineer
Signing Official:City Manager—Michael Brandt
Duly Authorized Representative: NA
Table 8: Summary of Responsible Parties
Position Name Phone No. Fax No. Email
City Manager Michael Brandt 336-475-5599 michael.brandt(aThomasville-
nc.ora
City Clerk Wendy Martin 336-475-4214 wendy.martin@Thomasville-
nc.gov
Public Works Daryl Poole 336-475-4239 Daryl.poole(c)Thomasville-
Director nc.Qov
City Planner Chuck George 336-475-4255 Chuck.George(a)Thomasvil le-
nc.net
City Attorney Misti Whitman 336-476-3158
Stormwater Josh Johnson, P.E. (336)226-5534 joshCoDawck.com
Engineer
Stormwater Janet Paith (336)226-5534 Jpaith(aawck.com
Coordinator
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City of Thomasville Page 8
General contacts for stormwater should be referred to Daryl Poole and Josh Johnson.
Designated Stormwater Administrator—Josh Johnson, P.E.—Contracted.
SWMP Component Responsible Position Staff Name Department
Stormwater Program City Manager See Table 8 Administration
Administration Stormwater Engineer
SWMP Management Public Works Director See Table 8 Administration
Stormwater Engineer
Public Education& Public Works Director See Table 8 Administration
Outreach Stormwater Coordinator
Public Involvement& Public Works Director See Table 8 Administration
Participation Stormwater Coordinator
Illicit Discharge Public Works Director See Table 8 Administration
Detection& Stormwater Engineer
Elimination
Construction Site Planner See Table 8 Administration
Runoff Control Stormwater Engineer
Post-Construction Planner See Table 8 Administration
Stormwater Stormwater Manager
Management
Pollution Stormwater Engineer See Table 8 Administration
Prevention/Good Public Works Director Public Works
Housekeeping for
Municipal Operations
Municipal Facilities Stormwater Engineer See Table 8 Administration
Operation& Public Works Director Public Works
Maintenance Program
Spill Response Program Stormwater Engineer See Table 8 Administration
Public Works Director Public Works
MS4 Operation& Stormwater Engineer See Table 8 Administration
Maintenance Program Public Works Director Public Works
Municipal SCM Stormwater Engineer See Table 8 Administration
Operation& Public Works Director Public Works
Maintenance Program
Pesticide,Herbicide& Stormwater Engineer See Table 8 Administration
Fertilizer Management Public Works Director Public Works
Program
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Vehicle&Equipment Stormwater Engineer See Table 8 Administration
Cleaning Program Public Works Director Public Works
Pavement Management Stormwater Engineer See Table 8 Administration
Program Public Works Director Public Works
Total Maximum Daily Planner
Load(TMDL) Stormwater Engineer
Requirements Public Works Director
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 10
4.2 Program Funding and Budget
In accordance with the issued permit,the City of Thomasville 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 of Thomasville funds it's Stormwater Programs through a Stormwater Fee. The City collects a
flat fee of$1.00/month from all utility users. The City uses this fee to pay for its Water Quality Programs
including its NPDES Phase II and Inflow/Infiltration/Exfiltration Program and/or studies. The City's
Stormwater Budget for the 2021 -22 Fiscal Year was $114,627 and the City plans to use accrued
stormwater balance for future stormwater specific projects. This includes investigating drainage
complaints from residents.
4.3 Shared Responsibility/Contracted Services
The City of Thomasville implements 5 of the 6 minimum control measures,with the 6th measure being
construction site runoff controls which is implemented through NC DEMLR's Erosion and Sediment
Control program.
The City of Thomasville contracts with Stormwater Smart for assistance with Public Education and
Public Involvement and Outreach. Stormwater Smart is not directly responsible for any items but rather
assists the City of Thomasville.
The City of Thomasville contracts engineering services with Alley,Williams, Carmen, and King,Inc.
Alley,Williams, Carmen, and King is not directly responsible for any items but rather assists the City of
Thomasville.
4.4 Co-Permittees
The are no other entities applying for co-permittee status under the NPDES MS4 permit number
NCS000436 for the City of Thomasville. Table 10 summarizes contact information for each co-
permittee.
