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HomeMy WebLinkAboutNCS000408_Final SWMP_20240523 Stormwater Management Plan City of Graham NCS000408 May 23, 2024 C3Tr OF G R A H A M i ,-POIN -.iNOLq%- I Table of Contents PART1: INTRODUCTION........................................................................................................................ I PART 2: CERTIFICATION........................................................................................................................2 PART 3: 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) .......................................................................................4 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.........................................................15 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........................................21 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 Graham 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 Graham 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 NCS000408 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 Graham and located within the corporate limits of the City of Graham. In preparing this current SWMP,the City of Graham 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. NCS000408 SWMP May 23,2024 City of Graham 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. N I 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: Print Aaron Holland Name: Title: Assistant City Manager Signed this '23rd day May of 20 24 NCS000408 SWMP May 23,2024 City of Graham Page 2 PART 3: MS4 INFORMATION 3.1 Permitted MS4 Area This SWMP applies throughout the corporate limits of the City of Graham, including all regulated activities associated with the discharge of stormwater from the MS4. The map below shows the corporate limits of City of Graham as of the date of this document. Corporate Limits are shown on the Map Below in Red 3.2 Existing MS4 Mapping The current MS4 mapping includes mapping of Storm drain piping, Streams, Pumpstations, Outfall Locations and Industrial Permitted sites. y •/'vie 0 NCS000408 SWMP May 23,2024 City of Graham Page 3 Table 1: Summary of Current MS4 Mapping Percent of MS4 Area 100 % Mapped** No. of Major Outfalls* Mapped 125 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. ** Graham's entire stormwater system is mapped currently but due to rapid growth this is an ongoing task. 3.3 Receiving Waters The City of Graham MS4 is located within the Cape Fear River Basin and discharges directly into 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 Haw River 16-(10.5) WS-V;NSW Benthos Town Branch 16-17 WS-II,HQW, Fecal Coliform NSW County Home Branch(Still House 16-17-1 WS-V;NSW N/A Branch Big Alamance Creek 16-19-(4.5) WS-11, N/A H W,NSW Back Creek(Little Creek) 16-19-5 WS-V;NSW N/A Little Alamance Creek 16-19-11 WS-V,NSW Urban Stormwater Bowden Branch(Boyd Creek) 16-19-11-2 WS-V;NSW N/A 3.4 MS4 Interconnection The City of Graham's MS4 is interconnected with the NCDOT MS4 within NCDOT owned right of ways. 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 NCS000408 SWMP May 23,2024 City of Graham Page 4 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 Jordan Lake TMDL Nitrogen,Phosphorus N Y Haw River Turbidity,Fecal Coliform N Y The Jordan Lake TMDL is the subject of extensive rulemaking, of which the City of Graham complies with and will comply with future rulemaking regarding. The City is also a partner with the City of Burlington and NCDOT in the Little Alamance Creek Category 4b Demonstration Plan. That plan is outlined extensively at littlealamancecreek.com. Little Alamance Creek is impaired for stormwater runoff with an unknown pollutant. 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 Schweinitz's Flowering Plants Endangered Schweinitzil Sunflower Danus Plexippus Monarch Butterfly Insects Candidate Fusconaia Masoni Atlantic Pigtoe Clams Proposed Threatened Notropis Cape Fear Shiner Fishes Endangered Mekistocholas 3.7 Industrial Facility Discharges The City of Graham MS4 jurisdictional area includes the following industrial facilities which hold NPDES Industrial Stormwater Permits, as determined from the NCDEQ Maps&Permit Data web page. NCS000408 SWMP May 23,2024 City of Graham Page 5 Table 5: NPDES Stormwater Permitted Industrial Facilities Permit Number Owner Organization Name Facildo NCG050243 Acucote Inc Acucote Incorporated -Graham NCG080662 City of Graham City of Graham-Public Works Facility NCG081025 Waste Industries LLC GFL Alamance Hauling Facility NCG110021 City of Graham Graham WWTP NCG030016 Luxfer Gas Cylinders Luxfer Gas Cylinders NCG160229 Neyra Industries Inc Neyra Industries, Inc. NCG070071 Permatech LLC Vesuvius NCG08455 Pilot Travel Center, LLC PTL#6955 3.8 Non-Stormwater Discharges The water quality impacts of non-stormwater discharges have been evaluated by the City of Graham as summarized in Table 6 below. The unpermitted non-stormwater flows listed as incidental do not significantly impact water quality. The City of Graham 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 Graham. 