4.5 Measurable Goals for Program Administration
The City of Thomasville will manage and report the following Best Management Practices(BMPs) for
the administration of the Stormwater Management Program.
DRAFT NCS000436 SWMP October 19,2023
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Table 11: Program Administration BMPs
Permit 1.6: Permit Renewal Application
Ref. Measures to submit a permit renewal application no later than 180 days prior to the expiration date of the
NPDES MS4 permit.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
1. Permit Renewal Application
Submit a permit renewal application 1.Draft SWMP 1.Permit Year 5 1.Yes/No
and Draft SWMP no later than 180 applicable to the
prior to permit expiration proceeding 5 years
following permit re-
issuance.
2. Certify the stormwater 2.Permit Year 5 2.Date of permit renewal
permit renewal application submittal
application(Permit
renewal application form
and Draft SWMP for the
next 5-year permit cycle)
and submit to NCDEQ at
least 180 days prior to
permit expiration.
Permit 2.1.1 Review Adequate Funding and Staffing
Ref. Review adequate funding and staffing to implement and manage the provisions of the SWMP and meet the
re uirements of the permit.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
2. Review Adequate Funding and Staffing needs.
Confirm that the program is 1.Verify adequate
adequately funded and staffed. funding in the City's 1.Permit Year 1-5 1.Adequate/Inadequate
Budget
Permit 2.1.2 Program Implementation
Ref. Measures to evaluate the performance and effectiveness of the SWMP program components at least
annually.Results shall be used by the permittee to modify the program components as necessary to
accomplish the intent of the Stormwater Program.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
3. Annual Self-Assessment
Evaluate the performance and
effectiveness of the program 1.Prepare,conduct and
components at least annually.Results document an annual 1.Annually
shall be used to modify the program evaluation of the Permit Years 1—5 1.Yes/No
components as necessary to program components.
accomplish the intent of the
Stormwater Program.
DRAFT NCS000436 SWMP October 19,2023
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Table 11: Program Administration BMPs
Permit 2.2 Minimum Control Measures
Ref. Maintain written procedures for implementing the six minimum control measures(MCM's),which identify
s ecific action steps, schedules,resources and responsibilities for implementing the MCM's.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
4. Procedures for implementing the Minimum Control Measures(MCM's)
1. Create all requires 1.Permit Year 1 1.Yes/No
written procedures for
implementing the six
MCM's
2.Review and update all 2.Permit Year 2-5 1.Yes/No
written procedures as
needed.
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City of Thomasville Page 13
PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM
The City of Thomasville will implement a Public Education and Outreach Program to distribute
educational materials to the community or conduct equivalent outreach activities about the impacts of
storm water discharges on water bodies and steps the public can take to reduce pollutants in storm water
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 12 below. In addition,the City of
Thomasville is required to inform businesses and the general public of the hazards associated with illicit
discharges, illegal dumping and improper disposal of waste.
Table 12: Summary of Target Pollutants &Audiences
Target Pollutants/Sources Target Audience(s)
Litter Residents,Businesses, Schools
Sediment Residents,Businesses
Nitrogen and Phosphorous Fertilizer/Residents
The City of Thomasville will manage, implement, and report on the following public education and
outreach BMPs.
The City partners with Stormwater SMART, an education and outreach organization hosted by the
Piedmont Triad Regional Council(PTRC). Stormwater SMART is a cooperative group that is funded by
several Piedmont municipalities. It was created in 2005 to provide education and outreach for MS4
Permittees(like Mebane) and concentrates on direct education of school children and residents.
Piedmont Triad Regional Council
Stormwater Smart
Danica Heflin
1398 Carrollton Crossing Drive, Kernersville, NC 27284
(336) 904-0300
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Table 13: Public Education and Outreach BMPs
Permit 3.2.2 and 3.2.4: Outreach to Targeted Audiences
Ref. Measures to identify the specific elements and implementation of a Public Education and Outreach Program to
share educational materials to the community or conduct equivalent outreach activities about the impacts of
stormwater discharges on water bodies and how the public can reduce pollutants in stormwater runoff. The
permittee shall provide educational information to identified target audiences on pollutants/sources identified in
table 12 above; and shall document the extent of exposure of each media, event or activity, including those
elements implemented locally or throu h a cooperative agree ent.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
5. Maintain a Stormwater education plan
Maintain education plan. Include in 1.Maintain Public 1.Annually 1.Yes/No
Plan the BMPs,schedule,targeted Education and Permit Years 1-5
audiences,and measurable goals. Engagement
Summarize plan and implementation Plan,documenting the
progress in each annual report existing outreach and
education program
implemented by City
staff,including process
for identifying target
audiences for each
pollutant and source.
6. Educational Stormwater Mailers,Brochures,and Posters
Distribute Public Education Materials 1.Distribute public 1.Annually 1.Report number of
to identified user groups.Materials education materials,at Permit Years 1-5 educational
may be supplied through outside public events,schools,in materials distributed.
Stormwater information sources. mailings and upon
request.
Permit 2.1.7,3.2.3 and 3.6.5(c): Web Site
Ref. Measures to provide a web site designed to convey the program's message(s) and provide online materials
including 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
and SWMP. The web page shall also provide developers with all relevant post-construction requirements,
design standards, checklists and/or other materials.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
7. City's Stormwater Webpage
Update and maintain the City's 1.Verify City's 1.Annually 1 Yes,No,Partial
Stormwater Webpage. stormwater webpage is Permit Years 1-5
current.
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City of Thomasville Page 15
Permit 3.2.5: Stormwater Hotline
Ref. Measures for a stormwater hotline/helpline for the purpose of public education and outreach.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
8. Helpline/Hotline
All stormwater related calls will be 1.Maintain Hotline 1. Continuously 1.Total annual number
forwarded to the Public Works Permit Years 1-5 of calls
Director who will then distribute the
information to appropriate
em to ees.
9. Festivals,Local Fairs and Events
Participate in local festivals annually 1.Distribute education 1.Annually 1.Report number of
by providing a stormwater information and interact Permit Years 1-5 Events and individuals
information booth starting.Provide with the public. contacted.
bilingual messages on the importance
of clean water and on specific
activities that can be carried out to
help keep stormwater clean.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 16
PART 6: PUBLIC INVOLVEMENT AND PARTICIPATION PROGRAM
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 Thomasville will manage,implement and report the following public involvement and
participation BMPs.
Table 14: Public Involvement and Participation BMPs
Permit 3.3.1: Public Input
Ref. Mechanisms for public involvement that provide for input on stormwater issues and the stormwater program.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
10. Public Stormwater Program Meeting
A public meeting will be held 1.Hold a public meeting 1.Permit Years 2 and 4 1.Date of Event
Bi-annually to discuss the to solicit information
implementation of the permit. This about the City's
meeting will provide the public with Stormwater Program
the opportunity to be involved with
the stormwater program.
Permit 3.3.2: Volunteer Opportunities
Ref. Measures to provide volunteer opportunities designed to promote ongoing citizen participation.
A B C D
BMP Description of BMP Measurable Goal(s) Schedule for Annual Reporting
No. Implementation Metric
11. Volunteer Stormwater Program
The City will promote various 1.Hold one event per 1.17all and Spring 1.Number of Events
volunteer stormwater programs year in the community. Permit Years 1-5
annually.These may include Big
Sweep,Adopt-A-Stream programs,
and Storm Drain Stenciling.
12. Helpline/Hotline
All stormwater related calls will be 1.Maintain the 1.Annually 1.Yes/No
forwarded to the Public Works stormwater
Director who will then distribute the administration helpline
information to appropriate to receive public
employees. complaints.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 17
PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM
The City of Thomasville will develop,manage,implement, document,report and enforce an Illicit
Discharge Detection and Elimination Program which shall, at a minimum, include the following illicit
discharge detection and elimination BMPs.