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 Graham to determine whether they may significantly impact water quality. Currently runoff from car washing in The City of Graham 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 NCS000408 SWMP May 23,2024 City of Graham Page 6 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 3.9 Target Pollutants and Sources In addition to those target pollutants identified below,the City of Graham 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 Graham 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 The City of Graham is a partner in the Little Alamance Creek Category 4B Implementation Plan. The plan is available at littlealmancecreek.com and includes extensive discussions regarding potential pollutants in stormwater. NCS000408 SWMP May 23,2024 City of Graham Page 7 PART 4: STORMWATER MANAGEMENT PROGRAM ADMINISTRATION 4.1 Organizational Structure City Of Graham Organizational Chart City C;Tax City Attorneyity Engineer City M Fire Chief Co/lector Public Works Director Finance Director Police Chief Water Billing & Collection Administrator City Clerk Planning Director Table 8: Summary of Responsible Parties Position Name Phone No. Fax No. Email City Manager Megan Garner 336-570-6700 336-570-6703 mgarner(@cityofgraham.com Assistant City Aaron Holland 336-570-6700 336-570-6703 aholland6d�citvofgraham.com Manager City Clerk Renee Ward 336-570-6500 336-570-6703 rward(a)cityofgraham.com Public Works Burke Robertson 336-570-6709 336-570-6703 brobertson(a).cityofgraham.com Director Utilities Director Tonya Mann 336-578-3264 336-570-6703 tmann(d-)citvofgraham.com City Planner Cameron West 336-570-6700 336-570-6703 cwest(a)citvofgraham.com City Attorney Robert(Bob)Ward 336-228-1433 336-570-6703 law cityofgraham.com J. Bryan Coleman City Engineer Josh Johnson, P.E. (336)226-5534 (336)226-3034 josh(c�awck.com /Stormwater Manager Stormwater Janet Paith (336)226-5534 (336)226-3034 jpaith awck.com Coordinator General contacts for Stormwater program should be referred to Burke Robertson &Josh Johnson Designated Stormwater Administrator—Josh Johnson, P.E.—Contracted NCS000408 SWMP May 23, 2024 City of Graham Page 8 SWMP Component Responsible Position Staff Name Department Stormwater Program Assistant City Manager Sce Table 8 Administration Administration Stormwater Engineer SWMP Management Assistant City Manager See Table 8 Administration Stormwater Engineer Public Education& Assistant City Manager See Table 8 Administration Outreach Stormwater Manager Public Involvement& Assistant City Manager See Table 8 Administration Participation Stormwater Manager Illicit Discharge Assistant City Manager See Table 8 Administration Detection& Stormwater Engineer Elimination Construction Site Assistant City Manager See Table 8 Administration Runoff Control Stormwater Engineer Post-Construction City Manager See Table 8 Administration Stormwater Stormwater Manager Management Pollution Assistant City Manager See Table 8 Administration Prevention/Good Stormwater Engineer Public Works Housekeeping for Public Works Director Municipal Operations Utilities Director Municipal Facilities Assistant City Manager See Table 8 Administration Operation& Stormwater Engineer Public Works Maintenance Program Public Works Director Spill Response Program Assistant City Manager See Table 8 Administration Stormwater Engineer Public Works Public Works Director MS4 Operation& Assistant City Manager See Table 8 Administration Maintenance Program Stormwater Engineer Public Works Public Works Director Municipal SCM Assistant City Manager See Table 8 Administration Operation& Stormwater Engineer Public Works Maintenance Program Public Works Director Pesticide,Herbicide& Assistant City Manager See Table 8 Administration Fertilizer Management Stormwater Engineer Public Works Program Public Works Director Vehicle&Equipment Assistant City Manager See Table 8 Administration Cleaning Program Stormwater Engineer Public Works Public Works Director NCS000408 SWMP May 23,2024 City of Graham Page 9 Pavement Management Assistant City Manager See Table 8 Administration Program Stormwater Engineer Public Works Public Works Director Total Maximum Daily Assistant City Manager See Table 8 Administration Load(TMDL) Stormwater Engineer Requirements NCS000408 SWMP May 23,2024 City of Graham Page 10 Program Funding and Budget In accordance with the issued permit,the City of Graham 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 Graham funds it's Stormwater Programs through a Stormwater Fee. The City collects a flat fee of$2/month from utility users within the City Limits.For the 2021-22 fiscal year the City budgeted $70,000 for stormwater services. The City uses its budget to pay for its Water Quality Programs including its NPDES Phase 11 and Jordan Lake Programs. The City's Water Supply Watershed Inspection Program is funded through fees collected during the permitting and review process. The City has also used excess funding from the stormwater fund to fund other stormwater or water quality projects. This includes investigating drainage complaints from residents and investigating potential inflow/infiltration/exfiltration between the collections system and the MS4. 