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit 3.4.1: MS4 Map
Ref. Measures to develop,update and maintain a municipal storm sewer system map including stormwater
conveyances, flow direction,major outfalls and waters of the United States receiving stormwater discharges.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
13. Storm sewer system map showing outfalls and the receiving body of water.
Maintain system map in support of 1.Maintain mapping as 1.Continuously,with 1.Yes/No
inspection program. The map will System changes. updates made annually.
note outfalls and receiving body of
water for each outfall.
Permit 3.4.2: Regulatory Mechanism
Ref. Measures to provide an IDDE ordinance or other regulatory mechanism that provides legal authority to
prohibit,detect, and eliminate illicit connections and discharges, illegal dumping and spills into the MS4,
includin enforcement procedures and actions.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
14. Review Illicit Discharge Ordinance
Maintain adequate ordinance or other 1.Maintain and enforce 1.Biannually 1.Yes/No
legal authorities to public ordinances. Permit Years 2&4
prohibit illicit connections and Update,if necessary,to
discharges and enforce the maintain legal
approved IDDE program. authority.
Permit 3.4.3: IDDE Plan
Ref. Measures to maintain and implement a written IDDE Plan to detect and address illicit discharges,illegal
dumping and any non-stormwater discharges identified as significant contributors of pollutants to the MS4.
The plan shall provide standard procedures and documentation to:
a) Locate priority areas likely to have illicit discharges,
b) Conduct routine dry weather outfall inspections,
c) Identify illicit discharges and trace sources,
d) Eliminate the source(s) of an illicit discharge, and
e) Evaluate and assess the IDDE Program.
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Table 15: Illicit Discharge Detection and Elimination BMPs
A B C D
BMP
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
15. Inspection/detection program to detect dry weather flows at MS4 outfalls.
Maintain written procedures and/or 1.Maintain IDDE Plan. 1.Annually 1.Yes/No
SOPS for detecting and tracing the Review and update Permit Years 1-5
sources of illicit discharges and for IDDE Plan as needed.
removing the sources or reporting the
sources to the State to be properly
permitted.
16. Stream walks/Dry weather testing 1.Inspect 20%outfalls 1.Annually 1.Number of outfalls
and Outfall Inspections Permit Years 1-5 inspected for year
Permit 3.4.4: IDDE Tracking
Ref. Measures for tracking and documenting the date(s) an illicit discharge, illicit connection or illegal dumping
was observed,the results of the investigation, any follow-up of the investigation,the date the investigation was
closed,the issuance of enforcement actions, and the ability to identify chronic violators.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
17. Establish/Maintain a tracking system for managing reported problem areas.
Document the date of investigations, 1.Maintain IDDE 1.Continuously 1.Number of IDDE
any enforcement action(s)or investigation records, Investigations for year
remediation that occurred notices of
violations and
compliance and other
program records.
Permit 3.4.5: Staff IDDE Training
Ref. Measures to provide training for municipal staff and contractors who, as part of their normal job
responsibilities,may observe an illicit discharge, illicit connection, illegal dumping or spills. Training shall
include how to identify and report illicit discharges, illicit connections, illegal dumping and spills. Each staff
trainingevent shall be documented, including the a enda/materials, date, and number of staff participating.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
18. Train employees on how to inspect for illicit connections
Conduct in person or virtual training 1.Conduct employee 1.Annually 1.Report number of
for appropriate municipal staff on training and document Permit Years 1-5 staff who completed
detecting and reporting illicit attendance. IDDE training.
connections and discharges.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 19
Table 15: Illicit Discharge Detection and Elimination BMPs
Permit 3.4.6: IDDE Reporting
Ref. Measures for the public and staff to report illicit discharges, illegal dumping and spills. The mechanism shall
be publicized to facilitate reporting and shall be managed to provide rapid response by appropriately trained
personnel.
A B C D
BMP
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
19. Maintain Program to report discharges to personnel and the public
Maintain and publicize reporting 1. Maintain reporting 1.Annually 1.Yes/No
mechanism(s)for the helpline and email Permit Years 1-5
public to report illicit connections address.
and discharges
PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
In accordance with 15A NCAC 02H .0153,the City of Thomasville relies upon the North Carolina
Sedimentation Pollution Control Act(SPCA)of 1973 as a qualifying alternative program to meet a
portion of the NPDES MS4 Permit requirements for construction site runoff control measures. 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 contact information for the responsible party for Construction Site Runoff Controls within the
City of Thomasville is:
NC Sedimentation and Erosion Control Program
Winston-Salem Regional Office
Tamera Eplin,P.E.Regional Environmental Engineer
450 west Hanes Mill Rd., Suite 300,
Winston Salem,NC 27105-7407
Phone: 336/776-9800
www.deg.nc.2ov
The City of Thomasville implements minimal BMP's regarding NC Sedimentation and Erosion Control
due to lack of legal authority. All calls regarding erosion control are to be referred to NC DEQ as noted
above.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 20
Table 17: Construction Site Runoff Control BMPs
Permit 3.5.6: Public Input
Ref. Measures to provide and promote a means for the public to notify the appropriate authorities of observed
erosion and sedimentation problems.
A B C D
BMP
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
20. Municipal Staff Training
Train municipal staff who receive 1. Train municipal staff
calls from the public on the protocols 1.Annually 1.Number of staff
for referral and tracking of on proper handling of Permit Years 1-5 trained.
construction site runoff control construction site runoff
complaints. control complaints.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 21
PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM
The City of Thomasville operates a Post Construction Site Runoff Control Program that regulates
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 Thomasville and discharge into the MS4. These elements are
designed to minimize water quality impacts utilizing a combination of structural Stormwater Control
Measures(SCMs)and/or non-structural BMPs appropriate for the community and ensure adequate long-
term operation and maintenance of SCMs.
The City also operates a high-density water supply watershed program that is handled similarly to its Post
Construction runoff program but which includes reduced triggers and more stringent regulations.
The City's post construction ordinance is contained in Section 87-1 of its Code of Ordinances. The City
maintains a stormwater design manual that is deemed equal or more stringent than the NC DEQ BMP
Manual.
The annual reporting metrics for the post construction program are provided in Table 20: Post
Construction Site Runoff Control BMPs below.
Table 20: Post Construction Site Runoff Control BMPs
Permit 3.6.5(a),3.6.5(b), and 4.1.3: Minimum Post-Construction Reporting Requirements
Ref. Measures to document activities over the course of the fiscal year(July 1 —June 30)including appropriate
information to accurately describe ro ress, status, and results.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
21. Standard Reporting
Implement standardized tracking, 1. Track number of low 1. Continuously 1.Number of plan
documentation,inspections and density and high density Permit Years 1-5 reviews performed for
reporting mechanisms to compile plan reviews performed. low density and high
appropriate data for the annual self- density.
assessment process. Data shall be 2. Track number of low 2. Continuously 2.Number of plan
provided for each Post-Construction/ density and high density Permit Years 1-5 approvals issued for low
Qualifying Alternative Program I plans approved. I density and high density.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 22
Table 20: Post Construction Site Runoff Control BMPs
being implemented as listed in Tables 3.Maintain a current 3. Continuously 3. Summary of number
18 and 19. inventory of low density Permit Years 1-5 and type of SCMs added
projects and constructed to the inventory;and
SCMs including SCM number of low density
type or low density projects constructed.
location and last
—inspection date.
4. Track number of SCM 4. Continuously 4.Number of SCM
inspections performed. Permit Years 1-5 inspections.
5.Track number and 5. Continuously 5.Number of
type of enforcement Permit Years 1-5 enforcement actions
actions taken. issued.
Permit 3.6.2: Legal Authority
Ref. Measures to maintain adequate legal authorities through ordinance or other regulatory mechanism to: (a)review
designs and proposals for new development and redevelopment to determine whether adequate stormwater
control measures will be installed, implemented, and maintained, (b)request information such as stormwater
plans,inspection reports,monitoring results, and other information deemed necessary to evaluate compliance
with the Post-Construction Stormwater Management Program, and(c)enter private property for the purpose of
inspecting at reasonable times any facilities, equipment,practices, or operations related to stormwater
discharges to determine whether there is compliance with the Post-Construction Stormwater Management
Program.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
22. Review the Post Construction Ordinance
Review the Post Construction 1.Add additional 1.Annually 1.Report any ordinance
Ordinance for compliance with NC Measures as needed Permit Years 1-5 revisions added annually.