4.2 Shared Responsibility/Contracted Services The City of Graham implements 5 of the 6 minimum control measures,with the 6t'measure being construction site runoff controls which is implemented through NC DEMLR's Erosion and Sediment Control program. The City of Graham 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 Graham. The City of Graham 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 Graham. 4.3 Co-Permittees The are no other entities applying for co-permitee status under the NPDES MS4 permit number NCS000408 for the City of Graham. 4.4 Measurable Goals for Program Administration The City of Graham will manage and report the following Best Management Practices(BMPs)for the administration of the Stormwater Management Program. NCS000408 SWMP May 23,2024 City of Graham Page 11 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 1.Permit Year 1-5 1.Adequate/Inadequate adequately funded and staffed. funding in the City's Budget. Stormwater Services Contract 1. Sign contract 1.Permit Year 1 1.Yes/No 2.Review contract for all 2.Review 2.Yes/No permit required items. Permit Years 2-5 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 NCS000408 SWMP May 23,2024 City of Graham Page 12 Table 11: Program Administration BMPs 3. Annual Self-Assessment Evaluate the performance and 1.Prepare,conduct and 1.Annually 1.Yes/No effectiveness of the program document an annual Permit Year 1 —5 components at least annually.Results evaluation of the shall be used to modify the program program components. components as necessary to accomplish the intent of the Stormwater Program. 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 required 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 2.Yes/No written procedures as needed. 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 5. City's Stormwater Webpage Update and maintain the City's 1.Verify City's 1.Annually 1.Yes/No Stormwater Webpage. stormwater webpage is Permit Year 1-5 current. 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 NCS000408 SWMP May 23,2024 City of Graham Page 13 Table 11: Program Administration BMPs 6. Helpline/Hotline All stormwater related calls will be 1. Confirm hotline 1.Continuously 1.Total annual number forwarded to the Public Works number works and log Permit Year 1-5 of calls Director who will then distribute the calls. information to appropriate employees. NCS000408 SWMP May 23,2024 City of Graham Page 14 PART 5: PUBLIC EDUCATION AND OUTREACH PROGRAM The City of Graham 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 Graham 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 Graham will manage,implement,and report 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 Graham)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 NCS000408 SWMP May 23,2024 City of Graham Page 15 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 7. 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 Year 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. 8. Educational Stormwater Mailers,Brochures,and Posters Distribute Public Education Materials Distribute public 1. Annual 1. Contact Hours to identified user groups.Materials education materials at: 2. Annual 2. Contact Hours may be supplied through outside 1. public events 3. Annual 3. Number of Stormwater information sources. 2. schools 4. Annual Educational 3. mailings Materials 4. municipal Distributed. facilities 4. Number of Educational Materials Distributed. 5. NCS000408 SWMP May 23,2024 City of Graham 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 Graham 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 9. 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 10. Volunteer Stormwater Program The City will promote various 1.Hold one event per 1.Fall and Spring 1.Number of Events volunteer stormwater programs year in the community. Permit Years 1-5 annually.These may include Big Sweep,Creek Week,Adopt-A- 2 Participants per 2.Fall and Spring 2. The number of Stream programs,and Storm Drain program Permit Years 1-5 participants. Stenciling. 3. Estimate of Effectiveness of Event:Amount of Bags Collected, Number of Storm Drains Marked NCS000408 SWMP May 23,2024 City of Graham Page 17 PART 7: ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM The City of Graham 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 11. 