DWQ guidance and local
effectiveness.Phase II Post-
Construction Ordinance will
incorporate Jordan Lake Nutrient
Strategy Regulations in conjunction
with NC Session Law and DWQ
regulations.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 23
Table 20: Post Construction Site Runoff Control BMPs
Permit 3.6.3: Plan Review and Approval
Ref. Measures to maintain plan review and approval authority, standards and procedures to: (a)Require Federal,
State, and local government projects to comply with Post-Construction Program requirements throughout the
entire MS4 permitted area,unless the entity is subject to its own NPDES MS4 permit or a qualifying alternative
program, (b)Conduct site plan reviews of all new development and redeveloped sites that disturb greater than
or equal to one acre, and sites that disturb less than one acre that are part of a larger common plan of
development or sale for compliance with 15A NCAC 02H .1017 and the qualifying alternative programs that
apply within your jurisdiction, (c)Ensure that each project has an Operation and Maintenance Agreement that
complies with 15A NCAC 02H .1050(12), (d)Ensure that each project has an Operation and Maintenance Plan
that complies with 15A NCAC 02H .1050(13),(e)Ensure that each project has recorded deed restrictions and
protective covenants,that require the project to be maintained consistent with approved plans, and(f)Ensure
that each SCM and associated maintenance accesses be protected in a permanent recorded easement per 15A
NCAC 02H 1050 9 and(10).
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
23. Review standards and policies that ensure structural BMPs continue to be in conformance with the state's
Stormwater Management Design Manual
Review local standards to remain in 1.Add additional 1.Annually 1.Report any BMP
compliance with the NC DWQ BMP Measures as needed Permit Years 1-5 manual measures added
Manual.Additional measures and annually.
techniques may be added to the local
ordinance as they are investigated.
24. Review maintenance standards and inspection program to ensure that on-site controls continue to function as
designed.
Review the maintenance standards 1.Add additional 1.Annually 1.Report the number of
and inspection program for local on- Measures as needed Permit Years 1-5 inspections annually
site controls.
25. Maintain the education program created for land developers and the public.
Provide educational materials and 1.Maintain stormwater 1. Continuous 1.Report changes to the
training for developers. permitting guidance Permit Years 1-5 permitting guidance
document for developers document made
and designers. annually.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 24
Table 20: Post Construction Site Runoff Control BMPs
Permit 3.6.4: Inspections and Enforcement
Ref. Measures to maintain inspection and enforcement authority, standards and procedures to: (a) Conduct post-
construction inspections prior to issuing a Certificate of Occupancy or a Temporary Certificate of Occupancy.
Alternatively,the project owner may provide a surety bond to guarantee compliance with the approved plan(s),
(b)Ensure that the project has been constructed in accordance with the approved plan(s), (c)Ensure annual
inspection of each permitted SCM to ensure compliance with the approved Operation and Maintenance
Agreement, (d)Ensure inspection of low-density projects at least once during the permit term, and(e)Require
that inspections be conducted by a qualified professional.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
26. Inspections and long-term maintenance of Stormwater Control Measures (SCMs)
Maintain an inspection and 1.Maintain and receive 1.Annually 1.Report number of sites
maintenance plan for SCM's.Annual SCM inspection reports Permit Years 1-5 with SCMs
SCM Inspections performed by a and follow up on the
qualified professional. SCM functioning status of Report number of sites
maintenance and inspections will be SCM's where SCM inspections
reviewed by the City during the have been received.
permit cycle.
Report SCM
enforcement activities
27. Operation and Maintenance Plan
Require submittal of operation and 1.Require submittal of 1. Continuously 1.Report number of sites
maintenance plan(s)prior to operation and Permit Years 1-5 with newly approved
certificate of occupancy and maintenance plan(s) operation and
maintain records of each plan. prior to certificate of maintenance plan(s).
occupancy and
maintain records of each
plan.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 25
Permit 3.6.6: Fecal Coliform Reduction
Ref. Measures to control,to the maximum extent practicable, sources of fecal coliform per 15A NCAC 02H
.1017(7). At a minimum,the program shall include: (a)A pet waste management component,which may be
achieved by revising an existing litter ordinance, and(b)An on-site domestic wastewater treatment system
component, if applicable,which may be coordinated with local county health department,to ensure proper
operation and maintenance of such systems.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
28. Pet Waste Stations at Parks
Provide Pet waste stations at City 1.Maintain Pet Waste 1. Continuously 1.Report the number of
owned parks as needed Stations in City owned Permit Years 1-5 Waste stations the City
arks maintains.
29. Coordinate with the county health department on fecal coliform contamination caused by onsite
wastewater treatments stems.
Coordinate with the county health 1. Contact County Health 1.Annually 1.Report the number of
department on a program to minimize Department to inquire Permit Years 1-5 failed systems connected
the potential for fecal coliform about failing systems to the City's wastewater
contamination by ensuring proper system.
operation and maintenance of on-site
wastewater treatments stems.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 26
PART 10:POLLUTION PREVENTION AND GOOD HOUSEKEEPING PROGRAMS
This SWMP provides a comprehensive pollution prevention and good housekeeping strategy for the City
of Thomasville municipal facilities and operations. Pollution prevention and good housekeeping is
accomplished through the implementation of seven required programs,which collectively 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.
Pollution prevention and good housekeeping for municipal operations includes the following programs:
1. Municipal Facilities Operation and Maintenance Program
2. Spill Response Program
3. MS4 Operation and Maintenance Program
4. Municipal SCM Operation and Maintenance Program
5. Pesticide,Herbicide and Fertilizer Management Program
6. Vehicle and Equipment Maintenance Program
7. Pavement Management Program
The City of Thomasville will manage, implement and report the pollution prevention and good
housekeeping BMPs as specified in Table 21 below for each required program.
Table 21: Pollution Prevention and Good Housekeeping BMPs
Permit 3.7.1: Municipal Facilities Operation and Maintenance Program
Ref. Measures to manage facilities that are owned and operated by the permittee and have the potential for generating polluted
stormwater runoff. The permittee shall maintain a current inventory of municipal facilities;perform facility inspections
and routine maintenance;establish specific frequencies,schedules,and standard documentation;provide staff training on
general stormwater awareness and imp ementing pollution prevention and good housekeeping ractices.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
30. Maintain Inventory and O&M Manual of Municipal Facilities and Operations
Document the existing inspection and 1.Document and
maintenance program for municipal maintain municipal
facilities and operations that are facility inspections, 1.Annually Permit LYes/No
determined to be potential sources of including any corrective Years 1-5
polluted runoff. action.
31. Inspect Municipal Facilities and 1. Inspect Municipal 1.Annually Permit 1.Report Number of
Operations for sources of polluted Facilities Years 1-5 facilities inspected.
runoff.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 27
Permit 3.7.2: Spill Response Program
Ref. Measures for facilities and operations that store and/or use materials that have the potential to contaminate stormwater
runoff if spilled. The permittee shall maintain written spill response procedures and train staff on spill response
rocedures.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
32. Spill Response Procedures
Maintain spill response procedures 1.Maintain City-wide 1.Annually 1.Yes/No
for municipal facilities and spill and site-specific Permit Years 1-5
operations owned and operated by the response procedures.
permittee that have been determined
by the permittee to have significant
potential for generating polluted
stormwater runoff.
33. Staff Training
Train Staff on proper procedures and 1.Conduct employee 1.Annually 1.Number of staff who
protocol to handle spills training and Permit Years 1-5 completed PPGH
document attendance. training
Permit 3.7.3: MS4 Operation and Maintenance Program
Ref. Measures to minimize pollutants in the stormwater collection system. The permittee shall provide operation and
maintenance staff training on stormwater awareness and pollution prevention,perform MS4 inspections,maintain the
collection system including catch basins and conveyances;and establish specific frequencies,schedules,and standard
documentation.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
34. O&M for municipally owned or maintained catch basins and conveyance systems
Continue to implement/and maintain 1.Inspect and maintain 1.Annually 1.Yes/No.
the O&M Program for the municipal MS4 to verify they Permit Years 1-5
storm sewer system including catch function as conduits of
basins,and the conveyance system. stormwater.