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 12. Review Illicit Discharge Ordinance Maintain adequate ordinance or other 1.Maintain and enforce 1.Review ordinance 1.Yes/No legal authorities to public ordinances. biannually-Permit prohibit illicit connections and Update,if necessary,to Years 2&4 discharges and enforce the maintain legal approved IDDE program. authority. NCS000408 SWMP May 23,2024 City of Graham Page 18 Table 15: Illicit Discharge Detection and Elimination BMPs 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. A B C D BMP No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 13. 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 Review and update Permit Years 1-5 and tracing the sources of illicit IDDE Plan as needed. discharges and for removing the sources or reporting the sources to the State to be properly permitted. 14. Stream walks/Dry weather testing 1.Inspect 20%outfalls. 1.Annually 1.Number of outfalls and Outfall Inspections Permit Year 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 15. Establish/Maintain a tracking system for managing reported problem areas. Document the date of investigations, 1.Maintain IDDE 1.Continuously 1.Report number of any enforcement action(s)or investigation records, IDDE investigations, remediation that occurred. notices of number of NOVs violations and issued,number of compliance and other enforcement actions program records. taken,number of NOVs closed. NCS000408 SWMP May 23,2024 City of Graham Page 19 Table 15: Illicit Discharge Detection and Elimination BMPs 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 16. 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 Year 1-5 staff who completed detecting and reporting illicit attendance. IDDE training. connections and discharges. 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 17. 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 Year 1-5 public to report illicit connections address. and discharges. NCS000408 SWMP May 23,2024 City of Graham Page 20 PART 8: CONSTRUCTION SITE RUNOFF CONTROL PROGRAM In accordance with 15A NCAC 02H .0153,the City of Graham 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 Graham 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.gov The City of Graham 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. 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 18. Municipal Staff Training Train municipal staff who receive 1.Train municipal staff 1.Annually 1.Number of staff calls from the public on the protocols on proper handling of Permit Year 1-5 trained. for referral and tracking of construction site runoff construction site runoff control control complaints. complaints. 19. Construction Site Waste Management Construction material and 1.Confirm city authority 1.Permit Year 1 1.Yes/No construction waste pollutant control on construction site code. pollutant controls when pollutant is"leaving or likely leaving the site". NCS000408 SWMP May 23,2024 City of Graham Page 21 Table 17: Construction Site Runoff Control BMPs 2.Maintain Authority 2.Permit Year 2-5 2.Yes/No Maintain. NCS000408 SWMP May 23,2024 City of Graham Page 22 PART 9: POST-CONSTRUCTION SITE RUNOFF CONTROL PROGRAM The City of Graham 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 Graham 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 it's Post Construction runoff program but which includes reduced triggers and more stringent regulations. The City's post construction ordinance is contained in Section 157 of it's 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 rogress, status, and results. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 20. Standard Reporting Implement standardized tracking, 1. Track number of low 1. Continuously 1.Number of plan documentation,inspections and density and high density Permit Year 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 Year 1-5 approvals issued for low Qualifying Alternative Program plans approved. density and high density. being implemented as listed in Tables 3.Maintain a current 3. Continuously 3. Summary of number 18 and 19. inventory of low density Permit Year 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 Year 1-5 inspections. 5. Track number and 5. Continuously 5.Number of type of enforcement Permit Year 1-5 enforcement actions actions taken. issued. NCS000408 SWMP May 23,2024 City of Graham Page 23 Table 20: Post Construction Site Runoff Control BMPs 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 21. Review the Post Construction Ordinance Review the Post Construction 1.Add additional 1.Permit Year 1 1.Yes/No Ordinance for compliance with NC Measures as needed 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. 