2.Review the MS4 Plan, 2.Annually 2.Yes/No.
and revise,if necessary. Permit Years 1-5
Implement inspection
and maintenance
programs documented in
the MS4 Plan.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 28
Permit 3.7.4: Municipal SCM Operation and Maintenance Program
Ref. Measures to manage municipally owned,operated,and/or maintained structural stormwater control measures(SCMs)that
are installed for compliance with the permittee's post-construction program. The permittee shall maintain a current
inventory of SCMs,perform SCM inspections and maintenance,and shall establish specific frequencies,schedules,and
documentation.
LN
A B C D
Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
35. O&M for municipally owned or maintained structural stormwater controls
Maintain an inspection,inventory, 1.Inspect and maintain 1.Annually 1.Report number of
and maintenance program for SCMs SCMs so that they are Permit Years 1-5 municipal SCMs
owned and operated by function properly as Inspected
the municipality. designed
Permit 3.7.5: Pesticide,Herbicide and Fertilizer Management Program
Ref. Measures to minimize water quality impacts from the use of landscape chemicals. The permittee shall provide routine
pollution prevention and chemical use,storage and handling training,and shall ensure compliance with permits and
a licator certifications.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
36. Pesticide,Herbicide and Fertilizer Application Management
Manage Staff Pesticide license and 1.Review staff license that 1. Annually 1.Report number of staff
follow all requirements to safely they are up to date Permit Years 1-5 with license
handle and apply pesticides,
herbicides,and fertilizers. 2.Provide training for staff 2.Annually 2.Report number of staff
on the use of chemicals Permit Years 1-5 that attended training and
e of training.
Permit 3.7.6: Vehicle and Equipment Maintenance Program
Ref. Measures to prevent and minimize contamination of stormwater runoff from areas used for municipal vehicle and
equipment maintenance and/or cleaning. The permittee shall ensure that municipal industrial facilities subject to NPDES
industrial permitting comply with those permit requirements,provide routine pollution prevention training to staff,
perform routine inspections,and establish specific frequencies, schedules,and documentation.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
37. Vehicle Washing and Maintenance Program
Document and maintain procedures 1.Maintain procedures for 1.Annually 1.Yes/No
to prevent or minimize contamination vehicle and equipment Permit Years 1-5
of stormwater runoff from all areas cleaning operations and
used for vehicle and equipment update,if necessary.
cleaning
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 29
Permit 3.7.7: Pavement Management Program
Ref. Measures to reduce pollutants in stormwater runoff from municipally owned streets,roads,and parking lots within the
permittee's corporate limits. The permittee shall implement measures to control litter,leaves,debris,particulate and fluid
ollutants associated with vehicles,and establish specific fre uencies,schedules,and documentation.
BMP A B C D
No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting
Implementation Metric
38. Streets,Roads,and Public Parking Lots Maintenance Program
Implement and maintain BMPs to 1.Evaluate options to 1.Permit Year 1. 1.Yes/No
reduce polluted stormwater runoff implement BMPs to
from municipally owned streets, reduce polluted
roads,and public parking lots within stormwater runoff from
the corporate limits as fiscally municipally owned
feasible. streets,roads,and public
parking lots.Factors for
evaluation are water
quality benefits,
technical feasibility,
safety,and fiscal
responsibility.
2.Create program for 2.Permit Year 2. 2.Yes/No
reducing polluted
stormwater runoff from
municipally owned
streets,roads,and public
parking lots.
3.Implement program for 3.Permit Years 3-5. 3.Yes/No
reducing polluted
stormwater runoff from
municipally owned
streets,roads,and public
parking lots.
DRAFT NCS000436 SWMP October 19,2023
City of Thomasville Page 30