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 22. 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.Yes/No compliance with the NC DWQ BMP Measures as needed. Permit Year 1-5 Manual.Additional measures and techniques may be added to the local ordinance as they are investigated. NCS000408 SWMP May 23,2024 City of Graham Page 24 Table 20: Post Construction Site Runoff Control BMPs 23. 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.Yes/No and inspection program for local on- Measures as needed. Permit Year 1-5 site controls. 24. Maintain the education program created for land developers and the public. Provide educational materials and 1.Maintain stormwater 1. Continuous 1.Yes/No training for developers. permitting guidance Permit Year 1-5 document for developers and designers. 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 25. Inspections and long-term maintenance of Stormwater Control Measures(SCMs) Maintain an inspection and 1.Maintain and receive 1.Annually 1. Report number of maintenance plan for SCM's.Annual SCM inspection reports Permit Year 1-5 sites with SCMs SCM Inspections performed by a and follow up on the 2. Report number of qualified professional. SCM functioning status of sites where SCM maintenance and inspections will be SCM's. inspections have reviewed by the City during the been received permit cycle. 3. Report SCM enforcement activities 26. 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 Year 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. NCS000408 SWMP May 23,2024 City of Graham Page 25 Table 20: Post Construction Site Runoff Control BMPs 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 27. 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 Year 1-5 Pet Waste stations the parks. City maintains. NCS000408 SWMP May 23,2024 City of Graham 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 Graham 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 Graham 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 28. Maintain Inventory and O&M Manual of Municipal Facilities and Operations Document and maintain municipal 1.Maintain inventory of 1.Review Annually 1. Total number of facility inspections program for municipal facilities that Permit Year 1-5 facilities sources of polluted runoff. are determined to be potential sources of polluted runoff. 29. Inspect Municipal Facilities and 1.Inspect Municipal 1.Annually 1.Report Number of Operations for sources of polluted Facilities and Operations Permit Year 1-5 facilities inspected runoff. NCS000408 SWMP May 23,2024 City of Graham 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 30. 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 Year 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. 31. 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 Year 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 32. 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 Year 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 Year 1-5 Implement inspection and maintenance programs documented in the MS4 Plan. 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. BMP A B C D No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric L NCS000408 SWMP May 23,2024 City of Graham Page 28 33. O&M for municipally owned or maintained structural stormwater controls Develop and maintain an O&M 1. Create a municipal SCM 1.Annually 1.Report number of program for all municipally owned Inventory. Permit Year 1-5 municipal SCMs SCMs. 2.Inspect and maintain 2.Annually 2.Report number of SCMs so that they function Permit Year 1-5 SCMs inspected as 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 34. 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 Year 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 Year 1-5 that attended training and type 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 35. 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 Year 1-5 of stormwater runoff from all areas cleaning operations and used for vehicle and equipment update,if necessary. cleaning. NCS000408 SWMP May 23,2024 City of Graham 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 I No. Description of BMP Measurable Goal(s) Schedule for Annual Reporting Implementation Metric 36. Streets,Roads,and Public Parking Lots Maintenance Program Implement and maintain street 1.Evaluate options to 1.Permit Year 1 1.Yes/No sweeping program to reduce polluted implement BMPs to stormwater runoff from municipally reduce polluted owned streets,roads,and public stormwater runoff from parking lots within the city 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 and maintain 2.Permit Year 2-5 2. Cubic Yards of Debris street sweeping program &Pollutant Collected. for reducing polluted stormwater runoff from municipally owned streets,roads,and public parking lots. NCS000408 SWMP May 23,2024 City of Graham Page 30